Santa Ana Rezone Project
Final Initial Study/Mitigated Negative Declaration
City of Santa Ana, Orange County, California
PREPARED FOR:
City of Santa Ana
Planning and Building Agency
20 Civic Center Plaza
Santa Ana, CA 92701
714.647.2700
Contact: Rudy Rosas, Deputy Public Works Director/City Engineer PREPARED BY:
FirstCarbon Solutions
250 Commerce, Suite 210
Irvine, CA 92602
714.508.4100
Contact: Jason Brandman, Project Director
Angela Wolfe, Project Manager
August 14, 2025
Finalized February 11, 2026
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Acronyms and Abbreviations v
1 - Introduction 1
1.1 - Purpose 1
1.2 - Project Location 1
1.3 - Environmental Setting 1
1.4 - General Plan and Zoning Designation 2
1.4.1 - General Plan Designation 2
1.4.2 - Zoning Designation 3
1.5 - Project Description 3
1.5.1 - Site Access 3
1.5.2 - Landscaping 4
1.5.3 - Utilities 4
1.5.4 - Phasing and Construction 4
1.5.5 - Operation 4
1.6 - Required Discretionary Approvals 4
1.7 - Intended Uses of This Document 5
2 - Environmental Checklist and Environmental Evaluation 19
2.1 Aesthetics 20
2.2 Agriculture and Forestry Resources 23
2.3 Air Quality 27
2.4 Biological Resources 37
2.5 Cultural Resources and Tribal Cultural Resources 41
2.6 Energy 48
2.7 Geology and Soils 51
2.8 Greenhouse Gas Emissions 57
2.9 Hazards and Hazardous Materials 61
2.10 Hydrology and Water Quality 65
2.11 Land Use and Planning 71
2.12 Mineral Resources 74
2.13 Noise 76
2.14 Population and Housing 85
2.15 Public Services 87
2.16 Recreation 90
2.17 Transportation 92
2.18 Utilities and Service Systems 96
2.19 Wildfire 100
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2.20 Mandatory Findings of Significance 103
3 - List of Preparers 107
Appendix A: Air Quality, Greenhouse Gas Emissions, and Energy Supporting Information
Appendix B: Biological Resources Supporting Information Appendix C: Cultural Resources Supporting Information
Appendix D: Noise Supporting Information
Appendix E: Traffic Supporting Information
E.1 - Trip Generation Assessment
E.2 - Vehicle Miles Traveled Screening Evaluation
Tables
Table 1: Maximum Daily Construction Emissions 31
Table 2: Maximum Daily Operation Emissions 32
Table 3: Construction Localized Significance Screening Analysis 33 Table 4: Operation Localized Significance Screening Analysis 34 Table 5: Project Trip Generation 93
Exhibits
Exhibit 1: Regional Location Map 7
Exhibit 2: Local Vicinity Map 9
Exhibit 3: Existing General Plan Land Use Designation 11 Exhibit 4: Proposed General Plan Land Use Designation 13 Exhibit 5: Existing Zoning Designation 15
Exhibit 6: Proposed Zoning Designation 17
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ACRONYMS AND ABBREVIATIONS
A1 General Agriculture
AB Assembly Bill
ADA Americans with Disabilities Act
ADT Average Daily Traffic
ALUC Airport Land Use Commission
AQMP Air Quality Management Plan
AQP Air Quality Plan
ARB California Air Resources Board
BACM Best Available Control Measure
BERD Built Environment Resource Directory
BMP Best Management Practice
C1 Community Commercial
C2 General Commercial
CAL FIRE California Department of Forestry and Fire Prevention CALGreen California Green Building Standards Code
CalEEMod California Emissions Estimator Model
CalRecycle California Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CAP Climate Action Plan
CAAQS California Ambient Air Quality Standards
CBC California Building Standards Code
CEQA California Environmental Quality Act
CDFW California Department of Fish and Wildlife
CESA California Endangered Species Act
CGS California Geological Survey
CHL California Historical Landmarks
CHRIS California Historical Resources Information System CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
CNPS California Native Plant Society
CNPS Inventory California Native Plant Society Electronic Inventory CO carbon monoxide
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx CO2e carbon dioxide equivalent
CONCCP County of Orange Natural Communities Conservation Plan CPHI California Points of Historical Interest
CRHR California Register of Historical Resources
CWA Clean Water Act
DAMP Drainage Area Management Plan
dB decibels
dBA A-weighted decibels
DOC California Department of Conservation
DPM diesel particulate matter
DPR California Department of Parks and Recreation
DTSC California Department of Toxic Substance Control
EDD California Employment Development Department
EIR Environmental Impact Report
EPA United States Environmental Protection Agency
EV electrical vehicle
FAR floor area ratio
FCS FirstCarbon Solutions
FGC California Fish and Game Code
FHSZ Fire Hazard Safety Zone
FIRM Flood Insurance Rate Map
FMMP Farmland Mapping and Monitoring Program
FTA Federal Transit Administration
GC General Commercial
GGUSD Garden Grove Unified School District
GHG greenhouse gas
GPA General Plan Amendment
HCP Habitat Conservation Plan
HREC historically recognized environmental condition
in/sec inches per second
IPaC Information for Planning and Consultation
IS/MND Initial Study/Mitigated Negative Declaration
kWh kilowatt hours
Ldn day/night average noise level
Leq equivalent noise/sound level
Lmax maximum noise/sound level
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx LOS Level of Service
LST localized significance threshold
MBTA Migratory Bird Treaty Act
MEP maximum extent practicable
Metropolitan Metropolitan Water District of Southern California mgd million gallons per day
MLD Most Likely Descendant
MM Mitigation Measure
mph miles per hour
MRZ Mineral Resource Zone
MS4 Municipal Separate Storm Sewer System
MT metric tons
NAHC Native American Heritage Commission
NAAQS National Ambient Air Quality Standards
NCCP Natural Community Conservation Plan
NOI Notice of Intent
NOX nitrogen oxides
NPDES National Pollutant Discharge Elimination System
NRCS Natural Resources Conservation Service
NRHP National Register of Historic Places
PM2.5 particular matter less than 2.5 micrometers in diameter PM10 particular matter less than 10 micrometers in diameter OCFA Orange County Fire Authority
OC San Orange County Sanitation District
OCTA Orange County Transportation Authority
OEHHA Office of Environmental Health Hazard Assessment
OS Open Space
OUSD Orange Unified School District
PEIR Program Environmental Impact Report
ppm parts per million
PPV peak particle velocity
REC Recognized Environmental Condition
rms root mean square
ROG reactive organic gases
RPS Renewables Portfolio Standard
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SAPD Santa Ana Police Department
SAUSD Santa Ana Unified School District
SB Senate Bill
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCE Southern California Edison
SCCIC South Central Coastal Information Center
SLF Sacred Lands File
SMARA Significant Mineral Aggregate Resource Area
SoCAB South Coast Air Basin
SOX sulfur oxides
SR State Route
SRA State Responsibility Area
SRRE Source Reduction and Recycling Element
State Water Board California State Water Resources Control Board SWPPP Storm Water Pollution Prevention Plan
TAC toxic air contaminant
TAZ Transportation Analysis Zone
TCR Tribal Cultural Resource
TPA Transit Priority Area
TUSD Tustin Unified School District
UA Urbanized Area
USDA United States Department of Agriculture
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
UWMP Urban Water Management Plan
VdB vibration in decibels
VMT Vehicle Miles Traveled
VOC volatile organic compound
WEAP Worker Environmental Awareness Program
WQMP Water Quality Management Plan
WSS Web Soil Survey
Santa Ana Rezone Project
Initial Study/Mitigated Negative Declaration
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx 1 - INTRODUCTION
1.1 - Purpose
The purpose of this Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) is to identify any potential environmental impacts that would result from the implementation of the Santa Ana Rezone Project (proposed project) in the City of Santa Ana (City), California. Pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15367, the City of Santa Ana has discretionary authority over the proposed project and is the Lead Agency in the preparation of this Draft IS/MND and any additional environmental documentation required for the proposed project.
The remainder of this section provides a brief description of the project location and the primary project characteristics. Section 2 includes an environmental checklist that provides an overview of the potential impacts that may result from project implementation, elaborates on the information contained in the environmental checklist, and provides justification for each checklist response.
Feasible mitigations are analyzed to reduce all impacts to below a level of significance. Section 3 contains the List of Preparers.
1.2 - Project Location
The project site is located at 1801 East Chestnut Avenue in the City of Santa Ana, in Orange County, California (Exhibit 1). The project lies directly on the border of Santa Ana and Tustin, with its neighboring parcels to the east and south located in the City of Tustin. The project site corresponds with Assessor’s Parcel Number (APN): 402-212-01 and is located within the Tustin, California United States Geological Survey (USGS) 7.5-minute Topographic Quadrangle Map, Township 5 South, Range 9 West, Section 00 (Latitude 33° 44' 34" North; Longitude 117° 50' 28" West).
1.3 - Environmental Setting
The approximately 3.48-acre project site is a trapezoidal-shaped parcel that is relatively flat and located in an urban area. The project site is bounded by Interstate 5 (I-5) to the north, Church of Christ in Tustin to the east, East Main Street and Saddleback Mobile Lodge Club to the south, and the Santa Ana Zoo to the west. The Santa Ana River is located approximately 4 miles west of the project site and, based on the general area topography and existing surface conditions, surface water flow is expected to be to the south-southwest.
The parcel is currently an unpaved gravel lot that provides overflow parking for the Santa Ana Zoo, which is owned and operated by the City. Access to the site is provided via a paved 30-foot-wide by 500-foot-long access road from East Main Street.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Located on the northeastern corner of the parcel beyond the access road is a freestanding utility building. The approximately 900-square-foot utility building currently operates as a groundwater production well (City of Santa Ana Well 31) and is serviced by the City’s Public Works Agency. The utility building would remain in place, and no improvements to this structure are anticipated as part of the proposed project. Additionally, there are several storage trailer structures located in the northwestern corner of the parcel which currently provide office space for zoo employees as well as storage and staging associated with the zoo operations. The structures in the northwestern corner would also remain in place, and no improvements are anticipated.
1.4 - General Plan and Zoning Designation
The Santa Ana General Plan (General Plan) provides long-term policy direction to guide the physical development, quality of life, economic health, and sustainability of the City through 2045. The General Plan is the primary policy document for the City. The General Plan was updated following the certification of the 2021 Final Recirculated Program Environmental Impact Report (PEIR) for the City of Santa Ana General Plan Update (2021 Recirculated PEIR). The purpose of the 2021 Recirculated PEIR was to inform the Lead Agency, responsible agencies, decision-makers, and the general public of the environmental effects of implementation of the General Plan update. The 2021 Recirculated PEIR addresses the potential environmental effects of the General Plan, including effects that may be significant and adverse; evaluates a number of alternatives to the General Plan; and identifies mitigation measures to reduce or avoid adverse effects.1,2
1.4.1 - General Plan Designation
According to the General Plan Land Use Map, the project site is currently designated as Open Space (OS) (Exhibit 2).3 Permitted uses under the OS land use designation include recreational and green spaces, including parks, commercial open space; and public facilities such as water channels and rail infrastructure.4
The proposed project would amend the existing General Plan land use designation from Open Space (OS) to General Commercial (GC) (Exhibit 3). The GC designation allows for retail and service establishments; recreational, cultural, and entertainment uses; business and professional offices; and vocational schools. These uses are designed to be along arterial corridors and support the development and continued operation of recreational, cultural, entertainment, employment, and educational opportunities near established residential neighborhoods. This designation allows for a
1 City of Santa Ana. 2022. Santa Ana General Plan. April. 2 Placeworks. 2021. Santa Ana General Plan Update Final Recirculated Program Environmental Impact Report – Prepared for the City of Santa Ana. October.
3 City of Santa Ana. 2022. Land Use Element. Website: https://www.santa-ana.org/documents/general-plan-land-use- element/. Accessed January 30, 2025.
4 Ibid.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx typical maximum building height of 35 feet and a maximum intensity of 0.5 floor area ratio (FAR) for GC, 1.0 FAR for GC-1, and 1.5 FAR for GC-1.5.5
1.4.2 - Zoning Designation
The project site is currently zoned General Agriculture (A1) by the City of Santa Ana Zoning Ordinance (Exhibit 4), which permits farming (of crop agriculture and horticulture, grazing, small animal farms, and similar types), parks and recreational buildings of public or quasi-public use (golf courses, country clubs and other similar uses), accessory buildings, temporary sale stands for agricultural goods, and a single one-family dwelling unit.6 The proposed project includes a rezone of the project site from A1 to General Commercial (C2) (Exhibit 5 and Exhibit 6). The C2 zone district permits all uses of the Community Commercial (C1) district as well as automotive garages, equipment rental yards, metal shops, wholesale establishments, truck, trailer, tractor and boat sales, research institutions, and more. Under the proposed project, the City plans to develop the site as an automobile parking lot; parking structures are permitted under both C1 and C2 districts.7
1.5 - Project Description
The City proposes to continue the use of the existing overflow parking lot to serve the Santa Ana Zoo, maintaining its current function. However, under the proposed project, the lot would be improved with paving, marked parking spaces and circulation lanes, enhancing both its appearance and operational efficiency. The access road would be demolished and reconstructed as part of the parking lot improvements. In compliance with the 2022 California Building Standards Code (CBC) and the 2022 California Green Building Standards Code, Title 24, Part 11 (CALGreen) with July 2024 Supplement, the parking lot would contain a total of 250 parking stalls, including 200 standard stalls, 40 standard electric vehicle (EV) stalls, and 10 EV Americans with Disabilities Act (ADA) stalls. All stalls would be accessible to zoo patrons when overflow parking is required. A solar panel shade structure would also be constructed above the EV parking stalls.
1.5.1 - Site Access
Regional access to the site is provided via I-5 at the Mabury Street/Zoo Lane exit. Local access to the site is provided via the existing driveway located along East Main Street.
5 City of Santa Ana. 2022. Land Use Element. Website: https://www.santa-ana.org/documents/general-plan-land-use- element/. Accessed January 30, 2025.
6 City of Santa Ana. Municipal Code. Section 41-201. Website:
https://library.municode.com/ca/santa_ana/codes/code_of_ordinances?nodeId=PTIITHCO_CH41ZO_ARTIIIUSDIRESP_ DIV1A1GEAG_S41-201USPEA1DI. Accessed January 28, 2025.
7 City of Santa Ana. Municipal Code. Section 41-377. Website:
https://library.municode.com/ca/santa_ana/codes/code_of_ordinances?nodeId=PTIITHCO_CH41ZO_ARTIIIUSDIRESP_ DIV13C2GECO. Accessed January 28, 2025.
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1.5.2 - Landscaping
The project site currently includes several shrubs and a few trees along the southern and western perimeter of the parcel. The proposed project would include replacement of landscaping within the parking lot, including replacement of drought-tolerant landscaping along the southern portion of the parcel. The vegetation along the western perimeter would remain intact.
1.5.3 - Utilities
The proposed project is currently served and would continue to be served by the following utility providers:
• Electricity: Southern California Edison
• Natural Gas: Southern California Gas Company
• Sewage: City of Santa Ana Public Works Agency
• Potable Water: Santa Ana Water Resources Division
• Solid Waste Removal: Republic Services
1.5.4 - Phasing and Construction
Construction activities would start as early as the first quarter of 2027. Development would be completed in a single phase, beginning in January 2027 and concluding by March 2027.
1.5.5 - Operation
The EV charging area would be available to zoo patrons and would align with zoo operating hours:
10:00 a.m. to 4:00 p.m., 7 days a week all year (including holidays). For the month of July (2025), the zoo also offers extended hours on Saturdays and Sundays from 5:00 p.m. to 7:00 p.m. with doors closing at 8:00 p.m. and select Wednesdays from 5:00 p.m. to 6:30 p.m. with doors closing at 7:30 p.m. The overflow parking lot would continue to operate as it currently does, being utilized on an as- needed basis to accommodate periods of high demand.
1.6 - Required Discretionary Approvals
The City of Santa Ana has discretionary authority over the proposed project and is the CEQA Lead Agency for the preparation of this Draft IS/MND. The following approvals are required in order to implement the proposed project:
• City Approval of the Draft IS/MND
• Development Plan review and approval
• General Plan Amendment (GPA) from General Agriculture to General Commercial • Zoning Code Amendment from Open Space to General Commercial • Building Permit for installation of solar panel shade structure and EV charging stations
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1.7 - Intended Uses of This Document
This Draft IS/MND has been prepared to document any potential significant adverse environmental impacts associated with the proposed project and identify feasible mitigation that would reduce any impacts to below a level of significance. This document will also serve as a basis for soliciting comments and input from members of the public and public agencies regarding the proposed project.
The Draft IS/MND will be circulated for a minimum of 20 days, during which comments concerning the analysis contained in the Draft IS/MND should be sent to:
Rudy Rosas, PE
Deputy Director, Public Works/City Engineer
City of Santa Ana, Public Works Agency
20 Civic Center Plaza
Santa Ana, CA 92701
Phone: 714.647.5690
[email protected]
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Golden Circle Dr
Lyon St
City of Santa Ana
City of Tustin
Zoo Ln
Palm St
P
R4
A1
R4
R4
R1
C2
M1
R3
R3
C2
C2
C2
C2
C2
R2
O
A1
C1
C5
C2
O
C2
C5 A1
SD54 OZ1 C5 C5
C1
PP
M1
O
E Chestnut Ave
R3
¥
4 0 0 0 4 0 0 2 0 0
F e e t
F C S
E x i s t i n g Z o n i n g D e s i g n a t i o n s C I T Y O F S A N T A A N A
Santa Ana
Zoo
California Department
of Transportation
Legend
P r o j e c t S i t e
Zoning Designations
C 5 - A r t e r i a l C o m m e r c i a l
C 1 - C o m m u n i t y C o m m e r c i a l
A 1 - G e n e r a l A g r i c u l t u r a l
C 2 - G e n e r a l C o m m e r c i a l
M 1 - L i g h t I n d u s t r i a l
O Z 1 - M e t r o E a s t O v e r l a y Z o n e R 3 - M u l t i p l e - F a m i l y R e s i d e n c e O - O p e n S p a c e L a n d
P - P r o f e s s i o n a l
R 1 - S i n g l e - F a m i l y R e s i d e n c e S D 5 4 - S p e c i f i c D e v e l o p m e n t N o . 5 4 R 4 - S u b u r b a n A p a r t m e n t
R 2 - T w o - F a m i l y R e s i d e n c e
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0 3 2 7 0 0 4 7 " 0 9 / 2 0 2 5 | 5 _ p r o p o s e d _ z o n i n g . m x d Exhibit 6
S o u r c e : B i n g A e r i a l I m a g e r y . O r a n g e C o u n t y P u b l i c W o r k s , G I S O p e n D a t a P o r t a l . S e p t e m b e r 2 0 2 4 . C i t y o f S a n t a A n a .
S A N T A A N A R E Z O N E P R O J E C T I N I T I A L S T U D Y / M I T I G A T E D N E G A T I V E D E C L A R A T I O N §¨¦
5 E Main St
E 1st St
Golden Circle Dr
Lyon St
City of Santa Ana
City of Tustin
Zoo Ln
Palm St
P
R4
A1
R4
R4
R1
C2
M1
R3
R3
C2
C2
C2
C2
C2
R2
O
C2
C1
C5
C2
O
C2
C5 A1
SD54 OZ1 C5 C5
C1
PP
M1
O
E Chestnut Ave
R3
¥
4 0 0 0 4 0 0 2 0 0
F e e t
F C S
P r o p o s e d Z o n i n g D e s i g n a t i o n s C I T Y O F S A N T A A N A
Santa Ana
Zoo
California Department
of Transportation
Legend
P r o j e c t S i t e
Zoning Designations
C 5 - A r t e r i a l C o m m e r c i a l
C 1 - C o m m u n i t y C o m m e r c i a l
A 1 - G e n e r a l A g r i c u l t u r a l
C 2 - G e n e r a l C o m m e r c i a l
M 1 - L i g h t I n d u s t r i a l
O Z 1 - M e t r o E a s t O v e r l a y Z o n e R 3 - M u l t i p l e - F a m i l y R e s i d e n c e O - O p e n S p a c e L a n d
P - P r o f e s s i o n a l
R 1 - S i n g l e - F a m i l y R e s i d e n c e S D 5 4 - S p e c i f i c D e v e l o p m e n t N o . 5 4 R 4 - S u b u r b a n A p a r t m e n t
R 2 - T w o - F a m i l y R e s i d e n c e
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Santa Ana Rezone Project
Initial Study/Mitigated Negative Declaration
FCS 19
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx 2 - ENVIRONMENTAL CHECKLIST AND
ENVIRONMENTAL EVALUATION
Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages.
Aesthetics Agriculture and Forestry Resources Air Quality Biological Resources Cultural Resources and Tribal
Cultural Resources
Energy
Geology and Soils Greenhouse Gas Emissions Hazards and Hazardous Materials
Hydrology and Water Quality Land Use and Planning Mineral Resources Noise Population and Housing Public Services
Recreation Transportation Mandatory Findings of
Significance
Utilities and Services
Systems
Wildfire
Environmental Determination
On the basis of this initial evaluation:
I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measure based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.
I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.
Date: Signed:
8/10/2025
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
20 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.1 Aesthetics
Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a
scenic vista?
b) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic building within a
State Scenic Highway?
c) In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those that
are experienced from publicly accessible
vantage point). If the project is in an
urbanized area, would the project conflict
with applicable zoning and other
regulations governing scenic quality?
d) Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?
Environmental Evaluation
Setting
The project site is located in a highly urbanized area. The United States Census Bureau defines an Urbanized Area (UA) as an area that must encompass at least 5,000 people or at least 2,000 housing units.8 An estimated 310,539 people live in the City.9 The Conservation Element of the Santa Ana
8 US Census. 2022. Redefining Urban Areas following the 2020 Census. Website:
https://www.census.gov/newsroom/blogs/random-samplings/2022/12/redefining-urban-areas-following-2020-census.html.
Accessed April 28, 2025.
9 US Census. 2024. Quick Facts Santa Ana. Website:
https://www.census.gov/quickfacts/fact/table/santaanacitycalifornia,sanangelocitytexas,US/PST045224. Accessed April 28, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 21
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx General Plan notes that views of the Santa Ana Mountains are possible on clear days.10 The Conservation Element also lists scenic resources within the City, including the Santa Ana River and Santiago Creek, which are also part of the County Open Space network. 11 The project site is located approximately 4 miles east of the Santa Ana River and approximately 2.52 miles south of Santiago Creek. According to California’s Scenic Highway Mapping System, there are no designated Scenic Highways within the project vicinity; State Route (SR) 91, located 7.87 miles to the north, is the closest designated Scenic Highway.12 The project site is located in an urbanized area adjacent to West First Street with high levels of existing light. The adjacent commercial, residential, and light industrial uses generate light and glare along all sides of the project site.
Would the project:
a) Have a substantial adverse effect on a scenic vista? No impact. Scenic vistas are generally recognized as public panoramic views of natural features.
The Conservation Element does not identify specific scenic vistas but lists scenic resources within the City, including the Santa Ana River and Santiago Creek, as well as views of the Santa Ana Mountains which are visible on clear days.
The project site is directly adjacent to an I-5 overpass which obstructs views to the northeast. Neither the Santa Ana Mountains, Santa Ana River, nor Santiago Creek are visible from the project site; therefore, there are no known scenic resources visible from the project site. As such, the proposed project would not affect scenic vistas within the area and no impact would occur. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic building within a State Scenic Highway? No impact. The nearest officially designated State Scenic Highway, SR 91, is located 7.87 miles to the north. Because of the distance and intervening development, the project site is not visible from this Scenic Highway and would not result in any impacts to scenic resources within the highway.
Moreover, the project site and surrounding area are not characterized by unique visual resources or historic structures. Thus, the proposed project would not damage any existing scenic resources in or around the project site and, as such, there would be no impacts.
10 City of Santa Ana. 2022. Conservation Element. Website: https://general-plan-santa-ana-ca.proudcity.com/conservation- element/. Accessed April 28, 2025.
11 Ibid.
12 California Department of Transportation (Caltrans). 2025. California State Scenic Highway System Map. Website:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa. Accessed February 7, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
22 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Less than significant impact. The project site is located in an urbanized area supporting commercial and residential uses. Currently, the project site is zoned A1 and is designated by the General Plan as OS. The proposed project would include a zone change to rezone the project site to C2, as well as a GPA to redesignate the project site as GC, both of which allow for operation of a parking lot. The proposed parking lot would continue to serve the zoo with overflow capacity and would therefore be consistent with the surrounding land uses and zoning with respect to scenic quality as it would enhance an existing parking lot with paving, striping, EV charging, and updated landscaping. As such, the proposed project would not conflict with applicable zoning and other regulations pertaining to scenic quality and impacts would be less than significant. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less than significant impact. The proposed project would include standard parking lot lighting, which would not exceed 35 feet in height and would be directed downward and shielded to avoid glare, as per Section 9.7 in the City’s Commercial Design Guidelines.13 As the proposed project would be in compliance with City regulations regarding new sources of nighttime lighting, the proposed parking lot lighting would not adversely affect day or nighttime views in the area. The proposed project would not result in a new substantial source of light or glare which would affect nighttime views of the area, and a less than significant impact would occur.
Mitigation Measures
None required.
13 City of Santa Ana. 2022. Chapter 9: Commercial Design Guidelines. Website: https://www.santa- ana.org/documents/chapter-9-commercial-design-guidelines-citywide-design-guidelines/. Accessed April 28, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 23
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.2 Agriculture and Forestry Resources
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the State’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.
Would the project:
a) Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farmland), as shown on the
maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the
California Resources Agency, to
nonagricultural use?
b) Conflict with existing zoning for agricultural
use, or a Williamson Act Contract?
c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in
Public Resources Code Section 12220(g)),
timberland (as defined by Public
Resources Code Section 4526), or
timberland zoned Timberland Production
(as defined by Government Code Section
51104(g))?
d) Result in the loss of forest land or
conversion of forest land to non-forest use?
e) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland, to nonagricultural use or
conversion of forest land to non-forest
use?
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Evaluation
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation (DOC) as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the State’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board (ARB).
Setting
The DOC Farmland Mapping and Monitoring Program (FMMP) was established by the State Legislature in 1982 to assess the location, quality, and quantity of agricultural lands and conversion of these lands over time. The FMMP has established five farmland categories:
• Prime Farmland (F) is farmland with the best combination of physical and chemical features able to sustain long-term agricultural production. This land must have been used for irrigated agricultural production at some time during the last 4 years before the mapping date and have the ability to store moisture in soil well.
• Farmland of Statewide Importance (S) is similar to Prime Farmland but contains greater slopes and a lesser ability to store soil moisture.
• Unique Farmland (U) is usually irrigated but may include non-irrigated orchards or vineyards as found in some climate zones in California. This land must still have been cropped sometime during 4 years prior to the mapping date.
• Farmland of Local Importance (L) is important to the local agricultural economy as determined by each county’s board of supervisors and local advisory committee. • Grazing Land (G) is land on which the existing vegetation is suited to the grazing livestock.
This category was developed in cooperation with the California Cattlemen’s Association, University of California Cooperative Extension, and other groups interested in the extent of grazing activities.
According to the FMMP Orange County Important Farmland, the City does not contain any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance parcels.14 No farmland or agricultural activity exists on or in the vicinity of the project site. The City is designated Urban and
14 California Department of Conservation (DOC). 2025. California Important Farmland Finder. Website:
https://maps.conservation.ca.gov/DLRP/CIFF/. Accessed February 5, 2025.
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Built-Up Land by the FMMP , which is defined as land that is occupied by structures with a building density of at least 1 unit to 1.5 acres, or approximately six structures to a 10-acre parcel.
The Williamson Act, codified in 1965 as the California Land Conversation Act, allows local governments to enter into contracts with private landowners, offering tax incentives in exchange for an agreement that the land will remain undeveloped or related open space use only for a period of 10 years.
Additionally, according to the Williamson Act map for Orange County FMMP, the project site is not under a Williamson Act Contract and there are no Williamson Act lands in the vicinity.15 CEQA requires the evaluation of forest and timber resources where those resources are present; however, the project site is located within a commercial area of Santa Ana and there is no forest land as described in Public Resources Code Section 12220(g), timberland as defined by Public Resources Code Section 4526, or property zoned for Timberland Production as defined by Government Code Section 51104(g) on the site or in its vicinity.
Would the project:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use? No impact. There is currently no Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) within the City, including the project site. Therefore, impacts related to Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) would not occur. b) Conflict with existing zoning for agricultural use, or a Williamson Act Contract? Less than significant impact. There is currently no land in the City under a Williamson Act Contract.16
According to the Zoning Ordinance, the project site is zoned A1, although it currently operates as an overflow parking lot for the zoo. The proposed project would continue this use, and includes a proposed rezoning to C2 to ensure alignment between the ongoing use of the site and the underlying zoning. As such, the proposed project would not conflict with zoning.
While the proposed project would change existing zoning that allows for agricultural use, the proposed project would not impact an existing agricultural use nor would it have any impact on a Williamson Act Contract. Therefore, impacts would be less than significant.
15 City of Santa Ana. 2021. Final Recirculated Program Environmental Impact Report, Chapter 8 - Impacts Found Not to Be Significant. Website: https://general-plan-santa-ana-ca.proudcity.com/documents/chapter-8-impacts-found-not-to-be- significant/. Accessed July 7, 2025.
16 Ibid.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
26 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
No impact. CEQA requires the evaluation of forest and timber resources where those resources are present; however, the project site is located in an urban built-up area and there is no forest or timberland in the vicinity. The project site is developed and used as an overflow parking lot for the Santa Ana Zoo. The project site is not designated as or zoned for forest land, timberland, or Timberland Production. As such, no impact would occur.
d) Result in the loss of forest land or conversion of forest land to non-forest use? No impact. The project is located in an urban built-up area; there is no forest land within the vicinity of the project site. The project site does not contain forest land and is used as an overflow parking lot for the Santa Ana Zoo. As such, no impact would occur.
e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to nonagricultural use or conversion of forest land to non-forest use?
No impact. As mentioned above, there is no farmland or forestland in or around the project site.
Therefore, the proposed project would not induce the conversion of Farmland to nonagricultural uses or the conversion of forest land to non-forest use. No Impact would occur.
Mitigation Measures
None required.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 27
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Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.3 Air Quality
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.
Would the project:
a) Conflict with or obstruct implementation of
the applicable air quality plan?
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which
the project region is nonattainment under
an applicable federal or State ambient air
quality standard?
c) Expose sensitive receptors to substantial
pollutant concentrations?
d) Result in other emissions (such as those
leading to odors or) adversely affecting a
substantial number of people?
Environmental Evaluation
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.
Setting
The proposed project is located within the City of Santa Ana, in Orange County, which is within the South Coast Air Basin (SoCAB). The SoCAB includes all of Orange County, Los Angeles County (except for the Antelope Valley), the non-desert portion of western San Bernardino County, and the western and Coachella Valley portions of Riverside County. The San Gabriel, San Bernardino, and San Jacinto Mountains bound the SoCAB on the north and east while the Pacific Ocean lies to the west of the SoCAB. The southern limit of the SoCAB is the San Diego County line. The SoCAB is under the jurisdiction of South Coast Air Quality Management District (SCAQMD). 17 The air pollutants for which national and State standards have been promulgated and that are most relevant to air quality planning and regulation in the SoCAB include ozone, nitrogen oxides (NO X),
17 South Coast Air Quality Management District (SCAQMD). 2022. Air Quality Management Plan.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
28 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx carbon monoxide (CO), particulate matter, including dust, 10 micrometers or less in diameter (PM10), and particulate matter, including dust, 2.5 micrometers or less in diameter (PM2.5). In addition, toxic air contaminants (TACs) are of concern in the SoCAB. Each of these pollutants is briefly described below. Other pollutants that are regulated but not considered an issue in the project area are sulfur dioxide, vinyl chloride, sulfates, hydrogen sulfide, and lead; the proposed project would not emit substantial quantities of those pollutants, so they are not discussed further in this section.
Ozone is a gas that is formed when reactive organic gases (ROG), also known as volatile organic compounds (VOC), and NOX—both byproducts of internal combustion engine exhaust—undergo slow photochemical reactions in the presence of sunlight. Ozone concentrations are generally highest during the summer months when direct sunlight, light wind, and warm temperature conditions are conducive to its formation. Ozone effects can include the following: irritation of the respiratory system; reduced lung function; breathing pattern changes; reduced breathing capacity; inflammation and damage to cells that line the lungs; lungs more susceptible to infection; aggravated asthma; aggravated other chronic lung diseases; permanent lung damage; some immunological changes; increased mortality risk; and vegetation and property damage.
CO is a colorless, odorless gas produced by the incomplete combustion of fuels. CO concentrations tend to be the highest during winter mornings, with little to no wind, when surface-based inversions trap the pollutant at ground levels. Because CO is emitted directly from internal combustion engines—unlike ozone—and motor vehicles operating at slow speeds are the primary source of CO in the SoCAB, the highest ambient CO concentrations are generally found near congested transportation corridors and intersections. Potential health effects from CO range depending on exposure: slight headaches; nausea; aggravation of angina pectoris (chest pain) and other aspects of coronary heart disease; decreased exercise tolerance in persons with peripheral vascular disease and lung disease; impairment of central nervous system functions; possible increased risk to fetuses; and death.
PM10 and PM2.5 consist of extremely small, suspended particles or droplets 10 microns and 2.5 microns or smaller in diameter, respectively. Some sources of particulate matter, like pollen and windstorms, are naturally occurring. However, in populated areas, most particulate matter is caused by road dust, diesel soot, combustion products, abrasion of tires and brakes, and construction activities. Health effects from short-term exposure (hours per days) can include the following: irritation of the eyes, nose, throat; coughing; phlegm; chest tightness; shortness of breath; and aggravation of existing lung disease causing asthma attacks and acute bronchitis; those affected with heart disease can suffer heart attacks and arrhythmias. Health effects from long-term exposure can include the following: reduced lung function; chronic bronchitis; changes in lung morphology; and death.
TACs refer to a diverse group of air pollutants that can affect human health but have not had ambient air quality standards established for them. Diesel particulate matter (DPM) is a TAC emitted from construction equipment and diesel-fueled vehicles and trucks. Some short-term (acute) effects of DPM exposure include eye, nose, throat, and lung irritation; coughing; headache; light-headedness; and nausea. Studies have linked elevated particle levels in the air to increased hospital admissions, emergency room visits, asthma attacks, and premature deaths among those suffering from
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 29
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx respiratory problems. Human studies on the carcinogenicity of DPM demonstrate an increased risk of lung cancer, although the increased risk cannot be clearly attributed to diesel exhaust exposure.
Construction and operation of the proposed project would be subject to applicable SCAQMD rules and requirements. The SCAQMD CEQA Air Quality Significance Thresholds were developed to assist local jurisdictions and lead agencies in complying with the requirements of CEQA regarding potentially adverse impacts to air quality.18
Would the project:
a) Conflict with or obstruct implementation of the applicable air quality plan? Less than significant impact. The 2022 Air Quality Management Plan (AQMP) is the current applicable regional Air Quality Plan (AQP) of SCAQMD. The primary goals of the AQP are to protect public health and protect the climate. The 2022 AQMP includes the integrated strategies and measures needed to meet the National Ambient Air Quality Standards (NAAQS). Furthermore, the 2022 AQMP demonstrates attainment of the 1-hour and 8-hour ozone NAAQS as well as the latest 24-hour and annual PM
2.5 standards.19
Because the proposed project does not involve population or employment growth, determining consistency with the 2022 AQMP involves assessing whether applicable control measures contained in the 2022 AQMP are implemented and whether implementation of the proposed project would disrupt or hinder implementation of AQP control measures. All projects within SCAQMD’s jurisdiction are required to implement Rule 403 as the Best Available Control Measures (BACMs) during construction activities. The proposed project would implement all BACMs consistent with Rule 403 during construction activities and would be consistent with the assumptions in the AQMP.
Furthermore, the proposed project is a typical construction design for parking lots and would not include any special features that would disrupt or hinder implementation of the AQMP control measures.
In addition, if a project’s emissions do not exceed the SCAQMD regional thresholds for VOC, NO X,
CO, SOX, PM10, or PM2.5, it follows that the project’s emissions would not exceed the allowable limit for each project in order for the region to attain and maintain ambient air quality standards, which is the primary goal of air quality plans. As shown in Impact 2.3(b), the proposed project would not exceed the SCAQMD’s regional thresholds of significance during construction and operation.
Therefore, the proposed project would not conflict with or obstruct implementation of the 2022 AQMP.
This impact would be less than significant.
18 South Coast Air Quality Management District (SCAQMD). 2023. Air Quality Significance Thresholds. Website:
https://www.aqmd.gov/docs/default-source/ceqa/handbook/south-coast-aqmd-air-quality-significance- thresholds.pdf?sfvrsn=f7601d61_25. Accessed July 25, 2025. 19 South Coast Air Quality Management District (SCAQMD). 2022. Air Quality Management Plan.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard?
Less than significant impact. The SCAQMD’s thresholds of significance represent the allowable amount of emissions a project can generate without generating a cumulatively considerable contribution to regional air quality impacts. Therefore, a project that would not exceed the SCAQMD thresholds of significance on a project level also would not be considered to result in a cumulatively considerable contribution to these regional air quality impacts. The region is nonattainment for the federal and State ozone standards, nonattainment for the federal and State PM2.5 standards, and nonattainment for State PM10 standards. Impacts related to construction and operations of the proposed project are addressed separately below.
Construction Emissions
Emissions from construction-related activities are generally short-term in duration but may still cause adverse air quality impacts. The proposed project would generate emissions from construction equipment exhaust, vehicle and truck travel, and fugitive dust. These construction emissions include criteria air pollutants and precursors from the operation of heavy construction equipment.
Construction Fugitive Dust
The SCAQMD requires all development projects to implement Rule 403–Fugitive Dust in order to ensure that construction-related fugitive dust emissions are considered less than significant.
Compliance with this rule is achieved through the application of BACMs. For example, some BACMs that would be required include watering active construction sites three times daily, applying nontoxic chemical soil stabilizers to inactive construction areas, and suspending all grading activities when wind speeds exceed 25 miles per hour (mph). These required measures would help to reduce potential fugitive dust emissions associated with construction activities for the proposed project.
Construction emissions were estimated for the activities associated with removal of existing ground materials, site preparation, grading, trenching, installation of the EV charging stations and solar panel structures, and paving. Based on City-provided information, it is expected that construction of the proposed project would be completed in three months (January–March 2027). The construction schedule and off-road construction equipment list can be found in Appendix A. The exhaust emissions generated by construction equipment are based on the hours of operation, horsepower, and load factors of the equipment. The duration of construction activity and associated equipment represent a reasonable approximation of the expected construction fleet as required by CEQA Guidelines.
The proposed project’s maximum daily construction emissions are shown and compared with the significance thresholds in Table 1.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Table 1: Maximum Daily Construction Emissions
Construction Emissions
Regional Pollutant Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
Maximum Daily Emissions 4.88 29.69 23.61 0.08 8.76 2.33 SCAQMD Significance Threshold 75 100 550 150 150 55
Exceed Threshold? No No No No No No
Notes:
CO = carbon monoxide
NOX = nitrogen oxides
PM10 = particulate matter less than 10 microns in diameter PM2.5 = particulate matter less than 2.5 microns in diameter SCAQMD = South Coast Air Quality Management District
SOX = sulfur oxides
VOC = volatile organic compounds
The PM10 and PM2.5 emissions reflect the combined exhaust and fugitive dust emissions with dust control measures from SCAQMD Rule 403.
Source: Appendix A.
As shown in Table 1, the combined construction emissions from all components of the proposed project would be below the recommended thresholds of significance. Therefore, project construction would result in a less than significant impact.
Operational Emissions
The proposed project would generate operational emissions principally from vehicle traffic accessing the site. The proposed project’s trip generation during operation is taken from Urban Crossroads’ Santa Ana Rezone Trip Generation Assessment (Appendix E). For conservative analysis, the project’s vehicle fleet mix has not been adjusted to reflect that the majority of vehicles accessing the EV charging station portion of the proposed project would be electric vehicles that would not generate emissions. The following analysis relates to localized and regional criteria pollutant impacts.
Emissions resulting from various aspects of the proposed project are discussed separately below.
The proposed project’s maximum daily operations emissions are shown and compared with the significance thresholds in Table 2.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Table 2: Maximum Daily Operation Emissions
Operations
Regional Pollutant Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
Maximum Daily Emissions 3.26 1.85 20.33 0.05 4.44 1.15
SCAQMD Significance Threshold 55 55 550 150 150 55
Exceed Threshold? No No No No No No
Notes:
CO = carbon monoxide
NOX = nitrogen oxides
PM10 = particulate matter less than 10 microns in diameter PM2.5 = particulate matter less than 2.5 microns in diameter SCAQMD = South Coast Air Quality Management District
SOX = sulfur oxides
VOC = volatile organic compounds
Source: Appendix A.
As shown in Table 2, operational criteria pollutant emissions would not be anticipated to exceed the recommended thresholds of significance. Therefore, the proposed project’s long-term operational impacts would be less than significant.
c) Expose sensitive receptors to substantial pollutant concentrations? Less than significant impact. This impact evaluates the potential for the proposed project’s construction and operational emissions to expose sensitive receptors to substantial pollutant concentration. Sensitive receptors are defined as those individuals who are sensitive to air pollution including children, the elderly, and persons with pre-existing respiratory or cardiovascular illness. For purposes of CEQA, the SCAQMD considers a sensitive receptor to be a location where a sensitive individual could remain for 24 hours, such as residences, hospitals, or convalescent facilities.20 For the proposed project, the closest off-site sensitive receptor is a mobile home community located approximately 160 feet south of the project boundary.
Localized Significance Thresholds
The SCAQMD has developed localized significance thresholds (LSTs) as a tool to assist lead agencies in analyzing localized air quality impacts to sensitive receptors in the vicinity of the project.
The SCAQMD’s LST Methodology outlines how to analyze localized impacts from common pollutants of concern, including NOx, CO, PM10, and PM2.5.21 Localized air quality impacts would occur if pollutant concentrations at sensitive receptors exceeded applicable NAAQS or California Ambient Air
20 South Coast Air Quality Management District (SCAQMD). 2008. Final Localized Significance Threshold Methodology.
Revised July 2008. Website: http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/localized- significance-thresholds. Accessed July 22, 2025.
21 Ibid.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Quality Standards (CAAQS). To minimize efforts, the SCAQMD developed mass rate lookup tables as a simple screening procedure. If a project’s on-site emissions do not exceed the screening levels for any pollutant, it can be concluded that the project would not cause or contribute to an adverse localized air quality impact. Screening levels are provided for various distances (i.e., 82 feet [25 meters], 164 feet [50 meters], 328 feet [100 meters], 656 feet [200 meters], and 1,640 feet [500 meters]) between the project boundary and the nearest sensitive receptor and various project site acreages (i.e., 1, 2, and 5 acres). As discussed above, the closest sensitive receptors are 160 feet, or approximately 50 meters, south of the project site.
The LST Methodology only applies to on-site emissions and states that “off-site mobile emissions from the project should not be included in the emissions compared to LSTs.” However, if a project’s overall emissions (i.e., including off-site mobile emissions) are below the LSTs, then the proposed project’s on-site impacts would also fall below the LSTs. For streamlined yet conservative analysis purposes, and given the proposed project’s minimal construction and operation emissions, the proposed project’s overall emissions are compared to the LSTs.
Localized Construction Analysis
Although the project site is 3.43 acres, the proposed project would only actively disturb fewer acres a day during construction phases. Therefore, the LST screening thresholds for 1 acre were utilized for the LST analysis, which are the most stringent screening thresholds. The LSTs have been obtained from the LST Methodology for 1-acre project sites located in Source Receptor Area 17, Central Orange County.
Table 3 presents the proposed project’s maximum daily on-site emissions compared with the applicable LSTs.
Table 3: Construction Localized Significance Screening Analysis Activity
On-site Emissions (pounds per day)
NOX CO PM10 PM2.5
Maximum Daily Construction Emissions 29.69 23.61 8.76 2.33 Localized Significance Thresholds
(SRA 17, 1-acre site, 50 meter distance to receptor) 83 173 12 4 Exceeds Threshold? No No No No
Notes:
NOX = oxides of nitrogen
CO = carbon monoxide
PM10 = particulate matter less than 10 microns in diameter PM2.5 = particulate matter less than 2.5 microns in diameter SRA = State Responsibility Area
Source of emissions: Appendix A.
Source of thresholds: SCAQMD Mass Rate Lookup Tables for 1-acre site in Source Receptor Area 17 for sensitive receptors located 50 meters from the project site.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx As shown in Table 3, project construction emission would not exceed the SCAQMD’s most stringent LSTs and would not be expected to result in concentrations that could exceed ambient air quality standards or contribute substantially to an existing exceedance of an ambient air quality standard.
Impacts relating to localized construction emissions would be less than significant.
Localized Operation Analysis
Similar to the construction LST analysis above, the applicable operational LSTs were obtained for a project located in State Responsibility Aea (SRA) 17 with the nearest sensitive receptor being 50 meters away. Long-term operations for the proposed project would occur on the 3.43-acre project site. The LST screening levels only provide thresholds for 1-acre, 2-acre, or 5-acre sites. Therefore, for conservative analysis, the LST thresholds for a 2-acre site are used to determine project impacts.
Table 4 presents the proposed project’s maximum daily on-site emissions compared with the appropriate LSTs.
Table 4: Operation Localized Significance Screening Analysis Activity
On-site Emissions (pounds per day)
NOX CO PM10 PM2.5
Maximum Daily Operation Emissions 29.69 23.61 4.44 1.15 Localized Significance Thresholds
(SRA 17, 2-acre site, 50 meter distance to receptor) 114 1041 5 2 Exceeds Threshold? No No No No
Notes:
NOX = oxides of nitrogen
CO = carbon monoxide
PM10 = particulate matter less than 10 microns in diameter PM2.5 = particulate matter less than 2.5 microns in diameter
Source of emissions: Appendix A.
Source of thresholds: SCAQMD Mass Rate Lookup Tables for 2-acre site in Source Receptor Area 17 for sensitive receptors located 50 meters from the project site.
As shown in Table 3, project operation emissions would not exceed the SCAQMD’s LSTs and would not be expected to result in concentrations that could exceed ambient air quality standards or contribute substantially to an existing exceedance of an ambient air quality standard. Impacts relating to localized operation emissions would be less than significant.
Project CO Hotspot Assessment
An adverse CO concentration, known as a hotspot, would occur if an exceedance of the State 1-hour standard of 20 parts per million (ppm) or the 8-hour standard of 9 ppm were to occur. CO emissions are a function of vehicle idling time, meteorological conditions, and traffic flow. Under certain extreme
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthy levels (i.e., adversely affect residents, school children, hospital patients, the elderly, etc.).22 Because traffic congestion is highest at intersections where vehicles queue and are subject to reduced speeds, these hot spots are typically produced at intersection locations.
None of the intersections near the project site would have peak-hour traffic volumes exceeding those at the intersections modeled in the 2003 AQMP. Additionally, the adjacent roadways are not located in an area where vertical or horizontal atmospheric mixing is substantially limited, such as a tunnel or overpass. Furthermore, there are no factors unique to the local meteorology to conclude that this intersection would yield higher CO concentrations if modeled in detail. Therefore, the operational CO impact would be less than significant.
Toxic Air Contaminants Impact to Sensitive Receptors
The proposed project would generate TACs, such as DPM, during construction due to the use of off- road construction equipment and haul trucks. DPM is represented as exhaust emissions of PM10 and PM2.5. As shown in Table 3, project construction would emit at most 8.76 and 2.33 pounds per day of PM10 and PM2.5. As discussed in Impact 2.3(b), emissions during construction would not exceed the SCAQMD’s significance thresholds for PM2.5 and PM10 and would not be expected to result in concentrations that could exceed ambient air quality standards or contribute substantially to an existing exceedance of an ambient air quality standard.
In addition, the Office of Environmental Health Hazard Assessment (OEHHA)’s risk assessment methodology is designed to be health-protective and assumes chronic exposure over a 30-year residential receptor duration to estimate maximum individual cancer risk. However, the construction activities for the proposed project are short-term in nature, with an estimated duration of only three months. Given this limited timeframe, exposure to DPM from diesel-powered construction equipment would be brief and substantially less than the multi-year exposure period assumed in OEHHA’s conservative risk models.
As a result, even if sensitive receptors are located near the construction site, the actual health risk from construction emissions would be orders of magnitude lower than a typical 30-year chronic exposure scenario. Based on this brief construction window and the temporary nature of emissions, the project’s construction-related health risks are considered less than significant.
Post-construction, the proposed project would be used as an overflow parking lot. The vehicles that access the site would largely be gasoline or electricity powered and would not be a significant source of DPM emissions. Therefore, the proposed project’s operation-related health risks are considered less than significant.
22 California Office of Environmental Health Hazard Assessment (OEHHA). 2015. Air Toxics Hot Spot Program Risk Assessment Guidelines – Guidance Manual for Preparation of Health Risk Assessments. Website:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. Accessed July 25, 2025.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx d) Result in other emission (such as those leading to odors) adversely affecting a substantial number of people?
Less than significant impact. The proposed project would not be a source of other emissions, such as those leading to odors, during operations. During construction, a limited number of diesel engines would be operating on the project site for limited durations. Diesel exhaust and VOCs from these diesel engines would be emitted during construction of the proposed project, which are objectionable to some; however, the duration of construction activities is expected to be very short (3 months), emissions would disperse rapidly from the project site, and diesel exhaust odors would be consistent with existing vehicle odors in the area. Post-construction, the proposed project would continue to operate as a parking lot and would not be an odor generating use. Considering this information, construction and operation of the proposed project would not create other emissions or odors adversely affecting a substantial number of people; impacts would be less than significant.
Mitigation Measures
None required.
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Impact with
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Less than
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Impact No Impact
2.4 Biological Resources
Would the project:
a) Have a substantial adverse effect, either
directly or through habitat modifications, on
any species identified as a candidate,
sensitive, or special-status species in local or
regional plans, policies, or regulations, or by
the California Department of Fish and Wildlife
or United States Fish and Wildlife Service?
b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional plans,
policies, and regulations or by the California
Department of Fish and Wildlife or United
States Fish and Wildlife Service?
c) Have a substantial adverse effect on State or
federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal,
etc.) through direct removal, filling,
hydrological interruption, or other means?
d) Interfere substantially with the movement of
any native resident or migratory fish or wildlife
species or with established native resident or
migratory wildlife corridors, or impede the use
of wildlife nursery sites?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or State Habitat
Conservation Plan?
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Evaluation
Setting
Methods
The biological resources evaluation included a review of existing environmental documentation for the project site and vicinity, including literature pertaining to the habitat requirements of special-status species with the potential to occur in the project vicinity and federal register listings, protocols, and species data provided by the United States Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW). FirstCarbon Solutions (FCS) Biologists also reviewed topographic maps, aerial photographs, and published soil surveys and queried special-status species databases, including the USFWS Information for Planning and Consultation (IPaC) database,23 the California Natural Diversity Database (CNDDB),24 and the California Native Plant Society Electronic Inventory of Rare and Endangered Vascular Plants of California (CNPS Inventory).25 The literature and database reviews were conducted on April 23, 2025, and are included in Appendix B.
Environmental Setting
The project site is located in an urbanized area and is surrounded by I-5 to the north, Church of Christ in Tustin to the east, East Main Street and Saddleback Mobile Lodge Club to the south, and the Santa Ana Zoo to the west. The project site is currently a gravel lot and is relatively flat, with minimal slopes increasing from south to north. Ornamental trees and shrubs are located along the southern and western boundaries of the site.
Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service? No impact. The project site contains ornamental trees located along the southern and western boundaries. Under existing conditions, areas within 500 feet of the project site are urbanized with no native vegetation communities or wildlife habitats present. Because of the urban/developed nature of the project site and lack of suitable habitat, there is no potential for occurrence of the special-status plant and wildlife species recorded within the Tustin, California USGS 7.5-minute Topographic Quadrangle Map and the eight surrounding quadrangle search area that encompasses the project
23 United States Fish and Wildlife Service (USFWS). 2025. Information for Planning and Consultation (IPaC). Website:
https://ecos.fws.gov/ipac/. Accessed April 23, 2025.
24 California Department of Fish and Wildlife (CDFW). 2025. CNDDB RareFind 5 California Natural Diversity Database Query for Special-Status Species. Website: https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data. Accessed April 23, 2025.
25 California Native Plant Society (CNPS). 2025. California Native Plant Society Rare and Endangered Plant Inventory.
Website: http://www.rareplants.cnps.org/. Accessed April 23, 2025.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx site as recorded in the CNDDB and CNPS Inventory (Appendix B). Therefore, no impacts to sensitive or special-status species would occur.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service?
No impact. The area surrounding the project site is fully developed. The project site does not contain any naturally occurring vegetation communities that could be considered sensitive, including riparian habitat. Therefore, no impact would occur.
c) Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? No impact. The project site occurs in an urbanized area in the City, and no wetlands or other hydrological features that meet criteria as waters of the United States or waters of the State are present within the proposed project site. Additionally, the project site is not located adjacent to any known potentially jurisdictional water body. According to the Natural Resources Conservation Service (NRCS) Web Soil Survey (WSS),26 one soil type is mapped on the project site, Mocho loam. These soils are not known to support vernal pools. Therefore, implementation of the proposed project would not result in impacts to State or federally protected wetlands, including vernal pools. No impact would occur.
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of wildlife nursery sites?
Less than significant impact with mitigation incorporated. The project site is developed and is surrounded by urbanized areas, roads, and highways on all sides that limit wildlife movement through the project site. The project site itself does not serve as a wildlife movement corridor.
The project site contains vegetation that could provide suitable nesting habitat for bird species protected under the Migratory Bird Treaty Act (MBTA) and the Fish and Game Code. If ground- disturbing or vegetation-removing construction activities are initiated during the nesting season, they could disturb nesting and breeding birds on the ground surface, in trees and shrubs, and on structures on and adjacent to the project site, which would be considered a significant impact under CEQA. Potential construction-related project impacts on migratory birds include destruction of eggs or occupied nests, mortality of young, and causing parental abandonment of nests with eggs or pre- fledged young birds. With the implementation of Mitigation Measure (MM) BIO-1a and MM BIO-1b, potential project impacts to nesting native and migratory birds would be reduced to a less than significant level.
26 Natural Resources Conservation Service (NRCS). 2025. Web Soil Survey (WSS). United States Department of Agriculture (USDA). Website: https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx. Accessed April 23, 2025.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less than significant impact. The proposed project would be required to comply with the City Municipal Code pertaining to the protection of trees, specifically Article VII, Regulation for the Planting, Maintenance, and Removal of Trees. Compliance with this Code would ensure that the proposed project would not conflict with any local policies or ordinances protecting trees or other biological resources. As such, impacts would be less than significant. f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State Habitat Conservation Plan?
No impact. The project site is not located within the boundaries of any federal Habitat Conservation Plan (HCP) or State Natural Community Conservation Plan (NCCP). The project site is outside of the County of Orange Natural Communities Conservation Plan/Habitat Conservation Plan (CONCCP/HCP) as authorized by the CDFW through the NCCP Act (California Fish and Game Code [FGC] § 2800) and Sections 2081 and 2084 of the California Endangered Species Act (CESA) and by the USFWS through Sections 7 and 10 of the federal Endangered Species Act. Therefore, the proposed project would not conflict with an HCP, NCCP, or other approved local, regional, or State HCP. No impact would occur.
Mitigation Measures
MM BIO-1a Nesting Bird Pre-construction Surveys
If ground-disturbing or vegetation-removing construction activities or tree removal is proposed during the breeding/nesting season for migratory birds (typically February 1 through September 15), a qualified Biologist shall conduct pre-construction surveys for special-status birds and other migratory birds within the construction area, including a 300-foot survey buffer, no more than 3 days prior to the start of ground- disturbing activities in the construction area.
MM BIO-1b Avoidance of Active Avian Nests
If an active nest is located during pre-construction surveys or at any point during the construction phase of the proposed project, the United States Fish and Wildlife Service (USFWS) and/or California Department of Fish and Wildlife (CDFW) (as appropriate) shall be notified regarding the status of the nest. Furthermore, construction activities shall be restricted as necessary to avoid disturbance of the nest until it is abandoned, or a qualified Biologist deems disturbance potential to be minimal. Restrictions may include establishment of exclusion zones (no ingress of personnel or equipment at a minimum radius of 300 feet around an active raptor nest and a 50-foot radius around an active migratory bird nest) or alteration of the construction schedule.
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Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.5 Cultural Resources and Tribal Cultural Resources
Would the project:
a) Cause a substantial adverse change in
the significance of a historical resource as
pursuant to Section 15064.5?
b) Cause a substantial adverse change in
the significance of an archaeological
resource pursuant to Section 15064.5?
c) Disturb any human remains, including
those interred outside of formal
cemeteries?
Would the project cause a substantial adverse change in the significance of a Tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, 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:
d) 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), or
e) 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.
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Setting
This section describes the existing cultural resources setting and potential effects from project implementation on the project site and its surrounding area. Descriptions and analysis in this section are based on information provided by the California Native American Heritage Commission (NAHC), South Central Coastal Information Center (SCCIC), National Register of Historic Places (NRHP), California Register of Historical Resources (CRHR), California Historic Landmarks list, California Points of Historical Interest (CPHI) list, California Historical Resources Inventory, and the California Built Environment Resource Directory (BERD). The non-confidential records search results and other correspondence are included in Appendix C.
South Central Costal Information Center
On February 25, 2025, a records search for the project site and a 0.5-mile search radius was conducted at the SCCIC located California State University, Fullerton. To identify any historic properties or resources, the current inventories of the NRHP, the CRHR, the California Historical Landmark (CHL) list, the CPHI list, and the BERD for Orange County were reviewed to determine the existence of previously documented local historical resources. Results from the SCCIC indicate that three historic built environment resources are recorded within a 0.5-mile of the project site; however, no resources are recorded within the project boundaries. In addition, nine area-specific survey reports are on file within the 0.5-mile radius, and two of them partially address the project site. This indicates that the project site has not been fully surveyed for cultural resources.
Native American Heritage Commission
On February 10, 2025, FCS sent a letter to the NAHC in an effort to determine whether any sacred sites are listed on its Sacred Lands File (SLF) for the project site. A response was received on February 26, 2025, indicating that the SLF search produced a negative result for Native American cultural resources in the proposed project. The NAHC included a list of 22 Tribal representatives available to provide additional information pertaining to Tribal Cultural Resources (TCRs). To ensure that all Native American knowledge and concerns over potential TCRs that may be affected by the proposed project are addressed, a letter containing project information and requesting any additional information was sent to each Tribal representative on March 4, 2025. One response was received on March 6, 2025, from the Santa Rosa Band of Cahuilla Indians stating that the Tribe would defer any comments to Soboba Band of Luiseño Indians cultural resource department. No additional responses have been received to date.
Pedestrian Survey and Buried Site Potential
On March 13, 2025, FCS Staff Archaeologist Maximillian Ochoa conducted a pedestrian survey for unrecorded cultural resources at the project site. The project site is 3.48 acres and is entirely hardscaped, it is bordered by I-5 to the north, the Santa Ana Zoo to the west, East Main Street to the south, and Church of Christ in Tustin to the east. The survey covered the subject property where possible, beginning in the southeastern corner of the project site. The topographical conditions of the
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx survey were for the most part relatively flat and clear with approximately 5 percent of native soil visibility. The project site is heavily disturbed by modern materials and is utilized as a parking lot. The eastern boundary of the project site was unable to be thoroughly surveyed as it contained a utility building that was fenced off and locked which can be seen in Photographs 1 and 4 (Appendix C), respectively. Furthermore, a fence divides a portion of the southern boundary from the rest of the proposed project which can be seen in Photographs 3 and 10 (Appendix C).
As the project site is heavily covered by manufactured materials such as trailers in the northwest and by construction equipment to the east and south and is made up of mainly compacted dirt and gravel.
Conducting traditional 15-meter transects to survey was forgone in favor of photography and utilizing corner overview shots to display the conditions of the project site. During the survey, Mr. Ochoa examined all areas of the exposed ground surface for pre-contact artifacts (e.g., fire-affected rock, milling tools, flaked stone tools, toolmaking debris, ceramics), soil discoloration and depressions that might indicate the presence of a cultural midden, faunal and human osteological remains, and features indicative of the former presence of structures or buildings (e.g., postholes, standing exterior walls, foundations) or historic debris (e.g., glass, metal, ceramics). All areas of the project site were closely examined for culturally modified soils or other indicators of potential historic or pre-contact resources. No historic or pre-contact cultural resources or raw materials were observed.
In addition to the pedestrian survey, the potential for unidentified cultural resources in the vicinity was reviewed against geologic and topographic geographic information system data for the general area and information from other nearby projects. The proposed project was evaluated against a set of criteria identified by a geoarchaeological overview of the Central Valley that was prepared for the California Department of Transportation (Caltrans) Districts 6 and 9. 27 This study mapped the
“archaeological sensitivity,” or potential to support the presence of buried pre-contact archaeological deposits, throughout the San Francisco Bay Area based on geology and environmental parameters including distance to water and landform slope. The methodology used in the study is applicable to other parts of California and concluded that sites consisting of flat, Holocene-era deposits in close proximity to water resources had a moderate to high probability of containing subsurface archaeological deposits when compared to earlier Pleistocene deposits situated on slopes or further away from drainages, lakes, and rivers.
According to the geologic map of the Northern Santa Ana Mountains, California,28 the project site is situated on younger alluvium deposits (Qya). Applying the criteria set forth above, the terrain of the project site is flat and completely hardscaped, and there is no water source in proximity to the proposed project. Based on the negative SLF search results, pedestrian survey, and the absence of pre-contact resources within the project site or the 0.5-mile search radius, the potential for unanticipated buried cultural resources to be impacted by project construction is low.
27 Meyer, J., D. Craig Young, and Jeffrey S. Rosenthal. 2010. Volume I: A Geoarchaeological Overview and Assessment of Caltrans District 6 and 9, Cultural Resources Inventory of Caltrans District 6/9 Rural Conventional Highways. Submitted to Central California Department of Transportation, District 6. 28 United States Department of the Interior Geological Survey. 1929. Geologic Map of the Northern Santa Ana Mountains, California.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Cultural Resources
Would the project:
a) Cause a substantial adverse change in the significance of a historical resource as pursuant to Section 15064.5?
No impact. Results from the SCCIC indicate that no historical resources have been recorded within the project site; however, three historic built environment resources have been recorded within the
0.5-mile search radius of the project site. In addition, the pedestrian survey failed to identify any historical resources within the project site. Furthermore, a review of 29 historic aerial photographs depicting the project site from 1946 to 2022 indicate that the project site remained undeveloped. The project site does not contain any buildings, structures, or objects that could potentially qualify as historical resources under CEQA. Therefore, there would be no impact related to historical built environment resources.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Less than significant impact with mitigation incorporated. Results from the SCCIC indicate that there are no pre-contact archaeological resources located within the project boundaries, or the 0.5- mile radius. In addition, the pedestrian survey failed to identify any archaeological resources. While there are no known archaeological resources within the project site, it is possible that earthmoving activities associated with project construction could encounter previously undiscovered archaeological resources. Archaeological resources can include but are not limited to stone, bone, wood, or shell artifacts or features, including hearths and structural elements. Damage or destruction of these resources would be a potentially significant impact. Implementation of MM CUL-1 would ensure that this potential impact is reduced to a less than significant level. As such, the proposed project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5 with the implementation of MM CUL-1. Impacts would be less than significant with mitigation incorporated.
c) Disturb any human remains, including those interred outside of formal cemeteries? Less than significant impact with mitigation incorporated. As noted above, results from the SCCIC and pedestrian survey failed to locate or identify any human remains and/or cemeteries. The potential for the disturbance of any human remains is considered low. While it is unlikely that the presence of human remains exists within or near the project site, there is always the possibility that subsurface construction activities associated with the proposed project, such as grading or trenching, could potentially damage or destroy previously undiscovered human remains.
In the event of the accidental discovery or recognition of any human remains, CEQA Guidelines Section 15064.5, Health and Safety Code Section 7050.5, and Public Resources Code Sections 5097.94 and 5097.98 must be followed. MM CUL-2 further specifies the procedures to follow in the event human remains are uncovered. Along with compliance with these guidelines and statutes,
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx implementation of this mitigation would reduce potential impacts related to human remains to a less than significant level.
Tribal Cultural Resources
Would the project cause a substantial adverse change in the significance of a Tribal Cultural Resource, defined in Public Resources Code Section 21074 as either a site, feature, 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:
d) 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), or
Less than significant impact with mitigation incorporated. A review of the CRHR, local registers of historic resources, the SCCIC records search, and the NAHC SLF search results, and subsequent Tribal representative outreach failed to identify any listed or eligible for listing TCRs that may be adversely affected by the proposed project. Should any undiscovered TCRs be encountered during project construction, implementation of MM CUL-1 and MM CUL-2 would ensure that undiscovered TCRs are not adversely affected by project-related construction activities. e) 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.
Less than significant impact with mitigation incorporated. Tribal consultation efforts conducted by the City pursuant to Assembly Bill (AB) 52 and Senate Bill (SB) 18 to identify additional significant TCRs meeting the criteria set forth in Public Resources Code Section 5024.1 (c) were initiated on April 11, 2025, and letters were sent to each Tribe on the NAHC consultation list. Three Tribal responses were received requesting to consult on the proposed project.
The Juaneño Band of Mission Indians Acjachemen Nation 84A consultation meeting was scheduled on May 15, 2025, to discuss any concerns that the Tribe may have pertaining to the development of the proposed project. The Tribe did not express any concerns about the implementation of the project. Consultation concluded on May 15, 2025.
The Juaneño Band of Mission Indians Acjachemen Nation–Belardes requested to consult on May 21, 2025. On May 27, 2025, the Tribe requested to consult via email correspondence. The Tribe also requested additional information pertaining to the extent of ground disturbance and a copy of the California Historical Resources Information System (CHRIS) SCCIC record search results. This information was provided to the Tribe on May 29, 2025, and June 11, 2025. The Tribe requested a draft of the inadvertent discovery plan, when available, and that information was provided to the Tribe on July 29, 2025. On July 30, 2025, the Tribe provided a response and did not express concerns
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx pertaining to the inadvertent discovery plan; however, the Tribe requested to be notified if any changes are made to the mitigation measures. Consultation concluded on July 30, 2025.
The City received a response from the Gabrieleño Band of Mission Indians–Kizh Nation on May 14, 2025, requesting to consult on the proposed project. A consultation meeting was scheduled on July 22, 2025; however, Chairman Salas was unable to attend the meeting and the Tribe indicated that they would email information/requirements to the City and thereby satisfy consultation. Consultation efforts are ongoing.
Should any undiscovered TCRs be encountered during project construction, implementation of MM CUL-1 and MM CUL-2 would ensure that undiscovered TCRs are not adversely affected by project- related construction activities. As such, construction-related impacts would be less than significant with the implementation of mitigation
Mitigation Measures
MM CUL-1 Prior to the initiation of construction activities, all construction personnel conducting ground disturbance at the site shall be provided Worker Environmental Awareness Program (WEAP) cultural resources “tailgate” training. The training shall include visual aids, a discussion of applicable laws and statutes relating to archaeological resources, types of resources that may be found within the project site, and procedures to be followed in the event such resources are encountered. The training shall be conducted by an Archaeologist who meets the Secretary of the Interior’s Professional Qualification Standards for archaeology.
In the event that buried archaeological resources are discovered during construction, operations shall stop within a 100-foot radius of the find and an Archaeologist who meets the Secretary of Interior’s Professional Qualification Standards for archaeology shall be consulted to determine whether the resource requires further study. The qualified Archaeologist shall make recommendations to the Lead Agency on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section15064.5 of the CEQA Guidelines. Potentially significant cultural resources consist of, but are not limited to, stone, bone, fossils, wood, or shell artifacts or features, including hearths, structural remains, or historic dumpsites. Any previously undiscovered resources found during construction within the project area shall be recorded on appropriate California Department of Parks and Recreation (DPR) forms and evaluated for significance in terms of CEQA criteria. If the resources are determined to be unique historic resources as defined under Section 15064.5 of the CEQA Guidelines, mitigation measures shall be identified by the monitor and recommended to the Lead Agency. Appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. The Lead
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Agency, along with other relevant or Tribal officials, shall be contacted upon the discovery of cultural resources to begin coordination on the disposition of the find(s).
Treatment of any significant cultural resources shall be undertaken with the approval of the Lead Agency. No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Upon coordination with the Lead Agency, any archaeological artifacts recovered shall be donated to an appropriate Tribal custodian or a qualified scientific institution where they would be afforded applicable cultural resources laws and guidelines.
MM CUL-2 Stop Construction Upon Encountering Human Remains In the event of the accidental discovery or recognition of any human remains, CEQA Guidelines Section 15064.5, Health and Safety Code Section 7050.5, and Public Resources Code Sections 5097.94 and Section 5097.98 shall be followed. If during the course of project construction, there is accidental discovery or recognition of any human remains, the following steps shall be taken:
1. There shall be no further excavation or disturbance of the site where human remains are discovered and/or any nearby area reasonably suspected to overlie adjacent human remains until the County Coroner is contacted to determine whether the remains are Native American and if an investigation of the cause of death is required. If the coroner determines the remains to be Native American, the coroner shall contact the Native American Heritage Commission (NAHC) within 24 hours, and the NAHC shall identify the person or persons it believes to be the Most Likely Descendant (MLD) of the deceased Native American. The MLD may make recommendations to the City or the person responsible for the excavation work within 48 hours, for means of treating or disposing of, with appropriate dignity, the human remains, and any associated grave goods as provided in Public Resource Code Section 5097.98.
2. Where the following conditions occur, the City or an authorized representative shall rebury the Native American human remains and associated grave goods with appropriate dignity either in accordance with the recommendations of the MLD or on the project site in a location not subject to further subsurface disturbance:
• The NAHC is unable to identify an MLD or the MLD failed to make a recommendation within 48 hours after being notified by the commission. • The descendant identified fails to make a recommendation. • The City or an authorized representative rejects the recommendation of the descendant, and mediation by the NAHC fails to provide measures acceptable to the City.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
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Significant
Impact
Less than
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Impact with
Mitigation
Incorporated
Less than
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Impact No Impact
2.6 Energy
Would the project:
a) Result in potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during project
construction or operation?
b) Conflict with or obstruct a State or local
plan for renewable energy or energy
efficiency?
Environmental Evaluation
Setting
Energy use, especially through fossil fuel consumption and combustion, relates directly to environmental quality since it can adversely affect air quality and generate greenhouse gas (GHG) emissions that contribute to climate change. Electrical power is generated through a variety of sources, including fossil fuel combustion, hydropower, wind, solar, biofuels, and others. Natural gas is widely used to heat buildings, prepare food in restaurants and residences, and fuel vehicles, among other uses. Fuel use for transportation is related to the fuel efficiency of cars, trucks, and public transportation; choice of different travel modes such as auto, carpool, and public transit; and miles traveled by these modes, and generally based on petroleum-based fuels such as diesel and gasoline.
Electric vehicles may not have any direct emissions but do have indirect emissions via the source of electricity generated to power the vehicle. Construction and routine operation and maintenance of transportation infrastructure also consume energy. Southern California Edison (SCE) provides electricity to the project site.
Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less than significant impact. A discussion of the proposed project’s energy use is presented below.
Energy calculations and supporting information are included as part of Appendix A of this Draft IS/MND.
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During construction, the proposed project would result in energy consumption through the combustion of fossil fuels in construction vehicles, worker commute vehicles, and construction equipment, and the use of electricity for temporary buildings, lighting, and other sources. No natural gas would be utilized as part of construction. Fossil fuels used for construction vehicles and other energy-consuming equipment would be used during removal of existing ground material, site preparation, grading, trenching, installation of EV charging stations and solar panel structures, and paving. The types of equipment could include gasoline- and diesel-powered construction and transportation equipment, including trucks, dozers, frontend loaders, forklifts, and cranes. Other equipment could include electrically driven equipment such as pumps and other tools.
Construction-related worker and hauling vehicle trips would consume an estimated 4,827 gallons of diesel and gasoline, combined, and construction-related equipment would consume an estimated 5,135 gallons of diesel and gasoline, combined, during project construction.
Limitations on idling of vehicles and equipment and requirements that equipment be properly maintained would result in fuel savings. California Code of Regulations Title 13, Sections 2449(d)(3) and 2485 limit idling from both on-road and off-road diesel-powered equipment and are enforced by the ARB. In addition, given the cost of fuel, contractors and owners have a strong financial incentive to avoid wasteful, inefficient, and unnecessary consumption of energy during construction.
Because of the temporary nature of construction and the financial incentives for contractors to implement energy-efficient practices, project construction activities would not result in wasteful, inefficient, and unnecessary consumption of energy. Therefore, the construction-related impact related to fuel and electricity consumption would be less than significant.
Operation
Operations for the proposed project would include vehicles accessing the proposed parking lot and EV charging stations. It is estimated that the annual fuel consumption by these vehicles would be approximately 79,073 gallons of gasoline, 7,255 gallons of diesel, 641 gallons of compressed natural gas, and 35,732 kilowatt hours (kWh) of electricity. The proposed project would contribute to a reduction in fossil fuel consumption and further the State’s energy goals by providing EV charging stations. For conservative analysis purposes, the vehicle fuel consumption estimates are based on County-average vehicle category percentages (e.g., gasoline versus electricity versus diesel versus compressed natural gas fueled vehicles) and do not account for the fact that a greater portion of vehicles would likely be electric vehicles given the proposed project’s nature including a portion of EV charging. In addition, the proposed solar panel structures would further offset energy consumption by offsetting some of the electricity usage. Electricity consumption of the parking lot for lighting purposes would be approximately 130,884 kilowatt hours per year (kWh/year).
The proposed project is not anticipated to result in wasteful, inefficient, or unnecessary electricity consumption as electricity would be used to power EV vehicles and provide lighting on-site, both are necessary uses of electricity. The proposed use of lighting on-site is necessary to illuminate the parking lot during operational hours and is consistent with standard safety, accessibility, and security requirements for publicly accessible facilities. The lighting system would be designed to comply with
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx the applicable provisions of the 2022 CBC (Title 24, Part 6 – California Energy Code), which mandates energy-efficient lighting technologies, controls, and performance thresholds. Therefore, the operational impacts related to energy consumption would be less than significant. b) Conflict with or obstruct a State or local plan for renewable energy or energy efficiency?
No impact. A discussion of the proposed project’s potential to conflict with or obstruct a State or local plan for renewable energy or energy efficiency is presented below.
Construction
As described above, construction activities would involve energy consumption in various forms and would be limited by California regulations such as California Code of Regulations Title 13, Sections 2449(d)(3) and 2485, which limit idling from both on-road and off-road diesel-powered equipment and are enforced by the ARB. The proposed project would be required to comply with these regulations.
There are no renewable energy standards applicable to construction activities for the proposed project.
Thus, it is anticipated that construction of the proposed project would not conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing energy use or increasing the use of renewable energy. Therefore, there would be no impact.
Operation
Additionally, the proposed project would consume electricity delivered by a California utility during operation. According to SB 100, California’s Renewables Portfolio Standard (RPS) requires that 100 percent of electricity retail sales in California be sourced with renewable energy sources by 2045.
SCE would provide the delivery of electricity to the proposed project through the existing grid. SB 32 mandates a Statewide GHG emissions reduction goal to 40 percent below 1990 levels by the year 2030. Further, Executive Order B-55-18 establishes a new statewide goal to achieve carbon neutrality by 2045 at the latest and maintain net negative emissions after 2045. Therefore, the proposed project would receive electricity from a utility company that meets California’s RPS requirements as well as the State requirements through 2045.
In addition, the proposed project would be designed and constructed in accordance with the applicable State’s Title 24 energy efficiency standards. Part 11, Chapter 4 and 5 of the State Title 24 energy efficiency standards establishes mandatory measures for nonresidential buildings, including material conservation and resource efficiency. The proposed project would be required to comply with these mandatory measures and would be constructed in accordance with City standards. Thus, the proposed project would not conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing energy use or increasing the use of renewable energy. There would be no impact.
Mitigation Measures
None required.
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Impact
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Impact No Impact
2.7 Geology and Soils
Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning
Map issued by the State Geologist for
the area or based on other substantial
evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure,
including liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss
of topsoil?
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable
as a result of the project, and potentially
result in on- or off-site landslide, lateral
spreading, subsidence, liquefaction or
collapse?
d) 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?
e) 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?
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f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
Environmental Evaluation
Setting
Seismically induced surface rupture is defined as the physical displacement of surface deposits in response to an earthquake’s seismic waves. Surface rupture is most likely along active faults and typically occurs during earthquakes of magnitude five or higher. Not all earthquakes result in surface rupture.
The Alquist-Priolo Earthquake Fault Zoning Act was passed in 1972 to mitigate the hazard of surface faulting to structures for human occupancy. The Act’s main purpose is to prevent the construction of buildings used for human occupancy on the surface trace of active faults. The Act requires the State Geologist to establish regulatory zones, known as Alquist-Priolo Earthquake Fault Zones, around the surface traces of active faults and to issue appropriate maps. If an active fault is found, a structure for human occupancy cannot be placed over the trace of the fault and must be set back from the fault (typically 50 feet).
Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist- Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
Less than significant impact. The project site is not located within an identified Alquist-Priolo Earthquake Fault Hazard Zone.29 According to the City General Plan Safety Element, there are no known fault traces located in the City. The closest fault is the San Joaquin Hills Fault, located approximately 3.6 miles south; additional faults include El Moderno, located approximately 5.7 miles to the north, and the Newport Inglewood Fault zone, located approximately 6 miles to the
29 California Department of Conservation (DOC) . 2025. Earthquake Zones of Required Investigation. Website:
https://maps.conservation.ca.gov/cgs/informationwarehouse/eqzapp/. Accessed February 6, 2025.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx southwest.30 Therefore, the probability of surface fault rupture occurring from an active fault is considered low. Additionally, the proposed project would be required to follow seismic design parameters based upon the 2022 CBC for the construction of the proposed solar shade structures, which would further reduce impacts related to rupture of a known earthquake fault. As such, impacts are considered less than significant.
ii) Strong seismic ground shaking?
Less than significant impact. Seismic ground shaking is influenced by the proximity of the site to an earthquake fault, the intensity of the seismic event, and the underlying soil composition. A geologic hazard likely to affect the project site is ground shaking as a result of movement along an active fault zone in the vicinity of the subject site. Although the site is not located on an earthquake fault, seismic ground shaking would occur with activity along active faults in the vicinity, as listed in question a) i), above. As the proposed project is a parking lot, it would not result in potential impacts related to seismic ground shaking; in the construction of the proposed solar shade structures, impacts would be less than significant with implementation of seismic design requirements of the 2022 CBC. iii) Seismic-related ground failure, including liquefaction? Less than significant impact. Liquefaction is a mode of ground failure that results from the generation of high water pressures during earthquake ground shaking, causing loss of shear strength.
Liquefaction is typically a hazard where loose sandy soils exist below groundwater. The California Geological Survey (CGS) has designated certain areas within Southern California as potential liquefaction hazard zones. These are areas considered at risk of liquefaction-related ground failure during a seismic event, based upon mapped surficial deposits and the presence of a relatively shallow water table.31
The project site is not located in a CGS Liquefaction Hazard Zone; the nearest CGS Liquefaction Hazard Zone is located approximately 0.2 mile south of the project site.32 This zone is defined as an area where historical occurrence of liquefaction or local geological, geotechnical, and groundwater conditions indicate a potential for permanent ground displacements such that mitigation would be required. According to the General Plan Safety Element, the areas of the City that are susceptible to liquefaction are in close proximity to the Santa Ana River. The project area is approximately 4 miles from the Santa Ana River.
The proposed project includes paving of an existing overflow gravel parking lot and associated access roadway. In addition, there would be a separate publicly accessible area in the southern portion of the
30 United States Geological Survey (USGS). 2025. U.S. Quaternary Faults. Website:
https://usgs.maps.arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9b0aadf88412fcf. Accessed February 6, 2025.
31 United States Geological Survey (USGS). 2025. U.S. What is liquefaction? Website: https://www.usgs.gov/faqs/what- liquefaction. Accessed February 6, 2025.
32 California Department of Conservation (DOC). 2025. Earthquake Zones of Required Investigation. Website:
https://maps.conservation.ca.gov/cgs/informationwarehouse/eqzapp/. Accessed February 6, 2025.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx project site containing a solar panel shade structure above the EV charging stations and associated EV charging stalls. Although the project site is outside of any areas susceptible to liquefaction, it is in proximity to such areas. The only proposed structures on the project site that may be affected by seismic events are the proposed solar shade structures, which, as discussed above, would be constructed consistent with seismic design requirements of the 2022 CBC. As such, impacts related to seismic-related ground failure, including liquefaction, would be less than significant. iv) Landslides?
No impact. The project is located on a relatively flat site that is surrounded by existing development and not located adjacent to any hills or steep slopes. According to the 2021 Recirculated PEIR, there is the potential for slope failure and landslides to occur near the banks of the Santa Ana River or Santiago Creek; however, these areas are approximately 4 miles west of the project site. As such, there no impacts would occur.33
b) Result in substantial soil erosion or the loss of topsoil? No impact. The project site is an existing gravel parking lot, which would be paved as part of the implementation of the proposed project. Accordingly, the proposed project would not result in the potential for soil erosion or loss of topsoil. As such, there would be no impact. c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Less than significant impact. The following analysis is based on the 2021 Recirculated PEIR, the General Plan Safety Element, and data from the CGS.34,35,36 • Liquefaction or Collapse: The project site is located outside of a liquefaction zone, with the closest being approximately 0.2 mile south. As discussed above, the proposed project would not include large structures that would pose a hazard in the event of a seismic event related to unstable soils. Additionally, the proposed solar shade structures would be constructed consistent with seismic design requirements of the 2022 CBC. Impacts would be less than significant.
• Lateral Spreading: As discussed in the response to liquefaction (see above) the site is not located in a liquefaction hazard area. The project site is in a relatively flat urbanized area and is not in the vicinity of slopes that would be susceptible to liquefaction (slope areas that have
33 City of Santa Ana. 2021. City of Santa Ana General Plan Update. 2021 Recirculated PEIR. October. 34 California Department of Conservation (DOC). 2025. California Geological Survey - Earthquake Zones of Required Investigation. Website: https://maps.conservation.ca.gov/cgs/informationwarehouse/eqzapp/. Accessed July 10, 2025. 35 City of Santa Ana. 2021. City of Santa Ana General Plan Update. 2021 Recirculated PEIR. October. 36 City of Santa Ana. 2022. City of Santa Ana General Plan – Safety Element. April.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx sufficient height, slope ratio, and underlying geologic conditions that can result in liquefaction.) Impacts would be less than significant.
• Landslide: The site is not located within a designated area where previous occurrence of landslide movement or local topographic, geological, geotechnical, and subsurface water conditions occurred. The site is flat and is not located near slopes that would be susceptible to landslides. Impacts from landslides would be less than significant. • Subsidence: According to the 2021 Recirculated PEIR, the areas of the City most susceptible to subsidence are the margins of the Santa Ana River and Santiago Creek; however, these areas are approximately 4 miles west of the project site. Further, the proposed project would not include large structures that would pose a hazard in the event of a seismic event related to unstable soils, and the proposed solar shade structures would be constructed consistent with seismic design requirements of the 2022 CBC. Impacts would be less than significant.
d) 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? Less than significant impact. The 2021 Recirculated PEIR notes that there is some potential for expansive soils throughout the City, especially in areas where clays and elastic silts may be present, including alluvial soils and weathered granitic and fine-grained sedimentary rocks.37 As described above, the proposed project would not include large structures that would pose a hazard in the event of a seismic event related to unstable soils and largely consists of repaving an existing parking lot.
Additionally, the proposed solar shade structures would be constructed consistent with seismic design requirements of the 2022 CBC. Impacts would be less than significant. e) 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?
No impact. The proposed project does not propose the use of septic tanks; therefore, no impacts to soils due to the use of septic systems would occur.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less than significant impact. The project site is located on the Tustin Plain, which is situated on younger alluvium deposits (Qya)38 comprised of a variety of unconsolidated and interbedded mud, sand, and gravel which were transported and deposited from repeated flooding of streams composed of headwaters in the Peninsular Ranges that are continuously transported gradually today and have a
37 City of Santa Ana. 2021. City of Santa Ana General Plan Update. 2021 Recirculated PEIR. October. 38 United States Department of the Interior Geological Survey. 1929. Geologic Map of the Northern Santa Ana Mountains, California.
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
56 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx depth ranging between zero to approximately 460 feet below the surface.39 Although younger alluvium deposits (Qya) have a low to moderate potential for containing significant paleontological resources due to their young age, the rock units are known to yield paleontological resources such as the remains of Pleistocene-age mammals deposited by streams from higher elevated areas, as well as marine vertebrates and several classes of marine invertebrates. As such, a paleontological records search was conducted by the Los Angeles County Museum of Natural History on February 16, 2025, to determine whether any fossil localities have been uncovered in the project region and related rock units to indicate whether ground-disturbing activities during the construction phases of the proposed project could yield significant paleontological resources. While the records search did not locate any significant fossil localities uncovered in the direct project area, five localities were identified in the same sedimentary deposits that may constitute the stratigraphy beneath the project site consisting of both marine and nonmarine vertebrates and marine invertebrates. In addition, an excavation project approximately 3.4 miles south of the project site yielded marine invertebrates and bone fragments of marine vertebrates within a sandy lens about three feet below the surface near Peters Canyon Wash.40 The proposed project largely consists of repaving an existing parking lot; however, excavation would occur around the footings of the proposed solar structure. Since the younger alluvium deposits (Qya) have contained significant paleontological resources, ground-disturbing activities may uncover and potentially damage a unique paleontological resource.
The proposed project would be subject to compliance with SC 2.5-1, which provides measures to implement if paleontological resources are encountered during construction activities such as temporarily halting construction and contacting a qualified Paleontologist to analyze the significance of the discovery and to develop a paleontological resources impact mitigation plan, if necessary, prior to resuming ground-disturbing activities. Since construction of the proposed project would be required to abide by SC 2.5-1, the proposed project would not destroy a unique paleontological resource and impacts would be less than significant.
Standard Conditions
SC 2.5-1 In the event that paleontological resources are encountered during grading and construction operations, all construction activities shall be temporarily halted or redirected to permit a qualified Paleontologist to assess the find for significance and, if necessary, develop a paleontological resources impact mitigation plan for the review and approval by the City prior to resuming excavation activities.
39 Schoellhamer, J.E, J.G. Vedder, R.F. Yerkes, and D.M. Kinney. 1981. Geology of the Northern Santa Ana Mountains, California.
40 Beth Padon. 2022. Final letter report for Archaeological and Paleontological Monitoring at Warner Avenue Storage Facility Phase 2 at 2960 Warner Ave, Irvine. August 19.
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Significant
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Less than
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2.8 Greenhouse Gas Emissions
Would the project:
a) Generate greenhouse gas emissions,
either directly or indirectly, that may have a
significant impact on the environment?
b) Conflict with any applicable plan, policy or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gases?
Environmental Evaluation
Setting
The City of Santa Ana and the project site are located within the SoCAB, which is under the jurisdiction of the SCAQMD. CEQA Guidelines Section 15064.4 gives lead agencies the discretion to assess GHG emissions of projects quantitatively or qualitatively, while also considering several other factors that may be used in the determination of significance of GHG emissions from a project, including the extent to which the project may increase or reduce GHG emissions, whether a project exceeds an applicable significance threshold, and the extent to which the project complies with regulations or requirements adopted to implement a plan for the reduction or mitigation of GHG emissions. However, CEQA Guidelines Section 15064.4 does not establish a threshold of significance.
CEQA Guidelines Section 15064.6 provides lead agencies the discretion to establish significance thresholds for their respective jurisdictions, and in establishing those thresholds, a lead agency may appropriately look to thresholds developed by other public agencies or suggested by other experts, if any threshold chosen is supported by substantial evidence. The City of Santa Ana has adopted a Climate Action Plan (CAP); however, the CAP does not contain a numerical significance threshold for assessing impacts related to GHG emissions. The SCAQMD formed a Working Group to provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA documents and was proposing to adopt a tiered approach for evaluating GHG emissions for development projects where SCAQMD is the lead agency. As of the last Working Group meeting held in September 2010, the Working Group identified a “bright-line” screening-level threshold of 3,000 MT
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
58 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx CO2e annually for all land use types.41,42 However, the proposed threshold was based on the State’s GHG emissions reduction goal identified in AB 32 for the year 2020, which has been outdated, and SCAQMD never adopted the threshold. Impacts of climate change are experienced on a global scale regardless of the location of GHG emission sources; therefore, a numerical significance threshold for individual development projects is speculative. Throughout the State, air districts are moving from numerical significance thresholds to qualitative significance thresholds that focus on project features to reduce GHG emissions or consistency with GHG reduction plans. For example, in the Bay Area Air Quality Management District’s (Bay Area Air District) 2022 CEQA Guidelines, the GHG thresholds of significance are either whether land use projects include certain project design elements related to buildings and transportation or whether the project is consistent with a local GHG reduction strategy that meets the criteria under CEQA Guidelines Section 15183.5(b). This is a major update to Bay Area Air District’s 2017 CEQA Guidelines, where a numerical significance threshold was required. To reduce GHG emissions impact, it is more effective for development projects to include project features that directly or indirectly reduce GHG emissions than to rely on a numerical significance threshold, which highly depends on the type and size of the development. Therefore, the significance of the proposed project’s potential impacts regarding GHG emissions and climate change will be assessed solely on its consistency with plans and policies adopted for the purposes of reducing GHG emissions and mitigating the effects of climate change.
Would the project:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less than significant impact. The proposed project would generate GHG emissions during construction and operation (e.g., mobile emissions, emission from the manufacturing and transport of building materials during construction, and emissions from generation of electricity for operations).
The proposed project’s construction and operational emissions are presented below for information purposes.
Construction GHG Emissions
During project construction, GHGs would be generated by construction activities, such as site clearing, operation of heavy-duty construction vehicles, materials and debris hauling, paving, and construction worker vehicle trips. These emissions would be considered short-term in duration.
Construction emissions were estimated using California Emissions Estimator Model (CalEEMod).
Construction assumptions used to estimate GHG emissions are consistent with those used to
41 South Coast Air Quality Management District (SCAQMD). 2008. Board Letter – Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans. Website:https://www.aqmd.gov/docs/default- source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/ghgboardsynopsis.pdf. Accessed July 25, 2025.
42 South Coast Air Quality Management District (SCAQMD). 2010. Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15. Websitehttps://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases- (ghg)-ceqa-significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf. Accessed July 25, 2025.
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 59
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx estimate air pollutant emissions, as described under Impact 2.3(b). The proposed project construction would generate 99 MT CO2e (Appendix A).
Operational GHG Emissions
Operational or long-term GHG emissions occur over the life of the proposed project. Sources for operational emissions include:
• Motor Vehicles: These emissions refer to tailpipe exhaust from the cars and trucks that would travel to and from the project site.
• Indirect Electricity: These emissions refer to those generated by off-site power plants to supply electricity required for the proposed project.
The proposed project is estimated to generate approximately 821 MT CO2e/year (Appendix A). For conservative analysis purposes, the vehicle fuel consumption estimates are based on County average vehicle category percentages (e.g., gasoline versus electricity versus diesel versus compressed natural gas) and do not account for the fact that greater portion of vehicles would likely be electric vehicles given the project’s nature including a portion of EV charging. In addition, the proposed solar panel structures would further offset energy consumption by offsetting some of the electricity usage.
Project Impacts
As discussed above, the significance of the proposed project’s potential impacts regarding GHG emissions and climate change will be assessed solely on its consistency with plans and policies adopted for the purposes of reducing GHG emissions and mitigating the effects of climate change.
The proposed project would continue the use of the existing overflow parking lot to serve the Santa Ana Zoo, maintaining its current function. However, under the proposed project, the lot would be improved with paving, marked parking spaces, and circulation lanes, enhancing both its appearance and operational efficiency. The use of this portion of the proposed project is unchanged and would not generate additional trips. The proposed EV charging component would directly support and advance General Plan Policies CN-1.12 and M-5.6 by expanding the City’s clean transportation infrastructure and promoting the use of low- and zero-emission vehicles. 43,44 By installing electric vehicle charging
stations within the parking lot, the proposed project provides essential infrastructure to encourage the adoption of alternative fuel vehicles, consistent with the City’s goals for sustainable transportation and climate resilience. Additionally, the proposed project aligns with the ARB’s 2022 Scoping Plan, which identifies widespread electrification of the transportation sector as a critical strategy to achieve the State’s GHG emission reduction targets. The proposed project contributes to regional and statewide efforts to reduce transportation-related emissions and supports the transition toward a cleaner, more
43 Policy CN-1.12 - Sustainable Infrastructure: Encourage the use of low or zero-emission vehicles, bicycles, nonmotorized vehicles, and car-sharing programs by supporting new and existing development that includes sustainable infrastructure and strategies such as vehicle charging stations, drop-off areas for ride sharing services, secure bicycle parking, and transportation demand management programs.
44 Policy M-5.6 - Clean Fuels and Vehicles: Encourage the use of alternative fuel vehicles and mobility technologies through the installation of supporting infrastructure.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
60 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx sustainable mobility system. Therefore, the proposed project would have a less than significant impact related to GHG emissions.
b) Conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less than significant impact. As explained above, the proposed project would further the City and State’s climate goals by providing the necessary EV charging infrastructure to support the electrification of the transportation sector. Therefore, the proposed project would not conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. This impact would be less than significant.
Mitigation Measures
None required.
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2.9 Hazards and Hazardous Materials
Would the project:
a) Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials?
b) Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous
materials into the environment?
c) Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school?
d) Be located on a site which is included on a
list of hazardous materials sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment?
e) For a project located within an airport land
use plan or, where such a plan has not
been adopted, within two miles of a public
airport or public use airport, would the
project result in a safety hazard or
excessive noise for people residing or
working in the project area?
f) Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
62 FCS
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g) Expose people or structures, either directly
or indirectly to a significant risk of loss,
injury or death involving wildland fires?
Environmental Evaluation
Setting
Information and analysis for the Hazards and Hazardous Materials impacts analysis are derived from the General Plan and online research.
The Department of Toxic Substance Control’s interface map, Envirostor, identified only one site within the project vicinity that possibly represented historically Recognized Environmental Conditions (HRECs) and Recognized Environmental Conditions (RECs); however, there is no environmental history on the project site itself. The identified site, COMPAK Foods (80000999), is located 0.4 mile northwest of the site, although the most recent information for the site is a document from 1999, which noted no major concerns.45 The site status has remained inactive since 2018.
Would the project:
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less than significant impact. The proposed project includes repaving of the existing overflow parking lot and associated access roadway.
During the paving of the project site, limited amounts of hazardous materials would be used, including standard construction materials and petroleum-based products (e.g., vehicle fuel and degreasers), typical of this type of action. The proposed project would be required to comply with all federal, State, and local standards and regulations while handling, storing, and disposing of these hazardous materials. Compliance with all federal, State, and local standards and regulations would ensure that project impacts related to the routine transport, use, and disposal of hazardous materials would be less than significant.
45 California Department of Toxic Substances Control (DTSC). 2025. EnviroStor. Website:
https://www.envirostor.dtsc.ca.gov/public/profile_report.asp?global_id=80000999. Accessed July 8, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 63
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx During the operation phase of the project, no hazardous or potentially hazardous materials would be routinely handled, stored, or dispensed on the project site. The proposed parking lot would not generate any hazardous materials. Therefore, long-term impacts associated with handling, storing, or disposal of hazardous materials would be less than significant. b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
No impact. As a parking lot that is continuing an existing parking lot use, the proposed project would not create a significant hazard to the public or environment. As such, no impact would occur. c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No impact. Saint Jeanne De Lestonnac Middle School is located approximately 0.25 mile east of the project site. As a parking lot, the proposed project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing school.
As such, no impact would occur.
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? No impact. Database searches via GeoTracker and Envirostor websites indicate that the project site is not identified on any lists compiled pursuant to Government Code Section 65962.5.46,47 Although one site, COMPAK Foods (80000999), located 0.4 mile northwest of the site, may represent HRECs and RECs in the vicinity of the project site, there is no environmental history on the project site itself.
And as discussed above, COMPAK Foods has remained an inactive status since 2018 and no major concerns are noted as currently being present. As such, no impact would occur.
46 California State Water Resources Control Board (State Water Board). 2025. GeoTracker. Website:
https://geotracker.ecointeractive.com/map/?CMD=runreport&myaddress=1801+E+Chestnut+Ave%2C+Santa+Ana%2C+ CA+92701. Accessed July 8, 2025.
47 California Department of Toxic Substances Control (DTSC). 2025. EnviroStor. Website:
https://www.envirostor.dtsc.ca.gov/public/profile_report.asp?global_id=80000999. Accessed July 8, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
64 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
No impact. The nearest airport is John Wayne Airport, located approximately 4.8 miles southwest of the project site. According to the John Wayne Airport Land Use Plan, the project site is not located within its planning area or influence area.48 Therefore, there would be no associated impact. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
No impact. The proposed project does not possess characteristics that would physically impair or otherwise interfere with emergency response as outlined in the Orange County Fire Authority (OCFA) Standards of Cover and Deployment Plan 2014 or evacuation in the project vicinity. The proposed project also does not possess characteristics that would interfere with the implementation of the Santa Ana Hazard Mitigation Plan. As such, no impact would occur.49 50 g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
No impact. The proposed project is located in an urban built-up area and is surrounded by urban development on all sides. According to the California Department of Forestry and Fire Prevention (CAL FIRE), Fire Hazard Severity Zones Map, the project site is not located within or near SRAs or lands classified as a Very High Fire Hazard Severity Zone.51 Therefore, the proposed project would not expose people or structures, either directly or indirectly to impacts involving wildland fires.
Mitigation Measures
None required.
48 Airport Land Use Commission (ALUC). 2008. Airport Land Use Commission. Website:
https://www.ocair.com/about/administration/airport-governance/commissions/airport-land-use-commission/. Accessed February 20, 2025.
49 Orange County Fire Authority (OCFA). 2014. OCFA Standards of Cover and Deployment Plan 2014. Website:
https://ocfa.org/Uploads/Orange%20County%20Fire%20Authority%20SOC_FINAL.pdf. Accessed February 20, 2025. 50 City of Santa Ana. 2022. Hazard Mitigation Plan. October 11. 51 California Department of Forestry and Fire Prevention (CAL FIRE). Fire Hazard Severity Zone Viewer. Website:
https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/. Accessed February 20, 2025.
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Significant
Impact
Less than
Significant
Impact with
Mitigation
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Less than
Significant
Impact No Impact
2.10 Hydrology and Water Quality
Would the project:
a) Violate any water quality standards or
waste discharge requirements or otherwise
substantially degrade surface or
groundwater quality?
b) Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the project
may impede sustainable groundwater
management of the basin?
c) Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would:
(i) result in substantial erosion or siltation
on- or off-site;
(ii) substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on- or off-
site;
(iii) create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems
or provide substantial additional
sources of polluted runoff; or
(iv) impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation?
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
66 FCS
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e) Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan?
Environmental Evaluation
Setting
Project-related impacts related to water quality can generally occur over several different periods:
• During the earthwork and construction phase, when the potential for erosion, siltation, and sedimentation would be the greatest;
• Following construction, before the establishment of ground cover, when the erosion potential may remain relatively high; and
• After project completion, when impacts related to sedimentation would decrease markedly but those associated with urban runoff would remain similar to existing conditions.
National Pollutant Discharge Elimination System
Under Section 402 of the Clean Water Act (CWA), the United States Environmental Protection Agency (EPA) has established regulations under the National Pollutant Discharge Elimination System (NPDES) program to control direct stormwater discharges from construction activities disturbing one acre or more of land. In California, the State Water Resources Control Board (State Water Board) administers the NPDES permitting program and is responsible for developing NPDES permitting requirements. The NPDES program regulates industrial pollutant discharges, which include construction activities. The State Water Board works in coordination with the Regional Water Quality Control Boards (RWQCBs) to preserve, protect, enhance, and restore water quality. The City is within the jurisdiction of the Santa Ana RWQCB.
Short-term Construction
Dischargers whose projects disturb 1 or more acres of soil (or whose projects disturb less than 1 acre but are part of a larger common plan of development that in total disturbs 1 or more acres), are required to obtain coverage under the General Permit for Discharges of Storm Water Associated with Construction Activity Construction General Permit Order 2009-0009-DWQ. Construction activity subject to this permit includes clearing, grading, and disturbances to the ground, such as stockpiling or excavation, but it does not include regular maintenance activities performed to restore the original line, grade, or capacity of the facility. To obtain coverage for discharges under the General
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Construction Permit, dischargers are required to electronically file the Permit Registration Documents, which include a Notice of Intent (NOI), a Storm Water Pollution Prevention Plan (SWPPP), and other compliance-related documents required by the General Permit, and to mail the appropriate permit fee to the State Water Board.
Long-term Operations
The Municipal Storm Water Permitting Program regulates stormwater discharges from Municipal Separate Storm Sewer Systems (MS4). Most of these permits are issued to a group of co-permittees encompassing an entire metropolitan area. The MS4 permits require the discharger to develop and implement a Stormwater Management Plan/Program with the goal of reducing the discharge of pollutants to the maximum extent practicable (MEP).52 The management programs specify what Best Management Practices (BMPs) will be used to address certain program areas. The program areas include public education and outreach, illicit discharge detection and elimination, construction and post-construction, and good housekeeping for municipal operations.
The Orange County Flood Control District, the County of Orange, and the City of Santa Ana, along with 51 other incorporated cities therein (Permittees), discharge pollutants from their MS4s.
Stormwater and non-stormwater flows enter and are conveyed through the MS4s and are discharged to surface water bodies of the Orange County Region. These discharges are regulated under countywide waste discharge requirements (contained in Order No. R8-2009-0030 [as amended by Order No. R8-2010-0062], Waste Discharge Requirements for the County of Orange, Orange County Flood Control District, and the incorporated cities within the Santa Ana Region Area-wide Urban Storm Water Runoff Orange County) which were approved on May 19, 2011. Order No. R8-2009- 0030, which serves as an NPDES permit, has expired but remains in effect until the Santa Ana RWQCB adopts a new permit.
The Permit requires the development and implementation of a program addressing stormwater pollution issues in development planning for private projects. The primary objectives of the municipal stormwater program requirements are to (1) effectively prohibit non-stormwater discharges; and (2) reduce the discharge of pollutants from stormwater conveyance systems to the MEP statutory standard. The County Model Water Quality Management Plan (WQMP) was developed as part of the municipal stormwater program to address stormwater pollution from new development and redevelopment by the private sector. This WQMP contains a list of the minimum required BMPs that must be employed for a designated project. The Permittees are required to adopt the Program’s requirements in their own water quality regulations. Developers must incorporate appropriate WQMP requirements into their project plans. Each Permittee must approve the project plan as part of their development plan approval process and prior to issuing grading permits for projects covered by the model WQMP requirements.
52 MEP is the performance standard specified in Section 402(p) of the Clean Water Act.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
68 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Would the project:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?
Less than significant impact. The project would be undertaken in accordance with the Orange County Drainage Area Management Plan (DAMP) (Santa Ana Municipal Code § 18-156, Control of Urban Runoff). Prior to issuance of a grading or building permit for the project, applicable City agencies would review the project plans and impose terms, conditions, and requirements on the project, as needed. Additionally, the proposed project would be subject to compliance with Chapter 19, Article IV—Water Pollution of the City Municipal Code, which addresses compliance with the 2003 DAMP. Overall, the proposed project would be subject to compliance with the Orange County DAMP, which requires the preparation of a WQMP that specifies the proposed BMPs. The impact would be less than significant.
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less than significant impact. According to the City of Santa Ana 2020 Urban Water Management Plan (UWMP), the City receives water from the Lower Santa Ana River groundwater basin, which is managed by the Orange County Water District, and from imported water from the Metropolitan Water District of Southern California (Metropolitan). Groundwater is pumped from 20 active wells throughout the City. As discussed under Impact 18(b), the City anticipates having adequate water supplies through year 2040. Because of its nature, the proposed project would not require the use of groundwater. Thus, project implementation would result in a less than significant impact to groundwater supplies
The project site is not located within a designated groundwater recharge basin or area identified as critical for groundwater replenishment. Accordingly, the proposed project would not interfere with groundwater recharge to a degree that would impede sustainable groundwater management of the basin. Additionally, the project site is currently used for parking and is heavily compacted due to daily vehicular use. As such it has a very low infiltration rate and does not represent a significant contribution to groundwater recharge. The proposed project would continue to route stormwater to existing drainage facilities and would comply with local stormwater management standards. For these reasons the proposed project would have a less than significant impact with respect to groundwater supplies and recharge.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 69
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx c) Substantially alter the existing drainage pattern of 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:
(i) result in substantial erosion or siltation on- or off-site; Less than significant impact. Project construction activities such as demolition, grading, paving, and site improvements may result in loose sediment, which can be transported by surface water or wind into nearby storm drains and waterways.
The proposed project would not alter the course of a stream or river as the Santa Ana River is located approximately 4 miles west of the project area. The proposed project would involve construction in an area that is currently covered by a gravel parking lot. As described above, the project site is currently used for parking and is heavily compacted due to daily vehicular use. The proposed project would not substantially alter the existing drainage pattern of the site in a manner that would result in substantial erosion or siltation on- or off-site. As such, impacts related to the alteration of existing drainage patterns in the area that could result in substantial erosion or siltation on- or off-site would be less than significant.
(ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site;
Less than significant impact. Project construction activities such as demolition, grading, paving, and site improvements may result in loose sediment that can be picked up by surface water or wind into nearby storm drains and into waterways. The proposed project would not alter the existing drainage pattern of the site and would not alter the path of a stream or river, as explained above. As such, impacts related to the alteration of existing drainage patterns in the area that could result in flooding on- or off-site would be less than significant. (iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
Less than significant impact. The proposed project would be served by the City’s stormwater drainage system. Construction activities such as demolition, grading, and paving could introduce additional pollutants and sediment into water runoff and flow into nearby storm drains. Continuous use and operation of the site would not create or contribute runoff water that would exceed the capacity of existing stormwater drains on the project site with implementation of these BMPs.
Therefore, impacts are considered less than significant. (iv) impede or redirect flood flows?
No impact. The project site is not located within a floodplain. The proposed project would not add additional impervious surfaces or alter the course of a stream or river. Therefore, there are no impacts related to impeding or redirecting flood flow would occur.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
70 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
No impact. A seiche is an earthquake or slide-induced wave that can be generated in an enclosed body of water. There is no enclosed body of water in the project vicinity. Therefore, the proposed project is not in a seiche zone.
The project site is surrounded by existing development and is not located within a floodplain or flood hazard zone. The nearest body of water is the Santa Ana River approximately 4 miles to the west.
A tsunami is a sea wave generated by an earthquake, landslide, volcanic eruption, or even a large meteor hitting the ocean. An event such as an earthquake creates a large displacement of water resulting in a rise or mounding at the ocean surface that moves away from this center as a sea wave.
Tsunamis generally affect coastal communities and low-lying (low-elevation) river valleys in the vicinity of the coast. Buildings closest to the ocean and near sea level are most at jeopardy. According to the CGS Orange County Tsunami Inundation Maps, the project site is not located within a tsunami inundation area.
53 Potential risk from mudflow (e.g., mudslide, debris flow) does not exist within the project area as steep slopes are not located in the project vicinity. Therefore, because the proposed project is not in a flood hazard, tsunami, or seiche zone, therefore project implementation would not risk release of pollutants from inundation by seiche, tsunami, or mudflow. No impact would occur. e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less than significant impact. The proposed project would not conflict with the County Watershed Program and the County’s NPDES program. Therefore, construction impacts related to water quality control plan or groundwater management plan consistency would be less than significant. In addition, Santa Ana Municipal Utility Services would provide potable water to the project site. As a result, the proposed project would not conflict with or obstruct a sustainable groundwater management plan.
Therefore, operational impacts related to obstructing implementation of a water quality control plan or groundwater management plan would be less than significant.
Mitigation Measures
None required.
53 California Department of Conservation (DOC). Orange County Tsunami Hazard Areas. Website:
https://www.conservation.ca.gov/cgs/tsunami/maps/orange. Accessed May 6, 2025.
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 71
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.11 Land Use and Planning
Would the project:
a) Physically divide an established
community?
b) 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?
Environmental Evaluation
Setting
According to the City’s General Plan Land Use Map, the project site is currently designated as OS (Exhibit 2).54 Permitted uses under the OS land use designation include recreational and green spaces, including parks, commercial open space; and public facilities such as water channels and rail infrastructure.
55 The proposed project would include a GPA change the land use designation from the existing OS to GC (Exhibit 3). The GC designation allows for retail and service establishments; recreational, cultural, and entertainment uses; business and professional offices; vocational schools; and parking facilities.
These uses are designed to be along arterial corridors and support the development and continued operation of recreational, cultural, entertainment, employment, and educational opportunities near established residential neighborhoods. This designation allows for a typical maximum height of 35 feet and a maximum intensity of 0.5 FAR for GC, 1.0 FAR for GC-1, and 1.5 FAR for GC-1.5. 56 The project site is currently zoned A1 by the City Zoning Ordinance (Exhibit 4), which permits farming (of crop agriculture and horticulture, grazing, small animal farms, and similar types), parks and recreational buildings of public or quasi-public use (golf courses, country clubs and other similar uses), accessory buildings, temporary sale stands for agricultural goods, and single-family residences
54 City of Santa Ana. 2022. Land Use Element. April 2022. Website: https://www.santa-ana.org/documents/general-plan- land-use-element/. Accessed May 6, 2025
55 Ibid.
56 Ibid.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
72 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx limited to a density of 1 dwelling unit per 6,000 square feet of lot area provided the lot has an area of
0.5 acre or less.57
The proposed project includes a rezone of the project site from A1 to Commercial (C2) (Exhibit 5).
The C2 zone district permits all uses of the C1 district as well as automotive garages, equipment rental yards, metal shops, wholesale establishments, truck, trailer, tractor and boat sales, research institutions, and more. The project proposes to develop the site as an automobile parking lot; parking structures are permitted under both C1 and C2 districts.58 Would the project:
a) Physically divide an established community?
No impact. The physical division of an established community typically refers to the construction of a linear feature, such as an interstate highway or railroad tracks, or removal of a means of access, such as a local bridge that would impact mobility within an existing community of between a community and outlying area. The project site is currently used as an overflow parking lot associated with the Santa Ana Zoo, and the proposed project would continue this use. Accordingly, the proposed project would not physically divide an established community and there would be no impact. b) 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?
Less than significant impact. The General Plan and Zoning Ordinance defines the permitted land uses and the corresponding development standards within the City. The project site is designated as OS by the General Plan and zoned as A1.
The proposed project seeks a GPA to change the land use from OS to GC and zoning from A1 to C2 to allow for the paving of the existing overflow gravel parking lot and associated access roadway. In addition, there would be a separate publicly accessible area in the southern portion of the project site containing a solar panel shade structure above the EV charging stations and associated EV charging stalls.
As described above, the GC designation and C2 zone each allow for parking facilities.
The proposed uses are consistent with current uses, the proposed land use and zoning designations.
Furthermore, the proposed project is compatible with the surrounding land uses because the project site would continue to act as an overflow parking facility serving the Santa Ana Zoo. As such, upon
57 City of Santa Ana. Municipal Code. Section 41-201. Website:
https://library.municode.com/ca/santa_ana/codes/code_of_ordinances?nodeId=PTIITHCO_CH41ZO_ARTIIIUSDIRESP_ DIV1A1GEAG_S41-201USPEA1DI. Accessed May 6, 2025.
58 City of Santa Ana. Municipal Code. Section 41-377. Website:
https://library.municode.com/ca/santa_ana/codes/code_of_ordinances?nodeId=PTIITHCO_CH41ZO_ARTIIIUSDIRESP_ DIV13C2GECO. Accessed May 6, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 73
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx approval of the proposed GPA and rezone, the proposed project would not result in a conflict with any existing land use plan, policy, or regulation. Therefore, impacts would be less than significant.
Mitigation Measures
None required.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
74 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.12 Mineral Resources
Would the project:
a) Result in the loss of availability of a known
mineral resource that would be of value to
the region and the residents of the State?
b) 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?
Environmental Evaluation
Setting
According to the 2021 Recirculated PEIR prepared for the General Plan, the majority of the City is zoned as MRZ-3, which shows that the significance of mineral deposits cannot be determined from the available data. A small area in the northeast corner of the City is mapped as MRZ-2, meaning significant mineral resources are known or very likely. This area is the southern tip of the Lower Santiago Creek Resource Area and the Santa Ana River Resource Area, 1.5 miles north of the City planning area. There is also a small area in the southeast portion of the City that is mapped MRZ-1, which means an area where no significant mineral resources are present or there is little likelihood that significant mineral resources are present.59
The 2021 Recirculated PEIR found that no mineral resource sectors and no active or inactive mines were in the entire City planning area. The nearest mineral resource sector is Sector J of the Lower Santiago Creek Resource Area located 1 mile northeast of the City.60 Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State?
59 City of Santa Ana. 2021. Final Recirculated Program Environmental Impact Report, Chapter 5.11 - Mineral Resources.
Website: https://storage.googleapis.com/proudcity/generalplansantaanaca/uploads/2023/12/Chapter-5.11-Mineral- Resources.pdf. Accessed February 12, 2025.
60 Ibid.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 75
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx No impact. The closest regionally significant resource MRZ-2 zones are in the southern tip of the Lower Santiago Creek Resource Area and the Santa Ana River Resource Area, in the northern part of City, about 3 miles north of the proposed project. The proposed project is located within a highly urbanized area which does not have any active mining operations. No impact would occur. b) 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? No impact. As stated above, 2021 Recirculated PEIR does not identify any mineral resource sectors within the City. The project site is zoned as A1 by the City Zoning Ordinance and the proposed project would rezone to C2, neither of which permit mining activities. The project site is not a site that contains mineral resources that are locally important to the area; thus, no impact would occur.
Mitigation Measures
None required.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
76 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.13 Noise
Would the project result in:
a) Generation of a substantial temporary or
permanent increase in ambient noise
levels in the vicinity of the project in excess
of standards established in the local
general plan or noise ordinance, or
applicable standards of other agencies?
b) Generation of excessive groundborne
vibration or groundborne noise levels?
c) For a project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, would the project
expose people residing or working in the
project area to excessive noise levels?
Setting
Characteristics of Noise and Vibration
Noise is defined as unwanted sound. Sound levels are usually measured and expressed in decibels (dB), with 0 dB corresponding roughly to the threshold of hearing. Most of the sounds that we hear in the environment do not consist of a single frequency, but rather a broad band of frequencies, with each frequency differing in sound level. The intensities of each frequency add together to generate a sound. Noise is typically generated by transportation, specific land uses, and ongoing human activity.
The standard unit of measurement of the loudness of sound is the dB. The 0 point on the dB scale is based on the lowest sound level that the healthy, unimpaired human ear can detect. Changes of 3 dB or less are only perceptible in laboratory environments. A change of 3 dB is the lowest change that can be perceptible to the human ear in outdoor environments. While a change of 5 A-weighted decibel (dBA) is considered to be the minimum readily perceptible change to the human ear in outdoor environments.
Since the human ear is not equally sensitive to sound at all frequencies, the dBA scale was derived to relate noise to the sensitivity of humans. It gives greater weight to the frequencies of sound to which
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 77
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx the human ear is most sensitive. The A-weighted sound level is the basis for a number of various sound level metrics, including the day/night sound level (Ldn) and the Community Noise Equivalent Level (CNEL), both of which represent how humans are more sensitive to sound at night. In addition, the equivalent continuous sound level (Leq) is the average sound energy of time-varying noise over a sample period and the Lmax is the maximum instantaneous noise level occurring over a sample period.
Groundborne vibration consists of rapidly fluctuating motion through a solid medium, specifically the ground, which has an average motion of zero and in which the motion’s amplitude can be described in terms of displacement, velocity, or acceleration. The effects of groundborne vibration typically only cause a nuisance to people, but in extreme cases, excessive groundborne vibration has the potential to cause structural damage to buildings. Although groundborne vibration can be felt outdoors, it is typically only an annoyance to people indoors where the associated effects of the shaking of a building can be notable. Groundborne noise is an effect of groundborne vibration and only exists indoors, since it is produced from noise radiated from the motion of the walls and floors of a room, and may also consist of the rattling of windows or dishes on shelves.
Several different methods are used to quantify vibration amplitude such as the maximum instantaneous peak in the vibrations velocity, which is known as the peak particle velocity (PPV) or the root mean square (rms) amplitude of the vibration velocity. Because of the typically small amplitudes of vibrations, vibration velocity is often expressed in decibels—denoted as LV—and is based on the reference quantity of 1 microinch per second. To distinguish vibration levels from noise levels, the unit is written as “VdB.”
Although groundborne vibration can be felt outdoors, it is typically only an annoyance to people indoors where the associated effects of the shaking of a building can be notable. When assessing annoyance from groundborne vibration, vibration is typically expressed as rms velocity in units of decibels of 1 microinch per second, with the unit written in VdB. Typically, developed areas are continuously affected by vibration velocities of 50 VdB or lower. Human perception to vibration starts at levels as low as 67 VdB. Annoyance due to vibration in residential settings starts at approximately 70 VdB.
Existing Conditions
The dominant noise sources in the project vicinity include traffic on local roadways, primarily from traffic on Santa Ana Freeway, which runs along the northern and eastern boundary of the project site.
Regulatory Framework
The project site is located in the City of Santa Ana and this analysis was performed using the City’s noise regulations. The City addresses noise in its policies and regulations of the Noise Element of its General Plan and in Article VI Noise Control of City’s Code of Ordinances. These policies and regulations are summarized below.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
78 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx General Plan
The City has established the following goals and implementation measures that are applicable to the proposed project and that are designed to prevent significant increases in noise levels in the community and to minimize the adverse effects of currently-existing noise sources:
Goal N-2 Noise Generators—Reduce the impact of known sources of noise and vibration.
Implementation Action 2.1—Alternative Paving: Evaluate the use of alternative paving materials that can reduce traffic noise, as feasible, depending on roadway conditions and cost-efficiency.
Code of Ordinances
The Municipal Code contains Noise Control Ordinances in Article VI of Chapter 18, Health and Sanitation. Sections of the Municipal Code that are applicable to the proposed project are summarized below.
Municipal Code Section 18-312 establishes exterior noise standards, limiting noise levels at receiving residential homes to 55 dBA during the daytime hours between 7:00 a.m. and 10:00 p.m. and 50 dBA during the nighttime hours between 10:00 p.m. and 7:00 a.m. Noise generation at any location within the City, when measured on any other residential property, must not exceed the following:
1. The above noise standard for a cumulative period of more than 30 minutes in any hour; or
2. The noise standard plus 5 dBA for a cumulative period of more than 15 minutes in any hour; or
3. The noise standard plus 10 dBA for a cumulative period of more than 5 minutes in any hour; or
4. The noise standard plus 15 dBA for a cumulative period of more than 1 minute in any hour; or
5. The noise standard plus 20 dBA for any period of time.
If the ambient noise level exceeds any of the first four noise limit categories above, the cumulative period applicable to that category shall be increased to reflect the ambient noise level. If the ambient noise level exceeds the fifth noise limit category, the maximum allowable noise level under that category shall be increased to reflect the maximum ambient noise level.
Section 18-313 establishes interior noise standards, limiting noise levels at receiving residential homes to 55 dBA during the daytime hours between 7:00 a.m. and 10:00 p.m., and 45 dBA during the nighttime hours between 10:00 p.m. and 7:00 a.m. Noise generation at any location within the City of Santa Ana, when measured within any other dwelling unit on any residential property, must not exceed the following:
1. The interior noise standard for a cumulative period of more than 5 minutes in any hour; or
2. The interior noise standard plus 5 dBA for a cumulative period of more than 1 minute in any hour; or
3. The interior noise standard plus 10 dBA for any period of time.
If the ambient noise level exceeds any of the first two noise limit categories above, the cumulative period applicable to that category shall be increased to reflect the ambient noise level. If the ambient
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 79
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx noise level exceeds the third noise limit category, the maximum allowable noise level under that category shall be increased to reflect the maximum ambient noise level.
Municipal Code Section 18-314 notes that noise sources associated with construction, repair, remodeling, or grading of any real property are exempt from the noise performance standards of the Municipal Code, provided said activities do not take place between the hours of 8:00 p.m. and 7:00 a.m. on weekdays, including Saturday, or any time on Sunday or a federal holiday.
Impact Analysis
Would the project result in:
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Short-term Construction Impacts
Less than significant. For purposes of this analysis, a significant impact would occur if construction activities would result in a substantial temporary increase in ambient noise levels in excess of the City’s established standards applicable to construction noise.
The Municipal Code establishes allowable hours and noise standards for construction activities and equipment. Construction activities, including the operation of any tools or equipment used in construction, are restricted between the hours of 7:00 a.m. and 8:00 p.m. Monday through Saturday; construction activities are prohibited on Sundays and federal holidays.
In addition, while the City has not established quantitative noise level thresholds for construction activities, this analysis uses the noise limits established by the Federal Transit Administration (FTA) to determine substantial temporary increase due to construction noise. The FTA identifies construction noise limits in the Transit Noise and Vibration Impact Assessment Manual. During daytime hours, a significant temporary increase would be an increase in excess of the average daily noise levels of 80 dBA Leq(8-hour) as measured at a receiving noise-sensitive land use.
Noise impacts from construction activities associated with the project would be a function of the noise generated by construction equipment, equipment location, sensitivity of nearby land uses, and the timing and duration of the construction activities.
Construction Traffic Noise
Haul truck trips, construction worker vehicle trips, and other construction-related trips would occur over the course of the proposed project’s construction. Haul truck trips typically have the greatest potential to result in substantial off-site noise increases along nearby roadways. The previously discussed Municipal Code noise limits have no applicability to road-legal trucks operating on public roads, but the following analysis nevertheless demonstrates that the proposed project’s haul trucks would have a less than significant impact on roadside noise levels in the vicinity of the project site.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
80 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Based on the traffic analysis prepared for the proposed project,61 the project site driveway currently generates an average of 246 two-way trips per day, with 24 trips during the AM peak-hour and 20 trips during the PM peak-hour. Based on the air quality modeling performed for this project, construction of the proposed project would generate a maximum of 119 total trips per day during any phase of project construction; 104 of these trips would be truck haul trips. This equates to less than 15 total trips per hour over the course of a standard construction workday. Typically, an approximate doubling of traffic volumes is required to cause 3 dBA noise increases, which are considered barely noticeable. The proposed project’s addition of less than 15 total trips per hour would not double existing hourly trips on roadway segments accessing the project site. As such, the proposed project’s maximum daily construction trips would not result in noticeable (much less substantial) noise increases along surrounding roadways and this impact would be less than significant.
Construction Equipment Noise
Construction is completed in discrete steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. These various sequential phases would change the character of the noise generated on the site and, therefore, the noise levels surrounding the site as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase. Typical operating cycles for these types of construction equipment may involve 1 or 2 minutes of full power operation followed by 3 or 4 minutes at lower power settings. Impact equipment such as pile drivers is not being used during construction of the proposed project.
The site preparation phase, which includes excavation and grading of the site, tends to generate the highest noise levels because the noisiest construction equipment is earthmoving equipment.
Earthmoving equipment includes excavating machinery and compacting equipment, such as bulldozers, draglines, backhoes, front loaders, roller compactors, scrapers, and graders. Typical operating cycles for these types of construction equipment may involve 1 or 2 minutes of full power operation followed by 3 or 4 minutes at lower power settings.
Construction of the project requires the use of graders, excavators, dozers, front end loaders, and backhoes. The maximum noise level generated by each bulldozer, excavator, and grader is assumed to be 85 dBA L
max at 50 feet from this equipment. A characteristic of sound is that each doubling of sound sources with equal strength increases a sound level by 3 dBA. Assuming that each piece of construction equipment operates at some distance from the other equipment, a reasonable worst- case combined noise level during this phase of construction would be 90 dBA Lmax at a distance of 50 feet from the acoustic center of a construction area. This would result in a reasonable worst-case hourly average of 86 dBA Leq.
The closest noise-sensitive receptors to the project site are single-family residences located south of the project site. The closest residence would be located approximately 160 feet from the acoustic
61 Urban Crossroads, Inc. 2025. Santa Ana Rezone Trip Generation Assessment. July 23.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 81
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx center of construction activity where multiple pieces of heavy construction equipment would potentially operate simultaneously at the project site. This was measured from the project boundary line to the residential property line to provide a conservative approach. At this distance, with minimal shielding from an existing concrete wall, worst-case construction noise levels could range up to approximately 72 dBA Lmax, intermittently, and could have an hourly average of up to 66 dBA Leq at the façade of the nearest single-family residential home. The calculation spreadsheet with detailed modeling assumptions is provided in Appendix D.
These reasonable worst-case construction noise levels would only occur periodically throughout the day as construction equipment operates along the nearest project boundaries. Additionally, these noise levels would drop off at a rate of 6 dBA per doubling of distance as the equipment moves over the project site. Therefore, the calculated reasonable worst-case 8-hour average noise level for construction assuming construction equipment moves over the project site would be 61 dBA Leq(8-hour) as measured at the nearest residential receptor.
These calculated conservative worst-case construction noise levels would not exceed the FTA’s threshold of 80 dBA Leq(8-hour) as measured at the nearest residential receptors. Furthermore, the proposed project will be required to comply with the City’s permissible hours for construction (7:00 a.m. and 8:00 p.m. Monday through Saturday; construction activities are prohibited on Sundays and federal holidays) which would ensure that construction noise would not result in a substantial increase in nighttime noise levels in the project vicinity. Therefore, the analysis demonstrates that the proposed project’s construction noise would not result in a substantial increase in excess of established standards and the impact would be less than significant.
Operational/Stationary Source Noise Impacts
Less than significant impact. A significant impact would occur if operational noise levels generated by stationary noise sources at the proposed project site would result in a substantial permanent increase in ambient noise levels in excess of any of the noise performance thresholds established in the City Municipal Code. The City has established an exterior noise limit of 55 dBA Leq hourly average during daytime hours and a noise limit of 50 dBA Leq hourly average during nighttime hours for receiving residential land uses. However, the City notes that if the existing ambient noise level exceeds these standards, the ambient noise level shall be considered the standard.
The proposed project would include parking lot activities, similar to the project site’s existing parking lot activities.
Parking Lot Activities
Typical parking lot activities include people conversing, doors shutting, and vehicles idling, which generate noise levels ranging from approximately 60 dBA to 70 dBA Lmax at 50 feet. These activities are expected to occur sporadically throughout the day as visitors and staff arrive and leave parking lot areas at the project site.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
82 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx The nearest noise-sensitive receptor is the single-family residential land use located south of the project site. The nearest façade of the single-family land use is located approximately 160 feet south of the nearest proposed parking areas. At this distance, with minimal shielding from an existing concrete wall, noise levels associated with daily parking lot activities would attenuate to approximately 47 dBA Leq. The calculation spreadsheet with detailed modeling assumptions is provided in Appendix D.
Noise levels resulting from parking lot activities at the proposed project site would not exceed the City’s exterior noise limit of 55 dBA Leq hourly average during daytime hours, and a noise limit of 50 dBA Leq hourly average during nighttime hours, for receiving residential land uses. Therefore, operational noise levels due to parking lot activities would not result in a substantial permanent increase in excess of any of the noise performance thresholds and would represent a less than significant impact.
Operational/Mobile Source Noise Impacts
Less than significant impact. A significant impact would occur if project-generated traffic would result in a substantial increase in ambient noise levels compared with those that would exist without the proposed project. Typically, a doubling of the Average Daily Traffic (ADT) hourly volumes on a roadway segment is required in order to result in an increase of 3 dBA in traffic noise levels, which, as discussed in the characteristics of noise discussion above, is the lowest change that can be perceptible to the human ear in outdoor environments. Therefore, for the purposes of this analysis, a doubling of the existing ADT volumes would result in a substantial permanent increase in traffic noise levels.
Based on the traffic analysis prepared for the proposed project by Urban Crossroads, 62 the proposed
project is anticipated to generate an addition of 876 trips per day with 37 AM peak-hour trips and 63 PM peak-hour trips. Because of the high level of residential development to the south of the project site, the existing ADT on this roadway segment would be substantially higher than the trips generated by this project. As such, these new net trips would not double existing average daily trips; therefore, the proposed project would not result in a substantial permanent increase in ambient noise levels from project-generated traffic trips and mobile source operational noise impacts would be less than significant.
b) Generation of excessive groundborne vibration or groundborne noise levels? Less than significant impact. A significant impact would occur if the proposed project would generate groundborne vibration or groundborne noise levels in excess of established standards. The City has not established requirements regarding construction vibration impacts; therefore, for the purposes of this analysis, the FTA guidelines for vibration impacts are used to determine potential significant construction and operational-related vibration impacts.63
62 Urban Crossroads, Inc. 2025. Santa Ana Rezone Trip Generation Assessment. July 23 63 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. September.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx This section analyzes both construction and operational groundborne vibration and noise impacts.
Groundborne vibrations consist of rapidly fluctuating motions within the ground that have an average motion of zero. Vibrating objects in contact with the ground radiate vibration waves through various soil and rock strata to the foundations of nearby buildings. Groundborne noise is generated when vibrating building components radiate sound, or noise, generated by groundborne vibration. In general, if groundborne vibration levels do not exceed levels considered to be perceptible, then groundborne noise levels would not be perceptible in most interior environments. Therefore, this analysis focuses on determining exceedances of groundborne vibration levels.
Short-term Construction Vibration Impacts
Of the variety of equipment that would be used during construction, small vibratory rollers would produce the greatest groundborne vibration levels. Impact equipment such as pile drivers would not be used during construction of this project. Large vibratory rollers produce groundborne vibration levels ranging up to 0.201 inch per second (in/sec) PPV at 25 feet from the operating equipment.
The nearest building structure to the project construction footprint is the cement block structure located east of the project site. This structure is located approximately 40 feet from the nearest construction footprint where small vibratory rollers would potentially operate. At this distance, groundborne vibration levels would range up to 0.099 in/sec PPV from operation of the types of equipment that would produce the highest vibration levels. This is below the FTA’s construction vibration damage criteria of 0.2 in/sec PPV for this type of structure, a building of nonengineered timber and masonry construction. As a result, construction of the proposed project would not expose nearby buildings to groundborne vibration levels in excess of their applicable FTA damage criteria and this impact would be less than significant.
Operational Vibration Impacts
Implementation of the project would not include any new permanent sources that would expose persons in the project vicinity to groundborne vibration levels that could be perceptible without instruments at any existing sensitive land use in the project vicinity. Additionally, there are no active sources of groundborne vibration in the project vicinity that would produce vibration levels that would be perceptible without instruments within the project site. Therefore, there would be no impact related to operational groundborne vibration.
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
No impact. The airport nearest to the project site is John Wayne International Airport, located approximately 4.28 miles south of the project site. While aircraft noise is occasionally audible at the project site, because of the distance from the airport and the orientation of runways and flight patterns, the project site does not lie within the established noise contours of John Wayne International Airport and is not close enough to any other airports to be affected by aviation noise.
Furthermore, the proposed project is not a noise-sensitive land use; it is a parking lot that would not
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
84 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx expose people residing or working in the project area to excessive noise levels. Therefore, implementation of the proposed project would not expose persons residing or working in the project vicinity to noise levels from airport activity that would exceed normally acceptable standards for the proposed land use development, and no impact would occur.
Mitigation Measures
None required.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.14 Population and Housing
Would the project:
a) Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)?
b) Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?
Environmental Evaluation
Setting
In May of 2025, the Anaheim-Santa Ana-Irvine Metropolitan Division held 1,697,900 jobs and a 3.6 percent unemployment rate, which is lower than the 4.9 percent unemployment rate for the State of California.64 The City had a population of 315,325 and 84,070 dwelling units, which gives a 3.82 persons per household rate.65
Would the project:
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
No impact. The proposed project is a parking lot and does not include any residential uses or large scale commercial or industrial operations. The proposed project would require a temporary construction workforce and would result in a nominal amount of permanent employment associated
64 California Employment Development Department (EDD). 2025. Anaheim-Santa Ana-Irvine Metropolitan Division.
Website: https://labormarketinfo.edd.ca.gov/geography/orange-county.html. Accessed July 8, 2025. 65 California Department of Finance. 2025. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020–2025. Website: https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for- cities-counties-and-the-state-2020-2025/. Accessed July 8, 2025.
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
86 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx with continued operation of the parking lot. Therefore, there would be no impact associated with growth inducement.
b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No impact. The project site does not contain existing housing that would be removed or affected by the proposed project. Therefore, there would be no impact on existing housing, necessitating the construction of replacement housing elsewhere.
Mitigation Measures
None required.
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Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporate
d
Less than
Significant
Impact No Impact
2.15 Public Services
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) Fire protection?
b) Police protection?
c) Schools?
d) Parks?
e) Other public facilities?
Environmental Evaluation
Setting
The OCFA provides both fire protection and emergency medical response services to the City. The OCFA operates 10 stations throughout the City and has access to an additional 76 stations in its service area.66 According to the City Public Safety Element, each station covers a service radius of approximately 1.5 miles throughout the City. The first fire unit response goal is less than 5 minutes.67 The closest fire station to the project site is OCFA Station No. 72, located approximately 0.32 mile north.
The Santa Ana Police Department (SAPD) provides police protection to the City. The SAPD is divided into two policing divisions, East and West, and these are further divided into four districts overseen by two district commanders. As of August 2019, 348 sworn positions and 250 professional staff positions serve the SAPD. The General Plan Public Safety Element indicates the City’s central police station is located in Civic Center approximately 2.7 miles northwest of the project site.
66 Orange County Fire Authority (OCFA). 2024. Fire Stations. Website: https://www.ocfa.org/AboutUs/FireStations.aspx.
Accessed February 5, 2025.
67 City of Santa Ana. 2010. Safety Element. Website: https://www.santa-ana.org/documents/public-safety-element/.
Accessed February 5, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
88 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx The Education Element of the General Plan indicates the City is served by four school districts: Santa Ana Unified School District (SAUSD), Garden Grove Unified School District (GGUSD), Tustin Unified School District (TUSD), and Orange Unified School District (OUSD). Public education in the City is primarily provided by SAUSD, whose facilities account for over 90 percent of school resources in the City.68
The City contains three libraries. The Main Library is located at the 26 Civic Center Plaza and the Newhope Library is located at 122 North Newhope Street.69 There is also a library located in the McFadden Institute of Technology School Center at 2701 Raitt Street which is associated with the public school system.
According to the General Plan Open Space, Parks, and Recreation Element, the City has about 400 acres of public park and recreation facilities distributed throughout the City. 70 Santa Ana has a population of 310,797 in 2024.71 This results in approximately 1.3 acres of open space for each 1,000 residents.
Would the project:
Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) and b) Fire protection and police protection?
Less than significant impact. As the continuation of an existing parking lot, the proposed project would not change the demand for fire or police protection or emergency services.
Furthermore, proposed project plans would be reviewed and approved by the Santa Ana Building and Safety Division and the OCFA, which would ensure adequate emergency access, fire hydrant availability, and compliance with all applicable codes and standards. Compliance with the above regulations, as well as the City’s permit process and City Municipal Code requirements would ensure that project implementation would not produce a significant impact on fire or police protection services.
68 City of Santa Ana. 2010. Education Element. Website: https://www.santa-ana.org/documents/general-plan-education- element/. Accessed February 5, 2025.
69 City of Santa Ana. 2024. Library Location and Hours. Website: https://www.santa-ana.org/library-locations-and-hours/.
Accessed February 5, 2025.
70 City of Santa Ana. 2024. Open Space, Parks, and Recreation Element. Website: https://www.santa- ana.org/documents/general-plan-open-space-parks-and-recreation-element/. Accessed February 5, 2025. 71 California Department of Finance. 2025. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020- 2024. Website: https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for-cities- counties-and-the-state-2020-2024/. Accessed February 5, 2025.
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 89
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx The Southeast District of the SAPD provides police services to the project area. The main SAPD building is located approximately 1.95 miles northwest from the project site at 60 Civic Center Plaza.
The proposed project would not require the construction of new SAPD facilities or expansion of existing facilities. Project implementation is not anticipated to increase SAPD response times to the project site or surrounding vicinity. In addition, the project plans would be reviewed and approved by the Santa Ana Building and Safety Division and SAPD, which would ensure that adequate safety and crime prevention measures are provided.
Compliance with the above regulations as well as the City’s discretionary review process would ensure that project implementation would result in a less than significant impact related to fire, police protection, and emergency services.
c), d), and e) Schools, Parks, and Other Public Facilities? No impact. The proposed project includes paving of the existing overflow gravel parking lot and associated access roadway. The proposed project does not include any residential uses and therefore would not increase the population or demand for schools, parks, or other facilities in the City.
According to the City’s General Plan Open Space, Parks and Recreation Element, Santa Ana has approximately 400 acres of public park and recreation facilities and the City strives to maintain approximately 2 acres of open space for each 1,000 residents. Santa Ana has population of 310,797 in 2024. Using the same 400 acres, this results in approximately 1.3 acres of open space for each 1,000 residents. Currently, the City operates 49 parks and recreational facilities within the City as well as playgrounds at several schools. As stated above, the proposed project would rezone and repave an existing overflow parking lot to also provide EV charging stations and solar panel shade structures.
The implementation of the proposed project would not increase population or demand for park services in the City; therefore, no impact would occur.
The City operates three libraries. The Main Library, which is located at 26 Civic Center Plaza, approximately 1.94 miles to the northwest of the project site, and the Newhope Library, which is located at 122 North Newhope Street, approximately 5.08 miles to the west of the project site. The McFadden Library located in the MIT School Center is located approximately 3.81 miles to the southwest at 2701 Raitt Street. The population would not increase because of the proposed project and, therefore, no impacts would occur.
Mitigation Measures
None required.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
90 FCS
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Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
2.16 Recreation
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial
physical deterioration of the facility would occur
or be accelerated?
b) Does the project include recreational facilities
or require the construction or expansion of
recreational facilities, which might have an
adverse physical effect on the environment?
Environmental Evaluation
Setting
According to the City’s General Plan Open Space, Parks and Recreation Element, Santa Ana has approximately 400 acres of public park and recreation facilities and strives to maintain approximately 2 acres of open space for each 1,000 residents. As stated above, in 2024 the ratio shifted to approximately 1.3 acres of open space for each 1,000 residents. Currently, the City operates 49 parks and recreational facilities as well as several school playgrounds.72 a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
No impact. The proposed project includes paving of an existing overflow gravel parking lot and associated access roadway. The proposed project is not residential in nature and would not result in an increase in residents. Therefore, implementation of the proposed project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. As such, no impacts would occur.
72 City of Santa Ana. 2024. Parks Locations and Information. Website: https://www.santa-ana.orgparks-locations-and- information/. Accessed February 5, 2025.
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx b) Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment?
No Impact. The proposed project includes paving of an existing overflow gravel parking lot and associated access roadway. The project would continue the existing operation of a parking lot and would not have growth inducing impacts. There are no plans to construct recreational facilities for the project; thus, no impacts would occur.
Mitigation Measures
None required.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
92 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.17 Transportation
Would the project:
a) Conflict with a program plan, ordinance or
policy of the circulation system, including
transit, roadway, bicycle and pedestrian
facilities?
b) Would the project conflict or be
inconsistent with CEQA Guidelines
Section 15064.3, subdivision (b)?
c) Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm equipment)?
d) Result in inadequate emergency access?
Environmental Evaluation
Setting
This section is in par based, in part, on the Trip Generation Assessment and the Vehicle Miles Traveled (VMT) Screening Evaluation prepared for the proposed project by Urban Crossroads, Inc., on July 23, 2025.7374 The Trip Generation Assessment and VMT Screening Evaluation are included in Appendix E.
Would the project:
a) Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Less than significant impact. According to the Trip Generation Assessment prepared for the proposed project, the existing use of the project site as an overflow parking lot for the Santa Ana Zoo currently produces an average of 246 two-way trips per day. Given that the proposed project would continue to operate as an overflow parking lot for the Santa Ana Zoo, trip generation would be
73 Urban Crossroads, Inc. 2025. Santa Ana Rezone Trip Generation Assessment. July 23. 74 Urban Crossroads, Inc. 2025. Santa Ana Rezone Vehicle Miles Traveled (VMT) Screening Evaluation. July 23.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx expected to remain the same with the exception of the additional 50 EV charging stations (outside of the overflow parking lot). According to the Trip Generation Assessment, the EV charging component of the proposed project would be anticipated to generate approximately 876 two-way trips per day, for a total of 1,122 two-way trips per day for the proposed project. Table 5 shows the trip generation for the proposed project.
Table 5: Project Trip Generation
Project Trip Generation Quantity Units
AM Peak-hour PM Peak-hour
Daily In Out Total In Out Total
Existing Overflow Parking 250 Stalls 20 4 24 3 17 20 246 External EV Charging
Station
50 Stalls 22 15 37 32 31 63 876
Proposed Project Total 42 19 61 35 48 83 1,122
The City’s Traffic Impact Study Guidelines does not have any specific trip-based criteria defining when a Level of Service (LOS) based traffic study should be prepared, although most agencies utilize a 50 or 100 peak-hour. However, once the trips associated with the new EV component are dispersed from the proposed project’s driveway, the proposed project would likely contribute fewer than 50 net new peak-hour trips to any off-site intersection. As such, additional analysis was not determined to be necessary.
The General Plan’s Mobility Element governs transportation planning within the City and lays out goals and policies managing developments affecting pedestrian bicycle, vehicle, and public transportation. The proposed project would preserve the existing use of the project site as an overflow parking lot for the Santa Ana Zoo and would not include changes to the existing pedestrian or bicycle routes adjacent to the project site, including the Class IV Bicycle Track on 1st Street. The proposed project would also not include changes to the roadways adjacent to the project site and, according to the Trip Generation Assessment summarized above, would not produce a significant amount of new peak-hour vehicle trips. As such, the proposed project would not conflict with the Mobility Element of the General Plan and impacts would be less than significant. b) Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
Less than significant impact. CEQA requires all lead agencies to adopt VMT as the measure for identifying transportation impacts for land use projects. To comply with CEQA, the City of Santa Ana adopted their City of Santa Ana Traffic Impact Study, referred to in the VMT Screening Evaluation as the City’s Guidelines. The City’s Guidelines list standardized screening methods for project-level VMT analysis that can be used to identify when a proposed land use development project is anticipated to result in a less than significant impact thereby eliminating the need to conduct a full VMT analysis.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
94 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx The City of Santa Ana VMT screening criteria, as described within the City Guidelines, are listed below:
• Projects which serve the local community and have the potential to reduce VMT, such as neighborhood K-12 schools and local-serving retail less than 50,000 square feet (Charter schools are excluded from this criteria).
• Projects that generate less than 110 net daily trips. • Projects located within Transit Priority Areas (TPAs).75 • Projects located in a low VMT generating TAZ (Transportation Analysis Zone).
As noted in Table 5, the proposed project would generate approximately 1,122 daily vehicle trips, which exceeds the City’s 110 daily vehicle trip threshold. Additionally, according to the VMT Screening Evaluation, the project site is not located within a TAZ that generates VMT at least 15 percent below the Orange County average. Therefore, the proposed project does not qualify for screening based on location within a low VMT area.
However, the proposed project meets the local-serving screening criteria, as it supports the continued use of overflow parking for the adjacent Santa Ana Zoo, a community-serving facility, and includes EV charging infrastructure intended for local residents and Zoo visitors. Additionally, the proposed project meets the Transit Priority Area (TPA) screening criteria, as it is located within a TPA mapped by the City’s Guidelines and is served by Orange County Transportation Authority (OCTA) Routes 64 and 83, which operate at 15-minute headways.
Because the proposed project satisfies the local-serving and TPA screening criteria, it is presumed to have a less than significant VMT impact, and no further VMT analysis is required. As such, impacts would be less than significant.
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less than significant impact. The proposed project would not include significant changes to the existing access point on East Main Street and would not include any hazardous design features. The access road servicing the current parking lot would be reconstructed as part of the proposed parking lot improvements and would be constructed to allow adequate circulation within the project site. As such, the proposed circulation improvements would be compatible with the proposed use. Impacts would be less than significant.
75 TPAs are defined as a 0.5-mile radius around an existing or planned major transit stop (e.g., Metrolink Station, Streetcar Station, etc.) or an existing stop along a high-quality transit corridor.
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx d) Result in inadequate emergency access?
Less than significant impact. The project would provide adequate emergency access in all phases of development. In addition, the project applicant would be required to comply with applicable Fire Department and Division of Building and Safety regulations relating to emergency access. Vehicular access for the proposed project will be provided via one unsignalized driveway on East Main Street.
The driveway would be modeled to ensure adequate emergency vehicle clearance; as such no significant impacts related to emergency vehicle access would occur.
Mitigation Measures
None required.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
96 FCS
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Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.18 Utilities and Service Systems
Would the project:
a) Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or stormwater
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects?
b) Have sufficient water supplies available to
serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years?
c) Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it has
adequate capacity to serve the project’s
projected demand in addition to the
provider’s existing commitments?
d) Generate solid waste in excess of State or
local standards, or in excess of the
capacity of local infrastructure, or
otherwise impair the attainment of solid
waste reduction goals?
e) Comply with federal, State, and local
management and reduction statutes and
regulations related to solid waste?
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Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Evaluation
Setting
Domestic water services in the City of Santa Ana are mainly provided by the Santa Ana Municipal Utility Services.76 Two small water companies serve a portion of the City through groundwater wells.
On average, the Santa Ana Water Department delivers 43 million gallons of water daily to some 345,000 residents. This service is provided through 20 ground water wells, seven import water connections, seven pump stations, 10 reservoirs, and 480 miles of transmission and distribution pipelines. Santa Ana is a member city of the Metropolitan, which receives water from the State Water Project emanating from sources of the Sierra Nevada Mountain range and the Colorado River via Lake Havasu.
According to the 2024 Santa Ana Water Quality Report, Santa Ana pumps approximately 85 percent of its water supply from 20 City-owned wells and purchases 15 percent of its supply from Metropolitan. The City’s wells can provide a maximum of 71 million gallons per day (mgd) and Metropolitan can provide 65 mgd. Approximately 390 miles of local sewer lines are maintained by the City, with sewer trunks owned and maintained by the Orange County Sanitation District (OC San).
The OC San’s Green Acres Project allows for the reuse of reclaimed wastewater for industrial and landscape irrigation uses. Waste Management provides solid waste collection services to the City.
Solid waste is transported by truck to the Sunset Environmental Service Transfer Station in Irvine and the CVT Transfer Station in Anaheim. The City adopted a Source Reduction and Recycling Element (SRRE) in 1992. This plan calls for recycling, composting, special waste disposal, and education and public information programs.
Would the project:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Less than significant impact. The proposed project would be served by existing electricity, natural gas, sewer, and water utility infrastructure on the project site. The proposed project includes paving of an existing overflow gravel parking lot and associated access roadway. In addition, there would be a separate publicly accessible area in the southern portion of the project site containing a solar panel shade structure above the EV charging stations and associated EV charging stalls. As such, the proposed project would not include uses that would increase demand for water, wastewater, electric power, or natural gas services. The proposed project would include the construction and operation of 50 EV chargers and parking lot lighting. However, as noted in Section 2.6, a portion of this electricity is anticipated to be offset by the operation of the proposed solar shade structures. Furthermore, the
76 City of Santa Ana. 2025. Services. Website: https://www.santa-ana.org/services/#/city/answers/municipal-utility-services/.
Accessed July 8, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
98 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx lighting system for the parking lot and the EV charging stalls would connect to existing electrical service and would not generate demand beyond the capacity of current utility providers. No trenching, grading, or utility upgrades are proposed that would trigger the need for expanded infrastructure or result in significant environmental effects. No upgrades to off-site electrical transmission systems or substations are proposed or anticipated.
The proposed project would disturb more than 1 acre of land and would be required to prepare a SWPPP that would address stormwater drainage during construction. Therefore, the proposed project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities.
Impacts would be less than significant.
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? No impact. The proposed project includes paving of an existing overflow gravel parking lot and associated access roadway. In addition, there would be a separate publicly accessible area in the southern portion of the project site containing a solar panel shade structure above the EV charging stations and associated EV charging stalls. The proposed project would not include any uses that require water. Therefore, the proposed project would not result in a change in water demand for the project site compared to its current use. As such, no impacts would occur. c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? No impact. The proposed project includes paving of the existing overflow gravel parking lot and associated access roadway. The proposed project does not include any uses that would generate demand for wastewater services. As such, no impacts would occur. d) 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?
Less than significant impact. The proposed project includes paving of an existing overflow gravel parking lot and associated access roadway. Solid waste may be produced during the construction phase of the proposed project. According to the 2021 Final Recirculated PEIR, the City is serviced by 17 landfills. The Frank R. Bowerman Sanitary landfill receives the most waste from the City and has an estimated closing year of 2053, with a maximum permitted throughput of 11,500 tons per day.77 The 2021 Final Recirculated PEIR determined that the buildout of the General Plan would not
77 California Department of Resources Recycling and Recovery (CalRecycle). 2025. SWIS Facility/Site Activity Details - Frank R. Bowerman Landfill (30-AB-0360). Website:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2767?siteID=2103. Accessed July 8, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 99
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx produce waste in excess of capacity of local solid waste infrastructure.78 As such, development included in the proposed project would not generate solid waste in excess of local solid waste infrastructure and impacts would be less than significant. e) Comply with federal, State, and local management and reduction statutes and regulations related to solid waste?
Less than significant impact. The proposed project includes paving of an existing overflow gravel parking lot and associated access roadway. In addition, there would be a separate publicly accessible area in the southern portion of the project site containing a solar panel shade structure above the EV charging stations and associated EV charging stalls. Solid waste may be produced during the construction phase of the proposed project. The proposed project is expected to be serviced by Republic Services. Participation in the City’s recycling programs during project construction and operation would ensure that the proposed project would not conflict with federal, State, and local statutes and regulations related to solid waste. Furthermore, the proposed project would meet or exceed standards set forth in CALGreen. As such, impacts would be less than significant.
Mitigation Measures
None required.
78 City of Santa Ana. 2021. Santa Ana General Plan Update Final Recirculated Program Environmental Impact Report.
October. Website: https://general-plan-santa-ana-ca.proudcity.com/other-resources/environmental-documents/. Accessed February 26, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
100 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
2.19 Wildfire
If located in or near State Responsibility Areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted
emergency response plan or emergency
evacuation plan?
b) Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and
thereby expose project occupants to,
pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of
associated infrastructure (such as roads,
fuel breaks, emergency water sources,
power lines or other utilities) that may
exacerbate fire risk or that may result in
temporary or ongoing impacts to the
environment?
d) Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of
runoff, post-fire slope instability, or
drainage changes?
Environmental Evaluation
Setting
Santa Ana is classified as an urban built-up city by the DOC, characterized by heavy development.
The closest Local Responsibility Very High Fire Hazard Severity Zone (FHSZ) is approximately 4.3 east, both near Peters Canyon.79
79 California Department of Forestry and Fire Prevention (CAL FIRE). Fire Hazard Severity Zone Viewer. Website:
https://experience.arcgis.com/experience/6a9cb66bb1824cd98756812af41292a0/. Accessed July 18, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 101
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Would the project:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
No impact. According to the CAL FIRE Fire Hazard Severity Zones Map, the project site is not located within or near a SRA or lands classified as a Very High FHSZ. 80 The proposed project does not possess characteristics that would physically impair or otherwise interfere with emergency response as outlined in the OCFA Standards of Cover and Deployment Plan 2014 or with emergency evacuations in the project vicinity.81 As such, no impact would occur. b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
No impact. According to the CAL FIRE Fire Hazard Severity Zones Map, the project site is not located within SRAs or lands classified as a Very High FHSZ. 82 The proposed project is located in an urban built-up area and is surrounded by existing development on all sides. Therefore, no impact would occur.
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
No Impact. According to the CAL FIRE Fire Hazard Severity Zones Map, the project site is not located within or near SRAs or lands classified as a Very High FHSZ. 83 The project would continue the existing use of the site as a parking lot and would not require installation or maintenance of infrastructure that may exacerbate fire risk.
The proposed project would include adequate emergency access via the direct exit onto East Main Street. The project site is an urban area surrounded by existing development and adjacent to the I-5 freeway. The project would not require emergency water sources because potable water is currently provided by the Santa Ana Water Department, which has adequate water supplies available to serve the proposed project and future development during normal, dry, and multiple dry years. Therefore, impacts related to infrastructure that exacerbates fire risk would be less than significant.
80 California Department of Forestry and Fire Prevention (CAL FIRE). Fire Hazard Severity Zone Viewer. Website:
https://experience.arcgis.com/experience/6a9cb66bb1824cd98756812af41292a0. Accessed July 18, 2025. 81 Orange County Fire Authority (OCFA). 2014. OCFA Standards of Cover and Deployment Plan 2014. Website:
https://ocfa.org/Uploads/Orange%20County%20Fire%20Authority%20SOC_FINAL.pdf. Accessed February 5, 2025. 82 California Department of Forestry and Fire Prevention (CAL FIRE). Fire Hazard Severity Zone Viewer. Website:
https://experience.arcgis.com/experience/6a9cb66bb1824cd98756812af41292a0. Accessed July 18, 2025. 83 Ibid.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
102 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
No Impact. According to the CAL FIRE Fire Hazard Severity Zones Map, the project site is not located within or near State responsibility areas or lands classified as a Very High Fire Hazard Severity Zone.84 Further, the project site is relatively flat and is surrounded by urban uses. As noted previously, the project site is located in Zone X: a zone that corresponds to areas outside of the 500- year flood. These conditions preclude the possibility of subjecting people or structures to significant risks related to post-fire slope instability and landslides. As such, there would be no impact.
Mitigation Measures
None required.
84 California Department of Forestry and Fire Prevention (CAL FIRE). Fire Hazard Severity Zone Viewer. Website:
https://experience.arcgis.com/experience/6a9cb66bb1824cd98756812af41292a0. Accessed July 18, 2025.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 103
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporate
d
Less than
Significant
Impact No Impact
2.20 Mandatory Findings of Significance
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species, cause
a fish or wildlife population to drop below
self-sustaining levels, threaten to
eliminate a plant or animal community,
substantially reduce the number or
restrict the range of a rare or endangered
plant or animal, or eliminate important
examples of the major periods of
California history or prehistory?
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively
considerable” means that the
incremental effects of a project are
considerable when viewed in connection
with the effects of past projects, the
effects of other current projects, and the
effects of probable future projects)?
c) Does the project have environmental
effects, which will cause substantial
adverse effects on human beings, either
directly or indirectly?
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
104 FCS
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx Environmental Evaluation
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?
Less than significant impact with mitigation incorporated. With implementation of MM BIO-1a, MM BIO-1b, MM CUL-1, and MM CUL-2, the proposed project would not substantially degrade the quality of the environment, substantially reduce the habitat of fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory.
MM BIO-1a and MM BIO-1b would protect the potential biological integrity of the site from impacts related to potential construction impacts. Additionally, MM CUL-1, and MM CUL-2 would reduce the proposed project’s impacts on unforeseen discovery of any important examples of major periods of California history or prehistory. As such, impacts would be less than significant. b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?
Less than significant impact with mitigation incorporated. The proposed project would result in potentially significant project-level impacts related to biological resources, cultural resources, geology and soils, hazards and hazardous materials, noise and transportation (design hazards). However, MM BIO-1a, MM BIO-1b, MM CUL-1, and MM CUL-2 would be implemented as part of the proposed project. The mitigation measures would, among other things, protect the potential biological integrity of the site from potential construction impacts, as well as reduce the proposed project’s impacts on previously unknown cultural or archaeological resources on the project site as well as any human remains. The mitigation measures would reduce each impact to a level of less than significant.
All other impacts of the proposed project were determined either to have no impact or to be less than significant without the need for mitigation. Cumulatively, the proposed project would not result in a significant contribution to cumulatively considerable cumulative impacts. Therefore, the proposed project, in conjunction with other future development projects, would not result in any cumulatively considerable impacts.
SANTA ANA REZONE PROJECT
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
FCS 105
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx c) Does the project have environmental effects, which will cause substantial adverse effects on human beings, either directly or indirectly? Less than significant impact with mitigation incorporated. The previous sections of this IS/MND reviewed the proposed project’s potential impacts related to biological resources, cultural resources, geology, hazards and hazardous materials, and noise, among other environmental issue areas. No significant public health or safety risks were identified. As concluded in these previous discussions, the proposed project would result in less than significant impacts with implementation of MM BIO-1a, MM BIO-1b, MM CUL-1, and MM CUL-2. Therefore, with implementation of the specified mitigation and standard BMPs and conditions of approval, the proposed project would cause less than significant adverse effects on human beings.
Mitigation Measures
MM BIO-1a, MM BIO-1b, MM CUL-1, and MM CUL-2.
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Santa Ana Rezone Project
Initial Study/Mitigated Negative Declaration
FCS 107
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx 3 - LIST OF PREPARERS
FirstCarbon Solutions
250 Commerce, Suite 210
Irvine, CA 92601
Phone: 714.508.4100
Project Director .............................................................................................................. Jason Brandman Senior Project Manager ....................................................................................................... Angela Wolfe Project Manager ....................................................................................................... Brittany Perez, MBA Legal Counsel ................................................................................................................. Megan Starr, JD Director of Noise and Air Quality .............................................................................. Phil Ault, LEED® AP Director of Cultural Resources ....................................................................... Dana DePietro, PhD, RPA Principal Biologist .............................................................................................................. Michael Tuma, Senior Archaeologist ......................................................................................................... Stefanie Griffin Environmental Services Analyst .......................................................................................... Henry Welch Environmental Services Analyst ........................................................................................ David Salloum Senior Managing Editor ........................................................................................................ Susie Harris Publications Manager ............................................................................................................. Alec Harris Technical Editor ...................................................................................................................... Sarah Vine Technical Document Manager ....................................................................................... Melissa Ramirez GIS/Graphics .............................................................................................................. Karlee McCracken GIS/Graphics ................................................................................................................ Sebastian Macias Urban Crossroads, Inc.—Technical Subconsultant
Suite 230
20341 Southwest Birch Street
Newport Beach, CA 92660
Phone: 949.660.1994
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