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SUPPLEMENTAL ITEM #3 TLSP
SUPPLEMENTAL ITEM #3 TUSTIN LEGACY SPECIFIC PLAN EIS/EIR ADDENDUM/INITIAL STUDY (SEPTEMBER 2019) LEGACY MEDICAL PLAZA TUSTIN, CALIFORNIA TUSTIN LEGACY SPECIFIC PLAN ENVIRONMENTAL IMPACT STATEMENT/ENVIRONMENTAL IMPACT REPORT ADDENDUM/INITIAL STUDY SCH NO. 1994071005 Prepared for- M=2011 South Orange County Community College District 28000 Marguerite Parkway Mission Viejo,California 92692 Prepared by: E I P 1 D SOLUTIONS, INC. EPD Solutions, Inc. 2 Park Street,Suite 1 120 Irvine,California 92614 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Table of Contents Table of Contents 1. Introduction....................................................................................................................................1 1.1 Project Summary.........................................................................................................................................1 1.2 Organization of Addendum.....................................................................................................................1 1.3 Development Background.........................................................................................................................1 1.4 Previous Environmental Documentation..................................................................................................2 1.5 Purpose of this Addendum........................................................................................................................4 1.6 Basis for an EIR Addendum......................................................................................................................4 1.7 Evaluation of Alternatives.........................................................................................................................5 1.8 Summary of Findings.................................................................................................................................5 1.9 Intended Use of this Addendum..............................................................................................................6 1.10 Environmental Checklist Form...................................................................................................................6 1.10.1 Project Title............................................................................................................................................7 1.10.2 Lead Agency Name,Address and Contact Person........................................................................7 1.10.3 Responsible Agency Name,Address and Contact Person............................................................7 1.10.4 Project Location.....................................................................................................................................7 1.10.5 Project Sponsor's Name and Address..............................................................................................7 1.10.6 General Plan Designation—Existing ...............................................................................................7 1.10.7 Zoning - Existing...................................................................................................................................8 1.10.8 Environmental Factors Potentially Affected.....................................................................................8 1.10.9 Environmental Determination..............................................................................................................9 2. Project Description.......................................................................................................................10 2.1 Project Site Location and Composition................................................................................................ 10 2.2 Project Components................................................................................................................................ 14 2.2.1 Project Entitlements............................................................................................................................ 14 2.2.2 Project Improvements and Use........................................................................................................ 14 2.2.3 Parking Area..................................................:................................................................................... 19 2.2.4 Utilities................................................................................................................................................. 19 2.2.5 Landscaping & Stormwater Management.................................................................................... 19 3. Environmental Evaluation and Explanation of Checklist Responses..........................................19 3.1 Aesthetics..................................................................................................................................................20 3.1.1 Existing Conditions.............................................................................................................................20 3.1.2 Project Impact Evaluation.................................................................................................................20 3.2 Agriculture and Forest Resources.........................................................................................................23 3.2.1 Existing Conditions.............................................................................................................................23 3.2.2 Project Impact Evaluation..........................................................................................:......................23 3.3 Air Quality................................................................................................................................................25 3.3.1 Existing Conditions.............................................................................................................................25 3.3.2 Project Impact Evaluation.................................................................................................................25 3.4 Biological Resources................................................................................................................................29 3.4.1 Existing Conditions.............................................................................................................................29 3.4.2 Project Impact Evaluation.................................................................................................................29 3.5 Cultural Resources...................................................................................................................................32 3.5.1 Existing Conditions.............................................................................................................................32 3.5.2 Project Impact Evaluation.................................................................................................................32 3.6 Energy.......................................................................................................................................................34 3.6.1 Existing Conditions.............................................................................................................................34 3.6.2 Project Impact Evaluation.................................................................................................................34 3.7 Geology and Soils..................................................................................................................................36 3.7.1 Existing Conditions.............................................................................................................................36 3.7.2 Project Impact Evaluation.................................................................................................................36 3.8 Greenhouse Gas Emissions....................................................................................................................40 i August 2019 Legacy Medical Plaza Addendum/Environmental Checklist Table of Contents 3.8.1 Existing Conditions.............................................................................................................................40 3.8.2 Project Impact Evaluation.................................................................................................................40 3.9 Hazards and Hazardous Materials.....................................................................................................42 3.9.1 Existing Conditions.............................................................................................................................42 3.8.2 Project Impact Evaluation.................................................................................................................42 3.10 Hydrology and Water Quality............................................................................................................45 3.10.1 Existing Conditions.............................................................................................................................45 3.10.2 Project Impact Evaluation.................................................................................................................45 3.11 Land Use and Planning .........................................................................................................................49 3.1 1.1 Existing Conditions............................................................................................................................49 3.1 1.2 Project Impact Evaluation.................................................................................................................49 3.12 Mineral Resources...................................................................................................................................52 3.12.1 Existing Conditions.............................................................................................................................52 3.12.2 Project Impact Evaluation.................................................................................................................52 3.13 Noise............................................ 54 I 3.13.1 Existing Conditions.............................................................................................................................54 3.13.2 Project Impact Evaluation.................................................................................................................54 3.14 Population and Housing.........................................................................................................................57 3.14.1 Existing Conditions.............................................................................................................................57 3.14.2 Project Impact Evaluation.................................................................................................................57 3.15 Public Services..........................................................................................................................................59 3.15.1 Existing Conditions.............................................................................................................................59 3.15.2 Project Impact Evaluation.................................................................................................................59 3.16 Recreation...................... 63 3.16.1 Existing Conditions.............................................................................................................................63 3.16.2 Project Impact Evaluation.............................................. .....................................63 3.17 Transportation..........................................................................................................................................65 g 3.17.1 Existing Conditions.............................................................................................................................65 3.17.2 Project Impact Evaluation.................................................................................................................65 i 3.18 Tribal Cultural Resources.......................................................................................................................70 j 3.18.1 Existing Conditions........................................................................................................................ 70 3.18.2 Project Impact Evaluation.................................................................................................................70 3.19 Utilities and Service Systems.................................................................................................................73 J 3.19.1 Existing Conditions.............................................................................................................................73 3.18.2 Project Impact Evaluation.................................................................................................................73 3.20 Wildfire.....................................................................................................................................................76 a 3.20.1 Existing Conditions.............................................................................................................................76 3.20.2 Project Impact Evaluation.................................................................................................................76 3.21 Mandatory Findings of Significance....................................................................................................78 4. Summary of Mitigation Measures...............................................................................................80 5. Sources/Acronyms.......................................................................................................................96 5.1 Sources......................................................................................................................................................96 5.2 Acronyms...................................................................................................................................................98 6. Report Preparers......................................................................................................................100 List of Figures Figure1. Regional Map................................................................................................................................................. 11 Figure2. Project Site Boundaries................................................................................................................................. 12 Figure3.Aerial of Project Site..................................................................................................................................... 13 Figure1. Conceptual Site Plan..................................................................................................................................... 15 Figure5. Conceptual Floor Plan................................................................................................................................... 16 Figure6. Conceptual Elevations.............................................................................................................................17-18 ii September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Table of Contents List of Tables Table 1. Environmental Factors Potentially Affected..................................................................................................8 Table2. Environmental Determination............................................................................................................................9 Table 3. Proposed Development Breakdown............................................................................................................ 14 Table 4. Project Trip Generation.......................................................................................67 Table S. Specific Plan FEIS/EIR Mitigation Measures Applicable to Project Site...............................................81 Appendix Appendix A 2018 Annual Mitigation Monitoring and Status Report,MCAS Tustin FEIS/EIR iii September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Introduction I . Introduction 1 .1 Project Summary The Legacy Medical Plaza (proposed Project) consists of the construction of one medical office building (Legacy Medical Plaza)on a site owned by the South Orange County Community College District(SOCCCD or District)in the Advanced Technology Education Park(ATEP)in Tustin Legacy in the city of Tustin.The Legacy Medical Plaza consists of approximately 50,000 square feet(SF)of gross floor area in a two-story structure. The Project would include infrastructure improvements such as parking areas, underground utility line connections, landscaping, and new access driveways on Hope Drive and Victory Road. Access will also be provided via the existing Innovation Drive via a new driveway connecting to the Project site to the east. Further details about the proposed Project can be found in Section 2.Project Description.The Project requests the following approvals from the City of Tustin: Site Plan and Design Review (Limited Site Plan Review for Land Use Category 2), and Issuance of a Grading Permit. The Project will be approved, carried out, and implemented by SOCCCD as Lead Agency and the City of Tustin(City) as a Responsible Agency. 1 .2 Organization of Addendum The organization of this CEQA document is according to the following sections: Section 1: Introduction Section 2: Project Description Section 3: Environmental Evaluation / Section A: Summary of Mitigation Measures Section 5: Sources/Acronyms Section 6: Report Preparers Appendix This Addendum incorporates the Environmental Checklist Form from Appendix G of the State CEQA Guidelines as the Initial Study. The environmental issue impact questions contained in Section 3 of this document also conform to the required contents of this Environmental Checklist Form. 1.3 Development Background As mentioned previously,the project site is within the City of Tustin and on property owned by the SOCCCD. The Project site and surrounding area has undergone previous planning efforts detailed below. MCAS Tustin Reuse Plan The Marine Corps Air Station (MCAS),Tustin was realigned and closed on July 2, 1999,in accordance with the Base Realignment and Closure Act. When the original decision was made in 1991 to close MCAS Tustin, the City of Tustin began planning for a reuse plan. The Department of Defense recognized the City of Tustin as the Lead Agency or Local Redevelopment Authority for preparation of the required reuse planning documents. The City of Tustin determined that the most appropriate tool to guide the conversion of the base from military to civilian use and to facilitate entitlements and permitting was the preparation of a combined Specific Plan/Reuse Plan. The MCAS Tustin was divided up into 1,500 acres of land within the City of Tustin and 95 acres in the City of Irvine.The Reuse Plan was adopted in 1996. Conveyance of property to the City of Tustin was officially approved with the execution of an Agreement between the United States of America and the City of Tustin, California for the Conveyance of a Portion of ( the Former Marine Corps Air Station Tustin dated May 13,2002,as subsequently amended (as so amended, 1 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Introduction the"Navy Agreement").The Agreement provided for the phased conveyance of approximately 1,153 acres at the former MCAS Tustin located within the City of Tustin and all utility systems at the former facility (within both the City of Tustin and City of Irvine jurisdictional boundaries) and certain personal property items. The Navy Agreement also identified parcels that the Navy would auction to private developers. Following approval of the Navy Agreement additional conveyances were made between the City and other agencies including, but not limited to the Orange County Sheriff's Department, Tustin Unified School District, Irvine Unified School District, Rancho Santiago Community College District,and SOCCCD. MCAS Tustin Specific Plan The MCAS Tustin Specific Plan was originally adopted in 2003 and has been amended several times since then to respond to changing market conditions.A Specific Plan is one tool for implementing goals and policies of the Tustin General Plan.A Specific Plan also contains the development and reuse regulations that constitute the zoning for the property. As a federal installation, MCAS Tustin was not subject to local zoning and planning requirements. Since conversion to civilian use,the property is now under the jurisdictional authority of either the City of Tustin or the City of Irvine and is subject to local codes and ordinances. In 2017,the City approved a comprehensive amendment to the MCAS Tustin Specific Plan and renamed the document as the "Tustin Legacy Specific Plan."This amendment did not change the land use or allowed uses on the ATEP site from those permitted prior to the amendment. SOCCCD ATEP Development Agreement and Development Framework The ATEP site is located at the western portion of the Tustin Legacy Specific Plan and partially owned by in fee the SOCCCD with remaining leased to SOCCCD. SOCCCD staff originally developed various plans based on an irregularly-shaped 68-acre site.In 2013,negotiations between SOCCCD and the City resulted in a land exchange between the two agencies,a decision to extend Bell Avenue(now Victory Road)through the ATEP Site, and a Development Agreement and Restated Conveyance Agreement(DA) permitting up to 1,087,970 SF of education-oriented and general office use building space. The Development Agreement also set in place the development standards that are applicable to the ATEP site, which includes the City of Tustin Municipal Code and MCAS Tustin Specific Plan (referred to herein as the "Effective Standards"). The ATEP site was also reconfigured and the acreage slightly reduced to 62 acres. In 2015, SOCCCD adopted the Development Framework for the ATEP site to inform future development design for Saddleback College, Irvine Valley College, and for non-SOCCCD educational and non-educational partners. 1 A Previous Environmental Documentation A Final Joint Program Environmental Impact Statement/Environmental Impact Report (FEIS/EIR) for the Disposal and Reuse of Marine Corps Air Station (MCAS) Tustin was prepared by the City of Tustin and the Department of the Navy (Navy) in accordance with the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA) dated October 1996, as amended by the Errata dated September 1998. The Mitigation Monitoring and Reporting Program (MMRP) for the FEIS/EIR was adopted by the City on January 16, 2001 (Resolution 00-90). On March 3, 2001, a Record of Decision (ROD) was issued by the Navy approving the FEIS/EIR (2001 FEIS/EIR) and the Specific Plan. The following State Clearinghouse number is associated with the 2001 FEIS/EIR: 1994071005. There have been two supplements and six addenda to the 2001 FEIS/EIR: 1. Supplement to the FEIS/EIR in 2004 for a one-mile extension of Tustin Ranch Road from Walnut Avenue on the north to the future alignment of Valencia North Loop Road on the south; 2. Addendum to the FEIS/EIR in 2006 for the MCAS Tustin Zone Change (Specific Plan Amendment) 05-002, Master Developer Disposition and Development Agreement, and Development Plan Addendum; C 2 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Introduction 3. Addendum in 2008 related to SOCCCD's approval of a Long-Range Academic & Facilities Plan and a Long-Range Academic Plan for ATEP (SOCCCD Resolution 08-35) (2008 Addendum); 4. Addendum in 2009 related to a Concept Plan for Phase 3A of the ATEP campus (Phase 3A Concept Plan Addendum) (SOCCCD Resolution 09-05) (2009 Addendum); 5. Addendum in 2011 related to an exchange of land between the District and the County of Orange (SOCCCD Resolution 11-38) (201 1 Addendum); 6. Addendum to the FEIS/EIR in 2013 to process General Plan Amendment 2013-001, Specific Plan Amendment 2013-001, Development Agreement 2013-002, and an Agreement for Exchange of Real Property between the City and SOCCCD on 22 acres (SOCCCD Resolution 13-18) (2013 Addendum); 7. Addendum in 2016 related to the ATEP First Building and Infrastructure Improvements Project; an addendum on May 23, 2016 related to the Restated Exchange Agreement and Ground Lease between SOCCCD and the County of Orange (2016 Addendum); and 8. Supplemental EIR on July 20,2017 (2017 Supplemental EIR)for a General Plan Amendment 2015- 02 and Specific Plan Amendment 2015-01 (Tustin Legacy Specific Plan). The 2017 Supplemental EIR analyzed the potential impacts related to land use changes to Planning Areas 8 through 19, which resulted in 2,212 more residential units and 1,755,306 fewer square feet within the Tustin Legacy Specific Plan. The 2001 FEIS/EIR document,the supplements,and the City's and District's addenda are collectively referred to herein as the "FEIS/EIR." In addition,the City has certified multiple CEQA documents associated with prior amendments to the MCAS Tustin Specific Plan and development projects within Tustin Legacy. Section 1.5.2 of the 2001 FEIS/EIR states that the FEIS/EIR is a Program EIR and it is intended to be used as the CEQA compliance document for all public and private actions made in furtherance of,the Specific Plan. The FEIS/EIR analyzed the environmental consequences of the Navy disposal and local community reuse of the MCAS Tustin per the Reuse Plan and the MCAS Tustin Specific Plan/Reuse Plan (MCAS Tustin Specific Plan), which was subsequently amended to be called the Tustin Legacy Specific Plan (when referring to the MCAS Tustin Specific Plan,Tustin Legacy Specific Plan and amendments,they are referred to in this document as the Specific Plans).The CEQA analysis also analyzed the environmental impacts of certain"Implementation Actions" that the City of Tustin and City of Irvine must take to implement the MCAS Tustin Specific Plan, including but not limited to the adoption by the City of Tustin of the MCAS Tustin Specific Plan and adoption of the MCAS Tustin Redevelopment Plan. The MCAS Tustin Specific Plan proposed and the FEIS/EIR analyzed a multi-year development period for the planned urban reuse project (Tustin Legacy). When individual activities within the Specific Plans are proposed,the lead agency is required to examine the individual activities to determine if their effects were fully analyzed in the FEIS/EIR.The agency can approve the activities as being within the scope of the project covered by the FEIS/EIR. If the agency finds that pursuant to Sections 15162, 15163, 15164, and 15183 of the CEQA Guidelines no new effects would occur, nor would a substantial increase in the severity of previously identified significant effects occur,then no supplemental or subsequent EIR is required.1 ( MCAS Tustin Zone Change(Specific Plan Amendment)05-002,Development and Disposition Agreement and Development Plan Addendum,p. 1-1. 3 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Introduction 1 .5 Purpose of this Addendum Pursuant to Sections 15051 and 15367 of the State CEQA Guidelines,SOCCCD is the Lead Agency for the CEQA compliance associated with the Project because it will approve,carry out, and implement the Project and will be the first agency to approve the Project.The City will be a responsible agency. Based on the analysis in this Initial Study and Addendum,the SOCCCD determined that the potential impacts of the Project were previously analyzed in or are substantially similar to the impacts analyzed in the FEIS/EIR and that none of the conditions identified in Public Resources Code Section 21 166 or Section 15162 of the CEQA Guidelines apply. The SOCCCD determined that they would prepare this Addendum to: (1) evaluate whether the Project's environmental impacts were already analyzed in the FEIS/EIR; (2) document the District's findings with respect to the Project and its environmental determinations; and, (3) evaluate and document that a new, supplemental or subsequent EIR, Negative Declaration (ND), or Mitigated Negative Declaration (MND) or other CEQA document was not warranted. This Addendum is the appropriate CEQA documentation for the project because: • the Project does not change the land uses that are currently permitted within the Tustin Legacy Specific Plan,the impacts of which have been previously analyzed in the FEIS/EIR; • the Project would not permit an intensification of permitted uses that would lead to increased environmental impacts beyond those that are already identified in the FEIS/EIR; • the Project does not modify previously analyzed projects in any substantive way; • no new mitigation measures are required; • none of the conditions identified in Public Resources Code Section 21 166 or Section 15162 of the CEQA Guidelines apply; and, • no new significant adverse project-specific or cumulative impacts in any environmental areas were identified,nor would any project-specific or cumulative impacts in any environmental areas be made worse as a result of implementing the Project. 1 .6 Basis for an EIR Addendum An agency may prepare an addendum to a prior EIR pursuant to CEQA Guidelines Section 15164 that states, in pertinent part,that: "The lead agency [...] shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for the preparation of a subsequent EIR have occurred."An agency may prepare an addendum to document its decision that a subsequent EIR is not required. (CEQA Guidelines Section 15164,subdivisions (a) and (e) and Section 15162,subdivision (a)). The Project is consistent with and aids in the implementation of the Specific Plans and DA. Specifically, the Project is considered to be in Land Use Category 2 of the DA and would not change the overall intent of the Education Village (PA-1), which is described as a "specialized educational environment with an array of public-serving uses" (Tustin Legacy Specific Plan,pg.2-10).The uses permitted by the DA further SOCCCD's educational mission as discussed in SOCCCD's Long-Range Academic and Facilities Plan, dated October 2008 and which was the subject of an addendum certified on November 12,2008 (SOCCCD Resolution 08- 35). Furthermore,the DA allows for permitted uses consistent with the educational mission of SOCCCD. Such mission is to have tenants on the ATEP site who are engaged in or supportive of activities which consist principally of research and development, other technology-oriented businesses or operations which are complementary or closely related to curricula then taught on the ATEP site. SOCCCD envisioned educational activities on the ATEP site as well as partnerships with appropriate business enterprises to provide internships, workforce training opportunities, and other innovative arrangements. In 2013,an amendment was proposed to the MCAS Tustin Specific Plan and Development Agreement,which was subject to an addendum certified on May 22, 2013. The 2013 Addendum consisted of an agreement 4 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Introduction between the District and the City called the Agreement for the Exchange of Real Property (Exchange Agreement). The Exchange Agreement delineates the terms and processes associated with the exchange of the ultimate ownership of approximately 22 acres of land within the former MCAS Tustin, an area now referred to as "Tustin Legacy."The project also included an amendment to the MCAS Tustin Specific Plan to modify the permitted land uses and land use intensities in parts of Neighborhood A and to construct an extension of Bell Avenue as a Secondary Arterial (now existing Victory Road); a General Plan Amendment (GPA) to add the Bell Avenue (Victory Road) extension to the City's circulation plan and correct preexisting inconsistencies with the MCAS Tustin Specific Plan;the DA and associated implementation documents;and an agreement for the funding and construction of Bell Avenue (Victory Road). At least one project has been developed under the Development Framework and Development Agreement, which was analyzed under the 2013 and 2016 addendum: the School of Integrated Design, Engineering and Automation (IDEA) at ATEP(IDEA Building),which was subject to an addendum certified on May 2,2016. Further, relative to the overall Tustin Legacy development, the Project would not significantly change the intensity or scale of development approved in the Tustin Legacy Specific Plan, District's DA, Long-Range Academic and Facilities Plan (LRP),Concept Plan, Land Exchange Agreement, or analyzed in the previously certified FEIS/EIR. There are no new significant impacts resulting from the Project, nor is there any substantial increase in the severity of any previously identified environmental impacts. In addition, the circumstances under which the Project would be implemented would not result in new or more severe significant environmental impacts. None of the conditions described in Section 15162 of the CEQA Guidelines have occurred. Specifically, there have not been:(1)changes to the Project that require major revisions to the previously certified FEIS/EIR l or addenda due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects;(2)substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions to the previous FEIS/EIR or addenda due to the i i involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant s effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR or addenda was certified as complete. SOCCCD and Project Sponsor will continue to comply with j the adopted applicable MMRPs. i 1 .7 Evaluation of Alternatives CEQA requires a comparative evaluation of a Project and alternatives to the Project, including the "No Project" alternative. This Addendum relies on the FEIS/EIR for the evaluation of alternatives. The FEIS/EIR addressed a reasonable range of alternatives for the project. The City of Tustin is implementing Alternative 1 of the FEIS/EIR,and there is no information indicating that the City should implement a different alternative or that a different alternative is feasible. Consistent with Section 15183 of the State CEQA Guidelines that identifies which environmental evaluation is required for projects that are consistent with a community plan or zoning,there is no need to address new alternatives in this Addendum. Additionally, there are no circumstances cited in Section 15162 of the State CEQA Guidelines, which require preparation of a subsequent EIR relative to alternatives. 1 .8 Summary of Findings Based on the initial study analysis and environmental checklist prepared for the Project and pursuant to Section 15162, 15163, 15164,and 15183 of the CEQA Guidelines,SOCCCD has determined,on the basis of substantial evidence in the light of the whole record,that: 5 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Introduction • The Project was examined in light of the FEIS/EIR and has been adequately analyzed in the FEIS/EIR because the Project does not substantively modify the previously-analyzed proposal included in the Tustin Legacy Specific Plan; • The Project would not have any effects that were not already examined in the FEIS/EIR , no new mitigation measures are required, and there are no new significant adverse project-specific or cumulative impacts in any environmental areas that were identified, nor would any project-specific or cumulative impacts in any environmental areas be made worse as a result of implementing the Project; • All feasible mitigation measures identified in the FEIS/EIR have been incorporated into subsequent actions that the Project Sponsor commit to fully implement; • There is no information indicating that a different Alternative should be implemented or is feasible under the Tustin Legacy Specific Plan; • The Project does not propose substantial changes to the Tustin Legacy Specific Plan or DA which would require major revisions to the FEIS/EIR due to new or substantially more severe significant environmental effects than previously analyzed in the FEIS/EIR; • There have been no substantial changes in circumstances under which the Project would be undertaken that would require major revisions to the FEIS/EIR due to new or substantially more severe significant environmental effects than previously analyzed in the FEIS/EIR; and • No new information of substantial importance as described in subsection (a)(3) of Section 15164 has been revealed that would require major revisions to the FEIS/EIR or their conclusions. 1 .9 Intended Use of this Addendum This Addendum, which includes the Environmental Checklist/Initial Study for the Project, will serve as the appropriate CEQA documentation for all applicable public agency decision-makers and the public regarding the objectives and components of the Project. The CEQA Guidelines defines an Initial Study as a preliminary analysis prepared by a Lead Agency to determine whether a new,supplemental,or subsequent EIR, Negative Declaration(ND),or Mitigated Negative Declaration (MND) or other CEQA document must be prepared or to identify the significant environmental effects to be analyzed in an EIR.2 This Addendum has been prepared in accordance with the following: • California Environmental Quality Act of 1970 (Public Resources Code Sections 21000-21177); • California Code of Regulations, Title 14, Division 6, Chapter 3 (State CEQA Guidelines, Sections 15000-15387); and, • SOCCCD guidelines for the implementation of CEQA. This Addendum is intended to serve as the CEQA document for any activities by the City, SOCCCD, or any responsible or other agency's actions in implementing, approving, permitting, or carrying out the Project in any other way. 1 .10 Environmental Checklist Form This checklist and the following evaluation of environmental impacts takes into consideration the preparation of environmental documents prepared at an earlier stage in the Project.Therefore,the checklist and analysis evaluate whether the environmental effects of the Project were covered in the FEIS/EIR pursuant to Section 15162 and 15168 of the CEQA Guidelines. 2 California Code of Regulations, Title 14, Division 6, Chapter 3 (State CEQA Guidelines), Sections 15365 and 15367. - 6 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Introduction The FEIS/EIR analyzed a multi-year development period for the Tustin Legacy planned urban reuse project. When individual development activities within the Tustin Legacy Specific Plan are proposed,the lead agency is required to examine individual activities to determine if their effects were fully analyzed in the FEIS/EIR. The lead agency can approve the activities as being within the scope of the project covered by the FEIS/EIR if the agency finds that pursuant to Sections 15162, 15163, 15164, and 15183 of the CEQA Guidelines that no new effects would occur, nor would a substantial increase in the severity of previously identified significant effects occur. Then the lead agency can determine that no supplemental or subsequent environmental document is required. The Project will be approved, carried out, and implemented by SOCCCD. As lead agency, SOCCCD has prepared this comprehensive Environmental Checklist to determine if the Project is within the scope of the FEIS/EIR and if new effects would occur as a result of the Project and to document its findings in this Addendum. s In January 2018, the Governor's Office of Planning & Research (OPR) proposed updates to the CEQA j Guidelines to the California Natural Resources Agency. In late 2018,the Natural Resources Agency finalized the updates to the CEQA Guidelines. The updated Guidelines became effective on December 28, 2018. I 1.10.1 Project Title y 1 Legacy Medical Plaza Project S 1.10.2 Lead Agency Name,Address and Contact Person South Orange County Community College District 28000 Marguerite Parkway Mission Viejo, CA 92692 Attention:Ann-Marie Gabel,Vice Chancellor Business Services (949) 582-4664 1.10.3 Responsible Agency Name, Address and Contact Person City of Tustin 300 Centennial Way I Tustin, California 92780 Attention: Elizabeth Binsack,Community Development Director (714) 573-3140 9 1.10.4 Project Location The Project site is located on the westerly side of the Advanced Technology & Education Park (ATEP) site, I south of Orange County Rescue Mission, east of Red Hill Avenue, and north of Victory Road within the Tustin r Legacy development (former MCAS Tustin). 1.10.5 Project Sponsor's Name and Address ACS Development Group, Inc. 1.10.6 General Plan Designation — Existing Tustin Legacy Specific Plan 7 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Introduction 1.10.7 Zoning - Existing Tustin Legacy Specific Plan (SP-1 Specific Plan). The Project site is also covered by an existing DA. The Specific Plan designation for the Project site is Education Village (PA 1), located within Neighborhood A. 1.10.8 Environmental Factors Potentially Affected Any 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. The following table provides a summary of these environmental issue areas. Table 1. Environmental Factors Potentially Affected Aesthetics Agriculture and Forest Resources El Air Quality Biological Resources Cultural Resources Energy ❑ Geology/Soils ❑ Greenhouse Gas Emissions ❑ Hazards and Hazardous Materials Hydrology/Water Qualit Land Use/Planning Mineral Resources El I Noise Population/Housing I Public Services Recreation Transportation Tribal Cultural Resources ❑ Utilities/Service Systems ❑ Wildfire ❑ Mandatory Findings of Significance C C 8 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Introduction 1.10.9 Environmental Determination �. tl Based on this initial evaluation,the following table identifies the environmental determination. Table 2. Environmental Determination I 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. E I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. I find that the proposed project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards,and 2) has been addressed by mitigation 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 the significant effects that would result from the Project have been previously addressed in an earlier certified Environmental Impact Report (Tustin Legacy Specific Plan Amendment [General Plan Amendment 2015-02, Specific Plan Amendment 2015-01] Supplemental Environmental Impact Report,July 2017[State Clearinghouse No. 19940471005])and that none of the if the determinations set forth in the Public Resources Code Section 21166 and State CEQA Guidelines Section 15162 can be established and, thus, an ADDENDUM to Supplemental Environmental Impact Report shall be prepared. I find that although the proposed project could have an effect on the environment, there WILL NOT be a significant effect in this case 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, mitigated or overridden pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project,nothing further is required. { s Signature Date i Ann-Marie Gabel,Vice Chancellor Business Services South Orange County Community College District S I 9 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 2. Project Description 2.1 Project Site Location and Composition The Project site is located in the City of Tustin in the County of Orange within the former MCAS Tustin, now referred to as "Tustin Legacy" (regional map in Figure 1). Tustin Legacy encompasses the area within the City of Tustin. Tustin Legacy is a 1,51 1-acre mixed-use project,which will ultimately include housing,various commercial businesses, a various light industrial uses,schools,and community and regional parks. Portions of Tustin Legacy are developed, including an approximately one-million-square-foot outdoor shopping mall called "The District," single- and multi-family home communities, an elementary school, a homeless/transitional shelter, an abused and neglected children facility,a sheriff academy facility, Phase I of the ATEP campus and local parks.The city of Santa Ana borders Tustin Legacy to the west and southwest. Tustin Legacy is in close proximity to five freeways: the Costa Mesa (SR-55), Santa Ana (1-5), Laguna (SR- 133), Garden Grove (SR-22), and San Diego (1-405) freeways (see Figure 1). Major roadways bordering Tustin Legacy include Red Hill Avenue on the west, Edinger Avenue/Irvine Center Drive on the north, Jamboree Road on the east, and Barranca Parkway on the south. Jamboree Road provides access to the Eastern Transportation Corridor (SR-261 toll road). John Wayne Airport is located approximately 3.5 miles to the south, and the Tustin Metrolink Commuter Rail Station is located approximately 1.5 miles to the northeast of the Project site. The Project site is located on the western side of Tustin Legacy. The Project site consists of 3.5 acres,which is a part of the 62-acre ATEP site.The Project site is located within PA 1, which is a 128.3-acre portion of Neighborhood A (Figure 2). To the north of the Project site is the Orange County Rescue Mission and Hope Drive; east is the IDEA Building, City-owned buildings, a planned public community park and a Tustin Unified School District elementary school;south is Victory Road;and west is Red Hill Avenue. Demolition of all former military structures and associated infrastructure that once occupied the ATEP site was completed in two stages,in 2012 and 2015. 10 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation r f : Orange r�) Past acres Orange U FAo,J,na WOM L' riiuth Tustin _;( •' " '.� 1 It aY C "e• -. w" Santa Ana _.Tustin PROJECT SITE �" Wl'.w�i>9h.Mr i1"1 �i South c"it Irvine y,. I b r I 4 � 1 mile N Figure 2. Regional Map 11 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 2 .�G PR City PRVPERTY ouT$Ir}f -- ^p I�-�—•- {I Y oG Tustin r MCAS BOUNDARY,IN REUSE PLANT u u MUT ER FNL IS ATiGN SITE F {..17 R EVEAYN, PA 7 RC yl ROAD PA 4 PA 5 V$ NP LANI3tilYJWNE 1n y,i .. . w ..- E ROATa e _ PA 2 MDR CP c RC VALENCiAAVE PA tJ �. - 11 t,IQF F f T T AVT a PA 3 y PA 6 RC. IN"� URP RC TB � BELL AVEV. w;rc+Fww l NP ES WAS Tustm PRpec[ specific Plan I Ev ' AIL"..1 WARNtR AVF. CIlY Of f,1D, Santa Ana NP " . MAIiHIE htUllNt/SIF ROM PS-P PA 22 FfART+AtJCt. � _ PK%YY CITY .�. OF a IRVINE Figure 3. Project Site Boundaries 12 September 2019 Legacy Medical Plazc Addendum/Environmental Checklist Environmental Evaluation LEGEND V Figure 3.Aerial of Project Sits Project Site Boundary ' .x 140. V • i $A •�' ^ ' , tis n Figure A.Aerial of Project Site 13 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 2.2 Project Components 2.2.1 Project Entitlements The Project is subject to the following approvals by the City of Tustin: • Site Plan and Design Review (Site Plan Review for Land Use Category 2) • Issuance of a Grading Permit California Division of the State.Architect (DSA) approval may be needed for certain vehicle and pedestrian passage and access ways. The components of the Project are described in more detail below. Refer to Figure 4 for the location of these features. 2.2.2 Project Improvements and Use The Project entails the construction of one medical office building (Legacy Medical Plaza). The Legacy Medical Plaza consists of approximately 50,000 SF of gross floor area in a two-story structure. The Project would include site improvements such as parking areas, underground utility line connections, landscaping, and access driveways from Victory Road, Innovation Drive and Hope Drive (see Figure 4).A raised median will be constructed on Victory Road from Red Hill Avenue to the first driveway on Victory Road to prevent left turns into and out of the driveway on Victory Road.Innovation Drive will remain a full access intersection. The proposed medical office building is a two-story structure, 33 feet in height, with a gross floor area of 50,000 sq. ft.Table 3 shows the breakdown between of the proposed building by floor and suite. Table 3. Proposed Development Breakdown Floor Suite No. Suite Area SF Total(SF) 100 15, First 150 9,800 24,900 Second 200 15,360 25,100 250 9 40 TOTAL 1 50,000 Figure 4, 5, and 6 illustrate the Project's conceptual site plan, floor plans, elevations and a rendering, respectively. The Legacy Medical Plaza would be a tenant of the ATEP campus.The Project Sponsor,ACS Development Group, Inc. ("ACS") is required to support educational opportunities varying in categories of activity,which is outlined in the Ground Lease between SOCCCD and ACS. Categories of activity include educational support to landlord/programs, such as sponsorship of college events and scholarships; educational support to landlord students,such as hiring of students for internships,career fairs,and industry tours;and educational support to industry,such as providing workshops. C 14 September 2019 a 3 8 FIE I � '•1 Q I 7 '- r` o Q WICMf?y ROAD wn n D rF .p 7 � r..�...:rZ�" ..;f""""""`••`".,., moi � m m al L. i Q w s t N (D B n r� e� y a R !S y �t a T C CD 0` r) 3 n f0 c 4 a 0 $3 rn ten$ [ a N � Z3 Q 3 m m � na Q o_ � � o 1 A ■ 4 • • N N� tl ..64ti "7p1� I� i I �iiN ■ � i . i 1 � 1 0 -11 175 �,. .. t rn ?� wr n N is w FO n € — n C m N " ny �. Z c m ya.x xry•pn rr t 0 ra � D Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation The main entry of the First Building would face southwest, towards a round driveway and drop-off area, pedestrian walkway, and parking lot.A secondary access point would be located at the northeast entrance facing an outdoor patio area. The exterior would exhibit a contemporary design with a combination of concrete panels, cut stone facing, and blue grey aluminum framed windows. 2.2.3 Parking Area A 270-space parking area is planned to surround the proposed building,which is a ratio of 5.4 spaces per 1,000 SF. The parking lot would include three drop off areas, loading, and 258 standard stalls and 12 accessible stalls. Access to the parking area would be from three driveways: one that leads to Hope Drive, one leading to Victory Road,and one leading to Innovation Drive.Tenants and visitors to the Legacy Medical Plaza would only be permitted to park in this parking lot; parking by SOCCCD students would not be permitted. Enforcement would be overseen by the Legacy Medical Plaza operator. 'i The proposed number of parking spaces does not meet the minimum required spaces, which is 292. The Project Sponsor will be required to meet the Effective Standards. 7 2.2.4 Utilities u Utilities would be extended into the site from existing utility line stubs along Victory Road. Reclaimed water, a domestic water, and sanitary sewer would connect from Victory Road to the southeastern side of the I j proposed building. 1 2.2.5 Landscaping & Stormwater Management Landscaped areas would be installed in planting areas subject to the ATEP design guidelines. Landscaped areas are planned around the proposed building, within the parking area, and on the perimeter of the Project site. Landscaping could be used to accommodate stormwater treatment features, including, but not limited to bioswales. In addition,the Project would connect to existing storm drain on Victory Road per City of Tustin standards. 3. Environmental Evaluation and Explanation of Checklist Responses This checklist and the following evaluation of environmental impacts take into consideration the FEIS/EIR which s' fully analyzed the Project. 9 The Project does not involve any changes in development intensity or modification in development standards. i The checklist and initial study evaluate whether the conditions identified in Sections 15162 and 15168 of the CEQA Guidelines have occurred and require the preparation of a subsequent EIR,supplemental EIR,ND, or MND. 1 k The following information is presented for each of the topical issues presented in the Initial Study 1 environmental checklist: • Existing Conditions • Project Impact Evaluation o Potentially Significant Impact o Less than Significant with Mitigation o Less than Significant Impact o No New Impact—a check mark in the No New Impact box equates to No Substantial Change from Previous Analysis (FEIS/EIR) • Mitigation Measures • Sources 19 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.1 Aesthetics 3.1.1 Existing Conditions The Project site contains a parking lot,trees, and vacant disturbed land. The site is within the ATEP campus, which includes the two-story IDEA Building and associated improvements. Remnants of the former MCAS Tustin including asphalt-paved streets, parking lots, concrete sidewalks, building foundations, landscaping/groundcover, and underground utilities still exist. Structures part of the decommissioned MCAS Tustin (constructed between 1943 and 1988) located within the Project site have been demolished. There are no recognized scenic vistas or scenic highways in the vicinity of the Project site. 3.1.2 Project Impact Evaluation Except as provided in Public Resources Code Section 21099,would the project: a) Have a substantial adverse Potentially Less than Less than No New effect on a scenic vista? Significant Significant Significant ` Impact Impact With Impact Mitigation _ _ Incorporation ❑ ❑ ❑ E b) Substantially damage scenic Potentially Less than Less than = No New resources,including,but not limited to, Significant I Significant : Significant = Impact trees, rock outcroppings, and historic Impact With Impact buildings within a state scenic Mitigation highway? Incorporation ❑ ❑ ❑ C) In non-urbanized areas, �X Potentially Less than Less than No New substantially degrade the existing Significant Significant Significant ; Impact visual character or quality of the site Impact With Impact and its surroundings?(Public views are Mitigation those that are experienced from Incorporation 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 j Potentially Less than Less than 1 No New substantial light or glare,which would ` Significant = Significant 1 Significant Impact adversely affect day or nighttime Impact With t Impact i views in the area? Mitigation j Incorporation ❑ ❑ ❑ 20 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation Summary of FEIS/EIR: The FEIS/EIR identified aesthetics impacts of implementation of the Specific Plans. Visual impacts were considered significant if sensitive viewers(foreground residential viewers along Edinger Avenue and Harvard Avenue)would experience strong contrast or if there would be strong contrast to areas of high scenic quality. The Specific Plans development would alter the appearance of the project area as seen from the surrounding viewshed, and views from within the site. Development would create visual contrast between new development and existing scattered buildings,hardscape,and vacant land in various portions of the project area over the approximately 20-year development duration. However, the FEIS/EIR determined that the only significant visual impact identified in the FEIS/EIR was the potential loss of both blimp hangars(Hangers 28 and 29),which would change existing foreground,middle-ground,and background views. The 2016 Addendum concluded that the proposed IDEA Building would not cause aesthetic impacts that were not previously analyzed in the FEIS/EIR. The IDEA Building was determined to be a similar use as those proposed in the Tustin Legacy Specific Plan and previously analyzed in the FEIS/EIR. �y Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: f The proposed Project would construct a new two-story 50,000 square-foot medical office building at the northeast corner of Victory Road and Red Hill Avenue. The proposed building would be surrounded by 9 landscaping in planting areas subject to ATEP design guidelines, have a maximum height of 33 feet, and i would exhibit a contemporary design with a combination of concrete panels,cut stone facing,and blue grey aluminum framed windows.The size and scale of the Project is consistent with the Tustin Legacy Specific Plan development standards and would be similar to the IDEA Building and that of other buildings in Tustin Legacy. i Response to a-d: { No Impact Due to No Substantial Change from Previous Analysis.The Project would not cause aesthetic impacts that were not previously analyzed in the FEIS/EIR. The Project proposes to develop structures and uses that s are similar to those proposed in the Tustin Legacy Specific Plan and previously analyzed in the FEIS/EIR.The Project's square footage, height, setbacks, and other development standards are consistent with those in prior analyses. The FEIS/EIR anticipated that former MCAS buildings located on the Project site would be demolished and replaced with new construction.Visual changes to the Project vicinity have already occurred with the development of Orange County Rescue Mission, ATEP Phase I, the Rancho Santiago Community College Orange County Sheriff's Training Academy,the Orange County Animal Care Center,the U.S.Armed Forces Reserve Center,the County's Abused Children's Shelter,residential neighborhoods north and south of Valencia Avenue,the Tustin Unified School District's Heritage Elementary School,as well as the demolition of buildings on the ATEP site and the construction of the IDEA at ATEP building. There are no new or increased significant adverse project-specific or cumulative impacts with regard to r aesthetics and visual quality that would occur as a result of the implementation of the Project. There is no I new information relative to aesthetics and visual quality that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR. No new mitigation measures are required in relation to impacts to aesthetics and visual quality. The visual impacts of planned construction in the Tustin Legacy Specific Plan's Neighborhood A were analyzed in the FEIS/EIR,and there would be no new or substantially different aesthetic impacts as a result of the Project. Future construction on the properties would comply with the site development standards in the Tustin Legacy Specific Plan. Therefore, the overall intensity of the proposed development and the general character of the Project site would not be substantially altered by the Project. Construction of the Project would continue the visual change from the abandoned military facilities onsite to a master-planned, multistory development. This visual change, as part of the overall visual change of the former base to the larger Tustin Legacy development was not a significant impact in the FEIS/EIR. There are 21 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation no designated scenic vistas in the Project area;therefore,the Project would not result in a substantial adverse effect on a scenic vista. The Project site is also not located within the vicinity of a designated state scenic highway. The Project would not change the conclusions of the historical analysis of the historic blimp hangars from the FEIS/EIR relative to visual changes since the Project would not affect these hangars. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to aesthetics. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects;or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR were certified as complete. Mitigation Nonitoring Required: No new impacts or substantially more severe aesthetic impacts would result from the approval and implementation of the Project;therefore,no new or revised mitigation measures are required for aesthetics and visual quality. In addition,there are no applicable mitigation measures contained in the City's 2018 City of Tustin Annual MMRP Report(2018 MMRP)for the FEIS/EIR with regard to aesthetics and visual quality. No refinements related to the Project are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. Mitigation/Monitoring Measures Not Being Implemented: Mitigation Measure Vis-1, regarding urban design plan adoption in conjunction with any zoning ordinance amendments, is the responsibility of other areas of the Tustin Legacy Specific Plan to implement, and therefore is not within the Project's responsibility to implement. 22 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.2 Agriculture and Forest Resources t 3.2.1 Existing Conditions There were no agricultural uses on the Site in the recent past.There are currently no agricultural uses on the Site. 3.2.2 Project Impact Evaluation In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California 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, ; Potentially j Less than s.'' Less than No New Unique Farmland, or Farmland of i Significant I Significant Significant Impact Statewide Importance (Farmland), as I Impact I With ( Impact shown on the maps prepared pursuant Mitigation to the Farmland Mapping and ( Incorporation Monitoring Program of the California Resources Agency,to non-agricultural use? j g ❑ ❑ ❑ b) Conflict with existing zoning Potentially Less than Less than No New for agricultural use, or a Williamson ` Significant Significant Significant ; Impact Act contract? Impact With Impact Mitigation Incorporation ❑ ❑ ❑ i C) Conflict with existing zoning ; Potentially Less than s Less than No New for, forest land (as defined in Public a Significant Significant Significant Impact Resources Code section 12220(g)), Impact With Impact timberland (as defined by Public Mitigation Resources Code section 4526), or ° Incorporation timberland zoned Timberland Production (as defined by Government Code section 51104(g))? ❑ ❑ ❑ d) Result in the loss of forest land Potentially I Less than Less than No New or conversion of forest land to non- Significant ` Significant Significant : Impact forest use? = Impact With Impact Mitigation = = Incorporation 23 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation e) Involve other changes in the B Potentially Less than Less than No New existing environment, which, due to Significant Significant Significant Impact their location or nature,could result in Impact With ! Impact conversion of Farmland, to non- ! Mitigation i agricultural use or conversion of forest Incorporation land to non-forest use2 i ❑ i ❑ ❑ Summary of Impacts from the FEIS f EIR: The FEIS/EIR identified 702 acres of Important Farmland onsite: 682 acres of Prime Farmland and 20 acres of Farmland of Statewide Importance. In 1999, 530 acres were leased for cultivation with row crops and citrus.Conversion of farmland to nonagricultural uses was identified as a significant and unavoidable impact in the FEIS/EIR. No substantial change to the previous analysis was identified in the 2004 Supplemental EIR, 2006 Addendum, 2013 Addendum or 2016 Addendum. Since certification of the FEIS/EIR, all agricultural activities have ceased. The current California Department of Conservation's Farmland Mapping and Monitoring (FMMP),published August 2011,has been updated to reflect the absence of agricultural activities. The Tustin Legacy Specific Plan area is mapped as"Urban and Built-Up Land" and "Other Land." Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Response to a-e: No Impact Due to No Substantial Change from Previous Analysis. The Project would not cause impacts to agriculture and forest resources that were not previously analyzed in the FEIS/EIR. There continue to be no agricultural resources on the property.There are no new or increased significant adverse project-specific or cumulative impacts with regard to agricultural resources that are identified as a result of the approval and implementation of the Project.The impacts of the development of the properties has already been analyzed in the FEIS/EIR.There is no new information relative to agricultural resources that was not in existence at the time the FEIS/EIR was prepared. Therefore, no new mitigation measures are required in relation to impacts to agricultural resources. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to agricultural resources. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects;or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation Monitoring Required: In certifying the FEIS/EIR, the Tustin City Council adopted Findings of Fact and Statement of Overriding Considerations on January 16, 2001 concluding that impacts to agricultural resources on other areas of MCAS Tustin were unavoidable(Resolution No.00-90).No mitigation is required. MitigationJMonitoring Not Being Implemented: No new impacts or substantially more severe impacts will result from the District's and City's approval and implementation of the Project;therefore,no new or revised mitigation measures are required for agricultural resources. In addition,there are no applicable mitigation measures contained in the City's approved MMRP for the FEIS/EIR with regard to agricultural resources. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. l' 24 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.3 Air Quality 3.3.1 Existing Conditions The Site is presently not in use. Former military buildings on the ATEP campus have been demolished. Tustin Legacy has been building out pursuant to the Specific Plan.The ATEP site has also experienced development, including the construction of the IDEA Building. 3.3.2 Project Impact Evaluation Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct Potentially Less than Less than ' No New implementation of the applicable air Significant I Significant i Significant Impact q quality plan? I Impact With I Impact y Mitigation i Incorporation ' E ❑ ❑ b) Result in a cumulatively Potentially j Less than Less than No New considerable net increase of any Significant Significant Significant Impact criteria pollutant for which the project Impact I With ; Impact I region is non-attainment under an i Mitigation applicable federal or state ambient = Incorporation j air quality standard? ❑ ❑ i ❑ E C) Expose sensitive receptors to Potentially Less than Less than No New substantial pollutant concentrations? Significant Significant Significant Impact Impact With Impact Mitigation j Incorporation ❑ ❑ ❑ 3 d) Result in other emissions (such ' Potentially Less than Less than I No New as those leading to odors) adversely Significant I Significant Significant j Impact affecting a substantial number of I Impact i With Impact people? I Mitigation I Incorporation I ❑ ❑ ❑ Summary of Impacts from the FEIS/EIR: The 2001 FEIS/EIR addressed consistency of the MCAS Specific Plan with the South Coast Air Quality Management District (SCAQMD) Air Quality Management Plans (AQMPs), construction-related emissions, operational emissions, localized carbon monoxide (CO) "hotspots," and air toxics. The FEIS/EIR concluded that the Specific Plans would not be consistent with the 1994 and 1997 AQMPs because these plans did not 25 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation consider the planned intensity assumed by the Specific Plans. This impact was significant and unavoidable, and a statement of overriding considerations was adopted. The 2001 FEIS/EIR concluded that there were significant and unavoidable construction-related (short-term) emissions that exceeded the SCAQMD thresholds. Even with incorporation of mitigation measures, impacts were determined to remain significant and a statement of overriding considerations was adopted. Operational emissions were also considered significant and unavoidable even with implementation of the City's Traffic Reduction/Traffic Demand Management program (Ordinance No. 1062, approved in 1991), which has policies to reduce long-term emissions.A statement of overriding considerations was adopted for this impact. However, the FEIS/EIR concluded that operational emissions from businesses would comply with SCAQMD's regulations for operation and would be less than significant. The 2001 FEIS/EIR concluded that no sensitive receptors would be exposed to CO hotspots. The analysis included intersections with the highest traffic volumes and LOS during years 2005 and 2020. The 2013 Addendum analyzed future implementation of the ATEP campus and updated the air quality analysis to identify construction and operational related impacts resulting from the construction of between 194,109 and 816,929 SF of academic office space beyond the previously analyzed amounts, and an increase in the trip cap. In addition,the 2013 Addendum analyzed the extension of Victory Road. Based on this analysis it was determined that SCAQMD thresholds would not be exceeded and no new significant impacts would occur. Operational emissions resulting from an increased trip cap of 10,000 ADT would be below SCAQMD daily emissions thresholds for operations,and there would not be a significant operational- period air quality impact from the Project. Similarly, the 2016 Addendum analyzed the construction and operation of the IDEA Building and determined that there would be no potential for new or increased significant adverse project-specific or cumulative air quality impacts. The 2017 SEIR analyzed the potential air quality impacts generated as a result of land use changes within \ the Specific Plan area. The SEIR determined the types of land uses proposed would be similar to the types of land uses under the approved plan and the net change in emissions would not exceed SCAQMD regional significance thresholds for operation-related emissions. The amendments discussed in the 2017 SEIR represented an increase in air pollutant emissions; however, the net change in emissions would not exceed SCAQMD thresholds for construction emissions. No new impacts were determined in the 2017 SEIR related to air quality. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Response to a-d: No Impact Due to No Substantial Change from Previous Analysis. The Project would not cause impacts to air quality that were not previously analyzed in the FEIS/EIR,including the addendum for the DA.The Tustin City Council adopted Findings and a Statement of Overriding Considerations for the FEIS/EIR on January 16, 2001 to address significant unavoidable short-term (construction), long-term (operational), and cumulative air quality impacts for the MCAS Tustin Specific Plan. The City also adopted mitigation measures (AQ-1, AQ-2,AQ-3, and AQ-4)to reduce these unavoidable adverse impacts. The Project site is located in the South Coast Air Basin, which is under the jurisdictional boundaries of the SCAQMD. The SCAQMD and Southern California Association of Governments (SLAG) are responsible for preparing the AQMP, which addresses federal and state Clean Air Act (CAA) requirements. The AQMP details goals, policies, and programs for improving air quality in the Basin and achieving the U.S. National Ambient Air Quality Standards (NAAQS). In preparation of the AQMP, SCAQMD and SCAG use land use designations contained in City's General Plan (including to the MCAS Tustin Specific Plan) to forecast, inventory,and allocate regional emissions from land use and development-related sources.The 2016 AQMP 26 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation incorporates scientific and technological information and planning assumptions, including the 2016 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) as well as a new rule for redevelopment projects. For purposes of analyzing consistency with the AQMP, if a proposed project would have a development density and vehicle trip generation that is substantially greater than what was anticipated in the General Plan, then the proposed project would conflict with the AQMP. On the other hand, if a project's density is consistent with the General Plan,its emissions would be consistent with the assumptions in the AQMP, and the project would not conflict with SCAQMD's attainment plans. In addition, the SCAQMD considers projects consistent with the AQMP if the project would not result in an increase in the frequency or severity of existing air quality violations or cause a new violation. The Project would construct a new medical building, which is consistent with the planned used on the ATEP site. Similarly,the Project would result in the allotted average daily trips generated by the Project. Therefore, the Project would not result in a substantial change from previous air quality impact analysis. Furthermore, vehicle trips as a result of the Project would be less than previously analyzed because vehicle emissions have reduced due to recently improved fuel efficiency and emissions standards with automobiles. Consistent with the findings in the FEIS/EIR,implementation of proposed development on the Project site could result in significant unavoidable short-term construction air quality impacts because it is a part of the"project" analyzed in the FEIS/EIR for which this finding was made. Construction activities associated with the Project site were previously addressed in the FEIS/EIR. The proposed 50,000 SF of built space are within the scope of the previously analyzed total SF of office space in the 2013 District/City Land Exchange Addendum. There would be no potential for new or increased significant adverse project-specific or cumulative impacts with regard to air quality that would occur as a result of the approval and implementation of the Project that was not previously analyzed in the FEIS/EIR. There is no substantial new information that shows there will be different or more significant long-term and/or cumulative impacts on the environment as a result of the Project than described in the FEIS/EIR. Therefore,the Project and its implementation are consistent with and previously analyzed in the FEIS/EIR and no new mitigation measures are required in relation to impacts to air quality. Buildout of the MCAS Tustin site, including the ATEP area, was found in the FEIS/EIR to result in significant unavoidable air quality impacts. Consistent with these findings, development on the Project site could also result in significant unavoidable long-term and cumulative air quality impacts because it is part of the "project" analyzed in the FEIS/EIR for which this finding was made. Mitigation measures included in the FEIS/EIR will be implemented as appropriate by the Project Sponsor. The Project Sponsor will implement Mitigation Measures AQ-1 through AQ-3. The implementation of Mitigation Measure AQ-4 is the responsibility of the City and/or the City of Irvine and is not within the responsibility of the SOCCCD. The proposed Project would include land uses that have the potential to generate toxic air contaminants (TACs). Land uses that have the potential to be substantial stationary sources would require a permit from SCAQMD for TAC emissions. Examples include industrial land uses, such as chemical processing facilities, chrome-plating facilities,dry cleaners, and gasoline-dispensing facilities. Emissions of TACs from these types of land uses would be controlled by SCAQMD through permitting and would be subject to further study and health risk assessment prior to the issuance of any necessary air quality permits under SCAQMD Rule 1401. Based on this rule, the 2017 Supplemental EIR determined that impacts related to air toxics would be less than significant.The permitting process ensures that stationary source emissions would be below the SCAQMD significance thresholds of 10 in one million cancer risk and 1 for acute risk at the maximally exposed individual. Similarly, the proposed Project would implement SCAQMD Rule 1401 and General Regulation Rule 3.18.4(c), which addresses fumes, odors, and other forms for air pollutions. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to air quality. Specifically, there have not been: (1) 27 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation ZMonitoring Required: Specific air quality mitigation measures have been adopted by the Tustin City Council in certifying the FEIS/EIR for both operational and construction-related activities for development at Tustin Legacy. The mitigation measures for air quality impacts that are applicable to the Project during the implementation stages (i.e., construction) include Mitigation Measures AQ-1 and AQ-2. The Project Sponsor would implement Mitigation Measure AQ-1 by complying with South Coast Air Quality Management District Rules to reduce short-term air pollutant emissions. Mitigation Measure AQ-2 would be implemented by requiring the use of low volatile organic compound (VOC) architectural coatings for all interior and exterior painting operations. Mitigation Measure AQ-3, which relates to Transportation Demand Management Plan (TDM),will be implemented for new non-residential projects with 100 or more employees and expanded projects where additional square footage would result in a total of 100 or more employees. As stated above,the FEIS/EIR also concludes that Tustin Legacy Specific Plan-related operational air quality impacts are significant and cannot be fully mitigated.A Statement of Overriding Considerations for the FEIS/EIR was adopted by the Tustin City Council on January 16, 2001 to address significant unavoidable short-term, long-term, and cumulative air quality impacts associated with all development of the Tustin Legacy Specific Plan. No new mitigation measures are required. The Project will implement the relevant mitigation measures of the 2018 MMRP that are applicable to the Project. Mitigation IMonitoring Not Being Implemented: All relevant mitigation measures will be implemented by SOCCCD and the City (AQ-1 through AQ-3) or the City independently (AQ-4). 28 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.4 Biological Resources 3.4.1 Existing Conditions Many parts of the Tustin Legacy Specific Plan area are developed or currently under construction. Vacant land on site has largely been graded and contains no native vegetation. Additionally, the Tustin Legacy Specific Plan area currently has public and private neighborhood parks in residential neighborhoods between both Tustin and Irvine. The Project site is vacant disturbed land with an asphalt-paved parking lot, overgrown vegetation, and multiple trees. The site is within an urbanized area and not adjacent to any waterways. 3.4.2 Project Impact Evaluation Would the project: a) Have a substantial adverse Potentially Less than Less than ` No New effect, either directly or through ` Significant I Significant Significant : Impact habitat modifications, on any species Impact ; With : Impact identified as a candidate,sensitive,or Mitigation special status species in local or Incorporation regional plans, policies, or ? _ regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? ❑ _ ❑ I ❑ _ E b) Have a substantial adverse Potentially Less than Less than No New effect on any riparian habitat or Significant I Significant Significant Impact other sensitive natural community Impact f With Impact identified in local or regional plans, i Mitigation I policies, regulations, or by the s Incorporation California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? ❑ ❑ ❑ E C) Have a substantial adverse t Potentially Less than Less than No New effect on state or federally protected Significant Significant Significant Impact wetlands (including, but not limited to, ? Impact I With Impact marsh, vernal pool, coastal, etc.) I I Mitigation through direct removal, filling, I Incorporation hydrological interruption, or other $ s means? ❑ ❑ ❑ , C 29 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation d) Interfere substantially with 1 Potentially Less than 1 Less than I No New the movement of any native resident ; Significant Significant Significant Impact or migratory fish or wildlife species or { Impact j With j Impact with established native resident or Mitigation i migratory wildlife corridors, or ! Incorporation impede the use of native wildlife nursery Sites? ! ❑ ❑ ❑ e) Conflict with any local Potentially Less than f Less than No New policies or ordinances protecting Significant Significant Significant Impact biological resources, such as a tree Impact With Impact preservation policy or ordinance? Mitigation t i Incorporation ❑ ❑ I ❑ f) Conflict with the provisions of Potentially Less than Less than No New an adopted Habitat Conservation Significant Significant Significant I Impact Plan, Natural Community ' Impact i With ' Impact Conservation Plan,or other approved I Mitigation I i local, regional, or state habitat Incorporation s conservation plan? ❑ ❑ ❑ Summary of Impacts from the FEISIEIR: Vegetation onsite was identified as cultivated fields and nonnative grassland in the FEIS/EIR.Only individual j- remnants of native plant species, but no intact native habitat, were identified.The FEIS/EIR determined that (\ implementation of the MCAS Tustin Specific Plan would result in impacts to jurisdictional waters and wetlands and to southwestern pond turtle. The FEIS/EIR did not find burrowing owls or suitable habitat for burrowing owl onsite. Mitigation measures were required in the FEIS/EIR and revised in the 2006 Addendum; the aforementioned impacts are less than significant after implementation of mitigation.Note that a capture and relocation plan was approved by California Department of Fish and Wildlife (CDFW) for the southwestern pond turtle, and all turtles have been relocated. The FEIS/EIR identified several potential jurisdictional waters onsite, including but not limited to ditches and drainages,the Santa Ana/Santa Fe Channel,the Barranca Channel,and Peters Canyon Channel.It identified impacts to 16.2 acres of jurisdictional waters, 2.4 acres of which were vegetated wetlands, The 2006 Addendum, which covered 1,511 acres of the project area in the City of Tustin, identified 0.68 acre of federally protected wetlands in that area. Mitigation measures for impacts to jurisdictional waters and wetlands were included in the FEIS/EIR and revised in the 2006 Addendum. The FEIS/EIR determined that there would be no impacts to federally listed threatened or endangered plant or animal species. It found that there would be a direct impact to four loggerhead shrike, but that it would not have an overall adverse effect to the population in southern California. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-f: No Impact Due to No Substantial Change from Previous Analysis. The Project would not cause impacts to biological resources that were not previously analyzed in the FEIS/EIR. The FEIS/EIR analyzed the future development of the whole of Neighborhood A and the associated biological impacts. No new areas will be developed under the Project.There are no new or increased significant adverse project-specific or cumulative 30 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation impacts with regard to biological resources that would occur as a result of the adoption and implementation of the Project. In 2010, the U.S. Army Corps of Engineers (ACOE), Regional Water Quality Control Board (RWQCB), and California Department of Fish and Game (now the California Department of Fish and Wildlife, CDFW) determined that the ATEP Site does not contain land that is subject to their jurisdiction or that warrants their oversight. There is no other new information relative to biological resources that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR and no new mitigation measures are required in relation to impacts on biological resources. Based on current delineations of wetlands and jurisdictional waters, the Project will not affect wetlands or jurisdictional waters. The impacts resulting from the implementation of the Project, if any, would be those identified in the FEIS/EIR. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to biological resources.Specifically,there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects;or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. I p V Mitigation/Monitoring Required: The mitigation measures applicable during implementation of the Project have been identified in the City's 2018 MMRP. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required for implementation (i.e.,construction) of the Project. The Project will implement the relevant mitigation measures of the adopted MMRP and as stated in the 2018 MMRP. Mitigation/Monitoring Not Being Implemented: The Project Sponsor would not need to implement Mitigation { Bio-1 because the Project would not affect jurisdictional waters of the U.S. or vegetated wetlands. With regard to Mitigation Bio-2, Bio-3, and Bio-4, which deal with capture and relocation of pond turtles and restoration of pond turtle habitat,these measures do not apply to the Project because no ponds exist on the 9 Project site. If the Site continues to reveal no presence of southwestern pond turtles,Mitigation Measures Bio- 1, Bio-2, Bio-3, and Bio-4 would not be implemented as part of the Project. I i 31 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.5 Cultural Resources " 3.5.1 Existing Conditions The Project site is vacant and disturbed land with a paved asphalt parking lot,multiple trees,and overgrown vegetation. Numerous archaeological surveys have been conducted at the former MCAS Tustin Site. There are no cultural resources identified on the Project site in the FEIS/EIR. 3.5.2 Project Impact Evaluation Would the project: a) Cause a substantial adverse y Potentially { Less than Less than No New change in the significance of a 1 Significant Significant = Significant Impact historical resource pursuant to E Impact With Impact §15064.5? ; Mitigation i Incorporation ❑ ❑ ❑ b) Cause a substantial adverse Potentially Less than Less than No New change in the significance of an Significant Significant Significant ' Impact archaeological resource pursuant to Impact With Impact §15064.5? Mitigation Incorporation ❑ ❑ ❑ C) Disturb any human remains, Potentially Less than Less than No New including those interred outside of Significant Significant Significant Impact formal cemeteries? Impact With Impact Mitigation Incorporation ❑ ❑ Z Summary of Impacts from the FEIS f EIR: The 2001 FEIS/EIR identified the following resources: Hangar 28(northern hangar)and Hangar 29(southern hangar) are both listed on the National Register of Historic Places. The two hangars, along with other resources onsite,were determined to be eligible for listing as a discontiguous National Historic District.Other resources include Buildings 28A and 29A,mooring mats 1 through 5,and the roads connecting these structures to Hangars 28 and 29. When previous environmental documents were prepared, it was unknown whether implementation of the Tustin Legacy Specific Plan would involve demolition of both, one, or neither of the hangars. It was determined that the loss of both hangars would be a significant and unavoidable impact.. Mitigation measures were required for impacts to the two hangars and the above-described related historical resources. Impacts were identified as significant and unavoidable after implementation of mitigation. In accordance with Section 106 of the National Historic Preservation Act,the City of Tustin,the State Historic Preservation Office (SHPO),the Advisory Council on Historic Preservation,the Department of the Navy,and the County of Orange executed a Memorandum of Agreement that identified measures to mitigate the impacts of the destruction of portions of the eligible historic district,including the removal of Hangar 28 and Hangar 29 (RBF 2008). Pursuant to the agreement,the County of Orange conducted a marketing study of Hangar 28 and the City of Tustin conducted a marketing study of Hangar 29. Both jurisdictions reached the conclusion that there is no economically viable use for the hangars, requiring implementation of mitigation 32 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation measures from Stipulation III of the agreement. The required mitigation measures included a written history, documentary video, and exhibit. All mitigation measures identified in Stipulation III of the agreement have been satisfied. One archaeological site was known to be located within the MCAS Tustin Specific Plan area; this site was destroyed by construction of two tanks before 1971. The site was described as containing shells, and an arrowshaft straightener, mortar, and metate were reportedly discovered at the site. Impacts to archaeological resources were identified as less than significant after mitigation in the FEIS/EIR. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: The proposed Project would construct a new 50,000 square-foot medical office building with parking lot and landscaping onsite.The Project site would be graded during construction.There are no existing structures onsite to be demolished. Excavation would be conducted during construction for utilities to connect underground from Victory Road. Responses to a-c: No Impact Due to No Substantial Change from Previous Analysis. The Project would not cause impacts to cultural resources that were not previously analyzed in the FEIS/EIR. The Project proposes to develop the same areas as proposed in the Tustin Legacy Specific Plan and previously analyzed in the FEIS/EIR. The Project would not cause impacts to cultural resources. The impacts of the Tustin Legacy Specific Plan on cultural resources, including any that may be present on the Project site, were considered in the FEIS/EIR. It is possible that previously unidentified buried archeological resources within the Project site could be discovered during grading and other construction activities. With the inclusion of Mitigation Measures Arch- 2, which requires construction monitoring for cultural resources, potential impacts to these resources can be reduced to a level of insignificance as found in the FEIS/EIR. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to cultural and paleontological resources. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures j or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. i Mitigation/Monitoring Required: The Project Sponsor would implement Mitigation Measure Arch-2 by retaining a County-certified archaeologist and conducting the required consultations prior to obtaining grading permits. I Mitigation/Monitoring Not Being Implemented: Other mitigation measures for cultural resources in the FEIS/EIR and City's 2018 MMRP are not applicable to the Project site and are the responsibility of others to implement. r I 33 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.6 Energy 3.6.1 Existing Conditions The Project site is a vacant site with an asphalt-paved parking lot,multiple trees,and overgrown vegetation. There are no existing uses on the site that generate the need for energy resources. 3.6.2 Project Impact Evaluation Would the project: a) Result in potentially j Potentially € Less than Less than ! No New significant environmental impact due Significant Significant Significant 1 Impact to wasteful,inefficient,or unnecessary Impact With Impact consumption of energy resources, I Mitigation i f during project construction or j Incorporation operation? ❑ f ❑ I b) Conflict with or obstruct a Potentially Less than _ Less than No New state or local plan for renewable I Significant Significant = Significant : Impact energy or energy efficiency? I Impact With _ Impact Mitigation Incorporation s El ! ❑ 1 ❑ s Summary of Impacts from the FEISJEIR: Energy was not previously analyzed as a separate individual topic. This does not mean the Energy was not analyzed. Rather, impacts related to energy were addressed within greenhouse gas and utilities impact analyses. Since the State CEQA Guidelines has been revised by the Office of Planning and Research to include separate criteria and thresholds, this Addendum includes energy as a separate topic. The environmental setting for the 2017 SEIR established that there is an increased energy demand is a result of increases in average temperature and higher frequency of extreme heat events combined with new residential development across the state driving up the demand for cooling. Energy demand is reduced with the adoption of applicable energy efficiency programs, building and appliance standards, and use of renewable sources.The 2001 FEIS/EIR generally concluded that the implementation and future development of the MCAS Tustin Specific Plan would increase energy consumption, analyzed under sections covering air quality, but that implementation of the State's energy conservation standards would reduce the impact. Development at the ATEP site at the level permitted by the DA was included in the 2001 FEIS/EIR. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-b: No Impact Due to No Substantial Change from Previous Analysis. The Project would construct a new 50,000 gross square foot medical office building on an existing vacant site. The construction and operation of the Project would generate demand for electricity, natural gas, as well as gasoline for motor vehicle trips. Operational use of energy includes the heating, cooling, and lighting of building areas, water heating, operation of electrical systems,parking lot and outdoor lighting,and the transport of electricity,natural gas, and water to the areas where they would be consumed.This use of energy is typical for urban development, and no operational activities or land uses occur that would result in extraordinary energy consumption. C 34 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation The proposed Project would be required to meet the current Title 24 energy efficiency standards,which are updated on 3-year cycles. Typical Title 24 measures include insulation; use of energy-efficient heating, ventilation, and air conditioning equipment (HVAC); solar-reflective roofing materials; energy-efficient indoor and outdoor lighting systems; reclamation of heat rejection from refrigeration equipment to generate hot water; and incorporation of skylights,etc. There is no other new information relative to energy that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are 3 consistent with the FEIS/EIR and no new mitigation measures are required in relation to impacts on energy. The impacts resulting from the implementation of the Project,if any,would be those identified in the FEIS/EIR. u Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to geology and soils. Specifically,there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: No new impacts or substantially more severe impacts will result from the adoption and implementation of the Project; therefore,no new or revised mitigation measures are required ? for energy. In addition,there are no mitigation measures contained in the City's 2018 MMRP with regard to J geology and soils. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. i Mitigation/Monitoring Not Being_Implemented: There are no new or revised mitigation measures for energy. In addition,there are no mitigation measures contained in the City's 2018 MMRP with regard to energy. 1 i 1 1 35 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.7 Geology and Soils 3.7.1 Existing Conditions There are no known geotechnical conditions that would preclude implementation of the Project. Geotechnical conditions on the Project site are similar to geotechnical conditions throughout Tustin Legacy. 3.7.2 Project Impact Evaluation Would the project: a) Directly or indirectly cause j Potentially Less than Less than I No New potential substantial adverse effects, Significant Significant ! Significant 11 Impact including the risk of loss, injury, or j Impact With Impact I death involving: i Mitigation j i Incorporation I 1 i) Rupture of a known ❑ ❑ ❑ earthquake fault, as delineated on j the most recent Alquist-Priolo = d 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 j Mines and Geology Special i Publication 42. a) Directly or indirectly cause Potentially Less than Less than No New potential substantial adverse effects, Significant Significant Significant Impact including the risk of loss, injury, or Impact With Impact death involving: Mitigation Incorporation ii) Strong seismic ground El3 El ' ❑ i shaking? s s a) Directly or indirectly cause j Potentially I Less than 1 Less than No New potential substantial adverse effects, 4 Significant I Significant Significant Impact including the risk of loss, injury, or # Impact x With Impact death involving: j '; Mitigation ( I Incorporation I iii) Seismic-related ground failure, ❑ ❑ ; ❑ ❑ including liquefaction? a) Directly or indirectly cause I Potentially ` Less than f Less than No New potential substantial adverse effects, Significant Significant Significant j Impact including the risk of loss, injury, or Impact I With Impact a death involving: I Mitigation Incorporation s iv) Landslides? 1 ❑ 111 ❑ C 36 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation b) Result in substantial soil Potentially I Less than Less than No New erosion or the loss of topsoil? Significant Significant Significant I Impact Impact With Impact t Mitigation { 1 Incorporation ❑ ❑ 11:1 C) Be located on a geologic unit Potentially s Less than ' Less than No New or soil that is unstable, or that would t Significant Significant Significant I Impact become unstable as a result of the Impact With Impact project, and potentially result in on- s Mitigation site or off-site landslide, lateral Incorporation spreading,subsidence,liquefaction or collapse? ❑ ❑ ❑ d) Be located on expansive soil, Potentially Less than Less than = No New as defined in Table 18-1-B of the ' Significant Significant I Significant ' Impact Uniform Building Code (1994), Impact ' With ; Impact creating substantial direct or indirect Mitigation risks to life or property? Incorporation e) Have soils incapable of Potentially j Less than Less than ) No New adequately supporting the use of = Significant = Significant = Significant = Impact 1 septic tanks or alternative waste ? Impact With Impact water disposal systems where sewers j Mitigation are not available for the disposal of : Incorporation waste water? ❑ ❑ I ❑ 'S a i f) Directly or indirectly destroy 11 Potentially ; Less than Less than No New a unique paleontological resource or i Significant Significant Significant Impact site or unique geologic feature? Impact With I Impact F Mitigation °s j Incorporation ❑ ❑ ❑ 10 Summary of Impacts from the FEISJEIR: Impacts related to collapsible soils, regional subsidence, expansive soils, slope instability, and erosion were identified in the FEIS/EIR as less than significant after compliance with state and local regulations and standards, and established engineering procedures and techniques. No impacts related to landslides or mudflows were identified. No active faults were identified on or next to the site. The FEIS/EIR identified 10 active faults ranging from 10 miles to 48 miles from the project area and estimated to be capable of generating earthquakes ranging from magnitude 6.5 to 7.8. Impacts related to surface rupture of a fault, strong ground shaking, ground failure including liquefaction, tsunamis and seiches, and flooding due to dam failure after an earthquake were all identified as less than significant. Site soils were identified as highly to very highly expansive in the FEIS/EIR. Measures identified in the FEIS/EIR for reducing hazards from expansive soils include removal of clay-rich soils and replacement with 37 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation a specified thickness of nonexpansive granular soil beneath structures, concrete slabs, and footings; improving the expansive soil with presaturation of expansive materials; supplemental reinforcement of the building foundations and slabs; and installing post-construction drainage control to minimize the collection of water under or adjacent to structures. Impacts were identified as less than significant in the FEIS/EIR after compliance with state and local regulations. Soils underlying the site were identified as having moderate to high sensitivity for paleontological resources in the FEIS/EIR. However, impacts to paleontological resources were identified as less than significant after mitigation in the FEIS/EIR. SummarX of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-f: No Impact Due to No Substantial Change from Previous Analysis. Implementation of the Project would not cause any direct impacts to geology and soils.The Project proposes to develop the same areas as proposed in the Tustin Legacy Specific Plan and previously analyzed in the FEIS/EIR. There are no new or increased significant adverse project-specific or cumulative impacts with regard to geology and soils that are identified as a result of the adoption and implementation of the Project.There is no new information relative to geology and soils that was not in existence at the time the FEIS/EIR as prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR and no new mitigation measures are required in relation to impacts to geology and soils. The FEIS/EIR found that impacts to soils and geology resulting from implementation of the Tustin Legacy Specific Plan would include non-seismic hazards(such as local settlement, regional subsidence, expansive soils, slope instability,erosion, and mudflows) and seismic hazards (such as surface fault displacement,high- intensity ground shaking,ground failure and lurching,seismically-induced settlement,and flooding associated with dam failure). As identified in the FEIS/EIR,it is possible that previously unidentified buried paleontological resources within the Project could be discovered during grading and other construction activities. With the inclusion of Mitigation Measures Paleo-1 and Paleo-2, which require construction monitoring for paleontological resources, potential impacts to these resources can be reduced to a level of insignificance as found in the FEIS/EIR. The FEIS/EIR concluded that compliance with state and local regulations and standards, along with established engineering procedures and techniques, would avoid unacceptable risk or the creation of significant impacts related to geotechnical issues. No substantial change is expected during implementation of the Project from the analysis previously completed in the certified FEIS/EIR. Based on the foregoing,none of the conditions identified in CEGA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to geology and soils. Specifically,there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or(3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: No new impacts or substantially more severe impacts will result from the adoption and implementation of the Project;therefore,no new or revised mitigation measures are required 38 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation for geology and soils. SOCCCD and the City would require the Project Sponsor to implement Mitigation Measures Paleo-1 and Paleo-2 by retaining a County-certified paleontologist and complying with the requirements of the established Paleontology Resources Management Plan (PRMP) for Tustin Legacy. In addition,there are no mitigation measures contained in the City's 2018 MMRP with regard to geology and soils. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. I Mitigation/Monitoring Not Being Implemented:There are no new or revised mitigation measures for geology and soils. In addition, there are no mitigation measures contained in the City's 2018 MMRP with regard to geology and soils. r n k, C u s I y I 1 / a s 4 e 2 QQv S s i V I I l 39 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.8 Greenhouse Gas Emissions 3.8.1 Existing Conditions Emitting greenhouse gases (GHGs) into the atmosphere is not itself an adverse environmental effect. Rather, it is the increased accumulation of GHGs in the atmosphere that result in global climate change. The consequences of that climate change can cause adverse environmental effects. Due to the complex physical, chemical, and atmospheric mechanisms involved in global climate change, it is not possible to predict the specific impact, if any,to global climate change from one project's relatively small incremental increase in emissions. One project's contribution is not likely to be significant by itself. Rather,the inquiry is whether the impact of the project's emissions of GHGs is cumulatively considerable. The Tustin Legacy Specific Plan planning area consists of open space in addition to residential,commercial, retail,and institutional uses.These uses currently generate GHG emissions from natural gas used for energy, heating and cooking, electricity usage, vehicle trips associated with each land use, area sources such as landscaping equipment and consumer cleaning products, from water demand,wastewater generation, and solid waste generation. 3.8.2 Project Impact Evaluation Would the project: a) Would the project generate Potentially Less than Less than No New greenhouse gas emissions, either Significant Significant Significant Impact directly or indirectly,that may have a Impact With Impact significant impact on the environment? Mitigation j- Incorporation (\ ❑ ❑ ❑ b) Would the project conflict ; Potentially Less than Less than No New with an applicable plan, policy, or } Significant j Significant 1 Significant I Impact regulation adopted for the purpose 1Impact With Impact of reducing the emissions of ; € Mitigation 4 I greenhouse gases? I I Incorporation ❑ ❑ ❑ Summary of Impacts from the FEIS/EIR: The 2001 FEIS/EIR did not evaluate greenhouse gas (GHG)emissions impacts because,prior to SB 97 which went into effect January 1, 2010,it was not included in the CEQA Guidelines Appendix G checklist and the City of Tustin did not have adopted thresholds at the time of preparation. The 2013 Addendum analyzed a modified Project that included an extension to Bell Avenue,construction of academic and office space beyond the previously analyzed amounts, and an increase in the ATEP trip budget. The air quality impact analysis assumed the construction of an additional 816,929 SF of academic space beyond that currently permitted. The 2013 Addendum also analyzed the impacts associated with 194,109 SF of academic and office space. The 2013 Addendum found that there were no substantial changes from the previous analysis in the FEIS/EIR. The 2017 Supplemental EIR concluded that implementation of the Tustin Legacy Specific Plan as amended would result in a substantial increase of GHG emissions that would exceed the South Coast Air Quality Management District's proposed significance thresholds. However, the Tustin Legacy Specific Plan as amended in 2017 was found to reduce annual emissions by 12,239 MTCO2e per year and per capita 40 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation emissions by 0.7 MTCO2e/SP compared to the MCAS Tustin Specific Plan adopted in 2001. Mitigation measures AQ-3 and AQ-4 applied to the impacts associated with the amended Tustin Legacy Specific Plan and found that impacts would be reduced to a less than significant impact. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-b: No Impact Due to No Substantial Change from Previous Analysis. Implementation of the Project would not result in any increase in GHG emissions compared to the Tustin Legacy Specific Plan analyzed in the FEIS/EIR, including the District/City Land Exchange Addendum. The Project implements the previously approved and analyzed Tustin Legacy Specific Plan with no increase in building square footage,trip counts,or other factors that could potentially contribute to GHG emissions.The Project is consistent with the City's General Plan.The General Plan was incorporated into the Southern California Association of Government's (SCAG) 2016- 2040 Regional Transportation Plan/Sustainable Community Strategy(SCS).On June 4,2012,the California Air Resources Board (CARB) found that the SCS would achieve the 2020 and 2035 GHG emission reduction targets established by CARB pursuant to the Sustainable Communities and Climate Protection Act of 2008 (referred to as SB 375).The Project would comply with all federal,state,regional and local regulations that reduce GHGs. A project, itself, does not generate enough GHG emissions on its own to influence global climate change.A GHG analysis measures a project's contribution to the cumulative environmental impact. The 2017 SEIR and the GHG analysis prepared for the 2017 SEIR included the proposed Project. Therefore, with the implementation of the proposed Project,there are no new or increased significant adverse project-specific or cumulative impacts with regard to GHG emissions. The Project and its implementation are consistent with the FEIS/EIR and, no new mitigation measures are required in relation to impacts to GHG emissions. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to climate change. Specifically,there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: No new impacts or substantially more severe impacts would result from implementation of the Project; therefore, no new or revised mitigation measures are required with regard to greenhouse gas emissions. In addition, there are no mitigation measures contained in the City's 2018 MMRP for the FEIS/EIR with regard to GHG emissions. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. Mitigation/Monitoring Not Being Implemented: Mitigation measure AQ-3 was included in the 2017 SEIR, but is not applicable to the proposed Project's air quality impacts and instead are included under greenhouse gas emissions analysis. Similarly, Mitigation Measure AQ-4 was added to the 2017 SEIR, but is only applicable to cities for implementation. Al September 2019 Legacy Medical Plaza Addend um/Environmental Checklist Environmental Evaluation 3.9 Hazards and Hazardous Materials 3.9.1 Existing Conditions The entire MCAS Tustin site was analyzed and potential impacts identified for hazardous materials during the base closure proceedings and in the 2001 FEIR/EIS. Portions of the Tustin Legacy Specific Plan are presently undergoing remediation,and therefore remain under Navy ownership. These areas are leased to the City under a Lease in Furtherance of Conveyance agreement (LIFOC). The non-fee portions of the ATEP site were subsequently subleased from the City to SOCCCD pursuant to the LIFOC agreement. The Navy is responsible for the remediation of hazards and hazardous materials resulting from its activities until remediation is completed. The Project site is located in the fee portion of the property owned by SOCCCD and is not within the area subject to the LIFOC agreement or affected by the Navy's remediation activities. Asbestos-containing materials (ACMs) and lead-based paint (LBP) were identified in previous surveys within the Tustin Legacy Specific Plan. There are well-established existing laws and procedures for remediating these two conditions. Remediation of these conditions have been addressed as part of a building demolition program on SOCCCD properties, and will also be implemented by the City as demolition proceeds on their properties. The demolition work was previously approved by the SOCCCD and is not a part of the Project. The presence of these two conditions in the military buildings has been thoroughly analyzed in the previously certified FEIS/EIR and does not affect the implementation of the Project. 3.8.2 Project Impact Evaluation Would the project: a) Create a significant hazard ' Potentially Less than Less than No New to the public or the environment Significant Significant Significant Impact through the routine transport, use, or Impact d With I Impact disposal of hazardous materials? Mitigation } Incorporation ❑ ❑ ❑ b) Create a significant hazard I Potentially i Less than I Less than No New to the public or the environment Significant I Significant Significant I Impact through reasonably foreseeable Impact i With j Impact upset and accident conditions € I Mitigation involving the release of hazardous I Incorporation materials into the environment? ❑ ❑ ❑ I � C) Emit hazardous emissions or Potentially € Less than Less than No New handle hazardous or acutely Significant Significant ? Significant Impact hazardous materials, substances, or 1 Impact I With Impact waste within one-quarter mile of an [ 1 Mitigation existing or proposed school? i Incorporation 9 i 42 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation d) Be located on a Site, which is ? Potentially Less than I Less than No New included on a list of hazardous E Significant s Significant I Significant Impact materials Sites compiled pursuant to i Impact With Impact I Government Code Section 65962.5 i 1 Mitigation and, as a result, would it create a Incorporation significant hazard to the public or the environment? a } ❑ ❑ ❑ e) For a project located within i Potentially ! Less than i Less than No New an airport land use plan or, where Significant Significant i Significant Impact such a plan has not been adopted, i Impact i With I Impact within two miles of a public airport or s Mitigation i public use airport, would the project d Incorporation result in a safety hazard or excessive noise for people residing or working r in the project area? 1 E ❑ i ❑ i f) Impair implementation of or Potentially Less than Less than No New physically interfere with an adopted Significant Significant Significant Impact emergency response plan or Impact With Impact emergency evacuation plan? Mitigation Incorporation ❑ ❑ ❑ g) Expose people or structures, Potentially Less than ; Less than No New either directly or indirectly to a Significant Significant Significant Impact significant risk of loss, injury or death Impact i With : Impact involving wildland fires? Mitigation Incorporation ❑ ❑ ❑ 3 Summary of Impacts from the FEIS/EIR: Multiple hazardous materials sites were identified in the FEIS/EIR. Contaminants include trichloroethylene, trichloropropane, jet fuel, petroleum hydrocarbons, volatile organic compounds, metals, and polynuclear aromatic hydrocarbons. Asbestos-containing materials were identified in 77 buildings onsite, and nonresidential buildings built before 1980 were assumed to contain lead-based paint. Impacts were identified in the FEIS/EIR as less than significant after remediation of environmental contamination per existing agreements and regulatory compliance. Subsequent analysis provided in the 2006 and 2013 Addenda identified progress made by the ongoing cleanup activities. Other cases of hazardous materials identified in the FEIR/EIS have been closed; site closure includes a determination by a regulatory agency that no further remedial action is required. Multiple compliance programs are in place allowing ongoing cleanup of hazardous materials sites by the Navy after the property was transferred. The 1999 Federal Facilities Site Remediation Agreement provides for coordinated remediation via these compliance programs under the oversight of DTSC in coordination with the Santa Ana RWQCB. The Navy will remediate all hazardous materials sites overlain by proposed residential uses to residential standards pursuant to the compliance programs. 43 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-g: No Impact Due to No Substantial Change from Previous Analysis. Implementation of the Project would not cause any direct impacts to hazards and hazardous materials. There are no new or increased significant adverse project-specific or cumulative impacts with regards to hazards and hazardous materials that are identified as a result of the adoption and implementation of the Project.There is no new information relative to hazards and hazardous materials that was not in existence at the time the FEIS/EIR was prepared. Therefore,the Project and its implementation are consistent with the FEIS/EIR and no new mitigation measures are required in relation to impacts from hazards and hazardous materials. The FEIS/EIR included a detailed discussion of the historic and then-current hazardous material use and hazardous waste generation within the Tustin Legacy Specific Plan area.The Navy is responsible for planning and executing environmental restoration programs in response to releases of hazardous substances for MCAS Tustin. The FEIS/EIR concluded that the implementation of the Tustin Legacy Specific Plan would not have a significant environmental impact from the hazardous wastes, substances, and materials on the property during construction or operation since the Navy would implement various remedial actions pursuant to the Compliance Programs that would remove,manage,or isolate potentially hazardous substances in soils and groundwater.As identified in the FEIS/EIR,the Project site is within the boundaries of the Airport Environs Land Use Plan (AELUP) and is subject to height restrictions.The Project does not propose changes to the 100- foot height limitation included in the Tustin Legacy Specific Plan. As mentioned previously, the Project site not included in the LIFOC area and is not affected by the Navy's remediation activities. Implementation of the proposed Project would not interfere with the Navy's remediation activities. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to hazards and hazardous materials. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: No new impacts or substantially more severe impacts will result from implementation of the Project; therefore, no new or revised mitigation measures are required with regard to hazards and hazardous materials. In addition, there are no mitigation measures contained in the City's 2018 MMRP with regard to hazards and hazardous materials. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. Mitigation IMonitoring Not Being Implemented: There are no new or revised mitigation measures for hazards and hazardous materials,and no mitigation measures are contained in the City's 2018 MMRP for the MCAS Specific Plan/Reuse Plan FEIS/EIR with regard to hazards and hazardous materials. 44 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.10 Hydrology and Water Quality t 3.10.1 Existing Conditions Surface water runoff from the ATEP campus generally flows east to Armstrong Avenue to existing 72-inch and 36-inch diameter drainpipes and south to Warner Avenue to a planned 36-inch diameter drainpipe. 3.10.2 Project Impact Evaluation Would the project: a) Would the project violate any I Potentially 9 Less than Less than No New water quality standards or waste I Significant i Significant Significant Impact discharge requirements or otherwise i Impact With Impact , substantially degrade surface or = Mitigation ` 1 ground water quality? Incorporation ❑ I ❑ 10 1 1 b) Substantially decrease I Potentially Less than : Less than No New groundwater supplies or interferer Significant Significant ; Significant ; Impact substantially with groundwater Impact With Impact E recharge such that the project may ' ; Mitigation impede sustainable groundwater I Incorporation 1 management of the basin? 1 ❑ t ❑ ❑ C) Substantially alter the Potentially Less than Less than No New existing drainage pattern of the Site Significant Significant Significant Impact or area, including through the Impact With Impact alteration of the course of a stream or Mitigation river or through the addition of Incorporation impervious surfaces, in a manner, . which would: ❑ ❑ ❑ y i) Result in substantial erosion or siltation on- or off-site? j C) Substantially alter the 1 Potentially s Less than € Less than # No New existing drainage pattern of the Site Significant i Significant I Significant Impact or area, including through the I Impact 1 With Impact ¢ alteration of the course of a stream or i Mitigation river or through the addition of 1 Incorporation { impervious surfaces, in a manner, ( s which would: ❑ ❑ ❑ ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite? 45 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation C) Substantially alter the Potentially 1 Less than i Less than ! No New existing drainage pattern of the Site i Significant Significant i Significant Impact or area, including through the Impact With Impact alteration of the course of a stream or j Mitigation j river or through the addition of Incorporation j impervious surfaces, in a manner, which would: � ❑ ❑ i ❑ iii) Create or contribute runoff water which would exceed the capacity of = existing or planned stormwater i drainage systems or provide j substantial additional sources of { polluted runoff? s I C) Substantially alter the Potentially Less than Less than No New existing drainage pattern of the Site Significant Significant Significant Impact or area, including through the Impact With Impact alteration of the course of a stream or Mitigation river or through' the addition of Incorporation impervious surfaces, in a manner, which would: ❑ I ❑ ❑ iv) Impede or redirect flood flows? d) In flood hazard, tsunami, or Potentially Less than ! Less than No New - seiche zones, risk release of pollutants Significant Significant Significant Impact due to project inundation? s Impact 3 With Impact Mitigation Incorporation ❑ ❑ ❑ E e) Conflict with or obstruct € Potentially Less than Less than No New implementation of a water quality Significant Significant S Significant Impact control plan or sustainable s Impact i With j Impact groundwater management plan? f Mitigation Incorporation El ❑ ❑ Summary of Impacts from the FEIS/EIR: Water Quality: Groundwater under the Specific Plans area ranges from brackish to saline; shallow groundwater onsite is contaminated with hazardous materials in several places.Water quality impacts were identified in the FEIS/EIR as less than significant after regulatory compliance. No substantial change was identified in subsequent environmental reviews. Hydrology: Planning Area 20 was designated as a 100-year flood zone by the Federal Emergency Management Agency (FEMA). Peters Canyon Channel was also identified as a 100-year flood zone. The balance of the project area was outside of 100-year flood zones. Tustin Legacy Specific Plan development would require storm drainage improvements to reduce flood hazards in Planning Area 20. Impacts were identified as less than significant in the FEIS/EIR. Implementation measures included in the 2004 Supplemental EIR required drainage studies and that projects make fair-share contributions to the Orange County Flood Control District for construction of flood control 46 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation facilities required by the affected projects. No substantial change from previous analysis was identified in t the 2006 Addendum. In 2004, a Master Runoff Management Plan for Tustin Legacy was approved by the City of Tustin. The Master Plan covered the ultimate buildout of the Tustin Legacy property, including all 22 Planning Areas and their ultimate land uses e.g., residential, mixed use,commercial, and park space. A master backbone storm drain system was designed and sized to accommodate the ultimate buildout peak flow for each Planning Area and land use. The design of the master storm drain system also includes significant detention systems to control and manage downstream peak flows. Since the approval of the Master Plan,much of the backbone storm drain infrastructure and detention systems have been constructed. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-e: No Impact Due to No Substantial Change from Previous Analysis. The Project would not cause a direct impact to hydrology and water quality. A Stormwater Pollution Prevention Plan (SWPPP), including an Erosion Control Plan,will be implemented during construction,and a Water Quality Management Plan (WQMP)will be implemented during operations. Each of these plans includes Best Management Practices (BMPs) to minimize impacts related to stormwater flows. As concluded in the FEIS/EIR, preparation of a WQMP for future development projects on the Project sites in compliance with all applicable regulatory standards would reduce water quality impacts from development activities to a level of insignificance. Additionally,the Project does not include any change to setbacks or other development standards that impact drainage. Any changes in drainage resulting from construction will be compliant with the master drainage plan in place for MCAS Tustin, as analyzed in the FEIS/EIR. The Project would not result in an increase of impervious surface area from the amount that was previously analyzed in the Tustin Legacy Specific Plan. t There are no new or increased significant adverse project-specific or cumulative impacts with regard to hydrology/water quality that are identified as a result of the adoption and implementation of the Project. There is no new information relative to hydrology/water quality that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR and no new mitigation measures are required in relation to impacts to hydrology/water quality. The Project proposes no change to the drainage pattern and water management systems previously analyzed in the FEIS/EIR. The drainage pattern and water management systems in the Project site vicinity would remain consistent with the Tustin Legacy Master Drainage Plan.Therefore,the analysis and conclusions in the FEIS/EIR relative to impacts related to groundwater supply, groundwater levels, or local recharge have not changed substantially. In addition, no change to the backbone drainage system is proposed. Therefore, no new or more severe impacts related to drainage patterns, drainage facilities, and potential flooding would result from the Project. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to hydrology and water quality. Specifically,there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as ( complete. 47 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation Mitigation/Monitoring Required: Compliance with existing rules and regulations would reduce any potential impacts related to water quality and groundwater to a level of insignificance and no new mitigation is required. The mitigation measures applicable during implementation (i.e., construction) of the Project have been identified in the City's adopted MMRP. Mitigation Measures WQ-1, WQ-2, WQ-4, and WQ-5 establish requirements related to preparation of a Stormwater Pollution Prevention Plan, compliance with Waste Discharge Requirements, and preparation of a Water Quality Management Plan, respectively. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required for implementation of the Project.The Project will implement the relevant mitigation measures of the adopted MMRP and as stated in the FEIS/EIR and 2018 MMRP, Mitigation/Monitoring Not Being Implemented: Mitigation Measure WQ-3 requires others to participate in the RWQCB's Nitrogen and Selenium Management Program (NSMP) Working Group and contribute to funding and implementing the Working Plan. Because this mitigation measure is the responsibility of others to implement, it does not fall within the responsibility of the Project to implement. C 48 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.11 Land Use and Planning 3.1 1.1 Existing Conditions In 2013,the plan for ATEP was further revised through a land exchange agreement with the City of Tustin, the addition of a new roadway, and modification of the trip caps affecting the site. CEQA analysis for the 2013 revisions was provided by the District/City Land Exchange Addendum. The former military buildings on the SOCCCD parcels have been demolished. The Project site is located within the ATEP campus and subject to the revisions from the 2013 land exchange agreement with the City of Tustin. The first building—the IDEA building—was built on the ATEP site and internal circulation roads and connections were constructed on the ATEP site. 3.1 1.2 Project Impact Evaluation j Would the project: a) Physically divide an I Potentially Less than Less than No New established community? Significant Significant Significant Impact Impact With Impact Mitigation Incorporation _ ❑ ❑ ❑ b) Cause a significant Potentially Less than Less than No New environmental impact due to a conflict Significant Significant Significant Impact 4 with any land use plan, policy, or Impact With Impact { regulation adopted for the purpose of Mitigation ' avoiding or mitigating an Incorporation environmental effect? Summary of Impacts from the FEIS/EIR: The FEIS/EIR determined that the project required amendments to the General Plan and Zoning Ordinance to provide consistency with the general plan and zoning designations in the cities of Tustin and Irvine. It found that the intensification and change of land uses pursuant to the Tustin Legacy Specific Plan could create land use incompatibilities with surrounding land uses and internal incompatibilities within the project area. Implementing Actions were incorporated to mitigate this impact by addressing compatibility through processing of land use plans and amendments consistent with the applicable general plans and zoning ordinances. In 2001,the City of Tustin adopted a General Plan land use designation "MCAS Tustin Specific Plan," and the Specific Plan was adopted on February 3,2003 (Ordinance 1257).As described previously,the Specific Plan established the zoning designations, development standards, and entitlement framework for future development in the Specific Plan area. The 2013 Addendum determined that implementation of the modified project would not cause any direct impacts to land use and planning. The development intensity (the amount of total square footage and corresponding FAR) was permitted to increase because the increase was negligible compared to the total amount of planned development within Tustin Legacy, and continued to be subject to trip caps imposed by the Tustin Legacy Specific Plan. The 2013 Addendum included an increase in the trip cap as a result of increased roadway capacity provided by the Bell Avenue extension (Victory Road). The 2013 Addendum 49 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation found no new impacts related to land use and planning.Similarly,the 2016 Addendum found no new impacts related to the construction and operation of the IDEA building. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-b: No Impact Due to No Substantial Change from Previous Analysis: Implementation of the Project would not cause any direct impacts to land use and planning. There would be no change to development intensity, building height restrictions, setbacks, signage, and other development standards. The Project would not physically divide any Specific Plan land use or conflict with the Specific Plan.There are no new or increased significant adverse project-specific or cumulative impacts with regard to land use and planning that are identified as a result of the adoption and implementation of the Project.There is no new information relative to land use and planning that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR and no new mitigation measures are required in relation to impacts to land use planning. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to land use and planning. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitorina Required: The FEIS/EIR concludes that there would be no significant unavoidable land use impacts. The Project and its implementation do not result in new or increased land use impacts in comparison to those previously identified in the FEIS/EIR. Mitigation Measure LU-2(k), regarding, the completion of drainage studies prior to grading for new development, is applicable because the Project includes grading and construction activities. The mitigation measures applicable to the Project were implemented following adoption of the Tustin Legacy Specific Plan. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. The District and City will implement the relevant mitigation measures of the adopted MMRP that are applicable to the Project. MitigationIMoniforina Not Being Implemented: Mitigation Measures LU-1 and LU-2 required the Cities of Tustin and Irvine respectively to amend their General Plans and zoning ordinances for the Tustin Legacy Project, and therefore are not within the responsibility of the Project. LU-2(a) requires that infrastructure construction be properly phased by the Cities of Tustin and Irvine, and therefore is not within the responsibility of the Project. LU-2(b)is not applicable to the SOCCCD since no recording of subdivision maps is proposed as part of the Project.Per the City's adopted 2018 MMRP,the SOCCCD recorded the necessary easements for the Property and Mitigation Measure LU-2(b) has been fulfilled. Mitigation Measure LU-2(c), regarding funding construction of capital improvements, does not apply to the SOCCCD because the City exempted the SOCCCD's property from fair-share backbone infrastructure fees (per section 4.7.1.2 of the District Conveyance Agreement); however, for the proposed project, which is a non-educational use, the mitigation measure would apply. Measures LU-2(g) and (i) are not applicable because the Project site is not within the 100-year floodplain (Federal Emergency Management Agency Flood Insurance Rate Map Panel No. 06059CO279J),and thus these Mitigation Measures are not within the responsibility of the Project.Mitigation Measure LU-2(h),regarding obtaining regulatory agency approvals prior to construction of regional flood control facilities, is not within the responsibility of the Project because 50 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation it only applies to the Tustin Legacy developer(s). Mitigation Measure LU-2(j), regarding local drainage ( systems,is not applicable because no subdivision maps are being recorded as part of the Project.Mitigation Measure LU-2(I), regarding an agreement with the Orange County Flood Control District for fair-share contributions to flood control facilities,is not applicable because no subdivision maps are being recorded as part of its Project and the Mitigation Measure only applies to the City of Tustin. In addition, the City exempted the SOCCCD's Property from fair-share backbone infrastructure fees per section 4.7.1.2 of the Conveyance Agreement. Mitigation Measure LU-2(t) is not applicable because no school fees are required for the Project. Mitigation Measure LU-2(u) is not applicable because the Project does not require a contribution to park facilities. Mitigation Measure LU-2(v) is not applicable to projects within the City of Tustin, and therefore is not within the Project's responsibility to implement. Measure LU-2(w), regarding the creation of a landscape maintenance district, is applicable to the Tustin Legacy developer, and therefore, is not within the Project's responsibility to implement. Finally, Mitigation Measure LU-2(x) is not applicable to the Project because no subdivision map is proposed as part of the Project, the Project is not adjacent to the Barranca Channel,and the City will provide any necessary bikeways along Red Hill Avenue. { i !i II� i a i i j i i i 3 fr I 0 1 51 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.12 Mineral Resources 3.12.1 Existing Conditions There are no known mineral resources or activities located on the Project Site. 3.12.2 Project Impact Evaluation Would the project: a) Result in the loss of Potentially Less than ' Less than No New availability of a known mineral ' Significant ' Significant 1 Significant Impact resource that would be of value to the Impact = With Impact region and the residents of the state? _ Mitigation Incorporation ❑ I ❑ ❑ b) Result in the loss of Potentially Less than ; Less than No New availability of a locally-important Significant = Significant Significant Impact mineral resource recovery Site Impact With Impact delineated on a local general plan, Mitigation specific plan or other land use plan? Incorporation Summary of Impacts from the FEIS/EIR: No mineral resources valuable to the region or the state or identified in the general plans of the cities of Tustin or Irvine, were identified in the FEIS/EIR. No impacts to mineral resources are identified in previous environmental documents. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-b: No Impact Due to No Substantial Change from Previous Analysis: The Project would not cause new impacts to mineral resources that were not previously analyzed in the FEIS/EIR.There are no new or increased significant adverse project-specific or cumulative impacts with regard to mineral resources that are identified as a result of the adoption and implementation of the Project.There is no new information relative to mineral resources that was not in existence at the time the FEIS/EIR was prepared.Therefore,the Project and its implementation are consistent with the FEIS/EIR and no new mitigation measures are required in relation to impacts to mineral resources. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to mineral resources. Specifically,there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: No new impacts or substantially more severe impacts would result from 52 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation implementation of the Project; therefore, no new or revised mitigation measures are required for mineral 1 resources. In addition,there are no mitigation measures contained in the City's 2018 MMRP for the FEIS/EIR with regard to mineral resources. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. Mitigation/Monitoring Not Being Implemented: There are no new or revised mitigation measures for mineral resources, and no mitigation measures are contained in the MMRP for the FEIS/EIR with regard to mineral resources. i s d 53 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.13 Noise 3.13.1 Existing Conditions The ambient noise environment on the Project site is influenced by the surrounding roadways, the RSCCD's Sheriff's Training Academy, a rail line located north of Edinger Avenue, and construction and remediation activities on surrounding parcels. 3.13.2 Project Impact Evaluation Would the project: a) Generation of a substantial Potentially Less than Less than No New temporary or permanent increase in Significant Significant Significant I Impact ambient noise levels in the vicinity of Impact With I Impact the project in excess of standards : Mitigation established in the local general plan ` Incorporation or noise ordinance, or applicable standards of other agencies? ❑ ❑ 1 ❑ b) Generation of excessive Potentially Less than = Less than No New groundborne vibration or Significant Significant Significant = Impact groundborne noise levels? Impact With ; Impact I Mitigation Incorporation ❑ I ❑ ❑ . C) For a project located within Potentially Less than Less than No New the vicinity of a private airstrip or an Significant Significant Significant a Impact airport land use plan or,where such a Impact ; With Impact plan has not been adopted,within two Mitigation miles of a public airport or public use Incorporation airport, would the project expose people residing or working in the project area to excessive noise levels? Summary of Impacts from the FEIS/EIR: The FEIS/EIR determined that noise impacts would be significant if noise levels for sensitive receptors exceeded noise criteria established in the noise elements of the general plans for the cities of Tustin, Irvine, and Santa Ana. Sensitive receptors are residences, schools, libraries, hospitals, and recreational areas. The FEIS/EIR identified that an increase of 3 dB over existing noise levels experienced by a sensitive receptor would be a significant impact. The FEIS/EIR determined that the increase in traffic levels would not result in a significant impact to roadways surrounding the Tustin Legacy Specific Plan area.However,significant noise impacts were found for residents near the extension of Tustin Ranch Road to Von Karman Avenue and to residential and park uses adjacent to Warner Avenue between Harvard and Culver Drive. " 54 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation The FEIS/EIR found that future sensitive receptors developed in accordance with the Tustin Legacy Specific Plan would incorporate applicable regulations and impacts would be less than significant. The FEIS/EIR also determined that there would be a significant impact to existing onsite housing planned for reuse. Mitigation measures were incorporated to reduce noise levels below 65 dB to less than significant levels. The 2013 Addendum determined implementation of the modified project would not cause any substantial impacts to noise. The land exchange and land use changes permitted an increased trip cap of 10,000 ADT. The primary land use in the vicinity of the Project site that would be impacted by an increase in noise was determined to be the Orange County Rescue Mission. The 2013 Addendum analyzed the projected noise levels 50 feet from roadway centerline post construction of the ATEP site, assuming the addition of 10,000 ADT. Many roadways were expected to experience a decrease in traffic noise when the Bell Avenue extension (Victory Road)was to be completed due to a shifting in traffic patterns resulting from the diverted traffic. Both Valencia Avenue and Warner Avenue were anticipated to experience up to a 2 dB reduction in traffic noise levels.Traffic noise along Armstrong Avenue south of Valencia Ave.was to have the potential to experience a noise increase of +2 dB CNEL at 50 feet from the roadway centerline, but this is less than the level of human detection and less than the significance threshold. The next highest project-associated traffic noise increase is on Red Hill Avenue between Bell Avenue and Valencia Avenue. This +1.0 dB CNEL increase was similarly less than significance thresholds and would not create a detectable noise increase. Traffic noise associated with the addition of 10,000 trips was therefore not expected to create a significant noise impact. Consistent with the 2013 Addendum,the 2016 Addendum also found that there would be no new or greater impact than was analyzed in the FEIS/EIR. The now constructed IDEA Building has not experienced noise levels greater than allowed noise levels. The 2017 Supplemental EIR found that a Tustin Legacy Specific Plan amendment would result in an increase in long-term operation-related noise along two roadway segments and reduce to a less than significant level with mitigation incorporated from the 2001 FEIS/EIR (MM N-1 and MM N-3) and the 2004 Supplemental EIR (MM NR-1 through NR-7). Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-c: No Impact Due to No Substantial Change from Previous Analysis: Implementation of the Project would not cause any impacts to noise beyond those previously analyzed in the FEIS/EIR. The Project is an implementation and construction of the scope of development previously analyzed for the site, and there is no change in the proposed land use or intensification of uses that would result in increased noise generation. Both short-term(construction-period)and long-term (operational-period)noise impacts were analyzed in the FEIS/EIR; construction and operation of the Project would be required to comply with applicable adopted mitigation measures and state and local regulations and standards, along with established engineering procedures and techniques, thus avoiding significant short-term construction-related noise impacts. The Project site is not located within the 60 CNEL contour for airport operations. Therefore, implementation of the Project would not involve the development of any noise-sensitive land uses susceptible to excessive noise related aircraft operations within the 60 CNEL. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to noise. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant ( environmental effects or a substantial increase in the severity of previously identified effects; (2)substantial 55 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation changes with respect to the circumstances under which the Project is undertaken that require major revisions j of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial (\ increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIVEIR were certified as complete. Mitigation Nonitoring Required: The FEIS/EIR concludes that with implementation of identified mitigation measures, there would be no significant impacts related to noise. The Project does not increase the severity of the noise impacts previously identified in the FEIS/EIR. Therefore, no refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. Mitigation Measure N-3 will apply to the project during construction to ensure interior and exterior noise levels do not exceed the City's noise standards. Mitigation Nonitoring Not Being_Implemented: Mitigation Measure N-1 is not applicable to the Project, as no residential buildings are being reused as part of the Project. Mitigation Measure N-2, regarding noise studies on surrounding properties during design of the intersection at Tustin Ranch Road at Edinger Avenue, have been completed by the City of Tustin. Mitigation Measure N-4 will not apply to the Project in relation to noise studies adjacent to Warner and Harvard Avenues. 56 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.14 Population and Housing 3.14.1 Existing Conditions There is no housing and associated population on the ATEP campus. 3.14.2 Project Impact Evaluation Would the project: a) Induce substantial unplanned Potentially I Less than Less than No New population growth in an area, either Significant Significant Significant Impact directly (for example, by proposing Impact With Impact new homes and businesses) or = = Mitigation j indirectly (for example, through Incorporation i extension of roads or other r infrastructure)? ' ❑ 1 ❑ ' ❑ ' ® b) Displace substantial numbers Potentially Less than Less than No New of existing people or housing, ' Significant Significant : Significant : Impact necessitating the construction of Impact s With Impact replacement housing elsewhere? Mitigation Incorporation I ❑ ❑ ❑ I ® Summary of Impacts from the FEIS f EIR: The 2001 FEIS/EIR found that development of the Tustin Legacy Specific Plan would have resulted in a total population of 12,514, (10,900 in Tustin), resulting in a net population increase of approximately 9,350 persons. The 2001 FEIS/EIR analyzed the demolition of the barracks units and conversion to civilian use. Buildout of the Tustin Legacy Specific Plan allowed 4,601 residential units, including the 1,537 converted or replaced units. In addition,the 2001 FEIS/EIR found that buildout would have resulted in about 24,500 net new jobs,or a net increase of approximately 24,500 jobs.In addition,the project was expected to generate 15,081 indirect jobs.The 2001 FEIS/EIR concluded that the increase in population,housing,and employment due to the implementation of the Tustin Legacy Specific Plan was a beneficial impact because it would fulfill an identified shortfall in housing and meet the goals of the project to generate jobs. The 2001 FEIS/EIR determined that there would be no adverse impact related to the jobs/housing balance. It was determined that the majority of new jobs would be filled by existing residents within Orange County and it would provide enough new housing for employees residing outside of the County.No significant impact was identified. The 2006 Addendum updated the demographic data and growth projections for the City of Tustin and County of Orange using the Orange County Projections 2004 (OCP 2004) prepared by the Center for Demographic Research (CDR) at California State University, Fullerton. OCP 2004 includes buildout projections assumed for the Tustin Legacy Specific Plan. The changes in projections showed an increase in population and employment in Tustin with a slightly lower housing stock,indicating a larger household size. The 2013 and 2016 addenda did not involve any changes to population or housing projections disclosed in previous environmental analyses. Therefore, no impact was a result of no substantial change from previous analysis. 57 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation The 2017 Supplemental EIR amended the Tustin Legacy Specific Plan from the construction of 4,601 residential units and 11,287,725 square feet of nonresidential building space to the construction of 6,813 residential units and 9,532,419 square feet of nonresidential building space. The difference between these two scenarios represented an overall increase of 2,212 dwelling units and a decrease of 1,755,306 square feet of building space. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: The proposed Project would construct a new 50,000 square foot medical office building. The Project would not include the construction of new housing. Responses to a-b: No Impact Due to No Substantial Change from Previous Analysis: Implementation of the Project would have no impacts to population and housing. There are no new or increased significant adverse project-specific or cumulative impacts with regard to population and housing that are identified as a result of the adoption and implementation of the Project. There is no new information relative to population and housing that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR and no new mitigation measures are required in relation to impacts to population and housing. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to population and housing. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects;or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: No new impacts or substantially more severe impacts would result from implementation of the District's adoption and implementation of the Project; therefore, no new or revised mitigation measures are required for population and housing. In addition,there are no mitigation measures contained in the City's 2018 MMRP for the FEIS/EIR with regard to population and housing. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. Mitigation/Monitoring Not Being Implemented: There are no mitigation measures contained in the City's 2018 MMRP for the FEIS/EIR with regard to population and housing. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. 58 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.15 Public Services l 3.15.1 Existing Conditions i Fire t The Orange County Fire Authority (OCFA) provides fire protection to the Project site and Tustin Legacy. Police { Police protection services for the SOCCCD properties are provided by the Irvine Valley College Police E Department with support from the City of Tustin and other cities that are a part of the mutual aid agreed- upon support. Schools I 6 There are no K-12 school facilities on the Project site. i Parks There are no existing parks on the Project site. 3.15.2 Project Impact Evaluation a) Would the project result in ! Potentially i Less than I Less than I No New substantial adverse physical impacts Significant ) Significant I Significant Impact associated with the provision of new z Impact t With Impact or physically altered governmental Mitigation P facilities, need for new or physically Incorporation altered governmental facilities, the g i construction of which could cause j significant environmental impacts, in j ! ! € 9 order to maintain acceptable service ! ! I I a ratios, response times or other performance objectives for any of the € I' I public services: Fire protection? ❑ ❑ _ ❑ Police protection? I ❑ ❑ j ❑ Schools? El El Li E9 Parks? I ❑ ❑ F ❑ Other public facilities? 1-1 ElEl Summary of Impacts from the FEIS f EIR: Fire Protection The FEIS/EIR determined that implementation of the Tustin Legacy Specific Plan would require additional firefighting personnel and equipment at existing fire stations. However, it found that buildout would not require new or expanded fire stations.All development projects would be required to meet Orange County Fire Authority (OCFA) regulations,and impacts were determined to be less than significant. Subsequent to the certification of the FEIS/EIR,in May 2003,the Navy Disposal Plan transferred to the City of Tustin a 1.25-acre site at Edinger Avenue and the West Connector for construction of the new fire station. 59 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation The fire station would be funded through development in Tustin Legacy and in the City of Irvine within the / former MCAS Tustin. (` Subsequently, OCFA reevaluated its need for fire protection facilities with respect to response times and determined it needed to move Station No. 37 to a new location in the Tustin Legacy Specific Plan area. In March 2005, the City entered into a Memorandum of Understanding with OCFA for a new fire station at Tustin Legacy. The 2006 Addendum found that the project would place a similar demand for fire protection services as the original project and that the fire station proposed in the Tustin Legacy Specific Plan area would meet the needs of the project. As determined by the FEIS/EIR, future projects would be required to comply with all OCFA regulations. Police Protection The FEIS/EIR determined that implementation of the Tustin Legacy Specific Plan would increase the demand for police services in the cities of Tustin and Irvine.The FEIS/EIR identified the need for two additional patrol units and three additional investigative units in the Tustin Police Department, and two additional sworn officers in the Irvine Police Department. However,it found that buildout would not require new or expanded police facilities and impacts would be less than significant. The 2006 Addendum found similar impacts with respect to police services and no new impacts were identified. Schools The Tustin Legacy Specific Plan area is within the service areas of the Tustin Unified School District (TUSD), Irvine Unified School District(IUSD),and Santa Ana Unified School District(SAUSD).TUSD serves the majority of the Tustin Legacy Specific Plan area,including Planning Areas 1,2,A-5,6,7, 8, 15, 16-19,and a portion of 13-1 A. IUSD serves a portion of Planning Area 15 and development east of Jamboree Road (Planning Areas 20, 21,and 22). SAUSD serves Planning Area 9-12 and a portion of Planning Area 13-1 A. Libraries The FEIS/EIR identified three public libraries within three miles of the Tustin Legacy Specific Plan area. It found that implementation of the Tustin Legacy Specific Plan would not require construction of a new library facility, and impacts were less than significant. Subsequently, Orange County Public Library (OCPL)entered into an agreement with the City of Tustin to expand the Tustin Branch Library in the Tustin Civic Center. The project was approved in September 2005 and evaluated in a mitigated negative declaration (SCH 20020A1001) adopted May 2002. In 2009, the new 32,000-square-foot library opened, replacing the 15,000-square-foot facility built in 1974. The new library has a book capacity of 209,000 volumes. Summary of Potential Proiect Specific and Cumulative Impacts with the Proposed Proiect• Response to a: No Impact Due to No Substantial Change from Previous Analysis: Implementation of the Project would not cause any significant impacts to public services. There are no new or increased significant adverse project- specific or cumulative impacts with regard to public services and facilities that are identified as a result of the adoption and implementation of the Project. There is no new information relative to public services and facilities that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR and no new mitigation measures are required in relation to impacts to public services and facilities. Fire Protection Fire protection for the Project site was discussed and analyzed in the FEIS/EIR. The Project results in no changes to that previous analysis, and no increased or new environmental effects on the environment from (` 60 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation those previously analyzed in the FEIS/EIR. f Implementation of the Project will require compliance with existing OCFA regulations regarding construction materials and methods, emergency access, water mains, fire flow,fire hydrants, sprinkler systems, building setbacks,and other relevant regulations.Adherence to these regulations will reduce the risk of uncontrollable fire and increase the ability to efficiently provide fire protection services to the Site. Pursuant to the FEIS/EIR, the existing fire stations in the Project vicinity with additional firefighting personnel and equipment will meet the demands created by the Project and other development within Tustin Legacy.A relocated and expanded Fire Station No. 37,located less than one mile east of the Project site,opened in 2014 to serve Tustin Legacy and surrounding areas. No new or expanded facilities were identified as being required and therefore no physical impacts were identified. Police Protection r Police protection for the Project site was discussed and analyzed in the FEIS/EIR. The Project results in no changes to that previous analysis, and no increased or new environmental effects on the environment from those previously analyzed in the FEIS/EIR, i n The Irvine Valley College Police Department has a similar level of law enforcement capabilities as Tustin j Police Department officers, including the capacity to cite and arrest offenders. They also have access to the emergency radio network that is shared with the Tustin Police Department, Orange County Sheriff's Department, OCFA, and other emergency personnel. The SOCCCD property is patrolled and serviced 24 j hours per day by a combination of the Irvine Valley College police and security services that are under the 1, management of the Irvine Valley College police.Tustin Police Department officers would respond to requests for assistance on the City-owned parcel. Implementation of the Project would not increase the need for police protection services in addition to what was anticipated in the FEIS/EIR. Schools a The Project does not include any residential development. Therefore, the Project does not generate K-12 students and there is no impact to schools. The Project Sponsor would not be required to pay school development fees consistent with Senate Bill (SB) 50 of 1998. Parks Consistent with the Tustin Legacy Specific Plan, the Project does not include any park development. PA 2, located north of Valencia Avenue and the ATEP campus, is identified in the Tustin Legacy Specific Plan as a "Community Park." PA 6, located across Armstrong Avenue from the Project site, is identified as an "Urban Regional Park."There is no change to the proposed park uses in PAs 2 and 6 as a result of the Project. Other Public Facilities The FEIS/EIR concluded that public facilities would be provided according to a phasing plan to meet projected needs as development of the Tustin Legacy Specific Plan proceeded. The Project would not increase the demand more than what was already analyzed in the previously certified FEIS/EIR. Mitigation/Monitoring Required: The FEIS/EIR concluded that there would be no significant unavoidable impacts related to public services.The Project and its implementation would not result in any new or increased impacts to public services beyond those identified in the FEIS/EIR. Therefore, no new mitigation measures are required. f The Project Sponsor would implement Mitigation Measure LU-2(m) by ensuring adequate public services are 61 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation included to serve the Tustin Legacy Specific Plan as a result of the adoption and implementation of the Project (such as the construction and operation of the proposed Project), as described in the 2018 MMRP. Under Mitigation Measure LU-2, the City is responsible for ensuring that adequate fire protection, police protection, library, and parks and recreational facilities needed to adequately serve the Tustin Legacy Project is provided as necessary. According to the 2018 MMRP, SOCCCD, pursuant to the Development Agreement and Restated and Amended (Conveyance) Agreement, is required to construct all on-site improvements,however,the City has exempted SOCCCD from City CFD funded Tustin Legacy Infrastructure costs for the primary educational uses while it requires payment of its Fair Share of Infrastructure fees for non-educational uses (such as the proposed Project), and is still subject to assessments from outside utility purveyors regardless of the use of project and would be responsible for any costs that are necessary if SOCCCD proposes to modify or alter existing Tustin Legacy Infrastructure as well as landscape maintenance easements. The Project Sponsor will implement Mitigation Measures LU-2(o) by coordinating directly with the OCFA regarding potential fire protection impacts of the Project. SOCCCD's Fire Master Plan has already been reviewed and approved by OCFA as part of Phase 1 of the ATEP Campus, Mitigation Measures LU-2 (p), (q), and (r), related to fire protection,will be implemented as specific developments are proposed for the Project site.Mitigation Measure LU-2(s),regarding police protection,has been implemented by the SOCCCD, and the Tustin Police Department has been consulted regarding the existing ATEP Campus and the development of MCAS Tustin. The Project Sponsor and SOCCCD will continue to coordinate with the Tustin Police Department on issues related to the policing of the Project site.Mitigation Measures LU-2(u) regarding the Fair Share Contribution program towards Tustin Legacy Infrastructure, which includes public park at Tustin Legacy is also applicable to the Project because of its non-educational use and is therefore within the responsibility of the Project. Mitigation-IMonitoring Not Being Implemented: The City will not implement Mitigation Measure LU-2(n) because the SOCCCD is not immediately adjacent to a trail system and did not implement a trail through \ the ATEP campus site. Mitigation Measure LU-2(t) regarding the payment of school fees is not applicable to the Project, and therefore is not within the responsibility of the Project. Mitigation Measure LU-2(w) regarding the creation of a landscape maintenance district is the responsibility of the Tustin Legacy master developer,and therefore is not within the responsibility of the Project.Mitigation Measure LU-2(x) regarding agreements with the County of Orange Harbors and Beaches and the City of Tustin for trail improvements are not applicable to the Project, and are therefore not within the responsibility of the Project. 62 September 2019 Legacy Medical Plaza Addendum/Enyironmental Checklist Environmental Evaluation 3.16 Recreation 3.16.1 Existing Conditions Consistent with the Tustin Legacy Specific Plan,there are no public recreational facilities on the ATEP Site. 3.16.2 Project Impact Evaluation a) Would the project increase I Potentially I Less than Less than No New the use of existing neighborhood and Significant Significant Significant I Impact regional parks or other recreational Impact With Impact facilities such that substantial physical i Mitigation deterioration of the facility would s Incorporation occur or be accelerated? ❑ ❑ ❑ E b) Does the project include Potentially ! Less than ' Less than No New recreational facilities or require the I Significant Significant Significant i Impact construction, expansion, or Impact With Impact j recreational facilities, which might F Mitigation have an adverse physical effect on the Incorporation environment? j ❑ ❑ i ❑ Summary of Impacts from the FEISZEIR: The FEIS/EIR evaluated recreational impacts of the Tustin Legacy Specific Plan that included 126 acres of public parkland, including 118 acres in the City of Tustin (84.5-acre regional park, 24.1-acre community park, and two 5-acre neighborhood parks) and an 8-acre neighborhood park in the City of Irvine. The FEIS/EIR found that the 118 acres of public parkland in Tustin was well over the requirement established by the City's municipal code (three acres of park per 1,000 residents). It determined that the provision of approximately 126 acres of parkland would result in a beneficial impact related to the provision of parks. Construction and operation of the proposed parks were also evaluated throughout the FEIS/EIR and mitigation measures were identified. The FEIS/EIR analyzed proposed Class I and II bikeways, riding and hiking trails proposed in the Tustin Legacy Specific Plan. Physical impacts of trail construction were identified throughout the FEIS/EIR along with the development areas. These recreational facilities were determined to be a beneficial impact to the project. j The 2006 Addendum identified an increase in parkland to 202 acres of public parks, an increase of 76 acres of public parkland compared to the original Tustin Legacy Specific Plan evaluated in the FEIS/EIR.The 2006 Addendum evaluated the elimination of a 159-acre private golf course that was originally proposed and determined that it would not have been completely accessible to the general public and may have resulted in increased environmental impacts. The Tustin Legacy Specific Plan would result in a beneficial impact related to recreation with a new community park and linear park system providing a focal point for the community.The 2006 Addendum identified a number of individual development projects that have been approved and provided additional private recreation facilities not originally envisioned in the Tustin Legacy Specific Plan. The 2006 Addendum determined that the Tustin Legacy Specific Plan would exceed the parkland dedication requirement and would not generate an increase in the use of existing recreational facilities.Additionally,it determined that the changes proposed in the bikeway and trail system would be a beneficial impact. 63 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation Similarly, the 2016 Addendum determined that the Project would not result in an increase of development intensity or change in uses that would result in increased use of existing parks or recreational facilities. The 2017 Supplemental EIR found that the Tustin Legacy Specific Plan Amendment would provide ample parkland,buildout would not increase the use of existing parks or cause the physical deterioration of existing recreational facilities. Therefore,it was determined that less than significant impacts of new changes or new information required revisions to the EIR. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-b: No Impact Due to No Substantial Change from Previous Analysis. The Project would not result in an increase of development intensity or change in uses that would result in increased use of existing parks or recreational facilities. There are no new or increased significant adverse project-specific or cumulative impacts with regard to recreation that are identified as a result of the adoption and implementation of the Project.There is no new information relative to recreation that was not in existence at the time the FEIS/EIR was prepared and no new mitigation measures are required in relation to impacts to recreation. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to recreation. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. MitigationNonitorina Required: No new impacts or substantially more severe impacts would result from the implementation of the Project;therefore,no new or revised mitigation measures are required for recreation. In addition,there are no mitigation measures contained in the City's MMRP for the FEIS/EIR with regard to recreation or recreational facilities. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. Mitigation/Monitoring Not Being Implemented: There are no new or revised mitigation measures for recreation or recreational facilities, and there are no mitigation measures contained in the City's MMRP for the FEIS/EIR with regard to recreation or recreational facilities. C 64 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.17 Transportation 3.17.1 Existing Conditions Major roadways near the Project site include: • Warner Avenue, a six-lane major arterial,to the south; • Red Hill Avenue to the west,currently six lanes and an eight-lane major arterial at future buildout; • Valencia Avenue,a four-lane secondary arterial,to the north; and • Armstrong Avenue, a four-lane secondary arterial,to the east. Access to the Project site is primarily from Victory Road and Innovation Drive, Victory Road is a recently constructed road,connecting to Bell Avenue from Red Hill Avenue. Hope Drive,a secondary road internal to the ATEP site provides access to the Project site from the north. o d 3.17.2 Project Impact Evaluation Would the project: a) Conflict with program, plan, 1 Potentially Less than Less than No ordinance or policy addressing the ! Significant Significant Significant Impact circulation system, including transit, I Impact WithImpact roadway, bicycle, and pedestrian Mitigation facilities? Incorporation ❑ i ❑ ❑ 1 ® b) Conflict or be inconsistent with Potentially ? Less than I Less than I No CEQA Guidelines section 15064.3, ' Significant Significant : Significant ' Impact q subdivision (b)? Impact With = Impact Mitigation Incorporation El1 ❑ ❑ iE C) Substantially increase 1 Potentially Less than Less than No geometric hazards due to a design I Significant Significant Significant I Impact feature (e.g., sharp curves or I Impact With Impact { dangerous intersections) or ; Mitigation incompatible uses (e.g., farm ' Incorporation I t equipment)? I 1 F ❑ , ❑ ❑ I d) Result in inadequate ` Potentially Less than Less than ` No emergency access? Significant Significant ` Significant e Impact Impact With Impact Mitigation Incorporation ❑ ❑ ' ❑ Summary of Impacts from the FEIS/EIR: The 2017 Supplemental EIR evaluated the potential for implementation of the Tustin Legacy Specific Plan Amendment to result in transportation impacts in the project and surrounding area. No new impacts were 65 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation made as a result of land use changes to Planning Areas 8 through 19. Impacts were determined to be significant and unavoidable. The 2001 FEIS/EIR determined that Tustin Legacy Specific Plan buildout was estimated to generate 216,445 average daily trips (ADT). The Tustin Legacy Specific Plan buildout was forecast to result in potentially significant impacts to 16 intersections for long-range (Year 2020) conditions. Mitigation measures were identified for all significant impacts, including fair-share contribution from proponents of development projects in the area. Even with incorporation of mitigation measures, impacts were determined to be significant and unavoidable in 2020 With Project conditions for the intersections of Tustin Ranch Road at Walnut Avenue and Jamboree Road at Barranca Parkway. Impacts to all other intersections were less than significant after mitigation. Additional mitigation measures required phased completion of roadway improvements onsite based on cumulative project-generated ADT. The 2001 FEIS/EIR determined that the increase in development would create additional demand for transit service. However, the buildout would improve the circulation system which would improve service for bus routing. No significant impacts were identified on the rail system. No significant pedestrian or bicycle impacts were identified in the 2001 FEIS/EIR;however,the planned bicycle trails would provide a benefit to the pedestrian and bicycle facilities. The 2004 Supplemental EIR identified a potentially significant additional impact at the intersection of Red Hill Avenue at Warner Avenue in the cities of Tustin and Santa Ana. Mitigation was required and implemented, and the impact was determined to be less than significant after mitigation. The 2013 Addendum identified increased local roadway capacity related to the extension of Bell Avenue (now Victory Road),which allowed for increased intensity of development on the project site without creating new or significant traffic impacts. A traffic study was prepared by Stantec in April 2013. The 2013 Addendum designated a trip cap of 5,470 ADT for the ATEP site and 1,672 ADT for the City parcels, whereas the overall MCAS Tustin planned trip count was 216,440 ADT. Furthermore,a trip generation table was produced for two development scenarios considered for the ATEP site. Scenario 1 increases the previously approved amount of development on the ATEP site by 194,119 SF,with the total square footage of the development being allocated to 51 percent educational and 49 percent office uses. Scenario 2 increases the previously approved amount of development on the ATEP site by 816,929 SF, with the entire development devoted to educational uses. The 2013 Traffic Study also evaluated requirements for site access,including lane geometry at the new Bell Avenue (Victory Road) intersections. Signal warrants and left-turn storage length requirements were analyzed. The analysis concluded that an appropriate design for the Bell Avenue extension, including the two major intersections at either end of the extension (at Red Hill and Armstrong Avenues), was feasible, and construction of the roadway extension would be accommodated with no adverse traffic conditions on other parts of the circulation system. Proper engineering of the roadway extension would therefore avoid any potential safety hazards due to design features. The 2013 Addendum analyzed that the project would not involve any increase in permitted heights on the site and would not be expected to have any impact on air traffic patterns at John Wayne Airport or any other aviation facility.In addition,by providing an additional access route to the ATEP site and Tustin Legacy, a positive impact on emergency access to existing and future development in the area would result from the project. The 2013 Addendum included analysis of a Class II bicycle lane and sidewalks along Bell Avenue. No public transit facility was proposed,as no bus route currently exists or is planned for the Bell Avenue extension.The bicycle lane and sidewalk would be beneficial to bicyclists and pedestrians. The GPA and SPA associated with the 2013 Addendum would identify a new Class II bicycle facility along the Bell Avenue extension.With these amendments, the project would not conflict with any adopted policies, plans, or programs regarding public transit, bicycle,or pedestrian facilities. C_ 66 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation The 2016 Addendum determined that the IDEA building did not propose any significant adjustments to the location or design of the three access points, nor did it increase the amount of traffic by adding square footage beyond that which was previously analyzed. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a —d: No Impact Due to No Substantial Change from Previous Analysis.The proposed Project would construct a new 50,000 gross square-foot medical office building at the northeast corner of Victory Road and Red Hill Avenue. # CEQA Guidelines section 15064.3 subdivision (b) discusses the use of vehicle miles traveled (VMT) for the u impact analysis. The requirement of this section takes effect in June 2020 or where an agency has adopted thresholds for VMT.The City and SOCCCD have not adopted any thresholds regarding VMT.Therefore,the project would not be inconsistent with CEQA Guidelines section 15064.3,subdivision (b),and impacts would not occur, and no substantial change from previous analysis would occur. 3 The 2013 Addendum to the FEIS/EIR evaluated scenarios for the ATEP campus. Scenario 1 assumed 51 percent for academic uses and 49 percent for office uses. Scenario 2 assumed 100 percent academic land j uses. Furthermore,Scenario 1 assumed 553,100 SF of General Office land uses and 7,075 ADT generated. Therefore, General Office land uses, which includes Medical Offices, per the DA would yield a vehicle trip 9 rate of 13.27 ADT per thousand SF. The trip generation table below compares the proposed Project with the 2013 Addendum methodology, which is detailed in the ATEP Traffic Study prepared in April 2013 (included as Appendix A of the 2013 Addendum). Table 4: Project Trip Generation AM Peak Hour PM Peak Hour Land Use Units Daily I In Out Total In Out Total s' Trip Rates 3 e f F f Learning Center' TSF 6.12 10.657 0.073 0.730 0.147 0.343 0.490 GeneralOffice',3 TSF 13.27 1 1.654 0.226 1.880 : 0.306 1.494 1.800 j i A TEP Scenario 1' i i a r Learning Center' 554.870 TSF 3396 365 41 405 82 190 272 General Office',3 533.100 TSF 7074 882 120 1002 163 796 960 s Approved Projects IDEA Building 32.492 TSF 199 21 2 24 5 11 16 Proposed Project Trip Generation Legacy Medical Plaza General Office3 50.000 TSF 1 664 i 83 11 94 15 75 90 Total Trips Remaining2 ¢ 9608 i I TSF= Thousand Square Feet ' Source:2013 Agreement for Exchange of Real Property GPA 2013-001,SPA 2013-001, DA 2013-002 AddendumlEnvironmental Checklist, 3.16 TransportationlTraffic 2 Tracking of projects within the analyzed ATEP Scenario 1 boundary by subtracting Daily trips from approved projects. 3 Pursuant to the DA,Exhibit H,Land Use Category 2,General Office,includes Medical Offices. 67 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation The proposed Project would be within the scope of Scenario 1. A new 50,000 square-foot medical office building would generate a total of 664 ADT. The Project's proponent has the right to use up to 664 ADT from the District's assigned ADTs and construct up to 50,000 gross square feet of building area consistent with the Development Framework and Development Agreement between the City of Tustin and the District dated May 22,2013,as amended.Therefore,as shown in Table 4,the proposed Project is within the 7,074 ADT for General Office land uses planned within ATEP,and thus within the 9,608 ADT for the overall ATEP site. The Project does not substantially modify the roadway system as previously analyzed in the FEIS/EIR. The square footage of development and the general location of the proposed medical office building is consistent with that which was previously analyzed. The Project includes improvements to provide access via driveways on Victory Road, Hope Drive, and Innovation Drive. The three access points were previously analyzed in the District/City Land Exchange Addendum,which included a Traffic Study. The Project does not propose any significant adjustments to the location or design of the three access points, nor does it increase the amount of traffic by adding square footage beyond that which was previously analyzed. On-site circulation would include a system of sidewalks, pedestrian walkways, and roadways connecting to Victory Road,Hope Drive,and the proposed medical office building.According to the 2013 Addendum,the extension of Bell Avenue (now Victory Road) included planned Class II bicycle lanes. These planned bicycle lanes would serve the Project site. With these features, the project would not conflict with any adopted policies, plans,or programs regarding public transit, bicycle,or pedestrian facilities. There are no new or increased significant adverse project-specific or cumulative impacts with regard to transportation that are identified as a result of the adoption and implementation of the Project. In addition, Mitigation Measure T/C-3 requires the Project Sponsor to pay its fair share of Infrastructure fees for non- educational uses (such as the proposed Project) to reduce potential cumulative impacts. There is no new information relative to transportation that was not in existence at the time the FEIS/EIR was prepared and no new mitigation measures are required in relation to impacts to traffic and transportation. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to recreation. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3)the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. MitigationMonitoring Required: The mitigation measures applicable during implementation of the Project have been identified in the City's adopted MMRP. Mitigation Measure T/C-1 requires that prior to the approval of a site development permit, the City of Tustin must review and approve the proposed traffic control and operations plans that would minimize the traffic impacts of proposed construction activity. The plans shall address roadway and lane closures, truck hours and routes, and notification procedures for planned short-term or interim changes in traffic patterns. Mitigation Measures T/C-2 through T/C-9, IA-1, IA-2,and IA-4 are implemented by the City of Tustin and/or the City of Irvine. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required for implementation (i.e., construction)of the Project.The Project will implement the relevant mitigation measures of the adopted MMRP 68 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation I as stated in the 2018 MMRP Annual Report. No new impacts or substantially more severe impacts will result from the District's adoption and implementation of the Project than originally considered by the previously j certified FEIS/EIR. Therefore, no new or revised mitigation measures are required. I MitigationZMonitoring Measures Not Being Implemented: Mitigation Measure IA-3 requires that prior to I approval of a development permit,the City of Tustin shall review traffic information provided for the project by the project developer. The City is required to evaluate project traffic impacts utilizing the circulation � system and capacity assumptions included in the FEIS/EIR. Compliance with this Mitigation Measure has been completed through the Traffic Study prepared by Stantec and included in Appendix A to the 2013 Addendum.The project would not exceed traffic capacity thresholds or require the implementation of traffic mitigation measures. With the approval of the Amended and Restated Conveyance Agreement, no further ' action is required in compliance with Mitigation Measure IA-5. For Mitigation Measures IA-6 and IA-7, the City has determined that no off-site roadway improvements are needed on the Project site. d i { i i i i 1 6 i I E� 3 69 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.18 Tribal Cultural Resources 3.18.1 Existing Conditions The Project site is a vacant site with an asphalt-paved parking lot,multiple trees,and overgrown vegetation. There are no historical resources onsite. 3.18.2 Project Impact Evaluation a) Would the project cause a Potentially : Less than = Less than = No New substantial adverse change in the I Significant Significant ' Significant Impact significance of a tribal cultural Impact With _ Impact resource, defined in Public Resources 1 Mitigation = _ Code section 21074 as either a site, I Incorporation 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 ElEl El historical resources as defined in F Public Resources Code section e 5020.1(k)? a) Would the project cause a Potentially Less than Less than No New substantial adverse change in the Significant Significant Significant Impact significance of a tribal cultural s Impact With Impact resource, defined in Public Resources = Mitigation Code section 21074 as either a site, Incorporation feature,place,cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural g value to a California Native American tribe, and that is: ii) A resource determined by the lead agency, in its discretion and f i supported by substantial evidence, to F I be significant pursuant to criteria set 3 forth in subdivision (c) of Public j Resources Code Section 5024.1. InEl El 11 El Z { applying the criteria set forth in I subdivision(c)of Public Resource Code i # s Section 5024.1,the lead agency shall consider the significance of the I s resourceto a California Native American tribe. 70 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation Summary of Impacts from the FEISJEIR: Tribal cultural resources were not analyzed in FEIS/EIR because the CEQA criteria and thresholds related to analyzing tribal cultural resources did not exist at the time the FEIS/EIR were prepared. Prior impact analysis regarding archaeological resources addressed Native American viewpoints and consultation under Mitigation Measure Arch-2. This mitigation measure would be triggered prior to the issuance of grading permits. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to ai—aii: No Impact Due to No Substantial Change from Previous Analysis. The Project site is a previously disturbed military site. Due to the existing vacant and disturbed conditions, no listed or eligible historical resources exist on the Project site. Thus, implementation of the Project would not result in new impacts related to historical resources. In addition,the Project site is not in an area known for having,or suspected of having,tribal cultural resources or human remains. In the unlikely event that human remains are encountered during earth removal or disturbance activities, the California Health and Safety Code Section 7050.5 requires that disturbance of the site shall halt until the coroner has conducted an investigation into the circumstances, manner, and cause of any death,and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation or to his or her authorized representative (included as a County condition of approval).The Coroner would also be contacted pursuant to Sections 5097.98 and 5097.99 of the Public Resources Code relative to Native American remains. Should the Coroner determine the human remains to be of Native American descent,the coroner must notify the Native American Heritage Commission (NAHC)within 24 hours.The NAHC would then be required to contact the most likely descendant of the deceased Native American, who would then serve as a consultant on how to proceed with treatment of the remains. Compliance with the established regulatory framework (i.e., California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98)would provide that any potential impacts to human remains would be less than significant. No new impact would occur. Assembly Bill (AB) 52 (Chapter 532, Statutes of 2014) establishes a formal consultation process for California tribes as part of the CEQA process and equates significant impacts on "tribal cultural resources" with significant environmental impacts (Public Resources Code [PRC] § 21084.2). AB 52 requires that lead agencies undertaking CEQA review evaluate,just as they do for other historical and archeological resources, a project's potential impact to a tribal cultural resource. As described previously, the site has been highly disturbed and the potential for the Project to impact tribal cultural resources is less than significant. In addition, AB 52 requires that lead agencies, upon request of a California Native American tribe, begin consultation prior to the release of a negative declaration, mitigated negative declaration, or EIR for a project. AB 52 does not apply to a Notice of Exemption or Addendum. As this CEQA document is an Addendum,the AB 52 requirements are not applicable. Mitigation Measure Arch-2 would reduce the potential impacts related to tribal cultural resources to a less than significant level. Thus, no new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the FEIS/EIR. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist regarding tribal cultural resources. There have not been 1) changes to the Project that require major revisions of the previous adopted EIR due to the involvement of ( new significant environmental effects or a substantial increase in the severity of previously identified effects; 71 September 2019 Legacy Medical Plaza Addendum/Enyironmental Checklist Environmental Eyaluation 2) substantial changes with respect to the circumstances under which the Project is undertaken that require " major revisions of the previous adopted EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or 3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the adopted EIR was adopted as completed. MitigationIMonitoring Required: The Project Sponsor would implement Mitigation Measure Arch-2 by retaining a County-certified archaeologist and conducting the required consultations prior to obtaining grading permits. If buried resources are found during grading within the reuse plan area, a qualified archaeologist would need to assess the Site significance and perform the appropriate.mitigation.The Native American viewpoint shall be considered during this process. This could include testing or data recovery. Native American consultation shall also be initiated during this process. Mitigation/Monitoring Measures Not Being Implemented: Other mitigation measures for tribal cultural resources in the FEIS/EIR and City's 2018 MMRP are not applicable to the Project site and are the responsibility of others to implement. C 72 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.19 Utilities and Service Systems 3.19.1 Existing Conditions All dry utilities (electricity, cable, telephone, and gas) and wet utilities (water, wastewater and reclaimed water) are located in the streets surrounding the Project site. Existing development on the ATEP campus connect to these utilities.. New utility services have been installed along Victory Road,south of the site. 3.18.2 Project Impact Evaluation Would the project: a) Require or result in the Potentially Less than Less than 1 No New relocation or construction of new Significant Significant Significant Impact water or wastewater treatment or r Impact With Impact storm water drainage, electric power, i E Mitigation ' 3 i natural gas, or telecommunications I Incorporation facilities,the construction or relocation of which could cause significant environmental effects? ` 0 ❑ ❑ ❑ 1 j b) Have sufficient water supplies j Potentially Less than Less than j No New available to serve the project and Significant Significant Significant Impact 5 reasonably foreseeable future Impact With Impact development during normal, dry and Mitigation multiple dry years? € Incorporation 1 ❑ 10 1 ❑ IE C) Result in a determination by Potentially Less than Less than No New the wastewater treatment provider, Significant Significant Significant Impact which serves or may serve the project Impact With Impact that it has adequate capacity to serve Mitigation the project's projected demand in Incorporation addition to the provider's existing commitments? P ❑ I ❑ I ❑ d) Generate solid waste in Potentially Less than ? Less than No New excess of State or local standards, or ` Significant Significant Significant ' Impact in excess of the capacity of local Impact With Impact infrastructure, or otherwise impair the ' I Mitigation attainment of solid waste reduction I r Incorporation goals? ❑ ❑ ❑ e) Comply with federal, state, = Potentially I Less than = Less than = No New and local management and reduction Significant Significant Significant Impact statutes and regulations related to Impact With : Impact solid waste? _ Mitigation Incorporation 73 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation Summary of Impacts from the FEIS f EIR: The FEIS/EIR determined that impacts to potable water supply and distribution,reclaimed water supply and distribution, wastewater conveyance and treatment, storm drainage, electricity supply and distribution, natural gas supply and distribution, and solid waste disposal were less than significant with no mitigation required. Utilities would be replaced and sized to accommodate the proposed land uses. The FEIS/EIR determined that at buildout the Tustin Legacy Specific Plan would demand 2.8 million gallons per day (mgd) of water and 1.8 mgd of reclaimed water. It would generate 2.5 mgd of wastewater, with a peak flow of 7.7 gallons per day (gpd). All utility infrastructure, including the storm drain system would be designed to adequately accommodate development. The 2013 Addendum determined no changes to the utilities plan presented in the Tustin Legacy Specific Plan and that any demolition, removal, replacement, and connection with new underground utilities and service systems in the adjoining streets would occur as previously analyzed in the FEIS/EIR. The 2013 Addendum increased size of 194,119 square feet (based on the more likely scenario of 51 percent academic space and A9 percent office space) to 816,929 square feet (based on the less likely scenario of 100 percent academic space) would yield only a negligible impact on utilities compared to the full scope of the Tustin Legacy Specific Plan, which included up to 4,601 residential units and over 1 1.4 million square feet of commercial, institutional, and recreational buildings. The full scope of this much larger development was evaluated in the FEIS/EIR as Alternative 1;however,the Tustin Legacy Specific Plan was ultimately approved with 10.4 million SF of nonresidential land uses. There is approximately 1 million SF of nonresidential uses that was fully analyzed in the FEIS/EIR but was not incorporated into the Tustin Legacy Specific Plan. The 2013 Addendum represents fewer SF than the excess square footage analyzed in the FEIS/EIR and therefore the 2013 Addendum impacts have already been assessed in the FEIS/EIR. At the time of the preparation of the 2017 Supplemental EIR,there were no changes to the utility providers servicing the Tustin'Legacy Specific Plan area.Water and wastewater services are provided by Irvine Ranch Water District (IRWD). Wastewater from the project area is treated at IRWD's Michelson Water Recycling Plant, which has capacity of 28 mgd and average wastewater flows of 18 mgd, and thus has residual capacity of about 10 mgd. A forecast Phase III expansion of the Michelson plant is planned to increase capacity to 33 mgd by 2025 (IRWD 201 A). The storm drain plan includes five major drainage areas with main line facilities and improvements to the OCFCD Barranca Channel.The backbone system follows the alignments of the major arterial roadways.The use of retention basins was also considered. Solid waste services are provided by the Orange County Waste and Recycling and CR&R Waste Services. Electricity is provided by Southern California Edison, and natural gas is provided by Southern California Gas Company. Telephone and cable are provided by AT&T,Cox Cable,and Time Warner. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: The proposed Project would construct a new 50,000 square foot medical office building. The Project would conned existing utilities within Victory Road to the proposed building. Responses to a-e: No Impact Due to No Substantial Change from Previous Analysis: The Project would not result in any change to the utilities plan presented in the Tustin Legacy Specific Plan, or require increased utility services beyond the levels analyzed in the FEIS/EIR, or the District/City Land Exchange Addendum. The square footage of development and the type of use at the Project site is consistent with that which was previously analyzed. As described in the 2013 Addendum, once individual buildings are proposed on the Project site (such as the 74 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation proposed Project), an evaluation of utility needs will occur to ensure the appropriate connections are provided. Project facilities would comply with local and State code requirements related to water efficiency and the minimization of wastewater and solid waste generation. Impacts related to these utilities were evaluated in the FEIS/EIR;the Project would not result in any increase in water use and wastewater and solid waste generation over the prior analyses. Relative to stormwater, the Project would be required to implement a WQMP consistent with current standards.This would result in substantial on-site water retention and infiltration, thereby reducing off-site drainage flows and minimizing impacts to the local drainage system.All storm drains would be designed in compliance with the Tustin Legacy Master Drainage Plan. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to utilities and service systems. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. MitigationIMonitoring Required: No new impacts or substantially more severe impacts would result from adopting or implementing the Project; therefore, no new or revised mitigation measures are required for j public utilities. In addition, there are no mitigation measures contained in the City's MMRP for the FEIS/EIR with regard to public utilities. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. i f Mitigation/Monitoring Not Being Implemented: There are no new or revised mitigation measures for public utilities, and no mitigation measures are contained in the MMRP with regard to public utilities. I i i s i 75 September 2019 Legacy Medical Plaza Addendum/Enyironmental Checklist Environmental Evaluation 3.20 Wildfire 3.20.1 Existing Conditions The Project site is vacant and disturbed with an asphalt-paved parking lot, multiple trees, and overgrown vegetation. 3.20.2 Project Impact Evaluation If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project: a) Substantially impair an F Potentially ` Less than Less than No New adopted emergency response plan or Significant Significant i Significant Impact emergency evacuation plan? Impact I With Impact Mitigation r i Incorporation ❑ 1 ❑ ❑ b) Due to slope, prevailing Potentially Less than I Less than No New winds, and other factors, exacerbate Significant i Significant Significant Impact wildfire risks, and thereby expose Impact t, With Impact F project occupants to, pollutant i Mitigation concentrations from a wildfire or the Incorporation i uncontrolled spread of a wildfire? ❑ , ❑ ❑ C) Require the installation or Potentially Less than Less than No New maintenance of associated Significant Significant t Significant Impact infrastructure (such as roads, fuel i Impact With Impact breaks, emergency water sources, Mitigation power lines or other utilities)—that may Incorporation exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? ❑ ❑ ❑ d) Expose people or structures to j Potentially Less than ', Less than No New significant risks, including downslope Significant ' Significant I Significant Impact or downstream flooding or landslides, t Impact I With j Impact j as a result of runoff, post-fire slope Mitigation I instability, or drainage changes? i Incorporation ❑ ❑ ❑ Summary of Impacts from the FEISJEIR: At the time of the prior environmental analysis, Wildfire, was not a specific topic analyzed because the CEQA criteria and thresholds related to analyzing wildfire did not exist at the time the 2017 Supplemental EIR was prepared. However, impacts related to wildfire was addressed in other sections of the prior environmental analysis. The 2017 Supplemental EIR found that no fire hazard severity zones are mapped onsite by the California Department of Forestry and Fire Prevention (CAL FIRE 2011). Development within the Tustin Legacy Specific Plan area is required to comply with Orange County Fire Authority regulations. 76 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation Buildout of the Tustin Legacy Specific Plan Amendment would not expose people or structures to substantial hazards from wildland fires, and no substantial new impact would occur. Summary of Potential Project Specific and Cumulative Impacts with the Proposed Project: Responses to a-d: No Impact Due to No Substantial Change from Previous Analysis: Implementation of the Project would not cause any direct impacts related to wildfires. The FEIS/EIR found that the Project site is not located within a fire hazard severity zone. Therefore, there are no new or increased significant adverse project-specific or cumulative impacts with regards to wildfires that are identified as a result of the construction and operation of the Project. There is no new information relative to wildfire that was not in existence at the time the FEIS/EIR and no new mitigation measures are required in relation to impacts from wildfires. As discussed in the 2013 Addendum,the ATEP campus would be required to be in compliance with existing OCFA regulations regarding construction materials and methods, emergency access, water mains,fire flow, fire hydrants, sprinkler systems, building setbacks, and other relevant regulations. This would reduce the potential impacts related to wildfires. Thus, no new impact would occur that was not analyzed in previous environmental analysis. Similarly, prior analysis determined that the Project would not result in an impact related to non-seismic geological hazards (such as slopes) and that compliance with state and local regulations and standards, along with established engineering procedures and techniques, would avoid unacceptable risk or the creation of significant impacts related to geotechnical issues. Based on the foregoing,none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures with regard to utilities and service systems. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. I Mitigation.lMonitoring Required: No new impacts or substantially more severe impacts would result from adopting or implementing the Project; therefore, no new or revised mitigation measures are required for wildfire. The Project Sponsor will implement Mitigation Measures LU-2(o) by coordinating directly with the OCFA regarding potential fire protection impacts of the Project. SOCCCD's Fire Master Plan has already been reviewed and approved by OCFA as part of Phase 1 of the ATEP Campus.Mitigation Measures LU-2 (p), (q), and (r), related to fire protection, will be implemented as specific developments are proposed for the Project site. No refinements are necessary to the FEIS/EIR mitigation measures and no new mitigation measures are required. Mitigation/Monitoring Not Being Implemented:There are no new or revised mitigation measures for wildfires, and no mitigation measures are contained in the MMRP with regard to wildfires. 77 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation 3.21 Mandatory Findings of Significance a) Does the project have the Potentially Less than Less than No New potential to substantially degrade the ' Significant I Significant Significant Impact quality of the environment, Impact With Impact substantially reduce the habitat of a Mitigation fish or wildlife species,cause a fish or Incorporation wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? ❑ ❑ ❑ b) Does the project have impacts i Potentially Less than Less than No New that are individually limited, but I Significant I Significant Significant ; Impact cumulatively considerable? ' Impact With ' Impact ("Cumulatively considerable" means ° Mitigation that the incremental effects of a Incorporation g project are considerable when viewed in connection with the effects of past iz projects, the effects of other currents f s projects, and the effects of probable future projects)? C) Does the project have Potentially Less than Less than No New environmental effects that will cause I Significant I Significant Significant = Impact substantial adverse effects on human ' Impact With Impact beings, either directly or indirectly? > Mitigation Incorporation _ ❑ ❑ I ❑ . Response to a-c: No Impact Due to No Substantial Change from Previous Analysis: The FEIS/EIR previously considered all environmental impacts associated with the implementation of the Tustin Legacy Specific Plan, including mandatory findings of significance associated with the implementation of the Project. The Project would not expand the area of development and would not impact any natural habitats or other areas inhabited by sensitive species. The Project would not increase development potential compared to the full scope of the Tustin Legacy Specific Plan evaluated in the FEIS/EIR, including the Phase 3A Concept Plan Addendum and the District/City Land Exchange Addendum. The Project would not cause unmitigated environmental effects that were not already examined in the FEIS/EIR. There are no new mitigation measures required and there are no new significant adverse project-specific or cumulative impacts in any environmental areas that were identified,nor would any project-specific or cumulative impacts in any environmental areas be made worse as a result of the Project.All feasible mitigation measures identified in the FEIS/EIR will be incorporated into subsequent actions that the District and City commit to fully implement.Therefore,the Project does not create any impacts that have not previously been addressed by the FEIS/EIR.. 78 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Environmental Evaluation i Further, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent EIR to evaluate Project impacts or mitigation measures with regard to environmental impacts. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: No new impacts or substantially more severe impacts would result from the Project;therefore,no new or revised mitigation measures are required. Mitigation/Monitorina Not Being Implemented: There are no new or revised mitigation measures for mandatory findings of significance and no mitigation measures are contained in the MMRP with regard to mandatory findings of significance. a i 1 I I II l 79 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Mitigation Measures 4. Summary of Mitigation Measures Project impacts and required mitigation (if necessary) are discussed in the environmental issue topical areas in Section 3 above—Environmental Evaluation. Based on the previously certified FEIS/EIR,the environmental evaluation determined that no new mitigation is needed for the Project. The following table (Table 5) lists the Specific Plans FEIS/EIR Mitigation Measures that are applicable to the Project. 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Q x (p 7Oa03 N K q n N p N p N 7 W N ^ N N 7 fl 1 1 fl o 3 O 5 ° N NC m (p N 3 ^ n 3 c U m c a m y 0 7 N m n A 'p y2 'O ^ n O p p N c O N o ° n v =� (v N _ m �. (0o 3 3 =: p 3 F fl n 3 o v m � Fs' 0 N a p °tr o °. 9 a 1 3 o p s 7 c c S n N W 3 W (o o fl N 0 M M � N o 3 $ p a � N o > � ( �g D� � Kf < k § $ E� �7 M _ X32 ; 2 � \ - J 20 R � � o �� J . � / -0 o 3 o n N j i 0 § S , * 2 K © , . 4 » Do § £ % % 2- 3:: c � @6 # m 60- 6006" , c _ = , , I � ar 2 ¢ J4 , � # EI " C ; ° ■ ; ^ �.0 a- 03 �— . E 0- 0 , , o i � i $ k � E2R ° "0 =r . 0 ; � �' 2i I _ ƒ $ � 2 ° o g03 13 � ¥ � f � � CA \ D % 2 F ©� ■ o # -n 03e m , 'a o m ¢ { } ; 2 ' A . A . @ « � m3 of A 13 o "0 0 § � � on n « f . 0 r m 0 1 ; 0 tr , � Legacy Medical Plaza Addendum/Environmental Checklist Sources and Acronyms 5. Sources/Acronyms 5.1 Sources The following sources were consulted in the preparation of this Initial Study. Field Observations California Air Resources Board, October 2013. Facts about California's Sustainable Communities Plans: Southern California Association of Governments 2012-2035 Regional Transportation Plan/Sustainable Communities Strategy California Air Resources Board, June 4, 2012. Executive Order G-12-039, Southern California Association of Governments (SLAG) Sustainable Communities Strategy (SCS) ARB Acceptance of GHG Quantification Determination City of Tustin and Department of the Navy, 1998. FEIS/EIR for Disposal and Reuse of MCAS Tustin and Addendum. City of Tustin, March 2018. 2018 Revised Annual Mitigation Monitoring and Status Report for Final Joint Environmental Impact Statement/Environmental Impact Report For the Disposal and Reuse of MCAS Tustin. City of Tustin, Reuse Plan adopted October 31, 1996,amended September 8, 1998,Specific Plan adopted by City Council Ordinance No. 1257 on February 3, 2003, and Specific Plan Amendment Adopted by City Council Ordinance No. 1311 on April 17, 2006. MCAS Tustin Specific Plan/Reuse Plan. City of Tustin General Plan City of Tustin Resolutions(including environmental checklists) regarding Tustin Legacy:00-90; 04-32; 04-73; 04-74;04-76;04-77; 05-28; 05-35;05-37;05-38;0540;05-71;05-75;05-76;05-77;05-78;06-42; 0643; 07-92; 08-09; 08-18; 08-38; 08-39; 08-42; 08-53. RGP Planning & Development Services, November 2008. South Orange County Community College District ATEP Advanced Technology & Education Park Long-Range Academic Plan and Facilities Plan, as amended by the October and November 2008 Erratas (LRP). RGP Planning & Development Services, November 2008. South Orange County Community College District ATEP Advanced Technology & Education Park Long-Range Academic Plan, as amended by the October 2008 Errata (LRAP). RGP Planning & Development Services, July 2008. CEQA Addendum/Initial Study for Advanced Technology Education Park (ATEP) Long Range Academic and Facilities Plan (LRP). RGP Planning &Development Services,October 2008. CEQA Addendum/Initial Study and Appendices errata for Advanced Technology Education Park (ATEP) Long Range Academic and Facilities Plan (LRP). RGP Planning & Development Services, April 2013. General Plan Amendment 2013-001, Specific Plan Amendment 2013-001,Development Agreement 2013-002,and Agreement for the Exchange of Real Property between City of Tustin and South Orange County Community College District.SOCCCD/City Land Exchange. CEQA Addendum/Initial Study. 96 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Sources and Acronyms RGP Planning & Development Services, March 2009. Advanced Technology & Education Park (ATEP) Phase 3A Concept Plan Project. CEQA Addendum/Initial Study. RGP Planning & Development Services, December 2011. Agreement for Exchange of Real Property. SOCCCD/County Land Exchange. CEQA Addendum/Initial Study. Southern California Association of Governments, April 4, 2012. 2012-2035 Regional Transportation Plan/Sustainable Communities Strategy,General Plan Land Use and Zoning Maps for City of Tustin. Southern California Association of Governments, 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy, General Plan Land Use and Zoning Maps for City of Tustin California Air Resources Board, Facts about California's Sustainable Communities Plans: Southern California Association of Governments 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy California Air Resources Board,Executive Order G-12-039,Southern California Association of Governments (SCAG) Sustainable Communities Strategy (SCS) ARB Acceptance of GHG Quantification Determination South Orange County Community College District, April 22, 2004. "Agreement Between the City of Tustin and The South Orange County Community College District For Conveyance of a Portion of MCAS,Tustin and The Establishment of an Advanced Technology Educational Campus" (the "District Conveyance Agreement"). South Orange County Community College District, November 2008. Resolution 08-35 Adopting the Addendum as Amended by the Errata dated November 2008 to the Final Environmental Impact Statement/Environment Impact Report for the Disposal and Reuse of the WAS Tustin and the WAS Tustin Specific Plan/Reuse Plan dated October 1996, as Amended by the Errata dated September 1998 pursuant to the California Environmental Quality Act for the Project, the Long-Range Academic and Facilities Plan dated June 2008 and as Amended by the Errata dated October 2008 and the Errata dated November 2008, and the Long-Range Academic Plan dated June 2008 and as Amended by the Errata dated October 2008. South Orange County Community College District,March 2009.ATEP Phase 3A Concept Plan. State of California,California Code of Regulations 1 97 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Sources and Acronyms 5.2 Acronyms ACM asbestos-containing materials ADT average daily trips AELUP Airport Environs Land Use Plan ATEP Advanced Technology & Education Park BMP best management practices CDFW California Department of Fish & Wildlife CEQA California Environmental Quality Act City City of Tustin CNEL community noise equivalent level County County of Orange RWQCB Regional Water Quality Control Board DAMP Drainage Area Management Plan District South Orange County Community College District DSA Division of the State Architect EIR Environmental Impact Report EIS Environmental Impact Statement EV education village FAR floor area ratio FEIS/EIR Program Final Joint EIS/EIR for the Disposal and Reuse of Marine Corps Air Station (MCAS) Tustin (SCH No. 94071005). FEMA Federal Emergency Management Agency FOST Finding of Suitability to Transfer GHG greenhouse gas ICU intersection capacity utilization - LBP lead-based paint LEED Leadership in Energy and Environmental Design LID low-impact development LIFOC Lease in Furtherance of Conveyance LOS Level of Service LRAP Long-Range Academic Plan LRP Long-Range Academic and Facilities Plan MBTA Migratory Bird Treaty Act MCAS Marine Corps Air Station MMRP Mitigation Monitoring and Reporting Program MND Mitigated Negative Declaration Navy Department of Navy ND Negative Declaration NEPA National Environmental Policy Act NSMP Nitrogen and Selenium Management Program OCFA Orange County Fire Authority OCFCD Orange County Flood Control District OCHCA Orange County Health Care Agency OCSD Orange County Sanitation District OCTA Orange County Transportation Authority PA planning area Reuse Plan MCAS Tustin Specific Plan (previously MCAS Tustin Reuse/Specific Plan) ROD Record of Decision RSCCD Rancho Santiago Community College District SARWQCB Santa Ana Regional Water Quality Control Board SB Senate Bill SCAB South Coast Air Basin 98 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Report Preparers 6. Report Preparers a The following professional firms and team members were involved in the preparation of the CEQA documentation for the proposed amendment to the MCAS Tustin Specific Plan. EPD Solutions, Inc. • Jeremy Krout,AICP, LEED GA, President • Konnie Dobreva,JD, Director of Environmental Planning y • Rafik Albert,AICP, LEED AP, Director of Planning I • Brandon Whalen, Environmental Planner 1 I I 1 i 8 p j l li i i y s 3 100 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Sources and Acronyms SCAQMD South Coast Air Quality Management District SCH State Clearinghouse SF square feet SOCCCD South Orange County Community College District SPA Specific Plan Amendment Specific Plan MCAS Tustin Specific Plan (previously MCAS Tustin Reuse/Specific Plan) SR state route SRP Short Range Plan SWPPP Stormwater Pollution Prevention Plan TSF . thousand square feet Tustin Legacy former MCAS Tustin Site VOC volatile organic compounds WQMP Water Quality Management Plan 99 September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Appendices The following link to the 2018 Annual Mitigation Monitoring and Status Report is accessible here; httl?s•//epdsolutions-my.sharepoint.corn/:b/:b:(pfepdserye rf EcR- KEX L1 'BU 'BKgbOGdLtz4b8Bl62hnnCFOf81 3uPLeb CwA?e=ADpl�_$_ September 2019 Legacy Medical Plaza Addendum/Environmental Checklist Appendices Appendix A 2018 Annual Mitigation Monitoring and Status Report, WAS Tustin FEIS/EIR September 2019