Agenda packet — Santa Ana City Council, April 19, 2022 (part 5 of 7)

City Council 30 – 18 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 87 Suggested Action Change: Action OS-1.7. Public parklands requirements for larger residential projects. Update the Residential Development Fee Ordinance for Larger Residential Projects to require public parkland v1ithin a 10 minute walking distance of the new residential projects. Amend Municipal Code Chapter 34, Article VIII to require that subdivision map approvals for residential subdivisions of more than 50 parcels dedicate parkland sufficient to provide three acres of park area per 1,000 people residing in the subdivision, consistent with Policy OS-1.3. Amend Municipal Code Chapter 35, Article IV to require that pro jects including 100+ residential units that are 80 percent market-rate or more and do not require a subdivision dedicate three acres of new public parkland concurrent with the completion of and within a 0.5-mile walking radius of the new residential project, and to require non-subdivision pro jects of 50 to 99 residential units that are 80 percent market-rate or more to dedicate two acres of public parkland concurrent with the completion of and within a 0.5 mile walking radius of the project. Consider allowing developers a reduction in on site open space by giving credits for park development or the provision of private park land. Establish provisions that allow these projects to reduce all onsite private and common open space requirements by 50 percent if new public parkland is provided within a 0.5-mile walking radius and by 80 percent if the new public parkland is immediately adjacent to or on the residential project property. To the greatest extent possible, parkland created via this dedication process shall be located in parkdeficient neighborhoods and environmental justice areas. Incentivize the creation of public parks that exceed City requirements, especially within park deficient and environmental justice areas. Establish incentives for coordination between two or more residential project (of any size) to create larger and/or more centralized public park space, such as a housing density bonus for the provision of open space as a public benefit and leveraging of Residential Development fees to partner with developers to create public open space.

Recommended Action Change: OS-1.7: Public Parklands Requirements for Larger Residential Projects. Update the Residential Development Fee Ordinance for large residential projects, which include projects of 100 residential units or more, to require public parkland within the City limits and a 10-minute walking distance of the new residential projects.

Action has been revised to state the size of projects that would quality under this action, but does not recommend providing the details included in the community comment. Specificity, such as in the suggested language, is too specific to include in the General Plan and would be addressed where feasible through the development of the Parks Master Plan as subsequent revisions to the City's Acquisition and Development Ordinance.

Collaborative Letter
(MPNA, OCEJ,
THRIVE, & Rise Up
Willowick) received

3.14.2022 / Rise Up
Willowick letter dated

9.15.2021
88 Suggested Policy Change: Policy OS-1.11: Funding Sources: Explore and pursue all available funding, including nontraditional funding sources, for park acquisition, facility development, programming, and maintenance of existing and new parks, in order to increase park investment per resident and meet the City's Park Standard of three acres per 1,000 residents (Policy OS-1.3). Set aside park funding to have monies on hand to acquire and develop parkland when opportunities arise and to leverage grant options.

Recommended Policy Change: OS-1.11: Funding Sources: Explore and pursue all available funding, including nontraditional funding sources, for park acquisition, facility development, programming, and maintenance of existing and new parks, to increase park investment per resident and meet the City's Park Standard of 3 acres per 1,000 residents. Set aside park funding to have monies on hand to acquire and develop parkland when opportunities arise and to leverage grant options.

Action has been modified to address community comment and new recommended goal of three (3) acres per 1,000 residents.

Collaborative Letter
(MPNA, OCEJ,
THRIVE, & Rise Up
Willowick) received

3.14.2022 / Rise Up
Willowick letter dated

9.15.2021
89 Suggested New Policy: Policy OS-1.14: Park Investment Per Resident. Increase per-resident investment in park maintenance and upgrades in order to ensure equitable access to well- maintained neighborhood parks for all City residents, and increase per-resident investment on new park acquisition and development to a level sufficient to achieve the City's Park Standard of three acres per 1,000 residents (Policy OS- 1.3).

Funding and allocation priorities are determined by the City through the budget process. Collaborative Letter (MPNA, OCEJ,
THRIVE, & Rise Up
Willowick) received

3.14.2022 / Rise Up
Willowick letter dated

9.15.2021

Page 17 ends

City Council 30 – 19 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 90 Suggested Language: Rise Up Willowick recommends a strong commitment to the reuse of Willowick Golf Course for the purpose that this community has consistently wanted: parkland and affordable housing. The General Plan should advance this commitment by creating a separate designation for Willowick in Figure LU-4 and Table LU-3, "Open Space/Affordable Housing (OS-AH)." The OS-AH designation would allow open space and park uses, along with a limited amount of housing deedrestricted to be offered at cost below market rates. It would allow a density of 30 dwelling units/acre, and allow housing and ancillary improvements to occupy up to 12 acres of the Willowick site. It would have a typical maximum height of four stories.

The General Plan description of the designation would read as follows: The Open Space-Affordable Housing designation ensures that the Willowick Golf Course site is developed to help meet Santa Ana’s needs for parkland and affordable housing. As of the adoption of this General Plan Update, the City of Garden Grove owns Willowick, but intends to close the golf course and redevelop the site. This offers Santa Ana a rare opportunity to guide the development of a large tract in the West Santa Ana Boulevard Focus Area, very close to Cesar Chavez Campesino Park and single-family home neighborhoods (designated LR-7 and LMR-11) to the north and northwest Open Space-Affordable Housing allows for the entire site to be kept in open space, with a wide variety of public uses available, including passive parkland, playgrounds, ballfields, and park-related structures. It also allows, but does not require, development of a portion of the site with relatively dense housing, which must be restricted to units provided at rates affordable to lower income households pursuant to Health and Safety Code Section 50079.5. Such housing may occupy no more than 12 acres and must be in a contiguous area (not scattered among parkland). The height and density limits ensure that any housing will be constructed at a scale to provide a transition from the adjacent single-family-home neighborhoods to the new parkland, while maintaining the open space character of the majority of the acreage.

N/A The General Plan update land use designation of Willowick Golf Course is Open Space and is not proposing any changes to this designation. This land is not owned by the City. Should the City Council desire to make changes to its designation, it should be addressed as a separate General Plan Amendment.

Rise Up Willowick
letter dated

3.18.2022
91 Suggested New Policy: Policy LU-XX: Support, with City funds as necessary and prudent, and encourage development on the Willowick Golf Course site consistent with the OS-AH designation, which would bring substantial public benefit. Change the land's designation or allowed uses with caution and only upon a finding, supported by strong evidence, that the proposed new use will provide equal or greater benefits to the city and people of Santa Ana.

Rise Up Willowick
letter dated

3.18.2023
92 Suggested Action Change: Action S-2.4: Lead contamination - Work with local and regional partners, such as Orange County Environmental Justice, Orange County Health Care Agency and University of California at Irvine Public Health, to understand the prevalence, sources, and implications of lead contamination of soil across Santa Ana. Collaborate with such local and regional partners and environmental justice stakeholders in proposing, selecting, and implementing solutions to mitigate (i.e., remove, cover, and remediate) hazardous lead-contaminated soils in the city in a manner that includes benchmarks (including but not limited to time benchmarks) and routine monitoring of soil lead levels to measure and track effectiveness of selected programs.

Recommended Action Change: S-2.4: Lead Contamination. Work with state, local and regional partners, such as the Department of Toxic Substances Control, South Coast Air Quality District, Orange County Environmental Justice, Orange County Health Care Agency and University of California at Irvine Public Health, to understand the prevalence, sources, and implications of lead contamination of soil across Santa Ana. Collaborate with such state agencies, local and regional partners and environmental justice stakeholders in proposing, selecting, and implementing measures to mitigate (i.e., remove, cover, and remediate) hazardous lead-contaminated soils in the city in a manner that includes key benchmarks and routine monitoring of soil lead levels to measure and track effectiveness of selected approach.

Action has been modified to address community comment. Alana M.W. LeBron, et.al., UCI letter
dated March 11, 2022

Page 18 ends

City Council 30 – 20 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 93 Suggested Agency/Time Frame Change: Action S-2.4: PBA & CDA / Target Year: 2022 Ongoing
Recommended Agency/Time Frame Change: PBA/CDA / Ongoing The comment is noted and is recommended to be included in its entirety. Alana M.W. LeBron, et.al., UCI letter
dated March 11, 2022
94 Suggested Action Change: Action CM-3.8: Environmental soil and human health screening measures - Collaborate with Orange County Health Care Agency and local stakeholders, such as Orange County Environmental Justice and UC Irvine Public Health, in efforts to provide increased healthcare services (i.e., blood lead testing, treatment) for residents of environmental justice communities, including undocumented, uninsured, and under-insured residents living in neighborhoods impacted by soil lead contamination and to agree upon locally acceptable and enforceable safety thresholds for lead exposure and contamination; collaborate to advocate for adjustment of the County and State policies for health and environmental screening levels to promote healthy outcomes related to lead contamination as recommended by health experts.

Recommended Action Change: CM-3.8: Environmental Soil and Human Health Screening.

Collaborate with Orange County Health Care Agency and local stakeholders, such as Orange County Environmental Justice and UC Irvine Public Health, in efforts to provide increased healthcare services (i.e., blood lead testing, treatment) for residents, especially those that reside in environmental justice communities. Additionally, collaborate to advocate for adjustment of the County and State policies for health and environmental screening levels to promote healthy outcomes related to lead contamination as recommended by health experts.

Action has been modified to reflect the spirit of the comment and to be inclusive of all persons residing in Santa Ana regardless of group affiliation, legal status, or insurance type or lack there of. Additionally, Orange County Health Care Agency (OCHCA) programs do not make a distinction of anyone's legal or insurance status when providing services related to lead.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022
95 Suggested New Action: Action CN-XX: Lead contamination - Work with local and regional partners, such as Orange County Environmental Justice, Orange County Health Care Agency and University of California at Irvine Public Health, to understand the prevalence, sources, and implications of lead contamination of soil across Santa Ana. Collaborate with such local and regional partners and environmental justice stakeholders in proposing, selecting, and implementing solutions to mitigate (i.e., remove, cover, and remediate) hazardous lead-contaminated soils in the city in a manner that includes benchmarks (including but not limited to time benchmarks) and routine monitoring of soil lead levels to measure and track effectiveness of selected programs.

Action addressing lead contamination already exists in the Safety Element (S-2.4) and need not be duplicate in different.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022
96 Suggested Action Change: Action LU-3.6: Lead paint abatement - Coordinate with County of Orange Health Care Agency and community organizations to strengthen local programs and initiatives to eliminate lead-based paint hazards, with priority given to residential buildings located within environmental justice area boundaries. When conducting lead paint abatement, ensure that workers have proper physical protections; safeguard other areas of the abated building or residence from lead or other toxins that may be re-suspended in the air, soil, and dust; provide support for temporary relocation of residents during abatement process; and monitor lead levels for workers, residents, and the indoor and outdoor environment of the residence that was abated.

N/A Workplace safety is already regulated by Cal/OSHA and is outside of the City's regulatory authority.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022
97 Suggested New Action: Action LU-XX: Protect workers’ health during lead paint abatement - Provide appropriate knowledge and protective gear and equipment for workers certified as lead renovators when conducting renovation activities. Ensure that trained workers have reasonable workloads and time frames for completion of renovation activities.

N/A Workplace safety is already regulated by Cal/OSHA and is outside of the City's regulatory authority.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022
98 Suggested Action Change: Action LU-3.18: Renovations and lead prevention - Require contractor training and/or certification for safe work practices to conduct residential renovations for pre-1978 structures that may contain existing lead paint.

Existing Action: LU-3.18: Renovations and Lead Prevention. Evaluate the feasibility of requiring contractor training and/or certification for safe work practices to conduct residential renovations for pre-1978 structures that may contain existing lead paint.

Training for contractors should only be implemented once full analysis of costs and benefits to the community have been thoroughly analyzed and already a part of the draft action.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022

Page 19 ends

City Council 30 – 21 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 99 Suggested Action Change: Action LU-3.19: Promote health - Partner with local organizations (e.g., OC Health Care Agency, Latino Health Access, Santa Ana Unified School District, and the Coalition of Community Health Centers, Orange County Environmental Justice, and other environmental justice organizations) to increase blood lead testing, outreach, education, and referral services through a ‘promotora’ or community peer outreach model that addresses the root causes of elevated blood lead levels impacting Santa Ana residents, with special focus in environmental justice communities and for children living in pre-1978 housing. Follow-up with households regarding the results of blood lead tests, discuss the meaning of the tests results, and share resources that individuals and households can leverage to address and prevent lead exposures.

Recommended Action Change: LU-3.19: Promote Health. Partner with local organizations (e.g., OC Health Care Agency, Latino Health Access, Santa Ana Unified School District, Garden Grove Unified School District, Orange County Environmental Justice, and the Coalition of Community Health Centers) to increase blood lead testing, outreach, education, and referral services through a ‘promotora’ or community peer outreach model that addresses the root causes of elevated blood lead levels impacting Santa Ana residents, with special focus in environmental justice communities and for children living in pre-1978 housing.

Action has been revised to include the Garden Grove Unified School District and Orange County Environmental Justice, but does not recommend detailing the types of services provided in the community comment, nor does it believe it is within the City's role to provide medical consultations and advice. Whatever service the City will be providing, should be left to be explored and agreed upon through the partnership with the listed agencies and groups through implementation of this draft action.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022
100 Suggested Action Change: Action LU-3.20: Safe housing - Require all residential rehabilitation projects that use local, or HUD federal funds to comply with the Lead Safe Housing Rule, to remove lead paint hazards, depending on the nature of work and the dollar amount of federal investment in the property. Ensure that low-income residents and renters are able to participate in remediation and abatement programs. Provide protection from retaliation by landlords for renters seeking lead assessments and/or remediation. Remove lead-soldered joints when replacing older joints.

N/A Tenant protections are addressed by state law. The City of Santa Ana has taken additional steps to ensure tenants are protected through its Just Cause Eviction and Rent Stabilization ordinances. Additionally, Action HE-52 in the proposed Housing Element Update includes holding annual small apartment managers’ workshop to train and educate property owners, HOAs, property managers, and tenants of best practices in property management, neighborhood safety, and landlord/tenant responsibilities; and partnering with legal assistance organizations to provide legal clinics for tenants on tenants’ rights and recourse for intimidation and unjust evictions. Additionally, Action LU-3.28: Tenant Protections will provide information to residential tenants regarding Landlord Tenant Laws in the State, such as AB 1481, and Santa Ana's Just Cause For Tenant Eviction and Rent Stabilization ordinances that provide protections against evictions for those who seek action to improve substandard housing and hazardous conditions. Together, the proposed actions already in the drafts will provide the protections being suggested.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022
101 Suggested Action Change: Action LU-3.21: Prevention education - Collaborate with local organizations such as Orange County Health Care Agency and State Environmental Protection Agency and community-based environmental justice organizations and identify funds to create a Santa Ana Prevent Lead Poisoning Education Program, with special focus on disadvantaged communities and pre-1978 housing stock. Implement mechanisms for local community-based environmental justice organizations to guide the Santa Ana Prevent Lead Poisoning Education Program and provide annual reports regarding fund activities and allocation of resources.

Recommended Action Change: LU-3.21: Prevention Education. Collaborate with local organizations such as Orange County Health Care Agency, State Environmental Protection Agency, and community-based environmental justice organizations to identify funds and create a Santa Ana Prevent Lead Poisoning Education Program, with special focus on disadvantaged communities and pre-1978 housing stock.

Action has been revised to include suggested edit, but does not include the specificity suggested by community comment for program. That level of program specificity will be addressed once the program is developed and funding for its implementation secured.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022
102 Suggested Action Change: Action LU-3.22: Public health outcomes. Support the Orange County Health Care Agency in their role in investigating public complaints regarding lead hazards, through investigation of residentidentified concerns and enforcement of local housing and soil standards to assure healthy outcomes, including for individuals and households presenting with concerns about lead exposures and/or with confirmed blood lead levels of >3.5ug/dL, which the Centers for Disease Control and Prevention indicates as the threshold for follow-up and case management based on the latest recommendation on May 14, 2021.

Recommended Action Change: LU-3.22: Public Health Outcomes. Support the Orange County Health Care Agency in their role in investigating public complaints regarding unsafe lead work practices and lead hazards wherein children are present, through enforcement of local housing standards to assure healthy outcomes including for individuals and households presenting with concerns about lead exposure and/or with confirmed lead levels of >3.5 ug/dL, which the Centers for Disease Control and Prevention indicates as the threshold for follow-up and case management in children.

Action has been revised to include suggested language. Alana M.W. LeBron, et.al., UCI letter
dated March 11, 2022

Page 20 ends

City Council 30 – 22 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 103 Suggested Action Change: Action LU-3.26: Health conditions - Work with Orange County Health Care Agency and local stakeholders including Orange County Environmental Justice and UC Irvine Public Health to identify baseline conditions for lead contamination in Santa Ana, routinely monitor indicators of lead contamination, and measure positive outcomes. Collaborate with these organizations to secure grant funds for soil testing, remediation (i.e., bioremediation, covering, removing), and prevention activities for residential properties in proximity to sites identified with high soil lead levels, with a focus on Environmental Justice census tracts. Publicly report findings from regular monitoring of soil lead levels and remediation and prevention activities.

Recommended Action Change: LU-3.26: Health Conditions. Work with state agencies including Department of Toxic Substances Control and South Coast Air Quality Management District, Orange County Health Care Agency, and local stakeholders including Orange County Environmental Justice and UC Irvine Public Health to identify baseline conditions for lead soil and air contamination in Santa Ana, routinely monitor indicators of lead suchcontamination, and measure positive outcomes. Collaborate with these organizations to secure grant funds for soil and air testing, remediation (e.g., bioremediation, covering, removing, air filtration), and prevention activities for residential properties in proximity to sites identified with high soil lead levels of soil pollution (including sites identified with soil lead levels of 80 ppm or higher), and air pollution with a focus on communities disproportionately affected by soil contamination.

Action has been revised to include suggested language, but does not include addition of new sentence at the end of action. Action CN-1.10 already addresses community comments related to making any environmental hazard or site history information public through publishing such reports on the Environmental Quality webpage (webpage is proposed as part of Action CN1.10). Per March 28, 2022 roundtable, new revisions related to soil and air included in response to MPNA comments to broaden collection of baseline conditions. Reference to 80 ppm added in response to OCEJ comments in context of pursuing grant funding.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022
104 Suggested Action Change: Action LU-3.29: Development site history - Update the City’s Development Review application process to require developers to provide information regarding the prior use of the site and history of hazardous materials on the property, in order to identify potential for site contamination from hazardous materials or soil lead contamination to be remediated. Make development site history publicly accessible.

N/A Making development project related documents is vital to maintaining a transparent development process. As such, and as already required by the City's Sunshine Ordinance, development projects are required to create project specific webpages where plans, reports, and renderings are published and available for public review. If the draft General Plan Update is approved and development site history reports are required, reports generated will be posted to the project webpage like the other documents. Suggested language is not needed as making such data publicly available is already required.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2022
105 Suggested Action Change: Action HP-1.5: Historic design standards - Update historic design standards for preserving historic setting and context, incorporating best practices related to landscape design, front yard fences, other property features, and remediation of lead-based paint and leadcontaminated soil.

N/A Action HP-1.5 is strictly related to design. While lead contamination is an important issue facing Santa Ana communities, it is not germane to this actions and is already being addressed through other policies and actions such as action LU-3.6 Lead Paint Abatement and action S2.4 Lead Contamination.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2023
106 Suggested Action Change: Action LU-4.3: Public improvements in activity nodes and focus areas - Create a public realm plan for each activity node and focus area to establish a unified vision for long-term improvements to streets, sidewalks, plazas, other public spaces, and placemaking elements. Identify soil contamination reduction opportunities and other public improvement priorities and pilot projects for each focus area. [Sic ] Program priority improvements and pilot projects into the City's Capital Improvement Program.

Suggested Language, LU-4, IA 4.7: Construction improvements. Identify best practices and communication tools to reduce soil contamination and monitor mitigation measures and oversight of private and public construction improvements to protect the soil, health and safety of workers, the community, and the soil, with focus on environmental justice areas.

Recommended Action Change: LU-4.3: Public Improvements in Activity Nodes and Focus Area.

Create a public realm plan for each activity node and focus area to establish a unified vision for longterm improvements to streets, sidewalks, plazas, other public spaces, and placemaking elements.

Identify public improvement priorities and pilot projects for each focus area and include them in the City's Capital Improvement Program. Program priority improvements and pilot projects into the City's Capital Improvement Program
Soil contamination reduction is an important issue facing Santa Ana communities. As such, there are numerous policies and actions specific to that issue. Augmenting soil contamination to this action, which is to formulate a vison and plan for public improvements at activity nodes, is not germane or necessary. Additional edits have been added to action for clarity.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2024

Page 21 ends

City Council 30 – 23 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 107 Suggested Action Change: Action CN-1.10: Environmental Justice Office Interagency Team - Establish an environmental justice office with at least one public health expert on staff to ensure capacity to play a leadership role in implementation of policy, implementation, and decisions involving environmental quality and environmental justice issues; to coordinate across agencies and engage residents to implement environmental justice aspects of the General Plan and quality interagency team to evaluate, monitor, and make recommendations to address air quality and environmental hazard issues, with a special focus on environmental justice areas; publish results and information on the City’s website through a dedicated Santa Ana Environmental Quality web page.

Recommended New Action: CM-3.9: Environmental Justice Staff. Identify funding and hire a fulltime Environmental Justice staff member to collaborate with the community to guide the implementation of the environmental justice policies and actions including community outreach, collaboration on environmental health studies, pursuing grants, and coordination with federal, state, and local agencies regarding environmental concerns in the City. Agency: CMO/PBA and Target Year: 2022.

The community comment is in alignment with comments provided by members of the City Council. Staff has prepared a recommended action to identify funding and hire a full-time EJ staff person per Council's input. Action revised in response to OCEJ comment that implementation of EJ policies and actions should be a collaboration and guided by the community.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2025
108 Suggested Action Change: Action LU-3.25: Engage EJ Communities - Work with community serving organizations, neighborhood leaders, and residents to form an Environmental Justice Office with at least one public health expert on staff to ensure capacity to play a leadership role in implementation of policy, implementation activities, and decisions involving environmental quality and environmental justice issues and to develop ongoing EJ Community Engagement programs for existing and new disadvantaged EJ communities, including multilingual communication protocols. Host biannual or quarterly Roundtable meetings with local stakeholders to guide and evaluate implementation of environmental justice policies.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2026
109 Suggested Action Change: Action CN-1.1: Public Education - Augment existing outreach programs to improve public awareness of State, regional and local agencies’ roles and resources to identify, monitor, and address air quality and other environmental hazards in the community; to provide regular reports to residents and environmental justice stakeholders that identify air quality and other environmental hazards as well as strategies for risk mitigation; and to allow space for community members to raise concerns about heretofore unidentified environmental health issues and environmental hazards in their neighborhoods.

Recommended Action Change: CN-1.13: Community Survey On Health Lifestyles. Plan for and conduct a community survey of residents every two years related to community health, pollution, parks, community engagement, and community services; with focused outreach for environment justice concerns and priority areas. Report findings of survey through the various media platforms and utilize input to inform periodic evaluation and update of General Plan.

The intent of the draft public education action is to improve public awareness of state, regional, and local agencies' roles and resoures. Action CN-1.13 provides an opportunity for community members to raise community health, pollution concerns, parks, service needs in their neighborhood. The timeframe of the survey has been revised to every two years. Two years will provide the needed time to formulate surveys, provide sufficient time to respond, collect data, analyze data, report findings, and formulate actions to address feedback. Through proposed actions, such as CN-1.10, results of surveys, analysis, and outcomes will be publicly accessible through the Environmental Quality webpage.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2027
110 Suggested Action Change: Action CN-1.13: Community survey on healthy lifestyles - Plan for and conduct a community survey of residents related to community health, air quality, parks, and community services; with focused outreach for environment justice concerns and priority areas (tie into other City efforts like Strategic Plan, park and recreation planning, community benefits, etc.). Collaborate with environmental justice organizations to design and interpret community survey findings and ensure that residents have several options for how to complete the survey (e.g., online, in-person, phone). Make surveys and summaries of survey findings available in multiple languages.

Recommended Action Change: CM-1.2: Community Conservation. Plan for and conduct a community survey every two years related to community health, pollution concerns, parks, community engagement, and community service needs, with focused outreach to environmental justice priority areas utilizing various platforms, such as social media and school events, to encourage substantial survey participation.

The intent of the draft Action is to obtain continually receive feedback from the community and is recommending conducting a targeted EJ survey that focuses on community health, pollution concerns, parks, service needs and City community engagement best practices. The timeframe has been revised to every two years. Two years will provide the needed time to formulate surveys, provide sufficient time to respond, collect data, analyze data, report findings, and formulate actions to address feedback. As previously mentioned, the Environmental Quality webpage proposed by action CN-1.10 will be the home of such survey results and summaries.

Alana M.W. LeBron,
et.al., UCI letter
dated March 11, 2028

Page 22 ends

City Council 30 – 24 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 111 Suggested Action Change: Action CN-1.14: Expanded interactions - Conduct regular meetings organized by City staff and invite decision-makers in neighborhoods within environmental justice area boundaries. In these meetings residents, community organizations, and businesses should be given a platform to easily communicate their unique issues and needs, as well as their recommendations on how best to implement environmental health, and environmental justice policies. Include a language interpreter(s) at these meetings so that all residents can engage. Ensure that these meetings bring together residents and multiple community-based organizations whose work focuses on environmental justice.

Recommended Action Change: CN-1.14: Expanded Interactions. Identify opportunities to expand attendance and support neighborhood associations and community groups to hold regular meetings with City staff and decision-makers in neighborhoods within environmental justice communities, so that residents, community organizations, and businesses can communicate their unique issues and needs, as well as their recommendations on how best to implement environmental quality, environmental health, and environmental justice policies. Arrange for language interpretation services as needed at these meetings so that all residents can participate.

Action has been revised to address comment. Alana M.W. LeBron, et.al., UCI letter
dated March 11, 2029
112 Suggested Policy Change: Policy PS-2.7: Staffing Level - Maintain Increase staffing levels for sworn peace officers, fire fighters, emergency medical responders, code enforcement, and civilian support staff to provide quality services and maintain an optimal response time citywide, as resources become available.

Recommended Policy Change: PS-2.7: Staffing Level. Increase staffing levels for sworn peace officers, fire fighters, emergency medical responders, code enforcement, and civilian support staff to provide quality services and maintain an optimal response time citywide, as resources become available.

The comment is noted and is recommended to be included in its entirety. City Council 113 Suggested Policy Change: Policy M-2.1: Interstate Freeways - Support Caltrans and OCTA efforts to modernize and improve freeways by improving safety, capacity, convenience of access, and operational efficiencies, while addressing impacts to neighborhoods.

Recommended Policy Change: M-2.1: Interstate Freeways. Support Caltrans and OCTA efforts to improve freeway safety, while addressing impacts to neighborhoods.

The comment is noted and is recommended to be included in its entirety. City Council 114 Suggested Policy Change: Policy M-2.2: Transit Services - Support OCTA, Caltrans, and other Work with regional and local transportation providers to enhance existing transit services entities to provide residents, workers, and visitors with safe, affordable, accessible, convenient, reliable, and attractive transit services.

Recommended Policy Change: M-2.2: Transit Services. Support OCTA, Caltrans, and other regional and local transportation providers to enhance existing transit services to provide residents, workers, and visitors with safe, affordable, accessible, convenient, reliable, and attractive transit services.

The comment is noted and is recommended to be included in its entirety. City Council 115 Suggested Policy Change: Policy M-4.5: Land Use Development Design - Ensure that building placement and design features create a desirable and active streetscape, by prioritizing pedestrian access directly from the street and placing parking lots to the rear of a development site.

Recommended Policy Change: M-4.5: Land Use Development Design. Ensure that building placement and design features create a desirable and active streetscape, by prioritizing pedestrian access directly from the street and placing parking lots to the rear of a development site.

The comment is noted and is recommended to be included in its entirety. City Council 116 Suggested Action Change: Action M-1.2: MPAH - Coordinate with external agencies to ensure the OCTA Master Plan of Arterial Highways accommodates current and future demand for all users while prioritizing the safety of people utilizing non-automobile modes of transportation.

Recommended Action Change: M-1.2: MPAH. Coordinate with external agencies to ensure the OCTA Master Plan of Arterial Highways accommodates current and future demand for all users while prioritizing the safety of people utilizing non-automobile modes of transportation.

The comment is noted and is recommended to be included in its entirety. City Council 117 Suggested Language: Change the first sentence of Page OS-1 to read as follows: The purpose of the Open Space Element is to identify, and preserve, and add open space areas that provide value to the community and enrich the quality of life.

Recommended Revision to Text: The purpose of the Open Space Element is to identify, preserve, and add open space areas that provide value to the community and enrich the quality of life.

The comment is noted and is recommended to be included in its entirety. City Council 118 Suggested Policy Change: Policy OS-1.3: Park Standard - Establish and maintain public parks, open space, and recreation requirements for new residential and nonresidential development to provide sufficient opportunities for Santa Ana residents and visitors. Attain a minimum of two three acres of land per 1,000 persons residing in the City of Santa Ana.

Recommended Policy Change: OS-1.3: Park Standard. Establish and maintain public parks, open space, and recreation requirements for new residential and nonresidential development to provide sufficient opportunities for Santa Ana residents and visitors. Attain a minimum of 3 acres of land per 1,000 persons residing in the City of Santa Ana.

The comment is noted and is recommended to be included in its entirety. City Council 119 Suggested Action Change: Action OS-1.16: Acquisitions to meet park standard.

Using the Park Master Plan as guidance, identify and acquire property within the City for park and open space use which will focus on bringing the park and recreation system to 2 3 acres of land per 1,000 residents with a plan to keep pace with future urban growth.

Recommended Action Change: OS-1.16: Acquisitions to Meet Park Standard. Using the Park Master Plan as guidance, identify and acquire property within the City for park and open space use which will focus on bringing the park and recreation system to 3 acres of land per 1,000 residents with a plan to keep pace with future urban growth.

The comment is noted and is recommended to be included in its entirety. City Council

Page 23 ends

City Council 30 – 25 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 120 Suggested Agency/Time Frame Change: Action S-2.5: PBA & CDA / Target Year: 2022 Ongoing
Recommended Agency/Time Frame Change: Action S-2.5: PBA & CDA / Target Year: Ongoing The comment is noted and is recommended to be included in its entirety. City Council 121 Suggested New Action: Add an Implementation Action that establishes a permanent Environmental Justice staff person whose responsibilities are to make sure that the goals and implementation actions related to improving the environment for our communities are being implemented and followed through, such as following through on a truly collaborative process to identify solutions to address lead contaminated soil, and coordinating with State agencies, such as AQMD, DTSC, etc. to make sure that they are following through on complaints filed on offenders here in Santa Ana and that those agencies are not issuing an overconcentrated amount of pollution-producing permits.

The community comment is in alignment with comments provided by members of the City Council. Staff has prepared a recommended action to identify funding and hire a full-time EJ staff person per Council's input.Action revised in response to OCEJ comment that implementation of EJ policies and actions should be a collaboration and guided by the community.

City Council
122 Recommended Agency/Time Frame: Action CM-3.9: CMO & PBA / Target Year: 2022. City Council 123 Suggested Action Change: Action LU-2.7: Fiscal Impact Model - Create Develop a project-level fiscal impact analysis model and that incorporates the appropriate mix of land uses to achieve fiscal sustainability, or at minimum, requirements that new development be fiscally neutrality or beneficial to the City into the development process to make informed land use decisions.

Recommended Action Change: LU-2.7: Fiscal Impact Model. Develop a fiscal impact analysis model that incorporates the appropriate mix of land uses to achieve fiscal sustainability, or at minimum, fiscal neutrality to make informed land use decisions. Require the completion of this analysis in mixed-use land use designations and in proposed conversion of commercial uses to residential or mixed-use projects.

This is a Staff revision to clarify the intent of the fiscal impact mode and its applicability. Staff 124 Suggested Action Change: Action LU-4.8: Mixed Use Lifestyles - Explore establishing Establish and implement thresholds in the Zoning Code to identify require minimum percentage of commercial uses to be included in mixed use land use designations, as supported by economic and fiscal studies and in proposed conversion of commercial uses to residential or mixed use projects.

Recommended Action Change: LU-4.8: Mixed Use Lifestyles. Establish and implement thresholds in the Zoning Code to require minimum percentage of commercial uses to be included in mixed-use land use designations and in proposed conversion of commercial uses to residential or mixed-use projects.

Staff is proposing these changes to clarify the intent of this action and its applicability to certain projects.

Staff
125 There are no provisions for the City to engage in soil-lead testing in residential neighborhoods, and no clear process or agreed upon safety thresholds for identifying lead contaminated properties.

Recommended Action Change: S-2.4: Lead Contamination. Work with state agencies including Department of Toxic Substances Control and South Coast Air Quality Management District, local and regional partners, such as Orange County Environmental Justice, Orange County Health Care Agency and University of California at Irvine Public Health, to understand the prevalence, sources, and implications of lead contamination of soil across Santa Ana. Collaborate with such state agencies, local and regional partners and environmental justice stakeholders in proposing, selecting, and implementing measures to mitigate (i.e., remove, cover, and remediate) hazardous lead-contaminated soils in the city in a manner that includes key benchmarks and routine monitoring of soil lead levels to measure and track effectiveness of selected approach.

Action has been modified to address community comment. Patricia Flores, OCEJ letter dated February
15, 2022

Page 24 ends

City Council 30 – 26 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 126 While implementation Action 2.4 of the Safety Element expresses a commitment to working with our organization to understand the prevalence of environmental lead contamination in Santa Ana and to proposing solutions and measurements of effectiveness, there is not an actual expressed commitment to remediating the lead. What's more, the timeline limits the action to 2022--with a problem as widespread as soil-lead contamination, on year is not enough time to effectively address the crisis.

Action has been modified to address community comment. Patricia Flores, OCEJ letter dated February
15, 2022
127 There is no commitment to collaborating with the Orange County Health Care Agency to provide healthcare services for undocumented and uninsured residents living in neighborhoods impacted by soil- lead contamination.

Recommended Action Change: CM-3.8 - Environmental Soil and Human Health Screening.

Patricia Flores, OCEJ
letter dated February
15, 2022
128 Accessibility of Public Comment: MPNA requests that residents be able to speak promptly and early on in City Council Meetings.

N/A This comment/suggestion does not relate to the GP Update, rather, protocols for City Council meetings.

MPNA Attachment III,

2.18.22 129 Meaningful Consideration of Public Comment: MPNA requests that public comments be taken seriously by Council members. Ideally, the City partners with the community in decision-making, including the development of alternatives and identifying solutions.

N/A This comment/suggestion does not relate to the GP Update, rather, to how City Council members communicate their decision making process in relation to public comments.

MPNA Attachment III,

2.18.22 130 Community Meetings MPNA requests that the City hold EJ Community Meetings twice each year. a) The EJ Community Meetings should focus on educating the community about environmental issues in their neighborhoods, engaging communities, and obtaining feedback for future and concurrent city planning goals.

Action has been modified to reflect the spirit of the edits. MPNA Attachment III,

2.18.22 131 Roundtable Meetings. MPNA requests that the City hold Roundtable Meetings with EJ community leaders, Government Agencies, and City Officials throughout the year. a) This will increase communication, accountability, and transparency between residents and government agencies. b) Agencies should include AQMD, DTSC, and OC Public Health. c) Experts from UC Irvine and representatives of SAUSD should be included. d) City officials must be present and should provide public health updates and compliance issues.

Existing Action: CN-1.10: Interagency Team. Establish an environmental quality interagency team to evaluate, monitor, and make recommendations to address air quality and environmental hazard issues, with a special focus on environmental justice areas. Publish results and information on the City’s website through a dedicated Santa Ana Environmental Quality webpage.

The Draft General Plan contains various policies and implementation actions related to increasing community engagement and participation regarding environmental justice issues.

Existing Action CN-1.10 will establish an interagency team to evaluate, monitor, and make recommendations to address EJ related issues. Through the formulation of this team and the environmental justice staff person proposed under new action CM-3.9, details such as frequency of meetings, workshops, outreach, and participants will be analyzed and developed.

MPNA Attachment III,

2.18.22 132 Progress Reports. City officials and attending agencies should provide progress reports with specific metrics for how pollution and contamination is being addressed and resolved in EJ communities during EJ Community Meetings and Roundtable Meetings.

Existing Action: CM-3.3: Health Metrics. Engage with the Orange County Health Care Agency and other stakeholders to monitor key health indicators to measure the success of the outcome of General Plan policies and the implementation plan, including reduction in incidence in asthma and low birth weight of infants.

Action CM-3.3 Health Metrics provides a mechanism by which city staff will engage with Orange County Health Care Agency to monitor health indicators to track the progress and effectiveness of related actions. Further, implementation of Action CN-1.10 Interagency Team will create evaluation and monitoring team and webpage to publicize data related to health metrics and other environmental health related data.

MPNA Attachment III,

2.18.22

Page 25 ends

City Council 30 – 27 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment

ENVIRONMENTAL RISK & REMEDIATION
133 Clearer data visualizations for EJ impacts: MPNA requests a better understanding of the cumulative and overlapping environmental impacts on EJ communities at risk of pollution exposure. a) Understandable visuals help communicate the gravity of EJ issues in each community to residents. b) Residents should know the City understands the extent of the pollution problem, and is addressing the EJ issues residents face. c) A clear understanding between residents and City officials provides a baseline for measuring progress on remediation goals.

Through the collaboration of local and regional stakeholders, community groups and the City (proposed Action CN-1.10 Interagency Team) and increased participation in community meetings, additional mapping tools to assist with communication, visualization, and outreach will be developed in accordance with community needs. The City will continue to monitor data and revise visualizations to be user-friendly and accessible. In addition, links to the California Office of Environmental Health Hazard Assessment (OEHHA) website and map viewer which identifies EJ tracts and provides map layers based on indicators utilized in determining EJ scores are published in the Environmental Quality webpage to assist residents in locating the information.

MPNA Attachment II,

2.18.22 134 Cumulative Impact Analyses: MPNA requests that the City incorporate into the General Plan Update maps and other visualizations depicting the overlap of water, soil, and air pollution and hazardous and toxic waste sites in Santa Ana. a) Existing maps from CalEnviroScreen (CES) in the EJ Background Appendix of the DPEIR show the Madison Park Neighborhood faces pollution exposure from air quality, toxic cleanup sites, groundwater threats, hazardous waste, and lead. b) The City should include details (zoomed-in versions) of these maps for every EJ Community in Santa Ana. c) These maps should be periodically updated for EJ Community Meetings. d) These results should distinguish between existing emissions, ongoing emitters, and newly planned emission sites.

The designation of a census tract as an EJ area is the result of a cumulative analysis of all of the indicators that the CalEnviroScreen methodology uses. Additionally, as the numerous programs to address EJ are undertaken, tailored visualizations for topical area or geographic area will be provided as needed. Moreover, designation of census tracts as EJ and census tract scores will continue to change based on new data and updates to the CalEnviroScreen. As such, providing up to date maps with the latest data and designations on the City's Environmental Quality webpage is a more optimal solution to providing the community up to date information.

MPNA Attachment II,

2.18.22 135 Maps of Emitters: MPNA requests maps marking where the current permitholders for emissions of any kind of pollution are located. Similarly, there should be separate map details for each EJ Community. a) Along with these maps, there should be explanations for how development will likely change the area over the next 25 years.

The California Department of Toxic Substances provides an interactive map viewer where members of the public can view location of permit holders, contaminated sites, and status of permits, with the option of only viewing permits in EJ tracts. https://dtsc.ca.gov/ Through the creation of the Environmental Quality webpage, this resource and others like it will be published on the City's webpage for ease of access and awareness.

MPNA Attachment II,

2.18.22 EMISSION STUDIES / PLANNED REMEDIATION IN EJ COMMUNITIES 136 The Plan should aim to reduce and eliminate existing emissions / toxic sites, and limit or avoid new sources of emissions and toxics. The current plan fails by not fully addressing remediation goal
A number of policies and actions address this comment. The Draft Plan includes a number of policies and actions that directly seek to reduce and/or eliminate heavy industrial uses near residences through development standards, incentives and amortization programs, creation of new land use designations that, if adopted, will no longer permit heavy industrial (Industrial Flex--South Main Street Focus Area and West Santa Ana Blvd.), and examining the feasibility of implementing new laws to prohibit heavy industry near homes. In addition, there are a number of actions that if adopted will lead to the City working more closely with air pollution regulating agencies to reduce pollution emissions. To see related actions see draft actions LU-3.2, LU-3.3, LU-3.4, LU-3.15, LU-3.23, LU-4.6, CN-1.1, CN-1.4, CN-1.5, CN-1.6, CN-1.7,CN-1.9, CN-1.12, CN-1.17, S-2.1, S-2.2, M-5.8, and draft policies m-1.7, CN-1.1, CN-1.3, CN1.15, CN-1.16, CN-1.18, OS-2.5, LU-3.12, and LU-4.3.

MPNA Attachment II,

2.18.22

Page 26 ends

City Council 30 – 28 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 137 Lead Action Plan. MPNA requests that the City create an aggressive action plan to address the soil-lead contamination in Santa Ana EJ Communities that is backed with clear, enforceable measures. a) While the City plans to address some aspects of lead-based paint contamination, it has neglected historical emissions of leaded gasoline. 2. Mitigation Measures. MPNA requests that the City analyze and provide mitigation measures for the increased soilcontamination that can occur from the demolition or removal of existing buildings that contain lead-based paint.

A number of policies and actions address this comment. The Draft Plan includes numerous actions aimed at addressing lead based contamination in the community, which were developed in partnership with community stakeholders. Lead contamination from non stationary sources like automobiles is a statewide problem and especially acute in urban environments where vehicle traffic is heaviest. The plan includes actions to help identify the exact cause of the pollution and to then seek funds to assist with remediation. The plan also includes actions to provide education related to renovations and construction on buildings that may have lead based products to reduce risk of lead poisoning.

Actions addressing lead contamination include S-2.4, LU-3.6, LU-3.17, LU-3.18, LU-3.19, LU3.20, LU-3.21, LU-3.22, LU-3.24, LU-3.26, and LU-3.29.

MPNA Attachment II,

2.18.22 138 Mitigation Measures. MPNA requests that the City analyze and provide mitigation measures for the increased soil-contamination that can occur from the demolition or removal of existing buildings that contain lead-based paint.

Recommended Action Change: LU-3.26: Health Conditions. Work with state agencies including Department of Toxic Substances Control and South Coast Air Quality Management District, Orange County Health Care Agency and local stakeholders including Orange County Environmental Justice and UC Irvine Public Health to identify baseline conditions for lead soil and air contamination in Santa Ana, routinely monitor indicators of lead such contamination, and measure positive outcomes. Collaborate with these organizations to secure grant funds for soil and air testing, remediation (e.g., bioremediation, covering, removing, air filtration), and prevention activities for residential properties in proximity to sites identified with high soil lead levels of soil pollution (including sites identified with soil lead levels of 80 ppm or higher), and air pollution, with a focus on communities disproportionately affected by soil contamination.

Action has been modified to address frequency of soil monitoring, examples of remediation and emphasis on communities disproportionally affected by soil contamination. Per March 28, 2022 roundtable, new revisions related to soil and air included in response to MPNA comments to broaden collection of baseline conditions. Reference to 80 ppm added in response to OCEJ comments in context of pursuing grant funding.

MPNA Attachment II,

2.18.22 139 Baseline Pollution studies and Progress Reports. MPNA requests that the City publish data establishing a clear baseline of pollution that exists today that affects communities, specifically EJ communities. 3 a) The data should be published yearly to track the effectiveness and weaknesses of the GPU and should be presented at EJ Community Meetings.

Existing Action: CN-3.3: Health Metrics. Engage with the Orange County Health Care Agency and other stakeholders to monitor key health indicators to measure the success of the outcome of General Plan policies and the implementation plan, including reduction in incidence in asthma and low birth weight of infants.

Once established through proposed Action CN-1.10, an interagency team focused on EJ issues can evaluate all existing studies, monitoring and reporting systems conducted by established hazardous material regulating agencies relevant to Santa Ana, and publish through proposed Environmental Quality webpage and start to evaluate health indicators to track effectiveness.

MPNA Attachment II,

2.18.22 140 1,000 Feet Minimum Buffer-Zones. MPNA requests that the City commit to creating buffer zones of at least 1,000 feet between industrial uses and sensitive receptors. a) Currently POLICY LU-3.11 states “Promote landscaping and other buffers to separate existing sensitive uses from rail lines, heavy industrial facilities, and other emissions sources. As feasible, apply more substantial buffers within environmental justice area boundaries.” However, the policy has no detailed, enforceable language. b) The GPU should explicitly require this 1,000 feet minimum buffer-zone.

Existing Action: LU-3.2: Design Guidelines and Standards. Update the zoning code's development and operational standards for industrial zones to address incompatibility with adjacent uses, including minimum distance requirements to buffer heavy industrial uses from sensitive receptors.

Conduct a study to evaluate and establish appropriate minimum distances and landscape buffers between polluting industrial uses from sensitive receptors such as residences, schools, day care, and public facilities.

Further analysis is required to determine what the appropriate buffer should be. If adopted, Action LU-3.2 will establish a process by which to study relevant data and best practices, to arrive at an appropriate distance, not simply choosing an arbitrary distance.

MPNA Attachment II,

2.18.22 141 Air Quality Enforceability. MPNA requests that the City incorporate language into the GPU that: a) Prioritizes EJ Communities b) Commits to initiate/implement its actions c) Defines when these actions would be triggered d) Commits to address incompatible land uses with EJ Communities.

Existing Action: LU-3.3: Healthy Lifestyles. Collaborate with residents and industry stakeholders to create a program to incentivize and amortize the removal of existing heavy industrial uses adjacent to sensitive uses.

There are 75 actions directly addressing EJ issues in the Draft Plan. The action/program table states what the City is committing to and when the action/program is expected to be completed. The Draft Plan also commits to establishing a buffer between heavy industrial uses and residences, and exploring incentives/amortization program to reduce conflicts between the two uses.

MPNA Attachment II,

2.18.22 142 The City must ensure the implementation of the GPU reduces and eliminates air emissions in EJ Communities. a) These problems are described in more detail in “Attachment A – MPNA Comments on the GPU” from our letter submitted as public comment titled “Comments on the City of Santa Ana’s General Plan Update” from October 29, 2020.

A number of policies and actions address this comment. As depicted in the CalEnviroScreen tool, air pollution is not contained within city borders, rather, is shaped by regional forces as well as topographical variations. As such, there are regional and state agencies tasked with tackling air pollution. There are numerous policies and actions in the Draft Plan to ensure Santa Ana is doing its part locally and regionally to reduce air pollution. To see related actions see draft actions LU-3.2, LU-3.3, LU-3.4, LU-3.15, LU-3.23, LU-4.6, CN-1.1, CN-1.4, CN-1.5, CN-1.6, CN-1.7,CN-1.9, CN-1.12, CN-1.17, S-2.1, S-2.2, M-5.8, and draft policies m-1.7, CN-1.1, CN-1.3, CN1.15, CN-1.16, CN-1.18, OS-2.5, LU-3.12, and LU4.3.

MPNA Attachment II,

2.18.22

Page 27 ends

City Council 30 – 29 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment

TRANSPARENCY AND ACCOUNTABILITY
143 EJ Progress Reports: The City should stay up to date on recommendations of the California DOJ Bureau of Environmental Justice with regard to Environmental Justice Goals and Implementation strategies, then update the community with new information. a) At EJ Community Meetings, the City should explain how it plans to implement its recommendations as part of the requested progress reports.

Existing Action: LU-3.25: Engage EJ Communities. Work with community serving organizations, neighborhood leaders, and residents to form an Environmental Justice Action Committee Ad Hoc Committee to develop ongoing EJ Community Engagement programs for existing and new disadvantaged EJ communities, including multilingual communication protocols. Host biannual or quarterly Roundtable meetings with local stakeholders to guide and evaluate implementation of environmental justice policies.

The City has received communication from DOJ stating that the Draft Plan complies with SB 1000 requirements. As indicated in action CN-1.10, an interagency team will be formed to work with stakeholders to address EJ issues and determine most effective ways to communicate with community members. Additionally, action LU-3.25 will build on the robust engagement strategy implemented during the General Plan Update to continue engaging EJ communities after the plan is adopted. Biannual removed in response to OCEJ comment during March 28, 2022 roundtable.

MPNA Attachment II,

2.18.22 144 Identify pollution violations. MPNA requests a complete list of companies that require special permits related to pollution and their history of violations between 2011-2021
N/A This is not a policy/program recommendation for the General Plan Update. Information related to permits and violations can be requested through pertinent regulating regional, state, or federal agencies.

MPNA Attachment II,

2.18.22 145 Collaborate on community information requests. MPNA requests the City be forthcoming on new permits and approvals for industrial activity by facilitating information and data requests pertaining to industrial land use N/A This is not a policy/program recommendation for the General Plan Update. The City maintains a transparent development review process, maintaining websites for development projects, a master development list online, requires all developers comply with noticing and meeting requirements in the Sunshine Ordinance, and responds to public records request in a timely manner.

MPNA Attachment II,

2.18.22 GREENSPACE / LAND PRESERVATION
146 MPNA requests that the City incorporate provisions using permits to incentivize developers to create or preserve greenspace.

Recommended Policy Change: OS-1.9: New Development. Require all new development to provide adequate parks and open space, including via parkland dedication or development fees, in order to meet the City's park standard. Ensure that new development includes pedestrian and multi- modal travelways to promote a quality living environment. For new development within park deficient and environmental justice areas, prioritize the creation and dedication of new public parkland over the collection of impact fees.

Policy has been modified to address community comments and to clarify and strengthen language.

MPNA Attachment II,

2.18.22 147 MPNA requests the ratio of parkland to resident be at least 4 acres per 1,000 residents, similar to neighboring communities. a) The GPU has a goal of only 2 acres of parkland per 1,000 residents. (1) Newport general plan: 5 acres per 1,000 residents (2) Irvine general plan: 5 acres per 1,000 residents (3) Fullerton general plan: 4 acres per 1,000 resident
Recommended Policy Change: OS-1.3: Park Standard. Establish and maintain public parks, open space, and recreation requirements for new residential and nonresidential development to provide sufficient opportunities for Santa Ana residents and visitors. Attain a minimum of 3 acres of land per 1,000 persons residing in the City of Santa Ana.

The community comment to increase the ratio in acres per 1,000 residents is in alignment with comments provided by members of City Council. This ratio has been increased to three (3) acres per 1,000 residents.

MPNA Attachment II,

2.18.22 148 We demand that the city establish a permanent Environmental Justice office with a public health expert on staff, to conduct regular meetings with residents and community organizations to guide implementation of these policies, give regular reports on local environmental health issues, and ensure a relationship of accountability and transparency between the city and the community.

MPNA, Leonel Flores,
February 10, 2022
letter

Page 28 ends

City Council 30 – 30 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 149 Santa Ana Suggests: Policy CN-1.1 Regional Planning Efforts “Coordinate air quality planning efforts with local and regional agencies to meet State and Federal ambient air quality standards in order to protect all residents from the health effects of air pollution.” Santa Ana Is Missing: A policy to test, measure, record, maintain, and reduce air pollution emissions. Santa Ana Could Adopt:

A policy more like that of the City of San Pablo’s Policy OSC-I-17 Prepare a Greenhouse Gas Emissions Reduction Plan to include a “baseline inventory of all known or reasonably discoverable sources of greenhouse gases (GHGs) that currently exist in the city and sources that existed in 1990... [a] projected inventory of the GHGs that can reasonably be expected to be emitted in the city in the year 2030 in accordance with discretionary land use decisions pursuant to this General Plan update and foreseeable communitywide and municipal operations... [a] target for the reduction of emissions...from those identified sources reasonably attributed to the City's discretionary land use decisions and municipal operations... [and a] list of feasible GHG reduction measures...whose purpose shall be to meet the established local reduction target, including energy conservation and "green building" requirements in municipal buildings and private development” (text in red added by City staff for context)
A number of policies and actions address this comment. The GHG reduction plan in San Pablo's General Plan draws on baseline and projected inventories from the State and regional air quality boards and agencies. Taking a similar approach, the Santa Ana GP Update actions seeks to collaborate with air pollution regulators to gather local data and create strategies to address emissions at the local level. See actions CN-1.1, CN-1.3, CN-1.6, CN-1.12, CN-1.19, and policies CN-1.3, S-1.2, CN-1.13, CN-1.15, and LU4.5.

MPNA Attachment IV,

2.18.22 150 Santa Ana Suggests: Action OS-1.1 Park Needs Assessment and Master Plan “Create, adopt, and implement a park needs assessment and master plan defining park service areas according to best practices, establishing a service area for each park facility, creating a tool to evaluate needs and prioritize improvements by quadrant or appropriate geographic subarea, and maintaining a list of priorities for the expansion and improvement of open space and recreational facilities in each quadrant or geographic subarea to attain a park land standard of 2 acres per 1,000 residents.” Santa Ana Is Missing: A policy that identifies more specific implementation plans Santa Ana Could Adopt: A policy more like that of the City of San Pablo’s Policy HEA-I-5 “Link park facility improvement priorities to a ranking system keyed to public health and recreational goals... a performance-based priority system establishes a ranking scale that measures each component (e.g. pool, court, bench, or trail) of its system against the scale related to public health. For example, it might be a one-to-three scale in which one is below expectations, two indicates that the component can meet its intended function for a given period of time, and three means that it exceeds expectations...” Recommended Action Change: OS-1.1: Park Needs Assessment And Master Plan. Create, adopt, and implement a park needs assessment and master plan, based on community input, defining park service areas according to best practices, establishing a service area for each park facility, creating a tool to evaluate needs and prioritize improvements by quadrant or appropriate geographic subarea, and maintaining a list of priorities for the expansion and improvement of open space and recreational facilities in each quadrant or geographic subarea to attain a park land standard of 3 acres per 1,000 residents.

Draft General Plan Action 1.1 identifies a needs assessment, master plan and mechanisms to guide all future park development and establish a methodology to prioritize park improvements, evaluation of needs and measures of how those needs are met. Both the San Pablo example and the actions included in Santa Ana's Draft Plan achieve the same goal, establishing a system by which to rank or prioritize park improvements and developments.

Moreover, the Action has been modified OS-1.1 to emphasize community input and increasing the park standard to three (3) acres per 1,000 residents.

MPNA Attachment IV,

2.18.22

Page 29 ends

City Council 30 – 31 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 151 Santa Ana Suggests: Action CM-3.6 Fresh and healthy foods. “Pursue programs, incentives, and/or grants to encourage urban agriculture and small grocery or convenience stores to sell fresh foods in the city, especially those within environmental justice area boundaries. Examples include grants or loans to purchase updated equipment, publicity, or directories of healthy food outlets, or connecting stores to wholesale sources of healthy, local, or organic food.” Santa Ana Is Missing: A policy to measure and increase fresh and healthy food access for environmental justice communities Santa Ana Could Adopt: A policy more like that of the City of Chino’s Policy P4 “In areas identified as underserved with healthy food sources, the City shall consider financial incentives to attract grocery store-anchored retail centers” with Actions A2-A5 to “Conduct a study to identify areas of the City that are underserved by grocery stores... attract retail that is currently lacking, such as grocery stores, work with brokers and existing stores to identify sites that could be appropriate for a specific store... Monitor vacancy rates and sales tax performance for retail areas in the City... [and] Actively recruit retail stores by marketing available sites and devoting staff time to working with potential tenants”
Recommended New Action: CM-3.6A: Food Deserts. Collaborate with Orange County Health Care Agency (OCHCA) to gather and map food desert data, and share publicly through the City's Environmental Quality webpage.

Food deserts were researched as part of the development of the draft General Plan. That research revealed that no food desert areas currently exist in Santa Ana. To monitor and visualize this data, staff recommends adding a new action to collaborate with OCHCA to gather and map data and make it available to the public through the Environmental Quality webpage (webpage is proposed as part of Action CN-1.10). Once the data is gathered and mapped, funds and effort resulting from Action CM-3.6 to create a program to expand fresh and healthy food options in the City and can be tailored and targeted at any areas that may develop into food deserts over time.

MPNA Attachment IV,

2.18.22 152 Santa Ana Suggests: Policy CM-3.2 Healthy Neighborhoods “Continue to support the creation of healthy neighborhoods by addressing public safety, use conflicts, hazardous soil contamination, incompatible uses, and maintaining building code standards.” Santa Ana Is Missing: A policy that identifies how such public safety issues will be identified and addressed Santa Ana Could Adopt: A policy more like that of the City of Alameda’s Policy 4.2 “Stimulate neighborhood and community improvement by providing financial and technical assistance in the form of low interest loans, technical assistance and code enforcement,” Policy 4.9 “to support programs designed to rehabilitate deteriorated units and encourage the maintenance and minor repair of structurally sound housing units,” and Policy 4.13 “to provide ongoing infrastructure maintenance in existing residential neighborhoods through the capital improvement program.”
A number of policies and actions address this comment. Providing healthy neighborhoods, specifically safe and sanitary housing as referenced in the comment, is of great importance and is addressed in both the General Plan Update and the Housing Element Update. The General Plan Update provides actions to help build and strengthen community, while the Housing Element Update provides actions related funding for rehabilitation and maintenance, facilitating workshops for owners and renters to understand landlord-tenant responsibilities, and ensuring neighborhood safety and infrastructure are addressed through the Capital Improvement Plan. See actions CM-1.7, CM1.8, OS-2.2, OS-3.2, LU-4.3, M-1.5, PS-1.6, HE-1, HE-2, HE-3, HE-4, HE-10, HE-11, and HE-12.

MPNA Attachment IV,

2.18.22 153 Santa Ana Suggests: Policy CM-3.3 Healthy Residential Programs “Invest in programs and public improvements that educate residents about opportunities to increase their physical activity and improve their health” Santa Ana Is Missing: A policy to educate the public on healthy residential programs Santa Ana Could Adopt: A policy more like that of the City of South Gate’s Policy P.3 “Information about community events should continue to be distributed to a wide range of community organizations including churches, senior facilities, schools, etc. using existing city-sponsored platforms such as the City website
A number of policies and actions address this comment. Community engagement has been instrumental in the development of the General Plan Update and will continue to be instrumental to the decision making process moving forward.

To that end, the Draft General Plan includes implementation actions to make community engagement and collaboration central to community education and decision making processes. See actions CM-1.1, CM-1.2, CM-1.3, LU-3.25.

MPNA Attachment IV,

2.18.22

Page 30 ends

City Council 30 – 32 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 154 Santa Ana Suggests: Action S-2.4 Lead Contamination “Work with local and regional partners, such as Orange County Environmental Justice, Orange County Health Care Agency and University of California at Irvine Public Health, to understand the prevalence, sources, and implications of lead contamination of soil across Santa Ana. Collaborate with environmental justice stakeholders in proposing solutions to remove hazardous lead-contaminated soils in the city and with benchmarks to measure and track effectiveness of proposed programs.” Santa Ana Is Missing: A policy to test, measure, record, maintain, reduce, and eliminate existing lead contamination, especially in areas disproportionately impacted by existing lead contamination. Ensure contaminated sites are remediated before new development occurs Santa Ana Could Adopt: A policy more like that of the City of Richmond’s Policy HL-40 “Ensure that contaminated sites in the city are adequately remediated before allowing new development. Engage the community in overseeing remediation of toxic sites and the permitting and monitoring of potentially hazardous industrial uses. Develop a response plan to address existing contaminated sites in the city...” and Action HW9.K for “standards dealing with the safe management of hazardous substances... [that] should require soil testing at development sites where contamination is suspected...”
Existing Action: LU-3.29: Development Site History. Update the City’s Development Review application process to require developers to provide information regarding the prior use of the site and history of hazardous materials on the property, in order to identify potential for site contamination from hazardous materials or soil lead contamination to be remediated.

The Draft Plan includes numerous actions aimed at addressing lead based contamination in the community, which were developed in partnership with community stakeholders. Lead contamination from non stationary sources like automobiles is a statewide problem and especially acute in urban environments where vehicle traffic is heaviest. The Draft Plan includes actions to help identify the exact cause of the pollution and to then seek funds to assist with remediation. The Draft Plan also includes actions to provide education related to renovations and construction on buildings that may have lead based products. Actions addressing lead contamination include S-2.4, LU-3.6, LU-3.17, LU-3.18, LU-3.19, LU-3.20, LU3.21, LU-3.22, LU-3.24, LU-3.26, and LU-3.29.

MPNA Attachment IV,

2.18.22 155 Santa Ana Suggests: Policy CM-1.2 Community Input “Engage residents and community facility users to provide input for facility improvements and programming.” Santa Ana Is Missing: A policy that effectively involves community members in the decision-making process Santa Ana Could Adopt:

A policy more like that of the City of National City’s Goal HEJ-1 “Meaningful and effective participation, promotion of community capacity building, and fair treatment of all segments of the public in the process of creating a healthy environment and developing, adopting, implementing, and enforcing environmental laws, regulations, and policies” with Policy HEJ-1.1 “Facilitate the involvement of community residents, businesses, and organizations in the development, adoption, and implementation of community health initiatives and consider their input throughout the decision making process” Policy HEJ1.2 to “Consider environmental justice issues as they are related to potential health impacts...” Policy HEJ-1.3 “Consider environmental justice issues as they are related to the equitable provision of desirable public amenities...” Policy HEJ-1.5 “Assure potentially affected community residents that they have opportunities to participate in decisions that affect their environment and health, and that the concerns of all participants involved will be considered in the decision-making process” and Policy HEJ-1.6 “Hold meetings and workshops at times and locations that are convenient for community members to attend, especially those that may be directly affected by a particular decision”
A number of policies and actions address this comment. The Draft General Plan contains various policies and implementation actions related to increasing community engagement and participation, with a focus on increasing participation from community members that reside in environmental justice areas and historically marginalized groups. See actions OS-1.15, OS-2.8, CM-1.2, CN-1.3, CN-1.11, CN-1.14, CN-1.15, LU-3.25, and policies LU-3.2, and CM-1.2.

MPNA Attachment IV,

2.18.22

Page 31 ends

City Council 30 – 33 4/19/2022
Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 # Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment 156 Santa Ana Suggests: Policy LU-3.11 Air Pollution Buffers “Promote landscaping and other buffers to separate existing sensitive uses from rail lines, heavy industrial facilities, and other emissions sources. As feasible, apply more substantial buffers within environmental justice area boundaries.” Santa Ana Is Missing: A policy to designate appropriate distances or standards for buffer zones Santa Ana Could Adopt: A policy more like that of the City of East Palo Alto’s Policy 10.3 “Plant landscape buffers between Highway 101 and residential areas...” which designates specific locations for buffer zones or CARB’s suggestion that sensitive land uses be separated from industrial uses by at least a distance of 1,000 feet.

MPNA Attachment IV,

2.18.22 157 South Bristol Street Land Use Focus Area: Redesignate the eastern block of Bristol Street between MacArthur and Alton Ave to UN-40 instead of DC-2.

The designation is a better transition with the adjacent neighborhood to the east.

Amend General Plan Land Use Map Map has been modified to reflect City Council. City Council 158 Recommended Action: LU-2.15: Community Serving Commercial Retail & Service Diversity Impact Analysis. Implement a requirement for mixed-use projects or proposals to convert commercial and other non-residential uses to residential or mixed-use projects to complete a community serving commercial retail & service diversity impact analysis to inform the decision making process and to ensure availability and diversity of commercial retail and service uses as part of the development proposal.

Recommended Action: LU-2.15: Community Serving Commercial Retail & Service Diversity Impact Analysis. Implement a requirement for mixed-use projects or proposals to convert commercial and other non-residential uses to residential or mixed-use projects to complete a community serving commercial retail & service diversity impact analysis to inform the decision making process and to ensure availability and diversity of commercial retail and service uses in Santa Ana as part of the development proposal.

Staff is proposing the Action to maintain the avialability and a balanced mix of community serving commercial retail and service uses within the City.

Staff

Page 32 ends

City Council 30 – 34 4/19/2022
1 Recommended Clarifications to the Draft April 2022 General Plan The following represents recommendations proposed by the community and City staff to the April 2022 version of the Draft General Plan. The updated content is shown by element, with policy and implementation actions displayed with tracked changes, with new content noted as underlined.

INTRODUCTION:

The following definitions under the Glossary section of the Introduction are proposed to be included as follows:

Open Space. Recreational and green spaces, including parks, commercial open space, manicured landscaped areas, and public facilities such as trail corridors, water channels and rail infrastructure.

Park and Parkland. Publicly accessible sites and green space that are owned and/or managed by the City of Santa Ana to support recreation and social gathering.

Park Deficient Area. Areas of the community that are outside the standard public parkland service radius such as 1/2 mile for Community Parks and ¼ mile for Neighborhood Parks, respectively.

COMMUNITY ELEMENT:

The following Community Element policies/implementation actions are proposed to be amended as follows:

Community Input. Policy CM-1.2, Page CM-04
Engage residents and community facility users with meaningful and effective participation to provide input and involve them in the decision-making process for community facility improvements and programming.

Healthy Residential Programs. Policy CM-3.3, Page CM-09 Invest in programs and public improvements that educate residents about opportunities to increase their physical activity and improve their health, especially in environmental justice communities with higher risk of negative public health outcomes.

Engage EJ Communities on Recreation and Cultural Programs. Action CM-1.1, Page CM-14 Incorporate community stakeholders from environmental justice communities to form an Environmental Justice Action Committee into existing and/or new ad hoc committees to guide the identification of recreational and cultural programing needs and desires. Agency/Time Frame: PRCSA & PBA/2023 Community Conversation. Action CM-1.2, Page CM-14
Plan for and conduct a community survey every three two years related to community health, air quality pollution concerns, parks, community engagement, and community service needs, with focused outreach to environmental justice priority areas, utilizing various platforms, such as social media and school events, to encourage substantial survey participation. Agency/Time Frame: CMO/2023 Every Two Years Environmental Soil and Human Health Screening Measures. Action CM-3.8, Page CM-15 Collaborate with Orange County Health Care Agency, and local stakeholders such as Orange County Environmental Justice and UC Irvine Public Health, in efforts to provide increase healthcare services (i.e., blood City Council 30 – 35 4/19/2022
2 lead testing, treatment) for residents, especially those that reside in environmental justice communities, Additionally, collaborate to advocate for adjustment of the County and State policies for health and environmental screening levels to promote healthy outcomes related to lead contamination as recommended by health experts. Agency/Time Frame: PBA/2023 Ongoing
Food Deserts. Action CM-3.6A, Page CM-15
Collaborate with Orange County Health Care Agency (OCHCA) to gather and map food desert data, and share publicly through the City's Environmental Quality webpage. Agency/Time Frame: PBA/2024 Environmental Justice Staff. Action CM-3.9, Page CM-15 & CM-16 Identify funding and hire a full-time Environmental Justice staff member to collaborate with the community to implement the environmental justice policies and actions including community outreach, collaboration on environmental health studies, pursuing grants, and coordination with federal, state, and local agencies regarding environmental concerns in the City. Agency/Time Frame: CMO/2022 MOBILITY ELEMENT:

The following Mobility Element policies/implementation actions are proposed to be amended as follows:

Proactive Mitigation. Policy M-1.7, Page M-04
Proactively mitigate existing and new potential air quality, noise, congestion, safety, and other impacts from the transportation network on residents and business, especially in environmental justice communities.

Interstate Freeways. Policy M-2.1, Page M-14
Support Caltrans and OCTA efforts to modernize and improve freeways by improving safety, capacity, convenience of access, and operational efficiencies, while addressing impacts to neighborhoods.

Transit Services. Policy M-2.2, Page M-14
Support OCTA, Caltrans, and other Work with regional and local transportation providers to enhance existing transit services entities to provide residents, workers, and visitors with safe, affordable, accessible, convenient, reliable, and attractive transit services.

Land Use Development Design. Policy M-4.5, Page M-16
Ensure that building placement and design features create a desirable and active streetscape, by prioritizing pedestrian access directly from the street and placing parking lots to the rear of a development site.

Air Pollution Mitigation. Policy M-4.9, Page M-16
Consider Utilize land use, building, site planning, and technology solutions to mitigate exposure to transportation-related air pollution, especially in environmental justice focus areas.

MPAH. Action M-1.2, Page M-21
Coordinate with external agencies to ensure the OCTA Master Plan of Arterial Highways accommodates current and future demand for all users while prioritizing the safety of people utilizing non-automobile modes of transportation. Agency/Time Frame: PWA/20212-2035

ECONOMIC PROSPERITY ELEMENT
The following Economic Prosperity Element policy is proposed to be amended as follows:

Mitigate Impacts. Policy EP-3.3, Page EP-09
Promote the development of sustainable and equitable new land use plans that proactively reduces negative health and economic impacts on existing residents and businesses, especially in environmental justice communities.

City Council 30 – 36 4/19/2022
3 PUBLIC SERVICES ELEMENT
The following Public Services Element policies are proposed to be amended as follows:

Staffing Levels. Policy PS-2.7, Page PS-08
Maintain Increase staffing levels for sworn peace officers, fire fighters, emergency medical responders, code enforcement, and civilian support staff to provide quality services and maintain an optimal response time citywide, as resources become available.

Resilient Facilities and Infrastructure. Policy PS-2.11, Page PS-09 Coordinate with utilities and public agencies to develop, maintain, relocate, and/or upgrade critical local and regional public facilities and infrastructure systems to ensure their resiliency during times of extreme weather or natural disasters, or toxic emission release.

CONSERVATION ELEMENT
The following Conservation Element policies/implementation actions are proposed to be amended as follows:

Regional Planning Efforts. Policy CN-1.1, Page CN-05
Coordinate air quality planning efforts with local and regional agencies to meet or exceed State and Federal ambient air quality standards in order to educate the community on and protect all residents from the health effects of air pollution.

Sensitive Receptor Decisions. Policy CN-1.5, Page CN-05 Consider potential Study the impacts of stationary and nonstationary emission sources on existing and proposed sensitive uses and opportunities to minimize health and safety risks. Develop and adopt new regulations on avoiding the siting of facilities that potentially emit increased pollution might significantly increase pollution near sensitive receptors within environmental justice area boundaries.

Community Survey on Healthy Lifestyles. Action CN-1.13, Page CN-20 Plan for and conduct a community survey of residents every two years related to community health, pollution air quality, parks, community engagement, and community services; with focused outreach for environment justice concerns and priority areas (tie into other City efforts like Strategic Plan, park and recreation planning, community benefits, etc.). Report findings of survey through the various media platforms and utilize input to inform periodic evaluation and update of the General Plan. Agency/Time Frame: CMO/2022 Every Two Years Expanded Interactions. Action CN-1.14, Page CN-20
Identify opportunities to expand regular attendance and support neighborhood associations and community groups to hold regular meetings with of City staff and decision-makersin at meetings for neighborhoods within environmental justice area boundaries communities, so that residents, community organizations, and businesses can more easily communicate their unique issues and needs, as well as their recommendations on how best to implement environmental quality, environmental health, and environmental justice polices.

Arrange for language interpretation services as needed Include a translator(s) at these meetings so that all residents can engage participate. Agency/Time Frame: PBA & CMO/Ongoing Preservation of Natural and Historic Resources. Action CN-2.4, Page CN-21 Identify and evaluate Collaborate with local indigenous tribes and other stakeholders to identify and evaluate potential incentives in the municipal code to encourage protection and enhancement of natural and historic resources. Agency/Time Frame: PBA/2023 Ongoing
City Council 30 – 37 4/19/2022
4 OPEN SPACE ELEMENT
The Introduction section on Page OS-01 of the Open Space Element is proposed to be amended as follows:

The purpose of the Open Space Element is to identify, and preserve, and add open space areas that provide value to the community and enrich the quality of life. Such lands or waters provide value in the form of recreation, health, biodiversity, wildlife conservation, and aesthetics. Additionally, open spaces are used for climate change mitigation and adaption, flood risk reduction, managed natural resources production, agricultural production, and protection from hazardous conditions. The Open Space Element will guide the City in its efforts to plan for open space lands in what is largely a built-out, urban environment.

The following Open Space Element policies/implementation actions are proposed to be amended as follows:

Park Standard. Policy OS-1.3, Page OS-05
Establish and maintain public parks, open space, and recreation requirements for new residential and nonresidential development to provide sufficient opportunities for Santa Ana residents and visitors. Attain a minimum of two three acres of land per 1,000 persons residing in the City of Santa Ana.

Park Distribution. Policy OS-1.4, Page OS-05
Ensure the that all City residents have access to public or private parks, recreation facilities, or trails in the City of Santa Ana, within 10-minute walking and biking distance of their homes. Prioritize provision, programs, and partnerships in park deficient in environmental justice areas.

Land Acquisition and Equitable Distribution. Policy OS-1.8, Page OS-06 Explore options for the acquisition of Acquire available lands for parks, open space, greenways and trail corridors, with priority given to sites that are within park deficient or and environmental justice areas.

New Development. Policy OS-1.9, Page OS-06
Ensure Require all new development to provide adequate parks and open space, including via parkland dedication or development fees, in order to meet the City’s park standard. Ensure that new development includes effectively integrates parks, open space, and pedestrian and multi-modal travelways to promote a quality living environment. For new development within park deficient and environmental justice areas, prioritize the creation and dedication of new public parkland over the collection of impact fees.

Creative Solutions for Deficiencies. Policy OS-1.10, Page OS-06 Develop creative and flexible solutions to provide greenspace and recreation activities in park-deficient neighborhoods where traditional parks are not feasible. Encourage public, private, and commercial recreational facilities in areas that are park deficient are physically open to the public and are affordable to residents of surrounding neighborhoods, and serve community needs.

Funding Sources. Policy OS-1.11, Page OS-06
Explore and pursue all available funding, including nontraditional funding sources, for park acquisition, facility development, programming, and maintenance of existing and new parks, and to increase investment per resident and meet the City’s park standard of three acres per 1,000 residents. Set aside park funding to have monies on hand to acquire and develop parkland when opportunities arise and to leverage grant options.

Park Needs Assessment and Master Plan. Action OS-1.1, Page OS-16 Create, adopt, and implement a park needs assessment and master plan, based on community input, defining park service areas according to best practices, establishing a service area for each park facility, creating a tool to evaluate needs and prioritize improvements by quadrant or appropriate geographic subarea, and maintaining a list of priorities for the expansion and improvement of open space and recreational facilities in City Council 30 – 38 4/19/2022
5 each quadrant or geographic subarea to attain a park land standard of 2 three acres per 1,000 residents.

Agency/Time Frame: PRCSA/2022
No-Net-Loss of Public Parkland. Action OS-1.4, Page OS-16 Establish land use provisions in the Municipal Code that prevent a net loss of public parkland in the City of Santa Ana. Require at least a 1:1 replacement if there is any loss of public parkland or City owned open space due to public or private development. Agency/Time Frame: PRCSA/2022 Development Fees. Action OS-1.6, Page OS-16
Evaluate Update the fees required by the City’s Residential Development Fee Acquisition and Development Ordinance and adjust them to increase the parkland dedication requirements to meet three acres of parkland per 1,000 residents better reflect current costs and needs. Require that fees collected in place of parkland dedication to be utilized to acquire or expand facilities within geographic proximity to new development or parkland deficient areas Update requirements regarding where fees are spent. Agency/Time Frame:

PRCSA/2022
Public Parkland Requirements for Residential Projects. Action OS-1.7, Page OS-06 Update the Residential Development Fee Ordinance for large residential projects, which include projects of 100 residential units or more, to require public parkland within the City limits and a 10-minute walking distance of the new residential projects. Agency/Time Frame: PRCSA & PBA/2022 New Parkland Collaborative. Action OS-1.10, Page OS-17
Coordinate with property owners to explore options to provide public access and programming on privatelyowned open space in park deficient areas, including options to acquire land through purchase, land dedication, easements, and land leases that would allow for permanent or temporary public use of land for open space and recreational opportunities. Agency/Time Frame: PRCSA/2022 & Ongoing Acquisitions to Meet Park Standard. Action OS-1.16, Page OS-17 Using the Park Master Plan as guidance, identify and acquire property within the City for park and open space use which will focus on bringing the park and recreation system to 2 three acres of land per 1,000 residents with a plan to keep pace with future urban growth. Agency/Time Frame: PRCSA/2022

SAFETY ELEMENT
The following Safety Element policies/implementation actions are proposed to be amended as follows:

Regional Collaboration. Policy S-2.1, Page S-07
Consult and collaborate with federal, state, and regional agencies to identify and regulate the use, storage and disposal and storage of hazardous materials, prevent the illegal transportation and disposal of hazardous waste, and facilitate the cleanup of contaminated sites.

Hazardous Waste Generators. Policy S-2.2, Page S-07
Collaborate with appropriate agencies to identify and inventory all users and handlers of hazardous materials to proactively mitigate potential impacts. Promote transparency and accountability by publishing city, regional, and state data and resources on toxic spills, water pollution, illegal discharges, industrial and commercial air violations on a dedicated Santa Ana Environmental Quality webpage.

Multiagency Education Campaign. Policy S-3.4, Page S-08 Develop cooperative partnerships and strengthen communication among public agencies, residents, nonprofit organizations, community groups, and businesses to promote sharing of educational information regarding seismic and geologic hazards and safety.

City Council 30 – 39 4/19/2022
6 Lead Contamination. Action S-2.4, Page S-15
Work with state, local and regional partners, such as the Department of Toxic Substances Control, South Coast Air Quality District, Orange County Environmental Justice, Orange County Health Care Agency and University of California at Irvine Public Health, to understand the prevalence, sources, and implications of lead contamination of soil across Santa Ana. Collaborate with such state agencies, local and regional partners and environmental justice stakeholders in proposing, selecting, and implementing measures to mitigate (i.e., remove, cover, and remediate) solutionsto remove hazardous lead-contaminated soils in the city in a manner that includes key and with benchmarks and routine monitoring of soil lead levels to measure and track effectiveness of proposed programs selected approach. Agency/Time Frame: PBA & CDA/2022 & Ongoing Business Education. Action S-2.5, Page S-15
Collaborate with state and county agencies and trade organizations to educate and inform industrial business owners about permit regulations required for safe facility operations and about best practices. Agency/Time Frame: PBA & CDA/2022-2024 Ongoing
Public Education. Action S-1.11, Page S-15
Continue to disseminate information on flooding, flood control on private property, floodplains, and flood preparedness, man-made hazards, hazard response plans, resources, and best practices in disaster events to the public through the City website, social media, and at City offices. Agency/Time Frame: CMO & PD/2022

LAND USE ELEMENT
The following Land Use Element policies/implementation actions are proposed to be amended as follows:

Air Pollution Buffers. Policy LU-3.11, Page LU-07
Promote Work with the Environmental Justice Action Committee to develop and implement landscaping and other local land use and zoning buffers strategies, guided by the Air Resources Board and the Southern California Air Quality Management District best practices, to separate existing sensitive uses from rail lines, heavy industrial facilities, and other emissions sources. As feasible, apply more substantial buffers within environmental justice area boundaries.

Community Benefits. Action LU-1.2, Page LU-69
Develop a standard of review for evaluation of a Require new development project's proposing a general plan amendment and/or a zone change to include as part of the development proposal, a net community benefit and implementation plan providing a net community benefits as desired by the City and in neighborhoods through public outreach. Example of community benefits may include, but is not limited to public realm improvements, dedication of park and open space for public use, expanded economic development opportunities, job opportunities, new community serving businesses and services, and removal of blight and incompatible land uses. Assess capital costs and ongoing operations and maintenance costs; conduct a financial feasibility analysis to determine the impacts of community benefits on the feasibility of desired types of development. Agency/Time Frame: PBA & CDA/2022 & Ongoing Community Serving Commercial Retail & Service Diversity Impact Analysis. Action LU-2.15. Page LU-70 Implement a requirement for mixed-use projects or proposals to convert commercial and other nonresidential uses to residential or mixed-use projects to complete a community serving commercial retail & service diversity impact analysis to inform the decision making process and to ensure availability and diversity of commercial retail and service uses in Santa Ana as part of the development proposal. Agency/Time Frame:

PBA & CDA/2022
Fiscal Impact Model. Action LU-2.7, Page LU-70
Create Develop a project-level fiscal impact analysis model and that incorporates the appropriate mix of land uses to achieve fiscal sustainability, or at a minimum, requirements that new development be fiscally City Council 30 – 40 4/19/2022
7 neutrality to make informed land use decisions or beneficial to the City into the development process. Require the completion of this analysis in mixed-use land use designations and in proposed conversion of commercial uses to residential or mixed-use projects. Agency/Time Frame: PBA & CDA/2022 Promote Health. Action LU-3.19, Page LU-72
Partner with local organizations (e.g., OC Health Care Agency, Latino Health Access, Santa Ana Unified School District, Garden Grove Unified School District, Orange County Environmental Justice, and the Coalition of Community Health Centers) to increase blood lead testing, outreach, education, and referral services through a ‘promotora’ or community peer outreach model that addresses the root causes of elevated blood lead levels impacting Santa Ana residents, with special focus in environmental justice communities and for children living in pre-1978 housing. Agency/Time Frame: PBA/2022 & Ongoing Prevention Education. Action LU-3.21, Page LU-72
Collaborate with local organizations such as Orange County Health Care Agency, and State Environmental Protection Agency, and community-based environmental justice organizations to identify funds and to create a Santa Ana Prevent Lead Poisoning Education Program, with special focus on disadvantaged communities and pre-1978 housing stock. Agency/Time Frame: PBA/2022 & Ongoing Public Health Outcomes. Action LU-3.22, Page LU-72
Support the Orange County Health Care Agency in their role in investigating public complaints regarding unsafe lead work practices and lead hazards wherein children are present, through enforcement of local housing standards to assure healthy outcomes including for individuals and households presenting with concerns about lead exposure and/or with confirmed lead levels of >3.5 ug/dL, which the Centers for Disease Control and Prevention indicates as the threshold for follow-up and case management in children.

Agency/Time Frame: PBA/2022 & Ongoing
Engage EJ Communities. Action LU-3.25, Page LU-72
Work with community serving organizations, neighborhood leaders, and residents to form an Ad Hoc Environmental Justice Action Committee to develop ongoing EJ Community Engagement programs for existing and new disadvantage EJ communities, including multilingual communication protocols. Host biannual or quarterly Roundtable meetings with local stakeholders to guide and evaluate implementation of environmental justice policies. Agency/Time Frame: PBA/2022 Health Conditions. Action LU-3.26, Page LU-72
Work with state agencies including the Department of Toxic Substances Control and South Coast Air Quality District, Orange County Health Care Agency, and local stakeholders including Orange County Environmental Justice and UC Irvine Public Health to identify baseline conditions for lead soil and air contamination in Santa Ana, routinely monitor indicators of lead such contamination, and measure positive outcomes. Collaborate with these organizations to secure grant funds for soil and air testing, and remediation (e.g., bioremediation, covering, removing, air filtration), and prevention activities for residential properties in proximity to sites identified with high soil lead levels of soil pollution (including sites identified with soil lead levels of 80 ppm or higher), and air pollution, with a focus on Environmental Justice census tracts communities disproportionally affected by soil contamination. Agency/Time Frame: PBA/2022-2024 Ongoing Tenant Protections. Action LU-3.28, Page LU-73
Provide information to residential tenants regarding Landlord Tenant Laws in the State, such as AB 1481, and Santa Ana’s Just Cause for Tenant Eviction and Rent Stabilization ordinance that provide protections against evictions for those who seek action to improve substandard housing and hazardous conditions. Agency/Time Frame: PBA/2022 & Ongoing
City Council 30 – 41 4/19/2022
8 Public Improvements in Activity Nodes and Focus Areas. Action LU-4.3, Page LU-73 Create a public realm plan for each activity node and focus area to establish a unified vision for long-term improvements to streets, sidewalks, plazas, other public spaces, and placemaking elements. Identify public improvement priorities and pilot projects for each focus area and include them in Program priority improvements and pilot projects into the City's Capital Improvement Program. Agency/Time Frame: PBA & PWA/2022-2027& Ongoing
Mixed Use Lifestyle. Action LU-4.8, Page LU-73
Explore Establish and implement establishing thresholds in the Zoning Code to require identify minimum percentage of commercial uses to be included in mixed use land use designations and in proposed conversion of commercial uses to residential or mixed use projects. , as supported by economic and fiscal studies.

Agency/Time Frame: PBA/2022 - 2027
Collaboration with Rail-Road Companies. Action LU-4.9, Page LU-73 Collaborate with rail road right-of-way owners and operators to renovate the walls between communities and rail lines that provide the maximum protection for the community and public health, including strategies to reduce air and noise pollution. Agency/Time Frame: PBA/2022 & Ongoing Land Use Designation 55 Freeway and Dyer Road, Table LU-7. Page LU-56 Revise table to include a note stating the following: “Hotels are permitted in the Industrial/Flex 3.0 land use designation at Brookhollow Specific Development (SD) Plan No. 8.” Land Use Maps. Revise the land use designation for eastern block of Bristol Street between MacArthur Boulevard and Alton Ave of District Center (DC-2) to Urban Neighborhood Medium Low (UN-40). This change will be reflected in following maps: Land Use Map Figure LU-1, Page LU 12, Density and Intensity Map Figure LU-4, Page LU 16, Land Use Map South Bristol Street Figure LU -20, Page LU 62.

Land Use Designation South Bristol Street, Table LU-8. Page LU 62 Revise table to include UN-40 Urban Neighborhood as one of the allowable designations for South Bristol Street as follows:

South Bristol Street Land Use and Urban Form narrative description to be revised per below, Page 63.

Left column, 2
nd Paragraph, revision includes: “The majority of the corridor north of Alton Avenue MacArthur Boulevard is planned with Urban Neighborhood land use designation…” Right column text below the Urban Neighborhood photo and title: The Urban Neighborhood district between Warner and Alton MacArthur allows medium- to medium-high density housing as well as commercial, and cultural projects up to three (UN-30) and five (UN-40) stories tall along Bristol corridor.

Medium-high density urban neighborhoods with a mix of attached single- and multifamily housing; mixed use residential with ground floor retail, services, and restaurants; cultural uses; public and open spaces
City Council 30 – 42 4/19/2022
9 HISTORIC PRESERVATION ELEMENT
The following Historic Preservation Element policies/implementation actions are proposed to be amended as follows:

Community Engagement. Action HP-3.4, Page HP-14
Community engagement. Prepare a community engagement plan that targets communities with historic resources that have low participation rates in historic preservation programs including hard to reach communities and affiliated tribes listed with the California Native American Heritage Commission.

Agency/Time Frame: PBA/2023
Public Awareness. Action HP-3.10, Page HP-14
Participate in and support efforts of preservation organizations, affiliated tribes listed with the California Native American Heritage Commission, and business groups to promote public awareness and educational opportunities that highlight historic preservation. Agency/Time Frame: PBA/Ongoing Native American Cultural Significance. Action HP-2.7, Page HP-13 Consult with all affiliated tribes listed with the California Native American Heritage Commission to identify sites of cultural, spiritual, and/or historical significance to their tribes, and work with them to preserve, restore or celebrate these sites, where feasible. Agency/Time Frame: PBA/2023 & Ongoing S:\Planning\General Plan 2016\Documents\EJ Materials\GP Matrix EJ\2022 Reponses\Ex 2 Recommended Clarifications to GP _ 4.8.2022.docx City Council 30 – 43 4/19/2022
Resolution No. 2022-XXX

Page 1 of 7 ends

RESOLUTION NO. 2022-XXX

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
SANTA ANA (1) CERTIFYING THE FINAL RECIRCULATED

PROGRAM ENVIRONMENTAL IMPACT REPORT FOR THE
GENERAL PLAN UPDATE, (2) ADOPTING ENVIRONMENTAL

FINDINGS OF FACT AND A STATEMENT OF OVERRIDING

CONSIDERATIONS FOR THE GENERAL PLAN UPDATE

PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY
ACT, (3) ADOPTING THE MITIGATION MONITORING AND
REPORTING PROGRAM, AND (4) APPROVING THE PROJECT
WHEREAS, the City of Santa Ana seeks to approve the City of Santa Ana General Plan Update; and
WHEREAS, the General Plan Update identified the following five focus areas for potential change and new growth: South Main Street, Grand Avenue/17th Street, West Santa Ana Boulevard, 55 Freeway/Dyer Road, and South Bristol Street; and WHEREAS, the total long-term potential growth within these focus areas is estimated at 17,575 new housing units, 2,263,130 non-residential building square footage, and 6,616 jobs; and
WHEREAS, the General Plan Update (“project”) requires, among other things:
(1) adoption of the Santa Ana General Plan Update; (2) certification of a Final Recirculated Program Environmental Impact Report; (3) adoption of Findings of Fact and Statement of Overriding Considerations; (4) adoption of the Mitigation Monitoring and Reporting Program; and (5) adoption of any ordinances, guidelines, standards, programs, actions, or other mechanisms that implement the Santa Ana General Plan update; and
WHEREAS, pursuant to Section 21067 of the Public Resources Code, and CEQA Guidelines Section 15367, the City of Santa Ana is the lead agency for the project; and
WHEREAS, in accordance with CEQA Guidelines Section 15063(a), the City as lead agency determined that a program EIR was required for the project, and therefore did not prepare an initial study; and
WHEREAS, pursuant to CEQA Guidelines Section 15082, on February 26, 2020, the City sent to the Office of Planning and Research and each responsible and trustee agency a Notice of Preparation—which was also published in the Orange City Council 30 – 44 4/19/2022
Resolution No. 2022-XXX

Page 2 of 7 ends

County Register, a newspaper of general circulation in the City of Santa Ana—stating that an environmental impact report would be prepared; and WHEREAS, pursuant to Public Resources Code Section 21083.9 and CEQA Guidelines Sections 15082(c) and 15083, the City held a duly noticed scoping meeting on March 5, 2020, to solicit comments on the scope of the environmental review of the proposed project; and
WHEREAS, a Draft Program Environmental Impact Report (“Draft PEIR”) (State Clearinghouse No. 2020029087) was prepared for the proposed project addressing comments received in response to the Notice of Preparation and evaluating the proposed project’s potentially significant environmental impacts; and WHEREAS, the Draft PEIR identified five significant and unavoidable impacts associated with the project that pertain to Air Quality, Cultural Resources, Greenhouse Gas Emissions, Noise, and Population and Housing; and
WHEREAS, the Draft PEIR further determined that the proposed project would require mitigation related to air quality, biological resources, cultural resources, geology and soils, greenhouse gas emissions, noise, and tribal cultural resources; and WHEREAS, consistent with State CEQA Guidelines Section 15087(e), the Draft PEIR was circulated for review and comment to the public, City Council, Planning Commission, local, regional and state agencies, and interested parties for a 45-day review period, from August 3, 2020, to September 16, 2020, a period that was extended thereafter to October 6, 2020; and
WHEREAS, the City released the Final PEIR, which consists of the Draft PEIR, all technical appendices prepared in support of the Draft PEIR, all written comment letters received on the Draft PEIR, errata to the Draft PEIR and technical appendices; and
WHEREAS, on November 9, 2020, the Planning Commission conducted a duly noticed public hearing to consider the Final PEIR and General Plan Update, at which the Planning Commission voted not to certify the Final PEIR and continue work on the General Plan Update to a future date to allow additional time for outreach to Santa Ana’s environmental justice (EJ) communities and in view of the COVID-19 pandemic; and
WHEREAS, in 2021, a Recirculated Draft Program Environmental Impact Report (“Recirculated Draft PEIR”) was prepared as a supplemental analysis to the original Draft PEIR to reflect updates to the project and based on an intensive, extended community outreach program conducted by the City between January and May 2021; City Council 30 – 45 4/19/2022
Resolution No. 2022-XXX

Page 3 of 7 ends

and
WHEREAS, the Recirculated Draft PEIR provided an update of the project description, and environmental setting and impact analyses for Air Quality, Hazards, and Recreation; incorporated a new alternative; and identified an additional significant unavoidable adverse environmental impact that pertains to Recreation; and WHEREAS, consistent with State CEQA Guidelines Section 15087(e), the Recirculated Draft PEIR was circulated for a 45-day public review period, from August 6, 2021, to September 20, 2021; and
WHEREAS, during the public comment period, copies of the Recirculated Draft PEIR were available for review and inspection at City Hall, on the City’s website, and at the Santa Ana Public Library; and
WHEREAS, during the public comment period, Planning Commission workstudy sessions were held on August 9, 2021 and August 23, 2021, and a public hearing held on September 13, 2021; and
WHEREAS, during the public comment period, the City consulted with and received comments from all responsible and trustee agencies, other regulatory agencies, and others pursuant to CEQA Guidelines Section 15086; and WHEREAS, on November 2, 2021, the City released the Final Recirculated PEIR, attached hereto as Exhibit A, which consists of the Recirculated Draft PEIR, all technical appendices prepared in support thereof, all documents incorporated by reference (including the Final PEIR), all written comment letters received on the Recirculated Draft PEIR, written responses to all written comment letters and verbal comments received on the Recirculated Draft PEIR, revisions to the Recirculated Draft PEIR and technical appendices, and the Mitigation Monitoring and Reporting Program; and
WHEREAS, on November 8, 2021, the Planning Commission conducted a duly noticed public hearing to consider the Final Recirculated PEIR and General Plan Update. After hearing all relevant testimony from staff, the public, and the City’s consultant team, the Planning Commission voted to recommend that the City Council certify the Final Recirculated PEIR, adopt the findings of fact, the statement of overriding considerations, and the mitigation monitoring and reporting program, and approve the project; and
WHEREAS, on December 7, 2021, the City Council held a duly noticed public hearing to consider the Final Recirculated PEIR and General Plan Update, which hearing was successively continued to the City Council meetings on December 21, City Council 30 – 46 4/19/2022
Resolution No. 2022-XXX

Page 4 of 7 ends

2021, January 18, 2022, and February 15, 2022, respectively; and WHEREAS, on February 15, 2022, the City Council heard the matter and afforded members of the public an opportunity to comment. No action on the item resulted; and
WHEREAS, on April 19, 2022, and based on further comments received by City staff, the City Council conducted a duly noticed public hearing to consider the Final Recirculated PEIR, at which hearing members of the public were afforded an opportunity to comment and the project was fully considered; and WHEREAS, all potentially significant adverse environmental impacts were sufficiently analyzed in the Final Recirculated PEIR; and WHEREAS, as contained herein, the City Council has endeavored in good faith to set forth the basis for its decision and recommendations on the project; and WHEREAS, all of the requirements of the Public Resources Code and the State CEQA Guidelines have been satisfied by the City in connection with the preparation of the Final Recirculated PEIR, which is sufficiently detailed so that all of the potentially significant environmental effects of the project have been adequately evaluated; and WHEREAS, all of the findings and conclusions made by the City Council pursuant to this Resolution are based upon the oral and written evidence presented to it as a whole and the entirety of the administrative record for the project, which are incorporated herein by this reference, and not based solely on the information provided in this Resolution; and
WHEREAS, the City Council finds that the project’s environmental impacts that are less than significant without implementation of project-specific mitigation measures, as identified in the Final Recirculated PEIR, are described in Section IV of the Findings of Fact, attached hereto as Exhibit B; and WHEREAS, the City Council finds that the project’s impacts that, without mitigation, would result in significant adverse impacts, and that upon implementation of the mitigation measures provided in the Final Recirculated PEIR, would be considered less than significant, are described in Section V of the Findings of Fact, attached hereto as Exhibit B; and
WHEREAS, the City Council finds that the project’s impacts that, even with mitigation measures, would remain significant and unavoidable are described in Section V of the Findings of Fact, attached hereto as Exhibit B; and City Council 30 – 47 4/19/2022
Resolution No. 2022-XXX

Page 5 of 7 ends

WHEREAS, the City Council finds that the reasonable alternatives to the project are described in Section VI of the Findings of Fact, attached hereto as Exhibit B; and WHEREAS, the Statement of Overriding Considerations that indicates the benefits of the project outweigh the unavoidable significant environmental effects is described in Section VII of the Findings of Fact, attached hereto as Exhibit B; and WHEREAS, all the mitigation measures identified in the Final Recirculated PEIR and necessary to reduce the potentially significant impacts of the project to a level of less than significant are set forth in the Mitigation Monitoring and Reporting Program (MMRP), attached hereto as Exhibit C; and
WHEREAS, prior to taking action, the City Council has heard, been presented with, reviewed, and considered all of the information and data in the administrative record, including but not limited to the Final Recirculated PEIR and all oral and written evidence presented to it during all meetings and hearings; and WHEREAS, the Final Recirculated PEIR reflects the independent judgment of the City Council and is deemed adequate for purposes of making decisions on the merits of the proposed project; and
WHEREAS, no comments made in the public hearing conducted by the City Council and no additional information submitted to the City have produced substantial new information requiring recirculation of the Final Recirculated PEIR or additional environmental review of the project under Public Resources Code Section 21092.1 and CEQA Guidelines Section 15088.5; and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santa Ana as follows:

Section 1. The above recitals are true and incorporated herein by reference.

Section 2. The City Council hereby finds that it has been presented with the Final Recirculated PEIR, which it has reviewed and considered, and further finds that the Final Recirculated PEIR is an accurate and objective statement that has been completed in full compliance with CEQA and the State CEQA Guidelines, and that the Final Recirculated PEIR reflects the independent judgment and analysis of the City, acting as lead agency for the project.

City Council 30 – 48 4/19/2022
Resolution No. 2022-XXX

Page 6 of 7 ends

Section 3. The City Council declares that no evidence of new significant impacts or any new information of “substantial importance,” as defined by State CEQA Guidelines Section 15088.5, has been received by the City after circulation of the Final Draft Recirculated PEIR that would require recirculation of the PEIR.

Section 4. The City Council hereby:

A. Certifies the Final Recirculated PEIR based on the entirety of the record of proceedings.

B. Adopts the Findings of Fact and Statement of Overriding Considerations, attached hereto and incorporated herein as Exhibit B, after balancing the significant and unavoidable air quality, cultural resources, greenhouse gas emissions, noise, recreation, and population and housing impacts of the proposed project against the benefits of the proposed project.

C. Adopts the Mitigation Monitoring and Reporting Program attached hereto and incorporated herein as Exhibit C, consistent with Public Resources Code Section 21081.6; makes implementation of the mitigation measures in the Mitigation Monitoring and Reporting Program a condition of approval of the project; and finds that in the event of any inconsistencies between the mitigation measures set forth herein and the Mitigation Monitoring and Reporting Program, the Mitigation Monitoring and Reporting Program shall control.

D. Approves the project, based upon the entire record before it, including the Final Recirculated PEIR, Findings of Fact and Statement of Overriding Considerations, and all written and oral evidence presented.

E. Directs City staff to cause a Notice of Determination to be filed and posted with the County of Orange Registrar-Recorder/County Clerk and the State Clearinghouse within five working days of the City Council’s final project approval.

Section 5. This Resolution shall take effect immediately upon its adoption by the City Council, and the Clerk of the Council shall attest to and certify the vote adopting this Resolution.

ADOPTED this _____ day of ____________, 2022.
________________________________
Vicente Sarmiento
Mayor
City Council 30 – 49 4/19/2022
Resolution No. 2022-XXX

Page 7 of 7 ends

APPROVED AS TO FORM:

Sonia R. Carvalho, City Attorney
By:

John M. Funk
Sr. Assistant City Attorney
AYES: Councilmembers
NOES: Councilmembers
ABSTAIN: Councilmembers
NOT PRESENT: Councilmembers _

CERTIFICATION OF ATTESTATION AND ORIGINALITY
I, DAISY GOMEZ, Clerk of the Council, do hereby attest to and certify the attached Resolution No. 2022-XXX to be the original resolution adopted by the City Council of the City of Santa Ana on _______________.

Date: ______________________ ________________________________ Clerk of the Council
City of Santa Ana
City Council 30 – 50 4/19/2022

EXHIBIT A
All materials for Exhibit A may be accessed at: https://www.santa-ana.org/generalplan/general-plan-environmental-documents and are also on file and available at the City’s Planning and Building Agency.

City Council 30 – 51 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -1- October 2021
Exhibit B

CEQA FINDINGS OF FACT

FOR THE

SANTA ANA GENERAL PLAN UPDATE

FINAL RECIRCULATED PROGRAM ENVIRONMENTAL IMPACT REPORT
City of Santa Ana
STATE CLEARINGHOUSE NO. 2020029087
I. INTRODUCTION
The California Environmental Quality Act (“CEQA”) requires that a number of written findings be made by the lead agency in connection with certification of an environmental impact report (“EIR”) prior to approval of the project pursuant to Sections 15091 and 15093 of the CEQA Guidelines and Section 21081 of the Public Resources Code. The State CEQA Guidelines Section 15091 provides:
(a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are:

1. Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the EIR.

2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can or should be adopted by such other agency.

3. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.
(b) The findings required by subdivision (a) shall be supported by substantial evidence in the record.
(c) The finding in subdivision (a)(2) shall not be made if the agency making the finding has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The finding in subsection (a)(3) shall describe the specific reasons for rejecting identified mitigation measures and project alternatives.

City Council 30 – 52 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -2- October 2021
(d) When making the findings required in subdivision (a)(1), the agency shall also adopt a program for reporting on or monitoring the changes which it has either required in the project or made a condition of approval to avoid or substantially lessen significant environmental effects. These measures must be fully enforceable through permit conditions, agreements, or other measures.
(e) The public agency shall specify the location and custodian of the documents or other materials which constitute the record of the proceedings upon which its decision is based.
(f) A statement made pursuant to Section 15093 does not substitute for the findings required by this section.

Public Resources Code Section 21061.1 defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.” CEQA Guidelines section 15364 adds another factor: “legal” considerations. (See Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 565 (Goleta II).)
The concept of “feasibility” also encompasses the question of whether a particular alternative or mitigation measure promotes the underlying goals and objectives of a project. (California Native Plant Soc. v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001 [“an alternative ‘may be found infeasible on the ground it is inconsistent with the project objectives as long as the finding is supported by substantial evidence in the record’”].) An alternative may also be rejected because it “would not ‘entirely fulfill’ [a] project objective.” (Citizens for Open Government v. City of Lodi (2012) 205 Cal.App.4th 296, 314-315.) “[F]easibility” under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors.” (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.)
With respect to a project for which significant impacts are not avoided or substantially lessened, a public agency, after adopting proper findings, may nevertheless approve the project if the agency first adopts a statement of overriding considerations setting forth the specific reasons why the agency found that the project's “benefits” rendered “acceptable” its “unavoidable adverse environmental effects.” (CEQA Guidelines, §§ 15093, 15043, subd. (b); see also Pub. Resources Code, § 21081, subd. (b).) The California Supreme Court has stated, “[t]he wisdom of approving . . . any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced.” (Goleta II, supra, 52 Cal.3d at p. 576.) When adopting Statements of Overriding Considerations, State CEQA Guidelines Section 15093 further provides:

City Council 30 – 53 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -3- October 2021
(a) CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposal project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.”
(b) Where the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the final EIR and/or other information in the record. This statement of overriding considerations shall be supported by substantial evidence in the record.
(c) If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091.

Having received, independently reviewed, and considered the Draft Program Environmental Impact Report (“Draft PEIR”), the Final Program Environmental Impact Report (“Final PEIR), the Recirculated Draft Program Environmental Impact Report (“Recirculated Draft PEIR”), and the Final Recirculated Program Environmental Impact Report (“Final Recirculated PEIR”) for the Santa Ana General Plan Update, SCH No. 2020029087 (collectively, the “PEIR”), as well as all other information in the record of proceedings on this matter, the following Findings of Facts (“Findings”) are hereby adopted by the City of Santa Ana (“City”) in its capacity as the CEQA Lead Agency.

These Findings set forth the environmental basis for the discretionary actions to be undertaken by the City for adoption and implementation of the Santa Ana General Plan Update (“Proposed Project”). This action includes the certification of the following:
 Santa Ana General Plan Update Program Environmental Impact Report, SCH No. 2020029087
A. DOCUMENT FORMAT
These Findings have been organized into the following sections:
1) Section I provides an introduction.
2) Section II provides a summary of the project, overview of the discretionary actions required for approval of the project, and a statement of the project’s objectives.

City Council 30 – 54 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -4- October 2021
3) Section III provides a summary of previous environmental reviews related to the project area that took place prior to the environmental review done specifically for the project, and a summary of public participation in the environmental review for the project. 4) Section IV sets forth findings regarding the environmental impacts that were determined to be—as a result of the Notice of Preparation (NOP) and consideration of comments received during the NOP comment period—either not relevant to the project or clearly not at levels that were deemed significant for consideration given the nature and location of the proposed project.
5) Section V sets forth findings regarding significant or potentially significant environmental impacts identified in the PEIR that the City has determined are either not significant or can feasibly be mitigated to a less than significant level through the imposition of project design features and/or mitigation measures. In order to ensure compliance and implementation, all of these measures are included in the Mitigation Monitoring and Reporting Program (“MMRP”) for the project and adopted as conditions of the project by the Lead Agency. Where potentially significant impacts can be reduced to less than significant levels through adherence to project design features and/or mitigation measures, these findings specify how those impacts were reduced to an acceptable level. Section V also includes findings regarding those significant or potentially significant environmental impacts identified in the PEIR that will or may result from the project and which the City has determined cannot feasibly be mitigated to a less than significant level.
6) Section VI sets forth findings regarding alternatives to the proposed project. 7) Section VII sets forth the statement of overriding considerations for the proposed project. 8) Section VIII sets forth the resolution regarding certification of the PEIR 9) Section IX sets for the resolution adopting a mitigation and monitoring plan for the proposed project.
10) Section X sets for the resolution regarding custodian of records for the proposed project.

B. RECORD OF PROCEEDINGS
For purposes of CEQA and these Findings, the Record of Proceedings for the proposed project consists of the following documents and other evidence, at a minimum:
 The NOP and all other public notices issued by the City in conjunction with the proposed project
 The Draft PEIR for the proposed project
 The Recirculated Draft PEIR
City Council 30 – 55 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -5- October 2021
 The Final PEIR for the proposed project
 The Final Recirculated PEIR for the proposed project including the Updated Draft PEIR (Volume II and III of the Final Recirculated PEIR)
 All written comments submitted by agencies or members of the public during the public review comment period on the Draft PEIR
 All written comments submitted by agencies or members of the public during the public review comment period on the Recirculated Draft PEIR
 All responses to written comments submitted by agencies or members of the public during the public review comment period on the Draft PEIR
 All responses to written comments submitted by agencies or members of the public during the public review comment period on the Recirculated Draft PEIR  All written and verbal public testimony presented during a noticed public hearing for the proposed project
 The Mitigation Monitoring and Reporting Program
 The reports and technical memoranda included or referenced in the Response to Comments  All documents, studies, EIRs, or other materials incorporated by reference in the Draft PEIR, Recirculated Draft PEIR, Final PEIR and Final Recirculated PEIR  The Resolutions adopted by the City of Santa Ana in connection with the proposed project, and all documents incorporated by reference therein, including comments received after the close of the comment period and responses thereto
 Matters of common knowledge to the City of Santa Ana, including but not limited to federal, state, and local laws and regulations
 Any documents expressly cited in these Findings
 Any other relevant materials required to be in the record of proceedings by Public Resources Code Section 21167.6(e)
The documents and other material that constitute the record of proceedings on which these findings are based are located at the City of Santa Ana Planning Division Counter. The custodian for these documents is the City of Santa Ana. This information is provided in compliance with Public Resources Code Section 21081.6(a)(2) and 14 California Code Regulations Section 15091(e).

C. CUSTODIAN AND LOCATION OF RECORDS
The documents and other materials that constitute the administrative record for the City’s actions related to the project are at the City of Santa Ana Planning Division, 20 Civic Center Plaza, M-20, City Council 30 – 56 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -6- October 2021
Santa Ana, CA 92701. The City’s Planning Division is the custodian of the administrative record for the project. Copies of these documents, which constitute the record of proceedings, are and at all relevant times have been and will be available upon request at the offices of the Planning Division Counter. This information is provided in compliance with Public Resources Code Section 21081.6(a)(2) and 14 California Code Regulations Section 15091(e).

City Council 30 – 57 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -7- October 2021
II. PROJECT SUMMARY
A. PROJECT LOCATION
Santa Ana is in the western central portion of Orange County, approximately 30 miles southwest of the city of Los Angeles and 10 miles northeast of Newport Beach. Orange County is surrounded by the counties of Los Angeles, San Bernardino, Riverside, and San Diego and is one of six counties comprising the Southern California Region.

Santa Ana is bordered by Orange and unincorporated areas of Orange County to the north, Tustin to the east, Irvine and Costa Mesa to the south, and Fountain Valley and Garden Grove to the west. In November 2019, the City annexed the 17th Street Island, a 24.78-acre area in the northeast portion of the city. The 17th Street Island is bounded by State Route 55 to the east, 17th Street to the south, and North Tustin Avenue to the west. The city also includes a portion of the Santa Ana River Drainage Channel in its sphere of influence (SOI). The city and its SOI are defined and referred to herein as the plan area.

Regional access to the city is provided by the Garden Grove Freeway (SR-22) and the Orange Freeway (SR-57) on the north, the Santa Ana Freeway (1-5) on the northeast, the Costa Mesa Freeway (SR-55) on the east, and the San Diego Freeway (l-405) on the south.

B. PROJECT DESCRIPTION
In March 2014, the City Council adopted the Santa Ana Strategic Plan. The Strategic Plan was the result of an extensive community outreach process and established specific goals, objectives, and strategies to guide the City’s major efforts. One of the key strategies identified was to complete a comprehensive update of the existing General Plan. The General Plan Update (GPU) will provide long-term policy direction to guide the physical development, quality of life, economic health, and sustainability of the Santa Ana community through 2045. The General Plan Update will identify areas of opportunity and provide options to enhance development potential in key areas of the city. It will also bring the city into compliance with recent State laws, reflect current conditions, and incorporate input from the general public, City staff, and other stakeholders.

The proposed GPU is organized into three sections: I, Services and Infrastructure; II, Natural Environment; and III, Built Environment. The proposed GPU addresses the eight topics required by state law as well as five optional topics. State law gives jurisdictions the discretion to incorporate optional topics and to address any of these topics in a single element or across multiple elements of the general plan. The 12 proposed elements of the GPU will replace the 16 elements of the current General Plan. The GPU will incorporate the current 2014–2021 housing element, and no substantive changes are anticipated. The topic of housing will be addressed as a separate effort in early 2022 in accordance with State law. The topic of environmental justice will be incorporated throughout the GPU, with goals and policies incorporated into multiple elements. The 12 elements of the proposed General Plan update are:

City Council 30 – 58 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -8- October 2021
Mandatory Topics Optional Topics
 Land Use Element
 Circulation Element
 Housing Element
 Open Space Element
 Conservation Element
 Safety Element
 Noise Element
 Public Services Element
 Urban Design Element
 Community Element
 Economic Prosperity Element
 Historic Preservation Element
The proposed GPU is comprehensive both in its geography and subject matter. It addresses the entire territory within the plan area’s boundary and the full spectrum of issues associated with management of the plan area. The GPU also includes forecasts of long-term conditions and outlines development goals and policies; exhibits and diagrams; and the objectives, principles, standards, and plan proposals throughout its various elements. The GPU can be found online at https://www.santa-ana.org/general-plan. The General Plan Policy Framework can be accessed at
https://www.santa-ana.org/sites/default/files/pb/generalplan/documents/GeneralPlanPolicyFrameworkMaster.DRAFT.cmo2.pdf.

Coordination and consistency are essential between the elements of the GPU, but in particular with the land use element. The circulation element, which identifies proposed improvements to the transportation system, may impact surrounding land uses and future development. The urban design element sets forth policies and programs to improve the city’s design and urban form. The conservation element protects and maintains the city’s natural, cultural, and other resources, with a focus on preserving aesthetics and the environmental quality of the city.

Both the land use element and the circulation element are described in more depth below. Focus areas and specific plan/special zoning areas are also described.

Updated Land Use Element
The updated land use element will guide growth and development (e.g., infill development, redevelopment, use, and revitalization/restoration) within the plan area by designating land uses as shown in the proposed land use map. Figure 3-7 of the Updated Draft PEIR (Volume II of the Final Recirculated PEIR) shows the 13 proposed land use designations of the General Plan update, and Table 3-4 gives a general description of the land use designations that are added to the GPU and were not in the current General Plan. Land use designations define the type and nature of development that would be allowed in a given location of the plan area. The land use designations and patterns are intended to provide the basis for more detailed zoning designations and development intensities, requirements, and standards established in the City’s development code.

It is important to note that the updated land use element is a regulatory document that defines the framework for future growth and development in the plan area but does not directly result in City Council 30 – 59 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -9- October 2021
development in and of itself. Before any project can be developed in the plan area, it must be analyzed for conformance with the General Plan Update, zoning requirements, and other applicable local and state requirements; comply with the requirements of CEQA; and obtain all necessary clearances and permits.

Updated Circulation Element
The circulation element update is integrally related to federal, state, and regional transportation programs as well as local plans and regulations. The City’s role in transportation planning has become increasingly important because recent legislation in the areas of growth management, congestion management, and air quality require more active local coordination to meet regional objectives. Furthermore, the circulation element update is intended to guide future development of the city’s transportation system in a manner consistent with the updated land use element.

The Master Plan of Streets and Highways (MPSH) details proposed street classifications to reflect buildout of the city’s roadway system. The street classifications include Freeway, Major Arterial, Primary Arterial, Secondary Arterial, Divided Collector Arterial, and Collector Arterial. As part of the implementation of complete streets principles,1 a series of modifications to the city’s roadway network has been identified and includes both the reclassification of roadways and assignment of new MPSH roadway classifications to selected existing streets.

A number of proposed roadway reclassifications, adoptions, and removals from the MPSH are as follows:
 Reclassified as Divided Collector Arterial:
 Santa Clara Avenue west of Tustin Avenue (currently Secondary Arterial)  Flower Street between Warner Avenue and 1st Street (currently Secondary Arterial)  Chestnut Avenue between Standard Avenue and eastern city limit (currently Secondary/Primary Arterial)
 Raitt Street between Segerstrom Avenue and Santa Ana Boulevard (currently Secondary Arterial)
 Civic Center Drive between Fairview Street and Bristol Street (currently Secondary Arterial)
 Penn Way between I-5 on/off ramps and Washington Avenue (currently Secondary Arterial)
 Santiago Street between 15th Street and 6th Street (currently Secondary Arterial)  Standard Avenue between 6th Street and Warner Avenue (currently Secondary Arterial) 1 Complete streets are transportation facilities that are planned, designed, operated, and maintained to provide safe mobility for all users, including bicyclists, pedestrians, transit vehicles, truckers, and motorists, appropriate to the function and context of the facility.

City Council 30 – 60 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -10- October 2021
 Santa Ana Boulevard between French Street and Santiago Street (currently Primary Arterial)
 Santa Ana Boulevard between Raitt Street and Flower Street (currently Major Arterial)  Cambridge Street between Fairhaven Avenue and SR-22 freeway (currently Local Arterial)
 Hazard Avenue between Euclid Street and Harbor Boulevard (currently Secondary Arterial)
 Halladay Avenue between Warner Avenue and Dyer Road (currently Secondary Arterial)  McFadden Avenue between Harbor Boulevard and Grand Avenue (currently Secondary Arterial)
 Broadway between 1st Street and 17th Street (currently Secondary Arterial)  4th Street between French Street and Grand Avenue (currently Primary/Secondary Arterial)
 Fairhaven Avenue from Grand Avenue to Tustin Avenue (currently Secondary Arterial)  Reclassified as Primary Arterial:
 Santa Ana Boulevard between Flower Street and Ross Street (currently a Major Arterial)  1st Street between Bristol Street and Tustin Avenue (currently Major Arterial)  Reclassify as Collector Arterial:
 Civic Center Drive between French Street and Santiago Street (currently a Secondary Arterial)
 Add the following to the MPSH as Divided Collector Arterial:
 Greenville Street between Segerstrom Avenue and Warner Avenue  Add the following to the MPSH as Collector Streets:
 Civic Center Drive between Spurgeon Street and Santiago Street (currently Local Street)  Broadway from Anahurt Street to Main Street (currently Local Road)  Remove the following from the MPSH
 Memory Lane from the City Center Drive to SR-22
 Wright Street from 14th Street to Fruit Street
 4th Street from French Street to Ross Street
 Washington Avenue from Broadway to Main Street
 10th street from Broadway to Main Street
 Columbine Avenue from Main Street to 55 FWY
 Halladay street from Dyer Road to Alton pkwy
City Council 30 – 61 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -11- October 2021
The majority of the proposed reclassifications aim to reduce existing rights-of-way for vehicular traffic lanes to make room for bicycle and pedestrian improvements. Landmark streets are also identified within or adjacent to the Santa Ana Downtown Historic District, which is listed on the National Register of Historic Places.

The circulation element update incorporates the proposed Santa Ana-Garden Grove Fixed Guideway project, which will introduce new transit service to the city. Santa Ana is working with Garden Grove and Orange County Transit Authority to build a fixed guideway system called the OC Streetcar. Expected to begin operations in 2021, the OC Streetcar will link the Santa Ana Regional Transportation Center to a new multimodal hub at Harbor Boulevard/Westminster Avenue in Garden Grove. OC Streetcar will serve historic downtown Santa Ana and Civic Center.

Along its four-mile route, OC Streetcar will connect with 18 Orange County Transit Authority bus routes and increase transportation options along Santa Ana Boulevard, 4th Street, the Pacific Electric right-of-way, and Harbor Boulevard.

Focus Areas

1. South Main Street Focus Area
The South Main Street focus area introduces the opportunity for greater flexibility and a more dynamic mix of land uses and urban design along the properties fronting Main Street. The intent is to transition an auto-dominated corridor into a transit- and pedestrian-friendly corridor through infill development without disrupting the surrounding lower-density neighborhoods. The objectives of this focus area are:
 Facilitate redevelopment and property improvements along Main Street.  Create a more active and dynamic streetscape.
 Protect established residential neighborhoods.
 Support transit, pedestrian, and nonmotorized travel.

The majority of properties fronting Main Street will be designated Urban Neighborhood, allowing for future development to include commercial uses, low- and medium-density housing, or a combination of both in a vertically mixed-use format. South of Warner Avenue, the Industrial/Flex designation will offer new options for small-scale manufacturing, live-work, and retail opportunities.

The balance of the focus area will remain designated for Low Density Residential or Institutional to reflect the existing development patterns and land uses. New buildings and spaces will be sensitive to the surrounding low-density neighborhoods while still emphasizing the creation of active and attractive urban spaces.

2. Grand Avenue / 17th Street Focus Area
The Grand Avenue / 17th Street focus area will foster the development of an urban mixed-use corridor connecting into the city’s downtown and transit core. The intent is to create opportunities City Council 30 – 62 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -12- October 2021
for a new mix of land uses and design to transition Grand Avenue from a series of auto-oriented shopping plazas to a series of dynamic urban spaces. The objectives of this focus area are:
 Create mixed-use corridors and urban villages.
 Promote infill development while respecting established neighborhoods.  Foster community spaces and neighborhood-serving amenities.  Develop opportunities for live-work, artist spaces, and small-scale manufacturing.  Maintain compatible nodes of commercial activity.

The majority of land in this focus area is planned for Urban Neighborhood or District Center land use designations, which will allow a blend of residential and commercial uses to develop simultaneously, as market conditions allow. An intense mixed-use area is envisioned adjacent to the Santa Ana Regional Transportation Center, along the east side of Grand Avenue south of I-5.

This part of the focus area will support larger, more visually dynamic buildings and urban spaces that complement and benefit from the adjacent regional transit center.

North of I-5, the buildings and spaces will be sensitive to the surrounding low-density neighborhoods but will still emphasize the creation of active and attractive urban spaces. A mix of residential, retail, and office will be interspersed along the frontage of Grand Avenue, with a concentrated node of commercial and mixed-use residential uses at Grand Avenue and 17th Street. A small portion of the focus area is designated for Industrial/Flex and General Commercial to support small-scale manufacturing, live-work, and retail opportunities will be located along 17th Street near the Regional Transportation Center.

3. West Santa Ana Boulevard Focus Area
The West Santa Ana Boulevard focus area connects the Harbor Mixed Use Transit Corridor Specific Plan area and Downtown Santa Ana, and the OC Streetcar Project improvements will create the physical transit link in 2022. The intent is to transition a group of auto-oriented neighborhoods, businesses, and institutions into a series of transit-oriented neighborhoods that support and benefit from future streetcar stops. The objectives of this focus area are:
 Develop housing and mixed-use opportunities near streetcar stations.  Promote infill development while respecting established neighborhoods.  Buffer industrial land uses and residential neighborhoods.  Create opportunities for clean industrial/maker-type spaces.

4. 55 Freeway / Dyer Road Focus Area
The 55 Freeway / Dyer Road focus area will transition from almost exclusively professional office to a range of commercial, industrial/flex, and mixed-use development. The intent is to create opportunities for a truly urban lifestyle with easy access to Downtown Santa Ana, multiple transit options, and the new investments and amenities in adjacent communities. The objectives of this focus area are:
 Provide housing opportunities at an urban level of intensity at the city’s edge.

City Council 30 – 63 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -13- October 2021
 Enhance opportunities for corporate offices.
 Attract economic activity into the city from surrounding communities.  Protect industrial and office employment base.
 Maintain hotel and commercial uses.

The overall scale and experience of the focus area along the freeway and city boundary will reflect an urban intensity and design, with inspiring building forms and public spaces. At the southeastern edge, the District Center land use designation will facilitate large residential mixed-use developments in structures that incorporate high-density housing, hotels, and complementary expansions of commercial uses. Adjacent to the 55 freeway, the Industrial/Flex land use designation will promote large-scale office-industrial flex spaces, multilevel corporate offices, and research and development uses.

The node surrounding the freeway interchange will remain as currently planned for General Commercial uses, with new improvements introducing development and spaces that complement the existing examples and elements.

South Bristol Street Focus Area
The South Bristol Street focus area represents Santa Ana’s southern gateway and is a part of the South Coast Metro area. Between Sunflower and Alton Avenues, the District Center land use designation will create opportunities to transform auto-oriented shopping plazas to walkable, bikefriendly, and transit-friendly urban villages that incorporate a mix of high intensity office and residential living with experiential commercial uses. The objectives of this focus area are:
 Capitalize on the success of the South Coast Metro area.  Introduce mixed-use urban villages and encourage experiential commercial uses that are more walkable, bike friendly, and transit oriented.
 Provide for mixed-use opportunities while protecting adjacent, established, low-density neighborhoods.

Between MacArthur Boulevard and Alton Avenue, the form and intensity will scale down but remain distinctly urban in nature. The redevelopment of the auto-oriented commercial plazas will result in the construction of landmark buildings and structures set in and around spaces accessible to future occupants and the general public. The corridor north of Alton Avenue is planned with the Urban Neighborhood land use designation, allowing for commercial and residential projects, frequently in a mixed-use format, to develop in accordance with market fluctuations. The buildings and spaces in this part of the focus area will be sensitive to the surrounding low-density neighborhoods but will still emphasize the creation of active and attractive urban spaces.

City Council 30 – 64 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -14- October 2021
Specific Plan/Special Zoning
There are seven planning areas that represent specific plans and other special zoning areas that were previously adopted: Adaptive Reuse Project Incentive Area (2014), Bristol Street Corridor Specific Plan (1991/2018), Harbor Mixed Use Transit Corridor Specific Plan (2014), MainPlace Specific Plan (2019), Metro East Mixed-Use Overlay Zone (2007/2018), Midtown Specific Plan (1996), and Transit Zoning Code Specific Development (2010). The most recent adoption/amendment date for each document is noted in parentheses.

Adaptive Reuse Project Incentive Area
The Adaptive Reuse Ordinance, Section 41-1651 of the Santa Ana Municipal Code, provides alternative building and fire standards for the conversion of eligible buildings, or portions thereof, from nonresidential uses to dwelling units, guest rooms or joint living, and work quarters. Eligible structures are buildings within the Adaptive Reuse project incentive area that were constructed in accordance with building and zoning codes in effect prior to July 1, 1974, or which have been determined to be a Historically Significant. The Project Incentive Area includes properties in the Midtown Specific Plan area; the Transit Zoning Code area; the Metro East Mixed-Use Overlay Zone; the North Main Street Corridor on both sides of Main Street, from 17th Street to the northernmost MainPlace Drive; and the East 1st Street Corridor on both sides of 1st Street from Grand Avenue to Elk Lane. Residential uses are allowed in the Project Incentive Area irrespective of the underlying zoning as part of an approved Adaptive Reuse Project.

Harbor Mixed Use Transit Corridor Specific Plan
The Harbor Mixed Use Transit Corridor Specific Plan covers the 2.5-mile segment of Harbor Boulevard on the west side of Santa Ana. The approximately 305-acre planning area includes parcels adjacent to Harbor Boulevard between Westminster Avenue and Lilac Avenue as well as parcels along Westminster Avenue, 1st Street, and 5th Street. The Harbor Mixed Use Transit Corridor Specific Plan creates the zoning necessary to take advantage of the regional and local transit investments made along and around Harbor Boulevard. The plan expands development options to include residential alongside or integrated into a mix of nonresidential uses.

MainPlace Specific Plan
The purpose of the MainPlace Specific Plan is to transform MainPlace mall into a family‐oriented retail, entertainment, and dining destination. The plan creates a mixed-use urban village with a revitalized mall at its central core. The Specific Plan area is on the north edge of Santa Ana, between Main Street on the east and SR-22 and I-5 to the north and west. The property is identified in the current General Plan land use element as District Center. The District Center designation includes the major activity areas of the city, designed to serve as anchors to the city’s commercial corridors and to accommodate major development activity. No General Plan amendment is required for the specific plan, and the MainPlace Specific Plan is the zoning for the property and defines the allowable uses within its boundaries.

City Council 30 – 65 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -15- October 2021
Metro East Mixed-Use Overlay Zone
The Metro East Mixed Use (MEMU) Overlay Zone consists of an original MEMU Overlay Zone and an expansion component. The original MEMU Overlay Zone is largely developed with commercial and office uses and comprises approximately 200 acres immediately east of the I-5 and immediately west of SR-55. It is bounded by I-5 on the west and south, Tustin Avenue on the east, and East Sixth Street on the north. The MEMU expansion area added 33.52 acres or approximately 48 parcels to the original MEMU Overlay Zone area. The additional project area extends west primarily along First Street and is generally bounded by the I-5 to the east, Grand Avenue to the west, East Chestnut Avenue to the south, and Fourth Street to the north.

The overall objectives of the MEMU Overlay Zone are to encourage a more active commercial and residential community, provide an expanded economic base, maximize property sales tax revenues, improve the jobs/housing balance within the city, and provide for a range of housing options identified in the 2014 housing element.

Midtown Specific Plan
The Midtown Specific Plan area is generally bounded by 17th Street to the north, Civic Center Drive to the south, North Ross Street to the west, and North Spurgeon Street to the east. The Midtown area is readily accessible from the Santa Ana Freeway (I-5). Midtown is envisioned as an integrated district of civic, business, cultural, and retail activity with a small residential component.

Transit Zoning Code Specific Development
The City adopted a Transit Zoning Code to provide zoning for the integration of new infill development into existing neighborhoods; to allow for the reuse of existing structures; to provide for a range of housing options, including affordable housing; and to provide a transit-supportive, pedestrian-oriented development framework to support the addition of new transit infrastructure.

The code encompasses an area in the central urban core of Santa Ana that comprises over 100 blocks and 450 acres. The area is west of I-5 and bounded by First Street on the south, Flower Street on the west, Grand Avenue on the east, and Civic Center Drive on the north.

General Plan Buildout Scenario
In general, many areas currently designated for General Commercial and Professional Office will expand opportunities for residential development by a proposed change in General Plan land use designation to Urban Neighborhood or District Center. Industrial Flex will be introduced in each of the five focus areas and replace Industrial land use designations that currently exist to allow for cleaner industrial and commercial uses with live-work opportunities.

Furthermore, state law allows a graduated density bonus for the inclusion of affordable housing units For an increasing amount of affordable units (by percentage), a project is allowed an increasing ability to exceed the permitted density (up to a cap of 35 percent). Recent updates to state housing law (Assembly Bill 1763, effective January 1, 2020), enables projects that are 100 City Council 30 – 66 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -16- October 2021
percent affordable (either 100 percent lower income or 80 percent lower and 20 percent limited moderate), to obtain a density bonus of 80 percent, or no limit if within one-half mile of a major transit stop. However, not every proposed project pursuant to the GPU would include affordable units, and not every project that includes affordable units would need a density bonus. Proposed projects pursuant to the GPU are not required to build at densities that exceed maximum limits; the law only requires that jurisdictions grant the density bonus if requested. The buildout methodology for the GPU was based on past development trends, current development trends, and a forecast market analysis. These trends accounted for any units approved (density bonus or otherwise), to determine the appropriate density and amount of development to assume.

Additionally, the optimal density of affordable units is at or below the density levels assumed for forecasting buildout. Generally, projects beyond 50 to 70 units per acre require Type 1 construction (steel and concrete structure), which is much more expensive than Type V construction (wood structure). Accordingly, affordable projects are rarely greater than 70 units per acre except for very small parcels. The average densities used to calculate projected buildout at 2045 are 50 to 90 units per acre in the three most intense focus areas; 55 Freeway/Dyer Road, Grand Avenue/17th Street, and South Bristol Street focus areas. For the remaining two focus areas, a residential assumption at 30 units per acre was used over a broad area to account for development at or above the maximum density of 30 units per acre. The maximum is 20 units per acre for projects proposed exclusively residential in the South Main Focus Area. The maximum is 30 units per acre for a relatively small part of the West Santa Ana Boulevard Focus Area. The City’s buildout projections are therefore considered to include and account for the application of density bonus provisions of state law to future projects.

Furthermore, the potential for development in specific plan and special zoning areas is based on the forecast buildout at the time of the respective zoning document’s adoption, minus the amount of new development built between the adoption date and 2019.

Growth outside of the focus areas and special planning areas is expected to be incremental and limited. Some growth was projected for the professional office surrounding the Orange County Global Medical Center and along Broadway north of the Midtown Specific Plan. Some growth was also projected for the commercial and retail area south of the West Santa Ana Boulevard focus area. Finally, some additional residential development is expected on a small portion (5 percent) of single-family and multifamily lots through the construction of second units.

For the focus areas, the forecast buildout is based on development at approximately 80 percent of the maximum allowed development for each respective land use designation.

C. DISCRETIONARY ACTIONS AND APPROVALS
Project development requires the following discretionary actions and approvals from the City:
 Adoption of the Santa Ana General Plan update
 Certification of PEIR
City Council 30 – 67 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -17- October 2021
 Adoption of Findings of Fact and Statement of Overriding Considerations  Adoption of the Mitigation Monitoring Program
 Adoption of any ordinances, guidelines, programs, actions, or other mechanisms that implement the Santa Ana General Plan update
D. STATEMENT OF PROJECT OBJECTIVES
The updated General Plan is based on a vision statement and core values established as part of an extensive, multiyear community outreach effort. The City has identified the following core values to guide the General Plan Update (GPU):
 Health. The people of Santa Ana value a physical environment that encourages healthy lifestyles, a planning process that ensures that health impacts are considered, and a community that actively pursues policies and practices that improve the health of our residents.
 Equity. Residents value taking all necessary steps to ensure equitable outcomes, expanding access to the tools and resources that residents need, and balancing competing interests in an open and democratic manner.
 Sustainability. Santa Ana values land use decisions that benefit future generations, plans for the impacts of climate change, and incorporates sustainable design practices at all levels of the planning process.
 Culture. The Santa Ana’s community values efforts that celebrate our differences as a source of strength, preserve and build upon existing cultural resources, and nurture a citywide culture of empowered residents.
 Education. Santa Ana values the creation of lifelong learners, the importance of opening up educational opportunities to all residents, and investing in educational programs that advance residents’ economic well-being.

These core values were used as the basis to define more specific project objectives to aid decision makers in their review of the GPU and associated environmental impacts. The objectives include:

1. Promote infill development while respecting and protecting established neighborhoods.

2. Optimize high density residential and mixed-use development that maximizes potential use of mass transit.

3. Provide locations for new housing development that maximizes affordable housing opportunities to achieve both City and regional housing goals.

4. Facilitate new development at intensities sufficient to generate community benefits and attract economic activity.

City Council 30 – 68 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -18- October 2021

5. Provide housing and employment opportunities at an urban level of intensity at the City’s edge.

6. Introduce mixed-use urban villages and encourage experiential commercial uses that are more walkable, bike-friendly, and transit-oriented.

7. Develop opportunities for live/work, artist spaces, and small-scale manufacturing.

City Council 30 – 69 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -19- October 2021
III. ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION PROCESS In conformance with CEQA, the State CEQA Guidelines, and the City of Santa Ana CEQA Guidelines, the City conducted an extensive environmental review of the proposed project.  The City of Santa Ana concluded that a PEIR should be prepared, and the Notice of Preparation (NOP) was released for a 30-day public review period from February 26, 2020, through March 27, 2020. The NOP was posted at the Orange County Clerk’s Office on February 26, 2020. The notice was published in the Orange County Register, a newspaper of general circulation. Under CEQA, a lead agency may proceed directly with preparation of a PEIR without preparation of an Initial Study if it is clear that a PEIR will be required (State CEQA Guidelines § 15060[d]). The City of Santa Ana made such a determination for this project and did not prepare an Initial Study.
 Completion of a scoping process, in which the public was invited by the City of Santa Ana to participate. The scoping meeting for the PEIR was held on March 5, 2020, at 6:00 p.m. at the Santa Ana Police Community Room at 60 Civic Center Plaza in Santa Ana. The notice of a public scoping meeting was included in the NOP distributed on February 26, 2020.  Preparation of a Draft PEIR by the City of Santa Ana, which was made available for a 45- day public review period (August 3, 2020, through September 16, 2020) and extended to October 6, 2020. The Notice of Availability (NOA) for the Draft PEIR was sent to all persons, agencies, and organizations on the list interested persons, sent to the State Clearinghouse in Sacramento for distribution to public agencies, and published in the August 3, 2020, Orange County Register. The NOA was posted at the Orange County Clerk’s Office on August 3, 2020.

Copies of the Draft PEIR were made available for public review at the City of Santa Ana, Planning Division Counter at 20 Civic Center Plaza, M-20, Santa Ana, CA 92701, and the City of Santa Ana Public Library at 26 Civic Center Plaza, Santa Ana, CA 92701. The Draft EIR was also available for review and download on City website: https://www.santaana.org/general-plan.  The Final PEIR contained comments on the Draft PEIR, responses to those comments, revisions to the Draft PEIR, if any, and appended documents. The Final PEIR was released for a 10-day agency review period prior to certification of the Final PEIR.  At its November 9, 2020, public hearing, the Planning Commission voted not to certify the Final PEIR and continue work on the GPU to a future date to allow additional time for outreach to Santa Ana’s environmental justice (EJ) communities.
 The City performed an intensive, extended community outreach program conducted between January and May 2021 as described in Section 2.4 of the Updated Draft PEIR (Volume II of the Recirculated Final PEIR).
 Pursuant to Draft PEIR comments, the Planning Commission public hearing, and an expanded EJ community outreach program, the City made the decision to prepare a City Council 30 – 70 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -20- October 2021
Recirculated Draft PEIR to discuss and evaluate impacts related to environmental justice, to conclude that the recreation-related impacts of the proposed GPU would result in a significant impact, and to define a new project alternative to reduce recreational impacts.  The City recirculate the Draft PEIR chapters that had been revised and the NOA was released for a 45-day public review period from August 6, 2021 through September 20, 2021. The NOA directed reviewers to only submit comments on the revised Draft PEIR chapters included in the Recirculated Draft PEIR since the comments in the Final PEIR adequately addressed comments received on portions of the Draft PEIR that had not been recirculated.  One September 13th, the City conducted a Planning Commission Study Session to discuss the Recirculated Draft PEIR. Verbal comments from the public, received during the Study Session were addressed in the Final Recirculated PEIR.
 After considering the PEIR and in conjunction with making these findings, the City of Santa Ana hereby finds that, pursuant to Section 15092 of the CEQA Guidelines, approval of the project will result in significant effects on the environment; however, the significant effects will be eliminated or substantially lessened where feasible, and the City has determined that remaining significant effects are acceptable under Section 15093.  The Mitigation Monitoring and Reporting Program is hereby adopted to ensure implementation of feasible mitigation measures identified in the PEIR. The City of Santa Ana finds that these mitigation measures are fully enforceable conditions on the project and shall be binding upon the City and affected parties.
 The City of Santa Ana finds that the project is in the public interest and is necessary for the public health, safety, and welfare.
 The City of Santa Ana hereby certifies the Final Recirculated PEIR in accordance with the requirements of CEQA.
 Pursuant to CEQA Guidelines Section 15095, staff is directed as follows: a) copy of the Final Recirculated PEIR and CEQA Findings of Fact shall be retained in the project files; b) copy of the Final Recirculated PEIR and CEQA Findings of Fact shall be provided to all CEQA "responsible" agencies.

City Council 30 – 71 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -21- October 2021
IV. ENVIRONMENTAL ISSUES THAT WERE DETERMINED NOT TO BE POTENTIALLY

AFFECTED BY THE PROPOSED PROJECT
A. IMPACTS DETERMINED TO BE LESS THAN SIGNIFICANT DURING THE SCOPING

PROCESS
Based on the public scoping process (including review of NOP responses and input at the public scoping meeting), in addition to analysis prepared for the Draft PEIR, the City determined, based upon the threshold criteria for significance, that the project would have no impact or a less than significant impact on the following potential environmental issues (see Updated Draft PEIR, Chapter 8, Impacts Found Not to Be Significant). It was determined, therefore, that these potential environmental issues would be precluded from detailed discussion in the Draft PEIR. Based upon the environmental analysis presented in the Draft PEIR, and the comments received by the public on the Draft PEIR, no substantial evidence was submitted to or identified by the City which indicated that the project would have an impact on the following environmental areas:
(a) Agriculture and Forestry Resources: The City does not have any significant agricultural resources. Additionally, Santa Ana has no land designated or zoned for agricultural use and does not have any land subject to a Williamson Act contract. Santa Ana does not have any land designated or zoned for forestland, timberland, or zoned Timberland Production. (b) Wildfire: According to CAL FIRE, the nearest fire hazard severity zone (FHSZ) in an SRA to the City of Santa Ana is a high FHSZ about 4.0 miles east along the western edge of Loma Ridge. The nearest FHSZ in an LRA is about 3.8 miles away at the southern tip of the Peters Canyon Regional Park. The city is not in or near SRAs or lands classified as very high FHSZs.

Additionally, no area in the city is on the wildland-urban interface.

All other topical areas of evaluation included in the Environmental Checklist were determined to require further assessment in the Draft PEIR.

B. IMPACTS DETERMINED TO BE LESS THAN SIGNIFICANT IN THE PEIR This section identifies impacts of the proposed project determined to be less than significant without implementation of project-specific mitigation measures. This determination, however, does assume compliance with existing regulations, as detailed in each respective topical section of Chapter 5 in the Updated Draft PEIR.
(a) Aesthetics: Buildout under the GPU will be at a greater intensity/density in all five focus areas compared to existing conditions. While maximum height would generally be similar to existing buildings, the overall increase in allowed intensity and height across the focus areas would lead to a visually denser urban setting and alter Santa Ana’s existing skyline. Buildout under the GPU would not have a substantial adverse effect on scenic vistas (such as the Santa Ana River and Santiago Creek) since these existing open space parcels would remain unchanged. Additionally, no state scenic highways, eligible or officially designated, traverse the city nor are located near the city. Therefore, the GPU would not damage scenic resources, including rock outcroppings, trees, and historic buildings within state scenic City Council 30 – 72 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -22- October 2021
highways. The GPU would also create new sources of light or glare in the project area, but adverse impacts would be minimized with compliance to building codes. (b) Biological Resources: Development pursuant to the GPU would not impact riparian habitat or other sensitive natural communities. Additionally, the GPU would not impact wetlands and jurisdictional waterways. The GPU would not conflict with an adopted NCCP/HCP as the City is not within a NCCP/HCP area and would not conflict with local policies or ordinances protecting biological resources.
(c) Cultural Resources: The likelihood that human remains may be discovered during clearing and grading activities is considered extremely low. In the unlikely event human remains are uncovered, impacts would be less than significant upon compliance with California and Safety Code Section 7050.5.
(d) Energy: Implementation of proposed policies under the GPU, in conjunction with and complementary to regulatory requirements, will ensure that energy demand associated with growth under the GPU would not be inefficient, wasteful, or unnecessary. Additionally, the GPU would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
(e) Geology and Soils: The plan area’s location and underlying geology make it likely to experience seismic hazards, including strong seismic ground shaking, and secondary hazards, like liquefaction. No active surface faults are mapped and zoned under the AP Zoning Act in the plan area. Additionally, all structures that would be constructed in accordance with the GPU would be designed to meet or exceed current design standards as found in the latest CBC. Most of the plan area is within an area susceptible to liquefaction; however, all structures constructed under the GPU would be designed in accordance with current seismic design standards as found in the CBC. There are no substantial hazards with respect to slope stability, as the plan area is mostly flat. Unstable geologic unit or soils conditions, including soil erosion, could result from development of the GPU. Mandatory compliance with existing regulations, including the preparation and submittal of a SWPPP and a soil engineering evaluation, would reduce soil erosion impacts to a less than significant level. Implementation of the CBC design code, which has been adopted by the City and requires that structures be designed to mitigate expansive and compressible soils, would reduce impacts to a less than significant level. The probability of subsidence impacts is generally low in the majority of Santa Ana; however, the statutorily required sustainable groundwater management practices of the Orange County Water District would ensure that impacts would be less than significant. Future development in the plan area would require connection to the City’s sewer system as the City of Santa Ana does not allow for the installation of septic tanks.
(f) Greenhouse Gas Emissions: The GPU would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.

City Council 30 – 73 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -23- October 2021
(g) Hazards and Hazardous Materials: Construction and operations under the GPU would involve the transport, use, and/or disposal of hazardous materials; however, compliance with existing regulations would ensure that construction workers and the general public are not exposed to any risks related to hazardous materials during demolition and construction.

Furthermore, strict adherence to all emergency response plan requirements set by the Orange County Fire Authority would be required throughout the duration of project construction. GPU buildout is expected to result in some increase in the number of hazardous waste generators; however, hazardous wastes would be stored, transported, and disposed of in conformance with existing regulations of the EPA, US Department of Transportation, CalRecycle, and other agencies. Use, storage, transport, and disposal of hazardous materials in conformance with regulations would reduce both the likelihood of an accidental release and the potential consequences in the event of an accidental release.

The plan area includes 555 sites on a list of hazardous materials compiled pursuant to Government Code Section 65962.5 that could create a significant hazard to the public or the environment. Any development, redevelopment, or reuse on or next to any of these sites would require environmental site assessment by a qualified environmental professional to ensure that the project would not disturb hazardous materials on any of the hazardous materials sites or plumes of hazardous materials diffusing from one of the hazardous materials sites, and that any proposed development, redevelopment, or reuse would not create a substantial hazard to the public or the environment.

Santa Ana is in the vicinity of an airport or within the jurisdiction of an airport land use plan.

Projects approved under the proposed GPU would be required to comply with FAA airspace protection regulations using the AELUP consistency determination process.

The buildout of the GPU would not result in substantial changes to the circulation patterns or emergency access routes, and would not block or otherwise interfere with use of evacuation routes. Buildout would not interfere with operation of the City’s Emergency Operations Center and would not interfere with operations of emergency response agencies or with coordination and cooperation between such agencies.

Santa Ana is not in a designated fire hazard zone, and implementation of the GPU will not expose structures and/or residences to wildland fire danger. (h) Hydrology and Water Quality: Projects pursuant to the GPU would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. Development pursuant to the GPU would increase the demand on groundwater use but would not impede sustainable groundwater management of the basin. Development pursuant to the GPU would increase the amount of pervious surfaces in the plan area, but could substantially increase the rate or amount of surface runoff in some focus areas in a manner which would result in flooding off-site or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems. In flood hazard, tsunami, or seiche zones, development pursuant to the GPU would not risk release of pollutants due to project inundation or impede or redirect flood flows. Development City Council 30 – 74 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -24- October 2021
pursuant to the GPU would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. (i) Land Use Planning: Implementation of the GPU would not divide an established community.

Additionally, the GPU would be consistent with the Airport Environs Land Use Plan for the John Wayne Airport. Implementation of the GPU would be consistent with the goals of the Southern California Association of Governments’ RTP/SCS. Implementation of the GPU would also be consistent with the OCTA Congestion Management Plan. (j) Mineral Resources: Project implementation would not result in the loss of availability of a known mineral resource.
(k) Noise: The proximity of the plan area to an airport or airstrip would not result in exposure of future residents and/or workers to excessive airport-related noise. (l) Population and Housing: The proposed GPU would provide more housing opportunities than currently exist. Therefore, implementation of the GPU would not displace people and/or housing.
(m) Public Services: The GPU would introduce new structures and allow for up to 22,361 new residents and workers in the OCFA and Santa Ana Police Department service boundaries, thereby increasing the requirement for fire protection facilities and personnel, as well as increasing the service needs for the Main Library and the Newhope Library Learning Center.

The GPU would also generate additional students who would impact the school enrollment capacities of the Santa Ana Unified School District, Garden Grove Unified School District, and Orange Unified School District. However, upon implementation of regulatory requirements and standard conditions of approval the project would not create significant impacts related to fire protection services, police protection, library services, or school services.
(n) Transportation and Traffic: The GPU is consistent with adopted programs, plans, and policies addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Additionally, GPU implementation would result in a reduction of vehicle miles traveled per service population (VMT/SP) in comparison to existing City conditions, and would achieve a VMT/SP at least 15 percent lower than the countywide VMT/SP. Finally, circulation improvements associated with future development that would be accommodated by the GPU would be designed to adequately address potentially hazardous conditions (sharp curves, etc.), potential conflicting uses, and emergency access. (o) Utilities and Service Systems: Development pursuant to the GPU would require or result in the relocation or construction of new or expanded wastewater facilities. However, Orange County Sanitation District (OCSD) has a functioning and effective process in place to ensure the regional sewer infrastructure will support future developments under the Santa Ana GPU.

Additionally, OCSD and OC Water District have adequate capacity to serve development pursuant to the GPU in addition to the providers existing commitments. Development City Council 30 – 75 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -25- October 2021
pursuant to the GPU would require or result in the relocation or construction of new or expanded water facilities. However, the City would have adequate capacity for the proposed increases in water flows across the city under implementation of the GPU and would be able to serve the additional dwelling units and commercial square footage proposed. Furthermore, GPU policies encourage the maintenance and upgrade of water infrastructure through impact fees from new development, and the exploration of other funding sources. Water supply would be adequate to meet development pursuant to the GPU. Existing and/or proposed stormwater drainage facilities would be able to accommodate proposed development pursuant to the GPU. Existing and/or proposed solid waste facilities would be able to accommodate development pursuant to the GPU and comply with related solid waste regulations. Development pursuant to the GPU would require or result in the relocation or construction of new or expanded electric power and natural gas. However, the net increases in natural gas demands due to the GPU buildout are within the amounts that SoCalGas forecasts that it will supply to its customers, and buildout would not require SoCalGas to obtain increased natural gas supplies over its currently forecast supplies.

City Council 30 – 76 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -26- October 2021
V. FINDINGS REGARDING POTENTIALLY SIGNIFICANT ENVIRONMENTAL IMPACTS The following potentially significant environmental impacts were analyzed in the PEIR, and the effects of the project were considered. Because of environmental analysis of the project and the identification of relevant General Plan policies; compliance with existing laws, codes, and statutes; and the identification of feasible mitigation measures, some potentially significant impacts have been determined by the City to be reduced to a level of less than significant, and the City has found—in accordance with CEQA Section 21081(a)(1) and State CEQA Guidelines Section 15091(a) (1)—that “Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant effects on the environment.” This is referred to herein as “Finding 1.”
Where the City has determined—pursuant to CEQA Section 21081(a)(2) and State CEQA Guidelines Section 15091(a)(2)—that “Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency,” the City’s finding is referred to herein as “Finding 2.” Where, as a result of the environmental analysis of the project, the City has determined that either (1) even with the identification of project design features, compliance with existing laws, codes and statutes, and/or the identification of feasible mitigation measures, potentially significant impacts cannot be reduced to a level of less than significant, or (2) no feasible mitigation measures or alternatives are available to mitigate the potentially significant impact, the City has found in accordance with CEQA Section 21081(a)(3) and State CEQA Guidelines Section 15091(a)(3) that “Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the environmental impact report.” This is referred to herein as “Finding 3.”
A. IMPACTS MITIGATED TO LESS THAN SIGNIFICANT
The following summary describes impacts of the proposed project that, without mitigation, would result in significant adverse impacts. Upon implementation of the mitigation measures provided in the PEIR, the impacts would be considered less than significant.

1. Air Quality
Impact 5.2-6: Industrial land uses accommodated under the General Plan update could create other emissions, such as those leading to objectionable odors, that would adversely affect a substantial number of people.

Industrial land uses associated with the GPU may generate potentially significant odor impacts for a substantial number of people. Impacts from potential odors generated from residential and other nonresidential land uses associated with the GPU are considered less than significant.

Impacts associated with construction-generated odors are considered less than significant.

City Council 30 – 77 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -27- October 2021
The Industrial and Industrial Flex land uses are not anticipated to produce odors, and Mitigation Measure AQ-4 would ensure that odor impacts are minimized and facilities would comply with South Coast AQMD Rule 402. Therefore, Impact 5.2-6 would be less than significant.

Mitigation Measures
AQ-4 Prior to discretionary approval by the City of Santa Ana, if it is determined that a development project has the potential to emit nuisance odors beyond the property line, an odor management plan shall be prepared by the project applicant and submitted to the City of Santa Ana for review and approval. Facilities that have the potential to generate nuisance odors include, but are not limited to:
• Wastewater treatment plants
• Composting, green waste, or recycling facilities
• Fiberglass manufacturing facilities
• Painting/coating operations
• Large-capacity coffee roasters
• Food-processing facilities
The odor management plan shall demonstrate compliance with the South Coast Air Quality Management District’s Rule 402 for nuisance odors. The Odor Management Plan shall identify the best available control technologies for toxics (T-BACTs) that will be utilized to reduce potential odors to acceptable levels, including appropriate enforcement mechanisms. T-BACTs may include but are not limited to scrubbers (i.e., air pollution control devices) at the industrial facility. T-BACTs identified in the odor management plan shall be identified as mitigation measures in the environmental document prepared for the development project and/or incorporated into the project’s site plan.

Finding
Finding 1. The City hereby makes Finding 1. Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measure above. The City of Santa Ana hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

2. Biological Resources
Impact 5.3-1: Implementation of the General Plan Update could result in adverse impacts to candidate, sensitive, or special-status species.

The inventory of existing conditions determined that no parcels with a proposed land use designation that allows for development (i.e., not an open space designation) currently has City Council 30 – 78 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -28- October 2021
sensitive vegetation. All parcels currently have ruderal vegetation and little to no biological value.

Therefore, there is no current indication that future development in accordance with the GPU would have significant unavoidable biological impacts. However, the programmatic analysis prepared for this GPU was not at the detailed, site-specific analysis required for a specific development project. Site-specific analyses could reveal biological resources not identified in the Biological and Natural Resources Report. Therefore, there is a potential for biological impacts associated with implementation of the GPU. Therefore, implementation of the GPU could result in a potentially significant impact.

The letter received from CDFW states that the Santa Ana River and its tributaries historically supported federally endangered southern California steelhead. CDFW’s letter requests that the Draft PEIR include an analysis of any proposed major stream crossings in the context of fish passage, and states that the analysis should include, but not be limited to, steelhead presence or historic presence, existing conditions including habitat and barrier assessments, any known projects to remove barriers or restore habitat that would affect or be affected by this project, and cumulative impacts to steelhead populations and/or habitat resulting from this project. The GPU does not propose any major stream crossings. If any future development project entails improvements for stream crossings (e.g. Santa Ana River and Santiago Creek), project-level CEQA compliance would require a biological resources report that would address potential impacts to endangered species, including the California steelhead.

Impact 5.3-1 would be less than significant with compliance with all applicable federal, state, and local regulations and incorporation of mitigation measure BIO-1.

Mitigation Measures
BIO-1 For development or redevelopment projects that would disturb vegetated land or major stream and are subject to CEQA, a qualified biologist shall conduct an initial screening to determine whether a site-specific biological resource report is warranted. If needed, a qualified biologist shall conduct a field survey for the site and prepare a biological resource assessment for the project, including an assessment of potential impacts to sensitive species, habitats, and jurisdictional waters. The report shall recommend mitigation measures, as appropriate, to avoid or limit potential biological resource impacts to less than significant.

Finding
Finding 1. The City hereby makes Finding 1. Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measures above. The City of Santa Ana hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

City Council 30 – 79 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -29- October 2021
Impact 5.3-4: Implementation of the General Plan Update could result in adverse impacts to candidate, sensitive, or special-status species.

The City of Santa Ana is largely urbanized, and migration corridors are generally limited to the Santa Ana River and the Santiago Creek. Development under the GPU would result in the further infill of the city and removal of vacant sites. The GPU would not change land use designations of parcels that encompass the Santa Ana River or the Santiago Creek. However, development under the GPU could further result in vegetation removal, intrusion by humans and pets, and increased noise and air pollutants, which could impact wildlife movement and nesting sites. Therefore, the buildout of the GPU could affect wildlife movement, nesting sites, and migratory birds protected under the Migratory Bird Treaty Act as well as state law.

Impact 5.3-4 would be less than significant with compliance with all applicable federal, state, and local regulations and incorporation of mitigation measure BIO-1.

Mitigation Measures
Refer to BIO-1 above.

3. Cultural Resources
Impact 5.4-2: Development in accordance with the General Plan Update could impact archaeological resources.

Development involving ground disturbance within the plan area has the potential to impact known and unknown archaeological resources. Typically, surface-level and subsurface archaeological sites and deposits can be affected by ground-disturbing activities associated with most types of construction. Based on literature review and records searches, eight archaeological resources have been recorded within the plan area, including four prehistoric sites, one multicomponent site, and three historic isolates. The plan area includes many locations that would have been favorable for prehistoric Native American occupation. While most of the plan area has been developed over the course of the twentieth century, buried resources may remain in areas where developments such as parking lots, parks, or structures with shallow foundations have required only minimal ground disturbance. A review of historical and ethnographic maps indicates a moderate likelihood that intact subsurface archaeological resources would be encountered during redevelopment.

Archaeological resources impacts are site specific, but more intensive development can result in cumulative impacts on a regional level and should be considered in addition to individual project City Council 30 – 80 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -30- October 2021
impacts on individual sites. As determined by the respective lead agency on a project by project basis, Phase I Cultural Resources studies would be required before ground disturbances and demolition activities are permitted to occur. The study would identify resources on the affected project sites that are, or appear to be, eligible for listing on the National or California Register.

Such studies would also recommend mitigation measures to protect and preserve archaeological and tribal cultural resources.

Mitigation Measures CUL-4 through CUL-7 were developed to reduce potential individual and cumulative impacts associated with future development and redevelopment. Mitigation Measure CUL-4 requires an archaeological resources assessment be conducted for future development projects to identify any known archaeological resources and sensitivity of the site. Mitigation Measures CUL-5 through CUL-7 detail the next steps required should the archaeological resources assessment identify known resources or determine the site to have high or moderate resource sensitivity. Upon compliance with Mitigation Measures CUL-4 through CUL-7, individual and cumulative impacts to archaeological resources would be reduced to less than significant levels.

Mitigation Measures
CUL-4 For projects with ground disturbance—e.g., grading, excavation, trenching, boring, or demolition that extend below the current grade—prior to issuance of any permits required to conduct ground-disturbing activities, the City shall require an Archaeological Resources Assessment be conducted under the supervision of an archaeologist that meets the Secretary of the Interior’s Professionally Qualified Standards in either prehistoric or historic archaeology.

Assessments shall include a California Historical Resources Information System records search at the South Central Coastal Information Center and of the Sacred Land Files maintained by the Native American Heritage Commission. The records searches will determine if the proposed project area has been previously surveyed for archaeological resources, identify and characterize the results of previous cultural resource surveys, and disclose any cultural resources that have been recorded and/or evaluated. If unpaved surfaces are present within the project area, and the entire project area has not been previously surveyed within the past 10 years, a Phase I pedestrian survey shall be undertaken in proposed project areas to locate any surface cultural materials that may be present.

CUL-5 If potentially significant archaeological resources are identified, and impacts cannot be avoided, a Phase II Testing and Evaluation investigation shall be performed by an archaeologist who meets the Secretary of the Interior’s Standards to determine significance prior to any ground-disturbing activities. If resources are determined significant or unique through Phase II testing, and site avoidance is not possible, appropriate site-specific mitigation measures shall be undertaken. These might include a Phase III data recovery program implemented by a qualified archaeologist City Council 30 – 81 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -31- October 2021
and performed in accordance with the Office of Historical Preservation’s “Archaeological Resource Management Reports (ARMR): Recommended Contents and Format” (OHP 1990) and “Guidelines for Archaeological Research Designs” (OHP 1991).

CUL-6 If the archaeological assessment did not identify archaeological resources but found the area to be highly sensitive for archaeological resources, a qualified archaeologist shall monitor all ground-disturbing construction and pre-construction activities in areas with previously undisturbed soil. The archaeologist shall inform all construction personnel prior to construction activities of the proper procedures in the event of an archaeological discovery. The training shall be held in conjunction with the project’s initial on-site safety meeting and shall explain the importance and legal basis for the protection of significant archaeological resources. In the event that archaeological resources (artifacts or features) are exposed during ground-disturbing activities, construction activities in the immediate vicinity of the discovery shall be halted while the resources are evaluated for significance by an archaeologist who meets the Secretary’s Standards, and tribal consultation shall be conducted in the case of a tribal resource. If the discovery proves to be significant, the long-term disposition of any collected materials should be determined in consultation with the affiliated tribe(s), where relevant; this could include curation with a recognized scientific or educational repository, transfer to the tribe, or respectful reinternment in an area designated by the tribe.

CUL-7 If an Archaeological Resources Assessment does not identify potentially significant archaeological resources but the site has moderate sensitivity for archaeological resources (Mitigation Measure CUL-4), an archaeologist who meets the Secretary’s Standards shall be retained on call. The archaeologist shall inform all construction personnel prior to construction activities about the proper procedures in the event of an archaeological discovery. The pre-construction training shall be held in conjunction with the project’s initial on-site safety meeting and shall explain the importance and legal basis for the protection of significant archaeological resources. In the event that archaeological resources (artifacts or features) are exposed during ground-disturbing activities, construction activities in the immediate vicinity of the discovery shall be halted while the on-call archaeologist is contacted. The resource shall be evaluated for significance and tribal consultation shall be conducted, in the case of a tribal resource. If the discovery proves to be significant, the long-term disposition of any collected materials should be determined in consultation with the affiliated tribe(s), where relevant.

Finding
Finding 1. The City hereby makes Finding 1. Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measures City Council 30 – 82 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -32- October 2021
above. The City of Santa Ana hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

4. Geology and Soils
Impact 5.6-4: Future development that would be accommodated by the General Plan Update could impact known and unknown paleontological resources.

Paleontological resources are recognized as nonrenewable and therefore receive protection under the California Public Resources Code and CEQA. Adoption of the GPU in itself will not directly affect paleontological resources. Long-term implementation of the GPU land use plan could allow development (e.g., infill development, redevelopment, and revitalization/restoration), including grading, of known and unknown sensitive areas. Grading and construction activities of undeveloped areas or redevelopment that requires more intensive soil excavation than in the past could potentially disturb paleontological resources. Therefore, future development that would be accommodated by the GPU could potentially unearth previously unrecorded resources. Review and protection of paleontological resources are also afforded by CEQA for individual development projects that would be accommodated by the GPU, subject to discretionary actions that are implemented in accordance with the land use plan of the GPU. Fossil localities have been found in the vicinity of the plan area, although not in the plan area itself.

Mitigation Measures GEO-1 through GEO-3 prescribe requirements for monitoring based on the sensitivity of sites for paleontological resources. Under GEO-1, areas that range from high to low sensitivity are required to prepare a Paleontological Resources Monitoring and Mitigation Plan.

With adherence to mitigation measures GEO-1 through GEO-3, Impact 5.6-4 would be less than significant.

Mitigation Measures
GEO-1 High Sensitivity. Projects involving ground disturbances in previously undisturbed areas mapped as having “high” paleontological sensitivity shall be monitored by a qualified paleontological monitor on a full-time basis. Monitoring shall include inspection of exposed sedimentary units during active excavations within sensitive geologic sediments. The monitor shall have authority to temporarily divert activity away from exposed fossils to evaluate the significance of the find and, if the fossils are determined to be significant, professionally and efficiently recover the fossil specimens and collect associated data. The paleontological monitor shall use field data forms to record pertinent location and geologic data, measure stratigraphic sections (if applicable), and collect appropriate sediment samples from any fossil localities.

GEO-2 Low-to-High Sensitivity. Prior to issuance of a grading permit for projects involving ground disturbance in previously undisturbed areas mapped with “low-to-high” paleontological sensitivity, the project applicant shall consult with a geologist or paleontologist to confirm whether the grading would occur at depths that could encounter highly sensitive sediments for paleontological resources. If confirmed that City Council 30 – 83 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -33- October 2021
underlying sediments may have high sensitivity, construction activity shall be monitored by a qualified paleontologist. The paleontologist shall have the authority to halt construction during construction activity as outlined in Mitigation Measure GEO-3.

GEO-3 All Projects. In the event of any fossil discovery, regardless of depth or geologic formation, construction work shall halt within a 50-foot radius of the find until its significance can be determined by a qualified paleontologist. Significant fossils shall be recovered, prepared to the point of curation, identified by qualified experts, listed in a database to facilitate analysis, and deposited in a designated paleontological curation facility in accordance with the standards of the Society of Vertebrate Paleontology (2010). The most likely repository is the Natural History Museum of Los Angeles County. The repository shall be identified and a curatorial arrangement shall be signed prior to collection of the fossils.

Finding
Finding 1. The City hereby makes Finding 1. Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measures above. The City of Santa Ana hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

5. Noise
Impact 5.12-3: Buildout of the individual land uses and projects for implementation of the GPU may expose sensitive uses to excessive levels of groundborne vibration.

Construction Vibration Impacts. Construction activity at projects within the plan area would generate varying degrees of ground vibration, depending on the construction procedures and equipment. Operation of construction equipment generates vibrations that spread through the ground and diminish with distance from the source. The effect on buildings in the vicinity of the construction site varies depending on soil type, ground strata, and receptor-building construction.

The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibrations at moderate levels, to slight structural damage at the highest levels. Vibration from construction activities rarely reaches the levels that can damage structures but can achieve the audible and perceptible ranges in buildings close to the construction site.

Vibration generated by construction equipment has the potential to be substantial, since it has the potential to exceed the FTA criteria for architectural damage (e.g., 0.12 inches per second [in/sec] PPV for fragile or historical resources, 0.2 in/sec PPV for non-engineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry). Construction details and equipment for future project-level developments under the GPU are not known at this time but may cause vibration impacts.

City Council 30 – 84 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -34- October 2021
With implementation of Mitigation Measures N-2, N-3, and N-4, coupled with adherence to associated performance standards, Impact 5.12-3 would be reduced to less-than-significant levels. Specifically, Mitigation Measure N-2 would reduce potential vibration impacts during construction below the pertinent thresholds, and Mitigation Measures N-3 and N-4 (operationsrelated vibration) would reduce potential vibration impacts from commercial/industrial uses and proposed uses near existing railroads and facilities to less-than-significant levels. No significant and unavoidable vibration impacts would remain.

Operational Vibration Impacts. Commercial and industrial operations within the plan area would generate varying degrees of ground vibration, depending on the operational procedures and equipment. Such equipment-generated vibrations would spread through the ground and diminish with distance from the source. The effect on buildings in the vicinity of the vibration source varies depending on soil type, ground strata, and receptor-building construction. The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibrations at moderate levels, to slight structural damage at the highest levels. In addition, future sensitive receptors could be placed within close proximity to existing railroad lines through buildout in the plan area.

Because specific project-level information is not available at this time, it is not possible to quantify future vibration levels at vibration-sensitive receptors that may be near existing and future vibration sources.

With implementation of Mitigation Measures N-2, N-3, and N-4, coupled with adherence to associated performance standards, Impact 5.12-3 would be reduced to less-than-significant levels. Specifically, Mitigation Measure N-2 would reduce potential vibration impacts during construction below the pertinent thresholds, and Mitigation Measures N-3 and N-4 (operationsrelated vibration) would reduce potential vibration impacts from commercial/industrial uses and proposed uses near existing railroads and facilities to less-than-significant levels. No significant and unavoidable vibration impacts would remain.

Mitigation Measures
N-2 Prior to issuance of a building permit for a project requiring pile driving during construction within 135 feet of fragile structures, such as historical resources, 100 feet of non-engineered timber and masonry buildings (e.g., most residential buildings), or within 75 feet of engineered concrete and masonry (no plaster); or a vibratory roller within 25 feet of any structure, the project applicant shall prepare a noise and vibration analysis to assess and mitigate potential noise and vibration impacts related to these activities. This noise and vibration analysis shall be conducted by a qualified and experienced acoustical consultant or engineer. The vibration levels shall not exceed Federal Transit Administration (FTA) architectural damage thresholds (e.g., 0.12 inches per second [in/sec] peak particle velocity [PPV] for fragile or historical resources, 0.2 in/sec PPV for non-engineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry). If vibration levels would exceed City Council 30 – 85 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -35- October 2021
this threshold, alternative uses such as drilling piles as opposed to pile driving and static rollers as opposed to vibratory rollers shall be used. If necessary, construction vibration monitoring shall be conducted to ensure vibration thresholds are not exceeded.

N-3 New residential projects (or other noise-sensitive uses) located within 200 feet of existing railroad lines shall be required to conduct a groundborne vibration and noise evaluation consistent with Federal Transit Administration (FTA)-approved methodologies.

N-4 During the project-level California Environmental Quality Act (CEQA) process for industrial developments under the General Plan Update or other projects that could generate substantial vibration levels near sensitive uses, a noise and vibration analysis shall be conducted to assess and mitigate potential noise and vibration impacts related to the operations of that individual development. This noise and vibration analysis shall be conducted by a qualified and experienced acoustical consultant or engineer and shall follow the latest CEQA guidelines, practices, and precedents.

Finding
Finding 1. The City hereby makes Finding 1. Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measures above. The City of Santa Ana hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

6. Tribal Cultural Resources
Impact 5.17-1: The proposed project could cause a substantial adverse change in the significance of a tribal cultural resource that is listed or eligible for listing in the California Register of Historical Resources or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).

The Sacred Land File search yielded positive results, indicating that known tribal resources exist within the plan area. Further, a CHRIS records search at SCCIC indicates that 23 archaeological resources were previously recorded within 0.5 mile of the plan area. Of these resources, eight archaeological resources were located within the plan area; these include four prehistoric sites with habitation debris and lithic scatters, one multicomponent site, and three historic isolates. The plan area includes many locations that would have been favorable for prehistoric Native American occupation. While the city is urbanized and most of the plan area has been developed, buried resources may remain in areas of minimal ground disturbance, such as parks, parking lots, and structures with shallow foundations. Tribal cultural resources are site specific in nature.

City Council 30 – 86 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -36- October 2021
Implementation of Mitigation Measures CUL-4 through CUL-7 would reduce impacts relating to tribal cultural resources to less than significant.

Mitigation Measures
Refer to Mitigation Measures CUL-4 through CUL-7 in section A.3, above.

Finding
Finding 1. The City hereby makes Finding 1. Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measures above. The City of Santa Ana hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

Impact 5.17-2: The proposed project could cause a substantial adverse change in the significance of a tribal cultural resource that is determined by the lead agency to be significant pursuant to criteria in Public Resources Code Section 5024.1(c).

Future development as a result of the implementation of the GPU could include grading in portions of the City with sensitivity to tribal cultural resources. Grading and construction activities that require more intensive soil excavation than in the past could potentially cause disturbance to tribal cultural resources. Future development could potentially unearth previously unknown or unrecorded tribal cultural resources.

Because the NAHC SLF search yielded positive results and the Gabrieleño Band of Mission Indians – Kizh Nation identified sensitive areas within the city, the buildout of the GPU may cause a substantial adverse change in the significance of tribal cultural resources. Earthwork activities may occur with buildout under the GPU that could impact previously undisturbed tribal cultural resources.

Implementation of Mitigation Measures CUL-4 through CUL-7 would reduce impacts relating to tribal cultural resources to less than significant.

Mitigation Measures
Refer to Mitigation Measures CUL-4 through CUL-7 in section A.3, above.

Finding
Finding 1. The City hereby makes Finding 1. Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measures above. The City of Santa Ana hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

City Council 30 – 87 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -37- October 2021
B. SIGNIFICANT UNAVOIDABLE ADVERSE IMPACTS
The following summary describes the unavoidable adverse impact of the GPU where mitigation measures were found to be either infeasible or would not lessen impacts to less than significant.

The following impacts would remain significant and unavoidable.

1. Air Quality
Impact 5.2-1: The additional population growth forecast for the General Plan Update and the associated emissions would not be consistent with the assumptions of the air quality management plan.

Support for this environmental impact conclusion is fully discussed in Section 5.2, Air Quality, starting on page 5.2-45 of the Updated Draft PEIR.

The GPU would be inconsistent with the South Coast Air Quality Management Plan (AQMP) because buildout under the GPU would exceed the population estimates assumed for the AQMP and would cumulatively contribute to the nonattainment designations of the South Coast Air Basin (SoCAB). Buildout of the GPU would exceed current population estimates for the city, and therefore the emissions associated with the additional population are not included in the current regional emissions inventory for the SoCAB. Additionally, air pollutant emissions associated with buildout of the GPU would cumulatively contribute to the nonattainment designations in the SoCAB. Therefore, overall, the GPU would be inconsistent with the AQMP.

Incorporation of Mitigation Measure AQ-2 into future development projects for the operation phase would contribute to reduced criteria air pollutant emissions associated with buildout of the GPU.

Additionally, goals and policies in the GPU would promote increased capacity for alternative transportation modes and implementation of transportation demand management strategies.

However, due to the magnitude and scale of the land uses that would be developed, no mitigation measures are available that would reduce operation and construction impacts below South Coast AQMD thresholds. In addition, the population and employment assumptions of the AQMP would continue to be exceeded until the AQMP is revised and incorporates the projections of the GPU.

Therefore, Impact 5.2-1 would remain significant and unavoidable.

Mitigation Measure
AQ-2 Prior to discretionary approval by the City of Santa Ana for development projects subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects), project applicants shall prepare and submit a technical assessment evaluating potential project operation phase-related air quality impacts to the City of Santa Ana for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (South Coast AQMD) methodology in assessing air quality impacts. If operation-related air pollutants are determined to have the potential to exceed the South Coast AQMD’s adopted thresholds of significance, the City of Santa Ana shall require that applicants for new development City Council 30 – 88 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -38- October 2021
projects incorporate mitigation measures to reduce air pollutant emissions during operational activities. The identified measures shall be included as part of the conditions of approval. Possible mitigation measures to reduce long-term emissions could include, but are not limited to the following:
• For site-specific development that require refrigerated vehicles, the construction documents shall demonstrate an adequate number of electrical service connections at loading docks for plug-in for the anticipated number of refrigerated trailers to reduce idling time and emissions.
• Applicants for manufacturing and light industrial uses shall consider energy storage and combined heat and power in appropriate applications to optimize renewable energy generation systems and avoid peak energy use. • Site-specific developments with truck delivery and loading areas and truck parking spaces shall include signage as a reminder to limit idling of vehicles while parked for loading/unloading in accordance with California Air Resources Board Rule 2845 (13 CCR Chapter 10 § 2485).
• Provide changing/shower facilities as specified in Section A5.106.4.3 of the CALGreen Code (Nonresidential Voluntary Measures).
• Provide bicycle parking facilities per Section A4.106.9 (Residential Voluntary Measures) of the CALGreen Code.
• Provide preferential parking spaces for low-emitting, fuel-efficient, and carpool/van vehicles per Section A5.106.5.1 of the CALGreen Code (Nonresidential Voluntary Measures).
• Provide facilities to support electric charging stations per Section A5.106.5.3 (Nonresidential Voluntary Measures) and Section A5.106.8.2 (Residential Voluntary Measures) of the CALGreen Code.
• Applicant-provided appliances (e.g., dishwashers, refrigerators, clothes washers, and dryers) shall be Energy Star–certified appliances or appliances of equivalent energy efficiency. Installation of Energy Star–certified or equivalent appliances shall be verified by Building & Safety during plan check. • Applicants for future development projects along existing and planned transit routes shall coordinate with the City of Santa Ana and Orange County Transit Authority to ensure that bus pad and shelter improvements are incorporated, as appropriate.

Finding
Finding 3. Changes or alterations have been required in, or incorporated into, the GPU that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measure above. The City of Santa Ana hereby City Council 30 – 89 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -39- October 2021
finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

However, the City finds that there are no other mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

Impact 5.2-2: Construction activities associated with future development that would be accommodated under the General Plan Update could generate short-term emissions in exceedance of the South Coast Air Quality Management District’s threshold criteria.

Support for this environmental impact conclusion is fully discussed in Section 5.2, Air Quality, starting on page 5.2-47 of the Updated Draft PEIR.

Buildout of the GPU would occur over a period of approximately 25 years or longer. Construction activities associated with buildout of the GPU could generate short-term emissions that exceed the South Coast AQMD’S significance thresholds during this time and cumulatively contribute to the nonattainment designations of the SoCAB. Implementation of Mitigation Measure AQ-1 would reduce criteria air pollutant emissions from construction-related activities to the extent feasible.

However, construction time frames and equipment for site-specific development projects are not available at this time, and there is a potential for multiple development projects to be constructed at one time, resulting in significant construction-related emissions. Therefore, despite adherence to Mitigation Measure AQ-1, Impact 5.2-2 would remain significant and unavoidable.

Mitigation Measures
AQ-1 Prior to discretionary approval by the City of Santa Ana for development projects subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects), project applicants shall prepare and submit a technical assessment evaluating potential project construction-related air quality impacts to the City of Santa Ana for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (South Coast AQMD) methodology for assessing air quality impacts. If construction-related criteria air pollutants are determined to have the potential to exceed the South Coast AQMD’s adopted thresholds of significance, the City of Santa Ana shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be City Council 30 – 90 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -40- October 2021
incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City. Mitigation measures to reduce construction-related emissions could include, but are not limited to:
• Require fugitive-dust control measures that exceed South Coast AQMD’s Rule 403, such as:
 Use of nontoxic soil stabilizers to reduce wind erosion.  Apply water every four hours to active soil-disturbing activities. • Use construction equipment rated by the United States Environmental Protection Agency as having Tier 3 (model year 2006 or newer) or Tier 4 (model year 2008 or newer) emission limits, applicable for engines between 50 and 750 horsepower • Ensure that construction equipment is properly serviced and maintained to the manufacturer’s standards.
• Limit nonessential idling of construction equipment to no more than five consecutive minutes.
• Limit on-site vehicle travel speeds on unpaved roads to 15 miles per hour. • Install wheel washers for all exiting trucks or wash off all trucks and equipment leaving the project area.
• Use Super-Compliant VOC paints for coating of architectural surfaces whenever possible. A list of Super-Compliant architectural coating manufactures can be found on the South Coast AQMD’s website.

Finding
Finding 3. Changes or alterations have been required in, or incorporated into, the GPU that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measure above. The City of Santa Ana hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

The City finds that there are no other mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, City Council 30 – 91 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -41- October 2021
technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

Impact 5.2-3: Implementation of the General Plan Update would generate long-term emissions in exceedance of South Coast AQMD’s threshold criteria.

Support for this environmental impact conclusion is fully discussed in Section 5.2, Air Quality, starting on page 5.2-48 of the Updated Draft PEIR.

Buildout in accordance with the GPU would generate long-term emissions that would exceed South Coast AQMD’s regional significance thresholds and cumulatively contribute to the nonattainment designations of the SoCAB. Mitigation Measure AQ-2, in addition to the goals and policies of the GPU, would reduce air pollutant emissions to the extent feasible. The measures and policies covering topics such as expansion of the pedestrian and bicycle networks, promotion of public and active transit, and support to increase building energy efficiency and energy conservation would also reduce criteria air pollutants in the city. Further, compared to existing baseline year conditions, emissions of NOx, CO, and SOx are projected to decrease from current levels despite growth associated with the GPU.

However, Impact 5.2-3 would remain significant and unavoidable due to the magnitude of the overall land use development associated with the GPU. Contributing to the nonattainment status would also contribute to elevating health effects associated with these criteria air pollutants.

Reducing emissions would further contribute to reducing possible health effects related to criteria air pollutants.

It is speculative for this broad-based GPU to determine how exceeding the regional thresholds would affect the number of days the region is in nonattainment, since mass emissions are not correlated with concentrations of emissions, or how many additional individuals in the air basin would suffer health effects. South Coast AQMD is the primary agency responsible for ensuring the health and welfare of sensitive individuals to elevated concentrations of air quality in the SoCAB, and at the present time it has not provided methodology to assess the specific correlation between mass emissions generated and the effect on health in order to address the issue raised in the Friant Ranch case.

Ozone concentrations are dependent upon a variety of complex factors, including the presence of sunlight and precursor pollutants, natural topography, nearby structures that cause building downwash, atmospheric stability, and wind patterns. Because of the complexities of predicting ground-level ozone concentrations in relation to the National and California Ambient Air Quality Standards, it is not possible to link health risks to the magnitude of emissions exceeding the significance thresholds. To achieve the health-based standards established by the EPA, the air districts prepare air quality management plans that detail regional programs to attain the ambient air quality standards. However, because cumulative development within the city would exceed the regional significance thresholds, the proposed project could contribute to an increase in health effects in the basin until the attainment standards are met in the SoCAB.

City Council 30 – 92 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -42- October 2021
Mitigation Measures
Refer to Mitigation Measure AQ-2, above.

Finding
Finding 3. Changes or alterations have been required in, or incorporated into, the GPU that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measure above. The City of Santa Ana hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

The City finds that there are no other mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

Impact 5.2-4: Operation of industrial and warehousing land uses accommodated under the General Plan Update could expose sensitive receptors to substantial toxic air contaminant concentrations.

Support for this environmental impact conclusion is fully discussed in Section 5.2, Air Quality, starting on page 5.2-50 of the Updated Draft PEIR.

Buildout of the GPU could expose sensitive receptors to substantial concentrations of toxic air contaminants (TAC). Buildout could result in new sources of criteria air pollutant emissions and/or TACs near existing or planned sensitive receptors. Review of development projects by South Coast AQMD for permitted sources of air toxics (e.g., industrial facilities, dry cleaners, and gasoline dispensing facilities) would ensure that health risks are minimized. Additionally, Mitigation Measure AQ-3 would ensure mobile sources of TACs not covered under South Coast AQMD permits are considered during subsequent, project-level environmental review by the City of Santa Ana. Individual development projects would be required to achieve the incremental risk thresholds established by South Coast AQMD, and TACs would be less than significant.

However, implementation of the GPU would generate TACs that could contribute to elevated levels in the air basin. Though individual projects would achieve the project-level risk threshold of 10 per million, they would nonetheless contribute to the higher levels of risk in the SoCAB.

Therefore, the GPU’s cumulative contribution to health risk is significant and unavoidable.

City Council 30 – 93 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -43- October 2021
Mitigation Measures
AQ-3 Prior to discretionary approval by the City of Santa Ana, project applicants for new industrial or warehousing development projects that 1) have the potential to generate 100 or more diesel truck trips per day or have 40 or more trucks with operating dieselpowered transport refrigeration units, and 2) are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, or nursing homes), as measured from the property line of the project to the property line of the nearest sensitive use, shall submit a health risk assessment (HRA) to the City of Santa Ana for review and approval. The HRA shall be prepared in accordance with policies and procedures of the State Office of Environmental Health Hazard Assessment and the South Coast Air Quality Management District and shall include all applicable stationary and mobile/area source emissions generated by the proposed project at the project site. If the HRA shows that the incremental cancer risk and/or noncancer hazard index exceed the respective thresholds, as established by the South Coast AQMD at the time a project is considered (i.e., 10 in one million cancer risk and 1 hazard index), the project applicant will be required to identify and demonstrate that best available control technologies for toxics (T-BACTs), including appropriate enforcement mechanisms, are capable of reducing potential cancer and noncancer risks to an acceptable level. T-BACTs may include, but are not limited to, restricting idling on-site, electrifying warehousing docks to reduce diesel particulate matter, or requiring use of newer equipment and/or vehicles. T BACTs identified in the HRA shall be identified as mitigation measures in the environmental document and/or incorporated into the site plan.

Finding
Finding 3. Changes or alterations have been required in, or incorporated into, the GPU that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measure above. The City of Santa Ana hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

The City finds that there are no other mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

City Council 30 – 94 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -44- October 2021
Impact 5.2-5: Development and operation of land uses accommodated by the General Plan Update could generate emissions that exceed the localized significance thresholds and expose sensitive receptors to substantial concentrations of criteria air pollutants.

Support for this environmental impact conclusion is fully discussed in Section 5.2, Air Quality, starting on page 5.2-53 of the Updated Draft PEIR.

Because existing sensitive receptors may be close to project-related construction activities and large emitters of on-site operation-related criteria air pollutant emissions, construction and operation emissions generated by individual development projects have the potential to exceed South Coast AQMD’s Local Significance Thresholds (LSTs). Mitigation Measures AQ-1 and AQ-2 would reduce the regional construction and operation emissions associated with buildout of the GPU and therefore also result in a reduction of localized construction- and operation-related criteria air pollutant emissions, to the extent feasible. However, even with the implementation of these mitigation measures, Impact 5.2-5 would remain significant and unavoidable.

Mitigation Measures
Mitigation Measures AQ-1 and AQ-2 would also be applicable in reducing construction- and operation-related LST impacts.

Finding
Finding 3. Changes or alterations have been required in, or incorporated into, the GPU that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measures above. The City of Santa Ana hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

The City finds that there are no other mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

City Council 30 – 95 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -45- October 2021

2. Cultural Resources
Impact 5.4-1: Buildout consistent with the General Plan Update could impact an identified historic resource.

Support for this environmental impact conclusion is fully discussed in Section 5.4, Cultural Resources, starting on page 5.4-26 of the Updated Draft PEIR.

Generally, potential impacts to historical resources resulting from future projects developed pursuant to the GPU would be mitigated by the City’s fulfillment of its statutory responsibilities under CEQA. However, for certain development pursuant to the GPU, the City may determine that significant impacts to historical resources cannot be avoided. The City shall require, at a minimum, that the affected historical resources be thoroughly documented before issuance of any permits. Though the possible demolition or alteration of a historical resource cannot be mitigated to a less than significant level, recordation of the resource will reduce significant adverse impacts to historical resources to the maximum extent feasible.

With fulfillment of the CUL-1 and CUL-2, future development consistent with the GPU would result in a less than significant impact to cultural resources. However, if significant impacts cannot be avoided, the City shall require, at a minimum, that the affected historical resources are documented consistent with Mitigation Measure CUL-3. The Historical Resources Technical Report determined that unavoidable impacts to historical resources resulting from future development under the GPU will be reduced to the maximum extent feasible but will still be significant with implementation of Mitigation Measure CUL-3. Therefore, the development under the GPU would result in significant and unavoidable impacts.

Mitigation Measures
CUL-1 Identification of Historical Resources and Potential Project Impacts. For structures 45 years or older, a Historical Resources Assessment (HRA) shall be prepared by an architectural historian or historian meeting the Secretary of the Interior’s Professional Qualification Standards. The HRA shall include: definition of a study area or area of potential effect, which will encompass the affected property and may include surrounding properties or historic district(s); an intensive level survey of the study area to identify and evaluate under federal, State, and local criteria significance historical resources that might be directly or indirectly affected by the proposed project; and an assessment of project impacts. The HRA shall satisfy federal and State guidelines for the identification, evaluation, and recordation of historical resources. An HRA is not required if an existing historic resources survey and evaluation of the property is available; however, if the existing survey and evaluation is more than five years old, it shall be updated.

CUL-2 Use of the Secretary of the Interior’s Standards. The Secretary of the Interior’s Standards for the Treatment of Historic Properties shall be used to the maximum extent practicable to ensure that projects involving the relocation, conversion, City Council 30 – 96 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -46- October 2021
rehabilitation, or alteration of a historical resource and its setting or related new construction will not impair the significance of the historical resource. Use of the Standards shall be overseen by an architectural historian or historic architect meeting the Secretary of the Interior’s Professional Qualification Standards. Evidence of compliance with the Standards shall be provided to the City in the form of a report identifying and photographing character-defining features and spaces and specifying how the proposed treatment of character-defining features and spaces and related construction activities will conform to the Standards. The Qualified Professional shall monitor the construction and provide a report to the City at the conclusion of the project. Use of the Secretary’s Standards shall reduce the project impacts on historical resources to less than significant.

CUL-3 Documentation, Education, and Memorialization. If the City determines that significant impacts to historical resources cannot be avoided, the City shall require, at a minimum, that the affected historical resources be thoroughly documented before issuance of any permits and may also require additional public education efforts and/or memorialization of the historical resource. Though demolition or alteration of a historical resource such that its significance is materially impaired cannot be mitigated to a less than significant level, recordation of the resource will reduce significant adverse impacts to historical resources to the maximum extent feasible. Such recordation should be prepared under the supervision of an architectural historian, historian, or historic architect meeting the Secretary of the Interior’s Professional Qualification Standards and should take the form of Historic American Buildings Survey (HABS) documentation. At a minimum, this recordation should include an architectural and historical narrative; archival photographic documentation; and supplementary information, such as building plans and elevations and/or historic photographs. The documentation package should be reproduced on archival paper and should be made available to researchers and the public through accession by appropriate institutions such as the Santa Ana Library History Room, the South Central Coastal Information Center at California State University, Fullerton, and/or the HABS collection housed in the Library of Congress. Depending on the significance of the adversely affected historical resource, the City, at its discretion, may also require public education about the historical resource in the form of an exhibit, web page, brochure, or other format and/or memorialization of the historical resource on or near the proposed project site. If memorialized, such memorialization shall be a permanent installation, such as a mural, display, or other vehicle that recalls the location, appearance, and historical significance of the affected historical resource, and shall be designed in conjunction with a qualified architectural historian, historian, or historic architect.

Finding
Finding 3. Changes or alterations have been required in, or incorporated into, the GPU that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These City Council 30 – 97 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -47- October 2021
changes are identified in the form of the mitigation measures above. The City of Santa Ana hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

The City finds that there are no other mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

3. Greenhouse Gas Emissions
Impact 5.7-1: Implementation of the proposed General Plan Update would result in a decrease in GHG emissions in horizon year 2045 from existing baseline but may not meet the long-term GHG reduction goal under Executive Order S-03-05.

Support for this environmental impact conclusion is fully discussed in Section 5.7, Greenhouse Gas Emissions, starting on page 5.7-31 of the Updated Draft PEIR.

Implementation of Mitigation Measure GHG-1 would ensure that the City is tracking and monitoring the City’s GHG emissions in order to chart a trajectory to achieve the long-term, year 2050, GHG reduction goal set by Executive Order S-03-05. However, at this time, there is no plan past 2030 that achieves the long-term GHG reduction goal established under Executive Order S-03-05. As identified by the California Council on Science and Technology, the state cannot meet the 2050 goal without major advancements in technology. Advancements in technology in the future could provide additional reductions and allow the state and City to meet the 2050 goal, but in the meantime, Impact 5.7-1 would be significant and unavoidable.

Mitigation Measures
GHG-1 The City of Santa Ana shall update the Climate Action Plan (CAP) every five years to ensure the City is monitoring the plan’s progress toward achieving the City’s greenhouse gas (GHG) reduction target and to require amendment if the plan is not achieving the specified level. The update shall consider a trajectory consistent with the GHG emissions reduction goal established under Executive Order S-03-05 for year 2050 and the latest applicable statewide legislative GHG emission reduction that may be in effect at the time of the CAP update (e.g., Senate Bill 32 for year 2030). The CAP update shall include the following:

City Council 30 – 98 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -48- October 2021
• GHG inventories of existing and forecast year GHG levels. • Tools and strategies for reducing GHG emissions to ensure a trajectory with the long-term GHG reduction goal of Executive Order S-03-05. • Plan implementation guidance that includes, at minimum, the following components consistent with the proposed CAP:
 Administration and Staffing
 Finance and Budgeting
 Timelines for Measure Implementation
 Community Outreach and Education
 Monitoring, Reporting, and Adaptive Management
 Tracking Tools
Finding
Finding 3. Changes or alterations have been required in, or incorporated into, the GPU that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measure above. The City of Santa Ana hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

The City finds that there are no other mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

4. Noise
Impact 5.12-1: Construction activities associated with buildout of the plan area would result in temporary noise increases at sensitive receptors.

Support for this environmental impact conclusion is fully discussed in Section 5.12, Noise, starting on page 5.12-29 of the Updated Draft PEIR.

Implementation of Mitigation Measure N-1 would reduce potential noise impacts during construction to the extent feasible. However, due to the potential for proximity of construction activities to sensitive uses, the number of construction projects occurring simultaneously, and the potential duration of construction activities, construction noise could result in a temporary City Council 30 – 99 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -49- October 2021
substantial increase in noise levels above ambient conditions. Therefore, impacts would remain significant and unavoidable. It should be noted that the identification of this program-level impact does not preclude the finding of less-than-significant impacts for subsequent projects analyzed at the project level.

Mitigation Measures
N-1 Construction contractors shall implement the following measures for construction activities conducted in the City of Santa Ana. Construction plans submitted to the City shall identify these measures on demolition, grading, and construction plans submitted to the City: The City of Santa Ana Planning and Building Agency shall verify that grading, demolition, and/or construction plans submitted to the City include these notations prior to issuance of demolition, grading, and/or building permits. • Construction activity is limited to the hours: Between 7 AM to 8 PM Monday through Saturday, as prescribed in Municipal Code Section 18-314(e). Construction is prohibited on Sundays.
• During the entire active construction period, equipment and trucks used for project construction shall use the best-available noise control techniques (e.g., improved mufflers, equipment re-design, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds), wherever feasible. • Impact tools (e.g., jack hammers and hoe rams) shall be hydraulically or electrically powered wherever possible. Where the use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used along with external noise jackets on the tools.
• Stationary equipment, such as generators and air compressors shall be located as far as feasible from nearby noise-sensitive uses.
• Stockpiling shall be located as far as feasible from nearby noise-sensitive receptors.
• Construction traffic shall be limited, to the extent feasible, to approved haul routes established by the City Planning and Building Agency.
• At least 10 days prior to the start of construction activities, a sign shall be posted at the entrance(s) to the job site, clearly visible to the public, that includes permitted construction days and hours, as well as the telephone numbers of the City’s and contractor’s authorized representatives that are assigned to respond in the event of a noise or vibration complaint. If the authorized contractor’s representative receives a complaint, he/she shall investigate, take appropriate corrective action, and report the action to the City.
• Signs shall be posted at the job site entrance(s), within the on-site construction zones, and along queueing lanes (if any) to reinforce the prohibition of City Council 30 – 100 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -50- October 2021
unnecessary engine idling. All other equipment shall be turned off if not in use for more than 5 minutes.
• During the entire active construction period and to the extent feasible, the use of noise-producing signals, including horns, whistles, alarms, and bells, shall be for safety warning purposes only. The construction manager shall use smart back-up alarms, which automatically adjust the alarm level based on the background noise level or switch off back-up alarms and replace with human spotters in compliance with all safety requirements and laws.
• Erect temporary noise barriers (at least as high as the exhaust of equipment and breaking line-of-sight between noise sources and sensitive receptors), as necessary and feasible, to maintain construction noise levels at or below the performance standard of 80 dBA Leq. Barriers shall be constructed with a solid material that has a density of at least 4 pounds per square foot with no gaps from the ground to the top of the barrier.

Finding
Finding 3. Changes or alterations have been required in, or incorporated into, the GPU that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measure above. The City of Santa Ana hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

The City finds that there are no other mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

Impact 5.12-2: Buildout of the plan area would cause a substantial traffic noise increase on local roadways and could locate sensitive receptors in areas that exceed established noise standards.

Support for this environmental impact conclusion is fully discussed in Section 5.12, Noise, starting on page 5.12-30 of the Updated Draft PEIR.

Mitigation Measure N-2 would reduce potential interior noise impacts to future noise-sensitive receptors below the thresholds. However, there are no feasible or practical mitigation measures available to reduce project-generated traffic noise to less than significant levels for existing City Council 30 – 101 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -51- October 2021
residences along affected roadways. No individual measures and no set of feasible or practical mitigation measures are available to reduce project-generated traffic noise to less than significant levels in all cases. Thus, traffic noise would remain a significant and unavoidable impact. It should be noted that the identification of this program-level impact does not preclude the finding of lessthan-significant impacts for subsequent projects analyzed at the project level.

Mitigation Measures
Refer to Mitigation Measure N-2, above.

Finding
Finding 3. Changes or alterations have been required in, or incorporated into, the GPU that avoid or substantially lessen the significant environmental effect as identified in the PEIR. These changes are identified in the form of the mitigation measure above. The City of Santa Ana hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

The City finds that there are no mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

5. Population and Housing
Impact 5.13-1: The GPU would directly induce substantial unplanned population growth.

Support for this environmental impact conclusion is fully discussed in Section 5.13, Population and Housing, starting on page 5.13-12 of the Updated Draft PEIR.

Full buildout of the GPU would result in a population of 431,629, and the city’s 2045 population growth would be approximately 20 percent greater than the Orange County Council of Governments’ 2045 projections. Furthermore, the city’s housing units at buildout would be 115,053, which exceeds the Orange County Council of Governments’ projection by 38 percent.

There are no feasible mitigation measures to mitigate the population and housing growth at buildout, and impacts would be significant and unavoidable.

City Council 30 – 102 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -52- October 2021
Mitigation Measures
There are no feasible mitigation measures to mitigate the population and housing growth at buildout.

Finding
Finding 3. The City finds that there are no mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

City Council 30 – 103 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -53- October 2021

6. Recreation
Impact 5.15-1: The General Plan Update would generate additional residents that would increase the use of existing park and recreational facilities such that substantial physical deterioration of the facility could occur or be accelerated.

Support for this environmental impact conclusion is fully discussed in Section 5.15, Recreation, starting on page 5.15-27 of the Updated Draft PEIR.

Although required park fees for development could be sufficient to fund new parks and improvements, there is a lack of available land and lack of land designated as Open Space within the General Plan Update to develop new parks or expand existing facilities. The City of Santa Ana is essentially built.

Incorporation of Mitigation Measure REC-1 to monitor new residential development within the Dyer/55 Fwy focus area would contribute to reducing impacts to existing public parks within a ½ radius of the focus area. Compliance with this mitigation measure, regulatory requirements, and implementation of proposed GPU policies and implementation actions would reduce the potential impact of the proposed GPU on existing park facilities. However, because of the existing park deficiencies and scale of development in park-deficient areas, the project’s impact would be significant and unavoidable.

Mitigation Measures
REC-1 The City shall monitor new residential development within the Dyer/55 Fwy focus area.

Development proposals for projects including 100 or more residential units shall be required to prepare a public park utilization study to evaluate the project’s potential impacts on existing public parks within a one half (1/2) mile radius to the focus area.

The evaluation shall include the population increase due to the project and the potential for the new resident population to impact existing public parks within the radius. Each study shall also consider the cumulative development in the Dyer/55 Fwy and the potential for a cumulative impact on existing public parks within the radius.

If the study determines that the project, or it’s incremental cumulative impacts would result in a significant impact (substantial physical deterioration or substantial acceleration of deterioration) to existing public parks, the project shall be required to mitigate this impact. Measures to mitigate the significant impact may include but are not limited to land dedication and fair-share contribution to acquire new or to enhance existing public parks within the radius. Mitigation shall be completed prior to issuance of occupancy permits.

City Council 30 – 104 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -54- October 2021
Finding
Finding 3. The City finds that there are no mitigation measures that are feasible, taking into consideration specific economic, legal, social, technological or other factors, that would mitigate this impact to a less-than-significant level, and further, that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the PEIR, as discussed in Section G of these Findings (Public Resources Code §§ 21081(a)(1), (3); Guidelines §§ 15091(a)(1), (3)). As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or statewide environmental benefits, of the GPU outweigh its significant effects on the environment.

Impact 5.15-2: Population increases resulting from project implementation would increase recreation demands that would require construction or expansion of recreation facilities that would have potential to result in physical impacts to the environment.

Support for this environmental impact conclusion is fully discussed in Section 5.15, Recreation, starting on page 5.15-29 of the Updated Draft PEIR.

Population increases resulting from the implementation of the GPU would increase recreation demands and require construction or expansion of recreation facilities. Although construction and/or expansion of new parks and recreation facilities would be subject to GPU policies and implementation actions; regulatory requirements, and future, project specific environmental review under CEQA, it is still possible that development of such facilities could result in significant unavoidable impacts
Mitigation Measures
There are no feasible mitigation measures to mitigate the impacts to recreation at buildout.

City Council 30 – 105 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -55- October 2021
VI. FINDINGS REGARDING ALTERNATIVES
CEQA requires that an EIR include a discussion of reasonable project alternatives that would “feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any significant effects of the project, and evaluate the comparative merits of the alternatives” (CEQA Guidelines § 15126.6[a]).

As discussed above, the PEIR identified significant impacts in a number of categories. The following impacts could be mitigated below a level of significance: air quality, biological resources, cultural resources, geology and soils, noise, tribal cultural resources impacts. The following impacts cannot be mitigated below a level of significance: certain air quality, cultural resources, greenhouse gas (GHG) emissions, noise, population and housing, and recreation impacts.

The PEIR analyzed four alternatives to the proposed project that could reduce some, if not all, of the impacts.

A. ALTERNATIVES CONSIDERED AND REJECTED DURING THE SCOPING/PROJECT

PLANNING
“Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts” (CEQA Guidelines § 15126.6[c]).

Alternative Circulation Element – Roadway Classifications. The proposed circulation element in the GPU evolved over a long process and coordination with the Orange County Transportation Authority (OCTA). During this process, alternative packages of arterial roadway classifications were considered that involved roadways in OCTA’s Master Plan of Arterial Highways (MPAH).

The majority of reclassifications proposed were identified for bicycle facility safety improvements in the City’s Safe Mobility Santa Ana (SMSA) Plan, prepared in 2016. Most of the reclassifications identified were for roadways where bicycle and pedestrian safety improvements would require roadway reconfiguration and a reduction in the number of existing or planned travel lanes. Many of the SMSA recommendations across the city have already been, or are in the process of being, implemented along arterial roadways without reducing the number of lanes.

A cursory review of two optional roadway reclassification packages was conducted to determine whether these optional plans would have the potential to eliminate significant impacts of the proposed GPU and meet most the project objectives. It was determined that a detailed evaluation of this alternative was not needed to provide a reasonable range of EIR project alternatives.

Transportation/traffic impacts of the proposed project were determined to be less than significant (VMT/SP falls below the significance threshold for the GPU without mitigation). Although these alternatives may have some potential to reduce VMT (by reducing the number of travel lanes for some roadways) and thereby also potentially reduce air quality, greenhouse gas, and traffic noise impacts, these alternatives would also result in more inconsistencies with the MPAH and result in more traffic congestion. Although traffic congestion is no longer a CEQA consideration, the GPU sets forth standards for level of service that will be considered by decision-makers. Moreover, the City Council 30 – 106 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -56- October 2021
Reduced Density and RTP/SCS Consistency alternatives were determined to be meaningful alternatives to consider for the potential of reducing air quality, GHG, and traffic noise impacts.

Reduced Traffic Noise Alternative. Since traffic noise was determined to be a significant, unavoidable impact of the proposed GPU, a project alternative designed to eliminate this significant impact was considered. The required reductions in traffic volumes (ADT) were determined along roadways where buildout of the GPU would result in significant noise increases.

These estimates were compared to the surrounding land uses that would generate ADTs for those roadway segments. Traffic noise along these roadways would both exceed the noise standard and abut sensitive land uses (e.g., residences, schools, hospitals). Several segments would experience significant, unavoidable traffic noise impacts without the land use changes proposed under the GPU. Since significant traffic noise could not be avoided, further evaluation of this alternative was not deemed to be meaningful.

B. ALTERNATIVES SELECTED FOR FURTHER ANALYSIS
Given the significant, unavoidable impacts identified for the proposed GPU, project alternatives with the potential to substantially reduce development were identified for further review.

Significant GPU impacts to long-term air quality, GHG emissions, population and housing, and recreation all directly relate to the level of development that would occur within the city. At the programmatic level of this GPU PEIR, site-specific information regarding potential significant historical impacts is not available, and therefore, an alternative could not be customized to reduce that impact. A reduced intensity alternative would also be expected to reduce the significant traffic noise impact (as discussed above). A reduced park demand alternative was also analyzed to address the significant and unavoidable impacts to recreation. The following development alternatives to the proposed GPU were chosen for further analysis.

No Project / Current General Plan Alternative
The evaluation of the No Project alternative is required by CEQA. The No Project alternative is typically defined as the development scenario that would occur if the project as proposed is not adopted. For a General Plan, the No Project alternative is typically represented by the jurisdiction’s existing General Plan, including land use plan, circulation master plan, and policies in each General Plan element. Therefore, this alternative assumes that the existing General Plan—with various adoption dates for different elements between 1982 and 2014—would remain in effect. This existing General Plan also reflects amendments, including new Specific Plans and special zoning areas that have been adopted through the Notice of Preparation for this GPU.

Finding. The City Council rejects the No Project/Current General Plan Alternative on the basis of policy and economic factors as explained herein. (See Pub. Resources Code, § 21061.1; CEQA Guidelines, § 15364; see also City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; California Native Plant Soc. v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) Specific economic, legal, social, technological, or other considerations, including provision of employment City Council 30 – 107 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -57- October 2021
opportunities for highly trained workers, make infeasible this project alternative identified in the Final Recirculated PEIR.

This alternative would result in similar impacts to 11 impact categories, reduced impacts to 5 environmental impacts, and increase impacts to 4 categories. Impacts would be similar for agricultural resources, biological resources, cultural resources, energy, geology and soils, hazards and hazardous materials, hydrology and water quality, mineral resources, noise, tribal cultural resources, and wildfire. This alternative would reduce impacts for aesthetics, population and housing, public services, recreation, and utilities and service systems. Impacts to air quality, greenhouse gas emissions, land use and planning, and transportation would increase. This alternative does not mitigate any of the significant and unavoidable impacts associated with the GPU to a less than significant impact. It would also exceed the City’s VMT threshold. Overall, impacts under this alternative would decrease in comparison to the proposed project.

The No Project/Current General Plan alternative would not achieve many of the proposed project objectives. The existing land use plan does not provide the opportunities to provide housing and employment at the levels required to meet local and regional goals. Moreover, the No Project alternative would not provide numerous general policies as included in the GPU to achieve these goals and invigorate communities. The current General Plan, however, protects established neighborhoods and several Specific Plans and Special Zoning areas would provide for infill opportunities, protect established neighborhoods, and result in mixed-use villages and bike- and pedestrian-friendly communities.

Reduced Intensity Alternative
(Reduced capacity for the 55 Freeway/Dyer and South Bristol focus areas) Under the GPU, the only areas that include revisions to land use designations to accommodate new growth are within the five focus areas. The majority of remaining growth would occur within previously approved Specific Plans and Special Zoning areas. A nominal amount of growth is assumed to occur in other areas of the city and would not require land use amendments. The Reduced Intensity Alternative would substantially reduce development capacity within two focus areas, 55 Freeway/Dyer and South Bristol Street, which accommodate approximately 65 percent of the housing unit growth and 72 percent of the nonresidential use (by building square footage) of the growth projected for the combined focus areas under the GPU. For the focus areas, the forecast buildout is based on development at approximately 80 percent of the maximum allowed development for each respective land use designation. For this alternative, development of the 55 Freeway/Dyer and South Bristol focus areas would be reduced to approximately 50 percent of the maximum allowed per the land use designations. This alternative would reduce housing units by a total of 5,383 and would reduce total building square footage by approximately 4.2 million square feet distributed between these two focus areas. This alternative would also reduce population by 19,825 and jobs by 9,184. Overall, this alternative would reduce the housing growth accommodated by the GPU land use changes by approximately 18 percent and reduce nonresidential building square footage by approximately 27 percent.

City Council 30 – 108 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -58- October 2021
Finding. The City Council rejects the Reduced Intensity Alternative on the basis of policy and economic factors as explained herein. (See Pub. Resources Code, § 21061.1; CEQA Guidelines, § 15364; see also City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; California Native Plant Soc. v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible this project alternative identified in the Final Recirculated PEIR.

This alternative would result in similar impacts to 7 impact categories, reduce impacts to 12 categories, and increase impacts to 1 category. Impacts would be similar for aesthetics, agricultural resources, biological resources, hazards and hazardous materials, hydrology and water quality, mineral resources, and wildfire. This alternative would decrease impacts to air quality, cultural resources, energy, geology and soils, greenhouse gas emissions, noise, population and housing, public services, recreation, tribal cultural resources, transportation, and utilities and services. It would be expected to increase land use and planning impacts relative to the GPU. As with the GPU, impacts to air quality, cultural resources, greenhouse gas emissions, noise, population and housing, and recreation would remain significant and unavoidable. Overall, impacts under this alternative would be decreased in comparison to the proposed project.

The Reduced Density Alternative reduces the level of development for two of the five focus areas (55 Freeway/Dyer Road and South Bristol Street) relative to the GPU. No other changes to the GPU are made for this alternative. It is assumed to include the same General Plan policies and would not modify the circulation element or related improvements. Therefore, this alternative would attain many of the project’s objectives. It would not “optimize” high density housing and mass transit opportunities, and so was found not to attain objective No. 2. It would, however, achieve objectives Nos. 3 through 5, but to a lesser extent than the proposed GPU. With the reduced opportunities in the 55 Freeway/Dyer Road and South Bristol focus areas, it would not be as effective in providing affordable housing opportunities, and may not be as economically feasible in terms of funding community benefits. It would provide mixed-use opportunities that are bike and pedestrian friendly and provide opportunities for live-work, artist spaces, and small-scale manufacturing.
2020 RTP/SCS Consistency Alternative
(Reduced development for RTP/SCS population/housing consistency) This alternative was developed to evaluate an update to the General Plan that would be consistent with the population and housing projections used to develop the Southern California Association of Governments’ (SCAG) most recent Regional Transportation Plan / Sustainable Communities Strategy (RTP/SCS)—Connect SoCal (adopted May 7, 2020). Connect SoCal is a long-range visioning plan that balances future mobility and housing needs with economic, environmental, and public health goals. The plan embodies a collective vision for the region’s future and is developed with input from local governments, county transportation commissions, tribal governments, nonprofit organizations, businesses, and local stakeholders in the counties of Imperial, Los Angeles, City Council 30 – 109 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -59- October 2021
Orange, Riverside, San Bernardino, and Ventura. The proposed GPU would result in a significant population and housing impact because development under the GPU would substantially exceed the projections used in Connect SoCal. SCAG uses locally prepared population and housing projections to develop the regional plan. For the City of Santa Ana, those projections were provided by the Orange County Council of Governments, as prepared by the Center for Demographic Research. The population/housing figures reflected for Santa Ana in the regional plan for 2045 are: population, 360,100; total housing units, 80,100; and total jobs, 176,400.

Projections for the RTP/SCS (Connect SoCal) use land use designations as approved in adopted general plans. The employment projections are similar for the GPU and RTP/SCS scenarios, but the RTP/SCS projections for population and housing units are substantially lower than GPU projections (18 percent and 27 percent lower, respectively). The RTP/SCS alternative, therefore, represents the least-development-intensive project alternative evaluated for the PEIR.  This alternative would substantially reduce the growth that would be accommodated within the focus areas under the GPU. New growth within the focus areas would total 6,380 housing units and approximately 3.7 million square feet of nonresidential uses, instead of a total additional 23,955 housing units and approximately 15.7 million square feet within the focus areas. This alternative distributes anticipated development through the focus areas and the approved Specific Plans/Special Zoning areas. For purposes of this alternative, it is assumed that a development cap would be used to limit total growth to the projections shown.  Subsequent updates of the regional plan would incorporate updated land use from the GPU and resolve the substantial discrepancy between the population and housing projections. Note also that the PEIR concludes that the GPU is consistent with the goals of the RTP/SCS. This alternative has been defined to eliminate the significant impact associated with substantial population growth that is inconsistent with the regional plan, as well as reduce other significant growth-related (AQ/GHG, traffic noise) impacts associated with the GPU as proposed.

Finding. The City Council rejects the 2020 RTP/SCS Consistency Alternative on the basis of policy and economic factors as explained herein. (See Pub. Resources Code, § 21061.1; CEQA Guidelines, § 15364; see also City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; California Native Plant Soc. v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible this project alternative identified in the Final Recirculated PEIR.

This alternative would reduce impacts to 12 environmental impacts, result in similar impacts to 6 categories, and increase impacts to 1 category. It would reduce impacts to air quality, biological resources, cultural resources, energy, geology and soils, greenhouse gas emissions, noise, population and housing, public services, recreation, tribal cultural resources, and utilities and service systems. Impacts would be very similar for aesthetics, agricultural resources, hazards and hazardous materials, hydrology and water quality, mineral resources, and wildfire. It would increase impacts to land use and planning. It would also increase impacts to transportation and City Council 30 – 110 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -60- October 2021
potentially introduce a new significant impact. It is anticipated, however, that under this alternative, transportation could be mitigated to less than significant. Under the GPU, transportation impacts are less than significant without mitigation. As with the GPU, impacts to air quality, cultural resources, greenhouse gas emissions, noise, and recreation would remain significant and unavoidable. The impact to population and housing would be reduced to less than significant.

Overall, impacts under this alternative would be reduced in comparison to the proposed project.

Due to the substantial reduction in housing opportunities citywide, this alternative is the least effective in achieving the project objectives of the GPU. By setting a development cap to limit housing and nonresidential development to the projections for the city in the 2020 RTP/SCS, this alternative reduces housing units by 31,515 compared to the GPU. It reduces housing development potential within the focus areas by 73 percent in comparison to the GPU, and reduces overall city future development by 27 percent. To achieve this reduction, the development cap would not only limit focus area development but would restrict the entitled housing in Specific Plans/Special Zoning areas (reducing total housing within these areas by almost 14,000 units).

This alternative clearly would not optimize high density housing that maximizes mass transit use (objective No. 2) or provide urban-level intensities at the urban edges (objective No. 3). Moreover, it would not facilitate intensities that attract economic activities, particularly since it would not allow the maximum entitlement of approved Specific Plans and Special Zoning areas. It would achieve the remainder of the objectives, but to a lesser extent than the GPU. It would protect established neighborhoods, but not promote infill development as much as the GPU or other alternatives (objective No. 1). It would provide only limited opportunities for live-work and artist spaces and small-scale manufacturing (objective No. 7).

Reduced Park Demand Alternative
The City’s Park standard of 2 acres per 1,000 residents is not achieved under existing conditions and development allowed under the GPU would further exacerbate park and open space shortages. Without new parks, growth in any of the focus areas would exacerbate the current level of park deficiency either in or adjacent to disadvantaged communities. The areas proposed for substantial new residential development under the GPU were compared to the distribution of existing parks—location, size, and demand—to define the Reduced Park Demand Alternative.

The Reduced Park Demand Alternative reduces residential growth by 11,225 units by eliminating or reducing residential land uses and intensity in the five focus areas. Overall, nonresidential square footage would be reduced by a total of approximately 2.8 million square feet within the focus areas compared to the proposed GPU. The nonresidential square footage would increase, however, in two of the focus areas: 17th Street/Grand Avenue by 697,000 square feet, and South Bristol by 739,000 square feet. New residential growth under this alternative would largely be in currently planned areas that are generally near a substantial number of existing park facilities.

Some residential growth would be introduced into two focus areas at substantially lower intensities to reduce the potential impact on park facilities. Changes to the focus areas are as follows:
 South Main Street. This focus area would remain as currently planned as a commercial corridor (GC) instead of Urban Neighborhood (UN) and District Center (DC) to reduce intensity City Council 30 – 111 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -61- October 2021
so that there are no additional units constructed beyond existing conditions; there is a significant presence of EJ communities that are served by parks, but the existing parks are very small.
 South Bristol Focus Area. District Center (DC) changed to Urban Neighborhood (UN) to reduce intensity by 2,273 units on sites that are more than a half mile from existing parks (generally west of Bristol and south of MacArthur Boulevard).  Grand Avenue/17th Street. Stay as currently planned as a lower density residential (LR-7) and commercial corridor (GC) to reduce intensity so that there are no additional units constructed beyond existing conditions, because much of the focus area is more than a half mile from existing parks.
 West Santa Ana Boulevard. This focus area would remain as currently planned with lower density residential (LR-7) instead of Urban Neighborhood (UN) to reduce intensity so that no additional units are constructed beyond existing conditions; there is a significant presence of EJ communities with areas that are farther than a half mile from existing parks in this focus area.
 55 Freeway/Dyer Road. District Center (DC) changed to Urban Neighborhood (UN) to reduce intensity by 5,381 units because a majority of the area is more than a half mile from existing parks in Santa Ana; the reduced intensity would also reduce potential impacts on adjacent parkland in Tustin.

Finding. The City Council rejects the Reduced Park Demand Alternative on the basis of policy and economic factors as explained herein. (See Pub. Resources Code, § 21061.1; CEQA Guidelines, § 15364; see also City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; California Native Plant Soc. v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible this project alternative identified in the Recirculated PEIR.

This alternative would result in similar impacts to 6 impact categories, reduced impacts to 12 categories, and increased impacts to 2 categories. Impacts would be similar for aesthetics, agricultural resources, hazards and hazardous materials, hydrology and water quality, mineral resources, and wildfire. This alternative would decrease impacts to air quality, biological resources, cultural resources, energy, geology and soils, greenhouse gas emissions, noise, population and housing, public services, recreation, tribal cultural resources, transportation, and utilities and services. It would reduce the recreation impacts of the proposed GPU, as it was designed to do, and would improve the park acres/resident ratio compared to the proposed GPU.

Recreation impacts to disadvantaged communities would also be reduced. Given the lack of available land for new parks, however, it would not eliminate the significant, unavoidable impact of the project. It would be expected to increase land use and planning impacts relative to the GPU.

As with the GPU, impacts to air quality, cultural resources, greenhouse gas emissions, noise, City Council 30 – 112 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -62- October 2021
population and housing, and recreation would remain significant and unavoidable. Overall, impacts under this alternative would be decreased in comparison to the proposed project.

This alternative would attain some of the project’s objectives. It would promote infill development to a lesser extent than the GPU and would protect established neighborhoods (Objective 1), and would also develop opportunities of live-work, artist spaces, and small-scale manufacturing (Objective 7). Given the substantial reduction in housing units, it was also concluded that it would not meet Objectives 2 and 3, to maximize high density residential development and mixed use proximate to potential mass transit use (Objective 2) and to maximize affordable housing and achieve City and regional housing goals (Objective 3). It would, however, achieve Objectives 4 through 6, but to a lesser extent than the proposed GPU. With new opportunities eliminated in three focus areas and the reduced opportunities in the 55 Freeway /Dyer Road and South Bristol focus areas, it would not be as effective in providing affordable housing opportunities and may not be as economically feasible in terms of funding community benefits. It would provide mixeduse opportunities that are bike and pedestrian friendly and provide opportunities for live-work, artist spaces, and small-scale manufacturing.

C. ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires a lead agency to identify the “environmentally superior alternative” and, in cases where the “No Project” Alternative is environmentally superior to the GPU, the environmentally superior development alternative must be identified. One alternative has been identified as “environmentally superior” to the GPU:
 The RTP/SCS Consistency Alternative is concluded to be the environmentally superior alternative. The No Project alternative is not environmentally superior to the proposed GPU.

Both the Reduced Density and RTP/SCS alternatives reduce environmental impacts in comparison to the GPU, but the RTP/SCS reduces more impacts and eliminates a significant, unavoidable impact of the GPU. This alternative was designed to eliminate the significant population impact of the GPU, but it also reduces potential future development more than any of the other alternatives.

City Council 30 – 113 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -63- October 2021
VII. STATEMENT OF OVERRIDING CONSIDERATIONS
A. INTRODUCTION
The City of Santa Ana is the Lead Agency under CEQA for preparation, review and certification of the PEIR for General Plan Update (project). As the Lead Agency, the City is also responsible for determining the potential environmental impacts of the proposed action and which of those impacts are significant, and which can be mitigated through imposition of mitigation measures to avoid or minimize those impacts to a level of less than significant. CEQA then requires the Lead Agency to balance the benefits of a proposed action against its significant unavoidable adverse environmental impacts in determining whether or not to approve the proposed project.

In making this determination the City is guided by CEQA Guidelines Section 15093, Statement of Overriding Considerations, which states:
a. CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.”
b. When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the final EIR and/or other information in the record.

The statement of overriding considerations shall be supported by substantial evidence in the record.
c. If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091.

In addition, Public Resources Code Section 21081(b) requires that where a public agency finds that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in an EIR and thereby leave significant unavoidable effects, the public agency must also find that overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects of the project.

Pursuant to Public Resources Code Section 21081(b) and the State CEQA Guidelines Section 15093, the City has balanced the benefits of the proposed project against the unavoidable adverse impacts associated with the project and has adopted all feasible mitigation measures City Council 30 – 114 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -64- October 2021
with respect to these impacts. The City also has examined alternatives to the proposed project, none of which both meets the project objectives and is environmentally preferable to the proposed project, for the reasons discussed in the Findings and Facts in Support of Findings.

The City of Santa Ana, as the Lead Agency for this project, and having reviewed the PEIR for the GPU, and reviewed all written materials within the City’s public record and heard all oral testimony presented at public hearings, adopts this Statement of Overriding Considerations, which has balanced the benefits of the project against its significant unavoidable adverse environmental impacts in reaching its decision to approve the project.

B. OVERRIDING CONSIDERATIONS
The City, after balancing the specific economic, legal, social, technological, and other benefits of the project, has determined that the unavoidable adverse environmental impacts identified above may be considered acceptable due to the following specific considerations, which outweigh the unavoidable, adverse environmental impacts of the project, and each of which, standing alone, is sufficient to support approval of the project, in accordance with CEQA Section 21081(b) and CEQA Guidelines Section 15093. The specific economic, legal, social, technological, or other benefits of the project are as follows:

1. The community, land use, and public services elements of the project encourage healthy lifestyles, a planning process that ensures that health impacts are considered, and policies and practices that improve the health of residents. The policies also affirm and support a socially and economically diverse community with equitable distribution of resources.

2. Implementation of the GPU fulfills one of the key strategies identified in the Santa Ana Strategic Plan in the completion of a comprehensive update of the existing General Plan.

3. The project improves the jobs-housing balance; the ratio of 1.5 would give the city a more equal distribution of employment and housing. The population growth resulting directly from the proposed GPU would be offset by the level of employment opportunity provided to the city’s residents and workers commuting into Santa Ana.

4. The project results in a reduction of vehicle miles traveled per service population (VMT/SP) and a reduction in related traffic congestion, air quality, and greenhouse gas emissions compared with existing conditions because the GPU includes policies that promote the reduction of VMT. Policy 2.5 of the land use element encourages infill mixed-use development at all ranges of affordability to reduce VMT, and policy 4.5 aims to concentrate development along high-quality transit corridors. Policy 4.6 of the circulation element promotes reductions in automobile trips and VMT by encouraging transit use and nonmotorized transportation as alternatives to augmenting roadway capacity.

5. The project provides additional housing to support the regionally forecasted increase in economic activities and employment increases.

City Council 30 – 115 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -65- October 2021

6. Implementation of the project would introduce policies and actions that address the importance of protecting the health of residents and the environment by improving air quality, reducing greenhouse gas emissions, and encouraging active transportation.

7. The project implements the SCAG Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) land use policies related to population and housing by providing additional housing near employment centers.

8. The project facilitates the economic development of the city by promoting development that is mixed use, pedestrian friendly, transit oriented, and clustered around activity centers through new and infill residential development. Additionally, the proposed project would improve the city’s jobs/housing balance by supporting development that provides housing and employment opportunities to enable people to live and work in Santa Ana.

9. Implementation of the project would coordinate air quality planning efforts to meet state and federal ambient air quality standards by considering the goals of the Climate Action Plan in all major decision on land use and public infrastructure investment and investing in low- to zero-emission vehicles. These policies also promote development that meets or exceeds standards for energy-efficient building design, and the consideration of sensitive of potential emission sources on sensitive uses.

10. The project promotes economic growth and diversity within the city. The economic prosperity element of the GPU includes policies related to improving Santa Ana’s economy and its role within the region.

City Council 30 – 116 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -66- October 2021
VIII. RESOLUTION REGARDING CERTIFICATION OF THE PEIR
The City of Santa Ana finds that it has reviewed and considered the Final Recirculated PEIR in evaluating the proposed project, that the Final Recirculated PEIR is an accurate and objective statement that fully complies with CEQA and the State CEQA Guidelines, and that the Final Recirculated PEIR reflects the independent judgment of the City.

The City of Santa Ana declares that no new significant information, as defined by State CEQA Guidelines, section 15088.5, has been received by the City after circulation of the Recirculated Draft PEIR that would require further recirculation.

The City of Santa Ana certifies the PEIR based on the entirety of the record of proceedings, including but not limited to the following findings and conclusions:

Findings: The following significant environmental impacts have been identified in the PEIR and will require mitigation as set forth in Section V of this Resolution but cannot be mitigated to a level of insignificance: air quality (project-related and cumulative), cultural resources (projectrelated), greenhouse gas emissions (project-related), noise (project-related), population and housing (project-related), recreation (project-related).

Conclusions

1. Except the impacts (stated above) relating to air quality, cultural resources, greenhouse gas, noise, population and housing, and recreation all significant environmental impacts from the implementation of the proposed project have been identified in the PEIR and, with implementation of the mitigation measures identified, will be mitigated to a level of insignificance.

2. Other alternatives to the proposed project, which could potentially achieve the basic objectives of the proposed project, have been considered and rejected in favor of the proposed project.

3. Environmental, economic, social, and other considerations and benefits derived from the development of the proposed project override and make infeasible any alternatives to the proposed project or further mitigation measures beyond those incorporated into the proposed project.

City Council 30 – 117 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -67- October 2021
IX. RESOLUTION ADOPTING A MITIGATION MONITORING AND REPORTING PLAN Pursuant to Public Resources Code section 21081.6, the City of Santa Ana hereby adopts the Mitigation Monitoring and Reporting Plan attached to this Resolution as Exhibit A. In the event of any inconsistencies between the mitigation measures as set forth herein and the Mitigation Monitoring and Reporting Plan, the Mitigation Monitoring and Reporting Plan shall control.

City Council 30 – 118 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -68- October 2021
X. RESOLUTION REGARDING CONTENTS AND CUSTODIAN OF RECORDS The documents and materials that constitute the record of proceedings on which these findings have been based are located at the City of Santa Ana Planning Division Counter. The custodian for these records is the City of Santa Ana. This information is provided in compliance with Public Resources Code section 21081.6.

The record of proceedings for the City’s decision on the project consists of the following documents, at a minimum:

1. The NOP and all other public notices issued by the City in conjunction with the project.

2. The Draft PEIR for the Santa Ana General Plan Update.

3. All comments submitted by agencies or members of the public during the 45-day comment period on the Draft PEIR and the 20-day extension to the comment period.

4. The Final PEIR for the Santa Ana General Plan Update, including comments received on the Draft PEIR, responses to those comments, and technical appendices.

5. The Recirculated Draft PEIR for the Santa Ana General Plan Update.

6. All comments submitted by agencies or members of the public during the 45-day comment period on the Recirculated Draft PEIR.

7. The Final Recirculated PEIR for the Santa Ana General Plan Update, including comments received on the Recirculated Draft PEIR, responses to those comments, and technical appendices.

8. The Mitigation Monitoring and Reporting Plan for the project.

9. All findings, resolutions, and ordinances adopted by the City in connection with the General Plan Update, and all documents cited or referred to therein.

10. All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the project prepared by the City, consultants to the City, or responsible or trustee agencies with respect to the City’s compliance with the requirements of CEQA and with respect to the City’s action on the Santa Ana General Plan Update.

11. All documents submitted to the City by other public agencies or members of the public in connection with the General Plan Update PEIR up through project approval. Matters of common knowledge to the City, including, but not limited to federal, state, and local laws and regulations.

12. Any documents expressly cited or referenced in these findings, in addition to those cited above.

City Council 30 – 119 4/19/2022
Santa Ana General Plan Update
CEQA Findings of Fact and Statement
Of Overriding Considerations -69- October 2021

13. Any other materials required for the record of proceedings by Public Resources Code section 21167.6, subdivision (e).

The following location is where the record may be reviewed:

City of Santa Ana, Planning Division Counter
20 Civic Center Plaza, M-20
Santa Ana, CA 92701
This page intentionally left blank.

City Council 30 – 120 4/19/2022
October 2021 | Mitigation Monitoring and Reporting Program Santa Ana General Plan Update
City of Santa Ana
Prepared for:

City of Santa Ana
Contact: Melanie G. McCann, Principal Planner
20 Civic Center Plaza
Santa Ana, CA 92702
[email protected]
Prepared by:

PlaceWorks
Contact: JoAnn Hadfield, Principal
3 MacArthur Place, Suite 1100
Santa Ana, California 92707
714.966.9220
[email protected]
www.placeworks.com

EXHIBIT C
City Council 30 – 121 4/19/2022
City Council 30 – 122 4/19/2022

GENERAL PLAN UPDATE MITIGATION MONITORIN G AND REPORTING PROG RAM

CITY OF SANTA ANA
Mitigation Monitoring and Reporting Program
October 2021 Page i
Section Page

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

1.1 PURPOSE OF MITIGATION MONITORING AND REPORTING PROGRAM............................ 1

1.2 PROJECT SUMMARY ......................................................................................................................................... 2

1.3 PROJECT LOCATION ....................................................................................................................................... 5

1.4 MITIGATION MONITORING PROGRAM ORGANIZATION........................................................... 6 List of Tables
Table Page
Table 1-1 Proposed Land Use Designations and Statistics.............................................................................. 3 Table 1-2 Buildout Statistical Summary .............................................................................................................. 5 Table 1-3 Mitigation Monitoring and Reporting Requirements...................................................................... 7 City Council 30 – 123 4/19/2022

GENERAL PLAN UPDATE MITIGATION MONITORIN G AND REPORTING PROG RAM

CITY OF SANTA ANA
Mitigation Monitoring and Reporting Program
Page ii PlaceWorks
This page intentionally left blank.

City Council 30 – 124 4/19/2022
October 2021 Page 1

1. Introduction

1.1 PURPOSE OF MITIGATION MONITORING AND REPORTING

PROGRAM
This Mitigation Monitoring and Reporting Program (MMRP) has been developed to provide a vehicle to monitor mitigation measures and conditions of approval outlined in the Final Recirculted Program Environmental Impact Report. The MMRP has been prepared in conformance with Section 21081.6 of the Public Resources Code and City of Santa Ana monitoring requirements. Section 21081.6 states:
(a) When making the findings required by paragraph (1) of subdivision subsection (a) of Section 21081 or when adopting a mitigated negative declaration pursuant to paragraph (2) of subdivision (c) of Section 21080, the following requirements shall apply:
(1) The public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation. For those changes which have been required or incorporated into the project at the request of a responsible agency or a public agency having jurisdiction by law over natural resources affected by the project, that agency shall, if so requested by the lead agency or a responsible agency, prepare and submit a proposed reporting or monitoring program.
(2) The lead agency shall specify the location and custodian of the documents or other material which constitute the record of proceedings upon which its decision is based. (b) A public agency shall provide that measures to mitigate or avoid significant effects on the environment are fully enforceable through permit conditions, agreements, or other measures.

Conditions of project approval may be set forth in referenced documents which address required mitigation measures or, in the case of the adoption of a plan, policy, regulation, or other public project, by incorporating the mitigation measures into the plan, policy, regulation, or project design.
(c) Prior to the close of the public review period for a draft environmental impact report or mitigated negative declaration, a responsible agency, or a public agency having jurisdiction over natural resources affected by the project, shall either submit to the lead agency complete and detailed performance objectives for mitigation measures which would address the significant effects on the environment identified by the responsible agency or agency having jurisdiction over natural resources affected by the project, or refer the lead agency to appropriate, readily available guidelines or reference documents. Any mitigation measures submitted to a lead City Council 30 – 125 4/19/2022

GENERAL PLAN UPDATE MITIGATION MONITORIN G AND REPORTING PROG RAM

CITY OF SANTA ANA
Mitigation Monitoring and Reporting Program

Page 2 ends

Santa Ana City CouncilApril 19, 2022

Santa Ana City Council
April 19, 2022