Santa Ana City Council
September 16, 2025

FY 2024-2025 (QUARTER 4) REPORT TO THE CITY OF SANTA ANA Contract Name: Homeless Management Information Systems (HMIS) Contract Term: July 1, 2024 - June 30, 2025
Reporting Period: Quarter 4: April 1, 2025 – June 30, 2025 Reporting Period Actual Served
Quarter 1: July 1st - September 30th 18
Quarter 2: October 1st - December 31st 64
Quarter 3: January 1st - March 31st 104
Quarter 4: April 1st - June 30th 85
Total 271
Quarterly Activities
Based on scope of services, the following was achieved during Q4 FY 24-25:
211OC performed the following activities to engage with 4 agencies in Santa Ana who are ESG sub-recipients and also HMIS participants (including Domestic Violence agencies), to increase the accuracy of data collected and disseminated:
• 2 ESG sub-recipients participated in the HMIS User meeting in April. • 2 ESG sub-recipients participated in the HMIS User meeting in May. • 3 ESG sub-recipients participated in the HMIS User meeting in June. • The following user accounts were active at each agency during the quarter:

Staff Access Role
Agency
Agency
Manager
Agency
Staff Total
Illumination Foundation 3 63 66
Interval House 0 0 0
Santa Ana Police Department 1 4 5
WISEPlace 2 5 5
Program accomplishments
Reports:
• Quarterly Data Quality Reports Cards were published on our website.

EXHIBIT 1
City Council 27 – 37 9/16/2025

• Project Performance Reports were published for Permanent Supportive Housing & Other Permanent Housing, Rapid Re-Housing and Transitional Housing
• Published the ESG Quarterly Dashboard
Provided additional guidance in the monthly User Meeting on the following topics:
• April: Provide on-going support with HIC PIT, CES Housing Assessment Forms Update, Client Consent Form Update, Reassign Case Manager, Program Move, Agency Set Up Review Dashboard, and LSA Data Quality Dashboards
• May: Provide on-going support with HIC PIT, Assign CES Case Manager, Pre-Assessment Screening Form Update, Adding Documents to a Client's Record, Bed Reservation Workflow, Maintaining Households on the Community Queue, CES Clients Active with Service Provider & on CES CQ Report, Proposed Data Standards Changes, and 2025 Agency Audits
• June: Provide on-going support with HIC PIT, System Performance Measures, HMIS Policies and Procedures Update, Clarity Feature Updates: Check In Button and Signature Field Type, 2025 Agency Audits, Data Entry for Social Security Number, Removing Household From Community Queue, Exiting Clients from a Program, Reopen a Program Enrollment, Potential Exits Report Support:
• Help users understand the different components of data quality • Continued 2024 HMIS Agency Audit: HMIS Training and Support, Client Privacy, Security Check, HMIS Data Quality
• Hosted Live Webinars: Looker Training, Deeper Dive into Looker Training, and HMIS Part 2 Live Training New program information
• No new projects were set-up in the past quarter.

Up-to-date program statistics on expenditures, caseload and activities • Please reference 211OC’s billing report for program expenditures and the above areas of the Q4 FY 24- 25 report for detailed description of activities.

EXHIBIT 1
City Council 27 – 38 9/16/2025
The Orange Countv Register
1920 Main St., Suite 225
Irvine, Ca 92614
714-796-7000
5211379

CNSB / CNSB-ACCOMMODATIONS
915 E 1ST ST

ORDER EXPEDITING
LOS ANGELES, CA 90012-4050
FILE NO. 3958469

AFFIDAVIT OF PUBLICATION
STATE OF CALIFORNIA, } ss.

County of Orange
I am a citizen of the United States and a resident of the County aforesaid; I am over the age of eighteen years, and not a party to or interested in the above entitled matter. I am the principal clerk of The Orange County Register, a newspaper of general circulation, published in the city of Santa Ana, County of Orange, and which newspaper has
been adjudged to be a newspaper of general circulation by the Superior Court of the County of Orange, State of
California, under the date of November 19, 1905, Case No.

A-21046, that the notice, of which the annexed is a true printed copy, has been published in each regular and
entire issue of said newspaper and not in any supplement thereof on the following dates, to wit:
08/18/2025
I certify (or declare) under the penalty of perjury under the laws of the State of California that the foregoing is true and correct:

Executed at Anaheim, Orange County, California, on
Date: August 18, 2025.
��
Signature
1 1111111 111 1111111111111111111111111 11111 11111 111111111 ll11111111 11111111 * A O O O O O 7 1 8 4 0 6 2 *
r,LP1w12/15/16

PROOF OF PUBLICATION
EXHIBIT 2
City Council 27 – 39 9/16/2025
r.lP1"12/15!16 2
All t.:vrmn-llrn_:::; nnt11n1c ru me
(APE; R sho�d<1 be sObmitte-<l l,;i the
City of .Santa Ano, Communl!'f
Devclwment Depar!mont no latar
thon 4:0() p,m., on September 16,
202 •.

Questions ond written commen1S
regon:ling. th" CAPER ,;ind Action
Pion Amcndmenfmoy beoddressed
to Mr. Do111d Flores, HQUsing
Pro1m1ms Coordlncrtor, 20 Civic
Center Plow, Sonia "ma, CA 92701
,ttlores0)Satlta-<ina.org. You trWi
ulso call (714) 647-6561.

ACCESSISILITY TO MEETINGS
AND OOCUME;NTS
It is th� inteotio� of the City to
<:omply · with S.e<:tion . 504 .. of tM
Rehabili1Cltion .,,er Of l9T.l, OS
omended,. the Americans. witll
Disabifiti,;s Ad (ADA) of 1990 and
I.he ADA .Am�ndment Ac tot '.!DOS, .the
Fair Housing Act, the. Archltecturol
Barr,ors.Act, at1d 1110Cit11's<1dbpted
Umited En-g:ii:Sh Proficienr:Y Pian
(LEP) In all respects. lfyou'.requice
public .documents in· ati occ.essibie
fOTfT1d,f1 ... '.the , . GHv •• �t�l.l ... , ,riiake
reasonable. efforts to accommc><Jate
V-OUf request. If, <IS d partiCiPdlil II1
thFs,-meetJn:�,- VOU- will :n'eeQ·:?PeCiol
<rss,stance beyc>ncl wlmt. is normally
prov_j'Q�dr .. :-
�fl�Judtri9 a�xtli:O�Y. • aid�
o�d ,ervi.ces, the City will uttemm lo
<1ccomm.o.dofe you • In every
reo.�ona1>1e ma.nner. Pleose co.ntoc1
ll4,M7'6520 ot'.le-o.st <IS h<:iurs �,,or to
fhc
. mt'liiting to fnform us . of• ·yetur
needs .• and ... to . det�rmine if
<rcc<,mrnodotlo� is. fe�si b.1 e.
tl>e CHY • doe.s nol Md shct I I not
dtsc.drrl.i_nate on ·_th
.
�_.bosi:s of n:ice�
,;;olor;. r-eli\Ji.on (creed), se�der,
'!iru1de.r:· • . . t-?C�t��sionr_ 090�--
_. nation_..11
<1rigrn !011c�frvl, di&c.bili!Yirt1<1rit□I ,sfo.tus, sexual Orient<:rtfon,_.n:,mtan• :Sl<JIUS,.Ocf'.Onl' <l)ner i,roJr>CWd Closs
$:latu�'._jq 'oov: Qf it:;i octlvitie� or
or>erations,
.Si tlt!necpl'e!llJ!lta$ en esP<tffQI,
f!JV,;>rde lldrnQr, al 714,667":l.241;
Nu cn!J(!n I c ting t!n1,Vrt, xin
l n thQ.i <;h<tKrtslle.H(I s. (714) 667,
. . . 2241. .
.
. . .
/l you chal/eng.e tt>e declslon. on the
a/xJvr; l1J!1f/f,r, i'iJI/ mar lie /imlfed lo
rc1",.fng iontr . ti/·c,se·: issvi,s :•rov or
someorre e/s'e raised. at 1/-/e r,utJ-lic
he'<,i'ilig .4�$ci'tbed iii .fh'iS notice, 6,: in'..wrll/errcorres.PO(lde.ncecfeliverea lo the City of Scn.taAna at or pr/or
.!(4
:
:fhi!·'fjdb!iC: ,h'eriring�·
J.emiHer L; Holl, CMC
CityClerlc ••
llllwi5 . : ...

CNSs39Sll.469#
ORAN(;E! C':O!JNTY REl'.llSTF.R
EXHIBIT 2
City Council 27 – 40 9/16/2025
California Newspaper Service Bureau
Public Notice Advertising Since 1934
Tel 1-800-788-7840 Fax 1-800-474-9444
Local Offices and Representatives in:

Los Angeles, Santa Ana, San Diego, Riverside/San Bernardino, San Francisco, Oakland, San Jose, Sacramento
Special Services Available in Phoenix

DECLARATION
I am a resident of Los Angeles County, over the age of
eighteen years and not a party to or interested in the
matter noticed.

The notice, of which the annexed is a printed copy
appeared in the:

LA OPINION
On the following dates:
08/18/2025
I certify (or declare) under penalty of perjury that the foregoing is true and correct.

Dated at Los Angeles, California, this
21st day of August 2025
Irene Andal
Signature
3958473
"The only Public Notice which is justifiable
from the standpoint of true economy and the public interest, is that which reaches those who are affected by it"
I llllll llll llll llll lllll lllll 1111111111 111111111111111111111 IIII IIII * A 0 0 0 0 0 7 1 8 3 2 7 8 *
' Tambien pued"e ·11amar a
\ ' estado milltar, o cualquier ' (714) 647-6561.

AC otro estatus de clase C ES I B I LI DAD protegida en cualquiera A AEUNIONES y de sus actividades y DOCUMENTOS operaciones. Es la intenci6n de la Si tiene preguntas Ciudad cump\ir con la en espailol, favor de :_ Secci6n 504 de la Ley de llamar al 714-667-2241. Rehabilitaci6n de 1973, N0u can nen li;ic b8ng segUn enmendada, la ueng ViE;?t, xin di�i:, thoi;ii : Ley de Estadourndenses cha Kristie Ha s6 (714) con Discapacidades 667-2241. (ADA, par sus siglas en Si impugna a decisi6n : ingles) de 1990 Y la Ley sabre el asunto anterior, de Enmienda de Ada de es posible que se le 2008, la Ley de Vivienda limite a plantear solo los Justa, la Ley de Barreras problemas que usted u Arquitect�nicas,.Y el Plan otra perso,na plantearon de Dominic Lim1tado del en la audiencia pUblica lngles,{LEP, por sus siglas descrita en ese aviso, en 1ng1es) adoptada O en correspondencia por la Ciudad en todos escrita O entregada a la las aspectos. Si usted Ciudad de Santa Ana en necesita documentos O antes de la audiencia pUblicos en un formate pUbl i
ca.
accesib\e, la Ciudad hara Jennifer L. Hall, CMC las esfuerzos razona_bles Secretaria de a Ciudad para adaptar s.u .sollc1tud. , 8/18/25 Si, coma part1c1pante en I CNS- esta reu_ni6n, necesita_ra 3958473# I LA OPINl6N asistenc1a especial mas all8. de lo que
normalmente se brinda,
incluyendo servicios
y ayudas auxiliares,
la Ciudad intentar8.
acomodar\o de todas
las maneras razonables.

Comunlquese al 714-
647-6520 al menos
48 horas antes de la
reuni6n para informarnos
de sus necesidades y :
determinar si es factible
la adaptaci6n. . . .

La Ciudad no d1scnm1na
rn discriminar8. par
motives de raza, : color, religi6n . (credo),
genera, exprest6n . de
genera edad, ongen nadon8.t (ascendencla),
discapacidad, estado
ci�il,
_
orientaci6n s�xu�I,
EXHIBIT 2
City Council 27 – 41 9/16/2025
California Newspaper Service Bureau
Public Notice Advertising Since 1934
Tel 1-800-788-7840 Fax 1-800-4 7 4-9444
Local Offices and Representatives in:

Los Angeles, Santa Ana, San Diego, Riverside/San Bernardino, San Francisco, Oakland, San Jose, Sacramento
Special Services Available in Phoenix

DECLARATION
I am a resident of Los Angeles County, over the age of
eighteen years and not a party to or interested in the
matter noticed.

The notice, of which the annexed is a printed copy
appeared in the:

NGUOI VIET
On the following dates:
08/19/2025
I certify (or declare) under penalty of perjury that the foregoing is true and correct.

Dated at Los Angeles, California, this
25th day of August 2025
lreneAndal
Signature
3958478
''The only Public Notice which is justifiable
from the standpoint of true economy and the public interest, is that which reaches those who are affected by it"
I lllllll llll lllll llll llll llll lllll lllll lllll lllll lllll 1111111111111 1111 * A O O O O O 7 1 8 7 O 6 3 *
THONG ftAO YE PH!EN �IEU
TRAN CONG C9NG
Cic Chuong Trinh Lip Ke Hoach
vi PhatTrifo Cong Dong'
cua Bi Gia Cuva PhitTriln Oo Thi
Hoo Kl
BAN Di/THAO BAO CAO OANH GIA
HltU SUATHANG NAM
01/0C HdP NHAT (CAPER) CHO NAM
• TAICHINH 2014-1025
Thong Bao Cong Cong: Ban du th!o
CAPER 2024-2025 da sin sing di xem
xetvi g
6py,
Thinh ph6 Santa Ana di chuan biBan
duthio Bio cio Hi\u suit vi Dini g
la
H/p nhlt HinJ nim !CAPER) 2024·
2025. Bao cao nay danh g1a tien dQ cUa
Th3nh phO trong vi�c d�t dt1qc cac m�c
tieu phit triln nhi o vi c9ng dong cho
nam tli chinh 1014-2015, nhu di neu
trong Ke Hoach Hanh D¢ng Mot Nim
di duQc thong qua. Chuong trinh nay
bao gom cic hoar d¢ng duoc tii trp
thong qua c tro phat
trlEn cOng , Doi ta'c dau
tu �O�E I tr9 g iii phip
khancaylESG),
Theo Ke hoach tham gia cUa cOng dan
Thinh ph6 va Cole quy dinh cUa lien
bang 114 CFR 91.105\ CAPER co thedugc
cOng chting xem xet va binh luan trong
thai gian 15 ngiy, t� ngiy 5 thing 9
Mn ngiy 19 thing 9 nim2025,
Ban co the xem xet Ban thao CAPER t_r/c
tiep tai: Santa Ana City Hall, 10 Civic
Center Plaza, 8th floor
Santa Ana, CA 91701
ChtinQ t6i tran trgng kfnh m011a1 ca ell
din va cic ben lien quan dong gop i
kien trnng thoi gian dinh gia nay.

Ngoa, ra, Du thao CAPER se duQc trinh
bay tai cic 'phien Dieu Iran Cong khai
sau day
, Sulc hQp Uy ban Phit triln Cqng
dong
Thu Tu, ngay 17 thing 8 nam 1015, luc
4:30 chieu
, Cujc hQp Hqi dong Thanh pho
Thu Ba, ngay 16 thang 9 nam 1025, luc
6:00 t6i [T10ng phan Phien dieutran
cong khai cua chuong trinh nghi sil)
1 �ien d6n� g6p cila bqn r&t quan tr9ng
d61 v\J
i
chung tOi, Vui lbng nhan co hOi
nay d€ xem l�i bao cao va chia sf Y ki�n
cUa ban.

BINH PHAM C0A CONG CHONG
Cac ban sao cua ban duthao mar nhat
cua CAPER se c6 sin de cong chung xem
xet tai lfa diem sau:
https:/ iwww.sa nta-a na. org/hou sing1 grant-funding/ C6ng chUng duqc mOi gu'1
nh�n xe1
bing van ban vi CAPER. fat cl cicnhJn
xet lien quan den CAPER phai dugc g�
den Thanh pho Santa Ana, Phong Phat
trien Cong dong (City of Santa Ana,
Community Development llepartment)
khong muon hdn 4:00 chieu, ngay 16
Thang Chin, 2014.
cac cau h6i va nhan xet bang van ban
lien quan den CAPER vi B!n sila d6i
Ke hoach Hanh dong co the dude gui
tOi Ong David FlOres, Dieu phOl viEn
Chuong trinh Nhi !, 10 Civic Center
Plaza Santa Ana, CA 91701 dllores@
santa-ana,org. QuY vi cUng c6 the g9i
[714)647-6561.

KHA NANG Tl!P CAN cAc CUD( HOP
VWILl(U • • •
Thanh pho co i dinh tuan thu Mic 504
cua Dao Luat Phuc H6i nam 1973, di
duac sila d5i, Dio lu!t Nguoi Khuyit
Tat Hoa Ky [ADA) nam 1990 va Dao Lu!t
Sua Ooi ADA nam 1008, Dao Lu!t Nh, b
Kien TrUc,
Anh Han Ch€ moi ma!.

Nfu quYvi yeu c3u cac tai li�u c6ng c(ing
o dinh dang c6 the truy cip dug, Thanh
ph6 se c6 nhung no Ive hdp Ii de thich
nghi cho yeu cau cua quy vi. Neu, vai tu
each la thanh vien tham dv cuoc hop
nay, quy v! se can hO trq d�c bi�t ngoai
nhung g
i thong thuong duqc cung cap,
bao g6m cac dich v� va trq c� ph� trq,
Thanh phose c6g!ng thich nghi cha qui
vj theo mo, cich thuc hqp i, Vui long
lien h/ so 714-647-6510 t nhat 48 gio
trudc cu¢c h9p de thong bao cha chung
t0iv€nhu cau cUa quyvf va xac dinh xem
s/thich n
9 hi c6 kha thi hay khong.

Thanh pho khong vase khong phan bi/t
d6i �/J dVa tren chUng tOc. mau da, 16n
giao [ti
n ngudngl, gidi t
i
n� bieu li/n
giO
i
t
l
nh, tuOi 13r, ngu6n g6r qu6c gia
[to tien), khuyet tat, tinh trang hon nhan,
' khuynh huon9 tinhdic, tinh trang quan
nhin, ooic bat kj tang lq, dude bao vi
nao khac t10ng oat ky hoat d¢ng ho!c
v�n hanh nao ctia n6.

Cic cu9c h9p cua H9i d6ng Thanh pho
duoc truyin hinh tren Kenh l hole phat
Si tiene preguntas en espaftol, favor
de Ila mar al [714) �67-2241.

Neu can lien lac bing tieng Vi\\
xin cfren thoai cho Kristie Ha (714)
true ti�p t�i www.santa-ana,oig.' cac
th�nh v1en cl/a c<ing ch\Jng cO the gui
nMfl xet qu3 email t�i ecomments@
santa-ana.orgvao 4 giCI chi€u ngay h9p,
tham gia h¢i ngh! tU xa bang each g9i
so 669-900-9128 [ID: 315-965-149), hoac
bing cich tham gia h¢i thio tren web
qua zoom tqi https:/fus02web.zoom
uslj/315965149.

Vui lo"] truy �P santa-anao�/ci�­
meetings flf bift them thOng tin, Thanh
phO Santa Ana cam an ct1 dan v
i sv kfn
nhan va linh hoqt lien t�c cUa h9 khi
chUng tOi tiep we quan blnh giaa slfan
toanva svtham gia ctia c6ng cMng.
• 667,2241.

Niu thach tMc quy/1 a/nh vi van di trio,
quy v/ c6 rhe chi duqc neu ra nhrJng vOn
de m� qtJY. vihoac n9t/Cli khdc d6 neu ra
tqi ph1en 1Mu trOn cong cQng d!l�c mD td
1rong th6n9 bdo nay, hodc lrong thug,,
a/n H9i Do119 Thanh Ph6 cuo Thanh PM
Santa Ana vao Ilic, hoqc wac phifn dri.u
tranc6ng khai.

Jennifer L. Hall,CMC
Thu Ky Thanh Pho
B/19/15
CNS-3958478#

NGUOIVIET
EXHIBIT 2
City Council 27 – 42 9/16/2025
Planning and Building Agency
www.santa-ana.org/pb
Item # 28
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
September 16, 2025
TOPIC: The Village Santa Ana Specific Plan Entitlements and Development Agreement (1561 W. Sunflower Avenue)

AGENDA TITLE
Public Hearing - Amendment Application (Zone Change) No. 2025-01, Vesting Tentative Tract Map No. 2025-06, Development Agreement No. 2025-01, and Overrule of the Orange County Airport Land Use Commission’s Determination of Inconsistency for The Village Santa Ana Specific Plan Entitlements and Development Agreement (1561 W.

Sunflower Avenue)
Legal notice published in the OC Reporter on September 5, 2025 and notices mailed on same date.

RECOMMENDED ACTIONS

1. Adopt a resolution: (1) certifying the Final Supplemental Environmental Impact Report No. 2025-01 (SCH No. 2020029087) for the Project; (2) adopting Environmental Findings of Fact and a Statement of Overriding Considerations for the Project; (3) adopting a Mitigation Monitoring and Reporting Program for the Project; and (4) approving the Project;
RESOLUTION NO. 2025-XXX entitled A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA ANA: (1) CERTIFYING THE FINAL SUPPLEMENTAL

ENVIRONMENTAL IMPACT REPORT FOR THE VILLAGE SANTA ANA
SPECIFIC PLAN PROJECT (SCH NO. 2020029087); (2) ADOPTING

ENVIRONMENTAL FINDINGS OF FACT AND A STATEMENT OF OVERRIDING

CONSIDERATIONS FOR THE PROJECT PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT; AND (3) ADOPTING THE MITIGATION

MONITORING AND REPORTING PROGRAM

2. Adopt a resolution approving Vesting Tentative Tract Map No. 2025-06 (County Map No. 2023-159), as conditioned;
RESOLUTION NO. 2025-XXX entitled A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF SANTA ANA APPROVING VESTING TENTATIVE TRACT MAP NO. 2025-06 (COUNTY MAP NO. 2023-159), AS CONDITIONED, FOR THE City Council 28 – 1 9/16/2025
The Village Santa Ana Specific Plan Entitlements and Development Agreement (1561 W.

Sunflower Avenue)
September 16, 2025

VILLAGE SANTA ANA SPECIFIC PLAN PROJECT GENERALLY LOCATED AT 1561 W. SUNFLOWER AVENUE

3. Adopt a resolution overruling the Orange County Airport Land Use Commission’s determination that The Village Santa Ana Specific Plan is inconsistent with the Airport Environs Land Use Plan of John Wayne Airport, including supportive findings (requires two-thirds vote);
RESOLUTION NO. 2025-XXX entitled A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF SANTA ANA OVERRULING THE ORANGE COUNTY
AIRPORT LAND USE COMMISSION’S DETERMINATION THAT THE VILLAGE SANTA ANA SPECIFIC PLAN PROJECT GENERALLY LOCATED AT 1561 W.

SUNFLOWER AVENUE, IS INCONSISTENT WITH THE AIRPORT ENVIRONS

LAND USE PLAN FOR JOHN WAYNE AIRPORT, INCLUDING SUPPORTIVE

FINDINGS

4. Conduct a first reading and adopt an ordinance approving Amendment Application No. 2025-01 establishing The Village Santa Ana Specific Plan (Specific Plan No. 6) and approving a zone change for the Project Site at 1561 W. Sunflower Avenue from Specific Development No. 48 to Specific Plan No. 6; and ORDINANCE NO. NS-XXXX entitled AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SANTA ANA APPROVING AMENDMENT APPLICATION NO. 2025-01 TO ESTABLISH THE VILLAGE SANTA ANA SPECIFIC PLAN AND TO

APPROVE A ZONE CHANGE FOR THE PROJECT SITE GENERALLY
LOCATED AT 1561 W. SUNFLOWER AVENUE, FROM SPECIFIC
DEVELOPMENT NO. 48 TO THE VILLAGE SANTA ANA SPECIFIC PLAN (SP-6)

5. Conduct a first reading and adopt an uncodified ordinance approving Development Agreement No. 2025-01.

ORDINANCE NO. NS-XXXX entitled AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SANTA ANA APPROVING DEVELOPMENT AGREEMENT NO. 2025-01 FOR THE VILLAGE SANTA ANA SPECIFIC PLAN PROJECT GENERALLY LOCATED AT 1561 W. SUNFLOWER AVENUE, BETWEEN THE

CITY OF SANTA ANA AND SOUTH COAST PLAZA, A CALIFORNIA GENERAL

PARTNERSHIP
GOVERNMENT CODE §84308 APPLIES: Yes
Executive Summary
Justin McCusker, on behalf of South Coast Plaza, a California general partnership (“Applicant” and “Property Owner”), is seeking approval of various entitlements to facilitate the redevelopment of a 17.2-acre site into a mixed-use urban village (“Project”).

City Council 28 – 2 9/16/2025
The Village Santa Ana Specific Plan Entitlements and Development Agreement (1561 W.

Sunflower Avenue)
September 16, 2025

The project site is located along the southern edge of the City of Santa Ana (“City”), on the northeast corner of West Sunflower Avenue and South Bear Street, transected by South Plaza Drive. The project site includes 11 addresses (1561, 1611, 1621, 1631, 1641, and 1661 W. Sunflower Avenue; 3820, 3840, and 3951 S. Plaza Drive; and 3811 and 3851 S. Bear Street) and seven parcels (412-131-10, 412-131-20, 412-131-21, 412-451- 01, 412-451-02, 412-451-03, and 412-451-04), collectively referred to as 1561 W.

Sunflower Avenue (“Project Site”).

Project entitlements include Amendment Application (AA) No. 2025-01 to establish the Village Santa Ana Specific Plan (SP-6) and to change the zoning district of the Project Site from Specific Development No. 48 (SD-48) to SP-6; Vesting Tentative Tract Map (VTTM) No. 2025-06 (County Map No. 2023-159) to subdivide the Project Site into six buildable lots; and Development Agreement (DA) No. 2025-01 outlining terms and conditions for the Project. In addition, in accordance with the California Environmental Quality Act (CEQA) the Project requires: (1) certification of a Final Supplemental Environmental Impact Report (SEIR) No. 2025-01 (SCH No. 2020029087); (2) adoption of Environmental Findings of Fact and a Statement of Overriding Consideration; and (3) adoption of a Mitigation Monitoring and Reporting Program (MMRP). Lastly, the Project requires overruling the Orange County Airport Land Use Commission’s (ALUC) determination that the Project is inconsistent with the Airport Environs Land Use Plan (AELUP) of John Wayne Airport (JWA), including supportive findings.

Pursuant to sections 41-592 and 41-667 of the Santa Ana Municipal Code (SAMC), approval of a specific plan and a zone change is required by the City Council by ordinance. In accordance with Section 65864 et seq. of the California Government Code (Gov. Code), the City Council is authorized to enter into binding development agreements with persons having legal or equitable interests in real property for the development of such property. In accordance with Section 21676 of the Public Utilities Code (PUC), the City Council may overrule ALUC’s determination by a two-thirds vote if it makes specific findings that the Project is consistent with the purposes of the State Aeronautics Act.

Lastly, pursuant to Section 34-127 of the SAMC, the Planning Commission is authorized to review and approve tentative tract maps; however, since the Project requires review of other entitlements by the City Council, the City Council is required to act on this matter as well.

Staff is recommending approval of the Applicant’s request because the Project is consistent with the General Plan land use designation for the Project Site, implements the goals and vision of the South Bristol Street Focus Area (SBSFA) of the General Plan, and provides for a high-quality mixed-use urban village that will contribute community benefits and new economic development opportunities for the City.

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Planning Commission Recommendation
The Planning Commission held a public hearing for the Project on August 11, 2025. As part of its deliberation, the Planning Commission deliberated the topics summarized in Table 1 for the applicant to address but ultimately voted unanimously (7-0) to recommend that the City Council approve the requested entitlements and development agreement as drafted. Where provided, the Applicant’s responses are summarized in the table below.

Table 1: Planning Commission Topics for Applicant Consideration Topic Summary Applicant Response
Native Lands
Acknowledgement
Formally recognize the Indigenous
peoples of the site’s history through an
onsite marker or designated space.

As applications for specific projects are
submitted for review, opportunities to
honor the Indigenous peoples with
ancestral ties will be explored.

Project Interface
with Bear Street
Frontages facing Bear Street should
include enhanced architecture and
pedestrian-oriented elements to create
an active and functional building and
public realm interface.

The proposed specific plan is a higherlevel planning document with design concepts, including architectural and
landscape elements, that will be
implemented through individual projects
submitted to the City.

Hotel Use
Permissibility
Consider requiring a conditional use
permit (CUP) for hotels in the specific
plan area.

The Public Hearing portion of the
meeting had closed when this topic was
discussed; the Planning Commission
did not vote to reopen the Public Hearing
to provide an opportunity for response.

The City received 17 public comments on the Project that were submitted online. The majority of the comments were in support of the Project. The City prepared written responses for each comment received prior to the 3:30 p.m. deadline; the responses were uploaded to the record and printed for the public hearing prior to the 5:30 p.m. meeting.

Those responses are attached to this report as Exhibit 11. During the public hearing, a total of six individuals provided comments on the Project; four were in support and two were in opposition of the Project.

DISCUSSION
The Project proposes to redevelop the Project Site with a mixed-use urban village on six parcels. The Project would permit up to 1,583 residential units (encompassing approximately 1,850,000 square feet of building space) with a projected population of 3,659 individuals (at a 95.9 percent occupancy rate), 80,000 square feet of commercial space, 300,000 square feet of office space, and 13.8 acres of public and private outdoor and recreation space (of which 7.5 acres will be publicly accessible open space). These uses would occupy mixed-use, residential, and commercial buildings varying in height from one to 25 stories. The Project’s focal point is a central commercial area that would City Council 28 – 4 9/16/2025
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include a variety of commercial uses, such as restaurants, a market, and retail uses, with additional commercial uses extending through the ground floor of adjacent residential buildings creating an urban village design.

Table 2: Project Location Information and Applicable Code Sections Item Information
Project Address and Council Ward 1561 W. Sunflower Avenue – Ward 4 Nearest Intersections West Sunflower Avenue and South Bear Street, transected by South Plaza Drive
Existing General Plan District Center – High (DC-5)
Existing Zoning Designation Specific Development No. 48 (SD-48) Proposed Zoning Designation Specific Plan No. 6 (SP-6)
North Multi-family communities of Versailles on
the Lake and Saint Albans
East Commercial Center / Related Bristol
Specific Plan (SP-5)
West Village Creek condominium community in
the City of Costa Mesa
Surrounding Land Use
South South Coast Plaza in the City of Costa
Mesa
Property Size 17.2 acres
Existing Site Development
The Project Site is currently developed with the South Coast Plaza Village commercial center, which consists of
approximately 164,049 square feet of retail shops,
restaurants, offices, and a cinema building. Other
improvements include surface parking and landscaping.

Use Permissions Mixed-use urban villages permissible by the DC-5 General Plan land use designation.

Development
Standards
Appendix A, Table LU-A-1 (Interim
Development Standards) of the General
Plan Land Use Element. Municipal Code Section Sections
Affected
Entitlements Sections 34-12, 41-592, and 41-667 of
the SAMC.

Should the Project be approved, construction of the Project would be implemented in five phases to account for market conditions and to ensure that access, public facilities, and infrastructure connections are appropriately installed to serve the Project. These phases may overlap and completion of the Project may take up to 20 years, depending on market factors. As the requested entitlements would establish a specific plan, individual Project phases would be reviewed through the administrative Development Project Review process, similar to what takes place in other master-planned areas of the City, such as the MainPlace Mall and Harbor Mixed Use Transit Corridor specific plans, and as approved for the Related Bristol Specific Plan (SP-5). If individual phases do not satisfy the development standards and design review requirements of the City, they would be remanded to the Planning Commission for review.

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Table 3: Project Breakdown and Phasing Plan
Phase Phase 1 Phase 2 Phase 3 Phase 4 Phase 5 Total
Residential
(Units) 360 513 177 264 269 1,583
Commercial
(Square feet) 73,175 --- --- 6,825 --- 80,000
Office
(Square feet) --- --- --- 300,000 --- 300,000
Parking
(Number of Stalls) 797 719 248 1,298 377 3,439
Publicly
Accessible Open
Space
(Acres)

3.1 2.3 0.4 1.2 0.5 7.5
Proposed Circulation and Mobility
The Project would provide a pedestrian network allowing residents, visitors, and other users to circulate from one space to another throughout the Project Site, with connections to the SP-5 area as well. The Project would be designed with three tiers of pathways: (1) sidewalks, (2) pedestrian paths, and (3) a fitness loop. Sidewalks would provide access to and from the Project Site, and would allow residents and visitors to walk to nearby destinations, such as South Coast Plaza. Sidewalks would be parallel to the existing public roadways and will range in width from five to eight feet. Pedestrian paths would form the core of the pedestrian network for the Project. All pedestrian paths would lead to the central commercial area. The proposed fitness loop would be a unique Project feature providing both a recreational amenity to residents and a functional component of the pedestrian network. The fitness loop would consist of an outer loop around the perimeter of the Project Site and an inner loop connecting to proposed gardens, open space, and retail areas within the Project Site, enabling runners, pedestrians, and other users to reach every corner of the Project Site.

The Project also proposes a network of bikeways that would enable residents and other users to travel to and from the Project Site via bicycle. The bicycle network has been designed in accordance with the planned bikeways identified in the Mobility Element (ME) of the General Plan, and would include a new Class IV cycle track along West Sunflower Avenue and a new Class I bike path along South Bear Street. The Project would also include amenities throughout the Project Site for users to park their bicycles.

The proposed circulation network would consist of existing public roadways and a new internal network of private streets and drives that would offer access throughout the Project Site. Vehicular access to the Project Site would continue to be provided from three existing public roadways: (1) Sunflower Avenue, (2) Plaza Drive, and (3) Bear Street. The City Council 28 – 6 9/16/2025
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Project would improve Sunflower Avenue with a new Class IV cycle track, landscape buffers, and enhanced sidewalks. Improvements to Plaza Drive would include a road expansion from 64 to 80 feet to accommodate proposed loading zones, center medians, sidewalks, and landscape buffers. In addition, two new traffic signals would be installed along Plaza Drive. Improvements to Bear Street would include upgraded bicycle facilities and a new traffic signal. To address community input during the outreach process, the Project would also include a new traffic signal at the intersection of Bear Street and Wakeham Place.

The Project would include a new internal network of private roadways to support mobility throughout the Project Site. Private roadways fall under three roadway categories: (1) private drives, (2) private streets, and (3) driveways. Private drives would support the internal circulation of people and goods for the Project Site. Private streets would provide the same functions as the proposed private drives but would also provide public entitles, such as the City and utilities companies, access to the Project Site for utility purposes.

Proposed driveways would provide residents and businesses access to specific building areas. Private drives and streets would be designed with one travel lane in each direction, with planting and pedestrian paths on both sides. The private drives and streets would also provide access to emergency vehicles for fire, ambulance, and police services.

Multiple loading zones are proposed to accommodate passengers and goods. These include designated passenger loading zones that would create safe and comfortable entries for passengers that are dropped off or picked up via ridesharing or other modes.

The designated passenger loading zones would be designed to prevent queuing in vehicular travel lanes. The Project would also include commercial loading zones to separate the movement of goods from the movement of people and to support businesses throughout the Project Site.

The Project would provide parking to accommodate residents and visitors that drive to and from the Project by a combination of underground parking, above-ground structure parking, and on-street parking. Above- or below-ground structured parking would be provided for each residential, mixed-use, or office building. Underground and on-street parking would be provided adjacent to the proposed Village Plaza area, which would include retail, food and beverage, among other uses. A portion of these parking spaces would be designated and equipped with charging receptacles for electric vehicles for residential and nonresidential uses in accordance with the California Green Building Standards Code (CALGreen). Table 4 provides a breakdown of the proposed vehicular and bicycle parking ratios being proposed by the Project.

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Table 4: Proposed Vehicular and Bicycle Parking Ratios
Use Ratio
Vehicular Parking
Office 3 parking spaces per 1,000 square feet
Residential 1.4 parking spaces per unit (1)
Commercial 4 parking spaces per 1,000 square feet
Bicycle Parking
Residential Minimum of 10 bicycle parking spaces per multi-family building Commercial 5 percent of the required vehicular parking
Notes:
(1) With Parking Management Plan strategies such as valet services, the Project can accommodate, if needed, a parking ratio of 2 parking spaces per unit.

Proposed Open Space and Landscape Concept
The Project proposes open space and an immersive landscaping concept as essential components of placemaking for the Project. At full buildout, the Project would provide a combined 13.8 acres of public and private outdoor and recreation space. Approximately

7.5 acres would be publicly accessible open space and 6.3 acres would be private outdoor and amenity spaces for the residents.

Public open spaces would consist of active spaces, outdoor seating areas, garden paseos, recreational lawns, and the fitness loop. Private open space amenities would include outdoor balconies and patios, pools and spas, outdoor kitchens, and communal gathering spaces. The Project would provide unique areas of active and passive open space. Active areas would include walkways, programmable roadways, a promenade, garden paseos, and the fitness loop, which would provide pedestrian and exercise opportunities and connections to the proposed amenities and retail areas in the Project.

Passive open spaces would include recreation-ready spaces such as pocket parks, a dog park, and gathering areas including a promenade suitable for outdoor programming, such as outdoor yoga, fitness classes, outdoor movie nights, and other gathering activities. In addition, the Project would be designed with private open space amenities throughout the buildings. These spaces would provide residents with communal gathering spaces and intimate gardens; opportunities for recreation; and amenity facilities including pools and spas, outdoor kitchens, and socializing areas. Additionally, the residential areas would include other private open space areas such as private balconies and patios. The Project would also include a number of planting zones with a variety of native and drought-tolerant trees, plants, shrubs, and ground covers to create an immersive garden experience. The planting zones would complement the architecture of the Project to create a unique sense of place and foster community gathering.

Infrastructure, Utility, and Other Improvements
The Project would construct new private water mains and private fire hydrants within the Project Site to service each proposed structure for domestic and fire water purposes. The City Council 28 – 8 9/16/2025
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Project would include the construction of an onsite private sewer network that would convey all sewer flows generated west of Plaza Drive to discharge to an existing Orange County Sanitation District (OC San) trunk sewer main located along Sunflower Avenue.

Sewer flows generated east of Plaza Drive would connect to an existing OC San sewer main along Plaza Drive as well as an existing City owned sewer main along Sunflower Avenue to utilize available existing capacities in the system. The proposed Project grading and storm drain network would be designed to match existing drainage and flow patterns to best utilize the capacities available in the existing public storm drain system.

Development of the Project would include the construction of new public water mains, fire hydrants, and meters. New domestic, irrigation, and fire water service connections for each proposed structure would be made directly to the existing and proposed public water mains.

While the Project Site has been fully developed with the current uses, the proposed Project entails a greater intensity of uses compared with existing operations, and would therefore require a greater demand on utility systems and public services. Utility connections and extensions, distribution lines, and collection lines would be extended and/or upgraded, as needed, from existing infrastructure locations and would be analyzed during each phase of the Project.

Site and Project Background
Site History
Through the 1960s, uses in the Project vicinity remained mostly for agricultural uses. The first major retail development in this rural setting occurred in 1967, when former lima bean producers C.J. Segerstrom and Sons (“Segerstrom Family”) constructed the South Coast Plaza mall on land just south of the Project Site. In 1973, the Segerstrom Family built the South Coast Village, current Project Site development, providing an open-air pedestrian center in the area. The Segerstrom Family still owns the Project Site and has maintained a long-standing presence in the City and County of Orange since the 1890s.

General Plan Update (2022)
In April 2022, the City Council adopted the General Plan Update (GPU) that established a long-term vision for the City. The GPU Land Use Element (LU) designates the Project Site as DC-5 within the SBSFA. Development in the DC-5 designation is intended to provide urban retail, residential, mixed-use, and employment centers with an intensity of up to 5.0 floor area ratio (FAR) and 125 dwelling units per acre (du/acre). Mixed-use projects may be vertical or horizontal with a maximum height of 25 stories.

The SBSFA serves as a prominent southern gateway to Santa Ana. The DC-5 designation envisions transforming traditional auto-oriented shopping plazas into vibrant, City Council 28 – 9 9/16/2025
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urban villages that prioritize pedestrian, bike, and transit mobility. The SBSFA envisions a built environment that includes:
1) New development that establishes vibrant public outdoor space appropriately scaled to the size and type of project;
2) Building designs that are dynamic and strong, creating a distinct impression; and 3) Office and mixed-use spaces of similar scale to those south of Sunflower Avenue.

Project Background
On August 7, 2023, the Applicant submitted the Project to the City for review by the Development Review Committee (DRC). Since the initial submittal, the Applicant has held numerous community meetings and has revised the Project to incorporate feedback received from the community and comments provided by the DRC. Over the last year, the Applicant worked with staff to finalize technical reports, including the final SEIR.

PROJECT ANALYSIS
Specific Plan No. 6
Pursuant to Section 41-592 of the SAMC, the approval and establishment of a specific plan requires approval of an ordinance by the City Council, with the Planning Commission serving as an advisory body. Furthermore, Government Code Section 65451 requires that a specific plan include text and diagrams that specify:
1) The distribution, location, and extent of the uses of land, including open space, in the area covered by the specific plan;
2) The proposed distribution, location, and extent and intensity of major components of public and private transportation, sewage, water, drainage, solid waste disposal, energy, and other essential facilities proposed within the area covered by the specific plan and needed to support land uses described in the specific plan; 3) Standards and criteria by which development will proceed, and standards for the conservation, development, and utilization of natural resources, where applicable; and
4) A program of implementation measures, including regulations, programs, infrastructure projects, and financing measures necessary to execute the specific plan.

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The specific plan tool has been identified as the appropriate zoning tool for the Project in order to implement the vision of the SBSFA of the GPU. The proposed SP-6 for the Project contains the required components listed above (attached hereto as Exhibit 7). SP6 includes the following six chapters:
1) Introduction. Provides an overview of SP-6, including the Project setting and background; purpose; authority; and relationship to other relevant plans, programs, and regulations;
2) Vision and Guiding Principles. Describes the vision and guiding principles for the Project, along with key features of the urban design and placement elements of the Project;
3) Development Plan. Establishes the land use plan, buildout summary, and permitted uses for the Project Site. It also describes the open space and landscape concepts; pedestrian, bike, and vehicular circulation; and infrastructure such as water, sewer, and storm drain;
4) Development Regulation. Provides permitted uses and development standards.

Standards include building form, setbacks, building orientation, and open space requirements. It also includes maximum density and intensity for development, parking standards, and signage regulations;
5) Design Guidelines. Complementary to Chapter 4, Chapter 5 contains guidelines related to the design of the Project Site and buildings and information about architectural materials and landscape inspiration, including a list of recommended trees, plants, shrubs, and ground cover; and
6) Administration and Implementation. Establishes the responsibility, enforcement, and interpretation of the plan. It also includes processes for the review of phase developments and modifications and amendments to the plan. This chapter also covers financing for the Project.

In addition to these chapters, SP-6 also contains supporting appendices that include governing definitions, summary of general plan consistency, economic and fiscal impact analysis, traffic circulation analysis, parking management plan, and regulations pertaining to alcohol sales.

SP-6 is consistent with and was guided by the goals and policies of the GPU.

Furthermore, the applicant is proposing a site plan, mix of uses, architectural design and landscape concepts, and development regulations in the SP-6 that were informed and guided by the following seven principles:

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1) A Village Community. The Village Santa Ana will offer a unique setting for shopping, dining, and accessing daily services. Unlike traditional commercial centers dominated by surface parking, this neighborhood village will be the hub of activity, designed within a parklike setting that creates an intimate and relaxing environment.
2) Warm, Timeless, and Iconic Architectural Design. Through high-quality humanscale design elements, selection of warm materials, four-sided architecture, and places for terrace gardens and green walls, the design of the buildings will work holistically with the landscaping and parklike village atmosphere. 3) Diversity of Outdoor Spaces and Activities at Multiple Levels. People who visit or live at The Village will find a multitude of unique outdoor spaces for strolling, reading, dining, meeting friends, exercising, and playing. The retail village common areas may be programmed for recurring activities such as movie nights, seasonal events, exercise options such as outdoor yoga, family nights, and other opportunities for nearby residents. Ground level residential amenities in the buildings surrounding the retail village will open to the village square and have amenitized open space as their front yard. Rooftops, terraces, and balconies will overlook the activities at the ground level and offer an array of amenities for residents.
4) An Extension of the Arts. There is an array of indoor and outdoor art installations on Segerstrom properties and others in the area that can virtually or physically become part of an art walk (such as Noguchi’s California Scenario, Serra’s Connector, and Perry’s The Ram). The Village Santa Ana will be an extension of the art walk, showcasing art works in the form of landscaping, stand-alone art pieces, and local artisan retail. Distinctive architecture and high-quality materials will contribute to the character of The Village Santa Ana. 5) Activated Streets. Contrasted with the existing site layout, new residential and commercial buildings will orient toward the streets and retail village and provide easy access for pedestrians. The streetscape and building setbacks along Sunflower Avenue, Plaza Drive, and Bear Street, and internal Project roads will be designed with a cohesive palette of drought-tolerant plants with unique characteristics, brightly colored flowers, and a mix of succulents and trees. 6) Sustainable Foundation. Planning, design, and development of The Village Santa Ana is rooted in sustainability. Like prior generations, this new development will aim to protect and care for the land. Best practices for reduced energy and water consumption, sustainably sourced materials, and integration of pervious surfaces along with thoughtful plant selection will support on-site water retention for this green village community. All of these features and more will ensure a lasting, sustainable development for generations to come.

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7) Balance of Land Uses. The Village Santa Ana will contain a broad mix of land uses serving regional, community, and local needs. This includes a mix of retail, restaurant, and entertainment uses that complement South Coast Plaza and contribute to the local Santa Ana economy. The Village Santa Ana will also help meet the significant demand for additional housing in the community.

Table 5 provides an analysis of SP-6 that warrants staff’s recommendation of approval of the requested action.

Table 5: Key Issues Analysis
Key Issue Analysis
Scale and Compatibility SP-6 is intended to produce a dynamic, mixed-use village that is integrated into and respects the surrounding community. The GPU land use designation of DC-5 for the Project Site allows developments up to 25 stories tall. SP-6 limits building heights to 25 stories and buildings adjacent to the northern property line will be limited to 8 stories, which is consistent with the GPU. Furthermore, through the City’s DRC process for each phase and design guidelines contained in SP-6, new buildings will be reviewed and designed to be compatible with the existing surrounding uses by including upper story step-backs and other features to reduce upper story massing.

Density and Intensity The DC-5 designation of the GPU allows a density of up to 125 du/acre and a maximum FAR of 5.0. SP-6 is consistent with the density and intensity of the GPU. The Project, as designed, is proposing a density of 93 du/acre and a FAR of 3.0, below what is permissible by the GPU. Typical residential densities of existing multiple-family communities in the area range from 16 to 25 du/acre; however, SP-6 includes a variety of development standards, design guidelines, and amenities designed not only to reduce the impact of higher-density residential development, but to also enhance existing community-wide amenities for existing residences surrounding the Project Site. The Project’s density and FAR is comparable with the density of 91 du/acre and FAR of 2.7 approved for SP-5.

The Project will feature 7.5 acres of publicly accessible open space, which will be accessible to all Santa Ana residents and programmed with functions to provide active and passive recreation. The Project also includes private residential open space and amenity space that will ensure a livable environment for residents.

Onsite Parking The Project will provide approximately 3,439 parking stalls and the parking ratios are consistent with newer developments recently constructed and with the parking ratios approved for the adjacent SP-5. Parking would be provided through a combination of underground parking, above-ground structure parking, and on-street parking. Above- or below-ground structured parking would be provided for each residential, mixed-use, or office building.

Underground and on-street parking would be provided adjacent to the proposed village plaza area, which would include retail, food and beverage, among other uses. A portion of these parking spaces would be designated and equipped with charging receptacles for electric vehicles for residential and nonresidential uses in accordance with CALGreen.

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Key Issue Analysis
A Parking Management Plan (PMP), attached hereto as Appendix E of Exhibit 7, was prepared for the Project to ensure adequate parking is being provided and managed properly for all residents, tenants, employees, and guests. The PMP identifies how parking stalls will be assigned, how gates will be managed, and how access (keycard, access codes) for residents, guests, employees, and the public will be provided. Based on the provided PMP, sufficient parking will be provided to satisfy the parking demand for residents, guests, patrons, and employees of the Project. Nevertheless, a condition of approval requiring the Applicant to implement and enforce the appropriate parking management strategies recommended in the PMP has been included.

Affordable Housing and
Opportunity Creation
Ordinance (AHOCO)
The City’s inclusionary housing ordinance, known as AHOCO, generally applies to housing projects proposing five or more units that are also requesting an increase in allowable density or are located in certain sections of the City that were “up-zoned,” such as through zone change or general plan amendment to allow additional residential development after November 28, 2011. As the Project is located in a section of the City that meets this threshold (SBSFA), the Applicant’s request is subject to the AHOCO requirements of production of affordable housing or payment of inlieu fees. Pursuant to Sections 41-1903 (Exempt Projects) and 41-1904 (Options to Satisfy Inclusionary Requirements) of the SAMC, the Applicant has indicated intent to select the option to pay in-lieu fees at a rate of $5 per square foot of habitable residential area through the requested development agreement. Based on available figures for the Project and under the current ordinance, staff’s analysis of the Project indicates the Project could generate approximately $7,100,000 in in-lieu fees, based on 1,583 units proposed, unit types/mix, and square footages. Any in-lieu fees generated by the Project must be spent on production of affordable housing in the City of Santa Ana.

Regional Housing Needs
Allocation (RHNA)
The State has placed an urgent emphasis on housing of all types. Santa Ana’s RHNA for the current General Plan Housing Element cycle (6th Cycle), which extends from 2021-2029, includes 3,137 housing units. This allocation is for housing units to be constructed to support the anticipated growth in the City over this period.

The City has a proven track record of not only planning for housing but issuing building permits for the construction of housing at all affordability categories as demonstrated by exceeding its 5th Cycle (2014-2021) RHNA by over 2,300 percent. The City is also on pace to meet or well exceed its affordable housing and other residential development requirements for the 6 th Cycle, far outpacing any city in Orange County, as evidenced by issuing 4,441 permits for housing units across all affordability categories, as detailed in the latest (2024) Housing Element Annual Progress Report, fulfilling 100 percent of its RHNA for above moderate housing. However, very-low, low, and moderate housing numbers have not been met and the Project would assist with AHOCO in-lieu fees that can be utilized to target the remaining housing categories. SP-6 would assist the City in achieving its housing goals in a location where high intensity urban development is City Council 28 – 14 9/16/2025
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Key Issue Analysis
both achievable and consistent with the current and envisioned surrounding urban form.

Amendment Application No. 2025-01
Pursuant to Sections 41-659 through 41-667 of the SAMC, the approval of an amendment application (zone change) requires approval of an ordinance by the City Council.

Amendment applications may be granted when it can be shown that the request is consistent with the intent and purpose of Chapter 41 (Zoning) of the SAMC, with previous amendments, and it is in substantial conformance with the General Plan. The Applicant is requesting approval of AA No. 2025-01 in order to change the zoning designation of the Project Site from SD-48 to SP-6 in order to guide future development of the Project Site consistent with the GPU and SBSFA.

Existing Zoning District Designation Proposed Zoning District Designation The SD-48 zoning district for the Project Site was established in 1989 for the purposes of facilitating the development of the South Coast Plaza Village. The SD-48 zoning district does not allow for residential uses and does not provide the means to achieve the goals and objectives of the Project or the General Plan land designation of DC-5 to produce a dynamic mixed-use village with residential, commercial, and open space land uses.

Therefore, approval of the requested amendment application to establish SP-6 is required to implement the vision of the Project and to establish consistency with the General Plan.

Vesting Tentative Tract Map No. 2025-06
Subdivision requests are governed by Chapter 34 (Subdivisions) of the SAMC. Pursuant to sections 66473.5 and 66474 of the California Subdivision Map Act (SMA), applications for vesting tentative tract maps are approved when it can be shown that findings can be made in support of the request. Specifically, findings related to the proposal need to be made that find the project is consistent with the General Plan, the site is physically suitable SP6
SP6
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for the type and density of the proposed project, the proposed project will not cause substantial environmental damage or substantially and avoidably injure fish and wildlife or their habitat, the proposed project will not cause serious public health problems, or the proposed project will not conflict with easements necessary for public access through or use of the property. Using this information, staff has prepared the following analysis, which, in turn, forms the basis for the recommendation contained in this report. In analyzing the Applicant’s request, staff believes that the following analysis warrants approval of VTTM No. 2025-06.

The Applicant is seeking approval of VTTM No. 2025-06 (County Map No. 2023-159) to subdivide the Project Site into six lots, attached hereto as Exhibit 9. The subdivision will allow the financing of individual components of the Project Site due to differences in phasing and funding mechanisms for commercial, residential, mixed-use, serviceoriented, parking, and open space components of the Project. The map also details roadway and utility improvements, as well as creation of new private roadways on the Project Site, in order to develop the Project Site as a pedestrian-oriented, mixed-use urban village. Covenants, Conditions, and Restrictions (CC&Rs) will be adopted to define the operating and maintenance requirements. They will also maintain a property owner’s association responsible for maintenance and enforcement of the CC&Rs and will ensure that parking and access can be shared throughout the entire Project Site.

In reviewing the Project, staff determined that the proposal, as conditioned, is consistent with the various provisions of the GPU, SAMC, and SMA. The Project Site is physically suitable for the type and density of the proposed Project, and the design and improvements of the proposed Project will not cause substantial environmental damage or substantially and avoidably injure fish and wildlife or their habitat. Lastly, the design and improvements of the proposed Project will not cause serious public health problems, and will not conflict with any easements necessary for public access through or use of the property within the proposed Project. The Project is located in an urbanized area that is proposed for redevelopment with additional urbanization in the form of commercial, service, residential, and open space land uses, and the Project Site is already served by infrastructure necessary and will be enhanced to support the proposed development.

General Plan Consistency
The Project implements the vision and objectives of the SBSFA by transforming an autooriented shopping center to a walkable, bike-friendly, and transit-friendly urban village that incorporates a mix of high-intensity office and residential living with experiential commercial uses. The Project is consistent with the allowed intensity and density of the DC-5 land use designation of the GPU. The Project also supports several goals and policies of the GPU. Specifically, the Project is consistent with the following goals and policies:

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• Policy CM-1.6 (Recreation on Private Property) of the Community Element, of promoting development and use of privately-owned recreation and entertainment facilities that help meet the needs of Santa Ana residents as the Project would include publicly accessible open space that would be made available to the general public through a public access easement with the City and would remain in effect through the life of the Project. Additional information regarding the required public access easement is discussed further in the Development Agreement Section of this report.
• Policy CN-1.6 (New and Infill Residential Development) of the Conservation Element encourages development that is mixed use, pedestrian friendly, transit oriented, and clustered around centers. The Project would introduce a mixed-use urban village and encourage experiential commercial uses that are more walkable, bike-friendly, and transit-oriented. The Project would create a commercial core providing for sufficient local serving and destination retail uses, residential opportunities, workplaces, and entertainment amenities to enable residents and shoppers to reduce reliance on the automobile.
• Policy EP-3.4 (Complete Communities) of the Economic Prosperity Element encourages the development of “complete communities” that provide a range of housing, services, amenities, and transportation options that support the retention and attraction of skilled workforce and employment. The Project would implement the vision of the SBSFA of creating an urban village that includes a range of uses.

The Project would promote a business-friendly environment where businesses thrive and would facilitate a “complete community” with a range of housing, services, and amenities and transportation options to support the retention and attraction of a skilled workforce and employment base.
• Policy HE-1.5 (Infrastructure and Public Services) of the Housing Element (HE) encourages the development of quality community facilities, physical infrastructure, traffic management and parking control, and other public services to promote the livability, safety, and vitality of neighborhoods. The Project would provide safe access points for pedestrians and bicyclists and would include new traffic signals along Bear Street and Plaza Drive to improve traffic management.

The PMP would also assist in controlling parking impacts. • Policy HE-2.6 (Housing Design) of the HE requires excellence in architectural design through the use of materials and colors, building treatments, landscaping, open space, parking, and environmentally sensitive (“green”) building and design practices. One primary objective of SP-6 is to bring high quality design to the Project Site, focusing on green standards, durable materials, visual integrity, and timeless architecture. The Project would incorporate quality design, from the larger design of the commercial and residential structures to the small details of materials, landscaping, pedestrian network, and communal gathering spaces.

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• Policy LU-2.1 (Employment Opportunities) of the Land Use Element (LU) encourages a broad spectrum of land uses and development that offer employment opportunities for current and future Santa Ana residents. The Project would include a mix of land uses that will serve as a catalyst for reinvestment, stimulate economic activity, commerce, and new development opportunities in and around the SBSFA. The Project would also have a positive contribution to the local economy through new capital investment, the creation of jobs, and the expansion of the tax base through the Project’s long-term investment and commitment to the City of Santa Ana.
• Policy LU-2.3 (Supportive Spaces) of the LU element encourages providing a diversity of land uses that support residents, visitors, and businesses, such as open space, areas for community gatherings, and outdoor entertainment venues.

One of the primary goals of the Project is to foster a neighborly environment where residents can live, work, and recreate in a vibrant village community. The Project would encourage walkability, safety, shopping, and dining, and would create community centric spaces for residents of all ages and abilities. • Policy LU-2.10 (Smart Growth) of the LU element emphasizes focusing high density residential in mixed-use villages, designated planning focus areas, downtown Santa Ana, and along major travel corridors. The Project is located with the SBSFA, a planned focus area. The Project would achieve the vision of the SBSFA of creating high density housing within and along a mixed-use village that would be the hub of activity, designed as a park-like setting that would create an intimate and relaxing environment.
• Policy M-1.2 (Balanced Multimodal Network) of the Mobility Element (M) encourages providing a balanced and equitable multimodal circulation network that reflects current and changing needs. The Project would accommodate a variety of transportation within and to/from the Project Site, including automobiles, walking, bikes, and rideshare. The Project would include an internal pedestrian network providing multiple access points along Bear Street, Sunflower Avenue, and Plaza Drive. Additionally, the Project would include for new bike lanes through and around the Project Site and bicycle parking stations. • Policy OS-1.9 (New Development) of the Open Space (OS) Element requires all new development to provide adequate parks and open space, including via parkland dedication or development fees, in order to meet the City’s Park standard.

Ensure that new development includes pedestrian and multi-modal travel ways to promote a quality living environment. For new development within park deficient and environmental justice areas, prioritize the creation and dedication of new public parkland over the collection of impact fees. The Project would provide approximately 7.5 acres of publicly accessible open space, consisting of both active and passive open space that would be open to the general public through a City Council 28 – 18 9/16/2025
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public access easement with the City and would remain in effect through the life of the Project. Additionally, the Project would require 90 square feet of private open space and 100 square feet of active or passive open space per unit. The Project also prioritizes open space as a key placemaking feature of the development. • Policy OS-2.1 (Recreation Variety) of the OS element encourages a variety of recreation facilities and activities to meet the diverse needs of the community. It also encourages the need for indoor and outdoor recreation opportunities, as well as traditional and trending activities. The Project would feature key open space areas. The Promenade has been designed to draw pedestrians from the residential area west of Bear Street, South Plaza Drive, and beyond to create a distinct destination along Sunflower Avenue. The Square is intended to be an intimate hub for public gathering, events, and relaxation from day to night. Various seating areas, water features, and experiential lighting and art are envisioned to activate the Square. A Fitness Loop would encircle and thread through the Project Site and include special markers to provide a continuous fitness path for residents and neighbors. The Recreation Lawn has been designed as an area where the community and their pets can gather and relax in a low-water-grass space.

Moreover, the Project is consistent with and supports Implementation Action No. LU-2.12 (Distinctive Districts) of the LU that requires the development and adoption of specific plans or corridor plans for each of the five focus areas that establish regulations and design standards. A full list of all applicable General Plan goals and policies that support the Project are attached hereto as Appendix B of Exhibit 7.

Development Agreement No. 2025-01
The Applicant has requested approval of a development agreement, DA No. 2025-01.

Development agreements are contracts negotiated between project proponents and public agencies, such as the City of Santa Ana, that govern the land uses that may be allowed in a particular project (Gov. Code Section 65864 et seq.). Although a development agreement is subject to negotiation, allowable land uses must be consistent with the local planning policies formulated by the legislative body through its general plan and consistent with any applicable specific plan, such as the proposed SP-6 (Gov. Code Section 65867.5). In addition, approval of a development agreement, requires adoption of an ordinance by the City Council.

To evaluate DA No. 2025-01 and identify priorities for agreement terms, the City Council formed an Ad Hoc committee in March 2025 comprised of three City Council members.

The Ad Hoc committee met to review the Applicant’s proposed terms, identify community priorities, and ensure that the final agreement addressed the Ad Hoc committee’s priorities. While review of a development agreement is a private contractual process, the extensive community engagement process and routine staff meetings with City Council City Council 28 – 19 9/16/2025
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members ensured that community priorities were effectively communicated to the Ad Hoc committee and informed the negotiation process.

DA No. 2025-01 contains an initial term (duration), extension process, community benefits, indemnification, monitoring and reporting, inclusionary housing, open space, infrastructure, modifications, and other relevant items, attached hereto for reference as Exhibit 8. These terms have been crafted to ensure the Project is of high-quality with positive financial impacts to the City. Table 6 provides a summary of major deal points in DA No. 2025-01.

Table 6: DA Major Deal Points
Deal Point Ad Hoc Committee
Recommendation
Proposed by DA
Term (Duration) and
Extension
One 20-year term, and one fiveyear automatic extension.

Extension subject to
construction commencement of
no less than 50,000 square feet
of commercial area and 360
residential dwelling units.

Applicant has agreed to this term and
proposed agreement was modified to
capture this change.

Timing of
Development
No building permits for
residential units shall be issued
in excess of 360 residential units
until building permits are
obtained for at least 50,000
square feet of commercial
space.

Applicant has agreed to this term and
proposed agreement was modified to
capture this change.

Community Benefit
Payments
Accept Community Benefit
Payment of $9,300,000 but
provide a larger upfront payment
and provide payments in less
intervals.

Applicant has revised the proposed
agreement to provide the Community
Benefit Payment in four payments instead
of five and increased Payment No. 1 by
$500,000. Payments will be provided as
follows:
• Payment No. 1 of $2,500,000 prior to
demolition permits being issued;
• Payment No. 2 of $3,600,000 prior to
permit issuance of Phase 2
• Payment No. 3 of $1,300,000 prior to
permit issuance of Phase 3
• Payment No. 4 of $1,900,000 prior to
permit issuance of Phase 4
Open Space Accept the construction of 7.5
acres of publicly accessible
open space to satisfy the City’s
park provision and fee
requirements. The developer
Applicant has agreed to these terms.

The SEIR prepared for the Project
identifies that the Project will result in a
demand for 11.4 acres of parkland, which
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Deal Point Ad Hoc Committee
Recommendation
Proposed by DA
must enter into a public access
easement for the publicly
accessible open space, which
must be recorded against the
Property Site for the life of the
Project.
is 3.9 acres more than the 7.5 acres being
proposed. However, the Project will remain
consistent with the General Plan pursuant
to Table OS-3 (Open Space Element
Implementation) of the General Plan,
Action Nos. 1.7 and 1.10. Action No. 1.7,
which recognizes the challenges and
difficulty in creating new open space and
parklands in a built-out environment and
provides for a reduction in on-site open
space by giving credits for park land for
public use as an incentive toward
developer creation of open space areas
that are accessible to the public. Action
No. 1.10 encourages collaboration with
property owners to provide public access
and programming on private open space.

Inclusionary Housing
Fee
Accept payment of $5 per
square feet of habitable space
Applicant has agreed to these terms.

Pursuant to SAMC Section 41-1903(a), the
Applicant has proposed a development
agreement to comply with Section 41-1904
of the SAMC, allowing payment of in-lieu
fees. SAMC Section 41-1904 provides
options to satisfy the AHOCO, including
on-site units, off-site units, and payment of
in-lieu fees. For projects containing 20 or
more units, the in-lieu fee is as high as $15
per square feet, but may be as low as $5
per square feet if determined by a
development agreement or if using skilled
and trained workforce. The in-lieu fees for
the Project are estimated to be
$7,100,000.

Overrule of Airport Land Use Commission’s Inconsistency Determination Pursuant to Section 21676(b) of the PUC, on June 19, 2025, the ALUC for Orange County held a public hearing on the Project and found the Project to be inconsistent with the AELUP for JWA per:
• Section 2.1.3 of the AELUP for JWA which states that a Determination of No Hazard to Air Navigation does not automatically equate to a Consistency determination by the ALUC and that the Commission may find a project Inconsistent based on an Obstruction determination; and City Council 28 – 21 9/16/2025
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• Section 3.2.1 of the AELUP for JWA which states that “within the boundaries of the AELUP, any land use may be found to be inconsistent with the AELUP which … permits structures of excessive height in areas which would affect adversely the continued operation of the airport; or permits activities or facilities that would affect adversely aeronautical operations.”
As a final review authority on legislative acts, the City Council may, after a public hearing, choose to overrule the ALUC's determination of inconsistency by following the procedure established in PUC sections 21676 and 21676.5. As part of the GPU, the City Council adopted a resolution on April 19, 2022, in accordance with the procedure established in PUC sections 21676 and 21676.5 to overrule the ALUC’s finding that the GPU was inconsistent with the AELUP for JWA. The action to overrule the ALUC’s decision on the GPU was based on the desire to advance the vision for the South Bristol Street and 55 Freeway/Dyer Road focus areas, which envision a dynamic, mixed-use environment with building heights and massing ranging from six to 25 stories.

At their July 15, 2025, meeting, City Council authorized staff to initiate the process for the City Council to consider the Project and to propose overriding the determination made by the ALUC by (1) issuing a Notice of Intent to Overrule and (2) giving notice to the ALUC of its decision to overrule as required by PUC Section 21676(b). On July 16, 2025, the Planning Division provided a Notice of Intent to Overrule the Commission’s determination with findings to the ALUC and Caltrans Division of Aeronautics. On August 12, 2025, Caltrans Division of Aeronautics responded to the City’s Notice of Intent, attached hereto as Exhibit 13 for City Council’s review and consideration, and on August 15, 2025, ALUC responded to the City’s Notice of Intent, attached hereto as Exhibit 14 for City Council’s review and consideration.

PUC Section 21676 permits the City Council, by a two-thirds vote of the members constituting a quorum, to overrule the ALUC’s determination if it finds that the proposed project is consistent with the purposes of the State Aeronautics Act. The Act states: “It is the public interest to provide for the orderly development of each public use airport in this State and the area surrounding these airports so as to promote the overall goals and objectives of the California noise standards…and to prevent the creation of new noise and safety problems.”
Based on staff’s review of the Project, the Project will not adversely impact the operations of the airport, the future development plans that exists for the airport, the approaches to the airport runways, create noise concerns, or create public health, safety, or welfare concerns. Additionally, the Project falls within a level of acceptable risk considered to be a community norm. Multiple taller structures than those proposed in the Project Site exist closer to the airport and its runways, notably in the cities of Costa Mesa, Irvine, and Newport Beach. Out of an abundance of caution and consistent with past practice, the Applicant will be required to record an avigation/aviation easement with both the County City Council 28 – 22 9/16/2025
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and the City to prevent claims, actions, or lawsuits for nuisance or interference with the use of the property against the City and JWA.

Community Engagement and Public Notification
Due to the complexity and scale of the Project, public outreach and notification were conducted using a variety of manners to engage broad segments of the community.

Community engagement and public notification processes for the Project exceeded the minimum requirements of the City. Upon submittal of the proposed Project to the City, staff met with the Applicant to provide information about the various neighborhood associations, business groups, and other communities surrounding the Project Site. Staff and the Applicant routinely attended community meetings in the vicinity of the Project Site to provide updates, receive feedback, and answer questions. Details of the public engagement component of the Project is also documented within SP-6, attached hereto as Exhibit 7.

Sunshine Ordinance Community Meetings and Additional Community Meetings In accordance with Article II.II (Public Meetings for Certain Development Projects) of Chapter 2 (Administration) of the SAMC, the Project hosted its first Sunshine Ordinance community meeting on August 23, 2023. Approximately 150 people attended the meeting, which was held at the Westin South Coast Plaza. The meeting was led by the Applicant’s community liaison whom gave a presentation on the Project before opening the floor to questions. The majority of the questions from attendees focused on traffic and parking.

There were also questions about rent versus for sale housing, how the Project would address affordable housing, and the viability of office space. Questions were addressed by the Applicant’s team. Meeting materials providing additional information on the Project including location and history, circulation and parking, architecture and design, infrastructure systems, land use, and vision and guiding principles were available throughout the room. Participants were also able to provide comments and questions via comment cards and sign up for email updates. Following the meeting, the meeting materials were made available on the City’s Project webpage.

The second required Sunshine Ordinance meeting was held on November 8, 2023.

Approximately 80 people attended the second meeting, which was held at the Westin South Coast Plaza. The Applicant’s community liaison led the meeting and gave a presentation on the Project before opening the floor for questions. The questions covered topics regarding traffic and parking, project schedule and construction, affordable housing and rents, and access to future amenities. Similar to the first meeting, participants were able to provide comments and questions via comment cards and sign up for email updates. The Project email and website were also promoted. Following the meeting, the meeting materials were made available on the City’s Project webpage.

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In addition to the required Sunshine Ordinance meetings, the Applicant has held and attended over 100 community meetings, including attending and presenting at large and small group meetings and individual one-on-one meetings. The Applicant has made themselves available for feedback from the general public and has returned countless phone calls, messages, and other correspondences. The Project has a dedicated community liaison with relationships in the community who has provided and continues to ensure up-to-date information is available to all members of the community. Lastly, City staff have made themselves available on a regular basis to answer the community’s questions about the Project through in-person and virtual meetings.

Online Content
As required by the Sunshine Ordinance, the City also established a Project webpage. The webpage has been routinely updated with Sunshine Ordinance meeting materials, Project information, key meeting dates, draft environmental documents, and the draft specific plan. The webpage also contains the City’s contact information with a direct phone number and email address to the Case Planner. In addition, the Applicant created a Project website and email to provide a broad overview of the Project and gather input from those who could not attend in-person meetings.

Planning Commission Work-Study Session
A Planning Commission work-study session was held on June 23, 2025, during which members of the Planning Commission were provided a presentation on the Project, its status at the time of the work-study session, and an opportunity to provide general comments and pose questions. The public comment portion of the meeting was opened to allow for any Project-related public comment on the Project.

Mandatory Public Hearing Notification Measures
Project notifications were posted, published, and mailed in accordance with City and State regulations. Copies of the public notice, including a 2,000-foot notification radius map, and the site posting are provided in Exhibit 11. In addition, even though the Project Site is not located within the boundaries of any neighborhood association, staff contacted the provided contacts for the Sandpointe, South Coast, Republic Homes, Metro Classic, Morning Sunwood, Thornton Park, Sunwood Central, and the Rosewood Baker neighborhood associations to ensure they were aware of the Project and public hearings.

ENVIRONMENTAL IMPACT
GPU Final Program Environmental Impact Report (“Final PEIR”) In April 2022, the City certified the GPU Final PEIR (SCH No. 2020029087) and adopted the GPU. The GPU Final PEIR is a program environmental impact report that examines City Council 28 – 24 9/16/2025
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the existing environment and the total scope of environmental effects that would occur as a result of buildout of the GPU land uses. The GPU Final PEIR comprehensively evaluated the potential environmental impacts stemming from adoption of the GPU and subsequent implementing projects. Moreover, this type of environmental document allows subsequent implementing activities, such as the proposed Project, to be evaluated through “tiering.” Tiering refers to the coverage of general matters in broader EIRs, such as the GPU Final PEIR, with subsequent narrower EIRs or ultimately site-specific EIRs incorporating by reference the general discussions and concentrating solely on the issues specific to the EIR subsequently prepared, such as in the case of the Project’s Supplemental EIR. Tiering is appropriate when the sequence of EIRs is (1) from a general plan, policy, or program EIR to a program, plan, or policy EIR of lesser scope or to a sitespecific EIR, (2) from an EIR on a specific action at an early stage to a subsequent EIR or a supplement to an EIR at a later stage.

The Project Site is located within the SBSFA and has a land use designation of DC-5, which has a maximum FAR of 5.0, a maximum of 125 dwelling du/ac, and a maximum height of 25 stories. This level of redevelopment was included in the GPU Final PEIR buildout, and applicable mitigation measures were identified, as necessary, to reduce impacts. A project is consistent with the GPU if the development density and intensity does not exceed what was contemplated and analyzed in the certified GPU EIR and complies with the associated standards applicable to that development density (State CEQA Guidelines Section 15183(i)(2)).

Supplemental Environmental Impact Report (SEIR)
In compliance with CEQA, and as required by Public Resources Code (PRC) Section 21166 and CEQA Guidelines Section 15162, the City of Santa Ana has prepared a SEIR that evaluates the potential of the proposed Project to result in new or substantially greater environmental impacts than previously identified in the GPU Final PEIR. The City’s certified PEIR examines the impacts associated with buildout of the Santa Ana General Plan. Once a Program EIR is prepared, subsequent activities within the program or changes to the program must be evaluated to determine whether additional CEQA documentation needs to be prepared.

The Project Site is within the SBSFA and development of the site was analyzed in the GPU Final PEIR at a programmatic level at 5.0 FAR and 125 du/ac assumption per the GPU DC-5 land use designation. The Project proposes a phased redevelopment of the Project Site, consistent with the DC-5 land use designation, and the City conducted project-level analysis to determine if the development of the Project would involve new significant environmental effects or a substantial increase in the impacts that were previously identified in the GPU Final PEIR. Following this project-level analysis, the City of Santa Ana prepared an SEIR that evaluated the potential of the proposed Project to result in new or substantially greater impacts than previously identified; applied the mitigation measures prescribed in the GPU FEIR; and where new or more significant City Council 28 – 25 9/16/2025
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impacts were identified, included Project specific mitigation measures. In addition, where impacts could not be mitigated to below a less than significant level, the SEIR made new significant and unavoidable findings. The Project’s SEIR also provides information regarding short-term, long-term, direct, indirect, and cumulative environmental effects of the Project. It identifies feasible mitigation measures and alternatives that would minimize or eliminate the potentially significant impacts associated with implementation of the Project.

SEIR’s Notice of Preparation
On November 3, 2023, the City sent to the Office of Land Use and Climate Innovation (LCI) and each responsible trustee agency a Notice of Preparation (NOP), stating that a SEIR would be prepared for the Project. A total of nine comments were received during the 30-day NOP review period which began on November 3, 2023, and ended on December 3, 2023.

SEIR Scoping Meeting
Pursuant to PRC Section 21083.9 and CEQA Guidelines sections 15082(c)(1) and 15083, the City hosted a public scoping meeting on November 15, 2023, to solicit comments on the scope of the environmental review of the proposed Project. Approximately 15 residents attended the meeting and raised concerns about traffic, pedestrian safety, and construction noise and debris. These issues were addressed in the Draft SEIR. In addition, participants were encouraged to submit comments on paper or via email to ensure inclusion in the draft SEIR and environmental analyses.

Draft and Final SEIR Public Review and Availability
The City determined at the onset of review and preparation based on analyses, the GPU Final PEIR, existing site conditions, setting, and responses to the NOP, that the Project would have no impact or a less than significant impact on the following environmental topic areas and that no further, detailed analysis of these topics was required in the SEIR:

Aesthetics, Agriculture and Forestry Resources, Biological Resources, Mineral Resources, and Wildfire. In particular, with respect to aesthetics, PRC Section 21099 provides that “aesthetic and parking impacts of a residential, mixed-use residential, or employment center project on an infill site within a transit priority area shall not be considered significant impacts on the environment.” Here, the proposed Project is located in a Transit Priority Area and therefore the SEIR did not include a detailed analysis of aesthetics. However, a discussion on the topic is included in the Land Use and Planning section of the SEIR.

For each topical area of potential significance, the SEIR evaluates impacts of the Project, what was evaluated by the GPU Final PEIR, mitigation measures already in place and adopted by the GPU Final PEIR’s MMRP, and project-specific mitigation measures.

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Section 15126.2(b) of the CEQA Guidelines requires an EIR to describe “any significant impacts, including those which can be mitigated but not reduced to a level of insignificance.” Potential environmental effects of the proposed Project and mitigation measures are discussed in detail throughout Chapter 4 of the Draft SEIR. The Draft SEIR determined that mitigation measures were required to mitigate impacts to a less than significant level for the following resource areas: air quality, cultural resources, geology and soils, noise, and tribal cultural resources.

However, the Draft SEIR concluded that despite the incorporation of all feasible mitigation measures, the proposed Project would nonetheless result in significant and unavoidable impacts to recreation. The impacts do not increase the severity of the impacts identified in the GPU Final PEIR. As detailed in Section 4.12 of the SEIR (Recreation), the City currently has approximately 1.2 acres of public park and/or recreational space per every 1,000 residents, which is below the City’s parkland aspirational standard of three acres of parkland per 1,000 residents. Based on the City’s parkland aspirational standard of three acres of public park and/or recreational space per 1,000 residents, buildout of the Project results in a need for approximately 11.4 additional acres of parkland to serve the estimated 3,815 new residents of the Project Site. The 7.5 acres of publicly accessible open space by the Project would be approximately 3.9 acres less than the City’s parkland aspirational standard. Although the proposed Project and cumulative projects would be required to provide park and recreational facilities, private open space, and/or pay in-lieu fees as required by the SAMC, the impacts related to the amount of parkland within the City would be cumulatively considerable and cumulative impacts related to parks and recreational facilities would be significant.

The SEIR also evaluated the following alternatives to the proposed Project that would feasibly avoid or lessen the proposed Project’s significant environmental impacts while attaining most of the proposed Project’s objectives: Alternative 1 (No project/No build), Alternative 2 (Reduced project alternative that reduces the commercial component to 50,000 square feet and eliminates the 300,000-square-foot office), and Alternative 3 (Reduced project alternative with no subterranean parking that would reduce the proposed residential units to 1,000 units, reduce the commercial component to 25,000 square feet, and eliminate subterranean parking). A detailed analysis of environmental impacts and feasibility of each alternative is included in the Final SEIR.

A MMRP has been prepared for the Project and is attached to the resolution certifying the Final SEIR No. 2025-01. A Statement of Overriding Considerations will be necessary should the City Council decide to approve the Project because of the significant and unavoidable impacts to recreation. The Statement of Overriding Considerations and Findings for the Project is attached hereto as Exhibit A to Exhibit 1.

As required by CEQA Guidelines Section 15087(a), the City filed a Notice of Completion with LCI, State Clearinghouse, indicating that the Draft SEIR had been completed and was available for public review. On April 17, 2025, a Notice of Availability (NOA) of the City Council 28 – 27 9/16/2025
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Draft SEIR was published and the Draft SEIR was circulated for a 52-day public review and comment period from April 17, 2025, through June 29, 2025. During the public comment period, copies of the Draft SEIR and technical appendices were available for review and inspection at City Hall, on the City’s project webpage, and at the Southwest Senior Center. The City received a total of eight comments from various individuals, organizations, or government agencies during this period.

On August 8, 2025, the City released the Final SEIR, which contains the Draft SEIR, all technical appendices prepared in support of the Draft SEIR, all written comment letters received on the Draft SEIR, written responses to all written comment letters received on the Draft SEIR, and errata to the Draft SEIR and technical appendices. In accordance with PRC Section 21092.5, copies of the written responses to public agencies that submitted comments during the 45-day review period will be forwarded to those agencies at least 10 days prior to certification of the Final SEIR by the City Council, with copies of the Final SEIR document. Pursuant to CEQA Guidelines Section 15089(b), lead agencies may provide an opportunity for review of the Final SEIR by the public or by commenting agencies before a project is approved, but is not required to do so; the Final SEIR is available for review on the City’s website at https://www.santa-ana.org/supplementalenvironmental-impact-report-the-village-santa-ana-specific-plan/, at the Southwest Senior Center, and at City Hall.

Staff recommends that the City Council certify the Final SEIR and adopt the MMRP for the Project, and adopt CEQA Findings of Fact and Statement of Overriding Considerations. The entire Final SEIR and all required components, including comments, responses, detailed analyses, and the MMRP, are contained within Exhibit 6 of this report.

FISCAL IMPACT
The GPU Land Use Element requires projects proposing a zone change, such as the proposed project, to evaluate economic, fiscal, and community benefits impacts through various analyses (Policy Nos. LU-2.4, LU-3.1, and Implementation Action No. LU-1.2). In accordance with the GPU, the Applicant prepared a market, fiscal, and economic analysis, attached hereto as Appendix C of Exhibit 7, that was peer-reviewed by a City consultant. The analysis concludes that given the amenity-rich environment of the Project Site, its location in a market area with higher than average rents, and the relatively low vacancy rates of nearby mixed-use and multiple-family residential communities, the Project’s residential, commercial, and office components could be absorbed by the market area. The other reports’ conclusions about the proposed Project and its impacts are outlined in Table 7 below.

City Council 28 – 28 9/16/2025
The Village Santa Ana Specific Plan Entitlements and Development Agreement (1561 W.

Sunflower Avenue)
September 16, 2025

Table 7: Key Economic, Fiscal, and Community Benefits Findings Topic Existing Site Proposed Project Net Change
Key Economic Benefit Findings
One-Time Impacts Not applicable 8,658 city-captured
jobs, including direct,
indirect, and induced
full- and part-time jobs;
$700 million citycaptured labor income;
and $1.1 billion citycaptured economic
output
Not
applicable
Recurring (Ongoing)
Impacts
Estimated 280 jobs 1,167 city-captured
jobs, including direct,
indirect, and induced
full- and part-time jobs;
$133 million citycaptured labor income;
and $119 million citycaptured economic
output
Increase of 887 jobs.

Jobs-Housing Balance 156,000 jobs city-wide;
83,005 housing units
city-wide; and 1.88
jobs-housing balance
157,167 jobs city-wide;
84,588 housing units
city-wide; and 1.86
jobs-housing balance
1,167 jobs resulting
from the project; 1,583
new housing units; 0.02
decline jobs-housing
balance, resulting in a
positive shift toward the
direction of a 1:1 jobhousing balance
Key Fiscal Impacts Findings
Total Annual Site
Revenues to the City’s
General Fund
$525,000 $5,493,100 $4,968,100
Total Annual Site
Expenditures from the
City’s General Fund
(Cost of Services)
$190,000 $2,824,500 $2,634,500
Net Annual Site
General Fund Fiscal
Impact to the City
$335,000 $2,668,600 $2,333,600
Land Residual Value Findings
Total Net Assessed
Value (NAV) Not applicable $1,265,000,000 Not applicable Total Costs Not applicable $1,100,000,000 Not applicable Excess of NAV over
Costs Not applicable $165,000,000 Not applicable
City Council 28 – 29 9/16/2025
The Village Santa Ana Specific Plan Entitlements and Development Agreement (1561 W.

Sunflower Avenue)
September 16, 2025

Topic Existing Site Proposed Project Net Change
Community Benefits Impacts Findings
Housing Construction None 1,583 units 1,583 units, assisting the City with meeting its
RHNA allocations
Community Benefit
Payment
None $9.3 million $9.3 million for
community benefits that
the City Council can
determine how to utilize
Affordable Housing InLieu FundsNone $7.1 million in in-lieu fees
$7.1 million in in-lieu
fees that can be used
for the construction of
affordable housing in
the City
Publicly Accessible
Open Space
None 7.5 acres 7.5 acres of publicly
accessible open space
that will be made
available to the general
public through an
easement
Urban Design and
Image of the City
Traditional, suburban
shopping center with
surface parking
Contemporary, iconic
mixed-use urban village
with mid- and high-rise
structures, urban
village street network,
bicycle lanes, on-street
parking, outdoor dining
areas, and high-quality
furnishings
Enhancement of the
City at a key gateway
intersection (Bristol
Street and Sunflower
Avenue), capitalizing
on the success of
South Coast Plaza and
adjacency to the I-405
freeway

EXHIBITS

1. Resolution (1) certifying the Final SEIR No. 2025-01 (SCH No. 2020029087) for the Project, (2) adopting Environmental Findings of Fact and a Statement of Overriding Considerations for the Project, (3) adopting a MMRP for the Project, and (4) approving the Project.

2. Ordinance approving Amendment Application No. 2025-01 establishing The Village Santa Ana Specific Plan (Specific Plan No. 6) and approving a zone change for the Property Site from Specific Development No. 48 (SD-48) to Specific Plan No. 6.

3. Ordinance approving Development Agreement No. 2025-01.

4. Resolution approving Vesting Tentative Tract Map No. 2025-06 (County Map No. 2023-159), as conditioned.

City Council 28 – 30 9/16/2025
The Village Santa Ana Specific Plan Entitlements and Development Agreement (1561 W.

Sunflower Avenue)
September 16, 2025

5. Resolution overruling the Orange County Airport Land Use Commission’s determination that the Project is inconsistent with the AELUP of JWA, including supportive findings.

6. Link to Final Supplemental Environmental Impact Report

7. Link to The Village Santa Ana Specific Plan and Appendices

8. Development Agreement

9. Vesting Tentative Tract Map No. 2025-06

10.Link to Sunshine Ordinance Meeting Materials

11.Responses to Planning Commission Comments Received Prior to the 3:30 p.m. deadline on August 11, 2025

12.Link to Planning Commission Agenda Packet

13.Caltrans Division of Aeronautics Response to City’s Notice of Intent

14.ALUC Response to City’s Notice of Intent

15.Copy of Public Notice
Submitted By: Ali Pezeshkpour, AICP, Executive Director of Planning and Building Agency
Approved By: Alvaro Nuñez, City Manager
City Council 28 – 31 9/16/2025
Resolution No. 2025-XXX

RESOLUTION NO. 2025-XXX

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

ENVIRONMENTAL IMPACT REPORT FOR THE VILLAGE
SANTA ANA SPECIFIC PLAN PROJECT (SCH NO.
2020029087); (2) ADOPTING ENVIRONMENTAL FINDINGS

OF FACT AND A STATEMENT OF OVERRIDING

CONSIDERATIONS FOR THE PROJECT PURSUANT TO
THE CALIFORNIA ENVIRONMENTAL QUALITY ACT; AND
(3) ADOPTING THE MITIGATION MONITORING AND

REPORTING PROGRAM
WHEREAS, in April 2022, the City of Santa Ana (“City”) certified the General Plan Update (GPU) Final Environmental Impact Report (FEIR) (SCH No. 202002908) and adopted its GPU; and
WHEREAS, the GPU Land Use Element guides development by designating land uses, evaluates the potential environmental effects associated with implementation of the GPU, and addresses appropriate and feasible mitigation measures that would minimize or eliminate these impacts; and
WHEREAS, The Village Santa Ana Specific Plan Project (“Project”) site is located within the GPU South Bristol Street Focus Area (SBSFA) and is consistent with the GPU land use designation; and
WHEREAS, the Project includes 11 addresses (1561, 1611, 1621, 1631, 1641, and 1661 West Sunflower Avenue; 3820, 3840, and 3951 South Plaza Drive; and 3811 and 3851 South Bear Street) and seven parcels (412-131-10, 412-131-20, 412-131-21, 412-451-01, 412-451-02, 412-451-03, and 412-451-04), collectively referred to as 1561 W. Sunflower Avenue (“Project Site”).

WHEREAS, the Project entails, among other things: (1) demolition of the existing structures on the Project Site; (2) the establishment of a new The Village Santa Ana Specific Plan (SP No. 6) and a change of zone for the Project Site from Specific Development No. 48 (SD-48) to SP No. 6 designation; (3) redevelopment of the Project Site into an urban village consisting of up to 1,583 residential units, 80,000 square feet of retail space, and 300,000 square feet of office space, including 7.5 acres of publicly accessible open space and onsite parking and landscaping; and (4) approval of Vesting Tentative Tract Map (VTTM) No. 2025- 06; and
WHEREAS, the City, in accordance with the California Environmental Quality Act (CEQA), determined that a Supplemental Environmental Impact Report (SEIR) to the GPU FEIR is required to evaluate the potential of the Project to result in new or substantially greater environmental impacts than previously identified in the GPU FEIR, and therefore did not prepare an initial study in accordance with State CEQA Guidelines Section 15063(a); and
City Council 28 – 32 9/16/2025
Resolution No. 2025-XXX

WHEREAS, pursuant to Section 21067 of the Public Resources Code, and State CEQA Guidelines Section 15367, the City of Santa Ana is the lead agency for the Project; and
WHEREAS, pursuant to State CEQA Guidelines Section 15082, on November 3, 2023, the City sent to the Office of Land Use and Climate Innovation and each responsible and trustee agency a Notice of Preparation (NOP), which was also published in the Orange County Register, a newspaper of general circulation in the City of Santa Ana, stating that a SEIR would be prepared; and
WHEREAS, nine comment letters were received in response to the NOP; and WHEREAS, pursuant to Public Resources Code Section 21083.9 and State CEQA Guidelines sections 15082(c) and 15083, the City held a duly noticed scoping meeting on November 15, 2023, to solicit comments on the scope of the environmental review of the proposed Project, and two (2) written comments were received; and WHEREAS, a Draft Supplemental Environmental Impact Report (Draft SEIR) (SCH No. 2020029087) was prepared for the Project addressing comments received in response to the NOP and evaluating the proposed Project’s potentially significant environmental impacts; and
WHEREAS, the Draft SEIR determined that mitigation measures were required to mitigate impacts to a less than significant level for the following resource areas: air quality, cultural resources, geology and soils, noise, and tribal cultural resources; and WHEREAS, the Draft SEIR further concluded that despite the incorporation of all feasible mitigation measures, the proposed Project would nonetheless result in significant and unavoidable impacts relating to recreation; and
WHEREAS, in accordance with State CEQA Guidelines Section 15085, a Notice of Completion (NOC) was prepared and filed with the Office of Land Use and Climate Innovation on April 17, 2025; and
WHEREAS, as required by State CEQA Guidelines Section 15087(a), the City provided Notice of Availability of the Draft SEIR to the public at the same time that the City sent the NOC to the Office of Land Use and Climate Innovation on April 17, 2025; and WHEREAS, during the public comment period, copies of the Draft SEIR and technical appendices were available for review and inspection at City Hall, on the City’s website, and at the City of Santa Ana Southwest Senior Center; and WHEREAS, consistent with State CEQA Guidelines Section 15087(e), the Draft SEIR was circulated for a 52-day public review and comment period from April 17, 2025, to June 9, 2025; and
WHEREAS, during the public review and comment period, the City consulted with and requested comments from all responsible and trustee agencies, other regulatory agencies, and others pursuant to State CEQA Guidelines Section 15086; and City Council 28 – 33 9/16/2025
Resolution No. 2025-XXX

WHEREAS, the City received eight (8) written comment letters on the Draft SEIR; and
WHEREAS, pursuant to Public Resources Code Section 21092.5, the City provided copies of its responses to commenting public agencies at least ten (10) days prior to the City’s consideration of the Final SEIR, on August 4, 2025; and WHEREAS, on August 4, 2025, the City released the Final SEIR; and WHEREAS, the Final SEIR consists of the Draft SEIR, all technical appendices prepared in support thereof; all documents incorporated by reference, all written comments letters received on the Draft SEIR, written responses to all written comments letters and verbal comments received on the Draft SEIR, revisions to the Draft SEIR and technical appendices, the Mitigation Monitoring and Reporting Program (MMRP), and Statement of Overriding Considerations; and
WHEREAS, on August 11, 2025, the Planning Commission conducted the public hearing to consider the Final SEIR and the Project, and solicited comments on the document. After hearing all relevant testimony from staff, the public and the City’s consultant team, the Planning Commission voted to recommend that the City Council certify the SEIR for the Project, adopt Environmental Findings of Fact and a Statement of Overriding Considerations for the Project, adopt a MMRP for the Project, and approve the Project; and
WHEREAS, on September 16, 2025, the City Council held a duly noticed public hearing to consider the Final SEIR and the Project, at which hearing members of the public were afforded an opportunity to comment and the Project was fully considered; and WHEREAS, all potentially significant adverse environmental impacts were sufficiently analyzed in the Final SEIR; and
WHEREAS, as contained herein, the City has endeavored in good faith to set forth the basis for its decision and recommendations on the Project; and WHEREAS, all of the requirements of the Public Resources Code and the CEQA Guidelines have been satisfied by the City in connection with the preparation of the Final SEIR, which is sufficiently detailed so that all of the potentially significant environmental effects of the Project have been adequately evaluated; and WHEREAS, the Final SEIR prepared in connection with the Project sufficiently analyzes the Project’s potentially significant environmental impacts, and the Final SEIR analyzes a range of feasible alternatives to address whether these effects can be reduced to a level of less than significant; and
WHEREAS, the City has made certain findings of fact, as set forth in Exhibit A to this Resolution, attached hereto and incorporated herein, based upon the oral and written evidence presented to it as a whole and the entirety of the administrative record for the Project, which are incorporated herein by this reference; and City Council 28 – 34 9/16/2025
Resolution No. 2025-XXX

WHEREAS, the City finds that the Project’s environmental topics that would result in no impact, as identified in the Final SEIR, are described in Chapter 4 of the Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the City finds that the Project’s environmental impacts that are less than significant without implementation of project-specific mitigation measures, as identified in the Final SEIR, are described in Chapter 4 of the Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the City finds that the Project’s impacts that, without mitigation, would result in significant adverse impacts, and that upon implementation of the mitigation measures provided in the Final SEIR, would be considered less than significant, are described in Chapter 5 of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the City finds that the Project’s impacts that, even with mitigation measures, would remain significant and unavoidable are described in Chapter 6 of the Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the cumulative impacts of the Project identified in the Final SEIR and set forth herein, are described in Chapters 4, 5, and 6 of the Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the potential significant irreversible environmental changes that would result from the proposed Project are described in Chapter 7 of the Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the existence of any growth-inducing impacts and commitment of resources resulting from the proposed Project are described in Chapter 8 of the Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the City finds that the reasonable alternatives to the Project are described in Chapter 9 of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the Statement of Overriding Considerations that indicates the benefits of the Project outweigh the unavoidable significant environmental effects is described in Chapter 10 of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, all the mitigation measures identified in the Final SEIR and necessary to reduce the potentially significant impacts of the Project to a level of less than significant are set forth in the MMRP, attached hereto as Exhibit B; and WHEREAS, prior to acting on the Project, the City has heard, been presented with, reviewed, and considered all of the information and data in the administrative record, including but not limited to the Final SEIR and all oral and written evidence presented to it during all meetings and hearings; and
WHEREAS, the Final SEIR reflects the independent judgment of the City and is deemed adequate for purposes of making decisions on the merits of the Project; and City Council 28 – 35 9/16/2025
Resolution No. 2025-XXX

WHEREAS, no comments made in the public hearing conducted by City Council and no additional information submitted to the City Council have produced substantial new information requiring recirculation of the Final SEIR or additional environmental review of the Project under Public Resources Code Section 21092.1 and State CEQA Guidelines Section 15088.5; and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred.

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

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

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

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

Section 4. The City Council hereby:

A. Certifies the Final SEIR based on the entirety of the record of proceedings.

B. Adopts the Findings of Fact and Statement of Overriding Considerations, attached hereto and incorporated herein as Exhibit A, after balancing the significant and unavoidable recreation impacts of the proposed Project against the benefits of the proposed Project.

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

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

City Council 28 – 36 9/16/2025
Resolution No. 2025-XXX

Section 5. The documents and materials associated with this Resolution that constitute the record of proceedings on which these findings are based are located at Santa Ana City Hall, 20 Civic Center Plaza, Santa Ana, CA 92701. The Planning Manager is the custodian of records for the record of proceedings. This information is provided pursuant to Public Resources Code Section 21081.6.

Section 6. This Resolution shall take effect immediately upon its adoption by the City Council, and the City Clerk shall attest to and certify the vote adopting this Resolution.

ADOPTED this _____ day of _______________, 2025.
_________________________
Valerie Amezcua
Mayor
APPROVED AS TO FORM:

Sonia R. Carvalho, City Attorney
By: _________________________
Melissa M. Crosthwaite
Senior Assistant City Attorney
AYES: Councilmembers: _______________________________________ NOES: Councilmembers: _______________________________________ ABSENT: Councilmembers: _______________________________________ ABSTENTIONS: Councilmembers: _______________________________________ City Council 28 – 37 9/16/2025
Resolution No. 2025-XXX

CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, Jennifer L. Hall, City Clerk, do hereby attest to and certify the attached Resolution No. 2025-XXX to be the original resolution adopted by the City Council of the City of Santa Ana on ____________________, 2025.

Date: _______________ _________________________
Jennifer L. Hall
City Clerk
City of Santa Ana
City Council 28 – 38 9/16/2025
City Council 28 – 39 9/16/2025
CEQA Findings of Fact
and
Statement of Overriding Considerations
for
The Village Santa Ana Specific Plan Project
State Clearinghouse No. 2020029087
Lead Agency:

City of Santa Ana
20 Civic Center Plaza, M-20
Santa Ana, CA 92701
August 2025
City Council 28 – 40 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations i

TABLE OF CONTENTS
SECTION PAGE NO.

CHAPTER 1 INTRODUCTION..................................................................................................... 1-1

1.1 Statutory Requirements............................................................................................... 1-1

1.2 Document Format........................................................................................................ 1-2

1.3 Location and Custodian of Record of Proceedings ..................................................... 1-3 CHAPTER 2 PROJECT SUMMARY ............................................................................................ 2-1

2.1 Description of Project Proposed for Approval.............................................................. 2-1

2.2 Agreements, Permits, and Approvals .......................................................................... 2-2

2.3 Project Objectives........................................................................................................ 2-3 CHAPTER 3 ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION................................... 3-1 CHAPTER 4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES........................................................................... 4-1

4.1 Aesthetics .................................................................................................................... 4-1

4.2 Agriculture and Forestry Resources ............................................................................ 4-3

4.3 Air Quality .................................................................................................................... 4-4

4.4 Biological Resources ................................................................................................... 4-6

4.5 Cultural Resources ...................................................................................................... 4-8

4.6 Energy ....................................................................................................................... 4-10

4.7 Geology and Soils ..................................................................................................... 4-12

4.8 Greenhouse Gas Emissions...................................................................................... 4-13

4.9 Hazards and Hazardous Materials ............................................................................ 4-15

4.10 Hydrology and Water Quality..................................................................................... 4-20

4.11 Land Use and Planning ............................................................................................. 4-25

4.12 Mineral Resources..................................................................................................... 4-27

4.13 Noise ......................................................................................................................... 4-28

4.14 Population and Housing ............................................................................................ 4-29

4.15 Public Services .......................................................................................................... 4-30

4.16 Transportation ........................................................................................................... 4-34

4.17 Utilities and Service Systems .................................................................................... 4-37

4.18 Wildfire....................................................................................................................... 4-45 City Council 28 – 41 9/16/2025

TABLE OF CONTENTS
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations ii
CHAPTER 5 LESS-THAN-SIGNIFICANT ENVIRONMENTAL EFFECTS WITH MITIGATION INCORPORATED........................................................................................................................5-1

5.1 Air Quality ....................................................................................................................5-1

5.2 Cultural Resources ......................................................................................................5-6

5.3 Geology and Soils .......................................................................................................5-8

5.4 Noise .........................................................................................................................5-13

5.5 Tribal Cultural Resources ..........................................................................................5-16 CHAPTER 6 SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL EFFECTS..........................6-1

6.1 Recreation ...................................................................................................................6-1 CHAPTER 7 FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES…………………..........................................................................................................7-1 CHAPTER 8 FINDINGS REGARDING GROWTH-INDUCING IMPACTS........................................8-1 CHAPTER 9 FINDINGS REGARDING PROJECT ALTERNATIVES..............................................9-1

9.1 Discussion of Alternatives Considered but Rejected...................................................9-2

9.1.1 Buildout of the Zoning Designation Alternative ....................................................9-2

9.1.2 Off-Site Alternative ...............................................................................................9-3

9.2 Alternatives Selected for Further Analysis...................................................................9-3

9.2.1 Alternative 1: No Project/No Build ........................................................................9-4

9.2.2 Alternative 2: Reduced Project Alternative...........................................................9-5

9.2.3 Alternative 3: Reduced Project with No Subterranean Parking Alternative..........9-6

9.3 Environmentally Superior Alternative ..........................................................................9-7 CHAPTER 10 STATEMENT OF OVERRIDING CONSIDERATIONS............................................10-1

10.1 Introduction................................................................................................................10-1

10.2 Significant Unavoidable Impacts ...............................................................................10-2

10.3 Project Benefits .........................................................................................................10-2

10.4 Conclusion.................................................................................................................10-3 City Council 28 – 42 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 1-1
CHAPTER 1

INTRODUCTION
These California Environmental Quality Act (CEQA) Findings of Fact and Statement of Overriding Considerations are for The Village Santa Ana Specific Plan Project, herein referred to as the “Project.” The City of Santa Ana (lead agency) prepared a Supplemental Environmental Impact Report (EIR) to the City’s General Plan Update (GPU) Final Program EIR (GPU PEIR) (State Clearinghouse No. 2020029087) for the Project. The GPU PEIR was certified by the City on April 19, 2022.

1.1 STATUTORY REQUIREMENTS
CEQA requires that a number of written findings be made by the lead agency in connection with certification of an EIR prior to approval of a project pursuant to Sections 15091 and 15093 of the State CEQA Guidelines and Section 21081 of the Public Resources Code (PRC). The State CEQA Guidelines Section 15091 provides that:
(a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are:
(1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can or should be adopted by such other agency. (3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.

In short, pursuant to State CEQA Guidelines sections 15091(a) and (b), CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to avoid or mitigate significant environmental impacts that would otherwise occur with implementation of a proposed project. However, project mitigation or alternatives are not required, where they are infeasible or where the responsibility for modifying a proposed project lies with another agency.

Pursuant to PRC Section 21081(b), when a lead agency approves a project with significant effects that cannot be mitigated to a less-than-significant level, the public agency is required to find that specific overriding economic, legal, social, technological, or other benefits of the proposed project outweigh the significant effects on the environment. State CEQA Guidelines Section 15093(a) states that:

If the specific economic, legal, social, technological, or other benefits… of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.” City Council 28 – 43 9/16/2025
1 INTRODUCTION
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 1-2
The Supplemental EIR for the Project is composed of the following elements:
• The Village Santa Ana Specific Plan Project Draft Supplemental EIR and Technical Appendices (April 2025);
• The Village Santa Ana Specific Plan Project Final Supplemental EIR (August 2025); and • Santa Ana General Plan Update Program Environmental Impact Report (GPU PEIR), SCH No. 2020029087.

1.2 DOCUMENT FORMAT
The Findings of Fact is organized into the following sections:

Chapter 1: Introduction outlines the organization of this document and identifies the location and custodian of the record of proceedings.

Chapter 2: Project Summary provides a summary of the Project, overview of the discretionary actions required for approval of the Project, and a statement of the Project’s objectives.

Chapter 3: Environmental Review and Public Participation Process provides a summary of previous environmental reviews related to the Project area that took place prior to the environmental review done specifically for the Project, and a summary of public participation in the environmental review for the Project.

Chapter 4: No Environmental Effects and Less Than Significant Environmental Effects without Mitigation Measure presents a summary of those environmental issue areas where no impacts or less than significant impacts would occur and a corresponding finding adopting the Initial Study and PEIR’s conclusions of no impact or less than significant impacts.

Chapter 5: Less Than Significant Environmental Effects with Mitigation Incorporated presents a summary of potentially significant environmental effects for which implementation of identified feasible mitigation measures would avoid or substantially reduce the environmental effects to less-than-significant levels and provides a corresponding finding for each effect. In order to ensure compliance and implementation, all of these measures are included in the Mitigation Monitoring and Reporting Program (MMRP) for the Project and adopted as conditions of the Project by the Lead Agency.

Chapter 6: Significant and Unavoidable Environmental Effects presents a summary of significant and unavoidable effects for which there are no known feasible mitigation measures that would avoid or substantially reduce the environmental effects to less-than-significant levels and provides a corresponding finding for each effect.

Chapter 7: Findings Regarding Significant Irreversible Environmental Changes presents a summary of the significant irreversible environmental changes that would occur should the Project be implemented.

Chapter 8: Findings Regarding Growth-Inducing Impacts presents a summary of the growthinducing effects considered for the Project.

Chapter 9: Findings Regarding Project Alternatives presents a summary of the alternatives considered for the proposed Project.

City Council 28 – 44 9/16/2025
1 INTRODUCTION
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 1-3
Chapter 10: Statement of Overriding Considerations presents a summary of all of the significant unavoidable adverse impacts associated with the implementation of the proposed Project. In addition, this chapter identifies the proposed Project’s substantial benefits that outweigh and override the proposed Project’s significant unavoidable impacts, such that the impacts are considered acceptable.

1.3 LOCATION AND CUSTODIAN OF RECORD OF PROCEEDINGS
The documents and other materials that constitute the record of proceedings upon which the City’s Project approval is based are located at the City’s Planning Division office at 20 Civic Center Plaza, M-20, Santa Ana, CA 92701. The City’s Planning Division is the custodian of the administrative record for the project. Copies of these documents, which constitute the record of proceedings, are and at all relevant times have been and will be available upon request at the offices of the Planning Division Counter. The record of proceedings is provided in compliance with PRC Section 21081.6(a)(2) and State CEQA Guidelines Section 15091(e).

City Council 28 – 45 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 2-1
CHAPTER 2

PROJECT SUMMARY

2.1 DESCRIPTION OF PROJECT PROPOSED FOR APPROVAL
The Village Santa Ana Specific Plan Project would provide for redevelopment of the approximately 17.2-acre site located on the northeast corner of West Sunflower Avenue and Bear Street, transected by South Plaza Drive. The project site comprises seven parcels (Assessor’s Parcel Numbers 412-451-01 through -04 and 412-131-10, -20, -21 ((Project Site)). The Project Site is currently occupied by the South Coast Plaza Village commercial center on both sides of South Plaza Drive which consists of approximately 164,049 square feet of retail shops and restaurants, offices, and the Regency Theatres cinema building. The City’s GPU Land Use Element designates the project site as District Center-High (DC-5) within the South Bristol Street Focus Area (SBSFA). Development in the DC-5 designation is intended to provide urban retail, residential, mixed-use, and employment centers. The Project Site is currently zoned as Specific Development Plan No. 48 (SD-48) which was adopted in 1989 and was last amended in 1997.

The Project would redevelop the site with mixed-use commercial and residential, residential only, and commercial only buildings. A central commercial area would include a variety of commercial uses, such as restaurants, a market, and retail uses, with additional commercial uses extending through the ground floor of adjacent residential buildings. Stand-alone residential and mixed-use buildings would provide housing opportunities for residents in the City’s SBSFA. In total, The Project would include up to 1,583 residential units (encompassing approximately 1,850,000 square feet of building space), 80,000 square feet of retail space, 300,000 square feet of office space, and approximately 7.5 acres of publicly accessible open space and common areas. The Specific Plan includes a maximum height of 25 stories with a minimum of 1 story for commercial/office only buildings and no minimum height for residential or mixed-use buildings.

Parking would be provided in tower and podium buildings and underground building levels with up to four levels below grade.

At full buildout, the Project is anticipated to provide a combined 13.8 acres of public and private outdoor and recreation space including approximately 7.5 acres of publicly accessible open space and common areas and 6.3 acres of private outdoor and amenity spaces. Public open spaces at the Project would consist of active spaces, outdoor seating, garden paseos, a fitness loop, and a recreational lawn. Private open space amenities include outdoor balconies and patios, pools and spas, outdoor kitchens, and communal gathering spaces. The proposed Project would also include roadway and streetscape modifications and improvements along Sunflower Avenue, Bear Street, and South Plaza Drive in addition to new access points throughout the project site and a bicycle network which includes a new Class IV cycle track along Sunflower Avenue, and a new Class I bike path along Bear Street.

Construction of the proposed Project is anticipated to begin January 2026 and could take up to 20 years to complete. Construction of the proposed Project would be implemented in a series of five phases to reflect anticipated market conditions and to ensure that access, public facilities, and infrastructure connections are appropriately installed to serve the Project. Demolition of the entire Project Site would occur during the first phase of the construction period. Subsequently, the construction period for each phase would generally include excavation, grading, trenching, pile driving, installation of utilities, building construction, architectural coating, paving activities, City Council 28 – 46 9/16/2025
2 PROJECT SUMMARY
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 2-2
and installation of landscaping and hardscape elements for the respective phase. The maximum excavation would reach approximately 52 feet below grade where up to four levels of subterranean parking are proposed. Approximately 420,000 cubic yards of total material would be excavated and likely hauled away from the project site.

2.2 AGREEMENTS, PERMITS, AND APPROVALS
The following approvals and/or permits would be required to implement the proposed Project. The environmental documentation for the proposed Project would be used to facilitate compliance with federal, state, and local laws and ordinances, as well as granting permits by various federal, state, and local agencies having jurisdiction over one or more aspects of the Project.

City of Santa Ana
• The Village Santa Ana Specific Plan adoption by ordinance by City Council • Environmental Impact Report (EIR) certification in accordance with the California Environmental Quality Act (CEQA) by resolution by City Council • Development Agreement: A development agreement between the Applicant and the City describing development rights and public benefits for the development pursuant Government Code Section 65864 et seq. The Development Agreement will be reviewed concurrently with the Village Santa Ana Specific Plan and requires adoption by ordinance by City Council.
• Tentative Tract Map to create legal conveyable lots for project development, formalize the parcel boundaries, and provide for public rights-of-way for project access. The Tentative Tract Map will be reviewed concurrently with the Village Santa Ana Specific Plan and requires adoption by resolution by City Council. • Demolition, grading, and building permits
City of Costa Mesa
• Issuance of encroachment permits
Santa Ana Regional Water Quality Control Board
• National Pollutant Discharge Elimination System (NPDES) Construction General Permit (Order No. 2022-0057-DWQ)
• Orange County MS4 Permit (Order R8-2009-0030, NPDES No. CAS618030, as amended by Order No. R8-2010-0062)
• General Waste Discharge Requirements for Discharges to Surface Waters Resulting from De Minimis Discharges or Groundwater Dewatering Operations, and/or Groundwater Cleanup/Remediation Operations at Sites within the Newport Bay Watershed Permit (Order No. R8-2019-0061, NPDES No. CAG918002) Federal Aviation Administration
• Form 7460-1, Notice of Actual Construction or Alteration City Council 28 – 47 9/16/2025
2 PROJECT SUMMARY
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 2-3
Orange County Airport Land Use Commission
• Land use review
Orange County Transportation Authority (OCTA)
• Issuance of approvals associated with bus stop improvements and relocations South Coast Air Quality Management District
• Issuance of any permits to construct or permits to operate

2.3 PROJECT OBJECTIVES
State CEQA Guidelines Section 15124(b) (Title 14, California Code of Regulations [CCR]) requires that the description of the project shall contain a statement of objectives sought by the proposed project. The project objectives have been developed to incorporate the GPU objectives and vision, including the GPU SBSFA objectives. The following are the proposed Project objectives:
• Implements the vision and objectives established in the City of Santa Ana General Plan for the South Bristol Street Focus Area as the City’s southern gateway and part of the South Coast Metro area by creating opportunities to transform auto-oriented shopping plazas to walkable, bike-friendly, and transit-friendly urban villages that incorporate a mix of high-intensity office and residential living with experiential commercial uses. The following are based on the South Bristol Street Focus Area objectives:
o Capitalizes on the success of the South Coast Metro area; o Introduces mixed-use urban villages and encourage experiential commercial uses that are more walkable, bike friendly, and transit oriented; and, o Provides for mixed-use opportunities while protecting adjacent, established low density neighborhoods.
• Fosters a neighborly environment where residents can live, work, and recreate in a vibrant village community.
• Anchors Santa Ana’s South Bristol Street Focus Area as envisioned by the City, which is to transform conventional auto-oriented shopping plazas into dynamic nodes of activity that blend healthy living, working, shopping, and dining in a contemporary village environment.
• Captures Orange County’s indoor-outdoor lifestyle through attention to detail in the design of buildings, selection of materials, infusion of nature in outdoor spaces, and the activities offered in the Village.
• Builds on the foundation of this dynamic area through new experiences in food, fitness, and artisan retail.
• Complements the successful South Coast Metro area with a diversity of new housing in a jobs-rich environment.
• Attracts the innovative and start-up culture of Orange County and provides thoughtfully designed spaces to create and showcase new offerings.

City Council 28 – 48 9/16/2025
2 PROJECT SUMMARY
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 2-4
• Complements and does not compete with the emerging business environment of Downtown Santa Ana.
• Allows for the flexible redevelopment of the underutilized project site to provide a balanced mix of residential, retail, recreation, and office uses in the South Bristol Street Focus Area that integrate into the existing urban systems and provide a safe and attractive environment for living and working, as encouraged by the GPU. • Develops high quality residential spaces that reflect modern lifestyles, while responding to the vision of the GPU to help bring higher density housing into a jobs-rich area of the City planned for growth, to facilitate balancing the City’s jobs-housing ratio. • Provides a positive contribution to the local economy through new capital investment, the creation of new jobs, development of more commercial opportunities, attraction of economic activity, and the expansion of the tax base.
• Enhances alternative transportation activity by creating a walkable and bikeable mixeduse development that links with existing facilities and transit services to encourage nonautomotive travel within the Specific Plan area and the local community. • Improves existing infrastructure to support the Village Santa Ana Specific Plan consistent with the General Plan conditions.
• Provides a project that contributes to the creation of a vibrant urban core for the City by providing vibrant and attractive community amenities, recreational and open space areas, and gathering spaces that are directly accessible to residents and the community, and takes advantage of the site’s location within the South Coast Metro area. • Provides on-site open space and community-serving recreational amenities recognizing that this area of the City is currently identified as park-deficient by the GPU. • Provides community benefits commensurate with the Specific Plan development proposal including public open space onsite and locations for public community events, as well as streetscape improvements along the project site frontages of Sunflower Avenue and Bear Street.

City Council 28 – 49 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 3-1
CHAPTER 3

ENVIRONMENTAL REVIEW AND PUBLIC

PARTICIPATION
In conformance with CEQA and the State CEQA Guidelines, the City of Santa Ana conducted an extensive environmental review of the Project, which included a Draft Supplemental EIR and a Final Supplemental EIR, including technical reports, along with a public review and comment period. The following is a summary of the City’s environmental review of this project:
• The City of Santa Ana concluded that a Supplemental EIR should be prepared, and the Notice of Preparation (NOP) was released for a 30-day public review period from November 3, 2023 through December 4, 2023 pursuant to State CEQA Guidelines 15082.

The NOP was posted at the Orange County Clerk’s Office on November 3, 2023. The notice was published in the Orange County Register, available at the City of Santa Ana, Planning Division Counter, located at 20 Civic Center Plaza, M-20, Santa Ana, CA 92701, and the City of Santa Ana Public Library, located at 26 Civic Center Plaza, Santa Ana, CA 92701. Under CEQA, a Lead Agency may proceed directly with preparation of the EIR without preparation of an Initial Study if it is clear that an EIR will be required (State CEQA Guidelines Section 15060[d]).
• The NOP public review period ran for 30 days. The City received response letters from the State, regional and local public agencies, and interested parties. These comment letters were included in Appendix A: Notice of Preparation and Scoping Comments of the Draft Supplemental EIR.
• A duly-noticed scoping meeting for the Supplemental EIR was held on November 15, 2023, at 6:00 p.m. at the McFadden Institute of Technology located at 2701 South Raitt Street in the City of Santa Ana to obtain information from the public as to issues that should be addressed in the Supplemental EIR. The notice of a public scoping meeting was included in the NOP distributed on November 3, 2023 and was published in the Orange County Register and was sent to agencies, interested parties, and individuals who requested to be notified of the Project.
• The Draft Supplemental EIR was distributed by the City of Santa Ana, which was made available for a 52-day public review period (April 17, 2025 through June 9, 2025). The Notice of Availability (NOA) for the Draft Supplemental EIR was sent to all persons, agencies and organizations on the interest list interested persons, published on April 17, 2025, at the Orange County Register, and posted at the Orange County Clerk’s Office and the State Clearinghouse (SCH) at the Governor’s Office of Land Use and Climate Innovation (LCI) on April 17, 2025. Copies of the Draft Supplemental EIR were made available for public review at the City of Santa Ana, Planning Division Counter, located at 20 Civic Center Plaza, M-20, Santa Ana, CA 92701, and the Southwest Senior Center, located at 2201 West McFadden Avenue, Santa Ana, CA 92704. The Draft Supplemental EIR was also available for review and download via the following City website location and CEQAnet web portal: https://www.santa-ana.org/the-village-santa-ana-specific-plan/ and https://ceqanet.opr.ca.gov/. Additionally, the NOA was published in the Orange County Register.

City Council 28 – 50 9/16/2025
3 ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 3-2
• The City received a total of eight comment letters on the Draft Supplemental EIR from public agencies and organizations regarding the merits of the Project or questions regarding the Project. The City prepared responses to all written comments. The comments and responses are contained in Section 2, Responses to Comments, of the Final Supplemental EIR. Additionally, the Final Supplemental EIR contains revisions to the Draft Supplemental EIR and final Mitigation Monitoring and Reporting Program. • In accordance with CEQA, the City provided written responses to the public agencies that commented on the Draft Supplemental EIR at least 10 days prior to certification of the Supplemental EIR.
• Pursuant to State CEQA Guidelines Section 15095, staff is directed as follows: a) copy of the Final Supplemental EIR and CEQA Findings of Fact shall be retained in the Project files; and b) copy of the Final Supplemental EIR and CEQA Findings of Fact shall be provided to the Project applicant who is responsible for providing a copy of the same to all CEQA "responsible" agencies.
• Hearings before the City Council were held following a recommendation from the Planning Commission.

City Council 28 – 51 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-1
CHAPTER 4
NO ENVIRONMENTAL EFFECTS AND LESS-THANSIGNIFICANT ENVIRONMENTAL EFFECTS WITHOUT

MITIGATION MEASURES
Based on the Supplemental EIR, the Project would have no or less-than-significant environmental effects for the specific areas associated with the topics identified below.

4.1 AESTHETICS
Threshold AE-1: The Project would not have a substantial adverse effect on a scenic vista.

Findings: The City finds that the Project would result in less than significant impacts to aesthetics related to scenic vistas. (Draft Supplemental EIR, pp. 5-5 – 5-6.) Explanation of the Rationale: The Project would include a mix of commercial and residential development that would be at a greater intensity and density in both height and area, as compared to existing conditions. However, the Project is not located within or near a scenic vista, as defined by the City’s GP Conservation Element. The Santa Ana River is located approximately 2.5 miles to the west of the Project site; Santiago Creek is located approximately 4.6 miles north of the Project site. The Project activities would be limited to the boundaries of the project site. Therefore, the Project would not have a substantial adverse effect on a scenic vista. Impacts would be less than significant. (Draft Supplemental EIR, pp. 5-5 – 5-6.) Threshold AE-2: The Project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.

Findings: The City finds that the Project would result in no impact to aesthetics related to scenic resources within a state scenic highway. (Draft Supplemental EIR, p. 5-6.) Explanation of the Rationale: The GPU PEIR states that no state scenic highways, eligible or officially designated, traverse the City nor are located near the City. Though buildout consistent with the GPU would lead to infill development and intensify the urban landscape, it would not damage scenic resources, including rock outcroppings, trees, and historic buildings within state scenic highways. There are no eligible or state designated scenic highways in the vicinity of the Project site. Therefore, the Project would not impact scenic resources within a state scenic highway, and there would be no impact. (Draft Supplemental EIR, p. 5-6.) Threshold AE-3: The Project would not conflict with applicable zoning and other regulations governing scenic quality.

Findings: The City finds that the Project would result in less than significant impacts to aesthetics and would not conflict with applicable zoning and other regulations governing scenic quality. (Draft Supplemental EIR, pp. 5-6 – 5-7.)
City Council 28 – 52 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-2
Explanation of the Rationale: The Project site has a General Plan land use designation of DC5, which is intended to provide urban retail, residential, mixed-use, and employment centers with an intensity of up to 5.0 floor area ratio and/or 125 dwelling units per acre, and a maximum height of 25 stories. The Project would be consistent with this land use designation and development standards, as it would include mixed-use commercial and residential buildings ranging up to 25 stories with an intensity of up to 5.0 floor area ratio and 125 dwelling units per acre. The Project site is currently zoned as SD-48; however, the project’s specific plan would replace SD-48 as the zoning for The Village and would contain the development standards, permitted uses, and administrative processes for future development at the Project site.

As the Project would be designed with a cohesive style that is compatible with its surrounding development, the Project would support the existing visual character of the Project area.

Therefore, the Project would not conflict with applicable zoning and other regulations governing scenic quality, and impacts would be less than significant. (Draft Supplemental EIR, pp. 5-6 – 5-7.)
Threshold AE-4: The Project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

Findings: The City finds that the Project would result in less than significant impacts to aesthetics related to light and glare. (Draft Supplemental EIR, pp. 5-7 – 5-8.) Explanation of the Rationale: The Project would intensify development at the Project site both horizontally and vertically, with a mix of residential, commercial, office, parking, and open space uses. Thus, the Project would result in additional sources of light, such as building lighting, landscape lighting, lighting along pedestrian pathways, security lighting, and parking lot lighting.

In addition, the Project would result in additional sources of glare due to light reflecting off parked or traveling cars and building windows. However, the Project would utilize lighting that is typical of the existing and surrounding developments. In addition, similar to development under the GPU, the Project would be required to comply with the Title 24 Standards as amended by the Santa Ana Municipal Code Chapter 8, Article II and the City’s Lighting Standards (Section 5 of the City’s Engineering Standards and Plans). In addition, the specific plan specifies implementation of the exterior and landscape lighting design requirements. Therefore, because the Project would comply with applicable regulations and implement lighting design criteria, the Project would not adversely affect day or nighttime views in the area and impacts would be less than significant. (Draft Supplemental EIR, pp. 5-7 – 5-8.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning aesthetics.

Findings: The City finds that the Project would result in less than significant cumulative impacts to aesthetics. (Draft Supplemental EIR, pp. 5-5 – 5-8.) Explanation of the Rationale: The Project is a mixed-use project located on an infill site. The Project would include development that would be at a greater intensity and density in both height and area, as well as additional sources of light, as compared to existing conditions. However, the Project is not located within or near a scenic vista, would not substantially damage scenic resources, and would be consistent with land use designation and development standards.

City Council 28 – 53 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-3
Therefore, cumulative impacts related to aesthetics would be less than significant. (Draft Supplemental EIR, pp. 5-5 – 5-8.)

4.2 AGRICULTURE AND FORESTRY RESOURCES
Threshold AF-1: The Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural uses.

Findings: The City finds that the Project would result in no impact to agriculture and forestry resources related to the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. (Draft Supplemental EIR, p. 5-8.) Explanation of the Rationale: According to the California Department of Conservation’s California Important Farmland Finder mapping tool, the Project site and surrounding uses are designated as “Urban and Built-Up Land.” Therefore, no farmland exists on the Project site and the Project would not convert farmland to non-agricultural use. (Draft Supplemental EIR, p. 5-8.) Threshold AF-2: The Project would not conflict with existing zoning for agricultural use, or a Williamson Act contract.

Findings: The City finds that the Project would result in no impact to agriculture and forestry resources related to conflict with existing zoning for agricultural use, or a Williamson Act contract. (Draft Supplemental EIR, p. 5-8.)
Explanation of the Rationale: The Project site is zoned for Specific Development (SD-48), which does not allow for agricultural use. Additionally, according to the California Department of Conservation’s California Williamson Act Enrollment Finder mapping tool, Orange County does not have any land subject to a Williamson Act Contract. Therefore, the Project would not conflict with existing zoning for agricultural use or with a Williamson Act contract. (Draft Supplemental EIR, p. 5-8.)
Threshold AF-3: The Project would not conflict with existing zoning for, or cause rezoning of, forestland, timberland, or timberland zoned Timberland Production.

Findings: The City finds that the Project would result in no impact to agriculture and forestry resources related to conflict with existing zoning for, or rezoning of, forestland, timberland, or timberland zoned Timberland Production. (Draft Supplemental EIR, p. 5-9.) Explanation of the Rationale: The City does not have any land designated or zoned for forestland, timberland, or timberland zoned Timberland Production. The Project site is zoned for Specific Development (SD-48), which does not allow for forestland or timberland uses. Therefore, the Project would not conflict with existing zoning for forestland or timberland uses. (Draft Supplemental EIR, p. 5-9.)
Threshold AF-4: The Project would not result in the loss of forestland or conversion of forest land to non-forest use.

City Council 28 – 54 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-4
Findings: The City finds that the Project would result in no impact to agriculture and forestry resources related to the loss of forestland or conversion of forest land to non-forest use. (Draft Supplemental EIR, p. 5-9.)
Explanation of the Rationale: The GPU PEIR states that the City does not have any land designated or zoned for forestland. The Project site is currently developed with existing commercial retail and surface parking lot uses and does not contain any forest land. Therefore, the Project would not result in the loss of forest land or convert forest land to non-forest use. (Draft Supplemental EIR, p. 5-9.)
Threshold AF-5: The Project would not involve other changes in the existing environment, which, due to their location or nature, could result in conversion of Farmland to nonagricultural use or conversion of forestland to nonforest use.

Findings: The City finds that the Project would result in no impact to agriculture and forestry resources related to other changes in the existing environment which could result in conversion of Farmland to nonagricultural use or conversion of forestland to non-forest use. (Draft Supplemental EIR, p. 5-9.)
Explanation of the Rationale: The City does not have any significant agricultural resources or land designated or zoned for forestland, timberland, or timberland zoned Timberland Production.

The Project site and vicinity are designated as “Urban and Built-Up Land,” and no farmland exists on the Project site or surrounding uses. Therefore, the Project would not convert farmland or forest land to non-agricultural or non-forest use. (Draft Supplemental EIR, p. 5-9.) Cumulative Impacts: The Project would not result in cumulative impacts concerning agriculture and forestry resources.

Findings: The City finds that the Project would result in no cumulative impacts concerning agriculture and forestry resources. (Draft Supplemental EIR, pp. 5-8 – 5-9.) Explanation of the Rationale: The City does not have any significant agricultural resources or land designated or zoned for forestland, timberland, or timberland zoned Timberland Production.

Additionally, Orange County does not have any land subject to the Williamson Act Contract. The Project site and vicinity are designated as “Urban and Built-Up Land,” and no agriculture or forestry resources exists on the Project site or surrounding uses. (Draft Supplemental EIR, pp. 5- 8 – 5-9.)

4.3 AIR QUALITY
Threshold AQ-4: The Project would not result in other emissions, such as those leading to odors, adversely affecting a substantial number of people.

Findings: The City finds that the Project would result in less than significant impacts to air quality related to other emissions, such as odors. (Draft Supplemental EIR, pp. 4.1-47 – 4.1-48.) City Council 28 – 55 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-5
Additionally, the City finds that the Project will implement the following regulatory requirements (Draft Supplemental EIR, p. 4.1-9):

RR AQ-2: Construction activities will be conducted in compliance with California Code of Regulations, Title 13, Section 2449, which requires that nonessential idling of construction equipment is restricted to five minutes or less.

RR AQ-3: Construction activities will be conducted in compliance with any applicable South Coast Air Quality Management District rules and regulations, including but not limited to:
• Rule 403, Fugitive Dust, for controlling fugitive dust and avoiding nuisance. • Rule 402, Nuisance, which states that a project shall not “discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.”
• Rule 1113, which limits the volatile organic compound content of architectural coatings.
• Rule 1466, Soil Disturbance. Projects that involve earth-moving activities of more than 50 cubic yards of soil with applicable toxic air contaminants are subject to this rule.

Explanation of the Rationale: Construction activities associated with the Project may generate detectable odors from heavy-duty equipment exhaust and architectural coatings. However, construction-related odors would be short-term in nature and cease upon completion of construction activities. According to the Odor Complaints, Health Impacts, and Monitoring Methods prepared for the California Air Resources Board, odors typically come from industrial facilities, including wastewater treatment plants, municipal solid waste landfills, trash transfer stations, composting facilities, animal agriculture, chemical and petroleum industries, and roadkill collection facilities. The Project would not include any of these uses or odor sources. Because the Project would include restaurants, there is the potential for uses within the immediate area to experience odors associated with restaurant operations. However, the Project comply with SCAQMD Rule 402 (Nuisance), which prohibits emission of any material that causes nuisance to a considerable number of persons or endangers the comfort, health, or safety of any person.

Compliance with SCAQMD Rule 402 would ensure potential restaurant-related odors during Project operation would not create objectionable odors affecting a substantial number of people, and impacts related to odors during Project operation would be less than significant. (Draft Supplemental EIR, pp. 4.1-47 – 4.1-48.)
City Council 28 – 56 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-6

4.4 BIOLOGICAL RESOURCES
Threshold B-1: The Project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S.

Fish and Wildlife Service.

Findings: The City finds that the Project would result in less than significant impacts to biological resources related to species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service. (Draft Supplemental EIR, pp. 5-9 – 5-10.) Explanation of the Rationale: The Project site is fully developed with existing commercial uses and surface parking, and the surrounding area is heavily urbanized with residential and commercial uses. The Project would involve infill development within an already highly disturbed urban environment. The Project site includes limited, ornamental landscaping, including grass lawns and trees. Due to the urbanized nature of the project site and surrounding area, there are no natural, vegetated areas that could support candidate, sensitive, or special status species, or habitat for such species. However, the existing trees on-site may provide habitat to nesting birds, which are protected pursuant to the federal Migratory Bird Treaty Act of 1918 (MBTA) and the California Fish and Game Code. The Project would comply with all applicable federal, state, and local regulations including the MBTA and the California Fish and Game Code Section 3503, which protect nesting birds and their eggs/young. To maintain compliance with the MBTA and California Fish and Game Code, clearance surveys would be conducted prior to any ground disturbance or vegetation removal activities to avoid direct or indirect impacts to active bird nests and/or nesting birds if construction occurs during the nesting bird season. Therefore, the Project would not result in direct impacts to special-status species identified as a candidate, sensitive, or special-status species and impacts would be less than significant. (Draft Supplemental EIR, pp. 5-9 – 5-10.) Threshold B-2: The Project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

Findings: The City finds that the Project would result in no impact to biological resources related to a substantial adverse effect on any riparian habitat or other sensitive natural community. (Draft Supplemental EIR, pp. 5-10 – 5-11.)
Explanation of the Rationale: The Project site is fully developed with commercial retail uses and contains limited, ornamental landscaping. The ground cover consists primarily of paved, developed areas and limited areas of vegetation, including trees and grass. There is no riparian habitat or other sensitive natural communities within the Project site. Therefore, implementation of the Project would not impact any riparian habitat or other sensitive natural community. (Draft Supplemental EIR, pp. 5-10 – 5-11.)
City Council 28 – 57 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-7
Threshold B-3: The Project would not have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

Findings: The City finds that the Project would result in no impact to biological resources related to state or federally protected wetlands. (Draft Supplemental EIR, p. 5-11.) Explanation of the Rationale: Based on a review of the U.S. Fish and Wildlife Service National Wetlands Inventory, there are no wetlands within the Project site. Furthermore, no potential jurisdictional drainages or wetland features were observed within Project site. The National Wetlands Inventory identifies several wetland features in the Project vicinity. However, these wetland habitats are engineered and man-made, and the Project would not impact these nearby wetland features. Therefore, the Project would not have a substantial adverse effect on state or federally protected wetlands, and no impact would occur. (Draft Supplemental EIR, p. 5-11.) Threshold B-4: The Project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

Findings: The City finds that the Project would result in less than significant impacts to biological resources related to interfering with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impeding the use of native wildlife nursery sites. (Draft Supplemental EIR, pp. 5-11 – 5.12.) Explanation of the Rationale: The Project site is located approximately 2.4 miles east of the Santa Ana River, and 5.2 miles south of Santiago Creek. As such, the Project would not result in impacts to either of these corridors. In addition, the Project site is not located within any wildlife corridors, as it is fully developed and surrounded by urban land uses that provide minimal to no opportunities for movement of wildlife. The Project would remove ornamental trees at the Project site, which may provide suitable nesting habitat for birds protected under the MBTA. To maintain compliance with the MBTA and California Fish and Game Code Section 3503, clearance surveys would be conducted prior to any ground disturbance or vegetation removal activities to avoid direct or indirect impacts to active bird nests and/or nesting birds if construction occurs during the nesting bird season. With compliance to the requirements of the MBTA, any direct or indirect impacts on nesting birds would be reduced to a less than significant level. (Draft Supplemental EIR, pp. 5-11 – 5.12.)
Threshold B-5: The Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

Findings: The City finds that the Project would result in less than significant impacts to biological resources related to local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. (Draft Supplemental EIR, p. 5-12.) City Council 28 – 58 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-8
Explanation of the Rationale: The Project would remove a number of existing trees within the rights-of-way. The Project would adhere to the following sections of the Municipal Code, which contains codes that pertain to trees within parkways and rights-of-way: Section 33-191 Damaging City Trees, Section 33-185 Street Tree Species to be Planted, and Section 33-188 Site Plan Approval, as well as Article VII, Regulation for the Planting, Maintenance, and Removal of Trees.

Therefore, the Project would not conflict with applicable tree policies. (Draft Supplemental EIR, p. 5-12.)
Threshold B-6: The Project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

Findings: The City finds that the Project would result in no impact to biological resources related to conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. (Draft Supplemental EIR, p. 5-12.)
Explanation of the Rationale: The City of Santa Ana is not located within a Habitat Conservation Plan or Natural Community Conservation Plan area. Therefore, the Project would not conflict with applicable Habitat Conservation Plans or Natural Community Conservation Plans, and no impact would occur. (Draft Supplemental EIR, p. 5-12.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning biological resources.

Findings: The City finds that the Project would result in less than significant cumulative impacts to biological resources. (Draft Supplemental EIR, pp. 5-9 – 5-12.) Explanation of the Rationale: The Project site is fully developed with existing commercial uses and surface parking, and the surrounding area is heavily urbanized with residential and commercial uses. The Project would involve infill development within an already highly disturbed urban environment. The Project would result in no impacts related to sensitive natural communities; federally protected wetlands; and conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan; and less-than-significant impacts related to candidate, sensitive, or special status species; migratory fish or wildlife species or wildlife corridors; and conflict with local policies or ordinances protecting biological resources. Therefore, cumulative impacts related to biological resources would be less than significant. (Draft Supplemental EIR, pp. 5-9 – 5-12.)

4.5 CULTURAL RESOURCES
Threshold C-1: The Project would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.

Findings: The City finds that the Project would result in no impact related to a substantial adverse change in the significance of a historical resource. (Draft Supplemental EIR, pp. 4.2-13 – 4.2-14.) City Council 28 – 59 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-9
Explanation of the Rationale: A records search conducted for the Project indicated a total of three cultural resources are documented within the half-mile search radius of the Project site.

However, none of these resources are located within or adjacent to the Project area, and no built environment resources within the project area were identified in the Built Environment Resource Directory. Additionally, the existing South Coast Village was evaluated for listing on the California Register of Historical Resources in accordance with Section 15064.5(a)(2)-(3) of the State CEQA Guidelines, and is recommended ineligible for listing in the California Register. Therefore, the Project would not cause a substantial adverse change in the significance of a historical resource and no impact would occur. (Draft Supplemental EIR, pp. 4.2-13 – 4.2-14.) Threshold C-3: The Project would not disturb any human remains, including those interred outside of dedicated cemeteries.

Findings: The City finds that the Project would result in less than significant impacts to cultural resources related to human remains. (Draft Supplemental EIR, pp. 4.2-16 – 4.2-17.) Additionally, the City finds that the Project will implement the following regulatory requirement (Draft Supplemental EIR, p. 4.2-5):

RR CUL-1: California Health and Safety Code Section 7050.5 requires that if human remains are discovered within the proposed project site, disturbance of the site shall halt and remain halted until the coroner has investigated the circumstances, manner, and cause of any death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation, or to his or her authorized representative. If the coroner determines that the remains are not subject to his or her authority and if the coroner recognizes or has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.

Explanation of the Rationale: Sensitivity for buried human remains would be low at the Project site, as the Project site does not contain cemeteries or known burial grounds, and past construction activities have disturbed the entire property. However, as the Project would require excavations that are anticipated to disturb a large part of the Project site at varying depths up to a maximum depth of 52 feet for the subsurface parking garage, there is potential to encounter previously unknown human remains. In the event that human remains are discovered, the remains would be treated in accordance with California Health and Safety Code Section 7050.5 (RR CUL-1), State CEQA Guidelines Section 15064.5, and Public Resources Code Section 5097.98. Compliance with these regulations would ensure that impacts to human remains would be less than significant. (Draft Supplemental EIR, pp. 4.2-16 – 4.2-17.) City Council 28 – 60 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-10

4.6 ENERGY
Threshold E-1: The Project would not result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.

Findings: The City finds that the Project would result in no impact to energy related to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. (Draft Supplemental EIR, pp. 4.3-11 – 4.2-18.) Additionally, the City finds that the Project will implement the following regulatory requirements (Draft Supplemental EIR, p. 4.3-4):

RR E-1: Construction activities will be conducted in compliance with California Code of Regulations Section 2485, which requires that nonessential idling of construction equipment be restricted to five minutes or less.

RR E-2: At least 65 percent of all nonhazardous construction and demolition waste from nonresidential construction associated with future development in the plan area shall be recycled and/or salvaged for reuse in line with the 2016 California Green Building Standards Code Section 5.408 (California Code of Regulations, Title 24, Part 11).

RR E-3: New buildings implemented as part of the General Plan Update are required to achieve the current California Building Energy and Efficiency Standards (California Code of Regulations, Title 24, Part 6) and California Green Building Standards Code (California Code of Regulations, Title 24, Part 11).

RR E-4: Any appliances associated with development in the Plan Area shall meet the requirements of the 2012 Appliance Efficiency Regulations.

RR E-5: Development under the General Plan Update shall support the goals of the renewables portfolio standard, SB 350, and SB 100 to achieve a tiered increase in the use of renewable energy to 60 percent by 2030, and 100 percent by 2045.

RR E-7: Development under the General Plan Update shall be in compliance with state and local solid waste regulations including AB 939, AB 341, AB 1327, AB 1826, and Section 5.408 of 2016 California Green Building Standards Code (California Code of Regulations, Title 24, Part 11).

Explanation of the Rationale: The Project’s annual average fuel consumption from gasoline construction vehicle use during Phase 4 (phase with most gasoline consumption) would account for 0.299 percent of the City’s forecasted consumption of gasoline fuel and 0.029 percent of the County’s annual gasoline consumption. Additionally, the Project’s annual average fuel consumption from diesel construction equipment use during Phase 1 (phase with most diesel consumption) would account for 0.166 percent of the City’s forecasted consumption of diesel fuel and 0.225 percent of the County’s annual diesel consumption. As such, construction would have a nominal effect on the local and regional energy supplies. Additionally, the Project would comply with regulatory requirements, such as the 2022 CalGreen Code, USEPA Construction Equipment Fuel Efficiency Standard, and California Code of Regulations Title 13, Sections 2449 and 2485.

City Council 28 – 61 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-11
Therefore, construction fuel consumption would not be any more inefficient, wasteful, or unnecessary than other similar development projects.

The Project’s operational automotive transportation at full buildout is estimated to result in a net increase that would account for 0.493 percent of the City and 0.053 percent of the County’s forecasted annual consumption of fuel for the buildout year of 2045. As such, the Project would account for a nominal percentage of the forecasted annual operational automotive fuel consumption for both the City and County and, thus, would have a nominal effect on the local and regional energy supplies. The Project’s operational energy consumption at full buildout would result in a net increase of approximately 0.602 percent in electricity consumption and approximately 0.309 percent in natural gas consumption of the City’s consumption in for the buildout year of 2045. The Project would also be required to comply with the most current and applicable version of the Title 24 Building Energy Efficiency Standards and CALGreen Code.

Overall, the Project would account for a nominal energy consumption percentage of the City and County’s annual energy consumption. Therefore, the Project would not result in a significant increase in construction and operational energy consumption. As such, impacts resulting from the Project would be less than significant. (Draft Supplemental EIR, pp. 4.3-11 – 4.2-18.) Threshold E-2: The Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Findings: The City finds that the Project would result in less than significant impacts to energy related to conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Draft Supplemental EIR, pp. 4.3-19 – 4.3-23.)
Explanation of the Rationale: The Project would comply with the State and regional plans for renewable energy and energy efficiency. State and regional plans for renewable energy and energy efficiency include the California Energy Commission’s Integrated Energy Policy Report and Title 24 standards, including the CALGreen Code. The Project would meet the most current and latest Title 24 standards for energy efficiency and incorporate all applicable energy efficiency measures (solar panels, high efficiency lighting, energy efficient appliances, etc.). Compliance with Title 24 standards, including the CALGreen Code, would ensure the Project’s consistency with the Integrated Energy Policy Report building energy efficiency recommendations, which would, in turn, ensure project conformance with the State’s energy reduction goals. The Project would also comply with applicable energy goals and policies in the GPU. As such, impacts resulting from the Project related to consistency with adopted energy conservation plans or state/local energy standards for renewable energy or energy efficiency would be less than significant. (Draft Supplemental EIR, pp. 4.3-19 – 4.3-23.) Cumulative Impacts: The Project would not result in cumulative impacts concerning energy.

Findings: The City finds that the Project would result in less than significant cumulative impacts related to energy. (Draft Supplemental EIR, pp. 4.3-24 – 4.3-26.) Explanation of the Rationale: The Project’s electricity demand would not significantly increase Southern California Edison’s total electricity demand for its service population, and the Project’s natural gas demand would be nominal compared to SoCalGas’ total natural gas demand for its service population. The Project transportation fuel usage would represent a small percentage of total fuel consumption within Orange County. In addition, the Project would not cause any new or City Council 28 – 62 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-12
additional significant cumulative impacts related to consistency with adopted energy conservation plans or state/local energy standards for renewable energy or energy efficiency. Therefore, cumulative impacts related to energy were determined to be less than significant. (Draft Supplemental EIR, pp. 4.3-24 – 4.3-26.)

4.7 GEOLOGY AND SOILS
Threshold G-1(i): The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault.

Findings: The City finds that the Project would result in less than significant impacts to geology and soils related to rupture of a known earthquake fault. (Draft Supplemental EIR, p. 4.4-9.) Additionally, the City finds that the Project will implement the following regulatory requirements (Draft Supplemental EIR, pp. 4.4-3 – 4.4-4):

RR G-1: Every public agency enforcing building regulations must adopt the provisions of the California Building Code (CBC), which is Title 24, Part 2 of the California Code of Regulations. The most recent version is the 2019 CBC (effective January 1, 2020).1 The CBC is updated every three years and provides minimum standards to protect property and public safety by regulating the design and construction of excavations, foundations, building frames, retaining walls, and other building elements to mitigate the effects of seismic shaking and adverse soil conditions. The CBC also contains provisions for earthquake safety based on factors including occupancy type, the types of soil and rock on-site, and the strength of ground shaking with specified probability of occurring at a site.

RR G-2: Santa Ana Municipal Code, Chapter 8, Buildings and Structures. These codes address grading standards, excavation, and fills. This also includes compliance with regulations for unreinforced masonry structures in accordance with “Unreinforced Masonry Law,” found in California Government Code §§ 8875 et seq. The City of Santa Ana Building Official may place additional requirements upon the construction of infrastructure, buildings, and other improvements based on the findings from plan check, soils testing, and geotechnical investigations.

Explanation of the Rationale: There are no known active faults located within or adjacent to the Project site. The Project site is also not located within an Alquist-Priolo Fault Rupture Hazard Zone. Therefore, the potential for primary ground rupture of a known earthquake fault is considered very low at the Project site. Moreover, earthquake fault zones are existing environmental conditions and the Project would not exacerbate the risk of earthquake faults.

Impacts related to rupture of a known earthquake fault would be less than significant. (Draft Supplemental EIR, p. 4.4-9.)
Threshold G-1(iv): The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides.

Findings: The City finds that the Project would result in less than significant impacts to geology and soils related to landslides. (Draft Supplemental EIR, p. 4.4-13).

City Council 28 – 63 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-13
Explanation of the Rationale: The project site is not located within a zone of earthquake induced landslide. Additionally, similar to the overall City topography, the project site is relatively flat; thus, there would be no hazards related to slope stability. (Draft Supplemental EIR, p. 4.4-13.) Threshold G-2: The Project would not result in substantial soil erosion or the loss of topsoil.

Findings: The City finds that the Project would result in less than significant impacts to geology and soils related to substantial soil erosion or the loss of topsoil. (Draft Supplemental EIR, pp. 4.4-13 – 4.4-14).

Explanation of the Rationale: Construction of the Project would result in ground surface disturbance during excavation and grading that could create the potential for erosion of soils to occur. During construction, transport of sediments by stormwater runoff and wind would be prevented through BMPs, such as implementation of Rule 403 dust control measures required by the South Coast Air Quality Management District and a Storm Water Pollution Prevention Plan for construction activities. In addition, the proposed addition of open space and expanded landscaping would result in less impervious area compared to existing conditions, reducing the potential for runoff and soil erosion. Therefore, with implementation of a project-specific Storm Water Pollution Prevention Plan, associated BMPs during construction, and installation of landscaping and open space to stabilize soils throughout the Project site, the Project would not result in substantial soil erosion or the loss of topsoil and impacts would be less than significant. (Draft Supplemental EIR, pp. 4.4-13 – 4.4-14.)
Threshold G-5: The Project would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater.

Findings: The City finds that the Project would result in no impact to geology and soils related to the use of septic tanks or alternative wastewater disposal systems. (Draft Supplemental EIR, p. 4.4-18.)
Additionally, the City finds that the Project will implement the following regulatory requirement (Draft Supplemental EIR, p. 4.4-4):

RR G-3: Santa Ana Municipal Code Section 39-51 requires that all buildings or structures within the city that require plumbing fixtures must be connected to a public sewer.

Explanation of the Rationale: The Project would not use septic tanks or alternative wastewater disposal systems. Sanitary wastewater at the project site is handled through connections to the existing sanitary sewer system. No impact would occur. (Draft Supplemental EIR, p. 4.4-18.)

4.8 GREENHOUSE GAS EMISSIONS
Threshold GHG-1: The Project would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

Findings: The City finds that the Project would result in less than significant impacts to greenhouse gases emissions. (Draft Supplemental EIR, pp. 4.5-18 – 4.5-23.) City Council 28 – 64 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-14
Additionally, the City finds that the Project will implement the following regulatory requirement (Draft Supplemental EIR, p. 4.5-7):

RR GHG-1: New buildings are required to achieve the current California Building Energy Efficiency Standards (Title 24, Part 6) and California Green Building Standards (CALGreen) Code (Title 24, Part 11). The 2019 Building Energy Efficiency Standards became effective January 1, 2020. The Building and Energy Efficiency Standards and CALGreen are updated tri-annually.

RR GHG-2: Construction activities are required to adhere to California Code of Regulations, Title 13, Section 2449, which restricts the nonessential idling of construction equipment to five minutes or less.

RR GHG-3: New buildings are required to adhere to the California Green Building Standards Code and Water Efficient Landscape Ordinance requirements to increase water efficiency and reduce urban per capita water demand.

RR GHG-7: The California Green Building Standards Code (CALGreen) requires the recycling and/or salvaging for reuse at minimum of 65 percent of the nonhazardous construction and demolition waste generated during most “new construction” projects (CALGreen Code §§ 4.408 and 5.408). Construction contractors are required to submit a construction waste management plan that identifies the construction and demolition waste materials to be diverted from disposal by recycling, reuse on the project, or salvaged for future use or sale and the amount (by weight or volume).

Explanation of the Rationale: The net increase in emissions from the Project compared to existing conditions is 1.40 MTCO2e per year. Compared to the GPU horizon year emissions per service population of 3.5 MTCO2e per year, the Project would result in a less severe impact. The Project would be consistent with the 2022 Scoping Plan, 2020-2045 RTP/SCS, City of Santa Ana General Plan, and the City’s Climate Action Plan. As the Project is consistent with these GHG reduction plans, the Project would also be consistent with the State’s long-term goal to achieve statewide carbon neutrality (zero-net emissions). Specifically, the Project would be consistent with several GPU goals and policies that may reduce GHG emissions, including goals and policies from the Conservation Element related to air quality and climate, energy resources, and water resources, and those from the Mobility Element related to sustainable transportation design.

Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.5-18 – 4.5-23.) Threshold GHG-2: The Project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Findings: The City finds that the Project would result in less than significant impacts to greenhouse gases emissions related to conflict with an applicable plan, policy or regulation.

Additionally, the City finds that the Project will implement regulatory requirements RR GHG-1 through RR GHG-3 and RR GHG-7 (listed above). (Draft Supplemental EIR, pp. 4.5-23 – 4.5-34.) Explanation of the Rationale: The Project’s characteristics render it consistent with Statewide, regional, and local climate change mandates, plans, policies, and recommendations. More City Council 28 – 65 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-15
specifically, the GHG plan consistency analysis provided above demonstrates that the Project would comply with the regulations and GHG reduction goals, policies, actions, and strategies outlined in the 2022 Scoping Plan, 2020-2045 RTP/SCS, and the City’s GPU and Climate Action Plan. Consistency with these plans would reduce the impact of the Project’s incremental contribution to GHG emissions. Accordingly, the Project would not conflict with any applicable plan, policy, regulation, or recommendation adopted for the purpose of reducing GHG emissions.

Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.5-23 – 4.5-34.) Cumulative Impacts: The Project would not result in cumulative impacts concerning greenhouse gas emissions.

Findings: The City finds that the Project would result in less than significant cumulative impacts concerning greenhouse gas emissions. Additionally, the City finds that the Project will implement regulatory requirements RR GHG-1 through RR GHG-3 and RR GHG-7 (listed above). (Draft Supplemental EIR, pp. 4.5-34 – 4.5-35.)
Explanation of the Rationale: State CEQA Guidelines Section 15183.5(b) states that compliance with GHG related plans can support a determination that a project’s cumulative effect is not cumulatively considerable. The Project would be consistent with the 2022 Scoping Plan, the 2020-2045 RTP/SCS, the City of Santa Ana General Plan, and the City’s Climate Action Plan.

As the Project is consistent with these GHG reduction plans, the Project would also be consistent with the State’s long-term goal to achieve carbon neutrality (zero-net emissions). Impacts related to the generation of GHGs and consistency with an applicable GHG plan would be less than significant. Therefore, the Project’s contribution to cumulative impacts related to GHGs would not be cumulatively considerable. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.5-34 – 4.5-35.)

4.9 HAZARDS AND HAZARDOUS MATERIALS
Threshold H-1: The Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

Findings: The City finds that the Project would result in less than significant impacts to hazards and hazardous materials related to routine transport, use, or disposal of hazardous materials. (Draft Supplemental EIR, pp. 4.6-17 – 4.6-19.)
Additionally, the City finds that the Project will implement the following regulatory requirement (Draft Supplemental EIR, p. 4.6-9):

RR HAZ-1: Hazardous materials and hazardous wastes will be transported to and/or from projects developed under the General Plan Update in compliance with any applicable state and federal requirements, including the U.S. Department of Transportation regulations listed in the Code of Federal Regulations (Title 49, Hazardous Materials Transportation Act); California Department of Transportation standards; and the California Occupational Safety and Health Administration standards.

City Council 28 – 66 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-16
RR HAZ-2: Hazardous waste generation, transportation, treatment, storage, and disposal will be conducted in compliance with Subtitle C of the Resource Conservation and Recovery Act (Code of Federal Regulations, Title 40, Part 263), including the management of nonhazardous solid wastes and underground tanks storing petroleum and other hazardous substances. The projects developed under the General Plan Update will be designed and constructed in accordance with the regulations of the Orange County Health Care Agency, Environmental Health Division, which serves as the designated Certified Unified Program Agency.

RR HAZ-4: Demolition activities that have the potential to expose construction workers and/or the public to asbestos-containing materials or lead-based paint will be conducted in accordance with applicable regulations, including, but not limited to:
• South Coast Air Quality Management District’s Rule 1403 • California Health and Safety Code (Section 39650 et seq.) • California Code of Regulations (Title 8, Section 1529) • California Occupational Safety and Health Administration regulations (California Code of Regulations, Title 8, Section 1529 [Asbestos] and Section 1532.1 [Lead]) • Code of Federal Regulations (Title 40, Part 61 [asbestos], Title 40, Part 763 [asbestos], and Title 29, Part 1926 [asbestos and lead]) RR HAZ-5: The removal of hazardous materials, such as polychlorinated biphenyls (PCBs), mercury-containing light ballast, and mold, will be completed in accordance with applicable regulations pursuant to 40 CFR 761 (PCBs), 40 CFR 273 (mercury-containing light ballast), and 29 CFR 1926 (molds) by workers with the hazardous waste operations and emergency response (HAZWOPER) training, as outlined in 29 CFR 1910.120 and 8 CCR 5192.

RR HAZ-6: New construction, excavations, and/or new utility lines within 10 feet or crossing existing high-pressure pipelines, natural gas/petroleum pipelines, or electrical lines greater than 60,000 volts will be designed and constructed in accordance with the California Code of Regulations (Title 8, Section 1541).

Explanation of the Rationale: The existing buildings on the project site were constructed between 1971 and 1973 and it is likely that the building materials contain asbestos-containing materials (ACMs), lead-based paint, and polychlorinated biphenyls. Surveys, testing, and abatement would be required prior to demolition of the existing buildings, in addition to proper removal and disposal, and would be conducted in accordance with the existing SCAQMD Rule 1403, California Occupational Safety and Health Administration, and California Health and Safety Code. With compliance with relevant regulations and requirements, project construction activities would not expose people to a substantial risk resulting from the release of hazardous materials into the environment. Impacts would be less than significant.

During operation, the Project would include use, storage, and disposal of hazardous materials typically associated with residential and commercial uses, including restaurants and retail stores.

City Council 28 – 67 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-17
However, as with Project construction, all hazardous materials used on the Project site during operation would be used, stored, and disposed of in accordance with manufacturer’s standards and all applicable federal, state, and local requirements. Therefore, with compliance with manufacturer’s standards and all applicable local, state, and federal laws and regulations relating to environmental protection and the management of hazardous materials, impacts associated with the routine transport, use, or disposal of hazardous materials during operation of the Project would be less than significant. (Draft Supplemental EIR, pp. 4.6-17 – 4.6-19.) Threshold H-2: The Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Findings: The City finds that the Project would result in less than significant impacts to hazards and hazardous materials related to reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Additionally, the City finds that the Project will implement regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ-4 through RR HAZ-6 (listed above). (Draft Supplemental EIR, pp. 4.6-19 – 4.6-20.) Explanation of the Rationale: The Phase I Environmental Site Assessment conducted for the Project revealed no evidence of Recognized Environmental Conditions (RECs) and/or Controlled Recognized Environmental Conditions (CRECs) in connection with the Project site. In the event that hazardous materials are found on-site during construction activities, materials would be removed in accordance with procedural requirements and regulations for the proper removal and disposal. With compliance with relevant regulations and requirements, Project construction activities would not expose people to a substantial risk resulting from the reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.6-19 – 4.6-20.) Threshold H-3: The Project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.

Findings: The City finds that the Project would result in no impacts related to hazards and hazardous materials within one-quarter mile of an existing or proposed school. Additionally, the City finds that the Project will implement regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ4 through RR HAZ-6 (listed above). (Draft Supplemental EIR, pp. 4.6-20 – 4.6-21.) Explanation of the Rationale: There are no schools within one-quarter mile of the Project site.

The closest school to the Project site is California Pacific Charter Schools, located approximately

0.3 mile to the southwest. No impacts would occur. (Draft Supplemental EIR, pp. 4.6-20 – 4.6-21.) Threshold H-4: The Project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment.

Findings: The City finds that the Project would result in no impacts to hazards and hazardous materials related to hazardous materials sites pursuant to Government Code Section 65962.5.

City Council 28 – 68 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-18
Additionally, the City finds that the Project will implement regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ-4 through RR HAZ-6 (listed above). (Draft Supplemental EIR, pp. 4.6-21 – 4.6-22.)
Explanation of the Rationale: The Project site is not included on any hazardous waste site lists included in the Department of Toxic Substances Control’s EnviroStor database, which includes CORTESE sites and the Environmental Protection Agency’s database of regulated facilities, or other lists compiled pursuant to Section 65962.5 of the Government Code. No impacts would occur. (Draft Supplemental EIR, pp. 4.6-21 – 4.6-22.)
Threshold H-5: The Project would not result in a safety hazard or excessive noise for people residing or working in the project area within two miles of a public airport or public use airport.

Findings: The City finds that the Project would result in no impacts to hazards and hazardous materials related to airports. (Draft Supplemental EIR, pp. 4.6-22 – 4.6-23.) Additionally, the City finds that the Project will implement regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ-4 through RR HAZ-7 (listed above) and the following regulatory requirement (Draft Supplemental EIR, p. 4.6-9):

RR HAZ-7: Development will be designed and constructed in accordance with the airport environs land use plan for John Wayne Airport. Building height restrictions, as specified in the airport environs land use plan, would apply in the city.

Explanation of the Rationale: The Project site is located approximately 1.5 miles northwest of Santa Ana Airport (SNA) and outside any SNA Safety Compatibility Zones (including the Runway Protection Zones) and the 60 dbA CNEL noise contours. Therefore, the Project would not result in a safety hazard or excessive noise for people residing or working in the Project area. Further, the Project site is located within the Airport Environs Land Use Plan Notification Area for SNA, which includes the Federal Aviation Regulations Part 77 Notification Area. The Project is required to be submitted to the Federal Aviation Agency (FAA) and the Orange County Airport Land Use Commission for aeronautical review. Upon completion of the review process, the project would not result in a safety hazard or excessive noise for people residing or working in the Project area.

No impact would occur. (Draft Supplemental EIR, pp. 4.6-22 – 4.6-23.) Threshold H-6: The Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

Findings: The City finds that the Project would result in less than significant impacts to hazards and hazardous materials related to an adopted emergency response plan or emergency evacuation plan. Additionally, the City finds that the Project will implement regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ-4 through RR HAZ-7 (listed above). (Draft Supplemental EIR, pp. 4.6-23 – 4.6-24.)
Explanation of the Rationale: The Project would introduce new residential units, retail, and office uses to a site that currently only includes retail uses. During construction of the Project, while it is expected that the majority of construction activities would be confined to the Project site, limited City Council 28 – 69 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-19
off site construction activities may occur in adjacent street rights-of-way intermittently, which could potentially require partial, temporary lane closures. However, if temporary lane closures are necessary, the remaining travel lanes would remain open in accordance with standard traffic control plans that would be submitted to and reviewed by the City’s Public Works Agency Development Engineering staff, which would ensure adequate circulation and emergency access.

Upon completion of construction activities, all travel lanes would be restored to preexisting conditions.

Operation of the Project would generate traffic in the Project site vicinity and would result in some modifications to the Project site’s access. However, public and private roadways throughout the Project site would be designed to accommodate emergency vehicles for fire, ambulance, and police services. The roadways would not have restricted access such as gates that would prevent emergency vehicles from reaching the intended destinations. Roadway improvements and new roadway construction would be constructed in accordance with the Orange County Fire Authority standards and code requirements. Therefore, the Project would not physically interfere with or impair the implementation of the City’s emergency response plan. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.6-23 – 4.6-24.) Threshold H-7: The Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.

Findings: The City finds that the Project would result in no impacts to hazards and hazardous materials related to wildland fires. Additionally, the City finds that the Project will implement regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ-4 through RR HAZ-7 (listed above). (Draft Supplemental EIR, pp. 4.6-24.)
Explanation of the Rationale: The Project site is located in an urban, developed area within the City and is surrounded by commercial and multi-family residential uses. No wildlands occur within or near the Project site. No impacts related to risk of wildland fires would occur. (Draft Supplemental EIR, p. 4. 6-24.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning hazards and hazardous materials.

Findings: The City finds that the Project would result in less than significant cumulative impacts concerning hazards and hazardous materials. Additionally, the City finds that the Project will implement regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ-4 through RR HAZ-7 (listed above). (Draft Supplemental EIR, pp. 4.6-25 – 4.6-26.)
Explanation of the Rationale: As with the Project, related projects would require evaluation for potential threats to public safety, including those associated with the use, storage, and/or disposal of hazardous materials and would be required to comply with all applicable local, state, and federal laws, rules and regulations. Because environmental safety issues are largely site-specific, this evaluation would occur on a case-by-case for each individual project affected, in conjunction with development proposals on these properties. The Project would result in less than significant impacts related to hazards and hazardous materials. Therefore, the Project’s impacts related to hazards and hazardous materials would not be cumulatively considerable, and cumulative City Council 28 – 70 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-20
impacts to hazards and hazardous materials would be less than significant. (Draft Supplemental EIR, pp. 4.6-25 – 4.6-26.)

4.10 HYDROLOGY AND WATER QUALITY
Threshold HYD-1: The Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.

Findings: The City finds that the Project would result in less than significant impacts to hydrology and water quality related to water quality standards or waste discharge requirements violations. (Draft Supplemental EIR, pp. 4.7-11 – 4.7-14.)
Additionally, the City finds that the Project will implement the following regulatory requirement (Draft Supplemental EIR, pp. 4.7-5 – 4.7-6):

RR HYD-1: All development pursuant to the General Plan Update shall comply with the requirements of the Construction General Permit (Order No. 2022-0057-DWQ) for stormwater discharges associated with construction activity. Compliance requires filing a Notice of Intent, a Risk Assessment, a Site Map, a Storm Water Pollution Prevention Plan and associated best management practices, an annual fee, and a signed certification statement.

RR HYD-4: All development pursuant to the General Plan Update shall comply with the requirements of the Orange County MS4 Permit (Order R8-2009-0030, NPDES No.

CAS618030, as amended by Order No. R8-2010-0062). The MS4 Permit requires new development and redevelopment projects to:
• Control contaminants into storm drain systems
• Educate the public about stormwater impacts
• Detect and eliminate illicit discharges
• Control runoff from construction sites
• Implement best management practices and site-specific runoff controls and treatments for new development and redevelopment
RR HYD-5: All development pursuant to the General Plan Update shall comply with the requirements detailed in Chapter 18 Article IV of the Santa Ana Municipal Code.

Explanation of the Rationale: Construction activities associated with the Project have the potential to result in the conveyance of soils and other pollutants due to soil erosion during grading and soil stockpiling and subsequent siltation into municipal storm drains. However, construction activities would comply with requirements of the Construction General Permit (as required by RR HYD-1), including a project specific SWPPP and associated best management practices (BMPs).

Construction dewatering discharges would comply with the requirements of the Santa Ana RWQCB’s Groundwater Discharge Permit, which requires sampling and treatment measures as City Council 28 – 71 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-21
necessary to ensure groundwater discharges would not contain high levels of pollutants.

Therefore, with compliance to the Construction General Permit and Groundwater Discharge Permit, the Project would not violate water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater during construction, and constructionrelated impacts would be less than significant.

The Project’s storm drain network would be designed to match existing drainage and flow patterns to best utilize the capacities available in the existing public storm drain system. The Project would follow the requirements of the local MS4 Permit, as required by RR HYD-4, and the Orange County Technical Guidance Document and incorporate post-construction BMPs and low impact development (LID) measures in its project-specific water quality management plan (WQMP). The Project’s WQMP must be reviewed and approved by the City to ensure it complies with the local MS4 Permit and Orange County DAMP regulations. Therefore, with incorporation of typical postconstruction BMPs and LID measures and adherence to applicable permits, the Project would not violate water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater during operation, and operational impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-11 – 4.7-14.) Threshold HYD-2: The Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.

Findings: The City finds that the Project would result in less than significant impacts to hydrology and water quality related to groundwater. Additionally, the City finds that the Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft Supplemental EIR, pp. 4.7-14 – 4.7-15.)
Explanation of the Rationale: Construction of the Project would require dewatering activities due to the Project’s excavation for the proposed subterranean parking. However, dewatering activities would be temporary and would not substantially decrease groundwater supplies.

Additionally, the Project would add a projected 339 acre-feet per year (AFY) of water demand in the current year, which is approximately 1 percent of overall City water demand. The City would have sufficient supply to meet the current and projected demand of the Project during normal, single-dry, and multiple-dry years. In single-dry and multiple-dry years, thus, the Project would not substantially decrease groundwater supplies. Further, because the Project site is already developed with paved surfaces, development of the Project would not interfere with groundwater recharge. Therefore, the Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-14 – 4.7-15.)
Threshold HYD-3(i): The Project would not 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: result in substantial erosion or siltation on- or off-site.

Findings: The City finds that the Project would result in less than significant impacts to hydrology and water quality related to substantial erosion or siltation. Additionally, the City finds that the Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft Supplemental EIR, pp. 4.7-16 – 4.7-17.)
City Council 28 – 72 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-22
Explanation of the Rationale: Construction of the Project would require demolition of the existing building structures, including foundations, floor slabs, and utilities systems and excavation for subterranean parking structures which could temporarily alter the existing drainage pattern of the site and could result in flooding on- or offsite. However, drainage would be controlled because the Project would comply with the Construction General Permit and Groundwater Discharge Permit. With adherence to the applicable permits and implementation of a project-specific SWPPP and associated BMPs, construction of the project would not substantially alter the existing drainage pattern of the site or area in a manner which would result in substantial erosion or siltation on- or off-site.

The Project’s grading and storm drain network would be designed to match existing drainage and flow patterns and would integrate bio-filtration methods, pervious surfaces, and selective plant materials to encourage on-site water retention. The Project would incorporate BMPs and LID measures following the local MS4 Permit requirements (RR HYD-4) and Orange County Technical Guidance Document; comply with the Santa Ana Municipal Code (RR HYD-5) and the Construction General Permit (RR HYD-1); and prepare a WQMP to reduce impacts related to erosion or siltation. Therefore, the Project would not substantially alter the existing drainage pattern of the site or area in a manner which would result in substantial erosion or siltation on- or off-site. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-16 – 4.7-17.) Threshold HYD-3(ii): The Project would not 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 substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site.

Findings: The City finds that the Project would result in less than significant impacts to hydrology and water quality related to flooding from surface runoff. Additionally, the City finds that the Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft Supplemental EIR, pp. 4.7-17 – 4.7-18.)
Explanation of the Rationale: As previously discussed, the Project would adhere to the applicable permits and implementation of a project-specific SWPPP and associated BMPs.

Therefore, construction of the Project would not substantially alter the existing drainage pattern of the site or area in a manner which would result in substantial erosion or siltation on- or off-site.

Due to the high podium building drainage demand and the presence of multiple subterranean garage entrances, on-site drainage systems would be sized to contain the 100-year storm hydraulic grade line below the proposed finished surface to address the existing ponding issues.

The Project’s grading and storm drain network design would ensure surface runoff, including ponding water at the public driveways, would not result in flooding on- and off-site. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-17 – 4.7-18.) Threshold HYD-3(iii): The Project would not 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 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.

City Council 28 – 73 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-23
Findings: The City finds that the Project would result in less than significant impacts to hydrology and water quality related to stormwater drainage. Additionally, the City finds that the Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft Supplemental EIR, pp. 4.7-19 – 4.7-20.)
Explanation of the Rationale: As previously discussed, the Project would adhere to applicable permits (e.g., Construction General Permit and Santa Ana RWQCB’s Groundwater Discharge Permit, if necessary) and implement a project-specific SWPPP and associated BMPs; therefore, construction of the Project would not substantially alter the existing drainage pattern of the site or area in a manner which would result in substantial runoff water or polluted runoff.

The Project grading and storm drain network would be designed to match the existing drainage and flow patterns to best utilize the capacities available in the existing public storm drain system and may use underground detention systems and/or on-site drainage systems to contain excess flows. The Project site would be required to implement bio-filtration as the primary water quality treatment method. During each phase of Project development, the associated localized drainage and water quality systems dedicated to each building site would be confirmed during the design permitting phase with the City and constructed with each building before connecting to the on-site backbone storm drain system. Therefore, the Project would not create or contribute runoff water, including ponding water, which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-19 – 4.7-20.) Threshold HYD-3(iv): The Project would not 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 impede or redirect flood flows.

Findings: The City finds that the Project would result in less than significant impacts to hydrology and water quality related to flood flows. Additionally, the City finds that the Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft Supplemental EIR, pp. 4.7-20 – 4.7-21.)
Explanation of the Rationale: As discussed previously, with adherence to the applicable permits (e.g., Construction General Permit and Santa Ana RWQCB’s Groundwater Discharge Permit, if necessary), implementation of a project-specific SWPPP and associated BMPs, construction of the Project would not substantially alter the existing drainage pattern of the site or area in a manner which would impede or redirect flood flows. Additionally, the Project site is not located within a Special Flood Hazard Area, defined as the area that will be inundated by the base flood or 100-year flood. Therefore, the potential for Project facilities to impede or redirect flood flows is considered low. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-20 − 4.7-21.)
Threshold HYD-4: The Project would not, in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.

Findings: The City finds that the Project would result in less than significant impacts to hydrology and water quality related to flood hazard, tsunami, or seiche zones. Additionally, the City finds City Council 28 – 74 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-24
that the Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft Supplemental EIR, pp. 4.7-21 – 4.7-22.) Explanation of the Rationale: The Project site is not located within a Special Flood Hazard Area and the risk of flood hazard is low. Tsunamis affect low-lying areas along the coastline. As the Project site is located approximately 6 miles from the coastline, the risk of tsunami hazard is low.

The Project site is within the inundation area of the Santiago Creek and the Prado Dam. However, as stated in the GPU PEIR, the USACE and DSOD have ongoing assessments and measures to certify dam efficiencies, and Santiago Creek and Prado Dam are required to maintain EAPs, which would help minimize property damage and loss of life in emergency conditions. Therefore, the risk of project inundation is low. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-21 – 4.7-22.)
Threshold HYD-5: The Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Findings: The City finds that the Project would result in less than significant impacts to hydrology and water quality related to conflict with a water quality control plan or sustainable groundwater management plan. Additionally, the City finds that the Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft Supplemental EIR, pp. 4.7-22 – 4.7-23.)
Explanation of the Rationale: The Project would adhere to the requirements of the Construction General Permit, Orange County MS4 Permit, and the City’s Municipal Code as required by RR HYD-1, HYD-4, and HYD-5, to reduce impacts to surface and groundwater quality. Water supply for the Project would be provided by connections to the existing City utility infrastructure and not by groundwater wells. The project’s projected water demand would be sufficiently accommodated by the City’s water supply. Therefore, the Project would not obstruct or conflict with a water quality control plan or sustainable groundwater management plan. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-22 – 4.7-23.) Cumulative Impacts: The Project would not result in cumulative impacts concerning hydrology and water quality.

Findings: The City finds that the Project would result in less than significant cumulative impacts concerning hydrology and water quality. Additionally, the City finds that the Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft Supplemental EIR, pp. 4.7-23 – 4.7-25.)
Explanation of the Rationale:

Similar to the Project, construction activities associated with GPU buildout and the related projects have the potential to convey soils and other pollutants into municipal storm drains. During operation of these projects, stormwater runoff from project sites could introduce or increase pollutants that could runoff into municipal storm drains. However, as with the Project, projects developed pursuant to the GPU and the related projects within the watersheds would be required to implement water quality control measures pursuant to the NPDES General Construction Permit, such as implementation of a SWPPP (for projects disturbing greater than one acre), a City Council 28 – 75 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-25
WQMP (for development and redevelopment projects), and BMPs to eliminate or reduce the discharge of pollutants in stormwater discharges, reduce runoff, reduce erosion and sedimentation, and increase filtration and infiltration. The NPDES permit requirements have been set by the SWRCB and implemented by the RWQCB and the Orange County DAMP to reduce incremental effects of individual projects so that they would not result in significant cumulative impacts.

Additionally, the projected water demand from the GPU at buildout, which includes the Project, is well within the projected total water demand for 2040 in the 2015 Urban Water Management Plan for normal, dry year, and multiple dry year scenarios. Additionally, as the other related projects in the cities of Irvine and Costa Mesa are within the OC Basin, it is assumed that the projected total water demand for 2040 in the 2015 Urban Water Management Plan for normal, dry year, and multiple dry year scenarios would be sufficient for the related projects. Further, mandatory compliance with each city’s Municipal Code would ensure that buildout of the GPU, the related projects, and the Project would result in less than significant cumulative impacts related to flood hazards.

Therefore, the Project’s contribution to cumulative impacts related to hydrology and water quality would not be cumulatively considerable. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-23 – 4.7-25.)

4.11 LAND USE AND PLANNING
Threshold LU-1: The Project would not physically divide an established community.

Findings: The City finds that the Project would result in less than significant impacts to land use and planning related to physically dividing an established community. (Draft Supplemental EIR, pp. 4.8-20 – 4.8-21.)
Additionally, the City finds that the Project will implement the following regulatory requirement (Draft Supplemental EIR, pp. 4.8-8 – 4.8-9):

RR LU-1: Development associated with the General Plan Update would be designed and constructed in accordance with the applicable provisions of Chapter 41 (Zoning) of the City of Santa Ana Municipal Code. Development within specific plan areas, overlay areas, and specific development districts would implement zoning and development standards that are applicable within these subareas in addition to those in the underlying zoning district.

RR HAZ-7: Development will be designed and constructed in accordance with the airport environs land use plan (AELUP) for John Wayne Airport. Building height restrictions, as specified in the AELUP, would apply in the city
Explanation of the Rationale: The Project implements land uses and activities that were envisioned and analyzed in the GPU PEIR. The Project site is currently developed with 164,049 square feet of commercial uses, which comprises approximately 22 percent of the 17.2-acre site.

City Council 28 – 76 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-26
The remaining project site is comprised of surface parking. The Project site currently does not have any residential uses and no existing established community exists within the Project site.

The Project site is surrounded by commercial and multi-family residential uses, and the Project, which proposes a mixed-use community that would include mixed-use commercial and residential, residential only, and commercial only buildings, would connect the surrounding properties through the proposed pedestrian, bicycle, and vehicular network. Additionally, the Project would not introduce any new roadways that would bisect existing communities or neighborhoods. Therefore, the Project would not physically divide an established community,.

Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.8-20 – 4.8-21.) Threshold LU-2: The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Findings: The City finds that the Project would result in less than significant impacts to land use and planning related to conflict with a land use plan, policy, or regulation. Additionally, the City finds that the Project will implement regulatory requirements RR LU-1 and RR HAZ-7 (listed above). (Draft Supplemental EIR, pp. 4.8-21 – 4.8-52.)
Explanation of the Rationale: The Project is consistent with applicable regional and local plans and programs that have been adopted for the purpose of avoiding or mitigating an environmental effect including SCAG’s 2020-2045 RTP/SCS, the Airport Environs Land Use Plan for John Wayne Airport (SNA), the City’s General Plan, and applicable zoning. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.8-21 – 4.8-52.) Cumulative Impacts: The Project would not result in cumulative impacts concerning land use and planning.

Findings: The City finds that the Project would result in less than significant cumulative impacts concerning land use and planning. Additionally, the City finds that the Project will implement regulatory requirements RR LU-1 and RR HAZ-7 (listed above). (Draft Supplemental EIR, pp. 4.8-52 – 4.8-53.)
Explanation of the Rationale: As with the Project, the GPU buildout and each related project would be required to comply with their applicable land use plan and be subject to review by City regulatory agencies and CEQA review. The Project would not physically divide an established community or conflict with applicable land use plans and zoning standards. Therefore, the Project’s contribution to cumulative impacts to land use and planning would not be cumulatively considerable. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.8-52 – 4.8-53.)
City Council 28 – 77 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-27

4.12 MINERAL RESOURCES
Threshold M-1: The Project would not 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.

Findings: The City finds that the Project would result in no impacts to mineral resources related to the loss of availability of a known mineral resource that would be of value to the region and the residents of the state. (Draft Supplemental EIR, pp. 5-12 – 5-13.) Explanation of the Rationale: The Project site is entirely located in an area designated as MRZ3, indicating that the significance of mineral deposits cannot be determined from the available data. The Project site is currently developed with existing commercial retail and surface parking lot uses. No mineral extraction occurs within or near the Project site, and no mineral extraction would occur with implementation of the Project. Thus, the Project would not 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 would occur. (Draft Supplemental EIR, pp. pp. 5-12 – 5-13.) Threshold M-2: The Project would not result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan.

Findings: The City finds that the Project would result in no impacts to mineral resources related to the loss of availability of a locally-important mineral resource recovery site. (Draft Supplemental EIR, p. 5-13.)
Explanation of the Rationale: The Project is not delineated as a locally important mineral resource recovery site in the GPU or other land use plan. The Project would be located within a fully developed urban site with no mineral resource sectors or active or inactive mines. Therefore, implementation of the Project would not result in the loss of availability of a locally-important mineral resource recovery site. No impact would occur. (Draft Supplemental EIR, p. 5-13.) Cumulative Impacts: The Project would not result in cumulative impacts concerning mineral resources.

Findings: The City finds that the Project would result in less than significant cumulative impacts concerning mineral resources. (Draft Supplemental EIR, pp. 5-12 – 5-13.) Explanation of the Rationale: The Project site is entirely located in an area designated as MRZ3 and is not delineated as a locally important mineral resource recovery site in the GPU or other land use plan. The Project site is currently developed with existing commercial retail and surface parking lot uses. No mineral extraction occurs within or near the Project site, and no mineral extraction would occur with implementation of the Project. Thus, the Project would not 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 or of a locally-important mineral resource recovery site. No impact would occur. Therefore, the Project’s contribution to cumulative impacts related to mineral resources would not be cumulatively considerable. No impacts would occur. (Draft Supplemental EIR, pp. 5-12 – 5-13.)
City Council 28 – 78 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-28

4.13 NOISE
Threshold N-2: The Project would not result in generation of excessive groundborne vibration or groundborne noise levels.

Findings: The City finds that the Project would result in less-than-significant impacts to noise related to generation of excessive groundborne vibration. (Draft Supplemental EIR, pp. 4.9-32 – 4.9-35.)
Explanation of the Rationale: Project construction can generate varying degrees of groundborne vibration, depending on the construction procedure and the construction equipment used. The ground-borne vibration generated during construction activities would primarily impact existing sensitive uses that are located adjacent to or within the immediate vicinity of individual projects. The Project may potentially use pile drivers during construction and the nearest residences are multi-family residences approximately 75 feet from the Project site, resulting in vibration levels ranging from approximately 0.0006 inch/second PPV to approximately 0.1239 inch/second PPV at 75 feet. As a result, construction groundborne vibration would not be capable of exceeding the 0.2 inch-per-second PPV significance threshold for human annoyance or building damage at the nearest sensitive receptor. Therefore, vibration impacts would be less than significant impact during construction.

Implementation of the Project would not involve land uses that include or require equipment, facilities, or activities that would result in perceptible groundborne vibration. Heavy duty trucks would occasionally travel through the surrounding roadways; however, it is unusual for vibration from sources, such as buses and trucks, to be perceptible, even in locations close to major roads.

As such, it can be reasonably inferred that operation of the Project would not create perceptible vibration impacts to the nearest sensitive receptors. Therefore, vibration impacts related to human annoyance and building damage during operation would be less than significant. (Draft Supplemental EIR, pp. 4.9-32 – 4.9-35.)
Threshold N-3: The Project would not expose people residing or working in the project area located within two miles of a public airport or public use airport to excessive noise levels.

Findings: The City finds that the Project would result in less-than-significant impacts to noise related to exposing people residing or working in the project area located within two miles of a public airport or public use airport to excessive noise levels. (Draft Supplemental EIR, pp. 4.9-35 – 4.9-36.)
Explanation of the Rationale: The nearest airport is John Wayne Airport (SNA) located approximately 1.5 miles southeast of the Project site. The Project site is located within the Airport Environs Land Use Plan for John Wayne Airport (SNA) and the Federal Aviation Regulations Part 77 Notification Area, but outside of the General Aviation Runway Safety Zones. Future sensitive uses proposed under the Project would be located outside of the 60 dBA CNEL noise contour of SNA. Additionally, the project site is not located within the vicinity of a private airstrip or related facilities. (Draft Supplemental EIR, p. 4.9-36.)
City Council 28 – 79 9/16/2025
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ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-29

4.14 POPULATION AND HOUSING
Threshold P-1: The Project would not 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).

Findings: The City finds that the Project would result in less-than-significant impacts to population and housing related to substantial unplanned population growth. (Draft Supplemental EIR, pp. 4.10-10 – 4.10-12.)
Explanation of the Rationale: The Project would draw from the large regional workforce to build out the phases during construction. As the nature of typical construction efforts in urbanized, developed areas such as the Project is temporary and involves commuting to construction sites, the construction workers are not expected to relocate to the Project site area and result in substantial unplanned population growth in the area. Construction impacts would be less than significant.

The Project would introduce housing and a residential population to a site where none currently exist and would provide housing for approximately 3,659 individuals, at a 95.9 percent occupancy rate. With respect to the Orange County Council of Governments projections, the Project would be approximately 1.02 percent of the population and approximately 1.9 percent of the housing in Santa Ana and would not exceed the growth identified in the GPU PEIR. The Project would benefit the City by introducing multi-family housing in a jobs-rich area in which employees would be able to easily commute to nearby employment opportunities. In addition, as the area is jobs-rich and as the Project would slightly reduce (improve) the jobs to housing ratio, the addition of residential units in the area would not require additional direct or indirect job growth. Furthermore, jobs associated with the Project’s retail and office uses would be filled to some extent by employees already residing in the vicinity of the Project. Thus, the employment growth from the Project would not exceed the growth identified in the GPU PEIR.

The Project would be consistent with the land use designations proposed in the GPU PEIR, which allow for urban retail, residential, mixed-use, and employment centers with an intensity of up to

5.0 floor area ratio (FAR) and/or 125 dwelling units per acre; thus, no new substantial unplanned population growth would occur that was not previously analyzed in the GPU PEIR. Therefore, impacts related to unplanned population growth as a result of the Project would be less than significant. (Draft Supplemental EIR, pp. 4.10-10 – 4.10-12.) Threshold P-2: The Project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

Findings: The City finds that the Project would result in no impacts to population and housing related to displacement of existing people or housing. (Draft Supplemental EIR, pp. 4.10-12 – 4.10-13.)
Explanation of the Rationale: The Project site is currently developed with existing commercial retail uses and surface parking lot uses. No housing or residents are currently located within the Project site. The Project would redevelop the approximately 17.2-acre site within the South Bristol City Council 28 – 80 9/16/2025
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Street Focus Area with a mix of residential and commercial uses that would provide approximately 1,583 residential units. Consistent with the GPU, implementation of the Project would provide additional housing opportunities. Therefore, no people or housing would be displaced, and no impacts would occur. (Draft Supplemental EIR, pp. 4.10-12 – 4.10-13.) Cumulative Impacts: The Project would not result in cumulative impacts concerning population and housing.

Findings: The City finds that the Project would result in less than significant cumulative impacts concerning population and housing. (Draft Supplemental EIR, pp. 4.10-13 – 4.10-17.) Explanation of the Rationale: Cumulative development located in the City of Santa Ana propose various uses, including, but not limited to, apartments, single-family residences, offices, commercial/retail uses, restaurants, hotels, warehouses, industrial uses, and gas station and car wash uses. The Project with the related projects would account for 16.7 percent of the projected housing growth (5.2 percent of the GPU buildout), 14.6 percent of the projected population growth (3.3 percent of the GPU buildout), and 12.9 percent of the projected employment growth (0.9 percent of the GPU buildout) for the City. With respect to the OCCOG 2045 projections, the project in combination with related projects would contribute to approximately 7.2 percent of the housing and 3.9 percent of the population in Santa Ana. As previously described, the addition of housing within the Project area would help to balance the jobs-housing ratio within the City, providing a more equal distribution of employment and housing for the City and thereby reducing commute trips and improving air quality. On a citywide scale, the GPU buildout and related projects within the City of Santa Ana are within the GPU’s vision and forecasted development buildout of accommodating growth in a responsible manner by providing a balance of jobs and housing.

Therefore, the Project’s contribution to cumulative impacts associated with population and housing would not be cumulatively considerable. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.10-12 – 4.10-17.)

4.15 PUBLIC SERVICES
Threshold FP-1: The Project would not result in unplanned population growth or substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios and response times or other performance objectives for fire protection services.

Findings: The City finds that the Project would result in less-than-significant impacts to public services related to fire protection services. (Draft Supplemental EIR, pp. 4.11-14 – 4.11-15.) Additionally, the City finds that the Project will implement the following regulatory requirement (Draft Supplemental EIR, p. 4.11-3):

RR FP-1: New buildings are required to meet the fire regulations outlined in the California Health and Safety Code (Sections 13000 et seq.).

City Council 28 – 81 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

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Explanation of the Rationale: Construction and operation of the Project would increase demand for fire protection and emergency medical services over existing conditions. However, the Project would be consistent with the land use designations proposed in the GPU PEIR; thus, no new substantial unplanned growth would occur that was not previously analyzed in the GPU PEIR.

Additionally, while the calls for service from the additional population and employment at the Project site could result in an increase in response times from nearby fire stations, Orange County Fire Authority (OCFA) fire protection equipment and staffing may be augmented by the City, as needed, and the Project would include payment of applicable fees to the City’s general fund towards fire protection facilities. Additionally, the Project would comply with OCFA’s Fire Prevention Guideline B-09 related to access driveways, access walkways to and around buildings, water supply, and siting of hydrants consistent with the California Fire Code and California Building Standards Code. Therefore, the Project’s impacts on fire protection services would be less than significant. (Draft Supplemental EIR, pp. 4.11-14 – 4.11-15.) Threshold PP-1: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios and response times or other performance objectives for police protection services.

Findings: The City finds that the Project would result in less-than-significant impacts to public services related to police protection services. (Draft Supplemental EIR, pp. 4.11-15 – 4.11-17.) Explanation of the Rationale: The Project would be consistent with the land use designations proposed in the GPU PEIR; thus, no new substantial unplanned growth would occur that was not previously analyzed in the GPU PEIR. Nonetheless, this anticipated growth generated by the Project would increase service calls but is expected to create the typical range of police service calls, which may relate to crime and safety issues during project construction (e.g., theft of building materials and construction equipment and vandalism) and during project operation (e.g., vehicle burglaries, thefts, commercial shoplifting, and disturbances). The Santa Ana Police Department would review and approve the final site plans to ensure that Crime Prevention through Environmental Design measures are incorporated into the Project’s design. Additionally, the Project would generate revenues for the City’s general fund (in the form of property taxes, sales tax, etc.) that could be used for the provision of new police facilities in the City. Therefore, the Project’s impacts on police protection services would be less than significant. (Draft Supplemental EIR, pp. 4.11-15 – 4.11-17.)
Threshold SS-1: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios and response times or other performance objectives for school services.

Findings: The City finds that the Project would result in less-than-significant impacts to public services related to school services. (Draft Supplemental EIR, pp. 4.11-17 – 4.11-18.) Additionally, the City finds that the Project will implement the following regulatory requirement (Draft Supplemental EIR, p. 4.11-6):

City Council 28 – 82 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-32
RR SS-1: New residential and commercial development shall pay development fee authorized by Section 65996 of the California Government Code to be “full and complete school facilities mitigation.”
Explanation of the Rationale: The Project would have the potential to generate approximately 307 new elementary school students, 176 new intermediate school students, and 226 new high school students, for a total of 709 new students. All three Santa Ana Unified School District schools serving the project site have enrollment capacity to serve the Project at buildout. In addition, the Project would be required to pay developer/impact fees pursuant to Senate Bill 50, which would further reduce potential impacts to school services. Pursuant to California Government Code Section 65995, payment of development fees would provide full and complete mitigation of school impacts. (Draft Supplemental EIR, pp. 4.11-17 – 4.11-18.) Threshold LS-1: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered library facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios and response times or other performance objectives for library services.

Findings: The City finds that the Project would result in less-than-significant impacts to public services related to library services. (Draft Supplemental EIR, pp. 4.11-18 – 4.11-20.) Additionally, the City finds that the Project will implement the following regulatory requirement (Draft Supplemental EIR, p. 4.11-6):

RR LS-1: New residential development shall pay a property excise tax per the City Municipal Code Section 35-114, Residential Development Tax.

Explanation of the Rationale: The Project would be consistent with the land use designations proposed in the GPU PEIR; thus, no new substantial unplanned growth would occur that was not previously analyzed in the GPU PEIR. Nonetheless, the anticipated growth generated by the Project would increase the demand for library services in the City. However, through compliance with the policies regarding the payment of residential development tax and property taxes, which would contribute to the City’s general fund that could potentially be used for the expansion of the existing libraries or construction of new library facilities, the Project’s impacts on library services would be less than significant. (Draft Supplemental EIR, pp. 4.11-18 – 4.11-20.) Cumulative Impacts: The Project would not result in cumulative impacts concerning public services.

Findings: The City finds that the Project would result in less than significant cumulative impacts concerning public services. (Draft Supplemental EIR, pp. 4.11-20 – 4.11-23.) City Council 28 – 83 9/16/2025
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Explanation of the Rationale:

Fire Protection
Buildout of the GPU and the related projects would be reviewed by the City and/or OCFA prior to permit approval to ensure that all new development implement fire protection design features pursuant to the CFC and CBSC to reduce potential fire hazards. In addition, each related project proposing buildings over two stories in height would be required to pay a fire facilities fee. The Project would be consistent with the land use designations evaluated in the GPU PEIR; thus, no new substantial unplanned growth would occur that was not previously analyzed in the GPU PEIR. Further, Project implementation would improve the fire safety of the project site compared to existing conditions and adhere to OCFA’s Fire Prevention Guideline B-09. The Project would also contribute the appropriate payment of the fire facilities fee, residential development tax, and property taxes, which would contribute to the City’s general fund that could potentially be used for the expansion of existing fire stations or construction new fire protection facilities. Therefore, the Project’s contribution to cumulative impacts associated with fire protection and emergency services would not be cumulatively considerable, and therefore, cumulative impacts would be less than significant. (Draft Supplemental EIR, pp. 4.11-20 – 4.11-21.) Police Protection
Buildout of the GPU and related projects within the City of Santa Ana would have the potential to generate additional demand for police protection services by the Santa Ana Police Department.

However, as part of the development project review process, the Santa Ana Police Department would review and approve the final site plans for GPU buildout and each related project within the City. In addition, GPU buildout and each related project within the City would generate revenues to the City’s general fund (in the form of property taxes, sales tax, etc.) that could be applied toward the provision of new police facilities and related staffing in the City. The Project would not result in substantial unplanned population growth that was not previously analyzed in the GPU PEIR. Design of the Project would be reviewed and approved by the Santa Ana Police Department, and the Project would generate revenues for the City’s general fund that could be used for the provision of new police facilities in the City. Therefore, the Project’s contribution to cumulative impacts associated with police protection services would not be cumulatively considerable, and therefore, cumulative impacts to police protection services would be less than significant. (Draft Supplemental EIR, p. 4.11-21.)
School Services
Buildout of the GPU and related projects within the boundaries of Santa Ana Unified School District and Orange Unified School District have the potential to result in the need for additional school resources. However, cumulative development would be subject to all applicable laws, ordinances, and regulations in place for school services, such as payment to fund new schools from the fee program pursuant to Senate Bill 50. Additionally, the Project would be consistent with the land use designations proposed in the GPU PEIR; thus, no new substantial unplanned growth would occur that was not previously analyzed in the GPU PEIR. Additionally, the Project would be required to pay developer/impact fees pursuant to Senate Bill 50. As such, the Project’s contribution to cumulative impacts associated with school services would not be cumulatively considerable, and therefore, cumulative impacts to school services would be less than significant. (Draft Supplemental EIR, pp. 4.11-21 – 4.11-22.)
City Council 28 – 84 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-34
Library Services
Buildout of the GPU and the related projects within the City would potentially increase the need for library services. However, only the projects that involve the development of residential uses would generate additional demand for library services. Cumulative development within the City with a residential component would be required to comply with RR LS-1 for the payment of the residential development tax and property taxes, which would contribute to the City’s general fund that could potentially be used for the expansion of the existing libraries or construction new library facilities. Additionally, the Project would not result in new substantial unplanned growth that was not previously analyzed in the GPU PEIR. Project implementation would also result in the payment of the residential development tax and property taxes, which could potentially be used for the expansion of the existing libraries or construction new library facilities. Therefore, the Project’s contribution to cumulative impacts associated with library services would not be cumulatively considerable, and therefore, cumulative impacts to library services would be less than significant. (Draft Supplemental EIR, pp. 4.11-22 – 4.11-23.)

4.16 TRANSPORTATION
Threshold T-1: The Project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.

Findings: The City finds that the Project would result in less-than-significant impacts to transportation related to conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. (Draft Supplemental EIR, p. 4.13-11.)
Additionally, the City finds that the Project will implement the following regulatory requirements (Draft Supplemental EIR, p. 4.13-4):

RR T-1: The City will design and operate a balanced, multimodal circulation system network with all users in mind—including bicyclists, public transportation vehicles and riders, and pedestrians of all ages and abilities in line with the California Complete Streets Act (Assembly Bill 1358).

RR T-2: Projects pursuant to the General Plan Update will implement fire protection requirements as detailed in the Orange County Fire Authority’s Fire Prevention Guidelines and in the California Fire Code.

Explanation of the Rationale: The Project would enhance the existing circulation network by including improvements to existing roadways, providing a new internal network of private roadways and loading zones to encourage the safe movement of people and goods, and providing adequate parking for residents and visitors to the Project site. Additionally, the Project would maintain the existing public transit stops located within, directly adjacent to, or in the vicinity of the Project site and would continue to serve the ridership in the area which would include the residents, employees, and visitors of the Project. The Project would also enhance the existing bicycle and pedestrian facilities within the Project vicinity to allow residents, visitors, and other City Council 28 – 85 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-35
users to travel throughout The Village. Therefore, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system for roadways, transit, bicycle or pedestrian facilities. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.13-11 – 4.13-14.)
Threshold T-2: The Project would not conflict or be inconsistent with State CEQA Guidelines Section 15064.3(b).

Findings: The City finds that the Project would result in less-than-significant impacts to transportation related to conflict or inconsistency with State CEQA Guidelines Section 15064.3(b).

Additionally, the City finds that the Project will implement regulatory requirements RR T-1 through RR T-2 (listed above). (Draft Supplemental EIR, pp. 4.13-14 – 4.13-18.) Explanation of the Rationale: The Project is located in a Transit Priority Area (TPA), and the proposed land uses are consistent with the RTP/SCS. Additionally, the Project would not result in an increase in the VMT per service population (VMT/SP) from what was analyzed in the GPU PEIR. The Traffic Impact Study Guidelines identifies areas in the City that cannot be screened out because they are not located in a TPA and would, therefore, require a VMT analysis; however, the Project is not located within such an area and is therefore screened out of VMT analysis.

Therefore, the Project would not conflict or be inconsistent with State CEQA Guidelines Section 15064.3(b). Impacts related to VMT as a result of the Project would be less than significant. (Draft Supplemental EIR, pp. 4.13-14 – 4.13-18.)
Threshold T-3: The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

Findings: The City finds that the Project would result in less-than-significant impacts to transportation related to substantially increasing hazards due to a geometric design feature or incompatible uses. Additionally, the City finds that the Project will implement regulatory requirements RR T-1 through RR T-2 (listed above). (Draft Supplemental EIR, pp. 4.13-18 – 4.13-19.)
Explanation of the Rationale: The Project would change circulation and mobility throughout the Project site by providing sidewalks, pedestrian paths, and a bicycle network. Additionally, the Project would include improvements to existing roadways, including Sunflower Avenue, Plaza Drive, and Bear Street. All roadway improvements and new roadway construction would be constructed in accordance with the Orange County Fire Authority standards and requirements, the Santa Ana Citywide Design Guidelines, and design guidelines of the California Manual of Uniform Traffic Control Devices. Additionally, during construction, a traffic control plan would be implemented to ensure that appropriate construction traffic control measures are utilized for adequate and safe access and circulation within and near the Project site for all modes of transportation, including emergency vehicles. Consistent with the GPU PEIR, circulation network improvements are subject to review by the City’s Public Works engineering staff, which would ensure that roadway and circulation network improvements meet geometric design standards and, thus, would not substantially increase hazards. Lastly, the Project is consistent with the land use designation of the site and, thus, would not introduce any incompatible uses that would result in transportation hazards. Therefore, impacts related to substantially increased hazards due to a City Council 28 – 86 9/16/2025
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geometric design feature or incompatible uses would be less than significant. (Draft Supplemental EIR, pp. 4.13-18 – 4.13-19.)
Threshold T-4: The Project would not result in inadequate emergency access.

Findings: The City finds that the Project would result in less-than-significant impacts to transportation related to inadequate emergency access. Additionally, the City finds that the Project will implement regulatory requirements RR T-1 through RR T-2 (listed above). (Draft Supplemental EIR, p. 4.13-20.)
Explanation of the Rationale: The proposed public and private roadways throughout the Project site would be designed to accommodate emergency vehicles for fire, ambulance, and police services. The roadways would not have restricted access such as gates that would prevent emergency vehicles from reaching the intended destinations. Roadway improvements and new roadway construction would be constructed in accordance with the Orange County Fire Authority standards and requirements. During construction, a traffic control plan would be implemented to ensure that adequate and safe access is available within and near the Project site. Appropriate construction traffic control measures would be utilized to ensure that emergency access to the Project site and the safe circulation of all modes of transportation is maintained on adjacent rightsof-way. Therefore, impacts related to inadequate emergency access would be less than significant. (Draft Supplemental EIR, p. 4.13-20.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning transportation.

Findings: The City finds that the Project would result in less-than-significant cumulative impacts concerning transportation. Additionally, the City finds that the Project will implement regulatory requirements RR T-1 through RR T-2 (listed above). (Draft Supplemental EIR, pp. 4.13-21 – 4.13-3.)
Explanation of the Rationale: Cumulative development under the GPU buildout and related projects, including surrounding jurisdictions for the Cities of Costa Mesa and Irvine, would be separately reviewed and approved by the respective jurisdiction to ensure their consistency with applicable programs, plans, ordinances, and policies; VMT impacts; and compliance with existing building and fire code standards associated with emergency access hazards. The Project would connect to the existing circulation system while providing new facilities to enhance the use of public transit, pedestrian, and bicycle mobility and would not conflict with a plan, ordinance, or policy addressing circulation; would be consistent with SCAG’s Connect SoCal RTP/SCS and provide for public transit options to future project users to further reduce VMT; and would be designed in conformance with the City and Orange County Fire Authority’s design standards to ensure that no potentially hazardous design features or inadequate emergency access would be introduced. Therefore, the Project’s contribution to cumulative impacts associated with transportation would not be cumulatively considerable. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.13-21 – 4.13-23.)
City Council 28 – 87 9/16/2025
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4.17 UTILITIES AND SERVICE SYSTEMS
Threshold U-1: The Project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

Findings: The City finds that the Project would result in less-than-significant impacts to utilities and service systems related to new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities. (Draft Supplemental EIR, pp. 4.15-22 – 4.15-27.)
Additionally, the City finds that the Project will implement the following regulatory requirements (Draft Supplemental EIR, pp. 4.15-8 – 4.15-14):

Water
RR U-5: Any development implemented under the General Plan Update shall abide by the water conservation and efficiency requirements detailed in Chapter 8, Article XVI, Chapter 39, Article VI and Chapter 41, Article XVI of the Santa Ana Municipal Code.

RR U-6: Water connection fees shall be paid in accordance with Chapter 39, Article II of the City’s Municipal Code and plumbing shall be installed in compliance with Chapter 8, Article III.

RR U-7 (Water): Water Supply Assessments and written verifications shall be prepared for any development implemented under the General Plan Update that meets the criteria of Senate Bill 610 or Senate Bill 221.

Wastewater
RR U-1: Any sewer utility infrastructure improvement associated with development under the General Plan Update shall be designed, constructed, and operated in accordance with Chapter 8, Article III, and Chapter 39, Article III, and of the Santa Ana Municipal Code.

RR U-2: Any new connections to the Orange County Sanitation District system or expansion of a previous connection shall pay a capital facilities charge in accordance with Ordinance No. OCSD-40.

RR U-3: Sewer utility infrastructure improvements associated with development under the General Plan Update shall be designed, constructed, and operated in accordance with the Orange County Sanitation District’s Ordinance Nos. 25 and 48 and the wastewater discharge requirements of the National Pollutant Discharge Elimination System permit (Order No. R8-2012-0035).

City Council 28 – 88 9/16/2025
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Stormwater
RR U-8 (Stormwater): Storm drain shall be installed in compliance with Chapter 8, Article III, of the Santa Ana Municipal Code.

RR HYD-1: All development pursuant to the General Plan Update shall comply with the requirements of the Construction General Permit (Order No. 2012-0006-DWQ) for stormwater discharges associated with construction activity. Compliance requires filing a Notice of Intent (NOI), a Risk Assessment, a Site Map, a Stormwater Pollution Prevention Plan (SWPPP) and associated best management practices (BMPs), an annual fee, and a signed certification statement.

RR HYD-4: All development pursuant to the General Plan Update shall comply with the requirements of the Orange County MS4 Permit (Order R8-2009-0030, NPDES No.

CAS618030, as amended by Order No. R8-2010-0062). The MS4 Permit requires new development and redevelopment projects to:
• Control contaminants into storm drain systems
• Educate the public about stormwater impacts
• Detect and eliminate illicit discharges
• Control runoff from construction sites
• Implement best management practices and site-specific runoff controls and treatments for new development and redevelopment.

Dry Utilities
RR U-10: New buildings are required to achieve the current California Building Energy and Efficiency Standards (Title 24, Part 6) and California Green Building Standards Code (CALGreen) (Title 24, Part 11).

RR U-11: All new appliances would comply with the 2012 Appliance Efficiency Regulations (Title 20, California Code of Regulations, Sections 1601 through 1608).

Explanation of the Rationale:

Water
The Project would involve the installation of water mains, hydrants, fire sprinklers, and proposed recycled water and irrigation laterals and meters based on City and County input during the design permitting phase. The water infrastructure improvements would comply with the City of Santa Ana Design Guidelines for Water and Sewer Facilities and City of Santa Ana’s Construction Standards. Construction impacts associated with the installation of new water mains, fire hydrants, and water connections would be temporary and would primarily involve trenching in order to place the water lines below ground within previously disturbed roadways. Moreover, water infrastructure improvement projects were considered in the GPU PEIR and supported by City Council 28 – 89 9/16/2025
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GPU policies. Therefore, the Project’s impacts related to the relocation or construction of new or expanded water facilities would be less than significant. As such, impacts resulting from the Project would be less than significant. (Draft Supplemental EIR, p. 4.15-23.) Wastewater
The Project would result in an increase in wastewater generation due to the Project site’s change in land use from commercial to mixed-use (i.e., residential uses and higher density would result in greater wastewater generation. The Project’s generated flow of 0.200 cubic feet per second (cfs) would match the existing flow and no additional wastewater capacity would be required. As part of Project development requirements, the Sewer Capacity Study, was submitted to the Orange County Sanitation District (OC San) to verify capacity of the County sewer mains. OC San review identified that there is existing capacity within the Sunflower trunk main; however, the smaller Vitrified Clay Pipe (VCP) sewer mains in Bear Street and Plaza Drive have no additional capacity beyond current discharges. Thus, the Project would include the construction of an onsite private sewer network that would convey a majority of sewer flows generated west of Plaza Drive within a private sewer network to connect to the City’s VCP sewer main. All new connections would be constructed per City and OC San standards. Final alignment, points of connections, and limits of sewer removal and replacement would be developed during the design permitting phase.

All proposed wastewater infrastructure improvements and connections would comply with the City of Santa Ana Design Guidelines for Water and Sewer Facilities, City of Santa Ana’s Construction Standards and City and OC San standards, which provide design criteria and construction methods. Construction impacts associated with the installation of new sewer connections and facilities would be temporary and would primarily involve trenching in order to place the lines below ground. Further, the proposed wastewater infrastructure improvements would be located in areas within the Project site and in previously disturbed roadways, and thus, the impacts from installation and upgrades of the proposed on-site private sewer network are already accounted for in the various resource sections of this Supplemental EIR. Therefore, with the Project’s impacts related to the relocation or construction of new or expanded wastewater facilities would be less than significant. As such, impacts resulting from the Project would be less than significant. (Draft Supplemental EIR, pp. 4.15-23 – 4.15-25.)
Stormwater
The Project’s grading and storm drain network would be designed to match the existing drainage and flow patterns to best utilize the capacities available in the existing public storm drain system.

The Project would integrate bio-filtration methods, pervious surfaces, and selective plant materials to encourage on-site water retention. Final routing of the storm drain system may require the construction of underground detention systems to handle a minimum of the 10-year design storm, per the latest version of the Orange County Local Drainage Manual and would be developed with City and County input during the design permitting phase. The proposed drain improvements would be constructed within previously disturbed roadways. Additionally, the impacts from installation and upgrades to the storm drain system are already accounted for in the various resource sections of this Supplemental EIR. Therefore, the Project’s impacts related to the relocation or construction of new or expanded stormwater facilities would be less than significant.

As such, impacts resulting from the Project would be less than significant. (Draft Supplemental EIR, pp. 4.15-25 – 4.15-26.)
City Council 28 – 90 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-40
Dry Utilities
The Project would result in service lines for new buildings to be extended or relocated from the existing infrastructure. While the Project would increase energy demand at the site compared to existing conditions, it would be required to comply with the latest applicable Building Energy Efficiency Standards and CALGreen requirements which provide efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting reducing energy usage. The Project would also install solar panels on at least 30 percent of the roof area of buildings to generate electricity onsite, offsetting demand from Southern California Edison’s electrical distribution system. As such, energy consumption for the project would be below California Energy Commission’s forecasts, the City’s forecasted consumption for the proposed buildout of the General Plan in 2045, and the current Countywide usage. Therefore, Project development would not require Southern California Edison or Southern California Gas Company to obtain new or expanded electricity or natural gas facilities, other than those proposed on-site. Thus, the Project’s impacts related to the relocation or construction of new or expanded electrical or natural gas facilities would be less than significant.

Further, the existing communication services such as telephone, wi-fi, and cable television would continue to be provided to the Project site by multiple providers. As various telecommunications providers are available in the region, no significant expansion or construction of the telecommunications network is anticipated. Therefore, the Project’s impacts related to the relocation or construction of new or expanded telecommunications facilities would be less than significant. As such, impacts resulting from the Project would be less than significant. (Draft Supplemental EIR, pp. 4.15-26 – 4.15-27.)
Threshold U-2: The Project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.

Findings: The City finds that the Project would result in less-than-significant impacts to utilities and service systems related to water supply. Additionally, the City finds that the Project will implement regulatory requirements RR U-5 through RR U-7 (listed above). (Draft Supplemental EIR, pp. 4.15-27 – 4.15-30.)
Explanation of the Rationale: Water demand for the Project during construction activities such as soil compaction, dust control, and truck wheel washing, would be supplied by water trucks and/or through connections to nearby water distribution lines. Construction activities would occur intermittently throughout the construction period and would be temporary in nature; therefore, construction impacts related to water supply would be less than significant.

For operations, the net water demand generated by the Project site at buildout would be 339 acrefeet per year (AFY) which is approximately 1 percent of the overall City water demand. The Project’s future water demand from 2025 through 2045 would range from 300 AFY to 286 AFY.

In addition to the City’s existing and planned future uses, the projected water demand for the Project would be met by the City’s water supply during normal, single-dry, and multiple-dry years.

Additionally, the Project would comply with water conservation and efficiency requirements required by the Santa Ana Municipal Code, pay water connection fees, and implement GPU City Council 28 – 91 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-41
policies for water conservation, such as installing drought-tolerant plants, low-water turf surface, bio-filtration planters, green roofs, drip irrigation, and localized capture and reuse. Therefore, the Project would have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.15-27 – 4.15-30.) Threshold U-3: The Project would result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.

Findings: The City finds that the Project would result in less-than-significant impacts to utilities and service systems related to wastewater treatment. Additionally, the City finds that the Project will implement regulatory requirements RR U-1 through RR U-3 (listed above). (Draft Supplemental EIR, pp. 4.15-30 – 4.15-31.)
Explanation of the Rationale: The Project would result in an increase in wastewater flows generated from the Project site. The OC San’s Treatment Plant No. 1 serves the General Plan area and has a treatment capacity of 182 million gallons per day (mgd) and a minimum residual treatment capacity of 52 mgd. The Project would result in a 0.27-mgd increase in wastewater flows to Treatment Plant No. 1. Therefore, Treatment Plant No. 1 would have sufficient capacity to treat the 0.27 mgd of wastewater flows generated by the Project in addition to existing commitments. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.15-30 – 4.15--1.)
Threshold U-4: The Project would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

Findings: The City finds that the Project would result in less-than-significant impacts to solid waste related to generation in excess of state or local standards, capacity of the local infrastructure or otherwise impair the attainment of solid waste reduction goals. (Draft Supplemental EIR, pp. 4.15-31 – 4.15-33.)
Additionally, the City finds that the Project will implement the following regulatory requirements (Draft Supplemental EIR, p. 4.15-13):

RR U-7 (Solid Waste): All development pursuant to the General Plan Update shall comply with Section 4.408 of the 2019 California Green Building Code Standards, which requires new development projects to submit and implement a construction waste management plan in order to reduce the amount of construction waste transported to landfills.

RR U-8 (Solid Waste): All development pursuant to the General Plan Update shall store and collect recyclable materials in compliance with Assembly Bill 341. Green waste will be handled in accordance with Assembly Bill 1826.

City Council 28 – 92 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-42
Explanation of the Rationale: Construction of the Project would generate a total of approximately 17,846 tons over the course of a 20-year period, a large percentage of which would occur during phase one, which includes demolition of the existing uses at the Project site. All future construction activities would be required to demonstrate compliance with Assembly Bill (AB) 939, which requires that at least 50 percent of waste produced is recycled, reduced, or composted. In addition, the project would be constructed in accordance with CALGreen, which requires recycling a minimum of 65 percent of the nonhazardous construction and demolition debris, and submittal of a construction waste management plan. Compliance with these regulations, as well as RR U-7 requiring implementation of a construction waste management plan, would ensure the project’s construction-related solid waste impacts would be less than significant.

Operation of the Project would generate a total of approximately 35,700 pounds per day, or 17.85 tons per day (tpd). The maximum permitted capacity for the Frank Bowerman Sanitary Landfill and the Olinda Alpha Landfill are 11,500 tpd and 8,000 tpd, respectively. Both landfills have an average daily disposal rate of approximately 7,000 tpd, indicating that they would have sufficient capacity to accommodate the Project’s 17.85 tpd of solid waste (i.e., less than 1 percent of the residual disposal capacity of the Frank Bowerman Sanitary Landfill). The Project would also be required to comply with RR U-8, which states that all development pursuant to the GPU would be required to store and collect recyclable materials and green waste in accordance with AB 341 and AB 1826. Additionally, the Project would implement GPU policies to incorporate recycling and organics collection activities to align with state waste reduction goals. Therefore, the Project would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.15-31 – 4.15-33.)
Threshold U-5: The Project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

Findings: The City finds that the Project would result in less-than-significant impacts to utilities and service systems related to compliance with solid waste federal, state, and local management and reduction statutes and regulations. Additionally, the City finds that the Project will implement regulatory requirements RR U-7 through RR U-8 (listed above). (Draft Supplemental EIR, p. 4.15-34.)
Explanation of the Rationale: Construction of the Project would be required to comply with the requirements of AB 939, which requires that at least 50 percent of waste produced is recycled, reduced, or composted, and CALGreen, which requires recycling a minimum of 65 percent of the nonhazardous construction and demolition debris and submittal of a construction waste management plan. Operation of the Project would also be required to comply with AB 939; AB 341, which requires diversion of a minimum of 75 percent of operational solid waste; and Chapter 16 Article II of the City’s Municipal Code, which incorporates the waste requirements of SB 1383 for single-family, multi-family, and commercial uses. Additionally, the Project would implement waste disposal services to allow for trash, recycling, and food waste for all residential and commercial uses. Therefore, the Project would comply with applicable state and local regulations related to solid waste. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.15-31 – 4.15-33.)
City Council 28 – 93 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-43
Cumulative Impacts: The Project would not result in cumulative impacts concerning utilities and service systems.

Findings: The City finds that the Project would result in no cumulative impacts concerning utilities and service systems. Additionally, the City finds that the Project will implement regulatory requirements RR U-1 through RR U-3; RR U-5 through RR U-8; RR U-10 through RR U-11; RR HYD-1; and RR HYD-4 (listed above). (Draft Supplemental EIR, pp. 4.15-35 – 4.15-38.) Explanation of the Rationale:

Water
The geographic context for the analysis of cumulative impacts to water supply and infrastructure is the City’s water service area, which covers 27.5 square miles and includes the City of Santa Ana and a small neighborhood in the City of Orange, near Tustin Avenue and Fairhaven by the northeast corner of Santa Ana. The City’s 2020 UWMP forecasts the water supply and demand for its water service through 2045 which considers the GPU buildout assumptions and accounted for the water demand generated by the types of land uses proposed by the related projects within the City’s water service area. As such, the City would have adequate water supplies to meet the water demand during normal, single dry, and multiple dry years through 2045. In addition, the City is able to purchase more water from MWD if necessary. Further, projects resulting from GPU buildout and the related projects would be required to comply with regulatory requirements and GPU policies that promote water conservation, prepare a Water Supply Assessment, and require City review of each water service connection and infrastructure improvement.

The Project would have a less than significant impact on the City’s water infrastructure and the City would have sufficient water supplies to serve the Project during normal, single-dry, and multiple-dry years. Therefore, the Project’s contribution to cumulative impacts to water supply or infrastructure would not be cumulatively considerable, and as such, cumulative impacts to water supply or infrastructure would be less than significant. (Draft Supplemental EIR, pp. 4.15-35 – 4.15-38.)
Wastewater
The geographic context for the analysis of cumulative impacts to wastewater conveyance and treatment would be the sewer service area of the City, which encompasses 27.2 square miles, and OC San’s service area, which covers a 479-square-mile area of central and northwest Orange County and includes the cities of Santa Ana, Costa Mesa, and Irvine. Buildout of the GPU and related projects would increase wastewater generation, thus cumulatively increasing wastewater generation and infrastructure capacity, potentially requiring the relocation or construction of new or expanded wastewater facilities. However, they would be required to perform a sewer monitoring study to determine the adequacy of the sewer system, to pay the OC San Capital Facilities Charge for new connections to the OC San System, and adhere to local standards.

Additionally, wastewater flows would be conveyed to OC San’s Treatment Plant No. 1 or Treatment Plant No. 2 for treatment which has a combined total capacity of 632 mgd. The project’s connections and upgrades to the sewer lines would result in less-than-significant impacts. In addition, wastewater generated by the Project would be adequately served by OC San’s Treatment Plant No. 1. Therefore, the Project’s contribution to cumulative impacts to wastewater City Council 28 – 94 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-44
conveyance and treatment infrastructure would not be cumulatively considerable, and cumulative impacts related to wastewater treatment would be less than significant. (Draft Supplemental EIR, p. 4.15-36.)
Stormwater
The extent of analysis of cumulative impacts for storm drainage systems is contiguous with the City and Orange County Flood Control District (OCFCD) service areas. Depending on the project type and design (e.g., new construction or significant reconstruction), buildout of the GPU and all related projects could cumulatively increase stormwater flows, potentially requiring the relocation or construction of new or expanded stormwater facilities; however, they would adhere to the requirements of the NPDES and applicable permits (e.g., MS4, Industrial General Permit, and Construction General Permit), which prevent post-development stormwater flows from exceeding pre-development flows. Further, GPU buildout and the related projects would undergo the development and review process and require hydrology studies as needed to assess stormwater runoff and drainage. As such, GPU buildout and the related projects would result in less than significant cumulative impacts related to stormwater.

The Project’s grading and storm drain network would be designed to match the existing drainage and flow patterns to best utilize the capacities available in the existing public storm drain system.

The Project would integrate bio-filtration methods, pervious surfaces, and selective plant materials to encourage on-site water retention to ensure less than significant impacts related to stormwater drainage. Therefore, the Project’s contribution to cumulative impacts related to stormwater or infrastructure would not be cumulatively considerable, and thus, cumulative impacts to stormwater or infrastructure would be less than significant. (Draft Supplemental EIR, pp. 4.15-36 – 4.15-37.) Solid Waste
The extent of analysis of cumulative impacts for solid waste collection and disposal services is contiguous with the Waste Management of Orange County service area. Solid waste generated by GPU buildout and the related projects within the City of Santa Ana would be primarily disposed of at the Frank R. Bowerman Sanitary Landfill in Irvine and the Olinda Alpha Landfill in Brea. The Orange County solid waste landfill system would continue maintain the 15-year countywide solid waste landfill capacity as required by AB 939. Both landfills have sufficient capacity to accommodate solid waste generated by the related projects and the Project. Moreover, the Project and related projects would comply with all regulatory requirements to reduce solid waste generation, including the requirements of AB 939, CALGreen, AB 341, and AB 1826, which would reduce the amount of solid waste generated. Therefore, the Project’s contribution to cumulative impacts related to solid waste would not be cumulatively considerable, and as such, cumulative impacts to solid waste would be less than significant. (Draft Supplemental EIR, pp. 4.15-37 – 4.15-38.)
Dry Utilities
The extent of analysis of cumulative impacts for dry utilities (i.e., natural gas and electricity services) is contiguous with the Southern California Gas Company and Southern California Edison service areas. Although future developments would result in the use of renewable and nonrenewable electricity and natural gas resources during construction and operation, which could limit future availability, the sizes and types of uses proposed by the GPU buildout and City Council 28 – 95 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-45
related projects would use such resources on a relatively small scale. Additionally, future development projects, including the Project, would be expected to incorporate energy conservation features in compliance with applicable regulations, such as the Title 24 standards, which include the CALGreen Code. The Project would not result in the need for expanded facilities from SoCalGas, SCE, or telecommunications providers, as the existing capacities for dry utilities would be sufficient to meet the Project’s needs. Thus, the Project’s contribution to cumulative impacts to dry utility services would not be cumulatively considerable, and as such, cumulative impacts to dry utility services would be less than significant. (Draft Supplemental EIR, p. 4.15-38.)

4.18 WILDFIRE
Threshold W-1: The Project would not substantially impair an adopted emergency response plan or emergency evacuation plan.

Findings: The City finds that the Project would result in no impact to wildfire related to impairing an adopted emergency response plan or emergency evacuation plan. (Draft Supplemental EIR, p. 5-13.)
Explanation of the Rationale: The Project site is located within the City, which is not located in or near a state responsibility area or lands classified as a very high fire hazard severity zone (VHFHSZ). The nearest state responsibility area classified as VHFHSZ to the City is about four miles east along the western edge of Loma Ridge, and the nearest VHFHSZ in a local responsibility area is about 3.8 miles east at the southern tip of the Peters Canyon Regional Park.

Therefore, the Project would not substantially impair an adopted emergency response plan or emergency evacuation plan, and no impact to wildfire would occur. (Draft Supplemental EIR, p. 5-13.)
Threshold W-2: The Project would not, 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.

Findings: The City finds that the Project would result in no impact to wildfire related to exacerbating wildfire risks and exposing project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. (Draft Supplemental EIR, p. 5-13.) Explanation of the Rationale: As previously discussed, the Project site is located within the City, which is not located in or near a state responsibility area or lands classified as a VHFHSZ.

Therefore, the Project would not, 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. No impact to wildfire would occur. (Draft Supplemental EIR, p. 5-13.)
Threshold W-3: The Project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

City Council 28 – 96 9/16/2025
4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT

ENVIRONMENTAL EFFECTS WITHOUT MITIGATION MEASURES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 4-46
Findings: The City finds that the Project would result in no impact to wildfire related to requiring the installation or maintenance of associated infrastructure that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment. (Draft Supplemental EIR, p. 5-14.) Explanation of the Rationale: As previously discussed, the Project site is located within the City, which is not located in or near a state responsibility area or lands classified as a VHFHSZ.

Therefore, the Project would not require the installation or maintenance of associated infrastructure that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment, and no impact to wildfire would occur. (Draft Supplemental EIR, p. 5-14.) Threshold W-4: The Project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

Findings: The City finds that the Project would result in no impact to wildfire related to exposing people or structures to significant risks due to runoff, post-fire slope instability or drainage changes. (Draft Supplemental EIR, p. 5-14.)
Explanation of the Rationale: As previously discussed, the Project site is located within the City, which is not located in or near a state responsibility area or lands classified as a VHFHSZ.

Therefore, the Project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. No impact to wildfire would occur. (Draft Supplemental EIR, p. 5-14.) Cumulative Impacts: The Project would not result in cumulative impacts concerning wildfire.

Findings: The City finds that the Project would result in no cumulative impacts concerning wildfire. (Draft Supplemental EIR, pp. 5-13 – 5-14.)
Explanation of the Rationale: The Project site is located within the City, which is not located in or near a state responsibility area or lands classified as a VHFHSZ. Therefore, no cumulative impacts to wildfire would occur. (Draft Supplemental EIR, pp. 5-13 – 5-14.) City Council 28 – 97 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 5-1
CHAPTER 5

LESS-THAN-SIGNIFICANT ENVIRONMENTAL

EFFECTS WITH MITIGATION INCORPORATED
Based on the Supplemental EIR, the Project would have less-than-significant environmental effects with mitigation incorporated for the specific areas associated with the topics identified below.

5.1 AIR QUALITY
Threshold AQ-1: The Project would not conflict with or obstruct implementation of the applicable air quality plan with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that the following mitigation measure shall be implemented to reduce potentially significant air quality impacts resulting from the Project (Draft Supplemental EIR, p. 4.1-40):

Project-Specific MM AQ-1: Prior to the issuance of occupancy permits, the Planning Division shall confirm that the proposed project’s Covenants, Conditions, and Restrictions (CC&Rs) and/or tenant lease agreements include contractual language that all landscaping equipment used on-site shall utilize at least 50 percent electric landscaping equipment (e.g., lawnmowers, leaf blowers, hedge trimmers). All residential and nonresidential properties shall be equipped with exterior electrical outlets to accommodate this requirement. This requirement shall be included in the third-party vendor agreements for landscape services for the building owner and tenants, as applicable.

Additionally, the City finds that the Project will implement the following regulatory requirements RR AQ-1 through RR AQ-3 (Draft Supplemental EIR, pp. 4.1-8 – 4.1-9):

RR AQ-1: New buildings are required to achieve the current California Building Energy Efficiency Standards (Title 24, Part 6) and California Green Building Standards Code (CALGreen) (Title 24, Part 11). The 2019 Building Energy Efficiency Standards became effective January 1, 2020. The Building and Energy Efficiency Standards and CALGreen are updated tri-annually with a goal to achieve net zero buildings energy for 2030.

RR AQ-2: Construction activities will be conducted in compliance with California Code of Regulations, Title 13, Section 2449, which requires that nonessential idling of construction equipment is restricted to five minutes or less.

RR AQ-3: Construction activities will be conducted in compliance with any applicable South Coast Air Quality Management District rules and regulations, including but not limited to:

City Council 28 – 98 9/16/2025
5 LESS-THAN-SIGNIFICANT ENVIRONMENTAL EFFECTS

WITH MITIGATION INCORPORATED
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 5-2
• Rule 403, Fugitive Dust, for controlling fugitive dust and avoiding nuisance. • Rule 402, Nuisance, which states that a project shall not “discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.”
• Rule 1113, which limits the volatile organic compound content of architectural coatings.
• Rule 1466, Soil Disturbance. Projects that involve earth-moving activities of more than 50 cubic yards of soil with applicable toxic air contaminants are subject to this rule.

Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.1, Air Quality, pages 4.1-27 through 4.1-30 of the Draft Supplemental EIR.

The following presents a summary of that rationale:

The determination of 2022 Air Quality Management Plan (AQMP) consistency focuses on the long-term influence of a project on air quality in the South Coast Air Basin (SCAB). The Project would not result in a long-term impact on the region’s ability to meet State and Federal air quality standards. Further, the Project’s long-term influence on air quality in the SCAB would also be consistent with the South Coast Air Quality Management District (SCAQMD) and Southern California Association of Government’s (SCAG’s) goals and policies and is considered consistent with the 2022 AQMP. As such, impacts resulting from the Project would be less than significant for volatile organic compounds (VOCs) with implementation of Project-Specific MM AQ-1 and regulatory requirements RR AQ-1 through RR AQ-3.

Threshold AQ-2: The Project would not 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 with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that the following mitigation measures shall be implemented to reduce potentially significant air quality impacts resulting from the Project (Draft Supplemental EIR, pp. 4.1-39 – 4.1-40):

GPU PEIR MM AQ-1: Prior to discretionary approval by the City of Santa Ana for development projects subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects), project applicants shall prepare and submit a technical assessment evaluating potential project construction-related air quality impacts to the City of Santa Ana for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing air quality impacts. If construction-related criteria air pollutants are determined to have the potential City Council 28 – 99 9/16/2025
5 LESS-THAN-SIGNIFICANT ENVIRONMENTAL EFFECTS

WITH MITIGATION INCORPORATED
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 5-3
to exceed the SCAQMD’s adopted thresholds of significance, the City of Santa Ana shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City. Mitigation measures to reduce construction-related emissions could include, but are not limited to:
• Require fugitive-dust control measures that exceed SCAQMD’s Rule 403, such as:
o Use of nontoxic soil stabilizers to reduce wind erosion. o Apply water every four hours to active soil-disturbing activities. o Tarp and/or maintain a minimum of 24 inches of freeboard on trucks hauling dirt, sand, soil, or other loose materials.
• Use construction equipment rated by the United States Environmental Protection Agency as having Tier 3 (model year 2006 or newer) or Tier 4 (model year 2008 or newer) emission limits, applicable for engines between 50 and 750 horsepower. • Ensure that construction equipment is properly serviced and maintained to the manufacturer’s standards.
• Limit nonessential idling of construction equipment to no more than five consecutive minutes.
• Limit on-site vehicle travel speeds on unpaved roads to 15 miles per hour. • Install wheel washers for all exiting trucks or wash off all trucks and equipment leaving the project area.
• Use Super-Compliant volatile organic compound paints for coating of architectural surfaces whenever possible. A list of Super-Compliant architectural coating manufactures can be found on the SCAQMD’s website.

GPU PEIR MM AQ-2: Prior to discretionary approval by the City of Santa Ana for development projects subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects), project applicants shall prepare and submit a technical assessment evaluating potential project operation phase-related air quality impacts to the City of Santa Ana for review and approval. The evaluation shall be prepared in conformance with SCAQMD methodology in assessing air quality impacts. If operation-related air pollutants are determined to have the potential to exceed the SCAQMD’s adopted thresholds of significance, the City of Santa Ana shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during operational activities. The identified measures shall be included as part of the conditions of approval. Possible mitigation measures to reduce long-term emissions could include, but are not limited to the following:
• For site-specific development that requires refrigerated vehicles, the construction documents shall demonstrate an adequate number of electrical service City Council 28 – 100 9/16/2025
5 LESS-THAN-SIGNIFICANT ENVIRONMENTAL EFFECTS

WITH MITIGATION INCORPORATED
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 5-4
connections at loading docks for plug-in of the anticipated number of refrigerated trailers to reduce idling time and emissions.
• Applicants for manufacturing and light industrial uses shall consider energy storage and combined heat and power in appropriate applications to optimize renewable energy generation systems and avoid peak energy use. • Site-specific developments with truck delivery and loading areas and truck parking spaces shall include signage as a reminder to limit idling of vehicles while parked for loading/unloading in accordance with California Air Resources Board Rule 2845 (13 CCR Chapter 10 Section 2485).
• Provide changing/shower facilities as specified in Section A5.106.4.3 of the CALGreen Code (Nonresidential Voluntary Measures).
• Provide bicycle parking facilities per Section A4.106.9 (Residential Voluntary Measures) of the CALGreen Code and Sec. 41-1307.1 of the Santa Ana Municipal Code.
• Provide preferential parking spaces for low-emitting, fuel-efficient, and carpool/van vehicles per Section A5.106.5.1 of the CALGreen Code (Nonresidential Voluntary Measures).
• Provide facilities to support electric charging stations per Section A5.106.5.3 (Nonresidential Voluntary Measures) and Section A5.106.8.2 (Residential Voluntary Measures) of the CALGreen Code.
• Applicant-provided appliances (e.g., dishwashers, refrigerators, clothes washers, and dryers) shall be Energy Star–certified appliances or appliances of equivalent energy efficiency. Installation of Energy Star– certified or equivalent appliances shall be verified by Building & Safety during plan check. • Applicants for future development projects along existing and planned transit routes shall coordinate with the City of Santa Ana and Orange County Transit Authority to ensure that bus pad and shelter improvements are incorporated, as appropriate.

Refer to Project-Specific MM AQ-1, above.

Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.1, Air Quality, pages 4.1-31 through 4.1-41 of the Draft Supplemental EIR.

The following presents a summary of that rationale:

The evaluation provided in the Draft Supplemental EIR determined that the Project’s constructionrelated and operation phase-related air quality impacts would be less than significant, with the exception of operational VOC emissions during the summer. Regarding the mitigation measures in the GPU PEIR related to this threshold, the technical assessment and appendices prepared for the Project satisfy GPU PEIR MM AQ-1 and MM AQ-2, which require preparation of a technical assessment evaluating a potential project’s construction-related and operation phase-related air quality impacts. The possible mitigation measures to reduce short-term and long-term emissions City Council 28 – 101 9/16/2025
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listed under GPU PEIR MM AQ-1 and AQ-2 are either suggested for industrial uses or do not directly reduce operational VOC emissions. Therefore, Project-Specific MM AQ-1 would be implemented to reduce significant impacts related to VOCs during Project operations.

Threshold AQ-3: The Project would not expose sensitive receptors to substantial pollutant concentrations with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that GPU PEIR MM AQ-1 (listed above) shall be implemented to reduce potentially significant air quality impacts resulting from the Project. (Draft Supplemental EIR, p. 4.1-39.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.1, Air Quality, pages 4.1-42 through 4.1-47 of the Draft Supplemental EIR.

The following presents a summary of that rationale:

The Project would not expose sensitive receptors to substantial pollutant concentrations, including to significant health risk impacts for residential sensitive receptors during project construction with the implementation of GPU PEIR MM AQ-1. Pursuant to GPU PEIR MM AQ-1, the Project requires use of construction equipment rated by the USEPA as having Tier 4 (model year 2008 or newer) emissions limits, applicable for engines between 50 and 750 horsepower. The total highest calculated carcinogenic risk would be approximately 7.36 in one million and would not exceed the SCAQMD threshold of 10 in one million with the implementation of GPU PEIR MM AQ-1. Therefore, construction activities associated with the Project are not anticipated to result in a significant cancer or other health risk to nearby sensitive receptors, and, as such, the health impacts during construction of the Project would be less than significant with mitigation incorporated.

Further, by complying with GPU PEIR MM AQ-1, the Project would reduce construction-related DPM emissions and associated acute risk, and the highest maximum chronic and acute hazard index associated with the mitigated emissions from Project construction at residential sensitive receptors would be 0.136 and 0.918 and would not exceed the 1.0 chronic hazard index for individual significance. Therefore, the Project’s chronic and acute hazard index would be less than significant with mitigation incorporated.

Cumulative Impacts: The Project would not result in cumulative impacts concerning air quality with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that GPU PEIR MM AQ-1 and Project Specific MM AQ-1 (listed previously) shall be implemented to reduce potentially significant air quality impacts resulting from the Project. (Draft Supplemental EIR, pp. 4.1-39 – 4.1-41.) City Council 28 – 102 9/16/2025
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Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.1, Air Quality, pages 4.1-48 through 4.1-51 of the Draft Supplemental EIR.

The following presents a summary of that rationale:

The Project would not have a considerable contribution to cumulative impacts related to consistency with applicable air quality plans or regional and localized emissions with the implementation of Project-Specific MM AQ-1, to reduce the Project’s operational emissions of VOCs and its contribution of ozone precursors to the SCAB to below the SCAQMD’s threshold of significance. Additionally, GPU PEIR MM AQ-1 would require the use of construction equipment rated by the USEPA as having Tier 4 emissions limits for engines between 50 and 750 horsepower to reduce the carcinogenic and acute hazard risks. Therefore, cumulative impacts related to consistency with applicable air quality plans and regional and localized emissions were determined to be less than significant after mitigation.

5.2 CULTURAL RESOURCES
Threshold C-2: The Project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to State CEQA Guidelines Section 15064.5 with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that the following mitigation measure shall be implemented to reduce potentially significant cultural resource impacts resulting from the Project (Draft Supplemental EIR, pp. 4.2-15 – 4.2-16):

GPU PEIR MM CUL-6: If the archaeological assessment did not identify archaeological resources but found the area to be highly sensitive for archaeological resources, a qualified archaeologist and a Native American monitor approved by a California Native American Tribe identified by the Native American Heritage Commission as culturally affiliated with the project area shall monitor all ground-disturbing construction and preconstruction activities in areas with previously undisturbed soil of high sensitivity. The archaeologist shall inform all construction personnel prior to construction activities of the proper procedures in the event of an archaeological discovery. The training shall be held in conjunction with the project’s initial on-site safety meeting and shall explain the importance and legal basis for the protection of significant archaeological resources. The Native American monitor shall be invited to participate in this training. In the event that archaeological resources (artifacts or features) are exposed during ground-disturbing activities, construction activities in the immediate vicinity of the discovery shall be halted while the resources are evaluated for significance by an archaeologist who meets the Secretary’s Standards. and This will include tribal consultation and coordination with the Native American monitor in the case of a prehistoric archaeological resource or tribal resource. If the discovery proves to be significant, the long-term disposition of any collected materials should be determined in consultation with the affiliated tribe(s), where City Council 28 – 103 9/16/2025
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relevant; this could include curation with a recognized scientific or educational repository, transfer to the tribe, or respectful reinternment in an area designated by the tribe.

Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.2, Cultural Resources, pages 4.2-14 through 4.2-16 of the Draft Supplemental EIR. The following presents a summary of that rationale:

Due to the Project site’s past disturbances, which resulted in the disturbance of archaeological sites buried at shallow depths, the sensitivity for cultural resources consisting of archaeological sites is considered low at and near the surface of the Project site. However, this does not preclude the possibility that subsurface archaeological deposits underlie the project site, especially in areas where only minimal ground disturbance have occurred (i.e., the existing surface parking lots or structures with shallow foundations). Additionally, the sensitivity for potential buried prehistoric archaeological sites increases in the undisturbed soils at lower depths. The Project would require a maximum depth of 52 feet for the proposed subsurface parking garage increasing the sensitivity for potential buried prehistoric archaeological resources. Therefore, the Project would incorporate GPU PEIR MM CUL-6, which would reduce impacts to potential archaeological resources. With the implementation of the GPU PEIR MM CUL-6, impacts to archaeological resources would be less than significant.

Cumulative Impacts: The Project would not result in cumulative impacts concerning cultural resources with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that GPU PEIR MM CUL-6 (listed previously) shall be implemented to reduce potentially significant cultural resource impacts resulting from the Project. (Draft Supplemental EIR, pp. 4.2-15 – 4.2-16.) Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.2, Cultural Resources, pages 4.2-17 through 4.2-19 of the Draft Supplemental EIR. The following presents a summary of that rationale:

The Project would not have a considerable contribution to cumulative impacts related to archaeological resources with implementation of GPU PEIR MM CUL-6, which would reduce the potential to impact undiscovered resources during ground-disturbing activities during Project construction of the proposed subsurface parking garage. Incorporation of GPU PEIR MM CUL-6 would reduce the Project’s potential impacts to archaeological resources to less than significant levels. Therefore, the Project’s impacts to archaeological resources would not be cumulatively considerable.

City Council 28 – 104 9/16/2025
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5.3 GEOLOGY AND SOILS
Threshold G-1(ii): The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: strong seismic ground shaking, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that the following mitigation measures shall be implemented to reduce potentially significant geological impacts resulting from the Project (Draft Supplemental EIR, p. 4.4-11):

Project-Specific MM G-1: Incorporation of and Compliance with a Design-Level Geotechnical Investigation. A final design-level geotechnical investigation that complies with all applicable state and local code requirements shall be prepared for each project structure by a qualified, California-licensed geotechnical engineer consistent with the California Building Code and City of Santa Ana requirements applicable at the time of issuance of grading or construction permits. The final design-level geotechnical investigation shall include recommendations related to site grading and earthwork, fill materials, compaction, foundations, dewatering, and other structural elements. The report recommendations shall be included in construction specifications and permits, approved by the City’s Building and Safety Division, and confirmed through on-site inspections.

Project-Specific MM G-2: Implementation of Geotechnical Recommendations. Project plans, grading specifications, and construction permitting shall incorporate site-specific earthwork and ground improvement requirements related to seismic ground shaking, liquefaction, settlement, collapse, subsidence, and expansive soils consistent with the California Building Code and City of Santa Ana requirements applicable at the time of issuance of grading or construction permits as stated in the final design-level geotechnical investigation and approved by the City’s Building and Safety Division. This shall include recommendations related to site grading and earthwork, fill materials, compaction, foundations, dewatering, and other structural elements.

Additionally, the City finds that the Project will implement regulatory requirements RR G-1 through RR G-3 (listed above). (Draft Supplemental EIR, pp. 4.4-3 – 4.4-4.) Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.4, Geology and Soils, pages 4.4-10 through 4.4-12 of the Draft Supplemental EIR. The following presents a summary of that rationale:

One of the primary seismic hazards at the Project site is ground shaking due the Project site’s proximity to the San Joaquin Hills Blind Thrust Fault and the Newport-Inglewood Fault. Consistent with the GPU PEIR, the Project would be designed and constructed to meet or exceed current design standards as found in the latest California Building Code (CBC) and other applicable local, state, and federal codes to minimize impacts related to strong seismic ground shaking.

City Council 28 – 105 9/16/2025
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Additionally, the City requires the Project-specific engineering design recommendations from a design-level geotechnical investigation be incorporated into grading plans and building specifications as a condition of construction permit approval. These recommendations have been incorporated into Project-Specific MM G-1 and MM G-2. Therefore, impacts to seismic ground shaking would be less than significant with mitigation incorporated.

Threshold G-1(iii): The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
seismic-related ground failure, including liquefaction, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that Project-Specific MM G-1 and MM G-2 (listed previously) shall be implemented to reduce potentially significant geological impacts resulting from the Project. Additionally, the City finds that the Project will implement regulatory requirements RR G-1 through RR G-3 (listed above). (Draft Supplemental EIR, p. 4.4-11.) Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.4, Geology and Soils, pages 4.4-12 through 4.4-13 of the Draft Supplemental EIR. The following presents a summary of that rationale:

Another primary seismic hazard at the Project site is potential ground deformation due to liquefaction, based on California Regional Geologic Maps indicating the Project site as having potentially liquefiable soil. Though the liquefaction analysis performed for the Project indicated that the Project site has low to moderate liquefaction potential due to the clay layer that caps the site and the depth to the liquefaction prone layers, Project-Specific MM G-1 and MM G-2 would be implemented which requires review and approval of the final design-level geotechnical investigation, including proper foundation design measures based on 2022 CBC standards, by the City’s Building and Safety Division as part of the construction permit approval process.

Therefore, impacts to seismic-related ground failure, including liquefaction would be less than significant with mitigation incorporated.

Threshold G-3: The Project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that Project-Specific MM G-1 and MM G-2 (listed previously) shall be implemented to reduce potentially significant geological and soil impacts resulting from the Project to less-than-significant. Additionally, the City finds that the Project will implement regulatory requirements RR G-1 through RR G-3 (listed above). (Draft Supplemental EIR, p. 4.4-11.)
City Council 28 – 106 9/16/2025
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Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.4, Geology and Soils, pages 4.4-15 through 4.4-17 of the Draft Supplemental EIR. The following presents a summary of that rationale:

The Project site is underlain by moderately compressible soils as well as soil with low to moderate potential for seismically induced settlements. Model analysis resulted in 1 to 2 inches of total settlement below a mat slab foundation. Implementation of Project-Specific MM G-1 and MM G2 to prepare a detailed geotechnical investigation in support of the final design plans and apply the recommendations which include measures related to foundation specifications for heavier, intermediate, and lighter structures, such as use of pile or pier foundations, mat/raft foundations, stone columns, injection grouting, or deep soil mixing, to reduce impacts related to settlement and collapse, would result in less than significant impacts related to settlement and collapse.

In addition, the Project site has relatively shallow groundwater conditions. Direct groundwater extraction would not occur as part of the Project; however, excavations deeper than approximately 10 to 15 feet are likely to encounter groundwater seepage, and excavations deeper than 15 feet may encounter artesian conditions. Project-Specific MM G-1 and MM G-2 to prepare a detailed geotechnical investigation in support of the final design plans would include local dewatering and inflow control for excavations deeper than approximately 15 to 20 feet for construction activities.

Therefore, impacts to subsidence would be less than significant with mitigation incorporated.

Further, slope failure and landslides are not a major hazard in Santa Ana because the entire city is nearly flat. Lateral spreading is a type of liquefaction-induced ground failure on mildly sloping ground. Impacts related to landslides or lateral spreading are less than significant. Refer to Threshold G-1(iii) for the discussion on liquefaction.

Threshold G-4: The Project would not be located on expansive soil, as defined in Table 18- 1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that Project-Specific MM G-1 and MM G-2 (listed previously) shall be implemented to reduce potentially significant soil impacts resulting from the Project. Additionally, the City finds that the Project will implement regulatory requirements RR G-1 through RR G-3 (listed above). (Draft Supplemental EIR, p. 4.4-11.) Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.4, Geology and Soils, pages 4.4-17 through 4.4-18 of the Draft Supplemental EIR. The following presents a summary of that rationale:

The Project site contains alluvium which consists primarily of clay and silt in the upper 15 to 20 feet, with local thin lenses of sandy alluvium. Below 20 feet, there is considerably more sand and sandy silt layers, with local thin layers of clay. Clay-based soils are susceptible to expansion; therefore, implementation of Project-Specific MM G-1 and MM G-2 would include recommendations or measures for preventing expansive soils as part of the detailed geotechnical City Council 28 – 107 9/16/2025
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investigation in support of the final design plans. Therefore, impacts to expansive soils would be less than significant with mitigation incorporated.

Threshold G-6: The Project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that the following mitigation measures shall be implemented to reduce potentially significant paleontological impacts resulting from the Project (Draft Supplemental EIR, p. 4.4-20 – 4.4-21):

GPU PEIR MM GEO-2: Prior to issuance of a grading permit for projects involving ground disturbance in previously undisturbed areas mapped with “low-to-high” paleontological sensitivity, the project applicant shall consult with a geologist or paleontologist to confirm whether the grading would occur at depths that could encounter highly sensitive sediments for paleontological resources. If confirmed that underlying sediments may have high sensitivity, construction activity shall be monitored by a qualified paleontologist. The paleontologist shall have the authority to halt construction during construction activity as outlined in Mitigation Measure GEO-3.

GPU PEIR MM GEO-3: In the event of any fossil discovery, regardless of depth or geologic formation, construction work shall halt within a 50-foot radius of the find until its significance can be determined by a qualified paleontologist. Significant fossils shall be recovered, prepared to the point of curation, identified by qualified experts, listed in a database to facilitate analysis, and deposited in a designated paleontological curation facility in accordance with the standards of the Society of Vertebrate Paleontology (2010).

The most likely repository is the Natural History Museum of Los Angeles County. The repository shall be identified and a curatorial arrangement shall be signed prior to collection of the fossils.

Project-Specific MM G-3: The project applicant shall retain a qualified professional paleontologist to monitor or supervise full-time monitoring should excavation occur into native Pleistocene-age soil and bedrock greater than 4 feet in depth. Ground disturbance refers to activities that would impact subsurface geologic deposits, such as grading, excavation, boring, etc. Activities taking place in current topsoil or within previously disturbed fill sediments, e.g., clearing, grubbing, pavement rehabilitation, do not require paleontological monitoring. Bedrock can occur at varying depths depending on the portion of the project area.

If no significant fossils have been recovered after 50 percent of excavation has been completed, full-time monitoring may be modified to weekly spot-check monitoring at the discretion of the qualified professional paleontologist. If the qualified professional paleontologist determines during the course of excavations that project excavations are City Council 28 – 108 9/16/2025
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located within fill or disturbed soils, or that the sensitivity for significant paleontological resources is otherwise low, then monitoring may be reduced or suspended at the qualified professional paleontologist’s discretion. The determination to reduce or discontinue paleontological monitoring in the project area shall be based on the professional opinion of the qualified professional paleontologist regarding the potential for fossils to be present after a reasonable extent of the geology and stratigraphy has been evaluated.

Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.4, Geology and Soils, pages 4.4-19 through 4.4-21 of the Draft Supplemental EIR. The following presents a summary of that rationale:

No significant fossils have been previously recovered from the project area, but several vertebrate and invertebrate fossils have been recovered within one mile of the project area and exposures of rock formations are anticipated to underlie the Project area. The geology of the Project area may include Pleistocene-age deposits at unknown depths, suggesting that Project-related ground-disturbing activities, such as for the proposed subsurface parking garage that would require a maximum excavation depth of 52 feet, have the potential to destroy or otherwise adversely impact significant paleontological resources below young Holocene-age soils at unknown depths within the Project area. Therefore, the Project would implement GPU PEIR MMs GEO-2 and GEO-3. GPU MM GEO-2 requires consultation with a geologist or paleontologist to confirm whether the grading would occur at depths that could encounter highly sensitive sediments for paleontological resources. In compliance with GPU PEIR MM GEO-2, construction activity for the Project would be monitored by a qualified paleontologist. GPU MM GEO-3 would require work be halted in the event of a fossil discovery. Additionally, Project-Specific MM G-3 provides procedures for paleontological monitoring. Therefore, impacts to paleontological resources would be less than significant with mitigation incorporated.

Cumulative Impacts: The Project would not result in cumulative impacts concerning geology and soils, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that GPU PEIR MM GEO-2 and MM GEO-3 and Project-Specific MM G-1 through G-3 (listed previously) shall be implemented to reduce potentially significant geology and soils impacts resulting from the Project. Additionally, the City finds that the Project will implement regulatory requirements RR G-1 through RR G-3 (listed above). (Draft Supplemental EIR, pp. 4.4-11 and 4.4-20 – 4.4-21.) Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.4, Geology and Soils, pages 4.4-21 through 4.4-22 of the Draft Supplemental EIR. The following presents a summary of that rationale:

Due to the site-specific nature of geological conditions (e.g., soils, geological features, subsurface features, seismic features), geological impacts are typically limited to individual projects and their project sites, and do not contribute to cumulative impacts. The GPU buildout and all projects on City Council 28 – 109 9/16/2025
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the related project lists would be subject to their own project-specific impact analysis and would be required to incorporate feasible mitigation measures to reduce any potentially significant impacts to a less than significant level. The Project would implement mitigation measures (i.e., Project-Specific MM G-1 and MM G-2) to reduce impacts to a less than significant level. As a result, the Project’s incremental effects would not cause the combined cumulative impacts to become significant and thus, are not cumulatively considerable.

The GPU PEIR identified a significant but mitigable impact on previously unrecorded paleontological resources, to which the related projects could incrementally contribute. Such cumulative impacts from grading activities for projects within the City of Santa Ana would be reduced with the implementation of GPU PEIR MM GEO-1 through MM GEO-3. Additionally, all related projects (including those within Costa Mesa and Irvine) would adhere to their respective General Plan policies and/or mitigation measures to protect paleontological resources. The excavation required for the proposed subsurface parking garage could encounter sensitive sediments for paleontological resources. However, the Project would implement GPU PEIR MMs GEO-2 and GEO-3 and Project-Specific MM G-3, which would protect any discovered paleontological resources. Therefore, the Project’s contribution to cumulative impacts on paleontological resources would not be cumulatively considerable, and therefore, would be less than significant with mitigation incorporated.

5.4 NOISE
Threshold N-1: The Project would not result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that the following mitigation measure shall be implemented to reduce potentially significant noise impacts resulting from the Project (Draft Supplemental EIR, p. 4.9-32):

Project-Specific MM NOI-1: Prior to the issuance of a permit to conduct nighttime construction activities (e.g., overnight concrete pours), the Project Applicant shall obtain a permit from the City to complete work outside the standard construction hours outlined in Santa Ana Municipal Code Section 18-314(e). In addition, the Project Applicant and/or contractor(s) shall develop a nighttime construction noise control plan that demonstrates the construction techniques that will be implemented to ensure noise levels remain below the Federal Transit Administration’s (FTA’s) nighttime construction noise criterion of 70 dBA Leq (A-weighted decibel equivalent sound level). Examples of such construction techniques include but are not limited to the following:
• Locate stationary equipment (e.g., generators, air compressors, etc.) away from off-site residences/sensitive receptors.

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• Surround stationary equipment with noise barriers or utilize a temporary noise barrier to block the line of sight from such equipment to nearby off-site residences/sensitive receptors.
• Identify minimum separation distances between mobile equipment (e.g., concrete mixer trucks, concrete pump trucks, etc.) and residences/sensitive receptors.

Additionally, the City finds that the Project will implement the following regulatory requirements RR NOI-1 through RR NOI-3 (Draft Supplemental EIR, p. 4.9-4):

RR NOI-1: California Building Code: The California Building Code (CBC), Title 24, Part 2, Volume 1, Chapter 12, Interior Environment, Section 1207.11.2, Allowable Interior Noise Levels, requires that interior noise levels attributable to exterior sources shall not exceed 45 dB in any habitable room. The noise metric is evaluated as either the day-night average sound level (Ldn) or the community noise equivalent level (CNEL), consistent with the noise element of the local general plan.

The State of California’s noise insulation standards for non-residential uses are codified in the California Code of Regulations, Title 24, Building Standards Administrative Code, Part 11, CALGreen. CALGreen noise standards are applied to new or renovation construction projects in California to control interior noise levels resulting from exterior noise sources. Proposed projects may use either the prescriptive method (Section

5.507.4.1) or the performance method (Section 5.507.4.2) to show compliance. Under the prescriptive method, a project must demonstrate transmission loss ratings for the wall and roof-ceiling assemblies and exterior windows when located within a noise environment of 65 dBA CNEL or higher. Under the performance method, a project must demonstrate that interior noise levels do not exceed 50 dBA Leq(1hr).

RR NOI-2: Construction Noise Sources: Section 18-314(e) of the Santa Ana Municipal Code prohibits construction activities to the hours of 7:00 AM to 8:00 PM Monday through Saturday.

RR NOI-3: Stationary Noise Sources: Section 18.312 of the Santa Ana Municipal Code establishes standards for stationary noise sources.

Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.9, Noise, pages 4.9-20 through 4.9-32 of the Draft Supplemental EIR. The following presents a summary of that rationale:

The Project operational noise impacts would result in less than significant impacts. The Project’s construction noise would not have the potential to exceed the FTA’s construction noise criterion of 80 dBA Leq. Furthermore, Project construction activities would comply with the construction hours specified in Section 18-314(e) of the Santa Ana Municipal Code, which restricts construction activities to the daytime hours of 7:00 a.m. to 8:00 p.m., Monday through Saturday.

The only exception would be for nighttime concrete pours, which would occur a maximum of 2 nights per phase, should continuous pours be necessary for geotechnical considerations. Noise City Council 28 – 111 9/16/2025
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from nighttime construction activity could exceed the FTA’s nighttime construction noise criterion of 70 dBA Leq at off-site residential uses. As such, implementation of Project-Specific MM NOI-1 would reduce noise levels during nighttime concrete pours by at least 10 dBA. Project-Specific MM NOI-1 requires a nighttime construction control plan and implementation of construction techniques, including installation of temporary noise barriers or enclosures during Phases 2 and 3 to protect sensitive receptors to the north and west, use of mufflers on construction equipment, and placement of construction equipment away from sensitive receptors. Therefore, impacts to construction noise during nighttime concrete pours would be less than significant with mitigation incorporated.

Cumulative Impacts: The Project would not result in cumulative impacts concerning noise, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that Project-Specific MM NOI-1 (listed previously) shall be implemented to reduce potentially significant noise impacts resulting from the Project. (Draft Supplemental EIR, p. 4.9-32.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.9, Noise, pages 4.9-36 through 4.2-44 of the Draft Supplemental EIR. The following presents a summary of that rationale:

Construction activities associated with the Project and cumulative growth may overlap, resulting in increased construction noise in the Project vicinity. However, construction noise primarily affects the areas immediately adjacent to a construction site. Due to the distance and intervening structures, cumulative construction noise from related projects would not be perceptible. With exception of the Related Bristol Specific Plan Project, the related projects are located at distances well removed from the Project site. The Related Bristol Specific Plan Project is located directly to the east of the Project site of which construction of the area closest to the Project would not overlap (Related Bristol Specific Plan Phase 1 construction start 2026) with construction of the Project in the area directly adjacent (Project Phase 4 construction start 2036). The Related Bristol Specific Plan Project is anticipated to be completed in 2036. With the rapid attenuation of noise with distance, construction noise from the Project and Related Bristol Specific Plan Project would not combine to result in significant cumulative effects. The Project would implement ProjectSpecific MM NOI-1 to reduce noise levels during nighttime concrete pours by at least 10 dBA by requiring a nighttime construction control plan and implementation of construction techniques, including installation of temporary noise barriers or enclosures during Phases 2 and 3 to protect sensitive receptors to the north and west, use of mufflers on construction equipment, and placement of construction equipment away from sensitive receptors. In the unlikely event that nighttime concrete pours for both the Related Bristol Specific Plan Project and the Project occur on the same nights in the vicinity of each other, both projects would be required to obtain a permit from the City, including development of a nighttime construction noise control plan, as specified in the respective project-specific noise mitigation measures, which would reduce noise levels below the significance criteria. Cumulative impacts related to mobile, stationary, and vibration City Council 28 – 112 9/16/2025
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would be less than significant. Therefore, the Project’s contribution to cumulative impacts on noise would not be cumulatively considerable, and therefore, would be less than significant with mitigation incorporated.

5.5 TRIBAL CULTURAL RESOURCES
Threshold TCR-1: The Project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k), with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that the following mitigation measures shall be implemented to reduce potentially significant tribal cultural resource impacts resulting from the Project (Final Supplemental EIR, p. 3-9 – 3-11):

GPU PEIR MM CUL-6, listed previously.

Project-Specific MM TCR-1: Native American Monitor - Gabrieleño Band of Mission Indians-Kizh Nation:
a. The project applicant shall retain a Native American monitor from or approved by the Gabrieleño Band of Mission Indians-Kizh Nation. The monitor shall be retained prior to the commencement of any “ground-disturbing activity” for the subject project at any project locations (i.e., both onsite and any offsite locations that are included in the project description/definition and/or required in connection with the proposed project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.
b. A copy of the executed monitoring agreement shall be submitted to the Lead Agency prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity. c. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe.

Monitor logs will identify and describe any discovered tribal cultural resources, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral) human remains City Council 28 – 113 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 5-17
and burial goods. Copies of monitor logs will be provided to the project applicant upon written request to the Tribe.
d. Onsite tribal monitoring by the Kizh Nation and/or their representatives shall conclude upon the earlier of the following (1) written confirmation to the Kizh from a designated point of contact for the project applicant or lead agency that all ground-disturbing activities and phases that may involve ground-disturbing activities on the project site or in connection with the project are complete; or (2) a determination and written notification by the Kizh to the project applicant or Lead Agency that no future, planned construction activity and/or development/construction phase at the project site possesses the potential to impact Kizh tribal cultural resources.

Project-Specific MM TCR-2: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/Non-Ceremonial): Gabrieleño Band of Mission Indians-Kizh Nation
a. Upon discovery of any tribal cultural resources, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered tribal cultural resource has been fully assessed by the Kizh monitor in consultation with a qualified archaeologist.

The Kizh will recover and retain all discovered tribal cultural resources in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.

Project-Specific MM TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects:
a. Native American human remains are defined in Public Resources Code Section 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute.
b. If Native American human remains and/or grave goods are discovered or recognized on the project site, then Public Resources Code Section 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed. c. Human remains and grave/burial goods shall be treated alike per Public Resources Code Section 5097.98(d)(1) and (2).
d. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.
e. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

Project-Specific MM TCR-4: Native American Monitor - Juaneño Band of Mission Indians, Acjachemen Nation- Belardes:
a. The Project applicant shall retain a Native American Monitor from or approved by the Juaneño Band of Mission Indians, Acjachemen Nation- Belardes. The monitor City Council 28 – 114 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 5-18
shall be retained prior to the commencement of any ground-disturbing activity for the subject project at all project locations (i.e., both on-site and any off-site locations that are included in the project description/ definition and/or required in connection with the project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.
b. A copy of the executed monitoring agreement shall be submitted to the (City) prior to the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence ground disturbing activity. c. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe.

Monitor logs will identify and describe any discovered tribal cultural resources (TCRs), including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the Project applicant upon written request to the Tribe. d. On-site tribal monitoring by the Juaneño Band of Mission Indians and/or their representatives shall conclude upon the latter of the following (1) written confirmation to the Tribe or Tribal monitoring agency from a designated point of contact for the Project applicant that all ground-disturbing activities and phases that may involve the Project are complete; or (2) a determination and written notification by the Tribe or Tribal monitoring agency to the Executive Director of the Planning and Building Agency, or designee that no future, planned construction activity and/or development/construction phase at the Project site possesses the potential to impact TCRs.

Project-Specific MM TCR-5: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/Non-Ceremonial) - Juaneño Band of Mission Indians, Acjachemen Nation- Belardes:
a. Upon discovery of any tribal cultural resources (TCRs), all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Juaneño Band of Mission Indians monitor in consultation with a qualified archaeologist. The Tribe or Tribal monitoring agency will recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.

Project-Specific MM TCR-6: Tribal Cultural Resource Finds, Dispute Resolution, and Final Disposition:

If a tribal cultural resource is identified, then avoidance is the preferred treatment. If avoidance is not feasible and both Tribal monitoring entities claim cultural affiliation with and/or ancestral ties to the discovered resources, then a Cultural Resources Monitoring and Treatment Plan shall be created by the archaeologist, in coordination with the City Council 28 – 115 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 5-19
consulting tribes (Gabrieleño Band of Mission Indians-Kizh Nation and the Juaneño Band of Mission Indians, Acjachemen Nation-Belardes) and all subsequent finds shall be subject to this Plan. The consultation effort is intended to be a meaningful and timely process of seeking, discussing, and considering carefully the views of others, in a manner that is cognizant of all parties’ cultural values and, where feasible, seeking agreement on the appropriate treatment and disposition of TCRs discovered. Final disposition of any excavated resources may include, but would not be limited to, reburying, relocating, recording, and/or another culturally appropriate treatment such as transfer to one of the consulting tribes for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes. If it is determined that mutual agreement cannot be reached within 30 days of the initial consultation meeting, the Plan shall be written such that any excavated resources shall be reinterred on site in a location free from future ground-disturbing construction activities after documentation is complete. Project construction will not resume within the immediate vicinity of the discovery (i.e., not less than the surrounding 50 feet) until the Cultural Resources Monitoring and Treatment Plan is prepared and implemented to the satisfaction of the City.

Additionally, the City finds that the Project will implement the following regulatory requirements (Draft Supplemental EIR, p. 4.14-4):

RR TCR-1: As per Assembly Bill 52, within 14 days of deciding to undertake a project or determining that a project application is complete, the lead agency must provide formal written notification to all tribes who have requested it.

RR CUL-1: California Health and Safety Code Section 7050.5 requires that if human remains are discovered within the proposed project site, disturbance of the site shall halt and remain halted until the coroner has investigated the circumstances, manner, and cause of any death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation, or to his or her authorized representative. If the coroner determines that the remains are not subject to his or her authority and if the coroner recognizes or has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.

Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.14, Tribal Cultural Resources, pages 4.14-9 through 4.14-12 of the Draft Supplemental EIR and in Chapter 3, Revisions to the Draft Supplemental EIR, of the Final Supplemental EIR. The following presents a summary of that rationale:

The Project’s Sacred Lands File search yielded negative results and additional research identified no historical or archaeological resources within the Project site and a 0.5-mile radius. The City consulted with the Gabrieleño Band of Mission Indians-Kizh Nation and the Juaneño Band of Mission Indians, Acjachemen Nation-Belardes. Due to the Project site’s location in an area where Native American tribes are known to have a cultural affiliation, there is the possibility that archaeological resources, including tribal cultural resources, could be encountered during ground disturbing construction activities. As previously discussed, excavations for the Project are anticipated to disturb a large part of the Project site to a maximum depth of approximately 52 feet City Council 28 – 116 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 5-20
for the subsurface parking garage. The sensitivity for potential buried prehistoric archaeological sites at the Project site is considered low at the surface and near surface due to past disturbances; however, the sensitivity increases in these undisturbed soils. Therefore, implementation of GPU PEIR MM CUL-6 would require monitoring during all ground-disturbing construction activity and pre-construction activities within previously undisturbed soils by a qualified archaeologist and a Native American monitor, worker training, and procedures in case of a find. In addition, ProjectSpecific MM TCR- 1 through MM TCR-5 are proposed for implementation as requested by the Gabrieleño Band of Mission Indians-Kizh Nation and the Juaneño Band of Mission Indians, Acjachemen Nation-Belardes, to require procedures for Native American monitoring and to avoid potential impacts to tribal cultural resources that may be unearthed from project construction activities. Project-Specific MM TCR-6 is proposed for resource identification, dispute resolution, and final disposition in the event of an unanticipated discovery of a tribal cultural resource.

Therefore, Project impacts to tribal cultural resources would be less than significant with mitigation incorporated.

Threshold TCR-2: The Project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is 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 Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that GPU PEIR MM CUL-6 and ProjectSpecific MM TCR-1 through MM TCR-6 (listed previously) shall be implemented to reduce potentially significant tribal cultural resource impacts resulting from the Project. (Final Supplemental EIR, p. 3-9 – 3-11.)
Additionally, the City finds that the Project will implement regulatory requirements RR TCR-1 through RR CUL-1 (listed above). (Draft Supplemental EIR, p. 4.14-4.) Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.14, Tribal Cultural Resources, pages 4.14-13 through 4.14-14 of the Draft Supplemental EIR and in Chapter 3, Revisions to the Draft Supplemental EIR, of the Final Supplemental EIR. The following presents a summary of that rationale:

As previously discussed, the Project’s Sacred Lands File search yielded negative results and additional research identified no historical or archaeological resources within the Project site and a 0.5-mile radius. The City’s consultation with the Gabrieleño Band of Mission Indians-Kizh Nation City Council 28 – 117 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 5-21
and the Juaneño Band of Mission Indians, Acjachemen Nation-Belardes determined tribal cultural resources may potentially be encountered during ground disturbing construction activities. The potential to encounter buried prehistoric archaeological sites exists for excavation in undisturbed soils. Therefore, GPU PEIR MM CUL-6 and Project-Specific MM TCR-1 through MM TCR-6 would be implemented to require Native American monitoring during any ground disturbing activities on the Project site and to avoid potential impacts to tribal cultural resources that may be unearthed from Project construction activities. Therefore, project impacts to tribal cultural resources would be less than significant with mitigation incorporated.

Cumulative Impacts: The Project would not result in cumulative impacts concerning tribal cultural resources, with the implementation of mitigation.

Findings: The City finds that changes or alterations have been required in, or incorporated into, the Project, which avoid or substantially lessen the significant environmental effect as identified in the Final Supplemental EIR. Specifically, the City finds that GPU PEIR MM CUL-6 and ProjectSpecific MM TCR-1 through MM TCR-6 (listed previously) shall be implemented to reduce potentially significant tribal cultural resource impacts resulting from the Project. Additionally, the City finds that the Project will implement regulatory requirements RR TCR-1 through RR CUL-1 (listed above). (Draft Supplemental EIR, p. 4.14-4.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.14, Tribal Cultural Resources, pages 4.14-14 through 4.14-15 of the Draft Supplemental EIR and in Chapter 3, Revisions to the Draft Supplemental EIR, of the Final Supplemental EIR. The following presents a summary of that rationale:

As previously discussed, the Project site and vicinity are not known to contain tribal cultural resources. However, the excavation required for the proposed subsurface parking garage could encounter prehistoric archaeological sites containing tribal cultural resources. If tribal cultural resources are encountered during construction, the Project has the potential to contribute to cumulative impacts. However, the Project would implement GPU PEIR MM CUL-6 and ProjectSpecific MM TCR-1 through MM TCR-6, which would protect any discovered tribal cultural resources. Therefore, the Project’s contribution to cumulative impacts on tribal cultural resources would not be cumulatively considerable and would be less than significant with mitigation incorporated.

City Council 28 – 118 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 6-1
CHAPTER 6

SIGNIFICANT AND UNAVOIDABLE

ENVIRONMENTAL EFFECTS
The Final EIR determined that the Project has potentially significant environmental effects that cannot be feasibly mitigated to less-than-significant levels, and such impacts would be significant and unavoidable. These impacts and the corresponding findings are identified below.

6.1 RECREATION
Threshold R-1: The Project would 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.

Findings: The City finds that specific economic, legal, social, technological, or other considerations make infeasible the mitigation measures or project alternatives identified in the Final Supplemental EIR. While changes or alterations have been required in, or incorporated into, including regulatory requirement RR REC-1 below, the Project to address this significant effect on the environment, no feasible mitigation measures exist to reduce impacts to a less-thansignificant level.

RR REC-1: Residential development associated with the General Plan Update will be required to comply with the provisions of the Municipal Code Chapter 35, Article IV (Residential Development Fee). Residential development is mandated to pay fees, dedicate land in lieu thereof, or a combination of both for the purpose of preserving recreational facilities in the City.

However, pursuant to PRC Section 21081(a)(3), as described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable based on specific overriding considerations found in Chapter 8 below.

Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.12, Recreation, pages 4.12-10 through 4.12-13 of the Draft Supplemental EIR. The following presents a summary of that rationale:

The Project would redevelop an approximately 17.2-acre site with a mix of residential and commercial uses and is conservatively estimated to provide housing for 3,815 individuals. To meet the GPU policy of providing 3 acres of public park or recreational space per 1,000 residents, the Project would need to provide a total of 11.4 acres. The Project would meet a significant portion of this increased need through provision of 7.5 acres of publicly accessible open space and common areas, which equates to providing 2 acres of publicly accessible open space per 1,000 residents. These publicly accessible areas include active spaces, such as walkways and a fitness loop, and passive open spaces, such as pocket parks and gathering areas for outdoor programming. Additionally, the Project would provide 6.3 acres of private outdoor and amenity spaces, including outdoor balconies and patios, pools and spas, communal gathering spaces, etc., totaling a combined 13.8 acres, or approximately 80 percent of the 17.2-acre Project site, of City Council 28 – 119 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 6-2
public and private outdoor and recreational space to the residents. This total 13.8 acres is anticipated to meet the potential park and recreation needs of the Project residents; however, the Project residents may also use park and recreational facilities that are in the vicinity of the Project site. Such additional park visits may result in physical deterioration of recreational facilities due to the increased foot traffic and usage of park facilities. Such wear on facilities would be expected to contribute to the need for maintenance activities including, but are not limited to: replacement or fixing of picnic area tables and trash receptacles; painting and equipment maintenance of basketball, tennis, swimming, and other sports facilities; upkeep on playfield, trail, and landscaped areas; and maintenance of restroom and parking areas.

Nonetheless, the Project would meet the City’s 2022 Parks Master Plan short-range goal of providing 1.5 acres of parkland per 1,000 residents and comply with applicable municipal code requirements and Regulatory Requirement (RR) REC-1 requiring residential development fees for the acquisition, construction, and renovation of park and recreation facilities pursuant to Santa Ana Municipal Code Section 35-108 of Chapter 35, Article 4, and Sections 35-110 and 35-111 of Chapter 35, Article 4. The Project would contribute additional public park and recreation space to the City’s available public parkland and recreational spaces at a ratio of 2 acres per 1,000 residents, which is higher than the 1.2 ratio assessed for the GPU buildout, in the GPU PEIR.

Moreover, the Project would provide tax revenues to the City, including contributions to the applicable community facilities district, for park maintenance that would help offset the additional deterioration occurring from the Project residents. Taken together, the Project’s proposed 13.8 acres of outdoor and recreational space (comprised of 7.5 acres of publicly accessible open space and 6.3 acres of private outdoor and amenity spaces), combined with the payment of applicable fees and tax revenues serve to reduce potential impacts discussed in the GPU PEIR. Regardless, since the Project would not fully meet the GPU policy of providing 3 acres of parkland and recreation facilities per 1,000 residents, it is reasonably foreseeable that the Project would result in the increased use of existing parks and recreational facilities in a manner that results in accelerated substantial physical deterioration of the facilities.

Furthermore, the City of Santa Ana is essentially fully built out and there is a lack of available vacant land to develop substantial new parks or expand existing facilities. Therefore, as identified in the GPU PEIR, there would be no feasible mitigation measures that would be able to reduce this significant impact, or the project’s contribution thereto, to a less-than-significant level. As such, impacts would be significant and unavoidable, which is consistent with the findings of the GPU PEIR.

Threshold R-2: The Project would include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

Findings: The City finds that specific economic, legal, social, technological, or other considerations make infeasible the mitigation measures or project alternatives identified in the Final Supplemental EIR. While changes or alterations have been required in, or incorporated into, including regulatory requirement RR REC-1 (listed above), the Project to address this significant effect on the environment, no feasible mitigation measures exist to reduce impacts to a less-thansignificant level. However, pursuant to PRC Section 21081(a)(3), as described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable based on specific overriding considerations found in Chapter 8 below.

City Council 28 – 120 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 6-3
Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.12, Recreation, pages 4.12-13 through 4.12-15 of the Draft Supplemental EIR. The following presents a summary of that rationale:

The Project would provide 7.5 acres of public park/recreation and open space, which when considering the Project’s 3,815 residents at maximum buildout, results in a ratio of 2 acres per 1,000 residents, which is higher than the 1.2 ratio (based on 516.86 acres for 431,629 residents) assessed in the GPU PEIR for the GPU buildout. Further, the Project would be developing this park/recreation and open space in the South Bristol Street Focus Area, an area identified by the GPU PEIR and the 2022 Parks Master Plan that is deficient in public parkland and recreational resources. Additionally, the Project would be required to pay applicable fees pursuant to Municipal Code Section 35-108 of Chapter 35, Article 4, and Sections 35-110 and 35-111 of Chapter 35, Article 4, in accordance with RR REC-1, to be used towards the future expansion or renovation of parks and recreational facilities in the City, as well as other applicable community facilities district fees assessed to maintain park facilities.

However, as previously discussed, the Project’s provision of parkland would not fully meet the GPU policy to provide a ratio of 3 acres of parkland for every 1,000 residents. While development of the Project would not result in significant unmitigable impacts to the environmental resources such as air quality, cultural resources, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, noise, transportation, and tribal cultural resources, development and operation of future new or expanded recreational facilities may have an adverse physical effect on the environment, including impacts relating to air quality, biological resources, lighting, noise, and traffic. Consequently, impacts from the Project would be potentially significant.

As discussed in the GPU PEIR, the City of Santa Ana is essentially fully built out and there is limited available land to develop new parks or expand existing facilities, and there would be no feasible mitigation measures that would reduce significant impacts related to the City’s parkland to resident ratio to a less-than-significant level. The Project is consistent with the buildout envisioned in the GPU for the Project area, which was analyzed in the GPU PEIR along with buildout of the City and found to result in significant and unavoidable impacts related to related to recreation, based on the possibility that future project-specific developments could result in significant, adverse physical effects on the environment. The Project’s provision of 7.5 acres of public park and recreation facilities and applicable fees would lessen the impact identified in the GPU PEIR. Therefore, while the Project would contribute to the significant and unavoidable recreation impacts disclosed in the GPU PEIR, the Project would not result in a substantial increase in the severity of the previously identified impacts and would not result in any new significant impacts.

Cumulative Impacts: The Project would result in cumulative impacts concerning recreation.

Findings: The City finds that specific economic, legal, social, technological, or other considerations make infeasible the mitigation measures or project alternatives identified in the Final Supplemental EIR. While changes or alterations have been required in, or incorporated into, including regulatory requirement RR REC-1 (listed above), the Project to address this significant effect on the environment, no feasible mitigation measures exist to reduce impacts to a less-thansignificant level. However, pursuant to PRC Section 21081(a)(3), as described in the Statement City Council 28 – 121 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 6-4
of Overriding Considerations, the City has determined that this impact is acceptable based on specific overriding considerations found in Chapter 8 below.

Explanation of the Rationale: The rationale and facts supporting the above finding are fully developed in Section 4.12, Recreation, pages 4.12-15 through 4.12-18 of the Draft Supplemental EIR. The following presents a summary of that rationale:

Together with the contribution from the Project’s maximum buildout of 3,815 persons and 7.5 acres of publicly accessible parks/recreation facilities and open space, the Project plus the related projects would result in a total of 14,273 persons and 21.4 acres of publicly accessible park/recreation facilities and open space, for a ratio of 1.5 acres per 1,000 residents. While the Project and the related projects would improve the GPU buildout’s parkland-per-resident ratio and would be required to provide park and recreational facilities and/or pay in-lieu fees as required by the municipal code, due to the lack of available land to develop new parks or expand existing facilities, the ratio would still remain below the GPU’s parkland standard. For this reason, the Project’s incremental contribution relating to the deficiency of parkland within the City would be cumulatively considerable. No feasible mitigation measures were identified in the GPU EIR to reduce this impact to a less than significant level and there remain no feasible mitigation measures. While the Project’s incremental contribution to cumulative impacts related to recreation would improve the existing cumulative scenario and the impacts identified in the GPU PEIR, cumulative impacts to recreation resources would remain significant and unavoidable.

City Council 28 – 122 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 7-1
CHAPTER 7

FINDINGS REGARDING

SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL

CHANGES
Sections 15126(c) and 15126.2(c) of the CEQA Guidelines, require that an EIR address any significant irreversible environmental changes that would occur should the project be implemented. Generally, a project would result in significant irreversible environmental changes if any of the following would occur:
• The project would involve a large commitment of non-renewable resources; • The primary and secondary impacts of the project would generally commit future generations to similar uses;
• The project involves uses in which irreversible damage could result from any potential environmental accidents; or
• The proposed consumption of resources is not justified.

Commitment of the Proposed Project’s Site for Future Generations The Project site is developed with existing commercial uses. Implementation of the Project would continue the commercial uses and also provide residential uses. Secondary effects associated with construction and operation of the Project include: emissions of air pollutants; consumption of non-renewable energy; and increased ambient noise due to increased activities. However, the Project implements land uses and activities that were envisioned and analyzed in the GPU PEIR, and as analyzed in the aforementioned sections, the Project would not result in unmitigable significant impacts beyond those identified in the GPU PEIR. As a result, the Project would not result in a new commitment of the Project site for future generations. (Draft Supplemental EIR, pp. 5-3 – 5-4.)
Large Commitment of Resources
Resources that would be consumed during Project construction include water, electricity, natural gas, fossil fuels, and building materials, such as lumber, cement, steel, copper, other metals, glass, aggregate, asphalt, and composite materials. However, the building materials would largely be used during construction and would not be further consumed during operations. Additionally, use of such resources would not be unusual compared with other construction projects and would not substantially affect the availability of such resources.

During operations, the proposed commercial and residential uses would consume utility resources, such as water, electricity, natural gas, and other petroleum-based fuels, as well as paints, solvents, and cleaner for normal maintenance activities, similar to other residential and commercial uses. The Project would not substantially affect the availability of such resources. (Draft Supplemental EIR, p. 5-4.)
City Council 28 – 123 9/16/2025
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IRREVERSIBLE ENVIRONMENTAL CHANGES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 7-2
Consumption of Resources
Construction and operation of the Project would require the use of both renewable and nonrenewable resources and construction materials. However, the Project would not involve the wasteful or unjustifiable use of non-renewable resources during construction or long-term operation. None of the building materials anticipated for the Project would be unique, rare, in short supply, or require creation of new resource extraction sites or new manufacturing and delivery channels. The Project would meet the most current and latest Title 24 standards for energy efficiency and incorporate all applicable energy efficiency measures (solar panels, high efficiency lighting, energy efficient appliances, etc.), which help to reduce energy consumption. The Project site is also located in a designated Transit Opportunity Corridor and would develop the site with residential, commercial, office, and recreation opportunities that would encourage use of public transportation. Further, implementation of the Project would also satisfy the achievement of the Project objectives, which includes objectives that are beneficial to the growth and prosperity of the City. (Draft Supplemental EIR, p. 5-4.)
Irreversible Environmental Damage
Construction and long-term operation of the Project would involve the limited transport, storage, use, and disposal of hazardous materials related to typical residential and commercial uses.

However, all hazardous materials used on the Project site would be used, stored, and disposed of in accordance with manufacturer’s standards and all applicable federal, state, and local requirements such as those set forth by the California Occupational Safety and Health Administration, California Emergency Management Agency, California Department of Toxic Substances Control, and the Orange County Environmental Health Division of the Health Care Agency. Further, the Phase I Environmental Site Assessment prepared for the Project did not identify recognized environmental conditions at the site that would create significant hazards to the public and environment. Therefore, the Project would not involve uses in which irreversible damage could result from a potential environmental accident associated with the Project. (Draft Supplemental EIR, pp. 5-4 – 5-5.)
City Council 28 – 124 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 8-1
CHAPTER 8

FINDINGS REGARDING

GROWTH-INDUCING IMPACTS
Section 15126.2(e) of the State CEQA Guidelines requires a Draft EIR to discuss the ways the Project could foster economic or population growth or the construction of additional housing, directly or indirectly, in the surrounding environment. In accordance with State CEQA Guidelines Section 15126.2(e), a Project would be considered to have a growth-inducing effect if it would:
• Directly or indirectly foster economic or population growth, or the construction of additional housing in the surrounding environment;
• Remove obstacles to population growth (e.g., construction of an infrastructure expansion to allow for more construction in service areas); • Tax existing community service facilities, requiring the construction of new facilities that could cause significant environmental effects; or
• Encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively.

In addition, State CEQA Guidelines states that that growth inducement must not be assumed.

State CEQA Guidelines Section 15126.2(e) states that growth-inducing effects are not to be construed as necessarily beneficial, detrimental or of little significance to the environment.

Therefore, the following analysis is provided as additional information on ways in which the Project could contribute to significant changes in the environment beyond the direct consequences of developing the land use concepts examined in the Draft Supplemental EIR.

Establish substantial new permanent employment opportunities or otherwise stimulate economic activity such that it would result in the need for additional housing, businesses, and services to support increased economic activities.

The Project would redevelop the site to provide up to 1,583 residential units (encompassing approximately 1,850,000 square feet of building space), 80,000 square feet of retail space, 300,000 square feet of office space, and approximately 7.5 acres of publicly accessible open space and common areas. Based on employment factors provided in the GPU PEIR, the proposed retail and office space would generate approximately 985 jobs, resulting in a generated net increase of 657 jobs compared to existing conditions. The generated net increase resulting from the Project would not exceed the projected increase for nonresidential uses and employment in the South Bristol Street Focus Area and therefore, would not result in unplanned employment growth.

In addition, the Project would slightly reduce (improve) the City’s jobs to housing ratio and would benefit the City by introducing multi-family housing to the project site in a jobs-rich area in which employees would be able to easily commute to nearby employment opportunities. Because the area is jobs-rich, the addition of residential units in the area would not require additional job growth. Therefore, the residential units would not indirectly result in the need for additional employment opportunities, which could result in unplanned growth.

City Council 28 – 125 9/16/2025
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Furthermore, jobs associated with the project’s retail and office uses would be filled to some extent by employees already residing in the vicinity of the Project. Residents and employees in the Project vicinity would have convenient access to sustainable multimodal transportation that would allow for walking, biking, and the use of existing transit, which could reduce vehicular trips and thus, reduce travel impacts related to traffic, air quality, and greenhouse gas emissions. In addition, as the Project would provide housing, it would not result in the need for additional housing. Implementation of the Project would stimulate economic activity as envisioned in the GPU in a manner that balances the City’s needs for housing, commerce, and recreation, without inducing unplanned growth. (Draft Supplemental EIR, p. 5-15.) Remove obstacles to growth, e.g., through the construction or extension of major infrastructure facilities that do not presently exist in the project area or would add substantial capacity that could accommodate additional unplanned growth.

The Project is an infill redevelopment of an existing commercial property in the SBSFA. Overall, the Project would redevelop the existing on-site infrastructure systems for water, water quality, wastewater, and stormwater utility improvements to meet project-related demand. The new infrastructure would not provide additional capacity beyond what is needed to serve the Project.

In addition, because the Project is within a developed area that is receiving services from existing utility infrastructure and would connect to the existing infrastructure, development of the Project would not result in an expansion of overall capacity, extension of infrastructure, or provision of services in areas or an unserved area. Therefore, implementation of the Project would not remove obstacles to growth or add substantial capacity that could accommodate additional unplanned growth. (Draft Supplemental EIR, pp. 5-15 – 5-16.)
Remove obstacles to growth through changes in existing regulations pertaining to land development.

Adoption of the Village Santa Ana Specific Plan, which contains the proposed development standards, permitted uses, and administrative processes for future development, pursues the envisioned buildout of the property as part of the City’s GPU Land Use Plan. The Project would be consistent with the land use designations proposed in the GPU PEIR, which allow for urban retail, residential, mixed-use, and employment centers with an intensity of up to 5.0 FAR and/or 125 dwelling units per acre.

Additionally, the Project’s estimated 3,659 residents would be 3.8 percent of the GPU PEIR’s estimated 96,855 persons resulting from Citywide growth, and the proposed 1,583 housing units would be 4.4 percent of the GPU PEIR’s estimated 36,261 housing units planned to be added Citywide. Therefore, the population and housing growth from the Project would not exceed the growth identified in the GPU PEIR. The Project would generate a net increase of 657 jobs which would not exceed the increase in 3,505,130 square feet of nonresidential space and 7,855 jobs projected for the SBSFA. Further, the Project would have a 0.42 jobs to housing ratio (i.e., 657 jobs to 1,583 housing units). The City of Santa Ana is jobs-rich with an existing jobs-housing ratio of 2.0. The Project would slightly reduce (improve) the jobs to housing ratio and would benefit the City by introducing multi-family housing to the Project site in a jobs-rich area in which employees would be able to easily commute to nearby employment opportunities. In addition, as the area is jobs-rich, the addition of residential units in the area would not require additional job growth. Thus, the resulting population, housing, and employment growth from the Project would not exceed the growth identified in the GPU PEIR, and no new substantial unplanned population growth would occur that was not previously analyzed in the GPU PEIR. Further, Therefore, the Project would City Council 28 – 126 9/16/2025
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not remove obstacles to growth through changes in existing regulations pertaining to land development. (Draft Supplemental EIR, pp. 5-16 – 5-17.) Result in the Need to Expand One or More Public Service Facilities to Maintain Desired Levels of Service
Implementation of the Project would result in increased demand for fire protection, police protection, school services, and recreational facilities. The provision of new or physically altered government facilities is typically associated with unplanned population growth or new residential development. Buildout of the Project would not increase demand beyond that assumed for buildout of the South Bristol Street Focus Area in the GPU PEIR, and thus, would not be considered unplanned population growth. Further, the Project would adhere to regulations and requirements such as undergoing site plan review by the Orange County Fire Authority and Santa Ana Police Department and payment of facility fees and developer/impact fees. Therefore, the Project would not result in the need to expand one or more public service facilities to maintain desired levels of service. (Draft Supplemental EIR, p. 5-17.) Involve Some Other Action that Could Encourage and Facilitate Other Activities that Could Significantly Affect the Environment
The Project involves a zoning amendment to replace the existing SD-48 zoning of the Project site; however, the proposed amendment is specific to the allowable land uses at the Project site. The Project would not propose changes to any of the City’s building safety standards (i.e., building, grading, plumbing, mechanical, electrical, or fire codes). The Project would comply with all applicable City plans, policies, and ordinances. In addition, project features and mitigation measures have been identified to reduce potential environmental impacts to the amount feasible.

Therefore, the Project would not involve some other action that could encourage and facilitate other activities that significantly affect the environment. (Draft Supplemental EIR, p. 5-17 – 5-18.) City Council 28 – 127 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 9-1
CHAPTER 9

FINDINGS REGARDING

PROJECT ALTERNATIVES
The Draft Supplemental EIR analyzed three alternatives to the Project as proposed and evaluated these alternatives for their ability to avoid or reduce the Project’s significant environmental effects while also meeting the majority of the Project’s objectives. The City finds that it has considered and rejected as infeasible the alternatives identified in the EIR and described below. This section sets forth the potential alternatives to the Project analyzed in the EIR and evaluates them in light of the Project objectives, as required by CEQA.

Where significant impacts are identified, section 15126.6 of the State CEQA Guidelines requires EIRs to consider and discuss alternatives to the proposed actions. Subsection (a) states:
(a) An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

Subsection 15126.6(b) states the purpose of the alternatives analysis:
(b) Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section 21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.

In subsection 15126.6(c), the State CEQA Guidelines describe the selection process for a range of reasonable alternatives:
(c) The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the Project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. Additional information explaining the choice of alternatives may be included in the administrative record.

Among the factors that may be used to eliminate alternatives from detailed City Council 28 – 128 9/16/2025
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consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.

The range of alternatives required is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed Project. Alternatives are limited to ones that would avoid or substantially lessen any of the significant effects of the Project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the Project.

As set forth in these findings, the implementation of the Project would not in result in significant impacts that are considered unavoidable, with the exception of impacts related to recreation. In making the alternatives findings below, the City of Santa Ana certifies that it has independently reviewed and considered the information on alternatives provided in the EIR, including the information provided in the comments on the Draft Supplemental EIR and the responses thereto.

9.1 DISCUSSION OF ALTERNATIVES CONSIDERED BUT REJECTED
Section 15126.6(c) of the State CEQA Guidelines specifies that an EIR should (1) identify alternatives that were considered by the lead agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process; and (2) briefly explain the reasons underlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives; (ii) infeasibility; and/or (iii) inability to avoid significant environmental impacts.

Alternatives that were considered but rejected during the scoping process for detailed evaluation in Section 6.5 Alternatives Considered but Rejected of the Draft Supplemental EIR are discussed below:

9.1.1 Buildout of the Zoning Designation Alternative
The Buildout of the Zoning Designation Alternative would entail buildout of the project site pursuant to the standards and regulations in the City’s SD-48, amended in January 1989.1 The SD-48 permitted uses include, but are not limited to, retail specialty, office, restaurants, specialty markets, beauty salons, banks, and theaters. Conditional uses permitted included live dance entertainment and alcoholic beverage sales. The SD-48 also includes development standards for parking for land use types, building setbacks (at a minimum of 15 feet), height (at a maximum of 35 feet), landscaping, signage, and building uses. The project site is currently occupied by the South Coast Plaza Village commercial center on both sides of South Plaza Drive which consists of approximately 164,049 square feet of retail shops and restaurants, offices, and the Regency Theatres cinema building. The majority of the buildings are at the maximum height of 35 feet. The property also provides surface parking, a variety of trees and a half-acre open space lawn area.

Therefore, the existing development at the project site is reflective of the standards established under SD-48. It is not realistic that the site would be redeveloped with new or modified commercial uses consistent with the existing SD-48 zoning. Additionally, the permitted uses under the SD-48 do not allow for residential, office, or open space uses. 1 City of Santa Ana, January 17, 1989, Specific Development No. 48, Amendment Application 1017 NS-1997.

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Finding: The City Council rejects the Buildout of the Zoning Designation Alternative, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) this alternative would not achieve the basic project objectives of developing a residential mixed-use residential project and would not implement the GPU’s vision for the South Bristol Street Focus Area; and (2) the alternative is technically, financially, and legally infeasible given that the existing development at the Project site is reflective of the standards established under SD-48 and it is not realistic the site would be redeveloped with new or modified commercial uses consistent with the existing SD-48 zoning Thus, this alternative was eliminated from further consideration

9.1.2 Off-Site Alternative
According to State CEQA Guidelines Section 15126.6[f][2][A], only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR. The Project would not cause any new significant impacts or substantial increase in previously identified significant impacts from those identified in the GPU PEIR.

As discussed in the project objectives, a fundamental purpose of building out the Project at the selected Project site is to implement the vision and objectives established in the City of Santa Ana General Plan for the South Bristol Street Focus Area, primarily to transform auto-oriented shopping plazas into walkable, bike-friendly, and transit-friendly urban villages. Thus, the Project would redevelop an existing auto-oriented plaza that has already been disturbed by previous uses and is served by existing services, avoiding the need for new construction at an undeveloped site.

Additionally, due to their age, the existing buildings at the South Coast Plaza Village have outdated infrastructure, which results in operational inefficiencies and outdated seismic code compliance.

The Project site is located in a fully developed urban area of the City of Santa Ana and acquiring off-site property may not be financially reasonable or logistically feasible. Acquiring new property outside of the existing project site would also not eliminate the need to transform the existing autooriented shopping plazas in the South Bristol Street Focus Area into urban villages. Furthermore, there are limited, if any available properties comparable to the Project site of sufficient size, dimensions, and land use designation (District Center), and without existing residences that would otherwise require displacement within the GPU-identified South Bristol Street Focus Area and South Coast Metro Area that would allow for high-intensity mixed uses.

Finding: The City Council rejects the Off-Site Alternative, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) the alternative would not meet project objectives; and (2) acquiring off-site property may not be financially reasonable or logistically feasible. For these reasons, this alternative has been eliminated from further consideration.

9.2 ALTERNATIVES SELECTED FOR FURTHER ANALYSIS
The following alternatives were selected for evaluation in Section 6.6 Alternatives Selected for Further Analysis of the Draft Supplemental EIR:
• Alternative 1: No Project/No Build Alternative
• Alternative 2: Reduced Project Alternative
• Alternative 3: Reduced Project with No Subterranean Parking Alternative City Council 28 – 130 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 9-4
Table 9-1: Summary Comparison of the Impacts of the Alternatives provides, in summary format, a comparison between the level of impacts for each alternative and the Project. In addition, Table 9-2: Summary Comparison of the Alternatives’ Ability to Meet Project Objectives provides a comparison of the ability of each of the alternatives to meet the objectives of the Project.

9.2.1 Alternative 1: No Project/No Build
Pursuant to State CEQA Guidelines Section 15126.6(e), the EIR is required to evaluate and analyze the impacts of a No Project Alternative. When the project is the revision of an existing land use or regulatory plan, policy, or ongoing operation, the No Project Alternative includes what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.

Further, State CEQA Guidelines Section 15126.6(e)(3)(B) states, “In certain instances, the no project alternative means ‘no build’ wherein the existing environmental setting is maintained.” In addition, the No Project/No Build Alternative includes what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.

Therefore, under this alternative, no new development would occur on the project site, and the site would remain in its existing condition as the South Coast Plaza Village with seven existing buildings, totaling approximately 164,049 square feet of existing commercial retail uses, with surface parking and landscaping. In this alternative scenario, the seven buildings are assumed to be fully operational as a shopping plaza with multiple retail uses, a restaurant, and a movie theater. (Draft Supplemental EIR, p. 6-7.)
Environmental Effects: The No Project/No Build Alternative would result in the continued operation of the existing South Coast Plaza Village, containing seven commercial buildings, surface parking, and landscaping. Development and operation of the proposed mixed-use development would not occur. As a result, the No Project/No Build Alternative would result in reduced impacts related to construction and operation compared to the Project and would not require the mitigation measures related to air quality, cultural resources, geology and soils, noise, and tribal cultural resources. However, the benefits of the Project would also not occur, including implementation of the GPU South Bristol Street Focus Area objectives; improvements to roadway, pedestrian, bicycle infrastructure; low impact development (LID) -compliant infrastructure improvements; provision of housing within a Transit Priority Area (TPA); and improvements to the jobs/housing balance. Further, the No Project/No Build Alternative would not build out the GPU’s DC-5 designation as a major development activity area and anchor to the City’s commercial corridors and would not implement the GPU South Bristol Street Focus Area vision and objectives, or the SCAG policies promoting high-density, infill development. This alternative also would not assist in the improvement of the job/housing balance or reduction in vehicle miles traveled (VMT).

Therefore, this alternative would not be consistent with the GPU and would not implement the City’s land use plan to the same extent as the Project. Impacts under the No Project/No Build Alternative related to land use would be greater than the less-than-significant impacts of the Project. Generally, the impacts of the No Project/No Build Alternative would be less in severity than those of the Project and would not require implementation of mitigation measures, with the exception of land use and planning; however, this alternative would not implement the benefits resulting from the Project. (Draft Supplemental EIR, pp. 6-8 – 6-13.) City Council 28 – 131 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 9-5
Attainment of Project Objectives: The No Project/No Build Alternative not meet any of the project objectives listed in Section 2.3, Project Objectives. The No Project/No Build Alternative would continue the operation of the existing South Coast Plaza Village and maintain the existing seven commercial buildings and surface parking. The No Project/No Build Alternative would not implement the mixed-use development, containing integrated residential and commercial uses, which contributes to the creation of a vibrant urban core by enhancing community amenities, recreational, and open space areas and providing alternative transportation and mobility options in the GPU South Bristol Street Focus Area. The Project site would remain a conventional autooriented shopping plaza with large surface parking areas. (Draft Supplemental EIR, pp. 6-13 – 6-14.)
Findings: The City Council rejects Alternative 1: No Project/No Build Alternative, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative:
(1) the alternative fails to meet any of the basic Project objectives; (2) the alternative would result in increased impacts relating to land use and planning; and (3) the alternative is infeasible.

9.2.2 Alternative 2: Reduced Project Alternative
The Reduced Project Alternative would reduce the commercial square footage, change the residential mix to reduce the number of residents, and remove the office uses from the mixed use development to minimize operational impacts to volatile organic compounds associated with area sources and construction-related impacts related to ground disturbance. Alternative 2 would reduce the total commercial square footage to 50,000 square feet, provide 1,433 multi-family residential units and 150 senior (age restricted) living units, and provide 7.5 acres of publicly accessible parks/recreation facilities and open space. To support the Reduced Project Alternative’s mix of uses, the total number of parking stalls would be reduced to 2,296 stalls.

Further, the total amount of bicycle stalls would be reduced to 138 stalls. Maximum excavation depths would reach 14 feet below ground surface (bgs) for one level of subterranean parking under this alternative. (Draft Supplemental EIR, p. 6-14.) Environmental Effects: The Reduced Project Alternative would result in a reduced magnitude of construction-related impacts to air quality, GHG emissions, and noise. However, as with the Project, impacts would still be less than significant or less than significant with mitigation, which would be similar to those of the Project due to the similar types of construction activities.

During operation, the Reduced Project Alternative would be expected to result in reduced emissions of criteria pollutants and GHGs, energy consumption, vehicle miles traveled, overall population, and demand for public services, parks, and utility services. The overall reduction in volume of these factors would occur primarily due to the reduced commercial square footage elimination of office uses, and the replacement of some standard residential units with senior living residences. The Reduced Project Alternative would provide 7.5 acres of publicly accessible parks/recreation facilities and open space, resulting in a slightly higher recreation-to-resident ratio of 2.1 acres per 1,000 residents than the Project. However, significant and unavoidable impacts to recreation would remain. Although the volume of impacts would be reduced by the Reduced Project Alternative in comparison to the Project, the Reduced Project Alternative would not eliminate the significant and unavoidable recreation impacts or the less than significant impacts of the Project. (Draft Supplemental EIR, pp. 6-14 – 6-20.) Attainment of Project Objectives: The Reduced Project Alternative would meet the project objectives, but not to the same extent as the Project. The Reduced Project Alternative would still transform the conventional auto-oriented shopping plaza with large surface parking areas to a City Council 28 – 132 9/16/2025
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mixed-use development. However, this alternative would not maximize the opportunities to the same extent as the Project as described in the Project objectives to incorporate a mix of highintensity office and residential living with experiential commercial uses as there would be fewer retail services and no office uses. Although this alternative would still provide new retail services and associated jobs, the fewer retail services would result in a net decrease of jobs from existing conditions and would not complement the South Coast Metro area with a diversity of new housing in a jobs-rich environment as strongly as the Project. (Draft Supplemental EIR, p. 6-21.) Findings: The City Council rejects Alternative 2: Reduced Project Alternative, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative:
(1) the alternative fails to meet the basic Project objectives to the same extent as the proposed Project; and (2) the alternative fails to avoid or reduce the Project’s significant and unavoidable impacts relating to recreation.

9.2.3 Alternative 3: Reduced Project with No Subterranean Parking Alternative The Reduced Project with No Subterranean Parking Alternative would reduce residential and commercial uses and remove office space to minimize operational impacts to volatile organic compounds associated with area sources and avoid the construction-related impacts related to ground disturbance required for subterranean parking (i.e., excavations below 14 bgs). Alternative 3 would reduce the number of residential units to 1,000 units, the total commercial area to 25,000 square feet, and the publicly accessible parks/recreation facilities and open space to 6.8 acres.

This alternative would not include the proposed subterranean parking level and associated excavation activities and would reduce the overall length and magnitude of construction phasing.

Alternative 3 would construct two surface parking lots and a three-level parking garage in addition to the podium parking levels within the residential buildings. To support Alternative 3, a parking garage would be added to Block D (located in the northern central portion of the project site), and surface parking would be added to Blocks F and H (located in the eastern central portion and the center of the project site, respectively). The total amount of parking stalls would be reduced to 1,500 stalls, and the total amount of bicycle stalls would be reduced to 96 stalls. (Draft Supplemental EIR, p. 6-21.)
Environmental Effects: The Reduced Project with No Subterranean Parking Alternative would result in a reduced magnitude of impacts related to construction activities and resulting area and depth of ground disturbance. As such, construction impacts related to air quality, cultural resources, geology and soils, GHG emissions, noise, and tribal cultural resources would be reduced. However, as with the Project, impacts would still be less than significant or less than significant with mitigation, but residual impacts would be less when compared to those of the Project.

During operation, the Reduced Project with No Subterranean Parking Alternative would be expected to result in reduced emissions of criteria pollutants and GHGs, energy consumption, vehicle miles traveled, overall population, and demand for public services and utility services. The Reduced Project with No Subterranean Parking Alternative would provide 6.8 acres of publicly accessible parks/recreation facilities and open space, resulting in a higher recreation-to-resident ratio of 2.8 acres per 1,000 residents than the Project. However, significant and unavoidable impacts to recreation would remain. Although the volume of impacts would be reduced by the Reduced Project with No Subterranean Parking Alternative in comparison to the Project, the Reduced Project with No Subterranean Parking Alternative would not eliminate the significant and unavoidable recreation impacts or the less than significant impacts of the Project. (Draft Supplemental EIR, pp. 6-27 – 6-28.)
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Attainment of Project Objectives: The Reduced Project with No Subterranean Parking Alternative would not fully meet all of the project objectives. Though the Reduced Project with No Subterranean Parking Alternative would transform the conventional auto-oriented shopping plaza with large surface parking areas to a mixed-use development, this alternative would not maximize the opportunities as described in the project objectives as there would be fewer retail services and park space, no office uses, and no subsurface shared parking areas. The reduced commercial and removal of office uses would result in a net decrease of jobs from existing conditions that would not fully maximize the economic opportunities of the project site as encouraged by the GPU or complement the South Coast Metro area with a diversity of new housing in a jobs-rich environment. (Draft Supplemental EIR, p. 6-28.) Findings: The City Council rejects Alternative 3: Reduced Project with No Subterranean Parking Alternative, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) the alternative fails to meet the basic Project objectives to the same extent as the proposed Project; and (2) the alternative fails to avoid or reduce the Project’s significant and unavoidable impacts relating to recreation.

9.3 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires a lead agency to identify the “environmentally superior alternative” when significant environmental impacts result from a proposed project and, in cases where the “No Project” Alternative is environmentally superior to the project, the environmentally superior development alternative must be identified. The Environmentally Superior Alternative for the proposed project would be the No Project/No Build Alternative. When the No Project alternative is identified as the environmentally superior alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives. (State CEQA Guidelines, §15126.6(3)(1).) One alternative has been identified as “environmentally superior” to the Project:
the Reduced Project with No Subterranean Parking Alternative. The reduction or elimination of project components under this alternative would result in reduced impacts to operational air quality emissions, energy, GHG emissions, noise, population and housing, transportation, and demand for public services and utility services. The Reduced Project with No Subterranean Parking Alternative would still require mitigation measures during construction related to air quality, cultural resources, geology and soils, noise, and tribal cultural resources, though the residual impacts would be less than those of the Project.

Operation of the Reduced Project with No Subterranean Parking Alternative would still result in less than significant impacts that are similar when compared to the Project for hazards and hazardous materials, hydrology and water quality, and land use and planning. This alternative would also result in reduced operational air quality emissions, eliminating the need for the ProjectSpecific MM AQ-1. The Reduced Project with No Subterranean Parking Alternative would provide

6.8 acres of publicly accessible parks/recreation facilities and open space, resulting in a recreation-to-resident ratio of 2.8 acres per 1,000 residents which is higher than the 1.2 ratio of the GPU PEIR but lower than the GPU’s parkland standard of 3 acres per 1,000 residents. Thus, significant and unavoidable impacts to recreation would remain. Although the volume of impacts would be reduced by the Reduced Project with No Subterranean Parking Alternative in comparison to the Project, the Reduced Project with No Subterranean Parking Alternative would not eliminate the significant and unavoidable recreation impacts or the less than significant impacts of the Project. The Reduced Project with No Subterranean Parking Alternative would provide fewer residential units, retail services, and no office uses, and thus would implement the GPU South Bristol Street Focus Area objectives and many of the SCAG policies related to highCity Council 28 – 134 9/16/2025 9 FINDINGS REGARDING PROJECT ALTERNATIVES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 9-8
density, infill development, and improvement of the job/housing balance at a lesser extent than the Project. However, impacts to land use and planning would be less than significant and similar to those of the Project.

Overall, although the magnitude of impacts would be less under the Reduced Project with No Subterranean Parking Alternative in comparison to the Project, the Reduced Project with No Subterranean Parking Alternative would not eliminate the significant and unavoidable recreation impacts, the less than significant impacts of the Project, or the need for mitigation.

In addition, the Reduced Project with No Subterranean Parking Alternative would not fully meet all of the Project objectives. As previously discussed, though the Reduced Project with No Subterranean Parking Alternative would transform the conventional auto-oriented shopping plaza with large surface parking areas to a mixed-use development, this alternative would not maximize the opportunities as described in the Project objectives as there would be fewer retail services and park space, no office uses, and no subsurface shared parking areas. The reduced commercial and removal of office uses would result in a net decrease of jobs from existing conditions that would not fully maximize the economic opportunities of the Project site as encouraged by the GPU. Overall, with the exception of a few Project objectives, this alternative meets most of the Project objectives, but not to the same extent as the Project. (Draft Supplemental EIR, p. 6-29.)
City Council 28 – 135 9/16/2025
9 FINDINGS REGARDING PROJECT ALTERNATIVES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 9-9
Table 9-1: Summary Comparison of the Impacts of the Alternatives Impact Topic GPU PEIR Impact Project Impact
Alternative 1:

No Project/
No Build
Alternative
Alternative 2:

Reduced Project
Alternative
Alternative 3:

No Subterranean
Parking Alternative
Air Quality S/U LTS/M Less (NI) Less (LTS/M) Less (LTS/M) Cultural Resources S/U LTS/M Less (NI) Similar (LTS/M) Less (LTS/M) Energy LTS LTS Less (NI) Less (LTS) Less (LTS)
Geology and Soils LTS/M LTS/M Less (LTS) Similar (LTS/M) Less (LTS/M) Greenhouse Gas Emissions S/U LTS Similar (LTS) Less (LTS) Less (LTS) Hazards and Hazardous Materials LTS LTS Similar (LTS) Similar (LTS) Similar (LTS) Hydrology and Water Quality LTS LTS Similar (LTS) Similar (LTS) Similar (LTS) Land Use and Planning LTS LTS Greater (LTS) Similar (LTS) Similar (LTS) Noise S/U LTS/M Less (LTS) Less (LTS/M) Less (LTS/M)
Population and Housing S/U LTS Less (NI) Less (LTS) Less (LTS) Public Services LTS LTS Less (NI) Less (LTS) Less (LTS) Recreation S/U S/U* Less (NI) Similar (S/U*) Less (S/U*) Transportation LTS LTS Similar (NI) Less (LTS) Less (LTS) Tribal Cultural Resources LTS/M LTS/M Less (NI) Similar (LTS/M) Less (LTS/M) Utilities and Service Systems LTS LTS Less (LTS) Less (LTS) Less (LTS) Notes: LTS = Less than Significant; LTS/M = Less than Significant with Mitigation; NI = No Impact; S/U = Significant and Unavoidable *Impacts do not increase the severity of the impacts identified in the GPU PEIR.

Source: Michael Baker International, 2025.

City Council 28 – 136 9/16/2025
9 FINDINGS REGARDING PROJECT ALTERNATIVES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 9-10
Table 9-2: Summary Comparison of the Alternatives’ Ability to Meet Project Objectives Objective Proposed
Project
Alternative 1:

No Project/
No Build
Alternative
Alternative 2:

Reduced Project
Alternative
Alternative 3:

No Subterranean
Parking
Alternative
Implement the vision and objectives established in the City of Santa Ana General Plan for the South Bristol Street Focus Area as the City’s southern gateway and part of the South Coast Metro area by creating opportunities to transform auto-oriented shopping plazas to walkable, bike-friendly, and transit-friendly urban villages that incorporate a mix of high-intensity office and residential living with experiential commercial uses. The following are based on the South Bristol Street Focus Area objectives:
• Capitalize on the success of the South Coast Metro area; • Introduce mixed-use urban villages and encourage experiential commercial uses that are more walkable, bike friendly, and transit oriented;
• Provide for mixed-use opportunities while protecting adjacent, established low density neighborhoods
Yes No
Yes, but not to the
same extent as the
proposed project (no
high-intensity office)
Yes, but not to the
same extent as the
proposed project
(no high-intensity
office)
Foster a neighborly environment that blends healthy living, working, shopping, and dining in a contemporary village environment. Yes No Yes, but not to the
same extent as the
proposed project
(reduced commercial
and removal of office
uses)
Yes, but not to the
same extent as the
proposed project
(reduced
commercial and
removal of office
uses)
Anchor the South Bristol Street Focus Area, as envisioned by the City, by transforming conventional auto-oriented shopping plazas with large surface parking areas to a community that maximizes opportunities for onsite open space which can be accomplished through the provision of subsurface shared parking and intensity of land use permitted by the General Plan.

Yes No
Yes, but not to the
same extent as the
proposed project
(reduced to one level
of subterranean
parking)
No
City Council 28 – 137 9/16/2025
9 FINDINGS REGARDING PROJECT ALTERNATIVES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 9-11
Table 9-2: Summary Comparison of the Alternatives’ Ability to Meet Project Objectives Objective Proposed
Project
Alternative 1:

No Project/
No Build
Alternative
Alternative 2:

Reduced Project
Alternative
Alternative 3:

No Subterranean
Parking
Alternative
Capture Orange County’s indoor-outdoor lifestyle through attention to detail in the design of buildings, selection of materials, infusion of nature in outdoor spaces, and the activities offered in the Village.

Yes No Yes Yes
Builds on the foundation of dynamic areas through new experiences in food, fitness, and artisan retail. Yes No
Yes, but not to the
same extent as the
proposed project
(fewer retail services
may not include food,
fitness, or artisan
retail)
Yes, but not to the
same extent as the
proposed project
(fewer retail
services)
Complements the successful South Coast Metro area with a diversity of new housing in a jobs-rich environment. Yes No
Yes, but not to the
same extent as the
proposed project
(would result in a net
decrease of jobs from
existing)
Yes, but not to the
same extent as the
proposed project
(would result in a
net decrease of
jobs from existing)
Attracts the innovative and start-up culture of Orange County and provides thoughtfully designed spaces to create and showcase new offerings.

Yes No
Yes, but not to the
same extent as the
proposed project
(reduced commercial
and removal of office
uses)
Yes, but not to the
same extent as the
proposed project
(reduced
commercial and
City Council 28 – 138 9/16/2025
9 FINDINGS REGARDING PROJECT ALTERNATIVES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 9-12
Table 9-2: Summary Comparison of the Alternatives’ Ability to Meet Project Objectives Objective Proposed
Project
Alternative 1:

No Project/
No Build
Alternative
Alternative 2:

Reduced Project
Alternative
Alternative 3:

No Subterranean
Parking
Alternative
removal of office
uses)
Complements and does not compete with the emerging business environment of Downtown Santa Ana. Yes No Yes Yes
Allow for the flexible redevelopment of the underutilized Project site to provide a balanced mix of residential and commercial uses in the South Bristol Street Focus Area that integrate into the existing urban systems and provide a safe and attractive environment for living and working, as encouraged by the GPU.

Yes No
Yes, but not to the
same extent as the
proposed project
(reduced commercial
and removal of office
uses)
Yes, but not to the
same extent as the
proposed project
(reduced
residential/commer
cial and removal of
office uses)
Develop high quality residential spaces that reflect modern lifestyles, while responding to the vision of the GPU to help bring higher density housing into a jobs-rich area of the City planned for growth, to facilitate balancing the City’s jobs-housing ratio.

Yes No
Yes, but not to the
same extent as the
proposed project
(reduced commercial
and removal of office
uses)
Yes, but not to the
same extent as the
proposed project
(reduced
residential/commer
cial and removal of
office uses)
Provide a positive contribution to the local economy through new capital investment, attraction of economic activity, and the expansion of the tax base.

Yes No
Yes, but not to the
same extent as the
proposed project
(reduced commercial
and removal of office
uses)
Yes, but not to the
same extent as the
proposed project
(reduced
commercial and
removal of office
uses)
Enhance alternative transportation activity by creating a walkable and bikeable mixed-use development that links with existing facilities and Yes No Yes Yes City Council 28 – 139 9/16/2025
9 FINDINGS REGARDING PROJECT ALTERNATIVES
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 9-13
Table 9-2: Summary Comparison of the Alternatives’ Ability to Meet Project Objectives Objective Proposed
Project
Alternative 1:

No Project/
No Build
Alternative
Alternative 2:

Reduced Project
Alternative
Alternative 3:

No Subterranean
Parking
Alternative
transit services to encourage non-automotive travel within the Specific Plan area and the local community.

Provide a project that contributes to the creation of a vibrant urban core for the City by providing engaging and attractive community amenities, recreational and open space areas, and gathering spaces that serve both residents of the project and the surrounding community.

Yes No Yes Yes
Create new open space and community-serving recreational amenities in an identified park-deficient area. Yes No Yes Yes
Source: Michael Baker International, 2025.

City Council 28 – 140 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 10-1
CHAPTER 10

STATEMENT OF

OVERRIDING CONSIDERATIONS

10.1 INTRODUCTION
The City of Santa Ana is the Lead Agency under CEQA for preparation, review and certification of the Supplemental EIR for proposed The Village Santa Ana Specific Plan Project (proposed Project or The Village). As the Lead Agency, the City is also responsible for determining the potential environmental impacts of the proposed action and which of those impacts are significant, and which can be mitigated through imposition of mitigation measures to avoid or minimize those impacts to a level of less than significant. CEQA then requires the Lead Agency to balance the benefits of a proposed action against its significant unavoidable adverse environmental impacts in determining whether or not to approve the proposed Project. In making this determination the City is guided by State CEQA Guidelines Section 15093, Statement of Overriding Considerations, which states:
a) CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.” b) When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the final EIR and/or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. c) If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091.

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

Pursuant to Public Resources Code Section 21081(b) and the State CEQA Guidelines Section 15093, the City has balanced the benefits of the proposed Project against the unavoidable adverse impacts associated with the Project and has adopted all feasible mitigation measures with respect to these impacts. The City also has examined alternatives to the Project, none of which both meet the Project objectives and are environmentally preferable to the Project for the City Council 28 – 141 9/16/2025
10 STATEMENT OF OVERRIDING CONSIDERATIONS
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 10-2
reasons discussed in the Findings (as described in Chapter 7, Findings Regarding Project Alternatives).

The City of Santa Ana, as the Lead Agency for this Project, and having reviewed the information contained in The Village Santa Ana Specific Plan Draft Supplemental EIR and the Final Supplemental EIR, including responses to comments, and reviewed all written materials within the City’s public record and heard all oral testimony presented at public hearings, adopts this Statement of Overriding Considerations, which has balanced the benefits of the Project against the significant unavoidable adverse environmental impacts in reaching its decision to approve the Project.

10.2 SIGNIFICANT UNAVOIDABLE IMPACTS
Although all potential project impacts have been substantially avoided or mitigated as described in the preceding findings, there is no complete mitigation for the Project impacts related to recreation. Details of the significant unavoidable adverse impacts related to recreation were discussed in the Supplemental EIR and are summarized or were otherwise provided in the CEQA Findings of Fact (as described above).

10.3 PROJECT BENEFITS
The City, after balancing the specific economic, legal, social, technological, and other benefits of the Project, has determined that the unavoidable adverse environmental impacts identified above are considered acceptable due to the following specific considerations which outweigh the unavoidable, adverse environmental impact of the Project, each of which standing alone is sufficient to support approval of the Project, in accordance with Public Resources Code Section 21081(b) and State CEQA Guidelines Section 15093. The specific economic, legal, social, technological, or other benefits of the Project are as follows:
• The Project implements the vision of the General Plan for the South Bristol Street Focus Area by:
o Capitalizing on the success of the South Coast Metro area; o Introducing mixed-use urban villages and encouraging experiential commercial uses that are more walkable, bike friendly, and transit-oriented; o Providing for mixed-use opportunities while protecting adjacent, established low density neighborhoods.
• The Project fosters a neighborly environment where residents can live, work, and recreate in a vibrant village community.
• The Project anchors Santa Ana’s South Bristol Street Focus Area as envisioned by the City to transform conventional auto-oriented shopping plazas into dynamic nodes of activity that blend healthy living, working, shopping, and dining in a contemporary village environment with 7.5 acres of publicly accessible open space and common areas which captures Orange County’s indoor-outdoor lifestyle.
• The Project allows for the flexible redevelopment of the underutilized project site to provide a balanced mix of residential, retail, recreation, and office uses in the South Bristol Street Focus Area that integrate into the existing urban systems and provide a safe and attractive environment for living and working, as encouraged by and consistent with the GPU.

City Council 28 – 142 9/16/2025
10 STATEMENT OF OVERRIDING CONSIDERATIONS
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 CEQA Findings of Fact and Statement of Overriding Considerations 10-3
• The Project will redevelop the underutilized and currently vehicle-centric site by introducing a mixed-use development within a Pedestrian Opportunity Zone by developing sidewalks, pedestrian pathways, and a fitness loop to encourage pedestrian mobility to reduce overall VMT compared to the existing conditions. • The Project provides a positive contribution to the local economy through new capital investment, the creation of new jobs, development of more commercial opportunities, attraction of economic activity, and the expansion of the tax base. • The Project develops high quality residential spaces that reflect modern lifestyles, while responding to the vision of the GPU to help bring higher density housing into a jobs-rich area of the City planned for growth, to facilitate balancing the City’s jobs-housing ratio. • The Project includes new residential and mixed-use buildings that would provide housing opportunities for residents in the City’s South Bristol Street Focus Area which complements the successful South Coast Metro area with a diversity of new housing in a jobs-rich environment and implements the goals and policies of SCAG’s Regional Transportation Plan/Sustainable Communities Strategy.
• The Project enhances alternative transportation activity by creating a walkable and bikeable mixed-use development that links with existing facilities and transit services to encourage non-automotive travel within the Specific Plan area and the local community. • The Project contributes to the creation of a vibrant urban core for the City by providing vibrant and attractive community amenities, recreational and open space areas, and gathering spaces that are directly accessible to residents and the community, and takes advantage of the site’s location within the South Coast Metro area. • The Project provides community benefits commensurate with the Specific Plan development proposal including public open space onsite and locations for public community events, as well as streetscape improvements along the Project site frontages of Sunflower Avenue and Bear Street.

10.4 CONCLUSION
The City Council finds that each of the specific economic, legal, social, technological, environmental, and other considerations, and the benefits of the Project separately and independently outweigh the remaining significant, adverse impacts related to recreation and is an overriding consideration independently warranting approval of the Project. The remaining significant adverse impacts identified in Chapter 6 above, are acceptable in light of each of these overriding considerations, and the substantial evidence that supports the enumerated benefits of the Project can be found in the Findings of Fact herein, the Final Supplemental EIR, the Project itself, and the record of all proceedings in connection with the approval of the Project. In the event that any court decision or regulatory action results in a determination that there are additional remaining significant impacts resulting from the City’s approval of the Project that cannot be avoided even with the incorporation of all feasible mitigation measures into the Project, the CEQA Findings of Fact and Statement of Overriding Considerations herein shall be deemed to apply to such additional remaining significant impacts.

City Council 28 – 143 9/16/2025
City Council 28 – 144 9/16/2025
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-1
CHAPTER 4

MITIGATION MONITORING AND REPORTING

PROGRAM
The California Environmental Quality Act (CEQA) requires a lead or public agency that approves or carries out a project for which an Environmental Impact Report has been certified which identifies one or more significant adverse environmental effects and where findings with respect to changes or alterations in the project have been made, to adopt a “reporting or monitoring program for the changes to the project which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment” (CEQA, Public Resources Code Sections 21081, 21081.6). In compliance with these requirements, the City of Santa Ana, lead agency, has prepared the Mitigation Monitoring and Reporting Program (MMRP) to ensure that adopted mitigation measures are successfully implemented for the Village Santa Ana Specific Plan Project (project). The MMRP for the project, presented as Table 4-1, lists the mitigation measures by environmental topic and identifies the timing for each measure, the responsible party, and the monitoring party. The City of Santa Ana is the lead agency for the project and is responsible for implementation of the MMRP.

Any modifications to the terms and/or timing of the mitigation measures in this MMRP shall provide a level of environmental protection equal to, or greater than the approved mitigation measure.

The City of Santa Ana, in conjunction with any appropriate agencies or City departments, shall determine the adequacy of any proposed modifications and, if necessary, may refer said determination to the Planning Commission and/or City Council. Any costs associated with information required to make a determination of adequacy shall be borne by the Applicant. No changes to the MMRP shall be permitted unless the MMRP continues to satisfy the requirements of CEQA as determined by the City, the lead agency for the project.

City Council 28 – 145 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-2
Table 4-1: Mitigation Monitoring and Reporting Program
Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance

AIR QUALITY
RR AQ-1 New buildings are required to achieve the current California Building Energy Efficiency Standards
(Title 24, Part 6) and California Green Building
Standards Code (CALGreen) (Title 24, Part 11).

The 2019 Building Energy
Efficiency Standards became effective January 1,
2020. The Building and Energy Efficiency
Standards and CALGreen are updated tri-annually
with a goal to achieve net zero buildings energy for
2030.

Prior to the
issuance of
occupancy
permits
Property Owner
or Project
Applicant
City of Santa
Ana Planning
Division
RR AQ-2 Construction activities will be conducted in
compliance with California Code of Regulations,
Title 13, Section 2449, which requires that
nonessential idling of construction equipment is
restricted to five minutes or less.

During
construction
Project
Applicant/
Construction
Contractor
City of Santa Ana
Building
Safety Division
RR AQ-3 Construction activities will be conducted in
compliance with any applicable South Coast Air
Quality Management District rules and regulations,
including but not limited to:
• Rule 403, Fugitive Dust, for controlling
fugitive dust and avoiding nuisance.
• Rule 402, Nuisance, which states that a
project shall not “discharge from any
source whatsoever such quantities of air
contaminants or other material which
cause injury, detriment, nuisance, or
annoyance to any considerable number of
persons or to the public, or which endanger
the comfort, repose, health or safety of any
such persons or the public, or which cause,
or have a natural tendency to cause, injury
or damage to business or property.”
Prior to
demolition and
during
construction
Project
Applicant/
Construction
Contractor
City of Santa Ana
Building
Safety Division
City Council 28 – 146 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-3
Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
• Rule 1113, which limits the volatile organic
compound content of architectural
coatings.
• Rule 1466, Soil Disturbance. Projects that
involve earth-moving activities of more
than 50 cubic yards of soil with applicable
toxic air contaminants are subject to this
rule.

GPU PEIR
MM AQ-1
Prior to discretionary approval by the City of Santa
Ana for development projects subject to CEQA
(California Environmental Quality Act) review (i.e.,
non-exempt projects), project applicants shall
prepare and submit a technical assessment
evaluating potential project construction-related
air quality impacts to the City of Santa Ana for
review and approval. The evaluation shall be
prepared in conformance with South Coast Air
Quality Management District (SCAQMD)
methodology for assessing air quality impacts. If
construction-related criteria air pollutants are
determined to have the potential to exceed the
SCAQMD’s adopted thresholds of significance,
the City of Santa Ana shall require that applicants
for new development projects incorporate
mitigation measures to reduce air pollutant
emissions during construction activities. These
identified measures shall be incorporated into all
appropriate construction documents (e.g.,
construction management plans) submitted to the
City and shall be verified by the City. Mitigation
measures to reduce construction-related
emissions could include, but are not limited to:
• Require fugitive-dust control measures
that exceed SCAQMD’s Rule 403, such
as:

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
Note: This
measure has been
satisfied with the
analysis in The
Village at Santa
Ana Supplemental
EIR, as described
on p. 4.1-38 of the
Draft
Supplemental EIR.

City Council 28 – 147 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-4
Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
o Use of nontoxic soil stabilizers to
reduce wind erosion.
o Apply water every four hours to
active soil-disturbing activities.
o Tarp and/or maintain a minimum
of 24 inches of freeboard on
trucks hauling dirt, sand, soil, or
other loose materials.
• Use construction equipment rated by the
United States Environmental Protection
Agency as having Tier 3 (model year
2006 or newer) or Tier 4 (model year
2008 or newer) emission limits, applicable
for engines between 50 and 750
horsepower.
• Ensure that construction equipment is
properly serviced and maintained to the
manufacturer’s standards.
• Limit nonessential idling of construction
equipment to no more than five
consecutive minutes.
• Limit on-site vehicle travel speeds on
unpaved roads to 15 miles per hour.
• Install wheel washers for all exiting trucks
or wash off all trucks and equipment
leaving the project area.
• Use Super-Compliant volatile organic
compound paints for coating of
architectural surfaces whenever possible.

A list of Super-Compliant architectural
coating manufactures can be found on the
SCAQMD’s website.

City Council 28 – 148 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-5

GPU PEIR
MM AQ-2
Prior to discretionary approval by the City of Santa
Ana for development projects subject to CEQA
(California Environmental Quality Act) review (i.e.,
non-exempt projects), project applicants shall
prepare and submit a technical assessment
evaluating potential project operation phaserelated air quality impacts to the City of Santa Ana for review and approval. The evaluation shall be
prepared in conformance with SCAQMD
methodology in assessing air quality impacts. If
operation-related air pollutants are determined to
have the potential to exceed the SCAQMD’s
adopted thresholds of significance, the City of
Santa Ana shall require that applicants for new
development projects incorporate mitigation
measures to reduce air pollutant emissions during
operational activities. The identified measures
shall be included as part of the conditions of
approval. Possible mitigation measures to reduce
long-term emissions could include, but are not
limited to the following:
• For site-specific development that
requires refrigerated vehicles, the
construction documents shall
demonstrate an adequate number of
electrical service connections at loading
docks for plug-in of the anticipated
number of refrigerated trailers to reduce
idling time and emissions.
• Applicants for manufacturing and light
industrial uses shall consider energy
storage and combined heat and power in
appropriate applications to optimize
renewable energy generation systems
and avoid peak energy use.
• Site-specific developments with truck
delivery and loading areas and truck
parking spaces shall include signage as a
Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
Note: This
measure has been
satisfied with the
analysis in The
Village at Santa
Ana Supplemental
EIR, as described
on p. 4.1-38 of the
Draft
Supplemental EIR.

City Council 28 – 149 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-6
reminder to limit idling of vehicles while
parked for loading/unloading in
accordance with California Air Resources
Board Rule 2845 (13 CCR Chapter 10 §
2485).
• Provide changing/shower facilities as
specified in Section A5.106.4.3 of the
CALGreen Code (Nonresidential
Voluntary Measures).
• Provide bicycle parking facilities per
Section A4.106.9 (Residential Voluntary
Measures) of the CALGreen Code and
• Sec. 41-1307.1 of the Santa Ana
Municipal Code.
• Provide preferential parking spaces for
low-emitting, fuel-efficient, and
carpool/van vehicles per Section
A5.106.5.1 of the CALGreen Code
(Nonresidential Voluntary Measures).
• Provide facilities to support electric
charging stations per Section A5.106.5.3
(Nonresidential Voluntary Measures) and
Section A5.106.8.2 (Residential Voluntary
Measures) of the CALGreen Code.
• Applicant-provided appliances (e.g.,
dishwashers, refrigerators, clothes
washers, and dryers) shall be Energy
Star–certified appliances or appliances of
equivalent energy efficiency. Installation
of Energy Star– certified or equivalent
appliances shall be verified by Building &
Safety during plan check.
• Applicants for future development projects
along existing and planned transit routes
shall coordinate with the City of Santa Ana
and Orange County Transit Authority to
ensure that bus pad and shelter
City Council 28 – 150 9/16/2025
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
improvements are incorporated, as
appropriate.

ProjectSpecific
MM AQ-1
Prior to the issuance of occupancy permits, the
Planning Division shall confirm that the proposed
project’s Covenants, Conditions, and Restrictions
(CC&Rs) and/or tenant lease agreements include
contractual language that all landscaping
equipment used on-site shall utilize at least 50
percent electric landscaping equipment (e.g.,
lawnmowers, leaf blowers, hedge trimmers). All
residential and non-residential properties shall be
equipped with exterior electrical outlets to
accommodate this requirement. This requirement
shall be included in the third-party vendor
agreements for landscape services for the building
owner and tenants, as applicable.

Prior to the
issuance of
occupancy
permits
Property Owner
or Project
Applicant
City of Santa
Ana Planning
Division

CULTURAL RESOURCES
RR CUL-1 California Health and Safety Code Section 7050.5 requires that if human remains are discovered
within the proposed project site, disturbance of the
site shall halt and remain halted until the coroner
has investigated the circumstances, manner, and
cause of any death, and the recommendations
concerning the treatment and disposition of the
human remains have been made to the person
responsible for the excavation, or to his or her
authorized representative. If the coroner
determines that the remains are not subject to his
or her authority and if the coroner recognizes or
has reason to believe the human remains to be
those of a Native American, he or she shall contact,
by telephone within 24 hours, the Native American
Heritage Commission.

During
construction
Project
Applicant/
Construction
Contractor
City of Santa Ana
Planning Division
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4 MITIGATION MONITORING AND REPORTING PROGRAM
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-8
Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance

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

Prior to and
during
construction
activities and
grounddisturbance
activities
Project
Applicant/
Construction
Contractor
City of Santa Ana
Planning Division
City Council 28 – 152 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
ENERGY
RR E-1 Construction activities will be conducted in
compliance with California Code of Regulations
Section 2485, which requires that nonessential
idling of construction equipment be restricted to five
minutes or less.

During
construction
Project
Applicant/
Construction
Contractor
City of Santa Ana
Building Safety
Division
RR E-2 At least 65 percent of all nonhazardous
construction and demolition waste from
nonresidential construction associated with future
development in the plan area shall be recycled
and/or salvaged for reuse in line with the 2016
California Green Building Standards Code Section

5.408 (California Code of Regulations, Title 24,
Part 11).

During
construction
Project
Applicant/
Construction
Contractor
City of Santa Ana
Building Safety
Division
RR E-3 New buildings implemented as part of the General Plan Update are required to achieve the current
California Building Energy and Efficiency
Standards (California Code of Regulations, Title
24, Part 6) and California Green Building
Standards Code (California Code of Regulations,
Title 24, Part 11).

Prior to the
issuance of
occupancy
permits
Property Owner
or Project
Applicant
City of Santa
Ana Planning
Division
RR E-4 Any appliances associated with development in the Plan Area shall meet the requirements of the 2012
Appliance Efficiency Regulations.

Prior to the
issuance of
occupancy
permits
Property Owner
or Project
Applicant
City of Santa
Ana Planning
Division
RR E-5 Development under the General Plan Update shall
support the goals of the renewables portfolio
standard, SB 350, and SB 100 to achieve a tiered
increase in the use of renewable energy to 60
percent by 2030, and 100 percent by 2045.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
RR E-7 Development under the General Plan Update shall
be in compliance with state and local solid waste
regulations including AB 939, AB 341, AB 1327, AB
1826, and Section 5.408 of 2016 California Green
Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
City Council 28 – 153 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
Building Standards Code (California Code of
Regulations, Title 24, Part 11).

GEOLOGY AND SOILS
RR G-1 Every public agency enforcing building regulations must adopt the provisions of the California Building
Code (CBC), which is Title 24, Part 2 of the
California Code of Regulations. The most recent
version is the 2019 CBC (effective January 1,
2020). The CBC is updated every three years and
provides minimum standards to protect property
and public safety by regulating the design and
construction of excavations, foundations, building
frames, retaining walls, and other building
elements to mitigate the effects of seismic shaking
and adverse soil conditions. The CBC also
contains provisions for earthquake safety based on
factors including occupancy type, the types of soil
and rock on-site, and the strength of ground
shaking with specified probability of occurring at a
site.

Prior to
discretionary
approval
Project
Applicant
City of Santa Ana
Building Safety
Division
RR G-2 Santa Ana Municipal Code, Chapter 8, Buildings
and Structures. These codes address grading
standards, excavation, and fills. This also includes
compliance with regulations for unreinforced
masonry structures in accordance with
“Unreinforced Masonry Law,” found in California
Government Code §§ 8875 et seq. The City of
Santa Ana Building Official may place additional
requirements upon the construction of
infrastructure, buildings, and other improvements
based on the findings from plan check, soils
testing, and geotechnical investigations.

Prior to
discretionary
approval
Project
Applicant
City of Santa Ana
Building Safety
Division
RR G-3 Santa Ana Municipal Code Section 39-51 requires
that all buildings or structures within the city that
require plumbing fixtures must be connected to a
public sewer.

Prior to
discretionary
approval
Project
Applicant
City of Santa Ana
Building Safety
Division
City Council 28 – 154 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-11
Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance

GPU PEIR
MM GEO-2
Prior to issuance of a grading permit for projects
involving ground disturbance in previously
undisturbed areas mapped with “low-to-high”
paleontological sensitivity, the project applicant
shall consult with a geologist or paleontologist to
confirm whether the grading would occur at depths
that could encounter highly sensitive sediments for
paleontological resources. If confirmed that
underlying sediments may have high sensitivity,
construction activity shall be monitored by a
qualified paleontologist. The paleontologist shall
have the authority to halt construction during
construction activity as outlined in Mitigation
Measure GEO-3.

Prior to the
issuance of
grading or
construction
permits and, if
necessary,
during grounddisturbing
activities
Project
Applicant/
Construction
Contractor
City of Santa Ana
Planning Division

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

During grounddisturbing
activities
Project
Applicant/
Construction
Contractor
City of Santa Ana
Planning Division
ProjectSpecific
MM G-1
Incorporation of and Compliance with a DesignLevel Geotechnical Investigation A final design-level geotechnical investigation that
complies with all applicable state and local code
requirements shall be prepared for each project
structure by a qualified, California-licensed
geotechnical engineer consistent with the
Prior to the
issuance of
grading or
construction
permits
Project
Applicant/
Construction
Contractor
City of Santa Ana
Planning
Division/City of
Santa Ana
Building Safety
Division
City Council 28 – 155 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
California Building Code and City of Santa Ana
requirements applicable at the time of issuance of
grading or construction permits. The final designlevel geotechnical investigation shall include recommendations related to site grading and
earthwork, fill materials, compaction, foundations,
dewatering, and other structural elements. The
report recommendations shall be included in
construction specifications and permits, approved
by the City’s Building and Safety Division, and
confirmed through on-site inspections.

ProjectSpecific
MM G-2
Implementation of Geotechnical
Recommendations
Project plans, grading specifications, and
construction permitting shall incorporate sitespecific earthwork and ground improvement requirements related to seismic ground shaking,
liquefaction, settlement, collapse, subsidence, and
expansive soils consistent with the California
Building Code and City of Santa Ana requirements
applicable at the time of issuance of grading or
construction permits as stated in the final designlevel geotechnical investigation and approved by the City’s Building and Safety Division. This shall
include recommendations related to site grading
and earthwork, fill materials, compaction,
foundations, dewatering, and other structural
elements.

Prior to the
issuance of
grading or
construction
permits
Project
Applicant/
Construction
Contractor
City of Santa Ana
Planning
Division/City of
Santa Ana
Building Safety
Division
ProjectSpecific
MM G-3
The project applicant shall retain a qualified
professional paleontologist to monitor or supervise
full-time monitoring should excavation occur into
native Pleistocene-age soil and bedrock greater
than 4 feet in depth. Ground disturbance refers to
activities that would impact subsurface geologic
deposits, such as grading, excavation, boring, etc.

Activities taking place in current topsoil or within
During grounddisturbing
activities
Project
Applicant/
Construction
Contractor
City of Santa Ana
Planning Division
City Council 28 – 156 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-13
Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
previously disturbed fill sediments, e.g., clearing,
grubbing, pavement rehabilitation, do not require
paleontological monitoring. Bedrock can occur at
varying depths depending on the portion of the
project area.

If no significant fossils have been recovered after
50 percent of excavation has been completed, fulltime monitoring may be modified to weekly spotcheck monitoring at the discretion of the qualified professional paleontologist. If the qualified
professional paleontologist determines during the
course of excavations that project excavations are
located within fill or disturbed soils, or that the
sensitivity for significant paleontological resources
is otherwise low, then monitoring may be reduced
or suspended at the qualified professional
paleontologist’s discretion. The determination to
reduce or discontinue paleontological monitoring in
the project area shall be based on the professional
opinion of the qualified professional paleontologist
regarding the potential for fossils to be present after a reasonable extent of the geology and stratigraphy
has been evaluated.

GREENHOUSE GAS EMISSIONS
RR GHG-1 New buildings are required to achieve the current California Building Energy Efficiency Standards
(Title 24, Part 6) and California Green Building
Standards (CALGreen) Code (Title 24, Part 11).

The 2019 Building Energy Efficiency Standards
became effective January 1, 2020. The Building
and Energy Efficiency Standards and CALGreen
are updated tri-annually.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
RR GHG-2 Construction activities are required to adhere to California Code of Regulations, Title 13, Section
During
construction
Project
Applicant/
Construction
Contractor
City of Santa Ana
Building
Safety Division
City Council 28 – 157 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
2449, which restricts the nonessential idling of
construction equipment to five minutes or less.

RR GHG-3 New buildings are required to adhere to the
California Green Building Standards Code and
Water Efficient Landscape Ordinance
requirements to increase water efficiency and
reduce urban per capita water demand.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
RR GHG-7 The California Green Building Standards Code
(CALGreen) requires the recycling and/or
salvaging for reuse at minimum of 65 percent of the
nonhazardous construction and demolition waste
generated during most “new construction” projects
(CALGreen Code §§ 4.408 and 5.408).

Construction contractors are required to submit a
construction waste management plan that
identifies the construction and demolition waste
materials to be diverted from disposal by recycling,
reuse on the project, or salvaged for future use or
sale and the amount (by weight or volume).

Prior to
discretionary
approval
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division
ProjectSpecific
MM AQ-1
See above under Air Quality -- -- -- --

HAZARDS AND HAZARDOUS MATERIALS
RR HAZ-1 Hazardous materials and hazardous wastes will be transported to and/or from projects developed
under the General Plan Update in compliance with
any applicable state and federal requirements,
including the U.S. Department of Transportation
regulations listed in the Code of Federal
Regulations (Title 49, Hazardous Materials
Transportation Act); California Department of
Transportation standards; and the California
Occupational Safety and Health Administration
standards.

During
construction
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division/City of
Santa Ana
Building Safety
Division
City Council 28 – 158 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
RR HAZ-2 Hazardous waste generation, transportation,
treatment, storage, and disposal will be conducted
in compliance with Subtitle C of the Resource
Conservation and Recovery Act (Code of Federal
Regulations, Title 40, Part 263), including the
management of nonhazardous solid wastes and
underground tanks storing petroleum and other
hazardous substances. The projects developed
under the General Plan Update will be designed
and constructed in accordance with the regulations
of the Orange County Health Care Agency,
Environmental Health Division, which serves as the
designated Certified Unified Program Agency.

During
construction
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division/City of
Santa Ana
Building Safety
Division
RR HAZ-4 Demolition activities that have the potential to expose construction workers and/or the public to
asbestos-containing materials or lead-based paint
will be conducted in accordance with applicable
regulations, including, but not limited to:
• South Coast Air Quality Management
District’s Rule 1403
• California Health and Safety Code
(Section 39650 et seq.)
• California Code of Regulations (Title 8,
Section 1529)
• California Occupational Safety and Health
Administration regulations (California
Code of Regulations, Title 8, Section
1529 [Asbestos] and Section 1532.1
[Lead])
• Code of Federal Regulations (Title 40,
Part 61 [asbestos], Title 40, Part 763
[asbestos], and Title 29, Part 1926
[asbestos and lead])
During
construction
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division/City of
Santa Ana
Building Safety
Division
City Council 28 – 159 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
RR HAZ-5 The removal of hazardous materials, such as
polychlorinated biphenyls (PCBs), mercurycontaining light ballast, and mold, will be completed in accordance with applicable regulations pursuant
to 40 CFR 761 (PCBs), 40 CFR 273 (mercurycontaining light ballast), and 29 CFR 1926 (molds) by workers with the hazardous waste operations
and emergency response (HAZWOPER) training,
as outlined in 29 CFR 1910.120 and 8 CCR 5192.

During
construction
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division/City of
Santa Ana
Building Safety
Division
RR HAZ-6 New construction, excavations, and/or new utility lines within 10 feet or crossing existing highpressure pipelines, natural gas/petroleum pipelines, or electrical lines greater than 60,000
volts will be designed and constructed in
accordance with the California Code of Regulations
(Title 8, Section 1541).

During
construction
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division/City of
Santa Ana
Building Safety
Division
RR HAZ-7 Development will be designed and constructed in accordance with the airport environs land use plan
for John Wayne Airport. Building height restrictions,
as specified in the airport environs land use plan,
would apply in the city.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division/ALUC

HYDROLOGY AND WATER QUALITY
RR HYD-1 All development pursuant to the General Plan
Update shall comply with the requirements of the
Construction General Permit (Order No. 2022-
0057-DWQ) for stormwater discharges associated
with construction activity. Compliance requires
filing a Notice of Intent, a Risk Assessment, a Site
Map, a Storm Water Pollution Prevention Plan and
associated best management practices, an annual
fee, and a signed certification statement.

Prior to
issuance of
permit
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division/City of
Santa Ana
Building Safety
Division
RR HYD-4 All development pursuant to the General Plan
Update shall comply with the requirements of the
Orange County MS4 Permit (Order R8-2009-
Prior to
issuance of
permit
Project
Applicant/
City of Santa
Ana Planning
Division/City of
City Council 28 – 160 9/16/2025
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
0030, NPDES No. CAS618030, as amended by
Order No. R8-2010-0062). The MS4 Permit
requires new development and redevelopment
projects to:
• Control contaminants into storm drain
systems
• Educate the public about stormwater
impacts
• Detect and eliminate illicit discharges
• Control runoff from construction sites
• Implement best management practices
and site-specific runoff controls and
treatments for new development and
redevelopment
Construction
Contractor
Santa Ana
Building Safety
Division
RR HYD-5 All development pursuant to the General Plan
Update shall comply with the requirements detailed
in Chapter 18 Article IV of the Santa Ana Municipal
Code.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division

LAND USE AND PLANNING
RR LU-1 Development associated with the General Plan
Update would be designed and constructed in
accordance with the applicable provisions of
Chapter 41 (Zoning) of the City of Santa Ana
Municipal Code. Development within specific plan
areas, overlay areas, and specific development
districts would implement zoning and development
standards that are applicable within these
subareas in addition to those in the underlying
zoning district.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
RR HAZ-7 See above under Hazards and Hazardous
Materials
Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
City Council 28 – 161 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
NOISE
RR NOI-1 California Building Code: The California Building Code (CBC), Title 24, Part 2, Volume 1, Chapter
12, Interior Environment, Section 1207.11.2,
Allowable Interior Noise Levels, requires that
interior noise levels attributable to exterior sources
shall not exceed 45 dB in any habitable room. The
noise metric is evaluated as either the day-night
average sound level (Ldn) or the community noise
equivalent level (CNEL), consistent with the noise
element of the local general plan.

The State of California’s noise insulation standards
for non-residential uses are codified in the
California Code of Regulations, Title 24, Building
Standards Administrative Code, Part 11, California
Green Building Standards Code (CALGreen).

CALGreen noise standards are applied to new or
renovation construction projects in California to
control interior noise levels resulting from exterior
noise sources. Proposed projects may use either
the prescriptive method (Section 5.507.4.1) or the
performance method (Section 5.507.4.2) to show
compliance. Under the prescriptive method, a
project must demonstrate transmission loss ratings
for the wall and roof-ceiling assemblies and exterior
windows when located within a noise environment
of 65 dBA CNEL or higher. Under the performance
method, a project must demonstrate that interior
noise levels do not exceed 50 dBA Leq(1hr).

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
RR NOI-2 Construction Noise Sources: Section 18-314(e) of the Santa Ana Municipal Code prohibits
construction activities to the hours of 7:00 AM to
8:00 PM Monday through Saturday.

During
construction
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division
City Council 28 – 162 9/16/2025
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
RR NOI-2 Stationary Noise Sources: Section 18.312 of the Santa Ana Municipal Code establishes standards
for stationary noise sources (see Table 4.9-2: Land
Use Compatibility for Community Noise
Environments of the Draft Supplemental EIR).

During
construction
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division
Project
Specific
MM NOI-1
Prior to the issuance of a permit to conduct
nighttime construction activities (e.g., overnight
concrete pours), the Project Applicant shall obtain
a permit from the City to complete work outside the
standard construction hours outlined in Santa Ana
Municipal Code Section 18-314(e). In addition, the
Project Applicant and/or contractor(s) shall develop
a nighttime construction noise control plan that
demonstrates the construction techniques that will
be implemented to ensure noise levels remain
below the FTA’s nighttime construction noise
criterion of 70 dBA Leq. Examples of such
construction techniques include but are not limited
to the following:
• Locate stationary equipment (e.g.,
generators, air compressors, etc.) away
from off-site residences/sensitive
receptors.
• Surround stationary equipment with noise
barriers or utilize a temporary noise barrier
to block the line of sight from such
equipment to nearby off-site
residences/sensitive receptors.
• Identify minimum separation distances
between mobile equipment (e.g., concrete
mixer trucks, concrete pump trucks, etc.)
and residences/sensitive receptors.

Prior to
issuance of a
permit to
conduct
nighttime
construction
activities
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division/City of
Santa Ana
Building Safety
Division
City Council 28 – 163 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance

PUBLIC SERVICES
RR FP-1 New buildings are required to meet the fire
regulations outlined in the California Health and
Safety Code (Sections 13000 et seq.).

Prior to the
issuance of
occupancy
permits
Property Owner
or Project
Applicant
City of Santa
Ana Planning
Division
RR SS-1 New residential and commercial development
shall pay development fee authorized by Section
65996 of the California Government Code to be
“full and complete school facilities mitigation.”
Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
RR LS-1 New residential development shall pay a property excise tax per the City Municipal Code Section
35-114, Residential Development Tax.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division

RECREATION
RR REC-1 Residential development associated with the
General Plan Update will be required to comply
with the provisions of the Municipal Code Chapter
35, Article IV (Residential Development Fee).

Residential development is mandated to pay fees,
dedicate land in lieu thereof, or a combination of
both for the purpose of preserving recreational
facilities in the City.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division

TRANSPORTATION
RR T-1 The City will design and operate a balanced,
multimodal circulation system network with all
users in mind—including bicyclists, public
transportation vehicles and riders, and
pedestrians of all ages and abilities in line with the
California Complete Streets Act (Assembly Bill
1358).

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
City Council 28 – 164 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
RR T-2 Projects pursuant to the General Plan Update will implement fire protection requirements as detailed
in the Orange County Fire Authority’s Fire
Prevention Guidelines and in the California Fire
Code.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division

TRIBAL CULTURAL RESOURCES
RR TCR-1 As per Assembly Bill 52, within 14 days of
deciding to undertake a project or determining that
a project application is complete, the lead agency
must provide formal written notification to all tribes
who have requested it.

Prior to
discretionary
approval
Project
Applicant
City of Santa
Ana Planning
Division
RR CUL-1 See above under Cultural Resources -- -- -- --

GPU PEIR
MM CUL-6 See above under Cultural Resources -- -- -- -- ProjectSpecific
MM TCR-1
Native American Monitor - Gabrieleño Band of
Mission Indians-Kizh Nation:
a. The project applicant shall retain a Native
American monitor from or approved by the
Gabrieleño Band of Mission Indians-Kizh
Nation. The monitor shall be retained prior to
the commencement of any “grounddisturbing activity” for the subject project at any project locations (i.e., both onsite and
any offsite locations that are included in the
project description/definition and/or required
in connection with the proposed project, such
as public improvement work). “Grounddisturbing activity” shall include, but is not limited to, demolition, pavement removal,
potholing, auguring, grubbing, tree removal,
boring, grading, excavation, drilling, and
trenching.
b. A copy of the executed monitoring
agreement shall be submitted to the Lead
Prior to and
during grounddisturbing
activities
Project
Applicant/
Construction
Contractor
City of Santa Ana
Planning Division
City Council 28 – 165 9/16/2025
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
Agency prior to the earlier of the
commencement of any ground-disturbing
activity, or the issuance of any permit
necessary to commence a ground-disturbing
activity.
c. The monitor will complete daily monitoring
logs that will provide descriptions of the
relevant ground-disturbing activities, the type
of construction activities performed, locations
of ground-disturbing activities, soil types,
cultural-related materials, and any other
facts, conditions, materials, or discoveries of
significance to the Tribe. Monitor logs will
identify and describe any discovered tribal
cultural resources, including but not limited
to, Native American cultural and historical
artifacts, remains, places of significance, etc.,
(collectively, tribal cultural resources, or
“TCR”), as well as any discovered Native
American (ancestral) human remains and
burial goods. Copies of monitor logs will be
provided to the project applicant upon written
request to the Tribe.
d. Onsite tribal monitoring by the Kizh Nation
and/or their representatives shall conclude
upon the earlier of the following (1) written
confirmation to the Kizh from a designated
point of contact for the project applicant or
lead agency that all ground-disturbing
activities and phases that may involve
ground-disturbing activities on the project site
or in connection with the project are
complete; or (2) a determination and written
notification by the Kizh to the project
applicant or Lead Agency that no future,
planned construction activity and/or
City Council 28 – 166 9/16/2025
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Party
Signature/Date
of Compliance
development/construction phase at the
project site possesses the potential to impact
Kizh tribal cultural resources.

ProjectSpecific
MM TCR-2
Unanticipated Discovery of Tribal Cultural
Resource Objects (Non-Funerary/NonCeremonial) - Gabrieleño Band of Mission Indians-Kizh Nation:
a. Upon discovery of any tribal cultural
resources, all construction activities in the
immediate vicinity of the discovery shall cease
(i.e., not less than the surrounding 50 feet)
and shall not resume until the discovered tribal
cultural resource has been fully assessed by
the Kizh monitor in consultation with a
qualified archaeologist. The Kizh will recover
and retain all discovered tribal cultural
resources in the form and/or manner the Tribe
deems appropriate, in the Tribe’s sole
discretion, and for any purpose the Tribe
deems appropriate, including for educational,
cultural and/or historic purposes.

During grounddisturbing
activities
Project
Applicant/
Construction
Contractor
City of Santa Ana
Planning Division
ProjectSpecific
MM TCR-3
Unanticipated Discovery of Human Remains and
Associated Funerary or Ceremonial Objects:
a. Native American human remains are defined
in Public Resources Code section 5097.98
(d)(1) as an inhumation or cremation, and in
any state of decomposition or skeletal
completeness. Funerary objects, called
associated grave goods in Public Resources
Code Section 5097.98, are also to be treated
according to this statute.
b. If Native American human remains and/or
grave goods are discovered or recognized on
the project site, then Public Resource Code
During grounddisturbing
activities
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division
City Council 28 – 167 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
section 5097.9 as well as Health and Safety
Code Section 7050.5 shall be followed.
c. Human remains and grave/burial goods shall
be treated alike per Public Resources Code
section 5097.98(d)(1) and (2).
d. Preservation in place (i.e., avoidance) is the
preferred manner of treatment for discovered
human remains and/or burial goods.
e. Any discovery of human remains/burial
goods shall be kept confidential to prevent
further disturbance.

ProjectSpecific
MM TCR-4
Native American Monitor - Juaneño Band of
Mission Indians, Acjachemen Nation- Belardes:
a. The Project applicant shall retain a Native
American Monitor from or approved by the
Juaneño Band of Mission Indians,
Acjachemen Nation- Belardes. The monitor
shall be retained prior to the
commencement of any ground-disturbing
activity for the subject project at all project
locations (i.e., both on-site and any off-site
locations that are included in the project
description/ definition and/or required in
connection with the project, such as public
improvement work). “Ground-disturbing
activity” shall include, but is not limited to,
demolition, pavement removal, potholing,
auguring, grubbing, tree removal, boring,
grading, excavation, drilling, and trenching.
b. A copy of the executed monitoring
agreement shall be submitted to the (City)
prior to the commencement of any grounddisturbing activity, or the issuance of any permit necessary to commence ground
disturbing activity.

During grounddisturbing
activities
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division
City Council 28 – 168 9/16/2025
4 MITIGATION MONITORING AND REPORTING PROGRAM
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Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
c. The monitor will complete daily monitoring
logs that will provide descriptions of the
relevant ground-disturbing activities, the
type of construction activities performed,
locations of ground-disturbing activities, soil
types, cultural-related materials, and any
other facts, conditions, materials, or
discoveries of significance to the Tribe.

Monitor logs will identify and describe any
discovered tribal cultural resources (TCRs),
including but not limited to, Native American
cultural and historical artifacts, remains,
places of significance, etc., as well as any
discovered Native American (ancestral)
human remains and burial goods. Copies of
monitor logs will be provided to the Project
applicant upon written request to the Tribe.
d. On-site tribal monitoring by the Juaneño
Band of Mission Indians and/or their
representatives shall conclude upon the
latter of the following (1) written confirmation
to the Tribe or Tribal monitoring agency
from a designated point of contact for the
Project applicant that all ground-disturbing
activities and phases that may involve the
Project are complete; or (2) a determination
and written notification by the Tribe or Tribal
monitoring agency to the Executive Director
of the Planning and Building Agency, or
designee that no future, planned
construction activity and/or
development/construction phase at the
Project site possesses the potential to
impact TCRs.

City Council 28 – 169 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-26
Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
ProjectSpecific
MM TCR-5
Unanticipated Discovery of Tribal Cultural
Resource Objects (Non-Funerary/NonCeremonial) - Juaneño Band of Mission Indians, Acjachemen Nation- Belardes:
a. Upon discovery of any tribal cultural
resources (TCRs), all construction
activities in the immediate vicinity of the
discovery shall cease (i.e., not less than
the surrounding 50 feet) and shall not
resume until the discovered TCR has
been fully assessed by the Juaneño Band
of Mission Indians monitor in consultation
with a qualified archaeologist. The Tribe
or Tribal monitoring agency will recover
and retain all discovered TCRs in the form
and/or manner the Tribe deems
appropriate, in the Tribe’s sole discretion,
and for any purpose the Tribe deems
appropriate, including for educational,
cultural and/or historic purposes.

During grounddisturbing
activities
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division
ProjectSpecific
MM TCR-6
Tribal Cultural Resource Finds, Dispute
Resolution, and Final Disposition:

If a tribal cultural resource is identified, then
avoidance is the preferred treatment. If avoidance
is not feasible and both Tribal monitoring entities
claim cultural affiliation with and/or ancestral ties
to the discovered resources, then a Cultural
Resources Monitoring and Treatment Plan shall
be created by the archaeologist, in coordination
with the consulting tribes (Gabrieleño Band of
Mission Indians-Kizh Nation and the Juaneño
Band of Mission Indians, Acjachemen NationBelardes) and all subsequent finds shall be subject to this Plan. The consultation effort is
intended to be a meaningful and timely process of
seeking, discussing, and considering carefully the
During grounddisturbing
activities
Project
Applicant/
Construction
Contractor
City of Santa
Ana Planning
Division
City Council 28 – 170 9/16/2025
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City of Santa Ana The Village Santa Ana Specific Plan Project August 2025 Final Supplemental Environmental Impact Report 4-27
Regulatory Requirements/Mitigation Measures Timing Responsible Party
Monitoring
Party
Signature/Date
of Compliance
views of others, in a manner that is cognizant of
all parties’ cultural values and, where feasible,
seeking agreement on the appropriate treatment
and disposition of TCRs discovered. Final
disposition of any excavated resources may
include, but would not be limited to, reburying,
relocating, recording, and/or another culturally
appropriate treatment such as transfer to one of
the consulting tribes for any purpose the Tribe
deems appropriate, including for educational,
cultural and/or historic purposes. If it is
determined that mutual agreement cannot be
reached within 30 days of the initial consultation
meeting, the Plan shall be written such that any
excavated resources shall be reinterred on site in
a location free from future ground-disturbing
construction activities after documentation is
complete. Project construction will not resume
within the immediate vicinity of the discovery (i.e.,
not less than the surrounding 50 feet) until the
Cultural Resources Monitoring and Treatment
Plan is prepared and implemented to the
satisfaction of the City.

City Council 28 – 171 9/16/2025
Ordinance No. NS-XXX