Regional: 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy Table 16 includes an analysis of the Project’s consistency with the GHG-related objectives of the 2020-2045 RTP/SCS.
Table 16
Consistency with the 2020-2045 RTP/SCS
Objectives
Increase percentage of region’s total The Project would result in an increase of 507 households in an household growth occurring within HQTAs. HQTA, including both townhomes and attached apartments.
Consistency Analysisa
Increase percent of the region’s total The Project is an infill development that would create more employment growth occurring within HQTAs. service-related retail and commercial jobs, consistent with the 2020 RTP/SCS policies and would focus on job growth in
HQTAs.
Decrease total acreage of greenfield or The Project is an infill development that would reduce the otherwise rural land uses converted to urban demand for sprawl development in greenfield or rural areas on use. the fringes of Southern California.
Decrease daily vehicle miles driven per The Project is an infill development amid heavy transit person. infrastructure that would reduce daily VMT per capita. The Project is served by two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station to the west.
Decrease average daily distance traveled for The Project is an infill development in the dense urban corridor work and non-work trips (in miles) with a heavy density of housing and jobs amid transit infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would reduce per capita travel distances.
Increase percentage of work and non-work The Project is an infill development in the dense urban corridor trips which are less than 3 miles in length. with a heavy density of housing and jobs amid transit infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would increase the rate of travel less than three miles in length.
Increase share of short trip lengths for The Project is an infill development in the dense urban corridor commute purposes. with a heavy density of housing and jobs amid transit infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would shorten commute trips.
Decrease average minutes of delay The Project is an infill development in the dense urban corridor experienced per capita due to traffic within an HQTA and within a heavy density of housing and jobs congestion. amid transit infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would reduce the rate of growth in auto traffic and congestion by virtue of its Cabrillo Town Center City of Santa Ana
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Table 16
Consistency with the 2020-2045 RTP/SCS
Objectives Consistency Analysisa
transit and active transportation mode share given its location along this major corridor.
Decrease excess travel time resulting from The Project is an infill development in the dense urban corridor the difference between a reference speed with a heavy density of housing and jobs amid transit and actual speed. infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would reduce the rate of growth in auto traffic and congestion by virtue of its transit and active transportation mode share given its location. As such, the Project would help reduce recurrent traffic congestion delay for general vehicles.
Decrease excess travel time for heavy-duty The Project is an infill development in the dense urban corridor trucks result from the difference between with a heavy density of housing and jobs amid transit reference speed and actual speed. infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would reduce the rate of growth in auto traffic and congestion by virtue of its transit and active transportation mode share. As such, the Project would help reduce recurrent traffic congestion delay for heavy-duty trucks.
Increase percentage of PM peak period trips The Project is an infill development in the dense urban corridor completed within 45 minutes by travel mode. with a heavy density of housing and jobs amid transit infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would reduce the rate of growth in auto traffic and congestion by virtue of its transit accessibility. Because the Project’s location will attract travel to and from the corridor and local community, the share of PM peak period trips that are less than 45 minutes would increase when compared to an urban sprawl location.
Increase percentage of trips that use transit The Project is an infill development in the dense urban corridor (work and all trips) with a heavy density of housing and jobs amid transit infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would help increase transit mode share.
Decrease average travel time to work (all The Project is an infill development in the dense urban corridor modes) with a heavy density of housing and jobs amid transit infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would reduce the rate of growth in auto traffic and congestion by virtue of its transit and active transportation mode share given its location along the corridor. As such, average travel time to work should be reduced when compared to an urban sprawl location.
Increase percentage of trips using either The Project is an infill development in the dense urban corridor walking or biking (by trip type) with a heavy density of housing and jobs amid transit infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would reduce the rate of Cabrillo Town Center City of Santa Ana
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Table 16
Consistency with the 2020-2045 RTP/SCS
Objectives Consistency Analysisa
growth in auto traffic and congestion by virtue of its transit accessibility along the corridor.
Reduce per capita GHG emissions (from The Project is an infill development in the dense urban corridor 2005 levels) within an HQTA with a heavy density of housing and jobs amid transit infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would reduce the rate of growth in auto traffic and congestion by virtue of its transit accessibility. As such, it is consistent with AB 32, SB 32, SB 375, and other initiatives designed to reduce per capita GHG emissions from 2005 levels.
Increase percentage of trips using a travel The Project is an infill development in the dense urban corridor mode other than single occupancy vehicle with a heavy density of housing and jobs amid transit (SOV) infrastructure (two OCTA bus lines 64 and 71, as well as the Santa Ana Metrolink station) that would reduce the rate of growth in SOV use and congestion by virtue of its transit accessibility within walking distance of the Project Site.
Locally, the City has several conservation-based plans, programs, and requirements that also indirectly produce GHG reductions. While these are not considered climate action plans, the Project’s consistency with these local initiatives is summarized below for informational purposes.
Santa Ana Climate Action Plan
The 2022 CAP provides a summary table of Climate-Ready Development Standards, including mandatory measures that are applicable to development projects. It should be noted that most of the CAP’s measures are voluntary, with financial incentives available to promote increased implementation of those measures. As shown in Table 17, the Project would be substantially consistent with the City’s CAP.
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Table 17
Project Consistency with the Santa Ana CAP
Source Measure Consistency
The Project includes retail uses along Fourth Street
Development of Local Retail and Cabrillo Town Drive that would serve the Project Service Nodes and the larger Santa Ana community that would help reduce VMT associated with travel to retail services.
The Project includes 507 residences along Fourth
Local Residential Nodes Near Street and Cabrillo Town Drive on a largely Transportation Retail and Employment
and Land Use
commercial corridor that would help reduce VMT
associated with travel from residences.
Measures The Project includes retail and commercial uses along Local Employment Nodes Fourth Street and Cabrillo Town Drive that would Near Residential and Retail serve the Project Site and the larger Santa Ana Areas community that would help reduce VMT associated
with travel to retail services within an HQTA.
End of Trip Facilities in New The Project includes short- and long-term parking for Projects bicycles for both residents and commercial tenants.
The Project would meet energy efficiency
requirements for the commercial spaces and comply
with current 2022 CalGreen requirements.
Title 24 Energy Efficiency
Standards – Commercial. CommunityWide Energy
Measures Title 24 Energy Efficiency The Project would meet energy efficiency Standards – Residential. requirements for the residential spaces.
Residential and commercial tenants would have fullservice recycling options consistent with AB 341 that would help increase diversion of waste from landfills.
The Project would provide artificial turf in its common areas and courtyards that would reduce water
consumption.
AB 341 Commercial and
Multifamily Recycling. Solid Waste,
Water, and
Wastewater
Measures Turf Removal.
Source: City of Santa Ana, Climate Action Plan (Final); December 2015.
Post-2030 Analysis
Recent studies show that the state’s existing and proposed regulatory framework will put the state on a pathway to reduce its GHG emissions level to 40 percent below 1990 levels by 2030, and to 80 percent below 1990 levels by 2050 if additional appropriate reduction measures are adopted.13 Even though these studies did not provide an exact regulatory and technological roadmap to achieve the 2030 and 2050 goals, they demonstrated that various combinations of policies could allow the statewide emissions level to remain very low through 2050, suggesting that the combination of new technologies and other regulations not analyzed in the studies could allow 13 Energy and Environmental Economics (E3). “Summary of the California State Agencies’ PATHWAYS Project: Long-term Greenhouse Gas Reduction Scenarios” (April 2015); Greenblatt, Jeffrey, Energy Policy, “Modeling California Impacts on Greenhouse Gas Emissions” (Vol. 78, pp. 158–172). The California Air Resources Board, California Energy Commission, California Public Utilities Commission, and the California Independent System Operator engaged E3 to evaluate the feasibility and cost of a range of potential 2030 targets along the way to the state’s goal of reducing GHG emissions to 80 percent below 1990 levels by 2050. With input from the agencies, E3 developed scenarios that explore the potential pace at which emission reductions can be achieved, as well as the mix of technologies and practices deployed. E3 conducted the analysis using its California PATHWAYS model. Enhanced specifically for this study, the model encompasses the entire California economy with detailed representations of the buildings, industry, transportation, and electricity sectors.
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the state to meet the 2050 target. After the findings of these studies, SB 32 was passed on September 8, 2016, and would require the state board to ensure that statewide GHG emissions are reduced to 40 percent below the 1990 level by 2030. As discussed above, the new plan, outlined in SB 32, involves increasing renewable energy use, imposing tighter limits on the carbon content of gasoline and diesel fuel, putting more electric cars on the road, improving energy efficiency, and curbing emissions from key industries.
As discussed above, SCAG’s 2020-2045 RTP/SCS establishes a regulatory framework for achieving GHG reductions from the land use and transportation sectors pursuant to SB 375 and the state’s long-term climate policies. The 2020-2045 RTP/SCS ensures VMT reductions and other measures that reduce regional emissions from the land use and transportation sectors.
The Project is the type of land use development that is encouraged by the 2020-2045 RTP/SCS to reduce VMT and expand multi-modal transportation options for the region to achieve the GHG reductions from the land use and transportation sectors required by SB 375, which, in turn, advances the state’s long-term climate policies. By furthering implementation of SB 375, the Project supports regional land use and transportation GHG reductions substantially consistent with state climate targets for 2020 and beyond. In addition, the Project would be consistent with the Actions and Strategies set forth in the 2020-2045 RTP/SCS. Therefore, the Project would be consistent with the 2020-2045 RTP/SCS.
Conclusion
Given the Project’s substantial consistency with state, SCAG, and City GHG emissions reduction goals and objectives, the Project is consistent with applicable plans, policies, and regulations adopted for the purpose of reducing the emissions of GHG emissions. In the absence of adopted standards and established significance thresholds, and given this consistency, it is concluded that the Project’s incremental contribution to GHG emissions and their effects on climate change would not be cumulatively considerable.
Mitigation Measures
None required.
4.8.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
Although the topic of GHG emissions is new to the CEQA Guidelines (when compared to the 2006 CEQA Guidelines), as demonstrated above for informational purposes, the Project would be substantially consistent with all applicable GHG emissions reduction plans and would not result in any significant impacts related to GHG emissions. Thus, the Project would not result in new or more severe significant environmental impacts as compared with the potential GHG impacts resulting from a Project consistent with the uses, building density and intensity and envelope permitted by the Overlay Zone assumed in the Certified EIR .
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4.8.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
Although the topic of GHG emissions is new to the CEQA Guidelines (when compared to the 2006 CEQA Guidelines), as demonstrated above for informational purposes, the Project would be substantially consistent with all applicable GHG emissions reduction plans and would not result in any significant impacts related to GHG emissions as could have occurred at the time of adoption of the Certified EIR, given the Project’s consistency with the Overlay Zone’s permitted uses, intensity, density and building envelope. Thus, the Project would not result in new or more severe significant environmental impacts than could have occurred at the time of the Certified EIR.
Further, GHG emissions-related impacts have long been known and understood at the time the Certified EIR was certified, and therefore, does not constitute new information for the purposes of this analysis.
4.8.5 Mitigation Measures Addressing Impacts
None required.
4.8.6 Conclusion
Although the topic of GHG emissions is new to the CEQA Guidelines (when compared to the 2006 CEQA Guidelines), as demonstrated above for informational purposes, the Project would be substantially consistent with all applicable GHG emissions reduction plans and would not result in any significant impacts related to GHG emissions. Thus, the Project would not result in new or more severe significant environmental impacts.
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4.9 Hazards and Hazardous Materials
Any Substantial Any Substantially
Changes
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Changed
Circumstances
Involving New
Significant Impact
or Substantially
More Severe
Any New
Information of Incorporates
Substantial
Importance?
Project
Impact
Issues (and supporting
Information Sources)
Determination
in EIR
Mitigation
Impacts? Measure(s)?
HAZARDS AND HAZARDOUS
MATERIALS: Would the project:
(a) Create a significant
hazard to the public or the
environment through the
routine transport, use, or
disposal of hazardous
materials?
Less Than
Significant with
Mitigation
No
No
No
No
No
No
Yes
Yes
(b) Create a significant
hazard to the public or the
environment through the
reasonably foreseeable
upset and accident
Less Than
Significant With
conditions involving the Mitigation
likely release of
hazardous materials into
the environment?
(c) Emit hazardous emissions
or handle hazardous or
acutely hazardous Less Than
Significant materials, substances, or
waste within one-quarter
mile of an existing or
No No No No
proposed school?
(d) Be located on a site which
is included on a list of
hazardous materials sites
compiled pursuant to
Government Code Less Than
Significant with
Mitigation
No No No No §65962.5 and, as a result,
would it create a
significant hazard to the
public or the
environment?
(e) For a project located
within an airport land use
plan or, where such a
plan has not been
adopted, within two miles
of a public airport or
public use airport, would
the project result in a
safety hazard or
Less Than
Significant With
Mitigation
No No No No
excessive noise for
people residing or working
in the project area?
(f) Impair implementation of
or physically interfere with
an adopted emergency
response plan or
Less Than
Significant With
Mitigation
No
No
No
No
No
No
Yes
No
emergency evacuation
plan?
(g) Expose people or
structures either directly No Impact
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Any Substantial Any Substantially
Changes
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Changed
Circumstances
Involving New
Significant Impact
or Substantially
More Severe
Any New
Information of Incorporates
Substantial
Importance?
Project
Impact
Determination
in EIR
Issues (and supporting
Information Sources)
Mitigation
Impacts? Measure(s)?
or indirectly to a
significant risk of loss,
injury or death involving
wildland fires?
4.9.1 Impact Determination in the EIR
Routine Transport, Use, or Disposal of Hazardous Materials The Certified EIR stated that the Overlay Zone is characterized by office and commercial facilities.
Implementation of the Overlay Zone would introduce residential uses and create a mixed-use area that is divided into four distinct districts. While the residential, commercial and office mixeduses that could be developed under Overlay Zone are not expected to introduce any unusual hazardous materials to the area, some hazardous materials would be used in varying amounts during construction and operation of future occupation and would consist mostly of typical household-type cleaning products as well as maintenance products (e.g., paints, solvents, cleaning products). Additionally, grounds and landscape maintenance within the development area could also use a wide variety of commercial products formulated with hazardous materials, including fuels, cleaners and degreasers, solvents, paints, lubricants, adhesives, sealers, and pesticides/herbicides.
Exposure of persons to hazardous materials could occur in the following manners: improper handling or use of hazardous materials or hazardous wastes during construction or operation of future developments, particularly by untrained personnel; transportation accident; environmentally unsound disposal methods; or fire, explosion or other emergencies. The types and amounts of hazardous materials would vary according to the nature of the activity. In some cases, it is the type of hazardous material that is potentially hazardous; in others, it is the amount of hazardous material that could present a hazard.
Whether a person exposed to a hazardous substance would suffer adverse health effects depends upon a complex interaction of factors that determine the effects of exposure to hazardous materials: the exposure pathway (the route by which a hazardous material enters the body); the amount of material to which the person is exposed; the physical form (e.g., liquid, vapor) and characteristics (e.g., toxicity) of the material; the frequency and duration of exposure; and the individual's unique biological characteristics, such as age, gender, weight, and general health. Adverse health effects from exposure to hazardous materials may be short-term (acute) or long-term (chronic). Acute effects can include damage to organs or systems in the body and possibly death. Chronic effects, which may result from long-term exposure to a hazardous material, can also include organ or systemic damage, but chronic effects of particular concern Cabrillo Town Center City of Santa Ana
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include birth defects, genetic damage, and cancer. Implementation of existing hazardous materials regulations were established at the state level to ensure compliance with federal regulations to reduce the risk to human health and the environment from the routine use of hazardous substances.
All new developments that handle or use hazardous materials would be required to comply with existing regulations, standards, and guidelines established by the EPA, State, Orange County, and the City of Santa Ana related to storage, use, and disposal of hazardous materials. Specific requirements for implementation of these statutes are codified in Title 40 of the Code of Federal Regulations (CFR). Additional regulations that apply to workplace safety are contained in CFR Titles 8 and 29. Regulations that pertain to radioactive materials are included in CFR Title 10.
The USDOT Office of Hazardous Materials Safety prescribes strict regulations for the safe transportation of hazardous materials, as described in Title 49 of the Code of Federal Regulations and implemented by Title 13 of the CCR.
Additionally, both the federal and state governments require all businesses that handle more than a specified amount of hazardous materials to submit a business plan to a regulatory agency.
Specifically, any new business that meets the specified criteria must submit a full hazardous materials disclosure report that includes an inventory of the hazardous materials generated, used, stored, handled, or emitted; and emergency response plans and procedures to be used in the event of a significant or threatened significant release of a hazardous material. Specific requirements for implementation are codified primarily in Title 26 of the California Code of Regulations (CCR) and Chapter 6.95 of the California Health and Safety Code.
Hazardous materials are required to be stored in designated areas designed to prevent accidental release to the environment. California Building Code (CBC) requirements prescribe safe accommodations for materials that present a moderate explosion hazard, high fire or physical hazard, or health hazards. Compliance with all applicable federal and state laws related to the storage of hazardous materials would be implemented to maximize containment (through safe handling and storage practices) and to provide for prompt and effective cleanup if an accidental release occurs.
Adherence to existing regulations would ensure compliance with safety standards related to the use and storage of hazardous materials, and the safety procedures mandated by applicable federal, state, and local laws and regulations (RCRA, California Hazardous Waste Control Law, and principles prescribed by the California Department of Health Services, Centers for Disease Control and Prevention, and National Institutes of Health), which would ensure that risks resulting from the routine transportation, use, storage, or disposal of hazardous materials or hazardous wastes associated with construction and implementation of the Overlay Zone would be less than significant. No mitigation is required.
The Certified EIR also stated implementation of the Overlay Zone would not result in land uses that would create a significant hazard to the public or the environment. However, it is possible that existing uses within the vicinity could create a significant hazard to future residents of the Cabrillo Town Center City of Santa Ana
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area. The Overlay Zone is located directly between two heavily traveled freeways (I-5 and SR55), which could emit hazardous amounts of diesel exhaust. Due to the proximity of the freeways and the potential increase in residential uses as a result of project implementation, this could pose a potentially significant impact. In order to ensure that existing conditions within the Overlay Zone area do not pose a significant health threat to future uses, compliance with Mitigation Measure MM-OZ 4.6-1 would be required. Implementation of Mitigation Measure MM-OZ 4.6-1 would ensure that risks associated with diesel emissions from the nearby freeways would be thoroughly evaluated prior to construction of residential uses. The health risk assessments would identify any unacceptable risk and would provide recommendations to reduce the risk within acceptable limits. Thus, development within the Overlay Zone would not pose an actual or potential endangerment to future residents. Therefore, it was determined that this impact will be reduced to a less than significant level.
Release of Hazardous Materials
The Certified EIR stated that the Overlay Zone would primarily result in urban infill and redevelopment with mixed-uses within the Overlay Zone area, existing structures may need to be demolished prior to the construction of new buildings. Demolition of existing structures could result in exposure of construction personnel and the public to hazardous substances such as asbestos or lead-based paints, depending on the age of the structure. In addition, the disturbance of soils and the demolition of existing structures could result in the exposure of construction workers or employees to health or safety risks if contaminated structures and/or soils are encountered during construction. Exposure to contaminated structures or soil could occur from asbestos or lead in older buildings, unknown contaminants that have not previously been identified, or existing contamination present at locations identified in the site records search.
Exposure to hazardous materials during construction activities could occur through any of the following:
•
•
Direct dermal contact with hazardous materials
Incidental ingestion of hazardous materials (usually due to improper hygiene, when workers fail to wash their hands before eating, drinking, or smoking) • Inhalation of airborne dust released from dried hazardous materials Demolition Activities
While specific development projects are not associated with approval of the Overlay Zone it is assumed that older buildings could be demolished as uses are redeveloped according to the overlay zone. With that activity, construction workers and nearby workers and/or future residents could potentially be exposed to airborne lead-based paint dust, asbestos fibers, and/or other contaminants. In addition, there is the possibility that future development may also uncover previously undiscovered soil contamination as well as result in the release of potential contaminants that may be present in building materials (e.g., mold, lead, etc.). It was determined that this could result in a potentially significant impact.
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Lead and Asbestos
Federal and State regulations govern the renovation and demolition of structures where materials containing lead and asbestos are present. These requirements include: SCAQMD Rules and Regulations pertaining to asbestos abatement (including Rule 1403), Construction Safety Orders 1529 (pertaining to asbestos) and 1532.1 (pertaining to lead) from Title 8 of the California Code of Regulations, Part 61, Subpart M of the Code of Federal Regulations (pertaining to asbestos), and lead exposure guidelines provided by the U.S. Department of Housing and Urban Development (HUD). Asbestos and lead abatement must be performed and monitored by contractors with appropriate certifications from the State Department of Health Services. In addition, Cal/OSHA has regulations concerning the use of hazardous materials, including requirements for safety training, availability of safety equipment, hazardous materials exposure warnings, and emergency action and fire prevention plan preparation. Cal/OSHA enforces the hazard communication program regulations, which include provisions for identifying and labeling hazardous materials, describing the hazards of chemicals, and documenting employee-training programs. All demolition that could result in the release of lead and/or asbestos must be conducted according to Cal/OSHA standards. It was determined that adherence to existing regulations, which require appropriate testing and abatement actions for hazardous materials, will ensure that impacts are less than significant.
Soil and Groundwater Contamination
Unknown Contaminated Sites
Aside from the potential release of hazardous materials from demolition of existing structures within the Overlay Zone, grading and excavation of sites for future development resulting from implementation of the Overlay Zone may also expose construction workers and the public to potentially unknown hazardous substances present in the soil or groundwater. If any unidentified sources of contamination are encountered during grading or excavation, the removal activities required could pose health and safety risks such as the exposure of workers, materials handling personnel, and the public to hazardous materials or vapors. Such contamination could cause various short-term or long-term adverse health effects in persons exposed to the hazardous substances. In addition, exposure to contaminants could occur if the contaminants migrated from the contaminated zone to surrounding areas either before or after the surrounding areas were developed, or if contaminated zones were disturbed by future development at the contaminated location. If exposed to hazardous substances, this would result in a significant hazard to the public.
It is also possible that old underground storage tanks (USTs) that were in use prior to permitting and record keeping requirements may be present in the Overlay Zone. If an unidentified UST were uncovered or disturbed during construction activities, it would be closed in place or removed.
Removal activities could pose both health and safety risks, such as the exposure of workers, tank handling personnel, and the public to tank contents or vapors. Potential risks, if any, posed by USTs would be minimized by managing the tank according to existing Orange County standards Cabrillo Town Center City of Santa Ana
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as enforced and monitored by the Department of Environmental Health. The extent to which groundwater may be affected, if at all, depends on the type of contaminant, the amount released, and depth to groundwater at the time of the release. If groundwater contamination is identified, remediation activities would be required by the Santa Ana Regional Water Quality Control Board (SARWQCB) prior to the commencement of any new construction activities.
Existing Contaminated Sites
Another potential hazard to construction workers and the public could involve construction activities on existing sites that may potentially be contaminated. However, any new development occurring on these documented hazardous materials sites would have to be preceded by remediation and cleanup under the supervision of the State Department of Toxic Substance Control (DTSC) before construction activities could begin, if such actions have not already occurred.
In order to address the potential for encountering contamination within the Overlay Zone, Mitigation Measures MM-OZ 4.6-2 and MM-OZ 4.6-3 will minimize the potential risk of contamination by implementing investigation and remediation efforts at future development sites.
As such, the potential impacts associated with unknown contamination will be reduced to a less than significant level.
Compliance with existing regulations and implementation of Mitigation Measures MM-OZ 4.6-2 and MM-OZ4.6-3 would ensure that construction workers and the general public would not be exposed to any unusual or excessive risks related to hazardous materials during construction activities. As such, it was determined that impacts associated with the exposure of construction workers and the public to hazardous materials during construction activities will be less than significant.
Off-Site Transportation of Hazardous Materials
The United States Department of Transportation (USDOT) Office of Hazardous Materials Safety prescribes strict regulations for the safe transportation of hazardous materials, as described in Title 49 of the Code of Federal Regulations and implemented by Title 13 of the CCR.
The transportation of hazardous materials can result in accidental spills, leaks, toxic releases, fire, or explosion. It is possible that licensed vendors could bring some hazardous materials to and from new retail-commercial sites in the Overlay Zone as a result of the subsequent projects constructed pursuant to the proposed project. However, appropriate documentation for all hazardous waste that is transported in connection with specific project-site activities would be provided as required for compliance with existing hazardous materials regulations codified in Titles 8, 22, and 26 of the California Code of Regulations, and their enabling legislation set forth in Chapter 6.95 of the California Health and Safety Code. In addition, specific project-site developers shall comply with all applicable Federal, State, and local laws and regulations Cabrillo Town Center City of Santa Ana
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pertaining to the transport, use, disposal, handling, and storage of hazardous waste, including but not limited to, Title 49 of the Code of Federal Regulations.
Compliance with all applicable Federal and State laws related to the transportation of hazardous materials would reduce the likelihood and severity of accidents during transit, thereby ensuring that a less than significant impact would occur. No mitigation is required.
Hazardous Materials Storage
Hazardous materials are required to be stored in designated areas designed to prevent accidental release to the environment. California Building Code (CBC) requirements prescribe safe accommodations for materials that present a moderate explosion hazard, high fire or physical hazard, or health hazards. Compliance with all applicable Federal and State laws related to the storage of hazardous materials would be implemented to maximize containment (through safe handling and storage practices described above) and to provide for prompt and effective cleanup if an accidental release occurs, thereby ensuring that a less than significant impact would occur. No mitigation is required.
Hazardous Materials Use
Hazardous materials use would present a slightly greater risk of accident than hazardous materials storage. However, for those employees who would work with hazardous materials, the amount of hazardous materials that are handled at any one time are generally relatively small, reducing the potential consequences of an accident during handling. Further, specific project-site activities would be required to comply with Federal and State laws to eliminate or reduce the consequence of hazardous materials accidents. For example, employees who would work around hazardous materials would be required to wear appropriate protective equipment, and safety equipment is routinely available in all areas where hazardous materials are used.
The Santa Ana Fire Department Haz-Mat personnel responds to hazardous materials incidents.
Major hazardous materials accidents associated with retail-commercial uses are extremely infrequent, and additional emergency response capabilities are not anticipated to be necessary to respond to the potential incremental increase in the number of incidents that could result from implementation of the proposed project. Further, adherence to applicable regulations as discussed above would be required to reduce any potential consequences of a hazardous materials operational accident. Thus, impacts related to the use of hazardous materials would be less than significant.
Summary
Compliance with Titles 8, 22, 26, and 49 of the California Code of Regulations, and their enabling legislation set forth in Chapter 6.95 of the California Health and Safety Code, would ensure that this impact is less than significant by requiring compliance with applicable laws and regulations that would reduce the risk of hazardous materials use, transportation, and handling through the Cabrillo Town Center City of Santa Ana
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implementation of established safety practices, procedures, and reporting requirements. No mitigation is required.
Release Hazardous Materials Near a School
The Certified EIR stated that there are two schools located within one-quarter mile of the Overlay Zone. No additional schools are proposed in the Overlay Zone as part of the Overlay Zone. As discussed previously, limited amounts of some hazardous materials could be used in the construction and operation of new developments in the Overlay Zone, including the use of standard construction materials (e.g., paints, solvents, and fuels), cleaning and other maintenance products (used in the maintenance of buildings, pumps, pipes and equipment), diesel and other fuels (used in construction and maintenance equipment and vehicles), and the limited application of pesticides associated with landscaping around new developments. None of these materials would result in hazardous emissions or are considered acutely hazardous.
Although hazardous materials and waste generated from future development may pose a health risk to nearby schools, all businesses that handle or have on-site transportation of hazardous materials would be required to comply with the provisions of the City’s Fire Code and any additional elements as required in the California Health and Safety Code Article 1 Chapter 6.95 for Business Emergency Plan. As described previously, both the federal and state governments require all businesses that handle more than a specified amount of hazardous materials to submit a business plan to a regulatory agency.
The routine transport, use, and disposal of these materials would be subject to a wide range of laws and regulations intended to minimize potential health risks associated with their use or the accidental release of such substances. Compliance with existing regulations would minimize the risks associated with the exposure of sensitive receptors, including schools, to hazardous materials. This impact would be less than significant. No mitigation is required.
Listed Hazardous Materials Site
The Certified EIR stated that the Overlay Zone contains sites that have been identified on various regulatory databases as being contaminated from the release of hazardous substances in the soil, including d storage tanks and small-quantity generators of hazardous waste. Implementation of the Overlay Zone could lead to development of these sites. As discussed under Impact 4.6-3, development of these sites would be required to undergo remediation and cleanup before construction activities can begin. If contamination at any specific project site were to exceed regulatory action levels, the proponent would be required to undertake remediation procedures prior to grading and development under the supervision of appropriate regulatory oversight agencies (e.g., Santa Ana Fire Department, Orange County Environmental Health Division, Department of Toxic Substances Control, or Regional Water Quality Control Board), depending on the nature of any identified contamination. Thus, implementation of Mitigation Measures MMOZ 4.6-2 and MM-OZ 4.6-3, above, would ensure that contaminated sites undergo remediation activities prior to development activities. Consequently, if future development under the Overlay Zone is located on a site that is included on a list of hazardous materials sites, remediation would Cabrillo Town Center City of Santa Ana
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ensure that this impact would be reduced to a less-than-significant level.
Airport Hazards
The Certified EIR stated that John Wayne Airport (JWA) is the nearest public airport, which is located approximately 6.5 miles to the southwest of the Overlay Zone. As discussed previously in the Regulatory Framework, the Overlay Zone is located within a height restriction of 200 feet that overlays the entirety of Orange County. Because land uses that may occur in the Active Urban district under the Overlay Zone could exceed 200 feet in height, any such uses (over 200 feet in height) would subsequently fall within the Airport Planning Area for JWA. Therefore, any construction or alteration of more than 200 feet in height above the ground level at a project site requires filing with the FAA. Projects meeting this threshold must comply with procedures provided by Federal and State law, including filing a Notice of Proposed Construction or Alteration (FAA Form 7460-1). Specifically, filing the FAA Form 7460-1 would be required for any proposed structure that would be greater than 200 feet in height, at which time FAA would conduct an aeronautical study to determine if the structure would have an adverse effect on the airport or on aeronautical operations. Subsequent to the findings of the FAA aeronautical study, the project would be subject to ALUC consistency review.
As mentioned previously, development in the Active Urban district under the Overlay Zone could involve structures that exceed 200 feet in height. Development in the Neighborhood Transitional and Village Center districts would be more restricted in height limitations and would not be expected to exceed 200 feet in height. Because specific development projects are not proposed in the Overlay Zone, it is unknown whether future developments would actually be greater than 200 feet.
Additionally, it is possible that during the temporary construction period of projects in the Active Urban district, cranes could be used for a limited time to affix the floors and other appurtenances.
The FAA recognizes that construction of structures normally requires the use of temporary construction equipment that is of a greater height than the proposed structure.
Therefore, because future development could exceed 200 feet in height in the Active Urban district, this would be considered a potentially significant impact. Thus, implementation of Mitigation Measure MM-OZ 4.6-4 would be required for future development that could exceed 200 feet in height, which would require FAA approval to be obtained to ensure that construction and operation of future projects do not present a hazard to air navigation.
In addition, due to the fact that buildings within the Active Urban district may exceed 200 feet in height and because of the required City approvals for the Overlay Zone (i.e., General Plan Amendment and Zone change), the City would submit a referral for the Overlay Zone to the ALUC per Public Utilities Code (PUC) Section 21676(b) and the AELUP. Coupled with implementation of Mitigation Measure MM-OZ 4.6-4, future development in the Overlay Zone would not result in a safety hazard for people residing or working in the Overlay Zone area. It was determined that this impact will be reduced to a less-than-significant level.
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Heliports
Heliports are not proposed within the Overlay Zone. Due to the potential for an increase in residential uses within the Overlay Zone, it is assumed that heliports would be discouraged for future development because of noise and other safety issues. However, should heliports be proposed in the future within the Overlay Zone, such developments would be required to be submitted through the City to the ALUC for review and action (pursuant to Public Utilities Code Section 2166.5). While not anticipated, any future heliport projects must comply with the state permit procedure provided by law and with conditions of approval imposed or recommended by the FAA, ALUC for Orange County, and by Caltrans/Division of Aeronautics. As such, this impact was determined to be less than significant
Impair Emergency Response Plan
The Certified EIR stated that construction of future development in the Overlay Zone could result in short-term temporary impacts on street traffic adjacent to the proposed sites during construction activities due to roadway improvements and potential extension of construction activities into the right-of-way. This could result in a reduction in the number of lanes or temporary closure of certain street segments. Any such impacts would be limited to the construction period and would affect only adjacent streets or intersection. However, Mitigation Measures MM-OZ 4.6-5 and MM-OZ 4.6-6 would be required to ensure that temporary street closures would not affect emergency access in the vicinity of future developments.
Operation of the various residential uses and businesses or facilities developed as part of the Overlay Zone could increase traffic on roads or modify existing transportation routes and could interfere with the response times of emergency vehicles, which would be potentially significant in the case of a hazardous material spill. Implementation of Mitigation Measure MM-OZ 4.6-7 would require the City to update their Emergency Preparedness Plan to address changes in the emergency response for accidental release of hazardous materials that may be used, stored, and/or transported at any new facility. Furthermore, the haulers and users of hazardous materials would be required to register with the Santa Ana Fire Department and would be regulated and monitored under the auspices of City.
With implementation of Mitigation Measures MM-OZ 4.6-5 through MM-OZ 4.6-7, the Overlay Zone would not interfere with any emergency response or emergency evacuation plans, and this impact was determined to be less than significant.
Wildland Fires
The Certified EIR stated that the Overlay Zone is located in a dense urban environment and is surrounded by existing development. There are no wildland areas, nor wildland interface areas, located in the project vicinity. Consequently, no wildland fires would affect, or be affected by, implementation of the Overlay Zone. Therefore, no impacts would occur.
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Mitigation Measures
MM-OZ 4.6-1 For future residential uses that are developed under the Overlay Zone within 500 feet of an existing freeway, a health risk assessment (HRA) for diesel exhaust shall be prepared. Recommendations contained within the HRA shall be implemented in project design.
MM-OZ 4.6-2 Prior to the issuance of grading permits on any project site, the site • Investigate the project site to determine whether it or immediately adjacent areas have a record of hazardous material contamination via the preparation of a preliminary environmental site assessment (ESA), which shall be submitted to the City for review. If contamination is found the report shall characterize the site according to the nature and extent of contamination that is present before development activities precede at that site.
•
•
If contamination is determined to be on site, the City, in accordance with appropriate regulatory agencies, shall determine the need for further investigation and/or remediation of the soils conditions on the contaminated site. If further investigation or remediation is required, it shall be the responsibility of the site developer(s) to complete such investigation and/or remediation prior to construction of the project.
If remediation is required as identified by the local oversight agency, it shall be accomplished in a manner that reduces risk to below applicable standards and shall be completed prior to issuance of any occupancy permits.
MM-OZ 4.6-3 In the event that previously unknown or unidentified soil and/or groundwater contamination that could present a threat to human health or the environment is encountered during construction of the proposed project, construction activities in the immediate vicinity of the contamination shall cease immediately. If contamination is encountered, a Risk Management Plan shall be prepared and implemented that (1) identifies the contaminants of concern and the potential risk each contaminant would pose to human health and the environment during construction and post-development and (2) describes measures to be taken to protect workers, and the public from exposure to potential site hazards. Such measures could include a range of options, including, but not limited to, physical site controls during construction, remediation, long-term monitoring, post-development maintenance or access limitations, or some combination thereof. Depending on the nature of contamination, if any, appropriate agencies shall be notified (e.g., City of Santa Ana Fire Department). If needed, a Site Health and Safety Plan that meets Occupational Safety and Health Administration requirements shall be prepared and in place prior to commencement of work in any contaminated area.
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MM-OZ 4.6-4
MM-OZ 4.6-5
For development of structures that exceed 200 feet in height above ground level at a development site, Applicants shall file a Notice of Proposed Construction or Alteration with the FAA (FAA Form 7460-1). Following the FAA’s nautical evaluation of the project, projects must comply with conditions of approval imposed or recommended by the FAA. Subsequent to the FAA Prior to initiation of construction activities, any development within the Overlay Zone shall have a completed traffic control plan, prepared by the developer, that will be implemented during construction activities. This may include, but is not limited to, the maintenance of at least one unobstructed lane in both directions on surrounding roadways. At any time only a single lane is available, the developer shall provide a temporary traffic signal, signal carriers (i.e., flag persons), or other appropriate traffic controls to allow travel in both directions.
If construction activities require the complete closure of a roadway segment, the developer shall provide appropriate signage indicating alternative routes.
MM-OZ 4.6-6
MM-OZ 4.6-7
The City Planning Department shall consult with the Santa Ana Police Department and the Santa Ana Fire Department to disclose temporary closures and alternative travel routes in order to ensure adequate access for emergency vehicles when construction of future projects would result in temporary land or roadway closures.
The Santa Ana Fire Department, in consultation with other applicable City Departments (e.g., Police), shall update their Emergency Preparedness Plan prior to occupancy of the first project developed under the Overlay Zone, to address potential for accidental release of hazardous materials that may be used, stored, and/or transported in association with operation of project implementation.
4.9.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project does not include any development that would extend beyond the building envelope considered in the Certified EIR, and no changes are proposed to the Overlay Zone to accommodate the Project. As discussed below, the Project would incorporate mitigation measures to minimize impacts related to hazards and hazardous materials would be less than significant, and accordingly, would not result in any new or increased significant impacts beyond those already identified in the Certified EIR.
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Routine Transport, Use, or Disposal of Hazardous Materials/Release of Hazardous Materials/ Handling Near Schools/ Listed Hazardous Materials Site The Project would not introduce any unusual hazardous materials to the area and would be required to adhere to existing regulations to ensure compliance with safety standards related to the use and storage of hazardous materials, and the safety procedures mandated by applicable federal, state, and local laws and regulations (RCRA, California Hazardous Waste Control Law, and principles prescribed by the California Department of Health Services, Centers for Disease Control and Prevention, and National Institutes of Health), including those that minimize the risks associated with the exposure of sensitive receptors, including schools. The nearest school to the Project Site is more than one-quarter mile away and the Project Site has not been identified on any of the various regulatory databases as being contaminated from the release of hazardous substances in the soil, including d storage tanks and small-quantity generators of hazardous waste. Further, in compliance with Mitigation Measure MM-OZ 4.6-2, a Phase I Environmental Site Assessment (ESA) has been prepared for the Project by Weis Environmental, dated January 16, 2022 (refer to Attachment E). The Phase I ESA concluded that no evidence of recognized environmental conditions, controlled recognized environmental conditions, or historical recognized environmental conditions in connection with the Project Site. In any event, the Project will still implement Mitigation Measure MM-OZ 4.6-3, which requires certain actions in the event an unanticipated contamination is discovered. Thus, the Project would not result in any new or increased significant impacts related to the routine transport, use, and disposal of hazardous materials, the accidental release of hazardous materials, or handling of hazardous materials near schools beyond impacts already identified in the Certified EIR.
As previously discussed, the Project is greater than 500 feet away from the nearest freeway.
Therefore, Mitigation Measure MM-OZ 4.6-1, requiring preparation of a HRA for projects within 500 feet of the nearest freeway, does not apply.
Airport Hazards
The Project Site is not located within the JWA Airport Influence Area, and the Project would not include buildings that reach a height of 200 feet or taller.14 Thus, implementation of Mitigation Measure MM-OZ 4.6-4 is not required. Thus, the Project would not result in any new or increased significant impacts related to hazardous materials site list beyond impacts already identified in the Certified EIR.
Impair Emergency Response Plan
The Project would be required to implement Mitigation Measures MM-OZ 4.6-5 through MM-OZ
4.6-7 to ensure that the Project would not interfere with any emergency response or emergency evacuation plans. Thus, the Project would not result in any new or increased significant impacts related to emergency response beyond impacts already identified in the Certified EIR. 14 Orange County Airport Land Use Commission, Airport Influence Area for John Wayne Airport, available at https://files.ocair.com/media/2021-
02/jwanotf2008.pdf?VersionId=7s4A26J9sMzn02SK2kO3c9kcnvAT8f9s.
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Wildland Fires
The Project Site is located in a dense urban environment and is surrounded by existing development. Further the Project Site is not located within a designated Very High Fire Hazard Severity Zone or State Responsibility Area where wildfire risk is most acute. There are no wildland areas, nor wildland interface areas, located in the vicinity of the Project Site. Thus, the Project would not result in any new or increased significant impacts related to wildland fires beyond impacts already identified in the Certified EIR.
Mitigation Measures
The Project would implement Mitigation Measures MM-OZ 4.6-5, MM-OZ 4.6-6, and MM-OZ 4.6- 7 from the Certified EIR.
4.9.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to hazards and hazardous materials have occurred within the vicinity of the Project Site since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
4.9.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance that has become available relative to hazards and hazardous materials that would result in new or more severe significant environmental impacts.
4.9.5 Mitigation Measures Addressing Impacts
The Project would implement Mitigation Measures MM-OZ 4.6-1, MM-OZ 4.6-2, MM-OZ 4.6-3, MM-OZ 4.6-5, MM-OZ 4.6-6, and MM-OZ 4.6-7 from the Certified EIR.
4.9.6 Conclusion
Based on the above, no new significant impacts or a substantial increase in previously identified impacts to hazards and hazardous materials would occur as a result of the Project. Therefore, the impacts to hazards and hazardous materials do not meet the standards for a subsequent or supplemental EIR pursuant to PRC Section 21166 and CEQA Guidelines Section 15162.
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4.10 Hydrology and Water Quality
Any Substantial Any Substantially
Changes
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Changed
Circumstances
Involving New
Significant Impact
or Substantially
More Severe
Any New
Information of
Substantial
Importance?
Project
Incorporates
Mitigation
Impact
Issues (and supporting Information
Sources)
Determination
in EIR Impacts? Measure(s)?
HYDROLOGY AND WATER QUALITY:
Would the project:
(a) Violate any water quality
standards or waste discharge
requirements or otherwise
substantially degrade surface
or groundwater quality?
Less Than
Significant With
Mitigation
No
No
No
No
No
No
Yes
No
(b) Substantially decrease
groundwater supplies or
interfere substantially with
groundwater recharge such
that the project may impede
sustainable groundwater
management of the basin?
Less Than
Significant
(c) Substantially alter the existing
drainage pattern of the site or
area, including through the
alteration of the course of a
stream or river or through the
addition of impervious
surfaces, in a manner which
would:
Less Than
Significant With
Mitigation
(i) Result in substantial erosion or
siltation on- or off-site?
No
No
No
No
No
No
Yes
No
(ii)Substantially increase the rate
or amount of surface runoff in a
manner which would result in
flooding on- or off-site?
Less Than
Significant With
Mitigation
(iii) Create or contribute runoff
water which would exceed the
capacity of existing or planned
stormwater drainage systems or
provide substantial additional
sources of polluted runoff?
Less Than
Significant With
Mitigation
No No No No
(iv) Impede or redirect flood
flows? No Impact
No Impact
No
No
No
No
No
No
No
No
(d) In flood hazard, tsunami, or
seiche zones, risk release of
pollutants due to project
inundation?
(e) Conflict with or obstruct
implementation of a water
quality control plan or Less Than
Significant No No No No
sustainable groundwater
management plan?
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4.10.1 Impact Determination in the EIR
Water Quality
The Certified EIR concluded that construction activities in the Overlay Zone could include road improvements and realignments, installation and realignment of utilities, demolition of existing structures for new development or replacement and new development. Areas that disturb one or more acres of land surface are subject to the Construction General Permit, 99-08-DWQ adopted by the State Water Resources Control Board (SWRCB). Preparation of a Stormwater Pollution Prevention Plan (SWPPP) is required for compliance with the National Pollutant Discharge Elimination System (NPDES) General Construction Stormwater Activity Permit. Compliance with the permit would involve filing a Notice of Intent with the SWRCB and preparing and submitting a SWPPP prior to construction activities. The SWPPP must describe the site, the facility, erosion and sediment controls, runoff water quality monitoring, means of waste disposal, implementation of approved local plans, control of construction sediment and erosion control measures, maintenance responsibilities, and non-stormwater management controls. Inspection of construction sites before and after storms is required to identify stormwater discharge from the construction activity and to identify and implement controls where necessary. The Construction General Permit requirements would need to be satisfied prior to beginning construction on any project located on a site greater than one acre.
Water quality degradation from construction would be specific to each site within the Overlay Zone and depend largely on the areas affected and the length of time soils are subject to erosion and construction activities on site. All development would be subject to regional and local regulations, including the City’s Water Pollution Ordinance, adopted to ensure compliance with federal requirements for the control of urban pollutants to stormwater runoff which enters the network of storm drains throughout the County of Orange. Contractors constructing new development or redevelopment projects are required to comply with the conditions of the City’s Local Implementation Plan (LIP) and the Orange County Drainage Area Master Plan (DAMP), including the implementation of appropriate best management practices (BMPs) to control stormwater runoff so as to prevent any deterioration of water quality.
In order to ensure compliance with existing regulations, implementation of Mitigation Measure MM-OZ 4.7-1 would be required for future development projects in the Overlay Zone. Compliance with Mitigation Measure MM-OZ 4.7-1 and applicable permit requirements for construction conditions will ensure that construction water quality effects for future development in the Overlay Zone will be reduced to the maximum extent practicable and will be considered less than significant.
Operation of future developments in the Overlay Zone could result in the addition of contaminants into the stormwater runoff entering the City’s drainage system. The major source of pollution to runoff and infiltrating groundwater would be contaminants that have accumulated on the land surface over which stormwater passes. Between rainstorms, material would be deposited on the streets, paved areas, roof tops, and other surfaces from debris dropped or scattered by Cabrillo Town Center City of Santa Ana
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individuals, wastes and dirt from construction and renovation or demolition, fecal droppings from animals, oil and various residues contributed by vehicular traffic, and fallout of air-borne particles.
Discretionary projects would require the preparation of a Water Quality Management Plan (WQMP). A WQMP would be specific to the expected pollutants that would be present in the stormwater flow from project sites after completion of construction. The WQMP would incorporate the requirements of DAMP Section 7, including all feasible recommended BMPs. It would include site design, source control, and treatment control BMPs to address the specific pollutants anticipated from the project and project site and would detail the specific operation and maintenance of each BMP. The WQMP would outline a routine maintenance schedule for each BMP, in compliance with the DAMP and local regulations.
In addition, as discussed previously, developments within the City would be subject to the provisions of the City’s Water Pollution Ordinance. Further, as is required for construction activities, operation of new development or redevelopment projects are required to comply with provisions set forth the City’s LIP and the DAMP, including the implementation of appropriate BMPs to control stormwater runoff so as to prevent any deterioration of water quality.
Compliance with Mitigation Measure MM-OZ 4.7-1, NPDES permits requirements, the DAMP, and the City’s LIP and Municipal Code would reduce the risk of water degradation within the Overlay Zone from the operation of new developments to the maximum extent practicable.
Therefore, since violation of waste discharge requirements or water quality standards would be minimized, this impact was determined to be less than significant.
Groundwater Recharge/Conflict with Groundwater Management Plan The Certified EIR stated that construction activities would primarily occur as part of infill/redevelopment, with the exception of the potential for development on the limited number of vacant sites in the Overlay Zone. According to the City’s General Plan, Santa Ana does not serve as the main spreading basin for groundwater recharge. Depending on the groundwater table at particular project sites within the Overlay Zone, pile driving, dewatering, and other construction activities that would encounter groundwater could potentially occur. While the insertion of support and foundation structures in the groundwater may reduce the storage capacity of groundwater, the displaced volume would not be substantial relative to the volume of the Basin. Likewise, while dewatering would remove groundwater, the volume of water removed would not likely be substantial relative to groundwater pumping for water supply. Also, water used during construction for cleaning, dust control, and other uses would be nominal. Thus, construction activities would not substantially deplete groundwater supplies nor interfere substantially with groundwater recharge. This impact was determined to be less than significant.
Future development under the Overlay Zone would lead to increases in water consumption, particularly because residential uses typically use more water than commercial and office uses (which characterize the area). However, because the majority of the Overlay Zone area is developed with existing uses, the potential future development would not substantially reduce areas of ground percolation and recharge because the existing uses would simply be replaced Cabrillo Town Center City of Santa Ana
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with new uses. The City does not serve as the main spreading basin for groundwater recharge.
Thus, any development on the limited undeveloped land within the Overlay Zone, groundwater recharge would not substantially affect groundwater recharge. Therefore, because the majority of the Overlay Zone is already developed and because the Overlay Zone area is not used for groundwater recharge, the operation of future development under the Overlay Zone would not interfere substantially with groundwater recharge. This impact was determined to be less than significant.
Erosion/Siltation
The Certified EIR stated that construction activities under the Overlay Zone would involve stockpiling, grading, excavation, paving, and other earth-disturbing activities, which could result in the alteration of existing drainage patterns. These types of activities would constitute a temporary alteration of drainage patterns. However, future development would be required to comply with the DAMP and the City’s corresponding LIP, which serves as the primary policy and implementation document for compliance with the NPDES Stormwater permits. Compliance with NPDES regulations and the City’s Municipal Code would reduce the risk of short-term erosion resulting from drainage alteration during construction to a less-than-significant impact.
The majority of the Overlay Zone is developed with office and commercial uses. The introduction of new uses throughout the Overlay Zone is not anticipated to result in substantial changes to the existing drainage patterns because existing drainage facilities would continue to be used and the amount of drainage would remain similar to present levels. However, it is possible that future development in the Overlay Zone could result in minor alterations to drainage, such as changes in ground surface permeability via paving, or changes in topography via grading and excavation.
The above discusses applicable regulations that would limit pollutant discharges from future development in the Overlay Zone. In addition, all development in the Overlay Zone would be subject to the provisions of the City’s LIP and Orange County DAMP. These regulations include the implementation of appropriate BMPs including a range of methods that could minimize offsite erosion, including but not limited to hydrodynamic devices, swales/biofilters, basins, and various filters.
In addition, as required by Mitigation Measure MM-OZ 4.7-1, future developments would be required to prepare a storm drain plan and WQMP. Implementation of these plans would reduce the volume of sediment-laden runoff discharging from sites within the Overlay Zone.
Consequently, because future projects in the Overlay Zone are not anticipated to substantially alter drainage patterns in comparison to existing conditions in the area, and because adherence to existing requirements would reduce erosion and siltation during operation, this impact was determined to be less than significant.
Onsite and Offsite Flooding/Contribution of Runoff
The Certified EIR stated that future development in the Overlay Zone would generally result in infill development or redevelopment. As such, most of the future projects would not result in new Cabrillo Town Center City of Santa Ana
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development that would substantially alter drainage patterns because these areas are already developed with existing uses and impervious surfaces. However, limited development of land that is currently vacant (i.e., agricultural parcels) and covered with permeable surfaces may occur. Although minimal, increased impervious surfaces would increase stormwater runoff in the Overlay Zone. In addition, it is unknown whether the existing drainage system throughout the Overlay Zone is adequate. Therefore, in order to provide a conservative assessment, it is possible that this increased runoff could exceed the capacity of existing and planned infrastructure and cause downstream flooding impacts.
The Certified EIR stated that adherence to Mitigation Measure MM-OZ 4.7-1 would require the preparation of a WQMP and implementation of appropriate BMPs, which could incorporate stormwater detention facilities, and would reduce the volume of runoff generated (and potential for flooding) in the Overlay Zone. However, because the existing capacity of the existing storm drain system in the Overlay Zone is unknown, it was determined that this impact could be potentially significant. Implementation of Mitigation Measure MM-OZ 4.7-2 is required to address these issues.
Impede/Redirect Flood Flows
The Certified EIR stated the Overlay Zone is not within the 100-year flood hazard area and is outside the 0.2 percent annual chance floodplain. As there would be no risk of flooding in the Overlay Zone, there would be no impact to the placement of structures which would impede or redirect flood flows, and no impacts will occur.
Tsunami/Seiche Water Quality Hazards
The Certified EIR stated Overlay Zone is located approximately 9 miles from the Pacific Ocean and 130 feet above sea level, which is a sufficient distance so as not to be subject to tsunami impacts. No impact associated with tsunamis is anticipated to occur. The closest enclosed bodies of water that could result in earthquake-induced seiches are the Prado Dam, which is located near the City of Corona to the northwest of the Cleveland National Forest, or the Santiago Dam, which is located approximately 12 miles east of the area in Silverado. The project site is not located within a flood hazard (inundation) area associated with either dam. Therefore, overflow as the result of a seiche would not expose people or structures to a significant risk of loss, injury, or death involving inundation by seiche within the Overlay Zone. The City is located on nearly flat surfaces and there are no areas with slopes significant enough to cause mudflows near the Overlay Zone which would expose people or structures to a significant risk of loss, injury, or death.
Therefore, no impact associated with mudflows is anticipated to occur. In summary, it was determined that there will be no impact to the exposure of people or structures at the Overlay Zone to a significant risk of loss, injury, or death involving inundation by a seiche, tsunami, or mudflow.
Mitigation Measures
MM-OZ 4.7-1 In order to comply with the 2003 DAMP, future development projects in the Cabrillo Town Center City of Santa Ana
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Overlay Zone shall prepare Storm Drain Plans, Stormwater Pollution Prevention Plans (SWPPP), and Water Quality Management Plans (WQMP) conforming to the current National Pollution System (NPDES) requirements, prepared by a Licensed Civil Engineer or Environmental Engineer, shall be submitted to the Department of Public Works for review and approval. • A SWPPP shall be prepared and updated as needed during the course of construction to satisfy the requirements of each phase of the development. The plan shall incorporate all necessary Best Management Practices (BMPs) and other City requirements to eliminate polluted runoff until all construction work for the project is completed. The SWPPP shall include treatment and disposal of all dewatering operation flows, and for nuisance flows during construction.
A WQMP shall be prepared, maintained, and updated as needed to satisfy the requirements of the adopted NPDES program. The plan shall incorporate water quality measures for all improved phases of the project.
•
• Location of the BMPs shall not be within the public right-of-way.
MM-OZ 4.7-2 Prior to issuance of grading permits, future development projects in the Overlay Zone shall submit a Hydrology and Hydraulic Study to the Public Works Department for review and approval. If existing facilities are not adequate to handle runoff that may be generated by the proposed development, then the applicant shall propose feasible remedies to assure that adequate be available prior to issuance of occupancy permits. The applicant may propose storm drain improvements to be constructed in order to meet project needs. If necessary, storm drain upgrades cannot be implemented prior to issuance of occupancy permits, on site detention facilities or other methods acceptable to the City shall be included with new development projects to ensure that post-construction runoff does not exceed pre-development quantities.
4.10.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project does not include any development that would extend beyond the building envelope considered in the Certified EIR, and no changes are proposed to the Overlay Zone to accommodate the Project. As discussed below, the Project would incorporate mitigation measures to minimize impacts related to hydrology and water quality Cabrillo Town Center City of Santa Ana
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would be less than significant, and accordingly, would not result in any new or increased significant impacts beyond those already identified in the Certified EIR.
Water Quality
The Project would implement Mitigation Measure MM-OZ 4.7-1, which requires preparation and implementation of a SWPP that would incorporate BMPs and other City requirements to eliminate polluted runoff until all construction work for the Project is complete. Additional Mitigation Measure MM-OZ 4.7-1 requires the preparation and maintenance of a WQMP in compliance with the adopted NPDES program. The WQMP would incorporate water quality measures for all phases of the Project. Further, the Project would be subject to the provisions of the City’s Water Pollution Ordinance and provisions set forth the City’s LIP and the DAMP. Thus, the Project would not result in any new or increased significant impacts related to water quality beyond impacts already identified in the Certified EIR.
Groundwater Recharge/ Conflict with Groundwater Management Plan The Project Site is currently developed with impervious surfaces and is not a source of groundwater recharge. The Project would not change this. Thus, the Project would not result in any new or increased significant impacts related to water quality beyond impacts already identified in the Certified EIR.
Erosion/Siltation
The Project would be required to implement Mitigation Measure MM-OZ 4.7-1, which requires preparation of a WQMP in compliance with NPDES regulations, the DAMP, and the City’s Municipal Code and would reduce the risk of erosion. These regulations include the implementation of appropriate BMPs including a range of methods that could minimize off-site erosion, including but not limited to hydrodynamic devices, swales/biofilters, basins, and various filters. Thus, the Project would not result in any new or increased significant impacts related to erosion and siltation beyond impacts already identified in the Certified EIR.
Onsite and Offsite Flooding/ Contribution of Runoff
As previously discussed, the Project would incorporate Mitigation Measure MM-OZ 4.7-1, which requires the preparation of a WQMP and implementation of appropriate BMPs, which could incorporate stormwater detention facilities and would reduce the volume of runoff generated (and potential for flooding). However, to conservatively confirm no potential impacts, the Project would also incorporate Mitigation Measure MM-OZ 4.7-2, which requires preparation of a Hydrology and Hydraulic Study to ensure the existing storm drain capacity could accommodate the Project and that the Project would not result in on- or off-site flooding. Thus, the Project would not result in any new or increased significant impacts related to on- or off-site flooding beyond impacts already identified in the Certified EIR.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
153 City Council 18 – 587 10/3/2023
Impede/Redirect Flood Flows
The Project Site is still not located in a flood hazard area and would not impede or redirect flood flows. Thus, the Project would not result in any new or increased significant impacts related to impeding or redirecting flood flows beyond impacts already identified in the Certified EIR.
Tsunami/Seiche Water Quality Hazards
The Project Site is still not located in an area that is subject to tsunami/seiche/mudflow hazards.
Thus, the Project would not result in any new or increased significant impacts related to water quality hazards beyond impacts already identified in the Certified EIR.
4.10.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to hydrology and water quality have occurred within the vicinity of the Project Site since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
4.10.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance which has become available relative to hydrology and water quality that would result in new or more severe significant environmental impacts.
4.10.5 Mitigation Measures Addressing Impacts
The Project would implement Mitigation Measures MM-OZ 4.7-1 and MM-OZ 4.7-2 from the Certified EIR.
4.10.6 Conclusion
Based on the above, no new significant hydrologic/water quality impacts or a substantial increase in previously identified hydrologic/water quality impacts would occur as a result of the Project.
Therefore, the impacts on hydrology and water quality do not meet the standards for a subsequent or supplemental EIR pursuant to Public Resources Code Section 21166 or CEQA Guidelines Section 15162.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
154 City Council 18 – 588 10/3/2023
4.11 Land Use and Planning
Any Substantially
Changed
Any Substantial
Changes Involving
New Significant
Impacts or
Circumstances
Involving New
Significant Impact
or Substantially
More Severe
Any New
Information of Incorporates
Substantial Mitigation
Importance? Measure(s)?
Project
Impact
Issues (and supporting Information Determination Substantially More Sources) in EIR Severe Impacts? Impacts?
LAND USE AND PLANNING: Would the
project:
(a) Physically divide an established
community?
Less Than
Significant No
No
No
No
No
No
No
No
(b) Cause a significant environmental
impact due to a conflict with any
land use plan, policy or Less Than
regulation adopted for the Significant
purpose of avoiding or mitigating
an environmental effect?
4.11.1 Impact Determination in the EIR
Land Use Conflicts
The Certified EIR stated that the Overlay Zone would allow for introduction of residential, commercial, and entertainment uses in a largely office-oriented district. The transition of the area from a predominantly office-oriented area to a mixed-use center would occur over time as individual properties are developed under the Overlay Zone standards and guidelines.
Land use incompatibility can occur where differences exist among uses that are near each other.
These incompatibilities may result from differences in the physical scale of development, noise levels, traffic levels, hours of operation, and other factors. The potential for conflicts exists in particular where mixed-use development occurs. The Overlay Zone adds new mixed-use designations to an area that is designated primarily as Professional and Commercial uses. Mixeduse development would be permissible within the Neighborhood Transitional, Village Center, and Active Urban districts, such that residential uses could be placed in proximity to commercial, office, and entertainment uses, including those in a highly urbanized environment.
Development standards contained in the Overlay Zone provide guidance that would minimize conflicts among uses in mixed-use facilities. Principles to minimize conflicts include:
1.2 Objectives
• Achieve the harmonious integration of new mixed-use development within the existing fabric of the mid-rise and high-rise environment
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
155 City Council 18 – 589 10/3/2023
4.2 Development Intensity (FAR)
• The overall scale and massing of development within the Overlay Zone should transition from 2 story scale of the Neighborhood Transitional district to mid-rise development in the Village Center district and high-rises in the Active Urban district adjacent to the Santa Ana Freeway.
Neighborhood Transitional
o New development in the Neighborhood Transitional district shall be of a low scale and should serve as a visual transition between the Village Center and adjacent residential areas to the north.
o New develop shall be compatible in height, scale, and mass with adjacent residential development to the north, with heights ranging between two and three stories.
Village Center
o New development in the Village Center district is more intensive in scale than the Neighborhood Transitional district and shall serve as a visual transition from the low-intensity development of the Neighborhood Transitional district to the highintensive development in the Active Urban district.
Active Urban
o New development shall relate in similarity of scale, height, and configuration with adjacent buildings.
o New development shall be designed and oriented to promote intensive public activity at the ground level that integrates and establishes a cohesive transition with adjacent districts.
Project-specific features would depend on the types of uses proposed and the specific design of individual projects. Examples of design elements to reduce conflicts include screening of mechanical equipment, and locating these uses away from residential components; specific locations and hours of operation for service deliveries; and separate vehicular entrances for residential and commercial uses. Implementation of Development Standards therefore ensure that design of mixed use development does not result in significant land use incompatibilities.
In many locations, the addition of uses similar to existing uses would occur. For instance, in the Office District, uses would continue as currently permitted, and additional offices could be built in the Neighborhood Transitional district. Where additional development that is the same as or similar to existing development could occur, these uses would be compatible.
Neighborhood Transitional: Existing land uses in the Neighborhood Transitional district consist of one- and two-story office buildings. Land uses that would be permitted within this district under Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
156 City Council 18 – 590 10/3/2023
the Overlay Zone would be limited to residential, live/work, or office uses, limited to three stories in height.
The Neighborhood Transitional district would remain as a low-intensity neighborhood as it is intended in the General Plan, and act as a transition between the single-family residential to the north and adjacent Village Center district and high-intensity Active Urban district to the south. The Neighborhood Transitional district development will be designed to provide an appropriate interface with the adjacent single-family residential area to the north by incorporating high levels of landscaping and design features.
Village Center: Existing land uses in the Village Center district consist of office buildings one to four stories in height, and minor retail, auto-related retail, and motel uses. Land uses that would be permitted within this District under the Overlay Zone include commercial, office, and residential uses. The area would remain as a mid-rise building environment with heights between four and six stories. The Village Center is intended to serve as the focal point and central gathering place within the Overlay Zone, with an emphasis on creating a vibrant, attractive, and highlyinterconnected pedestrian environment. The Village Center will provide open spaces, niches, and areas for gatherings and activities along streets, paseos, and interconnecting walkways that link the Village Center to adjacent districts and nearby public parks north of the district.
Active Urban: Existing development in the Active Urban district includes primarily office, with minor retail/commercial, auto-related retail, and a motel and care/rehab facility. Land uses that would be permitted within this district under the Overlay Zone include commercial, office, residential, and entertainment uses (all uses that would occur in Village Center, plus entertainment uses). Pursuant to the General Plan, the Active Urban district is intended as the location for well-designed high-rise mixed-use developments in a highly urbanized environment.
Developments will be designed to showcase an amenity-enhanced environment that provides numerous open space opportunities for the enjoyment of residents, employees, and visitors, and to promote pedestrian connections between this District and the Village Center as well as Cabrillo Park located north of the Overlay Zone.
The Office District: Existing development in the Office District consists almost entirely of office uses, with minor retail/commercial, and a care/rehab facility. Land uses and intensity standards that would be permitted within this district under the Overlay Zone would continue pursuant to the existing Zoning Code.
Provided that the above objectives and development standards are implemented into the design of individual projects, land use impacts to the Office District and adjacent communities would be less than significant. The land use character of the area would change from a largely officeoriented district to a mixed-use area with development divided into a series of districts and scaled in a variety of intensities. Because the Overlay Zone would not adversely affect existing land uses, impacts to established communities within and adjacent to the Overlay Zone were determined to be less than significant.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
157 City Council 18 – 591 10/3/2023
Physically Divide an Established Community
The Certified EIR stated the Overlay Zone does not include any features that would be considered divisive. Rather, the Development Standards of the Overlay Zone are intended to allow cohesive development. The required public realm improvements would enhance and unify the existing with the new development and create linkages to adjacent communities through pedestrian amenities and an integrated and interconnected open space and landscaping network. Existing uses would continue to be permitted within the Overlay Zone and be subject to the regulations and development standards of the underlying zoning districts, with the exception that certain standards contained in the Overlay Zone as to public realm improvements would be required.
Because the Overlay Zone would encourage connectivity, impacts to established communities within and adjacent to the Overlay Zone would be less than significant.
Plan Consistency
The Certified EIR stated that the City’s General Plan Land Use Element designates the entire Overlay Zone within the Professional and Administrative (PAO) land use category. The General Plan identifies the following uses as types of uses typically located in the PAO district:
•
•
Professional and administrative offices/office parks;
Service activities such as copy centers, courier services, travel agencies, and restaurants when such uses are an integral component of a planned office development; and Professional uses such as accountants, attorneys, doctors, engineers, and insurance brokers.
•
The Land Use Element also prescribes a floor area ratio (FAR) intensity standard from 0.5 to 1.0 FAR for the PAO land use category.
Adoption of the Overlay Zone would conflict with the adopted General Plan by permitting additional uses including commercial, residential, and entertainment uses. The Santa Ana General Plan will be amended as part of the approval process of the Overlay Zone to include the Overlay Zone. Therefore, impacts of the Overlay Zone would be less than significant.
Development within the Overlay Zone would consist of development ranging in intensity from AR, exceeding the General Plan recommended FAR threshold of 1.0; however, the proposed intensity standards by district generally reflect the intent of the General Plan. The General Plan prescribes an FAR of 0.5 for those areas adjacent to low-density residential neighborhoods. The Neighborhood Transitional District in the Overlay Zone contains an intensity standard ranging from 0.5 to 0.75. The General Plan also designates the area south of Fourth Street as a “major development area” with high-intensity and high-quality regional office projects. The Active Urban District and the Office District of the Overlay Zone are located within this area. The existing highrise Xerox Center (SD 54) within the proposed Office District is an example of development appropriate for the “major development area”. It has an FAR of over 3. While the FAR allowance in the Overlay Zone exceeds the range prescribed in the General Plan, the Santa Ana General Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
158 City Council 18 – 592 10/3/2023
Plan will be amended as part of approval of the Overlay Zone to reflect the Overlay Zone intensity standards. Therefore, impacts of the Overlay Zone would be less than significant.
Under the City’s existing zoning, there are six land use zones within the Overlay Zone. The provisions of the Overlay Zone would apply to all properties within the Overlay Zone but would not supersede the underlying zoning districts. All regulations, development standards, and requirements in the underlying zoning districts would continue to apply to those properties that are developed according to the existing standards, with the exception that certain standards contained in the Overlay Zone as to public realm improvements would be required. Properties within the Overlay Zone may choose to develop to the standards contained within the Overlay Zone as an alternative to developing to the standards of the underlying zoning districts. Therefore, adoption of the Overlay Zone would be complementary to, and compatible with the existing Zoning Code.
Mitigation Measures
None identified or required.
4.11.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project is consistent with the permitted uses, density and intensity, building envelope and development standards contained in the Overlay Zone and evaluated in the Certified EIR. The Project will pay in-lieu fees required by the City’s 2021 Affordable Housing Opportunity and Creation Ordinance. Thus, no changes are proposed to the Overlay Zone to accommodate the Project that were not considered in the Certified. EIR. . Thus, the Project would not result in any new or increased significant land use impacts beyond those already identified in the Certified EIR.
4.11.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to land use and planning have occurred within the vicinity of the Project Site since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
159 City Council 18 – 593 10/3/2023
4.11.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance which has become available relative to land use that would result in new or more severe significant environmental impacts.
4.11.5 Mitigation Measures Addressing Impacts
None required.
4.11.6 Conclusion
Based on the above, no new significant land use impacts or a substantial increase in previously identified land use impacts would occur as a result of the Project. Therefore, the impacts to land use do not meet the standards for a subsequent or supplemental EIR pursuant to CEQA Guidelines Section 15162.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
160 City Council 18 – 594 10/3/2023
4.12 Mineral Resources
Any Substantial Any Substantially
Changes
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Changed
Circumstances
Involving New
Significant Impact
or Substantially
More Severe
Any New
Information of Incorporates
Substantial
Importance?
Project
Impact
Issues (and supporting Information Determination Mitigation Sources) in EIR Impacts? Measure(s)?
MINERAL RESOURCES: Would the
project:
(a) Result in the loss of
availability of a known
mineral resource that would
be of value to the region
and the residents of the
state?
No Impact
No Impact
No
No
No
No
No
No
No
No
(b) Result in the loss of
availability of a locallyimportant mineral resource
recovery site delineated on
local general plan, specific
plan or other land use plan?
4.12.1 Impact Determination in the EIR
The Certified EIR stated that the Overlay Zone would not result in any impacts related to mineral resources.
Mitigation Measures
None required.
4.12.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project does not include any development that would extend beyond the building envelope considered in the Certified EIR, and no changes are proposed to the Overlay Zone to accommodate the Project. Thus, the Project would not result in any new or increased significant impacts related to mineral resources beyond those already identified in the Certified EIR.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
161 City Council 18 – 595 10/3/2023
4.12.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to mineral resources have occurred within the vicinity of the Project Site since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
4.12.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance which has become available relative to mineral resources that would result in new or more severe significant environmental impacts.
4.12.5 Mitigation Measures Addressing Impacts
Because the EIR determined the Project would have no impact on mineral resources, no mitigation measures were required. Implementation of the Project does not change these impact determinations. Therefore, no additional mitigation measures are required.
4.12.6 Conclusion
Based on the above, no new significant mineral resources or a substantial increase in previously identified mineral resources would occur as a result of the Project. Therefore, the impacts to mineral resources do not meet the standards for a subsequent or supplemental EIR pursuant to CEQA Guidelines Section 15162.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
162 City Council 18 – 596 10/3/2023
4.13 Noise
Any Substantial Any Substantially
Changes
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Changed
Circumstances
Involving New
Significant Impact
or Substantially
More Severe
Any New
Information of Incorporates
Substantial Mitigation
Importance? Measure(s)?
Project
Impact
Issues (and supporting Information Determination
Sources) in EIR Impacts?
NOISE: Would the project result in:
(a) Generation of a substantial
temporary or permanent
increase in ambient noise
levels in the vicinity of the
project in excess of Significant and
Unavoidable No
No
No
No
No
No
Yes
Yes
standards established in the
local general plan or noise
ordinance, or applicable
standards of other
agencies?
(b) Generation of excessive
groundborne vibration or
groundborne noise levels?
Significant and
Unavoidable
(c) For a project located within
the vicinity of a private
airstrip or an airport land
use plan or, where such a
plan has not been adopted,
within two miles of a public
airport or public use airport,
would the project expose
people residing or working
in the project area to
No Impact No No No No
excessive noise levels?
4.13.1 Impact Determination in the EIR
Substantial Temporary or Permanent Increase In Noise
The Certified EIR stated that the Overlay Zone has the potential to result in events that may exceed permitted noise levels. The primary sources of noise associated with the Overlay Zone would be construction activities and project-related traffic volumes. Secondary sources include increased human activity throughout the sites. Noise limits for sensitive uses established in Section 18-311 and 18-312 of the Santa Ana Municipal Code.
Development of projects under the Overlay Zone would require the use of heavy equipment for demolition, site excavation, installation of utilities, site grading, paving, and building fabrication.
Construction activities would also involve the use of smaller power tools, generators, and other sources of noise. During each stage of construction there would be a different mix of equipment operating, and noise levels would vary based on the amount of equipment in operation and the location of the activity.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
163 City Council 18 – 597 10/3/2023
Noise that would be experienced by sensitive uses due to development associated with implementation of the Overlay Zone is determined at their property lines. While the nearest sensitive uses vary at different locations in and around the Overlay Zone and as specific development plans have not yet been determined at individual sites, for the purpose of this analysis it is assumed that sensitive receptors could be as close as 50 feet from where construction would take place. Sensitive receptors in the project vicinity could experience noise levels up to 86 dBA L as a result of construction activities, or as high as 107 dBA Leq in the event that pile drivers are used. Section 18-314(e) of the Municipal Code allows for noise resulting from construction activities to be exempt from noise limits established in the Code. In accordance with the Noise Ordinance, construction activities would also be limited to the hours of 7:00 A.M. and 8:00 P.M. on Monday through Saturday, and is prohibited on Sundays and federal holidays. As construction would not occur except during the times permitted in the Noise Ordinance, and as the Municipal Code, Section 18-314(e) of the Municipal Code allows construction noise in excess of standards to occur between these hours, the Overlay Zone would not violate established standards.
Development within the Overlay Zone would be required to implement Mitigation Measures MMOZ 4.9-1 through MM-OZ 4.9-4. Implementation of these mitigation measures would ensure that impacts associated with construction-related noise would be less than significant.
Operation of the Overlay Zone could expose noise-sensitive land uses to noise levels that exceed the standards established by the City of Santa Ana General Plan. This is considered a potentially significant impact. Implementation of Mitigation Measures MM-OZ 4.9-5 through MM-OZ 4.9-7 would reduce this impact to a less-than-significant level.
Sources of noise generated by implementation of the Overlay Zone would include new stationary sources (such as rooftop heating, ventilation, and air conditioning [HVAC] systems for the residential and office uses). The Overlay Zone would also introduce new activity and noise to the area as residences are included and people are attracted to the new mix of uses that would develop as part of the Overlay Zone. Noise monitoring on the project site indicates that existing noise levels on site exceed the 65 dBA “desirable maximum” noise standard for high density residential uses. Development of new residences in areas where existing noise levels are over 65 dBA would constitute a significant impact. As the noise levels monitored on-site exceed the 65 dBA thresholds, the project site would not meet acceptable noise levels for a residential use. It should be noted that some monitoring locations such as First Street between Cabrillo Park Drive and Golden Circle Drive are primarily commercial corridors hat typically do not qualify as sensitive receptors. Further, impacts related to substantial permanent increases in ambient noise levels that could potentially result with implementation of the Overlay Zone are discussed below.
The City of Santa Ana General Plan states that all residential uses should be protected with sound insulation over and above that provided by normal building construction when constructed in areas exposed to greater than 60 dBA CNEL. As such, Mitigation Measures MM-OZ 4.9-5 and MM-OZ 4.9-6 shall be implemented for all residential development within the Overlay Zone Area Cabrillo Town Center City of Santa Ana
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164 City Council 18 – 598 10/3/2023
where the existing noise levels exceed the 60 dBA CNEL standard established in the General Plan.
Mitigation Measure MM-OZ 4.9-5 would ensure that exterior living spaces, such as porches and patios are constructed in a manner that noise levels do not exceed the 65 dBA CNEL. Further implementation of Mitigation Measure MM-OZ 4.9-6 would ensure that interior living spaces of the residential units do not exceed 45 dBA CNEL. Therefore, this impact would be reduced to a level of less than significant.
Heating, ventilation, and air conditioning (HVAC) systems that would be installed for the new residential building associated with the Overlay Zone can result in noise levels that average between 50 and 65 dBA Leq at 50 feet from the equipment. As 24-hour CNEL noise levels are about 6.7 dBA greater than 24-hour Leq measurements, this means that the HVAC equipment associated with the retail-commercial buildings could generate community noise levels that average between 57 to 72 dBA CNEL at 50 feet when the equipment is operating constantly over 24 hours. These HVAC units would be mounted on the rooftops of the proposed buildings and would be screened from view by building features. However, the installation of shielding around these HVAC systems would be required as part of the Overlay Zone, as stated in Mitigation Measure MM-OZ 4.9-7 below.
The shielding installed around these systems would typically reduce noise levels by approximately 15 dBA, which could reduce HVAC system noise to approximately 50 dBA Leq at 50 feet from the equipment, which would be approximately 56.7 dBA CNEL. Implementation of Mitigation Measure MM-OZ 4.9-1 would ensure that impacts related to the HVAC systems would remain below the 65 dBA CNEL “Desirable Maximum” exterior noise level guideline established in the City’s General Plan for high density residential uses. As such impacts to residents of the Overlay Zone relating to HVAC systems were determined to be less than significant.
Operation of the Overlay Zone would not include special events or temporary activities which would cause an increase in ambient noise levels. In addition, operation of the Overlay Zone would not require periodic use of special stationary equipment that would expose off-site sensitive receptors to an increase in ambient noise levels above those existing without the Overlay Zone.
Therefore, there would be no temporary or periodic noise impacts to on- or off-site receptors due to operation of the Overlay Zone. This impact was determined to be less than significant.
Groundborne Vibration
The Certified EIR stated that construction-related vibration has two potential impacts. First, vibration at high enough levels can result in human annoyance. Second, groundborne vibration can potentially damage the foundations and exteriors of historic structures. Groundborne vibration that can cause this kind of damage is typically limited to impact equipment, especially pile drivers.
Construction activities that would occur under the Overlay Zone have the potential to generate low levels of groundborne vibration. Vibration that would be experienced from the use of construction equipment ranges from a small bulldozer, which reaches as high as 58 vibration decibels (VdB) at a distance of 25 fee, and an impact pile-drivers, which reaches as high as 112 Cabrillo Town Center City of Santa Ana
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VdB at a distance of 25 feet. Like noise, groundborne vibration will attenuate at a rate of approximately 6 VdB per doubling of distance. The groundborne vibration generated during construction activities would primarily impact existing sensitive uses (e.g., residences, schools, and hospitals) that are located adjacent to, or within, the vicinity of specific projects. These sensitive uses could sometimes be located as close as 25 feet to the construction site or as far as several hundred feet away. Vibration levels could reach up to 87 VdB at sensitive uses located within 25 feet of construction. For sensitive uses that are located at or within 25 feet of potential project construction sites, sensitive receptors (e.g., residents, school children, and hospital patients) at these locations may experience vibration levels during construction activities that exceed the Federal Transportation Administration’s (FTA) vibration impact threshold of 85 VdB for human annoyance. So long as construction occurs more than 50 feet from sensitive receptors, the impact associated with groundborne vibration generated by the equipment would be below 85 VdB and thus would be less than significant. However, as specific site plans or constructions schedules are unknown at this time, it may be possible that construction activities could occur as close as 25 feet from sensitive receptors. This would result in these sensitive receptors experiencing vibration impacts above the threshold of 85 VdB, in which case this impact would be potentially significant. Implementation of Mitigation Measures MM-OZ 4.9-1 through MM-OZ
4.9-4 would help to reduce this impact, but not to a less-than-significant level. Therefore, it was determined that this impact would remain significant and unavoidable.
During operation of the Overlay Zone, background operational vibration levels would be expected to average around 50 VdB, as discussed previously in this section. This is substantially less than the 85 VdB threshold for people in the vicinity of the project site. Groundborne vibration resulting from operation of the Overlay Zone would primarily be generated by trucks making periodic deliveries to the Overlay Zone. However, these types of deliveries would be consistent with deliveries that are made along roadways to commercial uses in the Overlay Zone and in the Overlay Zone vicinity and would not increase groundborne vibration above existing levels.
Because no substantial sources of groundborne vibration would be built as part of the Overlay Zone, no vibration impacts would occur during operation of the Overlay Zone. Therefore, operation of the Overlay Zone would not expose sensitive receptors on or off site to excessive groundborne vibration or groundborne noise levels, and this impact was determined to be less than significant.
Airport Noise
The Certified EIR stated that the Overlay Zone is not located within an airport land use plan or within 2.0 miles of a public airport or public use airport. The nearest public airport to the project is the John Wayne Airport, which is located approximately 6.5 miles southwest of the Overlay Zone.
Further, the Overlay Zone is located over 5,000 feet from the 60 CNEL noise contour for John Wayne Airport. Thus, no impact related to the exposure of people residing or working in the project site to excessive airport-related noise levels is anticipated.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
166 City Council 18 – 600 10/3/2023
Mitigation Measures
MM-OZ 4.9-1 Construction activities shall be limited to the following general restrictions. In the event that there is a conflict between the City of Santa Ana Municipal Code and the City of Tustin Municipal Code, the more restrictive measures shall be applied:
• All construction activity within the City shall be conducted in accordance with Section 18- 314(e) of the City of Santa Ana Municipal Code.
• All construction activity within 200 feet of the City of Tustin Border shall be conducted in accordance with Section 4617(e) of the City of Tustin Municipal Code.
MM-OZ 4.9-2 The project applicant shall require by contract specifications that the following construction best management practices (BMPs) be implemented by contractors to reduce construction noise levels:
• Two weeks prior to the commencement of construction, notification must be provided to surrounding land uses within 1,000 feet of a project site disclosing the construction schedule, including the various types of activities that would be occurring throughout the duration of the construction period
•
•
•
•
Ensure that construction equipment is properly muffled according to industry standards and be in good working condition
Place noise-generating construction equipment and locate construction staging areas away from sensitive uses, where feasible Schedule high noise-producing activities between the hours of 8:00 a.m. and 5:00 p.m. to minimize disruption on sensitive uses Implement noise attenuation measures, which may include, but are not limited to, temporary noise barriers or noise blankets around stationary construction noise sources
•
•
Use electric air compressors and similar power tools rather than diesel equipment, where feasible
Construction-related equipment, including heavy-duty equipment, motor vehicles, and portable equipment, shall be turned off when not in use for more than 30 minutes
• Construction hours, allowable workdays, and the phone number of the job superintendent shall be clearly posted at all construction entrances to allow for surrounding owners and residents to contact the job superintendent. If the City or the job superintendent receives a complaint, the superintendent shall investigate, take appropriate corrective action, and report the action taken to the reporting party.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
167 City Council 18 – 601 10/3/2023
• Contract specifications shall be included in the proposed project construction documents, which shall be reviewed by the City prior to issuance of a grading permit.
MM-OZ 4.9-3 The project applicant shall require by contract specifications that construction staging areas along with the operation of earthmoving equipment within the project area would be located as far away from vibration and noise-sensitive sites as possible. Contract specifications shall be included in the proposed project construction documents, which shall be reviewed by the City prior to issuance of a grading permit.
MM-OZ 4.9-4
MM-OZ 4.9-5
The project applicant shall require by contract specifications that heavily loaded trucks used during construction would be routed away from residential streets. Contract specifications shall be included in the proposed project construction documents, which shall be reviewed by the City prior to issuance of a grading permit.
Where future residential uses would be construction in areas exposed to noise level greater than 60 dBA CNEL, prior to issuance of building permits, building plans shall reflect the construction of noise barriers around patios and balconies. The barriers shall be constructed of materials that provide a surface density of at least four pounds per square foot and shall be continuous, without gaps or gates. The height of the barriers shall be sufficient to reduce the exterior noise levels to a CNEL of 65 dBA or less, and shall be determined by a qualified acoustical consultant as part of the final engineering design of the project
MM-OZ 4.9-6
MM-OZ 4.9-7
Prior to issuance of building permits, building plans shall specify the STC rating of windows and doors for all residential land uses. Window and door ratings shall be sufficient to reduce the interior noise level to a CNEL of 45 dBA or less, and shall be determined by a qualified acoustical consultant as part of the final engineering design of the project
The developer shall provide proper shielding for all new HVAC systems used by the proposed residential and mixed-use buildings to achieve an attenuation of 15 dBA at 50 feet from the equipment.
4.13.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project does not include any development Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
168 City Council 18 – 602 10/3/2023
that would extend beyond the building envelope considered in the Certified EIR, and no changes are proposed to the Overlay Zone to accommodate the Project. As discussed below, the Project would incorporate mitigation measures to minimize impacts related to noise and vibration would be less than significant, and accordingly, would not result in any new or increased significant impacts beyond those already identified in the Certified EIR.
The types of construction activities, operational activities, and construction and mechanical equipment and associated construction and operational noise and vibration levels would be substantially similar to those identified in the Certified EIR. The Project would implement Mitigation Measures MM-OZ 4.9-1 through MM-OZ 4.9-7 to protect residential receptors and to minimize construction and operational noise and vibration levels. Thus, the Project would not result in any new or increased significant impacts related to substantial temporary or permanent increase in noise and vibration beyond impacts already identified in the Certified EIR.
Further, a Project-specific noise analysis was prepared by DKA Planning (refer to Attachment F). in June 2023, DKA Planning took short-term noise measurements near the Project site to determine the current ambient noise conditions near the four nearest sensitive receptors: Cabrillo Park, 2001 E. 4th Street, the southeast corner of 4th Street and Cabrillo Park Drive, and 618 Sherry Lane. Regarding construction, the Project would comply with Santa Ana Municipal Code Section 18-314 and construction activities would be limited to the hours of 7:00 A.M. and 8:00 P.M. on Monday through Saturday, and would be prohibited on Sundays and federal holidays.
Table 7 of the DKA Noise Report demonstrates that construction of the Project would not increase ambient noise levels at any nearby sensitive receptor by more than 3.4 dBA and therefore would not result in significant noise impacts to those receptors, including Cabrillo Park directly north of the Project Site and 724 North Parkcenter Drive, the closest residence, located 80 feet northeast of the Project Site within the Lake Dianne Apartment complex. Regarding operation, Table 9 of the DKA Noise Report demonstrates that Project operation, including noise associated with mechanical and landscaping equipment, vehicles, outdoor and recreational uses, and trash and recycling services, would not increase ambient noise levels at any nearby sensitive receptor and therefore would not result in significant operational noise impacts to those receptors. The Project would also implement Mitigation Measures MM-OZ 4.9-1 through MM-OZ 4.9-7 of the Certified EIR to protect residential receptors and to minimize construction and operational noise and vibration levels. Thus, the Project would not result in any new or increased significant impacts related to substantial temporary or permanent increase in noise and vibration beyond impacts already identified in the Certified EIR.
Regarding airport noise, the nearest public airport to the project is the John Wayne Airport, which is located approximately 7 miles southwest of the Project Site well beyond the 60 CNEL noise contour for John Wayne Airport. Thus, no impact related to the exposure of people residing or working in the project site to excessive airport-related noise levels is anticipate.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
169 City Council 18 – 603 10/3/2023
4.13.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to noise have occurred and no substantial new noise sources have been identified within the vicinity of the Project since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
4.13.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance that has become available relative to noise impacts that would result in new or more severe significant environmental impacts.
4.13.5 Mitigation Measures Addressing Impacts
The Project would implement Mitigation Measures MM-OZ 4.9-1 through MM-OZ 4.9-7 from the Certified EIR.
4.13.6 Conclusion
Based on the above, no new significant noise impacts or a substantial increase in previously identified noise impacts would occur as a result of the Project. Therefore, the impacts to noise do not meet the standards for a subsequent or supplemental EIR pursuant to CEQA Guidelines Section 15162.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
170 City Council 18 – 604 10/3/2023
4.14 Population and Housing
Any Substantial Any Substantially
Changes
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Changed
Circumstances
Involving New
Significant Impact
or Substantially
More Severe
Any New
Information of Incorporates
Substantial
Importance?
Project
Impact
Issues (and supporting
Information Sources)
Determinatio
n in EIR
Mitigation
Impacts? Measure(s)?
POPULATION AND HOUSING: Would
the project:
(a) Induce substantial
unplanned population
growth in an area, either
directly (for example, by
proposing new homes and
businesses) or indirectly
(for example, through
extension of roads or
other infrastructure)?
Less Than
Significant No
No
No
No
No
No
No
No
(b) Displace substantial
numbers of existing
people or housing,
necessitating the
construction of
No Impact
replacement housing
elsewhere?
4.14.1 Impact Determination in the EIR
Unplanned Growth
The Certified EIR stated that the Overlay Zone would provide for infill development that makes maximum use of existing infrastructure. As the majority of development that would occur under the Overlay Zone would be infill or redevelopment, the development permitted under the Overlay Zone would not require significant regional public infrastructure upgrades for any utility, transportation facility, or public service. However, any new development would be required to include provisions to make the necessary improvements in order to facilitate implementation of the Overlay Zone. Project developers would be required to fund their fair-share allocation of any necessary public infrastructure associated with development under the Overlay Zone. Any infrastructure improvements would occur during a period of regional growth. Due to the fact that net new infrastructure developments would be minimal, it is not anticipated that the infrastructure improvements would result in measurable population growth in or around the Overlay Zone area.
As such, the indirect population growth impact resulting from infrastructure improvements associated with the Overlay Zone was determined to be less than significant.
Implementation of the Overlay Zone is intended to accommodate existing and future population growth forecasted for the City by introducing new residential housing within the Overlay Zone, as well as new employment opportunities in and around the Overlay Zone area.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
171 City Council 18 – 605 10/3/2023
Implementation of the Overlay Zone would enact zoning changes to allow for up to 5,551 multifamily residential units. In order to quantify the direct population increase that would result from new housing in the Overlay Zone, it is necessary to determine an appropriate pph estimate to use. Based on an average person per household size of 2.0 persons per household (pph), the estimated direct population growth associated with the potential 5,551 new residential units in the Overlay Zone would be approximately 11,102 people (5,551 units x 2.0 pph). In addition, the Overlay Zone would allow for a total of 1,275,440 square feet of commercial/retail/service uses and a total of 3,410,507 square feet of office building uses. These development potential totals would represent a net increase of 963,154 square feet of commercial/retail/service uses and a net increase of 690,339 square feet of office uses compared to existing conditions within the Overlay Zone. The net new commercial and office uses in the Overlay Zone could generate an estimated 2,343 additional jobs.
A population increase (without the project) of 16,905 residents is projected between 2005 and 2030 for the City, representing an annual average growth rate of 0.2 percent or approximately 676 residents per year. The direct population growth estimated to be associated with the project— approximately 11,102 people, or approximately 65 percent of the projected growth—would not result in growth exceeding this projection but is considered substantial in relation to the level of forecasted population growth.
The Overlay Zone was not planned or considered in the land use factors that SCAG or the City used to estimate the population growth forecast for Santa Ana. Therefore, the population growth associated with the project is not accounted for in the population growth projections. When coupled with natural population increases in the City that will result from births and migration, the project-related direct population growth would result in population growth in the City that far exceeds the projected growth.
However, in comparison to the average annual growth rate of 0.2 percent projected for the City, the population of Orange County is forecast to grow by an annual average growth rate of 0.6 percent between 2005 and 2030, while the population of the SCAG Region is forecast to grow by an average of 1.1 percent per year during this same 25-year period. Due to the fact that the City’s population is forecasted to grow at a slower rate than the County and SCAG Region, the forecasted project-related direct population growth in the City is not considered substantial relative to the surrounding areas.
Additionally, although the potential housing units (and associated population increase) were not previously anticipated, the City is relatively built-out and has limited opportunities for additional residential development. Specifically, according to the 2000 Housing Element of the General Plan, there was a potential for only 1,775 residential units to be developed on the City’s remaining undeveloped and underutilized properties. Even if all of these units were developed, the population increase that could be accommodated would only range between 3,550 and 8,343 persons (depending on a pph factor of 2.0 or 4.7). Therefore, in order to accommodate the forecasted population growth that is anticipated to continue to occur, infill and reutilization of underdeveloped land has become a priority in the City. In particular, as discussed in the City’s Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
172 City Council 18 – 606 10/3/2023
2000 Housing Element, the City’s intent is to intensify compatible residential development through adaptive reuse and mixed use within the District Center designation and other existing commercial zones. As discussed in the Land Use Element of the General Plan, District Centers are considered to be the City’s “Major Development Areas,” where the most intense development in the City is targeted. The Overlay Zone is a Major Development Area even though it is not designated as a District Center.
SCAG projections indicate an increase of up to 13,394 employees in the City from 2005-2030.
The Overlay Zone could generate up to 2,343 employment positions and would not substantially affect the employment forecasts within the City. With an existing (2005) jobs/housing ratio of 2.3 within the City, the new mix of residential and commercial/service and office uses in the Overlay Zone would improve the overall jobs/housing ratio to 2.4.
The Overlay Zone new commercial/service and office uses would generate an estimated 2,343 long-term employment positions. Based on similar projects, the distribution of part-time to fulltime would be approximately 60 percent (1,405) full-time jobs and 40 percent (937) part-time jobs.
Based upon resident worker characteristics for similar cities, it is estimated that approximately 25 percent of the new employees generated by the Overlay Zone, or about 585 workers, could relocate to the City. If it is conservatively assumed that each of these employees forms a single new household in the City (in residential units outside of the Overlay Zone area), these households could add approximately 2,749 additional residents to the City (585 worker households x 4.7 persons per household for areas in the City outside of the Overlay Zone).
The direct increase in population of 11,102 people that would be associated with the Overlay Zone residential units and the potential indirect increase in population of 2,749 people associated with the new employment opportunities generated by the Overlay Zone would result in a total population increase of approximately 13,851 people in the City. As noted above, this assumes that none of the new employees would reside in the new residential units within the Overlay Zone area. Based on the population projections, the projected population growth in Santa Ana between 2005 and 2030 is approximately 16,905 persons. The total direct and indirect population growth estimated to be associated with the project—approximately 13,851 people—will not result in growth exceeding this projection but is considered substantial in relation to the level of forecasted population growth.
The increased population and housing resulting from new development do not necessarily cause direct adverse physical environmental effects; however, indirect physical environmental effects such as population-driven traffic or air quality impacts could occur. These indirect physical environmental effects associated with population increases are analyzed in the relevant technical sections of this EIR.
Although the housing units under the Overlay Zone were not accounted for in the City and SCAG regional growth projections, implementation of the Overlay Zone is consistent with the overall intent of the City’s goals to provide adequate housing opportunities to meet its “fair share” of projected housing needs. In essence, implementation of the Overlay Zone would allow the City to Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
173 City Council 18 – 607 10/3/2023
accommodate the projected growth increases. Additionally, due to the fact that the City’s population is forecasted to grow at a slower rate than the County and SCAG Region, the forecasted project-related direct and indirect population growth in the City is not considered substantial relative to the surrounding areas. As such, this impact was determined to be less than significant.
Displace Housing or People
The Certified EIR stated the Overlay Zone is developed with commercial and office uses. Because no residential uses are located within the overlay zone boundaries, implementation of the Overlay Zone would not require the demolition of any existing housing and construction of replacement housing would not be necessary. Rather, implementation of the Overlay Zone would permit residential uses in an area that prohibits these uses. Consequently, no impact would occur.
Mitigation Measures
None required or identified.
4.14.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project does not include any development that would extend beyond the building envelope considered in the Certified EIR, and no changes are proposed to the Overlay Zone to accommodate the Project. Therefore, the Project’s housing and population generation would be consistent with that identified in the Certified EIR. Thus, the Project would not result in any new or increased significant impacts related to unplanned growth beyond impacts already identified in the Certified EIR.
There is no housing on the Project Site. As such, the Project would not displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere, and no impacts related to this issue would occur.
4.14.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to population and housing have occurred within the vicinity of the Project since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
174 City Council 18 – 608 10/3/2023
4.14.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance that has become available relative to population and housing impacts that would result in new or more severe significant environmental impacts.
4.14.5 Mitigation Measures Addressing Impacts
None required.
4.14.6 Conclusion
Based on the above, no new significant population and housing impacts or a substantial increase in previously identified population and housing impacts would occur as a result of the Project.
Therefore, the impacts to population and housing do not meet the standards for a subsequent or supplemental EIR pursuant to PRC Section 21166 and CEQA Guidelines Section 15162.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
175 City Council 18 – 609 10/3/2023
4.15 Public Services
Any
Substantially
Changed
Circumstances
Involving New
Significant
Impact or
Any Substantial
Changes
Involving New
Significant
Impacts or Any New Project
Impact
Determination
in EIR
Substantially
More Severe
Impacts?
Substantially
More Severe
Impacts?
Information of Incorporates
Issues (and supporting Information
Sources)
Substantial Mitigation
Importance? Measure(s)?
PUBLIC SERVICES:
Would the project result in substantial
adverse physical impacts associated
with the provision of new or physically
altered governmental facilities, need for
new or physically altered governmental
facilities, the construction of which
could cause significant environmental
impacts, in order to maintain acceptable
service ratios, response times or other
performance objectives for any of the
public services:
Less Than
Significant (a) Fire protection? No
No
No
No
No
No
No
No Less Than
Significant
(b) Police protection?
Less Than
(c) Schools? Significant No No No Yes
With Mitigation
Less Than
Significant
(d) Parks? No
No
No
No
No
No
No
No Less Than
Significant (e) Other public facilities?
4.15.1Impact Determination in the EIR
Fire
The Certified EIR stated adequate response times and staff are present at both Fire Stations serving the Overlay Zone. The addition of 5,551 residential units and office and commercial uses would increase demands on the Santa Ana Fire Department (SAFD). However, both stations serving the area have response times from 5 to 8 minutes, which the City considers adequate.
The additional demands from new development in the area are not expected to decrease response times or require additional staffing. The SAFD notified that they would be able to handle the increased service demands with their current staffing and equipment.
Adequate water flow is available with ample water pressure for fire services. SAFD’s Guide for the Determination of Fire Flow is used to estimate fire flow demands from new development.
Structures that require fire flow over 3,500 gallons per minute are either redesigned to lower the fire flow or to include a fire sprinkler system to reduce fire flow demand. The provision of automatic fire sprinklers would reduce the demand, as well as compliance with the Uniform Fire Code, Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
176 City Council 18 – 610 10/3/2023
Uniform Building Code, applicable state codes, National Fire Protection Association Fire Codes, and the Santa Ana Municipal Code.
Fire facilities fees would further assist in offsetting incremental increased demands from new development. A fire facilities fee is required as a condition of approval prior to the issuance of a building permit for construction of buildings exceeding two stories in height (excluding parking structures and excluding buildings owned and occupied by agencies of the federal, state or local governments). The SAFD also collects a plan check fee which is a fixed percentage of the building permit fee for review of building plans associated with new commercial, industrial, and multi-family residential units. Additional plan check fees for fire sprinkler, fire alarm, automatic extinguishing systems, and other fire protection systems are based on a fee schedule. SAFD also collects a one-time construction inspection fee for fire inspections. The Fire Department also collects an annual fee in the form of an “occupancy permit” for certain types of business, such as restaurants with large assemblage areas.
New development would be required to meet all access, water and fire protection system required under the California Building Code and Fire Code, and the City Municipal Codes. Therefore, impacts on City fire services would be less than significant.
Police
The Certified EIR stated the nearest Santa Ana Police Department (SAPD) station is the SAPD Main Headquarters located at 60 Civic Center Plaza approximately 2 miles from the Overlay Zone per the SAPD. The current officer-to-citizen ratio of 2 to 1,000 is consistent with City goal of between 1.3 to 1.5 officer per 1,000 residents. The Overlay Zone would result in the addition of 11,102 persons to the Overlay Zone at buildout. This would decrease the officer to citizen ratio from 2 to 1.95, which is well above the existing City service goals for police protection.
The number of calls from the Overlay Zone in the context of the entire City with a population of about 350,000 residents would not substantially affect the level of police protection and service provided by the SAPD. However, given the magnitude of the population increase at buildout, the addition of the Overlay Zone could affect how the SAPD resources are allocated.
Annual fees, collected in proportion to the revenue generated by a project, are collected for ongoing police protection services. All of the fees collected by the City are deposited into the City’s General Fund and dispersed to the appropriate departments during the annual budgetary process. Although not necessary to maintain sufficient levels of police service, additional personnel and possibly equipment would ensure no change to the ratio of officers to population.
The police department has indicated that the project must comply with the City’s Building Security Ordinance and the basic Crime Prevention through Environmental Design (CPTED) principles.
Also, the individual projects in the Mixed Use zone would be required to prepare mandated security plan, which would require a final Police Department approval. Thus, the Overlay Zone would have less than significant effect on the police services of the City.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
177 City Council 18 – 611 10/3/2023
Schools
The Certified EIR stated that full build out of residential development under the Overlay Zone could result in an additional 5,551 residential units in the Overlay Zone. With the identified generation rate of 0.284 students per unit, the Overlay Zone would generate approximately 1,576 students in the Tustin Unified School District (TUSD). TUSD is already in excess of its capacity by 89 students. Thus, with the existing schools and no future plans for expansion of TUSD facilities, TUSD will be unable to accommodate the additional 1,576 students. Incorporation of Mitigation Measure MM-OZ 4.11-1 would reduce this potentially significant impact to less-thansignificant levels.
Parks
The Certified EIR stated that implementation of future development within the Overlay Zone would provide a variety of open space/recreational opportunities. New development within the Overlay Zone would be required to include an open space/recreation component that is accessible to the public through the main street-facing façade entry of a project. Common open space amenities could include courtyards, plazas, tennis courts, swimming pools, spas, permanently equipped gym/exercise rooms, or other permanent amenities. Private open space/recreation areas could include balconies, loggias, terraces, or rooftop decks. Publicly accessible open space/recreation areas would be designed to optimize linkages and connections with adjacent properties within the Districts and would be visible and accessible from public rights-of-way to engage the interest of pedestrians and encourage public use. Open space/recreation areas would also encourage active use and pedestrian activity between the public and the private realm. Further, individual projects would be required to make payments of Park Acquisition and Development Fees based on the City’s Municipal Code Section 34-200 to Section 34-214. Consequently, the provision of open space within individual developments coupled with the payment of fees as appropriate would ensure that demands on parkland are not exacerbated. Impacts would be less than significant.
Libraries
The Certified EIR stated that the Overlay Zone is served by two libraries, the Santa Ana Public Library and the New hope Branch of the Santa Ana library system. Combined, these libraries have a collection of approximately 301,966 items and an overall size of 49,000 square feet (40,000 square feet main library and 9,000 square feet branch library). No new library facilities or expansions are planned for the immediate future. Using the guidelines identified above, implementation of the Overlay Zone would require approximately 5,551 sf of library space and approximately 22,204 volumes due to an estimated increase of approximately 11,102 persons under full build-out of the Overlay Zone. The City’s library system is funded through the general fund and does not have a fee collection system in place to obtain fees from a developer. The tax base afforded by the additional development within the Overlay Zone would contribute to the City’s general fund, which is distributed to various City services, including libraries. Therefore, any necessary improvements/modifications to the existing Santa Ana library system would be implemented using the general fund and determined on an as-needed annual basis by the City.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
178 City Council 18 – 612 10/3/2023
As such, any increase in the need for library resources would be implemented by the City irrespective of the project, although aided by the additional tax base from development within the Overlay Zone, and impacts were determined to be less than significant.
Mitigation Measures
MM-OZ 4.11-1 Individual project developers shall pay school impact fees prior to the issuance of occupancy permits.
4.15.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project does not include any development that would extend beyond the building envelope considered in the Certified EIR, and no changes are proposed to the Overlay Zone to accommodate the Project. The Project’s demand for fire protection, police protection, school, library and park services would be substantially similar to that identified in the Certified EIR. Additionally, the Project would be required to meet all access, water and fire protection system required under the California Building Code and Fire Code and the City Municipal Code. Additionally, the Project would be required to comply with the City’s Building Security Ordinance and the basic CPTED principles. Also, the Project would be required to prepare a mandated security plan, which would require a final Police Department approval. The Project would also implement Mitigation Measure MM-OZ 4.11-1 and pay school impact fees to minimize impacts to school services. Finally, the Project would pay taxes that would go into the City’s General Fund a portion of which supports library services and would be required to make payments of Park Acquisition and Development Fees based on the City’s Municipal Code Section 34-200 to Section 34-214 and to provide open space in accordance with the City’s open space requirements. Thus, the Project would not result in any new or increased significant impacts related to public services beyond impacts already identified in the Certified EIR.
Mitigation Measures
The Project would implement Mitigation Measure MM-OZ 4.11-1 from the Certified EIR.
4.15.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to public services and recreation have occurred within the vicinity of the Project since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
179 City Council 18 – 613 10/3/2023
4.15.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance that has become available relative to public services and recreation that would result in new or more severe significant environmental impacts.
4.15.5 Mitigation Measures Addressing Impacts
The Project would implement Mitigation Measure MM-OZ 4.11-1 from the Certified EIR.
4.15.6 Conclusion
Based on the above, no new significant public services impacts or a substantial increase in previously identified public services impacts would occur as a result of the Project. Therefore, the impacts on public services do not meet the standards for a subsequent or supplemental EIR pursuant to CEQA Guidelines Section 15162.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
180 City Council 18 – 614 10/3/2023
4.16 Recreation
Do Proposed
Changes
Any New
Circumstances
Involving New
Significant
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impact or Information Project
Impact
Determination
in EIR
Substantially
More Severe
Impacts?
Requiring New Incorporates
Issues (and supporting Information
Sources)
Analysis or Mitigation
Verification? Measure(s)?
RECREATION
(a) Would the project increase
the use of existing
neighborhood and regional
parks or other recreational
facilities such that substantial
physical deterioration of the
facility would occur or be
accelerated?
Less Than
Significant No
No
No
No
No
No
No
No
(b) Does the project include
recreational facilities or
require the construction or
expansion of recreational
facilities which might have an
adverse physical effect on
the environment?
Less Than
Significant
4.16.1 Impact Determination in the EIR
Increase Use of Parks/Recreational Facilities/Construction/Expansion of Recreational Facilities
The Certified EIR stated that implementation of future development within the Overlay Zone would provide a variety of open space/recreational opportunities. New development within the Overlay Zone would be required to include an open space/recreation component that is accessible to the public through the main street- facing façade entry of a project. Common open space amenities could include courtyards, plazas, tennis courts, swimming pools, spas, permanently equipped gym/exercise rooms, or other permanent amenities. Private open space/recreation areas could include balconies, loggias, terraces, or rooftop decks. Publicly accessible open space/recreation areas would be designed to optimize linkages and connections with adjacent properties within the Districts and would be visible and accessible from public rights-of-way to engage the interest of pedestrians and encourage public use. Open space/recreation areas would also encourage active use and pedestrian activity between the public and the private realm. Further, individual projects would be required to make payments of Park Acquisition and Development Fees based on the City’s Municipal Code Section 34-200 to Section 34-214. Consequently, the provision of open space within individual developments coupled with the payment of fees as appropriate would ensure that demands on parkland are not exacerbated. Impacts were determined to be less than significant.
Mitigation Measures
None required or identified.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
181 City Council 18 – 615 10/3/2023
3.15.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project does not include any development that would extend beyond the building envelope considered in the Certified EIR, and no changes are proposed to the Overlay Zone to accommodate the Project. The Project’s demand for parks would be substantially similar to that identified in the Certified EIR. Additionally, the Project would be required to make payments of Park Acquisition and Development Fees based on the City’s Municipal Code Section 34-200 to Section 34-214 and to provide open space in accordance with the City’s open space requirements. The Project would provide a total of 33,572 square feet of private open space and 76,187 square feet of common open space (a total of 109,759 square feet), exceeding the amount required by 58,769 square feet. The Project would also provide 47,810, exceeding the amount required by 8,744 square feet. Thus, the Project would not result in any new or increased significant impacts related to parks beyond impacts already identified in the Certified EIR.
3.15.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to recreation have occurred within the vicinity of the Project since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
3.15.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance that has become available relative recreation that would result in new or more severe significant environmental impacts.
3.15.5 Mitigation Measures Addressing Impacts
None required.
3.15.6 Conclusion
Based on the above, no new significant recreation impacts or a substantial increase in previously identified public services impacts would occur as a result of the Project. Therefore, the impacts to recreation do not meet the standards for a subsequent or supplemental EIR pursuant to CEQA Guidelines Section 15162.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
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4.16 Transportation
Any Substantial Any Substantially
Changes
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Changed
Circumstances
Involving New
Significant Impact
or Substantially
More Severe
Any New
Information of Incorporates
Substantial
Importance?
Project
Impact
Determination
in EIR
Issues (and supporting
Information Sources)
Mitigation
Impacts? Measure(s)?
TRANSPORTATION / TRAFFIC: Would
the project:
(a) Conflict with a program, plan,
ordinance or policy addressing
the circulation system,
including transit, roadway,
bicycle and pedestrian
facilities?
Less Than
Significant No
No
No
No
No
No
No
No
No
No
No
No
(b) Conflict or be inconsistent with
CEQA Guidelines Section NA
15064.3 subdivision (b)?
(c) Substantially increase hazards
due to a geometric design
feature (e.g., sharp curves or
dangerous intersections) or
incompatible uses (e.g., farm
equipment)?
Less Than
Significant
Less Than
Significant
With Mitigation
(d) Result in inadequate
emergency access?
No No No Yes
4.16.1 Impact Determination in the EIR
Increase in Traffic/ LOS
The Certified EIR stated that the significance of local street segment impacts related to excess vehicle traffic is usually determined on a case-by-case basis because each street segment has unique characteristics. The City has established goals for maintaining LOS D or better on local streets. The ability to determine LOS on a local street is very difficult for several reasons. Most importantly, each street is unique in character. Local streets vary considerably in terms of street width, adjacent land uses, density, presence of schools, day care, senior housing, proximity to other major streets, and other factors. A level of traffic which may be perceived as too much on one street may be acceptable on another. Furthermore, a lane of traffic, carrying the traditional LOS D volume on an arterial street, would be far too much traffic for most residential streets. The City has established LOS guidelines based on average daily traffic (ADT) along particular street segments depending on the street segment type. The maximum roadway capacities, in ADT, are based on the number of lanes and roadway classification.
For the Overlay Zone, the LOS for roadway segments is determined by comparing the ADT volumes for each roadway segment to the appropriate LOS D capacity for that roadway classification. When the ADT volume is within the LOS D volume criteria, the roadway segment is operating at an acceptable LOS. The Certified EIR presents the ADT segment analysis for 31 roadway segments in and surrounding the Overlay Zone, both for existing conditions and Cabrillo Town Center City of Santa Ana
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assuming full buildout of the Overlay Zone. One roadway segment (Cabrillo Park Drive between First Street and Fourth Street) is expected to operate at an unacceptable LOS under the Overlay Zone with the expected traffic levels and secondary arterial roadway configuration. However, this roadway is currently constructed with a raised median and can be considered to be four lanes divided, justifying a higher allowable daily capacity of 33,800. As such, implementation of the Overlay Zone would not be anticipated to increase traffic volumes such that street segment volume capacities are exceeded, and impacts were determined to be less than significant.
In evaluating consistency with the Certified EIR traffic analysis, twenty-nine of the 38 intersections analyzed in the study area would remain at LOS D or better under the “Buildout without Project” conditions, while only 19 of the intersections would operate at LOS D or better under the “Buildout with Project” conditions. Traffic impacts created by the Overlay Zone can be evaluated by comparing these scenarios (with and without project conditions).
The Overlay Zone will contribute to unacceptable levels of service at eight of the intersections evaluated in the AM peak hour. The impact at these eight intersections is considered significant based on the identified criteria. It is also important to note that two additional intersections (First Street at Newport Avenue and Irvine Boulevard at Newport Avenue) would also operate at unacceptable levels (LOS E). However, based on the City of Tustin’s threshold criteria, these intersections would not be considered significant due to the Overlay Zone because the project’s contribution is less than 0.03.
The Overlay Zone would contribute to unacceptable LOS at 16 of the intersections evaluated in the PM peak hour, which include a majority of the signalized intersections along Fourth Street between the I-5 Freeway and the SR-55 Freeway. The impact at these intersections is considered significant based on City criteria.
Thus, a total of 17 different intersections would be impacted by buildout of the Overlay Zone during either the AM or PM peak hour, or both, which is considered potentially significant. Full buildout of the Overlay Zone is dependent on future individual development projects, of which the exact type and location is presently unknown. As such, the Certified EIR has identified potential improvement measures below that would serve to reduce the impacts at the seventeen affected intersections. As development occurs within the Overlay Zone, the following improvement measures may be implemented as part of future development projects, as required. In addition, an improvement measure is also identified for the First Street at Newport Avenue, which is not an impact but which does operate at an unacceptable LOS due to background traffic growth.
However, some of the intersections that would operate at unacceptable LOS are outside of the jurisdiction of the City. As such, the City cannot ensure implementation of these improvements. If these improvements were not implemented, LOS would remain below acceptable levels as a result of implementation of the proposed Overlay Zone.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
184 City Council 18 – 618 10/3/2023
Potential Improvement Measures
• First Street at Cabrillo Park Drive—The intersection of First Street at Cabrillo Park Drive experiences an acceptable LOS in the AM and PM peak hours. With the addition of background traffic growth and traffic from the Overlay Zone the LOS is expected to decline to LOS F in the PM peak hour. The recommended mitigation for this intersection is restriping for a second eastbound left turn lane, by reducing the eastbound through approach to two lanes. This improvement will fully mitigate traffic impacts to LOS C.
•
•
First Street at Elk Lane—The intersection of First Street at Elk Lane is operating at LOS D in the PM peak hour. The addition of background traffic growth and traffic from the Overlay Zone is expected to result in a decline in LOS to LOS F in the PM peak hour. The recommended mitigation for this intersection is the construction of a second northbound right turn lane and northbound right turn overlap signal phasing.
These improvements will fully mitigate traffic impacts to LOS C.
Fourth Street at SR-55 Southbound Ramps—The intersection of Fourth Street at SR-55 Southbound Ramps currently operates at LOS D or better in the AM and PM peak hours. Background traffic growth and traffic from the Overlay Zone is expected to result in a decline in LOS to LOS F in the AM and PM peak hours. The recommended mitigation for this intersection is the construction of an eastbound free-right turn lane and changing the southbound ramp configuration to two left and two right turn lanes. These improvements fully mitigate impacts to LOS D.
• Fourth Street at Tustin Avenue—The intersection of Fourth Street at Tustin Avenue currently experiences an acceptable LOS (LOS C or better) in the AM and PM peak hours. The addition of background traffic growth and traffic from the Overlay Zone is expected to reduce LOS to LOS F in both the AM and PM peak hours. The recommended mitigation for this intersection is the construction of a westbound rightturn lane, a second eastbound left-turn lane, and a northbound right-turn lane (to allow conversion of the northbound shared thru-right lane to a through lane). Also, northbound right-turn overlap signal phasing should be installed. These improvements will partially mitigate project impacts to LOS E. As such, if the improvement measures were implemented, this intersection would not be mitigated to a level of less than significant.
• Fourth Street at Golden Circle—The intersection of Fourth Street at Golden Circle currently operates at LOS A in both the AM and PM peak hours. Background traffic growth and traffic from the Overlay Zone is expected to result in a decline in level of service to LOS E in the PM peak hour. The recommended mitigation for this intersection is the construction of an eastbound right turn lane, and a change in the southbound lane configuration to provide one left turn lane and one shared throughright turn lane. These improvements will fully mitigate traffic impacts to LOS D.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
185 City Council 18 – 619 10/3/2023
• Fourth Street at Cabrillo Park Drive—The intersection of Fourth Street at Cabrillo Park Drive currently experiences an acceptable LOS (LOS C or better) in both the AM and PM peak hours. The addition of background traffic growth and traffic from the Overlay Zone is expected to reduce LOS to LOS F in the PM peak hour. The recommended mitigation for this intersection is the construction of a westbound right turn lane, a northbound right turn lane, and a southbound right turn lane, and restriping to change the lane configuration of the north/south approaches. The northbound and southbound approaches should be controlled by a split phase intersection control and restriped to provide one left, one shared through-left, one through, and one right turn lane. These improvements are expected to fully mitigate impacts to LOS D. •
•
I-5 Northbound Ramps and Fourth Street—The intersection of the I-5 northbound ramps and Fourth Street is expected to operate at a poor LOS (LOS F) in the PM peak hour with the addition of background traffic growth and traffic from the Overlay Zone. The recommended mitigation for this intersection is the construction of a second westbound right turn lane. This improvement will fully mitigate traffic impacts to LOS C. However, as this intersection is outside the jurisdiction of the City of Santa Ana, the City cannot ensure implementation of this improvement.
Seventeenth Street at Cabrillo Park Drive—The intersection of 17th Street at Cabrillo Park Drive currently has a good LOS in both the AM and PM peak hours (LOS B or better). With the addition of background traffic growth and traffic from the Overlay Zone LOS is expected to decline to LOS E in the PM peak hour. The recommended mitigation to address impacts at this intersection is the restriping of the northbound lane configuration to one left, one shared left-through, and one right turn lane, with split signal phasing. These improvements are expected to fully mitigate traffic impacts at this intersection to LOS D.
•
•
Seventeenth Street at Tustin Avenue—The intersection of 17th Street and Tustin Avenue currently operates at Level of Service C or better in the AM and PM peak hours.
Level of service is expected to decline to LOS E in the AM peak hour due to growth in background traffic and traffic from the Overlay Zone. The recommended mitigation for this intersection is the construction of a third northbound through/right turn lane and designating the lanes to allow vehicles to turn right from the right turn lane and from the adjacent (new) through lane. These improvements would fully mitigate traffic impacts at this intersection to LOS D.
First Street at Prospect Avenue—The intersection of 1st Street at Prospect Avenue is currently operating at LOS A in the AM and PM peak hours. Background traffic growth and traffic from the Overlay Zone is expected to cause a decline in LOS to LOS E in the PM peak hour. The increase in V/C at this intersection is above the impact threshold of 0.03 for the City of Tustin. The recommended mitigation for this intersection is the construction of a northbound right turn lane and northbound right turn overlap signal Cabrillo Town Center City of Santa Ana
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phasing. These improvements will fully mitigate traffic impacts to LOS D. However, as this intersection is outside the jurisdiction of the City of Santa Ana, the City cannot ensure implementation of this improvement.
• First Street at Newport Avenue—The intersection of First Street at Newport Avenue currently experiences LOS C or better in the AM and PM peak hours. The addition of background traffic growth is expected to result in a decline in LOS at this intersection to LOS E in the AM peak hour. Although the Overlay Zone would not result in a significant impact at this intersection because the contribution is less than the identified threshold of 0.03, improvements to this intersection are feasible, but not required. The improvements at this intersection include eastbound right turn overlap signal phasing and provision of a third southbound through lane, by constructing a southbound right-turn lane. These improvements will improve intersection performance to LOS C. However, as this intersection is outside the jurisdiction of the City of Santa Ana, the City cannot ensure implementation of this improvement. • Irvine Boulevard at SR-55 Northbound Ramps—The intersection of Irvine Boulevard at SR-55 Northbound Ramps is currently operating at LOS D or better in the AM and PM peak hours. The addition of background traffic growth and traffic from the proposed project is expected to result in a decline in LOS to LOS F in the AM and PM peak hours.
The recommended mitigation for this intersection is the construction of a westbound free-right turn lane and the conversion of the third eastbound through lane to a second eastbound left turn lane. These improvements fully mitigate traffic impacts at this intersection to LOS D.
• Parkcourt at Cabrillo Park Drive—The intersection of Cabrillo Park Drive and Parkcourt currently operates at LOS C or better in the AM and PM peak hours. Level of service is expected to decline to LOS F in the PM peak hour with the addition of background traffic growth and traffic from the Overlay Zone. The recommended mitigation for this intersection is the prohibition of cross-traffic through the use of median islands, diverters, or other means. This improvement will fully mitigate the traffic impacts at this intersection.
•
•
Fruit Street at Cabrillo Park Drive—The intersection of Cabrillo Park Drive and Fruit Street currently operates at LOS B in both the AM and PM peak hours. Future background traffic growth and traffic from the Overlay Zone is expected to result in a decline in LOS to LOS E in the PM peak hour. The recommended mitigation for this intersection is the installation of a traffic signal or a roundabout. Either improvement is expected to result in an improvement to LOS C or better, fully mitigating impacts.
Wellington Avenue at Cabrillo Park Drive—The intersection of Cabrillo Park Drive and Wellington Avenue currently operates at LOS C in both the AM and PM peak hours. Level of service is expected to decline to LOS F in both the AM and PM peak hours due to growth in background traffic and traffic from the Overlay Zone. The Cabrillo Town Center City of Santa Ana
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recommended mitigation for this intersection is the installation of a traffic signal or a roundabout. Either improvement is expected to result in an improvement to LOS B or better, fully mitigating impacts.
• Tustin Avenue and Sixth Street—The intersection of Tustin Avenue and Sixth Street currently operates at LOS D in both the AM and PM peak hours. Level of service is expected to decline to LOS F in the AM and PM peak hours with the addition of background traffic growth and traffic from the Overlay Zone. The recommended mitigation for this intersection is the prohibition of eastbound-westbound cross-traffic through the construction of median islands or diverters. This improvement will fully mitigate the traffic impacts at this intersection. Intersection performance will improve to LOS D.
•
•
Fourth Street and Parkcenter—The intersection of Fourth Street and Parkcenter currently operates at LOS B in both the AM and PM peak hours. Growth in background traffic and traffic from the Overlay Zone is expected to result in a decline to LOS F in the PM peak hour. The recommended mitigation for this intersection is the installation of a traffic signal. Impacts will be fully mitigated to LOS B.
First Street and B Street—The intersection of First Street and B Street currently operates at LOS E in the PM peak hour. Growth in background traffic and traffic from the Overlay Zone is expected to result in a decline in LOS to LOS F in both the AM and PM peak hours. The recommended mitigation for this intersection is the installation of a traffic signal. Impacts will be fully mitigated to LOS B at this intersection.
However, as this intersection is outside the jurisdiction of the City of Santa Ana, the City cannot ensure implementation of this improvement.
Summary
The potential intersection improvements described above are expected to fully mitigate all traffic impacts to an acceptable LOS (LOS D or better), except at one intersection (Fourth Street at Tustin Avenue), as noted above. The Mitigation Measures MM-OZ 4.12-2 through MM-OZ
4.12-4 shall be implemented to reduce the potential impacts that would occur with implementation and full buildout of the Overlay Zone. Some of the significantly impacted intersections would be located outside of the City’s jurisdiction; thus, the City of Santa Ana cannot ensure implementation of the suggested improvements. In addition, at least one of the identified intersections would not be mitigated to a less-than-significant level even with mitigation. Therefore, although it is assumed that a majority of the identified improvement measures could be implemented to mitigate impacts, due to a variety of constraints, at least one (if not more) of the intersections would not be improved to an acceptable level of service. Consequently, full buildout of the Overlay Zone would result in an increase in traffic that is substantial in relation to the existing traffic load and capacity of the street system, and this impact was determined to be significant and unavoidable.
Cabrillo Town Center City of Santa Ana
Technical Memorandum August 2023
188 City Council 18 – 622 10/3/2023
Air Traffic Patterns
As discussed previously, the Certified EIR stated that the Overlay Zone is located approximately
6.5 miles northeast of JWA and is located outside of the Airport Planning Area for JWA. However, because the Overlay Zone could result in the development of structures that are more than 200 feet above ground level, filing with the FAA is required. As required by mitigation measure MMOZ 4.6-4, any future projects within the Overlay Zone that would exceed 200 feet in height (from ground level at the project site) would be required to file a Notice of Proposed Construction or Alteration (FAA Form 7460-1). Therefore, compliance with recommendations or guidelines from the FAA would ensure that future development would not result in any change to air traffic patterns. This impact was determined to be less than significant.
Parking
The Certified EIR stated that the Overlay Zone would consist of approximately 5,551 residential units, over 3.4 million sf of office space, and 1.3 million sf of commercial space. The uses in each zone determine the amount of parking required. Parking requirements within the City of Santa Ana are provided in Chapter 41 of the City of Santa Ana Municipal Code. Since the exact uses that would be developed under the Overlay Zone are not known at this time, the precise amount of parking required is not known. As the City’s Municipal Code regulates the amount of parking necessary for development within the City, future development within the Overlay Zone would be required to adhere to existing regulations, as well as the guidelines listed above in Table 4.12-9 of the Certified EIR. Any future development projects within the Overlay Zone would be subject to review to ensure compliance with the City’s parking requirements of the Overlay Zone and Municipal Code. Thus, future development projects would be required to provide adequate parking, and this impact was determined to be less than significant.
Design Hazards
The Certified EIR stated that the Overlay Zone will be designed to utilize the existing network of regional and local roadways located within the vicinity of the study area. Three additional street segments may be constructed during implementation of the Overlay Zone in conjunction with reuse of the properties under a private development scenario. Additional proposed changes to road design within the study area as a part of the Overlay Zone could include potential improvement measures. Most of the identified improvements include the addition of one lane to a road segment, or the addition of a turn lane at an intersection and would not represent an increase in hazards associated with a design feature. Rather, these recommended improvements are designed to reduce potential hazards due to congestion. As such, this impact was determined to be less than significant.
Emergency Access
The Certified EIR stated the Overlay Zone would be required to meet all applicable local and State regulatory standards for adequate emergency access. Emergency access within the Overlay Zone Area is covered previously under the Hazards and Hazardous Materials topic in the Cabrillo Town Center City of Santa Ana
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discussion of whether the Project would impair an emergency response plan. Adherence to applicable local and state regulatory standards and mitigation measures identified within under that topic ensures this impact remains less than significant.
Conflict with Transit, Bicycle, Pedestrian Facilities Plans The Certified EIR stated that the Overlay Zone would not conflict with adopted policies, plans, or programs supporting alternative transportation. The Overlay Zone would comply with City of Santa Ana Municipal Code requirements and would provide bicycle racks, parking spaces for carpool/vanpool vehicles, and display rideshare information. In addition, the Overlay Zone is intended to provide a live-work community that would reduce daily vehicle trips, thereby encouraging alternative transportation via pedestrian and bicycle traffic. After analyzing public transit within two miles of the Overlay Zone, the following facilities and/or programs could be incorporated into the project to help encourage public transit patronage for program-related trips.
Note that the implementation responsibility for some of these facilities and programs would fall on agencies other than Santa Ana, the lead agency for this project. Thus, coordination between the City of Santa Ana, local and regional transit providers, and the project developer will be required on several of these items. The Mitigation Measure MM-OZ 4.12-1 shall be implemented, as required by applicable local, state, or federal laws or regulations, or the Overlay Zone. As the Overlay Zone would be consistent with the City’s goals and policies pertaining to expanding alternative transportation, and because the Overlay Zone is designed to facilitate alternative transportation, this impact was determined to be less than significant.
Congestion Management
The Certified EIR stated that the Orange County Transportation Authority is designated as the Congestion Management Agency (CMA) to oversee the Orange County CMP. The following three intersections are the only CMP intersections within the study area:
•
•
•
First Street at I-5 South Bound On Ramp (Santa Ana)
Fourth Street at SR-55 Southbound Ramps (Santa Ana)
Irvine Boulevard at SR-55 Northbound Ramps (Tustin)
All three CMP intersections are signalized. As discussed above in the Thresholds of Significance, a traffic-related project contribution is considered significant for the City of Santa Ana intersections if the change in ICU is greater than 0.01, which is more stringent than the CMP criteria. In addition, a traffic related project contribution is considered significant for the City of Tustin intersection if the change in ICU is greater than 0.03, as identified by the CMP.
As discussed above in Impact 4.12-7, two of the CMP intersections, Fourth Street/SR-55 Southbound ramps and Irvine Boulevard/SR-55 Northbound ramps, would experience poor LOS due to the proposed project. Implementation of the above identified improvement measures for these two intersections would improve the level of service to acceptable operating conditions (LOS D). Therefore, if the improvement measures are implemented in the future under specific development projects, impacts to these intersections would be less than significant. However, Cabrillo Town Center City of Santa Ana
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implementation of the improvement measures for these intersections cannot be ensured by the City, particularly because one of the intersections (Irvine Boulevard at SR-55 Northbound Ramps) is located outside of the City’s jurisdiction. Therefore, this impact was determined to be considered significant and unavoidable, and the City adopted a statement of overriding considerations.
Mitigation Measures
MM-OZ 4.12-1 As part of the project, the City of Santa Ana and the project sponsors shall work with the transit providers to implement various transit-related measures to improve and expand bus system service within the Overlay Zone. These measures may include, but are not limited to, the following:
• Adding bus stops to the Overlay Zone along existing and proposed roadways
•
•
•
Changing bus service headways to respond to increased demand Changing bus service destinations to respond to changing demand Adding local shuttle service for employees and patrons of the Overlay Zone
The details of bus service improvements shall be determined in coordination with OCTA. The following recommendations would help encourage public transit patronage for project-related trips:
•
•
•
Bus Stop Locations—Relocation of existing bus stops and the provision of additional bus stops should be considered to accommodate transit users at convenient locations.
Days of Operation—The City should work with OCTA to consider changes to route times to serve nighttime and weekend project visitors and employees.
Headway—The City should work with OCTA to review route headways to determine if it would be appropriate to reduce them to accommodate transit riders within the Overlay Zone.
MM-OZ 4.12-2 Future development within the proposed Overlay Zone shall prepare separate traffic studies, specific to the individual projects that are proposed. The traffic studies for future projects shall be prepared by a qualified traffic engineer of the City’s choosing. Further, and as determined by the traffic studies, the above identified improvement measures shall be implemented as a condition of the proposed development, either through the direct construction of improvements by the project applicant or through payment of a fee, as required by the program detailed in MM-OZ 4.12-4.
MM-OZ 4.12-3 The City of Santa Ana Planning Department, in cooperation with the Department of Public Works, shall monitor the traffic signals within the Overlay Cabrillo Town Center City of Santa Ana
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Zone Study Area once every five years to ensure that traffic signal timing is optimized.
MM-OZ 4.12-4 The City of Santa Ana shall institute a program for systematic mitigation of impacts as development proceeds within the Overlay Zone to ensure mitigation of the individual improvements. The program shall prescribe the method of participation in the mitigation program by individual projects and guide the timely implementation of the mitigation measures. The program should include the following elements:
• A funding and improvement program should be established to identify financial resources adequate to construct all identified mitigation measures in a timely basis.
• The program should allow for acquisition of entire properties including business relocation where necessary to construct mitigation measures.
Funds derived from sale of surplus acquired properties should be returned to the program.
•
•
All properties that redevelop within the Overlay Zone should participate in the program on a fair share per new development trip basis. The fair share should be based upon the total cost of all identified mitigation measures, divided by the peak hour trip generation increase forecast. This rate per peak hour trip should be imposed upon the incremental traffic growth for any new development within the Overlay Zone.
The program shall include resources to conduct preliminary engineering studies to complete alignment studies and project specific environmental clearances for Tustin Avenue at Seventeenth Street and at Fourth Street. •
•
The program should raise funds from full development of the Overlay Zone to fund all identified mitigation measures.
The program should monitor phasing development of the Overlay Zone and defer or eliminate improvements if the densities permitted in the Overlay Zone are not occurring.
•
•
Program phasing should be monitored through preparation of specific project traffic impact studies for any project that is expected to include more than 100 dwelling units or 100,000 square feet of non-residential development. Traffic impact studies should use traffic generation rates that are deemed to be most appropriate for the actual development proposed.
The program should initiate project development to assure timely completion of the improvements identified to be needed for the First and Cabrillo Towers project by 2010 or as soon after as practically feasible.
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•
•
•
•
Properties within Santa Ana and within one-half mile of the Overlay Zone that redevelop to result in higher traffic generation should also participate in the program to insure equity.
The program should provide for full construction of projects outside of Santa Ana, if the Overlay Zone will create a traffic impact based upon the CMP.
The program should provide fair share contribution to construction costs of other improvements outside of the Overlay Zone if they are identified in this traffic study but they are not impacted as defined by the CMP.
The fair share contribution would presume participation by other developments outside of the City of Santa Ana (generally within the City of Tustin) in proportion to traffic growth at the affected sites. •
•
Traffic impact studies for future projects shall be prepared by a qualified traffic engineer approved or retained by the City.
The City may elect to implement appropriate mitigation measures as a condition of approval of the proposed developments, where appropriate.
All or part of the costs of these improvements may be considered to be a negotiated credit toward the program, however the program must be administered in a manner that assures that it can fund necessary improvements to maintain adequate level of service at all intersections within this study. If funding of priority improvements cannot be assured, credit for construction of lower priority improvements may not be assured or may be postponed until more program funds are available. • Traffic studies for future developments within the Overlay Zone must also use trip generation rates which are specific for these projects and are approved by the City. The traffic consultant preparing traffic studies for specific projects in the Overlay Zone must use City-approved trip generation rates specific to these projects. These studies are subject to City review.
4.16.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project does not include any development that would extend beyond the permitted density, allowable units, or building envelope considered Cabrillo Town Center City of Santa Ana
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in the Certified EIR, and no changes are proposed to the Overlay Zone to accommodate the Project.
Further, in compliance with Mitigation Measure MM-OZ 4.12-2, a site-specific traffic study has been prepared for the Project by Linscott, Law & Greenspan Engineers that analyzes the potential traffic impacts consistent with the methodology in the Certified EIR (refer to Attachment G). The Project traffic study concludes that the Project’s fair share contribution to following specific improvement measures from the list in the Certified EIR that would mitigate potential impacts:
Cabrillo Park Drive/Fourth Street: Widen and provide the additional right-of-way required to construct an exclusive westbound right-turn lane with 125-feet of storage and 90-feet transition.
Modify the existing traffic signal as necessary.
SR 55 SB Ramps at Fourth Street: Modify the eastbound shared through/right-turn lane to construct a free-right turn lane. Modify the existing traffic signal as necessary. This improvement is subject to the review and approval of the City of Santa Ana, City of Tustin and/or Caltrans.
SR 55 NB Ramps at Fourth Street: Modify the eastbound approach to provide dual left-turn lanes and two through lanes. Modify the existing traffic signal as necessary. This improvement is subject to the review and approval of the City of Santa Ana, City of Tustin and/or Caltrans.
Per Mitigation Measure MM-OZ 4.12-2, these improvement measures would be implemented as a condition of the Project, either through the direct construction of improvements or through payment of a fair share contribution fee, as required by the program detailed in Mitigation Measure MM-OZ 4.12-4. Accordingly, the Project’s trips were accounted for in the Certified EIR, and with the required mitigation, the Project would not result in any new or increased significant LOS impacts beyond those already identified in the Certified EIR.
Since adoption of the Certified EIR, the LOS metric for analyzing transportation and traffic impacts under CEQA has been replaced with a VMT analysis to address consistency with CEQA Guidelines Section 15064.3(b). However, recent California case law confirms that CEQA Guidelines Section 15064.3(b) only applies prospectively to CEQA documents that have not yet been circulated for public review and not to CEQA documents that rely on previously certified EIRs that complied with applicable CEQA requirements when publicly reviewed. The court in Olen Properties Corp. v. City of Newport Beach (2023) 93 Cal.App.5th 270 explicitly recognizes that VMT impacts were known of and understood at the time the EIR in that case was certified (i.e., 2006, just like the Certified EIR for the Overlay Zone) and therefore do not constitute new information that would trigger recirculation. Thus, a project relying on a previously certified EIR under CEQA Guidelines 15168(c) is not required to provide a VMT analysis if: (1) the previously certified EIR evaluated transportation impacts based on LOS and (2) the subsequent project is within the scope of the impacts assessed in the previously certified EIR and any applicable mitigation measures are adopted...
The 2006 Certified EIR was certified well before CEQA Guidelines Section 15064.3(b) was adopted and relies on an LOS analysis, not a VMT analysis, to analyze the Overlay Zone’s transportation impacts. The CEQA findings associated with the Project will not be circulated for Cabrillo Town Center City of Santa Ana
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public review. Therefore, no VMT analysis is not required to evaluate the Project’s consistency with the Certified EIR and the lead agency is evaluating consistency based only on LOS. . In any event, in response to public comments received an analysis of the Project’s VMT impacts is included in this document for informational purposes only.
VMT Impacts (Informational Purposes Only)
The analysis and information presented below are based on the Vehicle Miles Traveled (VMT) Screening Assessment prepared by Linscott, Law & Greenspan Engineers in compliance with the City of Santa Ana Traffic Impact Study Guidelines (dated September 2019) (refer to Attachment H1), which was confirmed in writing by the Director of Public Works, Zdenek Kekula, on August 22, 2023 (refer to Attachment H2).
PROJECT SCREENING CRITERIA
Project screening is used to determine if a project will be required to conduct a detailed VMT analysis. The following section discusses the various screening methods outlined in the City of Santa Ana Traffic Impact Study Guidelines (dated September 2019), and outlines whether the Project will screen out, either in its entirety or partially, based on individual land uses.
The City of Santa Ana Traffic Impact Study Guidelines states that several types of projects can be screened out from a VMT assessment using the criteria below, indicating that these projects have the potential to reduce VMT per service population (VMT/SP) and result in a less-thansignificant transportation impact:
• Projects which serve the local community and have the potential to reduce VMT, such as neighborhood K-12 schools and local-serving retail less than 50,000 square feet (Charter schools are excluded from this criteria).
Based on the above, the Project’s retail component will screen out since it has local-serving retail of less than 50,000 square feet.
• Projects that generate less than 110 net daily trips.
Based on the above and as presented in Table 18, the Project will not screen out since it will generate more than 110 net daily trips.
• Projects located within TPA or HQTA. Appendix A of the City of Santa Ana Traffic Impact Study Guidelines (dated September 2019) presents the transit priority areas in the City.
Due to the many high quality transit routes in the City, much of the City is a transit priority area.
o TPA are defined as a ½ mile radius around an existing or planned major transit stop (e.g., Metrolink Station, Streetcar Station, etc.) or an existing stop along a high quality transit corridor.
o HQTAs are defined as a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours. A map of HQTAs can be reviewed on SCAG’s website.
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o Projects that are in TPAs will also be required to complete a secondary screening step to verify the proposed project’s consistency with the assumptions from the RTP/SCS. This consistency can be a land use review (e.g., are the proposed land uses already included in the RTP/SCS) or can be reviewed from a VMT/SP perspective (e.g., does the resulting land use increase or decrease the VMT/SP in the Traffic Analysis Zone (TAZ) compared to the RTP/SCS assumptions).
Table 18
Project Traffic Generation Rates and Forecast
Description Daily AM Peak Hour PM Peak Hour
2 Way Enter Exist Total Enter Exit Total
Trip Rates
215: Single Family Attached Housing
221: Multifamily Housing – Mid-Rise
710: General Office Building
7.20 4.54
10.84 54.45
31%
23%
88%
60%
69%
77%
12%
40%
0.48 0.37
1.52 2.36
57%
61%
17%
50%
43% 0.57
39% 0.39
83% 1.44
822: Strip Retail Plaza (40k) 50% 6.59
Existing Land Use Trip Generation
Cabrillo Park Drive and E. 4th Office 1,876
Buildings (173,025 sf)
231 32 263 42 207 249
Project Trip Generation
Cabrillo Town Center Apartments (449 du) 2,038
316
124
38 8
15 9
128
6 2
166
14 17
107
19 3
68 19
13 14
175
38 16
Cabrillo Town Center Retail (5,800 sf)
Cabrillo Town Center L/W Commercial (11,400 sf)
Cabrillo Town Center Townhomes (58 du) 418 16 28 19 33
Total Project Trip Generation 2,896
Internal Trip Capture (5%) -145
70 -4
155
-8
225
-12
148
-7
114
-6
262
-13
Adjusted Project Trip Generation 2,751
Less Existing Trips -1,876
66 -231
-165
147
-32
115
213
-263
-50
141
-42
99 108
-207 -249
-99
249
Net Project Trips 875 0
sf = square feet du = dwelling unit
Source: LLG, 2023. Refer to Attachment H1.
Based on existing conditions and SCAG data, the Project Site is located within a HQTA (i.e., half a mile from a bus stop located on a single High Quality Transit Corridor [HQTC], defined as a corridor with 15-minute peak hour service or better). Specifically, OCTA Route 64 qualifies as a HQTC because it is a fixed route bus service with service intervals no longer than 15 minutes during peak commute hours (refer to Attachment H3 for OCTA Routh 64 schedule). There are eight OCTA Route 64 stops located within a ½ mile of the Project.
Further, as discussed above, the proposed land uses are consistent with the 2020-2045 RTP/SCS. The Project is consistent with the land uses in the 2020-2045 RTP/SCS, which assumed the Project Site would be constructed as an urban, mixed-use development that would reduce area VMT, consistent with the TPA designation. The 2020-2045 RTP/SCS recognizes that development within Priority Growth Areas, including TPAs, supports mode shift and shortened trip distances. The Project Site is within an identified Priority Growth Area, where urban development can contribute to reduced VMT and associated emissions. The District Center Cabrillo Town Center City of Santa Ana
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designation permits broad use types, including commercial, retail, hospitality, residential, and office uses that facilitate high-intensity development with an urban character. The Project proposes diverse uses consistent with those permitted by the General Plan – residential, and local serving retail and commercial uses – and would implement development to achieve an urban character and is consistent with the land uses assumed for the project site as part of the 2020- 2045 RTP/SCS.
In addition, the Project's consistency has been evaluated with applicable goals and policies of the City's General Plan Circulation Element, including:
•
•
•
•
Policy 1.1: Coordinate transportation improvements in a manner which minimizes disruptions to the community.
Policy 1.3: Utilize advance technology to improve traffic flow and minimize the need for land acquisition.
Policy 1.4: Maintain at least a level of service “D” on arterial street intersections, except in major development areas.
Policy 1.6: Improve intersection capacity on major arterials to accommodate increased traffic demands.
•
•
Policy 2.7: Continue design practices which facilitate the safe use of circulation systems.
Policy 3.1: Support the efforts of regional, state, and federal agencies to enhance local and express bus services.
• Policy 3.2: Support programs which complement bus and rail services for specialized transit needs.
•
•
Policy 3.3: Support the expansion of commuter rail services.
Policy 3.4: Encourage the development of multi-modal transit opportunities within major development areas.
• Policy 3.5: Enhance sidewalks and pedestrian systems to promote their use as a means of travel.
Furthermore, the 2020-2045 RTP/SCS integrates strategies for land use and transportation centered around sustainability, protecting and preserving existing transportation infrastructure, increasing capacity through improved systems managements, and providing more transportation choices, in order to help reduce GHG emissions from transportation. The City’s General Plan consistency, and thus the Project’s consistency, with the 2020-2045 RTP/SCS can be evaluated based on the following applicable goals:
•
•
RTP/SCS G1: Encourage regional economic prosperity and global competitiveness.
RTP/SCS G2: Improve mobility, accessibility, reliability, and travel safety for people and goods.
•
•
RTP/SCS G3: Enhance the preservation, security, and resilience of the regional transportation system.
RTP/SCS G4: Increase person and good movement and travel choices within the transportation system.
•
•
RTP/SCS G5: Reduce greenhouse gas emissions and improve air quality.
RTP/SCS G6: Support healthy and equitable communities.
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•
•
RTP/SCS G7: Adapt to a changing climate and support an integrated regional development pattern and transportation network.
RTP/SCS G8: Leverage new transportation technologies and data driven solutions that result in more efficient travel.
Hence, given the above, the Project would screen out of a full VMT analysis even if required since it is within a TPA/HQTA, where existing transit service provided by OCTA provides service intervals no longer than 15 minutes during the peak commute hours.
CONCLUSION
A VMT analysis is only required prospectively for CEQA documents circulated for public review after implementation of CEQA Guidelines Section 15064.3(b). As the Certified EIR predated the implementation of the VMT requirements outlined in Senate Bill 743 and CEQA Guideline Section 15064.3(b), a VMT analysis was not included in the Certified EIR. Further, the CEQA findings associated with the Project will not be circulated for public review. Therefore, a VMT analysis is not required for the Project, and the determination of consistency with the Certified EIR is based on the LOS discussion above. Nevertheless, a VMT analysis has been produced for informational purposes only in response to public comments received on the topic , which, although legally not required, demonstrates that, consistent with the City of Santa Ana Traffic Impact Study Guidelines (dated September 2019) and based on the VMT screening methodology and findings outlined in the Screening Memorandum (refer to Attachment H1), the Project would not result in VMT impacts even if required due to (1) the Project Site’s location within a TPA/HQTA (i.e., within ½ mile of the 8 bus stop along OCTA Route 64 that has a 15-minute peak-hour service (refer to Attachment H3), and (2) the Project’s consistency with the 2020-2045 RTP/SCS.) Conflict with Transit, Bicycle, and Pedestrian Facilities Plans The Project would implement Mitigation Measure MM-OZ 4.12-1, which requires transit-related improvements. Thus, the Project would not result in any new or increased significant impacts related to conflict with transit, bicycle, and pedestrian facilities plans beyond impacts already identified in the Certified EIR.
Design Hazards
In compliance with Mitigation Measure MM-OZ 4.12-2, the Project has prepared a site-specific traffic study prepared by a qualified traffic engineer that analyzes the potential traffic impacts consistent with the methodology in the Certified EIR (refer to Attachment G). The Project traffic study analyzes the Project Site’s access and internal circulation. Additionally, a sight distance analysis was prepared for the Project by Linscott, Law & Greenspan Engineers, which shows that the Project driveway is expected to be adequate (refer to Attachment I). Thus, the Project would not result in any new or increased significant impacts related to a design hazard beyond impacts already identified in the Certified EIR.
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Emergency Access
The Project would implement MM-OZ 4.6-7, requiring coordination with the City Fire Department in preparation of an Emergency Preparedness Plan. Thus, the Project would not result in any new or increased significant impacts related to emergency access beyond impacts already identified in the Certified EIR.
Mitigation Measures
The Project would implement Mitigation Measures MM-OZ 4.4.12-1, MM-OZ 4.4.12-2, MM-OZ
4.4.12-4 and MM-OZ 4.6-7 from the Certified EIR, including the following specific improvements identified in the site-specific traffic study prepared for the Project in accordance with Mitigation Measure MM 4.12-2:
Cabrillo Park Drive/Fourth Street: Widen and provide the additional right-of-way required to construct an exclusive westbound right-turn lane with 125-feet of storage and 90-feet transition.
Modify the existing traffic signal as necessary.
SR 55 SB Ramps at Fourth Street: Modify the eastbound shared through/right-turn lane to construct a free-right turn lane. Modify the existing traffic signal as necessary. This improvement is subject to the review and approval of the City of Santa Ana, City of Tustin and/or Caltrans.
SR 55 NB Ramps at Fourth Street: Modify the eastbound approach to provide dual left-turn lanes and two through lanes. Modify the existing traffic signal as necessary. This improvement is subject to the review and approval of the City of Santa Ana, City of Tustin and/or Caltrans.
4.16.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to transportation have occurred, and no substantial new significant traffic sources have been identified within the vicinity of the Project since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
4.16.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance that has become available relative to transportation that would result in new or more severe significant environmental impacts related to transportation.
4.16.5 Mitigation Measures Addressing Impacts
The Project would implement Mitigation Measures MM-OZ 4.4.12-1 and MM-OZ 4.6-7 from the Certified EIR.
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4.16.6 Conclusion
Based on the above, no new significant transportation impacts or a substantial increase in previously identified transportation impacts would occur as a result of the Project. Therefore, the impacts to transportation do not meet the standards for a subsequent or supplemental EIR pursuant to PRC Section 21166 and CEQA Guidelines Section 15162.
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4.17 Tribal Cultural Resources
Any Substantial
Changes
Any Substantially
Changed
Involving New
Significant
Circumstances
Involving New Any New
Impacts or Significant Impact Information Project
Impact
Determination
in EIR
Substantially
More Severe
Impacts?
or Substantially
More Severe
Impacts?
of Incorporates
Mitigation
Measure(s)?
Issues (and supporting Information
Sources)
Substantial
Importance
TRIBAL CULTURAL RESOURCES: Would
the project:
(a) Would the project cause a
substantial adverse change in
the significance of a tribal
cultural resource, defined in
Public Resources Code
section 21074 as either a site,
feature, please, cultural
landscape that is
geographically defined in
terms of the size and scope of
the landscape, sacred place,
or object with cultural value to
a California Native American
tribe, and that is:
(i) Listed or eligible for listing in
the California Register of
Historical Resources, or in the
local register of historical
resources as defined in Public
Resources Code Section
5020.1(k)? NA NA NA NA NA
(ii) A resource determined by the
lead agency in its discretion
and supported by substantial
evidence, to be significant
pursuant to criteria set forth in
subdivision (c) of Public
Resources Code Section
5024.1. In applying the criteria
set forth in subdivision (c) of
Public Resources Code
Section 5024.1, the lead
agency shall consider the
significance of the resource to
a California Native American
tribe? NA NA NA NA NA
4.17.1 Impact Determination in the EIR
Tribal cultural resources was not a topic in the 2006 CEQA Guidelines. Thus, the Certified EIR did not include an analysis of tribal cultural resources impacts.
Mitigation Measures
Not applicable.
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4.17.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
Assembly Bill (AB) 52 went into effect on July 1, 2015, and requires that for a project for which a Notice of Preparation (NOP) for a Draft EIR was filed on or after July 1, 2015, the lead agency is required to consult with a California Native American tribe that is traditionally and culturally affiliated with the geographic area of a proposed project, if: (1) the tribe requested to the lead agency, in writing, to be informed by the lead agency of proposed projects in that geographic area; and (2) the tribe requests consultation, prior to the release of a negative declaration, mitigated negative declaration or environmental impact report for a project. The NOP for the Certified EIR was released on March 10, 2006, and as such, the lead agency was not required to comply with the requirements of AB 52. The Final Certified EIR was released in 2007, and thus, did not include responses to the updated Appendix G questions related to tribal cultural resources.
AB 52 tribal consultation is also only required prior to the release of a negative declaration, mitigated negative declaration, or environmental impact report. Because the Project relies on the Certified EIR as a later activity, no negative declaration, mitigated negative declaration, or environmental impact report will be released. Therefore, AB 52 tribal consultation is not required for the Project.
The Certified EIR stated that according to the City of Santa Ana Land Use Element EIR, an archaeological records search at the UCLA Institute of Archaeology indicated there is a single recorded prehistoric site within the City. The site, near Santiago Creek in the northwest section of the City, contained grinding stones and was disturbed by the development of a residential subdivision in 1965. An additional six prehistoric sites are located within one mile of the City boundaries. Eighteen post contact (following European contact) archaeological sites have also been identified in the City. None of these known archaeological resources occur within the Overlay Zone boundaries. However, the presence of historic and archaeological sites in the City indicates that the City (including the Overlay Zone) has a potential for archaeological and historical resources and the resources of prehistoric and historic cultures may still be intact beneath existing developments.
An archival records search for known archaeological sites was made at the SCCIC for a study area encompassing the Overlay Zone and an additional ½-mile “buffer zone” beyond the Overlay Zone boundaries. No archaeological sites have been identified within the Overlay Zone or within the 0.5-mile radius beyond the Overlay Zone included in the study area. This does not preclude the potential for archaeological sites to be identified during future ground-disturbing construction activities.
Further, it should be noted that the Native American Heritage Commission was consulted with regard to the Overlay Zone, and no known Native American cultural resources are known to occur in the area.
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The Certified EIR concluded that implementation of the Overlay Zone has the potential to cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5 of the CEQA Guidelines, but implementation of Mitigation Measures MM-OZ 4.4- 2 through MM-OZ 4.4-4 that require monitoring by a qualified archaeologist during any grounddisturbing activities below 10 feet below ground surface, evaluation of any uncovered resources, and coordination with the County Coroner and the NAHC if human remains are uncovered would ensure that impacts related to unknown archaeological resources, including tribal cultural resources, will be less than significant.
As discussed previously in this document, the Project would include excavation beyond 10 feet below ground surface and would be required to implement Mitigation Measures MM-OZ 4.4-2 and MM-OZ 4.4-3, requiring construction monitoring by a qualified archeologist and certain actions in the event that a potential resource is encountered during Project construction. Thus, the Project would not result in any new or increased significant impacts related to archaeological resources, including tribal resources, beyond impacts already identified in the Certified EIR.
Mitigation Measures
Not applicable.
4.17.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to tribal cultural resources have occurred, and no substantial new sources of tribal cultural resources have been identified within the vicinity of the Project since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
4.17.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance which has become available relative to tribal cultural resources that would result in new or more severe significant environmental impacts.
4.17.5 Mitigation Measures Addressing Impacts
Not applicable.
4.17.6 Conclusion
Based on the above, no new significant tribal cultural resources or a substantial increase in previously identified tribal cultural resources would occur as a result of the Project. Therefore, the impacts to tribal cultural resources do not meet the standards for a subsequent or supplemental EIR pursuant to PRC Section 21166 and CEQA Guidelines Section 15162.
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4.18 Utilities and Service Systems
Any Substantial Any Substantially
Changes
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Changed
Circumstances
Involving New Any New
Significant Impact Information Project
Incorporates
Mitigation
Impact or Substantially
More Severe
Impacts?
of
Issues (and supporting
Information Sources)
Determination
in EIR
Substantial
Importance? Measure(s)?
UTILITIES AND SERVICE SYSTEMS:
Would the project:
(a) Require or result in the
relocation or construction of
new or expanded water,
wastewater treatment or
storm water drainage, electric
power, natural gas, or Less Than
Significant No No No No
telecommunications facilities
or expansion of existing
facilities, the construction of
which could cause significant
environment effects?
(b) Have sufficient water supplies
available to serve the project
and reasonably foreseeable
future development during
normal, dry, and multiple dry
years?
Less Than
Significant No
No
No
No
No
No
No
No
(c) Result in a determination by
the wastewater treatment
provider which serves or may
serve the project that it has
adequate capacity to serve
the project’s projected
Less Than
Significant
demand in addition to the
provider’s existing
commitments?
(d) Generate solid waste in
excess of State or local
standards, or in excess of the
capacity of local Less Than
Significant No
No
No
No
No
No
No
No
infrastructure, or otherwise
impair the attainment of solid
waste reduction goals?
(e) Comply with federal, state
and local management and
reduction statutes and
regulations related to solid
waste?
Less Than
Significant
4.18.1 Impact Determination in the EIR
Water Treatment
The Certified EIR stated that the City’s imported surface water supply is primarily treated at the Metropolitan Water District (MWD) Diemer Filtration Plant, located in Yorba Linda, with a treatment capacity of approximately 520 million gallons per day of water (MGD,) flowing at an average of 140 MGD in the winter (27 percent capacity) and 375 MGD in the summer (72 percent capacity). In addition to Diemer-treated imported water, the City also receives potable water from Cabrillo Town Center City of Santa Ana
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MWD’s Weymouth Filtration Plant, which operates at approximately 42 percent capacity during the winter and 65 percent capacity during the summer. Additional development accommodated under the Overlay Zone would increase water use within the City, thus increasing the need for water treatment services. As discussed above, MWD can meet 100 percent of the City’s imported water needs until at least the year 2030. Beyond that date, improvements associated with the State Water Project supply, additional local projects, water conservation, and additional water transfers may be needed to adequately serve the City. The Orange County Water District (OCWD), which provides the groundwater supply to the City, anticipates that there would be sufficient groundwater supplies to meet projected future demand requirements in Santa Ana.
Implementation of the Overlay Zone would not require or result in the construction of new water treatment facilities or the expansion of existing facilities, and impacts would be less than significant. No mitigation is required.
Wastewater Treatment
Implementation of the Overlay Zone would generate additional demand on the existing sewer system from increased sewage flows. New residential, commercial and office growth would generate wastewater that would require treatment. As described in the Existing Conditions section, wastewater service within the Overlay Zone area is provided by the City and the Orange County Sanitation District (OCSD). Wastewater from the City’s system and OCSD is treated by the OCSD at their two treatment plants. The OCSD Treatment Plant No. 1 maintains a design capacity of 174 mgd and treats on average a flow of 90 mgd. Treatment Plant No. 2 maintains a design capacity of 276 mgd and treats on average a flow of 153 mgd. Plant No. 1 and Plant No. 2 are operating at 52 percent and 55 percent of design capacity, respectively. Therefore, each of the treatment plants serving the City is operating below their design capacity.
The additional 1.106 mgd of wastewater, as stated above under Impact 4.13-4, would be distributed between OCSD Treatment Plant No. 1 and Treatment Plant No. 2. Each of these plants has the capacity to treat the full increase in sewage from the Overlay Zone. To illustrate the most conservative analysis, if the entire Overlay Zone’s wastewater went to Treatment Plant No. 1, its average flow would increase to approximately 91 mgd, an increase of 1.1 percent, and the plant would still operate below its design capacity. If the entire City’s sewage were directed to Treatment Plant No. 2, its average flow would increase to approximately 154 mgd, an increase of 0.6 percent, and the plant would operate below its design capacity. Because increased wastewater due to implementation of the proposed General Plan Update could be accommodated within the existing treatment infrastructure, expansion would not be required. Therefore, impacts to the wastewater treatment facilities associated with increased growth in the City would be less than significant, and no mitigation is required.
OCSD maintains certain trunk sewer lines that may require expansion on an as needed basis due to incremental increases in sewage generation as a result of a new development. The City would also maintain local sewer lines and upgrades as part of individual projects. Implementation of Mitigation Measure MM-OZ 4.13-1 would ensure that any new development within the Overlay Zone does not result in an exceedance of an existing sewer conveyance capacity for City and OCSD facilities, and impacts would be less than significant.
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Storm Water Drainage
The Certified EIR stated that adherence to Mitigation Measure MM-OZ 4.7-1 would require the preparation of a WQMP and implementation of appropriate BMPs, which could incorporate stormwater detention facilities, and would reduce the volume of runoff generated (and potential for flooding) in the Overlay Zone. However, because the existing capacity of the existing storm drain system in the Overlay Zone is unknown, this is considered a potentially significant impact.
Implementation of Mitigation Measure MM-OZ 4.7-2 would be required to address these issues.
Water Supply
The Certified EIR stated that domestic water for the Overlay Zone is supplied by both groundwater and imported surface water sources, as discussed above. A majority of water supplied to the Overlay Zone is supplied by groundwater from the Basin. Specifically, approximately 69 percent of the water supplied by the City’s service area is supplied by groundwater from the Basin, and the remaining 31 percent of water supply is provided by MWD. Implementation of the proposed General Plan Update would increase the population and amount of development within the City, which in turn would increase the demand for water supplies.
The Overlay Zone would allow a maximum of 6,661,489 square feet of residential, 3,410,507 square feet of office space and 1,275,440 square feet of commercial space at completion. A Water Supply Assessment was done by Dudek to assess the water demand and supply conditions for the Overlay Zone area.
According to the WSA provided as Appendix I to the Certified EIR, analysis of water supply projections for the City demonstrates that projected supplies will exceed demand through the year 2030. These projections consider land use based on the Metro East Mixed-Use Zone development intensities; projections from the City’s 2005 UWMP; water development programs and projects; and water conservation. Analysis shows that groundwater and imported water are anticipated to remain stable to the City, based on studies and reports of the Orange County Water District (OCWD) and the Metropolitan Water District of Southern California (Metropolitan), respectively. The 20-year projection, and beyond, of water demand will be met by approximately 70 percent groundwater, based on an expected long-term Basin Production Percentage (BPP), and 30 percent imported water confirmed reliable by Metropolitan. Additionally, analysis of normal, single-dry, and multiple-dry year scenarios also demonstrate the City’s ability to meet or exceed demand during the 20-year planning period, even under reduced imported water supply conditions. Additionally, the City has the opportunity to increase supply to meet demand, if extraordinary circumstances require, through the following measures: 1) production of groundwater above the BPP up to the basin safe yield; 2) increasing imported water purchases; and 3) increased water conservation measures. Reliability of future water supplies to the region will be ensured through continued implementation of the local agency programs, OCWD’s LongTerm Facilities Plan, and the combined efforts and programs among member agencies of Metropolitan, such as the Integrated Resources Plan (IRP) and proposed Capital Improvement Program. Agencies include all water wholesalers and retailers, the Orange County Sanitation Cabrillo Town Center City of Santa Ana
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District (OCSD), the Santa Ana Regional Water Quality Control Board (RWQCB), and the Santa Ana Watershed Project Authority (SAWPA). Collectively, the information included in this Water Supply Assessment identifies a sufficient water supply and reliability to the City, now and into the future, including a sufficient water supply for the Overlay Zone.
Also, the expansion of the existing network of water lines will not be required for the purpose of the project. The existing network would ensure continuous water supply with adequate volume and pressure and quality at all times to the Overlay Zone. However, should improvements to the existing water system be required or additional facilities be deemed necessary, the property developer would be required to pay its fair share of the cost of all or portions of the needed improvements. Thus, the impact of the Project on water services would be less than significant.
No mitigation measures would be required.
Electricity/Natural Gas
The Certified EIR stated that in peak days, the increase in demand from implementation of future development under the Overlay Zone would contribute to electricity supply and delivery constraints. However, all future development would be constructed in compliance with Title 24 energy efficiency standards.
By the time future development would be constructed under the Overlay Zone, it is expected that some steps outlined in the CEC action plan will have been implemented to alleviate energy constraints. If these constraints do remain, they could be addressed through “rolling blackouts,” which are limited to specific geographic areas for a period of hours. Further, if energy constraints remain, they are a reflection of the broad energy supply issues experienced by California as a whole, and not unique to the demands of the development in the City.
Further, the CEC licensed two additional power plants in 2001 that were anticipated to provide California with electrical energy supply capacity and the ability to meet peak load demand in excess of forecasts of regional energy supplies. Consequently, although the Overlay Zone would result in an increased electricity demand in the City, additional energy demands resulting from the Overlay Zone would be adequately met by current and planned infrastructure during most of the year. Further, development under the Overlay Zone would be required to comply with the energy conservation measures contained in Title 24, which would reduce the amount of energy needed for the operation of any buildings constructed as a part of the Overlay Zone.
Additionally, the current electrical demand of the Overlay Zone is within the capacity limitations of the electrical facilities serving the City. Excluding any unforeseen problems, existing distribution resources have the ability to serve all existing customer loads in accordance with its rules and tariffs. The projected electrical demand of the Overlay Zone area and for build-out under the Overlay Zone is expected to be within SCE’s current 10-year load forecasts. Though SCE’s total system demand is expected to continue to increase annually, excluding any unforeseen problems, SCE’s plans for new distribution resources would be adequate to serve all existing and new customer loads throughout the next decade. SCE does not expect that utilities deregulation will Cabrillo Town Center City of Santa Ana
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207 City Council 18 – 641 10/3/2023
affect service to the Overlay Zone area. However, to reduce any potential impacts associated with build out of the Overlay Zone, SCE recommends the use of energy-efficient and high-performance design for nonresidential and residential building design and construction.
SCGC declares itself a “reactive” utility and will provide natural gas as customers request its services. SCGC has also indicated that an adequate supply of natural gas is available to serve additional development, and that the natural gas level of service provided to the City would not be impaired by buildout under the Overlay Zone. Any expansion of service necessitated by implementation of the Overlay Zone would be in accordance with SCGC’s policies and extension rules on file with the California Public Utilities Commission at the time contractual agreements are made.
Although the Overlay Zone would result in the energy demand increases in demand noted above, an adequate energy supply is anticipated to be available, as the electrical and gas supplies and infrastructure to support demand are provided as needed by SCE and SCGC. Therefore, the Overlay Zone would not substantially increase demands beyond the available supply. In case of electricity, the cost associated with relocating the facilities, if required shall be borne by the developer. The developer will also be required to make contractual arrangements with SCGC prior to initiation of construction for the gas. Prior to the issuance of grading permits, the project developer shall coordinate with SCE/SCGC to determine the exact location of all underground and overhead electrical/gas facilities. All electrical/gas facilities and associated structures left on the site shall be protected from damage. Grading plans should reflect the undergrounding of utility lines serving the project
The project-generated demand for electricity and natural gas would be negligible in the context of overall demand within the City of Santa Ana and the state and thus is not anticipated to require substantial upgrades or expansion of existing energy systems. Though the project would not increase the energy demand significantly, mitigation measures are suggested to promote conservation of energy to further reduce the impact.
Implementation of Mitigation Measure MM-OZ 4.13-2 would foster efficient energy use and ensure that a less than significant impact remains with respect to energy.
Solid Waste
The Certified EIR stated that based on the existing uses, the Overlay Zone generates a total of
9.54 tons of waste every day. The entire waste generated is hauled to the Frank R. Bowerman Landfill. The solid waste generation of the Overlay Zone is expected to increase by 15.62 tons/day or 164 percent compared to existing conditions. However, the amount signifies less than one percent of the existing maximum permitted capacity of 8,500 tons per day of the landfill.
Compliance with the City’s recycling program would further reduce long-term solid waste disposal service impacts. Thus, the project would have a less than significant impact on the landfill capacity. No mitigation is required.
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Additionally, the California Integrated Waste Management Act of 1989 (AB 939) requires that local jurisdictions divert at least 50 percent of all solid waste generated by January 1, 2000. Per the City Program, individual projects within the Overlay zone would be required to comply with the Source Reduction and Recycling Element (SRRE) program for diverting the solid waste. The City already diverts 60 percent of its solid waste generated and is well above the compliance levels.
Under the SRRE program, implementation of the Overlay Zone would be consistent with AB 939 as well. Thus, a less-than- significant impact would occur. No mitigation is required.
Mitigation Measures
MM-OZ 4.13-1 The developer is required to undertake a site-specific sewer evaluation, including flow monitoring required as part of the project design to determine the adequacy of the existing sewer pipe capacity in the affected project area lines.
MM-OZ 4.13-2 The project shall implement energy conservation measures (such as energyefficient lighting and micro-processor-controlled HVAC equipment) to reduce the demand for electricity and natural measures shall be subject to modification as new technologies are developed or if current technology becomes obsolete through replacement.
4.18.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project includes the demolition and removal of all existing improvements from the Project Site and development of the site with a mixed-use development including up to 507 residential dwelling units, approximately 26,800 square feet of commercial uses, and associated parking, utility infrastructure, landscaping, and open space, all of which is allowed under the Overlay Zone, and is consistent with the Overlay Zone standards. The Project does not include any development that would extend beyond the permitted uses, density, and intensity or building envelope considered in the Certified EIR, and no changes are proposed to the Overlay Zone to accommodate the Project. The Project’s water demand is within the envelope of projected water usage analyzed as part of the WSA conducted for the Certified EIR that concluded the uses and development density and intensity proposed within the Overlay Zone could be adequately served by the water purveyor. As discussed below, the Project would incorporate mitigation measures to further minimize impacts related to utilities and service systems, and accordingly, would not result in any new or increased significant impacts beyond those already identified in the Certified EIR.
The Project’s water and wastewater treatment requirements have been accounted for in the Certified EIR. The Project would be required to implement MM-OZ 4.7-2, which requires preparation of a Hydrology and Hydraulic Study to ensure the existing storm drain capacity could accommodate the Project. Further, the Project’s energy consumption and solid waste generation has also been accounted for in the Certified EIR. Thus, the Project would not result in any new or increased significant impacts related to utilities and service systems beyond impacts already identified in the Certified EIR.
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Finally, in the Project Site area, existing telephone service is typically provided by AT&T, and existing cable television/internet is typically provided by Spectrum (formerly Time Warner Cable).
The Project Site could be served by existing telecommunications facilities that are available in the Project Site area and would not require new or expanded facilities. Therefore, Project impacts related to telecommunications facilities would be less than significant.
4.18.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to utilities and service systems have occurred within the vicinity of the Project since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
4.18.4 Any new information of substantial importance that demonstrates that the Project would result in new significant impacts or substantial increase in the severity of significant impacts?
There is no new information of substantial importance that has become available relative to utilities and service systemsthat would result in new or more severe significant environmental impacts related to utilities.
4.18.5 Mitigation Measures Addressing Impacts
The Project would implement Mitigation Measures MM-OZ 4.13-1 and MM-OZ 4.13-2 from the Certified EIR.
4.18.6 Conclusion
Based on the above, no new significant utilities and service system impacts or a substantial increase in previously identified utility impacts would occur as a result of the Project. Therefore, the impacts on utilities and service systems do not meet the standards for a subsequent or supplemental EIR pursuant to CEQA Guidelines Section 15162.
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4.19 Wildfire
Any Substantial Any Substantially
Changes
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Changed
Circumstances
Involving New Any New
Significant Impact Information Project
Incorporates
Mitigation
Impact
Determination
in EIR
or Substantially
More Severe
Impacts?
of
Issues (and supporting Information
Sources)
Substantial
Importance? Measure(s)?
WILDFIRE: If located in or near state
responsibility areas or lands classified
as very high fire hazard severity
zones, would the project:
(a) Substantially impair an
adopted emergency No Impact
No Impact
No
No
No
No
No
No
No
No
response plan or emergency
evacuation plan?
(b) Due to slope, prevailing
winds, and other factors,
exacerbate wildfire risks,
and thereby expose project
occupants to, pollutant
concentrations from a
wildfire or the uncontrolled
spread of a wildfire?
(c) Require the installation or
maintenance of associated
infrastructure (such as
roads, fuel breaks,
emergency water sources,
power lines or other utilities)
that may exacerbate fire risk
or that may result in
No Impact No No No No
temporary or ongoing
impacts to the environment?
(d) Expose people or structures
to significant risks, including
downslope or downstream
flooding or landslides, as a
result of runoff post-fire
slope instability, or drainage
change?
No Impact No No No No
4.19.1 Impact Determination in the EIR
The Certified EIR stated that the Overlay Zone is located in a dense urban environment and is surrounded by existing development. There are no wildland areas, nor wildland interface areas, located in the project vicinity. Consequently, no wildland fires would affect, or be affected by, implementation of the Project. Therefore, no impacts would occur.
Mitigation Measures
None required or identified.
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4.19.2Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
The Project Site is located in a dense urban environment and is surrounded by existing development. There are no wildland areas, nor wildland interface areas, located in the vicinity of the Project Site. The Project site is also not located within a Very High Fire Hazard Severity Zone or a State Responsibility Area. Thus, the Project would not result in any new or increased significant impacts related to wildland fires beyond impacts already identified in the Certified EIR.
Mitigation Measures
None required.
4.19.3 Any substantial changes in circumstances involving new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR?
No substantial changes in the circumstances related to wildfire have occurred, and no substantial new sources or wildfire have been identified within the vicinity of the Project since the certification of the Certified EIR that would result in new or more severe significant environmental impacts.
4.19.4 Any New Information of Substantial Importance?
There is no new information of substantial importance which has become available relative to wildfire that would result in new or more severe significant environmental impacts.
4.19.5 Mitigation Measures Addressing Impacts
None required.
4.19.6 Conclusion
Based on the above, no new significant wildfire impacts or a substantial increase in previously identified wildfire impacts would occur as a result of the Project. Therefore, the impacts to wildfire do not meet the standards for a subsequent or supplemental EIR pursuant to CEQA Guidelines Section 15162.
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AIR QUALITY TECHNICAL REPORT
Introduction
This technical report addresses the air quality impacts generated by construction and operation of the proposed Cabrillo Town Center project in the City of Santa Ana. The analysis evaluates the consistency of the Project with the air quality policies set forth within the South Coast Air Quality Management District’s (SCAQMD) Air Quality Management Plan (AQMP) and the City’s General Plan. The analysis of Project-generated air emissions focuses on whether the Project would cause an exceedance of an ambient air quality standard or SCAQMD significance threshold. Calculation worksheets, assumptions, and model outputs used in the analysis are included in the Technical Appendix to this analysis.
Regulatory Framework
Federal
The Federal Clean Air Act (CAA) was first enacted in 1955 and has been amended numerous times in subsequent years, with the most recent amendments in 1990. At the federal level, the United States Environmental Protection Agency (USEPA) is responsible for implementation of some portions of the CAA (e.g., certain mobile source and other requirements). Other portions of the CAA (e.g., stationary source requirements) are implemented by state and local agencies. In California, the CCAA is administered by the California Air Resources Board (CARB) at the state level and by the air quality management districts and air pollution control districts at the regional and local levels.
The 1990 amendments to the CAA identify specific emission reduction goals for areas not meeting the National Ambient Air Quality Standard (NAAQS). These amendments require both a demonstration of reasonable further progress toward attainment and incorporation of additional sanctions for failure to attain or to meet interim milestones. The sections of the CAA which are most applicable to the Project include Title I (Nonattainment Provisions) and Title II (Mobile Source Provisions).
NAAQS have been established for seven major air pollutants: CO (carbon monoxide), NO2 (nitrogen dioxide), O3 (ozone), PM2.5 (particulate matter, 2.5 microns), PM10 (particulate matter, 10 microns), SO2 (sulfur dioxide), and Pb (lead).
The Clean Air Act (CAA) requires the USEPA to designate areas as attainment, nonattainment, or maintenance (previously nonattainment and currently attainment) for each criteria pollutant based on whether the National Ambient Air Quality Standards (NAAQS) have been achieved. Title I provisions are implemented for the purpose of attaining NAAQS. The federal standards are summarized in Table 1.
The USEPA has classified Orange County as a nonattainment area for O3, PM2.5, and Pb.
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Table 1
State and National Ambient Air Quality Standards and Attainment Status for LA County California
Attainment Status
Federal
Attainment Status
Averaging
Pollutant Period Standards Standards
0.09 ppm
(180 µg/m3)
1-hour
8-hour
Non-attainment
N/A1
-- --
Ozone (O3)
0.070 ppm
(137 µg/m3)
0.070 ppm
(137 µg/m3)
Non-attainment
24-hour 50 µg/m3
20 µg/m3
Non-attainment
Non-attainment
150 µg/m3
--
Maintenance
--
Respirable
Particulate Matter
(PM )
Annual Arithmetic
10 Mean
24-hour -- -- 35 µg/m3
12 µg/m3
Non-attainment
Non-attainment
Fine Particulate
Annual Arithmetic
Mean
Matter (PM2.5) 12 µg/m3 Non-attainment
20 ppm 35 ppm
1-hour
8-hour
Attainment
Attainment
Maintenance
Maintenance
Carbon Monoxide
(CO)
(23 mg/m3) (40 mg/m3)
9.0 ppm 9 ppm
(10 mg/m3) (10 mg/m3)
0.18 ppm
(338 µg/m3)
0.030 ppm
(57 µg/m3)
100 ppb
(188 µg/m3)
53 ppb
1-hour Attainment
Attainment
Maintenance
Maintenance
Nitrogen Dioxide (NO2
)
Annual Arithmetic
Mean (100 µg/m3
)
0.25 ppm
(655 µg/m3)
0.04 ppm
75 ppb
1-hour Attainment
Attainment
Attainment
--
(196 µg/m3)
Sulfur Dioxide (SO2)
Lead (Pb)
24-hour -- (105 µg/m3
)
30-day average 1.5 µg/m3
--
Attainment
--
-- --
Calendar Quarter 0.15 µg/m3 Non-attainment
Extinction of
0.07 per
kilometer
Visibility Reducing
Particles 8-hour N/A No Federal Standards
Sulfates 24-hour
1-hour
25 µg/m3 Attainment
Unclassified
N/A
No Federal Standards
No Federal Standards
No Federal Standards
Hydrogen Sulfide
(H2S)
0.03 ppm
(42 µg/m3)
0.01 ppm
(26 µg/m3)
Vinyl Chloride 24-hour
1N/A = not available
Source: CARB, Ambient Air Quality Standards, and attainment status, 2020 (www.arb.ca.gov/desig/adm/adm.htm).
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CAA Title II pertains to mobile sources, such as cars, trucks, buses, and planes. Reformulated gasoline and automobile pollution control devices are examples of the mechanisms the USEPA uses to regulate mobile air emission sources. The provisions of Title II have resulted in tailpipe emission standards for vehicles, which have been strengthened in recent years to improve air quality. For example, the standards for NOX emissions have been lowered substantially and the specification requirements for cleaner burning gasoline are more stringent.
The USEPA regulates emission sources that are under the exclusive authority of the federal government, such as aircraft, ships, and certain types of locomotives. USEPA has jurisdiction over emission sources outside state waters (e.g., beyond the outer continental shelf) and establishes various emission standards, including those for vehicles sold in states other than California. Automobiles sold in California must meet stricter emission standards established by CARB. USEPA adopted multiple tiers of emission standards to reduce emissions from non-road diesel engines (e.g., diesel-powered construction equipment) by integrating engine and fuel controls as a system to gain the greatest emission reductions.
The first federal standards (Tier 1) for new non-road (or off-road) diesel engines were adopted in 1994 for engines over 50 horsepower, to be phased-in from 1996 to 2000. On August 27, 1998, USEPA introduced Tier 1 standards for equipment under 37 kW (50 horsepower) and increasingly more stringent Tier 2 and Tier 3 standards for all equipment with phase-in schedules from 2000 to 2008. The Tier 1 through 3 standards were met through advanced engine design, with no or only limited use of exhaust gas after-treatment (oxidation catalysts). Tier 3 standards for NOX and hydrocarbon are similar in stringency to the 2004 standards for highway engines. However, Tier 3 standards for particulate matter were never adopted. On May 11, 2004, USEPA signed the final rule introducing Tier 4 emission standards, which were phased-in between 2008 and 2015. The Tier 4 standards require that emissions of particulate matter and NOX be further reduced by about 90 percent. Such emission reductions are achieved through the use of control technologies—including advanced exhaust gas after-treatment.
State
California Clean Air Act. In addition to being subject to the requirements of CAA, air quality in California is also governed by more stringent regulations under the California Clean Air Act (CCAA). In California, CCAA is administered by CARB at the state level and by the air quality management districts and air pollution control districts at the regional and local levels. CARB, which became part of the California Environmental Protection Agency in 1991, is responsible for meeting the state requirements of the CAA, administering the CCAA, and establishing the California Ambient Air Quality Standards (CAAQS). The CCAA, as amended in 1992, requires all air districts in the State to endeavor to achieve and maintain the CAAQS. CAAQS are generally more stringent than the corresponding federal standards and incorporate additional standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles.
CARB regulates mobile air pollution sources, such as motor vehicles. CARB is responsible for setting emission standards for vehicles sold in California and for other emission sources, such as consumer products and certain off-road equipment. CARB established passenger vehicle fuel specifications in March 1996. CARB oversees the functions of local air pollution control districts and air quality management districts, which, in turn, administer air quality activities at the regional and county levels.
The State standards are summarized in Table 1.
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The CCAA requires CARB to designate areas within California as either attainment or nonattainment for each criteria pollutant based on whether the CAAQS thresholds have been achieved. Under the CCAA, areas are designated as nonattainment for a pollutant if air quality data shows that a state standard for the pollutant was violated at least once during the previous three calendar years. Exceedances that are affected by highly irregular or infrequent events are not considered violations of a state standard and are not used as a basis for designating areas as nonattainment. Under the CCAA, Orange County is designated as a nonattainment area for O3, PM10, and PM2.5.
In August 2022, CARB approved regulations to ban new gasoline-powered cars beginning with 2035 models. Automakers will gradually electrify their fleet of new vehicles, beginning with 35 percent of 2026 models sold. In March 2023, USEPA approved CARB’s regulations that mandate that all new mediumand heavy-duty trucks would be zero emissions by 2045 where feasible. Trucking companies would also have to gradually convert their existing fleets to zero emission vehicles.
Toxic Air Contaminant Identification and Control Act. The public’s exposure to toxic air contaminants (TACs) is a significant public health issue in California. CARB’s statewide comprehensive air toxics program was established in the early 1980s. The Toxic Air Contaminant Identification and Control Act created California's program to reduce exposure to air toxics. Under the Toxic Air Contaminant Identification and Control Act, CARB is required to use certain criteria in the prioritization for the identification and control of air toxics. In selecting substances for review, CARB must consider criteria relating to "the risk of harm to public health, amount or potential amount of emissions, manner of, and exposure to, usage of the substance in California, persistence in the atmosphere, and ambient concentrations in the community" [Health and Safety Code Section 39666(f)].
The Toxic Air Contaminant Identification and Control Act also requires CARB to use available information gathered from the Air Toxics "Hot Spots" Information and Assessment Act program to include in the prioritization of compounds. CARB identified particulate emissions from diesel-fueled engines (diesel PM) TACs in August 1998. Following the identification process, CARB was required by law to determine if there is a need for further control, which led to the risk management phase of the program. For the risk management phase, CARB formed the Diesel Advisory Committee to assist in the development of a risk management guidance document and a risk reduction plan. With the assistance of the Diesel Advisory Committee and its subcommittees, CARB developed the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles and the Risk Management Guidance for the Permitting of New Stationary Diesel-Fueled Engines. The Board approved these documents on September 28, 2000, paving the way for the next step in the regulatory process: the control measure phase. During the control measure phase, specific Statewide regulations designed to further reduce diesel PM emissions from diesel-fueled engines and vehicles have and continue to be evaluated and developed. The goal of each regulation is to make diesel engines as clean as possible by establishing state-of-the-art technology requirements or emission standards to reduce diesel PM emissions.
Breathing H2S at levels above the state standard could result in exposure to a disagreeable rotten eggs odor. The State does not regulate other odors.
California Air Toxics Program. The California Air Toxics Program was established in 1983, when the California Legislature adopted Assembly Bill (AB) 1807 to establish a two-step process of risk identification and risk management to address potential health effects from exposure to toxic substances Cabrillo Town Center Project
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in the air.1 In the risk identification step, CARB and the Office of Environmental Health Hazard Assessment (OEHHA) determine if a substance should be formally identified, or “listed,” as a TAC in California. Since inception of the program, a number of such substances have been listed, including benzene, chloroform, formaldehyde, and particulate emissions from diesel-fueled engines, among others.2 In 1993, the California Legislature amended the program to identify the 189 federal hazardous air pollutants as TACs.
In the risk management step, CARB reviews emission sources of an identified TAC to determine whether regulatory action is needed to reduce risk. Based on results of that review, CARB has promulgated a number of airborne toxic control measures (ATCMs), both for mobile and stationary sources. In 2004, CARB adopted an ATCM to limit heavy-duty diesel motor vehicle idling in order to reduce public exposure to diesel PM and other TACs. The measure applies to diesel-fueled commercial vehicles with gross vehicle weight ratings greater than 10,000 pounds that are licensed to operate on highways, regardless of where they are registered. This measure does not allow diesel-fueled commercial vehicles to idle for more than five minutes at any given time.
In addition to limiting exhaust from idling trucks, CARB adopted regulations on July 26, 2007 for off-road diesel construction equipment such as bulldozers, loaders, backhoes, and forklifts, as well as many other self-propelled off-road diesel vehicles to reduce emissions by installation of diesel particulate filters and encouraging the replacement of older, dirtier engines with newer emission-controlled models. In April 2021, CARB proposed a 2020 Mobile Source Strategy that seeks to move California to 100 percent zero-emission off-road equipment by 2035.
Assembly Bill 2588 Air Toxics “Hot Spots” Program. The AB 1807 program is supplemented by the AB 2588 Air Toxics “Hot Spots” program, which was established by the California Legislature in 1987.
Under this program, facilities are required to report their air toxics emissions, assess health risks, and notify nearby residents and workers of significant risks if present. In 1992, the AB 2588 program was amended by Senate Bill (SB) 1731 to require facilities that pose a significant health risk to the community to reduce their risk through implementation of a risk management plan.
Air Quality and Land Use Handbook: A Community Health Perspective. The Air Quality and Land Use Handbook: A Community Health Perspective provides important air quality information about certain types of facilities (e.g., freeways, refineries, rail yards, ports) that should be considered when siting sensitive land uses such as residences.3 CARB provides recommended site distances from certain types of facilities when considering siting new sensitive land uses. The recommendations are advisory and should not be interpreted as defined “buffer zones.” If a project is within the siting distance, CARB recommends further analysis. Where possible, CARB recommends a minimum separation between new sensitive land uses and existing sources.
1 2
3 California Air Resources Board, California Air Toxics Program, www.arb.ca.gov/toxics/toxics.htm, last reviewed by CARB September 24, 2015.
California Air Resources Board, Toxic Air Contaminant Identification List, www.arb.ca.gov/toxics/id/taclist.htm, last reviewed by CARB July 18, 2011.
California Air Resources Board, Air Quality and Land Use Handbook, a Community Health Perspective, April 2005.
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Air Quality and Land Use Handbook. CARB published the Air Quality and Land Use Handbook (CARB Handbook) on April 28, 2005 to serve as a general guide for considering health effects associated with siting sensitive receptors proximate to sources of TAC emissions. The recommendations provided therein are voluntary and do not constitute a requirement or mandate for either land use agencies or local air districts. The goal of the guidance document is to protect sensitive receptors, such as children, the elderly, acutely ill, and chronically ill persons, from exposure to TAC emissions. Some examples of CARB’s siting recommendations include the following: (1) avoid siting sensitive receptors within 500 feet of a freeway, urban road with 100,000 vehicles per day, or rural roads with 50,000 vehicles per day; (2) avoid siting sensitive receptors within 1,000 feet of a distribution center (that accommodates more than 100 trucks per day, more than 40 trucks with operating transport refrigeration units per day, or where transport refrigeration unit operations exceed 300 hours per week); and (3) avoid siting sensitive receptors within 300 feet of any dry cleaning operation using perchloroethylene and within 500 feet of operations with two or more machines.
California Code of Regulations. The California Code of Regulations (CCR) is the official compilation and publication of regulations adopted, amended or repealed by the state agencies pursuant to the Administrative Procedure Act. The CCR includes regulations that pertain to air quality emissions.
Specifically, Section 2485 in CCR Title 13 states that the idling of all diesel-fueled commercial vehicles (weighing over 10,000 pounds) used during construction shall be limited to five minutes at any location.
In addition, Section 93115 in CCR Title 17 states that operation of any stationary, diesel-fueled, compression-ignition engines shall meet specified fuel and fuel additive requirements and emission standards.
Regional (South Coast Air Quality Management District)
The SCAQMD was created in 1977 to coordinate air quality planning efforts throughout Southern California. SCAQMD is the agency principally responsible for comprehensive air pollution control in the region. Specifically, SCAQMD is responsible for monitoring air quality, as well as planning, implementing, and enforcing programs designed to attain and maintain the CAAQS and NAAQS in the district. SCAQMD has jurisdiction over an area of 10,743 square miles consisting of Orange County; the non-desert portions of Los Angeles, Riverside, and San Bernardino counties; and the Riverside County portion of the Salton Sea Air Basin and Mojave Desert Air Basin. The Basin portion of SCAQMD’s jurisdiction covers an area of 6,745 square miles. The Basin includes all of Orange County and the nondesert portions of Los Angeles, Riverside, and San Bernardino counties.
Programs that were developed by SCAQMD to attain and maintain the CAAQS and NAAQS include air quality rules and regulations that regulate stationary sources, area sources, point sources, and certain mobile source emissions. SCAQMD is also responsible for establishing stationary source permitting requirements and for ensuring that new, modified, or relocated stationary sources do not create net emission increases. However, SCAQMD has primary authority over about 20 percent of NOx emissions, a precursor to ozone formation. All projects in the SCAQMD jurisdiction are subject to SCAQMD rules and regulations, including, but not limited to the following:
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•
•
SCAQMD Rule 402, which states that a person shall not discharge from any source whatsoever such quantities of air contaminants or other materials which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health, or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.
SCAQMD Rule 403, would reduce the amount of particulate matter entrained in ambient air as a result of anthropogenic fugitive dust sources by requiring actions to prevent, reduce or mitigate fugitive dust emissions.
•
•
•
•
SCAQMD Rule 431.2, would require use of low-sulfur fuel in construction equipment.
SCAQMD Rule 445 would prohibit the inclusion of wood burning fireplaces in any residences.
SCAQMD Rule 1113, which limits the VOC content of architectural coatings.
In accordance with Section 2485 in Title 13 of the California Code of Regulations, the idling of all diesel-fueled commercial vehicles (with gross vehicle weight over 10,000 pounds) during construction would be limited to five minutes at any location. • In accordance with Section 93115 in Title 17 of the California Code of Regulations, operation of any stationary, diesel-fueled, compression-ignition engines would meet specific fuel and fuel additive requirements and emissions standards.
Air Quality Management Plan. SCAQMD adopted the 2022 Air Quality Management Plan (AQMP) on December 2, 2022, updating the region’s air quality attainment plan to address the “extreme” ozone nonattainment status for the Basin and the severe ozone non-attainment for the Coachella Valley Basin by laying a path for attainment by 2037. This includes reducing NOx emissions by 67 percent more than required by adopted rules and regulations in 2037. The AQMP calls on strengthening many stationary source controls and addressing new sources like wildfires, but still concludes that the region will not meet air quality standards without a significant shift to zero emission technologies and significant federal action. The 2022 AQMP relies on the growth assumptions in SCAG’s 2020-2045 RTP/SCS.
Multiple Air Toxics Exposure Study V. To date, the most comprehensive study on air toxics in the Basin is the Multiple Air Toxics Exposure Study V, released in August 2021.4 The report included refinements in aircraft and recreational boating emissions and diesel conversion factors. It finds a Basin average cancer risk of 455 in a million (population-weighted, multi-pathway), which represents a decrease of 54 percent compared to the estimate in MATES IV (page ES-13). The monitoring program measured more than 30 air pollutants, including both gases and particulates. The monitoring study was accompanied by computer modeling that estimated the risk of cancer from breathing toxic air pollution based on emissions and weather data. About 88 percent of the risk is attributed to emissions associated with mobile sources, with the remainder attributed to toxics emitted from stationary sources, which include large industrial operations, such as refineries and metal processing facilities, as well as smaller businesses such as gas stations and chrome plating facilities (page ES-12). The results indicate that 4 South Coast Air Quality Management District, MATES-V Study. https://www.aqmd.gov/home/air-quality/airquality-studies/health-studies/mates-v Cabrillo Town Center Project
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diesel PM is the largest contributor to air toxics risk, accounting on average for about 50 percent of the total risk (Figure ES-2).
Regional (Southern California Association of Governments) SCAG is the regional planning agency for Los Angeles, Orange, Ventura, Riverside, San Bernardino, and Imperial Counties, and addresses regional issues relating to transportation, the economy, community development and the environment. SCAG coordinates with various air quality and transportation stakeholders in Southern California to ensure compliance with the federal and state air quality requirements, including the Transportation Conformity Rule and other applicable federal, state, and air district laws and regulations. As the federally designated Metropolitan Planning Organization (MPO) for the six-county Southern California region, SCAG is required by law to ensure that transportation activities “conform” to, and are supportive of, the goals of regional and state air quality plans to attain the NAAQS. In addition, SCAG is a co-producer, with the SCAQMD, of the transportation strategy and transportation control measure sections of the AQMP for the Air Basin.
SCAG adopted the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) on September 23, 2020. The RTP/SCS aims to address the transportation and air quality impacts of 3.7 million additional residents, 1.6 additional households, and 1.6 million additional jobs from 2016 to 2045. The Plan calls for $639 billion in transportation investments and reducing VMT by 19 percent per capita from 2005 to 2035. The updated plan accommodates 21.3 percent growth in population from 2016 (3,933,800) to 2045 (4,771,300) and a 15.6 percent growth in jobs from 2016 (1,848,300) to 2045 (2,135,900). The regional plan projects several benefits:
•
•
•
•
•
•
•
Decreasing drive-along work commutes by three percent
Reducing per capita VMT by five percent and vehicle hours traveled per capita by nine percent Increasing transit commuting by two percent
Reducing travel delay per capita by 26 percent
Creating 264,500 new jobs annually
Reducing greenfield development by 29 percent by focusing on smart growth Locating six more percent household growth in High Quality Transit Areas (HQTAs), which concentrate roadway repair investments, leverage transit and active transportation investments, reduce regional life cycle infrastructure costs, improve accessibility, create local jobs, and have the potential to improve public health and housing affordability. • Locating 15 percent more jobs in HQTAs
•
•
Reducing PM2.5 emissions by 4.1 percent
Reducing GHG emissions by 19 percent by 2035
Local (City of Santa Ana)
City of Santa Ana General Plan Conservation Element. The Conservation Element of the City’s 2022 General Plan sets forth the goals, objectives, and policies that guide the City’s direction on air quality.
The Conservation Element includes Goal CN-1 (Air Quality and Climate), which aims to “[p]rotect air resources, improve regional and local air quality, and minimize the impacts of climate change.” It includes several policies germane to controlling criteria pollutant emissions from development projects:
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Policy CN-1.4:
Policy CN-1.5:
Development Standards. Support new development that meets or exceeds standards for energy-efficient building design and site planning.
Sensitive Receptor Decisions. Study the impacts of stationary and non-stationary emission sources on existing and proposed sensitive uses and opportunities to minimize health and safety risks. Develop and adopt new regulations avoiding the siting of facilities that potentially emit increased pollution near sensitive receptors within environmental justice area boundaries
Policy CN-1.6:
Policy CN-1.7:
New and Infill Residential Development. Promote development that is mixed use, pedestrian friendly, transit oriented, and clustered around activity centers.
Housing and Employment Opportunities. Improve the city’s jobs/housing balance ratio by supporting development that provides housing and employment opportunities to enable people to live and work in Santa Ana.
Policy CN-1.8: Promote Alternative Transportation. Promote use of alternate modes of transportation in the City of Santa Ana, including pedestrian, bicycling, public transportation, car sharing programs, and emerging technologies.
Policy CN-14:
Policy CN-17:
Transportation Demand Management. Require and incentivize projects to incorporate transportation demand management techniques.
Indoor Recreation. Encourage new development to provide indoor recreation space when located in areas with high levels of localized air pollution or if site is adjacent to freeways or heavy industrial uses.
Existing Conditions
Pollutants and Effects
Air quality is defined by ambient air concentrations of seven specific pollutants identified by the USEPA to be of concern with respect to health and welfare of the general public. These specific pollutants, known as “criteria air pollutants,” are defined as pollutants for which the federal and State governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. Criteria air pollutants include carbon monoxide (CO), ground-level ozone (O3), nitrogen oxides (NOX), sulfur oxides (SOX), particulate matter ten microns or less in diameter (PM10), particulate matter
2.5 microns or less in diameter (PM2.5), and lead (Pb). The following descriptions of each criteria air pollutant and their health effects are based on information provided by the SCAQMD.5 Carbon Monoxide (CO). CO is primarily emitted from combustion processes and motor vehicles due to incomplete combustion of fuel. Elevated concentrations of CO weaken the heart’s contractions and lower the amount of oxygen carried by the blood. It is especially dangerous for people with chronic heart disease. Inhalation of CO can cause nausea, dizziness, and headaches at moderate concentrations and can be fatal at high concentrations.
5 South Coast Air Quality Management District, Final Program Environmental Impact Report for the 2012 AQMP, December 7, 2012.
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Ozone (O ). 3 O is a gas that is formed when volatile organic compounds (VOCs) and nitrogen oxides 3 (NOX)—both byproducts of internal combustion engine exhaust—undergo slow photochemical reactions in the presence of sunlight. O3 concentrations are generally highest during the summer months when direct sunlight, light wind, and warm temperature conditions are favorable. An elevated level of O3 irritates the lungs and breathing passages, causing coughing and pain in the chest and throat, thereby increasing susceptibility to respiratory infections and reducing the ability to exercise. Effects are more severe in people with asthma and other respiratory ailments. Long-term exposure may lead to scarring of lung tissue and may lower lung efficiency.
Nitrogen Dioxide (NO ). 2 NO is a byproduct of fuel combustion and major sources include power plants, 2 large industrial facilities, and motor vehicles. The principal form of nitrogen oxide produced by combustion is nitric oxide (NO), which reacts quickly to form NO2, creating the mixture of NO and NO2 commonly called NO . NO absorbs blue light and results in a brownish-red cast to the atmosphere and X 2 reduced visibility. NO also contributes to the formation of PM . Nitrogen oxides irritate the nose and 2 10 throat, and increase one’s susceptibility to respiratory infections, especially in people with asthma. The principal concern of NOX is as a precursor to the formation of ozone.
Sulfur Dioxide (SO ). 2 Sulfur oxides (SO ) are compounds of sulfur and oxygen molecules. SO is the X 2 pre- dominant form found in the lower atmosphere and is a product of burning sulfur or burning materials that contain sulfur. Major sources of SO2 include power plants, large industrial facilities, diesel vehicles, and oil-burning residential heaters. Emissions of sulfur dioxide aggravate lung diseases, especially bronchitis. It also constricts the breathing passages, especially in asthmatics and people involved in moderate to heavy exercise. SO2 potentially causes wheezing, shortness of breath, and coughing. High levels of particulates appear to worsen the effect of sulfur dioxide, and long-term exposures to both pollutants leads to higher rates of respiratory illness.
Particulate Matter (PM and PM 10 2.5). The human body naturally prevents the entry of larger particles into the body. However, small particles, with an aerodynamic diameter equal to or less than 10 microns (PM10), and even smaller particles with an aerodynamic diameter equal to or less than 2.5 microns (PM2.5), can enter the body and become trapped in the nose, throat, and upper respiratory tract. These small particulates can potentially aggravate existing heart and lung diseases, change the body’s defenses against inhaled materials, and damage lung tissue. The elderly, children, and those with chronic lung or heart disease are most sensitive to PM and PM . Lung impairment can persist for two 10 2.5 to three weeks after exposure to high levels of particulate matter. Some types of particulates can become toxic after inhalation due to the presence of certain chemicals and their reaction with internal body fluids.
Lead (Pb). Lead is emitted from industrial facilities and from the sanding or removal of old lead-based paint. Smelting or processing the metal is the primary source of lead emissions, which is primarily a regional pollutant. Lead affects the brain and other parts of the body’s nervous system. Exposure to lead in very young children impairs the development of the nervous system, kidneys, and blood forming processes in the body.
State-Only Criteria Pollutants
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Visibility-Reducing Particles. Deterioration of visibility is one of the most obvious manifestations of air pollution and plays a major role in the public’s perception of air quality. Visibility reduction from air pollution is often due to the presence of sulfur and NOX, as well as PM.
Sulfates (SO4
2-). Sulfates are the fully oxidized ionic form of sulfur. Sulfates occur in combination with metal and/or hydrogen ions. In California, emissions of sulfur compounds occur primarily from the combustion of petroleum-derived fuels (e.g., gasoline and diesel fuel) that contain sulfur. This sulfur is oxidized during the combustion process and subsequently converted to sulfate compounds in the atmosphere. Effects of sulfate exposure at levels above the standard include a decrease in ventilatory function, aggravation of asthmatic symptoms, and an increased risk of cardio-pulmonary disease.
Sulfates are particularly effective in degrading visibility, and, due to fact that they are usually acidic, can harm ecosystems and damage materials and property.
Hydrogen Sulfide (H S). 2 H S is a colorless gas with the odor of rotten eggs. It is formed during bacterial 2 decomposition of sulfur-containing organic substances. Also, it can be present in sewer gas and some natural gas and can be emitted as the result of geothermal energy exploitation. Breathing H2S at levels above the state standard could result in exposure to a very disagreeable odor.
Vinyl Chloride. Vinyl chloride is a colorless, flammable gas at ambient temperature and pressure. It is also highly toxic and is classified as a known carcinogen by the American Conference of Governmental Industrial Hygienists and the International Agency for Research on Cancer. At room temperature, vinyl chloride is a gas with a sickly-sweet odor that is easily condensed. However, it is stored at cooler temperatures as a liquid. Due to the hazardous nature of vinyl chloride to human health, there are no end products that use vinyl chloride in its monomer form. Vinyl chloride is a chemical intermediate, not a final product. It is an important industrial chemical chiefly used to produce polyvinyl chloride (PVC).
The process involves vinyl chloride liquid fed to polymerization reactors where it is converted from a monomer to a polymer PVC. The final product of the polymerization process is PVC in either a flake or pellet form. Billions of pounds of PVC are sold on the global market each year. From its flake or pellet form, PVC is sold to companies that heat and mold the PVC into end products such as PVC pipe and bottles. Vinyl chloride emissions are historically associated primarily with landfills.
Toxic Air Contaminants (TACs)
TACs refer to a diverse group of “non-criteria” air pollutants that can affect human health but have not had ambient air quality standards established for them. This is not because they are fundamentally different from the pollutants discussed above but because their effects tend to be local rather than regional. TACs are classified as carcinogenic and noncarcinogenic, where carcinogenic TACs can cause cancer and noncarcinogenic TAC can cause acute and chronic impacts to different target organ systems (e.g., eyes, respiratory, reproductive, developmental, nervous, and cardiovascular). CARB and OEHHA determine if a substance should be formally identified, or “listed,” as a TAC in California. A complete list of these substances is maintained on CARB’s website.6
Diesel particulate matter (DPM), which is emitted in the exhaust from diesel engines, was listed by the state as a TAC in 1998. DPM has historically been used as a surrogate measure of exposure for all 6 California Air Resources Board, Toxic Air Contaminant Identification List, www.arb.ca.gov/toxics/id/taclist.htm, last reviewed by CARB July 18, 2011.
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diesel exhaust emissions. DPM consists of fine particles (fine particles have a diameter less than 2.5 micrometer (μm)), including a subgroup of ultrafine particles (ultrafine particles have a diameter less than 0.1 μm). Collectively, these particles have a large surface area which makes them an excellent medium for absorbing organics. The visible emissions in diesel exhaust include carbon particles or “soot.” Diesel exhaust also contains a variety of harmful gases and cancer-causing substances.
Exposure to DPM may be a health hazard, particularly to children whose lungs are still developing and the elderly who may have other serious health problems. DPM levels and resultant potential health effects may be higher in close proximity to heavily traveled roadways with substantial truck traffic or near industrial facilities. According to CARB, DPM exposure may lead to the following adverse health effects:
(1) aggravated asthma; (2) chronic bronchitis; (3) increased respiratory and cardiovascular hospitalizations; (4) decreased lung function in children; (5) lung cancer; and (6) premature deaths for people with heart or lung disease.7,8
Project Site
The Project Site is located within the South Coast Air Basin (the Basin); named so because of its geographical formation is that of a basin, with the surrounding mountains trapping the air and its pollutants in the valleys or basins below. The 6,745-square-mile Basin includes all of Orange County and the non-desert portions of Los Angeles, Riverside, and San Bernardino Counties. It is bounded by the Pacific Ocean to the west; the San Gabriel, San Bernardino and San Jacinto Mountains to the north and east; and the San Diego County line to the south. Ambient pollution concentrations recorded in the Orange County portion of the Basin are among the highest in the four counties comprising the Basin.
USEPA has classified Orange County as a nonattainment area for O3, PM2.5, and lead. This classification denotes that the Basin does not meet the NAAQS for these pollutants. In addition, under the CCAA, Orange County is designated as a nonattainment area for O , PM , and PM . The air quality within the 3 10 2.5 Basin is primarily influenced by a wide range of emissions sources, such as dense population centers, heavy vehicular traffic, industry, and meteorology.
Air pollutant emissions are generated in the local vicinity by stationary and area-wide sources, such as commercial activity, space and water heating, landscaping maintenance, consumer products, and mobile sources primarily consisting of automobile traffic.
Air Pollution Climatology. The topography and climate of Southern California combine to make the Basin an area of high air pollution potential. During the summer months, a warm air mass frequently descends over the cool, moist marine layer produced by the interaction between the ocean’s surface and the lowest layer of the atmosphere. The warm upper layer forms a cap over the cooler surface layer which inhibits the pollutants from dispersing upward. Light winds during the summer further limit ventilation.
Additionally, abundant sunlight triggers photochemical reactions which produce O3 and the majority of particulate matter.
Air Monitoring Data. The SCAQMD monitors air quality conditions at 38 source receptor areas (SRA) throughout the Basin. The Project Site is located in SCAQMD’s Central Orange County receptor area. 7 8
California Air Resources Board, Overview: Diesel Exhaust and Health, www.arb.ca.gov/research/diesel/dieselhealth.htm, last reviewed by CARB April 12, 2016.
California Air Resources Board, Fact Sheet: Diesel Particulate Matter Health Risk Assessment Study for the West Oakland Community: Preliminary Summary of Results, March 2008.
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Historical data from the area was used to characterize existing conditions in the vicinity of the Project area. Table 2 shows pollutant levels, State and federal standards, and the number of exceedances recorded in the area from 2019 through 2021. The one-hour State standard for O3 was exceeded twice during this three-year period. The federal standard was exceeded once in that same period. In addition, the daily State standard for PM10 was exceeded twice. The daily federal standard for PM2.5 was exceeded four times. CO and NO2 levels did not exceed the CAAQS from 2019 to 2021 for 1-hour (and 8-hour for CO).
Table 2
Ambient Air Quality Data
Maximum Concentrations and Frequencies
of Exceedance Standards
Pollutants and State and Federal Standards 2019 2020 2021 Ozone (O3)
Maximum 1-hour Concentration (ppm)
Days > 0.09 ppm (State 1-hour standard)
Days > 0.070 ppm (Federal 8-hour standard)
0.0096 0.142
6 0.089
1 1
0 15 0
Carbon Monoxide (CO2)
Maximum 1-hour Concentration (ppm)
Days > 20 ppm (State 1-hour standard)
Maximum 8-hour Concentration (ppm)
Days > 9.0 ppm (State 8-hour standard)
2.4 0
2.3 0
2.1 0
1.3 0
1.8 0
1.5 0
Nitrogen Dioxide (NO2)
Maximum 1-hour Concentration (ppm)
Days > 0.18 ppm (State 1-hour standard)
0.0594
0 0.0709
0 0.0671
0 PM10
Maximum 24-hour Concentration (µg/m3)
Days > 50 µg/m3 (State 24-hour standard)
127
13 120
13 115
12 PM2.5
Maximum 24-hour Concentration (µg/m3)
Days > 35 µg/m3 (Federal 24-hour standard)
36.1 3
41.4 1
54.4 9
Sulfur Dioxide (SO2)
Maximum 24-hour Concentration (ppb)
Days > 0.04 ppm (State 24-hour standard)
N/A
N/A
N/A
N/A
N/A
N/A
ppm = parts by volume per million of air.
µg/m3 = micrograms per cubic meter.
N/A = not available at this monitoring station.
Source: SCAQMD annual monitoring data at Central Orange County subregion (http://www.aqmd.gov/home/air-quality/air-quality-datastudies/historical-data-by-year) accessed July 26, 2023.
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Existing Health Risk in the Surrounding Area. Based on the MATES-V model, the calculated cancer risk in the Project area (zip code 92705) is approximately 416 in a million.9 The cancer risk in this area is predominately related to nearby sources of diesel particulate matter (e.g., diesel trucks and traffic on the northbound mainline of the Santa Ana Freeway (I-5) 750 feet to the west). In general, the risk at the Project Site is higher than 37 percent of the population across the South Coast Air Basin.
The Office of Environmental Health Hazard Assessment, on behalf of the California Environmental Protection Agency (CalEPA), provides a screening tool called CalEnviroScreen that can be used to help identify California communities disproportionately burdened by multiple sources of pollution. According to CalEnviroScreen, the Project Site (Census tract 6059075403) is located in the 71st percentile, which means the Project Site has an overall environmental pollution burden higher than at least 71 percent of other communities within California.10
Sensitive Receptors. Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. The California Air Resources Board (CARB) has identified the following groups who are most likely to be affected by air pollution:
children less than 14 years of age, the elderly over 65 years of age, athletes, and people with cardiovascular and chronic respiratory diseases. According to the SCAQMD, sensitive receptors include residences, schools, playgrounds, childcare centers, athletic facilities, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes.
The Project Site is located on the Fourth Street corridor, which is populated with a mix of residential, retail, and commercial uses near the Project Site. Sensitive receptors within 0.25 miles of the Project Site include, but are not limited to, the following representative sampling:
•
•
•
•
Cabrillo Park, 1820 East Fruit Street; directly north of the Project Site.
Residences, 724 North Parkcenter Drive; 80 feet northeast of the Project Site Residences, 618 Sherry Lane; 400 feet west of the Project Site.
Residences, 1901 East First Street; 450 feet south of the Project Site.
Existing Project Site Emissions. The Project Site is improved with four commercial buildings totaling 173,025 square feet and 617 surface parking spaces. As summarized in Table 3, most existing air quality emissions are associated with the 1,876 daily vehicle trips traveling to and from the Project Site.11 Table 3
Existing Daily Operations Emissions
Daily Emissions (Pounds Per Day)
Emissions Source VOC NOX CO SOX PM10 PM2.5
9 South Coast Air Quality Management District, Multiple Air Toxics Exposure Study in the South Coast Air Basin (MATES-V), MATES Interactive Carcinogenicity Map, 2021, V https://experience.arcgis.com/experience/79d3b6304912414bb21ebdde80100b23/page/home/?data_id=data Source_105-a5ba9580e3aa43508a793fac819a5a4d%3A26&views=view_39%2Cview_1, accessed July 20, 2023.
10 Office of Environmental Health Hazard Assessment,
https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40, accessed July 20, 2023. 11 Linscott Law & Greenspan, Memorandum: Vehicle Miles Traveled Assessment for the Proposed Cabrillo Town Center Mixed-Use Project; June 27, 2023.
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Table 3
Existing Daily Operations Emissions
Area Sources
Energy Sources
Mobile Sources
Regional Total
5.4 0.1
0.1 1.2
5.7 7.0
7.5 1.0
<0.1
<0.1
0.2 <0.1
0.1 <0.1
0.1 6.9 62.9
71.4 13.4
13.5 3.5
12.3 0.2 3.6
Source: DKA Planning, 2023 based on CalEEMod 2022.1.1.14 model runs, Summer season (included in Appendix).
Project Impacts
Methodology
The air quality analysis conducted for the Project is consistent with the methods described in the SCAQMD CEQA Air Quality Handbook (1993 edition), as well as the updates to the CEQA Air Quality Handbook, as provided on the SCAQMD website. The SCAQMD recommends the use of the California Emissions Estimator Model (CalEEMod, version 2022.1.1.14) as a tool for quantifying emissions of air pollutants that will be generated by constructing and operating development projects. The analyses focus on the potential change in air quality conditions due to Project implementation. Air pollutant emissions would result from both construction and operation of the Project. Specific methodologies used to evaluate these emissions are discussed below.
Construction. Sources of air pollutant emissions associated with construction activities include heavyduty off-road diesel equipment and vehicular traffic to and from the Project construction site. Projectspecific information was provided describing the schedule of construction activities and the equipment inventory required from the Applicant. Details pertaining to the schedule and equipment can be found in the Technical Appendix to this analysis. The CalEEMod model provides default values for daily equipment usage rates and worker trip lengths, as well as emission factors for heavy-duty equipment, passenger vehicles, and haul trucks that have been derived by the CARB. Maximum daily emissions were quantified for each construction activity based on the number of equipment and daily hours of use, in addition to vehicle trips to and from the Project Site.
The SCAQMD recommends that air pollutant emissions be assessed for both regional scale and localized impacts. The regional emissions analysis includes both on-site and off-site sources of emissions, while the localized emissions analysis focuses only on sources of emissions that would be located on the Project Site.
Localized impacts were analyzed in accordance with the SCAQMD Localized Significance Threshold (LST) methodology.12 The localized effects from on-site portion of daily emissions were evaluated at sensitive receptor locations potentially impacted by the Project according to the SCAQMD’s LST methodology, which uses on-site mass emission look-up tables and Project-specific modeling, where appropriate.13 SCAQMD provides LSTs applicable to the following criteria pollutants: NO , CO, PM , X 10 12 South Coast Air Quality Management District, Final Localized Significance Methodology, revised July 2008. 13 South Coast Air Quality Management District, LST Methodology Appendix C-Mass Rate LST Look-Up Table, October 2009.
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and PM . SCAQMD does not provide an LST for SO since land use development projects typically 2.5 2 result in negligible construction and long-term operation emissions of this pollutant. Since VOCs are not a criteria pollutant, there is no ambient standard or SCAQMD LST for VOCs. Due to the role VOCs play in O3 formation, it is classified as a precursor pollutant, and only a regional emissions threshold has been established.
LSTs represent the maximum emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard and are developed based on the ambient concentrations of that pollutant for each source receptor area and distance to the nearest sensitive receptor. The mass rate look-up tables were developed for each source receptor area and can be used to determine whether or not a project may generate significant adverse localized air quality impacts. SCAQMD provides LST mass rate look-up tables for projects with active construction areas that are less than or equal to five acres. If the project exceeds the LST look-up values, then the SCAQMD recommends that project-specific air quality modeling must be performed. Please refer to Threshold b below, for the analysis of localized impacts from on-site construction activities. In accordance with SCAQMD guidance, maximum daily emissions of NO , CO, PM , and PM X 10 2.5 from onsite sources during each construction activity were compared to LST values for a five-acre site having sensitive receptors within 25 meters (82 feet).14This is appropriate given the 8.97-acre site and the proximity of sensitive receptors immediately north of the Project Site.
The Basin is divided into 38 SRAs, each with its own set of maximum allowable LST values for on-site emissions sources during construction and operations based on locally monitored air quality. Maximum on-site emissions resulting from construction activities were quantified and assessed against the applicable LST values.
The significance criteria and analysis methodologies in the SCAQMD's CEQA Air Quality Handbook were used in evaluating impacts in the context of the CEQA significance criteria listed below. The SCAQMD localized significance thresholds (LSTs) for NO2, CO, and PM10 were initially published in June 2003 and revised in July 2008.15 The LSTs for PM were established in October 2006. Updated 16
2.5 LSTs were published on the SCAQMD website on October 21, 2009.17 Table 4 presents the significance criteria for both construction and operational emissions. 14 South Coast Air Quality Management District, Fact Sheet for Applying CalEEMod to Localized Significance Thresholds, 2008.
15 South Coast Air Quality Management District, Fact Sheet for Applying CalEEMod to Localized Significance Thresholds, 2008.
16 South Coast Air Quality Management District, Final – Methodology to Calculate Particulate Matter (PM) 2.5 and PM 2.5 Significance Thresholds, October 2006.
17 South Coast Air Quality Management District, Final Localized Significance Threshold Methodology Appendix C – Mass Rate LST Look-Up Tables, October 21, 2009.
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Table 4
SCAQMD Emissions Thresholds
Construction Emissions Operation Emissions Criteria Pollutant Regional 75 Localized /a/ Regional
55 Localized /a/
Volatile Organic Compounds (VOC)
Nitrogen Oxides (NOX)
Carbon Monoxide (CO)
Sulfur Oxides (SOX)
Respirable Particulates (PM10)
Fine Particulates (PM2.5)
--
183
1,253
--
--
183
1,253
--
100
550
150
55 550
150
150
55 150 13 3
55 7 2
/a/ Localized significance thresholds assumed a five-acre and 25-meter (82-foot) receptor distance in the Central Orange County source receptor area. The SCAQMD has not developed LST values for VOC or SOX. Pursuant to SCAQMD guidance, sensitive receptors closer than 25 meters to a construction site are to use the LSTs for receptors at 25 meters (SCAQMD Final Localized Significance Threshold Methodology, June 2008).
Source: SCAQMD, South Coast AQMD Air Quality Significance Thresholds, 2019 Operations. CalEEMod also generates estimates of daily and annual emissions of air pollutants resulting from future operation of a project. Operational emissions of air pollutants are produced by mobile sources (vehicular travel) and stationary sources (utilities demand). Utilities for the Project Site are provided by Southern California Edison (SCE) for electricity and Southern California Gas for natural gas.
CalEEMod has derived default emissions factors for electricity and natural gas usage that are applied to the size and land use type of the Project in question. CalEEMod also generates estimated operational emissions associated water use, wastewater generation, and solid waste disposal.
Similar to construction, SCAQMD’s CalEEMod software was used for the evaluation of Project emissions during operation. CalEEMod was used to calculate on-road fugitive dust, architectural coatings, landscape equipment, energy use, mobile source, and stationary source emissions.18 To determine if a significant air quality impact would occur, the net increase in regional and local operational emissions generated by the Project was compared against the SCAQMD’s significance thresholds.19 Details describing the operational emissions of the Project can be found in in the Technical Appendix.
Toxic Air Contaminants Impacts (Construction and Operations). Potential TAC impacts are evaluated by conducting a qualitative analysis consistent with the CARB Handbook followed by a more detailed analysis (i.e., dispersion modeling), as necessary. The qualitative analysis consists of reviewing the Project to identify any new or modified TAC emissions sources. If the qualitative evaluation does not rule out significant impacts from a new source, or modification of an existing TAC emissions source, a more detailed analysis is conducted.
18 Energy consumption estimates with CalEEMod 2022.1.1.14 are based on the California Energy Commission’s 2020 Residential Appliance Saturation Survey (residential uses) and 2021 Commercial Forecast database, both of which reflected the 2019 Title 24 energy efficiency standards. These energy consumption estimates were adjusted to reflect the 2022 Title 24 standards that cumulatively produce a 0.49 percent reduction in electricity use and 0.45 percent reduction in natural gas use when compared to the 2019 standards. 19 South Coast Air Quality Management District, Air Quality Significance Thresholds, revised March 2015.
SCAQMD based these thresholds, in part on the federal Clean Air Act and, to enable defining “significant” for CEQA purposes, defined the setting as the South Coast Air Basin. (See SCAQMD, CEQA Air Quality Handbook, April 1993, pp. 6-1-6-2).
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Thresholds of Significance
State CEQA Guidelines Appendix G
Would the Project:
a) Conflict with or obstruct implementation of the applicable air quality plan; b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard; c) Expose sensitive receptors to substantial pollutant concentrations; or d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
City and SCAQMD Thresholds
For this analysis the Appendix G Thresholds are relied upon. The analysis utilizes factors and considerations recommended by the City of Santa Ana and SCAQMD Thresholds, as appropriate, to assist in answering the Appendix G Threshold questions. (a) Construction
The City recommends that determination of significance be made on a case-by-case basis, considering the following criteria to evaluate construction-related air emissions:
(i) Combustion Emissions from Construction Equipment
•
•
•
Type, number of pieces and usage for each type of construction equipment; Estimated fuel usage and type of fuel (diesel, natural gas) for each type of equipment; and Emission factors for each type of equipment.
(ii) Fugitive Dust—Grading, Excavation and Hauling
•
•
•
•
•
Amount of soil to be disturbed on-site or moved off-site; Emission factors for disturbed soil;
Duration of grading, excavation and hauling activities; Type and number of pieces of equipment to be used; and
Projected haul route.
(iii) Fugitive Dust—Heavy-Duty Equipment Travel on Unpaved Road •
•
•
Length and type of road;
Type, number of pieces, weight and usage of equipment; and Type of soil.
(iv) Other Mobile Source Emissions
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•
•
Number and average length of construction worker trips to Project Site, per day; and Duration of construction activities.
In addition, the following criteria set forth in the SCAQMD’s CEQA Air Quality Handbook serve as quantitative air quality standards to be used to evaluate project impacts under the Appendix G Thresholds. Under these thresholds, a significant threshold would occur when:20 • Regional emissions from both direct and indirect sources would exceed any of the following SCAQMD prescribed threshold levels: (1) 100 pounds per day for NOX; (2) 75 pounds a day for VOC; (3) 150 pounds per day for PM or SO ; (4) 55 pounds per day for PM ; and (5) 550 10 X 2.5 pounds per day for CO.
• Maximum on-site daily localized emissions exceed the LST, resulting in predicted ambient concentrations in the vicinity of the Project Site greater than the most stringent ambient air quality standards for CO (20 ppm [23,000 μg/m3] over a 1-hour period or 9.0 ppm [10,350 μg/m3] averaged over an 8-hour period) and NO2 (0.18 ppm [339 μg/m3] over a 1-hour period, 0.1 ppm [188 μg/m3] over a three-year average of the 98th percentile of the daily maximum 1-hour average, or 0.03 ppm [57 μg/m3] averaged over an annual period). • Maximum on-site localized PM10 or PM2.5 emissions during construction exceed the applicable LSTs, resulting in predicted ambient concentrations in the vicinity of the Project Site to exceed the incremental 24-hour threshold of 10.4 μg/m3 or 1.0 μg/m3 PM10 averaged over an annual period.
(b) Operation
The City bases the determination of significance of operational air quality impacts on criteria set forth in the SCAQMD’s CEQA Air Quality Handbook.21 As discussed above, the City uses Appendix G as the thresholds of significance for this analysis. Accordingly, the following serve as quantitative air quality standards to be used to evaluate project impacts under the Appendix G thresholds. Under these thresholds, a significant threshold would occur when:
• Operational emissions exceed 10 tons per year of volatile organic gases or any of the following SCAQMD prescribed threshold levels: (1) 55 pounds a day for VOC;22 (2) 55 pounds per day for NO ; (3) 550 pounds per day for CO; (4) 150 pounds per day for SO ; (5) 150 pounds per day X X for PM ; and (6) 55 pounds per day for PM .23 10 2.5
• Maximum on-site daily localized emissions exceed the LST, resulting in predicted ambient concentrations in the vicinity of the Project Site greater than the most stringent ambient air quality standards for CO (20 parts per million (ppm) over a 1-hour period or 9.0 ppm averaged over an 20 South Coast Air Quality Management District, Air Quality Significance Thresholds, revised March 2015. 21 South Coast Air Quality Management District, Air Quality Significance Thresholds, revised March 2015. 22 For purposes of this analysis, emissions of VOC and reactive organic compounds (ROG) are used interchangeably since ROG represents approximately 99.9 percent of VOC emissions. 23 South Coast Air Quality Management District, Quality Significance Thresholds, www.aqmd.gov/docs/defaultsource/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf, last updated March 2015.
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8-hour period) and NO2 (0.18 ppm over a 1-hour period, 0.1 ppm over a 3-year average of the 98th percentile of the daily maximum 1-hour average, or 0.03 ppm averaged over an annual period).24
•
•
•
Maximum on-site localized operational PM10 and PM2.5 emissions exceed the incremental 24- hour threshold of 2.5 μg/m3 or 1.0 μg/m3 PM10 averaged over an annual period.25 The Project causes or contributes to an exceedance of the California 1-hour or 8-hour CO standards of 20 or 9.0 ppm, respectively; or
The Project creates an odor nuisance pursuant to SCAQMD Rule 402. (c) Toxic Air Contaminants
The City recommends that the determination of significance shall be made on a case-by-case basis, considering the following criteria to evaluate TACs:
• Would the project use, store, or process carcinogenic or non-carcinogenic toxic air contaminants which could result in airborne emissions?
In assessing impacts related to TACs in this section, the City uses Appendix G as the thresholds of significance. The criteria identified above will be used where applicable and relevant to assist in analyzing the Appendix G thresholds. In addition, the following criteria set forth in the SCAQMD’s CEQA Air Quality Handbook serve as quantitative air quality standards to be used to evaluate project impacts under Appendix G thresholds. Under these thresholds, a significant threshold would occur when:26 • The Project results in the exposure of sensitive receptors to carcinogenic or toxic air contaminants that exceed the maximum incremental cancer risk of 10 in one million or an acute or chronic hazard index of 1.0.27 For projects with a maximum incremental cancer risk between 1 in one million and 10 in one million, a project would result in a significant impact if the cancer burden exceeds 0.5 excess cancer cases.
(d) Consistency with Applicable Air Quality Plans
CEQA Guidelines Section 15125 requires an analysis of project consistency with applicable governmental plans and policies. This analysis is conducted to assess potential project impacts against 24 South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, revised July 2008.
25 South Coast Air Quality Management District, Final—Methodology to Calculate Particulate Matter (PM) 2.5 and PM Significance Thresholds, October 2006. 2.5
26 South Coast Air Quality Management District, CEQA Air Quality Handbook, April 1993, Chapter 6 (Determining the Air Quality Significance of a Project) and Chapter 10 (Assessing Toxic Air Pollutants). 27 Hazard index is the ratio of a toxic air contaminant’s concentration divided by its Reference Concentration, or safe exposure level. If the hazard index exceeds one, people are exposed to levels of TACs that may pose noncancer health risks.
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Threshold (a) from the Appendix G thresholds. In accordance with the SCAQMD’s CEQA Air Quality Handbook, the following criteria are used to evaluate a project’s consistency with the AQMP:28 • Will the Project result in any of the following:
–
–
–
An increase in the frequency or severity of existing air quality violations; Cause or contribute to new air quality violations; or
Delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP?
• Will the Project exceed the assumptions utilized in preparing the AQMP? – Is the Project consistent with the population and employment growth projections upon which AQMP forecasted emission levels are based;
–
–
Does the Project include air quality mitigation measures; or To what extent is Project development consistent with the AQMP land use policies? The Project’s impacts with respect to these criteria are discussed to assess the consistency with the SCAQMD’s AQMP and SCAG regional plans and policies. In addition, the Project’s consistency with the City of Santa Ana General Plan Conservation Element is discussed.
Project Design Features. The Project would comply with the 2022 California Green Building Standards Code (CalGreen, effective January 1, 2023).29 Further energy efficiency and sustainability features would include native plants and drip/subsurface irrigation systems, individual metering or sub metering for water use, leak detection systems, and electric vehicle charging capacity.
The Project’s infill location would promote the concentration of development in an urban location with extensive infrastructure and access to public transit facilities. The Project’s proximity to public transportation would reduce vehicle miles traveled for residents and visitors who want options to driving cars.
Analysis of Project Impacts
a. Would the Project conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant Impact. The Project’s air quality emissions would not exceed any state or federal standards. Therefore, the Project would not increase the frequency or severity of an existing violation or cause or contribute to new violations for these pollutants. As the Project would not exceed any of the state and federal standards, the Project would also not delay timely attainment of air quality standards or interim emission reductions specified in the AQMP.
With respect to the determination of consistency with AQMP growth assumptions, the projections in the AQMP for achieving air quality goals are based on assumptions in SCAG’s 2020-2045 RTP/SCS regarding population, housing, and growth trends. Determining whether or not a project exceeds the 28 South Coast Air Quality Management District, CEQA Air Quality Handbook, April 1993, p. 12-3. 29 California Building Codes: http://www.bsc.ca.gov/Codes.aspx.
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assumptions reflected in the AQMP involves the evaluation of three criteria: (1) consistency with applicable population, housing, and employment growth projections; (2) project mitigation measures; and (3) appropriate incorporation of AQMP land use planning strategies. The following discussion provides an analysis with respect to each of these three criteria. • Is the project consistent with the population, housing, and employment growth projections upon which AQMP forecasted emission levels are based?
A project is consistent with the AQMP, in part, if it is consistent with the population, housing, and employment assumptions that were used in the development of the AQMP. In the case of the 2022 AQMP, two sources of data form the basis for the projections of air pollutant emissions: the City of Santa Ana General Plan and SCAG’s RTP. The General Plan serves as a comprehensive, long-term plan for future development of the City.
The 2020-2045 RTP/SCS provides socioeconomic forecast projections of regional population growth.
The population, housing, and employment forecasts, which are adopted by SCAG’s Regional Council, are based on local plans and policies applicable to the specific area; these are used by SCAG in all phases of implementation and review. The 2020-2045 RTP/SCS accommodates 360,100 persons; 80,100 households; and 172,400 jobs in the City of Santa Ana by 2045.
Based on SCAG’s average 2016 persons-per-household rate for the City of 4.6 persons per household,30 the Project would add a net residential population of approximately 2,334 people to the Project Site based on the 507 dwelling units proposed. The Project’s residential population would represent approximately 11.7 percent of the forecast population growth between 2016 and 2045.
Development of the Project also would result in the removal of about 542 on-site jobs based on the 173,025 square feet of general office uses.31 Thus, the Project’s estimated employment impact would not help produce job growth that exceeds the capacity that is accommodated in the 2022 AQMP. As a result, the Project would be consistent with the projections in the AQMP. • Does the project implement feasible air quality mitigation measures? As discussed below under Thresholds (b), (c), and (d), the Project would not result in any significant air quality impacts and therefore would not require mitigation. In addition, the Project would comply with all applicable regulatory standards as required by SCAQMD. Furthermore, with compliance with the regulatory requirements identified above, no significant air quality impacts would occur. As such, the proposed Project meets this AQMP consistency criterion. • To what extent is project development consistent with the land use policies set forth in the AQMP?
30 Southern California Association of Governments; Final Connect SoCal Demographics and Growth Forecast by Jurisdiction; https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-andgrowth-forecast.pdf?1606001579. 31 Prepared by The Natelson Company, Inc. for the Southern California Association of Governments, Employment Density Study Summary Report; October 2001. Assumes 319 square feet average per general office (low-rise) employee.
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With regard to land use developments such as the Project, the AQMP’s air quality policies focus on the reduction of vehicle trips and vehicle miles traveled (VMT). The Project would serve to implement a number of land use policies of the City of Santa Ana, SCAQMD, and SCAG. The Project would be designed and constructed to support and promote environmental sustainability. The Project represents an infill development within an existing urbanized area that would concentrate more housing and population within a high quality transit area (HQTA). “Green” principles are incorporated throughout the Project to comply with the Green Building Code and the California Green Building Standards Code (CALGreen) through energy conservation, water conservation, and waste reduction features.
The air quality plan applicable to the Project area is the 2022 AQMP, the current management plan for progression toward compliance with State and federal clean air requirements. The Project would be required to comply with all regulatory measures set forth by the SCAQMD. Implementation of the Project would not interfere with air pollution control measures listed in the 2022 AQMP. In addition, as demonstrated in the following analyses, the Project would not result in significant emissions that would jeopardize regional or localized air quality standards.
The Project Site is classified as “District Center” (Medium High DC-3) in the General Plan, a classification that allows mixed-use residential, retail, and commercial development at a 3.0 Floor Area Ratio such as that proposed by the Project. 32 As such, the RTP/SCS’ assumptions about growth in the City accommodate population, housing, and job growth on the Project Site. As a result, the Project would be consistent with the growth assumptions in the City’s General Plan. Because the AQMP accommodates growth forecasts from local General Plans, the emissions associated with this Project are accounted for and mitigated in the region’s air quality attainment plans. The air quality impacts of development on the Project Site are accommodated in the region’s emissions inventory for the 2020-2045 RTP/SCS and 2022 AQMP. Therefore, Project impacts with respect to AQMP consistency would be less than significant.
City of Santa Ana Policies
The Project would offer convenient access to public transit and opportunities for walking and biking (including the provision of bicycle parking), thereby facilitating a reduction in VMT. In addition, the Project would be consistent with the existing land use pattern in the vicinity that concentrates urban density along major arterials and near transit options based on the following:
•
•
The Project Site is within a HQTA, which reflects areas with rail transit service or bus service where lines have peak headways of less than 15 minutes.33 The Project is considered a Transit Priority Project under SB 375, as it contains at least 50 percent residential uses, with a minimum net density of at least 20 dwelling units per acre, and is within 0.5 miles of a major transit stop.
• Local public transit service in the area includes:
32 City of Santa Ana General Plan Land Use Element,
https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/05/May_2023_General_Plan_Land_Use _Element.pdf.
33 Southern California Association of Governments Data Portal https://scag.ca.gov/sites/main/files/fileattachments/0903fconnectsocal_active-transportation.pdf?1606001530, Cabrillo Town Center Project
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o Orange County Transportation Authority Line 64, which runs east-west along First Street, connecting the Westminster Mall to the City of Tustin. The nearest bus stop is on 1st Street near Golden Circle Drive, approximately 900 feet south of the Project Site. o Orange County Transportation Authority Line 71, which runs north-south near the Project Site along Tustin Avenue, with the nearest bus stop at 4th Street, approximately 1,400 feet east of the Project Site.
o Santa Ana Metrolink station, approximately 4,900 feet west of the Project Site. This station accesses the Orange County and Inland Empire-Orange County lines.
The City’s General Plan Conservation Element identifies seven policies with strategies for advancing the City’s clean air goals that are applicable directly or indirectly to development projects. As illustrated in Table 5, the Project is consistent with the applicable policies in the Conservation Element, as the Project would implement sustainability features that would reduce vehicular trips, reduce VMT, and encourage the use of alternative modes of transportation. Therefore, the Project would result in a less than significant impact related to consistency with the Conservation Element.
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Table 5
Project Consistency with City of Santa Ana General Plan Conservation Element Project Consistency Strategy
Consistent. While the policy calls for the City to
promote energy-efficient design and site planning, the
Project’s site plan sets back housing from the Santa Ana Freeway and Fourth Street to maximize the buffer zone
from these sources of vehicular emissions.
Policy CN-1.4: Development Standards.
Support new development that meets or
exceeds standards for energy-efficient building
design and site planning.
Consistent. While the policy calls for the City to
promote land use planning that protects sensitive
receptors from air quality impacts, the Project’s site plan sets back housing from the Santa Ana Freeway and
Policy CN-1.5: Sensitive Receptor Decisions.
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 Fourth Street to maximize the buffer zone from these adopt new regulations avoiding the siting of sources of vehicular emissions. It should be noted that facilities that potentially emit increased pollution the Project lies outside the 24 census tracts in the City near sensitive receptors within environmental
justice area boundaries.
that are considered environmental justice
communities.34
Consistent. The Proposed Project is located in an infill location and would redevelop a low-density office park
with needed housing supply that is located near major
activity centers along 1st Street and 4th Street, with
access to the Santa Ana Metrolink Station.
Policy CN-1.6: New and Infill Residential
Development. Promote development that is
mixed use, pedestrian friendly, transit oriented,
and clustered around activity centers.
Consistent. The Proposed Project is located would
improve the supply of housing along the Fourth Street
corridor, which is largely flanked by commercial. Uses
Policy CN-1.7: Housing
Opportunities. Improve the city’s jobs/housing
and Employment
balance ratio by supporting development that and provides both local and Citywide balance between. provides housing and employment opportunities Housing and jobs. The Project also increases the to enable people to live and work in Santa Ana. diversity of housing options, with studio units, townhomes, and live/work units.
Policy CN-1.8: Promote Alternative
Transportation. Promote use of alternate modes
of transportation in the City of Santa Ana,
Consistent. The Proposed Project would include shortand long-term bicycle parking for residents and the commercial tenants. The Project would also provide 81
electric vehicle charging stations for residents and
another nine for guests.
including pedestrian, bicycling, public
transportation, car sharing programs, and
emerging technologies.
Policy CN-14: Transportation
Management. Require and incentivize projects
to incorporate transportation demand
management techniques.
Demand Consistent. The Proposed Project would include shortand long-term bicycle parking for residents and the commercial tenants.
Consistent. As the Project Site is 750 feet east of the Santa Ana Freeway, its site plan includes an indoor club room, indoor fitness room, as well as outdoor pools
located in central courtyards that are both set back from the freeway and shielded by the internal buildings on the Project Site.
Policy CN-17: Indoor Recreation. Encourage
new development to provide indoor recreation
space when located in areas with high levels of
localized air pollution or if site is adjacent to
freeways or heavy industrial uses.
Source: DKA Planning, 2023.
34 City of Santa Ana, Environmental Justice Community Maps; https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/Environmental-Justice-CommunitiesMap_20211015v2.pdf, Cabrillo Town Center Project
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b. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Less Than Significant Impact.
Construction
A cumulatively considerable net increase would occur if the project’s construction impacts substantially contribute to air quality violations when considering other projects that may undertake construction activities at the same time. Individual projects that generate emissions that do not exceed SCAQMD’s significance thresholds would not contribute considerably to any potential cumulative impact. SCAQMD neither recommends quantified analyses of the emissions generated by a set of cumulative development projects nor provides thresholds of significance to assess the impacts associated with these emissions.35 Construction-related emissions were estimated using the SCAQMD’s CalEEMod 2022.1.1.14 model and a projected construction schedule of at least 36 months. Table 5 summarizes the estimated construction schedule that was modeled for air quality impacts.
Table 6
Construction Schedule Assumptions
Phase
Demolition
Duration Notes
Removal of 6,000 tons of demolition debris in 10-cubic yard capacity trucks, hauled up to 20 miles to the Olinda Alpha Landfill.
Months 1-2
Month 3 (one
week)
Grubbing and removal of trees, plants, landscaping, weeds over a 64,000 square-foot area Site Preparation
Grading Approximately 400 cubic yards of soil hauled 20 miles to Olinda Alpha Landfill in 14-cubic yard capacity trucks. Months 3-5 Trenching for utilities, including gas, water, electricity, and telecommunications. Trenching
Paving
Months 6-8
Months 9-11 Flatwork, including paving of driveways and walkways Footings and foundation work (e.g., pouring concrete pads), framing, welding; installing mechanical, electrical, and plumbing. Floor assembly, cabinetry and carpentry, elevator installations, low voltage systems, trash management.
Months 12-
36 Building Construction
Architectural Coatings Months 33-
36 Application of interior and exterior coatings and sealants.
Source: DKA Planning, 2023.
35 South Coast Air Quality Management District, 2003 White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution: “As Lead Agency, the AQMD uses the same significance thresholds for project specific and cumulative impacts for all environmental topics analyzed in an Environmental Assessment or EIR…Projects that exceed the project-specific significance threshold are considered by the SCAQMD to be cumulatively considerable. This is the reason project-specific and cumulative thresholds are the same.
Conversely, projects that do not exceed the project-specific thresholds are not considered to be cumulatively significant.
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The Project would be required to comply with the following regulations, as applicable:
• SCAQMD Rule 403, would reduce the amount of particulate matter entrained in ambient air as a result of anthropogenic fugitive dust sources by requiring actions to prevent, reduce or mitigate fugitive dust emissions.
•
•
SCAQMD Rule 1113, which limits the VOC content of architectural coatings.
SCAQMD Rule 402, which states that a person shall not discharge from any source whatsoever such quantities of air contaminants or other materials which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health, or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. •
•
In accordance with Section 2485 in Title 13 of the California Code of Regulations, the idling of all diesel-fueled commercial vehicles (with gross vehicle weight over 10,000 pounds) during construction would be limited to five minutes at any location.
In accordance with Section 93115 in Title 17 of the California Code of Regulations, operation of any stationary, diesel-fueled, compression-ignition engines would meet specific fuel and fuel additive requirements and emissions standards.
Regional Emissions
Construction activity creates air quality impacts through the use of heavy-duty construction equipment and through vehicle trips generated by construction workers traveling to and from the Project Site. NOX emissions would primarily result from the use of construction equipment and truck trips.
Fugitive dust emissions would peak during grading activities, where approximately 400 cubic yards of soil would be exported from the Project Site. All construction projects in the Basin must comply with SCAQMD Rule 403 for fugitive dust. Rule 403 control requirements include measures to prevent the generation of visible dust plumes. Measures include, but are not limited to, applying water and/or soil binders to uncovered areas, reestablishing ground cover as quickly as possible, utilizing a wheel washing system or other control measures to remove bulk material from tires and vehicle undercarriages before vehicles exit the Project Site, and maintaining effective cover over exposed areas. Compliance with Rule 403 would reduce regional PM2.5 and PM10 emissions associated with construction activities by approximately 61 percent.
During the building finishing phase, the application of architectural coatings (e.g., paints) would release VOCs (regulated by SCAQMD Rule 1113). The assessment of construction air quality impacts considers each of these potential sources. Construction emissions can vary substantially from day to day, depending on the level of activity, the specific type of operation and, for dust, the prevailing weather conditions.
As shown in Table 7, construction of the Project would produce VOC, NO , CO, SO , PM and PM
2.5 X X 10
emissions that do not exceed the SCAQMD’s regional thresholds. As a result, construction of the Project Cabrillo Town Center Project
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would not contribute substantially to an existing violation of air quality standards for regional pollutants (e.g., ozone). This impact is considered less than significant.
Localized Emissions
In addition to maximum daily regional emissions, maximum localized (on-site) emissions were quantified for each construction activity. The localized construction air quality analysis was conducted using the methodology promulgated by the SCAQMD. Look-up tables provided by the SCAQMD were used to determine localized construction emissions thresholds for the Project.36 LSTs represent the maximum emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard and are based on the most recent background ambient air quality monitoring data (2019-2021) for the Project area.
Table 7
Daily Construction Emissions
Daily Emissions (Pounds Per Day)
Construction Phase Year VOC
3.8 NOX
38.6 29.8
15.5 15.7
CO SOX
0.1 0.1
0.1 0.1
PM10
10.0 8.3
PM2.5
2024 5.6
2025
2026
2027
34.9 44.1
42.3 46.7
3.3 2.6
2.9 8.2 2.2
63.2 9.6 2.5
Maximum Regional Total
Regional Threshold
63.2 75
38.6 100
No
46.7 550
No
0.1 150
No
10.0 150
No
5.6 55
Exceed Threshold? No No
Maximum Localized Total
Localized Threshold
Exceed Threshold?
57.5 N/A
N/A
33.0 183
No
21.7 1,253
No
0.1 N/A
N/A
4.1 13
1.8 7
No No
The construction dates are used for the modeling of air quality emissions in the CalEEMod software. If construction activities commence later than what is assumed in the environmental analysis, the actual emissions would be lower than analyzed because of the increasing penetration of newer equipment with lower certified emission levels.
Assumes implementation of SCAQMD Rule 403 (Fugitive Dust Emissions) Source: DKA Planning, 2023 based on CalEEMod 2022.1.1.14 model runs. LST analyses based on five-acre site with 25-meter distances to receptors in Central Orange County source receptor area. Estimates reflect the peak summer or winter season, whichever is higher. Totals may not add up due to rounding. Modeling sheets included in the Technical Appendix.
Maximum on-site daily construction emissions for NO , CO, PM , and PM were calculated using X 10 2.5 CalEEMod and compared to the applicable SCAQMD LSTs for the Central Orange County SRA based on construction site acreage that is five acres in area, the highest site area identified by SCAQMD for their LSTs. Potential impacts were evaluated at the closest off-site sensitive receptor, which is Cabrillo 36 South Coast Air Quality Management District, LST Methodology Appendix C-Mass Rate LST Look-up Table, revised October 2009.
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Park immediately north of the Project Site. The closest receptor distance on the SCAQMD mass rate LST look-up tables is 25 meters.
As shown in Table 7, above, the Project would produce emissions that do not exceed the SCAQMD’s recommended localized standards of significance for NO2 and CO during the construction phase.
Similarly, construction activities would not produce PM10 and PM2.5 emissions that exceed localized thresholds recommended by the SCAQMD. These estimates assume the use of Best Available Control Measures (BACMs) that address fugitive dust emissions of PM and PM through SCAQMD Rule 403. 10 2.5 This would include watering portions of the site that are disturbed during grading activities and minimizing tracking of dirt onto local streets. Therefore, construction impacts on localized air quality are considered less than significant.
Operation
Operational emissions of criteria pollutants would come from area, energy, and mobile sources. Area sources include consumer products such as household cleaners, architectural coatings for routine maintenance, and landscaping equipment. Energy sources include electricity and natural gas use for space cooling and heating and water heating.37 The CalEEMod program generates estimates of emissions from energy use based on the land use type and size. The Project would also produce longterm air quality impacts to the region primarily from motor vehicles that access the Project Site. The Project could add up to 875 net vehicle trips to the local roadway network on a weekday at the start of operations in 2027, considering the removal of the existing commercial auto center.38 As shown in Table 8, the Project’s emissions would not exceed the SCAQMD’s regional or localized significance thresholds. Therefore, the operational impacts of the Project on regional and localized air quality are considered less than significant.
c. Expose sensitive receptors to substantial pollutant concentrations? Less Than Significant Impact. There are several sensitive receptors within 0.25 miles of the Project Site that could be exposed to air pollution from construction and operation of the Project, including, but are not limited to, the following representative sampling:
•
•
•
•
Cabrillo Park, 1820 East Fruit Street; directly north of the Project Site.
Residences, 724 North Parkcenter Drive; 80 feet northeast of the Project Site Residences, 618 Sherry Lane; 400 feet west of the Project Site.
Residences, 1901 East First Street; 450 feet south of the Project Site. 37 When electricity is used in buildings or local developments, electricity generation typically takes place offsite at power plants.
38 Linscott Law & Greenspan, Memorandum: Vehicle Miles Traveled Assessment for the Proposed Cabrillo Town Center Mixed-Use Project; June 27, 2023.
Cabrillo Town Center Project
Air Quality Technical Report
PAGE 29 City of Santa Ana
July 2023 City Council 18 – 675 10/3/2023
Table 8
Daily Operations Emissions
Daily Emissions (Pounds Per Day)
Emissions Source VOC
28.6 0.1
NOX
0.6 1.7
6.3 8.6
-7.0
1.6 55
CO
45.2 0.8
SOX
<0.1
<0.1
0.2 PM10
0.1 PM2.5
0.1 0.1
5.1 5.2
-3.6
1.6 55
Area Sources
Energy Sources 0.1
Mobile Sources 8.5 74.9
121.0
-71.4
49.6 550
19.6 19.8
-13.5
6.3 Regional Total 37.2
-12.3
24.9 55
0.2 Existing Total -0.2
<0.1
150
No
Net Regional Total
Regional Significance Threshold
Exceed Threshold?
150
No No No No No
Net Localized Total
Localized Significance Threshold
Exceed Threshold?
28.7 N/A
N/A
2.3 183
No
46.0 1,253
No
<0.1
N/A
N/A
0.2 3
0.2 2
No No
LST analyses based on five-acre site with 25-meter distances to receptors in Central Orange County SRA
Source: DKA Planning, 2023 based on CalEEMod 2022.1.1.14 model runs (included in the Technical Appendix). Totals reflect the summer season maximum and may not add up due to rounding.
Construction
Construction of the Project could expose sensitive receptors to substantial pollutant concentrations if maximum daily emissions of regulated pollutants generated by sources located on and/or near the Project Site exceeded the applicable LST values presented in Table 4, or if construction activities generated significant emissions of TACs that could result in carcinogenic risks or non-carcinogenic hazards exceeding the SCAQMD Air Quality Significance Thresholds of 10 excess cancers per million or non-carcinogenic Hazard Index greater than 1.0, respectively. As discussed above, the LST values were derived by the SCAQMD for the criteria pollutants NO , CO, PM , and PM to prevent the occurrence of concentrations X 10 2.5 exceeding the air quality standards at sensitive receptor locations based on proximity and construction site size.
As shown in Table 7, during construction of the Project, maximum daily localized unmitigated emissions of NO , CO, PM , and PM from sources on the Project Site would remain below each of the respective 2 10 2.5 LST values. Unmitigated maximum daily localized emissions would not exceed any of the localized standards for receptors that are within 25 meters of the Project’s construction activities. Therefore, based on SCAQMD guidance, localized emissions of criteria pollutants would not have the potential to expose sensitive receptors to substantial concentrations that would present a public health concern.
The primary TAC that would be generated by construction activities is diesel PM, which would be released from the exhaust stacks of construction equipment. The construction emissions modeling conservatively assumed that all equipment present on the Project Site would be operating simultaneously throughout most of the day, while in all likelihood this would rarely be the case. Average daily emissions of diesel PM would be less than one pound per day throughout the course of Project construction. Therefore, the magnitude of Cabrillo Town Center Project
Air Quality Technical Report
PAGE 30 City of Santa Ana
July 2023 City Council 18 – 676 10/3/2023
daily diesel PM emissions, would not be sufficient to result in substantial pollutant concentrations at off-site locations nearby.
Furthermore, according to SCAQMD methodology, health risks from carcinogenic air toxics are usually described in terms of individual cancer risk. “Individual Cancer Risk” is the likelihood that a person exposed to concentrations of TACs over a 30-year period will contract cancer based on the use of standard riskassessment methodology. The entire duration of construction activities associated with implementation of the Project is anticipated to be approximately 36 months, and the magnitude of daily diesel PM emissions will vary over this time period. No residual emissions and corresponding individual cancer risk are anticipated after construction. Because there is such a short-term exposure period, construction TAC emissions would result in a less than significant impact. Therefore, construction of the Project would not expose sensitive receptors to substantial diesel PM concentrations, and this impact would be less than significant.
Operation
The Project Site would be redeveloped with multi-family residences, retail, and office uses, land uses that are not typically associated with TAC emissions. Typical sources of acutely and chronically hazardous TACs include industrial manufacturing processes (e.g., chrome plating, electrical manufacturing, petroleum refinery). The Project would not include these types of potential industrial manufacturing process sources. It is expected that quantities of hazardous TACs generated on-site (e.g., cleaning solvents, paints, landscape pesticides) for the types of proposed land uses would be below thresholds warranting further study under California Accidental Release Program.
When considering potential air quality impacts under CEQA, consideration is given to the location of sensitive receptors within close proximity of land uses that emit TACs. CARB has published and adopted the Air Quality and Land Use Handbook: A Community Health Perspective, which provides recommendations regarding the siting of new sensitive land uses near potential sources of air toxic emissions (e.g., freeways, distribution centers, rail yards, ports, refineries, chrome plating facilities, dry cleaners, and gasoline dispensing facilities).39 The SCAQMD adopted similar recommendations in its Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning.40 Together, the CARB and SCAQMD guidelines recommend siting distances for both the development of sensitive land uses in proximity to TAC sources and the addition of new TAC sources in proximity to existing sensitive land uses.
The primary sources of potential air toxics associated with Project operations include DPM from delivery trucks (e.g., truck traffic on local streets and idling on adjacent streets) and to a lesser extent, facility operations (e.g., natural gas fired boilers). However, these activities, and the land uses associated with the Project, are not considered land uses that generate substantial TAC emissions. It should be noted that the SCAQMD recommends that health risk assessments (HRAs) be conducted for substantial individual sources of DPM (e.g., truck stops and warehouse distribution facilities that generate more than 100 trucks per day or more than 40 trucks with operating transport refrigeration units) and has 39 California Air Resources Board, Air Quality and Land Use Handbook, a Community Health Perspective, April 2005.
40 South Coast Air Quality Management District, Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning, May 6, 2005.
Cabrillo Town Center Project
Air Quality Technical Report
PAGE 31 City of Santa Ana
July 2023 City Council 18 – 677 10/3/2023
provided guidance for analyzing mobile source diesel emissions.41 Based on this guidance, the Project would not include these types of land uses and is not considered to be a substantial source of DPM warranting a refined HRA since daily truck trips to the Project Site would not exceed 100 trucks per day or more than 40 trucks with operating transport refrigeration units. In addition, the CARB-mandated airborne toxic control measures (ATCM) limits diesel-fueled commercial vehicles (delivery trucks) to idle for no more than five minutes at any given time, which would further limit diesel particulate emissions.
As the Project would not contain substantial TAC sources and is consistent with the CARB and SCAQMD guidelines, the Project would not result in the exposure of off-site sensitive receptors to carcinogenic or toxic air contaminants that exceed the maximum incremental cancer risk of 10 in one million or an acute or chronic hazard index of 1.0, and potential TAC impacts would be less than significant.
The Project would generate long-term emissions on-site from area and energy sources that would generate negligible pollutant concentrations of CO, NO , PM , or PM at nearby sensitive receptors. 2 2.5 10 While long-term operations of the Project would add traffic to local roads that produces off-site emissions, these would not result in exceedances of CO air quality standards at roadways in the area due to three key factors. First, CO hotspots are extremely rare and only occur in the presence of unusual atmospheric conditions and extremely cold conditions, neither of which applies to this Project area.
Second, auto-related emissions of CO continue to decline because of advances in fuel combustion technology in the vehicle fleet. Finally, the Project would not contribute to the levels of congestion that would be needed to produce emissions concentrations needed to trigger a CO hotspot, as it would add 875 vehicle trips to the local roadway network on weekdays when the development could be leased and operational in 2027. 42 However, peak hour vehicle travel would generally reduce from existing conditions, as traffic to and from Project Site would reduce by 50 trips and zero trips during the peak A.M. and P.M. hours, respectively.43 This would represent a reduction in peak hour traffic, which would benefit arterials like Fourth Street between Tustin Avenue and Cabrillo Park Drive, which carry 23,828 vehicles during a weekday.44 This would help reduce any potential that traffic volumes would generate CO exceedances of the ambient air quality standard.45
Finally, the Project would not result in any substantial emissions of TACs during the construction or operations phase. During the construction phase, the primary air quality impacts would be associated with the combustion of diesel fuels, which produce exhaust-related particulate matter that is considered 41 South Coast Air Quality Management District, Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis, 2002. 42 Linscott Law & Greenspan, Memorandum: Vehicle Miles Traveled Assessment for the Proposed Cabrillo Town Center Mixed-Use Project; June 27, 2023.
43 Ibid.
44 City of Santa. Ana GIS Open Data portal, accessed July 26, 2023. 2015 traffic counts adjusted by a one percent adjustment to reflect ambient traffic growth. https://gis-santaana.opendata.arcgis.com/datasets/927f0b948fcf400eaf1c13d35239a7b1/explore?location=33.749256%2C117.838786%2C17.62 45 South Coast Air Quality Management District; 2003 AQMP. As discussed in the 2003 AQMP, the 1992 CO Plan included a CO hotspot analysis at four intersections in the peak A.M. and P.M. time periods, including Long Beach Boulevard and Imperial Highway (Lynwood), Wilshire Boulevard and Veteran Avenue (Westwood), Sunset Boulevard and Highland Avenue (Hollywood), and La Cienega Boulevard and Century Boulevard (Inglewood). The busiest intersection was Wilshire and Veteran, used by 100,000 vehicles per day.
The 2003 AQMP estimated a 4.6 ppm one-hour concentration at this intersection, which meant that an exceedance (20 ppm) would not occur until daily traffic exceeded more than 400,000 vehicles per day.
Cabrillo Town Center Project
Air Quality Technical Report
PAGE 32 City of Santa Ana
July 2023 City Council 18 – 678 10/3/2023
a toxic air contaminant by CARB based on chronic exposure to these emissions. 46 However, construction activities would not produce chronic, long-term exposure to diesel particulate matter. During long-term project operations, the Project does not include typical sources of acutely and chronically hazardous TACs such as industrial manufacturing processes and automotive repair facilities. As a result, the Project would not create substantial concentrations of TACs.
In addition, the SCAQMD recommends that health risk assessments be conducted for substantial sources of diesel particulate emissions (e.g., truck stops and warehouse distribution facilities) and has provided guidance for analyzing mobile source diesel emissions.47 The Project would not generate a substantial number of truck trips. Based on the limited activity of TAC sources, the Project would not warrant the need for a health risk assessment associated with on-site activities. Therefore, the Project’s operational impacts on local sensitive receptors would be less than significant. d. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less Than Significant Impact. The Project would not result in activities that create objectionable odors.
The Project is a housing, retail, and office development that would not include any activities typically associated with unpleasant odors and local nuisances (e.g., rendering facilities, dry cleaners). SCAQMD regulations that govern nuisances (i.e., Rule 402, Nuisances) would regulate any occasional odors associated with any of the proposed land uses. As a result, any odor impacts from the Project would be considered less than significant.
46 California Office of Environmental Health Hazard Assessment. Health Effects of Diesel Exhaust. www. http://oehha.ca.gov/public_info/facts/dieselfacts.html
47 South Coast Air Quality Management District, Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Emissions, December 2002.
Cabrillo Town Center Project
Air Quality Technical Report
PAGE 33 City of Santa Ana
July 2023 City Council 18 – 679 10/3/2023
TECHNICAL APPENDIX
City Council 18 – 680 10/3/2023
EXISTING EMISSIONS
City Council 18 – 681 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Cabrillo Town Center (Existing) Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
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City Council 18 – 682 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
4.3.2. Unmitigated
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
4.5. Waste Emissions by Land Use
4.5.2. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated 2 / 26
City Council 18 – 683 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
5. Activity Data
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.15. Operational Off-Road Equipment
3 / 26
City Council 18 – 684 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
4 / 26
City Council 18 – 685 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
5 / 26
City Council 18 – 686 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name
Operational Year
Lead Agency
Land Use Scale
Analysis Level for Defaults
Windspeed (m/s)
Precipitation (days)
Location
Cabrillo Town Center (Existing)
2023
City of Santa Ana
Project/site
County
2.50 18.6
1901 E 4th St, Santa Ana, CA 92705, USA
County Orange
City Santa Ana
Air District South Coast AQMD
South Coast
5962
Air Basin
TA Z
EDFZ 7
Electric Utility
Gas Utility
Southern California Edison
Southern California Gas
App Version 2022.1.1.14
1.2. Land Use Types
Land Use Subtype Size
173
Unit Lot Acreage
8.97 Building Area (sq ft) Landscape Area (sq Special Landscape Population —
Description
—
ft) Area (sq ft)
General Office
Building
1000sqft 173,025 0.00 —
6 / 26
City Council 18 – 687 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected
2. Emissions Summary
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Unmit. 12.3
—
6.95 —
71.4 —
0.16 —
0.20 —
13.3 —
13.5 —
0.19 —
3.37 —
3.56 Daily, Winter —
(Max)
Unmit. 11.0
—
7.40 —
59.1 —
0.15 —
0.18 —
13.3 —
13.5 —
0.18 —
3.37 —
3.55 Average Daily —
(Max)
Unmit. 11.8
—
7.52 —
65.8 —
0.15 —
0.19 —
13.3 —
13.5 —
0.18 —
3.37 —
3.55 Annual (Max) —
Unmit. 2.15 1.37 12.0 0.03 0.04 2.42 2.46 0.03 0.62 0.65
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Mobile
Area
6.86 5.38
0.06 —
5.71 0.06
1.18 —
62.9 7.52
0.99 —
0.15 < 0.005
0.01 —
0.09 0.01
0.09 —
13.3 —
13.4 0.01
0.09 —
0.09 0.01
0.09 —
3.37 —
3.46 0.01
0.09 —
Energy
Water
— —
— —
7 / 26
City Council 18 – 688 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Waste
Refrig.
Total
— — — — — — — — — —
— — — — — — — — — —
12.3 —
6.95 —
71.4 —
0.16 —
0.20 —
13.3 —
13.5 —
0.19 —
3.37 —
3.56 Daily, Winter —
(Max)
Mobile
Area
6.78 4.14
0.06 —
6.22 —
58.1 —
0.14 —
0.09 —
13.3 —
13.4 —
0.09 —
3.37 —
3.46 —
Energy
Water
Waste
Refrig.
Total
1.18 —
0.99 —
0.01 —
0.09 —
— 0.09
—
0.09 —
— 0.09
— — —
— — — — — — — — — —
— — — — — — — — — —
11.0 —
7.40 —
59.1 —
0.15 —
0.18 —
13.3 —
13.5 —
0.18 —
3.37 —
3.55 Average Daily —
Mobile
Area
6.74 4.99
0.06 —
6.29 0.04
1.18 —
59.6 5.15
0.99 —
0.14 < 0.005
0.01 —
0.09 0.01
0.09 —
13.3 —
13.4 0.01
0.09 —
0.09 0.01
0.09 —
3.37 —
3.46 0.01
0.09 —
Energy
Water
Waste
Refrig.
Total
— —
— —
— — — — — — — — — —
— — — — — — — — — —
11.8 —
7.52 —
65.8 —
0.15 —
0.19 —
13.3 —
13.5 —
0.18 —
3.37 —
3.55 Annual —
Mobile
Area
1.23 0.91
0.01 —
1.15 0.01
0.21 —
10.9 0.94
0.18 —
0.03 < 0.005
< 0.005
—
0.02 < 0.005
0.02 —
2.42 —
2.44 < 0.005
0.02 —
0.02 < 0.005
0.02 —
0.62 —
0.63 < 0.005
0.02 —
Energy
Water
Waste
Refrig.
Total
— —
— —
— — — — — — — — — —
— — — — — — — — — —
2.15 1.37 12.0 0.03 0.04 2.42 2.46 0.03 0.62 0.65
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City Council 18 – 689 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Mobile source emissions results are presented in Sections 2.6. No further detailed breakdown of emissions is available.
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
General Office
Building
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
General Office
Building
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
General Office
Building
Total — — — — — — — — — —
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E
9 / 26
City Council 18 – 690 PM10D PM10T PM2.5E PM2.5D 10/3/2023 PM2.5T Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Daily, Summer
(Max)
— — — — — —
—
— — —
—
—
General Office
Building
0.06 1.18 0.99 0.01 0.09 0.09 0.09 0.09
Total 0.06
—
1.18 —
0.99 —
0.01 —
0.09 —
—
—
0.09 —
0.09 —
—
—
0.09 Daily, Winter —
(Max)
General Office
Building
0.06 1.18 0.99 0.01 0.09 — 0.09 0.09 — 0.09
Total 0.06
—
1.18 —
0.99 —
0.01 —
0.09 —
—
—
—
0.09 —
0.09 —
—
—
—
0.09 Annual —
General Office
Building
0.01 0.21 0.18 < 0.005 0.02 0.02 0.02 0.02
Total 0.01 0.21 0.18 < 0.005 0.02 — 0.02 0.02 — 0.02
4.3. Area Emissions by Source
4.3.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Consumer
Products
3.70 0.44
1.23 — — — — —
—
—
— — —
—
—
—
Architectural
Coatings
— — — — — — —
Landscape
Equipment
0.06 7.52 < 0.005 0.01 0.01 0.01 0.01
Total 5.38
—
0.06 —
7.52 —
< 0.005
—
0.01 —
—
—
0.01 —
0.01 —
—
—
0.01 Daily, Winter —
(Max)
10 / 26
City Council 18 – 691 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Consumer
Products
3.70 0.44
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Architectural —
Coatings
Total 4.14
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Consumer
Products
0.68 Architectural
Coatings
0.08 0.15
0.91 — — — — —
—
—
— — —
—
—
—
Landscape
Equipment
0.01 0.01
0.94 0.94
< 0.005
< 0.005
< 0.005
< 0.005
< 0.005
< 0.005
< 0.005
< 0.005
< 0.005
Total < 0.005
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
General Office
Building
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
General Office
Building
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual —
11 / 26
City Council 18 – 692 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Total —
4.5. Waste Emissions by Land Use
4.5.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
General Office
Building
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
General Office
Building
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
General Office
Building
Total — — — — — — — — — —
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T 12 / 26
City Council 18 – 693 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Daily, Summer
(Max)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
General Office —
Building
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
General Office
Building
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
General Office
Building
Total — — — — — — — — — —
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
—
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.8. Stationary Emissions By Equipment Type
13 / 26
City Council 18 – 694 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
—
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
—
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.10. Soil Carbon Accumulation By Vegetation Type
14 / 26
City Council 18 – 695 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T 15 / 26
City Council 18 – 696 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Daily, Summer
(Max)
— — — — — — — — — —
Avoided
Subtotal
Sequestered
Subtotal
Removed
Subtotal
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Avoided
Subtotal
Sequestered
Subtotal
Removed
Subtotal
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Avoided
Subtotal
Sequestered
Subtotal
Removed
Subtotal
—
16 / 26
City Council 18 – 697 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
5. Activity Data
5.9. Operational Mobile Sources
5.9.1. Unmitigated
Land Use Type Trips/Weekday
1,876
Trips/Saturday
1,876
Trips/Sunday
1,876
Trips/Year
684,740
VMT/Weekday
18,760
VMT/Saturday
18,760
VMT/Sunday
18,760
VMT/Year
Total all Land Uses 6,847,400
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq ft)
Non-Residential Exterior Area Coated Parking Area Coated (sq ft) (sq ft)
0 0.00 259,538 86,513 —
5.10.3. Landscape Equipment
Season Unit Value
0.00 250
Snow Days
Summer Days
day/yr
day/yr
5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) 17 / 26
City Council 18 – 698 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Land Use Electricity (kWh/yr)
3,083,355
CO2
349
CH4 N2O Natural Gas (kBTU/yr)
General Office Building 0.0330 0.0040 4,385,573
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) General Office Building 30,752,382 0.00
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year)
161
Cogeneration (kWh/year)
General Office Building —
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP
1,430
Quantity (kg)
0.02 Operations Leak Rate Service Leak Rate Times Serviced General Office Building Household refrigerators R-134a 1.00 and/or freezers
0.60 0.00
General Office Building Other commercial A/C
and heat pumps
R-410A 2,088 < 0.005 4.00 4.00 18.0
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day
18 / 26
City Council Hours Per Day Horsepower Load Factor 18 – 699 10/3/2023 Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)
5.17. User Defined
Equipment Type Fuel Type
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
19 / 26
City Council 18 – 700 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat
Extreme Precipitation
Sea Level Rise
9.03 3.50
0.00 1.31
annual days of extreme heat
annual days with precipitation above 20 mm
meters of inundation depth
Wildfire annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider different increments of sea level rise coupled with extreme storm events. Users may select from four model simulations to view the range in potential inundation depth for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 50 meters (m) by 50 m, or about 164 feet (ft) by 164 ft.
Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
6.2. Initial Climate Risk Scores
Climate Hazard
Temperature and Extreme Heat
Extreme Precipitation
Sea Level Rise
Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score 0 0 0 N/A
N/A
N/A
N/A
N/A
N/A
0 N/A
0 N/A
0 Wildfire 0 0 0
Flooding N/A N/A N/A
20 / 26
City Council 18 – 701 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Drought N/A
N/A
0 N/A
N/A
0 N/A
N/A
0 N/A
N/A
N/A
Snowpack Reduction
Air Quality Degradation
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.
6.3. Adjusted Climate Risk Scores
Climate Hazard
Temperature and Extreme Heat
Extreme Precipitation
Sea Level Rise
Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score 1 1 1 2
N/A
1 N/A
1 N/A
1 N/A
2 Wildfire 1 1 1 2
Flooding N/A
N/A
N/A
1 N/A
N/A
N/A
1 N/A
N/A
N/A
1 N/A
N/A
N/A
2 Drought
Snowpack Reduction
Air Quality Degradation
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. 21 / 26
City Council 18 – 702 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Indicator Result for Project Census Tract
Exposure Indicators
AQ-Ozone
—
57.8 73.8
85.3 53.8
71.1 0.00
90.8 98.3
—
AQ-PM
AQ-DPM
Drinking Water
Lead Risk Housing
Pesticides
Toxic Releases
Traffic
Effect Indicators
CleanUp Sites
Groundwater
91.8 0.00
82.8 0.00
22.1 —
Haz Waste Facilities/Generators
Impaired Water Bodies
Solid Waste
Sensitive Population
Asthma 55.8
47.8 41.7
—
Cardio-vascular
Low Birth Weights
Socioeconomic Factor Indicators
Education 75.4
48.1 66.9
54.4 28.2
Housing
Linguistic
Poverty
Unemployment
22 / 26
City Council 18 – 703 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic —
Above Poverty
Employed
55.40870012
82.72808931
52.89362248
—
Median HI
Education
Bachelor's or higher
High school enrollment
Preschool enrollment
Transportation
Auto Access
35.41639933
100
31.82343128
—
58.09059412
62.68446041
—
Active commuting
Social
2-parent households
Voting
93.16052868
23.85474143
Neighborhood —
Alcohol availability
Park access
53.74053638
48.29975619
98.84511741
72.33414603
38.34210189
—
Retail density
Supermarket access
Tree canopy
Housing
Homeownership
Housing habitability
Low-inc homeowner severe housing cost burden
37.89298088
43.38508918
27.93532658
23 / 26
City Council 18 – 704 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Low-inc renter severe housing cost burden
Uncrowded housing
Health Outcomes
78.69883229
20.37726165
—
Insured adults 24.71448736
Arthritis 67.1
Asthma ER Admissions
High Blood Pressure
Cancer (excluding skin)
Asthma
50.7 72.3
55.0 49.0
Coronary Heart Disease
Chronic Obstructive Pulmonary Disease
Diagnosed Diabetes
Life Expectancy at Birth
Cognitively Disabled
Physically Disabled
Heart Attack ER Admissions
Mental Health Not Good
Chronic Kidney Disease
Obesity
61.0 53.7
54.0 67.7
95.5 83.0
78.0 41.5
45.1 51.8
Pedestrian Injuries 60.5
Physical Health Not Good
Stroke
44.3 58.2
Health Risk Behaviors
Binge Drinking
—
15.4 Current Smoker 44.4
No Leisure Time for Physical Activity
Climate Change Exposures
40.3 —
24 / 26
City Council 18 – 705 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 Wildfire Risk 0.0
SLR Inundation Area
Children
0.0 64.0
60.7 29.3
72.2 33.6
—
Elderly
English Speaking
Foreign-born
Outdoor Workers
Climate Change Adaptive Capacity
Impervious Surface Cover
Traffic Density
46.9 99.3
23.0 —
Traffic Access
Other Indices
Hardship 66.1
Other Decision Support —
2016 Voting 58.2
7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 71.0
57.0 No
Healthy Places Index Score for Project Location (b)
Project Located in a Designated Disadvantaged Community (Senate Bill 535) Project Located in a Low-Income Community (Assembly Bill 1550) Project Located in a Community Air Protection Program Community (Assembly Bill 617) Ye s
No
a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
25 / 26
City Council 18 – 706 10/3/2023
Cabrillo Town Center (Existing) Detailed Report, 7/26/2023 No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
Land Use Project plan
26 / 26
City Council 18 – 707 10/3/2023
City Council 18 – 708 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Cabrillo Town Center (Future) Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
3. Construction Emissions Details
3.1. Demolition (2024) - Unmitigated
3.3. Site Preparation (2024) - Unmitigated
3.5. Grading (2024) - Unmitigated
3.7. Grading (2025) - Unmitigated
1 / 55
City Council 18 – 709 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
3.9. Building Construction (2025) - Unmitigated
3.11. Building Construction (2026) - Unmitigated
3.13. Building Construction (2027) - Unmitigated
3.15. Paving (2025) - Unmitigated
3.17. Architectural Coating (2027) - Unmitigated
3.19. Trenching (2025) - Unmitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
4.3.2. Unmitigated
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
4.5. Waste Emissions by Land Use
2 / 55
City Council 18 – 710 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
4.5.2. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
3 / 55
City Council 18 – 711 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
4 / 55
City Council 18 – 712 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5 / 55
City Council 18 – 713 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
6 / 55
City Council 18 – 714 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name
Construction Start Date
Operational Year
Lead Agency
Land Use Scale
Analysis Level for Defaults
Windspeed (m/s)
Precipitation (days)
Location
Cabrillo Town Center (Future)
9/2/2024
2027
City of Santa Ana
Project/site
County
2.50 18.6
1901 E 4th St, Santa Ana, CA 92705, USA
County Orange
City Santa Ana
Air District South Coast AQMD
South Coast
5962
Air Basin
TA Z
EDFZ 7
Electric Utility
Gas Utility
Southern California Edison
Southern California Gas
App Version 2022.1.1.14
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq Special Landscape Population Description ft) Area (sq ft)
7 / 55
City Council 18 – 715 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Apartments Mid Rise 449 Dwelling Unit
1000sqft
Space
11.8 0.13
8.08 839,447
5,800
8,000
500
—
—
—
2,066
—
—
—
—
Strip Mall 5.80
Enclosed Parking 898
with Elevator
312,051 0.00 —
Parking Lot 11.0
116
Space
Space
0.10 1.04
0.00 0.00
0.00 —
—
—
—
—
Enclosed Parking —
Structure
46,400
General Office
Building
11.4 58.0
1000sqft 0.26
3.63 11,400 500 —
—
— —
Condo/Townhouse Dwelling Unit 150,530 1,000 267 —
1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
—
Unmit. 63.2
—
29.7 —
46.7 —
0.06 —
1.11 —
9.16 —
9.55 —
1.02 —
2.19 —
2.54 Daily, Winter —
(Max)
Unmit. 3.75
—
38.6 —
40.2 —
0.06 —
1.62 —
8.42 —
10.0 —
1.50 —
4.14 —
5.64 Average Daily —
(Max)
Unmit. 19.2
—
11.1 —
28.2 —
0.04 —
0.31 —
5.51 —
5.80 —
0.28 —
1.32 —
1.59 Annual (Max) —
Unmit. 3.50 2.03 5.14 0.01 0.06 1.01 1.06 0.05 0.24 0.29 8 / 55
City Council 18 – 716 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily - Summer —
(Max)
2024
2025
2026
2027
2.75 3.08
2.91 63.2
—
29.7 16.1
15.1 15.7
—
24.7 44.1
42.3 46.7
—
0.06 0.05
0.05 0.05
—
1.11 0.46
0.40 0.38
—
3.07 7.80
7.80 9.16
—
4.18 8.26
8.21 9.55
—
1.02 0.42
0.37 0.35
—
0.61 1.87
1.87 2.19
—
1.63 2.29
2.24 2.54
Daily - Winter —
(Max)
2024 3.75
3.27 2.90
2.58 —
38.6 29.8
15.5 14.7
—
34.9 40.2
38.5 36.9
—
0.06 0.06
0.05 0.05
—
1.62 1.24
0.40 0.36
—
8.42 7.80
7.80 7.80
—
10.0 8.26
8.21 8.16
—
1.50 1.14
0.37 0.34
—
4.14 1.87
1.87 1.87
—
5.64 2.63
2.24 2.21
—
2025
2026
2027
Average Daily
2024 0.76
1.36 2.07
19.2 —
7.78 8.33
11.1 6.54
—
6.76 16.4
28.2 17.4
—
0.01 0.02
0.04 0.02
—
0.31 0.28
0.29 0.16
—
0.89 2.58
5.51 3.60
—
1.20 2.87
5.80 3.76
—
0.28 0.26
0.27 0.14
—
0.29 0.65
1.32 0.86
—
0.57 0.92
1.59 1.01
—
2025
2026
2027
Annual
2024 0.14
0.25 0.38
3.50 1.42
1.52 2.03
1.19 1.23
2.99 5.14
3.18 < 0.005
< 0.005
0.01 < 0.005
0.06 0.05
0.05 0.03
0.16 0.47
1.01 0.66
0.22 0.52
1.06 0.69
0.05 0.05
0.05 0.03
0.05 0.12
0.24 0.16
0.10 0.17
0.29 0.18
2025
2026
2027
2.4. Operations Emissions Compared Against Thresholds
9 / 55
City Council 18 – 717 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Unmit. 37.2
—
8.61 —
121
—
0.22 —
0.31 —
19.5 —
19.8 —
0.29 —
4.94 —
5.23 Daily, Winter —
(Max)
Unmit. 31.9
—
8.75 —
70.2 —
0.21 —
0.27 —
19.5 —
19.7 —
0.26 —
4.94 —
5.20 Average Daily —
(Max)
Unmit. 35.4
—
8.95 —
103
—
0.21 —
0.28 —
19.5 —
19.8 —
0.27 —
4.94 —
5.21 Annual (Max) —
Unmit. 6.46 1.63 18.7 0.04 0.05 3.55 3.60 0.05 0.90 0.95
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Mobile
Area
8.49 28.6
0.10 —
6.33 0.58
1.70 —
74.9 45.2
0.76 —
0.20 < 0.005
0.01 —
0.12 0.06
0.14 —
19.5 —
19.6 0.06
0.14 —
0.11 0.05
0.14 —
4.94 —
5.05 0.05
0.14 —
Energy
Water
Waste
Refrig.
Total
— —
— —
— — — — — — — — — —
— — — — — — — — — —
37.2 —
8.61 —
121
—
0.22 —
0.31 —
19.5 —
19.8 —
0.29 —
4.94 —
5.23 Daily, Winter —
(Max)
Mobile 8.42 6.88 69.3 0.19 0.12 19.5 19.6 0.11 4.94 5.05 10 / 55
City Council 18 – 718 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Area 23.4
0.10 —
0.17 1.70
—
0.07 0.76
—
< 0.005
0.01 —
0.01 0.14
—
— 0.01
0.14 —
0.01 0.14
—
— 0.01
0.14 —
Energy
Water
Waste
Refrig.
Total
— —
— —
— — — — — — — — — —
— — — — — — — — — —
31.9 —
8.75 —
70.2 —
0.21 —
0.27 —
19.5 —
19.7 —
0.26 —
4.94 —
5.20 Average Daily —
Mobile
Area
8.36 26.9
0.10 —
6.95 0.29
1.70 —
71.1 30.9
0.76 —
0.20 < 0.005
0.01 —
0.12 0.03
0.14 —
19.5 —
19.6 0.03
0.14 —
0.11 0.02
0.14 —
4.94 —
5.05 0.02
0.14 —
Energy
Water
Waste
Refrig.
Total
— —
— —
— — — — — — — — — —
— — — — — — — — — —
35.4 —
8.95 —
103
—
0.21 —
0.28 —
19.5 —
19.8 —
0.27 —
4.94 —
5.21 Annual —
Mobile
Area
1.53 4.92
0.02 —
1.27 0.05
0.31 —
13.0 5.64
0.14 —
0.04 < 0.005
< 0.005
—
0.02 0.01
0.02 —
3.55 —
3.57 0.01
0.02 —
0.02 < 0.005
0.02 —
0.90 —
0.92 < 0.005
0.02 —
Energy
Water
Waste
Refrig.
Total
— —
— —
— — — — — — — — — —
— — — — — — — — — —
6.46 1.63 18.7 0.04 0.05 3.55 3.60 0.05 0.90 0.95
3. Construction Emissions Details
3.1. Demolition (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 11 / 55
City Council 18 – 719 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Location
Onsite
ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E PM2.5D PM2.5T
— —
—
—
Daily, Summer —
(Max)
— — — — — — — —
Off-Road 2.62 24.9 21.7 0.03 1.06 — 1.06 0.98 — 0.98
Equipment
Demolition — — — — — 1.88
0.00 —
1.88 0.00
—
— 0.29
0.00 —
0.29 0.00
—
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Daily, Winter —
(Max)
Off-Road 2.62 24.9 21.7 0.03 1.06 — 1.06 0.98 — 0.98
Equipment
Demolition — — — — — 1.88
0.00 —
1.88 0.00
—
— 0.29
0.00 —
0.29 0.00
—
Onsite truck
Average Daily
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.32 3.00 2.62 < 0.005 0.13 — 0.13 0.12 — 0.12 Equipment
Demolition
Onsite truck
Annual
— — — — — 0.23
0.00 —
0.23 0.00
—
— 0.03
0.00 —
0.03 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.06 0.55 0.48 < 0.005 0.02 — 0.02 0.02 — 0.02 Equipment
Demolition
Onsite truck
Offsite
— — — — — 0.04
0.00 —
0.04 0.00
—
— 0.01
0.00 —
0.01 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
Worker
Vendor
Hauling
0.06 0.00
0.08 0.06
0.00 4.79
0.90 0.00
2.09 0.00
0.00 0.03
0.00 0.00
0.05 0.20
0.00 0.99
0.20 0.00
1.03 0.00
0.00 0.05
0.05 0.00
0.28 0.05
0.00 0.32
12 / 55
City Council 18 – 720 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Daily, Winter
(Max)
— — — — — — — — — —
Worker
Vendor
0.06 0.00
0.08 —
0.07 0.00
4.97 —
0.78 0.00
2.11 —
0.00 0.00
0.03 —
0.00 0.00
0.05 —
0.20 0.00
0.99 —
0.20 0.00
1.03 —
0.00 0.00
0.05 —
0.05 0.00
0.28 —
0.05 0.00
0.32 —
Hauling
Average Daily
Worker
Vendor
0.01 0.00
0.01 —
0.01 0.00
0.61 —
0.10 0.00
0.25 —
0.00 0.00
< 0.005
—
0.00 0.00
0.01 —
0.02 0.00
0.12 —
0.02 0.00
0.12 —
0.00 0.00
0.01 —
0.01 0.00
0.03 —
0.01 0.00
0.04 —
Hauling
Annual
Worker
Vendor
< 0.005
0.00 < 0.005
< 0.005
0.00 0.11
0.02 0.00
0.05 0.00
0.00 < 0.005
0.00 0.00
< 0.005
< 0.005
0.00 0.02
< 0.005
0.00 0.02
0.00 0.00
< 0.005
< 0.005
0.00 0.01
< 0.005
0.00 Hauling 0.01
3.3. Site Preparation (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location
Onsite
ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E PM2.5D PM2.5T
— —
—
—
Daily, Summer —
(Max)
— — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — —
Off-Road 3.65
—
36.0 —
32.9 —
0.05 —
1.60 —
— 1.60
7.68 1.47
—
— 1.47
3.94 Equipment
Dust From
Material
7.68 3.94
Movement
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Average Daily —
13 / 55
City Council 18 – 721 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Off-Road 0.05
—
0.49 —
0.45 —
< 0.005
—
0.02 —
— 0.02
0.11 0.02
—
— 0.02
0.05 Equipment
Dust From
Material
0.11 0.05
Movement
Onsite truck
Annual
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.01 0.09 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 Equipment
Dust From
Material
— — — — — 0.02 0.02 — 0.01 0.01
Movement
Onsite truck
Offsite
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — —
Worker
Vendor
0.06 0.08
0.00 2.57
—
0.91 0.00
1.09 —
0.00 0.00
0.01 —
0.00 0.00
0.02 —
0.23 0.23 0.00
0.00 0.02
—
0.05 0.05
0.00 0.00 0.00 0.00 0.00
Hauling
Average Daily
Worker
Vendor
0.04 0.51 0.54 0.14 0.17
— — — — —
< 0.005
0.00 < 0.005
0.00 0.04
—
0.01 0.00
0.01 —
0.00 0.00
< 0.005
—
0.00 0.00
< 0.005
—
< 0.005
0.00 < 0.005
0.00 0.00
0.00 < 0.005
—
< 0.005
0.00 < 0.005
0.00 Hauling
Annual
< 0.005
—
0.01 0.01 < 0.005
—
< 0.005
— — —
Worker
Vendor
< 0.005
0.00 < 0.005
0.00 0.01
< 0.005
0.00 < 0.005
0.00 0.00
< 0.005
0.00 0.00
< 0.005
< 0.005
0.00 < 0.005
0.00 0.00
0.00 < 0.005
< 0.005
0.00 < 0.005
0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005
14 / 55
City Council 18 – 722 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
3.5. Grading (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location
Onsite
ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E PM2.5D PM2.5T
— —
—
—
Daily, Summer —
(Max)
— — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — —
Off-Road 3.52
—
34.3 —
30.2 —
0.06 —
1.45 —
— 1.45
3.59 1.33
—
— 1.33
1.42 Equipment
Dust From
Material
3.59 1.42
Movement
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Average Daily —
Off-Road 0.37 3.62 3.19 0.01 0.15 — 0.15 0.14 — 0.14
Equipment
Dust From
Material
— — — — — 0.38 0.38 — 0.15 0.15
Movement
Onsite truck
Annual
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.07 0.66 0.58 < 0.005 0.03 — 0.03 0.03 — 0.03 Equipment
Dust From
Material
— — — — — 0.07 0.07 — 0.03 0.03
Movement
Onsite truck
Offsite
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
15 / 55
City Council 18 – 723 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Daily, Winter
(Max)
— — — — — — — — — —
Worker
Vendor
0.07 0.09
0.00 0.07
—
1.04 0.00
0.03 —
0.00 0.00 0.26 0.26 0.00 0.06 0.06
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling
Average Daily
Worker
Vendor
< 0.005
—
< 0.005
—
< 0.005
—
0.01 0.02 < 0.005
—
< 0.005
—
< 0.005
— — —
0.01 0.01
0.00 0.01
—
0.12 0.00
< 0.005
—
0.00 0.00 0.03 0.03 0.00 0.01 0.01
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling
Annual
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
Worker
Vendor
< 0.005
0.00 < 0.005
0.00 < 0.005
0.02 0.00
< 0.005
0.00 0.00 < 0.005
0.00 < 0.005
0.00 0.00 < 0.005
0.00 < 0.005
0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005
3.7. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location
Onsite
ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E PM2.5D PM2.5T
— —
—
—
Daily, Summer —
(Max)
— — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — —
Off-Road 3.20
—
29.7 —
28.3 —
0.06 —
1.23 —
— 1.23
3.59 1.14
—
— 1.14
1.42 Equipment
Dust From
Material
3.59 1.42
Movement
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Average Daily —
16 / 55
City Council 18 – 724 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Off-Road 0.19
—
1.80 —
1.72 —
< 0.005
—
0.07 —
— 0.07
0.22 0.07
—
— 0.07
0.09 Equipment
Dust From
Material
0.22 0.09
Movement
Onsite truck
Annual
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.04 0.33 0.31 < 0.005 0.01 — 0.01 0.01 — 0.01 Equipment
Dust From
Material
— — — — — 0.04 0.04 — 0.02 0.02
Movement
Onsite truck
Offsite
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — —
Worker
Vendor
0.07 0.08 0.97
0.00 0.03
—
0.00 0.00 0.26 0.26 0.00 0.06 0.06
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling
Average Daily
Worker
Vendor
< 0.005
—
0.07 < 0.005
—
< 0.005
—
0.01 0.02 < 0.005
—
< 0.005
—
< 0.005
— — — —
< 0.005
0.00 < 0.005
0.00 0.06
0.00 < 0.005
—
0.00 0.00 0.02 0.02 0.00 < 0.005
0.00 < 0.005
0.00 0.00 0.00 0.00 0.00 0.00
Hauling
Annual
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
Worker
Vendor
< 0.005
0.00 < 0.005
0.00 0.01
0.00 < 0.005
0.00 0.00 < 0.005
0.00 < 0.005
0.00 0.00 < 0.005
0.00 < 0.005
0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 17 / 55
City Council 18 – 725 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
3.9. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location
Onsite
ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E PM2.5D PM2.5T
— —
—
—
Daily, Summer —
(Max)
— — — — — — — —
Off-Road 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40
Equipment
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Daily, Winter —
(Max)
Off-Road 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40
Equipment
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Average Daily —
Off-Road 0.34 3.13 3.90 0.01 0.13 — 0.13 0.12 — 0.12
Equipment
Onsite truck
Annual
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.06 0.57 0.71 < 0.005 0.02 — 0.02 0.02 — 0.02 Equipment
Onsite truck
Offsite
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
Worker
Vendor
Hauling
1.85 0.10
0.00 —
1.81 3.84
0.00 —
29.2 1.91
0.00 —
0.00 0.03
0.00 —
0.00 0.03
0.00 —
6.81 0.99
0.00 —
6.81 1.02
0.00 —
0.00 0.03
0.00 —
1.60 0.27
0.00 —
1.60 0.30
0.00 Daily, Winter —
(Max)
18 / 55
City Council 18 – 726 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Worker
Vendor
1.84 0.10
0.00 —
2.06 3.98
0.00 —
25.2 1.95
0.00 —
0.00 0.03
0.00 —
0.00 0.03
0.00 —
6.81 0.99
0.00 —
6.81 1.02
0.00 —
0.00 0.03
0.00 —
1.60 0.27
0.00 —
1.60 0.30
0.00 —
Hauling
Average Daily
Worker
Vendor
0.54 0.03
0.00 —
0.61 1.20
0.00 —
7.90 0.58
0.00 —
0.00 0.01
0.00 —
0.00 0.01
0.00 —
2.01 0.29
0.00 —
2.01 0.30
0.00 —
0.00 0.01
0.00 —
0.47 0.08
0.00 —
0.47 0.09
0.00 —
Hauling
Annual
Worker
Vendor
0.10 0.01
0.00 0.11
0.22 0.00
1.44 0.11
0.00 0.00
< 0.005
0.00 0.00
< 0.005
0.00 0.37
0.05 0.00
0.37 0.06
0.00 0.00
< 0.005
0.00 0.09
0.01 0.00
0.09 0.02
Hauling 0.00
3.11. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location
Onsite
ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E PM2.5D PM2.5T
— —
—
—
Daily, Summer —
(Max)
— — — — — — — —
Off-Road 1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35
Equipment
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Daily, Winter —
(Max)
Off-Road 1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35
Equipment
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Average Daily —
Off-Road 0.77 7.04 9.26 0.02 0.27 — 0.27 0.25 — 0.25
Equipment
19 / 55
City Council 18 – 727 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Onsite truck
Annual
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.14 1.28 1.69 < 0.005 0.05 — 0.05 0.05 — 0.05 Equipment
Onsite truck
Offsite
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
Worker
Vendor
Hauling
1.76 0.08
0.00 —
1.59 3.70
0.00 —
27.5 1.85
0.00 —
0.00 0.03
0.00 —
0.00 0.03
0.00 —
6.81 0.99
0.00 —
6.81 1.02
0.00 —
0.00 0.03
0.00 —
1.60 0.27
0.00 —
1.60 0.30
0.00 Daily, Winter —
(Max)
Worker
Vendor
1.76 0.07
0.00 —
1.82 3.85
0.00 —
23.7 1.89
0.00 —
0.00 0.03
0.00 —
0.00 0.03
0.00 —
6.81 0.99
0.00 —
6.81 1.02
0.00 —
0.00 0.03
0.00 —
1.60 0.27
0.00 —
1.60 0.30
0.00 —
Hauling
Average Daily
Worker
Vendor
1.25 0.05
0.00 —
1.30 2.77
0.00 —
17.6 1.34
0.00 —
0.00 0.02
0.00 —
0.00 0.02
0.00 —
4.81 0.70
0.00 —
4.81 0.72
0.00 —
0.00 0.02
0.00 —
1.13 0.19
0.00 —
1.13 0.21
0.00 —
Hauling
Annual
Worker
Vendor
0.23 0.01
0.00 0.24
0.50 0.00
3.21 0.24
0.00 0.00
< 0.005
0.00 0.00
< 0.005
0.00 0.88
0.13 0.00
0.88 0.13
0.00 0.00
< 0.005
0.00 0.21
0.04 0.00
0.21 0.04
Hauling 0.00
3.13. Building Construction (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T 20 / 55
City Council 18 – 728 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Onsite —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Summer —
(Max)
Off-Road 1.03 9.39 12.9 0.02 0.34 — 0.34 0.31 — 0.31
Equipment
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Daily, Winter —
(Max)
Off-Road 1.03 9.39 12.9 0.02 0.34 — 0.34 0.31 — 0.31
Equipment
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Average Daily —
Off-Road 0.43 3.90 5.37 0.01 0.14 — 0.14 0.13 — 0.13
Equipment
Onsite truck
Annual
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.08 0.71 0.98 < 0.005 0.03 — 0.03 0.02 — 0.02 Equipment
Onsite truck
Offsite
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
Worker
Vendor
Hauling
1.49 0.07
0.00 —
1.56 3.55
0.00 —
25.8 1.76
0.00 —
0.00 0.03
0.00 —
0.00 0.03
0.00 —
6.81 0.99
0.00 —
6.81 1.02
0.00 —
0.00 0.03
0.00 —
1.60 0.27
0.00 —
1.60 0.30
0.00 Daily, Winter —
(Max)
Worker
Vendor
Hauling
1.48 0.07
0.00 1.60
3.70 0.00
22.2 1.81
0.00 0.00
0.03 0.00
0.00 0.03
0.00 6.81
0.99 0.00
6.81 1.02
0.00 0.00
0.03 0.00
1.60 0.27
0.00 1.60
0.30 0.00
21 / 55
City Council 18 – 729 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Average Daily
Worker
— — — — — — — — — —
0.61 0.03
0.00 —
0.75 1.55
0.00 —
9.59 0.74
0.00 —
0.00 0.01
0.00 —
0.00 0.01
0.00 —
2.79 0.41
0.00 —
2.79 0.42
0.00 —
0.00 0.01
0.00 —
0.65 0.11
0.00 —
0.65 0.12
0.00 —
Vendor
Hauling
Annual
Worker 0.11
0.01 0.00
0.14 0.28
0.00 1.75
0.13 0.00
0.00 < 0.005
0.00 0.00
< 0.005
0.00 0.51
0.07 0.00
0.51 0.08
0.00 0.00
< 0.005
0.00 0.12
0.02 0.00
0.12 0.02
0.00 Vendor
Hauling
3.15. Paving (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location
Onsite
ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E PM2.5D PM2.5T
— —
—
—
Daily, Summer —
(Max)
— — — — — — — —
Off-Road 0.80 7.45 9.98 0.01 0.35 — 0.35 0.32 — 0.32
Equipment
Paving 0.37
0.00 —
— — — — — — — — —
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Daily, Winter —
(Max)
Average Daily — — — — — —
—
— — —
—
—
Off-Road 0.14 1.35 1.80 < 0.005 0.06 0.06 0.06 0.06
Equipment
Paving 0.07
0.00 —
— — — — — — — — —
Onsite truck
Annual
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.03 0.25 0.33 < 0.005 0.01 — 0.01 0.01 — 0.01 Equipment
22 / 55
City Council 18 – 730 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Paving 0.01
0.00 —
— — — — — — — — —
Onsite truck
Offsite
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
Worker
Vendor
Hauling
0.05 0.00
0.00 —
0.05 0.00
0.00 —
0.84 0.00
0.00 —
0.00 0.00
0.00 —
0.00 0.00
0.00 —
0.20 0.00
0.00 —
0.20 0.00
0.00 —
0.00 0.00
0.00 —
0.05 0.00
0.00 —
0.05 0.00
0.00 Daily, Winter —
(Max)
Average Daily
Worker
— — — — — — — — — —
0.01 0.00
0.00 —
0.01 0.00
0.00 —
0.14 0.00
0.00 —
0.00 0.00
0.00 —
0.00 0.00
0.00 —
0.04 0.00
0.00 —
0.04 0.00
0.00 —
0.00 0.00
0.00 —
0.01 0.00
0.00 —
0.01 0.00
0.00 —
Vendor
Hauling
Annual
Worker < 0.005
0.00 0.00
< 0.005
0.00 0.00
0.03 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.01
0.00 0.00
0.01 0.00
0.00 0.00
0.00 0.00
< 0.005
0.00 0.00
< 0.005
0.00 0.00
Vendor
Hauling
3.17. Architectural Coating (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location
Onsite
ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E PM2.5D PM2.5T
— —
—
—
Daily, Summer —
(Max)
— — — — — — — —
Off-Road 0.11
60.2 0.83
—
1.13 —
< 0.005
—
0.02 —
—
—
0.02 —
0.02 —
—
—
0.02 —
Equipment
Architectural
Coatings
23 / 55
City Council 18 – 731 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Daily, Winter —
(Max)
Average Daily — — — — — —
—
— — —
—
—
Off-Road 0.03 0.25 0.34 < 0.005 0.01 0.01 0.01 0.01
Equipment
Architectural
Coatings
18.0 — — — — — — — — —
Onsite truck
Annual
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.01 0.05 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 Equipment
Architectural
Coatings
3.28 — — — — — — — — —
Onsite truck
Offsite
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
Worker
Vendor
Hauling
0.30 0.00
0.00 —
0.31 0.00
0.00 —
5.15 0.00
0.00 —
0.00 0.00
0.00 —
0.00 0.00
0.00 —
1.36 0.00
0.00 —
1.36 0.00
0.00 —
0.00 0.00
0.00 —
0.32 0.00
0.00 —
0.32 0.00
0.00 Daily, Winter —
(Max)
Average Daily
Worker
— — — — — — — — — —
0.09 0.00
0.00 —
0.11 0.00
0.00 —
1.38 0.00
0.00 —
0.00 0.00
0.00 —
0.00 0.00
0.00 —
0.40 0.00
0.00 —
0.40 0.00
0.00 —
0.00 0.00
0.00 —
0.09 0.00
0.00 —
0.09 0.00
0.00 —
Vendor
Hauling
Annual
Worker 0.02
0.00 0.02
0.00 0.25
0.00 0.00
0.00 0.00
0.00 0.07
0.00 0.07
0.00 0.00
0.00 0.02
0.00 0.02
Vendor 0.00
24 / 55
City Council 18 – 732 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.19. Trenching (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location
Onsite
ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E PM2.5D PM2.5T
— —
—
—
Daily, Summer —
(Max)
— — — — — — — —
Off-Road 0.19 1.29 1.45 < 0.005 0.06 — 0.06 0.05 — 0.05 Equipment
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Daily, Winter —
(Max)
Off-Road 0.19 1.29 1.45 < 0.005 0.06 — 0.06 0.05 — 0.05 Equipment
Onsite truck 0.00
—
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 Average Daily —
Off-Road 0.03 0.22 0.25 < 0.005 0.01 — 0.01 0.01 — 0.01 Equipment
Onsite truck
Annual
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Off-Road 0.01 0.04 0.05 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 Equipment
Onsite truck
Offsite
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
0.00 —
Daily, Summer
(Max)
— — — — — — — — — —
Worker
Vendor
Hauling
0.01 0.00
0.00 0.01
0.00 0.00
0.14 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.03
0.00 0.00
0.03 0.00
0.00 0.00
0.00 0.00
0.01 0.00
0.00 0.01
0.00 0.00
25 / 55
City Council 18 – 733 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Daily, Winter
(Max)
— — — — — — — — — —
Worker
Vendor
0.01 0.00
0.00 —
0.01 0.00
0.00 —
0.12 0.00
0.00 —
0.00 0.00
0.00 —
0.00 0.00
0.00 —
0.03 0.00
0.00 —
0.03 0.00
0.00 —
0.00 0.00
0.00 —
0.01 0.00
0.00 —
0.01 0.00
0.00 —
Hauling
Average Daily
Worker
Vendor
< 0.005
0.00 0.00
—
< 0.005
0.00 0.00
—
0.02 0.00
0.00 —
0.00 0.00
0.00 —
0.00 0.00
0.00 —
0.01 0.00
0.00 —
0.01 0.00
0.00 —
0.00 0.00
0.00 —
< 0.005
0.00 0.00
—
< 0.005
0.00 0.00
—
Hauling
Annual
Worker
Vendor
< 0.005
0.00 0.00
< 0.005
0.00 0.00
< 0.005
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
< 0.005
0.00 0.00
< 0.005
0.00 0.00
0.00 0.00
0.00 < 0.005
0.00 0.00
< 0.005
0.00 Hauling 0.00
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Mobile source emissions results are presented in Sections 2.6. No further detailed breakdown of emissions is available.
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Apartments Mid
Rise
— — — — — — — — — —
26 / 55
City Council 18 – 734 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking with
Elevator
Parking Lot —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking
Structure
General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou —
se
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Apartments Mid
Rise
— — — — — — — — — —
Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking with
Elevator
Parking Lot —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking
Structure
General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou —
se
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Apartments Mid
Rise
27 / 55
City Council 18 – 735 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking with
Elevator
Parking Lot —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking
Structure
General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou
se
Total
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Apartments Mid 0.07
Rise
1.26 0.54 0.01 0.10 — 0.10 0.10 — 0.10
Strip Mall < 0.005 0.01
0.00 0.01
0.00 < 0.005
0.00 < 0.005
0.00 —
—
< 0.005
0.00 < 0.005
0.00 —
—
< 0.005
Enclosed 0.00
Parking with
Elevator
0.00 Parking Lot 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 —
—
0.00 0.00
0.00 0.00
—
—
0.00 Enclosed 0.00
Parking
Structure
General Office
Building
< 0.005 0.08 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01
28 / 55
City Council 18 – 736 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Condo/Townhou 0.02
se
0.35 0.15 < 0.005 0.03 — 0.03 0.03 — 0.03
Total 0.10
—
1.70 —
0.76 —
0.01 —
0.14 —
—
—
0.14 —
0.14 —
—
—
0.14 Daily, Winter —
(Max)
Apartments Mid 0.07
Rise
1.26 0.54 0.01 0.10 — 0.10 0.10 — 0.10
Strip Mall < 0.005 0.01
0.00 0.01
0.00 < 0.005
0.00 < 0.005
0.00 —
—
< 0.005
0.00 < 0.005
0.00 —
—
< 0.005
Enclosed 0.00
Parking with
Elevator
0.00 Parking Lot 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 —
—
0.00 0.00
0.00 0.00
—
—
0.00 Enclosed 0.00
Parking
Structure
General Office
Building
< 0.005 0.08
0.35 0.07
0.15 < 0.005
< 0.005
0.01 0.03
—
—
0.01 0.03
0.01 0.03
—
—
0.01 Condo/Townhou 0.02 0.03
se
Total 0.10
—
1.70 —
0.76 —
0.01 —
0.14 —
—
—
—
0.14 —
0.14 —
—
—
—
0.14 Annual —
Apartments Mid 0.01
Rise
0.23 0.10 < 0.005 0.02 0.02 0.02 0.02
Strip Mall < 0.005 < 0.005
0.00 < 0.005
0.00 < 0.005
0.00 < 0.005
0.00 —
—
< 0.005
0.00 < 0.005
0.00 —
—
< 0.005
Enclosed 0.00
Parking with
Elevator
0.00 Parking Lot 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 —
—
0.00 0.00
0.00 0.00
—
—
0.00 Enclosed 0.00
Parking
Structure
General Office
Building
< 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 29 / 55
City Council 18 – 737 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Condo/Townhou < 0.005
Total 0.02
0.06 0.31
0.03 0.14
< 0.005
< 0.005
0.01 0.02
—
—
0.01 0.02
0.01 0.02
—
—
0.01 0.02
4.3. Area Emissions by Source
4.3.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Hearths 0.01
21.6 0.17
—
0.07 —
< 0.005
—
0.01 —
—
—
0.01 —
0.01 —
—
—
0.01 Consumer —
Products
Architectural
Coatings
1.80 5.21
— — — — —
—
— — —
—
—
Landscape
Equipment
0.41 45.1 < 0.005 0.04 0.04 0.03 0.03
Total 28.6
—
0.58 —
45.2 —
< 0.005
—
0.06 —
—
—
0.06 —
0.05 —
—
—
0.05 Daily, Winter —
(Max)
Hearths 0.01
21.6 0.17
—
0.07 —
< 0.005
—
0.01 —
—
—
0.01 —
0.01 —
—
—
0.01 Consumer —
Products
Architectural
Coatings
1.80 — — — — — — — — —
Total 23.4
—
0.17 —
0.07 —
< 0.005
—
0.01 —
—
—
—
—
0.01 —
0.01 —
—
—
—
—
0.01 Annual —
Hearths < 0.005
3.94 < 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
—
< 0.005
Consumer —
Products
30 / 55
City Council 18 – 738 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Architectural
Coatings
0.33 0.65
4.92 — — — — —
—
—
— — —
—
—
—
Landscape
Equipment
0.05 0.05
5.64 5.64
< 0.005
< 0.005
0.01 0.01
0.01 0.01
< 0.005
< 0.005
< 0.005
Total < 0.005
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Apartments Mid
Rise
— — — — — — — — — —
Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking with
Elevator
Parking Lot —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking
Structure
General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou —
se
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Apartments Mid
Rise
— — — — — — — — — —
31 / 55
City Council 18 – 739 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking with
Elevator
Parking Lot —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking
Structure
General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou —
se
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Apartments Mid
Rise
Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking with
Elevator
Parking Lot —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking
Structure
General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou
se
Total
4.5. Waste Emissions by Land Use
32 / 55
City Council 18 – 740 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
4.5.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Apartments Mid
Rise
— — — — — — — — — —
Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking with
Elevator
Parking Lot —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking
Structure
General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou —
se
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Apartments Mid
Rise
— — — — — — — — — —
Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking with
Elevator
Parking Lot —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking
Structure
33 / 55
City Council 18 – 741 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou —
se
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Apartments Mid
Rise
Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking with
Elevator
Parking Lot —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Enclosed —
Parking
Structure
General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou
se
Total
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Apartments Mid
Rise
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Strip Mall —
34 / 55
City Council 18 – 742 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 General Office
Building
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Condo/Townhou —
se
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Apartments Mid
Rise
— — — — — — — — — —
Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
General Office —
Building
Condo/Townhou
se
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Apartments Mid
Rise
Strip Mall —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
General Office —
Building
Condo/Townhou
se
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Total —
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T 35 / 55
City Council 18 – 743 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Daily, Summer
(Max)
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
—
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T 36 / 55
City Council 18 – 744 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Daily, Summer
(Max)
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Daily, Winter —
(Max)
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Total — — — — — — — — — —
37 / 55
City Council 18 – 745 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Daily, Winter
(Max)
— — — — — — — — — —
Total —
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Annual
Total
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG
—
NOx
—
CO
—
SO2
—
PM10E
—
PM10D
—
PM10T
—
PM2.5E
—
PM2.5D
—
PM2.5T
Daily, Summer —
(Max)
Avoided
Subtotal
Sequestered
Subtotal
Removed
Subtotal
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Daily, Winter —
(Max)
Avoided
Subtotal
Sequestered
Subtotal
Removed
Subtotal
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38 / 55
City Council 18 – 746 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Avoided
Subtotal
Sequestered
Subtotal
Removed
Subtotal
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5. Activity Data
5.1. Construction Schedule
Phase Name
Demolition
Phase Type Start Date
9/2/2024
11/1/2024
11/8/2024
8/1/2025
5/1/2025
5/1/2027
2/3/2025
End Date
10/31/2024
11/7/2024
1/31/2025
7/31/2027
7/31/2025
9/30/2027
4/30/2025
Days Per Week
5.00 Work Days per Phase Phase Description
Demolition 44.0
5.00 61.0
521
—
—
—
—
—
—
—
Site Preparation
Grading
Site Preparation
Grading
5.00 5.00
Building Construction
Paving
Building Construction
Paving
5.00 5.00 66.0
Architectural Coating 109
Trenching
Architectural Coating
Trenching
5.00 5.00 63.0
5.2. Off-Road Equipment
5.2.1. Unmitigated
Phase Name
Demolition
Demolition
Equipment Type
Rubber Tired Dozers
Excavators
Fuel Type
Diesel
Engine Tier
Average
Number per Day Hours Per Day
8.00 Horsepower
367
Load Factor
2.00 0.40
Diesel Average 3.00 8.00 36.0 0.38
39 / 55
City Council 18 – 747 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Demolition Concrete/Industrial
Saws
Diesel
Diesel
Average 1.00 8.00 33.0 0.73
Site Preparation
Site Preparation
Rubber Tired Dozers Average
Average
3.00 4.00
8.00 8.00
367 0.40
Tractors/Loaders/Backh Diesel 0.37
oes
84.0 Grading
Grading
Grading
Graders Diesel
Diesel
Average
Average
Average
1.00 2.00
2.00 8.00
8.00 8.00
148 0.41
0.38 0.37
Excavators 36.0
Tractors/Loaders/Backh Diesel 84.0
oes
Grading Scrapers Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Average
Average
Average
Average
Average
Average
Average
2.00 1.00
3.00 1.00
1.00 1.00
3.00 8.00
8.00 8.00
8.00 7.00
8.00 7.00
423
367
82.0 14.0
367
46.0 84.0
0.48 0.40
0.20 0.74
0.29 0.45
0.37 Grading Rubber Tired Dozers
Building Construction Forklifts
Building Construction
Building Construction
Building Construction
Building Construction
Generator Sets
Cranes
Welders
Tractors/Loaders/Backh Diesel
oes
Paving Pavers Diesel
Diesel
Diesel
Diesel
Diesel
Average
Average
Average
Average
Average
2.00 2.00
2.00 1.00
1.00 8.00
8.00 8.00
6.00 8.00
81.0 89.0
36.0 37.0
40.0 0.42
0.36 0.38
0.48 0.50
Paving Paving Equipment
Paving Rollers
Architectural Coating
Trenching
Air Compressors
Trenchers
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name
Demolition
Demolition
Trip Type
—
One-Way Trips per Day Miles per Trip Vehicle Mix
— — —
Worker 15.0 18.5 LDA,LDT1,LDT2
40 / 55
City Council 18 – 748 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Demolition Vendor
Hauling
Onsite truck
—
— 10.2
20.0 —
HHDT,MHDT
Demolition 54.5 HHDT
Demolition — HHDT
Site Preparation
Site Preparation
Site Preparation
Site Preparation
Site Preparation
Grading
— — —
Worker
Vendor
Hauling
Onsite truck
—
17.5 —
18.5 10.2
20.0 —
LDA,LDT1,LDT2
HHDT,MHDT
28.2 HHDT
— HHDT
— — —
Grading Worker
Vendor
Hauling
Onsite truck
—
20.0 —
18.5 10.2
20.0 —
LDA,LDT1,LDT2
HHDT,MHDT
HHDT
Grading
Grading 0.82
Grading — HHDT
Building Construction
Building Construction
Building Construction
Building Construction
Building Construction
Paving
— — —
Worker
Vendor
Hauling
Onsite truck
—
521
116
0.00 —
18.5 10.2
20.0 —
LDA,LDT1,LDT2
HHDT,MHDT
HHDT
HHDT
— — —
Paving Worker
Vendor
Hauling
Onsite truck
—
15.0 —
18.5 10.2
20.0 —
LDA,LDT1,LDT2
HHDT,MHDT
HHDT
Paving
Paving 0.00
Paving — HHDT
Architectural Coating
Architectural Coating
Architectural Coating
Architectural Coating
— — —
Worker
Vendor
Hauling
104
—
18.5 10.2
20.0 LDA,LDT1,LDT2
HHDT,MHDT
0.00 HHDT
41 / 55
City Council 18 – 749 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Architectural Coating
Trenching
Onsite truck
—
— — HHDT
— — —
Trenching Worker 2.50
—
18.5 10.2
20.0 —
LDA,LDT1,LDT2
HHDT,MHDT
HHDT
Trenching Vendor
Trenching Hauling
Onsite truck
0.00 Trenching — HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
5.5. Architectural Coatings
Phase Name Residential Interior Area Coated Residential Exterior Area Coated Non-Residential Interior Area Non-Residential Exterior Area Coated (sq ft)
Parking Area Coated (sq ft)
24,110
(sq ft) (sq ft) Coated (sq ft)
Architectural Coating 2,004,703 668,234 43,689 10,588
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Ton of
Debris)
Material Exported (Ton of
Debris)
Acres Graded (acres) Material Demolished (Ton of
Debris)
Acres Paved (acres)
Demolition
Site Preparation
Grading
0.00 —
0.00 1,422
400
0.00 7.50
183
6,000
0.00 0.00
0.00 —
—
— —
Paving 0.00 0.00 0.00 9.22
5.6.2. Construction Earthmoving Control Strategies
42 / 55
City Council 18 – 750 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Control Strategies Applied
Water Exposed Area
Frequency (per day) PM10 Reduction PM2.5 Reduction
2 2
61%
36%
61%
Water Demolished Area 36%
5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Apartments Mid Rise 0%
Strip Mall
—
0.00 8.08
0.10 1.04
0.00 —
0%
Enclosed Parking with Elevator
Parking Lot
100%
100%
100%
0%
Enclosed Parking Structure
General Office Building
Condo/Townhouse 0%
5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year
0.00 CO2
349
349
346
346
CH4
0.03 0.03
0.03 0.03
N2O
2024
2025
2026
2027
< 0.005
< 0.005
< 0.005
< 0.005
0.00 0.00
0.00 5.9. Operational Mobile Sources
5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year 43 / 55
City Council 18 – 751 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Total all Land Uses 2,751 2,751 2,751 1,004,115 27,510 27,510 27,510 10,041,150
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise
Wood Fireplaces
—
0 Gas Fireplaces 10
Propane Fireplaces 0
Electric Fireplaces
No Fireplaces
0 439
Conventional Wood Stoves 0
Catalytic Wood Stoves
Non-Catalytic Wood Stoves
Pellet Wood Stoves
Condo/Townhouse
Wood Fireplaces
0 0
0 —
0 Gas Fireplaces 0
Propane Fireplaces
Electric Fireplaces
No Fireplaces
0 0
58 Conventional Wood Stoves 0
Catalytic Wood Stoves
Non-Catalytic Wood Stoves
Pellet Wood Stoves
0 0
0 44 / 55
City Council 18 – 752 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq ft)
Non-Residential Exterior Area Coated Parking Area Coated (sq ft) (sq ft)
2004703.4249999998 668,234 43,689 10,588 24,110
5.10.3. Landscape Equipment
Season Unit Value
0.00 250
Snow Days
Summer Days
day/yr
day/yr
5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr)
1,645,960
CO2
346
346
346
346
346
346
346
CH4 N2O Natural Gas (kBTU/yr)
4,986,972
34,724
Apartments Mid Rise
Strip Mall
0.0330
0.0330
0.0330
0.0330
0.0330
0.0330
0.0330
0.0040
0.0040
0.0040
0.0040
0.0040
0.0040
0.0040
56,964
Enclosed Parking with Elevator 1,151,915 0.00
Parking Lot 3,778 0.00
Enclosed Parking Structure
General Office Building
Condo/Townhouse
162,466
203,151
266,346
0.00 288,950
1,393,761
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) 45 / 55
City Council 18 – 753 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Apartments Mid Rise
Strip Mall
16,849,017
429,621
0.00 126,724
6,480
Enclosed Parking with Elevator 0.00
Parking Lot 0.00 0.00
Enclosed Parking Structure
General Office Building
Condo/Townhouse
0.00 0.00
2,026,165
2,176,488
6,480
15,840
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Mid Rise
Strip Mall
513 —
—
—
—
—
—
—
6.09 0.00
0.00 0.00
10.6 66.3
Enclosed Parking with Elevator
Parking Lot
Enclosed Parking Structure
General Office Building
Condo/Townhouse
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant
R-410A
GWP
2,088
Quantity (kg)
< 0.005
Operations Leak Rate
2.50 Service Leak Rate
2.50 Times Serviced
Apartments Mid Rise Average room A/C & 10.0
Other residential A/C
and heat pumps
46 / 55
City Council 18 – 754 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Apartments Mid Rise
Strip Mall
Household refrigerators R-134a
and/or freezers
1,430
2,088
1,430
0.12 0.60
4.00 1.00
0.00 4.00
0.00 1.00
18.0 1.00
Other commercial A/C
and heat pumps
R-410A < 0.005
Strip Mall Stand-alone retail 0.04
refrigerators and
freezers
R-134a
Strip Mall Walk-in refrigerators
and freezers
R-404A 3,922
1,430
2,088
2,088
< 0.005
0.02 7.50
0.60 4.00
2.50 7.50
0.00 4.00
2.50 20.0
1.00 18.0
10.0 General Office Building Household refrigerators R-134a and/or freezers
General Office Building Other commercial A/C
and heat pumps
R-410A < 0.005
Condo/Townhouse Average room A/C & < 0.005
Other residential A/C
and heat pumps
R-410A
Condo/Townhouse Household refrigerators R-134a
and/or freezers
1,430 0.12 0.60 0.00 1.00
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) 47 / 55
Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr) City Council 18 – 755 10/3/2023 Cabrillo Town Center (Future) Detailed Report, 7/26/2023
5.17. User Defined
Equipment Type Fuel Type
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location
9.03 Unit
Temperature and Extreme Heat annual days of extreme heat 48 / 55
City Council 18 – 756 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Extreme Precipitation
Sea Level Rise
Wildfire
3.50 0.00
1.31 annual days with precipitation above 20 mm
meters of inundation depth
annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider different increments of sea level rise coupled with extreme storm events. Users may select from four model simulations to view the range in potential inundation depth for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 50 meters (m) by 50 m, or about 164 feet (ft) by 164 ft.
Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
6.2. Initial Climate Risk Scores
Climate Hazard
Temperature and Extreme Heat
Extreme Precipitation
Sea Level Rise
Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score 0 0 0 N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0 N/A
0 N/A
0 Wildfire 0 0 0
Flooding N/A
N/A
N/A
0 N/A
N/A
N/A
0 N/A
N/A
N/A
0 Drought
Snowpack Reduction
Air Quality Degradation
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.
6.3. Adjusted Climate Risk Scores
49 / 55
City Council 18 – 757 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Climate Hazard
Temperature and Extreme Heat
Extreme Precipitation
Sea Level Rise
Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score 1 1 1 2
N/A
1 N/A
1 N/A
1 N/A
2 Wildfire 1 1 1 2
Flooding N/A
N/A
N/A
1 N/A
N/A
N/A
1 N/A
N/A
N/A
1 N/A
N/A
N/A
2 Drought
Snowpack Reduction
Air Quality Degradation
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
Indicator Result for Project Census Tract
Exposure Indicators
AQ-Ozone
—
57.8 73.8
85.3 53.8
71.1 0.00
AQ-PM
AQ-DPM
Drinking Water
Lead Risk Housing
Pesticides
50 / 55
City Council 18 – 758 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Toxic Releases
Traffic
90.8 98.3
Effect Indicators —
CleanUp Sites
Groundwater
91.8 0.00
82.8 0.00
22.1 —
Haz Waste Facilities/Generators
Impaired Water Bodies
Solid Waste
Sensitive Population
Asthma 55.8
47.8 41.7
—
Cardio-vascular
Low Birth Weights
Socioeconomic Factor Indicators
Education 75.4
48.1 66.9
54.4 28.2
Housing
Linguistic
Poverty
Unemployment
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic
Above Poverty
Employed
Median HI
Education
—
55.40870012
82.72808931
52.89362248
—
51 / 55
City Council 18 – 759 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Bachelor's or higher
High school enrollment
Preschool enrollment
Transportation
35.41639933
100
31.82343128
—
Auto Access 58.09059412
62.68446041
—
Active commuting
Social
2-parent households
Voting
93.16052868
23.85474143
Neighborhood —
Alcohol availability
Park access
53.74053638
48.29975619
98.84511741
72.33414603
38.34210189
—
Retail density
Supermarket access
Tree canopy
Housing
Homeownership 37.89298088
43.38508918
27.93532658
78.69883229
20.37726165
—
Housing habitability
Low-inc homeowner severe housing cost burden
Low-inc renter severe housing cost burden
Uncrowded housing
Health Outcomes
Insured adults 24.71448736
Arthritis 67.1
Asthma ER Admissions
High Blood Pressure
Cancer (excluding skin)
50.7 72.3
55.0 52 / 55
City Council 18 – 760 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Asthma 49.0
61.0 53.7
54.0 67.7
95.5 83.0
78.0 41.5
45.1 51.8
60.5 44.3
58.2 —
Coronary Heart Disease
Chronic Obstructive Pulmonary Disease
Diagnosed Diabetes
Life Expectancy at Birth
Cognitively Disabled
Physically Disabled
Heart Attack ER Admissions
Mental Health Not Good
Chronic Kidney Disease
Obesity
Pedestrian Injuries
Physical Health Not Good
Stroke
Health Risk Behaviors
Binge Drinking 15.4
44.4 40.3
—
Current Smoker
No Leisure Time for Physical Activity
Climate Change Exposures
Wildfire Risk 0.0
SLR Inundation Area
Children
0.0 64.0
60.7 29.3
72.2 33.6
—
Elderly
English Speaking
Foreign-born
Outdoor Workers
Climate Change Adaptive Capacity
53 / 55
City Council 18 – 761 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Impervious Surface Cover
Traffic Density
46.9 99.3
23.0 —
Traffic Access
Other Indices
Hardship 66.1
Other Decision Support —
2016 Voting 58.2
7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 71.0
57.0 No
Healthy Places Index Score for Project Location (b)
Project Located in a Designated Disadvantaged Community (Senate Bill 535) Project Located in a Low-Income Community (Assembly Bill 1550) Project Located in a Community Air Protection Program Community (Assembly Bill 617) Ye s
No
a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
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City Council 18 – 762 10/3/2023
Cabrillo Town Center (Future) Detailed Report, 7/26/2023 Land Use Project plans and LLG trip generation estimates. Population based on SCAG’s average 2016 persons-per-household rate for the City of 4.6 persons per household.
Construction: Construction Phases
Construction: Off-Road Equipment
Construction: Trips and VMT
Operations: Hearths
Developer information
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MATES V TOXIC EMISSIONS OVERVIEW
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CALENVIROSCREEN 4.0 OUTPUT
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July 2022
HISTORIC RESOURCES ASSESSMENT
TOWN CENTER PLAZA
SANTA ANA, CALIFORNIA
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July 2022
HISTORIC RESOURCES ASSESSMENT
TOWN CENTER PLAZA
SANTA ANA, CALIFORNIA
FRH Realty LLC
5355 Mira Sorrento Place, Suite 100
San Diego, California 92121
Prepared by:
Casey Tibbet, M.A., and Eugene Heck, M.A.
LSA
1500 Iowa Avenue, Suite 200
Riverside, California 92507
(951) 781-9310
Project No. FRC2201
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MANAGEMENT SUMMARY
LSA conducted a historic resources assessment for Town Center Plaza located in Santa Ana, Orange County, California. The assessment included archival research, outreach to local historical groups, a field survey, and this report. The project area includes four parcels (Assessor’s Parcel Numbers 400- 051-02, -09, -14, and -15) that together make up the approximately 8-acre project area, which is currently developed with four office buildings built between 1971 and 1978. The project proposes to demolish the existing office buildings and construct affordable housing on the site. The City of Santa Ana (City), as Lead Agency for the project, required this study as part of the environmental review process to comply with the California Environmental Quality Act (CEQA).
The purpose of the study is to provide the City with the necessary information and analysis to determine, as mandated by CEQA, whether the proposed project would cause substantial adverse changes to any historical resources that may exist in or around the project area. In order to identify and evaluate such resources, LSA conducted historical background research and carried out an intensive-level field survey.
The project area is developed with four office buildings (1901 and 1971 East 4th Street and 515 and 525 North Cabrillo Park Drive) and related parking. Only the building at 1971 East 4th Street dates to the historic period (50 years of age or older; pre-1973). Therefore, in compliance with CEQA, this is the only building that was documented and evaluated for historical significance.
As a result of the research and field survey, the commercial building at 1971 East 4th Street does not appear to be historically significant under either the California Register or City of Santa Ana criteria.
It is not a historical resource as defined by CEQA. As previously noted, the building is part of an approximately 8-acre phased development, Town Center Plaza, that includes four buildings with a cohesive design aesthetic. However, the development as a whole is less than 50 years old and none of the buildings are exceptional examples of a particular style.
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TABLE OF CONTENTS
MANAGEMENT SUMMARY ..................................................................................................................... i TABLE OF CONTENTS .............................................................................................................................. ii INTRODUCTION .......................................................................................................... 1 METHODS................................................................................................................... 4 Archival Research .......................................................................................................................... 4 Field Survey ................................................................................................................................... 4 RESULTS ..................................................................................................................... 5 Research........................................................................................................................................ 5 Field Survey ................................................................................................................................. 16 SIGNIFICANCE EVALUATION...................................................................................... 24 Definitions................................................................................................................................... 24 Evaluation.................................................................................................................................... 25 RECOMMENDATIONS ............................................................................................... 28 REFERENCES ............................................................................................................. 29
FIGURES
Figure 1: Project Location and Vicinity................................................................................................... 2 Figure 2: Project Area............................................................................................................................. 3 Figure 3: 1971 East 4th Street, façade. View to the east (1/18/22)..................................................... 17 Figure 4: 1971 East 4th Street, south and east elevations. View to the northwest (1/18/22). ........... 17 Figure 5: 1971 East 4th Street, north elevation and façade (west elevation). View to the southeast (1/18/22). ................................................................................................................... 18 Figure 6: 1971 East 4th Street, exterior stairway, east elevation. View to the north (1/18/22). ........ 18 Figure 7: 1971 East 4th Street, second floor hallway. View to the west (1/18/22). ............................ 19 Figure 8: 1971 East 4th Street, second level, center of the building. View to the south toward courtyard surrounded by office suites (1/18/22). There is a similar courtyard to the north............................................................................................................................................ 19 Figure 9: 1971 East 4th Street, second level, courtyard. View to the north toward the center of the building shows the third story office (1/18/22)................................................................ 20 Figure 10: 1901 East 4th Street, south and east elevations. View to the northwest (1/18/22). ......... 21 Figure 11: 525 North Cabrillo Park Drive, façade. View to the north (1/18/22).................................. 22 Figure 12: 515 North Cabrillo Park Drive, façade. View to the north (1/18/22).................................. 22
APPENDIX
A: DEPARTMENT OF PARKS AND RECREATION (DPR) 523 FORMS
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INTRODUCTION
At the request of FRH Realty LLC, LSA Associates, Inc. (LSA) performed a historic resources study on approximately 8 acres of land in Santa Ana, Orange County, California (Figures 1 and 2). The subject property of the study, 1901 and 1971 East 4th Street and 515 and 525 North Cabrillo Park Drive (Assessor’s Parcel Numbers 400-051-02, -09, -14, and -15), is located at the northeast corner of East 4th Street and North Cabrillo Park Drive, in Section 8, Township 5 South, Range 9 West, San Bernardino Baseline and Meridian, as depicted on the United States Geological Survey Tustin, California 7.5-minute topographic quadrangle map (USGS 1981). The study is part of the environmental review process for the proposed redevelopment of the properties. The City of Santa Ana (City), as Lead Agency for the project, required the study in compliance with the California Environmental Quality Act (CEQA; Public Resources Code [PRC] § 21000, et seq.) and the City’s Places of Historical and Architectural Significance (Chapter 30 of the Santa Ana Municipal Code).
LSA performed the present study to provide the City with the necessary information and analysis to determine, as mandated by CEQA, whether the proposed project would cause substantial adverse changes to any historical resources that may exist in or around the project area. In order to identify and evaluate such resources, LSA conducted historical background research and carried out an intensive-level field survey. The following report is a complete account of the methods, results, and final conclusion of the study.
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SOURCE: USGS 7.5' Quad - Orange (1981), Tustin (1981), CA I:\FRC2201\GIS\MXD\ProjLocation_USGS.mxd (6/15/2022)
FIGURE 1
Town Center Plaza Project
Project Location and Vicinity
0 1000 2000
FEET
LEGEND
Project Location
San Bernardino
County
Orange
County
Ã73
Ã261
Ã72
Ã133
à Ã71
90 Ã142
Ã1 Ã55
Ã22
Ã57
Ã91
Ã241
Project
Location
§¨¦105
§¨¦605
§¨¦5
§¨¦405
§¨¦5
Project Vicinity
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Fruit St
Park Court Pl
Cabrillo Park Dr
Golden Circle Dr
Park Center Dr
Brown St
Mirasol St
Dayna St
D ai nne St
Mantle Ln
6th St
Sherry Ln 4th St
400-051-02
400-051-09
400-051-14
400-051-15
§¨¦5
SOURCE: Nearmap (5/31/2022)
I:\FRC2201\GIS\MXD\ProjectArea.mxd (7/22/2022)
FIGURE 2
Town Center Plaza Project
Project Area
0 150 300
FEET
LEGEND
Project Area
Parcel Boundary
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METHODS
ARCHIVAL RESEARCH
LSA completed archival research during the months of January, May, and June 2022. Research methods focused on the review of a variety of primary and secondary source materials relating to the history and development of the project area. Sources included, but were not limited to, online sources, published literature in local and regional history, news articles, historic aerial photographs, and historic maps. The primary historical themes identified are post-World War II commercial development in Santa Ana and architecture.
FIELD SURVEY
Field surveys were conducted on January 18 and May 31, 2022. In January, LSA architectural historian Casey Tibbet and LSA photographer Dennis Lechner conducted a survey of all four buildings as part of a due diligence report. During the survey, Mr. Lechner took numerous photographs of the exterior of the buildings, as well as overviews of the property and setting and architectural details. Ms. Tibbet made detailed notations regarding the structural and architectural characteristics and current conditions of the buildings and associated features. The pair then conducted a brief reconnaissance survey of the vicinity to determine whether the project area is within a potential historic district.
On May 31, 2022, a follow-up field survey was conducted by LSA architectural historian Eugene Heck and LSA photographer Dennis Lechner. The purpose of the follow-up survey was to consider Town Center Plaza in relation to the 174-acre Parkcenter development that surrounds it. Using historic aerial photographs and contemporaneous newspaper photographs, Mr. Heck identified and fieldchecked 18 individual commercial, residential, and landscaped (park) areas within Parkcenter, starting with Town Center Plaza. The extensive fieldwork included photographing and making detailed observations of apartment complexes, tract houses, commercial developments, shopping centers, and parks within the area bounded by Tustin Avenue to the east, 17th Street to the north, Mabury Street and North Cabrillo Park Drive to the west, and 1st Street to the south.
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RESULTS
RESEARCH
Early Settlement
In 1810, José Antonio Yorba and his nephew, Juan Pablo Peralta, received a land grant from the Spanish civil governor of Alta California. Sergeant Yorba had served with the Portola Expedition, which explored the area of the current project in 1769. The Yorbas and the Peraltas were two of the most prominent families in Alta California. Yorba named the land Rancho Santiago de Santa Ana.
The land grant consisted of around 63,000 acres covering 25 miles between the Santa Ana River, the mountains to the east, and the ocean. No other rancho from the Spanish or Mexican Period is entirely located within today's Orange County boundaries (Marsh 1994).
Settlement of the region was facilitated by the partitioning of Rancho Santiago de Santa Ana in 1868. Partitioning allowed Americans such as Abel Stearns, E. Glassell, and Jacob Ross to acquire rights to large tracts of land.
William Henry Spurgeon and his brother, Granville, both natives of Kentucky, came to California during the Gold Rush. The Granville brothers and an associate, Ward Bradford, searched the area between Tustin City and the Santa Ana River, looking for a potential townsite location. In October 1869, Ward Bradford and William Henry Spurgeon purchased 74 acres of land from Jacob Ross, who had purchased a portion of the rancho land (Parker 1963). They bought the land for approximately $8 per acre (Parker 1963). After the purchase, Bradford took the westerly half of the land and Spurgeon the easterly half. Bradford soon sold off his interest in the land and moved from the area.
Spurgeon began mapping what was to become the Santa Ana townsite, named for the valley and the rancho.
Spurgeon had the townsite surveyed by George Wright, and on December 13, 1870, Spurgeon recorded a map of his new community (Parker 1963). The new subdivision consisted of 24 blocks with 10 lots each (Tibbet 2008). The boundaries of the new townsite were 7th Street on the north, 1st Street on the south, West Street (now Broadway) on the west, and Spurgeon Street on the east (Friis 1965). (This area is located 1.7 miles west of the current project area.) Spurgeon constructed a road between Santa Ana and a ford called Rodriquez crossing, which crossed the Santa Ana River west of Orange. This new road enabled the stage line that ran between Los Angeles and San Diego to come through Santa Ana before it continued in a southeasterly direction to Tustin City and San Juan Capistrano. The stage stopped twice weekly delivering passengers and mail at Spurgeon’s store at the corner of Broadway and 4th Street.
In 1877, an effort was initiated by several businessmen to convince the Southern Pacific Railroad (SP) to extend its line from Anaheim to Santa Ana (Sapphos 2011). James H. Fruit and James McFadden joined Spurgeon and organized the Western Development Company. The company raised enough funds to pay the SP a bonus and purchase 160 acres of land northeast of and adjacent to the original Santa Ana townsite (Swanner 1953). The Western Development Company named the new area “Santa Ana East” (Sapphos 2011). It plotted the tract with streets running parallel with and at City Council 18 – 776 10/3/2023
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right angles to the railroad tracks. Once the SP claimed the land it needed for a depot (1878), the company subdivided the remaining acreage into business lots (Parker 1963).
On June 1, 1886, with a population of approximately 2,000, Santa Ana was incorporated (City of Santa Ana n.d.). William Henry Spurgeon, founder of the city, was elected mayor. Two years later the Atchison, Topeka & Santa Fe Railway arrived. The Santa Ana and Tustin Street Railroad was running along First; the Santa Ana and Westminster Railroad on Second; and the Santa Ana, Orange & Tustin Street Railway connected the SP depot with downtown Santa Ana. By the close of the 1880s, the commercial core of Santa Ana remained five city blocks centered at 4th and Main Streets.
One- and two-story brick buildings predominated. Merchants resisted the SP and were reluctant to relocate or open new business establishments in Santa Ana East, close to the depot, as was hoped for by its developers (Parker 1963).
Between 1890 and 1920, many homes were built in Santa Ana East, approximately 20 square blocks of them comprise the French Park National Register District (Marsh 1994; City of Santa Ana n.d.).
Commercial development was spurred along 4th Street by the arrival in 1906 of the Pacific Electric Railway’s “Red Cars” (Friis 1965).
Downtown Santa Ana was the site of important civic growth. In 1901, the Orange County Courthouse was completed (extant; Preserve Orange County 2018). In 1903, W.H. Spurgeon donated land to build a library funded by Andrew Carnegie (demolished; Carnegie Libraries 2009). A new City Hall was erected at the intersection of Third and Main Street in 1904 (Pacific Coast Architecture Database 2005–2022). Regrettably, Santa Ana’s Chinatown, at the intersection of Bush and 3rd Streets, was destroyed by fire in 1906 (Orange County Register 2022). A city inspection had reportedly uncovered a case of leprosy there (Swanner 1953).
At the turn of the 20th century the project area was outside the Santa Ana city limits and the town of Tustin was unincorporated. An early map of the Tustin Road District shows the Mabury Tract, an irregular shape bordered by 17th Street on the north. As shown on the map, many of the lots were owned by the “Mabury Trust Company” (McBride 1913).
Hiram Mabury
Except where noted, the following section is adapted from the Pacific Bank Handbook of California, by Pacific Bank 1888.
Hiram Mabury (1825–1903) was born in Allegheny City, Pennsylvania, and remained there attending school and educating himself in business until age 18, when he moved to southern Indiana and entered the mercantile career. He displayed such energy, foresight, and general ability that he was chosen to manage three Ohio River steamers and remained in command until 1864. No record was found indicating that he served either the Union or the Confederacy during the Civil War.
He was one of the organizers and builders of the first railroad from Louisville to Indianapolis. He founded the First National Bank of Jeffersonville, Indiana, and was City Council 18 – 777 10/3/2023
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an active promoter of the Ohio Falls Car Company, a heavy industry. He was also associated with the Bank of Kentucky and the Bank of Louisville.
In 1866, he visited California, and being pleased with the climate, people, and prospects, he decided to make his home in San Francisco. In March 1888, he relocated to San Jose and was identified with that city until his death.
He was so active in banking and finance that his mug book biographer dubbed him “The Father of Banks of the Pacific Coast.” Besides his large part in building San Jose’s Woolen Mills, Street Railway, and Water Works, he was either the leader or one of the prime movers in organizing and developing the following banks:
• Pacific Bank of San Francisco
• San Jose Savings Bank
• Consolidated National Bank of San Diego
• First National Bank of Los Angeles
• Bank of Anaheim
• Commercial Bank of Santa Ana
• Salinas City Bank
• Bank of San Jose
• First National Bank of Fresno
• Bank of Tulare
• Bank of Selma
• Bank of Pasadena
• Bank of Riverside
• Garden City Bank
He had interests in several other savings banks, was a large investor in the Los Angeles Street Railway, and was an extensive landowner throughout Southern California. At the time of his death, he was one of the owners of the ferry system across the Ohio River between Jeffersonville and Louisville, Kentucky (Los Angeles Times 1903).
Like James Irvine (1827–1886), Llewellen Bixby (1825–1896), and other California land barons, Hiram Mabury invested for the long-term. Hiram and his wife, Josephine, had two sons and five daughters (Los Angeles Times 1903). Although he occasionally turned a quick profit, as in the case of his real estate investment near MacArthur Park, which went on to become the site of the Downtown Branch of the Los Angeles Public Library (Los Angeles Times 1925), his overall strategy was to keep his land holdings intact, living off the income generated by operations such as ranching, oil leases, and growing Valencia oranges in Orange County.
To protect the family fortune, he formed the H & J Mabury Trust Company of Boston, Massachusetts (Los Angeles Times 1925). At some point, perhaps around the time of Hiram’s passing, the trust was reorganized as the H & J Mabury City Council 18 – 778 10/3/2023
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Company (California Secretary of State var.). His widow Josephine moved to Los Angeles to be near her sons (Ancestry.com var.; Oakland Tribune 1912). There was a great scandal in 1912, involving one of the daughters, who committed suicide after being arrested in New York for concealing gems in her hat to avoid paying customs duties (Napa Weekly Journal 1912).
Project Area
The current project area was at one time a portion of approximately 400 acres owned by the H & J Mabury Company, known locally as “The Mabury Ranch,” between 1st and 17th Streets, Mabury Street, and Tustin Avenue (Santa Ana Orange County Register 1939). On the eve of World War II, the Mabury Ranch manager expressed confidence in the future of the citrus industry. He was repurchasing 10 acres of former company orange groves at the southeast corner of the intersection of 17th and Mabury Street (currently the site of an El Pollo Loco restaurant; Santa Ana Orange County Register 1939). This gave the H & J Mabury Company, except for one or two properties, solid frontage of land from 1st Street to 17th Street on Mabury Street (Santa Ana Orange County Register 1939).
A comparison of historic aerial photographs of the area shows two small housing tracts were built in the 1950s and Interstate 5, but it was not until the 1970s that the orange groves markedly begin to disappear (Aerial Photographs var.).
Plans to develop the 174-acre Mabury Ranch were unveiled by the O. K. Earl Corporation of Pasadena at a Santa Ana City Council meeting (Los Angeles Times 1970). Known as the “Mabury Orchards” project, Earl estimated it would take 7 to 10 years to complete, at a cost of $100 million (Los Angeles Times 1970). About 50 acres had been developed when the project was transferred to the Earl Development Corporation, a newly formed subsidiary of the O. K. Earl Corporation, headed by Senior Vice President Donald A. McGilvray (Los Angeles Times 1971 and 1972).
Don McGilvray (1924–1987) was an influential developer who went on to form Parkcenter Corporation, acquiring all the development rights to the remaining 125 acres from H & J Mabury Co. (Los Angeles Times 1975 and 1987; California Secretary of State var.). He had earlier expressed his views regarding speculative building in a panel discussion before the industrial development committee of the Los Angeles Chamber of Commerce: The investor should count on taking no more than 12 to 18 months to lease the completed building. In deciding when to break ground for a speculative structure, he advised that speculators “Pick a time of prosperity. If you pick the wrong business cycle, you may have no takers, and time, in our business, is money.” Build all-purpose, flexible structures, 10,000 to 25,000 square feet in size. To allow for future expansion of tenants, the builder should avoid overbuilding his lot. He called for flexibility in leasing; small firms taking a shortterm lease are often willing to pay more than a long-term occupant (Los Angeles Times 1965a).
It was McGilvray who commissioned Don C. Fassknacht and Associates, an architectural landscape firm based in Tustin, to do site planning and environmental concepts for a 290-unit garden apartment complex on Cabrillo Park Drive at 15th Street; about half of the 11.24-acre site was dedicated to open space and landscaping (Los Angeles Times 1973a and 1973b). McGilvray and his team of former O. K. Earl executives may be responsible for the high quality of much of Parkcenter’s City Council 18 – 779 10/3/2023
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architecture and landscape architecture because they retained architectural control of the development after selling the land to individual developers (Santa Ana Orange County Register 1977).
Sunset Builders, owned by Robert Porter Gillman, has been identified as the builder of 1971 East 4th Street (City of Santa Ana var.). Bob Gillman (1930–1999) had worked as a farm hand on a ranch at 4612 Baranca Road in his youth; he served as an aircraft mechanic in the Air Force Reserve throughout the 1950s and 1960s, and he met his wife while stationed in Fairbanks, Alaska (Ancestry.com var.). In 1961, he was pictured with the Director of Civil Defense for Orange County, a retired Air Force Major, checking plans for the construction of civilian residential fallout shelters (Tustin News 1961). During the Cuban Missile Crisis of October 1962, his reserve unit was called to active duty and sent to Florida for 1 month (Petaluma Argus Courier 1987). Sunset Builders and Ken Himes were identified as the architect and builder of 525 Cabrillo Park Drive, the third office building constructed in Town Center Plaza (City of Santa Ana var.). They also are the architect and builder for El Rancho Plaza at 421 North Brookhurst Street in Anaheim (Los Angeles Times 1965b and 1965c).
Adjacent to the El Rancho Plaza buildings, at 511 North Brookhurst Street, is a building that bears a striking resemblance to 525 Cabrillo Park Drive, the third of the Town Center Plaza buildings (Google Streetview).
Mr. Himes was not listed in the 1970 edition of American Architects Directory. He is a licensed architect in the states of California and Washington (California Secretary of State var.). Various news articles show Mr. Himes has designed many buildings, primarily in Southern California in the 1970s and 1980s as a partner in Kenneth R. Himes and Associates, Himes-Peters, and Himes Peters Jepson (Tibbet 2022). There is no evidence indicating that Mr. Himes’ work has influenced the course of architectural development.
Postwar Growth and Suburbanization
Except where noted, this section is adapted from Tract Housing in California, 1945–1973: A Context for National Register Evaluation, by the California Department of Transportation 2011.
The population of the United States grew by more than 50 percent between 1940 and 1970, from about 132 million residents to just over 203 million. This growth was not uniform across the country, but varied greatly by region, within regions, and even within metropolitan areas. Generally, the Western states (from the Rocky Mountains to the Pacific Coast) grew at a much greater rate than the rest of the country during this period. Rural populations declined across the country, relative to metropolitan areas. In the 1950s alone, more than 10 million Americans moved from farms to urban or suburban areas.
A substantial majority of the population growth in the postwar era occurred in the suburbs. The proportion of the U.S. population living in suburbs grew slowly in the period between the two World Wars, from 15 to 20 percent. However, by 1970 more than a third of all Americans lived in the suburbs and the nation's approximately 75 million suburbanites for the first time exceeded the number of Americans living in cities. The United States had become a suburban nation.
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California grew much more rapidly in the postwar period than most of the other regions of the country. Many servicemen who had been stationed in California bases during the war decided to settle in the State after being discharged, rather than returning to their home states. Job growth sparked by the defense economy brought migrants from across the country to California. As in the rest of the country, the postwar baby boom also played a significant role in the State’s population growth. While California’s population grew by 88 percent between 1950 and 1970 (from 10.6 million to 19.95 million), the number of school-age children quadrupled during this period.
California ranked fifth in population among the states in the 1940 census, following New York, Pennsylvania, Illinois, and Ohio. Comparison with Ohio illustrates California's dramatic growth in the postwar period. In 1940, the population of California was close to that of Ohio, with both states having slightly more than 6.9 million residents. Between 1940 and 1970, Ohio grew at the same rate as the country, about 54 percent, to 10.65 million. California's population nearly tripled during this same period, to almost 20 million, and was fast approaching a population twice that of Ohio. California passed New York to become the nation's most populous state in 1962. More than one in every 12 Americans now lived in California.
The Postwar Economy
The United States experienced nearly three decades of sustained economic growth following World War II. With much of the rest of the industrialized world ravaged by the war, the U.S. exported food and manufactured goods across the globe.
Domestic spending on both industrial and consumer goods also drove postwar economic expansion. By 1973, the nation’s gross national product had grown to three times what it had been in 1948.
In the early postwar years, the high rate of household formation and the baby boom led to a dramatic increase in the purchase of consumer goods, such as household furniture, appliances, toys, and children’s clothing. While overall consumer spending increased by 60 percent during the second half of the 1940s, spending on furniture and appliances increased by 240 percent. Americans purchased more than 11 million television sets and 20 million refrigerators from the end of the war to 1951.
In California, wartime growth of industrial and military facilities set the stage for postwar prosperity. Military appropriations to the State, particularly for hi-tech research and development, remained high throughout the Cold War era, which of course included the Korean War and the Vietnam War. As a leading center for the aircraft and aerospace industries, Southern California benefitted enormously from military spending. Defense contracts and military bases became a pillar of the State’s economy, along with manufacturing, agriculture, tourism, and the television and motion picture industries. Growth itself became an important part of the California economy, sustaining retail sales and a robust construction industry.
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Transportation and Suburban Growth
Automobile purchases were another large part of the increase in consumer spending during the postwar years. Annual domestic production of automobiles rose from 2 million in 1946 to 8 million by 1955, while motor vehicle registrations more than doubled from about 26 million in 1945 to 54 million in 1956. This growth in auto ownership coincided with a decline in the use of buses, streetcars, and trains. Transit ridership within metropolitan areas of the U.S. peaked in 1947 and began a long, steady decline thereafter. The geographical spread and low population densities of the postwar suburbs, combined with the increasing dispersion of employment and shopping centers, made transit impractical for most people living outside the older and denser urban areas. Los Angeles led the nation’s major cities in both rates of auto ownership and abandonment of public transportation. By the end of the 1950s, 95 percent of all trips in Los Angeles were by private automobile.
As in the rest of the United States, much of the postwar housing boom in California predated the construction of the Interstate. In general, freeway construction was neither a cause nor a means of metropolitan expansion in the late 1940s and 1950s.
President Eisenhower signed the Federal Aid Highway Act into law in 1956, but many of California’s most important freeways remained under construction more than a decade later. Before the war or shortly thereafter, if a freeway was planned, development would commence along its corridor, even though the actual construction of the freeway was years away. In many other areas, builders anticipated that existing roads and highways would be sufficient or would be improved and expanded to accommodate future growth. At the close of the 1940s, only a couple of freeways had been built, such as the North Sacramento freeway or Los Angeles’s Arroyo Seco Parkway.
Substantial extension of metropolitan freeways in the late 1960s and 1970s brought about a second phase of suburban growth more extensive than the initial postwar boom. At least initially, the new freeways allowed commuters to live farther from their places of work without a significant increase in commuting time. The benefit of more distant but less expensive land (and therefore more affordable housing) began to compete with the benefit of proximity to employment centers, leading to the explosive physical expansion of metropolitan areas.
The migration of jobs from cities to suburbs followed close on the heels of suburban population growth. More than three-quarters of all new manufacturing and retail jobs created between 1950 and 1970 were in suburban areas. By 1973 suburban employment exceeded city employment. This later phase of postwar growth saw the beginning of “edge cities,” with midrise and even high-rise office buildings and shopping malls forming new centers of employment, professional services, and retail trade, adjacent to freeway interchanges. Edge cities arose well beyond not only the older central cities and streetcar suburbs, but far beyond much of the earlier phase of postwar suburban growth as well.
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For example, although the East Bay suburbs between Oakland and San Jose experienced dramatic growth from the mid-1940s to the 1950s, by the late 1960s the fastest growth was in the east-of-East Bay communities situated along the BART line and the Interstate 680 corridor: Concord, Walnut Creek, and Pleasanton.
Similarly, as the San Fernando Valley and the southerly suburbs of Los Angeles approached build-out in the mid-1960s, housing construction moved north, into Ventura County; east, into the Inland Empire communities of Riverside and San Bernardino counties; and especially south, into coastal Orange County.
The postwar metropolitan region is often imagined as a central city dominated by a downtown business district and surrounded by bedroom suburbs. However, this image was accurate only briefly and then only as a snapshot of a constantly evolving metropolis. By the mid-1970s, most American metropolitan areas had become complex and multicentered entities with housing, retail, and employment widely dispersed across an area far greater than that of prewar metropolitan areas.
Modernism and New Formalism Styles
Except where noted, this section is adapted from “A History of American Architecture: Buildings in Their Cultural and Technological Context,” by Mark Gelernter 1999.
In the aftermath of the devastation wrought by World War II much of the world, including America, acquired a new enthusiasm for technology. This eventually influenced architecture. High Technology fully entered most people’s lives during the 1950s and 1960s: commercial jets; televisions; landing a man on the moon.
Many people believed that science and technology would solve most of the world's problems. People in the Third World (former colonies) mimicked the High Technology of Europe and America. Architectural ideas seen to be derived from High Technology spread throughout the world.
This amounted to the triumph of Modernism, whose austere, ahistorical forms symbolized a break with the past and a shiny new age of peace and prosperity. It was the atomic age. The Modernist conception of design as rational problem-solving appealed to the generation that had similarly used rational problem-solving methods to tackle the logistical complexities of World War II. The Modernist emphasis on rational and efficient building techniques accorded well with the general enthusiasm for High Technology during this period. For both government and private corporations, the visual characteristics of the Modernist style seemed to sum up their own self-image: rational, efficient, confident possessors of immense power and wealth, and yet neither flashy nor desirous of individual expression.
Architectural styles possess no single, intrinsic meaning. In the 1920s and 1930s, radical Modernism stood for Socialism and Collectivism. In the 1950s, Modernism stood for conservative American Government and American Free Enterprise (corporations). By the 1960s, the Modernist style had crossed all economic and political boundaries into: Communist countries of the Soviet Block; Social City Council 18 – 783 10/3/2023
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Democratic Western European countries; developing nations of the Third World.
Most observers probably saw the same virtues in the Modernist style for the postwar era. Some valued the style because it was the official style of America, now the unquestioned leader of the Western world.
American prestige helped spread Modernism, but the main ideas still came from Europe. Le Corbusier (1887–1965) was promoting a popular, influential version of Modernism. He moved beyond the white boxes of his 1920s designs to compose powerful forms like the Unite d’habitation, Marseille, France (1946–1952) and other projects. He moved away from thin stucco walls to massive concrete structures heavily modeled with external sun screens and other projections. Le Corbusier built these in roughly cast concrete (“biton brut”) which frankly expressed the rough boarding framework into which the concrete was poured. Later known as “Brutalist” style, it was primarily a raw concrete construction technique, although the structures also had a primitive emotional presence.
In the 1920s, Le Corbusier had proposed bulldozing central Paris “…to make way for free-standing towers, regularly lined up in the landscape.” World War II destruction gave him the opportunity to put his ideas into practice. Unite d’habitation was a prototype; but one of what he wanted, which was an entire city of housing blocks standing on columns above the sweeping natural landscape, each one intended to replace an entire traditional neighborhood.
Interior “streets” ran down the length of this prototype on every third floor, giving access to interlocking two-story tall apartments. Le Corbusier provided a variety of unit sizes, hoping to encourage a variety of social groups to live together. A shopping arcade in the middle of the block, playgrounds, and a gymnasium on the roof were meant to provide all the usual neighborhood amenities within the structure itself. Fundamentally, Le Corbusier saw Modernism as, “…a mechanism for re-engineering society.”
Le Corbusier’s vision of pristine towers hovering above the landscape inspired many postwar Modernist architects and urban planners. But his Marseille scheme proved too controversial and too expensive; no further expansion was attempted. Many housing projects in Europe were in bombed-out city centers, and many were on the periphery. A popular variation of Le Corbusier’s concept was the point-block or tower block, which “…piled more stories on a smaller footprint to create what was in essence a housing skyscraper.” These stood clustered together on the landscape and often rivaled the old church spires as the most dominant features on the skyline. Many European governments embraced these new forms of housing as a fast, cheap way to rebuild and a way to control the endless spread of suburbs during the baby boom. It was affordable housing for a wider range of social classes— government supported.
American cities were not bombed out, but decades of middle-class “white flight” to suburbs left city cores surrounded by a disproportionate number of poor people, City Council 18 – 784 10/3/2023
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usually racial minorities. Money too fled the cities with the middle classes, leaving many neighborhoods with a crumbling housing stock and decaying services.
Conditions seemed so dire President Truman signed the Housing Act of 1949, giving government authority to compel land acquisition in city centers. Government then sold or leased the land to redevelopment agencies who constructed statesubsidized housing for the poor. “Urban renewal,” as it was euphemistically known, represented the continuing legacy of Roosevelt's New Deal efforts to solve problems by means of extensive federal intervention. As in prewar Federal Housing projects, the architects and planners chose not to reconstruct traditional rows of houses on streets; they chose to construct Le Corbusier’s housing towers in urban parks. In America, wrecking balls and bulldozers cleared the way, funded by federal tax dollars. Adding to the destruction was President Eisenhower's Interstate Highway Act of 1956, linking together most of America's largest cities and towns. The Interstate shot into commercial centers of cities, irreparably splitting old neighborhoods in two and providing an even easier route for those fleeing to suburbs. In America, Le Corbusier’s idyllic landscape quickly deteriorated into asphalt parking lots and uncultivated dirt. Vandalism and crime were rampant in federal housing projects. Whether it was due to social factors or the physical design, it gave Modernism a black eye.
Mies van der Rohe (1886–1969), student of Peter Behrens, was the other great Modernist architect of this time. Mies headed the Bauhaus for 3 years until Nazis closed the school in 1933. He went to the United States in 1938, where he became director of the Armour Institute (later known as the Illinois Institute of Technology), in Chicago.
Far less interested in the social aspect of architecture than Le Corbusier, Mies saw buildings as technical and visual problems to be solved. His motto was “less is more.” He wanted architecture to reveal fundamental essence (“form follows function”). His technique was to build a simple and rational structural cage onto which he hung an external cladding system completely subservient to the structure’s inherent geometrical grid. Because the cladding system was now reduced to a thin and lightweight veneer of glass, it came to be known as a curtain wall, acknowledging that it simply hung like a curtain from the frame to protect the insides of the building from the weather. Skidmore, Owings and Merrill (SOM) had earlier experimented with a number of these ideas, but Mies clarified and perfected them.
Mies offered low-rise and high-rise versions of his style. The campus for Illinois Institute of Technology was the low-rise idea. He placed several freestanding pavilions on a rational planning grid, each one comprised of simple boxes with flat roofs. Each building was itself strictly planned on a rational cartesian grid, which established the location of the structure, the walls and openings.
The high-rise idea is exemplified by the Seagram Building in New York City, 1954-58 (Phillip Johnson as associate architect). The Seagram Building is a simple box strictly City Council 18 – 785 10/3/2023
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organized with a regular grid. There are no visual surprises or complexities. Careful proportions, the studied craft of simplicity, and the inexorable regularity of repeating elements are its character-defining features. Mies had to fireproof the steel frame with concrete, so the metal we see on the outside of the building is not the real structure but rather a veneer simulating the structure. The aesthetic desire for a certain appearance inevitably overcame the philosophical desire to express everything truthfully. Like Le Corbusier, Mies lifted the Seagram Building off the ground to form an entry lobby and to create a sense of the outdoors flowing through the building. He also set the building back from the street and apart from its neighbors on a public plaza, treating it as an isolated object in space rather than as an infill in a continuous streetline of buildings. Mies had a pure vision of his glass boxes, uncorrupted by the visual clutter of the city around them. If he could not build on a campus like ITT, he would carve out a little park. So where once only major public buildings like town halls or churches stood apart from the city in their own plazas or town squares, now private corporate headquarters were elevated to the same status.
One Miesian building set back from the continuous façade of buildings stands alone as a jewel; an entire street of them set back in their plaza radically alters the urban setting. Many admired the way in which these plazas opened up the cramped, crowded cities. When a large number of Miesian buildings in their plazas clustered together, it became a source of civic pride. Los Angeles, Denver, Atlanta, Hong Kong; the city began to exude the image Le Corbusier envisioned: gleaming, hi-tech centers of commerce and industry, unencumbered by the past and looking boldly to the future.
However, as the future unfolded these curtain-walled boxes posing as corporate headquarters, office parks, government buildings, apartment buildings, schools, and shopping centers caused many to question whether an abstracted ideal vision is preferable to a more nuanced approach, designing differently for different locations. To these architects and critics “Less is a bore.” The Modernist vision looked windswept and barren, devoid of the hustle and bustle, visual and sensory richness, and spatial enclosure of traditional urban streets. In the 1950s and early 1960s, even as Modernism was sweeping across America, they sensed that it had lost sight of art or beauty in favor of constructional efficiency. They were well aware of the virtues of a rational constructional system, but the work did not express the highest cultural aspirations of what was now the most powerful nation on earth.
These architects were known as the New Formalists or Neo-neo-Classicists. As the name suggests, many turned to traditional Classical ideas for inspiration. They explored various ways in which the basic frame and cover box could be elaborated or even decorated to provide a more elegant or commanding presence. After all, the Classical temple was based on a rational grid of columns and beams, just like a Miesian glass box. Many New Formalists, including Edward Durell Stone, Minoru Yamasaki, and Philip Johnson, played out Modernist variations on Classical forms.
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The American Embassy in New Delhi, India, exemplifies Stone’s approach. He wrapped a Classical colonnade around a simple box, although he replaced the usual thick stone columns with astringently thin gilded steel supports. He further modernized and dematerialized the walls of the box itself, constructing them of perforated terrazzo blocks which served as sun screens. Perforated screens in masonry and aluminum, and the extensive use of richly gilded surfaces and structures, were among the character-defining features of this style. The master architect Philip Johnson also explicitly referred to the Classical temple in his Sheldon Memorial Art Gallery, Lincoln, Nebraska, 1963. Here he even hints at a Roman arcade, with the flattened arches smoothly bridging between the sharp-edged columns. Yet, the overall effect is decidedly modern. Each bay looks like a giant panel that was stamped out by an industrial process, like the one that stamps out car doors, while the open bays at the center of the entrance reveal a Miesian frame and glass infill.
Although examples of the New Formalism can be found scattered around the country, the idea never caught on extensively. From the strictly Modernist point of view, the forms returned too explicitly to the discredited traditional styles. Their constructional realities were too often disguised or obscured. From a traditionalist point of view, the lack of detail failed to moderate the scale and bulk of what were still in reality large Modernist boxes. Both sides tended to view these buildings as lacking in substance. They may also be viewed as tentative precursors to Postmodernism, the architectural movement of the 1970s and 1980s that attempted to bridge the gap between the modern and the traditional.
Previous Studies
In January 2022, LSA prepared a due diligence report that included preliminary research and field observations for the project area (Tibbet 2022). As part of that study, input was sought from various historical groups and individuals. The feedback provided suggested that the project area might be part of the Parkcenter development and that Parkcenter may be an important planned development in Santa Ana. It was also suggested that the project area (Town Center Plaza) be looked at in the context of the overall Parkcenter development. The cohesive design aesthetic of the four buildings in the project area was also noted. This input was taken into consideration as part of this study.
FIELD SURVEY
January 2022
During the January 2022 survey, all four buildings in the project area were intensively surveyed although only the building at 1971 East 4th Street is 50 years of age (Figures 3–9). The building is described below.
This beige, three-story commercial building has dark brown trim. It is rectangular in plan, wood or steel framed, and rests on a poured concrete foundation. Exterior wall cladding is textured stucco.
The composition roof is flat, with a low-pitched parapet visibly clad in red clay Spanish tiles. Broad eaves extend beyond a cantilevered balcony, which is arcaded and has simple metal railing. The City Council 18 – 787 10/3/2023
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façade is symmetrical and centered on a monumental arched entry projecting above the parapet.
The entry extends the full length of the building’s minor east-west axis. The symmetrical façade on the other side of the building is identical; in effect, there are two primary elevations. The balcony’s arcade of two dozen bays is repeated and extended to the minor elevations. The office suites are arranged in a grid centered on the elevator shaft. Eleven-foot-tall ceilings define the proportions of their wood surround door openings and glass curtain wall panels.
Figure 3: 1971 East 4th Street, façade. View to the east (1/18/22).
Figure 4: 1971 East 4th Street, south and east elevations. View to the northwest (1/18/22).
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Figure 5: 1971 East 4th Street, north elevation and façade (west elevation).
View to the southeast (1/18/22).
Figure 6: 1971 East 4th Street, exterior stairway, east elevation. View to the north (1/18/22).
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Figure 7: 1971 East 4th Street, second floor hallway. View to the west (1/18/22).
Figure 8: 1971 East 4th Street, second level, center of the building. View to the south toward courtyard surrounded by office suites (1/18/22). There is a similar courtyard to the north.
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Figure 9: 1971 East 4th Street, second level, courtyard. View to the north toward the center of the building shows the third story office (1/18/22).
The building reads from the street as two stories; the third floor consists of one small office space over the entry, accessed by stairs. Exterior staircases at the corners of the building have pebblestone treads, and distinctive railings of wood and metal. The staircases have metal stringers. Brick masonry walls are seen by the corner staircases and by the elevator shaft on the second floor, where they have arched openings with metal gates accessing two small “courtyards.” The building is in good condition. Other than the usual modifications made by the tenants to the interior spaces, there were no signs of significant alterations. At a little over 40,000 square feet, it may be classified as a medium-sized office building. Mature pine trees line gently sloping ground toward 4th Street; mature palm trees line the drive toward the center of the project area (Town Center Plaza). This building is the oldest of four built between 1971 and 1978; together, they comprise the small business park known as Town Center Plaza. The building was designed on a grid and likewise, the business park was laid out on a grid that determined the relationships between the buildings. Central to the modernist design is the “plaza,” a large open area, in this case an asphalt concrete paved parking lot.
The second oldest building in the park is 1901 East 4th Street (1974; Figure 10). It has a square plan and textured stucco walls, with red Spanish clay roof tiles, cantilevered balconies, and arches. More importantly, its notable design features and motifs tie it to the other buildings, as do minor details.
For example, the distinctive wood and metal railing seen at 1971 is again seen at 1901, as are the pebblestone treads, but this time the staircase stringers are wood, not metal. As a modernized version of a Southern California Spanish Colonial Revival regional identity dating back to Arthur Benton and Charles Lummis, these buildings complement each other.
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Figure 10: 1901 East 4th Street, south and east elevations. View to the northwest (1/18/22).
The third and fourth buildings completed in the park are more closely related to each other than to the first two, although they all share many features (Figures 11 and 12). Ken Himes is known to have designed 525 North Cabrillo Park Drive (1976) and likely designed 515 North Cabrillo Park Drive (1978) as well (City of Santa Ana var.; Los Angeles Times 1975). With these buildings, abstraction has progressed a bit further from regional identity, eschewing balconies, toward more classic, templelike façades. The articulated horizontal bands on both 525 and 515 are notable.
Each of the four buildings stands as a separate object in space, related by materials, workmanship, and design. They do not crowd each other. The outer lot lines of the parcels form the business park boundaries.
May 2022
The focus of the May 2022 survey was threefold:
1. To determine whether the 174-acre Parkcenter development has any cohesive design elements such as complementary architectural styles, signage, streetlights, street trees, or other features that identify it as a planned development;
2. To determine if the Parkcenter development has any potential to be a historic district; and
3. To determine whether the Town Center Plaza displays any design features that connect it to or identify it as part of the Parkcenter development.
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Figure 11: 525 North Cabrillo Park Drive, façade. View to the north (1/18/22).
Figure 12: 515 North Cabrillo Park Drive, façade. View to the north (1/18/22).
The survey revealed that the Parkcenter development does not have a cohesive design aesthetic.
Instead, it appears that although it may have been planned as a large mixed-use development, it was developed by individual entities with oversight by Parkcenter Corporation headed by McGilvray.
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As a result, the 174-acre area has some well-designed properties, but it does not have any particular character or identity. Furthermore, most of the development, including three of the Town Center Plaza buildings, is not yet 50 years of age. At this time, based on this reconnaissance-level survey, Parkcenter does not appear to have the potential to be a historic district.
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SIGNIFICANCE EVALUATION
Based on the research results discussed above, the following sections present the historical significance evaluation of the building at 1971 East 4th Street in the project area under the California Register and local criteria to determine whether it qualifies as a “historical resource” for the purposes of CEQA. Although the other buildings in the project area are not yet 50 years of age, some consideration is given to the business park as a whole.
DEFINITIONS
CEQA (PRC Chapter 2.6, Section 21083.2 and California Code of Regulations [CCR] Title 145, Chapter 3, Article 5, Section 15064.5) calls for the evaluation and recordation of historical resources. The criteria for determining the significance of impacts to historical resources are based on Section 15064.5 of the CEQA Guidelines and Guidelines for the Nomination of Properties to the California Register. Properties eligible for listing in the California Register and subject to review under CEQA are those meeting the criteria for listing in the California Register, National Register, or designation under a local ordinance.
California Register of Historical Resources
The California Register criteria are based on National Register criteria. For a property to be eligible for inclusion in the California Register, one or more of the following criteria must be met:
1. It is associated with the events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States;
2. It is associated with the lives of persons important to local, California, or national history;
3. It embodies the distinctive characteristics of a type, period, region, or method or construction, or represents the work of a master, or possesses high artistic values; and/or
4. It has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the Nation.
In addition to meeting one or more of the above criteria, the California Register requires that sufficient time has passed since a resource’s period of significance to “obtain a scholarly perspective on the events or individuals associated with the resource.” Fifty years is used as a general estimate of time needed to develop the perspective to understand the resource’s significance (CCR 4852 [d][2]).
The California Register also requires that a resource possess integrity, which is defined as “the authenticity of an historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource’s period of significance” (California Office of Historic Preservation 1999:2). To retain integrity, a resource should have its original location, design, setting, materials, workmanship, feeling, and association. Which of these factors is most important depends on the City Council 18 – 795 10/3/2023
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particular criterion under which the resource is considered eligible for listing (California Office of Historic Preservation 1999).
City of Santa Ana (Chapter 30-Places of Historical and Architectural Significance) Any person or group may request a building, or part thereof, structure, object, or site to be designated to be included on the city register of historical properties (called “register” in this section). The applicant must submit documentation that demonstrates how the nominated building, structure, object, or site satisfies the criteria for designation. A building, structure, object, or site may be designated for inclusion on the register if the building, structure, object, or site is 50 or more years old and if the commission finds that one or more of the following conditions are met:
1. Buildings, structures, or objects with distinguishing characteristics of an architectural style or period that exemplify a particular architectural style or design features
2. Works of notable architects, builders, or designers whose style influenced architectural development
3. Rare buildings, structures, or objects or original designs
4. Buildings, structures, objects, or sites of historical significance which include places:
a. Where important events occurred;
b. Associated with famous people, original settlers, renowned organizations and businesses; c. Which were originally present when the city was founded; or d. That served as important centers for political, social, economic, or cultural activity.
5. Sites of archaeological importance
6. Buildings or structures that were connected with a business or use which was once common, but is now rare
EVALUATION
The building at 1971 East 4th Street was constructed in 1971 and is being evaluated for historical significance in compliance with CEQA. It is one of four buildings in the approximately 8-acre Town Center Business Park, which was developed between 1971 and 1978.
The building is evaluated below and on Department of Parks and Recreation (DPR) forms (Appendix A) for historical significance under the criteria for listing in the California Register and for designation under the City’s ordinance. Many of the City’s criteria for designation are similar to those of the California Register. Where appropriate, the two sets of criteria have been combined to avoid redundancy.
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California Register Criterion 1: Is associated with the events that have made a significant contribution to the broad patterns of California’s history and cultural heritage. Santa Ana Criteria 4(a) and 4(d): Buildings, structures, objects or sites of historical significance which include places: (a) Where important events occurred; and (d) That served as important centers for political, social, economic, or cultural activity.
This building is one of four buildings within the Town Center Plaza business park and the only one that has reached 50 years of age. Town Center Plaza is marginally associated with postwar (1945–1973) growth and suburbanization, since the building at 1971 East 4th Street was constructed at the end of this period. Town Center Plaza is within the 174-acre postwar (and beyond) mixed-use Parkcenter development area and is less than 2 miles east of Santa Ana’s original business district. The Parkcenter area was among the last of the orange groves to be developed. Historic aerials show a gradual buildout of this area between Interstate 5, State Route 55, and 17th and 1st Streets during the 1960s, 1970s, and 1980s. Many buildings in the area were constructed less than 50 years ago. Field survey observations outside the project area, however, did not confirm a level of visual cohesion sufficient to identify a potential historic district to which Town Center Plaza contributes. It is possible that additional research and the passage of time may warrant the formal evaluation of Parkcenter, but for now it remains outside the scope of the current study and, in any case, three of the four buildings in the Town Center Plaza are not yet 50 years of age.
California Register Criterion 2: Is associated with the lives of persons important in our past. Santa Ana Criterion 4(b): Buildings, structures, objects or sites of historical significance which include places: (b) Associated with famous people, original settlers, renowned organizations and businesses.
The land is indirectly associated with Hiram Mabury, a 19th century venture capitalist who invested in California real estate and was active in banking. Mabury and his family owned land in Orange County but resided elsewhere. No famous people, original settlers, renowned organizations or businesses are associated with the building at 1971 East 4th Street or the Town Center Plaza business park.
California Register Criterion 3: Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values.
Santa Ana Criteria 1 and 2: (1) Buildings, structures or objects with distinguishing characteristics of an architectural style or period, that exemplify a particular architectural style or design features; and (2) Works of notable architects, builders, or designers whose style influenced architectural development.
The building has distinguishing characteristics of the Modern style including horizontal massing, a very low-pitched roof, interior courtyards and spaces designed to bring the outside in, recessed and protected entries, and glass walls. It also has characteristics of the New Formalism style such as the arches/arcades, monumental entrances, smooth wall surfaces, and delicate City Council 18 – 797 10/3/2023
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details like the stair railings. However, it is not a true representation of either style. No evidence was found that the building at 1971 East 4th Street is the work of a master architect, builder, or designer. While the building design incorporates interesting architectural details, it does not possess high artistic values because it does not epitomize the design principles of a particular style more fully than other buildings of a similar era and style.
As a whole, Town Center Plaza has many of the distinguishing characteristics of the Modern and New Formalism styles and is clearly identifiable as a small business park. The designs, materials, workmanship, and landscaped setting all retain what appears to be a high level of integrity.
However, none of these buildings are of exceptional importance and only the earliest of them, 1971 East 4th Street, has achieved 50 years of age.
California Register Criterion 4: Has yielded, or may be likely to yield, information important in prehistory or history.
Santa Ana Criterion 5: Sites of archaeological importance.
This 1971 building was built of standard materials using standard building techniques; it is of no archaeological importance and is not likely to yield important information about history or prehistory.
The following addresses the remaining Santa Ana criteria for designation. Santa Ana Criterion 3: Rare buildings, structures, or objects or original designs.
The Town Center Plaza building at 1971 East 4th Street incorporates elements of the Modern and New Formalism styles, neither of which is rare in Orange County or the larger Southern California region. Business parks, such as Town Center Plaza, are also common throughout the area.
Santa Ana Criterion 4(c): Buildings, structures, objects or sites of historical significance which include places which were originally present when the city was founded.
The Town Center Plaza building at 1971 East 4th Street is a postwar commercial building; the business park was not present when the city was founded. Santa Ana Criterion 6: Buildings or structures that were connected with a business or use which was once common, but is now rare.
The Town Center Plaza building at 1971 East 4th Street was never connected with a business or use which was once common but is now rare. Most of the tenants provide professional services such as medical, legal, or financial. Town Center Plaza as a whole is a business park, which is a very common property type.
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RECOMMENDATIONS
As a result of the research and field survey, the commercial building at 1971 East 4th Street does not appear to be historically significant under either the California Register or City of Santa Ana criteria.
It is not a historical resource as defined by CEQA. Although it is part of an approximately 8-acre phased development (Town Center Plaza) with a cohesive design aesthetic, the buildings are not exceptional examples of a particular style, and the development as a whole is less than 50 years old.
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REFERENCES
Aerial Photographs
Var. 1980 and 1985 accessed online June 7, 2022 at: http://www.historicaerials.com and 1939 to 1990 accessed online June 7, 2022 at: https://www.ocgis.com/ocpw/historicalimagery/.
Ancestry.com
Var. A variety of records were accessed online in January and June 2022 at: http://home. ancestry.com/. These include city directories, voter registration records, and United States Census Data.
California Department of Transportation
2011 Tract Housing in California, 1945-1973: A Context for National Register Evaluation.
Sacramento: Caltrans.
California Office of Historic Preservation
1999 California Register and National Register: A Comparison (for purposes of determining eligibility for the California Register), OHP Technical Assistance Series #6.
California Secretary of State
Var. bizfile Online. Records accessed June 2, 2022 at: http://sos.ca.gov/.
Carnegie Libraries
2009 Santa Ana, Orange County. Accessed online in June 2022 at: https://www.carnegielibraries.org/california/santaana.html City of Santa Ana
n.d. City of Santa Ana website accessed June 12, 2022 at: http://www.ci.santaana.ca.us/library/history/timeline.asp.
Var. Building Permits provided by City staff. On file at the City of Santa Ana.
Friis, Leo J.
1965 Orange County Through Four Centuries. Pioneer Press, Santa Ana California, California.
Gelernter, Mark
1999 A History of American Architecture: Buildings in Their Cultural and Technological Context.
University Press of New England. Lebanon, NH.
Los Angeles Times
1903 Millionaire Financier Dead in San Jose. July 8, page A4. 1925 Thousands Percent Yearly. January 1, page C18.
1965a Speculative Industrial Building: Take a Chance and Think Small. July 7, pages 49 and 55. 1965b Office Center Ground Broken. September 19, page 210.
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1965c Photo Standalone 29—No Title. September 19, page M26. 1970 Mabury Ranch Development Plans Outlined. April 8, page 56. 1971 Earl Forms New Division. September 12, page 157.
1972 Republic Title in New Offices. March 12, page 149. 1973a 2 Streets Completed. July 1, page 142.
1973b Fassknacht to Lay Out Site. August 12, page 97.
1975 Parkcenter Corp. Buys Old Santa Ana Ranch. August 10, page 66. 1976 3rd Parkcenter Plaza Building Rising in Santa Ana. January 11, page 105. 1987 Obituary McGilvray, Donald Alexander, Jr. March 23, page 34. 1999 Obituary Gillman, Bob. October 17, page 450.
Marsh, Dianne
1994 Santa Ana, an Illustrated History. Heritage Publishing, Encinitas, California.
McBride, J.L.
1913 Plat Book of Orange County. H.S. Crocker and Company, Los Angeles, California.
Napa Weekly Journal
1912 Couldn’t Face Disgrace: Caught in Attempt to Smuggle in Jewels, Woman of a Wealthy Family Commits Suicide. March 22, page 1.
Oakland Tribune
1912 Confesses Evading Customs Duties. March 20, page 2.
Orange County Register
2022 Santa Ana Apologizes for 1906 Burning of its Chinatown. May 24. Accessed online in June 2022.
Pacific Bank
1888 Pacific Bank Handbook of California, page 13. Accessed online June 2, 2022 at: https:// www.google.com/books/edition/Pacific_Bank_Handbook_of_California/vCSR9VK8lJUC?hl =en&gbpv=1&dq=%22Hiram+Mabury%22&pg=PA13&printsec=frontcover.
Pacific Coast Architecture Database
2005–2022 City of Santa Ana, Santa Ana City Hall #3, Santa Ana, CA. Accessed online in June 2022 at: https://pcad.lib.washington.edu/building/14076/.
Parker, C.E. and Marilyn
1963 Orange County: Indians to Industry. First American Title Insurance and Trust Company, Santa Ana, California.
City Council 18 – 801 10/3/2023
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Petaluma Argus-Courier
1987 Reunion of former aircraft mechanics set this weekend. August 26, page 2.
Preserve Orange County
2018 Old Orange County Courthouse. Accessed online in June 2022 at: https://www. preserveorangecounty.org/places/2018/8/9/old-orange-countycourthouse#:~:text=The%20courthouse%2C%20which%20occupied%20an,inside%20thos e%20halls%20of%20justice.
Santa Ana Orange County Register
1939 Addition to Orange Acreage Shows Confidence In Future. April 20, page 13. 1977 There’s Building In Santa Ana. April 10, pages I-7 and 10.
Sapphos Environmental, Inc.
2011 Historic American Buildings Survey, 501 East Fifth St. (Whitson-Powelson House): HABS No. CA-2839. Accessed online May 28, 2022, at: https://tile.loc.gov/storageservices/master/pnp/habshaer/ca/ca3700/ca3766/data/ca3766data.pdf Swanner, Charles D.
1953 Santa Ana: A Narrative of Yesterday, 1870-1910. Saunders Press, Claremont, California.
Tibbet, Casey
2008 Cultural Resources Assessment: 601 and 611–613 East Santa Ana Boulevard, City of Santa Ana, Orange County, California.
2022 Due Diligence Study for Four Properties at the Northeast Corner of East 4th Street and North Cabrillo Park Drive in the City of Santa Ana, California.
Tustin News
1961 Local Tract Homes’ Fallout Shelters Set. August 24, page 5.
United States Geological Survey (USGS)
1981 Tustin, California 7.5-minute topographic quadrangle map.
City Council 18 – 802 10/3/2023
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APPENDIX A
DEPARTMENT OF PARKS AND RECREATION (DPR) 523 FORMS
City Council 18 – 803 10/3/2023
DPR 523A (1/95) *Required information
State of California The Resources Agency Primary #
DEPARTMENT OF PARKS AND RECREATION HRI #
PRIMARY RECORD Trinomial
NRHP Status Code 6Z
Other Listings
Review Code Reviewer Date