Attachment 5 - Exhibit C of Resolution - CEQA Findings of Fact and Overriding Considerations — Thousand Oaks City Council, June 23, 2026

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 1

1.0 CEQA Findings of Fact and Overriding Considerations

1.1 Background
The California Environmental Quality Act (CEQA) requires that written findings be made by the lead agency in connection with certification of an environmental impact report (EIR) prior to approval of a project pursuant to Sections 15091 and 15093 of the CEQA Guidelines and Section 21081 of the Public Resources Code. This document provides the findings required by CEQA and the specific reasons for considering a project acceptable, even though a project may have significant impacts that are infeasible to mitigate to less than significant levels.

The lead agency is responsible for the adequacy and objectivit y of the EIR. The City of Thousand Oaks (City), as lead agency, has subjected the Draft EIR and Final EIR to the agency’s own review and analysis.

1.1.1 Project Summary
Project Location
The proposed Downtown Thousand Oaks Project (project) site is located in the eastern portion of the City, approximately 0.7-miles east of State Route 23 (SR-23) and the Ventura Freeway (Highway 101) interchange. The project site sits in a low-lying area of the City, along Thousand Oaks Boulevard, and is visible from nearby hillside trails to the north. The 17.68-acre project site is comprised of the following:
x A total of 16 complete parcels:
o Assessor’s Parcel Numbers (APNs): 670-0-182-060; 670-0-182-190; 670-0-182-210; 670-0-182-220; 670-0-182-230; 670-0-181-090; 670-0-181-110; 670-0-181-140; 670-0-181-235; 670-0-181-250; 670- 0-181-260; 670-0-181-270; 670-0-181-340; 670-0-181-350; 670-0-181-360; 671-0-240-450; and x Two partial parcels:
o APNs 671-0-240-460 and 670-0-182-050; and
x Three Public Right-of-Way segments: Thousand Oaks Boulevard (south side frontage improvements), Dallas Drive, and Oakwood Drive.

All parcels are presently owned by the City, except for APN 670-0-182-050, located at 1868 East Thousand Oaks Boulevard, which the City plans to acquire as part of the proposed project. APN 671-0-240-460 is presently owned by the City but is anticipated to be transferred to T.O. Lakes LLC pursuant to a recorded Development Agreement with the City, dated October 7, 2025. The project site is generally described as being located at 2100 East Thousand Oaks Boulevard, the address of the existing Civic Arts Plaza (CAP) complex.

A small portion of the project site, located at 1868 East Thousand Oaks Boulevard, is zoned as being within the Thousand Oaks Boulevard Specific Plan (SP-20) area and is designated as Commercial Neighborhood. No changes would be proposed to the zoning or land use designation of this parcel.

Satellite parking locations to be used during peak demand for downtown use and during construction for laydown storage include:

1. 265 South Rancho Road (existing parking areas); and

2. 110 South Conejo School Road.

It should also be noted that APNs 671-0-240-485 and 671-0-240-475 are part of the Civic Arts Plaza Specific Plan (SP- 11), which is being updated in its entirety. However, those parcels would not be affected by the Specific Plan ATTACHMENT #5
Exhibit C

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 2
Amendment, nor would those parcels be developed in any way as part of the proposed project. Future improvements on those parcels have already been contemplated by 2021-70424-MND.

Project Description
The project proposes, generally, to create a pedestrian-o riented downtown, including new construction facilitating mixed-use residential, a hotel, commerci al, office, and entertainment uses, partial reconstruction of the existing City Hall, development of public amenities such as a park plaza and outdoor amphitheatre, as well as supporting infrastructure such as new roadways, reconfigured utilities, and stormwater management. Temporary relocation of City staff and in-person public services to off-site location(s) within existing permitted office space within City boundaries is anticipated during reconstruction of the existing City Hall. Overall, the proposed project involves two components: (1) development of two mixed-use buildings, a hotel, a park, a restaurant, associated infrastructure, hardscape, landscaping, and site improvements (herein referenced as the “development component”), and (2) development of a bandshell and associated amphitheatre, the adaptive reuse of the existing CAP, and the temporary relocation of City staff and in-person public services associated with the existing City Hall to off-site location(s) within existing permitted office space within City boundaries (herein referenced as the “adaptive reuse, outdoor amphitheatre, and temporary relocation components”).

A General Plan Amendment would be required to change the existing land use designation of a 5.33-acre portion of the project site. The proposed project would use the parking fa cilities at 265 South Rancho Road and 110 South Conejo School Road for satellite parking during peak demand times. These locations would also be utilized for off-site construction laydown areas. Construction of the proposed project would occur in five phases: Phase I, Phase 2A, Phase 2B, Phase 2C, and Phase 3, and is anticipated to commence in 2027 and be completed by 2032.

The project would require the following approvals:
x General Plan Amendment;
x Specific Plan Amendment;
x Tentative Tract Map;
x Development Permit;
x Protected Tree Permit;
x Special Use Permit;
x Construction Permits, including building, grading, foundation, and associated permits; and x Certification of the Final Environmental Impact Report.

1.1.2 Project Objectives
The project objectives are outlined below:
x Provide a mixed-use community on the project site, located within the General Plan Downtown Subarea, of sufficient residential and commercial density to generate consistent activity, stimulate economic growth, and catalyze future private reinvestment in the surrounding area, thereby making best economic use of City-owned parcels and increasing tax revenues in support of City services. x Provide flexible public spaces for community and cultu ral events like farmers' markets, performances, and gatherings throughout the day, which position the project site as the premier destination for civic, cultural, and entertainment uses.
x Renovate and rehabilitate the existing City Hall administrative offices in a manner that facilitates improved City service delivery, public wayfinding, governmental transp arency, efficiency, and accessibility, and encourages public participation in civic life.

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x Provide market-rate affordable housing units to help alleviate the State’s housing crisis and support the City’s Regional Housing Needs Assessment (RHNA) goals.
x Provide a new hotel use of sufficient scale and density to support the performing arts venues on the site by creating overnight accommodation for visitors and/or performers, increasing daily visitors to support commercial businesses within the downtown area; and to maximize new transient occupancy tax revenues to the City.
x Incentivize alternative modes of travel such as rideshare, bicycling, and walking to, from, and within the site by consolidating parking, providing pedestrian-focused street design, and including active ground-floor commercial or entertainment uses in all structures.
x Position new development to screen the existing parking garage from view from Thousand Oaks Boulevard and neighboring properties.

1.1.3 Environmental Review Process
The Final EIR includes the Draft EIR (dat ed March 2026); revisions to informatio n presented in the Draft EIR; written comments received during the Draft EIR public review peri od; written response to those comments; an Errata; and a Mitigation Monitoring and Reporting Program (State Clearinghouse No. 2025090621) (herein referred to collectively as the Final EIR). In conformance with CEQA, including the CEQA Guidelines, the City conducted an extensive environmental review of the proposed project. The following is a summary of the City’s environmental review process:
x Pursuant to CEQA Guidelines Section 15082, as amended, the City circulated a Notice of Preparation (NOP) to public agencies and members of the public who had requested such notice for a 30-day period. The NOP was submitted to the State Clearinghouse and posted at the Ventura County Clerk’s office on September 11, 2025, with the 30-day review period beginning on September 11, 2025, and ending on October 13, 2025. Copies of t h e N O P w e r e m a d e a v a i l a b l e f o r p u b l i c r e v i e w a t t h e C i t y o f T h o u s a n d O a k s C o m m u n i t y D e v e l o p m e n t Department, Planning Division, and on the City’s website (https://toaks.gov/environmental). x A public scoping meeting was held on September 24, 2025, via Zoom. x A Draft EIR was prepared and distributed for a 45-day public review period beginning March 6, 2026, through April 21, 2026. A Notice of Availability (NOA) was announced in the local newspaper, submitted to the State Clearinghouse, sent to public agencies and interested persons and organizations, and posted at the Ventura County Clerk’s office on March 6, 2026. Copies of the Draft EIR were made available for public review at the City of Thousand Oaks Community Development Department, Planning Division, Newbury Park Library, Grant R. Brinhall Library, and on the City’s website.
x A Final EIR was prepared, which included comment letters received on the Draft EIR, responses to those comment letters, revisions to information presented in the Draft EIR, errata, and a Mitigation Monitoring and Reporting Program. The Final EIR was released for a 10-day agency review period prior to certification of the Final EIR. It should be noted that pursuant to CEQA Guidelines Section 15088(b), the City also provided written responses to commenting agencies at least 10 days prior to certification of the Final EIR. x Public hearings on the proposed project were held, including one Thousand Oaks Planning Commission (Planning Commission) hearing on May 18, 2026, and one Thousand Oaks City Council (City Council) hearing on June 23, 2026.

1.1.4 Record of Proceedings
For the purposes of CEQA and these Findings, the Record of Proceedings for the proposed project includes, but is not limited to, the following documents and other evidence:
x The NOP, NOA, and all other public notices issued by the City in conjunction with the proposed project; x The Draft EIR and the Final EIR for the proposed project;

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x All written comment letters submitted by agencies, organizations, or members of the public during the public review comment period of the Draft EIR;
x All responses to written comment letters submitted by agencies, organizations, or members of the public during the public review comment period on the Draft EIR; x All clarifications and modifications to the Draft EIR, all of which do not affect the overall conclusions of the environmental document and are not considered to result in any new or substantially greater significant impacts as compared to those identified in the Draft EIR; x All written and verbal public testimony presented during noticed public hearing(s) for the proposed project; x The Mitigation Monitoring and Reporting Program;
x The reports and technical memoranda included or referenced in the Final EIR; x All documents, studies, EIRs, or other materials incorporated by reference in the Draft EIR and Final EIR; x The Resolutions adopted by the Planning Commission and City Council in connection with the proposed project, and all documents incorporated by reference therein; x Matters of common knowledge to the City, including, but not limited to, federal, State, and local laws and regulations; and
x Any documents expressly cited in these Findings.

1.1.5 Custodian and Location of Records
The documents and other materials that constitute the record of proceedings for the City’s actions related to the Downtown Thousand Oaks Project are located at the City of Thousand Oaks Community Development Department, Planning Division, 2100 Thousand Oaks Boulevard, Thousand Oaks, CA 91362. The City’s Community Development Director is the custodian of the record of proceedings for the Final EIR. Copies of these documents, which constitute the record of proceedings, are, and at all relevant times have been and will be, available upon request at the offices of the City of Thousand Oaks Community Development Departme nt. This information is provided in compliance with Public Resources Code Section 21081.6(a)(2) and CEQA Guidelines Section 15091(e).

1.1.6 Independent Judgement and Finding
The City selected and retained CSG Consultants, Inc. (CSG) to prepare the EIR. CSG prepar ed the EIR under the City's supervision and direction. All findings set forth herein are ba sed on substantial evidence in the record, as indicated, with respect to each specific finding.

Finding:

The City has exercised independent judgment in accordance with Public Resources Code Section 21082.1(c)(3) in retaining its own environmental consultant and directing the consultant in the preparation of the EIR. The City has independently reviewed and analyzed the EIR and finds that the report reflects the City's independent judgment.

The City Council has considered all the evidence presented in its consideration of the proposed project and the EIR, including, but not limited to, the Final EIR, written and oral evidence presented at hearings on the project, and written evidence submitted to the City by individuals, organizations, agencies, and other entities. Based on such evidence, the City Council finds that with respect to each environmental impact identified in the review process, the impact is either:
(1) less than significant and would not require mitigation; (2) potentially significant but would be avoided or reduced to a less than significant level by implementation of identified mitigation measures; or (3) would be significant and not fully mitigatable but would be, to the extent feasible, lessened by implementation of identified mitigation measures.

The EIR also identifies certain significant adverse environmental effects of the proposed project that cannot be avoided or substantially lessened. Before approving this project, the City Council also adopts a Statement of Overriding Considerations, which finds, based on specific reasons and s ubstantial evidence in the record (as specified in Section

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 5

1.3, Statement of Overriding Considerations), that certain identified economic, social, or other benefits of the proposed project outweigh such unavoidable adverse environmental effects.

1.2 Findings and Facts
The City of Thousand Oaks, as lead agency, is required under CEQA to make written findings concerning each alternative and each significant environmental impact identified in the Draft EIR and Final EIR.

Specifically, regarding findings, CEQA Guidelines Section 15091 provides:
x No public agency shall approve or carry out a project fo r which an EIR has been certfied which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompan ied by a brief explanation of the rationale for each finding. The possible findings are:
o Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Final EIR. o Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.
o Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternative identified in the Final EIR.
x The findings required by subsection (a) shall be supported by substantial evidence in the record. x The findings in subdivision (a)(2) shall not be made if the agency making the findings has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The findings in subsection (a)(3) shall describe the specific reasons fo r rejecting identified mitigation measures and project alternatives.
x When making the findings required in subdivision (a)(1), the agency shall also adopt a program forreportin gon or monitoring the changes which it has either required in the project or made a condition of approval to avoid or substantially lessen significant environmental effect s. These measures must be fully enforceable through permit conditions, agreements, or other measures.
x The public agency shall specify the location and custodian of the documents or other material which constitute the record of the proceedings upon which its decision is based. x A statement pursuant to Section 15093 does not substitute for the findings required by this section.

The “changes or alterations” referred to in CEQA Guidelines Section 15091(a)(1) may include a wide variety of measures or actions as outlined in CEQA Guidelines Section 15370, including:
x Avoiding the impact altogether by not taking a certain action or parts of an action. x Minimizing impacts by limiting the degree or magnitude of the action and its implementation. x Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment. x Reducing or eliminating the impact over time by pres ervation and maintenance operations during the life of the action.
x Compensating for the impact by replacing or providing substitute resources or environments.

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1.2.1 Format
This section summarizes the significant environmental impacts of the proposed project, describes how these impacts are to be mitigated, and discusses various alternatives to the proposed project, which were developed in an effort to reduce the remaining significant environmental impacts.

The remainder of this section is divided into the following subsections:
x Section 1.2.2, Findings on Impacts Determined to be Less Than Significant: This section presents the impacts of the proposed project that were determined in the EIR to be less than significant without the addition of mitigation measures and presents the rationales for these determinations. x Section 1.2.3, Findings on Impacts Mitigated to Less Than Significant: This section presents potentially significant impacts of the proposed project that were identified in the Final EIR, the mitigation measures identified in the Mitigation Monitoring and Reporting Program that would reduce such impacts to less than significant levels, and the rationales for the findings. x Section 1.2.4, Findings on Significant Unavoidable Impacts: This section presents potentially significant impacts of the proposed project that were identified in the Final EIR, the mitigation measures identified in the Mitigation Monitoring and Reporting Program that would reduce impacts, the findings for significant unavoidable impacts, and the rationales for the findings. x Section 1.2.5, Findings on Recirculation: This section presents the reasoning as to why recirculation is not required under CEQA Guidelines Section 15088.5.
x Section 1.2.6, Findings on Project Alternatives: This section presents alternatives to the project and evaluates them in relation to the findings outlined in CEQA Guidelines Section 15091(a)(3), which allows a public agency to approve a project that would result in one or more significant environmental effects if the project alternatives are found to be infeasible because of specific economic, legal, social, technological, or other considerations. This section also identifies the environmentally superior alternative, any significant irreversible environmental changes that would occur should the proposed project be implemented, and growth-inducing impacts, pursuant to CEQA Guidelines Sections 15126(c) through 15126(e) and 15126.2.

1.2.2 Findings on Impacts Determined to be Less Than Significant Consistent with CEQA Guidelines Sections 15126.2 and 1512 8, the EIR focused its analysis on potentially significant impacts and limited discussion of other impacts for which it can be seen with certainty that there is no potential for significant adverse environmental effects. CEQA Guidelines Section 15091 does not require specific findings to address environmental effects that an EIR identifies as “no impact” or as a “less than significant impact.” Finding:

The City finds that, based on substantial evidence in the record, the following potential impacts, to the extent they result from the proposed project, would be less than significant, or would have no impact, and would not require mitigation.

Aesthetics/Light and Glare
The proposed project would not have a substantial adverse impact on a scenic vista; refer to pages 5.1-23 through 5.1- 45 of Draft EIR Section 5.1, Aesthetics/Light and Glare.

The proposed project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway; refer to pages 5.1-45 through 5.1-47 of Draft EIR Section 5.1.

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The proposed project, combined with other cumulative projects, would not result in significant impacts to scenic vistas; refer to pages 5.1-61 and 5.1-62 of Draft EIR Section 5.1.

The proposed project, combined with other cumulative projects, would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within an eligible State Scenic Highway; refer to page 5.1-62 of Draft EIR Section 5.1.

Air Quality
The proposed project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people; refer to pages 5.2-41 and 5.2-42 of Draft EIR Section 5.2, Air Quality.

The proposed project, combined with other cumulative projects, would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people; refer to pages 5.2-44 and 5.2-45 of Draft EIR Section 5.2.

Biological Resources
The proposed project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service; refer to page 5.3-16 of Draft EIR Section 5.3, Biological Resources.

The proposed project would not have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means; refer to pages 5.3-16 and 5.3-17 of Draft EIR Section 5.3.

The proposed project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migr atory wildlife corridors or impede the use of native wildlife nursery sites; refer to pages 5.3-17 and 5.3-18 of Draft EIR Section 5.3.

The proposed project would not conflict with the provisio ns of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan; refer to page 5.3- 21 of Draft EIR Section 5.3.

The proposed project, combined with other cumulative projects, would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service; refer to page 5.3-22 of Draft EIR Section 5.3.

The proposed project, combined with other cumulative projects, would not have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means; refer to page 5.3-23 of Draft EIR Section 5.3.

The proposed project, combined with other cumulative projects, would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites; refer to page 5.3-23 of Draft EIR Section 5.3.

The proposed project, combined with other cumulative projects, would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Pl an, or other approved local, regional, or state habitat conservation plan; refer to page 5.3-24 of Draft EIR Section 5.3.

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Cultural Resources
The proposed project would not disturb any human remains, including those interred outside of dedicated cemeteries; refer to pages 5.4-26 and 5.4-27 of Draft EIR Section 5.4, Cultural Resources.

The proposed project, combined with other cumulative projects, would not disturb any human remains, including those interred outside of dedicated cemeteries; refer to page 5.4-28 of Draft EIR Section 5.4.

Energy
The proposed project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; refer to pages 5.5-10 through

5.5-16 of Draft EIR Section 5.5, Energy.

The proposed project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency; refer to pages 5.5-16 through 5.5-18 of Draft EIR Section 5.5.

The proposed project, combined with other cumulative projects, would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; refer to pages 5.5-18 and 5.5-19 of Draft EIR Section 5.5.

The proposed project, combined with other cumulative projec ts, would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency; refer to pages 5.5-19 and 5.5-20 of Draft EIR Section 5.5.

Geology and Soils
The proposed project would not result in substantial soil er osion or the loss of topsoil; refer to pages 5.6-12 through

5.6-13 of Draft EIR Section 5.6, Geology and Soils.

The proposed project would not have soils incapable of adeq uately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater; refer to pages 5.6-15 and

5.6-16 of Draft EIR Section 5.6.

Greenhouse Gas Emissions
The proposed project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases; refer to pages 5.7-28 through 5.7-43 of Draft EIR Section 5.7, Greenhouse Gas Emissions.

Greenhouse gas emissions generated by the project, combined with other cumulative projects would not have a significant cumulative impact on global climate change or conflict with an applicable greenhouse gas reduction plan, policy or regulation; refer to page 5.7-43 of Draft EIR Section 5.7.

Hazards and Hazardous Materials
The proposed project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; refer to pages 5.8-23 and 5.8-24 of Draft EIR Section 5.8, Hazards and Hazardous Materials.

The proposed project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment; refer to pages 5.8-24 through 5.8-26 of Draft EIR Section 5.8.

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The proposed project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school; refer to page 5.8-26 of Draft EIR Section 5.8.

The proposed project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would not create a significant hazard to the public or the environment; refer to pages 5.8-26 and 5.8-27 of Draft EIR Section 5.8.

The proposed project is not located within 2 miles of a public airport or public use airport and would not result in a safety hazard or excessive noise for people residing or working in the project area; refer to pages 5.8-27 and 5.8-28 of Draft EIR Section 5.8.

The proposed project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; refer to pages 5.8-28 and 5.8-29 of Draft EIR Section 5.8.

The proposed project would not expose people or structures, ei ther directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires; refer to pages 5.8-29 through 5.8-31 of Draft EIR Section 5.8.

The proposed project, combined with other cumulative projects, would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; refer to page 5.8-32 of Draft EIR Section 5.8.

The proposed project, combined with other cumulative projects, would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment; refer to pages 5.8-32 and 5.8-33 of Draft EIR Section 5.8.

The proposed project, combined with other cumulative projects, would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school; refer to page 5.8-33 of Draft EIR Section 5.8.

The proposed project, combined with other cumulative projects, would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, could create a significant hazard to the public or the environment; refer to page 5.8-33 of Draft EIR Section 5.8.

The proposed project, combined with other cumulative projects, would not be located within an airport land use plan area or, where such a plan has not been adopted, within two miles of a public airport or public use airport, and could result in a safety hazard or excessive noise for people residi ng or working in the project area; refer to page 5.8-34 of Draft EIR Section 5.8.

The proposed project, combined with other cumulative projects, would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; refer to page 5.8-34 of Draft EIR Section 5.8.

The proposed project, combined with other cumulative projects, would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires; refer to page 5.8-35 of Draft EIR Section 5.8.

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Hydrology and Water Quality
The proposed project would not violate water quality stan dards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality; refer to pages 5.9-15 through 5.9-18 of Draft EIR Section 5.9, Hydrology and Water Quality.

The proposed project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin; refer to pages 5.9-18 through 5.9-21 of Draft EIR Section 5.9.

The proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site, or 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 impede or redirect flood flows; refer to pages 5.9-21 through 5.9-24 of Draft EIR Section 5.9.

The proposed project would not be located in a flood hazard, tsunami, or seiche zone, resulting in the risk of release of pollutants due to project inundation; refer to pages 5.9-24 and 5.9-25 of Draft EIR Section 5.9.

The proposed project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan; refer to pages 5.9-25 and 5.9-26 of Draft EIR Section 5.9.

The proposed project, combined with other cumulative projects, would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality; refer to pages 5.9-26 and

5.9-27 of Draft EIR Section 5.9.

The proposed project, combined with other cumulative projects, would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin; refer to page 5.9-27 of Draft EIR Section 5.9.

The proposed project, combined with other cumulative proj ects, would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in s ubstantial erosion or siltation on- or off-site, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site, or 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 impede or redirect flood flows; refer to pages 5.9-27 and

5.9-28 of Draft EIR Section 5.9.

The proposed project, combined with other cumulative projects, would not be located in a flood hazard, tsunami, or seiche zone, resulting in the risk of release of pollutants due to project inundation; refer to page 5.9-28 of Draft EIR Section 5.9.

The proposed project, combined with other cumulative projects, would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan; refer to pages 5.9-28 and 5.9-29 of Draft EIR Section 5.9.

Land Use and Planning
The proposed project would not physically divide an established community; refer to pages 5.10-6 and 5.10-7 of Draft EIR Section 5.10, Land Use and Planning.

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The proposed project would not cause a significant environm ental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect; refer to pages 5.10-7 through 5.10-19 of Draft EIR Section 5.10.

The proposed project, combined with other cumulative projects, would not physically divide an established community; refer to pages 5.10-19 and 5.10-20 of Draft EIR Section 5.10.

The proposed project, combined with other cumulative projects, would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulati on adopted for the purpose of avoiding or mitigating an environmental effect; refer to page 5.10-20 of Draft EIR Section 5.10.

Noise
The proposed project would not generate excessive groundborne vibration or groundborne noise levels; refer to pages

5.11-36 through 5.11-39 of Draft EIR Section 5.11, Noise.

The proposed project would not be 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, and would not expose people residing or working in the project area to excessive noise levels; refer to pages 5.11-39 and 5.11-40 of Draft EIR Section 5.11.

The proposed project, combined with other cumulative projects, would not generate 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; refer to pages 5.11-40 through 5.11-42 of Draft EIR Section 5.11.

The proposed project, combined with other cumulative projects, would not generate excessive groundborne vibration or groundborne noise levels; refer to page 5.11-42 of Draft EIR Section 5.11.

Population and Housing
The proposed project would not induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indire ctly (for example, through extension of roads or other infrastructure); refer to pages 5.12-10 through 5.12-19 of Draft EIR Section 5.12, Population and Housing.

The proposed project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere; refer to pages 5.12-19 and 5.12-20 of Draft EIR Section 5.12.

The proposed project, combined with other cumulative projects, would not induce substantial unplanned population growth in an area, either directly or indirectly; refer to pages 5.12-21 through 5.12-23 of Draft EIR Section 5.12.

The proposed project, combined with other cumulative projects, would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere; refer to page 5.12-23 of Draft EIR Section 5.12.

Public Services and Recreation
The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection; refer to pages 5.13-7 through 5.13-9 of Draft EIR Section 5.13, Public Services and Recreation.

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The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable servic e ratios, response times or other performance objectives for police protection; refer to pages 5.13-9 through 5.13-12 of Draft EIR Section 5.13.

The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for schools; refer to pages 5.13-12 and 5.13-13 of Draft EIR Section 5.13.

The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered park facilities, the co nstruction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks; refer to pages 5.13-13 and 5.13-14 of Draft EIR Section 5.13.

The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered public facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for other public facilities; refer to pages 5.13-14 and 5.13-15 of Draft EIR Section 5.13.

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, and would include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment; refer to pages 5.13-15 and 5.13-16 of Draft EIR Section 5.13.

The proposed project, combined with other cumulative projects, would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection; refer to pages 5.13-16 and 5.13-17 of Draft EIR Section 5.13.

The proposed project, combined with other cumulative projects, would not result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection; refer to page 5.13-17 of Draft EIR Section 5.13.

The proposed project, combined with other cumulative projects, would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to main tain acceptable service ratios, response times or other performance objectives for schools; refer to pages 5.13-17 and 5.13-18 of Draft EIR Section 5.13.

The proposed project, combined with other cumulative projects, would not result in substantial adverse physical impacts associated with the provision of new or physically altered park facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks; refer to page 5.13-18 of Draft EIR Section 5.13.

The proposed project, combined with other cumulative projects, would not result in substantial adverse physical impacts associated with the provision of new or physically altered public facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for other public facilities; refer to page 5.13-18 of Draft EIR Section 5.13.

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The proposed project, combined with other cumulative projects, 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, and include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment; refer to pages 5.13-18 and 5.13-19 of Draft EIR Section 5.13.

Transportation
The proposed project would not conflict with a program, plan , ordinance or policy addressing the circulation system including transit, roadway, bicycle and pedestrian facilities; refer to pages 5.14-13 and 5.14-14 of Draft EIR Section 5.14, Transportation.

The proposed project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); refer to pages 5.14-18 and 5.14-19 of Draft EIR Section 5.14.

The proposed project would not result in inadequate emergency access; refer to pages 5.14-19 and 5.14-20 of Draft EIR Section 5.14.

The proposed project, combined with other cumulative projects, would not conflict with a program, plan, ordinance or policy addressing the circulation system including transit, roadway, bicycle and pedestrian facilities; refer to page 5.14- 21 of Draft EIR Section 5.14.

The proposed project, combined with other cumulative projects, would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); refer to pages 5.14-21 and 5.14-22 of Draft EIR Section 5.14.

The proposed project, combined with other cumulative projects, would not result in inadequate emergency access; refer to page 5.14-22 of Draft EIR Section 5.14.

Utilities and Service Systems
The proposed project would have sufficient water supplies av ailable to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years, and would not require or result in the relocation or construction of new water treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects; refer to pages 5.16-19 through 5.16-21 of Draft EIR Section 5.16, Utilities and Service Systems.

The proposed project would result in a determination by the wastewater treatment provider, which serves or may serve the project, that it has adequate capacity to serve the project’s project demand in addition to the provider’s existing commitments, or result in the relocation or construction of new wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significan t environmental effects; refer to pages 5.16-22 and 5.16-23 of Draft EIR Section 5.16.

The proposed project would not result in the relocation or construction of new stormwater drainage facilities, the construction or relocation of which could cause significan t environmental effects; refer to pages 5.16-23 and 5.16-24 of Draft EIR Section 5.16.

The proposed project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainme nt of solid waste reduction goals and would comply with

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Federal, State, and local management and reduction statutes and regulations related to solid waste; refer to pages

5.16-24 through 5.16-26 of Draft EIR Section 5.16.

The proposed project would not result in the relocation or construction of new or expanded dry utility facilities, which could cause significant environmental effects; refer to pages 5.16-26 and 5.16-27 of Draft EIR Section 5.16.

The proposed project, combined with other cumulative projects, would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years, and would not require or result in the relocation or construction of new water treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects; refer to page 5.16-28 of Draft EIR Section 5.16.

The proposed project, combined with other cumulative projects, would result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s project demand in addition to the provider’s existing commitments, and would not result in the relocation or construction of new wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects; refer to pages 5.16-28 and 5.16-29 of Draft EIR Section 5.16.

The proposed project, combined with other cumulative projects, would not result in the relocation or construction of new stormwater drainage facilities, the construction or relocation of which could cause significant environmental effects; refer to page 5.16-29 of Draft EIR Section 5.16.

The proposed project, combined with other cumulative projects, would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals and could comply with Federal, State, and local management and reduction statutes and regulations related to solid waste; refer to page 5.16-29 of Draft EIR Section 5.16.

The proposed project, combined with other cumulative projects, would not result in the relocation or construction of new or expanded dry utility facilities, which could cause significant environmental effects; refer to page 5.16-30 of Draft EIR Section 5.16.

Wildfire
The proposed project would not substantially impair an adopted emergency response plan or emergency evacuation plan; refer to pages 5.17-15 through 5.17-37 of Draft EIR Section 5.17, Wildfire.

The proposed project would not, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire; refer to pages 5.17-37 through 5.17-39 of Draft EIR Section 5.17.

The proposed project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; refer to pages 5.17-39 through 5.17-41 of Draft EIR Section 5.17.

The proposed project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes; refer to pages 5.17-41 and

5.17-42 of Draft EIR Section 5.17.

The proposed project, combined with other cumulative projects, would not substantially impair an adopted emergency response plan or emergency evacuation plan; refer to pages 5.17-42 and 5.17-43 of Draft EIR Section 5.17.

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The proposed project, combined with other cumulative projects, would not, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire; refer to pages 5.17-43 and 5.17-44 of Draft EIR Section 5.17.

The proposed project, combined with other cumulative projects, would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or on going impacts to the environment; refer to page 5.17-44 of Draft EIR Section 5.17.

The proposed project, combined with other cumulative projects, would not expose people or structures to significant risks, including downslope or downstream flooding or landslid es, as a result of runoff, post-fire slope instability, or drainage changes; refer to pages 5.17-44 and 5.17-45 of Draft EIR Section 5.17.

1.2.3 Findings on Impacts Mitigated to Less Than Significant The following summary describes the potential impacts of the proposed project that, without mitigation, would result in significant adverse impacts. Upon implementation of the mitigation measures provided in the Draft EIR, these potential impacts would be reduced to less than significant levels.

Aesthetics/Light and Glare
Impact AES-3 The proposed project would not, in urbanized areas, conflict with applicable zoning and other regulations governing scenic quality.

Applicable Threshold of Significance: 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 points). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.1, Aesthetics/Light and Glare, and in particular, starting on page 5.1-47 and concluding on page 5.1-54 of the Draft EIR.

Project-Level Analysis
For purposes of CEQA, an “urbanized area” is defined by Public Resources Code Section 21071 as an incorporated city with a population of at least 100,000 persons (or a population of at least 100,000 persons when combined with not more than two contiguous incorporated cities), or an unincorporated area completely surrounded by incorporated cities and with a total population of more than 100,000 persons. The project site is located in the City of Thousand Oaks, which, as of 2025, has a population of approximately 122,468 persons. 1 Thus, for the purposes of this threshold, the project’s potential to conflict with applicable zoning and other regulations governing scenic quality is evaluated.

The project site is developed and surrounded by urbanized uses. Development of the proposed project would maintain the compatibility, character, and visual quality of the proj ect site within the Downtown Core by redeveloping and adaptively reusing the existing CAP (Building C1) and developi ng five new built features (i.e., a restaurant and park complex, a bandshell/amphitheatre, a hotel, and two mixed-use complexes, referred to as Buildings B1, B2, E1, E2, and E3, respectively).

1 State of California Department of Finance. E-1 Population and Housing Estimates for Cities, Counties, and the State – January 1, 2024 and 2025. May 2025. https://dof.ca.gov/media /docs/forecasting/Demographics/estimates-e1/E- 1_2025_InternetVersion.xlsx. Accessed December 15, 2025.

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Proposed improvements to Building C1 (the existing CAP) wo uld create a more vibrant, arts-focused civic space with improved public access and wayfinding. The reconstructed si ngle-level Kavli Terrace would be accessible via a grand staircase and a public elevator tower from East Main Street and the walkway from the existing parking garage. City Hall administrative offices would “bookend” other uses within the structure by being placed in east and west wings, and a public-facing City Services lobby would be introduced. The base of the building beneath Kavli Terrace would be transparent in design and utilize art-driven programs to activate the park edge, such as a multi-purpose performance venue, a public market/food hall, and art incubator spaces. These functions would be framed by a highly-glazed façade and anchored by scored precast concrete panels, giving the building a grounded, tactile base. On the ground level of the existing west wing, the existing northern façade would be removed and replaced with glass to open new views into the park and improve natural daylighting deep into the building. The maximum height of the newly constructed portions of Building C1, from the ground level, would be five stories, or 80 feet.

The proposed public park (Carpenter Park) would include architectural treatments that highlight the mature oak trees on-site. Raised decks built from sustainable wood, erected on platforms to protect tree roots, would provide event seating throughout the park, and an additional event platform wrapped around a large Valley oak would provide space for special events and community markets. Play areas would include a 750-square-foot interactive splash pad with a community-designed mosaic surface, as well as a 2,743-square-foot play structure with climbing zones and swings. The park would also feature a custom-designed artistic steel stru cture, offering shade and a focal point of the park visible from Thousand Oaks Boulevard; a 7,220-square-foot grassy area for picnics and events; and curved concrete and stone walls with integrated lighting, connecting the lawn to surrounding areas. Building B1 would feature a two-story restaurant with an enclosed patio overlooking the proposed splash pad. Materials would include concrete, steel, glass, wood, and tile. The design of Carpenter Park incorporates hardscape, water features, landscape vegetation, functional turf areas, shade structures, play structures, public art, and seating areas, and is designed to reflect the natural features and topography of the project site while preserving existing mature oak trees.

The amphitheatre would be located in the southeast corner of the project site, surrounded by mature oak and sycamore trees between Building C1 and The Lakes property. Art installations, interpretive exhibits, and interactive sculptures are proposed to enhance the space. Building B2 would be a single-story, 21-foot, 7-inch-tall structure, with an 877-square- foot covered unenclosed stage, and a 538-square-foot restroom, changing room, and storage area. The building materials are proposed to include concrete, steel, wood, and/or composite wood trellising, perforated metal, and other accent materials. The stage canopy is intended to function as a non-roofed trellis structure to allow natural light to permeate through. The frontage to the bandshell stage is planned to include a level 1,100-square-foot paved area and a 6,700-square-foot lawn, with terraced seat walls for elevated views. Around the lawn, 3,446 square feet of platform decking would be constructed near the existing valley oaks, providing a flexible area for tables, chairs, and benches under the many existing oak and sycamore trees. The area is intended to be flexible to accommodate events and performances, as well as function as a passive and reflective area among the existing mature trees on most days of the week.

Building E1 is a proposed 142-room hotel with a gross area of 122,873 square feet and a maximum height of seven stories, or 92 feet, located in the center of the project site. The northern elevation would serve as the hotel’s main entrance, where the façade of the first two stories would be glass; intermittent slabs of rammed earth and a long balcony on the second level would provide variation in the massing for these first two stories. Upper levels would appear more uniform, where hotel rooms would be separated by wood slat siding, and windows would be framed in dark bronze aluminum. The hotel’s ground-floor outdoor seating patio and seventh-floor rooftop bar would be visible from the northern elevation as well. The building’s height variations would be more apparent from the eastern and western elevations, where the façades would each feature limestone veneer, gray concrete, and colorful murals. The hotel’s second-level outdoor pool deck would be visible fr om the eastern elevation as well. All rooftop mechanical equipment would be screened. An exterior pedestrian stai rway would connect the hotel to Building C2 and to West

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Main Street. Overall, the hotel would be designed to harmonize the unique styles of the proposed structures surrounding it on-site, while appearing inviting to guests and viewers from East Thousand Oaks Boulevard.

Mixed-use Building E2 is proposed as a seven-story, 92-foo t, 6-inch tall, 161-unit building, totaling approximately 257,034 square feet. Due to the topography of the project site, the building would appear as a six-story building from the north along West Main Street. The building is generally designed as a modified U-shape built atop a podium parking deck, where the podium deck serves as a common outdoor courtyard level for residents, with views oriented toward the north to public areas along West Main Street. The top floor of Building E2 is set back to reduce apparent massing and create additional rooftop amenity spaces with views of the hillsides to the north. The orientation of the courtyard deck toward West Main Street also breaks the massing of the building into two primary components, each with unique but complementary architectural treatments. Primary exterior building materials would include plaster, vertical composite wood siding, masonry, decorative tile, and board form concrete in a lighter, more neutral color scheme.

Mixed-use Buildings E3 is a proposed four-story, 63-foot-tall, 79-unit mixed-use building totaling approximately 108,386 gross square feet. The above-grade structure is broken up into three distinct building elements (E3.1, E3.2, and E3.3), which would appear as separate buildings at the ground level but would be connected via a subterranean parking structure. Subcomponents E3.1 and E3.2 are designed to have a distinct material palette from part E3.3, which serves to provide variation along Thousand Oaks Boulevard. Parts E3.1 and E3.2 utilize neutral plaster tones, vertical wood siding, rich brick tones, decorative tile, and board-formed co ncrete. Part E3.3 utilizes lighter brick tones, horizontal wood siding, and painted vertical wood siding. The overall palette is a darker, richer tone than Building E2, with a more industrial look. Both buildings E2 and E3 rely in abrupt variations in materials and colors within the same façade as well as balconies to break up building massing.

Overall, the design of the proposed project would generally adhere to the architectural principles of Southern California regional modernism and mid-century modernism. The project intends to create a space that position’s the project site as the premier destination for civic, cultural, and entertainm ent uses; renovate and rehabilitate the existing City Hall administrative offices in a manner that facilitates public wa yfinding and encourages public participation in civic life; incentivize alternative modes of travel by providing pedestrian-focused street design and including active ground-floor commercial or entertainment uses in all structures; and position new development to screen the existing parking garage from view from Thousand Oaks Boulevard and neighboring properties. Across the project site, a cohesive plant palette of grasses, succulents, and native species would span 26,807 square feet. Additional trees would enhance the property’s natural features, while select street trees are chosen for their ability to thrive in the narrower spaces between buildings, and trees in planters and tree grates would create shade al ong pedestrian facilities. The pedestrian-oriented project would feature walkways, paseos, promenades, shade structures, public art, seat walls, benches, and public spaces for events such as farmers' markets. The proposed project’s lighting design and impacts related to light and glare are discussed in Impact Statement AES-4.

As an infill development project located within the City’s Downtown Core and generally within the boundaries of SP- 11, the project as proposed, including the proposed General Plan Amendment to change Subarea E from the Institutional land use designation to the Mixed-Use land use designation and to adjust language to allow an exception to the height maximum required in the Mixed-Use land use designation, the project would be required to comply with all applicable design standards, including standards in SP-1 1, as amended, and, where silent, standards in the City’s Design Guidelines, Thousand Oaks Municipal Code (Municipal Code) Title 9 regulations, and Freeway Corridor Design Guidelines. Additionally, as detailed in Draft EIR Table 5.1- 1, Consistency with the General Plan Policies that Govern Scenic Quality, and Draft EIR Table 5.1-2, Consistency wi th SP-11 Policies that Govern Scenic Quality, following implementation of the Tree Protection Plan that was prep ared for the project (Mitigation Measure [MM] BIO-4), the proposed project would be consistent with the City’s goals and policies governing scenic quality, and impacts in this regard would be less than significant with mitigation incorporated. Refer to Draft EIR Section 5.10, Land Use and Planning, and Draft EIR Appendix L, General Plan Consistency Checklists, for a comprehensive analysis of the applicable General Plan and SP-11 goals, policies, and development standards.

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Programmatic-Level Analysis
The analysis provided above for the Project-Level Analysis is also applicable to the adaptive reuse and outdoor amphitheatre components, as it applies to the project site as a whole. There are no unique considerations of the proposed development of the adaptive reuse and outdoor amphitheatre components that would cause different impacts than those already analyzed above. As such, impacts of the adaptive reuse and outdoor amphitheatre components would be less than significant with mitigation incorporated.

It is acknowledged that the temporary relocation component could introduce people to off-site locations (within existing permitted office space) within City boundaries that are located in areas developed with differing uses and visual character. However, this component would not result in new development or significant additional employees exceeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off-site. Therefore, the temporary relocation component would not result in impacts on scenic quality regulations and visual character.

MITIGATION MEASURES

PROJECT-LEVEL ANALYSIS
MM-BIO-4 Tree Protection Plan Compliance. The proposed project shall comply with the requirements of the Tree Protection Plan, prepared by Bancroft Construction Services, dated January 9, 2026, available in Appendix E.

PROGRAMMATIC-LEVEL ANALYSIS
MM-BIO-4 is also applicable to the adaptive reuse and outdoor amphitheatre components because development of these components would impact protected trees on-site.

Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measure above. Upon implementation of the required mitigation measure, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

Impact AES-4 The proposed project would not create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area.

Applicable Threshold of Significance: Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.1, Aesthetics/Light and Glare, and in particular, starting on page 5.1-55 and concluding on page 5.1-61 of the Draft EIR.

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Project-Level Analysis
A significant impact may occur if lighting, as part of the proposed project, exceeds adopted thresholds for light and glare, including exterior lighting or light spillover, or if the proposed project creates a substantial new source of light or glare.2
Construction
Project construction activities could involve temporary glare impacts as a result of construction equipment and materials. Pursuant to Municipal Code Section 8-11.01, Construction activities restricted to certain hours, construction of the proposed project would be limited to occur between the hours of 7:00 a.m. and 7:00 p.m. Monday through Saturday, and would be prohibited on Sundays unless a permit has been issued by the Public Works Director. Thus, as no construction activities would occur after 7:00 p.m. from Monday through Saturday, or on Sundays without a permit, short-term construction activities would cease at 7:00 p.m. This would apply to the parking and laydown storage activities that would occur at the temporary off-site locations as well. As such, lighting-related impacts would be less than significant.

Operations
Development of the proposed project would increase lighting at the project site compared to existing conditions. The project proposes a combination of accent, building-mounted, bollard, catenary, pedestrian, and area lighting to create a welcoming visual hierarchy that provides scale, enhances wayfinding, and improves safety. Additional exterior building accent lighting would be strategically implemented to better define space, celebrate the existing mature oak trees on-site, and highlight entry points. Specifically, lighting fixtures throughout the project site and building exterior would be light-emitting diode (LED) type with lumen packages selected to provide light levels in accordance with the recommendations of the Illuminating Engineering Society of North America (IESNA) handbook and recommended practice guides and local ordinances. Project site lightin g was selected in order to comply with outdoor lighting ordinances, align with light pollution reduction targets and Leadership in Energy and Environmental Design (LEED) credits, and meet International Dark-Sky Association (IDA) recommendations. Area and street lighting fixtures would have full cutoff capabilities, curfew-based controls would be programmed, and occupancy-based site lighting would be used where possible. The project would not include blinking , flashing, or lighting of unusually high intensity or brightness.

All lighting within the project site would comply with SP-11, as amended and, where silent, the Thousand Oaks Municipal Code regarding off-street parking lighting and signage, as well as the California Building Code (CBC), Chapter 10, Section 1008.2.3, regarding mandatory illumination requirements from a building’s exit to the public way, and the Green Building Code, Chapter 5, Section 106.8, regarding mandatory non-residential light pollution reduction requirements related to backlight, uplight, and glare. These standards specify that lighting should be downcast and shielded to reduce or avoid light trespass and glare while providing the minimum required lighting to meet safety standards.

Nevertheless, nighttime lighting has the potential to impact the adjacent residential properties to the east and west of the project site, particularly the development of the bandshell (Building B2) and amphitheatre on the east, and the development of the new mixed-use building (Building E2) on the west where no development currently exists.

Implementation of MM-AES-1 would require the project applicant to submit a photometric plan to the City for review and approval, demonstrating minimized light spillover to the adjacent residential uses in compliance with CALGreen.

Building materials would be consistent with the existing architectural style within the project vicinity and would utilize neutral tones and non-reflective materials, such as wo od, concrete, limestone, brick, and bronzed and darkened

2 Light spill is typically defined as the presence of unwanted light on properties adjacent to the property being illuminated. With respect to lighting, the degree of illumination may vary widely depending on the amount of light generated, height of the light source, presence of barriers or obstructions, type of light source, and weather conditions.

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aluminum. All metal components and glass would be of non-reflective finishes. Building windows and vehicles have the potential to create new sources of glare; however, thes e uses and glare sources would be consistent with the surrounding land uses, as the project site is currently developed and is entirely surrounded by existing urban development, including the adjacent Highway 101. Thus, neighboring uses would not be exposed to substantial daytime glare because of building materials. Impacts would be less than significant in this regard.

Overall, with compliance with applicable lighting regulati ons, visual consistency with surrounding development, and implementation of MM-AES-1, the project would not result in substantial new sources of light or glare on the project site that would adversely affect day or nighttime views in the area. Impacts would be less than significant with mitigation incorporated.

Shade and Shadow
As the project proposes five new structures ranging in height from 21 feet, 7 inches, to 92 feet, 6 inches, increased shade/shadow in the area has been considered. Although shading is common and expected in urban areas and is considered a beneficial feature when it provides cover from excess sunlight and heat, it can have an adverse impact if it interferes with sun-dependent activities, such as rout inely useable outdoor spaces associated with residential, recreational, or institutional land uses (e.g. schools, convalescent homes); commercial uses such as pedestrian-oriented outdoor spaces or restaurants with outdoor dining areas; nurseries; and existing solar collectors. These uses are considered sensitive because sunlight and shade are important for function, physical comfort, or commerce.

Shadow patterns of the proposed development onto adjacent uses were captured during the most extreme times of the year: during the winter solstice (December 21st), when th e sun is at its lowest point in the sky, and shadows are longest, and during the summer solstice (June 21st), when the sun is at its highest point, and shadows are shortest. The solstices refer to the two points on the Earth's path around the sun and are generally considered the beginning of winter and summer.

Given the placement of the sun in the winter months, the Winter Solstice is considered to have the largest shadows cast throughout the day. As depicted in Draft EIR Exhibit 5.1-14, Existing and Proposed Shade Analysis: December 21, the shadow conditions cast by the proposed development throughout the day at the height of the winter season would encroach on adjacent uses twice per day – on adjacent uses to the west at 8:00 a.m., and on adjacent uses to the north and east at 4:00 p.m. Shade sensitive uses to the west include existing single-family residences, shade-sensitive uses to the north include the Gardens of the World cultural garden, and shade-sensitive uses to the east include future multi- family residential uses at The Lakes. Based on Draft EIR Exhibit 5.1-14, the shadows cast on the residential uses to the west would be limited to a duration of less than four hours, as the shadow moves drastically northward by 12:00 p.m.

Additionally, the shadows cast on the Gardens of the World would be limited to a duration of less than one hour as the sun sets before 5:00 p.m. during the height of winter. Further, the shadows cast on The Lakes property would be limited to the roadway right-of-way. It is acknowledged that none of these off-site areas would experience increased shading in the summer months. As shown in Draft EIR Exhibit 5.1-15, Existing and Proposed Shade Analysis: June 21, the proposed project would not cast shadows on adjacent proper ties during the Summer Solstice. Overall, as the project would not result in prolonged increases in shade onto off-site sunlight-light sensitive uses compared to existing conditions, the shadows created by the project would be less than significant.

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It is acknowledged that the temporary relocation component could introduce people to off-site locations (within existing permitted office space) within City boundaries that have different types of lighting and sources of glare.

However, this component would not result in new development or significant additional employees exceeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off- site. Therefore, the temporary relocation component would not result in impacts on light and glare.

MITIGATION MEASURES

PROJECT-LEVEL ANALYSIS
MM-AES-1 Photometric Plan. The project Applicant shall retain a licen sed Professional Engineer to prepare a photometric plan, to be submitted to the City of Thousand Oaks, for review and approval prior to issuance of building permits demonstrating compliance with the California Green Building Standards Code, Title 24, Part 11 (CALGreen). With the exception of bollard and similar ground-level lighting, all exterior lighting shall be shielded and downcast to minimize light trespass and glare on adjacent residential properties while providing the minimum required lighting to meet safety standards.

PROGRAMMATIC-LEVEL ANALYSIS
MM-AES-1 is also applicable to the adaptive reuse and outdoor amphitheatre components because these components would also include lighting that could affect adjacent residential properties.

Cumulative Impacts The proposed project, combined with other cumulative projects, would not, in urbanized areas, conflict with applicable zoning and other regulations governing scenic quality.

CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” As outlined in Draft EIR Table 4-1, Cumulative Projects List, and illustrated on Draft EIR Exhibit 4-1, Cumulative Project Locations, cumulative projects are situated in the site vicinity.

Of the cumulative projects listed in Draft EIR Table 4-1, it is acknowledged that the residential project approved at 2200 East Thousand Oaks Boulevard (Project No. 4) and the mixed-use development proposed at 1850 East Thousand Oaks Boulevard (Project No. 18) would be within the viewshed of the project site and would therefore be the most likely to share in cumulative impacts with the proposed project. Project No. 4 would have an average height of 75 feet and would be located adjacent to the eastern boundary of the project site. Project No. 18 would have a maximum height of five stories and would be located adjacent to the western boundary of the project site, fronting East Thousand Oaks Boulevard.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.1, Aesthetics/Light and Glare, and in particular, on page 5.1-63 of the Draft EIR.

As discussed, the low-lying areas of the City are largely built out. As a result, the cumulative development projects identified in Draft EIR Table 4-1 primarily consist of infill development and would result in development similar to what

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 22
currently exists in the surrounding vicinity. The City would review site-specific development proposals against the City’s Design Guidelines and Municipal Code requirements for all future projects requiring discretionary approval. This regulatory procedure would ensure cumulative development is reviewed against the qualities and characteristics expected of development and major renovations in the City. Cumulative development would be reviewed against applicable Thousand Oaks General Plan 2045 (General Plan ) policies and site development standards included in Municipal Code Title 9 that aid in governing scenic quality.

As indicated under Impact Statement AES-3, the proposed project would be consistent with applicable zoning and regulations related to scenic quality following implementation of the Tree Protection Plan (MM-BIO-4). Further, project implementation would be subject to general consistency with the City’s Design Guidelines and compliance with Municipal Code Development Standards (e.g., lot size, setback, density, open space, signage, lighting, and landscaping requirements). Overall, these standards would serve to improve the scenic quality within the project site. Thus, cumulative impacts to scenic quality regulations would be less than significant with mitigation incorporated, and the proposed project would not significantly contribute to cumulative impacts in this regard.

MITIGATION MEASURES

PROGRAMMATIC-LEVEL ANALYSIS
MM-BIO-4 is also applicable to the adaptive reuse and outdoor amphitheatre components because development of these components would impact protected trees on-site.

Cumulative Impacts The proposed project, combined with other cumulative projects, would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.1, Aesthetics/Light and Glare, and in particular, on pages 5.1-63 and 5.1-64 of the Draft EIR.

Development of cumulative projects could result in increased lighting in the City. However, Project Nos. 4 and 18, in addition to the proposed project, include infill development and as such, would not introduce light and glare on sites where no sources currently exist. All future development would be required to comply with the exterior lighting requirements included in Municipal Code Sections 9-4.2405(b), and 9-4.2308(b) as well as be generally consistent with the City’s Design Guidelines. Future development would be required to shield or recess exterior lighting so that direct glare and reflections are contained within the boundaries of the parcel and must be directed downward and away from adjoining properties and public rights-of-way. Blinking, flashing, or lighting of unusually high intensity or brightness is not allowed under the Municipal Code. In addition, the City would review the future cumulative development proposals

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against the City’s Design Guidelines, as applicable, for al l future projects requiring discretionary approval. This regulatory procedure would review building materials to ensure neighboring uses are not exposed to substantial daytime glare or excessive lighting.

As discussed under Impact Statement AES-4, short-term and long-term impacts to lighting would be reduced to less than significant levels following conformance with Municipal Code Sections 9-4.1109, 9-4.2405(b), and 9-4.2308(b), as well as be generally cons istent with the City’s Design Guidelines. Addi tionally, the California Energy Code’s Lighting Requirements would apply. Further, per MM-AES-1, the project Applicant would submit a photometric plan to the City for review and approval, demonstrating minimized light spillo ver to the adjacent residential uses in compliance with CALGreen. Thus, with adherence to MM-AES-1, the project wo uld not cumulatively contribute to the creation of substantial new lighting or glare and impacts in this regard would be less than significant.

MITIGATION MEASURES

Air Quality
Impact AQ-3 The proposed project would not expose sensitive receptors to substantial pollutant concentrations.

Applicable Threshold of Significance: Expose sensitive receptors to substantial pollutant concentrations? Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.2, Air Quality, and in particular, starting on page 5.2-36 and concluding on page 5.2-41 of the Draft EIR.

Project-Level Analysis
Localized Air Quality Health Impacts
Construction
The proposed project’s construction activities would involve the operation of diesel-powered equipment, which would emit diesel particulate matter (DPM). In 1998, the California Air Resources Board (CARB) identified diesel exhaust as a toxic air contaminant (TAC). Cancer health risks associated with exposure to diesel exhaust is typically associated with

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 24
chronic exposure, in which a 30-year exposure period often is assumed. Construction of the proposed project would be required to comply with California Code of Regulations, Titl e 13, Sections 2449(d)(2) and 2485, to minimize the idling time of construction equipment either by shutting it off when not in use or by reducing the idling time to no more than five minutes. Implementation of these regulations would reduce the amount of DPM emissions from the construction of the proposed project. However, to further evaluate potential health risks impacts associated with TAC, including DPM emissions associated with construction, an HRA has been performed. Draft EIR Table 5.2-9, Maximum Individual Cancer Risk During Construction (Unmitigated), provides th e total highest calculated carc inogenic risk at off-site sensitive receptors during each phase of construction.

As shown in Draft EIR Table 5.2-9, Project Maximum Individual Cancer Risk During Construction (Unmitigated), the total highest calculated carcinogenic risk would occur during Phase 1, and it would be approximately 13.09 in one million and would exceed the threshold of 10 in one million. The proposed construction activities would overlap during Phase

2. As such, the total highest calculated carcinogenic risk would occur during overlapping construction phases (Phase 2a+Phase2b+Phase 2c) and would be approximately 19.67 in one million, and would exceed the threshold of 10 in one million. Further, the cumulative highest calculated carcinog enic risk from all construction activities would be approximately 33.04 in one million and would exceed the threshold of 10 in one million. As such, the impact on cancer risk would be potentially significant. However, the proposed project would be required to implement MM-AQ-1 requiring all construction equipment above 50 HP to use Tier-4 final engines.

Draft EIR Table 5.2-11, Maximum Individual Cancer Risk During Construction (Mitigated), provides the highest total calculated carcinogenic risk at off-site sensitive areas during each phase of construction.

As shown in Draft EIR Table 5.2-11, Project Maximum Individual Cancer Risk During Construction (Mitigated), the total highest calculated carcinogenic risk would occur during Phase 2b, and it would be approximately 2.60 in one million and would not exceed the threshold of 10 in one million. Th e proposed project construction activities would overlap during Phase 2. As such, the total highest calculated carc inogenic risk would occur during overlapping construction phases (Phase 2a+Phase2b+Phase 2c) would be approximately 6.24 in one million and would not exceed the threshold of 10 in one million. Further, the cumulative highest calculated carcinogenic risk from all construction activities would be approximately 8.79 in one million and would not exceed the threshold of 10 in one million. Therefore, the impact related to cancer risk would not be significant with the implementation of MM- AQ-1.

The significance thresholds for TAC exposure also require an evaluation of non-cancer risk stated in terms of a hazard index. Non-cancer chronic hazard risk is calculated by dividing the annual average concentration by REL for that substance. The REL is defined as the concentration at which no adverse non-cancer health effects are anticipated. The potential for acute non-cancer hazards is evaluated by comparing the maximum short-term exposure level to an acute REL. RELs are designed to protect sensitive individuals within the population. The calculation of acute non-cancer hazard risk is similar to the procedure for chronic non-cancer hazard risk. Currently, OEHHA has not set an acute REL for DPM. dŽďĞĐŽŶƐĞƌǀĂƚŝǀĞ͕ƚŚĞĂĐƵƚĞZ
>ĨŽƌĐƌŽůĞŝŶ;ŝ͘Ğ͕͘Ϯ͘ϱʅŐͬm3) is used instead given that Acrolein is a major component of diesel exhaust and is considered the worst-case acute REL for diesel exhaust emissions.

A chronic hazard index of 1.0 is considered individually significant. The maximum chronic hazard index associated with unmitigated construction emissions at residential sensitive receptors would be 0.933; therefore, impacts related to chronic health hazards during construction would be less than significant. The maximum acute hazard index associated with unmitigated construction emissions at residential sensitive receptors would be 2.5. Accordingly, the proposed project would result in less than significant impacts related to acute health hazard risks during project construction at residential sensitive receptors.

However, by complying with MM-AQ-1, the project would reduce construction-related DPM emissions and associated acute risk, and the highest maximum chronic and acute hazard index associated with the mitigated emissions from project construction at residential sensitive receptors would be 0.06 and 0.44. It should be noted that the acute hazard

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 25
was calculated using the REL of Acrolein, which only consti tutes a small portion of total DPM emissions. As such, the acute hazard value presented is conservative. Therefore, the project’s chronic and acute hazard index would be less than significant with mitigation incorporated.

Therefore, by complying with MM-AQ-1, the health impacts during construction of the proposed project would be less than significant.

Operation
The proposed project would involve the development of residential, office, retail, and restaurant uses that would result in limited operational activities, including landscaping main tenance operations and boilers for restaurant uses, that would not generate excessive DPM or other TAC emissions. According to CARB, land uses that generate excess DPM or other TAC emissions include freeways and high-traffic roads, distribution centers, rail yards, ports, refineries, chrome platers, dry cleaners, and gasoline dispensing facilities. 3 The project does not include any of these uses. Therefore, operation of the proposed project is not anticipated to result in an elevated cancer or other health risk to nearby sensitive receptors, and, as such, the health impact duri ng operation of the proposed project would be less than significant.

Carbon Monoxide Hotspots
CO emissions are a function of vehicle idling time, meteorol ogical conditions, and traffic flow. Under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthful levels (i.e., adversely affecting residents, school children, hospital patients, the elderly, etc.). The Ventura County Air Pollution Control District (VCAPCD) requires a quantified assessment of CO hotspots when a project would generate indirect emissions greater than the applicable ozone project significance thresholds (25 pounds per day of NOX and ROG), and may significantly impact roadway intersections that are currently operating at, or are expected to operate at, Levels of Service (LOS) E or F. Because traffic congestion is highes t at intersections where vehicles queue and are subject to reduced speeds, these hot spots are typically produced at intersections.

An operational traffic analysis was prepared as part of the Traffic, Circulation and VMT Study (appended to the Draft EIR) to analyze potential circulation system deficiencies that may result from project implementation including level of service (LOS) and queuing deficiencies; refer to Draft EIR Se ction 5.14, Transportation. The traffic analysis concluded that the study-area intersections operate at an acceptable LOS under existing, existing plus project, cumulative, and cumulative plus project scenarios. Therefore, according to the VCAPCD guidelines, the project is not qualified for a quantified assessment of CO hotspots. Less than significant impacts would result in this regard.

Valley Fever
The project would not impact undisturbed land; the project is an infill development on previously disturbed land, which is not a source of Valley Fever spores. In the unlikely even t that construction activities would release the spores that cause Valley Fever, increases in Valley Fever tend to occur only after major ground-disturbing events. Other factors include disturbance of topsoil of undeve loped land (to a depth of 12 inches); dry, alkaline, sandy soils; virgin, undisturbed, non-urban areas; and special events (fairs, concerts, motocross track) on unvegetated soil. The VCAPCD has no recommended threshold for a significant Valley Fe ver impact. However, because the proposed project would not involve the above factors, and fugitive dust would be minimized by complying with VCAPCD Rule 55, impacts would be less than significant.

Health Risk Impacts of On-Site Sensitive Receptors
The project site is located adjacent to Highway 101. The carcinogenic and non-carcinogenic hazards resulting from the DPM emissions from trucks traveling on Highway 101 adjacent to the proposed project were evaluated using the EPA

3 California Air Resources Board, 2005, Air Quality and Land Use Handbook: A Community Health Perspective, http://www.aqmd.gov/docs/default-source/ceqa/handbook/california-air-resources-board-air-quality-and-land-use-handbook-a- community-health-perspective.pdf.

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 26
AERMOD dispersion model. The modeled pollutant concentrations represent outdoor exposure levels, and consistent with OEHHA guidance, the modeling conservatively does not apply indoor exposure adjustments for receptors. Because individuals typically spend the majority of their time indoors rather than outdoors at a single location for 24 hours per day4, the modeled AERMOD concentrations are considered a conservative representation of actual exposure conditions at the project site.

The highest overall annual concentration of diesel exhaust from Highway 101 to the proposed project’s on-site sensitive ƌĞĐĞƉƚŽƌƐǁŽƵůĚďĞϬ͘ϬϱϱϴϱʅŐͬŵ 3 and the highest calculated carcinogenic risk would be approximately 9.43 in one million at the on-site sensitive receptors. In addition, Ca lifornia Code of Regulations Title 24, Part 6 requires new buildings to install MERV 13 or higher air filtration on space-conditioning and mechanical ventilation systems that provide outdoor air to habitable spaces. While MERV 13 filtration would substantially reduce indoor PM 10 concentrations by 95 percent, which includes DPM, these reductions are not accounted for in the risk calculations, which are based on unmitigated outdoor exposure assumptions. Therefore, the cancer risk estimates are conservative, and actual indoor exposures would be lower with implementation of required MERV 13 filtration. Thus, carcinogenic exposures from the trucks traveling on Highway 101 are calculated to be within acceptable limits and would not exceed VCAPCD threshold of 10 in one million.

Construction Health Risk Impacts of On-Site Sensitive Receptors As previously stated, a Health Risk Assessment (HRA) was co nducted to evaluate potential health risks to the on-site sensitive receptors during all phases of project construction. The analysis addresses both existing and newly introduced receptors, ensuring compliance with applicable air quality and health risk standards. During Phase 1, Phase 2a, and Phase 2, existing on-site receptors would be present within the project site during construction activities, such as City staff working within the CAP building. Further, Phase 2a would introduce new sensitive receptors, including residential and hotel uses. The HRA accounted for these additional receptors to ensure a comprehensive risk evaluation. Draft EIR Table 5.2-10, On-Site Maximum Individual Cancer Risk During Construction (Unmitigated), provides the total highest calculated carcinogenic risk at on-site sensitive receptors during each phase of construction.

As shown in Draft EIR Table 5.2-10, the total highest calculat ed carcinogenic risk would be approximately 0.85 in one million and would occur during Phase 2b construction activities. In Draft EIR Table 5.2-10, the total highest calculated carcinogenic risk from all construction activities would be approximately 2.16 and would not exceed the threshold of 10 in one million. The impact to cancer risk would be not potentially significant. However, the project would be required to implement MM-AQ-1 requiring all construction equipment above 50 HP to use Tier-4 final engines. Therefore, with the implementation of MM-AQ-1, the total highest calculated carcinogenic risk would be less than that shown in Draft EIR Table 5.2-10. As such, the impact to cancer risk would be less than significant with mitigation incorporated.

Programmatic-Level Analysis
The analysis provided above for the Project-Level Analysis is also applicable to the adaptive reuse and outdoor amphitheatre components, as it applies to the project site as a whole. At full buildout, the adaptive reuse and outdoor amphitheatre components would result in a maximum buildout potential of up to 24,970 square feet of commercial uses and 84,150 square feet of institutional uses, including 2,744 institutional performance venue seats. However, the Project-Level Analysis applies to the adaptive reuse and outdoor amphitheatre components because these activities would involve similar construction methods, equipment, a nd exposure conditions, would affect the same receptors, and would be subject to the same VCAPCD thresholds and mi tigation requirements. Therefore, impacts in this regard would be less than significant with the implementation of MM-AQ-1.

4 California Air Resources Board Research Division and University of California, Berkeley, Activity Patterns of California Residents, May 1991. The study indicates that on average, adults and adolescents in California spent almost 15 hours per day inside their homes, and 6 hours in other indoor locations, for a total of 21 hours (87 percent of the day). Approximately two hours per day were spent in transit, and just over one hour per day was spent in outdoor locations

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It is acknowledged that the temporary relocation component could introduce people to off-site locations (within existing permitted office space) within City boundaries that could be located in proximity to additional sensitive receptors. However, this component would not result in new development or significant additional employees exceeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off-site. Therefore, the temporary relocation component would not result in impacts on sensitive receptors.

MITIGATION MEASURES

PROJECT-LEVEL ANALYSIS
MM-AQ-1 The Construction Contractor shall ensure that off-road diesel construction equipment of 50 horsepower (HP) or greater shall comply with EPA/CARB Tier 4 emissions standards or equivalent and shall ensure that all construction equipment is tuned and maintained in accordance with the manufacturer’s specifications. This requirement shall be verified through submittal of an equipment inventory that includes the following information: (1) Type of Equipment, (2) Engine Year and Age, (3) Number of Years Since Rebuild of Engine (if applic able), (4) Type of Fuel Used, (5) Engine HP, (6) Verified Diesel Emission Control Strategy (VDE CS) information if applicable and other related equipment data. A Certification Statement is also required to be made by the Contractor for documentation of compliance and for future review by the VCAPCD, as necessary. The Certification Statement must state that the Contractor agrees to compliance and acknowledges that a violation of this requirement shall constitute a material breach of contract.

PROGRAMMATIC-LEVEL ANALYSIS
Mitigation Measure AQ-1 is also applicable to the adaptive reuse and outdoor amphitheatre components because they would involve construction in proximity to the same sensitive receptors.

Cumulative Impacts The proposed project, combined with other cumulative projects, would not expose sensitive receptors to substantial pollutant concentrations.

CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” As outlined in Draft EIR Table 4-1 and illustrated on Draft EIR Exhibit 4-1, cumulative projects are situated in the site vicinity.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.2, Air Quality, and in particular, on pages 5.2-43 and 5.2-44 of the Draft EIR.

Construction
Construction activities associated with the project woul d not expose sensitive receptors to substantial pollutant concentrations. As discussed under Impact Statement AQ-3 , project-level localized air quality construction health impacts would not exceed VCAPCD-adopted significance thresholds with implementation of MM-AQ-1. In addition, future cumulative projects in the vicinity would be required to evaluate construction-related emissions and implement

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mitigation measures, as necessary, under CEQA. Therefore, construction of the project, when considered in combination with other cumulative development, would not result in substantial pollutant concentrations at sensitive receptor locations.

Operation
Operational emissions from the project would not expose sensitive receptors to substantial pollutant concentrations.

As demonstrated in the project-level analysis, localized air quality operational health impacts would not exceed VCAPCD-adopted thresholds. In addition, ongoing advancements in emission reduction technologies, strategies, and regulatory programs would further reduce regional air pollutant concentrations over time.

Accordingly, the project would not expose sensitive receptors to substantial pollutant concentrations, and cumulative impacts related to sensitive receptor exposure would be less than significant.

MITIGATION MEASURES
MM-AQ-1 The Construction Contractor shall ensure that off-road diesel construction equipment of 50 horsepower (HP) or greater shall comply with EPA/CARB Tier 4 emissions standards or equivalent and shall ensure that all construction equipment is tuned and maintained in accordance with the manufacturer’s specifications. This requirement shall be verified through submittal of an equipment inventory that includes the following information: (1) Type of Equipment, (2) Engine Year and Age, (3) Number of Years Since Rebuild of Engine (if applicable), (4) Type of Fuel Used, (5) Engine HP, (6) Verified Diesel Emission Control Strategy (VDE CS) information if applicable and other related equipment data. A Certification Statement is also required to be made by the Contractor for documentation of compliance and for future review by the VCAPCD, as necessary. The Certification Statement must state that the Contractor agrees to compliance and acknowledges that a violation of this requirement shall constitute a material breach of contract.

Biological Resources
Impact BIO-1 The proposed project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

Applicable Threshold of Significance: Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.3, Biological Resources, and in particular, starting on page 5.3-12 and concluding on page 5.3-16 of the Draft EIR.

The Michael Baker International (Michael Baker) Biological Resources Assessment, dated February 06, 2026, provided in Draft EIR Appendix D, is based on data from the U.S. Fish and Wildlife Service (USFWS) Information for Planning and

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Consultation (IPaC) project planning tool, California Department of Fish and Wildlife (CFDW) California Natural Diversity Database RareFind 5 (CNDDB), and California Native Plant Society’s (CNPS) Inventory of Rare and Endangered Plants of California (IRP). The analysis is also based on the Downtown Thousand Oaks Project Arborist Report (Arborist Report), prepared by Bancroft Construction Services, dated January 9, 2026, included in Draft EIR Appendix E.

Project-Level Analysis
The project site is composed of developed, disturbed, and landscaped land covers and does not contain the natural vegetation communities, or for some, the aquatic habitats, that are suitable to support the special-status plant and wildlife species that are known to occur within the region. As a result, the proposed project is not expected to have direct or indirect impacts on any special-status plant or wildlife species. However, as described in Draft EIR Section

5.3.1, nesting birds, roosting bats, and Crotch’s bumble bee have some potential to occur within the project site and, if present, could be directly impacted during vegetation removal or indirectly impacted by noise, vibration, and human presence during project construction. To avoid and minimize impacts to these biological resources, Mitigation Measures provided in the City of Thousand Oaks 2045 General Plan Update EIR (2023) (General Plan EIR) shall be implemented to reduce potential impacts to special-status species to less than significant.

Additionally, although bat maternity roosting is not expected to occur on-site, individual or small groups of day- and/or night-roosting bats have the potential to occur on-site and could be directly impacted during vegetation removal or indirectly impacted by noise, vibration, and human presence associated with construction. Potential significant impacts and measures to reduce impacts to less than significant are presented below.

Special-Status Plant Species
Based on the results of the field survey, a review of the specific habitat preferences, distributions, and elevation ranges, Michael Baker determined that none of the 64 special-status plant species identified during the database reviews are expected to occur within the project site. Impacts to special-status plant species would be less than significant.

Special-Status Wildlife Species
Based on the results of the field survey, a review of the specific habitat preferences, distributions, and elevation ranges, Michael Baker determined that none of the 54 special-status wildlife species identified during the database reviews are expected to occur within the project site.

Nesting birds protected under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC) could be directly impacted by construction equipment and indirect ly impacted by construction noise, dust, and vibrations, which can result in increased nestling mortality due to nest abandonment or decreased feeding frequency. Although no active bird nests were observed and bird activity was generally low during the field survey, the project site provides nesting habitat for most year-round and seasonal avian residents in the form of mature trees and other vegetation, as well as structures on-site. To reduce potential impacts to nesting birds, MM-BIO-1, taken from the General Plan EIR, requires a pre-construction nesting bird clearance survey to determine the presence/absence, location, and status of any active nests on or adjacent to the project site. If the nesting bird clearance survey indicates the presence of an active nest(s), MM-BIO-1 requires buffers to ensure that any nesting migratory native birds are protected pursuant to the MBTA.

The project site does not contain suitable colonial maternit y roosting habitat for bats; however, individuals or small groups of bats can utilize tree foliage and small crevices a nd cavities within trees, and man-made structures for day- and/or night-roosting. Although no individuals or signs of ba ts were observed during the field survey, the project site provides trees and structures within which maternity roosting bats may roost. To reduce potential impacts to maternity roosting bats, MM-BIO-2, taken from the General Plan EIR, requires a pre-construction survey for day- and/or night- roosting or maternity-roosting bats to determine the presen ce/absence, location, and status of any roosting bats or

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maternity roosts. If the bat clearance survey indicates the presence of roosting bats, MM-BIO-2 requires avoidance of the roost(s) the development of project-specific mitigation measures if the roost(s) cannot be avoided.

Additionally, as described in Draft EIR Section 5.3.1, Crotch’s bumble bee has some potential to occur on-site as a migrating or foraging transient. To confirm the project site’s suitability to provide foraging, nesting, and/or overwintering habitat for the species, MM-BIO-3, taken from the General Plan EIR, would be required to identify any suitable habitat for the species on-site and subsequently determine if focused protocol surveys for the species are needed. With implementation of this measure, impacts to Crotch’s bumble bee would be reduced to less than significant.

With the implementation of MM-BIO-1, MM-BIO-2, and MM-BIO-3, future development in accordance with the proposed development component would not result in significant impacts to special-status wildlife species. Impacts to special-status wildlife species would be less than significant with mitigation incorporated.

Conclusion
Overall, with the implementation of MM-BIO-1 (pre-construction nesting bird surveys), MM-BIO-2 (pre-construction roosting bat surveys), and MM-BIO-3 (Crotch’s bumble bee surveys), project impacts to special-status species would be less than significant.

Programmatic-Level Analysis
The analysis provided above for the Project-Level Analysis is also applicable to the adaptive reuse and outdoor amphitheatre components, as it applies to the project site as a whole. There are no unique considerations of the proposed development of the adaptive reuse and outdoo r amphitheatre components that would cause different impacts than those already analyzed abov e. The species identified above as havi ng the potential to occur within the entire project site could potentially be located within the areas proposed for the development of the adaptive reuse and outdoor amphitheatre components. Construction acti vities associated with the adaptive reuse and outdoor amphitheatre components could result in indirect or direct impacts to special-status species associated with the removal of on-site trees and/or structures. Therefore, MM-BIO-1, MM-BIO-2, and MM-BIO-3 would be required to minimize potential impacts to nesting birds, roosting bats, and/or Crotch’s bumble bee to less than significant. Through implementation of MM-BIO-1 through MM-BIO-3, which would be applicable to all construction phases and activities associated with the proposed project, the adaptive reuse and outdoor amphitheatre components would result in less than significant impacts on special-status species. Moreover, the adaptive reuse and outdoor amphitheatre components would be required to comply with the MBTA and CFGC, which establish procedures and requirements for the protection of special-status species.

The adaptive reuse and outdoor amphitheatre components are accounted for in the project area, which encompasses approximately 17.68 acres and is currently developed with a variety of commercial and institutional uses. The Biological Resources Assessment that the analysis herein is based on combined the adaptive reuse and outdoor amphitheatre components with the project-level development component; the field survey encompassed the entire project area, and the resulting conclusions regarding the potential presence of special-status species and associated impacts assumed complete implementation of the proposed project. As analyzed above and in the Biological Resources Assessment, the proposed project, including the adaptive reuse and outdoor amphitheatre components, would result in less than significant impacts on special-status species with compliance with the MBTA and CFGC, and implementation of MM- BIO-1 through MM-BIO-3.

It is acknowledged that the temporary relocation compon ent could introduce people to off-site locations (within existing permitted office space) within City boundaries, at which other special-status species may occur. However, this component would not result in new development or sign ificant additional employees exceeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off-site.

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Therefore, the temporary relocation component would not result in impacts on special-status species. Impacts would be less than significant with mitigation incorporated.

MITIGATION MEASURES

PROJECT-LEVEL ANALYSIS
MM-BIO-1 Conduct Pre-Construction Bird Surveys and Implement Avoidance and Minimization Measures. For construction activities initiated during the bird nesting season February 15 through September 15 (as early as January 1 for raptors), involving removal of vegetation, abandoned structures, man- made features, or other nesting bird habitat, a pre-construction nesting bird survey shall be conducted no more than five (5) days prior to initiation of ground disturbance and vegetation removal. The nesting bird pre-construction survey shall be conducted on foot and shall include an area on and around the construction site at a distance determined by a qualified biologist, including staging and storage areas. The minimum survey radii surrounding the work area shall be 500 feet. The survey shall be conducted by a qualified biologist familiar with the identification of avian species known to occur in the Thousand Oaks region. If construction lapses for five (5) days or longer, the qualified biologist shall conduct another focused survey before project activities are reinitiated. If nests are found, an avoidance buffer shall be determined by the biologist dependent upon the species, the proposed work activity, and existing disturbances associated with land uses outside the site. The qualified biologist shall observe the active nest to establish a behavioral baseline of the adults and nestlings, if present. The qualified biologist shall monitor the active nests while construction activities are happening to detect signs of disturbance and behavioral change as a result of construction impacts, such as noise, vibration, odors, or worker/equipment motion. If signs of disturbance and behavioral changes are observed, the qualified biologist shall stop all construction work causing those changes until a larger avoidance buffer is established or until it is determined that the nesting period is completed. The buffer shall be demarcated by the biologist with bright orange construction flagging, construction lathe, or other means to demarcate the boundary. All construction personnel shall be notified of the buffer zone as a “Nesting Bird Area” and shall avoid entering the buffer zone until a biologist determines that the nest is no longer active. No ground-disturbing activities shall occur within the buffer until the biologist has confirmed that breeding/nesting is completed and the young have fledged the nest.

A report summarizing the pre-construction survey(s) shall be prepared by a qualified biologist and be included on project site plans and submitted to the City prior to the commencement of construction activities.

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construction activities occur during the bat maternity season (April 1 through August 31), special- status bat species emergence survey(s) shall be conducted. Emergence surveys shall be conducted in areas of suitable bat habitat (e.g., near buildings or trees) during the bat maternity season to document any special-status bat species emerging from features identified during the habitat assessment survey. Generally, the emergence survey(s) shall be conducted approximately one hour prior to sunset and last a minimum of two hours after sunset; however, the timing shall be determined by the qualified biologist. Passive acoustic monitoring equipment shall be utilized during the emergence surveys to identify bats to the species level. In the event multiple features were identified in the habitat assessment in which bats may occur, at the discretion of the qualified biologist, either multiple emergency surveys may be necessary or additional acoustic equipment may need to be set up in order to capture the acoustics of bats as they emerge at dusk. Roosting sites documented within or adjacent to a project site during the maternity season shall be avoided. Specifically, the qualified biologist shall determine an appropriate buffer around the roost site where construction shall be avoided. The buffer typically ranges in size, between 100 to 300 feet around the roost site, depending on potential resulting project impacts and surrounding terrain. For example, if the project will result in high noise decibels and the roost site is exposed without surrounding trees or hills, the buffer may be increased to reduce disturbances to the roosting bats during breeding activities. Buffer distances may also be at the discretion of the USFWS and/or CDFW if special-status bat species are present in the maternity roost.
Should special-status bat species be documented within the project site, and the roost site cannot be avoided by the project, a bat mitigation and/or management plan shall be developed for roost relocation. Mitigation and management plans will require consultation with and approval from the USFWS and/or CDFW prior to the commencement of construction.

MM-BIO-3 Conduct Pre-construction Crotch’s Bumble Bee Surveys and Implement Avoidance Measures. For construction activities located in vacant or undeveloped areas containing open grasslands, shrublands, or chaparral, a habitat assessment for Crotch’s bumble bee shall be performed by a qualified biologist knowledgeable and experienced with Crotch’s bumble bee and the habitat in which they occur. If the biologist determines that suitable habitat for Crotch’s bumble bee is present, a focused survey shall be performed during the species’ active flight period for Crotch’s bumble bee and peak blooming period of nectar and pollen sources (May 1 through July 31). The Crotch’s bumble bee survey shall be conducted on foot and shall encompass the entirety of the project site and focus on areas that allow for the highest probability of detection, such as high abundance nectar or pollen sources and rodent burrows that may be used for breeding and nesting. If Crotch’s bumble bee is determined to be present, the project proponent shall map the locations of the observed bumblebee, areas of abundant nectar or pollen sources, and any active nesting sites. A report summarizing the results of the habitat assessment and focused survey (if required) shall be prepared by the qualified biologist and shall be submitted to the City prior to the commencement of construction activities. Further, consultation with the CDFW will be necessary in the event Crotch’s bumble bee was observed within the project site and an Incidental Take Permit, in accordance with the California Endangered Species Act, may be required prior to initiating any ground disturbance on the site.

PROGRAMMATIC-LEVEL ANALYSIS
MM-BIO-1, MM-BIO-2, and MM-BIO-3 are also applicable to the adaptive reuse and outdoor amphitheatre components because these components would result in demolition and construction on the same project site. All three mitigation

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measures shall be applied and the corresponding surveys conducted at the start of each construction phase of the proposed project that requires human activity on-site.

Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measures above. Upon implementation of the required mitigation measures, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

Impact BIO-5 The proposed project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

Applicable Threshold of Significance: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.3, Biological Resources, and in particular, starting on page 5.3-18 and concluding on page 5.3-21 of the Draft EIR.

Project-Level Analysis
The project site does not coincide with any of the County of Ventura’s wildlife movement, connectivity, or critical passage area overlays and would not conflict with or require consideration of these overlays.

City-Protected Trees
The City protects oak trees and landmark trees through City Ordinance (Municipal Code Sections 9-4.42 and 9-4.43) and the City's Oak Tree Preservation and Protection Guidelines (Resolution 2010-014). In accordance with the Oak Tree Ordinance, no person shall cut, remove, encroach into the protected zone, or relocate any oak tree on any public or private property within the City, unless a valid protected tree permit has been issued by the City pursuant to the provisions of the Oak Tree Ordinance and the Oak Tree Pres ervation and Protection Guidelines. No person shall cut, remove, encroach into the protected zone, or relocate any landmark tree on any public or private property within the City unless a valid protected tree permit has been issued by the City pursuant to the Landmark Tree Preservation and Protection Ordinance.

As shown on the Tree Protection, Relocation and Removals Plan, most of the protected tree impacts would occur at the western portion of the project site where new development is proposed; whereas many of the mature protected trees (mostly oaks) located within the plaza park at the eastern portion of the project site would be retained. For the purposes of evaluating potential project-related impacts on prot ected trees, encroachment means any intrusion into the protected zone of a tree, including but not limited to, grading, excavation, trenching, dumping of materials, equipment storage, building structures, paving, or other improvements. Encroachment does not include the action of a person physically entering the tree’s protected zone. Construction-related encroachments were considered based on a tree’s protective zone (TPZ) and the location of the nearest ground disturbance that would occur during construction activities (e.g., grading, excavation, and trenching). Anticipated canopy pruning that would be required for construction equipment access and/or fire department vertical clearance was also considered when assessing potential tree impacts.

Minor impacts would occur where construction activities would occur within the TPZ but are not likely to compromise the health or structural integrity of the tree or generally would encompass less than 20 percent of the tree’s canopy and roots. Major impacts would occur where construction activities would occur within the TPZ and may result in the future decline of the tree, such as from grading, excavation, fill, soil compaction, substantial branch removal, and/or encroaching 20 percent or more into the tree’s canopy or roots. Excavation or trenching located within three-to-five

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times the distance of the tree’s trunk diameter may result in decline, even if total encroachment of the tree’s canopy & roots is less than 20 percent. Trees in this category were also assessed to determine if the degree of proposed encroachment is likely to result in a decline in plant health or would create a possible future risk to public safety.

The proposed project would require the removal of and encroachment into on-site trees protected under the City’s Oak and Landmark Tree Preservation and Protection ordinances. The Arborist Report identified a total of 122 protected trees that have a tree protected zone located within or overlapping the project site area of disturbance. Of the 122 protected trees, 45 would be removed, including 31 coast live oaks, nine valley oaks, one California sycamore, and four toyon. Additionally, 39 protected trees would be encroached upon, including 21 major encroachments (construction activities proposed within more than 20 percent of the tree’s canopy or roots, which may result in the future decline or mortality of the tree), and 18 minor encroachments (construction activities within less than 20 percent of the tree’s roots or canopy and not expected to compromise the health of the tree). Eight of the major encroachments are considered “severe”. Twenty-eight (28) protected trees would be avoided during project implementation and retained on-site, including 17 coast live oaks, seven valley oaks, three toyon, and one California sycamore. Most of the protected tree impacts would occur in the western portion of the project site, where new development is proposed. Many of the mature protected trees (mostly oaks) located within the northeastern portion of the project site would be retained.

Additionally, 10 trees have been identified for relocation, in cluding five coast live oaks and five valley oaks. The trees were selected based on their structure, relatively sma ll size, and location. They would be moved to the vacant southeastern corner of the project site, located south of th e existing service road to the Kavli Theatre loading dock, west of Conejo School Road, and north of Highway 101. This portion of the project site has adequate space between native vegetation for introducing the relocated oak trees, and they are expected to have a high survival rate, if planted in accordance with the guidelines in the Arborist Report.

In order to comply with the City ordinances, the proposed project would mitigate the removal of and encroachment into protected trees by planting three mitigation trees for every protected tree that is removed or faces major “severe” encroachment impacts. The project proposes to plant 159 mitigation trees both on- and off-site. One hundred and thirty-five (135) mitigation trees would be planted to replace the 45 protected trees that would be removed, and an additional 24 mitigation trees would be planted for the eight protected trees that would have major encroachments that are considered severe. As described in the Arborist Report, 11 oak trees (four coast live oak, three valley oak, and four island oak) would be planted on-site, and 148 oak trees would be planted off-site within City-owned property, public Right-of-Ways, or in open space areas owned and managed by the Conejo Open Space Conservation Agency. The required replacement trees include a mix of protected tree species, including 94 24-inch, and 47 36-inch box trees.

Therefore, the proposed project would comply with the Ci ty’s oak and landmark tree preservation and protection ordinances by replacing protected trees at the required ratio.

However, inadvertent impacts outside of the designated impa ct footprint during project construction could result in the trimming, pruning, removal, or encroachment into the protected zones of protected oak and landmark trees. There is also the potential for other short-term and long-term i ndirect impacts to affect the proposed replacement trees if not properly monitored, and the proposed relocated trees if not properly transported and monitored. The Arborist Report includes a Tree Protection Plan that describes avoidance and minimization measures to be used during pre- construction, construction, post-construction, relocation, and planting to ensure that all City ordinances and guidelines are followed and that all affected protected, relocated, and replacement trees survive. MM-BIO-4 requires compliance with the Tree Protection Plan.

Thousand Oaks General Plan 2045
The City’s General Plan includes Goal C-4 and Policy 4.1, which provide for the protection of oak and landmark trees through implementation of the City’s Oak Tree and Landmark Tree Ordinances (see Draft EIR Section 5.3.2).

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x Goal C-4: Protect oak and landmark trees to maintain Thousand Oaks’ unique environmental character. o Policy 4.1 Protected tree preservation: Continue to implement the City’s Oak Tree and Landmark Tree Ordinances per the Municipal Code and the Oak Tree Preservation and Protection Guidelines.

As described above, the proposed project would comply with the Ordinances and Oak Tree Preservation and Protection Guidelines through the implementation of MM-BIO-4, wh ich requires compliance with the Tree Protection Plan.

Because the proposed project would comply with the Ordinances, the proposed project would be consistent with the goals and policies of the General Plan. Implementation of MM-BIO-4 would ensure the proposed project does not conflict with the General Plan’s goals and policies related to oak and landmark trees.

Conclusion
With the implementation of MM-BIO-4 (Tree Protection Plan Compliance), project impacts to local biological resources policies or ordinances would be less than significant.

Programmatic-Level Analysis
The analysis provided above for the Project-Level Analysis is also applicable to the adaptive reuse and outdoor amphitheatre components, as it applies to the project site as a whole. There are no unique considerations of the proposed development of the adaptive reuse and outdoo r amphitheatre components that would cause different impacts than those already analyzed above. Construction of the adaptive reuse and outdoor amphitheatre components would require the removal of and/or construction activities within the vicinity of trees located on-site. The adaptive reuse and outdoor amphitheatre components are accounted for in the project area. The Biological Resources Assessment and the Arborist Report that the analysis herein is based on combined the adaptive reuse and outdoor amphitheatre components with the project-level development component; the field surveys encompassed the entire project area, and the resulting conclusions regarding the removal and protection-in-place of protected trees on-site and associated impacts assumed complete implementation of the proposed project. As analyzed above, the proposed project, including the adaptive reuse and outdoor amphitheatre components, would result in less than significant impacts on protected trees through compliance with the City's Oak Tree Preservation and Protection Guidelines, and implementation of MM-BIO-4. MM-BIO-4 would be required to ensure compliance with the Tree Protection Plan developed for the proposed project within the Arborist Report.

Through implementation of MM-BIO-4, the adaptive reuse and outdoor amphitheatre components would result in less than significant impacts on local biological resources policie s and ordinances. It is acknowledged that the temporary relocation component could introduce people to off-site loca tions (within existing permitted office space) within City boundaries at which other protected trees may occur. However, this component would not result in new development or significant additional employees exc eeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off-site. Therefore, the temporary relocation component would not result in impacts on local biological resources policies and ordinances. Therefore, impacts would be less than significant with mitigation incorporated.

MITIGATION MEASURES

PROGRAMMATIC-LEVEL ANALYSIS
MM-BIO-4 is also applicable to the adaptive reuse and outdoor amphitheatre components, as development of these components would also require the removal, relocation, and/or encroachment into the protected zone of on-site trees.

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Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measure above. Upon implementation of the required mitigation measure, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted.

Cumulative Impacts The proposed project, combined with other cumulative projects, would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” The cumulative analysis below considers the proposed project’s impacts in conjunction with the future buildout of the General Plan and cumulative projects listed in Draft EIR Table 4-1, Cumulative Projects List.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.3, Biological Resources, and in particular, on page 5.3-22 of the Draft EIR.

Similar to future development within the project site, cumulative projects would be required to undergo project-specific environmental review under CEQA and the lead agency’s discretionary review process to determine potential impacts to sensitive special-status species and any required mitigation. Future projects would also be required to comply with existing requirements related to nesting migratory native birds, including the MBTA. Future environmental review for related projects may require preparation of a biological resources assessment and focused protocol surveys to evaluate project-specific impacts to special-status species and identify required mitigation.

The proposed development, adaptive reuse, and outdoor amphitheatre components could impact special-status species. However, implementation of MM-BIO-1 (pre-construction nesting bird surveys), MM-BIO-2 (roosting bat surveys), and MM-BIO-3 (Crotch’s bumble bee surveys) would reduce impacts to less than significant levels. Thus, the project would not result in cumulatively considerable impacts to sensitive special-status species. Cumulative impacts in this regard would be less than significant.

MITIGATION MEASURES
MM-BIO-1 Conduct Pre-Construction Bird Surveys and Implement Avoidance and Minimization Measures. For construction activities initiated during the bird nesting season February 15 through September 15 (as early as January 1 for raptors), involving removal of vegetation, abandoned structures, man- made features, or other nesting bird habitat, a pre-construction nesting bird survey shall be conducted no more than five (5) days prior to initiation of ground disturbance and vegetation removal. The nesting bird pre-construction survey shall be conducted on foot and shall include an area on and around the construction site at a distance determined by a qualified biologist, including staging and storage areas. The minimum survey radii surrounding the work area shall be 500 feet. The survey shall be conducted by a qualified biologist familiar with the identification of avian species known to occur in the Thousand Oaks region. If construction lapses for five (5) days or longer, the qualified biologist shall conduct another focused survey before project activities are reinitiated. If nests are found, an avoidance buffer shall be determined by the biologist dependent upon the species, the proposed work activity, and existing disturbances associated with land uses

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outside the site. The qualified biologist shall observe the active nest to establish a behavioral baseline of the adults and nestlings, if present. The qualified biologist shall monitor the active nests while construction activities are happening to detect signs of disturbance and behavioral change as a result of construction impacts, such as noise, vibration, odors, or worker/equipment motion. If signs of disturbance and behavioral changes are observed, the qualified biologist shall stop all construction work causing those changes until a larger avoidance buffer is established or until it is determined that the nesting period is completed. The buffer shall be demarcated by the biologist with bright orange construction flagging, construction lathe, or other means to demarcate the boundary. All construction personnel shall be notified of the buffer zone as a “Nesting Bird Area” and shall avoid entering the buffer zone until a biologist determines that the nest is no longer active. No ground-disturbing activities shall occur within the buffer until the biologist has confirmed that breeding/nesting is completed and the young have fledged the nest.

A report summarizing the pre-construction survey(s) shall be prepared by a qualified biologist and b e i n c l u d e d o n p r o j e c t s i t e p l a n s a n d s u b m i t t e d t o t h e C i t y p r i o r t o t h e c o m m e n c e m e n t o f construction activities.

MM-BIO-2 Special-Status Bat Species Habitat Assessment Survey and Emergence Survey(s). For construction activities where trees, abandoned structures, or other habitat for roosting bats is present and construction activities may occur during seasonal periods of bat activity, construction activities shall occur outside the maternity season from April 1 through August 31, as feasible. Should construction timing not allow for it, a special-status bat habitat assessment survey shall be conducted by a qualified biologist no more than five (5) days prior to any construction activities during the bat maternity season. The survey shall document any evidence of special- status bat species that may occur in proposed work areas through direct observation (e.g., roosting bats) and/or sign(s) (e.g., bat guano). If no observance and/or sign(s) of special-status bats are detected during these surveys, then construction-related activities may proceed. If observance or sign(s) of special-status bat species are detected during the survey, and construction activities occur during the bat maternity season (April 1 through August 31), special- status bat species emergence survey(s) shall be conducted. Emergence surveys shall be conducted in areas of suitable bat habitat (e.g., near buildings or trees) during the bat maternity season to document any special-status bat species emerging from features identified during the habitat assessment survey. Generally, the emergence survey(s) shall be conducted approximately one hour prior to sunset and last a minimum of two hours after sunset; however, the timing shall be determined by the qualified biologist. Passive acoustic monitoring equipment shall be utilized during the emergence surveys to identify bats to the species level. In the event multiple features were identified in the habitat assessment in which bats may occur, at the discretion of the qualified biologist, either multiple emergency surveys may be necessary or additional acoustic equipment may need to be set up in order to capture the acoustics of bats as they emerge at dusk. Roosting sites documented within or adjacent to a project site during the maternity season shall be avoided. Specifically, the qualified biologist shall determine an appropriate buffer around the roost site where construction shall be avoided. The buffer typically ranges in size, between 100 to 300 feet around the roost site, depending on potential resulting project impacts and surrounding terrain. For example, if the project will result in high noise decibels and the roost site is exposed without surrounding trees or hills, the buffer may be increased to reduce disturbances to the roosting bats during breeding activities. Buffer distances may also be at the discretion of the USFWS and/or CDFW if special-status bat species are present in the maternity roost.

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Should special-status bat species be documented within the project site, and the roost site cannot be avoided by the project, a bat mitigation and/or management plan shall be developed for roost relocation. Mitigation and management plans will require consultation with and approval from the USFWS and/or CDFW prior to the commencement of construction.

Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measures above. Upon implementation of the required mitigation measures, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

Cumulative Impacts The proposed project, combined with other cumulative projects, would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.3, Biological Resources, and in particular, on pages 5.3-23 and 5.3-24 of the Draft EIR.

Similar to future development within the project site, cumulative projects would be required to undergo project-specific environmental review under CEQA and the lead agency’s discretionary review process to determine potential impacts to local policies or ordinances protecting biological resources and any required mitigation. Future environmental review for related projects may require preparation of a biological resources assessment or arborist report and focused protocol surveys to evaluate project-specific impacts to local policies or ordinances and identify required mitigation.

The proposed development, adaptive reuse, and outdoor amphitheatre components could impact local policies and ordinances regarding oak and landmark tree preservation and protection. However, implementation of MM-BIO-4 (Tree Protection Plan Compliance) would reduce impacts to less than significant levels. Thus, the project would not result in

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cumulatively considerable impacts to local policies or ordi nances protecting biological resources. Cumulative impacts in this regard would be less than significant.

MITIGATION MEASURES
MM-BIO-4 Tree Protection Plan Compliance. The proposed project shall comply with the requirements of the Tree Protection Plan, prepared by Bancroft Construction Services, dated January 9, 2026, available in Appendix E.

Cultural Resources
Impact CUL-1 The proposed project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5.

Applicable Threshold of Significance: Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.4, Cultural Resources, and in particular, starting on page 5.4-21 and concluding on page 5.4-24 of the Draft EIR.

Draft EIR Section 5.4 is primarily based on the Historical/Archaeological Resources Survey Report, Downtown Thousand Oaks Project, City of Thousand Oaks, Ventura County, California (Cultural Report), prepared by CRM TECH and dated October 12, 2025, as well as the Extended Phase I Archaeological Exploration Program, Downtown Thousand Oaks Project, City of Thousand Oaks, Ventura County, California (Extended Phase I Archaeological Study), prepared by CRM TECH and dated December 23, 2025; refer to Draft EIR Appendix F, Historical/Archaeological Resources Survey, and Draft EIR Appendix G, Extended Phase I Archaeological Study Project-Level Analysis
Historic-Period Resources
Based on the Cultural Report, three commercial buildings fr om the historic period were identified at the proposed locations for Buildings E2 and E3 and associated infrastructure and hardscape improvements. The buildings include an auto service shop, a former tavern, and a former Taco Bell restaurant at 1934, 1938, and 1948 Thousand Oaks Boulevard, respectively. The buildings were constructed between 1955 and 1968 and therefore meet the age threshold for consideration as potential “historical resources”. As pa rt of the cultural resources study, CRM TECH recorded the buildings into the California Historical Resources Inventory; they were evaluated for historical significance and were found to be ineligible for listing in the California Register of Historical Resources or for local designation.

The existing CAP complex was built between 1992 and 1994 and was designed by master architect Antoine Predock, who was responsible for dozens of notable buildings in California and other states. Guidelines for the California Register of Historical Resources provide for the consideration of properties less than 50 years old for listing, but such properties are required to be of “exceptional importance”. Though the CAP serves as a hub for performing arts and local government operations, the complex does not possess characteristics which would stow upon the buildings an exceptional level of significance as required by the California Register.

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The CAP is notable for its connection to Antoine Predock. However, based on the Cultural Report, there is no evidence that the design for these buildings represents an exceptiona l or particularly important example of his extensive body of work. Additionally, Predock remained active in the field of architecture through the early 2000s before passing away in 2024; therefore, the end of his arch itectural career was too recent to allow for an adequate assessment of his contribution to the field or the significance of this project in his career. Thus, the CAP does not warrant consideration as a potential historical resource due to insufficient age, and its architecture not being of particular significance to the history of the surrounding area or Antoine Predock.

According to the Cultural Report, no other properties of hi storical origin were encountered within the project area.

Therefore, there are no buildings within the project site that constitute “historical resources” pursuant to CEQA.

Within one mile of the project site, the Cultural Report iden tified 36 additional cultural resource studies, from which 10 cultural resources were recorded, including two historic-period sites. One of the historic-period sites was a group of rock features located in the hills on the southwestern side of Highway 101, and the other represented a group of buildings, including a former restaurant and a residence, all of which were demolished in 2017. Neither of the historic- period sites were found within the vicinity of the project site, and the proposed project would not affect these sites.

Prehistoric Archaeological Resources
Based on the Cultural Report, a previously recorded archaeological site, Site 56-000654, was found to be lying partially within the project area of disturbance. Site 56-000654 was first recorded in the 1970s as an artifact scatter from a prehistoric village or seasonal habitation area. The site was evaluated through an archaeological testing program in 1986, prior to the construction of the CAP, and was found not to constitute a “unique archaeological resource”.

Mitigative data recovery was subsequently carried out, and much of the site was removed during the CAP project under archaeological monitoring. However, a more recent archae ological monitoring program in 2004-2005 focused on the adjacent “The Lakes” property, which observed additional prehistoric archaeological remains on the surface within the current project site, resulting in an expansion of the boundary of Site 56-000654.

During the field survey for the Cultural Report, two possible prehistoric artifacts were noted on the surface of the project site, although both occurred in an extensively disturbed context. Due to the undeveloped nature of the southeastern and northwestern portions of the project site under existing conditions, the Extended Phase I Archaeological Study was conducted to resurvey the project site, conduct archaeological excavations, analyze the recovered artifacts in a laboratory, and assess the potential for “historical resources” to occur within the project site.

The Extended Phase I Archaeological Study determined that the recovered artifacts were both common by-products of toolmaking throughout prehistoric times. Additionally, two lithic materials were discovered during the excavations; however, this material is widely available in the Thousand Oaks/Conejo Valley area. Therefore, no diagnostic artifacts or significant archaeological features were found within the project site. Based on the Extended Phase I Archaeological Study, the recent findings from Site 56-000654 hold little potential for any important archaeological data for the study of local and regional prehistory. The remnants of the site in the project area do not meet the criteria for listing in the California Register of Historical Resources and do not qua lify as a “historical resource” or a “unique archaeological resource” pursuant to CEQA.

Additionally, the Extended Phase I Archaeological Study determined that the portion of the project area located in the northwest corner of the site, west of Dallas Drive, which appears to be less disturbed upon surface observation, has undergone substantial past disturbance. Evidence of disturbance was discovered at 60 centimeters below the ground surface, exceeding the depths of the artifacts recovered duri ng the excavations. Therefore, the project site does not retain the unaltered original surface soils from the prehistoric or early historic period.

Within one mile of the project site, the Cultural Report iden tified 36 additional cultural resource studies, from which 10 cultural resources were recorded, including eight prehistoric sites. Most of the prehistoric sites consisted of stone tools, lithic scatters, rock shelters, and quarries. All of the sites were located in the hills on the southwestern side of

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Highway 101. None of the prehistoric sites were found within the vicinity of the project site, and the proposed project would not affect these sites.

Therefore, there are no known historical resources or unique archaeological resources within the project site. However, due to the demonstrated sensitivity of the project site and surrounding area for archaeological remains from the prehistoric period, there is potential for the unanticipated discovery of cultural resources during project construction.

MM-CUL-1 and MM-CUL-2 are required to reduce potential impacts to an archaeological resource qualifying as a historical resource. MM-CUL-1 requires Worker Environm ental Awareness Program training for all construction personnel and monitors prior to the start of construction activities. MM-CUL-2 requires a qualified archaeologist to be present on-site to monitor all ground-disturbing activities. With the implementation of MM-CUL-1 and MM-CUL-2, future development in accordance with the proposed development component would not result in significant impacts on historical resources. Impacts to historical resources would be less than significant with mitigation incorporated.

Additionally, the Cultural Report and Extended Phase I Arch aeological Study that the analysis herein is based on combined the adaptive reuse and outdoor amphitheatre components with the project-level development component; the initial field survey encompassed the entire project area. The Extended Phase I Archaeological Study did not include the portions of the project area proposed for develo pment of the adaptive reuse and outdoor amphitheatre components, as further investigation of these locations was not determined necessary by the Cultural Report. The conclusions of both studies regarding the potential pres ence of historic resources and associated impacts assumed complete implementation of the proposed project. As anal yzed above, the CAP does not warrant consideration as a potential historical resource, and the proposed project, including the adaptive reuse and outdoor amphitheatre components, would result in less than significant impacts on historic resources with the implementation of MM-CUL-1 and MM-CUL-2. Although it is unlikely that undiscovered historic resources may be present within the development footprints of the adaptive reuse and outdoor amphitheatre components, because of the demonstrated sensitivity of the entire project area for cultural resources, MM-CUL-1 and MM-CUL-2 would also be required for the adaptive reuse and outdoor amphitheatre components to reduce potential impacts to historic resources to less than significant.

It is acknowledged that the temporary relocation compon ent could introduce people to off-site locations (within existing permitted office space) within City boundaries at which other cultural resources may be present. However, this component would not result in new development and would be temporary in nature. No construction is proposed off- site. Therefore, the temporary relocation component would not result in impacts on historic resources. Through implementation of MM-CUL-1 and MM-CUL-2, which would be applicable to all construction phases and activities associated with the proposed project, the adaptive reuse and outdoor amphitheatre components would result in less than significant impacts on historic resources.

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MITIGATION MEASURES

PROJECT-LEVEL ANALYSIS
MM-CUL-1 Worker Environmental Awareness Program. Worker Environmental Awareness Program (WEAP) training shall be provided to all construction personnel and monitors who are not trained archaeologists prior to the start of construction activities. A basic presentation and handout or pamphlet shall be prepared to ensure proper iden tification and treatment of inadvertent cultural resource discoveries. The purpose of the WEAP training is to provide specific details on the kinds of cultural materials, both prehistoric and historic, that may be identified during construction of the project and explain the importance of and legal basis for the protection of cultural resources. Each worker shall also be provided with the proper procedures to follow in the event that cultural resources or human remains are discovered during ground-disturbing activities. These procedures include work curtailment or redirection, and the immediate notification of the site supervisor and the qualified archaeological and Native American monitors. If the discovery is Native American, a Native American monitor shall be notified. The Applicant shall ensure that construction personnel are made available for and attend the training and retain documentation demonstrating attendance.

MM-CUL-2 Unanticipated Discovery of Cultural Resources. The project applicant shall retain a qualified archaeologist who meets the Secretary of the Inte rior’s Professional Qualifications Standards for archaeology and has experience in California prehisto ric and historic resources, prior to the start of any earthwork activities related to project construction, to monitor all ground-disturbing activities within the areas of native soil (i.e., below existing areas of artificial fill from previous construction). In the event that potential prehisto ric or historic-era archaeological resources (sites, features, or artifacts) are exposed during construction activities for the project, all construction work occurring within a 50-foot buffer of the find shall immediately stop, and a qualified archaeologist must be notified immediately to assess the significance of the find and determine whether or not additional study is warranted. Depending on the significance of the find under the California Environmental Quality Act (CEQA), the archaeologist may simply reco rd the find and allow work to continue. If the discovery proves significant under CEQA, additional work (e.g., preparation of an archaeological treatment plan, testing, or data recovery) may be warranted. If it is determined that the discovered archaeological resource constitutes a significant resource, avoidance and preservation in place is the preferred manner of mitigation. Preservation in place may be accomplished by, but is not limited to, avoidance, incorporating the resource into open space, capping, or deeding the site into a permanent conservation easement. If Native American resource s are discovered or are suspected, each of the consulting tribes for the project shall be notified, as dictated by California Health and Safety Code Section 7050.5, California Public Resources Code Section 5097.98, and CEQA Guidelines Section 15064.5(e). An archaeological monitoring report shall be prepared within 60 days following completion of ground disturbance and submitte d to the City of Thousand Oaks Community Development Director for review. This report shall document compliance with approved mitigation, document the monitoring efforts, and include an appendix with daily monitoring logs. The final report shall be submitted to the South-Central Coastal Information Center and interested consulting tribes.

PROGRAMMATIC-LEVEL ANALYSIS
MM-CUL-1 and MM-CUL-2 are also applicable to the adaptive reuse and outdoor amphitheatre components due to the demonstrated sensitivity of the entire project area to contain cultural resources.

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mitigation measures above. Upon implementation of the required mitigation measures, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

Impact CUL-2 The proposed project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5.

Applicable Threshold of Significance: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is include d in Draft EIR Section 5.4, Cultural Resources, and in particular, starting on page 5.4-24 and concluding on page 5.4-26 of the Draft EIR.

Project-Level Analysis
Only one known archaeological resource was identified within the project site as a result of the Cultural Report. Site 56-000654 overlaps the project site boundary. However, as described above, the Extended Phase I Archaeological Study determined that the artifacts discovered within Site 56 -000654 do not qualify as “unique archaeological resources” pursuant to CEQA. No “unique archaeological resources” are known to be present within the project site. No additional archaeological resources were identified within or immediat ely adjacent to the project site. Previous grading of the project site to develop the CAP complex and the commercial buildings located in the northwestern portion of the project site removed native soils that would have the potential to contain intact archaeological deposits. Additionally, during the development of the CAP complex, mitigative data recovery was conducted to remove artifacts from the site.

The Extended Phase I Archaeological Study also determined that the portion of the project area located in the northwest corner of the site, west of Dallas Drive, which appears to be less disturbed upon surface observation, has undergone substantial past disturbance and does not retain the unalte red original surface soils from the prehistoric period. As such, the likelihood of encountering intact archaeological de posits that qualify as unique archaeological resources during project implementation is low. Nonetheless, should project-related ground disturbing activities encounter subsurface archaeological deposits that qualify as unique archaeological resources, the project could cause a substantial adverse change in the significance of an archaeological resource. Implementation of MM-CUL-1 and MM-CUL-2 would reduce potential impacts on unknown archaeological deposits to less than significant.

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components, as further investigation of these locations was not determined necessary by the Cultural Report. The conclusions of both studies regarding the potential pres ence of archaeological resources and associated impacts assumed complete implementation of the proposed project. As analyzed above, the proposed project, including the adaptive reuse and outdoor amphitheatre components, would result in less than significant impacts on archaeological resources with the implementation of MM-CUL-1 and MM-CUL-2. Although it is unlikely that undiscovered archaeological resources may be present within the development footprints of the adaptive reuse and outdoor amphitheatre components, because of the demonstrated sensitivity of the entire project area for cultural resources, MM-CUL-1 and MM-CUL-2 would also be required for the adaptive reuse and outdoor amphitheatre components to reduce potential impacts to archaeological resources to less than significant.

It is acknowledged that the temporary relocation component could introduce people to off-site locations (within existing permitted office space) within City boundaries at which other cultural resources may be present. However, this component would not result in new development and would be temporary in nature. No construction is proposed off- site. Therefore, the temporary relocation component would not result in impacts on archaeological resources. Through implementation of MM-CUL-1 and MM-CUL-2, which would be applicable to all construction phases and activities associated with the proposed project, the adaptive reuse and outdoor amphitheatre components would result in less than significant impacts on archaeological resources.

MITIGATION MEASURES

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preferred manner of mitigation. Preservation in place may be accomplished by, but is not limited to, avoidance, incorporating the resource into open space, capping, or deeding the site into a permanent conservation easement. If Native American resources are discovered or are suspected, each of the consulting tribes for the project shall be notified, as dictated by California Health and Safety Code Section 7050.5, California Public Resources Code Section 5097.98, and CE QA Guidelines Section 15064.5(e). An archaeological monitoring report shall be prepared within 60 days following completion of ground disturbance and submitte d to the City of Thousand Oaks Community Development Director for review. This report shall document compliance with approved mitigation, document the monitoring efforts, and include an appendix with daily monitoring logs. The final report shall be submitted to the South-Central Coastal Information Center and interested consulting tribes.

Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measures above. Upon implementation of the required mitigation measures, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

Cumulative Impacts The proposed project, combined with other cumulative projects, would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5.

CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” The cumulative analysis below considers the proposed project’s impacts in conjunction with the future buildout of the General Plan and cumulative projects listed in Draft EIR Table 4-1, Cumulative Projects List.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.4, Cultural Resources, and in particular, on page 5.4-27 of the Draft EIR.

Cumulative projects developed in the vicinity of the project site have the potential to result in cumulatively considerable impacts on historical resources. However, impacts on cult ural resources are generally site-specific. Similar to the proposed project, related cumulative projects would be re quired to undergo project-specific environmental review under CEQA and the lead agency’s discretionary review pr ocess to determine potential impacts based on project- specific ground-disturbing activities.

As summarized above, there are no known historical resources located on the project site. The existing buildings at the project site do not qualify as “historical resources” pursuant to CEQA. Additionally, the Extended Phase I Archaeological Study determined that archaeological Site 56-000654 does not contain known historical resources within the project site. However, due to the demonstrated sensitivity of the project site for cultural resources, MM-CUL-1 and MM-CUL- 2 are required to reduce potential impacts to historical reso urces to less than significant. Thus, the proposed project would not contribute to a cumulatively considerable impact. Cumulative impacts would be less than significant.

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MITIGATION MEASURES
MM-CUL-1 Worker Environmental Awareness Program. Worker Environmental Awareness Program (WEAP) training shall be provided to all construction personnel and monitors who are not trained archaeologists prior to the start of construction activities. A basic presentation and handout or pamphlet shall be prepared to ensure proper iden tification and treatment of inadvertent cultural resource discoveries. The purpose of the WEAP training is to provide specific details on the kinds of cultural materials, both prehistoric and historic, that may be identified during construction of the project and explain the importance of and legal basis for the protection of cultural resources. Each worker shall also be provided with the proper procedures to follow in the event that cultural resources or human remains are discovered during ground-disturbing activities. These procedures include work curtailment or redirection, and the immediate notification of the site supervisor and the qualified archaeological and Native American monitors. If the discovery is Native American, a Native American monitor shall be notified. The Applicant shall ensure that construction personnel are made available for and attend the training and retain documentation demonstrating attendance.

MM-CUL-2 Unanticipated Discovery of Cultural Resources. The project applicant shall retain a qualified archaeologist who meets the Secretary of the Inte rior’s Professional Qualifications Standards for archaeology and has experience in California prehisto ric and historic resources, prior to the start of any earthwork activities related to project construction, to monitor all ground-disturbing activities within the areas of native soil (i.e., below existing areas of artificial fill from previous construction). In the event that potential prehisto ric or historic-era archaeological resources (sites, features, or artifacts) are exposed during construction activities for the project, all construction work occurring within a 50-foot buffer of the find shall immediately stop, and a qualified archaeologist must be notified immediately to assess the significance of the find and determine whether or not additional study is warranted. Depending on the significance of the find under the California Environmental Quality Act (CEQA), the archaeologist may simply reco rd the find and allow work to continue. If the discovery proves significant under CEQA, additional work (e.g., preparation of an archaeological treatment plan, testing, or data recovery) may be warranted. If it is determined that the discovered archaeological resource constitutes a significant resource, avoidance and preservation in place is the preferred manner of mitigation. Preservation in place may be accomplished by, but is not limited to, avoidance, incorporating the resource into open space, capping, or deeding the site into a permanent conservation easement. If Native American resourc es are discovered or are suspected, each of the consulting tribes for the project shall be notified, as dictated by California Health and Safety Code Section 7050.5, California Public Resources Code Section 5097.98, and CE QA Guidelines Section 15064.5(e). An archaeological monitoring report shall be prepared within 60 days following completion of ground disturbance and submitted to the City of Thousand Oaks Community Development Director for review. This report shall document compliance with approved mitigation, document the monitoring efforts, and include an appendix with daily monitoring logs. The final report shall be submitted to the South-Central Coastal Information Center and interested consulting tribes.

Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measures above. Upon implementation of the required mitigation measures, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

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Cumulative Impacts The proposed project, combined with other cumulative projects, would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.4, Cultural Resources, and in particular, on pages 5.4-27 and 5.4-28 of the Draft EIR.

Cumulative projects developed in the vicinity of the project site have the potential to result in cumulatively considerable impacts on archaeological resources. However, impacts on cultural resources are generally site-specific. Similar to the proposed project, related cumulative projects would be re quired to undergo project-specific environmental review under CEQA and the lead agency’s discretionary review pr ocess to determine potential impacts based on project- specific ground-disturbing activities.

As summarized above, there are no known archaeological resources located on the project site. The Extended Phase I Archaeological Study determined that archaeological Site 56-000654 does not contain known, unique archaeological resources within the project site. However, due to the demonstrated sensitivity of the project site for cultural resources, MM-CUL-1 and MM-CUL-2 are required to reduce potential impacts to archaeological resources to less than significant.

Thus, the proposed project would not contribute to a cumulatively considerable impact. Cumulative impacts would be less than significant.

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treatment plan, testing, or data recovery) may be warranted. If it is determined that the discovered archaeological resource constitutes a significant resource, avoidance and preservation in place is the preferred manner of mitigation. Preservation in place may be accomplished by, but is not limited to, avoidance, incorporating the resource into open space, capping, or deeding the site into a permanent conservation easement. If Native American resources are discovered or are suspected, each of the consulting tribes for the project shall be notified, as dictated by California Health and Safety Code Section 7050.5, California Public Resources Code Section 5097.98, and CE QA Guidelines Section 15064.5(e). An archaeological monitoring report shall be prepared within 60 days following completion of ground disturbance and submitted to the City of Thousand Oaks Community Development Director for review. This report shall document compliance with approved mitigation, document the monitoring efforts, and include an appendix with daily monitoring logs. The final report shall be submitted to the South-Central Coastal Information Center and interested consulting tribes.

Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measures above. Upon implementation of the required mitigation measures, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

Geology and Soils
Impact GEO-1 The proposed project would not directly or indirectly cause potential substantial adverse effects involving seismic-related hazards.

Applicable Threshold of Significance: 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 a nd Geology Special Publication 42; ii) strong seismic ground shaking; iii) seismic-related ground failure, including liquefaction; iv) or landslides? Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.6, Geology and Soils, and in particular, starting on page 5.6-10 and concluding on page 5.6-12 of the Draft EIR.

Draft EIR Section 5.6 is based in part on the Preliminary Geotechnical Investigation, Civic Arts Plaza Master Plan, City of Thousand Oaks, 2100 Thousand Oaks Blvd, Thousand Oaks, California 91362 (Geotechnical Investigation), prepared by Cotton, Shires, and Associates, Inc. (CSA), dated May 2025. A complete copy of this technical study is included in Draft EIR Appendix H, Geotechnical Investigation.

Project-Level Analysis
Rupture of a Known Fault
As indicated in Draft EIR Section 5.6.1, the project site is not located in an Alquist-Priolo Earthquake Fault Zone. No active surface faults are mapped across the site. Further, no evidence of active faulting was observed at the project site during the field investigation conducted as part of the Geotechnical Investigation. As such, the probability of fault rupture is considered low. Less than significant impacts would occur in this regard.

Ground Shaking
Although the development component would introduce new buildings and associated residents, visitors, and workers, the development component would not exacerbate ground shaking on-site or in the project area. The Southern California region regularly experiences seismic activity. As indicated in Draft EIR Section 5.6.1, the primary seismic

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hazard at the site is the potential for moderate to severe ground shaking in response to large-magnitude earthquakes generated during the lifetime of the development component. However, the risk of strong ground motion is common to all construction in the Southern California region and is typically mitigated through building design in accordance with the CBC.

As part of the Geotechnical Investigation, a site-specific ground motion hazard analysis was performed in accordance with ASCE 7-22 to obtain site-specific seismic design ac celeration parameters, the risk-targeted maximum considered earthquake response spectrum, and the design earthquake response spectrum. The site-specific seismic design parameters are presented in Table 3, 2022 CBC Seismic Design Criteria, of the Geotechnical Investigation. These design requirements would minimize the potential for building collapse and general building damage during seismic ground shaking. The project would be required to comply with the CBC, which includes earthquake safety standards based on a variety of factors, including occupancy type, types of soils and rocks on-site, and strength of probable ground motion at the project site. In accordance with the CBC and Municipal Code Title 8, Chapter 1, the project would be required to demonstrate compliance with the site-specific design recommendations identified in the Geotechnical Investigation to minimize the potential for damage and major injury during a seismic event; refer to MM-GEO-1. Implementation of MM-GEO-1 would ensure the construction and design recommendations presented in the Geotechnical Investigation are incorporated into the project design and grading an d building plans. Following compliance with the CBC and Municipal Code as well as implementation of MM-GEO-1, im pacts related to strong seismic ground shaking would be reduced to less than significant levels.

Seismic-Related Ground Failure Including Liquefaction
The Geotechnical Investigation concluded that liquefaction is not considered a significant hazard at the project site; thus, less than significant impacts would occur in this regard.

Landslides
The potential for landslides to occur at the project site is considered low, given that the project site is not located within an Earthquake-Induced Landslide Hazard Zone, and no eviden ce of landslides was observed during the field survey associated with the Geotechnical Investigation. As such, impacts would be less than significant in this regard.

However, this component would not result in new development or significant additional employees exceeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off- site. Therefore, the temporary relocation would not result in impacts on seismic-related hazards.

In accordance with the CBC and Municipal Code Title 8, Chapter 1, the adaptive reuse and outdoor amphitheatre components would be required to demonstrate compliance with the site-specific design recommendations identified in the Geotechnical Investigation to minimize the potential for damage and major injury during a seismic event; refer to MM-GEO-1. Implementation of MM-GEO-1 would ensure the construction and design recommendations presented in the Geotechnical Investigation are incorporated into the project design and grading and building plans. Following compliance with the CBC and Municipal Code as well as implementation of MM-GEO-1, impacts related to seismic- related hazards, including strong seismic ground shaking, would be reduced to less than significant levels.

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MITIGATION MEASURES

PROJECT-LEVEL ANALYSIS
MM-GEO-1 Geotechnical Investigation Recommendations. Prior to issuance of a grading permit, the project applicant shall demonstrate, to the satisfaction of the City of Thousand Oaks Public Works Department, that the recommendations for design and construction identified in the Geotechnical Investigation, Preliminary Geotechnical Investigation, Civic Arts Plaza Master Plan, City of Thousand Oaks, 2100 Thousand Oaks Blvd, Thousand Oaks, California 91362, prepared by Cotton, Shires, and Associates, Inc., dated May 2025 (Geotechnical Investigation), and subsequent reports/amendments to the Geotechnical Investigation, have been inco rporated into the projec t design, grading, and building plans, as applicable.

PROGRAMMATIC-LEVEL ANALYSIS
MM-GEO-1 is also applicable to the adaptive reuse and outdoor amphitheatre components because they are located on the same project site and are therefore subject to the same seismic hazards.

Impact GEO-3 The proposed project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse.

Applicable Threshold of Significance: 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?
Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.6, Geology and Soils, and in particular, starting on page 5.6-13 and concluding on page 5.6-14 of the Draft EIR.

Project-Level Analysis
Slope Stability and Landslides
As indicated in Draft EIR Section 5.6.1 and analyzed under Impact GEO-1, the potential for landslides or slope instabilities to occur at the project site is considered low, given that the project site is not located within an Earthquake- Induced Landslide Hazard Zone, and no evidence of landslides was observed during the field survey associated with the Geotechnical Investigation. As such, impacts would be less than significant in this regard.

Subsidence
As indicated in Draft EIR Section 5.6.1, the project site is not located in an area of known subsidence. Nonetheless, the project would be required to demonstrate compliance with the site-specific design recommendations identified in the Geotechnical Investigation to reduce impacts regarding geology and soils. Implementation of MM-GEO-1 would ensure the construction and design recommendations presented in the Geotechnical Investigation are incorporated into the project design and grading and building plans. Following compliance with the CBC and Municipal Code as well as implementation of MM-GEO-1, impacts in this regard would be reduced to less than significant levels.

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Liquefaction and Lateral Spreading
As indicated in Draft EIR Section 5.6.1, the site is not lo cated within a State-Designated Liquefaction Hazard Zone.

Subsurface conditions encountered during the Geotechnical Investigation indicate that conditions encountered by other previous studies in proximity to the project site genera lly consist of medium dense and stiff native alluvial soils with moderately plastic fines overlying bedrock with variable depths of perched groundwater within the native soils.

Based on these conditions, the Geotechnical Investigation co ncluded that liquefaction is not considered a significant hazard at the project site. Nonetheless, the project would be required to demonstrate compliance with the site-specific design recommendations identified in the Geotechnical Investigation to reduce impacts regarding geology and soils.

Implementation of MM-GEO-1 would ensure the construc tion and design recommendations presented in the Geotechnical Investigation are incorporated into the project design and grading and building plans. Following compliance with the CBC and Municipal Code as well as implementation of MM-GEO-1, impacts in this regard would be reduced to less than significant levels.

Ground Settlement and/or Collapse
As indicated in Draft EIR Section 5.6.1, the project site is not considered susceptible to ground settlement. Nonetheless, the project would be required to demonstrate compliance with the site-specific design recommendations identified in the Geotechnical Investigation to reduce impacts regard ing geology and soils. Implementation of MM-GEO-1 would ensure the construction and design recommendations presented in the Geotechnical Investigation are incorporated into the project design and grading and building plans. Following compliance with the CBC and Municipal Code as well as implementation of MM-GEO-1, impacts in this regard would be reduced to less than significant levels.

It is acknowledged that the temporary relocation component could introduce people to off-site locations (within existing permitted office space) within City boundaries that are closer to areas with additional unstable geologic units or soils. However, this component would not result in new development or significant additional employees exceeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off-site. Therefore, the temporary relocation component would not result in impacts related to unstable geologic units or soils.

In accordance with the CBC and Municipal Code, the adaptive reuse and outdoor amphitheatre components would be required to demonstrate compliance with the site-specific design recommendations identified in the Geotechnical Investigation to reduce impacts regarding geology and soils; refer to MM-GEO-1. Implementation of MM-GEO-1 would ensure the construction and design recommendations presented in the Geotechnical Investigation are incorporated into the project design and grading and building plans. Following compliance with the CBC and Municipal Code as well as implementation of MM-GEO-1, impacts related to unstab le geologic units or soils wo uld be reduced to less than significant levels.

MITIGATION MEASURES

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Investigation, Preliminary Geotechnical Investigation, Civic Arts Plaza Master Plan, City of Thousand Oaks, 2100 Thousand Oaks Blvd, Thousand Oaks, Ca lifornia 91362, prepared by Cotton, Shires, and Associates, Inc., dated May 2025 (Geotechnical Investigation), and subsequent reports/amendments to the Geotechnical Investigation, have been inco rporated into the project design, grading, and building plans, as applicable.

Impact GEO-4 The proposed project would not be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.6, Geology and Soils, and in particular, starting on page 5.6-14 and concluding on page 5.6-15 of the Draft EIR.

Project-Level Analysis
As indicated in Draft EIR Section 5.6.1, on-site soils are anticipated to have low to moderate plasticity; thus, on-site soils would have a moderate expansion potential. Nonetheless, the project would be required to demonstrate compliance with the site-specific design recommendations identified in the Geotechnical Investigation to reduce impacts regarding geology and soils. Implementation of MM-GEO-1 would ensure the construction and design recommendations presented in the Geotechnical Investigation are incorporated into the project design and grading and building plans.

Following compliance with the CBC and Municipal Code as well as implementation of MM-GEO-1, impacts in this regard would be reduced to less than significant levels.

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accounted for with current staffing levels, and would be te mporary in nature. No construction is proposed off-site.

Therefore, the temporary relocation component would not result in impacts related to expansive soils.

In accordance with the CBC and Municipal Code, the adaptive reuse and outdoor amphitheatre components would be required to demonstrate compliance with the site-specific design recommendations identified in the Geotechnical Investigation to reduce impacts regarding geology and soils; refer to MM-GEO-1. Implementation of MM-GEO-1 would ensure the construction and design recommendations presented in the Geotechnical Investigation are incorporated into the project design and grading and building plans. Following compliance with the CBC and Municipal Code as well as implementation of MM-GEO-1, impacts related to expansive soils would be reduced to less than significant levels.

MITIGATION MEASURES

Impact GEO-6 The proposed project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Applicable Threshold of Significance: Directly or indirectly destroy a unique paleontological resource or site, or a unique geologic feature?
Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.6, Geology and Soils, and in particular, starting on page 5.6-16 and concluding on page 5.6-18 of the Draft EIR.

Project-Level Analysis
According to the Geotechnical Investigation, the project site is located within the Transverse Range Geomorphic Province, which is characterized by east-trending ridge and valley sequences, resulting from normal and reversed faulting that uplifted the Santa Ynez and Santa Susana Mountains. More specifically, the project site is underlain by Miocene volcanic conglomerate, which crops out in the hills that make up the southern portion of the site, and Holocene to late-Pleistocene age colluvium and alluvium, which cover the flatter northern half of the site. The Geotechnical

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Investigation indicates that hard to very hard volcanic basalt of the middle Miocene Conejo Volcanics underlies the volcanic conglomerate and colluvial/alluvial soils. As such, on-site soils are considered to have paleontological sensitivity ranging from low (Holocene) to high (late-Pleistocene); refer to General Plan EIR Table 4.8-1.

The proposed project would involve grading and earthwork on-site, which would include 84,900 cubic yards of cut and 29,900 cubic yards of fill, resulting in 55,000 cubic yard s of net export. Due to the scale and depth of the proposed grading and earthwork activities on-site, these activities could occur within areas of high paleontological sensitivity and have the potential to encounter undocumented scientifically significant paleontological resources. Nonetheless, MM- GEO-2 would require paleontological monitoring to be present if project construction occurs at depths that could encounter highly sensitive sediments for paleontological resources. MM-GEO-2 provides procedures for construction workers to follow in the event of any fossil discovery to ensure grading is halted to assess the find for significance and any paleontological finds are properly excavated and preserved. With the implementation of MM-GEO-2, impacts in this regard would be reduced to less than significant levels.

Programmatic-Level Analysis
The analysis provided above for the Project-Level Analysis is also applicable to the adaptive reuse and outdoor amphitheatre components, as it applies to the project site as a whole. There are no unique considerations of the proposed development of the adaptive reuse and outdoor amphitheatre components that would cause different impacts than those already analyzed above. The adaptive reuse and outdoor amphitheatre components are located on the project site, and thus, would be subject to similar areas of high paleontological sensitivity and have the potential to encounter undocumented scientifically significant paleontological resources. MM-GEO-2 would require paleontological monitoring to be present if project construction occurs at depths that could encounter highly sensitive sediments for paleontological resources. MM-GEO-2 provides procedures for construction workers to follow in the event of any fossil discovery to ensure grading is halted to assess the find for significance and any paleontological finds are properly excavated and preserved. With the implementation of MM-GEO-2, impacts in this regard would be reduced to less than significant levels.

It is acknowledged that the temporary relocation component could introduce people to off-site locations (within existing permitted office space) within City boundaries that may have sensitivity to paleontological resources. However, this component would not result in new development or significant additional employees exceeding those already accounted for with current staffing levels, and would be te mporary in nature. No construction is proposed off-site.

Therefore, the temporary relocation component would not result in impacts on paleontological resources.

MITIGATION MEASURES
MM-GEO-2 Technical Paleontological Assessment. Prior to issuance of grading permits, the project applicant shall provide a technical paleontological assessment prepared by a qualified paleontologist, defined as a paleontologist who meets the Society of Vertebrate Paleontology (SVP) standards for a Principal Investigator or Project Paleontologist, assessing the sensitivity of the project site for buried paleontological resources to the City of Thousand Oaks Community Development Department, Planning Division for review and approval.

If resources are known or reasonably anticipated, the assessment shall provide a detailed mitigation plan, including a monitoring program and recovery and/or in situ preservation plan, based on the recommendations of the qualified paleontologist. The mitigation plan shall include, but not be limited to, the following:
x A qualified paleontologist shall be retained for the project and shall be on call during grading and other significant ground-disturbing activities;

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x Should any potentially significant fossil resources be discovered, no further grading shall occur in the area of the discovery until the qualified paleontologist and City of Thousand Oaks Community Development Department, Planning Division concur s in writing that adequate provisions are in place to protect these resources; and
x Unanticipated discoveries shall be evaluated for si gnificance by the qualified paleontologist. If a resource is determined to be significant by th e qualified paleontologist, the resource shall be collected and catalogued in accordance with SVP guidelines and ade quately curated in an institution with appropriate staff and facilities.

A report of findings with an itemized accession inventory shall be prepared as evidence that monitoring has been successfully completed and shall be submitted and approved by the City of Thousand Oaks Community Development Department, Planning Division prior to the granting of occupancy permits.

PROGRAMMATIC-LEVEL ANALYSIS
MM-GEO-2 is also applicable to the adaptive reuse and outdoor amphitheatre components because they are located on the same project site and therefore have the same potential to encounter undiscovered paleontological resources.

Cumulative Impacts The proposed project, combined with other cumulative projects, would not expose people and structures to potential substantial adverse effects involving geology and soils.

CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” The cumulative analysis below considers the proposed project’s impacts in conjunction with the future buildout of the General Plan and cumulative projects listed in Draft EIR Table 4-1, Cumulative Projects List.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is includ ed in Draft EIR Section 5.6, Geology and Soils, and in particular, on page 5.6-18 of the Draft EIR.

Cumulative projects identified in Draft EIR Table 4-1 would be located within proximity to similar soil conditions as the proposed project. However, in the event of an earthquake, the intensity of seismic ground shaking would vary by site based on earthquake magnitude, distance to the epicenter, and geology of the area between the epicenter and the cumulative project sites, and thus geologic hazards would vary accordingly. Similar to proposed/future development within the project site, cumulative projects would be required to comply with existing federal, State, and local regulations regarding geologic hazards (e.g., Earthquake Hazards Reduction Act, Seismic Hazard Mapping Act, NPDES program, CBC, and Municipal Code).

As concluded above, geologic/seismic hazards associated with the proposed project would be less than significant upon implementation of regulatory requirements and MM-GEO-1, which would require the project to demonstrate compliance with the site-specific design recommendations identified in the Geotechnical Investigation to reduce impacts regarding geology and soils. Implementation of MM-GEO-1 would ensure the construction and design

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recommendations presented in the Geotechnical Investigatio n are incorporated into the project design and grading and building plans. Thus, cumulative impacts would be reduced to less than significant levels in this regard.

MITIGATION MEASURES
MM-GEO-1 Geotechnical Investigation Recommendations. Prior to issuance of a grading permit, the project applicant shall demonstrate, to the satisfaction of the City of Thousand Oaks Public Works Department, that the recommendations for design and construction identified in the Geotechnical Investigation, Preliminary Geotechnical Investigation, Civic Arts Plaza Master Plan, City of Thousand Oaks, 2100 Thousand Oaks Blvd, Thousand Oaks, California 91362, prepared by Cotton, Shires, and Associates, Inc., dated May 2025 (Geotechnical Investigation), and subsequent reports/amendments to the Geotechnical Investigation, have been inco rporated into the projec t design, grading, and building plans, as applicable.

Cumulative Impacts The proposed project, combined with other cumulative projects, would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is incl uded in Draft EIR Section 5.6, Geology and Soils, and in particular, on pages 5.6-18 and 5.6-19 of the Draft EIR.

Cumulative impacts to paleontological resources would occur when the impacts of the proposed project, in conjunction with other projects and development in the City, result in cumulatively considerable impacts to paleontological resources. Like the proposed project, the related cumulative projects identified in Draft EIR Table 4-1 could encounter undiscovered paleontological resources where grading occurs in native soils. As concluded in Impact Statement GEO-6, project excavation may extend into deposits with high pale ontological sensitivity and has the potential to encounter undocumented scientifically significant paleontological resources. However, with the implementation of MM-GEO-2, project impacts to paleontological resources would be reduced to less than significant levels.

Thus, the proposed project, combined with other related cumulative projects, would not cause a cumulatively considerable significant impact to previously undiscovered paleontological resources.

If resources are known or reasonably anticipated, the assessment shall provide a detailed mitigation plan, including a monitoring program and recovery and/or in situ preservation plan, based on the

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recommendations of the qualified paleontologist. The mitigation plan shall include, but not be limited to, the following:
x A qualified paleontologist shall be retained for the project and shall be on call during grading and other significant ground-disturbing activities;
x Should any potentially significant fossil resources be discovered, no further grading shall occur in the area of the discovery until the qualified paleontologist and City of Thousand Oaks Community Development Department, Planning Division concur s in writing that adequate provisions are in place to protect these resources; and
x Unanticipated discoveries shall be evaluated for si gnificance by the qualified paleontologist. If a resource is determined to be significant by th e qualified paleontologist, the resource shall be collected and catalogued in accordance with SVP guidelines and ade quately curated in an institution with appropriate staff and facilities.

Greenhouse Gas Emissions
Impact GHG-1 The proposed project would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

Applicable Threshold of Significance: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.7, Greenhouse Gas Emissions, and in particular, starting on page 5.7-22 and concluding on page 5.7-28 of the Draft EIR.

Project-Level Analysis
Construction
The proposed project would involve the demolition of existing commercial retail uses and the construction of a mix of residential and commercial uses. Construction of the proposed project would generate temporary GHG emissions primarily from construction equipment, construction worker trips to and from the project site, and heavy trucks to transport demolition debris, excavated soil, and building materials. Construction GHG emissions are typically summed and amortized over the lifetime of a project (conservatively assumed to be 30 years) and then added to the operational emissions.

The proposed project would be constructed over five phases in approximately five years, beginning in October 2027.

For the GHG emission analysis, the modeling assumed no overlap between each construction phase would occur, with the exception of Phases 2a, 2b, and 2c. Table 5.7-2, Construction Greenhouse Gas Emissions, summarizes the total GHG

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emissions from each phase and the amortized GHG emissions. As shown below, the construction of the proposed project would result in approximately 5,746.70 MTCO 2e of GHG emissions. Amortized over a 30-year period 5, the proposed project would generate 191.56 MTCO2e per year of GHG emissions.

Operation
As discussed, Phase 1 would be completed and operational prior to any subsequent phase (i.e., Phase 2a, Phase 2b, etc.). Phase 2a through Phase 2c has the potential to construct simultaneously and as such, would potentially start operations simultaneously. Operation of Phase 3 would occur after Phase 2a through 2c are operational. It should be noted that Phase 1 would involve construction of linear roadway and infrastructure improvements and would not involve any operational GHG emissions. Annual operational emissions and amortized construction emissions for each phase (Phases 2a, 2b, 2c and 3) of the proposed project are presented in Draft EIR Table 5.7-3, Unmitigated Project Operational Energy Consumption.

As shown in Draft EIR Table 5.7-3, at full buildout, the total amount of project-related unmitigated GHG emissions from direct and indirect sources combined would result in approximately 7,553.03 MTCO 2e per year. As previously stated, the City has not adopted a numerical significance threshold for assessing impacts related to GHG emissions, nor have the VCAPCD, CARB, or any other State or regional agency adopted a numerical significance threshold for assessing GHG emissions that is applicable to the project.

It should be noted that the proposed project would implement MM-AQ-2 and MM-AQ-3 to further reduce operational criteria pollutant emissions and are applicable to the proposed project. MM-AQ-2 requires the project to use low-VOC cleaning materials and paints during architectural coating, and MM-AQ-3 would require the project to use all electric landscaping equipment. Annual operational emissions and amortized construction emissions for each phase (Phases 2a, 2b, 2c, and 3) of the proposed project are presented in Draft EIR Table 5.7-4, Mitigated Project Operational Energy Consumption.

As shown in Draft EIR Table 5.7-4, at full buildout, the total amount of project-related mitigated GHG emissions from direct and indirect sources combined would result in approximately 7,428.01 MTCO 2e per year. As previously stated, the City has not adopted a numerical significance threshold for assessing impacts related to GHG emissions, nor have the VCAPCD, CARB, or any other State or regional agency adopted a numerical significance threshold for assessing GHG emissions that is applicable to the project. As such, pe r the Impact Statement GHG-2, below, the proposed project would not have a significant impact on emissions, since the proposed project would be consistent with applicable measures in the 2024-2050 RTP/SCS, 2022 Scoping Plan, and the General Plan. Impacts in this regard would be less than significant.

However, the Project -Level Analysis applies to the adaptive reuse and outdoor amphitheatre components because these activities would involve similar construction methods, equipment, and exposure conditions, and would be subject to similar mitigation measures requirements during operation. Impacts would be less than significant with mitigation incorporated.

5 South Coast Air Quality Management District, Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans, December 5, 2008.

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It is acknowledged that the temporary relocation component could introduce people to off-site locations (within existing permitted office space) within City boundaries. However, this component would not result in new development or significant additional employees exceeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off-site. Therefore, the temporary relocation component would not result in impacts related to GHG emissions.

MITIGATION MEASURES

PROJECT-LEVEL ANALYSIS
MM-AQ-2 Prior to the issuance of a building permit, the Applicant shall demonstrate that the project’s architectural coatings will be “Super Compliant” or have a volatile organic compound (VOC) standard of less than 10 grams per liter.

MM-AQ-3 Any development agreement or long-term lease ag reement associated with any building within the project site, and in which the City is party, shall require all landscaping equipment used on public landscape areas to utilize 100 percent electric landscaping equipment (e.g., lawnmowers, leaf blowers, hedge trimmers). In addition, for any areas within the project site that are maintained by the City, the City shall utilize 100 percent electric landscaping equipment. All properties shall be equipped with exterior electrical outlets to accommodate the landscape equipment requirement. Provision of such electrical requirements shall be checked by the City of Thousand Oaks Building Division prior to building permit or electrical permit issuance.

PROGRAMMATIC-LEVEL ANALYSIS
MM-AQ-2 and MM-AQ-3 are also applicable to the adaptive reuse and outdoor amphitheatre components because they would involve similar construction methods, equipment, and exposure conditions.

Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measures above. Upon implementation of the required mitigation measures, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

Noise
Impact NOI-1 The proposed project would not generate 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.

Applicable Threshold of Significance: 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?
Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.11, Noise, and in particular, starting on page 5.11-19 and concluding on page 5.11.36 of the Draft EIR.

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Project-Level Analysis
Construction
Typical activities associated with construction are highly noticeable temporary noise sources. Noise from construction activities is generated by two primary sources: (1) the transport of workers and equipment/materials to construction sites and (2) the noise related to active construction equipment. These noise sources can be a nuisance to local residents and businesses or, in some cases, unbearable to sensitive receptors (i.e., residences, hospitals, senior centers, schools, day care facilities, etc.).

The effects of construction noise largely depend on the type of construction activities occurring on any given day, noise levels generated by those activities, distances to noise-sensitive receptors, and the existing ambient noise environment in the receptor’s vicinity. Construction generally occurs in several discrete construction phases, with each phase requiring different equipment with varying noise characteristics. Construction noise levels in the project vicinity would fluctuate depending on the type, number, and duration of usage for the varying equipment. These phases alter the characteristics of the noise environment generated on the proposed project site and in the surrounding community for the duration of the construction process. As discussed above, the proposed project would be constructed in phases (Phase 1 through Phase 3), and certain phases would have the potential to occur simultaneously (Phase 2a through Phase 2c). The following evaluation analyzes the construction noise generated by each phase.

Construction noise levels are to be quantified and compared against the City’s construction noise standards. As such, the project would result in a significant impact if project-related construction activities' noise exceeds construction noise standard of 80 dBA L eq at residential receptors and if construction occurs outside of the permissible hours as outlined in Municipal Code Section 8-11.01.

Construction activities associated with Phase 1 would include the following construction phases:
x Linear, Grading and Excavation;
x Linear, Demolition, Utilities, and Sub-Grade;
x Linear, Paving;
x Demolition; and
x Grading.

According to the FTA Transit Noise and Vibration Impact Assessment Manual General Noise Assessment methodology, noise can be considered as concentrated at the center of a project site. Due to the nature of Phase 1 (linear improvements), construction activities would be spread throughout the project site. As such, the estimated noise levels were calculated from the center of the project site. The closest sensitive receptor to the center of the project site is the single-family residential uses adjacent to the project site to the west. As such, the geographic center of the project site is approximately 490 feet from the nearest commercial us e to the northwest and approximately 550 feet away from the nearest residential sensitive receptor. The estimated construction noise levels at the nearest receptors are presented in Draft EIR Table 5.11-7, Phase 1 Construction Noise Levels at the Nearest Receptors. To present a conservative impact analysis, the estimated noise levels were calculated for a scenario in which all heavy construction equipment was assumed to operate simultaneously. It should be noted that RCNM models equipment noise with an

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acoustic usage factor, which accounts for the percentage of time during construction that equipment would operate at full power.6
As shown in Draft EIR Table 5.11-7, construction-generated noise levels would range from 64.0 dba Leq to 68.3 dba Leq at the nearest sensitive residential receptor, located approximately 550 feet to the west of the geographical center of the project site. Additionally, construction-generated noise levels would range from 65.1 dba Leq to 69.3 dba Leq at the nearest commercial structure to the northwest. It should be noted that modeling of construction noise levels in table

5.11-7 assumes that construction equipment would operate simultaneously and represent a worse-case scenario. At the distances of 550 feet and 490 feet, construction-related noise associated with Phase 1 would not exceed the city’s daytime construction noise threshold of 80 dba Leq for residential uses and 85 dba Leq for commercial uses, respectively; refer to Draft EIR Table 5.11-5. Additionally, Phase 1 construction activities would comply with the city’s permitted hours of construction between 7:00 a.m. and 7:00 p.m., Monday through Saturday, pursuant to Municipal Code Section 8-11.01.

Therefore, Phase 1 construction noise levels would not exceed the applicable construction noise threshold and would comply with the permitted hours of construction; construction-related noise impacts associated with Phase 1 would be less than significant.

Phase 2a
Phase 2a would involve the construction of three building s (Buildings E1 through E3), installation of roadway improvements, excavation for subterranean and podium garage foundations, and installation of utility infrastructure connections. Construction activities associated with Phase 2a would include the following construction phases:
x Grading;
x Building Construction;
x Paving; and
x Architectural Coating.

The closest sensitive residential receptor to the Phase 2a construction site is the single-family residential uses adjacent to the project site to the west, approximately 350 feet from the center of the Phase 2a construction activities. The closest commercial use is the existing commercial bu ilding located at 1868 Thousand Oaks Boulevard, located approximately 250 feet away from the center of the Phase 2a construction activities. The estimated construction noise levels at these nearest receptors are presented in Draft EI R Table 5.11-8, Phase 2a Construction Noise Levels at the Nearest Receptors.

As shown in Draft EIR Table 5.11-8, construction-generated noise levels would range from 56.8 dBA Leq to 71.3 dBA Leq at the nearest sensitive residential receptor, and construction-generated noise levels would range from 59.7 dBA Leq to

74.2 dBA Leq at the nearest commercial receptor. It should be note d that the modeling of construction noise levels in Table 5.11-8 assumes that construction equipment would operate simultaneously and represent a worst-case scenario.

At the distances of 350 feet and 250 feet, construction-rel ated noise associated with Phase 2a would not exceed the City’s daytime construction noise threshold of 80 dBA L eq for residential uses and 85 dBA L eq for commercial uses, respectively; refer to Draft EIR Table 5.11-5. Additionally, Phase 2a construction activities would comply with the City’s permitted hours of construction between 7:00 a.m. and 7:00 p.m., Monday through Saturday, pursuant to Municipal Code Section 8-11.01.

Additionally, construction activities associated with Phase 2a have the potential to overlap. Draft EIR Table 5.11-8 presents the approximate noise levels during overlapping co nstruction activities (i.e., building construction, paving,

6 Federal Highway Administration, FHWA Roadway Construction Noise Model User’s Guide, https://www.fhwa.dot.gov/environment/noise/construction_noise/rcnm/rcnm.pdf. Accessed October 9, 2025.

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architectural coating, etc.). As shown in Draft EIR Table 5.11-8, construction-related noise would be approximately 70.9 dBA Leq and 73.8 dBA Leq at the nearest residential and commercial receptors, respectively, and would not exceed the City’s daytime construction noise threshold of 80 dBA Leq for residential uses and 85 dBA Leq for commercial uses.

Therefore, Phase 2a construction noise levels would not exceed the applicable construction noise threshold and would comply with the permitted hours of construction; construction-related noise impacts associated with Phase 2a would be less than significant.

Phase 2b
Phase 2b entails construction of the proposed Carpenter Park and its associated amenities, Building B1 (i.e., the Park Restaurant), and new frontage improvements along Thousand Oaks Boulevard. Construction activities associated with Phase 2b would include the following construction phases:
x Grading;
x Building Construction;
x Paving; and
x Architectural Coating.

The closest sensitive residential receptors to the Phase 2b construction site are the existing townhomes to the north, approximately 420 feet from the center of the Phase 2b co nstruction activities. The closest commercial use is the restaurant building located at 2087 Thousand Oaks Boulevard to the north, approximately 200 feet from the center of the Phase 2b construction activities. The estimated construction noise levels at these nearest receptors are presented in Draft EIR Table 5.11-9, Phase 2b Construction Noise Levels at the Nearest Receptors.

As shown in Draft EIR Table 5.11-9, construction-generated noise levels would range from 55.2 dBA Leq to 67.4 dBA Leq at the nearest sensitive residential receptor, and construction-generated noise levels would range from 61.6 dBA Leq to

73.8 dBA Leq at the nearest commercial structure. It should be noted that the modeling of construction noise levels in Draft EIR Table 5.11-9 assumes that construction equipment would operate simultaneously and represent a worst-case scenario. At the distances of 420 feet and 200 feet, constr uction-related noise associated with Phase 2b would not exceed the City’s daytime construction noise threshold of 80 dBA Leq for residential uses and 85 dBA Leq for commercial uses, respectively; refer to Draft EIR Table 5.11-5. Additionally, Phase 2b construction activities would comply with the City’s permitted hours of construction between 7:00 a.m. and 7:00 p.m., Monday through Saturday, pursuant to Municipal Code Section 8-11.01.

Additionally, construction phases of Phase 2b have the potential to overlap. Draft EIR Table 5.11-9 presents the approximate noise levels during overlapping construction phases (i.e., building construction, paving, architectural coating, etc.). As shown in Draft EIR Table 5.11-9, construction-related noise would be approximately 68.3 dBA L eq and

74.8 dBA Leq at the nearest residential and commercial receptors, respectively, and would not exceed the City’s daytime construction noise threshold of 80 dBA Leq for residential uses and 85 dBA Leq for commercial uses.

Therefore, Phase 2b construction noise levels would not exceed the applicable construction noise threshold and would comply with the permitted hours of construction; construction-related noise impacts associated with Phase 2b would be less than significant.

Phase 2c
Phase 2c would involve the demolition of approximately 48,000 square feet of an existing building area to construct approximately 80,900 square feet of new floor area. Phase 2c would also include the renovation and adaptive reuse of approximately 33,650 square feet of existing building area. Additionally, Phase 2c would involve the construction of the

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proposed East Main Street, including connections to Lakes Drive and a proposed roundabout between Buildings E1 and E3. Construction activities associated with Phase 2c would include the following construction phases:
x Grading;
x Building Construction;
x Paving; and
x Architectural Coating.

The closest sensitive residential receptors to the Phase 2c co nstruction site are the existing townhomes to the north, approximately 700 feet from the center of the Phase 2c construction activities. The closest commercial receptor is the commercial building to the east, approximately 400 feet from the center of the Phase 2c construction activities. The estimated construction noise levels at these nearest receptors are presented in Draft EIR Table 5.11-10, Phase 2c Construction Noise Levels at the Nearest Receptors.

As shown in Draft EIR Table 5.11-10, construction-generated noise levels would range from 50.8 dBA Leq to 64.4 dBA Leq at the nearest sensitive residential receptor, and construction-generated noise levels would range from 55.6 dBA Leq to

69.3 dBA Leq at the nearest commercial structure. It should be noted that the modeling of construction noise levels in Draft EIR Table 5.11-10 assumes that construction equipm ent would operate simultaneously and represent a worst- case scenario. At the distances of 700 feet and 400 feet, construction-related noise associated with Phase 2c would not exceed the City’s daytime construction noise threshold of 80 dBA Leq for residential uses and 85 dBA Leq for commercial uses, respectively; refer to Draft EIR Table 5.11-5. Additionally, Phase 2c construction activities would comply with the City’s permitted hours of construction between 7:00 a.m. and 7:00 p.m., Monday through Saturday, pursuant to Municipal Code Section 8-11.01.

Additionally, construction phases of Phase 2c have the potential to overlap. Draft EIR Table 5.11-10 presents the approximate noise levels during overlapping construction phases (i.e., building construction, paving, architectural coating, etc.). As shown in Draft EIR Table 5.11-10, construction-related noise would be approximately 63.5 dBA L eq and

68.4 dBA L eq at the residential and commercial receptors, respectively, and would not exceed the City’s daytime construction noise threshold of 80 dBA Leq for residential uses and 85 dBA Leq for commercial uses.

Therefore, Phase 2c construction noise levels would not exceed the applicable construction noise threshold and would comply with the permitted hours of construction; construction-related noise impacts associated with Phase 2c would be less than significant.

Phase 3
Phase 3 involves the construction of a bandshell amphitheatre and associated seating areas, and new pavement/lawn areas on the southeast portion of the project site. Construction activities associated with Phase 3 would include the following construction phases:
x Building Construction;
x Paving; and
x Architectural Coating.

As previously stated, the construction of Phase 3 would be located on the southeast portion of the project site. The closest sensitive residential receptors to the center of the Phase 3 construction activities are the existing townhomes located 750 feet to the north. The nearest commercial re ceptor is the adjacent commercial building to the east, approximately 150 feet away from the center of the Phase 3 construction activities. The estimated construction noise levels at the nearest receptors are presented in Draft EIR Table 5.11-11, Phase 3 Construction Noise Levels at the Nearest Receptors.

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As shown in Draft EIR Table 5.11-11, construction-generated noise levels would range from 50.2 dBA Leq to 60.8 dBA Leq at the nearest sensitive residential receptor, approximately 750 feet to the north of the geographical center of the Phase 3 construction site. Additionally, construction-generated noise levels would range from 64.1 dBA Leq to 74.7 dBA Leq at the nearest commercial structure when measured from the center of the Phase 3 construction site. It should be noted that the modeling of construction noise levels in Draft EIR Table 5.11-11 assumes that construction equipment would operate simultaneously and represents a worst-case scenario. At distances of 750 feet and 150 feet, construction-related noise associated with Phase 3 would not exceed the City’s daytime construction noise threshold of 80 dBA L eq for residential uses and 85 dBA L eq for commercial uses, respectively; refer to Draft EIR Table 5.11-5.

Additionally, Phase 3 construction activities would comply with the City’s permitted hours of construction between 7:00 a.m. and 7:00 p.m., Monday through Saturday, pursuant to Municipal Code Section 8-11.01.

Additionally, the construction phases of Phase 3 have the potential to overlap. Draft EIR Table 5.11-11 presents the approximate noise levels during overlapping construction phases (i.e., building construction, paving, architectural coating, etc.). As shown in Draft EIR Table 5.11-11, construction-related noise would be approximately 63.8 dBA Leq and

77.7 dBA L eq at the residential and commercial receptors, respectively, and would not exceed the City’s daytime construction noise threshold of 80 dBA Leq for residential uses and 85 dBA Leq for commercial uses.

Therefore, Phase 3 construction noise levels would not exceed the applicable construction noise threshold and would comply with the permitted hours of construction; construction-related noise impacts associated with Phase 3 would be less than significant.

Overlapping Project Phases
As discussed, the construction of Phase 1 would be comple ted prior to the construction of any subsequent phases.

Phases 2a through 2c are physically independent from one another but have the potential to be constructed simultaneously. Phase 3 would commence upon the completion of the prior phases. Since the construction of the proposed project (Phase 2a through 2c) would have the potential for overlapping construction activities, the following evaluation quantifies the combined co nstruction-related noise impacts. To present the worst-case scenario, the following evaluation quantifies the simultaneous construction of all three Phase 2 project phases.

According to the FTA Transit Noise and Vibration Impact Assessment Manual General Noise Assessment methodology, noise can be considered as concentrated at the center of the site. As such, the following evaluation utilizes the distance of the center of the overlapping phases (i.e., Phase 2a through 2c) to the closest residential and commercial receptors.

The estimated construction noise levels at the nearest receptors are presented in Draft EIR Table 5.11-12, Overlapping Construction Noise Levels at the Nearest Receptors.

As shown in Draft EIR Table 5.11-12, construction-generated noise levels from the simultaneous construction of Phase 2a through 2c would range from 58.5 dBA Leq to 72.0 dBA Leq at the closest residential receptor and would range from

60.4 dBA Leq to 74.0 dBA Leq at the closest commercial receptor. As such, construction-generated noise levels would not exceed the City’s daytime construction noise threshold for residential (80 dBA L eq) uses and commercial (85 dBA L eq) uses. Furthermore, all construction activities would comply with the City’s permitted hours of construction between 7:00 a.m. and 7:00 p.m., Monday through Saturday, pursuant to Municipal Code Section 8-11.01. Since construction noise levels would not exceed the applicable construction noise threshold and would comply with the permitted hours of construction, construction-related noise impacts from the simultaneous construction of Phases 2a through 2c would be less than significant.

Construction Trips
Construction activities would also caus e increased noise along routes throughout the City due to the movement of equipment and workers, as well as haul trips. According to Caltrans, a doubling of traffic (100 percent increase) on a roadway would result in a perceptible increase in traffic noise levels (3 dBA). As such, a significant impact would occur if construction-related trips doubled existing traffic volumes. As previously discussed, the construction of the proposed

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 65
project would occur in phases. Phase 1 would be completed prior to any subsequent phase (i.e., Phase 2a, Phase 2b, etc.). Phases 2a through 2c have the potential to occur simultaneously, but the construction and operation of these phases would not be physically dependent on one another. Construction of Phase 3 would occur after construction of Phases 2a through 2c is completed. Draft EIR Table 5.11-13, Construction Trips, displays the projected construction trips associated with each phase; refer to Draft EIR Appendix C. It should be noted that to present a conservative analysis, the table displays the maximum daily trips from worker, vendor, and hauling trips for each phase. Additionally, Draft EIR Table 5.11-13 shows the combined maximum daily trips associated with the construction of Phases 2a through 2c, since they may occur simultaneously.

As shown in Draft EIR Table 5.11-13, construction of the proposed project would generate a minimum of 40 trips to a maximum of 1,011 trips per day. Due to the location of the proposed project, construction trips associated with the proposed project would travel along Thousand Oaks Boulevard and then merge onto State Route 23. Additionally, construction trips would also travel along Thousand Oaks Boulevard, Hampshire Road, and then merge onto Highway 101. According to Appendix D, Transportation Memo and Data, of the City of Thousand Oaks General Plan Update 2045 Draft Environmental Impact Report, the roadways have the following existing average daily trips (ADT):
x Thousand Oaks Boulevard between State Route 23 to Rancho Road – 22,990 ADT; x Thousand Oaks Boulevard between Rancho Road to Erbes Road – 26,580 ADT; x Thousand Oaks Boulevard between Erbes Road to Conejo School Road – 21,090 ADT; x Thousand Oaks Boulevard between Conejo School Road to Hampshire Road – 19,710 ADT; and x Hampshire Road between Thousand Oaks Boulevard to Highway 101 – 11,950 ADT.

The maximum number of construction trips associated with the proposed project (1,011 trips) would not double existing traffic volumes along surrounding roadways (i.e., Thousand Oaks Boulevard, Hampshire Boulevard). Since the construction-related trips would not double existing traffic volumes, there would not be a perceptible increase (3 dBA) in traffic noise. Additionally, mobile traffic noise from construction trips would be temporary and would cease upon project completion. Thus, impacts in this regard would be less than significant.

Operation
Based on Draft EIR dĂďůĞථϱ͘ϭϭ-6, the noise significance thresholds become more stringent as the combined existing, project, and cumulative CNEL increases, reflecting increased sensitivity in noisier environments. At CNEL levels below 55 dBA, no increase is considered significant; however, between 55 and 60 dBA, a CNEL increase of 3.0 dBA constitutes a significant impact, while a 1.0 dBA increase represents a substantial contribution to cumulative impacts. In the 60 to 70 dBA range, the thresholds are reduced to 1.5 dBA for significance and 0.5 dBA for substantial contribution, and when CNEL exceeds 70 dBA, even a 1.0 dBA increase is considered significant due to the already elevated noise conditions.

Based on Draft EIR Table 5.11-2, ambient noise levels at the surrounding residential receptors range between approximately 57.5 dBA L
eq to 66.1 dBA Leq. Accordingly, a noise increase would be considered significant if project or cumulative conditions result in an increase of 3.0 dBA at receptors with ambient noise levels between 55 and 60 dBA, or 1.5 dBA at receptors with ambient noise levels between 60 and 70 dBA.

Phase 1
Phase 1 would involve demolition of existing commercial structures, installation of utility improvements (i.e., sewer line installation, stormwater detention facilities and conveyance lines, domestic water lines, etc.), and roadway construction (proposed West Road, Oakwood Drive Extension, Oakwood Drive/West Road roundabout, etc.). Phase 1 land uses (linear improvement and bridge construction) would not require regular maintenance during operation, install new stationary noise sources, or generate additional traffic. As such, the proposed Phase 1 land uses would not generate any new sources of operational noise, and a less than significant impact would occur in this regard.

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Phase 2a
Phase 2a would involve the construction of three building s (Buildings E1 through E3), installation of roadway improvements, excavation for subterranean and podium garage foundations, and installation of utility infrastructure connections. Building E1 would include the construction and operation of a hotel building, Building E2 would include the construction and operation of a seven-story mixed-us e residential building, and Building E3 would include the construction and operation of a four-story mixed-use reside ntial building. As such, operational noise associated with Phase 2a would mainly include noise from the mechanical equipment, such as Heating, Ventilation, and Air Conditioning (HVAC) units, and crowd noise at outdoor gathering areas.

Mechanical Equipment Noise
Typically, mechanical equipment and HVAC units generate noise levels of 66 dBA at 3 feet from the source.7 Based upon the Inverse Square Law, sound levels decrease by 6 dBA for each doubling of distance from the source. 8 The nearest sensitive receptors are the existing residential receptor bu ildings located immediately adjacent to the west of the project site. However, the closest structure to this receptor is Building E2, which would be constructed during Phase 2A of the project and would be located approximately 50 feet away. As previously mentioned, Building E2 is a seven-story mixed-use structure consisting of 161 residential apartments and 8,950 square feet of ground-floor commercial space.

Therefore, mechanical HVAC units noise impacts would be analyzed from Building E2 to the nearest sensitive receptor to the west. Building E1 and E3 would be located further away and would be shielded from the line-of-sight from this existing off-site sensitive receptor to the west.

Due to the size of Building E2, a single central HVAC system would be installed to provide heating and cooling throughout the building. At a distance of 50 feet, HVAC noise from a central HVAC system would be approximately 42 dBA. As shown in Draft EIR Table 5.11-3, ambient noise levels at the residential receptor to the west of the project site are approximately 57.5 dBA Leq. The introduction of noise generated from mechanical noise (42 dBA Leq) would increase ambient noise levels to 57.6 dBA. As such, mechanical noise generated from the proposed project would increase the ambient noise levels by 0.1 dBA and would not exceed the significance threshold of 3.0 dBA. Further, HVAC equipment currently exists on the rooftops of existing buildings, and thus, the project’s HVAC equipment would not represent new noise sources in the project area. As such, impacts would be less than significant in this regard.

Outdoor Activity Areas
Outdoor activity area noise that is typical of residential land uses includes children playing, pets, amplified music, and pool and spa equipment operation. Noise from outdoor activities would primarily occur during the “daytime” activity hours, assuming noise decreases during nighttime hours (e .g., people go to sleep and/or close their windows).

Residential uses include multi-family residential uses in either mixed-use buildings or apartment/multi-family buildings.

The potential noise impacts from such outdoor activity areas would be dependent on various factors, including the type, scale, and intensity of use of such facilities, the orientation of projects in relation to the activity area, the proximity of sensitive receptors, and the background ambient noise le vel. Per Assembly Bill 1307 and Public Resources Code Section 21085, “the effects of noise generated by [residential] project occupants and their guests on human beings is not a significant effect on the environment.”
Crowd Noise
Crowd noise levels associated with Phase 2a operational activities are estimated using published reference sound levels for typical human activity, adjusted for distance attenuat ion and shielding effects. Calculations are intended to represent conservative conditions and are used to assess whether potential noise exposure would exceed applicable operational noise thresholds. Clarifying assumptions regarding reference levels and receptor distances provides clear information and consistency.

7 Elliot H. Berger, Rick Neitzel, and Cynthia A. Kladden, Noise Navigator Sound Level Database with Over 1700 Measurement Values , July 26, 2015.
8 Cyril M. Harris, Noise Control in Buildings, 1994.

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Due to the nature of Phase 2a land uses, outdoor gathering areas would be located throughout the project site. These areas would be accessed by the public and would have the potential to generate crowd noise. Noise generated by groups of people (i.e., crowds) depends on several factor s, including vocal effort, im pulsiveness, and the random orientation of the crowd members. According to Prediction of Crowd Noise, crowd noise is approximately 62 dBA at one meter (i.e., 3.28 feet) from the source.9,10 Noise has a decay rate due to distance attenuation, which is calculated based on the Inverse Square Law. Based upon the Inverse Square Law, sound levels decrease by 6 dBA for each doubling of distance from the source.11 The closest sensitive receptors are the existi ng residential uses located immediately to the west of the project site. However, as previously st ated, the nearest mixed-use building, Building E2, would be located approximately 50 feet away.

At a distance of 50 feet, crowd noise would be approximately 23 dBA L eq. A noise level of approximately 38 dBA L eq would not increase the noise levels above typical ambient noise levels in an urban environment. As shown in Draft EIR Table 5.11-3, ambient noise level at the residential receptor to the west of the project site is approximately 57.5 dBA Leq. As such, the proposed Phase 2a crowd noise levels would not exceed the existing ambient noise levels. Therefore, impacts would be less than significant.

Phase 2b
Phase 2b involves constructing the proposed Carpenter Park and its associated amenities, Building B1, which would be used as a restaurant, and construction of new frontage improvements along Thousand Oaks Boulevard. Carpenter Park would function as a central gathering place and would accommodate community events and civic gatherings. As such, operational noise associated with Phase 2b would mainly include noise from the mechanical equipment, HVAC units on Building B1, and crowd noise at Carpenter Park. The nearest sensitive receptor to the Phase 2b area would be existing townhomes (Sensitive Receptor 2), and an existing senior care facility located approximately 300 feet north of the proposed Building B1 and Carpenter Park, refer to Draft EIR Exhibit 5.11-1.

Mechanical Equipment Noise
As previously stated, typically, mechanical equipment HVAC units generate noise levels of 66 dBA at 3 feet from the source. Based upon the Inverse Square Law, sound levels decrease by 6 dBA for each doubling of distance from the source.12 HVAC units' noise levels at the nearest sensitive receptor to the north (i.e., the existing senior care facility) would be approximately 36 dBA. As shown in Draft EIR Table 5.11-3, ambient noise levels at the senior care facility are approximately 58.4 dBA Leq. The introduction of noise generated from mechanical noise (36 dBA Leq) would not increase the existing ambient noise levels. As such, the mechanical noise generated from the proposed project would not exceed the significance threshold of 3.0 dBA over the existing conditions. Impacts would be less than significant in this regard.

Outdoor Activity Areas
Phase 2b of the proposed project would construct Carpenter Park, which includes a restaurant along the Thousand Oaks Boulevard frontage. Carpenter Park would function as a central gathering place and would accommodate community events and civic gatherings. These areas would be accessed by the public and would have the potential to generate crowd noise. As previously stated, noise generated by groups of people (i.e., crowds) is dependent on several factors, including vocal effort, impulsiveness, and the random orientation of the crowd members. According to Prediction of Crowd Noise, crowd noise is approximately 62 dBA at one meter (i.e., 3.28 feet) from the source. 13, 14

9 Crowd noise is estimated at 60 dBA at one meter (3.28 feet) away for raised normal speaking. This noise level would have a +5 d BA adjustment for the impulsiveness of the noise source, and a -3 dBA adjustment for the random orientation of the crowd members.

Therefore, crowd noise would be approximately 62 dBA at one meter from the source. 10 Hayne, M.J., Prediction of Crowd Noise, November 2006. 11 Ibid.
12 Cyril M. Harris, Noise Control in Buildings, 1994.
13 Crowd noise is estimated at 60 dBA at one meter (3.28 feet) away for raised normal speaking. This noise level would have a +5 dBA adjustment for the impulsiveness of the noise source, and a -3 dBA adjustment for the random orientation of the crowd members.

Therefore, crowd noise would be approximately 62 dBA at one meter from the source. 14 Hayne, M.J., Prediction of Crowd Noise, November 2006.

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Noise has a decay rate due to distance attenuation, which is calculated based on the Inverse Square Law. Based upon the Inverse Square Law, sound levels decrease by 6 dBA for each doubling of distance from the source. 15 The closest sensitive receptor to the proposed Carpenter Park would be existing townhomes (Sensitive Receptor 2) located approximately 300 feet to the north; refer to Draft EIR Exhibit 5.11-1.

At a distance of 300 feet, crowd noise would be approximately 23 dBA L eq. A noise level of approximately 23 dBA L eq
would not increase the noise levels above typical ambien t noise levels in an urban environment. While noise measurements were not taken at the townhomes, noise measurements were taken at the multi-family residential uses and senior care facility to the west and east, respectively, that were similar distances away as the townhomes to the project site. Noise measurements conducted at these receptors indicate that ambient noise levels range from 58.4 to

58.9 dBA Leq; refer to Draft EIR Table 5.11-3. The introduction of noise generated from crowd noise (23 dBA Leq) would not increase the ambient noise levels. As such, crowd noise would not increase ambient noise levels by 3.0 dBA, and impacts would be less than significant in this regard.

Phase 2c
Phase 2c would involve demolishing approximately 48,000 s quare feet of an existing building area to construct approximately 80,900 square feet of new floor area. Phase 2c would also include the renovation and adaptive reuse of approximately 33,650 square feet of existing building area . Due to the nature of Phase 2c, it would not install new stationary noise sources beyond existing conditions. Over all, the proposed Phase 2c would include renovating the existing CAP building and would not generate any new sources of operational noise. Thus, a less than significant impact would occur in this regard.

Phase 3
Phase 3 includes constructing a bandshell amphitheatre, associated seating areas, and new pavement/lawn areas on the southeast portion of the project site. The nearest sensitive receptor would be the existing townhomes (Sensitive Receptor 2), and the senior care facility located approximately 300 feet north of the proposed amphitheatre. It should also be noted that there are existing buildings located between the proposed amphitheatre and the nearest sensitive receptor, which would block the line-of-sight and provide noise shielding by approximately 10 to 15 dBA. 16 Amphitheatre Event Noise
The amphitheatre is expected to host events up to appr oximately 100 times per year, with events that could be scheduled any day of the week during daytime hours. Op erational noise would include noise associated with the speakers and crowd activities during the events. The average noise levels during rock, pop, and hip hop concerts would be approximately 106 dBA at the loudest location (near the speakers).17 For the purposes of this analysis, crowd noise is not evaluated independently, as noise generated by the amplified speaker system represents the primary and controlling source of event -related noise. As previously stated, the near est sensitive receptor would be the existing townhomes (Sensitive Receptor 2), and the senior care facility located approximately 300 feet north of the proposed amphitheatre.

At a distance of 300 feet, the amphitheatre noise levels would be approximately 56 dBA L eq. While noise measurements
were not taken at the townhomes, noise measurements were taken at the multi-family residential uses and senior facility to the west and east, respectively, that were similar distances to the townhomes from the project site. Noise measurements conducted at these receptors indicate that ambient noise levels range from 58.4 to 58.9 dBA Leq; refer to Draft EIR Table 5.11-3. The introduction of noise generated from the proposed amphitheatre (56 dBA Leq) would not

15 Ibid.
16 United States Department of Transportation, Federal Highway Administration, Highway Traffic Noise Analysis and Abatement Policy and Guidance, https://www.fhwa.dot.gov/environMent/noise/regulations_and_guidance/polguide/polguide05.cfm, accessed December 15, 2025.
17 Elliot H. Berger, Rick Neitzel, and Cynthia A. Kladden, Nois e Navigator Sound Level Database with Over 1700 Measurement Values, July 26, 2015.

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increase the ambient noise levels over existing condition s. Furthermore, there are existing commercial buildings between the proposed amphitheatre and the sensitive receptors to the north that would provide additional noise reduction and screening. As such, amphitheatre noise levels would not increase ambient noise levels by 3.0 dBA, and impacts would be less than significant in this regard.

Off-Site Mobile Noise
Roadway segment noise levels for the “Existing” and “Existing with Project” scenarios were compared to evaluate project-related operational mobile noise impacts. According to Draft EIR Table 5.11-14, Existing and Existing With Project Traffic Noise Levels, under the “Existing” scenario, noise levels at 100 feet from the roadway centerline would range from 49.0 dBA to 61.7 dBA CNEL. Existing baseline tr affic noise levels would not be greater than 65 dBA CNEL along the surrounding roadways, such as Thousand Oaks Boulevard and Dallas Drive.

According to Section 5.14, Transportation, of the Draft EIR, the proposed project would generate a total net of 5,876 trips per day after taking into account internal trip credits and deducting trips generated from the existing on-site uses.

However, it should be noted that the proposed project would result in fewer trips along Dallas Drive compared to existing conditions. Under the “Existing with Project” scen ario, noise levels at 100 feet from the roadway centerline would range from 45.9 dBA to 62.3 dBA CNEL. Draft EIR Tabl e 5.11-14 compares the increase in noise levels between the “Existing” scenario and the “Existing With Project” scenario. As shown, the increase in noise levels between the two scenarios would range from 0.0 dBA to 0.7 dBA CNEL. Further, it should be noted that “Existing With Project” scenario noise levels along Dallas Drive (45.9 dBA CNEL) would be less than existing conditions (49.0 dBA CNEL).

Based on Draft EIR dĂďůĞථϱ͘ϭϭ-6, when the resulting combined CNEL at a noise-sensitive land use falls within the 60 to 70ථdBA range, a long-term operational traffic noise impact would be considered significant only if noise levels increase by 1.5ථdBA or greater. As shown in Draft EIR Table 5.11-14, the change in noise levels between the “Existing” scenario and the “Existing With Project” scenario would be less than 1.5 dBA for all roadway segments. Further, “Existing With Project” scenario traffic noise levels would remain below the City’s land use compatibility standards of 65 dBA CNEL at these roadway segments. Therefore, project-related traffic would not result in permanent noise increases that meet or exceed the applicable long-term noise increase thresholds, and long -term operational traffic noise impacts would be less than significant.

Conclusion
In conclusion, both construction and operational noise impacts resulting from the proposed project would be less than significant.

As construction noise levels would remain below applicable significance thresholds, the use of construction noise reduction techniques identified in General Plan Noise Elem ent Policy N-3.2 is not necessary to reduce impacts to be less than significant; however, the measures required by Policy N-3.2 will be applied as standard conditions of approval.

Impacts on On-Site Receptors
Construction Noise Impacts
Since the proposed project would be constructed in various phases, construction activities may impact future sensitive receptors within the project site (i.e., CAP and the proposed hotel and residential uses in Buildings E1 through E3). To present the worst scenario, the construction phase (i.e., bu ilding construction, paving, architectural coating) with the highest potential to generate construction noise from the various phases (i.e., Phase 1, Phase 2a, Phase 2b, etc.) is used to determine potential impacts on on-site sensitive receptors. As previously stated, according to the FTA Transit Noise and Vibration Impact Assessment Manual General Noise Assessment methodology, noise can be considered concentrated at the center of the site. As such, the following construction evaluation uses the distance from the center of each phase to existing and proposed on-site receptors to determine if construction noise exceeds applicable thresholds. Construction noise levels would be quantified and compared against the City’s construction noise standards.

As such, the project would result in a significant impact if project-related construction activities' noise exceeds

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 70
construction noise standard of 80 dBA L eq at residential receptors and 85 dBA L eq at commercial receptors and if construction occurs outside of the permissible hours as outlined in Municipal Code Section 8-11.01.

The estimated construction noise levels at the nearest on-site receptors are presented in Draft EIR Table 5.11-15, Construction Noise Levels at On-Site Receptors. As shown in Draft EIR Table 5.11-15, construction-generated noise levels would range from 73.8 dBA Leq to 77.8 dBA Leq at the on-site receptors (i.e., CAP and proposed hotel use [Building E1]). As discussed above, the noise levels presented in Draft EIR Table 5.11-15 represent a worst-case scenario in which all construction equipment operates simultaneously. Addi tionally, construction-genera ted noise levels would not exceed the City’s daytime construction noise threshold for commercial (85 dBA Leq – CAP) and residential (80 dBA Leq – proposed residential and hotel) uses. All construction acti vities would comply with the City’s permitted hours of construction between 7:00 a.m. and 7:00 p.m., Monday through Saturday, pursuant to Municipal Code Section 8-11.01.

Therefore, construction noise levels would not exceed the applicable construction noise threshold and would comply with the permitted hours of construction. Construction-related noise impacts to on-site receptors would be less than significant in this regard.

Operational Noise Impacts
As previously noted, the proposed project would be constructed in five phases. This section evaluates operational noise impacts for Phases 2a, 2b, 2c, and 3; Phase 1 is excluded be cause it involves only roadway and utility improvements and would not generate operational noise sources. Although Phases 2a, 2b, and 2c could be constructed concurrently, this analysis conservatively assumes sequential completion of each phase to isolate operational impacts. Each subsequent phase introduces new on-site sensitive receptors—such as the CAP, hotel, and mixed-use residential uses— that could be affected by operational noise from later phases. The analysis quantifies potential operational noise levels from project-generated sources (e.g., mechanical equipment, amplified sound, and outdoor activities) using reference noise levels, distance attenuation based on the inverse square law, and shielding assumptions where intervening structures provide line-of-sight obstruction.

Although site-specific noise measurements were not conducted within the project site, representative measurements from nearby locations indicate that ambient noise levels at the project site. Based on Draft EIR Table 5.11-2, measured ambient noise levels at the surrounding receptors range between approximately 57.5 dBA L eq to 66.1 dBA L eq.

Accordingly, a noise increase would be considered significan t if project or cumulative conditions result in an increase of 3.0 dBA at receptors with ambient noise levels between 55 and 60 dBA, or 1.5 dBA at receptors with ambient noise levels between 60 and 70 dBA.

Phase 2a
Phase 2a would introduce three primary structures: Building E1 (hotel), Building E2 (seven-story mixed-use residential), and Building E3 (four-story mixed-use residential). Operational noise sources during this phase would primarily include mechanical equipment such as HVAC units and activity-rel ated noise from outdoor gathering areas associated with these uses. The existing on-site sensitive receptors during Phase 2a operation would be those within the CAP. The nearest building to the existing CAP would be Building E1 and would be located adjacent to the CAP building. Due to the size of Building E1, a single central HVAC system would be installed to provide heating and cooling throughout the building. At a distance of 50 feet, HVAC noise from a central HVAC system would be approximately 42 dBA. Furthermore, HVAC noise is currently present in the project vicinity from existing buildings in the area, and thus, the project would not introduce a new noise source.

CEQA FINDINGS OF FACT DOWNTOWN THOUSAND OAKS PROJECT FINAL ENVIRONMENTAL IMPACT REPORT CSG CONSULTANTS 71
EIR Table 5.11-3. Therefore, operational HVAC noise would be well below existing ambient conditions and is not anticipated to result in a perceptible increase in noise levels at the on-site sensitive receptors.

Phase 2b
Phase 2b would include the development of Carpenter Park and associated amenities, as well as Building B1, which would operate as a park restaurant. Operational noise sources during this phase would primarily consist of mechanical equipment (e.g., HVAC units for the restaurant) and activity-r elated noise from outdoor park uses and dining areas.

Activity-related noise from the park would be intermittent and generally comparable to existing noise levels at the park.

Sensitive receptors during Phase 2b operation would include the CAP and the hotel and residential uses introduced in Phase 2a. The nearest receptors to the Building B1 HVAC units would be those within the existing CAP, located approximately 250 feet away, followed by Building E3, locate d about 300 feet west. At a distance of 250 feet, HVAC noise from a central HVAC system would be approximately 24 dBA.

As previously stated, site-specific noise measurements were not conducted within the project site; representative measurements from nearby locations indicate that ambient noise levels in the vicinity range from 57.5 to 66.1 dBA Leq; refer to Draft EIR Table 5.11-3. Therefore, operational HVAC noise would be well below existing ambient conditions and is not anticipated to result in a perceptible increase in noise levels at the on-site sensitive receptors.

Phase 2c
Phase 2c would involve the temporary relocation of City staff and the demolition and renovation of the existing CAP area. Operational noise sources during this phase would pr imarily consist of mechanical equipment associated with temporary facilities (e.g., HVAC units) and activity-related noise from staff operations. Sensitive receptors during Phase 2c operation would include the hotel (Building E1) and mixed-use residential buildings (E2 and E3) introduced in Phase 2a. The nearest receptor to temporary HVAC units would be the hotel, located approximately 25 feet from the construction and renovation area. However, Phase 2c would not install new stationary noise sources over the existing conditions. As such, the proposed Phase 2c would include renovating the existing CAP building and would not generate any new sources of operational noise, and a less than significant impact would occur in this regard.

Phase 3
Phase 3 would involve the construction and operation of Building B2 (bandshell) and the amphitheatre, which would introduce amplified sound sources associated with live performances and events. As previously stated, the amphitheatre is anticipated to host up to approximately 100 events per year, scheduled on any day of the week during daytime hours. Operational noise sources would include amplified sound from speakers and crowd activities during events. For the purposes of this analysis, crowd noise is not evaluated independently, as noise generated by the amplified speaker system represents the primary and controlling source of event -related noise. Based on reference data for live music performances, average noise levels during rock, pop, and hip hop concerts can reach approximately 106 dBA at the loudest location near the speakers. Sensitive receptors during Phase 3 operation would include the hotel (Building E1), mixed-use residential buildings (E2 and E3), and CAP. The closest receptor is CAP, located immediately adjacent to the amphitheatre area, followed by Carpenter Park located approximately 50 feet to the north, Building E1 located approximately 360 feet to the west, and Building E3 located approximately 415 feet to the northwest. However, Buildings E1 and E3 are not in the direct line of sight of the amphitheatre, as they are shielded by Building C1 (CAP).

Therefore, for the purpose of this analysis, operational noise impacts from the amphitheatre are analyzed at all four on-site receptors.

The estimated amphitheatre noise levels at the nearest on-site receptors are presented in Draft EIR Table 5.11-16, Amphitheatre Noise Levels at On-Site Receptors. Therefore, amphitheatre noise levels have the potential to exceed ambient noise levels at the CAP and Carpenter Park. As such, impacts would be potentially significant.

However, the proposed project would be required to implement MM-NOI-1, which requires preparation of a project-specific detailed noise impact study once the final site plan is confirmed, including final stage location, speaker

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configuration, and event operations. The noise study would evaluate amplified and non-amplified amphitheatre events, assess noise levels at nearby sensitive receptors (including elevated receptors), and confirm compliance with applicable City of Thousand Oaks noise standards. If necessary, the study would identify and require implementation of feasible operational mitigation measures to ensure compliance. Th erefore, with implementation of MM-NOI-1, noise impacts from the proposed amphitheatre on existing on-site receptors would be reduced to a less-than-significant level.

Although implementation of this component could result in a minor, temporary increase in roadway noise levels associated with employee relocation, such increases would be minimal and would not result in significant noise impacts.

Additionally, this component would not result in new development or significant additional employees exceeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off- site. Therefore, the temporary relocation component would not result in impacts related to substantial noise increases.

MITIGATION MEASURES

PROJECT-LEVEL ANALYSIS
MM-NOI-1 To reduce potential noise impacts from amphithe atre events on nearby sensitive receptors, the amphitheatre operator shall prepare a project-specific detailed noise impact study, as follows:

1. Once the detailed site plan is finalized, including the final stage location, speaker configuration, and event operations, a project-sp ecific detailed noise impact study shall be prepared by a qualified acoustical consultant prior to operation of the amphitheatre. The study shall evaluate amplified and non-amplif ied events at the amphitheatre and assess noise levels at all nearby sensitive receptors, including elevated receptors (e.g., upper floors of adjacent buildings), under worst-case operating scenarios.

2. The noise study shall demonstrate compliance with the City of Thousand Oaks General Plan 2045 Noise Element significance criteria for lo ng term operational noise, as identified in Table 5.11-6, including applicable noise increase thresholds at sensitive receptors. If the study identifies exceedances of the applicable significance thresholds, feasible mitigation measures shall be identified and implemented to reduce noise levels to below the applicable thresholds. Such measures may include, but are not limited to, limitations on amplified sound levels, restrictions on hours of operation, limitations on the number of amplified events per month, and/or other operational controls.

3. Any recommended mitigation measures shall be implemented prior to commencement of amphitheatre events and shall be subject to review and approval by the City of Thousand Oaks Planning Division.

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PROGRAMMATIC-LEVEL ANALYSIS
MM-NOI-1 is also applicable to the adaptive reuse and outdoor amphitheatre components because these components would introduce noise sources to nearby sensitive receptors.

Tribal Cultural Resources
Impact TCR-1 The proposed project would not cause a substantial adverse change in the significance of a Tribal Cultural Resource that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).

The proposed project would not cause a substantial adverse change in significance of a Tribal Cultural Resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.

Applicable Threshold of Significance: Would the project cause a substantial adverse change in the significance of a tribal cultural resources, 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: i) 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(k), or ii) A resources determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in Subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.15, Tribal Cultural Resources, and in particular, starting on page 5.15-6 and concluding on page 5.15-9 of the Draft EIR.

Project-Level Analysis
Refer to Impact Statements CUL-1 through CUL-3. As stated, the SLF search did not identify any known tribal cultural resources within the project site. As discussed in Draft EIR Section 5.4, Cultural Resources, there are no historical resources present within the project site. A large archaeological site, identified in the 1970s, is located within the project area, overlaps with the project site, and consists primarily of artifact deposits from a prehistoric Native American village or a seasonal habitation area. The site is designated as Site 56-000654 and covers approximately 20 acres.

Archaeological excavations, testing, and data recovery programs occurred at the project site in 1970, 1986, and 1992, after which it was determined that the salvage excavation s had adequately and completely mitigated any potentially adverse impacts that might occur.

However, during a monitoring program in 2004-2005, additional prehistoric remains were observed which resulted in the site boundary for Site 56-000654 being extended into the proposed project area, including the entire southern portion of the project site and the undeveloped portion of the project site, located north of the parking structure, west

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of Dallas Drive, and south of the commercial buildings located along Thousand Oaks Boulevard. Further archaeological testing and monitoring was recommended to be conducted on the newly incorporated areas in order to detect subsurface archaeological deposits in areas that had not yet been developed by the original CAP project.

No surface features or artifacts of potential archaeological significance are known to be present at the project site. CRM TECH completed an Extended Phase I Archaeological Study for specific areas of the project site on December 23, 2025.

The Study determined that there are no known historical or unique archaeological resources present within the project site. Two artifacts were recovered from the excavations, however, neither were determined to be significant, nor do they meet the criteria for listing in the California Register of Historical Resources or qualify as a “historical resource” or a “unique archaeological resource” for CEQA-compliance purposes.

Implementation of the proposed development component wo uld include excavation on the undeveloped portion of the project site, located west of Dallas Drive, which is noted to have sensitivity for previously undiscovered archaeological resources. Based on the demonstrated sensitivity of the project site for buried prehistoric cultural remains, MM-CUL-1 is required to provide Worker Environmental Awareness Program training, and MM-CUL-2 is required to provide archaeological monitoring during all earth-moving operations associated with the proposed project.

Compliance with MM-CUL-1 and MM-CUL-2 would reduce potential impacts related to prehistoric archaeological resources, including of Native American origin, to less than significant.

As stated above, the City did not receive any requests for tribal consultation following the distribution of notification letters to California Native American tribes affiliated with the project area pursuant to AB 52 and SB 18. Therefore, no additional tribal cultural resources have been identified or are known to occur on-site.

While it is not anticipated that human remains, including those interred outside of formal cemeteries, would be encountered during construction, prior to any ground-disturbing activities in the annexation area, compliance with existing State regulations set forth in the City’s standard condition of approval regarding human remains would be required to ensure the proper identification and handling of the remains. If human remains are found, those remains would require proper treatment in accordance with applicable laws. State of California Public Resources Health and Safety Code Sections 7050.5 through 7055 describe the general provisions for human remains. Specifically, Health and Safety Code Section 7050.5 describes the requirements if any human remains are accidentally discovered during excavation of a site.

As required by State law, the requirements and procedures set forth in Section 5097.98 of the California Public Resources Code would be implemented, including notification of the County Coroner, notification of the Native American Heritage Commission, and consultation with the individual identified by the Native American Heritage Commission to be the most likely descendant. If human remains are found during excavation, excavation must stop near the find and any area that is reasonably suspected to overlay adjacent remains until the County Coroner has been called out, the remains have been investigated, and appropriate recommendations have been made for the treatment and disposition of the remains.

The majority of the proposed project would occur in areas of the site that have already been graded and developed, reducing the possibility of encountering intact subsurface archaeological deposits during ground disturbance. Although no tribal cultural resources are expected to occur on-site, the project site overlaps with a prehistoric archaeological site and has a sensitivity for previously undiscovered cultur al resources. Implementation of MM-CUL-1 and MM-CUL-2 would ensure that no substantial adverse changes would occur to any previously undiscovered resources, and appropriate measures would be taken to handle the resource(s). Because the proposed project would involve earthmoving activities, there is the possibility, albeit low, that such actions could unearth, expose, or disturb previously unknown human remains. Compliance with State and local regulations, set forth in the City’s standard condition of approval related to the proper treatment of human remains, would reduce potential impacts on human remains to less

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than significant. Therefore, with compliance with MM-CUL-1 and MM-CUL-2, impacts related to tribal cultural resources as a result of the proposed project would be less than significant.

The adaptive reuse and outdoor amphitheatre components would occur in a portion of the project site that has been disturbed and subject to previous development. Before cons truction of the existing Civic Arts Plaza complex began, mitigative data recovery was carried out throughout that portion of the project area in the 1990s to remove prehistoric cultural remains. Under archaeological monitoring, salvage excavations were conducted in 1992. The CEQA analysis for the existing Civic Arts Plaza project determined that the salvage excavations had “adequately and completely mitigated any adverse impacts that might occur” to the site. Therefore, it is anticipated that the development of the adaptive reuse and outdoor amphitheatre components, which would o ccur within the existing CAP complex area, would not encounter previously undiscovered cultural resources. However, out of an abundance of caution and due to the cultural resources sensitivity of the entire project site, MM-CUL-1 and MM-CUL-2 are required to reduce potential impacts to tribal cultural resources to less than significant. Additi onally, compliance with existing State regulations regarding human remains, as set forth in the City’s standard conditions of approval, would reduce impacts to less than significant.

Therefore, through implementation of MM-CUL-1 and MM-CUL-2, which would be applicable to all construction phases and activities associated with the proposed project, the adaptive reuse and outdoor amphitheatre components would result in less than significant impacts on tribal cultural resources.

However, this component would not result in new development and would be temporary in nature. No construction is proposed off-site. Therefore, the temporary relocation component would not result in impacts on tribal cultural resources.

MITIGATION MEASURES

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archaeology and has experience in California prehisto ric and historic resources, prior to the start of any earthwork activities related to project construction, to monitor all ground-disturbing activities within the areas of native soil (i.e., below existing areas of artificial fill from previous construction). In the event that potential prehistoric or historic-era archaeological resources (sites, features, or artifacts) are exposed during construction activities for the project, all construction work occurring within a 50-foot buffer of the find shall immediately stop and a qualified archaeologist must be notified immediately to assess the significance of the find and determine whether or not additional study is warranted. Depending on the significance of the find under the California Environmental Quality Act (CEQA), the archaeologist may simply record the fi nd and allow work to continue. If the discovery proves significant under CEQA, additional work (e.g., preparation of an archaeological treatment plan, testing, or data recovery) may be warranted. If it is determined that the discovered archaeological resource constitutes a significant resource, avoidance and preservation in place is the preferred manner of mitigation. Preservation in place may be accomplished by, but is not limited to, avoidance, incorporating the resource into open space, capping, or deeding the site into a permanent conservation easement. If Native American resourc es are discovered or are suspected, each of the consulting tribes for the project shall be notified, as dictated by California Health and Safety Code Section 7050.5, California Public Resources Code Section 5097.98, and CE QA Guidelines Section 15064.5(e). An archaeological monitoring report shall be prepared within 60 days following completion of ground disturbance and submitted to the City of Thousand Oaks Community Development Director for review. This report shall document compliance with approved mitigation, document the monitoring efforts, and include an appendix with daily monitoring logs. The final report shall be submitted to the South Central Coastal Information Center and interested consulting tribes.

Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measures above. Upon implementation of the required mitigation measures, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

Cumulative Impacts The proposed project, combined with other cumulative projects, would not cause a substantial adverse change in the significance of a Tribal Cultural Resource that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).

The proposed project, combined with other cumulative projects, would not cause a substantial adverse change in the significance of a Tribal Cultural Resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.

CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” The cumulative analysis below considers the proposed project’s impacts in conjunction with the future buildout of the General Plan and cumulative projects listed in Draft EIR Table 4-1, Cumulative Projects List.

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Level of Significance: Impacts would be less than significant with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.15, Tribal Cultural Resources, and in particular, on page 5.15-9 of the Draft EIR.

Cumulative projects developed in the vicinity of the project site have the potential to result in cumulatively considerable impacts on tribal cultural resources. However, impacts on tribal cultural resources are generally site-specific. Similar to the proposed project, related cumulative projects would be required to undergo project-specific environmental review under CEQA and the lead agency’s discretionary review pr ocess to determine potential impacts based on project- specific ground-disturbing activities.

As summarized above, there are no historical resources located on-site, and no tribal cultural resources are anticipated to occur on-site. However, the project site is located within a known archaeological resource site and has a sensitivity for previously undiscovered prehistoric cultural resources. Therefore, MM-CUL-1 and MM-CUL-2 are required to reduce potential impacts related to tribal cultural resources to le ss than significant. With compliance with these mitigation measures, the proposed project would not contribute to a cumulatively considerable impact. Cumulative impacts would be less than significant.

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conservation easement. If Native American resources are discovered or are suspected, each of the consulting tribes for the project shall be notified, as dictated by California Health and Safety Code Section 7050.5, California Public Resources Code Section 5097.98, and CE QA Guidelines Section 15064.5(e). An archaeological monitoring report shall be prepared within 60 days following completion of ground disturbance and submitte d to the City of Thousand Oaks Community Development Director for review. This report shall document compliance with approved mitigation, document the monitoring efforts, and include an appendix with daily monitoring logs. The final report shall be submitted to the South Central Coastal Information Center and interested consulting tribes.

Finding: Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. These changes are identified in the form of the mitigation measures above. Upon implementation of the required mitigation measures, the potentially significant impact would be reduced to a less than significant level. The City of Thousand Oaks hereby finds that implementation of the mitigation measures is feasible, and the measures are therefore adopted.

1.2.4 Findings on Significant Unavoidable Impacts
The following summary describes the unavoidable impacts of the proposed project, where mitigation measures were found to be infeasible or would not lessen impacts to less than significant levels even with the implementation of feasible mitigation measures. The following impacts would remain significant and unavoidable.

Air Quality
Impact AQ-1 The proposed project would conflict with or obstruct the implementation of the applicable air quality plan.

Applicable Threshold of Significance: Conflict with or obstruct implementation of the applicable air quality plan? Level of Significance: Impacts would be significant and unavoidable with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.2, Air Quality, and in particular, starting on page 5.2-22 and concluding on page 5.2-25 of the Draft EIR.

Project-Level Analysis
A significant air quality impact may occur if a project is not consistent with the applicable air quality management plan (AQMP) adopted by the VCAPCD, or would in some way represent a substantial hindrance to employing the policies, or obtaining the goals, of that plan.

The proposed project is located within the South-Central Coast Air Basin, which is within the jurisdictional boundaries of the VCAPCD. Consistency with the VCAPCD 2022 AQMP means that a project is consistent with the goals, objectives, and assumptions set forth in the 2022 AQMP that are designed to achieve Federal and State air quality standards. The 2022 AQMP was adopted by the VCAPCD Air Pollution Control Board on December 13, 2022, and incorporates the scientific and technical information and planning assumptions, including the latest applicable growth assumptions from SCAG’s 2020-2045 RTP/SCS, and updated emission inventory methodologies for various source categories. According to VCAPCD’s Air Quality Assessment Guidelines, project consistency with the 2022 AQMP can be determined by comparing the actual population growth in the County with the projected growth rates used in the 2022 AQMP and the CARB on-road emissions forecast as a basis for vehicle emission forecasting. The projected growth rate in population is used as an indicator of future emissions from population-related emission categories in the 2022 AQMP. These emission estimates are used, in part, to project the date by which the County will attain the federal ozone standard. The County’s Planning Division maintains an ongoing population tracking system. Therefore, a demonstration of consistency with the

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population forecasts used in the most recently adopted 2022 AQMP should be used for assessing project consistency with the 2022 AQMP.

The project would construct a 142-room hotel with guest amenities, 240 apartments, and approximately 80,546 square feet of commercial retail space within the project site. The project would also renovate the existing CAP by demolishing approximately 48,800 square feet and constructing approximately 80,900 square feet of new building area.

As of January 1, 2025, the City’s population estimate is approximately 122,468 persons. 18 The project would induce population growth directly by developing 240 residential units in the City. Based on Section 5.12, Population and Housing, of the Draft EIR, buildout of the development component of the proposed project would introduce up to 660 residents, 240 dwelling units, and 152 jobs to the City ; refer to Draft EIR Table 5.12-5, Development Component Population Increase Assumption. It is anticipated that a portion of the workforce would be drawn from existing residents or nearby communities. Employment-related population change is influenced by numerous factors, including housing availability, household preferences, and commute patterns, and cannot be predicted with certainty. As such, the assumptions used in this analysis are conservative an d likely to overstate, rather than understate, potential population effects. Therefore, the proposed development component would increase the population by a total of 812 people. Based on the population forecast provided in the 2020-2045 RTP/SCS, Thousand Oaks is estimated to have approximately 144,700 residents by 2045 (the 2020-2045 RTP/SCS horizon year).19 Therefore, between 2025 and 2045, Thousand Oaks is expected to have an estimated population growth of 22,232 residents. The project-generated 812 additional residents represent approximately 3.6 percent of the anticipated population growth in the City between 2024 and 2045. Thus, the project-generated population grow th would represent a small fraction of the population growth projections in the 2020-2045 RTP/SCS. Since the VCAPCD has incorporated the 2020-2045 RTP/SCS projections into the 2022 AQMP, it can be concluded that the project would also be consistent with the 2022 AQMP.

Furthermore, the proposed project would also include a 14 2-room hotel and approximately 80,546 square feet of commercial retail uses. Due to the nature of these uses , the development of commercial and retail uses would not directly induce population growth. It is anticipated that a portion of the workforce would be drawn from existing residents or nearby communities. Employment-related population change is influenced by numerous factors, including housing availability, household preferences, and commute patterns, and cannot be predicted with certainty. As such, the assumptions used in this analysis are conservative and likely overstate, rather than understate, potential population effects. Further, it should be noted that the project supports the City’s intended urban pattern by amending SP-11 to implement the General Plan policies, and the Downtown Core Master Plan’s Primary Actions and Supporting Activities.

The project proposed infill development with in the Downtown Core, placing new mixed -use, hotel, commercial, and cultural uses as well as sufficient supporting infrastructure on an underutilized civic site. Therefore, with the approval of land use designation changes and Specific Plan Amendment, the project is consistent with the types, intensity, and patterns of land use envisioned for the site and would be considered consistent with the General Plan. Further, the population, employment, and housing, which are adopted by SCAG’s Regional Council, are based on the local plans and policies applicable to Thousand Oaks. As the VCAPCD has incorporated these same projections into the 2022 AQMP, it can be concluded that the proposed project would be consistent with the projections.

The project site is designated “Institutional” per the General Plan Land Use Element and is zoned and regulated by SP- 11, which governs development of the property except for the property at 1868 East Thousand Oaks Boulevard, which is designated as “Commercial Neighborhood” and zoned “Thousand Oaks Boulevard Specific Plan (SP-20)”. The project proposes a General Plan Amendment to change the land use designation of 5.33-acres within the project area from

18 California Department of Finance, Population and Housing Estima tes for Cities, Counties, and th e State, January 2021-2024, wit h 2020 Benchmark, https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for-cities-counties- and-the-state-2020-2024/, accessed March 17, 2025.
19 Southern California Association of Governments, Connect SoCal 2020, Demographics and Growth Forecast, https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-and-growth-forecast.pdf?1606001579, accessed March 17, 2025.

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Institutional to Mixed-Use and to allow exceptions to height limits under the Mixed-Use designation. It also proposes a Specific Plan Amendment to revise SP-11 subarea bounda ries, development standards, and entitlement procedures within the new Downtown Core area of the Civic Arts Plaza Specific Plan. Finally, the project includes a subdivision to consolidate 14 parcels into nine parcels, adjust rights-of-way and easements, and establish new utility, access, and parking easements.

Further, it should be noted that the proposed project is consistent with the Thousand Oaks Climate & Environmental Action Plan (CEAP) GHG reduction measures as detailed in Table 5.7-8, Consistency with the Thousand Oaks Climate & Environmental Action Plan of the Draft EIR. As shown in Draft EIR Table 5.7-8, the proposed project would minimize VMT to the extent feasible by concentrating development in an existing downtown, providing a pedestrian oriented layout, offering a mix of residential, commercial, recrea tional, and entertainment uses, and incorporating bicycle facilities. Although the project exceeds the applicable CE QA VMT threshold, CEQA significance determinations are distinct from policy consistency findings. By supporting infi ll development, shortening trip lengths, enabling internal trip capture, and improving conditions for walking and bicy cling, the project advances the City’s per capita VMT reduction objectives and is therefore consistent with the VMT reduction features.

However, while the project is generally consistent with the land use, population, and growth assumptions of the 2022 AQMP, the project’s operational emissions would exceed VC APCD thresholds. Therefore, the project would not be considered fully consistent with the 2022 AQMP. This is because VCAPCD’s significance thresholds are designed to ensure that individual projects do not impede the region’s progress toward attaining and maintaining federal and state air quality standards. Exceeding the VCAPCD’s significance thresholds indicates that the project would generate emissions beyond those anticipated in the 2022 AQMP’s co ntrol strategies and regional emissions budget, thereby conflicting with the 2022 AQMP’s emissions-reduction framework.

Therefore, the proposed project is considered consistent with the VCAPCD’s 2022 AQMP with respect to population and land use assumptions. However, because project’s op erational emissions could exceed VCAPCD thresholds, the project would be considered inconsistent with the 2022 AQMP’s emissions-reduction strategy. Therefore, impacts would be significant and unavoidable.

At full programmatic buildout, the adaptive reuse and outdoor amphitheatre components would allow up to approximately 24,970 square feet of commercial uses and 84,150 square feet of institutional uses, including up to 2,744 institutional performance venue seats. The project site is designated “Institutional” under the General Plan Land Use Element and is regulated by SP-11, with a portion of the site designated “Commercial Neighborhood” and regulated by SP-20. Based on Section 5.12, Population and Housing, of the Draft EIR, buildout of the adaptive reuse component of the proposed project would introduce approximately 79 jobs to the City. It is anticipated that a portion of the workforce would be drawn from existing residents or nearby communities. Employment-related population change is influenced

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by numerous factors, including housing availability, household preferences, and commute patterns, and cannot be predicted with certainty. Therefore, the proposed adaptive reuse component would increase the population by a total of 79 people. Combined with the development component, the proposed project would increase the on-site population by approximately 891 people, which would represent a small fraction of the population growth projections in the 2020- 2045 RTP/SCS.

As analyzed under Project-Level Analysis, implementati on of the adaptive reuse and outdoor amphitheatre components would require amendments to the General Plan and applicable specific plans to modify land use designations, development standards, and entitlement procedures within the Downtown Core area. With approval of these land use designation changes and specific plan amendments, future development facilitated by the adaptive reuse and outdoor amphitheatre components would be consistent with the types, intensity, and patterns of land use envisioned for the site and would be consistent with the General Plan.

While implementation of these components would incrementally increase employment within the City, such growth would occur in a manner consistent with adopted local land use plans and regional growth assumptions. Accordingly, development enabled by the adaptive reuse and outdoor amphitheatre components would represent infill development within an established urban area and would be consistent with the planning framework upon which regional population and employment projections are based. Therefore, the analysis provided above for the Project- Level Analysis is also applicable to the adaptive reuse and outdoor amphitheatre components. However, as discussed above, because project -related operational emissions could exceed the applicable VCAPCD thresholds, the adaptive reuse and outdoor amphitheatre components would also conflict with the emissions-reduction framework of the 2022 AQMP. As a result, impacts related to AQMP consistency would be considered significant and unavoidable, with implementation of MM-AQ-1 through MM-AQ-3.

MITIGATION MEASURES

MM-AQ-2 Prior to the issuance of a building permit, the Applicant shall demonstrate that the project’s architectural coatings will be “Super Compliant” or have a volatile organic compound (VOC) standard of less than 10 grams per liter.

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building permit or electrical permit issuance.

PROGRAMMATIC-LEVEL ANALYSIS
MM-AQ-1, MM-AQ-2, and MM-AQ-3 are also applicable to the adaptive reuse and outdoor amphitheatre components because these components would involve similar constructi on methods, equipment, and exposure conditions, would affect the same receptors, and would be subject to the same VCAPCD thresholds.

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

Nevertheless, the City of Thousand Oaks finds that there are no additional feasible mitigation measures, taking into consideration specific economic, legal, social, technological, or other factors, that would mitigate this impact to a less than significant level, and, further, that specific economic , legal, social, technological, or other considerations, make infeasible the alternatives identified in the EIR, as discussed in Section 1.2.6, Findings on Project Alternatives, of these Findings (Public Resources Code Sections 21081(a)(1) and (3); CEQA Guidelines Sections 15091(a)(1) and (3). As described in the Statement of Overriding Considerations, the City of Thousand Oaks has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or Statewide environmental benefits, of the proposed project outweigh its significant effects on the environment.

Impact AQ-2 The proposed project would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard.

Applicable Threshold of Significance: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard? Level of Significance: Impacts would be significant and unavoidable with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.2, Air Quality, and in particular, starting on page 5.2-25 and concluding on page 5.2-36 of the Draft EIR.

Project-Level Analysis
Construction
Short-term air quality impacts are predicted to occur during grading and construction activities associated with the project implementation. Temporary air emissions would result from the following activities:
x Particulate (fugitive dust) emissions from grading and building construction; and x Exhaust emissions from the construction equipment and the motor vehicles of the construction crew.

The proposed project would be constructed over five phases in approximately six years, beginning in October 2027.

Draft EIR Table 5.2-4, Unmitigated Maximum Daily Construction Emissions, presents the project’s anticipated daily short- term construction emissions for all construction phases. As shown in Draft EIR Table 5.2-4, construction related emissions would not exceed the VCAPCD emission thresholds during Phase 2b, Phase 2c, and Phase 3 construction. However, emissions from the proposed project’s construction activities would exceed the VCAPCD thresholds during Phase 1 and Phase 2a for NO
x. As such, the proposed project would be required to implement MM-AQ-1 requiring all construction equipment above 50 horsepower (HP) to use Tier 4 engines during all phases of construction.

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Draft EIR Table 5.2-5, Mitigated Maximum Daily Construction Emissions, presents the project’s anticipated daily short-term construction emissions for all construction phases with mitigation incorporated. As shown in Draft EIR Table 5.2-5, with the implementation of MM-AQ-1, emissions from the proposed project’s construction activities would not exceed the VCAPCD thresholds during all phases of construction.

Overlapping Project Phases
As discussed, the construction of Phase 1 would be comple ted prior to the construction of any subsequent phases.

Phase 2a, Phase 2b, and Phase 2c are physically independent from one another but have the potential to be constructed simultaneously. Phase 3 would commence upon construction completion of the prior phases. Since the construction of the proposed project (Phase 2a, Phase 2b, and Phase 2c) would have the potential for overlapping construction activities, the following evaluation quantifies the combined construction-related emissions. To present the worst-case scenario, the following evaluation quantifies the simultaneo us construction emissions of all three Phase 2 project phases. Draft EIR Table 5.2-6 , Phase 2 Overlapping Maximum Daily Construction Emissions, presents both the project’s anticipated unmitigated and mitigated daily short-term construction emissions for all construction phases.

As shown in Draft EIR Table 5.2-6, construction emissions of all three Phase 2 project phases would exceed the VCAPCD emission thresholds for NO X under the unmitigated scenario. However, with the implementation of MM-AQ-1, emissions would be reduced to under the VCAPCD thresholds during Phase 2 (Phase 2a+Phase 2b+Phase 2c) of construction. Therefore, the project would result in a less than significant impact with mitigation incorporated.

Operation
Operational emissions generated by both stationary and mobile sources would result from normal daily activities on the project site after occupation (i.e., increased concentrations of ROG, NO X, SOX, PM10, PM2.5, and CO). Mobile source
emissions would be generated by motor vehicles traveling to and from the project site. Stationary area source emissions would be generated by the operation of landscape maintenance equipment, potential machinery, and use of consumer products. Stationary energy emissions would result from the consumption of electricity and natural gas associated with the project. Draft EIR Table 5.2-7, Unmitigated Long-Term Operational Air Emissions, presents the project’s anticipated operational emissions. It should be noted that Phase 1 would involve construction of linear roadway and infrastructure improvements and would not involve any operational criteria pollutant emissions.

As shown in Draft EIR Table 5.2-7, criteria pollutants from the operation of the proposed project would not exceed the VCAPCD thresholds during the operation of individual phases. However, at full buildout, the proposed project would exceed the VCAPCD thresholds for ROG. As such, the proposed project is required to implement MM-AQ-2 requiring the use of low VOC (less than or equal to 10 grams per liter) during the architectural coating phase, and MM-AQ-3 requiring the project to use all electric landscaping equipment.

Draft EIR Table 5.2-8, Mitigated Long-Term Operational Air Emissions, presents the project’s anticipated emissions during each operational phase. As shown in Draft EIR Table 5.2-8, MM-AQ-2 and MM-AQ-3 would primarily reduce area source emissions.

As shown in Draft EIR Table 5.2-8, with the implementation of MM-AQ-2 and MM-AQ-3, criteria pollutants from the operation of the proposed project would not exceed the VCAPCD thresholds during the operation of individual phases.

Additionally, at full buildout, the project’s operational emissions would not exceed VCAPCD thresholds, with the exception of ROG. As depicted in Draft EIR Table 5.2-8, ROG emissions would be primarily generated from mobile and area sources. The project incorporates multiple TDM and VMT reduction strategies to reduce mobile source emissions; refer to Draft EIR Section 3.0, Project Description. No additional feasible TDM or VMT reduction strategies exist that could meaningfully reduce ROG emissions. Additionally, MM-AQ-2 and MM-AQ-3 would reduce ROG emissions to the maximum extent feasible, and no additional area source mitigation measures exist that could further reduce ROG emissions.

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Furthermore, as noted above, mobile emissions were mode led with CalEEMod, which relies on EMFAC2021 emission factors. EMFAC2021 incorporates several California mobile -source regulations, such as the Advanced Clean Trucks (ACT), Zero-Emission Airport Shuttle, Heavy-Duty Vehicle and Engine Emission Warranty and Maintenance Provisions (Warranty Phase 1), and the Heavy-Duty Omnibus regulations.20 On June 12, 2025, the federal government rescinded the Clean Air Act waivers that allowed California to enforc e these regulations, and the EPA subsequently approved off-model adjustment factors on November 21, 2025, to remove the emissions benefits of these regulations from EMFAC2021.21 Because CalEEMod has not been updated to reflect the adjustment factors, the mobile-source emissions shown in Draft EIR Table 5.2-8 account for the regulatory benefits and likely underestimate mobile emissions.

Therefore, ROG emissions shown in Draft EIR Table 5.2-8 would likely exceed the VCAPCD threshold and impacts would be significant and unavoidable.

Air Quality Health Impacts
Adverse health effects induced by criteria pollutant emissions are highly dependent on a multitude of interconnected variables (e.g., cumulative concentrations, local mete orology and atmospheric conditions, and the number and character of exposed individuals [e.g., age, gender]). In particular, O3 precursors VOCs, also referred to as ROG and NOX, affect air quality on a regional scale. Health effects related to ozone are therefore the product of emissions generated by numerous sources throughout a region. Existing models have limited sensitivity to small changes in criteria pollutant concentrations, and, as such, translating project-generated criteria pollutants to specific health effects or additional days of non-attainment would produce meaningless results. Even with an exceedance of the VCAPCD regional ROG threshold, the project’s incremental contribution to region al pollutant levels would remain nominal and would not produce meaningful or measurable changes in human health risk.

As noted in the Brief of Amicus Curiae by the South Coast Air Quality Management District (SCAQMD),22 the SCAQMD acknowledged it would be extremely difficult, if not imposs ible to quantify health impacts of criteria pollutants for various reasons including modeling limitations as well as where in the atmosphere air pollutants interact and form.

Further, as noted in the Brief of Amicus Curiae by the San Joaquin Valley Air Pollution Control District (SJVAPCD), 23 SJVAPCD has acknowledged that currently available modeling tools are not equipped to provide a meaningful analysis of the correlation between an individual development project’s air emissions and specific human health impacts.

The SCAQMD acknowledges that health effects quantificatio n from ozone, as an example is correlated with the increases in the ambient level of ozone in the air (concentration) that an individual person breathes. SCAQMD’s Brief of Amicus Curiae states that it would take a large amount of additional emissions to cause a modeled increase in ambient ozone levels over the entire region. The SCAQMD states that based on their own modeling in the SCAQMD’s 2012 Air Quality Management Plan, a reduction of 432 tons (864,000 pounds) per day of NO X and a reduction of 187 tons (374,000 pounds) per day of VOCs would reduce ozone levels at the highest monitored site by only nine parts per billion. As such, the SCAQMD concludes that it is not currently possible to accurately quantify ozone-related health

20 California Air Resources Board, EMFAC2021 Adjustment Factors Request Letter, Attachment A: EMFAC Off-Model Adjustment Factors to Remove Emissions Benefits of Advanced Clean Trucks, Zero-Emission Airport Shuttle, Warranty Phase 1, and Heavy-Duty Omnibus Regulations, available at: https://ww2.arb.ca.gov/sites/default/files/2025-12/Attachment%20A%20- %20Description%20of%20EMFAC2021%20Adjustment%20Factors.pdf, accessed February 10, 2026. 21 United States Environmental Protection Agency, EPA Off-Model Adjustment Factors Approval Letter, available at:
https://www.epa.gov/system/files/documents/2025-12/epa-off-model-adjustment-factors-approval-letter.pdf, accessed February 10, 2026.
22 South Coast Air Quality Management District, Application of the South Coast Air Quality Management District for Leave to File Brief of Amicus Curiae in Support of Neither Party and Brief of Amicus Curiae. In the supreme Court of California. Sierra Club, Reviv e the San Joaquin, and League of Women Voters of Fresno v. County of Fresno, 2014. 23 San Joaquin Valley Air Pollution Control District, Application for Leave to File Brief of Amicus Curiae Brief of San Joaquin V alley Unified Air Pollution Control District in Support of Defendant and Respondent, County of Fresno and Real Party In Interest and Respondent, Friant Ranch, L.P. In the Supreme Court of California. Sierra Club, Revive the San Joaquin, and League of Women Vot ers of Fresno v. County of Fresno, 2014.

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impacts caused by NOX or VOC emissions from relatively small projects (defined as projects with regional scope) due to photochemistry and regional model limitations.

Accordingly, while the project would exceed the VCAPCD regional ROG threshold, the exceedance does not provide a basis for quantifying or inferring specific health effects. Given the regional nature of ozone formation, the insensitivity of photochemical models to small emission increments, and the absence of any reliable methodology to correlate project emissions with health outcomes, the project’s contri bution to criteria air pollutant–related health impacts would remain less than significant.

It is acknowledged that the temporary relocation component could introduce people to off-site locations (within existing permitted office space) within City boundaries th at could be located in proximity to additional sensitive receptors. However, this component would not result in new development or significant additional employees exceeding those already accounted for with existing staffing levels, and would be temporary in nature. No construction is proposed off-site. Therefore, the temporary relocation component would not result in impacts related to criteria pollutants.

MITIGATION MEASURES

PROJECT-LEVEL ANALYSIS
MM-AQ-1 The Construction Contractor shall ensure that off-road diesel construction equipment of 50 horsepower (HP) or greater shall comply with EPA/CARB Tier 4 emissions standards or equivalent and shall ensure that all construction equipment is tuned and maintained in accordance with the manufacturer’s specifications. This requirement shall be verified through submittal of an equipment inventory that includes the following information: (1) Type of Equipment, (2) Engine Year and Age, (3) Number of Years Since Rebuild of Engine (if applicable), (4) Type of Fuel Used, (5) Engine HP, (6) Verified Diesel Emission Control Strategy (VDE CS) information if applicable and other related equipment data. A Certification Statement is also required to be made by the Contractor for documentation of compliance and for future review by the VCAPCD, as necessary. The Certification Statement must state that the Contractor agrees to compliance and acknowledges that a violation of this requirement shall constitute a material breach of contract.

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exterior electrical outlets to accommodate the landscape equipment requirement. Provision of such electrical requirements shall be checked by the City of Thousand Oaks Building Division prior to building permit or electrical permit issuance.

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

Cumulative Impacts The proposed project, combined with other cumulative projects, would conflict with or obstruct implementation of the applicable air quality plan.

CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” As outlined in Draft EIR Table 4-1 and illustrated on Draft EIR Exhibit 4-1, cumulative projects are situated in the site vicinity.

Level of Significance: Impacts would be significant and unavoidable with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.2, Air Quality, and in particular, on page 5.2-42 of the Draft EIR.

Future related projects would be required to analyze project-level consistency with applicable air quality plans, including the 2022 AQMP. As analyzed above, operational concentrations of criteria air pollutants of the project would not exceed VCAPCD thresholds, with the exception of ROG. Because a VCAPCD threshold exceedance indicates that a project would contribute emissions beyond those anticipated in the 2022 AQMP, the project’s ROG emissions would likely contribute to an increase in the frequency or severity of existing air quality violations and therefore represent a cumulatively considerable contribution to a significant cumulative air quality impact. Although the project would be consistent with the VCAPCD and SCAG goals and policies, an d the growth anticipated by the project would align with SCAG’s regional growth forecast and the 2022 AQMP, th e VCAPCD ROG threshold exceedance would result in a cumulatively considerable contribution to a significant cumulative impact. Therefore, cumulative air quality impacts associated with ROG emissions would be significant and unavoidable.

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

Cumulative Impacts The proposed project, combined with other cumulative projects, would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard.

Level of Significance: Impacts would be significant and unavoidable with mitigation incorporated.

Support for this environmental impact conclusion is included in Draft EIR Section 5.2, Air Quality, and in particular, on page 5.2-43 of the Draft EIR.

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Construction
The VCAPCD neither recommends quantified analyses of cu mulative construction emissions, nor does it provide separate methodologies or thresholds of significance to be used to assess cumulative construction impacts. The VCAPCD significance thresholds for construction are intended to meet the objectives of the 2022 AQMP to ensure the NAAQS and CAAQS are not exceeded. As the project applicant has no control over the timing or sequencing of cumulative projects in the project vicinity, any quantitative analysis to ascertain the daily construction emissions that assumes multiple, concurrent construction would be speculative. Future cumulative projects would also be required to analyze construction emission impacts on a project-level under CEQA and implement mitigation as needed.

As indicated in Draft EIR Table 5.2-6, the project would not result in short-term air quality impacts as the project-level emissions would not exceed the VCAPCD adopted construction thresholds with the implementation of MM-AQ-1.

Therefore, the project would not result in cumulatively considerable impacts with regards to short-term construction air quality emissions.

Operation
The VCAPCD has set forth both a methodological framework as well as significance thresholds for the assessment of a project’s cumulative operational air quality impacts. The VCAPCD’s approach for assessing cumulative impacts is based on the VCAPCD’s 2022 AQMP forecasts of attainment of NAAQS in accordance with the requirements of the Federal and State CAAs. This forecast also considers SCAG’s 2020-2045 RTP/SCS forecasted future regional growth. As such, the analysis of cumulative impacts focuses on determining whether the project is consistent with the growth assumptions upon which the VCAPCD’s 2022 AQMP is based. If the project is consistent with the growth assumptions, then the future development would not impede the attainment of NAAQS, and a significant cumulative air quality impact would not occur.

As discussed above, the project’s operational emissions would not exceed the VCAPCD operational thresholds, with the exception of ROG. Because a VCAPCD threshold exceedance indicates that a project would contribute emissions beyond those anticipated in the 2022 AQMP, the project’s ROG emissions would likely contribute to an increase in the frequency or severity of existing air quality violations and therefor e represent a cumulatively considerable contribution to a significant cumulative air quality impact. Although emission reduction technologies, strategies, and plans continue to advance, the project’s exceedance of the ROG VCAPCD threshold demonstrates a substantial contribution to regional ozone precursor emissions. Therefore, due to the projec t’s exceedance of the VCAPCD ROG threshold, cumulative operational air quality impacts would be significant and unavoidable.

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MM-AQ-3 Any development agreement or long-term lease ag reement associated with any building within the project site, and in which the City is party, shall require all landscaping equipment used on public landscape areas to utilize 100 percent electric landscaping equipment (e.g., lawnmowers, leaf blowers, hedge trimmers). In addition, for any areas within the project site that are maintained by the City, the City shall utilize 100 percent electric landscaping equipment. All properties shall be equipped with exterior electrical outlets to accommodate the landscape equipment requirement. Provision of such electrical requirements shall be checked by the City of Thousand Oaks Building Division prior to building permit or electrical permit issuance.

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

Transportation
Impact T-2 The proposed project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b).

Applicable Threshold of Significance: Conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b)?
Level of Significance: Impacts would be significant and unavoidable.

Support for this environmental impact conclusion is included in Draft EIR Section 5.14, Transportation, and in particular, starting on page 5.14-14 and concluding on page 5.14-18 of the Draft EIR.

Draft EIR Section 5.14 is based in part on the Traffic, Circulation, and VMT Study, prepared by Associated Transportation Engineers, dated January 28, 2026, which is included in Draft EIR Appendix O, Traffic, Circulation, and VMT Study.

Project-Level Analysis
VMT Screening Criteria
As mentioned in Draft EIR Section 5.14, Transportation, any project subject to CEQA review that is not determined to be exempt per the State CEQA Guidelines would require an initial screening to determine if the project warrants further transportation assessment. Projects subject to CEQA review that meet at least one of the screening criteria are considered exempt for the purposes of CEQA and are presumed to have VMT impacts that are less than significant.

Specifically, the City’s VMT Analysis for CEQA Compliance Administrative Policy provides screening criteria to determine VMT impacts based on trip generation and low VMT areas, which are as follows:
x Trip Generation: Any project that generates less than 100 p.m. peak hour trips based on the ITE 11th Edition Trip Generation Manual or most current edition published at the time the project application is submitted.

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o Not Applicable: Based on the Traffic, Circulation, and VMT Study, the proposed project would result in a net increase of 5,876 average daily traffic (ADT), 238 a.m. peak hours trips, and 401 p.m. peak hour trips. As such, the proposed project would exceed the 100 p.m. peak hour trips threshold and would not meet the trip generation screening criteria.
x Low VMT Area: This criteria includes a map-based approach. Different sections of the City display different VMT characteristics based on land use and other factors. Areas where the General Plan favors intensification of development are generally areas of low average VMT. The following methodology must be used for determining if a project meets the map-based screening threshold: a) The proposed project must be consistent with the General Plan designation and zoning; b) The VCTC has produced a countywide model for VMT and will provide maps to member agencies when available. The City’s Public Works Department will obtain and maintain the most current map for the purpose of this interim policy; c) For projects located in low VMT areas, the applicant must demonstrate that the project will resu lt in a similar level of VMT as the surrounding land use within the TAZ, as shown on the best available map approved by the City’s Community Development Director and the City’s Public Works Department staff for project analysis. Where the project site is on the boundary of another TAZ, the same low VMT as the TAZ in which the project site is located must be determined.

The VMT methodology may use VMT per capita, per employee, or net VMT as allowed by the California Government Code.
o Not Applicable: As listed in Section 3.11, Discretionary Approvals, the proposed project would require a General Plan Amendment to change the land use designation of a 5.33-acre portion of the project site from Institutional to Mixed-Use and adjust the language allowing an exception to the height maximum required by the Mixed-Use Land Use Designation; and, a Specific Plan Amendment to revise SP-11 subarea boundaries, associated acreages, text, exhibits regarding development and design standards, and procedures for minor or major changes to entitlements under SP-11, specifically within the proposed new Downtown Core Subarea (i.e., Subareas B, C, and E) between Conejo School Road and the western project boundary. Additionally, the project site is not located in a low VMT area.

As such, the proposed project would not meet the aforementioned screening criteria.

As analyzed above, the proposed project does not meet any of the City’s screening criteria and thus, would require a TIA to determine the project’s environmental impact. As such, a CEQA Transportation Assessment was prepared to evaluate VMT against the City’s recommended thresholds; refer to Draft EIR Appendix O.

Full VMT Analysis and Modeling Assumptions
VMT has been calculated using the VCTM, consistent with the City’s VMT Analysis for CEQA Compliance Administrative Policy. The VCTM is a land-use-based model (a subarea model of the SCAG travel demand model) that is consistent with the 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy (2016–2040 RTP/SCS) travel-demand model assumptions and inputs. The model consists of a 2016 base year scenario and a 2040 future year scenario. The 2016 base year scenario was utilized for this analysis, wh ich is a region-wide standard for existing and baseline conditions analysis. The VCTM provides work-based VMT per employee data for the City as well as the various TAZs within the City, including the TAZ that encompasses the project site (60189101). The VCTM data was used to establish the home-based VMT per employee thresholds for the City and to estimate the home-based VMT per resident and work-based VMT per employee for the project. The following data was applied to the project TAZ to account for the proposed project in the VCTM:
24 x Residential: 240 net new households, 552 net new residents (population); and

24 It should be noted that the net new residents (population) and net new employee values differ from those in other EIR sections as these values are calculated using the VCTM’s Model SED Category and Employment/Population Conversion Factors, which differ from those used in other EIR sections; refer to Appendix A, Socio-economic Data Conversion, of the Traffic, Circulation, and VMT Stu dy (Draft EIR Appendix O), for the conversion calculations.

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x Non-residential: 298 net new employees.

As shown in Draft EIR Table 5.14-1, Residential VMT Summar y, the existing citywide home-based VMT per capita is

15.33 VMT per capita. The VCTM data shows that the residents within the project TAZ generate 0.22 VMT per capita without the project. At project buildout, the residential component of the proposed project would result in 7.04 VMT per capita (with implementation of the TDM and VMT reduct ion strategies incorporated as part of the project’s characteristics; refer to Draft EIR Section 3.0, Project Description, for a comprehensive list of these strategies) with the project.25 Overall, the residential component of the project would be below the citywide baseline impact threshold of

15.33 VMT per capita, and VMT impacts would be less than significant in this regard.

As shown in Draft EIR Table 5.14-2, Employee VMT Summary, the existing citywide work-based VMT per employee is

22.62 VMT per employee. The VCTM data shows that the employees within the project TAZ generate 24.29 VMT per employee without the project. At project buildout, the em ployee component of the proposed project would result in

26.37 VMT per employee (with implementation of the TDM and VMT reduction strategies incorporated as part of the project’s characteristics) with the project. 26 Overall, the employee component of the project would be above the citywide baseline impact threshold of 22.62 VMT per employee, and impacts would remain significant and unavoidable in this regard.

As detailed in the City’s VMT Analysis for CEQA Comp liance Administrative Policy, the City has adopted an administrative policy stating that thresholds of significance would be determined on a case-by-case basis. The project consists of a variety of residential and non-residential uses; thus, a modified threshold of significance has been utilized to account for the mixed-use nature of the project:
x A significant impact would occur if the project TAZ’s VMT per service population (i.e., residents plus employees) in the “with project” scenario exceeds the project TAZ’s VMT per service population in the existing/baseline scenario.

As shown in Draft EIR Table 5.14-3, Service Population VMT Summary, the existing citywide VMT per service population is 17.83 VMT per service population. The VCTM data shows that the TAZ generates 23.76 VMT per service population with the project. With the implementation of the TDM and VMT reduction strategies incorporated as part of the project’s characteristics, the proposed project would result in 19.37 VMT per service population with the project. When comparing the VMT results from the project’s TAZ and utilizing the VMT per service population metric to account for the variety of land uses, the proposed project would not be forecasted to result in a potentially significant VMT impact.

Overall, the VCTM data shows that the proposed project would result in an overall reduction in the VMT per service population generated by TAZ, and VMT impacts would be less than significant in this regard.

Conclusion
In conclusion, as a conservative approach, TAZ work-bas ed VMT per employee with the project would result in significant and unavoidable impacts even with the implementation of the TDM and VMT reduction strategies incorporated as part of the project’s characteristics. Thus, VMT-related impacts would remain significant and unavoidable in this regard.

25 Refer to Appendix B, VMT Outputs and Reduction Measures, of the Traffic, Circulation, and VMT Study (Draft EIR Appendix O), fo r VMT per capita calculation with and without total reduction values. 26 Ibid.

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impacts than those already analyzed above. Specifically, the adaptive reuse and outdoor amphitheatre components would not exceed the VMT impacts described above. TAZ work-based VMT per employee with the project would result in significant and unavoidable impacts, even with the implementation of the TDM and VMT reduction strategies incorporated as part of the project’s characteristics. As such, VMT-related impacts would remain significant and unavoidable in this regard.

It is acknowledged that the temporary relocation component could introduce people to off-site locations (within existing permitted office space) within City boundaries. However, this component would not result in new development or significant additional employees exc eeding those already accounted for with current staffing levels, and would be temporary in nature. No construction is proposed off-site. Overall, the temporary relocation component, combined with the development, adaptive reuse, and outdoor amphitheatre components, would result in VMT-related impacts that are significant and unavoidable.

MITIGATION MEASURES
No mitigation measures are feasible.

Finding: The City of Thousand Oaks finds that there are no feasible mitigation measures, taking into consideration specific economic, legal, social, technological, or other factors, that would mitigate this impact to a less than significant level, and, further, that specific economic, legal, social, technological, or other considerations, make infeasible the alternatives identified in the EIR, as discussed in Section 1.2.6, Findings on Project Alternatives, of these Findings (Public Resources Code Sections 21081(a)(1) and (3); CEQA Guidelines Sections 15091(a)(1) and (3). As described in the Statement of Overriding Considerations, the City of Thousa nd Oaks has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or Statewide environmental benefits, of the proposed project outweigh its significant effects on the environment.

Cumulative Impacts The proposed project, combined with other cumulative projects, would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b).

CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” The cumulative analysis below considers the proposed project’s impacts in conjunction with the future buildout of the General Plan and cumulative projects listed in Draft EIR Table 4-1, Cumulative Projects List.

Level of Significance: Impacts would be significant and unavoidable.

Support for this environmental impact conclusion is included in Draft EIR Section 5.14, Transportation, and in particular, on page 5.14-21 of the Draft EIR.

The VMT analysis prepared for the project evaluated VMT impa cts under the TAZ in relation to the regional area. As the project would result in significant and unavoidable VMT impacts (TAZ work-based VMT per employee), the project would make an incremental but significant contribution to cumulatively considerable regional VMT. Therefore, the project’s contributions to cumulative impacts would be significant and unavoidable.

MITIGATION MEASURES
No mitigation measures are feasible.

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alternatives identified in the EIR, as discussed in Section 1.2.6, Findings on Project Alternatives, of these Findings (Public Resources Code Sections 21081(a)(1) and (3); CEQA Guidelines Sections 15091(a)(1) and (3). As described in the Statement of Overriding Considerations, the City of Thousa nd Oaks has determined that this impact is acceptable because specific overriding economic, legal, social, technological, or other benefits, including regionwide or Statewide environmental benefits, of the proposed project outweigh its significant effects on the environment.

1.2.5 Findings on Recirculation
CEQA Guidelines Section 15088.5(a) requires a lead agency to “recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the Draft EIR for public review under Section 15087, but before certification. As used in this section, the term “information” can include changes in the project or environmental setting as well as additional data or ot her information. New information added to an EIR is not ‘significant’ unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement.” Comment letters received on the Draft EIR, and responses to those comment letters provided in the Final EIR, do not identify any significant new information requiring recirculation. As a result, pursuant to CEQA Guidelines Section 15088.5, a recirculation of the Draft EIR is not required.

1.2.6 Findings on Project Alternatives
CEQA requires that the discussion of alternatives focus on alternatives to the project or its location that are capable of avoiding or substantially lessening any significant effects of the project. As discussed in the Draft EIR, upon compliance with existing regulations and mitigation measures, projec t implementation would not result in any significant and unavoidable impacts, with the exception of air quality and transportation, including: (1) The proposed project would conflict with or obstruct implementation of the applicab le air quality plan despite the implementation of MM-AQ-1 through MM-AQ-3; (2) The proposed project would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainmet under an applicable federal or State ambient air quality standard despite the implementation of MM-AQ-1 through MM-AQ-3 ; and (3) The proposed project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b). It should be noted that no mitigation measures are feasible for transportation-related impacts.

Alternative 1 – No Project Alternative
In accordance with the CEQA Guidelines, “the no project analysis shall discuss the existing conditions…, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.” The CEQA Guidelines continue to state that “in certain instances, the no project alternative means ‘n o build’ wherein the existing environmental setting is maintained.” The No Project Alternative includes a discussion and analysis of the existing baseline conditions at the time the Notice of Preparation (NOP) was published on September 11, 2025. The No Project scenario is described and analyzed to enable the decision-makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project.

Under the No Project Alternative, the proposed development, adaptive reuse, outdoor amphitheatre, and temporary relocation components would not occur. The site’s current General Plan land use designation (Institutional) would remain in place. The proposed SP-11 amendments would not be adopted, and the subareas within the site that are designated by the current SP-11 would remain the same. Given that the site is currently developed with uses consistent with the existing land use designation and zoning (i.e., the Civic Arts Plaza complex, including City Hall), it is reasonably expected that buildout of the site under existing designations and zoning would be the same as existing conditions. The site would continue to operate as an institutional use center with City Hall services, performing arts venues, public park

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space, and three commercial tenants located along Thousand Oaks Boulevard. The existing structures on-site would remain, the undeveloped space located west of Dallas Drive, north of the existing parking structure, and south of the commercial buildings along Thousand Oaks Boulevard would remain undeveloped and underutilized, and no development would occur. Similar to the proposed project, the existing use at 1868 East Thousand Oaks Boulevard would remain.

Unlike the proposed project, the No Project Alternative would not require a General Plan Amendment, Specific Plan Amendment, Tentative Tract Map, Protected Tree Permit, Special Use Permit, Final Subdivision Map, entitlements, Development/Purchase Agreement, Landscape Plan Check, Drainage Plan, Water and Sewer Plan, Water Quality Management Plan, Infrastructure Plans/Permits, Grading Permits, Building Permits, Major/Minor Modifications, encroachment permits, Fire Protection Clearances, or NPDES permit.

Conclusion: The No Project Alternative would have less environmental impacts compared to the proposed project in every topical area; however, it would not attain any of the proposed project’s basic objectives. The No Project Alternative would not be consistent with the goals in the City’s planning documents, provide expanded economic opportunities, develop economically viable uses on the site, introduce new affordable housing units, incentivize alternative modes of travel, rehabilitate the existing City Hall, provide a mixed-use community with the Downtown Subarea, provide a new hotel, screen the existing parking ga rage, or provide flexible community space; refer to Draft EIR Table 8-1, No Project Alternative and Project Objectives.

Finding: This alternative is rejected because it would not ac complish any of the objectives of the proposed project.

The findings of the proposed project set forth in this document and the overriding social, economic, and other issues set forth in the Statement of Overriding Considerations provide support for the proposed project and the elimination of this alternative from further consideration.

Alternative 2 – Existing Culvert to Remain Alternative
The Existing Culvert to Remain Alternative proposes the development of the bandshell and amphitheatre (Building B2), restaurant (Building B1), hotel (Building E1), mixed-use bu ildings (Buildings E2 and a physically separated version of Building E3, see below), adaptive reuse of City Hall (Build ing C1), and all of the same infrastructure, landscaping, hardscape, roadway, and site improvements as the proposed project. However, this alternative proposes to keep the existing underground culvert that is located under the site of the proposed Building E3 in place, which would prohibit the development of subterranean parking for Building E3.

The existing Ventura County Watershed Protection District culvert transects the northern portion of the project site, undulating across the proposed Building E3 footprint. In a previous conceptual design (May 2024), the existing culvert alignment was anticipated to remain. This resulted in 4 separate structures proposed in place of the currently proposed Building E3, including:
x Building B1*: Mixed Use – 4,600 square feet of commercial, 23 residential units x Building B2*: Mixed Use – 4,651 square feet of commercial, 12 residential units x Building C1*: Commercial – 3,354 square feet of commercial x Building C2*: Commercial – 1,020-square-foot commercial “kiosk” *The Building numbering proposed above has since been revised for the proposed project. All four buildings above would have constituted what is now being proposed as the single mixed-use Building E3 in their place, as part of the proposed project. The se buildings have no relation to the currently proposed Building B1 (restaurant), Building B2 (bandshell and amphitheatre), Buildi ng C1 (Civic Arts Plaza), or Building C2 (parking structure). These building numbers shall be considered separately for this alternative only.

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This alternative would have no subterranean parking and would rely solely on shared parking with the podium parking proposed in Building E2. All other proposed project features would remain the same. The configuration of the four buildings proposed above would include both mixed-use buildings located west of Dallas Drive and the two commercial buildings located on the east side of Dallas Drive. Key di fferences between this alternative and the proposed project are outlined in Draft EIR Table 8-2, Proposed Project vs Existing Culvert to Remain: Alternative Key Differences.

Overall, this alternative results in 44 fewer residential units, approximately 5,500 less square feet of commercial area, 77 fewer parking spaces, and approximately 49,500 less cubic yards of grading since no subterranean parking garage would be possible given the existing culvert alignment. Development of this alternative would still include demolition of the three existing commercial structures fronting Thou sand Oaks Boulevard and partial renovation of the existing Civic Arts Plaza complex. Under the Existing Culvert to Remain Alternative, all of the same project approvals, including a General Plan Amendment and Specific Plan Amendment, would be required, similar to the proposed project. This alternative would require less grading; however, the overa ll construction period is expected to be similar to the proposed project.

Conclusion: The Existing Culvert to Remain Alternative would no t attain all of the proposed project’s objectives; compared to the proposed project, it would not provide the same residential and commercial density to generate consistent activity on-site that would stimulate economic growth. This alternative would develop fewer residential units and less commercial square footage than the proposed projec t, and would therefore not meet the project’s goals of sufficient economic use of the City’s parcels. This alternative would also not provide the quantity of affordable housing units desired by the City compared to the proposed project. Additionally, this alternative would not avoid the significant and unavoidable impacts related to air quality and transportation that would similarly result from the proposed project.

Therefore, this alternative would not achieve all project objectives or significantly reduce environmental impacts compared to the proposed project. Relocating the culvert would increase the development potential of the E3 building pad, thereby improving project economics, increasing service population within the project area, contributing to the success and vitality of the overall project, and providing additional parking spaces necessary to serve the development.

Finding: This alternative is rejected because it would accomplish some, but not all, of the objectives of the proposed project. The findings of the proposed project set forth in this document and the overriding social, economic, and other issues set forth in the Statement of Overriding Considerations provide support for the proposed project and the elimination of this alternative from further consideratio n. The City Council rejects the Existing Culvert to Remain Alternative for the following reasons: (1) this alternativ e would not provide the same residential and commercial density as the proposed project; (2) this alternative would not provide the quantity of affordable housing units as the proposed project; and (3) this alternative would not avoid the significant and unavoidable impacts related to air quality and transportation that would similarly result from the proposed project.

Alternative 3 – Alternative Unit Mix Alternative
The Alternative Unit Mix Alternative proposes the developm ent of the bandshell and amphitheatre (Building B2), restaurant (Building B1), hotel (Building E1), mixed-use buildings (Buildings E2 and Building E3), adaptive reuse of City Hall (Building C1), and all of the same infrastructure, landscaping, hardscape, roadway, and site improvements as the proposed project. However, this alternative proposes a different unit mix for Buildings E2 and E3; the alternative unit mix was determined by calculating the potential total unit count for the buildings with a target of approximately 25 percent studios/one-bedrooms, 50 percent two-bedrooms, and 25 percent three-bedrooms, while maintaining the same proposed building massing and envelopes as the proposed project. Key differences between this alternative and the proposed project are outlined in Dr aft EIR Table 8-4, Proposed Project vs Alternative Unit Mix: Alternative Key Differences.

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This alternative results in 184 total units, or 56 fewer residential units than the proposed project. This alternative would also include 22 three-bedroom units, which are not included in the proposed project. Though the unit configuration would be different, no other differences are proposed to the design of the mixed-use structures compared to the proposed project. Development of this alternative would still include demolition of the three existing commercial structures fronting Thousand Oaks Boulevard and partial renovation of the existing Civic Arts Plaza complex. Under the Alternative Unit Mix Alternative, all of the same project approvals, including a General Plan Amendment and Specific Plan Amendment, would be required, similar to the proposed project. The construction period is expected to be similar to the proposed project.

Conclusion: The Alternative Unit Mix Alternative would not attain all of the proposed project’s objectives; compared to the proposed project, it would not provide the same residential density to generate consistent activity on-site that would stimulate economic growth. This alternative would develop fewer residential units than the proposed project and would therefore not meet the project’s goals of sufficient economic use of the City’s parcels. This alternative would also not provide the quantity of affordable housing units desired by the City compared to the proposed project.

Additionally, this alternative would not avoid the signif icant and unavoidable impacts related to air quality and transportation that would similarly result from the proposed project; VMT-related impacts from this alternative would be marginally greater than the VMT impacts of the proposed project. Therefore, this alternative would not achieve all project objectives or significantly reduce environmental impacts compared to the proposed project.

Finding: This alternative is rejected because it would accomplish some, but not all, of the objectives of the proposed project. The findings of the proposed project set forth in this document and the overriding social, economic, and other issues set forth in the Statement of Overriding Considerations provide support for the proposed project and the elimination of this alternative from further consideration. The City Council rejects the Alternative Unit Mix Alternative for the following reasons: (1) this alternative would not provide the same residential density as the proposed project; (2) this alternative would not provide the quantity of affordable housing units as the proposed project; and (3) this alternative would not avoid the significant and unavoidable impacts related to air quality and transportation that would similarly result from the proposed project.

Environmentally Superior Alternative
Draft EIR Table 8-6, Comparison of Alternatives, summarizes the comparative analysis presented above (i.e., the alternatives compared to the proposed project). Review of Draft EIR Table 8-6 indicates that the No Project Alternative is the environmentally superior alternative, because it woul d avoid or lessen the majority of impacts associated with development of the proposed project. According to CEQA Guidelines Section 15126.6(e), “if the environmentally superior alternative is the “no project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” Accordingly, an environmentally superior alternative among the other alternatives is identified below.

The Existing Culvert to Remain Alternative would have less environmental impacts compared to the proposed project with regard to energy, GHG emissions, hydrology and water quality, noise, population and housing, public services and recreation, utilities and service systems, and wildfire. The impacts of this alternative related to energy, hydrology and water quality, population and housing, public services and recreation, utilities and service systems, and wildfire would be less than significant, similar to the proposed project. The impacts of this alternative related to GHG emissions and noise would be less than significant with mitigation incorporated, similar to the proposed project. This alternative would result in similar environmental impacts to aesthetics, biological resources, cultural resources, geology and soils, hazards and hazardous materials, land use and planning, and tribal cultural resources as the proposed project. Impacts related to air quality would still be significant and unavoidable, with mitigation incorporated, and impacts related to transportation would still be significant and unavoidable, similar to the proposed project. Air quality and VMT impacts

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would be slightly reduced in comparison to the proposed project, due to the reduced unit count, commercial square footage, and grading, however, impacts would still be significant and unavoidable.

The Existing Culvert to Remain Alternative would not achiev e all of the project’s objectives. This alternative would develop fewer residential units and less commercial square footage than the proposed project, and would therefore not meet the project’s goals of sufficient economic use of the City’s parcels (Objective 1). This alternative would also not provide the quantity of affordable housing units desired by the City compared to the proposed project (Objective 4). Additionally, this alternative would not avoid the sign ificant and unavoidable impacts related to air quality and transportation that would similarly result from the proposed project. Overall, this alternative would be environmentally superior based on marginal reductions in impacts related to air quality, energy, GHG emissions, hydrology and water quality, noise, population and housing, public services and recreation, utilities and service systems, and wildfire, but it would not achieve project Objective 1 and would not achieve Objective 4 to the same extent as the proposed project, and it would still result in significant and unavoidable impacts on air quality and transportation. Therefore, this alternative would not achieve all project objectives or si gnificantly reduce environmental impacts compared to the proposed project.

The Alternative Unit Mix Alternative would have less environmental impacts compared to the proposed project with regard to energy, GHG emissions, noise, population and ho using, public services and recreation, utilities and service systems, and wildfire. The impacts of this alternative rela ted to energy, population and housing, public services and recreation, utilities and service systems, and wildfire would be less than significant, similar to the proposed project. The impacts of this alternative related to GHG emissions a nd noise would be less than significant with mitigation incorporated, similar to the proposed project. This alte rnative would result in similar environmental impacts to aesthetics, biological resources, cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and planning, and tribal cultural resources as the proposed project. Impacts related to air quality would still be significant and unavoidable, with mitigation incorporated, and impacts related to transportation would still be significant and unavoidable, and marginally greater compared to the proposed project. Air quality impacts would be slightly reduced in comparison to the proposed project, due to the reduced unit count; however, VMT impacts would be marginally greater, and impacts would still be significant and unavoidable.

The Alternative Unit Mix Alternative would not achieve all of the project’s objectives. This alternative would not maximize the development capacity of the site. This alternative would develop fewer residential units than the proposed project, and would therefore not meet the project’s goals of sufficient economic use of the City’s parcels (Objective 1). This alternative would also not provide the quantity of affordable housing units desired by the City compared to the proposed project (Objective 4). Additionally, this alternative would not avoid the significant and unavoidable impacts related to air quality and transportation that would similarly result from the proposed project; VMT-related impacts from this alternative would be marginally greater than the VMT impacts of the proposed project.

Overall, this alternative would marginally reduce impact s related to air quality, energy, GHG emissions, noise, population and housing, public services and recreation, utilit ies and service systems, and wildfire, compared to the proposed project, but it would not achieve project Objective 1 and would not achieve Objective 4 to the same extent as the proposed project. It would result in marginally greater VMT impacts, and would still result in significant and unavoidable impacts on air quality and transportation. Therefore, this alternative would not achieve all project objectives or significantly reduce environmental impacts compared to the proposed project.

Between the Existing Culvert to Remain Alternative and the Alternative Unit Mix Alternative, the Existing Culvert to Remain Alternative would be environmentally superior because it would also reduce impacts to hydrology and water quality and transportation, and the reduction in impacts to air quality would be greater than with the Alternative Unit Mix Alternative. However, this alternative would not achi eve all of the project objectives; it would not meet the project’s goals of sufficient economic use of the City’s parcels, and would not provide the quantity of affordable housing units desired by the City compared to the proposed project. Additionally, this alternative would not avoid the significant

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and unavoidable impacts related to air quality and transportation that would similarly result from the proposed project.

Therefore, this alternative would not achieve all project objectives or significantly reduce environmental impacts compared to the proposed project.

1.3 Statement of Overriding Considerations
Pursuant to Public Resources Code Section 21081(b) and CE QA Guidelines Section 15093, the City of Thousand Oaks has balanced the benefits of the proposed project against the following significant and unavoidable impacts associated with the proposed project and has adopted all feasible mitigation measures with respect to transportation and air quality. The City has also examined alternatives to the proposed project. Based on Draft EIR Table 8-6, the “No Project” Alternative is the environmentally superior alternative, as it would avoid or lessen most of the project’s environmental impacts, including its significant and unavoidable transporta tion and air quality impacts, reducing them to less than significant levels. According to CEQA Guidelines Section 15126.6(e), “if the environmentally superior alternative is the 'no project' alternative, the EIR sh all also identify an environmentally superior alternative among the other alternatives.” Accordingly, the Existing Culvert to Remain Alternative is considered envi ronmentally superior to the proposed project, since this alternative would have less environmental impact compared to the proposed project with regard to energy, GHG emissions, hydrology and water qualit y, noise, population and housing, public services and recreation, utilities and service systems, and wildfire. Howeve r, it is acknowledged that impacts related to air quality would still be significant and unavoidable, with mitigation incorporated, and impacts related to transportation would still be significant and unavoidable, similar to the proposed project. Air quality and VMT impacts would be slightly reduced in comparison to the proposed project, due to the reduced unit count, commercial square footage, and grading, however, impacts would still be significant and unavoidable.

Regarding a Statement of Overriding Considerations, CEQA Guidelines Section 15093 provides:
x CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.”
x When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not avoided or substa ntially lessened, the agency shall state in writing the specific reasons to support its action based on the final EIR and/or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. x If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091.

1.3.1 Background
C E Q A r e q u i r e s d e c i s i o n m a k e r s t o b a l a n c e t h e b e n e f i t s o f the proposed project against its significant unavoidable environmental risks when determining whether to approve th e project. If the benefits of the project outweigh the significant unavoidable adverse effects, those effects ma y be considered “acceptable” (CEQA Guidelines Section 15093[a]). CEQA requires the agency to support, in writing, the specific reasons for considering a project acceptable when significant impacts are infeasible to mitigate. Such reasons must be based on substantial evidence in the Final EIR or elsewhere in the administrative record (CEQA Guidelines Section 15093[b]). The agency’s statement is referred to as a Statement of Overriding Considerations.

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The following sections provide a description of each of th e project’s significant and unavoidable adverse impacts and the justification for adopting a Statement of Overriding Considerations.

1.3.2 Significant and Unavoidable Adverse Impacts
The following impacts of the proposed project are considered significant, unavoidable, and adverse based on the Draft EIR, Final EIR, Mitigation Monitoring and Reporting Program, and the findings discussed in Section 1.2, Findings and Facts, of this document.

Air Quality
x Impact AQ-1: The proposed project would conflict with or obstruct implementation of the applicable air quality plan;
x Impact AQ-2: The proposed project would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainme nt under an applicable federal or State ambient air quality standard;
x Cumulative Impact (AQ-1): The proposed project, combined with other cumulative projects, would conflict with or obstruct implementation of the applicable air quality plan; and x Cumulative Impact (AQ-2): The proposed project, combined with other cumulative projects, would result in a cumulatively considerable net increase of any criteria pollutant for which the region is non-attainment under an applicable federal or State ambient air quality standard.

Transportation
x Impact T-2: The proposed project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b); and
x Cumulative Impact (T-2): The proposed project, combined with other cumulative projects, would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b).

1.3.3 Considerations in Support of the Statement of Overriding Considerations CEQA requires the lead agency to balance the benefits of a proposed project against its unavoidable environmental risks in determining whether to approve the project. After balancing the specific economic, legal, social, technological, and other benefits, including regionwide or Statewide environmental benefits, of the proposed project, the City has determined that the significant, unavoidable, adverse environmental impacts identified above are considered “acceptable” due to the following considerations, which outweigh the significant, unavoidable, adverse environmental impacts of the proposed project.

Incorporates Mitigation Measures and Alternatives Analysis The City finds that all feasible mitigation measures have been imposed to lessen project impacts; furthermore, that the alternatives to the project are infeasible because while they have similar or less environmental impacts, they do not meet project objectives or provide benefits to the same extent as the proposed project, or are otherwise socially or economically infeasible when compared to the project, as described in herein.

Statement of Overriding Considerations No. 1: Contributes Towards Meeting the City’s Housing Goals and RHNA Requirements.

As recognized by the California Legislature, “California has a housing supply and affordability crisis of historic proportions.” (Government Code Section 65589.5; see also Government Code Section 65009 [“The Legislature finds and declares that there currently is a housing crisis in California and it is essential to reduce delays and restraints upon expeditiously completing housing projects”].) In order to alleviate that crisis, the Legislature has taken a number of

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steps to ensure that local jurisdictions accommodate their sh are of needed housing, including by requiring that cities adopt, and update according to a fixed schedule, the Housing Element portion of their General Plan, and submit said element to the State Department of Housing and Community Development for review (Government Code Section 65585). Among other items, the Housing Element is required to demonstrate how the city will meet its share of regional housing needs, known as its RHNA (Government Code Sectio n 65583). If a city does not have adequate sites to accommodate its RHNA, it is required to rezone sites in order to meet its allocation (see Government Code Section 65583(c)(1)(A); see also Government Code Section 65913.1 [requiring cities to “zone sufficient vacant land for residential use”]). More specifically, the RHNA is an asse ssment process performed period ically as part of housing element and general plan updates at the local level. The RHNA quantifies the housing need by income group within each jurisdiction during specific planning periods. The 6th RHNA cycle covers the housing element planning period from October 2021 through October 2029. The 6th Cycle Final RHNA Allocation Plan was approved by the HCD on March 22, 2021. SCAG prepared the region’s RHNA allocation in October 2020 to address the State-mandated regional housing need determination for the 2021-2029 planning period and to fairly distribute the housing needs throughout the region.

The RHNA allows communities to anticipate growth so that collectively, the region can grow in ways that enhance quality of life, improve access to jobs, promote transportation mobility, and address social equity and fair share housing needs.

The RHNA represents the minimum number of housing units each community is required to plan for through a combination of: (1) zoning adequate sites at suitable densities to provide affordability, and (2) housing programs to support production of below-market rate units. The City of Thousand Oaks’ allocations from the 6th Cycle RHNA, distributed among the four income categories, are shown in Draft EIR Table 5.12-3, City of Thousand Oaks 2021-2029 RHNA Allocation. As shown in Table 5.12-3, the following units are required: (1) 368 units for extremely low income; (2) 367 units for very low income; (3) 494 units for low income; (4) 532 units for moderate income; and (5) 860 units for above moderate income. Given that the project would provide up to 240 housing units, including 39 deed-restricted units for low-income households (26 units within Building E2 and 13 units within Building E3), the project would be a step towards meeting the City’s affordable housing allocations and contribute to the City’s future housing goals.

Statement of Overriding Considerations No. 2: Contribute Towards Economic Development.

The proposed project would create a new pedestrian-oriented downtown, including new construction facilitating mixed-use residential, a hotel, commerci al, office, and entertainment uses, partial reconstruction of the existing City Hall, development of public amenities such as a park pl aza and outdoor amphitheatre, as well as supporting infrastructure such as new roadways , reconfigured utilities, and stormwater management. The proposed non- residential land uses are forecast to create approximately 231 new jobs through project buildout. The new commercial uses, along with new employee spending within City limits, would generate additional sales and use tax revenue.

Additionally, the 142-key hotel would provide occupancy tax that would benefit the City’s tax base. Once constructed, the proposed project would generate additional on-site revenue through additional property tax revenues for the City.

Statement of Overriding Considerations No. 3: Provide Open Space and Recreational Amenities in an Underserved Area.

The proposed project would allow development of on-site open space through a combination of common and private recreation areas, including a 2.16-acre park (i.e., Carpente r Park), which would be developed on-site. Carpenter Park would feature community-focused amenities and accommodate up to 70 vendor tents, 100 square feet in size, during special events such as farmers' markets and seasonal community events. Additional key features of Carpenter Park would include a park restaurant (Building B1), splash pad, raised decks, oak tree event deck, sculptural shade canopy, play areas, multi-purpose lawn, terraced seat walls, and a pedestrian-only emergency access road (i.e., East Main Road).

As such, the project would introduce new public open spac e and recreational amenities to the project area, which currently has minimal publicly accessible open space/recreational amenities.

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1.3.4 Conclusion
Pursuant to Public Resources Code Section 21081(b) and CEQA Guidelines Section 15093, the City Council has balanced the project’s benefits against the significant unavoidable project impacts. The City Council finds that the project’s benefits of implementing the proposed project outweigh the project’s significant unavoidable impacts, and those impacts, therefore, are considered acceptable in light of the project’s benefits. The City Council finds that each of the benefits described above is an overriding consideration, independent of the other benefits, that warrants approval of the project notwithstanding the project’s significant unavoidable impacts.

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cdd:440-35/kr/H:COMMON/City Council/Agenda Packet/2026/2026-06-23/Downtown Project/DTTO SP-2025-70001 Attach 5 Exhibit C of Attachment 2.pdf/pz (FILE ID: SP-2025-70001)

Thousand Oaks City CouncilJune 23, 2026

Thousand Oaks City Council
June 23, 2026