Santa Ana Rezone Project
Mitigation Monitoring and Reporting Program
City of Santa Ana, Orange County, California
PREPARED FOR:
City of Santa Ana
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, Senior Project Manager
August 14, 2025
•• • FCS
An ADEC Innovation
THIS PAGE INTENTIONALLY LEFT BLANK
Santa Ana Rezone Project
Mitigation Monitoring and Reporting Program
FCS 1
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/0327/03270047/MMRP/03270047 Santa Ana Rezone Project MMRP.docx
PREFACE
Section 21081.6 of the California Environmental Quality Act (CEQA) and CEQA Guidelines Section 15097 require a Lead Agency to adopt a Mitigation Monitoring and Reporting Program (MMRP) whenever it adopts a Mitigated Negative Declaration (MND) in conjunction with a project approval.
The purpose of the MMRP is to ensure compliance with the mitigation measures occurs during project implementation.
The IS/MND prepared for the proposed Santa Ana Rezone Project (proposed project) concluded that project implementation could result in potentially significant effects on the environment and mitigation measures were incorporated into the proposed project or are required as a condition of project approval that reduce these potential impacts to a less than significant level. This MMRP documents how and when the mitigation measures adopted by the Lead Agency will be implemented and confirms that potential environmental impacts are reduced to less than significant levels as identified in the IS/MND.
This document does not discuss those subjects that the environmental analysis demonstrates would result in less than significant impacts and for which no mitigation was proposed or necessary.
THIS PAGE INTENTIONALLY LEFT BLANK
SANTA ANA REZONE PROJECT
MITIGATION MONITORING AND REPORTING PROGRAM
FCS 3
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/0327/03270047/MMRP/03270047 Santa Ana Rezone Project MMRP.docx Table 1: Santa Ana Rezone Project Mitigation Monitoring and Reporting Program Mitigation Measures Method of Verification
Timing of
Verification
Responsible for
Verification
Verification of Completion
Date Initial
2.4 Biological Resources
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
Project applicant or
contractor shall submit
the biologist’s resume or
curriculum vitae (CV)
demonstrating relevant
education, certifications,
and field experience to
the City; project applicant
shall also submit a copy
of executed contract with
the biologist, showing
scope of work and
timeline to City
Confirm pre-construction
surveys for nesting birds
were conducted
Prior to ground-
disturbing or
vegetation-removing
construction
Prior to ground-
disturbing or
vegetation-removing
construction
City of Santa Ana
Planning and
Building Agency
City of Santa Ana
Planning and
Building Agency
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 Confirm the United
States Fish and Wildlife
Service and/or California
Department of Fish and
Wildlife have been
notified
During pre-
construction
surveys; during
construction
City of Santa Ana
Planning and
Building Agency
SANTA ANA REZONE PROJECT
MITIGATION MONITORING AND REPORTING PROGRAM
FCS 4
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/0327/03270047/MMRP/03270047 Santa Ana Rezone Project MMRP.docx Mitigation Measures Method of Verification
Timing of
Verification
Responsible for
Verification
Verification of Completion
Date Initial
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
Verify that construction
activities have been
restricted or a qualified
biologist has deemed
potential disturbance to
be minimal
2.5 Cultural Resources and Tribal Cultural
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 Submit evidence to City
that a WEAP training has
been conducted by an
Archaeologist who meets
the Secretary of the
Interior’s Professional
Qualification Standards
for archaeology
Document that
operations have stopped
in daily construction logs;
Project applicant or
contractor shall submit
the qualified
Archaeologist’s resume
or curriculum vitae (CV)
demonstrating relevant
Prior to the initiation
of construction
activities;
During construction;
Upon discovery of
resources;
City of Santa Ana
Planning and
Building Agency;
City of Santa Ana
Planning and
Building Agency;
SANTA ANA REZONE PROJECT
MITIGATION MONITORING AND REPORTING PROGRAM
FCS 5
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/0327/03270047/MMRP/03270047 Santa Ana Rezone Project MMRP.docx Mitigation Measures Method of Verification
Timing of
Verification
Responsible for
Verification
Verification of Completion
Date Initial
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 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 where they would be afforded applicable cultural resources laws and guidelines.
education, certifications,
and field experience to
the City; project applicant
shall also submit a copy
of executed contract with
the Archaeologist,
showing scope of work
and timeline to the City;
Verify that any previously
undiscovered resources
have been recorded on
appropriate DPR forms
and evaluated for
significance in terms of
CEQA criteria;
Inclusion of applicable
mitigation measures for
significant resources on
project plans;
Record that the Lead
Agency and other
relevant or Tribal officials
have been contacted to
coordinate on disposition
of the finds;
Upon discovery of
resources;
Upon discovery of
resources;
Upon discovery of
resources;
City of Santa Ana
Planning and
Building Agency
City of Santa Ana
Planning and
Building Agency
City of Santa Ana
Planning and
Building Agency
City of Santa Ana
Planning and
Building Agency
SANTA ANA REZONE PROJECT
MITIGATION MONITORING AND REPORTING PROGRAM
FCS 6
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/0327/03270047/MMRP/03270047 Santa Ana Rezone Project MMRP.docx Mitigation Measures Method of Verification
Timing of
Verification
Responsible for
Verification
Verification of Completion
Date Initial
Inclusion on project plans
that no further grading
shall occur until the Lead
Agency approves the
mitigation measures;
approval of mitigation
measures;
Verify that any artifacts
recovered are donated to
an appropriate Tribal
custodian or a qualified
scientific institution via
written documentation.
Upon discovery of
resources;
Upon discovery of
resources
City of Santa Ana
Planning and
Building Agency
City of Santa Ana
Planning and
Building Agency
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 Confirm construction
activities have ceased,
and the County Coroner
has been contacted as
recorded in daily
construction logs;
Confirm construction
activities have ceased,
and the County Coroner
has been contacted as
recorded in daily
construction logs;
During construction
During construction
City of Santa Ana
Planning and
Building Agency
City of Santa Ana
Planning and
Building Agency
SANTA ANA REZONE PROJECT
MITIGATION MONITORING AND REPORTING PROGRAM
FCS 7
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/0327/03270047/MMRP/03270047 Santa Ana Rezone Project MMRP.docx Mitigation Measures Method of Verification
Timing of
Verification
Responsible for
Verification
Verification of Completion
Date Initial
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.
If the remains are
determined to be of
Native American origin,
confirm the MLD and
NAHC have been
contacted via email;
Confirm contact with
MLD and compliance
with Public Resources
Section 5097.98 via
written or email
correspondence
During construction
During construction
City of Santa Ana
Planning and
Building Agency
City of Santa Ana
Planning and
Building Agency
2.7 Geology and Soils
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 Confirm construction
operations and activities
are halted and redirected
to a qualified
During grading and
construction
operations;
City of Santa Ana
Planning and
Building Agency
SANTA ANA REZONE PROJECT
MITIGATION MONITORING AND REPORTING PROGRAM
FCS 8
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/0327/03270047/MMRP/03270047 Santa Ana Rezone Project MMRP.docx Mitigation Measures Method of Verification
Timing of
Verification
Responsible for
Verification
Verification of Completion
Date Initial
significance and, if necessary, develop a paleontological resources impact mitigation plan for the review and approval by the City prior to resuming excavation activities.
paleontologist as
recorded in daily
construction log;
Review and approval of a
paleontological
resources impact
mitigation plan that is
incorporated into project
plans
Prior to resuming
excavation activities
City of Santa Ana
Planning and
Building Agency