1 project information

CITY OF ANAHEIM Environmental Checklist Form

1 Project Information

PROJECT CASE AND NUMBERS:

Development Project - DEV2018-00059

Conditional Use Permit - CUP3516A

LEAD AGENCY NAME AND ADDRESS:

City of Anaheim

200 S Anaheim Boulevard, Suite 162

Anaheim, CA 92805

CONTACT PERSON AND PHONE NUMBER:

Andy Uk, Associate Planner

(714) 765-5238

[email protected]

PROJECT NAME:

Extra Space Storage Facility Expansion

PROJECT APPLICANT:

NAME: Mark Glasmire

COMPANY: Extra Space Properties

ADDRESS: 2795 E Cottonwood Pkwy, #400

CITY/ST/ZIP: Salt Lake City, 84121

EMAIL: [email protected]

PHONE: 801-365-4542

AUTHORIZED AGENT:

NAME: Kevin Prociw

COMPANY: The Monolith Group

ADDRESS: 20645 N. Pima Rd, Suite #145

CITY/ST/ZIP: Scottsdale, AZ 85255

EMAIL: [email protected]

PHONE: 480-719-300

mailto:[email protected]

City of Anaheim Extra Space Storage Facility Expansion

DEV2018-00059 Initial Study/Mitigated Negative Declaration

SITE ADDRESS:

1705 S State College Blvd, Anaheim, CA 92806

ASSESSOR’S PARCEL NUMBER:

082-250-84, 082-261-13

1.1 PROJECT OVERVIEW

1.1.1 Regional Setting

The project site is located in Orange County within the eastern portion of the City of

Anaheim (City). The City is located approximately seven (7) miles northwest from

Downtown Santa Ana and 23 miles southeast from Downtown Los Angeles. The cities of

Yorba Linda, Placentia, Fullerton, Buena Park, Cypress, Stanton, Garden Grove, and

Orange and unincorporated Orange County border the City of Anaheim. Interstate 5 (I -5)

and State Routes (SR) 39, 55, 57, 90, 91, and 241 provide regional access to the City of

Anaheim.

1.1.2 Local Setting

The Extra Space Storage Facility is located at 1705 South State College Boulevard, City

of Anaheim, Orange County, California. The 5.32-acre Project Site is located on the east

side of State College Boulevard (Assessor’s Parcel Numbers [APN]: 082-250-84, 082-261-

13), south of the AT&SF railroad. Major intersections are Cerritos Avenue to the North and

Katella Avenue to the south. The nearest freeways to the Project Site are Interstate (I) 5 to

the west and State Route 57 (SR-57) to the east. The Metrolink rail mainline (AT&SF

Railroad) abuts the project site to the north; industrial uses are located north of the railroad.

Residential and industrial land uses are located to the west, southwest and south,

respectively to the project site. State College Boulevard borders the project site to the east;

a commercial center with a hotel, church, offices, retail and restaurants are located further

east across State College Boulevard. The project site is in an urbanized area in the City.

Figure 1 - Project Site, shows the project site and its relative location.

1.2 ENVIRONMENTAL SETTING

1.2.1 Existing Land Use

The project site is 5.32-acres, consisting of two (2) parcels (APN: 082-250-84, 082-261-

13). The existing use at the project site is an Extra Space Storage facility.

1.2.2 Existing General Plan Land Use and Zoning



The General Plan designates the Project Site for Office-Low land use. The Project Site is

within the Industrial (I) Zone and the Office District of the Platinum Triangle Mixed Use

(PTMU) Overlay Zone.



Figure 1 – Project Site



1.3 PROJECT DESCRIPTION

1.3.1 Proposed City Approvals

Adoption of a Mitigated Negative Declaration and a Mitigation Monitoring and

Reporting Program

Approval of a Conditional Use Permit (CUP) to amend a previously approved CUP to

permit the expansion of the Extra Space Storage Facility with a 0.60 Floor Area Ratio

(FAR) (147,670 sq. ft.) in the Industrial (I) Zone, where the Anaheim Municipal Code

permits a maximum FAR of 0.50 (121,044 sq. ft.).

1.3.2 Description of the Project

The existing Extra Space Storage facility has five self-storage buildings, which contain 505

storage units and a main office, totaling 63,491 square-feet (sq. ft.) of building floor area.

The Applicant proposes to demolish two buildings and a portion of a third building at the

existing Extra Space Storage facility to construct five new self-storage buildings, including

one three-story, and four single-story buildings. The proposed project would increase the

total floor area to 147,670 sq. ft. and provide 1,278 storage units in eight buildings. The

proposed project would exceed the permitted FAR of 0.5 (121,044 sq. ft.), with a proposed

FAR of 0.6 (147,670 sq. ft.). The proposed project would provide forty-five parking spaces,

which includes three disabled parking spaces. Figure 2 – Site Plan, shows the building

footprint of the proposed project.

1.3.3 Project Phasing

The applicant anticipates starting construction in August 2020 and completing construction

in approximately nine months. Construction activities would include two weeks of

demolition, one week for site preparation, six weeks for excavation and grading, twenty-

four weeks of building construction, two weeks of paving and four weeks of architectural

coating. No import of soil would be required. Construction activities would require

construction equipment such as an excavator, graders, rough terrain forklifts, rollers, skid

steer loads, and generator sets. Construction would occur five-days a week. In accordance

with the Anaheim Municipal Code (AMC) Chapter 6.70, construction crews would restrict

their activities to between 7:00 a.m. and 7:00 p.m. on weekdays. The applicant anticipates

operation of the proposed project to commence in 2021.



Figure 2 – Site Plan



2 Environmental Checklist 2.1 Other Project Information

1. Other Public Agencies Whose Approval is Required

Santa Ana Regional Water Quality Control Board (RWQCB). The proposed

project requires a National Pollution Discharge Elimination System (NPDES)

Permit and Construction General Permit.

South Coast Air Quality Management District (SCAQMD): Compliance with

Air Quality permits for demolition and construction.

2. Have California Native American tribes traditionally and culturally affiliated with

the project area requested consultation pursuant to Public Resources Code section

21080.3.1? If so, is there a plan for consultation that includes, for example, the

determination of significance of impacts to tribal cultural resources, procedures

regarding confidentiality, etc.?

City staff contacted the California Native American Heritage Commission to request a

list of California Native American tribes traditionally and culturally affiliated with the

project area. The City has notified tribal groups who submitted a letter requesting

notification in compliance with Assembly Bill (AB) 52 and received a consultation

request from two tribes;

Gabrieleño Band of Mission Indians - Kizh Nation.

Juaneno Band of Mission Indians, Acjachemen Nation - Belardes.

As such, the City consulted with the applicable tribes. City staff and the applicable tribes

deemed consultations complete. Therefore, the City has complied with AB 52.



2.2 Environmental Determination

The environmental factors checked below would be potentially affected by this project, involving at least

one impact that is a “Potentially Significant Impact,” as indicated by the checklist on the following pages.

☐ Aesthetics ☐ Agriculture / Forestry Resources ☐ Air Quality

☐ Biological Resources ☐ Cultural Resources ☐ Energy

☐ Geology / Soils ☐ Greenhouse Gas Emissions ☐ Hazards / Hazardous Materials

☐ Hydrology / Water Quality ☐ Land Use / Planning ☐ Mineral Resources

☐ Noise ☐ Population / Housing ☐ Public Services

☐ Recreation ☐ Transportation ☐ Tribal Cultural Resources

☐ Utilities / Service Systems ☐ Wildlife ☐ Mandatory Findings of

Significance

DETERMINATION: On the basis of this initial evaluation:

☐ I find that the proposed project COULD NOT have a significant effect on the environment, and a

NEGATIVE DECLARATION will be prepared.

☒ I find that although the proposed project could have a significant effect on the environment, there

will not be a significant effect in this case because revisions in the project have been made by or

agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be

prepared.

☐ I find that the proposed project MAY have a significant effect on the environment, and an

ENVIRONMENTAL IMPACT REPORT is required.

☐ I find that the proposed project MAY have a "potentially significant" or "potentially significant

unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed

in an earlier document pursuant to applicable legal standards, and 2) has been addressed by

mitigation measures based on the earlier analysis as described on attached sheets. An

ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that

remain to be addressed.

☐ I find that although the proposed project could have a significant effect on the environment, because

all potentially significant effects (a) have been analyzed adequately in an earlier EIR or

NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or

mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or

mitigation measures that are imposed upon the proposed project, nothing further is required.

05/06/2020 Signature of City of Anaheim Representative Date

ANDY UK, ASSOCIATE PLANNER 714-765-5238

Printed Name / Title Phone Number

2.3 ENVIRONMENTAL IMPACTS EVALUATION



1) All answers must take account of the whole action involved, including offsite as well as

onsite, cumulative as well as project-level, indirect as well as direct, and construction as

well as operational impacts.

2) A list of “Supporting Information Sources” must be attached and other sources used or

individuals contacted should be cited in the Narrative Summary for each section.

3) Response Column Heading Definitions:

a) Potentially Significant Impact is appropriate if there is substantial evidence that an

effect may be significant. If there are one or more “Potentially Significant Impact”

entries when the determination is made, an EIR is required.

b) Potentially Significant Unless Mitigation Incorporated applies where the

incorporation of mitigation measures has reduced an effect from “Potentially Significant

Impact” to a “Less Than Significant Impact”. The mitigation measures must be

described, along with a brief explanation of how they reduce the effect to a less than

significant level.

c) Less Than Significant Impact applies where the project creates no significant impacts,

only Less Than Significant impacts.

d) No Impact applies where a project does not create an impact in that category. A “No

Impact” answer is adequately supported if the referenced information sources show that

the impact simply does not apply to projects like the one proposed (e.g., the project falls

outside of a fault rupture zone). A “No Impact” answer should be explained where it is

based on project-specific factors as well as general standards (e.g., the project will not

expose sensitive receptors to pollutants, based on a project-specific screening analysis).

4) Earlier analyses may be used where, pursuant to a tiering, program EIR, Master EIR, or

other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative

declaration (Section 15062(c)(3)(D)). In this case, a brief discussion should identify the

following:

a) Earlier Analysis Used. Identify and state where they are available for review.

b) Impacts Adequately Addressed. Identify which effects from the checklist were within the

scope of and adequately analyzed in an earlier document pursuant to applicable legal

standards, and state whether such effects were addressed by mitigation measures based on

the earlier analysis.

c) Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures

Incorporated”, describe the mitigation measures which were incorporated or refined from

the earlier document and the extent to which they address site-specific conditions for the

project.



Incorporate into the checklist any references to information sources for potential impacts

(e.g., the General Plan, zoning ordinance). Reference to a previously prepared or outside

document should, where appropriate, include a reference to the page or pages where the

statement is substantiated.

The explanation of each issue should identify:

a) The significance criteria or threshold, if any, used to evaluate each question; and

b) The mitigation measure identified, if any, to reduce the impact to less than significant.



3 Environmental Checklist This section provides an evaluation of the impact categories and questions contained in the

checklist and identifies mitigation measures, if applicable.

3.1 Aesthetics

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No

Impact Except as provided in Public Resources Code Section 21099, would the project:

a) Have a substantial adverse effect on a scenic

vista? ☐ ☐ ☐ ☒

b) Substantially damage scenic resources,

including, but not limited to, trees, rock

outcroppings, and historic buildings within a

state scenic highway?

☐ ☐ ☐ ☒

c) In nonurbanized areas, substantially degrade the

existing visual character or quality of public

views of the site and its surroundings? (Public

views are those that are experienced from

publicly accessible vantage point). If the project

is in an urbanized area, would the project

conflict with applicable zoning and other

regulations governing scenic quality?

☐ ☐ ☐ ☒

d) Create a new source of substantial light or glare

which would adversely affect day or nighttime

views in the area? ☐ ☐ ☒ ☐

a) No Impact. The proposed project is located in a relatively flat, built-out area of the City.

There are no scenic views on or near the project site. The City’s General Plan does not

identify any portions of the project site or surrounding areas as a scenic vista.1 Therefore,

development of this project will not affect a scenic vista. Therefore, no impacts would

occur and mitigation measures are required.

b) No Impact. The proposed project site is not located near a designated or eligible

California scenic highway and there are no rock outcroppings or historic buildings onsite.

The closest scenic highway to the site is SR-91, located almost six miles east of the project

site. The project would not affect any scenic resources.23 Therefore, no impacts would

occur and mitigation measures are required.

c) No Impact. The proposed project is within an urbanized area and as discussed in Section

3.11(b) Land Use and Planning; the proposed project would be consistent with applicable

1City of Anaheim, General Plan and Zoning Code Update Environmental Impact Report No. 330. May 25, 2004.

Accessible at http://www.anaheim.net/913/Environmental-Impact-Report, Accessed on April 6, 2020. 2 Ibid.

3California Department of Transportation (DOT). California Scenic Highway Mapping System, 2020. Accessible at

http://www.dot.ca.gov/hq/LandArch/16_livability/scenic_highways/index.htm, Accessed April 6, 2020.

http://www.anaheim.net/913/Environmental-Impact-Report

http://www.dot.ca.gov/hq/LandArch/16_livability/scenic_highways/index.htm



General Plan Land Use designation and zoning. The proposed project would not conflict

with the existing visual character of the area or with the Urban Design Element of the

City’s General Plan. Furthermore, the Anaheim Municipal Code (AMC) does not include

other regulations governing scenic quality. The proposed project would not conflict with

applicable zoning or other regulations governing scenic quality. Therefore, no impact

would occur and no mitigation measures are required.

d) Less-than-significant impact.

Construction light and glare

While construction would not occur during nighttime hours, the proposed project could

use construction-related nighttime lighting at the construction site for safety and security

purposes. However, all temporary construction lighting would be set up and removed upon

completion of construction. Additionally, the project site is an urbanized setting

characterized by a moderate amount of nighttime lighting, so project construction lighting

would not adversely affect daytime or nighttime views in the area. Therefore, impacts

would be less-than-significant and no mitigation measures are required.

Operational light and glare

The project site is currently an existing Extra Space Storage facility. The proposed project

would demolish two buildings and a portion of a third building of the existing Extra Space

Storage facility and construct five new self-storage buildings, including one 3-story, and

four single-story buildings, at the Extra Space Storage facility. The proposed project would

not substantially alter the visual characteristic of the project site and the current use of the

site as a storage facility would not change. However, the improvements at the project site,

as result of the proposed project would include new lighting installed for parking spaces

and for exterior building illumination for nighttime purposes. However, these light sources

would not be significant and would comply with the City’s municipal code. Daytime glare

is most often associated with mid- to high-rise buildings with exterior façades comprised

largely or entirely of highly reflective glass or other reflective materials from which the

sun can reflect, particularly following sunrise and prior to sunset. The proposed project

includes a three-story building, which would be finished in neutral tone colors and would

include non-reflective glass on all sides of the structure. The proposed project would not

generate excessive lighting or glare that would adversely affect daytime views in the area.

Therefore, impacts would be less-than-significant and no mitigation measures are

required.



3.2 Agriculture and Forestry Resources

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No

Impact In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to

the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of

Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether

impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to

information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of

forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest

carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would

the project: a) Convert Prime Farmland, Unique Farmland, or

Farmland of Statewide Importance (Farmland),

as shown on the maps prepared pursuant to the

Farmland Mapping and Monitoring Program of

the California Resources Agency, to non-

agricultural use?

☐ ☐ ☐ ☒

b) Conflict with existing zoning for agricultural

use, or a Williamson Act contract? ☐ ☐ ☐ ☒

c) Conflict with existing zoning for, or cause

rezoning of, forest land (as defined in Public

Resources Code Section 12220(g)), timberland

(as defined by Public Resources Code

Section 4526), or timberland zoned Timberland

Production (as defined by Government Code

Section 51104(g))?

☐ ☐ ☐ ☒

d) Result in the loss of forest land or conversion of

forest land to non-forest use? ☐ ☐ ☐ ☒

e) Involve other changes in the existing

environment which, due to their location or

nature, could result in conversion of Farmland,

to non-agricultural use or conversion of forest

land to non-forest use?

☐ ☐ ☐ ☒

a-e) No Impact. The Department of Conservation’s most recent Farmland Mapping and

Monitoring Program map for Orange County identifies the project site as “urban and built-

up land.”4 The project site and surrounding areas do not contain agricultural uses or related

operations, or forest land. Therefore, the project would not convert Prime Farmland,

Unique Farmland, or Farmland of Statewide Importance to non-agricultural uses. No

agricultural zoning is present in the surrounding area and no nearby lands are enrolled

under the Williamson Act.5 Therefore, no impact would occur and no mitigation measures

are required.

4California Department of Conservation (DOC) Agricultural Preserves 2004, Williamson Act Parcels, Orange

County, California. Accessible at ftp://ftp.consrv.ca.gov/pub/dlrp/wa/Orange_WA_03_04.pdf, Accessed on April 6,

2020. 5Ibid

ftp://ftp.consrv.ca.gov/pub/dlrp/wa/Orange_WA_03_04.pdf



3.3 Air Quality

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No

Impact Where available, the significance criteria established by the applicable air quality management district or air pollution

control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct implementation of the

applicable air quality plan? ☐ ☐ ☒ ☐

b) Result in a cumulatively considerable net

increase of any criteria pollutant for which the

project region is non-attainment under an

applicable federal or state ambient air quality

standard?

☐ ☐ ☒ ☐

c) Expose sensitive receptors to substantial

pollutant concentrations? ☐ ☐ ☒ ☐

d) Result in other emissions (such as those leading

to odors) adversely affecting a substantial

number of people? ☐ ☐ ☒ ☐

The primary air pollutants of concern for which ambient air quality standards (AAQS)

have been established are ozone (O3), carbon monoxide (CO), coarse inhalable particulate

matter (PM10), fine inhalable particulate matter (PM2.5), sulfur dioxide (SO2), nitrogen

dioxide (NO2), and lead (Pb). The federal and California Clean Air Act classifies areas as

either in attainment or nonattainment for each criteria pollutant based on whether the

AAQS have been achieved. The South Coast Air Basin (SCAB), which the South Coast

Air Quality Management District (SCAQMD) manages, is designated nonattainment for

O3, and PM2.5 under the California and National AAQS, nonattainment for PM10 under

the California AAQS, and nonattainment for lead (Los Angeles County only) under the

National AAQS. The applicable air quality plan is the SCAQMD 2016 Air Quality

Management Plan (AQMP). The SCAQMD bases the AQMP on regional growth

population and employment projections provided in the Southern California Association

of Governments (SCAG) 2016-2040 Regional Transportation Plan/Sustainable

Communities Strategy (RTP/SCS). The 2016 AQMP provides policies and control

measures that will reduce emissions to attain both state and federal ambient air quality

standards by their applicable deadlines. Environmental review of individual projects

within the SCAB must demonstrate that the proposed project will not exceed daily

construction and operational emissions thresholds, as established by SCAQMD. The

environmental review must also demonstrate that individual projects would not increase

the number or severity of existing air quality violations. The SCAQMD CEQA Air Quality

Handbook identifies two key indicators of consistency with the AQMP:

1. Whether the project would result in an increase in the frequency or severity of

existing air quality violations or cause or contribute to new violations, or delay timely

attainment of air quality standards or the interim emission reductions specified in the

air quality plan; and

2. Whether the project would exceed the forecasted growth incorporated into the



AQMP via the RTP/SCS.

The SCAQMD has developed regionally specific air quality significance thresholds to

assess potential impacts that may result from construction and operation of projects. Daily

emissions of volatile organic compounds (VOC), nitrogen oxides (NOX), carbon

monoxide (CO), sulfur oxides (SOX), and respirable particulate matter less than ten (10)

microns in diameter (PM10) and fine particulate matter less than 2.5 microns in diameter

(PM2.5) should be quantified and assessed on both regional and localized scales, in

accordance with SCAQMD methodology.

The primary guidance is contained in the SCAQMD CEQA Air Quality Handbook.6

SCAQMD has established 500-meters or 1,640-feet, as the distance for assessing localized

air quality impacts. The following sensitive receptors are located within 500-meters of the

project site:

Residential

Residences (Jefferson Platinum Triangle Apartments) located adjacent to the

project site.

Residences (Park Viridian) located approximately 740-feet southwest of the project

site

Recreational/Open Space

Magnolia Park located approximately 450-feet southwest of the project site.

Localized Significance Threshold

The Localized Significance Threshold (LST) Methodology provides a look-up table for

construction and operational emissions. The LST Methodology bases the emissions on the

emission rate, location, and distance from receptors; and, provides a methodology for air

dispersion modeling to evaluate whether a construction or operation could cause an

exceedance of an ambient air quality standard. Staff analyzed the local air quality emissions

from construction using the SCAQMD’s Mass Rate Localized Significance Threshold

Look-Up Tables and the methodology described in Localized Significance Threshold

Methodology to determine if the daily emissions of CO, NOx, PM10, and PM2.5, from the

proposed project would result in a significant impact to local air quality.7

a) Less-than-significant impact.

6SCAQMD, Air Quality Analysis Guidance Handbook, Accessible at http://www.aqmd.gov/home/rules-

compliance/ceqa/air-quality-analysis-handbook, Accessed on April 22,2020. 7SCAQMD, Localized Significance Thresholds, Accessible at http://www.aqmd.gov/home/rules-

compliance/ceqa/air-quality-analysis-handbook/localized-significance-thresholds, Accessed on April 22, 2020.

http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook


http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/localized-significance-thresholds




Construction

Construction of the proposed project has the potential to create air quality impacts from

the use of heavy-duty construction equipment and through vehicle trips generated by

construction workers and haul trucks traveling to and from the project site. Fugitive dust

emissions would primarily result from site preparation (e.g., demolition and grading)

activities. NOX emissions would predominantly result from the use of construction

equipment and haul truck trips. The assessment of construction air quality impacts

considers all of these emissions sources. Construction emissions can vary from day-to-

day, depending on the level of activity, the specific type of operation; and, for dust,

prevailing weather conditions.

It is mandatory for all construction projects in the SCAB to comply with SCAQMD Rule

403 for Fugitive Dust. Rule 403 control requirements include measures to prevent the

generation of visible dust plumes. Measures include, but are not limited to, applying soil

binders to uncovered areas, re-establishing ground cover as quickly as possible, utilizing

a wheel washing system or other control measures to remove bulk material from tires and

vehicle undercarriages before vehicles exit the project site, and maintaining effective cover

over exposed areas. Compliance with Rule 403 would reduce regional PM2.5 and PM10

emissions associated with construction activities by approximately 61 percent.

The air quality analysis that staff conducted for the proposed project is consistent with the

methods described in the SCAQMD CEQA Air Quality Handbook (1993 edition), as well

as the updates to the CEQA Air Quality Handbook provided on the SCAQMD website.

The SCAQMD recommends the use of the California Emissions Estimator Model

(CalEEMod, version 2016.3.2) as a tool for quantifying emissions of air pollutants

generated by constructing and operating development projects. The applicant provided

Project-specific information describing the schedule of construction activities and the

equipment inventory required.

The applicant expects construction to begin in August 2020 and take approximately nine

months. Construction activities would include two weeks of demolition, one week for site

preparation, six weeks for excavation and grading, twenty-four weeks of building

construction, two weeks of paving and four weeks of architectural coating. No import of

soil would be required. Construction activities would require construction equipment such

as an excavator, graders, rough terrain forklifts, rollers, skid steer loads, and generator

sets. Maximum daily emissions for each construction activity were estimated based on

heavy-duty equipment use and fugitive dust (on-site) and vehicular travel to and from the

project site (off-site).



TABLE 1 – REGIONAL CONSTRUCTION EMISSIONS

Construction Activity

pounds per day (lbs/day)

VOC NOX CO SOX PM10 PM2.5

Demolition (2020) 0.6 5.6 5.9 >0.1 2.5 0.6

Site Preparation (2020) 0.2 2.4 3.4 >0.1 0.1 0.1

Grading (2020) 1.0 10.8 7.7 >0.1 1.0 0.5

Building Construction (2020) 1.5 13.4 12.3 >0.1 1.4 0.8

Building Construction (2021) 1.4 12.3 14.9 >0.1 1.4 0.8

Paving (2021) 0.5 4.0 4.7 >0.1 0.4 0.2

Architectural Coating (2021) 55.5 4.1 5.2 >0.1 0.4 0.3

Maximum Emission 55.5 13.4 14.9 >0.1 2.5 0.8

Significance Threshold 75 100 550 150 150 55

Exceed Threshold? No No No No No No Staff adjusted CalEEMod emissions for fugitive dust to account for a 61 percent control efficiency associated with SCAQMD Rule 403.

CalEEMod emissions modeling files can be found in Appendix A

Table 1 (above) shows the maximum unmitigated daily regional emissions for activity.

Maximum daily emissions of all air pollutants would remain below all applicable regional

SCAQMD thresholds. In addition to maximum daily regional emissions, staff quantified

maximum localized (on-site) emissions for each construction activity.

Table 2 presents the results of emissions modeling from on-site construction sources. The

LSTs selected for comparison values are for a five-acre construction site, in Sensitive

Receptor Area (SRA) 17 with a sensitive receptor within 25-meters.8 Maximum on-site

emissions during project construction would not exceed the applicable LST values. The

proposed project would not exceed applicable SCAQMD thresholds during construction

activities. Construction activities would not produce a concentration of emissions that

would cause harmful effects to the health and well-being to the sensitive receptors

identified within 500-meters of the project site. Therefore, impacts would be less-than-

significant and no mitigation measures are required.

8Ibid



Operation

The proposed project would generate regional operational emissions from vehicle trips,

area sources, and energy use. The proposed land uses would generate 127 daily trips. It is

likely that the proposed project would include forklifts powered with natural gas or

electricity; and therefore, emissions would be negligible. The CalEEMod program

generates estimates of emissions from energy use based on the land use type and size of

the project. Table 3 presents the CalEEMod results for operation of the proposed project.

Operational activities would not produce a concentration of emissions that would cause

harmful effects to the health and well-being to the sensitive receptors identified within

500-meters of the project site. Future occupation of the proposed project would not result

in daily emissions that exceed any applicable SCAQMD thresholds. Therefore, impacts


TABLE 2 - LOCALIZED CONSTRUCTION EMISSIONS

Construction Activity


NOX CO PM10 PM2.5

Demolition (2020) 5.6 5.9 2.5 0.6

Site Preparation (2020) 2.4 3.4 0.1 0.1

Grading (2020) 10.8 7.7 1.0 0.5

Building Construction (2020) 13.4 12.3 1.4 0.8

Building Construction (2021) 12.3 14.9 1.4 0.8

Paving (2021) 4.0 4.7 0.4 0.2

Architectural Coating (2021) 4.1 5.2 0.4 0.3

Maximum Emission 13.4 14.9 2.5 0.8

Significance Threshold 183 1,253 13 7.0

Exceed Threshold? No No No No Staff adjusted CalEEMod emissions for fugitive dust to account for a 61 percent control efficiency associated with

SCAQMD Rule 403.

LST values based for a five (5)-acre site in SRA 17.

CalEEMod Emissions modeling files can be found in Appendix A



TABLE 3 - DAILY OPERATIONAL EMISSIONS

Operational Emissions Source


VOC NOX CO SOX PM10 PM2.5

Area Sources 0.6 >0.1 >0.1 >0.1 >0.1 >0.1

Energy Sources >0.1 0.2 0.1 >0.1 >0.1 >0.1

Mobile Sources >0.1 0.3 0.7 >0.1 0.2 >0.1

Total Daily Operational Emission 0.6 0.5 0.8 >0.1 0.2 >0.1

Significance Threshold 55 55 550 150 150 55

Exceed Threshold? No No No No No No CalEEMod emissions modeling files can be found in Appendix A

The second consistency criterion requires that the proposed project not exceed the

assumptions in the AQMP. The applicant anticipates that the proposed project would have

three employees during operation of the facility. The proposed small-scale infill

development of this size has no potential to interfere with growth projections and would

have no potential to result in growth that would exceed the projections incorporated in the

AQMP. Therefore, impacts would be less-than-significant and no mitigation measures are

required.

b) Less-than-significant impact. The SCAQMD designates SCAB as nonattainment of the

California Ambient Air Quality Standards and National Ambient Air Quality Standards

for O3, PM10, and PM2.5. There is an ongoing regional cumulative impact associated with

these air pollutants. The SCAQMD guidance on cumulative impacts allows an individual

project to emit allowable quantities of these pollutants on a regional scale without

significantly contributing to the cumulative impacts. Because no single project by itself

would result in nonattainment of regional air quality standards, and that all past, present

and future development projects need to be cumulatively considerable. As discussed

above, air pollutant emissions associated with construction of the proposed project would

not exceed any applicable SCAQMD air quality thresholds of significance. The SCAQMD

does not consider individual project emissions of lesser magnitude than the mass daily

thresholds to be cumulatively considerable. The proposed project would not result in a

cumulatively considerable net increase of nonattainment pollutants. Therefore, impacts

would be less-than-significant and no mitigation measures would be required.

c) Less-than-significant impact. A significant impact may occur when a project would

generate pollutant concentrations to a degree that would significantly affect sensitive

receptors, which include populations that are more susceptible to the effects of air

pollution than the population at large. The analysis below addresses exposure of sensitive

receptors for the following situations: Carbon Monoxide (CO) hotspots; localized

emissions concentrations, toxic air contaminants (TACs, specifically diesel PM) from on-

site construction; and asbestos during demolition.

CO Hot Spots. An analysis of CO “hot spots” is needed to determine whether the change

in the level of service (LOS) of an intersection due to the proposed project would have the



potential to result in exceedances of the CAAQS or NAAQS. CO exceedances are caused

by vehicular emissions, primarily when vehicles are idling at intersections. Vehicle

emissions standards have become increasingly stringent in the last 20 years. Currently, the

CO standard in California is a maximum of 3.4 grams per mile for passenger cars

(requirements for certain vehicles are more stringent). With the turnover of older vehicles,

introduction of cleaner fuels, and implementation of control technology on industrial

facilities, CO concentrations have steadily declined. Accordingly, with the steadily

decreasing CO emissions from vehicles, even very busy intersections do not result in

exceedances of the CO standard.

The SCAQMD re-designated the SCAB as in attainment in 2007 for CO; and therefore,

the SCAQMD’s AQMP no longer addresses CO. The 2003 AQMP is the most recent

version that addresses CO concentrations. As part of the SCAQMD CO Hotspot Analysis,

the SCAQMD modeled the Wilshire Boulevard/Veteran Avenue intersection, one of the

most congested intersections in Southern California with an average daily traffic (ADT)

volume of approximately 100,000 vehicles, for CO concentrations. This modeling effort

identified a CO concentration high of 4.6 ppm, which is well below the 35-ppm federal

standard. The proposed project considered herein would not produce the volume of traffic

required to generate a CO hot spot in the context of SCAQMD’s CO Hotspot Analysis.

The findings of the trip generation analysis (Appendix F) anticipates that the proposed

project will produce approximately 127 daily trips. Based on this volume of trips the CO

hotspots and localized air quality impacts related to mobile‐source emissions would not

occur at any intersections in the project vicinity resulting from the proposed project.


required.

Toxic Air Contaminants. Construction would result in the generation of diesel particulate

matter (diesel PM) emissions from the use of off-road diesel equipment required for

grading and excavation, paving, and other construction activities. The amount to which

the receptors are exposed (a function of concentration and duration of exposure) is the

primary factor used to determine health risk (i.e., potential exposure to toxic air

contaminant emission levels that exceed applicable standards). The California Office of

Environmental Health Hazard Assessment (OEHHA) developed a cancer risk factor and

noncancer chronic reference exposure level for Dielsel PM and the links health-related

risks associated with diesel-exhaust emissions to long-term exposure and the associated

risk of contracting cancer.9 The use of diesel-powered construction equipment would be

temporary and episodic. The duration of exposure would be short, exhaust from

construction equipment is highly dispersive, and the concentration of diesel PM dissipates

rapidly. Current models and methodologies for conducting health risk assessments are

associated with longer-term exposure periods of 9, 30, and 70 years, which do not correlate

well with the temporary and highly variable nature of construction activities. Project

construction involves phased activities in several areas across the site and the proposed

project would not require the extensive use of heavy-duty construction equipment or diesel

trucks in any one location over the duration of development, which would limit the

9California Office of Environmental Health Hazard Assessment, Air Toxics Hotspots Program. February 2015.

Accessible at https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, Accessed on April 8, 2020.



exposure of any proximate individual sensitive receptor to TACs. Construction of the

proposed project would be approximately nine months and over the course of construction

activities, average diesel PM emissions would be approximately 0.6 pounds per day. It is

unlikely that diesel PM concentrations would be of any public health concern during the

nine month construction period, and diesel PM emissions would cease upon completion

of construction activities. Therefore, impacts would be less-than-significant and mitigation

measures are not required.

Localized Significance Threshold. As discussed in Section 3.3(a) Air Quality, construction

and operational emissions would not exceed SCAQMD LSTs. The proposed project would

not result in significant localized construction or operational emissions. Therefore,

impacts would be less-than-significant and no mitigation measures are required.

d) Less-than-significant impact. The SCAQMD CEQA Air Quality Handbook identifies

certain land uses as sources of odors. These land uses include agriculture, wastewater

treatment plant, food processing plants, chemical plants, composting, refineries, landfills,

dairies, and fiberglass molding. The proposed project does not propose to include any

odor-inducing uses on the project site. During construction-related activities, the proposed

project may produce some odors (not substantial pollutant concentrations) typical of

construction vehicles (e.g., diesel exhaust from grading and construction equipment).

These odors are a temporary short-term impact typical of construction projects that would

disperse rapidly. During operations, the proposed project, would comply with SCAQMD

Rule 402, which would prohibit any air quality discharge that would be a nuisance or pose

any harm to individuals of the public. On-site trash receptacles would have the potential

to create adverse odors. The facility would mitigate associated trash odors by properly

storing and disposing of trash in compliance with the City’s municipal code. The proposed

project would not include any of the land uses identified by the SCAQMD as odor sources.

Therefore, impacts would be-less-than significant and no mitigation measures are

required.



3.4 Biological Resources

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No

Impact Would the project

a) Have a substantial adverse effect, either directly

or through habitat modifications, on any species

identified as a candidate, sensitive, or special

status species in local or regional plans, policies,

or regulations, or by the California Department

of Fish and Wildlife or U.S. Fish and Wildlife

Service?

☐ ☐ ☐ ☒

b) Have a substantial adverse effect on any riparian

habitat or other sensitive natural community

identified in local or regional plans, policies,

regulations or by the California Department of

Fish and Wildlife or U.S. Fish and Wildlife

Service?

☐ ☐ ☐ ☒

c) Have a substantial adverse effect on state or

federally protected wetlands (including, but not

limited to, marsh, vernal pool, coastal, etc.)

through direct removal, filling, hydrological

interruption, or other means?

☐ ☐ ☐ ☒

d) Interfere substantially with the movement of any

native resident or migratory fish or wildlife

species or with established native resident or

migratory wildlife corridors, or impede the use

of native wildlife nursery sites?

☐ ☐ ☐ ☒

e) Conflict with any local policies or ordinances

protecting biological resources, such as a tree

preservation policy or ordinance? ☐ ☐ ☐ ☒

f) Conflict with the provisions of an adopted

Habitat Conservation Plan, Natural Community

Conservation Plan, or other approved local,

regional, or state habitat conservation plan?

☐ ☐ ☐ ☒

a-f) No Impact. The project site is located in an urbanized area developed with residential,

commercial, and industrial uses. The project site has been previously disturbed and there

is no natural habitat for special status species. There are no known candidates, sensitive or

special status species within the vicinity of the project site. The project site does not

contain and is not adjacent to any riparian habitat or other sensitive natural community.

There are no wetlands on or near the project site. The project site is surrounded by urban

development. A private rail right-of-way is adjacent northeast of the project site, there are

various arterial streets to the north, east, south and west of the project site and further west

is Interstate 5 (I-5) freeway. These transportation corridors do not provide opportunities

to any habitat linkage. Therefore, the proposed project would not interfere with the

movement of native resident or migratory fish or wildlife species. The proposed project

does not conflict with ordinances protecting biological resources and no impact would



occur in this regard. Lastly, the project site is not located in the Orange County Central

and Coastal Natural Community Natural Community Conservation Plan/Habitat

Conservation Plan area.10 Therefore, no impact would occur and no mitigation measures

are required.

3.5 Cultural Resources

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Cause a substantial adverse change in the

significance of a historical resource pursuant to

§ 15064.5? ☐ ☒ ☐ ☐

b) Cause a substantial adverse change in the

significance of an archaeological resource

pursuant to § 15064.5? ☐ ☒ ☐ ☐

c) Disturb any human remains, including those

interred outside of dedicated cemeteries? ☐ ☒ ☐ ☐

a-b) Less-than-significant impact with mitigation. According to CEQA Guidelines, Section

15064.5, and Public Resources Code Section 21083.1, the proposed project would be

considered to have a significant impact if it would cause a substantial adverse change in a

significance of a unique archaeological resource (i.e., an artifact, object, or site) about

which it can be clearly demonstrated that, without merely adding to the current body of

knowledge, there is a high probability that it contains information needed to answer

important scientific research questions, has a special and particular quality, such as being

the oldest or best available example of its type, or is directly associated with scientifically

recognized important prehistoric or historic event or person. According to the City's

General Plan EIR, archaeological sites within the City are often located along creek areas,

ridgelines, and vistas. Many of these types of landforms are located within the Hill and

Canyon Area of the City, and the City only has one major cultural resource site (CA-Ora-

303) that it has identified and registered. This site is adjacent to State Route 91 (SR-91).

The project site is not located near this registered site.

Prior to the release of this initial study, the City solicited a tribal consultation per AB 52.

The City communicated with interested tribes via email and via certified mailed letters, to

inform them of the proposed project. On April 20, 2020 the City, sent consultation notices

and the Gabrieleno Band of Mission Indians – Kizh Nation and Juaneno Band of Mission

Indians, Acjachemen Nation- Belardes have indicated that the proposed project is within

their Ancestral Tribal Territory. Thus, the City consulted with the two tribes to ensure

proper mitigations measures are set forth. Comments of the consultation letters are

included as Appendix B.


Accessible at http://www.anaheim.net/913/Environmental-Impact-Report, Accessed on April 8, 2020.




Implementation of the proposed project would require grading, excavation and trenching

on the site. The site is highly disturbed and, as such, it is unlikely any significant

archaeological resources would be uncovered. As conditions of approval, the applicant

would implement Mitigation Measure MM CUL-1 and MM CUL-2 in the event of the

inadvertent discovery of historic or archaeological resources and with the implementation

of Mitigation Measure MM CUL-1 and MM CUL-2, impacts would be less-than-

significant.

Mitigation Measure:

MM CUL-l In the event a potentially significant cultural resource is encountered during

subsurface earthwork activities, all construction activities within a 100-foot radius of the

find shall cease and workers should avoid altering the materials until an archaeologist who

meets the Secretary of Interior’s Professional Qualification Standards for archaeology has

evaluated the situation. The applicant shall include a standard inadvertent discovery clause

in every construction contract to inform contractors of this requirement. Potentially

significant cultural resources consist of but are not limited to stone, bone, glass, ceramics,

fossils, wood, or shell artifacts, or features including hearths, structural remains, or historic

dumpsites. The archaeologist shall make recommendations concerning appropriate

measures that the project applicant will implement to protect the resource, including but

not limited to excavation and evaluation of the finds in accordance with Section 15064.5

of the CEQA Guidelines. The project applicant shall submit a final report to the City

Engineer detailing the findings and disposition of the specimens of any previously

undiscovered resources found during construction within the project site. Upon completion

of the grading, the archaeologist shall notify the City of Anaheim as to when the project

applicant will submit the final report.

MM CUL-2 In the event that fossils or fossil-bearing deposits are discovered during construction

activities, excavations within a 100-foot radius of the find shall be temporarily halted or

diverted. The applicant shall notify a qualified paleontologist who shall examine the

discovery. The applicant shall include a standard inadvertent discovery clause in every

construction contract to inform contractors of this requirement. The paleontologist shall

document the discovery as needed in accordance with Society of Vertebrate Paleontology

standards and assess the significance of the find under the criteria set forth in CEQA

Guidelines Section 15064.5. The paleontologist shall notify the appropriate agencies to

determine procedures that the project applicant shall follow before the City allows

construction activities to resume at the location of the find. If the applicant determines that

avoidance is not feasible, the paleontologist shall prepare an excavation plan for mitigating

the effect of construction activities on the discovery. The applicant shall submit the plan to

the City of Anaheim for review and approval prior to implementation, and the applicant

shall adhere to the recommendations in the plan

Implementation of Mitigation Measure MM CUL-1 and MM CUL-2 will ensure that the

potential impacts due to accidental discovery of significant archaeological resources are

reduced to a less-than-significant level by requiring that if a find is made, activity is



stopped, and appropriate measures are taken.

c) Less-than-significant impact with mitigation. Staff is not aware of any human remains

or cemeteries that exist within or near the project area. However, there is always the

possibility that subsurface construction activities associated with the proposed project,

such as trenching and grading, could potentially damage or destroy previously

undiscovered human remains. Accordingly, this is a potentially significant impact. In the

event of the accidental discovery or recognition of any human remains, CEQA Guidelines

Section 15064.5; Health and Safety Code Section 7050.5; California Public Resources

Code (PRC) Section 5097.94 and Section 5097.98 must be followed. In the unlikely event

that there is a discovery of human remains, implementation of Mitigation Measure MM

CUL-3 would reduce this potential impact to a less-than-significant level.

Mitigation Measure:

MM CUL-3 In the event of the accidental discovery or recognition of any human remains, CEQA

Guidelines Section 15064.5; Health and Safety Code Section 7050.5; PRC Section 5097.94

and Section 5097.98 shall be followed. If during the course of project development there

is accidental discovery or recognition of any human remains, the following steps shall also

be taken:

1. There shall be no further excavation or disturbance within 100 feet of the remains

until the County Coroner is contacted to determine if the remains are Native American and

if an investigation of the cause of death is required. If the coroner determines the remains

to be Native American, the coroner shall contact the NAHC within 24 hours, and the

NAHC shall identify the person or persons it believes to be the most likely descendant

(MLD) of the deceased Native American. The MLD may make recommendations to the

landowner or the person responsible for the excavation work within 48 hours, for means of

treating or disposing of, with appropriate dignity, the human remains and any associated

grave goods as provided in PRC Section 5097.98.

2. Where the following conditions occur, the landowner or his or her authorized

representative shall rebury the Native American human remains and associated grave

goods with appropriate dignity either in accordance with the recommendations of the most

likely descendant or on the project site in a location not subject to further subsurface

disturbance:

The NAHC is unable to identify a most likely descendent or the most likely

descendent failed to make a recommendation within 48 hours after being notified

by the NAHC.

The descendant identified fails to make a recommendation.

The landowner or his authorized representative rejects the recommendation of the

descendant, and mediation by the NAHC fails to provide measures acceptable to

the landowner.

Additionally, PRC Section 15064.5 requires the following relative to Native American



Remains:

When an Initial Study identifies the existence of, or the probable likelihood of,

Native American Remains within a project, a lead agency shall work with the

appropriate Native Americans as identified by the NAHC as provided in PRC

5097.98. The Project Applicant may develop a plan for treating or disposing of,

with appropriate dignity, the human remains and any items associated with Native

American Burials with the appropriate Native Americans as identified by the

NAHC.

3.6 Energy

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Result in potentially significant environmental

impact due to wasteful, inefficient, or

unnecessary consumption of energy resources,

during project construction or operation?

☐ ☐ ☒ ☐

b) Conflict with or obstruct a state or local plan for

renewable energy or energy efficiency? ☐ ☐ ☒ ☐


Regulatory Framework

California State Building Regulation

California Building Code: Building Energy Efficiency Standards. Energy

conservation standards for new residential and non-residential buildings were adopted by

the California Energy Resources Conservation and Development Commission (now the

CEC) in June 1977 and most recently revised in 2016 (Title 24, Part 6, of the California

Code of Regulations [CCR]). Title 24 requires the design of building shells and building

components to conserve energy. The CEC updates these standards periodically to allow

for consideration and possible incorporation of new energy efficiency technologies and

methods. On June 10, 2015, the CEC adopted the 2016 Building Energy Efficiency

Standards, which went into effect on January 1, 2017. The 2016 Standards continues to

improve upon the previous 2013 Standards for new construction of, and additions and

alterations to, residential and nonresidential buildings. Under the 2016 Standards,

residential and nonresidential buildings are 28 and 5 percent more energy efficient than

the 2013 Standards, respectively. Buildings that are constructed in accordance with the

2013 Building Energy Efficiency Standards are 25 percent (residential) to 30 percent

(nonresidential) more energy efficient than the prior 2008 standards as a result of better

windows, insulation, lighting, ventilation systems, and other features. While the 2016

standards do not achieve zero net energy, they do get very close to the state’s goal and

make important steps toward changing residential building practices in California. The



2019 standards is the final step to achieve zero net energy for newly constructed residential

buildings throughout California. The 2019 standards move towards cutting energy use in

new homes by more than 50 percent and requires installation of solar photovoltaic systems

for single-family homes and multi-family buildings of three stories and less. Four key

areas the 2019 standards focuses on include 1) smart residential photovoltaic systems; 2)

updated thermal envelope standards (preventing heat transfer from the interior to exterior

and vice versa); 3) residential and nonresidential ventilation requirements; 4) and

nonresidential lighting requirements. Under the 2019 standards, nonresidential buildings

are 30 percent more energy efficient compared to the 2016 standards while single-family

homes are 7 percent more energy efficient. When accounting for the electricity generated

by the solar photovoltaic system, single-family homes use 53 percent less energy

compared to homes built to the 2016 standards.

California Building Code: CALGreen. On July 17, 2008, the California Building

Standards Commission adopted the nation’s first green building standards. The California

Green Building Standards Code (24 CCR, Part 11, known as “CALGreen”) was adopted

as part of the California Building Standards Code. CALGreen established planning and

design standards for sustainable site development, energy efficiency (in excess of the

California Energy Code requirements), water conservation, material conservation, and

internal air contaminants.12 The mandatory provisions of CALGreen became effective

January 1, 2011, and were last updated in 2019. The 2019 CALGreen became effective on

January 1, 2020.

Senate Bill 350. Senate Bill 350 (de Leon), was signed into law in September 2015. SB

350 establishes tiered increases to the RPS of 40 percent by 2024, 45 percent by 2027, and

50 percent by 2030. SB 350 also set a new goal to double the energy efficiency savings in

electricity and natural gas through energy efficiency and conservation measures.

SB 100. On September 10, 2018, Governor Brown signed SB 100, which replaces the SB

350 requirement of 45 percent renewable energy by 2027 with the requirement of 50

percent by 2026. The bill also raises California’s RPS requirements for 2050 from 50

percent to 60 percent. SB 100 also establishes RPS requirements for publicly owned

utilities that consist of 44 percent renewable energy by 2024, 52 percent by 2027, and 60

percent by 2030. Furthermore, the bill also establishes an overall state policy that eligible

renewable energy resources and zero-carbon resources supply 100 percent of all retail

sales of electricity to California end-use customers and 100 percent of electricity procured

to serve all state agencies by December 31, 2045. Under the bill, the state cannot increase

carbon emissions elsewhere in the western grid or allow resource shuffling to achieve the

100 percent carbon-free electricity target.

Local Regulation

The City’s Green Element outlines goals and policies conserve energy during the

construction and operation of buildings.11 Key goals and policies from the Green Element

11City of Anaheim, General Plan: Green Element, revised June 2018, available at

http://www.anaheim.net/712/General-Plan , Accessed on April 22, 2020.

http://www.anaheim.net/712/General-Plan



regarding new construction are:

Goal 15.2: Continue to encourage site design practices that reduce and conserve

energy.

o Policy 15.2(1): Encourage increased use of passive and active solar design

in existing and new development (e.g., orienting buildings to maximize

exposure to cooling effects of prevailing winds and locating landscaping

and landscape structures to shade buildings).

o Policy 15.2(2): Encourage energy-efficient retrofitting of existing buildings

throughout the City.

Goal 17.1: Encourage building and site design standards that reduce energy costs.

o Policy 17.1(1): Encourage designs that incorporate solar and wind exposure

features such as daylighting design, natural ventilation, space planning and

thermal massing.

Construction Energy Consumption

The main forms of available energy supply are electricity, natural gas, and oil. During

construction of the proposed project, the consumption of energy would be in the form of

electricity associated with the conveyance of water used for dust control, powering lights,

electronic equipment, or other construction activities that require electrical power.

Construction activities typically do not involve the consumption of natural gas. However,

construction activities would also consume energy in the form of petroleum-based fuels

associated with the use of off- road construction vehicles and equipment, round-trip

construction worker travel to the project site, and delivery and haul truck trips.

Construction activities would comply with CARB’s “In-Use Off- Road Diesel Fueled

Fleets Regulation”, which limits engine idling times to reduce harmful emissions and

reduce wasteful consumption of petroleum-based fuel. Additionally, the proposed project

would comply the California Renewable Portfolio Standard, the Clean Energy and

Pollution reduction Act of 2015 (Senate Bill (SB) 350). Compliance with local, state, and

federal regulations would reduce short-term energy demand during the proposed project’s

construction to the extent feasible, and proposed project construction would not result in a

wasteful or inefficient use of energy. Therefore, a less-than-significant impact would occur

and no mitigation measures are required.

Operational Energy Consumption

During operations of the proposed project, Anaheim Public Utilities (APUD) would

provide electricity and APUD obtains its power supply from a range of non-renewable and

renewable sources. Southern California Gas Company (SoCal Gas) would provide natural

gas to the project site. Energy use associated with operation of the proposed project would

be typical of commercial uses, requiring electricity and natural gas for interior and exterior



building lighting, heating, ventilation, and air conditioning, electronic equipment,

machinery, refrigeration, appliances, security systems, and more. Maintenance activities

during operations, such as landscape maintenance, would involve the use of electric or gas-

powered equipment. In addition to on-site energy use, the proposed project would result in

transportation energy use associated with vehicle trips generated by the proposed

commercial development. However, the proposed project does not involve any

characteristics or processes that would require the use of equipment that would be more

energy intensive than the amount used for comparable activities or involve the use of

equipment that would not conform to current emissions standards and related fuel

efficiencies. The proposed project will be subject to the California Green Building

Standards Code, which requires new buildings to reduce water consumption, employ

building commissioning to increase building system efficiencies for large buildings, divert

construction waste from landfills, and install low pollutant-emitting finish materials. The

proposed project does not include any feature (i.e., substantially alter energy demands) that

will interfere with implementation of these state and City codes and plans. Therefore, a

less-than-significant impact would occur and no mitigation measure would be required.

b) Less-than-significant impact. The City of Anaheim General Plan Green Element

contains energy goals and policies applicable to the proposed project, including Green

Element Goal 15.2; (Policies 1 and 2 encouraging site design practices to reduce and

conserve energy), and Green Element Goal 17.1, (Policy 1 encouraging building and site

design standards that reduce energy costs.). Project design and operation would comply

with the most current State Building Energy Efficiency Standards (Title 24), appliance

efficiency regulations, and green building standards. Compliance with Title 24 standards

and CALGreen standards would ensure the proposed project incorporates energy-efficient

features. The proposed project would support the City’s goals by complying with Title 24

energy and efficiency standards and green building standards as amended by the AMC

section 15.03. Additionally, the City would review building plans and construction plans

prior to the approval of the Proposed Project. This review would further ensure that the

proposed project would comply with local and state regulations. The 2019 CALGreen

standards require the recycling and/or salvaging of a minimum of 65 percent of

nonhazardous construction and demolition waste. Adherence to the California Public

Utilities Commission’s energy requirements, as well as the most current Title 24 and

CALGreen standards would ensure conformance with the City of Anaheim General Plan

Green Element goals and policies, as well as the State’s goal of promoting energy

efficiency and renewable energy. The proposed project would not conflict with or obstruct

a state or local plan for renewable energy or energy efficiency. Therefore, would be less-

than-significant and no mitigation is required.



3.7 Geology and Soils

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Directly or indirectly cause potential substantial

adverse effects, including the risk of loss, injury,

or death involving:

i) Rupture of a known earthquake fault, as

delineated on the most recent Alquist-Priolo

Earthquake Fault Zoning Map, issued by the

State Geologist for the area or based on

other substantial evidence of a known fault?

Refer to Division of Mines and Geology

Special Publication 42.

☐ ☐ ☒ ☐

ii) Strong seismic ground shaking? ☐ ☐ ☒ ☐

iii) Seismic-related ground failure, including

liquefaction? ☐ ☐ ☐ ☒

iv) Landslides? ☐ ☐ ☐ ☒

b) Result in substantial soil erosion or the loss of

topsoil? ☐ ☐ ☒ ☐

c) Be located on a geologic unit or soil that is

unstable, or that would become unstable as a

result of the project, and potentially result in on-

or off-site landslide, lateral spreading,

subsidence, liquefaction or collapse?

☐ ☐ ☐ ☒

d) Be located on expansive soil, as defined in Table

18-1-B of the Uniform Building Code (1994),

creating substantial direct or indirect risks to life

or property?

☐ ☐ ☐ ☒

e) Have soils incapable of adequately supporting

the use of septic tanks or alternative waste water

disposal systems where sewers are not available

for the disposal of waste water?

☐ ☐ ☐ ☒

f) Directly or indirectly destroy a unique

paleontological resource or site or unique

geologic feature? ☐ ☒ ☐ ☐

This section utilizes the following technical studies in its analysis:

Geotechnical Engineering Report, Terracon Consultants, Inc. April 24, 2018

(Appendix C)

a.i) Less-than-significant impact. There are no known active earthquake faults, or Alquist-

Priolo Earthquake Fault Zones, that traverse the City12. While no active or potentially

active faults traverse the City, the entire Southern California region is seismically active.


Accessible at: http://www.anaheim.net/913/Environmental-Impact-Report, Accessed on April 20, 2020.




The City is located between two major active fault zones: the Newport-Inglewood fault

zone and the Whittier-Elsinore fault zone.13 The Newport-Inglewood fault passes within

seven (7)-miles of the western limits of the City. The Whittier-Elsinore fault passes within

one (1)-mile of the northeastern end of the City. The proposed project will not expose

people or structures to potential substantial adverse effects involving the rupture of a

known earthquake fault. Therefore, a less-than-significant impact would occur and no

mitigation measures are required.

a.ii) Less-than-significant impact. As discussed above, the project site is not located within

an established Alquist-Priolo Earthquake Fault Zone. However, like all areas in southern

California, movement associated with the active faults could cause strong ground motion

at the project site. The degree of ground shaking and earthquake-induced damage is

dependent on multiple factors such as distances to causative faults, earthquake

magnitudes, and expected ground accelerations. Therefore, all construction is required to

occur in compliance with the most current California Building Code (CBC) requirements.

Additionally, compliance with existing local City building standards and other applicable

seismic related design requirements would further reduce the potential for damage to occur

as the result of rupture of known earthquake faults in the region. Potential for this type of

activity is similar throughout Southern California and the proposed project does not pose

a unique or unusual risk. Therefore, impacts would be less-than-significant and no

mitigations measures are required.

a.iii, iv) No Impact. Liquefaction is a mode of ground failure that results from the generation

of high pore water pressures during earthquake ground shaking, causing loss of shear

strength. Liquefaction is typically a hazard where loose sandy soils exist below

groundwater. The California Geologic Survey (CGS) has designated certain areas within

Southern California as potential liquefaction hazard zones. These are areas considered at

a risk of liquefaction-related ground failure during a seismic event, based upon mapped

surficial deposits and the presence of a relatively shallow water table. The project site is

not located within a liquefaction hazard zone as designated by the CGS. Based on the CGS

hazard maps and the subsurface conditions encountered at the project site, the potential

for liquefaction at the site is low. Other geologic hazards related to liquefaction, such as

lateral spreading, are therefore also low. The project site does not lie in an officially

designated liquefaction hazard zone nor a landslide potential.1415 Construction would be

required to comply with Chapter 15.03 of the AMC, which requires compliance with the

CBC and therefore accepted statewide regulations for seismic safety. Therefore, no

impacts would occur and no mitigation measures are required.

b) Less-than-significant impact. During ground disturbing activities, such as grading and

excavation, the project site could potentially be subject to soil erosion or loss of topsoil.

Construction of the proposed project would be required to comply with local and state

13Ibid. 14California Geological Survey, Earthquake Zones of Required Investigation - Anaheim Quadrangle, 1998,

https://gmw.conservation.ca.gov/SHP/EZRIM/Maps/ANAHEIM_EZRIM.pdf. 15City of Anaheim, General Plan and Zoning Code Update Environmental Impact Report No. 330. May 25, 2004.

Available at http://www.anaheim.net/913/Environmental-Impact-Report, Accessed on April 20,2020.




codes regulating construction activities and soil erosion. Locally, the proposed project

would be required to comply with the AMC Chapter 17.04, Grading, Excavations, Fills,

Watercourses, which is in place to ensure that excavation and fills that may affect drainage

and watercourses are in accordance with good engineering practice. The proposed project

would also be required to comply with AMC Section 10.09.030, Control of Urban Runoff,

which requires that new development develop a water quality management plan (WQMP).

State regulations, would require the project applicant to obtain a Construction General

Permit (CGP) issued by the State Water Resources Control Board (SWRCB). The CGP is

in place to minimize water pollution from construction activities, including erosion. The

proposed improvements at the project site would be subject to the National Pollution

Discharge Elimination System (NPDES) permitting regulations, including the

development and implementation of a Stormwater Pollution Prevention Plan (SWPPP),

discussed in Section 3.10 Hydrology and Water Quality. The proposed project’s

construction contractor would be required to prepare and implement a SWPPP and

associated best management practices (BMPs) in compliance with the CGP during grading

and construction. Adherence with existing state and local laws regulating construction

activities would minimize soil erosion from project-related construction activities.

Therefore, soil erosion impacts due to project construction would be less-than-significant


c) No Impact. As discussed in Section 3.7 (a.iii, iv) Geology and Soils, the project site does

not lie within a liquefaction hazard zone. Since the project site is not within a liquefaction

hazard zone; there would be no potential for lateral spreading because lateral spreading is

a type of liquefaction‐induced ground failure associated with the lateral displacement of

surficial blocks of sediment resulting from liquefaction in a subsurface layer. There are no

known, ongoing or planned extractions of groundwater, gas, oil, or geothermal energy that

will cause subsidence at the project site. Construction would be required to comply with

Chapter 15.03 of the AMC, which requires compliance with the CBC and therefore

accepted statewide regulations for seismic safety. Therefore, no impacts would occur and

no mitigation measures are required.

d) No Impact. Expansive soils are those that undergo volume changes as moisture content

fluctuates, swelling substantially when wet or shrinking when dry. Soil expansion can

cause damage to building foundations, roads and other structures. Because the proposed

project would involve grading and construction activities that would occur on flat ground,

substantial soil erosion or loss of topsoil would not occur. All construction and grading

activity would comply with the City’s existing ordinances and policies, including those

aimed at erosion control such as Code Title 17, Land Development and Resources and the

current version of the Uniform Building Code. Therefore, no impacts would occur and no


e) No Impact. The proposed project would not include the use of septic tanks or alternative

wastewater disposal systems. The project site is in an urbanized area of the City, and the

proposed project would connect to the City’s wastewater system. Therefore, no impacts




f) Less-than-significant impact with mitigation. Surficial sediments at the project site area

consist of younger terrestrial Quaternary Alluvium, with older terrestrial Quaternary

sediments occurring at various depths, as part of the floodplain deposits from the Santa

Ana River. These deposits typically do not contain significant vertebrate fossils, at least in

the uppermost layers. Surface grading or very shallow excavations in the uppermost few

feet of the younger Quaternary Alluvium at the project site are unlikely to uncover

significant fossil vertebrate remains. Deeper excavations may encounter significant

vertebrate fossils in older Quaternary deposits. Therefore, implementation of Mitigation

Measure MM GEO-1 would reduce potential impacts to paleontological resources to a

less-than-significant level.

Mitigation Measure:

MM GEO-1 During rough grading activities, which are defined as any grading activity occurring

at depths below four feet from the existing surface, close monitoring should occur to

quickly and professionally collect any specimens without impeding development and

sediment samples should be collected and processed by a qualified professional to

determine the small fossil potential. In the event that paleontological resources are

inadvertently unearthed during excavation and grading activities of any future development

project, the paleontologist or contractor shall temporarily cease all earth-disturbing

activities within a 100-foot radius of the area of discovery. The qualified professional shall

evaluate the significance of the finding and determine the appropriate course of action. If

avoidance of the resource(s) is not feasible, the applicant shall follow salvage operation

requirements pursuant to Section 15064.5 of the State CEQA Guidelines. After the

proposed project has appropriately avoided or mitigated the find, work in the area may

resume. Nothing in this mitigation measure precludes the retention of a single cross-trained

observer who is qualified to monitor for both archaeological and paleontological resources.



3.8 Greenhouse Gas Emissions

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Generate greenhouse gas emissions, either

directly or indirectly, that may have a significant

impact on the environment? ☐ ☐ ☒ ☐

b) Conflict with an applicable plan, policy or

regulation adopted for the purpose of reducing

the emissions of greenhouse gases? ☐ ☐ ☒ ☐

The “greenhouse effect” is the natural process that retains heat in the troposphere, the

bottom layer of the atmosphere. Without the greenhouse effect, thermal energy would

“leak” into space resulting in a much colder and inhospitable planet. With the greenhouse

effect, the global average temperature is approximately 61 ̊F (16 ̊C). Greenhouse gases

(GHGs) are the components of the atmosphere responsible for the greenhouse effect. The

amount of heat retained is proportional to the concentration of GHGs in the atmosphere.

As more GHGs release into the atmosphere, GHG concentrations increase and the

atmosphere retains more heat, increasing the effects of climate change. The Kyoto

Protocol for emission reduction targets identified six gases: carbon dioxide (CO2),

methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC),

and sulfur hexafluoride (SF6). When accounting for GHGs, all types of GHG emissions

are expressed in terms of CO2 equivalents (CO2e) and are typically quantified in metric

tons (MT) or million metric tons (MMT).

CO2, CH4, and N2O contribute to approximately 80 percent of the total heat stored in the

atmosphere. Both human activities and natural sources emit these three gases. Each of the

GHGs affect climate change at different rates and persist in the atmosphere for varying

lengths of time. Global Warming Potential (GWP) is the relative measure of the potential

for a GHG to trap heat in the atmosphere. The GWP allows comparisons of the global

warming impacts of different gases. Specifically, it is a measure of how much energy the

emissions of one ton of a gas will absorb over a given period, relative to the emissions of

one ton of CO2. The larger the GWP, the more that a given gas warms the Earth compared

to CO2 over that period. GWPs provide a common unit of measure, which allows analysts

to add up emissions estimates of different gases (e.g., to compile a national GHG

inventory), and allows policymakers to compare emissions reduction opportunities across

sectors and gases.

GHGs, primarily CO2, CH4, and N2O, are emitted as a result of stationary source

combustion of natural gas in equipment such as water heaters, boilers, process heaters, and

furnaces. GHGs are also emitted from mobile sources such as on-road vehicles and off-

road construction equipment burning fuels such as gasoline, diesel, biodiesel, propane, or

natural gas (compressed or liquefied). Indirect GHG emissions result from electric power



generated elsewhere (i.e., power plants) used to operate process equipment, lighting, and

utilities at a facility. Included in GHG quantification is electric power, which is used to

pump the water supply (e.g., aqueducts, wells, pipelines) and disposal and decomposition

of municipal waste in landfills.

Regulations and Significance Criteria.

California Governor Arnold Schwarzenegger issued Executive Order S-3-05 in June 2005,

which established the following GHG emission reduction targets: (a) by 2010: Reduce

GHG emissions to 2000 levels; (b) by 2020: Reduce GHG emissions to 1990 levels; and,

(c) by 2050: Reduce GHG emissions to 80 percent below 1990 levels, which is the level

estimated to stabilize climate temperatures to a 2 degree increase and avoid further

escalation of environmental impacts from global warming to agricultural resources,

diseases, water supply, sea-level rise, and other harmful impacts.

AB 32. AB 32 Statutes of 2006, Health and Safety Code Section 38500 et seq. require that

CARB determine what the Statewide GHG emissions level was in 1990 and approve a

Statewide GHG emissions limit that is equivalent to that level, to be achieved by 2020.

CARB approved a 2020 emissions limit of 427 million metric tons of CO2equivalent

(MTCO2e). Additionally, issued in April 2015, Executive Order (EO) EO-15 requires

Statewide GHG emissions to be reduced 40 percent below 1990 levels by 2030.

EOB-30-15, which Governor Brown issued in April 2015, requires statewide GHG

emissions to be reduced 40 percent below 1990 levels by 2030. SB 32, signed into law in

September 2016, codifies the 2030 GHG reduction target in EO B-30-15. SB 32 authorizes

CARB to adopt an interim GHG emissions level target for the State to achieve by 2030

and to adopt rules and regulations in an open public process to achieve the maximum,

technologically feasible, and cost-effective GHG reductions. With SB 32, the California

Legislature passed companion legislation AB 197, which provided additional direction for

developing an updated Scoping Plan. CARB released the second update to the Scoping

Plan to reflect the 2030 target set by EO B-30-15 and codified by SB 32 in November

2017.

SB 375. In 2008, SB 375, the Sustainable Communities and Climate Protection Act, was

adopted to connect the GHG emissions reductions targets established in the 2008 Scoping

Plan for the transportation sector to local land use decisions that affect travel behavior. Its

intent is to reduce GHG emissions from light-duty trucks and automobiles (excludes

emissions associated with goods movement) by aligning regional long-range

transportation plans, investments, and housing allocations to local land use planning to

reduce VMT and vehicle trips. Specifically, SB 375 required CARB to establish GHG

emissions reduction targets for each of the 18 metropolitan planning organizations

(MPOs). SCAG is the MPO for the Southern California region, which includes the

counties of Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial.

Pursuant to the recommendations of the Regional Transportation Advisory Committee,

CARB adopted per capita reduction targets for each of the MPOs rather than a total

magnitude reduction target. SCAG’s targets are an eight (8) percent per capita reduction



from 2005 GHG emission levels by 2020 and a 13 percent per capita reduction from 2005

GHG emission levels by 2035. The 2020 targets are smaller than the 2035 targets because

a significant portion of the built environment in 2020 has been defined by decisions that

have already been made. In general, the 2020 scenarios reflect that more time is needed

for large land use and transportation infrastructure changes. Most of the reductions in the

interim will come from improving the efficiency of the region’s transportation network.

The targets would result in 3 MMTCO2e of reductions by 2020 and 15 MMTCO2e of

reductions by 2035. Based on these reductions, the State would meet the passenger vehicle

target in CARB’s Scoping Plan (for AB 32).

SB 100. On September 10, 2018, Governor Brown signed SB 100, which replaces the SB

350 requirement of 45 percent renewable energy by 2027 with the requirement of 50

percent by 2026 and also raises California’s RPS requirements for 2050 from 50 percent

to 60 percent. SB 100 also establishes RPS requirements for publicly owned utilities that

consist of 44 percent renewable energy by 2024, 52 percent by 2027, and 60 percent by

2030. Furthermore, the bill also establishes an overall state policy that eligible renewable

energy resources and zero-carbon resources supply 100 percent of all retail sales of

electricity to California end-use customers and 100 percent of electricity procured to serve

all state agencies by December 31, 2045. Under the bill, the state cannot increase carbon

emissions elsewhere in the western grid or allow resource shuffling to achieve the 100

percent carbon-free electricity target.

Senate Bill 350. Senate Bill 350 (de Leon) was signed into law in September 2015. SB

350 establishes tiered increases to the RPS of 40 percent by 2024, 45 percent by 2027, and

50 percent by 2030. SB 350 also set a new goal to double the energy efficiency savings in

electricity and natural gas through energy efficiency and conservation measures.

Assembly Bill 1493. AB 1493 (Pavley I) enacted California vehicle GHG emission

standards. Pavley I is a clean-car standard that reduces GHG emissions from new

passenger vehicles (light-duty auto to medium-duty vehicles) from 2009 through 2016 and

was anticipated to reduce GHG emissions from new passenger vehicles by 30 percent in

2016. California implements the Pavley I standards through a waiver granted to California

by the EPA. In 2012, the EPA issued a Final Rulemaking that sets even more stringent

fuel economy and GHG emissions standards for model year 2017 through 2025 light-duty

vehicles (see also the discussion on the update to the Corporate Average Fuel Economy

standards under Federal Laws, above). In January 2012, CARB approved the Advanced

Clean Cars program (formerly known as Pavley II) for model years 2017 through 2025.

The program combines the control of smog, soot, and global warming gases and

requirements for greater numbers of zero-emission vehicles into a single package of

standards. Under California’s Advanced Clean Car program, by 2025, new automobiles

will emit 34 percent fewer global warming gases and 75 percent fewer smog-forming

emissions.

California Building Code: Building Energy Efficiency Standards. Energy

conservation standards for new residential and non-residential buildings were adopted by

the California Energy Resources Conservation and Development Commission (now the



CEC) in June 1977 and most recently revised in 2016 (Title 24, Part 6, of the California

Code of Regulations [CCR]). Title 24 requires the design of building shells and building

components to conserve energy. The CEC updates these standards periodically to allow

for consideration and possible incorporation of new energy efficiency technologies and

methods. On June 10, 2015, the CEC adopted the 2016 Building Energy Efficiency

Standards, which went into effect on January 1, 2017. The 2016 Standards continues to

improve upon the previous 2013 Standards for new construction of, and additions and

alterations to, residential and nonresidential buildings. Under the 2016 Standards,

residential and nonresidential buildings are 28 and 5 percent more energy efficient than

the 2013 Standards, respectively. Buildings that are constructed in accordance with the

2013 Building Energy Efficiency Standards are 25 percent (residential) to 30 percent

(nonresidential) more energy efficient than the prior 2008 standards as a result of better

windows, insulation, lighting, ventilation systems, and other features. While the 2016

standards do not achieve zero net energy, they do get very close to the state’s goal and

make important steps toward changing residential building practices in California. The

2019 standards is the final step to achieve zero net energy for newly constructed residential

buildings throughout California. The 2019 standards move towards cutting energy use in

new homes by more than 50 percent and requires installation of solar photovoltaic systems

for single-family homes and multi-family buildings of three stories and less. Four key

areas the 2019 standards focuses on include 1) smart residential photovoltaic systems; 2)

updated thermal envelope standards (preventing heat transfer from the interior to exterior

and vice versa); 3) residential and nonresidential ventilation requirements; 4) and

nonresidential lighting requirements. Under the 2019 standards, nonresidential buildings

are 30 percent more energy efficient compared to the 2016 standards while single-family

homes are 7 percent more energy efficient. When accounting for the electricity generated

by the solar photovoltaic system, single-family homes use 53 percent less energy

compared to homes built to the 2016 standards.

California Building Code: CALGreen. On July 17, 2008, the California Building

Standards Commission adopted the nation’s first green building standards. The

Commission adopted the California Green Building Standards Code (24 CCR, Part 11,

known as “CALGreen”) as part of the California Building Standards Code. CALGreen

established planning and design standards for sustainable site development, energy

efficiency (in excess of the California Energy Code requirements), water conservation,

material conservation, and internal air contaminants. The mandatory provisions of

CALGreen became effective January 1, 2011, and were last updated in 2019. The 2019

CALGreen became effective on January 1, 2020.

Greenhouse Gas Guidelines

The CEQA Guidelines require lead agencies to adopt GHG thresholds of significance.

When adopting these thresholds, the amended Guidelines allows lead agencies to consider

thresholds of significance adopted or recommended by other public agencies, or

recommended by experts, provided that the thresholds are supported by substantial

evidence, and/or to develop their own significance threshold. Neither the City nor



SCAQMD has officially adopted a quantitative threshold value for determining the

significance of GHG emissions that projects will generate under CEQA.

SCAQMD published the Draft Guidance Document – Interim CEQA Greenhouse Gas

(GHG) Significance Threshold in October 2008.16 SCAQMD convened a GHG CEQA

Significance Threshold Stakeholder Working Group beginning in April of 2008 to

examine alternatives for establishing quantitative GHG thresholds within the district’s

jurisdiction. The Working Group proposed a tiered screening methodology for assessing

the potential significance of GHG emissions generated by CEQA projects. The tiered

screening methodology was in the minutes of the final Working Group meeting on

September 28, 2010.17

The City has not adopted GHG significance thresholds but may set a project-specific

threshold based on the context of a particular project, including the proposed project. Thus,

the analysis uses the SCAQMD Working Group expert recommendation because: (1) it is

in the same air quality basin that the experts analyzed. (2) It is a storage facility that is

within an industrial zone, but its emissions characteristics closely resembles commercial

uses. (3) This information appears to corroborate the SCAQMD staff’s finding that the

policy objective of capturing 90 percent of all GHG emissions for this region can be

achieved with a screening level of 3000 MTCO2eq/yr. Therefore, staff is recommending

that lead agencies use this value for residential and commercial developments, including

industrial parks, warehouses, etc. For the proposed project, SCAQMD’s proposed 3,000

MTCO2e/yr non-industrial screening threshold is used as the significance threshold in

addition to the qualitative thresholds of significance set forth in Section VIII of State

CEQA Guidelines Appendix G. The 3,000 MTCO2e/yr screening threshold represents a

90 percent capture rate (i.e., this threshold captures projects with approximately 90 percent

of GHG emissions from new sources). Staff estimated GHG emissions that the proposed

project would generate using CalEEMod, as recommended by the SCAQMD. CalEEMod

quantifies GHG emissions from construction activities and future operation of projects.

Sources of GHG emissions during project construction will include heavy-duty off-road

diesel equipment and vehicular travel to and from the project site. Sources of GHG

emissions during project operation will include employee, customer and delivery vehicular

travel, energy demand, water use, and waste generation. In accordance with SCAQMD

methodology, staff amortized the total amount of GHG emissions that construction of the

proposed project would generate over a 30-year operational period to represent long-term

impacts.

a) Less-than-significant impact. Global climate change is not confined to a particular

project area and is generally accepted as the consequence of global industrialization over

the last 200 years. A typical project, even a very large one, does not generate enough GHG

16SCAQMD, Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold, October

2008. 17SCAQMD, Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15, September 28,

2010, Accessible at http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-

significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf?sfvrsn=2, Accessed April 22,

2020.

http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf?sfvrsn=2

http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf?sfvrsn=2



emissions on its own to influence global climate change significantly; hence, the issue of

global climate change is, by definition, a cumulative environmental impact.

Table 4 presents the estimated GHG emissions that the proposed project would release to

the atmosphere on an annual basis. Construction of the proposed project would produce

approximately 158 MTCO2e, or 5.3 MTCO2e annually over a 30-year period. The total

annual operating emissions would be approximately 1,353 MTCO2e per year after

accounting for amortized construction emissions. This mass rate is substantially below the

most applicable quantitative draft interim threshold of 3,000 MTCO2e per year

recommended by SCAQMD to capture 90 percent of CEQA projects within its

jurisdiction. Therefore, the proposed project would result in a less-than-significant impact

related to GHG emissions.

TABLE 4 - ESTIMATED ANNUAL GREENHOUSE GAS EMISSIONS

Scenario and Source Annual GHG Emissions (MTCO2e per Year)

Construction Emissions Amortized (Direct)/a/ 5.3

Area Source Emissions (Direct) >0.1

Energy Source Emissions (Indirect) 762

Mobile Source Emissions 236

Waste Disposal Emissions (Indirect) 92

Water Distribution Emissions (Indirect) 258

Total Emissions 1,353

Significance Threshold 3000

Exceed Threshold? No /a/ Based on SCAQMD guidance, emissions summary including 30-year amortization with construction.

Overall, development and operation of the proposed project would not generate net annual

emissions that exceed the SCAQMD threshold of 3,000 MTCO2e per year. Therefore,


b) Less-than-significant impact. Applicable plans adopted for reducing GHG emissions

include the CARB Scoping Plan and SCAG’s Regional Transportation Plan/Sustainable

Communities Strategy (RTP/SCS). Below is a consistency analysis between the proposed

project and these plans.

CARB’s Scoping Plan is California’s GHG reduction strategy to achieve the state’s GHG

emissions reduction target established by AB 32, which is to return to 1990 emission levels

by year 2020. The CARB Scoping Plan is applicable to state agencies and is not directly

applicable to cities/counties and individual projects. Nonetheless, the Scoping Plan has

been the primary tool used to develop performance-based and efficiency-based CEQA

criteria and GHG reduction targets for climate action planning. Since adoption of the 2008

Scoping Plan, state agencies have adopted programs in the plan, and the legislature has

passed additional legislation to achieve the GHG reduction targets. Statewide strategies to

reduce GHG emissions include the Low Carbon Fuel Standard (LCFS), California

Appliance Energy Efficiency regulations, California Renewable Energy Portfolio

standard, changes in the Corporate Average Fuel Economy (CAFE) standards, and other



early action measures as necessary to ensure the state is on target to achieve the GHG

emissions reduction goals of AB 32. In addition, new buildings are required to comply

with the latest applicable Building Energy Efficiency Standards and CALGreen Code. On

December 24, 2017, CARB adopted the Final 2017 Climate Change Scoping Plan Update

to address the new 2030 interim target to achieve a 40 percent reduction below 1990 levels

by 2030, established by SB 32. While measures in the Scoping Plan would generally apply

to state agencies and not the proposed project, compliance with these statewide measures

adopted since AB 32 and SB 32 would reduce the proposed project’s GHG emissions. The

proposed project would not obstruct implementation of the CARB Scoping Plan.


required.

With regards to local climate planning initiatives, SCAG adopted the 2016-2040 RTP/SCS

to balance future mobility and housing needs with economic, environmental and public

health goals. RTP/SCS states that lead agencies such as local jurisdictions have the sole

discretion in determining a local project’s consistency with the plan. The RTP/SCS

focuses the majority of new job growth in high-quality transit areas and other opportunity

areas on existing main streets, in downtowns, and commercial corridors, resulting in an

improved jobs-housing balance and more opportunity for transit-oriented development.

The RTP/SCS also includes programs, policies and measures to address air quality

emissions and reduce GHG emissions that are consistent with the provisions of Section

15091 of the CEQA Guidelines, including but not limited to reducing emissions resulting

from a project through implementation of project features, project design, or other

measures; incorporating design measures to reduce energy consumption and increase use

of renewable energy, and using the minimum feasible amount of GHG emitting

construction materials. The proposed project would be consistent with the RTP/SCS by

complying with CalGreen. CalGreen lays out minimum requirements for newly

constructed buildings in California, which will reduce GHG emissions through improved

efficiency and process improvements. It requires builders to install plumbing that cuts

indoor water use by as much as 20 percent, to divert 50 percent of construction waste from

landfills to recycling, and to use low-pollutant paints, carpets, and floors. By complying

with Title 24, the proposed project would be consistent with RTP/SCS. OCTA bus stations

near the project site connect the site to the surrounding City and Southern California

region. The proposed project would not interfere with SCAG’s ability to implement the

regional strategies outlined in the RTP/SCS. Therefore, impacts would be less-than-




3.9 Hazards and Hazardous Materials

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Create a significant hazard to the public or the

environment through the routine transport, use,

or disposal of hazardous materials? ☐ ☐ ☒ ☐

b) Create a significant hazard to the public or the

environment through reasonably foreseeable

upset and accident conditions involving the

release of hazardous materials into the

environment?

☐ ☐ ☒ ☐

c) Emit hazardous emissions or handle hazardous

or acutely hazardous materials, substances, or

waste within one-quarter mile of an existing or

proposed school?

☐ ☐ ☐ ☒

d) Be located on a site which is included on a list

of hazardous materials sites compiled pursuant

to Government Code § 65962.5 and, as a result,

would it create a significant hazard to the public

or the environment?

☐ ☐ ☐ ☒

e) For a project located within an airport land use

plan or, where such a plan has not been adopted,

within two miles of a public airport or public

use airport, would the project result in a safety

hazard or excessive noise for people residing or

working in the project area?

☐ ☐ ☐ ☒

f) Impair implementation of or physically interfere

with an adopted emergency response plan or

emergency evacuation plan? ☐ ☐ ☒ ☐

g) Expose people or structures, either directly or

indirectly, to a significant risk of loss, injury or

death involving wildland fires? ☐ ☐ ☐ ☒

a,b) Less-than-significant impact. Exposure of the public or the environment to hazardous

materials can occur through transportation accidents; environmentally unsound disposal

methods; improper handling of hazardous materials or hazardous wastes (particularly by

untrained personnel); and/or emergencies, such as explosions or fires. The severity of these

potential effects varies by type of activity, concentration and/or type of hazardous

materials or wastes, and proximity to sensitive receptors. The applicant does not anticipate

that construction of the proposed project would involve the transport, use, creation or

disposal of hazardous materials. The proposed project would use small quantities of

potentially hazardous substances such as gasoline, diesel fuel, lubricants for machines, and

other petroleum-based products would be used on the project site. Should any unknown

contaminated soils or other hazardous materials be discovered and be removed from the

project site, the soils/material can be transported only by a licensed hazardous waste hauler

in covered containment devices in compliance with all applicable County, State, and

federal requirements. During grading and construction activities, the contractor would be



required to comply applicable City zoning code requirements, including prohibition of the

active or passive discharge or disposal of soil or construction debris into the storm drain.

Additionally, the owner/contractor is required to comply with the current version of the

State’s GCP, which requires the development and implementation of a SWPPP. SWPPPs

address the prevention or elimination of potential pollutants associated with all applicable

types of construction related materials and wastes onsite. During the operational phase of

the project, treatment control BMPs would remove pollutants generated to the maximum

extent practicable as defined in the County’s Drainage Area Management Plan (DAMP).

The type and amount of hazardous materials on site would be typical of those used for a

typical commercial business. This analysis assumes that all potentially hazardous

materials would be contained, stored, and used in accordance with manufacturer’s

instructions and handled in compliance with applicable standards and regulations.

Therefore, less-than-significant impacts would occur and no mitigation measures are

required.

c) No Impact. There are no schools located within one (1/4)-quarter mile of the project site.

Neither construction nor operation of the proposed project would generate acutely

hazardous materials or wastes, and the limited use of any hazardous materials would be

contained, stored, and used in accordance with manufacturer's guidelines as well as

according to all applicable federal, state, and local standards and regulations regarding

hazardous materials. Therefore, no impacts would occur and no mitigation measures are

required.

d) No Impact. The project site is not on the Envirostor database, maintained by the California

Department of Toxic Substances.18 Therefore, no impacts would occur and no mitigation

measures are required.

e) No Impact. Fullerton Municipal Airport is approximately 8.4-miles north of the project

site and Los Alamitos Armed Forces Reserve is located approximately 10.1 miles west of

the project site. The project site does not fall within an airport land use planning area. The

proposed project would not result in a safety hazard for people at the project site.

Therefore, no impacts would occur and no mitigation is required.

f) Less-than-significant impact. The City approved its Emergency Operations Plan (EOP)

in June 2017. The EOP provides comprehensive policy and guidance for emergency and

response operations, and details the responsibilities of residents, organizations, and City-

departments. The City uses Anaheim Alert to contact residents during emergencies to

provide information regarding evacuations. The project site is developed, and proposed

project implementation would not significantly increase traffic or the need for services.

No road closures would occur on State College Boulevard, during construction. Therefore,

less-than-significant impacts would occur and no mitigation is required.

g) No Impact. The California Department of Forestry and Fire Protection (CAL FIRE) has

18California Department of Toxic Substances Control (DTSC). Cortese List. Accessible at

https://calepa.ca.gov/SiteCleanup/CorteseList/, accessed on April 23,2020

https://calepa.ca.gov/SiteCleanup/CorteseList/



mapped fire threat potential throughout California. The project site is not within an

identified State or Local fire hazard area. The proposed project would not expose people

or structures to a risk of loss, injury or death involving wildland fires. The project site is

in a developed urban area and it is not adjacent to or near any wildland areas. See Section

3.20, Wildfire, for more discussion on this topic. Therefore, no impact would occur and

no mitigation is required.

3.10 Hydrology and Water Quality

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Violate any water quality standards or waste

discharge requirements or otherwise

substantially degrade surface or ground water

quality?

☐ ☐ ☒ ☐

b) Substantially decrease groundwater supplies or

interfere substantially with groundwater

recharge such that the project may impede

sustainable groundwater management of the

basin?

☐ ☐ ☒ ☐

c) Substantially alter the existing drainage pattern

of the site or area, including through the

alteration of the course of a stream or river or

through the addition of impervious surfaces, in a

manner which would:

i) result in a substantial erosion or siltation on-

or off-site; ☐ ☐ ☒ ☐

ii) substantially increase the rate or amount of

surface runoff in a manner which would

result in flooding on- or offsite; ☐ ☐ ☒ ☐

iii) create or contribute runoff water which

would exceed the capacity of existing or

planned stormwater drainage systems or

provide substantial additional sources of

polluted runoff; or

☐ ☐ ☒ ☐

iv) impede or redirect flood flows? ☐ ☐ ☒ ☐

d) In flood hazard, tsunami, or seiche zones, risk

release of pollutants due to project inundation? ☐ ☐ ☐ ☒

e) Conflict with or obstruct implementation of a

water quality control plan or sustainable

groundwater management plan? ☐ ☐ ☒ ☐


Preliminary Drainage Study, Blue Peak Engineering, Inc. May 24, 2018

(Appendix D)

County of Orange/Santa Ana Region Priority Project Preliminary Water Quality

Management Plan (PWQMP) Blue Peak Engineering, Inc. August 6, 2019.

(Appendix E)



Geotechnical Engineering Report, Terracon Consultants, Inc. April 24, 2018

(Appendix C)


Urban runoff, during both dry and wet weather conditions, discharges into storm drains,

and in most cases, flows directly to creeks, rivers, lakes, and the ocean. Polluted runoff

can have harmful effects on drinking water, recreational water, and wildlife. The proposed

project would pipe runoff from the project site to the front of the site along State College

Boulevard where the project would pump the runoff to grade and discharge it into the curb

and gutter in State College Boulevard. Runoff is captured in a public catch basin

downstream of the property. Runoff is piped downstream to the East Garden Grove

Wintersburg Channel. The project site runoff would flow to Drainage Basin 26. Drainage

Basin 26 has a tributary drainage area of approximately 800 acres. The City of Anaheim

Master Plan of Storm Drainage does not note any deficiencies for East Garden Grove

Wintersburg Channel Tributary Area.19

Construction Impact

During construction, there is the potential for short-term surface water quality impacts.

Such impacts include runoff of loose soils and/or a variety of construction wastes and fuels

that the surface runoff would carry off-site into local storm drains and streets that drain

eventually into water resources. The proposed project would be required to obtain a

NPDES GCP from the SWRCB and prepare a SWPPP. The SWPPP includes BMPs to

reduce water quality impacts, including various measures to control on-site erosion, reduce

sediment flows into storm water and wind erosion; reduce tracking of soil and debris into

adjacent roadways and off-site areas; and manage wastes, materials, wastewater, liquids,

hazardous materials, stockpiles, equipment, and other site conditions to prevent pollutants

from entering the storm drain system. Implementation of the provisions of the NPDES

permit and compliance with City grading requirements would minimize construction

impacts through BMPs that reduce construction-related pollutants. Therefore, impacts


Operational Impact

Stormwater runoff from the proposed project has the potential to introduce small amounts

of pollutants into the stormwater system. The project site is 100 percent impervious; the

post development condition would be approximately 97 percent impervious. Runoff from

the existing site flows to curb and gutter or v-gutters from the west side of the site to the

east side of the site. The gutters convey the runoff to a series of inlets along the southern

property line. From these inlets, runoff is piped to the front of the site along State College

Blvd where it is pumped to grade and discharges into the curb and gutter in State College

Blvd. With the proposed project, the drainage pattern will remain the same except for

19City of Anaheim, Master Plan of Storm Drainage for East Garden Grove Wintersburg Channel Tributary Area,

January 2006. Accessible at http://www.anaheim.net/DocumentCenter/View/9163/East-GG-Wintersburg?bidId=,

Accessed on April 21, 2020.

http://www.anaheim.net/DocumentCenter/View/9163/East-GG-Wintersburg?bidId=



mitigated treatment runoff volume that the proposed project will divert to an underground

system to infiltrate into the soil. The infiltration storage capacity volume would be

approximately 3,337 cubic feet and this infiltration system would be considered an

infiltration BMP. Runoff from the new buildings will discharge at grade; v-gutters will

convey the runoff along the fronts of the building, maintaining the existing drainage paths.

Prior to the issuance of a building permit for the proposed project, the project applicant

would have to comply with all applicable regulations and obtain a NPDES stormwater

permit to indicate that the project features BMPs. As such, the proposed project would not

violate water quality standards, waste discharge requirements, or stormwater NPDES

standards, or otherwise substantially degrade water quality. Therefore, impacts would be

less-than-significant an no mitigation measures are required.

b) Less-than-significant impact. The City receives approximately 75 percent of its water

supply from groundwater from Orange County Basin (OC Basin) and 25 percent from

imported water. The OC Basin, managed by Orange County Water District (OCWD). It

underlies the northerly half of Orange County beneath broad lowlands and covers

approximately 350 square miles, bordered by the Coyote and Chino Hills to the north, the

Santa Ana Mountains to the northeast, and the Pacific Ocean to the southwest. The City

owns and operates a network of groundwater wells to supply potable water to their users.

The City is currently using a small amount of recycled water and is planning to increase

its water use in the future.

As discussed in the Geotechnical Engineering Report (Appendix C) prepared for the

proposed project, the subsurface investigation did not encounter groundwater. The project

site is not a groundwater recharge area, and the proposed project would not interfere

substantially with groundwater recharge. Therefore, impacts would be less-than-


c.i-iii) Less-than-significant impact. As discussed in Section 3.10 (a) Hydrology and Water

Quality, The applicant would be required to implement a SWPPP and monitoring plan,

which include BMPs. Development of these BMPs would ensure the proposed project

does not result in substantial on-site or off-site erosion or siltation. The proposed project

would not result in a significant change to the drainage pattern of the project site. The

proposed project would not involve the alteration of the course of a stream or river. As

previously addressed, the proposed project would follow a similar drainage pattern

compared to existing conditions. Additionally, the Preliminary Drainage Study

(Appendix D) concludes that runoff from the proposed project’s storm water

infrastructure would be decreased, from existing conditions. The proposed project would

not create or contribute runoff water, which would exceed the capacity of existing or

planned storm water drainage systems or provide substantial additional sources of polluted

runoff. Therefore, impacts would be less-than-significant and no mitigation measures are

required.

c.iv) Less-than-significant impact. The proposed project is not within a flood zone. With the

incorporation of the proposed project’s storm water infrastructure, the proposed project

would not impede or redirect flood flows. Furthermore, as discussed above, the proposed



project would be required to implement a SWPPP and monitoring plan, which includes

BMPs. Therefore, impacts would be less-than-significant and no mitigation measures are

required.

d) No Impact. The project site is not located within a tsunami, flood hazard, seiche zone.

Therefore, the proposed project would not be at risk of pollutant release due to project

inundation. Therefore, no impact s would occur and no mitigation measures are required.

e) Less-than-significant impact. The Santa Ana Regional Water Quality Board (RWQCB)

and its Basin Plan regulate water quality in the City. The Basin Plan contains water quality

goals and policies and identifies beneficial uses for receiving waters, along with water

quality criteria and standards consistent with federal and state water quality laws. The

proposed project would be required to comply with the NPDES CGP and SWPPP

requirements and implement BMPs. Thus, the proposed project would not violate any

water quality standards and would not obstruct the implementation of the Basin Plan. The

OCWD manages groundwater in the Orange County Basin. As discussed in Sections

3.10(a) and 3.10(b) Hydrology and Water Quality, the proposed project would not violate

any water quality standards and would not decrease groundwater supplies or interfere

substantially with groundwater recharge. Therefore, impacts would be less-than-


3.11 Land Use and Planning

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Physically divide an established community? ☐ ☐ ☐ ☒

b) Cause a significant environmental impact due to

a conflict with any land use plan, policy, or

regulation adopted for the purpose of avoiding

or mitigating an environmental effect?

☐ ☐ ☒ ☐

a) No Impact. The proposed project would demolish two buildings and a portion of a third

building of an existing Extra Space Storage facility and construct five (5) new self-storage

buildings, including one 3-story, and four (4) single-story buildings, at the Extra Space

Storage facility. The proposed project would not displace any residences and does not

proposed any new roads. The proposed project would not divide nearby residential

communities located north, south, or west of the project site. Therefore, no impacts would

occur and no mitigation is required.

b) Less-than-significant impact.

The proposed project requires the following discretionary actions:



Adoption of a Mitigated Negative Declaration and a Mitigation Monitoring and

Reporting Program

Approval of a Conditional Use Permit (CUP) to amend a previously approved CUP to

permit the expansion of the Extra Space Storage facility with a 0.60 Floor Area Ratio

(FAR) (147,670 sq. ft.) in the Industrial (I) Zone, where the Anaheim Municipal Code

permits a maximum FAR of 0.50 (121,044 sq. ft.).

The General Plan designates the Project Site for Office-Low land use. The Project Site is

within the Industrial (I) Zone and the Office District of the Platinum Triangle Mixed Use

(PTMU) Overlay Zone. The property owner has the option to develop the property in

compliance with either the I Zone or the PTMU Overlay Zone. The applicant has elected

to develop in conformance with the I Zone. The proposed project is consistent with the

General Plan and the I Zone. The I Zone has a maximum permitted floor area ratio (FAR)

of .50 FAR. As discussed above, the proposed project would demolish two buildings and

a portion of a third building of an existing Extra Space Storage facility and construct five

new self-storage buildings, including one three-story, and four single-story buildings, at

the Extra Space Storage facility. The proposed project would increase the total floor area

to 147,670 sq. ft. (0.6 FAR). The proposed project would exceed the maximum allowable

0.50 FAR (121,044 sq. ft). However, the AMC permits an increase in the maximum FAR

with the approval of a CUP.

In addition, Council Policy 7.2 provides guidance on the location of self storage facilities.

The policy states that:

Self-storage facilities may continue to be permitted in the C-G (Commercial

General), and I (Industrial) Zones subject to the approval of a conditional use

permit. The unique and opportune design features of self-storage facilities are most

appropriate for irregularly-shaped properties which may further be constrained

by accessibility or visibility and which may not be suitable for conventional types

of development. A limited number of these types of properties are found in

commercial and industrial zones. Provided there does not appear to be other

viable or strategic uses of the property, the architecture of the facility is of high

quality, the use is appropriate and compatible with its surrounding land uses, and

the facility is in compliance with all Zoning Code Development Standards

(including setbacks where possible, signage and landscaping), self-storage

facilities may be conditionally permitted in the C-G, or I Zones.

General Plan, Zoning and Council Policy Consistency

The General Plan Land Use Element guides development throughout the City and defines

development amount, type, density, etc. The General Plan designates the Project Site for

Office-Low land use. The Office-Low land use designation allows for a variety of small-

scale office uses, including local branches of financial institutions, legal services,

insurance services, real estate, and medical or dental offices and support services. The

Office-Low designation is intended to facilitate office development of up to three stories

in height. Areas designated as Office-Low can develop as stand-alone projects or within a



business park setting. Staff considers the expansion of the existing self-storage facility as

The applicant would develop the proposed project pursuant to the I Zone. The intent of

the “I” Industrial Zone is to provide for and encourage the development of industrial uses

and their related facilities, recognize the unique and valuable existing industrial land

resources, and encourage industrial employment opportunities within the City. Targeted

industries include research and development, repair services, wholesale activities,

distribution centers, and manufacturing and fabrication. In some situations, other types of

uses are allowed with a minor conditional use permit or conditional use permit. The City

previously permitted the existing Extra Space Storage facility through the approval of a

CUP. The applicant proposes to amend the CUP to permit the expansion of the facility

with a 0.60 FAR in the I Zone, where the Anaheim Municipal Code permits a maximum

FAR of 0.50.

Pursuant to Council Policy 7.2, the existing and expansion of the Extra Space Storage

facility is located on a narrow irregularly shaped property, adjacent to a railroad, within

the I Zone. The proposed design of the expansion would be compatible with the existing

facility and surrounding land use. Therefore, the proposed project meets the criteria of

Council Policy 7.2.

The proposed project would be consistent with the General Plan, the I Zone and Council

Policy 7.2. With the Planning Commission’s approval of a Mitigated Negative Declaration

and Mitigation Monitoring Reporting Program; and, the approval of a CUP to amend a

previously approved CUP to permit the expansion of the facility with a 0.60 FAR in the I

Zone, where the Anaheim Municipal Code permits a maximum FAR of 0.50. The proposed

project would not cause a significant environmental impact due to a conflict with any land

use plan, policy, or regulation. Therefore, a less-than-significant impacts would occur and


3.12 Mineral Resource

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Result in the loss of availability of a known

mineral resource that would be a value to the

region and the residents of the state? ☐ ☐ ☐ ☒

b) Result in the loss of availability of a locally

important mineral resource recovery site

delineated on a local general plan, specific plan

or other land use plan?

☐ ☐ ☐ ☒

a,b) No Impact. There are no significant mineral resources that exist on or in the immediate

vicinity of the project site.20 Therefore, no impacts would occur and no mitigation

20City of Anaheim, General Plan and Zoning Code Update Environmental Impact Report No. 330 Chapter 5.9




Mineral Resources. May 25, 2004. Accessible at http://www.anaheim.net/913/Environmental-Impact-Report,

Accessed on April 14, 2020.




3.13 Noise

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Generation of a substantial temporary or

permanent increase in ambient noise levels in

the vicinity of the project in excess of standards

established in the local general plan or noise

ordinance, or applicable standards of other

agencies?

☐ ☐ ☒ ☐

b) Generation of excessive groundborne vibration

or groundborne noise levels? ☐ ☐ ☒ ☐

c) For a project located within the vicinity of a

private airstrip or an airport land use plan or,

where such a plan has not been adopted, within

two miles of a public airport or public use

airport, would the project expose people

residing or working in the project area to

excessive noise levels?

☐ ☐ ☐ ☒

a) Less-than-significant impact. Existing codes and regulations typically describe sound in

terms of the loudness (amplitude) and frequency (pitch). The standard unit of measurement

for sound is the decibel (dB). The human ear is not equally sensitive to sound at all

frequencies. The A-weighted scale, abbreviated dBA, reflects the normal hearing

sensitivity range of the human ear. Noise is generally defined as unwanted sound. Since

the human ear is not equally sensitive to a given sound level at all frequencies, a special

frequency-dependent rating scale has been devised to relate noise to human sensitivity.

The A-weighted decibel scale (dBA) provides this compensation by discriminating against

frequencies in a manner approximating the sensitivity of the human ear. Sensitivity to

noise increases during the evening and at night because excessive noise interferes with the

ability to sleep.

Regulatory Framework

California State Noise Regulation

The State of California regulates freeway noise, sets standards for sound transmission,

provides occupational noise control criteria, identifies noise standards, and provides

guidance for local land use compatibility. State law requires that each county and city

adopt a general plan that includes a noise element which is to be prepared according to

guidelines adopted by the Governor’s Office of Planning and Research. The purpose of

the noise element is to “limit the exposure of the community to excessive noise levels.”

California Code of Regulations, Title 24. The California Code of Regulations, Title 24:

Part 1, Building Standards Administrative Code, and Part 2, California Building Code



codifies the State’s noise insulation standards. These noise standards apply to new

construction in California for the purpose of interior noise compatibility from exterior

noise sources. The regulations specify that acoustical studies must be prepared when

noise-sensitive structures, such as residential buildings, schools, or hospitals, are located

near major transportation noise sources, and where such noise sources create an exterior

noise level of 65 dBA (Community Noise Equivalent Level) CNEL or higher. Acoustical

studies that accompany building plans must demonstrate that the design of the structure

will limit interior noise in habitable rooms to acceptable noise levels. For new residential

buildings, schools, and hospitals, the acceptable interior noise limit for new construction

is 45dBA CNEL.

City of Anaheim

City of Anaheim General Plan. The Noise Element of the City’s General Plan contains

noise and land use compatibility standards for various land uses throughout the City.21 The

City uses these standards and criteria in the land use planning process to reduce future

noise and land use incompatibilities. The standards shown in the table are the primary tool

that allows the City to ensure integrated planning for compatibility between land uses and

outdoor noise.

City of Anaheim Noise Ordinance AMC Chapter 6.70. The City has the authority to set

land use noise standards and place restrictions on private activities that generate excessive

or intrusive noise. The AMC specifies applicable standards for these activities. The AMC

limits sound levels for stationary sources of noise radiated for extended periods from any

premises in excess of 60 decibels at the property line. Sound created by construction or

building repair of any premises within the City is also exempt from the applications of the

AMC during the hours of 7:00 a.m. and 7:00 p.m.

AMC Section 18.040.090.060. The Planning Commission may grant a deviation from the

requirements pertaining to exterior noise levels, given that all of the following conditions

exist:

The deviation does not exceed 5 dB above the prescribed levels for exterior noise;

and

Measures to attenuate noise to the prescribed levels would compromise or conflict

with the aesthetic value of the project.

Construction Noise

Construction of the proposed project would last for approximately nine months and

include various heavy construction equipment including excavators, backhoes, and

graders. The City exempts construction or building repair of any premises within the City

during the hours between 7:00 a.m. and 7 p.m. The construction of the proposed project

21City of Anaheim, General Plan: Noise Element, Figure N-2: Land Use Compatibility for Community Noise

Exposure (Exterior), May 2004. Accessible at http://www.anaheim.net/712/General-Plan, Accessed on April 14,

2020.




would take place between the hours of 7:00 a.m. and 7 p.m. and would comply with State

and Local regulation and ordinances. Therefore, impacts would be less-than-significant


Operational Noise

The proposed project would increase the total floor area to 147,670 sq. ft. and provide

1,278 storage units in eight buildings. The main source of noise would be vehicle noise

from traffic trips of the employees and customers, which would result in approximately

127 daily vehicle trips as shown in Appendix F. The number of trips is a small percentage

of the daily traffic on the surrounding roadways and would not constitute a significant

increase in noise. Therefore, less-than-significant impacts would occur and no mitigation


b) Less-than-significant impact.

Construction Vibration

Construction can generate varying degrees of ground vibration, depending on the

construction procedures and equipment. Operation of construction equipment generates

vibrations that spread through the ground and diminish with distance from the source. The

effect on buildings near the construction site varies depending on soil type, ground strata,

and receptor-building construction. The effects from vibration can range from no

perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible

vibrations at moderate levels, to slight structural damage at the highest levels. Vibration

from construction activities rarely reaches the levels that can damage structure. The

proposed project’s construction phase and associated construction equipment could

produce vibration from vehicle travel as well as demolition, grading and building

construction activities. The City has no vibration standards; however, as suggested in the

General Plan EIR, activities such as blasting, or the use of pile drivers during construction

typically cause excessive groundbourne vibration.22 This analysis assumes, as a reasonable

worst-case scenario, an impact pile driver, which would generate greater vibrations.

Caltrans sets the criterion level for pile driving at between 0.2 and 2 inches per second. A

reasonable worst-case scenario assumes the use of the 0.2 inch per second criterion.

Caltrans presents the vibration produced by a 50,000 foot-pound force with distance for

both clayey and sandy/silt soils as a function of distance. Caltrans indicates that the

distance to the 0.2 inch per second minimum criterion falls at a distance of approximately

50 feet. The proposed project would not involve pile driving or blasting activities, during

construction, thus the vibration impacts would be reasonably low. Therefore, less-than-

significant impacts would occur and no mitigation measures are required.

Operation Vibration


Accessible at http://www.anaheim.net/913/Environmental-Impact-Report, Accessed on April 16 2020.




The operation of the proposed project would not include any substantial long-term

vibration sources and no significant vibration effects from operation of the proposed

project would occur. Therefore, less-than-significant impacts would occur and no


c) No Impact. The nearest public airport is Fullerton Municipal Airport, approximately 8.4

miles north of the project site, and the nearest private air strip is the Los Alamitos Army

Airfield, approximately 10.1 miles to the west of the project site. Therefore, no impact


3.14 Population and Housing

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Induce substantial unplanned population growth

in an area, either directly (for example, by

proposing new homes and businesses) or

indirectly (for example, through extension of

roads or other infrastructure)?

☐ ☐ ☐ ☒

b) Displace substantial numbers of existing people

or housing, necessitating the construction of

replacement housing elsewhere? ☐ ☐ ☐ ☒

a,b) No Impact. No housing exists on the site and the proposed project does not include any

housing units. As such, no replacement housing would be necessary and no increase

housing units or population would occur. Therefore, no impacts would occur and no


3.15 Public Services

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Result in substantial adverse physical impacts

associated with the provision of new or

physically altered governmental facilities, need

for new or physically altered governmental

facilities, the construction of which could cause

significant environmental impacts, in order to

maintain acceptable service ratios, response

times, or other performance objectives for any

of the public services:

i.Fire protection? ☐ ☐ ☒ ☐

ii.Police protection? ☐ ☐ ☒ ☐



Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No

Impact

iii.Schools? ☐ ☐ ☐ ☒

iv.Parks? ☐ ☐ ☐ ☒

v.Other public facilities? ☐ ☐ ☐ ☒

a.i) Less-than-significant impact. The Anaheim Fire & Rescue (AF&R) provides fire

protection services in the City. The AF&R operates twelve fire stations comprised of ten

engine companies and five truck companies, and employs approximately 209 sworn fire

personnel. the AF&R staffs twelve engine companies, ten of which are designated

paramedic companies; five truck companies; one contract paramedic company; one

hazardous materials unit; one technical rescue unit; and two Battalions, housed in Fire

Station 6 (Euclid Fire Station) and Station 8 (Riverdale Station). The AF&R maintains a

response time goal that requires the first engine company to respond within 5 minutes to

90 percent of all incidents and 8 minutes to the remaining 10 percent of incidents. The

AF&R also requires a maximum of 10 minutes for the first truck company to respond to

100 percent of all incidents AF&R is responsible for all fire, rescue and medical aid calls

in the City. The AF&R maintains a response time goal that requires the first engine

company to respond within five minutes to 90 percent of all incidents and eight minutes

to the remaining ten percent of incidents. The AF&R also requires a maximum of ten

minutes for the first truck company to respond to 100 percent of all incidents.

The construction of the proposed project would incrementally increase demands for fire

protection services. However, such increases are minimal and the City would meet the

demand for fire service with existing firefighting resources. Therefore, less-than-


a.ii) Less Than Significant Impact. Law enforcement and crime prevention services are

provided by the Anaheim Police Department (APD). Police services provided include

patrol, investigations, traffic enforcement, traffic control, vice and narcotics enforcement,

airborne patrol, crime suppression, community policing, tourist-oriented policing, and

detention facilities. The APD headquarters is at 425 South Harbor Boulevard,

approximately 3.4 miles northwest of the project site. The APD employs 408 sworn

officers. The ratio of sworn police officers is approximately 1.14 officers per 1,000

population. APD has four districts: West, Central, South, and East. The approximate

average response time of patrol units to Priority 1 emergency calls throughout the

jurisdiction is 6 minutes and 55 seconds.

The construction of the proposed project would incrementally increase demands for police

protection services. However, such increases are minimal and the City would meet the

demand for fire service with existing Police resources. Therefore, less-than-significant

impacts would occur and no mitigation measures are required.



a.iii-v) No Impact. The proposed project would not include the construction of housing and

would not generate additional population, including students. Therefore, no impacts would

occur and no mitigation measures are required.

3.16 Recreation

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Would the project increase the use of existing

neighborhood and regional parks or other

recreational facilities such that substantial

physical deterioration of the facility would

occur or be accelerated?

☐ ☐ ☐ ☒

b) Does the project include recreational facilities or

require the construction or expansion of

recreational facilities which might have an

adverse physical effect on the environment?

☐ ☐ ☐ ☒

a,b) No Impact. The proposed project would not increase the use of existing parks or facilities

and would not include the construction or expansion of any recreational facilities, neither

in the short or long-term. No impacts would occur and no mitigation measures are

required.



3.17 Transportation

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Conflict with a program, plan, ordinance or

policy addressing the circulation system,

including transit, roadway, bicycle and

pedestrian facilities?

☐ ☐ ☒ ☐

b) Conflict or be inconsistent with CEQA

Guidelines § 15064.3, subdivision (b)? ☐ ☐ ☐ ☒

c) Substantially increase hazards due to a

geometric design feature (e.g., sharp curves or

dangerous intersections) or incompatible uses

(e.g., farm equipment)?

☐ ☐ ☐ ☒

d) Result in inadequate emergency access? ☐ ☐ ☐ ☒


Anaheim Extra Space Storage Trip Generation Analysis, TJW Engineering, Inc.

October 10, 2019 (Appendix F)

Traffic Guidelines

The City’s Traffic Study Guidelines state that a traffic study is required for a project that

meets the following criteria:

a) When the AM or PM peak hour trip generation is expected to exceed 100 vehicle

trips from the proposed development.

b) Projects on the Congestion Management Program (CMP) Highway System which

generate 1,600 Average Daily Trips (ADT) or adjacent to CMP Highway System

which generate 2,400 ADT

c) Projects that will add 51 or more trips during either AM or PM peak hours to any

monitored CMP intersection.

d) Any project where variations from the City of Anaheim Traffic Study Guidelines

are being proposed.

Site Access State Route 91 (SR-91) to the north, Interstate 5 (I-5) to the west, and State Route 57(SR-

57) to the east provide regional access to the project site. Cerritos Avenue, State College

Boulevard, and Katella Avenue provide local access. The site has one existing driveway,

from State College Boulevard.

Cerritos Avenue. Is an east-west, four-lane divided roadway and forms the northern

boundary of the project site. Cerritos Avenue has two travel lanes in each direction, and



center two-way left-turn lane. The posted speed limit is 35 miles per hour (mph). The City

of Anaheim General Plan classifies Cerritos Avenue as Primary Arterial.23 Cerritos

Avenue is approximately 1,670-feet north of the project site.

State College Boulevard. Is a north-south, six-lane divided roadway and forms the eastern

boundary of the project site. State College Boulevard has three travel lanes in each

direction, and median crossover left-turn lane. The posted speed limit is 30 mph. The

General Plan classifies State College Boulevard as a Major Arterial. Access to the project

site would be accessible via a driveway, from State College Boulevard.

Katella Avenue. Is an east-west, six-lane divided roadway and forms the southern

boundary of the project site. Katella Avenue has three travel lanes in each direction, and

median crossover left-turn lane. The posted speed limit is 35 mph. The General Plan

classifies Katella Avenue as a Major Arterial. Katella Avenue is approximately 880-feet

south of the project site.

Transit Service

The Orange County Transportation Authority (OCTA) provides public transit service in

the project vicinity. One southbound bus stop is approximately 280-feet north of the

project along State College Boulevard. One northbound bus stop is approximately 330-

feet north of the project site along State College

Project Trip Generation

Trip generation estimates for the existing uses and the proposed project are based on the

Institute of Transportation Engineers (ITE) Trip Generation Manual (10th Edition) trip

rates. Based on the proposed project’s existing and proposed land use the trip generation

was determined using the Mini‐Warehouse Land Use Code (151). As presented in Table

5. The proposed project is projected to generate a net total of eight (8) AM Peak Hour

trips, 14 PM Peak Hour trips and 127 daily trips.

23City of Anaheim, General Plan: Circulation Element, Revised June 2018. Accessible at

http://www.anaheim.net/712/General-Plan, Accessed on April 23, 2020.




TABLE 5 - PROJECT TRIP GENERATION

Land Use

Qty

Units/a/

Daily Trips

(ADTs)

AM Peak Hour PM Peak Hour

Rate In:Out

Split

Volume Rate In:Out

Split

Volume

Rate Volume In Out Total In Out Total

EXISTING

Mini-

Warehouse

63.5 TSF 1.51 96 0.10 60:40 4 3 7 0.17 47:53 5 6 11

DEMOLITION

Mini-

Warehouse

23.6 TSF 1.51 36 0.10 60:40 2 1 3 0.17 47:53 2 3 5

CONSTRUCTION

Mini-

Warehouse

107.8 TSF 1.51 163 0.10 60:40 7 4 11 0.17 47:53 9 10 19

Net new

total

84.2 TSF 127 5 3 8 7 7 14

/a/TSF = Thousand Square Feet

Table information can be obtained in Appendix F

a) Less-than-significant impact. The volume of automobile and truck traffic associated with

project-related construction activities would vary throughout the construction phases, as

different activities occur. However, project-related construction traffic would be

temporary in nature and cease to exist upon project completion. As shown in Table 5, the

proposed project would generate 127 daily trips with eight (8) AM peak hour and 14 PM

peak hour trips. The proposed project would not exceed 100 vehicle trips during AM/PM

Peak Hour. The proposed project would not generate 1,600 ADT or more on a CMP

Highway system. The proposed project would not add 51 or more trips during AM/PM

Peak Hour to any monitored CMP Highway. The proposed project does not have unusual

variations from the City of Anaheim Traffic Study Guidelines. OCTA will continue to

provide public transit bus service with two bus stops near the project site. The proximity

of these bus stops would provide near access to transit service. The proposed project would

not modify the existing pedestrian sidewalks along State College Boulevard, adjacent to

and providing access to the project site. The nearest bicycle facilities are located on

Cerritos Avenue, approximately 1,700 feet north of the project site. The proposed project

would not affect pedestrian or bicycle facilities. The proposed project would not conflict

with a program, plan, ordinance or policy addressing the circulation system. Therefore,

impacts would be less-than-significant and no mitigations measures are required.

b) No Impact. On December 28, 2018, the California Natural Resources Agency adopted

revised State CEQA Guidelines. State CEQA Guidelines Section 15064.3 codifies the

removal of vehicle delay and level of service (LOS) from consideration for transportation

impacts under CEQA. With the adopted CEQA Guidelines, Lead Agencies are required to

evaluate transportation impacts based on a project’s effect on vehicle miles traveled

(VMT). State CEQA Guidelines Section 15064.3 requires Lead Agencies to analyze

projects using VMT starting July 1, 2020. The City is in the process of updating its

transportation impact criteria to be consistent with the CEQA revisions. As a result, the



City has not adopted guidelines as of the date of this document, and analysis of vehicle

levels of service remains the appropriate method for determining a project’s transportation

impact per the City’s General Plan.

In late 2019, State courts stated that under Section 21099, subdivision (b)(2), existing law

is that “automobile delay, as described solely by level of service or similar measures of

vehicular capacity or traffic congestion shall not be considered a significant impact on the

environment” under CEQA, except for roadway capacity projects. While this project does

not create a significant impact through level of service or delay, for the purposes of this

recent court decision, the analysis of this project included VMT screening analysis. For

the VMT screening analysis, the proposed project was analyzed using the example

screening criteria identified in the “Technical Advisory on Evaluating Transportation

Impacts in CEQA”, dated December 2018 from the Governor’s Office of Planning and

Research (OPR). Projects located in areas with low VMT is one of the screening thresholds

that could be used for determining if a VMT analysis is required. The OPR Technical

Advisory suggests that projects that match the adjacent land uses already located within

an efficient VMT area (low VMT-generating zone) have a less than significant

transportation impact. To determine whether this assumption should apply to the proposed

project, staff used the Orange County Traffic Analysis Model (OCTAM) to measure VMT

performance for each traffic analysis zone (TAZ) throughout the region. A TAZ has

similar boundaries to the census tracts. The project site is located within a TAZ below the

County average of VMT per capita. Therefore, the OPR Technical Advisory, staff could

screen the proposed project from a VMT analysis, and could presume a less than

significant impact on VMT. Therefore, the proposed project would not conflict or be

inconsistent with State CEQA Guidelines Section 15064.3(b). Therefore, no impact would

occur and no mitigation measures are required.

c) No Impact. The proposed project does not include the use of any incompatible vehicles

or equipment on the project site, such as farm equipment. The proposed project would

not provide any off-site roadway improvements that could substantially increase hazards

due to a design feature. The proposed project is compatible with the surrounding land

uses and zoning. The applicant would construct all on-site and site-adjacent

improvements, including traffic signing/striping and project driveways, as approved by

the City of Anaheim Public Works Department. Sight distance at project access points

would comply with applicable City/California Department of Transportation sight

distance standards. Therefore, no impact would occur and no mitigation measures are

required.

d) No Impact. The proposed project would provide access to the self-storage facility from

State College Boulevard, via a driveway. The proposed project would be compliant with

the City’s AF&R requirements; the proposed project would include minimum roadway

width, fire apparatus access roads, fire lanes, signage, access devices and gates, and

access walkways, among other requirements, which would ensure emergency access to

the project site. The proposed project would not require the complete closure of any

public or private streets or roadways during construction. Temporary construction

activities would not impede use of the road for emergencies or access for emergency



response vehicles. Following compliance with AF&R access requirements, the proposed

project would provide adequate emergency access to the project site. Therefore, less-

than-significant impacts would occur and no mitigation measures are required.

3.18 Tribal Cultural Resources

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Would the project cause a substantial adverse

change in the significance of a tribal cultural

resource, defined in Public Resources Code §

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 5020.1(k), or

☐ ☒ ☐ ☐

ii) A resource determined by the lead agency, in

its discretion and supported by substantial

evidence, to be significant pursuant to

criteria set forth in subdivision (c) of Public

Resources Code § 5024.1. In applying the

criteria set forth in subdivision (c) of Public

Resource Code § 5024.1, the lead agency

shall consider the significance of the

resource to a California Native American

tribe.

☐ ☒ ☐ ☐

a.i, ii) Less-than-significant impact with mitigation. There are no known tribal cultural

resources within the boundaries of the project site. The project site has been previously

developed and disturbed, and does not meet any of the historical resources criteria outlined

in the PRC 2024.1. In considering the significance of the resource to a California Native

American tribe, the City contacted the NAHC for the listing of tribes with traditional lands

or cultural places located within the boundaries of the project site and to search the Sacred

Lands File (SLF). The SLF search result was negative. The City contacted the tribes per

the NAHC listing, and two tribal representatives responded. The tribe’s main concerns

include potential discoveries that may occur during grading activities. The following tribal

members who contact the City regarding the proposed project:

Andrew Salas of Gabrieleño Band of Mission Indians - Kizh Nation. The

Gabrieleño Band of Mission Indians - Kizh Nation.

Joyce Perry of the Juaneno Band of Mission Indians, Acjachemen Nation-

Belardes.



For this reason, they recommended a tribal monitor(s) be present during ground-disturbing

activities, to ensure that the project applicant would ensure proper documentation, salvaging, and

protection of any inadvertent discovery of tribal cultural resources encountered during ground-

disturbing activities. Upon discovery, if the finds are determined to be Native American human

remains, the coroner will notify the NAHC as mandated by state law who will then appoint a Most

Likely Descendent. Because there is a possibility that grading and excavation activities during

construction of the proposed project could affect previously undisturbed tribal cultural resources,

staff has included Mitigation Measure MM TCR-1 to reduce potential impacts to less than

significant.

MM TCR-1 Prior to the commencement of any grading and/or construction activity, the project

applicant shall retain a Native American Monitor and a copy of the executed contract shall

be submitted to the City of Anaheim Planning and Building Department. The Tribal

monitor will only be present on-site during the construction phases that involve ground-

disturbing activities. Ground disturbing activities are defined by the applicable tribes as

activities that may include, but are not limited to, pavement removal, potholing or auguring,

grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the

project area. The Tribal Monitor will complete daily monitoring logs that will provide

descriptions of the day’s activities, including construction activities, locations, soil, and

any cultural materials identified. The on-site monitoring shall end when the Project Site

grading and excavation activities are completed, or when the Tribal Representatives and

monitor have indicated that the Project Site has a low potential for impacting Tribal

Cultural Resources. Upon discovery of any archaeological resources, construction

activities shall cease in the immediate vicinity of the find until the find can be assessed. All

archaeological resources unearthed by project construction activities shall be evaluated by

the qualified archaeologist and Tribal monitor approved by the applicable tribes. If the

resources are Native American in origin, the applicable tribe shall coordinate with the

project applicant regarding treatment and curation of these resources. Typically, the Tribe

will request reburial or preservation for educational purposes. Work may continue on other

parts of the Project Site while evaluation and, if necessary, mitigation takes place (CEQA

Guidelines Section 15064.5[f]). If a resource is determined by the qualified archaeologist

to constitute a “historical resource” or “unique archaeological resource,” time allotment

and funding sufficient to allow for implementation of avoidance measures, or appropriate

mitigation, must be available. The treatment plan established for the resources shall be in

accordance with CEQA Guidelines Section 15064.5(f) for historical resources and PRC

Sections 21083.2(b) for unique archaeological resources. Preservation in place (i.e.,

avoidance) is the preferred manner of treatment. If preservation in place is not feasible,

treatment may include implementation of archaeological data recovery excavations to

remove the resource along with subsequent laboratory processing and analysis. Any

historic archaeological material that is not Native American in origin shall be curated at a

public, non-profit institution with a research interest in the materials, such as the Natural

History Museum of Los Angeles County or the Fowler Museum, if such an institution

agrees to accept the material. If no institution accepts the archaeological material, it shall

be offered to a local school or historical society in the area for educational purposes.



3.19 Utilities and Service Systems

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Require or result in the relocation or

construction of new or expanded water,

wastewater treatment or storm water

drainage, electric power, natural gas, or

telecommunications facilities, the

construction or relocation of which could

cause significant environmental effects?

☐ ☐ ☒ ☐

b) Have sufficient water supplies available to

serve the project and reasonably foreseeable

future development during normal, dry and

multiple dry years?

☐ ☐ ☒ ☐

c) Result in a determination by the waste water

treatment provider, which serves or may

serve the project that it has adequate capacity

to serve the project’s projected demand in

addition to the provider’s existing

commitments?

☐ ☐ ☒ ☐

d) Generate solid waste in excess of state or

local standards, or in excess of the capacity

of local infrastructure, or otherwise impair

the attainment of solid waste reduction

goals?

☐ ☐ ☒ ☐

e) Comply with federal, state, and local

management and reduction statutes and

regulations related to solid waste? ☐ ☐ ☒ ☐


Water and Wastewater. The Anaheim Public Works Department would serve the proposed

project for wastewater (sanitary sewer) collection service. The Orange County Sanitation

District (OCSD) treats wastewater generated in the City. The project is located within a

developed area with an existing public wastewater main in South State College Blvd,

adjacent to the site that currently serves the property. The latest Central Anaheim Master

Plan of Sanitary Sewers does not identify existing wastewater facilities in South State

College Blvd as deficient in either the “Existing” or “Build-out” conditions.24 Due to the

small amounts of wastewater produced by the proposed project there would not be

significant impacts to the current sewer system. Therefore, impacts would be less-than-


Stormwater. On-site grading and drainage improvements proposed in conjunction with the

proposed site work would be required to meet the City’s and Orange County Flood Control

24City of Anaheim, Central Anaheim Master Plan of Sanitary Sewers. December 2017. Accessible at

https://www.anaheim.net/583/Storm-Drainage-Sanitary-Sewer-Master-Pla, Accessed on April 15, 2020.

https://www.anaheim.net/583/Storm-Drainage-Sanitary-Sewer-Master-Pla



District’s (OCFCD) flood control criteria including design discharges, design/construction

standards and maintenance features. As discussed in Section 3.10(a) Hydrology and Water

Quality, the proposed project’s drainage pattern will remain the same except for the

mitigated treatment runoff volume that the proposed project will divert to an underground

system to infiltrate into the soil. Runoff from the new buildings will discharge at grade;

new v-gutters will convey the runoff along the fronts of the building, maintaining the

existing drainage paths. The proposed project would not alter any drainage pattern in a

manner that would result in substantial erosion or siltation on or offsite. There are no

streams or rivers on the site that the proposed project would alter. Erosion and siltation

impacts potentially resulting from the proposed project would, for the most part, occur

during the project’s site preparation and grading phase. Implementation of the NPDES

permit requirements, SWPPP and BMPs as they apply to the site, would reduce potential

erosion, siltation, and water quality impacts. Therefore, impacts would be less-than-


Electrical Power, Natural Gas, Telecommunications. The project site is in a developed,

urbanized portion of the City that and is served by existing electrical power, natural gas,

and telecommunications services. The proposed project is an existing commercial storage

facility that would develop new buildings. The project site is adjacent to other existing

commercial operations and uses. New electricity, gas, and telecommunications

connections would be established for the project; however, no substantial electrical, gas,

or telecommunications infrastructure is present on or adjacent to the project site that would

need to be relocated to accommodate the project. Therefore, impacts would be less-than-


b) Less-than-significant impact. APUD, Water Services Division, operates the City’s water

production and distribution system. The City of Anaheim 2015 Urban Water Management

Plan (UWMP) was prepared in compliance with the requirements of the Urban Water

Management Planning Act (UWMPA). The UWMPA requires every urban water supplier

providing water for municipal purposes to more than 3,000 customers or supplying more

than 3,000 AF of water annually to prepare, adopt, and file a UWMP with the California

Department of Water Resources (DWR) every five years in the years ending in zero and

five. The2015 UWMP provides water supply planning for a 25-year planning period in

five (5)-year increments and identifies water supplies needed to meet existing and future

demands. The demand analysis must identify supply reliability under three hydrologic

conditions: a normal year, a single-year, and multiple dry years. The City’s service area is

approximately 49.63 square miles and includes approximately 63,800 municipal

connections. The City relies on a combination of approximately 70 percent local

groundwater from the Orange County Groundwater Basin (OC Basin) and 30 percent

imported water from the Colorado River and State Water Project supplies provided by the

Municipal Water District (MWD). The current water system includes eight (8) import

connections to MWD, 18 active wells, 14 water reservoirs, and approximately 752 miles

of water mains. The City also maintains 14 interconnections with neighboring cities and

districts to supply water during emergencies. In 2015, the City supplied a volume of

approximately 62,053 AF of water to municipal customers. In its most recent UWMP, the

City determined that it would have reliable supplies to meet single-and multiple dry-year



demands from 2020 through 2040, even with a six percent increase from 2015 demand

totals. The City expects total demand to increase from 62,050 AF in 2020 to 67,143 AF in

2040. The City would meet this demand through diversified supply and water conservation

measures. The UWMP also includes a Water Shortage Contingency Plan that describes

policies that MWD and the City have in place to respond to catastrophic interruption and

reduction in water supply. The proposed project would result in 147,670 sq. ft. of building

floor area and proposes no water-intensive activities or uses in or around the facility. The

proposed project would not exceed water supplies or result in a significant increase in

water demand. Therefore, less-than-significant impacts would occur and no mitigation


c) Less-than-significant impact. As discussed in section 3.19(a) Utilities and Service

Systems, the City’s sanitary sewer collection service would serve the proposed project .

OCSD treats wastewater generated in the City. The project is located within a developed

area with an existing public wastewater main in South State College Boulevard, adjacent

to the site that currently serves the property. The the latest Central Anaheim Master Plan

of Sanitary Sewers does not identify existing wastewater facilities in South State College

Boulevard as deficient in either the “Existing” or “Build-out” conditions. There would be

small amounts of wastewater produced by the proposed project. Therefore, less-than-


d) Less-than-significant impact. Republic Services, a private recycling and non-hazardous

solid waste hauler, provide solid waste services in the City. Republic Services is

responsible for all residential, commercial, and industrial waste and recycling services.

Solid waste is disposed of in Orange County Waste and Recycling Landfills. Currently,

there are three active landfills in the County: Olinda Alpha, Frank R. Bowerman, and

Prima Deshecha. The landfills are among the largest statewide and receive more than four

million tons of waste annually. Olinda-Alpha Landfill in the City of Brea accepts up to

8,000 tons per day (tpd) and has a remaining capacity of 34,200,000 cubic yards (cy).

Frank R. Bowerman Landfill in the City of Irvine accepts up to 11,500 tpd and has a

remaining capacity of 205,000,000 cy. Prima Deshecha Landfill in San Juan Capistrano

accepts up to 4,000 tpd and has a remaining capacity of 134,300,000 cy. The proposed

project would include the demolition of the existing paved surfaces on site, which would

require the project applicant to remove debris from the project site. In compliance with the

State of California Waste Management Act (AB 939) and California Green Building

Codes, the City requires applicants to deposit 65 percent or more of demolition debris

generated at a project site from landfills. Existing landfills have sufficient capacity to serve

the proposed project. Compliance with all applicable regulations and laws regarding solid

waste would further reduce impacts. Therefore, impacts would be less than significant and

no mitigation is required.

e) Less-than-significant impact. As discussed above, solid waste would be disposed of at

existing Orange County Waste and Recycling landfills. Disposal of solid waste would

comply with all federal, state, and local statues and regulations related to solid waste. The

proposed project would include receptacles for recyclables and garbage. Therefore,




3.20 Wildfire

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No


a) Substantially impair an adopted emergency

response plan or emergency evacuation plan? ☐ ☐ ☐ ☒

b) Due to slope, prevailing winds, and other

factors, exacerbate wildfire risks, and thereby

expose project occupants to pollutant

concentrations from a wildfire or the

uncontrolled spread of a wildfire?

☐ ☐ ☐ ☒

c) Require the installation or maintenance of

associated infrastructure (such as roads, fuel

breaks, emergency water sources, power

lines or other utilities) that may exacerbate

fire risk or that may result in temporary or

ongoing impacts to the environment?

☐ ☐ ☐ ☒

d) Expose people or structures to significant

risks, including downslope or downstream

flooding or landslides, as a result of runoff,

post-fire slope instability, or drainage

changes?

☐ ☐ ☐ ☒

a-c) No Impact. According to the CAL FIRE Hazard Severity Zone Map for the City of

Anaheim, the project site is not within a State Responsibility Area.25 The project site is in

a Non-Very High Fire Hazard Severity Zone (VHFHSZ) zone within a local responsibility

area. The project site is flat and does not have a slope or other features that could

exacerbate wildfire risks. The proposed project would tie into existing infrastructure that

currently serves the project area. Project implementation would not result in the new

construction, installation, or maintenance of new infrastructure that would exacerbate fire

risk. The proposed project construction would not require the complete closure of any

public or private streets or roadways during construction. Temporary construction

activities would not impede use of the road for emergencies or access for emergency

response vehicles. The proposed project would not result in inadequate emergency access.

Therefore, no impact would occur and no mitigation measures are required.

d) No Impact. The proposed project is located in a developed, urbanized area, and

surrounded primarily by commercial and residential uses. There are no slopes or hills near

the project site. Absent these conditions, the proposed project would not have the potential

to expose people or structures to significant risks due to runoff, post-fire slope instability,

or drainage changes. Therefore, no impacts would occur and no mitigation measures are

required,

25CalFire, Anaheim Very High Fire Hazard Severity Zones in LRA. Accessible at

https://www.anaheim.net/DocumentCenter/View/5085/Very-High-Fire-Hazard-Severity-Zones-in-LRA?bidId=,

Accessed April 23, 2020.

https://www.anaheim.net/DocumentCenter/View/5085/Very-High-Fire-Hazard-Severity-Zones-in-LRA?bidId=



3.21 Mandatory Findings of Significance

Issues

Potentially

Significant

Impact

Less Than

Significant

With

Mitigation

Incorporated

Less Than

Significant

Impact

No

Impact

a) Does the project have the potential to

substantially degrade the quality of the

environment, substantially reduce the habitat

of a fish or wildlife species, cause a fish or

wildlife population to drop below self-

sustaining levels, threaten to eliminate a

plant or animal community, substantially

reduce the number or restrict the range of a

rare or endangered plant or animal or

eliminate important examples of the major

periods of California history or prehistory?

☐ ☐ ☒ ☐

b) Does the project have the potential to achieve

short-term environmental goals to the

disadvantage of long-term environmental

goals?

☐ ☐ ☒ ☐

c) Does the project have impacts that are

individually limited, but cumulatively

considerable? (“Cumulatively considerable”

means that the incremental effects of a

project are considerable when viewed in

connection with the effects of past projects,

the effects of other current projects, and the

effects of probable future projects.)

☐ ☐ ☒ ☐

d) Does the project have environmental effects

which will cause substantial adverse effects

on human beings, either directly or

indirectly?

☐ ☐ ☒ ☐

a) Less-than-significant impact. The project site does not contain any special status or

sensitive biological resources. The proposed project would not substantially reduce the

habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-

sustaining levels threaten to eliminate sensitive plant or animal community, or

substantially reduce the number or restrict the range of a rare or endangered plant or

animal.

The proposed project would involve earthmoving activities that could potentially unearth

or disturb prehistoric archaeological resources. Such actions could unearth, expose, or

disturb subsurface paleontological, archaeological, historical, or Native American

resources that were not observable on the surface. However, with the incorporation of

mitigation measures, potential affects to paleontological or cultural resources that

represent major periods of California history or prehistory would be less than significant.

b) Less-than-significant impact. As discussed through this Initial Study, the proposed



project would not have short-term and/or long-term environmental impacts with

implementation of mitigation measures related to air quality, cultural resources, geology

and soils, hazards and hazardous materials, transportation, and tribal cultural resources.

Therefore, the proposed project would not result in failure to achieve short-term nor long-

term environmental goals. Impacts would be less than significant, and no additional


c) Less-than-significant impact. As discussed throughout this Initial Study, the proposed

project would have no impact and/or less than significant impacts with and without

mitigation measures. Therefore, all impacts are individually limited and do not result in

any cumulatively significant impacts. No additional mitigation measures are required.

d) No Impact. All potential impacts of the proposed project have been identified, and

mitigation measures have been prescribed, where applicable, to reduce all potential

impacts to less-than-significant levels. Upon implementation of mitigation measures

included in this Initial Study and compliance with existing regulations, the proposed

project would not have the potential to result in substantial adverse impacts on human

beings either directly or indirectly. Therefore, impacts would be less-than-significant and




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Anaheim Fire and Rescue. 2017. Standards of Cover 2017-2022.

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ards%20of%20Cover13358.pdf

Arcadis, City of Anaheim 2015 Urban Water Management Plan, June 2016

http://anaheim.net/DocumentCenter/View/11777/Anaheim-UWMP-2016?bidId=

Blue Peak Engineering, Inc. County of Orange/Santa Ana Region Priority Project Preliminary

Water Quality Management Plan (PWQMP) Blue August 6, 2019.

Blue Peak Engineering, Inc. Preliminary Drainage Study, May 24, 2018

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https://www.anaheim.net/DocumentCenter/View/5085/Very-High-Fire-Hazard-Severity-Zones-

in-LRA?bidId=,

California Air Pollution Control Officers Association (CAPCOA). 2017. California Emissions

Estimator Model (CalEEMod). Version 2016.3.2.

California Air Resources Board (CARB), Area Designations Maps/State and National,

http://www.arb.ca.gov/desig/desig.htm

California Air Resources Board (CARB), Final Proposed Short-Lived Climate Pollutant

Reduction Strategy, March 2017. https://www.arb.ca.gov/cc/shortlived/shortlived.htm.

California Air Resources Board (CARB). 2017a, March 14. Final Proposed Short-Lived Climate

Pollutant Reduction Strategy. https://www.arb.ca.gov/cc/shortlived/shortlived.htm.

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Appendix A

Air Quality Calculations



Appendix B

Tribal Consultation



Appendix C

Geotechnical Engineering Report



Appendix D

Preliminary Drainage Study



Appendix E

Preliminary Water Quality Management Plan

(PWQMP)



Appendix F

Trip Generation Report

1 project information

Documents