HomeMy WebLinkAboutCC RES 24-77Docusign Envelope ID: 84DE734F-1604-46B3-8E5C-03CD38415370
RESOLUTION NO. 24-77
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF TUSTIN,
CALIFORNIA, CERTIFING THE FINAL ENVIRONMENTAL IMPACT REPORT
AND ADOPTING ENVIRONMENTAL FINDINGS, A STATEMENT OF
OVERRIDING CONSIDERATIONS, AND ERRATA FOR GENERAL PLAN
AMENDMENT 2024-0001, ZONE CHANGE 2024-0001, AND CODE
AMENDMENT 2024-0003 - HOUSING ELEMENT SITE 17 (ENDERLE
CENTER)
The City Council of the City of Tustin does hereby resolve as follows:
I. The City Council finds and determines as follows:
A. That the City's 2021-2029 6th Cycle Housing Element of the General Plan
(Housing Element) was certified by the California Department of Housing
and Community Development in October 2022. The Housing Element
contains the goals and policies the City intends to implement to address
several housing -related issues.
B. That the Housing Element sets forth a Housing Implementation Program
that provides for specific actions the City intends to undertake to achieve
the goals and policies of the Housing Element.
C. That pursuant to Housing Element Program 1.1(b) and 1.1(f), the City is
proposing an overlay zone ("overlay district") for the Enderle Center,
Housing Element Site 17 ("Project Site"). Residential uses are currently
not allowed on the Project Site. Upon approval of the Proposed Project,
the Project Site could accommodate 413 units over approximately 7 acres
of developable land within the existing 11.8-acre site. The anticipated
development over 7 acres may take place on underutilized asphalt parking
lot areas, and not require demolition of any existing buildings. Parking
displaced as a result of redevelopment would be accommodated by
vertical parking structures located within the proposed development.
D. That pursuant to Housing Element Program 1.1(g), General Plan
Amendment 2024-0001, Code Amendment 2024-0003, and Zone Change
2024-0002 were initiated by the City to allow residential use by right for
housing developments in which at least 20 percent of the units are
affordable to lower income households pursuant to Government Code
Section 65583.2 provisions and would to be consistent with State housing
law.
E. That the City proposes the following actions ("Proposed Project"):
Resolution 24-77
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• GPA 2024-0001 — A request for a General Plan Amendment (GPA)
to establish that higher density residential uses are allowed in the
Planned Community Commercial/Business (PCCB) land use
designation when prescribed by a Housing Overlay (HO) or a
Specific Plan (SP);
• CA 2024-0003 — A request to establish a Housing Overlay (HO)
District (overlay zone) in conjunction with the Planned Community
Commercial District (base zone); and
• ZC 2024-0001 — A request to amend the City's zoning map to apply
the Housing Overlay (HO) District to the Project Site.
F. That GPA 2024-0001, CA 2024-0003, and ZC 2024-0001 constitutes a
"project" that is subject to the terms of the California Environmental Quality
Act ("CEQA") (Pub. Resources Code §21000 et. seq.).
G. That pursuant to the California Environmental Quality Act (CEQA) (Public
Resources Code Section 21000 et seq.), the City of Tustin, as lead agency,
determined that an Environmental Impact Report (EIR) should be prepared
to analyze all potential adverse environmental impacts of the Project and
corresponding General Plan Amendment, Code Amendment, and zone
change, which together are referred to as the "Proposed Project"; and
H. That the City sent a Notice of Preparation (NOP) of a Draft EIR to the
Office of Planning and Research, responsible and trustee agencies, and
other interested parties on or about February 15, 2024; and
That the NOP was circulated for 30 days pursuant to State CEQA
Guidelines sections 15082 and 15083, until March 18, 2024, to invite
comments from responsible and trustee agencies, the public, and other
interested parties regarding the scope of the EIR; and
J. That the City received written comments in response to the NOP, which
assisted the City in the scope and analysis for the Draft EIR, and also held
a series of public meetings and workshops regarding the scope of the
Proposed Project; and
K. That the City received four (4) responses/comments from interested
parties and responsible and trustee agencies in response to the NOP; and
L. That on June 6, 2024, the City initiated the 45-day public review period on
the Draft EIR by filing a Notice of Availability with the State Office of
Resolution 24-77
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Docusign Envelope ID: 84DE734F-1604-46B3-8E5C-03CD38415370
Planning and Research, publishing the Notice in the Tustin News, and
releasing the Draft EIR (State Clearinghouse [SCH] No. 2024020747) for
public review and comment; and
M. That pursuant to State CEQA Guidelines, Section 15086, the City
consulted with and requested comments from all responsible and trustee
agencies, other regulatory agencies, and other interested parties during
the 45-day comment period, which ran from June 7, 2024 to July 22, 2024;
and
N. That during the public review period, copies of the Draft EIR were
provided online on the City's website, were available for public review in
printed form at City Hall and the Tustin Library; and
O. That the City received written comments on the Draft EIR during the public
review period for the Draft EIR.
P. That following the close of the public comment period and after review of
the comments received on the Draft EIR, the City prepared a Final EIR,
consisting of comments received on the Draft EIR, written responses to
those comments, and revisions and errata to the Draft EIR. For purposes
of this Resolution, the EIR shall refer to the Draft EIR, including all
technical studies and appendices to the Draft EIR, as revised by the Final
EIR's errata section, together with the other sections of the Final EIR,
including all the technical studies and appendices to the Final EIR, and the
Errata to the Final EIR. The Draft EIR, the Final EIR, and all technical
studies and appendices to the Final EIR are hereby incorporated herein by
reference to this Resolution and are on file with the City Clerk. The Errata
to the Final EIR, which is attached hereto as Exhibit A and incorporated
herein, reflects changes made to mitigation measures and text within the
EIR sections.
Q. That the Findings of Fact and Statement of Overriding Considerations,
attached hereto as Exhibit C, and incorporated herein, set forth the
environmental impacts identified in the Final EIR that the City finds are
less than significant and do not require mitigation, the environmental
impacts identified in the Final EIR as potentially significant but which the
City finds can be mitigated to a less than significant level through the
implementation of all feasible mitigation measures, the environmental
impacts identified in the Final EIR as potentially significant but which the
City finds cannot be fully mitigated to a less than significant level despite
the imposition of all feasible mitigation measures, the cumulative
environmental impacts resulting from the Proposed Project, the significant
and irreversible environmental changes that would result from the
Proposed Project, but which would be mitigated, the existence of any
Resolution 24-77
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growth -inducing impacts resulting from the Proposed Project identified in
the Final EIR, and a statement supporting the Proposed Project
notwithstanding the potentially significant environmental impacts which
could not feasibly be mitigated.
R. That alternatives to the Proposed Project that might eliminate or reduce
significant environmental impacts are described in Exhibit C, Statement of
Overriding Considerations, pursuant to CEQA, attached hereto and
incorporated herein by this reference.
S. That the City has endeavored in good faith to set forth the basis for its
decision on the Proposed Project in the Findings of Fact as well as to
explain why the benefits of the Proposed Project outweigh the
environmental impacts the EIR determines are significant and
unavoidable.
T. That all of the requirements of CEQA and the State CEQA Guidelines
have been satisfied by the City of Tustin in the EIR, which is sufficiently
detailed so that all of the potentially significant environmental effects of the
Proposed Project have been adequately evaluated; and
U. That the EIR prepared in connection with the Proposed Project sufficiently
analyzes both the feasible mitigation measures necessary to avoid or
substantially lessen the Proposed Project's potential environmental
impacts and a range of feasible alternatives capable of eliminating or
reducing these effects in accordance with CEQA and the State CEQA
Guidelines; and
V. That a public hearing was duly called, noticed, and held on said
application on September 24, 2024, by the Planning Commission. At that
time, the Planning Commission continued the public hearing to October 8,
2024; and
W. The Planning Commission called, noticed, and held a public hearing on
said application on October 8, 2024, and recommended City Council
approval of this Resolution; and
X. That a public hearing was duly called, noticed and held by the Tustin City
Council on November 19, 2024, by the Tustin City Council. At that time,
the City Council continued the public hearing to a future date; and
Y. The City Council called, noticed, and held a public hearing on said
application on December 17, 2024; and
Resolution 24-77
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Docusign Envelope ID: 84DE734F-1604-46B3-8E5C-03CD38415370
Z. That on December 17, 2024, the City Council was presented with,
reviewed, and considered all the information and data in the administrative
record, including the Final EIR, and all oral and written evidence
presented to it during all meetings and hearings, all of which are
incorporated herein by reference; and
AA. That the City has not received any comments or additional information that
produced substantial new information requiring recirculation or additional
environmental review under Public Resources Code Sections 21166 and
21092.1 or State CEQA Guidelines Section 15088.5; and
BB. That all other legal prerequisites to the adoption of the Resolution have
occurred.
II. The Proposed Project would have significant and unavoidable impacts related to
the following environmental issue areas: air quality and greenhouse gas
emissions.
III. Findings of Fact and Statement of Overriding Considerations. In accordance with
State CEQA Guidelines Sections 15091, 15092, and 15093, the Planning
Commission recommends the Tustin City Council adopt the CEQA Findings of
Fact and the Statement of Overriding Considerations pursuant to CEQA,
attached hereto as Exhibit C, and incorporated herein by reference as is fully set
forth herein.
IV. Certification of Final EIR. In accordance with State CEQA Guidelines Section
15090, the Planning Commission recommends the Tustin City Council certify
that:
• The Final EIR is an accurate and objective statement that has been
completed in compliance with CEQA and the State CEQA Guidelines, and
that together with the errata, attached hereto as Exhibit A and incorporated
herein by reference as is fully set forth herein, includes all the
environmental impacts of the Proposed Project and mitigation measures;
• The Planning Commission and City Council have been presented with and
have reviewed and considered the information contained in the EIR, prior to
the Tustin City Council approving the Proposed Project; and
• The EIR reflects the City Council's independent judgment and analysis.
V. Recirculation Not Required. The Planning Commission recommends that the
Tustin City Council declare that the City has not received evidence of new
significant impacts, as defined by the State CEQA Guidelines, Section 15088.5,
after circulation of the Draft EIR that would require recirculation, which is further
Resolution 24-77
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Docusign Envelope ID: 84DE734F-1604-46B3-8E5C-03CD38415370
set forth in the Findings (Exhibit C), nor have any of the conditions requiring a
subsequent or supplemental EIR listed in Public Resources Code Section 21166
occurred.
VI. Notice of Determination. The Planning Commission recommends that the Tustin
City Council direct staff to file a Notice of Determination with the Orange County
Clerk Recorder within five (5) working days of final approval of the Proposed
Project.
If any section, subsection, subdivision, sentence, clause, phrase, or portion of
this Resolution is for any reason held to be invalid or unconstitutional by the
decision of any court of competent jurisdiction, then such decision shall not affect
the validity of the remaining portions of this Resolution. The Planning
Commission of the City of Tustin hereby declares that the Planning Commission
would have adopted this Resolution, and each section, subsection, subdivision,
sentence, clause, phrase, or portion thereof, irrespective of the fact that anyone
or more sections, subsections, subdivisions, sentences, clauses, phrases, or
portions thereof be declared unconstitutional, invalid, or ineffective.
PASSED AND ADOPTED at a regular meeting of the Tustin City Council held on the
17t" day of December, 2024.
ATTEST:
DS
Signed by:
fVi(A
a.Su
ER'°14.04ASU DA,
City Clerk
APPROVED AS TO FORM:
�DocuSigned by:
�.':A�k'd'
DA" D$EERFEN'DIG,
City Attorney
Signed by:
AU !'WLEWBARD,
Mayor
Resolution 24-77
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Docusign Envelope ID: 84DE734F-1604-46B3-8E5C-03CD38415370
STATE OF CALIFORNIA
COUNTY OF ORANGE
CITY OF TUSTIN
CERTIFICATION FOR RESOLUTION NO. 24-77
I, Erica N. Yasuda, City Clerk and ex-officio Clerk of the City Council of the City of Tustin,
California, do hereby certify that the whole number of the members of the City Council of
the City of Tustin is five; that the above and foregoing Resolution No. 24-77 was duly
passed and adopted at a regular meeting of the Tustin City Council, held on the 17t" day of
December, 2024, by the following vote:
COUNCILMEMBER AYES: Nielsen, Gallagher, Schnell, Fink (4)
COUNCILMEMBER NOES: (0)
COUNCILMEMBER ABSTAINED: (0)
COUNCILMEMBER ABSENT: (0)
COUNCILMEMBER RECUSED: Lumbard (1)
DS
�Signed by:
f-n(A. UO'st' J,a
ERIGADW4Y SUDA,
City Clerk
Exhibits:
A. Final Environmental Impact Report (FEIR) — Enderle Center
B. Draft Environmental Impact Report (DEIR) — Enderle Center
C. Findings of Fact and Statement of Overriding Considerations for Final
Environmental Impact Report — Enderle Center
Resolution 24-77
Page 7 of 7
EXHIBIT A
THE ENDERLE CENTER REZONE
PROJECT
SCH NO. 2024020747
prepared for
City of Tustin
300 Centennial Way
Tustin, CA 92780
prepared with the assistance of
EIRD Solutions Inc.,
Irvine, CA 92612
(949) 794-1180
4
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Mir
A A7 T-77
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aim
September 2024,�.. j
Final Environmental
!7- t rt
Impact R
&Tt
E P
SOLUTIONS,INC
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E I P I D SOLUTIONS,INC
3333 Michelson Drive, Suite 500
Irvine, CA 92612
(949) 794-1 180
www.epdsolutions.com
Enderle Center Rezone
Table of Contents
Table of Contents
1. Introduction................................................................................................................................................ 1 -1
2. Errata......................................................................................................................................................... 2-1
3. Response to Comments............................................................................................................................ 3-1
4. Mitigation Monitoring and Reporting Program..................................................................................4-1
Tables
TABLE 3-1 : COMMENTS RECEIVED ON THE DEIR................................................................................................................3-1
TABLE 4-1 : MITIGATION MONITORING AND REPORTING PROGRAM................................................................................4-3
City of Tustin
Final EIR
September 2024
Enderle Center Rezone Project Table of Contents
This page intentionally left blank.
City of Tustin
Final EIR
September 2024
Enderle Center Rezone Project 1.0 Introduction
1. Introduction
This Final Environmental Impact Report (Final EIR) has been prepared in conformance with the environmental
policy guidelines for the implementation of the California Environmental Quality Act (CEQA) to evaluate the
environmental effects that may result from construction and operation of the proposed Enderle Center Rezone
Project (proposed Project).
According to CEQA Guidelines Section 15132, the Final EIR shall consist of:
(a) The Draft Environmental Impact Report (Draft EIR) or a revision of the Draft EIR;
(b) Comments and recommendations received on the Draft EIR, either verbatim or in summary;
(c) A list of persons, organizations, and public agencies commenting on the Draft EIR;
(d) The responses of the lead agency to significant environmental points raised in the review and consultation
process;
(e) Any other information added by the lead agency.
This document contains responses to comments received on the Draft EIR during the public review period,
which began June 7, 2024, and ended on July 22, 2024. This document has been prepared in accordance
with CEQA, the State CEQA Guidelines, and represents the independent judgment of the lead agency, which
is the City of Tustin. This document and the circulated Draft EIR comprise the Final EIR in accordance with
CEQA Guidelines, Section 15132.
FORMAT OF THE FINAL EIR
The following chapters are contained within this document:
Chapter 1.0, Introduction. This chapter describes CEQA requirements and the content of the Final EIR.
Chapter 2.0, Errata. This chapter contains revisions made to the Draft EIR as a result of the comments received
by agencies and organizations as described in Chapter 2.0, and/or errors and omissions discovered since
release of the Draft EIR for public review.
The City of Tustin has determined that none of this material constitutes significant new information that
requires recirculation of the Draft EIR for further public comment under CEQA Guidelines Section 15088.5.
The additional material clarifies existing information prepared in the Draft EIR and does not present any
new substantive information. None of this new material indicates that the Project would result in a significant
new environmental impact not previously disclosed in the Draft EIR. Additionally, none of this material
indicates that there would be a substantial increase in the severity of a previously identified environmental
impact that would not be mitigated, or that there would be any of the other circumstances requiring
recirculation described in Section 15088.5.
Chapter 3.0, Response to Comments. This chapter provides a list of agencies and organizations who
commented on the Draft EIR, as well as copies of their comment letters received during and following the
public review period, and individual responses to their comments.
Chapter 4.0, Mitigation, Monitoring, and Reporting Program. This chapter includes the Mitigation
Monitoring and Reporting Program (MMRP). CEQA requires lead agencies to "adopt a reporting and
mitigation monitoring program for the changes to the project which it has adopted or made a condition of
project approval in order to mitigate or avoid significant effects on the environment" (CEQA Section
City of Tustin 1 -1
Final EIR
September 2024
Enderle Center Rezone Proiect 1.0 Introduction
21081.6, CEQA Guidelines Section 15097). The MMRP was prepared based on the mitigation measures
included in the Draft EIR with revisions from this Final EIR, as needed.
1.2 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES
CEQA Guidelines Section I5204(a) outlines parameters for submitting comments and reminds persons and
public agencies that the focus of review and comment of Draft EIRs should be "on the sufficiency of the
document in identifying and analyzing the possible impacts on the environment and ways in which the significant
effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional
specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant
environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined
in terms of what is reasonably feasible ... CEQA does not require a lead agency to conduct every test or perform
all research, study, and experimentation recommended or demanded by commenters. When responding to
comments, lead agencies need only respond to significant environmental issues and do not need to provide all
information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR."
CEQA Guidelines Section 15204(c) further advises, "Reviewers should explain the basis for their comments,
and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion
supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered
significant in the absence of substantial evidence." Section 15204 (d) also states, "Each responsible agency and
trustee agency shall focus its comments on environmental information germane to that agency's statutory
responsibility." Section 15204 (e) states, "This section shall not be used to restrict the ability of reviewers to
comment on the general adequacy of a document or of the lead agency to reject comments not focused as
recommended by this section."
In accordance with CEQA, Public Resources Code (PRC) Section 21092.5, copies of the written responses to
public agencies are being forwarded to those agencies at least 10 days prior to certification of the Final
EIR, with copies of this Final EIR document, which conforms to the legal standards established for response to
comments on the Draft EIR pursuant to CEQA.
City of Tustin 1-2
Final EIR
September 2024
Enderle Center Rezone Project 2.0 Errata
2. Errata
2.1 INTRODUCTION
As provided in Section 15088(c) of the CEQA Guidelines, responses to comments may take the form of a
revision to a Draft EIR or may be a separate section in the Final EIR. This section complies with the latter
option and provides changes to the Draft EIR in this chapter shown as strikethrough text (i.e., strik g„)
signifying deletions and red underlined text (i.e., underline) signifying additions. These changes are meant
to provide clarification, corrections, or minor revisions made to the Draft EIR initiated by the Lead Agency,
City of Tustin, reviewing agencies, the public, and/or consultants based on their review. Text changes are
presented in the section and page order in which they appear in the Draft EIR. None of the corrections or
additions constitutes significant new information or substantial project changes that, in accordance with CEQA
Guidelines Section 15088.5, would trigger the need to recirculate portions or all of the Draft EIR.
2.2 CHANGES TO THE DRAFT ENVIRONMENTAL IMPACT REPORT
2.2.1 Section 1 Executive Summary
Location: Section 1.6, Summary of Impacts, pp. 1-5
Explanation for Change and Discussion:
The Draft EIR erroneously left Mitigation Measure AQ-1 out of Table 1-1, Summary of Impacts, in Draft EIR
Section 1, Executive Summary. Additionally, the level of significance before mitigation and after mitigation
has been revised from "less than significant" to "significant and unavoidable". The Draft EIR has been
updated accordingly.
Changes to the Draft EIR:
Impact
Applicable
Level of
Mitigation
Level of
Standard Condition,
Significance Before
Measures
Significance After
Plan, Program, or
Mitigation
Mitigation
Policy (PPP), or
Project Design
Feature (PDF)
5.1 Air Quality
Impact AQ-3:
PPP AQ-1: Rule
Les5 then Signifieein
Mitigation Measure
Less then SignifiEent
AQ-1. Prior to
Would the Project
403. As listed above.
Potentially
Significant and
Unavoidable
expose sensitive
receptors to
substantial pollutant
PPP AQ-2: Rule
1 113. The Project is
Significant
building permit
approval by the
City of Tustin (City)
for future
concentrations?
required to comply
with the provisions
of South Coast Air
development
projects, project
Quality
Management District
applicants shall
prepare and submit
Rule (SCAQMD) Rule
a technical
1 1 1 3. Only "Low-
Volatile Organic
Compounds" paints
assessment
evaluating
potential project -
(no more than 50
related air quality
gram liter of VOC)
City of Tustin 2-1
Final EIR
September 2024
Enderle Center Rezone Project 2.0 Errata
and/or High
impacts, including
a localized impacts
Pressure Low
analysis, to the City
Volume (HPLV)
for review and
applications shall be
used.
approval. The
analysis shall be
prepared in
conformance with
South Coast Air
Quality
Management
District (SCAQMD)
methodology. If
project -related
emissions exceed
applicable
SCAQMD
thresholds of
significance, the
City shall require
that applicants for
new development
projects incorporate
mitigation
measures to reduce
emissions. The
identified measures
shall be included
as part of the
conditions of
approval.
Additionally, if
project -related
localized emissions
exceed the
SCAQMD's
thresholds, a
dispersion
modeling analysis
shall be conducted
to calculate
potential health risk
from project
implementation,
and all necessary
mitigation
measures shall be
implemented.
Cumulative
PPP AQ-1: Rule
Less thein Signifieeint
PIene-required
Less then Signif
403. As listed
Potentially
Mitigation Measure
Significant and
AQ-1. As listed
Unavoidable
above.
Significant
above.
PPP AQ-2: Rule
1113. As listed
above.
PPP-AQ-3: Rule
402. As listed
above.
City of Tustin 2-2
Final EIR
September 2024
Enderle Center Rezone Proiect 2.0 Errata
2.2.2 Section 5.1 Air Quality
Location: Section 5.1.7, Cumulative Impacts, pp. 5.1-30
Explanation for Change and Discussion:
The Draft EIR contained an error regarding the labeling of a Mitigation Measure. The Draft EIR labeled
Mitigation Measure AQ-1 as AIR- 1, rather than AQ-1. This error is repeated throughout the section and is
also updated accordingly.
Changes to Draft EIR:
As discussed in Impact AQ-3 the Project would not result in an exceedance of the SCAQMD LSTs during
project construction. However, net new emissions associated with the future development of the proposed
Project would exceed the SCAQMD LSTs for PM10 during operational activities. While Mitigation Measure
AIRI AO-1 would serve to reduce localized emissions associated with buildout of the project, localized
emission impacts would remain significant and unavoidable. Therefore, impacts on human health risks would
be cumulatively considerable and would be significant and unavoidable.
This error is repeated, and updated by reference, on Draft EIR page 5.10-31.
Location: Section 5.1.8, Existing Regulations and Plans, Programs, or Policies, pp. 5.1-31
Explanation for Change and Discussion:
The Draft EIR contained an error regarding the labeling of an existing Plan, Program, or Policy. The Draft
EIR labeled the third listed PPP as PPP AQ-4 rather than PPP AQ-3. This PPP has been updated accordingly.
Changes to Draft EIR:
PPP AQ-43: Rule 402. The Project is required to comply with the provisions of South Coast Air Quality
Management District (SCAQMD) Rule 402. The Project shall not discharge from any source whatsoever such
quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any
considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of
any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to
business or property.
2.2.3 Section 5.3 Greenhouse Gas Emissions
Location: Section 5.3.7, Cumulative Impacts, pp. 5.3-15
Explanation for Change and Discussion:
The Draft EIR contained an error regarding the cumulative impact analysis which noted that the "Project
would not exceed the SCAQMD threshold.."; however, as discussed in the analysis predicating the cumulative
impact analysis, the Project would result in an exceedance for the SCAQMD threshold. This statement has
been updated accordingly.
Changes to Draft EIR:
As previously stated, GHG emissions associated with the potential future buildout under the Project would
net --exceed the SCAQMD threshold of 3,000 MT CO2e/yr. Since GHG is a global issue, it is unlikely that
the proposed Project would generate enough GHG emissions to influence GHG emissions on its own;
however, because project -related CO2e emissions would exceed the SCAQMD's threshold, the proposed
Project would have a significant contribution to cumulatively considerable GHG emission impacts.
City of Tustin 2-3
Final EIR
September 2024
Enderle Center Rezone Proiect 2.0 Errata
Location: Section 5.3.10, Mitigation Measures, pp. 5.3-16
Explanation for Change and Discussion:
The Draft EIR contained Mitigation Measure GHG-1, which identified that only projects with discretionary
approval would require a technical assessment evaluating potential project -related GHG impacts. However,
the mitigation measure has been revised to increase clarity for future applicants on specific actions and
performance standards. In revising the measure for clarity, it was broken up into two separate measures to
reflect the requirement for GHG-reduction mitigation, in addition to the need for future projects with
additional discretionary actions to prepare a separate GHG assessment with project -specific measures.
Changes to Draft EIR:
Mitigation Measure GHG-1: PFier �e building pemiit appFeyel by the City ef Tustin (City) fer future
she" be prepaFed In cenferngeince with South Coast Air Quality Management District (SCAQMD�
ei-1 ier Statewide GHGreduction teirg ._� Prior to issuance of a building permit, the City shall require that
applicants for new residential development projects incorporate mitigation measures to reduce GHG
emissions. ,
The identified measures shall be included as part of the project's approval. Possible mitigation measures
to reduce operational emissions could include, but are not limited to, the following
• Increase in insulation such that heat transfer and thermal bridging is minimized;
• Limit air leakage through the structure and/or within the heating and cooling distribution system;
• Use of energy -efficient space heating and cooling equipment;
• Installation of dual -paned or other energy efficient windows;
• Use of interior and exterior energy efficient lighting that exceeds the incumbent California Title 24
Energy Efficiency performance standards;
• Installation of automatic devices to turn off lights where they are not needed;
• Application of an exterior paint and surface color palette that emphasizes light and off-white colors
that reflect heat away from buildings;
• Design of buildings with "cool roofs" using products certified by the Cool Roof Rating Council,
and/or exposed roof surfaces using light and off-white colors;
• Design of buildings to accommodate photo -voltaic solar electricity systems or the installation of
photo -voltaic solar electricity systems;
• Installation of ENERGY STAR -qualified energy -efficient appliances, heating and cooling systems,
office equipment, and/or lighting products.
• Landscaping palette emphasizing drought tolerant plants;
• Use of water -efficient irrigation techniques;
• U.S. EPA Certified WaterSense-labeled or equivalent faucets, high -efficiency toilets MEN, and
water -conserving shower heads.
Mitiaation Measure GHG-2: Prior to discretionary approval by the Citv of Tustin (City) for residential
development projects subject to California Environmental Quality Act (CEQA) review, project applicants
shall prepare and submit a technical assessment evaluating potential project -related greenhouse gas
(GHG) impacts to the City for review and approval. The evaluation shall be prepared in conformance
with South Coast Air Quality Management District (SCAQMD) methodology. If project -related GHG
City of Tustin 2-4
Final EIR
September 2024
Enderle Center Rezone Project 2.0 Errata
emissions exceed applicable SCAQMD thresholds of significance and/or Statewide GHG reduction
targets, project -specific measures shall be identified and implemented, which would be reviewed and
confirmed by the City.
2.2.4 Section 5.9 Transportation
Location: Section 5.9.3.2, Existing Transit Service, page 5.9-6
Explanation for Change and Discussion:
In response to Comment 3.2, the commenter states that Section 5.9.3.2, Existing Transit Service (DEIR page
5.9-6), erroneously included OCTA bus routes 61, 65, 75, and 463 as routes that serve the City. Additionally,
the comment states that the section left out bus routes 59, 64, 70, 72, 79, 90, 167, 472, and 473 which do
serve the City. The discussion has been revised to remove the bus routes that do not serve the City and include
the additional bus routes which do serve the City.
Changes to DEIR:
Public transit bus service for the City is provided by the Orange County Transportation Authority (OCTA).
The established network includes Routes 59,60, &�-, 64, 65-, 66, 70, 71, 72, 7-5-, 79, 90, 167, 472, and 46-3
473. The Project is not located within a Transit Priority Area (TPA); however, adjacent to the Project at the
junction of 17th Street and Enderle Center Drive, there are two existing public transit bus stations served by
Route 60 with bus service every 30 minutes. These stations are situated on both the northern side of 17th
Street and Yorba Street and on the southern side of 17th Street and Enderle Center Drive. The major routes
of travel for Route 60 include Larwin Square to Long Beach via Newport and Seventeenth. Route 60 operates
on approximately 30-minute headways on weekdays and weekends and connects to the Newport
Transportation Center.
2.2.5 Section 5.10 Tribal Cultural Resources
Location: Section 5.10.8, Existing Regulations and Plans, Programs, or Policies, pp. 5.10-7
Explanation for Change and Discussion:
Policy measure, PPP CUL-1, was included to outline the regulatory requirements to be implemented in the
event that human remains are found during future project construction. The measures has been slightly revised
to provide clarity and reflect the latest regulatory process.
Changes to DEIR:
PPP CUL-1: Human Remains. Should human remains or funerary objects be discovered during Project
construction, the Project would be required to comply with State Health and Safety Code Section 7050.5,
which states that no further disturbance may occur in the vicinity of the body (within a 100-foot buffer of the
find) until the County Coroner has made a determination of origin and disposition pursuant to Public Resources
Code Section 5097.98. The County Coroner must be notified of the find immediately. If the remains are
determined to be prehistoric, the Coroner will notify the Native American Heritage Commission by
telephone within 24 hours, which will determine the identity of and notify a Most Likely Descendant (MLD).
With the permission of the landowner or his/her authorized representative, the MLD may inspect the site of
the discovery. The MLD must complete the inspection and make recommendations or preferences for
treatment within 48 hours ef netefleateen by the NAHG after beina aranted access to the site.
Location: 5.10.11, Mitigation Measures pp. 5.10-7
Explanation for Change and Discussion:
City of Tustin 2-5
Final EIR
September 2024
Enderle Center Rezone
2.0 Errata
Mitigation Measure TCR-1 outlines the agreement framework between applicants and/or developers and
Native American Monitors regarding ground -disturbing activities of future potential projects. The measure
has been slightly revised to provide additional clarification on when a qualified archaeologist may be
retained for monitoring of tribal cultural resources and the type of activities exempt from future monitoring.
Changes to Draft EIR:
TCR-1: Retain a Native American Monitor Prior to Commencement of Ground -Disturbing Activities
a. Prior to the issuance of demolition or grading permits for any projects that would disturb previously
undisturbed soils (native soils) or soils that have native fill, the project applicant/developer shall retain
a Native American Monitor, with first preference given to the Gabrieleno Band of Mission Indians — Kizh
Nation, who responded to the City's request for consultation on November 14, 2023 (first preference
Tribe, Tribe). The applicant/developer shall allow 45 days from the initial contact with the first
preference tribe to enter into a contract for monitoring services. If the applicant/developer is unable to
contact the Kizh Nation after three documented attempts or is unable to secure an agreement, the
applicant shall report to the lead agency, and the lead agency will contact the Kizh Nation to validate
that the parties were unable to enter into an agreement. The ~~~"cent/deyeleper she" h_ye Fn_ ,
three decumented attempts te directly eenieet the Kh-h Nefien te enter inte e tribal menitering
agreement. If the applicant/developer can demonstrate they were unable to secure an agreement with
the first preference tribe, as validated and documented by the Community Development Department in
writing, or if the contracted tribe fails to fulfill its obligation under the contract terms, then the
applicant/developer may retain an alternative qualified tribal monitor from a culturally affiliated tribe,
or if none are available, an otherwise qualified archaeologist may be retained as if -approved by
the City.
The monitor shall be retained prior to the issuance of a demolition permit or grading permit, and the
commencement of any development related "ground -disturbing activity" for the subject project at all
project locations (i.e., both on -site and any off -site locations that are included in the project
description/definition and/or required in connection with the project, such as public improvement work).
"Ground -disturbing activity" shall include, but is not limited to, demolition, pavement removal, auguring,
grubbing, boring, grading, excavation, drilling, and trenching for the purposes of reconstruction and new
development. "Ground -disturbing activity" shall not include miner removal or maintenance of existing
small facilities and utilities 'zrciiiities such as potholing, tree removal, and parking lot maintenance. This
mitigation measure does not apply to IsFejeets activities that would only disturb soils made up of artificial
fill, as verified by a soils or geotechnical report.
b. A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the
commencement of any ground -disturbing activity, or the issuance of any permit necessary to commence
a ground -disturbing activity.
c. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground -
disturbing activities, the type of construction activities performed, locations of ground -disturbing
activities, soil types, and cultural -related materials, and any etheF facts, renditions, mateFieils, or
disceye of significance to the Kizh Nation. Monitor logs will identify and describe any discovered
TCRs, h9eluding but not limited , Native American cultural and historical artifacts, remains, places of
significance, etc., (collectively, tribal cultural resources, or "TCR"), as well as any discovered Native
American (ancestral) human remains and burial associated grave goods. Copies of monitor logs will be
provided to the project applicant/lead agency upon written request to the consulting tribe. If a monitor
is selected from a tribe other than the Kizh Nation, the Kizh Nation shall be contacted if any discoveries
are found.
d. On -site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the
censulting tribe monitor from a designated point of contact for the project applicant/lead agency that
all ground -disturbing activities and phases that may involve ground -disturbing activities and that have
City of Tustin 2-6
Final EIR
September 2024
Enderle Center Rezone Project 2.0 Errata
the potential to impact local TCRs on the project site or in connection with the project are complete
(2) the monitor determines based on field observations that there is no likelihood of encountering
intact TCRs. Monitoring may be reduced in extent or frequency as determined appropriate by the
monitor.
Location: 5.10.11, Mitigation Measures pp. 5.10-8
Explanation for Change and Discussion:
Mitigation Measure TCR-2 outlines the process that applicants and/or developers shall take in the event of
an unanticipated discovery of a TCR during ground -disturbing activities of future potential projects. The
measure has been slightly revised to provide additional clarification on the responsibilities of various entities
in the notification and decision -making process related to discovered TCRs.
Changes to Draft EIR:
TCR-2: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/Non-Ceremonial)
A, Upon discovery of any TCRs, all c-n en ground -disturbing activities in the immediate vicinity of the
discovery shall cease (i.e., net less `hen the surrounding 50 feet) and shall not resume until the discovered
TCR has been44iy assessed by the tribal monitor and consulting archaeologist. If the censulting tribe monitor
is other than the Gabrieleno Band of Mission Indians — Kizh Nation, the Kizh Nation shall be contacted and
the consulting tribe monitor and/or Kizh Nation will recover and retain all discovered TCRs in the form
and/or manner the 'viz" Nation deemeds appropriate, in the agreement with Kizh Nation sele discFetier
and c__ any e the K"" Natien `,,., rns appropriate, including for educational, cultural and/or historic
purposes.
Location: 5.10.11, Mitigation Measures pp. 5.10-8
Explanation for Change and Discussion:
Mitigation Measure TCR-3 outlines the process that applicants and/or developers shall take in the event of
an unanticipated discovery of human remains and associated funerary or ceremonial objects during ground -
disturbing activities of future potential projects. The measure has been slightly revised to provide additional
clarification regarding the latest regulatory language under PRC 5097.98 and Health and Safety Code
Section 7050.5.
Changes to Draft EIR:
TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects
a. Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and
in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods
in Public Resources Code Section 5097.98, are also to be treated according to this statute.
b. If Native American human remains are discovered or recognized on the project
site, then Public: D,...,.......e /-',.d 5097.9 as well ar, Health and Safety Code Section 7050.5 shall be
followed.
c. Human remains and associated gravefburia' goods shall be treated alike -in the same manner per
California Public Resources Code section 5097.98(d)(1) and (2).
d. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human
remains and/or i rg ave goods.
e. Any discovery of human remains/il rg ave goods shall be kept confidential to prevent further
disturbance.
City of Tustin 2-7
Final EIR
September 2024
Enderle Center Rezone
2.0 Errata
2.2.6 Section 5.11 Utilities and Service Systems
Location: Section 5.1 1.3.9, Wastewater Mitigation Measures, pp. 5.1 1-16
Explanation for Change and Discussion:
In Response to Comment 1.2, the commenter requests Mitigation Measure UT-2 be revised to require future
project sewer capacity analyses to also be reviewed and approved by Orange County Sanitation District
(OC San). The Mitigation Measure has been revised accordingly to add OC San as a reviewer and approval
body.
Changes to DEIR:
MM UT-2 Future proposed Projects shall prepare capacity analyses of existing sewer utilities in the
area to ensure conveyance and pressure is adequate for future projects proposed. The
developer shall then identify infrastructure improvements necessary for the proposed
development. The developer will be responsible for preparing a capacity analysis in
coordination with the EOCWD and the City. The developer shall then submit the sewer
capacity analysis to the Orange County Sanitation District (OC San) for review and
verification that there is available sewer capacity. The capacity analysis and infrastructure
improvements shall be reviewed and approved by EOCWD, OC San, and the City prior to
approval of the construction permit.
2.2.7 Section 7.0 Effects Not Found Significant
Location: 7.3, Biological Resources, pp. 7-4
Explanation for Change and Discussion:
The Initial Study (Appendix A of the Draft Environmental Impact Report [DEIR]) identified that the Project
would result in less than significant impacts with mitigation on biological resources, as summarized in Chapter
7, Effects Found Not Significant. Mitigation Measure 13I0-1 has been revised to reflect the correct City
department responsible for verification of retention of a qualified biologist for vegetation and tree removal
actives.
Changes to Draft EIR:
PPP 13I0-1 Street Trees. Installation of street trees shall occur in compliance with the City of Tustin
Municipal Code Article 7, Chapter 3, Section 7308.
MM 13I0-1 Migratory Bird Treaty Act. Prior to commencement of grading activities, the City 1g
9iy+sien Community Development Department shall verify that, in the event that vegetation
and tree removal activities occur within the active breeding season for birds (February 1—
September 15), the Project applicant (or their Construction Contractor) shall retain a
qualified biologist (meaning a professional biologist that is familiar with local birds and
their nesting behaviors) to conduct a nesting bird survey no more than 3 days prior to
commencement of construction activities.
The nesting survey shall include the Project site and areas immediately adjacent to the site
that could potentially be affected by Project -related construction activities, such as noise,
human activity, and dust, etc. If active nesting of birds is observed within 100 feet of the
designated construction area prior to construction, the qualified biologist shall establish an
appropriate buffer around the active nests (e.g., as much as 500 feet for raptors and 300
City of Tustin 2-8
Final EIR
September 2024
Enderle Center Rezone
2.0 Errata
feet for non -raptors [subject to the recommendations of the qualified biologist]), and the
buffer areas shall be avoided until the nests are no longer occupied and the juvenile birds
can survive independently from the nests.
Location: 7.4, Cultural Resources, pp. 7-4
Explanation for Change and Discussion:
The Initial Study (Appendix A of the DEIR) identified that the Project would result in less than significant
impacts with mitigation on cultural resources, as summarized in Chapter 7, Effects Found Not Significant.
Existing plans and policies that would avoid potential impacts were also included. As discussed above, PRC
5097.98 requires the most likely descendant (MLD) must complete the inspection of the remains within 48
hours of obtaining access to the site. The PPP CUL-1 has been updated to reflect this accordingly.
Changes to Draft EIR:
See changes to PPP CUL-1: Human Remains above under Section 5.10 Tribal Cultural Resources.
City of Tustin 2-9
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
3. Response to Comments
This section of the Final Environmental Impact Report (FEIR; Final EIR) for the Enderle Center Rezone Project
(Project) includes a copy of all comment letters that were submitted during the public review period for the
Draft Environmental Impact Report (DEIR), along with responses to comments in accordance with California
Environmental Quality Act (CEQA) Guidelines Section 15088. The 45-day review period for the DEIR began
on June 7, 2024, and ended on July 22, 2024. A total of three comment letters were received in response
to the DEIR during the 45-day public review period, and one comment letter was received after the close of
the public review period.
The responses amplify or clarify information provided in the DEIR and/or refer the reader to the appropriate
place in the document where the requested information can be found. Comments that are not directly related
to environmental issues (e.g., opinions on the merits of the Project unrelated to its environmental impacts) are
noted for the record. Where text changes in the DEIR are warranted based on comments received, updated
Project information, or other information provided by City staff, those changes are noted in the response to
comment and the reader is directed to Chapter 2.0, Errata, of this FEIR.
These changes to the analysis contained in the DEIR represent only minor clarifications/amplifications and do
not constitute significant new information. In accordance with CEQA Guidelines Section 15088.5, recirculation
of the DEIR is not required.
All written comments received on the DEIR are listed in Table 3-1. All comment letters received on the DEIR
have been coded with a number to facilitate identification and tracking. The comment letters were reviewed
and divided into individual comments, with each comment containing a single theme, issue, or concern.
Individual comments and the responses to them were assigned corresponding numbers. To aid readers and
commenters, electronically bracketed comment letters have been reproduced in this document with the
corresponding responses provided immediately following each comment letter.
Table 3-1: Comments Received on the DEIR
Comment Letter
Commenter
Date
1
Orange County Sanitation District
June 27, 2024
2
California Department of Transportation, District 12
July 1 8, 2024
3
Orange County Transportation Authority (OCTA)
July 22, 2024
4
City of Irvine
July 25, 2024
To finalize the EIR for the Project, the following responses were prepared to address these comments.
City of Tustin 3-1
Final EIR
September 2024
Enderle Center Rezone
3.0 Response to Comments
Comment Letter 1: Orange County Sanitation District (OCSan), dated June 27, 2024
ounta Ellie Aveley. ue
CA
6SAN� Fnunta In Valley. CA 82708
714.962.2411
-ORANGE COUNTVSAMITATIONDIMICT www-ncwn4rpv
June 27, 2024 s mrpg
Ananclm
Samantha Beierr Senior Planner
City of Tustin areQ
Community Development Department Buena Park
300 Centennial Way, Tustin, CA 92780
Cypress
SUBJECT: Enderle Center Rezone Project — Notice of Preparation of a Draft FnuntainNallay
Environmental Impact Report Fullerton
WOW Gmve
Thank you far providing the Notice of Availability (NOA) of a Draft Environmental Impact HuntinMn Beach
Report for the Enderle Center Rezone Project_ The project site is bound on the north Irwine
by I Th Street-, on the east by Enderle Center Drive and the eastern property line of 1.1
properties fronting Enderie Center Drive-, to the south by Vandenbery Lane-, and to the La Habra
west. by the 55 Freeway, including properties west of YDrba Street. La Palma
Los Alamitos
The City of Tustin is proposing a Zone Code Amendment to create a Housing
Overlay district to the Project site. Based on the desired purpose of the rezoning, 4e rt Been
there may be some sewer issues_ Developers should coordinate with the Orange OFangff
County Sanitation District (OC San) if/when any sewer improvements are proposed 1.2
for future project bui Id cuts in the project arlla. Also, prior to approval of construction Placsntla
permits under Mitigation Measure LIT-2, include submittal of a sewer capacity Santa Ana
analysis of existing wastewater utility in the area for OC San review and obtain Sew Fwacn
sewer capacity verification from OC San.
9tarkwn
If you have any questions regarding this letter, please contact Kevin Hadden, 1.3 Tustin
Principal Slat[ Analyst, Planning Divisionr at(714) 593-7462 or khadden0-ocsan_cll
Villa Park
county at ura nga
Brawn, Andrew
Sanitary District
Andrew Brown
Midway Engineering Supervisor Sanitary District
Planning Division Irvine714 593-7052 Water
Ranch
r ❑iatriut
Yorba Linda
AB,KH.by Wnt r❑iatrice
httpsJlocsdgov-shaiepdntmrnlsite&PannirgCEQA Externally GeneratedO024 Comment Lelters'City of Tustin
Resperrse Ltr2924DC2&_docz
Our Mrssratl: To protect pe ima hesith and me environment ty
orovOrwo effective wastewater eoUectio i+ rreKmenr. and recycling. Yedr9
City of Tustin 3-2
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Response to Comment Letter 1: Orange County Sanitation District (OC San), dated June 27, 2024
Response to Comment 1.1: This comment provides a summary of the Project location. This comment is
introductory in nature and does not raise a specific issue with the adequacy of the Draft EIR or raise any
other CEQA issue. Therefore, no further response is required or provided.
Response to Comment 1.2: This comment summarizes that the Project proposes a Zone Code Amendment to
create a Housing Overlay and states that the rezoning may lead to sewer issues. The comment states future
developers should coordinate with OC San at the time sewer improvements are proposed and requests that
Mitigation Measure UT-2 be revised to include coordination with OC San. The mitigation measure has been
revised to include coordination and approval by OC San as shown below and included in Chapter 2.0,
Errata.
Section 5.11 Utilities and Service Svstems. Daae 5.11-16
MM UT-2 Future proposed Projects shall prepare capacity analyses of existing sewer utilities in the area to
ensure conveyance and pressure is adequate for future projects proposed. The developer shall then identify
infrastructure improvements necessary for the proposed development. The developer will be responsible for
preparing a capacity analysis in coordination with the EOCWD and the City. The developer shall then
submit the sewer capacity analysis to the Orange County Sanitation District (OC San) for review and
verification that there is available sewer capacity. The capacity analysis and infrastructure improvements
shall be reviewed and approved by EOCWD, OC San, and the City prior to approval of the construction
permit.
Response to Comment 1.3: This comment provides contact information for who to reach out to with any
questions about the comment letter. The comment is conclusionary in nature and does not raise any specific
concerns with the adequacy of the Draft EIR or raise any other specific CEQA issue. As substantiated by the
responses above, none of the conditions arise which would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. No revisions per this comment are required and no further response is
required or provided.
City of Tustin 3-3
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Comment Letter 2: California Department of Transportation (Caltrans), dated July 18, 2024
CALIFORNIA STATE TRANSPORTATION A017NCV
California Department vt Transpvrtativn
MTRICT 12
1750 East 4m Street. Suite 100 1 SANTA ANA CA 92705
16" 328-60W I FAX {d57] 329-6522 TTY 711
htlos-lldotea.aavlcalhurisfle3Frneldistrict-12
July]8, 2024
Samantha Beier
City of Tustin
30D Centennial Way
Tustin CA 92780
Dear fats. Beier,
GAVIN NEWSOrA. OOYCRNOR
File: LDRJCEQA
SCH #2024020747
LDR LOG #202202499
S R-55
Thank you for including the California Department of Transportation (Caltrans) in the
review of the Draft Environmental Impact Report for the Enderle Rezone project. The
City of Tustin is praposinq a General Plan Amendment (GPA) and zone change for the
application of a Housing Overl❑y (HO) district aver a existing commercial
development known as the Enderle Center. Pursuant to Housing Element Program 1 .1 f,
the city is proposing an overlay zone {"overlay district") for the Project site to add 413
housing units. The anticipated development does not rely on the demolition of any
existing buildings, but rather focuses an area currently used for surface p❑rking.
Additionally, the Project anticipates the additional development of 1 18,467 square
feet of nonresidential uses in the future, for a total nanresidenti❑I development
capacity of 205,6D3 square feet on the Project site, purse❑nt to the Ganer❑I Plan. A
specific development project is not proposed as part of this Rezoninq Project. The
Project involves approvaI of the proposed Housing Overlay, a General Plan
Amendment, Zoning Code Amendment, and a Zone Change. The Project site is
generally bounded an the north by 1 7th Street; an the east by Enderle Center Drive
and the eastern property line of properties fronting Enderle Center Drive; to the south
by Vandenberg Lane; and to the west by the 55 Freeway, including properties west of
Yorba Street.
The mission of Caltrans is to provide ❑ safe and reliable transport❑tian network that
serves all people and respects the env ronment. Caltrans is a responsible agency on
this project and has the fallowing comments:
2-1
1. The proposed project increases the capacity of allowable housing units and will
function as a mixed -use site. Mixed -use development offers an opportunity to 2.2
encourage multi -modal travel and reduce VMT. Short local car trips can
potentially be replaced with walking and bicycling trips.
2. Consider complete street designs on streets surrounding the project ❑rea. There 2 3
are opportunities far connections to other modes of transportation near the
"Provide a sore and reioble transportation nelw+orkthat series all people and respects the emironrnerd"
City of Tustin 3-4
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Ms. Samantha Beier
July 18, 2024
Page 2
project. These include the Santa Ana Metrolink Station, OCTA Bus Route 60, and 2-3
a Class II bike lane east of Prospect Avenue. cont-
3. Caltrans encourages the design of Complete Streets that include high -quality
pedestrian and bicycle facilities that are safe and comfortable for users of all 2-4
ages and abilities. Consider enhancing bike and pedestrian infrastructure on
1 7th Street.
4. During construction, please ensure that appropriate detours and safety
measures are in place that prioritize the mobility, access, and safety of bicyclists,
pedestrians, and transit users. If adjacent sidewalks or bike lanes need to be -5
closed If adjacent sidewalks or bike lanes need to be closed during
construction, please ensure that closures and detours are clearly signed. See
OCTA's bikeways map for the regional landscape of complete streets
hii;ps://www.octci.net/r)df/ocbikewaysmap.pdf
There is a missing crosswalk at the southeast comer of the Project site on Enderle
Center Drive and Vandenberg Lane. Adding a crosswalk here would support 2 6
pedestrian accessibility between the housing community south of Vandenberg
Lane to businesses of future housing at the project site.
Consider mid block crosswalks with s❑fety features on Yorba Street and End erie
Center Drive to connect future housing development on east and west side of
the project site to the businesses at Enderle Center. This will enhance walkability 2-7
and accessibility and provide convenient access between the residential areas
and local businesses.
He❑se consider the following recommendations from CcJtrans March 18, 2024, letter:
7. Ensure that truck p❑rkingr ingress and egress, and staging will not interfere with
vehicle parkingr pedestrian paths, or bicycle lanes/bicycle parking. 2-8
Establish freight pick up & drop off times that do not ca1ncida with peak
commute hours to reduce passenger vehicle conflicts and congestion for
freight. Consider designating on -street freight -only parking and delivery time -9
windows so trucks will not resort to double parking, thus causing street traffic
congestion.
9. For the multifamily residential units proposed, consider how many individual 2.10
packages will be delivered daily to individual residences. Amazon lockers or an
"Provide a sar2 and reriable transportation network that serves all people and respeots the environment"
City of Tustin 3-5
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Ms. Samantha Beier
July 18, 2024
Page 3
equivalent shared drop-off location can help reduce the amount of driving 2"1 0
done by delivery trucks and can increase the efficiency of deliveries, cant.
10.Werk with local partners and community representatives to mitigate any truck 2-11
traffic routing onto residential streets or conflicting with other road users,
including and especially bicyclists and pedestrians.
11.In the event of anyworlc performed within Caltrans right-of-way, an
encroachment permit will be required prior to construction. Please submit all 12
applications and associated documents/plans via online web portal base
Caltrans Encroachment Permit System (CEPS) at hitps;{#ceps.dot.cci.gov/
12.Any work performed within Caltrans right of way (Rf W) will require discretionary
review and approval by Caltrans and an encroachment permit will be required
far any work within the Caltrans R#W prior to construction. Prior to submitting to
Caltrans Permit's branch, applicant should fill out Applicant's Checklist to
Determine Applicable Review Process (QMAP List) Form TR-041 6 to determine if
project oversighflcoordination with Caltrans Project Manager is needed.
Applicant must submit signed Standard Encroachment Permit application
form TR-0100 along with a deposit payable to Caltrans. Deposit amount will be
dependent on when the application is submitted. Public corporations are legally
exempt from encroachment permit fees. Please note that all utility work should
be disclosed prior to permit submittal, and utility companies are to apply for
separate permits for their corresponding work.
li
Please continue to coordinate with Caltrans for any future developments that could
potentially impact State transportation facilities. 11 you have any questions, please do 2.14
not hesitate to contact Maryam MDlavi, at Maryam.Molavl9dot.co.gov.
Sincerely,
Scott Shelley
Branch Chief - Local Development Review/Climate Change/Transit
District 12
"Provide a sole and reioble trvnsportaticn netxork that serves all people and respects the environment.
City of Tustin 3-6
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Response to Comment Letter 2: California Department of Transportation (Caltrans), dated July 18, 2024
Response to Comment 2.1: This comment summarizes project understanding and provides an introduction to
the comment letter. This comment is introductory in nature and does not raise a specific issue with the
adequacy of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or
provided.
Response to Comment 2.2: The comment acknowledges that the Project would facilitate mixed use
development, which has the potential to reduce VMT and encourage multi -modal travel. This comment has
been noted for the record. This comment does not raise a specific issue with the adequacy of the Draft EIR
or raise any other CEQA issue. Therefore, no further response is required or provided.
Response to Comment 2.3: The commenter recommends consideration of complete street design surrounding
the Project site. Additionally, the commenter suggests connections to other modes of transportation near the
Project site, including Santa Ana Metrolink Station, OCTA Bus Route 60, and the Class II bike lane east of
Prospect Avenue.
As noted by the commenter in their summary of Project understanding, the Project being considered includes
a General Plan Amendment (GPA) and implementation of a Housing Overlay (HO) to accommodate
potential future development of 413 dwelling units in consistency with the City's approved Housing Element.
No actual development is proposed as part of this project. All future development projects would be required
to undergo plan check review with the City and project -specific traffic studies would be required as
determined appropriate by the City's traffic guidelines.
The Project site is currently developed and there are no bike lanes on the public roadway network currently
serving the Project site. The closest existing bike lane to the Project site is a Class II Bike Lane east of Prospect
Avenue along 17'h Street. According to Figure C-5, Master Bikeway Plan, of the City's General Plan, a Class
II bike lane is planned along Prospect Avenue, approximately 1,000 feet west of the Project site. However,
this bike lane has not been implemented. Sidewalks currently exist on both sides of 17'h Street, Vandenburg
Lane, and Yorba Street and on the northbound side of Enderle Center Drive. Future projects would be
required to analyze, and incorporate as feasible, access to alternative modes of transportation and
collaborate with applicable regional, state, and federal parties during the development process (see
General Plan Circulation Element Policies 1.3, 1.10, 1.1 1, 6.2, and 6.14). Therefore, future projects would
be evaluated with a project -specific study and plan check, which would ensure the project is consistent with
the City's policies to consider and implement access to alternative modes of transportation and no further
response is required or provided.
Response to Comment 2.4: The commenter encourages the design of Complete Streets that include high
quality pedestrian and bicycle facilities. Specifically, the commenter suggests enhancing bike and pedestrian
infrastructure on 17'h Street. As discussed above in Response to Comment 2.3, future projects would be
evaluated with a project -specific traffic study and plan check as applicable, which would ensure the project
is consistent with the City's policies to consider and implement access to alternative modes of transportation.
As future residential projects are proposed, the City will continue to identify potential roadway, bicycle, and
pedestrian improvements that could enhance connectivity to surrounding facilities and uses.
Response to Comment 2.5: The commenter indicates that during construction, the City should ensure that
appropriate detour and safety measures are in place that prioritize the mobility, access, and safety of
bicyclists, pedestrians, and transit users. Any closures should be clearly signposted.
Per the City's Standard Plans and Design Standards, all traffic control, temporary signage and striping,
barricading, and detouring shall be as depicted on the traffic control plan submitted and approved by the
City, and per the requirements of the California Manual on Uniform Traffic Control Devices (CA MUTCD). All
layouts shall be reviewed by the City's project inspector for conformance with the approved plan. The Project
City of Tustin 3-7
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
does not propose any development; however, all future projects would be required to follow City guidelines
for detours, signage, and other traffic control activities.
Response to Comment 2.6: The commenter notes that there is a missing crosswalk at the southeast corner of
the Project site on Enderle Center Drive and Vandenberg Lane. The comment further suggests that adding a
crosswalk would support connectivity between the Project site and residential community south of
Vandenberg Lane.
No development is currently proposed as part of the Project. As discussed above in Response to Comment
2.3, future projects would be evaluated with a project -specific traffic study and plan check as applicable.
As future projects are proposed, the City will identify potential roadway, bicycle, and pedestrian
improvements that could enhance connectivity to surrounding facilities and uses.
Response to Comment 2.7: The commenter requests that the City consider midblock crosswalks with safety
features on Yorba Street and Enderle Center Drive to provide connectivity between the Project site and
commercial uses to the east and west.
No development is currently proposed as part of the Project. As discussed above in Response to Comment
2.3, future projects would be evaluated with a project -specific traffic study and plan check as applicable.
As future projects are proposed, the City will identify potential roadway, bicycle, and pedestrian
improvements that could enhance connectivity to surrounding facilities and uses.
Response to Comment 2.8: The commenter recommends that the City ensure proposed truck parking,
circulation, and construction staging would not interfere with vehicle, bicycle, or pedestrian circulation and
parking.
The transportation analysis within the DEIR was prepared pursuant to SB 743, which requires that VMT
thresholds be utilized for traffic analysis, and State CEQA Guidelines Section 15064.3 that states that a
project's effect on automobile delay shall not constitute a significant environmental impact. As such, the
Project TIA is not considered part of the DEIR or supporting CEQA documentation since it is an analysis of
automobile delay and level of service issues. Further, the comments and questions provided by the commenter
do not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. However, the
City will coordinate with Caltrans to address their concerns regarding the TIA and will continue to
communicate with Caltrans as future development is proposed.
As noted by the commenter in their summary of Project understanding, the Project being considered includes
a General Plan Amendment (GPA) and implementation of a Housing Overlay (HO) to accommodate
potential future development of 413 dwelling units in consistency with the City's approved Housing Element.
No actual development is proposed as part of this project. All future development projects would be required
to undergo plan check review with the City and project -specific traffic studies would be required as
determined appropriate by the City's traffic guidelines.
Further, while the Draft EIR analysis considers future buildout of the remaining 118,474 SF of maximum
nonresidential use currently allocated to the Project site by the City's General Plan, the Project does not
propose an increase in allowed nonresidential uses, nor does the Project propose development of any
nonresidential projects at this time. Future residential construction could require a temporary increase in truck
traffic and staging; however, each project would be required to prepare a project -specific Stormwater
Pollution Prevention Plan (SWPPP) in compliance with the Construction General Permit (CGP), which would
include proposed construction staging areas and would be reviewed and approved by a City Engineer.
Additionally, any required detour for pedestrian or bicycle paths would be outlined in a traffic control plan
prepared pursuant to the City's Standard Plans and Design Standards. Therefore, the Project would not result
in direct increase in truck traffic or staging. Future indirect truck traffic and staging would be coordinated
City of Tustin 3-8
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
on a project -by -project basis in the future. This comment does not raise a specific issue with the adequacy
of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.
Response to Comment 2.9: The commenter recommends that the City coordinate freight pickup and drop
off times around peak commute times to reduce freight and vehicle conflicts. The commenter also suggests
that the City consider designated on -street freight -only parking and delivery windows to avoid truck double
parking and traffic congestion.
As discussed above in Response to Comment 2.8, the Project would allow for future development of up to
413 dwelling units within the Project site. The Project does not propose development, therefore at this time
it is too speculative to determine specific level of service patterns. All future development projects would be
required to undergo plan check review with the City and project -specific traffic studies would be required
as determined appropriate by the City's traffic guidelines.
Further, as discussed in Response to Comment 2.8, circulation and level of service are analyzed in the Project
TIA, which is not part of the EIR. However, the City will continue to coordinate with Caltrans regarding their
TIA comments and address any other level of service -related concerns. Therefore, this comment does not
raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. No further response
is required or provided.
Response to Comment 2.10: The commenter recommends the City determine how many individual packages
will be delivered daily to individual residences and consider the implementation of Amazon lockers or drop-
off locations to reduce the amount of delivery driving needed.
As discussed above in Response to Comment 2.9, the Project does not propose development and future
projects are too speculative to determine specific level of service patterns at this time. Project -specific traffic
studies would be prepared as necessary for all future development pursuant to the requirements of the City
traffic guidelines.
Further, as discussed in Response to Comment 2.8, circulation and level of service are analyzed in the Project
TIA, which is not part of the EIR. However, the City will continue to coordinate with Caltrans regarding their
TIA comments and address any other level of service -related concerns. Therefore, this comment does not
raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. No further response
is required or provided.
Response to Comment 2.11: The commenter recommends the City coordinate with local partners and
community representatives to mitigate truck traffic on residential streets or other conflicts with road users,
including bicyclists and pedestrians.
As discussed above in Response to Comment 2.9, the Project does not propose development, therefore at
this time it is too speculative to determine specific level of service patterns. Project -specific traffic studies
would be prepared as necessary for all future development pursuant to the requirements of the City traffic
guidelines.
Further, as discussed in Response to Comment 2.8, circulation and level of service are analyzed in the Project
TIA, which is not part of the EIR. However, the City will continue to coordinate with Caltrans regarding their
TIA comments and address any other level of service -related concerns. Additionally, as discussed under Draft
EIR Section 5.4, Land Use, future projects would be required to analyze, and incorporate as feasible, access
to alternative modes of transportation and collaborate with applicable regional, state, and federal parties
during the development process (see General Plan Circulation Element Policies 1.3, 1.10, 1.1 1, 6.2, and
6.14). Therefore, the Project would not result in conflict with road users and no further response is required
or provided.
City of Tustin 3-9
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Response to Comment 2.12: The commenter notifies the City that any work performed within Caltrans right-
of-way would require an encroachment permit prior to construction. The commenter provides the link to the
Caltrans Encroachment Permit System.
As discussed above in Response to Comment 2.9, the Project does not propose development, therefore at
this time it is too speculative to determine specific level of service patterns. Future development projects
would follow the appropriate Caltrans encroachment permit process as necessary. This comment has been
noted for the record and no further response is required or provided.
Response to Comment 2.13: This comment states that any work performed within Caltrans right of way
would require discretionary review and approval by Caltrans to obtain an encroachment permit prior to
construction. The commenter notes that prior to initiating the encroachment permit process, the applicant
should fill out the Applicant's Checklist to Determine Applicable Review Process (QMAP List) Form TR-0416
to determine if project oversight/coordination with Caltrans Project Manager is needed. The commenter
provides additional encroachment permit application instructions.
As discussed above in Response to Comment 2.9, the Project does not propose development, therefore at
this time it is too speculative to determine specific level of service patterns. Future development projects
would follow the appropriate Caltrans encroachment permit process as necessary. This comment has been
noted for the record and no further response is required or provided.
Response to Comment 2.14: The commenter requests that the City continues to coordination with Caltrans
for any future developments that could potentially impact State transportation facilities and provides a
contact. This comment is conclusory in nature and does not raise a specific issue with the adequacy of the
Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.
City of Tustin 3-10
Final EIR
September 2024
Enderle Center Rezone
3.0 Response to Comments
Comment Letter 3: Orange County Transportation Authority (OCTA), dated July 22, 2024
FA
O OTA
July 2-2, 2024
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Ms. Samantha Beier
Senior Planner
Community Development Department
300 Centennial Way
Tustin, CA 92TBO
Via email- Housin(iElementRezene(c tustinca_org
Subject: Notice of Availability of a draft Environmental Impact Report
for the Enderle Center Rezone Project
Dear hls_ Beier -
The Grange County Transportation Authority (OCTA) appreciates the opportunity
to review the Notice of Availability of a Draft Environmental Impact Report (EIR) 3.1
for the Enderle Center Rezone Project. OCTA has the following comments for
]lour consideraticn:
In the Draft EIR an page 4-9, in Section 4.5.9 Transportation, Existing
Transit Service:
Please include Routes 59, 64, 70, 72, 79, 90, 167, 472, and 473, 3.2
these routes serve the City of Tustin (City)_
Please remove Routes 61, 65, 75, and 463, these routes do not
serve the City.
In Appendix ❑ VMT Analysis on page 9, Figure 2, please include the
sections of McFadden Avenue and Walnut Avenue as being served by 3.3
Route 66, as shown in Attachment A. The short version of Route 66
serving the City has peak weekday frequencies of 15 minutes.
e encourage open communication with OCTA on any matte rs d isc u ssed herein_
Should you have any comments or questions, please contact me at (714) 560- 3.4
5907 or at di3hugDocta_net.
Sincerely,
Dan Phu
Manager, Environmental Programs
DP:tc
Attachment: AttachmentA - Tustin HQTC Map
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&W SdutM MAO ShW t PO_ Box 14184 f crangc ! Caffornia RM3 1584 t (71,9 5MOCTA {8 D
City of Tustin 3-1 1
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Attachment A — Tustin High Quality Transit Corridor Map
-�� Tustin
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Lyon Street
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City of Tustin 3-12
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Response to Comment Letter 3: Orange County Transportation Authority (OCTA), dated July 22, 2024
Response to Comment 3.1: This comment provides an introduction to the comment letter. This comment is
introductory in nature and does not raise a specific issue with the adequacy of the Draft EIR or raise any
other CEQA issue. Therefore, no further response is required or provided.
Response to Comment 3.2: This comment states that DEIR Section 5.9, Transportation, specifically Section
5.9.3.2, Existing Transit Service (DEIR page 5.9-6), erroneously included OCTA bus routes 61, 65, 75, and
463 as routes that serve the City. Additionally, the comment states that the section left out bus routes 59, 64,
70, 72, 79, 90, 167, 472, and 473, which do serve the City. The discussion has been revised to remove the
bus routes that do not serve the City and include the bus routes that do serve the City, as shown below and
included in Chapter 2.0, Errata.
Section 5.9 Transportation, page 5.9-6
Public transit bus service for the City is provided by the Orange County Transportation Authority
(OCTA). The established network includes Routes 59,60, 6� 64, 6-5, 66, 70. 71, 72, 7� 79, 90,
167, 472, and 4-6-3 473. The Project is not located within a Transit Priority Area (TPA); however,
adjacent to the Project at the junction of 17th Street and Enderle Center Drive, there are two existing
public transit bus stations served by Route 60 with bus service every 30 minutes. These stations are
situated on both the northern side of 17th Street and Yorba Street and on the southern side of 17th
Street and Enderle Center Drive. The major routes of travel for Route 60 include Larwin Square to
Long Beach via Newport and Seventeenth. Route 60 operates on approximately 30-minute
headways on weekdays and weekends and connects to the Newport Transportation Center.
Response to Comment 3.3: This comment states that the Vehicle Miles Traveled (VMT) Analysis, included as
Appendix D to the DEIR, references an outdated figure illustrating the High Quality Transit Corridors (HQTC)
in the City of Tustin. The comment states that sections of McFadden Avenue and Walnut Avenue are served
by Route 66 and the figure included in the VMT Analysis needs to be updated to reflect this.
The VMT Analysis was prepared using the City of Tustin Vehicle Miles Traveled Analysis Guidelines, dated
March 2024. While the City appreciates that OCTA identifies sections of McFadden Avenue and Walnut
Avenue as a HQTC, the City's adopted guidelines are based on the Southern California Association of
Government's (SCAG) definition and determination of HQTCs in the area. SCAG defines a HQTC as being
within one half -mile of a well -serviced transit stop or a transit corridor with 15-minute or less service
frequency during peak commute hours. The City's adopted VMT Guideline were in effect at the time of the
DEIR's preparation, and revisions to the Guidelines are not a part of the proposed Project; therefore, the
City does not intend to revise the approved VMT Guidelines at this time. Regardless, City staff will continue
to coordinate with OCTA on policy matters. This comment does not raise a specific issue with the adequacy
of the Draft EIR or raise any other CEQA issue. Therefore, no further response is required or provided.
Response to Comment 3.4: This comment provides contact information for who to reach out to with any
questions about the comment letter. The comment is conclusionary in nature and does not raise any specific
concerns with the adequacy of the Draft EIR or raise any other specific CEQA issue. As substantiated by the
responses above, none of the conditions arise which would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. No revisions per this comment are required and no further response is
required or provided.
City of Tustin 3-1 3
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Comment Letter 4: City of Irvine, dated July 25, 2024
pF JAB&
Community Development
cityofirvine.org
City of Irvine, One Civic Center Plaza, P.O. Box 19575, Irvine, Ca]hbmia 92fi2 -%75 949-724-6000
July 25, 2024
Samantha Beier Email: Housing ElementRezonefi)tustinca_om
Senior Planner
City of Tustin
300 Centennial Way
Tustin, CA 92780
Subject: Notice of Availability (NDA) of a Draft Environmental Impact Report
(EIR) in Compliance with Title 14 Section 15D87(a) of the California
Cade of Regulations for the Enderle Center Rezone Project
Samantha Beier:
The City of Irvine is in receipt of the NOA of a Draft EIR for the Enderle Center Rezone
Project in the City of Tustin_ Pursuant to Housing Element Project 1.11, the City of Tustin
is proposing an overlay zone for the project_ To accomplish this, the City of Tustin is
requesting a GPA to estabiish a h igher density residential uses within the PCCB land use
designation when prescribed by a Housing Overlay or SpeUriic Plan. The Enderle Center
has the capacity of up to 413 housing units consistent with Tustin's Housing Element_
Starr has reviewed the project and has no comments. It you have any questions, please
contact Senior Planner Justin Equina at leguina(ciiyafirvine_org or at 949-724-6364.
Thank you far the opportunity to review the project.
Sincerely,
ar
Justin Equina
Senior Planner
4.1
City of Tustin 3-14
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
Response to Comment Letter 4: City of Irvine, dated July 25, 2024
Response to Comment 4.1: This comment provides a brief summary of the Project description and states
that the City of Irvine has reviewed the Project and has no comments. This comment does not raise a specific
issue with the adequacy of the Draft EIR or raise any other CEQA issue. Therefore, no further response is
required or provided. This comment is noted for the record.
City of Tustin 3-15
Final EIR
September 2024
Enderle Center Rezone Project 3.0 Response to Comments
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City of Tustin 3-16
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
4. Mitigation Monitoring and Reporting Program
4.1 INTRODUCTION
The California Environmental Quality Act (CEQA) requires a lead or public agency that approves or carries
out a project for which an Environmental Impact Report (EIR) has been certified, which identifies one or more
significant adverse environmental effects and where findings with respect to changes or alterations in the
project have been made, to adopt a "...reporting or monitoring program for the changes to the project
which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects
on the environment" (CEQA, Public Resources Code Sections 21081, 21081.6).
A Mitigation Monitoring and Reporting Program (MMRP) is required to ensure that adopted mitigation
measures are successfully implemented. The City of Tustin is the Lead Agency for the Project and is
responsible for implementation of the MMRP. This report describes the MMRP for the Project and identifies
the parties that will be responsible for monitoring implementation of the individual mitigation measures in
the MMRP.
4.2 MITIGATION MONITORING AND REPORTING PROGRAM
The MMRP for the Project will be active through all phases of the Project, including design, construction, and
operation. The attached table identifies the mitigation program required to be implemented by the City for
the Project. The table identifies mitigation measures required by the City to mitigate or avoid significant
impacts associated with the implementation of the Project, the timing of implementation, and the responsible
party or parties for monitoring compliance.
The MMRP also includes a column that will be used by the compliance monitor (individual responsible for
monitoring compliance) to document when implementation of the measure is completed. As individual Plans,
Programs, and Policies and mitigation measures are completed, the compliance monitor will sign and date
the MMRP, indicating that the required actions have been completed.
City of Tustin 4-1
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September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
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City of Tustin 4-2
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Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Table 4-1: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
AIR QUALITY
PPP AQ-1: Rule 403. The Project is required to comply with the
Prior to grading
Project developers/
The City Community
provisions of South Coast Air Quality Management District
permit approval;
applicants and
Development Dept.
Initials:
(SCAQMD) Rule 403, which includes the following:
and during
construction
will confirm that this
• All clearing, grading, earth -moving, or excavation activities
construction activities
contractors
requirement appears
shall cease when winds exceed 25 mph per SCAQMD
in the construction
Date:
guidelines in order to limit fugitive dust emissions.
specifications.
• The contractor shall ensure that all disturbed unpaved roads
and disturbed areas within the project are watered, with
complete coverage of disturbed areas, at least 3 times daily
during dry weather; preferably in the mid -morning,
afternoon, and after work is done for the day.
• The contractor shall ensure that traffic speeds on unpaved
roads and Project site areas are reduced to 15 miles per hour
or less.
PPP AQ-2: Rule 1113. The Project is required to comply with the
Prior to grading
Project developers/
The City Community
provisions of South Coast Air Quality Management District Rule
permit approval;
applicants and
Development Dept.
Initials:
(SCAQMD) Rule 1 1 13. Only "Low -Volatile Organic Compounds"
and during
construction
will examine project
paints (no more than 50 gram/liter of VOC) and/or High Pressure
construction activities
contractors
contracts, plans, and
Low Volume (HPLV) applications shall be used.
specifications for this
Date:
requirement and
monitor for
compliance.
PPP AO-3: Rule 402. The Project is required to comply with the
Prior to grading or
Project developers/
The City Community
provisions of South Coast Air Quality Management District
building permit
applicants and
Development Dept.
Initials:
(SCAQMD) Rule 402. The Project shall not discharge from any
approval; and
construction
will examine project
source whatsoever such quantities of air contaminants or other
during construction
contractors
plans and monitor
material which cause injury, detriment, nuisance, or annoyance to
and operation
for compliance.
Date:
any considerable number of persons or to the public, or which
endanger the comfort, repose, health or safety of any such
persons or the public, or which cause, or have a natural tendency
to cause, injury or damage to business or property.
MM AQ-1. Prior to building permit approval by the City of Tustin
Prior to building
Project developers/
The City Community
(City) for future development projects, project applicants shall
permit approval
applicants
Development Dept.
prepare and submit a technical assessment evaluating potential
will confirm that this
City of Tustin 4-3
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
project -related air quality impacts, including a localized impacts
requirement has
analysis, to the City for review and approval. The analysis shall
been completed
Initials:
be prepared in conformance with South Coast Air Quality
prior to final plan
Management District (SCAQMD) methodology. If project -related
approval.
emissions exceed applicable SCAQMD thresholds of significance,
Date:
the City shall require that applicants for new development
projects incorporate mitigation measures to reduce emissions. The
identified measures shall be included as part of the conditions of
approval. Additionally, if project -related localized emissions
exceed the SCAQMD's thresholds, a dispersion modeling analysis
shall be conducted to calculate potential health risk from project
implementation, and all necessary mitigation measures shall be
implemented.
BIOLOGICAL RESOURCES
PPP BIO-1: Street Trees. Installation of street trees shall occur in
Prior to grading and
Project
The City Community
compliance with the City of Tustin Municipal Code Article 7,
building permit
developers/applica
Development Dept.
Initials:
Chapter 3, Section 7308.
approval; and
nts and construction
will approve
during construction
contractors
landscape plan prior
Date:
activities
to issuance of
grading permits.
MM BIO-1: Migratory Bird Treaty Act. Prior to commencement of
Before
Project developers/
The City Community
grading activities, the City Community Development Department
commencement of
applicants and
Development Dept.
Initials:
shall verify that, in the event that vegetation and tree removal
grading activities
construction
will determine if
activities occur within the active breeding season for birds
contractors
surveys are needed
Date:
(February 1—September 15), the Project applicant (or their
prior to issuance of
Construction Contractor) shall retain a qualified biologist
permits for grading
(meaning a professional biologist that is familiar with local birds
activities based on
and their nesting behaviors) to conduct a nesting bird survey no
the timeline and will
more than 3 days prior to commencement of construction activities.
examine project
permitting for these
The nesting survey shall include the Project site and areas
requirements and
immediately adjacent to the site that could potentially be
monitor for
affected by Project -related construction activities, such as noise,
compliance.
human activity, and dust, etc. If active nesting of birds is observed
within 100 feet of the designated construction area prior to
construction, the qualified biologist shall establish an appropriate
buffer around the active nests (e.g., as much as 500 feet for
raptors and 300 feet for non -raptors [subject to the
recommendations of the qualified biologist]), and the buffer areas
City of Tustin 4-4
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
shall be avoided until the nests are no longer occupied and the
juvenile birds can survive independently from the nests.
CULTURAL RESOURCES
PPP CUL-1: Human Remains. Should human remains or funerary
During grading and
Project developers/
The City Community
objects be discovered during Project construction, the Project
construction activities
applicant,
Development Dept.
Initials:
would be required to comply with State Health and Safety Code
construction
will review project
Section 7050.5, which states that no further disturbance may occur
contractors
plans and
Date:
in the vicinity of the body (within a 100-foot buffer of the find)
specifications to
until the County Coroner has made a determination of origin and
ensure these
disposition pursuant to Public Resources Code Section 5097.98.
requirements are
The County Coroner must be notified of the find immediately. If
met and would
the remains are determined to be prehistoric, the Coroner will
monitor to verify
notify the Native American Heritage Commission by telephone
compliance.
within 24 hours, which will determine the identity of and notify a
Most Likely Descendant (MLD). With the permission of the
landowner or his/her authorized representative, the MLD may
inspect the site of the discovery. The MLD must complete the
inspection and make recommendations or preferences for
treatment within 48 hours after being granted access to the site.
MM CUL-1: Inadvertent Discovery. In the event that potential
Prior to grading
Project developers/
The City Community
archaeological resources are discovered during excavation,
permit approval;
applicants and
Development Dept.
Initials:
grading, or construction activities, work shall cease within 50 feet
and during
construction
will examine project
of the find until a qualified archaeologist from the City or County
construction activities
contractors
contracts, plans, and
Date:
List of Qualified Archaeologists has evaluated the find to
specifications for
determine whether the find constitutes a "unique archaeological
these requirements
resource," as defined in Section 21 083.2(g) of the California
and monitor for
Public Resources Code. Any resources identified shall be treated
compliance.
in accordance with California Public Resources Code Section
21083.2(g).
If the discovered resource(s) appears Native American in origin,
a Native American Monitor shall be contacted to evaluate any
potential tribal cultural resource(s) and shall have the opportunity
to consult on appropriate treatment and curation of these
resources. The discovery would also be reported to the City and
the South Central Coastal Information Center (SCCIC).
Prior to the issuance of any permits for ground -disturbing activities
that include the excavation of soils (including as grading,
City of Tustin 4-5
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
excavation, and trenching), the City of Tustin shall ensure that all
Project grading and construction plans and specifications include
requirement to halt construction activity and contact an
archaeologist as specified above.
ENERGY
PPP E-1: CalGreen Compliance. The Project is required to comply
Prior to building
Project developers/
The City Building
with the CalGreen Building Code to ensure efficient use of energy.
permit approval
applicants and
Division will review
Initials:
CalGreen specifications are required to be incorporated into
construction
Project plans and
building plans as a condition of building permit approval.
contractors
specifications for
Date:
these requirements
and monitor for
compliance.
GEOLOGY AND SOILS
PPP GEO-1: CBC Title 24, Part 2. Structures built in the City are
Prior to grading and
Project developers/
The City Building
required to be built in compliance with the CBC (California Code
building permit
applicants and
Division will examine
Initials:
of Regulations, Title 24, Part 2) that provides provisions for
approval
construction
project contracts,
earthquake safety based on factors including building occupancy
contractors
plans, and
Date:
type, the types of soils onsite, and the probable strength of
specifications for
ground motion. Compliance with the CBC would require the
these requirements
incorporation of 1 ) seismic safety features to minimize the
and monitor for
potential for significant effects as a result of earthquakes; 2)
compliance.
proper building footings and foundations; and 3) construction of
the building structure so that it would withstand the effects of
strong ground shaking. Implementation of CBC standards would
be verified by the City during the plan check and permitting
process.
PPP GEO-2: Policy 8.5 of the Conservation/Open
Prior to grading and
Project developers/
The City Community
Space/Recreation Element. Project applicants would be required
building permit
applicants and
Development Dept.
Initials:
to submit applications for building and grading permits, and
approval
construction
will examine project
applications for subdivision for adjacency to, threats from, and
contractors
contracts, plans, and
Date:
impacts on geological hazards arising from seismic events,
specifications for
landslides, or other geologic hazards such as expansive soils and
these requirements
subsidence areas, which would be reviewed by the City during
and monitor for
plan check.
compliance.
MM GEO-1: All future projects implemented through the proposed
Prior to grading and
Project developers/
The City Community
housing overlay would be required to conduct a project -specific
building permit
applicants and
Development Dept.
geotechnical investigation to ensure that the site's soils are
approval
will review and
City of Tustin 4-6
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
adequate for the construction and operation of the proposed
construction
approve
project. Future projects would be required to implement measures
contractors
development specific
Initials:
identified within the project -specific geotechnical investigation.
geotechnical
investigation and
Date:
ensure its
requirements are
included in
development
contracts, plans, and
specifications and
monitor for
compliance.
HYDROLOGY AND WATER QUALITY
PPP HYD-1: SWPPP. Prior to issuance of any grading or
Prior to grading or
Project developers/
The City Public
demolition permits, the applicant shall provide the City Building
demolition/building
applicants and
Works and
Initials:
Division evidence of compliance with the NPDES (National
permit approval
construction
Community
Pollutant Discharge Elimination System) requirement to obtain a
contractors
Development
Date:
construction permit from the State Water Resource Control Board
Departments will
(SWRCB). The permit requirement applies to grading and
examine project
construction sites of one acre or larger. The Project
contracts, plans, and
applicant/proponent shall comply by submitting a Notice of Intent
specifications for
(NOI) and by developing and implementing a Stormwater
these requirements
Pollution Prevention Plan (SWPPP) and a monitoring program and
and monitor for
reporting plan for the construction site.
compliance.
PPP HYD-2: City of Tustin Grading Manual. All future projects
Prior to grading or
Project developers/
The City Community
are required to comply with the City of Tustin Grading Manual
demolition/building
applicants and
Development Dept.
Initials:
(1990). Implementation of grading manual standards would be
permits approval
construction
will examine project
verified by the City during the plan check and permitting process.
and during
contractors
contracts, plans, and
Date:
construction activities
specifications for
these requirements
and monitor for
compliance.
PPP HYD-3: WQMP. Prior to the approval of the Grading Plan
Prior to grading
Project developers/
The City Public
and issuance of Grading Permits a completed Water Quality
permit approval
applicants and
Works Dept. will
Initials:
Management Plan (WQMP) shall be prepared by the Project
construction
examine project
applicant and submitted to and approved by the City Public
contractors
contracts, plans, and
Works Department. The WQMP shall identify all Post-
specifications for
Date:
Construction, Site Design, Source Control, and Treatment Control
these requirements
City of Tustin 4-7
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
Best Management Practices (BMPs) that will be incorporated into
and monitor for
the development Project to minimize the adverse effects on
compliance.
receiving waters.
GREENHOUSE GAS EMISSIONS
Mitigation Measure GHG-1: Prior to issuance of a building
Prior to building
Project Developers
The City Community
permit, the City shall require that applicants for new residential
permit approval
/applicants
Development Dept.
Initials:
development projects incorporate mitigation measures to reduce
will review project
GHG emissions. The identified measures shall be included as part
plans and ensure
Date:
of the project's approval. Possible mitigation measures to reduce
mitigation measures
operational emissions could include, but are not limited to, the
to reduce GHG
following:
emissions are
incorporated into the
• Increase in insulation such that heat transfer and thermal
project, as
bridging is minimized;
appropriate, prior to
• Limit air leakage through the structure and/or within the
issuance of buildingpermit.
heating and cooling distribution system;
• Use of energy -efficient space heating and cooling
equipment;
• Installation of dual -paned or other energy efficient windows;
• Use of interior and exterior energy efficient lighting that
exceeds the incumbent California Title 24 Energy Efficiency
performance standards;
• Installation of automatic devices to turn off lights where they
are not needed;
• Application of an exterior paint and surface color palette
that emphasizes light and off-white colors that reflect heat
away from buildings;
• Design of buildings with "cool roofs" using products certified
by the Cool Roof Rating Council, and/or exposed roof
surfaces using light and off-white colors;
• Design of buildings to accommodate photo -voltaic solar
electricity systems or the installation of photo -voltaic solar
electricity systems;
• Installation of ENERGY STAR -qualified energy -efficient
appliances, heating and cooling systems, office equipment,
and/or lighting products.
City of Tustin 4-8
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
• Landscaping palette emphasizing drought tolerant plants;
• Use of water -efficient irrigation techniques;
U.S. EPA Certified WaterSense-labeled or equivalent faucets,
high -efficiency toilets (HETs), and water -conserving shower heads.
Mitigation Measure GHG-2: Prior to discretionary approval by
Prior to
Project Developers
The City Community
the City of Tustin (City) for residential development projects
discretionary
/applicants
Development Dept.
Initials:
subject to California Environmental Quality Act (CEQA) review,
approval
Planning Division will
project applicants shall prepare and submit a technical assessment
ensure receipt,
Date:
evaluating potential project -related greenhouse gas (GHG)
review, and
impacts to the City for review and approval. The evaluation shall
approval of GHG
be prepared in conformance with South Coast Air Quality
technical assessment
Management District (SCAQMD) methodology. If project -related
and inclusion of
development specific
GHG emissions exceed applicable SCAQMD thresholds of
measures, as
significance and/or Statewide GHG reduction targets, project-
appropriate, prior to
specific measures shall be identified and implemented, which
discretionary
would be reviewed and confirmed by the City.
approval.
NOISE
PPP NOW: Construction Hours. Per the Tustin City Code Section
During construction
Project developer/
The City Community
4616, construction activities are allowed only between the hours
Construction
Development Dept.
Initials:
of 7:00 AM and 6:00 PM, Monday through Friday and between
contractor/ City of
will enforce grading
9:00 AM to 5:00 PM on Saturdays with no activity allowed on
Tustin Building
and construction
Date:
Sundays and City -observed federal holidays.
Department
permitting; and
monitor for
compliance.
MM NOI-1: All future development shall prepare a project-
Prior to grading and
Project developers/
The City Community
specific Final Acoustical Report to confirm whether any proposed
building permit
applicants
Development Dept.
Initials:
exterior noise sensitive areas would experience noise levels
approval
will review and
greater than 65 dBA CNEL and whether interior noise levels would
approve
exceed 45 dBA CNEL and identify any noise reduction features
development specific
Date:
for the proposed development (e.g. upgraded windows with
noise analysis and
Sound Transmission Class (STC) ratings of 30-35). Additionally,
ensure any noise
the Final Acoustical Report shall confirm that proposed siting of
requirements are
noise -generating stationary sources, if any will not result in an
included in
exceedance of applicable noise thresholds at surrounding land
development
uses.
contracts, plans, and
specifications and
City of Tustin 4-9
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
monitor for
compliance.
RECREATION
PPP R-1: City Park Requirements. Tustin City Code Section 9331
Prior to grading and
Project developers/
The City Community
— Dedications, Reservations and Development Fees. All future
building permit
applicants
Development Dept.
Initials:
development shall be consistent with this standard.
approval
will review project
plans and
specifications to
Date:
ensure these
requirements are
met and would
monitor to verify
compliance.
TRANSPORTATION
PPP T-1: Sidewalk Standards. Sidewalks shall be provided on a
Prior to grading and
Project developers/
The City Building
private street for attached and detached residential products in
construction permit
applicants and
Division will review
Initials:
accordance with Standard B102 of the City's Construction
approval
construction
project plans and
Standards, Storm Drain and On -Site Private Improvements, and is
contractors
specifications to
Date:
subject to compliance with applicable accessibility requirements
ensure these
of the American Disabilities Act, Title 24 of the Uniform Building
requirements are
Code as locally amended, and the Department of Housing and
met and would
Urban Development's Fair Housing Accessibility Guidelines.
monitor to verify
compliance.
PPP T-2: Traffic Control/Utilities. All future development
Prior to grading or
Project developers/
The City Public
constructed under the Project shall be subject to the traffic control
demolition/building
applicants and
Works Dept. will
Initials:
standards specified by the City's latest Standard Plans and Design
permit approval
construction
review project plans
Standards, which includes the requirement for Traffic Control Plan
contractors
and specifications to
during construction, the process prior to commencing construction
ensure these
Date:
within the City public right-of-way (including utility work), and
requirements are
specifications for operational roadway and traffic control design.
met and would
monitor to verify
compliance.
TRIBAL CULTURAL RESOURCES
PPP TCR-1: Native American historical and cultural resources and
Prior to grading or
Project developers/
The City Community
sacred sites are protected under PRC Sections 5097.9 to
demolition/building
applicant,
Development Dept.
Initials:
5097.991, which require that descendants be notified when
permit approval
construction
will review project
Native American human remains are discovered and provide for
contractors
plans and
Date:
City of Tustin 4-10
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Timing
Responsible Party
Verification Method
Date Completed and
Initials
treatment and disposition of human remains and associated grave
specifications to
goods.
ensure these
requirements are
met and would
monitor to verify
compliance.
TCR-1: Retain a Native American Monitor Prior to
Prior to grading or
Project developers/
The City Community
Commencement of Ground -Disturbing Activities
demolition/building
applicant,
Development Dept.
Initials:
a. Prior to the issuance of demolition or grading permits for any
permit approval;
construction
will review project
Date:
projects that would disturb previously undisturbed soils (native
and during grading
contractors, Native
plans and
soils) or soils that have native fill, the project
and demolition
American Monitor
specifications to
applicant/developer shall retain a Native American Monitor,
activities
ensure these
with first preference given to the Gabriele"no Band of Mission
requirements are
met and would
Indians — Kizh Nation, who responded to the City's request for
monitor to verify
consultation on November 14, 2023 (first preference Tribe,
compliance.
Tribe). The applicant/developer shall allow 45 days from the
initial contact with the first preference tribe to enter into a
contract for monitoring services. If the applicant/developer is
unable to contact the Kizh Nation after three documented
attempts, or is unable to secure an agreement, the applicant
shall report to the lead agency, and the lead agency will
contact the Kizh Nation to validate that the parties were
unable to enter into an agreement. If the
applicant/developer can demonstrate they were unable to
secure an agreement with the first preference tribe, as
validated and documented by the Community Development
Department in writing, or if the contracted tribe fails to fulfill
its obligation under the contract terms, then the
applicant/developer may retain an alternative qualified
tribal monitor from a culturally affiliated tribe, or if none are
available, an otherwise qualified archaeologist may be
retained as approved by the City.
The monitor shall be retained prior to the issuance of a
demolition permit or grading permit, and the commencement
of any development related "ground -disturbing activity" for
the subject project at all project locations (i.e., both on -site
and any off -site locations that are included in the project
description/definition and/or required in connection with the
project, such as public improvement work). "Ground -
City of Tustin 4-1 1
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Timing
Responsible Party
Verification Method
Date Completed and
Initials
disturbing activity" shall include, but is not limited to,
demolition, pavement removal, auguring, grubbing, boring,
grading, excavation, drilling, and trenching for the purposes
of reconstruction and new development. "Ground -disturbing
activity" shall not include removal or maintenance of existing
small facilities and utilities such as potholing, tree removal,
and parking lot maintenance. This mitigation measure does
not apply to activities that would only disturb soils made up
of artificial fill, as verified by a soils or geotechnical report.
b. A copy of the executed monitoring agreement shall be
submitted to the lead agency prior to the commencement of
any ground -disturbing activity, or the issuance of any permit
necessary to commence a ground -disturbing activity.
C. The monitor will complete daily monitoring logs that will
provide descriptions of the relevant ground -disturbing
activities, the type of construction activities performed,
locations of ground -disturbing activities, soil types, and
cultural -related materials of significance to the Kizh Nation.
Monitor logs will identify and describe any discovered Native
American cultural and historical artifacts, remains, places of
significance, etc., (collectively, tribal cultural resources, or
"TCR"), as well as any discovered Native American
(ancestral) human remains and associated grave goods.
Copies of monitor logs will be provided to the project
applicant/lead agency upon written request to the consulting
tribe. If a monitor is selected from a tribe other than the Kizh
Nation, the Kizh Nation shall be contacted if any discoveries
are found.
d. On -site tribal monitoring shall conclude upon the latter of the
following (1 ) written confirmation to the monitor from a
designated point of contact for the project applicant/lead
agency that all ground -disturbing activities and phases that
may involve ground -disturbing activities and that have the
potential to impact local TCRs on the project site or in
connection with the project are complete; or (2) the monitor
determines based on field observations that there is no
likelihood of encountering intact TCRs. Monitoring may be
reduced in extent or frequency as determined appropriate
by the monitor.
City of Tustin 4-12
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
TCR-2: Unanticipated Discovery of Tribal Cultural Resource
Objects (Non-Funerary/Non-Ceremonial). Upon discovery of
any TCRs, all ground -disturbing activities in the immediate vicinity
of the discovery shall cease (i.e., not less than the surrounding 50
feet) and shall not resume until the discovered TCR has been
assessed by the tribal monitor and consulting archaeologist. If the
monitor is other than the Gabrielefio Band of Mission Indians —
Kizh Nation, the Kizh Nation shall be contacted and the monitor
and/or Kizh Nation will recover and retain all discovered TCRs in
the form and/or deemed appropriate, in agreement with Kizh
Nation including for educational, cultural and/or historic purposes.
TCR-3: Unanticipated Discovery of Human Remains and
Associated Funerary or Ceremonial Objects
a. Native American human remains are defined in PRC 5097.98
(d)(1) as an inhumation or cremation, and in any state of
decomposition or skeletal completeness. Funerary objects,
called associated grave goods in Public Resources Code
Section 5097.98, are also to be treated according to this
statute.
b. If Native American human remains are discovered or
recognized on the project site, then Health and Safety Code
Section 7050.5 shall be followed.
C. Human remains and associated grave goods shall be treated
in the same manner per California Public Resources Code
section 5097.98(d)(1) and (2).
d. Preservation in place (i.e., avoidance) is the preferred
manner of treatment for discovered human remains and/or
grave goods.
e. Any discovery of human remains/grave goods shall be kept
confidential to prevent further disturbance.
UTILITIES AND SERVICE SYSTEMS
PPP UT-1: California Building Code. All future development
constructed under the Project shall be subject to the latest version
of the California Building Code (CBC) which outlines regulations
for building planning and construction in the state, including
Implementation
Timing
During grading
During grading
Prior to grading or
demolition/building
permit approval;
during construction
activities
Responsible Party
Project developers/
applicant,
construction
contractors, Native
American Monitor
Project developers/
applicant,
construction
contractors, Native
American Monitor
Project developers/
applicants and
construction
contractors
Verification Method
The City Community
Development Dept.
will review project
plans and
specifications to
ensure these
requirements are
met and would
monitor to verify
compliance.
The City Community
Development Dept.
will review project
plans and
specifications to
ensure these
requirements are
met and would
monitor to verify
compliance.
The City Building
Division will examine
project contracts,
plans, and
specifications for
Date Completed and
Initials
Initials:
Date:
Initials:
Date:
Initials:
Date:
City of Tustin 4-13
Final EIR
September 2024
Enderle Center Rezone Project 4.0 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
occupancy classification, structural design, building materials,
these requirements
infrastructure needs and fire -resistance requirements.
and monitor for
compliance.
MM UT-1: Future proposed Projects shall prepare capacity
Prior to grading or
Project developers/
The City Public
analyses of existing water utilities in the area to ensure
building permit
applicant
Works Dept. will
Initials:
conveyance and pressure is adequate for future projects
approval
review the required
proposed. The developer shall then identify infrastructure
capacity analysis
Date:
improvements necessary for the proposed development. The
ensure adequate
developer will be responsible for preparing a capacity analysis
capacity is available
in coordination with the City. The capacity analysis and
prior to approval of
infrastructure improvements shall be reviewed and approved by
the construction
the City prior to approval of the construction permit.
permit.
MM UT-2: Future proposed Projects shall prepare capacity
Prior to grading or
Project developers/
The City Public
analyses of existing sewer utilities in the area to ensure
building permit
applicant
Works Dept. will
Initials:
conveyance and pressure is adequate for future projects
approval
review the required
proposed. The developer shall then identify infrastructure
capacity analysis
Date:
improvements necessary for the proposed development. The
ensure adequate
developer will be responsible for preparing a capacity analysis
capacity is available
in coordination with the EOCWD and the City. The developer shall
prior to approval of
then submit the sewer capacity analysis to the Orange County
the construction
Sanitation District (OC San) for review and verification that there
permit.
is available sewer capacity. The capacity analysis and
infrastructure improvements shall be reviewed and approved by
EOCWD, OC San, and the City prior to approval of the
construction permit.
City of Tustin 4-14
Final EIR
September 2024
EXHIBIT B
THE ENDERLE CENTER REZONE
PROJECT
SCH NO. 2024020747
prepared for
City of Tustin
300 Centennial Way
Tustin, CA 92780
prepared with the assistance of
EIRD Solutions Inc.,
Irvine, CA 92612
(949) 794-1180
4
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Mir
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aim
June 2024
Draft Environments
Impact Report -:4
V
M own
E P D%
SOLUTIONS,INC
E I P I D SOLUTIONS,INC
3333 Michelson Drive, Suite 500
Irvine, CA 92612
(949) 794-1 180
www.epdsolutions.com
Enderle Center Rezone
Table of Contents
Table of Contents
1. Executive Summary.................................................................................................................................. 1-1
2. Introduction................................................................................................................................................ 2-1
3. Project Description................................................................................................................................... 3-1
4. Environmental Setting..............................................................................................................................4-1
5. Environmental Impact Analysis............................................................................................................... 5-1
5.1 Air Quality...........................................................................................................................................5.1-1
5.2 Energy..................................................................................................................................................5.2-1
5.3 Greenhouse Gas Emissions................................................................................................................5.3-1
5.4 Land Use and Planning......................................................................................................................5.4-1
5.5 Noise.....................................................................................................................................................5.5-1
5.6 Population and Housing....................................................................................................................5.6-1
5.7 Public Services.....................................................................................................................................5.7-1
5.8 Recreation............................................................................................................................................5.8-1
5.9 Transportation.....................................................................................................................................5.9-1
5.10 Tribal Cultural Resources.............................................................................................................5.10-1
5.1 1 Utilities and Service Systems.......................................................................................................
5.1 1-1
6. Other CEQA Considerations..................................................................................................................6-1
7. Effects Found Not Significant.................................................................................................................7-1
8. Alternatives...............................................................................................................................................
8-1
9. EIR Preparers and Persons Contacted.................................................................................................
9-1
City of Tustin
Draft EIR
June 2024
Enderle Center Rezone Project Table of Contents
Figures
FIGURE3-1 : REGIONAL LOCATION....................................................................................................................................3-3
FIGURE3-2: LOCAL VICINITY.............................................................................................................................................3-5
FIGURE3-3: AERIAL VIEW..................................................................................................................................................3-7
FIGURE 3-4: EXISTING GENERAL PLAN LAND USE..........................................................................................................
3-1 3
FIGURE3-5: EXISTING ZONING......................................................................................................................................3-1
5
FIGURE3-6: PROPOSED ZONING...................................................................................................................................3-17
FIGURE 5-1 : CUMULATIVE PROJECTS.................................................................................................................................5-5
FIGURE 5.5-1 : NOISE MEASUREMENT LOCATIONS........................................................................................................5.5-9
FIGURE 5.5-2: AIRPORT NOISE CONTOURS................................................................................................................5.5-1
1
FIGURE5.9-1 : PROJECT CIRCULATION..........................................................................................................................5.9-7
FIGURE 5.9-2: LOW VMT GENERATING AREA - VMT PER CAPITA.............................................................................5.9-1
1
FIGURE 5.9-3: LOW VMT GENERATING AREA - VMT PER EMPLOYEE........................................................................5.9-1
3
Tables
TABLE 1 -1 : SUMMARY OF IMPACTS....................................................................................................................................1 -5
TABLE 2-1 : SUMMARY OF NOP COMMENT LETTERS.........................................................................................................2-3
TABLE 3-1 : SURROUNDING EXISTING LAND USE AND ZONING DESIGNATIONS...............................................................3-9
TABLE 3-2: EXISTING AND PROPOSED PROJECT SITE CHARACTERISTICS......................................................................... 3-1 0
TABLE 3-3: OPENING YEAR BUILDOUT SUMMARY..........................................................................................................3-1 1
TABLE 4-1 : SURROUNDING EXISTING LAND USE AND ZONING DESIGNATIONS...............................................................4-2
TABLE 5-1 : CUMULATIVE PROJECTS LIST............................................................................................................................5-3
TABLE 5.1 -1 : AMBIENT AIR QUALITY STANDARDS FOR CRITERIA POLLUTANTS.............................................................. 5.1-2
TABLE 5.1 -2: SOURCES AND HEALTH EFFECTS OF AIR POLLUTANTS............................................................................5.1 -1 2
TABLE 5.1 -3: AIR QUALITY MONITORING SUMMARY 2020-2022...........................................................................5.1 -1 5
TABLE 5.1 -4: ATTAINMENT STATUS OF CRITERIA POLLUTANTS IN THE SOUTH COAST AIR BASIN (SCAB)
.................5.1 -17
TABLE 5.1 -5: SCAQMD REGIONAL AIR QUALITY THRESHOLDS.................................................................................5.1 -1 8
TABLE 5.1 -6: SCAQMD LOCALIZED SIGNIFICANCE THRESHOLDS..............................................................................5.1 -1 8
TABLE 5.1 -7: TENTATIVE PROJECT CONSTRUCTION SCHEDULE...................................................................................5.1 -23
TABLE 5.1 -8: DIESEL CONSTRUCTION EQUIPMENT UTILIZED BY CONSTRUCTION PHASE.............................................5.1 -24
TABLE 5.1 -9: PROJECT CONSTRUCTION EMISSIONS...................................................................................................5.1 -24
TABLE 5.1 -1 0: PROJECT OPERATIONAL EMISSIONS....................................................................................................5.1 -25
TABLE 5.1 -1 1 : PROJECT LOCALIZED CONSTRUCTION EMISSIONS(LBS/DAY).............................................................5.1 -27
TABLE 5.1 -1 2: PROJECT LOCALIZED OPERATIONAL EMISSIONS (LBS/DAY)................................................................5.1 -27
TABLE 5.2-1 : ENERGY CONSUMPTION ESTIMATES DURING CONSTRUCTION................................................................5.2-7
TABLE 5.2-2: ENERGY CONSUMPTION ESTIMATES DURING OPERATION....................................................................... 5.2-7
TABLE 5.3-1 : GREENHOUSE GAS EMISSIONS (MT/YR)..............................................................................................5.3-1 2
TABLE 5.4-1: PROJECT CONSISTENCY WITH 2O20 SCAG CONNECT SOCAL REGIONAL
TRANSPORTATION
PLAN/SUSTAINABLE COMMUNITIES STRATEGY POLICIES.............................................................................................5.4-1 5
TABLE 5.4-2: PROJECT CONSISTENCY WITH 2O24 SCAG CONNECT SOCAL REGIONAL
TRANSPORTATION
PLAN/SUSTAINABLE COMMUNITIES STRATEGY POLICIES.............................................................................................5.4-18
TABLE 5.4-3: PROJECT CONSISTENCY WITH RELEVANT GENERAL PLAN GOALS, POLICIES, AND OBJECTIVES
........... 5.4-22
TABLE 5.5-1 : VIBRATION SCREENING STANDARDS........................................................................................................5.5-3
TABLE 5.5-2: CITY OF TUSTIN GENERAL PLAN NOISE ELEMENTSTANDARDS................................................................5.5-5
City of Tustin
Draft EIR
June 2024
Enderle Center Rezone Proiect Table of Contents
TABLE 5.5-3: CITY OF TUSTIN MUNICIPAL CODE RESIDENTIAL NOISE STANDARDS....................................................... 5.5-6
TABLE 5.5-4: SUMMARY OF 24-HOUR AMBIENT NOISE LEVEL MEASUREMENTS...........................................................
5.5-6
TABLE 5.5-5: CLOSEST SENSITIVE RECEPTORS TO THE PROJECT SITE.............................................................................
5.5-7
TABLE 5.5-6: CONSTRUCTION REFERENCE NOISE LEVELS............................................................................................5.5-1
5
TABLE 5.5-7: CONSTRUCTION NOISE LEVEL AT NEAREST RECEPTORS.........................................................................5.5-1
6
TABLE 5.5-8: TRAFFIC NOISE LEVELS WITHOUT AND WITH PROPOSED PROJECT......................................................5.5-18
TABLE 5.5-9: VIBRATION SOURCE LEVELS FOR CONSTRUCTION EQUIPMENT..............................................................
5.5-1 9
TABLE 5.5-1 0: CONSTRUCTION VIBRATION LEVELS AT NEAREST RECEPTORS.............................................................5.5-20
TABLE 5.6-1 : CITY OF TUSTIN RHNA BY INCOME LEVEL...............................................................................................5.6-2
TABLE 5.6-2: CITY AND COUNTY EXISTING AND PROJECTED POPULATION, 2019-2050..........................................
5.6-4
TABLE 5.6-3: CITY AND COUNTY HOUSING ESTIMATES BY TYPE 2023.......................................................................
5.6-4
TABLE 5.6-4: CITY AND COUNTY EXISTING AND PROJECTED HOUSING UNITS, 2019-2050....................................
5.6-5
TABLE 5.6-5: CITY AND COUNTY EXISTING AND PROJECTED EMPLOYMENT, 2019-2050.........................................
5.6-5
TABLE 5.6-6: JOBS — HOUSING TRENDS IN THE CITY OF TUSTIN..................................................................................
5.6-6
TABLE 5.7-1 : FIRE STATIONS NEAR THE PROJECT SITE...................................................................................................5.7-3
TABLE 5.7-2: FIRE STATIONS CALLS FOR SERVICE AND RESPONSE DATA — 2023........................................................
5.7-4
TABLE 5.7-3: EXISTING SCHOOL CAPACITY OF SCHOOLS SERVING THE PROJECT SITE .............................................
5.7-1 1
TABLE 5.7-4: TUSTIN UNIFIED SCHOOL DISTRICT STUDENT GENERATION RATES ........................................................
5.7-1 2
TABLE 5.7-5: STUDENTS AT PROJECT BUILDOUT..........................................................................................................5.7-1
2
TABLE 5.7-6: REMAINING SCHOOL CAPACITY WITH BUILDOUT OF THE PROPOSED PROJECT ....................................
5.7-1 3
TABLE 5.8-1 : TUSTIN PARK FACILITIES WITHIN 2 MILES OF THE PROJECT SITE..............................................................
5.8-3
TABLE 5.9-1 : EXISTING ROADWAY CHARACTERISTICS WITHIN SPECIFIC PLAN STUDY AREA........................................5.9-5
TABLE 5.9-2: PROPOSED PROJECT TRIP GENERATION................................................................................................5.9-18
TABLE 5.9-3: VMT ANALYSIS OF RESIDENTIAL OF PROJECT IMPACT PER CITY GUIDELINES........................................5.9-20
TABLE 5.9-4: VMT ANALYSIS OF COMMERCIAL PART OF PROJECT IMPACT PER CITY GUIDELINES............................5.9-21
TABLE 5.11 -1 : TUSTIN PROJECTED WATER SUPPLY.....................................................................................................5.1
1 -3
TABLE 5.1 1 -2: WATER SUPPLY AND DEMAND DURING NORMAL, DRY, AND MULTIPLE DRY YEAR SCENARIOS
(AF) 5.1 1 -4
TABLE 5.11 -3: SOLID WASTE DEMAND FROM OPERATION OF THE PROPOSED PROJECT .......................................
5.1 1 -24
TABLE 8-1 : IMPACT COMPARISON OF THE PROPOSED PROJECT AND ALTERNATIVES.....................................................
8-1 5
TABLE 8-2: COMPARISON OF THE PROPOSED PROJECT AND ALTERNATIVES' ABILITY TO MEET OBJECTIVES
................. 8-1 6
Appendices
APPENDIX A NOTICE OF PREPARATION, SCOPING COMMENTS, AND INITIAL STUDY
APPENDIX B AIR QUALITY, ENERGY, AND GREENHOUSE GAS REPORT
APPENDIX C NOISE AND VIBRATION IMPACT ANALYSIS
APPENDIX D VEHICLE MILES TRAVELED ANALYSIS
APPENDIX E ARCHAEOLOGICAL RESOURCES RECORDS SEARCH
City of Tustin iii
Draft EIR
June 2024
Enderle Center Rezone
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City of Tustin
Draft EIR
June 2024
Enderle Center Rezone Project 1.0 Executive Summary
1. Executive Summary
This Draft Environmental Impact Report (EIR) evaluates the environmental effects that may result from the
construction and operation of the Enderle Center Rezone Project (proposed Project). This EIR has been
prepared in conformance with State and City of Tustin environmental policy guidelines for the implementation
of the California Environmental Quality Act (CEQA).
This Draft EIR is being circulated for review and comment by the public and other interested parties, agencies,
and organizations for 45 days in accordance with Section 15087 and Section 15105 of the CEQA
Guidelines. During the 45-day review period, the Draft EIR will be available for public review at the City
of Tustin website(www.tustinca.orci /Housing ElementRezone).
A physical copy is available for review at the following locations:
City of Tustin Orange County Library — Tustin Branch
300 Centennial Way 345 E. Main Street
Tustin, CA 92780 Tustin, CA 92780
Written comments related to environmental issues in the Draft EIR should be addressed to:
Samatha Beier, Senior Planner
Community Development Department
300 Centennial Way, Tustin, CA 92780
Housing ElementRezone@tustinca.org
A Notice of Availability of the Draft EIR was published concurrently with distribution of this document.
1.1 PROJECT BACKGROUND
The City of Tustin is required by State law to periodically update its Housing Element, a mandatory
component of the City's General Plan. The Housing Element is the City's housing policy and planning document
that identifies housing needs and constraints, and sets forth goals, policies, and programs that address the
future housing needs for all income levels over an eight -year planning period that coincides with a Regional
Housing Needs Allocation (RHNA). The City of Tustin prepared the 2021-2029 Housing Element of the
General Plan — the most recent update to the Housing Element that covers the Sixth Cycle planning period
from October 15, 2021, to October 15, 2029 — in accordance with Government Code Section 65580 et
seq. (Housing Elements).
On October 5, 2021, the City Council adopted Resolution No. 21-86, certifying the Negative Declaration
(ND) for General Plan Amendment (GPA) 2021-0002, which analyzed environmental impacts related to the
City's Draft Housing Element Update of the General Plan (Resolution No. 21-87, approving GPA 2021-
0002). Following preparation of the Draft Housing Element Update and certification of the ND, the Draft
Housing Element went through several rounds of revisions and submittal for review to the State Department
of Housing and Community Development (HCD). The City received formal HCD certification of the Housing
Element Update on September 12, 2022. On October 4, 2022, the City Council adopted Resolution No. 22-
47, approving GPA 2022-0002 for the final Housing Element Update.
The 2021-2029 Housing Element includes several provisions that aim to ensure the City can meet the required
"fair share" of affordable housing units, as specified by the State of California. During the Housing Element
process, the City assessed a number of sites and areas throughout the community that would be able to
accommodate the City's assigned 2021 Regional Housing Needs Allocation (RHNA). The City identified 19
City of Tustin 1 -1
Draft EIR
June 2024
Enderle Center Rezone Project 1.0 Executive Summary
sites and one housing category (accessory dwelling units [ADUs]/junior accessory dwelling units [JADUs]) as
qualifying sites to accommodate its RHNA allocation. Of the 19 Housing Element inventory sites, The Market
Place (Housing Element Site 18) was identified as necessary for rezoning under Housing Element Program
1.1 f in order to allow for high density residential development.
1.2 PROJECT LOCATION
The Project site is approximately 1 1.80 acres and is located within the City of Tustin. The City is in the central
portion of Orange County and is surrounded by the cities of Irvine to the south, Santa Ana to the west,
Orange and unincorporated Orange County to the north; and unincorporated Orange County to the east.
Major freeways and highways within or bordering the City of Tustin are the 1-5 freeway through the center,
State Route (SR) 55 to the west, SR 261 to the east, and the 1-405 freeway to the south, as illustrated in
Figure 3-1, Regional Location.
The Project site consists of Assessor Parcel Numbers (APNs) 401-251-04, -05, and -06; 401-252-05, -06, -
08, -09, and -10; and 401-253-03 and -04. The Project site is generally bounded on the north by 17th
Street; on the east by Enderle Center Drive and the eastern property line of properties fronting Enderle
Center Drive; to the south by Vandenberg Lane; and to the west by the 55 freeway, including properties
west of Yorba Street. The local vicinity of the Project site is illustrated in Figure 3-2, Local Vicinity.
1.3 PROJECT DESCRIPTION SUMMARY
Pursuant to Housing Element Program 1.1 f, the City is proposing an overlay zone ("overlay district") for the
project site. To accommodate this, a General Plan Amendment (GPA) is needed to establish that higher
density residential uses are allowed in the Planned Community Commercial Business (PCCB) land use
designation when prescribed by a Housing Overlay (HO) district or a Specific Plan (SP); a Zoning Code
Amendment (ZCA) to establish Housing Overlay as an overlay zone in conjunction with the Planned
Community Commercial districts (base zone); and a Zone Change (ZC) that amends the City's zoning map to
apply a Housing Overlay ("HO") district to the project site.
The Housing Element identified Enderle Center as having capacity for 413 housing units. The anticipated
development density was determined through the Housing Element process and is a conservative estimate
based on development trends in nearby communities. The anticipated development does not rely on the
demolition of any existing building, but rather focuses on areas used for surface parking. No specific
development is proposed as part of this Project, but this Draft EIR has analyzed all known anticipated impacts
of the development of the proposed housing units.
Proposed Housing Overlay District. In addition to the permitted uses under the existing PC COM zoning, the
overlay zone would allow residential land uses. Thus, the HO would be added "on top" of the existing PC
COM zone (i.e., Base Zone). The overlay zone would also provide development standards related to parking,
height, noise, and other standards applicable to residential uses. The HOD text would include a provision
that the HOD supersedes the development standards and allowed uses listed within the Base Zone.
Residential uses are currently not allowed on the Project site. Upon approval of the HOD, the Project site
could accommodate 413 units over approximately 7 acres of developable land within the existing 1 1.8-
acre site. This would result in a density of 59 du/ac. The anticipated development over 7 acres may take
place on underutilized asphalt parking lot areas, and would not require demolition of any existing buildings.
Parking displaced as a result of redevelopment would be accommodated by vertical parking structures
located within the proposed development.
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Enderle Center Rezone Project 1.0 Executive Summary
Infrastructure. Roadways and utilities may be required to support development of future residential
construction within the Project site. Future onsite infrastructure improvements that may be necessary for
residential development within the Enderle Center include storm drains, wastewater, water, and dry utilities
that would connect to existing facilities within the Project site or adjacent to the Project area. Specific
infrastructure improvements required to support residential development within the Enderle Center are not
known at this time and will not be known until a development project is proposed.
1.4 PROJECT OBJECTIVES
CEQA Guidelines §151 24(b) (14 California Code of Regulations [CCR]) requires "A statement of objectives
sought by the proposed project. A clearly written statement of objectives would help the Lead Agency
develop a reasonable range of alternatives to evaluate in the EIR and would aid the decision makers in
preparing findings or a statement of overriding considerations, if necessary. The statement of objectives
should include the underlying purpose of the project."
The primary purpose and goal of the Project is to accommodate the City's 6th Cycle RHNA identified within
the City of Tustin 2021-2029 Housing Element. The Project would achieve this goal through the following
objectives:
a. Creation of a Housing Overlay District to allow residential development at densities to
achieve the estimated capacities determined in the Housing Element and without inhibitors
to residential development.
b. Increase the number of housing opportunities available in Tustin to ensure the City provides
its fair share of housing units within a variety of income categories.
c. Increase flexibility in allowed uses and development potential in an underutilized area of
the City of Tustin.
2. Promote a diverse housing stock with products that are offered at a wide range of sizes and
affordability.
1.5 SUMMARY OF ALTERNATIVES
Section 8.0, Alternatives, of this EIR analyzes a range of reasonable alternatives to the proposed Project.
The alternatives that are analyzed in detail in Section 8.0 are summarized below.
• No Project/No Development Alternative. This alternative consists of the Project not being approved,
and the Project site would remain in the conditions that existed at the time the Notice of Preparation was
published (February 16, 2024).
• Reduced Nonresidential Project Alternative. The Reduced Nonresidential Project alternative would
allow for the same potential future development of housing units to occur as proposed by the Project,
but with a reduction of nonresidential uses of 35 percent. The Reduced Nonresidential Project Alternative
would allow for the potential future buildout of 413 residential units and 46,510 SF of new
nonresidential development. The reduced nonresidential square footage would allow for increased
setbacks, passenger vehicle parking, and truck parking. Areas planned for physical impact would be
identical to those required for development of the proposed Project. This alternative would still require
a General Plan Amendment (GPA), adoption of a zone change and a Zoning Code Amendment (ZCA),
and development of Objective Design Standards (ODS).
• Alternate Site Alternative. An alternate site for the Project was eliminated from further consideration.
Any alternate site would need to occur within the City of Tustin. The City is required by state law to
rezone housing shortfall sites according to what has been approved under the certified Housing Element
(Government Code § 65583.2, Senate Bill 197). The site identified within the City's 2021 -2029 Housing
City of Tustin 1-3
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Enderle Center Rezone Project 1.0 Executive Summary
Element is Enderle Center (Project site), and an alternate site would fail to meet most of the project
objectives, is infeasible, and would not be compliant with state law or the City's Housing Element.
Additionally, if the Project were to occur on an alternate site and rezoning were conducted within a
different commercial center in the City, similar impacts would result and comparable mitigation would
be required; therefore, impacts would not be reduced under this alternative. Therefore, this alternative
has been determined infeasible.
• No Project/Buildout of Existing Land Use Alternative. A No Project/Buildout of Existing Land Use
alternative was eliminated for further consideration. Under this alternative, buildout of the nonresidential
uses would occur as permitted under the existing land use designations, but the Project site would not be
rezoned to allow for residential uses. The City is required by state law to rezone housing shortfall sites
according to what has been approved under the certified Housing Element (Government Code §
65583.2, Senate Bill 197). The site identified within the City's 2021-2029 Housing Element is Enderle
Center (Project site) and failing to rezone the site for future housing would fail to meet all of the project
objectives, which would therefore render the alternative as infeasible, and further, would not be
compliant with state law or the City's Housing Element.
• Reduced Project Development. A Reduced Project Development Alternative was eliminated from further
consideration. The Reduced Project Development alternative would redesignate the Project site to allow
for development of future residential and additional square footage of nonresidential development,
similar to the proposed Project. However, Project buildout would be reduced by 20 percent for
residential and by 95 percent for new nonresidential, limiting the overall future buildout to a maximum
of 330 residential units and 4,787 SF (91,923 SF total) of additional nonresidential development. This
alternative would still require approval of the Housing Overlay (HO) District, a General Plan Amendment
(GPA), adoption of a zone change, adoption of a zoning code amendment (ZCA), and development of
Objective Design Standards (ODS). This alternative would eliminate the Project's significant and
unavoidable GHG impact by reducing GHG emissions 77 percent, from 12,804 MT CO2e/yr. net new
emissions (Project buildout minus existing use) to 2,999 MT CO2e/yr, proportional to the proposed
reduction in development. However, under this alternative, only five percent of the additional
nonresidential square footage (above and beyond what is existing) currently allowed under existing
provisions would be developed. Furthermore, under this alternative, only 330 dwelling units would be
allowed to be constructed and the City would have an 83 dwelling unit deficit in meeting their state
mandated RHNA fair share. Because this alternative would not meet the City's legal obligation to rezone
the site to meet the necessary residential capacity consistent with the City's certified Housing Element
Update, this alternative has been rendered infeasible and is rejected from further consideration.
1.6 SUMMARY OF IMPACTS
Table 1-1 summarizes the conclusions of the environmental analysis contained in this Draft EIR. Section 7.0,
Effects Not Found Significant, establishes that the proposed Project would not result in impacts related to
certain thresholds from CEQA Appendix G including Aesthetics, Agricultural Resources, Biological Resources,
Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Mineral Resources, and Wildfire.
Thus, no further assessment of those impacts was required in the Draft EIR. Therefore, the numbering of
impacts shown in Table 1-1 reflects the omission of further evaluation for certain thresholds.
Relevant standard conditions of approval are identified, and mitigation measures are provided for all
potentially significant impacts. The level of significance of impacts after the proposed mitigation measures
are applied are identified as either significant and unavoidable, less than significant, or no impact.
City of Tustin 1-4
Draft EIR
June 2024
Enderle Center Rezone
Table 1-1: Summary of Impacts
1.0 Executive
Impact
Applicable Standard Condition,
Level of Significance
Mitigation Measures
Level of Significance
Plan, Program, or Policy (PPP),
Before Mitigation
After Mitigation
or Project Design Feature (PDF)
5.1 Air Quality
Impact AQ-1: Would the Project
No Impact
None required
No impact
conflict with or obstruct
implementation of the applicable
air quality plan?
Impact AQ-2: Would the Project
PPP AQ-1: Rule 403. The Project
Less than Significant
None required
Less than Significant
result in a cumulatively
is required to comply with the
considerable net increase of any
provisions of South Coast Air
criteria pollutant for which the
Quality Management District
Project region is non -attainment
(SCAQMD) Rule 403, which
under an applicable federal or
includes the following:
State ambient air quality
standard?
• All clearing, grading, earth -
moving, or excavation
activities shall cease when
winds exceed 25 mph per
SCAQMD guidelines in order
to limit fugitive dust
emissions.
• The contractor shall ensure
that all disturbed unpaved
roads and disturbed areas
within the project are
watered, with complete
coverage of disturbed
areas, at least 3 times daily
during dry weather;
preferably in the mid-
morning, afternoon, and
after work is done for the
day.
The contractor shall ensure that
traffic speeds on unpaved roads
and Project site areas are
City of Tustin 1-5
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Level of Significance
Mitigation Measures
Level of Significance
Plan, Program, or Policy (PPP),
Before Mitigation
After Mitigation
or Project Design Feature (PDF)
reduced to 15 miles per hour or
less.
Impact AQ-3: Would the Project
PPP AQ-1: Rule 403. As listed
Potentially Significant
Mitigation Measure AIR-1. Prior
Significant and
expose sensitive receptors to
above.
to discretionary approval by the
Unavoidable
substantial pollutant
PPP AQ-2: Rule 1113. The
City of Tustin (City) for residential
concentrations?
Project is required to comply with
development projects subject to
the provisions of South Coast Air
California Environmental Quality
Quality Management District Rule
Act (CEQA) review, project
(SCAQMD) Rule 1113. Only
applicants shall prepare and
"Low -Volatile Organic
submit a technical assessment
Compounds" paints (no more than
evaluating potential project-
50 gram/liter of VOC) and/or
related air quality impacts,
High Pressure Low Volume (HPLV)
including a localized impacts
applications shall be used.
analysis, to the City for review and
approval. The analysis shall be
prepared in conformance with
South Coast Air Quality
Management District (SCAQMD)
methodology. If project -related
emissions exceed applicable
SCAQMD thresholds of
significance, the City shall require
that applicants for new
development projects incorporate
mitigation measures to reduce
emissions. The identified measures
shall be included as part of the
conditions of approval.
Additionally, if project -related
localized emissions exceed the
SCAQMD's thresholds, a dispersion
modeling analysis shall be
conducted to calculate potential
health risk from project
implementation.
Impact AQ-4: Would the Project
PPP AQ-4: Rule 402. The Project
Less than Significant
None required
Less than Significant
result in other emissions (such as
is required to comply with the
those leading to odors) adversely
provisions of South Coast Air
City of Tustin 1-6
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
affecting a substantial number of
Quality Management District
people?
(SCAQMD) Rule 402. The Project
shall not discharge from any
source whatsoever such quantities
of air contaminants or other
material which cause injury,
detriment, nuisance, or
annoyance to any considerable
number of persons or to the
public, or which endanger the
comfort, repose, health or safety
of any such persons or the public,
or which cause, or have a natural
tendency to cause, injury or
damage to business or property
Cumulative
PPP AQ-1: Rule 403. As listed
Potentially Significant
Mitigation Measure AIR-1. As
Significant and
above.
listed previously.
Unavoidable
PPP AQ-2: Rule 1113. As listed
above.
PPP-AQ-3: Rule 402. As listed
above.
5.2 Energy
Impact ENE-1: Would the Project
PPP E-1: CalGreen Compliance:
Less than Significant
None required
Less than Significant
result in potentially significant
The Project is required to comply
environmental impact due to
with the CalGreen Building Code
wasteful, inefficient, or
to ensure efficient use of energy.
unnecessary consumption of
CalGreen specifications are
energy resources, during project
required to be incorporated into
construction or operation?
building plans as a condition of
building permit approval.
Impact ENE-2: Would the Project
PPP E-1: CalGreen Compliance.
Less than Significant
None required
Less than Significant
conflict with or obstruct a State or
As listed above.
local plan for renewable energy
or energy efficiency?
Cumulative
PPP E-1: CalGreen Compliance.
Less than Significant
None required
Less than Significant
As listed above.
City of Tustin 1-7
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Level of Significance
Mitigation Measures
Level of Significance
Plan, Program, or Policy (PPP),
Before Mitigation
After Mitigation
or Project Design Feature (PDF)
5.3 Greenhouse Gas Emissions
Impact GHG-1: Would the
PPP E-1: CALGreen Compliance.
Potentially Significant
Mitigation Measure GHG-1. Prior
Significant and
Project generate greenhouse gas
As listed above.
to discretionary approval by the
Unavoidable
emissions, either directly or
City of Tustin (City) for future
indirectly, that may have a
development projects, project
significant impact on the
applicants shall prepare and
environment?
submit a technical assessment
evaluating potential project -
related greenhouse gas (GHG)
impacts to the City for review and
approval. The evaluation shall be
prepared in conformance with
South Coast Air Quality
Management District (SCAQMD)
methodology. If project -related
GHG emissions exceed applicable
SCAQMD thresholds of
significance and/or Statewide
GHG reduction targets, the City
shall require that applicants for
new development projects
incorporate mitigation measures to
reduce GHG emissions. Mitigation
measures could include, but are not
limited, to energy efficiency
measures, water conservation and
efficiency measures, solid waste
measures, and transportation and
motor vehicles measures. The
identified measures shall be
included as part of the conditions
of approval.
Impact GHG-2: Would the
PPP E-1: CALGreen Compliance.
Potentially Significant
Mitigation Measure GHG-1. As
Significant and
Project conflict with an applicable
As listed above.
listed above.
Unavoidable
plan, policy, or regulation
adopted for the purpose of
reducing the emissions of
greenhouse gases?
City of Tustin 1-8
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Level of Significance
Mitigation Measures
Level of Significance
Plan, Program, or Policy (PPP),
Before Mitigation
After Mitigation
or Project Design Feature (PDF)
Cumulative
PPP E-1: CALGreen Compliance.
Potentially Significant
Mitigation Measure GHG-1. As
Significant and
As listed above.
listed above.
Unavoidable
5.4 Land Use and Planning
Impact LU-2: Would the Project
PPP GEO-1: CBC Title 24, Part 2.
Less than Significant
None required
Less than Significant
cause a significant environmental
Structures built in the City are
impact due to a conflict with any
required to be built in compliance
land use plan, policy, or
with the CBC (California Code of
regulation adopted for the
Regulations, Title 24, Part 2) that
purpose of avoiding or mitigating
provides provisions for
an environmental effect?
earthquake safety based on
factors including building
occupancy type, the types of soils
onsite, and the probable strength
of ground motion. Compliance
with the CBC would require the
incorporation of 1 ) seismic safety
features to minimize the potential
for significant effects as a result
of earthquakes; 2) proper
building footings and
foundations; and 3) construction
of the building structure so that it
would withstand the effects of
strong ground shaking.
Implementation of CBC standards
would be verified by the City
during the plan check and
permitting process.
PPP HYD-1: SWPPP. Prior to
issuance of any grading or
demolition permits, the applicant
shall provide the City Building
Division evidence of compliance
with the NPDES (National
Pollutant Discharge Elimination
System) requirement to obtain a
construction permit from the State
Water Resource Control Board
City of Tustin 1-9
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
(SWRCB). The permit requirement
applies to grading and
construction sites of one acre or
larger. The Project
applicant/proponent shall
comply by submitting a Notice of
Intent (NOI) and by developing
and implementing a Stormwater
Pollution Prevention Plan
(SWPPP) and a monitoring
program and reporting plan for
the construction site.
PPP HYD-2: City of Tustin
Grading Manual. All future
projects are required to comply
with the City of Tustin Grading
Manual (1990). Implementation
of grading manual standards
would be verified by the City
during the plan check and
permitting process.
PPP HYD-3: WQMP. Prior to the
approval of the Grading Plan
and issuance of Grading Permits
a completed Water Quality
Management Plan (WQMP) shall
be prepared by the Project
applicant and submitted to and
approved by the City Public
Works Department. The WQMP
shall identify all Post -
Construction, Site Design. Source
Control, and Treatment Control
Best Management Practices
(BMPs) that will be incorporated
into the development Project in
order to minimize the adverse
effects on receiving waters.
City of Tustin 1-10
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June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
PPP T-1: Sidewalk Standards.
Sidewalks shall be provided on a
private street for attached and
detached residential products in
accordance with Standard B102
of the City's Construction
Standards, Storm Drain and On -
Site Private Improvements, and is
subject to compliance with
applicable accessibility
requirements of the American
Disabilities Act, Title 24 of the
Uniform Building Code as locally
amended, and the Department of
Housing and Urban
Development's Fair Housing
Accessibility Guidelines.
PPP T-2: Traffic
Control/Utilities. All future
development constructed under
the Project shall be subject to the
traffic control standards specified
by the City's latest Standard
Plans and Design Standards,
which includes the requirement for
Traffic Control Plan during
construction, the process prior to
commencing construction within
the City public right-of-way
(including utility work), and
specifications for operational
roadway and traffic control
design
Cumulative
PPP GEO-1: CBC Title 24, Part 2.
Less than Significant
None required.
Less than Significant
As listed above.
PPP HYD-1: SWPPP. As listed
above.
City of Tustin
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
PPP HYD-2: City of Tustin
Grading Manual. As listed
above.
PPP HYD-3: WOMP. As listed
above.
PPP T-1: Sidewalk Standards. As
listed above.
PPP T-2: Traffic
Control/Utilities. As listed above.
5.5 Noise
Impact NOI-1: Would the Project
PPP NOW: Construction Hours.
Potentially Significant
Mitigation Measure NOI-1: All
Less than Significant
result in generation of a
Per the Tustin City Code Section
future development shall prepare
substantial temporary or
4616, construction activities are
a project -specific Final Acoustical
permanent increase in ambient
allowed only between the hours
Report to confirm whether any
noise levels in the vicinity of the
of 7:00 AM and 6:00 PM,
proposed exterior noise sensitive
Project in excess of standards
Monday through Friday and
areas would experience noise
established in the local general
between 9:00 AM to 5:00 PM on
levels greater than 65 dBA CNEL
plan or noise ordinance, or
Saturdays with no activity
and whether interior noise levels
applicable standards of other
allowed on Sundays and City-
would exceed 45 dBA CNEL and
agencies?
observed federal holidays.
identify any noise reduction
features for the proposed
development (e.g. upgraded
windows with Sound Transmission
Class (STC) ratings of 30-35).
Additionally, the Final Acoustical
Report shall confirm that proposed
siting of noise -generating
stationary sources, if any, will not
result in an exceedance of
applicable noise thresholds at
surrounding land uses.
Impact NOI-2: Would the Project
PPP NOW: Construction Hours.
Less than Significant
None required
Less than Significant
result in generation of excessive
As listed above.
groundborne vibration or
groundborne noise levels?
Impact NOW: For a project
No Impact
None required.
No Impact
located within the vicinity of a
City of Tustin 1 -1 2
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
private airstrip or an airport land
use plan or, where such a plan has
not been adopted, within two
miles of a public airport or public
use airport, would the Project
expose people residing or
working in the Project area to
excessive noise levels?
Cumulative
PPP N0I-1: Construction Hours.
Potentially Significant
Mitigation Measure NOW. As
Less than Significant
As listed above.
listed above.
5.6 Population and Housing
Impact POP-1: Would the Project
Less than Significant
None required.
Less than Significant.
induce substantial unplanned
population growth in an area,
either directly (for example, by
proposing new homes and
businesses) or indirectly (for
example, through extension of
roads or other infrastructure)?
Cumulative
Less than Significant
None required.
Less than Significant.
5.7 Public Services
Impact PS-1: Would the Project
PPP PS-1: OCFA Fire Prevention
Less than Significant
None required.
Less than Significant.
result in substantial adverse
Guideline B-09, Fire Master Plans
physical impacts associated with
for Commercial and Residential
the provision of new or physically
Development.
altered governmental facilities,
PPP PS-2: Tustin Code of
need for new or physically
Ordinances Chapter 8100;
altered governmental facilities,
Building and Construction Codes
the construction of which could
Adopted by Reference.
cause significant environmental
PPP PS-3: Government Code
impacts, in order to maintain
Section 65995(b).
acceptable service ratios,
response times, or other
performance objectives for any
of the public services:
(i) Fire protection?
City of Tustin 1 -1 3
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
(ii) Police protection?
(iii) Schools?
(iv) Parks?
(v) Other public facilities?
Cumulative
PPP PS-1: As listed above.
Less than Significant
None required.
Less than Significant.
PPP PS-2 : As listed above.
PPP PS-3: As listed above.
5.8 Recreation
Impact REC-1: Would the Project
PPP R-1: City Park
Less than Significant
None required.
Less than Significant
increase the use of existing
Requirements. Tustin City Code
neighborhood and regional
Section 9331 — Dedications,
parks or other recreational
Reservations and Development
facilities such that substantial
Fees. All future development shall
physical deterioration of the
be consistent with this standard.
facility would occur or be
accelerated?
Impact REC-2: Does the Project
PPP R-1: City Park
Less than Significant
None required.
Less than Significant
include recreational facilities or
Requirements. As listed above.
require the construction or
expansion of recreational
facilities which might have an
adverse physical effect on the
environment?
Cumulative
PPP R-1: City Park
Less than Significant
None required.
Less than Significant
Requirements. As listed above.
5.9 Transportation
Impact TRA-1: Would the Project
Less than Significant
None required
Less than Significant
conflict with a program, plan,
ordinance, or policy addressing
the circulation system, including
transit, roadway, bicycle, and
pedestrian facilities?
Impact TRA-2: Would the Project
Less than Significant
None required
Less than Significant
conflict or be inconsistent with
City of Tustin 1-14
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Level of Significance
Mitigation Measures
Level of Significance
Plan, Program, or Policy (PPP),
Before Mitigation
After Mitigation
or Project Design Feature (PDF)
CEQA Guidelines § 15064.3,
subdivision (b)?
Impact TRA-3: Would the Project
PPP T-1: Sidewalk Standards.
Less than Significant
None required
Less than Significant
substantially increase hazards
Sidewalks shall be provided on a
due to a geometric design
private street for attached and
feature (e.g., sharp curves or
detached residential products in
dangerous intersections) or
accordance with Standard B102
incompatible uses (e.g., farm
of the City's Construction
equipment)?
Standards, Storm Drain and On -
Site Private Improvements, and is
subject to compliance with
applicable accessibility
requirements of the American
Disabilities Act, Title 24 of the
Uniform Building Code as locally
amended, and the Department of
Housing and Urban
Development's Fair Housing
Accessibility Guidelines.
PPP T-2: Traffic Control/Utilities.
All future development
constructed under the Project shall
be subject to the traffic control
standards specified by the City's
latest Standard Plans and Design
Standards, which includes the
requirement for Traffic Control
Plan during construction, the
process prior to commencing
construction within the City public
right-of-way (including utility
work), and specifications for
operational roadway and traffic
control design.
Impact TRA-4: Would the Project
PPP T-1: Sidewalk Standards. As
Less than Significant
None required
Less than Significant
result in inadequate emergency
listed above.
access?
PPP T-2: Traffic Control/Utilities.
As listed above.
City of Tustin 1 -15
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Level of Significance
Mitigation Measures
Level of Significance
Plan, Program, or Policy (PPP),
Before Mitigation
After Mitigation
or Project Design Feature (PDF)
Cumulative
PPP T-1: Sidewalk Standards. As
Less than Significant
None required
Less than Significant
listed above.
PPP T-2: Traffic Control/Utilities.
As listed above.
5.10 Tribal Cultural Resources
Impact TCR-1: Would the Project
PPP TCR-1: Native American
Potentially Significant
Less than Significant
cause a substantial adverse
historical and cultural resources
Mitigation Measure TCR-1:
change in the significance of a
and sacred sites are protected
Retain a Native American
tribal cultural resource, defined in
under PRC Sections 5097.9 to
Monitor Prior to Commencement
Public Resources Code § 21074
5097.991, which require that
of Ground -Disturbing Activities.
as either a site, feature, place,
descendants be notified when
a. Prior to the issuance of
cultural landscape that is
Native American human remains
demolition or grading permits
geographically defined in terms
are discovered and provide for
for any projects that would
of the size and scope of the
treatment and disposition of
disturb previously undisturbed
landscape, sacred place, or
human remains and associated
soils (native soils) or soils that
object with cultural value to a
grave goods.
have native fill, the project
California Native American tribe,
PPP CUL-1: Human Remains.
applicant/developer shall
and that is:
Should human remains or
retain a Native American
(i) Listed or eligible for listing in
funerary objects be discovered
Monitor, with first preference
the California Register of
during Project construction, the
given to the Gabrieleno Band
Historical Resources, or in a local
Project would be required to
of Mission Indians — Kizh
register of historical resources as
comply with State Health and
defined in Public Resources Code
Safety Code Section 7050.5,
Nation, who responded to the
section 5020.1(k)?
which states that no further
City's request for consultation
(ii) A resource determined by the
disturbance may occur in the
on November 14, 2023 (first
lead agency, in its discretion and
vicinity of the body (within a 100-
preference Tribe, Tribe). The
supported by substantial
foot buffer of the find) until the
applicant/developer shall
evidence, to be significant
County Coroner has made a
allow 45 days from the initial
pursuant to criteria set forth in
determination of origin and
contact with the first
subdivision (c) of Public Resources
disposition pursuant to Public
preference tribe to enter into
Code § 5024.1, the lead agency
Resources Code Section 5097.98.
a contract for monitoring
shall consider the significance of
The County Coroner must be
services. If the
the resource to a California
notified of the find immediately.
applicant/developer is
Native American tribe?
If the remains are determined to
unable to contact the Kizh
be prehistoric, the Coroner will
Nation after three
notify the Native American
Heritage Commission, which will
documented attempts or is
determine the identity of and
unable to secure an
City of Tustin 1 -1 6
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
notify a Most Likely Descendant
agreement, the applicant shall
(MLD). With the permission of the
report to the lead agency and
landowner or his/her authorized
who will contact the Kizh
representative, the MILD may
Nation to validate that the
inspect the site of the discovery.
parties were unable to enter
The MILD must complete the
into an agreement. The
inspection within 48 hours of
applicant/developer shall
notification by the NAHC.
have made three documented
attempts to contact the Kizh
Nation directly to enter into a
tribal monitoring agreement.
If the applicant/developer
can demonstrate they were
unable to secure an
agreement with the first
preference tribe, as validated
and documented by the
Community Development
Department in writing, or if the
contracted tribe fails to fulfill
its obligation under the
contract terms, then the
applicant/developer may
retain an alternative qualified
tribal monitor from a culturally
affiliated tribe if approved
by the City.
The monitor shall be retained
prior to the issuance of a
demolition permit or grading
permit, and the
commencement of any
development related
"ground -disturbing activity"
for the subject project at all
project locations (i.e., both on -
City of Tustin 1 -17
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
site and any off -site locations
that are included in the project
description/definition and/or
required in connection with the
project, such as public
improvement work). "Ground -
disturbing activity" shall
include, but is not limited to,
demolition, pavement
removal, auguring, grubbing,
boring, grading, excavation,
drilling, and trenching for the
purposes of reconstruction and
new development. "Ground -
disturbing activity" shall not
include minor maintenance
activities such as potholing,
tree removal, and parking lot
maintenance. This mitigation
measure does not apply to
projects that would only
disturb soils made up of
artificial fill, as verified by a
soils or geotechnical report.
b. A copy of the executed
monitoring agreement shall be
submitted to the lead agency
prior to the commencement of
any ground -disturbing
activity, or the issuance of any
permit necessary to commence
a ground -disturbing activity.
C. The monitor will complete
daily monitoring logs that will
provide descriptions of the
City of Tustin 1 -1 8
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
relevant ground -disturbing
activities, the type of
construction activities
performed, locations of
ground -disturbing activities,
soil types, cultural -related
materials, and any other facts,
conditions, materials, or
discoveries of significance to
the Kizh Nation. Monitor logs
will identify and describe any
discovered TCRs, including but
not limited to, Native
American cultural and
historical artifacts, remains,
places of significance, etc.,
(collectively, tribal cultural
resources, or "TCR"), as well
as any discovered Native
American (ancestral) human
remains and burial goods.
Copies of monitor logs will be
provided to the project
applicant/lead agency upon
written request to the
consulting tribe. If a monitor is
selected from a tribe other
than the Kizh Nation, the Kizh
Nation shall be contacted if
any discoveries are found.
d. On -site tribal monitoring shall
conclude upon the latter of the
following 0 ) written
confirmation to the consulting
tribe from a designated point
of contact for the project
City of Tustin 1 -1 9
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
applicant/lead agency that
all ground -disturbing activities
and phases that may involve
ground -disturbing activities
and that have the potential to
impact local TCRs on the
project site or in connection
with the project are complete.
Mitigation Measure TCR-2:
Unanticipated Discovery of Tribal
Cultural Resource Objects (Non-
Funerary/Non-Ceremonial):
Upon discovery of any TCRs, all
construction activities in the
immediate vicinity of the discovery
shall cease (i.e., not less than the
surrounding 50 feet) and shall not
resume until the discovered TCR
has been fully assessed by the
tribal monitor and consulting
archaeologist. If the consulting
tribe is other than the Gabrieleno
Band of Mission Indians — Kizh
Nation, the Kizh Nation shall be
contacted and the consulting tribe
will recover and retain all
discovered TCRs in the form
and/or manner the Kizh Nation
deems appropriate, in the Kizh
Nation sole discretion, and for any
purpose the Kizh Nation deems
appropriate, including for
educational, cultural and/or
historic purposes.
City of Tustin 1 -20
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
Mitigation Measure TCR-3:
Unanticipated Discovery of
Human Remains and Associated
Funerary or Ceremonial Objects
a. Native American human
remains are defined in PRC
5097.98 (d)(1) as an
inhumation or cremation, and
in any state of decomposition
or skeletal completeness.
Funerary objects, called
associated grave goods in
Public Resources Code Section
5097.98, are also to be
treated according to this
statute.
b. If Native American human
remains and/or grave goods
are discovered or recognized
on the project site, then Public
Resource Code 5097.9 as
well as Health and Safety
Code Section 7050.5 shall be
followed.
C. Human remains and
grave/burial goods shall be
treated alike per California
Public Resources Code section
5097.98(d)(1) and (2).
d. Preservation in place (i.e.,
avoidance) is the preferred
manner of treatment for
discovered human remains
and/or burial goods.
City of Tustin 1 -21
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
e. Any discovery of human
remains/burial goods shall be
kept confidential to prevent
further disturbance.
Cumulative
PPP TCR-1: As listed above.
Potentially Significant
TCR-1: Retain a Native American
Less than Significant
PPP CUL-1: Human Remains. As
Monitor Prior to Commencement
listed above.
of Ground -Disturbing Activities.
As listed above.
TCR-2: Unanticipated Discovery
of Tribal Cultural Resource
Objects (Non-Funerary/Non-
Ceremonial). As listed above.
TCR-3: Unanticipated Discovery
of Human Remains and
Associated Funerary or
Ceremonial Objects. As listed
above.
5.11 Utilities and Service Systems
Impact UT-1: Would the Project
PPP HYD-1: SWPPP. As listed
Potentially Significant
Mitigation Measure UT-1: Future
Less than Significant
require or result in the relocation
above.
proposed Projects shall prepare
or construction of new or
PPP T-2: Traffic Control/Utilities.
capacity analyses of existing
expanded water, wastewater
As listed above.
water utilities in the area to ensure
treatment or stormwater
PPP UT-1: California Building
conveyance and pressure is
drainage, electric power, natural
Code. All future development
adequate for future projects
gas, or telecommunications
constructed under the Project shall
proposed. The developer shall
facilities, the construction or
be subject to the latest version of
then identify infrastructure
relocation of which could cause
the California Building Code
improvements necessary for the
significant environmental effects?
(CBC) which outlines regulations
proposed development. The
for building planning and
developer will be responsible for
construction in the state, including
preparing a capacity analysis in
occupancy classification,
coordination with the City. The
structural design, building
capacity analysis and
materials, infrastructure needs
infrastructure improvements shall
and fire -resistance requirements.
be reviewed and approved by the
City prior to approval of the
construction permit.
City of Tustin 1 -22
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Level of Significance
Mitigation Measures
Level of Significance
Plan, Program, or Policy (PPP),
Before Mitigation
After Mitigation
or Project Design Feature (PDF)
Impact UT-2: Would the Project
Less than Significant
Less than Significant
have sufficient water supplies
available to serve the Project and
reasonably foreseeable future
development during normal, dry,
and multiple dry years?
Impact HYD-1: Would the
Less than Significant
Less than Significant
Project substantially decrease
groundwater supplies or interfere
substantially with groundwater
recharge such that the project
may impede sustainable
groundwater management of the
basin?
Impact HYD-2: Would the
Less than Significant
Less than Significant
Project conflict with or obstruct
implementation of a water
quality control plan or
sustainable groundwater
management plan?
Impact UT-3: Would the Project
PPP HYD-1: SWPPP. As listed
Potentially Significant
Less than Significant
require or result in the
above.
Mitigation Measure UT-2: Future
construction of new wastewater
PPP T-2: Traffic Control/Utilities.
proposed Projects shall prepare
facilities, or expansion of existing
As listed above.
capacity analyses of existing
facilities, the construction of which
PPP UT-1: California Building
sewer utilities in the area to ensure
could cause significant
Code. As listed above.
conveyance and pressure is
environmental effects?
adequate for future projects
proposed. The developer shall
then identify infrastructure
improvements necessary for the
proposed development. The
developer will be responsible for
preparing a capacity analysis in
coordination with the EOCWD and
the City. The capacity analysis and
infrastructure improvements shall
be reviewed and approved by
City of Tustin 1 -23
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Level of Significance
Mitigation Measures
Level of Significance
Plan, Program, or Policy (PPP),
Before Mitigation
After Mitigation
or Project Design Feature (PDF)
EOCWD and the City prior to
approval of the construction
permit.
Impact UT-4: Would the Project
Potentially Significant
MM UT-2: As listed above.
Less than Significant
result in a determination by the
wastewater treatment provider,
which serves or may serve the
Project that it has adequate
capacity to serve the Project's
projected demand in addition to
the provider's existing
commitments?
Impact UT-5: Would the Project
PPP HYD-1: SWPPP. As listed
Less than Significant
Less than Significant
require or result in the relocation
above.
or construction of new drainage
PPP HYD-3: WOMP. As listed
facilities, or expansion of existing
above.
facilities, the construction of which
PPP T-2: Traffic Control/Utilities.
could cause significant
As listed above.
environmental effects.
Impact UT-6: Would the Project
Potentially Significant
None required.
Less than Significant
generate solid waste in excess of
State or local standards, or in
excess of the capacity of local
infrastructure, or otherwise impair
the attainment of solid waste
reduction goals?
Impact UT-7: Would the Project
Less than Significant
Less than Significant
comply with federal, State, and
local management and reduction
statutes and regulations related
to solid waste?
Impact UT-8: Would the Project
Less than Significant
Less than Significant
require or result in the relocation
or construction of a new or
expanded electric power, natural
City of Tustin 1 -24
Draft EIR
June 2024
Enderle Center Rezone
1.0 Executive
Impact
Applicable Standard Condition,
Plan, Program, or Policy (PPP),
or Project Design Feature (PDF)
Level of Significance
Before Mitigation
Mitigation Measures
Level of Significance
After Mitigation
gas, or telecommunications
facilities, the construction of which
could cause significant
environmental effects?
Cumulative
PPP HYD-1: SWPPP. As listed
Potentially Significant
Mitigation Measure UT-1: Water
Less than Significant
above.
Utilities Capacity Analyses. As
PPP HYD-3: WOMP. As listed
listed above.
above.
Mitigation Measure UT-2:
PPP T-2: Traffic Control/Utilities.
Wastewater Utilities Capacity
As listed above.
Analyses. As listed above.
PPP UT-1: California Building
Code. As listed above.
City of Tustin 1 -25
Draft EIR
June 2024
Enderle Center Rezone Project 1.0 Executive Summary
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City of Tustin 1 -26
Draft EIR
June 2024
Enderle Center Rezone Project 2. Introduction
2. Introduction
This Draft Environmental Impact Report (EIR) is an informational document that evaluates the environmental
effects that may result from the planning, construction, and operation of the proposed Enderle Center Rezone
Project (Project), which requires approval of the General Plan Amendment, Zoning Code Amendment, Zone
Change, Housing Overlay district and adoption of Objective Design Standards for residential development.
2.1 PURPOSE OF THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
The California Environmental Quality Act (CEQA) requires that all State and local governmental agencies
consider the environmental consequences of projects over which they have discretionary authority prior to
taking action on those projects. The CEQA Guidelines provide the following information regarding the
purpose of an EIR:
• Project Information and Environmental Effects. An EIR is an informational document that will inform
public agency decision makers and the public of the potential significant environmental effect(s) of a
project, identify possible ways to minimize the significant effects, and describe reasonable alternatives
to the project. The public agency shall consider the information in the EIR along with other information
that may be presented to the agency (State CEQA Guidelines Section 151 21(a)).
• Standards for Adequacy of an EIR. An EIR should be prepared with a sufficient degree of analysis to
enable decision makers to make an intelligent decision that takes into account environmental
consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive,
but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. Disagreement
among experts does not make an EIR inadequate, but the EIR should summarize the main points of
disagreement among the experts. The courts have looked not for perfection but for adequacy,
completeness, and a good faith effort at full disclosure (State CEQA Guidelines Section 15151 ).
As a public disclosure document, the purpose of an EIR is not to recommend either approval or denial of a
project, but to provide information regarding the physical environmental changes that would result from an
action being considered by a public agency to aid in the agency's decision -making process.
2.2 LEGAL AUTHORITY
This Draft EIR has been prepared in accordance with all criteria, standards, and procedures of CEQA
(California Public Resource Code Section 21000 et seq.) and the State CEQA Guidelines (California Code
of Regulations, Title 14, Division 6, Chapter 3, Section 15000 et seq.).
Pursuant to CEQA Section 21067 and State CEQA Guidelines Article 4 and Section 15367, the City of Tustin
is the Lead Agency under whose authority this Draft EIR has been prepared. "Lead Agency" refers to the
public agency that has the principal responsibility for carrying out or approving a project. Serving as the
Lead Agency and before taking action on any approvals for the Project, the City of Tustin has the obligation
to: (1) ensure that this Draft EIR has been completed in accordance with CEQA; (2) review and consider the
information contained in this Draft EIR as part of its decision -making process; (3) make a statement that this
Draft EIR reflects the City of Tustin's independent judgment; (4) ensure that all significant effects on the
environment are eliminated or substantially lessened where feasible; and, if necessary, (5) make written
findings for each unavoidable significant environmental effect stating the reasons why mitigation measures
or Project alternatives identified in this Draft EIR are infeasible and citing the specific benefits of the
proposed Project that outweigh its unavoidable adverse effects (State CEQA Guidelines Sections 15090
through 15093).
City of Tustin 2-1
Draft EIR
June 2024
Enderle Center Rezone Proiect 2. Introduction
Pursuant to State CEQA Guidelines Sections 15040 through 15043, and upon completion of the CEQA
review process, the City of Tustin will have the legal authority to do any of the following:
• Approve the Project;
• Require feasible changes in any or all activities involved in the Project in order to substantially lessen or
avoid significant effects on the environment;
• Disapprove the Project, if necessary, in order to avoid one or more significant effects on the environment
that would occur if the Project was approved as proposed; or
• Approve the Project even though the Project would cause a significant effect on the environment if the
City of Tustin makes a fully informed and publicly disclosed decision that: (1) there is no feasible way to
lessen the effect or avoid the significant effect; and (2) expected benefits from the Project will outweigh
significant environmental impacts of the Project.
2.3 EIR SCOPE AND CONTENT
Impacts Found to be Potentially Significant. The City prepared an Initial Study (IS) and determined that
an EIR should be prepared for the Project. As a result, and pursuant to the requirements of CEQA, the IS and
a Notice of Preparation (NOP) was prepared and circulated between February 16, 2024, and March 20,
2024, for the required 30-day public review period. The purpose of the NOP was to solicit early comments
from public agencies with expertise in subjects that are discussed in this Draft EIR and to solicit comments
from the public regarding potential Project environmental impacts. The IS, NOP, and any written responses
to the NOP are included in Appendix A of this Draft EIR. Topics requiring a detailed level of analysis
evaluated in this Draft EIR have been identified based upon the responses to both the IS/NOP and a review
of the Project by the City. The City determined through the initial review process that impacts related to the
following topics are potentially significant as discussed in the IS and require a detailed level of analysis in
this Draft EIR.
• Air Quality
• Energy
• Greenhouse Gas Emissions
• Hydrology and Water Quality
• Land Use and Planning
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation
• Tribal Cultural Resources
• Utilities and Service Systems
Impacts Found Not to be Significant. CEQA Guidelines Section 151 26.2(a) states that "[a]n EIR shall identify
and focus on the significant effects on the environment." Topics that have been determined not to be
significant and are therefore not discussed in detail in the Draft EIR were identified based upon the responses
to the IS/NOP and a review of the Project by the City. As further detailed in Section 7, Impacts Found Not
to Be Significant, of this Draft EIR, and as discussed in the IS, the City determined through the initial review
process that impacts related to the following topics are not potentially significant and are not required to
be analyzed in this Draft EIR.
• Aesthetics
• Agriculture and Forestry Resources
• Biological Resources
• Cultural Resources
• Geology and Soils
• Hazards and Hazardous Materials
• Mineral Resources
• Wildfire
City of Tustin 2-2
Draft EIR
June 2024
Enderle Center Rezone Project 2. Introduction
2.4 ENVIRONMENTAL IMPACT REPORT PROCESS
A project -level analysis has been provided pursuant to State CEQA Guidelines Section 15161. This Draft
EIR meets the content requirements discussed in State CEQA Guidelines Article 9, beginning with State CEQA
Guidelines Section 15120.
2.4.1 Notice of Preparation/Initial Study
The NOP requested members of the public and public agencies to provide input on the scope and content
of environmental impacts that should be included in the Draft EIR being prepared. Comments received on
the IS/NOP are included in Appendix A and summarized in Table 2-1, which also includes a reference to
the Draft EIR section(s) in which issues raised in the comment letters are addressed.
Table 2-1: Summary of NOP Comment Letters
Comment Letter and Commenter Relevant Draft EIR Sections
State and Local Agencies
Native American Heritage Commission (NAHC), February 21, 2024
The comment includes a description of requirements Section 5.1 0, Tribal Cultural Resources
regarding requirements for preparation of an
Environmental Impact Report (EIR) pursuant to CEQA
Guidelines Section 15064. Additionally, the commenter
provides requirements and project applicability under
Assembly Bill 52 (AB 52) and Senate Bill 18 (SB 18).
The commenter recommends consultation with California
Native American tribes that are traditionally and
culturally affiliated with the geographic area of the
proposed project as early as possible. The commenter
provides a summary of requirements for AB 52 and SB
18 process.
California Department of Transportation (Caltrans), March 18, 2024
This comment letter states that the Project is in proximity Section 5.3, Air Quality
to SR-55 thus a VMT study should be completed with Section 5.14, Transportation
mitigation measures, as necessary and OPR's guidelines
be used. The comment letter also encourages
accompanying complete street elements, such as bike
lanes, and pedestrian safety features to enhance safety
for all road users; and suggests the addition of a
discussion on existing bus route services and potential
future transit improvement opportunities as well as the
encouragement of said transit to future residents for
reduced traffic congestion, VMT, and improved Air
Quality. The comment letter also suggests Amazon
package deliveries be considered to reduce traffic
congestion and that the Project ensure truck parking and
ingress/egress points do not interfere with bicycle and
vehicle parking or pedestrian paths. In addition, the
comment letter suggests that freight pick up and drop off
times not coincide with peak commute hours and that on
street freight -only parking be considered as well as that
the Project work with local partners to mitigate truck
traffic on residential streets. Lastly, the comment letter
states that any work performed within a Caltrans right-
of-way will require discretionary approval and as such,
appropriate applications should be completed.
City of Tustin 2-3
Draft EIR
June 2024
Enderle Center Rezone Proiect 2. Introduction
Orange County Fire Authority (OCFA), March 19, 2024
This comment letter states the OCFA provides medical Section 5.7, Public Services
services response to 23 cities in Orange County and all
unincorporated areas and operates 78 fire stations
throughout Orange County. The letter states OCFA
believes the Project will have a less than significant
impact related to fire services.
2.4.2 Public Scoping Meeting
Pursuant to Section 15082(c)(1) of the CEQA Guidelines, the City of Tustin hosted a public scoping meeting
for members of the public and public agencies to provide input as to the scope and content of the
environmental information and analysis to be included in the Draft EIR for the Project. A scoping meeting
was held on March 6, 2024 at Tustin Area Senior Center located at 200 S C St, Tustin, CA 92780.
Attendants of the public scoping meeting were mostly patrons of the Enderle Center and residents of Tustin,
in addition to a few retail business owners. Comments received from the attendees during the Scoping
Meeting included concerns regarding traffic congestion, water supply, hazardous materials, public services,
land use, and aesthetics. More specifically, concerns that were raised included: parking for buildout of the
proposed Project and traffic delays on the adjacent freeway ramps; whether increased development could
impact existing water supply; whether hazardous materials were considered based on the historical use of
the site; whether the school district has sufficient capacity to serve the Project; and how new development on
the site could impact neighboring visual character.
2.4.3 Public Review of the Draft EIR
The City of Tustin has filed a Notice of Completion (NOC) with the Governor's Office of Planning and
Research State Clearinghouse, indicating that this Draft EIR has been completed and is available for review
and comment. The Project requires a General Plan Amendment; thus, the Project meets the definition of a
project of statewide, regional, or areawide significance pursuant to Section 15206 of the CEQA Guidelines
and is subject to noticing requirements accordingly. A Notice of Availability (NOA) of the Draft EIR was
published concurrently with distribution of this document. The Draft EIR is being circulated for review and
comment by the public and other interested parties, agencies, and organizations for 45 days in accordance
with State CEQA Guidelines Sections 15087 and 15105. During the 45-day review period, the Draft EIR is
available for public review digitally on the City of Tustin's website at:
https://www.tustinca.org/HousingElementRezone
A physical copy is available for review at the following locations:
City of Tustin Orange County Library — Tustin Branch
300 Centennial Way 345 E. Main Street
Tustin, CA 92780 Tustin, CA 92780
Written comments related to environmental issues in the Draft EIR should be addressed to:
Samatha Beier, Senior Planner
City of Tustin
300 Centennial Way
Tustin, CA 92780
(714) 573-3354
Housing ElementRezone@tustinca.org
City of Tustin 2-4
Draft EIR
June 2024
Enderle Center Rezone
2. Introduction
2AA Final EIR
Upon completion of the 45-day review period of the Draft EIR, written responses to all comments related to
the environmental issues in the Draft EIR will be prepared and incorporated into a Final EIR. Written responses
to comments will be made available at least 10 days prior to the public hearing at which the certification of
the Final EIR will be considered by the City Council. These comments, and their responses, will be included in
the Final EIR for consideration by the City of Tustin, as well as other responsible and trustee agencies per
CEQA. The Final EIR may also contain corrections and additions to the Draft EIR and other information
relevant to the environmental issues associated with the Project. The Final EIR will be available for public
review prior to its certification by the City of Tustin. Notice of availability of the Final EIR will be sent to all
who comment on the Draft EIR.
2.5 ORGANIZATION OF THIS DRAFT EIR
This Draft EIR is organized into the following Sections. To help the reader locate information of interest, a
brief summary of the contents of each chapter is provided.
• Section 1, Executive Summary: This section provides a brief summary of the Project area, the Project,
and alternatives. This section also provides a summary of the potential environmental impacts and
mitigation measures, applicable Project design features, applicable regulatory requirements, and the
level of significance after implementation of the mitigation measure. The level of significance after
implementation of the proposed mitigation measure(s) will be characterized as either less than significant
or significant and unavoidable.
• Section 2, Introduction: This section provides an overview of the purpose and use of the EIR, the scope
of this Draft EIR, a summary of the legal authority for the Draft EIR, a summary of the environmental
review process, and the general format of this document.
• Section 3, Project Description: This section provides a detailed description of the Project, its objectives,
and a list of Project -related discretionary actions.
• Section 4, Environmental Setting: This section provides a discussion of the existing conditions within the
Project area.
• Section 5, Environmental Impact Analysis: This section is divided into sub -sections for each
environmental impact area. Each section includes a summary of the existing statutes, ordinances, and
regulations that apply to the environmental impact area being discussed; the analysis of the Project's
direct and indirect environmental impacts on the environment, including potential cumulative impacts that
could result from the Project; applicable Project design features, standard conditions, and plans, policies,
and programs that could reduce potential impacts; and feasible mitigation measures that would reduce
or eliminate the significant adverse impacts identified. Impacts that cannot be mitigated to less than
significant are identified as significant and unavoidable.
• Section 6, Other CEQA Considerations: This section summarizes the significant and unavoidable impacts
that would occur from implementation of the Project and provides a summary of the environmental effects
of the implementation of the Project that were found not to be significant. Additionally, this section
provides a discussion of various CEQA-mandated considerations including growth -inducing impacts and
the identification of significant irreversible changes that would occur from implementation of the Project.
In addition, this section provides a discussion of impacts found not to be significant.
• Section 7, Effects Found Not to be Significant: This section summarizes the potential environmental
effects related to the Project that were determined not to be significant during preparation of this EIR.
• Section 8, Alternatives: This section describes and analyzes a reasonable range of alternatives to the
Project. The CEQA-mandated No Project Alternative is included along with alternatives that would
City of Tustin 2-5
Draft EIR
June 2024
Enderle Center Rezone
2. Introduction
reduce one or more significant effects of the proposed Project. As required by the CEQA Guidelines,
the environmentally superior alternative is also identified.
• Section 9, Report Preparation and Persons Contacted: This section lists authors of the Draft EIR and City
of Tustin staff that assisted with the preparation and review of this document. This section also lists other
individuals and/or organizations that were contacted for information that is included in this Draft EIR
document.
2.6 INCORPORATION BY REFERENCE
State CEQA Guidelines Section 15150 allows for the incorporation "by reference all or portions of another
document... most appropriate for including long, descriptive, or technical materials that provide general
background but do not contribute directly to the analysis of a problem at hand." The purpose of
incorporation by reference is to assist the Lead Agency in limiting the length of this Draft EIR. Where this
Draft EIR incorporates a document by reference, the document is identified in the body of the Draft EIR,
citing the appropriate section(s) of the incorporated document and describing the relationship between the
incorporated part of the referenced document and this Draft EIR.
City of Tustin 2-6
Draft EIR
June 2024
Enderle Center Rezone Project 3. Project Description
3. Project Description
"Project," as defined by the State CEQA Guidelines, means "the whole of an action, which has a potential
for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect
physical change in the environment, and that is any of the following: (1)... enactment and amendment of
zoning ordinances, and the adoption and amendment of local General Plans or elements thereof pursuant
to Government Code Sections 65100-65700." (14 California Code of Regulations [CCR] Section 15378(a).)
The Project analyzed in this Draft EIR does not propose any specific development. This Draft EIR analyzes
the potential for future development that the Project could facilitate, if approved. For analysis purposes, the
Project is assumed to be developed in one phase and constructed by 2029. The Draft EIR analyzes buildout
at a programmatic level of detail, based upon maximum development potential of the Project, compared to
the existing conditions.
3.1 PROJECT BACKGROUND
The City of Tustin prepared the 2021-2029 Housing Element of the General Plan in accordance with
Government Code Section 65580 et seq. The City is required by State law to periodically update its Housing
Element, a mandatory component of the City's General Plan. The update to the Housing Element covers the
Sixth Cycle planning period from October 15, 2021 to October 15, 2029. The Housing Element is the City's
housing policy and planning document that identifies housing needs and constraints, and sets forth goals,
policies, and programs that address the future housing needs for all income levels over an eight -year
planning period that coincides with a Regional Housing Needs Allocation (RHNA).
On October 5, 2021, the City Council adopted Resolution No. 21-86, certifying the Negative Declaration
(ND) for GPA 2021-0002 (and Resolution No. 21-87, approving GPA 2021-0002), which analyzed
environmental impacts related to the City's Draft Housing Element Update of the General Plan. The Draft
Housing Element Update was prepared, as required by State Housing Element law. Following preparation
of the Draft Housing Element Update and certification of the ND, the Draft Housing Element went through
several rounds of revisions and submittal for review to the State Department of Housing and Community
Development (HCD). The City received formal certification of the Housing Element Update from HCD on
September 12, 2022. On October 4, 2022, the City Council adopted Resolution No. 22-47, approving
General Plan Amendment 2022-0002 for the final Housing Element Update.
The 2021-2029 Housing Element includes several provisions that aim to ensure the City can meet the required
"fair share" of affordable housing units, as specified by the State of California. During the Housing Element
process, the City assessed a number of properties and areas throughout the community that would be able
to accommodate the City's assigned 2021 Regional Housing Needs Allocation (RHNA). The City identified
19 sites and one housing category (accessory dwelling units [ADUs]/junior accessory dwelling units [JADUs])
as qualifying sites to accommodate their RHNA allocation. Of the 19 Housing Element inventory sites, Enderle
Center (Housing Element Site 17) was identified as necessary for rezoning under Housing Element Program
1.1 f to allow for high density residential/mixed use development.
Enderle Center (the Project site) consists of approximately 11.80 acres of privately owned property.
Currently, the Project site is developed with a commercial center. Of the site area, seven acres within the
southeastern portion of the Project site have been identified as suitable for housing development. These
seven acres are currently made up of paved parking areas and, based on the proposed overlay zone,
redevelopment of the site would accommodate up to 413 housing units.
City of Tustin 3-1
Draft EIR
June 2024
Enderle Center Rezone Project 3. Project Description
3.2 PROJECT LOCATION
The Project site is approximately 1 1.80 acres and is located within the City of Tustin. The City is in the central
portion of Orange County and is surrounded by the cities of Irvine to the south, Santa Ana to the west,
Orange and unincorporated Orange County to the north; and unincorporated Orange County to the east.
Major freeways and highways within or bordering the City of Tustin are the 1-5 freeway through the center,
State Route (SR) 55 to the west, SR 261 to the east, and the 1-405 freeway to the south, as illustrated in
Figure 3-1, Regional Location.
The Project site consists of Assessor Parcel Numbers (APNs) 401-251-04, -05, and -06; 401-252-05, -06, -
08, -09, and -10; and 401-253-03 and -04. The Project site is generally bounded on the north by 17rh
Street; on the east by Enderle Center Drive and the eastern property line of properties fronting Enderle
Center Drive; to the south by Vandenberg Lane; and to the west by the 55 freeway, including properties
west of Yorba Street.
The local vicinity of the Project site is illustrated in Figure 3-2, Local Vicinity.
3.3 EXISTING CONDITIONS
The Enderle Center is currently developed with 87,136 SF of commercial business, including 28,750 SF of
restaurant use, 39,960 SF of retail and service use, 18,426 SF of office use, and surface parking lots. The
site also includes ornamental landscaping along the perimeter and throughout the parking areas. Figure 3-
3, Aerial, illustrates the Project site in its current condition.
City of Tustin 3-2
Draft EIR
June 2024
Regional Location
Orange
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Enderle Center Rezone Project Figure 3-1
City of Tustin
Enderle Center Rezone Project 3. Project Description
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City of Tustin 3-4
Draft EIR
June 2024
Local Vicinity
T F 1-
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Enderle Center Rezone Project Figure 3-2
City of Tustin
Enderle Center Rezone Project 3. Project Description
This page intentionally left blank.
City of Tustin 3-6
Draft EIR
June 2024
Aerial View
N
ri Project Site A
Enderle Center Rezone Project Figure 3-3
City of Tustin
Enderle Center Rezone Project 3. Project Description
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City of Tustin 3-8
Draft EIR
June 2024
Enderle Center Rezone Project 3. Project Description
3.3.1 Existing Land Use and Zoning
The Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM). The PCCB land use designation
provides opportunities for a variety of miscellaneous retail, professional office, and service -oriented business
activities. The PC COM zoning is intended to allow diversification of the relationships of various buildings,
structures and open spaces in planned building groups while ensuring substantial compliance with the district
regulations and other provisions of the Planned Community District zone.
The Project site's existing General Plan land use and zoning designations are shown in Figure 3-4, Existing
General Plan Land Use and Figure 3-5, Existing Zoning.
3.3.2 Surrounding General Plan and Zoning Designations
The Project site is located within a developed area. The surrounding land uses and their designations are
described in Table 3-1.
Table 3-1: Surrounding Existing Land Use and Zoning Designations
Existing Land Use
General Plan Designation
Zoning Designation
North
Retail Commercial (Cl) with
17'h Street followed by
Community Commercial (CC),
Parking Overlay, Commercial
commercial, residential and office
Planned Community
General (CG), & Planned
uses
Commercial/Business (PCCB)
Community Commercial (PC
COM)
East
Enderle Center Drive followed by
Planned Community
Planned Community
office uses
Commercial/Business (PCCB)
Commercial (PC COM)
South
Vandenberg Lane followed by
Planned Community
Planned Community
residential uses
Residential (PCR)
Residential (PC RES)
West
Tustin city limits and SR-55
Professional and
Administrative Office (PAO)
Professional (P) &
freeway, followed by
&
Community Commercial (Cl)
restaurants and office uses in the
General Commercial (GC)
(City of Santa Ana)
City of Santa Ana
(City of Santa Ana)
3.4 PROJECT OBJECTIVES
CEQA Guidelines §15124(b) (14 California Code of Regulations [CCR]) requires "A statement of objectives
sought by the proposed project. A clearly written statement of objectives would help the Lead Agency
develop a reasonable range of alternatives to evaluate in the EIR and would aid the decision makers in
preparing findings or a statement of overriding considerations, if necessary. The statement of objectives
should include the underlying purpose of the project." The primary purpose and goal of the Project is to
accommodate the City's 6th Cycle RHNA identified within the City of Tustin 2021-2029 Housing Element.
The Project would achieve this goal through the following objectives:
a. Creation of a Housing Overlay (HO) District to allow residential development at densities
to achieve the estimated capacities determined in the Housing Element and without inhibitors
to residential development.
b. Increase the number of housing opportunities available in Tustin to ensure the City provides
its fair share of housing units within a variety of income categories.
c. Increase flexibility in allowed uses and development potential in an underutilized area of
the City of Tustin.
City of Tustin 3-9
Draft EIR
June 2024
Enderle Center Rezone Project 3. Project Description
d. Promote a diverse housing stock with products that are offered at a wide range of sizes
and affordability.
3.5 DESCRIPTION OF THE PROJECT
3.5.1 Project Overview
Pursuant to Housing Element Program 1.1 f, the City is proposing an overlay zone ("overlay district") for the
project site. To accommodate this, a General Plan Amendment (GPA) is needed to establish that higher
density residential uses are allowed in the Planned Community Commercial Business (PCCB) land use
designation when prescribed by a Housing Overlay (HO) district or a Specific Plan (SP); a Zoning Code
Amendment (ZCA) to establish Housing Overlay District (overlay zone) in conjunction with the Planned
Community Commercial Districts (base zone); and a Zone Change (ZC) that amends the City's zoning map to
apply a Housing Overlay ("HO") District to the project site. The HO District for the Project authorizes the
submittal of a development plan for the construction of housing on up to 7 acres of the site's 11.80 acres, up
to a total of 413 dwelling units. The HO District exists "on top" of the existing PC COM zoning, and therefore
would allow for the housing to be constructed in lieu of, or in addition to, the existing shopping center and/or
new commercial development.
The Housing Element identified the Enderle Center as having capacity for 413 housing units. The anticipated
development density was determined through the Housing Element process and is a conservative estimate
based on development trends in nearby communities. The anticipated development does not rely on the
demolition of any existing building, but rather focuses on areas used for surface parking. No specific
development is proposed as part of this Project, but this Draft EIR has analyzed all known anticipated impacts
of the development of the proposed housing units. Table 3-2 lists the existing and proposed Project site land
use regulation characteristics.
Table 3-2: Existing and Proposed Project Site Characteristics
Existing
Proposed
GP Land
Zoning
Maximum
GP Land
Zoning
Maximum
Maximum
Use
Designation
Allowable
Use
Designation
Density
Allowable
Units
(DU/AC)
Units
Enderle
PCCB
PC COM
0
PCCB
PC COM &
59
413 on
Center
HO
7 aces
3.5.2 Buildout Development Summary
Residential uses are currently not allowed on the Project site. Upon approval of the HO, the Project site could
accommodate 413 units over approximately 7 acres of developable land within the existing 1 1.8-acre site.
This would result in a density of 59 du/ac. The Project site is envisioned to function as a mixed -use site and
a portion of the Project site would remain as nonresidential land use. The Project site has a General Plan
land use designation of Planned Community Commercial/Business (PCCB). The General Plan PCCB
designation allows for development of up to Floor Area Ratio (FAR) 1.5:1. However, the General Plan
assumes the average site to develop up to an FAR of 0.4:1. Based on the General Plan development
assumption, the Project site is assumed to be developed with 205,610 SF of nonresidential use.
For purposes of the Project analysis, an Opening Year of 2029 has been assumed. The assumed buildout of
the site by 2029 is broken down below, as shown in Table 3-3.
City of Tustin 3-10
Draft EIR
June 2024
Enderle Center Rezone Project 3. Project Description
Table 3-3: Opening Year Buildout Summary
Land Use
Existing
Housing Overlay
District
Opening Year Buildout
(2029)
Residential (du)
-
413
413
Office (SF)
18,426
-
67,840
Retail (SF)
39,960
-
94,290
Restaurant (SF)
28,750
-
43,480
Total Residential
-
413
413
Total Nonresidential
87,136
-
205,610
3.5.3 Project Features
Proposed General Plan Amendment
The proposed Project includes a GPA establish that higher density residential uses are allowed in the Planned
Community Commercial Business (PCCB) land use designation when prescribed by a Housing Overlay (HO)
district or a Specific Plan (SP). The GPA will amend the text within the Land Use Element to clarify the purpose
and function of a HO and describe how the HO implements General Plan goals and policies.
Proposed Housing Overlay District
During the Housing Element process, the City identified the Enderle Center as a suitable commercial site for
rezoning to allow mixed -use development, which introduced the opportunity to allow higher density housing
in either horizontal or vertical mixed -use development on the site. This would be accomplished with a Housing
Overlay.
In addition to the permitted uses under the existing PC COM zoning, the overlay zone would allow residential
land uses. Thus, the HO would be added "on top" of the existing PC COM zone (i.e., Base Zone). The overlay
zone would also provide development standards related to parking, setbacks, height, and other standards
applicable to residential uses. The HO text would include a provision that the HO supersedes the
development standards and allowed uses listed within the Base Zone.
Residential uses are currently not allowed on the Project site. Upon approval of the HO, the Project site could
accommodate 413 units over approximately 7 acres of developable land within the existing 1 1.8-acre site.
This would result in a density of 59 du/ac. The anticipated development over 7 acres may take place on
underutilized asphalt parking lot areas, and not require demolition of any existing buildings. Parking
displaced as a result of redevelopment would be accommodated by vertical parking structures located
within the proposed development.
Proposed Zone Change
The Project also includes an amendment to the City's Zoning Map to add the newly codified HO on top of
the site's existing PC COM zoning. Figure 3-6, Proposed Zoning, illustrates the proposed zone change.
The proposed zone change would require an amendment to Tustin City Code (TCC), Article 9 (Land Use),
Chapter 2 (Zoning), Part 5, to establish a HO, which allows for higher density residential development, and
stipulates that Objective Design Standards (ODS) will apply to properties within the boundary of the Housing
Overlay (HO) District.
City of Tustin 3-1 1
Draft EIR
June 2024
Enderle Center Rezone Project 3. Project Description
Nonresidential Buildout
The Project site is envisioned to function as a mixed -use site and a portion of the Project site would remain
as nonresidential land use. The Project site has a General Plan land use designation of Planned Community
Commercial/Business (PCCB). The General Plan PCCB designation allows for development of up to Floor
Area Ratio (FAR) 1.5:1. However, the General Plan assumes the average site to develop up to an FAR of
0.4:1. Based on the General Plan development assumption, the Project site is assumed to be developed with
205,610 SF of nonresidential use.
The Enderle Center is currently developed with 87,136 SF of commercial business uses, including 28,750 SF
of restaurant use, 39,960 SF of retail and service use, and 18,426 SF of office use. Therefore, the total
remaining nonresidential use assumed for future buildout of the Project site is 118,474 SF.
Therefore, the Project anticipates the future additional nonresidential buildout of 118,474 SF, or a total
nonresidential development capacity of 205,610 SF for the Project site. Future nonresidential projects
proposed that are within the remaining development capacity of the site would be required to comply with
the existing PCCB development standards and would the City's existing plan review process. Future
nonresidential development is anticipated to be developed within exiting undeveloped areas, and the
Project does not assume demolition of existing structures. No development is proposed as part of this rezone
Project.
Housing Element Programs Applicable to the Project Site
The 2021-2029 Housing Element included several housing programs to be implemented during the 2021-
2029 planning period. The discussion below outlines three programs that are applicable to the proposed
Project.
Program 1.2a
Program 1.2a provides that the City will amend its Zoning Code to remove subjective design guidance in
TCC Section 9272 (Design Review) and adopt new Objective Design Standards (ODS) to ensure that the
City can provide clear guidance regarding project design, in order to streamline the development of high -
quality residential development. The ODS would include provisions consistent with the requirements of Senate
Bill (SB) 35. Program 1.2a is anticipated to be complete in October 2024.
Program 1.2c
Program 1.2c directs the City to develop parking standards to facilitate residential housing production as
part of mixed -use developments, adaptive reuse projects, and new residential developments. The program
provides that parking displaced as a result of redevelopment may be replaced with vertical parking
structures, as needed, to provide required parking. Additionally, the parking standards would incentivize
creative parking strategies such as parking credits for transit rich development, and allowance of parking
structures and parking lifts, by right and subject to the ODS.
Infrastructure Improvements
Roadways and utilities may be required to support development of future residential construction within the
Project site. Future onsite infrastructure improvements that may be necessary for residential development
within the Enderle Center include storm drains, wastewater, water, and dry utilities that would connect to
existing facilities within the Project site or adjacent to the Project area. Specific infrastructure improvements
required to support residential development within the Enderle Center are not known at this time and will
not be known until a specific development project is proposed.
City of Tustin 3-1 2
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11
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0 F VIO
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■■■
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Enderle Center Rezone Project 3. Project Description
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City of Tustin 3-14
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Existing Zoning
Q Project Site
1UNUM111111110
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NONE
N
A
Q R1 - Single Family Residential - C1 - Retail Commercial
- R2 - Duplex Residential - C2 - Central Commercial
R3 - Multiple Family Residential - CG - Commercial General
- R4 - Suburban Residential - PC COM - Planned Community Commercial
JlIlloq PC RES - Planned Community Residential = PM - Planned Industrial
PD - Planned Development - M - Industrial
- MHP - Mobile Home Park - PC IND - Planned Community Industrial
0 PR - Professional - PI - Public and Institutional
= PCPI - Planned Community Public and Institutional
Enderle Center Rezone Project Figure 3-5
City of Tustin
Enderle Center Rezone Project 3. Project Description
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City of Tustin 3-16
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Proposed Zoning
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O R1 - Single Family Residential
In R2 - Duplex Residential
0 R3 - Multiple Family Residential
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R4 - Suburban Residential
PC RES - Planned Community Residential
PD - Planned Development
0 MHP - Mobile Home Park
0 PR - Professional
® HO - Housing Overlay
- C1 -Retail Commercial
- C2 - Central Commercial
- CG - Commercial General
- PC COM - Planned Community Commercial
0 PM - Planned Industrial
M - Industrial
0 PC IND - Planned Community Industrial
PI - Public and Institutional
- PCPI - Planned Community Public and Institutional
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Enderle Center Rezone Project Figure 3-6
City of Tustin
Enderle Center Rezone Project 3. Project Description
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Enderle Center Rezone Project 3. Project Description
3.6 DISCRETIONARY APPROVALS AND PERMITS
Preparation of an EIR is anticipated for the Project. The City of Tustin has primary approval responsibility
for the Project. As such, the City serves as the Lead Agency for the EIR pursuant to CEQA Guidelines §15050.
The Tustin Planning Commission will evaluate the EIR and the Project and make a recommendation to the City
Council whether the Project should be approved and the EIR be certified. The City Council is the decision -
making authority for the Project and will consider the Project along with the Planning Commission's
recommendations, and will make a final decision to approve, approve with changes, or deny the Project.
The City, including the Planning Commission and the City Council, will consider the information in the EIR and
the Project's administrative record in its decision -making processes. In the event of approval of the Project
and certification of the EIR, the City would conduct administrative and discretionary review and grant
ministerial and discretionary permits and approvals to implement Project requirements, conditions of
approval, and future development within the Enderle Center.
Approval and implementation of the HO requires City approval of the following discretionary actions:
• Certification of the EIR;
• Adoption of the GPA to establish that higher density residential uses are allowed in the Planned
Community Commercial Business (PCCB) land use designation when prescribed by a Housing Overlay
(HO) district or a Specific Plan (SP);
• Adoption of the ZCA to establish the zoning, development regulations, guidelines, and implementation
provisions governing development of the HO;
• Approval of the HO for the Project site;
• Adoption of the zone change (ZC) to modify the City's Zoning Map to add the HO over the site's existing
PC COM zoning.
The EIR may be used by various governmental decisionmakers for discretionary permits and actions that are
necessary or may be requested in connection with implementation of future development projects pursuant
to the Project. Additional discretionary, administrative, and/or ministerial actions may be necessary from
other responsible agencies to fully implement the Project. The state or local agencies that may rely upon the
information contained in the EIR when considering approval of permits may include the:
• Tustin Unified School District.
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Enderle Center Rezone Proiect 4. Environmental
4. Environmental Setting
The purpose of this section is to provide a description of the environmental setting of the Project site and
surrounding area as it existed at the time of the Notice of Preparation (NOP) was published, from both a
local and regional perspective. In addition to the summary below, detailed environmental setting descriptions
are provided in each subsection of Section 5 of this Draft EIR.
4.1 REGIONAL SETTING
The Project site is located in the City of Tustin. The City of Tustin encompasses approximately 1 1.08 square
miles and is surrounded by the cities of Irvine to the south and east, Santa Ana to the west, and Orange and
unincorporated Orange County to the north. Regional access is provided by Interstate (1) 5 through the center
of the City, State Route (SR) 55 to the west, SR-261 to the east, and 1-405 freeway to the south.
4.2 LOCAL SETTING AND PROJECT LOCATION
The Project site is approximately 1 1.80 acres and is located within the City of Tustin. The Project site consists
of Assessor Parcel Numbers (APNs) 401-251-04, -05, and -06; 401-252-05, -06, -08, -09, and -10; and
401-253-03 and -04. The Project site is generally bounded on the north by 17t' Street; on the east by
Enderle Center Drive and the eastern property line of properties fronting Enderle Center Drive; to the south
by Vandenberg Lane; and to the west by SR-55, including properties west of Yorba Street. The existing site
and surrounding area is shown in Figure 3-2, Local Vicinity.
4.3 EXISTING LAND USE AND ZONING
The Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM). The PCCB land use designation
provides opportunities for a variety of miscellaneous retail, professional office, and service -oriented business
activities. The PC COM zoning is intended to allow diversification of the relationships of various buildings,
structures and open spaces in planned building groups while ensuring substantial compliance with the district
regulations and other provisions of the Planned Community District zone.
The Project site's existing General Plan land use and zoning designations are shown in Figure 3-4, Existing
General Plan Land Use and Figure 3-5, Existing Zoning.
4.4 SURROUNDING LAND USES AND DEVELOPMENT
The Project site is located within a developed area. The surrounding land uses and their designations are
described in Table 4-1.
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Enderle Center Rezone
4. Environmental
Table 4-1: Surrounding Existing Land Use and Zoning Designations
Existing Land Use
General Plan Designation
Zoning Designation
North
Retail Commercial (Cl) with
17'h Street followed by
Community Commercial (CC),
Parking Overlay, Commercial
commercial, residential and office
Planned Community
General (CG), & Planned
uses
Commercial/Business (PCCB)
Community Commercial (PC
COM)
East
Enderle Center Drive followed by
Planned Community
Planned Community
office uses
Commercial/Business (PCCB)
Commercial (PC COM)
South
Vandenberg Lane followed by
Planned Community
Planned Community
residential uses
Residential (PCR)
Residential (PC RES)
West
Tustin city limits and
Professional and
Administrative Office (PAO)
Professional (P) &
freeway, followed by
by
&
Community Commercial (Cl)
restaurants and office uses in the
General Commercial (GC)
(City of Santa Ana)
City of Santa Ana
(City of Santa Ana)
4.5 PHYSICAL ENVIRONMENTAL CONDITIONS
CEQA Guidelines Section 151 25(a)(1) states that the physical environmental condition in the vicinity of the
Project as it existed at the time the EIR's NOP was released for public review normally be used as the
comparative baseline for the EIR. The NOP for this EIR was released for public review on February 16, 2024.
The following pages include a description of the physical environmental conditions ("existing conditions") on
a regional and local basis at the approximate time the NOP was released. More information regarding the
Project site's environmental setting is provided in the specific subsections of EIR Section 5, Environmental
Analysis.
4.5.1 Air Quality
The Project area is located within the South Coast Air Basin (Basin), which is under the jurisdiction of the South
Coast Air Quality Management District (SCAQMD). The Basin is a 6,600-square-mile coastal plain bounded
by the Pacific Ocean to the southwest and the San Gabriel, San Bernardino, and San Jacinto Mountains to
the north and east. The Basin includes the non -desert portions of Los Angeles, Riverside, and San Bernardino
counties, and all of Orange County.
The ambient concentrations of air pollutants are determined by the amount of emissions released by sources
and the atmosphere's ability to transport and dilute such emissions. Natural factors that affect transport and
dilution include terrain, wind, atmospheric stability, and sunlight. Therefore, existing air quality conditions in
the area are determined by such natural factors as topography, meteorology, and climate, in addition to
the amount of emissions released by existing air pollutant sources.
Atmospheric conditions such as wind speed, wind direction, and air temperature gradients interact with the
physical features of the landscape to determine the movement and dispersal of air pollutants. The
topography and climate of Southern California combine to make the Basin an area of high air pollution
potential. The Basin is a coastal plain with connecting broad valleys and low hills, bounded by the Pacific
Ocean to the west and high mountains around the rest of the perimeter. The general region lies in the semi-
permanent high-pressure zone of the eastern Pacific, resulting in a mild climate tempered by cool sea
breezes with light average wind speeds. The usually mild climatological pattern is disrupted occasionally by
periods of extremely hot weather, winter storms, or Santa Ana winds. During the summer months, a warm air
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June 2024
Enderle Center Rezone Proiect 4. Environmental
mass frequently descends over the cool, moist marine layer produced by the interaction between the ocean's
surface and the lowest layer of the atmosphere. The warm upper layer forms a cap over the cool marine
layer and inhibits the pollutants in the marine layer from dispersing upward. In addition, light winds during
the summer further limit ventilation. Furthermore, sunlight triggers the photochemical reactions which produce
ozone.
Air quality monitoring stations are located throughout the nation and are maintained by the local air pollution
control district and State air quality regulating agencies. The SCAQMD, together with the CARB, maintains
ambient air quality monitoring stations in the Basin. The air quality monitoring station closest to the Project
site is located at 1630 Pampas Lane in Anaheim, California.
Pollutant monitoring results for years 2020 to 2022 at the Anaheim ambient air quality monitoring station,
shown in Table 5.1-3, indicate that air quality in the area has generally been moderate. As indicated in the
monitoring results, the federal PM10 standard was not exceeded during the 3-year period. The State PM10
standard was exceeded 5 times in 2020, once in 2021, and once in 2022. Similarly, the federal PM2.5
standard had 12 exceedances in 2020, 10 exceedances in 2021, and no exceedances in 2022. The State
1-hour ozone standards were exceeded 6 times in 2021, no times in 2021, and once in 2022. The State 8-
hour ozone standards were exceeded 16 times in 2020, no times in 2021, and once in 2022. The federal
8-hour standards were exceeded 15 times in 2021, no times in 2021, and once in 2022. The CO and NO2
standards were not exceeded in this area during the 3-year period. SO2 data was not available from 2020
to 2022 at air quality monitoring stations in Orange County.
Sensitive Land Uses
For the purposes of this analysis, sensitive receptors are areas of population that have an increased sensitivity
to air pollution or environmental contaminants. Sensitive receptor locations include residences, schools,
daycare centers, hospitals, parks, and similar uses which are sensitive to air quality. Impacts on sensitive
receptors are of particular concern because they are the population most vulnerable to the effects of air
pollution. The Project site is surrounded primarily by residential, commercial, and office uses. The areas
adjacent to the Project site include residential uses to the south, commercial uses to the north and east, and
State Route 55 to the west.
The closest sensitive receptors to the Project site are residential uses, located approximately 70 feet south
of the Project site (see Figure 2-3, Aerial View).
4.5.2 Energy
Electricity
The Southern California Edison Company (SCE) is the electrical purveyor in the City of Tustin. SCE provides
electricity service to more than 14 million people in a 50,000 square -mile area of central, coastal and
Southern California. California utilities are experiencing increasing demands that require modernization of
the electric distribution grid to, among other things, accommodate two-way flows of electricity and increase
the grid's capacity. SCE is in the process of implementing infrastructure upgrades to ensure the ability to
meet future demands. In addition, as described by the Edison International 2022 Annual Report, the SCE
electrical grid modernization effort supports implementation of California requirements to achieve carbon
neutrality by 2045. The State has set Renewables Portfolio Standards that require retail sellers of electricity
to provide 60 percent of power from renewable resources by 2030. The State also requires sellers of
electricity to deliver 100 percent of retail sales from carbon -free sources by 2045, including interim targets
of 90 percent by 2035 and 95 percent by 2040. In 2022 approximately 48 percent of power that SCE
delivered to customers came from carbon -free resources (Southern California Edison, 2022).
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Enderle Center Rezone Proiect 4. Environmental
The Project site is currently served by the electricity distribution systems that exist along the roadways
adjacent to the Project site.
Natural Gas
The Southern California Gas Company (SoCalGas) is the natural gas purveyor in the City of Tustin and is
the principal distributor of natural gas in Southern California. The total natural gas consumption in Orange
County in 2022 was 573 million therms (572,454,744 therms). SoCalGas estimates that gas demand will
decline at an annual rate of 1.5 percent from 2022 to 2035 due to modest economic growth, mandated
energy efficiency standards and programs, renewable electricity goals, and fuel substitution (Southern
California Gas Company, et. al., 2022). The gas supply available to SoCalGas is regionally diverse and
includes supplies from California sources (onshore and offshore), Southwestern U.S. supply sources, the Rocky
Mountains, and Canada. SoCalGas designs its facilities and supplies to provide continuous service during
extreme peak demands and has identified the ability to meet peak demands through 2035.
The Project is within the service area of Southern California Gas Company (SoCal Gas).
4.5.3 Greenhouse Gas Emissions
Gases that trap heat in the atmosphere are called greenhouse gases (GHGs). The major concern with GHGs
is that increases in their concentrations are contributing to global climate change. Global climate change is
a change in the average weather on Earth that can be measured by wind patterns, storms, precipitation,
and temperature. Although there is disagreement as to the rate of global climate change and the extent of
the impacts attributable to human activities, most in the scientific community agree that there is a direct link
between increased emissions of GHGs and long-term global temperature increases.
The principal GHGs are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6),
perfluorocarbons (PFCs), and hydrofluorocarbons (HFCs). Because different GHGs have different warming
potential, and CO2 is the most common reference gas for climate change, GHG emissions are often quantified
and reported as CO2 equivalents (CO2e). For example, SF6 is a GHG commonly used in the utility industry
as an insulating gas in circuit breakers and other electronic equipment. SF6, while comprising a small fraction
of the total GHGs emitted annually world-wide, is a much more potent GHG, with 22,800 times the global
warming potential as CO2. Therefore, an emission of one metric ton (MT) of SF6 could be reported as an
emission of 22,800 MT of CO2e. Large emission sources are reported in million metric tons (MMT) of CO2e.
The principal GHGs are described below, along with their global warming potential.
The State emitted approximately 381.3 MMT CO2e emissions in 2021, 12.1 MMT CO2e higher than 2020
levels and 49.7 MMT CO2e below the 2020 GHG limit of 431 MMT CO2e. The California Air Resources
Board (CARB) estimates that transportation was the source of approximately 38 percent of the State's GHG
emissions in 2021. The next largest sources included industrial sources at approximately 19 percent and
electricity generation at 16 percent. The remaining sources of GHG emissions were commercial and
residential activities at 10 percent, agriculture at 8 percent, high Global Warming Potentials (GWP) such as
refrigerants at 6 percent, and waste at 2 percent.
4.5.4 Land Use and Planning
The Project site is located within the City of Tustin, which is in the central portion of Orange County and is
surrounded by the cities of Irvine to the south and east, Santa Ana to the west, and Orange and
unincorporated Orange County to the north. The approximately 11.8-acre Project site consists of the
following parcels: Assessor Parcel Numbers (APNs) 401-251-04, -06; 401-252-05, -06, -08, -09, -10; and
401-253-04 and -03. The Enderle Center is currently developed with 87,136 SF of commercial business,
including 28,750 SF of restaurant use, 39,960 SF of retail and service use, 18,426 SF of office use, and
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Enderle Center Rezone Proiect 4. Environmental
surface parking lots. The site also includes ornamental landscaping along the perimeter and throughout the
parking areas.
The Project site has a General Plan land use designation of PCCB and a zoning designation of PC COM.
The PCCB land use designation provides opportunities for a variety of miscellaneous retail, professional
office, and service -oriented business activities. The PC COM zoning is intended to allow diversification of the
relationships of various buildings, structures and open spaces in planned building groups while ensuring
substantial compliance with the district regulations and other provisions of the Planned Community District
zone.
4.5.5 Noise
Existing Noise Levels
To assess existing noise levels of the environment, long-term (24-hour) noise level measurements were
conducted on January 23 and 24, 2024, at two locations as shown on Figure 5.5-1. The background ambient
noise levels in the Project area are dominated by the transportation -related noise associated with surface
streets and surrounding commercial and office uses. Table 5.5-4 provides a summary of the measured hourly
noise levels and calculated CNEL level from the long-term noise level measurements. As shown in Table 5.5-
4 Summary of 24-Hour Ambient Noise Level Measurements, in Section 5.05, the calculated CNEL levels range
from 66.9 dBA CNEL to 73.7 dBA CNEL.
Existing Vibration
Aside from periodic construction work that may occur in the vicinity of the Project area, the Project site and
adjacent land uses are not currently exposed to sources of groundborne vibration.
Existing Airport Noise
John Wayne Airport (SNA) is located approximately 5.5 miles southwest of the Project site. The Project site
is located outside of the airport's 60 CNEL noise contour. In addition, the General Aviation Noise Ordinance
restricts airport operations between 1 1:00 p.m. and 7:00 a.m., to limit the hours of noise generated by SNA.
Sensitive Receivers
Sensitive receptors are generally defined as locations where people reside or where the presence of
unwanted sound could otherwise adversely affect the use of the land. Noise -sensitive land uses are generally
considered to include residences, schools, hospitals, and recreation areas. Existing offsite sensitive noise
receptors where someone can remain for 24-hours in the vicinity of the Project site consists of residences. The
closest offsite residences are located 70 feet south of the site as listed in Table 5.5-5, included within Section
5.05.
4.5.6 Population and Housing
The Project site is approximately 1 1.80 acres and is currently developed with 87,136 SF of commercial
business, including 28,750 SF of restaurant use, 39,960 SF of retail and service use, 18,426 SF of office use,
and surface parking lots. The site also includes ornamental landscaping along the perimeter and throughout
the parking areas.
City of Tustin 4-5
Draft EIR
June 2024
Enderle Center Rezone
4. Environmental
Population
According to the California DOF, the City of Tustin had a population of 79,558 in 2023 (California
Department of Finance, 2023). Based on SCAG Connect SoCal methodology the City of Tustin had a
population of 80,400 persons in 2019 and estimates that the City's population will increase to 93,317 in
2050, which is a 16.1 percent increase. In comparison, the SCAG projects the County of Orange will have
a 7.8 percent increase in population between 2019 and 2050.
Housing
The California Department of Finance (DOF) estimates that the City of Tustin contained 28,405 housing units
in 2023. The housing types in the City of Tustin compared to those in the entire County are provided in Table
5.6-3. As shown, the County has a higher percentage of detached single-family housing units and a lower
percentage of single-family attached and multi -family housing units than the City. In addition, the California
DOF details that the City had an average household size of 2.88 persons per household. In comparison, the
County had an average household size of 2.83 persons per household.
The California DOF population and housing estimates for 2023 detail that the City of Tustin has a vacancy
rate of 3.4 percent. In comparison, the vacancy rate Countywide is higher at 5.1 percent.
The SCAG estimates that between 2019 and 2050, the number of housing units in the City will increase by
25.9 percent while the number of housing units in the County will increase by 17.2 percent.
Employment
The City of Tustin is estimated to contain 51,700 employment opportunities as of 2019. The SCAG regional
growth projections anticipate the number of jobs in the City of Tustin to increase by 37.9 percent to 71,300
jobs in the year 2050. In comparison, the County is projected to see a 11.9 percent increase in the number
of jobs by 2050.
The SCAG 2019 Local Profile for Tustin identifies that 7.3 percent of Tustin residents work and live in the
City, while 92.7 percent commute to other places (Southern California Association of Governments, 2019).
Of the commuters residing in Tustin, the largest percentage commute to the City of Irvine (18.6 percent),
Santa Ana (10.4 percent), Anaheim (5.5 percent), and Orange (5.2 percent).
Jobs -Housing Ratio
The jobs -housing ratio is a general measure of the total number of jobs and housing units in a defined
geographic area, without regard to economic constraints or individual preferences. SCAG applies the jobs -
housing ratio at the regional and subregional levels to analyze the fit between jobs, housing, and
infrastructure. A major focus of SCAG's regional planning efforts has been to improve this balance. SCAG
defines the jobs -housing balance as follows:
Jobs and housing are in balance when an area has enough employment opportunities for
most of the people who live there and enough housing opportunities for most of the people
who work there. The region as a whole is, by definition, balanced.... Job -rich subregions
have ratios greater than the regional average; housing -rich subregions have ratios lower
than the regional average. Ideally, job -housing balance would... assure not only a
numerical match of jobs and housing but also an economic match in type of jobs and housing.
There is no ideal ratio adopted in state, regional, or city policies. However, the American Planning Association
includes recommends a target ratio of 1.5 jobs per housing unit; communities with more than 1.5 jobs per
dwelling unit are considered jobs -rich; those with fewer than 1.5 are "housing rich," meaning that more
City of Tustin 4-6
Draft EIR
June 2024
Enderle Center Rezone Proiect 4. Environmental
housing is provided than employment opportunities in the area (Weitz, 2003). A job -housing imbalance can
indicate potential air quality and traffic problems associated with commuting. The projected 2050 jobs -to -
housing ratios for the City of Tustin and Orange County are 2.1 and 1.61, respectively. This indicates that
both the City of Tustin and Orange County are jobs -rich.
4.5.7 Public Services
Fire Protection Services
Fire protection and emergency medical services in the City of Tustin are provided by the OCFA through a
contract for services. The Orange County Fire Authority (OCFA) provides fire suppression, emergency
medical, rescue, fire prevention, hazardous materials coordination, and wildland management services.
OCFA serves 23 cities in Orange County and all unincorporated areas. Within the City of Tustin, OCFA
provides services from three fire stations. Additionally, there are four fire stations in the City of Santa Ana
and unincorporated Orange County within service distance from the Project site.
The Project site is within the Primary Responsibility Area of OCFA Station 21, which is located approximately
2 miles from the site. However, resources are deployed upon a regional service delivery system, assigning
personnel and equipment to emergency incidents without regard to jurisdictional boundaries. Therefore, the
site may be served by other OCFA stations in the vicinity. These include OCFA Station 72, located
approximately 1.6 miles from the Project site; OCFA Station 70, located approximately 1.8 miles from the
Project site; OCFA Station 75, located approximately 3.3 miles from the site; and OCFA Station 8, located
approximately 3.6 miles from the site. The location, equipment, and staffing of the fire stations that would
serve the Project site are provided in Table 5.7-1, included within section 5.07.
Table 5.7-2 shows that there were 16,276 incident totals from the three fire stations in the City of Tustin in
2022. Of the calls for service, 70 percent (11,397) were for emergency medical calls, 1.5 percent (237)
were for fire incidents, and 28.5 percent (4,642) were for other incidents, which includes: cancelled service
calls, ruptures, hazardous conditions, false alarms, and miscellaneous calls.
According to the Table PS-3, Emergency Service Standards, of the Tustin General Plan, Tustin has a target
response time of 5 minutes for 90 percent of incidents related to fire response and basic life support unit
responses. The standard response time for the advanced life support unit is 10 minutes for 90 percent of
incidents (City of Tustin, 2018).
OCFA's current response standards are based on a 90Th Percentile. The OCFA current standard for response
is 8:30 minutes at the 90Th percentile. Table 5.1 1-2 provides a summary of service and response metrics for
the closest responding stations to the Project site in 2023. According to OCFA, in 2023, OCFA first unit on
scene response at the 901h percentile to the project area was 8:35 minutes
Police Services
The Tustin Police Department provides police services throughout the City. Police Department headquarters
are located at 300 Centennial Way, Tustin, CA 92780, which is approximately 1.7 roadway miles southeast
from the Project site. As of May 2024, the Tustin Police Department has 83 full time Sworn Police Officers,
7 part time Sworn Officers, 44 full time civilian support personnel and 12 part time civilian support personnel.
According to the California Department of Finance, the City of Tustin had a population of 78,559 residents
in 2023 (California Department of Finance, 2023). Based on this population estimate, the City's sworn officer
to population ratio is 1.1 officers per 1,000 population.
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Draft EIR
June 2024
Enderle Center Rezone Proiect 4. Environmental
According to the Table PS-3, Emergency Service Standards, of the Tustin General Plan, the Tustin Police
Department has a target response time of 3.5 minutes for emergency calls and 13 minutes for non -emergency
calls (City of Tustin, 2018).
Tustin Police Department groups calls for service into four priority categories, described below.
• Priority 1: Immediate threat to life or significant threat to public safety. Priority 1 calls are
dispatched immediately.
• Priority 2: Crimes in progress or other calls for service with a potential threat to public safety that
do not rise to the level of a Priority 1 call. These calls are dispatched as soon as possible.
• Priority 3: Calls for service with a reporting party who is waiting for an officer.
• Priority 4: Report calls with a delay in reporting and limited suspect information.
Average response times for each call type between January 1, 2023, to December 31, 2023, City wide
are provided below.
• Priority 1 — 00:05:43
• Priority 2 — 00:14:25
• Priority 3 — 00:42:27
• Priority 4 — 00:53:36
School Services
The Project site is located within the Tustin Unified School District (TUSD) boundary which includes the City of
Tustin, portions of the City of Irvine and portions of unincorporated areas of Orange County. TUSD has a
total of 29 schools including: 16 elementary schools, two Kindergarten through 81"-grade schools, one
Kindergarten through 121"-grade online school, four middle schools, one 6'"-grade through 121"-grade
academy, four high schools, and one adult education school.
According to the data from California Department of Education, TUSD has an enrollment of 21,830 students
in the 2022/2023 school year (California Department of Education, 2024). The Project site is in the
attendance areas of Guin Foss Elementary School (18492 Vanderlip Ave), which is approximately 1.3
roadway miles and 1.0 linear miles from the Project site; Columbus Tustin Middle School (17952 Beneta
Way), which is approximately 1.1 roadway miles and 0.7 linear miles from the Project site; and Foothill
High School (19251 Dodge Ave), which is approximately 2.2 roadway and 1.7 linear miles from the Project
site (PowerSchool, 2024).
Other Public Facilities
The Orange County Public Library (OCPL) provides library services to the City, including the Project site.
OCPL has 33 branch libraries in 24 incorporated cities and unincorporated areas of Orange County and
has a system -wide collection of approximately 2.5 million items (Orange County Public Libraries, 2020). The
City of Tustin has one branch library operated by OCPL: the Tustin Library, located at 345 East Main Street,
approximately 1.7 roadway miles southeast of the Project site.
4.5.8 Recreation
According to the City's General Plan, in 201 1, the City had 113 acres of existing local and community parks,
but needed an additional 114 acres to serve its population based on a standard of 3 acres per 1,000
persons and the January 2011 City population of 75,781 (City of Tustin, 2018). According to the City Parks
and Recreation Director, the City of Tustin currently has 183.2 acres of parkland (C. Clanton, personal
City of Tustin 4-8
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June 2024
Enderle Center Rezone Proiect 4. Environmental
communication, 2024 March 18). As discussed in Section 5.10, Population and Housing, the City had a
population of 77,558 in 2023. Therefore, the City has approximately 2.36 acres of public park and/or
recreational space per 1,000 residents. Thus, the City of Tustin is currently parkland deficient and is not
meeting its City standard of three acres of parkland per 1,000 residents. However, the City is currently in
the design phase for a new joint -use park at Heideman School (15571 Williams Street) that is expected to
completed in 2026 that will contribute to the City's existing parkland (City of Tustin, 2024).
There are no existing parks within the Project site. The closest existing park and recreation facilities to the
Project site (within 2 miles) in the City of Tustin are listed in Table 5.8-1. As shown, the City currently has
three existing parks that provide 20.4 acres of parkland within 2 miles of the Project site.
A.5.9 Transportation
Existing Roadway Network
The public roadway network serving the Project site includes 17rh Street, Yorba Street, Enderle Center Drive,
Vandenburg Lane, and SR-55, which are described below.
• 171h Street is a six -lane divided roadway with sidewalks on both sides that is designated as a major
arterial in the City of Tustin General Plan. 171h Street is oriented in the east -west direction, has no bike
lanes, and has a posted speed limit of 40 miles per hour (mph). On -street parking is not permitted on
either side of this roadway.
• Yorba Street is a four -lane undivided roadway between 171h Street and Vandenberg Lane and is
oriented in the north -south direction with sidewalks on both sides. The roadway is designated as a
secondary arterial in the City of Tustin General Plan and the posted speed limit is 40 mph. On -street
parking is not permitted along this roadway and there are no bike lanes.
• Enderle Center Drive is a two-lane undivided roadway between 17'h Street and Vandenberg Lane and
is undesignated in the General Plan. Enderle Center Drive is oriented in the north -south direction, has no
bike lanes, has a posted speed limit of 40 mph, and has a sidewalk on the east side.
• Vandenberg Lane is a two-lane undivided roadway between Yorba Street and Enderle Center Drive
and is undesignated in the General Plan. The roadway is aligned in an east -west direction, has sidewalks
on both sides of the street, and has a posted speed limit of 35 mph. On -street parking is permitted
along this roadway.
• SR 55 is a 1 2-lane divided roadway oriented regionally in the north -south direction. The posted speed
limit on SR-55 is 55 mph and it is classified as a freeway in the General Plan. On -street parking is not
permitted along this roadway.
Existing Site Access
Vehicular access to the Project site is currently provided via unsignalized driveways along 171h Street, Yorba
Street, Vandenberg Lane, and Enderle Center Drive. Signalized access is provided on Yorba Street at the
intersection of Vandenberg Lane.
Existing Transit Service
Public transit bus service for the City is provided by the Orange County Transportation Authority (OCTA).
The established network includes Routes 60, 61, 65, 66, 71, 75 and 463. The Project is not located within a
Transit Priority Area (TPA); however, adjacent to the Project at the junction of 17th Street and Enderle Center
Drive, there are two existing public transit bus stations served by Route 60 with bus service every 30 minutes.
These stations are situated on both the northern side of 171h Street and Yorba Street and on the southern
side of 171h Street and Enderle Center Drive. The major routes of travel for Route 60 include Larwin Square
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to Long Beach, via Newport and Seventeenth. Route 60 operates on approximately 30-minute headways
on weekdays and weekends and connects to the Newport Transportation Center.
The Metrolink Orange County Line and the Inland Empire -Orange County commuter lines travel through
Tustin, with stops at the Santa Ana Metrolink Station located 1.7 miles west of the Project site, and the
Orange Metrolink Station located 2.5 miles northwest of the Project site. In addition, passenger rail service
is provided from two Amtrak depots in neighboring cities; Irvine to the east and Santa Ana to the west, which
connects travelers throughout California, including to neighboring communities in Los Angeles and San Diego
counties.
Existing Bicycle and Pedestrian Facilities
There are no bike lanes on the public roadway network currently serving the Project site. Sidewalks currently
exist on both sides of 17rh Street, Vandenburg Lane, and Yorba Street and on the northbound side of Enderle
Center Drive.
Existing Vehicle Miles Traveled
The Project site is currently vacant and undeveloped. The Project site is located in one low VMT area (per
capita), which is defined as a traffic analysis zone (TAZ). The City of Tustin average city-wide VMT under
the 2016 Base Model Year is 15.0 home -based VMT per capita and 25.1 home -based work VMT per
employee. The Project site currently generates regular vehicle trips, comprised of 7,058 daily trips, with 444
trips in the AM peak hour and 648 trips in the PM peak hour.
4.5.10 Tribal Cultural Resources
A records search from the South Central Coastal Information Center (SCCIC) at California State University,
Fullerton was completed and encompassed the Project site and a 500-foot buffer surrounding the Project
(BFSA Environmental Services, 2024). Based on the records search results, no resources are recorded within
the Project site or within the 500-foot search buffer. Additionally, no previous studies are recorded on the
property, although there are two studies recorded within the search area. However, neither of the two studies
are directly related to the Project site.
Sacred Lands File Search
TCRs can include archaeological sites, built environment resources, locations of events or ceremonies, resource
procurement areas, and natural landscape features with special significance to one or more indigenous
groups. The City requested a Sacred Lands File (SLF) Search from the Native American Heritage Commission
(NAHC) and received the results on October 19, 2023. The SLF returned negative results, indicating that no
known tribal resources are located within the Project area.
4.5.1 1 Utilities and Service Systems
Water Supply and Demand
Water is supplied to the Project site by the City of Tustin. The City is a retail water supplier that provides
water to its residents and other customers using the imported potable water from Municipal Water District
of Orange County (MWDOC), obtained through East Orange County Water District (EOCWD), and local
groundwater from the Orange County Groundwater Basin (OC Basin), which is managed by the Orange
County Water District (OCWD) (Arcadis U.S., Inc. , 2020).
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Enderle Center Rezone Proiect 4. Environmental
The City's water supply consists of a combination of imported water and local groundwater. The City's main
source of water supply is groundwater from the OC Basin. In 2020, the City's actual water supply totaled
10,447 acre-feet (AF), which included 7,034 AF of untreated groundwater and 3,038 AF desalinated
groundwater from OC Basin, and 375 AF of imported water from MWDOC/EOCWD.
The City's 2020 UWMP forecasts that by 2045 the City's water supply mix will shift to 85 percent
groundwater and 15 percent imported water. Table 5.1 1-1 provides the City's total projected water supply
capacities expected to be available through 2045.
The City's water demand in 2021 was 10,374 AF, and is projected to decrease to 10,081 AF by 2025
(Arcadis U.S., Inc. , 2020). The 2020 UWMP also describes that water demands per capita have been
decreasing in recent years due to new state and local regulations related to water conservation. The 2020
UWMP describes that Tustin Water Department customers used 95 gallons per capita per day (GPCD) in
2020, which is below the target of 151 GPCD for 2020 (Arcadis U.S., Inc. , 2020). As shown in Table 5.15-
2, the 2020 UWMP indicates that the City has supply capabilities that would be sufficient to meet demands
from 2025 to 2045 under the normal, single dry -year, and multiple dry years. Thus, the City would continue
to be able to utilize imported water supply as needed.
Groundwater: In Fiscal Year (FY) 2019-20, the City relied on approximately 10,072 AFY (approximately
96 percent of the City's water supply portfolio for FY 2019-20) from the OC Basin to meet its demands. The
OC Basin covers an area of approximately 350 square miles, bordered by the Puente Hills and Chino Hills
to the north, the Santa Ana Mountains to the northeast, and the Pacific Ocean to the southwest. The basin
boundary extends to the Orange -Los Angeles county line to the northwest. Replenishment supplies for the
OC Basin include capture of increasing Santa Ana River flows, purified recycled water, purchases of
replenishment water from Metropolitan, and expansion of local supplies.
Imported Water: Approximately 4 percent of the City's potable water needs are met by imported water
purchased from EOCWD (who purchases from the Metropolitan Water District of Southern California [MET]
through MWDOC). MET's principal sources of water are the Colorado River via the Colorado River Aqueduct
(CRA) and the Lake Oroville watershed in Northern California through the State Water Project (SWP).
Surface Water: Currently, there are no direct surface water uses in the City's service area. As of 2021, there
are no planned direct uses of surface water in the City's service area (Arcadis U.S., Inc. , 2020).
Recycled Water: There are currently no direct recycled water uses within the City's service area.
Water Exchanges and Transfers: The City maintains interconnections with other agencies result in the ability
to share water supplies during short term emergency situations or planned shutdowns of major imported
water systems. Currently, the City maintains four emergency interconnections with Golden State Water
Company, the City of Santa Ana, and Irvine Ranch Water District. All four connections are six inches in
diameter, need to be manually activated, and supply flow in both directions.
Water Infrastructure
The City operates 13 wells, six reservoirs with a combined storage capacity of approximately 13.83 million
gallons (MG) and manages a 172-mile water mains system with 14,341 service connections (Arcadis U.S.,
Inc. , 2020)
Wastewater
Wastewater services are provided to the Project site by East Orange County Water District (EOCWD). In
2020, EOCWD collected approximately 360 AF of wastewater (Arcadis U.S., Inc., 2020).
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Enderle Center Rezone Proiect 4. Environmental
EOCWD's sewer system service area encompasses about 7,780 acres and includes portions of the Cities of
Orange and Tustin and unincorporated communities of North Tustin, Lemon Heights, Cowan Heights, and
Panorama Heights in the County of Orange.
EOCWD's wastewater system includes 171 miles of sewer lines and 3,700 manholes, serving about 18,000
customers. The gravity collection system conveys wastewater to points of connection with the wastewater
systems owned by the City of Orange, Irvine Ranch Water District (IRWD), and OC San.
EOCWD coordinates with Orange County Sanitation District (OC San) and OCWD for wastewater and
recycled water services. EOCWD does not own or operate its own wastewater treatment facilities and sends
all collected wastewater to OC San for treatment and disposal. Wastewater collected within EOCWD's
service area is conveyed to OC San's wastewater treatment plants in Fountain Valley (Plant No. 1) and
Huntington Beach (Plant No. 2). Plant No. 1 has a total rated primary capacity of 108 MGD and a secondary
treatment capacity of 80 MGD. Plant No. 2 has a rated primary capacity of 168 MGD and secondary
treatment capacity of 90 MGD.
Wastewater from the Project site is treated at OC San's Plant No. 1 in Fountain Valley. Enderle Center is
currently served by the existing 8-inch diameter sewer lines in 17th Street, Yorba Street, Enderle Center
Drive, and Vandenberg Lane
Storm Drainage Facilities
The Project site is currently developed with commercial uses. The Project site currently drains into the City's
stormwater sewer system via a series of culverts and drains. Stormwater drains to the southeast corner of
the site into a catch basin at the Vanderberg Lane and Enderle Center Drive intersection. The storm drain
then continues east and connects to the existing Orange County Flood Control District (OCFCD) facility
located between Enderle Center Drive and Prospect Avenue. Because the site is currently almost entirely
paved, future development would increase intensity of development, but would not result in additional
impervious surfaces that could increase the volume and velocity of stormwater runoff.
Solid Waste
The two closest landfills to the Project site are the Frank R. Bowerman Landfill in Irvine and the Olinda Alpha
Sanitary Landfill in Brea. The Frank R. Bowerman Landfill is permitted to accept 11,500 tons per day of
solid waste and is permitted to operate through 2053. In January 2024, the maximum tonnage received
was 8,710.78 tons. Thus, the facility had additional capacity of 2,789.22 tons per day (CalRecycle, 2024).
Per a Solid Waste Facility Permit (SWFP) issued on July 8, 2021, the Olinda Alpha Sanitary Landfill is
permitted to receive 10,000 tons per day for 36 days of the year and is permitted to receive 8,000 tons
per day for the other 271 days of the year. The Olinda Alpha Sanitary Landfill is permitted to operate
through 2036. In January 2024, the maximum tonnage received was 8,404 tons, which is below the 10,000
tons per day that the facility is allowed to receive for 36 days of the year (CalRecycle, 2024). Thus, the
Olinda Alpha Sanitary Landfill has additional capacity to accept solid waste that may be generated by the
Project.
Electrical, Natural Gas, and Telecommunications Facilities
Electricity
Electricity is provided to the Project by Southern California Edison (SCE). SCE provides electric power to
more than 15 million persons within its 50,000 square mile service area. According to SCE's 2022 Power
Content Label Mix, SCE derives electricity from varied energy resources including: biomass and biowaste,
geothermal, hydroelectric, solar, wind, nuclear, and natural gas. SCE also purchases power from independent
power producers and utilities, which includes out-of-state providers (California Energy Commission, 2022).
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Enderle Center Rezone
4. Environmental
Natural Gas
Natural gas would be provided to the Project by the Southern California Gas Company (SoCal Gas).
SoCalGas provides natural gas to more than 21 million persons within its 24,000 square mile service area
(SoCalGas, 2024).
Telecommunications
Telecommunications would be provided to the Project by AT&T and Cox Communications.
4.6 REFERENCES
Airport Land Use Commission for Orange County. (2008, April). Airport Land Use Commission. Retrieved from
John Wayne Airport Orange County: httl2s://www.ocair.com/about/administration/airport-
aovernance/commissions/airport-land-use-commission/
Arcadis U.S., Inc.. (2020). Tustin 2020 Urban Water Management Plan .
Arcadis U.S., Inc. (2020). East Orange County Water District 2020 Urban Water Management Plan.
BFSA Environmental Services. (2024). Archaeological Resources Records Search Results for the Enderle Center
Project, Tustin, California (APNs 407-252-05, -06, -08, through -7 0, 40 7-253-03, and -04).
California Department of Education. (2024). Data Quest. Retrieved from 2022-23 Enrollment by Grade:
https://dq.cde.ca.gov/dataquest/dgcensus/EnrGrdLevels.aspx?cds=3073643&agglevel=district
&year=2022-23
California Department of Finance. (2023, May). E-5 Population and Housing Estimates for Cities, Counties,
and the State — January 1, 202 7 -2023. Retrieved from State of California Department of Finace.
California Energy Commission. (2022). 2022 Power Content Label Southern California Edison. Retrieved from
California Energy Commission: https://www.energy.ca.gov/programs-and-
toaics/prog rams/power-source-disclosure-grogram /power -content -label
CalRecycle. (2024). SWIS Facility/Site Summary Frank R. Bowerman Landfill (30-AB-0360). Retrieved from
CalRecycle: https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/21 03
CalRecycle. (2024). SWIS Facility/Site Summary Olinda Alpha Landfill (30-AB-0035). Retrieved from
CalRecycle: https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/2093
City of Tustin. (2018). City of Tustin General Plan.
City of Tustin. (2024). City of Tustin Parks & Recreation Director, Chad Clanton. Retrieved from City of Tustin.
City of Tustin. (2019). Parks Information. Retrieved from Tustin Parks and Recreation:
https://www.tustinca.org/715/Parks-Information
Federal Transit Administration. (2006). Transit Noise and Vibration Impact Assessment. Retrieved from
Department of Transportation: chrome-
extension://efaidnbmnnnibpcaipcglclefindmkaj/https://docs.vcrma.org/images/pdf/planning/ce
qa/FTA_Noise_and_Vibration_Manual.pdf
LSA. (2024). Noise and Vibration Impact Analysis Enderle Center Project
Governor's Office of Planning and Research (OPR). (2005). State of Califonria Tribal Consultation Guidlines.
City of Tustin 4-1 3
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Enderle Center Rezone
4. Environmental
PowerSchool. (2024). Tustin Unified School District. Retrieved from MySchool Locator:
https://locator.pea.powerschooI.com/?StudyID=215986
SoCalGas. (2024). Company Profile. Retrieved from SoCalGas: https://www.socalgas.com/about-
us/company_profile
Southern California Association of Governments. (2024, April). 2024-2050 Regional Transportation
PlanlSustainable Communities Strategy. Retrieved from https://scag.ca.gov/connect-socal
Southern California Association of Governments. (2019, May). Local Profiles. Retrieved from Southern
California Association of Governments: https://scaci.ca.gov/data-tools-local-profiles
Southern California Gas Company, et. al. (2022). 2022 California Gas Report. Retrieved from Southern
California Gas Company:
https://www.socalgas.com/sites/default/files/Joint_Utility_Biennial_Comprehensive_California_G
as_Report_2022.pdf
Weitz, J. (2003). Jobs -Housing Balance. Planning Advisory Service Report Number 576. American Planning
Association.
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Enderle Center Rezone Proiect 5. Environmental
5. Environmental Impact Analysis
This chapter examines the environmental setting of the Project, analyzes its effects and the significance of its
impacts, and recommends mitigation measures to reduce or avoid impacts. This chapter is divided into
subsections for each environmental issue area that was determined to need further study in the Draft EIR
through the Notice of Preparation (NOP) review and comment process (see Appendix A). Environmental topic
areas discussed in this Draft EIR include the following:
5.1 Air Quality
5.2 Energy
5.3 Greenhouse Gas Emissions
5.4 Land Use and Planning
5.5 Noise
5.6 Population and Housing
5.7 Public Services
5.8 Recreation
5.9 Transportation
5.10 Tribal Cultural Resources
5.11 Utilities and Service Systems
This Draft EIR evaluates the direct and indirect impacts resulting from the planning, construction, and
operations of the Project. Under CEQA, EIRs are intended to focus their discussion on significant impacts and
may limit discussion of other impacts to a brief explanation of why the impacts are not significant.
FORMAT OF ENVIRONMENTAL TOPIC SECTIONS
Each environmental topic section generally includes the following main subsections:
• Introduction. This subsection describes the purpose of analysis for the environmental topic and
referenced documents used to complete the analysis. This subsection may define terms used.
• Regulatory Setting. This subsection describes applicable federal, State, and local plans, policies, and
regulations that the Project must address and may affect its implementation.
• Environmental Setting. This subsection describes the existing physical environmental conditions
(environmental baseline) related to the environmental topic being analyzed.
• Thresholds of Significance. This subsection sets forth the thresholds of significance (significance criteria)
used to determine whether impacts are "significant." The thresholds of significance used to assess the
significant of impacts are based on those provided in Appendix G of the CEQA Guidelines.
• Methodology. This subsection provides a description of the methods used to analyze the impact and
determine whether it would be significant or less than significant.
• Environmental Impacts. This subsection provides an analysis of the impact statements for each identified
significance threshold. The analysis of each impact statement is organized as follows:
o A statement of the CEQA threshold being analyzed.
o The Draft EIR's conclusion as to the significance of the impact.
o An impact assessment that evaluates the changes to the physical environment that would result from
the Project.
o An identification of significance comparing identified impacts of the Project to the significance
threshold with implementation of existing regulations, prior to implementation of any required
mitigation.
• Cumulative Impacts. This subsection describes the potential cumulative impacts that would occur from
the Project's environmental effects in combination with other cumulative projects (See Table 5-1).
• Existing Regulations and Regulatory Requirements. This subsection describes a list of applicable laws
and regulations that would reduce potentially significant impacts.
• Level of Significance Before Mitigation. This subsection describes a determination of the significance of
the impacts after the application of existing regulatory requirements and prior to any mitigation.
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5. Environmental
• Mitigation Measures. For each impact determined to be potentially significant after the application of
applicable laws and regulations, feasible mitigation measure(s) to be implemented are provided.
Mitigation measures include enforceable actions to:
o Avoid a significant impact;
o Minimize the severity of a significant impact;
o Rectify an impact by repairing, rehabilitating, or restoring the effected physical environment;
o Reduce or eliminate the impact over time through preservation and/or maintenance operations
during the life of the Project; and/or
o Compensate for the impact by replacing or providing substitute resources or environmental conditions.
• Level of Significance After Mitigation. This section provides the determination of the impact's level of
significance after the application of regulations, regulatory requirements, and mitigation measures.
IMPACT SIGNIFICANCE CLASSIFICATIONS
The below classifications are used throughout the impact analysis in this Draft EIR to describe the level of
significance of environmental impacts. Although the criteria for determining significance are different for
each topic area, the environmental analysis applies a uniform classification of the impacts based on
definitions consistent with CEQA and the CEQA Guidelines.
• No Impact. The Project would not change the environment.
• Less than Significant. The Project would not cause any substantial, adverse change in the environment.
• Less than Significant with Mitigation Incorporated. The Draft EIR includes mitigation measures that
avoid substantial adverse impacts on the environment.
• Significant and Unavoidable. The Project would cause a substantial adverse effect on the environment,
and no feasible mitigation measures are available to reduce the impact to a less -than -significant level.
CUMULATIVE IMPACTS
Cumulative impacts refer to the combined effect of the proposed Project's impacts with the impacts of other
past, present, and reasonably foreseeable probable future projects. Both CEQA and the CEQA Guidelines
require that cumulative impacts be analyzed in an EIR. As set forth in the CEQA Guidelines Section 15130(b),
"the discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of
occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to
the project alone." The CEQA Guidelines direct that the discussion should be guided by practicality and
reasonableness and focus on the cumulative impacts that would result from the combination of the proposed
project and other projects, rather than the attributes of other projects which do not contribute to cumulative
impacts.
According to Section 15355 of the CEQA Guidelines, "cumulative impacts" refers to two or more individual
effects which, when considered together, are considerable or which compound or increase other
environmental impacts:
a) The individual effects may be changes resulting from a single project or a number of separate projects.
b) The cumulative impact from several projects is the change in the environment which results from the
incremental impact of the project when added to other closely related past, present, and reasonably
foreseeable probable future projects. Cumulative impacts can result from individually minor but
collectively significant projects taking place over a period of time.
Therefore, the cumulative discussion in this Draft EIR focuses on whether the impacts of the proposed Project
are cumulatively considerable within the context of impacts caused by other past, present, and reasonably
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Enderle Center Rezone Proiect 5. Environmental
foreseeable future projects. Additionally, pursuant to the CEQA Guidelines Section 151 30(a)(1), an EIR
should not discuss cumulative impacts that do not result at least in part from the project being evaluated in
the EIR. Thus, cumulative impact analysis is not provided for any environmental issue where the proposed
Project would have no environmental impact. Analysis of cumulative impacts is, however, provided for all
Project impacts that are evaluated within this Draft EIR.
CEQA Guidelines Section 151 30(b)(1) states that the information utilized in an analysis of cumulative impacts
should come from one of the following, or a reasonable combination of the two:
• A list of past, present, and probable future projects producing related or cumulative impacts, including
those projects outside the control of the lead agency; or
• A summary of projections contained in an adopted local, regional, or statewide plan or related planning
document that describes or evaluates conditions contributing to the cumulative effect.
The cumulative analysis for air quality, greenhouse gas emissions, and transportation relies on projections
contained in adopted local, regional, or statewide plans or related planning documents, such as the Southern
California Regional Transportation Plan and relevant regional plans developed by the Southern California
Association of Governments (SCAG). The cumulative analyses for other environmental issues use the list of
projects approach which identifies past projects which have recently been constructed, present projects which
have recently been approved and are under construction, and probable future projects that are under
entitlement review that were known of at the time the NOP was published. As described previously, the
cumulative project list is part of the environmental setting/baseline that includes past, present, and probable
future projects for which development applications were submitted to lead agencies prior to publishing of
the NOP.
Different types of cumulative impacts occur over different geographic areas. For example, the geographic
scope of the cumulative air quality analysis, where cumulative impacts occur over a large area, is different
from the geographic scope considered for cumulative analysis of aesthetic resources, for which cumulative
impacts are limited to project area viewsheds. Thus, in assessing aesthetic resources impacts, only
development within and immediately adjacent to the Project area would contribute to a cumulative visual
effect is analyzed, whereas cumulative transportation impacts are based upon annual growth projections
and the other proposed and/or foreseeable development within the traffic study area of roadways and
intersections. Because the geographic scope and other parameters of each cumulative analysis discussion can
vary, the cumulative geographic scope, and the cumulative projects included in the geographic scope (when
the list of projects approach is used), are described for each environmental topic. Table 5-1 provides a list
of projects considered in this cumulative environmental analysis, which was compiled per information
provided by each agency, and Figure 5-1 shows the locations.
Table 5-1: Cumulative Projects List
No. Project Address Land Use Size
City of Tustin
T-1
Medical Office Bldg.'
17631 17th St
Institution
12,320 SF
Tustin, CA
T-2
Jessup by Intracorp2
17802 & 17842 Irvine Blvd
SFR & MFR
SFR: 4 DU
Tustin, CA
MFR: 36 DU
City of Santa Ana
SA-1
Baja Fish Tacos
2107 17th Street
Commercial
5,005 SF
Santa Ana, CA
SA-2
Tustin Service Station
2230 Tustin Ave,
Commercial
2,150 SF
Santa Ana, CA
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5. Environmental
No.
Project
Address
Land Use
Size
SA-3
McDonald's Drive -Through'
2101 Santa Clara Ave
Commercial
3,975 SF
Santa Ana, CA
SA-4
New ARCO AM/PM Service
2301 Seventeenth Street
Commercial
4,000 SF
Station'
Santa Ana, CA
SA-5
Park Court Office Building
1 801 Parkcourt Place
Institution
3,974 SF
Santa Ana, CA
SA-6
Russell Fischer Center'
301 Tustin Ave
Commercial
10,143 SF
Santa Ana, CA
Notes: Multi -Family Residential (MFR). Single Family Residential (SFR). SF = square feet. DU = dwelling units.
' The project includes demolition and replacement of an existing use (non -vacant).
2 Project size indicates the added units and/or square feet where expansion of existing facilities is proposed, not the
total operational size.
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Enderle Center Rezone Project Figure 5-1
City of Tustin
Enderle Center Rezone
5. Environmental
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5.1 Air
5.1 Air Quality
5.1.1 INTRODUCTION
This section provides an overview of the existing air quality within the City of Tustin and surrounding region,
a summary of applicable regulations, and analyses of potential short-term and long-term air quality impacts
from implementation of the proposed Project. Mitigation measures are recommended as necessary to reduce
significant air quality impacts. This section is based upon the following.
• City of Tustin General Plan (including 2021-2029 Housing Element). Adopted November 2018 (updated
October 2022).
• Tustin City Code
• Connect SoCal 2024 Regional Transportation PlanlSustainable Communities Strategy (RTP/SCS),
adopted April 2024.
• Enderle Center Project Air Quality, Energy, and Greenhouse Gas Report, LSA, March 2024, Appendix B.
5.1.2 REGULATORY SETTING
5.1.2.1 Federal Regulation
United States Environmental Protection Agency
Criteria Air Pollutants
At the federal level, the United States Environmental Protection Agency (USEPA) has been charged with
implementing national air quality programs. The USEPA's air quality mandates are drawn primarily from the
Federal Clean Air Act (CAA), which was enacted in 1970. The most recent major amendments to the CAA
were made by Congress in 1990.
The CAA requires the USEPA to establish National Ambient Air Quality Standards (NAAQS). The USEPA has
established primary and secondary NAAQS for the following criteria air pollutants: ozone, CO, NO2, S02,
PM10, PM2.5, and lead. Table 5.1-1 shows the NAAQS for these pollutants. The CAA also requires each state
to prepare an air quality control plan, referred to as a state implementation plan (SIP). The CAA Amendments
of 1990 (CAAA) added requirements for states with nonattainment areas to revise their SIPS to incorporate
additional control measures to reduce air pollution. The SIP is modified regularly, and the interval can vary
between one to a few years, to reflect the latest emissions inventories, planning documents, and rules and
regulations of the air basins, as reported by their jurisdictional agencies. The SIP was most recently modified
in 2022 and was modified twice in that year. The USEPA is responsible for reviewing all SIPS to determine
whether they conform to the mandates of the CAA and its amendments, and to determine whether
implementing the SIPS will achieve air quality goals. If the USEPA determines a SIP to be inadequate, a
federal implementation plan that imposes additional control measures may be prepared for the
nonattainment area.
The USEPA also has regulatory and enforcement jurisdiction over emission sources beyond state waters (outer
continental shelf), and those that are under the exclusive authority of the federal government, such as aircraft,
locomotives, and interstate trucking. The USEPA's primary role at the state level is to oversee state air quality
programs. The USEPA sets federal vehicle and stationary source emissions standards and provides research
and guidance in air pollution programs.
City of Tustin 5.1-1
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June 2024
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5.1 Air
Hazardous Air Pollutants
The USEPA has programs for identifying and regulating hazardous air pollutants (HAPs). Title III of the CAAA
directed the USEPA to promulgate national emissions standards for HAPs (NESHAP). Major sources are
defined as stationary sources with potential to emit more than 10 tons per year (tpy) of any HAP or more
than 25 tpy of any combination of HAPs; all other sources are considered area sources. The emissions
standards are to be promulgated in two phases. In the first phase (1992-2000), the USEPA developed
technology -based emission standards designed to produce the maximum emission reduction achievable.
These standards are generally referred to as requiring maximum achievable control technology (MACT). For
area sources, the standards may be different, based on generally available control technology. In the second
phase (2001-2008), the USEPA promulgated health -risk -based emissions standards when deemed
necessary, to address risks remaining after implementation of the technology -based NESHAP standards.
Table 5.1-1: Ambient Air Quality Standards for Criteria Pollutants
State
National
Pollutant Health and Atmospheric
Pollutant
Averaging Time
Standard
Standard
Effects
Major Pollutant Sources
Ozone
1 hour
0.09 ppm
---
High concentrations can directly
Formed when ROG and NOx react in
8 hours
0.07 ppm
0.075 ppm
affect lungs, causing irritation.
the presence of sunlight. Major sources
Long-term exposure may cause
include on -road motor vehicles, solvent
damage to lung tissue.
evaporation, and commercial /
industrial mobile equipment.
Carbon
1 hour
20 ppm
35 ppm
Classified as a chemical
Internal combustion engines, primarily
Monoxide
8 hours
9.0 ppm
9 ppm
asphyxiant, carbon monoxide
gasoline -powered motor vehicles.
(CO)
interferes with the transfer of fresh
oxygen to the blood and deprives
sensitive tissues of oxygen.
Nitrogen
1 hour
0.18 ppm
0.100 ppm
Irritating to eyes and respiratory
Motor vehicles, petroleum refining
Dioxide
Annual
0.030 ppm
0.053 ppm
tract. Colors atmosphere reddish-
operations, industrial sources, aircraft,
(NO2)
Arithmetic Mean
brown.
ships, and railroads.
Sulfur
1 hour
0.25 ppm
75 ppb
Irritates upper respiratory tract;
Fuel combustion, chemical plants, sulfur
Dioxide
3 hours
---
0.50 ppm
injurious to lung tissue. Can yellow
recovery plants, and metal processing.
(S02)
24 hours
0.04 ppm
0.14 ppm
the leaves of plants, destructive to
Annual
---
0.03 ppm
marble, iron, and steel. Limits
Arithmetic Mean
visibility and reduces sunlight.
Respirable
24 hours
50 pg/m3 150 Ng/m3
May irritate eyes and respiratory
Dust and fume -producing industrial and
Particulate
Annual
20 jag/m3 ---
tract, decreases in lung capacity,
agricultural operations, combustion,
Matter
Arithmetic Mean
cancer and increased mortality.
atmospheric photochemical reactions,
(PMio)
Produces haze and limits visibility.
and natural activities (e.g., wind -raised
dust and ocean sprays).
Fine
24 hours
--- 35 jag/m3
Increases respiratory disease, lung
Fuel combustion in motor vehicles,
Particulate
Annual
12 Ng/m3 12 Ng/m3
damage, cancer, and premature
equipment, and industrial sources;
Matter
Arithmetic Mean
death. Reduces visibility and results
residential and agricultural burning;
(PM2.5)
in surface soiling.
Also, formed from photochemical
reactions of other pollutants, including
NOx, sulfur oxides, and organics.
Lead (Pb)
30 Day Average
1.5 jag/m3 ---
Disturbs gastrointestinal system,
Present source: lead smelters, battery
Calendar
--- 1.5 j.lg/m3
and causes anemia, kidney disease,
manufacturing and recycling facilities.
Quarter
and neuromuscular and
Past source: combustion of leaded
Rolling 3-Month
--- 0.15 pg/m3
neurological dysfunction (in severe
gasoline.
Average
cases).
Hydrogen
1 hour 0.03 ppm
No National
Nuisance odor (rotten egg smell),
Geothermal power plants, petroleum
Sulfide
Standard
headache and breathing difficulties
production and refining
(higher concentrations)
Sulfates
24 hour 25 pg/m3
No National
Decrease in ventilatory functions;
Industrial processes.
(SO4)
Standard
aggravation of asthmatic
symptoms; aggravation of cardio-
pulmonary disease; vegetation
damage; degradation of visibility;
property damage.
Visibility
8 hour Extinction of
No National
Reduces visibility, reduced airport
See PM2.5.
Reducing
0.23/km;
Standard
safety, lower real estate value,
Particles
visibility of
and discourages tourism.
10 miles or
more
Note: ppm = parts per million; ppb = parts per billion; jag/m3 = micrograms per cubic meter.
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Enderle Center Rezone Proiect 5.1 Air
The CAAA also required the USEPA to promulgate vehicle or fuel standards containing reasonable
requirements that control toxic emissions of, at a minimum, benzene and formaldehyde. Performance criteria
were established to limit mobile -source emissions of toxics, including benzene, formaldehyde, and 1,3-
butadiene. In addition, Section 219 required the use of reformulated gasoline in selected areas with the
most severe ozone nonattainment conditions to further reduce mobile -source emissions.
5.1.2.2 State Regulations
California Air Resources Board
Criteria Air Pollutants
The California Air Resources Board (CARB), a department of the California Environmental Protection Agency,
oversees air quality planning and control throughout California. CARB is responsible for coordination and
oversight of state and local air pollution control programs in California and for implementation of the
California Clean Air Act (CCAA). The CCAA, which was adopted in 1988, requires CARB to establish the
California Ambient Air Quality Standards (CAAQS). CARB has established CAAQS for sulfates, hydrogen
sulfide, vinyl chloride, visibility -reducing particulate matter, and the above -mentioned criteria air pollutants.
Applicable CAAQS are shown in Table 5.1-1.
The CCAA requires all local air districts in the state to endeavor to achieve and maintain the CAAQS by the
earliest practical date. The act specifies that local air districts shall focus particular attention on reducing the
emissions from transportation and area -wide emission sources and provides districts with the authority to
regulate indirect sources.
Among CARB's other responsibilities are overseeing compliance by local air districts with California and
federal laws, approving local air quality plans, submitting SIPS to the USEPA, monitoring air quality,
determining and updating area designations and maps, and setting emissions standards for new mobile
sources, consumer products, small utility engines, off -road vehicles, and fuels.
The California Air Resources Board Handbook
CARB has developed an Air Quality and Land Use Handbook which is intended to serve as a general
reference guide for evaluating and reducing air pollution impacts associated with new projects that go
through the land use decision -making process (California Air Resources Board, 2005). According to the CARB
Handbook, air pollution studies have shown an association between respiratory and other non -cancer health
effects and proximity to high traffic roadways. Other studies have shown that diesel exhaust and other
cancer -causing chemicals emitted from cars and trucks are responsible for much of the overall cancer risk
from airborne toxics in California. The CARB Handbook recommends that county and city planning agencies
strongly consider proximity to these sources when finding new locations for "sensitive" land uses such as
homes, medical facilities, daycare centers, schools, and playgrounds.
Land uses that can produce air pollution sources of concern include freeways, rail yards, ports, refineries,
distribution centers, chrome plating facilities, dry cleaners, and large gasoline service stations. Key
recommendations in the CARB Handbook include taking steps to avoid siting new, sensitive land uses:
• Within 500 feet of a freeway, urban roads with 100,000 vehicles/day or rural roads with 50,000
vehicles/day;
• Within 1,000 feet of a major service and maintenance rail yard;
• Immediately downwind of ports (in the most heavily impacted zones) and petroleum refineries;
• Within 300 feet of any dry cleaning operation (for operations with two or more machines, provide 500
feet); and
City of Tustin 5.1 -3
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5.1 Air
• Within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per
year or greater).
The CARB Handbook specifically states that its recommendations are advisory and acknowledges land use
agencies must balance other considerations, including housing and transportation needs, economic
development priorities, and other quality of life issues.
The recommendations are generalized and do not consider site -specific meteorology, freeway truck
percentages, or other factors that influence risk for a particular project site. The purpose of this guidance is
to help land use agencies determine when to further examine project sites for actual health risk associated
with the location of new sensitive land uses.
Toxic Air Contaminants
Toxic Air Contaminants (TACs) are airborne substances capable of causing short-term (acute) and long-term
(chronic or carcinogenic, i.e., cancer causing) adverse human health effects (i.e., injury or illness). Air quality
regulations also focus on TACs. In general, for those TACs that may cause cancer, there is no concentration
that does not present some risk. In other words, there is no safe level of exposure. This contrasts with the
criteria for air pollutants, for which acceptable levels of exposure can be determined and for which ambient
standards have been established. Instead, the USEPA and CARB regulate HAPs and TACs, respectively,
through statutes and regulations that generally require the use of the maximum achievable control technology
or best available control technology for toxics and to limit emissions. These statutes and regulations, in
conjunction with additional rules set forth by the districts, establish the regulatory framework for TACs.
TACs in California are regulated primarily through the Tanner Air Toxics Act (Assembly Bill [AB] 1807
[Chapter 1047, Statutes of 1983]) and the Air Toxics Hot Spots Information and Assessment Act (Hot Spots
Act) (AB 2588 [Chapter 1252, Statutes of 1987]). AB 1807 sets forth a formal procedure for CARB to
designate substances as TACs. This includes research, public participation, and scientific peer review before
CARB can designate a substance as a TAC. To date, CARB has identified more than 21 TACs and adopted
the USEPA's list of HAPs as TACs. Most recently, diesel PM was added to the CARB list of TACs. Once a TAC
is identified, CARB then adopts an airborne toxics control measure for sources that emit that particular TAC.
If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce
exposure below that threshold. If there is no safe threshold, the measure must incorporate best available
control technology to minimize emissions.
The Air Toxics Hot Spots Information and Assessment Act requires existing facilities emitting toxic substances
above a specified level to prepare a toxic -emission inventory, prepare a risk assessment if emissions are
significant, notify the public of significant risk levels, and prepare and implement risk reduction measures.
CARB published the Air Quality and Land Use Handbook: A Community Health Perspective (Handbook),
which provides guidance concerning land use compatibility with TAC sources (CARB, 2005). Although it is not
a law or adopted policy, the Handbook offers advisory recommendations for the siting of sensitive receptors
near uses associated with TACs, such as freeways and high -traffic roads, commercial distribution centers, rail
yards, ports, refineries, dry cleaners, gasoline stations, and industrial facilities, to help keep children and
other sensitive populations out of harm's way. In addition, CARB has promulgated the following specific rules
to limit TAC emissions:
• CARB Rule 2485 (1 3 CCR, Chapter 10 Section 2485), Airborne Toxic Control Measure to Limit Diesel -
Fueled Commercial Motor Vehicle Idling
• CARB Rule 2480 (1 3 CCR Chapter 10 Section 2480), Airborne Toxic Control Measure to Limit School
Bus Idling and Idling at Schools
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5.1 Air
• CARB Rule 2477 (1 3 CCR Section 2477 and Article 8), Airborne Toxic Control Measure for In -Use Diesel
Fueled Transport Refrigeration Units (TRU) and TRU Generator Sets and Facilities Where TRUs Operate
California Assembly Bill 1493— Pavley
In 2002, the California Legislature adopted AB 1493 requiring the adoption of regulations to develop fuel
economy standards for the transportation sector. In September 2004, pursuant to AB 1493, the CARB
approved regulations to reduce fuel use and emissions from new motor vehicles beginning with the 2009
model year (Pavley Regulations). CARB, EPA, and the U.S. Department of Transportation's National Highway
Traffic and Safety Administration (NHTSA) have coordinated efforts to develop fuel economy standards for
model 2017-2025 vehicles, which are incorporated into the "Low Emission Vehicle" (LEV) Regulations.
California Code of Regulations (CCR) Title 13, Motor Vehicles, Section 2449(d)(3)
No vehicle or engines subject to this regulation may idle for more than 5 consecutive minutes. The idling limit
does not apply to:
• Idling when queuing,
• Idling to verify that the vehicle is in safe operating condition,
• Idling for testing, servicing, repairing or diagnostic purposes,
• Idling necessary to accomplish work for which the vehicle was designed (such as operating a crane),
• Idling required to bring the machine system to operating temperature, and
• Idling necessary to ensure safe operation of the vehicle.
Title 24 Energy Efficiency Standards and California Green Building Standards
California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code (CALGreen) was first
adopted in 1978 in response to a legislative mandate to reduce California's energy consumption. CALGreen
is updated on a regular basis, with the most recently approved update consisting of the 2022 California
Green Building Code Standards that became effective January 1, 2023.
The 2022 CALGreen standards that reduce air quality emissions and are applicable to the proposed Project
include, but are not limited to, the following:
• Short-term bicycle parking. If the new project or an additional alteration is anticipated to generate
visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors' entrance,
readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with
a minimum of one two -bike capacity rack (5.106.4.1.1).
• Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenant -occupants,
provide secure bicycle parking for 5% of the tenant -occupant vehicular parking spaces with a minimum
of one bicycle parking facility (5.106.4.1.2).
• Designated parking for clean air vehicles. In new projects or additions to alterations that add 10 or
more vehicular parking spaces, provide designated parking for any combination of low -emitting, fuel -
efficient and carpool van pool vehicles as shown in Table 5.106.5.2 (5.106.5.2).
• EV charging stations. New construction shall facilitate the future installation of EV supply equipment. The
compliance requires empty raceways for future conduit and documentation that the electrical system has
adequate capacity for the future load. The number of spaces to be provided is contained within Table
5.106. 5.3.3 (5.106.5.3). Additionally, Table 5.106.5.4.1 specifies requirements for the installation of
raceway conduit and panel power requirements for medium- and heavy-duty electric vehicle supply
equipment for warehouses, grocery stores, and retail stores.
City of Tustin 5.1 -5
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Enderle Center Rezone Proiect 5.1 Air
• Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight,
uplight and glare ratings per Table 5.106.8 (5.106.8).
• Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the
nonhazardous construction and demolition waste in accordance with Section 5.408.1.1. 5.405.1.2, or
5.408.1.3; or meet a local construction and demolition waste management ordinance, whichever is more
stringent (5.408.1).
• Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation and
soils resulting primarily from land clearing shall be reused or recycled. For a phased project, such
material may be stockpiled on site until the storage site is developed (5.408.3).
• Recycling by Occupants. Provide readily accessible areas that serve the entire building and are
identified for the depositing, storage, and collection of non -hazardous materials for recycling, including
(at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a
lawfully enacted local recycling ordinance, if more restrictive (5.410.1).
• Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings
(faucets and showerheads) shall comply with the following:
o Water Closets. The effective flush volume of all water closets shall not exceed 1.28 gallons per flush
(5.303.3.1)
o Urinals. The effective flush volume of wall -mounted urinals shall not exceed 0.125 gallons per flush
(5.303.3.2.1). The effective flush volume of floor- mounted or other urinals shall not exceed 0.5
gallons per flush (5.303.3.2.2).
o Showerheads. Single showerheads shall have a minimum flow rate of not more than 1.8 gallons per
minute and 80 psi (5.303.3.3.1). When a shower is served by more than one showerhead, the
combined flow rate of all showerheads and/or other shower outlets controlled by a single valve
shall not exceed 1.8 gallons per minute at 80 psi (5.303.3.3.2).
o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not more
than 0.5 gallons per minute at 60 psi (5.303.3.4.1). Kitchen faucets shall have a maximum flow rate
of not more than 1.8 gallons per minute of 60 psi (5.303.3.4.2). Wash fountains shall have a
maximum flow rate of not more than 1.8 gallons per minute (5.303.3.4.3). Metering faucets shall
not deliver more than 0.20 gallons per cycle (5.303.3.4.4). Metering faucets for wash fountains shall
have a maximum flow rate of not more than 0.20 gallons per cycle (5.303.3.4.5).
• Outdoor potable water used in landscaped areas. Nonresidential developments shall comply with the
local water efficient landscape ordinance or the current California Department of Water Resources'
Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent (5.304.1).
• Water meters. Separate submeters or metering devices shall be installed for new buildings or additions
in excess of 50,000 SF or for excess consumption where any tenant within a new building or within an
addition is projected to consume more than 1,000 gallons per day (GPD) (5.303.1.1 and 5.303.1.2).
• Outdoor water uses in rehabilitated landscape projects equal or greater than 2,500 SF. Rehabilitated
landscape projects with an aggregate landscape area equal to or greater than 2,500 SF requiring a
building or landscape permit (5.304.3).
• Commissioning. For new buildings 10,000 SF and over, building commissioning shall be included in the
design and construction processes of the building project to verify that the building systems and
components meet the owner's or owner representative's project requirements (5.410.2).
The 2022 CALGreen Building Standards Code has been adopted by the Tustin City Code pursuant to
Ordinance No. 1529.
City of Tustin 5.1 -6
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.1 Air
5.1.2.3 Regional Regulations
South Coast Air Quality Management District
Criteria Air Pollutants
The South Coast Air Quality Management District (SCAQMD) attains and maintains air quality conditions in
the Basin through a comprehensive program of planning, regulation, enforcement, technical innovation, and
promotion of the understanding of air quality issues. The clean air strategy of SCAQMD includes preparation
of plans for attainment of ambient air quality standards, adoption and enforcement of rules and regulations
concerning sources of air pollution, and issuance of permits for stationary sources of air pollution. SCAQMD
also inspects stationary sources of air pollution and responds to citizen complaints; monitors ambient air
quality and meteorological conditions; and implements programs and regulations required by the CAA, CAA
Amendments, and CCAA. Air quality plans applicable to the proposed Project are discussed below.
Air Quality Management Plan
SCAQMD and the Southern California Association of Governments (SCAG) are responsible for preparing
the air quality management plan (AQMP), which addresses federal and State CAA requirements. The AQMP
details goals, policies, and programs for improving air quality in the Basin.
The 2012 AQMP was adopted by the SCAQMD Governing Board on December 12, 2012. The purpose of
the 2012 AQMP for the Basin is to set forth a comprehensive and integrated program that will lead the
region into compliance with the federal 24-hour PM2.5 air quality standard, and to provide an update to the
Basin's commitment towards meeting the federal 8-hour ozone standards. The AQMP would also serve to
satisfy recent USEPA requirements for a new attainment demonstration of the revoked 1 -hour ozone
standard, as well as a vehicle miles travelled (VMT) emissions offset demonstration. The 2012 AQMP, as
approved by CARB, serves as the official SIP submittal for the federal 2006 24-hour PM2.5 standard. In
addition, the AQMP updates specific new control measures and commitments for emissions reductions to
implement the attainment strategy for the 8-hour ozone SIP. The 2012 AQMP set forth programs which
require integrated planning efforts and the cooperation of all levels of government: local, regional, State,
and federal.
In March 2017 AQMD finalized the 2016 AQMP, which continued to evaluate integrated strategies and
control measures to meet the NAAQS, as well as explore new and innovative methods to reach its goals.
Some of these approaches include utilizing incentive programs, recognizing existing co -benefit programs
from other sectors, and developing a strategy with fair -share reductions at the federal, State, and local
levels. Similar to the 2012 AQMP, the 2016 AQMP incorporated scientific and technological information
and planning assumptions, including the 2016 RTP/SCS and updated emission inventory methodologies for
various source categories.
The 2022 AQMP was adopted by the SCAQMD Governing Board on December 2, 2022. The 2022 AQMP
builds upon measures already in place from previous AQMPs. It also includes a variety of additional
strategies such as regulation, accelerated deployment of available cleaner technologies (e.g., zero emissions
technologies, when cost-effective and feasible, and low NOx technologies in other applications), best
management practices, co -benefits from existing programs (e.g., climate and energy efficiency), incentives,
and other CAA measures to achieve the 2015 federal 8-hour ozone standard. SCAQMD included a total of
49 control measures in the 2022 AQMP, including control measures focused on widespread deployment of
zero emission and low NOx technologies through a combination of regulatory approaches and incentives.
The RTP/SCS also provides a combination of transportation and land use strategies that help the region
achieve State GHG emissions reduction goals and Federal Clean Air Act requirements, preserve open space
City of Tustin 5.1 -7
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June 2024
Enderle Center Rezone Proiect 5.1 Air
areas, improve public health and roadway safety, support our vital goods movement industry, and use
resources more efficiently. GHG emissions resulting from development -related mobile sources are the most
potent source of emissions.
SCAQMD Rules and Regulations
All projects are subject to SCAQMD rules and regulations. Specific rules applicable to the proposed Project
include the following:
Rule 203 — Permit to Operate. A person shall not operate or use any equipment or agricultural permit unit,
the use of which may cause the issuance of air contaminants, or the use of which may reduce or control the
issuance of air contaminants, without first obtaining a written permit to operate from the Executive Officer
or except as provided in Rule 202. The equipment or agricultural permit unit shall not be operated contrary
to the conditions specified in the permit to operate.
Rule 401 — Visible Emissions. A person shall not discharge into the atmosphere from any single source of
emission whatsoever any air contaminant for a period or periods aggregating more than three minutes in
any 1 hour that is as dark or darker in shade as that designated No. 1 on the Ringelmann Chart, as published
by the United States Bureau of Mines.
Rule 402 — Nuisance. A person shall not discharge from any source whatsoever such quantities of air
contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable
number of persons or to the public, or that endanger the comfort, repose, health, or safety of any such
persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or
property. The provisions of this rule do not apply to odors emanating from agricultural operations necessary
for the growing of crops or the raising of fowl or animals.
Rule 403 — Fugitive Dust. SCAQMD Rule 403 governs emissions of fugitive dust during and after
construction. Compliance with this rule is achieved through application of standard Best Management
Practices (BMP), such as application of water or chemical stabilizers to disturbed soils, covering haul vehicles,
restricting vehicle speeds on unpaved roads to 15 miles per hour, sweeping loose dirt from paved site access
roadways, cessation of construction activity when winds exceed 25 mph, and establishing a permanent
ground cover on finished sites.
Rule 403 requires project applicants to control fugitive dust using the best available control measures such
that dust does not remain visible in the atmosphere beyond the property line of the emission source. In
addition, Rule 403 requires implementation of dust suppression techniques to prevent fugitive dust from
creating an offsite nuisance. Applicable Rule 403 dust suppression (and PM10 generation) techniques to
reduce impacts on nearby sensitive receptors may include, but are not limited to, the following:
• Apply nontoxic chemical soil stabilizers according to manufacturers' specifications to all inactive
construction areas (previously graded areas inactive for 10 days or more).
• Water active sites at least three times daily. Locations where grading is to occur shall be thoroughly
watered prior to earthmoving.
• Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least 0.6 meters (2 feet)
of freeboard (vertical space between the top of the load and top of the trailer) in accordance with the
requirements of California Vehicle Code Section 23114.
• Reduce traffic speeds on all unpaved roads to 15 miles per hour (mph) or less.
• Suspend all grading activities when wind speeds (including instantaneous wind gusts) exceed 25 mph.
• Provide bumper strips or similar best management practices where vehicles enter and exit the
construction site onto paved roads, or wash off trucks and any equipment leaving the site each trip.
• Replant disturbed areas as soon as practical.
City of Tustin 5.1 -8
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5.1 Air
• Sweep onsite streets (and offsite streets if silt is carried to adjacent public thoroughfares) to reduce the
amount of particulate matter on public streets. All sweepers shall be compliant with SCAQMD Rule
1 1 86.1, Less Polluting Sweepers.
Rule 481 — Spray Coating. This rule applies to all spray painting and spray coating operations and
equipment and states that a person shall not use or operate any spray painting or spray coating equipment
unless one of the following conditions is met:
• The spray coating equipment is operated inside a control enclosure, which is approved by the Executive
Officer. Any control enclosure for which an application for permit for new construction, alteration, or
change of ownership or location is submitted after the date of adoption of this rule shall be exhausted
only through filters at a design face velocity not less than 100 feet per minute nor greater than 300
feet per minute, or through a water wash system designed to be equally effective for the purpose of
air pollution control.
• Coatings are applied with high -volume low-pressure, electrostatic and/or airless spray equipment.
• An alternative method of coating application or control is used which has effectiveness equal to or
greater than the equipment specified in the rule.
Rule 1108 - Volatile Organic Compounds. This rule governs the sale, use, and manufacturing of asphalt
and limits the volatile organic compound (VOC) content in asphalt used in the Basin. This rule also regulates
the VOC content of asphalt used during construction. Therefore, all asphalt used during construction of the
Project must comply with SCAQMD Rule 1108.
Rule 1113 — Architectural Coatings. No person shall apply or solicit the application of any architectural
coating within the SCAQMD with VOC content in excess of the values specified in a table incorporated in
the Rule.
Rule 1 143 — Paint Thinners and Solvents. This rule governs the manufacture, sale, and use of paint thinners
and solvents used in thinning of coating materials, cleaning of coating application equipment, and other
solvent cleaning operations by limiting their VOC content. This rule regulates the VOC content of solvents
used during construction. Solvents used during the construction phase must comply with this rule.
Rule 2305 — Warehouse Indirect Source Rule. On May 7, 2021, the SCAQMD Governing Board approved
Rule 2305. The stated purpose of the Indirect Source Rule "is to reduce local and regional emissions of
nitrogen oxides and particulate matter, and to facilitate local and regional emission reductions associated
with warehouses and the mobile sources attracted to warehouses in order to assist in meeting state and
federal air quality standards for ozone and fine particulate matter." The rule applies to owners and
operators of new and existing warehouses located in the South Coast Air Basin "with greater than or equal
to 100,000 square feet of indoor space in a single building that may be used for warehousing activities by
one or more warehouse operators." The rule imposes a "Warehouse Points Compliance Obligation" (WPCO)
on warehouse operators. Operators would be allowed to satisfy the WPCO by accumulating "Warehouse
Actions and Investments to Reduce Emissions Points" (WAIRE Points) in a given 1 2-month period. WAIRE Points
will be awarded by implementing measures to reduce emissions listed on the WAIRE Menu, or by
implementing a custom WAIRE Plan approved by the SCAQMD.
5.1.2.4 Local Regulations
City of Tustin General Plan
The City of Tustin has not prepared a Climate Action Plan. The City's General Plan includes policies related
to air quality in the Conservation, Open Space, and Recreation Element that include the following:
City of Tustin 5.1 -9
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5.1 Air
Conservation, Open Space, and Recreation Element
Goal 1: Reduce air pollution through proper land use, transportation and energy use planning.
Policy 1.1: Cooperate with the South Coast Air Quality Management District and the Southern
California Association of Governments in their effort to implement provisions of the region's
Air Quality Management Plan, as amended.
Policy 1.2: Design safe and efficient vehicular access to commercial land uses from arterial streets to
insure efficient vehicle ingress and egress.
Policy 1.3: Locate multiple family developments close to commercial areas to encourage pedestrian
rather than vehicular travel.
Policy 1.3: Create the maximum possible opportunities for bicycles as an alternative transportation
mode and recreational use.
Goal 2: Improve air quality by influencing transportation choices of mode, time of day, or
whether to travel and to establish a jobs/housing balance.
Policy 2.1: Reduce vehicle trips through incentives, regulations and/or Transportation Demand
Management (TDM) programs.
Policy 2.2: Reduce total vehicle miles traveled (VMT) through incentives, regulations and/or
Transportation Demand Management.
Policy 2.6: Encourage non -motorized transportation through the provision of bicycle and pedestrian
pathways.
Policy 2.7: Encourage employer rideshare and transit incentives programs by local businesses.
Policy 2.8: Manage non-residential parking supply to discourage auto use, while ensuring that economic
development goals will not be sacrificed.
Goal 3: Reduce particulate emissions to the greatest extent feasible.
Policy 3.1: Adopt incentives, regulations, and/or procedures to minimize particulate emissions from
paved and unpaved roads, agricultural uses, parking lots, and building construction.
5.1.3 ENVIRONMENTAL SETTING
Climate and Meteorology
The Project area is located within the South Coast Air Basin (Basin), which is under the jurisdiction of the South
Coast Air Quality Management District (SCAQMD). The Basin is a 6,600-square-mile coastal plain bounded
by the Pacific Ocean to the southwest and the San Gabriel, San Bernardino, and San Jacinto Mountains to
the north and east. The Basin includes the non -desert portions of Los Angeles, Riverside, and San Bernardino
counties, and all of Orange County.
The annual average temperature varies little throughout the Basin, ranging from the low to middle 60s°F.
With a more pronounced oceanic influence, coastal areas show less variability in annual minimum and
maximum temperatures than inland areas. The climatological station closest to the site is the Tustin Irvine
Ranch Station. The monthly average maximum temperature recorded at this station ranged from 66.8°F in
January to 85.2°F in August, with an annual average maximum of 75.4°F. The monthly average minimum
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temperature recorded at this station ranged from 40.2°F in January to 59XF in August, with an annual
average minimum of 49.4°F.
Most of the annual rainfall in the Basin occurs between November and March. Summer rainfall is minimal
and is generally limited to scattered thundershowers in coastal regions and slightly heavier showers in the
eastern portion of the Basin and along the coastal side of the mountains. Average monthly rainfall at the
Tustin Irvine Ranch Station varied from 0.01 inch in July to 2.67 inches in March, with an annual total of 12.86
inches. Patterns in monthly and yearly rainfall totals are unpredictable due to fluctuations in the weather.
The Basin experiences a persistent temperature inversion (increasing temperature with increasing altitude)
as a result of the Pacific high-pressure system. This inversion limits the vertical dispersion of air contaminants,
holding them relatively near the ground. As the sun warms the ground and the lower air layer, the
temperature of the lower air layer approaches the temperature of the base of the inversion (upper) layer
until the inversion layer finally breaks, allowing vertical mixing with the lower layer. This phenomenon is
observed in mid -afternoon to late afternoon on hot summer days when the air appears to clear up suddenly.
Winter inversions frequently break by midmorning.
Winds in the Project area blow predominantly from the south-southwest, with relatively low velocities. Wind
speeds in the Project area average about 5 miles per hour (mph). Summer wind speeds average slightly
higher than winter wind speeds. Low average wind speeds, together with a persistent temperature inversion,
limit the vertical dispersion of air pollutants throughout the Basin. Strong, dry, north, or northeasterly winds,
known as Santa Ana winds, occur during the fall and winter months, dispersing air contaminants. The Santa
Ana conditions tend to last for several days at a time.
The combination of stagnant wind conditions and low inversions produces the greatest pollutant
concentrations. On days of no inversion or high wind speeds, ambient air pollutant concentrations are the
lowest. During periods of low inversions and low wind speeds, air pollutants generated in urbanized areas
are transported predominantly on shore into Riverside and San Bernardino Counties. In the winter, the
greatest pollution problems are CO and NOx because of extremely low inversions and air stagnation during
the night and early morning hours. In the summer, the longer daylight hours and brighter sunshine combine to
cause a reaction between hydrocarbons and NOx to form photochemical smog. Smog is a general term that
is naturally occurring fog that has become mixed with smoke or pollution. In this context it is better described
as a form of air pollution produced by the photochemical reaction of sunlight with pollutants that have been
released into the atmosphere, especially by automotive emissions.
Criteria Air Pollutants
The California Air Resources Board (CARB) and the United States Environmental Protection Agency (USEPA)
currently focus on the following air pollutants as indicators of ambient air quality: ozone (Os), carbon
monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), respirable particulate matter with an
aerodynamic diameter of 10 micrometers or less (PMio), fine particulate matter with an aerodynamic
diameter of 2.5 micrometers or less (PM2.5), and lead. These pollutants are referred to as "criteria air
pollutants" because they are the most prevalent air pollutants known to be injurious to human health. Extensive
health -effects criteria documents regarding the effects of these pollutants on human health and welfare have
been prepared over the years.' Standards have been established for each criteria pollutant to meet specific
public health and welfare criteria set forth in the federal Clean Air Act (CAA). California has generally
adopted more stringent ambient air quality standards for the criteria air pollutants (referred to as State
Ambient Air Quality Standards, or State standards) and has adopted air quality standards for some
1 Additional sources of information on the health effects of criteria pollutants can be found at CARB and USEPA's websites at
http://www.arb.ca.gov/research/health/health.htm and http://www.epa.gov/air/airpollutants.htmll respectively.
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pollutants for which there is no corresponding national standard, such as sulfates, hydrogen sulfide, vinyl
chloride, and visibility -reducing particles.
Table 5.1-2 summarizes the sources and health effects of air pollutants discussed in this section.
Table 5.1-2: Sources and Health Effects of Air Pollutants
Pollutants
Sources
Primary Effects
Carbon
•
Incomplete combustion of fuels and
•
Reduced tolerance for exercise
Monoxide (CO)
other carbon -containing substances,
•
Impairment of mental function
such as motor exhaust
•
Impairment of fetal development
0
Natural events, such as decomposition
•
Death at high levels of exposure
of organic matter
•
Aggravation of some heart diseases (angina)
Nitrogen Dioxide
•
Motor vehicle exhaust
•
Aggravation of respiratory illness
(NO2)
•
High temperature stationary
•
Reduced visibility
combustion
•
Reduced plant growth
•
Atmospheric reactions
•
Formation of acid rain
Ozone
0
Atmospheric reaction of organic
•
Aggravation of respiratory and cardiovascular diseases
(Os)
gases with nitrogen oxides in sunlight
•
Irritation of eyes
•
Impairment of cardiopulmonary function
•
Plant leaf injury
Lead
•
Contaminated soil
•
Impairment of blood functions and nerve construction
(Pb)
•
Behavioral and hearing problems in children
Suspended
*
Stationary combustion of solid fuels
•
Reduced lung function
Particulate
0
Construction activities
•
Aggravation of the effects of gaseous pollutants
Matter
•
Industrial processes
•
Aggravation of respiratory and cardiorespiratory diseases
(PM2.5 and PMio)
•
Atmospheric chemical reactions
•
Increased cough and chest discomfort
•
Soiling
•
Reduced visibility
Sulfur Dioxide
*
Combustion of sulfur -containing fossil
•
Aggravation of respiratory diseases (asthma, emphysema)
(S02)
fuels
•
Reduced lung function
•
Smelting of sulfur -bearing metal ores
•
Irritation of eyes
Industrial processes
•
Reduced visibility
•
Plant injury
•
Deterioration of metals, textiles, leather, finishes, coatings,
etc.
Source: California Air Resources Board (2015).
Ozone
Ozone (Os), the main component of photochemical smog, is primarily a summer and fall pollution problem.
Ozone is not emitted directly into the air; but is formed through a complex series of chemical reactions
involving other compounds that are directly emitted. These directly emitted pollutants (also known as ozone
precursors) include reactive organic gases (ROGs) or volatile organic compounds (VOCs), and oxides of
nitrogen (NOx). While both ROGs and VOCs refer to compounds of carbon, ROG is a term used by CARB
and is based on a fist of exempted carbon compounds determined by CARB. VOC is a term used by the
USEPA and is based on its own exempt fist. The time period required for ozone formation allows the reacting
compounds to spread over a large area, producing regional pollution problems. Ozone concentrations are
the cumulative result of regional development patterns rather than the result of a few significant emission
sources.
Once ozone is formed, it remains in the atmosphere for one or two days. Ozone is then eliminated through
reaction with chemicals on the leaves of plants, attachment to water droplets as they fall to earth ("rainout"),
or absorption by water molecules in clouds that later fall to earth with rain ("washout").
Short-term exposure to ozone can irritate the eyes and cause constriction of the airways. In addition to
causing shortness of breath, ozone can aggravate existing respiratory diseases such as asthma, bronchitis,
and emphysema.
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5.1 Air
Carbon Monoxide
CO is a colorless, odorless gas produced by the incomplete combustion of carbon -containing fuels, such as
gasoline or wood. CO concentrations tend to be the highest during the winter morning, when little to no wind
and surface -based inversions trap the pollutant at ground levels. Because CO is emitted directly from internal
combustion engines, unlike ozone, motor vehicles operating at slow speeds are the primary source of CO in
the Basin. The highest ambient CO concentrations are generally found near congested transportation
corridors and intersections.
Nitrogen Dioxide
NO2 is a reddish -brown gas that is a by-product of combustion processes. Automobiles and industrial
operations are the main sources of NO2. Combustion devices emit primarily nitric oxide (NO), which reacts
through oxidation in the atmosphere to form NO2. The combined emissions of NO and NO2 are referred to
as NOx, which are reported as equivalent NO2. Aside from its contribution to ozone formation, NO2 can
increase the risk of acute and chronic respiratory disease and reduce visibility. NO2 may be visible as a
coloring component of a brown cloud on high pollution days, especially in conjunction with high ozone levels.
Sulfur Dioxide
SO2 is a colorless, extremely irritating gas or liquid that enters the atmosphere as a pollutant mainly as a
result of burning high sulfur -content fuel oils and coal, and from chemical processes occurring at chemical
plants and refineries. When SO2 oxidizes in the atmosphere, it forms sulfur trioxide (SO3). Collectively, these
pollutants are referred to as sulfur oxides (SOx).
Major sources of 502 include power plants, large industrial facilities, diesel vehicles, and oil -burning
residential heaters. Emissions of SO2 aggravate lung diseases, especially bronchitis. This compound also
constricts the breathing passages, especially in people with asthma and people involved in moderate to
heavy exercise. SO2 potentially causes wheezing, shortness of breath, and coughing. Long-term SO2
exposure has been associated with increased risk of mortality from respiratory or cardiovascular disease.
Particulate Matter
PM10 and PM2.5 consist of particulate matter that is 10 microns or less in diameter and 2.5 microns or less in
diameter, respectively (a micron is one -millionth of a meter). PM10 and PM2.5 represent fractions of particulate
matter that can be inhaled into the air passages and the lungs and can cause adverse health effects. Acute
and chronic health effects associated with high particulate levels include the aggravation of chronic
respiratory diseases, heart and lung disease, and coughing, bronchitis and respiratory illnesses in children.
Particulate matter can also damage materials and reduce visibility. One common source of PM2.5 is diesel
exhaust emissions.
PM10 consists of particulate matter emitted directly into the air (e.g., fugitive dust, soot, and smoke from
mobile and stationary sources, construction operations, fires, and natural windblown dust) and particulate
matter formed in the atmosphere by condensation and/or transformation of SO2 and ROG. Traffic generates
particulate matter emissions through entrainment of dust and dirt particles that settle onto roadways and
parking lots. PM10 and PM2.5 are also emitted by burning wood in residential wood stoves and fireplaces
and open agricultural burning. PM2.5 can also be formed through secondary processes such as airborne
reactions with certain pollutant precursors, including ROGs, ammonia (NH3), NOx, and SOx.
Lead
Lead is a metal found naturally in the environment and present in some manufactured products. There are a
variety of activities that can contribute to lead emissions, which are grouped into two general categories,
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stationary and mobile sources. On -road mobile sources include light -duty automobiles; light-, medium-, and
heavy-duty trucks; and motorcycles.
Emissions of lead have dropped substantially over the past 40 years. The reduction before 1990 is largely
due to the phase -out of lead as an anti -knock agent in gasoline for on -road automobiles. Substantial emission
reductions have also been achieved due to enhanced controls in the metals processing industry. In the Basin,
atmospheric lead is generated almost entirely by the combustion of leaded gasoline and contributes less
than one percent of the material collected as total suspended particulates.
Toxic Air Contaminants
In addition to the criteria pollutants discussed above, toxic air contaminants (TACs) are another group of
pollutants of concern. TACs are injurious in small quantities and are regulated by the USEPA and the CARB.
Some examples of TACs include benzene, butadiene, formaldehyde, and hydrogen sulfide. The
identification, regulation, and monitoring of TACs is relatively recent compared to that for criteria pollutants.
TACs do not have ambient air quality standards (AAQS), but are regulated by the USEPA, the CARB, and
the SCAQMD. In 1998, the CARB identified particulate matter from diesel -fueled engines as a TAC. The
CARB has completed a risk management process that identified potential cancer risks for a range of activities
using diesel -fueled engines. High -volume freeways, stationary diesel engines, and facilities attracting heavy
and constant diesel vehicle traffic (e.g., distribution centers and truck stops) were identified as posing the
highest risk to adjacent receptors. Other facilities associated with increased risk include warehouse
distribution centers, large retail or industrial facilities, high -volume transit centers, and schools with a high
volume of bus traffic. Health risks from TACs are a function of both concentration and duration of exposure.
Unlike TACs emitted from industrial and other stationary sources noted above, most diesel particulate matter
(DPM) is emitted from mobile sources —primarily "off -road" sources such as construction and mining
equipment, agricultural equipment, and truck -mounted refrigeration units, as well as "on -road" sources such
as trucks and buses traveling on freeways and local roadways.
Although not specifically monitored, recent studies indicate that exposure to DPM may contribute significantly
to a cancer risk (a risk of approximately 500 to 700 in 1,000,000) that is greater than all other measured
TACs combined. The technology for reducing DPM emissions from heavy-duty trucks is well established, and
both State and federal agencies are moving aggressively to regulate engines and emission control systems
to reduce and remediate diesel emissions. The CARB anticipated that by 2020, average statewide DPM
concentrations will decrease by 85 percent from levels in 2000 with full implementation of the CARB's Diesel
Risk Reduction Plan, meaning that the statewide health risk from DPM is expected to decrease from 540
cancer cases in 1,000,000 to 21.5 cancer cases in 1,000,000. The CARB 2000 Diesel Risk Reduction Plan is
still the most recent version and has not been updated.
CO Hotspots
An adverse CO concentration, known as a "hot spot" is an exceedance of the state one -hour standard of 20
ppm or the eight -hour standard of 9 ppm. It has long been recognized that CO hotspots are caused by
vehicular emissions, primarily when idling at congested intersections. In response, vehicle emissions standards
have become increasingly stringent in the last twenty years. Currently, the allowable CO emissions standard
in California is a maximum of 3.4 grams/mile for passenger cars (there are requirements for certain vehicles
that are more stringent). With the turnover of older vehicles, introduction of cleaner fuels, and implementation
of increasingly sophisticated and efficient emissions control technologies, CO concentration in the SCAB is
now designated as attainment.
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5.1 Air
Odorous Emissions
Odors are generally regarded as an annoyance rather than a health hazard. However, manifestations of a
person's reaction to foul odors can range from psychological (e.g., irritation, anger, or anxiety) to
physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache). Offensive odors
are unpleasant and can lead to public distress generating citizen complaints to local governments. Although
unpleasant, offensive odors rarely cause physical harm. The occurrence and severity of odor impacts depend
on the nature, frequency, and intensity of the source, wind speed, direction, and the sensitivity of receptors.
Existing Conditions
The State emitted approximately 381.3 MMT CO2e emissions in 2021, 12.1 MMT CO2e higher than 2020
levels and 49.7 MMT CO2e below the 2020 GHG limit of 431 MMT CO2e (California Air Resources Basin,
2023). CARB estimates that transportation was the source of approximately 38 percent of the State's GHG
emissions in 2021. The next largest sources included industrial sources at approximately 19 percent and
electricity generation at 16 percent. The remaining sources of GHG emissions were commercial and
residential activities at 10 percent, agriculture at 8 percent, high Global Warming Potentials (GWP) such as
activities involving refrigerants at 6 percent, and waste at 2 percent. GHG is discussed further in Section
5.3.
Air quality monitoring stations are located throughout the nation and are maintained by the local air pollution
control district and State air quality regulating agencies. The SCAQMD, together with the CARB, maintains
ambient air quality monitoring stations in the Basin. The air quality monitoring station closest to the Project
site is located at 1630 Pampas Lane in Anaheim, California.
Pollutant monitoring results for the years 2020 to 2022 at the Anaheim ambient air quality monitoring station,
shown in Table 5.1-3, indicate that air quality in the area has generally been moderate. As indicated in the
monitoring results, the federal PM10 standard was not exceeded during the 3-year period. The State PM10
standard was exceeded 5 times in 2020, once in 2021, and once in 2022. Similarly, the federal PM2.5
standard had 12 exceedances in 2020, 10 exceedances in 2021, and no exceedances in 2022. The State
1-hour ozone standards were exceeded 6 times in 2021, no times in 2021, and once in 2022. The State 8-
hour ozone standards were exceeded 16 times in 2020, no times in 2021, and once in 2022. The federal
8-hour standards were exceeded 15 times in 2021, no times in 2021, and once in 2022. The CO and NO2
standards were not exceeded in this area during the 3-year period. SO2 data was not available from 2020
to 2022 at air quality monitoring stations in Orange County.
Table 5.1-3: Air Quality Monitoring Summary 2020-2022
Pollutant Standard 2020 2021 1 2022
Carbon Monoxide (CO)
Maximum 1 -hour concentration (ppm)
2.3
2.1
2.4
Number of days exceeded:
State: > 20 ppm
0
0
0
Federal: > 35 ppm
0
0
0
Maximum 8-hour concentration (ppm)
1.7
1.5
1.4
Number of days exceeded:
State: > 9 ppm
0
0
0
Federal: > 9 ppm
0
0
0
Ozone (03)
Maximum 1-hour concentration (ppm) 1 10.142 10.089 10.102
Number of days exceeded: I State: > 0.09 ppm 16
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5.1 Air
Pollutant
Standard
2020
2021
2022
Maximum 8-hour concentration (ppm)
0.098
0.068
0.077
Number of days exceeded:
State: > 0.07 ppm
16
0
1
Federal: > 0.07 ppm
15
0
1
Coarse Particulates (PM10)
Maximum 24-hour concentration (Ng/m3)
74.8
63.6
67.0
Number of days exceeded:
State: > 50 pg/m3
5
1
1
Federal: > 150 Ng/m3
0
0
0
Annual arithmetic average concentration (pg/m3)
30.8
23.4
20.9
Exceeded for the year:
State: > 20 pg/m3
Yes
Yes
Yes
Federal: > 50 Ng/m3
No
No
No
Fine Particulates (PM2.5)
Maximum 24-hour concentration (Ng/m3)
64.8
54.4
33.1
Number of days exceeded:
Federal: > 35 pg/m3
12
10
0
Annual arithmetic average concentration (pg/m3)
12.4
1 1 .6
9.9
Exceeded for the year:
State: > 12 pg/m3
Yes
No
No
Federal,: > 12 pg/m3
No
No
No
Nitrogen Dioxide (NO2)
Maximum 1-hour concentration (ppm)
0.071
0.067
0.053
Number of days exceeded:
State: > 0.250 ppm
0
0
0
Annual arithmetic average concentration (ppm)
0.013
0.012
0.012
Exceeded for the year:
Federal: > 0.053 ppm
No
No
No
Sulfur Dioxide (SO2)
Maximum 1 -hour concentration (ppm)
ND
ND
ND
Number of days exceeded:
State: > 0.25 ppm
ND
ND
ND
Maximum 24-hour concentration (ppm)
ND
ND
ND
Number of days exceeded:
State: > 0.04 ppm
ND
ND
ND
Federal: > 0.14 ppm
ND
ND
ND
Annual arithmetic average concentration (ppm)
ND
ND
ND
Exceeded for the year:
Federal: > 0.030 ppm
ND
ND
ND
Sources: CARB (2023) and USEPA (2023).
On March 7, 2024, the federal annual PM2.5 standard was revised from 12.0 pg/m3 to 9.0 pg/m3. However,
since the data presented in Table 3.C-1 is through 2022, it uses the 12.0 pg/m3 standard that was in effect
through 2022.
pg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
ND = No data. There were insufficient (or no) data to determine the value.
Ppm = parts per million
USEPA = United States Environmental Protection Agency
The CARB is required to designate areas of the state as "attainment", "nonattainment", or "unclassified" for
all State standards. An attainment designation for an area signifies that pollutant concentrations did not
violate the standard for that pollutant in that area. A nonattainment designation indicates that a pollutant
concentration violated the standard at least once, excluding those occasions when a violation was caused by
an exceptional event, as defined in the criteria. An unclassified designation signifies that data do not support
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either an attainment or nonattainment status. The CCAA divides districts into moderate, serious, and severe
air pollution categories, with increasingly stringent control requirements mandated for each category.
The USEPA designates areas for Os, CO, and NO2 as either "does not meet the primary standards", or "cannot
be classified", or "better than national standards". For S02, areas are designated as "does not meet the primary
standards", "does not meet the secondary standards", "cannot be classified", "or better than national standards".
Table 5.1-4 provides a summary of the attainment status for the Basin with respect to NAAQS and CAAQS.
Table 5.1-4: Attainment Status of Criteria Pollutants in the South Coast Air Basin (SCAB)
Criteria Pollutant
State Designation
Federal Designation
Os — 1-hour standard
Nonattainment
Extreme Nonattainment
Os — 8-hour standard
Nonattainment
Extreme Nonattainment
PM1 o
Nonattainment
Attainment/Maintenance
PM2.5
Nonattainment
Serious Nonattainment
CO
Attainment
Attainment/Maintenance
NO2
Attainment
Attainment/Maintenance
S02
N/A
Attainment/Unclassified
Pb2
Attainment
Attainment'
Source: Air Quality Impact Analysis, 2024 (Appendix B).
Sensitive Land Uses
Land uses such as schools, children's daycare centers, hospitals, and convalescent homes are considered to
be more sensitive to poor air quality than the general public, because the population groups associated with
these uses have increased susceptibility to respiratory distress. In addition, residential uses are considered
more sensitive to air quality conditions than commercial and industrial uses, because people generally spend
longer periods of time at their residences, resulting in greater exposure to ambient air quality conditions.
Recreational land uses are considered moderately sensitive to air pollution. Exercise places a high demand
on respiratory functions, which can be impaired by air pollution, even though exposure periods during
exercise are generally short. In addition, noticeable air pollution can detract from the enjoyment of
recreation. The closest sensitive receptors to the Project site include residential uses, located approximately
70 feet south of the Project's site boundary (see Figure 2-3, Aerial View).
5.1.4 THRESHOLDS OF SIGNIFICANCE
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. Appendix G of State
CEQA Guidelines indicates that a project could have a significant effect if it were to:
AQ-1 Conflict with or obstruct implementation of the applicable air quality plan.
AQ-2 Result in a cumulatively considerable net increase of any criteria pollutant for which the project
region is non -attainment under an applicable federal or state ambient air quality standard.
AQ-3 Expose sensitive receptors to substantial pollutant concentrations.
AQ-4 Result in other emissions (such as those leading to odors) adversely affecting a substantial number
of people.
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5.1 Air
Regional Significance Thresholds
The SCAQMD's most recent regional significance thresholds from March 2023 for regulated pollutants are
listed in Table 5.1-5. The SCAQMD's CEQA air quality methodology provides that any projects that result
in daily emissions that exceed any of the thresholds in Table 5.1-5 would be considered to have both an
individually (Project -level) and cumulatively significant air quality impact.
Table 5.1-5: SCAQMD Regional Air Quality Thresholds
Pollutant
Construction
Operations
Nox
100 Ibs/day
55 Ibs/day
VOC
75 Ibs/day
55 Ibs/day
PM10
150 Ibs/day
150 Ibs/day
PM2.5
55 Ibs/day
55 Ibs/day
sox
150 Ibs/day
150 Ibs/day
CO
550 Ibs/day
550 Ibs/day
Lead
3 Ibs/day
3 Ibs/day
Source: Air Quality Impact Analysis.
2024 (Appendix Bl.
Local Significance Thresholds
The SCAQMD published its Final Localized Significance Threshold Methodology in July 2008, recommending
that all air quality analyses include an assessment of air quality impacts to nearby sensitive receptors. This
guidance was used to analyze potential localized air quality impacts associated with construction of the
Project. Localized significance thresholds (LST) are developed based on the size or total area of the emission
source, the ambient air quality in the source receptor area, and the distance to the project. Sensitive receptors
include residences, schools, hospitals, and similar uses that are sensitive to adverse air quality.
LSTs are developed based on the ambient concentrations of that pollutant for each of the 38 source receptor
areas (SRAs) in the Basin. The Project site is located within Central Orange County (SRA 17). For the Project,
the appropriate SRA for the LST is the nearby Central Orange County (SRA 17). SCAQMD provides LST
screening tables for 25-, 50-, 100-, 200-, and 500-meter source -receptor distances. As identified above,
the closest sensitive receptors to the Project site include residential uses, located approximately 70 feet south
of the Project's site boundary. In cases where sensitive receptors may be closer than 82 feet (25 meters),
any distance within the 82-foot (25-meter) buffer zone can be used. As such, the minimum distance of 25
meters was conservatively used for the "worst case scenario". Based on the anticipated construction
equipment, it is assumed that the maximum daily disturbed acreage during construction would be 3.5 acres.
The 5-acre thresholds were used for Project operation. Table 5.1-6 lists the conservative emissions thresholds
that apply during potential future Project construction and operation.
Table 5.1-6: SCAQMD Localized Significance Thresholds
Pollutant Emissions Threshold (Ibs/day)
Emissions Source
NO, CO PM10 PM2.5
Construction 149.0 984.0 9.5 5.5
Operations 183.0 1,253.0 3.0 2.0
Source: South Coast Air Quality Management District (2008).
CO = carbon monoxide PM10 = particulate matter less than 10 microns in size
Ibs/day = pounds per day PM2.5 = particulate matter less than 2.5 microns in size
NOx = nitrogen oxides
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5.1 Air
Local Microscale Concentration Standards
The significance of localized project impacts under CEQA depends on whether ambient CO levels in the
vicinity of the project are above or below State and federal CO standards. Because ambient CO levels are
below the standards throughout the Basin, a project would be considered to have a significant CO impact if
project emissions result in an exceedance of one or more of the 1-hour or 8-hour standards. The following
are applicable local emission concentration standards for CO:
• California State 1 -hour CO standard of 20 parts per million (ppm)
• California State 8-hour CO standard of 9 ppm
5.1.5 METHODOLOGY
This analysis focuses on the nature and magnitude of the change in the air quality environment that could
potentially occur through future buildout of the Project, based on the maximum development assumptions
that are outlined in Section 3.0, Project Description. Therefore, the following analysis provides a conservative
assumption of emissions that represent "worst case scenario".
Air pollutant emissions associated with the Project would result from construction equipment usage and from
construction -related traffic. Additionally, emissions would be generated from operations of the future
residences and from traffic volumes generated by this new use. The net increase in emissions generated by
these activities and other secondary sources have been quantitatively estimated and compared to the
applicable thresholds of significance recommended by SCAQMD.
AQMP Consistency
SCAQMD's CEQA Handbook suggests an evaluation of the following two criteria to determine whether a
project involving a legislative land use action (such as the proposed General Plan land use and zoning
designation changes) would be consistent or in conflict with the AQMP:
1. The project would not generate population and employment growth that would be inconsistent with
SCAG's growth forecasts.
2. The project would not result in an increase in the frequency or severity of existing air quality violations
or cause or contribute to new violations or delay the timely attainment of air quality standards or the
interim emissions reductions specified in the AQMP.
Consistency Criterion No. 1 refers to the SCAG's growth forecast and associated assumptions included in the
AQMP. The future air quality levels projected in the AQMP are based on SCAG's growth projections, which
are based, in part, on the general plans of cities and counties located within the SCAG region, and, in part,
on SCAG's three Land Development Categories. Therefore, if the level of housing or employment related to
the Project are consistent with the applicable assumptions used in the development of the AQMP, the Project
would not jeopardize attainment of the air quality levels identified in the AQMP.
Consistency Criterion No. 2 refers to the California Ambient Air Quality Standards (CAAQS). An impact
would occur if the long-term emissions associated with the Project would exceed SCAQMD's regional
significance thresholds for operation -phase emissions.
Construction Emissions
Construction activities can generate a substantial amount of air pollution. Construction activities are
considered temporary; however, short-term impacts can contribute to exceedances of air quality standards.
Construction activities include demolition, site preparation, earthmoving, and general construction. The
City of Tustin 5.1 -1 9
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.1 Air
emissions generated from these common construction activities include fugitive dust from soil disturbance, fuel
combustion from mobile heavy-duty diesel and gasoline powered equipment, portable auxiliary equipment,
and worker commute trips.
The California Emissions Estimator Model version 2022.1 (CaIEEMod) computer program was used to
calculate emissions from on -site construction equipment and emissions from worker and vehicle trips to the
site. Information regarding a specific development project is not yet known; however, for the purposes of
this analysis, future development of the additional 413 units and remaining commercial buildout capacity
associated with the proposed project could occur anytime between October 2024 and October 2029.
Therefore, to be conservative, this analysis assumes a project construction schedule based on a start date of
October 2024 and a default construction duration in CaIEEMod and assuming architectural coating would
overlap with building construction activities. The proposed project would demolish the existing surface
parking area but would not demolish any existing buildings. This analysis also assumes that the proposed
project would comply with SCAQMD Rule 403 measures. In addition, this analysis assumes the use of Tier 2
construction equipment, which was also included in CaIEEMod. All other construction details are not yet known;
therefore, default assumptions (e.g., construction worker and truck trips and fleet activities) from CaIEEMod
were used.
Operational Emissions
The air quality analysis includes estimating emissions associated with long-term operation of the proposed
project. Consistent with the SCAQMD guidance for estimating emissions associated with land use
development projects, the CaIEEMod computer program was used to calculate the long-term operational
emissions associated with the project.
This analysis evaluates the buildout of 413 units and remaining commercial buildout capacity within the
project site and compares the potential impacts to impacts associated with the existing commercial uses as
determined based on two CaIEEMod runs.
As identified in the Project Description, the existing uses that were modeled consist of the Enderle Center that
is currently developed with 87,136 sq ft of commercial business uses, including 28,750 sq ft of restaurant
use, 39,960 sq ft of retail and service use, and 18,426 sq ft of office use. The analysis was conducted using
land use codes High Turnover (Sit Down Restaurant), Strip Mall, General Office Building, and Parking Lot. Trip
generation rates used in CaIEEMod for the existing uses were based on the trip generation rate of 7,058
ADT.
The analysis of the future buildout of the project site included the existing development, the buildout of 413
units, and the addition of the total remaining nonresidential use including a total of 67,837 sq ft of restaurant
use, 94,288 sq ft of retail and service use, and 43,477 sq ft of office use. The analysis was conducted using
land use codes Apartments Mid Rise, High Turnover (Sit Down Restaurant), Strip Mall, and General Office
Building assuming a total trip generation of 18,528 ADT. This analysis assumes that the proposed project
would not include any woodburning hearths or wood stoves. Where project -specific data were not available,
default assumptions (e.g., energy usage, water usage, and solid waste generation) from CaIEEMod were
used to estimate project emissions.
5.1.6 ENVIRONMENTAL IMPACTS
IMPACT AQ-1: THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT IMPLEMENTATION OF
THE APPLICABLE AIR QUALITY PLAN.
City of Tustin 5.1-20
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June 2024
Enderle Center Rezone
5.1 Air
No Impact.
A consistency determination plays an essential role in local agency project review by linking local planning
and unique individual projects to the air quality plans. A consistency determination fulfills the CEQA goal of
fully informing local agency decision -makers of the environmental costs of the project under consideration at
a stage early enough to ensure that air quality concerns are addressed. Only new or amended General
Plan elements, Specific Plans, and significantly unique projects need to undergo a consistency review due to
the air quality plan strategy being based on projections from local General Plans.
Consistency with the 2022 AQMP would be achieved if the project is consistent with the goals, objectives,
and assumptions in this plan to achieve the federal and State air quality standards. Per SCAQMD's CEQA
Air Quality Handbook, there are two main indicators of a project's consistency with the AQMP:
Indicator 1: Whether the project would result in an increase in the frequency or severity of existing air
quality violations, cause or contribute to new violations, or delay timely attainment of the ambient air quality
standards or emission reductions in the AQMP.
Indicator 1: As demonstrated below, the regional emissions generated by construction and operation
of the proposed project would be less than the SCAQMD emissions thresholds. As such, the proposed
project would not be inconsistent with Indicator 1.
Indicator 2: Whether the project would exceed the assumptions in the AQMP. The AQMP strategy is, in part,
based on projections from local general plans.
Indicator 2: The CEQA Air Quality Handbook indicates that consistency with AQMP growth
assumptions must be analyzed for new or amended General Plan elements, Specific Plans, and
significant projects. Significant projects include airports, electrical generating facilities, petroleum
and gas refineries, designation of oil drilling districts, water ports, solid waste disposal sites, and
offshore drilling facilities.
The proposed Project includes a GPA to amend the City's existing General Plan to allow for a higher density
of residential development in commercial land use designations than are currently allowed and to_create a
Housing Overlay (HO) zone. The proposed Project would not directly result in physical development, but
upon approval of the Housing Overlay, the Project site could accommodate 413 units as a result of the
changes in regulations. As such, this analysis evaluates whether the Project would exceed the 2022 AQMP's
assumptions.
With respect to determining the proposed Project's consistency with AQMP growth assumptions, the
projections in the AQMP for achieving air quality goals are based on assumptions in SCAG's RTP/SCS
regarding population, housing, and growth trends. According to SCAG's 2020-2045 RTP/SCS, the City's
population, households, and employment are forecast to increase by approximately 10,500 residents, 4,100
households, and 21,600 jobs, respectively, between 2016 and 2045.
As identified in Section 3.0, Project Description, the City's 2021-2029 Housing Element identifies several
adequate sites that are able to accommodate the development of up to additional housing units for the City
to meet its estimated housing growth needs identified in the SCAG's RHNA allocation. Of the Housing Element
inventory sites, Enderle Center (the Project site) was identified as necessary for rezoning under Housing
Element Program 1.1 f to allow for high density residential/mixed use development. The proposed project
would accommodate up to 413 housing units to help the City meet its RHNA allocation.
As described in Section 5.6, Population and Housing, the development of 413 housing units would result in
approximately 1,189 additional residents based on the estimated 2.88 persons per household in Tustin.
Future development implemented in accordance with the proposed Housing Overlay Zone would
accommodate planned regional housing growth included in the SCAG RHNA and would be required to
City of Tustin 5.1-21
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.1 Air
adhere to the General Plan. Therefore, since the purpose of the proposed Project is to accommodate planned
regional housing growth included in the SCAG RHNA, the proposed Project would not exceed the growth
assumptions in the SCAG's RTP/SCS or the AQMP.
In addition, since the proposed Project would not include airports, electrical generating facilities, petroleum
and gas refineries, designation of oil drilling districts, water ports, solid waste disposal sites, and offshore
drilling facilities, the proposed Project is not a significant project as defined by the SCAQMD CEQA Air
Quality Handbook. Therefore, it is unlikely that the proposed Project would interfere with SCAQMD's goals
for improving air quality in the region. The proposed Project would not conflict with the 2022 AQMP and,
as such, would not jeopardize attainment of the CAAQS and NAAQS in the area under the jurisdiction of the
SCAQMD. The proposed Project is therefore considered consistent with Indicator 2.
Summary: Based on the discussion above, the proposed Project would not conflict or obstruct implementation
of applicable air quality plans under Indicator 1 because the proposed Project would result in pollutant
emissions below the SCAQMD's thresholds. The Project would also be consistent with the regional AQMP
(Indicator 2), since the purpose of the Project is to accommodate planned regional housing growth included
in the SCAG RHNA. As such, based on the consistency analysis presented above, the proposed Project would
be consistent with the regional AQMP.
IMPACT AQ-2: THE PROJECT WOULD NOT RESULT IN A CUMULATIVELY CONSIDERABLE NET
INCREASE OF ANY CRITERIA POLLUTANT FOR WHICH THE PROJECT REGION IS
NON -ATTAINMENT UNDER AN APPLICABLE FEDERAL OR STATE AMBIENT AIR
QUALITY STANDARD.
Less than Significant Impact.
The Basin is designated as non -attainment for Os and PM2.5 for federal standards and non -attainment for
Os, PMio, and PM2.5 for State standards. The SCAQMD's nonattainment status is attributed to the region's
development history. Past, present, and future development projects contribute to the region's adverse air
quality impacts on a cumulative basis. By its very nature, air pollution is largely a cumulative impact. No
single project is sufficient in size to, by itself, result in nonattainment of AAQS. Instead, a project's individual
emissions contribute to existing cumulatively significant adverse air quality impacts. If a project's contribution
to the cumulative impact is considerable, then the project's impact on air quality would be considered
significant.
In developing thresholds of significance for air pollutants, the SCAQMD considered the emission levels for
which a project's individual emissions would be cumulatively considerable. If a project exceeds the identified
significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air
quality impacts to the region's existing air quality conditions. Therefore, additional analysis to assess
cumulative impacts is unnecessary. The following analysis assesses the Project -level construction- and
operation -related air quality impacts.
Construction
It is important to note that the Project would not, in and of itself entitle, propose, or otherwise require the
construction of new development. The proposed project would create a Housing Overlay Zone that would
accommodate 413 units.
Construction activities associated with the construction of additional housing units and remaining commercial
buildout capacity that could occur with implementation of the Project would be through the horizon year
2029, which would cause short-term emissions of criteria air pollutants. The primary source of emissions is the
operation of construction equipment. Before development can take place, a project will be required to be
City of Tustin 5.1-22
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.1 Air
analyzed for conformance with the General Plan, zoning requirements, and other applicable local and State
requirements; comply with the requirements of CEQA; and obtain all necessary clearances and permits.
Construction activities would include demolition of existing parking lots and landscaping, site preparation,
grading, building construction, architectural coating, and paving activities. Construction -related effects on air
quality are typically greatest during the grading phase due to the disturbance of soil. If not properly
controlled, these activities would temporarily generate particulate emissions. Sources of fugitive dust would
include disturbed soils at construction sites. Unless properly controlled, vehicles leaving construction sites
would deposit dirt and mud on local streets, which could be an additional source of airborne dust after it
dries. PM10 emissions would vary from day to day, depending on the nature and magnitude of construction
activity and local weather conditions. PM10 emissions would depend on soil moisture, silt content of soil, wind
speed, and the amount of operating equipment. Larger dust particles would settle near the source, whereas
fine particles would be dispersed over greater distances from the construction site.
Water or other soil stabilizers can be used to control dust, resulting in emission reductions of 50 percent or
more. The SCAQMD has established Rule 403 (Fugitive Dust), which would require the contractor to implement
measures that would reduce the amount of particulate matter generated during the construction period.
In addition to dust -related PM10 emissions, heavy trucks and construction equipment powered by gasoline
and diesel engines would generate CO, S02, NOX, VOCs and some soot particulate (PM2.5 and PM10) in
exhaust emissions. If construction activities were to increase traffic congestion in the area, CO and other
emissions from traffic would increase slightly while those vehicles idle in traffic. These emissions would be
temporary in nature and limited to the immediate area surrounding the construction site.
Construction emissions were estimated for development envisioned under the Project using CaIEEMod. As
described in the Methodology section above, information regarding a specific development project is not
yet known; however, for the purposes of this analysis, future development of the additional 413 units and
remaining commercial buildout capacity associated with the proposed Project could occur anytime between
October 2024 and October 2029. Therefore, to be conservative, this analysis assumes a Project construction
schedule based on a start date of October 2024 and a default construction duration in CaIEEMod. Table
5.1-7 lists the tentative schedule, and Table 5.1-8 lists the potential construction equipment to be used during
Project construction under each phase of construction. Construction -related emissions are presented in Table
5.1-9.
Table 5.1-7: Tentative Project Construction Schedule
Phase Number
Phase Name
Phase Start Date
Phase End Date
Number of
Days/Week
Number of Days
1
Demolition
10/7/2024
1 1 /4/2024
5
20
2
Site Preparation
1 1 /5/2024
1 1 /19/2024
5
10
3
Grading
11/20/2024
1/1/2025
5
30
4
Building
Construction
1 /2/2025
2/26/2026
5
300
5
Paving
2/27/2026
3/27/2026
5
20
6
Architectural
Coating
12/8/2025
4/25/2026
5
100
Source: Compiled by LSA assuming construction would start October 2024 with a default construction duration in CalEEMod and
assuming architectural coating would overlap with building construction activities. This analysis also assumes demolition of the
surface parking lot would occur over a 30-day period (March 2024).
City of Tustin 5.1-23
Draft EIR
June 2024
Enderle Center Rezone
5.1 Air
Table 5.1-8: Diesel Construction Equipment Utilized by Construction Phase
Construction
Phase
Off -Road Equipment Type
Off -Road Equipment
Unit Amount
Hours Used
per Day
Horsepower
Load
Factor
Demolition
Concrete/Industrial Saws
1
8
33
0.73
Excavators
3
8
36
0.38
Rubber Tired Dozers
2
8
367
0.4
Site Preparation
Rubber Tired Dozers
3
8
367
0.4
Tractors/Loaders/Backhoes
4
8
84
0.37
Grading
Excavators
2
8
36
0.38
Graders
1
8
148
0.41
Rubber Tired Dozers
1
8
367
0.4
Scrapers
2
8
423
0.48
Tractors/Loaders/Backhoes
2
8
84
0.37
Building
Cranes
1
7
367
0.29
Construction
Forklifts
3
8
82
0.2
Generator Sets
1
8
14
0.74
Tractors/Loaders/Backhoes
3
7
84
0.37
Welders
1
8
46
0.45
Paving
Pavers
2
8
81
0.42
Paving Equipment
2
8
89
0.36
Rollers
2
8
36
0.38
Architectural
Coating
Air Compressors
1
6
37
0.48
Source: Compiled by LSA using CalEEMod defaults (March 2024).
CalEEMod = California Emissions Estimator Model
Table 5.1-9: Project Construction Emissions
Year
Emissions (lbs/day)
VOCs
NOx
CO
sox
PM10
PM2.5
2024
1.4
48.9
36.4
0.1
11.2
5.0
2025
38.0
48.9
36.3
0.1
6.6
2.7
2026
37.9
23.5
34.8
<0.1
6.6
2.1
Maximum Daily Emissions
37.9
48.9
36.4
0.1
11.2
5.0
SCAQMD Thresholds
75.0
100.0
550.0
150.0
150.0
55.0
Exceeds?
No
No
No
No
No
No
Source: Air Quality Impact Analysis, March 2024
CO = carbon monoxide
Ibs/day = pounds per day
NOx = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size
PMio = particulate matter less than 10 microns in size
SCAQMD = South Coast Air Quality Management District
SOx = sulfur oxides
VOCs = volatile organic compounds
As shown in Table 5.1-8, construction emissions associated with future development, as envisioned under the
Project would not exceed the SCAQMD thresholds for VOCs, NOX, CO, sulfur oxides (SOX), PM2.5, or PM10
emissions. Future development projects would be required to comply with SCAQMD Rule 403: Fugitive Dust,
which would further reduce construction -related emissions. Therefore, future construction of development
projects consistent with the Project would not result in emissions that would result in significant impact related
City of Tustin 5.1-24
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.1 Air
to net increase of any criteria pollutant for which the project region is in nonattainment under an applicable
federal or State ambient air quality standard.
Operation
Operational activities associated with the additional housing units and remaining commercial buildout
capacity consistent with the buildout envisioned as part of the proposed Project would result in long-term air
pollutant emissions associated with mobile sources (e.g., vehicle trips), energy sources (e.g., natural gas), and
area sources (e.g., architectural coatings and the use of landscape maintenance equipment). Before
development can take place, a project would be required to be analyzed for conformance with the General
Plan, zoning requirements, and other applicable local and State requirements; comply with the requirements
of CEQA; and obtain all necessary clearances and permits.
PM10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into the
atmosphere from vehicles traveling on paved roadways. Entrainment of PM10 occurs when vehicle tires
pulverize small rocks and pavement and the vehicle wakes generate airborne dust. The contribution of tire
and brake wear is small compared to the other PM emission processes. Gasoline -powered engines have
small rates of particulate matter emissions compared with diesel -powered vehicles. The existing uses
generate approximately 7,058 ADT and the proposed Project would generate approximately 18,528 ADT,
as noted in Section 5.9, Transportation.
Energy source emissions result from activities in buildings for which electricity and natural gas are used. The
quantity of emissions is the product of usage intensity (i.e., the amount of natural gas) and the emission factor
of the fuel source. Major sources of energy demand for the Project could include building mechanical systems,
such as heating and air conditioning, though the Project would not include the use of natural gas. The
residential units would be constructed in compliance with the version of the Title 24 energy standards and
the CALGreen Code in effect at the time building permit applications are submitted.
Typically, area source emissions consist of direct sources of air emissions located at the Project site, including
architectural coatings, consumer products, and the use of landscape maintenance equipment.
Long-term operation emissions associated with development consistent with the Project were calculated using
CalEEMod. Model results are shown in Appendix B of this document.
The results shown in Table 5.1-10 indicate that the net new emissions associated with the future development
of the Project would not exceed the significance criteria for VOCs, NOX, CO, SOX, PM10, or PM2.5
emissions; thus, the Project would not have a significant impact on regional air quality.
Table 5.1-10: Project Operational Emissions
Emission Type Emissions (lbs/day)
VOCs NO. CO I SOX PM10 PM2.5
Existing Uses
Existing Uses Mobile Sources
23.7
19.0
192.5
0.5
42.0
10.9
Existing Uses Area Sources
2.8
<0.1
3.8
<0.1
<0.1
<0.1
Existing Uses Energy Sources
0.1
1.1
0.9
<0.1
0.1
0.1
Total Existing Uses Emissions
26.5
20.0
197.2
0.5
42.1
11.0
Full Buildout of the Project site
Project Buildout Mobile
62.4
50.4
511.7
1.2
112.1
29.0
Sources
Project Buildout Area
18.0
6.2
34.9
<0.1
0.5
0.5
Sources
City of Tustin 5.1-25
Draft EIR
June 2024
Enderle Center Rezone
5.1 Air
Project Buildout Energy
0.2
3.7
2.6
<0.1
0.3
0.3
Sources
Total Project Buildout
80.6
60.2
549.2
1.3
112.9
29.8
Emissions
Net New Emissions (Project
54.1
40.2
352.0
0.8
70.8
18.8
Buildout — Existing Uses)
SCAQMD Thresholds
55.0
55.0
550.0
150.0
150.0
55.0
Significant?
No
No
No
No
No
No
Source: Air Quality Impact Analysis, (March 2024)
CO = carbon monoxide PMio = particulate matter less than 10 microns in size
Ibs/day = pounds per day SCAQMD = South Coast Air Quality Management District
NOx = nitrogen oxides SOx = sulfur oxides
PM2.5 = particulate matter less than 2.5 microns in size VOCs = volatile organic compounds
IMPACT AQ-3: THE PROJECT WOULD EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL POLLUTANT
CONCENTRATIONS.
Significant and Unavoidable.
CO Hotspots
Vehicular trips associated with the Project would contribute to congestion at intersections and along roadway
segments in the Project vicinity. Localized air quality impacts would occur when emissions from vehicular
traffic increase as a result of the Project. The primary mobile -source pollutant of local concern is CO, a direct
function of vehicle idling time and, thus, of traffic flow conditions. CO transport is extremely limited; under
normal meteorological conditions, CO disperses rapidly with distance from the source. However, under
certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may
reach unhealthful levels, affecting local sensitive receptors (e.g., residents, schoolchildren, the elderly, and
hospital patients). Typically, high CO concentrations are associated with roadways or intersections operating
at unacceptable levels of service or with extremely high traffic volumes. In areas with high ambient
background CO concentrations, modeling is recommended to determine a project's effect on local CO levels.
An assessment of project -related impacts on localized ambient air quality requires that future ambient air
quality levels be projected. Existing CO concentrations in the immediate Project vicinity are not available.
Ambient CO levels monitored at the Anaheim monitoring station, the closest station to the City of Tustin,
showed a highest recorded 1 -hour concentration of 2.4 ppm (the State standard is 20 ppm) and a highest
8-hour concentration of 1.7 ppm (the State standard is 9 ppm) during the past 3 years (Table 5.1-3). The
highest CO concentrations would normally occur during peak traffic hours; hence, CO impacts calculated
under peak traffic conditions represent a worst -case analysis.
Full buildout of development consistent with the Project would generate 11,470 net new ADT in the immediate
vicinity of the opportunity sites and would result in 757 net new AM peak -hour trips and in 1,041 net new
PM peak -hour trips. The Project would not result in any operational deficiencies to the surrounding roadway
system. The evaluation of the study area intersections shows that the addition of traffic associated with new
residential development allowed under the Project's Housing Overlay Zone is not expected to create
significant level of service changes under Project build out. Therefore, Project traffic would not create any
significant adverse impacts to nearby intersections.
Therefore, given the extremely low level of CO concentrations in the City, and lack of traffic impacts at any
intersections, project -related vehicles are not expected to contribute significantly or result in the CO
concentrations exceeding the State or federal CO standards. Therefore, the Project would result in a less
than significant impact.
City of Tustin 5.1-26
Draft EIR
June 2024
Enderle Center Rezone
5.1 Air
Health Risk Assessment
The SCAQMD recommends the evaluation of localized air quality impacts to sensitive receptors such as
residential land uses in the immediate vicinity of the Project site as a result of construction and operational
activities. The thresholds are based on standards established by the SCAQMD in its Localized Significance
Thresholds (LST) Methodology and are measured against construction and operational emissions that occur
on a specific Project site (Southern California Air Quality Managment District, 2021). These emissions are
primarily generated from heavy-duty construction equipment and demolition, grading, and trenching
activities. Construction and operational activities associated with the construction of additional housing units
and remaining commercial buildout capacity that could occur with implementation of the Project would have
the potential to cause or contribute to significant localized air quality impacts to nearby residential land
uses.
Construction and operation emissions associated with development consistent with the Project were compared
to the LST screening tables in SRA 17, based on a 25-meter source -receptor distance.
By design, the localized impacts analysis only includes on -site emission sources; however, the CalEEMod
outputs do not separate on -site and off -site emissions for mobile sources. For a worst -case scenario
assessment, the emissions (detailed in Tables 5.1 -1 1 and 5.1-1 2 below) assume all area and energy source
emissions would occur on site, and 5 percent of the Project -related new mobile sources, which is an estimate
of the amount of Project -related on -site vehicle travel, would occur on site. Given that the majority of vehicle
travel would occur off site and considering the total overall VMT and trip length included in CalEEMod,
assuming that 5 percent of the Project's VMT would occur on site is conservative.
The results of the LST analysis, summarized in Tables 5.1-1 1 and 5.1-12, indicate that the Project would
result in an exceedance of the SCAQMD LSTs for PM10 during Project construction and operation.
Table 5.1-11: Project Localized Construction Emissions (Ibs/day)
Source
NOx
CO
PM10
PM2.5
On -Site Project Construction Emissions
48.8
35.3
8.8
4.9
Localized Significance Threshold
149.0
984.0
9.5
5.5
Exceeds Threshold?
No
No
No
No
CO = carbon monoxide
Ibs/day = pounds per day
NOx = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size
PMio= particulate matter less than 10 microns in size
Table 5.1-12: Project Localized Operational Emissions (Ibs/day)
Source
NOx
CO
PM10
PM2.5
On -Site Project Buildout Net New
Emissions
10.4
48.8
4.2
1.6
Localized Significance Threshold
183.0
1,253.0
3.0
2.0
Exceeds Threshold?
No
No
Yes
No
CO = carbon monoxide
Ibs/day = pounds per day
NOx = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size
PMio= particulate matter less than 10 microns in size
The results of the LST analysis, summarized in Table 5.1-1 1, indicate that the Project would not result in an
exceedance of the SCAQMD LSTs during Project construction. However, net new emissions associated with
City of Tustin 5.1-27
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.1 Air
the future development of the proposed Project would exceed the SCAQMD LSTs for PM10 during
operational activities. As shown in Table 5.1-1 2 above, the majority of the PM10 emissions are associated
with mobile sources from project -related vehicle trips. Emissions of motor vehicles are controlled by State
and federal standards, and the project has no control over these standards. Furthermore, this analysis
considers the most conservative scenario for future development allowed under the proposed Project, as
details regarding future projects are unknown, and it is not known whether development would occur.
Although future development details are unknown, implementation of Mitigation Measure AQ-1 would
require a project -specific assessment of potential localized impacts for future projects and if future projects
exceed the applicable LST thresholds, a dispersion modeling analysis would be necessary to calculate health
risk from project implementation. While Mitigation Measure AQ-1 would serve to reduce localized emissions
associated with buildout of the project, localized emission impacts would remain significant and unavoidable.
It should be noted that the amount of emissions from a project does not necessarily correspond to the
concentrations of air pollutants. A dispersion modeling analysis would be necessary to calculate health risk
from project implementation. However, since it is not possible to translate the amount of an unknown future
specific project's emissions to a particular concentration, it is not possible to calculate the risk factor for a
particular health effect at the time of this analysis.
Known health effects related to ozone include worsening of bronchitis, asthma, and emphysema and a
decrease in lung function. Particulate matter can also lead to a variety of health effects in people. These
include premature death of people with heart or lung disease, heart attacks, irregular heartbeat, decreased
lung function, and increased respiratory symptoms. Regional emissions of criteria pollutants contribute to
these known health effects. The SCAQMD is the primary agency responsible for ensuring the health and
welfare of sensitive individuals and that they are not exposed to elevated concentrations of criteria
pollutants in the Basin. To achieve the health -based standards established by the USEPA, the SCAQMD
prepared an AQMP that details regional programs to attain ambient air quality standards.
The analysis for the Project identifies that construction and operational emissions associated with
development envisioned as part of the Project would be less than significant under the SCAQMD's thresholds
for VOCs, NOX, CO, SOX, PM2.5, or PM10 emissions. However, it should be noted that the SCAQMD's
numeric regional mass daily thresholds does not necessarily correspond to a determination for health risk
impacts to sensitive receptors. This is because the mass daily thresholds are in pounds per day emitted into
the air, whereas health effects are determined based on the concentration of emissions in the air at a
particular receptor (e.g., ppm by volume of air, or pg/m3 of air). State and federal ambient air quality
standards were developed to protect the most susceptible population groups from adverse health effects
and were established in terms of parts per million or micrograms per cubic meter for the applicable emissions.
However, the SCAQMD acknowledges that they have only been able to correlate potential health outcomes
for very large emissions sources; specifically, 6,620 pounds per day (Ibs/day) of NOx, and 89,180 Ibs/day
of VOCs were expected to result in approximately 20 premature deaths per year and 89,947 school
absences due to ozone. As identified in 5.1-10 above, construction of the proposed Project would generate
a maximum of 48.9 Ibs/day of NOx and 29.7 Ibs/day of VOCs and as shown in 5.1-1 1, operation of the
proposed Project would generate a maximum of 22.4 Ibs/day of NOx and 39.7 Ibs/day of VOCs.
Therefore, it is not expected that any future development associated with the proposed Project would
generate 6,620 Ibs/day of NOx or 89,180 Ibs/day of VOC emissions.
Therefore, emissions associated with the Project are not sufficiently high enough to correlate health effects
on a Basin -wide level.
Current scientific, technological, and modeling limitations prevent the relation of expected adverse air
quality impacts to likely health consequences. For this reason, this discussion explains why it is not feasible to
provide such an analysis. However, once a specific project is proposed, it would still be required to conduct
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a site -specific localized impact analysis that evaluates potential project health impacts at a project level
relative to immediately adjacent land uses.
In addition, the Project would be required to comply with SCAQMD standard conditions, including Rule 403
(Fugitive Dust) to control fugitive dust and Rule 1 1 1 3 (Architectural Coatings) to control VOC emissions from
paint. Furthermore, any necessary mitigation would be imposed at the project level once such future projects
are proposed. However, the Project is conservatively assumed to result in a significant and unavoidable
health risk impact.
Asbestos
Naturally occurring asbestos (NOA) refers to the asbestos mineral as a natural component of soils or rocks,
as opposed to asbestos in commercial products or other processing operations. Ultramafic rocks may contain
asbestos or asbestos -like materials. Naturally occurring asbestos can be released from rocks or soils by
routine human activities, such as construction, mining, agriculture, or natural weathering processes. If NOA is
disturbed and fibers are released into the air it may become a health risk from inhalation. According to the
California Geological Survey, no such rock has been identified in the Project vicinity (LSA, 2024). When
demolition is proposed to accommodate construction, the demolition of existing buildings could expose
asbestos used in building materials. The construction of development projects envisioned under the Project
would only include the demolition of the existing surface parking; therefore, existing buildings on the Project
site would not be demolished as part of the Project. Therefore, the potential risk for naturally occurring
asbestos during potential future project construction is small and would be less than significant.
IMPACT AQ-4: THE PROJECT WOULD NOT RESULT IN OTHER EMISSIONS (SUCH AS THOSE LEADING
TO ODORS) ADVERSELY AFFECTING A SUBSTANTIAL NUMBER OF PEOPLE.
Less than Significant Impact.
The proposed Project would not emit other emissions, such as those generating objectionable odors, that
would affect a substantial number of people. The threshold for odor is identified by SCAQMD Rule 402,
Nuisance, which states:
A person shall not discharge from any source whatsoever such quantities of air contaminants or other
material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons
or to the public, or which endanger the comfort, repose, health or safety of any such persons or the
public, or which cause, or have a natural tendency to cause, injury or damage to business or property.
The provisions of this rule shall not apply to odors emanating from agricultural operations necessary
for the growing of crops or the raising of fowl or animals.
The type of facilities that are considered to result in other emissions, such as objectionable odors, include
wastewater treatments plants, compost facilities, landfills, solid waste transfer stations, fiberglass
manufacturing facilities, paint/coating operations (e.g., auto body shops), dairy farms, petroleum refineries,
asphalt batch plants, chemical manufacturing, and food manufacturing facilities.
During construction of future development allowed under the Project, some odors may be present due to
diesel exhaust. However, these odors would be temporary and limited to the construction period. The Project
would allow for the development of future residential and commercial uses and would not include any
activities or operations that would generate objectionable odors and once operational. Therefore, the
proposed Project would not result in other emissions (such as those leading to odors) affecting a substantial
number of people.
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5.1.7 CUMULATIVE IMPACTS
This section presents information regarding potential cumulative impacts associated with the proposed
Project. As defined in the State CEQA Guidelines, cumulative impacts are the incremental effects of an
individual project when viewed in connection with the effects of past, current, and probable future projects
within the cumulative impact area. Table 5-1 in Section 5.0, Environmental Impact Analysis, provides a list of
cumulative projects; however, because of the lack of available emissions data for the cumulative projects,
cumulative emissions were not evaluated quantitatively. Table 5-1 lists the cumulative projects and provides
a brief description and the distances from the Project site and Figure 5-1 includes a map of the various
cumulative projects considered. The list includes two projects within the City of Santa Ana, and six projects
within the City of Tustin.
The SCAQMD 2022 AQMP evaluates regional conditions within the Basin and sets regional emission
significance thresholds for both construction and operation of development projects that apply to project -
specific impacts and cumulatively -considerable impacts. Therefore, per SCAQMD's methodology, if an
individual project would result in air emissions of criteria pollutants that exceeds the SCAQMD's thresholds
for project -specific impacts, then it would also result in a cumulatively considerable net increase of these
criteria pollutants.
As described in Impact AQ-2 above, emissions from construction and operation would not exceed
SCAAQMD's thresholds for any criteria pollutant at the regional or local level after implementation of
existing regulations. Therefore, operational sources emissions would not be cumulatively considerable and
would be less than significant.
As discussed in Impact AQ-3 the Project would not result in an exceedance of the SCAQMD LSTs during
project construction. However, net new emissions associated with the future development of the proposed
Project would exceed the SCAQMD LSTs for PM10 during operational activities. While Mitigation Measure
AIR-1 would serve to reduce localized emissions associated with buildout of the project, localized emission
impacts would remain significant and unavoidable. Therefore, impacts on human health risks would be
cumulatively considerable and would be significant and unavoidable.
As discussed in Impact AQ-4, the Project would not expose surrounding uses to objectionable odors. Thus,
there is no potential for odors from the Project to combine with odors from surrounding development Projects
and expose nearby sensitive receptors to offensive odors. Therefore, the Project would not result in significant
cumulative impacts related to odors.
5.1.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES.
Existing Regulations
State
• California Green Building Standards Code (Code of Regulations, Title 24 Part b)
Regional
• SCAQMD Rule 402: Nuisance Odors
• SCAQMD Rule 403: Fugitive Dust
• Rule 481 — Spray Coating.
• Rule 1 108 - Volatile Organic Compounds.
• SCAQMD Rule 1 1 1 3: Architectural Coatings
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• Rule 1 143 — Paint Thinners and Solvents.
Plans, Programs, or Policies
These actions will be included in the Project's mitigation monitoring and reporting program (MMRP):
PPP AQ-1: Rule 403. The Project is required to comply with the provisions of South Coast Air Quality
Management District (SCAQMD) Rule 403, which includes the following:
• All clearing, grading, earth -moving, or excavation activities shall cease when winds exceed 25 mph
per SCAQMD guidelines in order to limit fugitive dust emissions.
• The contractor shall ensure that all disturbed unpaved roads and disturbed areas within the project
are watered, with complete coverage of disturbed areas, at least 3 times daily during dry weather;
preferably in the mid -morning, afternoon, and after work is done for the day.
• The contractor shall ensure that traffic speeds on unpaved roads and Project site areas are reduced
to 15 miles per hour or less.
PPP AQ-2: Rule 1113. The Project is required to comply with the provisions of South Coast Air Quality
Management District Rule (SCAQMD) Rule 1 1 1 3. Only "Low -Volatile Organic Compounds" paints (no more
than 50 gram/liter of VOC) and/or High Pressure Low Volume (HPLV) applications shall be used.
PPP A04: Rule 402. The Project is required to comply with the provisions of South Coast Air Quality
Management District (SCAQMD) Rule 402. The Project shall not discharge from any source whatsoever such
quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any
considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of
any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to
business or property.
5.1.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
The Project would result in no impact related to Impact AQ-1 and less than significant impacts to Impacts
AQ-2 and AQ-4. The Project would result in a potentially significant impact to AQ-3.
5.1.10 MITIGATION MEASURES
Mitigation Measure AIR-1. Prior to building permit approval by the City of Tustin (City) for future
development projects, project applicants shall prepare and submit a technical assessment evaluating
potential project -related air quality impacts, including a localized impacts analysis, to the City for review
and approval. The analysis shall be prepared in conformance with South Coast Air Quality Management
District (SCAQMD) methodology. If project -related emissions exceed applicable SCAQMD thresholds of
significance, the City shall require that applicants for new development projects incorporate mitigation
measures to reduce emissions. The identified measures shall be included as part of the conditions of approval.
Additionally, if project -related localized emissions exceed the SCAQMD's thresholds, a dispersion modeling
analysis shall be conducted to calculate potential health risk from project implementation, and all necessary
mitigation measures shall be implemented.
5.1.1 1 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Upon implementation of existing regulatory requirements, the Project would result in no impact related to
Impact AQ-1 and less than significant impacts related to Impacts AQ-2 and AQ-4. Impact AQ-3 would be
significant and unavoidable even with implementation of mitigation measures.
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5.1.1 2 REFERENCES
California Air Resources Basin. (2023). California Greenhouse Gas Emissions for 2000 to 2027, Trends of
Emissions and Otherindicators Report. Retrieved from
https://ww2.arb.ca.gov/sites/default/files/2023-1 2/2000_2021 _ghg_inventory_trends.pdf
California Air Resources Board. (2005, April). Air Quality and Land Use Handbook: A Community Health
Perspective. Retrieved from https://www.agmd.gov/docs/default-
source/cega/handbook/california-air-resources-board-air-quality-and-1and -use-handbook-a-
community-health-perspective.pdf
LSA. (2024). The Market Place Project Air Quality, Energy, and Greenhouse Gas Report.
Southern California Air Quality Managment District. (2021). Localized Significance Thresholds. Retrieved from
http://www.agmd.gov/home/rules-compliance/cega/air-quality-analysis-handbook/localized-
significance-thresholds
Southern California Association of Governments. (2024, April). Connect SoCal 2024-2050 Regional
Transportation Plan/Sustainable Communities Strategy. Retrieved from https://scag.ca.gov/connect-
socal
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5.2
5.2 Energy
5.2.1 INTRODUCTION
This section of the Draft EIR assesses the significance of the use of energy, including electricity, natural gas
and gasoline, and diesel fuels, that would result from implementation of the Project. It discusses existing
energy use patterns and examines whether the Project (including development and operation) would result
in the consumption of large amounts of fuel or energy or use such resources in a wasteful manner.
Refer to Section 5.3, Greenhouse Gas Emissions, for a discussion of the relationship between energy
consumption and greenhouse gas (GHG) emissions, and Section 5.11, Utilities and Service Systems, for a
discussion of water consumption. This section includes data from the following City documents and report
from LSA in Appendix B:
• City of Tustin General Plan (including 202 7 -2029 Housing Element). Adopted November 20 7 8 (updated
October 2022).
• Tustin City Code
• Enderle Center Project Air Quality, Energy, and Greenhouse Gas Report, LSA, March 2024, Appendix B.
5.2.2 REGULATORY SETTING
5.2.2.1 Federal Regulations
Energy Independence and Security Act, Corporate Average Fuel Efficiency Standards
On December 19, 2007, the Energy Independence and Security Act of 2007 was signed into law, requiring
an increased Corporate Average Fuel Economy (CAFE) standard of 35 miles per gallon (mpg) for the
combined fleet of cars and light trucks by the 2020 model year.
In addition to setting increased CAFE standards for motor vehicles, the Energy Independence and Security
Act includes the following additional provisions:
• Renewable Fuel Standard (RFS) (Section 202)
• Appliance and Lighting Efficiency Standards (Sections 301-325)
• Building Energy Efficiency (Sections 41 1-441)
Additional provisions of the Act address energy savings in government and public institutions, promoting
research for alternative energy, additional research in carbon capture, international energy programs, and
the creation of green jobs.
Energy Policy Act of 2005
The Energy Policy Act of 2005 seeks to reduce reliance on non-renewable energy resources and provide
incentives to reduce current demand on these resources. For example, under this Act, consumers and
businesses can obtain federal tax credits for purchasing fuel -efficient appliances and products (including
hybrid vehicles), building energy -efficient buildings, and improving the energy efficiency of commercial
buildings. Additionally, tax credits are available for the installation of qualified fuel cells, stationary
microturbine power plants, and solar power equipment.
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5.2
Corporate Average Fuel Economy (CAFE) Standards
On March 31, 2022, the National Highway Traffic Safety Administration (NHTSA) finalized the Corporate
Average Fuel Economy (CAFE) standards for Model Years 2024-2026 Passenger Cars and Light Trucks. The
amended CAFE standards would require an industry wide fleet average of approximately 49 mpg for
passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8 percent annually for
model years 2024-2025, and 10 percent annually for model year 2026. The final standards are estimated
to save about 234 billion gallons of gas between the model years 2030 to 2050.
5.2.2.2 State Regulations
Assembly Bill 1575, Warren-Alquist Act
In 1975, largely in response to the oil crisis of the 1970s, the State Legislature adopted Assembly Bill
(AB) 1575 (also known as the Warren-Alquist Act), which created the CEC. The statutory mission of the CEC
is to forecast future energy needs; license power plants of 50 megawatts (MW) or larger; develop energy
technologies and renewable energy resources; plan for and direct State responses to energy emergencies;
and, perhaps most importantly, promote energy efficiency through the adoption and enforcement of
appliance and building energy efficiency standards. AB 1575 also amended Public Resources Code
(PRC) Section 21 100(b)(3) and State CEQA Guidelines Section 15126.4 to require Environmental Impact
Reports (EIRs) to include, where relevant, mitigation measures proposed to minimize the wasteful, inefficient,
and unnecessary consumption of energy caused by a project. Thereafter, the State Resources Agency created
Appendix F to the State CEQA Guidelines. Appendix F assists EIR preparers in determining whether a project
will result in the inefficient, wasteful, and unnecessary consumption of energy. Appendix F of the State CEQA
Guidelines also states that the goal of conserving energy implies the wise and efficient use of energy and
the means of achieving this goal, including (1) decreasing overall per capita energy consumption; (2)
decreasing reliance on fossil fuels such as coal, natural gas, and oil; and (3) increasing reliance on renewable
energy sources.
Senate Bill 1389, Energy: Planning and Forecasting
In 2002, the State Legislature passed Senate Bill (SB) 1389, which required the CEC to develop an
integrated energy plan every 2 years for electricity, natural gas, and transportation fuels for the California
Energy Policy Report. The plan calls for the State to assist in the transformation of the transportation system
to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least
environmental and energy costs. To further this policy, the plan identifies several strategies, including
assistance to public agencies and fleet operators in implementing incentive programs for zero emission
vehicles (ZEVs) and their infrastructure needs, and encouragement of urban designs that reduce vehicle miles
traveled (VMT) and accommodate pedestrian and bicycle access.
In compliance with the requirements of SB 1389, the CEC adopts an Integrated Energy Policy Report every
2 years and an update every other year. The most recently adopted report includes the 2023 Integrated
Energy Policy Report (California Energy Commission, 2023). The Integrated Energy Policy Report covers a
broad range of topics, including decarbonizing buildings, integrating renewables, energy efficiency, energy
equity, integrating renewable energy, updates on Southern California electricity reliability, climate
adaptation activities for the energy sector, natural gas assessment, transportation energy demand forecast,
and the California Energy Demand Forecast. The Integrated Energy Policy Report provides the results of the
CEC's assessments of a variety of energy issues facing California. Many of these issues will require action if
the State is to meet its climate, energy, air quality, and other environmental goals while maintaining energy
reliability and controlling costs.
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5.2
Renewable Portfolio Standard
SB 1078 established the California Renewable Portfolio Standards program in 2002. SB 1078 initially
required that 20 percent of electricity retail sales be served by renewable resources by 2017; however,
this standard has become more stringent over time. In 2006, SB 107 accelerated the standard by requiring
that the 20 percent mandate be met by 2010. In April 2011, SB 2 required that 33 percent of electricity
retail sales be served by renewable resources by 2020. In 2015, SB 350 established tiered increases to the
Renewable Portfolio Standards of 40 percent by 2024, 45 percent by 2027, and 50 percent by 2030. In
2018, SB 100 increased the requirement to 60 percent by 2030 and required that all the State's electricity
come from carbon -free resources by 2045. SB 100 took effect on January 1, 2019 (California Public Utilities
Commission, 2019).
Title 24, California Building Code
Energy consumption by new buildings in California is regulated by the Building Energy Efficiency Standards,
embodied in Title 24 of the California Code of Regulations (CCR), known as the California Building Code
(CBC). The CEC first adopted the Building Energy Efficiency Standards for Residential and Non-residential
Buildings in 1978 in response to a legislative mandate to reduce energy consumption in the State. The CBC
is updated every 3 years, with the most recent update consisting of the 2022 CBC that became effective
January 1, 2023. The efficiency standards apply to both new construction and rehabilitation of both
residential and non-residential buildings, and regulate energy consumed for heating, cooling, ventilation,
water heating, and lighting. The building efficiency standards are enforced through the local building permit
process. Local government agencies may adopt and enforce energy standards for new buildings, provided
these standards meet or exceed those provided in CCR Title 24.
California Green Building Standards Code (CALGreen Code)
In 2010, the California Building Standards Commission (CBSC) adopted Part 11 of the Title 24 Building
Energy Efficiency Standards, referred to as the California Green Building Standards Code (CALGreen
Code). The CALGreen Code took effect on January 1, 2011. The CALGreen Code is updated on a regular
basis, with the most recent update consisting of the 2022 CALGreen Code standards that became effective
January 1, 2023. The CALGreen Code established mandatory measures for residential and non-residential
building construction and encouraged sustainable construction practices in the following five categories: (1)
planning and design, (2) energy efficiency, (3) water efficiency and conservation, (4) material conservation
and resource efficiency, and (5) indoor environmental quality. Although the CALGreen Code was adopted
as part of the State's efforts to reduce greenhouse gas (GHG) emissions, the CALGreen Code standards
have co -benefits of reducing energy consumption from residential and non-residential buildings subject to
the standard.
California Energy Efficiency Strategic Plan
On September 18, 2008, the CPUC adopted California's first Long -Term Energy Efficiency Strategic Plan,
presenting a roadmap for energy efficiency in California. The Plan articulates a long-term vision and goals
for each economic sector and identifies specific near -term, mid-term, and long-term strategies to assist in
achieving those goals. The plan also reiterates the following four specific programmatic goals known as the
"Big Bold Energy Efficiency Strategies" that were established by the CPUC in Decisions D.07-10-032 and
D.07-12-051:
• All new residential construction will be zero net energy (ZNE) by 2020.
• All new commercial construction will be ZNE by 2030.
• 50 percent of commercial buildings will be retrofitted to ZNE by 2030.
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50 percent of new major renovations of State buildings will be ZNE by 2025.
5.2.2.3 Local and Regional Regulations
City of Tustin General Plan
The City of Tustin addresses energy in the Conservation, Open Space, and Recreation Element of the City of
Tustin General Plan. The Conservation, Open Space, and Recreation Element contains policies that work to
reduce energy consumption. The following policies are applicable to the Project.
Goal 4: Reduce emissions through reduced energy consumption.
Policy 4.1: Promote energy conservation in all sectors of the City including residential, commercial, and
industrial.
Policy 4.2: Promote local recycling of wastes and the use of recycled materials.
Goal11: Conserve energy resources through use of available energy technology and
conservation practices.
Policy 1 1.2: Maintain local legislation to establish, update and implement energy performance building
code requirements established under State Title 24 Energy Regulations.
Tustin City Code
Tustin City Code Article 8, Section 8100, Building and Construction Codes Adopted by Reference by the City,
includes adoption of 2022 California Energy Code (Title 24, Part 6), The 2022 California Green Building
Standards Code (Title 24, Part 1 1), and 2022 California Building Code (Title 24, Part 2), as well as other
state standards.
5.2.3 ENVIRONMENTAL SETTING
5.2.3.1 Electricity
The Southern California Edison Company (SCE) is the electrical purveyor in the City of Tustin. SCE provides
electricity service to more than 14 million people in a 50,000 square -mile area of central, coastal and
Southern California. California utilities are experiencing increasing demands that require modernization of
the electric distribution grid to, among other things, accommodate two-way flows of electricity and increase
the grid's capacity. SCE is in the process of implementing infrastructure upgrades to ensure the ability to
meet future demands. In addition, as described by the Edison International 2022 Annual Report, the SCE
electrical grid modernization effort supports implementation of California requirements to achieve carbon
neutrality by 2045. The state has set Renewables Portfolio Standards that require retail sellers of electricity
to provide 60 percent of power from renewable resources by 2030. The state also requires sellers of
electricity to deliver 100 percent of retail sales from carbon -free sources by 2045, including interim targets
of 90 percent by 2035 and 95 percent by 2040. In 2022 approximately 48 percent of power that SCE
delivered to customers came from carbon -free resources (Southern California Edison, 2022).
The Project site is currently served by the electricity distribution systems that exist along the roadways
adjacent to the Project site.
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5.2
5.2.3.2 Natural Gas
The Southern California Gas Company (SoCalGas) is the natural gas purveyor in the City of Tustin and is
the principal distributor of natural gas in Southern California. SoCalGas estimates that gas demand will
decline at an annual rate of 1.5 percent from 2022 to 2035 due to modest economic growth, mandated
energy efficiency standards and programs, renewable electricity goals, and fuel substitution (Southern
California Gas Company, et. al., 2022). The gas supply available to SoCalGas is regionally diverse and
includes supplies from California sources (onshore and offshore), Southwestern U.S. supply sources, the Rocky
Mountains, and Canada. SoCalGas designs its facilities and supplies to provide continuous service during
extreme peak demands and has identified the ability to meet peak demands through 2035.
The Project is within the service area of Southern California Gas Company (SoCal Gas).
5.2.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:
ENE-1 Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project construction or operation.
ENE-2 Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
5.2.5 METHODOLOGY
A number of factors are considered when weighing whether a project would use a proportionately large
amount of energy or whether the use of energy would be wasteful in comparison to other projects. Factors
such as the use of on -site renewable energy features, energy conservation features or programs, and relative
use of transit are considered.
According to Appendix F of the CEQA Guidelines, conserving energy is defined as decreasing overall per
capita energy consumption, decreasing reliance on natural gas and oil, and increasing reliance on renewable
energy sources. Neither Appendix F of the CEQA Guidelines nor Public Resources Code Section 21 100(b)(3)
offer a numerical threshold of significance that might be used to evaluate the potential significance of energy
consumption of a project. Rather, the emphasis is on reducing "the wasteful, inefficient, and unnecessary
consumption of energy."
Construction activities would result in wasteful, inefficient, or unnecessary use of energy if construction
equipment is old or not well maintained, if equipment is left to idle when not in use, if travel routes are not
planned to minimize vehicle miles traveled, or if excess lighting or water is used during construction activities.
Energy usage during project operation would be considered "wasteful, inefficient, and unnecessary" if the
project were to violate federal, state, and/or local energy standards, including Title 24 of the California
Code of Regulations, inhibit pedestrian or bicycle mobility, inhibit access to transit, or inhibit feasible
opportunities to use alternative energy sources, such as solar energy, or otherwise inhibit the conservation of
energy.
5.2.6 ENVIRONMENTAL IMPACTS
IMPACT ENE-1: THE PROJECT WOULD NOT RESULT IN POTENTIALLY SIGNIFICANT ENVIRONMENTAL
IMPACT DUE TO WASTEFUL, INEFFICIENT, OR UNNECESSARY CONSUMPTION OF
ENERGY RESOURCES, DURING PROJECT CONSTRUCTION OR OPERATION.
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5.2
Less than Significant Impact.
As identified in Section 3.0, Project Description, the existing uses that were modeled consists of the Enderle
Center that is currently developed with 87,136 sq ft of commercial business uses, including 28,750 sq ft of
restaurant use, 39,960 sq ft of retail and service use, and 18,426 sq ft of office use. The analysis was
conducted using land use codes High Turnover (Sit Down Restaurant), Strip Mall, General Office Building, and
Parking Lot. Trip generation rates used in CalEEMod for the existing uses were based on the trip generation
rate of 7,058 ADT.
The analysis of the future buildout of the project site included the existing development, the buildout of 413
units, and the addition of the total remaining nonresidential use including a total of 67,837 sq ft of restaurant
use, 94,288 sq ft of retail and service use, and 43,477 sq ft of office use. The analysis was conducted using
land use codes Apartments Mid Rise, High Turnover (Sit Down Restaurant), Strip Mall, and General Office
Building assuming a total trip generation of 18,528 ADT. This analysis assumes that the proposed project
would not include any woodburning hearths or wood stoves. Where project -specific data were not available,
default assumptions (e.g., energy usage, water usage, and solid waste generation) from CalEEMod were
used to estimate Project impacts.
Potential future buildout of the Project would increase the demand for energy through day-to-day operations
and fuel consumption associated with Project construction. This section discusses energy use resulting from
buildout of the Project and evaluates whether the Project would result in the wasteful, inefficient, or
unnecessary consumption of energy resources or conflict with any applicable plans for renewable energy
and energy efficiency.
Construction
Construction activities associated with the construction of additional housing units and remaining commercial
buildout capacity that could occur with implementation of the project would be through the horizon year
2029, which would cause fuel consumption associated with construction activities. The primary source of
emissions is the operation of construction equipment. Before development can take place, a project will be
required to be analyzed for conformance with the General Plan, zoning requirements, and other applicable
local and State requirements; comply with the requirements of CEQA; and obtain all necessary clearances
and permits.
Construction activities would include grading, site preparation, building construction, architectural coating,
and paving activities. Construction activities require energy associated with the manufacture and
transportation of building materials, grading activities, and building construction. Construction activities also
typically require electricity to power construction -related equipment and do not involve the consumption of
natural gas.
Transportation energy represents the largest energy use during construction and would be from the transport
and use of construction equipment, delivery vehicles and haul trucks, and construction worker vehicles that
would use petroleum fuels (e.g., diesel fuel and/or gasoline). Therefore, the analysis of energy use during
construction focuses on fuel consumption. Construction trucks and vendor trucks hauling materials to and from
a site would be anticipated to use diesel fuel, whereas construction workers traveling to and from a site
would be anticipated to use gasoline -powered vehicles. Fuel consumption from transportation uses depends
on the type and number of trips, VMT, the fuel efficiency of the vehicles, and the travel mode.
Estimates of fuel consumption (diesel fuel and gasoline) from construction equipment, construction trucks, and
construction worker vehicles were based on default construction equipment assumptions and trip estimates
from CalEEMod and fuel efficiencies from EMFAC2021. Fuel consumption estimates are presented in Table
5.2-1. CalEEMod output sheets and detailed energy calculations are included in Appendix B.
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Table 5.2-1: Energy Consumption Estimates during Construction
Energy Type
Total Energy Consumption
Percentage of Increase Countywide
Diesel Fuel (total gallons)
117,690
0.07
Gasoline (total gallons)
148,345
0.01
Source: Compiled by LSA (March 2024).
As indicated in Table 5.2-1, development envisioned under the Project would consume approximately
117,690 gallons of diesel fuel and approximately 148,345 gallons of gasoline during construction. Based
on fuel consumption obtained from EMFAC2021, approximately 1.2 billion gallons of gasoline and
approximately 157.1 million gallons of diesel will be consumed from vehicle trips in Orange County in 2024.
Therefore, construction of future development as envisioned under the proposed project would increase the
annual construction generated fuel use in Orange County approximately by approximately 0.07 percent
for diesel fuel usage and by approximately 0.01 percent for gasoline fuel usage. As such, project
construction would have a negligible effect on local and regional energy supplies. Furthermore, impacts
related to energy use during construction would be temporary and relatively small in comparison to Orange
County's overall use of the State's available energy resources. No unusual project characteristics would
necessitate the use of construction equipment that would be less energy efficient than at comparable
construction sites in the region or the State. In addition, construction activities are not anticipated to result in
an inefficient use of energy as gasoline and diesel fuel would be supplied by construction contractors who
would conserve the use of their supplies to minimize their costs on the project. The project would not cause or
result in the need for additional energy facilities or an additional or expanded delivery system. For these
reasons, fuel consumption during construction would not be inefficient, wasteful, or unnecessary.
Operation
Operational activities associated with the 413 additional housing units and remaining commercial buildout
capacity consistent with the buildout envisioned as part of the Project would result in energy demand
associated with natural gas use, electricity consumption, and fuel used for vehicle trips. Energy consumption
was estimated for the proposed project using default energy intensities by land use type in CaIEEMod. In
addition, the proposed project would also result in energy usage associated with gasoline and diesel fuel
consumed by project -related vehicle trips. Trip generation rates for the proposed project were based on
the project's trip generation estimates. The existing uses generate approximately 7,058 ADT and the
proposed project would generate approximately 18,528 ADT. The amount of operational fuel use was
estimated using CARB's EMFAC2021 model, which provided projections for typical daily fuel usage in
Orange County. Electricity, natural gas, and fuel usage estimates associated with the Project are shown in
Table 5.2-2.
Table 5.2-2: Energy Consumption Estimates during Operation
Energy Type Annual Energy Consumption
Existing Uses
Electricity Consumption (kWh year)
1,984,211
Natural Gas Consumption (therms year)
40,171
Gasoline (gallons/year)
640,878
Diesel Fuel (gallons/year)
54,200
Full Buildout of the Project Site
Electricity Consumption (kWh year) 5,564,016
Natural Gas Consumption (therms/year) 140,666
Gasoline (gallons/year) 1,755,365
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Diesel Fuel (gallons/year) 148,455
Net New Energy Usage (Project Buildout — Existing Uses)
Electricity Consumption (kWh year)
3,579,805
Natural Gas Consumption (therms/year)
100,495
Gasoline (gallons/year)
1,1 14,487
Diesel Fuel (gallons/year)
94,255
Source: Compiled by LSA (March 2024).
Wh = kilowatt-hours
As shown in Table 5.2-2, the estimated potential increase in electricity demand associated with development
consistent with the proposed project is 3,579,805 kWh per year. Total electricity consumption in Orange
County in 2022 was 20,244 GWh (20,243,721,856 kWh). Therefore, operation of the proposed project
would increase the annual electricity consumption in Orange County by approximately 0.02 percent.
Additionally, as shown in Table 5.2-2, the estimated potential increase in natural gas demand associated
with development consistent with the proposed project is 100,495 therms per year. Total natural gas
consumption in Orange County in 2022 was 573 million therms (572,454,744 therms). Therefore, operation
of the proposed project would increase the annual natural gas consumption in Orange County by
approximately 0.02 percent.
Electrical and natural gas demand associated with future operations would not be considered inefficient,
wasteful, or unnecessary in comparison to other similar developments in the region. Furthermore, the
proposed project would not conflict with or obstruct a State or local plan for renewable energy or energy
efficiency. All future development would be required to adhere to all federal, State, and local requirements
for energy efficiency, including the latest Title 24 standards. Title 24 building energy efficiency standards
establish minimum efficiency standards related to various building features, including appliances, water and
space heating and cooling equipment, building insulation and roofing, and lighting, which would reduce
energy usage.
Construction of the 413 additional housing units and remaining commercial buildout capacity would also
result in energy usage associated with gasoline and diesel fuel consumed by project -related vehicle trips.
As shown in Table 5.2-2, the increase in fuel use associated with the vehicle trips generated by the proposed
project is estimated at approximately 1,1 14,487 gallons of gasoline and 94,255 gallons of diesel fuel per
year. Based on fuel consumption obtained from EMFAC2021, approximately 1.2 billion gallons of gasoline
and approximately 157.1 million gallons of diesel will be consumed from vehicle trips in Orange County in
2024. Therefore, vehicle trips associated with the proposed project would increase the annual fuel use in
Orange County by approximately 0.09 percent for gasoline fuel usage and approximately 0.06 percent
for diesel fuel usage. Fuel consumption associated with vehicle trips generated by project operations would
not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the
region.
Although future development, as envisioned under the proposed project would result in an increase in
demand for electricity, this increase would not require SCE to expand or construct infrastructure that could
cause substantial environmental impacts because each of the opportunity sites are already served by utilities
or directly adjacent to existing urban development. Similarly, expansion of natural gas infrastructure is not
anticipated due to cumulative development. Transportation energy use would also increase; however, this
transportation energy use would not represent a major amount of energy use when compared to the amount
of existing development and to the total number of vehicle trips and VMT throughout Orange County and
the region. As such, the buildout associated with the proposed project would not result in a potentially
significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources
during project construction or operation.
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IMPACT ENE-2: THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT A STATE OR LOCAL PLAN
FOR RENEWABLE ENERGY OR ENERGY EFFICIENCY.
Less than Significant Impact.
In 2002, the Legislature passed SB 1389, which required the CEC to develop an integrated energy plan
every 2 years for electricity, natural gas, and transportation fuels for the Integrated Energy Policy Report.
The plan calls for the State to assist in the transformation of the transportation system to improve air quality,
reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy
costs. To further this policy, the plan identifies several strategies, including assistance to public agencies and
fleet operators in implementing incentive programs for ZEVs and their infrastructure needs, and
encouragement of urban designs that reduce VMT and accommodate pedestrian and bicycle access.
The CEC's 2023 Integrated Energy Policy Report provides the results of the CEC's assessments of a variety of
energy issues facing California. As indicated above, energy usage on the project site during construction
would be temporary in nature and would be relatively small in comparison to the overall use in the County.
In addition, energy usage associated with operation of the proposed project would be relatively small in
comparison to the overall use in Orange County, and the State's available energy resources. Therefore,
energy impacts at the regional level would be negligible. Because California's energy conservation planning
actions are conducted at a regional level, and because the proposed project's total impact on regional
energy supplies would be minor, the proposed project would not conflict with or obstruct California's energy
conservation plans as described in the CEC's Integrated Energy Policy Report. Additionally, as demonstrated
above, the proposed project would not result in the inefficient, wasteful, and unnecessary consumption of
energy.
5.2.7 CUMULATIVE IMPACTS
The geographic context for analysis of cumulative impacts regarding energy includes past, present, and
future development within southern California because energy supplies (including electricity, natural gas,
and petroleum) are generated and distributed throughout the southern California region.
All development projects throughout the region would be required to comply with the energy efficiency
standards in the Title 24 requirements. Additionally, some of the developments could provide for additional
reductions in energy consumption by use of solar panels, sky lights, or other LEED-type energy efficiency
infrastructure. With implementation of the existing energy conservation regulations, cumulative electricity
and natural gas consumption would not be cumulatively wasteful, inefficient, or unnecessary.
Transportation energy use and gasoline demand would also increase; however, this transportation energy
use would not represent a major amount of energy use when compared to the amount of existing
development or to the total number of vehicle trips and VMT throughout Orange County and the region. For
these reasons, the consumption of petroleum would not occur in a wasteful, inefficient, or unnecessary manner
and would be less than cumulatively considerable.
5.2.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
State
California Energy Code (Code of Regulations, Title 24 Part 6).
• CalGreen Building Standards Code
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Plans, Programs, or Policies
These actions will be included in the Project's mitigation monitoring and reporting program (MMRP):
PPP E-1: CalGreen Compliance: The Project is required to comply with the CalGreen Building Code to
ensure efficient use of energy. CalGreen specifications are required to be incorporated into building plans
as a condition of building permit approval.
5.2.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements, Impacts E-1 and E-2 would be less than significant.
5.2.10 MITIGATION MEASURES
Impacts related to energy would be less than significant and no mitigation measures are required.
5.2.1 1 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts related to energy would be less than significant.
5.2.1 2 REFERENCES
California Energy Commission. (2023). 2023 Integrated Energy Policy Report (Docket Number: 23 IEPR 01).
California Public Utilities Commission. (2019). Renewables Portfolio Standard Program. Retrieved from
cpuc.ca.gov/rps (accessed January 2024)
LSA. (2024). Air Quality, Energy, and Greenhouse Gas Impact Report, Enderle Center.
Southern California Edison. (2022). 2022 Annual Report Edison International and Southern California Edison.
Retrieved from https://download.edison.com/406/files/20232/2022-eix-sce-annual-
report.pdf?Signature=U4RDvQwS5mPYIU4gXT%2BouS9xKgQ%3D&Expires=1710973701 &AW
SAccessKeyld=AKIAJX7XEOOELCYGIVDQ&versionld=bpeN_aiySep67UMc7RtP51 1 pg9M511 27
&response-content-disposition=attachment
Southern California Gas Company, et. al. (2022). 2022 California Gas Report. Retrieved from Southern
California Gas Company:
https://www.socalgas.com/sites/default/files/Joint_Utility_Biennial_Comprehensive_California_G
as_Report_2022.pdf
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5.3 Greenhouse Gas Emissions
5.3.1 INTRODUCTION
This section of the Draft EIR evaluates greenhouse gas (GHG) emissions associated with the Project and its
contribution to global climate change. Specifically, this section evaluates the extent to which GHG emissions
from the Project contribute to elevated levels of GHGs in the Earth's atmosphere and, consequently,
contribute to climate change. This section also addresses the Project's consistency with applicable plans,
policies, and public agency regulations adopted for the purpose of reducing the emissions of GHGs. The
analysis within this section is based on the following City documents and technical report in Appendix B:
• City of Tustin General Plan (including 2021-2029 Housing Element). Adopted November 2018 (updated
October 2022).
• Tustin City Code
• Connect SoCal 2024 Regional Transportation PlanlSustainable Communities Strategy (RTPISCS), adopted
April 2024.
• Enderle Center Project Air Quality, Energy, and Greenhouse Gas Report, LSA, March 2024, Appendix B.
5.3.2 REGULATORY SETTING
5.3.2.1 Federal Regulations
California Assembly Bill 1493— Pavley
In 2002, the California Legislature adopted AB 1493 requiring the adoption of regulations to reduce GHG
emissions in the transportation sector. In September 2004, pursuant to AB 1493, the CARB approved
regulations to reduce GHG emissions from new motor vehicles beginning with the 2009 model year (Pavley
Regulations). In September 2009, CARB adopted amendments to the Pavley Regulations to reduce GHG
from 2009 to 2016. CARB, EPA, and the U.S. Department of Transportation's National Highway Traffic and
Safety Administration (NHTSA) have coordinated efforts to develop fuel economy and GHG standards for
model 2017-2025 vehicles. The GHG standards are incorporated into the "Low Emission Vehicle" (LEV)
Regulations.
California Executive Order S-3-05 — Statewide Emission Reduction Targets
Executive Order S-3-05 was signed by Governor Arnold Schwarzenegger in June 2005. Executive Order
S-3-05 establishes statewide emission reduction targets through the year 2050:
• By 2010, reduce GHG emissions to 2000 levels;
• By 2020, reduce GHG emissions to 1990 levels; and
• By 2050, reduce GHG emissions to 80 percent below 1990 levels.
Assembly Bill 1279
Assembly Bill (AB) 1 279 requires the state to achieve net zero greenhouse gas emissions (GHG) as soon as
possible, but no later than 2045, and to achieve and maintain net negative greenhouse gas emissions
thereafter. The bill also requires California to reduce statewide GHG emissions by 85 percent compared to
1990 levels and directs the California Air Resources Board (CARB) to work with relevant state agencies to
achieve these goals.
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California Assembly Bill 32 (AB 32), Global Warming Solutions Act of 2006 (Chapter 488, Statutes of
2006)
In 2006, the Legislature passed the California Global Warming Solutions Act of 2006 [Assembly Bill 32 (AB
32)], which created a comprehensive, multi -year program to reduce greenhouse gas (GHG) emissions in
California. AB 32 required the California Air Resources Board (CARB or Board) to develop a Scoping Plan
that describes the approach California will take to reduce GHGs to achieve the goal of reducing emissions
to 1990 levels by 2020. The Scoping Plan was first approved by the Board in 2008 and must be updated
at least every five years. Since 2008, there have been two updates to the Scoping Plan. Each of the Scoping
Plans has included a suite of policies to help the State achieve its GHG targets, in large part by leveraging
existing programs whose primary goal is to reduce harmful air pollution. The 2017 Scoping Plan identifies
how the State can reach the 2030 climate target to reduce greenhouse gas (GHG) emissions by 40 percent
from 1990 levels, and substantially advance toward the 2050 climate goal to reduce GHG emissions by 80
percent below 1990 levels.
The AB 32 Scoping Plan also anticipates that local government actions will result in reduced GHG emissions
because local governments have the primary authority to plan, zone, approve, and permit development to
accommodate population growth and the changing needs of their jurisdictions. The Scoping Plan also relies
on the requirements of Senate Bill 375 (discussed below) to align local land use and transportation planning
for achieving GHG reductions.
The Scoping Plan must be updated every five years to evaluate AB 32 policies and ensure that California
is on track to achieve the 2020 GHG reduction goal. In 2014, CARB released the First Update to the Scoping
Plan, which builds upon the Initial Scoping Plan with new strategies and recommendations. The First Update
identifies opportunities to leverage existing and new funds to further drive GHG emission reductions through
strategic planning and targeted low carbon investments. This update defines CARB's climate change priorities
for the next five years and sets the groundwork to reach long-term goals set forth in Executive Order S-3-
05. The update highlights California's progress toward meeting the "near -term" 2020 GHG emission
reduction goals in the original 2008 Scoping Plan. It also evaluates how to align the state's "longer -term"
GHG reduction strategies with other state policy priorities for water, waste, natural resources, clean energy,
transportation, and land use.
In 2017, CARB released the proposed Second Update to the Scoping Plan, which identifies the State's post-
2020 reduction strategy. The Second Update would reflect the 2030 target of a 40 percent reduction below
1990 levels, set by Executive Order B-30-15 and codified by SB 32.
On December 15, 2022, CARB adopted the 2022 Scoping Plan. The 2022 Scoping Plan builds on the 2017
Scoping Plan as well as the requirements set forth by AB 1279, which directs the state to become carbon
neutral no later than 2045. To achieve this statutory objective, the 2022 Scoping Plan lays out how California
can reduce GHG emissions by 85% below 1990 levels and achieve carbon neutrality by 2045. The Scoping
Plan scenario to do this is to "deploy a broad portfolio of existing and emerging fossil fuel alternatives and
clean technologies, and align with statutes, Executive Orders, Board direction, and direction from the
governor." The 2022 Scoping Plan sets one of the most aggressive approaches to reach carbon neutrality
in the world. Unlike the 2017 Scoping Plan, CARB advocates compliance with a local GHG reduction strategy
or climate action plan (CAP) consistent with CEQA Guidelines section 151 83.5.
Senate Bill 375 (Chapter 728, Statutes of 2008)
In August 2008, the Legislature passed, and on September 30, 2008, Governor Schwarzenegger signed SB
375, which addresses GHG emissions associated with the transportation sector through regional
transportation and sustainability plans. Regional GHG reduction targets for the automobile and light -truck
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sector for 2020 and 2035, as determined by CARB, are required to consider the emission reductions
associated with vehicle emission standards (see SB 1493), the composition of fuels (see Executive Order S-
1-07), and other CARB-approved measures to reduce GHG emissions. Regional metropolitan planning
organizations (MPOs) will be responsible for preparing a Sustainable Communities Strategy (SCS) within
their Regional Transportation Plan (RTP). The goal of the SCS is to establish a development plan for the
region, which, after considering transportation measures and policies, will achieve, if feasible, the GHG
reduction targets. If an SCS is unable to achieve the GHG reduction target, an MPO must prepare an
Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through
alternative development patterns, infrastructure, or additional transportation measures or policies. SB 375
provides incentives for streamlining CEQA requirements by substantially reducing the requirements for
"transit priority projects," as specified in SB 375, and eliminating the analysis of the impacts of certain
residential projects on global warming and the growth -inducing impacts of those projects when the projects
are consistent with the SCS or Alternative Planning Strategy. On September 23, 2010, CARB adopted the
SB 375 targets for the regional MPOs.
Executive Order B-30-15 - 2030 Statewide Emission Reduction Target
Executive Order B-30-15 was signed by Governor Jerry Brown on April 29, 2015, establishing an interim
statewide GHG reduction target of 40 percent below 1990 levels by 2030, which is necessary to guide
regulatory policy and investments in California in the midterm, and put California on the most cost-effective
path for long-term emission reductions. Under this Executive Order, all state agencies with jurisdiction over
sources of GHG emissions are required to continue to develop and implement emissions reduction programs
to reach the state's 2050 target and attain a level of emissions necessary to avoid dangerous climate change.
According to the Governor's Office, this Executive Order is in line with the scientifically established levels
needed in the United States to limit global warming below 2°C - the warming threshold at which scientists
say there will likely be major climate disruptions such as super droughts and rising sea levels.
Senate Bill 32 (Chapter 249, Statutes of 2016)
Senate Bill 32 was signed on September 8, 2016, by Governor Jerry Brown. SB 32 requires the state to
reduce statewide GHG emissions to 40 percent below 1990 levels by 2030, a reduction target that was
first introduced in Executive Order B-30-15. The new legislation builds upon the AB 32 goal of 1990 levels
by 2020 and provides an intermediate goal to achieving S-3-05, which sets a statewide GHG reduction
target of 80 percent below 1990 levels by 2050. A related bill that was also approved in 2016, AB 197
(Chapter 250, Statutes of 2016) creates a legislative committee to oversee regulators to ensure that ARB is
not only responsive to the Governor, but also the Legislature.
AB 398 - Extension of Cap and Trade Program to 2030 (Chapter 617, Statutes of 2017)
AB 398was signed by Governor Brown on July 25, 2017, and became effective immediately as urgency
legislation. AB 398, among other things, extended the cap and trade program through 2030.
Senate Bill 97 (Chapter 185, Statutes of 2007)
SB 97 (Health and Safety Code Section 21083.5) was adopted in 2007 and required the Office of Planning
and Research to prepare amendments to the CEQA Guidelines for the mitigation of GHG impacts. The
amendments became effective on March 18, 2010. The CEQA Amendments provide guidance to public
agencies regarding the analysis and mitigation of the effects of GHG emissions in CEQA documents. A new
section, CEQA Guidelines Section 15064.4, was added to assist agencies in determining the significance of
GHG emissions. The CEQA Section gives discretion to the lead agency whether to: (1) use a model of
methodology to quantify GHG emissions resulting from a project, and which model or methodology to use;
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or (2) rely on a qualitative analysis or performance -based standards. CEQA does not provide guidance to
determine whether the project's estimated GHG emissions are significant or cumulatively considerable.
Also amended were CEQA Guidelines Sections 15126.4 and 15130, which address mitigation measures
and cumulative impacts respectively. However, GHG mitigation measures are referenced in general terms,
and no specific measures are identified. Additionally, the revision to the cumulative impact discussion
requirement (Section 151 30) simply directs agencies to analyze GHG emissions in an EIR when a project's
incremental contribution of emissions may be cumulatively considerable, however it does not answer the
question of when emissions are cumulatively considerable.
The 2018 amendments to the CEQA Guidelines provided expanded guidance to lead agencies in evaluating
GHG impacts, as outlined in Sections 15064.4 and 15064.7. A lead agency has discretion to select the
model or methodology it considers most appropriate to enable decision makers to evaluate a project's
incremental contribution to climate change, provided that the model or methodology is supported by
substantial evidence.
Section 15183.5 permits programmatic GHG analysis and later project -specific tiering, as well as the
preparation of Greenhouse Gas Reduction Plans. Compliance with such plans can support a determination
that a project's cumulative effect is not cumulatively considerable, according to Section 15183.5(b).
Title 24 Energy Efficiency Standards and California Green Building Standards
California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code (CalGreen) is updated
every three years. The most recent update was the 2022 California Green Building Code Standards that
became effective on January 1, 2023.
The 2022 Energy Code encourages efficient electric heat pumps, establishes electric -ready requirements for
new homes, expands solar photovoltaic and battery storage standards, and strengthens ventilation
standards, among other requirements. The California Energy Commission anticipates that the 2022 Energy
Code will provide $1.5 billion in consumer benefits and reduce GHG emissions by 10 million metric tons.
The 2022 CALGreen standards that reduce GHG emissions and are applicable to the Project include, but
are not limited to, the following:
• Short-term bicycle parking. If the new project or an additional alteration is anticipated to generate
visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors' entrance,
readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with
a minimum of one two -bike capacity rack (5.106.4.1.1).
• Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenant -occupants,
provide secure bicycle parking for 5% of the tenant -occupant vehicular parking spaces with a minimum
of one bicycle parking facility (5.106.4.1.2).
• Designated parking for clean air vehicles. In new projects or additions to alterations that add 10 or
more vehicular parking spaces, provide designated parking for any combination of low -emitting, fuel -
efficient and carpool van pool vehicles as shown in Table 5.106.5.2 (5.106.5.2).
• EV charging stations. New construction shall facilitate the future installation of EV supply equipment. The
compliance requires empty raceways for future conduit and documentation that the electrical system has
adequate capacity for the future load. The number of spaces to be provided for is contained in Table
5.106. 5.3.3 (5.106.5.3). Additionally, Table 5.106.5.4.1 specifies requirements for the installation of
raceway conduit and panel power requirements for medium- and heavy-duty electric vehicle supply
equipment for warehouses, grocery stores, and retail stores.
• Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight,
uplight and glare ratings per Table 5.106.8 (5.106.8).
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• Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the
nonhazardous construction and demolition waste in accordance with Section 5.408.1.1. 5.405.1.2, or
5.408.1.3; or meet a local construction and demolition waste management ordinance, whichever is more
stringent (5.408.1 ).
• Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation and
soils resulting primarily from land clearing shall be reused or recycled. For a phased project, such
material may be stockpiled on site until the storage site is developed (5.408.3).
• Recycling by Occupants. Provide readily accessible areas that serve the entire building and are
identified for the depositing, storage, and collection of non -hazardous materials for recycling, including
(at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a
lawfully enacted local recycling ordinance, if more restrictive (5.410.1).
• Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings
(faucets and showerheads) shall comply with the following:
o Water Closets. The effective flush volume of all water closets shall not exceed 1.28 gallons per flush
(5.303.3.1)
o Urinals. The effective flush volume of wall -mounted urinals shall not exceed 0.125 gallons per flush
(5.303.3.2.1). The effective flush volume of floor- mounted or other urinals shall not exceed 0.5
gallons per flush (5.303.3.2.2).
o Showerheads. Single showerheads shall have a minimum flow rate of not more than 1.8 gallons per
minute and 80 psi (5.303.3.3.1). When a shower is served by more than one showerhead, the
combined flow rate of all showerheads and/or other shower outlets controlled by a single valve
shall not exceed 1.8 gallons per minute at 80 psi (5.303.3.3.2).
o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not more
than 0.5 gallons per minute at 60 psi (5.303.3.4.1). Kitchen faucets shall have a maximum flow rate
of not more than 1.8 gallons per minute of 60 psi (5.303.3.4.2). Wash fountains shall have a
maximum flow rate of not more than 1.8 gallons per minute (5.303.3.4.3). Metering faucets shall
not deliver more than 0.20 gallons per cycle (5.303.3.4.4). Metering faucets for wash fountains shall
have a maximum flow rate not more than 0.20 gallons per cycle (5.303.3.4.5).
• Outdoor potable water uses in landscaped areas. Nonresidential developments shall comply with a local
water efficient landscape ordinance or the current California Department of Water Resources' Model
Water Efficient Landscape Ordinance (MWELO), whichever is more stringent (5.304.1).
• Water meters. Separate submeters or metering devices shall be installed for new buildings or additions
in excess of 50,000 SF or for excess consumption where any tenant within a new building or within an
addition that is project to consume more than 1,000 gallons per day (GPD) (5.303.1.1 and 5.303.1.2).
• Outdoor water uses in rehabilitated landscape projects equal or greater than 2,500 SF. Rehabilitated
landscape projects with an aggregate landscape area equal to or greater than 2,500 SF requiring a
building or landscape permit (5.304.3).
• Commissioning. For new buildings 10,000 SF and over, building commissioning shall be included in the
design and construction processes of the building project to verify that the building systems and
components meet the owner's or owner representative's project requirements (5.410.2).
The 2022 CalGreen Building Standards Code has been adopted by the Tustin City Code in Section 8100.
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5.3.2.2 Local and Regional Regulations
City of Tustin General Plan
The City of Tustin addresses issues relevant to GHG emissions in the Conservation, Open Space, and
Recreation Element of the City of Tustin General Plan. The Conservation, Open Space, and Recreation
Element contains policies that work to reduce GHG emissions. The following policies are applicable to the
Project:
Goal 1: Reduce air pollution through proper land use, transportation and energy use planning.
Policy 1.1: Cooperate with the South Coast Air Quality Management District and the Southern
California Association of Governments in their effort to implement provisions of the region's
Air Quality Management Plan, as amended.
Policy 1.2: Design safe and efficient vehicular access to commercial land uses from arterial streets to
insure efficient vehicular ingress and egress.
Policy 1.3: Locate multiple family developments close to commercial areas to encourage pedestrian
rather than vehicular travel.
Policy 1.7: Create the maximum possible opportunities for bicycles as an alternative transportation
mode and recreational use.
Goal 2: Improve air quality by influencing transportation choices of mode, time of day, or
whether to travel and to establish a jobs/housing balance.
Policy 2.1: Reduce vehicle trips through incentives, regulations and/or Transportation Demand
Management (TDM) programs.
Policy 2.2: Reduce total vehicle miles traveled (VMT) through incentives, regulations and/or
Transportation Demand Management.
Policy 2.6: Encourage non -motorized transportation through the provision of bicycle and pedestrian
pathways.
Policy 2.7: Encourage employer rideshare and transit incentives programs by local businesses.
Policy 2.8: Manage non-residential parking supply to discourage auto use, while ensuring that economic
development goals will not be sacrificed.
5.3.3 ENVIRONMENTAL SETTING
Gases that trap heat in the atmosphere are called GHGs. The major concern with GHGs is that increases in
their concentrations are contributing to global climate change. Global climate change is a change in the
average weather on Earth that can be measured by wind patterns, storms, precipitation, and temperature.
Although there is disagreement as to the rate of global climate change and the extent of the impacts
attributable to human activities, most in the scientific community agree that there is a direct link between
increased emissions of GHGs and long-term global temperature increases.
The principal GHGs are carbon dioxide (CO2), methane (CH4), nitrous oxide (N20), sulfur hexafluoride (SF6),
perfluorocarbons (PFCs), and hydrofluorocarbons (HFCs). Because different GHGs have different warming
potential, and CO2 is the most common reference gas for climate change, GHG emissions are often quantified
and reported as CO2 equivalents (CO2e). For example, SF6 is a GHG commonly used in the utility industry
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as an insulating gas in circuit breakers and other electronic equipment. SF6, while comprising a small fraction
of the total GHGs emitted annually world-wide, is a much more potent GHG, with 22,800 times the global
warming potential as CO2. Therefore, an emission of one metric ton (MT) of SF6 could be reported as an
emission of 22,800 MT of CO2e. Large emission sources are reported in million metric tons (MMT) of CO2e.
The principal GHGs are described below, along with their global warming potential.
Carbon dioxide: Carbon dioxide (CO2) is an odorless, colorless, natural GHG. Carbon dioxide's global
warming potential is 1. Natural sources include decomposition of dead organic matter; respiration of
bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing. Anthropogenic
(manmade) sources are from burning coal, oil, natural gas, and wood.
Methane: Methane (CH4) is a flammable gas and is the main component of natural gas. It has a lifetime of
12 years, and its global warming potential is 28. Methane is extracted from geological deposits (natural
gas fields). Other sources are landfills, fermentation of manure, and decay of organic matter.
Nitrous oxide: Nitrous oxide (N2O) (laughing gas) is a colorless GHG that has a lifetime of 121 years, and
its global warming potential is 265. Sources include microbial processes in soil and water, fuel combustion,
and industrial processes.
Sulfur hexafluoride: Sulfur hexafluoride (SF6) is an inorganic, odorless, colorless, and nontoxic,
nonflammable gas that has a lifetime of 3,200 years and a high global warming potential of 23,500. This
gas is manmade and used for insulation in electric power transmission equipment, in the magnesium industry,
in semiconductor manufacturing, and as a tracer gas.
Perfluorocarbons: Perfluorocarbons (PFCs) have stable molecular structures and only break down by
ultraviolet rays about 60 kilometers above Earth's surface. Because of this, they have long lifetimes, between
10,000 and 50,000 years. Their global warming potential ranges from 7,000 to 11,000. Two main sources
of perfluorocarbons are primary aluminum production and semiconductor manufacturing.
Hydrofluorocarbons: Hydrofluorocarbons (HFCs) are a group of GHGs containing carbon, chlorine, and at
least one hydrogen atom. Their global warming potential ranges from 100 to 12,000. Hydrofluorocarbons
are synthetic manmade chemicals used as a substitute for chlorofluorocarbons in applications such as
automobile air conditioners and refrigerants.
Some of the potential effects in California of global warming may include loss in snow pack, sea level rise,
more extreme heat days per year, more high ozone days, more forest fires, and more drought years.
Globally, climate change has the potential to impact numerous environmental resources through potential,
though uncertain, impacts related to future air temperatures and precipitation patterns. The projected effects
of global warming on weather and climate are likely to vary regionally, but are expected to include the
following direct effects:
• Higher maximum temperatures and more hot days over nearly all land areas;
• Higher minimum temperatures, fewer cold days and frost days over nearly all land areas;
• Reduced diurnal temperature range over most land areas;
• Increase of heat index over land areas; and
• More intense precipitation events.
There are also many secondary effects that are projected to result from global warming, including global
rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity.
While the possible outcomes and the feedback mechanisms involved are not fully understood and much
research remains to be done, the potential for substantial environmental, social, and economic consequences
over the long term may be great.
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GHGs are produced by both direct and indirect emissions sources. Direct emissions include consumption of
natural gas, heating and cooling of buildings, landscaping activities and other equipment used directly by
land uses. Indirect emissions include the consumption of fossil fuels for vehicle trips, electricity generation,
water usage, and solid waste disposal.
Global Emissions
Worldwide emissions of GHGs in 2020 totaled 22.9 billion metric tons (MT) of CO2e. Global estimates are
based on country inventories developed as part of the programs of the United Nations Framework
Convention on Climate Change.
United States Emissions
In 2021, the year for which the most recent data are available, the United States emitted about 5,586.0
million metric tons of CO2e (MMT CO2e) after accounting for sequestration from the land sector. Overall, net
emissions increased 6.4 percent from 2020 to 2021, and decreased 16.6 percent from 2005 levels. The
increase in total GHG emissions was driven by an increase in CO2 emissions from fossil fuel combustion.
In 2021, CO2 emissions from fossil fuel combustion increased by 7 percent relative to the previous year. This
increase in fossil fuel consumption emissions was due primarily to economic activity rebounding after the
height of the COVID-19 pandemic. Of the five major sectors —residential and commercial, agricultural,
industry, transportation, and electricity generation —transportation accounted for the highest amount of
GHG emissions in 2021 (approximately 28 percent), with electricity generation second at 25 percent and
emissions from industry third at 23 percent (U.S. Environmental Protection Agency, 2023).
State of California Emissions
The State emitted approximately 381.3 MMT CO2e emissions in 2021, 12.1 MMT CO2e higher than 2020
levels and 49.7 MMT CO2e below the 2020 GHG limit of 431 MMT CO2e. CARB estimates that
transportation was the source of approximately 38 percent of the State's GHG emissions in 2021. The next
largest sectors included industrial sources at approximately 19 percent, and electricity generation at
16 percent. The remaining sources of GHG emissions were commercial and residential activities at 10
percent, agriculture at 8 percent, high Global Warming Potentials (GWP) such as refrigerants at 6 percent,
and waste at 2 percent.
5.3.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
GHG-1 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant
impact on the environment.
GHG-2 Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the
emissions of greenhouse gases.
CEQA Guidelines Section 15064.4 provides discretion to the lead agency whether to: (1) use a model of
methodology to quantify GHG emissions resulting from a project, and which model or methodology to use;
or (2) rely on a qualitative analysis or performance -based standards. In addition, CEQA does not provide
guidance to determine whether the project's estimated GHG emissions are significant, but recommends that
lead agencies consider several factors that may be used in the determination of significance of project
related GHG emissions, including:
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• The extent to which the project may increase or reduce GHG emissions as compared to the existing
environmental setting.
• Whether the project emissions exceed a threshold of significance that the lead agency determines
applies to the project.
• The extent to which the project complies with regulations or requirements adopted to implement a
statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
CEQA Guidelines Section 15130(f) describes that the effects of GHG emissions are by their very nature
cumulative and should be analyzed in the context of CEQA's requirements for cumulative impact analysis.
Additionally, CEQA Guidelines Section 15064(h)3 states that a project's incremental contribution to a
cumulative impact can be found not cumulatively considerable if the project would comply with an approved
plan or mitigation program that provides requirements to avoid or lesson the cumulative problem.
To provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA
documents, SCAQMD convened a GHG CEQA Significance Threshold Working Group (Working Group).
Based on the last Working Group meeting held in September 2010 (Meeting No. 15), SCAQMD proposed
to adopt a tiered approach for evaluating GHG emissions for development projects where SCAQMD is not
the lead agency:
• Tier 1. Exemptions: If a project is exempt from CEQA, project -level and cumulative GHG emissions are
less than significant.
• Tier 2. Consistency with a locally adopted GHG Reduction Plan: If the project complies with a GHG
emissions reduction plan or mitigation program that avoids or substantially reduces GHG emissions in
the project's geographic area (i.e., city or county), project -level and cumulative GHG emissions are less
than significant.
• Tier 3. Numerical Screening Threshold: If GHG emissions are less than the numerical screening -level
threshold, project -level and cumulative GHG emissions are less than significant.
For projects that are not exempt or where no qualifying GHG reduction plans are directly applicable,
SCAQMD requires an assessment of GHG emissions. The 10,000 MT of CO2e per year (MT CO2e/yr)
threshold for industrial uses would be recommended for use by all lead agencies. Under Option 1,
separate screening thresholds are proposed for residential projects (3,500 MT CO2e/yr), commercial
projects (1,400 MT CO2e/yr), and mixed -use projects (3,000 MT CO2e/yr). Under Option 2, a single
numerical screening -level threshold of 3,000 MT CO2e/yr would be used for all non -industrial projects.
• Tier 4. Performance Standards: If emissions exceed the numerical screening threshold, a more detailed
review of the project's GHG emissions is warranted. SCAQMD has proposed an efficiency target for
projects that exceed the bright -line threshold. The current recommended approach is per capita
efficiency targets. SCAQMD is not recommending use of a percent emissions reduction target; Instead,
SCAQMD proposes a 2020 efficiency target of 4.8 MT CO2e/yr per service population (for project -
level analyses and 6.6 MT CO2e/yr per service population for plan -level projects (e.g., program -level
projects such as general plans). The GHG efficiency metric divides annualized GHG emissions by the
service population, which is the sum of residents and employees, per the following equation:
Rate of Emission: GHG Emissions (MT CO2e/yr) = Service Population
The efficiency evaluation consists of comparing the project's efficiency metric to efficiency targets.
Efficiency targets represent the maximum quantity of emissions each resident and employee in the State
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of California could emit in various years based on emissions levels necessary to achieve the statewide
GHG emissions reduction goals. A project that results in a lower rate of emissions would be more efficient
than a project with a higher rate of emissions, based on the same service population. The metric considers
GHG reduction measures integrated into a project's design and operation (or through mitigation). The
per capita efficiency targets are based on the AB 32 GHG reduction target and 2020 GHG emissions
inventory prepared for the CARB's 2008 Scoping Plan.
Relative to the 2035 target date, this target date was selected to be consistent with the GHG reduction
target date of SB 375. Overall, GHG reductions by the SB 375 target date of 2035 would be
approximately 40 percent. This 40 percent reduction was applied to the 2020 targets, resulting in an
efficiency threshold for plans of 4.1 MT CO2e/yr and an efficiency threshold at the project level of 3.0
MT CO2e/yr.
For the purpose of this analysis, the Project will first be compared to the SCAQMD screening -level Tier 3
Numerical Screening Threshold of 3,000 MT CO2e/yr for all land use type projects. If it is determined that
the Project is estimated to exceed this numerical threshold, it will then be compared to the SCAQMD-
recommended 2035 efficiency -based plan -level threshold of 4.1 MT CO2e/yr per service population. The
plan -level threshold is appropriate for use in this analysis since this analysis evaluates buildout at The Enderle
Center at the plan level, including the 413 units allowed under the Housing Overlay Zone and remaining
commercial buildout capacity associated with the proposed Project. In addition, the Project is also evaluated
for compliance with the 2022 Scoping Plan and the 2024-2050 RTP/SCS.
5.3.5 METHODOLOGY
The California Emissions Estimator Model (CaIEEMod) v2022.1.1.20 has been used to determine construction
and operational GHG emissions for buildout of the Project, based on the maximum development assumptions
outlined in Section 3.0, Project Description. The purpose of this model is to calculate construction -source and
operational -source GHG emissions from direct and indirect sources; and quantify applicable air quality and
GHG reductions achieved from measures incorporated into the Project to reduce or minimize GHG emissions.
For construction phase Project emissions, GHGs are quantified and, per SCAQMD methodology, the total
GHG emissions for construction activities are divided by 30-years, and then added to the annual operational
phase of GHG emissions.
In addition, CEQA requires the lead agency to consider the extent to which the Project complies with
regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or
mitigation of GHG emissions. Therefore, this section addresses whether the Project complies with various
programs and measures designed to reduce GHG emissions. There is no Statewide program or regional
program or plan that has been adopted with which all new development must comply; thus, this analysis has
identified the regulations most relevant to the City of Tustin and the Project.
Recognizing that the field of global climate change analysis is rapidly evolving, the approaches advocated
most recently indicate that for determining a project's contribution to GHG emissions, lead agencies should
calculate, or estimate, emissions from vehicular traffic, energy consumption, water conveyance and treatment,
waste generation, construction activities, and any other significant source of emissions within the Project area.
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5.3.6 ENVIRONMENTAL IMPACTS
IMPACT GHG-1: THE PROJECT WOULD GENERATE GREENHOUSE GAS EMISSIONS, EITHER DIRECTLY
OR INDIRECTLY, THAT MAY HAVE A SIGNIFICANT IMPACT ON THE ENVIRONMENT.
An Air Quality, Energy, and Greenhouse Gas Impact Report was prepared for the Project (LSA, 2024). The
analysis and conclusions are incorporated into the discussion below. The full report can be found in Appendix
B.
Significant and Unavoidable.
As identified in the Project Description, the City's 2021-2029 Housing Element identifies several adequate
sites that are able to accommodate the development for the City to meet its estimated housing growth needs
identified in the SCAG's RHNA allocation. Of the Housing Element inventory sites, The Enderle Center (the
Project site) was identified as having capacity for 413 housing units on seven acres of the existing Center's
parking lots (equating to 59 dwelling units per acre). Additionally, the Project site has additional existing
nonresidential capacity. The Project site is assumed to be developed with 205,610 SF of nonresidential uses.
The Enderle Center is currently developed with 87,136 SF of commercial businesses, including 28,750 SF of
restaurant use, 39,960 SF of retail and service use, and 18,426 SF of office use. Therefore, the total
remaining nonresidential use assumed for future buildout of the Project site is 118,474 SF. The analysis below
considers potential future buildout of 413 residential units (high density multifamily) and the remaining
commercial buildout capacity.
Construction
Construction activities associated with the construction of additional housing units and remaining commercial
buildout capacity would cause short-term GHG emissions. Construction activities with the proposed project
would produce combustion emissions from various sources. During construction, GHGs would be emitted
through the operation of construction equipment and from worker and builder supply vendor vehicles, each
of which typically use fossil -based fuels to operate. The combustion of fossil -based fuels creates GHGs such
as CO2, CHa, and N20. Furthermore, CHa is emitted during the fueling of heavy equipment. Exhaust emissions
from on -site construction activities would vary daily as construction activity levels change.
As indicated above, the SCAQMD does not have an adopted threshold of significance for construction -
related GHG emissions. However, lead agencies are required to quantify and disclose GHG emissions that
would occur during construction. The SCAQMD then requires the construction GHG emissions to be amortized
over the life of the project, defined by the SCAQMD as 30 years, added to the operational emissions, and
compared to the applicable interim GHG significance threshold tier.
As discussed under Section 5.1, Air Quality, and shown in Table 5.1-6, information regarding a specific
development project is not yet known; however, for the purposes of this analysis, future development of the
additional 413 units and remaining commercial buildout capacity associated with the Project could occur
anytime between October 2024 and October 2029. Therefore, to be conservative, this analysis assumes a
Project construction schedule based on a start date of October 2024 and a construction period of two years
(construction ending April 2026). Using CaIEEMod, it is estimated that development envisioned under the
Project would generate approximately 1,522.9 MT CO2e during construction of the project. When
annualized over the 30-year life of the project, annual emissions would be 50.8 MT CO2e.
Operation
Operational activities associated with the additional housing units and remaining commercial buildout
capacity consistent with the buildout envisioned as part of the Project would result in long-term GHG emissions
associated with mobile sources (e.g., vehicle trips), area sources (e.g., maintenance activities and
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landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling
and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). Mobile -
source GHG emissions would include project -generated vehicle trips to and from the project. Area -source
emissions would be associated with activities such as landscaping and maintenance on the project site. Energy
source emissions would be generated at off -site utility providers because of the increased electricity demand
generated by the project. Waste source emissions generated by the Project include energy generated by
land filling and other methods of disposal related to transporting and managing project -generated waste.
In addition, water source emissions associated with the Project are generated by water supply and
conveyance, water treatment, water distribution, and wastewater treatment.
Following guidance from the SCAQMD, GHG emissions were estimated using CaIEEMod. Table 5.3-1 shows
the calculated GHG emissions for development consistent with the Project.
As discussed above, according to SCAQMD, a project would have less than significant GHG emissions if it
would result in operational -related GHG emissions of less than 3,000 MT CO2e/yr. Based on the analysis
results, full buildout of the development envisioned under the Project would result in a net increase of 12,804
MT CO2e/yr, which would exceed the SCAQMD threshold of 3,000 MT CO2e/yr. Therefore, consistent with
the SCAQMD's interim guidance, the following discussion compares the proposed Project to the efficiency -
based threshold.
The development of 413 housing units would result in approximately 1,189 additional residents based on
the estimated 2.88 persons per household in Tustin. In addition, the proposed Project would include an
additional 39,087 sq ft of restaurant use, 54,328 sq ft of retail and service use, and 25,051 sq ft of office
use. Future development, as envisioned under the proposed Project, would result in 365 new employees. The
total service population (residents plus employees) would be 1,554 persons. The proposed project would
result in per service population emissions of 8.2 metric tons of CO2 per year per service population (MT
CO2e/yr/SP), which would exceed the SCAQMD's plan -level screening threshold of 4.1 MT CO2e/yr/SP.
Therefore, operation of the proposed Project would generate significant GHG emissions that would have a
significant effect on the environment.
Table 5.3-1: Greenhouse Gas Emissions (MT/yr)
Emissions Source I Operational Emissions (MT/yr)
CO2 I CH4 I N20 I CO2e
Existing Uses
Existing Uses Mobile Sources
6,169.3
1.8
691.7
0.3 0.3
<0.1 <0.1
<0.1 <0.1
6,271.5
1.8
694.2
Existing Uses Area Sources
Existing Uses Energy Sources
Existing Uses Water Sources
29.3
0.5 <0.1
45.0
Existing Uses Waste Sources
35.8
3.6 0.0
125.3
Total Existing Uses Emissions
6,927.9
4.4 0.3
7,137.8
Full Buildout of the Project Site
Project Buildout Mobile Sources
16,874.0
100.0
2,088.8
99.6
0.9 0.7
<0.1 <0.1
0.1 <0.1
1.7 <0.1
17,151.0
100.2
2,096.0
152.9
Project Buildout Area Sources
Project Buildout Energy Sources
Project Buildout Water Sources
Project Buildout Waste Sources
1 1 1 .7
1 1 .2 <0.1
390.9
Project Buildout Emissions
19,274.1
13.9 0.7
19,891.0
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Amortized Construction Emissions
50.8
Total Project Buildout Annual Emissions
19,941.8
Net New Emissions (Project Buildout — Existing Uses)
12,804.0
SCAQMD Threshold
3,000
Exceed?
Yes
Per Service Population Emissions
8.2
SCAQMD Efficiency Target Threshold
4.1
Exceed?
Yes
Source: Compiled by LSA (March 2024).
CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent MT/yr = metric tons per year
N20 = nitrous oxide
SCAQMD = South Coast Air Quality Management District
However, as identified above, before development can occur, once a specific development project is
proposed, it would be required to be analyzed for conformance with the General Plan, zoning requirements,
and other applicable local and State requirements; comply with the requirements of CEQA; and obtain all
necessary clearances and permits. As demonstrated above, the likely scale and extent of build out associated
with future projects is unknown; however, this analysis assumes the most conservative estimate that would
likely exceed the SCAQMD thresholds. As such, implementation of Mitigation Measure GHG-1 would require
a project -specific assessment of potential GHG impacts and implementation of feasible mitigation measures
to reduce GHG emissions for future projects allowed under the proposed Project. While Mitigation Measure
GHG-1 would serve to reduce GHG emissions associated with buildout of the Project, GHG emission impacts
would remain significant and unavoidable because compliance with future efficiency targets cannot be
assured and not enough information is known regarding future projects to recommend further mitigation.
IMPACT GHG-2: THE PROJECT WOULD CONFLICT WITH AN APPLICABLE PLAN, POLICY OR
REGULATION ADOPTED FOR THE PURPOSE OF REDUCING THE EMISSIONS OF
GREENHOUSE GASES.
Significant and Unavoidable.
An evaluation of the Project's consistency with the 2022 Scoping Plan and the 2024-2005 RTP/SCS is
provided below.
2022 Scoping Plan
The following discussion evaluates the Project according to the goals of the 2022 Scoping Plan, EO B-30-
15, AB 1279, SB 32, and AB 197.
EO B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by
2030. CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, to reflect the 2030
target set by EO B-30-15 and codified by SB 32. SB 32 affirms the importance of addressing climate
change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990
levels by 2030 contained in EO B-30-15. SB 32 builds on AB 32 and keeps us on the path toward achieving
the State's 2050 objective of reducing emissions to 80 percent below 1990 levels. The companion bill to SB
32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG
emissions. Additional direction in AB 197 intended to provide easier public access to air emissions data that
are collected by CARB was posted in December 2016. AB 1 279 establishes State policy to achieve net zero
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GHG emissions no later than 2045 and for Statewide anthropogenic GHG emissions to be reduced to at
least 85 percent below 1990 levels by 2045.
In addition, the 2022 Scoping Plan assesses progress toward the statutory 2030 target, while laying out a
path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed
to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and
working lands, and others, and is designed to meet the State's long-term climate objectives and support a
range of economic, environmental, energy security, environmental justice, and public health priorities.
The 2022 Scoping Plan focuses on building clean energy production and distribution infrastructure for a
carbon -neutral future, including transitioning existing energy production and transmission infrastructure to
produce zero -carbon electricity and hydrogen, and utilizing biogas resulting from wildfire management or
landfill and dairy operations, among other substitutes. The 2022 Scoping Plan states that in almost all sectors,
electrification will play an important role. The 2022 Scoping Plan evaluates clean energy and technology
options and the transition away from fossil fuels, including adding four times the solar and wind capacity by
2045 and about 1,700 times the amount of current hydrogen supply. As discussed in the 2022 Scoping Plan,
EO N-79-20 requires that all new passenger vehicles sold in California will be zero -emission by 2035, and
all other fleets will have transitioned to zero -emission as fully possible by 2045, which will reduce the
percentage of fossil fuel combustion vehicles.
Energy efficient measures are intended to maximize energy efficiency building and appliance standards,
pursue additional efficiency efforts including new technologies and new policy and implementation
mechanisms, and pursue comparable investment in energy efficiency from all retail providers of electricity
in California. In addition, these measures are designed to expand the use of green building practices to
reduce the carbon footprint of California's new and existing inventory of buildings. Buildout of the Project
would be required to comply with the latest Title 24 and CALGreen Code standards regarding energy
conservation and green building standards. Therefore, the Project would comply with applicable energy
measures.
Water conservation and efficiency measures are intended to continue efficiency programs and use cleaner
energy sources to move and treat water. Increasing the efficiency of water transport and reducing water
use would reduce GHG emissions. As noted above, buildout associated with the Project would be required
to comply with the latest Title 24 and CALGreen Code standards, which include a variety of different
measures, including reduction of wastewater and water use. In addition, the Project would be required to
comply with the California Model Water Efficient Landscape Ordinance. Therefore, the Project would not
conflict with any of the water conservation and efficiency measures.
The goal of transportation and motor vehicle measures is to develop regional GHG emissions reduction
targets for passenger vehicles. Specific regional emission targets for transportation emissions would not
directly apply to the Project. The second phase of Pavley standards will reduce GHG emissions from new
cars by 34 percent from 2016 levels by 2025, resulting in a three percent decrease in average vehicle
emissions for all vehicles by 2020. Vehicles traveling to the project site would comply with the Pavley II (LEV
III) Advanced Clean Cars Program. Therefore, the Project would not conflict with the identified transportation
and motor vehicle measures.
2024-2050 Regional Transportation Plan/Sustainable Communities Strategy
SCAG's RTP/SCS identifies that land use strategies that focus on new housing and job growth in areas served
by high quality transit and other opportunity areas would be consistent with a land use development pattern
that supports and complements the proposed transportation network. The core vision in the 2024-2050
RTP/SCS is to better manage the existing transportation system through design management strategies,
integrate land use decisions and technological advancements, create complete streets that are safe to all
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roadway users, preserve the transportation system, and expand transit and foster development in transit -
oriented communities. The 2024-2050 RTP/SCS contains transportation projects to help more efficiently
distribute population, housing, and employment growth, as well as forecast development that is generally
consistent with regional -level general plan data. The forecasted development pattern, when integrated with
the financially constrained transportation investments identified in the 2024-2050 RTP/SCS, would reach
the GHG emissions reduction target set by CARB, including the regional target of reducing GHG emissions
from autos and light -duty trucks by 19 percent by 2035 (compared to 2005 levels). The 2024-2050
RTP/SCS does not require that local General Plans, Specific Plans, or zoning be consistent with the 2024-
2050 RTP/SCS but provides incentives for consistency for governments and developers.
The objectives of the 2024-2050 RTP/SCS are to create a region with: transit as a backbone of the
transportation system; more Complete Streets where people and safety are prioritized; policies that
encourage emerging technologies and mobility innovations that support rather than hamper regional goals;
more housing, jobs, and mobility options closer together in Priority Development Areas to preserve natural
lands and open spaces; more housing to address the existing housing need as defined by the RHNA; safe
and fluid movement of goods, with a commitment to the broad deployment of zero- and near -zero emission
technologies.
With respect to determining the Project's consistency with AQMP growth assumptions, the projections in the
AQMP for achieving air quality goals are based on assumptions in SCAG's RTP/SCS regarding population,
housing, and growth trends. According to SCAG's 2024— 2050 RTP/SCS, in 2019, the City's population was
80,400 residents and the City had 27,000 households and 51,700 jobs. Households are forecast to increase
by approximately 6,800 households by 2035 and 7,000 households by 2050 and employment are forecast
to increase by approximately 14,600 jobs by 2035 and 19,600 jobs by 2050. (Southern California
Association of Governments, 2024).
As identified in the Project Description, the City's 2021-2029 Housing Element identifies several adequate
sites that are able to accommodate the development of additional housing units for the City to meet its
estimated housing growth needs identified in the SCAG's RHNA allocation. Of the Housing Element inventory
sites, Enderle Center (the project site) was identified as necessary for rezoning under Housing Element
Program 1.1 f to allow for high density residential/mixed use development. The proposed project would
accommodate up to 413 housing units to help the City meet its RHNA allocation.
The development of 413 housing units would result in approximately 1,189 additional residents based on
the estimated 2.88 persons per household average in Tustin (State of California Department of Finance,
2023). Future development implemented in accordance with the proposed Housing Overlay Zone would
accommodate planned regional housing growth included in the SCAG RHNA and would be required to
adhere to the General Plan. Therefore, since the purpose of the proposed Project is to accommodate planned
regional housing growth included in the SCAG RHNA, the proposed Project would not exceed the growth
assumptions in the SCAG's RTP/SCS or the AQMP. Based on the nature of the proposed Project, it is
anticipated that implementation of the proposed Project would not interfere with SCAG's ability to implement
the regional strategies outlined in the RTP/SCS.
Implementing SCAG's RTP/SCS will greatly reduce the regional GHG emissions from transportation, helping
to achieve statewide emissions reduction targets. The proposed Project would not interfere with SCAG's
ability to achieve the region's GHG reduction target of 19 percent below 2005 per capita emissions levels
by 2035.
Although the proposed Project would be consistent with the identified measures and goals from the 2022
Scoping Plan and 2024-2050 RTP/SCS, the proposed Project would result in a significant and unavoidable
impact for GHG emissions based on SCAQMD thresholds. As such, the proposed Project would not comply
with existing State regulations adopted to achieve the overall GHG emissions reduction goals identified in
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the 2022 Scoping Plan, EO B-30-15, and AB 197 and would not be consistent with applicable State plans
and programs designed to reduce GHG emissions. Therefore, the proposed Project would conflict with
applicable plans, policies, and regulations adopted for the purpose of reducing the emissions of GHGs.
5.3.7 CUMULATIVE IMPACTS
This section presents information regarding potential cumulative impacts associated with the proposed
project. As defined in the State CEQA Guidelines, cumulative impacts are the incremental effects of an
individual project when viewed in connection with the effects of past, current, and probable future projects
within the cumulative impact area. Table 5-1 in Section 5.0, Environmental Impact Analysis, provides a list of
cumulative projects; however, because of the lack of available emissions data for the cumulative projects,
cumulative emissions were not evaluated quantitatively. Table 5-1 lists the cumulative projects and provides
a brief description and the distances from the Project site and Figure 5-1 includes a map of the various
cumulative projects considered. The list includes two projects within the City of Santa Ana, and six projects
within the City of Tustin.
GHG impacts are by their nature cumulative impacts. Localized impacts of climate change are the result of
the cumulative impact of global emissions. The combined benefits of reductions achieved by all levels of
government help to slow or reverse the growth in GHG emissions. In the absence of comprehensive
international agreements on appropriate levels of reductions achieved by each country, another measure of
cumulative contribution is required. This serves to define the State's share of the reductions regardless of the
activities or lack of activities of other areas of the U.S. or the world. Therefore, a cumulative threshold based
on consistency with State targets and actions to reduce GHGs is an appropriate standard of comparison for
significance determinations.
As previously stated, GHG emissions associated with the buildout under the proposed Project would exceed
the SCAQMD thresholds of 3,000 MT CO2e/yr and 4.1 MT CO2e/yr/SP. Since GHG is a global issue, it is
unlikely that the proposed Project would generate enough GHG emissions to influence GHG emissions on its
own; however, because Project -related CO2e emissions would exceed the SCAQMD's thresholds, the
proposed Project would have a significant contribution to cumulatively considerable GHG emission impacts.
5.3.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
State
• Clean Car Standards — Pavley Assembly Bill 1493
• California Executive Order S-3-05
• Assembly Bill 32 (Global Warming Solutions Act of 2006)
• Senate Bill 375
• California Executive Order B-30-15
• Senate Bill 32
• California Green Building Standards Code (Code of Regulations, Title 24 Part 6)
Plans, Programs, or Policies
PPP E-1: CALGreen Compliance. Listed previously in Section 5.2, Energy.
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5.3.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact GHG-1 and Impact GHG-2 would be potentially significant.
5.3.10 MITIGATION MEASURES
Mitigation Measure GHG-1. Prior to building permit approval by the City of Tustin (City) for future
development projects, project applicants shall prepare and submit a technical assessment evaluating
potential project -related greenhouse gas (GHG) impacts to the City for review and approval. The evaluation
shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD)
methodology. If project -related GHG emissions exceed applicable SCAQMD thresholds of significance
and/or Statewide GHG reduction targets, the City shall require that applicants for new development
projects incorporate mitigation measures to reduce GHG emissions. Mitigation measures could include, but
are not limited to: energy efficiency measures, water conservation and efficiency measures, solid waste
measures, and transportation and motor vehicles measures. The identified measures shall be included as part
of the project's approval.
5.3.1 1 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact GHG-1 and Impact GHG-2 would be significant and unavoidable.
5.3.1 2 REFERENCES
City of Tustin. (2018, November). City of Tustin General Plan. Retrieved from
https://www.tustinca.org/DocumentCenter/View/71 3/City-of-Tustin-General-Plan-PDF
LSA. (2024). Enderle Center Project Air Quality, Energy, and Greenhouse Gas Impact Report.
Southern California Air Quality Management District. (1993, April). CEQA Air Quality Handbook. Retrieved
from https://www.agmd.gov/home/rules-compliance/cega/air-quality-analysis-handbook/cega-
air-quality-handbook-(1993)
Southern California Association of Governments. (2024, April). Connect SoCal 2024-2050 Regional
Transportation Plan/Sustainable Communities Strategy. Retrieved from https://scag.ca.gov/connect-
socal
State of California Department of Finance. (2023, May). Population and Housing Estimates for Cities,
Counties, and the State — January 1, 2022 and 2023. Retrieved from
https://dof.ca.gov/forecasting/demographics/estimates-el /
U.S. Environmental Protection Agency. (2023). Inventory of U.S. Greenhouse Gas Emissions and Sinks: 7990-
2021. Retrieved from https://www.epa.gov/system/files/documents/2023-04/US-GHG-
Inventory- 2023-Main-Text.pdf
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5.4 Land Use and Planning
5.4.1 INTRODUCTION
In accordance with CEQA Guidelines Section 151 25(d), this section provides a summary of the plans, policies,
and regulations of the City of Tustin, and regional, State, and federal agencies that have policy and
regulatory control over the Enderle Center area and the proposed Project. Policy conflicts do not, in and of
themselves, indicate a significant environmental effect within the meaning of CEQA. To the extent that
physical environmental impacts may result from such conflicts, those impacts are analyzed in this EIR in the
specific topical sections to which the impact pertains (e.g., noise, air quality, greenhouse gas emissions, or
transportation). More specifically, this section examines the potential for the proposed Enderle Center Rezone
Project to physically divide an established community and/or conflict with any applicable land use plan,
policy, or regulation of an agency with jurisdiction over the Project adopted for the purpose of avoiding or
mitigating an environmental effect, including relevant goals and policies of the recently updated City of
Tustin General Plan (2018), the Tustin City Code, and the SCAG Final 2020-2045 and 2024-2050 Regional
Transportation Plan/Sustainable Communities Strategy (RTP/SCS), "Connect SoCal".
• City of Tustin General Plan (including 2021-2029 Housing Element), adopted November 2018, updated
October 2022).
• Tustin City Code
• Connect SoCal 2020-2045 Regional Transportation PlanlSustainable Communities Strategy (RTPISCS),
adopted September 2020.
• Connect SoCal 2024-2050 Regional Transportation PlanlSustainable Communities Strategy (RTPISCS),
adopted April 2024.
5.4.2 REGULATORY SETTING
5.4.2.1 State Regulations
California Planning and Zoning Law
The legal framework under which California cities and counties exercise local planning and land use functions
is set forth in California Planning and Zoning Law, Government Code Sections 65000-66499.58. Under
State planning law, each city and county must adopt a comprehensive, long-term General Plan (GP). State
law gives cities and counties wide latitude in how a jurisdiction may create a GP, but there are fundamental
requirements that must be met. As stated in Section 65302 of the California Government Code, "The general
plan shall consist of a statement of development policies and shall include a diagram or diagrams and text
setting forth objectives, principle, standard, and plan proposals." While a GP will contain the community
vision for future growth, California law also requires each plan to address the mandated elements listed in
Section 65302. The mandatory elements for all jurisdictions are land use, circulation, housing, conservation,
open space, noise, and safety. Each of the elements must contain text and descriptions setting forth objectives,
principles, standards, policies, and plan proposals.
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5.A.2.2 Local and Regional Regulations
SCAG Final 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTPISCS),
(Connect SoCal 2020)
The Southern California Association of Governments (SCAG) is designated by federal law as a Metropolitan
Planning Organization (MPO) and under State law as a Regional Transportation Planning Agency and a
Council of Governments. The SCAG region encompasses six counties (Imperial, Los Angeles, Orange,
Riverside, San Bernardino, and Ventura) and 191 cities in an area covering more than 38,000 square miles.
SCAG develops transportation and housing strategies for Southern California as a whole.
On September 3, 2020, SCAG's Regional Council adopted Connect SoCal, the 2020-2045 Regional
Transportation Plan/Sustainable Communities Strategy (2020 RTP/SCS), which includes long range regional
transportation plans, regional transportation improvement programs, regional housing needs allocations, and
other plans for the region. Most of the plan's goals are related to regional transportation infrastructure and
the efficiency of transportation in the region. SCAG is required by federal law (23 U.S.C. Section 134 et
seq.) to prepare and update the long-range RTP/SCS every four years in order to readjust its vision for the
future, assess challenges, and rearticulate goals. On April 4, 2024, SCAG approved "Connect SoCal," the
2024-2050 RTP/SCS. Connect SoCal 2024 outlines a vision for a more resilient and equitable future, with
investment, policies and strategies for achieving the region's shared goals through 2050.
The following SCAG Connect SoCal sustainable community land use related policies are intended to be
supportive of implementing the RTP/SCS. Several are directly tied to supporting related GHG reductions
while others support the broader goals of Connect SoCal:
Focus Growth Near Destinations & Mobility Options
• Emphasize land use patterns that facilitate multimodal access to work, educational and other
destinations.
• Focus on a regional jobs/housing balance to reduce commute times and distances and expand job
opportunities near transit and along center -focused main streets.
• Plan for growth near transit investments and support implementation of first/last mile strategies.
• Promote the redevelopment of underperforming retail developments and other outmoded nonresidential
uses.
• Prioritize infill and redevelopment of underutilized land to accommodate new growth, increase amenities
and connectivity in existing neighborhoods.
• Encourage design and transportation options that reduce the reliance on and number of solo car trips
(this could include mixed -uses or locating and orienting close to existing destinations).
• Identify ways to "right size" parking requirements and promote alternative parking strategies (e.g.,
shared parking or smart parking).
Promote Diverse Housing Choices
• Preserve and rehabilitate affordable housing and prevent displacement.
• Identify funding opportunities for new workforce and affordable housing development.
• Create incentives and reduce regulatory barriers for building context -sensitive accessory dwelling units
to increase housing supply.
• Provide support to local jurisdictions to streamline and lessen barriers to housing development that
supports reduction of greenhouse gas emissions.
Leverage Technology Innovations
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• Promote low emission technologies such as neighborhood electric vehicles, shared rides hailing, car
sharing, bike sharing and scooters by providing supportive and safe infrastructure such as dedicated
lanes, charging and parking/drop-off space.
• Improve access to services through technology —such as telework and telemedicine as well as other
incentives such as a "mobility wallet," an app-based system for storing transit and other multi -modal
payments.
• Identify ways to incorporate "micro -power grids" in communities, for example solar energy, hydrogen
fuel cell power storage and power generation.
Support Implementation of Sustainability Policies
• Pursue funding opportunities to support local sustainable development implementation projects that
reduce greenhouse gas emissions.
• Support statewide legislation that reduces barriers to new construction and that incentivizes development
near transit corridors and stations.
• Support local jurisdictions in the establishment of Enhanced Infrastructure Financing Districts (EIFDs),
Community Revitalization and Investment Authorities (CRIAs), or other tax increment or value capture
tools to finance sustainable infrastructure and development projects, including parks and open space.
• Work with local jurisdictions/communities to identify opportunities and assess barriers to implement
sustainability strategies.
• Enhance partnerships with other planning organizations to promote resources and best practices in the
SCAG region.
• Continue to support long range planning efforts by local jurisdictions.
• Provide educational opportunities to local decisionmakers and staff on new tools, best practices, and
policies related to implementing the Sustainable Communities Strategy.
Promote a Green Region
• Support development of local climate adaptation and hazard mitigation plans, as well as project
implementation that improves community resiliency to climate change and natural hazards.
• Support local policies for renewable energy production, reduction of urban heat islands and carbon
sequestration.
• Integrate local food production into the regional landscape.
• Promote more resource efficient development focused on conservation, recycling, and reclamation.
• Preserve, enhance, and restore regional wildlife connectivity.
• Reduce consumption of resource areas, including agricultural land.
• Identify ways to improve access to public park space.
City of Tustin General Plan
The City of Tustin GP is the City's principal long-range policy and planning document guiding the
development, conservation, and enhancement of Tustin. The GP was adopted by the City in 2018 and
contains seven elements that provide a comprehensive collection of goals and policies related to the physical
development of the City. The City is also required by State law to periodically update its Housing Element,
a mandatory component of the City's GP. The update to the Housing Element was adopted by the City in
2021 and certified by the State of California Housing and Community Development Department (HCD) in
2022. The GP goals and policies that are relevant to the proposed Project are listed below by GP Element.
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Land Use Element
Goal 1: Provide for a well-balanced land use pattern that accommodates existing and future
needs for housing, commercial and industrial land, open space and community facilities
and services, while maintaining a healthy, diversified economy adequate to provide
future City services.
Policy 1.1: Preserve the low -density quality of Tustin's existing single-family neighborhoods while
permitting compatible multi -family development to meet regional housing needs where best
suited from the standpoint of current development, accessibility, transportation and public
facilities.
Policy 1.2: Provide for and encourage the development of neighborhood -serving commercial uses in
areas of Tustin presently underserved by such uses. Encourage the integration of retail or
service commercial uses on the street level of office projects.
Policy 1.6: Ensure an adequate supply of commercial and industrial land within the City of Tustin for
potential commercial and industrial expansion and development.
Policy 1.7: As part of the City's attraction to business and industry, provide adequate sites to house
future employees.
Policy 1.10: Ensure that the distribution and intensity of land uses are consistent with the Land Use Plan
and classification system.
Policy 1.1 1: Where feasible, increase the amount and network of public and private open space and
recreational facilities which will be adequate in size and location to be useable for active
or passive recreation as well as for visual relief.
Goal 2: Ensure that future land use decisions are the result of sound and comprehensive
planning.
Policy 2.1: Consider all General Plan goals and policies, including those in other General Plan elements,
in evaluating proposed development projects for General Plan consistency.
Goal3: Ensure that new development is compatible with surrounding land uses in the
community, the City's circulation network, availability of public facilities, existing
development constraints and the City's unique characteristics and resources.
Policy 3.7: Encourage the preservation and enhancement of public vistas, particularly those seen from
public places.
Goal4: Assure a safe, healthy and aesthetically pleasing community for residents and
businesses.
Policy 4.1: Mitigate traffic congestion and unacceptable levels of noise, odors, dust and light and glare
which affect residential areas and sensitive receptors.
Policy 4.2: Ensure a sensitive transition between commercial or industrial uses and residential uses by
means of such techniques as buffering, landscaping and setbacks.
Policy 4.3: Where mixed uses are permitted, ensure compatible integration of adjacent uses to
minimize conflicts.
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Goal 6: Improve urban design in Tustin to ensure development that is both architecturally and
functionally compatible, and to create uniquely identifiable neighborhoods, commercial
and business park districts.
Policy 6.2: Encourage and promote high quality design and physical appearance in all development
projects.
Policy 6A Preserve and enhance the City's special residential character and "small town" quality by
encouraging and maintaining Tustin's low density residential neighborhoods through
enforcement of existing land use and property development standards and the harmonious
blending of buildings and landscape.
Policy 6.9: Upgrade the visual quality of edge conditions between industrial and residential uses
through street tree planting and on -site landscaping.
Policy 6.12: Review and revise, as necessary, the City's development standards to improve the quality
of new development in the City and to protect the public health and safety.
Goal 8: Ensure that necessary public facilities and services should be available to accommodate
development proposed on the Land Use Policy Map.
Policy 8.1: Encourage within economic capabilities, a wide range of accessible public facilities and
community services including fire and police protection, flood control and drainage,
educational, cultural and recreational opportunities and other governmental and municipal
services. Senate Bill (SB) 50, adopted in 1998, prohibits the City from using the inadequacy
of school facilities as a basis for denying or conditioning the development of property. SB
50, however, gave school districts new authority to raise school impact mitigation fees. In
addition, the voters passed Proposition 1 A in November 1998, which provides $9.2 billion
dollars in bonds to construct new or expand existing schools. In summary, school districts
have the financial means and legal authority to respond to new development
Policy 8.7: To ensure an orderly extension of essential services and facilities, and preservation of a
free -flowing circulation system, continue to require provision of essential facilities and
services at the developer's expense where these systems do not exist or are not already
part of the City's financed capital improvement program.
Policy 8.8: Maintain and improve, where necessary, the City's infrastructure and facilities.
Goal 9: Continue to provide for a planned community in East Tustin compatible with the land
use characteristics of the local area and sensitive to the natural environment.
Policy 9.6: Retain natural landscape to the maximum extent possible, and incorporate planting in new
development areas compatible with the character and quality of the natural surrounding
environment.
Housing Element
Goal 1: Provision of an adequate supply of housing to meet the need for a variety of housing
types and the diverse socio-economic needs of all community residents commensurate
with the City's identified housing needs in the RHNA allocation.
Policy 1.1: Provide site opportunities inventory of vacant and underutilized land for development of
housing that responds to diverse community needs in terms of housing type, cost and location,
emphasizing locations near services and transit.
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Policy 1.4: Initiate development permit and zoning code streamlining strategies to encourage and
expedite residential development (i.e. accessory dwelling units, affordable housing units,
and investments in existing buildings) to reduce and eliminate regulatory barriers.
Policy 1.5: Encourage infill development or site redevelopment within feasible development sites for
homeownership and rental units through the implementation of smart growth principles,
allowing for the construction of higher density housing, affordable housing, and mixed -use
development (the vertical and horizontal integration of commercial and residential uses) in
proximity to employment opportunities, community facilities and services, and amenities.
Goal2: Promote fair housing opportunities for all people regardless of their special
characteristics as protected under state and federal fair housing laws.
Policy 2.3: Promote the dispersion and integration of housing for low- and very -low income families
throughout the community.
Policy 2.6: Promote fair housing opportunities by supporting the continuation of policies that require
relocation assistance, and/or to provide incentives and assistance for purchase of the units
by low- and moderate -income households.
Goal 5: Ensure that new housing is sensitive to the existing natural and built environment.
Policy 5.1: Prioritize sustainable housing developments in proximity to services and employment centers
thereby enabling the use of public transit, walking or bicycling and promoting an active
lifestyle.
Policy 5.2: Promote green building practices for more sustainable energy conservation measures in the
construction of new housing or rehabilitated units.
Housing Element Programs
The 2021-2029 Housing Element included several housing programs to be implemented during the 2021-
2029 planning period.
Program 1.2a
Program 1.2a provides that the City will amend its Zoning Code to remove subjective design guidance in
Tustin City Code Section 9272 (Design Review) and adopt new Objective Design Standards (ODS) to ensure
that the City can provide clear guidance regarding project design, in order to streamline the development
of high -quality residential development. The ODS would include provisions consistent with the requirements
of Senate Bill (SB) 35. Program 1.2a is anticipated to be complete in October 2024.
Program 1.2c
Program 1.2c directs the City to develop parking standards to facilitate residential housing production as
part of mixed -use developments, adaptive reuse projects, and new residential developments. The program
provides that parking displaced as a result of redevelopment may be replaced with vertical parking
structures, as needed, to provide required parking. Additionally, the parking standards would incentivize
creative parking strategies such as parking credits for transit rich development, and allowance of parking
structures and parking lifts, by right and subject to the ODS.
Circulation Element
Goal 1: Preserve the low -density quality of Tustin's existing single-family neighborhoods while
permitting compatible multi -family development to meet regional housing needs where
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best suited from the standpoint of current development, accessibility, transportation and
public facilities.
Policy 1.2: Develop and implement circulation system standards for roadway and intersection
classifications, right-of-way width, pavement width, design speed, warrant requirements,
capacity, maximum grades and associated features such as medians and bicycle lanes or
trails that are adjacent or off -road.
Policy 1.3: Coordinate roadway improvements with applicable regional, state and federal
transportation plans and proposals.
Policy 1 A Develop and implement thresholds and performance standards for acceptable levels of
service.
Policy 1.10: Require that proposals for major new developments include a future traffic impact analysis
which identifies measures to mitigate any identified project impacts.
Policy 1.1 1: Encourage new development which facilitates transit services, provides for non -vehicular
circulation and minimizes vehicle miles traveled.
Policy 1.13: Minimize effects of transportation noise wherever possible so as to comply with the Noise
Element.
Policy 1.15: Ensure construction of existing roadways to planned widths, as new developments are
constructed.
Policy 1.16: Continue to require dedication of right-of-way and construction of required public
improvements on streets adjacent to construction projects at the developers expense.
Goal 5: Support development of a public transportation system that provides mobility to all City
inhabitants and encourages use of public transportation as an alternative to automobile
travel.
Policy 5.2: Require new development to fund transit facilities, such as bus shelters and turn -outs, where
deemed necessary to meet public needs arising in conjunction with development.
Policy 5.5: Promote new development that is designed in a manner which facilitates provision or
expansion of transit service and provides non -automobile circulation within the development.
Goal 6: Increase the use of non -motorized modes of transportation.
Policy 6.1: Promote the safety of pedestrians and bicyclists by adhering to uniform standards and
practices, including designation. of bicycle lanes, off -road bicycle trails, proper signage,
and adequate sidewalk, bicycle lane, and off -road bicycle trail widths.
Policy 6.2: Maintain existing pedestrian facilities and require new development to provide pedestrian
walkways between developments, schools and public facilities.
Policy 6.8: Support retrofit installation of sidewalks in industrial districts and Planned Community
Business Parks as development occurs.
Policy 6.14: Require new development to dedicate land and fund improvement of bicycle, pedestrian
and equestrian facilities, where deemed necessary to meet public needs arising in
conjunction with development.
Goal 7: Provide for well -designed and convenient parking facilities.
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Policy 7.1: Consolidate parking, where appropriate, to eliminate the number of ingress and egress
points onto arterials.
Policy 7.2: Provide sufficient off-street parking for all land uses.
Conservation, Open Space, and Recreation Element
Goal 1: Reduce air pollution through proper land use, transportation and energy use planning.
Policy 1.1: Cooperate with the South Coast Air Quality Management District and the Southern
California Association of Governments in their effort to implement provisions of the region's
Air Quality Management Plan, as amended.
Policy 1.3: Locate multiple family developments close to commercial areas to encourage pedestrian
rather than vehicular travel.
Policy 1.4: Develop neighborhood parks near concentrations of residents to encourage pedestrian
travel to the recreation facilities.
Policy 1.6: Cooperate and participate in regional air quality management plans, programs, and
enforcement measures.
Goal 2: Improve air quality by influencing transportation choices of mode, time of day, or
whether to travel and to establish a jobs/housing balance.
Policy 2.1: Reduce vehicle trips through incentives, regulations and/or Transportation Demand
Management (TDM) programs.
Policy 2.2: Reduce total vehicle miles traveled (VMT) through incentives, regulations and/or
Transportation Demand Management.
Policy 2.1 2: Implement land use policy contained in the Land Use Element toward the end of achieving
jobs/housing balance goals.
Goal 3: Reduce particulate emissions to the greatest extent feasible.
Policy 3.1: Adopt incentives, regulations, and/or procedures to minimize particulate emissions from
paved and unpaved roads, agricultural uses, parking lots, and building construction.
Goal 4: Reduce emissions through reduced energy consumption.
Policy 4.1: Promote energy conservation in all sectors of the City including residential, commercial, and
industrial.
Goal 5: Protect water quality and conserve water supply.
Policy 5.2: Protect groundwater resources from depletion and sources of pollution.
Policy 5.3: Conserve imported water by requiring water conservation techniques, water conserving
appliances, and drought -resistant landscaping.
Policy 5.5: Protect water quality by responsible agency support of enforcement of water quality
standards for water imported into the County, and to preserve the quality of water in the
groundwater basin and streams.
Goal 7: Conserve and protect natural plant and animal communities.
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Policy 7.1: Inventory unique or significant tree stands, with particular attention given to the cedar stand,
eucalyptus groves, and eucalyptus windrows in East Tustin. Develop standards to retain or
incorporate the eucalyptus windrows and groves into development plans where feasible.
The redwood/sequoia stand has been retained within a park site and integrated into the
park design.
Policy 7.2: Conserve important plant communities and wildlife habitats, such as riparian areas, wildlife
movement corridors, wetlands, and significant tree stands through the practice of creative
site planning, revegetation, and open space easements/dedications.
Policy 7A Require new development to revegetate graded areas.
Goal 8: Conserve and protect significant topographical features, important watershed areas,
resources, and soils.
Policy 8.1: Develop standards to preserve the unique variety of land forms indigenous in hillside areas,
and ensure that the development process is structured to ensure that grading and siting
practice reflects the natural topography.
Policy 8.2: Control erosion during and following construction through proper grading techniques,
vegetation replanting, and the installation of proper drainage control improvements.
Policy 8.3: Encourage the practice of proper soil management techniques to reduce erosion,
sedimentation, and other soil -related problems.
Policy 8.5: Review applications for building and grading permits, and applications for subdivision for
adjacency to, threats from, and impacts on geological hazards arising from seismic events,
landslides, or other geologic hazards such as expansive soils and subsidence areas.
Policy 8.6: Site planning and architectural design shall respond to the natural landform whenever
possible to minimize grading and viewshed intrusion.
Policy 8.8: Require geotechnical studies for developments that are proposed for steep slopes and
where geological instability may be suspected. Where a precise location of the El Modena
fault is determined, appropriate building setbacks shall be established per State law.
Policy 8.10: Mitigate the impacts of development on sensitive lands such as steep slopes, wetlands,
cultural resources, and sensitive habitats through the environmental review process.
Policy 8.16: Site buildings and align roadways to maximize public visual exposure to natural features.
Goal 10: Reduce solid waste produced within City.
Policy 10.2: Ensure that the City diverts from landfills a maximum of 50% of the solid waste generated
in the City as required by the California Integrated Waste Management Board.
Goal11: Conserve energy resources through use of available energy technology and
conservation practices.
Policy 1 1.2: Maintain local legislation to establish, update and implement energy performance building
code requirements established under State Title 24 Energy Regulations.
Goal 12: Maintain and enhance the City's unique culturally and historically significant building
sites or features.
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Policy 1 2.2: Retain and protect significant areas of archaeological, paleontological, or historical value
for education and scientific purposes.
Goal 13: Preserve Tustin's archaeological and paleontological resources.
Policy 1 3.1: Require a site inspection by certified archaeologists or paleontologists for new development
in designated sensitive areas.
Policy 13.2: Require mitigation measures where development will affect archaeological or
paleontological resources.
Goal 14: Encourage the development and maintenance of a balanced system of public and
private parks, recreation facilities, and open spaces that serves the needs of existing
and future residents in the City of Tustin.
Policy 14.8: Encourage and, where appropriate, require the inclusion of recreation facilities and open
space within future residential, industrial and commercial developments.
Policy 14.12: Ensure that the City's laws and related implementation tools relating to park dedication and
development (e.g., ordinances, regulations, in -lieu fee schedules, etc.) reflect current land
and construction costs, and are, in fact, providing adequate park land and facilities
concurrent with population growth.
Goal 17: Operate and maintain existing and future parks and recreation facilities so they are
safe, clean, and attractive to the public; and preserve, protect, and enhance both existing
and potential natural recreation areas to ensure that long-term public investments and
values are not unreasonably preempted, compromised, or prevented by neglect or
short-term considerations.
Policy 17.2: Require park designs (including landscape treatments, buildings, irrigation, etc.) that are
durable, reasonably standardized, and economical to maintain.
Goal 18: Ensure that the recreational goals and policies are pursued and realized in an organized,
incremental, and cost effective manner and consistent with the City of Tustin's financial
resources and legal authorities and the appropriate responsibilities of other agencies,
the private sector, and individual and group users.
Policy 1 8.5: Conserve the City's Quimby Act authority by utilizing, wherever practicable, the City's broad
powers to enact and enforce its General Plan, Specific Plan(s), Redevelopment Plan(s),
subdivision ordinance and Zoning Ordinance to secure public and private recreation sites,
open space, trails, and other related land use objectives of community planning significance.
Public Safety Element
Goal 1: Reduce the risk to the community's inhabitants from flood hazards.
Policy 1.1: Identify flood hazard areas and provide appropriate land use regulations for areas subject
to flooding.
Policy 1.5: Require detention basins as a flood control measure where applicable to reduce the risk
from flood hazards.
Goal 3: Reduce the risk to the community from geologic and seismic hazards.
Policy 3.1: Require review of soil and geologic conditions by a State -Licensed Engineering Geologist
to determine stability prior to the approval of development where appropriate.
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5.4 Land Use and
Policy 3.5: Ensure that structures for human occupancy, critical structures, and vital emergency facilities
are designed to minimize damage from potential geologic/seismic hazards and avoid
functional impairment.
Policy 3.7: Include and periodically review and update emergency procedures for earthquakes in the
City's Emergency Preparedness Plan.
Goal 4: Reduce the risk to the community's inhabitants from exposure to hazardous materials
and wastes.
Policy 4.3: Transportation of hazardous waste will be minimized and regulated where possible to avoid
environmentally sensitive areas and populated, congested, and dangerous routes.
Policy 4.5: Establish regulations requiring land uses involved in the production, storage, transportation,
handling, or disposal of hazardous materials to be located a safe distance from other land
uses that may be adversely affected by such activities.
Policy 4.15: Coordinate with the County of Orange in the implementation of the National Pollution
Discharge Elimination System Permits (NPDES) regulations.
Goal 5: Reduce the risk to the community's inhabitants from fires or explosions.
Policy 5.4: Enforce building code requirements that assure adequate fire protection.
Policy 5.6: Cooperate with Orange County Fire Authority to ensure the provision of adequate and cost-
effective fire protection services.
Goal 6: Stabilize demand for law enforcement services.
Policy 6.1: Provide appropriate levels of police protection within the community.
Policy 6.5: Promote the use of defensible space concepts (site and building lighting, visual observation
of open spaces, secured areas, etc.) in project design to enhance public safety.
Goal 8: Improve the City's ability to respond to natural and manmade emergencies.
Policy 8.1: Maintain an up-to-date Emergency Operations Plan identifying all available resources and
funds for use in the event of a disaster and establishing implementing actions or procedures
under the Plan for rescue efforts, medical efforts, emergency shelters, provision of supplies,
and all other response efforts recommended by the State Office of Emergency Services and
the Federal Emergency Management Agency (FEMA). Include procedures for dealing with
specific events such as earthquake, major rail and roadway accidents, flooding, and
hazardous materials.
Noise Element
Goal 1: Use noise control measures to reduce the impact from transportation noise sources.
Policy 1.1: Pursue construction of new barriers, or the augmentation of existing barriers, to reduce noise
impacts along the Route 5 and Route 55 freeways along segments directly next to
residential areas.
Policy 1.11: Consider noise impacts to residential neighborhoods when designating truck routes and
major circulation corridors.
Goal 2: Incorporate noise considerations into land use planning decisions.
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5.4 Land Use and
Policy 2.1: Adopt planning guidelines that establish acceptable noise standards for various land uses
throughout the Tustin Planning Area.
Policy 2.3: Use noise/land use compatibility standards as a guide for future planning and development.
Policy 2.4: Review proposed projects in terms of compatibility with nearby noise -sensitive land uses
with the intent of reducing noise.
Policy 2.5: Require new residential developments located in proximity to existing commercial/industrial
operations to control residential interior noise levels as a condition of approval.
Policy 2.6: Require that commercial uses developed as part of a mixed -use project (with residential)
not be noise intensive. Design mixed -use structures to prevent transfer of noise from the
commercial to the residential use.
Policy 2.7: Require new commercial/industrial operations located in proximity to existing or proposed
residential areas to incorporate noise mitigation into project design.
Goal 3: Develop measures to control non -transportation noise impacts.
Policy 3.1: Implement a review process of Tustin's noise ordinance, and City policies and regulations
affecting noise.
Policy 3.2: Minimize the impacts of construction noise on adjacent land uses through limiting the
permitted hours of activity.
Policy 3.3: Require City departments to observe state and federal occupational safety and health noise
standards.
Growth Management Element
Goal 2: Ensure adequate transportation facilities are provided for existing and future inhabitants
of the City.
Policy 2.1: Require that all new development pay its share of the street improvement costs associated
with the development, including regional traffic mitigation.
Policy 2.5: All new development shall be required to establish a development phasing program which
phases approval of development commensurate with required improvements to roadway
capacity. The Phasing Plan shall include an overall buildout development plan which can
demonstrate the ability of the infrastructure to support the planned development.
Policy 2.6: Development phasing for new projects shall be a component of the development review
and entitlement process and shall be approved prior to issuance of building or grading
permits.
Tustin City Code (Tustin Municipal Code)
Chapter 2, Zoning
Chapter 2, Zoning, of the City's Municipal Code regulates the location and uses of specific uses within the
city, including residences, businesses, trades, industries, use of buildings, structures, and land, the location,
height, bulk, and size of buildings and structures. The zoning standards are implemented to:
• Encourage the most appropriate use of land.
• Conserve and stabilize property value.
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Enderle Center Rezone Proiect 5.4 Land Use and
• Provide adequate open spaces for light and air and to prevent and fight fires.
• Prevent the undue concentration of population.
• Lessen congestion on streets and highways.
• Promote the health, safety, and the general welfare of the people, all as part of the GP of the City.
Part 5, Combining and Overlay Districts: Tustin City Code Article 9 (Land Use), Chapter 2 (Zoning), Part 5,
Combining and Overlay Districts, establishes multiple "overlay" designations for the City that are applied
over base zones. These designations are to be used along with underlying land -use designations established
in City zoning map. Overlay districts signify that an area or site has been identified to have distinct
characteristics, requiring special development standards, or allowing certain provisions beyond those for the
underlying zoning designation.
5.4.3 ENVIRONMENTAL SETTING
Enderle Center
Enderle Center (the Project site) consists of approximately 1 1.62 acres of land that includes the following
parcels: Assessor Parcel Numbers (APNs) 401-251-04, -05, and -06; 401-252-05, -06, -08, -09, and -10;
and 401-253-03 and -04. The Enderle Center is currently developed with 87,136 square feet (SF) of
commercial business, including 28,750 SF of restaurant use, 39,960 SF of retail and service use, 18,426 SF
of office use, and surface parking lots. The site also includes ornamental landscaping along the perimeter
and throughout the parking areas.
Existing General Plan Land Use and Zoning Designations
The Project site has a GP land use designation of Planned Community Commercial/Business (PCCB) and a
zoning designation of Planned Community Commercial (PC COM), as shown on Figure 2-4, Existing General
Plan Land Use, and Figure 2-5, Existing Zoning, in Chapter 3.0 Project Description. The PCCB land use
designation provides opportunities for a variety of miscellaneous retail, professional office, and service -
oriented business activities. The PC COM zoning is intended to allow diversification of the relationships of
various buildings, structures and open spaces in planned building groups while ensuring substantial
compliance with the district regulations and other provisions of the Planned Community District zone.
Surrounding Land Uses
The proposed Rezone Project is located within an urban area that is fully developed area. The surrounding
land uses and their designations are described Table 3-1, Surrounding Existing Land Use and Zoning
Designations, in Chapter 3.0, Project Description. The Project site is generally bounded on the north by 17th
Street; on the east by Enderle Center Drive and the eastern property line of properties fronting Enderle
Center Drive; to the south by Vandenberg Lane; and to the west by the 55 freeway, including properties
west of Yorba Street. The land uses immediately adjacent to the Specific Plan area include the following:
North: 17'h Street bounds the site to the north, followed by commercial, residential and office uses.
East: Enderle Center Drive borders the site to the east and includes office uses.
South: Vandenberg Lane bounds the site to the south followed by residential uses.
West: Tustin City limits and SR-55 freeway, followed by restaurants and office uses in the City of Santa
Ana.
City of Tustin 5.4-1 3
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Enderle Center Rezone Proiect 5.4 Land Use and
5.4.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
LU-1 Physically divide an established community.
LU-2 Cause a significant environmental impact due to a conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding or mitigating an environmental effect.
The Initial Study (Appendix A) established that the proposed Project would not result in impacts related to
Threshold LU-1; therefore, no further assessment of this threshold is required in this Draft EIR.
5.4.5 METHODOLOGY
The analysis of land use consistency impacts considers whether the proposed Project be inconsistent with (or
conflict with) with regional and local plans, policies, and regulations that are applicable to the proposed
rezone and Project site, including the SCAG RTP/SCS (Connect SoCal), City of Tustin GP, and zoning code.
Consistent with the scope and purpose of this EIR, this discussion primarily focuses on those goals and policies
that relate to avoiding or mitigating environmental impacts, and an assessment of whether any inconsistency
with these standards creates a significant physical impact on the environment. Thus, a project's inconsistency
with a policy is only considered significant if such inconsistency would cause significant physical environmental
impacts (as defined by CEQA Guidelines Section 15382).
CEQA Guidelines Section 151 25(d) requires that an EIR discuss inconsistencies with applicable plans that the
decision -makers should address. A project need not be consistent with each and every policy and objective
in a planning document. Rather, a project is considered consistent with the provisions of the identified regional
and local plans if it meets the general intent of the plans and would not preclude the attainment of the
primary goals of the land use plan or policy.
5.4.6 ENVIRONMENTAL IMPACTS
IMPACT LU-2: THE PROJECT WOULD NOT CAUSE A SIGNIFICANT ENVIRONMENTAL IMPACT DUE
TO A CONFLICT WITH ANY LAND USE PLAN, POLICY, OR REGULATION ADOPTED
FOR THE PURPOSE OF AVOIDING OR MITIGATING AN ENVIRONMENTAL EFFECT.
Less than Significant.
SCAG Connect SoCal Regional Transportation Plan/ Sustainable Communities Strategy Policies
SCAG strategies focus largely on implementing transit -oriented development and increasing the use of
regional transit, encouraging development patterns and densities that reduce infrastructure costs, and
providing affordable and a variety of housing types. The proposed GPA required for the Project would
implement SCAG strategies related to high -density, infill development, and improvement of the job/housing
balance that is centered around public transit opportunities. The Project provides for infill development in an
already developed urban area that would make use of the existing circulation and utility infrastructure. The
Project would allow for development of high -density residential uses and commercial uses that would create
a mixed -use environment in which residents would benefit from the proposed onsite uses and nearby
shopping, restaurant, and employment opportunities. Mixed -use development generally results in lower
vehicle miles traveled (VMT) due to the proximity of residential and nonresidential uses.
City of Tustin 5.4-14
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Enderle Center Rezone
5.4 Land Use and
Table 5.4-1: Project Consistency with 2020 SCAG Connect SoCal Regional Transportation
Plan/Sustainable Communities Strategy Policies
RTP/SCS Goal, Policy, or Objective Proposed Project Consistency with Policy
Focus Growth Near Destinations & Mobility Options
Emphasize land use patterns that
Consistent. The proposed Project includes a General Plan Amendment
facilitate multimodal access to work,
(GPA) to allow for a high intensity mixed -use development near multiple
educational and other destinations.
freeways, existing commercial uses and the OCTA transit system.
Focus on a regional jobs/housing balance
Consistent. The proposed Project would provide additional housing and
to reduce commute times and distances
commercial uses in a regional job centered area and is located near
and expand job opportunities near transit
transit and main streets and would improve the City's jobs/housing
and along center -focused main streets.
balance.
Plan for growth near transit investments
Consistent. The proposed Project includes a GPA to allow for future
and support implementation of first/last
residential development within an existing commercial center near
mile strategies.
multiple freeways and the OCTA transit system. The proposed mixed -
use land uses would reduce VMT by providing housing, retail,
restaurants, and services within the Project site (see Section 5.9,
Transportation).
Promote the redevelopment of
Consistent. The proposed Project would develop an existing
underperforming retail developments and
commercial center with large areas of surface parking and intensify the
other outmoded nonresidential uses.
existing site by allowing for the future development of residential uses.
The Project also considers future development of new nonresidential
uses (previously entitled) that would be developed consistent with
market demands and conditions.
Prioritize infill and redevelopment of
Consistent. The proposed Project is an infill use that would allow for
underutilized land to accommodate new
future development of an existing commercial center to accommodate
growth, increase amenities and
anticipated residential growth, and would provide connectivity to
connectivity in existing neighborhoods.
surrounding neighborhoods.
Encourage design and transportation
Consistent. The proposed Project includes a GPA to allow for future
options that reduce the reliance on and
residential development within an existing commercial center near
number of solo car trips (this could include
multiple freeways and the OCTA transit system. The proposed mixed -
mixed -uses or locating and orienting close
use land uses would reduce VMT by providing housing, retail,
to existing destinations).
restaurants, and services within the Project site (see Section 5.9,
Transportation).
Identify ways to "right size" parking
Consistent. The proposed ODS for the Project site would include
requirements and promote alternative
parking requirements and would provide flexibility in implementing the
parking strategies (e.g., shared parking
various parking requirements for residential and nonresidential uses.
or smart parking).
Future parking would likely include a combination of surface and
structure parking, which would be further regulated through compliance
with ODS created for the Project site.
Promote Diverse Housing Choices
Preserve and rehabilitate affordable Consistent. The Project site does not currently include any housing. No
housing and prevent displacement. housing would be displaced with the proposed Project. The proposed
Project provides for new housing in proximity to existing retail and
commercial services. The Project is prompted by the City's HEU, which is
meant to facilitate future development of a variety of housing types,
including affordable housing.
Identify funding opportunities for new Not applicable. The Project proposes an overlay zone to the site and
workforce and affordable housing does not propose any actual development or funding of future
development. development. The Project would not prevent SCAG from meeting this
goal.
Create incentives and reduce regulatory Consistent. The proposed Project would provide a housing overlay
barriers for building context -sensitive district to the Project site to increase housing supply. Implementation of
the Housina Overlay and ODS would help streamline development
City of Tustin
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June 2024
5.4-15
Enderle Center Rezone Proiect 5.4 Land Use and
RTP/SCS Goal, Policy, or Objective
Proposed Project Consistency with Policy
accessory dwelling units to increase
proposals and reduce regulatory barriers. The proposed Project would
housing supply.
not conflict with policies related to accessory dwelling units.
Provide support to local jurisdictions to
Consistent. The proposed Project provides for an increase in dwelling
streamline and lessen barriers to housing
units to increase housing supply. Implementation of the Housing Overlay
development that supports reduction of
and ODS would help streamline development proposals and reduce
greenhouse gas emissions.
regulatory barriers. The proposed Project provides for a substantial
increase in housing units in proximity to transit, pedestrian circulation,
and bicycle facilities to provide for multimodal transportation
opportunities and reduce vehicle miles traveled to support a reduction
in GHG emissions.
Leverage Technology Innovations
Promote low emission technologies such as
Not applicable. The Project proposes a housing overlay and does not
neighborhood electric vehicles, shared
propose any actual development or funding of future development.
rides hailing, car sharing, bike sharing
However, the California Building Code would be applicable to all future
and scooters by providing supportive and
projects, which includes requirement for EV charging and other low
safe infrastructure such as dedicated
emission technologies. The Project would not prevent SCAG from
lanes, charging and parking/drop-off
meeting this goal.
space.
Improve access to services through
Not applicable. Issues related to technological improvements are
technology —such as telework and
addressed on a citywide and regional basis. The Project would not
telemedicine as well as other incentives
prevent SCAG from meeting this goal.
such as a "mobility wallet," an app-based
system for storing transit and other multi -
modal payments.
Identify ways to incorporate "micro-
Not applicable. Issues related to "micro -power grids" would be
power grids" in communities, for example
addressed on a citywide and regional basis. All future development
solar energy, hydrogen fuel cell power
proposed as part of the Project would comply with CALGreen/Title 24
storage and power generation.
requirements. The Project would not prevent SCAG from meeting this
goal.
Support Implementation of Sustainability Policies
Pursue funding opportunities to support
Not applicable. The Project proposes a housing overlay and does not
local sustainable development
propose a specific development project or funding of future
implementation projects that reduce
development. The Project would not prevent SCAG from meeting this
greenhouse gas emissions.
goal.
Support statewide legislation that reduces
Consistent. The proposed Project includes a GPA to allow for future
barriers to new construction and that
residential development within an existing commercial center near
incentivizes development near transit
multiple freeways and the OCTA transit system. The proposed mixed -
corridors and stations.
use land uses would reduce VMT by providing housing, retail,
restaurants, and services within the Project site (see Section 5.9,
Transportation).
Support local jurisdictions in the
Not applicable. The Project proposes a housing overlay and does not
establishment of Enhanced Infrastructure
propose any actual development or funding of future development. The
Financing Districts (EIFDs), Community
Project would not prevent SCAG from meeting this goal.
Revitalization and Investment Authorities
(CRIAs), or other tax increment or value
capture tools to finance sustainable
infrastructure and development projects,
including parks and open space.
Work with local jurisdictions/communities
Not applicable. The Project proposes a housing overlay and does not
to identify opportunities and assess
propose any actual development or funding of future development. The
barriers to implement sustainability
Project would not prevent SCAG from meeting this goal.
strategies.
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Enderle Center Rezone
5.4 Land Use and
RTP/SCS Goal, Policy, or Objective
Proposed Project Consistency with Policy
Enhance partnerships with other planning
Consistent. The Project is being proposed pursuant to the certified HEU,
organizations to promote resources and
which was prepared to accommodate the City's Regional Housing
best practices in the SCAG region.
Needs Allocation, as delegated by SCAG. The City will continue to
partner with SCAG and other planning organizations in fulfillment with
City and regional goals.
Continue to support long range planning
Consistent. The Project is being proposed pursuant to the certified HEU,
efforts by local jurisdictions.
which was prepared to accommodate the City's Regional Housing
Needs Allocation, as delegated by SCAG. The City will continue to
partner with SCAG and other planning organizations in fulfillment with
City and regional goals.
Provide educational opportunities to local
Not applicable. The Project proposes a housing overlay in fulfillment of
decisions makers and staff on new tools,
the HEU and does not include oversight or education by SCAG. The
best practices, and policies related to
Project would not prevent SCAG from meeting this goal.
implementing the Sustainable
Communities Strategy.
Promote a Green Region
Support development of local climate
Consistent. The Project is proposed pursuant to the City's HEU. The HEU
adaptation and hazard mitigation plans,
Goal 5 states "Ensure that new housing is sensitive to the existing natural
as well as project implementation that
and built environment." Several policies are included to support this
improves community resiliency to climate
goal, including requirements for sustainable development and energy
change and natural hazards.
conservation. All future projects proposed within the Project site would
be required to comply with the City's goals, policies, and programs.
Additionally, all future development proposed as part of the Project
would comply with CALGreen/Title 24 requirements.
Support local policies for renewable
Consistent. The proposed Project is a land use planning project that
energy production, reduction of urban
includes ODS. All future development would be required to comply with
heat islands and carbon sequestration.
the City's ODS for the site and are required to comply with the
requirement of the California Building Code (CBC) (California Code of
Regulations, Title 24). Implementation of CBC standards and consistency
with ODS would be verified by the City during the plan check and
permitting process for future development within the Project site., as
ensured during the City's plan check.
Integrate local food production into the
Not applicable. This measure is a regional policy and is not applicable
regional landscape.
to urban infill development, such as that proposed by the housing
overlay Project.
Promote more resource efficient
Consistent. The proposed Project is a land use planning project that
development focused on conservation,
includes ODS. All future development would be required to comply with
recycling, and reclamation.
the City's ODS for the site and required to comply with the requirement
of the California Building Code (CBC) (California Code of Regulations,
Title 24). Implementation of CBC standards and consistency with ODS
would be verified by the City during the plan check and permitting
process for future development within the Project site., as ensured during
the City's plan check.
Preserve, enhance, and restore regional
Not applicable. The Project site and surrounding areas are completely
wildlife connectivity.
developed and do not contain biological habitats for which wildlife
connectivity would be an issue.
Reduce consumption of resource areas,
Not applicable. This measure is a regional policy and not related to an
including agricultural land.
urban transit -oriented environment. The Project site does not contain any
resource areas, including agricultural land.
Identify ways to improve access to public
Consistent. The Project proposes a housing overlay and does not
park space.
propose any actual development or funding of future development.
However, as described in Section 5. 8, Recreation, future development
under the Project would be required to provide for adequate
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RTP/SCS Goal, Policy, or Objective Proposed Project Consistency with Policy
recreational spaces or pay in lieu fees consistent with the City's park
space requirements (PPP R-1 ).
Source: Southern California Association of Governments (SCAG) 2020 Connect SoCal Regional Transportation Plan
Sustainable Communities Strategy
As defined under Code Regs. tit. 14 § 15126.2 "the lead agency should normally limit its examination to
changes in the existing physical conditions in the affected area as they exist at the time the notice of
preparation is published". The Notice of Preparation, included as Appendix A to this EIR, was circulated for
public review on February 16, 2024, and set the environmental baseline for the proposed Project. As
described previously, SCAG is required by federal and state law to prepare and update the RTP/SCS
every four years. Connect SoCal, the 2024-2050 RTP/SCS, was approved on April 4, 2024. Although the
2024 RTP/SCS was approved after the environmental baseline was set for the Project, Table 5.4-2 below
lists applicable strategic policies included in the updated RTP/SCS which the proposed Project would be
consistent with. As described above and in Table 5.4-1, the proposed GPA required for the Project would
implement SCAG strategies related to high -density, infill development, and improvement of the job/housing
balance that is centered around public transit opportunities consistent with Connect SoCal Policies.
Table 5.4-2: Project Consistency with 2024 SCAG Connect SoCal Regional Transportation
Plan/Sustainable Communities Strategy Policies
2024 Connect SoCal Strategy Policy
Proposed Project Consistency with Policy
Complete Streets
Support implementation of Complete
Consistent. The Project does not currently propose any development or
Streets demonstrations (including those
roadway improvements. Roadway improvements would be determined
addressing curb space management) to
at the time a development project is proposed, and would coordinate
accommodate and optimize new
with applicable regional, state, and federal transportation parties as
technologies and micromobility devices,
necessary. Future projects under the proposed Project would be
first/last mile connections to transit and
required to comply with the circulation system standards and traffic
last -mile deliveries
control standards specified by the City's latest Standard Plans and
Design Standards as ensured and verified by the City during the plan
check and permitting process, prior to obtaining building permits (PPP
T-1 and T-2).
Support community -led Complete Streets
Not applicable. This is not a project -specific goal and is therefore not
plans and projects, including those that
applicable.
take into account how to mitigate or
adapt to climate change impacts (e.g.,
extreme heat)
Transit and Multimodal Integration
Increase multimodal connectivity (e.g.,
Consistent. The proposed Project includes a GPA to allow for future
first/last mile transit and airport
residential development within an existing commercial center near
connections), which includes planning for
multiple freeways and the OCTA transit system. The Project site is
and developing mobility hubs throughout
located near commercial, retail, and office uses. Additionally, as
the SCAG region
described in Section 5.9, Transportation, the proposed Project is located
near established public transit and would promote an active lifestyle.
Through land use planning, support
Consistent. The proposed Project includes a GPA to allow for future
residential development along high-
residential development within an existing commercial center near
frequency transit corridors and around
multiple freeways and the OCTA transit system. The Project site is
transit/rail facilities and centers
located near commercial, retail, and office uses. Additionally, as
described in Section 5.9, Transportation, the proposed Project is located
near established public transit and would promote an active lifestyle.
Expand the region's networks of bicycle
Consistent. The Project does not currently propose any development or
and pedestrian facilities. This includes
roadway improvements. Roadway improvements would be determined
creating more low stress facilities, such as
at the time a development project is proposed, and would coordinate
with applicable regional, state, and federal transportation parties as
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Enderle Center Rezone Proiect 5.4 Land Use and
2024 Connect SoCal Strategy Policy Proposed Project Consistency with Policy
separated bikeways and bike paths, slow necessary. Future projects under the proposed Project would be
streets, and open streets required to comply with the circulation system standards and traffic
control standards specified by the City's latest Standard Plans and
Design Standards as ensured and verified by the City during the plan
check and permitting process, prior to obtaining building permits (PPP
T-1 and T-2).
Safety
Work with local, state and federal Not applicable. This is not a project -specific goal and is therefore not
partners to advance safer roadways, applicable.
including reduced speeds to achieve zero
deaths and reduce GHGs
Priority Development Areas
Support the development of housing in Consistent. The Regional Housing Needs Assessment (RHNA) is
areas with existing and planned mandated by State Housing Law as part of the periodic process of
infrastructure and availability of updating local housing elements of the General Plan. On November 7,
multimodal options, and where a critical 2019, SCAG's Regional Council voted to approve the Draft RHNA
mass of activity can promote location Methodology. The approved draft methodology allocated RHNA "fair
efficiency share" to various jurisdictions based on several variables, including
access to job and transit (Southern California Association of
Governments, 2020). At the regional level, SCAG planned for future
housing growth with a concentration in areas that have existing and
planned infrastructure and availability of multimodal options through
their "fair share" allocations. The Enderle Center Rezone Project is
proposed to make the GP consistent with the certified 2021-2029
Housing Element, which was prepared to accommodate the City's 6th
Cycle RHNA allocation. Therefore, the Project supports SCAG's regional
efforts to develop housing in existing and planned infrastructure and
availability of multimodal options through implementation of their State
Housing Law responsibilities.
Housing the Region
Provide technical assistance for
Consistent. The Project is being proposed pursuant to the certified HEU,
jurisdictions to complete and implement
which was prepared to accommodate the City's Regional Housing
their housing elements and support local
Needs Allocation, as delegated by SCAG. The City will continue to
governments and Tribal Entities to
partner with SCAG and other planning organizations in fulfillment with
advance housing production
City and regional goals.
Identify and pursue partnerships at the
Not applicable. This is not a project -specific goal and is therefore not
local, regional, state and federal levels to
applicable.
align utility, transit and infrastructure
investments with housing development and
equitable outcomes across the region
Sustainable Development
Research the availability of resources that
Consistent. The Project is proposed pursuant to the City's HEU. The HEU
can support the development of water
Goal 5 states "Ensure that new housing is sensitive to the existing natural
and energy -efficient building practices,
and built environment." Several policies are included to support this
including green infrastructure
goal, including requirements for sustainable development and energy
conservation. All future projects proposed within the Project site would
be required to comply with the City's goals, policies, and programs.
Additionally, all future development proposed as part of the Project
would comply with CALGreen/Title 24 requirements.
Air Quality
Coordinate with local, regional, state and
Consistent. As described in Section 5.1, Air Quality, particulate
federal partners to meet federal and
emissions would mostly be derived from mobile source emissions. Future
development would produce minimal mobile source emissions and would
City of Tustin 5.4-1 9
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.4 Land Use and
2024 Connect SoCal Strategy Policy Proposed Project Consistency with Policy
state ambient air -quality standards and also be required to comply with all relevant State, regional, and local
improve public health regulations and policies for reducing particulate emissions. However,
net new emissions associated with the future development of the
proposed Project would exceed the SCAQMD LSTs for PMio during
operational activities. The majority of the PM10 emissions are associated
with mobile sources from project -related vehicle trips. Although future
development details are unknown, implementation of Mitigation
Measure AQ-1 would require a project -specific assessment of potential
localized impacts for future projects and if future projects exceed the
applicable LST thresholds, a dispersion modeling analysis would be
necessary to calculate health risk from project implementation. In
addition, the Project would be required to comply with SCAQMD
standard conditions, including Rule 403 (Fugitive Dust) to control fugitive
dust and Rule 1 1 13 (Architectural Coatings) to control VOC emissions
from paint. Furthermore, any necessary mitigation would be imposed at
the project level once such future projects are proposed. However, the
Project is conservatively assumed to result in a significant and
unavoidable health risk impact.
Clean Transportation
Support the deployment of clean transit Consistent. The CARB innovative clean technology (ICT) rule requires all
and technologies to reduce greenhouse public transit agencies to gradually reduce fleet vehicle tailpipe
gas emissions as part of the CARB emissions and encourages them to provide innovative first and last -mile
innovative clean technology (ICT) rule connectivity and improved mobility for transit riders. As described in
Section 5.9, Transportation, the proposed Project is located near
established public transit and would promote an active lifestyle. The
Project site is served by OCTA. There are two bus stops within one mile
of the Project site. The nearest OCTA bus stop is located near the Yorba
Street/Enderle Center Drive and 17'" Street intersection, nearly
adjacent to the Project site. Additionally, the Metrolink Inland Empire -
Orange County Line has a stop 1.7 miles east of the Project of the
Project site, at the Santa Ana Metrolink Station. future projects would
be required, if deemed necessary, to fund transit facilities as ensured
and verified by the City during the plan check and permitting process,
prior to obtaining building permits. Additionally, all future development
proposed as part of the Project would comply with CALGreen/Title 24
requirements.
Natural and Agricultural Lands Preservation
Work with implementation agencies to
Consistent. The proposed Project includes a GPA to allow for future
support, establish or supplement voluntary
residential development within an existing commercial center near
regional advance mitigation programs
multiple freeways and the OCTA transit system. The proposed mixed -
(RAMP) for regionally significant
use land uses would reduce VMT by providing housing, retail,
transportation projects to mitigate
restaurants, and services within the Project site. Additionally, the Project
environmental impacts, reduce per -capita
would result in a less than significant impact on VMT (see Section 5.9,
VMT and provide mitigation opportunities
Transportation).
through the Intergovernmental Review
Process
Continue efforts to support partners in
Consistent. The Project site is completely developed and void of natural
identifying priority conservation areas—
topographical features, natural resources and soils. Design requirements
including habitat, wildlife corridors, and
established through ODS for the site would be created to ensure that
natural and agricultural lands —for
future projects are compatible with the surrounding environment and
permanent protection
development by including appropriate landscaping.
Support the integration of nature -based
Consistent. The Project site and surrounding areas are completely
solutions into implementing agency plans
developed and do not contain biological habitats for which wildlife
to address urban heat, organic waste
connectivity would be an issue. Additionally, each future residential
reduction, protection of wetlands, habitat
City of Tustin 5.4-20
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.4 Land Use and
2024 Connect SoCal Strategy Policy
Proposed Project Consistency with Policy
and wildlife corridor restoration,
project implemented as part of the housing overlay and Housing
greenway connectivity and similar efforts
Element would require a project -level plan check.
Climate Resilience
Develop partnerships and programs to
Not applicable. This is not a project -specific goal and is therefore not
support local and regional climate
applicable.
adaptation, mitigation and resilience
initiatives
Collaborate with partners to foster
Consistent. Future projects would be required to implement
adoption of systems and technologies that
landscaping and water conserving appliances pursuant to Section 9701
can reduce water demand and/or
of Article 9, Chapter 7 of the City of Tustin Municipal Code. Compliance
increase water supply, such as alternative
would be reviewed by the city during the permitting process.
groundwater recharge technologies,
Additionally, development and construction of the Project site would
stormwater capture systems, urban
require preparation and adherence to SWPPP and WQMP. Therefore,
cooling infrastructure and greywater
development of the site would not deplete or pollute groundwater
usage systems
resources. Additionally, all future development proposed as part of the
Project would comply with CALGreen/Title 24 requirements.
Workforce Development
Provide technical assistance to help local
Not applicable. This is not a project -specific goal and is therefore not
jurisdictions realize their economic and
applicable.
workforce -development goals
Encourage the growth of, and equitable
Consistent. The Project anticipates the future nonresidential capacity
access to, living -wage jobs throughout the
buildout of 118,474 SF within a portion of the Project site that allows
region
non-residential development. As described in Section 5.6, Population
and Housing, using employment generation rates from the 2001 SCAG
Employment Density Report, buildout of the 118,474 SF of
nonresidential space would result in approximately 365 employees (1
employee per 325 SF).
Source: Southern California Association of Governments (SCAG) 2024 Connect SoCal Regional Transportation Plan
Sustainable Communities Strategy
General Plan and Zoning Code
General Plan Land Use Designation. The Project site currently has a GP Land Use designation of Planned
Community Commercial/Business (PCCB). The GP Land Use Element states that the PCCB land use designation
provides opportunities for a mixture of all those activities permitted within the Community Commercial,
Professional Office, and Industrial land use designations. The PCCB designation may also permit other uses
(such as residential uses) which support this land use designation. The standard intensity of development is a
floor area ratio of 0.4:1 and the maximum intensity of development is a floor area ratio of 1.5:1. The overall
population density range for residential use within the PCCB designation is 2 to 54 persons per acre.
During the Housing Element process, the City identified the Enderle Center as a suitable commercial site for
rezoning to allow mixed -use development, which introduced the opportunity to allow higher density housing
in either horizontal or vertical mixed -use development on the site. The City's certified 2021-2029 Housing
Element identified the Enderle Center as having capacity for 413 housing units. The proposed Project would
implement the City's land use designation for the Project site by proposing a new overlay zone ("overlay
district"). This would be accomplished with a Housing Overlay (HO). To accommodate this, a General Plan
Amendment (GPA) is needed to establish that higher density residential uses are allowed in the Planned
Community Commercial Business (PCCB) land use designation when prescribed by a Housing Overlay (HO)
district or a Specific Plan (SP); a Zoning Code Amendment (ZCA) to establish the Housing Overlay District
(overlay zone) in conjunction with the Planned Community Commercial Districts (base zone); and a Zone
Change (ZC) that amends the City's zoning map to apply a Housing Overlay ("HO") District to the Project
site. Upon approval of the HO, the Project site could accommodate 413 units over approximately 7 acres
City of Tustin 5.4-21
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.4 Land Use and
of developable land within the existing 11.8-acre shopping center. This would result in a density of 59
du/ac. The anticipated development density was determined through the Housing Element process and is a
conservative estimate based on development trends in nearby communities. Therefore, with approval of the
GPA, the Project would bring the Land Use Element of the City General Plan into consistency with the HEU.
Additionally, the anticipated development does not rely on the demolition of any existing building, but rather
focuses on areas used for surface parking. The proposed Project would still be consistent with the current
zoning designation for the site while allowing for the development of housing as well. Thus, the proposed
Project would implement, and would not conflict with, the GP land use designation or the current zoning
designation for the site.
Land Use Consistency. As shown on Figure 3-4, Existing General Plan Land Use, and in Table 3-1, Surrounding
Existing Land Use and Zoning Designations, in Section 3.0, Project Description, the area located directly east
of the Project site, and northeast, is also designated as PCCB. The land uses north of the Project site located
across 171h Street are designated Community Commercial (CC) and the land uses south of the Project site
are designated Planned Community residential (PCR). The areas surrounding the Project site are developed
with residential, service, office, and commercial uses. Development of the site for mixed -use development
would integrate into the adjacent areas. The proposed Project would provide housing proximate to local
employment centers, commercial retail services and restaurants for onsite residents and employees working
nearby. No specific development is proposed as part of the Project; however, all future residential
development proposed within the Project site would be subject to the requirement and provisions of the
applicable Objective Design Standards (ODS). Design requirements established through ODS for the site
would be created to ensure compatibility with the existing development as well as surrounding land uses. All
future development would be required to comply with the City's ODS for the site.
Overall, the proposed Project would not result in a land use inconsistency. The proposed Project would allow
for a mix of uses, including residential, and would provide locational efficiency as it allows people to work,
live, and obtain services within a small area, which has the potential to reduce VMT in comparison to
residential development that is farther from employment and services. As described throughout this EIR, with
implementation of existing regulations, the proposed Project would not result in significant environmental
impacts such as light, noise, or air quality to the adjacent existing and planned land uses. Therefore, impacts
related to land use inconsistency would be less than significant.
GP Goals, Policies, and Objectives: The provision of residential development within the Project site was not
previously analyzed under existing land use plans. A detailed analysis of the proposed Project's consistency
with the applicable goals, policies, and objectives of the City's GP that serve to avoid or mitigate
environmental impacts is provided in Table 5.4-3 below. As described, the proposed Project would be
consistent with the relevant goals, policies, and objectives of the City's GP that avoid or mitigate
environmental impacts, and impacts related to conflict with a GP policy related to an environmental effect
would be less than significant.
Table 5.4-3: Project Consistency with Relevant General Plan Goals, Policies, and Objectives
General Plan Update Goal, Policy, or Objective Project Consistency
Land Use Element
Goal 1: Provide for a well-balanced land use pattern Consistent. The proposed Project would introduce
that accommodates existing and future needs for residential land uses to an existing commercial site.
housing, commercial and industrial land, open space and During the Housing Element process, the City identified
community facilities and services, while maintaining a the Enderle Center as a suitable commercial site for
healthy, diversified economy adequate to provide future rezoning to allow mixed -use development, which
City services. introduced the opportunity to allow higher density
housing in either horizontal or vertical mixed -use
development on the site. Additionally, the Project site is
City of Tustin 5.4-22
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
envisioned to function as a mixed -use site. A portion of
the Project site would remain as nonresidential land use,
providing a well -balance mix of residential and
commercial land uses. Thus, the proposed Project would
be consistent with Goal 1.
Policy 1.1: Preserve the low -density quality of Tustin's
Consistent. Development of the proposed Project would
existing single-family neighborhoods while permitting
allow higher density housing to be constructed on the
compatible multi -family development to meet regional
Project site. The anticipated development would occur
housing needs where best suited from the standpoint of
over 7 acres of underutilized asphalt parking lot areas
current development, accessibility, transportation and
adjacent to commercial, residential, and office uses as
public facilities.
well as SR 55. Thus, the proposed Project would be
consistent with Policy 1.1.
Policy 1.2: Provide for and encourage the development
Consistent. The proposed Project would implement a mix
of neighborhood -serving commercial uses in areas of
of uses, including commercial and residential, and would
Tustin presently underserved by such uses. Encourage the
provide locational efficiency as it allows people to work,
integration of retail or service commercial uses on the
live, and obtain services within a small area in
street level of office projects.
comparison to residential development that is farther
from employment and services. The Project anticipates
the future additional nonresidential buildout of 1 18,474
SF, or a total nonresidential development capacity of
205,610 SF for the Project site. Thus, the proposed
Project would be consistent with Policy 1.2.
Policy 1.6: Ensure an adequate supply of commercial
Consistent. The proposed Project anticipates the future
and industrial land within the City of Tustin for potential
nonresidential capacity buildout of 118,474 SF, or a
commercial and industrial expansion and development.
total nonresidential development capacity of 205,610
SF for the Project site. Based on market demand and
conditions, future development of commercial uses would
be constructed once a project is proposed. Thus, the
proposed Project would be consistent with Policy 1.6.
Policy 1.7: As part of the City's attraction to business and
Consistent. The proposed Project would implement a mix
industry, provide adequate sites to house future
of uses, including commercial and residential, and would
employees.
provide locational efficiency as it allows people to work,
live, and obtain services within a small area in
comparison to residential development that is farther
from employment and services. Thus, the proposed
Project would be consistent with Policy 1.7.
Policy 1.10: Ensure that the distribution and intensity of
Consistent. The proposed Project would include a GPA
land uses are consistent with the Land Use Plan and
and rezone of the Project site with a Housing Overlay
classification system.
District to allow for future development of up to 413
housing units, consistent with the City's certified 2021-
2029 Housing Element. Future residential development
would be within the boundaries of the existing Project
site and would be subject to ODS. Thus, the proposed
Project would be consistent with Policy 1.10.
Policy 1.11: Where feasible, increase the amount and
Consistent. As described in Section 5.8, Recreation,
network of public and private open space and
future implementation of development projects would be
recreational facilities which will be adequate in size and
required to determine their fair share of park facilities
location to be useable for active or passive recreation as
and either provide adequate park facilities or pay in
well as for visual relief.
lieu fees in accordance with Tustin City Code Section
9331 (PPP R-1). Thus, the proposed Project would be
consistent with Policy 1.1 1.
Goal 2: Ensure that future land use decisions are the
Consistent. The proposed Project would provide new
result of sound and comprehensive planning
residential development to an existing commercial land
use that would be compatible with the adjacent
City of Tustin 5.4-23
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Policy 2.1: Consider all General Plan goals and policies,
including those in other General Plan elements, in
evaluating proposed development projects for General
Plan consistency.
Goal 3: Ensure that new development is compatible with
surrounding land uses in the community, the City's
circulation network, availability of public facilities,
existing development constraints and the City's unique
characteristics and resources
Policy 3.7: Encourage the preservation and
enhancement of public vistas, particularly those seen
from public places.
Goal 4: Assure a safe, healthy and aesthetically pleasing
community for residents and businesses.
Policy 4.1: Mitigate traffic congestion and unacceptable
levels of noise, odors, dust and light and glare which
affect residential areas and sensitive receptors.
Policy 4.2: Ensure a sensitive transition between
commercial or industrial uses and residential uses by
means of such techniques as buffering, landscaping and
setbacks.
City of Tustin
Draft EIR
June 2024
Project Consistency
residential, commercial, and office land uses. Thus, the
proposed Project is consistent with Goal 2.
Consistent. This Table (Table 5.4-3) analyzes the
proposed Project's consistency with all GP element goals
and policies and finds no conflict. Thus, the proposed
Project is consistent with Policy 2.1.
Consistent. The proposed Project would provide new
residential development to an existing commercial land
use adjacent to existing residential, commercial, and
office land uses that would be compatible. As described
in section 5.7, Public Services, the proposed Project would
not result in public facility and service deficiencies.
Additionally, as described in the IS/NOP (Appendix A)
the proposed Project would be consistent with the City's
unique visual character. As described in Section 5.9,
Transportation, the proposed Project would not conflict
with the circulation network. Thus, the proposed Project is
consistent with Goal 3.
Consistent. As described in the IS/NOP (Appendix A),
future residential development would be within the
boundaries of the existing Enderle Center site and would
not impede any existing views of Peters Canyon
Ridgeline from 17'h Street. The provision for residential
development in an area formerly designated for
nonresidential land uses would not further diminish the
view of a scenic vista. Thus, the proposed Project is
consistent with Policy 3.7.
Consistent. The ODS would ensure high visual character
and quality of future residential development proposed
within the Project site. Additionally, each future
residential project implemented as part of the housing
overlay and Housing Element would require a project -
level plan check. Thus, the proposed Project would be
consistent with Goal 4.
Consistent. An Air Quality Report and Noise Report
were completed for the Project. Construction and
operational impacts related to odors and dust would be
less than significant with implementation of standard best
practices required through permits and agency
regulations, as discussed in Section 5.1, Air Quality, of
this EIR. Project impacts to light and glare would also be
less than significant as determined by the Initial Study
(Appendix A). Construction noise impacts would be less
than significant as discussed in Section 5.5, Noise.
Therefore, the Project would be consistent with Policy 4.1.
Consistent. Structures within the Enderle Center do not
currently have a maximum height limit or required
setback distances and site designs are evaluated on a
project -by -project basis due to the site's designation as
PC COM. Design requirements established through ODS
for the site would be created to ensure compatibility with
the surrounding land uses. The ODS would also ensure
high visual character and quality of future residential
development proposed within the Project site. All future
development would be required to comply with the City's
5.4-24
Enderle Center Rezone Proiect 5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Policy 4.3: Where mixed uses are permitted, ensure
compatible integration of adjacent uses to minimize
conflicts.
Goal 6: Improve urban design in Tustin to ensure
development that is both architecturally and functionally
compatible, and to create uniquely identifiable
neighborhoods, commercial and business park districts.
Policy 6.2: Encourage and promote high quality design
and physical appearance in all development projects.
Policy 6.4: Preserve and enhance the City's special
residential character and "small town" quality by
encouraging and maintaining Tustin's low density
residential neighborhoods through enforcement of
existing land use and property development standards
and the harmonious blending of buildings and landscape.
Policy 6.9: Upgrade the visual quality of edge
conditions between industrial and residential uses
through street tree planting and on -site landscaping.
Policy 6.12: Review and revise, as necessary, the City's
development standards to improve the quality of new
development in the City and to protect the public health
and safety.
Project Consistency
ODS for the site. Thus, the proposed Project would be
consistent with Policy 4.2.
Consistent. Design requirements established through
ODS for the site would be created to ensure
compatibility with the existing site development and
surrounding land uses. Thus, the proposed Project would
be consistent with Policy 4.3.
Consistent. Design requirements established through
ODS for the site would be created to ensure
compatibility with the existing site development and
surrounding land uses, such as compatible building
height, cohesive architectural style, and appropriate
landscaping. Thus, the proposed Project would be
consistent with Goal 6.
Consistent. Design requirements established through
ODS for the site would be created to ensure
compatibility with the existing site development and
surrounding land uses, such as compatible building
height, cohesive architectural style, and appropriate
landscaping. The ODS would ensure high visual character
and quality of future residential development proposed
within the Project site. All future development would be
required to comply with the City's ODS for the site. Thus,
the proposed Project would be consistent with Policy 6.2.
Consistent. Design requirements established through
ODS for the site would be created to ensure
compatibility with the existing site development and
surrounding land uses, such as compatible building
height, cohesive architectural style, and appropriate
landscaping. The ODS would ensure high visual character
and quality of future residential development proposed
within the Project site. All future development would be
required to comply with the City's ODS for the site. Thus,
the proposed Project would be consistent with Policy 6.4.
Consistent. Design requirements established through
ODS for the site would be created to ensure
compatibility with the existing site development and
surrounding land uses, such as compatible building
height, cohesive architectural style, and appropriate
landscaping. The ODS would ensure high visual character
and quality of future residential development proposed
within the Project site. All future development would be
required to comply with the City's ODS for the site. Thus,
the proposed Project would be consistent with Policy 6.9.
Consistent. The proposed Project would include a GPA
and rezone of the Project site with a Housing Overlay
District that would allow for future development of up to
413 housing units, consistent with the City's certified
2021-2029 Housing Element. Additionally, design
requirements established through ODS for the site would
be created to ensure compatibility with the existing site
development and surrounding land uses, such as
compatible building height, cohesive architectural style,
and appropriate landscaping. The ODS would ensure
high visual character and quality of future residential
City of Tustin 5.4-25
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.4 Land Use and
General Plan Update Goal, Policy, or Objective Project Consistency
development proposed within the Project site. All future
development would be required to comply with the City's
ODS for the site. Thus, the proposed Project would be
consistent with Policy 6.12.
Goal 8: Ensure that necessary public facilities and Consistent. As described in Section 5.7, Public Services,
services should be available to accommodate adequate public facilities and services are available to
development proposed on the Land Use Policy Map. support the proposed Project. Thus, the proposed Project
would be consistent with Goal 8. Additionally, as ensured
during the City's plan check, future subdivision projects
would be required to pay development impact fees
(DIFs) as needed.
Policy 8.1: Encourage within economic capabilities, a
wide range of accessible public facilities and community
services including fire and police protection, flood control
and drainage, educational, cultural and recreational
opportunities and other governmental and municipal
services. Senate Bill (SB) 50, adopted in 1998, prohibits
the City from using the inadequacy of school facilities as
a basis for denying or conditioning the development of
property. SB 50, however, gave school districts new
authority to raise school impact mitigation fees. In
addition, the voters passed Proposition 1 A in November
1998, which provides $9.2 billion dollars in bonds to
construct new or expand existing schools. In summary,
school districts have the financial means and legal
authority to respond to new development
Policy 8.7: To ensure an orderly extension of essential
services and facilities, and preservation of a free -
flowing circulation system, continue to require provision
of essential facilities and services at the developer's
expense where these systems do not exist or are not
already part of the City's financed capital improvement
program.
Consistent. As described in Section 5.7, Public Services,
adequate public facilities and services are available to
support the proposed Project. Thus, the proposed Project
would be consistent with Policy 8.1. Additionally, as
ensured during the City's plan check, future subdivision
projects would be required to pay DIFs, such as school
district fees, as needed.
Consistent. As described in Section 5.7, Public Services,
adequate public facilities, and services are available to
support the proposed Project. At the time development
projects are proposed, appropriate impact fees and
necessary coordination with agencies and utility
providers would occur to ensure essential services and
utilities are supplied to future residents and businesses
Additionally, a TIA was prepared as part of this Project
and will be assessed by the City to determine necessary
future improvements. The TIA would be available upon
request from the City of Tustin. Future development
would be responsible for implementing identified
improvements. Thus, the proposed Project would be
consistent with Policy 8.7.
Policy 8.8: Maintain and improve, where necessary, the Not Applicable. This is not a project -specific policy and
City's infrastructure and facilities. is therefore not applicable.
Goal 9: Continue to provide for a planned community in Not Applicable. This is not a project -specific goal and is
East Tustin compatible with the land use characteristics of therefore not applicable.
the local area and sensitive to the natural environment.
Policy 9.6: Retain natural landscape to the maximum Consistent. Design requirements established through
extent possible, and incorporate planting in new ODS for the site would be created to ensure that future
development areas compatible with the character and projects are compatible with the surrounding environment
quality of the natural surrounding environment and development by including appropriate landscaping.
Thus, the proposed Project would be consistent with Policy
9.6.
Housing Element
Goal 1: Provision of an adequate supply of housing to Consistent. During the Housing Element process, the City
meet the need for a variety of housing types and the identified the Enderle Center as a suitable commercial
City of Tustin 5.4-26
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
diverse socio-economic needs of all community residents
site for rezoning to allow mixed -use development, which
commensurate with the City's identified housing needs in
introduced the opportunity to allow higher density
the RHNA allocation.
housing in either horizontal or vertical mixed -use
development on the site. The Project would include a
GPA and rezone of the Project site with a Housing
Overlay District to allow for future development of up to
413 housing units, consistent with the City's certified
2021 -2029 Housing Element. Thus, the proposed Project
would be consistent with Goal 1.
Policy 1.1: Provide site opportunities inventory of vacant
Consistent. During the Housing Element process, the City
and underutilized land for development of housing that
identified the Enderle Center as a suitable commercial
responds to diverse community needs in terms of housing
site for rezoning to allow mixed -use development, which
type, cost and location, emphasizing locations near
introduced the opportunity to allow higher density
services and transit.
housing in either horizontal or vertical mixed -use
development on the site. The anticipated development
would occur over 7 acres of underutilized asphalt
parking lot areas adjacent to commercial, residential,
and offices use as well as SR 55. Thus, the proposed
Project would be consistent with Policy 1.1.
Policy 1.4: Initiate development permit and zoning code
Consistent. The Project would include a GPA and rezone
streamlining strategies to encourage and expedite
of the Project site with a Housing Overlay District to allow
residential development (i.e. accessory dwelling units,
for future development of up to 413 housing units,
affordable housing units, and investments in existing
consistent with the City's certified 2021-2029 Housing
buildings) to reduce and eliminate regulatory barriers.
Element. Per Housing Element Program 1.2a, the City will
develop ODS to ensure high quality residential
development, while simultaneously meeting the City's
goal of streamlining residential development to meet its
RHNA goals. Thus, the proposed Project would be
consistent with Policy 1.4.
Policy 1.5: Encourage infill development or site
Consistent. During the Housing Element process, the City
redevelopment within feasible development sites for
identified the Enderle Center as a suitable commercial
homeownership and rental units through the
site for rezoning to allow mixed -use development, which
implementation of smart growth principles, allowing for
introduced the opportunity to allow higher density
the construction of higher density housing, affordable
housing in either horizontal or vertical mixed -use
housing, and mixed -use development (the vertical and
development on the site. Development of the proposed
horizontal integration of commercial and residential uses)
Project would allow higher density housing to be
in proximity to employment opportunities, community
constructed on the Project site. The anticipated
facilities and services, and amenities.
development would occur over 7 acres of underutilized
asphalt parking lot areas adjacent to commercial,
residential, and office uses as well as SR 55. Thus, the
proposed Project would be consistent with Policy 1.5.
Goal 2: Promote fair housing opportunities for all people
Not Applicable. This is not a project -specific goal and
regardless of their special characteristics as protected
is therefore not applicable.
under state and federal fair housing laws.
Policy 2.3: Promote the dispersion and integration of
Consistent. During the Housing Element process, the City
housing for low- and very -low income families throughout
identified The Enderle Center as a suitable site to allow
the community.
mixed -use development, which introduced the
opportunity to allow higher density housing. The Project
would include a housing overlay on the Project site to
allow for future development of up to 413 housing units,
consistent with the City's certified 2021-2029 Housing
Element. The allowed densities under this Project would
provide for a variety of housing types and diverse socio-
economic needs. Thus, the proposed Project would be
consistent with Policy 2.3.
City of Tustin 5.4-27
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
Policy 2.6: Promote fair housing opportunities by
Not Applicable. This is not a Project -specific policy and
supporting the continuation of policies that require
is therefore not applicable.
relocation assistance, and/or to provide incentives and
assistance for purchase of the units by low- and
moderate -income households.
Goal 5: Ensure that new housing is sensitive to the existing
Consistent. The ODS would ensure high visual character
natural and built environment.
and quality of future residential development proposed
within the Project site. Additionally, each future
residential project implemented as part of the housing
overlay and Housing Element would require a project -
level plan check. Thus, the proposed Project would be
consistent with Goal 5.
Policy 5.1: Prioritize sustainable housing developments
Consistent. The Project site is located near commercial,
in proximity to services and employment centers thereby
retail, and office uses. Additionally, as described in
enabling the use of public transit, walking or bicycling
Section 5.9, Transportation, the proposed Project is
and promoting an active lifestyle.
located near established public transit and would
promote an active lifestyle. Thus, the proposed Project
would be consistent with Policy 5.1.
Policy 5.2: Promote green building practices for more
Consistent. As described in Section 5.2, Energy, future
sustainable energy conservation measures in the
development under the proposed Project would be
construction of new housing or rehabilitated units.
required to adhere to State and local regulations
regarding green building and sustainable practices such
as Title 24. Thus, the proposed Project would be
consistent with Policy 5.2.
Circulation Element
Goal 1: Preserve the low -density quality of Tustin's
existing single-family neighborhoods while permitting
compatible multi -family development to meet regional
housing needs where best suited from the standpoint of
current development, accessibility, transportation and
public facilities.
Policy 1.2: Develop and implement circulation system
standards for roadway and intersection classifications,
right-of-way width, pavement width, design speed,
warrant requirements, capacity, maximum grades and
associated features such as medians and bicycle lanes or
trails that are adjacent or off -road.
Policy 1.3: Coordinate roadway improvements with
applicable regional, state and federal transportation
plans and proposals.
Consistent. Development of the proposed Project would
allow higher density housing to be constructed on the
Project site. The anticipated development would occur
over 7 acres of underutilized asphalt parking lot areas
adjacent to commercial, residential, and office uses as
well as SR 55. Thus, the proposed Project would be
consistent with Goal 1 .
Consistent. Future projects under the proposed Project
would be required to comply with the circulation system
standards and traffic control standards specified by the
City's latest Standard Plans and Design Standards as
ensured and verified by the City during the plan check
and permitting process, prior to obtaining building
permits (PPP T-1 and T-2). Thus, the proposed Project
would be consistent with Policy 1.2.
Consistent. The Project does not currently propose any
development or roadway improvements. Roadway
improvements would be determined at the time a
development project is proposed, and would coordinate
with applicable regional, state, and federal
transportation parties as necessary. Future projects
under the proposed Project would be required to comply
with the circulation system standards and traffic control
standards specified by the City's latest Standard Plans
and Design Standards as ensured and verified by the City
during the plan check and permitting process, prior to
obtaining building permits (PPP T-1 and T-2). Thus, the
proposed Project would be consistent with Policy 1.3.
City of Tustin 5.4-28
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
Policy 1.4: Develop and implement thresholds and
Consistent. As described in Section 5.7, Public Services,
performance standards for acceptable levels of service.
adequate public facilities, and services are available to
support the proposed Project. At the time development
projects are proposed, appropriate impact fees and
necessary coordination with agencies and utility
providers would occur to ensure essential services and
utilities are supplied to future residents and businesses
Additionally, a TIA was prepared as part of this Project
and will be assessed by the City to determine necessary
future improvements. Future development would be
responsible for implementing identified improvements.
Thus, the proposed Project would be consistent with Policy
1.4.
Policy 1.10: Require that proposals for major new
Consistent. A TIA was prepared as part of this Project
developments include a future traffic impact analysis
and will be assessed by the City to determine necessary
which identifies measures to mitigate any identified
future improvements. Future development would be
project impacts.
responsible for implementing identified improvements.
Future major development under the proposed Project
would require preparation of a project -specific TIA to
identify project -specific impacts. Thus, the proposed
Project would be consistent with Policy 1.10.
Policy 1.11: Encourage new development which
Consistent. The proposed Project includes a GPA to
facilitates transit services, provides for non -vehicular
create a Housing Overlay to allow for future residential
circulation and minimizes vehicle miles traveled.
development within an existing commercial center near
multiple freeways and the OCTA transit system. The
proposed mixed -use land uses would reduce VMT by
providing housing, retail, restaurants, and services within
the Project site.
Policy 1.13: Minimize effects of transportation noise
Consistent. As discussed in Section 5.5, Noise, the Project
wherever possible so as to comply with the Noise
would result in a less than significant impact regarding
Element.
traffic noise. Future development under the proposed
Project would be required to ensure consistency with the
Project's noise analysis, and if inconsistent, would be
required to prepare a separate project -specific noise
analysis. A Final Acoustical Report would be required to
confirm the noise level exposure from stationary sources
to off -site sensitive land uses and to identify any specific
mitigation measures necessary to achieve an exterior
noise level below the City's noise standards. Consistency
with the approved Project would be determined during
City plan check.
Policy 1.15: Ensure construction of existing roadways to
Consistent. Future projects under the proposed Project
planned widths, as new developments are constructed.
would be required to comply with the circulation system
standards and traffic control standards specified by the
City's latest Standard Plans and Design Standards as
ensured and verified by the City during the plan check
and permitting process, prior to obtaining building
permits (PPP T-1 and T-2). Thus, the proposed Project
would be consistent with Policy 1.15.
Policy 1.16: Continue to require dedication of right -of-
Consistent. Future projects would be required to pay
way and construction of required public improvements on
their fair share of public improvements, comply with the
streets adjacent to construction projects at the
circulation system standards, and traffic control
developer's expense.
standards specified by the City's latest Standard Plans
and Design Standard, as ensured by the city during plan
check and prior to acquiring building permits (PPP T-1
City of Tustin 5.4-29
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
and T-2). Thus, the proposed Project would be consistent
with Policy 1.2. Thus, the proposed Project would be
consistent with Policy 1.1 6.
Goal 5: Support development of a public transportation
Not applicable. This Project does not include the
system that provides mobility to all City inhabitants and
development of public transit.
encourages use of public transportation as an alternative
to automobile travel.
Policy 5.2: Require new development to fund transit
Consistent. Future projects would be required, if
facilities, such as bus shelters and turn -outs, where
deemed necessary, to fund transit facilities as ensured
deemed necessary to meet public needs arising in
and verified by the City during the plan check and
conjunction with development.
permitting process, prior to obtaining building permits.
Thus, the proposed Project would be consistent with Policy
5.2.
Policy 5.5: Promote new development that is designed
Consistent. The proposed Project would allow for a mix
in a manner which facilitates provision or expansion of
of uses, including residential, and would provide
transit service and provides non -automobile circulation
locational efficiency as it allows people to work, live, and
within the development.
obtain services within a small area, which has the
potential to reduce VMT in comparison to residential
development that is farther from employment and
services. Thus, the proposed Project would be consistent
with Policy 5.5.
Goal 6: Increase the use of non -motorized modes of
Not Applicable. This is not a project -specific goal and is
transportation.
therefore not applicable.
Policy 6.1: Promote the safety of pedestrians and
Consistent. Future projects under the proposed Project
bicyclists by adhering to uniform standards and
would be required to comply with the circulation system
practices, including designation of bicycle lanes, off-
standards and traffic control standards specified by the
road bicycle trails, proper signage, and adequate
City's latest Standard Plans and Design Standards as
sidewalk, bicycle lane, and off -road bicycle trail widths.
ensured and verified by the City during the plan check
and permitting process, prior to obtaining building
permits (PPP T-1 and T-2). No specific development is
proposed at this time. Thus, the proposed Project would
be consistent with Policy 6.1.
Policy 6.2: Maintain existing pedestrian facilities and
Consistent. The Project would allow for future infill
require new development to provide pedestrian
development. Future development would utilize existing
walkways between developments, schools and public
sidewalks and potential future improvements would be
facilities.
made at the time projects are proposed. Thus, the
proposed Project would be consistent with Policy 6.2.
Policy 6.8: Support retrofit installation of sidewalks in
Not Applicable. The Project site is within an existing
industrial districts and Planned Community Business Parks
commercially developed area.
as development occurs.
Policy 6.14: Require new development to dedicate land
Not Applicable. This is not a project -specific goal, but a
and fund improvement of bicycle, pedestrian and
City initiative, and is therefore not applicable.
equestrian facilities, where deemed necessary to meet
public needs arising in conjunction with development.
Goal 7: Provide for well -designed and convenient
Consistent. Future projects under the proposed Project
parking facilities.
would be required to comply with the circulation system
standards and traffic control standards specified by the
City's latest Standard Plans and Design Standards as
ensured and verified by the City during the plan check
and permitting process, prior to obtaining building
permits (PPP T-1 and T-2). No specific development is
proposed at this time. Thus, the proposed Project would
be consistent with Goal 7.
City of Tustin 5.4-30
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
Policy 7.1: Consolidate parking, where appropriate, to
Consistent. Future projects under the proposed Project
eliminate the number of ingress and egress points onto
would be required to comply with the circulation system
arterials.
standards and traffic control standards specified by the
City's latest Standard Plans and Design Standards as
ensured and verified by the City during the plan check
and permitting process, prior to obtaining building
permits (PPP T-1 and T-2). No specific development is
proposed at this time. Thus, the proposed Project would
be consistent with Policy 7.1.
Policy 7.2: Provide sufficient off-street parking for all
Consistent. Future projects under the proposed Project
land uses
would be required to comply with the circulation system
standards and traffic control standards specified by the
City's latest Standard Plans and Design Standards as
ensured and verified by the City during the plan check
and permitting process, prior to obtaining building
permits (PPP T-1 and T-2). No specific development is
proposed at this time. Thus, the proposed Project would
be consistent with Policy 7.2.
Conservation, Open Space, and Recreation Element
Goal 1: Reduce air pollution through proper land use, Consistent. As described in section 5.2, Energy, future
transportation and energy use planning. development under the proposed Project would be
required to adhere to State and local regulations
regarding green building and sustainable practices such
as Title 24, as ensured and verified by the City during
the plan check and permitting process. Additionally,
future residential development within the existing
commercial center near multiple freeways and the OCTA
transit system would reduce VMT by providing housing,
retail, restaurants, and services within the Project sit
leading to reduced mobile -source emissions and energy
demand. Thus, the proposed Project would be consistent
with Goal 1.
Policy 1.1: Cooperate with the South Coast Air Quality Not Applicable. This is not a project -specific goal, but a
Management District and the Southern California City initiative, and is therefore not applicable.
Association of Governments in their effort to implement
provisions of the region's Air Quality Management Plan,
as amended.
Policy 1.3: Locate multiple family developments close to Consistent. The Project site is envisioned to function as a
commercial areas to encourage pedestrian rather than mixed -use site. The Enderle Center is currently
vehicular travel. developed with 87,136 SF of commercial business uses,
including 28,750 SF of restaurant use, 39,960 SF of
retail and service use, and 18,426 SF of office use. Upon
approval of the Housing Overlay District, the Project site
could accommodate 413 units over approximately 7
acres of developable land within the existing 1 1.8-acre
site. The Project anticipates the future additional
nonresidential buildout of 118,474 SF, or a total
nonresidential development capacity of 205,610 SF for
the Project site. Thus, the Project would accommodate
anticipated residential growth, and would increase
amenities, such as parks, provide connectivity to
surrounding neighborhoods, and increase walkability
and minimize VMT. The proposed Project would be
consistent with Policy 1.3.
City of Tustin 5.4-31
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
Policy 1.4: Develop neighborhood parks near
Consistent. As described in Section 5.8, Recreation,
concentrations of residents to encourage pedestrian
future implementation of development projects would be
travel to the recreation facilities.
required to determine their fair share of park facilities
and either provide adequate park facilities or pay in
lieu fees in accordance with Tustin City Code Section
9331 (PPP R-1). Thus, the proposed Project would be
consistent with Policy 1.4.
Policy 1.6: Cooperate and participate in regional air
Not Applicable. This is not a project -specific goal, but a
quality management plans, programs, and enforcement
City initiative, and is therefore not applicable.
measures.
Goal 2: Improve air quality by influencing transportation
Not Applicable. This is not a project -specific goal and
choices of mode, time of day, or whether to travel and
is therefore not applicable.
to establish a jobs/housing balance.
Policy 2.1: Reduce vehicle trips through incentives,
Consistent. As described in Section 5.9, Transportation,
regulations and/or Transportation Demand
the entire Project can be assumed to have a less than
Management (TDM) programs.
significant VMT impact, including both the commercial
and residential land uses in both the current and future
conditions. Thus, the proposed Project would be consistent
with Policy 2.1.
Policy 2.2: Reduce total vehicle miles traveled (VMT)
Consistent. As described in Section 5.9, Transportation,
through incentives, regulations and/or Transportation
the entire Project can be assumed to have a less than
Demand Management.
significant VMT impact, including both the commercial
and residential land uses in both the current and future
conditions. Additionally, future development of the
existing commercial center to accommodate anticipated
residential growth would provide connectivity to
surrounding neighborhoods, and increase walkability
and minimize VMT. Thus, the proposed Project would be
consistent with Policy 2.2.
Policy 2.12: Implement land use policy contained in the
Not Applicable. This is not a project -specific goal and
Land Use Element toward the end of achieving
is therefore not applicable.
jobs/housing balance goals.
Goal 3: Reduce particulate emissions to the greatest
Consistent. As described in Section 5.1, Air Quality,
extent feasible.
particulate emissions would mostly be derived from
mobile source emissions. Future development would
produce minimal mobile source emissions and would also
be required to comply with all relevant State, regional,
and local regulations and policies for reducing
particulate emissions. Thus, the proposed Project would
be consistent with Goal 3.
Policy 3.1: Adopt incentives, regulations, and/or
Not Applicable. This is not a project -specific goal, but a
procedures to minimize particulate emissions from paved
City initiative, and is therefore not applicable.
and unpaved roads, agricultural uses, parking lots, and
building construction.
Goal 4: Reduce emissions through reduced energy
Consistent. As described in Section 5.2, Energy, future
consumption.
development under the proposed Project would be
required to adhere to State and local regulations
regarding green building and sustainable practices such
as Title 24, as ensured and verified by the City during
the plan check and permitting process. Thus, the
proposed Project would be consistent with Goal 4.
Policy 4.1: Promote energy conservation in all sectors of
Consistent. As described in Section 5.2, Energy, future
the City including residential, commercial, and industrial.
development under the proposed Project would be
City of Tustin 5.4-32
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
required to adhere to State and local regulations
regarding green building and sustainable practices such
as Title 24, as ensured and verified by the City during
the plan check and permitting process. Thus, the
proposed Project would be consistent with Policy 4.1.
Goal 5: Protect water quality and conserve water
Consistent. As described in the IS/NOP in Section 5.10,
supply.
Hydrology and Water Quality (see Appendix A),
construction of future development facilitated by the
Project would be required to obtain coverage under the
NPDES General Permit for Discharges of Storm Water
Associated with Construction Activity. This would require
implementation of a SWPPP that is required to identify
all potential sources of pollution that are reasonably
expected to affect the quality of storm water discharges
from the construction site. Additionally, operation of the
proposed Project would be required to comply with the
requirements of the Orange County Drainage Area
Management Plan (DAMP) and the intent of the non -point
source NPDES Permit for Waste Discharge Requirements
for the County of Orange, Orange County Flood Control
District and the incorporated Cities of Orange County
within the Santa Ana Region. The DAMP requires that
new development and significant redevelopment
projects develop and implement a water quality
management plan (WQMP) that includes BMPs and low
impact development (LID) design features that would
provide onsite treatment of stormwater to prevent
pollutants from onsite uses from leaving the site. WQMPs
prepared for future development would be reviewed
and approved by the City to ensure it complies with the
MS4 Permit regulations. In addition, the City's permitting
process would ensure that all BMPs in the WQMP would
be implemented with the project. Thus, implementation of
a SWPPP and WQMP would protect water quality and
water supply. Thus, the proposed Project would be
consistent with Goal 5.
Policy 5.2: Protect groundwater resources from
Consistent. As described in Section 5.11, Utilities, the
depletion and sources of pollution.
Project site is fully developed and nearly 100 percent
impervious aside from some landscaped areas.
Therefore, implementation of the proposed Project
would not change the amount of impervious surface of
interfere with the rate of groundwater recharge
compared to existing conditions. Further, as described
above, development and construction of the Project site
would require preparation and adherence to SWPPP
and WQMP. Therefore, development of the site would
not deplete or pollute groundwater resources. Thus, the
proposed Project would be consistent with Policy 5.2.
Policy 5.3: Conserve imported water by requiring water
Consistent. Future projects would be required to
conservation techniques, water conserving appliances,
implement landscaping and water conserving appliances
and drought -resistant landscaping.
pursuant to Section 9701 of Article 9, Chapter 7 of the
City of Tustin Municipal Code. Compliance would be
reviewed by the City during the permitting process. Thus,
the proposed Project would be consistent with Policy 5.3.
Policy 5.5: Protect water quality by responsible agency
Not Applicable. This is not a project -specific goal, but a
support of enforcement of water quality standards for
City initiative, and is therefore not applicable.
City of Tustin 5.4-33
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
water imported into the County, and to preserve the
quality of water in the groundwater basin and streams.
Policy 7.1: Inventory unique or significant tree stands,
Not Applicable. The Project site is completely
with particular attention given to the cedar stand,
developed. Future development would not result in the
eucalyptus groves, and eucalyptus windrows in East
removal of tree stands.
Tustin. Develop standards to retain or incorporate the
eucalyptus windrows and groves into development plans
where feasible. The redwood/sequoia stand has been
retained within a park site and integrated into the park
design.
Policy 7.2: Conserve important plant communities and
Not Applicable. The Project site is completely
wildlife habitats, such as riparian areas, wildlife
developed. Future development would not result in the
movement corridors, wetlands, and significant tree stands
disturbance of important plant communities.
through the practice of creative site planning,
revegetation, and open space easements/dedications.
Policy 7.4: Require new development to revegetate
Consistent. All future projects are required to comply
graded areas.
with the City of Tustin Grading Manual (1990), which
includes requirements for the revegetation of graded
areas. Implementation of grading manual standards
would be verified by the City during the plan check and
permitting process. Thus, the proposed Project would be
consistent with Policy 7.4.
Goal 8: Conserve and protect significant topographical
Not applicable. The Project site is completely developed
features, important watershed areas, resources, and
and void of natural topographical features, natural
soils.
resources and soils.
Policy 8.1: Develop standards to preserve the unique
Consistent. The Project site is not located within a hillside
variety of land forms indigenous in hillside areas, and
area, is already developed with commercial land uses
ensure that the development process is structured to
and parking areas and would be subject to design
ensure that grading and siting practice reflects the
requirements established through ODS. Furthermore, all
natural topography.
future projects are required to comply with the City of
Tustin Grading Manual (1990). Implementation of
grading manual standards would be verified by the City
during the plan check and permitting process. Thus, the
proposed Project would be consistent with Policy 8.1.
Policy 8.2: Control erosion during and following
Consistent. As described above, development and
construction through proper grading techniques,
construction of the Project site would require preparation
vegetation replanting, and the installation of proper
and adherence to SWPPP and WQMP. Through
drainage control improvements.
implementation of BMP's, future development of the site
would require proper grading techniques, vegetation
replanting, and the installation of proper drainage
control improvements during and following construction.
Furthermore, all future projects are required to comply
with the City of Tustin Grading Manual (1990).
Implementation of grading manual standards would be
verified by the City during the plan check and permitting
process. Thus, the proposed Project would be consistent
with Policy 8.2.
Policy 8.3: Encourage the practice of proper soil
Consistent. Future development facilitated by the
management techniques to reduce erosion,
provision of residential land uses within the Project site
sedimentation, and other soil -related problems.
would be required to comply with the RWQCB NPDES
Construction General Permit requirements. Requirements
include installation of Best Management Practices (BMPs),
which establishes minimum stormwater management
requirements and controls. To reduce the potential for soil
erosion and the loss of topsoil, a SWPPP is required by
City of Tustin 5.4-34
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective I Project Consistency
Policy 8.5: Review applications for building and grading
permits, and applications for subdivision for adjacency
to, threats from, and impacts on geological hazards
arising from seismic events, landslides, or other geologic
hazards such as expansive soils and subsidence areas.
Policy 8.6: Site planning and architectural design shall
respond to the natural landform whenever possible to
minimize grading and viewshed intrusion.
Policy 8.8: Require geotechnical studies for
developments that are proposed for steep slopes and
where geological instability may be suspected. Where a
precise location of the El Modena fault is determined,
appropriate building setbacks shall be established per
State law.
City of Tustin
Draft EIR
June 2024
the RWQCB regulations to be developed by a
(Qualified SWPPP Developer) QSD. The SWPPP is
required to address site -specific conditions related to
specific grading and construction activities. The SWPPP
would identify potential sources of erosion and
sedimentation to prevent loss of topsoil during
construction, and to identify erosion control BMPs to
reduce or eliminate the erosion and loss of topsoil, such
as use of silt fencing, fiber rolls, or gravel bags;
stabilized construction entrances/exits; hydroseeding,
and similar measures. In addition to RWQCB
requirements, proposed development would need to
comply with the City of Tustin Grading Manual
procedures. Thus, the proposed Project would be
consistent with Policy 8.3.
Consistent. All future development permitted would be
required to comply with the requirement of the California
Building Code (CBC) (California Code of Regulations,
Title 24, Part 2) (PPP GEO-1 ), which is a minimum
requirement intended to protect life safety and prevent
collapse of structures. Implementation of CBC standards
would be verified by the City during the plan check and
permitting process Furthermore, all future projects are
required to comply with the City of Tustin Grading
Manual (1990). Implementation of grading manual
standards would be verified by the City during the plan
check and permitting process. Thus, the proposed Project
would be consistent with Policy 8.5.
Consistent. The Project site is located in an urban
environment and would develop design requirements
established through ODS for the site, and future
development within the site, which would be created to
ensure compatibility with the existing site development
and surrounding land uses, such as compatible building
height, cohesive architectural style, and appropriate
landscaping. Furthermore, all future projects are
required to comply with the City of Tustin Grading
Manual (1990). Implementation of grading manual
standards would be verified by the City during the plan
check and permitting process. Thus, the proposed Project
would be consistent with Policy 8.6.
Consistent. The Project site is outside of a 500-foot
radius from an active fault and is not subject to a special
development permit. The Project site contains existing
development, and the provision for additional
development would not exacerbate existing risk of
earthquake. Further, all future development permitted
would be required to comply with the requirement of the
California Building Code (CBC) (California Code of
Regulations, Title 24, Part 2). Implementation of CBC
standards would be verified by the City during the plan
check and permitting process for future development
within the Project site. Additionally, future projects would
be required to implement measures identified within the
project -specific geotechnical investigation (MM GEO-1 ).
5.4-35
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective I Project Consistency
Policy 8.10: Mitigate the impacts of development on
sensitive lands such as steep slopes, wetlands, cultural
resources, and sensitive habitats through the
environmental review process.
Policy 8.16: Site buildings and align roadways to
maximize public visual exposure to natural features.
Goal 10: Reduce solid waste produced within City.
Policy 10.2: Ensure that the City diverts from landfills a
maximum of 50% of the solid waste generated in the
City as required by the California Integrated Waste
Management Board.
Thus, the proposed Project would be consistent with Policy
8.8.
Consistent. The Project site is currently completely
paved; thus, implementation of the Project would not
result in an adverse effect, either directly or through
habitat modifications, on any sensitive species.
Additionally, the site does not contain wetlands or
sensitive habitats. If commencement of vegetation
clearing for any future residential development project
occurs between February 1 and September 15,
Mitigation Measure BIO-1 has been included to require
nesting bird surveys. Additionally, according to the
IS/NOP Section 5.5, Cultural Resources (see Appendix
A), there is a low potential that future construction could
result in inadvertent discovery of a buried archeological
resource. However, Mitigation Measure CUL-1 has been
incorporated to mitigate any potential impact to an
archeological resource. Furthermore, future development
would be required to comply with California Health and
Safety Code Section 7050.5, CEQA Section 15064.5,
and Public Resources Code Section 5097.98, and the
City of Tustin Grading Manual. Thus, the proposed
Project would be consistent with Policy 8.10.
Consistent. The Project site is currently developed as a
commercial site and is surrounded by other commercial
developments. The view of Peters Canyon Ridgeline from
the Project site is obstructed by surrounding buildings and
trees. The Project site is bordered by 17'h Street to the
north, which offers limited public views of Peters Canyon
Ridgeline to motorists, bicyclists, and pedestrians
traveling eastbound. Views to the east from CA-55 are
completely obstructed by adjacent developments and
the raised embankment. Thus, the proposed Project
would be consistent with Policy 8.16.
Consistent. Section 5.408.1 of the 2019 California
Green Building Standards Code requires demolition and
construction activities to recycle or reuse a minimum of 65
percent of the nonhazardous construction and demolition
waste. Additionally, operation of the Project would
generate waste as well. However, at least 75 percent of
the solid waste is required by AB 341 to be recycled. All
future development would be required to comply with
waste reduction regulations. Therefore, the Project would
be consistent with Goal 10.
Consistent. Section 5.408.1 of the 2019 California
Green Building Standards Code requires demolition and
construction activities to recycle or reuse a minimum of 65
percent of the nonhazardous construction and demolition
waste. Additionally, operation of the Project would
generate waste as well. However, at least 75 percent of
the solid waste is required by AB 341 to be recycled. All
future development would be required to comply with
waste reduction regulations. Therefore, the Project would
be consistent with Policy 10.2
City of Tustin 5.4-36
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
Goal 11: Conserve energy resources through use of
Consistent. As described in Section 5.2, Energy, future
available energy technology and conservation practices.
development under the proposed Project would be
required to adhere to State and local regulations
regarding green building and sustainable practices such
as Title 24, as ensured and verified by the City during
the plan check and permitting process. Thus, the
proposed Project would be consistent with Goal 11.
Policy 11.2: Maintain local legislation to establish,
Consistent. As described in Section 5.2, Energy, future
update and implement energy performance building
development under the proposed Project would be
code requirements established under State Title 24
required to adhere to State and local regulations
Energy Regulations.
regarding green building and sustainable practices such
as Title 24, as ensured and verified by the City during
the plan check and permitting process. Thus, the
proposed Project would be consistent with Policy 1 1.2.
Goal 12: Maintain and enhance the City's unique
Consistent. The Project site is completely developed. The
culturally and historically significant building sites or
Project site does not include any historically significant
features.
buildings. Additionally, there is a low potential that
future construction could result in inadvertent discovery
of a buried archeological resource. Mitigation Measure
CUL-1 has been incorporated to mitigate any potential
impact to an archeological resource. Thus, the proposed
Project would be consistent with Goal 12.
Policy 12.2: Retain and protect significant areas of
Consistent. A Cultural Records Search was conducted for
archaeological, paleontological, or historical value for
the Project site by BFSA Environmental Services in 2023
education and scientific purposes.
(see Appendix A). According to results of the cultural
record search prepared for the Project, the Project site
does not contain any historic resources. Additionally,
there is a low potential that future construction could
result in inadvertent discovery of a buried archeological
resource. Mitigation Measure CUL-1 has been
incorporated to mitigate any potential impact to an
archeological resource. Furthermore, the Project site is
not located in an area identified by the GP as "High
Paleontological Sensitivity" and the City has very
detailed standards and requirements for grading that
are designed to protect sensitive topographic, soil,
palaeontologic, and archaeologic resources. The Tustin
Grading Manual prescribes appropriate measures to
protect the earth by controlling erosion, sedimentation,
and storm drainage (PPP HYD-2). Proper grading, soil
management, and open space standards will work to
preserve any potential paleontological resources in the
very unlikely event that a resource is encountered. Thus,
the proposed Project would be consistent with Policy
12.2
Goal 13: Preserve Tustin's archaeological and
Consistent. As described above, the Project site has low
paleontological resources.
potential for archaeological and paleontological
resources. Additionally, Mitigation Measure CUL-1 has
been incorporated to mitigate any potential impact to
an archeological resource. The Tustin Grading Manual
prescribes appropriate measures to protect the earth by
controlling erosion, sedimentation, and storm drainage
(PPP HYD-2). Proper grading, soil management, and
open space standards will work to preserve any
potential paleontological resources in the very unlikely
event that a resource is encountered during future
City of Tustin 5.4-37
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
construction activities. Thus, the proposed Project would
be consistent with Goal 13.
Policy 13.1: Require a site inspection by certified
Consistent. Future projects within the Project site would
archaeologists or paleontologists for new development
require preparation of Geotechnical Investigations.
in designated sensitive areas.
Future projects would be required to implement measures
identified within the project -specific geotechnical
investigation (MM GEO-1 ). Additionally, a Cultural
Records Search (see Appendix A) was prepared to
determine the potential for historic and architectural
resources to occur within the Project site. Thus, the
proposed Project would be consistent with Policy 1 3.1 .
Policy 13.2: Require mitigation measures where
Consistent. As described above, the Project site has low
development will affect archaeological or
potential for archeological resources; however, future
paleontological resources.
development would be required to comply with
Mitigation Measure CUL-1 and all relevant regulatory
requirements. Additionally, the Project site is not located
in an area identified by the GP as "High Paleontological
Sensitivity." The City has very detailed standards and
requirements for grading that are designed to protect
sensitive topographic, soil, palaeontologic, and
archaeologic resources. The Tustin Grading Manual
prescribes appropriate measures to protect the earth by
controlling erosion, sedimentation, and storm drainage.
All future projects are required to comply with the City
of Tustin Grading Manual. Additionally, future projects
would be required to implement measures identified
within the project -specific geotechnical investigation (MM
GEO-1). Thus, the proposed Project would be consistent
with Policy 13.2.
Goal 14: Encourage the development and maintenance
Consistent. The Project proposes a housing overlay and
of a balanced system of public and private parks,
does not propose any actual development or funding of
recreation facilities, and open spaces that serves the
future development. However, as described in Section 5.
needs of existing and future residents in the City of Tustin.
8, Recreation, future development under the Project
would provide for adequate recreational spaces or pay
in lieu fees consistent with the City's park space
requirements (PPP R-1). Thus, the proposed Project would
be consistent with Goal 14.
Policy 14.8: Encourage and, where appropriate, require
Consistent. The Project proposes a land use change and
the inclusion of recreation facilities and open space within
does not propose any actual development or funding of
future residential, industrial and commercial
future development. However, as described in Section 5.
developments.
8, Recreation, future development under the Project
would provide for adequate recreational spaces or pay
in lieu fees consistent with the City's park space
requirements (PPP R-1 ).
Policy 14.12: Ensure that the City's laws and related
Not Applicable. This is not a project -specific policy and
implementation tools relating to park dedication and
is therefore not applicable.
development (e.g., ordinances, regulations, in -lieu fee
schedules, etc.) reflect current land and construction costs,
and are, in fact, providing adequate park land and
facilities concurrent with population growth.
Goal 17: Operate and maintain existing and future
Not Applicable. This is not a project -specific goal and
parks and recreation facilities so they are safe, clean,
is therefore not applicable.
and attractive to the public; and preserve, protect, and
enhance both existing and potential natural recreation
areas to ensure that long-term public investments and
City of Tustin 5.4-38
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
values are not unreasonably preempted, compromised,
or prevented by neglect or short-term considerations.
Policy 17.2: Require park designs (including landscape
Consistent. The ODS would ensure consistency with the
treatments, buildings, irrigation, etc.) that are durable,
City landscaping, building, and irrigation standards.
reasonably standardized, and economical to maintain.
Additionally, each future residential and commercial
project implemented as part of the housing overlay
would require a project -level plan check. Thus, the
proposed Project would be consistent with Policy 17.2.
Goal 18: Ensure that the recreational goals and policies
Consistent. Future subdivision projects would be
are pursued and realized in an organized, incremental,
required to pay DIFs, which include fees that would go
and cost effective manner and consistent with the City of
towards the development and maintenance of the City's
Tustin's financial resources and legal authorities and the
recreational resources. Thus, the proposed Project would
appropriate responsibilities of other agencies, the
be consistent with Goal 18.
private sector, and individual and group users.
Policy 18.5: Conserve the City's Quimby Act authority by
Consistent. Future subdivision projects would be
utilizing, wherever practicable, the City's broad powers
required to pay DIFs, which include fees that would go
to enact and enforce its General Plan, Specific Plan(s),
towards the development and maintenance of the City's
Redevelopment Plan(s), subdivision ordinance and
recreational resources. Thus, the proposed Project
Zoning Ordinance to secure public and private
would be consistent with Policy 18.5.
recreation sites, open space, trails, and other related
land use objectives of community planning significance
Public Safety Element
Goal 1: Reduce the risk to the community's inhabitants Consistent. According to the Federal Emergency
from flood hazards. Management Agency (FEMA) Map 06059C0164J, the
Project site is within Flood Zone X, or the 0.2 percent
annual change flood area, areas of 1 percent annual
chance flood with average depth less than 1 foot or with
drainage areas of less than 1 square mile (Federal
Emergency Management Agency, 2009). The site is not
within a special flood hazard area.
The Project site is currently completely developed and
completely paved, with the exception of some
ornamental landscaped areas. Future development
would not result in additional impervious surfaces that
could increase the volume and velocity of stormwater
runoff that would exacerbate flood conditions. Thus, the
proposed Project would be consistent with Goal 1.
Policy 1.1: Identify flood hazard areas and provide Consistent. As described above, the Project site is not
appropriate land use regulations for areas subject to located within a flood hazard area and would not
flooding. exacerbate flood conditions. Thus, the proposed Project
would be consistent with Policy 1.1.
Policy 1.5: Require detention basins as a flood control Consistent. Specific infrastructure improvements
measure where applicable to reduce the risk from flood required to support residential development within the
hazards. Enderle Center are not known at this time and will not be
known until a development project is proposed.
However, future development would comply with the
DAMP regulations which are included in the City's
Municipal Code in Section 4902 and are the
implementation method for NPDES Stormwater Permit
compliance. Compliance would ensure that all future
development within the Enderle Center incorporates
appropriate Site Design, Source Control, and Treatment
Control BMPs. Thus, the proposed Project would be
consistent with Policy 1.5.
City of Tustin 5.4-39
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective I Project Consistency
Goal 3: Reduce the risk to the community from geologic
and seismic hazards.
Policy 3.1: Require review of soil and geologic
conditions by a State -Licensed Engineering Geologist to
determine stability prior to the approval of development
where appropriate.
Policy 3.5: Ensure that structures for human occupancy,
critical structures, and vital emergency facilities are
designed to minimize damage from potential
geologic/seismic hazards and avoid functional
impairment.
Policy 3.7: Include and periodically review and update
emergency procedures for earthquakes in the City's
Emergency Preparedness Plan.
Goal 4: Reduce the risk to the community's inhabitants
from exposure to hazardous materials and wastes.
Consistent. Future projects within the Project site would
require preparation of Geotechnical Investigations.
Future projects would be required to implement measures
identified within the project -specific geotechnical
investigation (MM GEO-1). Further, all future
development permitted would be required to comply
with the requirement of the California Building Code
(CBC) (California Code of Regulations, Title 24, Part 2).
Implementation of CBC standards would be verified by
the City during the plan check and permitting process for
future development within the Project site. Thus, the
proposed Project would be consistent with Goal 3.
Consistent. Future projects within the Project site would
require preparation of Geotechnical Investigations.
Future projects would be required to implement measures
identified within the project -specific geotechnical
investigation (MM GEO-1 ). Further, all future
development permitted would be required to comply
with the requirement of the California Building Code
(CBC) (California Code of Regulations, Title 24, Part 2).
Implementation of CBC standards would be verified by
the City during the plan check and permitting process for
future development within the Project site. Thus, the
proposed Project would be consistent with Policy 3.1.
Consistent. Future projects within the Project site would
require preparation of Geotechnical Investigations.
Future projects would be required to implement measures
identified within the project -specific geotechnical
investigation (MM GEO-1 ). Further, all future
development permitted would be required to comply
with the requirement of the California Building Code
(CBC) (California Code of Regulations, Title 24, Part 2).
Implementation of CBC standards would be verified by
the City during the plan check and permitting process for
future development within the Project site. Thus, the
proposed Project would be consistent with Policy 3.5.
Consistent. The Project site is not designated as an
emergency evacuation route. The Project would not
impair the implementation of evacuation protocol in the
event of an emergency within the City or Project site.
Additionally, each future residential project implemented
as part of the housing overlay and Housing Element
would require a project -level plan check with the City
and would be reviewed by the City's fire department
(Orange County Fire Authority) to ensure proper
emergency access to and from the site. Thus, the
proposed Project would be consistent with Policy 3.7.
Consistent. The Project site is not located on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5. Additionally, all
future development through implementation of the
housing overlay and the City's certified 2021 -2029
Housing Element would be required to develop and
implement a SWPPP as required through the NPDES.
Implementation of a SWPPP would minimize potential
adverse effects to workers, the public, and the
City of Tustin 5.4-40
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
environment from the foreseeable upset and accident
conditions involving the release of hazardous materials.
Construction contract specifications would include strict
on -site handling rules and BMPs for hazardous materials.
Thus, the proposed Project would be consistent with Goal
4.
Policy 4.3: Transportation of hazardous waste will be
Consistent. Future construction and operational activities
minimized and regulated where possible to avoid
could involve the transport, use, and disposal of
environmentally sensitive areas and populated,
hazardous materials; however, the types of materials
congested, and dangerous routes.
are not acutely hazardous, and all storage, handling,
use, and disposal of these materials are regulated by
federal and State requirements that are implemented by
the City during building permitting for construction
activities. Thus, the proposed Project would be consistent
with Policy 4.3.
Policy 4.5: Establish regulations requiring land uses
Not Applicable. This is not a project -specific goal and is
involved in the production, storage, transportation,
therefore not applicable.
handling, or disposal of hazardous materials to be
located a safe distance from other land uses that may
be adversely affected by such activities.
Policy 4.15: Coordinate with the County of Orange in
Consistent. Construction of future projects would be
the implementation of the National Pollution Discharge
required to obtain coverage under the NPDES General
Elimination System Permits (NPDES) regulations.
Permit for Discharges of Storm Water Associated with
Construction Activity. This would require implementation
of a SWPPP that is required to identify all potential
sources of pollution that are reasonably expected to
affect the quality of storm water discharges from the
construction site. Additionally, operation of the proposed
Project would be required to comply with the
requirements of the DAMP and the intent of the non -point
source NPDES Permit for Waste Discharge Requirements
for the County of Orange, Orange County Flood Control
District and the incorporated Cities of Orange County
within the Santa Ana Region. The DAMP requires that
new development and significant redevelopment
projects develop and implement a WQMP that includes
BMPs and LID design features that would provide onsite
treatment of stormwater to prevent pollutants from onsite
uses from leaving the site. WQMPs prepared for future
development would be reviewed and approved by the
City to ensure it complies with the MS4 Permit
regulations. In addition, the City's permitting process
would ensure that all BMPs in the WQMP would be
implemented with the project. Thus, the proposed Project
would be consistent with Policy 4.15.
Goal 5: Reduce the risk to the community's inhabitants
Consistent. The Project site is currently developed as a
from fires or explosions.
commercial site and is surrounded by other commercial
developments. According to the CalFire Fire Hazard
Severity Zone Map, the City of Tustin contains very high
fire severity zones in the northeast portion of the City.
The Project site is not located within or near State
responsibility areas or lands classified as very high fire
hazard severity zones. All future development permitted
would be required to comply with the requirement of the
California Building Code (CBC) (California Code of
Regulations, Title 24, Part 2) (PPP GEO-1 ), which is a
City of Tustin 5.4-41
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Policy 5.4: Enforce building code requirements that
assure adequate fire protection.
Policy 5.6: Cooperate with Orange County Fire
Authority to ensure the provision of adequate and cost-
effective fire protection services.
Goal 6: Stabilize demand for law enforcement services.
Policy 6.1: Provide appropriate levels of police
protection within the community.
Policy 6.5: Promote the use of defensible space concepts
(site and building lighting, visual observation of open
spaces, secured areas, etc.) in project design to enhance
public safety.
Project Consistency
minimum requirement intended to protect life safety and
prevent collapse of structures. Additionally, all future
development would be required to comply with the
requirements of the California Fire Code (Title 24, Part
9), as ensured by the city during plan check and
permitting. Thus, the proposed Project would be
consistent with Goal 5.
Consistent. All future development permitted would be
required to comply with the requirement of the California
Building Code (CBC) (California Code of Regulations,
Title 24, Part 2) (PPP GEO-1 ), which is a minimum
requirement intended to protect life safety and prevent
collapse of structures. Additionally, all future
development would be required to comply with the
requirements of the California Fire Code (Title 24, Part
9), as ensured by the city during plan check and
permitting. Thus, the proposed Project would be
consistent with Policy 5.4.
Consistent. As discussed in Section 5.7, Public Services,
future subdivision projects would pay appropriate DIFs
for the maintenance of adequate public services.
Ongoing coordination would be conducted between the
City and Orange County Fire Authority (OCFA)
regarding growth planning. Thus, the proposed Project
would be consistent with Policy 5.6.
Consistent. As discussed in Section 5.7, Public Services,
future subdivision projects would pay appropriate DIFs
for the maintenance of adequate public services.
Ongoing coordination would be conducted between the
City and Orange County Fire Authority (OCFA)
regarding growth planning. Thus, the proposed Project
would be consistent with Goal 6.
Consistent. As discussed in Section 5.7, Public Services,
future subdivision projects would pay appropriate DIFs
for the maintenance of adequate public services.
Ongoing coordination would be conducted between the
City and Orange County Fire Authority (OCFA)
regarding growth planning. Thus, the proposed Project
would be consistent with Policy 6.1.
Consistent. All future development permitted would be
required to comply with the requirement of the California
Building Code (CBC) (California Code of Regulations,
Title 24, Part 2) (PPP GEO-1 ), which is a minimum
requirement intended to protect life safety and prevent
collapse of structures. Additionally, all future
development would be required to comply with the
requirements of the California Fire Code (Title 24, Part
9), as ensured by the city during plan check and
permitting. Additionally, all future development would
be required to comply with the City's ODS for the site.
Thus, the proposed Project would be consistent with Policy
6.5.
Goal 8: Improve the City's ability to respond to natural Not Applicable. This is not a project -specific goal and is
and manmade emergencies. therefore not applicable.
City of Tustin 5.4-42
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective I Project Consistency
Policy 8.1: Maintain an up-to-date Emergency Not Applicable. This is not a project -specific policy and
Operations Plan identifying all available resources and is therefore not applicable.
funds for use in the event of a disaster and establishing
implementing actions or procedures under the Plan for
rescue efforts, medical efforts, emergency shelters,
provision of supplies, and all other response efforts
recommended by the State Office of Emergency
Services and the Federal Emergency Management
Agency (FEMA). Include procedures for dealing with
specific events such as earthquake, major rail and
roadway accidents, flooding, and hazardous materials
Noise Element
Goal 1: Use noise control measures to reduce the impact
Consistent. As discussed in Section 5.5, Noise, the Project
from transportation noise sources.
would result in a less than significant impact regarding
traffic noise. Future development under the proposed
Project would be required to ensure consistency with the
Project's noise analysis, and if inconsistent, would be
required to prepare a separate project -specific noise
analysis. A Final Acoustical Report would be required to
confirm the noise level exposure from stationary sources
to off -site sensitive land uses and to identify any specific
mitigation measures necessary to achieve an exterior
noise level below the City's noise standards. Consistency
with the approved Project would be determined during
City plan check. Thus, the proposed Project would be
consistent with Goal 1 .
Policy 1.1: Pursue construction of new barriers, or the
Consistent. The Project site is adjacent to State Route 55.
augmentation of existing barriers, to reduce noise
Future residential projects could experience noise
impacts along the Route 5 and Route 55 freeways along
pollution from the adjacent freeway. All future projects
segments directly next to residential areas.
would require a Final Acoustical Report to determine
whether the proposed project meets the City's interior
and exterior noise -level standards, as discussed in
Section 5.5, Noise. Thus, the proposed Project would be
consistent with Policy 1.1.
Policy 1.11: Consider noise impacts to residential
Not Applicable. This is not a project -specific policy and
neighborhoods when designating truck routes and major
is therefore not applicable.
circulation corridors.
Goal 2: Incorporate noise considerations into land use
Consistent. The Project site is adjacent to State Route 55.
planning decisions.
Future residential projects could experience noise
pollution from the adjacent freeway. All future projects
would require a Final Acoustical Report to determine
whether the proposed project meets the City's interior
and exterior noise -level standards, as discussed in
Section 5.5, Noise. Thus, the proposed Project would be
consistent with Goal 2.
Policy 2.1: Adopt planning guidelines that establish
Consistent. Future development under the proposed
acceptable noise standards for various land uses
Project would be required to adhere to acceptable noise
throughout the Tustin Planning Area.
standards for the established land uses, as ensured by
the City during the plan check and permitting process. All
future projects would require a Final Acoustical Report to
determine whether the proposed project meets the City's
interior and exterior noise -level standards, as discussed
City of Tustin 5.4-43
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
in Section 5.5, Noise. Thus, the proposed Project would
be consistent with Policy 2.1.
Policy 2.3: Use noise/land use compatibility standards
Consistent. Future development under the proposed
as a guide for future planning and development.
Project would be required to adhere to acceptable noise
standards for the established land uses, as ensured by
the City during the plan check and permitting process. All
future projects would require a Final Acoustical Report to
determine whether the proposed project meets the City's
interior and exterior noise -level standards, as discussed
in Section 5.5, Noise. Thus, the proposed Project would
be consistent with Policy 2.3.
Policy 2.4: Review proposed projects in terms of
Consistent. Future development under the proposed
compatibility with nearby noise -sensitive land uses with
Project would be reviewed by the City for compatibility
the intent of reducing noise.
with nearby noise -sensitive land uses, as ensured during
the plan check and permitting. All future projects would
require a Final Acoustical Report to determine whether
the proposed project meets the City's interior and
exterior noise -level standards, as discussed in Section
5.5, Noise. Thus, the proposed Project would be consistent
with Policy 2.4.
Policy 2.5: Require new residential developments
Consistent. Future development under the proposed
located in proximity to existing commercial/industrial
Project would be required to adhere to acceptable noise
operations to control residential interior noise levels as a
standards for the established land uses, as ensured by
condition of approval.
the City during the plan check and permitting process. All
future projects would require a Final Acoustical Report to
determine whether the proposed project meets the City's
interior and exterior noise -level standards, as discussed
in Section 5.5, Noise. Thus, the proposed Project would
be consistent with Policy 2.5.
Policy 2.6: Require that commercial uses developed as
Consistent. The proposed Project includes a mixed -use
part of a mixed -use project (with residential) not be noise
development for commercial and residential land uses.
intensive. Design mixed -use structures to prevent transfer
Future development under the proposed Project would
of noise from the commercial to the residential use.
be reviewed by the City for compatibility with nearby
noise -sensitive land uses, as ensured during plan check
and permitting. All future projects would require a Final
Acoustical Report to determine whether the proposed
project meets the City's interior and exterior noise -level
standards, as discussed in Section 5.5, Noise. Thus, the
proposed Project would be consistent with Policy 2.6.
Policy 2.7: Require new commercial/industrial
Consistent. The proposed Project includes mixed -use
operations located in proximity to existing or proposed
development for commercial and residential land uses.
residential areas to incorporate noise mitigation into
Future commercial development under the proposed
project design.
Project would be reviewed by the City, as ensured during
plan check and permitting, and would incorporate noise
mitigation into project design as needed. Thus, the
proposed Project would be consistent with Policy 2.7.
Goal 3: Develop measures to control non -transportation
Consistent. The Project would allow for the potential
noise impacts.
future development of residential uses amongst
commercial land uses. Residential land uses are not
considered noise -intensive uses, and would not contribute
to new significant noise increase, as discussed in Section
5.5, Noise. Therefore, the Project would be consistent
with Goal 3.
City of Tustin 5.4-44
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
General Plan Update Goal, Policy, or Objective
Project Consistency
Policy 3.1: Implement a review process of Tustin's noise
Not Applicable. This is not a project -specific goal and is
ordinance, and City policies and regulations affecting
therefore not applicable.
noise.
Policy 3.2: Minimize the impacts of construction noise on
Consistent. Future development under the proposed
adjacent land uses through limiting the permitted hours
Project would be reviewed by the City for consistency
of activity.
with the permitted hours of activity, as ensured during
plan check and permitting. Thus, the proposed Project
would be consistent with Policy 3.2.
Policy 3.3: Require City departments to observe state
Not Applicable. This is not a project -specific policy and
and federal occupational safety and health noise
is therefore not applicable.
standards
Growth Management Element
Goal 2: Ensure adequate transportation facilities are
Consistent. A TIA was prepared as part of this Project
provided for existing and future inhabitants of the City.
and will be assessed by the City to determine necessary
future improvements. Future development would be
responsible for implementing identified improvements.
Future major development under the proposed Project
would require preparation of a project -specific TIA to
identify project -specific impacts. Thus, the proposed
Project would be consistent with Goal 2.
Policy 2.1: Require that all new development pay its
Consistent. Future projects would be required to pay
share of the street improvement costs associated with the
their fair share of street improvement costs as identified
development, including regional traffic mitigation.
in the Project TIA (available upon request by the City),
including regional traffic mitigation, as ensured and
verified by the City during the plan check and permitting
process, prior to obtaining building permits. Thus, the
proposed Project would be consistent with Policy 2.1
Policy 2.5: All new developments shall be required to
Consistent. Future projects would be required to
establish a development phasing program which phases
establish a phasing program as ensured and verified by
approval of development commensurate with required
the City during the plan check and permitting process,
improvements to roadway capacity. The Phasing Plan
prior to obtaining building permits. Thus, the proposed
shall include an overall buildout development plan which
Project would be consistent with Policy 2.5.
can demonstrate the ability of the infrastructure to
support the planned development.
Policy 2.6: Development phasing for new projects shall
Consistent. All future projects would be required to
be a component of the development review and
comply with the City of Tustin Grading Manual (1990).
entitlement process and shall be approved prior to
Implementation of grading manual standards would be
issuance of building or grading permits
verified by the City during the plan check and permitting
process. Thus, the proposed Project would be consistent
with Policy 2.6.
Source: City of Tustin General Plan
5.4.7 CUMULATIVE IMPACTS
The cumulative study area for land use and planning includes the neighboring city of Santa Ana. As shown
in Table 5-1, Cumulative Project List, and Figure 5-1, Cumulative Projects, in Section 5.0, Environmental Impact
Analysis, of this Draft EIR, the vicinity of the Project site includes numerous projects within the City of Santa
Ana. A large portion of these projects consist of multi -family residential, commercial, and office
developments, which are similar, consistent, and complementary to the proposed Project.
As described previously, the proposed Project would implement the objectives of the previously approved
2021-2029 City Housing Element. Also, as detailed in Tables 5.4-1, 5.4-2, and 5.4-3, the proposed Project
City of Tustin 5.4-45
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.4 Land Use and
is consistent with all of the relevant SCAG RTP/SCS Policies and the City's GP goals and policies adopted
for the purpose of avoiding or mitigating an environmental effect. Furthermore, the proposed Project, which
includes a GPA, Zoning Code Amendment, and Zone Change would thus be consistent with the GP and land
use designations and focused area development objectives. Because the proposed Project would implement
the GP (including the Housing Element) and would not result in conflicts with an applicable land use plan,
policy, or regulation of an agency with jurisdiction over the proposed Project, which has the purpose of
avoiding or mitigating an environmental effect, the proposed Project would not cumulatively contribute to
such an impact that could occur from related projects. Overall, the Project would be cumulatively beneficial
to meeting the statewide housing objectives as established through the regional and local RHNA. Project -
level impacts would be mitigated to less -than -significant levels through the implementation of mitigation
measures which would reduce any potentially reasonably foreseeable significant impacts from the
implementation of future development projects. As a result, cumulative impacts related to land use and
planning from the proposed Project would not be cumulatively considerable with implementation of
mitigation.
5.4.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
The following regulations are identified in the above analysis as existing regulations that would avoid or
minimize potential Project impacts.
• AB 341 (recycling)
• California Green Building Standards Code, Section 5.408.1 (Green building standards)
• California Code of Regulations, Title 24 (California building requirements)
• Government Code Section 65962.5 (Hazardous waste disclosure)
• City of Tustin Municipal Code, Section 9701 of Article 9, Chapter 7 (Water efficient landscapes)
• City of Tustin Municipal Code, Section 4902 (DAMP)
• City of Tustin Municipal Code, Article 4, Chapter 6 (City noise control)
• City of Tustin Municipal Code, Chapter 8 (Floodplain management)
Plans, Programs, or Policies
The following plans, programs, and policies are identified in the above analysis as existing regulations that
would avoid or minimize potential Project impacts.
PPP GEO-1 CBC Title 24, Part 2. Structures built in the City are required to be built in compliance with
the CBC (California Code of Regulations, Title 24, Part 2) that provides provisions for
earthquake safety based on factors including building occupancy type, the types of soils
onsite, and the probable strength of ground motion. Compliance with the CBC would require
the incorporation of 1) seismic safety features to minimize the potential for significant effects
as a result of earthquakes; 2) proper building footings and foundations; and 3) construction
of the building structure so that it would withstand the effects of strong ground shaking.
Implementation of CBC standards would be verified by the City during the plan check and
permitting process.
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide
the City Building Division evidence of compliance with the NPDES (National Pollutant
Discharge Elimination System) requirement to obtain a construction permit from the State
Water Resource Control Board (SWRCB). The permit requirement applies to grading and
City of Tustin 5.4-46
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
construction sites of one acre or larger. The Project applicant/proponent shall comply by
submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater
Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the
construction site.
PPP HYD-2 City of Tustin Grading Manual. All future projects are required to comply with the City of
Tustin Grading Manual (1990). Implementation of grading manual standards would be
verified by the City during the plan check and permitting process.
PPP HYD-3 WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a
completed Water Quality Management Plan (WQMP) shall be prepared by the Project
applicant and submitted to and approved by the City Public Works Department. The
WQMP shall identify all Post -Construction, Site Design. Source Control, and Treatment
Control Best Management Practices (BMPs) will be incorporated into the development
Project in order to minimize the adverse effects on receiving waters.
PPP T-1: Sidewalk Standards Sidewalks shall be provided on a private street for attached and
detached residential products in accordance with Standard B102 of the City's Construction
Standards, Storm Drain and On -Site Private Improvements, and is subject to compliance with
applicable accessibility requirements of the American Disabilities Act, Title 24 of the Uniform
Building Code as locally amended, and the Department of Housing and Urban
Development's Fair Housing Accessibility Guidelines.
PPP T-2: Traffic Control/Utilities All future development constructed under the Project shall be
subject to the traffic control standards specified by the City's latest Standard Plans and
Design Standards, which includes the requirement for Traffic Control Plan during construction,
the process prior to commencing construction within the City public right-of-way (including
utility work), and specifications for operational roadway and traffic control design.
5.4.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements, Impact LU-2 would be less than significant.
5.4.10 MITIGATION MEASURES
Refer to all mitigation measures presented in this Draft EIR. In instances where significant impacts are
identified as part of the Project's construction and/or operational phases, mitigation measures are provided
in the specific topic sections to reduce impacts to less -than -significant levels (or, if it is not possible to reduce
the Project's impacts to less -than -significant levels, mitigation is provided to minimize impacts to the maximum
level feasible).
5.4.1 1 LEVEL OF SIGNIFICANCE AFTER MITIGATION
With implementation of mitigation measures presented in this Draft EIR, the proposed Project would be
consistent with land use plans, policies, and regulations adopted for the purpose of avoiding or mitigating
an environmental effect. Therefore, no significant and unavoidable adverse impacts related to land use
would occur.
City of Tustin 5.4-47
Draft EIR
June 2024
Enderle Center Rezone
5.4 Land Use and
5.4.1 2 REFERENCES
BFSA Environmental Services. (2023a). Archaeological Resources Records Search Results for the Enderle
Center Project, Tustin.
California Department of Forestry and Fire Protection. (2022). Fire and Resource Assessment Program.
Retrieved from: https://www.fire.ca.gov/what-we-do/fire- resource -assessment- program
City of Tustin. (2018). General Plan. Available at: www.tustinca.org/DocumentCenter/View/713/City-of-
Tustin-General-Plan-PDF?bidld=
City of Tustin. (2022). Final Housing Element Update 2027-2029. Available at:
https://www.tustinca.org/1211 Housing -Element -Update
Federal Emergency Management Agency. (2009, December 3). Map Number 06059COl 64J. Retrieved
from Federal Insurance Rate Map:
https://msc.fema.gov/portaI/search?AddressQuery=enderle%20center%2C%2Otustin%2C%2Oc
a
LSA. (2024). Enderle Center Project Air Quality, Energy, and Greenhouse Gas Report
Southern California Association of Governments. (2020, September). Connect SoCal 2020-2045 Regional
Transportation PlanlSustainable Communities Strategy. Retrieved from
https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocaI-
plan O.pdf?1606001176
Southern California Association of Governments. (2024, April). Connect SoCal 2024-2050 Regional
Transportation PlanlSustainable Communities Strategy. Retrieved from https://scag.ca.gov/connect-
socal
City of Tustin 5.4-48
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
5.5 Noise
5.5.1 INTRODUCTION
This EIR section evaluates the potential noise and vibration impacts that could result from implementation of
the proposed Project. It discusses the existing noise environment within and around the Project site, as well
as the regulatory framework for regulation of noise. This section analyzes the effect of the proposed Project
on the existing ambient noise environment during demolition, construction, and operational activities; and
evaluates the proposed Project's noise effects for consistency with relevant local agency noise policies and
regulations. The analysis in this section also addresses impacts related to groundborne vibration. Information
in this section is based on the:
• City of Tustin General Plan (including 2021-2029 Housing Element), adopted November 2018 and
updated October 2022.
• Tustin City Code.
• Noise and Vibration Impact Analysis, LSA, March 2024, Appendix C.
Noise and Vibration Terminology
Various noise descriptors are utilized in this EIR analysis, and are summarized as follows:
dB: Decibel, the standard unit of measurement for sound pressure level.
dBA: A -weighted decibel, an overall frequency -weighted sound level in decibels that approximates the
frequency response of the human ear.
Leq: The equivalent sound level, which is used to describe noise over a specified period of time, typically 1
hour, in terms of a single numerical value. The Leq of a time -varying signal and that of a steady signal are
the same if they deliver the same acoustic energy over a given time. The Leq may also be referred to as the
average sound level.
Lmax: The instantaneous maximum noise level experienced during a given period of time.
Lmin: The instantaneous minimum noise level experienced during a given period of time.
Lx: The sound level that is equaled or exceeded "x" percent of a specified time period. The "x" thus
represents the percentage of time a noise level is exceeded. For instance, L50 and L90 represents the noise
levels that are exceeded 50 percent and 90 percent of the time, respectively.
Ldn: Also termed the "day -night" average noise level (DNL), Ldn is a measure of the average of A -weighted
sound levels occurring during a 24-hour period, accounting for the greater sensitivity of most people to
nighttime noise by weighting noise levels at night (penalizing" nighttime noises). Noise between 10:00 p.m.
and 7:00 a.m. is weighted by adding 10 dBA to take into account the greater annoyance of nighttime noises.
CNEL: The Community Noise Equivalent Level, which, similar to the Ldn, is the average A -weighted noise
level during a 24-hour day that is obtained after an addition of 5 dBA to measured noise levels between
the hours of 7:00 p.m. to 10:00 p.m. and after an addition of 10 dBA to noise levels between the hours of
10:00 p.m. to 7:00 a.m. to account for noise sensitivity in the evening and nighttime, respectively.
Ambient Noise Level: The background noise level associated with a given environment at a specified time
and is usually a composite of sound from many sources from many directions.
City of Tustin 5.5-1
Draft EIR
June 2024
Enderle Center Rezone Project 5.5 Noise
Effects of Noise
Noise is generally loud, unpleasant, unexpected, or undesired sound that is typically associated with human
activity that is a nuisance or disruptive. The effects of noise on people can be placed into four general
categories:
• Subjective effects (e.g., dissatisfaction, annoyance)
• Interference effects (e.g., communication, sleep, and learning interference)
• Physiological effects (e.g., startle response)
• Physical effects (e.g., hearing loss)
Although exposure to high noise levels has been demonstrated to cause physical and physiological effects,
the principal human responses to typical environmental noise exposure are related to subjective effects and
interference with activities. Interference effects refer to interruption of daily activities and include
interference with human communication activities, such as normal conversations, watching television, telephone
conversations, and interference with sleep. Sleep interference effects can include both awakening and
arousal to a lesser state of sleep. Regarding the subjective effects, the responses of individuals to similar
noise events are diverse and are influenced by many factors, including the type of noise, the perceived
importance of the noise, the appropriateness of the noise to the setting, the duration of the noise, the time of
day and the type of activity during which the noise occurs, and individual noise sensitivity.
In general, the more a new noise level exceeds the previously existing ambient noise level, the less
acceptable the new noise level will be to those hearing it. Regarding increases in A -weighted noise levels,
the following relationships generally occur:
• Except in carefully controlled laboratory experiments, a change of 1 dBA cannot be perceived.
• Outside of the laboratory, a 3-dBA change in noise levels is considered a barely perceivable difference.
• A change in noise levels of 5 dBA is considered a readily perceivable difference.
• A change in noise levels of 10 dBA is subjectively heard as doubling of the perceived loudness.
Noise Attenuation
Stationary point sources of noise, including mobile sources such as idling vehicles, attenuate (lessen) at a rate
of b dBA per doubling of distance from the source over hard surfaces to 7.5 dBA per doubling of distance
from the source over hard surfaces, depending on the topography of the area and environmental conditions
(e.g., atmospheric conditions, noise barriers [either vegetative or manufactured]). Thus, a noise measured at
90 dBA 50 feet from the source would attenuate to about 84 dBA at 100 feet, 78 dBA at 200 feet, 72 dBA
at 400 feet, and so forth. Widely distributed noise, such as a large industrial facility spread over many
acres or a street with moving vehicles, would typically attenuate at a lower rate, approximately 4 to b dBA
per doubling of distance from the source.
Hard sites are those with a reflective surface between the source and the receiver, such as asphalt or concrete
surfaces or smooth bodies of water. No excess ground attenuation is assumed for hard sites and the changes
in noise levels with distance (drop-off rate) is simply the geometric spreading of the noise from the source.
Soft sites have an absorptive ground surface such as soft dirt, grass, or scattered bushes and trees. In addition
to geometric spreading, an excess ground attenuation value of 1.5 dBA (per doubling distance) is normally
assumed for soft sites. Line sources (such as traffic noise from vehicles) attenuate at a rate between 3 dBA
for hard sites and 4.5 dBA for soft sites for each doubling of distance from the reference measurement.
City of Tustin 5.5-2
Draft EIR
June 2024
Enderle Center Rezone Project 5.5 Noise
Fundamentals of Vibration
Vibration is energy transmitted in waves through the ground or man-made structures. These energy waves
generally dissipate with distance from the vibration source. There are several different methods that are
used to quantify vibration. The peak particle velocity (PPV) is defined as the maximum instantaneous peak
of the vibration signal. The PPV is most frequently used to describe vibration impacts to buildings but is not
always suitable for evaluating human response (annoyance) because it takes some time for the human body
to respond to vibration signals. Instead, the human body responds to average vibration amplitude often
described as the root mean square (RMS). The RMS amplitude is defined as the average of the squared
amplitude of the signal and is most frequently used to describe the effect of vibration on the human body.
Decibel notation (VdB) is commonly used to measure RMS. VdB serves to reduce the range of numbers used
to describe human response to vibration. Typically, ground -borne vibration generated by man-made
activities attenuates rapidly with distance from the source of the vibration. Sensitive receivers for vibration
include structures (especially older masonry structures), people (especially residents, the elderly, and sick),
and vibration -sensitive equipment.
The background vibration -velocity level in residential areas is generally 50 VdB. Ground -borne vibration is
normally perceptible to humans at approximately 65 VdB. For most people, a vibration -velocity level of 75
VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels. Typical
outdoor sources of perceptible ground -borne vibration are construction equipment, steel -wheeled trains, and
traffic on rough roads. If a roadway is smooth, the ground -borne vibration is rarely perceptible. The range
of interest is from approximately 50 VdB, which is the typical background vibration -velocity level, to 100
VdB, which is the general threshold where minor damage can occur in fragile buildings.
5.5.2 REGULATORY SETTING
5.5.2.1 Federal Regulations
There are no federal regulations concerning noise impacts that are applicable to the Project.
5.5.2.2 State Regulations
Caltrans Vibration Guidance Manual
There are no vibration standards that are specifically applicable to the proposed Project, hence, California
Department of Transportation's (Caltrans) Transportation and Construction Vibration Guidance Manual
guidelines are used as a screening tool for assessing the potential for adverse vibration effects related to
human perception, which are listed in Table 5.5-1. It should be noted that the human annoyance threshold
of 0.04 is less (more conservative) than the Federal Transit Administration (FTA) building damage threshold
for a reinforced concrete building.
Table 5.5-1: Vibration Screening Standards
Peak Particle Velocity for
Caltrans Guidelines Continuous Sources
(PPV) (in/sec)
Human Annoyance
Barely Perceptible
0.01
Distinctly Perceptible
0.04
Strongly Perceptible
0.10
Severe
0.40
Source: Caltrans Transportation and Construction Vibration Guidance Manual, September 2013, Tables 19 & 20.
City of Tustin 5.5-3
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
Title 24, California Building Code
State regulations related to noise include requirements for the construction of new hotels, motels, apartment
houses, and dwellings other than detached single-family dwellings that are intended to limit the extent of
noise transmitted into habitable spaces. These requirements are collectively known as the California Noise
Insulation Standards and are found in California Code of Regulations, Title 24 (known as the Building
Standards Administrative Code), Part 2 (known as the California Building Code), Appendix Chapters 12 and
1 2A. For limiting noise transmitted between adjacent dwelling units, the noise insulation standards specify
the extent to which walls, doors, and floor ceiling assemblies must block or absorb sound. For limiting noise
from exterior sources, the noise insulation standards set forth an interior standard of DNL 45 dBA in any
habitable room and, where such units are proposed in areas subject to noise levels greater than DNL 60
dBA, require an acoustical analysis demonstrating how dwelling units have been designed to meet this interior
standard. If the interior noise level depends upon windows being closed, the design for the structure must
also specify a ventilation or air conditioning system to provide a habitable interior environment.
The mandatory measures for non-residential buildings state that new construction shall provide an interior
noise level that does not exceed an hourly equivalent level of 50 dBA Leq in occupied areas during any
hour of operation. Title 24 standards are enforced through the City's building permit application process.
5.5.2.3 Local and Regional Regulations
County of Orange General Aviation Noise Ordinance
To reduce noise from operation of John Wayne Airport (SNA) the General Aviation Noise Ordinance was
adopted by the County to regulate the hours of operation and the maximum permitted noise levels
associated with general aviation operations. The General Aviation Noise Ordinance specifies noise limits at
each noise monitoring station that vary by time of day. The Ordinance also prohibits commercial aircraft
departures between the hours of 10:00 p.m. and 7:00 a.m. and arrivals between the hours of 1 1:00 p.m.
and 7:00 a.m.
John Wayne Airport Environs Land Use Plan
The John Wayne Airport Environs Land Use Plan (AELUP) was adopted in 1975 and amended in 2008 and
is the applicable compatibility plan for John Wayne Airport. The land use compatibility plan establishes
policies to protect the public from the adverse effects of aircraft noise, to ensure that people and facilities
are not concentrated in areas susceptible to aircraft accidents, and to ensure that no structures or activities
adversely affect navigable airspace. Further, implementation of this plan forestalls urban encroachment on
the airport and allows for its continued operation (Airport Land Use Commission for Orange County, 2008).
General Plan
The City's General Plan Land Use Element includes the following goals and policies that are relevant to the
proposed Project (City of Tustin, 2018):
Goal 2: Ensure that future land use decisions are the result of sound and comprehensive
planning.
Policy 2.6: Maintain consistency with the Airport Environs Land Use Plan (AELUP) for John Wayne
Airport in terms of maximum allowable building height, noise levels, safety areas, and other
applicable standards.
City of Tustin 5.5-4
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
The City's General Plan Noise Element includes the following goals and policies that are relevant to the
proposed Project:
Goal 2: Incorporate noise considerations into land use planning decisions.
Policy 2.3: Use noise/land use compatibility standards as a guide for future planning and development.
Policy 2A Review proposed projects in terms of compatibility with nearby noise -sensitive land uses
with the intent of reducing noise impacts.
Policy 2.5: Require new residential developments located in proximity to existing commercial/industrial
operations to control residential interior noise levels as a condition of approval.
Policy 2.8: Replace a significant noise source with non -noise generating land uses when plans for future
use of areas are developed.
Goal 3: Develop measures to control non -transportation noise impacts.
Policy 3.1: Use noise/land use compatibility standards as a guide for future planning and development.
Policy 3.2: Minimize the impacts of construction noise on adjacent land uses through limiting the
permitted hours of activity.
Policy 3.2: Use noise/land use compatibility standards as a guide for future planning and development.
The City's Noise Element also includes standards related to excessive noise levels. The City's General Plan
noise standards for land uses are provided in Table 5.5-2.
Table 5.5-2: City of Tustin General Plan Noise Element Standards
Land Use
Noise Standards'
Interior2,3
Exterior
Residential -Single family, multifamily, duplex, mobile home
CNEL 45 dB
CNEL 65 dB4
Residential -Transient lodging, hotels, motels, nursing homes, hospitals
CNEL 45 dB
CNEL 65 dB
Private offices, church sanctuaries, libraries, board rooms, conference rooms,
theaters, auditoriums, concert halls, meeting halls, etc.
Leq(1 2) 45 dB(A)
-
Schools
Leq(1 2) 45 dB(A)
Leq(1 2) 67
dB(A)5
General offices, reception, clerical, etc.
Leq(1 2) 50 dB(A)
Bank lobby, retail store, restaurant, typing pool, etc.
Leq(1 2) 55 dB(A)
Manufacturing, kitchen, warehousing, etc.
Leq(1 2) 65 dB(A)
Parks, playgrounds
-
CNEL 65 dB5
Golf courses, outdoor spectator sports, amusement parks
CNEL 70 dB5
Source: City of Tustin General Plan Noise Element
Notes: (1) CNEL: Community Noise Equivalent Level. Leq(1 2): The A -weighted equivalent sound level averaged over a 12-hour period (usually
the hours of operation). (2) Noise standard with windows closed. Mechanical ventilation shall be provided per UBC requirements to provide a
habitable environment. (3) Indoor environment excluding bathrooms, toilets, closets and corridors. (4) Outdoor environment limited to rear yard
of single-family homes, multifamily patios and balconies (with a depth of 6' or more) and common recreation areas. (5) Outdoor environment
limited to playground areas, picnic areas, and other areas of frequent human use.
Tustin City Code
Pursuant to Tustin City Code Sections 4614 and 4615, noise levels at residential properties are restricted
from exceeding certain noise levels for extended periods of time. Table 5.5-3 provides the Municipal Code
interior and exterior noise standards that are applied to residential properties.
City of Tustin 5.5-5
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
Table 5.5-3: City of Tustin Municipal Code Residential Noise Standards
Land Use
Interior
Exterior
Time
Permissible Noise
Levels (dBA)
Time
Permissible Noise
Levels (dBA)
7:00 a.m. to 10:00 p.m.
55 dBA
7:00 a.m. to 10:00 p.m.
55 dBA
Residential
10:00 p.m. to 7:00 a.m.
40 dBA
10:00 p.m. to 7:00 a.m.
50 dBA
Mixed -Use
7:00 a.m.-10:00 p.m.
(residential uses only)
55 dBA
any time
60 dBA
10:00 p.m. to 7:00 a.m.
(residential uses only)
45 dBA
Source: City of Tustin Municipal Code, Article 4, Chapter 6, Section 4614 and 4615.
With respect to construction -related noise, Section 4616 of the Tustin City Code specifies that noise sources
associated with construction activities are prohibited before 7:00 AM and after 6:00 PM, Monday through
Friday; before 9:00 AM and after 5:00 PM on Saturdays; anytime on Sundays; or anytime during City -
observed federal holidays (City of Tustin, 2024).
5.5.3 ENVIRONMENTAL SETTING
Existing Noise Levels
To assess existing noise levels of the environment, long-term (24-hour) noise level measurements were
conducted on January 23 and 24, 2024, at two locations as shown on Figure 5.5-1. The background ambient
noise levels in the Project area are dominated by the transportation -related noise associated with surface
streets and surrounding commercial and office uses. Table 5.5-4 provides a summary of the measured hourly
noise levels and calculated CNEL level from the long-term noise level measurements. As shown in Table 5.5-
4, the calculated CNEL levels range from 66.9 dBA CNEL to 73.7 dBA CNEL.
Table 5.5-4: Summary of 24-Hour Ambient Noise Level Measurements
Location
Daytime
Noise
Levels'
(dBA Leq)
Evening
Noise
Levels2
(dBA Leq)
Nighttime
Noise
Levels3
(dBA Leq)
Daily Noise
Levels
(dBA CNEL)
14122 Paseo Verde, Tustin, CA
92780. Located in the front yard of a
LT-1
home on a tree, approximately 60
64.7— 66.8
61.9 — 64.9
50.4 — 62.3
66.9
feet away from the Vandenberg Lane
centerline.
14032 Enderle Center Drive, #102,
Tustin, CA 92780. Located south of an
LT-2
office building in the parking lot on a
65.8 — 68.8
69.4 — 69.8
62.4 — 69.2
73.7
light pole, approximately 120 feet
away from the Enderle Center Drive
centerline.
Source: Noise and Vibration Impact Analysis, 2024 (Appendix C).
Note: Noise measurements were conducted from January 23 to January 24, 2024, starting at 2:00 p.m.
Daytime Noise Levels = noise levels during the hours from 7:00 a.m. to 7:00 p.m.
2 Evening Noise Levels = noise levels during the hours from 7:00 p.m. to 10:00 p.m.
3 Nighttime Noise Levels = noise levels during the hours from 10:00 p.m. to 7:00 a.m.
Existing Vibration
Aside from periodic construction work that may occur in the vicinity of the Project area, the Project site and
adjacent land uses are not currently exposed to sources of groundborne vibration.
City of Tustin 5.5-6
Draft EIR
June 2024
Enderle Center Rezone Project 5.5 Noise
Existing Airport Noise
John Wayne Airport (SNA) is located approximately 5.5 miles southwest of the Project site. The Project site
is located outside of the airport's 60 CNEL noise contour. In addition, the General Aviation Noise Ordinance
restricts airport operations between 1 1:00 p.m. and 7:00 a.m., to limit the hours of noise generated by SNA.
Sensitive Receptors
Sensitive receptors are generally defined as locations where people reside or where the presence of
unwanted sound could otherwise adversely affect the use of the land. Noise -sensitive land uses are generally
considered to include: residences, schools, hospitals, and recreation areas. Existing offsite sensitive noise
receptors where someone can remain for 24 hours in the vicinity of the Project site consists of residences. The
closest offsite residences are located 70 feet south of the site as listed in Table 5.5-5.
Table 5.5-5: Closest Sensitive Receptors to the Project Site
Receptor Description
Distance and Direction from the Project Site
Residential
70 feet to the south
Commercial/Office
20 feet to the east
Commercial/Office
140 feet to the north
Commercial/Office
95 feet to the west
Source: Noise and Vibration Impact Analysis, 2024 (Appendix C).
City of Tustin 5.5-7
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
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City of Tustin 5.5-8
Draft EIR
June 2024
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5.5 Noise
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City of Tustin 5.5-10
Draft EIR
June 2024
Airport Noise Contours
A RMT Location � � N Airport Property (Approx.)
2022 Annual CNEL Contours (60-75 dB) — Runways I Taxiways
Enderle Center Rezone Project
City of Tustin
Figure 5.5-2
Enderle Center Rezone
5.5 Noise
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City of Tustin 5.5-12
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
5.5.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to
result in:
N0I-1 Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity
of the project in excess of standards established in the local general plan or noise ordinance, or
applicable standards of other agencies.
NOI-2 Generation of excessive groundborne vibration or groundborne noise levels.
NOI-3 For a project located within the vicinity of a private airstrip or an airport land use plan, or where
such a plan has not been adopted, within two miles of a public airport or public use airport,
expose people residing or working in the project area to excessive noise levels.
Construction Noise and Vibration
A potentially significant construction noise and vibration impact could occur if Project -related construction
activities:
• Occur before 7:00 AM and after 6:00 PM Monday through Friday, before 9:00 AM and after 5:00 PM
on Saturday, anytime on Sundays, or anytime on City -observed federal holidays (City of Tustin, 2024);
• Create noise levels which exceeds the Federal Transit Administration (FTA) threshold of daytime exterior
construction noise level of 80 dBA Leq or 70 dBA Leq nighttime acceptable noise level threshold at
nearby sensitive receiver locations; or
• Generate vibration levels which exceed the Caltrans Transportation and Construction Vibration Guidance
Manual vibration threshold of 0.3 PPV in/sec at nearby buildings.
Off -Site Traffic Noise
A potentially significant noise and vibration impact could occur if offsite traffic noise levels at existing and
future noise -sensitive land uses (e.g., residential, etc.):
• Are less than 60 dBA CNEL and the project creates a readily perceptible 5 dBA CNEL or greater project -
related noise level increase; or
• Range from 60 to 64 dBA CNEL and the project creates a barely perceptible 3 dBA CNEL or greater
project -related noise level increase; or
• Already exceeds 65 dBA CNEL, and the project creates a community noise level impact of greater than
1.5 dBA CNEL.
Operational Noise
The proposed Project may result in a potentially significant operational noise impact if Project -related
operational (stationary source) noise levels exceed the exterior 55 dBA daytime (7:00 a.m. to 10:00 p.m.)
or 50 dBA nighttime (10:00 p.m. to 7:00 a.m.) noise level standards for sensitive residential land uses.
5.5.5 METHODOLOGY
Construction Noise
To identify the temporary construction noise contribution to the existing ambient noise environment, the
construction noise levels anticipated from usage of construction equipment necessary for future buildout of
City of Tustin 5.5-13
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.5 Noise
the proposed Project were combined with the existing ambient noise level measurements at the sensitive
receiver locations. The construction noise levels are compared against the thresholds listed previously to
assess the level of significance associated with temporary construction noise level impacts.
Operational Noise
The primary source of noise associated with the operation from buildout of the proposed Project would be
from vehicular trips. The expected roadway noise level increases from vehicular traffic were calculated using
the Federal Highway Administration (FHWA) traffic noise prediction model and the average daily traffic
volumes prepared for the proposed Project. As detailed in Section 5.9, Transportation, existing uses on the
Project site generate approximately 7,058 average daily trips (ADT). With the buildout of the proposed
housing units and remaining commercial buildout capacity, the proposed Project would generate
approximately 11,470 ADT, resulting in 4,412 net new ADT. The increase in noise levels generated by the
vehicular trips have been quantitatively estimated and compared to applicable noise standards and
thresholds of significance.
Secondary sources of noise would include new stationary sources (such as heating, ventilation, and air
conditioning units) associated with the buildout of the new buildings on the Project site. The increase in noise
levels generated by these activities has been qualitatively analyzed and additional requirements for future
projects analysis are specified.
Vibration
Aside from noise levels, groundborne vibration would also be generated during construction at future
buildout of the proposed Project by various construction -related activities and equipment; and could be
generated by truck traffic traveling to and from the Project site. The potential ground -borne vibration levels
resulting from construction activities occurring from the proposed Project were estimated by data published
by the Federal Transit Administration (FTA). Thus, the groundborne vibration levels generated by these
sources have also been quantitatively estimated and compared to the applicable thresholds of significance
listed previously.
5.5.6 ENVIRONMENTAL IMPACTS
IMPACT NOI-1: THE PROJECT WOULD NOT RESULT IN GENERATION OF A SUBSTANTIAL
TEMPORARY OR PERMANENT INCREASE IN AMBIENT NOISE LEVELS IN THE VICINITY
OF THE PROJECT IN EXCESS OF STANDARDS ESTABLISHED IN THE LOCAL GENERAL
PLAN OR NOISE ORDINANCE, OR APPLICABLE STANDARDS OF OTHER AGENCIES.
Less than Significant Impact with Mitigation.
Construction
As described in Section 3.0, Project Description of this DEIR, the proposed Project would consist of a Housing
Overlay (HO) zone (overlay district) for the Project site which would allow residential on the Project site to
accommodate up to 413 housing units on 7 acres in areas that are currently used for surface parking. In
addition, there is a remaining development potential of 118,474 SF of nonresidential land uses (i.e. retail,
restaurant, office, etc.). The proposed Project does not propose any specific development projects; therefore,
no development is proposed as part of this Project. However, the following analysis considers the future
development of 413 units associated with the HO zone and remaining commercial buildout capacity which
is expected to occur anytime between October 2024 and October 2029.
Construction activities for the residential units would include demolition of the surface parking lot, site
preparation, grading, building construction, paving, and architectural coatings. As such, noise generated by
City of Tustin 5.5-14
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
construction equipment would include a combination of trucks, power tools, concrete mixers, and portable
generators that can reach high levels when combined. Construction is expected to occur in the following
stages: site preparation and grading, building construction, architectural coating, paving. The project
construction composite noise levels at a distance of 50 feet would range from 74 dBA Leq to 88 dBA Leq
with the highest noise levels occurring during the site preparation and grading phases, as shown in Table
5.5-6.
Table 5.5-6: Construction Reference Noise Levels
Equipment Description
Acoustical Usage Factor (%)'
Maximum Noise Level (Lmax) at 50 Feet2
Auger Drill Rig
20
84
Backhoes
40
80
Compactor (ground)
20
80
Compressor
40
80
Cranes
16
85
Dozers
40
85
Dump Trucks
40
84
Excavators
40
85
Flat Bed Trucks
40
84
Forklift
20
85
Front-end Loaders
40
80
Graders
40
85
Impact Pile Drivers
20
95
Jackhammers
20
85
Paver
50
77
Pickup Truck
40
55
Pneumatic Tools
50
85
Pumps
50
77
Rock Drills
20
85
Rollers
20
85
Scrapers
40
85
Tractors
40
84
Trencher
50
80
Welder
40
73
Source: FHWA Roadway Construction Noise Model User's Ciuide, table I (I-HWA 2UU6). Note: Noise levels reported in this table are rounded to
the nearest whole number.
1 Usage factor is the percentage of time during a construction noise operation that a piece of construction equipment is operating at full power.
2 Maximum noise levels were developed based on Specification 721.560 from the Central Artery/Tunnel program to be consistent with the City
of Boston's Noise Code for the "Big Dig" project.
FHWA = Federal Highway Administration Lmax = maximum instantaneous sound level
Per the Tustin City Code Section 4616, construction activities are allowed only between the hours of 7:00
a.m. and 6:00 p.m., Monday through Friday, and 9:00 a.m. to 5:00 p.m. on Saturdays, with no activity
City of Tustin 5.5-15
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.5 Noise
allowed on Sundays and City -observed federal holidays. Construction activities for future buildout would be
required to occur within the City's designated hours. Thus, future buildout construction activities would be in
compliance with the City's construction -related noise standards.
In addition, construction noise would be temporary in nature as the operation of each piece of construction
equipment would not be constant throughout the construction day, and equipment would be turned off when
not in use. The typical operating cycle for a piece of construction equipment involves one or two minutes of
full power operation followed by three or four minutes at lower power settings. Construction equipment for
future buildout is anticipated to include a combination of trucks, power tools, concrete mixers, and portable
generators.
While construction noise would vary, it is expected that composite noise levels during construction at the
nearest residential uses south of the Project would reach 70 dBA Leq. These predicted noise levels would
only occur when all construction equipment is operating simultaneously and therefore, are conservative
assumptions. While construction -related short-term noise levels have the potential to be higher than existing
ambient noise levels in the Project area under existing conditions, the noise impacts would no longer occur
once construction is completed. As shown on Table 5.5-7, construction noise from future buildout of the
proposed Project at the nearby receptor locations would range from 67 to 70 dBA Leq, which would not
exceed the 90 dBA Leq and 100 dBA Leq 1-hour construction noise level criteria as established by the FTA
for residential and commercial land uses. Therefore, impacts related to construction noise would be less than
significant.
Table 5.5-7: Construction Noise Level at Nearest Receptors
Composite Noise
Composite Noise Level
Receptor (Location)
Level (dBA Leq) at
Distance (feet)
(dBA Leq)
50 feet'
Residential (South)
380
70
Commercial/Office (East)
380
70
88
Residential (North)
440
69
Office (West)
515
67
Source: Noise and Vibration Impact Analysis, 2024 (Appendix C)
1 The composite construction noise level represents the grading phase which is expected to result in the greatest noise level as
compared to other phases.
Operation
Less than Significant Impact.
As described previously, a specific development project is not proposed as part of this Project, thus the
following analysis considers the future development of 413 units associated with the HO Zone and remaining
commercial buildout capacity, which is expected to occur anytime between October 2024 and October
2029.
Potential noise impacts associated with the operations of the proposed Project after buildout would be from
Project -generated vehicular traffic on the nearby roadways and from onsite activities, as described below.
The existing uses generate approximately 7,058 average daily trips (ADT). With the buildout of the
proposed housing units and remaining commercial buildout capacity, the proposed Project would generate
approximately 11,470 ADT, resulting in 4,412 net new ADT.
City of Tustin 5.5-16
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
Traffic Noise Impacts
Vehicle noise is a combination of the noise produced by the engine, exhaust and tires. The level of traffic
noise depends on three primary factors (1) the volume of traffic, (2) the speed of traffic, and (3) the number
of trucks in the flow of traffic.
As detailed in Section 5.9, Transportation, buildout of the proposed Project is anticipated to generate
approximately 4,412 net new ADT, including 313 new trips during the AM peak hour and 393 new trips
during the PM peak hour. Regional access to the Project site is provided by 1-55. Local access to the site is
provided via 17th Street, Yorba Street, Enderle Center Drive, and Vanderberg Lane. Table 5.5-8 provides
the traffic noise levels for the existing with and without Project scenarios and opening year with and without
Project, and future year with and without Project scenarios. These noise levels represent the worst -case
scenario, which assumes no shielding is provided between the traffic and the location where the noise contours
are drawn.
As shown in Table 5.5-8, the increase in Project -related traffic noise would be no greater than 2.3 dBA from
existing baseline conditions which is below the threshold of a 3.0 dBA noise level increase. Therefore, traffic
noise impacts from buildout of the proposed Project on off -site sensitive receptors would be less than
significant.
Stationary Noise Impacts
The Project and adjacent offsite land uses would be potentially exposed to stationary -source noise impacts
from the proposed onsite heating, ventilation, and air conditioning (HVAC) equipment and truck deliveries
and loading and unloading activities. It is expected that on -site stationary sources would meet the City of
Tustin maximum noise level standards.
However, given that specific details related to stationary impacts of future development within Enderle
Center are not known at this time, and will not be known until a development project is proposed, Mitigation
Measure NOI-1 (MM NOI-1) is included. MM NOI-1 would require all future development projects to
prepare a project -specific Final Acoustical Report to determine whether any proposed exterior noise
sensitive areas would experience noise levels greater than 65 dBA CNEL or interior noise levels of 45 dBA
CNEL; and to identify any noise reduction features for the proposed development (e.g. upgraded windows
with Sound Transmission Class (STC) ratings of 30-35). Additionally, the Final Acoustical Report shall confirm
that proposed siting of noise -generating stationary sources, if any, will not result in an exceedance of
applicable noise thresholds at surrounding land uses. Thus, with implementation of MM NOI-1, impacts
related to stationary noise impacts would be less than significant.
City of Tustin 5.5-17
Draft EIR
June 2024
Enderle Center Rezone
Table 5.5-8: Traffic Noise Levels Without and With Proposed Project
5.5 Noise
Existing
Opening Year - No
Opening Year - With Project
Future Year - No
Future Year - With Project
Project
Project
CNEL (dBA)
CNEL (dBA)
CNEL (dBA)
Increase
CNEL (dBA)
CNEL (dBA)
Increase
Roadway Segment
50 ft from
50 ft from
50 ft from
from
50 ft from
50 ft from
from
ADT
Centerline
ADT
Centerline
ADT
Centerline
Baseline
ADT
Centerline
ADT
Centerline
Baseline
of Nearest
of Nearest
of Nearest
Conditions
of Nearest
of Nearest
Conditions
Lane
Lane
Lane
(dBA)
Lane
Lane
(dBA)
17th St between SR-
55 SB Ramps & SR-55
39,346
68.9
39,802
68.9
44,963
69.5
0.6
41,852
69.2
47,013
69.7
0.5
NB Ramps
17th St between SR-
55 NB Ramps &
38,861
68.8
39,155
68.9
46,611
69.6
0.7
40,478
69.0
47,934
69.7
0.7
Carroll Way-Yorba St
South
17th St between
Carroll Way-Yorba St
34,006
68.3
34,151
68.3
39,312
68.9
0.6
34,801
68.4
39,963
69.0
0.6
South & Yorba St
North-Enderle Center
Dr
Yorba St
between 17th St
& Vandenberg
5,174
60.6
5,607
60.9
10,768
63.8
2.9
7,555
62.2
12,716
64.5
2.3
Ln
Enderle Center Dr
between 17th St &
3,197
53.6
3,453
53.9
6,320
56.6
2.7
4,604
55.2
7,471
57.3
2.1
Vandenberg Ln
Source: Noise and Vibration Impact Analysis, 2024 (Appendix C)
Note: Shaded cells indicate roadway segments adjacent to the project site.
ADT = average daily traffic
City of Tustin 5.5-18
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.5 Noise
IMPACT NOI-2: THE PROJECT WOULD NOT RESULT IN GENERATION OF EXCESSIVE GROUNDBORNE
VIBRATION OR GROUNDBORNE NOISE LEVELS.
Less than Significant Impact.
Construction
As described in Section 3.0, Project Description of this DEIR, residential uses are currently not allowed on the
Project site. The Project includes a General Plan Amendment (GPA) to establish a HO, which would allow for
the development of up to 413 residential units over approximately 7 acres of developable land within the
existing 1 1.8-acre site. The proposed Project does not propose any specific development projects; therefore,
no development is proposed as part of this Project. However, the following analysis considers the future
development of 413 units associated with the Housing Overlay Zone and remaining commercial buildout
capacity which could occur anytime between October 2024 and October 2029.
Construction activities for future development of the proposed Project would include demolition, excavation,
and grading activities, which have the potential to generate low levels of groundborne vibration. People
working in close proximity to the construction could be exposed to the generation of excessive groundborne
vibration or groundborne noise levels related to construction activities. The results from vibration can range
from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibrations
at moderate levels, to slight structural damage at the highest levels. Site ground vibrations from construction
activities very rarely reach the levels that can damage structures, but they can be perceived in the audible
range and be felt in buildings very close to a construction site.
Demolition, excavation, and grading activities would be required for the future buildout of the Project and
could result in varying degrees of ground vibration, depending on the equipment and methods used, distance
to the affected structures and soil type. For example, FTA guidelines show that a building consisting of
reinforced concrete, steel, or timber, sans plaster would not result in any construction vibration damage (LSA,
2024).Based on the reference vibration levels provided by the FTA, a large bulldozer represents the peak
source of vibration with a reference velocity of 0.089 in/sec peak particle velocity (PPV) or 87 vibration
velocity decibels (VdB) of ground -borne vibration when measured at 25 feet as shown in Table 5.5-9.
Table 5.5-9: Vibration Source Levels for Construction Equipment
Equipment
Reference PPV/Lv at 25 feet
Peak Particle Velocity
(inches/second)
Approximate Vibration Level
(Lv) (VdB) at 25 feet
Pile Driver (Impact), Typical
0.644
104
Pile Driver (Sonic), Typical
0.170
93
Vibratory Roller
0.210
94
Hoe Ram
0.089
87
Large Bulldozer2
0.089
87
Caisson Drilling
0.089
87
Loaded Trucks2
0.076
86
Jackhammer
0.035
79
Small Bulldozer
0.003
58
Source: Noise and Vibration Impact Analysis, 2024 (Appendix C)
RMS vibration velocity in decibels (VdB) is 1 pin/sec.
s Equipment shown in bold is expected to be used on site.
pin/sec = microinches per second; ft = foot feet; FTA = Federal Transit Administration; in/sec = inch inches per second; LV
= velocity in decibels; PPV = peak particle velocity; RMS = root -mean -square; VdB = vibration velocity decibels
City of Tustin 5.5-19
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.5 Noise
A significant vibration impact could occur if construction activities of the future buildout generate vibration
levels which exceed the FTA guidelines vibration threshold of 0.2 PPV in/sec at receiver locations or if
construction were to occur during the City's prohibited hours.
The primary source of vibration during future construction would be the operation of a bulldozer. As shown
on Table 5.5-9, a large bulldozer would create a vibration level of 0.089 inch per second PPV at 25 feet.
According to the Noise and Vibration Impact Analysis prepared for the proposed Project, the vibration level
at the nearest offsite structure (70 feet away) would be 0.019 inch per second PPV during future buildout,
as shown in Table 5.5-10, which is below the FTA vibration threshold of 0.2 PPV inch per second (LSA, 2024).
Additionally, Section 4616 of the Tustin City Code specifies that noise sources associated with construction
activities are prohibited before 7:00 AM and after 6:00 PM, Monday through Friday; before 9:00 AM and
after 5:00 PM on Saturdays; anytime on Sundays; or anytime during City -observed federal holidays.
Therefore, construction related vibration would not occur during sensitive nighttime hours. Therefore, impacts
related to construction vibration would be less than significant.
Table 5.5-10: Construction Vibration Levels at Nearest Receptors
Receptor (Location)
Reference Vibration
Level (PPV) at 25 ft'
Distance (ft) 2
Vibration Level
(PPV)
Residential (South)
0.089
70
0.019
Commercial/Office (East)
20
0.124
Residential (North)
140
0.007
Office (West)
95
0.012
Source: Noise and Vibration Impact Analysis, 2024 (Appendix C)
' The reference vibration level is associated with a large bulldozer which is expected to be representative of the heavy equipment used
during construction.
2 The reference distance is associated with the peak condition, identified by the distance from the perimeter of construction activities to
surrounding structures
Operation
Less than Significant Impact. As described previously, no development is proposed as part of this Project,
thus the following analysis considers the future development of 413 residential units associated with the HO
zone and remaining commercial buildout capacity, which could occur in the near future.
Potential vibration impacts associated with the operations of the proposed Project after buildout would be
from vehicular traffic such as heavy trucks for residents moving in and out of the units, product deliveries to
retail and restaurant uses, and garbage trucks for solid waste disposal. Truck vibration levels are dependent
on vehicle characteristics, load, speed, and pavement conditions. However, vibration levels generated from
Project -related traffic on the adjacent roadways by on -road vehicles would not be excessive because the
rubber tires and suspension systems of on -road vehicles provide vibration isolation. The residential
development contemplated by the Project would not generate a considerable level of heavy truck traffic or
any other source of vibration. Likewise, the additional 118,474 SF of nonresidential land uses would not
generate enough heavy truck traffic on their own to result in an increase in vibration impacts beyond existing
conditions, nor would they generate any other source of vibration during operations. Thus, operational
vibration impacts would be less than significant.
IMPACT NOI-3: THE PROJECT WOULD NOT, FOR A PROJECT LOCATED WITHIN THE VICINITY OF A
PRIVATE AIRSTRIP OR AN AIRPORT LAND USE PLAN, OR WHERE SUCH A PLAN HAS
NOT BEEN ADOPTED, WITHIN TWO MILES OF A PUBLIC AIRPORT OR PUBLIC USE
City of Tustin 5.5-20
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
AIRPORT, EXPOSE PEOPLE RESIDING OR WORKING IN THE PROJECT AREA TO
EXCESSIVE NOISE LEVELS.
No Impact. The Project site is located approximately 5.5 miles northeast of John Wayne Airport. According
to Figure 5.5-2, Airport Noise Contours, of the John Wayne Airport AELUP, the Project site is not located
within the 65 dBA CNEL noise contours (OC Airport Land Use Commission, 2008). No other airports exist
within the vicinity of the Project. Thus, implementation and development of the Project would not result in a
safety hazard or exposure to excessive noise for people residing or working in the area, and impacts would
be less than significant.
5.5.7 CUMULATIVE IMPACTS
Cumulative noise assessment considers development of the proposed Project in combination with ambient
growth and other development projects within the vicinity of the Project area. As noise is a localized
phenomenon, and drastically reduces in magnitude as distance from the source increases, only projects and
ambient growth in the nearby area could combine with the proposed Project to result in cumulative noise
impacts.
Future development of the proposed Project in combination with the related projects would result in an
increase in construction -related and traffic -related noise. However, Tustin City Code Article 4, Chapter 6,
Section 4616 limits noise producing construction activities to the hours of 7:00 AM and 6:00 PM on weekdays,
between 9:00 AM and 5:00 PM on Saturdays, any anytime on Sunday or City -observed federal holidays.
Also, construction noise and vibration are localized in nature and decrease substantially with distance.
Consequently, in order to achieve a substantial cumulative increase in construction noise and vibration levels,
more than one source emitting high levels of construction noise would need to be in close proximity to
construction of the future buildout.
Table 5-1 in Section 5.0, Environmental Impact Analysis lists the cumulative projects and provides a brief
description and the distances from the Project site. The list includes 6 projects within the City of Santa Ana
and 2 projects within the City of Tustin. As shown on Figure 5-1, there are no cumulative projects adjacent to
or within hearing distance of the Project site. The closest cumulative project is Cumulative Project No. 1
(Medical Office Bldg.), which demolished an existing restaurant building and is constructing a 12,320 SF
institutional building approximately 650 feet northeast of the Project site, along 17th Street. Cumulative
construction could result in the exposure of people to the generation of excessive groundborne vibration and
noise increases. Cumulative Project No.l was approved by the Planning Commission on May 24, 2022, and
is currently under construction.
The Project is solely a change in regulations to implement the City's certified Housing Element, so no
construction is currently proposed. However, a future construction project is anticipated to occur between
October 2024 and October 2029, which would involve construction. Construction of Cumulative Project No.
1 will likely be complete before a future project is approved as a result of the proposed Project. Therefore,
it is unlikely construction activities of future projects implemented under the proposed Project would combine
with Cumulative Project No. 1. Additionally, 17th Street separates the two projects, thus construction noise
and vibration levels from the Project would not combine to become cumulatively considerable. Construction
activities for cumulative projects would also be required to adhere to Municipal Code construction noise
regulations. Thus, cumulative noise and vibration impacts associated with construction activities would be less
than significant.
Cumulative mobile source noise impacts would occur primarily as a result of increased traffic on local
roadways due to the proposed Project and related projects within the study area. Therefore, cumulative
traffic -generated noise impacts have been assessed based on the contribution of the proposed Project traffic
City of Tustin 5.5-21
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.5 Noise
volumes on the roadways in the Project vicinity. The increase in noise levels associated with the traffic volumes
of the proposed Project were previously identified. As detailed, buildout of the proposed Project would
result in noise levels much lower than the 3 dBA threshold. Therefore, the Project would not result in a
cumulatively considerable impact when combined with existing and future development. Cumulative impacts
would be less than significant.
5.5.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• Tustin City Code Article 4, Chapter 6, Section 4616
Plans, Programs, or Policies
PPP N0I-1: Construction Hours. Per the Tustin City Code Section 4616, construction activities are
allowed only between the hours of 7:00 AM and 6:00 PM, Monday through Friday and
between 9:00 AM to 5:00 PM on Saturdays with no activity allowed on Sundays and City -
observed federal holidays.
5.5.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Prior to mitigation, Impact NOI-1 would be potentially significant without mitigation. With compliance with
existing regulations, Impact NOI-2 would be less than significant. No impact would occur related to Impact
NOI-3.
5.5.10 MITIGATION MEASURES
MM N0I-1 All future development shall prepare a project -specific Final Acoustical Report to confirm
whether any proposed exterior noise sensitive areas would experience noise levels greater
than 65 dBA CNEL and whether interior noise levels would exceed 45 dBA CNEL, and
identify any noise reduction features for the proposed development (e.g. upgraded
windows with Sound Transmission Class (STC) ratings of 30-35). Additionally, the Final
Acoustical Report shall confirm that proposed siting of noise -generating stationary sources,
if any will not result in an exceedance of applicable noise thresholds at surrounding land
uses.
5.5.1 1 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact NOI-1 would be less than significant after mitigation.
5.5.12 REFERENCES
Airport Land Use Commission for Orange County. (2008, April). Airport Land Use Commission. Retrieved from
John Wayne Airport Orange County: https://www.ocair.com/about/administration/airport-
governance/commissions/airport-land-use-commission/
City of Tustin. (2018). City of Tustin General Plan. Retrieved April 2024, from City of Tustin:
https://www.tustinca.org/DocumentCenter/View/71 3/City-of-Tustin-General-Plan-PDF
City of Tustin 5.5-22
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
City of Tustin. (2024). Chapter 6, Noise Control. Retrieved from City of Tustin Municipal Code:
https://library.municode.com/ca/tustin/codes/code_of_ordinances?nodeld=ART4HESA_CH6NOC
O_4617EX
LSA. (2024). Noise and Vibration Impact Analysis Enderle Center Project.
OC Airport Land Use Commission. (2008). John Wayne Airport AELUP. Retrieved from John Wayne Airport
Orange County: https://www.ocair.com/about/administration/airport-
governance/commissions/airport-land-use-commission/
City of Tustin 5.5-23
Draft EIR
June 2024
Enderle Center Rezone
5.5 Noise
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City of Tustin 5.5-24
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
5.6 Population and Housing
5.6.1 INTRODUCTION
This section examines the existing population, housing, and employment conditions in the City of Tustin and
assesses the proposed Project's potential impacts related to unplanned direct and indirect growth. The
demographic data and analysis presented in this section is based, in part, on the following documents and
resources:
• City of Tustin General Plan (including 2021-2029 Housing Element), adopted November 2018 and
updated October 2022.
• Tustin City Code.
• E-5 CitylCounty Population and Housing Estimates, 7/1/2023, California Department of Finance
(DOF).
• Demographics and Growth Forecast, 2024, Southern California Association of Governments
(SCAG).
Although evaluation of population, housing, and employment typically involves economic and social, rather
than physical environmental issues, population, housing, and employment growth are often precursors to
physical environmental impacts. According to Section 15382 of the CEQA Guidelines, "[a]n economic or
social change by itself shall not be considered a significant impact on the environment." Socioeconomic
characteristics should be considered in an EIR only to the extent that they create adverse impacts on the
physical environment.
5.6.2 REGULATORY SETTING
5.6.2.1 Federal Regulations
No federal laws, regulations, or executive orders apply to the Project.
5.6.2.2 State Regulations
California Housing Element Law
California Planning and Zoning Law requires each city and county to adopt a general plan to guide future
growth (California Government Code Section 65300). Among other things, the general plan must include a
housing element that identifies housing needs for all economic segments and provides opportunities for
housing development to meet that need. At the state level, the California Department of Housing and
Community Development Department (HCD) estimates the relative share of California's projected population
growth that would occur in each county based on California Department of Finance (DOF) population
projections and historical growth trends. These figures are compiled by HCD in a Regional Housing Needs
Assessment (RHNA) for each region of California. Where there is a regional council of governments, HCD
provides the RHNA to the council. Such is the case for the City of Tustin, which is a member of the Southern
California Association of Governments (SCAG). The council, in this case SCAG, then assigns a share of the
regional housing need to each of its cities and counties. The HCD oversees the process to ensure that the
council of governments distributes its share of the state's projected housing need.
Regional Housing Needs Allocation
The RHNA is mandated by state housing law as part of the periodic process of updating housing elements
of local general plans. State law requires that housing elements identify RHNA targets set by HCD to
City of Tustin 5.6-1
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
encourage each jurisdiction in the state to provide its fair share of very low-, low-, moderate-, and upper -
income housing. The RHNA provides a long-term outline for housing within the context of local and regional
trends and housing production goals.
SCAG determines total housing need for each city and county in Southern California based on three general
factors: 1) the number of housing units needed to accommodate future population and employment growth;
2) the number of additional units needed to allow for housing vacancies; and 3) the number of very low,
low, moderate, and above -moderate income households needed. All cities and counties are required to
ensure that sufficient sites are planned and zoned for housing, such that area would be available to
accommodate the projected housing needs, and to implement proactive programs that facilitate and
encourage the production of housing commensurate with its housing needs.
The planning period for the 6rh Cycle RHNA as prepared by SCAG, is an eight -year period from June 30,
2021, to October 15, 2029. The 6th Cycle RHNA allocated 6,782 housing units to the City of Tustin. The
income breakdown of the required housing units is provided in Table 5.6-1.
Table 5.6-1: City of Tustin RHNA by Income Level
Income Level Category
Number of Housing Units
Percent of Total
Very Low (< 50% of AMI)
1,724
25%
Low (50% to 80% of AMI)
1,046
15%
Moderate (80% to 120% of AMI)
1,132
17%
Above Moderate (> 1 20% of AMI)
2,880
42%
Total
6,782
100%
Notes: AMI = Area Median Income
Source: (Southern California Associated of Governments, 2021)
SCAG Regional Transportation Plan/Sustainable Communities Strategy
On April 4, 2024, SCAG adopted "Connect SoCal," the 2024-2050 Regional Transportation
Plan/Sustainable Communities Strategy (RTP/SCS). Connect SoCal integrates transportation planning with
economic development and sustainability planning to comply with state greenhouse gas (GHG) emissions
reduction goals, such as Senate Bill 375. The RTP/SCS is updated every four years as required by federal
and state regulations.
According to the RTP/SCS, by 2050, the population of Southern California is projected to increase by two
million people, with an increase of 1.6 million housing units, and 1.3 million jobs. However, growth is not
expected to be uniform across the region's counties or cities. During that time, transportation infrastructure
will need to substantially expand while also meeting the GHG emissions -reduction targets set by the
California Air Resources Board.
SCAG is empowered by state law to assess regional housing needs and provide a specific allocation of
housing needs for all economic segments of the community for each of the region's counties and cities. The
determination of each City's and county's share of regional housing needs that is required by law to be
reflected in municipal general plan housing elements is based on the growth projections of the RTP/SCS.
SCAG Regional Growth Projections
SCAG is responsible for producing socioeconomic forecasts and developing, refining, and maintaining macro
and small-scale forecasting models. The forecasts are developed in five-year increments. The current SCAG
projections are provided through the year 2050. Consistency with the growth forecast, at the sub -regional
level, is one criterion that SCAG uses in exercising its federal mandate to review "regionally significant"
development projects for conformity with regional plans.
City of Tustin 5.6-2
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
Based on SCAG methodology, the number of local employment opportunities will increase from 51,700 in
2019 to 71,300 in 2050. Additionally, SCAG projects the City's housing units will increase from 27,000 in
2019 to 34,000 in 2050 (Southern California Association of Governments, 2024).
5.6.2.3 Local and Regional Regulations
General Plan
The following goals and policies from the City's 2021-2029 Housing Element are relevant to the proposed
Project.
Goal 1: Provision of an adequate supply of housing to meet the need for a variety of housing
types and the diverse socio-economic needs of all community residents commensurate
with the City's identified housing needs in the RHNA allocation.
Policy 1.1: Variety of Housing Choices: Provide site opportunities inventory of vacant and
underutilized land for development of housing that responds to diverse community needs in
terms of housing type, cost and location, emphasizing locations near services and transit.
Policy 1.3: Regulatory Incentives. Support the use of regulatory incentives, such as density bonuses
and deferment of impact fees, to offset the costs of affordable housing while ensuring that
potential impacts are addressed.
Policy 1.4: Development Streamlining. Initiate development permit and zoning code streamlining
strategies to encourage and expedite residential development (i.e. accessory dwelling units,
affordable housing units, and investments in existing buildings) to reduce and eliminate
regulatory barriers.
Policy 1.5: Smart Growth Principles. Encourage infill development or site redevelopment within
feasible development sites for homeownership and rental units through the implementation
of smart growth principles, allowing for the construction of higher density housing,
affordable housing, and mixed -use development (the vertical and horizontal integration of
commercial and residential uses) in proximity to employment opportunities, community
facilities and services, and amenities.
5.6.3 ENVIRONMENTAL SETTING
Project Site
The Project site is approximately 1 1.80 acres and is currently developed with 87,136 SF of commercial
business, including 28,750 SF of restaurant use, 39,960 SF of retail and service use, 18,426 SF of office use,
and surface parking lots.
The Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM).
The Project proposes the addition of a housing overlay district which would allow residential land uses in
addition to the uses allowed under the existing PC COM zoning. Thus, the Housing Overlay (HO) district
would be added "on top" of the existing PC COM zone (i.e., Base Zone).
In addition, the Project includes a General Plan Amendment to establish via text that a higher density of
residential uses is allowed in the PCCB designation subject to limits contained within a Housing Overlay (HO)
district (zoning) or as allowed by a specific plan. The Project also includes an amendment to Tustin City Code
City of Tustin 5.6-3
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
(TCC), Article 9 (Land Use), Chapter 2 (Zoning), Part 5, to establish a HO district, which allows for high
density residential development, and stipulates that objective design standards for residential development
will apply to properties within the boundary of the HO district; and an amendment to the City's Zoning Map
to add the newly codified HO district on top of the site's existing PC COM zoning.
Population
According to the California DOF, the City of Tustin had a population of 79,558 in 2023 (California
Department of Finance, 2023). Based on SCAG Connect SoCal methodology, the City of Tustin had a
population of 80,400 persons in 2019 and estimates that the City's population will increase to 93,317 in
20501, which is a 16.1 percent increase. In comparison, the SCAG projects the County of Orange will have
a 7.8 percent increase in population between 2019 and 2050, as shown on Table 5.6-2.
Table 5.6-2: City and County Existing and Projected Population, 2019-2050
Year
City of Tustin Population
County of Orange Population
2019
80,400
3,191,000
2050
93,317
3,439,000
Projected Change
12,919
248,000
Projected Percent Change
16.1
7.8
Source: (Southern California Association of Governments, 2024)
Housing
The California DOF estimates that the City of Tustin contained 28,405 housing units in 2023. The housing
types in the City of Tustin compared to those in the entire County are provided in Table 5.6-3. As shown, the
County has a higher percentage of detached single-family housing units and a lower percentage of single-
family attached and multi -family housing units than the City. In addition, the California DOF details that the
City had an average household size of 2.88 persons per household. In comparison, the County had an
average household size of 2.83 persons per household.
Table 5.6-3: City and County Housing Estimates by Type 2023
City of Tustin Housing Units
County of Orange Housing Units
Unit Type
Number
Percent
Number
Percent
Single-family detached
9,910
34.9%
570,763
49.6%
Single-family attached
3,944
1 3.9%
143,166
12.4%
Multi -family (2-4 units)
3,956
13.9%
94,541
8.2%
Multi -family (5+ units)
9,731
34.3%
309,290
26.9%
Mobile Homes
864
3.0%
32,183
2.8%
Total
28,405
100%
1,149,943
100%
Source: (California Department of Finance, 2023)
The California DOF 2023 population and housing estimates for the City of Tustin indicate a vacancy rate of
3.4 percent. In comparison, the Countywide vacancy rate is higher at 5.1 percent.
I The 2050 population estimate was derived using the methodology presented in Section 4.5 of the SCAG Demographics & Growth
Forecast which states that an estimate of the future City -level population based on Connect SoCal's household forecast can be
derived using a county -level Population: Housing ratio from TABLE 12 and applying it to the City's future household growth (Southern
California Association of Governments, 2024).
City of Tustin 5.6-4
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
As shown in Table 5.6-4, SCAG estimates that between 2019 and 2050, the number of housing units in the
City will increase by 25.9 percent while the number of housing units in the County will increase by 17.2
percent.
Table 5.6-4: City and County Existing and Projected Housing Units, 2019-2050
Year
City of Tustin Housing Units
County of Orange Housing Units
2019
27,000
1,069,000
2050
34,000
1,253,000
Projected Change 2019-2050
7,000
184,000
Projected Percent Change 2019-2050
25.9
17.2
Source: (Southern California Association of Governments, 2024)
Employment
The City of Tustin is estimated to contain 51,700 employment opportunities as of 2019. The SCAG regional
growth projections anticipate the number of jobs in the City of Tustin to increase by 37.9 percent to 71,300
jobs in the year 2050. In comparison, the County is projected to see a 11.9 percent increase in the number
of jobs by 2050, as shown in Table 5.6-5.
Table 5.6-5: City and County Existing and Projected Employment, 2019-2050
Year
City of Tustin Employment
County of Orange Employment
2019
51,700
1,805,000
2050
71,300
2,019,000
Projected Change 2019-2050
19,600
214,000
Projected Percent Change 2019-
2050
37.9
11.9
Source: (Southern California Association of Governments, 2024)
The SCAG 2019 Local Profile for Tustin identifies that 7.3 percent of Tustin residents work and live in the
City, while 92.7 percent commute to other places (Southern California Association of Governments, 2019).
Of the commuters residing in Tustin, the largest percentage commute to the City of Irvine (18.6 percent),
Santa Ana (10.4 percent), Anaheim (5.5 percent), and Orange (5.2 percent).
Jobs — Housing Ratio
The jobs -housing ratio is a general measure of the total number of jobs and housing units in a defined
geographic area, without regard to economic constraints or individual preferences. SCAG applies the jobs -
housing ratio at the regional and subregional levels to analyze the fit between jobs, housing, and
infrastructure. A major focus of SCAG's regional planning efforts has been to improve this balance. SCAG
defines the jobs -housing balance as follows:
Jobs and housing are in balance when an area has enough employment opportunities for
most of the people who live there and enough housing opportunities for most of the people
who work there. The region as a whole is, by definition, balanced.... Job -rich subregions
have ratios greater than the regional average; housing -rich subregions have ratios lower
than the regional average. Ideally, job -housing balance would... assure not only a
numerical match of jobs and housing but also an economic match in type of jobs and housing.
There is no ideal ratio adopted in state, regional, or city policies. However, the American Planning Association
recommends a target ratio of 1.5 jobs per housing unit; communities with more than 1.5 jobs per dwelling
City of Tustin 5.6-5
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
unit are considered jobs -rich; those with fewer than 1.5 are "housing rich," meaning that more housing is
provided than employment opportunities in the area (Weitz, 2003). A job -housing imbalance can indicate
potential air quality and traffic problems associated with commuting. Table 5.6-6 provides the projected
jobs -to -housing ratios for the City, based on SCAG's 2024-2050 RTP/SCS.
Table 5.6-6: Jobs — Housing Trends in the City of Tustin
Employment in
Number of
2019 Jobs
Employment
Number of
2050 Jobs
2019
Dwelling
to Housing
in 2050
Dwelling
to Housing
Units in
Ratio
Units in
Ratio
2019
2050
City of Tustin
51,700
27,000
1.91
71,300
34,000
2.1
County of Orange
1,805,000
1,069,000
1.67
2,019,000
1,253,000
1.61
Source: (Southern California Association of Governments, 2024)
As shown on Table 5.6-6, the projected 2050 jobs -to -housing ratios for the City of Tustin and Orange County
are 2.1 and 1.61, respectively. This indicates that both the City of Tustin and Orange County are job -rich.
Therefore, it is possible that people employed in the City of Tustin are commuting from elsewhere.
5.6.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
POP-1 Induce substantial unplanned population growth in an area, either directly (for example, by
proposing new homes and businesses) or indirectly (for example, through extension of roads or
other infrastructure).
POP-2 Displace substantial numbers of existing people or housing, necessitating the construction of
replacement housing elsewhere.
The Initial Study (Appendix A) established that the proposed Project would not result in impacts related to
Threshold POP-2; therefore, no further assessment of this threshold is required in this Draft EIR.
5.6.5 METHODOLOGY
CEQA Guidelines Section 15064(e) states that a social or economic change generally is not considered a
significant effect on the environment unless the changes can be directly linked to a physical adverse change.
Additionally, CEQA Guidelines Appendix G indicates that a project could have a significant effect if it would
induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes
and businesses) or indirectly (e.g., through extension of roads or other infrastructure). Therefore, population
impacts are considered potentially significant if growth associated with the proposed Project would exceed
projections for the area and if such an exceedance would have the potential to create a significant adverse
physical change to the environment.
The methodology used to determine population, housing, and employment impacts began with data collection
regarding existing population and housing trends, which was obtained from the U.S. Census, state of
California DOF, and SCAG. 2024 SCAG data was used to determine the City's long-term population,
housing, and employment growth projections for the next 30 years. Additionally, 2023 California DOF data
was used to determine the existing population, estimated number of housing units in the City, and average
persons per household, as this was the available dataset at the time the NOP was released. The DOF
benchmarked all 2023 population and housing estimates to the 2020 decennial census. U.S. Census data
was also used, specifically, to capture the current employment statistics related to construction in the City. If
projected growth from the Project would exceed growth projections for the City and could create a
City of Tustin 5.6-6
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
significant change to the environment, the resulting growth would be considered "substantial," and a
significant impact would result.
5.6.6 ENVIRONMENTAL IMPACTS
IMPACT POP-1: THE PROJECT WOULD NOT INDUCE SUBSTANTIAL UNPLANNED POPULATION
GROWTH IN AN AREA, EITHER DIRECTLY (FOR EXAMPLE, BY PROPOSING NEW
HOMES AND BUSINESSES) OR INDIRECTLY (FOR EXAMPLE, THROUGH EXTENSION
OF ROADS OR OTHER INFRASTRUCTURE).
Less than Significant.
Housing and Population Growth: The proposed Project is a housing overlay within the Enderle Center site.
A specific development project is not proposed as part of this Project. The Project site does not currently
support residential uses. However, the development that could occur from future buildout of the proposed
housing zone is 413 dwelling units and 118,474 SF of additional nonresidential buildout. As described
previously, the City has an average of approximately 2.88 persons per household (California Department
of Finance, 2023). Using this estimate, buildout of the proposed 413 units could result in an additional 1,189
residents in the City.
As shown in Table 5.6-2, the population in the City of Tustin is expected to increase by 12,919 people
between 2019 and 2050. As shown in Table 5.6-4, housing stock in the city is expected to increase by 7,000
dwelling units between 2019 and 2050. Based on these growth projections, full buildout of the Project would
represent approximately 9.2 percent of the projected population growth and 5.9 percent of the projected
housing stock growth in the city. Thus, while the Project would result in an increase in population and housing
units in an area not previously planned for housing, the increase in population and number of housing units
that would result from the proposed Project would not exceed projections for the City.
Further, as reflected in Table 5.6-1, SCAG determined the City needs to provide a total of 6,782 housing
units to meet their RHNA. The City's 2021-2029 Housing Element identifies several adequate sites that are
able to accommodate the development of additional housing units for the City to meet its estimated housing
growth needs identified in the SCAG's RHNA allocation. Of the Housing Element inventory sites, the Enderle
Center (the Project site) was identified as necessary for rezoning under Housing Element Program 1.1 f to
allow for high density residential/mixed use development. Thus, while the proposed Project would result in
an increase to projected planned population, the Project would in part satisfy the State requirements to
provide new housing opportunities to increase housing supply. Additionally, the proposed Project supports
goals and policies of the Housing Element aimed to support a variety of housing types and densities. These
include:
• Goal 1: Provision of an adequate supply of housing to meet the need for a variety of housing
types and the diverse socio-economic needs of all community residents commensurate with the
City's identified housing needs in the RHNA allocation.
• Policy 1.1: Variety of Housing Choices. Provide site opportunities inventory of vacant and
underutilized land for development of housing that responds to diverse community needs in terms of
housing type, cost and location, emphasizing locations near services and transit.
• Policy 1.3: Regulatory Incentives. Support the use of regulatory incentives, such as density bonuses
and deferment of impact fees, to offset the costs of affordable housing while ensuring that potential
impacts are addressed.
• Policy 1.4: Development Streamlining. Initiate development permit and zoning code streamlining
strategies to encourage and expedite residential development (i.e. accessory dwelling units,
City of Tustin 5.6-7
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
affordable housing units, and investments in existing buildings) to reduce and eliminate regulatory
barriers.
• Policy 1.5: Smart Growth Principles. Encourage infill development or site redevelopment within
feasible development sites for homeownership and rental units through the implementation of smart
growth principles, allowing for the construction of higher density housing, affordable housing, and
mixed -use development (the vertical and horizontal integration of commercial and residential uses)
in proximity to employment opportunities, community facilities and services, and amenities.
Employment Growth: As described in Chapter 3, Project Description, the Project also anticipates the future
nonresidential capacity buildout of 118,474 SF within a portion of the Project site that allows non-residential
development. Using employment generation rates from the 2001 SCAG Employment Density Report, buildout
of the 1 18,474 SF of nonresidential space would result in approximately 365 employees (1 employee per
325 SF) (The Natelson Company, Inc., 2001).
As shown in Table 5.6-5, employment in the City of Tustin is expected to increase by 19,600 jobs between
2019 and 2050. Based on these growth projections, buildout of the nonresidential portion of the Project
would represent approximately 1.86 percent of the projected employment growth in the City. Thus, while
the Project would result in an increase in employment, the increase in the number of jobs that would result
from the proposed Project would not exceed projections for the City.
Jobs -Housing Balance. Effects of the proposed Project on jobs -housing balance are evaluated by adding
project -generated jobs and housing units to forecasts of employment and housing. As described previously,
the City of Tustin is jobs -rich, with an existing jobs -housing ratio of 1.91. The proposed Project would reduce
(improve) the jobs -housing ratio slightly by adding 413 residential units. The proposed Project would provide
a regional beneficial effect of providing the opportunity for housing on the Project site in a jobs -rich area,
where employees can easily travel to nearby employment opportunities.
In addition, because the area is jobs -rich, the addition of residential units in the area would not require
additional jobs that could result in growth. Conversely, the new residents would fill the need for employees
that are anticipated by SCAG projections. Thus, the additional residential units would not indirectly result in
the need for additional employment opportunities, which could result in growth. Therefore, this indirect impact
related to growth would be less than significant.
Construction. A specific development project is not proposed as part of this Project; however, construction
of future residential uses that may occur as a result of this Project would result in a temporary increased
demand for construction workers. Construction workers are anticipated to come from the City and surrounding
jurisdictions and commute daily to the jobsite. Although it is possible that the demand for workers could
induce some people to move to the region, this consideration would be de minimis, relative to the total number
of construction workers in the region. According to the U.S. Census Bureau, 2,303 individuals are employed
in the construction industry in the City of Tustin and 72,855 individuals are employed in the construction
industry in Orange County as a whole (United States Census Bureau, 2022). The supply of general
construction labor in the vicinity of the Project area is not expected to be constrained due to the temporary
nature of construction projects. As such, the existing labor pool can meet the construction needs of the Project,
and this labor pool would increase with the continued projected growth of Orange County. Therefore,
implementation of the Project would not induce substantial unplanned population growth directly or indirectly
through construction employment that could cause substantial adverse physical changes in the environment.
Impacts would be less than significant.
Infrastructure. Future development of the Project may require expansion of infrastructure to serve the
proposed uses at the site, including installation of new storm drains, wastewater, water (potable and
reclaimed), and dry utilities that would connect to existing facilities within the Project site or adjacent to the
City of Tustin 5.6-8
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
Project area. However, as outlined in Section 3.0, Project Description, specific infrastructure improvements
required to support residential development within the Enderle Center are not known at this time and will
not be known until a development project is proposed. Future development associated with allowed uses in
accordance with the proposed Housing Overlay Zone would be required to undergo project -level
environmental analysis under CEQA on a case -by -case basis. As such, future development projects would be
required to analyze project -specific impacts related to infrastructure improvements and the City's existing
population and housing stock.
5.6.7 CUMULATIVE IMPACTS
Impacts from cumulative population growth are considered in the context of their consistency with local and
regional planning efforts. As discussed, SCAG's 2024-2050 RTP/SCS serves as a long-range vision plan for
development in the counties of San Bernardino, Imperial, Los Angeles, Orange, Riverside, and Ventura. The
Project would not exceed the SCAG population, housing, and employment growth projections for the City
and would represent a nominal percentage of SCAG's overall projections for the City of Tustin. The Project
could result in a generation of 413 residential units at full buildout. Based on the growth projections analyzed
in SCAG's 2024-2050 RTP/SCS, full buildout of the Project would represent approximately 9.2 percent of
the projected population growth and 5.9 percent of the projected housing stock growth in the City of Tustin.
The Project is within the growth projections used to prepare RTP/SCS, thus, impacts related to cumulative
growth would be less than significant and not cumulatively considerable.
5.6.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
California Government Code Sections 65300, 65580-65589
Plans, Programs, or Policies
None.
5.6.9 PROJECT DESIGN FEATURES
None.
5.6.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact POP-1 would be less than significant.
5.6.1 1 MITIGATION MEASURES
No mitigation measures are required.
5.6.1 2 LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to population and housing would occur.
City of Tustin 5.6-9
Draft EIR
June 2024
Enderle Center Rezone Project 5.6 Population and Housing
5.6.1 3 REFERENCES
California Department of Finance. (2023, May). E-5 Population and Housing Estimates for Cities, Counties,
and the State — January 1, 2027-2023. Retrieved from State of California Department of
Finance.
California State University Fullerton. (2023). Orange County Jurisdiction Demographics. Retrieved from
College of Humanities and Social Sciences, Center for Demographic Research.
City of Tustin. (2022). Final Housing Element 202 7 -2029.
Southern California Associated of Governments. (2021). Regional Housing Needs Assessment. Retrieved
from Southern California Associated of Governments: https://scag.ca.gov/rhna
Southern California Association of Governments. (2019, May). Local Profiles. Retrieved from Southern
California Association of Governments: https://scag.ca.gov/data-tools-local-profiles
Southern California Association of Governments. (2024). Demographics and Growth Forecast Technical
Report.
The Natelson Company, Inc. (2001). Employment Density Study Summary Report.
United States Census Bureau. (2022). Industry by Sex for the Full -Time, Year -Round Civilian Employed
Population 16 Years and Over. American Community Survey, ACS 1-Year Estimates Subject Tables,
Table S2404. Retrieved from United States Census Bureau:
https://data.census.gov/table/ACSSTI Y2022.S2404?q=Orange%20County%20California&t=ln
dustry&g = 1 60XXOOUS0680854
Weitz, J. (2003). Jobs -Housing Balance. Planning Advisory Service Report Number 516. American Planning
Association.
City of Tustin 5.6-10
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.7 Public Services
5.7 Public Services
5.7.1 INTRODUCTION
This section describes the existing fire protection, police protection, schools, and library facilities that serve
the Project site and vicinity and evaluates the potential for implementation of the proposed Project to result
in an impact. This section of the Supplemental EIR addresses whether there are physical environmental effects
of new or expanded facilities that are necessary to maintain acceptable service levels related to fire, police,
schools, and library services. Park services are addressed in Section 5.8, Parks and Recreation. Public utilities
and service systems, including water, wastewater, drainage, and solid waste, are addressed in Section 5.1 1,
Utilities and Service Systems. Information within this section is based on the following:
• City of Tustin General Plan (including 2021-2029 Housing Element). Adopted November 2018
(updated October 2022).
• Tustin City Code
• Data provided by each service provider
Because CEQA focuses on physical environmental effects, this section analyzes whether any physical changes
resulting from an increase in service demands from development pursuant to the proposed Project could
result in significant adverse environmental effects. Thus, an increase in staffing associated with public services,
or an increase in calls for services, would not, by itself, be considered a physical change in the environment.
However, physical changes in the environment resulting from the construction of new facilities or an expansion
of existing facilities to accommodate the increased staff or equipment needs resulting from the proposed
Project could constitute a significant impact.
5.7.2 FIRE PROTECTION SERVICES
5.7.2.1 FIRE PROTECTION REGULATORY SETTING
California Fire Code
State fire regulations are set forth in Sections 13000 et seq. of the California Health and Safety Code,
which include regulations concerning building standards (as also set forth in Title 24, Part 9 of the California
Code of Regulations, the California Building Code), fire protection and notification systems, fire protection
devices (such as extinguishers and smoke alarms), building evacuation and access standards, and fire
suppression training.
California Health and Safety Code
Additional state fire regulations are set forth in Sections 13000 et seq. of the California Health and Safety
Code, which includes regulations for building standards, fire protection and notification systems, fire
protection devices such as extinguishers, smoke alarms, high-rise building and childcare facility standards,
and fire suppression training.
California Occupational Safety and Health Administration
In accordance with the California Code of Regulations, Title 8 Sections 1270 "Fire Prevention" and 6773
"Fire Protection and Fire Fighting Equipment," California Occupational Safety and Health Administration
(Cal/OSHA) has established minimum standards for fire suppression and emergency medical services. The
City of Tustin 5.7-1
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.7 Public Services
standards include, but are not limited to, guidelines on the handling of highly combustible materials, fire
house sizing requirements, restrictions on the use of compressed air, access roads, and the testing,
maintenance, and use of all firefighting and emergency medical equipment.
Orange County Fire Authority Fire Prevention Guideline B-09, Fire Master Plans for Commercial and
Residential Development
The Orange County Fire Authority (OCFA) Fire Prevention Guideline B-09 requires new structures to meet
standards related to access driveways, siting of hydrants, water supply, and building access, as required by
the California Fire Code. The guideline requires specific information be provided during the submittal of
plans for development projects to demonstrate compliance with all codes and other regulations governing
water availability for firefighting and emergency access to sites and structures within the jurisdictions served
by the OCFA. In addition, the guideline requires that plans be reviewed by the OCFA.
City of Tustin General Plan
The City's General Plan Public Safety Element contains the following goals and policies related to fire
services.
Goal 5: Reduce the risk to the community's inhabitants from fires or explosions.
Policy 5.1: Work closely with the Orange County Fire Authority to continue to operate an education
program regarding fire hazards.
Policy 5.2: Encourage the use of fire retardant roofing materials.
Policy 5.3: Establish and maintain mutual aid agreements with surrounding jurisdictions for fire
protection.
Policy 5.4: Enforce building code requirements that assure adequate fire protection.
Policy 5.5: Study alternatives for upgrading emergency water line capacities in deficient areas.
Policy 5.6: Cooperate with Orange County Fire Authority to ensure the provision of adequate and cost-
effective fire protection services.
Tustin City Code
Chapter 8100 — Building and Construction Codes Adopted by Reference. The Tustin City Code adopts the
California Fire Code as published by the California Building Standards Commission and the International
Code Council by reference. The California Fire Code is Title 24, Part 9 of the California Code of Regulations,
and regulates new structures, alterations, additions, changes in use or changes in structures. The Code includes
specific information regarding safety provisions, emergency planning, fire-resistant construction, fire
protection systems, means of egress and hazardous materials.
5.7.2.2 FIRE PROTECTION SERVICE ENVIRONMENTAL SETTING
Fire protection and emergency medical services in the City of Tustin are provided by the OCFA through a
contract for services. The OCFA provides fire suppression, emergency medical, rescue, fire prevention,
hazardous materials coordination, and wildland management services. OCFA serves 23 cities in Orange
County and all unincorporated areas. Within the City of Tustin, OCFA provides services from three fire
stations. Additionally, there are four fire stations in the City of Santa Ana and unincorporated Orange County
within service distance from the Project site.
City of Tustin 5.7-2
Draft EIR
June 2024
Enderle Center Rezone
5.7 Public Services
The Project site is within the Primary Responsibility Area of OCFA Station 21, which is located approximately
2 miles from the site. However, resources are deployed upon a regional service delivery system, assigning
personnel and equipment to emergency incidents without regard to jurisdictional boundaries. Therefore, the
site may be served by other OCFA stations in the vicinity. These include OCFA Station 72, located
approximately 1.6 miles from the Project site; OCFA Station 70, located approximately 1.8 miles from the
Project site; OCFA Station 75, located approximately 3.3 miles from the site; and OCFA Station 8, located
approximately 3.6 miles from the site. The location, equipment, and staffing of the fire stations that would
serve the Project site are provided in Table 5.7-1.
Table 5.7-1: Fire Stations Near the Project Site
Estimated
Fire Station
Location
Distance
Response
Equipment
Staffin 9
from Site'
Time to
Site
Daily Staffing:
-1 Fire Captain;
1 688 East 4th
-Medi72ngine
-1 Fire Apparatus Engineer;
Station 72
Street, Santa Ana,
1.6 miles
08:00
-2 Firefighters
CA 92701
Total Station Staffing: 12
Firefighters
Daily Staffing:
-Battalion 3
-1 Battalion Chief;
1 241 Irvine Blvd
-Medic Engine
-1 Fire Captain;
Station 21
Tustin CA 92780
2 miles
08:00
21
-1 Fire Apparatus Engineer;
-2 Firefighters
Total Station Staffing: 15
Daily Staffing:
-1 Fire Captain;
2301 North Old
-Medic Engine
-1 Fire Apparatus Engineer;
Station 70
Grand Street, Santa
1.8 miles
07:30
70
-2 Firefighters
Ana, CA 92705
-Engine 370
Total Station Staffing: 12
Firefighters
Daily Staffing:
-2 Fire Captains;
120 W Walnut
-Medic Engine
-2 Fire Apparatus
Station 75
Street, Santa Ana,
3.3 miles
13:00
75
Engineers;
CA 92701
-Medic Truck
4 Firefighters
75
Total Station Staffing: 24
Firefighters
Daily Staffing:
-1 Fire Captain;
10631 Skyline
-Medic Engine
-1 Fire Apparatus Engineer;
Station 8
Drive, Santa Ana,
3.6 miles
1 1:00
8
-2 Firefighters
CA 92705
Total Station Staffing: 12
Firefighters
Source: (Orange County Fire Authority, 2022) (Orange County Fire Authority, 2024)
'Measured from approximate center of site
As shown in Table 5.7-2, there were 16,276 incident totals from the three fire stations in the City of Tustin in
2022. Of the calls for service, 70 percent (11,397) were for emergency medical calls, 1.5 percent (237)
City of Tustin 5.7-3
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.7 Public Services
were for fire incidents, and 28.5 percent (4,642) were for other incidents, which includes: cancelled service
calls, ruptures, hazardous conditions, false alarms, and miscellaneous calls.
According to the Table PS-3, Emergency Service Standards, of the Tustin General Plan, Tustin has a target
response time of 5 minutes for 90 percent of incidents related to fire response and basic life support unit
responses. The standard response time for the advanced life support unit is 10 minutes for 90 percent of
incidents (City of Tustin, 2018).
OCFA's current response standards are based on a 901" Percentile. The OCFA current standard for response
is 8:30 minutes at the 901" percentile. Table 5.1 1-2 provides a summary of service and response metrics for
the closest responding stations to the Project site in 2023. According to OCFA, in 2023, OCFA first unit on
scene response at the 901" percentile to the project area was 8:35 minutes.
Table 5.7-2: Fire Stations Calls for Service and Response Data — 2023
Fire Station
Total Calls
for Services
Emergency
Medical Calls
Fire Calls
Other Calls
Total
Incidents
90th Percentile
Response
(min:second)
Station 72
4,470
3,047
80
1,343
4,470
09:00
Station 21
3,780
2,768
38
974
3,780
08:49
Station 70
2,743
1,795
39
909
2,743
08:39
Station 75
4,478
3,316
69
1,093
4,478
08:38
Station 8
805
471
11
323
805
10:31
Total
16,276
11,397
237
4,642
16,276
-
Source: Public Service Letter
5.7.2.3 FIRE PROTECTION SERVICE THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to
result in substantial adverse physical impacts associated with the provision of new or physically altered fire
protection facilities, the construction of which could cause significant environmental impacts, in order to
maintain acceptable service ratios, response times or other performance objectives for fire protection
services.
5.7.2.4 FIRE PROTECTION SERVICE METHODOLOGY
The potential impacts related to fire protection services were evaluated based on the ability of existing fire
department staffing, equipment, and facilities to meet the additional demand for fire protection and
emergency medical services resulting from implementation of the proposed Project. Impacts are considered
significant if implementation of the proposed Project would result in inadequate staffing levels, response
times, and/or increased demand for services that would require the construction or expansion of new or
altered facilities that might have an adverse physical effect on the environment. For fire services, a significant
impact could occur if the proposed Project generated the need for additional personnel or equipment that
could not be accommodated within the existing stations and would require the construction of a new station
or an expansion of an existing station.
5.7.2.5 FIRE PROTECTION SERVICE ENVIRONMENTAL IMPACTS
IMPACT PS-1: THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS
ASSOCIATED WITH THE PROVISION OF NEW OR PHYSICALLY ALTERED FIRE SERVICE
City of Tustin 5.7-4
Draft EIR
June 2024
Enderle Center Rezone
5.7 Public Services
FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT
ENVIRONMENTAL IMPACTS, IN ORDER TO MAINTAIN ACCEPTABLE SERVICE RATIOS
AND RESPONSE TIMES OR OTHER PERFORMANCE OBJECTIVES FOR FIRE PROTECTION
SERVICES.
Less than Significant Impact. The proposed Project is a Housing Overlay (HO) district within Enderle Center
site. The HO district will allow residential uses on the Project site, which currently only allows commercial uses.
The proposal is regulatory in nature, and a specific development project is not proposed at this time.
However, the development that could occur from future buildout of the proposed HO district is 413 dwelling
units and 118,474 SF of nonresidential uses. Construction and operation of future residential and
nonresidential development as a result of the proposed Project would increase demands for fire protection
and emergency medical services beyond the existing site condition. As described in Section 5.6, Population
and Housing, the proposed Project is estimated to result in 1,189 residents and 365 employees at full
buildout. The increased residential and employee population is expected to create the typical range of
service calls to OCFA, largely related to medical emergencies. Medical emergencies accounted for 70
percent of service calls of OCFA service calls in in the Project Area during 2023, while fire calls consisted of
1.5 percent of service calls (OCFA 2024).
As described above in Section 4, Environmental Setting, there are five existing fire stations within Tustin,
Santa Ana and the unincorporated County that would serve the Project site. The first responding station within
the primary responsibility area for the proposed Project (Station 21) is 2 miles from the Project site. The
other responding stations include Station 72 located 1.6 miles from the Project site, Station 70 located 1.8
miles from the Project site, Station 75 located 3.3 miles from the Project site, and Station 8 located 3.6 miles
from the Project site. The existing 90th percentile on -scene response time for emergency calls from the
responding Stations within the Project area is 8:35 minutes, which slightly exceeds the response time standard
901h percentile of 8:30 minutes. The existing 901h percentile response time for emergency calls from Station
21 is 8:49 minutes, which is also slightly above the response time standard.
While a specific development project is not proposed as part of this Project, approval of the Project would
allow up to 413 housing units and 118,474 SF of nonresidential space to be developed within the Project
site. Therefore, calls for service from the future additional population at the Project site could result in an
increase in response times, and result in Station 21 and the other OCFA fire stations further exceeding the
existing standards for service, if the calls coincide with other calls for service. However, because the Project
site is within four miles of five existing fire stations, and the Project site is within a developed area that is
currently served by a first responding station that is 2 miles from the Project site, and a second responding
station that is 1.6 miles from the Project site, the Project would not result in the requirement to construct a
new fire station.
Additionally, future development as a result of the proposed Project would be developed pursuant to the
most recent California building and fire codes, which would improve the fire safety of the Project site
compared to the existing buildings. California's building/fire codes are published in their entirety every
three years and were most recently updated in 2022. As with all projects within the City, future projects
allowed under the proposed Project would be required, per City permitting, to comply with existing
regulations, including the 2022 California Fire Code and the OCFA Fire Prevention Guideline B-09, Fire
Master Plans for Commercial and Residential Development, which include regulations for water supply, built
in fire protection systems, adequate emergency access, fire hydrant availability, and fire -safe building
materials, such as the following:
• Structures would have automatic fire sprinkler systems per National Fire Protection Association
Standard for the Installation of Sprinkler Systems (NFPA 1 3) as required by the California Building
and Fire Codes.
City of Tustin 5.7-5
Draft EIR
June 2024
Enderle Center Rezone
5.7 Public Services
• A fire alarm system would be installed per the requirements of the California Fire Code.
• Access to and around structures would meet OCFA and California Fire Code requirements.
• A water supply system to supply fire hydrants and fire hydrant spacing would meet OCFA and
California Fire Code requirements.
• Turning radius and access in and around the Project site and buildings would be designed to
accommodate large fire department vehicles and their weight per OCFA Fire Prevention Guideline
B-09.
• All electrically operated gates shall install emergency opening devices as approved by the OCFA.
• High rise provisions would be required for buildings over 75 feet high.
• Occupancy permits are required prior to occupancy of any part of the proposed Project.
Overall, with the five existing fire stations within approximately 4 miles of the Project site, and the first
responding station 2 miles from the proposed Project, the area has adequate nearby fire facilities to serve
the proposed Project in addition to the existing service needs of the area; and construction of a new or
expanded fire station would not be required as a result of the proposed Project. Thus, the proposed Project
would not result in substantial adverse physical impacts associated with the provision of, or the need for, new
or physically altered fire protection facilities. Overall, impacts related to fire protection services would be
less than significant.
Further, funding for fire facilities, equipment, and service personnel come from the City's General Fund.
Funding from property taxes, as a result of population growth, would be expected to grow roughly
proportional to any increase in residential units and businesses in the City. Therefore, the additional demand
for fire services and protection generated by the proposed Project would be satisfied through the General
Fund.
5.7.2.6 FIRE PROTECTION SERVICE CUMULATIVE IMPACTS
The geographic context for cumulative fire protection and emergency services is the OCFA service area. Like
the proposed Project, cumulative projects in the City would be reviewed by City and OCFA staff prior to
permit approval to ensure that the projects implement fire protection design features per the California
Building Code and the California Fire Code, which are intended to reduce risk of fire and impacts on fire
protection services. Additionally, property and sales tax collected from cumulative projects would increase
the City's General Fund in rough proportion to population increases, providing funding for any improvements
necessary to maintain adequate fire protection facilities, equipment, and/or personnel. Therefore, cumulative
impacts associated with fire services would be less than cumulatively considerable.
5.7.2.7 FIRE PROTECTION SERVICE EXISTING STANDARD CONDITIONS AND
PLANS, PROGRAMS OR POLICIES
The following standard regulations would reduce potential impacts related to fire protection services:
• OCFA Fire Prevention Guideline B-09, Fire Master Plans for Commercial and Residential
Development
• Tustin City Code, Chapter 8100; Building and Construction Codes Adopted by Reference
5.7.2.8 FIRE PROTECTION SERVICE LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact PS-1 would be less than significant.
City of Tustin 5.7-6
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.7 Public Services
5.7.2.9 FIRE PROTECTION SERVICE MITIGATION MEASURES
No mitigation measures are required.
5.7.2.10 FIRE PROTECTION SERVICE LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to fire protection services would occur.
5.7.3 POLICE SERVICES
5.7.3.1 POLICE SERVICES REGULATORY SETTING
City of Tustin General Plan
The City's General Plan Public Safety Element contains the following goals and policies related to police
services.
Goal 6: Stabilize demand for law enforcement services.
Policy 6.1: Provide appropriate levels of police protection within the community.
Policy 6.2: Periodically evaluate service levels and service criteria.
Policy 6.3: Pursue State and Federal monies to offset the cost of providing police protection.
Policy 6.4: Cooperate with the Orange County Sheriff's Department and surrounding police
departments to provide back-up police assistance in emergency situations.
Policy 6.5: Promote the use of defensible space concepts (site and building lighting, visual
observation of open spaces, secured areas, etc.) in project design to enhance public
safety.
Policy 6.6: Enhance public awareness and participation in crime prevention by developing new, and
expanding existing, educational programs dealing with personal safety awareness, such
as neighborhood watch, commercial association programs, and community -oriented
policing.
5.7.3.2 POLICE SERVICES ENVIRONMENTAL SETTING
The Tustin Police Department provides police services throughout the City. Police Department headquarters
are southeast of the Project site, at 300 Centennial Way, Tustin, CA 92780, which is approximately 1.7
roadway miles southeast from the Project site.
As of May 2024, the Tustin Police Department has 83 full time Sworn Police Officers, 7 part time Sworn
Officers, 44 full time civilian support personnel and 12 part time civilian support personnel. According to the
California Department of Finance, the City of Tustin had a population of 78,559 residents in 2023 (California
Department of Finance, 2023). Based on this population estimate, the City's sworn officer to population ratio
is 1.1 officers per 1,000 population.
City of Tustin 5.7-7
Draft EIR
June 2024
Enderle Center Rezone Project 5.7 Public Services
Police Department Performance Standards
According to the Table PS-3, Emergency Service Standards, of the Tustin General Plan, the Tustin Police
Department has a target response time of 3.5 minutes for emergency calls and 13 minutes for non -emergency
calls (City of Tustin, 2018).
Tustin Police Department groups calls for service into four priority categories, described below.
• Priority 1: Immediate threat to life or significant threat to public safety. Priority 1 calls are
dispatched immediately.
• Priority 2: Crimes in progress or other calls for service with a potential threat to public safety that
do not rise to the level of a Priority 1 call. These calls are dispatched as soon as possible.
• Priority 3: Calls for service with a reporting party who is waiting for an officer.
• Priority 4: Report calls with a delay in reporting and limited suspect information.
Average response times for each call type between January 1, 2023, to December 31, 2023, City wide
are provided below.
• Priority 1 — 00:05:43
• Priority 2 — 00:14:25
• Priority 3 — 00:42:27
• Priority 4 — 00:53:36
5.7.3.3 POLICE SERVICES THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to
result in substantial adverse physical impacts associated with the provision of new or physically altered
police department facilities, the construction of which could cause significant environmental impacts in order
to maintain acceptable service ratios, response times or other performance objectives for police services.
5.7.3.4 POLICE SERVICES METHODOLOGY
The potential impacts related to police services were evaluated based on the ability of existing and planned
Police Department staffing, equipment, and facilities to meet the additional demand for police services
resulting from implementation of the proposed Project. Impacts are considered significant if implementation
of the proposed Project would result in inadequate staffing levels, response times, and/or increased demand
for services that would require the construction or expansion of new or altered facilities that might have an
adverse physical effect on the environment. For police services, a significant impact could occur if the
proposed Project generated the need for additional personnel or equipment that could not be
accommodated within the existing station and substations and would require the construction of a new station
or an expansion of an existing station.
5.7.3.5 POLICE SERVICES ENVIRONMENTAL IMPACTS
IMPACT PS-2 THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS
ASSOCIATED WITH THE PROVISION OF NEW OR PHYSICALLY ALTERED POLICE
SERVICE FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT
ENVIRONMENTAL IMPACTS, IN ORDER TO MAINTAIN ACCEPTABLE SERVICE RATIOS
AND RESPONSE TIMES OR OTHER PERFORMANCE OBJECTIVES FOR POLICE SERVICES.
City of Tustin 5.7-8
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.7 Public Services
Less than Significant Impact. The proposed Project is a Housing Overlay (HO) district within the Enderle
Center site. The HO district will allow residential uses on the Project site, which currently only allows
commercial uses. The proposal is regulatory in nature, and a specific development project is not proposed
at this time. However, the development that could occur from future buildout of the proposed HOD is 413
dwelling units and 118,474 SF of nonresidential uses. Construction and operation of future residential and
nonresidential development as a result of the proposed Project would increase demands for police protection
services beyond the existing site condition. As described in Section 5.6, Population and Housing, the proposed
Project is estimated to result in 1,189 residents and 365 employees at full buildout. This residential and
employee population is expected to create the typical range of police service calls.
Crime and safety issues during Project construction may include theft of building materials and construction
equipment, malicious mischief, graffiti, and vandalism. During operation, the proposed Project is anticipated
to generate a typical range of police service calls, such as vehicle burglaries, residential thefts, commercial
shoplifting, and disturbances. Additionally, future applicants would be required to coordinate with the Tustin
Police Department prior to project approval to ensure that adequate security precautions and design
features are in place.
Based on the City's current ratio of officers to residents (1.1 officers per 1,000), future buildout of the
proposed Project would result in the need for one additional police officer (1,189/1,000 x 1.1 = 1.31). Although
future buildout of the proposed Project would incrementally increase the demand for City police protection
services, this demand would not be expected to require the construction of new facilities or the expansion of
existing facilities.
The Police Department's operating budget and expansion of facilities, personnel, and equipment is from the
City's General Fund. Funding from property taxes, as a result of population growth, would be expected to
grow roughly proportional to any increase in residential units and businesses in the City. Tustin Police
Department would continue to add staff and equipment on an as -needed basis to accommodate the
incrementally increasing demands from future development, including the proposed Project. Therefore, the
additional demand for police services and protection generated by the proposed Project would be satisfied
through the General Fund. Therefore, impacts would be less than significant.
5.7.3.6 POLICE SERVICES CUMULATIVE IMPACTS
The geographic area for cumulative analysis of police services is the service territory for Tustin Police
Department. The Police Department's operating budget is primarily generated through tax revenues and
fees collected from penalties and requested services. Increased property and sales tax from cumulative
projects would increase the City's General Fund in rough proportion to population increases, providing
funding for any improvements necessary to maintain adequate police protection facilities, equipment, and/or
personnel. Consequently, although the cumulative demand for police services would incrementally increase
over time, the addition of new officers and equipment to serve the demand is not likely to result in any
significant adverse cumulative impacts associated with the construction of new facilities or the alteration of
existing facilities. Further, should any new or altered facilities be required in the future, these facilities would
be subject to separate CEQA review. Therefore, cumulative impacts associated with police services would
be less than significant.
5.7.3.7 POLICE SERVICES EXISTING STANDARD CONDITIONS AND PLANS,
PROGRAMS OR POLICIES
There are no applicable regulations related to police services that would reduce potential impacts.
City of Tustin 5.7-9
Draft EIR
June 2024
Enderle Center Rezone
5.7 Public Services
5.7.3.8 POLICE SERVICES LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact PS-2 would be less than significant.
5.7.3.9 POLICE SERVICES MITIGATION MEASURES
No mitigation measures are required.
5.7.3.10 POLICE SERVICES LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to police services would occur.
5.7.4 SCHOOL SERVICES
5.7.4.1 SCHOOL SERVICES REGULATORY SETTING
California State Assembly Bill 2926: School Facilities Act of 1986
In 1986, AB 2926 was enacted to authorize the levy of statutory fees on new residential and
commercial/industrial development in order to pay for school facilities. AB 2926 was expanded and revised
in 1987 through the passage of AB 1600, which added Sections 66000 et seq. to the Government Code.
Under this statute, payment of statutory fees by developers serves as CEQA mitigation to satisfy the impact
of development on school facilities.
California Senate Bill 50
The passage of SB 50 in 1998 defined the needs analysis process that is codified in Government Code
Sections 65995.5 through 65998. Under the provisions of SB 50, school districts may collect fees to offset
the costs associated with increasing school capacity as a result of development. Level I fees are assessed
based upon the proposed square footage of residential, commercial/industrial, and/or parking structure
uses. Level II fees require the developer to provide one-half of the costs of accommodating students in new
schools, and the state provides the other half. Level III fees require the developer to pay the full cost of
accommodating the students in new schools and are implemented at the time the funds available from
Proposition 1 A (approved by the voters in 1998) are expended. School districts must demonstrate to the
state their long-term facilities needs and costs based on long-term population growth in order to qualify for
this source of funding.
City of Tustin General Plan
The City's General Plan Land Use Element contains the following goals and policies related to school services.
Goal 8: Ensure that necessary public facilities and services should be available to accommodate
development proposed on the Land Use Policy Map.
Policy 8.1: Encourage within economic capabilities, a wide range of accessible public facilities and
community services including fire and police protection, flood control and drainage,
educational, cultural and recreational opportunities and other governmental and municipal
services. Senate Bill (SB) 50, adopted in 1998, prohibits the City from using the inadequacy
of school facilities as a basis for denying or conditioning the development of property. SB
City of Tustin 5.7-10
Draft EIR
June 2024
Enderle Center Rezone
5.7 Public Services
50, however, gave school districts new authority to raise school impact mitigation fees. In
addition, the voters passed Proposition 1 A in November 1998, which provides $9.2 billion
dollars in bonds to construct new or expand existing schools. In summary, school districts
have the financial means and legal authority to respond to new development.
Goal 9: Continue to provide for a planned community in East Tustin compatible with the land
use characteristics of the local area and sensitive to the natural environment.
Policy 9.2: Provide for supporting land uses in East Tustin, including neighborhood commercial centers,
park and recreational facilities, and schools, to serve the residential community.
5.7.4.2 SCHOOL SERVICES ENVIRONMENTAL SETTING
The Project site is located within the Tustin Unified School District (TUSD) boundary, which includes the City of
Tustin, portions of the City of Irvine, and portions of unincorporated areas of Orange County. TUSD has a
total of 29 schools including: 16 elementary schools, two Kindergarten through 81"-grade schools, one
Kindergarten through 12r"-grade online school, four middle schools, one 6'"-grade through 121"-grade
academy, four high schools, and one adult education school.
According to the data from California Department of Education, TUSD has an enrollment of 21,830 students
in the 2022/2023 school year (California Department of Education, 2024). The Project site is in the
attendance areas of Guin Foss Elementary School (18492 Vanderlip Ave), which is approximately 1.3
roadway miles and 1.0 linear miles from the Project site; Columbus Tustin Middle School (17952 Beneta
Way), which is approximately 1.1 roadway miles and 0.7 linear miles from the Project site; and Foothill
High School (19251 Dodge Ave), which is approximately 2.2 roadway and 1.7 linear miles from the Project
site (PowerSchool, 2024). Table 5.7-3 shows the total capacity, the 2022-2023 school year enrollments,
and the remaining capacity of the schools that would serve students residing on the Project site. As shown on
Table 5.7-3, Guin Foss Elementary School does not have remaining capacity to serve additional students,
while Columbus Tustin Middle School and Foothill High School both have remaining capacity to serve
approximately 177 and 44 additional students, respectively.
Table 5.7-3: Existing School Capacity of Schools Serving the Project Site
School
2023/2024 Capacity
2022/2023 Enrollment
Remaining Capacity
Guin Foss Elementary School (K-5)
389
416
-27
Columbus Tustin Middle School (6-8)
781
604
177
Foothill High School (9-12)
2,232
2,188
44
Total
3,402
3,208
-194
Source: (Special District Financing & Administration, April 2024)
5.7.4.3 SCHOOL SERVICES THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to
result in substantial adverse physical impacts associated with the provision of new or physically altered
school facilities, the construction of which could cause significant environmental impacts, in order to maintain
acceptable service ratios, response times or other performance objectives for school services.
City of Tustin 5.7-1 1
Draft EIR
June 2024
Enderle Center Rezone
5.7 Public Services
5.7.4.4 SCHOOL SERVICES METHODOLOGY
The potential impacts related to school services were evaluated based on the ability of existing and planned
schools to accommodate the student population that would be generated by the proposed Project.
Specifically, impacts on schools are determined by analyzing the estimated increase in student population
as a result of Project build out, and comparing the increase to the capacity of schools that would serve the
Project site, which determines whether new or altered facilities would be required, the construction of which
could result in adverse environmental effects.
As described in the TUSD Fee Justification Report for Residential and Commercial/Industrial Development,
school districts anticipate the number of students that would be generated by new residential development
to plan for needed facilities. The generation rates used by the TUSD are listed in Table 5.7-4.
Table 5.7-4: Tustin Unified School District Student Generation Rates
School Type
Generation Rate (All
Dwelling Types)
Elementary School (K-5)
0.1602
Intermediate School (6-8)
0.0906
High School (9-12)
0.1208
Source: (Special District Financing & Administration, April 2024)
5.7.4.5 SCHOOL SERVICE ENVIRONMENTAL IMPACTS
IMPACT PS-3 THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS
ASSOCIATED WITH THE PROVISION OF NEW OR PHYSICALLY ALTERED SCHOOL
FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT
ENVIRONMENTAL IMPACTS.
Less than Significant Impact. The proposed Project is a rezone within the Enderle Center site. A specific
development project is not proposed as part of this Project. The proposed HO district will allow residential
uses on the Project site, which currently only allows commercial uses. However, the development that could
occur from future buildout of the proposed Housing Overlay is 413 dwelling units and 118,474 SF of
nonresidential uses. Future buildout of the Project would provide housing for families that may have school
children. As shown in Table 5.1 1-5, based on the TUSD student generation rates, the proposed Project would
result in 66 elementary students, 37 intermediate students, and 50 high school students, which would total
153 students at Project buildout. The student population would account for approximately 13 percent of the
total 1,189 residents at full occupancy.
Table 5.7-5: Students at Project Buildout
School Type
Generation Rate (All
Dwelling Types)
Dwelling Units
Project Generated
Students
Elementary School (K-5)
0.1602
413
66
Intermediate School (6-8)
0.0906
413
37
High School (9-1 2)
0.1208
413
50
Total Students
153
Source: (Special District Financing & Administration, April 2024)
As shown in Table 5.7-6, at buildout of the proposed Project, Guin Foss Elementary and Foothill High School
would be over -capacity and additional or expanded facilities may be needed, while Columbus Tustin Middle
City of Tustin 5.7-12
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.7 Public Services
School would retain additional capacity for future students. A service letter was sent to TUSD requesting
information regarding the District's ability to service the Project. On April 12, 2024, Tom Rizzuti, Director of
Facilities and Planning, responded stating TUSD has no current plans to build new schools in the District.
Additionally, the response stated that the District reserves the right to send students generated by the Project
to other schools in the District if space is not available at the current schools of attendance. Thus, although
two of the schools serving the Project site are over capacity, the District could send students generated by
the Project to other schools within the District that have capacity to accommodate additional students.
Table 5.7-6: Remaining School Capacity with Buildout of the Proposed Project
2023/2024
2022/2023
Remaining
Project
Remaining
School
Capacity
Enrollment
Capacity
Generated
Capacity
Students
with Project
Guin Foss Elementary School (K-
389
396
-27
67
-94
5)
Columbus Tustin Middle School
781
609
177
38
139
(6-8)
Foothill High School (9-12)
2,232
2,276
44
50
-6
Source: (Special District Financing & Administration, April 2024) (California Department of Education, 2024)
As described within the Regulatory Setting, the need for additional school facilities is addressed through
compliance with school impact fee assessment. SB 50 (Chapter 407 of Statutes of 1998) sets forth a state
school facilities construction program that includes restrictions on a local jurisdiction's ability to condition a
project on mitigation of a project's impacts on school facilities in excess of fees set forth in the Government
Code. These fees are collected by school districts at the time of issuance of building permits for commercial,
industrial, and residential projects. The existing TUSD development impact fee is $4.08 per square foot for
all new residential development, and $0.66 per square foot for new commercial development. Effective
June 21, 2024, the development impact fee for residential development will be %5,17 per square foot and
$0.48 per square foot for commercial development (Tustin Unified School District, 2024). Pursuant to
Government Code Section 65995, applicants pay developer fees to the appropriate school districts at the
time building permits are issued; and payment of the adopted fees provides full and complete mitigation of
school impacts. As a result, impacts related to school facilities would be less than significant with the
Government Code -required fee payments.
5.7.4.6 SCHOOL SERVICES CUMULATIVE IMPACTS
The geographic context for cumulative impacts to schools is the TUSD boundaries. The proposed Project and
other development within TUSD could generate additional students resulting in the need to expand or
construct new schools. As described above, at buildout, the proposed Project could generate approximately
153 additional students. Some of these students would be accommodated by the existing schools with
additional capacity. However, some students would be transferred by the District into other schools within
TUSD that have additional capacity.
The attendance boundaries of Guin Foss Elementary School, Columbus Tustin Middle School, and Foothill High
School include areas anticipating several residential development projects that are anticipated to generate
additional students within the attendance boundaries of these schools. Thus, the proposed Project in
combination with related projects would result in the exceedance of capacity at a minimum of two school
facilities, therefore Guin Foss Elementary and Foothill High School may be over capacity with implementation
of the proposed Project in combination with related projects.
However, as described above, the state provided authority for school districts to assess impact fees for both
residential and non-residential development projects. Fees collected in accordance with Government Code
City of Tustin 5.7-13
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June 2024
Enderle Center Rezone Proiect 5.7 Public Services
Section 65995(b) allow TUSD to plan and construct for future growth. Furthermore, the payment of those
fees constitutes full mitigation for the impacts generated by new development, per Government Code Section
65995, which would reduce potential impacts related to the projects cumulative school service impacts to a
less than significant level.
5.7.4.7 SCHOOL SERVICES EXISTING STANDARD CONDITIONS AND PLANS,
PROGRAMS OR POLICIES
• Government Code Section 65995(b)
5.7.4.8 SCHOOL SERVICES LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact PS-3 would be less than significant.
5.7.4.9 SCHOOL SERVICES MITIGATION MEASURES
No mitigation measures are required.
5.7.4.10 SCHOOL SERVICES LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to school services would occur.
5.7.5 LIBRARY SERVICES
5.7.5.1 LIBRARY SERVICES REGULATORY SETTING
There are no federal, state, or local regulations related to library services.
5.7.5.2 LIBRARY SERVICES ENVIRONMENTAL SETTING
The Orange County Public Library (OCPL) provides library services to the City, including the Project site.
OCPL has 33 branch libraries in 24 incorporated cities and unincorporated areas of Orange County and
has a system -wide collection of approximately 2.5 million items (Orange County Public Libraries, 2020). The
City of Tustin has one branch library operated by OCPL: the Tustin Library, located at 345 East Main Street,
approximately 1.7 roadway miles southeast of the Project site.
The Tustin Library branch has amenities such as public computers with internet access, a Memory Lab for
library users to digitize their own documents, a local history collection featuring books specific to the Tustin
community and surrounding area and OC Read. OC Read is a program designed to support adult learners
to further their work, family, and personal goals.
OCPL has a service standard of 0.2 SF of library facility per capita for the purpose of projecting the need
for additional library services (Orange County, 2020).
5.7.5.3 LIBRARY SERVICES THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to
result in substantial adverse physical impacts associated with the provision of a new or physically altered
library facility, the construction of which could cause significant environmental impacts, in order to maintain
acceptable service ratios, response times or other performance objectives for library services.
City of Tustin 5.7-14
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June 2024
Enderle Center Rezone
5.7 Public Services
5.7.5.4 LIBRARY SERVICES METHODOLOGY
The potential impacts related to library services were evaluated based on the ability of existing and planned
libraries to accommodate the population that would be generated by the proposed Project. Specifically,
impacts on libraries are determined by identifying the extent to which the Project would increase demand
for services and analyzing the estimated increase in capacity of libraries that would serve the Project site to
determine whether new or altered facilities would be required, the construction of which could result in
adverse environmental effects.
The potential impacts related to libraries are considered in the context of the capacity and use of existing
libraries. Due to the wide availability of information online, library usage has been declining in recent years
and library service needs are changing with increasing resources being available online and the availability
of high-speed internet services. As a result, library service standards (e.g., a certain number of volumes or
SF of building space per thousand residents) are no longer appropriate when assessing the needs of a
municipal library. A more appropriate standard is related to the physical usage of the library facility in
relation to its physical capacity.
Commercial and employment -generating land uses do not typically generate a demand for library services.
As such, the analysis of impacts on library services is based on the number of residents generated by the
proposed Project and their anticipated usage of library facilities.
5.7.5.5 LIBRARY SERVICES ENVIRONMENTAL IMPACTS
IMPACT PS-4 THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS
ASSOCIATED WITH THE PROVISION OF NEW OR PHYSICALLY ALTERED LIBRARY
FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT
ENVIRONMENTAL IMPACTS.
Less than Significant Impact. The proposed Project is a Housing Overlay (HO) district within the Enderle
Center site. The HO district will allow residential uses on the Project site, which currently only allows
commercial uses. The proposal is regulatory in nature, and a specific development project is not proposed
at this time. However, the development that could occur from future buildout of the proposed HOD is 413
dwelling units and 118,474 SF of nonresidential uses. As described in Chapter 5.6, Population and Housing,
buildout of the Project could result in an additional 1,189 residents in the City and 365 employees. This
increase in population would increase the demand for library services in the City. Based on OCPL's service
standards of 0.2 square feet of library space per capita, the Project would require approximately 518 SF
of library space. Funding for OCPL services is provided through County property taxes dedicated to the
library. These funds would be used to upgrade and expand existing facilities, as needed (The Davis
Company, 2010). Project impacts are anticipated to be adequately funded by an increase in tax revenue,
over an extended period of time, relative to the increase in development intensity. Therefore, future buildout
of the proposed Project would not result in the need for new or physically altered library facilities, the
construction of which could cause significant environmental impacts. Therefore, impacts to library services
would be less than significant.
5.7.5.6 LIBRARY SERVICES CUMULATIVE IMPACTS
The geographic scope for cumulative library services is the OCPL service area. Future development of the
proposed Project and cumulative projects would proportionally contribute to property taxes, a portion of
which would be dedicated to OCPL services. Cumulative projects could introduce residents into OCPL's service
area and increase demand for library services. However, all projects in the County would contribute towards
County property taxes that fund OCPL services throughout the County. These funds would be utilized to
upgrade and expand existing and/or planned library facilities and resources, as needed. Further, should
City of Tustin 5.7-15
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.7 Public Services
any new or altered facilities be required in the future, these facilities would be subject to separate CEQA
review. Therefore, impacts from cumulative impacts associated with library services would be less than
significant.
5.7.5.7 LIBRARY SERVICES EXISTING STANDARD CONDITIONS AND PLANS,
PROGRAMS OR POLICIES
• Government Code Section 65995(b)
5.7.5.8 LIBRARY SERVICES LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact PS-4 would be less than significant.
5.7.5.9 LIBRARY SERVICES MITIGATION MEASURES
No mitigation measures are required.
5.7.5.10 LIBRARY SERVICES LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to library services would occur.
5.7.6 REFERENCES
California Department of Education. (2023). 2022-23 Enrollment by Grade Tustin Unified Report (30-73643).
Retrieved from Data Quest:
htti2s://dq.cde.ca.gov/dataquest/dqcensus/EnrGrdLevels.aspx?cds=3073643&agglevel=district
&year=2022-23
California Department of Education. (2024). Data Quest. Retrieved from 2022-23 Enrollment by Grade:
https://dq.cde.ca.gov/dataquest/dgcensus/EnrGrdLevels.aspx?cds=3073643&agglevel=district
&year=2022-23
City of Tustin. (2018). City of Tustin General Plan.
City of Tustin. (2019, February 13). About Us. Retrieved from Tustin Police:
https://www.tustinca.org/l 77/About-Us
Orange County Fire Authority 2022 Statistical Annual Report. Accessed:
https://ocfa.org/Uploads/Transparency/OCFA%2OAnnual%2OReport%202022.pdf2O2O22202
018
Orange County. (2020). General Plan Public Services and Facilities Element. Retrieved from Orange County
Development Services: https://ocds.ocpubIicworks.com/service-areas/oc-development-
services/planning-development/codes-and-regulations/general-plan
Orange County Fire Authority. (2022). Fire Stations. Retrieved from Orange County Fire Authority:
https://www.ocfa.org/AboutUs/FireStations.aspx
Orange County Fire Authority. (2024). Operations. Retrieved from Orange County Fire Authority:
https://ocfa.org/AboutUs/Departments/0perations.aspx
Orange County Public Libraries. (2020). Libraries. Retrieved from Orange County Public Libraries:
https://www.ocpl.org/libraries
City of Tustin 5.7-16
Draft EIR
June 2024
Enderle Center Rezone
5.7 Public Services
PowerSchool. (2024). Tustin Unified School District. Retrieved from MySchool Locator:
https://locator.pea.powerschooI.com/?StudyID=215986
Special District Financing & Administration. (April 2024). Tustin Unified School District Fee Justification Report
for Residential & Commerical/Industrial Development.
SCAG Final 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy, "Connect SoCal
2024". Accessed: https://scag.ca.gov/connect-socal
The Davis Company. (2010). Orange County Public Libraries Facilities and Financing Study.
Tustin Unified School District. (2024). Developer Fees. Retrieved from
https://www.tustin.kl 2.ca.us/departments/business-services/fisca I -se rvices/deve loper-fees
City of Tustin 5.7-17
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5.7 Public Services
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City of Tustin 5.7-18
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5.8 Recreation
5.8 Recreation
5.8.1 INTRODUCTION
Pursuant to the requirements of CEQA, this section of the EIR analyzes whether the proposed Project would
(1) increase the use of existing parks and recreational facilities such that substantial physical deterioration
or degradation of the facilities would occur or be accelerated or that new or expanded facilities would be
required; or (2) result in substantial adverse construction -related effects associated with the provision of new
or physically altered parks and recreational facilities, whether onsite or offsite. Information within this section
is based on the following:
• City of Tustin General Plan (including 2021-2029 Housing Element), adopted November 2018 and
updated October 2022
• Tustin City Code
New housing can result in substantial population growth and the need for additional park and recreation
facilities. Because CEQA focuses on physical environmental effects, this section analyzes whether any physical
changes resulting from an increase in demands for park and recreation facilities from the proposed Project
could result in significant adverse environmental effects. Thus, an increase in use of parks and recreation
facilities would not, by itself, be considered a physical change in the environment. However, physical changes
in the environment resulting from the construction of new facilities or an expansion of existing facilities to
accommodate the increased staff or equipment needs related to substantial physical deterioration could
constitute a significant impact. The proposed Project has also been evaluated to determine its consistency
with the City's zoning code provisions related to the provision of park and recreation facilities.
5.8.2 REGULATORY SETTING
5.8.2.1 Federal Regulations
There are no federal regulations related to recreation that are applicable to the Project.
5.8.2.2 State Regulations
Mitigation Fee Act
The California Mitigation Fee Act, Government Code Sections 66000, et seq., allows cities to establish fees
to be imposed upon development projects for the purpose of mitigating the impact that the development
projects have upon a city's ability to provide specified public facilities. To comply with the Mitigation Fee
Act, a city must follow four primary requirements:
1. Make certain determinations regarding the purpose and use of a fee and establish a nexus or connection
between a development project or class of project and the public improvement being financed with the
fee;
2. Segregate fee revenue from the General Fund in order to avoid commingling of capital facilities fees
and general funds;
3. For fees that have been in the possession of the city for five years or more and for which the dollars
have not been spent or committed to a project the city must make findings each fiscal year describing
the continuing need for the money; and
A. Refund any fees with interest for developer deposits for which the findings noted above cannot be made.
City of Tustin 5.8-1
Draft EIR
June 2024
Enderle Center Rezone
5.8 Recreation
As described below, the City of Tustin has adopted a parkland dedication and/or in -lieu fee that is included
in Tustin City Code Section 9331(d).
5.8.2.3 Local and Regional Regulations
General Plan
The Conservation, Open Space, and Recreation Element of the City's General Plan includes the following
goals and policies that are relevant to the proposed Project:
Goal 1: Reduce air pollution through proper land use, transportation and energy use planning
Policy 1.4: Develop neighborhood parks near concentrations of residents to encourage pedestrian
travel to the recreation facilities.
Goal 14: Encourage the development and maintenance of a balanced system of public and
private parks, recreation facilities, and open spaces that serves the needs of existing
and future residents in the City of Tustin.
Policy 14.1: Provide Tustin with a full range of recreational and leisure opportunities that reflect the
community's current and future population size and demographic character.
Policy 14.2: Design new and renovated parks for convenient and accessible use by the disabled, elderly,
and otherwise less mobile persons within the community.
Policy 14.5: Coordinate with the Tustin Unified School District and other public and quasi -public agencies
for the maximum feasible use of public facilities to meet recreational needs.
Policy 14.6: Encourage all future public neighborhood and community parks in the City to be designed
as joint -use facilities contiguous with public schools and sharing playfields, playgrounds, and
other amenities wherever possible.
Policy 14.7: Require the incorporation and maintenance of open space areas which are located within
and primarily benefit particular subdivisions to be a financial responsibility of the
benefitting property owners.
Policy 14.8: Encourage and, where appropriate, require the inclusion of recreation facilities and open
space within future residential, industrial and commercial developments.
Policy 14.12: Ensure that the City's laws and related implementation tools relating to park dedication and
development (e.g., ordinances, regulations, in -lieu fee schedules, etc.) reflect current land
and construction costs, and are, in fact, providing adequate park land and facilities
concurrent with population growth.
Goal 17: Operate and maintain existing and future parks and recreation facilities so they are
safe, clean, and attractive to the public; and preserve, protect, and enhance both existing
and potential natural recreation areas to ensure that long-term public investments and
values are not unreasonably preempted, compromised, or prevented by neglect or
short-term considerations.
Policy 17.2: Require park designs (including landscape treatments, buildings, irrigation, etc.) that are
durable, reasonably standardized, and economical to maintain.
City of Tustin 5.8-2
Draft EIR
June 2024
Enderle Center Rezone
5.8 Recreation
Tustin City Code
Article 9, Chapter 3, Part 3, Section 9331(d) of the Tustin City Code discusses parkland dedications and
development fees for subdivisions. To adhere to the policies and standards for parks and recreational
facilities set forth in the General Plan Conservation/ Open Space/ Recreation Element, project proponents
may dedicate land or pay a fee in lieu or a combination of both. A park fee is required when: (1) there is
no public park or recreational facility required within the proposed subdivision; (2) the subdivision is less
than 50 parcels; or (3) the project is a conversion of an existing apartment complex to multiple -owner
occupancy. For subdivisions of 50 parcels or less, a project proponent may pay a fee in lieu of land
dedication. The Tustin City Code permits the voluntary dedication of land for park and recreation purposes
in subdivisions of 50 parcels or less. Dedication of land may be required by the City for a condominium,
stock cooperative, or community apartment project that exceeds 50 dwelling units, regardless of the number
of parcels. The land and fees must be used "only for the purpose of providing park and recreational facilities
to serve the area from which received, and the location of the land and amount of fees shall bear a
reasonable relationship to the use of the park and recreational facilities by the future inhabitants of the
subdivision, the community, and the general area from which it is received."
5.8.3 ENVIRONMENTAL SETTING
According to the City's General Plan, in 2011, the City had 113 acres of existing local and community parks,
but needed an additional 114 acres to serve its population based on a standard of 3 acres per 1,000
persons and the January 2011 City population of 75,781 (City of Tustin, 2018). According to the City Parks
and Recreation Director, the City of Tustin currently has 183.21 acres of parkland (C. Clanton, personal
communication, 2024 March 1 8). As discussed in Section 5.6, Population and Housing, of this Draft EIR, the
City had a population of 77,558 in 2023. Therefore, the City has approximately 2.36 acres of public park
and/or recreational space per 1,000 residents. Thus, the City of Tustin is currently parkland deficient and is
not meeting its standard of 3 acres of parkland per 1,000 residents. However, the City is currently in the
design phase for a new joint -use park at Heideman School (15571 Williams Street) that is expected to be
completed in 2026 that will contribute to the City's existing parkland.
There are no existing parks within the Project site. The closest existing park and recreation facilities to the
Project site (within 2 miles) in the City of Tustin are listed in Table 5.8-1. As shown, the City currently has two
existing parks that provide 20.4 acres of parkland within 2 miles of the Project site.
Table 5.8-1: Tustin Park Facilities within 2 Miles of the Project Site
Park Name
and Address
Amenities
Park
Acreage
Distance
from
Project Site
Travel Time
from Project
Site'
Columbus
ADA Accessible, Baseball / Softball Diamond, BBQs
13.9
1.2 miles
Walking: 25
Tustin Park
(2), Bocce Ball Court, Horseshoe Pit, Large Turf
acres
mins
Area, Parking, Picnic Areas, Picnic Shelter, Picnic
Driving: 3 mins
Tables (3 Tables), Playground, Restrooms
Peppertree
ADA Accessible, Baseball / Softball Diamond, BBQs
6.5 acres
1.2 miles
Walking: 27
Park
(2), Bocce Ball Court, Horseshoe Pit, Large Turf
mins
Area, Parking, Picnic Areas, Picnic Shelter, Picnic
Driving: 4 mins
Tables (3 Tables), Playground, Restrooms
Notes: 'Estimates per Google Maps
Source: (City of Tustin, 201 9)
' Note: This total includes Linear Park at Tustin Legacy which has not yet been constructed but has been set for future development.
City of Tustin 5.8-3
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Enderle Center Rezone
5.8 Recreation
5.8.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
REC-1 Increase the use of existing neighborhood and regional parks or other recreational facilities such
that substantial physical deterioration of the facility would occur or be accelerated.
REC-2 Include recreational facilities or require the construction or expansion of recreational facilities
which might have an adverse physical effect on the environment.
5.8.5 METHODOLOGY
The analysis below considers the increase in use of parks and recreation facilities that would be generated
by the proposed Project in relation to the ability of existing park and recreation facilities to accommodate
the increased use. The analysis considers whether an increase in use would result in the substantial physical
deterioration of existing recreational facilities, such as accelerated wear on sports facilities and fields, or in
the need for new or expanded facilities.
The analysis uses a parkland -to -population ratio to measure demand for recreational facilities that is based
upon the City's General Plan policy to attain 3 acres of park and recreation facilities per 1,000 residents.
The EIR evaluates the amount of recreational use areas that would be required by the proposed Project and
the extent of increased usage of existing parks and recreational facilities that might result in the substantial
physical deterioration of existing recreational facilities.
5.8.6 ENVIRONMENTAL IMPACTS
IMPACT REC-1: THE PROJECT WOULD NOT INCREASE THE USE OF EXISTING NEIGHBORHOOD AND
REGIONAL PARKS OR OTHER RECREATIONAL FACILITIES SUCH THAT SUBSTANTIAL
PHYSICAL DETERIORATION OF THE FACILITY WOULD OCCUR OR BE ACCELERATED.
Less than Significant.
The Project involves the implementation of a Housing Overlay (HO) district, which would allow for 7 acres of
the Project site to be developed with residential uses. A specific development project is not proposed as part
of the Project. However, implementation of the proposed Project would permit the development of 413
residential units within the Project site. In addition, there is a remaining development potential of 118,474
SF of nonresidential uses. The proposed Project would not directly affect park and recreational facilities;
however, it would increase the allowed residential density of the Project site, which in turn may result in an
increased number of residents who would use the existing parks and contribute to the cumulative demand
for regional and local parks and recreational facilities and services in Tustin.
As described in Section 5.8.3, Environmental Setting, as of March 2024, the City had a total of 183.2 acres
of parkland, or approximately 2.36 acres of parkland per 1,000 residents. Thus, the City is currently
parkland deficient and is not meeting its City standard of 3 acres per 1,000 residents. As described in
Section 5.6, Population and Housing, the Project is anticipated to result in 1,189 residents at full buildout.
This increase in residents could in turn increase demand for park and recreational facilities. Using the City's
standard of 3 acres of parkland for every 1,000 residents, the proposed Project would result in a demand
for approximately 3.57 additional acres of parkland to support the additional residents. Therefore, the
proposed Project would exacerbate the City's parkland deficiency. However, future implementation of
development projects would be required to determine their fair share of park facilities and either provide
adequate park facilities or pay in lieu fees in accordance with Tustin City Code (Article 9, Chapter 3, Part
3, Section 9331) (PPP R-1).
City of Tustin 5.8-4
Draft EIR
June 2024
Enderle Center Rezone Proiect 5.8 Recreation
Additionally, as listed in Table 5.8-1, there are 20.4 acres of parkland within 2 miles of the Project site
available for use by the proposed residents. Further, there is also an abundance of existing recreational
facilities within the region, such as Peters Canyon Regional Park, Santiago Canyon, and Crystal Cove State
Park, that would be available for use by future residents. Therefore, due to the limited increase of residents
that would occur from implementation of the proposed Project and the amount of available park space
within the vicinity of the Project site, future residents are not anticipated to increase the use of existing parks
and recreation facilities such that substantial physical deterioration of such parks and facilities would occur.
Therefore, impacts would be less than significant.
IMPACT REC-2: THE PROJECT WOULD NOT INCLUDE RECREATIONAL FACILITIES OR REQUIRE THE
CONSTRUCTION OR EXPANSION OF RECREATIONAL FACILITIES WHICH MIGHT
HAVE AN ADVERSE PHYSICAL EFFECT ON THE ENVIRONMENT.
Less than Significant.
As discussed above, the Project involves the implementation of a Housing Overlay (HO) district, which would
allow for 7 acres of the Project site to be developed with residential uses. The Project does not include the
construction or expansion of parks. As described above, implementation of future developments allowed by
the proposed Project may increase the population by approximately 1,189 persons, resulting in the need
for approximately 3.57 more acres of parkland to serve the future population. However, future
implementation of development projects would be required to determine park needs and to pay
development fees to contribute to the construction or expansion of recreational facilities. Should new facilities
be required as a result of new development within the Project site, these new developments would pay an
impact fee to the City pursuant to Tustin City Code Section 9331 (PPP R-1). Any new or expanded facilities
would be constructed by the City, since they are the responsible party that acquires, constructs, and maintains
new parks and recreation areas. Thus, the Project would have less -than -significant impacts on the construction
or expansion of recreational facilities or services.
5.8.7 CUMULATIVE IMPACTS
The cumulative area of recreation impacts for the proposed Project includes the City of Tustin. As detailed
previously, the City currently has approximately 2.36 acres of public park and/or recreational space per
every 1,000 residents, which is below the City's parkland standard of 3 acres of parkland per 1,000
residents. Based on 3 acres of public park and/or recreational space per 1,000 residents, buildout of the
proposed Project results in a need for approximately 3.57 acres of parkland to serve the 1,189 new
residents of the Project site. However, implementation of future development projects would be required to
determine their fair share of park facilities, and either provide adequate park facilities or pay in lieu fees,
in accordance with Tustin City Code Section 9331 (PPP R-1). Although there is currently a deficit of improved
City park space, all future proposed Project and cumulative projects would be required to provide park and
recreational facilities and/or pay in -lieu fees as required by the Tustin City Code, as described in the
General Plan and City Code. Therefore, the proposed Project's impacts related to the amount of parkland
within the City would not result in a cumulatively considerable impact related to parks and recreational
facilities.
5.8.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
California Code Sections 66000 (Mitigation Fee Act)
City of Tustin 5.8-5
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June 2024
Enderle Center Rezone
5.8 Recreation
Plans, Programs, or Policies
PPP R-1: City Park Requirements. Tustin City Code Section 9331 — Dedications, Reservations and
Development Fees. All future development shall be consistent with this standard.
5.8.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact REC-1 and Impact REC-2 would be less than significant.
5.8.10 MITIGATION MEASURES
5.8.1 1 NO MITIGATION MEASURES ARE REQUIRED FOR THE PROPOSED
PROJECT. LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to recreation would occur.
5.8.1 2 REFERENCES
City of Tustin. (2018). City of Tustin General Plan.
City of Tustin. (2019). Parks Information. Retrieved from Tustin Parks and Recreation:
https://www.tustinca.org/715/Parks-Information
City of Tustin 5.8-6
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June 2024
Enderle Center Rezone Proiect 5.9 T
5.9 Transportation
5.9.1 INTRODUCTION
This section addresses potential transportation impacts that may result from implementation of the proposed
Project. The following discussion addresses the existing transportation conditions in the Project area, identifies
applicable regulations, evaluates the proposed Project's consistency with applicable goals and policies,
identifies and analyzes environmental impacts, and, if necessary, recommends measures to reduce or avoid
adverse impacts anticipated from implementation of the proposed Project. This analysis has been prepared
in accordance with CEQA requirements to evaluate potential transportation impacts based on vehicle miles
traveled (VMT). Information within this section is based on the following:
• City of Tustin General Plan (including 2021 -2029 Housing Element), adopted November 2018, updated
October 2022.
• Tustin City Code.
• Connect SoCal 2024 Regional Transportation PlanlSustainable Communities Strategy (RTP/SCS), adopted
April 2024.
• Enderle Center Rezone Project Vehicle Miles Traveled (VMT) Analysis, prepared by EPD Solutions, May
2024 (Appendix D).
Transportation Terminology
• Major: A six- to seven -lane divided roadway with no on -street parking, with a typical right-of-way
width of 120 to 144 feet and a curb -to -curb pavement width of 102 to 126 feet. Major arterials
typically carry a significant volume of regional traffic. When the traffic volumes warrant a major arterial
highway in areas where a full 120 to 144 feet of right-of-way is not feasible due to existing structures
or topography, a lesser right-of-way (no less than 100 feet) can be used to accommodate a six -lane
facility. This is referred to as a "modified major" on the City Arterial Highway Plan.
• Primary: A four -lane divided roadway, with a typical right-of-way width of 100 feet and curb -to -curb
pavement width of 84 feet. Regional traffic will typically be less than for a major arterial, but primary
arterials form an important component of the regional transportation system. When the traffic volumes
warrant a primary arterial highway in areas where a full 100 feet of right-of-way is not feasible due
to existing structures or topography, a lesser right-of-way (no less than 80 feet) can be used to
accommodate a four -lane facility. This is referred to as a "modified primary" on the City Arterial
Highway Plan.
• Secondary: A four -lane undivided roadway, with a typical right-of-way width of 80 feet and a curb -
to -curb pavement width of 64 feet. These roadways serve as collectors, distributing traffic between
local streets, and major and primary arterials.
• Collector: A two-lane undivided roadway, with a minimum right-of-way width of 66 feet and a minimum
curb -to -curb width of 50 feet. The width may be increased to accommodate roadway features such as
bicycle lanes, on -street parking, and turn lanes. At level of service (LOS) "C," this road type
accommodates up to approximately 10,000 vehicle trips per day. This road functions as a collector
facility, however it tends to move traffic between two arterials rather than between local streets, it has
been added to the City's arterial highway system because it provides network continuity and is
regionally significant and may serve through traffic demand where projected volumes do not warrant a
higher classification such as Secondary.
• Divided Collector: A two-lane, two-way divided roadway, with a minimum right-of-way width of 80
feet and a minimum curb -to -curb width of 56 feet including on -street parking and bike lanes. The width
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may be decreased when no parking spaces are provided or increased to accommodate roadway
features such as turn lanes. At LOS "C," this road type accommodates up to approximately 15,000
vehicle trips per day. Similar to Collectors, this road functions as a collector facility, however it tends to
move traffic between two arterials rather than between local streets, it has been added to the City's
arterial highway system because it provides network continuity and is regionally significant and may
serve through traffic demand where projected volumes do not warrant a higher classification such as
Secondary.
• Class I Bike Path or Bike Trail. Provides a completely separated right-of-way designated for the
exclusive use of bicycles and pedestrians; crossflows with motorized vehicles minimized. The minimum
width for Class I (two-way) is 8 feet, desired width is 10-1 2 feet, and minimum shoulder width 2 feet on
each side. The minimum width for Class I (one-way) is 5 feet with minimum shoulder width of 2 feet on
each side.
• Class II Bike Lane. Provides a restricted right-of-way on a roadway's shoulder designated for the
exclusive or semi -exclusive use of bicycles with through travel by motor vehicles or pedestrians
prohibited; vehicle parking and crossflows by pedestrians and motorists permitted. Vehicle parking in a
Class II bike lane is not desirable and should be discouraged and/or restricted where possible.
Additional lane width (1 2 feet minimum and 13 feet desirable) shall be required if on -street parking is
permitted with a typical width of eight feet. A reduction in width to allow for restriping of an existing
roadway or for added turning lanes may be permitted. In such cases, a five-foot width, or gutter width
plus three feet, whichever is greater, is the minimum width.
• Class III Bikeway. Provides for shared use of roadway facilities. These bikeways share the street with
motor vehicles or share the sidewalk with pedestrians. In both conditions, bicycle use is a secondary
function of the pavement.
• Traffic Analysis Zone (TAZ). Traffic Analysis Zone (TAZ) refers to the geographic unit used for traffic
analysis within transportation planning models, such as the Orange County Transportation Analysis Model
(OCTAM) VMT Screening Tool model. A TAZ is a special area delineated by state and/or local
transportation officials for tabulating traffic -related data especially journey -to -work and place -of -work
statistics. A TAZ usually consists of one or more census blocks, block groups, or census tracts.
• Transit Priority Area (TPA). As defined by Senate Bill (SB) 743, a Transit Priority Area (TPA) is an area
located within a one-half mile of an existing or planned "major transit stop" or an existing stop along a
"high quality transit corridor." Per Public Resources Code, Section 21064.3, "`Major transit stop' means
a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit
service, or the intersection of two or more major bus routes with a frequency of service interval of 15
minutes or less during the morning and afternoon peak commute periods." Per Public Resources Code,
Section 21155, a high -quality transit corridor means a "corridor with fixed route bus service with service
intervals no longer than 15 minutes during peak commute hours."
• Vehicle Miles Traveled (VMT). VMT is defined as the total miles traveled by vehicles (within a
transportation network).
• Low VMT Area. The City of Tustin defines low VMT areas as traffic analysis zones (TAZs) with a total
daily VMT per capita or VMT per employee that is less than the base level for the city.
5.9.2 REGULATORY SETTING
5.9.2.1 State Regulations
Senate Bill 743 (Steinberg, 2013)
On September 27, 2013, Senate Bill 743 (SB 743) was signed into State law. The California legislature
found that with the adoption of the Sustainable Communities and Climate Protection Act of 2008 (SB 375),
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the State had signaled its commitment to encourage land use and transportation planning decisions and
investments that reduce vehicle miles traveled (VMT) and thereby contribute to the reduction of greenhouse
gas (GHG) emissions, as required by the California Global Warming Solutions Act of 2006 (AB 32).
SB 743 requires the California Governor's Office of Planning and Research to amend the State CEQA
Guidelines to provide an alternative to level of service (LOS) as the metric for evaluating transportation
impacts under CEQA. Particularly within areas served by transit, SB 743 requires the alternative criteria to
promote the reduction of greenhouse gas emissions, development of multimodal transportation networks, and
diversity of land uses. The alternative metric for transportation impacts detailed in the State CEQA
Guidelines is VMT. Jurisdictions had until July 1, 2020, to adopt and begin implementing VMT thresholds for
traffic analysis.
AB 1358: California Complete Streets Act
The California Complete Streets Act was implemented on January 1, 2011, which required circulation
elements to address the transportation system from a multimodal perspective. The bill states that streets,
roads, and highways must "meet the needs of all users... in a manner suitable to the rural, suburban, or urban
context of the general plan." This bill requires a circulation element to plan for all modes of transportation
where appropriate —including walking, biking, car travel, and transit. The Complete Streets Act also requires
circulation elements to consider the multiple users of the transportation system, including children, adults,
seniors, and people with disabilities.
California Fire Code
The California Fire Code sets requirements pertaining to fire safety and life safety, including for emergency
access and evacuation (California Code of Regulations Title 24 Part 9). The California Fire Code is
incorporated by reference in Article 8 Chapter 8100 of the Tustin Municipal Code.
5.9.2.2 Local and Regional Regulations
Regional Transportation Plan/Sustainable Communities Strategy
The Southern California Association of Governments (SCAG) is the designated metropolitan planning
organization for six Southern California counties (Ventura, Los Angeles, San Bernardino, Riverside, Orange,
and Imperial). As the designated metropolitan planning organization, SCAG is mandated by the federal
and State governments to prepare plans for regional transportation and air quality conformity. The most
recent plan adopted by SCAG is the 2024-2050 Regional Transportation Plan/Sustainable Communities
Strategy (RTP/SCS), also known as Connect SoCal, which was adopted in April 2024. The RTP/SCS
integrates transportation planning with economic development and sustainability planning and aims to
comply with State GHG emissions reduction goals, such as SB 375. With respect to transportation
infrastructure, SCAG anticipates, in the RTP/SCS, that the six -county region will have to accommodate
20,909,000 residents by 2050 while also meeting the GHG emissions reduction targets set by the California
Air Resources Board. SCAG is empowered by State law to assess regional housing needs and provide a
specific allocation of housing needs for all economic segments of the community for each of the region's
counties and cities. In addition, SCAG has taken on the role of planning for regional growth management.
City of Tustin General Plan
The City's General Plan includes the following goals and policies related to transportation in the Circulation
Element and Growth Management Element:
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Circulation Element
Goal 1: Provide a system of streets that meets the needs of current and future inhabitants and
facilitates the safe and efficient movement of people and goods throughout the City
consistent with the City's ability to finance and maintain such a system.
Policy 1.2: Develop and implement circulation system standards for roadway and intersection
classifications, right-of-way width, pavement width, design speed, warrant requirements,
capacity, maximum grades and associated features such as medians and bicycle lanes or
trails that are adjacent or off -road.
Policy 1.3: Coordinate roadway improvements with applicable regional, state and federal
transportation plans and proposals.
Policy 1 A Develop and implement thresholds and performance standards for acceptable levels of
service.
Policy 1.10: Require that proposals for major new developments include a future traffic impact analysis
which identifies measures to mitigate any identified project impacts.
Policy 1.11: Encourage new development which facilitates transit services, provides for non -vehicular
circulation and minimizes vehicle miles traveled.
Policy 1.15: Ensure construction of existing roadways to planned widths, as new developments are
constructed.
Policy 1.16: Continue to require dedication of right-of-way and construction of required public
improvements on streets adjacent to construction projects at the developers expense.
Goal 5: Support development of a public transportation system that provides mobility to all City
inhabitants and encourages use of public transportation as an alternative to automobile
travel.
Policy 5.2: Require new development to fund transit facilities, such as bus shelters and turn -outs, where
deemed necessary to meet public needs arising in conjunction with development.
Policy 5.5: Promote new development that is designed in a manner which facilitates provision or
expansion of transit service and provides non -automobile circulation within the development.
Goal 6: Increase the use of non -motorized modes of transportation.
Policy 6.1: Promote the safety of pedestrians and bicyclists by adhering to uniform standards and
practices, including designation. of bicycle lanes, off -road bicycle trails, proper signage,
and adequate sidewalk, bicycle lane, and off -road bicycle trail widths.
Policy 6.2: Maintain existing pedestrian facilities and require new development to provide pedestrian
walkways between developments, schools and public facilities.
Policy 6.8: Support retrofit installation of sidewalks in industrial districts and Planned Community
Business Parks as development occurs.
Policy 6.14: Require new development to dedicate land and fund improvement of bicycle, pedestrian
and equestrian facilities, where deemed necessary to meet public needs arising in
conjunction with development.
Goal 7: Provide for well -designed and convenient parking facilities.
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Policy 7.1: Consolidate parking, where appropriate, to eliminate the number of ingress and egress
points onto arterials.
Policy 7.2: Provide sufficient off-street parking for all land uses.
Growth Management Element
Goal 2: Ensure adequate transportation facilities are provided for existing and future inhabitants
of the City.
Policy 2.1: Require that all new development pay its share of the street improvement costs associated
with the development, including regional traffic mitigation.
5.9.3 ENVIRONMENTAL SETTING
The public roadway network serving the Project site includes 17'h Street, Yorba Street, Enderle Center Drive,
Vandenburg Lane, and State Route (SR) 55, which are described below and listed in Table 5.9-1.
• 171h Street is a six -lane divided roadway with sidewalks on both sides that is designated as a major
arterial in the City of Tustin General Plan. 17'h Street is oriented in the east -west direction, has no bike
lanes, and has a posted speed limit of 40 miles per hour (mph). On -street parking is not permitted on
either side of this roadway.
• Yorba Street is a four -lane undivided roadway between 1711 Street and Vandenberg Lane and is
oriented in the north -south direction with sidewalks on both sides. The roadway is designated as a
secondary arterial in the City of Tustin General Plan and the posted speed limit is 40 mph. On -street
parking is not permitted along this roadway and there are no bike lanes.
• Enderle Center Drive is a two-lane undivided roadway between 171h Street and Vandenberg Lane and
is undesignated in the General Plan. Enderle Center Drive is oriented in the north -south direction, has no
bike lanes, has a posted speed limit of 40 mph, and has a sidewalk on the east side.
• Vandenberg Lane is a two-lane undivided roadway between Yorba Street and Enderle Center Drive
and is undesignated in the General Plan. The roadway is aligned in an east -west direction, has sidewalks
on both sides of the street, and has a posted speed limit of 30 mph. On -street parking is permitted
along this roadway.
• SR 55 is a 1 2-lane divided roadway oriented in the north -south direction. The posted speed limit on SR
55 is 55 mph and it is classified as a freeway in the General Plan. On -street parking is not permitted
along this roadway.
Table 5.9-1, Existing Roadway Characteristics within Specific Plan Study Area, shows the roadway
characteristics of the roadways directly serving the Project site.
Table 5.9-1: Existing Roadway Characteristics within Specific Plan Study Area
Roadway
Designation
Number of Lanes
Sidewalks?
Bike Lane?
Fronting Project Site
171h Street (E/W)
Major Arterial
6-lane divided.
Yes, both sides.
No
Yorba Street (N/S)
Secondary Arterial
4- lane undivided.
Yes, both sides.
No
Yes, on the
Enderle Center
northbound side.
Drive (N/S)
Undesignated
2- lane undivided.
None on the
No
southbound side
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Roadway
Designation
Number of Lanes
Fronting Project Site
Sidewalks?
Bike Lane?
Vandenberg Lane
(E/W)
Undesignated
2-lane undivided
Yes, both sides.
No
SR 55(N/S)
Freeway
1 2- lane divided.
No, both sides
No
5.9.3.1 Existing Site Access
Vehicular access to the Project site is currently provided via unsignalized driveways along 17'h Street, Yorba
Street, Vandenberg Lane, and Enderle Center Drive. Signalized access is provided on Yorba Street at the
intersection of Vandenberg Lane.
5.9.3.2 Existing Transit Service
Public transit bus service for the City is provided by the Orange County Transportation Authority (OCTA).
The established network includes Routes 60, 61, 65, 66, 71, 75 and 463. The Project is not located within a
Transit Priority Area (TPA); however, adjacent to the Project at the junction of 17th Street and Enderle Center
Drive, there are two existing public transit bus stations served by Route 60 with bus service every 30 minutes.
These stations are situated on both the northern side of 17'h Street and Yorba Street and on the southern
side of 171h Street and Enderle Center Drive. The major routes of travel for Route 60 include Larwin Square
to Long Beach via Newport and Seventeenth. Route 60 operates on approximately 30-minute headways on
weekdays and weekends and connects to the Newport Transportation Center.
The Metrolink Orange County Line and the Inland Empire -Orange County commuter lines travel through
Tustin, with stops at the Santa Ana Metrolink Station located 1.7 miles west of the Project site and the Orange
Metrolink Station located 2.5 miles northwest of the Project site. In addition, passenger rail service is provided
from two Amtrak depots in neighboring cities; Irvine to the south and Santa Ana to the west, which connects
travelers to neighboring communities throughout Los Angeles and San Diego counties.
5.9.3.3 Existing Bicycle and Pedestrian Facilities
As shown on Table 5.9-1, there are no bike lanes on the public roadway network currently serving the Project
site. The closest existing bike lane to the Project site is a Class II Bike Lane east of Prospect Avenue along
17'h Street. According to Figure C-5, Master Bikeway Plan, of the City's General Plan, a Class II bike lane is
planned along Prospect Avenue, approximately 1,000 feet west of the Project site. However, this bike lane
has not been implemented. Sidewalks currently exist on both sides of 17rh Street, Vandenburg Lane, and
Yorba Street and on the northbound side of Enderle Center Drive.
5.9.3.4 Existing VMT
The Project site is currently vacant and undeveloped. As detailed in Table 5.9-2 below, the Project site
currently generates 7,058 daily trips, with 444 trips in the AM peak hour and 648 trips in the PM peak hour.
Low vehicle miles traveled (VMT) generating areas are defined as traffic analysis zones (TAZs) with a total
daily VMT per capita or VMT per employee that is less than the base level for the city. The Project site is
located in one low VMT area (per capita). The City of Tustin average city-wide VMT under the 2016 Base
Model Year is 15.0 home -based VMT per capita and 25.1 home -based work VMT per employee. The
Project site currently has a VMT of 12.0 per capita and a VMT of 23.7 per employee.
City of Tustin 5.9-6
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5.9.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
TRA-1 Conflict with a program, plan, ordinance, or policy addressing the circulation system, including
transit, roadway, bicycle, and pedestrian facilities.
TRA-2 Conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b).
TRA-3 Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment).
TRA-4 Result in inadequate emergency access.
Vehicle Miles Traveled Significance Criteria
State CEQA Guidelines Section I 5064.3(b)(1 ) provides that for land use projects:
VMT traveled exceeding an applicable threshold of significance may indicate a significant
impact. Generally, projects within 0.5 mile of either an existing major transit stop or a stop
along an existing high quality transit corridor should be presumed to cause a less than significant
transportation impact. Projects that decrease vehicle miles traveled in the project area
compared to existing conditions should be presumed to have a less than significant
transportation impact.
The Project is located in the City of Tustin (City). The City's Guidelines provide the following screening
thresholds to assess whether further VMT analysis is required. If a project meets one of the following criteria,
then the VMT impact of the project would be considered less -than -significant and no further analysis of VMT
would be required:
• Projects which consist of 100% affordable housing.
• Projects located within one half mile of qualifying transit. Qualifying transit is defined as follows:
o Major transit stop is defined as a site containing an existing rail transit station, a ferry terminal
served by either a bus or rail transit service, or the intersection of two or more major bus routes with
a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute
periods. (Pub. Resources Code, § 21064.3)
o High -quality transit corridor is defined as a corridor with fixed route bus service with service intervals
no longer than 15 minutes during peak commute hours. (Pub. Resources Code, § 21155).
• Projects which propose local serving retail (retail projects less than 50,000 square feet) or other local
serving uses. The types of projects considered local serving include K-1 2 schools, local parks, day care
centers, gas stations, libraries, fire stations, and other local serving civic uses.
• Projects located in a low VMT generating area propose a project similar to the conditions already
constructed in the area. Low VMT generating area is defined as traffic analysis zones (TAZs) with a total
daily VMT per capita or VMT per employee that is less than the base level for the city.
• Projects which generate less than 500 daily vehicle trips.
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VMT Per Capita
N
Legend: A
0 = VMT/employee less than or equal to City of Tustin 2016 citywide average VMT/employee
L_ j = City of Tustin Boundary
= Project Site
Enderle Center Rezone Project Figure 5.9-2
City of Tustin
Enderle Center Rezone
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City of Tustin 5.9-12
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VMT Per Employee
i
751
703
709
r15
7161
_- r{ 721
'35
754
756
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Legend: A
0 = VMT/employee less than or equal to City of Tustin 2016 citywide average VMT/employee
r -k = City of Tustin Boundary
L.a — Y Y
= Project Site
Enderle Center Rezone Project Figure 5.9-3
City of Tustin
Enderle Center Rezone
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5.9.5 METHODOLOGY
To determine whether the proposed Project would result in a significant impact related to conflict with a
program, plan, ordinance, or policy related to the effectiveness of the circulation system, the extent to which
the proposed Project would provide facilities to enhance the use of public transit, pedestrian, and bicycle
mobility, the proposed Project was compared to adopted plans for public transit, pedestrian mobility, and
bicycle facilities. A significant impact would result if the proposed Project resulted in a conflict that could
result in an impact on the environment.
As outlined in CEQA Guidelines Section 15064.3, except as provided for roadway capacity transportation
projects, a project's effect on automobile delay shall not constitute a significant environmental impact.
Therefore, this analysis has been prepared in accordance with CEQA requirements to evaluate potential
transportation impacts based on VMT. The City of Tustin Vehicle Miles Traveled Analysis Guidelines provides
criteria for projects that would be considered to have a less than significant impact on VMT and therefore
could be screened out from further analysis; and those that would have the potential to result in a VMT
impact and therefore require a VMT analysis based on VMT reduction thresholds. Consistent with the City
Guidelines, the VMT screening thresholds were used to identify if the proposed Project could have an impact
on VMT, which is detailed below. Trips generated by the proposed Project have been estimated based on
trip generation rates provided by the Institute of Transportation Engineers (ITE) Trip Generation Manual, 1 7t"
Edition, 2021.
Vehicle Miles Traveled Analysis Methodology
Consistent with the City's Guidelines, the VMT screening thresholds were used to identify if the Project could
have an impact on VMT. When a project fails to meet any of the aforementioned screening criteria, a more
comprehensive VMT analysis may be warranted. The City's guidelines require use of the Orange County
Transportation Analysis Model (OCTAM) for preparation of VMT analysis. The Model includes validated
scenarios for the years 2016 and 2045. These scenarios have been validated using existing traffic counts.
Data for years between 2016 and 2045 can be extrapolated using linear interpolation between the 2016
and 2045 Model output.
The City of Tustin VMT Guidelines utilizes recommendations provided by California Office of Planning and
Research (OPR) and modeling data provided by OCTA to establish the following VMT thresholds of
significance projects. The City's significance threshold for residential projects is based on the project's home -
based VMT per capita and the City's significance threshold for non-residential projects is based on the
project's employment VMT per employee. The significance criteria from the City's guidelines are as follows:
Residential Projects: A significant transportation impact occurs if:
1. The project's base year home -based VMT per capita exceeds the OCTAM base model year citywide
average VMT per capita for the City of Tustin.
2. The project's future year home -based VMT per capita exceeds the OCTAM base model year citywide
average VMT per capita for the City of Tustin.
Non-residential Projects: A significant transportation impact occurs if:
1. The project's base year employment VMT per employee exceeds the OCTAM base model year citywide
average VMT per employee for the City of Tustin.
2. The project's future year employment VMT per employee exceeds the OCTAM base model year
citywide average VMT per employee for the City of Tustin.
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The Project is located within one Model TAZ 1103. The total population and employed population of the
Project was calculated using the current household average in adjacent TAZs because there are currently no
existing households in TAZ 1103. The Project total households and population was entered into TAZ 1103.
Employment growth in TAZ 1103 was already accounted for by the model. The metric utilized as the
residential VMT threshold of significance for City of Tustin is the average city-wide VMT under 2016 Base
Model Year, which has been calculated to be 15.0 home -based VMT per capita. The metric utilized as the
employment VMT per employee VMT threshold of significance for City of Tustin is the average city-wide
VMT under 2016 Base Model Year, which has been calculated to be 25.1 home -based work VMT per
employee.
5.9.6 ENVIRONMENTAL IMPACTS
IMPACT TRA-1: THE PROJECT WOULD NOT CONFLICT WITH A PROGRAM, PLAN, ORDINANCE, OR
POLICY ADDRESSING THE CIRCULATION SYSTEM, INCLUDING TRANSIT, ROADWAY,
BICYCLE, AND PEDESTRIAN FACILITIES.
Less than Significant. The following analysis has been prepared pursuant to SB 743, which requires that
VMT thresholds be utilized for traffic analysis, and State CEQA Guidelines Section 15064.3 that states that
a project's effect on automobile delay shall not constitute a significant environmental impact.
Project Trip Generation: Vehicle trip estimates for future development under the proposed Project were
generated by using trip rates from the Institute of Transportation Engineers, Trip Generation I71h Edition,
2021. Existing conditions (Baseline) were assessed using trip rates for Land Use Code 932 (High -Turnover
Sit -Down Restaurant), 821 (Retail), and 710 (Office). Based on the density of the proposed housing, trip
rates for Land Use Code 221 (Multifamily Housing (Mid -Rise)) were used. Table 5.9-2 identifies the existing
trips generated by the existing development on the site and compares it to the potential future development
under the proposed Housing Overlay to determine the net increase in vehicle trips for the residential and
commercial portions of the Project. As detailed, potential future development is forecasted to generate
11,470 daily trips, with 757 trips in the AM peak hour and 1,041 trips in the PM peak hour. Future
development with the existing commercial development is forecasted to generate 18,528 daily trips,
including 1,201 AM peak hour and 1,689 PM peak hour trips.
Roadway: Regional access to the Project site is provided by SR-55. Local access to the site is provided via
17rh Street, Yorba Street, Vandenberg Lane, and Enderle Center Drive. Each roadway is described above
and in Table 5.9-1. The proposed Project would continue to provide vehicular access to the site from the
adjacent roadways and there would be no changes to the roadway access points. However, potential future
development facilitated by the Project may include driveway and roadway improvements. Specific roadway
improvements required to support residential development within the Enderle Center are not known at this
time and will not be known until a development project is proposed. Future projects under the proposed
Project would be required to comply with the circulation system standards and to adhere to uniform
standards and practices. Compliance with standards for roadway and intersection classifications, right-of-
way width, pavement width, design speed, warrant requirements, capacity, maximum grades and associated
features such as medians would be ensured and verified by the City during the plan check and permitting
process, prior to obtaining building permits. The proposed Project would not conflict with existing facilities
and would provide additional facilities as needed. Thus, impacts related to pedestrian facilities would not
occur.
Transit Services: As described previously, the Project vicinity is served by OCTA. There are two bus stops
within one mile of the Project site. The nearest OCTA bus stop is located near the Yorba Street/Enderle
Center Drive and 17th Street intersection, nearly adjacent to the Project site. Additionally, the Metrolink
Inland Empire -Orange County Line has a stop 1.7 miles east of the Project of the Project site, at the Santa
City of Tustin 5.9-16
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Enderle Center Rezone Proiect 5.9 Ti
Ana Metrolink Station. This existing transit service would continue to serve its ridership in the area.
Furthermore, specific infrastructure improvements required to support residential development within the
Enderle Center are not known at this time and will not be known until a development project is proposed.
However, potential future projects would be required, if deemed necessary, to fund transit facilities as
ensured and verified by the City during the plan check and permitting process, prior to obtaining building
permits. Therefore, the proposed Project would not alter or conflict with existing roadway facilities
addressed in the circulation element, and impacts related to roadway facilities would not occur.
Bicycle Facilities: As detailed previously, there are no bike lanes on any public roadway network currently
serving the Project site. In addition, the City's General Plan Circulation Element, Figure C-5 Master Bikeway
Plan, does not identify any roadway network currently serving the Project site as a planned bike lane or
bikeway. The nearest planned bicycle lane is located 1,000 feet west of the Project site at Prospect Avenue.
Implementation of the Project would not alter or conflict with existing or planned bike lanes or bicycle
transportation. Thus, impacts related to bicycle facilities would not occur.
Pedestrian Facilities: Sidewalks currently exist on both sides of 17'" Street, Vandenburg Lane, and Yorba
Street and on the northbound side of Enderle Center Drive within the vicinity of the Project site. The Project
does not propose a specific development or any demolition, including sidewalks; however, potential future
development facilitated by the Project may include sidewalk improvements. Specific sidewalk improvements
required to support residential development within the Enderle Center are not known at this time and will
not be known until a development project is proposed. Future projects under the proposed Housing Overlay
would be required to comply with and adhering to uniform standards and practices, including designation
of bicycle lanes and adequate sidewalk as ensured and verified by the city during the plan check and
permitting process, prior to obtaining building permits. Additionally future development is subject to
compliance with applicable accessibility requirements of the American Disabilities Act, Title 24 of the Uniform
Building Code as locally amended, and the Department of Housing and Urban Development's Fair Housing
Accessibility Guidelines (PPP T-1). Therefore, the proposed Project would not conflict with pedestrian
facilities, but instead would provide additional facilities. Thus, impacts related to pedestrian facilities would
not occur.
Policies: Section 5.4, Land Use, includes a list of applicable goals and policies related to the Project. Tables
5.4-1 and 5.4-2 include analysis of the Project's consistency with the 2020-2045 Regional Transportation
Plan/Sustainable Communities Strategy and City of Tustin General Plan, respectively. As discussed in Section
5.4, the Project would be consistent with all applicable goals and policies. Thus, impacts related to conflict
with a program, plan, ordinance, or policy addressing the circulation system of the Project site and
surrounding area would not occur.
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Table 5.9-2: Proposed Project Trip Generation
5.9 T
Scenario
Land Use
ITE
Unit
ITE Daily Trip
Project
Project
ITE AM Trip
Project
ITE PM Trip
Project
Code
Rate/Unit
Size
ADTs
Rate/Unit
AM Trips
Rate/Unit
PM Trips
High -Turnover (Sit-
932
KSF
107.20
28.75
3,082
9.57
275
9.05
260
Down) Restaurant
Existing Conditions (Baseline)
Retail
821
KSF
1 94.49
39.96
3,776
3.53
141
9.03
361
Office
710
KSF
10.84
18.426
200
1.52
28
1.44
27
Existing Conditions (Baseline)
TOTAL TRIPS
7,058
444
648
Proposed Multi-
221
DU
4.54
413
1,875
0.37
153
0.39
161
Family Housing
'Future High -
Proposed Housing Units +
Remaining Buildout Capacity
Turnover (Sit -Down)
932
KSF
107.20
39.09
4,190
9.57
374
9.05
354
(Project)
Restaurant
'Future Retail
821
KSF
94.49
54.33
5,133
3.53
192
9.03
491
'Future Office
710
KSF
10.84
25.051
272
1.52
38
1.44
36
Proposed Project
11,470
757
1,041
TOTAL TRIPS
Proposed Multi-
221
DU
4.54
413
1,875
0.37
153
0.39
161
Family Housing
Existing Conditions + Proposed
High -Turnover (Sit -
Housing Units + Remaining Buildout
Down) Restaurant
932
KSF
107.20
67.84
7,272
9.57
649
9.05
614
Capacity (Total)
Retail
821
KSF
94.49
94.29
8,909
3.53
333
9.03
851
Office
710
KSF
10.84
43.48
471
1.52
66
1.44
63
Existing Conditions + Proposed
Housing Units + Remaining
Buildout Capacity (Total)
18,528
1,201
1,689
TOTAL TRIPS
Notes: ADT = Average Daily Trips
DU = Dwelling Unit
ITE = Institute of Transportation Engineers Trip Generation Manual 11 th Edition, 2021
KSF = Thousand Square Feet
Source: VMT Analysis (Appendix D)
City of Tustin 5.9-18
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Enderle Center Rezone Proiect 5.9 T
IMPACT TRA-2: THE PROJECT WOULD NOT CONFLICT OR BE INCONSISTENT WITH CEQA GUIDELINES
§ 15064.3, SUBDIVISION (B).
Less than Significant.
As described previously, State CEQA Guidelines Section 15064.3(b) focuses on determining the significance
of VMT-related transportation impacts. The City of Tustin Guidelines contain screening thresholds to assess
whether a project has the potential to result in an impact and further VMT analysis is required. If none of the
screening criteria are met, then the project may require mitigation measures and/or VMT modeling to
determine if the VMT thresholds are exceeded.
The applicability of each criterion to the Project is discussed below.
Screening Criteria 1 — Affordable Housing Screening
As per the City's guidelines, projects that consist of 100% affordable housing will have a less -than -significant
impact on VMT. The Project does not consist of 100% affordable housing and therefore would not satisfy
the requirements of Screening criteria 1 - Affordable Housing Screening.
Screening Criteria 2 — High Quality Transit Screening
As per the City's guidelines, projects located within one half mile of qualifying transit may be presumed to
have a less than significant impact. The Project is located approximately 4 miles away from qualifying
transit; therefore, the Project would not satisfy the requirements of Screening Criteria 2 — High Quality Transit
screening.
Screening Criteria 3 - Project Type Screening
As per the City's guidelines, projects which propose local serving retail (retail projects less than 50,000
square feet) or other local serving uses would have a less than significant impact on VMT. The types of
projects considered local serving include K-12 schools, local parks, day care centers, gas stations, libraries,
fire stations, and other local serving civic uses.
Screening Criteria 3 would not apply to the residential portion of the Project. In addition, the Project proposes
retail use with an area of 118,474 SF, which is more than 50,000 square feet. Therefore, it would not satisfy
the requirements of Screening Criteria 3 - Project Type Screening.
Screening Criteria 4 - Low VMT Area Screening
The City's guidelines include a screening threshold for projects located in a low VMT generating area. Low
VMT generating area is defined as traffic analysis zones (TAZs) with a total daily VMT per capita or VMT
per employee that is less than the base level for the city.
The Project is located in a Low VMT Generating Area for VMT per capita based on the City's Guideline.
Therefore, the residential portion of the Project would satisfy the requirements of Screening Criteria 4 — Low-
VMT Area Screening. The residential portion of the Project would meet Screening Criteria 4 — Low-VMT Area
Screening, and therefore the residential portion of the Project's impact on VMT would be considered less -
than -significant.
The Project is not located in a Low VMT Generating Area for VMT per employee based on the City's
Guideline. Therefore, the commercial portion of the Project would not satisfy the requirements of Screening
Criteria 4 — Low-VMT Area Screening. Because the commercial portion of the Project would not meet any of
the City's screening criteria, the commercial portion of the Project's impact on VMT would not be considered
less -than -significant.
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5.9 T
Screening Criteria 5 - Generating less than 500 daily vehicle trips
As per the City's guidelines, projects which generate less than 500 daily vehicle trips would have a less than
significant impact on VMT.
As shown in Table 5.9-3, the future development of the Enderle Center site is forecasted to generate 11,470
daily trips, which is more than 500 daily vehicle trips. Therefore, the Project would not meet Screening
Criteria 5.
Screening Conclusions
Although the Project would meet Screening Citeria 4 for residential Low VMT Area Screening, a complete
VMT analysis (EPD Solutions, 2024) was conducted at the request of the City. The VMT analysis presented
in this analysis evaluates the VMT impacts of both the residential and commercial portions within the proposed
Enderle Center Housing Overlay Zone.
As described previously, State CEQA Guidelines Section 15064.3(b) focuses on determining the significance
of VMT-related transportation impacts. As stated above, according to the City's Guidance, a project's VMT
impacts are considered significant if the project's base year home -based VMT per capita or base year
employment VMT per employee exceeds the OCTAM base model year citywide average VMT per capita
or employee for the City of Tustin. Additionally, if the project's future year home -based VMT per capita or
future year employment VMT per employee exceeds the OCTAM base model year citywide average VMT
per employee or capita for the City of Tustin.
As shown in Table 5.9-3, the Project's home based VMT per capita would be lower than the OCTAM base
model year citywide average home based VMT per capita for the City of Tustin under both base and future
year conditions. The Project's home -based VMT per capita would be 19.7 percent below the City's threshold
under base conditions and 18.7 percent below the City's threshold under future conditions; therefore, the
residential portion of the Project would result in a less -than -significant VMT impact.
Table 5.9-3: VMT Analysis of Residential of Project Impact per City Guidelines
Base Year 2016
Future Year 2045
Project TAZ 1 103 Zone Total Home -based VMT
47,899
48,954
TAZ 1 103 Total Residents
3,991
4,029
Project 1103 Home -based VMT per capita
12.0
12.2
City of Tustin Baseline Home -based VMT
1,356,977
1,356,977
City of Tustin Baseline Total Residents
90,762
90,762
City of Tustin Baseline Home -based VMT per capita
15.0
15.0
Percent Above/Below Threshold
-1 9.7 percent
-1 8.7 percent
Impact?
No
No
Source: VMT Analysis (Appendix D)
As shown in Table 5.9-4, the Project's employment VMT per employee would be lower than the OCTAM
base model year citywide average employment VMT per employee for the City of Tustin under both base
and future year conditions. The Project's employment VMT per employee would be 5.5 percent below the
City's threshold under base conditions and 3.7 percent below the City's threshold under future conditions;
therefore, the commercial portion of the Project would result in a less -than -significant VMT impact.
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Table 5.9-4: VMT Analysis of Commercial Part of Project Impact per City Guidelines
Base Year 2016
Future Year 2045
Project TAZ 1 103 Zone Total Home -based Work VMT
261,211
273,166
TAZ 1 103 Total Employees
11,012
11,303
Project 1103 Home -based Work VMT per employee
23.7
24.2
City of Tustin Baseline Home -based Work VMT
1,475,341
1,475,341
City of Tustin Baseline Total Employees
58,774
58,774
City of Tustin Baseline Home -based Work VMT per employee
25.1
25.1
Percent Above/Below Threshold
-5.5 percent
-3.7 percent
Impact?
No
No
Source: VMT Analysis (Appendix D)
Overall, pursuant to the City's VMT analysis guidelines and guidance from OPR and CEQA Guidelines Section
15064.3(b), the entire Project can be assumed to have a less -than -significant VMT impact.
IMPACT TRA-3: THE PROJECT WOULD NOT SUBSTANTIALLY INCREASE HAZARDS DUE TO A
GEOMETRIC DESIGN FEATURE (E.G., SHARP CURVES OR DANGEROUS
INTERSECTIONS) OR INCOMPATIBLE USES (E.G., FARM EQUIPMENT).
Less than Significant.
The Project would include a General Plan Amendment, Zoning Code Amendment, and rezone of the Project
site with a Housing Overlay district to allow for future development of up to 413 housing units on
approximately seven acres of developable land within the existing 1 1.8-acre site. Although the Project does
not propose a specific development, the Project would provide for future proposed development through
implementation of the housing overlay and the City's certified 2021-2029 Housing Element. Therefore, future
residential development may result in temporary construction activities for roadway and driveway
improvements.
All roadway improvements would be constructed in accordance with applicable local, State, and federal
roadway standards and practices. As part of the grading plan and building plan review processes for future
development, City permits would require appropriate measures to facilitate the passage of persons and
vehicles through/around any required road closures and measures to properly route heavy-duty construction
vehicles entering and leaving the site (as applicable) consistent with the City of Tustin Standard Plans and
Design Standards (City of Tustin Department of Public Works, 2022) (PPP T-2). As a result, impacts related
to vehicular circulation design features and incompatible uses during construction of the proposed Project
would be less than significant.
Additionally, any proposed roadway improvements, restriping, and related street, and bikeway
improvements of local streets and internal driveways would be conducted in conformance with City design
standards for roadway improvements. Compliance with existing regulations would be ensured through the
City's traffic engineering review and construction permitting process for all future developments (PPP T-2).
As part of the Project, the City will develop objective design standards (ODS) that include parking, siting,
and additional standards consistent with the City of Tustin Standard Plans and Design Standards (City of
Tustin Department of Public Works, 2022) for any future development proposed under the Project. Further,
roadways, sidewalks, and bicycle improvements associated with the future development of commercial and
residential mixed uses allowed under the proposed Project would be similar to surrounding uses and would
not result in incompatible vehicular uses that could increase hazards. All future development would be subject
to the design requirements of the GP or ODS (whichever is more stringent, as applicable) (City of Tustin,
1997). As a result, impacts related to hazardous vehicular circulation design features and incompatible uses
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Enderle Center Rezone Proiect 5.9 T
during construction and operation of future development provided by the proposed Project would be less
than significant.
IMPACT TRA-4: THE PROJECT WOULD NOT RESULT IN INADEQUATE EMERGENCY ACCESS.
Less than Significant.
Construction
As described above, the Project does not propose a specific development. However, the Project would
provide for future proposed development through implementation of the housing overlay district. Future
development allowed under the new housing overlay district is speculative, but may require construction
activities, including equipment and supply staging and storage. However, all future development would be
required to ensure emergency access in accordance with Section 503 of the California Fire Code (Title 24,
California Code of Regulations, Part 9), which would be ensured through the City's permitting process.
Additionally, all potential road closures would be subject to review and approval by the City, including
issuance of an encroachment permit. Once offsite roadway, utility, pedestrian, and other potential
improvements are completed as part of future development, all road conditions will be restored to normal.
Thus, implementation of the Project, including potential future development through the City's permitting
process, would ensure existing regulations are adhered to. Therefore, impacts related to inadequate
emergency access during construction activities would be less than significant.
Operation
Operation of potential future development would also not result in inadequate emergency access or access
to nearby uses. Future applicants would be required to design and construct internal access and provide fire
suppression facilities (e.g., hydrants and sprinklers) in conformance with City's Standard Plans and Design
Standards (PPP T-2). Additionally, the City's Fire Department (OCFA) would review the development plans
prior to approval to ensure adequate emergency access pursuant to the requirements in the International
Fire Code and Section 503 of the California Fire Code (Title 24, California Code of Regulations, Part 9). As
a result, the proposed Project including potential future development would not result in inadequate
emergency access or access to nearby uses, and no impacts would occur.
5.9.7 CUMULATIVE IMPACTS
Vehicle Miles Traveled
The cumulative traffic study area for the proposed Project includes the City of Tustin and surrounding
jurisdictions. The information utilized in this cumulative analysis is based on the potential to combine with
impacts from projects in the vicinity of the proposed Project, as discussed in Section 5.0, Environmental Impact
Analysis, and listed in Table 5-1, Cumulative Projects List, and projections contained within OCTAM.
The Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA states
that "a project that falls below an efficiency -based threshold that is aligned with long-term environmental
goals and relevant plans would have no cumulative impact distinct from the project impact." As discussed
under Impact TRA-2, the Project would have a less -than -significant VMT impact. Therefore, the proposed
Project would not result in a cumulatively considerable impact related to VMT and cumulative traffic impacts
would also be less than significant.
Design and Roadway Hazards
The evaluation of Impact TR-3 and Impact TR-4 concluded that the proposed Project would not result in
impacts related to incompatible uses, hazards due to roadway design, or emergency access. Cumulative
City of Tustin 5.9-22
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Enderle Center Rezone Proiect 5.9 T
development in the City and surrounding jurisdictions would be subject to similar site -specific reviews,
including reviews of roadway design, geometrical design features, and future infrastructure improvements,
which would ensure projects are consistent with roadway design standards and would not result in unsafe
traffic conditions. Therefore, the Project's impact to increase in hazardous conditions would be less than
significant, and the Project would not contribute to a cumulatively considerable impact associated with
hazardous design features.
Alternative Transportation
The evaluation of Impact TRA-1 concluded that the proposed Project would not result in significant impacts
related to alternative transportation or policies addressing the circulation system. Cumulative development
in the City and surrounding jurisdictions would be subject to site -specific reviews, including reviews of
sidewalk, bike lane, and bus stop designs that would not allow potential cumulatively considerable impacts
related to alternative transportation. Therefore, the Project would not cumulatively combine with other
projects to result in impacts related to alternative transportation. Thus, cumulative impacts would be less than
significant.
5.9.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• Section 503 of the California Fire Code (Title 24, California Code of Regulations, Part 9)
• SCAG 2024 - 2050 Regional Transportation Plan/Sustainable Communities Strategy
• City of Tustin General Plan Circulation Element
• City of Tustin Municipal Code
Plans, Programs, or Policies
PPP T-1: Sidewalk Standards. Sidewalks shall be provided on a private street for attached and detached
residential products in accordance with Standard B102 of the City's Construction Standards, Storm Drain
and On -Site Private Improvements, and is subject to compliance with applicable accessibility requirements
of the American Disabilities Act, Title 24 of the Uniform Building Code as locally amended, and the
Department of Housing and Urban Development's Fair Housing Accessibility Guidelines.
PPP T-2: Traffic Control/Utilities. All future development constructed under the Project shall be subject to
the traffic control standards specified by the City's latest Standard Plans and Design Standards, which includes
the requirement for Traffic Control Plan during construction, the process prior to commencing construction
within the City public right-of-way (including utility work), and specifications for operational roadway and
traffic control design.
5.9.9 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts TRA-1 through TRA-4 would be less than significant.
5.9.10 MITIGATION MEASURES
No mitigation measures are required for the proposed Project.
City of Tustin 5.9-23
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Enderle Center Rezone Proiect 5.9 T
5.9.1 1 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts TRA-1 through TRA-4 would be less than significant.
5.9.12 REFERENCES
City of Tustin. (2018, November). City of Tustin General Plan. Retrieved from
https://www.tustinca.org/DocumentCenter/View/71 3/City-of-Tustin-General-Plan-PDF
City of Tustin Department of Public Works. (2022). Standard Plans and Design Standards. Retrieved from
https://www.tustinca.org/DocumentCenter/View/339/Public-Works-Standards-2022-Edition-PDF
City of Tustin (2024, March). Vehicle Miles Traveled Analysis Guidelines.
EPD Solutions. (2024). Enderle Center Rezone Project Vehicle Miles Traveled (VMT) Analysis. (Appendix D)
State of California Office of Planning and Research. (2018, April). Technical Advisory on Evaluating
Transportation Impacts in CEQA. Retrieved from https://ol2r.ca.gov/docs/20180416-
743 Technical Advisory 4.16.18.12df
City of Tustin 5.9-24
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Enderle Center Rezone Proiect 5.10 Tribal Cultural Resources
5.10 Tribal Cultural Resources
5.10.1 INTRODUCTION
This section addresses potential impacts to tribal cultural resources (TCRs) from implementation of the
proposed Project. Information within this section is based on the following:
• City of Tustin General Plan (including 2021-2029 Housing Element), adopted November 2018 and
updated October 2022.
• Archaeological Resources Records Search Results for the Enderle Center Project, Tustin, California (APNs
401-252-05, -06, -08 through -70, 401-253-03, and -04), prepared by BFSA Environmental Services,
February 16, 2024 (Appendix E).
Additionally, part of this analysis is based upon Project -specific coordination and consultation with California
Native American tribes that are traditionally and culturally affiliated with the Project region. In accordance
with Public Resources Code Section 15120(d), certain information and communications that disclose the
location of archaeological sites and sacred lands are allowed to be exempt from public disclosure.
5.10.2 REGULATORY SETTING
5.10.2.1 Federal Regulations
Archaeological Resources Protection Act
The Archaeological Resources Protection Act (ARPA) of 1979 regulates the protection of archaeological
resources and sites on federal and Native American lands. The ARPA regulates authorized archaeological
investigations on federal lands; increased penalties for looting and vandalism of archaeological resources;
and required that the locations and natures of archaeological resources be kept confidential in most cases.
In 1988, amendments to the ARPA included a requirement for public awareness programs regarding
archaeological resources.
Native American Graves Protection and Repatriation Act (NAGPRA)
NAGPRA is a federal law passed in 1990 that mandates museums and federal agencies to return certain
Native American cultural items —such as human remains, funerary objects, sacred objects, or objects of
cultural patrimony —to lineal descendants or culturally affiliated Indian tribes.
5.10.2.2 State Regulations
California Public Resources Code
Archaeological resources are protected pursuant to a wide variety of State policies and regulations
enumerated under the California Public Resources Code (PRC). In addition, cultural resources are recognized
as nonrenewable resources and therefore receive protection under the PRC and the California Environmental
Quality Act (CEQA).
PRC Sections 5097.9 to 5097.991 provide protection to Native American historical and cultural resources
and sacred sites and identify the powers and duties of the Native American Heritage Commission (NAHC).
These sections also require notification to descendants of discoveries of Native American human remains and
provide for treatment and disposition of human remains and associated grave goods.
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5.10 Tribal Cultural Resources
California Senate Bill 18
Senate Bill 18 (SB 18) (California Government Code Section 65352.3) sets forth requirements for local
governments to consult with California Native American tribes identified by the California NAHC to aid in
the protection of TCRs. The intent of SB 18 is to provide California Native American tribes an opportunity to
participate in local land use decisions at an early stage of planning to protect, or mitigate impacts on, TCRs.
The Tribal Consultation Guidelines: Supplement to General Plan Guidelines (OPR, 2005), identifies the following
contact and notification responsibilities of local governments:
• Prior to the adoption or any amendment of a general plan or specific plan, a local government must
notify the appropriate tribes (on the contact list maintained by the NAHC of the opportunity to conduct
consultations for the purpose of preserving, or mitigating impacts to, cultural places located on land
within the local government's jurisdiction that is affected by the proposed plan adoption or amendment.
Tribes have 90 days from the date on which they receive notification to request consultation, unless a
shorter timeframe has been agreed to by the tribe (Government Code Section 65352.3).
• Prior to the adoption or substantial amendment of a general plan or specific plan, a local government
must refer the proposed action to those tribes that are on the NAHC contact list and have traditional
lands located within the city or county's jurisdiction. The referral must allow a 45-day comment period
(Government Code Section 65352). Notice must be sent regardless of whether prior consultation has
taken place. Such notice does not initiate a new consultation process.
• Local government must send a notice of a public hearing, at least 10 days prior to the hearing, to tribes
who have filed a written request for such notice (Government Code Section 65092).
Because the proposed Project includes approval of a General Plan Amendment, it is subject to the statutory
requirements of SB 18 Tribal Consultation Guidelines.
California Assembly Bill 52
Assembly Bill 52 (AB 52) established a requirement under CEQA to consider "tribal cultural values, as well
as scientific and archaeological values when determining impacts and mitigation." PRC Section 21074(a)
defines tribal cultural resources (TCRs) as "[s]ites, features, places, cultural landscapes, sacred places, and
objects with cultural value to a California Native American tribe" that are either "[i]ncluded or determined
to be eligible for inclusion in the California Register of Historical Resources" or "in a local register of historical
resources." Additionally, defined cultural landscapes, historical resources, and archaeological resources may
be considered TCRs. PRC Section 21074(b), (c). The lead agency may also in its discretion treat a resource
as a TCR if it is supported with substantial evidence.
Projects for which a Notice of Preparation for a Draft EIR was filed on or after July 1, 2015, are required
to have lead agencies offer California Native American tribes traditionally and culturally affiliated with the
project area consultation on CEQA documents prior to submitting an EIR in order to protect TCRs. PRC Section
21080.3.1(b) defines "consultation" as "the meaningful and timely process of seeking, discussing, and
considering carefully the views of others, in a manner that is cognizant of all parties' cultural values and,
where feasible, seeking agreement." Consultation must "be conducted in a way that is mutually respectful of
each party's sovereignty [and] recognize the tribes' potential needs for confidentiality with respect to places
that have traditional tribal cultural significance." The consultation process is outlined as follows:
1. California Native American tribes traditionally and culturally affiliated with the project area submit
written requests to participate in consultations.
2. Lead agencies are required to provide formal notice to the California Native American tribes that
requested to participate within 14 days of the lead agency's determination that an application package
is complete or decision to undertake a project.
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5.10 Tribal Cultural Resources
3. California Native American tribes have 30 days from receipt of notification to request consultation on a
project.
4. Lead agencies initiate consultations within 30 days of receiving a California Native American tribe's
request for consultation on a project.
5. Consultations are complete when the lead agencies and California Native tribes participating have
agreed on measures to mitigate or avoid a significant impact on a TCR, or after a reasonable effort in
good faith has been made and a party concludes that a mutual agreement cannot be reached (PRC
Sections 21082.3(a), (b)(1)-(2); 21080.3.1(b)(1)).
AB 52 requires that the CEQA document disclose significant impacts on TCRs and discuss feasible alternatives
or mitigation to avoid or lessen an impact.
California Health and Safety Code Section 7050.5
Health & Safety Code Section 7050.5 requires that if human remains are discovered within the project site,
disturbance of the site shall halt and remain halted 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. If the coroner determines the remains are not subject to his or her authority
and recognizes or has reason to believe the human remains are those of a Native American, he/she shall
contact, by telephone within 24 hours, the NAHC.
California Public Resources Code Sections 5097.9 to 5097.991
PRC Sections 5097.9 to 5097.991 provide protection to Native American historical and cultural resources
and sacred sites and identify the powers and duties of the NAHC. These sections also require notification to
descendants of discoveries of Native American human remains and provide for treatment and disposition of
human remains and associated grave goods.
5.10.2.3 Local and Regional Regulations
General Plan
Conservation/Open Space/Recreation Element
Goal 12: Maintain and enhance the City's unique culturally and historically significant building
sites or features.
Policy 12.1: Identify, designate, and protect facilities of historical significance, where feasible.
Policy 12.2: Retain and protect significant areas of archaeological, paleontological, or historical value
for education and scientific purposes.
Policy 12.3: Development adjacent to a place, structure or object found to be of historic significance
should be designed so that the uses permitted and the architectural design will protect the
visual setting of the historical site.
Goal 13: Preserve Tustin's archaeological and paleontologic resources.
Policy 13.1: Require a site inspection by certified archaeologists or paleontologists for new development
in designated sensitive areas.
Policy 13.2: Require mitigation measures where development will affect archaeological or
paleontological resources.
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5.10 Tribal Cultural Resources
5.10.3 ENVIRONMENTAL SETTING
Tribal Cultural Resources
A records search from the South Central Coastal Information Center (SCCIC) at California State University,
Fullerton was completed and encompassed the Project site and a 500-foot buffer surrounding the Project
(BFSA Environmental Services, 2024). Based on the records search results, no resources are recorded within
the Project site or within the 500-foot search buffer. Additionally, no previous studies are recorded on the
property, although there are two studies recorded within the search area. However, neither of the two studies
are directly related to the Project site.
Sacred Lands File Search
TCRs can include archaeological sites, built environment resources, locations of events or ceremonies, resource
procurement areas, and natural landscape features with special significance to one or more indigenous
groups. The City requested a Sacred Lands File (SLF) Search from the NAHC and received the results on
October 19, 2023. The SLF returned negative results, indicating that no known tribal resources are located
in the Project area.
5.10.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
TCR-1 Cause a substantial adverse change in the significance of a tribal cultural resource, defined in
Public Resources Code § 21074 as either a site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope of the landscape, sacred place, or object
with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local
register of historical resources as defined in Public Resources Code section 5020.1(k), or
ii) A resource determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources
Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code §
5024.1, the lead agency shall consider the significance of the resource to a California Native
American tribe.
5.10.5 METHODOLOGY
The City requested a SLF Search from the NAHC and received the results on October 3, 2023. The SLF
returned negative results, indicating that no known tribal resources are located in the Project area.
In compliance with SB 18 and AB 52, on August 28, 2023, and October 26, 2023, the City sent letters to
the following Native American tribes that may have knowledge regarding TCRs in the Project vicinity:
• Campo Band of Diegueno Mission Indians
• Ewiiaapaayp Band of Kumeyaay Indians
• Gabrieleno Band of Mission Indians Kizh Nation
• Gabrieleno Tongva San Gabriel Mission Indians
• Gabrielino Tongva Nation
• Gabrielino Tongva Indians of California Tribal Council
• Gabrielino Tongva Tribe
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5.10 Tribal Cultural Resources
• Juaneno Mission Indians Acjachemen Belardes
• Juaneno Band of Mission Indians Acjachemen Nation 84A
• La Posta Band of Diegueno Mission Indians
• Manzanita Band of Kumeyaay Nation
• Mesa Grande Band of Diegueno Mission Indians
• Pala Band of Mission Indians
• Santa Rosa Band of Cahuilla Indians
• Soboba Band of Luiseno Indians
The Gabrieleno Band of Mission Indians — Kizh Nation responded on November 14, 2023. Consultation with
the Gabrieleno Band of Mission Indians — Kizh Nation occurred via email and the Tribe provided requested
mitigation measures. None of the other tribes have responded to the letters at the time of this Draft EIR.
5.10.6 ENVIRONMENTAL IMPACTS
IMPACT TCR-1: THE PROJECT WOULD NOT CAUSE A SUBSTANTIAL ADVERSE CHANGE IN THE
SIGNIFICANCE OF A TRIBAL CULTURAL RESOURCE, DEFINED IN PUBLIC RESOURCES
CODE § 21074 AS EITHER A SITE, FEATURE, PLACE, CULTURAL LANDSCAPE THAT IS
GEOGRAPHICALLY DEFINED IN TERMS OF THE SIZE AND SCOPE OF THE
LANDSCAPE, SACRED PLACE, OR OBJECT WITH CULTURAL VALUE TO A
CALIFORNIA NATIVE AMERICAN TRIBE, AND THAT IS:
(1) LISTED OR ELIGIBLE FOR LISTING IN THE CALIFORNIA REGISTER OF HISTORICAL
RESOURCES, OR IN A LOCAL REGISTER OF HISTORICAL RESOURCES AS DEFINED IN
PUBLIC RESOURCES CODE SECTION 5020.1(K), OR
(11) A RESOURCE DETERMINED BY THE LEAD AGENCY, IN ITS DISCRETION AND
SUPPORTED BY SUBSTANTIAL EVIDENCE, TO BE SIGNIFICANT PURSUANT TO
CRITERIA SET FORTH IN SUBDIVISION (C) OF PUBLIC RESOURCES CODE § 5024.1. IN
APPLYING THE CRITERIA SET FORTH IN SUBDIVISION (C) OF PUBLIC RESOURCE
CODE § 5024.1, THE LEAD AGENCY SHALL CONSIDER THE SIGNIFICANCE OF THE
RESOURCE TO A CALIFORNIA NATIVE AMERICAN TRIBE.
Less than Significant with Mitigation Incorporated.
Potential future construction from implementation of the proposed Project could include demolition, site
preparation, grading, building construction, architectural coating, and paving activities. Project buildout
would include the development of up to 413 residential units on the paved parking lot and landscape space
of the existing site and the buildout of an additional 118,474 SF of nonresidential development. Project
construction would include excavation at depths that could reach native, undisturbed soils that may contain
unknown tribal cultural resources. Project excavation and construction could result in impacts to inadvertent
tribal cultural resource finds that could cause substantial adverse change to the significance of such resources.
AB 52 requires meaningful consultation between lead agencies and California Native American tribes
regarding potential impacts on TCRs. Based on literature review (i.e., records check and archival research),
no prehistoric resource sites or isolates —including a historic TCR—as defined by PRC Section 5020.1(k) have
been identified within the Project site.
As described above, a SLF search and a list of Native American tribes who may have knowledge of cultural
resources in the Project area was requested from the Native American Heritage Commission. On October 3,
2023, the NAHC responded with a list of Native American tribes and that the SLF search yielded negative
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results for known TCRs or sacred lands within the Project area. To identify if any TCRs are potentially located
within the Project site, the City sent notices to the Native American tribes provided by the NAHC on August
28, 2023, and October 26, 2023, regarding the Project.
One response was received from the Gabrieleno Band of Mission Indians — Kizh Nation on November 14,
2023. The tribe requested to consult over email and provided mitigation measures to be incorporated into
the Project. As a result, Mitigation Measure TCR-1 is included, which requires prior to the commencement of
ground -disturbing activities, retainment of a Native American monitor with preference given to the consulting
tribe. In addition, Mitigation Measure TCR-2 is incorporated and provides procedures to follow in case of
an inadvertent TCR discovery. Mitigation Measure TCR-3 is also incorporated which complies with State
Health and Safety Code Section 7050.5, which states that no further disturbance may occur in the vicinity of
the body until the County Coroner has made a determination of origin and disposition pursuant to Public
Resources Code Section 5097.98. These measures would ensure the avoidance of impacts to buried TCRs
that may be present onsite.
No construction is proposed as part of this Project. However, future development associated with the Housing
Zone would be required to adhere to Mitigation Measures TCR-1, TCR-2, and TCR-3. Implementation of
Mitigation Measures TCR-1, TCR-2, and TCR-3 would ensure that potential impacts a result of the inadvertent
discovery of TCRs during future development would be less than significant.
5.10.7 CUMULATIVE IMPACTS
The cumulative study area for TCRs includes City of Tustin, which contains the same general tribal historic
setting. Other projects throughout the City that would involve ground disturbances could reveal buried TCRs.
Cumulative impacts to TCRs would be reduced by compliance with applicable regulations and consultations
required by SB 18 and AB 52. As described above, the Project site and vicinity is not known to contain TCRs;
however, Mitigation Measures TCR-1, TCR-2 and TCR-3 would be implemented to ensure that impacts would
not occur in the case of an inadvertent discovery of a potential TCR. These mitigation measures would ensure
that the proposed Project would not contribute to a cumulative loss of TCRs. Therefore, cumulative impacts
would be less than significant.
5.10.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• California Government Code Sections 5097.9-5097.99
• California Health and Safety Code Section 7050.5
• California Public Resources Code Sections 21073 et seq. (AB 52)
Plans, Programs, or Policies
The following Plans, Programs, or Policies (PPP) related to TCRs are incorporated into the Project and would
reduce impacts related to TCRs. These actions will be included in the Project's Mitigation Monitoring and
Reporting Program (MMRP):
PPP TCR-1: Native American historical and cultural resources and sacred sites are protected under PRC
Sections 5097.9 to 5097.991, which require that descendants be notified when Native American human
remains are discovered and provide for treatment and disposition of human remains and associated grave
goods.
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5.10 Tribal Cultural Resources
PPP CUL-1: Human Remains. Should human remains or funerary objects be discovered during Project
construction, the Project would be required to comply with State Health and Safety Code Section 7050.5,
which states that no further disturbance may occur in the vicinity of the body (within a 100-foot buffer of the
find) until the County Coroner has made a determination of origin and disposition pursuant to Public Resources
Code Section 5097.98. The County Coroner must be notified of the find immediately. If the remains are
determined to be prehistoric, the Coroner will notify the Native American Heritage Commission, which will
determine the identity of and notify a Most Likely Descendant (MLD). With the permission of the landowner
or his/her authorized representative, the MLD may inspect the site of the discovery. The MLD must complete
the inspection within 48 hours of notification by the NAHC.
5.10.9 PROJECT DESIGN FEATURES
None.
5.10.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Without mitigation, Impact TCR-1 would be potentially significant.
5.10.1 1 MITIGATION MEASURES
TCR-1: Retain a Native American Monitor Prior to Commencement of Ground -Disturbing Activities
a. Prior to the issuance of demolition or grading permits for any projects that would disturb previously
undisturbed soils (native soils) or soils that have native fill, the project applicant/developer shall retain
a Native American Monitor, with first preference given to the Gabrieleno Band of Mission Indians — Kizh
Nation, who responded to the City's request for consultation on November 14, 2023 (first preference
Tribe, Tribe). The applicant/developer shall allow 45 days from the initial contact with the first
preference tribe to enter into a contract for monitoring services. If the applicant/developer is unable to
contact the Kizh Nation after three documented attempts or is unable to secure an agreement, the
applicant shall report to the lead agency, and the lead agency will contact the Kizh Nation to validate
that the parties were unable to enter into an agreement. The applicant/developer shall have made
three documented attempts to directly contact the Kizh Nation to enter into a tribal monitoring
agreement. If the applicant/developer can demonstrate they were unable to secure an agreement with
the first preference tribe, as validated and documented by the Community Development Department in
writing, or if the contracted tribe fails to fulfill its obligation under the contract terms, then the
applicant/developer may retain an alternative qualified tribal monitor from a culturally affiliated tribe
if approved by the City.
The monitor shall be retained prior to the issuance of a demolition permit or grading permit, and the
commencement of any development related "ground -disturbing activity" for the subject project at all
project locations (i.e., both on -site and any off -site locations that are included in the project
description/definition and/or required in connection with the project, such as public improvement work).
"Ground -disturbing activity" shall include, but is not limited to, demolition, pavement removal, auguring,
grubbing, boring, grading, excavation, drilling, and trenching for the purposes of reconstruction and new
development. "Ground -disturbing activity" shall not include minor maintenance activities such as
potholing, tree removal, and parking lot maintenance. This mitigation measure does not apply to projects
that would only disturb soils made up of artificial fill, as verified by a soils or geotechnical report.
b. A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the
commencement of any ground -disturbing activity, or the issuance of any permit necessary to commence
a ground -disturbing activity.
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5.10 Tribal Cultural Resources
c. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground -
disturbing activities, the type of construction activities performed, locations of ground -disturbing
activities, soil types, cultural -related materials, and any other facts, conditions, materials, or discoveries
of significance to the Kizh Nation. Monitor logs will identify and describe any discovered TCRs, including
but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc.,
(collectively, tribal cultural resources, or "TCR"), as well as any discovered Native American (ancestral)
human remains and burial goods. Copies of monitor logs will be provided to the project applicant/lead
agency upon written request to the consulting tribe. If a monitor is selected from a tribe other than the
Kizh Nation, the Kizh Nation shall be contacted if any discoveries are found.
d. On -site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the
consulting tribe from a designated point of contact for the project applicant/lead agency that all
ground -disturbing activities and phases that may involve ground -disturbing activities and that have the
potential to impact local TCRs on the project site or in connection with the project are complete.
TCR-2: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/Non-Ceremonial)
A. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease
(i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully
assessed by the tribal monitor and consulting archaeologist. If the consulting tribe is other than the Gabrieleno
Band of Mission Indians — Kizh Nation, the Kizh Nation shall be contacted and the consulting tribe will recover
and retain all discovered TCRs in the form and/or manner the Kizh Nation deems appropriate, in the Kizh
Nation sole discretion, and for any purpose the Kizh Nation deems appropriate, including for educational,
cultural and/or historic purposes.
TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects
a. Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and
in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods
in Public Resources Code Section 5097.98, are also to be treated according to this statute.
b. If Native American human remains and/or grave goods are discovered or recognized on the project
site, then Public Resource Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be
followed.
c. Human remains and grave/burial goods shall be treated alike per California Public Resources Code
section 5097.98(d)(1) and (2).
d. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human
remains and/or burial goods.
e. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
5.10.1 2 LEVEL OF SIGNIFICANCE AFTER MITIGATION
The Mitigation Measures identified above, along with existing regulatory programs, would reduce potential
impacts associated with TCRs for Impact TCR-1 to a level that is less than significant. Therefore, no significant
unavoidable adverse impacts related to TCRs would occur.
5.10.13 REFERENCES
BFSA Environmental Services. (2024). Archaeological Resources Records Search Results for the Enderle Center
Project, Tustin, California (APNs 40 7-252-05, -06, -08, through - 7 0, 401-253-03, and -04).
City of Tustin. (2018). City of Tustin General Plan.
OPR (Governor's Office of Planning and Research). (2005). State of California Tribal Consultation Guidlines.
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5.11 Utilities and Service Systems
5.1 1.1 INTRODUCTION
This section of the EIR evaluates the potential effects on utilities and service systems from implementation of
the proposed Project by identifying anticipated demand and existing and planned utility availability. This
includes water supply and infrastructure, wastewater, drainage, solid waste, and dry utilities. Electric power,
natural gas, telecommunications, and renewable energy resources are also described in Section 5.2, Energy.
Water supply and infrastructure capacity information in this section is based on the following:
• City of Tustin General Plan (including 2021-2029 Housing Element), adopted November 2018 and
updated October 2022.
• Tustin City Code
• City of Tustin 2020 Urban Water Management Plan
• Data provided by each service provider
Because CEQA focuses on physical environmental effects, this section analyzes whether increases in demand
for water, wastewater, stormwater drainage, and solid waste utilities that would result from the proposed
Project would result in significant adverse physical environmental effects. For example, physical changes in
the environment resulting from the construction of new facilities or an expansion of existing wastewater
facilities could constitute a significant impact under CEQA.
5.1 1.2 WATER
5.11.2.1 WATER REGULATORY SETTING
Safe Drinking Water Act
The United States Environmental Protection Agency (U.S. EPA) administers the Safe Drinking Water Act, which
is the primary federal law that regulates the quality of drinking water and establishes standards to protect
public health and safety. The State Water Resources Control Board, Division of Drinking Water (DDW)
implements the requirements of the Act and oversees public water system quality statewide. USEPA
establishes legal drinking water standards for contaminants that could threaten public health.
California Urban Water Management Planning Act
Section 10610 of the California Water Code established the California Urban Water Management Planning
Act (CUWMPA). CUWMPA requires urban water suppliers to initiate planning strategies to ensure an
appropriate level of reliability in its water service. CUWMPA states that every urban water supplier that
provides water to 3,000 or more customers, or that annually provides more than 3,000 acre-feet of water
service, should make every effort to ensure the appropriate level of reliability in its water service to meet
the needs of its various categories of customers during normal, dry, and multiple -dry years. The CUWMPA
describes the contents of Urban Water Management Plan's (UWMP) as well as methods for urban water
suppliers to adopt and implement the plans. As described below, the City of Tustin has an updated 2020
UWMP that addresses water supply and demand through 2045.
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5.11 Utilities and Service
CALGreen Building Code
California Code of Regulations Title 24, Part 11, establishes the California Green Building Code or
CALGreen. The CALGreen Code is updated every three years and sets forth water efficiency standards (i.e.,
maximum flow rates) for all new plumbing and irrigation fittings and fixtures. Article 8, Chapter 1, Section
8100 of the Tustin Code of Ordinances adopts the California Green Building Standards Code by reference.
Sustainable Groundwater Management Act of 2014
The 2014 Sustainable Groundwater Management Act (SGMA) requires governments and water agencies of
high and medium priority basins to halt overdraft and bring groundwater basins into balanced levels of
pumping and recharge. Under SGMA, these basins should reach sustainability within 20 years of
implementing their sustainability plans. The Department of Water Resources (DWR) categorizes the priority
of groundwater basins. For critically over -drafted basins, sustainability should be reached by 2040. For the
remaining high and medium priority basins, 2042 is the deadline. The SGMA also requires local public
agencies and Groundwater Sustainability Agency's in high- and medium -priority basins to develop and
implement Groundwater Sustainability Plans (GSP) or Alternatives to GSPs. GSPs are detailed road maps
for how groundwater basins will reach long term sustainability. If a basin is adjudicated, then a GSA does
not need to be formed, nor does a GSP need to be prepared.
The Project overlies the Orange County Groundwater Basin (OC Basin). Pursuant to the SGMA, the DWR has
designated the OC Basin, (also known as Basin 8-1), as a medium priority basin for purposes of groundwater
management. The SGMA specifically calls for Orange County Water District (OCWD), which regulates the
OC Basin, to serve as the GSA. The SGMA allows Special Act Districts created by statute, such as OCWD,
to prepare and submit an alternative to a GSP that is "functionally equivalent" to a GSP. Basin 8-1 includes
the OCWD service area and several fringe areas outside of OCWD that are within the Basin 8-1 boundary.
Per the requirements of SGMA, an Alternative Plan must encompass the entire groundwater basin as defined
by DWR. On January 1, 2017, OCWD and the overlying agencies within Basin 8-1 jointly prepared and
submitted an alternative plan in compliance with SGMA (Basin 8-1 Alternative). The Basin 8-1 Alternative
was updated in January 2022.
City of Tustin General Plan
The Tustin General Plan Conservation/Open Space/Recreation Element includes the following goals and
policies that are related to water supply and the proposed Project.
Goal 5: Protect water quality and conserve water supply.
Policy 5.2: Protect groundwater resources from depletion and sources of pollution.
Policy 5.3: Conserve imported water by requiring water conservation techniques, water conserving
appliances, and drought -resistant landscaping.
Policy 5.4: Support the expansion of reclaimed water production and use wherever possible and
economically feasible.
Policy 5.5: Protect water quality by responsible agency support of enforcement of water quality
standards for water imported into the County, and to preserve the quality of water in the
groundwater basin and streams.
Policy 5.6: Coordinate water quality and supply programs with all responsible water agencies, and
cooperate and participate in plan preparation and programs.
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Tustin City Code
Article 9, Chapter 7 — Water Efficient Landscapes. The City promotes water use efficiency through water
efficient landscape requirements which were adopted by Ordinance in December 2015. The Code applies
to new landscape projects 500 square feet or greater and rehabilitated landscape projects 2,500 square
feet or greater. The code section provides implementation procedures and water use standards for the
purpose of providing water efficient landscapes in compliance with State law.
Article 4, Chapter 10 — Water Management Plan. The City created a comprehensive Water Conservation
Program pursuant to the California Water Code based upon the need to conserve water supplies and to
avoid or minimize the effects of any future shortages. The Water Conservation Program establishes
permanent water use restrictions and regulations to be implemented during times of declared water
shortages. It establishes six (6) levels of drought response actions to be implemented in times of shortage,
with increasing restrictions on water use in response to worsening drought conditions and decreasing
available supplies.
5.11.2.2 WATER ENVIRONMENTAL SETTING
Water is supplied to the Project site by the City of Tustin. The City is a retail water supplier that provides
water to its residents and other customers using the imported potable water from Municipal Water District
of Orange County (MWDOC), obtained through East Orange County Water District (EOCWD), and local
groundwater from the Orange County Groundwater Basin (OC Basin), which is managed by the Orange
County Water District (OCWD) (Arcadis U.S., Inc. , 2020).
Water Supply and Demand
The City's water supply consists of a combination of imported water and local groundwater. The City's main
source of water supply is groundwater from the OC Basin. In 2020, the City's actual water supply totaled
10,447 acre-feet (AF), which included 7,034 AF of untreated groundwater and 3,038 AF desalinated
groundwater from OC Basin, and 375 AF of imported water from MWDOC/EOCWD.
The City's 2020 UWMP forecasts that by 2045 the City's water supply mix will shift to 85 percent
groundwater and 15 percent imported water. Table 5.1 1-1 provides the City's total projected water supply
capacities expected to be available through 2045.
Table 5.11-1: Tustin Projected Water Supply
Source
Projected Water Supply (acre-feet)
2025
2030
2035
2040
2045
Groundwater
Orange County
desalinated)
Groundwater
8,569
8,604
8,521
8,440
8,413
Basin
Purchased or Imported
MWDOC /
1512
1,518
1,504
1,489
1,489
Water
EOCWD
Total Projected Water Supplies
10,081
10,122
10,025
9,929
i 9,898
Source: (Arcadis U.S., Inc. , 2020)
The City's water demand in 2021 was 10,374 AF, and is projected to decrease to 10,081 AF by 2025
(Arcadis U.S., Inc. , 2020). The 2020 UWMP also describes that water demands per capita have been
decreasing in recent years due to new state and local regulations related to water conservation. The 2020
UWMP describes that Tustin Water Department customers used 95 gallons per capita per day (GPCD) in
2020, which is below the target of 151 GPCD for 2020 (Arcadis U.S., Inc. , 2020). As shown in Table 5.1 1-
2, the 2020 UWMP indicates that the City has supply capabilities that would be sufficient to meet demands
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from 2025 to 2045 under the normal, single dry -year, and multiple dry years. Thus, the City would continue
to be able to utilize imported water supply as needed.
Table 5.11-2: Water Supply and Demand During Normal, Dry, and Multiple Dry Year Scenarios (AF)
Forecast Year 2025 2030 2035 2040 2045
Normal Year
Supply Totals (AF)
10,081
10,122
10,025
9,929
9,898
Demand Totals (AF)
10,081
10,122
10,025
9,929
9,898
Difference (AF)
0
0
0
0
0
Single -Dry Year
Supply Totals (AF)
10,686
10,729
10,627
10,525
10,491
Demand Totals (AF)
10,686
10,729
10,627
10,525
10,491
Difference (AF)
0
0
0
0
0
Multiple -Dry Years (First Year)
Supply Totals (AF)
10,996
10,695
10,709
10,606
10,518
Demand Totals (AF)
10,996
10,695
10,709
10,606
10,518
Difference (AF)
0
0
0
0
0
Multiple -Dry Years (Second Year)
Supply Totals (AF)
10,919
10,703
10,688
10,586
10,511
Demand Totals (AF)
10,919
10,703
10,688
10,586
10,511
Difference (AF)
0
0
0
0
0
Multiple -Dry Years (Third Year)
Supply Totals (AF)
10,841
10,712
10,668
10,565
10,505
Demand Totals (AF)
10,841
10,712
10,668
10,565
10,505
Difference (AF)
0
0
0
0
0
Multiple -Dry Years (Fourth Year)
Supply Totals (AF)
10,763
10,721
10,647
10,545
10,498
Demand Totals (AF)
10,763
10,721
10,647
10,545
10,498
Difference (AF)
0
0
0
0
0
Multiple -Dry Years (Fifth Year)
Supply Totals (AF)
10,686
10,729
10,627
10,525
10,491
Demand Totals (AF)
10,686
10,729
10,627
10,525
10,491
Difference (AF)
0
0
0
0
0
Source: (Arcadis U.S., Inc. , 2020)
Groundwater: In Fiscal Year (FY) 2019-20, the City relied on approximately 10,072 AFY (approximately
96 percent of the City's water supply portfolio for FY 2019-20) from the OC Basin to meet its demands. The
OC Basin covers an area of approximately 350 square miles, bordered by the Puente Hills and Chino Hills
to the north, the Santa Ana Mountains to the northeast, and the Pacific Ocean to the southwest. The basin
boundary extends to the Orange -Los Angeles county line to the northwest. Replenishment supplies for the
OC Basin include capture of increasing Santa Ana River flows, purified recycled water, purchases of
replenishment water from Metropolitan, and expansion of local supplies.
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The OC Basin is not adjudicated and as such, pumping from the OC Basin is managed through a process that
uses financial incentives to encourage groundwater producers to pump a sustainable amount of water.
OCWD manages the OC Basin through a Basin Production Percentage (BPP) that is determined each water
year based on groundwater conditions, availability of imported water supplies, water year precipitation,
Santa Ana River runoff, and basin management objectives. While there is no legal limit as to how much an
agency pumps from the OC Basin, there is a financial disincentive to pump above the BPP. Groundwater
production above the BPP is charged a Basin Equity Assessment (BEA) fee. The BEA is set so that the cost of
groundwater pumping above the BPP is greater than the cost of imported water. Each year, OCWD sets a
target amount of pumping, the BPP, and assesses a BEA on all water pumped above that limit. For example,
if the BPP is set at 77 percent for 2023-2024, all pumpers within the Basin, including the City, can supply
77 percent of their water needs from groundwater supplies at a cost significantly less than the cost of
imported water. If groundwater production is equal to or less than the BPP (i.e., less than 77 percent in the
example above), all producers within the Basin pay a replenishment assessment fee which is used to fund
groundwater replenishment and recharge programs aimed at ensuring the long-term viability and stability
of the Basin. A component of OCWD's BPP policy is to manage the groundwater basin so that the BPP will
not fluctuate more that 5 percent from year to year.
Imported Water: Approximately 4 percent of the City's potable water needs are met by imported water
purchased from EOCWD (who purchases from the Metropolitan Water District of Southern California [MET]
through MWDOC). MET's principal sources of water are the Colorado River via the Colorado River Aqueduct
(CRA) and the Lake Oroville watershed in Northern California through the State Water Project (SWP).
Surface Water: Currently, there are no direct surface water uses in the City's service area. As of 2021, there
are no planned direct uses of surface water in the City's service area (Arcadis U.S., Inc. , 2020).
Recycled Water: There are currently no direct recycled water uses within the City's service area.
Water Exchanges and Transfers: The City maintains interconnections with other agencies result in the ability
to share water supplies during short term emergency situations or planned shutdowns of major imported
water systems. Currently, the City maintains four emergency interconnections with Golden State Water
Company, the City of Santa Ana, and Irvine Ranch Water District. All four connections are six inches in
diameter, need to be manually activated, and supply flow in both directions.
Water Infrastructure
The City operates 13 wells, six reservoirs with a combined storage capacity of approximately 1 3.83 million
gallons (MG) and manages a 172-mile water mains system with 14,341 service connections (Arcadis U.S.,
Inc. , 2020). Existing water lines adjacent to the Project site are shown in Figure 5.1 1-1, Utilities.
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Project Site Q Water Q Sewer n
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5.11.2.3 WATER THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:
UT-1 Require or result in the construction of new water facilities, or expansion of existing facilities,
the construction of which could cause significant environmental effects.
UT-2 Have sufficient water supplies available to serve the project and reasonably foreseeable
development during normal, dry, and multiple dry years.
HYD-1 Substantially decrease groundwater supplies or interfere substantially with groundwater
recharge such that the project may impede sustainable groundwater management of the
basin.
HYD-2 Conflict with or obstruct implementation of a water quality control plan or sustainable
groundwater management plan.
5.11.2.4 WATER SERVICE METHODOLOGY
The evaluation of water supply considers the amount of water that would be required to support operation
of the proposed Project and compares the demand to the City's available water supply to identify if
sufficient water supplies are available to serve the proposed Project and reasonably foreseeable
development during normal, dry, and multiple dry years. Additionally, the water supply infrastructure in the
Project area was identified and evaluated to ensure design capacity would be adequate to supply the
Project site, or if expansions would be required to serve the proposed development.
5.11.2.5 WATER ENVIRONMENTAL IMPACTS
IMPACT UT-1: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR
CONSTRUCTION OF NEW WATER FACILITIES, OR EXPANSION OF EXISTING FACILITIES,
THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT ENVIRONMENTAL
EFFECTS.
Less than Significant Impact with Mitigation. The Project site is currently developed as a commercial site
and is surrounded by other commercial developments. The Project would include a General Plan Amendment
(GPA), Zone Code Amendment (CA) and rezone of the Project site with a Housing Overlay (HO) district to
allow for future development of the Project site with up to 413 housing units over approximately seven acres
of developable land within the existing 1 1.8-acre site, consistent with the City's certified 2021-2029 Housing
Element. Additionally, the Project anticipates the future nonresidential capacity buildout of 118,474 SF within
the remaining nonresidential -designated area of the Project site. A specific development project is not
proposed as part of this Project.
The water facilities currently serving the Project site would likely be sufficient to accommodate the anticipated
118,474 SF of additional nonresidential development proposed by the Project, as the additional
nonresidential square footage is the remaining development potential for the Project site authorized by the
City's General Plan Land Use Element. However, future residential projects proposed under the Project could
necessitate further water infrastructure, including new water connections, water pumps, and other
improvements to water utilities within the existing Project site footprint and within adjacent utility right-of-
way beneath 17'" Street, Yorba Street, Enderle Center Drive and Vandenberg Lane. Local improvements
are anticipated, and extensive offsite utility improvements are not assumed for the Project.
Future implementation of development projects pursuant to the proposed Project would include installation
of onsite water infrastructure and new connections to the water distribution system that would be sized to
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accommodate the increased water demand of new project -specific development on a project -by -project
basis. Water supply design specifications for each future site -specific development project would be
required to comply with the City of Tustin standards (per the California Building Code) regarding
requirements for design and operation of water distribution facilities and would be verified during plan
check (PPP UT-1). Additionally, Mitigation Measure UT-1 is incorporated into the Project to require future
projects to coordinate with the City and prepare a capacity analysis of existing water utilities in the area to
ensure conveyance and pressure is adequate. The capacity analysis is required to be reviewed and
approved by the City prior to the approval of construction permits.
Under the City's normal development review procedure for individual projects, the City determines the actual
water system design requirements of each site -specific development project, and the needs for any
improvements to the existing water supply infrastructure would be identified and required by the City
construction permit. The temporary construction of needed water system improvements would occur along
existing pipeline alignments and within existing street rights -of -way, and would be required to comply with
all City standards regarding construction noise, air quality and dust suppression mitigation requirements,
erosion control (through the required SWPPP) and temporary construction traffic controls. Implementation of
PPP HYD-1 would ensure that potential construction impacts related to any needed water line improvements
remain less than significant. Further, PPP T-2 is incorporated into the Project to require all utility work
occurring as part of future proposed projects to adhere to the traffic control standards specified by the
City's latest Standard Plans and Design Standards, which includes the requirement for a Traffic Control Plan
during construction, the process prior to commencing construction within the City public right-of-way (including
utility work), and specifications for operational roadway and traffic control design. As a result, potential
impacts related to build out of the proposed Project would not result in construction of new or expanded
water facilities that would result in a significant environmental effect. Therefore, impacts would be less than
significant.
IMPACT UT-2: TUSTIN WATER DEPARTMENT WOULD HAVE SUFFICIENT WATER SUPPLIES AVAILABLE
TO SERVE THE PROJECT AND REASONABLY FORESEEABLE DEVELOPMENT DURING
NORMAL, DRY, AND MULTIPLE DRY YEARS.
IMPACT HYD-1: THE PROJECT WOULD NOT SUBSTANTIALLY DECREASE GROUNDWATER SUPPLIES OR
INTERFERE SUBSTANTIALLY WITH GROUNDWATER RECHARGE SUCH THAT THE
PROJECT MAY IMPEDE SUSTAINABLE GROUNDWATER MANAGEMENT OF THE BASIN.
IMPACT HYD-2: THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT IMPLEMENTATION OF A
WATER QUALITY CONTROL PLAN OR SUSTAINABLE GROUNDWATER MANAGEMENT
PLAN.
Less than Significant Impact. The proposed Project would allow up to 413 residential units and 118,474
SF of non-residential uses, which would result in increased generation of water demand. As described in
Section 5.06, Population and Housing, the 413 additional residential units would generate 1,189 residents
at build out and full occupancy; and the 118,474 SF of non-residential uses is estimated to generate 365
employees.
Water Supply and Demand
Based on the City's water use per day in 2020 of 95 gallons per capita, the estimated 1,189 residents and
365 employees would generate an additional water demand of 147,630 gallons per day or 165.5 acre-
feet per year (AFY). Based on the City's UWMP supply and demand data and the limited increase in water
demand from the proposed Project, the City would have water supplies available to serve the Project.
Additionally, as shown in Table 5.1 1-2, the City would have sufficient water supplies to serve the Project
and cumulative development during normal, dry, and multiple dry year scenarios through 2045. Therefore,
implementation of the proposed Project would result in a less than significant impact related to water
supplies.
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Groundwater
The Project site is fully developed and is nearly 100 percent impervious aside from some landscaped areas.
Therefore, implementation of the proposed Project would not change the amount of impervious surface or
interfere with the rate of groundwater recharge at the Project site compared to existing conditions. Further,
the Project site is not in or near a groundwater recharge area/facility, nor does it represent a source of
groundwater recharge. Therefore, the Project would not substantially interfere with groundwater supplies or
recharge. Impacts would be less than significant.
OCWD serves as the groundwater manager over the OC Basin and sub -basins. OCWD adopted its first
Groundwater Management Plan in 1989. In July 2015, OCWD updated the Groundwater Management
Plan; however, this plan has been superseded by the Basin 8-1 Alternative Plan which was adopted in 2022.
As described previously, the Project would not decrease groundwater supplies or interfere substantially with
groundwater recharge. Therefore, the Project would not conflict or obstruct the implementation of the Basin
8-1 Alternative Plan. Additionally, groundwater supply and demand is evaluated through the City's 2020
UWMP which determined groundwater supplies are sufficient to serve the City's service area through 2045.
Therefore, the proposed Project would not conflict with or obstruct implementation of a water quality control
plan or sustainable groundwater management plan. Impacts would be less than significant.
5.11.2.6 WATER CUMULATIVE IMPACTS
The geographic scope of cumulative analysis for water service is the service area of the City. Cumulative
water supply impacts are associated with the adequacy of the City's primary sources of water, which include
groundwater pumped from the OC Basin and supplemental imported water supplied by EOCWD through
the MWDOC. As described above, water supplies have been planned through the City's 2020 UWMP, which
identifies the ability to meet a majority of future water demands through groundwater and imported
supplies. The City's UWMP provides projections for water supply and demand through 2045, and shows
that in normal, dry, and multiple dry year conditions with anticipated growth in the City's service area, the
City of Tustin Water Department would be able to meet water demand. As a result, cumulative impacts
would be less than significant.
5.11.2.7 EXISTING STANDARD CONDITIONS AND PLANS, PROGRAMS, OR
POLICIES
Existing Regulations
The following standard regulations would reduce potential impacts related to water:
• California Code of Regulations Title 24, Part 1 1; the California Green Building Code
• Tustin City Code Article 9, Chapter 7; Water Efficient Landscapes
• Tustin City Code Article 4, Chapter 10; Water Management Plan
Plans, Programs, or Policies
PPP UT-1: California Building Code. All future development constructed under the Project shall be subject
to the latest version of the California Building Code (CBC) which outlines regulations for building planning
and construction in the state, including occupancy classification, structural design, building materials,
infrastructure needs and fire -resistance requirements.
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide the
City Building Division evidence of compliance with the NPDES (National Pollutant Discharge Elimination
System) requirement to obtain a construction permit from the State Water Resource Control Board (SWRCB).
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The permit requirement applies to grading and construction sites of one acre or larger. The Project
applicant/proponent shall comply by submitting a Notice of Intent (NOI) and by developing and
implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting
plan for the construction site.
PPP T-2: Traffic Control/Utilities. All future development constructed under the Project shall be subject to
the traffic control standards specified by the City's latest Standard Plans and Design Standards, which includes
the requirement for Traffic Control Plan during construction, the process prior to commencing construction
within the City public right-of-way (including utility work), and specifications for operational roadway and
traffic control design.
5.11.2.8 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
With implementation of Mitigation Measure UT-1 and existing regulatory requirements that would be
ensured through the City's development permitting process, Impact UT-1 would be less than significant. With
implementation of existing regulatory requirements that would be ensured through the City's development
permitting process, Impacts UT-2, HYD-1 and HYD-2 would be less than significant.
5.11.2.9 WATER MITIGATION MEASURES
MM UT-1 Future proposed Projects shall prepare capacity analyses of existing water utilities in the
area to ensure conveyance and pressure is adequate for future projects proposed. The
developer shall then identify infrastructure improvements necessary for the proposed
development. The developer will be responsible for preparing a capacity analysis in
coordination with the City. The capacity analysis and infrastructure improvements shall be
reviewed and approved by the City prior to approval of the construction permit.
5.11.2.10 WATER LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to water supplies or water infrastructure would occur.
5.1 1.3 WASTEWATER
5.11.3.1 WASTEWATER REGULATORY SETTING
National Pollution Discharge Elimination System Permit
The NPDES permit system was established in the Federal Clean Water Act to regulate both point source
discharges (a municipal or industrial discharge at a specific location or pipe) and nonpoint source discharges
(diffuse runoff of water from adjacent land uses) to surface waters of the U.S. For point source discharges,
such as sewer outfalls, each NPDES permit contains limits on allowable concentrations and mass emissions of
pollutants contained in the discharge.
State Water Resources Control Board Statewide General Waste Discharge Requirements for Sewer
Systems
The Statewide General Waste Discharge Requirements for Sanitary Sewer Systems (SWRCB Order No
2006-0003-DWO) applies to sanitary sewer systems that are greater than one mile long and collect or
convey untreated or partially treated wastewater to a publicly owned treatment facility. The goal of Order
No. 2006-0003 is to provide a consistent statewide approach for reducing Sanitary Sewer Overflows
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Enderle Center Rezone Proiect 5.11 Utilities and Service
(SSOs), which are accidental releases of untreated or partially treated wastewater from sanitary sewer
systems, by requiring that:
1. In the event of an SSO, all feasible steps be taken to control the released volume and prevent
untreated wastewater from entering storm drains, creeks, etc.
2. If an SSO occurs, it must be reported to the SWRCB using an online reporting system developed by
the SWRCB.
3. All publicly owned collection system agencies with more than one mile of sewer pipe in the state
must develop a Sewer System Management Plan (SSMP), which must be updated every five years.
EOCWD has updated its SSMP in compliance with these requirements in 2019.
City of Tustin General Plan
The Tustin General Plan does not contain goals and policies related to wastewater.
5.11.3.2 WASTEWATER ENVIRONMENTAL SETTING
Wastewater services are provided to the Project site by EOCWD. In 2020, EOCWD collected
approximately 360 AF of wastewater (Arcadis U.S., Inc., 2020).
EOCWD's sewer system service area encompasses about 7,780 acres and includes portions of the Cities of
Orange and Tustin and unincorporated communities of North Tustin, Lemon Heights, Cowan Heights, and
Panorama Heights in the County of Orange.
EOCWD's wastewater system includes 171 miles of sewer lines and 3,700 manholes, serving about 18,000
customers. The gravity collection system conveys wastewater to points of connection with the wastewater
systems owned by the City of Orange, Irvine Ranch Water District (IRWD), and OC San.
EOCWD coordinates with Orange County Sanitation District (OC San) and OCWD for wastewater and
recycled water services. EOCWD does not own or operate its own wastewater treatment facilities and sends
all collected wastewater to OC San for treatment and disposal. Wastewater collected within EOCWD's
service area is conveyed to OC San's wastewater treatment plants in Fountain Valley (Plant No. 1) and
Huntington Beach (Plant No. 2). Plant No. 1 has a total rated primary capacity of 108 MGD and a secondary
treatment capacity of 80 MGD. Plant No. 2 has a rated primary capacity of 168 MGD and secondary
treatment capacity of 90 MGD.
Wastewater from the Project site is treated at OC San's Plant No. 1 in Fountain Valley. Enderle Center is
currently served by the existing 8-inch diameter sewer lines in 17'" Street, Yorba Street, Enderle Center
Drive, and Vandenberg Lane.
Existing wastewater lines adjacent to the Project site are shown in Figure 5.1 1-1, Utilities.
5.11.3.3 WASTEWATER THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:
UT-3 Require or result in the construction of new wastewater facilities, or expansion of existing
facilities, the construction of which could cause significant environmental effects; or
UT-4 Result in a determination by the wastewater treatment provider that would serve the project
that it has adequate capacity to serve the project's projected demand in addition to the
provider's existing commitments.
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5.11.3.4 WASTEWATER SERVICE METHODOLOGY
The evaluation of wastewater infrastructure quantifies the amount of wastewater that would be generated
from operation of the proposed Project and compares the demand to the existing and planned sewer
infrastructure in the Project area, and the wastewater treatment plant that treats flows from the Project site.
The evaluation identifies if expansions would be required to serve the proposed development, and if those
expansions have the potential to result in an environmental impact.
5.11.3.5 WASTEWATER ENVIRONMENTAL IMPACTS
IMPACT UT-3: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR
CONSTRUCTION OF NEW WASTEWATER FACILITIES, OR EXPANSION OF EXISTING
FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT
ENVIRONMENTAL EFFECTS.
Less than Significant Impact with Mitigation. The Project site is currently developed as a commercial site
and is surrounded by other commercial developments. The Project would include a GPA, CA, and a HO
district to allow for future development of the Project site with up to 413 housing units over approximately
seven acres of developable land within the existing 1 1.8-acre site, consistent with the City's certified 2021-
2029 Housing Element. Additionally, the Project anticipates the future nonresidential capacity buildout of
118,474 SF within the remaining nonresidential -designated area of the Project site. A specific development
project is not proposed as part of this Project.
The wastewater facilities currently serving the Project site would likely be sufficient to accommodate the
anticipated 118,474 SF of additional nonresidential development proposed by the Project, as the additional
nonresidential square footage is the remaining development potential contained within the City's General
Plan Land Use Element. However, future residential projects proposed under the Project could necessitate
further wastewater infrastructure, including new wastewater connections, sewer pumps, and other
improvements to wastewater utilities within the existing Project site footprint and within adjacent utility right-
of-way beneath 17r" Street, Yorba Street, Enderle Center Drive, and Vandenberg Lane. Local improvements
are anticipated, and extensive offsite utility improvements are not assumed for the Project.
Future implementation of development projects pursuant to the proposed Project would include installation
of onsite wastewater infrastructure and new connections to the wastewater distribution system that would be
sized to accommodate the increased wastewater demand of new project -specific development on a project -
by -project basis. Wastewater supply design specifications for each future site -specific development project
would be required to comply with the City of Tustin standards (per the California Building Code) regarding
requirements for design and operation of wastewater distribution facilities and would be verified during
plan check (PPP UT-1). Additionally, Mitigation Measure UT-2 is incorporated into the Project to require
future projects to coordinate with EOCWD and prepare a capacity analysis of existing wastewater utilities
in the area to ensure conveyance and pressure is adequate. The capacity analysis is required to be reviewed
and approved by EOCWD and the City prior to the approval of construction permits.
Under the City's normal development review procedure for individual projects, the City determines the actual
wastewater system design requirements of each site -specific development project, and the needs for any
improvements to the existing wastewater supply infrastructure would be identified and required by the City
construction permit. The temporary construction of needed wastewater system improvements would occur
along existing pipeline alignments and within existing street rights -of -way, and construction sites and would
be required to comply with all City standards regarding construction noise, air quality and dust suppression
mitigation requirements, erosion control (through the required SWPPP) and temporary construction traffic
controls. Implementation of PPP HYD-1 would ensure that potential construction impacts related to any
needed water line improvements remain less than significant. Further, PPP T-2 is incorporated into the Project
City of Tustin 5.1 1-14
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Enderle Center Rezone Proiect 5.11 Utilities and Service
to require all utility work occurring as part of future proposed projects to adhere to the traffic control
standards specified by the City's latest Standard Plans and Design Standards, which includes the requirement
for Traffic Control Plan during construction, the process prior to commencing construction within the City public
right-of-way (including utility work), and specifications for operational roadway and traffic control design.
As a result, potential impacts related to buildout of the proposed Project would not result in construction of
new or expanded wastewater facilities that would result in a significant environmental effect. Therefore,
impacts would be less than significant.
IMPACT UT-4: THE PROJECT WOULD RESULT IN A DETERMINATION BY THE WASTEWATER
TREATMENT PROVIDER THAT WOULD SERVE THE PROJECT THAT IT HAS ADEQUATE
CAPACITY TO SERVE THE PROJECTS PROJECTED DEMAND IN ADDITION TO EXISTING
COMMITMENTS.
Less than Significant Impact with Mitigation. Future buildout of the proposed Project would result in an
increase of wastewater generation from the site. Using EOCWD's wastewater flow factors, residential uses
use approximately 100 gallons per day per dwelling unit (gpd/du) and non-residential uses use
approximately 2,500 gallons per 1 per day per acre (gpd/ac) (J. Smyth, personal communication, March
27, 2024). Therefore, the estimated 413 residential dwelling units and 118,474 SF of nonresidential
employees would generate an additional wastewater demand of 21,100 gallons per day or 23.7 AFY.
Wastewater from the Project Site is treated at OC San's wastewater treatment plant in Fountain Valley
(Plant No. 1). Plant No. 1 has a total rated primary capacity of 108 MGD and a secondary treatment
capacity of 80 MGD. Thus, the amount of wastewater that would be generated by the proposed Project is
less than 1 percent of Plant No. 1's total remaining daily treatment capacity. As a result, the wastewater
treatment plant serving the Project would have adequate capacity to serve the proposed Project's demand
in addition to existing service commitments, and impacts would be less than significant.
Additionally, Mitigation Measure UT-2 is incorporated into the Project to require future projects to coordinate
with EOCWD and prepare a capacity analysis of existing wastewater utilities in the area to ensure
conveyance and pressure is adequate. The capacity analysis is required to be reviewed and approved by
EOCWD and the City prior to the approval of construction permits. With implementation of Mitigation
Measure UT-2, impacts would be less than significant.
5.11.3.6 WASTEWATER CUMULATIVE IMPACTS
Cumulative wastewater infrastructure impacts are considered on a systemwide basis and are associated with
the overall capacity of existing and planned infrastructure. The cumulative system evaluated includes the
sewer system and the conveyance system through wastewater disposal at the OC San's Wastewater
Treatment. As described previously, with the proposed Project, the sewer system would have sufficient
capacity to handle the increased flows resulting from implementation of the proposed Project. The continued
regular assessment, maintenance, and upgrades of the sewer system by EOCWD would reduce the potential
of cumulative development projects to result in a cumulatively substantial increase in wastewater such that
new or expanded facilities would be required. Thus, increases in wastewater in the sewer system would result
in a less than significant cumulative impact.
5.11.3.7 EXISTING STANDARD CONDITIONS AND PLANS, PROGRAMS, OR
POLICIES
Existing Regulations
• California Code of Regulations Title 24, Part 1 1; the California Green Building Code
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5.11 Utilities and Service
Plans, Programs, or Policies
PPP UT-1: California Building Code. All future development constructed under the Project shall be subject
to the latest version of the California Building Code (CBC) which outlines regulations for building planning
and construction in the state, including occupancy classification, structural design, building materials,
infrastructure needs and fire -resistance requirements.
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide the
City Building Division evidence of compliance with the NPDES (National Pollutant Discharge Elimination
System) requirement to obtain a construction permit from the State Water Resource Control Board (SWRCB).
The permit requirement applies to grading and construction sites of one acre or larger. The Project
applicant/proponent shall comply by submitting a Notice of Intent (NOI) and by developing and
implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting
plan for the construction site.
PPP T-2: Traffic Control/Utilities. All future development constructed under the Project shall be subject to
the traffic control standards specified by the City's latest Standard Plans and Design Standards, which includes
the requirement for Traffic Control Plan during construction, the process prior to commencing construction
within the City public right-of-way (including utility work), and specifications for operational roadway and
traffic control design.
5.11.3.8 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts UT-3 would be potentially significant and UT-4 would be less than significant.
5.11.3.9 WASTEWATER MITIGATION MEASURES
MM UT-2 Future proposed Projects shall prepare capacity analyses of existing sewer utilities in the
area to ensure conveyance and pressure is adequate for future projects proposed. The
developer shall then identify infrastructure improvements necessary for the proposed
development. The developer will be responsible for preparing a capacity analysis in
coordination with the EOCWD and the City. The capacity analysis and infrastructure
improvements shall be reviewed and approved by EOCWD and the City prior to approval
of the construction permit.
5.11.3.10 WASTEWATER LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to wastewater infrastructure would occur.
5.1 1.4 DRAINAGE
5.11.4.1 DRAINAGE REGULATORY SETTING
Santa Ana Regional Municipal Separate Storm Sewer System Permit
The Municipal Separate Storm Sewer System (MS4) Permit (Order No. R8-2009-0030) for the Santa Ana
Region regulates urban runoff from areas under jurisdiction of the Permit's various permittees, which include
Orange County, Orange County Flood Control District, and the incorporated cities within Orange County,
including the City of Tustin. When discharged, urban runoff (or stormwater) has the potential to mix with and
carry various pollutants into receiving waters. The Permit lists allowable and unallowable discharges and
requires implementation of Low Impact Development (LID) infrastructure, which are engineered facilities that
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are designed to retain and/or biotreat runoff on the project site. Developments that qualify as New
Development or Significant Redevelopment projects are considered priority projects and are required to
develop a site -specific water quality management plan (WQMP), which includes site design, source control,
and treatment control elements to reduce the discharge of pollutants in runoff. The WQMP is required to be
approved prior to the issuance of a building or grading permit, and post -construction best management
practices (BMPs) are required to be implemented. The MS4 Permit requires priority projects to infiltrate,
harvest and use, evapotranspire, or biotreat/biofilter, the 85th percentile of a 24-hour storm event (Design
Capture Volume). The MS4 Permit also requires the evaluation and use of LID features using the following
hierarchy of treatment: infiltration, evapotranspiration, harvest/reuse, and biotreatment.
Biotreatment BMPs are a broad class of LID BMPs that reduce stormwater volume to the maximum extent
practicable, treat stormwater using a suite of treatment mechanisms characteristic of biologically active
systems, and discharge water to the downstream storm drain system or directly to receiving waters.
Treatment mechanisms include media filtration (through biologically -active media), vegetative filtration
(straining, sedimentation, interception, and stabilization of particles resulting from shallow flow through
vegetation), general sorption processes (i.e., absorption, adsorption, ion exchange, precipitation, surface
complexation), biologically -mediated transformations, and other processes to address both suspended and
dissolved constituents. Examples of biotreatment BMPs include bioretention with underdrains, vegetated
swales, constructed wetlands, and proprietary biotreatment systems.
County of Orange Drainage Area Management Plan
The Drainage Area Management Plan (DAMP) is the County's primary policy, planning and implementation
document for NPDES Permit compliance. The DAMP describes the agreements, structures and programs that:
• Provide the framework for the program management activities and plan development;
• Provide the legal authority for prohibiting unpermitted discharges into the storm drain system and for
requiring BMPs in new development and significant redevelopment;
• Ensure that all new development and significant redevelopment incorporates appropriate Site Design,
Source Control, and Treatment Control BMPs to address specific water quality issues;
• Ensure that construction sites implement control practices that address construction related pollutants
including erosion and sediment control and onsite hazardous materials and waste management.
The DAMP requires that new development and significant redevelopment projects (or priority projects)
develop and implement a Preliminary WQMP that includes BMPs and LID design features that would provide
onsite treatment of stormwater to prevent pollutants from onsite uses from leaving the site. The WQMP is
required to be prepared in accordance with the North Orange County Technical Guidance Document (TGD),
which is provided as exhibit 7.111 to the DAMP.
City of Tustin General Plan
The Land Use Element includes the following policy related to drainage facilities:
Goal 8: Ensure that necessary public facilities and services should be available to accommodate
development proposed on the Land Use Policy Map.
Policy 8.5: Continue to make incremental improvements to the flood control and drainage system.
The Conservation/Open Space/Recreation Element includes the following policy related to drainage
facilities:
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Goal 8: Conserve and protect significant topographical features, important watershed areas,
resources, and soils.
Policy 8.2: Control erosion during and following construction through proper grading techniques,
vegetation replanting, and the installation of proper drainage improvements.
Tustin City Code
Article 4, Chapter 8 — Floodplain Management.
Article 4, Chapter 9, Section 4902 - Control of Urban Runoff. This code section states that all new
development and significant redevelopment within the City shall be undertaken in accordance with the
County Drainage Area Management Plan (DAMP) and any conditions and requirements established by the
City Community Development Department and Public Works Department, which are reasonably related to
the reduction or elimination of pollutants in storm water runoff from the project site. Prior to the issuance by
the City of a grading permit, building permit or nonresidential plumbing permit for any new development
or significant redevelopment, the City Community Development Department shall review the project plans
and impose terms, conditions, and requirements on the project.
5.11.4.2 DRAINAGE ENVIRONMENTAL SETTING
Storm Drainage Facilities
The Project site is currently developed with commercial uses. The Project site currently drains into the City's
stormwater sewer system via a series of culverts and drains. Stormwater drains to the southeast corner of
the site into a catch basin at the Vanderberg Lane and Enderle Center Drive intersection. The storm drain
then continues east and connects to the existing Orange County Flood Control District (OCFCD) facility
located between Enderle Center Drive and Prospect Avenue. Because the site is currently almost entirely
paved, future development would increase intensity of development, but would not result in additional
impervious surfaces that could increase the volume and velocity of stormwater runoff.
5.11.4.3 DRAINAGE THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:
UT-5 Require or result in the construction of new stormwater drainage facilities, or expansion of
existing facilities, the construction of which could cause significant environmental effects.
5.11.4.4 DRAINAGE METHODOLOGY
The evaluation of stormwater drainage infrastructure quantifies the amount of impervious surfaces and
stormwater runoff that would be generated from the proposed Project and identifies if runoff from the
proposed Project would be accommodated by the existing stormwater drainage infrastructure. The
evaluation identifies if expansions would be required to serve the proposed development, and if those
expansions have the potential to result in an environmental impact.
5.11.4.5 DRAINAGE ENVIRONMENTAL IMPACTS
IMPACT UT-5: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR
CONSTRUCTION OF NEW DRAINAGE FACILITIES, OR EXPANSION OF EXISTING
FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT
ENVIRONMENTAL EFFECTS.
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Less than Significant Impact. The Project site is currently developed as a commercial site and is surrounded
by other commercial developments. The Project would include a GPA, CA, and a HO district to allow for
future development of up to 413 housing units over a maximum area of seven (7) acres within the existing
1 1.8-acre site, consistent with the City's certified 2021-2029 Housing Element. Additionally, the Project
anticipates the future nonresidential capacity buildout of 118,474 SF within the remaining nonresidential -
designated area of the Project site. A specific development project is not proposed as part of this Project.
The Project site is fully developed and is nearly 100 percent impervious aside from some landscaped areas.
Therefore, implementation of the proposed Project would not change the amount of impervious surface and
would not substantially change the amount of storm water runoff, and is not anticipated to exceed capacity
of the existing stormwater drainage system.
Future implementation of development projects pursuant to the proposed Project would include installation
of onsite storm drain infrastructure and new connections to the existing storm drain system that would be
sized to accommodate the storm drain water demand of new project -specific development on a project -by -
project basis. Local improvements are anticipated, and extensive offsite utility improvements are not assumed
for the Project.
Additionally, the City's M54 permit and County Drainage Area Management Plan (DAMP) require new
development projects to prepare a WQMP (PPP HYD-3) that is required to include BMPs to reduce the
potential of stormwater pollutants through site design and structural treatment control BMPs. As part of the
permitting approval process, the proposed drainage and water quality design and engineering plans would
be reviewed by the City's Engineering Division to ensure that the site -specific design limits the potential for
sources of polluted runoff. Overall, adherence to the existing regulations would ensure that impacts as a
result of future development related to stormwater runoff would be less than significant.
Under the City's normal development review procedure for individual projects, the City determines the actual
storm drain system design requirements of each site -specific development project, and the needs for any
improvements to the existing water supply infrastructure would be identified and required by the City
construction permit. The temporary construction of needed storm drain system improvements would occur
along existing pipeline alignments and within existing street rights -of -way, and would be required to comply
with all City standards regarding construction noise, air quality and dust suppression mitigation requirements,
erosion control (through the required SWPPP) and temporary construction traffic controls. Implementation of
PPP HYD-1 would ensure that potential construction impacts related to any needed water line improvements
remain less than significant. Further, PPP T-2 is incorporated into the Project to require all utility work
occurring as part of future proposed projects to adhere to the traffic control standards specified by the
City's latest Standard Plans and Design Standards, which includes the requirement for Traffic Control Plan
during construction, the process prior to commencing construction within the City public right-of-way (including
utility work), and specifications for operational roadway and traffic control design. As a result, potential
impacts related to buildout of the proposed Project would not result in construction of new or expanded
stormwater drainage facilities that would result in a significant environmental effect.
Further, the Project site is included in the Federal Emergency Management Agency (FEMA) Flood Insurance
Rate Map (FIRM) Map Number 06059C0l 64J (Federal Emergency Management Agency, 2009). The Project
site is within an area designated as Zone X, areas of 0.2 percent annual chance of flood; areas of 1 percent
annual chance of flood with average depths of less than 1 foot or with drainage areas less than 1 square
mile; and areas protected by levees from 1 percent annual chance flood. Therefore, the Project site is not
currently within a designated flood zone.
As described above, the Project site is currently completely developed and completely paved, with the
exception of some ornamental landscaped areas. Therefore, future development would not result in
additional impervious surfaces that could increase the volume and velocity of stormwater runoff that would
exacerbate flood conditions. Therefore, impacts would be less than significant.
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5.11.4.6 DRAINAGE CUMULATIVE IMPACTS
The geographic scope for cumulative impacts related to stormwater drainage includes the geographic area
served by the existing stormwater infrastructure for the Project area, from capture of runoff through final
discharge points. As described above, the proposed Project would not cause a substantial change in the
amount of stormwater runoff from the Project site. As a result, the proposed Project would not generate
additional runoff that could combine with runoff from cumulative projects that could cumulatively combine to
impact drainage. Thus, cumulative impacts related to drainage would be less than significant.
5.11.4.7 EXISTING REGULATIONS AND PLANS, PROGRAMS OR POLICIES
Plans, Programs or Policies
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide the
City Building Division evidence of compliance with the NPDES (National Pollutant Discharge Elimination
System) requirement to obtain a construction permit from the State Water Resource Control Board (SWRCB).
The permit requirement applies to grading and construction sites of one acre or larger. The Project
applicant/proponent shall comply by submitting a Notice of Intent (NOI) and by developing and
implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting
plan for the construction site.
PPP HYD-3 WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a completed
Water Quality Management Plan (WQMP) shall be prepared by the Project applicant and submitted to
and approved by the City Public Works Department. The WQMP shall identify all Post -Construction, Site
Design. Source Control, and Treatment Control Best Management Practices (BMPs) that will be incorporated
into the development Project in order to minimize the adverse effects on receiving waters.
PPP T-2: Traffic Control/Utilities. All future development constructed under the Project shall be subject to
the traffic control standards specified by the City's latest Standard Plans and Design Standards, which includes
the requirement for Traffic Control Plan during construction, the process prior to commencing construction
within the City public right-of-way (including utility work), and specifications for operational roadway and
traffic control design.
5.11.4.8 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact UT-5 would be less than significant.
5.11.4.9 DRAINAGE MITIGATION MEASURES
No new mitigation measures are required for the proposed Project.
5.11.4.10 DRAINAGE LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to drainage would occur.
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5.1 1.5 SOLID WASTE
5.11.5.1 SOLID WASTE REGULATORY SETTING
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act of 1976 (Title 40 of the Code of Federal Regulations), Part
258, contains regulations for municipal solid waste landfills and requires states to implement their own
permitting programs incorporating the federal landfill criteria. The federal regulations address the location,
operation, design (liners, leachate collection, run-off control, etc.), groundwater monitoring, and closure of
landfills.
California Assembly Bill 939
The California Integrated Waste Management Act (AB 939) made all California cities, counties, and
approved regional solid waste management agencies responsible for enacting plans and implementing
programs to divert 25 percent of their solid waste by 1995 and 50 percent by year 2000. Later legislation
mandates the 50 percent diversion requirement be achieved every year.
California Assembly Bill 341
On October 6, 2011, Governor Brown signed AB 341 establishing a state policy goal that no less than 75
percent of solid waste generated be source reduced, recycled, or composted by 2020, and requiring
CalRecycle to provide a report to the Legislature that recommends strategies to achieve the policy goal. AB
341 also requires businesses and multi -family residential dwellings of five units or more, that generate four
or more cubic yards of commercial solid waste per week to implement recycling programs.
California Assembly Bill 1826
On September 28, 2014, Governor Brown signed AB 1826 requiring businesses to recycle their organic
waste on and after April 1, 2016, dependent on the amount of waste generated per week. This law requires
that local jurisdictions implement an organic waste recycling program to divert organic waste generated by
businesses and multifamily residential dwellings that consist of five or more units.
California Assembly Bill 827
Signed into law by Governor Newsom in 2019, AB 827 requires businesses subject to AB 1 826 and AB 341
starting July 1, 2020, to provide customers with easily accessible recycling and organics collection bins or
containers to collect these materials generated from products purchased on the premises.
California Senate Bill 1383
On September 19, 2016, Governor Brown signed SB 1 383 establishing regulations aimed to reduce organic
waste disposal 75 percent and reduce least 20 percent of currently disposed surplus edible food by 2025.
The intent of the law is to reduce methane, increase landfill usage, and provide additional food sources for
Californians.
California Green Building Standards
Section 5.408.1 Construction waste diversion. Recycle and/or salvage for reuse a minimum of 65 percent
of the nonhazardous construction and demolition waste.
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Section 5.410.1 Recycling by occupants. Provide readily accessible areas that serve the entire building
and are identified for the depositing, storage and collection of non -hazardous materials for recycling,
including (at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals, or meet
a lawfully enacted local recycling ordinance, if more restrictive.
City of Tustin General Plan
The City's General Plan Conservation/Open Space/Recreation Element contains the following goals and
policies related to solid waste services.
Goal 10: Reduce solid waste produced within City.
Policy 10.1: Implement policies of the adopted Tustin Source Reduction and Recycling Element and
Household Hazardous Waste Management Element.
Policy 10.2: Ensure that the City diverts from landfills a maximum of 50% of the solid waste generated
in the City as required by the California Integrated Waste Management Board.
Policy 10.3: Maximize public awareness of all source reduction programs, including opportunities for
community feedback and school education.
Policy 10.4: Maximize integration of all source reduction programs.
Policy 10.5: Assist in the development of local, regional, and statewide markets for materials collected
and processed through the source reduction programs.
Tustin City Code
Tustin City Code Article 4, Chapter 3, Part 1, covers the general provisions regarding solid waste handling
in order to protect the public health, safety and welfare and to meet the City's obligations under the
California Integrated Waste Management Act of 1989 (AB 939). It also covers the provisions of the
Mandatory Commercial Recycling requirements detailed in AB 341, the Mandatory Commercial Organics
Recycling requirements detailed in AB 1826, the Mandatory Organics Collection requirements detailed in
SB 1 383 and Customer Access to Recycling requirements detailed in AB 827.
5.11.5.2 SOLID WASTE ENVIRONMENTAL SETTING
The two closest landfills to the Project site are the Frank R. Bowerman Landfill in Irvine and the Olinda Alpha
Sanitary Landfill in Brea. The Frank Bowerman Landfill is permitted to accept 11,500 tons per day of solid
waste and is permitted to operate through 2053. In January 2024, the maximum tonnage received was
8,710.78 tons. Thus, the facility had additional capacity of 2,789.22 tons per day (CalRecycle, 2024). Per
a Solid Waste Facility Permit (SWFP) issued on July 8, 2021, the Olinda Alpha Sanitary Landfill is permitted
to receive 10,000 tons per day for 36 days of the year and is permitted to receive 8,000 tons per day for
the other 271 days of the year. The Olinda Alpha Sanitary Landfill is permitted to operate through 2036.
In January 2024, the maximum tonnage received was 8,404 tons, which is below the 10,000 tons per day
that the facility is allowed to receive for 36 days of the year (CalRecycle, 2024). Thus, the Olinda Alpha
Sanitary Landfill has additional capacity to accept solid waste that may be generated by the Project.
5.11.5.3 SOLID WASTE THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:
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5.11 Utilities and Service
UT-6 Generate solid waste in excess of state or local standards, or in excess of the capacity of
local infrastructure, or otherwise impair the attainment of solid waste reduction goals.
UT-7 Comply with federal, state, and local management and reduction statutes and regulations
related to solid waste.
5.11.5.4 SOLID WASTE METHODOLOGY
Solid waste generation from operation of the proposed Project was estimated using 2022.1 CaIEEMod solid
waste generation factors derived for multi -family residential and commercial uses. Solid waste volumes were
then compared with recent estimates of remaining disposal capacity of the landfill serving the City. In
addition, potential impacts related to compliance with solid waste regulations were evaluated by identifying
how the proposed Project would implement the relevant requirements.
5.11.5.5 SOLID WASTE ENVIRONMENTAL IMPACTS
IMPACT UT-6: THE PROJECT WOULD NOT GENERATE SOLID WASTE IN EXCESS OF STATE OR LOCAL
STANDARDS, OR IN EXCESS OF THE CAPACITY OF LOCAL INFRASTRUCTURE, OR
OTHERWISE IMPAIR THE ATTAINMENT OF SOLID WASTE REDUCTION GOALS.
IMPACT UT-7: THE PROJECT WOULD COMPLY WITH FEDERAL, STATE, AND LOCAL STATUTES AND
REGULATIONS RELATED TO SOLID WASTE.
Less than Significant Impact.
The Project does not propose a specific development project; however, the Project would facilitate future
residential development within the Project site where it is not currently permitted. As such, future development
within the Project site would generate an incremental increase in solid waste volumes requiring off -site
disposal during short-term construction and long-term operational activities. Users of solid waste collection
and disposal services would be required to pay service fees to the City's waste collection provider. As
discussed above, solid waste generated by future development within the Project site could be disposed of
at the Frank R. Bowerman Landfill and Olinda Alpha Sanitary Landfill.
A specific development project is not proposed at this time; however, implementation of the proposed Project
could result in the construction of 413 residential units and 118,474 SF of nonresidential development.
Construction
Future implementing project construction would generate solid waste for landfill disposal in the form of
packaging and discarded materials that would be removed from the site. Construction waste would be
properly characterized as required by law and recycled or disposed of at an appropriate type of landfill
for such materials. Section 5.408.1 of the 2022 California Green Building Standards Code requires
demolition and construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous
construction and demolition waste. Thus, the construction solid waste that would be disposed of at the landfill
would be approximately 35 percent of the waste generated. As described above, Frank Bowerman Landfill
is permitted to accept 11,500 tons per day of solid waste and the Olinda Alpha Sanitary Landfill is
permitted to receive 10,000 tons per day for 36 days of the year and is permitted to receive 8,000 tons
per day for the other 271 days of the year. Both of these landfills would be able to accommodate the
construction solid waste from the proposed Project. Therefore, impacts related to landfill facilities from
construction activities would be less than significant.
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5.11 Utilities and Service
Operation
Using solid waste generation rates provided by CalEEMod, operation of the proposed Project at buildout
would generate approximately 227.65 tons of solid waste per year, at least 75 percent of which is required
by California law to be recycled, which would reduce the volume of landfilled solid waste to approximately
56.9 tons per year, or 1.1 tons per week, as shown on Table 5.1 1-3.
Table 5.11-3: Solid Waste Demand from Operation of the Proposed Project
Land Use
Quantity
Generation Rate
Solid Waste Demand
Residential
413 units
0.25 tons/unit/year
103.25 tons per year
Nonresidential
118,474 SF
1.05 tons/1,000
SF/year
124.4 tons per year
Total Solid Waste
227.65 tons per year
Annual Landfill Disposal
with AB 341 (75% Reduction)
56.9 tons per year
Weekly Landfill Disposal with AB 341 (75% Reduction)
1.1 tons per week
Source: 2022.1 CalEEMod Solid Waste Generation Rates
As described above, Frank Bowerman Landfill is permitted to accept 11,500 tons per day of solid waste
and the Olinda Alpha Sanitary Landfill is permitted to receive 10,000 tons per day for 36 days of the year
and is permitted to receive 8,000 tons per day for the other 271 days of the year. Both landfills would be
able to accommodate the operational solid waste from future development under the proposed Project.
Thus, future development under the proposed Project would be served by a landfill with sufficient permitted
capacity to accommodate the Project's solid waste disposal needs and the proposed Project would not impair
the attainment of solid waste reduction goals. Thus, impacts related to landfill capacity would be less than
significant.
Future implementing projects would also be subject to Section 5.408.1 of the 2022 California Green Building
Standards Code that requires demolition and construction activities to recycle or reuse a minimum of 65
percent of the nonhazardous construction and demolition waste. Furthermore, future implementing projects
would be required to comply with all applicable State and local waste diversion requirements, including AB
939, AB 341, AB 1836, AB 827 and SB 1383. Therefore, the proposed Project would comply with all solid
waste statute and regulations; and impacts would be less than significant.
5.11.5.6 SOLID WASTE CUMULATIVE IMPACTS
Cumulative projects in the area would increase solid waste generation and decrease the available capacity
of the nearby landfills. However, as with the proposed Project, cumulative projects have been or would be
required to conduct an environmental review and would be required to adhere to solid waste regulations,
which are aimed at reducing overall solid waste levels. Furthermore, both the Frank R. Bowerman landfill
and the Olinda Alpha Landfill are forecasted to have sufficient capacity to serve current and future needs
until their scheduled closures in December 2053 and December 2036, respectively. Therefore, the increase
in solid waste from future buildout of the proposed Project would be less than cumulatively considerable and
would be less than significant.
5.11.5.7 EXISTING STANDARD CONDITIONS AND PLANS, PROGRAMS, OR
POLICIES
The following standard regulations would reduce potential impacts related to solid waste:
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5.11 Utilities and Service
• California Green Building Standards Code
• Assembly Bill 939 (Chapter 1095, Statutes of 1989)
• Assembly Bill 341 (Chapter 476, Statutes of 201 1)
• Assembly Bill 1826 (Chapter 727, Statutes of 2014)
• Assembly Bill 827
• Senate Bill 1383 (Chapter 395, Statutes of 2016)
• Tustin City Code Article 4, Chapter 3, Part 1
5.11.5.8 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts UT-6 and UT-7 would be less than significant.
5.11.5.9 SOLID WASTE MITIGATION MEASURES
No new mitigation measures are required for the proposed Project.
5.11.5.10 SOLID WASTE LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to solid waste would occur.
5.1 1.6 DRY UTILITIES
5.11.6.1 DRY UTILITIES REGULATORY SETTING
Title 24 Energy Efficiency Standards and California Green Building Standards
California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code (CalGreen) is updated
every three years. The most recent update is the 2022 California Green Building Code Standards that
became effective January 1, 2023. The 2022 CALGreen standards that are applicable to the proposed
Project include, but are not limited to, the following:
• Electric vehicle charging stations. Facilitate the future installation of electric vehicle supply equipment.
The compliance requires empty raceways for future conduit and documentation that the electrical system
has adequate capacity for the future load.
• Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight,
uplight and glare ratings per Title 24 Part 6 Table 5.106.8.
• Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings
(faucets and showerheads).
• Outdoor portable water use in landscaped areas. Nonresidential developments shall comply with a local
water efficient landscape ordinance or the current California Department of Water Resources' Model
Water Efficient (MWELO), whichever is more stringent.
City of Tustin General Plan
The City's General Plan Land Use Element contains the following policy related to dry utilities.
Goal 8: Ensure that necessary public facilities and services should be available to accommodate
development proposed on the Land Use Policy Map.
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5.11 Utilities and Service
Policy 8.6: Encourage planned improvements to electricity, natural gas, and communication service
systems.
5.11.6.2 DRY UTILITIES ENVIRONMENTAL SETTING
Electricity
Electricity is provided to the Project by Southern California Edison (SCE). SCE provides electric power to
more than 15 million persons within its 50,000 square mile service area. According to SCE's 2022 Power
Content Label Mix, SCE derives electricity from varied energy resources including: biomass and biowaste,
geothermal, hydroelectric, solar, wind, nuclear, and natural gas. SCE also purchases power from independent
power producers and utilities, which includes out-of-state providers (California Energy Commission, 2022).
Natural Gas
Natural gas would be provided to the Project by the Southern California Gas Company (SoCal Gas).
SoCalGas provides natural gas to more than 21 million persons within its 24,000 square mile service area
(SoCalGas, 2024).
Telecommunications
Telecommunications would be provided to the Project by AT&T and Cox Communications.
5.11.6.3 DRY UTILITIES THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a project could have a significant effect if it were to:
UT-8 Require or result in the relocation or construction of a new or expanded electric power,
natural gas, or telecommunications facilities, the construction of which could cause significant
environmental effects.
5.11.6.4 DRY UTILITIES METHODOLOGY
The evaluation of dry utilities identifies if dry utility demand from the Project would be accommodated via
existing dry utility infrastructure available to the Project. The evaluation identifies if expansions would be
required to serve the proposed development, and if those expansions have the potential to result in an
environmental impact.
5.11.6.5 DRY UTILITIES ENVIRONMENTAL IMPACTS
IMPACT UT-8: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR
CONSTRUCTION OF A NEW OR EXPANDED ELECTRIC POWER, NATURAL GAS, OR
TELECOMMUNICATIONS FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE
SIGNIFICANT ENVIRONMENTAL EFFECTS.
Less than Significant Impact. The proposed Project is a Housing Overlay (HO) district at the Enderle Center
site. The HO district will allow residential uses on the Project site, which currently only allows commercial uses.
The proposal is regulatory in nature, and a specific development project is not proposed at this time.
However, implementation of the proposed Project could result in 413 dwelling units and up to 118,474 SF
of nonresidential uses. Implementation of the future buildout would generate demand for electricity, natural
gas, communication systems, street lighting, and maintenance of public facilities.
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Electricity would be provided to the Project by SCE. Adequate commercial electricity supplies are presently
available to meet the incremental increase in demand attributed to the Project. Provision of electricity to the
Project site is not anticipated to require or result in the construction of new facilities or the expansion of
existing facilities, the construction or relocation of which would cause significant environmental impacts to
electricity. Impacts would be less than significant.
Natural gas service would be provided by SoCal Gas. Adequate commercial gas supplies are presently
available to meet the incremental increase in demand attributed to the Project. The proposed Project would
not require or result in the construction, expansion, or relocation of natural gas facilities that could result in a
significant environmental impact. Impacts related to natural gas would be less than significant.
Communication systems for the Project would be provided by AT&T and Cox Communications. AT&T and
Cox Communications are private companies that provide connection to the communication system on an as
needed basis. As such, the proposed Project is not anticipated to require or result in the construction of new
communications facilities or the expansion of existing facilities. Impacts would be less than significant.
Future Project Applicants would be responsible for coordinating with each utility company to ensure utility
improvements occur according to standard construction and operation procedures administered by the
California Public Utilities Commission. Any development in the City would be required to comply with energy
efficiency standards in Title 24 of the California Administrative Code, appliance efficiency regulations in
Title 20 of the California Administrative Code, CALGreen. Therefore, potential impacts associated with
utilities, including electricity, natural gas and communication systems would be less than significant and no
mitigation is required.
5.11.6.6 DRY UTILITIES CUMULATIVE IMPACTS
The geographic scope of cumulative analysis for dry utilities is the service area for the SCE, SoCalGas, AT&T
and Cox Communications, which serve the Project area. Cumulative impacts related to the provision of
facilities for electricity, natural gas and communications systems have been evaluated throughout this EIR.
Mitigation measures have been recommended in cases where cumulatively -considerable impacts associated
with utilities infrastructure were identified. Therefore, cumulatively -considerable impacts associated with the
provision of utility facilities to serve the Project would be less than significant.
5.11.6.7 EXISTING STANDARD CONDITIONS AND PLANS, PROGRAMS, OR
POLICIES
The following standard regulations would reduce potential impacts related to dry utilities:
• California Code of Regulations Title 24, Part 1 1; the California Green Building Code
5.11.6.8 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts UT-8 would be less than significant.
5.11.6.9 DRY UTILITIES MITIGATION MEASURES
No new mitigation measures are required for the proposed Project.
5.11.6.10 DRY UTILITIES LEVEL OF SIGNIFICANCE AFTER MITIGATION
No significant unavoidable adverse impacts related to dry utilities would occur.
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5.1 1.7 REFERENCES
Arcadis U.S., Inc.. (2020). Tustin 2020 Urban Water Management Plan .
Arcadis U.S., Inc. (2020). East Orange County Water District 2020 Urban Water Management Plan.
California Energy Commission. (2022). 2022 Power Content Label Southern California Edison. Retrieved from
California Energy Commission: https://www.energy.ca.gov/programs-and-
topics/programs/power-source-disclosure-program/power-content-label
CalRecycle. (2024). SWIS Facility/Site Summary Frank R. Bowerman Landfill (30-AB-0360). Retrieved from
CalRecycle: https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/21 03
CalRecycle. (2024). SWIS Facility/Site Summary Olinda Alpha Landfill (30-AB-0035). Retrieved from
CalRecycle: https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/2093
Federal Emergency Management Agency. (2009, December 3). Map Number 06059C0 7 64J. Retrieved from
Federal Insurance Rate Map:
https://msc.fema.gov/portal/search?AddressQuery=enderle%20center%2C%20tustin%2C%20c
a
SoCalGas. (2024). Company Profile. Retrieved from SoCalGas: https://www.socalgas.com/about-
us/company-profile
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Enderle Center Rezone Project 6.0 Other CEQA Considerations
6. Other CEQA Considerations
6.1 SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL EFFECTS
State CEQA Guidelines Section 151 26.2(c) requires an EIR to describe "any significant impacts, including
those which can be mitigated but not reduced to a level of insignificance." As described in detail in Section
5.0 of this Draft EIR, implementation of the Project would result in environmental impacts that cannot be
reduced to a level below significance after implementation of Project design features; regulatory
requirements; plans, programs, policies; and feasible mitigation measures. The significant impacts that cannot
be mitigated to a level below significance are summarized below.
6.1.1 Air Quality
Impact AQ-3, Expose sensitive receptors to substantial pollutant concentrations (Project -level and
Cumulative).
The Project would not result in an exceedance of the SCAQMD LSTs during project construction. However,
net new emissions associated with the future development of the proposed Project would exceed the
SCAQMD LSTs for PM10 during operational activities. The majority of the PMio emissions are associated with
mobile sources from project -related vehicle trips. Emissions of motor vehicles are controlled by State and
federal standards, and the project has no control over these standards. Furthermore, details of future projects
developed under the Housing Overlay (HO) district are not known at this time, therefore the analysis
considered the most conservative approach. Although future development details are unknown,
implementation of Mitigation Measure AQ-1 would require a project -specific assessment of potential
localized impacts for future projects and if future projects exceed the applicable LST thresholds, a dispersion
modeling analysis would be necessary to calculate health risk from future project implementation. While
Mitigation Measure AQ-1 would serve to reduce localized emissions associated with buildout of the project,
localized emission impacts would remain significant and unavoidable.
6.1.2 Greenhouse Gas Emissions
Impact GHG-1, Greenhouse Gas Emissions (Project -level and Cumulative). Construction and operation of
the Project would generate a net total of approximately 12,804 MTCO2e per year, thereby exceeding the
screening threshold of 3,000 MTCO2e per year. The total service population (residents plus employees)
would be 1,554 persons. The proposed project would result in per service population emissions of 8.2 metric
tons of CO2 per year per service population (MT CO2e/yr/SP), which would exceed the SCAQMD's plan -
level screening threshold of 4.1 MT CO2e/yr/SP. The proposed Project would implement Mitigation Measure
GHG-1 to minimize impacts to the greatest extent feasible. However, there is no way to quantify the
reductions from implementation of Mitigation Measure GHG-1 in CalEEMod. The likely scale and extent of
build out associated with future projects is unknown; however, the analysis assumes the most conservative
estimate would likely exceed the SCAQMD thresholds. While Mitigation Measure GHG-1 would serve to
reduce GHG emissions associated with buildout of the Project, GHG emission impacts would remain
significant and unavoidable because compliance with future efficiency targets cannot be assured and not
enough information is known regarding future projects to recommend further mitigation. As identified above,
before development can occur, once a specific development project is proposed it would be required to be
analyzed for conformance with the General Plan, zoning requirements, and other applicable local and State
requirements; comply with the requirements of CEQA; and obtain all necessary clearances and permits.
Notwithstanding, GHG emissions are conservatively assumed to be significant and unavoidable on a project -
level and cumulative basis.
City of Tustin 6-1
Draft EIR
June 2024
Enderle Center Rezone Project 6.0 Other CEQA Considerations
Impact GHG-2, Conflict with Plan, Policy, or Regulation for Reducing Greenhouse Gas Emissions
(Project -level and Cumulative). Although the proposed Project would be consistent with the identified
measures and goals from the CARB 2022 Scoping Plan and SCAG's 2024-2050 RTP/SCS (Connect SoCal),
the proposed Project would result in a significant and unavoidable impact for GHG emissions based on
SCAQMD thresholds. As such, the proposed Project would not comply with existing State regulations adopted
to achieve the overall GHG emissions reduction goals identified in the 2022 Scoping Plan, EO B-30-15, and
AB 197 and would not be consistent with applicable State plans and programs designed to reduce GHG
emissions. Therefore, the proposed Project would conflict with applicable plans, policies, and regulations
adopted for the purpose of reducing the emissions of GHGs and impacts would be significant and
unavoidable.
6.2 GROWTH INDUCEMENT
State CEQA Guidelines Section 151 26.2(e), Growth Inducing Impact of the Proposed Project, requires that
an EIR "discuss the ways in which the proposed project could foster economic or population growth, or the
construction of additional housing, either directly or indirectly, in the surrounding environment." The CEQA
Guidelines also indicate that it must not be assumed that growth in any area is necessarily beneficial,
detrimental, or of little significance to the environment. In general terms, a project may foster spatial,
economic, or population growth in a geographic area, if it meets any one of the following criteria:
1. Directly or indirectly foster economic or population growth, or the construction of additional housing, in
the surrounding environment;
2. Remove obstacles to population growth;
3. Require the construction of new or expanded facilities that could cause significant environmental effects;
or
4. Encourage and facilitate other activities that could significantly affect the environment, either individually
or cumulatively.
1. Does the Project directly or indirectly foster economic or population growth or the construction of
additional housing?
Growth -inducing potential of a project would be considered significant if it fosters growth or a concentration
of population in excess of what is assumed in master plans, land use plans, or in projections made by regional
planning agencies.
As described in Section 5.6, Population and Housing, the Project site is approximately 1 1.80 acres and is
currently developed with 87,136 SF of commercial business, including 28,750 SF of restaurant use, 39,960
SF of retail and service use, 18,426 SF of office use, and surface parking lots. The proposed Project is a
housing overlay within the Enderle Center site. No development is proposed as part of this Project. The
Project site does not currently support residential uses. However, the development that could occur from
future buildout of the proposed housing zone is 413 dwelling units and 118,474 SF of nonresidential buildout.
As detailed in Section 5.10, Population and Housing, the City has an average of approximately 2.88 persons
per household (California Department of Finance, 2023). Using this estimate, buildout of the proposed 413
units could result in an additional 1,189 residents in the city, which would be approximately 1 1.3 percent of
the projected population growth in the City of Tustin. Additionally, buildout of the proposed 413 units could
result in 10 percent of the projected housing stock growth in the City. Thus, while the Project would result in
an increase in population and housing units in an area not previously planned for housing, the increase in
population and number of housing units that would result from the proposed Project would not exceed
projections for the City.
City of Tustin 6-2
Draft EIR
June 2024
Enderle Center Rezone Project 6.0 Other CEQA Considerations
Further, SCAG determined the City needs to provide a total of 6,782 housing units to meet their Regional
Housing Needs Allocation (RHNA). Thus, the Project would contribute to the City's fair share of housing and,
in part, satisfy the State requirements to provide new housing opportunities to increase housing supply.
Additionally, the proposed Project implements goals and policies of the Tustin Housing Element that support
a variety of housing types and densities.
As described in Chapter 3, Project Description, the Project also anticipates the future nonresidential buildout
of the project area would add 118,474 SF of new non-residential development to the existing Enderle
Center. As described in Section 5.6, Population and Housing, an additional 118,474 SF of nonresidential
space would result in approximately 365 new employees (1 employee per 325 SF). Therefore, buildout of
the nonresidential portion of the Project would represent approximately 1.69 percent of the projected
employment growth in the City. Thus, while the Project would result in an increase in employment, the increase
in the number of jobs that would result from the proposed Project would not exceed projections for the City.
As described in Section 5.6, Population and Housing, the City of Tustin is jobs -rich, meaning the addition of
residential units in the area would not require additional jobs that could result in growth. Conversely, the
new residents would fill the need for employees that are anticipated by SCAG projections. Thus, the
additional residential units would not indirectly result in the need for additional employment opportunities,
which could result in growth. Therefore, this indirect impact related to growth would be less than significant.
Thus, impacts related to increased growth through the provision of employment opportunities would be less
than significant.
Overall, the Project site has historically provided employment opportunities and economic activity. The
proposed Project would provide for a different variety of employment opportunities and economic activities
that are consistent with development occurring and planned for in the Project vicinity. As detailed in Section
5.6, Population and Housing, the proposed Project would reduce (improve) the jobs -housing ratio slightly by
adding 413 residential units. The proposed Project would provide a regional beneficial effect of providing
the opportunity for housing on the Project site in a jobs -rich area, where employees can easily travel to
nearby employment opportunities. In addition, the future 413 residential units would not exceed the SCAG
population, housing, and employment growth projections for the City and would represent a nominal
percentage of SCAG's overall projections for the City of Tustin. Thus, the proposed Project provides housing
and would not result in the need for additional housing. Therefore, the economic effects of the proposed
Project would not result in the need for additional development to support the proposed Project and would
not result in a substantial impact on the environment.
2. Does the Project remove obstacles to population growth?
The elimination of a physical obstacle to growth is considered to be a growth inducing impact. A physical
obstacle to growth typically involves the lack of public service infrastructure. The Project would induce growth
if it would provide public services or infrastructure with excess capacity, which would serve lands that would
otherwise not be developable.
Remove obstacles to growth through changes in utility infrastructure. As described in Section 3.0, Project
Description, roadways, and utilities may be required to support development of future residential construction
within the Project site. Future onsite infrastructure improvements that may be necessary for residential
development within the Enderle Center include storm drains, wastewater, water, and dry utilities that would
connect to existing facilities within the Project site or adjacent to the Project area. Specific infrastructure
improvements required to support residential development within the Enderle Center are not known at this
time and will not be known until a development project is proposed. However, the Enderle Center is
surrounded by urban built-up land that is currently connected to the City's existing infrastructure system and
that is serving the Project site. Future development allowed under the proposed Project would connect to
existing infrastructure and would be sized appropriately to accommodate only the future development of
the Enderle Center, as ensured and verified by the City during the plan check and permitting process, prior
City of Tustin 6-3
Draft EIR
June 2024
Enderle Center Rezone Project 6.0 Other CEQA Considerations
to obtaining building permits. Additionally, future developers would need to conduct capacity analyses of
sewer and water utilities in the area, to ensure conveyance and pressure is adequate for future projects
proposed on a project -by -project basis. The developer will be responsible for preparing capacity analysis
and submitting them to the East Orange County Water District (EOCWD) and the City. The capacity analysis
and infrastructure improvements shall be reviewed and approved by EOCWD and the City prior to approval
of the construction permit, consistent with Mitigation Measure UT-1 in Section 5.1 1, Utilities.
Overall, future development allowed under the proposed Project could redevelop the existing onsite
infrastructure systems and replace multiple utility lines. However, the new infrastructure would not provide
additional capacity beyond what is needed to serve future development or what was previously planned
for by the City. Because the anticipated infrastructure improvements would only enhance services to
proposed developments and not provide an extension of service to areas that are currently not served, or
provide excess capacity, Project infrastructure improvements would not result in significant growth inducing
impacts.
Furthermore, future development allowed under the proposed Project could also implement circulation
improvements, which are unknown at this time, such as pedestrian and bicycle facilities, which would enhance
local circulation and use of transit. However, future circulation improvements would not extend circulation
into a new area or provide excess circulation capacity that could induce growth. As a result, the circulation
improvements would result in less than significant growth inducing impacts.
Remove obstacles to growth through changes in existing regulations pertaining to land development. The
Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM). A project could directly induce
growth if it would remove barriers to population growth such as changes to a jurisdiction's general plan and
zoning code, which allows new development to occur in underutilized areas. The proposed Project would
include a GPA to establish that higher density residential uses are allowed in the Planned Community
Commercial Business (PCCB) land use designation when prescribed by a Housing Overlay (HO) district or a
Specific Plan (SP). The Project also includes an amendment to Tustin City Code, Article 9 (Land Use), Chapter
2 (Zoning), Part 5, to establish a HO district, which allows for high density residential development, and
stipulates that objective design standards for residential development will apply to properties within the
boundary of the HO district.
The proposed Project is redevelopment of an already developed area that is surrounded by urban
development. The proposed Project would involve implementation of a HO district, which would allow
residential development of 413 dwelling units over a maximum area of seven acres and would allow for
future onsite residents and additional onsite employees. However, the zoning and land use changes are
parcel -specific and would not result in growth outside of the Project site, because the areas are either
completely developed or within development land use plans. The addition of a HO district to the Project
site's zoning designation would not result in removing an obstacle to growth within the Project vicinity.
In addition, SCAG policies concerning regional growth -inducement are included as part of Section 5.4, Land
Use and Planning, and Section 5.6, Population and Housing. As described in those sections, the growth
anticipated by SCAG's projections are consistent with the estimated future buildout of the proposed 413
units (1,189 residents) and an additional 118,474 SF of new nonresidential space (365 new employees).
Therefore, impacts related to growth from changes to existing regulations pertaining to land development
would be less than significant.
3. Does the proposed Project require the construction of new or expanded facilities that could cause
significant environmental effects?
City of Tustin 6-4
Draft EIR
June 2024
Enderle Center Rezone Project 6.0 Other CEQA Considerations
Growth induced by a project is considered a significant impact if it directly or indirectly affects the ability
of agencies to provide needed public services that requires the construction of new public service facilities,
or if it can be demonstrated that the potential growth significantly affects the environment in some other
way.
The proposed Project is expected to incrementally increase the demand for fire protection and emergency
response, police protection, school services, and recreational facilities and would not increase demand
beyond that assumed for buildout of the City of Tustin. As described in Section 5.1 1, Public Services, the
proposed Project would not require development of additional facilities or expansion of existing facilities to
maintain existing levels of service. Based on service ratios and build out projections, the proposed Project
would not create a demand for services beyond the capacity of existing facilities. Therefore, an indirect
growth inducing impact as a result of expanded or new public facilities that could support other development
in addition to the proposed Project would not occur. The proposed Project would not have significant growth
inducing consequences that would require the need to expand public services to maintain desired levels of
service.
4. Does the Project encourage or facilitate other activities that could significantly affect the environment,
either individually or cumulatively?
The proposed Project includes a GPA to amend the City's existing General Plan to establish that higher
density residential uses are allowed in the Planned Community Commercial Business (PCCB) land use
designation when prescribed by a Housing Overlay (HO) district or a Specific Plan (SP). In addition, the
Project also includes an amendment to the City's Zoning Map. The proposed zone change would require an
amendment to Tustin City Code, Article 9 (Land Use), Chapter 2 (Zoning), Part 5, to establish a HO district
that allows for higher density residential development, and stipulates that objective design standards will
apply to properties within the boundary of the HO district. The proposed Project would comply with all
applicable City plans, policies, and ordinances. In addition, Project features and mitigation measures have
been identified within this EIR to ensure that the proposed Project minimizes environmental impacts. The
proposed Project would not involve any precedent -setting action that could encourage and facilitate other
activities that significantly affect the environment.
6.3 SIGNIFICANT IRREVERSIBLE EFFECTS
State CEQA Guidelines require the EIR to consider whether "uses of nonrenewable resources during the initial
and continued phases of the project may be irreversible since a large commitment of such resources makes
removal or nonuse thereafter unlikely.... Also, irreversible damage can result from environmental accidents
associated with the project. Irretrievable commitments of resources should be evaluated to assure that such
current consumption is justified." (CEQA Guidelines Section 151 26.2(d)). "Nonrenewable resource" refers to
the physical features of the natural environment, such as land, waterways, mineral resources, etc. These
irreversible environmental changes may include current or future uses of non-renewable resources, and
secondary or growth -inducing impacts that commit future generations to similar uses.
Generally, a project would result in significant irreversible environmental changes if:
• The primary and secondary impacts would generally commit future generations to similar uses;
• The project would involve a large commitment of nonrenewable resources;
• The project would involve uses in which irreversible damage could result from any potential
environmental accidents associated with the project; or
• The proposed irretrievable commitments of nonrenewable resources are not justified (e.g., the project
involves the wasteful use of energy).
City of Tustin 6-5
Draft EIR
June 2024
Enderle Center Rezone
6.0 Other CEQA Considerations
The Project would result in or contribute to the following irreversible environmental changes:
• Lands in the Project site that are currently developed with commercial retail uses or parking area would
be committed to residential and/or commercial uses once the housing overlay is implemented. Secondary
effects associated with this irreversible commitment of land resources include:
o Increased vehicle trips on surrounding roadways during operation of future projects under the
proposed Project (see Section 5.9, Transportation).
o Emissions of air pollutants associated with construction and operation of future projects under the
proposed Project (see Section 5.1, Air Quality).
o Consumption of non-renewable energy associated with construction and operation of future projects
under the proposed Project due to the use of automobiles, lighting, heating and cooling systems,
appliances, and the like (see Section 5.3, Energy).
o Increased ambient noise associated with an increase in activities and traffic from future projects under
the proposed Project (see Section 5.9, Noise).
• Construction of future projects under the proposed Project as described in Section 3.0, Project Description,
would require the use of energy produced from non-renewable resources and construction materials.
In regard to energy usage from development of future projects under the proposed Project, as demonstrated
in the analyses contained in Section 5.3, Energy, the proposed Project would not involve wasteful or
unjustifiable use of non-renewable resources, and conservation efforts would be enforced during construction
and operation of future proposed development, as ensured and verified by the City during the plan check
and permitting process, prior to obtaining building permits. Development of future projects under the
proposed housing overlay would incorporate energy -generating and conserving project design features,
including those required by the California Building Code, California Energy Code Title 24, which specify
green building standards for new developments. Project -specific information related to energy consumption
is provided in Section 5.3, Energy, of this EIR.
6.4 REFERENCES
California Department of Finance. (2023, May). E-5 Population and Housing Estimates for Cities, Counties,
and the State — January 1, 2021-2023. Retrieved from State of California Department of
Finance.
City of Tustin. (2022). Housing Update 2021-2019.
The Natelson Company, Inc. (2001). Employment Density Study Summary Report.
City of Tustin 6-6
Draft EIR
June 2024
Enderle Center Rezone project 7. Effects Found Not
7. Effects Found Not Significant
CEQA Guidelines Section 151 26.2(a) states that "[a]n EIR shall identify and focus on the significant effects
on the environment." During the preparation of this EIR, the Project was determined in an Initial Study
(included in Appendix A of this Draft EIR) to have no potential to result in significant impacts under twelve
environmental issue areas as described below. Therefore, these issue areas were not required to be
analyzed in detail in EIR Section 5, Environmental Impact Analysis.
CEQA Guidelines Section 15128 requires that an EIR contain a statement briefly indicating the reasons that
various possible effects of a project were determined not to be significant and were therefore not discussed
in detail in the EIR. As allowed by CEQA Guidelines Section 15128, statements related to the above listed
topic areas are presented below.
7.1 AESTHETICS
Scenic Vista
Future residential development would be constructed within the boundaries of the existing Enderle Center
site and would not impede any existing views of Peters Canyon Ridgeline from 1711 Street. The provision for
residential development in an area formerly designated for nonresidential land uses would not further
diminish views of a scenic vista. Therefore, the Project would result in no impact.
Scenic Highway
According to the California Department of Transportation (Caltrans) Scenic Highway Map, the City of Tustin
does not contain any scenic highways within or surrounding the City (California Department of Transportation,
2018). The nearest State scenic highway is Route 91 in the City of Orange, approximately 8.5 miles to the
north. According to the County of Orange General Plan, there are no designated scenic roadways or scenic
vistas in the Project vicinity (County of Orange, 2005). Therefore, the Project would have no impact on scenic
resources within a State scenic highway.
Conflict with Regulations Governing Scenic Quality
The Project site is currently developed as a commercial shopping center and is surrounded by other
commercial development. The Project site is bordered to the north by 17th Street, followed by commercial,
residential and office uses; to the east by Enderle Center Drive, followed by office uses; to the south by
South Vandenberg Lane, followed by residential uses; and to the west by Tustin city limits and SR-55
freeway, followed by restaurants and office uses in the City of Santa Ana. The Project would include a
General Plan Amendment (GPA), Zoning Code Amendment (CA), and Zone Change (ZC) of the Project site
to apply a Housing Overlay (HO) district to allow for future development of up to 413 housing units,
consistent with the City's certified 2021-2029 Housing Element.
Per Housing Element Program 1.2a, the City will adopt Objective Design Standards (ODS) to ensure high
quality residential development, while simultaneously meeting the City's goal of streamlining residential
development to meet its Regional Housing Needs Allocation (RHNA) goals. Development is not proposed as
part of the Project; however, all future residential development proposed within the Project site would be
subject to the requirement and provisions of the applicable ODS.
The ODS would ensure high visual character and quality of future residential development proposed within
the Project site. All future residential development would be required to comply with the City's ODS for the
City of Tustin 7-1
Draft EIR
June 2024
Enderle Center Rezone Proiect 7. Effects Found Not
site. Therefore, the Project would not conflict with applicable zoning and other regulations governing scenic
quality and would have a less than significant impact on visual character and quality.
Light and Glare
The Project does not propose development but would allow for the future development of residential land
uses within an existing commercial shopping center. Future development could add additional nighttime light
sources, such as landscape lighting, security lighting, and the lighting from additional cars. As previously
discussed, all future projects would be required to comply with the applicable ODS for the site. The ODS
would include specific setbacks, lighting standards, and building materials that would ensure the avoidance
of potential lighting impacts. Further, all future projects would be required to comply with the City's light and
glare ordinance, which would be verified through plan check prior to project approval. Therefore, the Project
would result in a less -than -significant impact.
7.2 AGRICULTURE AND FOREST RESOURCES
Farmland
Per the California Department of Conservation (CDOC) Farmland Mapping and Monitoring Program (FMMP)
Map, the Project site is designated as Urban and Built -Up Land (California Department of Conservation,
2018). Further, the City does not currently include any commercial agricultural land uses. Existing zoning
categories within the City of Tustin do not allow for commercial agricultural uses. Therefore, the Project would
result in no impact on Prime Farmland, Unique Farmland, or Farmland of Statewide Importance.
Williamson Act Contract
The Project site is currently developed with commercial land uses and does not include agricultural land uses.
The Project site is not currently under a Williamson Act contract. Therefore, the Project would result in no
impact on existing zoning for agricultural use or a Williamson Act contract.
Forest Land/Timberland
The Project site is currently completely developed with commercial land use. The Project site does not include
forest land or timberland. Additionally, the Project site is currently zoned for Planned Community Commercial
(PC COM), which does not provide for forest land or timberland production and management. Therefore,
the Project would result in no impact on zoning of forest land or timberland or on the conversion of farmland
and timberland to non-agricultural or non -forest uses.
7.3 BIOLOGICAL RESOURCES
Special Status Species
The Project site consists of approximately 1 1.8 acres that are developed with existing commercial uses,
including restaurant, retail, and office establishments, a paved parking lot, and landscaping. The area
identified in the City's adopted Housing Element as most likely for future residential development is seven
acres of existing parking lot area of the Project site. The Project site is surrounded by urban development
with structures, paved parking, and ornamental landscaping. There is no evidence of either suitable habitat
for or the presence of any endangered, rare, threatened, or special status plant species (or associated
habitats) or wildlife species designated by the U.S. Fish and Wildlife Service (USFWS), California
Department of Fish and Wildlife (CDFW), or California Native Plant Society (CNPS).
City of Tustin 7-2
Draft EIR
June 2024
Enderle Center Rezone Proiect 7. Effects Found Not
The Project does not propose development; however, the Project would provide for future proposed
development through implementation of the housing overlay and the City's certified 2021-2029 Housing
Element. Future landscaping implemented as part of future projects would likely include a variety of
ornamental trees, shrubs, and groundcover. As the Project site is currently completely paved, implementation
of the Project would not result in an adverse effect, either directly or through habitat modifications, on any
sensitive species, and impacts would not occur.
Riparian Habitat and Sensitive Natural Communities
There is no existing riparian habitat or sensitive natural community within the developable area of the site.
Therefore, the Project would result in no impact.
Wetlands
There are no wetlands or riparian areas within the developable area of the site. Therefore, the Project
would result in no impact.
Wildlife Movement Corridor and Wildlife Nursery Sites
The Project site does not support conditions for migratory wildlife corridors or linkages. The Project site is
completely developed and surrounded by a roadway and developed land uses. The site and surrounding
areas do not provide function for wildlife land movement. Additionally, the surrounding area is developed
and urban. There are no rivers, creeks, or open drainages near the site that could function as a wildlife
corridor. Thus, implementation of the Project would not result in impacts related to wildlife movement or
wildlife corridors.
However, the Project site contains existing ornamental trees that could be used for nesting by common bird
species that are protected by the federal Migratory Bird Treaty Act (MBTA) and the California Fish and
Game Code Sections 3503.5, 3511, and 3515 during the avian nesting and breeding season that occurs
between February 1 and September 15. The provisions of the MBTA prohibit disturbing or destroying active
nests. Therefore, Mitigation Measure B1O-1 has been included to require that if commencement of vegetation
clearing for any future residential development project occurs between February 1 and September 15, a
qualified biologist shall conduct a nesting bird survey no more than 3 days prior to commencement of
activities to confirm the absence of nesting birds. With implementation of Mitigation Measure BIO-1, potential
impacts to nesting birds would be less than significant.
Biological Resource Policies
The Project site is urban and developed and contains no biological resources to be preserved under the
resource protection policies of the City's General Plan. Article 7, Chapter 3 of the Municipal Code addresses
the protection of "trees, plants or shrubs in or growing upon or over any public parkway street, highway,
alley, right-of-way, City -owned property in the City." The Project would not impact any such trees and
shrubs. To the extent that future development facilitated by the Project is required to plant new trees on
public property pursuant to Section 7308 of Article 7, Chapter 3, the Project would be required to comply
with the Municipal Code requirements as part of the City permitting process (PPP B10-1). As a result, impacts
would be less than significant.
Adopted Habitat Conservation Plan
The Project site does not contain any natural lands that are subject to an adopted Habitat Conservation Plan,
Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan.
Therefore, the Project would not result in impacts to biological habitat or conservation plans.
City of Tustin 7-3
Draft EIR
June 2024
Enderle Center Rezone
7. Effects Found Not
PPP BI0-1 Street Trees. Installation of street trees shall occur in compliance with the City of Tustin
Municipal Code Article 7, Chapter 3, Section 7308.
MM 13I0-1 Migratory Bird Treaty Act. Prior to commencement of grading activities, the City Building
Division shall verify that, in the event that vegetation and tree removal activities occur within
the active breeding season for birds (February 1—September 15), the Project applicant (or
their Construction Contractor) shall retain a qualified biologist (meaning a professional
biologist that is familiar with local birds and their nesting behaviors) to conduct a nesting
bird survey no more than 3 days prior to commencement of construction activities.
The nesting survey shall include the Project site and areas immediately adjacent to the site
that could potentially be affected by Project -related construction activities, such as noise,
human activity, and dust, etc. If active nesting of birds is observed within 100 feet of the
designated construction area prior to construction, the qualified biologist shall establish an
appropriate buffer around the active nests (e.g., as much as 500 feet for raptors and 300
feet for non -raptors [subject to the recommendations of the qualified biologist]), and the
buffer areas shall be avoided until the nests are no longer occupied and the juvenile birds
can survive independently from the nests.
7.4 CULTURAL RESOURCES
Historical Resources
According to the results of the Cultural Records Search prepared by Brian F. Smith and Associates
Environmental Services (BFSA) for the Project, the Project site does not contain any historical resources.
Additionally, the area proposed for future implementation of residential land uses pursuant to the Housing
Element is the existing parking lot, which does not contain any structures that could become historical in the
future. Therefore, the Project would result in no impact on a historical resource.
Archaeological Resources
According to results of the cultural record search prepared for the Project, the Project site does not contain
any archaeological resources. The Project site is currently developed as a commercial site and is surrounded
by other commercial developments. Therefore, the Project site is heavily disturbed and does not currently
contain any native undisturbed soils. However, the Project could facilitate future construction at depths
greater than previous excavation activities, which could result in the disturbance of undisturbed native soils.
Therefore, there is a low potential that future construction could result in inadvertent discovery of a buried
archeological resource. Mitigation Measure CUL-1 has been incorporated to mitigate any potential impact
to an archeological resource. In the event of an inadvertent discovery of a buried archeological resource,
work shall cease within 50 feet of the find until a qualified archaeologist from the City or County List of
Qualified Archaeologists has evaluated the find to determine whether the find constitutes a "unique
archaeological resource", and if the discovered resource(s) appears Native American in origin, a Native
American Monitor shall be contacted to evaluate any potential tribal cultural resource(s) and shall have the
opportunity to consult on appropriate treatment and curation of these resources. Prior to the issuance of any
permits for ground -disturbing activities that include the excavation of soils (including as grading, excavation,
and trenching), the City of Tustin shall ensure that all Project grading and construction plans and specifications
include requirement to halt construction activity and contact an archaeologist.
The City has detailed standards and requirements for grading that are designed to protect sensitive
topographic, soil, palaeontologic, and archaeologic resources. The Tustin Grading Manual prescribes
appropriate measures to protect the earth by controlling erosion, sedimentation, and storm drainage (PPP
City of Tustin 7-4
Draft EIR
June 2024
Enderle Center Rezone Proiect 7. Effects Found Not
HYD-2). Proper grading, soil management, and open space standards will work to preserve any potential
archaeological resources in the unlikely event that a resource is encountered. Therefore, the Project would
result in a less than significant impact with mitigation on archeological resources.
Human Remains
The Project site has been previously disturbed, as described above, and has not been previously used as a
cemetery. Thus, human remains are not anticipated to be uncovered during project construction. In addition,
California Health and Safety Code Section 7050.5, CEQA Section 15064.5, and Public Resources Code
Section 5097.98 (included as PPP CUL-1) mandate the process to be followed in the event of an accidental
discovery of any human remains. Specifically, California Health and Safety Code Section 7050.5 requires
that if human remains are discovered, disturbance of the site shall remain halted until the coroner has
conducted an investigation into the circumstances, manner, and cause of death, and made recommendations
concerning the treatment and disposition of the human remains to the person responsible for the excavation,
or to his or her authorized representative, in the manner provided in Section 5097.98 of the Public Resources
Code. If the coroner determines that the remains are not subject to his or her authority and if the coroner has
reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone
within 24 hours, the Native American Heritage Commission. Compliance with existing law would ensure that
significant impacts to human remains would not occur through the implementation of future construction
facilitated by the Project.
PPP CUL-1 Human Remains. In the event that human remains are encountered on the Project site, work
within 50 feet of the discovery shall cease and the County Coroner shall be notified
immediately consistent with the requirements of California Code of Regulations (CCR)
Section 15064.1). State Health and Safety Code Section 7050.5 states that no further
disturbance shall occur until the County Coroner has made a determination of origin and
disposition pursuant to Public Resources Code (PRC) Section 5097.98. Prior to the issuance
of grading permits, the City Community Department Director, or designee, shall verify that
all grading plans specify the requirements of CCR Section 15064.5(e), State Health and
Safety Code Section 7050.5, and PRC Section 5097.98, as stated above.
PPP HYD-2 City of Tustin Grading Manual. All future projects are required to comply with the City of
Tustin Grading Manual (1990). Implementation of grading manual standards would be
verified by the City during the plan check and permitting process.
MM CUL-1 Inadvertent Discovery. In the event that potential archaeological resources are discovered
during excavation, grading, or construction activities, work shall cease within 50 feet of the
find until a qualified archaeologist from the City or County List of Qualified Archaeologists
has evaluated the find to determine whether the find constitutes a "unique archaeological
resource," as defined in Section 21083.2(g) of the California Public Resources Code. Any
resources identified shall be treated in accordance with California Public Resources Code
Section 21083.2(g).
If the discovered resource(s) appears Native American in origin, a Native American Monitor
shall be contacted to evaluate any potential tribal cultural resource(s) and shall have the
opportunity to consult on appropriate treatment and curation of these resources. The
discovery would also be reported to the City and the South Central Coastal Information
Center (SCCIC).
Prior to the issuance of any permits for ground -disturbing activities that include the
excavation of soils (including as grading, excavation, and trenching), the City of Tustin shall
City of Tustin 7-5
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June 2024
Enderle Center Rezone
7. Effects Found Not
ensure that all Project grading and construction plans and specifications include requirement
to halt construction activity and contact an archaeologist as specified above.
7.5 GEOLOGY AND SOILS
Fault Rupture
According to the California Geological Survey available fault maps, the Project is approximately 10 miles
to the south of the nearest A-P fault, Whitter Fault (Parrish, Earthquake Zones of Required Investigation,
Yorba Linda Quadrangle, 2015). The Project is also approximately 11 miles to the north of the North Branch
Fault (Parrish, Earthquake Zones of Required Investigation, Seal Beach Quadrangle, 1999). Due to the
location of these faults, the general region is subject to the potential for earthquakes; however, the Project
site is outside of a 500-foot radius from an active fault and is not subject to a special development permit.
The Project site contains existing development, and the provision for additional development would not
exacerbate existing risk of earthquake. Further, all future development permitted would be required to
comply with the requirement of the California Building Code (CBC) (California Code of Regulations, Title 24,
Part 2) (PPP GEO-1), which is a minimum requirement intended to protect life safety and prevent collapse
of structures. Therefore, the Project would result in a less -than -significant impact.
Ground Shaking
Due to the Project's location within a seismically active region of Southern California, moderate to strong
ground shaking can be expected at the Project site. However, as described above, structures built in the City
are required to be built in compliance with the CBC (California Code of Regulations, Title 24, Part 2) which
provides provisions for earthquake safety based on factors including building occupancy type, the types of
soils onsite, and the probable strength of ground motion. Implementation of CBC standards would be verified
by the City during the plan check and permitting process (PPP GEO-1). Therefore, because the proposed
Project would be constructed in compliance with the CBC, the proposed Project would result in a less -than -
significant impact related to strong seismic ground shaking.
Liquefaction
According to the California Geological Survey available fault maps, the Project is approximately 1.25 miles
from the nearest liquefaction zone in the City of Orange (Parrish, Earthquake Zones of Required
Investigation, Orange Quadrangle, 1998). The southern portion of Tustin is also identified as partially within
a liquefaction zone. Additionally, all future projects implemented through the proposed housing overlay
would be required to conduct a project -specific geotechnical investigation to ensure that the site's soils are
adequate for the construction and operation of the proposed project. Future projects would be required to
implement measures identified within the project -specific geotechnical investigation (MM GEO-1). The Project
site is outside of a liquefaction zone and would be required to conduct project -specific geotechnical
investigations at the time that the project is proposed; therefore, the Project would result in a less -than -
significant impact with mitigation.
Landslides
The Project site is currently fully developed with commercial and office uses. The Project site is flat and is not
adjacent to or within the vicinity of steep slopes or other landforms susceptible to landslides. No development
is proposed as part of this Project. The provision of future residential development would not result in new
risk of loss, injury, or death involving a landslide. Therefore, the Project would result in no impact.
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Enderle Center Rezone
7. Effects Found Not
Soil Erosion
All proposed future development would be required to comply with the California Regional Water Quality
Control Board (RWQCB) Order No. R8-2010-0033, National Pollutant Discharge Elimination System
(NPDES) Permit No. CAS61 8033 — Construction General Permit requirements (PPP HYD-1). Requirements
include installation of Best Management Practices (BMPs), which establishes minimum stormwater
management requirements and controls. To reduce the potential for soil erosion and the loss of topsoil, a
Stormwater Pollution Prevention Plan (SWPPP) is required by the RWQCB regulations to be developed by
a QSD (Qualified SWPPP Developer). The SWPPP is required to address site -specific conditions related to
specific grading and construction activities. The SWPPP would identify potential sources of erosion and
sedimentation to prevent loss of topsoil during construction, and to identify erosion control BMPs to reduce
or eliminate the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel bags; stabilized
construction entrances/exits; hydroseeding, and similar measures. In addition to RWQCB requirements,
proposed development would need to comply with the City of Tustin Grading Manual procedures (PPP HYD-
2). The City of Tustin Grading Manual is a compilation of rules, procedures, and interpretations necessary to
carry out the provisions of the Tustin City Code relating to grading and excavation.
Following construction, future development would be required to prepare and implement a Water Quality
Management Plan (WQMP) per City standards. Future projects would be required to comply with the
requirements of the Orange County Drainage Area Management Plan (DAMP) and the intent of the non -
point source NPDES Permit for Waste Discharge Requirements for the County of Orange, Orange County
Flood Control District (OCFCD) and the incorporated cities of Orange County within the Santa Ana Region
(included as PPP HYD-3).
The DAMP regulations are included in the City's Municipal code in Section 4902 and are the implementation
method for NPDES Stormwater Permit compliance. The DAMP requires that new development and significant
redevelopment projects develop and implement a water quality management plan (WQMP) that includes
BMPs and low impact development (LID) design features that would provide onsite treatment of stormwater
to prevent pollutants from onsite uses from leaving the site. These requirements would ensure that future
projects would not result in substantial soil erosion or the loss of topsoil. With implementation of uniformly
applicable requirements (SWPPP, City of Tustin Grading Manual, and the DAMP), the Project would result
in a less -than -significant impact.
On- or Offsite Landslide, Lateral Spreading, Subsidence, Liquefaction, or Collapse
As described above, the Project site is located in a relatively flat, developed, urban area that does not
contain or adjacent to large slopes, and the Project would not generate large slopes. Therefore, impacts
related to landslides would not occur.
As discussed above, the Project site is outside of a zone identified as susceptible to liquefaction. Further, the
Project site then has a low potential for lateral spreading. However, all future projects implemented through
the proposed housing overlay would be required to conduct a project -specific geotechnical investigation to
ensure that the site's soils are adequate for the construction and operation of the proposed project. Future
projects would be required to implement measures identified within the project -specific geotechnical
investigation as specified in MM GEO-1.
According to the U.S. Geological Survey (USGS) Areas of Subsidence in California Map, the Project site is
within an area of subsidence as a result of excessive groundwater pumping (United States Geological
Survey, 2023). As such, all future projects implemented through the proposed housing overlay would be
required to conduct a project -specific geotechnical investigation to ensure that the site's soils are adequate
for the construction and operation of the proposed project as specified in MM GEO-1.
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Enderle Center Rezone Proiect 7. Effects Found Not
Therefore, the Project would result in a less -than -significant impact with mitigation related to the risk of
landslide, lateral spreading, subsidence, liquefaction, or collapse.
Expansive Soils
No development is proposed as part of this Project. All future projects would be required to comply with
applicable federal, State, and local policies and regulations established to prevent or reduce impacts due
to expansive soil, including Policy 8.5 of the Conservation/Open Space/Recreation Element of the City's
General Plan, which requires City review of threats from expansive soils during the development review
process (PPP GEO-2). Further, if necessary, geological investigations would be prepared and implemented
for each future project to reduce significant impacts (MM GEO-1). Therefore, the project would result in a
less -than -significant impact with mitigation.
Alternative Waste Disposal Systems
All future development would be served by the City sewer utilities and would not include the use of septic
tanks or alternative wastewater disposal systems. Therefore, the Project would result in no impact related to
alternative waste disposal systems.
Paleontological Resources
The Project site is currently developed as a commercial site and is surrounded by other commercial
developments. Therefore, the Project site is heavily disturbed and does not contain any native undisturbed
soils. However, the Project could facilitate future construction at depths greater than previous excavation
activities, which could result in the disturbance of undisturbed native soils. According to the City's
Conservation/Open Space/Recreation Element, the Project site is not located in an area identified by the
General Plan as "High Paleontological Sensitivity." (City of Tustin, 2018). Further, the City has detailed
standards and requirements for grading that are designed to protect sensitive topographic, soil,
palaeontologic, and archaeologic resources (PPP HYD-2). Proper grading, soil management, and open space
standards would work to preserve any potential paleontological resources in the unlikely event that a
resource is encountered. Therefore, the Project would result in a less -than -significant impact on a
paleontological resource, site, or geologic feature.
Plans, Policies, and Programs
PPP GEO-1 CBC Title 24, Part 2. Structures built in the City are required to be built in compliance with
the CBC (California Code of Regulations, Title 24, Part 2) that provides provisions for
earthquake safety based on factors including building occupancy type, the types of soils
onsite, and the probable strength of ground motion. Compliance with the CBC would require
the incorporation of 1) seismic safety features to minimize the potential for significant effects
as a result of earthquakes; 2) proper building footings and foundations; and 3) construction
of the building structure so that it would withstand the effects of strong ground shaking.
Implementation of CBC standards would be verified by the City during the plan check and
permitting process.
PPP GEO-2 Policy 8.5 of the Conservation/Open Space/Recreation Element. Project applicants would
be required to submit applications for building and grading permits, and applications for
subdivision for adjacency to, threats from, and impacts on geological hazards arising from
seismic events, landslides, or other geologic hazards such as expansive soils and subsidence
areas, which would be reviewed by the City during plan check.
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Enderle Center Rezone
7. Effects Found Not
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide
the City Building Division evidence of compliance with the NPDES (National Pollutant
Discharge Elimination System) requirement to obtain a construction permit from the State
Water Resource Control Board (SWRCB). The permit requirement applies to grading and
construction sites of one acre or larger. The Project applicant/proponent shall comply by
submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater
Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the
construction site.
PPP HYD-2 City of Tustin Grading Manual. All future projects are required to comply with the City of
Tustin Grading Manual (1990). Implementation of grading manual standards would be
verified by the City during the plan check and permitting process.
PPP HYD-3 WOMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a
completed Water Quality Management Plan (WQMP) shall be prepared by the Project
applicant and submitted to and approved by the City Public Works Department. The
WQMP shall identify all Post -Construction, Site Design, Source Control, and Treatment
Control Best Management Practices (BMPs) that will be incorporated into the development
Project to minimize the adverse effects on receiving waters.
Mitigation Measures (MM)
MM GEO-1 All future projects implemented through the proposed housing overlay would be required
to conduct a project -specific geotechnical investigation to ensure that the site's soils are
adequate for the construction and operation of the proposed project. Future projects would
be required to implement measures identified within the project -specific geotechnical
investigation.
7.6 HAZARDS AND HAZARDOUS MATERIALS
Routine Transport, Use, or Disposal of Hazardous Materials
Construction: Future construction activities could involve the transport, use, and disposal of hazardous
materials such as paints, solvents, oils, grease, and caulking. In addition, hazardous materials could be
needed for fueling and servicing construction equipment on the site. These types of materials are not acutely
hazardous, and all storage, handling, use, and disposal of these materials are regulated by federal and
State requirements that are implemented by the City during building permitting for construction activities.
These regulations include: the federal Occupational Safety and Health Act and Hazardous Materials
Transportation Act; Title 8 of the California Code of Regulations (CalOSHA), and the State Unified
Hazardous Waste and Hazardous Materials Management Regulatory Program. As a result, routine transport
and use of hazardous materials during construction would be consistent with applicable regulations and
would be less than significant.
Operation: The Project involves the provision for future development of up to 413 housing units, which involve
routinely using household hazardous materials including solvents, cleaning agents, paints, pesticides,
batteries, fertilizers, and aerosol cans. These types of materials are not acutely hazardous and would only
be used and stored in limited quantities. The normal routine use of these products pursuant to existing
regulations would not result in a significant hazard to people or the environment in the vicinity of the Project.
Additionally, the Project would create a mixed -use environment in which residential land uses would be
introduced into existing commercial land use (the Enderle Center). Existing commercial uses include a mix of
office, restaurant, and retail establishments. Existing commercial uses require the routine use of similar
hazardous materials as residential land uses (solvents, cleaning agents, paints, pesticides, batteries,
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June 2024
Enderle Center Rezone Proiect 7. Effects Found Not
fertilizers, and aerosol cans) and would not impose additional hazards to potential future residential uses.
Therefore, operation of the Project would not result in a significant hazard to the public or to the environment
through the routine transport, use, or disposal of hazardous waste, and impacts would be less than significant.
Release of Hazardous Materials into the Environment
Construction: To avoid an impact related to an accidental release, the use of BMPs during construction are
implemented as part of a SWPPP as required by the National Pollution Discharge Elimination System
General Construction Permit (and included as PPP HYD-1). All future development through implementation
of the housing overlay and the City's certified 2021-2029 Housing Element would be required to develop
and implement a SWPPP as required through NPDES. Therefore, construction of future development would
result in a less -than -significant impact.
Operation: As described previously, future operation of up to 413 residential units would include use of
limited hazardous materials, such as solvents, cleaning agents, paints, pesticides, batteries, fertilizers, and
aerosol cans. Normal routine use of typical residential products pursuant to existing regulations would not
result in a significant hazard to the environment, residents, or workers in the vicinity of the Project. As a result,
operation of the proposed Project would not create a reasonably foreseeable upset and accident condition
involving the release of hazardous materials into the environment, and impacts would be less than significant.
Hazardous Substances Within One -Quarter Mile of a School
The Project site is generally bounded on the north by 1711 Street; on the east by Enderle Center Drive, and
the eastern property line of properties fronting Enderle Center Drive; to the south by Vandenberg Lane;
and to the west by the 55 freeway, including properties west of Yorba Street. The nearest school, Loma
Vista Elementary School, is located approximately 2,100 feet to the east of the Project site. However, as
described previously, construction and operation of the Project could involve the use, storage, and disposal
of small amounts of hazardous materials on the Project site. These hazardous materials would be limited and
used and disposed of in compliance with federal, State, and local regulations, which would reduce the
potential for accidental release into the environment near a school. Therefore, the Project would not emit
hazardous or handle acutely hazardous materials, substances, or waste near a school, and impacts would
be less than significant.
Hazardous Materials Sites
The Project site is not located on a list of hazardous materials sites compiled pursuant to Government Code
Section 65962.5 (Department of Toxic Substances Control, 2023). Therefore, the Project would result in no
impact.
Airport Hazards
The nearest airport to the Project site is John Wayne Airport, located over 5.5 miles southwest of the Project
site. The Project site is not located within any land use compatibility zone for John Wayne Airport, nor is it
within an airport safety zone within the Airport Environs Land Use Plan (AELUP) (Orange County Airport Land
Use Commission, 2008). The Project's proximity to the airport would not result in potential safety hazards or
excessive noise for people that would reside or work within the Project site in the future. Therefore, the
Project would result in no impact.
Emergency Response Plan
The Project does not include proposed development and would not impair the implementation of evacuation
protocol in the event of an emergency within the City or Project site. Additionally, each future residential
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June 2024
Enderle Center Rezone Proiect 7. Effects Found Not
project implemented as part of the housing overlay and Housing Element would require a project -level plan
check with the City and would be reviewed by the City's fire department (Orange County Fire Authority) to
ensure proper emergency access to and from the site. Therefore, the Project would result in a less -than -
significant impact.
Wildfire Hazards
According to the CAL FIRE Fire Hazard Severity Zone Map, the Project site is not located within or near State
responsibility areas or lands classified as very high fire hazard severity zones (California Department of
Forestry and Fire Protection, 2023). Therefore, the Project would result in no impact regarding the exposure
of people or structures to risk of loss, injury, or death involving a wildland fire.
Plans, Policies, and Programs (PPP)
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide
the City Building Division evidence of compliance with the NPDES (National Pollutant
Discharge Elimination System) requirement to obtain a construction permit from the State
Water Resource Control Board (SWRCB). The permit requirement applies to grading and
construction sites of one acre or larger. The Project applicant/proponent shall comply by
submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater
Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the
construction site.
7.7 HYDROLOGY AND WATER QUALITY
Water Quality Standards
Construction: Potential water quality impacts during construction would be prevented through
implementation of a SWPPP (PPP HYD-1). Construction of the Project would disturb more than one acre of
soil; therefore, the proposed Project would be required to obtain coverage under the NPDES General Permit
for Discharges of Storm Water Associated with Construction Activity.
Adherence to the existing requirements and implementation of the appropriate BMPs, as ensured through
the City's plan check and permitting process, would ensure that the Project would not violate any water
quality standards or waste discharge requirements, potential water quality degradation associated with
construction activities would be minimized, and construction impacts would be less than significant.
Operation: Future development facilitated by the Project would include operation of residential uses.
Potential pollutants associated with the proposed uses include various chemicals from cleaners, pathogens
from pet wastes, nutrients from fertilizer, pesticides and sediment from landscaping, trash and debris, and
oil and grease from vehicles. If these pollutants discharge into existing stormwater systems, it could result in
further degradation of water quality. However, operation of the proposed Project would be required to
comply with the requirements of the Orange County Drainage Area Management Plan (DAMP) and the intent
of the non -point source NPDES Permit for Wast a Discharge Requirements for the County of Orange, Orange
County Flood Control District and the incorporated cities of Orange County within the Santa Ana Region
(included as PPP HYD-3). The DAMP regulations are included in the City's Municipal Code in Section 4902
and are the implementation method for NPDES Stormwater Permit compliance. The DAMP requires that new
development and significant redevelopment projects develop and implement a WQMP that includes BMPs
and LID design features that would provide onsite treatment of stormwater to prevent pollutants from onsite
uses from leaving the site. In addition, the City's permitting process would ensure that all BMPs in the WQMP
would be implemented with the project. Overall, implementation of the WQMP pursuant to the existing
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June 2024
Enderle Center Rezone Proiect 7. Effects Found Not
regulations (included as PPP HYD-3) would ensure that operation of the proposed Project would not violate
any water quality standards, waste discharge requirements, or otherwise degrade water quality, and
impacts would be less than significant.
Erosion or Siltation On- and Offsite
Construction: Construction of future development could result in a temporary disturbance of soils that could
cause erosion or siltation on- and off -site. However, all proposed development construction would be
required to comply with the California RWQCB Order No. R8-2010-0033, NPDES Permit No. CAS618033
— Construction General Permit requirements (PPP HYD-1). To reduce the potential for soil erosion and the
loss of topsoil, a SWPPP is required by the RWQCB regulations to be developed by a QSD. The SWPPP
would identify potential sources of erosion and sedimentation to prevent loss of topsoil during construction,
and to identify erosion control BMPs to reduce or eliminate the erosion and loss of topsoil, such as use of silt
fencing, fiber rolls, or gravel bags; stabilized construction entrances/exits; hydroseeding, and similar
measures. In addition to RWQCB requirements, proposed development would need to comply with the City
of Tustin Grading Manual procedures (PPP HYD-2).
Following construction, future development would be required to prepare and implement a WQMP per City
standards. Future projects would be required to comply with the requirements of the Orange County
Drainage Area Management Plan (DAMP) and the intent of the non -point source NPDES Permit for Waste
Discharge Requirements for the County of Orange, Orange County Flood Control District (OCFCD) and the
incorporated cities of Orange County within the Santa Ana Region (included as PPP HYD-3). The DAMP
requires that new development and significant redevelopment projects develop and implement a water
quality management plan (WQMP) that includes BMPs and low impact development (LID) design features
that would provide onsite treatment of stormwater to prevent pollutants from onsite uses from leaving the
site. These requirements would ensure that future projects would not result in substantial soil erosion or the
loss of topsoil. With implementation of uniformly applicable requirements (SWPPP, City of Tustin Grading
Manual, and the DAMP), the Project would result in a less -than -significant impact.
Operation
Changes due to development of the Project site could result in potential changes in the drainage pattern due
to siltation and erosion. However, the City's Municipal Separate Storm Sewer System (MS4) permit and
County DAMP require new development projects to prepare a WQMP (included as PPP HYD-3) that is
required to include BMPs to reduce the potential of erosion and/or sedimentation through site design and
structural treatment control BMPs. As part of the permitting approval process, the proposed drainage and
water quality design and engineering plans would be reviewed by the City's Engineering Division to ensure
that the site -specific design limits the potential for erosion and siltation. Overall, adherence to the existing
regulations would ensure that impacts as a result of future development related to alteration of a drainage
pattern and erosion/siltation from operational activities would be less than significant.
Surface Runoff
Future construction facilitated by the Project would require the demolition of existing pavement and
construction of building structures, including foundations, floor slabs, and utilities systems. These activities
could temporarily alter the existing drainage pattern of the site and change runoff flow rates. However, as
described previously, implementation of the Project requires a SWPPP (included as PPP WQ-1) that would
address site specific drainage issues related to construction of the Project and include BMPs to eliminate the
potential of flooding or alteration of a drainage pattern during construction activities. Compliance with the
Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-
1) as verified by the City through the construction permitting process would prevent construction -related
City of Tustin 7-1 2
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Enderle Center Rezone Proiect 7. Effects Found Not
impacts related to potential alteration of a drainage pattern or flooding on- or offsite from development
activities. Therefore, construction impacts would be less than significant.
Stormwater Drainage System
Construction: Construction of future development could result in a temporary disturbance of soils and the
use of construction equipment and materials that could increase pollutant loads discharged into stormwater
runoff. However, implementation of the Project requires a SWPPP (included as PPP HYD-1) that would
address site -specific pollutant and drainage issues related to construction of the Project and include BMPs to
eliminate the potential of polluted runoff and increased runoff during construction activities. This includes
regular monitoring and visual inspections during construction activities. Compliance with the Construction
General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD-1) as verified
by the City through the construction permitting process would prevent construction -related impacts related
to increases in run-off and pollution from development activities. Therefore, impacts would be less than
significant.
Operation: The Project site currently drains into the City's stormwater system via a series of culverts and
drains. Stormwater drains to the southeast corner of the site into a catch basin at the Vanderberg Lane and
Enderle Center Drive intersection. The storm drain then continues east and connects to the existing Orange
County Flood Control District (OCFCD) facility located between Enderle Center Drive and Prospect Avenue.
Because the site is currently almost entirely paved, future development would increase intensity of
development, but would not result in additional impervious surfaces that could increase the volume and
velocity of stormwater runoff. Therefore, future development would not be anticipated to exceed capacity
of the existing stormwater drainage system.
Additionally, as discussed previously, the City's MS4 permit and County DAMP require new development
projects to prepare a WQMP (included as PPP HYD-3) that is required to include BMPs to reduce the
potential of stormwater pollutants through site design and structural treatment control BMPs. As part of the
permitting approval process, the proposed drainage and water quality design and engineering plans would
be reviewed by the City's Engineering Division to ensure that the site -specific design limits the potential for
sources of polluted runoff. Overall, adherence to the existing regulations would ensure that impacts as a
result of future development related to stormwater runoff would be less than significant.
Flood Flows
The Project site is currently completely developed and completely paved, with the exception of some
ornamental landscaped areas. Future development would not result in additional impervious surfaces that
could increase the volume and velocity of stormwater runoff that would exacerbate flood conditions.
Therefore, the Project would result in a less -than -significant impact.
Flood Hazard, Tsunami, or Seiche Zones
According to the Federal Emergency Management Agency (FEMA) Map 06059COI64J, the Project site is
within Flood Zone X, or the 0.2 percent annual change flood area, areas of 1 percent annual chance flood
with average depth less than 1 foot or with drainage areas of less than 1 square mile (Federal Emergency
Management Agency, 2009). The site is not within a special flood hazard area.
The Project site is not located near an inland body of water that could result in impacts due to seiche. The
Pacific Ocean is located over 12 miles southwest of the Project site; consequently, there is no potential for
the Project site to be inundated by a tsunami that could release pollutants. In addition, the Project site is flat
and not located near any steep hillsides; therefore, there is no potential for the site to be adversely affected
by muciflow. Thus, implementation of the proposed Project would not expose people or structures to a
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Enderle Center Rezone Proiect 7. Effects Found Not
significant risk of loss, injury, or death involving inundation by seiche, tsunami, or mudf low that could release
pollutants due to inundation of the Project site. No impact would occur.
Plans, Policies, and Programs (PPP)
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide
the City Building Division evidence of compliance with the NPDES (National Pollutant
Discharge Elimination System) requirement to obtain a construction permit from the State
Water Resource Control Board (SWRCB). The permit requirement applies to grading and
construction sites of one acre or larger. The Project applicant/proponent shall comply by
submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater
Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the
construction site.
PPP HYD-2 City of Tustin Grading Manual. All future projects are required to comply with the City of
Tustin Grading Manual (1990). Implementation of grading manual standards would be
verified by the City during the plan check and permitting process.
PPP HYD-3 WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a
completed Water Quality Management Plan (WQMP) shall be prepared by the Project
applicant and submitted to and approved by the City Public Works Department. The
WQMP shall identify all Post -Construction, Site Design, Source Control, and Treatment
Control Best Management Practices (BMPs) that will be incorporated into the development
Project in order to minimize the adverse effects on receiving waters.
7.8 LAND USE AND PLANNING
Divide Established Community
The Project site is currently developed as a commercial center that includes restaurant, retail, and office uses.
The Project would include a GPA, CA, and rezone of the Project site with a Housing Overlay (HO) district to
allow for future development of up to 41 3 housing units, consistent with the City's certified 2021-2029
Housing Element. The Project does not propose development; however, the Project would provide for future
proposed development through implementation of the housing overlay and the City's certified 2021 -2029
Housing Element. Implementation of the Project would allow for the intensification of the existing site;
however, the introduction of residential land uses would not result in division of an established community.
Therefore, the Project would result in no impact.
7.9 MINERAL RESOURCES
The Project site is not identified for mineral resource extraction per the City's General Plan Conservation
Element (City of Tustin, 2018). Therefore, the Project would result in no impact on the loss of availability of
a known mineral resource or a locally important mineral resource recovery site.
7.10 POPULATION AND HOUSING
Displacement of People or Housing
The Project would include land use changes to allow for the future development of up to 413 housing units,
consistent with the City's certified 2021-2029 Housing Element, within an existing commercial land use.
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June 2024
Enderle Center Rezone Proiect 7. Effects Found Not
Therefore, the Project would not result in the displacement of existing people or housing and there would be
no impact.
7.11 WILDFIRE
The Project site is currently developed as a commercial site and is surrounded by other commercial
developments. According to the CalFire Fire Hazard Severity Zone Map, the City of Tustin contains very high
fire severity zones in the northeast portion of the City (California Department of Forestry and Fire Protection,
2023). The Project site is not located within or near State responsibility areas or lands classified as very high
fire hazard severity zones. Therefore, the project would result in no impact due to wildfire hazard.
7.12 REFERENCES
California Department of Conservation. (2018, November 1). DOC Maps: Division of Land Resource
Protection. Retrieved November 6, 2023, from California Important Farmland Finder:
https://maps.conservation.ca.gov/DLRP/CIFF/
California Department of Forestry and Fire Protection. (2023, December 19). CalFire Hazard Severity Zone
Viewer. Retrieved from Fire and Resource Assessment Program: https://egis.fire.ca.gov/FHSZ/
California Department of Transportation. (2018). California State Scenic Highway System Map. Retrieved
from
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd 3d807c46cc8e805
7116fIaacaa
California Waterboards. (2023). California 2078 Integrated Report Map. Retrieved from California 2018
Integrated Report: https://www.waterboards.ca.govHeader Control lerCalifornia 2018 Integrated
Report
City of Tustin. (2018, November). City of Tustin General Plan. Retrieved from
https://www.tustinca.Org/DocumentCenter/View/71 3/City-of-Tustin-General-Plan-PDF
County of Orange. (2005, April). County of Orange General Plan. Retrieved from Chapter IV Scenic
Highway Plan Map:
https://ocds.ocpublicworks.com/sites/ocpwocds/files/import/data/files/8588.pdf
Department of Toxic Substances Control. (2023, December 22). Hazardous Waste and Substances Sites List.
Retrieved from Envirostar: https://www.envirostor.dtsc.ca.gov/public/
Federal Emergency Management Agency. (2009, December 3). Map Number 06059C0161 J. Retrieved
from Federal Insurance Rate Map: https://msc.fema.gov/portal
Federal Emergency Management Agency. (2009, December 3). Map Number 06059C0I64J. Retrieved
from Federal Insurance Rate Map:
https://msc.fema.gov/portal/search?AddressQuery=enderle%20center%2C%20tustin%2C%20ca
Orange County Airport Land Use Commission. (2008, April 17). Land Use Plan for John Wayne Airport.
Retrieved from Orange County Airport Land Use Commission:
https://files.ocair.com/media/2021-02/JWA_AELUP-April-l7-
2008.pdf?Versionld=cBObyJjdad9OuY5im7Oaj5aWaT1 FS.vD
Parrish, J. G. (1998, April 15). Earthquake Zones of Required Investigation, Orange Quadrangle. Retrieved
from California Geological Survey: https://maps.conservation.ca.gov/cgs/EQZApp/app/
City of Tustin 7-15
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June 2024
Enderle Center Rezone
7. Effects Found Not
Parrish, J. G. (1999, March 25). Earthquake Zones of Required Investigation, Seal Beach Quadrangle.
Retrieved from California Geological Survey:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
Parrish, J. G. (2001, January 17). Earthquake Zones of Required Investigation, Tustin Quadrangle. Retrieved
from California Geological Survey: https://maps.conservation.ca.gov/cgs/EQZApp/app/
Parrish, J. G. (2015, December 4). Earthquake Zones of Required Investigation, Yorba Linda Quadrangle.
Retrieved from California Geological Survey:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
United States Geological Survey. (2023, December 19). Areas of Land Usbsidence in California. Retrieved
from USGS: https://ca.water.usgs.gov/land subsidence/california-subsidence-areas.html
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Enderle Center Rezone
8. Alternatives
8. Alternatives
8.1 INTRODUCTION
The identification and analysis of alternatives to a project is a fundamental part of the environmental review
process pursuant to CEQA. Public Resources Code (PRC) Section 21002.1(a) establishes the need to address
alternatives in an EIR by stating that in addition to determining a project's significant environmental impacts
and indicating potential means of mitigating or avoiding those impacts, "the purpose of an environmental
impact report is to identify alternatives to the project."
Pursuant to CEQA Guidelines Section 15126.6(a), an EIR must describe a reasonable range of alternatives
to the proposed project or to the project's location that would feasibly avoid or lessen its significant
environmental impacts while attaining most of the proposed project's objectives. CEQA Guidelines Section
151 26.6(b) emphasizes that the selection of project alternatives be based primarily on the ability to reduce
impacts relative to the proposed project. In addition, CEQA Guidelines Section 151 26.6(e)(2) requires the
identification and evaluation of an "Environmentally Superior Alternative".
Pursuant to CEQA Guidelines Section 151 26.6(d), discussion of each alternative presented in this EIR Section
is intended "to allow meaningful evaluation, analysis, and comparison with the proposed project." As
permitted by CEQA, the significant effects of each alternative are discussed in less detail than those of the
proposed Project, but in enough detail to provide perspective and allow for a reasoned choice among
alternatives to the proposed Project.
In addition, the "range of alternatives" to be evaluated is governed by the "rule of reason" and feasibility,
which requires the EIR to set forth only those alternatives that are feasible and necessary to permit an
informed and reasoned choice by the lead agency and to foster meaningful public participation (CEQA
Guidelines Section 15126.6(f)). CEQA generally defines "feasible" to mean an alternative that is capable
of being accomplished in a successful manner within a reasonable period of time, taking into account
economic, environmental, social, technological, and legal factors and other considerations (CEQA Guidelines
Sections 15091(a)(3), 15364).
Based on the CEQA requirements described above, the alternatives addressed in this EIR were selected in
consideration of one or more of the following factors:
• The extent to which the alternative could avoid or substantially lessen any of the identified significant
environmental effects of the proposed Project;
• The extent to which the alternative could accomplish the objectives of the proposed Project;
• The potential feasibility of the alternative;
• The appropriateness of the alternative in contributing to a "reasonable range" of alternatives that would
allow an informed comparison of relative advantages and disadvantages of the proposed Project and
potential alternatives to it; and
• The requirement of the CEQA Guidelines to consider a "no project" alternative; and to identify an
"environmentally superior" alternative in addition to the no project alternative (CEQA Guidelines Section
15126.6(e)).
Neither the CEQA statute, the CEQA Guidelines, nor recent court cases specify a specific number of
alternatives to be evaluated in an EIR. Rather, "the range of alternatives required in an EIR is governed by
the rule of reason that sets forth only those alternatives necessary to permit a reasoned choice" (CEQA
Guidelines 15126(f)).
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Enderle Center Rezone Project 8. Alternatives
8.2 SIGNIFICANT ENVIRONMENTAL EFFECTS
CEQA requires the alternatives selected for comparison in an EIR to avoid or substantially lessen one or more
significant effects of the Project being evaluated. This analysis evaluates both the potential to avoid or
reduce a significant and unavoidable impact, and to avoid the need for mitigation to obtain less than
significance levels.
The analysis in Chapter 5 of this Draft EIR determined that significant and unavoidable Project -specific and
cumulative air quality and greenhouse gas impacts would occur, as outlined below. Potentially significant
impacts of the Project related to noise, recreation, tribal cultural resources, and utilities can be mitigated to
a less than significant level.
8.2.1 Significant and Unavoidable Impact
Impact AQ-3 Expose sensitive receptors to substantial pollutant concentrations.
The results of the Localized Significance Thresholds (LST) analysis indicate that the Project would result in an
exceedance of the South Coast Air Quality Management District (SCAQMD) LST threshold for PM10 during
operation. The level of emissions from a project does not necessarily correspond to the concentrations of air
pollutants. A dispersion modeling analysis would be necessary to calculate health risk from project
implementation. Current scientific, technological, and modeling limitations prevent the relation of expected
adverse air quality impacts to likely health consequences. For this reason, it is not feasible to provide such
an analysis within this EIR.
Once a specific project is proposed, it would be required to conduct a site -specific localized impact analysis
that evaluates potential project health impacts at a project level relative to immediate adjacent land uses.
Mitigation Measure AQ-1 requires a project -specific assessment of potential localized impacts for future
projects and if future projects exceed the applicable LST thresholds, a dispersion modeling analysis would
be necessary to calculate health risk from project implementation. While Mitigation Measure AQ-1 would
serve to reduce localized emissions associated with buildout of the project, localized emission impacts would
remain significant and unavoidable.
Impact GHG-1 Generate greenhouse gas emissions that may have a significant impact on the
environment.
The Project assumes future buildout of 413 residential units and 118,474 square feet (SF) of additional
nonresidential uses (total buildout of 205,610 SF nonresidential uses). The proposed Project would be
anticipated to result in 12,804.0 MTCO2e of greenhouse gas (GHG) net new emissions (project build out
plus existing use) at full buildout, which exceeds the SCAQMD threshold of 3,000 MTCO2e that has been
applied to the Project. Therefore, the Project would result in a significant and unavoidable impact on Project -
level and cumulative GHG emissions. Mitigation Measure GHG-1 is included to require a project -specific
assessment of potential GHG impacts and implementation of feasible mitigation measures to reduce GHG
emissions for future projects allowed under the proposed Project. However, GHG impacts would remain
significant and unavoidable with implementation of Mitigation Measure GHG-1.
Impact GHG-2 Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing
the emissions of greenhouse gases.
Although the proposed Project would be consistent with the identified measures and goals from the CARB's
2022 Scoping Plan and SCAG's 2024-2050 RTP/SCS (Connect SoCal), the proposed Project would result
in a significant and unavoidable impact for GHG emissions based on SCAQMD thresholds. As such, the
proposed Project would not comply with existing State regulations adopted to achieve the overall GHG
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Enderle Center Rezone Proiect 8. Alternatives
emissions reduction goals identified in the 2022 Scoping Plan, EO B-30-15, and AB 197 and would not be
consistent with applicable State plans and programs designed to reduce GHG emissions. Therefore, the
proposed Project would conflict with applicable plans, policies, and regulations adopted for the purpose of
reducing the emissions of GHG and this impact would be significant and unavoidable.
8.2.2 Impacts Mitigated to Less than Significant
Impact NOI-1 Generate a substantial increase in ambient noise levels in the vicinity of the Project.
The Project and adjacent offsite land uses would be potentially exposed to stationary -source noise impacts
from the proposed onsite heating, ventilation, and air conditioning (HVAC) equipment and truck deliveries
and loading and unloading activities. It is expected that on -site stationary sources would meet the City of
Tustin maximum noise level standards. However, given that specific details related to stationary impacts of
future development within Enderle Center are not known at this time and will not be known until a
development project is proposed, Mitigation Measure NOI-1 is included. Mitigation Measure NOI-1 would
require all future development projects to prepare a project -specific Final Acoustical Report that identifies
any noise reduction features for the proposed development. With implementation of Mitigation Measure
NOI-1, noise impacts would be less than significant.
Impact TCR-1 Cause a substantial adverse change in the significance of a tribal cultural resource.
Project construction would include excavation at depths that could reach native, undisturbed soils that may
contain unknown tribal cultural resources. Project excavation and construction could result in impacts to
inadvertent tribal cultural resource finds that could cause substantial adverse change to the significance of
such resources. Mitigation Measures TCR-1, TCR-2, and TCR-3 were developed in coordination with the
Gabrieleno Band of Mission Indians — Kizh Nation and included in the Project. Future development associated
with the Project would be required to adhere to Mitigation Measures TCR-1, TCR-2, and TCR-3. Mitigation
Measure TCR-1 requires the retention of a Native American Monitor prior to of the issuance of a demolition
or grading permit for projects involving ground -disturbing activities; Mitigation Measure TCR-2 provides
procedures to follow in case of an inadvertent tribal cultural resource discovery; and Mitigation Measure
TCR-3 provides procedures to follow in case of an unanticipated discovery of human remains and associated
funerary or ceremonial objects. Implementation of Mitigation Measures TCR-1, TCR-2, and TCR-3 would
ensure that potential impacts a result of the inadvertent discovery of TCRs during future development would
be less than significant.
Impact UT-1 Require or result in the relocation or construction of new water facilities, or expansion of
existing facilities, the construction of which would cause significant environmental effects.
Future implementation of development projects as a result of the proposed Project would include installation
of onsite water infrastructure and new connections to the water distribution system. The new water
infrastructure and new connections would be sized to accommodate the increased water demand of new
project -specific development on a project -by -project basis. Water supply design specifications for each
future site -specific development project would be required to comply with the City of Tustin standards (per
the California Building Code) regarding requirements for design and operation of water distribution facilities
and would be verified during plan check (PPP UT- 1). In addition, Mitigation Measure UT-1 is included to
require future projects to coordinate with the City and prepare a capacity analysis of existing water utilities
in the area to ensure conveyance and pressure is adequate. The capacity analysis is required to be reviewed
and approved by the City prior to the approval of construction permits. With implementation of Mitigation
Measure UT-1, impacts would be less than significant.
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Enderle Center Rezone Proiect 8. Alternatives
Impact UT-3 Require or result in the relocation or construction of new wastewater facilities, or expansion
of existing facilities, the construction of which would cause significant environmental effects.
Future implementation of development projects as a result of the proposed Project would include installation
of onsite wastewater infrastructure and new connections to the wastewater distribution system. The new
wastewater infrastructure and new connections would be sized to accommodate the increased wastewater
demand of new project -specific development on a project -by -project basis. Wastewater supply design
specifications for each future site -specific development project would be required to comply with the City of
Tustin standards (per the California Building Code) regarding requirements for design and operation of
wastewater distribution facilities and would be verified during plan check (PPP UT-1). Additionally,
Mitigation Measure UT-2 is included to require future projects to coordinate with EOCWD and prepare a
capacity analysis of existing wastewater utilities in the area to ensure conveyance and pressure is adequate.
With implementation of Mitigation Measure UT-2, impacts would be less than significant.
Impact UT-4 Result in a determination by the wastewater treatment provider that would serve the Project
that it has adequate capacity to serve the Project's projected demand in addition to existing
commitments.
Wastewater from the Project Site is treated at OC San's wastewater treatment plant in Fountain Valley
(Plant No. 1). Plant No. 1 has a total rated primary capacity of 108 MGD and a secondary treatment
capacity of 80 MGD. Thus, the amount of wastewater that would be generated by the proposed Project is
less than 1 percent of Plant No. 1's total remaining daily treatment capacity. Mitigation Measure UT-2 is
incorporated into the Project to require future projects to coordinate with EOCWD and prepare a capacity
analysis of existing wastewater utilities in the area to ensure conveyance and pressure is adequate. The
capacity analysis is required to be reviewed and approved by EOCWD and the City prior to the approval
of construction permits. With implementation of Mitigation Measure UT-2, impacts would be less than
significant.
8.3 PROJECT OBJECTIVES
CEQA Guidelines §15124(b) (14 California Code of Regulations [CCR]) requires "A statement of objectives
sought by the proposed project. A clearly written statement of objectives would help the Lead Agency
develop a reasonable range of alternatives to evaluate in the EIR and would aid the decision makers in
preparing findings or a statement of overriding considerations, if necessary. The statement of objectives
should include the underlying purpose of the project." The primary purpose and goal of the Project is to
accommodate the City's 6th Cycle RHNA identified within the City of Tustin 2021-2029 Housing Element.
The Project would achieve this goal through the following objectives:
a. Creation of a Housing Overlay District to allow residential development at densities to achieve the
estimated capacities determined in the Housing Element and without inhibitors to residential
development.
b. Increase the number of housing opportunities available in Tustin to ensure the City provides its fair
share of housing units within a variety of income categories.
c. Increase flexibility in allowed uses and development potential in an underutilized area of the City
of Tustin.
d. Promote a diverse housing stock with products that are offered at a wide range of sizes and
affordability.
8.4 ALTERNATIVES CONSIDERED BUT REJECTED
Pursuant to State CEQA Guidelines Section 15126.6(c), an EIR must briefly describe the rationale for
selection and rejection of alternatives. The lead agency may make an initial determination as to which
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Enderle Center Rezone Proiect 8. Alternatives
alternatives are potentially feasible and, therefore, merit in-depth consideration, and which are infeasible
and need not be considered further. Alternatives that are remote or speculative, or the effects of which
cannot be reasonably predicted, need not be considered (State CEQA Guidelines Section 151 26.6(f), (f)(3)).
This section identifies alternatives considered by the lead agency but rejected as infeasible and provides a
brief explanation of the reasons for their exclusion. Alternatives may be eliminated from detailed
consideration in the Draft EIR if they fail to meet most of the project objectives, are infeasible, or do not
avoid any significant environmental effects.
Alternate Site Alternative. An alternate site for the Project was eliminated from further consideration. Any
alternate site would need to occur within the City of Tustin. The City is required by state law to rezone
housing shortfall sites according to what has been approved under the certified Housing Element
(Government Code § 65583.2, Senate Bill 197). The site identified within the City's 2021-2029 Housing
Element is Enderle Center (Project site), and an alternate site would fail to meet most of the project objectives,
is infeasible, and would not be compliant with state law or the City's Housing Element. Additionally, if the
Project were to occur on an alternate site and rezoning were conducted within a different commercial center
in the City, similar impacts would result and comparable mitigation would be required; therefore, impacts
would not be reduced under this alternative. Therefore, this alternative has been determined infeasible.
No Project/Buildout of Existing Land Use Alternative. Under this alternative, buildout of the nonresidential
uses would occur as permitted under the existing land use designations, but the Project site would not be
rezoned to allow for residential uses. This alternative was eliminated from further consideration. The City is
required by state law to rezone housing shortfall sites according to what has been approved under the
certified Housing Element (Government Code § 65583.2, Senate Bill 197). The site identified within the City's
2021-2029 Housing Element is Enderle Center (Project site) and failing to rezone the site for future housing
would fail to meet all of the project objectives, which would therefore render the alternative as infeasible,
and further, would not be compliant with state law or the City's Housing Element.
Reduced Project Development. The Reduced Project Development alternative would redesignate the Project
site to allow for development of future residential and additional square footage of nonresidential
development, similar to the proposed Project. However, Project buildout would be reduced by 20 percent
for residential and by 95 percent for new nonresidential; thereby limiting the overall future buildout to a
maximum of 330 residential units and a buildout of 91,923 SF nonresidential uses (including 4,787 SF of
additional nonresidential development and 87,136 SF of existing nonresidential development). This
alternative would still require approval of the Housing Overlay (HO) District, a General Plan Amendment
(GPA), adoption of a Zone Change (ZC), adoption of a zoning code amendment (CA), and development of
Objective Design Standards (ODS). This alternative would eliminate the Project's significant and unavoidable
GHG impact by reducing GHG emissions 77 percent, from 12,804 MT CO2e/yr. net new emissions (Project
buildout minus existing use) to 2,999 MT CO2e/yr, proportional to the proposed reduction in development.
However, under this alternative, only five percent of the additional nonresidential square footage (above
and beyond what is existing) currently allowed under existing provisions would be developed. Furthermore,
under this alternative, only 330 dwelling units would be allowed to be constructed and the City would have
an 83 dwelling unit deficit in meeting their state mandated RHNA fair share. Because this alternative would
not meet the City's legal obligation to rezone the site to meet the necessary residential capacity consistent
with the City's certified Housing Element Update, this alternative has been rendered infeasible and is rejected
from further consideration.
8.5 ALTERNATIVES SELECTED FOR FURTHER ANALYSIS
Two alternatives to the Project have been identified for further analysis as representing a reasonable range
of alternatives that attain most of the objectives of the Project, may avoid or substantially lessen any of the
significant effects of the Project, and are feasible from a development perspective. These alternatives have
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Enderle Center Rezone Proiect 8. Alternatives
been developed based on the criteria identified in Section 8.1. The following alternatives are further
described and analyzed in Section 8.6.
Alternative 1: No Project/No Development Alternative. This alternative consists of the Project not being
approved, and the Project site would remain in the conditions that existed at the time the Notice of
Preparation was published (February 16, 2024).
Alternative 2: Reduced Nonresidential Project Alternative. The Reduced Nonresidential Project alternative
would allow for the same potential future development of housing units to occur as proposed by the Project,
but limiting the buildout of nonresidential uses to 35 percent of the capacity in the General Plan. The Reduced
Nonresidential Project Alternative would allow for the potential future buildout of 413 residential units and
46,510 SF of new nonresidential development in addition to the existing shopping center. The reduced
nonresidential square footage would allow for increased setbacks, passenger vehicle parking, and truck
parking. Areas planned for physical impact would be identical to those required for development of the
proposed Project. This alternative would still require a General Plan Amendment (GPA), adoption of a Zone
Change (ZC) and a Zoning Code Amendment (CA), and development of Objective Design Standards (ODS).
8.6 ALTERNATIVE 1: NO PROJECT/NO DEVELOPMENT
Pursuant to State CEQA Guidelines Section 151 26.6(e), this Draft EIR is required to "discuss the existing
conditions at the time the Notice of Preparation is published, or if no notice of preparation is published, at
the time the environmental analysis is commenced, as well as what would be reasonably expected to occur
in the foreseeable future if the project were not approved, based on current plans and consistent with
available infrastructure and community services [... ] In certain instances, the no project alternative means `no
build' wherein the existing environmental setting is maintained."
The No Project/No Development Alternative allows decision -makers to compare the environmental impacts
of approving the proposed Project to the environmental impacts that would occur if the Project site were to
be left in its existing conditions for the foreseeable future. Under the existing conditions, the Project site is
currently developed with 87,136 SF of commercial business, including 28,750 SF of restaurant use, 39,960
SF of retail and service use, 18,426 SF of office use, and surface parking lots. The site also includes
ornamental landscaping along the perimeter and throughout the parking areas. Additional details and
figures regarding the existing conditions at the Project site are included in Section 4, Environmental Setting.
8.6.1 Environmental Impacts
Air Quality
Under this alternative no new development would occur in the Project site, and as such, no new stationary
sources of air pollution would be introduced. Although the Project's construction and operational air quality
emissions would be below applicable SCAQMD thresholds for VOCs, NOx, CO, SOx, and PM2.5, this
alternative would avoid the Project's less than significant impacts related to increase of these criteria
pollutants. In addition, this alternative would avoid the Project's significant and unavoidable impacts related
to exposure of sensitive receptors due to the Project's exceedance of the PMio LST during operations.
Therefore, the No Project/No Development Alternative would result in no impact and impact would be less
than the proposed Project.
Energy
No construction activities would occur at the Project site or operation of new structures that would increase
consumption of energy sources under this alternative. Existing commercial uses onsite would continue standard
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Enderle Center Rezone Proiect 8. Alternatives
operation and vehicles would continue to be used for traveling to and from the site. Electricity, gasoline, and
diesel fuel usage would all be lower for the existing commercial uses than for the Project. While this Draft
EIR determined the Project's impacts to energy would be less than significant, increased energy use
associated with this alternative would not occur. Therefore, the No Project/No Development Alternative
would result in less impacts than the proposed Project.
Greenhouse Gas Emissions
No new construction activities would occur at the Project site or operation of new structures that would
generate GHGs under this alternative. Under this alternative, no additional vehicle trips would be introduced
to the Project site, which is the source of most of the greenhouse gas emissions of the proposed Project as
discussed in Section 5.3, Greenhouse Gas Emissions. This alternative would be consistent with all applicable
air quality plans and would avoid the significant and unavoidable impact of greenhouse gas emissions that
would occur from the proposed Project. Therefore, the No Project/No Development Alternative would result
in less impacts than the proposed Project.
Land Use
This alternative would not result in new development, and as such, there would be no potential for land uses
to be introduced that would indirectly result in environmental impacts due to a conflict with an existing land
use plan. While the proposed residential use is not currently allowed by the land use designation of the site,
the existing use would continue to be allowed to operate and no new land uses would be introduced to the
site. Under this alternative no General Plan Amendment would be required. Overall, this alternative would
result in no impacts to land use and planning, and therefore, would be less than the Project's impacts.
Noise
Under this alternative, no development would occur onsite, and no new sources of noise would be introduced
at the Project site. Since no new development would occur and no additional traffic trips would be generated,
this alternative would not contribute to additional traffic noise. Mitigation necessary to ensure the Project
does not result in noise impacts on surrounding land uses would not be required under the No Project/No
Development alternative because no additional development would be proposed. In addition, this
alternative would not result in construction onsite and no construction noise or vibration would occur.
Therefore, this alternative would avoid the Project's less than significant impact and required mitigation
related to potential noise impacts of future development on surrounding land uses. Therefore, the No
Project/No Development Alternative would result in less impacts than the proposed Project.
Population and Housing
This alternative would not result in new development, and as such, would not result in induced growth or
displacement affecting population and housing. However, this alternative would also not result in the benefit
of adding new housing to the city, which would help result in a more balanced jobs -housing ratio.
Additionally, the No Project/No Development Alternative would not be consistent with Housing Element or
meet the SCAG and state -mandated fair share Regional Housing Needs Allocation (RHNA). The City would
be faced with severe penalties from the State. Therefore, the No Build Alternative could result in a significant
and unavoidable impact. Overall, this alternative would result in greater impacts than the Project.
Public Services
This alternative would not result in new development, and as such, would not result in increased demand for
public services such as fire and police services, school services, library services, or health services that require
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the new construction of public facilities. Therefore, while the Project's impacts would be less than significant
through compliance with regulatory programs, this alternative would result in less impacts.
Recreation
This alternative would not result in new development, and as such would not result in any new residences that
would potentially impact nearby parks or require the development of additional park facilities. However,
this alternative would also not result in the payment of the City's development impact fees when required
by the Tustin City Code. Therefore, while the Project's impacts would be less than significant with mitigation,
this alternative would result in less impacts.
Transportation
This alternative would not result in new development, and as such, would not result in any trips or traffic
related to operation of the Project site beyond vehicle trips associated with existing commercial operations.
This alternative would not impact existing transit service and alternative transportation facilities within the
Project site. The proposed Project would result in less than significant impacts related to VMT, geometric
hazards, and emergency access. As such, this alternative would result in less impacts than the proposed
Project.
Tribal Cultural Resources
Under this alternative, existing conditions would remain, and no new development would occur. No grading
would occur and there would be no potential impacts to tribal cultural resources that may be buried below
ground. Although mitigation would ensure that the Project would result in less than significant impacts on
tribal cultural resources, this alternative would avoid all potential impacts to tribal cultural resources, and no
mitigation measures would be required. Therefore, the No Project/No Development Alternative would result
in less impacts than the proposed Project.
Utilities and Service Systems
Under this alternative, existing conditions would remain, and no new development would occur. No additional
configurations or connections to existing domestic water, wastewater, stormwater drainage, electric power,
natural gas, or telecommunication facilities would be needed under this alternative, and there would be no
change in the demand for domestic water or wastewater treatment services. This alternative would also not
result in increased demand for solid waste collection and disposal. Selection of this alternative would result
in no impact to utilities and service system providers. While mitigation would ensure that the Project would
result in less than significant impacts, this alternative would avoid the need for mitigation, and no impacts
related to utilities and service systems would occur. Therefore, the No Project/No Development Alternative
would result in less impacts than the proposed Project.
8.6.2 Conclusion
Ability to Reduce Impacts
The No Project/No Development Alternative would result in continuation of the existing uses within the Project
site, and the proposed development would not occur. As a result, this alternative would avoid the need for
mitigation measures that are identified in Chapter 5.0 of this Draft EIR, which include measures related to
air quality, greenhouse gas emissions, noise, tribal cultural resources, and utilities. This alternative would also
avoid the significant and unavoidable impacts to air quality and greenhouse gases. However, this alternative
could result in a significant and unavoidable impact on population and housing due to noncompliance with
City of Tustin 8-8
Draft EIR
June 2024
Enderle Center Rezone Proiect 8. Alternatives
the City's certified Housing Element and the City's inability to meet its state mandated RHNA. This alternative
would result in lessened impacts to 10 of the 11 environmental topics analyzed in this Draft EIR (see Table
8-1).
However, the environmental benefits of the proposed Project would also not be realized, including providing
housing onsite that would result in a better jobs -housing balance in Tustin, which is currently considered jobs -
rich.
Ability to Achieve Project Objectives
As shown in Table 8-2, below, the No Project/No Development Alternative would not meet any of the Project
objectives. The purpose of the Project is to rezone the Project site to be consistent with the City Housing
Element Updated recently adopted by the City. The No Build Alternative would not result in rezoning to
allow residential development at densities to achieve the estimated capacities determined in the certified
Housing Element, and without inhibitors to residential development, such as overly stringent standards. It
would also not increase the number of housing opportunities available in Tustin, increase flexibility in allowed
uses and development potential in the City of Tustin or promote a diverse housing stock with a wide range
of sizes and affordability.
8.7 ALTERNATIVE 2: REDUCED NONRESIDENTIAL PROJECT ALTERNATIVE
Alternative 2: Reduced Nonresidential Project Alternative. The Reduced Nonresidential Project alternative
would allow for the potential future buildout of 413 residential units and 46,510 SF of new nonresidential
use over a maximum of 11.80 acres. The number of residential units and maximum acres would be the same
as the development assumption under the proposed Project, but with a decrease in total nonresidential use
of 35 percent. The total operational uses of this alternative, inclusive of existing Enderle Center uses, would
result in a buildout of 413 residential units and 133,641 SF of nonresidential uses.
The reduced nonresidential square footage would allow for increased setbacks, passenger vehicle parking,
and truck parking. Areas planned for physical impact would be identical to those required for development
of the proposed Project. Consistent with the proposed Project, specific infrastructure improvements are not
known at this time and would not be known until a development project is proposed. Future infrastructure
improvements may include roadways and utilities, drains, wastewater, water, and dry utilities. This
alternative would still require a General Plan Amendment (GPA), and adoption of a Zone Change (ZC) and
a Zoning Code Amendment (CA).
8.7.1 Environmental Impacts
Air Quality
Under this alternative, the same number of housing units (41 3) and approximately 35 percent less buildout
of nonresidential uses would be developed. Under this alternative, the intensity of construction would be
reduced as compared to the proposed Project, and overall emissions would be reduced with those identified
for the Project.
Operation of the proposed Project would result in 4.2 Ibs/day PMio, which exceeds the SCAQMD Localized
Significance Thresholds (LST) of 3.0 Ibs/day for Mo. The majority of PM10 emissions from the Project are
associated with mobile sources from Project -related vehicle trips. PMio emissions from the 413 residential
units alone are 0.65 Ibs/day, and PM10 emissions from nonresidential uses are 3.5 Ibs/day.
A reduction of 35 percent building area for nonresidential uses would reduce nonresidential PM10 emissions
to 2.3 Ibs/day. As such, operational PM10 emissions under this alternative would total 2.95 Ibs/day, inclusive
City of Tustin 8-9
Draft EIR
June 2024
Enderle Center Rezone Proiect 8. Alternatives
of 0.65 Ibs/day from residential and 2.3 Ibs/day from nonresidential, which is below the SCAQMD LST
threshold of 3.0 Ibs/day. Therefore, this alternative's operational impact on air quality emissions would be
less than the Project's significant and unavoidable impacts and would be less than significant. No mitigation
measures would be required under this alternative.
Energy
Under this alternative, the Project site would be developed with 413 residential units and 46,510 SF new
nonresidential development (for a total buildout of 133,641 SF of nonresidential development). Under this
alternative, the intensity of construction would be less than the proposed Project because construction time
would be reduced due to a reduction of nonresidential square footage. Furthermore, operational energy
demand would also be less than the Project because of a reduction in nonresidential uses. Overall, energy
demand would be reduced under this alternative during construction and operation. Therefore, the Reduced
Nonresidential Project alternative would continue to result in a less than significant impact and would be less
than Project impacts.
Greenhouse Gas Emissions
Under the Reduced Nonresidential Project alternative, approximately 35 percent less nonresidential
development would occur within the Project site. Therefore, a reduced volume of construction activities and
related production of GHG emissions would occur. In addition, the reduced amount of development by this
alternative would result in less stationary source emissions from onsite equipment, and less traffic associated
GHG emissions than the proposed Project. Therefore, the overall volume of GHG emissions would be reduced
in comparison to the proposed Project.
A majority of operational emissions under this alternative would be from nonresidential uses, and residential
uses would result in a negligible amount of GHG emissions. The proposed Project total buildout would result
in an annual emissions of 19,891 MTCO2e/yr., inclusive of 7,138 MTCO2e/yr. from existing uses. As such,
it is expected that GHG emissions from this alternative would be less as compared to the proposed Project,
but would continue to exceed the screening threshold of 3,000 MTCO2e/yr. Like the Project, this alternative
would implement Mitigation Measure GHG-1 that requires future project applicant to prepare a technical
assessment that evaluates potential project -related GHG impacts; and to incorporate mitigation measures
to reduce GHG emissions, if applicable. As such, consistent with the proposed Project, the Reduced
Nonresidential Project Alternative would result in a significant and unavoidable impact on GHG, but this
impact would be less than the Project.
Land Use
Under this alternative, the 1 1.80-acre site would be developed with 413 residential units and 46,510 SF of
new nonresidential development (for a total buildout of 133,641 SF nonresidential development). Consistent
with the Project, a GPA, ZC and CA would be required to accommodate residential uses within the Project
site. The GPA and ZC would require the City to establish a limit ("cap") on the amount of commercial
development that is currently authorized under the General Plan. This alternative would be similar in that it
would be consistent with all applicable plans and policies and would result in similar development as the
Project and meet all applicable Project initiatives. The Reduced Nonresidential Project Alternative would be
subject to the same goals, policies, programs, and regulations as the Project. Therefore, the Reduced
Nonresidential Project Alternative would result in similar less than significant impacts as the proposed Project.
City of Tustin 8-10
Draft EIR
June 2024
Enderle Center Rezone
8. Alternatives
Noise
Under this alternative, the southern portion of the Project site would be developed with 413 dwelling units
and 46,510 SF of new nonresidential development (for a total [existing plus new] of 133,641 SF
nonresidential development). The construction of this alternative would require site clearing, grading, and
construction activities similar to the proposed Project. However, under this alternative, construction activities
would occur for a shorter period of time due to the 35 percent reduction in nonresidential development.
Therefore, the construction noise impacts would remain less than significant, but would be lessened compared
to the Project.
Buildout of the proposed Project is anticipated to generate approximately 4,412 net new ADT, including
313 new trips during the AM peak hour and 393 new trips during the PM peak hour. The increase in Project -
related traffic noise would be no greater than 2.3 dBA from existing baseline conditions which is below the
threshold of a 3.0 dBA noise level increase. This alternative is anticipated to generate fewer new trips as
compared to the proposed Project because of the 35 percent reduction in nonresidential uses. As such, noise
impacts under this alternative would continue to be less than significant and would be less than the proposed
Project.
Similar to the proposed Project but to a lesser extent, the Project site and adjacent offsite land uses would
be potentially exposed to stationary -source noise impacts from the proposed onsite heating, ventilation, and
air conditioning (HVAC) equipment and truck deliveries and loading and unloading activities under this
alternative. It is expected that on -site stationary sources would meet the City of Tustin maximum noise level
standards. This alternative would also require implementation of Mitigation Measure NOI-1, that requires
preparation of a project -specific Final Acoustic Report for future development projects. Therefore, the
Reduced Nonresidential Project Alternative would result in a less than significant impact with mitigation and
would be less than Project impacts.
Population and Housing
Under this alternative, the 1 1.80-acre Project site would be developed with 413 dwelling units and 46,510
SF of new nonresidential development (for a total buildout of 133,641 SF nonresidential development).
Using employment generation rates from the 2001 SCAG Employment Density Report, buildout of the new
46,510 SF of nonresidential space would result in approximately 143 new employees (1 employee per 325
SF). The Reduced Nonresidential Project Alternative would result in the same number of dwelling units and
residents. Similar to the Project, this alternative would not exceed projections for the City. In addition,
because the area is jobs -rich, the addition of residential units in the area would not require additional jobs
that could result in growth. Conversely, the new residents would fill the need for employees that are
anticipated by SCAG projections. Additionally, the Project is in fulfillment of the City's RHNA, which is
allocated by SCAG, and therefore, this alternative would support the City in meeting the planned population
growth for the larger region. The Reduced Nonresidential Project Alternative would result in a less than
significant impact on population. Therefore, this alternative would result in similar less than significant impacts
as the Project. Overall, the Reduced Nonresidential Project Alternative would result in similar impacts as the
Project.
Public Services
Under this alternative, the 1 1.80-acre Project site would be developed with 413 dwelling units and new
46,510 SF of nonresidential development (for a total buildout of 133,641 SF nonresidential development).
Construction of this alternative would result in a slightly decreased demand for public services based on the
decreased amount of employment generated. The same fire and sheriff's stations would serve the
alternative, and the decrease in square footage developed would likely incrementally decrease the amount
City of Tustin 8-1 1
Draft EIR
June 2024
Enderle Center Rezone Proiect 8. Alternatives
of service calls received by these public services compared to the proposed Project. In addition, this
alternative would also require the payment of development impact fees imposed by the City, although the
amount of fees would likely be reduced. Through implementation of regulatory requirements, impacts would
be less than significant. Therefore, this alternative would result in similar less than significant impacts as the
proposed Project.
Recreation
As described in Section 5.6, Population and Housing, the Project is anticipated to result in 1,189 residents at
full occupancy. The Reduced Nonresidential Project Alternative would result in the same number of residents,
which results in a demand for approximately 3.57 acres of parkland to support the additional residents.
Tustin City Code Article 9, Chapter 3, Part 3, Section 9331(d) (Parkland Dedication) requires certain
residential projects to dedicate parkland or pay parkland dedication and development fee provisions. The
Reduced Nonresidential Project Alternative could include future development of housing that would be
subject to Parkland Dedication, the same as the proposed Project. This alternative would result in a less than
significant impact, and would result in similar impacts as the Project.
Transportation
Under this alternative, the 1 1.80-acre Project site would be developed with 413 dwelling units and 46,510
SF new of nonresidential development (for a total buildout of 133,641 SF nonresidential development). The
total nonresidential development would be reduced by 35 percent from the proposed Project's buildout
(71,962 SF less). Therefore, the Reduced Nonresidential Project alternative would result in fewer trips as
compared to the Project. The Reduced Nonresidential Project alternative would remain in a low VMT area
"per employee" and would therefore be screened out from further VMT analysis for nonresidential
development per the City VMT standards. The Project would propose the same number of housing units, and
therefore this alternative's home -based VMT per capita would be 19.7 percent below the City's threshold
under base conditions and 18.7 percent below the City's threshold under future conditions; therefore, the
residential portion of the Reduced Nonresidential Project alternative would result in a less than significant
VMT impact. Similar to the Project, this alternative would not impact existing or planned transportation
facilities, including pedestrian facilities, bicycle facilities, and public transportation infrastructure or
operation. Therefore, the Reduced Nonresidential Project Alternative would result in a less than significant
impact and would result in similar impacts as the Project.
Tribal Cultural Resources
Under this alternative, disturbances would occur to the 1 1.88-acre site. Project construction would require
grading and excavation and could result in potential impacts to tribal cultural resources that may be buried
below ground. Mitigation Measure TCR-1, TCR-2 and TCR-3 would reduce tribal cultural resource impacts
to less than significant levels, similar to the Project. Areas planned for physical impact would be identical to
those required for development of the proposed Project. Therefore, the Reduced Nonresidential Project
Alternative would result in similar impacts as the proposed Project.
Utilities and Service Systems
Under this alternative, the 1 1.80-acre Project site would be developed with 413 dwelling units and 46,510
SF of new nonresidential development (for a total buildout of 133,641 SF nonresidential development).
The level of development onsite would be decreased under this alternative as compared to the proposed
Project. Future development projects under both the Project and this alternative would require new
installation of onsite water infrastructure and new connections to the water distribution systems; like the
City of Tustin 8-1 2
Draft EIR
June 2024
Enderle Center Rezone Proiect 8. Alternatives
Project, this alternative would include Mitigation Measure UT-1 to require future projects to coordinate with
the City and prepare a capacity analysis of existing water utilities in the area to ensure conveyance and
pressure is adequate.
Furthermore, future development projects under both the Project and this alternative would require new
installation of onsite wastewater infrastructure and new connections to the wastewater distribution systems;
like the Project, this alternative would include Mitigation Measure UT-2 to require future projects to
coordinate with East Orange County Water District (EOCWD) and prepare a capacity analysis of existing
wastewater utilities in the area to ensure conveyance and pressure is adequate.
This alternative would result in a decrease in nonresidential square footage and would generate less solid
waste than the proposed Project.
Although impacts would be decreased under this alternative due to the decrease in nonresidential uses and
associated demand for utilities and service systems, impacts would continue to be less than significant with
implementation of Mitigation Measure UT-1 and Mitigation Measure UT-2. Overall, this alternative would
also result in less than significant impacts related to utilities and service systems but would result in a decrease
in impacts in comparison to the proposed Project.
8.7.2 Conclusion
Ability to Reduce Impacts
The Reduced Nonresidential Project Alternative would allow for the potential future buildout of 413 dwelling
units and 46,510 SF of new nonresidential development (for a total buildout of 133,641 SF nonresidential
development) within the 1 1.80-acre site. Development under the Reduced Nonresidential Project Alternative
would reduce nonresidential square footage by approximately 35 percent. The reduced square footage
would allow for increased setbacks, passenger vehicle parking, and truck parking. Areas planned for
physical impact on and offsite would be identical to those required for development of the proposed Project.
Mitigation measures for GHG, noise, recreation, tribal cultural resources, and utilities and service systems
would still be applicable to this alternative. Although, the Reduced Nonresidential Project Alternative would
generally result in a reduction of impacts due to the 35 percent reduction in nonresidential uses, this
alternative would only reduce the impact level of one of the 11 environmental topics analyzed in this Draft
EIR (operational air quality impacts) from significant and unavoidable with mitigation, to less than significant
(see Table 8-1). Furthermore, impacts to GHG would continue to be significant and unavoidable (although
slightly less).
Ability to Achieve Project Objectives
As shown in Table 8-2, below, the Reduced Nonresidential Project Alternative would meet all of the Project
objectives. This alternative would be consistent with what was planned for in the City's Housing Element
Update. The Reduced Project Alternative would allow for the creation of a Housing Overlay District to allow
residential development at densities to achieve the estimated capacities determined in the Housing Element
and without inhibitors to residential development. This alternative would also increase the number of housing
opportunities available in Tustin, increase flexibility in allowed uses and development potential in an
underutilized area of the City of Tustin, and promote a diverse housing stock with products that are offered
at a wide range of sizes and affordability.
City of Tustin 8-1 3
Draft EIR
June 2024
Enderle Center Rezone Project 8. Alternatives
8.8 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires a lead agency to identify the "environmentally superior alternative" when significant
environmental impacts result from a proposed Project. The No Project/No Development Alternative is
environmentally superior.
However, State CEQA Guidelines Section 15126.6(3)(1) states:
The "no project" analysis shall discuss the existing conditions at the time the notice of
preparation is published, or if no notice of preparation is published, at the time environmental
analysis is commenced, as well as what would be reasonably expected to occur in the
foreseeable future if the project were not approved, based on current plans and consistent with
available infrastructure and community services. If the environmentally superior alternative is
the "no project" alternative, the EIR shall also identify an environmentally superior alternative
among the other alternatives.
Therefore, pursuant to CEQA, because the No Project/No Development Alternative has been identified as
the Environmentally Superior Alternative, the Environmentally Superior Alternative among the other
alternatives would be Alternative 2: Reduced Nonresidential Project Alternative.
Alternative 2 would allow for the potential future buildout of 413 dwelling units and 46,510 SF of new
nonresidential development (for a total buildout of 133,641 SF nonresidential development) within the
11.80-acre site. Development under the Reduced Nonresidential Project Alternative would reduce
nonresidential square footage by approximately 35 percent. This alternative would avoid the Project's
significant and unavoidable operational air quality impacts to sensitive receptors. This alternative would not
require implementation of Mitigation Measure AQ-1 because the reduction of 35 percent building area for
nonresidential uses would reduce PMio emissions below SCAQMD thresholds. Moreover, the Reduced
Nonresidential Project Alternative would meet the Project objectives to the same extent as the Project.
However, this alternative would be required to implement applicable mitigation measures regarding GHG,
noise, tribal cultural resources, and utilities and service systems, similar to the Project. Impacts to GHG would
continue to be significant and unavoidable.
CEQA does not require the Lead Agency (City of Tustin) to choose the environmentally superior alternative.
Instead, CEQA requires the City to consider environmentally superior alternatives, weigh those considerations
against the environmental impacts of the proposed Project, and make findings that the benefits of those
considerations outweigh the harm. Table 8-1 provides, in summary format, a comparison between the level
of impacts for each alternative and the proposed Project. In addition, Table 8-2 provides a comparison of
the ability of each of the alternatives to meet the objectives of the proposed Project.
City of Tustin 8-14
Draft EIR
June 2024
Enderle Center Rezone
8. Alternatives
Table 8-1: Impact Comparison of the Proposed Project and Alternatives
Proposed Project
Alternative 1
Alternative 2
No Project/ No
Reduced Nonresidential
Development
Project
Air Quality
Significant and
No impact (less than the
Less than significant (less
unavoidable
Project)
than the Project)
Energy
Less than significant
No impact (less than the
Less than significant (less
Project)
than the Project)
Greenhouse Gases
Significant and
No impact (less than the
Significant and
unavoidable
Project)
Unavoidable (less than the
Project)
Land Use and Planning
Less than significant
No impact (less than the
Less than significant (same
Project)
as the Project)
Noise
Less than significant
No impact (less than the
Less than significant with
with mitigation
Project)
mitigation (same as the
Project)
Population and
Less than significant
Significant and
Less than significant (same
Housing
Unavoidable (more
as the Project)
than the Project)
Public Services
Less than significant
No impact (less than the
Less than significant (same
Project)
as the Project)
Recreation
Less than significant
No impact (less than the
Less than significant (same
Project)
as the Project)
Transportation
Less than significant
No impact (less than the
Less than significant (same
Project)
as the Project)
Tribal Cultural
Less than significant
No impact (less than the
Less than significant with
Resources
with mitigation
Project)
mitigation (same as the
Project)
Utilities and Service
Less than significant
No impact (less than the
Less than significant with
Systems
with mitigation
Project)
mitigation (less than the
Project)
Reduce Impacts of the Project?
Yes
Yes
Areas of Reduced Impacts Compared to the
10
4
Project
City of Tustin 8-15
Draft EIR
June 2024
Enderle Center Rezone
8. Alternatives
Table 8-2: Comparison of the Proposed Project and Alternatives' Ability to Meet Objectives
Project
Alternative 1
Alternative 2
No Project/ No
Reduced Project
Development
a. Creation of a Housing Overlay District to allow
Yes
No
Yes
residential development at densities to achieve
the estimated capacities determined in the
Housing Element and without inhibitors to
residential development
b. Increase the number of housing opportunities
Yes
No
Yes
available in Tustin to ensure the City provides its
fair share of housing units within a variety of
income categories.
C. Increase flexibility in allowed uses and
Yes
No
Yes
development potential in an underutilized area
of the City of Tustin.
d. Promote a diverse housing stock with products
Yes
No
Yes
that are offered at a wide range of sizes and
affordability.
City of Tustin 8-16
Draft EIR
June 2024
Enderle Center Rezone Proiect 9. EIR Preparers and Persons Contacted
9. EIR Preparers and Persons Contacted
EIR PREPARERS
City of Tustin
Justina Willkom, Community Development Director
Jay Eastman, Assistant Community Development Director
Samantha Beier, Senior Planner
Jorge Maldonado, Associate Planner
Adrianne DiLeva, Management Analyst II
EPD Solutions, Inc.
Konnie Dobreva, Vice President of Environmental Servies
Meghan Macias, TE, Director of Technical Services
Danielle Thayer, Associate Planner II
Abby Pal, Senior Transportation Planner
Megan Rupard, Assistant Planner
Sam Kelley, Assistant Planner
Jazmin Rodriguez, Assistant Planner
Simon Lin, Assistant Transportation Planner
BFSA Environmental Services
Tracy Stropes, M.A., RPA, Director/Principal Archaeologist
LSA Associates, Inc.
Cara Cunningham, Associate
J.T. Stephens, Executive Vice President
PERSONS CONTACTED
City of Tustin Parks and Recreation Department
Chad Clanton, Director of Parks & Recreation
East Orange County Water District
Jeff Smyth, P.E., Engineering Manager/East Orange County Water District
City of Tustin 9-1
Draft EIR
June 2024
Enderle Center Rezone Proiect 9. EIR Preparers and Persons Contacted
Orange County Fire Authority
Brian Fennessy, Fire Chief
Tamera Rivers, Management Analyst
Tustin Unified School District
Rina Lucchese, Director of Communications and Community Engagement
Tom Rizzuti, Director of Facilities and Planning
City of Tustin 9-2
Draft EIR
June 2024
Appendix A
Notice of Preparation, Scoping
Comments, and Initial Study
ORANGE COUNTY
CLERK -RECORDER
CEQA FILING COVER SHEET
THIS SPACE FOR CLERK'S USE ONLY
Complete and attach this form to each CEQA Notice filed with the County Clerk -Recorder
TYPE OR PRINT CLEARLY
Project Title
PUBLIC NOTICE/POSTING: ENDERLE CENTER REZONE PROJECT
(GPA-2024-0001, CA-2024-0003, AND ZC--2024-0001)
Check Document being Filed:
0 Environmental Impact Report (EIR)
® Mitigated Negative Declaration (MND) or Negative Declaration (ND)
QNotice of Exemption (NOE)
kVOther (Please fill in type): POSTING
FILED IN THE OFFICE OF THE ORANGE
COUNTY CLERK -RECORDER ON February 23, 2024
Posted for 30 days
DEPUTY CARINA HERRERA
Filing fees are due at the time a Notice of Determination/Exemption is filed with our office.For more Information
on filing fees and No Effect Determinations, please refer to California Code of Regulations, Title 14, section 753.5.
TUSTIN
_( . TI N
NOTICE �F PREPARA 0
AND SCOPING MEETING
1Lli.11l tit. OUR iJI L111
DATE: February 15, 2024
TO: Agencies, Organizations, and Interested Parties
SUBJECT: Notice of Preparation of a Draft Environmental Impact Report for the Enderle
Center Rezone Project in Compliance with Title 14, Section 15082(a) of the
California Code of Regulations
PUBLIC REVIEW: February 16, 2024, to March 18, 2024 March 20, 2024
The City of Tustin is proposing a General Plan Amendment (GPA) and zone change for the application of
a Housing Overlay (HO) district over an existing commercial development known as the Enderle Center.
As part of that process, the City intends to prepare an Environmental Impact Report (EIR), pursuant to the
requirements of the California Environmental Quality Act (CEQA) for the proposed GPA and zone change,
described below. We request your review and comments as to the scope and content of the proposed EIR,
as summarized in the Initial Study, available on the City's website at www.tustinca.PM/
Housing ElementRezon_e, or available at City offices, 300 Centennial Way, Tustin, California, 92780.
AGENCIES: The City requests your review on the scope and content of the environmental information
relevant to your agency's statutory responsibilities in connection with the proposed Project, in accordance
with California Code of Regulations, Title 14, Section 15082(b). Your agency will need to use the EIR
prepared by the City when considering any permits that your agency must issue, or other approval for the
project.
ORGANIZATIONS AND INTERESTED PARTIES: The City requests your comments and concerns
regarding the environmental issues associated with implementation of the proposed Project.
PROJECT TITLE: Enderle Center Rezone Project (GPA-2024-0001, CA-2024-0003, and ZC-2024-0001)
PROJECT LOCATION: The City is in the central portion of Orange County and is surrounded by the cities
of Irvine to the south and east, Santa Ana to the west, and Orange and unincorporated Orange County to
the north. The Project site is approximately 11.80 acres and consists of Assessor Parcel Numbers (APNs)
401-251-04, -05, and -06; 401-252-05, -06, -08, -09, and -10; and 401-253-03 and -04. As shown in Figure
1, Vicinity Map, the Project site is generally bounded on the north by 17th Street; on the east by Enderle
Center Drive and the eastern property line of properties fronting Enderle Center Drive; to the south by
Vandenberg Lane; and to the west by the 55 Freeway, including properties west of Yorba Street.
DESCRIPTION: The Enderle Center is an existing commercial development within the City of Tustin. The
Enderle Center is currently developed with 87,136 SF of commercial businesses, including 28,750 SF of
restaurant use, 39,960 SF of retail and service use, 18,426 SF of office use, and surface parking lots. The
City is proposing a Zoning Code Amendment (CA) to create a Housing Overlay (HO) district (Tustin City
Code Section 9253), and apply the HO district to the Project site. The proposed land use change is pursuant
to the City's 2021-2029 Housing Element Update (HEU), certified by the State of California Housing and
Community Development Department (HCD) on September 12, 2022, and adopted by the City on October
4, 2022. The proposed HO district applied to the Project site would allow for future residential development
with a maximum density of 413 units over a maximum development area of seven acres. The Initial Study
and EIR assume future residential development to occur in the undeveloped parking areas within the
Project site.
TUSTLN
NOTICE OF PREPARATION
AND SCOPING MEETING
SUILn1NG OUR FUTURL
"ONORINC OUR PAST
Figure 1 -Vicinity Map
'- � � s�nta Clorn Ave
...- :Yarba 5....., ... -
3S E
.or. nb In
.. , N T.Llk A— - -
Pro[ed She �y
CHAIRPERSON
Reginald Pagaling
Chumash
VICE -CHAIRPERSON
Bufly McQuillen
Yokayo Porno, Yuki,
Nomlaki
SECRETARY
Sara Duischke
Miwok
PARLIAMENTARIAN
Wayne Nelson
Luiseno
COMMISSIONER
Isaac Bojorquez
Ohlone-Costanoan
NATIVE AMERICAN HERITAGE COMMISSION
February 21, 2024
Samantha Beier
City of Tustin
300 Centennial Way
Tustin CA 92780
Re: 2024020747, Enderle Center Rezone Project, Orange County
Dear Ms. Beier:
The Native American Heritage Commission (NAHC) has received the Notice of Preparation
(NOP), Draft Environmental Impact Report (DEIR) or Early Consultation for the project
referenced above. The California Environmental Quality Act (CEQA) (Pub. Resources Code
§21000 at seq.), specifically Public Resources Code §21084.1, states that a project that may
cause a substantial adverse change in the significance of a historical resource, is a project that
may have a significant effect on the environment. (Pub. Resources Code § 21084.1; Cal. Code
Regs., tit.14, § 15064.5 (b) (CEQA Guidelines § 15064.5 (b)). If there is substantial evidence, in
light of the whole record before a lead agency, that a project may have a significant effect on
the environment, an Environmental Impact Report (EIR) shall be prepared. (Pub. Resources
Code §21080 (d); Cal. Code Regs., tit. 14, § 5064 subd.(a)(1) (CEQA Guidelines § 15064 (a)(1)).
In order to determine whether a project will cause a substantial adverse change in the
significance of a historical resource, a lead agency will need to determine whether there are
historical resources within the area of potential effect (APE).
COMMISSIONER
CEQA was amended significantly in 2014. Assembly Bill 52 (Gatto, Chapter 532, Statutes of
Stanley Rodriguez
2014) (AB 52) amended CEQA to create a separate category of cultural resources, "tribal
Kumeyaay
cultural resources" (Pub. Resources Code §21074) and provides that a project with an effect
that may cause a substantial adverse change in the significance of a tribal cultural resource is
a project that may have a significant effect on the environment. (Pub. Resources Code
COMMISSIONER
Lourena Bolden
§21084.2). Public agencies shall, when feasible, avoid damaging effects to any tribal cultural
Serrano
resource. (Pub. Resources Code §21084.3 (a)). AB 52 applies to any project for which a notice
of preparation, a notice of negative declaration, or a mitigated negative declaration is filed on
or after July 1, 2015. If your project involves the adoption of or amendment to a general plan or
COMMISSIONER
a specific plan, or the designation or proposed designation of open space, on or after March 1,
Reid Mhanovicn
Cahullla
2005, it may also be subject to Senate Bill 18 (Burton, Chapter 905, Statutes of 2004) (SB 18).
Both SB 18 and AB 52 have tribal consultation requirements. If your project is also subject to the
federal National Environmental Policy Act (42 U.S.C. § 4321 et seq.) (NEPA), the tribal
COMMISSIONER
consultation requirements of Section 106 of the National Historic Preservation Act of 1966 (154
Vacant
U.S.C. 300101, 36 C.F.R. §800 et seq.) may also apply.
EXECUTIVE SECRETARY
The NAHC recommends consultation with California Native American tribes that are
Raymond C.
traditionally and culturally affiliated with the geographic area of your proposed project as early
Hitchcock
as possible in order to avoid inadvertent discoveries of Native American human remains and
Miwok, Nisenan
best protect tribal cultural resources. Below is a brief summary of portions of AB 52 and SB 18 as
well as the NAHC's recommendations for conducting cultural resources assessments.
NAHC HEADQUARTERS
1550 Harbor Boulevard Consult your legal counsel about compliance with AB 52 and SB 18 as well as compliance with
Suite 100 any other applicable laws.
West Sacramento,
California 95691
(916) 373-3710
nahcOnahc.ca aov
NAHC.co.gov Page 1 of 5
AB 52
AB 52 has added to CEQA the additional requirements listed below, along with many other requirements:
1. Fourteen Day Period to Provide Notice of Completion of an Abolication/Decision to Undertake a Project:
Within fourteen (14) days of determining that an application for a project is complete or of a decision by a public
agency to undertake a project, a lead agency shall provide formal notification to a designated contact of, or
tribal representative of, traditionally and culturally affiliated California Native American tribes that have
requested notice, to be accomplished by at least one written notice that includes:
a. A brief description of the project.
b. The lead agency contact information.
c. Notification that the California Native American tribe has 30 days to request consultation. (Pub.
Resources Code §21080.3.1 (d)).
d. A "California Native American tribe" is defined as a Native American tribe located in California that is
on the contact list maintained by the NAHC for the purposes of Chapter 905 of Statutes of 2004 (SB 18).
(Pub. Resources Code §21073).
2. Begin Consultation Within 30 Days of Receiving a Tribe's Reauest for Consultation and Before Releasing a
Negative Declaration Mitigated Negative Declaration or Environmental Impact Report: A lead agency shall
begin the consultation process within 30 days of receiving a request for consultation from a California Native
American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project.
(Pub. Resources Code §21080.3.1, subds. (d) and (e)) and prior to the release of a negative declaration,
mitigated negative declaration or Environmental Impact Report. (Pub. Resources Code §21080.3.1 (b)).
a. For purposes of AB 52, "consultation shall have the same meaning as provided in Gov. Code §65352.4
(SB 18). (Pub. Resources Code §21080.3.1 (b)).
3. Mandatory Topics of Consultation If Requested by a Tribe: The following topics of consultation, if a tribe
requests to discuss them, are mandatory topics of consultation:
a. Alternatives to the project.
b. Recommended mitigation measures.
c. Significant effects. (Pub. Resources Code §21080.3.2 (a)).
4. Discretionary Topics of Consultation: The following topics are discretionary topics of consultation:
a. Type of environmental review necessary.
b. Significance of the tribal cultural resources.
c. Significance of the project's impacts on tribal cultural resources.
d. If necessary, project alternatives or appropriate measures for preservation or mitigation that the tribe
may recommend to the lead agency. (Pub. Resources Code §21080.3.2 (a)).
5. Confidentiality of Information Submitted by a Tribe During the Environmental Review Process: With some
exceptions, any information, including but not limited to, the location, description, and use of tribal cultural
resources submitted by a California Native American tribe during the environmental review process shall not be
included in the environmental document or otherwise disclosed by the lead agency or any other public agency
to the public, consistent with Government Code §6254 (r) and §6254.10. Any information submitted by a
California Native American tribe during the consultation or environmental review process shall be published in a
confidential appendix to the environmental document unless the tribe that provided the information consents, in
writing, to the disclosure of some or all of the information to the public. (Pub. Resources Code §21082.3 (c) (1)).
6. Discussion of Impacts to Tribal Cultural Resources in the Environmental Document: If a project may have a
significant impact on a tribal cultural resource, the lead agency's environmental document shall discuss both of
the following:
a. Whether the proposed project has a significant impact on an identified tribal cultural resource.
b. Whether feasible alternatives or mitigation measures, including those measures that may be agreed
to pursuant to Public Resources Code §21082.3, subdivision (a), avoid or substantially lessen the impact on
the identified tribal cultural resource. (Pub. Resources Code §21082.3 (b)).
Page 2 of 5
7. Conclusion of Consultation: Consultation with a tribe shall be considered concluded when either of the
following occurs:
a. The parties agree to measures to mitigate or avoid a significant effect, if a significant effect exists, on
a tribal cultural resource; or
b. A party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot
be reached. (Pub. Resources Code §21080.3.2 (b)).
8. Recommending Mitigation Measures Agreed Upon in Consultation in the Environmental Document• Any
mitigation measures agreed upon in the consultation conducted pursuant to Public Resources Code §21080.3.2
shall be recommended for inclusion in the environmental document and in an adopted mitigation monitoring
and reporting program, if determined to avoid or lessen the impact pursuant to Public Resources Code §21082.3,
subdivision (b), paragraph 2, and shall be fully enforceable. (Pub. Resources Code §21082.3 (a)).
9. Required Consideration of Feasible Miti ac ti ion: If mitigation measures recommended by the staff of the lead
agency as a result of the consultation process are not included in the environmental document or if there are no
agreed upon mitigation measures at the conclusion of consultation, or if consultation does not occur, and if
substantial evidence demonstrates that a project will cause a significant effect to a tribal cultural resource, the
lead agency shall consider feasible mitigation pursuant to Public Resources Code §21084.3 (b). (Pub. Resources
Code §21082.3 (e)).
10. Examples of Mitigation Measures That, If Feasible, May Be Considered to Avoid or Minimize Significant Adverse
Impacts to Tribal Cultural Resources:
a. Avoidance and preservation of the resources in place, including, but not limited to:
1. Planning and construction to avoid the resources and protect the cultural and natural
context.
ii. Planning greenspace, parks, or other open space, to incorporate the resources with culturally
appropriate protection and management criteria.
b. Treating the resource with culturally appropriate dignity, taking into account the tribal cultural values
and meaning of the resource, including, but not limited to, the following:
1. Protecting the cultural character and integrity of the resource.
H. Protecting the traditional use of the resource.
iii. Protecting the confidentiality of the resource.
c. Permanent conservation easements or other interests in real property, with culturally appropriate
management criteria for the purposes of preserving or utilizing the resources or places.
d. Protecting the resource. (Pub. Resource Code §21084.3 (b)).
e. Please note that a federally recognized California Native American tribe or a non -federally
recognized California Native American tribe that is on the contact list maintained by the NAHC to protect
a California prehistoric, archaeological, cultural, spiritual, or ceremonial place may acquire and hold
conservation easements if the conservation easement is voluntarily conveyed. (Civ. Code §815.3 (c)).
f. Please note that it is the policy of the state that Native American remains and associated grave
artifacts shall be repatriated. (Pub. Resources Code §5097.991).
11. Prerequisites for Certifying an Environmental Impact Report or Adopting a Mitigated Neaative Declaration or
Neaative Declaration with a Significant Impact on an Identified Tribal Cultural Resource: An Environmental
Impact Report may not be certified,,nor may a mitigated negative declaration or a negative declaration be
adopted unless one of the following occurs:
a. The consultation process between the tribes and the lead agency has occurred as provided in Public
Resources Code §21080.3.1 and §21080.3.2 and concluded pursuant to Public Resources Code
§21080.3.2.
b. The tribe that requested consultation failed to provide comments to the lead agency or otherwise
failed to engage in the consultation process.
c. The lead agency provided notice of the project to the tribe in compliance with Public Resources
Code §21080.3.1 (d) and the tribe failed to request consultation within 30 days. (Pub. Resources Code
§21082.3 (d)).
The NAHC's PowerPoint presentation titled, "Tribal Consultation Under AB 52: Requirements and Best Practices" may
be found online at: http://nahc.co.aov/wp-content/uploads 2/ 015/10/AB52TribalConsultation CalEPAPDF.pdf
Page 3 of 5
RM
SB 18 applies to local governments and requires local governments to contact, provide notice to, refer plans to, and
consult with tribes prior to the adoption or amendment of a general plan or a specific plan, or the designation of
open space. (Gov. Code §65352.3). Local governments should consult the Governor's Office of Planning and
Research's "Tribal Consultation Guidelines," which can be found online at:
httr)s://www.oiDr.ca.aov/docs/09 14 05 Updated Guidelines 922.df.
Some of SB 18's provisions include:
1. Tribal Consultation: If a local government considers a proposal to adopt or amend a general plan or a
specific plan, or to designate open space it is required to contact the appropriate tribes identified by the NAHC
by requesting a "Tribal Consultation List." If a tribe, once contacted, requests consultation the local government
must consult with the tribe on the plan proposal. A tribe has 90 days from the date of receipt of notification to
request consultation unless a shorter timeframe has been agreed to by the tribe. (Gov. Code §65352.3
(a)(2))•
2. No Statutory Time Limit on SB 18 Tribal Consultation. There is no statutory time limit on SB 18 tribal consultation.
3. Confidentiality: Consistent with the guidelines developed and adopted by the Office of Planning and
Research pursuant to Gov. Code §65040.2, the city or county shall protect the confidentiality of the information
concerning the specific identity, location, character, and use of places, features and objects described in Public
Resources Code §5097.9 and §5097.993 that are within the city's or county's jurisdiction. (Gov. Code §65352.3
(b))•
4. Conclusion of SB 18 Tribal Consultation: Consultation should be concluded at the point in which:
a. The parties to the consultation come to a mutual agreement concerning the appropriate measures
for preservation or mitigation; or
b. Either the local government or the tribe, acting in good faith and after reasonable effort, concludes
that mutual agreement cannot be reached concerning the appropriate measures of preservation or
mitigation. (Tribal Consultation Guidelines, Governor's Office of Planning and Research (2005) at p. 18).
Agencies should be aware that neither AB 52 nor SB 18 precludes agencies from initiating tribal consultation with
tribes that are traditionally and culturally affiliated with their jurisdictions before the timeframes provided in AB 52 and
SB 18. For that reason, we urge you to continue to request Native American Tribal Contact Lists and "Sacred Lands
File" searches from the NAHC. The request forms can be found online at: httr):/Inahc.co.gov/resources/forms/.
NAHC Recommendations for Cultural Resources Assessments
To adequately assess the existence and significance of tribal cultural resources and plan for avoidance, preservation
in place, or barring both, mitigation of project -related impacts to tribal cultural resources, the NAHC recommends
the following actions:
1. Contact the appropriate regional California Historical Research Information System (CHRIS) Center
(https://ohp.parks.co.gov/?page_id=30331) for an archaeological records search. The records search will
determine:
a. If part or all of the APE has been previously surveyed for cultural resources.
b. If any known cultural resources have already been recorded on or adjacent to the APE.
c. If the probability is low, moderate, or high that cultural resources are located in the APE.
d. If a survey is required to determine whether previously unrecorded cultural resources are present.
2. If an archaeological inventory survey is required, the final stage is the preparation of a professional report
detailing the findings and recommendations of the records search and field survey.
a. The final report containing site forms, site significance, and mitigation measures should be submitted
immediately to the planning department. All information regarding site locations, Native American
human remains, and associated funerary objects should be in a separate confidential addendum and
not be made available for public disclosure.
b. The final written report should be submitted within 3 months after work has been completed to the
appropriate regional CHRIS center.
Page 4 of 5
3. Contact the NAHC for:
a. A Sacred Lands File search. Remember that tribes do not always record their sacred sites in the
Sacred Lands File, nor are they required to do so. A Sacred Lands File search is not a substitute for
consultation with tribes that are traditionally and culturally affiliated with the geographic area of the
project's APE.
b. A Native American Tribal Consultation List of appropriate tribes for consultation concerning the
project site and to assist in planning for avoidance, preservation in place, or, failing both, mitigation
measures.
4. Remember that the lack of surface evidence of archaeological resources (including tribal cultural resources)
does not preclude their subsurface existence.
a. Lead agencies should include in their mitigation and monitoring reporting program plan provisions for
the identification and evaluation of inadvertently discovered archaeological resources per Cal. Code
Regs., tit. 14, § 15064.5(f) (CEQA Guidelines § 15064.5(f)). In areas of identified archaeological sensitivity, a
certified archaeologist and a culturally affiliated Native American with knowledge of cultural resources
should monitor all ground -disturbing activities.
b. Lead agencies should include in their mitigation and monitoring reporting program plans provisions
for the disposition of recovered cultural items that are not burial associated in consultation with culturally
affiliated Native Americans.
c. Lead agencies should include in their mitigation and monitoring reporting program plans provisions
for the treatment and disposition of inadvertently discovered Native American human remains. Health
and Safety Code §7050.5, Public Resources Code §5097.98, and Cal. Code Regs., tit. 14, § 15064.5,
subdivisions (d) and (e) (CEQA Guidelines § 15064.5, subds. (d) and (a)) address the processes to be
followed in the event of an inadvertent discovery of any Native American human remains and
associated grave goods in a location other than a dedicated cemetery.
If you have any questions or need additional information, please contact me at my email address:
Andrew.GrgenQNAHC.ca.aov.
Sincerely,
.4,�?W_aw,
Andrew Green
Cultural Resources Analyst
cc: State Clearinghouse
Page 5 of 5
CALIFORNIA STATE TRANSPORTATION AGENCY
GAVIN NEWSOM, GOVERNOR
California Department of Transportation
DISTRICT 12
1750 East 41h Street, Suite 100 1 SANTA ANA, CA 92705
(657) 328-6000 1 FAX (657) 328-6522 TTY 711
hftps://dot.ca.aov/calfrans-near-me/district-12
March 18, 2024
Samantha Beier
City of Tustin
300 Centennial Way
Tustin, CA 92780
Dear Ms. Beier,
File: LDR/CEQA
SC H #2024020747
LDR LOG #202202499
S R-55, 1-5
Thank you for including the California Department of Transportation (Caltrans) in the
review of the Notice of Preparation of a Draft Environmental Impact Report for the
Enderle Rezone project. The City of Tustin is proposing a General Plan Amendment
(GPA) and zone change for the application of a Housing Overlay (HO) district over an
existing commercial development known as the Enderle Center. Pursuant to Housing
Element Program 1.1 f, the city is proposing an overlay zone ("overlay district") for the
Project site to add 413 housing units. The anticipated development does not rely on
the demolition of any existing buildings, but rather focuses on areas currently used for
surface parking. Additionally, the Project anticipates the additional development of
118,467 square feet of nonresidential uses in the future, for a total nonresidential
development capacity of 205,603 square feet on the Project site, pursuant to the
General Plan. A specific development project is not proposed as part of this Rezoning
Project. The Project involves approval of the proposed Housing Overlay, a General
Plan Amendment, Zoning Code Amendment, and a Zone Change. The Project site is
generally bounded on the north by 17th Street; on the east by Enderle Center Drive
and the eastern property line of properties fronting Enderle Center Drive; to the south
by Vandenberg Lane; and to the west by the 55 Freeway, including properties west of
Yorba Street.
The mission of Caltrans is to provide a safe and reliable transportation network that
serves all people and respects the environment. Caltrans is a responsible agency on
this project and has the following comments:
1. Due to the proximity of the proposed project to SR-55 potential impacts are
anticipated according to Section 5-7. Please submit A Vehicle Miles Traveled
(VMT) based Traffic Impact Study (TIS) for this project. Please use the Governor's
Office of Planning and research guidance to identify VMT related impacts that
includes any potential mitigation measures necessary. If impact analysis leads
to findings of significance, please coordinate with Caltrans District 12 Local
Development on development of a Traffic Mitigation Agreement or similar
efforts.
"Provide a safe and reliable transportation network that serves all people and respects the environment"
Ms. Samantha Beier
March 18, 2024
Page 2
2. Please refer to OPR's Technical Advisory on Evaluating Transportation Impacts in
CEQA and Caltrans' Transportation Impact Study Guide for the VMT assessment.
Caltrans' Transportation Impact Study Guide: httl2s://dot.ca.gov/-/media/dot-
media/programs/transportation-planning/documents/sb-743/2020-05-20-
approved-vmt-focused-tisq-a 11 v.pdf
3. This rezoning will result in an increase of 413 residential units, including affordable
housing for low-income individuals. As part of this rezoning and subsequent
development, Caltrans encourages the consideration of accompanying
complete streets elements, such as bike lanes, and pedestrian safety features,
such as curb bump outs, rectangular rapid flashing beacons, and leading
pedestrian intervals. These should be considered throughout the project area, as
increased residential density provides an opportunity to enhance safety for all
road users.
4. Please Provide a discussion of existing bus route services and potential future
transit improvement opportunities for all including intercounty and regional
connectivity along with connectivity to rail services from the nearest train
stations provided by both Metrolink and Amtrak Pacific Surfliner. Encourage the
use of transit among future residents, visitors, and workers of the development.
Increasing multimodal transportation may lead to a reduction to congestion,
Vehicle Miles Traveled, and improve air quality. Provide adequate wayfinding
signage and related amenities to the transit stops within the project vicinity
roadways.
5. Ensure that truck parking, ingress and egress, and staging will not interfere with
vehicle parking, pedestrian paths, or bicycle lanes/bicycle parking.
6. Establish freight pick up & drop off times that do not coincide with peak
commute hours to reduce passenger vehicle conflicts and congestion for
freight. Consider designating on -street freight -only parking and delivery time
windows so trucks will not resort to double parking, thus causing street traffic
congestion.
7. For the multifamily residential units proposed, consider how many individual
packages will be delivered daily to individual residences. Amazon lockers or an
equivalent shared drop-off location can help reduce the amount of driving
done by delivery trucks and can increase the efficiency of deliveries.
8. Work with local partners and community representatives to mitigate any truck
traffic routing onto residential streets or conflicting with other road users,
including and especially bicyclists and pedestrians.
"Provide a safe and reliable transportation network that serves all people and respects the environment"
Ms. Samantha Beier
March 18, 2024
Page 3
9. In the event of any work performed within Caltrans right-of-way, an
encroachment permit will be required prior to construction. Please submit all
applications and associated documents/plans via online web portal base
Caltrans Encroachment Permit System (CEPS) at https://ceps.dot.ca.gov/
10.Any work performed within Caltrans right of way (R/W) will require discretionary
review and approval by Caltrans and an encroachment permit will be required
for any work within the Caltrans R/W prior to construction. Prior to submitting to
Caltrans Permit's branch, applicant should fill out Applicant's Checklist to
Determine Applicable Review Process (QMAP List) Form TR-0416 to determine if
project oversight/coordination with Caltrans Project Manager is needed.
Applicant must submit a signed Standard Encroachment Permit application
form TR-0100 along with a deposit payable to Caltrans. Deposit amount will be
dependent on when the application is submitted. Public corporations are legally
exempt from encroachment permit fees. Please note that all utility work should
be disclosed prior to permit submittal, and utility companies are to apply for
separate permits for their corresponding work.
Please continue to coordinate with Caltrans for any future developments that could
potentially impact State transportation facilities. If you have any questions, please do
not hesitate to contact Maryam Molavi, at Maryam.Molavi@dot.ca.gov.
Sincerely,
1�
Scott Shelley
Branch Chief - Local Development Review/Climate Change/Transit
District 12
"Provide a safe and reliable transportation network that serves all people and respects the environment"
ORANGE COUNTY FIRE AUTHORITY
P. O. Box 57115, Irvine, CA 92619-7115 • 1 Fire Authority Road, Irvine, CA 92602-0125
Brian Fennessy, Fire Chief (714) 573-6000 www.ocfa.org
March 19th, 2024
Samatha Beier Senior Planner
SBeler@tustinca.org
(714) 573 3354
Subject: Notice of Preparation of EIR for Enderle Center Tustin Ca
Dear Samatha:
Thank you for the opportunity to review the subject document. The Orange County Fire
Authority (OCFA) provides fire protection and emergency medical services response to 23
cities in Orange County and all unincorporated areas. The OCFA operates 78 fire stations
throughout Orange County.
We believe that the project will have less than a significant impact.
Please contact me at 714-573-6102 if you have any questions.
Sincerely.
Todd Letterman
Assistant Fire Marshal
Planning and Development
toddlettennan@ocfa.org
www.ocfa.org
Serving the Cities of. Aliso Viejo • Buena Park • Cypress • Dana Point • Garden Grove • Irvine • Laguna Hills • Laguna Niguel • Laguna Woods
Lake Forest • La Palma • Los Alamitos • Mission Viejo • Rancho Santa Margarita -San Clemente • San Juan Capistrano • Santa Ana
Seal Beach • Stanton • Tustin • Villa Park • Westminster • Yorba Linda • and Unincorporated Areas of Orange County
RESIDENTIAL SPRINKLERS AND SMOKE ALARMS SAVE LIVES
Enderle Center Rezone Project
Initial Study
Lead Agency:
City of Tustin
300 Centennial Way
Tustin, CA 92780
CEQA Consultant:
ENVIRONMENT I PLANNING I DEVELOPMENT SOLUTIONS, INC.
3333 Michelson Drive, Suite 500
Irvine, CA 92612
February 2024
of Tustin
Contents
Enderle Center Rezone Project
Initial Studv
1 INTRODUCTION.............................................................................................................................1
1.1 Purpose of the Initial Study..........................................................................................................................1
1.2 Document Organization.................................................................................................................................1
2 ENVIRONMENTAL SETTING...........................................................................................................3
2.1 Project Background........................................................................................................................................3
2.2 Project Location...............................................................................................................................................3
2.3 Existing Project Site........................................................................................................................................4
2.4 Existing General Plan Land Use and Zoning Designations.....................................................................4
2.5 Surrounding Land Uses..................................................................................................................................4
3 PROJECT DESCRIPTION................................................................................................................16
3.1 Project Overview.........................................................................................................................................
16
3.2 Project Features...........................................................................................................................................
16
3.3 Project Objectives........................................................................................................................................
18
3.4 Discretionary Approvals and Permits......................................................................................................
18
4 ENVIRONMENTAL CHECKLIST......................................................................................................22
4.1 Background...................................................................................................................................................22
4.2 Environmental Factors Potentially Affected............................................................................................
22
4.3 Determination...............................................................................................................................................23
4.4 Evaluation of Environmental Impacts........................................................................................................
24
5 ENVIRONMENTAL ANALYSIS.......................................................................................................25
5.1
Aesthetics.......................................................................................................................................................25
5.2
Agriculture and Forestry Resources..........................................................................................................
28
5.3
Air Quality....................................................................................................................................................
30
5.4
Biological Resources....................................................................................................................................
31
5.5
Cultural Resources........................................................................................................................................
34
5.6
Energy............................................................................................................................................................37
5.7
Geology and Soils.......................................................................................................................................
38
5.8
Greenhouse Gas Emissions.........................................................................................................................
44
5.9
Hazards and Hazardous Materials.........................................................................................................45
5.10
Hydrology and Water Quality................................................................................................................
49
5.11
Land Use and Planning...............................................................................................................................
56
5.12
Mineral Resources........................................................................................................................................
57
5.13
Noise..............................................................................................................................................................
58
5.14
Population and Housing..............................................................................................................................
59
5.15
PublicServices..............................................................................................................................................
60
5.16
Recreation.....................................................................................................................................................
61
5.17
Transportation..............................................................................................................................................
62
5.18
Tribal Cultural Resources............................................................................................................................
63
5.19
Utilities and Service Systems.....................................................................................................................
64
5.20
Wildfire.........................................................................................................................................................65
5.21
Mandatory Findings of Significance........................................................................................................
66
6 REFERENCES.................................................................................................................................68
of Tustin
Tables
Enderle Center Rezone Project
Initial Studv
Table 1-1: Surrounding Existing Land Use and Zoning Designations..................................................................A
Table 1-2: Existing and Proposed Project Site Characteristics......................................................................... 16
Figures
Figure 2-1: Regional Location................................................................................
Figure2-2: Local Vicinity........................................................................................
Figure2-3: Aerial.....................................................................................................
Figure 2-4: Existing General Plan Land Use .......................................................
Figure2-5: Existing Zoning.....................................................................................
Figure 3-1: Proposed Zoning.................................................................................
List of Appendices
Appendix A Cultural Record Search Results
Acronym List
A-P
Alquist-Priolo Earthquake Fault Zoning Act
AQMP
Air Quality Management Plan
AB
Assembly Bill
APN
Assessor's Parcel Numbers
BMPs
Best Management Practices
CARB
California Air Resources Board
CBC
California Building Code
CEQA
California Environmental Quality Act
CNEL
Community Noise Equivalent Level
dBA
A -weighted decibel
EIR
Environmental Impact Report
ESA
Environmental Site Assessment
FEMA
Federal Emergency Management Agency
FIRM
Flood Insurance Rate Maps
GHG
Greenhouse Gas
MBTA
Migratory Bird Treaty Act
NAAQS
National Ambient Air Quality Standards
NPDES
National Pollutant Discharge Elimination System
NAHC
Native American Heritage Commission
NOx
Nitrous Oxides
Os
Ozone
PM
Particulate Matter
RWQCB
Regional Water Quality Control Board
SB
Senate Bill
SCAQMD
South Coast Air Quality Management District
SCAG
Southern California Association of Governments
SWPPP
Stormwater Pollution Prevention Plan
TPZ
Timberland Production Zone
USFWS
United States Fish and Wildlife Service
USGS
United States Geologic Survey
WQMP
Water Quality Management Plan
........................................ 6
........................................ 8
.....................................
10
.....................................
12
.....................................
14
.....................................
20
Enderle Center Rezone Project
of Tustin Initial Studv
INTRODUCTION
1.1 PURPOSE OF THE INITIAL STUDY
This Initial Study has been prepared in accordance with the following:
• California Environmental Quality Act (CEQA) of 1970 (Public Resources Code Sections 21000 et
seq.); and
Guidelines for Implementation of the California Environmental Quality Act (State CEQA Guidelines)
(California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000 et seq.), as amended
and approved on December 28, 2018.
Pursuant to CEQA, this Initial Study has been prepared to analyze the potential for significant impacts on
the environment resulting from implementation of the proposed Project, described in greater detail in Section
3.0, Project Description. As required by State CEQA Guidelines Section 15063, this Initial Study is a
preliminary analysis prepared by the Lead Agency, the City of Tustin, to determine if a Mitigated Negative
Declaration or an Environmental Impact Report is required to evaluate the potential environmental impacts
associated with the Project.
This Initial Study informs the City of Tustin decision -makers, affected agencies, and the public of potentially
significant environmental impacts associated with the implementation of the Project. A "significant effect" or
"significant impact" on the environment means "a substantial, or potentially substantial, adverse change in any
of the physical conditions within the area affected by the project" (State CEQA Guidelines Section15382).
Given the Projects broad scope and level of detail, combined with previous analyses and current information
about the site and environs, the City's intent is to adhere to the following CEQA principles:
• Provide meaningful early evaluation of site planning constraints, service and infrastructure
requirements, and other local and regional environmental considerations (Public Resources Code
Section 21003.1).
• Encourage the applicant to incorporate environmental considerations into project conceptualization,
design, and planning at the earliest feasible time (State CEQA Guidelines Section 15004[b][3]).
• Specify mitigation measures for reasonably foreseeable significant environmental effects and
commit the City to future measures containing performance standards to ensure their adequacy when
detailed development plans and applications are submitted (State CEQA Guidelines Section
15126.4).
1.2 DOCUMENT ORGANIZATION
This Initial Study includes the following sections:
Section 1. Introduction
Provides information about CEQA and its requirements for environmental review and explains that an Initial
Study was prepared to evaluate the proposed Project's potential impacts to the physical environment, and
to determine if an Environmental Impact Report (EIR) is required.
Section 2. Environmental Setting
Provides information about the proposed Project's location.
of Tustin
Section 3. Project Description
Enderle Center Rezone Project
Initial Studv
Includes a description of the proposed Project's physical features and characteristics.
Section 4. Environmental Checklist
Includes the Environmental Checklist from Appendix G of the State CEQA Guidelines and identifies what
subject areas were determined to be new significant environmental effects or previously identified effects
that have a substantial increase in severity, based on the analysis in Section 5.
Section 5. Environmental Analysis
Evaluates the proposed Project's potential to result in significant adverse effects to the physical environment
and identifies if an EIR is required, and what environmental topics need to be analyzed in the EIR if so.
Enderle Center Rezone Project
of Tustin Initial Studv
2 ENVIRONMENTAL SETTING
2.1 PROJECT BACKGROUND
The City of Tustin prepared the 2021-2029 Housing Element Update of the General Plan in accordance
with Government Code Section 65580 et seq. The City is required by State law to periodically update its
Housing Element, a mandatory component of the City's General Plan. The update to the Housing Element
covers the Sixth Cycle planning period from October 15, 2021, to October 15, 2029. The Housing Element
is the City's housing policy and planning document that identifies housing needs and constraints, and sets
forth goals, policies, and programs that address the future housing needs for all income levels over an eight -
year planning period that coincides with a Regional Housing Needs Allocation (RHNA).
On October 5, 2021, the City Council adopted Resolution No. 21-86, certifying the Negative Declaration
(ND) for GPA 2021-0002 (and Resolution No. 21-87, approving GPA 2021-0002), which analyzed
environmental impacts related to the City's Draft Housing Element Update of the General Plan. The Draft
Housing Element Update was prepared, as required by State Housing Element law. Following preparation
of the Draft Housing Element Update and certification of the ND, the Draft Housing Element went through
several rounds of revisions and submittal for review to the State Department of Housing and Community
Development (HCD). The City received formal certification of the Housing Element Update from HCD on
September 12, 2022. On October 4, 2022, the City Council adopted Resolution No. 22-47, approving
General Plan Amendment 2022-0002 for the final Housing Element Update.
The 2021-2029 Housing Element includes several provisions that aim to ensure the City can meet the required
"fair share" of affordable housing units, as specified by the State of California. During the Housing Element
process, the City assessed a number of properties and areas throughout the community that would be able
to accommodate the City's assigned 2021 Regional Housing Needs Allocation (RHNA). The City identified
19 sites and one housing category (accessory dwelling units [ADUs]/junior accessory dwelling units [JADUs])
as qualifying sites to accommodate their RHNA allocation. Of the 19 Housing Element inventory sites, Enderle
Center (Housing Element Site 17) was identified as necessary for rezoning under Housing Element Program
1.1 f to allow for high density residential/mixed use development.
Enderle Center (the Project site) consists of approximately 11.80 acres of privately owned property.
Currently, the Project site is developed with a commercial center. Of the site area, 7 acres within the
southeastern portion of the Project site have been identified as suitable for housing development. These 7
acres are currently made up of paved parking areas. Based on the proposed overlay zone, redevelopment
of 7 acres of the site would accommodate up to 413 housing units.
2.2 PROJECT LOCATION
The Project site is approximately 1 1.80 acres and is located within the City of Tustin. The City is in the
central portion of Orange County and is surrounded by the cities of Irvine to the south and east, Santa Ana
to the west, and Orange and unincorporated Orange County to the north. Major freeways and highways
within or bordering the City of Tustin are the 1-5 freeway through the center, State Route (SR) 55 to the west,
SR 261 to the east, and the 1-405 freeway to the south, as illustrated in Figure 2-1, Regional Location.
The Project site is generally bounded on the north by 17th Street; on the east by Enderle Center Drive and
the eastern property line of properties fronting Enderle Center Drive; to the south by Vandenberg Lane;
and to the west by the 55 freeway, including properties west of Yorba Street. The Project site consists of
Assessor Parcel Numbers (APNs) 401-251-04, -05, and -06; 401-252-05, -06, -08, -09, and -10; and 401-
253-03 and -04.
The local vicinity of the Project site is illustrated in Figure 2-2, Local Vicinity.
3
of Tustin
2.3 EXISTING PROJECT SITE
Enderle Center Rezone Project
Initial Studv
The Enderle Center is currently developed with 87,136 SF of commercial business, including 28,750 SF of
restaurant use, 39,960 SF of retail and service use, 18,426 SF of office use, and surface parking lots. The
site also includes ornamental landscaping along the perimeter and throughout the parking areas. Figure 2-
3, Aerial, illustrates the Project site in its current condition.
2.4 EXISTING GENERAL PLAN LAND USE AND ZONING DESIGNATIONS
The Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM). The PCCB land use designation
provides opportunities for a variety of miscellaneous retail, professional office, and service -oriented business
activities. The PC COM zoning is intended to allow diversification of the relationships of various buildings,
structures and open spaces in planned building groups, while ensuring substantial compliance with the district
regulations and other provisions of the Planned Community District zone.
The Project site's existing General Plan land use and zoning designations are shown in Figure 2-4, Existing
General Plan Land Use and Figure 2-5, Existing Zoning.
2.5 SURROUNDING LAND USES
The Project site is located within a developed area. The surrounding land uses and their designations are
described in Table 1-1.
Table 1-1: Surrounding Existing Land Use and Zoning Designations
Existing Land Use
General Plan Designation
Zoning Designation
1 Th Street followed by
Community Commercial (CC),
Retail Commercial (Cl) with Parking
North
commercial, residential and
Planned Community
Overlay, Commercial General
office uses
Commercial/Business (PCCB)
(CG), & Planned Community
Commercial (PC COM)
East
Enderle Center Drive followed
Planned Community
Planned Community Commercial
by office uses
Commercial/Business (PCCB)
(PC COM)
South
Vandenberg Lane followed by
Planned Community Residential
Planned Community Residential
residential uses
(PCR)
(PC RES)
Tustin city limits and SR-55
Professional and Administrative
Professional (P) &
freeway, followed by
Office (PAO) &
West
restaurants and office uses in
General Commercial (GC)
Community Commercial (Cl)
the City of Santa Ana
(City of Santa Ana)
(City of Santa Ana)
4
of Tustin
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Enderle Center Rezone Project
Initial Studv
Regional Location
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Enderle Center Rezone Project Figure 2-1
City of Tustin
of Tustin
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Enderle Center Rezone Project
Initial Studv
Local Vicinity
T F 1-
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Project Site A
Enderle Center Rezone Project Figure 2-2
City of Tustin
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Enderle Center Rezone Project
Initial Studv
Aerial View
N
ri Project Site A
Enderle Center Housing Overlay Figure 2-3
City of Tustin
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Enderle Center Rezone Project
Initial Studv
11
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0 F VIO
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■■■
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of Tustin
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Enderle Center Rezone Project
Initial Studv
13
Existing Zoning
Q Project Site
1UNUM111111110
'"MEMO
NONE
N
A
Q R1 - Single Family Residential - C1 - Retail Commercial
- R2 - Duplex Residential - C2 - Central Commercial
R3 - Multiple Family Residential - CG - Commercial General
- R4 - Suburban Residential - PC COM - Planned Community Commercial
JlIlloq PC RES - Planned Community Residential = PM - Planned Industrial
PD - Planned Development - M - Industrial
- MHP - Mobile Home Park - PC IND - Planned Community Industrial
PR - Professional - PI - Public and Institutional
= PCPI - Planned Community Public and Institutional
Enderle Center Housing Overlay Figure 2-5
City of Tustin
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Enderle Center Rezone Project
Initial Studv
15
of Tustin
3 PROJECT DESCRIPTION
3.1 PROJECT OVERVIEW
Enderle Center Rezone Project
Initial Studv
Pursuant to Housing Element Program 1.1 f, the City is proposing an overlay zone ("overlay district") for the
project site. To accommodate this, a General Plan Amendment (GPA) is needed to establish that higher
density residential uses are allowed in the Planned Community Commercial Business Designation when
prescribed by a Housing Overlay (HO) district or a Specific Plan (SP); a Zoning Code Amendment (CA) to
establish a Housing Overlay zoning district (overlay zone) and associated criteria, which will be applied in
conjunction with the Planned Community Commercial District (base zone); and a Zone Change (ZC) that
amends the City's zoning map to apply a Housing Overlay (HO) district to the project site. The proposed
HO district would allow residential development of 413 dwelling units over a maximum area of seven (7)
acres.
The proposed project is consistent with the City's adopted Housing Element, which identified the Enderle
Center as having capacity for 41 3 housing units on seven acres of the existing Center's parking lots (equating
to 59 dwelling units per acre). The anticipated development density was determined through the Housing
Element process and is a conservative estimate based on development trends in nearby communities. The
anticipated development does not rely on the demolition of any existing building, but rather focuses on areas
used for surface parking. No development is proposed as part of this Project, but this Draft EIR has analyzed
all known anticipated impacts of the development of the proposed housing units. Table 1-2 lists the existing
and proposed Project site land use regulation characteristics.
Table 1-2: Existing and Proposed Project Site Characteristics
Existing
Proposed
Maximum
Maximum
Maximum
GP Land
Zoning
Allowable
GP Land
Zoning
Residential
Allowable
Use
Designation
Use
Designation
Units
Acreage
Units
Enderle
PC COM &
Center
PCCB
PC COM
0
PCCB
HO
7
413
3.2 PROJECT FEATURES
Proposed Housing Overlay District
During the Housing Element process, the City identified the Enderle Center as a suitable commercial site for
rezoning to allow mixed -use development, which introduced the opportunity to allow higher density housing
in either horizontal or vertical mixed -use development on the site. This would be accomplished with a "housing
overlay" zone.
The housing overlay zone would allow residential land uses in addition to the uses allowed under the existing
PC COM zoning. Thus, the Housing Overlay (HO) district would be added "on top" of the existing PC COM
zone (i.e., Base Zone). The overlay zone would also provide development standards related to parking,
height, noise, and other criteria applicable to residential uses. The HO district text will include a provision
that the HO district supersedes the development standards and allowed uses listed within the Base Zone.
Residential uses are currently not allowed on the Project site. Upon approval of the Housing Overlay (HO)
district, the Project site could accommodate 413 units on approximately 7 acres of developable land within
the existing 1 1.8-acre site. This could result in a density of 59 dwelling units per acre (du/ac). The anticipated
development over 7 acres may take place on underutilized asphalt parking lot areas and does not require
Enderle Center Rezone Project
of Tustin Initial Studv
demolition of existing buildings. Parking displaced as a result of redevelopment would be accommodated
by vertical parking structures located within the Project site.
Proposed General Plan Amendment
As described in Section 2, Environmental Setting, the Project site has a General Plan land use designation of
Planned Community Commercial/Business (PCCB). The PCCB designation is part of the City's General Plan
Planned Community (PC) designations and is intended to provide for a mix of commercial and office uses
such as hotel/motels, commercial centers, research and development, and professional offices. The Planned
Community Commercial designation may also permit other uses that support this land use designation, such
as residential uses. The overall population density range for residential uses within the PCCB designation is
2 to 54 persons per acre. The proposed General Plan Amendment (GPA) via text will establish that a higher
density of residential uses are allowed in the PCCB designation subject to limits contained within a Housing
Overlay (HO) district (zoning) or as allowed by a specific plan.
Proposed Zone Code Amendment
The Project includes an amendment to Tustin City Code (TCC), Article 9 (Land Use), Chapter 2 (Zoning), Part
5, to establish a Housing Overlay (HO) district, which allows for high density residential development, and
stipulates that objective development standards and design guidelines will apply to properties within the
boundary of the Housing Overlay (HO) district.
Proposed Zone Change
The Project also includes an amendment to the City's Zoning Map to add the newly codified Housing Overlay
(HO) district on top of the site's existing PC COM zoning. Figure 3-1, Proposed Zoning, illustrates the
proposed zone change.
Nonresidential Buildout
The Project site is envisioned to function as a mixed -use site, with a portion of the Project site maintaining
nonresidential land uses. The Project site has a General Plan land use designation of Planned Community
Commercial/Business (PCCB). The General Plan PCCB designation allows for development of a Floor Area
Ratio (FAR) up to 1.5:1 (one -and -a -half to one). However, the General Plan assumes the average site to
develop up to an FAR of 0.4:1. Based on the General Plan development assumption, the Project site is
assumed to be developed with 205,603 SF of nonresidential uses.
The Enderle Center is currently developed with 87,136 SF of commercial businesses, including 28,750 SF of
restaurant use, 39,960 SF of retail and service use, and 18,426 SF of office use. Therefore, the total
remaining nonresidential use assumed for future buildout of the Project site is 118,467 SF.
Therefore, the Project anticipates the additional development of nonresidential uses of 1 18,467 SF in the
future, for a total nonresidential development capacity of 205,603 SF on the Project site, pursuant to the
General Plan. Future nonresidential projects proposed that are within the remaining development capacity
of the site would be required to comply with the existing PCCB development standards and the City's plan
review process. Future nonresidential development is anticipated to be developed within exiting
undeveloped areas, and the Project does not assume demolition of existing structures. A specific development
project is not proposed as part of this Project.
Housing Element Programs Applicable to the Project Site
The 2021-2029 Housing Element included several housing programs to be implemented during the 2021-
2029 planning period. The discussion below outlines three programs that are applicable to the proposed
Project.
17
of Tustin
Program 1.2a
Enderle Center Rezone Project
Initial Studv
Program 1.2a provides that the City will amend its Zoning Code to remove subjective design guidance in
TCC Section 9272 (Design Review) and adopt new Objective Design Standards (ODS) to ensure that the
City can provide clear guidance regarding project design, in order to streamline the development of high -
quality residential development. The ODS would include provisions consistent with the requirements of Senate
Bill (SB) 35. Program 1.2a is anticipated to be complete in October 2024.
Program 1.2c
Program 1.2c directs the City to develop parking standards to facilitate residential housing production as
part of mixed -use developments, adaptive reuse projects, and new residential developments. The program
provides that parking displaced as a result of redevelopment may be replaced with vertical parking
structures, as needed, to provide required parking. Additionally, the parking standards would incentivize
creative parking strategies such as parking credits for transit rich development, and allowance of parking
structures and parking lifts, by right and subject to the ODS.
Infrastructure Improvements
Roadways and utilities may be required to support development of future residential construction within the
Project site. Future onsite infrastructure improvements that may be necessary for residential development
within the Enderle Center include storm drains, wastewater, water, and dry utilities that would connect to
existing facilities within the Project site or adjacent to the Project area. Specific infrastructure improvements
required to support residential development within the Enderle Center are not known at this time and will
not be known until a development project is proposed.
3.3 PROJECT OBJECTIVES
CEQA Guidelines §151 24(b) (14 California Code of Regulations [CCR]) requires "A statement of objectives
sought by the proposed project. A clearly written statement of objectives would help the Lead Agency
develop a reasonable range of alternatives to evaluate in the EIR and would aid the decision makers in
preparing findings or a statement of overriding considerations, if necessary. The statement of objectives
should include the underlying purpose of the project." The primary purpose and goal of the Project is to
accommodate the City's 6th Cycle RHNA identified within the City of Tustin 2021-2029 Housing Element.
The Project would achieve this goal through the following objectives:
• Creation of a Housing Overlay (HO) district to allow residential development at densities which
achieve the estimated capacities determined in the Housing Element, and without inhibitors to
residential development.
• Increase the number of housing opportunities available in Tustin to ensure the City provides its fair
share of housing units within a variety of income categories.
• Increase flexibility in allowed uses and development potential within an underutilized area of the
City of Tustin.
• Promote a diverse housing stock with products that are offered at a wide range of sizes and
affordability.
3.4 DISCRETIONARY APPROVALS AND PERMITS
Preparation of an EIR is anticipated for the Project. The City of Tustin has primary approval responsibility
for the Project. As such, the City serves as the Lead Agency for the EIR pursuant to CEQA Guidelines §15050.
The Tustin Planning Commission will evaluate the EIR and the Project and make a recommendation to the City
Council as to whether the Project should be approved and the EIR certified. The City Council is the decision -
making authority for the Project, and therefore will consider the Project along with the Planning Commission's
18
Enderle Center Rezone Project
of Tustin Initial Studv
recommendations, and make a final decision to approve, approve with changes, or deny the Project. The
City, including the Planning Commission and the City Council, will consider the information in the EIR and the
Project's administrative record in its decision -making processes. In the event that the Council certifies the EIR
and approves the Project, the City would subsequently conduct administrative and discretionary review of
development proposals and grant ministerial and discretionary permits and approvals that implement
Project requirements, conditions of approval, and future development within the Enderle Center.
Approval and implementation of the Housing Overlay (HO) district requires City approval of the following
discretionary actions:
• Certification of the EIR;
• Adoption of the GPA to allow higher density residential uses within Planned Community
Commercial/Business land use designations, subject to residential densities and development restrictions
established by a Housing Overlay (HO) district or specific plan;
• Adoption of a Zoning Code Amendment (CA) to establish the zoning, development regulations,
guidelines, and implementation provisions governing development of the Housing Overlay District.
• Adoption of a Zone Change (ZC) to modify the City's Zoning Map to add the Housing Overlay (HO)
district over the site's existing PC COM zoning; and
• Approval of a Housing Overlay (HO) district for the 1 1.8-acre Project site, authorizing 413 dwelling
units on 7 (seven) acres.
The EIR may be used by various governmental decisionmakers for discretionary permits and actions that are
necessary or may be requested in connection with implementation of future development projects pursuant
to the Project. Additional discretionary, administrative, and/or ministerial actions may be necessary from
other responsible agencies to fully implement the Project. The state or local agencies that may rely upon the
information contained in the EIR, when considering approval of permits, may include the following:
• Tustin Unified School District.
NO
Proposed Zoning
m_ m_ 111
== _■■ �■ I_ �a
■
Z �
0 Project Site ® HO -Housing Overlay
Q R1 - Single Family Residential EM C1 - Retail Commercial
- R2 - Duplex Residential = C2 - Central Commercial
R3 - Multiple Family Residential - CG - Commercial General
= R4 - Suburban Residential = PC COM - Planned Community Commercial
PC RES - Planned Community Residential = PM - Planned Industrial
PD - Planned Development - M - Industrial
MHP - Mobile Home Park - PC IND - Planned Community Industrial
= PR - Professional = PI - Public and Institutional
= PCPI - Planned Community Public and Institutional
' r■■r■rr■■ I
I
■mill■lN
■■■■■■■1
■■■■■■■1
■■■■■■■■■■■I
M
■■■1■■
otommom
A
Enderle Center Housing Overlay Figure 3-1
City of Tustin
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Enderle Center Rezone Project
Initial Studv
21
City of Tustin
4 ENVIRONMENTAL CHECKLIST
4.1 BACKGROUND
Enderle Center Rezone Project
Initial Study
Project Title: Enderle Center Rezone Project
Lead Agency: City of Tustin
Lead Agency Contact: Samantha Brier, Senior Planner
Project Location: 17350 17th St, Tustin, CA 92780
Project Sponsor's Name and Address: City of Tustin, 300 Centennial Way, Tustin, CA 92780
Existing General Plan and Zoning Designation: The Project site has a General Plan land use designation
of Planned Community Commercial/Business (PCCB) as shown in Figure 2-4, Existing General Plan Land
Use; and a zoning designation of Planned Community Commercial (PC COM) as shown in Figure 2-5,
Existing Zoning.
Project Description: Pursuant to Housing Element Program 1.1 f, the City is proposing a GPA, CA, ZC, and
Housing Overlay (HO) zone to allow residential development within the Enderle Center. The Housing
Element identified the Enderle Center as having capacity for 413 housing units. The anticipated
development density was determined through the Housing Element process and is a conservative estimate
based on development trends in nearby communities. The anticipated development does not rely on the
demolition of any existing buildings, but rather focuses on areas used for surface parking.
Surrounding Land Uses and Setting:
North: 17t' Street followed by commercial, residential, and office uses.
East: Enderle Center Drive followed by a fast-food restaurant and office uses.
South: Vandenberg Lane followed by residential uses.
West: City limits and the SR-55 Freeway.
Other Public Agencies Whose Approval is Required: None.
4.2 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The subject areas checked below were determined to be new significant environmental effects or to be
previously identified effects that have a substantial increase in severity either due to a change in project,
change in circumstances or new information of substantial importance, as indicated by the checklist and
discussion on the following pages.
Aesthetics
Agriculture/Forestry Resources
®
Air Quality
Biological Resources
Cultural Resources
®
Energy
Geology/Soils
®
Greenhouse Gas Emissions
Hazards/Hazardous Materials
®
Hydrology/Water Quality
®
Land Use/Planning
Mineral Resources
®
Noise
®
Population/Housing
®
Public Services
®
Recreation
®
Transportation
®
Tribal Cultural Resources
®
Utilities and Service Systems
Wildfire
®
Mandatory Findings of
Significances
22
of Tustin
4.3 DETERMINATION
On the basis of this initial evaluation:
Enderle Center Rezone Project
Initial Studv
I find that the proposed project COULD NOT have a significant effect on the environment, and a
NEGATIVE DECLARATION will be prepared.
1 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 DECLARACTION will be prepared.
I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
® I find that the proposed project MAY have a "potentially significant" or "potentially significant
unless mitigated" impact on the environment, but at least one effect 1) has been adequately
analyzed in an earlier analysis pursuant to applicable legal standards, and 2) has been addressed
by mitigation measures based on the earlier analysis as described on attached sheets. An
ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to
be addressed.
I find that although the proposed project could have a significant effect on the environment, because
all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE
DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant
to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are
imposed upon the proposed project, nothing further is required.
Signature Date
Name and Title Lead Agency
23
Enderle Center Rezone Project
of Tustin Initial Studv
4.4 EVALUATION OF ENVIRONMENTAL IMPACTS
A brief explanation is required for all answers except "No Impact" answers that are adequately
supported by the information sources a lead agency cites in the parentheses following each question. A
"No Impact" answer is adequately supported if the referenced information sources show that the impact
simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture
zone). A "No Impact" answer should be explained where it is based on project -specific factors as well
as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a
project -specific screening analysis).
2. All answers must take account of the whole action involved, including offsite as well as on -site, cumulative
as well as project -level, indirect as well as direct, and construction as well as operational impacts.
3. Once the lead agency has determined that a particular physical impact may occur, then the checklist
answers must indicate whether the impact is potentially significant, less than significant with mitigation,
or less than significant. "Potentially Significant Impact" is appropriate if there is substantial evidence
that an effect may be significant. If there are one or more "Potentially Significant Impact" entries when
the determination is made, an EIR is required.
4. "Negative Declaration: Potentially Significant Unless Mitigation Incorporated" applies where the
incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to a
"Less Significant Impact." The lead agency must describe the mitigation measures, and briefly explain
how they reduce the effect to a less than significant level (mitigation measures from "Earlier Analysis,"
as described in (5) below, may be cross-referenced).
5. Earlier analysis may be used where, pursuant to the tiering, program EIR, or other CEQA process, an
effect has been adequately analyzed in an earlier EIR or negative declaration. Guidelines Section
15063 (c)(3)(d). In this case, a brief discussion should identify the following:
a) Earlier Analysis Used. Identify and state where they are available for review.
b) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope
of and adequately analyzed in an earlier document pursuant to applicable legal standards, and
state whether such effects were addressed by mitigation measures based on the earlier analysis.
c) Mitigation Measures. For effects that are "Less than Significant with Mitigation Measures
Incorporated," describe the mitigation measures which were incorporated or refined from the earlier
document and the extent to which they address site -specific conditions for the project.
6. Lead agencies are encouraged to incorporate into the checklist references to information sources for
potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside
document should, where appropriate, include a reference to the page or pages where the statement is
substantiated.
7. Supporting Information Sources: A source list should be attached, and other sources used, or individuals
contacted should be cited in the discussion.
8. This is only a suggested form, and lead agencies are free to use different formats; however, lead
agencies should normally address the questions from this checklist that are relevant to a project's
environmental effects in whatever format is selected.
9. The analysis of each issue should identify: (a) the significance criteria or threshold used to evaluate each
question; and (b) the mitigation measure identified, if any, to reduce the impact to less than significance.
24
of Tustin
5 ENVIRONMENTAL ANALYSIS
Enderle Center Rezone Project
Initial Studv
This section provides evidence to substantiate the conclusions in the environmental checklist.
5.1 AESTHETICS
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
a)
Have a substantial adverse effect on a scenic vista?
El
El
El
E
b)
Substantially damage scenic resources, including, but
El
El
El
E
not limited to, trees, rock outcroppings, and historic
buildings within a state scenic highway?
c)
In nonurbanized areas, substantially degrade the
El
El
U
El
existing visual character or quality of public views of
the site and its surroundings? (Public views are those
that are experienced from publicly accessible vantage
point). If the project is in an urbanized area, would the
project conflict with applicable zoning and other
regulations governing scenic quality?
d)
Create a new source of substantial light or glare which
El
El
El
would adversely affect day or nighttime views in the
area?
a) Have a substantial adverse effect on a scenic vista?
No Impact. Scenic vistas consist of expansive, panoramic views of important, unique, or highly valued visual
features that are seen from public viewing areas. This definition combines visual quality with information
about view exposure to describe the level of interest or concern that viewers may have for the quality of a
particular view or visual setting. A scenic vista can be impacted in two ways: a development project can
have visual impacts by either directly diminishing the scenic quality of the vista or by blocking the view
corridors or "vista" of the scenic resource. Important factors in determining whether a proposed project would
block scenic vistas include the project's proposed height, mass, and location relative to surrounding land uses
and travel corridors.
The City of Tustin General Plan designates landforms and visual interest points as scenic resources within the
Conservation Element (City of Tustin, 2018). The City of Tustin protects public views along the ridge lines,
views toward the inland mountains and along scenic transportation corridors. Specifically, Policy 35, Protect
Scenic Views and Resources, protects views of the Peter Canyon Ridgeline:
Policy 35. Protect Scenic Views and Resources: Through the Hillside Review process, monitor and
limit development of Peters Canyon Ridgeline consistent with the requirements of the East Tustin
Specific Plan, Grading and Excavation Code and Grading Manual.
The Project site is currently developed as a commercial site and is surrounded by other commercial
developments. The view of Peters Canyon Ridgeline from the Project site is obstructed by surrounding
buildings and trees. The Project site is bordered by 1711 Street to the north, which offers limited public views
of Peters Canyon Ridgeline to motorists, bicyclists, and pedestrians traveling eastbound. Views to the east
from CA-55 are completely obstructed by adjacent developments and the raised embankment.
25
Enderle Center Rezone Project
of Tustin Initial Studv
The Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM). The Project would include a GPA,
CA and rezone of the Project site with a Housing Overlay (HO) district to allow for future development of
up to 413 housing units, consistent with the City's certified 2021-2029 Housing Element. Future residential
development would be constructed within the boundaries of the existing Enderle Center site and would not
impede any existing views of Peters Canyon Ridgeline from 1711 Street. The provision for residential
development in an area formerly designated for nonresidential land uses would not further diminish views
of a scenic vista. Therefore, the Project would result in no impact.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway?
No Impact. According to the California Department of Transportation (Caltrans) Scenic Highway Map, the
City of Tustin does not contain any scenic highways within or surrounding the City (California Department of
Transportation, 2018). The nearest state scenic highway is Route 91 in the City of Orange, approximately
8.5 miles to the north. According to the County of Orange General Plan, there are no designated scenic
roadways or scenic vistas in the Project vicinity (County of Orange, 2005). Therefore, the Project would have
no impact on scenic resources within a state scenic highway.
c) In nonurbanized areas, substantially degrade the existing visual character or quality of public views
of the site and its surroundings? (Public views are those that are experienced from publicly
accessible vantage point). Or if the project is in an urbanized area, would the project conflict with
applicable zoning and other regulations governing scenic quality?
Less Than Significant Impact. The Project site has a General Plan land use designation of Planned
Community Commercial/Business (PCCB) and a zoning designation of Planned Community Commercial (PC
COM). The Project site is currently developed as a commercial site and is surrounded by other commercial
developments. The Project site is bordered to the north by 17th Street, followed by commercial, residential
and office uses; to the east by Enderle Center Drive, followed by office uses; to the south by South
Vandenberg Lane, followed by residential uses; and to the west by Tustin city limits and SR-55 freeway,
followed by restaurants and office uses in the City of Santa Ana (see Table 1-1). The Project would include
a GPA, CA and rezone of the Project site with a Housing Overlay (HO) district to allow for future
development of up to 413 housing units, consistent with the City's certified 2021-2029 Housing Element.
Per Housing Element Program 1.2a, the City will develop objective development standards (ODS) to ensure
high quality residential development, while simultaneously meeting the City's goal of streamlining residential
development to meet its RHNA goals. Development is not proposed as part of the Project; however, all future
residential development proposed within the Project site would be subject to the requirement and provisions
of the applicable ODS. Commercial development within the Enderle Center does not currently have a
maximum height limit or required setback distances, and site design is evaluated on a project -by -project
basis due to the properties designation as Planned Community Commercial (PC COM). Design requirements
established through ODS for the site would be created to ensure compatibility with the existing site
development and surrounding land uses, such as compatible building height, cohesive architectural style, and
appropriate landscaping. The ODS would ensure high visual character and quality of future residential
development proposed within the Project site. All future development would be required to comply with the
City's ODS for the site. Therefore, the Project would not conflict with applicable zoning and other regulations
governing scenic quality and would have a less than significant impact on visual character and quality.
26
Enderle Center Rezone Project
of Tustin Initial Studv
d) Create a new source of substantial light or glare which would adversely affect day or nighttime
views in the area?
Less Than Significant Impact. Spill light occurs when lighting fixtures, such as streetlights, parking lot lighting,
exterior building lighting, and landscape lighting, are not properly aimed or shielded to direct light to the
desired location, and light escapes and partially illuminates a surrounding location. Sensitive uses (e.g.,
residential uses) surrounding the Project site could be impacted by the light from development within the
boundaries of the Project site if light spill occurs.
Glare is the result of improperly aimed or blocked lighting sources that are visible against a dark
background, such as the night sky. Glare may also refer to the sensation experienced looking into an
excessively bright light source that causes a reduction in the ability to see or causes discomfort. Glare
generally does not result in illumination of off -site locations but results in a visible source of light viewable
from a distance. Glare could also occur from building materials of the new structures, including glass and
other reflective materials.
The City of Tustin Municipal Code, Section 9271 hh, Light and Glare, includes the following requirements:
All exterior lighting shall be subject to the following standards, unless otherwise exempted by the
City of Tustin:
(a) Outdoor lighting shall be designed to minimize impacts from light pollution, including light
trespass and glare to minimize conflict caused by unnecessary illumination.
(b) Outdoor lighting fixtures that are used to illuminate a premises, architectural features or
landscape feature on private property shall be directed, shielded, or located in such a manner that
the light source is not directed off -site.
The Project does not propose development but would allow for the future development of residential land
uses within an existing commercial land use. Future development could add additional nighttime light sources,
such as landscape lighting, security lighting, and the lighting from additional cars. As previously discussed,
all future projects would be required to comply with the applicable ODS for the site. The ODS would include
specific setbacks, lighting standards, and building materials that would ensure the avoidance of potential
lighting impacts. Further, all future projects would be required to comply with the City's light and glare
ordinance, which would be verified through plan check prior to project approval. Therefore, the Project
would result in a less than significant impact.
27
of Tustin
5.2 AGRICULTURE AND FORESTRY RESOURCES
In determining whether impacts to agricultural resources are
Potentially
significant environmental effects, lead agencies may refer to
Significant
the California Agricultural Land Evaluation and Site
Impact
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 the
forest carbon measurement methodology provided in Forest
Protocols adopted by the California Air Resources Board.
Would the project:
a) Convert Prime Farmland, Unique Farmland, or Farmland
❑
of Statewide Importance (Farmland), as shown on the
maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency,
to non-agricultural use?
b) Conflict with existing zoning for agricultural use, or a
❑
Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning of, ❑
forest land (as defined in Public Resources Code section
12220(g)), timberland (as defined by Public Resources
Code section 4526), or timberland zoned Timberland
Production (as defined by Government Code section
51 104(g))?
Enderle Center Rezone Project
Initial Studv
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
❑ ❑
❑ ❑
❑ ❑
d) Result in the loss of forest land or conversion of forest land ❑ ❑ ❑
to non -forest use?
e) Involve other changes in the existing environment which, ❑ ❑ ❑
due to their location or nature, could result in conversion
of Farmland, to non-agricultural use or conversion of forest
land to non -forest use?
No
Impact
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the
maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California
Resources Agency, to non-agricultural use?
No Impact. The State of California Department of Conservation's Farmland Mapping and Monitoring
Program is charged with producing maps for analyzing impacts on the state's agricultural resources.
California's agricultural lands are rated based on soil quality and irrigation status. Per Section 21060.1 of
the State CEQA Guidelines, the following categories qualify as "agricultural land": Prime Farmland,
Farmland of Statewide Importance, or Unique Farmland.
Per the CDOC FMMP Map, the Project site is designated as Urban and Built -Up Land (California Department
of Conservation, 2018). Further, the City does not currently include any commercial agricultural land uses.
Existing zoning categories within the City of Tustin do not allow for commercial agricultural uses. Therefore,
the Project would result in no impact on Prime Farmland, Unique Farmland, or Farmland of Statewide
Importance.
28
of Tustin
Enderle Center Rezone Project
Initial Studv
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
No Impact. The Williamson Act (California Land Conservation Act of 1965) restricts the use of agricultural
and open space lands to farming and ranching by enabling local governments to contract with private
landowners for indefinite terms in exchange for reduced property tax assessments.
The Project site is currently developed with commercial land uses and does not include agricultural land uses.
The Project site is not currently under a Williamson Act contract. Therefore, the Project would result in no
impact on existing zoning for agricultural use or a Williamson Act contract.
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources
Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or
timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
No Impact. "Forest land" is defined as "land that can support 10 percent native tree cover of any species,
including hardwoods, under natural conditions, and that allows for management of one or more forest
resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other
public benefits." "Timberland" is defined as "land, other than land owned by the federal government and
land designated by the board as experimental forest land, which is available for, and capable of, growing
a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas
trees." "Timberland Production Zone" (TPZ) is defined as "an area which has been zoned pursuant to Section
51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and
harvesting timber and compatible uses, as defined in subdivision (h)."
The Project site is currently completely developed with commercial land use. The Project site does not include
forest land or timberland. Additionally, the Project site is currently zoned for Planned Community Commercial
(PC COM), which does not provide for forest land or timberland production and management. Therefore,
the Project would result in no impact on zoning of forest land or timberland.
d) Result in the loss of forest land or conversion of forest land to non -forest use?
No Impact. As discussed above, the Project site is currently completely developed as commercial land use
and does not include forest land. Therefore, the Project would have no impact on forest land.
e) Involve other changes in the existing environment which, due to their location or nature, could result
in conversion of Farmland to non-agricultural use or conversion of forest land to non -forest use?
No Impact. The Project site is within an urbanized area and is currently completely developed as commercial
land use. The area surrounding the Project site is also completely developed. The existing environment does
not include any agricultural land uses or forest land.
29
Enderle Center Rezone Project
City of Tustin Initial Study
5.3 AIR QUALITY
Where available, the significance criteria established by
Potentially
Less Than
Less Than
No Impact
the applicable air quality management or air pollution
Significant
Significant
Significant
control district may be relied upon to make the following
Impact
with
Impact
determinations. Would the project:
Mitigation
Incorporated
a) Conflict with or obstruct implementation of the
®
❑
❑
❑
applicable air quality plan?
b) Result in a cumulatively considerable net increase of
®
❑
❑
❑
any criteria pollutant for which the project region is
non- attainment under an applicable federal or state
ambient air quality standard?
c) Expose sensitive receptors to substantial pollutant
®
❑
❑
❑
concentrations?
d) Result in other emissions (such as those leading to odors)
®
❑
❑
❑
adversely affecting a substantial number of people?
a) through d)
Potentially Significant Impact. The Project site has a General Plan land use designation of Planned
Community Commercial/Business (PCCB) and a zoning designation of Planned Community Commercial (PC
COM). The Project would include a GPA, CA and rezone of the Project site with a Housing Overlay (HO)
district to allow for future development of up to 413 housing units, consistent with the City's certified 2021-
2029 Housing Element. The provision of development intensification could facilitate future operational air
quality impacts. Residential land uses have not been previously analyzed through applicable air quality
plans. The addition of residential land uses could result in a cumulatively considerable net increase of criteria
pollutants within the study area. Additionally, the introduction of new land uses to existing development could
expose sensitive receptors to substantial pollutant concentrations. Therefore, an air quality study will be
conducted for the Project to determine potential impacts and air quality impacts will be further analyzed
within the EIR.
30
Enderle Center Rezone Project
City of Tustin
Initial Study
5.4 BIOLOGICAL RESOURCES
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
a) Have a substantial adverse effect, either directly or
❑
❑
❑
through habitat modifications, on any species identified
as a candidate, sensitive, or special status species in local
or regional plans, policies, or regulations, or by the
California Department of Fish and Game or U.S. Fish and
Wildlife Service?
b)
Have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in
local or regional plans, policies, regulations or by the
California Department of Fish and Game or US Fish and
Wildlife Service?
c)
Have a substantial adverse effect on state or federally
❑
❑
❑
protected wetlands (including, but not limited to, marsh,
vernal pool, coastal, etc.) through direct removal, filling,
hydrological interruption, or other means?
d)
Interfere substantially with the movement of any native
❑
®
❑ ❑
resident or migratory fish or wildlife species or with
established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery
sites?
e)
Conflict with any local policies or ordinances protecting
❑
❑
® ❑
biological resources, such as a tree preservation policy
or ordinance?
f)
Conflict with the provisions of an adopted Habitat
❑
❑
❑
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat
conservation plan?
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special status species in local or regional plans, policies, or
regulations, or by the California Department of Wildlife or U.S. Fish and Wildlife Service?
No Impact. The Project site consists of approximately 11.8 acres that are developed with existing
commercial uses, including restaurant, retail, and office establishments, a paved parking lot, and
landscaping. The area identified in the City's adopted Housing Element as most likely for future residential
development is 7 acres of existing parking lot area within the southeast portion of the Project site. The Project
site is surrounded by urban developed areas with structures, paved parking, and ornamental landscaping.
There is no evidence of either suitable habitat for or the presence of any endangered, rare, threatened, or
special status plant species (or associated habitats) or wildlife species designated by the U.S. Fish and
Wildlife Service (USFWS), California Department of Fish and Wildlife (CDFW), or California Native Plant
Society (CNPS).
The Project does not propose development; however, the Project would provide for future proposed
development through implementation of the housing overlay and the City's certified 2021-2029 Housing
Element. Landscaping implemented as part of future projects would likely include a variety of ornamental
trees, shrubs, and groundcover. As the Project site is currently completely paved, implementation of the
31
Enderle Center Rezone Project
City of Tustin Initial Study
Project would not result in an adverse effect, either directly or through habitat modifications, on any sensitive
species, and impacts would not occur.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community
identified in local or regional plans, policies, or regulations, or by the California Department of Fish
and Wildlife or U.S. Fish and Wildlife Service?
No Impact. As discussed above, the area proposed for the provision of future residential development is
completely paved with a parking lot. There is no existing riparian habitat or sensitive natural community
within the developable area of the site. Therefore, the Project would result in no impact.
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited
to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or
other means?
No Impact. As discussed above, the area proposed for the provision of future residential development is
completely paved with a parking lot. There are no wetlands or riparian areas within the developable area
of the site. Therefore, the Project would result in no impact.
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species
or with established native resident or migratory wildlife corridors, or impede the use of native
wildlife nursery sites?
Less Than Significant Impact with Mitigation. Wildlife corridors are areas where wildlife movement is
concentrated due to natural or anthropogenic constraints and corridors provide access to resources such as
food, water, and shelter. Animals use these corridors to move between different habitats and provide
avenues for wildlife dispersal, migration, and contact between other populations.
The Project site does not support conditions for migratory wildlife corridors or linkages. The Project site is
completely developed and surrounded by a roadway and developed land uses. The site and surrounding
areas do not provide function for wildlife movement. Additionally, the surrounding area is developed and
urban. There are no rivers, creeks, or open drainages near the site that could function as a wildlife corridor.
Thus, implementation of the Project would not result in impacts related to wildlife movement or wildlife
corridors.
However, the Project site contains existing ornamental trees that could be used for nesting by common bird
species that are protected by the federal Migratory Bird Treaty Act (MBTA) and the California Fish and
Game Code Sections 3503.5, 3511, and 3515 during the avian nesting and breeding season that occurs
between February 1 and September 15. The provisions of the MBTA prohibit disturbing or destroying active
nests. Therefore, Mitigation Measure B10-1 has been included to require that if commencement of vegetation
clearing for any future residential development project occurs between February 1 and September 15, a
qualified biologist shall conduct a nesting bird survey no more than 3 days prior to commencement of
activities to confirm the absence of nesting birds. With implementation of Mitigation Measure B10-1, potential
impacts to nesting birds would be less than significant.
e) Conflict with any local policies or ordinances protecting biological resources?
Less Than Significant Impact. The Project site is urban and developed and contains no biological resources
to be preserved under the resource protection policies of the City's General Plan. Article 7, Chapter 3 of
the Municipal Code addresses the protection of "trees, plants or shrubs in or growing upon or over any public
parkway street, highway, alley, right-of-way, City -owned property in the City." The Project would not impact
any such trees and shrubs. To the extent that future development facilitated by the Project is required to
plant new trees on public property pursuant to Section 7308 of Article 7, Chapter 3, the Project would be
32
of Tustin
Enderle Center Rezone Project
Initial Studv
required to comply with the Municipal Code requirements as part of the City permitting process (PPP BIO-
1). As a result, impacts would be less than significant.
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact. The Project site is developed and in an urban area. The Project site does not contain any natural
lands that are subject to an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or
other approved local, regional, or state habitat conservation plan. Therefore, the Project would not result in
impacts to biological habitat or conservation plans.
Plans, Programs, or Policies (PPP)
PPP BIO-1 Street Trees. Installation of street trees shall occur in compliance with the City of Tustin
Municipal Code Article 7, Chapter 3, Section 7308.
Mitigation Measures
MM BIO-1 Migratory Bird Treaty Act. Prior to commencement of grading activities, the City Building
Division shall verify that, in the event that vegetation and tree removal activities occur within
the active breeding season for birds (February 1—September 15), the Project applicant (or
their Construction Contractor) shall retain a qualified biologist (meaning a professional
biologist that is familiar with local birds and their nesting behaviors) to conduct a nesting
bird survey no more than 3 days prior to commencement of construction activities.
The nesting survey shall include the Project site and areas immediately adjacent to the site
that could potentially be affected by Project -related construction activities, such as noise,
human activity, and dust, etc. If active nesting of birds is observed within 100 feet of the
designated construction area prior to construction, the qualified biologist shall establish an
appropriate buffer around the active nests (e.g., as much as 500 feet for raptors and 300
feet for non -raptors [subject to the recommendations of the qualified biologist]), and the
buffer areas shall be avoided until the nests are no longer occupied and the juvenile birds
can survive independently from the nests.
33
of Tustin
5.5 CULTURAL RESOURCES
Enderle Center Rezone Project
Initial Studv
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
a) Cause a substantial adverse change in the significance
❑
❑
❑
of a historical resource pursuant to §1 5064.5?
b) Cause a substantial adverse change in the significance
❑
®
❑
❑
of an archaeological resource pursuant to §1 5064.5?
c) Disturb any human remains, including those interred
❑
❑
®
❑
outside of formal cemeteries?
A Cultural Records Search (see Appendix A) was prepared by Brian F. Smith and Associates Environmental
Services (BFSA) for the Project to determine the potential for historic and architectural resources to occur
within the Project site and has been incorporated into the discussion below (BFSA Environmental Services,
2023).
a) Cause a substantial adverse change in the significance of a historical resource pursuant to
§ 15064.5?
No Impact. State CEQA Guidelines Section 15064.5 defines historic resources as resources listed or
determined to be eligible for listing by the State Historical Resources Commission, a local register of historical
resources, or the lead agency. Generally, a resource is considered "historically significant" if it meets one of
the following criteria:
i. Is associated with events that have made a significant contribution to the broad patterns of
California's history and cultural heritage;
ii. Is associated with the lives of persons important in our past;
iii. Embodies the distinctive characteristics of a type, period, region, or method of construction, or
represents the work of an important creative individual, or possesses high artistic values;
iv. Has yielded, or may be likely to yield, information important in prehistory or history.
According to results of the cultural record search prepared for the Project, the Project site does not contain
any historic resources. Additionally, the area proposed for future implementation of residential land uses
pursuant to the Housing Element is the existing parking lot, which does not contain any structures that could
become historic in the future. Therefore, the Project would result in no impact to a historical resource.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to
§ 15064.5?
Less Than Significant Impact with Mitigation. According to results of the cultural record search prepared
for the Project, the Project site does not contain any archaeological resources. The Project site is currently
developed as a commercial site and is surrounded by other commercial developments. Therefore, the Project
site is heavily disturbed and does not currently contain any native undisturbed soils. However, the Project
could facilitate future construction at depths greater than previous excavation activities, which could result in
the disturbance of undisturbed native soils. Therefore, there is a low potential that future construction could
result in inadvertent discovery of a buried archeological resource. Mitigation Measure CUL-1 has been
incorporated to mitigate any potential impact to an archeological resource. In the event of an inadvertent
discovery of a buried archeological resource, work shall cease within 50 feet of the find until a qualified
archaeologist from the City or County List of Qualified Archaeologists has evaluated the find to determine
whether the find constitutes a "unique archaeological resource", and if the discovered resource(s) appears
34
Enderle Center Rezone Project
of Tustin Initial Studv
Native American in origin, a Native American Monitor shall be contacted to evaluate any potential tribal
cultural resource(s) and shall have the opportunity to consult on appropriate treatment and curation of these
resources. Prior to the issuance of any permits for ground -disturbing activities that include the excavation of
soils (including as grading, excavation, and trenching), the City of Tustin shall ensure that all Project grading
and construction plans and specifications include requirement to halt construction activity and contact an
archaeologist.
The City has detailed standards and requirements for grading that are designed to protect sensitive
topographic, soil, palaeontologic, and archaeologic resources. The Tustin Grading Manual prescribes
appropriate measures to protect the earth by controlling erosion, sedimentation, and storm drainage (PPP
HYD-2). Proper grading, soil management, and open space standards will work to preserve any potential
archaeological resources in the unlikely event that a resource is encountered. Therefore, the Project would
result in a less than significant impact with mitigation on archeological resources.
c) Disturb any human remains, including those interred outside of formal cemeteries?
Less Than Significant Impact. The Project site has been previously disturbed, as described above, and has
not been previously used as a cemetery. Thus, human remains are not anticipated to be uncovered during
project construction. In addition, California Health and Safety Code Section 7050.5, CEQA Section 15064.5,
and Public Resources Code Section 5097.98 (included as PPP CUL-1) mandate the process to be followed
in the event of an accidental discovery of any human remains. Specifically, California Health and Safety
Code Section 7050.5 requires that if human remains are discovered, disturbance of the site shall remain
halted until the coroner has conducted an investigation into the circumstances, manner, and cause of death,
and made recommendations concerning the treatment and disposition of the human remains to the person
responsible for the excavation, or to his or her authorized representative, in the manner provided in Section
5097.98 of the Public Resources Code. If the coroner determines that the remains are not subject to his or
her authority and if the coroner has reason to believe the human remains to be those of a Native American,
he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Compliance
with existing law would ensure that significant impacts to human remains would not occur through the
implementation of future construction facilitated by the Project.
Plans, Policies, and Programs (PPP)
PPP CUL-1 Human Remains. In the event that human remains are encountered on the Project site, work
within 50 feet of the discovery shall cease and the County Coroner shall be notified
immediately consistent with the requirements of California Code of Regulations (CCR)
Section 15064.5(e). State Health and Safety Code Section 7050.5 states that no further
disturbance shall occur until the County Coroner has made a determination of origin and
disposition pursuant to Public Resources Code (PRC) Section 5097.98. Prior to the issuance
of grading permits, the City Community Department Director, or designee, shall verify that
all grading plans specify the requirements of CCR Section 15064.5(e), State Health and
Safety Code Section 7050.5, and PRC Section 5097.98, as stated above.
PPP HYD-2 City of Tustin Grading Manual. All future projects are required to comply with the City of
Tustin Grading Manual (1990). Implementation of grading manual standards would be
verified by the City during the plan check and permitting process.
Mitigation Measures (MM)
MM CUL-1 Inadvertent Discovery. In the event that potential archaeological resources are discovered
during excavation, grading, or construction activities, work shall cease within 50 feet of the
find until a qualified archaeologist from the City or County List of Qualified Archaeologists
has evaluated the find to determine whether the find constitutes a "unique archaeological
35
of Tustin
Enderle Center Rezone Project
Initial Studv
resource," as defined in Section 21083.2(g) of the California Public Resources Code. Any
resources identified shall be treated in accordance with California Public Resources Code
Section 21083.2(g).
If the discovered resource(s) appears Native American in origin, a Native American Monitor
shall be contacted to evaluate any potential tribal cultural resource(s) and shall have the
opportunity to consult on appropriate treatment and curation of these resources. The
discovery would also be reported to the City and the South Central Coastal Information
Center (SCCIC).
Prior to the issuance of any permits for ground -disturbing activities that include the
excavation of soils (including as grading, excavation, and trenching), the City of Tustin shall
ensure that all Project grading and construction plans and specifications include requirement
to halt construction activity and contact an archaeologist as specified above.
36
Enderle Center Rezone Project
City of Tustin Initial Study
5.6 ENERGY
Would the project:
a) Result in potentially significant environmental impact
due to wasteful, inefficient, or unnecessary consumption
of energy resources, during project construction or
operation?
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
Potentially
Less Than
Less Than
Significant
Significant
Significant
Impact
with
Impact
Mitigation
Incorporated
®
❑
❑
® ❑ ❑
No
Impact
El
El
a) and b)
Potentially Significant Impact. The Project site has a General Plan land use designation of Planned
Community Commercial/Business (PCCB) and a zoning designation of Planned Community Commercial (PC
COM). The Project would include a GPA, CA and rezone of the Project site with a Housing Overlay (HO)
district to allow for future development of up to 413 housing units, consistent with the City's certified 2021-
2029 Housing Element. The provision of development intensification could facilitate future energy impacts.
Residential land uses have not been previously analyzed for consistency with state or local energy plans and
policies. Additionally, the future construction and operation of potential development could result in a
substantial increase in energy consumption. Therefore, an energy study will be conducted for the Project to
determine potential impacts and energy impacts will be further analyzed within the EIR.
37
of Tustin
5.7 GEOLOGY AND SOILS
Enderle Center Rezone Project
Initial Studv
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
a)
Directly or indirectly cause potential substantial adverse
effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on
❑
❑
®
❑
the most recent Alquist-Priolo Earthquake Fault Zoning Map
issued by the State Geologist for the area or based on
other substantial evidence of a known fault? (Refer to
Division of Mines and Geology Special Publication 42)
ii) Strong seismic ground shaking?
iii) Seismic -related ground failure, including liquefaction?
❑
®
❑
❑
iv) Landslides?
❑
❑
❑
b)
Result in substantial soil erosion or the loss of topsoil?
❑
❑
®
❑
c)
Be located on a geologic unit or soil that is unstable, or that
❑
®
❑
❑
would become unstable as a result of the project, and
potentially result in on- or offsite landslide, lateral
spreading, subsidence, liquefaction, or collapse?
d)
Be located on expansive soil, as defined in Table 1 8-1 -B
❑
®
❑
❑
of the Uniform Building Code (1994), creating substantial
direct or indirect risks to life or property?
e)
Have soils incapable of adequately supporting the use of
❑
❑
❑
septic tanks or alternative wastewater disposal systems
where sewers are not available for the disposal of
wastewater?
f)
Directly or indirectly destroy a unique paleontological
❑
❑
®
❑
resource or site or unique geologic feature?
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or
death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other
substantial evidence of a known fault?
Less Than Significant Impact. In 1972, the Alquist-Priolo Special Studies Zones Act was signed into law. In
1994, it was renamed the Alquist-Priolo Earthquake Fault Zoning Act (A-P Act). The primary purpose of the
Act is to mitigate the hazard of fault rupture by prohibiting the location of structures for human occupancy
across the trace of an active fault. The A-P Act requires the State Geologist (Chief of the California Geology
Survey) to delineate "Earthquake Fault Zones" along with faults that are "sufficiently active" and "well-
defined." The boundary of an "Earthquake Fault Zone" is generally about 500 feet from major active faults
and 200 to 300 feet from well-defined minor faults. The A-P Act dictates that cities and counties withhold
development permits for sites within an Alquist-Priolo Earthquake Fault Zone until geologic investigations
demonstrate that the site zones are not threatened by surface displacements from future faulting.
38
Enderle Center Rezone Project
of Tustin Initial Studv
The Project site is located in the northwest corner of the City of Tustin. According to the California Geological
Survey available fault maps, the Project is approximately 10 miles to the south of the nearest A-P fault,
Whitter Fault (Parrish, Earthquake Zones of Required Investigation, Yorba Linda Quadrangle, 2015). The
Project is also approximately 1 1 miles to the north of the North Branch Fault (Parrish, Earthquake Zones of
Required Investigation, Seal Beach Quadrangle, 1999). Due to the location of these faults, the general
region is subject to the potential for earthquakes; however, the Project site is outside of a 500-foot radius
from an active fault and is not subject to a special development permit. The Project site contains existing
development, and the provision for additional development would not exacerbate existing risk of
earthquake. Further, all future development permitted would be required to comply with the requirement of
the California Building Code (CBC) (California Code of Regulations, Title 24, Part 2) (PPP GEO-1), which is
a minimum requirement intended to protect life safety and prevent collapse of structures. Therefore, the
Project would result in a less than significant impact.
Strong seismic ground shaking?
Less Than Significant Impact. The Project site is located within a seismically active region of Southern
California. As mentioned previously, the Whitter Fault is located 10 miles from the site (Parrish, Earthquake
Zones of Required Investigation, Yorba Linda Quadrangle, 2015). Thus, moderate to strong ground shaking
can be expected at the Project site. The amount of motion expected at the Project site can vary from none
to forceful depending upon the distance to the fault and the magnitude of the earthquake. Greater
movement can be expected at sites located closer to an earthquake epicenter, which consists of poorly
consolidated material such as alluvium, and in response to an earthquake of great magnitude.
Structures built in the City are required to be built in compliance with the CBC (California Code of
Regulations, Title 24, Part 2) that provides provisions for earthquake safety based on factors including
building occupancy type, the types of soils onsite, and the probable strength of ground motion. Compliance
with the CBC would require the incorporation of 1) seismic safety features to minimize the potential for
significant effects as a result of earthquakes; 2) proper building footings and foundations; and 3) construction
of the building structure so that it would withstand the effects of strong ground shaking. Implementation of
CBC standards would be verified by the City during the plan check and permitting process (PPP GEO-1).
Because the proposed Project would be constructed in compliance with the CBC, the proposed Project would
result in a less -than -significant impact related to strong seismic ground shaking.
iii. Seismic -related ground failure, including liquefaction?
Less Than Significant Impact with Mitigation. Soil liquefaction is a phenomenon in which saturated,
cohesionless soils layers, located within approximately 50 feet of the ground surface, lose strength due to
cyclic pore water pressure generation from seismic shaking or other large cyclic loading. During the loss of
stress, the soil acquires "mobility" sufficient to permit both horizontal and vertical movements. Soil properties
and soil conditions such as type, age, texture, color, and consistency, along with historical depths to ground
water are used to identify, characterize, and correlate liquefaction susceptible soils.
Soils that are most susceptible to liquefaction are clean, loose, saturated, and uniformly graded fine-grained
sands that lie below the groundwater table within approximately 50 feet below ground surface. Lateral
spreading is a form of seismic ground failure due to liquefaction in a subsurface layer.
According to the California Geological Survey available fault maps, the Project is approximately 1.25 miles
from the nearest liquefaction zone in the City of Orange (Parrish, Earthquake Zones of Required
Investigation, Orange Quadrangle, 1998). The southern portion of Tustin is also identified as partially within
a liquefaction zone. Additionally, all future projects implemented through the proposed housing overlay
would be required to conduct a project -specific geotechnical investigation to ensure that the site's soils are
adequate for the construction and operation of the proposed project. Future projects would be required to
implement measures identified within the project -specific geotechnical investigation (MM GEO-1). The Project
39
Enderle Center Rezone Project
City of Tustin Initial Study
site is outside of a liquefaction zone and would be required to conduct project -specific geotechnical
investigations at the time that the project is proposed; therefore, the Project would result in a less -than -
significant impact with mitigation.
iv. Landslides?
No Impact. Landslides and other slope failures are secondary seismic effects that are common during or
soon after earthquakes. Areas that are most susceptible to earthquake induced landslides are steep slopes
underlain by loose, weak soils, and areas on or adjacent to existing landslide deposits.
The Project site is currently fully developed with commercial and office uses. The Project site is flat and is not
adjacent to or within the vicinity of steep slopes or other landforms susceptible to landslides. The Project
would include a GPA, CA and rezone of the Project site with a Housing Overlay (HO) district to allow for
future development of up to 413 housing units, consistent with the City's certified 2021-2029 Housing
Element. The provision of future residential development would not result in new risk of loss, injury, or death
involving a landslide. Therefore, the Project would result in no impact.
b) Result in soil erosion or the loss of topsoil?
Less Than Significant Impact. The Project site is currently fully developed with commercial and office uses.
However, future development facilitated by the provision of residential land uses within the Project site could
result in ground disturbing activities as part of the construction.
All proposed development construction would be required to comply with the California Regional Water
Quality Control Board (RWQCB) Order No. R8-2010-0033, National Pollutant Discharge Elimination System
(NPDES) Permit No. CAS61 8033 — Construction General Permit requirements (PPP HYD-1). Requirements
include installation of Best Management Practices (BMPs), which establishes minimum stormwater
management requirements and controls. To reduce the potential for soil erosion and the loss of topsoil, a
Stormwater Pollution Prevention Plan (SWPPP) is required by the RWQCB regulations to be developed by
a QSD (Qualified SWPPP Developer). The SWPPP is required to address site -specific conditions related to
specific grading and construction activities. The SWPPP would identify potential sources of erosion and
sedimentation to prevent loss of topsoil during construction, and to identify erosion control BMPs to reduce
or eliminate the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel bags; stabilized
construction entrances/exits; hydroseeding, and similar measures. In addition to RWQCB requirements,
proposed development would need to comply with the City of Tustin Grading Manual procedures (PPP HYD-
2). The City of Tustin Grading Manual is a compilation of rules, procedures, and interpretations necessary to
carry out the provisions of the Tustin City Code relating to grading and excavation.
Following construction, future development would be required to prepare and implement a Water Quality
Management Plan (WQMP) per City standards. Future projects would be required to comply with the
requirements of the Orange County Drainage Area Management Plan (DAMP) and the intent of the non -
point source NPDES Permit for Waste Discharge Requirements for the County of Orange, Orange County
Flood Control District and the incorporated cities of Orange County within the Santa Ana Region (included
as PPP HYD-3).
The DAMP regulations are included in the City's Municipal Code in Section 4902 and are the implementation
method for NPDES Stormwater Permit compliance. The DAMP:
• Provides the framework for the program management activities and plan development;
• Provides the legal authority for prohibiting unpermitted discharges into the storm drain system and for
requiring BMPs in new development and significant redevelopment;
• Ensures that all new development and significant redevelopment incorporates appropriate Site Design,
Source Control, and Treatment Control BMPs to address specific water quality issues; and
40
of Tustin
Enderle Center Rezone Project
Initial Studv
• Ensures that construction sites implement control practices that address construction related pollutants
including erosion and sediment control and onsite hazardous materials and waste management.
The DAMP requires that new development and significant redevelopment projects develop and implement
a water quality management plan (WQMP) that includes BMPs and low impact development (LID) design
features that would provide onsite treatment of stormwater to prevent pollutants from onsite uses from
leaving the site. These requirements would ensure that future projects would not result in substantial soil
erosion or the loss of topsoil. With implementation of uniformly applicable requirements (SWPPP, City of
Tustin Grading Manual, and the DAMP), the Project would result in a less -than -significant impact.
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of
the project, and potentially result in on- or offsite landslide, lateral spreading, subsidence,
liquefaction or collapse?
Less Than Significant Impact with Mitigation. Landslides and other forms of mass wasting, including mud
flows, debris flows, and soil slips, occur as soil moves downslope under the influence of gravity. Landslides
are frequently triggered by intense rainfall or seismic shaking. As described in Response (a) (iv), the Project
site is located in a relatively flat developed urban area that does not contain or adjacent to large slopes,
and the Project would not generate large slopes. Therefore, impacts related to landslides would not occur.
Lateral spreading is a type of liquefaction -induced ground failure associated with the lateral displacement
of surficial blocks of sediment resulting from liquefaction in a subsurface layer. Once liquefaction transforms
the subsurface layer into a fluid mass, gravity plus the earthquake inertial forces may cause the mass to
move downslope towards a free face (such as a river channel or an embankment). Lateral spreading may
cause large horizontal displacements and such movement typically damages pipelines, utilities, bridges, and
structures. As discussed in Response (a), the Project site is outside of a zone identified as susceptible to
liquefaction. Further, the Project site then has a low potential for lateral spreading. However, all future
projects implemented through the proposed housing overlay would be required to conduct a project -specific
geotechnical investigation to ensure that the site's soils are adequate for the construction and operation of
the proposed project. Future projects would be required to implement measures identified within the project -
specific geotechnical investigation (MM GEO-1).
Subsidence is a general lowering of the ground surface over a large area that is generally attributed to
lowering of the ground water levels within a groundwater basin. Localized or focal subsidence or settlement
of the ground can occur as a result of an earthquake motion in an area where groundwater in basin is
lowered. The United States Geological Survey (USGS) has surveyed the state for areas of recorded
subsidence —historical and current —across California. According to the USGS Areas of Subsidence in
California Map, the Project site is within an area of subsidence as a result of excessive groundwater pumping
(United States Geological Survey, 2023). As described above, all future projects implemented through the
proposed housing overlay would be required to conduct a project -specific geotechnical investigation to
ensure that the site's soils are adequate for the construction and operation of the proposed project. Future
projects would be required to implement measures identified within the project -specific geotechnical
investigation (MM GEO-1).
Therefore, the Project would result in a less -than -significant impact with mitigation on the risk of landslide,
lateral spreading, subsidence, liquefaction or collapse.
d) Be located on expansive soil, as defined in in Table 18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to life or property?
Less Than Significant Impact with Mitigation. Expansive soils contain certain types of clay minerals that
shrink or swell as the moisture content changes; the shrinking or swelling can shift, crack, or break structures
built on such soils. Arid or semiarid areas with seasonal changes of soil moisture experience, such as southern
41
Enderle Center Rezone Project
of Tustin Initial Studv
California, have a higher potential of expansive soils than areas with higher rainfall and more constant soil
moisture.
The Project site is currently developed as a commercial site and is surrounded by other commercial
developments. The Project would include a GPA, CA and rezone of the Project site with a Housing Overlay
(HO) district to allow for future development of up to 413 housing units, consistent with the City's certified
2021-2029 Housing Element. All future projects would be required to comply with applicable Federal, State,
and local policies and regulations established to prevent or reduce impacts due to expansive soil, including
Policy 8.5 of the Conservation/Open Space/Recreation Element, which requires City review of threats from
expansive soils during the development review process (PPP GEO-2). Further, if necessary, geological
investigations would be prepared and implemented for each future project to reduce significant impacts
(MM GEO-1). Therefore, the project would result in a less -than -significant impact with mitigation.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater
disposal systems where sewers are not available for the disposal of wastewater?
No Impact. All future development would be served by the City sewer utilities and would not include the use
of septic tanks or alternative wastewater disposal systems. Therefore, the Project would result in no impact.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less Than Significant Impact. The Project site is currently developed as a commercial site and is surrounded
by other commercial developments. Therefore, the Project site is heavily disturbed and does not contain any
native undisturbed soils. However, the Project could facilitate future construction at depths greater than
previous excavation activities, which could result in the disturbance of undisturbed native soils. The City's
Conservation/Open Space/Recreation Element of the General Plan Figure COSR-2 identifies areas sensitive
to paleontological resources (City of Tustin, 2018). The Project site is not located in an area identified by
the General Plan as "High Paleontological Sensitivity." The City has detailed standards and requirements
for grading that are designed to protect sensitive topographic, soil, palaeontologic, and archaeologic
resources. The Tustin Grading Manual prescribes appropriate measures to protect the earth by controlling
erosion, sedimentation, and storm drainage (PPP HYD-2). Proper grading, soil management, and open space
standards will work to preserve any potential paleontological resources in the unlikely event that a resource
is encountered. Therefore, the Project would result in a less -than -significant impact on a paleontological
resource, site, or geologic feature.
Plans, Policies, and Programs (PPP)
The Project would be subject to the following PPP:
PPP GEO-1 CBC Title 24, Part 2. Structures built in the City are required to be built in compliance with
the CBC (California Code of Regulations, Title 24, Part 2) that provides provisions for
earthquake safety based on factors including building occupancy type, the types of soils
onsite, and the probable strength of ground motion. Compliance with the CBC would require
the incorporation of 1) seismic safety features to minimize the potential for significant effects
as a result of earthquakes; 2) proper building footings and foundations; and 3) construction
of the building structure so that it would withstand the effects of strong ground shaking.
Implementation of CBC standards would be verified by the City during the plan check and
permitting process.
PPP GEO-2 Policy 8.5 of the Conservation/Open Space/Recreation Element. Project applicants would
be required to submit applications for building and grading permits, and applications for
subdivision for adjacency to, threats from, and impacts on geological hazards arising from
42
of Tustin
Enderle Center Rezone Project
Initial Studv
seismic events, landslides, or other geologic hazards such as expansive soils and subsidence
areas, which would be reviewed by the City during plan check.
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide
the City Building Division evidence of compliance with the NPDES (National Pollutant
Discharge Elimination System) requirement to obtain a construction permit from the State
Water Resource Control Board (SWRCB). The permit requirement applies to grading and
construction sites of one acre or larger. The Project applicant/proponent shall comply by
submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater
Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the
construction site.
PPP HYD-2 City of Tustin Grading Manual. All future projects are required to comply with the City of
Tustin Grading Manual (1990). Implementation of grading manual standards would be
verified by the City during the plan check and permitting process.
PPP HYD-3 WOMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a
completed Water Quality Management Plan (WQMP) shall be prepared by the Project
applicant and submitted to and approved by the City Public Works Department. The
WQMP shall identify all Post -Construction, Site Design, Source Control, and Treatment
Control Best Management Practices (BMPs) that will be incorporated into the development
Project in order to minimize the adverse effects on receiving waters.
Mitigation Measures (MM)
MM GEO-1 All future projects implemented through the proposed housing overlay would be required
to conduct a project -specific geotechnical investigation to ensure that the site's soils are
adequate for the construction and operation of the proposed project. Future projects would
be required to implement measures identified within the project -specific geotechnical
investigation.
43
of Tustin
5.8 GREENHOUSE GAS EMISSIONS
Enderle Center Rezone Project
Initial Studv
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
a) Generate greenhouse gas emissions, either directly or
®
❑
❑
❑
indirectly, that may have a significant impact on the
environment?
b) Conflict with an applicable plan, policy or regulation
®
❑
❑
❑
adopted for the purpose of reducing the emissions of
greenhouse gases?
a) through b)
Potentially Significant Impact. Global climate change is not confined to a particular project area. A typical
project does not generate enough greenhouse gas (GHG) emissions on its own to influence global climate
change significantly; hence, the issue of global climate change is, by definition, a cumulative environmental
impact. GHGs are produced by both direct and indirect emissions sources. Direct emissions include
consumption of natural gas, heating and cooling of buildings, landscaping activities and other equipment
used directly by land uses. Indirect emissions include the consumption of fossil fuels for vehicle trips, electricity
generation, water usage, and solid waste disposal.
The Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM). The Project would include a GPA,
CA and rezone of the Project site with a Housing Overlay (HO) district to allow for future development of
up to 413 housing units, consistent with the City's certified 2021-2029 Housing Element. The provision of
development intensification could result in construction and operational GHG impacts due to the introduction
of new residential land uses. Specifically, the addition of mobile source emissions through the generation of
residential traffic could result in a significant GHG impact. Further, the Project could result in conflicts with
applicable plan, policy, and regulations adopted for the purpose of reducing the emissions of GHG.
Therefore, an air quality study will be conducted for the Project to determine potential impacts and GHG
impacts will be further analyzed within the EIR.
44
of Tustin
5.9 HAZARDS AND HAZARDOUS MATERIALS
Enderle Center Rezone Project
Initial Studv
Would the project:
Potentially
Less Than
Less Than No
Significant
Significant
Significant Impact
Impact
with
Impact
Mitigation
Incorporated
a)
Create a significant hazard to the public or the
❑
❑
® ❑
environment through the routine transport, use, or disposal
of hazardous materials?
b)
Create a significant hazard to the public or the
❑
❑
® ❑
environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous
materials into the environment?
c)
Emit hazardous emissions or handle hazardous or acutely
hazardous materials, substances, or waste within one -
quarter mile of an existing or proposed school?
d)
Be located on a site which is included on a list of hazardous
materials sites compiled pursuant to Government Code
Section 65962.5 and, as a result, would it create a
significant hazard to the public or the environment?
e)
For a project located within an airport land use plan or,
❑
❑
❑
where such a plan has not been adopted, within two miles
of a public airport or public use airport, would the project
result in a safety hazard or excessive noise for people
residing or working in the project area?
f)
Impair implementation of or physically interfere with an
❑
❑
® ❑
adopted emergency response plan or emergency
evacuation plan?
g)
Expose people or structures, either directly or indirectly,
❑
❑
❑
to a significant risk of loss, injury or death involving
wildland fires?
a) Create a significant hazard to the public or the environment through the routine transport, use, or
disposal of hazardous materials?
Less Than Significant Impact. A hazardous material is defined as any material that, due to its quantity,
concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human
health and safety or to the environment if released into the workplace or environment. Hazardous materials
include, but are not limited to, hazardous substances, hazardous wastes, and any material that a business or
the local implementing agency has a reasonable basis for believing would be injurious to the health and
safety of persons or harmful to the environment if released into the workplace or the environment.
Construction
The Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM). The Project site is currently
developed as a commercial site and is surrounded by other commercial developments. The Project would
include a GPA, CA and rezone of the Project site with a Housing Overlay (HO) district to allow for future
development of up to 413 housing units, consistent with the City's certified 2021 -2029 Housing Element. The
Project does not propose development; however, the Project would provide for future proposed
45
Enderle Center Rezone Project
City of Tustin Initial Study
development through implementation of the housing overlay and the City's certified 2021-2029 Housing
Element.
Future construction activities could involve the transport, use, and disposal of hazardous materials such as
paints, solvents, oils, grease, and caulking. In addition, hazardous materials could be needed for fueling and
servicing construction equipment on the site. These types of materials are not acutely hazardous, and all
storage, handling, use, and disposal of these materials are regulated by federal and state requirements
that are implemented by the City during building permitting for construction activities. These regulations
include: the federal Occupational Safety and Health Act and Hazardous Materials Transportation Act; Title
8 of the California Code of Regulations (CalOSHA), and the state Unified Hazardous Waste and Hazardous
Materials Management Regulatory Program. As a result, routine transport and use of hazardous materials
during construction would be consistent with applicable regulations and would be less than significant.
Operation
The Project involves the provision for future development of up to 413 housing units, which involve routinely
using household hazardous materials including solvents, cleaning agents, paints, pesticides, batteries,
fertilizers, and aerosol cans. These types of materials are not acutely hazardous and would only be used
and stored in limited quantities. The normal routine use of these products pursuant to existing regulations
would not result in a significant hazard to people or the environment in the vicinity of the Project. Additionally,
the Project would create a mixed -use environment in which residential land uses would be introduced into
existing commercial land use (the Enderle Center). Existing commercial uses include a mix of office, restaurant,
and retail establishments. Existing commercial uses require the routine use of similar hazardous materials as
residential land uses (solvents, cleaning agents, paints, pesticides, batteries, fertilizers, and aerosol cans) and
would not impose additional hazards to potential future residential uses. Therefore, operation of the Project
would not result in a significant hazard to the public or to the environment through the routine transport, use,
or disposal of hazardous waste, and impacts would be less than significant.
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset
and accident conditions involving the release of hazardous materials into the environment?
Less Than Significant Impact.
Construction
While the routine use, storage, transport, and disposal of hazardous materials in accordance with applicable
regulations during potential future construction activities would not pose health risks or result in significant
impacts; improper use, storage, transportation and disposal of hazardous materials and wastes could result
in accidental spills or releases, posing health risks to workers, the public, and the environment. To avoid an
impact related to an accidental release, the use of BMPs during construction are implemented as part of a
SWPPP as required by the National Pollution Discharge Elimination System General Construction Permit (and
included as PPP HYD-1). Implementation of an SWPPP would minimize potential adverse effects to workers,
the public, and the environment. Construction contract specifications would include strict on -site handling rules
and BMPs that include, but are not limited to:
• Establishing a dedicated area for fuel storage and refueling and construction dewatering activities
that includes secondary containment protection measures and spill control supplies;
• Following manufacturers' recommendations on the use, storage, and disposal of chemical products
used in construction;
• Avoiding overtopping construction equipment fuel tanks;
• Properly containing and removing grease and oils during routine maintenance of equipment; and
• Properly disposing of discarded containers of fuels and other chemicals.
46
Enderle Center Rezone Project
City of Tustin Initial Study
All future development through implementation of the housing overlay and the City's certified 2021-2029
Housing Element would be required to develop and implement a SWPPP as required through NPDES.
Therefore, construction of future development would result in a less -than -significant impact.
Operation
As described previously, future operation of up to 413 residential units would include use of limited
hazardous materials, such as solvents, cleaning agents, paints, pesticides, batteries, fertilizers, and aerosol
cans. Normal routine use of typical residential products pursuant to existing regulations would not result in a
significant hazard to the environment, residents, or workers in the vicinity of the Project. As a result, operation
of the proposed Project would not create a reasonably foreseeable upset and accident condition involving
the release of hazardous materials into the environment, and impacts would be less than significant.
c) Emit hazardous emissions or handle hazardous materials, substances, or waste within one -quarter
mile of an existing or proposed school?
Less Than Significant Impact. The Project site is generally bounded on the north by 17'" Street; on the east
by Enderle Center Drive, and the eastern property line of properties fronting Enderle Center Drive; to the
south by Vandenberg Lane; and to the west by the 55 freeway, including properties west of Yorba Street.
The nearest school, Loma Vista Elementary School, is located approximately 2,100 feet to the east of the
Project site. However, as described previously, construction and operation of the Project could involve the
use, storage, and disposal of small amounts of hazardous materials on the Project site. These hazardous
materials would be limited and used and disposed of in compliance with federal, state, and local regulations,
which would reduce the potential for accidental release into the environment near a school. Therefore, the
Project would not emit hazardous or handle acutely hazardous materials, substances, or waste near a school,
and impacts would be less than significant.
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public
or the environment?
No Impact. The Project site is not located on a list of hazardous materials sites compiled pursuant to
Government Code Section 65962.5 (Department of Toxic Substances Control, 2023). Therefore, the Project
would result in no impact.
e) For a project within an airport land use plan, or where such a plan has not been adopted, within
two miles of a public airport or public use airport, would the project result in a safety hazard or
excessive noise for people residing or working in the project area?
No Impact. The Airport Land Use Commission (ALUC) for Orange County has responsibility under state law
for formulating a comprehensive airport land use plan (ALUP) for the anticipated growth of each public use
airport and its surrounding vicinity. General Plans for cities affected by an ALUP must be consistent with that
plan. The purpose of the ALUP is to safeguard the general welfare of the inhabitants within the vicinity of
airports and to ensure the continued operation of the airports. The ALUC for Orange County has adopted
the Airport Environs Land Use Plan (AELUP) governing John Wayne Airport, AFRC Los Alamitos, Fullerton
Airport, and Heliports.
The Project site is approximately 5.5 miles to the north of the John Wayne Airport, which is the nearest
airport to the Project site. The Project site is not located within any land use compatibility zone for John
Wayne Airport, nor is it within an airport safety zone within the AELUP (Orange County Airport Land Use
Commission, 2008). The Project's proximity to the airport would not result in potential safety hazards or
excessive noise for people that would reside or work within the Project site in the future. Therefore, the
Project would result in no impact.
47
of Tustin
Enderle Center Rezone Project
Initial Studv
f) Impair implementation of an adopted emergency response plan or emergency evacuation plan?
Less Than Significant Impact. The Project site is located at the southeast of the corner of 1711 Street and 55
Freeway (State Route 55), a major arterial and highway, respectively. These adjacent roadways would
likely be utilized as evacuation routes in the event of an emergency evacuation of the Project site. Pursuant
to the City's Emergency Operations Plan, specific evacuation requirements will vary with each situation, but
should be carried out in a manner consistent with other critical functions (City of Tustin, 2019). Under ideal
circumstances there will be enough time for radio and/or television stations to broadcast the required
evacuation information via the Emergency Alert System, and if enough time is available, copies of the
evacuation order or notice and route. The Project site is not designated as an emergency evacuation route.
The Project would not impair the implementation of evacuation protocol in the event of an emergency within
the City or Project site. Additionally, each future residential project implemented as part of the housing
overlay and Housing Element would require a project -level plan check with the City and would be reviewed
by the City's fire department (Orange County Fire Authority) to ensure proper emergency access to and
from the site. Therefore, the Project would result in a less -than -significant impact.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death
involving wildland fires?
No Impact. The Project site is currently developed as a commercial site and is surrounded by other
commercial developments. According to the CalFire Fire Hazard Severity Zone Map, the City of Tustin
contains very high fire severity zones in the northeast portion of the City (California Department of Forestry
and Fire Protection, 2023). The Project site is not located within or near state responsibility areas or lands
classified as very high fire hazard severity zones. Therefore, the Project would result in no impact regarding
the exposure of people or structures to risk of loss, injury, or death involving a wildland fire.
Plans, Policies, and Programs (PPP)
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide
the City Building Division evidence of compliance with the NPDES (National Pollutant
Discharge Elimination System) requirement to obtain a construction permit from the State
Water Resource Control Board (SWRCB). The permit requirement applies to grading and
construction sites of one acre or larger. The Project applicant/proponent shall comply by
submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater
Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the
construction site.
48
of Tustin
5.10 HYDROLOGY AND WATER QUALITY
Enderle Center Rezone Project
Initial Studv
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
a) Violate any water quality standards or waste discharge
❑
❑
®
❑
requirements or otherwise substantially degrade surface or
ground water quality?
b) Substantially decrease groundwater supplies or interfere
®
❑
❑
substantially with groundwater recharge such that the
project may impede sustainable groundwater management
of the basin?
c) Substantially alter the existing drainage pattern of the site
or area, including through the alteration of the course of a
stream or river or through the addition of impervious
surfaces, in a manner which would:
i) Result in a substantial erosion or siltation on- or off -site;
❑
❑
®
❑
ii) Substantially increase the rate or amount of surface ❑ ❑ ® ❑
runoff in a manner which would result in flooding on- or
offsite;
iii) Create or contribute runoff water which would exceed ❑ ❑ ® ❑
the capacity of existing or planned stormwater drainage
systems or provide substantial additional sources of
polluted runoff; or
iv) Impede or redirect flood flows? ❑ ❑ ® ❑
d) In flood hazard, tsunami, or seiche zones, risk release of ❑ ❑ El E
pollutants due to project inundation?
e) Conflict with or obstruct implementation of a water quality ® ❑ ❑
control plan or sustainable groundwater management
plan?
a) Violate any water quality standards or waste discharge requirements or otherwise substantially
degrade surface or ground water quality?
Less Than Significant Impact.
The Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM). The Project site is currently
developed as a commercial site and is surrounded by other commercial developments. The Project would
include a GPA, CA and rezone of the Project site with a Housing Overlay (HO) district to allow for future
development of up to 413 housing units, consistent with the City's certified 2021-2029 Housing Element. The
Project does not propose development; however, the Project would provide for future proposed
development through implementation of the housing overlay and the City's certified 2021-2029 Housing
Element.
Construction
49
Enderle Center Rezone Project
of Tustin Initial Studv
The Project site is located in the northwestern portion of Tustin, which is part of the Newport Bay Watershed
(OC Watersheds, 2006). The entire watershed spans 154 square miles and is contained in the jurisdictional
boundary of Orange County. The largest drainage, San Diego Creek, and its many tributaries begin along
the coastal foothills of the Santa Ana Mountains and flow predominantly southwest into Newport Bay. The
Newport Bay Watershed is within the jurisdiction of the Santa Ana Regional Water Quality Control Board
(Regional Board), within the subunit of the Lower Santa Ana River Basin (designated Hydrologic Unit 801.1 1).
The Water Quality Control Plan for the Santa Ana River Basin lists Newport Bay both Upper and Lower, as
tributaries to the Pacific Ocean and also as receiving waters for San Diego Creek. The Project site is within
the Tustin/Irvine/Modeno Channel Tustin/Irvine/Modeno Channel Subwatershed, which is tributary to the
San Diego Creek: Reach 1. As of the 2018 303(d) impaired waters list, San Diego Creek: Reach 1 was listed
as impaired for nutrients, sedimentation/siltation, selenium, toxaphene, toxicity, indicator bacteria, benthic
community effects, DDT (dichlorodiphenyltrichloroethane), and malathion (California Waterboards, 2023).
Construction of future development facilitated by the Project would require grading and excavation of soils
over approximately seven acres, which would loosen sediment, and then have the potential to mix with
surface water runoff and degrade water quality. Additionally, construction would require the use of heavy
equipment and construction -related chemicals, such as concrete, cement, asphalt, fuels, oils, antifreeze,
transmission fluid, grease, solvents and paints. These potentially harmful materials could be accidentally
spilled or improperly disposed of during construction and, if mixed with surface water runoff, could wash
into and pollute waters.
These types of water quality impacts during construction would be prevented through implementation of a
SWPPP (PPP HYD-1). Construction of the Project would disturb more than one acre of soil; therefore, the
proposed Project would be required to obtain coverage under the NPDES General Permit for Discharges of
Storm Water Associated with Construction Activity. Construction activity subject to this permit includes
clearing, grading, and ground disturbances such as trenching, stockpiling, or excavation. The Construction
General Permit requires implementation of a SWPPP that is required to identify all potential sources of
pollution that are reasonably expected to affect the quality of storm water discharges from the construction
site. The SWPPP would generally contain a site map showing the construction perimeter, proposed buildings,
stormwater collection and discharge points, general pre- and post -construction topography, drainage
patterns across the site, and adjacent roadways. The SWPPP would also include construction BMPs.
Adherence to the existing requirements and implementation of the appropriate BMPs, as ensured through
the City's plan check and permitting process, would ensure that the Project would not violate any water
quality standards or waste discharge requirements, potential water quality degradation associated with
construction activities would be minimized, and construction impacts would be less than significant.
Operation
Future development facilitated by the Project would include operation of residential uses. Potential pollutants
associated with the proposed uses include various chemicals from cleaners, pathogens from pet wastes,
nutrients from fertilizer, pesticides and sediment from landscaping, trash and debris, and oil and grease
from vehicles. If these pollutants discharge into existing stormwater systems, it could result in further
degradation of water quality.
However, operation of the proposed Project would be required to comply with the requirements of the
Orange County Drainage Area Management Plan (DAMP) and the intent of the non -point source NPDES
Permit for Waste Discharge Requirements for the County of Orange, Orange County Flood Control District
and the incorporated cities of Orange County within the Santa Ana Region (included as PPP HYD-3).
The DAMP regulations are included in the City's Municipal Code in Section 4902 and are the implementation
method for NPDES Stormwater Permit compliance. The DAMP:
50
of Tustin
Enderle Center Rezone Project
Initial Studv
• Provides the framework for the program management activities and plan development;
• Provides the legal authority for prohibiting unpermitted discharges into the storm drain system and
for requiring BMPs in new development and significant redevelopment;
• Ensures that all new development and significant redevelopment incorporates appropriate Site
Design, Source Control, and Treatment Control BMPs to address specific water quality issues; and
• Ensures that construction sites implement control practices that address construction related pollutants
including erosion and sediment control and onsite hazardous materials and waste management.
The DAMP requires that new development and significant redevelopment projects develop and implement
a water quality management plan (WQMP) that includes BMPs and low impact development (LID) design
features that would provide onsite treatment of stormwater to prevent pollutants from onsite uses from
leaving the site. A WQMP is required to be approved prior to the issuance of a building or grading permit.
WQMPs prepared for future development would be reviewed and approved by the City to ensure it
complies with the MS4 Permit regulations. In addition, the City's permitting process would ensure that all
BMPs in the WQMP would be implemented with the project. Overall, implementation of the WQMP pursuant
to the existing regulations (included as PPP HYD-3) would ensure that operation of the proposed Project
would not violate any water quality standards, waste discharge requirements, or otherwise degrade water
quality, and impacts would be less than significant.
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge
such that the project may impede sustainable groundwater management of the basin?
Potentially Significant Impact. The Project site is currently developed as a commercial site and is surrounded
by other commercial developments. The Project would include a GPA, CA and rezone of the Project site with
a Housing Overlay (HO) district to allow for future development of up to 413 housing units, consistent with
the City's certified 2021-2029 Housing Element. The Project does not propose development; however, the
Project would provide for future proposed development through implementation of the housing overlay and
the City's certified 2021-2029 Housing Element. The provision for 413 additional housing units would require
additional water supply, which could result in decreased groundwater supply. Therefore, this topic will be
further analyzed in the EIR.
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration
of the course of a stream or river or through the addition of impervious surfaces, in a manner which
would:
i. result in a substantial erosion or siltation on- or off -site?
Less Than Significant Impact. The Project site does not include, and is not adjacent to, a natural stream or
river. Implementation of the Project would not alter the course of a stream or river.
The Project site is currently developed with commercial uses. The Project site currently drains into the City's
stormwater sewer system via a series of culverts and drains. Stormwater drains to the southeast corner of
the site into a catch basin at the Vanderberg Lane and Enderle Center Drive intersection. The storm drain
then continues east and connects to the existing Orange County Flood Control District (OCFCD) facility
located between Enderle Center Drive and Prospect Avenue.
Construction
Construction of future development facilitated by the Project would require the removal of asphalt within
the existing parking lot areas of the Project site and excavation of underlying soils. Construction could result
in a temporary disturbance of soils that could cause erosion or siltation on- and off -site.
51
Enderle Center Rezone Project
City of Tustin Initial Study
All proposed development construction would be required to comply with the California Regional Water
Quality Control Board (RWQCB) Order No. R8-2010-0033, National Pollutant Discharge Elimination System
(NPDES) Permit No. CAS618033 — Construction General Permit requirements (PPP HYD-1). Requirements
include installation of Best Management Practices (BMPs), which establishes minimum stormwater
management requirements and controls. To reduce the potential for soil erosion and the loss of topsoil, a
Stormwater Pollution Prevention Plan (SWPPP) is required by the RWQCB regulations to be developed by
a QSD (Qualified SWPPP Developer). The SWPPP is required to address site -specific conditions related to
specific grading and construction activities. The SWPPP would identify potential sources of erosion and
sedimentation to prevent loss of topsoil during construction, and to identify erosion control BMPs to reduce
or eliminate the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel bags; stabilized
construction entrances/exits; hydroseeding, and similar measures. In addition to RWQCB requirements,
proposed development would need to comply with the City of Tustin Grading Manual procedures (PPP HYD-
2). The City of Tustin Grading Manual is a compilation of rules, procedures, and interpretations necessary to
carry out the provisions of the Tustin City Code relating to grading and excavation.
Following construction, future development would be required to prepare and implement a Water Quality
Management Plan (WQMP) per City standards. Future projects would be required to comply with the
requirements of the Orange County Drainage Area Management Plan (DAMP) and the intent of the non -
point source NPDES Permit for Waste Discharge Requirements for the County of Orange, Orange County
Flood Control District and the incorporated cities of Orange County within the Santa Ana Region (included
as PPP HYD-3).
The DAMP regulations are included in the City's Municipal Code in Section 4902 and are the implementation
method for NPDES Stormwater Permit compliance. The DAMP:
• Provides the framework for the program management activities and plan development;
• Provides the legal authority for prohibiting unpermitted discharges into the storm drain system and for
requiring BMPs in new development and significant redevelopment;
• Ensures that all new development and significant redevelopment incorporates appropriate Site Design,
Source Control, and Treatment Control BMPs to address specific water quality issues; and
• Ensures that construction sites implement control practices that address construction related pollutants
including erosion and sediment control and onsite hazardous materials and waste management.
The DAMP requires that new development and significant redevelopment projects develop and implement
a water quality management plan (WQMP) that includes BMPs and low impact development (LID) design
features that would provide onsite treatment of stormwater to prevent pollutants from onsite uses from
leaving the site. These requirements would ensure that future projects would not result in substantial soil
erosion or the loss of topsoil. With implementation of uniformly applicable requirements (SWPPP, City of
Tustin Grading Manual, and the DAMP), the Project would result in a less -than -significant impact.
Operation
Changes due to development of the Project site could result in potential changes in the drainage pattern due
to siltation and erosion. However, the City's MS4 permit and County DAMP require new development projects
to prepare a WQMP (included as PPP HYD-3) that is required to include BMPs to reduce the potential of
erosion and/or sedimentation through site design and structural treatment control BMPs. As part of the
permitting approval process, the proposed drainage and water quality design and engineering plans would
be reviewed by the City's Engineering Division to ensure that the site -specific design limits the potential for
erosion and siltation. Overall, adherence to the existing regulations would ensure that impacts as a result of
future development related to alteration of a drainage pattern and erosion/siltation from operational
activities would be less than significant.
52
Enderle Center Rezone Project
City of Tustin Initial Study
ii. Substantially increase the rate or amount of surface runoff in a manner which would result in
flooding on- or offsite?
Less Than Significant Impact.
Construction
Construction of the proposed Project would require demolition of the existing building structures, including
foundations, floor slabs, and utilities systems, and crushing the existing pavement. These activities could
temporarily alter the existing drainage pattern of the site and change runoff flow rates. However, as
described previously, implementation of the Project requires a SWPPP (included as PPP WQ-1) that would
address site specific drainage issues related to construction of the Project and include BMPs to eliminate the
potential of flooding or alteration of a drainage pattern during construction activities. This includes regular
monitoring and visual inspections during construction activities. Compliance with the Construction General
Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-1) as verified by the
City through the construction permitting process would prevent construction -related impacts related to
potential alteration of a drainage pattern or flooding on- or offsite from development activities. Therefore,
construction impacts would be less than significant.
iii. Create or contribute runoff water which would exceed the capacity of existing or planned
stormwater drainage systems or provide substantial additional sources of polluted runoff?
Less Than Significant Impact.
The Project site is currently developed as a commercial site and is surrounded by other commercial
developments. The Project would include a GPA, CA and rezone of the Project site with a Housing Overlay
(HO) district to allow for future development of up to 413 housing units, consistent with the City's certified
2021 -2029 Housing Element. The Project does not propose development; however, the Project would
provide for future proposed development through implementation of the housing overlay and the City's
certified 2021-2029 Housing Element.
Construction
Construction of future development could result in a temporary disturbance of soils and the use of construction
equipment and materials that could increase pollutant loads discharged into stormwater runoff.
However, implementation of the Project requires a SWPPP (included as PPP HYD-1) that would address site -
specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate
the potential of polluted runoff and increased runoff during construction activities. This includes regular
monitoring and visual inspections during construction activities. Compliance with the Construction General
Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP HYD-1) as verified by the
City through the construction permitting process would prevent construction -related impacts related to
increases in run-off and pollution from development activities. Therefore, impacts would be less than
significant.
Operation
The Project site currently drains into the City's stormwater sewer system via a series of culverts and drains.
Stormwater drains to the southeast corner of the site into a catch basin at the Vanderberg Lane and Enderle
Center Drive intersection. The storm drain then continues east and connects to the existing Orange County
Flood Control District (OCFCD) facility located between Enderle Center Drive and Prospect Avenue. Because
the site is currently almost entirely paved, future development would increase intensity of development, but
would not result in additional impervious surfaces that could increase the volume and velocity of stormwater
53
Enderle Center Rezone Project
City of Tustin Initial Study
runoff. Therefore, future development would not be anticipated to exceed capacity of the existing
stormwater drainage system.
Additionally, as discussed previously, the City's MS4 permit and County DAMP require new development
projects to prepare a WQMP (included as PPP HYD-3) that is required to include BMPs to reduce the
potential of stormwater pollutants through site design and structural treatment control BMPs. As part of the
permitting approval process, the proposed drainage and water quality design and engineering plans would
be reviewed by the City's Engineering Division to ensure that the site -specific design limits the potential for
sources of polluted runoff. Overall, adherence to the existing regulations would ensure that impacts as a
result of future development related to stormwater runoff would be less than significant.
iv. impede or redirect flood flows?
Less Than Significant Impact.
The Project site is in the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM)
Map Number 06059C0l 64J (Federal Emergency Management Agency, 2009). The Project site is within an
area designated as Zone X, areas of 0.2 percent annual chance of flood; areas of 1 percent annual chance
of flood with average depths of less than 1 foot or with drainage areas less than 1 square mile; and areas
protected by levees from 1 percent annual chance flood. Therefore, the Project site is not currently within a
designated flood zone. The Project site is currently completely developed and completely paved, with the
exception of some ornamental landscaped areas. Future development would not result in additional
impervious surfaces that could increase the volume and velocity of stormwater runoff that would exacerbate
flood conditions. Therefore, the Project would result in a less -than -significant impact.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
No Impact.
According to the Federal Emergency Management Agency (FEMA) Map 06059C0164J, the Project site is
within Flood Zone X, or the 0.2 percent annual change flood area, areas of 1 percent annual chance flood
with average depth less than 1 foot or with drainage areas of less than 1 square mile (Federal Emergency
Management Agency, 2009). The site is not within a special flood hazard area.
A seiche is a surface wave created when an inland body of water is shaken, usually by earthquake activity.
The site also is not subject to flooding hazards associated with a seiche because there are no large body of
surface water located near the project site to result in effects related to a seiche, which could result in release
in pollutants due to inundation of the site. The Project site is not located near an inland body of water that
could result in impacts due to seiche.
The Pacific Ocean is located over 12 miles southwest of the Project site; consequently, there is no potential
for the Project site to be inundated by a tsunami that could release pollutants. In addition, the Project site is
flat and not located near any steep hillsides; therefore, there is no potential for the site to be adversely
affected by mudflow. Thus, implementation of the proposed Project would not expose people or structures
to a significant risk of loss, injury, or death involving inundation by seiche, tsunami, or mudflow that could
release pollutants due to inundation of the Project site. No impact would occur.
e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater
management plan?
Potentially Significant Impact. The Project site is currently developed as a commercial site and is surrounded
by other commercial developments. The Project would include a GPA, CA and rezone of the Project site with
a Housing Overlay (HO) district to allow for future development of up to 413 housing units, consistent with
the City's certified 2021 -2029 Housing Element. The Project does not propose development; however, the
54
of Tustin
Enderle Center Rezone Project
Initial Studv
Project would provide for future proposed development through implementation of the housing overlay and
the City's certified 2021-2029 Housing Element. The provision for 413 additional housing units would require
additional water supply, which could result in conflict with a sustainable groundwater management plan.
Therefore, this topic will be further analyzed in the EIR.
Plans, Policies, and Programs (PPP)
PPP HYD-1 SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide
the City Building Division evidence of compliance with the NPDES (National Pollutant
Discharge Elimination System) requirement to obtain a construction permit from the State
Water Resource Control Board (SWRCB). The permit requirement applies to grading and
construction sites of one acre or larger. The Project applicant/proponent shall comply by
submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater
Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the
construction site.
PPP HYD-2 City of Tustin Grading Manual. All future projects are required to comply with the City of
Tustin Grading Manual (1990). Implementation of grading manual standards would be
verified by the City during the plan check and permitting process.
PPP HYD-3 WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a
completed Water Quality Management Plan (WQMP) shall be prepared by the Project
applicant and submitted to and approved by the City Public Works Department. The
WQMP shall identify all Post -Construction, Site Design. Source Control, and Treatment
Control Best Management Practices (BMPs) that will be incorporated into the development
Project in order to minimize the adverse effects on receiving waters.
55
of Tustin
5.1 1 LAND USE AND PLANNING
Enderle Center Rezone Project
Initial Studv
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
a) Physically divide an established community?
❑
❑
❑
b) Cause a significant environmental impact due to a
®
❑
❑
❑
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
a) Physically divide an established community?
No Impact.
The Project site is currently developed as the Enderle Center, a commercial center that includes restaurant,
retail, and office uses. The Project would include a GPA, CA and rezone of the Project site with a Housing
Overlay (HO) district to allow for future development of up to 413 housing units, consistent with the City's
certified 2021-2029 Housing Element. The Project does not propose development; however, the Project
would provide for future proposed development through implementation of the housing overlay and the
City's certified 2021-2029 Housing Element. Implementation of the Project would allow for the intensification
of the existing site; however, the introduction of residential land uses would not result in division of an
established community. Therefore, the Project would result in no impact.
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Potentially Significant Impact.
The Project site has a General Plan land use designation of Planned Community Commercial/Business (PCCB)
and a zoning designation of Planned Community Commercial (PC COM). The Project would include a GPA,
CA and rezone of the Project site with a Housing Overlay (HO) district to allow for future development of
up to 413 housing units, consistent with the City's certified 2021-2029 Housing Element. The introduction of
residential land uses to an existing commercial site could result in conflicts with existing land use plans,
policies, and regulations. Therefore, the Project could result in a potentially significant impact and this topic
will be analyzed in the EIR.
56
of Tustin
5.1 2 MINERAL RESOURCES
Enderle Center Rezone Project
Initial Studv
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
a) Result in the loss of availability of a known mineral
❑
❑
❑
11
resource that would be of value to the region and the
residents of the state?
b) Result in the loss of availability of a locally important
❑
❑
❑
ED
mineral resource recovery site delineated on a local
general plan, specific plan, or other land use plan?
a) Result in the loss of availability of a known mineral resource that would be of value to the region
and the residents of the state?
No Impact. In order to protect the availability of mineral resources of value, the California Department of
Conservation identifies sites to which continuing access is important to satisfying mineral production needs of
the region and the State. The relative importance of potential mineral resource sites is indicated by inclusion
in one of four Mineral Resource Zones (MRZ):
• MRZ 1: No mineral resources
• MRZ 2: Significant resource area (quality and quantity known)
• MRZ 3: Significant resource area (quality and quantity unknown)
• MRZ 4: No information (applies primarily to high -value ores)
The Conservation/Open Space/Recreation Element identifies one mineral resource within the Tustin Planning
Area known as Mercury -Barite in Red Hill (City of Tustin, 2018). However, this resource is not utilized. The
Project site is not identified for mineral resource extraction. Therefore, the Project would result in no impact
on the loss of availability of a known mineral resource.
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on
the general plan, specific plan. or other land use plan?
No Impact. As discussed above, the Project site is not identified for mineral resource extraction per the City
General Plan Conservation Element (City of Tustin, 2018). Therefore, the Project would result in no impact
on the loss of availability of a locally important mineral resource recovery.
57
Enderle Center Rezone Project
City of Tustin Initial Study
5.13 NOISE
Would the project:
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the
project in excess of standards established in the local
general plan or noise ordinance, or applicable standards
of other agencies?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
c) For a project located within the vicinity of a private
airstrip or an airport land use plan or, where such a plan
has not been adopted, within two miles of a public
airport or public use airport, would the project expose
people residing or working in the project area to
excessive noise levels?
Potentially
Less Than
Less Than No
Significant
Significant
Significant Impact
Impact
with
Impact
Mitigation
Incorporated
®
❑
❑ ❑
® ❑
❑ ❑
® ❑
❑ ❑
a) through c)
Potentially Significant Impact. The Project site has a General Plan land use designation of Planned
Community Commercial/Business (PCCB) and a zoning designation of Planned Community Commercial (PC
COM). The Project would include a GPA, CA and rezone of the Project site with a Housing Overlay (HO)
district to allow for future development of up to 413 housing units, consistent with the City's certified 2021-
2029 Housing Element. The provision of development intensification could facilitate future noise impacts.
Residential land uses have not been previously analyzed for consistency with applicable noise standards.
The addition of residential land uses could result in a cumulatively considerable net increase of noise within
the study area due to the introduction of new mobile and stationary noise sources. Therefore, a noise study
will be conducted for the Project to determine potential noise impacts and this topic will be further analyzed
within the EIR.
58
of Tustin
5.14 POPULATION AND HOUSING
Enderle Center Rezone Project
Initial Studv
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
a) Induce substantial unplanned population growth in an
®
❑
❑
❑
area, either directly (for example, by proposing new
homes and businesses) or indirectly (for example, through
extension of roads or other infrastructure)?
b) Displace substantial numbers of existing people or
❑
❑
❑
housing, necessitating the construction of replacement
housing elsewhere?
a) Induce substantial unplanned population growth in an area, either directly or indirectly?
Potentially Significant Impact. The Project site has a General Plan land use designation of Planned
Community Commercial/Business (PCCB) and a zoning designation of Planned Community Commercial (PC
COM). The Project would include a GPA, CA and rezone of the Project site with a Housing Overlay (HO)
district to allow for future development of up to 413 housing units, consistent with the City's certified 2021-
2029 Housing Element. The provision of residential development within the Project site was not previously
analyzed under existing local or regional housing and land use plans. Therefore, the Project could facilitate
substantial unplanned population growth and this topic will be further analyzed within the EIR.
b) Displace substantial numbers of existing people or housing, necessitating the construction of
replacement housing elsewhere?
No Impact. The Project would include land use changes to allow for the future development of up to 413
housing units, consistent with the City's certified 2021-2029 Housing Element, within an existing commercial
land use. Therefore, the Project would not result in the displacement of existing people or housing and there
would be no impact.
59
of Tustin
5.15 PUBLIC SERVICES
Enderle Center Rezone Project
Initial Studv
a) Would the project result in substantial adverse physical
Potentially
Less Than
Less Than
No
impacts associated with the provision of new or physically
Significant
Significant
Significant
Impact
altered governmental facilities, need for new or physically
Impact
with
Impact
altered governmental facilities, the construction of which
Mitigation
could cause significant environmental impacts, in order to
Incorporated
maintain acceptable service ratios, response times or other
performance objectives for any of the public services:
i) Fire protection?
❑
❑
❑
ii) Police protection?
❑
❑
❑
❑
iii) Schools?
❑
❑
❑
❑
iv) Parks?
❑
❑
❑
❑
v) Other public facilities?
❑
❑
❑
❑
a) Result in substantial adverse physical impacts associated with the provision of new or physically
altered governmental facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or other performance
objectives for:
Potentially Significant Impact. The Project site has a General Plan land use designation of Planned
Community Commercial/Business (PCCB) and a zoning designation of Planned Community Commercial (PC
COM). The Project would include a GPA, CA and rezone of the Project site with a Housing Overlay (HO)
district to allow for future development of up to 413 housing units, consistent with the City's certified 2021-
2029 Housing Element. As previously discussed, the provision of residential development within the Project
site was not previously analyzed under existing local or regional plans and could result in substantial
unplanned population growth. Therefore, the potential unplanned future demand placed on public service
providers could require the development of new or physically altered fire, police, school, park, and library
facilities. The Project could result in a potentially significant impact and this topic will be further analyzed
within the EIR.
W
Enderle Center Rezone Project
City of Tustin Initial Study
5.16 RECREATION
Would the project:
a) Would the project increase the use of existing
neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of
the facility would occur or be accelerated?
b) Does the project include recreational facilities or require
the construction or expansion of recreational facilities
which might have an adverse physical effect on the
environment?
Potentially
Less Than
Less Than No
Significant
Significant
Significant Impact
Impact
with
Impact
Mitigation
Incorporated
❑
❑
❑ ❑
❑ ❑ ❑ ❑
a) and b)
Potentially Significant Impact. The Project site has a General Plan land use designation of Planned
Community Commercial/Business (PCCB) and a zoning designation of Planned Community Commercial (PC
COM). The Project would include a GPA, CA and rezone of the Project site with a Housing Overlay (HO)
district to allow for future development of up to 413 housing units, consistent with the City's certified 2021-
2029 Housing Element. As previously discussed, the provision of residential development within the Project
site was not previously analyzed under existing local or regional plans and could result in substantial
unplanned population growth. Therefore, the potential unplanned future demand placed on recreational
facilities could result in deterioration of nearby recreational facilities and/or require the development of
new or physically altered recreational facilities. The Project could result in a potentially significant impact
and this topic will be further analyzed within the EIR.
M
Enderle Center Rezone Project
City of Tustin Initial Study
5.17 TRANSPORTATION
Would the project:
a) Conflict with a program, plan, ordinance, or policy
addressing the circulation system, including transit,
roadway, bicycle, and pedestrian facilities?
b) Conflict or be inconsistent with CEQA Guidelines §
15064.3, subdivision (b)?
c) Substantially increase hazards due to a geometric design
feature (e.g., sharp curves or dangerous intersections) or
incompatible uses (e.g., farm equipment)?
d) Result in inadequate emergency access?
Potentially
Less Than
Less Than No
Significant
Significant
Significant Impact
Impact
with
Impact
Mitigation
Incorporated
®
❑
❑ ❑
®
❑
❑ ❑
®
❑
❑ ❑
® ❑ ❑ ❑
a) through d)
Potentially Significant Impact. The Project would include a GPA, CA and rezone of the Project site with a
Housing Overlay (HO) district to allow for future development of up to 413 housing units, consistent with the
City's certified 2021-2029 Housing Element. The Project does not propose development; however, the
Project would provide for future proposed development through implementation of the housing overlay and
the City's certified 2021-2029 Housing Element. Future residential development would result in the
generation of additional trips and demand placed on the existing circulation system. Land use changes could
result in inconsistencies with programs, plans, policies, and local ordinances regarding the circulation system.
Further, future residential development could result in a Vehicle Miles Traveled (VMT) Impact. Therefore, a
VMT study will be prepared for the Project and this topic will be analyzed in the EIR.
62
of Tustin
5.18 TRIBAL CULTURAL RESOURCES
a) Would the project cause a substantial adverse change
in the significance of a tribal cultural resource, defined
in Public Resources Code Section 21074 as either a site,
feature, place, cultural landscape that is geographically
defined in terms of the size and scope of the landscape,
sacred place, or object with cultural value to a
California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register
of Historical Resources, or in a local register of historical
resources as defined in Public Resources Code section
5020.1(k)?
ii) A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to be
significant pursuant to criteria set forth in subdivision (c)
of Public Resources Code Section 5024.1. In applying
the criteria set forth in subdivision (c) of Public Resource
Code Section 5024.1, the lead agency shall consider
the significance of the resource to a California Native
American tribe?
Enderle Center Rezone Project
Initial Studv
Potentially
Less Than
Significant
Significant
Impact
with
Mitigation
Incorporated
®
❑
Less Than No
Significant Impact
Impact
❑ ❑
® ❑ ❑ ❑
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource,
defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape
that is geographically defined in terms of the size and scope of the landscape, sacred place, or
object with cultural value to a California Native American tribe, and that is:
Potentially Significant Impact. The Project site has a General Plan land use designation of Planned
Community Commercial/Business (PCCB) and a zoning designation of Planned Community Commercial (PC
COM). The Project site is currently developed as a commercial site and is surrounded by other commercial
developments.
Tribal cultural resources are sites, features, places, cultural landscapes, sacred places, and objects with
cultural value to a California Native American tribe that are either eligible or listed in the California Register
of Historical Resources or local register of historical resources (Public Resources Code § 21074). Pursuant to
Assembly Bill 52 (AB 52), the City will conduct consultation with tribes that indicate an interest in consulting
on the Project. The results of the consultation will be incorporated into the EIR, and this topic will be further
analyzed.
63
Enderle Center Rezone Project
City of Tustin
Initial Study
5.19 UTILITIES AND SERVICE SYSTEMS
Would the project:
Potentially
Less Than
Less Than No Impact
Significant
Significant
Significant
Impact
with
Impact
Mitigation
Incorporated
a) Require or result in the relocation or construction of new
❑
❑
❑ ❑
or expanded water, wastewater treatment,
stormwater drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
b) Have sufficient water supplies available to serve the ❑ ❑ ❑ ❑
project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
c) Result in a determination by the wastewater treatment ❑ ❑ ❑ ❑
provider which serves or may serve the project that it
has adequate capacity to serve the project's projected
demand in addition to the provider's existing
commitments?
d) Generate solid waste in excess of state or local ❑ ❑ ❑ ❑
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
e) Comply with federal, state, and local management ❑ ❑ ❑ ❑
and reduction statutes and regulations related to solid
waste?
a) through e)
Potentially Significant Impact. The Project site has a General Plan land use designation of Planned
Community Commercial/Business (PCCB) and a zoning designation of Planned Community Commercial (PC
COM). The Project would include a GPA, CA and rezone of the Project site with a Housing Overlay (HO)
district to allow for future development of up to 413 housing units, consistent with the City's certified 2021-
2029 Housing Element. As previously discussed, the provision of residential development within the Project
site was not previously analyzed under existing local or regional plans and could result in substantial
unplanned population growth. The potential demand that could result from additional residential uses could
surpass the existing capacity and availability of resources and existing utility infrastructure. Therefore, the
potential unplanned future demand placed on water, wastewater treatment, stormwater drainage, electric
power, natural gas, or telecommunications facilities could require the development of construction of new or
expanded utility facilities. Additionally, future waste potentially generated by residential land uses could
exceed the solid waste capacity and standards/reduction goals for the Project site. The Project could result
in a potentially significant impact and this topic will be further analyzed within the EIR.
64
Enderle Center Rezone Project
City of Tustin Initial Study
5.20 WILDFIRE
If located in or near state responsibility areas or lands
classified as very high fire hazard severity zones, would
the project:
a) Substantially impair an adopted emergency response
plan or emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency
water sources, power lines or other utilities) that may
exacerbate fire risk or that may result in temporary or
ongoing impacts to the environment?
d) Expose people or structures to significant risks, including
downslope or downstream flooding or landslides, as a
result of runoff, post -fire slope instability, or drainage
changes?
Potentially
Less Than
Less Than
No
Significant
Significant
Significant
Impact
Impact
with
Impact
Mitigation
Incorporated
❑
❑
❑
❑
❑
❑
❑ ❑ ❑ 11
❑ ❑ ❑ 11
a) through d)
No Impact. The Project site is currently developed as a commercial site and is surrounded by other
commercial developments. According to the CalFire Fire Hazard Severity Zone Map, the City of Tustin
contains very high fire severity zones in the northeast portion of the City (California Department of Forestry
and Fire Protection, 2023). The Project site is not located within or near state responsibility areas or lands
classified as very high fire hazard severity zones. Therefore, the project would result in no impact due to
wildfire hazard.
65
of Tustin
5.21 MANDATORY FINDINGS OF SIGNIFICANCE
Enderle Center Rezone Project
Initial Studv
Potentially Less Than Less Than No
Significant Significant Significant Impact
Impact with Impact
Mitigation
Incorporated
a) Does the project have the potential to substantially
❑ ® ❑ ❑
degrade the quality of the environment, substantially
reduce the habitat of a fish or wildlife species, cause
a fish or wildlife population to drop below self-
sustaining levels, threaten to eliminate a plant or
animal community, substantially reduce the number or
restrict the range of a rare or endangered plant or
animal or eliminate important examples of the major
periods of California history or prehistory?
b) Does the project have impacts that are individually
® ❑ ❑ ❑
limited, but cumulatively considerable? ("Cumulatively
considerable" means that the incremental effects of a
project are considerable when viewed in connection
with the effects of past projects, the effects of other
current projects, and the effects of probable future
projects)?
c) Does the project have environmental effects which will
® ❑ ❑ ❑
cause substantial adverse effects on human beings,
either directly or indirectly?
a) Does the project have the potential to substantially degrade the quality of the environment,
substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to
drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially
reduce the number or restrict the range of a rare or endangered plant or animal or eliminate
important examples of the major periods of California history or prehistory?
Less Than Significant Impact with Mitigation. As discussed in Section 5.4, the Project site is currently
developed and does not contain habitat of a fish or wildlife species. However, the Project site contains
existing ornamental trees that could be used for nesting by common bird species that are protected by the
federal Migratory Bird Treaty Act (MBTA) and the California Fish and Game Code Sections 3503.5, 3511,
and 3515 during the avian nesting and breeding season that occurs between February 1 and September
15. The provisions of the MBTA prohibits disturbing or destroying active nests. Therefore, Mitigation Measure
BIO-1 has been included to require that if commencement of vegetation clearing occurs between February
1 and September 15, a qualified biologist shall conduct a nesting bird survey no more than 3 days prior to
commencement of activities to confirm the absence of nesting birds. With implementation of Mitigation
Measure BIO-1, potential impacts to nesting birds would be less than significant.
Additionally, as described in Section 5.5, the project site does not contain any buildings or structures that
meet any of the California Register of Historical Resources (California Register) criteria or qualify as
"historical resources" as defined by CEGA. Additionally, the Project site is completely paved and is not
anticipated to contain archaeological resources; however, Mitigation Measure CUL-1 has been included to
stop all ground disturbing activity within a 50-foot radius of an inadvertent discovery in the unlikely event
that a potential archeological resource is unearthed during excavation activities. Therefore, the proposed
project would not cause a substantial adverse change in the significance of a historical or archaeological
resource. As discussed in Section 5.8, the Project site is not sensitive to paleontological resources.
Therefore, the Project would result in a less than significant impact with mitigation on the potential to
Enderle Center Rezone Project
of Tustin Initial Studv
substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife
species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant
or animal community, substantially reduce the number or restrict the range of a rare or endangered plant
or animal or eliminate important examples of the major periods of California history or prehistory.
b) Does the project have impacts that are individually limited, but cumulatively considerable?
("Cumulatively considerable" means that the incremental effects of a project are considerable when
viewed in connection with the effects of past projects, the effects of other current projects, and the
effects of probable future projects)?
Potentially Significant Impact. Cumulative impacts are defined as two or more individual effects that, when
considered together, are considerable or that compound or increase other environmental impacts. The
cumulative impact from several projects is the change in the environment that results from the incremental
impact of the development when added to the impacts of other closely related past, present, and reasonably
foreseeable or probable future developments. Cumulative impacts can result from individually minor, but
collectively significant, developments taking place over a period. The CEQA Guidelines, Section 15130 (a)
and (b), states:
a) Cumulative impacts shall be discussed when the project's incremental effect is cumulatively
considerable.
b) The discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of
occurrence, but the discussion need not provide as great detail as is provided of the effects
attributable to the project. The discussion should be guided by the standards of practicality and
reasonableness.
As presented in this document, potential Project -related impacts are either less than significant or would be
less than significant with mitigation incorporated for impacts related to aesthetics, agriculture and forestry
resources, biological resources, cultural resources, geology and soils, hazards and hazardous materials,
mineral resources, and wildfire risk. Given that the potential Project -related impacts would be less than
significant or mitigated to a less than significant level, implementation of the proposed Project would not
result in impacts that are cumulatively considerable when evaluated with the impacts of other current projects,
or the effects of probable future projects. Therefore, the proposed Project's contribution to any significant
cumulative impacts would be less than cumulatively considerable for aesthetics, agriculture and forestry
resources, biological resources, cultural resources, geology and soils, hazards and hazardous materials,
mineral resources, and wildfire risk.
The Project could result in significant impacts on several environmental topics, and further, cumulatively
considerable impacts. Specifically, the Project has the potential to result in cumulatively considerable impacts
on energy, GHG, land use, noise, population and housing, public services, recreation, transportation, tribal
cultural resources, and utilities and service systems. The Project's potential for contribution to cumulatively
considerable impacts will be further analyzed within the EIR.
c) Does the project have environmental effects which will cause substantial adverse effects on human
beings, either directly or indirectly?
Potentially Significant Impact. As discussed in Sections 5.3, 5.1 1, and 5.13, the Project could facilitate
development that could result in significant air quality and noise impacts, as well as conflict with policies
implemented to mitigate environmental impacts on existing populations. An air quality and noise study will
be prepared for the Project to evaluate potential impacts on human beings, with specific focus on sensitive
receptor populations. Therefore, the Project could result in a potentially significant impact and this topic will
be further analyzed in the EIR.
67
of Tustin
6 REFERENCES
Enderle Center Rezone Project
Initial Studv
BFSA Environmental Services. (2023). Archaeological Resources Records Search Results for the Enderle Center
Project, Tustin,.
BFSA Environmental Services. (2023). Archaeological Resources Records Search Results for the Tustin Legacy
Specific PlanAmendment Project, Tustin, California.
California Department of Conservation. (2018, November 1). DOC Maps: Division of Land Resource
Protection. Retrieved November 6, 2023, from California Important Farmland Finder:
https://maps.conservation.ca.gov/DLRP/CIFF/
California Department of Forestry and Fire Protection. (2022). Fire and Resource Assessment Program.
Retrieved from California Department of Forestry and Fire Protection: California Department of
Forestry and Fire Protection
California Department of Forestry and Fire Protection. (2023, December 19). CalFire Hazard Severity Zone
Viewer. Retrieved from Fire and Resource Assessment Program: https://egis.fire.ca.gov/FHSZ/
California Department of Transportation. (2018). California State Scenic Highway System Map. Retrieved
from
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e805
7116f1aacaa
California Geological Survey. (1994). Generalized Mineral Land Classification Map of Orange County.
Retrieved from Open File Report 94-15, Plate 1.
ftp://ftp.consrv.ca.gov/pub/dmg/pubs/ofr/OFR_94-15/OFR_94-15_Plate_l .pdf.
California Geological Survey. (2020, July 29). California State Geoportal. Retrieved from CGS Seismic
Hazards Program: Liquefaction Zones: https://gis.data.ca.gov/datasets/cadoc::cgs-seismic-
hazards-program-liquefaction-zones
California State Water Resources Control Board. (2022, September 8). National Pollutant Discharge
Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction
and Land Disturbance Activities (General Permit). Retrieved from California State Water Resources
Control Board:
https://www.waterboards.ca.gov/water issues/prog rams/stormwater/construction/docs/2022-
0057-dwq-with-attachments/cg p 2022_order.pdf
California Waterboards. (2023). California 2078 Integrated Report Map. Retrieved from California 2018
Integrated Report: https://www.waterboards.ca.govHeader Control lerCalifornia 2018 Integrated
Report
City of Tustin. (2018, November). City of Tustin General Plan. Retrieved from
https://www.tustinca.org/DocumentCenter/View/71 3/City-of-Tustin-Genera I-Plan-PDF
City of Tustin. (2019, November). Emergency Operations Plan. Retrieved from EMERGENCY OPERATIONS
PLAN (EOP): https://www.tustinca.org/DocumentCenter/View/570/Emergency-Operations-Plan-
PDF
County of Orange. (2005, April). County of Orange General Plan. Retrieved from Chapter IV Scenic Highway
Plan Map: https://ocds.ocpublicworks.com/sites/ocpwocds/files/import/data/files/8588.pdf
Enderle Center Rezone Project
City of Tustin Initial Study
Department of Toxic Substances Control. (2023, December 22). Hazardous Waste and Substances Sites List.
Retrieved from Envirostar: https://www.envirostor.dtsc.ca.gov/public/
EPD Solutions. (2024). Danielle Example. Retrieved from EPD Solutions: www.cool.com
EPD Solutions. (2024). EPD Solutions. Retrieved from Jeremy Krout: www.cool.com
Federal Emergency Management Agency. (2009, December 3). 06059CO279J. Retrieved from FEMA Flood
Map Service Center: https://msc.fema.gov/portal/home
Federal Emergency Management Agency. (2009, December 3). Map Number 06059C0I 64J. Retrieved from
Federal Insurance Rate Map:
https://msc.fema.gov/porta I/sea rch?Ad d ressQuery=enderie%20center%2C%20tustin%2C%20c
a
OC Watersheds. (2006, July). Proposed 2007 Drainage Area Management Plan. Retrieved from Newport
Bay Watershed Action Plan: https://ocerws.ocpublicworks.com/sites/ocpwocerws/files/2021-
02/Newport%20Bay%20WAP.pdf
Orange County Airport Land Use Commission. (2008, April 17). Land Use Plan for John Wayne Airport.
Retrieved from Orange County Airport Land Use Commission: https://files.ocair.com/media/2021-
02/JWA_AELUP-April-17-2008.pdf?Versionld=cBObyJidad9OuY5im7Oai5aWaT1 FS.vD
Orange County Transportation Authority. (2016, November). Retrieved from Natural Community
Conservation Plan/Habitat Conservation Plan:
https://www.octa.net/pdf/NCCP%20HCP%20FINAL.pdf
Parrish, J. G. (1998, April 15). Earthquake Zones of Required Investigation, Orange Quadrangle. Retrieved
from California Geological Survey: https://maps.conservation.ca.gov/cgs/EQZApp/app/
Parrish, J. G. (1999, March 25). Earthquake Zones of Required Investigation, Seal Beach Quadrangle.
Retrieved from California Geological Survey:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
Parrish, J. G. (2015, December 4). Earthquake Zones of Required Investigation, Yorba Linda Quadrangle.
Retrieved from California Geological Survey:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
Placeworks. (2015). Tustin Legacy Specific Plan Amendment Initial Study. City of Tustin.
State Water Resource Control Board. (2023). GeoTracker. Retrieved from
https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=tustin+legacy%2C+t
ustin%2C+ca
U.S. Geological Survey. (2001). Areas of Land Subsidence in California. Retrieved November 10, 2023, from
LA / Santa Ana Basin: https://ca.water.usgs.gov/land subsidence/california-subsidence-areas.html
U.S. Geological Survey. (2023, October 31). National Land Cover Database. Retrieved November 6, 2023,
from NLCD 2021 Land Cover California Subset: https://data.ca.gov/dataset/nlcd-2021-land-
cove r-ca I iforni a -subset
United States Geological Survey. (2023, December 19). Areas of Land Usbsidence in California. Retrieved
from USGS: https://ca.water.usgs.gov/land subsidence/california-subsidence-areas.htmi
.•
of Tustin
End of document.
Enderle Center Rezone Project
Initial Studv
70
0
BFSA Environmental Services Archaeology/History/Paleontology/Biology
A Perennial Company
February 16, 2024
Jazmin Rodriguez
EPD Solutions
3333 Michelson Drive, Suite 500
Irvine, California 92660
RE: Archaeological Resources Records Search Results for the Enderle Center Project, Tustin,
California (APNs 401-252-05, -06, -08, through -10, 401-253-03, and -04)
Dear Ms. Rodriguez:
An archaeological resources records search has been completed for the Enderle Center
Project. The proposed approximately 11-acre project is located at the intersection of 17th Street
and Enderle Center Drive (Assessor's Parcel Numbers [APNs] APNs 401-252-05, -06, -08,
through -10, 401-253-03, and -04) within the city of Tustin, California. The subject property is
situated within an unsectioned portion of Township 5 South, Range 9 West on the U.S. Geological
Survey (USGS) Orange, California (7.5-minute) topographic quadrangle map. As part of the
environmental review process, BFSA Environmental Services, a Perennial Company (BFSA),
conducted an archaeological resources records search at the South Central Coastal Information
Center (SCCIC) at California State University, Fullerton.
Archaeological Records Search Results
The archaeological resources records search was completed by BFSA at the SCCIC on
August 22, 2023, and encompassed the project area as well as an additional 500 feet surrounding
the project. Based upon the records search results, no resources are recorded within the project or
the 500-foot buffer search area. No previous studies are recorded on the property, however, there
are two studies recorded within the search area that are not specific to the subject property (Padon
1989; McKenna 2001).
BFSA requested a review of the Sacred Lands File (SLF) by the Native American Heritage
Commission (NAHC) on August 18, 2023, to determine if any recorded Native American sacred
sites, or locations of religious or ceremonial importance are present within one mile of the project.
The results of this search were received on October 3, 2023. The results were negative.
14010 Poway Road, Suite A, Poway, California 92064; Phone (858) 484-0915
BFSA Environmental Services, a Perennial Company — Page 2
The full results of the SCCIC completed records search and the NAHC SLF search results
are attached to this letter report (Attachments A and B). Please contact us should you have any
questions or require additional study for this project.
Regards,
Tracy Stropes, M.A., RPA
Director/Principal Archaeologist
BFSA Environmental Services
Attachments:
Attachment A — Archaeological Records Search Results
Attachment B — NAHC Sacred Lands File Search Results
Archaeological Resources Records Search Results for the Enderle Center Project
ATTACHMENT A
Archaeological Records Search Results
BFSA Environmental Services, a Perennial Company
CALIFORNIA HISTORICAL RESOURCES INFORMATION SYSTEMS
RECORDS SEARCH
Company: BFSA Environmental Services, a Perennial Company
Processed By:
Date Processed:
Project Identification:
Information Center:
Search Radius:
Historical Resources:
Emily T. Soong
August 24, 2023
Enderle Center
South Central Coastal Information Center
500 Feet Buffer
Trinomial and Primary site maps have been reviewed. All sites within the project
boundaries and the specified radius of the project area have been plotted. Copies of the
site record forms have been reviewed for all recorded sites.
There are no resources located within a 500 feet radius of the current project area or
within the subject property.
Previous Survey Report Boundaries:
Project boundary maps have been reviewed. National Archaeological Database (NADB)
citations for reports within the project boundaries and within the specified radius of the
project area have been reviewed.
There are two reports within a 500 feet radius of the current project area, none of which
are located within the subject property.
N3 RESav,RCES iNSE—ttQCH /WE—)c� N Rcsourc,
500 Ft Buffer Enderle Center Project n 1:24,000
Project USGS Orange Quadrangle
(7.5-minute series) ETS BFSAES: 8/18/2023
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x+u[L& ' {
i
226
`P may.
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QProject
Enderle Center Project
USGS Orange Quadrangle
(7.5-minute series)
N A �ef 9Yt3 24,000
ETS BFSAES: 8/18/2023
Report List
Ender le Center
Report No. Other IDs
Year Author(s) Title
Affiliation Resources
OR-00946 Paleo - 1989 Padon, Beth Archaeological and Paleontological Review LSA Associates, Inc.
for 13911, 13931, and 13951 Carroll Way,
Tustin. Ca.
OR-02375 Cellular - 2001 McKenna, Jeanette A. Review of Culutral Resource McKenna et al.
Assess ment/evaluation for Cingular Wireless
Site Sc-001-01, Orange County, California
Page 1 of 1 SCCIC 8/22/2023 1:15:21 PM
Archaeological Resources Records Search Results for the Enderle Center Project
ATTACHMENT B
NAHC Sacred Lands File Search Results
BFSA Environmental Services
A Perennial Company
August 18, 2023
For: Native American Heritage Commission
915 Capitol Mall, Room 364
Sacramento, California 95814
From: Emily T. Soong
BFSA Environmental Services, a Perennial Company
14010 Poway Rd. Suite A
Poway, CA 92064
Archaeology/History/Paleontology/Biology
Re: Request for Sacred Lands File and Native American Contact List for the Enderle Center
Project, Tustin, Orange County, California.
I would like to request a record search of the Sacred Lands File and a list of appropriate Native
American contacts for the following project: Enderle Center Project (Project No. 23-222). The
project is an archaeological study located southeast of the intersection of Yorba Street and 17th
Street (APNs 401-252-05, -06, -08, -09, -10, 401-253-03, -04), Tustin, Orange County, California.
Specifically, the project is in an unsectioned portion of Township 5 South, Range 9 West as seen
on the USGS Orange, California topographic quadrangle. Please find the enclosed map on which
the project is delineated.
Thank you for your time.
Sincerely,
Emily T. Soong
Graphics/GIS
Billing: 14010 Poway Road, Suite A, Poway, CA 92064
Phone: 858-484-0915
Email: esoong@bfsa.perennialenv.com
Attachments:
USGS 7.5 Orange, California, topographic maps with project area delineated.
Sacred Lands File request form
14010 Poway Road, Suite A, Poway, California 92064; Phone 858-484-0915
Sacred Lands File & Native American Contacts List Request
NATIVE AMERICAN HERITAGE COMMISSION
915 Capitol Mall, RM 364 * Sacramento, CA 95814 * (916) 653-4082
(916) 657-5390 — Fax * nahc@pacbell.net
Information Below is Required for a Sacred Lands File Search
Project: Enderle Center Project (Project No. 23-222)
County: Orange
USGS Quadrangle Name(s): Orange
Township 5 South, Range 9 West
Company/Firm/Agency: BFSA Environmental Services, a Perennial
Company
Contact Person: Emily T. Soong
Street Address: 14010 Poway Road, Suite A
City: Poway Zip: 92064
Phone: 858-484-0915
Fax: 858-679-9896
Email: esoongkbfsa.perennialenv.com
Project Description:
I would like to request a record search of the Sacred Lands File and a list of
appropriate Native American contacts for the following project: Enderle Center
Project (Project No. 23-222). The project is an archaeological study located southeast
of the intersection of Yorba Street and 17th Street (APNs 401-252-05, -06, -08, -09, -
10, 401-253-03, -04), Tustin, Orange County, California. Specifically, the project is in
an unsectioned portion of Township 5 South, Range 9 West as seen on the USGS
Orange, California topographic quadrangle. Please find the enclosed map on which
the project is delineated.
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Project
Enderle Center Project
USGS Orange Quadrangle
(7.5-minute series)
N
A
1:24,000
ETS BFSAES: 8/18/2023
From: NAHC(cbNAHC
To: Emily Soona
Cc: Green, AndrewCla NAHC
Subject: RE: Request for Sacred Land Search for The Market Place Project (23-223)
Date: Saturday, August 19, 2023 9:16:27 AM
Attachments: imaae001.Dna
The Market Place Project Sacred Lands File form.pdf
The Market Place Proiect NAHC Search Reauest.Ddf
The Market Place Map.Ddf
This sender is trusted.
Hello,
Thank you for your message. We're in receipt of your request. We have recently hired new staff, and
this change in our office is creating some delays. We estimate a turn -around time of 4 weeks and
don't anticipate responding sooner than the end of that time frame. Please let us know if you have
any questions.
Kind regards,
Native American Heritage Commission
1550 Harbor Blvd, Suite 100
West Sacramento, CA 95691
(916) 373-3710
From: Emily Soong <esoong@bfsa.perennialenv.com>
Sent: Friday, August 18, 2023 10:48 AM
To: NAHC@NAHC <NAHC@nahc.ca.gov>
Cc: Jenni Stropes <jstropes@bfsa.perennialenv.com>
Subject: Request for Sacred Land Search for The Market Place Project (23-223)
To whom it may concern,
I would like to request a record search of the Sacred Lands File and a list of appropriate Native
American contacts for the following project: The Market Place Project (Project No. 23-223). The
project is an archaeological study located north of the intersection of Jamboree Road and Santa Ana
Freeway (APNs 500-291-02, -04, -06, -07, -08, -11, -21, -23, -24, -25, -26, -27, 500-312-01, -02, -04,
-06, -08, -09), Tustin, Orange County, California. Specifically, the project is in former Lomas De
Santiago and San Joaquin Ranchos, Township 1 South, Range 6 West as seen on the USGS Tustin,
California topographic quadrangle. Please find the enclosed map on which the project is delineated.
Best regards,
Emily T. Soong
BFSA Environmental Services
0333 )
BN':i.4 l:v�•inunnent:�l `J'CtVIL:C�
Phone: 858-484-0915
Email: esoong@bfsa.perennialenv.com
14010 Poway Road, Suite A
Poway, CA 92064
www.bfsa-ca.com
CHAIRPERSON
Reginald Pagaling
Chumash
VICE -CHAIRPERSON
Buffy McQuillen
Yokayo Pomo, Yuki,
Nomlaki
NATIVE AMERICAN HERITAGE COMMISSION
October 3, 2023
Emily T. Soong
BFSA Environmental Services
Via Email to: esoong@bfsa.perennialenv.com
Re: Enderle Center Project, Orange County
Dear Ms. Soong:
A record search of the Native American Heritage Commission (NAHC) Sacred Lands File (SLF)
SECRETARY
was completed for the information you have submitted for the above referenced project. The
Sara Dutschke
Miwok
results were negative. However, the absence of specific site information in the SLF does not
indicate the absence of cultural resources in any project area. Other sources of cultural
resources should also be contacted for information regarding known and recorded sites.
PARLIAMENTARIAN
Wayne Nelson
Attached is a list of Native American tribes who may also have knowledge of cultural resources
Luiseno
in the project area. This list should provide a starting place in locating areas of potential
adverse impact within the proposed project area. I suggest you contact all of those indicated;
COMMISSIONER
if they cannot supply information, they might recommend others with specific knowledge. By
Isaac Bojorquez
contacting all those listed, your organization will be better able to respond to claims of failure to
Ohlone-Costanoon
consult with the appropriate tribe. If a response has not been received within two weeks of
notification, the Commission requests that you follow-up with a telephone call or email to
COMMISSIONER
ensure that the project information has been received.
Stanley Rodriguez
Kumeyaay
If you receive notification of change of addresses and phone numbers from tribes, please notify
me. With your assistance, we can assure that our lists contain current information.
COMMISSIONER
Laurena Bolden
If you have any questions or need additional information, please contact me at my email
Serrano
address: Andrew.Green@nahc.ca.gov.
COMMISSIONER
Sincerely,
Reid Milanovich
Cahuilla
COMMISSIONER
Vacant
Andrew Green
Cultural Resources Analyst
EXECUTIVE SECRETARY
Raymond C.
Attachment
Hitchcock
Miwok, Nisenan
NAHC HEADQUARTERS
1550 Harbor Boulevard
Suite 100
West Sacramento,
California 95691
(916)373-3710
nahc@nahc.ca.aov
NAHC.ca.gov Page 1 Of 1
Native American Heritage Commission
Native American Contact List
Orange County
10/3/2023
Tribe Name
Fed (F)
Contact Person
Contact
Phone #
Fax #
Email Address
Cultural
Non-
Address
Affiliation
Fed (N)
Gabrieleno
N
Christina Swindall
P.O. Box 393
(844) 390-0787
admin@gabrielenoindians.org
Gabrieleno
Band of
Martinez, Secretary
Covina, CA, 91723
Mission Indians
- Kizh Nation
Gabrieleno
N
Andrew Salas,
P.O. Box 393
(844) 390-0787
admin@gabrielenoindians.org
Gabrieleno
Band of
Chairperson
Covina, CA, 91723
Mission Indians
- Kizh Nation
Gabrieleno/Ton
N
Anthony Morales,
P.O. Box 693
(626) 483-3564
(626) 286-1262
GTTribalcouncil@aol.com
Gabrieleno
gva San
Chairperson
San Gabriel, CA,
Gabriel Band of
91778
Mission Indians
Gabrielino
N
Sandonne Goad,
106 1/2 Judge John
(951) 807-0479
sgoad@gabrielino-tongva.com
Gabrielino
/Tongva Nation
Chairperson
Aiso St., #231
Los Angeles, CA,
90012
Gabrielino
N
Robert Dorame,
P.O. Box 490
(562) 761-6417
(562) 761-6417
gtongva@gmail.com
Gabrielino
Tongva Indians
Chairperson
Bellflower, CA,
of California
90707
Tribal Council
Gabrielino
N
Christina Conley,
P.O. Box 941078
(626) 407-8761
christina.marsden@alumni.usc.ed
Gabrielino
Tongva Indians
Cultural Resource
Simi Valley, CA,
u
of California
Administrator
93094
Tribal Council
Page 1 of 3
Tribe Name
Fed (F)
Contact Person
Contact
Phone #
Fax #
Email Address
Cultural
Non-
Address
Affiliation
Fed (N)
Gabrielino-
N
Sam Dunlap,
P.O. Box 3919
(909) 262-9351
tongvatcr@gmail.com
Gabrielino
Tongva Tribe
Cultural Resource
Seal Beach, CA,
Director
90740
Gabrielino-
N
Charles Alvarez,
23454 Vanowen
(310) 403-6048
Chavez1956metro@gmail.com
Gabrielino
Tongva Tribe
Chairperson
Street
West Hills, CA,
91307
Juaneno Band
N
Joyce Perry,
4955 Paseo Segovia
(949) 293-8522
kaamalam@gmail.com
Juaneno
of Mission
Cultural Resource
Irvine, CA, 92603
Indians
Director
Acjachemen
Nation -
Belardes
Juaneno Band
N
Heidi Lucero,
31411-A La Matanza
(562) 879-2884
jbmian.chairwoman@gmail.com
Juaneno
of Mission
Chairperson, THPO
Street
Indians
San Juan
Acjachemen
Capistrano, CA,
Nation 84A
92675
Pala Band of
F
Alexis Wallick,
PMB 50, 35008 Pala
(760) 891-3537
awallick@palatribe.com
Cupeno
Mission Indians
Assistant THPO
Temecula Road
Luiseno
Pala, CA, 92059
Pala Band of
F
Shasta Gaughen,
PMB 50, 35008 Pala
(760) 891-3515
(760) 742-3189
sgaughen@palatribe.com
Cupeno
Mission Indians
Tribal Historic
Temecula Road
Luiseno
Preservation Officer
Pala, CA, 92059
Santa Rosa
F
Lovina Redner,
P.O. Box 391820
(951) 659-2700
(951) 659-2228
Isaul@santarosa-nsn.gov
Cahuilla
Band of
Tribal Chair
Anza, CA, 92539
Cahuilla
Indians
Page 2 of 3
Tribe Name
Fed (F)
Contact Person
Contact
Phone #
Fax #
Email Address
Cultural
Non-
Address
Affiliation
Fed (N)
Soboba Band
F
Jessica Valdez,
P.O. Box 487
(951) 663-6261
(951) 654-4198
jvaldez@soboba-nsn.gov
Cahuilla
of Luiseno
Cultural Resource
San Jacinto, CA,
Luiseno
Indians
Specialist
92581
Soboba Band
F
Joseph Ontiveros,
P.O. Box 487
(951) 663-5279
(951) 654-4198
jontiveros@soboba-nsn.gov
Cahuilla
of Luiseno
Tribal Historic
San Jacinto, CA,
Luiseno
Indians
Preservation Officer
92581
This list is current only as of the date of this document. Distribution of this list does not relieve any person of statutory responsibility as defined in Section
7050.5 of the Health and Safety Code, Section 5097.94 of the Public Resource Section 5097.98 of the Public Resources Code.
This list is only applicable for contacting local Native Americans with regard to cultural resources assessment for the proposed Enderle Center Project,
Orange County.
Page 3 of 3
Appendix B
Air Quality, Energy, and
Greenhouse Gas Report
AIR QUALITY, ENERGY, AND
GREENHOUSE GAS IMPACT REPORT
ENDERLE CENTER PROJECT
CITY OF TUSTIN, CALIFORNIA
LSA
May 2024
AIR QUALITY, ENERGY, AND
GREENHOUSE GAS IMPACT REPORT
ENDERLE CENTER PROJECT
CITY OF TUSTIN, CALIFORNIA
Submitted to:
EPD Solutions, Inc.
3333 Michelson Drive, Suite 500
Irvine, California 92612
Prepared by:
LSA
3210 El Camino Real, Suite 100
Irvine, California 92602
(949) 553-0666
Project No. ESL2201.76
LSA
May 2024
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT ENDERLE CENTER PROJECT C A
MAY 2024 CITY OF TUSTIN, CALIFORNIA J A
TABLE OF CONTENTS
TABLE OF CONTENTS
FIGURES AND TABLES
LIST OF ABBREVIATIONS AND ACRONYMS............................................................................................
iv
INTRODUCTION..........................................................................................................
1
ProjectLocation............................................................................................................................. 1
ProjectDescription........................................................................................................................
1
Existing Land Uses in the Project Area.......................................................................................... 5
BACKGROUND............................................................................................................
6
Air Pollutants and Health Effects..................................................................................................
6
Ozone.................................................................................................................................................
7
CarbonMonoxide...............................................................................................................................7
ParticulateMatter..............................................................................................................................7
NitrogenDioxide.................................................................................................................................7
SulfurDioxide.....................................................................................................................................
7
Lead....................................................................................................................................................
8
Volatile Organic Compounds..............................................................................................................8
ToxicAir Contaminants.......................................................................................................................8
Energy..........................................................................................................................................
12
Electricity..........................................................................................................................................12
NaturalGas.......................................................................................................................................12
Fuel...................................................................................................................................................13
GreenhouseGases.......................................................................................................................
14
CarbonDioxide.................................................................................................................................15
Methane...........................................................................................................................................16
NitrousOxide....................................................................................................................................16
Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride....................................................16
BlackCarbon.....................................................................................................................................16
REGULATORY SETTING..............................................................................................
18
AirQuality Regulations................................................................................................................
18
FederalRegulations..........................................................................................................................18
StateRegulations..............................................................................................................................18
RegionalRegulations........................................................................................................................19
LocalRegulations..............................................................................................................................22
EnergyRegulatory Setting...........................................................................................................
23
FederalRegulations..........................................................................................................................24
StateRegulations..............................................................................................................................24
RegionalRegulations........................................................................................................................
26
LocalRegulations..............................................................................................................................26
Greenhouse Gas Regulatory Setting...........................................................................................
27
FederalRegulations..........................................................................................................................27
StateRegulations..............................................................................................................................27
RegionalRegulations........................................................................................................................34
LocalRegulations..............................................................................................................................35
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project -AQ Report 050124.docx (05/01/24) i
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT ENDERLE CENTER PROJECT L S A
MAY 2024 CITY OF TUSTIN, CALIFORNIA
SETTING.................................................................................................................... 36
AttainmentStatus.......................................................................................................................
36
Existing Climate and Air Quality..................................................................................................
36
Air Quality Monitoring Results....................................................................................................
38
Greenhouse Gas Emissions Inventory.........................................................................................
38
GlobalEmissions...............................................................................................................................38
UnitedStates Emissions...................................................................................................................38
State of California Emissions............................................................................................................40
METHODOLOGY........................................................................................................ 41
Construction Emissions............................................................................................................... 41
Operational Emissions.................................................................................................................41
EnergyUse................................................................................................................................... 42
Greenhouse Gas Analysis............................................................................................................ 42
THRESHOLDS OF SIGNIFICANCE................................................................................. 43
Criteria Pollutant Thresholds....................................................................................................... 43
Localized Impacts Analysis.......................................................................................................... 44
Local Microscale Concentration Standards................................................................................. 45
Greenhouse Gas Threshold......................................................................................................... 45
IMPACTS ANALYSIS................................................................................................... 47
AirQuality Impacts...................................................................................................................... 47
Consistency with Applicable Air Quality Plans.................................................................................47
Criteria Pollutant Analysis................................................................................................................49
Health Risk on Nearby Sensitive Receptors......................................................................................54
Asbestos...........................................................................................................................................
57
Odors................................................................................................................................................
57
EnergyImpacts............................................................................................................................
58
EnergyConsumption........................................................................................................................58
Conflict with Renewable Energy or Energy Efficiency Plans.............................................................61
Greenhouse Gas Impacts............................................................................................................
61
Generation of Greenhouse Gas Emissions.......................................................................................62
Consistency with Greenhouse Gas Emissions Reduction Plans........................................................65
CumulativeImpacts.....................................................................................................................
68
Cumulative Air Quality Impacts........................................................................................................
68
Cumulative Energy Impacts..............................................................................................................70
Cumulative Greenhouse Gas Impacts..............................................................................................71
CONCLUSION............................................................................................................
72
APPENDICES
A: CALEEMOD OUTPUT SHEETS
B: DETAILED ENERGY CALCULATIONS
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project - AQ Report 050124.docx (05/01/24)
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT ENDERLE CENTER PROJECT C A
MAY 2024 CITY OF TUSTIN, CALIFORNIA J A
FIGURES AND TABLES
FIGURES
Figure 1: Regional Project Location........................................................................................................ 2
Figure2: Project Site.............................................................................................................................. 3
TABLES
Table A: Sources and Health Effects of Air Pollutants............................................................................ 9
Table B: Federal and State Ambient Air Quality Standards..................................................................
10
Table C: Global Warming Potential of Greenhouse Gases...................................................................
15
Table D: Senate Bill 375 Regional Greenhouse Gas Emissions Reduction Targets ..............................
30
Table E: Attainment Status of Criteria Pollutants in the South Coast Air Basin ...................................
36
Table F: Ambient Air Quality at the Nearby Monitoring Stations........................................................
39
Table G: Regional Thresholds for Construction and Operational Emissions ........................................
44
Table H: South Coast Air Quality Management District Localized Significance Thresholds.................45
Table I: Tentative Project Construction Schedule................................................................................
50
Table J: Diesel Construction Equipment Utilized by Construction Phase .............................................
51
Table K: Project Construction Emissions..............................................................................................
51
Table L: Project Operational Emissions................................................................................................
53
Table M: Project Localized Construction Emissions (Ibs/day)..............................................................55
Table N: Project Localized Operational Emissions (Ibs/day)................................................................
55
Table O: Energy Consumption Estimates during Construction............................................................
59
Table P: Energy Consumption Estimates during Operation.................................................................
60
Table Q: Greenhouse Gas Emissions(MT/yr).......................................................................................
63
Table R: Cumulative Projects List.........................................................................................................
69
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project -AQ Report 050124.docx (05/01/24) I I
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT
MAY 2024
ENDE RUE CENTER PROJECT L C A
CITY OF TUSTI N, CALIFORNIA J /`�`
LIST OF ABBREVIATIONS AND ACRONYMS
°C
degrees Celsius
of
degrees Fahrenheit
µg/m3
micrograms per cubic meter
AAQS
ambient air quality standards
AB
Assembly Bill
APN
Assessor's Parcel Number
AQMP
Air Quality Management Plan
Basin
South Coast Air Basin
BTU
British thermal units
CAA
Clean Air Act
CAAQS
California Ambient Air Quality Standards
CAFE
Corporate Average Fuel Economy
CalEEMod
California Emissions Estimator Model
CalEPA
California Environmental Protection Agency
CALGreen Code
California Green Building Standards Code
CARB
California Air Resources Board
CAT
Climate Action Team
CBC
California Building Code
CBSC
California Building Standards Commission
CCAA
California Clean Air Act
CCR
California Code of Regulations
CEC
California Energy Commission
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project -AQ Report 050124.docx (05/01/24) Iv
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT
MAY 2024
ENDE RUE CENTER PROJECT L C A
CITY OF TUSTI N, CALIFORNIA J /`�`
CEQA
California Environmental Quality Act
CH4
methane
City
City of Tustin
CO
carbon monoxide
CO2
carbon dioxide
CO2e
carbon dioxide equivalent
County
County of Orange
CPUC
California Public Utilities Commission
DPM
diesel particulate matter
du/ac
dwelling units per acre
EIA
Energy Information Administration
EIR
Environmental Impact Report
EMFAC
California Emissions Factor Model
EO
Executive Order
GHG
greenhouse gas
GPA
General Plan Amendment
GWh
gigawatt-hour
GWP
global warming potential
H2S
hydrogen sulfide
HFCs
hydrofluorocarbons
HOD
Housing Overlay District
IPCC
Intergovernmental Panel on Climate Change
kWh
kilowatt-hour
Ibs/day
pounds per day
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project -AQ Report 050124.docx (05/01/24) v
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT
MAY 2024
ENDE RUE CENTER PROJECT L C A
CITY OF TUSTI N, CALIFORNIA J /`�`
LCFS
Low Carbon Fuel Standard
LST
Local Significance Threshold
mg/m3
milligrams per cubic meter
MMT
million metric tons
MMT CO2e
million metric tons of carbon dioxide equivalent
Mpg
miles per gallon
mph
miles per hour
MPO
Metropolitan Planning Organization
MT
metric tons
MT CO2e metric tons of carbon dioxide equivalent
MT CO2e/yr metric tons of carbon dioxide equivalent per year
MT CO2e/yr/SP metric tons of carbon dioxide equivalent per year per service
population
MW megawatt
N20
nitrous oxide
NAAQS
National Ambient Air Quality Standards
NHTSA
National Highway Traffic Safety Administration
NO
nitric oxide
NO2
nitrogen dioxide
NOx
nitrogen oxides
03
ozone (or smog)
OPR
Governor's Office of Planning and Research
PC COM
Planned Community Commercial
PCCB
Planned Community Commercial/Business
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AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT
MAY 2024
ENDE RUE CENTER PROJECT L C A
CITY OF TUSTI N, CALIFORNIA J /`�`
PFCs
perfluorocarbons
PM
particulate matter
PM2.5
particulate matter less than 2.5 microns in size
PM10
particulate matter less than 10 microns in size
ppb
parts per billion
ppm
parts per million
PRC
Public Resources Code
project
Tustin Enderle Center Project
RCP
Regional Comprehensive Plan
RHNA
Regional Housing Needs Allocation
ROCS
reactive organic compounds
ROGs
reactive organic gases
RPS
Renewables Portfolio Standard
RTIP
Regional Transportation Improvement Program
RTP
Regional Transportation Plan
RTP/SCS
Regional Transportation Plan/Sustainable Communities Strategy
SB
Senate Bill
SCAG
Southern California Association of Governments
SCE
Southern California Edison
SCS
Sustainable Communities Strategy
SF6
sulfur hexafluoride
S02
sulfur dioxide
sox
sulfur oxides
SoCalGas
Southern California Gas Company
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AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT
MAY 2024
ENDE RUE CENTER PROJECT L C A
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sq ft
square foot/feet
sq mi
square mile
SR-55
State Route 55
TAC
toxic air contaminant
UNFCCC
United Nations Framework Convention on Climate Change
USDOT
United States Department of Transportation
USEPA
United States Environmental Protection Agency
VMT
vehicle miles traveled
VOCs
volatile organic compounds
ZC
Zone Change
ZCA
Zoning Code Amendment
ZEV
zero -emission vehicle
ZNE
zero net energy
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AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT ENDERLE CENTER PROJECT C A
MAY 2024 CITY OF TUSTIN, CALIFORNIA J A
INTRODUCTION
This Air Quality, Energy, and Greenhouse Gas (GHG) Impact Report has been prepared to evaluate
the potential air quality, energy, and GHG emissions impacts associated with the Enderle Center
Project (project) in the City of Tustin (City), County of Orange (County), California. This report
follows the guidelines identified by the South Coast Air Quality Management District (SCAQMD) in
its California Environmental Quality Act (CEQA) Air Quality Handbook,' and associated updates. In
keeping with these guidelines, this analysis describes existing air quality, including air quality and
GHG emissions generated from project -related sources, regional air pollution, and global climate
change. In addition, this analysis discusses energy use resulting from implementation of the
proposed project and evaluates whether the proposed project would result in the wasteful,
inefficient, or unnecessary consumption of energy resources or conflict with any applicable plans for
renewable energy and energy efficiency.
PROJECT LOCATION
The 11.8-acre project site consists of Assessor's Parcel Numbers (APNs) 401-251-04, 401-251-06;
401-252-05, 401-252-06, 401-252-08, 401-252-09, 401-252-10; and 401-253-04 and 401-253-03. The
project site is generally bounded on the north by 17th Street; on the east by Enderle Center Drive
and the eastern property line of properties fronting Enderle Center Drive; to the south by
Vandenberg Lane; and to the west by State Route 55 (SR-55), including properties west of Yorba
Street. The project location is shown in Figure 1.
The Enderle Center is currently occupied with 87,136 square feet (sq ft) of commercial business
uses, including 28,750 sq ft of restaurant use, 39,960 sq ft of retail and service use, 18,426 sq ft of
office use, and surface parking lots. The site also includes ornamental landscaping along the
perimeter and throughout the parking areas. See Figure 2.
The project site has a General Plan land use designation of Planned Community Commercial/
Business (PCCB) and a zoning designation of Planned Community Commercial (PC COM). The PCCB
land use designation provides opportunities for a variety of miscellaneous retail, professional office,
and service -oriented business activities. The PC COM zoning is intended to allow diversification of
the relationships of various buildings, structures and open spaces in planned building groups while
ensuring substantial compliance with the district regulations and other provisions of the Planned
Community District zone.
PROJECT DESCRIPTION
The City of Tustin prepared the 2021-2029 Housing Element of the General Plan in accordance with
Government Code Section 65580 et seq. The City is required by State law to periodically update its
Housing Element, a mandatory component of the City's General Plan. The update to the Housing
Element covers the Sixth Cycle planning period from October 15, 2021, to October 15, 2029.
' South Coast Air Quality Management District (SCAQMD). 1993. CEQA Air Quality Handbook. Website:
http://www.agmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/ceqa-air-quality-
handbook-(1993) (accessed January 2024).
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AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT ENDERLE CENTER PROJECT C A
MAY 2024 CITY OF TUSTIN, CALIFORNIA J A
The Housing Element is the City's housing policy and planning document that identifies housing
needs and constraints, and sets forth goals, policies, and programs that address the future housing
needs for all income levels over an eight -year planning period that coincides with a Regional Housing
Needs Allocation (RHNA). During the Housing Element process, the City assessed a number of
properties and areas throughout the community that would be able to accommodate the City's
assigned RHNA. Of the Housing Element inventory sites, Enderle Center (the project site) was
identified as necessary for rezoning under Housing Element Program 1.1f to allow for high density
residential/mixed use development.
Pursuant to Housing Element Program 1.1f, the City is proposing an overlay zone (overlay district)
for the project site. To accommodate this, a General Plan Amendment (GPA) is needed to allow a
Housing Overlay District (residential uses) within Planned Community Commercial/Business land use
designations; a Zoning Code Amendment (ZCA) to establish Housing Overlay Districts (overlay zone)
in conjunction with the Planned Community Commercial Districts (base zone); and a Zone Change
(ZC) that amends the City's zoning map to apply a Housing Overlay District (HOD) to the project site.
The proposed HOD would allow for residential development with a maximum density of 59 dwelling
units per acre (du/ac) over a maximum development area of 7 acres.
The Housing Element identified the Enderle Center as having capacity for 413 housing units. The
anticipated development density was determined through the Housing Element process and is a
conservative estimate based on development trends in nearby communities. The anticipated
development does not rely on the demolition of any existing building, but rather focuses on areas
used for surface parking. No development is proposed as part of this project.
Residential uses are currently not allowed on the project site. Upon approval of the Housing Overlay
Zone, the project site could accommodate 413 units over approximately 7 acres of developable land
within the existing 11.8-acre site. The anticipated development over 7 acres would take place on
underutilized asphalt parking lot areas, and not require demolition of any existing buildings. Parking
displaced as a result of redevelopment would be accommodated by vertical parking structures
located within the proposed development.
In addition, the project site is envisioned to function as a mixed -use site and a portion of the project
site would remain as nonresidential land use. The project site is assumed to be developed with
205,603 sq ft of nonresidential use. As identified above, the Enderle Center is currently developed
with 87,136 sq ft of commercial business uses, including 28,750 sq ft of restaurant use, 39,960 sq ft
of retail and service use, and 18,426 sq ft of office use. Therefore, the total remaining nonresidential
use assumed for future buildout of the project site is an additional 118,467 sq ft, including 39,087
sq ft of restaurant use, 54,328 sq ft of retail and service use, and 25,051 sq ft of office use.
Roadways and utilities may be required to support development of future residential construction
within the project site. However, specific infrastructure improvements required to support
residential development within the Enderle Center are not known at this time and will not be known
until a development project is proposed.
The proposed project does not propose or approve any specific development projects. However, for
the purposes of this analysis, future development of the additional 413 units and remaining
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AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT ENDERLE CENTER PROJECT C A
MAY 2024 CITY OF TUSTIN, CALIFORNIA J A
commercial buildout capacity associated with the proposed project could occur anytime between
October 2024 and October 2029. Construction activities for the residential units would include
demolition of the surface parking lot, site preparation, grading, building construction, paving, and
architectural coatings.
The existing uses generate approximately 7,058 average daily trips (ADT).2 With the buildout of the
proposed housing units and remaining commercial buildout capacity, the proposed project would
generate approximately 18,528 ADT, resulting in 11,470 net new ADT.
The residential units would be constructed in compliance with the version of the California Title 24
Energy Efficiency Standards (Title 24 energy standards) and the Title 24 California Green Building
Standards Code (CALGreen Code) in effect at the time building permit applications are submitted.
EXISTING LAND USES IN THE PROJECT AREA
For the purposes of this analysis, sensitive receptors are areas of population that have an increased
sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include
residences, schools, daycare centers, hospitals, parks, and similar uses which are sensitive to air
quality. Impacts on sensitive receptors are of particular concern because they are the population
most vulnerable to the effects of air pollution. The project site is surrounded to the north by 17th
Street followed by commercial, residential and office uses; to the east by Enderle Center Drive
followed by office uses; to the south by Vandenberg Lane followed by residential uses; and to the
west by Tustin city limits and SR-55 and restaurants and office uses.
The closest sensitive receptors to the project site are residential uses, located approximately 70 feet
south of the project's site boundary.
2 EPD Solutions, Inc. 2024. Enderle Center Trip Generation.
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AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT ENDERLE CENTER PROJECT C A
MAY 2024 CITY OF TUSTIN, CALIFORNIA J A
BACKGROUND
This section provides current background information on air pollutants and their health effects. It
also provides current regulatory background information, including information from the California
Air Resources Board's (CARB) Air Quality and Land Use Handbook (CARB Handbook); a description
of the general health risks of toxics, and the significance criteria for project evaluation. In addition,
this section provides background information on energy usage in the project area and provides
regulatory background information, including federal, State, and local energy regulations.
AIR POLLUTANTS AND HEALTH EFFECTS
Both State and federal governments have established health -based ambient air quality standards
(California Ambient Air Quality Standards [CAAQS] and National Ambient Air Quality Standards
[NAAQS], respectively) for six criteria air pollutants:' carbon monoxide (CO), ozone (03), nitrogen
dioxide (NO2), sulfur dioxide (SOA lead (Pb), and suspended particulate matter (PM). In addition,
the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility -reducing
particles. These standards are designed to protect the health and welfare of the populace with a
reasonable margin of safety. Long-term exposure to elevated levels of criteria pollutants may result
in adverse health effects. However, emission thresholds established by an air district are used to
manage total regional emissions within an air basin based on the air basin's attainment status for
criteria pollutants. These emission thresholds were established for individual projects that would
contribute to regional emissions and pollutant concentrations and could adversely affect or delay
the projected attainment target year for certain criteria pollutants.
Because of the conservative nature of the thresholds and the basin -wide context of individual
project emissions, there is no known direct correlation between a single project and localized air
quality -related health effects. One individual project that generates emissions exceeding a threshold
does not necessarily result in adverse health effects for residents in the project vicinity. This
condition is especially true when the criteria pollutants exceeding thresholds are those with regional
effects, such as ozone precursors like nitrogen oxides (NOx) and volatile organic compounds (VOCs).
Occupants of facilities such as schools, daycare centers, parks and playgrounds, hospitals, and
nursing and convalescent homes are considered to be more sensitive than the general public to air
pollutants because these population groups have increased susceptibility to respiratory disease.
Persons engaged in strenuous outdoor work or exercise also have increased sensitivity to poor air
quality. Residential areas are considered more sensitive to air quality conditions, compared to
commercial and industrial areas, because people generally spend longer periods of time at their
residences, with greater associated exposure to ambient air quality conditions. Recreational uses
California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health
Perspective. April.
Criteria pollutants are defined as those pollutants for which the federal and State governments have
established ambient air quality standards, or criteria, for outdoor concentrations in order to protect public
health.
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are also considered sensitive compared to commercial and industrial uses due to greater exposure
to ambient air quality conditions associated with exercise.
Ozone
Rather than being directly emitted, ozone (03 or smog) is formed by photochemical reactions
between NOx and VOCs. Ozone is a pungent, colorless gas. Elevated ozone concentrations result in
reduced lung function, particularly during vigorous physical activity. This health problem is
particularly acute in sensitive receptors such as the sick, elderly, and young children. Ozone levels
peak during the summer and early fall months.
Carbon Monoxide
Carbon monoxide (CO) is formed by the incomplete combustion of fossil fuels, almost entirely from
automobiles. It is a colorless, odorless gas that can cause dizziness, fatigue, and impairments to
central nervous system functions. CO passes through the lungs into the bloodstream, where it
interferes with the transfer of oxygen to body tissues.
Particulate Matter
Particulate matter (PM) is the term used for a mixture of solid particles and liquid droplets found in
the air. Coarse particles are those that are 10 microns or less in diameter, or PM1o. Fine, suspended
particulate matter with an aerodynamic diameter of 2.5 microns or less, or PM2.5, is not readily
filtered out by the lungs. Nitrates, sulfates, dust, and combustion particulates are major components
of PM10 and PM2.5. These small particles can be directly emitted into the atmosphere as byproducts
of fuel combustion; through abrasion, such as tire or brake lining wear; or through fugitive dust
(wind or mechanical erosion of soil). They can also be formed in the atmosphere through chemical
reactions. Particulates may transport carcinogens and other toxic compounds that adhere to the
particle surfaces and can enter the human body through the lungs.
Nitrogen Dioxide
Nitrogen dioxide (NO2) is a reddish brown gas that is a byproduct of combustion processes.
Automobiles and industrial operations are the main sources of NO2. Aside from its contribution to
ozone formation, NO2 also contributes to other pollution problems, including a high concentration
of fine particulate matter, poor visibility, and acid deposition. NO2 may be visible as a coloring
component on high pollution days, especially in conjunction with high ozone levels. NO2 decreases
lung function and may reduce resistance to infection.
Sulfur Dioxide
Sulfur dioxide (S02) is a colorless, irritating gas formed primarily from incomplete combustion of
fuels containing sulfur. Industrial facilities also contribute to gaseous S02 levels in the region. S02
irritates the respiratory tract, can injure lung tissue when combined with fine particulate matter,
and reduces visibility and the level of sunlight.
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Lead
Leaded gasoline (phased out in the United States beginning in 1973), paint (on older houses and
cars), smelters (metal refineries), and the manufacture of lead storage batteries have been the
primary sources of lead (Pb) released into the atmosphere. Lead has multiple adverse neurotoxic
health effects, and children are at special risk. Some lead -containing chemicals cause cancer in
animals. Lead levels in the air have decreased substantially since leaded gasoline was eliminated.
Ambient lead concentrations are only monitored on an as -warranted, site -specific basis in California.
On October 15, 2008, the United States Environmental Protection Agency (USEPA) strengthened the
NAAQS for lead by lowering it from 1.5 to 0.15 micrograms per cubic meter (µg/m3). The USEPA
revised the monitoring requirements for lead in December 2010. These requirements focus on
airports and large urban areas, resulting in an increase in 76 monitors nationally.
Volatile Organic Compounds
Volatile organic compounds (VOCs) (also known as reactive organic gases [ROGs] and reactive
organic compounds [ROCS]) are formed from the combustion of fuels and the evaporation of organic
solvents. VOCs are not defined as criteria pollutants, however, because VOCs accumulate in the
atmosphere more quickly during the winter, when sunlight is limited and photochemical reactions
are slower, they are a prime component of the photochemical smog reaction. There are no
attainment designations for VOCs.
Toxic Air Contaminants
In addition to the criteria pollutants discussed above, toxic air contaminants (TACs) are another
group of pollutants of concern. TACs are injurious in small quantities and are regulated by the USEPA
and the CARB. Some examples of TACs include benzene, butadiene, formaldehyde, and hydrogen
sulfide. The identification, regulation, and monitoring of TACs is relatively recent compared to that
for criteria pollutants.
TACs do not have ambient air quality standards (AAQS), but are regulated by the USEPA, the CARB,
and the SCAQMD. In 1998, the CARB identified particulate matter from diesel -fueled engines as a
TAC. The CARB has completed a risk management process that identified potential cancer risks for a
range of activities using diesel -fueled engines.' High -volume freeways, stationary diesel engines,
and facilities attracting heavy and constant diesel vehicle traffic (e.g., distribution centers and truck
stops) were identified as posing the highest risk to adjacent receptors. Other facilities associated
with increased risk include warehouse distribution centers, large retail or industrial facilities, high -
volume transit centers, and schools with a high volume of bus traffic. Health risks from TACs are a
function of both concentration and duration of exposure.
Unlike TACs emitted from industrial and other stationary sources noted above, most diesel
particulate matter (DPM) is emitted from mobile sources —primarily "off -road" sources such as
construction and mining equipment, agricultural equipment, and truck -mounted refrigeration units,
as well as "on -road" sources such as trucks and buses traveling on freeways and local roadways.
CARB. 2000. Stationary Source Division and Mobile Source Control Division. Risk Reduction Plan to Reduce
Particulate Matter Emissions from Diesel -Fueled Engines and Vehicles. October.
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Although not specifically monitored, recent studies indicate that exposure to DPM may contribute
significantly to a cancer risk (a risk of approximately 500 to 700 in 1,000,000) that is greater than all
other measured TACs combined.6The technology for reducing DPM emissions from heavy-duty trucks
is well established, and both State and federal agencies are moving aggressively to regulate engines
and emission control systems to reduce and remediate diesel emissions. The CARB anticipated that by
2020, average statewide DPM concentrations will decrease by 85 percent from levels in 2000 with full
implementation of the CARB's Diesel Risk Reduction Plan,' meaning that the statewide health risk
from DPM is expected to decrease from 540 cancer cases in 1,000,000 to 21.5 cancer cases in
1,000,000. The CARB 2000 Diesel Risk Reduction Plan is still the most recent version and has not been
updated.
Table A summarizes the sources and health effects of air pollutants discussed in this section. Table B
presents a summary of CAAQS and NAAQS.
Table A: Sources and Health Effects of Air Pollutants
Pollutants
Sources
Primary Effects
Carbon
9 Incomplete combustion of fuels
9 Reduced tolerance for exercise
Monoxide (CO)
and other carbon -containing
• Impairment of mental function
substances, such as motor exhaust
• Impairment of fetal development
Natural events, such as
* Death at high levels of exposure
decomposition of organic matter
• Aggravation of some heart diseases (angina)
Nitrogen
9 Motor vehicle exhaust
• Aggravation of respiratory illness
Dioxide (NO2)
• High temperature stationary
• Reduced visibility
combustion
* Reduced plant growth
Atmospheric reactions
* Formation of acid rain
Ozone
* Atmospheric reaction of organic
* Aggravation of respiratory and cardiovascular diseases
(03)
gases with nitrogen oxides in
• Irritation of eyes
sunlight
• Impairment of cardiopulmonary function
• Plant leaf injury
Lead
* Contaminated soil
* Impairment of blood functions and nerve construction
(Pb)
• Behavioral and hearing problems in children
Suspended
• Stationary combustion of solid
• Reduced lung function
Particulate
fuels
• Aggravation of the effects of gaseous pollutants
Matter
* Construction activities
* Aggravation of respiratory and cardiorespiratory diseases
(PM2.s and
• Industrial processes
• Increased cough and chest discomfort
PM10)
• Atmospheric chemical reactions
• Soiling
• Reduced visibility
Sulfur Dioxide
• Combustion of sulfur -containing
• Aggravation of respiratory diseases (asthma, emphysema)
(S02)
fossil fuels
• Reduced lung function
Smelting of sulfur -bearing metal
• Irritation of eyes
ores Industrial processes
• Reduced visibility
• Plant injury
• Deterioration of metals, textiles, leather, finishes,
coatings, etc.
Source: California Air Resources Board (2015).
CARB. 2000. Stationary Source Division and Mobile Source Control Division. Risk Reduction Plan to Reduce
Particulate Matter Emissions from Diesel -Fueled Engines and Vehicles. October.
Ibid.
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Table B: Federal and State Ambient Air Quality Standards
Averaging
California Standardsa
Federal Standardsb
Concentration`
Method'
Primary0•e
SeconI
Methodg
Pollutant
Time
0.09 ppm
Ozone
1-Hour
3
(180 µg/m)
Ultraviolet
—
Same as
Ultraviolet
(O3)
Photometry
Primary
Photometry
0.07 ppm
0.070 ppm
8-Hour
(137 µg/m3)
(137 µg/m3)
Standard
Respirable
24-Hour
50 µg/m3
150 µg/m3
Inertial
Particulate
Gravimetric or Beta
Same as
Separation and
Annual
Matter
Arithmetic
20 3
µg/m
Attenuation
_
Primary
Gravimetric
(PM10)'
Mean
Standard
Analysis
Fine
24-Hour
35 µg/m3
Inertial
Particulate
Same as
Separation and
Annual
Matter
Arithmetic
12 µg/m3
Gravimetric or Beta
12.0 3
µg/m
Primary
Gravimetric
(PMz.$)'
Mean
Attenuation
Standard
Analysis
8 Hour
9.0 ppm
9 ppm
(10 mg/m3)
Non -Dispersive
(10 mg/m3)
Non -Dispersive
Carbon
Infrared
_
Infrared
20 ppm
35 ppm
Monoxide
1-Hour
(23 mg/m3)
Photometry
(40 mg/m3)
Photometry
(CO)
(NDIR)
(NDIR)
8-Hour
6 ppm
(Lake Tahoe)
(7m1
Annual
0.03
53 ppbg/m)
Same as
Nitrogen
Arithmetic
[ppm
(57 µ
Gas Phase
(300 µg/m3)
Primary
Gas Phase
Dioxide
Mean
Standard
Chemi-
(NO2)'
Chemi-luminescence
luminescence
0.18 ppm
100 ppb
1-Hour
(339 µg/m3)
(188 µg/m3)
30-Day
1.5 µg/m3
—
—
Average
High -Volume
Calendar
1.5 µg/m3
Lead
Quarter
—
Atomic
(for certain areas)
Same as
Sampler and
(Pb)',-
Absorption
Atomic
Rolling 3-
Primary
Absorption
Month
—
0.15 µg/m3
Standard
Average'
24-Hour
0.04 ppm
0.14 ppm
—
(105pg/m3)
(for certain areas)
Ultraviolet
3-Hour
—
_
0.5 ppm
(1300 µg/m3)
Sulfur
Fluorescence;
Dioxide
Ultraviolet
Spectra-
1-Hour
0.25 ppm
75 ppb
—
(SO2)'
Fluorescence
photometry
(655 µg/m3)
(196 µg/m3)'
(Pararosaniline
Annual
0.030 ppm
Method)
Arithmetic
—
(for certain areas)'
—
Mean
Visibility-
Beta Attenuation
Reducing
8-Hour
See footnote n
and Transmittance
No
Particles'
through Filter Tape.
Federal
Sulfates
24-Hour
25 µg/m3
Ion Chromatography
Hydrogen
0.03 ppm
Ultraviolet
Sulfide
1-Hour
(42 µg/m3)
Fluorescence
Standards
Vinyl Chloride'
24-Hour
0.01 ppm
(26 µg/m3)
Gas Chromatography
Source: California Air Resources Board (2016) (Website: https://www.arb.ca.gov/research/aaqs/aags2.pdf).
Table notes are provided on the following page.
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California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen dioxide, and
particulate matter (PMio, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be
equaled or exceeded. California Ambient Air Quality Standards are listed in the Table of Standards in Section 70200 of Title 17 of the
California Code of Regulations.
b National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more
than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year,
averaged over 3 years, is equal to or less than the standard. For PMio, the 24-hour standard is attained when the expected number of
days per calendar year with a 24-hour average concentration above 150 µg/m3 is equal to or less than one. For PM2.5, the 24-hour
standard is attained when 98 percent of the daily concentrations, averaged over 3 years, are equal to or less than the standard. Contact
USEPA for further clarification and current national policies.
Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference
temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference
temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per
mole of gas.
d Any equivalent measurement method which can be shown to the satisfaction of the CARB to give equivalent results at or near the level
of the air quality standard may be used.
e National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health.
f National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse
effects of a pollutant.
6 Reference method as described by the USEPA. An "equivalent method" of measurement may be used but must have a "consistent
relationship to the reference method" and must be approved by the USEPA.
h On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm.
On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 µg/m3 to 12.0 µg/m3. The existing national
24- hour PM2.5standards (primary and secondary) were retained at 35 µg/m3, as was the annual secondary standard of 15 µg/m3. The
existing 24-hour PM3o standards (primary and secondary) of 150 µg/m3 also were retained. The form of the annual primary and
secondary standards is the annual mean, averaged over 3 years.
To attain the 1-hour national standard, the 3-year average of the annual 981h percentile of the 1-hour daily maximum concentrations at
each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are
in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be
converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm.
k On June 2, 2010, a new 1-hour S02 standard was established, and the existing 24-hour and annual primary standards were revoked. To
attain the 1-hour national standard, the 3-year average of the annual 991h percentile of the 1-hour daily maximum concentrations at
each site must not exceed 75 ppb. The 1971 S02 national standards (24-hour and annual) remain in effect until one year after an area is
designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in
effect until implementation plans to attain or maintain the 2010 standards are approved.
Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm).
To directly compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the
national standard of 75 ppb is identical to 0.075 ppm.
The CARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health
effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations
specified for these pollutants.
The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 µg/m3 as a
quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated
nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008
standard are approved.
n In 1989, the CARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to
instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer" for the statewide and
Lake Tahoe Air Basin standards, respectively.
°C = degrees Celsius
µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
mg/m3 = milligrams per cubic meter
ppb = parts per billion
ppm = parts per million
USEPA = United States Environmental Protection Agency
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ENERGY
Electricity
Electricity is a manmade resource. The production of electricity requires the consumption or
conversion of energy resources (including water, wind, oil, gas, coal, solar, geothermal, and nuclear
resources) into energy. Electricity is used for a variety of purposes (e.g., lighting, heating, cooling,
and refrigeration, and for operating appliances, computers, electronics, machinery, and public
transportation systems).
According to the most recent data available, in 2022, California's electricity was generated
primarily by natural gas (47.5 percent), renewable sources (52.2 percent), large hydroelectric
(7.2 percent), nuclear (8.7 percent), coal (<1.0 percent), and other unspecified sources. Total electric
generation in California in 2022 was 287,220 gigawatt-hours (GWh), up 3.4 percent from the 2021
total generation of 277,764 GWh."
The project site is within the service territory of Southern California Edison (SCE). SCE provides
electricity to more than 15 million people in a 50,000-square-mile (sq mi) area of Central, Coastal,
and Southern California.9 According to the California Energy Commission (CEC), total electricity
consumption in the SCE service area in 2022 was 85,870 GWh (31,604 GWh for the residential sector
and 54,266 GWh for the non-residential sector). Total electricity consumption in Orange County in
2022 was 20,244 GWh (20,243,721,856 kilowatt hours [kWh]), including 7,830 GWh for the
residential sector and 12,414 GWh for the non-residential sector.lo
Natural Gas
Natural gas is a non-renewable fossil fuel. Fossil fuels are formed when layers of decomposing plant
and animal matter are exposed to intense heat and pressure under the surface of the Earth over
millions of years. Natural gas is a combustible mixture of hydrocarbon compounds (primarily
methane) that is used as a fuel source. Natural gas is found in naturally occurring reservoirs in deep
underground rock formations. Natural gas is used for a variety of uses (e.g., heating buildings,
generating electricity, and powering appliances such as stoves, washing machines and dryers, gas
fireplaces, and gas grills).
8 California Energy Commission (CEC). 2021a. 2020 Total System Electric Generation. Website: https://www.
energy.ca.gov/data-reports/energy-almanac/caIifornia-electricity-data/2020-tota I -system -electric -
generation (accessed January 2024).
9 Southern California Edison (SCE). 2020. About Us. Website: https://www.sce.com/about-us/who-we-are
(accessed January 2024).
10 CEC. 2023. Electricity Consumption by County and Entity. Website: http://www.ecdms.energy.ca.gov/
elecbycounty.aspx and http://www.ecdms.energy.ca.gov/elecbyutil.aspx (accessed January 2024).
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Natural gas consumed in California is used for electricity generation (45 percent), residential uses
(21 percent), industrial uses (25 percent), and commercial uses (9 percent). California continues to
depend on out-of-state imports for nearly 90 percent of its natural gas supply."
The Southern California Gas Company (SoCalGas) is the natural gas service provider for the project
site. SoCalGas provides natural gas to approximately 21.8 million people in a 24,000 sq mi service
area throughout Central and Southern California, from Visalia to the Mexican border.12 According to
the CEC, total natural gas consumption in the SoCalGas service area in 2022 was 5,026 million
therms (2,230 million therms for the residential sector). Total natural gas consumption in Orange
County in 2021 was 573 million therms (572,454,744 therms), including 352 million therms for the
residential sector and 221 million therms for the non-residential sector."
Fuel
Petroleum is also a non-renewable fossil fuel. Petroleum is a thick, flammable, yellow -to -black
mixture of gaseous, liquid, and solid hydrocarbons that occurs naturally beneath the earth's surface.
Petroleum is primarily recovered by oil drilling. It is refined into a large number of consumer
products, primarily fuel oil, gasoline, and diesel.
The average fuel economy for light -duty vehicles (autos, pickups, vans, and SUVs) in the United
States has steadily increased from about 14.9 miles per gallon (mpg) in 1980 to 22.9 mpg in 2021.14
Federal fuel economy standards have changed substantially since the Energy Independence and
Security Act was passed in 2007. This act, which originally mandated a national fuel economy
standard of 35 mpg by year 202015, applies to cars and light trucks of Model Years 2011 through
2020. In March 2020, the United States Environmental Protection Agency (USEPA) and National
Highway Traffic Safety Administration (NHTSA) finalized the Corporate Average Fuel Economy (CAFE)
standards for Model Years 2024-2026 Passenger Cars and Light Trucks, further detailed below.
Gasoline is the most used transportation fuel in California, with 97 percent of all gasoline being
consumed by light -duty cars, pickup trucks, and sport utility vehicles. According to the most recent
data available, in 2021, total gasoline consumption in California was 289,918 thousand barrels
11 CEC. 2021b. Supply and Demand of Natural Gas in California. Website: https://www.energy.ca.gov/data-
reports/energy-almanac/californias-natural-gas-market/supply-and-demand-natural-gas-california
(accessed January 2024).
12 Southern California Gas Company (SoCalGas). 2020. About SoCalGas. Website: https://www3.socalgas.
com/about-us/company-profile (accessed January 2024).
11 CEC. 2023. Gas Consumption by County and Entity. Website: http://www.ecdms.energy.ca.gov/gasby
county.aspx and http://www.ecdms.energy.ca.gov/gasbyutil.aspx (accessed January 2024).
14 U.S. Department of Transportation (USDOT). "Table 4-23: Average Fuel Efficiency of U.S. Light Duty
Vehicles." Website: https://www.bts.dot.gov/bts/bts/content/average-fuel-efficiency-us-light-duty-
vehicles (accessed January 2024).
15 U.S. Department of Energy. 2007. "Energy Independence & Security Act of 2007." Website: https://www.
afdc.energy.gov/laws/eisa (accessed January 2024).
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(12.2 billion gallons) or 1,464.7 trillion British Thermal Units (BTU).16 Of the total gasoline
consumption, 273,289 thousand barrels (11.5 billion gallons) or 1,380.7 trillion BTU were consumed
for transportation.17 Based on fuel consumption obtained from CARB's California Emissions Factor
Model, Version 2021 (EMFAC2021), approximately 1.2 billion gallons of gasoline and approximately
157.1 million gallons of diesel will be consumed from vehicle trips in Orange County in 2024..
GREENHOUSE GASES
Global climate change is the observed increase in the average temperature of the Earth's
atmosphere and oceans in recent decades. The Earth's average near -surface atmospheric
temperature rose 0.6 ± 0.2° Celsius (°C) or 1.1 ± 0.4° Fahrenheit (°F) in the 201" century. The
prevailing scientific opinion on climate change is that most of the warming observed over the last
50 years is attributable to human activities. The increased amounts of carbon dioxide (CO2) and
other GHGs are the primary causes of the human -induced component of warming. GHGs are
released by the burning of fossil fuels, land clearing, agriculture, and other activities, and lead to an
increase in the greenhouse effect.18
GHGs are present in the atmosphere naturally, are released by natural sources, or are formed from
secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal
contributors to human -induced global climate change are:
• CO2
• Methane (CH4)
• Nitrous oxide (N20)
• Hydrofluorocarbons (HFCs)
• Perfluorocarbons (PFCs)
• Sulfur hexafluoride (SF6)
Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the
atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere, and
enhancing the natural greenhouse effect, which is believed to be causing global warming. While
manmade GHGs include naturally -occurring GHGs such as CO2, methane, and N20, some gases, like
HFCs, PFCs, and SF6 are completely new to the atmosphere.
Certain gases, such as water vapor, are short-lived in the atmosphere. Others remain in the atmos-
phere for significant periods of time, contributing to climate change in the long term. Water vapor is
16 U.S. Energy Information Administration (EIA). 2022. California State Profile and Energy Estimates, Data.
Website: www.eia.gov/state/seds/data.php?incfile=/state/seds/sep_fuel/html/fuel_mg.html&sid=CA
(accessed January 2024).
17 Ibid.
18 The temperature on Earth is regulated by a system commonly known as the "greenhouse effect." Just as
the glass in a greenhouse lets heat from sunlight in and reduces the heat escaping, greenhouse gases like
carbon dioxide, methane, and nitrous oxide in the atmosphere keep the Earth at a relatively even
temperature. Without the greenhouse effect, the Earth would be a frozen globe; thus, although an excess
of greenhouse gas results in global warming, the naturally occurring greenhouse effect is necessary to
keep our planet at a comfortable temperature.
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excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric
concentrations are largely determined by natural processes, such as oceanic evaporation. For the
purposes of this air quality analysis, the term "GHGs" will refer collectively to the six gases listed
above.
These gases vary considerably in terms of Global Warming Potential (GWP), which is a concept
developed to compare the ability of each GHG to trap heat in the atmosphere relative to another
gas. The global warming potential is based on several factors, including the relative effectiveness of
a gas to absorb infrared radiation and length of time that the gas remains in the atmosphere
("atmospheric lifetime"). The GWP of each gas is measured relative to carbon dioxide, the most
abundant GHG; the definition of GWP for a particular GHG is the ratio of heat trapped by one unit
mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period.
GHG emissions are typically measured in terms of pounds or tons of "CO2 equivalents" (CO2e).
Table C shows the GWP for each type of GHG. For example, SF6 is 23,900 times more potent at
contributing to global warming than CO2.
Table C: Global Warming Potential of Greenhouse Gases
Gas
Atmospheric Lifetime
(Years)
Global Warming Potential
(100-Year Time Horizon)
Carbon Dioxide
50-200
1
Methane
12
25
Nitrous Oxide
114
310
11,700
HFC-23
270
HFC-134a
14
140
HFC-152a
1.4
140
PFC: Tetrafluoromethane (CF4)
50,000
6,500
PFC: Hexafluoromethane (C2F6)
10,000
9,200
Sulfur Hexafluoride (SF6)
3,200
23,900
Source: Second Update to the Climate Change Scoping Plan: Building on the Framework (CARB 2017). Website: www.arb.ca.gov/our-
work/programs/ab-32-climate-change-scoping-plan/2017-scoping-plan-documents (accessed January 2024).
HFC = hydrofluorocarbons
PFC = perfluorocarbons
The following discussion summarizes the characteristics of the six GHGs and black carbon.
Carbon Dioxide
In the atmosphere, carbon generally exists in its oxidized form, as carbon dioxide (CO2). Natural
sources of CO2 include the respiration (breathing) of humans, animals, and plants, volcanic out
gassing, decomposition of organic matter and evaporation from the oceans. Human caused sources of
CO2 include the combustion of fossil fuels and wood, waste incineration, mineral production, and
deforestation. Natural sources release approximately 150 billion tons of CO2 each year, far
outweighing the 7 billion tons of manmade emissions of CO2 each year. Nevertheless, natural removal
processes, such as photosynthesis by land- and ocean -dwelling plant species, cannot keep pace with
this extra input of manmade CO2, and consequently, the gas is building up in the atmosphere.
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In 2021, total annual CO2 accounted for approximately 81.2 percent of California's overall GHG
emissions.19 Transportation is the single largest source of CO2 in California, which is primarily
comprised of on -road travel. Electricity production, industrial and residential sources also make
important contributions to CO2 emissions in California.
Methane
Methane (CH4) is produced when organic matter decomposes in environments lacking sufficient
oxygen. Natural sources include wetlands, termites, and oceans. Decomposition occurring in landfills
accounts for the majority of human -generated CH4 emissions in California and in the United States
as a whole. Agricultural processes such as intestinal fermentation, manure management, and rice
cultivation are also significant sources of CH4 in California. Total annual emissions of CH4 accounted
for approximately 9.8 percent of GHG emissions in California in 2021.20
Nitrous Oxide
Nitrous oxide (N20) is produced naturally by a wide variety of biological sources, particularly
microbial action in soils and water. Tropical soils and oceans account for the majority of natural
source emissions. Nitrous oxide is a product of the reaction that occurs between nitrogen and
oxygen during fuel combustion. Both mobile and stationary combustion emit N20, and the quantity
emitted varies according to the type of fuel, technology, and pollution control device used, as well
as maintenance and operating practices. Agricultural soil management and fossil fuel combustion
are the primary sources of human -generated N20 emissions in California. Nitrous oxide emissions
accounted for approximately 3.4 percent of GHG emissions in California in 2021.21
Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride
HFCs are primarily used as substitutes for ozone -depleting substances regulated under the Montreal
Protoco1.22 PFCs and SF6 are emitted from various industrial processes, including aluminum smelting,
semiconductor manufacturing, electric power transmission and distribution, and magnesium
casting. There is no aluminum or magnesium production in California; however, the rapid growth in
the semiconductor industry leads to greater use of PFCs. HFCs, PFCs, and SF6 accounted for about
5.6 percent of GHG emissions in California in 2021.23
Black Carbon
Black carbon is the most strongly light -absorbing component of PM formed by burning fossil fuels
such as coal, diesel, and biomass. Black carbon is emitted directly into the atmosphere in the form of
PM2.5 and is the most effective form of PM, by mass, at absorbing solar energy. Per unit of mass in
19 CARB. 2022. GHGs Descriptions & Sources in California. Website: ww2.arb.ca.gov/ghg-descriptions-
sources (accessed January 2024).
20 Ibid.
21 Ibid.
22 The Montreal Protocol is an international treaty that was approved on January 1, 1989, and was
designated to protect the ozone layer by phasing out the production of several groups of halogenated
hydrocarbons believed to be responsible for ozone depletion.
23 CARB. 2022. op. cit.
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the atmosphere, black carbon can absorb one million times more energy than CO2.24 Black carbon
contributes to climate change both directly, such as absorbing sunlight, and indirectly, such as
affecting cloud formation. However, because black carbon is short-lived in the atmosphere, it can be
difficult to quantify its effect on global warming.
Most U.S. emissions of black carbon come from mobile sources (52 percent), particularly from diesel -
fueled vehicles. The other major source of black carbon is open biomass burning, including wildfires,
although residential heating and industry also contribute. The CARB estimates that the annual black
carbon emissions in California will be reduced approximately 50 percent below 2013 levels by 2030.21
24 U.S. Environmental Protection Agency (USEPA). 2015. Black Carbon, Basic Information. February 14, 2017.
Website: 19january2017snapshot.epa.gov/www3/airquality/blackcarbon/basic.html (accessed January
2024).
25 CARB. 2017b. Short -Lived Climate Pollutant Reduction Strategy. March. Website: https://ww2.arb.ca.gov/
sites/default/files/2020-07/final_SLCP_strategy.pdf (accessed January 2024).
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REGULATORY SETTING
AIR QUALITY REGULATIONS
The USEPA and the CARB regulate direct emissions from motor vehicles. The SCAQMD is the
regional agency primarily responsible for regulating air pollution emissions from stationary sources
(e.g., factories) and indirect sources (e.g., traffic associated with new development), as well as
monitoring ambient pollutant concentrations.
Federal Regulations
Federal Clean Air Act
The 1970 federal Clean Air Act (CAA) authorized the establishment of national health -based air
quality standards and also set deadlines for their attainment. The Federal Clean Air Act
Amendments of 1990 changed deadlines for attaining national standards as well as the remedial
actions required of areas of the nation that exceed the standards. Under the Clean Air Act, State and
local agencies in areas that exceed the national standards are required to develop State
Implementation Plans to demonstrate how they will achieve the national standards by specified
dates.
State Regulations
California Clean Air Act
In 1988, the California Clean Air Act (CCAA) required that all air districts in the State endeavor to
achieve and maintain CAAQS for CO, 03, S02, and NO2 by the earliest practical date. The California
Clean Air Act provides districts with authority to regulate indirect sources and mandates that air
quality districts focus particular attention on reducing emissions from transportation and area -wide
emission sources. Each nonattainment district is required to adopt a plan to achieve a 5 percent
annual reduction, averaged over consecutive 3-year periods, in district -wide emissions of each
nonattainment pollutant or its precursors. A Clean Air Plan shows how a district would reduce
emissions to achieve air quality standards. Generally, the State standards for these pollutants are
more stringent than the national standards.
California Air Resources Board
The CARB is the State's "clean air agency." The CARB's goals are to attain and maintain healthy air
quality, protect the public from exposure to toxic air contaminants, and oversee compliance with air
pollution rules and regulations.
Assembly Bill 2588 Air Toxics "Hot Spots" Information and Assessment Act. Under Assembly Bill
(AB) 2588, stationary sources of air pollutants are required to report the types and quantities of
certain substances their facilities routinely released into the air. The goals of the Air Toxics "Hot
Spots" Act are to collect emission data, identify facilities having localized impacts, determine health
risks, and notify nearby residents of significant risks.
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The California Air Resources Board Handbook. The CARB has developed an Air Quality and Land Use
Handbook 21which is intended to serve as a general reference guide for evaluating and reducing air
pollution impacts associated with new projects that go through the land use decision -making
process. According to the CARB Handbook, air pollution studies have shown an association between
respiratory and other non -cancer health effects and proximity to high traffic roadways. Other
studies have shown that diesel exhaust and other cancer -causing chemicals emitted from cars and
trucks are responsible for much of the overall cancer risk from airborne toxics in California. The
CARB Handbook recommends that county and city planning agencies strongly consider proximity to
these sources when finding new locations for "sensitive" land uses such as homes, medical facilities,
daycare centers, schools, and playgrounds.
Land uses that can produce air pollution sources of concern include freeways, rail yards, ports,
refineries, distribution centers, chrome plating facilities, dry cleaners, and large gasoline service
stations. Key recommendations in the CARB Handbook include taking steps to avoid siting new,
sensitive land uses:
• Within 500 feet of a freeway, urban roads with 100,000 vehicles/day or rural roads with 50,000
vehicles/day;
• Within 1,000 feet of a major service and maintenance rail yard;
• Immediately downwind of ports (in the most heavily impacted zones) and petroleum refineries;
• Within 300 feet of any dry cleaning operation (for operations with two or more machines,
provide 500 feet); and
• Within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million
gallons per year or greater).
The CARB Handbook specifically states that its recommendations are advisory and acknowledges
land use agencies have to balance other considerations, including housing and transportation needs,
economic development priorities, and other quality of life issues.
The recommendations are generalized and do not consider site -specific meteorology, freeway truck
percentages, or other factors that influence risk for a particular project site. The purpose of this
guidance is to help land use agencies determine when to further examine project sites for actual
health risk associated with the location of new sensitive land uses.
Regional Regulations
South Coast Air Quality Management District
The SCAQMD has jurisdiction over most air quality matters in the South Coast Air Basin (Basin). This
area includes all of Orange County, Los Angeles County except for the Antelope Valley, the non -
desert portion of western San Bernardino County, and the western and Coachella Valley portions of
26 CARB. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April.
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Riverside County. The SCAQMD is the agency principally responsible for comprehensive air pollution
control in the Basin and is tasked with implementing certain programs and regulations required by
the CAA and the CCAA. The SCAQMD prepares plans to attain CAAQS and NAAQS. SCAQMD is
directly responsible for reducing emissions from stationary (area and point) sources. The SCAQMD
develops rules and regulations, establishes permitting requirements, inspects emissions sources,
and enforces such measures though educational programs or fines, when necessary.
The proposed project could be subject to the following SCAQMD rules and regulations:27
Regulation IV - Prohibitions: This regulation sets forth the restrictions for visible emissions, odor
nuisance, fugitive dust, various air pollutant emissions, fuel contaminants, start-up/shutdown
exemptions, and breakdown events.
Rule 402 - Nuisance: This rule restricts the discharge of any contaminant in quantities that
cause or have a natural ability to cause injury, damage, nuisance, or annoyance to
businesses, property, or the public.
o Rule 403 - Fugitive Dust: This rule requires the prevention, reduction, or mitigation of
fugitive dust emissions from a project site. Rule 403 restricts visible fugitive dust to a project
property line, restricts the net PM10 emissions to less than 50 µg/m3 and restricts the
tracking out of bulk materials onto public roads. Additionally, Rule 403 requires an applicant
to utilize one or more of the best available control measures (identified in the tables within
the rule). Control measures may include adding freeboard to haul vehicles, covering loose
material on haul vehicles, watering, using chemical stabilizers, and/or ceasing all activities.
Finally, Rule 403 requires that a contingency plan be prepared if so determined by the
USEPA. In addition, SCAQMD Rule 403(e), Additional Requirements for Large Operations,
includes requirements to provide Large Operation Notification Form 403 N, appropriate
signage, additional dust control measures, and employment of a dust control supervisor that
has successfully completed the Dust Control training class in the South Coast Air Basin.
• Regulation XI - Source Specific Standards: Regulation XI sets emissions standards for different
sources.
Rule 1113 - Architectural Coatings: This rule limits the amount of VOCs from architectural
coatings and solvents, which lowers the emissions of odorous compounds.
The SCAQMD is responsible for demonstrating regional compliance with AAQS but has limited
indirect involvement in reducing emissions from fugitive, mobile, and natural sources. To that end,
the SCAQMD works cooperatively with the CARE, the Southern California Association of
Governments (SCAG), county transportation commissions, local governments, and other federal and
State government agencies. It has responded to this requirement by preparing a series of Air Quality
Management Plans (AQMPs) to meet CAAQS and NAAQS. SCAQMD and the SCAG are responsible
for formulating and implementing the AQMP for the Basin. The main purpose of an AQMP is to bring
27 SCAQMD. 2024. South Coast AQMD Rule Book. Website: https://www.agmd.gov/home/rules-compliance/
rules (accessed January 2024).
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the area into compliance with federal and State air quality standards. Every 3 years, SCAQMD
prepares a new AQMP, updating the previous plan and 20-year horizon.28
The Final 2022 Air Quality Management Plan is the currently adopted AQMP. Key elements of the
Final 2022 AQMP include the following:
• Calculating and taking credit for co -benefits from other planning efforts (e.g., climate, energy,
and transportation)
• A strategy with fair -share emission reductions at the federal, State, and local levels
• Investment in strategies and technologies meeting multiple air quality objectives
• Seeking new partnerships and significant funding for incentives to accelerate deployment of
zero -emission and near -zero emission technologies
• Enhanced socioeconomic assessment, including an expanded environmental justice analysis
• Attainment of the 24-hour PM2.5 standard in 2019 with no additional measures
• Attainment of the annual PM2.5 standard by 2025 with implementation of a portion of the 03
strategy
• Attainment of the 1-hour 03 standard by 2022 with no reliance on "black box' future technology
(CAA Section 182(e)(5) measures)
The 2022 AQMP builds upon measures already in place from previous AQMPs. It also includes a
variety of additional strategies such as regulation, accelerated deployment of available cleaner
technologies (e.g., zero emissions technologies, when cost-effective and feasible, and low NOx
technologies in other applications), best management practices, co -benefits from existing programs
(e.g., climate and energy efficiency), incentives, and other CAA measures to achieve the 2015 8-hour
ozone standard.
Southern California Association of Governments
SCAG is a council of governments for Los Angeles, Orange, Riverside, San Bernardino, Imperial, and
Ventura Counties. It is a regional planning agency and serves as a forum for regional issues relating
to transportation, the economy and community development, and the environment. SCAG is the
federally designated Metropolitan Planning Organization (MPO) for the majority of the southern
California region and is the largest MPO in the nation. With regard to air quality planning, SCAG
prepares the Regional Transportation Plan (RTP) and Regional Transportation Improvement Program
(RTIP), which address regional development and growth forecasts and form the basis for the land
use and transportation control portions of the AQMP and are utilized in the preparation of the air
28 SCAQMD. 2022. Final 2022 Air Quality Management Plan. December 2.
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quality forecasts and consistency analysis included in the AQMP. The RTP, RTIP, and AQMP are
based on projections originating within local jurisdictions.
Although SCAG is not an air quality management agency, it is responsible for developing
transportation, land use, and energy conservation measures that affect air quality. SCAG's Regional
Comprehensive Plan (RCP) provides growth forecasts that are used in the development of air
quality -related land use and transportation control strategies by the SCAQMD. The RCP is a
framework for decision -making for local governments, assisting them in meeting federal and State
mandates for growth management, mobility, and environmental standards, while maintaining
consistency with regional goals regarding growth and changes. Policies within the RCP include
consideration of air quality, land use, transportation, and economic relationships by all levels of
government.
SCAG adopted the Connect SoCal: The 2024-2050 Regional Transportation Plan/Sustainable
Communities Strategy (Connect SoCal 2024)29 on April 4, 2024. Connect SoCal 2024 is a long-range
visioning plan that balances future mobility and housing needs with economic, environmental, and
public health goals. Connect SoCal is an important planning document for the region, allowing
project sponsors to qualify for federal funding and takes into account operations and maintenance
costs, to ensure reliability, longevity, and cost effectiveness. The forecasted development pattern,
when integrated with the financially constrained transportation investments identified in Connect
SoCal 2024, would reach the GHG emissions reduction target set by CARB, including the regional
target of reducing GHG emissions from autos and light -duty trucks by 19 percent by 2035 (compared
to 2005 levels).
Local Regulations
City of Tustin General Plan
The City of Tustin addresses air quality in the Conservation, Open Space, and Recreation Element of
the City of Tustin General Plan.30 The Conservation, Open Space, and Recreation Element contains
policies that work to improve air quality and reduce particulate emissions. The following policies are
applicable to the proposed project:
• Policy 1.1: Cooperate with the South Coast Air Quality Management District and the Southern
California Association of Governments in their effort to implement provisions of the region's Air
Quality Management Plan, as amended.
• Policy 1.2: Design safe and efficient vehicular access to commercial land uses from arterial
streets to insure efficient vehicular ingress and egress.
29 Southern California Association of Governments (SCAG). 2024. Connect SoCal: The 2024-2050 Regional
Transportation Plan/Sustainable Communities Strategy of the Southern California Association of
Governments. Website: https://scag.ca.gov/sites/main/files/file-attachments/23-2987-connect-socal-
2024-final-complete-040424.pdf?1712261565 (accessed April 2024).
30 City of Tustin. 2017. City of Tustin General Plan. July.
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• Policy 1.3: Locate multiple family developments close to commercial areas to encourage
pedestrian rather than vehicular travel.
• Policy 1.7: Create the maximum possible opportunities for bicycles as an alternative
transportation mode and recreational use.
• Policy 2.1: Reduce vehicle trips through incentives, regulations and/or Transportation Demand
Management (TDM) programs.
• Policy 2.2: Reduce total vehicle miles traveled (VMT) through incentives, regulations and/or
Transportation Demand Management.
• Policy 2.6: Encourage non -motorized transportation through the provision of bicycle and
pedestrian pathways.
• Policy 2.7: Encourage employer rideshare and transit incentives programs by local businesses.
• Policy 2.8: Manage non-residential parking supply to discourage auto use, while ensuring that
economic development goals will not be sacrificed.
ENERGY REGULATORY SETTING
Federal and State agencies regulate energy use and consumption through various means and
programs. On the federal level, the U.S. Department of Transportation (USDOT), the United States
Department of Energy, and the USEPA are three federal agencies with substantial influence over
energy policies and programs. Generally, federal agencies influence and regulate transportation
energy consumption through establishment and enforcement of fuel economy standards for
automobiles and light trucks, through funding of energy -related research and development projects,
and through funding for transportation infrastructure improvements. On the State level, the
California Public Utilities Commission (CPUC) and the California Energy Commission (CEC) are two
agencies with authority over different aspects of energy.
The CPUC regulates privately owned electric, natural gas, telecommunications, water, railroad, rail
transit, and passenger transportation companies and serves the public interest by protecting
consumers and ensuring the provision of safe, reliable utility service and infrastructure at
reasonable rates, with a commitment to environmental enhancement and a healthy California
economy.
The CEC is the State's primary energy policy and planning agency. The CEC forecasts future energy
needs, promotes energy efficiency, supports energy research, develops renewable energy resources,
and plans for/directs state response to energy emergencies. The applicable federal, State, regional,
and local regulatory framework is discussed below.
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Federal Regulations
Energy Policy Act of 2005
The Energy Policy Act of 2005 seeks to reduce reliance on non-renewable energy resources and
provide incentives to reduce current demand on these resources. For example, under this Act,
consumers and businesses can obtain federal tax credits for purchasing fuel -efficient appliances and
products (including hybrid vehicles), building energy -efficient buildings, and improving the energy
efficiency of commercial buildings. Additionally, tax credits are available for the installation of
qualified fuel cells, stationary microturbine power plants, and solar power equipment.
Corporate Average Fuel Economy (CAFE) Standards
On March 31, 2022, the National Highway Traffic Safety Administration (NHTSA) finalized the
Corporate Average Fuel Economy (CAFE) standards for Model Years 2024-2026 Passenger Cars and
Light Trucks. The amended CAFE standards would require an industry wide fleet average of
approximately 49 mpg for passenger cars and light trucks in model year 2026, by increasing fuel
efficiency by 8 percent annually for model years 2024-2025, and 10 percent annually for model year
2026. The final standards are estimated to save about 234 billion gallons of gas between model
years 2030 to 2050.
State Regulations
Assembly Bill 1575, Warren-Alquist Act
In 1975, largely in response to the oil crisis of the 1970s, the State Legislature adopted Assembly Bill
(AB) 1575 (also known as the Warren-Alquist Act), which created the CEC. The statutory mission of
the CEC is to forecast future energy needs; license power plants of 50 megawatts (MW) or larger;
develop energy technologies and renewable energy resources; plan for and direct State responses
to energy emergencies; and, perhaps most importantly, promote energy efficiency through the
adoption and enforcement of appliance and building energy efficiency standards. AB 1575 also
amended Public Resources Code (PRC) Section 21100(b)(3) and State CEQA Guidelines Section
15126.4 to require Environmental Impact Reports (EIRs) to include, where relevant, mitigation
measures proposed to minimize the wasteful, inefficient, and unnecessary consumption of energy
caused by a project. Thereafter, the State Resources Agency created Appendix F to the State CEQA
Guidelines. Appendix F assists EIR preparers in determining whether a project will result in the
inefficient, wasteful, and unnecessary consumption of energy. Appendix F of the State CEQA
Guidelines also states that the goal of conserving energy implies the wise and efficient use of energy
and the means of achieving this goal, including (1) decreasing overall per capita energy
consumption; (2) decreasing reliance on fossil fuels such as coal, natural gas, and oil; and (3)
increasing reliance on renewable energy sources.
Senate Bill 1389, Energy: Planning and Forecasting
In 2002, the State Legislature passed Senate Bill (SB) 1389, which required the CEC to develop an
integrated energy plan every 2 years for electricity, natural gas, and transportation fuels for the
California Energy Policy Report. The plan calls for the State to assist in the transformation of the
transportation system to improve air quality, reduce congestion, and increase the efficient use of
fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies
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a number of strategies, including assistance to public agencies and fleet operators in implementing
incentive programs for zero emission vehicles (ZEVs) and their infrastructure needs, and
encouragement of urban designs that reduce vehicle miles traveled (VMT) and accommodate
pedestrian and bicycle access.
In compliance with the requirements of SB 1389, the CEC adopts an Integrated Energy Policy Report
every 2 years and an update every other year. The most recently adopted report includes the 2023
Integrated Energy Policy Report.31The Integrated Energy Policy Report covers a broad range of
topics, including decarbonizing buildings, integrating renewables, energy efficiency, energy equity,
integrating renewable energy, updates on Southern California electricity reliability, climate
adaptation activities for the energy sector, natural gas assessment, transportation energy demand
forecast, and the California Energy Demand Forecast. The Integrated Energy Policy Report provides
the results of the CEC's assessments of a variety of energy issues facing California. Many of these
issues will require action if the State is to meet its climate, energy, air quality, and other
environmental goals while maintaining energy reliability and controlling costs.
Renewable Portfolio Standard
SB 1078 established the California Renewable Portfolio Standards program in 2002. SB 1078 initially
required that 20 percent of electricity retail sales be served by renewable resources by 2017;
however, this standard has become more stringent over time. In 2006, SB 107 accelerated the
standard by requiring that the 20 percent mandate be met by 2010. In April 2011, SB 2 required that
33 percent of electricity retail sales be served by renewable resources by 2020. In 2015, SB 350
established tiered increases to the Renewable Portfolio Standards of 40 percent by 2024, 45 percent
by 2027, and 50 percent by 2030. In 2018, SB 100 increased the requirement to 60 percent by 2030
and required that all the State's electricity come from carbon -free resources by 2045. SB 100 took
effect on January 1, 2019.31
Title 24, California Building Code
Energy consumption by new buildings in California is regulated by the Building Energy Efficiency
Standards, embodied in Title 24 of the California Code of Regulations (CCR), known as the California
Building Code (CBC). The CEC first adopted the Building Energy Efficiency Standards for Residential
and Non-residential Buildings in 1978 in response to a legislative mandate to reduce energy
consumption in the State. The CBC is updated every 3 years, with the most recent update consisting
of the 2022 CBC that became effective January 1, 2023. The efficiency standards apply to both new
construction and rehabilitation of both residential and non-residential buildings, and regulate
energy consumed for heating, cooling, ventilation, water heating, and lighting. The building
efficiency standards are enforced through the local building permit process. Local government
agencies may adopt and enforce energy standards for new buildings, provided these standards meet
or exceed those provided in CCR Title 24.
31 CEC. 2023. 2023 Integrated Energy Policy Report. California Energy Commission. Docket Number:
23-IEPR-01.
32 California Public Utilities Commission (CPUC). 2019. Renewables Portfolio Standard Program. Website:
cpuc.ca.gov/rps (accessed January 2024).
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California Green Building Standards Code (CALGreen Code)
In 2010, the California Building Standards Commission (CBSC) adopted Part 11 of the Title 24
Building Energy Efficiency Standards, referred to as the California Green Building Standards Code
(CALGreen Code). The CALGreen Code took effect on January 1, 2011. The CALGreen Code is
updated on a regular basis, with the most recent update consisting of the 2022 CALGreen Code
standards that became effective January 1, 2023. The CALGreen Code established mandatory
measures for residential and non-residential building construction and encouraged sustainable
construction practices in the following five categories: (1) planning and design, (2) energy efficiency,
(3) water efficiency and conservation, (4) material conservation and resource efficiency, and
(5) indoor environmental quality. Although the CALGreen Code was adopted as part of the State's
efforts to reduce greenhouse gas (GHG) emissions, the CALGreen Code standards have co -benefits
of reducing energy consumption from residential and non-residential buildings subject to the
standard.
California Energy Efficiency Strategic Plan
On September 18, 2008, the CPUC adopted California's first Long -Term Energy Efficiency Strategic
Plan, presenting a roadmap for energy efficiency in California. The Plan articulates a long-term vision
and goals for each economic sector and identifies specific near -term, mid-term, and long-term
strategies to assist in achieving those goals. The Plan also reiterates the following four specific
programmatic goals known as the "Big Bold Energy Efficiency Strategies" that were established by
the CPUC in Decisions D.07-10-032 and D.07-12-051:
• All new residential construction will be zero net energy (ZNE) by 2020.
• All new commercial construction will be ZNE by 2030.
• 50 percent of commercial buildings will be retrofitted to ZNE by 2030.
• 50 percent of new major renovations of State buildings will be ZNE by 2025.
Regional Regulations
There are no regional regulations that apply to the proposed project.
Local Regulations
City of Tustin General Plan
The City of Tustin addresses energy in the Conservation, Open Space, and Recreation Element of the
City of Tustin General Plan.33 The Conservation, Open Space, and Recreation Element contains
policies that work to reduce energy consumption. The following policies are applicable to the
proposed project:
• Policy 4.1: Promote energy conservation in all sectors of the City including residential,
commercial, and industrial.
33 City of Tustin. 2017. op. cit.
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• Policy 4.2: Promote local recycling of wastes and the use of recycled materials.
GREENHOUSE GAS REGULATORY SETTING
This section describes regulations related to GHGs at the federal, State, and local level.
Federal Regulations
The United States has historically had a voluntary approach to reducing GHG emissions. However,
on April 2, 2007, the United States Supreme Court ruled that the USEPA has the authority to
regulate CO2 emissions under the CAA. While there currently are no adopted federal regulations for
the control or reduction of GHG emissions, the USEPA commenced several actions in 2009 to
implement a regulatory approach to global climate change.
This includes the 2009 USEPA final rule for mandatory reporting of GHGs from large GHG emission
sources in the United States. Additionally, the USEPA Administrator signed an endangerment finding
action in 2009 under the Clean Air Act, finding that six GHGs (CO2, CH4, N20, HFCs, PFCs, SF6)
constitute a threat to public health and welfare, and that the combined emissions from motor
vehicles cause and contribute to global climate change, leading to national GHG emission standards.
In October 2012, the USEPA and the NHTSA, on behalf of the U.S. Department of Transportation,
issued final rules to further reduce GHG emissions and improve CAFE standards for light -duty
vehicles for model years 2017 and beyond (77 Federal Register 62624). The NHTSA's CAFE standards
have been enacted under the Energy Policy and Conservation Act since 1978. This national program
requires automobile manufacturers to build a single light -duty national fleet that meets all
requirements under both federal programs and the standards of California and other states. This
program would increase fuel economy to the equivalent of 54.5 miles per gallon (mpg), limiting
vehicle emissions to 163 grams of CO2 per mile for the fleet of cars and light -duty trucks by model
year 2025 (77 Federal Register 62630).
On March 31, 2022, the NHTSA finalized the CAFE standards for Model Years 2024-2026 Passenger
Cars and Light Trucks. The amended CAFE standards would require an industry wide fleet average of
approximately 49 mpg for passenger cars and light trucks in model year 2026, by increasing fuel
efficiency by 8 percent annually for model years 2024-2025, and 10 percent annually for model year
2026. The final standards are estimated to save about 234 billion gallons of gas between model
years 2030 to 2050.
State Regulations
The CARB is the lead agency for implementing climate change regulations in the State. Since its
formation, the CARB has worked with the public, the business sector, and local governments to find
solutions to California's air pollution problems. Key efforts by the State are described below.
Assembly Bill 1493 (2002)
In a response to the transportation sector's significant contribution to California's CO2 emissions,
AB 1493 was enacted on July 22, 2002. AB 1493 requires the CARB to set GHG emission standards
for passenger vehicles and light duty trucks (and other vehicles whose primary use is noncommercial
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personal transportation in the State) manufactured in 2009 and all subsequent model years. These
standards (starting in model years 2009 to 2016) were approved by the CARB in 2004, but the
needed waiver of CCAA Preemption was not granted by the USEPA until June 30, 2009. The CARB
responded by amending its original regulation, now referred to as Low Emission Vehicle III, to take
effect for model years starting in 2017 to 2025. The Trump administration revoked California's
waiver in 2019; however, the Biden administration restored California's waiver in 2021.
Executive Order S-3-05 (2005)
Governor Arnold Schwarzenegger signed Executive Order (EO) S-3-05 on June 1, 2005, which
proclaimed that California is vulnerable to the impacts of climate change. To combat those
concerns, the executive order established California's GHG emissions reduction targets, which
established the following goals:
• GHG emissions should be reduced to 2000 levels by 2010;
• GHG emissions should be reduced to 1990 levels by 2020; and
• GHG emissions should be reduced to 80 percent below 1990 levels by 2050.
The Secretary of the California Environmental Protection Agency (CaIEPA) is required to coordinate
efforts of various State agencies in order to collectively and efficiently reduce GHGs. A biannual
progress report must be submitted to the Governor and State Legislature disclosing the progress
made toward GHG emission reduction targets. In addition, another biannual report must be
submitted illustrating the impacts of global warming on California's water supply, public health,
agriculture, the coastline, and forestry, and report possible mitigation and adaptation plans to
address these impacts.
The Secretary of CaIEPA leads this Climate Action Team (CAT) made up of representatives from State
agencies as well as numerous other boards and departments. The CAT members work to coordinate
statewide efforts to implement global warming emission reduction programs and the State's
Climate Adaptation Strategy. The CAT is also responsible for reporting on the progress made toward
meeting the statewide GHG targets that were established in the executive order and further defined
under AB 32, the "Global Warming Solutions Act of 2006." The first CAT Report to the Governor and
the Legislature was released in March 2006, which it laid out 46 specific emission reduction
strategies for reducing GHG emissions and reaching the targets established in the executive order.
The most recent report was released in December 2020.
Assembly Bill 32 (2006), California Global Warming Solutions Act
California's major initiative for reducing GHG emissions is AB 32, passed by the State legislature on
August 31, 2006. This effort aims at reducing GHG emissions to 1990 levels by 2020. The CARB has
established the level of GHG emissions in 1990 at 427 million metric tons (MMT) of CO2e. The
emissions target of 427 MMT requires the reduction of 169 MMT from the State's projected
business -as -usual 2020 emissions of 596 MMT. AB 32 requires the CARB to prepare a Scoping Plan
that outlines the main State strategies for meeting the 2020 deadline and to reduce GHGs that
contribute to global climate change. The Scoping Plan was approved by the CARB on December 11,
2008, and contains the main strategies California will implement to achieve the reduction of
approximately 169 MMT CO2e, or approximately 30 percent, from the State's projected 2020
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emissions level of 596 MMT CO2e under a business -as -usual scenario (this is a reduction of 42 MMT
CO2e, or almost 10 percent from 2002-2004 average emissions). The Scoping Plan also includes
CARB-recommended GHG reductions for each emissions sector of the State's GHG inventory. The
Scoping Plan calls for the largest reductions in GHG emissions to be achieved by implementing the
following measures and standards:
• Improved emissions standards for light -duty vehicles (estimated reductions of 31.7 MMT CO2e);
• The Low -Carbon Fuel Standard (15.0 MMT CO2e);
• Energy efficiency measures in buildings and appliances and the widespread development of
combined heat and power systems (26.3 MMT CO2e); and
• A renewable portfolio standard for electricity production (21.3 MMT CO2e).
The CARB approved the First Update to the Climate Change Scoping Plan on May 22, 2014. The First
Update identifies opportunities to leverage existing and new funds to further drive GHG emission
reductions through strategic planning and targeted low carbon investments. The First Update
defines CARB climate change priorities until 2020, and also sets the groundwork to reach long-term
goals set forth in EOs S-3-05 and B-16-2012. The Update highlights California's progress toward
meeting the "near -term" 2020 GHG emission reduction goals as defined in the initial Scoping Plan. It
also evaluates how to align the State's "longer -term" GHG reduction strategies with other State
policy priorities for water, waste, natural resources, clean energy, transportation, and land use.
CARB released a second update to the Scoping Plan, the 2017 Scoping Plan,34 to reflect the 2030
target set by EO B-30-15 and codified by SB 32.
Most recently, the 2022 Scoping Plan31 was approved in December 2022 and assesses progress
towards achieving the SB 32 2030 target and lay out a path to achieve carbon neutrality no later
than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by
assessing paths for clean technology, energy deployment, natural and working lands, and others,
and is designed to meet the State's long-term climate objectives and support a range of economic,
environmental, energy security, environmental justice, and public health priorities.
Senate Bill 97 (2007)
SB 97, signed by the Governor in August 2007 (Chapter 185, Statutes of 2007; Public Resources Code
[PRC], Sections 21083.05 and 21097), acknowledges climate change is a prominent environmental
issue that requires analysis under CEQA. This bill directed the Governor's Office of Planning and
Research (OPR) to prepare, develop, and transmit to the California Resources Agency guidelines for
mitigating GHG emissions or the effects of GHG emissions, as required by CEQA.
The California Natural Resources Agency adopted the amendments to the State CEQA Guidelines in
November 2018, which went into effect in December 2018. The amendments do not identify a
34 CARB. 2017a. California's 2017 Climate Change Scoping Plan. November.
35 CARB. 2021. 2022 Scoping Plan Update. May 10. Website: https://ww2.arb.ca.gov/sites/default/files/
2022-12/2022-sp.pdf (accessed January 2024).
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threshold of significance for GHG emissions, nor do they prescribe assessment methodologies or
specific mitigation measures. The amendments encourage lead agencies to consider many factors in
performing a CEQA analysis, but preserve the discretion granted by CEQA to lead agencies in making
their own determinations based on substantial evidence. The amendments also encourage public
agencies to make use of programmatic mitigation plans and programs when they perform individual
project analyses.
Senate Bill 375 (2008)
SB 375, the Sustainable Communities and Climate Protection Act, which establishes mechanisms for
the development of regional targets for reducing passenger vehicle GHG emissions, was adopted by
the State on September 30, 2008. On September 23, 2010, the CARB adopted the vehicular GHG
emissions reduction targets that had been developed in consultation with the Metropolitan Planning
Organization (MPOs); the targets require a 6 to 15 percent reduction by 2020 and between 13 to
19 percent reduction by 2035 for each MPO. SB 375 recognizes the importance of achieving
significant GHG reductions by working with cities and counties to change land use patterns and
improve transportation alternatives. Through the SB 375 process, MPOs such as the Fresno Council
of Governments will work with local jurisdictions in the development of Sustainable Communities
Strategy (SCS) designed to integrate development patterns and the transportation network in a way
that reduces GHG emissions while meeting housing needs and other regional planning objectives.
Pursuant to SB 375, the Los Angeles/Southern California reduction targets for per capita vehicular
emissions were 8 percent by 2020 and are 19 percent by 2035 as shown in Table D.
Table D: Senate Bill 375 Regional Greenhouse Gas Emissions
Reduction Targets
Metropolitan Planning Organization
By 2020 (percent)
By 2035 (percent)
San Francisco Bay Area
10
19
San Diego
15
19
Sacramento
7
19
Central Valley/San Joaquin
6-13
13-16
Los Angeles/Southern California
8
19
Source: California Air Resources Board (2018).
Executive Order B-30-15 (2015)
Governor Jerry Brown signed EO B-30-15 on April 29, 2015, which added the immediate target of:
• GHG emissions should be reduced to 40 percent below 1990 levels by 2030.
All State agencies with jurisdiction over sources of GHG emissions were directed to implement
measures to achieve reductions of GHG emissions to meet the 2030 and 2050 targets. CARB was
directed to update the AB 32 Scoping Plan to reflect the 2030 target, and therefore, is moving
forward with the update process. The mid-term target is critical to help frame the suite of policy
measures, regulations, planning efforts, and investments in clean technologies and infrastructure
needed to continue reducing emissions.
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Senate Bill 350 (2015) Clean Energy and Pollution Reduction Act
SB 350, signed by Governor Jerry Brown on October 7, 2015, updates and enhances AB 32 by
introducing the following set of objectives in clean energy, clean air, and pollution reduction for
2030:
• Raise California's renewable portfolio standard from 33 percent to 50 percent; and
• Increasing energy efficiency in buildings by 50 percent by the year 2030.
The 50 percent renewable energy standard will be implemented by the CPUC for the private utilities
and by the CEC for municipal utilities. Each utility must submit a procurement plan showing it will
purchase clean energy to displace other non-renewable resources. The 50 percent increase in
energy efficiency in buildings must be achieved through the use of existing energy efficiency retrofit
funding and regulatory tools already available to state energy agencies under existing law. The
addition made by this legislation requires State energy agencies to plan for and implement those
programs in a manner that achieves the energy efficiency target.
Senate Bill 32, California Global Warming Solutions Act of 2016, and Assembly Bill 197
In summer 2016 the Legislature passed, and the Governor signed, SB 32, and AB 197. SB 32 affirms
the importance of addressing climate change by codifying into statute the GHG emissions reductions
target of at least 40 percent below 1990 levels by 2030 contained in Governor Brown's April 2015
EO B-30-15. SB 32 builds on AB 32 and keeps us on the path toward achieving the State's 2050
objective of reducing emissions to 80 percent below 1990 levels, consistent with an
Intergovernmental Panel on Climate Change (IPCC) analysis of the emissions trajectory that would
stabilize atmospheric GHG concentrations at 450 parts per million CO2e and reduce the likelihood of
catastrophic impacts from climate change.
The companion bill to SB 32, AB 197, provides additional direction to CARB related to the adoption
of strategies to reduce GHG emissions. Additional direction in AB 197 meant to provide easier public
access to air emissions data that are collected by CARB was posted in December 2016.
Senate Bill 100
On September 10, 2018, Governor Brown signed SB 100, which raises California's Renewables
Portfolio Standard (RPS) requirements to 60 percent by 2030, with interim targets, and 100 percent
by 2045. The bill also establishes a State policy that eligible renewable energy resources and zero -
carbon resources supply 100 percent of all retail sales of electricity to California end -use customers
and 100 percent of electricity procured to serve all State agencies by December 31, 2045. Under the
bill, the State cannot increase carbon emissions elsewhere in the western grid or allow resource
shuffling to achieve the 100 percent carbon -free electricity target.
Executive Order B-55-18
EO B-55-18, signed September 10, 2018, sets a goal "to achieve carbon neutrality as soon as
possible, and no later than 2045, and achieve and maintain net negative emissions thereafter."
EO B-55-18 directs CARB to work with relevant State agencies to ensure future Scoping Plans
identify and recommend measures to achieve the carbon neutrality goal. The goal of carbon
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neutrality by 2045 is in addition to other statewide goals, meaning not only should emissions be
reduced to 80 percent below 1990 levels by 2050, but that, by no later than 2045, the remaining
emissions be offset by equivalent net removals of CO2e from the atmosphere, including through
sequestration in forests, soils, and other natural landscapes.
Assembly Bill 1279
AB 1279 was signed in September of 2022, and codifies the State goals of achieving net carbon
neutrality by 2045 and maintaining net negative GHG emissions thereafter. This bill also requires
California to reduce statewide GHG emissions by 85 percent compared to 1990 levels by 2045 and
directs CARB to work with relevant state agencies to achieve these goals.
Title 24, Part 11, Building Standards Code and CALGreen Code
In November 2008, the California Building Standards Commission established the California Green
Building Standards Code (CALGreen Code), which sets performance standards for residential and
non-residential development to reduce environmental impacts and encourage sustainable
construction practices. The CALGreen Code addresses energy efficiency, water conservation,
material conservation, planning and design, and overall environmental quality. The CALGreen Code
is updated every 3 years and was most recently updated in 2022 to include new mandatory
measures for residential as well as non-residential uses; the new measures took effect on January 1,
2023.
California Building Efficiency Standards (Title 24, Part 6)
The California Building Standards Code, or Title 24 of the California Code of Regulations (CCR)
contains the regulations that govern the construction of buildings in California. Within the Building
Standards Code, two parts pertain to the incorporation of both energy efficient and green building
elements into land use development. Part 6 is California's Energy Efficiency Standards for Residential
and Non -Residential Buildings. These standards were first adopted in 1978 in response to a
legislative mandate to reduce California's energy consumption and are updated on an
approximately 3-year cycle to allow consideration and possible incorporation of new energy efficient
technologies and methods. The current set of standards was adopted in 2022 and applies to projects
seeking building permits on or after January 1, 2023. Energy efficient buildings require less
electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases
GHG emissions.
Cap and Trade
The development of a cap -and -trade program was included as a key reduction measure of the CARB
AB 32 Climate Change Scoping Plan. The cap -and -trade program will help put California on the path
to meet its goal of reducing GHG emissions to 1990 levels by 2020 and ultimately achieving an
80 percent reduction from 1990 levels by 2050. The cap -and -trade emissions trading program
developed by the CARB took effect on January 1, 2012, with enforceable compliance obligations
beginning January 1, 2013. The cap -and -trade program aims to regulate GHG emissions from the
largest producers in the State by setting a statewide firm limit, or cap, on allowable annual GHG
emissions. The cap was set in 2013 at approximately 2 percent below the emissions forecast for
2020. In 2014, the cap declined approximately 2 percent. Beginning in 2015 and continuing through
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2020, the cap has been declining approximately 3 percent annually. The CARB administered the first
auction on November 14, 2012, with many of the qualified bidders representing corporations or
organizations that produce large amounts of GHG emissions, including energy companies,
agriculture and food industries, steel mills, cement companies, and universities. On January 1, 2015,
compliance obligation began for distributors of transportation fuels, natural gas, and other fuels.
The cap -and -trade program was initially slated to sunset in 2020 but the passage of SB 398 in 2017
extended the program through 2030.
Executive Order N-79-20
EO N-79-20, which was signed by the Governor on September 23, 2020, sets the following goals for
the State: 100 percent of in -state sales of new passenger cars and trucks shall be zero -emission by
2035; 100 percent of medium- and heavy-duty vehicles in the State shall be zero -emission by 2045
for all operations where feasible and by 2035 for drayage trucks; and 100 percent of off -road
vehicles and equipment in the State shall be zero -emission by 2035, where feasible.
Low Carbon Fuel Standard
In January 2007, EO S-01-07 established a Low Carbon Fuel Standard (LCFS). This executive order
calls for a statewide goal to be established to reduce the carbon intensity of California's
transportation fuels by at least 10 percent by 2020, and that an LCFS for transportation fuels be
established for California. The LCFS applies to all refiners, blenders, producers, or importers
("Providers") of transportation fuels in California, including fuels used by off -road construction
equipment. In June 2007, CARB adopted the LCFS under AB 32 pursuant to Health and Safety Code
Section 38560.5, and, in April 2009, CARB approved the new rules and carbon intensity reference
values with new regulatory requirements taking effect in January 2011. The standards require
providers of transportation fuels to report on the mix of fuels they provide and demonstrate they
meet the LCFS intensity standards annually. This is accomplished by ensuring that the number of
"credits" earned by providing fuels with a lower carbon intensity than the established baseline (or
obtained from another party) is equal to or greater than the "deficits" earned from selling higher
intensity fuels. In response to certain court rulings, CARB re -adopted the LCFS regulation in
September 2015, and the LCFS went into effect on January 1, 2016. In 2018, CARB approved
amendments to the regulation to readjust carbon intensity benchmarks to meet California's 2030
GHG reductions targets under SIB 32. These amendments include opportunities to promote zero
emission vehicle (ZEV) adoption, carbon capture and sequestration, and advanced technologies for
decarbonization of the transportation sector.
Advanced Clean Cars Program
In January 2012, CARB approved the Advanced Clean Cars program, which combines the control of
GHG emissions and criteria air pollutants, as well as requirements for greater numbers of ZEVs, into
a single package of regulatory standards for vehicle model years 2017 through 2025. The new
regulations strengthen the GHG standard for 2017 models and beyond. This will be achieved
through existing technologies, the use of stronger and lighter materials, and more efficient
drivetrains and engines. The program's ZEVs regulation requires battery, fuel cell, and/or plug-in
hybrid electric vehicles to account for up to 15 percent of California's new vehicle sales by 2025. The
program also includes a clean fuels outlet regulation designed to support the commercialization of
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zero -emission hydrogen fuel cell vehicles planned by vehicle manufacturers by 2015 by requiring
increased numbers of hydrogen fueling stations throughout the State. The number of stations will
grow as vehicle manufacturers sell more fuel cell vehicles. By 2025, when the rules will be fully
implemented, the statewide fleet of new cars and light trucks will emit 40 percent fewer GHGs and
75 percent fewer smog -forming emissions than 2012 model year vehicles.
Executive Order 8-48-18
In January 2018, Governor Brown signed EO B-48-18 requiring all State entities to work with the
private sector to have at least 5 million ZEVs on the road by 2030, as well as install 200 hydrogen
fueling stations and 250,000 electric vehicle charging stations by 2025. It specifies that 10,000 of the
EV charging stations should be direct current fast chargers. This order also requires all State entities
to continue to partner with local and regional governments to streamline the installation of ZEV
infrastructure. The Governor's Office of Business and Economic Development is required to publish
a Plug-in Charging Station Design Guidebook and update the 2015 Hydrogen Station Permitting
Guidebook to aid in these efforts. All State entities are required to participate in updating the 2016
Zero -Emissions Vehicle Action Plan to help expand private investment in ZEV infrastructure with a
focus on serving low-income and disadvantaged communities. Additionally, all State entities are to
support and recommend policies and actions to expand ZEV infrastructure at residential land uses,
through the LCFS program, and recommend how to ensure affordability and accessibility for all
drivers.
Regional Regulations
South Coast Air Quality Management District
In 2008, the SCAQMD formed a Working Group to identify GHG emissions thresholds for land use
projects that could be used by local lead agencies in the Basin. The Working Group developed
several different options that are contained in the SCAQMD 2008 draft guidance document titled,
Interim CEQA GHG Significance Threshold for Stationary Sources, Rules, and Plans," that could be
applied by lead agencies. On September 28, 2010, SCAQMD Working Group Meeting No. 15
provided further guidance, including a tiered approach for evaluating GHG emissions for
development projects where the SCAQMD is not the lead agency. The SCAQMD has not presented a
finalized version of these thresholds to the governing board.
The SCAQMD identifies the emissions level for which a project would not be expected to
substantially conflict with any State legislation adopted to reduce statewide GHG emissions. As such,
the utilization of a service population represents the rates of emissions needed to achieve a fair
share of the State's mandated emissions reductions. Overall, the SCAQMD identifies a GHG
efficiency level that, when applied statewide or to a defined geographic area, would meet the year
2020 and post-2020 emissions targets as required by AB 32 and SB 32. If projects are able to achieve
targeted rates of emissions per the service population, the State will be able to accommodate
expected population growth and achieve economic development objectives, while also abiding by
AB 32's emissions target and future post-2020 targets.
36 SCAQMD. 2008b. Interim CEQA GHG Significance Threshold for Stationary Sources, Rules, and Plans.
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Southern California Association of Governments
On April 4, 2024, SCAG adopted Connect SoCal 2024.37 In general, the SCS outlines a development
pattern for the region, which, when integrated with the transportation network and other
transportation measures and policies, would reduce vehicle miles traveled (VMT) from automobiles
and light -duty trucks and thereby reduce GHG emissions from these sources. For the SCAG region,
CARB has set GHG reduction targets at 8 percent below 2005 per capita emissions levels by 2020,
and 19 percent below 2005 per capita emissions levels by 2035. The 2024-2050 RTP/SCS lays out a
strategy for the region to meet these targets. Overall, the SCS is meant to provide growth strategies
that will achieve the regional GHG emissions reduction targets. Land use strategies to achieve the
region's targets include planning for new growth around high -quality transit areas and livable
corridors, and creating neighborhood mobility areas to integrate land use and transportation and
plan for more active lifestyles.38 However, the SCS does not require that local General Plans, Specific
Plans, or zoning be consistent with the SCS; SCAG is required to consider local land use controls
when drafting the SCS.
The horizon year for Connect SoCal 2024 is 2050 and the plan projects that by 2050, 66 percent of
new households and 54 percent of new jobs will be located in Priority Development Areas, either
near transit or in walkable communities. The objectives of Connect SoCal 2024 are to create a region
with: transit as a backbone of the transportation system; more Complete Streets where people and
safety are prioritized; policies that encourage emerging technologies and mobility innovations that
support rather than hamper regional goals; more housing, jobs, and mobility options closer together
in Priority Development Areas to preserve natural lands and open spaces; more housing to address
the existing housing need as defined by the RHNA; safe and fluid movement of goods, with a
commitment to the broad deployment of zero- and near -zero emission technologies.
Local Regulations
City of Tustin
The City of Tustin has not prepared a Climate Action Plan. The air quality and energy policies from
the City of Tustin General Plan, identified above, would also work to reduce GHG emissions.
37 SCAG. 2024. op. cit.
38 Ibid.
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SETTING
This section provides the current SCAQMD attainment status, climate and air quality, ambient air
quality monitoring results, and GHG emissions inventory.
ATTAINMENT STATUS
The CARB is required to designate areas of the state as attainment, nonattainment, or unclassified
for all State standards. An attainment designation for an area signifies that pollutant concentrations
did not violate the standard for that pollutant in that area. A nonattainment designation indicates
that a pollutant concentration violated the standard at least once, excluding those occasions when a
violation was caused by an exceptional event, as defined in the criteria. An unclassified designation
signifies that data do not support either an attainment or nonattainment status. The CCAA divides
districts into moderate, serious, and severe air pollution categories, with increasingly stringent
control requirements mandated for each category.
The USEPA designates areas for 03, CO, and NO2 as either does not meet the primary standards, or
cannot be classified, or better than national standards. For S02, areas are designated as does not
meet the primary standards, does not meet the secondary standards, cannot be classified, or better
than national standards.
Table E provides a summary of the attainment status for the Basin with respect to NAAQS and
CAAQS.
Table E: Attainment Status of Criteria Pollutants in the South Coast Air Basin
Pollutant
State
Federal
03 1 hour
Nonattainment
Extreme Nonattainment
03 8 hour
Nonattainment
Extreme Nonattainment
PM10
Nonattainment
Attainment/Maintenance
PM2.5
Nonattainment
Serious Nonattainment
CO
Attainment
Attainment/Maintenance
NO2
Attainment
Attainment/Maintenance
S02
N/A
Attainment/Unclassified
Lead
Attainment
Attainment'
All others
Attainment/Unclassified
Attainment/Unclassified
Source: South Coast Air Quality Management District (2018).
' Except in Los Angeles County.
CO = carbon monoxide PM,. = particulate matter less than 10 microns in size
N/A = not applicable PM2.5 = particulate matter less than 2.5 microns in size
NO2 = nitrogen dioxide S02 = sulfur dioxide
0, = ozone
EXISTING CLIMATE AND AIR QUALITY
Air quality in the planning area is not only affected by various emission sources (e.g., mobile and
industry), but also by atmospheric conditions (e.g., wind speed, wind direction, temperature, and
rainfall). The combination of topography, low mixing height, abundant sunshine, and emissions from
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the second-largest urban area in the United States gives the Basin some of the worst air pollution in
the nation.
The annual average temperature varies little throughout the Basin, ranging from the low to middle
60s°F. With a more pronounced oceanic influence, coastal areas show less variability in annual
minimum and maximum temperatures than inland areas. The climatological station closest to the
site is the Tustin Irvine Ranch Station.39 The monthly average maximum temperature recorded at
this station ranged from 66.8°F in January to 85.2°F in August, with an annual average maximum of
75.4°F. The monthly average minimum temperature recorded at this station ranged from 40.2°F in
January to 59.1°F in August, with an annual average minimum of 49.4°F. These levels are
representative of the project area.
The majority of annual rainfall in the Basin occurs between November and March. Summer rainfall is
minimal and is generally limited to scattered thundershowers in coastal regions and slightly heavier
showers in the eastern portion of the Basin and along the coastal side of the mountains. Average
monthly rainfall at the Tustin Irvine Ranch Station varied from 0.01 inch in July to 2.67 inches in
February, with an annual total of 12.86 inches. Patterns in monthly and yearly rainfall totals are
unpredictable due to fluctuations in the weather.
The Basin experiences a persistent temperature inversion (increasing temperature with increasing
altitude) as a result of the Pacific high. This inversion limits the vertical dispersion of air
contaminants, holding them relatively near the ground. As the sun warms the ground and the lower
air layer, the temperature of the lower air layer approaches the temperature of the base of the
inversion (upper) layer until the inversion layer finally breaks, allowing vertical mixing with the lower
layer. This phenomenon is observed in mid -afternoon to late afternoon on hot summer days when
the air appears to clear up suddenly. Winter inversions frequently break by midmorning.
Winds in the project area blow predominantly from the south-southwest, with relatively low
velocities. Wind speeds in the project area average about 5 miles per hour (mph). Summer wind
speeds average slightly higher than winter wind speeds. Low average wind speeds, together with a
persistent temperature inversion, limit the vertical dispersion of air pollutants throughout the Basin.
Strong, dry, north, or northeasterly winds, known as Santa Ana winds, occur during the fall and winter
months, dispersing air contaminants. The Santa Ana conditions tend to last for several days at a time.
The combination of stagnant wind conditions and low inversions produces the greatest pollutant
concentrations. On days of no inversion or high wind speeds, ambient air pollutant concentrations
are the lowest. During periods of low inversions and low wind speeds, air pollutants generated in
urbanized areas are transported predominantly on shore into Riverside and San Bernardino
Counties. In the winter, the greatest pollution problems are CO and NOx because of extremely low
inversions and air stagnation during the night and early morning hours. In the summer, the longer
daylight hours and brighter sunshine combine to cause a reaction between hydrocarbons and NOx
to form photochemical smog. Smog is a general term that is naturally occurring fog that has become
mixed with smoke or pollution. In this context it is better described as a form of air pollution
39 Western Regional Climate Center. Recent Climate in the West. Website: http://www.wrcc.dri.edu,
(accessed January 2024).
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produced by the photochemical reaction of sunlight with pollutants that have been released into the
atmosphere, especially by automotive emissions.
AIR QUALITY MONITORING RESULTS
Air quality monitoring stations are located throughout the nation and are maintained by the local air
pollution control district and State air quality regulating agencies. The SCAQMD, together with the
CARB, maintains ambient air quality monitoring stations in the Basin. The air quality monitoring
stations closest to the project site is located at 1630 Pampas Lane in Anaheim.
Pollutant monitoring results for years 2020 to 2022 at the Anaheim ambient air quality monitoring
stations, shown in Table F, indicate that air quality in the area has generally been moderate. As
indicated in the monitoring results, the federal PM10 standard was not exceeded during the 3-year
period. The State PM10 standard was exceeded 5 times in 2020, once in 2021, and once in 2022.
Similarly, the federal PM2.5 standard had 12 exceedances in 2020, 10 exceedances in 2021, and no
exceedances in 2022. The State 1-hour ozone standards were exceeded 6 times in 2021, no times in
2021, and once in 2022. The State 8-hour ozone standards were exceeded 16 times in 2020, no
times in 2021, and once in 2022. The federal 8-hour standards were exceeded 15 times in 2021, no
times in 2021, and once in 2022. The CO and NO2 standards were not exceeded in this area during
the 3-year period. S02 data were not available from 2020 to 022 at air quality monitoring stations in
Orange County.
GREENHOUSE GAS EMISSIONS INVENTORY
An emissions inventory that identifies and quantifies the primary human -generated sources and
sinks of GHGs is a well -recognized and useful tool for addressing climate change. This section
summarizes the latest information on global, United States, and California GHG emission
inventories.
Global Emissions
Worldwide emissions of GHGs in 2020 totaled 22.9 billion metric tons (MT) of CO2e. Global
estimates are based on country inventories developed as part of the programs of the United Nations
Framework Convention on Climate Change.40
United States Emissions
In 2021, the year for which the most recent data are available, the United States emitted about
5,586.0 million metric tons of CO2e (MMT CO2e) after accounting for sequestration from the land
sector. Overall, emissions in 2021 increased by 6 percent since and were 17 percent lower than 2005
levels. The increase in total GHG emissions was driven by an increase in CO2 emissions from fossil
fuel combustion.
40 United Nations Framework Convention on Climate Change (UNFCCC). 2021. GHG Data from UNFCCC.
Website: unfccc.int/process-and-meetings/transparency-and-reporting/greenhouse-gas-data/ghg-data-
unfccc/ghg-data-from-unfccc (accessed January 2024).
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Table F: Ambient Air Quality at the Nearby Monitoring Stations
Pollutant Standard 2020 1 2021 1 2022
Carbon Monoxide (CO)
Maximum 1-hour concentration (ppm)
2.3
2.1
2.4
Number of days exceeded:
State: > 20 ppm
0
0
0
Federal: > 35 ppm
0
0
0
Maximum 8-hour concentration (ppm)
1.7
1.5
1.4
Number of days exceeded:
State: > 9 ppm
0
0
0
Federal: > 9 ppm
0
0
0
Ozone (03)
Maximum 1-hour concentration (ppm)
0.142
0.089
0.102
Number of days exceeded:
State: > 0.09 ppm
6
0
1
Maximum 8-hour concentration (ppm)
0.098
0.068
0.077
Number of days exceeded:
State: > 0.07 ppm
16
0
1
Federal: > 0.07 ppm
15
0
1
Coarse Particulates (PMIo)
Maximum 24-hour concentration (µg/m3)
74.8
63.6
67.0
Number of days exceeded:
State: > 50 µg/m3
5
1
1
Federal: > 150 µg/m3
0
0
0
Annual arithmetic average concentration (µg/m3)
30.8
23.4
20.9
Exceeded for the year:
State: > 20 µg/m3
Yes
Yes
Yes
Federal: > 50 µg/m3
No
No
No
Fine Particulates (PM2.5)
Maximum 24-hour concentration (µg/m3)
64.8
54.4
33.1
Number of days exceeded:
Federal: > 35 µg/m3
12
10
0
Annual arithmetic average concentration (µg/m3)
12.4
11.6
9.9
Exceeded for the year:
State: > 12 µg/m3
Yes
No
No
Federal: > 15 µg/m3
No
No
No
Nitrogen Dioxide (NO2)
Maximum 1-hour concentration (ppm)
0.071
0.067
0.053
Number of days exceeded:
State: > 0.250 ppm
0
0
0
Annual arithmetic average concentration (ppm)
0.013
0.012
0.012
Exceeded for the year: Federal: > 0.053 ppm
No
No
No
Sulfur Dioxide (S02)
Maximum 1-hour concentration (ppm)
ND
ND
ND
Number of days exceeded:
State: > 0.25 ppm
ND
ND
ND
Maximum 24-hour concentration (ppm)
ND
ND
ND
Number of days exceeded:
State: > 0.04 ppm
ND
ND
ND
Federal: > 0.14 ppm
ND
ND
ND
Annual arithmetic average concentration (ppm)
ND
ND
ND
Exceeded for the year: Federal: > 0.030 ppm
ND
ND
ND
Sources: CARB (2023) and USEPA (2023).
µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
ND = No data. There were insufficient (or no) data to determine the value.
ppm = parts per million
USEPA = United States Environmental Protection Agency
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In 2021, CO2 emissions from fossil fuel combustion increased by 7 percent relative to the previous
year. This increase in fossil fuel consumption emissions was due primarily to economic activity
rebounding after the height of the COVID-19 pandemic. Of the five major sectors —residential and
commercial, agricultural, industry, transportation, and electricity generation —transportation
accounted for the highest amount of GHG emissions in 2021 (approximately 28 percent), with
electricity generation second at 25 percent and emissions from industry third at 23 percent.41
State of California Emissions
The State emitted approximately 381.3 MMT CO2e emissions in 2021, 12.1 MMT CO2e higher than
2020 levels and 49.7 MMT CO2e below the 2020 GHG limit of 431 MMT CO2e.42 CARB estimates that
transportation was the source of approximately 38 percent of the State's GHG emissions in 2021.
The next largest sources included industrial sources at approximately 19 percent and electricity
generation at 16 percent. The remaining sources of GHG emissions were commercial and residential
activities at 10 percent, agriculture at 8 percent, high GWP at 6 percent, and waste at 2 percent.43
41 USEPA. 2023. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2021. Website: https://www.
epa.gov/system/files/documents/2023-04/US-GHG-Inventory-2023-Main-Text.pdf (accessed January
2024).
42 CARB. 2023. California Greenhouse Gas Emissions for 2000 to 2021, Trends of Emissions and Other
Indicators Report. Website: https:Hww2.arb.ca.gov/sites/default/files/2023-12/2000_2021_ghg_
inventory_trends.pdf (accessed January 2024).
43 Ibid.
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AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT ENDERLE CENTER PROJECT C A
MAY 2024 CITY OF TUSTIN, CALIFORNIA J A
METHODOLOGY
The methodology used to estimate air quality, energy use, and GHG impacts is described below.
CONSTRUCTION EMISSIONS
Construction activities can generate a substantial amount of air pollution. Construction activities are
considered temporary; however, short-term impacts can contribute to exceedances of air quality
standards. Construction activities include demolition, site preparation, earthmoving, and general
construction. The emissions generated from these common construction activities include fugitive
dust from soil disturbance, fuel combustion from mobile heavy-duty diesel and gasoline powered
equipment, portable auxiliary equipment, and worker commute trips.
The California Emissions Estimator Model version 2022.1 (CaIEEMod) computer program was used
to calculate emissions from on -site construction equipment and emissions from worker and vehicle
trips to the site. Information regarding a specific development project is not yet known; however,
for the purposes of this analysis, future development of the additional 413 units and remaining
commercial buildout capacity associated with the proposed project could occur anytime between
October 2024 and October 2029. Therefore, to be conservative, this analysis assumes a project
construction schedule based on a start date of October 2024 and a default construction duration in
CaIEEMod and assuming architectural coating would overlap with building construction activities.
The proposed project would demolish the existing surface parking, but would not demolish any
existing buildings. This analysis also assumes that the proposed project would comply with SCAQMD
Rule 403 measures. In addition, this analysis assumes the use of Tier 2 construction equipment,
which was also included in CaIEEMod. All other construction details are not yet known; therefore,
default assumptions (e.g., construction worker and truck trips and fleet activities) from CaIEEMod
were used.
OPERATIONAL EMISSIONS
The air quality analysis includes estimating emissions associated with long-term operation of the
proposed project. Consistent with the SCAQMD guidance for estimating emissions associated with
land use development projects, the CaIEEMod computer program was used to calculate the long-
term operational emissions associated with the project.
This analysis evaluates the buildout of 413 units and remaining commercial buildout capacity within
the project site and compares the potential impacts to impacts associated with the existing
commercial uses as determined based on two CaIEEMod runs.
As identified in the Project Description, the existing uses that were modeled consists of the Enderle
Center that is currently developed with 87,136 sq ft of commercial business uses, including 28,750
sq ft of restaurant use, 39,960 sq ft of retail and service use, and 18,426 sq ft of office use. The
analysis was conducted using land use codes High Turnover (Sit Down Restaurant), Strip Mall,
General Office Building, and Parking Lot. Trip generation rates used in CaIEEMod for the existing
uses were based on the trip generation rate of 7,058 ADT.
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The analysis of the future buildout of the project site included the existing development, the
buildout of 413 units, and the addition of the total remaining nonresidential use including a total of
67,837 sq ft of restaurant use, 94,288 sq ft of retail and service use, and 43,477 sq ft of office use.
The analysis was conducted using land use codes Apartments Mid Rise, High Turnover (Sit Down
Restaurant), Strip Mall, and General Office Building assuming a total trip generation of 18,528 ADT.
This analysis also assumes that the proposed project would not include any woodburning hearths or
wood stoves. Where project -specific data were not available, default assumptions (e.g., energy
usage, water usage, and solid waste generation) from CalEEMod were used to estimate project
emissions.
ENERGY USE
The analysis of electricity/natural gas usage is based on the CalEEMod modeling conducted by LSA,
which quantifies energy use for project operations. Fuel consumption (diesel fuel and gasoline) from
vehicle trips during operation was conservatively estimated for the year 2024 of the proposed
project based on trip estimates from the CalEEMod model and fuel efficiencies from the CARB
EMission FACtor Model (EMFAC2021) model. Estimates of fuel consumption (diesel fuel and
gasoline) from construction trucks and construction worker vehicles were based on trip estimates
from the CalEEMod model and fuel efficiencies from the CARB EMFAC2021 model.
The analysis focuses on the three sources of energy that are relevant to the proposed project:
electricity, the equipment fuel necessary for project construction, and vehicle fuel necessary for
project operations. For the purposes of this analysis, the amount of electricity, construction fuel,
and fuel use from operations are quantified and compared to that consumed in Orange County. The
electricity use of the proposed project is analyzed as a whole on an annual basis. Electricity use was
estimated for the project using default energy intensities by land use type in CalEEMod.
GREENHOUSE GAS ANALYSIS
Recognizing that the field of global climate change analysis is rapidly evolving, the approaches
advocated most recently indicate that for determining a project's contribution to GHG emissions,
lead agencies should calculate, or estimate, emissions from vehicular traffic, energy consumption,
water conveyance and treatment, waste generation, construction activities, and any other
significant source of emissions within the project area. The CalEEMod results were used to quantify
GHG emissions generated by the project.
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ENDE RUE CENTER PROJECT L C A
CITY OF TUSTI N, CALIFORNIA J /`�`
THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines indicate that a project would normally have a significant adverse air
quality impact if project -generated pollutant emissions would:
• Conflict with or obstruct implementation of the applicable air quality plan;
• Result in a cumulatively considerable net increase of any criteria pollutant for which the project
is nonattainment under applicable federal or State ambient air quality standards;
• Expose sensitive receptors to substantial pollutant concentrations; or
• Result in other emissions (such as those leading to odors) affecting a substantial number of
people.
The State CEQA Guidelines indicate that a project would normally have a significant adverse energy
impact if the project would:
• Result in potentially significant environmental impact due to wasteful, inefficient, or
unnecessary consumption of energy resources, during project construction or operation; or
• Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
The State CEQA Guidelines indicate that a project would normally have a significant adverse
greenhouse gas emission impact if the project would:
Generate greenhouse gas emissions, either directly or indirectly, that may have a significant
impact on the environment; or
• Conflict with an applicable plan, policy or regulation adopted for the purpose of reduction the
emissions of greenhouse gases.
Certain air districts (e.g., SCAQMD) have created guidelines and requirements to conduct air quality
analysis. The SCAQMD's current guidelines, its CEQA Air Quality Handbook with associated updates,
were followed in this assessment of air quality and GHG impacts for the proposed project.
CRITERIA POLLUTANT THRESHOLDS
SCAQMD has established daily emissions thresholds for construction and operation of a proposed
project in the Basin. The emissions thresholds were established based on the attainment status of
the Basin with regard to air quality standards for specific criteria pollutants. Because the
concentration standards were set at a level that protects public health with an adequate margin of
safety, these emissions thresholds are regarded as conservative and would overstate an individual
project's contribution to health risks.
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Table G lists the CEQA significance thresholds for construction and operational emissions
established for the Basin. Projects in the Basin with construction- or operation -related emissions
that exceed any of their respective emission thresholds would be considered significant under
SCAQMD guidelines. These thresholds, which SCAQMD developed and that apply throughout the
Basin, apply as both project and cumulative thresholds. If a project exceeds these standards, it is
considered to have a project -specific and cumulative impact.
Table G: Regional Thresholds for Construction and Operational Emissions
Emissions Source
Pollutant Emissions Threshold (Ibs/day)
VOcs
NOx
co
PM10
PM2.5
sox
Construction
75
100
550
150
55
150
Operations
55
55
550
150
55
150
Source: SCAQMD. Air Quality Significance Thresholds. Website: http://www.agmd.gov/docs/default-source/ceqa/handbook/scaqmd-
air-quality-significance-thresholds.pdf (accessed January 2024).
CO = carbon monoxide PM2.5 = particulate matter less than 2.5 microns in size
Ibs/day = pounds per day SCAQMD = South Coast Air Quality Management District
NOx = nitrogen oxides Sox = sulfur oxides
PMto = particulate matter less than 10 microns in size VOCs = volatile organic compounds
LOCALIZED IMPACTS ANALYSIS
The SCAQMD published its Final Localized Significance Threshold Methodology in July 2008,
recommending that all air quality analyses include an assessment of air quality impacts to nearby
sensitive receptors.44 This guidance was used to analyze potential localized air quality impacts
associated with construction of the proposed project. Localized significance thresholds (LST) are
developed based on the size or total area of the emission source, the ambient air quality in the
source receptor area, and the distance to the project. Sensitive receptors include residences,
schools, hospitals, and similar uses that are sensitive to adverse air quality.
LSTs are based on the ambient concentrations of that pollutant within the project Source Receptor
Area (SRA) and the distance to the nearest sensitive receptor. For the proposed project, the
appropriate SRA for the LST is the nearby Central Orange County (SRA 17). SCAQMD provides LST
screening tables for 25, 50, 100, 200, and 500-meter source -receptor distances. As identified above,
the closest sensitive receptors to the project site include residential uses, located approximately 70
feet south of the project's site boundary. In cases where receptors may be closer than 82 feet (25
meters), any distances within the 82-foot (25-meter) buffer zone can be used. As such, the minimum
distance of 25 meters was used. Based on the anticipated construction equipment, it is assumed
that the maximum daily disturbed acreage during construction would be 3.5 acres.45 The 5-acre
thresholds were used for project operation. Table H lists the emissions thresholds that apply during
project construction and operation.
44 SCAQMD. 2008a. Final Localized Significance Threshold Methodology. July.
45 SCAQMD. n.d. Fact Sheet for Applying CaIEEMod to Localized Significance Thresholds. Website:
http://www.agmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/caleemod
guidance.pdf (accessed February 2024).
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Table H: South Coast Air Quality Management District Localized Significance
Thresholds
Emissions Source
Pollutant Emissions Threshold (Ibs/day)
N%
co
PM10
PMz.s
Construction
149.0
984.0
9.5
5.5
Operations
183.0
1,253.0
3.0
2.0
Source: South Coast Air Quality Management District (2008).
CO = carbon monoxide PM,o = particulate matter less than 10 microns in size
Ibs/day = pounds per day PM2.5 = particulate matter less than 2.5 microns in size
NO.= nitrogen oxides
LOCAL MICROSCALE CONCENTRATION STANDARDS
The significance of localized project impacts under CEQA depends on whether ambient CO levels in
the vicinity of the project are above or below State and federal CO standards. Because ambient CO
levels are below the standards throughout the Basin, a project would be considered to have a
significant CO impact if project emissions result in an exceedance of one or more of the 1-hour or
8-hour standards. The following are applicable local emission concentration standards for CO:
• California State 1-hour CO standard of 20 parts per million (ppm)
• California State 8-hour CO standard of 9 ppm
GREENHOUSE GAS THRESHOLD
To provide guidance to local lead agencies on determining significance for GHG emissions in their
CEQA documents, SCAQMD convened a GHG CEQA Significance Threshold Working Group (Working
Group). Based on the last Working Group meeting held in September 2010 (Meeting No. 15),
SCAQMD proposed to adopt a tiered approach for evaluating GHG emissions for development
projects where SCAQMD is not the lead agency:
Tier 1. Exemptions: If a project is exempt from CEQA, project -level and cumulative GHG
emissions are less than significant.
• Tier 2. Consistency with a locally adopted GHG Reduction Plan: If the project complies with a
GHG emissions reduction plan or mitigation program that avoids or substantially reduces GHG
emissions in the project's geographic area (i.e., city or county), project -level and cumulative
GHG emissions are less than significant.
Tier 3. Numerical Screening Threshold: If GHG emissions are less than the numerical screening -
level threshold, project -level and cumulative GHG emissions are less than significant.
For projects that are not exempt or where no qualifying GHG reduction plans are directly
applicable, SCAQMD requires an assessment of GHG emissions. The 10,000 MT of CO2e per year
(MT CO2e/yr) threshold for industrial uses would be recommended for use by all lead agencies.
Under Option 1, separate screening thresholds are proposed for residential projects (3,500 MT
CO2e/yr), commercial projects (1,400 MT CO2e/yr), and mixed -use projects (3,000 MT CO2e/yr).
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Under Option 2, a single numerical screening -level threshold of 3,000 MT CO2e/yr would be
used for all non -industrial projects.
• Tier 4. Performance Standards: If emissions exceed the numerical screening threshold, a more
detailed review of the project's GHG emissions is warranted. SCAQMD has proposed an
efficiency target for projects that exceed the bright -line threshold. The current recommended
approach is per capita efficiency targets. SCAQMD is not recommending use of a percent
emissions reduction target. Instead, SCAQMD proposes a 2020 efficiency target of 4.8 MT
CO2e/yr per service population (for project -level analyses and 6.6 MT CO2e/yr per service
population for plan -level projects (e.g., program -level projects such as general plans). The GHG
efficiency metric divides annualized GHG emissions by the service population, which is the sum
of residents and employees, per the following equation:
Rate of Emission: GHG Emissions (MT CO2e/yr) - Service Population
The efficiency evaluation consists of comparing the project's efficiency metric to efficiency
targets. Efficiency targets represent the maximum quantity of emissions each resident and
employee in the State of California could emit in various years based on emissions levels
necessary to achieve the statewide GHG emissions reduction goals. A project that results in a
lower rate of emissions would be more efficient than a project with a higher rate of emissions,
based on the same service population. The metric considers GHG reduction measures integrated
into a project's design and operation (or through mitigation). The per capita efficiency targets
are based on the AB 32 GHG reduction target and 2020 GHG emissions inventory prepared for
the CARB's 2008 Scoping Plan.
Relative to the 2035 target date, this target date was selected to be consistent with the GHG
reduction target date of SIB 375. Overall, GHG reductions by the SIB 375 target date of 2035
would be approximately 40 percent. This 40 percent reduction was applied to the 2020 targets,
resulting in an efficiency threshold for plans of 4.1 MT CO2e/yr and an efficiency threshold at the
project level of 3.0 MT CO2e/yr.
For the purpose of this analysis, the proposed project will first be compared to the SCAQMD
screening -level Tier 3 Numerical Screening Threshold of 3,000 MT CO2e/yr for all land use type
projects. If it is determined that the proposed project is estimated to exceed this numerical
threshold, it will then be compared to the SCAQMD-recommended 2035 efficiency -based plan -level
threshold of 4.1 MT CO2e/yr per service population. In addition, the proposed project is also
evaluated for compliance with the 2022 Scoping Plan and the 2024-2050 RTP/SCS.
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IMPACTS ANALYSIS
ENDE RUE CENTER PROJECT L C A
CITY OF TUSTI N, CALIFORNIA J /`�`
This section identifies the air quality, energy, and GHG emissions impacts associated with
implementation of the proposed project.
AIR QUALITY IMPACTS
Air pollutant emissions associated with the project would occur over the short term from
construction activities and over the long term from operational activities associated with the
proposed land uses.
Consistency with Applicable Air Quality Plans
A consistency determination plays an essential role in local agency project review by linking local
planning and unique individual projects to the air quality plans. A consistency determination fulfills
the CEQA goal of fully informing local agency decision -makers of the environmental costs of the
project under consideration at a stage early enough to ensure that air quality concerns are
addressed. Only new or amended General Plan elements, Specific Plans, and significantly unique
projects need to undergo a consistency review due to the air quality plan strategy being based on
projections from local General Plans.
Consistency with the 2022 AQMP would be achieved if the project is consistent with the goals,
objectives, and assumptions in this plan to achieve the federal and State air quality standards. Per
SCAQMD's CEQA Air Quality Handbook, there are two main indicators of a project's consistency with
the AQMP:
Indicator 1: Whether the project would result in an increase in the frequency or severity of
existing air quality violations, cause or contribute to new violations, or delay timely attainment of
the ambient air quality standards or emission reductions in the AQMP.
• Indicator 2: Whether the project would exceed the assumptions in the AQMP. The AQMP strategy
is, in part, based on projections from local general plans.
Indicator 1: As demonstrated below, the regional emissions generated by construction and
operation of the proposed project would be less than the SCAQMD emissions thresholds. As such,
the proposed project would not be consistent with Indicator 1.
Indicator 2: The CEQA Air Quality Handbook indicates that consistency with AQMP growth
assumptions must be analyzed for new or amended General Plan elements, Specific Plans, and
significant projects. Significant projects include airports, electrical generating facilities, petroleum
and gas refineries, designation of oil drilling districts, water ports, solid waste disposal sites, and
offshore drilling facilities.
The proposed project includes a GPA to amend the City's existing General Plan to create a Housing
Overlay Zone. The proposed project would not directly result in physical development but upon
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approval of the Housing Overlay Zone, the project site could accommodate 413 units. As such, this
analysis evaluates whether the project would exceed the 2022 AQMP's assumptions.
With respect to determining the proposed project's consistency with AQMP growth assumptions,
the projections in the AQMP for achieving air quality goals are based on assumptions in SCAG's
2024-2050 RTP/SCS regarding population, housing, and growth trends. According to SCAG's 2024-
2050 RTP/SCS, in 2019, the City's population was 80,400 residents and the City had 27,000
households and 51,700 jobs. Households are forecast to increase by approximately 6,800
households by 2035 and 7,000 households by 2050 and employment are forecast to increase by
approximately 14,600 jobs by 2035 and 19,600 jobs by 2050.46
As identified in the Project Description, the City's 2021-2029 Housing Element identifies several
adequate sites that are able to accommodate the development of up to additional housing units for
the City to meet its estimated housing growth needs identified in the SCAG's RHNA allocation. Of
the Housing Element inventory sites, Enderle Center (the project site) was identified as necessary for
rezoning under Housing Element Program 1.1f to allow for high density residential/mixed use
development. The proposed project would accommodate up to 413 housing units to help the City
meet its RHNA allocation.
The development of 413 housing units would result in approximately 1,189 additional residents
based on the estimated 2.88 persons per household41 in Tustin. Future development implemented
in accordance with the proposed Housing Overlay Zone would accommodate planned regional
housing growth included in the SCAG RHNA and would be required to adhere to the General Plan.
Therefore, since the purpose of the proposed project is to accommodate planned regional housing
growth included in the SCAG RHNA, the proposed project would not exceed the growth assumptions
in the SCAG's 2024-2050 RTP/SCS or the AQMP.
In addition, the proposed project would not include airports, electrical generating facilities,
petroleum and gas refineries, designation of oil drilling districts, water ports, solid waste disposal
sites, and offshore drilling facilities; therefore, it is unlikely that the proposed project would
interfere with SCAQMD's goals for improving air quality in the region. The proposed project would
not conflict with the 2022 AQMP and, as such, would not jeopardize attainment of the CAAQS and
NAAQS in the area under the jurisdiction of the SCAQMD. The proposed project is therefore
considered consistent with Indicator 2.
Summary: Based on the discussion above, the proposed project would not conflict or obstruct
implementation of applicable air quality plans under Indicator 1 because the proposed project
would result in pollutant emissions below the SCAQMD's thresholds. As such, based on the
46 Southern California Association of Governments (SCAG). 2024. Connect SoCal2024 Demographics &
Growth Forecast. Website: https:Hscag.ca.gov/sites/main/files/file-attachments/23-2987-tr-
demographics-growth-forecast-final-040424.pdf?1712261839 (accessed May 2024).
47 State of California, Department of Finance. 2023. E-1 Population Estimates for Cities, Counties and the
State with Annual Percent Change. May.
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consistency analysis presented above, the proposed project would be consistent with the regional
AQM P.
Criteria Pollutant Analysis
The Basin is designated as non -attainment for 03 and PM2.5 for federal standards and non -attainment
for 03, PM1o, and PM2.5 for State standards. The SCAQMD's nonattainment status is attributed to the
region's development history. Past, present, and future development projects contribute to the
region's adverse air quality impacts on a cumulative basis. By its very nature, air pollution is largely a
cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of AAQS.
Instead, a project's individual emissions contribute to existing cumulatively significant adverse air
quality impacts. If a project's contribution to the cumulative impact is considerable, then the project's
impact on air quality would be considered significant.
In developing thresholds of significance for air pollutants, the SCAQMD considered the emission
levels for which a project's individual emissions would be cumulatively considerable. If a project
exceeds the identified significance thresholds, its emissions would be cumulatively considerable,
resulting in significant adverse air quality impacts to the region's existing air quality conditions.
Therefore, additional analysis to assess cumulative impacts is unnecessary. The following analysis
assesses the potential project -level construction- and operation -related air quality impacts.
Construction Emissions
It is important to note that the proposed project would not, in and of itself entitle, propose, or
otherwise require the construction of new development. The proposed project would create a
Housing Overlay Zone that would accommodate 413 units.
Construction activities associated with the construction of additional housing units and remaining
commercial buildout capacity that could occur with implementation of the project would be through
the horizon year 2029, which would cause short-term emissions of criteria air pollutants. The
primary source of emissions is the operation of construction equipment. Before development can
take place, a project will be required to be analyzed for conformance with the General Plan, zoning
requirements, and other applicable local and State requirements; comply with the requirements of
CEQA; and obtain all necessary clearances and permits.
Construction activities would include demolition, site preparation, grading, building construction,
architectural coating, and paving activities. Construction -related effects on air quality are typically
greatest during the grading phase due to the disturbance of soils. If not properly controlled, these
activities would temporarily generate particulate emissions. Sources of fugitive dust would include
disturbed soils at construction sites. Unless properly controlled, vehicles leaving construction sites
would deposit dirt and mud on local streets, which could be an additional source of airborne dust
after it dries. PM10 emissions would vary from day to day, depending on the nature and magnitude
of construction activity and local weather conditions. PM10 emissions would depend on soil
moisture, silt content of soil, wind speed, and the amount of operating equipment. Larger dust
particles would settle near the source, whereas fine particles would be dispersed over greater
distances from the construction site.
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Water or other soil stabilizers can be used to control dust, resulting in emission reductions of
50 percent or more. The SCAQMD has established Rule 403 (Fugitive Dust), which would require the
contractor to implement measures that would reduce the amount of particulate matter generated
during the construction period.
In addition to dust -related PM10 emissions, heavy trucks and construction equipment powered by
gasoline and diesel engines would generate CO, S02, NOx, VOCs and some soot particulate (PM2.5
and PM1o) in exhaust emissions. If construction activities were to increase traffic congestion in the
area, CO and other emissions from traffic would increase slightly while those vehicles idle in traffic.
These emissions would be temporary in nature and limited to the immediate area surrounding the
construction site.
Construction emissions were estimated for development envisioned under the proposed project
using CalEEMod. As described in the Methodology section above, information regarding a specific
development project is not yet known; however, for the purposes of this analysis, future
development of the additional 413 units and remaining commercial buildout capacity associated
with the proposed project could occur anytime between October 2024 and October 2029.
Therefore, to be conservative, this analysis assumes a project construction schedule based on a start
date of October 2024 and a default construction duration in CaIEEMod. Table I lists the tentative
schedule, and Table J lists the potential construction equipment to be used during project
construction under each phase of construction. Construction -related emissions are presented in
Table K. CaIEEMod output sheets are included in Appendix A.
Table I: Tentative Project Construction Schedule
Phase
Number
Phase Name
Phase Start Date
Phase End Date
Number of
Days/Week
Number of Days
1
Demolition
10/7/2024
11/4/2024
5
20
2
Site Preparation
11/5/2024
11/19/2024
5
10
3
Grading
11/20/2024
1/1/2025
5
30
4
Building Construction
1/2/2025
2/26/2026
5
300
5
Paving
2/27/2026
3/27/2026
5
20
6
Architectural Coating
12/8/2025
4/25/2026
5
100
Source: Compiled by LSA assuming construction would start October 2024 with a default construction duration in CalEEMod and
assuming architectural coating would overlap with building construction activities (March 2024).
CalEEMod = California Emissions Estimator Model
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ENDE RUE CENTER PROJECT LSA
CITY OF TUSTI N, CALIFORNIA
Table J: Diesel Construction Equipment Utilized by Construction Phase
Construction Phase
Off -Road Equipment Type
Off -Road
Equipment
Unit Amount
Hours Used
per Day
Horsepower
Load Factor
Demolition
Concrete/Industrial Saws
1
8
33
0.73
Excavators
3
8
36
0.38
Rubber Tired Dozers
2
8
367
0.4
Site Preparation
Rubber Tired Dozers
3
8
367
0.4
Tractors/Loaders/Backhoes
4
8
84
0.37
Grading
Excavators
2
8
36
0.38
Graders
1
8
148
0.41
Rubber Tired Dozers
1
8
367
0.4
Scrapers
2
8
423
0.48
Tractors/Loaders/Backhoes
2
8
84
0.37
Building Construction
Cranes
1
7
367
0.29
Forklifts
3
8
82
0.2
Generator Sets
1
8
14
0.74
Tractors/Loaders/Backhoes
3
7
84
0.37
Welders
1
8
46
0.45
Paving
Pavers
2
8
81
0.42
Paving Equipment
2
8
89
0.36
Rollers
2
8
36
0.38
Architectural Coating
Air Compressors
1
6
37
0.48
Source: Compiled by LSA using CalEEMod defaults (March 2024).
CalEEMod = California Emissions Estimator Model
Table K: Project Construction Emissions
Project Construction
Maximum Pollutant Emissions (Ibs/day)
VOCs
NOx
CO
sox
PM10
PM2.5
2024
1.4
48.9
36.4
0.1
11.2
5.0
2025
38.0
48.9
36.3
0.1
6.6
2.7
2026
37.9
23.5
34.8
<0.1
6.6
2.1
Maximum Daily Emissions
37.9
48.9
36.4
0.1
11.2
5.0
SCAQMD Thresholds
75.0
100.0
550.0
150.0
150.0
55.0
Exceeds?
No
No
I No
I No
I No
No
Source: Compiled by LSA (March 2024).
CO = carbon monoxide
Ibs/day = pounds per day
NOx = nitrogen oxides
PM,,, = particulate matter less than 2.5 microns in size
PMio = particulate matter less than 10 microns in size
SCAQMD = South Coast Air Quality Management District
Sox = sulfur oxides
VOCs = volatile organic compounds
As shown in Table I, construction emissions associated with future development, as envisioned
under the proposed project would not exceed the SCAQMD thresholds for VOCs, NOx, CO, sulfur
oxides (SOx), PM2.5, or PM10 emissions. The proposed project would be required to comply with
SCAQMD Rule 403: Fugitive Dust, which would further reduce construction -related emissions.
Therefore, future construction of development projects consistent with the proposed project would
not result in emissions that would result in a cumulatively considerable net increase of any criteria
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pollutant for which the project is in nonattainment under an applicable federal or State ambient air
quality standard.
Operational Air Quality Impacts
Operational activities associated with the additional housing units and remaining commercial
buildout capacity consistent with the buildout envisioned as part of the proposed project would
result in long-term air pollutant emissions associated with mobile sources (e.g., vehicle trips), energy
sources (e.g., natural gas), and area sources (e.g., architectural coatings and the use of landscape
maintenance equipment). Before development can take place, a project will be required to be
analyzed for conformance with the General Plan, zoning requirements, and other applicable local
and State requirements; comply with the requirements of CEQA; and obtain all necessary clearances
and permits.
PM10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into
the atmosphere from vehicles traveling on paved roadways. Entrainment of PM10 occurs when
vehicle tires pulverize small rocks and pavement and the vehicle wakes generate airborne dust. The
contribution of tire and brake wear is small compared to the other PM emission processes.
Gasoline -powered engines have small rates of particulate matter emissions compared with diesel -
powered vehicles. The existing uses generate approximately 7,058 ADT and the proposed project
would generate approximately 18,528 ADT.
Energy source emissions result from activities in buildings for which electricity and natural gas are
used. The quantity of emissions is the product of usage intensity (i.e., the amount of natural gas)
and the emission factor of the fuel source. Major sources of energy demand for the proposed
project could include building mechanical systems, such as heating and air conditioning. The
residential units would be constructed in compliance with the version of the Title 24 energy
standards and the CALGreen Code in effect at the time building permit applications are submitted.
Typically, area source emissions consist of direct sources of air emissions located at the project site,
including architectural coatings, consumer products, and the use of landscape maintenance
equipment.
Long-term operation emissions associated with development consistent with the proposed project
were calculated using CalEEMod. Model results are shown in Table L below. CalEEMod output
sheets are included in Appendix A.
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Table L: Project Operational Emissions
Emission Type
Pollutant Emissions (Ibs/day)
VOCs NO. I CO SO. PM,,, PMzs
Existing Uses
Existing Uses Mobile Sources
23.7
19.0
192.5
0.5
42.0
10.9
Existing Uses Area Sources
2.8
<0.1
3.8
<0.1
<0.1
<0.1
Existing Uses Energy Sources
0.1
1.1
0.9
<0.1
0.1
0.1
Total Existing Uses Emissions
26.5
20.0
197.2
0.5
42.1
11.0
Full Buildout of the Project Site
Project Buildout Mobile Sources
62.4
50.4
511.7
1.2
112.1
29.0
Project Buildout Area Sources
18.0
6.2
34.9
<0.1
0.5
0.5
Project Buildout Energy Sources
0.2
3.7
2.6
<0.1
0.3
0.3
Total Project Buildout Emissions
80.6
60.2
549.2
1.3
112.9
29.8
Net New Emissions (Project Buildout
- Existing Uses)
54.1
40.2
352.0
0.8
70.8
18.8
SCAQMD Thresholds
55.0
55.0
550.0
150.0
150.0
55.0
Significant?
No
No
No
No
No
No
Source: Compiled by LSA (March 2024).
CO = carbon monoxide
Ibs/day = pounds per day
NOx = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size
PM10 = particulate matter less than 10 microns in size
SCAQMD = South Coast Air Quality Management District
Sox = sulfur oxides
VOCs = volatile organic compounds
The results shown in Table L indicate that the net new emissions associated with the future
development of the proposed project would not exceed the significance criteria for VOCs, NOx, CO,
Sox, PMlo, or PM2.5 emissions; thus, the proposed project would not have a significant effect on
regional air quality. Therefore, operation of the project would not result in a cumulatively
considerable net increase of any criteria pollutant for which the project is nonattainment under an
applicable federal or State ambient air quality standard.
Long -Term Microscale (CO Hot Spot) Analysis
Vehicular trips associated with the proposed project would contribute to congestion at intersections
and along roadway segments in the project vicinity. Localized air quality impacts would occur when
emissions from vehicular traffic increase as a result of the proposed project. The primary mobile -
source pollutant of local concern is CO, a direct function of vehicle idling time and, thus, of traffic
flow conditions. CO transport is extremely limited; under normal meteorological conditions, CO
disperses rapidly with distance from the source. However, under certain extreme meteorological
conditions, CO concentrations near a congested roadway or intersection may reach unhealthful
levels, affecting local sensitive receptors (e.g., residents, schoolchildren, the elderly, and hospital
patients). Typically, high CO concentrations are associated with roadways or intersections operating
at unacceptable levels of service or with extremely high traffic volumes. In areas with high ambient
background CO concentrations, modeling is recommended to determine a project's effect on local
CO levels.
An assessment of project -related impacts on localized ambient air quality requires that future
ambient air quality levels be projected. Existing CO concentrations in the immediate project vicinity
are not available. Ambient CO levels monitored at the Anaheim monitoring station, the closest
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station to the City of Tustin, showed a highest recorded 1-hour concentration of 2.4 ppm (the State
standard is 20 ppm) and a highest 8-hour concentration of 1.7 ppm (the State standard is 9
ppm) during the past 3 years (Table G). The highest CO concentrations would normally occur during
peak traffic hours; hence, CO impacts calculated under peak traffic conditions represent a worst -
case analysis.
The proposed project would generate 11,470 net new ADT in the immediate vicinity of the
opportunity sites and would result in 757 net new AM peak -hour trips and in 1,041 net new PM
peak -hour trips. The proposed project would not result in any operational deficiencies to the
surrounding roadway system. The evaluation of the study area intersections shows that the addition
of traffic associated with new development allowed under the proposed project's Housing Overlay
Zone is not expected to create significant level of service changes under buildout conditions.
Therefore, project traffic would not create any significant adverse impacts to nearby intersections.
Therefore, given the extremely low level of CO concentrations in the City, and lack of traffic impacts
at any intersections, project -related vehicles are not expected to contribute significantly or result in
the CO concentrations exceeding the State or federal CO standards.
Health Risk on Nearby Sensitive Receptors
The SCAQMD recommends the evaluation of localized air quality impacts to sensitive receptors such
as residential land uses in the immediate vicinity of the opportunity sites as a result of construction
and operational activities. The thresholds are based on standards established by the SCAQMD in its
Localized Significance Thresholds (LST) Methodology48 and are measured against construction and
operational emissions that occur on a specific project site. These emissions are primarily generated
from heavy-duty construction equipment and demolition, grading, and trenching activities.
Construction and operational activities associated with the construction of additional housing units
and remaining commercial buildout capacity that could occur with implementation of the proposed
project would have the potential to cause or contribute to significant localized air quality impacts to
nearby residential land uses.
Construction and operation emissions associated with development consistent with the proposed
project were compared to the LST screening tables in SRA 17, based on a 25-meter source -receptor
distance.
48 SCAQMD. 2021. Localized Significance Thresholds. Website: http://www.agmd.gov/home/rules-
compliance/ceqa/air-quality-analysis-handbook/localized-significance-thresholds (accessed January
2024).
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By design, the localized impacts analysis only includes on -site emission sources; however, the
CalEEMod outputs do not separate on -site and off -site emissions for mobile sources. For a worst -
case scenario assessment, the emissions detailed in Table N assume all area and energy source
emissions would occur on site, and 5 percent of the project -related new mobile sources, which is an
estimate of the amount of project -related on -site vehicle travel, would occur on site. Since the
majority of vehicle travel would occur off -site and considering the total overall VMT and trip length
included in CalEEMOd, assuming that the 5 percent of the project's VMT would occur on -site is
conservative.
Table M: Project Localized Construction Emissions (Ibs/day)
Source
NOx
c0
PM10
PM2.5
On -Site Project Construction Emissions
48.8
35.3
8.8
4.9
Localized Significance Threshold
149.0
984.0
9.5
5.5
Exceeds Threshold?
No
No
No
No
Source: Compiled by LSA (March 2024).
CO= carbon monoxide
Ibs/day = pounds per day
NO.= nitrogen oxides
PM2.5= particulate matter less than 2.5 microns in size
PMio= particulate matter less than 10 microns in size
Table N: Project Localized Operational Emissions (Ibs/day)
Source
NO,
c0
PM10
PM2.5
On -Site Project Buildout Net New
Emissions
10.4
48.8
4.2
1.6
Localized Significance Threshold
183.0
1,253.0
3.0
2.0
Exceeds Threshold?
No
No
Yes
No
Source: Compiled by LSA (March 2024).
CO= carbon monoxide PM,.,= particulate matter less than 2.5 microns in size
Ibs/day = pounds per day PM,o= particulate matter less than 10 microns in size
NO,= nitrogen oxides
The results of the LST analysis, summarized in Table M, indicates that the project would not result in
an exceedance of the SCAQMD LSTs during project construction. However, net new emissions
associated with the future development of the proposed project would exceed the SCAQMD LSTs
for PM10 during operational activities. As shown in Table L above, the majority of the PM10 emissions
are associated with mobile sources from project -related vehicle trips. Emissions of motor vehicles
are controlled by State and federal standards, and the project has no control over these standards.
As such, implementation of Mitigation Measure AIR-1 would require a project -specific assessment of
potential localized impacts and if the project exceeds the applicable LST thresholds, a dispersion
modeling analysis would be necessary to calculate health risk from project implementation.
Mitigation Measure AIR-1 Prior to discretionary approval by the City of Tustin (City) for
residential development projects subject to California
Environmental Quality Act (CEQA) review, project applicants shall
prepare and submit a technical assessment evaluating potential
project -related air quality impacts, including a localized impacts
analysis, to the City for review and approval. The analysis shall be
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prepared in conformance with South Coast Air Quality Management
District (SCAQMD) methodology. If project -related emissions exceed
applicable SCAQMD thresholds of significance, the City shall require
that applicants for new development projects incorporate
mitigation measures to reduce emissions. The identified measures
shall be included as part of the conditions of approval. Additionally,
if project -related localized emissions exceed the SCAQMD's
thresholds, a dispersion modeling analysis shall be conducted to
calculate potential health risk from project implementation.
While Mitigation Measure AIR-1 would serve to reduce localized emissions associated with buildout
of the project, localized emission impacts would remain significant and unavoidable.
It should be noted that the amount of emissions from a project does not necessarily correspond to
the concentrations of air pollutants. A dispersion modeling analysis would be necessary to calculate
health risk from project implementation. However, since it is not possible to translate the amount of
an unknown future specific project's emissions to a particular concentration, it is not possible to
calculate the risk factor for a particular health effect at the time of this analysis.
Known health effects related to ozone include worsening of bronchitis, asthma, and emphysema
and a decrease in lung function. Particulate matter can also lead to a variety of health effects in
people. These include premature death of people with heart or lung disease, heart attacks, irregular
heartbeat, decreased lung function, and increased respiratory symptoms. Regional emissions of
criteria pollutants contribute to these known health effects. The SCAQMD is the primary agency
responsible for ensuring the health and welfare of sensitive individuals and that they are not exposed
to elevated concentrations of criteria pollutants in the Basin. To achieve the health -based standards
established by the USEPA, the SCAQMD prepares an AQMP that details regional programs to attain the
ambient air quality standards.
Although the analysis for the proposed project identifies that construction emissions associated with
develop envisioned as part of the proposed project would not exceed the SCAQMD's thresholds for
VOCs, NOx, CO, SOX, PM2.5, or PM10 emissions, it should be noted that not exceeding the SCAQMD's
numeric regional mass daily thresholds does not necessarily correspond to a determination for
health risk impacts to sensitive receptors. This is because the mass daily thresholds are in pounds
per day emitted into the air, whereas health effects are determined based on the concentration of
emissions in the air at a particular receptor (e.g., ppm by volume of air, or µg/m3 of air). State and
federal ambient air quality standards were developed to protect the most susceptible population
groups from adverse health effects and were established in terms of parts per million or micrograms
per cubic meter for the applicable emissions.
However, the SCAQMD acknowledges that they have only been able to correlate potential health
outcomes for very large emissions sources; specifically, 6,620 pounds per day (Ibs/day) of NOx, and
89,180 Ibs/day of VOCs were expected to result in approximately 20 premature deaths per year and
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89,947 school absences due to ozone.49 As identified in Table K above, construction of the proposed
project would generate a maximum of 48.9 Ibs/day of NOx and 37.9 Ibs/day of VOCs and as shown in
Table L, operation of the proposed project would generate a maximum of 60.2 Ibs/day of NOx and
80.9 Ibs/day of VOCs. Therefore, it is not expected that any future development associated with the
proposed project would generate 6,620 Ibs/day of NOx or 89,180 Ibs/day of VOC emissions.
Therefore, emissions associated with the proposed project is not sufficiently high enough to
correlate health effects on a Basin -wide level.
Current scientific, technological, and modeling limitations prevent the relation of expected adverse
air quality impacts to likely health consequences. For this reason, this discussion explains why it is
not feasible to provide such an analysis. However, as required by Mitigation Measure AIR-1, once a
specific project is proposed, it would still be required to conduct a site -specific localized impact
analysis that evaluates potential project health impacts at a project level to immediately adjacent
land uses.
In addition, the project would be required to comply with SCAQMD standard conditions, including
Rule 403 (Fugitive Dust) to control fugitive dust and Rule 1113 (Architectural Coatings) to control
VOC emissions from paint. Furthermore, any necessary mitigation would be imposed at the project
level once such future projects are proposed.
Asbestos
Naturally occurring asbestos (NOA) refers to the asbestos mineral as a natural component of soils or
rocks, as opposed to asbestos in commercial products or other processing operations. Ultramafic
rocks may contain asbestos or asbestos -like materials. Naturally occurring asbestos can be released
from rocks or soils by routine human activities, such as construction, mining, agriculture, or natural
weathering processes. If NOA is disturbed and fibers are released into the air it may become a
health risk from inhalation. According to the California Geological Survey, no such rock has been
identified in the project vicinity50. When demolition is proposed during construction, the demolition
of existing buildings may expose asbestos used in building materials. The proposed project would
demolish the existing surface parking; however existing buildings on the project site would not be
demolished as part of the project. Therefore, the potential risk for naturally occurring asbestos
during project construction is small and would not be significant.
Odors
During construction of future development envisioned under the proposed project, some odors may
be present due to diesel exhaust. However, these odors would be temporary and limited to the
construction period. The proposed project would not include any activities or operations that would
generate objectionable odors and once operational, development envisioned under the proposed
49 Supreme Court of California. 2015. Sierra Club, Revive the San Joaquin, and League of Women Voters of
Fresno, Plaintiffs and Appellants, v. County of Fresno, Defendant and Despondent, and Friant Ranch, L.P.,
Real Part in Interest and Despondent. April.
50 California Geological Survey, n.d. Areas with Potential for Naturally Occurring Asbestos. Website:
https://www.arcgis.com/apps/webappviewer/index.html?id=da4b648958844134adc25ffO02dbealc
(accessed February 2024).
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project would not be a source of odors. Therefore, the proposed project would not result in other
emissions (such as those leading to odors) affecting a substantial number of people.
ENERGY IMPACTS
The following describes the potential impacts regarding energy resources that could result from
implementation of the proposed project.
Energy Consumption
The proposed project would increase the demand for energy through day-to-day operations and
fuel consumption associated with project construction. This section discusses energy use resulting
from implementation of the proposed project and evaluates whether the proposed project would
result in the wasteful, inefficient, or unnecessary consumption of energy resources or conflict with
any applicable plans for renewable energy and energy efficiency.
Construction Energy Use
Construction activities associated with the construction of additional housing units and remaining
commercial buildout capacity that could occur with implementation of the project would be through
the horizon year 2029, which would cause fuel consumption associated with construction activities.
The primary source of emissions is the operation of construction equipment. Before development
can take place, a project will be required to be analyzed for conformance with the General Plan,
zoning requirements, and other applicable local and State requirements; comply with the
requirements of CEQA; and obtain all necessary clearances and permits.
Construction activities would include grading, site preparation, building construction, architectural
coating, and paving activities. Construction activities require energy associated with the
manufacture and transportation of building materials, grading activities, and building construction.
Construction activities also typically require electricity to power construction -related equipment and
do not involve the consumption of natural gas.
Transportation energy represents the largest energy use during construction and would be from the
transport and use of construction equipment, delivery vehicles and haul trucks, and construction
worker vehicles that would use petroleum fuels (e.g., diesel fuel and/or gasoline). Therefore, the
analysis of energy use during construction focuses on fuel consumption. Construction trucks and
vendor trucks hauling materials to and from a site would be anticipated to use diesel fuel, whereas
construction workers traveling to and from a site would be anticipated to use gasoline -powered
vehicles. Fuel consumption from transportation uses depends on the type and number of trips,
VMT, the fuel efficiency of the vehicles, and the travel mode.
Estimates of fuel consumption (diesel fuel and gasoline) from construction equipment, construction
trucks, and construction worker vehicles were based on default construction equipment
assumptions and trip estimates from CalEEMod and fuel efficiencies from EMFAC2021. Fuel
consumption estimates are presented in Table O. CalEEMod output sheets are included in
Appendix A, and detailed energy calculations are included in Appendix B.
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Table O: Energy Consumption Estimates during Construction
Energy Type
Total Energy Consumption
Percentage of Increase Countywide
Diesel Fuel (total gallons)
117,690
0.07
Gasoline (total gallons)
148,345
0.01
Source: Compiled by LSA (March 2024).
As indicated in Table O, development envisioned under the proposed project would consume
approximately 117,690 gallons of diesel fuel and approximately 148,345 gallons of gasoline during
construction. Based on fuel consumption obtained from EMFAC2021, approximately 1.2 billion
gallons of gasoline and approximately 157.1 million gallons of diesel will be consumed from vehicle
trips in Orange County in 2024. Therefore, construction of future development as envisioned under
the proposed project would increase the annual construction generated fuel use in Orange County
approximately by approximately 0.07 percent for diesel fuel usage and by approximately 0.01
percent for gasoline fuel usage. As such, project construction would have a negligible effect on local
and regional energy supplies. Furthermore, impacts related to energy use during construction would
be temporary and relatively small in comparison to Orange County's overall use of the State's
available energy resources. No unusual project characteristics would necessitate the use of
construction equipment that would be less energy efficient than at comparable construction sites in
the region or the State. In addition, construction activities are not anticipated to result in an
inefficient use of energy as gasoline and diesel fuel would be supplied by construction contractors
who would conserve the use of their supplies to minimize their costs on the project. The project
would not cause or result in the need for additional energy facilities or an additional or expanded
delivery system. For these reasons, fuel consumption during construction would not be inefficient,
wasteful, or unnecessary.
Operational Energy Use
Operational activities associated with the additional housing units and remaining commercial
buildout capacity consistent with the buildout envisioned as part of the proposed project would
result in energy demand associated with natural gas use, electricity consumption, and fuel used for
vehicle trips. Energy consumption was estimated for the proposed project using default energy
intensities by land use type in CalEEMod. In addition, the proposed project would also result in
energy usage associated with gasoline and diesel fuel consumed by project -related vehicle trips. Trip
generation rates for the proposed project were based on the project's trip generation estimates.
The existing uses generate approximately 7,058 ADT and the proposed project would generate
approximately 18,528 ADT. The amount of operational fuel use was estimated using CARB's
EMFAC2021 model, which provided projections for typical daily fuel usage in Orange County.
Electricity, natural gas, and fuel usage estimates associated with the proposed project are shown in
Table P.
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Table P: Energy Consumption Estimates during Operation
Energy Type I Annual Energy Consumption
Existing Uses
Electricity Consumption (kWh/year)
1,984,211
Natural Gas Consumption (therms/year)
40,171
Gasoline (gallons/year)
640,878
Diesel Fuel (gallons/year)
54,200
Full Buildout of the Project Site
Electricity Consumption (kWh/year)
5,564,016
Natural Gas Consumption (therms/year)
140,666
Gasoline (gallons/year)
1,755,365
Diesel Fuel (gallons/year)
148,455
Net New Energy Usage (Project Buildout — Existing Uses)
Electricity Consumption (kWh/year)
3,579,805
Natural Gas Consumption (therms/year)
100,495
Gasoline (gallons/year)
1,114,487
Diesel Fuel (gallons/year)
94,255
Source: Compiled by LSA (March 2024).
kWh = kilowatt-hours
As shown in Table P, the estimated potential increase in electricity demand associated with
development consistent with the proposed project is 3,579,805 kWh per year. Total electricity
consumption in Orange County in 2022 was 20,244 GWh (20,243,721,856 kWh). Therefore,
operation of the proposed project would increase the annual electricity consumption in Orange
County by approximately 0.02 percent.
Additionally, as shown in Table P, the estimated potential increase in natural gas demand associated
with development consistent with the proposed project is 100,495 therms per year. Total natural
gas consumption in Orange County in 2022 was 573 million therms (572,454,744 therms). Therefore,
operation of the proposed project would increase the annual natural gas consumption in Orange
County by approximately 0.02 percent.
Electrical and natural gas demand associated with future operations would not be considered
inefficient, wasteful, or unnecessary in comparison to other similar developments in the region.
Furthermore, the proposed project would not conflict with or obstruct a State or local plan for
renewable energy or energy efficiency. All future development would be required to adhere to all
federal, State, and local requirements for energy efficiency, including the latest Title 24 standards.
Title 24 building energy efficiency standards establish minimum efficiency standards related to
various building features, including appliances, water and space heating and cooling equipment,
building insulation and roofing, and lighting, which would reduce energy usage.
Construction of the 413 additional housing units and remaining commercial buildout capacity would
also result in energy usage associated with gasoline and diesel fuel consumed by project -related
vehicle trips. As shown in Table P, the increase in fuel use associated with the vehicle trips
generated by the proposed project is estimated at approximately 1,114,487 gallons of gasoline and
94,255 gallons of diesel fuel per year. Based on fuel consumption obtained from EMFAC2021,
approximately 1.2 billion gallons of gasoline and approximately 157.1 million gallons of diesel will be
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consumed from vehicle trips in Orange County in 2024. Therefore, vehicle trips associated with the
proposed project would increase the annual fuel use in Orange County by approximately 0.09
percent for gasoline fuel usage and approximately 0.06 percent for diesel fuel usage. Fuel
consumption associated with vehicle trips generated by project operations would not be considered
inefficient, wasteful, or unnecessary in comparison to other similar developments in the region.
Although future development, as envisioned under the proposed project would result in an increase
in demand for electricity, this increase would not require SCE to expand or construct infrastructure
that could cause substantial environmental impacts because each of the opportunity sites are
already served by utilities or directly adjacent to existing urban development. Similarly, natural gas
infrastructure is not anticipated due to cumulative development. Transportation energy use would
also increase; however, this transportation energy use would not represent a major amount of
energy use when compared to the amount of existing development and to the total number of
vehicle trips and VMT throughout Orange County and the region. As such, the buildout associated
with the proposed project would not result in a potentially significant environmental impact due to
wasteful, inefficient, or unnecessary consumption of energy resources during project construction
or operation.
Conflict with Renewable Energy or Energy Efficiency Plans
In 2002, the Legislature passed SB 1389, which required the CEC to develop an integrated energy
plan every 2 years for electricity, natural gas, and transportation fuels for the Integrated Energy
Policy Report. The plan calls for the State to assist in the transformation of the transportation
system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with
the least environmental and energy costs. To further this policy, the plan identifies a number of
strategies, including assistance to public agencies and fleet operators in implementing incentive
programs for ZEVs and their infrastructure needs, and encouragement of urban designs that reduce
VMT and accommodate pedestrian and bicycle access.
The CEC's 20231ntegrated Energy Policy Report provide the results of the CEC's assessments of a
variety of energy issues facing California. As indicated above, energy usage on the project site during
construction would be temporary in nature and would be relatively small in comparison to the
overall use in the County. In addition, energy usage associated with operation of the proposed
project would be relatively small in comparison to the overall use in Orange County, and the State's
available energy resources. Therefore, energy impacts at the regional level would be negligible.
Because California's energy conservation planning actions are conducted at a regional level, and
because the proposed project's total impact on regional energy supplies would be minor, the
proposed project would not conflict with or obstruct California's energy conservation plans as
described in the CEC's Integrated Energy Policy Report. Additionally, as demonstrated above, the
proposed project would not result in the inefficient, wasteful, and unnecessary consumption of
energy.
GREENHOUSE GAS IMPACTS
This section describes the potential GHG impacts associated with implementation the proposed
project.
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Generation of Greenhouse Gas Emissions
This section describes the proposed project's construction- and operational -related GHG emissions
and contribution to global climate change. The SCAQMD has not addressed emission thresholds for
construction in its CEQA Air Quality Handbook; however, the SCAQMD requires quantification and
disclosure. Thus, an evaluation of the project's impacts related to the release of GHG emissions for
both construction and operational phases of the project is described below.
Short -Term Greenhouse Gas Emissions
Construction activities associated with the construction of additional housing units and remaining
commercial buildout capacity would cause short-term GHG emissions. Construction activities with
the proposed project would produce combustion emissions from various sources. During
construction, GHGs would be emitted through the operation of construction equipment and from
worker and builder supply vendor vehicles, each of which typically use fossil -based fuels to operate.
The combustion of fossil -based fuels creates GHGs such as CO2, CH4, and N20. Furthermore, CH4 is
emitted during the fueling of heavy equipment. Exhaust emissions from on -site construction
activities would vary daily as construction activity levels change.
As indicated above, the SCAQMD does not have an adopted threshold of significance for
construction -related GHG emissions. However, lead agencies are required to quantify and disclose
GHG emissions that would occur during construction. The SCAQMD then requires the construction
GHG emissions to be amortized over the life of the project, defined by the SCAQMD as 30 yearssl
added to the operational emissions, and compared to the applicable interim GHG significance
threshold tier.
Using CaIEEMod, it is estimated that development envisioned under the proposed project would
generate approximately 1,522.9 MT CO2e during construction of the project. When annualized over
the 30-year life of the project, annual emissions would be 50.8 MT CO2e.
Long -Term Greenhouse Gas Emissions
Operational activities associated with the additional housing units and remaining commercial
buildout capacity consistent with the buildout envisioned as part of the proposed project would
result in long-term GHG emissions associated with mobile sources (e.g., vehicle trips), area sources
(e.g., maintenance activities and landscaping), indirect emissions from sources associated with
energy consumption, waste sources (land filling and waste disposal), and water sources (water
supply and conveyance, treatment, and distribution). Mobile -source GHG emissions would include
project -generated vehicle trips to and from the project. Area -source emissions would be associated
with activities such as landscaping and maintenance on the project site. Energy source emissions
would be generated at off -site utility providers because of increased electricity demand generated
by the project. Waste source emissions generated by the proposed project include energy
generated by land filling and other methods of disposal related to transporting and managing
project -generated waste. In addition, water source emissions associated with the proposed project
s1 The SCAQMD has identified the average operational lifespan of buildings to be 30 years. Website:
http://www.agmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-cega-significance-
thresholds/ghgattachmente.pdf (accessed January 2024).
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ENDE RUE CENTER PROJECT L C A
CITY OF TUSTI N, CALIFORNIA J /`�`
are generated by water supply and conveyance, water treatment, water distribution, and
wastewater treatment.
Following guidance from the SCAQMD, GHG emissions were estimated using CaIEEMod. Table Q
shows the calculated GHG emissions for development consistent with the proposed project.
Table Q: Greenhouse Gas Emissions (MT/yr)
Emissions Source
Operational Emissions (MT/yr)
co, CH4 Nz0 COZe
Existing Uses
Existing Uses Mobile Sources
6,169.3
0.3
0.3
6,271.5
Existing Uses Area Sources
1.8
<0.1
<0.1
1.8
Existing Uses Energy Sources
691.7
<0.1
<0.1
694.2
Existing Uses Water Sources
29.3
0.5
<0.1
45.0
Existing Uses Waste Sources
35.8
3.6
0.0
125.3
Total Existing Uses Emissions
6,927.9
4.4
0.3
7,137.8
Full Buildout of the Project Site
Project Buildout Mobile Sources
16,874.0
0.9
0.7
17,151.0
Project Buildout Area Sources
100.0
<0.1
<0.1
100.2
Project Buildout Energy Sources
2,088.8
0.1
<0.1
2,096.0
Project Buildout Water Sources
99.6
1.7
<0.1
152.9
Project Buildout Waste Sources
111.7
11.2
<0.1
390.9
Project Buildout Emissions
19,274.1
13.9
0.7
19,891.0
Amortized Construction Emissions
50.8
Total Project Buildout Annual Emissions
19,941.8
Net New Emissions (Project Buildout - Existing Uses)
12,804.0
SCAQMD Threshold
3,000
Exceed?
Yes
Per Service Population Emissions
8.2
SCAQMD Efficiency Target Threshold
4.1
Exceed?
Yes
Source: Compiled by LSA (March 2024).
CH4 = methane MT/yr = metric tons per year
CO2 = carbon dioxide N20 = nitrous oxide
CO2e = carbon dioxide equivalent SCAQMD = South Coast Air Quality Management District
As discussed above, according to SCAQMD, a project would have less than significant GHG emissions
if it would result in operational -related GHG emissions of less than 3,000 MT CO2e/yr. Based on the
analysis results, the proposed project would result in a net increase of 12,804.0 MT CO2e/yr, which
would exceed the SCAQMD threshold of 3,000 MT CO2e/yr. Therefore, consistent with the
SCAQMD's interim guidance, the following discussion compares the proposed project to the
efficiency -based threshold.
The development of 413 housing units would result in approximately 1,189 additional residents
based on the estimated 2.88 persons per household52 in Tustin. In addition, the proposed project
52 State of California, Department of Finance. 2023. E-1 Population Estimates for Cities, Counties and the
State with Annual Percent Change. May.
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would include an additional 39,087 sq ft of restaurant use, 54,328 sq ft of retail and service use, and
25,051 sq ft of office use. Future development, as envisioned under the proposed project would
result in 365 new employees. The total service population (residents plus employees) would be
1,554 persons. The proposed project would result in per service population emissions of 8.2 metric
tons of CO2 per year per service population (MT CO2e/yr/SP), which would exceed the SCAQMD's
plan -level screening threshold of 4.1 MT CO2e/yr/SP.
The development of 413 housing units would result in approximately 1,189 additional residents
based on the estimated 2.88 persons per household53 in Tustin. In addition, the proposed project
would include an additional 39,087 sq ft of restaurant use, 54,328 sq ft of retail and service use, and
25,051 sq ft of office use. Future development, as envisioned under the proposed project would
result in 365 new employees. The total service population (residents plus employees) would be
1,554 persons. The proposed project would result in per service population emissions of 8.2 metric
tons of CO2 per year per service population (MT CO2e/yr/SP), which would exceed the SCAQMD's
plan -level screening threshold of 4.1 MT CO2e/yr/SP.
However, as identified above, before development can occur, once a specific development project is
proposed, it would be required to be analyzed for conformance with the General Plan, zoning
requirements, and other applicable local and State requirements; comply with the requirements of
CEQA; and obtain all necessary clearances and permits. As demonstrated above, the likely scale and
extent of build out associated with future projects would likely exceed the SCAQMD thresholds. As
such, implementation of Mitigation Measure GHG-1 would require a project -specific assessment of
potential GHG impacts and implementation of feasible mitigation measures to reduce GHG
emissions.
Mitigation Measure GHG-1 Prior to discretionary approval by the City of Tustin (City) for
residential development projects subject to California
Environmental Quality Act (CEQA) review, project applicants shall
prepare and submit a technical assessment evaluating potential
project -related greenhouse gas (GHG) impacts to the City for review
and approval. The evaluation shall be prepared in conformance with
South Coast Air Quality Management District (SCAQMD)
methodology. If project -related GHG emissions exceed applicable
SCAQMD thresholds of significance and/or Statewide GHG
reduction targets, the City shall require that applicants for new
development projects incorporate mitigation measures to reduce
GHG emissions. Mitigation measures could include, but are not
limited, to energy efficiency measures, water conservation and
efficiency measures, solid waste measures, and transportation and
motor vehicles measures. The identified measures shall be included
as part of the conditions of approval.
53 State of California, Department of Finance. 2023. E-1 Population Estimates for Cities, Counties and the
State with Annual Percent Change. May.
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While Mitigation Measure GHG-1 would serve to reduce GHG emissions associated with buildout of
the project, GHG emission impacts would remain significant and unavoidable because compliance
with future efficiency targets cannot be assured.
Consistency with Greenhouse Gas Emissions Reduction Plans
An evaluation of the proposed project's consistency with the 2022 Scoping Plan and the 2024-2050
RTP/SCS is provided below.
2022 Scoping Plan
The following discussion evaluates the proposed project according to the goals of the 2022 Scoping
Plan, EO B-30-15, AB 1279, SB 32, and AB 197.
EO B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels
by 2030. CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, to reflect the
2030 target set by EO B-30-15 and codified by SB 32. SB 32 affirms the importance of addressing
climate change by codifying into statute the GHG emissions reductions target of at least 40 percent
below 1990 levels by 2030 contained in EO B-30-15. SB 32 builds on AB 32 and keeps us on the path
toward achieving the State's 2050 objective of reducing emissions to 80 percent below 1990 levels.
The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the
adoption of strategies to reduce GHG emissions. Additional direction in AB 197 intended to provide
easier public access to air emissions data that are collected by CARB was posted in December 2016.
AB 1279 establishes State policy to achieve net zero GHG emissions no later than 2045 and for
Statewide anthropogenic GHG emissions to be reduced to at least 85 percent below 1990 levels by
2045.
In addition, the 2022 Scoping Plan assesses progress toward the statutory 2030 target, while laying
out a path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on
outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy
deployment, natural and working lands, and others, and is designed to meet the State's long-term
climate objectives and support a range of economic, environmental, energy security, environmental
justice, and public health priorities.
The 2022 Scoping Plan focuses on building clean energy production and distribution infrastructure
for a carbon -neutral future, including transitioning existing energy production and transmission
infrastructure to produce zero -carbon electricity and hydrogen, and utilizing biogas resulting from
wildfire management or landfill and dairy operations, among other substitutes. The 2022 Scoping
Plan states that in almost all sectors, electrification will play an important role. The 2022 Scoping
Plan evaluates clean energy and technology options and the transition away from fossil fuels,
including adding four times the solar and wind capacity by 2045 and about 1,700 times the amount
of current hydrogen supply. As discussed in the 2022 Scoping Plan, EO N-79-20 requires that all new
passenger vehicles sold in California will be zero -emission by 2035, and all other fleets will have
transitioned to zero -emission as fully possible by 2045, which will reduce the percentage of fossil
fuel combustion vehicles.
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Energy efficient measures are intended to maximize energy efficiency building and appliance
standards, pursue additional efficiency efforts including new technologies and new policy and
implementation mechanisms, and pursue comparable investment in energy efficiency from all retail
providers of electricity in California. In addition, these measures are designed to expand the use of
green building practices to reduce the carbon footprint of California's new and existing inventory of
buildings. As identified above, buildout of the proposed project would be required to comply with
the latest Title 24 and CALGreen Code standards regarding water efficiency and energy conservation
requirements. Therefore, the proposed project would comply with applicable energy measures.
Water conservation and efficiency measures are intended to continue efficiency programs and use
cleaner energy sources to move and treat water. Increasing the efficiency of water transport and
reducing water use would reduce GHG emissions. As noted above, buildout associated with the
proposed project would be required to comply with the latest Title 24 and CALGreen Code
standards, which include a variety of different measures, including reduction of wastewater and
water use. In addition, the project would be required to comply with the California Model Water
Efficient Landscape Ordinance. Therefore, the proposed project would not conflict with any of the
water conservation and efficiency measures.
The goal of transportation and motor vehicle measures is to develop regional GHG emissions
reduction targets for passenger vehicles. Specific regional emission targets for transportation
emissions would not directly apply to the proposed project. The second phase of Pavley standards
will reduce GHG emissions from new cars by 34 percent from 2016 levels by 2025, resulting in a
3 percent decrease in average vehicle emissions for all vehicles by 2020. Vehicles traveling to the
project site would comply with the Pavley II (LEV III) Advanced Clean Cars Program. Therefore, the
proposed project would not conflict with the identified transportation and motor vehicle measures.
2024-2050 Regional Transportation Plan/Sustainable Communities Strategy
SCAG's 2024-2050 RTP/SCS identifies that land use strategies that focus on new housing and job
growth in areas served by high quality transit and other opportunity areas would be consistent with
a land use development pattern that supports and complements the proposed transportation
network. The core vision in the 2024-2050 RTP/SCS is to better manage the existing transportation
system through design management strategies, integrate land use decisions and technological
advancements, create complete streets that are safe to all roadway users, preserve the
transportation system, and expand transit and foster development in transit oriented communities.
The 2024-2050 RTP/SCS contains transportation projects to help more efficiently distribute
population, housing, and employment growth, as well as forecast development that is generally
consistent with regional -level general plan data. The forecasted development pattern, when
integrated with the financially constrained transportation investments identified in the 2024-2050
RTP/SCS, would reach the GHG emissions reduction target set by CARE, including the regional
target of reducing GHG emissions from autos and light -duty trucks by 19 percent by 2035 (compared
to 2005 levels). The 2024-2050 RTP/SCS does not require that local General Plans, Specific Plans, or
zoning be consistent with the 2024-2050 RTP/SCS but provides incentives for consistency for
governments and developers.
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The objectives of the 2024-2050 RTP/SCS are to create a region with: transit as a backbone of the
transportation system; more Complete Streets where people and safety are prioritized; policies that
encourage emerging technologies and mobility innovations that support rather than hamper
regional goals; more housing, jobs, and mobility options closer together in Priority Development
Areas to preserve natural lands and open spaces; more housing to address the existing housing need
as defined by the RHNA; safe and fluid movement of goods, with a commitment to the broad
deployment of zero- and near -zero emission technologies.
With respect to determining the proposed project's consistency with AQMP growth assumptions,
the projections in the AQMP for achieving air quality goals are based on assumptions in SCAG's
2024-2050 RTP/SCS regarding population, housing, and growth trends. According to SCAG's 2024-
2050 RTP/SCS, in 2019, the City's population was 80,400 residents and the City had 27,000
households and 51,700 jobs. Households are forecast to increase by approximately 6,800
households by 2035 and 7,000 households by 2050 and employment are forecast to increase by
approximately 14,600 jobs by 2035 and 19,600 jobs by 2050.54
As identified in the Project Description, the City's 2021-2029 Housing Element identifies several
adequate sites that are able to accommodate the development of up to additional housing units for
the City to meet its estimated housing growth needs identified in the SCAG's RHNA allocation. Of
the Housing Element inventory sites, Enderle Center (the project site) was identified as necessary for
rezoning under Housing Element Program 1.1f to allow for high density residential/mixed use
development. The proposed project would accommodate up to 413 housing units to help the City
meet its RHNA allocation.
The development of 413 housing units would result in approximately 1,189 additional residents
based on the estimated 2.88 persons per household55 in Tustin. Future development implemented
in accordance with the proposed Housing Overlay Zone would accommodate planned regional
housing growth included in the SCAG RHNA and would be required to adhere to the General Plan.
Therefore, since the purpose of the proposed project is to accommodate planned regional housing
growth included in the SCAG RHNA, the proposed project would not exceed the growth assumptions
in the SCAG's 2024-2050 RTP/SCS or the AQMP. Based on the nature of the proposed project, it is
anticipated that implementation of the proposed project would not interfere with SCAG's ability to
implement the regional strategies outlined in the 2024-2050 RTP/SCS.
Implementing SCAG's 2024-2050 RTP/SCS will greatly reduce the regional GHG emissions from
transportation, helping to achieve statewide emissions reduction targets. The proposed project
would not interfere with SCAG's ability to achieve the region's GHG reduction target of 19 percent
below 2005 per capita emissions levels by 2035. As identified above, the proposed project would
help the City meet its RHNA allocation, which is consistent with SCAG's objectives to provide more
housing in Priority Development Areas to preserve natural lands and open spaces and to address the
54 SCAG. 2024. Connect SoCal2024 Demographics & Growth Forecast. Website:
https:Hscag.ca.gov/sites/ma in/fi Ies/fi le -attach ments/23-2987-tr-demogra ph ics-growth-forecast-fin a I
040424.pdf?1712261839 (accessed May 2024).
55 State of California, Department of Finance, 2023. E-1 Population Estimates for Cities, Counties and the
State with Annual Percent Change. May.
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existing housing need as defined by the RHNA. As such, the proposed project would be consistent
with SCAG's 2024-2050 RTP/SCS.
Although the proposed project would be consistent with the identified measures and goals from the
2022 Scoping Plan and 2024-2050 RTP/SCS, the proposed project would result in a significant and
unavoidable impact for GHG emissions based on SCAQMD thresholds. As such, the proposed project
would not comply with existing State regulations adopted to achieve the overall GHG emissions
reduction goals identified in the 2022 Scoping Plan, EO B-30-15, and AB 197 and would not be
consistent with applicable State plans and programs designed to reduce GHG emissions. Therefore,
the proposed project would conflict with applicable plans, policies, and regulations adopted for the
purpose of reducing the emissions of GHGs.
CUMULATIVE IMPACTS
This section presents information regarding potential cumulative impacts associated with the
proposed project. As defined in the State CEQA Guidelines, cumulative impacts are the incremental
effects of an individual project when viewed in connection with the effects of past, current, and
probable future projects within the cumulative impact area. Below is a list of cumulative projects;
however, because of the lack of available emissions data for the cumulative projects, cumulative
emissions were not evaluated quantitatively. Table R lists the cumulative projects and provides a
brief description and the distances from the project site.
Cumulative Air Quality Impacts
The cumulative impact area for air quality related to the proposed project is the South Coast Air
Basin. Each project in the Basin is required to comply with SCAQMD rules and regulations and is
subject to independent review. Future development that may take place with implementation of the
project would contribute criteria pollutants to the area during project construction and operation.
The Basin is currently designated as a nonattainment area for the federal 03 standard and PM2.5
standard and as a nonattainment area for the State 03, PM1o, and PM2.5 standard. Thus, the Basin
has not met the federal and State standards for these air pollutants. As identified above, a project's
individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a
project's contribution to the cumulative impact is considerable, then the project's impact on air
quality would be considered significant. If a project exceeds the identified significance thresholds, its
emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to
the region's existing air quality conditions.
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Table R: Cumulative Projects List
Distance from
Project
Project Address
Project Description
Project Site
City of Santa Ana Projects
Baja Fish Tacos
2107 17th Street, Santa
Construction of a 5,005-sq ft multi -tenant
2,275 feet
Ana, CA
commercial building.
Tustin Service
2230 Tustin Avenue,
Construction of a service station with six stations
3,330 feet
Station
Santa Ana, CA
and 12 fueling pumps and a 2,150-sq ft
convenience store.
McDonalds Drive-
2101 Santa Clara
Demolition of two residential units and
3,620 feet
Through
Avenue, Santa Ana, CA
construction of a 3,975-sq ft restaurant with drive-
thru.
New ARCO
2301 Seventeenth
Demolition an existing multi -tenant commercial
1,180 feet
AM/PM Service
Street, Santa Ana, CA
building in order to construct a new single- story,
Station
4,000-sq ft service station with a convenience
store to include fast food/retail space and eight
gasoline dispensers. Scope of work to include
underground storage tanks, 33 parking stalls, new
landscaping, and a trash enclosure.
Park Court Office
1801 Parkcourt Place,
Construction of a 3,974 sq ft office building within
4,230 feet
Building
Santa Ana, CA
an existing office park.
Russell Fischer
301 Tustin Avenue, Santa
Demolition of two commercial buildings
3,910 feet
Center
Ana, CA
(approximately 5,100 sq ft) and construction of a
service station with four stations and eight
dispensing pumps, a 2,775-sq ft convenience store,
and a 7,368-sq ft multi -tenant commercial
building.
City of Tustin Projects
Medical Office
17631 17th Street,
Demolition of existing 5,240 SF restaurant building
810 feet
Building
Tustin, CA
to construct a 12,320 SF, two-story medical office.
Jessup by
17802 & 17842 Irvine
Redevelopment of commercial center to construct
3,940 feet
Intracorp
Boulevard, Tustin, CA
40 residential units (36 attached duplexes and 4
single family units).
Source: EPD Solutions, Inc. (February 2024).
Air pollution is inherently a cumulative type of impact measured across an air basin. The Air Quality
Impacts section above includes an analysis of the proposed project's contribution to cumulative air
impacts. As demonstrated above, construction emissions associated with the proposed project
would not exceed the SCAQMD thresholds for VOCs, NOx, CO, SOx, PM2.5, or PM10 emissions.
Additionally, operational impacts from criteria pollutant emissions would also not exceed SCAQMD
thresholds. However, as discussed above, net new emissions associated with the future
development of the proposed project would exceed the SCAQMD LSTs for PM10 during operational
activities. As such, implementation of Mitigation Measure AIR-1 would require a project -specific
assessment of potential localized impacts and if the project exceeds the applicable LST thresholds, a
dispersion modeling analysis would be necessary to calculate health risk from project
implementation. As such, future cumulative growth within the City could result in potential health
risks. Therefore, air quality emissions associated with future development that may occur under the
proposed project would result in cumulatively considerable impact.
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Cumulative Energy Impacts
The geographic area for cumulative analysis of electricity is that of the SCE service area, while the
geographic area for cumulative analysis of natural gas service is that of the SoCalGas service area.
Construction of the additional 413 housing units and remaining commercial buildout capacity
associated with the proposed project would result in an increased services demand in electricity and
natural gas. Although the proposed project would result in an increase in demand for electricity, this
increase would not require SCE to expand or construct infrastructure that could cause substantial
environmental impacts. As discussed previously, total electricity consumption in the SCE service area
in 2022 was 85,870 GWh. By 2030, consumption is anticipated to increase by 12,000 GWh for the
low -demand scenario and by 22,000 GWh for the high -demand scenario.56 While this forecast
represents a large increase in electricity consumption, the proposed project's share of cumulative
consumption would be negligible. The proposed project, in combination with cumulative
development, is well within SCE's system -wide net annual increase in electricity supplies over the
2018 to 2030 period, and there are sufficient planned electricity supplies in the region for estimated
net increases in energy demands.
Similarly, additional natural gas infrastructure is not anticipated due to cumulative development.
Total natural gas consumption in the SoCalGas service area in 2022 was 5,026 million therms.
Between 2018 and 2030, total natural gas consumption in the SoCalGas service area is forecast to
remain steady for the low- and mid -demand scenarios and to increase by approximately 650 million
therms in the high -demand scenario due to intense energy efficiency efforts.57 The proposed
project's share of cumulative consumption of natural gas in the SoCalGas service area would be
negligible. It is anticipated that SoCalGas would be able to meet the natural gas demand of
cumulative development without additional facilities. In addition, both SCE and SoCalGas demand
forecasts include the growth contemplated by the proposed project and the other cumulative
development within their respective service areas. Increased energy efficiency to comply with
building energy efficiency standards would reduce energy consumption on a per -square -foot basis.
Furthermore, utility companies are required to increase their renewable energy sources to meet the
Renewable Portfolio Standards mandate of 60 percent renewable supplies by 2030. SCE and
SoCalGas plan to continue to provide reliable service to their customers and upgrade their
distribution systems as necessary to meet future demand.
Transportation energy use would also increase; however, this transportation energy use would not
represent a major amount of energy use compared to the amount of existing development and to
the total number of vehicle trips and VMT throughout Orange County and the region. The proposed
project and cumulative development are required to comply with various federal and State
government legislation to improve energy efficiency in buildings, equipment, and appliances, and
reduce VMT.
56 CEC. 2018. California Energy Demand, 2018-2030 Revised Forecast. Publication Number: CEC-200-2018-
002-CMF. February. Website: https://efiling.energy.ca.gov/getdocument.aspx?tn=223244 (accessed
February 2024).
57 Ibid.
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project -AQ Report 050124.docx (05/01/24) 70
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT
MAY 2024
ENDE RUE CENTER PROJECT L C A
CITY OF TUSTI N, CALIFORNIA J /`�`
As such, the proposed project would not result in an inefficient, wasteful, and unnecessary
consumption of energy. Therefore, the proposed project's contribution to impacts related to the
inefficient, wasteful, and unnecessary consumption of energy would not be cumulatively
considerable.
Cumulative Greenhouse Gas Impacts
GHG impacts are by their nature cumulative impacts. Localized impacts of climate change are the
result of the cumulative impact of global emissions. The combined benefits of reductions achieved
by all levels of government help to slow or reverse the growth in GHG emissions. In the absence of
comprehensive international agreements on appropriate levels of reductions achieved by each
country, another measure of cumulative contribution is required. This serves to define the State's
share of the reductions regardless of the activities or lack of activities of other areas of the U.S. or
the world. Therefore, a cumulative threshold based on consistency with State targets and actions to
reduce GHGs is an appropriate standard of comparison for significance determinations.
As previously stated, GHG emissions associated with the buildout under the proposed project would
exceed the SCAQMD thresholds of 3,000 MT CO2e/yr and 4.1 MT CO2e/yr/SP. Since GHG is a global
issue, it is unlikely that the proposed project would generate enough GHG emissions to influence
GHG emissions on its own; however, because project -related CO2e emissions would exceed the
SCAQMD's thresholds, the proposed project would have a significant contribution to cumulatively
considerable GHG emission impacts.
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project -AQ Report 050124.docx (05/01/24) 71
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT ENDERLE CENTER PROJECT C A
MAY 2024 CITY OF TUSTIN, CALIFORNIA J A
CONCLUSION
Based on the analysis presented above, construction and operation of the proposed project would
not result in the generation of criteria air pollutants that would exceed SCAQMD thresholds of
significance. Compliance with SCAQMD Rule 403 would further reduce construction dust impacts.
Even with the implementation of Mitigation Measure AIR-1, proposed project has the potential to
produce significant emissions that would affect nearby sensitive receptors. The project would not
result in other emissions (such as those leading to odors) affecting a substantial number of people.
In addition, the proposed project would not result in a potentially significant environmental impact
due to wasteful, inefficient, or unnecessary consumption of energy resources during project
construction or operation and would not conflict with or obstruct a State or local plan for renewable
energy or energy efficiency. Operation of the proposed project would generate GHG emissions that
would have a significant effect on the environment and would therefore not be consistent with the
2024-2050 RTP/SCS or the goals of the 2022 Scoping Plan.
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project -AQ Report 050124.docx (05/01/24) 72
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT
MAY 2024
APPENDIX A
ENDE RUE CENTER PROTECT L S A
CITY OF TUSTI N, CALIFORNIA
CALEEMOD OUTPUT SHEETS
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project - AQ Report 050124.docx (05/01/24)
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Enderle Center -Proposed Project (Construction) Custom Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User -Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
3. Construction Emissions Details
3.1. Demolition (2024) - Unmitigated
3.3. Site Preparation (2024) - Unmitigated
3.5. Grading (2024) - Unmitigated
3.7. Grading (2025) - Unmitigated
3.9. Building Construction (2025) - Unmitigated
3.11. Building Construction (2026) - Unmitigated
1 / 29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
3.13. Paving (2026) - Unmitigated
3.15. Architectural Coating (2025) - Unmitigated
3.17. Architectural Coating (2026) - Unmitigated
4. Operations Emissions Details
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off -Road Equipment
5.2.1. Unmitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
2/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
8. User Changes to Default Data
3/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
1. Basic Project Information
1.1. Basic Project Information
Project Name
Construction Start Date
Lead Agency
Land Use Scale
Analysis Level for Defaults
Windspeed (m/s)
Precipitation (days)
Location
County
City
Air District
Air Basin
TAZ
EDFZ
Electric Utility
Gas Utility
App Version
1.2. Land Use Types
Apartments Mid Rise 413
Dwelling Unit 7.00
Enderle Center - Proposed Project (Construction)
10/7/2024
Project/site
County
2.50
18.6
17350 17th St, Tustin, CA 92780, USA
Orange
Tustin
South Coast AQMD
South Coast
5961
7
Southern California Edison
Southern California Gas
2022.1.1.22
396,480
0.00 —
1,231
4/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
High Turnover (Sit 39.1 1000sgft 2.00 39,087 0.00
Down Restaurant)
Strip Mall 54.3 1000sgft 2.00 54,328 0.00
General Office 25.1 1000sgft 0.80 25,051 0.00
Building
1.3. User -Selected Emission Reduction Measures by Emissions Sector
No measures selected
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - -
Summer
(Max)
Unmit. 36.1 22.2 34.3 0.04 0.70 4.98 5.68 0.66 1.19 1.85
Daily, - - - - - - - -
Winter
(Max)
Unmit. 38.0 48.9 36.4 0.10 1.36 10.3 11.2 1.23 3.99 5.01
Average - - - - - - - - - -
Daily
(Max)
Unmit. 8.35 16.1 23.5 0.03 0.51 3.55 4.06 0.47 0.85 1.32
Annual - - - - - - - - - -
(Max)
Unmit. 1.52 2.94 4.28 < 0.005 0.09 0.65 0.74 0.09 0.16 0.24
2.2. Construction Emissions by Year, Unmitigated
- 8,927
8,927
0.26
0.46
9,094
- 13,428
13,428
0.92
1.60
13,928
- 6,306
6,306
0.19
0.33
6,417
- 1,044
1,044
0.03
0.05
1,062
5/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs
(lb/day for daily, MT/yr for annual)
Daily - - - - - -
-
-
- -
- -
Summer
(Max)
2025 1.88 22.2 34.3 0.04 0.70
4.98
5.68
0.66 1.19
1.85 -
2026 36.1 1.29 4.54 < 0.005 0.07
0.89
0.95
0.06 0.21
0.27 -
Daily -
Winter
(Max)
2024 1.40 48.9 36.4 0.10 1.36
10.3
11.2
1.23 3.99
5.01 -
2025 38.0 48.9 36.3 0.06 1.36
5.86
6.63
1.23 1.49
2.72 -
2026 37.9 23.5 34.8 0.04 0.77
5.86
6.63
0.72 1.40
2.11 -
Average - - - - -
-
-
- -
- -
Daily
2024 0.20 7.18 5.13 0.01 0.19
1.10
1.29
0.17 0.34
0.51 -
2025 3.02 16.1 23.5 0.03 0.51
3.55
4.06
0.47 0.85
1.32 -
2026 8.35 3.50 5.06 0.01 0.12
0.76
0.88
0.12 0.18
0.30 -
Annual - - - - -
-
-
- -
- -
2024 0.04 1.31 0.94 < 0.005 0.04
0.20
0.24
0.03 0.06
0.09 -
2025 0.55 2.94 4.28 < 0.005 0.09
0.65
0.74
0.09 0.16
0.24 -
2026 1.52 0.64 0.92 < 0.005 0.02
0.14
0.16
0.02 0.03
0.05 -
I Construction Emissions Details
3.1. Demolition (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Onsite - - - - -
-
-
- -
- -
6/29
8,927
8,927
0.26
0.46
9,094
1,017
1,017
0.02
0.03
1,030
13,428
13,428
0.92
1.60
13,928
9,700
9,700
0.29
0.49
9,856
9,569
9,569
0.27
0.49
9,724
1,451
1,451
0.08
0.09
1,482
6,306
6,306
0.19
0.33
6,417
1,280
1,280
0.04
0.06
1,300
240
240
0.01
0.02
245
1,044
1,044
0.03
0.05
1,062
212
212
0.01
0.01
215
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Daily,
-
-
-
-
-
-
- -
Summer
(Max)
Daily,
-
-
-
-
-
-
-
-
-
- -
Winter
(Max)
Off -Road
0.72
24.9
18.2
0.03
0.79
-
0.79
0.71
-
0.71 -
Equipment
Demolition
-
-
-
-
-
7.64
7.64
-
1.16
1.16 -
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Average
Daily
Off -Road
0.04
1.37
1.00
< 0.005
0.04
-
0.04
0.04
-
0.04 -
Equipment
Demolition
-
-
-
-
-
0.42
0.42
-
0.06
0.06 -
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Annual
-
-
-
-
-
-
-
-
-
- -
Off -Road
0.01
0.25
0.18
< 0.005
0.01
-
0.01
0.01
-
0.01 -
Equipment
Demolition
-
-
-
-
-
0.08
0.08
-
0.01
0.01 -
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Offsite
Daily,
-
-
-
-
-
-
-
-
-
- -
Summer
(Max)
Daily,
-
-
-
-
-
-
-
-
-
- -
Winter
(Max)
Worker
0.06
0.07
0.78
0.00
0.00
0.20
0.20
0.00
0.05
0.05 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
7/29
3,425
3,425
0.14
0.03
3,437
0.00
0.00
0.00
0.00
0.00
188
188
0.01
< 0.005
188
0.00
0.00
0.00
0.00
0.00
31.1
31.1
< 0.005
< 0.005
31.2
0.00
0.00
0.00
0.00
0.00
193
193
< 0.005
0.01
196
0.00
0.00
0.00
0.00
0.00
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Hauling 0.19 12.6 5.35
0.06 0.12 2.50 2.62 0.12 0.70 0.82
- 9,
Average -
- -
Daily
Worker < 0.005 < 0.005 0.04
0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005
- 1
0
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.
Hauling 0.01 0.70 0.29 < 0.005 0.01 0.14 0.14 0.01 0.04 0.04 - 5
Annual - - - - - - - - - - - -
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 1.
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.
Hauling < 0.005 0.13 0.05 < 0.005 < 0.005 0.02 0.03 < 0.005 0.01 0.01 - 8
9
3.3. Site Preparation (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Onsite - - - -
Daily, - - - -
Summer
(Max)
Daily, - - - - - - - - - - - -
Winter
(Max)
809 9,809 0.78 1.56 10,295
.7 10.7 < 0.005 < 0.005 10.9
00 0.00 0.00 0.00 0.00
37 537 0.04 0.09 564
78 1.78 < 0.005 < 0.005 1.80
00 0.00 0.00 0.00 0.00
.0 89.0 0.01 0.01 93.4
Off -Road 1.07 39.9 28.3 0.05 1.12 - 1.12 1.02 - 1.02 - 5,296 5,296 0.21 0.04 5,314
Equipment
Dust From - - - - - 7.67 7.67 - 3.94 3.94 - - - -
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00
truck
Average - - - - - - - - - - - - - - - -
Daily
8/29
Off -Road 1.07 39.9 28.3 0.05 1.12 - 1.12 1.02 - 1.02 - 5,296 5,296 0.21 0.04 5,314
Equipment
Dust From - - - - - 7.67 7.67 - 3.94 3.94 - - - -
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00
truck
Average - - - - - - - - - - - - - - - -
Daily
8/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Off -Road
0.03
1.09
0.78
< 0.005
0.03
-
0.03
0.03
-
0.03 -
Equipment
Dust From
-
-
-
-
-
0.21
0.21
-
0.11
0.11 -
Material
Movement
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Annual
-
-
-
-
-
-
-
-
-
- -
Off -Road
0.01
0.20
0.14
< 0.005
0.01
-
0.01
0.01
-
0.01 -
Equipment
Dust From
-
-
-
-
-
0.04
0.04
-
0.02
0.02 -
Material
Movement
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Offsite
-
-
-
-
-
-
-
-
-
- -
Daily,
-
-
-
-
-
-
-
-
-
- -
Summer
(Max)
Daily,
-
-
-
-
-
-
-
-
-
- -
Winter
(Max)
Worker
0.06
0.08
0.91
0.00
0.00
0.23
0.23
0.00
0.05
0.05 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Average
-
-
-
-
-
-
-
-
-
- -
Daily
Worker
< 0.005
< 0.005
0.03
0.00
0.00
0.01
0.01
0.00
< 0.005
< 0.005 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Annual
-
-
-
-
-
-
-
-
-
- -
Worker
< 0.005
< 0.005
< 0.005
0.00
0.00
< 0.005
< 0.005
0.00
< 0.005
< 0.005 -
9/29
145 145 0.01 < 0.005 146
0.00
0.00
0.00
0.00
0.00
24.0
24.0
< 0.005
< 0.005
24.1
0.00 0.00 0.00 0.00 0.00
226
226
< 0.005
0.01
228
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
6.27
6.27
< 0.005
< 0.005
6.35
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.04
1.04
< 0.005
< 0.005
1.05
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Vendor 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
Hauling 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
3.5. Grading (2024)
- Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily,
MT/yr for annual)
Onsite - -
- - -
- - -
- -
- -
-
-
-
-
Daily, - -
- - -
- - -
- -
- -
-
-
-
-
Summer
(Max)
Daily,
Winter
(Max)
Off -Road 1.33 48.8
35.3 0.06 1.36
- 1.36 1.23
- 1.23
- 6,598
6,598
0.27
0.05
6,621
Equipment
Dust From - -
- - -
3.59 3.59 -
1.42 1.42
- -
-
-
-
-
Material
Movement
Onsite 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
truck
Average - -
- - -
- - -
- -
- -
-
-
-
-
Daily
Off -Road 0.11 4.01
2.91 0.01 0.11
- 0.11 0.10
- 0.10
- 542
542
0.02
< 0.005
544
Equipment
Dust From - -
- - -
0.30 0.30 -
0.12 0.12
- -
-
-
-
-
Material
Movement
Onsite 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
truck
Annual - -
- - -
- - -
- -
- -
-
-
-
-
Off -Road 0.02 0.73
0.53 < 0.005 0.02
- 0.02 0.02
- 0.02
- 89.8
89.8
< 0.005
< 0.005
90.1
Equipment
10/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Dust From - -
- -
-
0.05
0.05
- 0.02 0.02
- -
-
-
Material
Movement
Onsite 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00 0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
truck
Offsite - -
- -
-
-
-
- - -
- -
-
-
-
-
Daily, - -
- -
-
-
-
- - -
- -
-
-
-
-
Summer
(Max)
Daily, - -
-
- - -
- -
-
-
Winter
(Max)
Worker 0.07 0.09
1.04 0.00
0.00
0.26
0.26
0.00 0.06 0.06
- 258
258
< 0.005
0.01
261
Vendor 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00 0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
Hauling 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00 0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
Average - -
- -
-
-
-
- - -
- -
-
-
-
-
Daily
Worker 0.01 0.01
0.09 0.00
0.00
0.02
0.02
0.00 < 0.005 < 0.005
- 21.5
21.5
< 0.005
< 0.005
21.8
Vendor 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00 0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
Hauling 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00 0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
Annual - -
- -
-
-
-
- - -
- -
-
-
-
-
Worker < 0.005 < 0.005
0.02 0.00
0.00
< 0.005
< 0.005
0.00 < 0.005 < 0.005
- 3.56
3.56
< 0.005
< 0.005
3.61
Vendor 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00 0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
Hauling 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00 0.00 0.00
- 0.00
0.00
0.00
0.00
0.00
3.7. Grading (2025) -
Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Onsite - -
- -
-
-
-
- - -
- -
-
-
-
-
11 / 29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Daily,
-
-
-
-
-
- -
Summer
(Max)
Daily,
-
-
-
-
-
-
-
-
-
- -
Winter
(Max)
Off -Road
1.33
48.8
35.3
0.06
1.36
-
1.36
1.23
-
1.23 -
Equipment
Dust From
-
-
-
-
-
3.59
3.59
-
1.42
1.42 -
Material
Movement
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Average
-
-
-
-
-
-
-
-
-
- -
Daily
Off -Road
< 0.005
0.10
0.07
< 0.005
< 0.005
-
< 0.005
< 0.005
-
< 0.005 -
Equipment
Dust From
-
-
0.01
0.01
-
< 0.005
< 0.005 -
Material
Movement
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Annual
-
-
-
-
-
-
-
-
-
- -
Off -Road
< 0.005
0.02
0.01
< 0.005
< 0.005
-
< 0.005
< 0.005
-
< 0.005 -
Equipment
Dust From
-
-
-
-
-
< 0.005
< 0.005
-
< 0.005
< 0.005 -
Material
Movement
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Offsite
-
-
-
-
-
-
-
-
-
- -
Daily,
-
-
-
-
-
-
-
-
-
- -
Summer
(Max)
6,599 6,599 0.27 0.05 6,622
0.00
0.00
0.00
0.00
0.00
12.9
12.9
< 0.005
< 0.005
13.0
0.00
0.00
0.00
0.00
0.00
2.14
2.14
< 0.005
< 0.005
2.15
0.00 0.00 0.00 0.00 0.00
12/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Daily,
Winter
(Max)
Worker
0.07
0.08
0.97
0.00
0.00
0.26
0.26
0.00
0.06
0.06 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Average
-
-
-
-
-
-
-
-
-
- -
Daily
Worker
< 0.005
< 0.005
< 0.005
0.00
0.00
< 0.005
< 0.005
0.00
< 0.005
< 0.005 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Annual
-
-
-
-
-
-
-
-
-
- -
Worker
< 0.005
< 0.005
< 0.005
0.00
0.00
< 0.005
< 0.005
0.00
< 0.005
< 0.005 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
3.9. Building Construction (2025) - Unmitigated
253
253
< 0.005
0.01
256
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.50
0.50
< 0.005
< 0.005
0.51
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.08
0.08
< 0.005
< 0.005
0.08
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Onsite - - - - - - - - - - - - - -
Daily, - - - - - - - - - - - - -
Summer
(Max)
Off -Road 0.62 18.9 14.3 0.02 0.69 - 0.69 0.64 - 0.64 -
Equipment
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 -
truck
Daily, - - - - - - - - - - -
Winter
(Max)
2,398
2,398
0.10
0.02
2,406
0.00
0.00
0.00
0.00
0.00
13/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Off -Road
0.62
18.9
14.3
0.02
0.69
-
0.69
0.64
-
0.64 -
Equipment
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Average
-
-
-
-
-
-
-
-
-
- -
Daily
Off -Road
0.44
13.4
10.2
0.02
0.49
-
0.49
0.46
-
0.46 -
Equipment
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Annual
-
-
-
-
-
-
-
- -
Off -Road
0.08
2.45
1.86
< 0.005
0.09
-
0.09
0.08
-
0.08 -
Equipment
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Offsite
-
-
-
-
-
-
-
-
-
- -
Daily,
-
-
-
-
-
-
-
-
-
- -
Summer
(Max)
Worker
1.20
1.18
19.0
0.00
0.00
4.43
4.43
0.00
1.04
1.04 -
Vendor
0.06
2.11
1.05
0.01
0.01
0.54
0.56
0.01
0.15
0.16 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Daily,
-
-
-
-
-
-
-
-
-
- -
Winter
(Max)
Worker
1.20
1.34
16.4
0.00
0.00
4.43
4.43
0.00
1.04
1.04 -
Vendor
0.05
2.19
1.07
0.01
0.01
0.54
0.56
0.01
0.15
0.16 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Average
-
-
-
-
-
-
-
-
-
- -
Daily
Worker
0.84
0.95
12.2
0.00
0.00
3.12
3.12
0.00
0.73
0.73 -
Vendor
0.04
1.57
0.76
0.01
0.01
0.38
0.39
0.01
0.11
0.12 -
14/29
2,398
2,398
0.10
0.02
2,406
0.00
0.00
0.00
0.00
0.00
1,708
1,708
0.07
0.01
1,714
0.00
0.00
0.00
0.00
0.00
283
283
0.01
< 0.005
284
0.00
0.00
0.00
0.00
0.00
4,503
4,503
0.05
0.16
4,569
2,027
2,027
0.11
0.28
2,119
0.00
0.00
0.00
0.00
0.00
4,285
4,285
0.06
0.16
4,334
2,028
2,028
0.11
0.28
2,114
0.00
0.00
0.00
0.00
0.00
3,094
3,094
0.04
0.11
3,134
1,444
1,444
0.08
0.20
1,507
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Hauling 0.00 0.00 0.00
0.00 0.00 0.00
0.00
0.00
0.00
0.00 -
Annual - - -
- - -
-
-
-
- -
Worker 0.15 0.17 2.23
0.00 0.00 0.57
0.57
0.00
0.13
0.13 -
Vendor 0.01 0.29 0.14
< 0.005 < 0.005 0.07
0.07
< 0.005
0.02
0.02 -
Hauling 0.00 0.00 0.00
0.00 0.00 0.00
0.00
0.00
0.00
0.00 -
3.11. Building Construction (2026)
- Unmitigated
Criteria Pollutants (lb/day for daily,
ton/yr for annual) and GHGs
(lb/day for daily, MT/yr for annual)
Onsite - - -
- - -
-
-
-
- -
Daily, - - -
- - -
-
-
-
- -
Summer
(Max)
Daily, - - -
- - -
-
-
-
- -
Winter
(Max)
Off -Road 0.62 18.9 14.3
0.02 0.69 -
0.69
0.64
-
0.64 -
Equipment
Onsite 0.00 0.00 0.00
0.00 0.00 0.00
0.00
0.00
0.00
0.00 -
truck
Average - - -
- - -
-
-
-
- -
Daily
Off -Road 0.07 2.11 1.60
< 0.005 0.08 -
0.08
0.07
-
0.07 -
Equipment
Onsite 0.00 0.00 0.00
0.00 0.00 0.00
0.00
0.00
0.00
0.00 -
truck
Annual - - -
- - -
-
-
-
- -
Off -Road 0.01 0.38 0.29
< 0.005 0.01 -
0.01
0.01
-
0.01 -
Equipment
Onsite 0.00 0.00 0.00
0.00 0.00 0.00
0.00
0.00
0.00
0.00 -
truck
15/29
0.00
0.00
0.00
0.00
0.00
512
512
0.01
0.02
519
239
239
0.01
0.03
250
0.00
0.00
0.00
0.00
0.00
2,397
2,397
0.10
0.02
2,405
0.00
0.00
0.00
0.00
0.00
267
267
0.01
< 0.005
268
0.00
0.00
0.00
0.00
0.00
44.3
44.3
< 0.005
< 0.005
44.4
0.00
0.00
0.00
0.00
0.00
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Offsite - -
- -
Daily, - -
- -
Summer
(Max)
Daily, -
-
-
-
-
- -
Winter
(Max)
Worker 1.14 1.19
15.4 0.00
0.00
4.43
4.43
0.00
1.04
1.04 -
Vendor 0.04 2.11
1.04 0.01
0.01
0.54
0.56
0.01
0.15
0.16 -
Hauling 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Average - -
- -
-
-
-
-
-
- -
Daily
Worker 0.13 0.13
1.79 0.00
0.00
0.49
0.49
0.00
0.11
0.11 -
Vendor < 0.005 0.24
0.11 < 0.005
< 0.005
0.06
0.06
< 0.005
0.02
0.02 -
Hauling 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Annual - -
- -
-
-
- -
Worker 0.02 0.02
0.33 0.00
0.00
0.09
0.09
0.00
0.02
0.02 -
Vendor < 0.005 0.04
0.02 < 0.005
< 0.005
0.01
0.01
< 0.005
< 0.005
< 0.005 -
Hauling 0.00 0.00
0.00 0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
3.13. Paving (2026)
- Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Onsite - -
- -
-
-
-
-
-
- -
Daily, - -
- -
-
-
-
-
-
- -
Summer
(Max)
Daily, - -
- -
-
-
-
-
-
- -
Winter
(Max)
4,203
4,203
0.06
0.16
4,253
1,995
1,995
0.10
0.28
2,081
0.00
0.00
0.00
0.00
0.00
475
475
0.01
0.02
482
222
222
0.01
0.03
232
0.00
0.00
0.00
0.00
0.00
78.7
78.7
< 0.005
< 0.005
79.7
36.8
36.8
< 0.005
0.01
38.5
0.00
0.00
0.00
0.00
0.00
16/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Off -Road
0.50
13.3
10.6
0.01
0.58
-
0.58
0.54
-
0.54 -
Equipment
Paving
0.00
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Average
-
-
-
-
-
-
-
-
-
- -
Daily
Off -Road
0.03
0.73
0.58
< 0.005
0.03
-
0.03
0.03
-
0.03 -
Equipment
Paving
0.00
-
-
-
-
-
-
-
-
- -
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Annual
-
-
-
- -
Off -Road
0.01
0.13
0.11
< 0.005
0.01
-
0.01
0.01
-
0.01 -
Equipment
Paving
0.00
-
-
-
-
-
-
-
-
- -
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Offsite
-
-
-
-
-
-
-
-
-
- -
Daily,
-
-
-
-
-
-
-
-
-
- -
Summer
(Max)
Daily,
-
-
-
-
-
-
-
-
-
- -
Winter
(Max)
Worker
0.05
0.05
0.68
0.00
0.00
0.20
0.20
0.00
0.05
0.05 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Average
-
-
-
-
-
-
-
-
-
- -
Daily
Worker
< 0.005
< 0.005
0.04
0.00
0.00
0.01
0.01
0.00
< 0.005
< 0.005 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
17/29
1,511
1,511
0.06
0.01
1,516
0.00
0.00
0.00
0.00
0.00
82.8
82.8
< 0.005
< 0.005
83.1
0.00
0.00
0.00
0.00
0.00
13.7
13.7
< 0.005
< 0.005
13.8
0.00
0.00
0.00
0.00
0.00
186
186
< 0.005
0.01
188
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
10.3
10.3
< 0.005
< 0.005
10.5
0.00
0.00
0.00
0.00
0.00
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00
Annual - - - - - - - - - - - - - -
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 1.71 1.71 < 0.005 < 0.005 1.73
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00
3.15. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) �I
Onsite - - - - - - - - - - - - - - - -
Dail - - - - - - - - - - - - - - - -
Y,
Summer
(Max)
Daily,
Winter
(Max)
Off -Road
0.05
1.09
0.96
< 0.005
0.07 -
0.07
0.06 -
0.06 -
Equipment
Architectu
35.8
-
-
-
- -
-
- -
- -
ral
Coatings
Onsite
0.00
0.00
0.00
0.00
0.00 0.00
0.00
0.00 0.00
0.00 -
truck
Average
-
-
-
-
- -
-
- -
- -
Daily
Off -Road
< 0.005
0.05
0.05
< 0.005
< 0.005 -
< 0.005
< 0.005 -
< 0.005 -
Equipment
Architectu
1.68
-
-
-
- -
-
- -
- -
ral
Coatings
Onsite
0.00
0.00
0.00
0.00
0.00 0.00
0.00
0.00 0.00
0.00 -
truck
18/29
134 134 0.01 < 0.005 134
0.00
0.00
0.00
0.00
0.00
6.27
6.27
< 0.005
< 0.005
6.29
0.00
0.00
0.00
0.00
0.00
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Annual
-
-
-
-
- -
-
-
-
Off -Road
< 0.005
0.01
0.01
< 0.005
< 0.005
-
< 0.005
< 0.005
-
< 0.005 -
1.04
1.04
< 0.005
< 0.005
1.04
Equipment
Architectu
0.31
ral
Coatings
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00
0.00
0.00
0.00
truck
Offsite
-
-
-
-
-
-
-
-
-
- -
-
-
-
-
-
Daily,
-
-
-
-
-
-
-
-
-
- -
-
-
-
-
-
Summer
(Max)
Daily,
Winter
(Max)
Worker
0.24
0.27
3.28
0.00
0.00
0.89
0.89
0.00
0.21
0.21 -
857
857
0.01
0.03
867
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00
0.00
0.00
0.00
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00
0.00
0.00
0.00
Average
-
-
-
-
-
-
-
-
-
- -
-
-
-
-
-
Daily
Worker
0.01
0.01
0.16
0.00
0.00
0.04
0.04
0.00
0.01
0.01 -
40.8
40.8
< 0.005
< 0.005
41.3
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00
0.00
0.00
0.00
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00
0.00
0.00
0.00
Annual
-
-
-
-
-
-
-
-
-
- -
-
-
-
-
-
Worker
< 0.005
< 0.005
0.03
0.00
0.00
0.01
0.01
0.00
< 0.005
< 0.005 -
6.75
6.75
< 0.005
< 0.005
6.84
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00
0.00
0.00
0.00
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00
0.00
0.00
0.00
3.17. Architectural Coating (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
19/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Location ROG NOx CO S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 CO2e
•
Summer
(Max)
Off -Road
0.05
1.09
0.96
< 0.005
0.07 -
0.07
0.06 -
0.06 -
Equipment
Architectu
35.8
-
-
-
- -
-
- -
- -
ral
Coatings
Onsite
0.00
0.00
0.00
0.00
0.00 0.00
0.00
0.00 0.00
0.00 -
truck
Daily,
-
-
- -
-
- -
-
Winter
(Max)
Off -Road
0.05
1.09
0.96
< 0.005
0.07 -
0.07
0.06 -
0.06 -
Equipment
Architectu
35.8
-
-
-
- -
-
- -
- -
ral
Coatings
Onsite
0.00
0.00
0.00
0.00
0.00 0.00
0.00
0.00 0.00
0.00 -
truck
Average
Daily
Off -Road
0.01
0.24
0.22
< 0.005
0.01 -
0.01
0.01 -
0.01 -
Equipment
Architectu
8.06
-
-
-
- -
-
- -
- -
ral
Coatings
Onsite
0.00
0.00
0.00
0.00
0.00 0.00
0.00
0.00 0.00
0.00 -
truck
Annual
Off -Road
< 0.005
0.04
0.04
< 0.005
< 0.005 -
< 0.005
< 0.005 -
< 0.005 -
Equipment
20 / 29
134 134 0.01 < 0.005 134
0.00 0.00 0.00 0.00 0.00
134 134 0.01 < 0.005 134
0.00
0.00
0.00
0.00
0.00
30.0
30.0
< 0.005
< 0.005
30.1
0.00
0.00
0.00
0.00
0.00
4.97
4.97
< 0.005
< 0.005
4.99
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Architectu 1.47
Coatings
Onsite
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
truck
Offsite
-
-
-
-
-
-
-
-
-
- -
Daily,
-
-
-
-
-
-
-
-
-
- -
Summer
(Max)
Worker
0.23
0.21
3.58
0.00
0.00
0.89
0.89
0.00
0.21
0.21 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Daily,
-
-
-
-
-
-
-
-
-
- -
Winter
(Max)
Worker
0.23
0.24
3.08
0.00
0.00
0.89
0.89
0.00
0.21
0.21 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Average
-
-
-
-
-
-
-
-
-
- -
Daily
Worker
0.05
0.05
0.72
0.00
0.00
0.20
0.20
0.00
0.05
0.05 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Annual
-
-
-
-
-
-
-
-
-
- -
Worker
0.01
0.01
0.13
0.00
0.00
0.04
0.04
0.00
0.01
0.01 -
Vendor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Hauling
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
4. Operations Emissions Details
4.10. Soil Carbon Accumulation By Vegetation Type
0.00 0.00 0.00 0.00 0.00
883
883
0.01
0.03
896
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
841
841
0.01
0.03
851
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
192
192
< 0.005
0.01
194
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
31.8
31.8
< 0.005
< 0.005
32.2
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
21 / 29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Total— — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Total— — — — — — — — — — — — — — — —
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
22/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Sequester — — — — — — — — — — — — — — — —
ed
Subtotal — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — -
- - - - - - - - - - - - - - - - -
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Avoided — — — — —
Subtotal — — — — —
Sequester — — — — —
ed
Subtotal
Removed
Subtotal
Annual
Avoided
Subtotal — — —
Sequester — — — — — — — — — —
ed
Subtotal — — — — — — — — — —
Removed — — — — — — — — — —
23 / 29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Subtotal - - -
5. Activity Data
5.1. Construction Schedule
Demolition
Demolition
10/7/2024
11 /4/2024
5.00
20.0
-
Site Preparation
Site Preparation
11/5/2024
11/19/2024
5.00
10.0
-
Grading
Grading
11 /20/2024
1 /1 /2025
5.00
30.0
-
Building Construction
Building Construction
1/2/2025
2/26/2026
5.00
300
-
Paving
Paving
2/27/2026
3/27/2026
5.00
20.0
-
Architectural Coating
Architectural Coating
12/8/2025
4/25/2026
5.00
100
-
5.2. Off -Road Equipment
5.2.1. Unmitigated
Equipment Type
Number per
Day
Hours Per
Day
Horsepower
Demolition
Concrete/Industrial
Diesel
Tier 2
1.00
8.00
33.0 0.73
Saws
Demolition
Excavators
Diesel
Tier 2
3.00
8.00
36.0 0.38
Demolition
Rubber Tired Dozers
Diesel
Tier 2
2.00
8.00
367 0.40
Site Preparation
Rubber Tired Dozers
Diesel
Tier 2
3.00
8.00
367 0.40
Site Preparation
Tractors/Loaders/Backh
Diesel
Tier 2
4.00
8.00
84.0 0.37
oes
Grading
Excavators
Diesel
Tier 2
2.00
8.00
36.0 0.38
Grading
Graders
Diesel
Tier 2
1.00
8.00
148 0.41
24/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Grading
Rubber Tired Dozers
Diesel
Tier 2
1.00
8.00
367
0.40
Grading
Scrapers
Diesel
Tier 2
2.00
8.00
423
0.48
Grading
Tractors/Loaders/Backh
Diesel
Tier 2
2.00
8.00
84.0
0.37
oes
Building Construction
Cranes
Diesel
Tier 2
1.00
7.00
367
0.29
Building Construction
Forklifts
Diesel
Tier 2
3.00
8.00
82.0
0.20
Building Construction
Generator Sets
Diesel
Tier 2
1.00
8.00
14.0
0.74
Building Construction
Tractors/Loaders/Backh
Diesel
Tier 2
3.00
7.00
84.0
0.37
oes
Building Construction
Welders
Diesel
Tier 2
1.00
8.00
46.0
0.45
Paving
Pavers
Diesel
Tier 2
2.00
8.00
81.0
0.42
Paving
Paving Equipment
Diesel
Tier 2
2.00
8.00
89.0
0.36
Paving
Rollers
Diesel
Tier 2
2.00
8.00
36.0
0.38
Architectural Coating
Air Compressors
Diesel
Tier 2
1.00
6.00
37.0
0.48
5.3. Construction Vehicles
5.3.1. Unmitigated
One -Way Trips
per Day
Demolition
-
-
-
-
Demolition
Worker
15.0
18.5
LDA,LDT1,LDT2
Demolition
Vendor
-
10.2
HHDT,MHDT
Demolition
Hauling
138
20.0
HHDT
Demolition
Onsite truck
-
-
HHDT
Site Preparation
-
-
-
Site Preparation
Worker
17.5
18.5
LDA,LDT1,LDT2
Site Preparation
Vendor
-
10.2
HHDT,MHDT
Site Preparation
Hauling
0.00
20.0
HHDT
25 / 29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Site Preparation
Onsite truck
—
—
HHDT
Grading
—
—
—
—
Grading
Worker
20.0
18.5
LDA,LDT1,LDT2
Grading
Vendor
—
10.2
HHDT,MHDT
Grading
Hauling
0.00
20.0
HHDT
Grading
Onsite truck
—
—
HHDT
Building Construction
—
—
—
—
Building Construction
Worker
339
18.5
LDA,LDT1,LDT2
Building Construction
Vendor
63.6
10.2
HHDT,MHDT
Building Construction
Hauling
0.00
20.0
HHDT
Building Construction
Onsite truck
—
—
HHDT
Paving
—
—
—
—
Paving
Worker
15.0
18.5
LDA,LDT1,LDT2
Paving
Vendor
—
10.2
HHDT,MHDT
Paving
Hauling
0.00
20.0
HHDT
Paving
Onsite truck
—
—
HHDT
Architectural Coating
—
—
—
—
Architectural Coating
Worker
67.8
18.5
LDA,LDT1,LDT2
Architectural Coating
Vendor
—
10.2
HHDT,MHDT
Architectural Coating
Hauling
0.00
20.0
HHDT
Architectural Coating
Onsite truck
—
—
HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Water unpaved roads twice daily
55%
55%
26/29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Limit vehicle speeds on unpaved roads to 25 mph
Sweep paved roads once per month
5.5. Architectural Coatings
Architectural Coating 802,872
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
44%
9%
267,624
177,699
44%
9%
59,233
Demolition 0.00
0.00
0.00
11,054
Site Preparation —
—
15.0
0.00 —
Grading —
—
90.0
0.00 —
Paving 0.00
0.00
0.00
0.00 0.00
5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per
day)
PM10 Reduction
Water Exposed Area 2
61 %
61 %
Water Demolished Area 2
36%
36%
5.7. Construction Paving
PavedArea
Apartments Mid Rise
—
0%
High Turnover (Sit Down Restaurant)
0.00
0%
27 / 29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
Strip Mall 0.00
General Office Building 0.00
5.8. Construction Electricity Consumption and Emissions Factors
kWh per Year and Emission Factor (Ib/MWh)
0%
0%
2024
0.00
532
0.03
< 0.005
2025
0.00
532
0.03
< 0.005
2026
0.00
532
0.03
< 0.005
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
28 / 29
Enderle Center - Proposed Project (Construction) Custom Report, 3/29/2024
8. User Changes to Default Data
Land Use
Operations: Vehicle Data
Operations: Hearths
Construction: Construction Phases
The project site is approximately 11.80 acres.
The proposed project would generate approximately 18,528 average daily trips.
Assuming no wood burning hearths.
Project construction could occur anytime between October 2024 and October 2029. Therefore, to be
conservative, this analysis assumes a project construction schedule based on a start date of October
2024 and a default construction duration in CalEEMod and assuming architectural coating would
overlap with building construction activities.
Construction: Off -Road Equipment Assuming the use of Tier 2 construction equipment.
29 / 29
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Enderle Center -Proposed Project (Operational) Custom Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User -Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
2.6. Operations Emissions by Sector, Mitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.1.2. Mitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
4.2.2. Electricity Emissions By Land Use - Mitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.2.4. Natural Gas Emissions By Land Use - Mitigated
4.3. Area Emissions by Source
4.3.1. Unmitigated
4.3.2. Mitigated
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.4.2. Mitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.5.2. Mitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.6.2. Mitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
4.7.2. Mitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.8.2. Mitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.9.2. Mitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated
5. Activity Data
5.9. Operational Mobile Sources
5.9.1. Unmitigated
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
5.9.2. Mitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.1.2. Mitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.10.4. Landscape Equipment - Mitigated
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.11.2. Mitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.12.2. Mitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.13.2. Mitigated
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.14.2. Mitigated
5.15. Operational Off -Road Equipment
5.15.1. Unmitigated
5.15.2. Mitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
5.18.2. Sequestration
5.18.2.1. Unmitigated
5.18.2.2. Mitigated
8. User Changes to Default Data
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
1. Basic Project Information
1.1. Basic Project Information
Project Name
Operational Year
Lead Agency
Land Use Scale
Analysis Level for Defaults
Windspeed (m/s)
Precipitation (days)
Location
County
City
Air District
Air Basin
TAZ
EDFZ
Electric Utility
Gas Utility
App Version
1.2. Land Use Types
Apartments Mid Rise 413
Dwelling Unit 7.00
Enderle Center - Proposed Project (Operational)
2024
Project/site
County
2.50
18.6
17350 17th St, Tustin, CA 92780, USA
Orange
Tustin
South Coast AQMD
South Coast
5961
7
Southern California Edison
Southern California Gas
2022.1.1.22
396,480
0.00 —
1,231
7/47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
High Turnover (Sit 67.8 1000sgft 2.00 67,837 0.00
Down Restaurant)
Strip Mall 94.3 1000sgft 2.00 94,288 0.00
General Office 43.5 1000sgft 0.80 43,477 0.00
Building
1.3. User -Selected Emission Reduction Measures by Emissions Sector
Transportation
T-5
Transportation
T-14*
Transportation
T-31-A*
Transportation
T-34*
Transportation
T-43*
Energy
E-1
Energy
E-2
Energy
E-12-13
Energy
E-13
Energy
E-15
Water
W-4
Water
W-5
Area Sources
LL-1
Area Sources AS-2
* Qualitative or supporting measure. Emission reductions not included in the mitigated emissions results.
2. Emissions Summary
Implement Commute Trip Reduction Program (Voluntary)
Provide Electric Vehicle Charging Infrastructure
Locate Project in Area with High Destination Accessibility
Provide Bike Parking
Provide Real -Time Transit Information
Buildings Exceed 2019 Title 24 Building Envelope Energy
Efficiency Standards
Require Energy Efficient Appliances
Install Electric Space Heater in Place of Natural Gas Heaters in
Residences
Install Electric Ranges in Place of Gas Ranges
Require All -Electric Development
Require Low -Flow Water Fixtures
Design Water -Efficient Landscapes
Replace Gas Powered Landscape Equipment with Zero -Emission
Landscape Equipment
Use Low-VOC Paints
8/47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day
for daily,
ton/yr for annual)
and GHGs(lb/day for daily,
MT/yr for annual
Daily,
-
-
-
-
-
-
-
-
-
-
Summer
(Max)
Unmit.
80.6
56.1
549
1.29
1.56
111
113
1.50
28.3
29.8
Mit.
75.6
53.8
507
1.26
1.42
109
111
1.37
27.8
29.1
%
6%
4%
8%
2%
9%
2%
2%
9%
2%
2%
Reduced
Daily,
-
-
-
-
-
-
-
-
-
-
Winter
(Max)
Unmit.
76.3
59.9
483
1.24
1.53
111
113
1.48
28.3
29.7
Mit.
74.9
57.8
474
1.21
1.42
109
111
1.37
27.8
29.1
%
2%
3%
2%
2%
7%
2%
2%
7%
2%
2%
Reduced
Average
-
-
-
-
-
-
-
-
-
-
Daily
(Max)
Unmit.
76.0
49.0
453
1.02
1.00
91.6
92.6
0.95
23.3
24.2
Mit.
72.2
46.8
423
1.00
0.87
90.1
91.0
0.82
22.9
23.7
%
5%
4%
7%
2%
13%
2%
2%
13%
2%
2%
Reduced
Annual
-
-
-
-
-
-
-
-
-
-
(Max)
Unmit.
13.9
8.94
82.7
0.19
0.18
16.7
16.9
0.17
4.25
4.42
Mit.
13.2
8.55
77.3
0.18
0.16
16.4
16.6
0.15
4.18
4.33
%
5%
4%
7%
2%
13%
2%
2%
13%
2%
2%
Reduced
772
145,839
146,611
84.5
5.21
150,898
760
140,879
141,639
82.9
5.09
145,841
2%
3%
3%
2%
2%
3%
772
140,886
141,658
84.7
5.45
145,524
760
136,083
136,843
83.2
5.32
140,631
2%
3%
3%
2%
2%
3%
772
115,618
116,390
84.0
4.82
120,221
760
111,122
111,882
82.5
4.70
115,637
2%
4%
4%
2%
2%
4%
128
19,142
19,270
13.9
0.80
19,904
126
18,397
18,523
13.7
0.78
19,145
2%
4%
4%
2%
2%
4%
9/47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day
for daily,
ton/yr for annual)
and GHGs(lb/day for daily, MT/yr for annual
Daily,
-
-
-
-
-
- -
- -
-
Summer
(Max)
Mobile
62.4
46.3
512
1.23
0.77
111 112
0.72 28.3
29.0
Area
18.0
6.13
34.8
0.04
0.50
- 0.50
0.49 -
0.49
Energy
0.21
3.70
2.63
0.02
0.29
- 0.29
0.29 -
0.29
Water
Waste
Refrig.
-
-
-
-
-
- -
- -
-
Total
80.6
56.1
549
1.29
1.56
111 113
1.50 28.3
29.8
Daily,
-
-
-
-
-
- -
- -
-
Winter
(Max)
Mobile
61.7
50.4
478
1.18
0.77
111 112
0.72 28.3
29.0
Area
14.4
5.82
2.48
0.04
0.47
- 0.47
0.47 -
0.47
Energy
0.21
3.70
2.63
0.02
0.29
- 0.29
0.29 -
0.29
Water
-
-
-
-
-
- -
- -
-
Waste
-
-
-
-
-
- -
- -
-
Refrig.
-
-
-
-
-
- -
- -
-
Total
76.3
59.9
483
1.24
1.53
111 113
1.48 28.3
29.7
Average
-
-
-
-
-
- -
- -
-
Daily
Mobile
59.2
44.7
428
1.00
0.66
91.6 92.3
0.61 23.3
23.9
Area
16.6
0.61
22.3
< 0.005
0.05
- 0.05
0.05 -
0.05
Energy
0.21
3.70
2.63
0.02
0.29
- 0.29
0.29 -
0.29
Water
-
-
-
-
-
- -
10/47
-
125,227
125,227
5.96
4.89
127,345
0.00
7,491
7,491
0.14
0.01
7,499
-
12,617
12,617
0.90
0.07
12,660
97.3
504
601
10.0
0.24
923
675
0.00
675
67.4
0.00
2,361
-
-
-
-
-
110
772
145,839
146,611
84.5
5.21
150,898
0.00
97.3
675
772
0.00
97.3
120,373
120,373
6.24
7,392
7,392
0.14
12,617
12,617
0.90
504
601
10.0
0.00
675
67.4
140,886
141,658
84.7
101,923
101,923
5.66
574
574
0.01
12,617
12,617
0.90
504
601
10.0
5.13
122,071
0.01
7,399
0.07
12,660
0.24
923
0.00
2,361
-
110
5.45
145,524
4.51
103,592
< 0.005
575
0.07
12,660
0.24
923
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Waste
-
-
-
-
-
675
0.00
675
67.4
0.00
2,361
Refrig.
- -
-
- -
-
-
-
-
-
110
Total
76.0
49.0
453
1.02
1.00
91.6 92.6
0.95
23.3 24.2
772
115,618
116,390
84.0
4.82
120,221
Annual
-
-
-
-
-
- -
-
-
-
-
-
-
Mobile
10.8
8.16
78.2
0.18
0.12
16.7 16.8
0.11
4.25 4.36
-
16,874
16,874
0.94
0.75
17,151
Area
3.03
0.11
4.07
< 0.005
0.01
- 0.01
0.01
- 0.01
0.00
95.1
95.1
< 0.005
< 0.005
95.2
Energy
0.04
0.68
0.48
< 0.005
0.05
- 0.05
0.05
- 0.05
-
2,089
2,089
0.15
0.01
2,096
Water
-
-
-
- -
-
- -
16.1
83.4
99.6
1.66
0.04
153
Waste
112
0.00
112
11.2
0.00
391
Refrig.
18.1
Total
13.9
8.94
82.7
0.19
0.18
16.7 16.9
0.17
4.25 4.42
128
19,142
19,270
13.9
0.80
19,904
2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily,
Summer
(Max)
Mobile
61.3
45.5
503
1.21
0.76 109
Area
14.2
5.82
2.48
0.04
0.47 -
Energy
0.14
2.49
2.09
0.01
0.19 -
Water
-
-
-
-
- -
Waste
-
-
-
-
- -
Refrig.
-
-
-
-
- -
Total
75.6
53.8
507
1.26
1.42 109
Daily,
-
-
-
-
- -
Winter
(Max)
Mobile
60.6
49.5
470
1.16
0.76 109
110
0.71
27.8 28.5
-
123,093
123,093
5.85
4.80
125,174
0.47
0.47
- 0.47
0.00
7,392
7,392
0.14
0.01
7,399
0.19
0.19
- 0.19
-
9,952
9,952
0.70
0.06
9,987
-
-
- -
85.3
442
527
8.78
0.21
809
-
-
- -
675
0.00
675
67.4
0.00
2,361
-
-
- -
-
-
-
-
-
110
111
1.37
27.8 29.1
760
140,879
141,639
82.9
5.09
145,841
110 0.71 27.8 28.5 - 118,322 118,322 6.13 5.04 119,990
11 / 47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Area
14.2
5.82
2.48
0.04
0.47
Energy
0.14
2.49
2.09
0.01
0.19
Water
-
-
-
-
-
Waste
-
-
-
-
-
Refrig.
-
-
-
-
-
Total
74.9
57.8
474
1.21
1.42
Average
-
-
-
Daily
Mobile
58.2
43.9
421
0.98
0.65
Area
13.8
0.40
0.17
< 0.005
0.03
Energy
0.14
2.49
2.09
0.01
0.19
Water
-
-
-
-
-
Waste
-
-
-
-
-
Refrig.
-
-
-
-
-
Total
72.2
46.8
423
1.00
0.87
Annual
-
-
-
-
-
Mobile
10.6
8.02
76.9
0.18
0.12
Area
2.53
0.07
0.03
< 0.005
0.01
Energy
0.03
0.45
0.38
< 0.005
0.03
Water
-
-
-
-
-
Waste
-
-
-
-
-
Refrig.
-
-
-
-
-
Total
13.2
8.55
77.3
0.18
0.16
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
-
0.47
0.47
-
0.47
0.00
7,392
7,392
0.14
0.01
7,399
-
0.19
0.19
-
0.19
-
9,928
9,928
0.69
0.06
9,962
-
-
-
85.3
442
527
8.78
0.21
809
-
-
-
675
0.00
675
67.4
0.00
2,361
-
-
-
-
-
-
-
-
110
109
111
1.37
27.8
29.1
760
136,083
136,843
83.2
5.32
140,631
90.1
90.8
0.60
22.9
23.5
-
100,229
100,229
5.56
4.43
101,871
-
0.03
0.03
-
0.03
0.00
506
506
0.01
< 0.005
507
-
0.19
0.19
-
0.19
-
9,945
9,945
0.70
0.06
9,979
-
-
-
-
-
85.3
442
527
8.78
0.21
809
-
-
-
-
-
675
0.00
675
67.4
0.00
2,361
-
-
-
-
-
-
-
-
-
-
110
90.1
91.0
0.82
22.9
23.7
760
111,122
111,882
82.5
4.70
115,637
16.4
16.6
0.11
4.18
4.29
-
16,594
16,594
0.92
0.73
16,866
-
0.01
0.01
-
0.01
0.00
83.8
83.8
< 0.005
< 0.005
83.9
-
0.03
0.03
-
0.03
-
1,646
1,646
0.12
0.01
1,652
-
-
-
-
-
14.1
73.1
87.3
1.45
0.03
134
-
-
-
-
-
112
0.00
112
11.2
0.00
391
-
-
-
-
-
-
-
-
-
-
18.1
16.4
16.6
0.15
4.18
4.33
126
18,397
18,523
13.7
0.78
19,145
12/47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily,
Summer
(Max)
Apartment
6.49
5.15
57.5
0.14
0.09
12.8
12.9
0.08
3.26
3.34 -
s
Mid Rise
High
24.4
18.0
198
0.47
0.30
43.0
43.3
0.28
10.9
11.2 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
29.9
22.0
243
0.58
0.37
52.7
53.0
0.34
13.4
13.7 -
General
1.58
1.16
12.9
0.03
0.02
2.79
2.81
0.02
0.71
0.73 -
Office
Building
Total
62.4
46.3
512
1.23
0.77
111
112
0.72
28.3
29.0 -
Daily,
-
-
-
-
-
-
-
- -
Winter
(Max)
Apartment
6.42
5.61
53.3
0.14
0.09
12.8
12.9
0.08
3.26
3.34 -
s
Mid Rise
High
24.1
19.5
185
0.46
0.30
43.0
43.3
0.28
10.9
11.2 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
29.6
23.9
227
0.56
0.37
52.7
53.0
0.34
13.4
13.7 -
General
1.56
1.27
12.0
0.03
0.02
2.79
2.81
0.02
0.71
0.73 -
Office
Building
Total
61.7
50.4
478
1.18
0.77
111
112
0.72
28.3
29.0 -
Annual
-
-
-
-
-
- -
13/47
14,408 14,408 0.65 0.55 14,645
48,394 48,394 2.32 1.90 49,215
59,289 59,289 2.84 2.32 60,295
3,136 3,136 0.15 0.12 3,190
125,227 125,227 5.96 4.89 127,345
13,847 13,847 0.68 0.57 14,036
46,519 46,519 2.43 1.99 47,178
56,992 56,992 2.98 2.44 57,799
3,015 3,015 0.16 0.13 3,058
120,373 120,373 6.24 5.13 122,071
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Apartment 1.16
1.04
9.97
0.03
0.02
2.32
2.33
0.01
0.59
0.60
- 2,318
2,318
0.11
0.10
2,353
Mid Rise
High 4.00
2.47
23.6
0.05
0.03
4.40
4.44
0.03
1.12
1.15
- 4,514
4,514
0.31
0.23
4,597
Turnover
(Sit Down
Restaurant i
Strip Mall 5.36
4.41
42.4
0.10
0.07
9.50
9.57
0.06
2.41
2.47
- 9,538
9,538
0.49
0.40
9,689
General 0.28
0.23
2.24
0.01
< 0.005
0.50
0.51
< 0.005
0.13
0.13
- 505
505
0.03
0.02
513
Office
Building
Total 10.8
8.16
78.2
0.18
0.12
16.7
16.8
0.11
4.25
4.36
- 16,874
16,874
0.94
0.75
17,151
4.1.2. Mitigated
Criteria Pollutants (lb/day for daily,
ton/yr for annual) and
GHGs (lb/day for daily, MT/yr for annual)
Daily, -
-
-
-
-
-
-
-
-
-
- -
-
-
-
-
Summer
(Max)
Apartment 6.49
5.15
57.5
0.14
0.09
12.8
12.9
0.08
3.26
3.34
- 14,408
14,408
0.65
0.55
14,645
s
Mid Rise
High 23.9
17.6
195
0.47
0.29
42.2
42.5
0.27
10.7
11.0
- 47,462
47,462
2.27
1.86
48,267
Turnover
(Sit Down
Restaurant i
Strip Mall 29.3
21.6
238
0.57
0.36
51.7
52.0
0.33
13.1
13.4
- 58,147
58,147
2.79
2.28
59,133
General 1.55
1.14
12.6
0.03
0.02
2.73
2.75
0.02
0.69
0.71
- 3,076
3,076
0.15
0.12
3,128
Office
Building
Total 61.3
45.5
503
1.21
0.76
109
110
0.71
27.8
28.5
- 123,093
123,093
5.85
4.80
125,174
Daily, -
-
-
-
-
-
-
-
-
-
- -
-
-
-
-
Winter
(Max)
14/47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Apartment 6.42 5.61 53.3 0.14
0.09
12.8
12.9
0.08
3.26
3.34
- 13,847
13,847
0.68
0.57
14,036
s
High 23.7 19.2 182 0.45
0.29
42.2
42.5
0.27
10.7
11.0
- 45,624
45,624
2.38
1.95
46,270
Turnover
(Sit Down
Restaurant i
Strip Mall 29.0 23.5 223 0.55
0.36
51.7
52.0
0.34
13.1
13.4
- 55,895
55,895
2.92
2.39
56,686
General 1.53 1.24 11.8 0.03
0.02
2.73
2.75
0.02
0.69
0.71
- 2,957
2,957
0.15
0.13
2,999
Office
Building
Total 60.6 49.5 470 1.16
0.76
109
110
0.71
27.8
28.5
- 118,322
118,322
6.13
5.04
119,990
Annual
Apartment 1.16 1.04 9.97 0.03
0.02
2.32
2.33
0.01
0.59
0.60
- 2,318
2,318
0.11
0.10
2,353
s
Mid Rise
High 3.92 2.43 23.1 0.05
0.03
4.32
4.35
0.03
1.10
1.13
- 4,427
4,427
0.30
0.22
4,508
Turnover
(Sit Down
Restaurant i
Strip Mall 5.26 4.33 41.6 0.10
0.07
9.32
9.38
0.06
2.37
2.43
- 9,355
9,355
0.48
0.40
9,502
General 0.28 0.23 2.20 0.01
< 0.005
0.49
0.50
< 0.005
0.13
0.13
- 495
495
0.03
0.02
503
Office
Building
Total 10.6 8.02 76.9 0.18
0.12
16.4
16.6
0.11
4.18
4.29
- 16,594
16,594
0.92
0.73
16,866
4.2. Energy
4.2.1. Electricity Emissions By Land Use
- Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs
(lb/day for daily, MT/yr for annual)
Daily, - - - -
-
-
-
-
-
-
- -
-
-
-
-
Summer
(Max)
15/47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Apartment — — — — — 2,207 2,207 0.14 0.02 2,215
Mid Rise
High 3,424 3,424 0.21 0.03 3,437
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — — — — —
General — — — — — — — — — —
Office
Building
Total
Daily,
Winter
(Max)
Apartment — — — — — — — — — —
s
Mid Rise
High — — — — — — — — — —
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — — — — —
General — — — — — — — — — —
Office
Building
Total — — — — — — — — — —
Annual — — — — — — — —
Apartment — — — — — — — — — —
s
Mid Rise
High — — —
Turnover
(Sit Down
Restaurant i
— 1,350
1,350
0.08
0.01
1,355
— 1,129
1,129
0.07
0.01
1,134
8,109
8,109
0.50
0.06
8,140
— 2,207
2,207
0.14
0.02
2,215
— 3,424
3,424
0.21
0.03
3,437
— 1,350
1,350
0.08
0.01
1,355
— 1,129
1,129
0.07
0.01
1,134
— 8,109
8,109
0.50
0.06
8,140
— 365
365
0.02
< 0.005
367
— 567
567
0.04
< 0.005
569
Strip Mall
16/47
223 223 0.01 < 0.005 224
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
General — —
187
187
0.01
< 0.005
188
Office
Building
Total — — —
— — — — 1,343
1,343
0.08
0.01
1,348
4.2.2. Electricity Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — —
— — — — —
—
—
—
—
Summer
(Max)
Apartment — — — — — — —
— — — — 2,059
2,059
0.13
0.02
2,067
s
Mid Rise
High — — — — — — —
— — — — 2,768
2,768
0.17
0.02
2,778
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — —
— — — — 1,169
1,169
0.07
0.01
1,173
General — — — — — — —
— 983
983
0.06
0.01
986
Office
Building
Total — — — — — — —
— — — — 6,978
6,978
0.43
0.05
7,005
Daily, — — — — — — —
— — — — —
—
—
—
—
Winter
(Max)
Apartment — — — — — — —
— — — — 2,043
2,043
0.13
0.02
2,051
s
Mid Rise
High — — — — — — —
— — — — 2,765
2,765
0.17
0.02
2,775
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — —
— — — — 1,165
1,165
0.07
0.01
1,169
17/47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
General - - - - - -
- 981
981
0.06
0.01
985
Office
Building
Total - - - - - -
6,953
6,953
0.43
0.05
6,980
Annual - - - - - -
- - - - - -
-
-
-
-
Apartment - - - - -
340
340
0.02
< 0.005
341
s
Mid Rise
High - - - - - -
- - - - - 458
458
0.03
< 0.005
460
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - -
General - - - - - - -
Office
Building
Total - - - - - - - - - -
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - -
Summer
(Max)
Apartment 0.07 1.16 0.49 0.01 0.09 - 0.09 0.09 - 0.09 -
s
Mid Rise
High 0.12 2.10 1.76 0.01 0.16 - 0.16 0.16 - 0.16 -
Turnover
(Sit Down
Restaurant
Strip Mall 0.01 0.15 0.13 < 0.005 0.01 - 0.01 0.01 - 0.01
193 193 0.01 < 0.005 194
163 163 0.01 < 0.005 163
1,154 1,154 0.07 0.01 1,158
1,470 1,470 0.13 < 0.005 1,474
2,503 2,503 0.22 < 0.005 2,510
181 181 0.02 < 0.005 181
18/47
General
0.02
0.30
0.25
< 0.005
0.02 -
Office
Building
Total
0.21
3.70
2.63
0.02
0.29 -
Daily,
-
-
-
-
- -
Winter
(Max)
Apartment
0.07
1.16
0.49
0.01
0.09 -
s
Mid Rise
High
0.12
2.10
1.76
0.01
0.16 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
0.01
0.15
0.13
< 0.005
0.01 -
General
0.02
0.30
0.25
< 0.005
0.02 -
Office
Building
Total
0.21
3.70
2.63
0.02
0.29 -
Annual
Apartment
0.01
0.21
0.09
< 0.005
0.02 -
s
Mid Rise
High
0.02
0.38
0.32
< 0.005
0.03 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
< 0.005
0.03
0.02
< 0.005
< 0.005 -
General
< 0.005
0.05
0.05
< 0.005
< 0.005 -
Office
Building
Total
0.04
0.68
0.48
< 0.005
0.05 -
4.2.4. Natural Gas Emissions By Land Use - Mitigated
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
0.02 0.02 - 0.02 - 353 353 0.03 < 0.005 354
0.29 0.29 - 0.29 - 4,507 4,507 0.40 0.01 4,520
0.09
0.09 -
0.09 -
1,470
1,470
0.13
< 0.005
1,474
0.16
0.16 -
0.16 -
2,503
2,503
0.22
< 0.005
2,510
0.01
0.01 -
0.01 -
181
181
0.02
< 0.005
181
0.02
0.02 -
0.02 -
353
353
0.03
< 0.005
354
0.29
0.29 -
0.29 -
4,507
4,507
0.40
0.01
4,520
0.02
0.02 -
0.02 -
243
243
0.02
< 0.005
244
0.03
0.03 -
0.03 -
414
414
0.04
< 0.005
416
< 0.005
< 0.005 -
< 0.005 -
30.0
30.0
< 0.005
< 0.005
30.0
< 0.005
< 0.005 -
< 0.005 -
58.5
58.5
0.01
< 0.005
58.6
0.05
0.05 -
0.05 -
746
746
0.07
< 0.005
748
19/47
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs
Daily,
-
-
-
-
- -
Summer
(Max)
Apartment
0.00
0.00
0.00
0.00
0.00 -
s
Mid Rise
High
0.11
2.08
1.75
0.01
0.16 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
0.01
0.15
0.13
< 0.005
0.01 -
General
0.01
0.26
0.22
< 0.005
0.02 -
Office
Building
Total
0.14
2.49
2.09
0.01
0.19 -
Daily,
-
-
-
-
- -
Winter
(Max)
Apartment
0.00
0.00
0.00
0.00
0.00 -
s
Mid Rise
High
0.11
2.08
1.75
0.01
0.16 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
0.01
0.15
0.13
< 0.005
0.01 -
General
0.01
0.26
0.22
< 0.005
0.02 -
Office
Building
Total
0.14
2.49
2.09
0.01
0.19 -
Annual
-
-
-
-
- -
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
'Ib/day for daily, MT/yr for annual)
0.00
0.00 -
0.00 -
0.00
0.00
0.00
0.00
0.00
0.16
0.16 -
0.16 -
2,486
2,486
0.22
< 0.005
2,493
0.01
0.01 -
0.01 -
179
179
0.02
< 0.005
179
0.02
0.02 -
0.02 -
309
309
0.03
< 0.005
310
0.19
0.19 -
0.19 -
2,974
2,974
0.26
0.01
2,982
0.00
0.00 -
0.00 -
0.00
0.00
0.00
0.00
0.00
0.16
0.16 -
0.16 -
2,486
2,486
0.22
< 0.005
2,493
0.01
0.01 -
0.01 -
179
179
0.02
< 0.005
179
0.02
0.02 -
0.02 -
309
309
0.03
< 0.005
310
0.19
0.19 -
0.19 -
2,974
2,974
0.26
0.01
2,982
20 / 47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Apartment
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00 -
0.00 -
s
Mid Rise
High
0.02
0.38
0.32
< 0.005
0.03 -
0.03
0.03 -
0.03 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
< 0.005
0.03
0.02
< 0.005
< 0.005 -
< 0.005
< 0.005 -
< 0.005 -
General
< 0.005
0.05
0.04
< 0.005
< 0.005 -
< 0.005
< 0.005 -
< 0.005 -
Office
Building
Total
0.03
0.45
0.38
< 0.005
0.03 -
0.03
0.03 -
0.03 -
4.3. Area Emissions by Source
4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily,
Summer
(Max)
0.00 0.00 0.00 0.00 0.00
412 412 0.04 < 0.005 413
29.6 29.6 < 0.005 < 0.005 29.7
51.1 51.1 < 0.005 < 0.005 51.3
492 492 0.04 < 0.005 494
Hearths 0.34 5.82 2.48 0.04 0.47 - 0.47 0.47 - 0.47 0.00 7,392 7,392 0.14 0.01 7,399
Consumer 12.9 - - - - - - - - - - - - - - -
Products
Architectu 1.20 - - - - - - - - - - - - - - -
ral
Coatings
Landscap 3.61 0.31 32.3 < 0.005 0.03 - 0.03 0.02 - 0.02 - 99.4 99.4 < 0.005 < 0.005 99.8
e
Equipmen
t
Total 18.0 6.13 34.8 0.04 0.50 - 0.50 0.49 - 0.49 0.00 7,491 7,491 0.14 0.01 7,499
21 / 47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Daily, - - - - - - -
Winter
(Max)
Hearths 0.34 5.82 2.48 0.04 0.47 - 0.47 0.47 - 0.47 0.00 7,392 7,392 0.14 0.01 7,399
Consumer 12.9 - - - - - - - - - - - - - - -
Products
Architectu 1.20 - - - - - - - - - - - - - - -
ral
Coatings
Total 14.4 5.82 2.48 0.04 0.47 - 0.47 0.47 - 0.47 0.00 7,392 7,392 0.14 0.01 7,399
Annual - - - - - - -
Hearths < 0.005 0.07 0.03 < 0.005 0.01 - 0.01 0.01 - 0.01 0.00 83.8 83.8 < 0.005 < 0.005 83.9
Consumer 2.35 - - - - -
Products
Architectu 0.22 - - - - - - - - - - - - - - -
ral
Coatings
Landscap 0.45 0.04 4.04 < 0.005 < 0.005 - < 0.005 < 0.005 - < 0.005 - 11.3
e
Equipmen
t
Total 3.03 0.11 4.07 < 0.005 0.01 - 0.01 0.01 - 0.01 0.00 95.1
4.3.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - - - -
Summer
(Max)
11.3 < 0.005 < 0.005 11.3
95.1 < 0.005 < 0.005 95.2
Hearths 0.34 5.82 2.48 0.04 0.47 - 0.47 0.47 - 0.47 0.00 7,392 7,392 0.14
Consumer 12.9
Products
0.01 7,399
22/47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Architectu 0.94 - -
-
-
Coatings
Total 14.2 5.82 2.48 0.04 0.47 - 0.47 0.47 - 0.47
0.00
7,392
7,392 0.14
0.01 7,399
Daily,
Winter
(Max)
Hearths 0.34 5.82 2.48 0.04 0.47 - 0.47 0.47 - 0.47
0.00
7,392
7,392 0.14
0.01 7,399
Consumer 12.9 - - - - - - - - -
-
-
- -
- -
Products
Architectu 0.94 - - - - - - - - -
-
-
- -
- -
ral
Coatings
Total 14.2 5.82 2.48 0.04 0.47 - 0.47 0.47 - 0.47
0.00
7,392
7,392 0.14
0.01 7,399
Annual
Hearths < 0.005 0.07 0.03 < 0.005 0.01 - 0.01 0.01 - 0.01
0.00
83.8
83.8 < 0.005
< 0.005 83.9
Consumer 2.35 - - - - - - - - -
-
-
- -
- -
Products
Architectu 0.17 - - - - - - - - -
-
-
- -
- -
ral
Coatings
Total 2.53 0.07 0.03 < 0.005 0.01 - 0.01 0.01 - 0.01
0.00
83.8
83.8 < 0.005
< 0.005 83.9
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - -
-
-
- -
- -
Summer
(Max)
23 / 47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Apartment - - - - - - 29.7 154 183 3.05 0.07 282
s
Mid Rise
High - - - - - - - 39.5 204 244 4.06 0.10 374
Turnover
(Sit Down
Restaurant i
Strip Mall -
General - - - - - - - - - -
Office
Building
Total -
Daily, - - - - - - - - - -
Winter
(Max)
Apartment - - - - - - - - - -
s
Mid Rise
High - - -
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - - - - - - -
General - - - - - - - - - -
Office
Building
Total - - - - - - - - - -
Annual - - - - - - -
Apartment - - - - - - - - - -
s
Mid Rise
High - - - - - - - - - -
Turnover
(Sit Down
Restaurant i
13.4
69.3
82.7
1.38
0.03
127
14.8
76.7
91.5
1.52
0.04
140
97.3
504
601
10.0
0.24
923
29.7
154
183
3.05
0.07
282
39.5
204
244
4.06
0.10
374
13.4
69.3
82.7
1.38
0.03
127
14.8
76.7
91.5
1.52
0.04
140
97.3
504
601
10.0
0.24
923
4.92
25.5
30.4
0.51
0.01
46.6
6.53
33.8
40.4
0.67
0.02
62.0
24/47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Strip Mall - - - - - - -
2.22
11.5
13.7
0.23
0.01
21.0
General - - - - - - -
- 2.45
12.7
15.1
0.25
0.01
23.3
Office
Building
Total - - - - - - -
- - - 16.1
83.4
99.6
1.66
0.04
153
4.4.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - -
- - - -
-
-
-
-
-
Summer
(Max)
Apartment - - - - - - -
- - - 23.8
123
147
2.45
0.06
226
s
Mid Rise
High - - - - - - -
- - - 35.8
185
221
3.68
0.09
340
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - - - -
- - - 12.3
63.6
75.9
1.26
0.03
117
General - - - - - - -
- - - 13.4
69.5
83.0
1.38
0.03
127
Office
Building
Total - - - - - - -
- - - 85.3
442
527
8.78
0.21
809
Daily, - - - - - - -
- - - -
-
-
-
-
-
Winter
(Max)
Apartment - - - - - - -
- - - 23.8
123
147
2.45
0.06
226
s
Mid Rise
High - - - - - - -
- - - 35.8
185
221
3.68
0.09
340
Turnover
(Sit Down
Restaurant i
25 / 47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Strip Mall - - - - -
- 12.3
63.6
75.9
1.26
0.03
117
General - - - - -
13.4
69.5
83.0
1.38
0.03
127
Office
Building
Total - - -
85.3
442
527
8.78
0.21
809
Annual - - - - -
- - - - - -
-
-
-
-
-
Apartment -
3.94
20.4
24.3
0.41
0.01
37.4
s
Mid Rise
High - - - - -
- - - - - 5.93
30.7
36.6
0.61
0.01
56.2
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - -
General - - - - - - -
Office
Building
Total - - - - - - - - - -
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - -
Summer
(Max)
Apartment - - - - - - - - - -
s
Mid Rise
2.03
10.5
12.6
0.21
0.01
19.3
2.22
11.5
13.7
0.23
0.01
21.1
14.1
73.1
87.3
1.45
0.03
134
165 0.00 165 16.5 0.00 576
26 / 47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
High - - - - - 435 0.00 435 43.5 0.00 1,522
Turnover
(Sit Down
Restaurant
Strip Mall - - - - - - - - - -
General - - - - - - - - - -
Office
Building
Total - - - - - - - - - -
Daily, - - - - - - - -
Winter
(Max)
Apartment - - - - - - -
s
Mid Rise
High - - - - - - - - - -
Turnover
(Sit Down
Restaurant
Strip Mall - - - - - - - - - -
General - - - - - - - - - -
Office
Building
Total - - - - - - - - - -
Annual - - - - - - - - - -
Apartment - - - - - - - - - -
s
Mid Rise
High - - -
Turnover
(Sit Down
Restaurant i
Strip Mall
53.4
0.00
53.4
5.33
0.00
187
21.8
0.00
21.8
2.18
0.00
76.2
675
0.00
675
67.4
0.00
2,361
165
0.00
165
16.5
0.00
576
435
0.00
435
43.5
0.00
1,522
53.4
0.00
53.4
5.33
0.00
187
21.8
0.00
21.8
2.18
0.00
76.2
675
0.00
675
67.4
0.00
2,361
27.3
0.00
27.3
2.72
0.00
95.4
72.0
0.00
72.0
7.20
0.00
252
27 / 47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
General - -
3.61
0.00
3.61
0.36
0.00
12.6
Office
Building
Total -
- - - 112
0.00
112
11.2
0.00
391
4.5.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - -
- - - -
-
-
-
-
-
Summer
(Max)
Apartment - - - - - - -
- - - 165
0.00
165
16.5
0.00
576
s
Mid Rise
High - - - - - - -
- - - 435
0.00
435
43.5
0.00
1,522
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - - - -
- - - 53.4
0.00
53.4
5.33
0.00
187
General - - - - - - -
- - - 21.8
0.00
21.8
2.18
0.00
76.2
Office
Building
Total - - - - - - -
- - - 675
0.00
675
67.4
0.00
2,361
Daily, - - - - - - -
- - - -
-
-
-
-
-
Winter
(Max)
Apartment - - - - - - -
- - - 165
0.00
165
16.5
0.00
576
s
Mid Rise
High - - - - - - -
- - - 435
0.00
435
43.5
0.00
1,522
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - - - -
- - - 53.4
0.00
53.4
5.33
0.00
187
28 / 47
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
General - - - - -
- - 21.8
0.00
21.8
2.18
0.00
76.2
Office
Building
Total - - - - -
- 675
0.00
675
67.4
0.00
2,361
Annual - - - - -
- - - - - -
-
-
-
-
-
Apartment - - - - -
27.3
0.00
27.3
2.72
0.00
95.4
s
Mid Rise
High - - - - -
- - - - - 72.0
0.00
72.0
7.20
0.00
252
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - -
General - - - - - - - - - -
Office
Building
Total - - - - - - - - - -
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - -
Summer
(Max)
Apartment - - - - - - - - - -
s
Mid Rise
High - - - - - - - - - -
Turnover
(Sit Down
Restaurant
8.83 0.00 8.83 0.88 0.00 30.9
3.61 0.00 3.61 0.36 0.00 12.6
112 0.00 112 11.2 0.00 391
2.84
106
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Strip Mall — — — — — — — — — 0.59
General — — — — — — — — 0.11
Office
Building
Total — — — — — — — — — — — — — — — 110
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Apartment — — — — — — — — — — — — — — — 2.84
s
Mid Rise
High 106
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — — —
— — — — — — — 0.59
General — — — — — — — —
— — — — — — — 0.11
Office
Building
Total
110
Annual
Apartment
0.47
s
Mid Rise
High — — — — — — — —
— — — — — — — 17.6
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — — —
— — — — — 0.10
General
0.02
Office
Building
Total — — — — — — — —
— — — — — — — 18.1
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
4.6.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — —
Summer
(Max)
Apartment — — — — — — — — — —
s
Mid Rise
High — — — — — — — — — —
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — —
General — — — — — — — — — —
Office
Building
Total — — — — — — — — — —
Daily, — — — — — —
Winter
(Max)
Apartment — — — — — — — — — —
s
Mid Rise
High — — — — — — — —
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — — — — —
General — — — — — — — — — —
Office
Building
Total — — — — — — — — — —
Annual — — — — — — — — — —
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2.84
106
0.59
0.11
110
2.84
106
0.59
0.11
110
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Apartment — — — — — — — 0.47
Mid Rise
High 17.6
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — — — — —
General — — — — — — — — — —
Office
Building
Total
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
0.10
0.02
18.1
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — —
Annual — — — — — — — — — — — —
Total — — — — — — — — — — —
4.7.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
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Daily, — — — — — — — —
Summer
(Max)
Total — — — — — — — —
Daily, — — — — — — — —
Winter
(Max)
Total — — — — — — — — — —
Annual — — — — — — — — — —
Total — — — — — — — — — —
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipmen
-
Daily, — — — — — — — — — — — — —
Summer
(Max)
Total
Daily,
Winter
(Max)
Total — — — — — — — — — — — — —
Annual — — — — — — — — — — — — —
Total — — — — — — — — — — — — —
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
4.8.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipmen
-
Daily, — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — —
Annual — — — — — — — — — — — — —
Total — — — — — — — — — — — — —
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — —
Daily, — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — —
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Annual — — — — — — — — — —
Total — — — — — — — — — —
4.9.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Total— — — — — — — — — — — — — — — —
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Total — — — — — — — — — —
Annual — — — — — — — — — —
Total — — — — — — — — — — — — — —
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — —
Annual — — — — — — — — — — — — —
Total — — — — — — — — — — — — —
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Sequester — — — — — — — — — — — — — — — —
ed
Subtotal — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — —
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Subtotal — — — — — — —
Daily, — — — — — — — — —
Winter
(Max)
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Sequester — — — — — — — — — — — — — — — —
ed
Subtotal — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — -
- - - - - - - - - - - - - - - - -
Annual — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Sequester — — — — — — — — — — — — — — — —
ed
Subtotal — — — — — — — — — —
Removed — — — — — — — — — —
Subtotal — — — — — — — — — —
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Total — — — — — —
Daily, — — — —
Winter
(Max)
Total — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Total— — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Total— — — — — — — — — — — — — — — —
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Sequester — — — — — — — —
Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — —
Daily, — — —
Winter
(Max)
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Sequester — — — — — — — — — — — — — — — —
ed
Subtotal — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Annual — — — — — — — — — —
Avoided — — — — — — — — — —
Subtotal — — — — — — — — — —
Sequester — — — — — — — — — —
ed
Subtotal —
Removed —
Subtotal —
5. Activity Data
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
5.9. Operational Mobile Sources
5.9.1. Unmitigated
Apartments Mid Rise 1,875
High Turnover (Sit 7,272
Down Restaurant)
Strip Mall 8,909
General Office 471
Building
5.9.2. Mitigated
Apartments Mid Rise
1,875
High Turnover (Sit
7,132
Down Restaurant)
Strip Mall
8,738
General Office
462
Building
1,875
1,875
684,382
18,159
18,159
18,159
6,627,917
7,272
7,272
2,654,326
24,021
60,776
60,776
12,600,648
8,909
8,909
3,251,885
74,458
74,458
74,458
27,177,052
471
471
172,021
3,939
3,939
3,939
1,437,636
1,875
1,875
684,382
18,159
18,159
18,159
6,627,917
7,132
7,132
2,603,205
23,558
59,605
59,605
12,357,966
8,738
8,738
3,189,255
73,024
73,024
73,024
26,653,636
462
462
168,708
3,863
3,863
3,863
1,409,948
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
Apartments Mid Rise -
Wood Fireplaces 0
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
Gas Fireplaces
Propane Fireplaces
Electric Fireplaces
No Fireplaces
Conventional Wood Stoves
Catalytic Wood Stoves
Non -Catalytic Wood Stoves
Pellet Wood Stoves
5.10.1.2. Mitigated
Apartments Mid Rise
Wood Fireplaces
Gas Fireplaces
Propane Fireplaces
Electric Fireplaces
No Fireplaces
Conventional Wood Stoves
Catalytic Wood Stoves
Non -Catalytic Wood Stoves
Pellet Wood Stoves
5.10.2. Architectural Coatings
802872
267,624
308,403
351
0
0
62
0
0
0
0
I
351
0
0
62
0
0
0
0
102,801
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
5.10.3. Landscape Equipment
Snow Days day/yr
Summer Days day/yr
5.10.4. Landscape Equipment - Mitigated
Snow Days day/yr
Summer Days day/yr
5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N20 and Natural Gas (kBTU/yr)
0.00
250
0.00
250
Apartments Mid Rise
1,513,989
532
0.0330
0.0040
4,587,126
High Turnover (Sit Down
2,349,217
532
0.0330
0.0040
7,810,183
Restaurant)
Strip Mall
926,037
532
0.0330
0.0040
564,497
General Office Building
774,773
532
0.0330
0.0040
1,101,988
5.11.2. Mitigated
Electricity (kWh/vr) and CO2 and CH4 and N20 and Natural Gas
Apartments Mid Rise 1,401,694 532 0.0330 0.0040 0.00
High Turnover (Sit Down 1,897,044 532 0.0330 0.0040 7,758,239
Restaurant)
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Strip Mall 799,124 532 0.0330 0.0040 558,092
General Office Building 672,960 532 0.0330 0.0040 963,712
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Apartments Mid Rise 15,498,093 0.00
High Turnover (Sit Down Restaurant) 20,590,816 0.00
Strip Mall 6,984,150 0.00
General Office Building 7,727,330 0.00
5.12.2. Mitigated
Apartments Mid Rise 12,418,622 0.00
High Turnover (Sit Down Restaurant) 18,684,107 0.00
Strip Mall 6,411,450 0.00
General Office Building 7,008,688 0.00
5.13. Operational Waste Generation
5.13.1. Unmitigated
Apartments Mid Rise 305 —
High Turnover (Sit Down Restaurant) 807 —
Strip Mall 99.0 —
General Office Building 40.4 —
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
5.13.2. Mitigated
Apartments Mid Rise 305 -
High Turnover (Sit Down Restaurant) 807 -
Strip Mall 99.0 -
General Office Building 40.4 -
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Apartments Mid Rise
Average room A/C &
R-410A
Other residential A/C
and heat pumps
Apartments Mid Rise
Household refrigerators
R-134a
and/or freezers
High Turnover (Sit
Household refrigerators
R-134a
Down Restaurant)
and/or freezers
High Turnover (Sit
Other commercial A/C
R-410A
Down Restaurant)
and heat pumps
High Turnover (Sit
Walk-in refrigerators
R-404A
Down Restaurant)
and freezers
Strip Mall
Other commercial A/C
R-410A
and heat pumps
Strip Mall
Stand-alone retail
R-134a
refrigerators and
freezers
Strip Mall
Walk-in refrigerators
R-404A
and freezers
General Office Building
Household refrigerators
R-134a
and/or freezers
2,088
< 0.005
2.50
2.50
10.0
1,430
0.12
0.60
0.00
1.00
1,430
0.00
0.60
0.00
1.00
2,088
1.80
4.00
4.00
18.0
3,922
< 0.005
7.50
7.50
20.0
2,088
< 0.005
4.00
4.00
18.0
1,430
0.04
1.00
0.00
1.00
3,922
< 0.005
7.50
7.50
20.0
1,430
0.02
0.60
0.00
1.00
44/47
General Office Building Other commercial A/C R-410A
and heat pumps
5.14.2. Mitigated
Apartments Mid Rise
Average room A/C &
R-410A
Other residential A/C
and heat pumps
Apartments Mid Rise
Household refrigerators
R-134a
and/or freezers
High Turnover (Sit
Household refrigerators
R-134a
Down Restaurant)
and/or freezers
High Turnover (Sit
Other commercial A/C
R-410A
Down Restaurant)
and heat pumps
High Turnover (Sit
Walk-in refrigerators
R-404A
Down Restaurant)
and freezers
Strip Mall
Other commercial A/C
R-410A
and heat pumps
Strip Mall
Stand-alone retail
R-134a
refrigerators and
freezers
Strip Mall
Walk-in refrigerators
R-404A
and freezers
General Office Building
Household refrigerators
R-134a
and/or freezers
General Office Building
Other commercial A/C
R-410A
and heat pumps
5.15. Operational
Off -Road Equipment
5.15.1. Unmitigated
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
2,088 < 0.005 4.00 4.00 18.0
2,088
< 0.005
2.50
2.50
10.0
1,430
0.12
0.60
0.00
1.00
1,430
0.00
0.60
0.00
1.00
2,088
1.80
4.00
4.00
18.0
3,922
< 0.005
7.50
7.50
20.0
2,088
< 0.005
4.00
4.00
18.0
1,430
0.04
1.00
0.00
1.00
3,922
< 0.005
7.50
7.50
20.0
1,430
0.02
0.60
0.00
1.00
2,088
< 0.005
4.00
4.00
18.0
Number per Day Hours Per Day Horsepower Load Factor
Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
5.15.2. Mitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day)
5.17. User Defined
[Equipment Type Fuel Type
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.1. Biomass Cover Type
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Enderle Center - Proposed Project (Operational) Custom Report, 3/29/2024
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
5.18.2.2. Mitigated
8. User Changes to Default Data
Land Use
Operations: Vehicle Data
The project site is approximately 11.80 acres.
The proposed project would generate approximately 18,528 average daily trips.
Operations: Hearths Assuming no wood burning hearths or wood stoves.
47 / 47
Enderle Center - Existing Uses Custom Report, 2/6/2024
Enderle Center - Existing Uses Custom Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User -Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
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Enderle Center - Existing Uses Custom Report, 2/6/2024
4.3.1. Unmitigated
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
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5. Activity Data
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.15. Operational Off -Road Equipment
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Enderle Center - Existing Uses Custom Report, 2/6/2024
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
8. User Changes to Default Data
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Enderle Center - Existing Uses Custom Report, 2/6/2024
1. Basic Project Information
1.1. Basic Project Information
Project Name
Operational Year
Lead Agency
Land Use Scale
Analysis Level for Defaults
Windspeed (m/s)
Precipitation (days)
Location
County
City
Air District
Air Basin
TAZ
EDFZ
Electric Utility
Gas Utility
App Version
1.2. Land Use Types
High Turnover (Sit 28.8
Down Restaurant)
1000sgft 2.00
28,750
Enderle Center - Existing Uses
2024
Project/site
County
2.50
18.6
17350 17th St, Tustin, CA 92780, USA
Orange
Tustin
South Coast AQMD
South Coast
5961
7
Southern California Edison
Southern California Gas
2022.1.1.21
0.00 —
5/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Strip Mall 40.0 1000sgft 2.00 39,960 0.00
General Office 18.4 1000sgft 0.80 18,426 0.00
Building
Parking Lot 7.00 Acre 7.00 0.00 0.00
1.3. User -Selected Emission Reduction Measures by Emissions Sector
No measures selected
2. Emissions Summary
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - - -
Summer
(Max)
Unmit. 26.5 18.5 197 0.47 0.38 41.7 42.1 0.36 10.6 10.9 245
Daily, - - - - - - - - - - -
Winter
(Max)
Unmit. 25.6 20.0 181 0.45 0.37 41.7 42.1 0.35 10.6 10.9 245
Average - - - - - - - - - - -
Daily
(Max)
51,309 51,554 27.1 1.93
49,474 49,718 27.2 2.03
53,045
51,053
Unmit. 25.0 17.6 162 0.37 0.33 33.5 33.8 0.31 8.49 8.80 245 41,600 41,845 27.0 1.76 43,157
Annual - - - - - - - - - - - - - - - -
(Max)
Unmit. 4.56 3.22 29.5 0.07 0.06 6.11 6.17 0.06 1.55 1.61 40.5 6,887 6,928 4.46 0.29 7,145
2.5. Operations Emissions by Sector, Unmitigated
6/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual
Daily,
-
-
-
-
-
-
-
-
-
-
-
Summer
(Max)
Mobile
23.7
17.4
192
0.46
0.29
41.7
42.0
0.27
10.6
10.9
-
Area
2.75
0.03
3.79
< 0.005
0.01
-
0.01
0.01
-
0.01
-
Energy
0.06
1.08
0.91
0.01
0.08
-
0.08
0.08
-
0.08
-
Water
28.7
Waste
216
Refrig.
-
-
-
-
-
-
-
-
-
-
-
Total
26.5
18.5
197
0.47
0.38
41.7
42.1
0.36
10.6
10.9
245
Daily,
-
-
-
-
-
-
-
-
-
-
-
Winter
(Max)
Mobile
23.4
19.0
180
0.44
0.29
41.7
42.0
0.27
10.6
10.9
Area
2.13
-
-
-
-
-
-
-
-
-
-
Energy
0.06
1.08
0.91
0.01
0.08
-
0.08
0.08
-
0.08
-
Water
-
-
-
-
-
-
-
-
-
-
28.7
Waste
-
-
-
-
-
-
-
-
-
-
216
Refrig.
-
-
-
-
-
-
-
-
-
-
-
Total
25.6
20.0
181
0.45
0.37
41.7
42.1
0.35
10.6
10.9
245
Average
-
-
-
-
-
-
-
-
-
-
-
Daily
Mobile
22.4
16.5
158
0.37
0.24
33.5
33.7
0.23
8.49
8.72
-
Area
2.56
0.02
2.59
< 0.005
< 0.005
-
< 0.005
< 0.005
-
< 0.005
-
Energy
0.06
1.08
0.91
0.01
0.08
-
0.08
0.08
-
0.08
-
Water
-
-
-
-
-
28.7
Waste
-
-
-
216
46,966
46,966
2.25
1.84
47,763
15.6
15.6
< 0.005
< 0.005
15.6
4,178
4,178
0.29
0.02
4,193
148
177
2.95
0.07
272
0.00
216
21.6
0.00
757
-
-
-
-
45.2
51,309
51,554
27.1
1.93
53,045
45,147
45,147
2.36
1.93
45,786
4,178
4,178
0.29
0.02
4,193
148
177
2.95
0.07
272
0.00
216
21.6
0.00
757
-
-
-
-
45.2
49,474
49,718
27.2
2.03
51,053
37,263
37,263
2.11
1.67
37,880
10.7
10.7
< 0.005
< 0.005
10.7
4,178
4,178
0.29
0.02
4,193
148
177
2.95
0.07
272
0.00
216
21.6
0.00
757
7/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Refrig
Total
25.0
17.6
162
0.37
0.33 33.5
33.8
0.31 8.49
8.80
245
Annual
-
-
-
-
- -
-
- -
-
-
Mobile
4.09
3.02
28.9
0.07
0.04 6.11
6.15
0.04 1.55
1.59
-
Area
0.47
< 0.005
0.47
< 0.005
< 0.005 -
< 0.005
< 0.005 -
< 0.005
-
Energy
0.01
0.20
0.17
< 0.005
0.01 -
0.01
0.01 -
0.01
-
Water
-
- -
-
- -
-
4.75
Waste
-
-
-
-
- -
-
- -
-
35.8
Refrig.
Total
4.56
3.22
29.5
0.07
0.06 6.11
6.17
0.06 1.55
1.61
40.5
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - -
Summer
(Max)
High 10.3 7.61 84.1 0.20 0.13 18.2 18.4 0.12 4.63 4.74
Turnover
(Sit Down
Restaurant i
Strip Mall 12.7 9.32 103 0.25 0.16 22.3 22.5 0.14 5.67 5.81
General 0.67 0.49 5.45 0.01 0.01 1.18 1.19 0.01 0.30 0.31
Office
Building
-
-
-
-
45.2
41,600
41,845
27.0
1.76
43,157
6,169
6,169
0.35
0.28
6,272
1.77
1.77
< 0.005
< 0.005
1.77
692
692
0.05
< 0.005
694
24.6
29.3
0.49
0.01
45.0
0.00
35.8
3.58
0.00
125
7.49
6,887
6,928
4.46
0.29
7,145
20,510 20,510 0.98
25,127 25,127 1.20
1,329 1,329 0.06
0.80 20,858
0.98 25,553
0.05 1,352
8/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Parking
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Lot
Total
23.7
17.4
192
0.46
0.29
41.7
42.0
0.27
10.6
10.9 -
Daily,
Winter
(Max)
High
10.2
8.28
78.6
0.19
0.13
18.2
18.4
0.12
4.63
4.74 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
12.5
10.1
96.2
0.24
0.16
22.3
22.5
0.14
5.67
5.81 -
General
0.66
0.54
5.09
0.01
0.01
1.18
1.19
0.01
0.30
0.31 -
Office
Building
Parking
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Lot
Total
23.4
19.0
180
0.44
0.29
41.7
42.0
0.27
10.6
10.9 -
Annual
-
-
-
-
-
-
-
-
-
- -
High
1.69
1.05
9.99
0.02
0.01
1.87
1.88
0.01
0.47
0.49 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
2.27
1.87
18.0
0.04
0.03
4.03
4.05
0.03
1.02
1.05 -
General
0.12
0.10
0.95
< 0.005
< 0.005
0.21
0.21
< 0.005
0.05
0.06 -
Office
Building
Parking
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
Lot
Total
4.09
3.02
28.9
0.07
0.04
6.11
6.15
0.04
1.55
1.59 -
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
0.00
0.00
0.00
0.00
0.00
46,966
46,966
2.25
1.84
47,763
19,715 19,715 1.03 0.84 19,995
24,154
24,154
1.26
1.03
24,496
1,278
1,278
0.07
0.05
1,296
0.00
0.00
0.00
0.00
0.00
45,147
45,147
2.36
1.93
45,786
1,913
1,913
0.13
0.10
1,948
4,042
4,042
0.21
0.17
4,106
214
214
0.01
0.01
217
0.00
0.00
0.00
0.00
0.00
6,169
6,169
0.35
0.28
6,272
9/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs
(lb/day for daily, MT/yr for annual)
Daily, — — — — — —
— — — — — —
—
—
—
—
Summer
(Max)
High — — — — — —
— — — — — 1,451
1,451
0.09
0.01
1,457
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — —
— — — — — 572
572
0.04
< 0.005
574
General — — — — — —
— — — — — 479
479
0.03
< 0.005
480
Office
Building
Parking — — — — — —
— — — — — 389
389
0.02
< 0.005
391
Lot
Total — — — — — —
— — — — — 2,891
2,891
0.18
0.02
2,902
Daily, — — — — — —
— — — — — —
—
—
Winter
(Max)
High — — — — — —
— — — — — 1,451
1,451
0.09
0.01
1,457
Turnover
(Sit Down
Restaurant
Strip Mall — — — — — —
— — — — — 572
572
0.04
< 0.005
574
General — — — — — —
— — — — — 479
479
0.03
< 0.005
480
Office
Building
Parking — — — — — —
— — — — — 389
389
0.02
< 0.005
391
Lot
Total — — — — — —
— — — — — 2,891
2,891
0.18
0.02
2,902
Annual — — — — — —
— — — — — —
—
—
—
—
High — — — — — —
— 240
240
0.01
< 0.005
241
Turnover
(Sit Down
Restaurant i
10/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Strip Mall - - - -
General - -
Office
Building
Parking - - -
Lot
Total - - - - - - - - - -
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily,
Summer
(Max)
High 0.05
0.89
0.75
0.01
0.07 -
0.07
0.07 -
0.07 -
Turnover
(Sit Down
Restaurant i
Strip Mall < 0.005
0.06
0.05
< 0.005
< 0.005 -
< 0.005
< 0.005 -
< 0.005 -
General 0.01
0.13
0.11
< 0.005
0.01 -
0.01
0.01 -
0.01 -
Office
Building
Parking 0.00
0.00
0.00
0.00
0.00 -
0.00
0.00 -
0.00 -
Lot
Total 0.06
1.08
0.91
0.01
0.08 -
0.08
0.08 -
0.08 -
Daily, -
-
-
-
- -
-
- -
- -
Winter
(Max)
High 0.05
0.89
0.75
0.01
0.07 -
0.07
0.07 -
0.07 -
Turnover
(Sit Down
Restaurant
Strip Mall < 0.005
0.06
0.05
< 0.005
< 0.005 -
< 0.005
< 0.005 -
< 0.005 -
11 / 26
94.7 94.7 0.01 < 0.005 95.1
79.2 79.2 < 0.005 < 0.005 79.5
64.5 64.5 < 0.005 < 0.005 64.7
479 479 0.03 < 0.005 480
1,061 1,061 0.09 < 0.005 1,064
76.7
76.7
0.01
< 0.005
76.9
150
150
0.01
< 0.005
150
0.00
0.00
0.00
0.00
0.00
1,287
1,287
0.11
< 0.005
1,291
1,061 1,061 0.09 < 0.005 1,064
76.7 76.7 0.01 < 0.005 76.9
Enderle Center - Existing Uses Custom Report, 2/6/2024
General
0.01
0.13
0.11
< 0.005
0.01 -
0.01
0.01 -
Office
Building
Parking
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00 -
Lot
Total
0.06
1.08
0.91
0.01
0.08 -
0.08
0.08 -
Annual
-
-
-
-
- -
-
- -
High
0.01
0.16
0.14
< 0.005
0.01 -
0.01
0.01 -
Turnover
(Sit Down
Restaurant
i
Strip Mall
< 0.005
0.01
0.01
< 0.005
< 0.005 -
< 0.005
< 0.005 -
General
< 0.005
0.02
0.02
< 0.005
< 0.005 -
< 0.005
< 0.005 -
Office
Building
Parking
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00 -
Lot
Total
0.01
0.20
0.17
< 0.005
0.01 -
0.01
0.01 -
4.3. Area Emissions by Source
4.3.1. Unmitigated
0.01 -
150
150
0.01
< 0.005
150
0.00 -
0.00
0.00
0.00
0.00
0.00
0.08 -
1,287
1,287
0.11
< 0.005
1,291
0.01 -
176
176
0.02
< 0.005
176
< 0.005 -
12.7
12.7
< 0.005
< 0.005
12.7
< 0.005 -
24.8
24.8
< 0.005
< 0.005
24.8
0.00 -
0.00
0.00
0.00
0.00
0.00
0.01 -
213
213
0.02
< 0.005
214
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - - - - -
Summer
(Max)
Consumer 1.89 - - - - - - - - - - - -
Products
Architectu 0.24 - - - - - - - - - - - -
ral
Coatings
12/26
Landscap 0.62 0.03 3.79 < 0.005 0.01 - 0.01 0.01 - 0.01
e
Total 2.75 0.03 3.79 < 0.005 0.01 - 0.01 0.01 - 0.01
Daily,
Winter
(Max)
Consumer 1.89 - - - - - - - - -
Products
Architectu 0.24 - - - - - - - - -
ral
Coatings
Total 2.13
Annual
Consumer 0.34
Products
Architectu 0.04 - - - - - - - - -
ral
Coatings
Enderle Center - Existing Uses Custom Report, 2/6/2024
15.6 15.6 < 0.005 < 0.005 15.6
15.6 15.6 < 0.005 < 0.005 15.6
Landscap 0.08 < 0.005 0.47 < 0.005 < 0.005 - < 0.005 < 0.005 - < 0.005 -
e
Equipmen
t
Total 0.47 < 0.005 0.47 < 0.005 < 0.005 - < 0.005 < 0.005 - < 0.005 -
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - -
Summer
(Max)
1.77 1.77 < 0.005 < 0.005 1.77
1.77 1.77 < 0.005 < 0.005 1.77
13/26
High - - - - - -
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - - - - - - -
General - - - - - - - - - -
Office
Building
Parking - - - - - - -
Lot
Total
Daily,
Winter
(Max)
High - - - - - - - - - -
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - - -
General
Office
Building
Parking - - - - - - - - - -
Lot
Total - - - - - - - - - -
Annual - - - - - - - - - -
High - - - - - - - - - -
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - - - - - - -
General - - - - - - - - - -
Office
Building
Enderle Center - Existing Uses Custom Report, 2/6/2024
16.7 86.6 103 1.72 0.04 159
5.67
29.4
35.0
0.58
0.01
53.8
6.28
32.5
38.8
0.65
0.02
59.5
0.00
0.00
0.00
0.00
0.00
0.00
28.7
148
177
2.95
0.07
272
16.7 86.6 103 1.72 0.04 159
5.67
29.4
35.0
0.58
0.01
53.8
6.28
32.5
38.8
0.65
0.02
59.5
0.00
0.00
0.00
0.00
0.00
0.00
28.7
148
177
2.95
0.07
272
2.77
14.3
17.1
0.28
0.01
26.3
0.94 4.86 5.80 0.10 < 0.005 8.91
1.04 5.38 6.42 0.11 < 0.005 9.86
14/26
Parking - - - - - - - -
Lot
Total - - - - - - - - - -
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual and GHGs ilb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - -
Summer
(Max)
High - - - - - - - - - -
Turnover
(Sit Down
Restaurant i
Strip Mall - - - - - - - - - -
General - - - - - - - - - -
Office
Building
Parking - - - - - - - - - -
Lot
Total - - - - - - - - - -
Daily, - - - - - - - - - -
Winter
(Max)
High - - - - - - - - - -
Turnover
(Sit Down
Restaurant i
Strip Mall
Enderle Center - Existing Uses Custom Report, 2/6/2024
0.00 0.00 0.00 0.00 0.00 0.00
4.75 24.6 29.3 0.49 0.01 45.0
184 0.00 184 18.4 0.00 645
22.6
0.00
22.6
2.26
0.00
79.1
9.24
0.00
9.24
0.92
0.00
32.3
0.00
0.00
0.00
0.00
0.00
0.00
216
0.00
216
21.6
0.00
757
184 0.00 184 18.4 0.00 645
22.6 0.00 22.6 2.26 0.00 79.1
15/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
General - - - - - - -
Office
Building
Parking - - - - - - - -
Lot
Total - - - - - - - - - -
Annual - - - - - - - - - -
High - - - - - - - - - -
Turnover
(Sit Down
Restaurant i
Strip Mall
General
Office
Building
Parking - - - - - - - - - -
Lot
Total - - - - - - - - - -
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
9.24
0.00
9.24
0.92
0.00
32.3
0.00
0.00
0.00
0.00
0.00
0.00
216
0.00
216
21.6
0.00
757
30.5
0.00
30.5
3.05
0.00
107
3.74
0.00
3.74
0.37
0.00
13.1
1.53
0.00
1.53
0.15
0.00
5.35
0.00
0.00
0.00
0.00
0.00
0.00
35.8
0.00
35.8
3.58
0.00
125
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, - - - - - - - - - - - - -
Summer
(Max)
High - - - - - - - - - - - - -
Turnover
(Sit Down
Restaurant i
44.9
Strip Mall - - - - - - - - - - - - - - - 0.25
16/26
General — — — — — — —
Office
Building
Total — — — — — — — — — —
Daily, — — — — — — — — — —
Winter
(Max)
High — — — — — — — — — —
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — — — — —
General — — — — — — — — — —
Office
Building
Total — — — — — — — — — —
Annual — — — — — — — — — —
High — — — — — — — — — —
Turnover
(Sit Down
Restaurant i
Strip Mall — — — — — — — — — —
General — — — — — — — — — —
Office
Building
Total — — — — — — — — — —
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Enderle Center - Existing Uses Custom Report, 2/6/2024
0.04
45.2
44.9
0.25
0.04
45.2
7.44
0.04
0.01
7.49
17/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Daily,
Summer
(Max)
Total — — — — — — — — — —
Daily, — — — — — — — — — —
Winter
(Max)
Total — — — — — — —
Annual — — — — — — — —
Total — — — — — — — —
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — —
Daily, — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — —
Annual — — — — — — — — — —
Total — — — — — — — — — —
18/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Total— — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — — — — —
19/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Annual — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — —
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — —
Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Daily, — — — — — — — — — — — — — — — —
Summer
(Max)
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Sequester — — — — — — — — — — — — — — — —
ed
Subtotal — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
20/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Daily,
Winter
(Max)
Avoided
Subtotal
Sequester
ed
Subtotal
Removed
Subtotal
Annual — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Sequester — — — — — — — — — — — — — — — —
ed
Subtotal — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — —
5. Activity Data
5.9. Operational Mobile Sources
5.9.1. Unmitigated
21 / 26
Enderle Center - Existing Uses Custom Report, 2/6/2024
High Turnover (Sit
3,082
3,082
3,082
1,124,930
10,180
25,757
25,757
5,340,281
Down Restaurant)
Strip Mall
3,776
3,776
3,776
1,378,174
31,556
31,556
31,556
11,517,849
General Office
200
200
200
72,904
1,669
1,669
1,669
609,285
Building
Parking Lot
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
0 0.00
5.10.3. Landscape Equipment
Snow Days
Summer Days
130,704
43,568
day/yr 0.00
day/yr 250
5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N20 and Natural Gas (kBTU/yr)
- •MNMM
•
18,295
22 / 26
Enderle Center - Existing Uses Custom Report, 2/6/2024
High Turnover (Sit Down
995,622
532
0.0330
0.0040
3,310,034
Restaurant)
Strip Mall
392,462
532
0.0330
0.0040
239,238
General Office Building
328,357
532
0.0330
0.0040
467,034
Parking Lot
267,110
532
0.0330
0.0040
0.00
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
High Turnover (Sit Down Restaurant) 8,726,594 0.00
Strip Mall 2,959,938 0.00
General Office Building 3,274,922 0.00
Parking Lot 0.00 0.00
5.13. Operational Waste Generation
5.13.1. Unmitigated
High Turnover (Sit Down Restaurant) 342 —
Strip Mall 42.0 —
General Office Building 17.1 —
Parking Lot 0.00 —
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
23/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
High Turnover (Sit
Household refrigerators
R-134a
1,430
0.00
0.60
0.00
1.00
Down Restaurant)
and/or freezers
High Turnover (Sit
Other commercial A/C
R-410A
2,088
1.80
4.00
4.00
18.0
Down Restaurant)
and heat pumps
High Turnover (Sit
Walk-in refrigerators
R-404A
3,922
< 0.005
7.50
7.50
20.0
Down Restaurant)
and freezers
Strip Mall
Other commercial A/C
R-410A
2,088
< 0.005
4.00
4.00
18.0
and heat pumps
Strip Mall
Stand-alone retail
R-134a
1,430
0.04
1.00
0.00
1.00
refrigerators and
freezers
Strip Mall
Walk-in refrigerators
R-404A
3,922
< 0.005
7.50
7.50
20.0
and freezers
General Office Building
Household refrigerators
R-134a
1,430
0.02
0.60
0.00
1.00
and/or freezers
General Office Building
Other commercial A/C
R-410A
2,088
< 0.005
4.00
4.00
18.0
and heat pumps
5.15. Operational
Off -Road Equipment
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
24/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
8. User Changes to Default Data
Land Use The project site is approximately 11.80 acres. Of the site area, 7 acres within the southeastern portion
of the project site have been identified as suitable for housing development. These 7 acres are
currently made up of paved parking areas.
25/26
Enderle Center - Existing Uses Custom Report, 2/6/2024
Operations: Vehicle Data
The existing uses generate approximately 7,058 average daily trips.
Operations: Hearths Assuming no wood burning hearths.
26 / 26
AIR QUALITY, ENERGY, AND GREENHOUSE GAS IMPACT REPORT
MAY 2024
APPENDIX B
ENDE RUE CENTER PROTECT L S A
CITY OF TUSTI N, CALIFORNIA
DETAILED ENERGY CALCULATIONS
\\aznasunifilerl\projects\ESL2201.76\Products\AQ\Tustin Enderle Center Project - AQ Report 050124.docx (05/01/24)
Construction Off -Road Equipment
Phase
Off -Road Equipment Type
Amount
Usage Hour/Day
Total Usage
Days
Total Usage
Hours/Equipment
Horsepower
Load Factor
Total Usage Hours/ Equipment
Horsepower -Hour
Fuel Usage
(gallons)
Concrete/Industrial Saws
1
8
20
160
33
0.73
160
3854.4
197.34528
Demolition
Excavators
3
8
20
480
36
0.38
480
6566.4
336.19968
Rubber Tired Dozers
2
8
20
320
367
0.4
320
46976
2405.1712
Rubber Tired Dozers
3
8
10
240
367
0.4
240
35232
1803.8784
Site Preparation
Tractors/Loaders/Backhoes
4
8
10
320
84
0.37
320
9945.6
509.21472
Excavators
2
8
30
480
36
0.38
480
6566.4
336.19968
Grading
Graders
1
8
30
240
148
0.41
240
14563.2
745.63584
Rubber Tired Dozers
1
8
30
240
367
0.4
240
35232
1803.8784
Scrapers
2
8
30
480
423
0.48
480
97459.2
4989.91104
Tractors/Loaders/Backhoes
2
8
30
480
84
0.37
480
14918.4
763.82208
Cranes
1
7
300
2100
367
0.29
2100
223503
11443.3536
Forklifts
3
8
300
7200
82
0.2
7200
118080
6045.696
Building Construction
Generator Sets
1
8
300
2400
14
0.74
2400
24864
1273.0368
Tractors/Loaders/Backhoes
3
7
300
6300
84
0.37
6300
195804
10025.1648
Welders
1
8
300
2400
46
0.45
2400
49680
2543.616
Pavers
2
8
20
320
81
0.42
320
10886.4
557.38368
Paving
Paving Equipment
2
8
20
320
89
0.36
320
10252.8
524.94336
Rollers
2
8
20
320
36
0.38
320
4377.6
224.13312
Architectural Coating
Air Compressors
1
6
100
600
37
0.48
600
10656
545.5872
Tota I
47074.17088
Diesel
Construction Truck and
Construction Worker Vehicle Fuel Efficiency
Vehicle Type
Vehicle Class
EMFAC 2021 Outputs
Fuel Consumption (1,000
gallons/day)
VMT (miles/
day)
Fuel Efficency
(miles/gallon)
Construction Truck
MHDT
129.3
1,155,908.7
8.9
HHDT
202.3
1,220,548.3
6.0
HHDT/MHDT
-
-
7.5
Construction Worker
Vehicle
LDA
1408.4
42,285,386.1
30.0
LDT1
139.0
3,495,530.4
25.2
LDT2
872.9
21,321,177.5
24.4
Worker Mix
-
-
27.4
Notes
1 For construction trucks assumes 50 percent HHDT and 50 percent MHDT vehicles, consistent with assumptions in CalEEMod for hauling trucks. For construction worker vehicles assumes 50 percent LDA, 25 percent LDT1, and 25 percent LDT2 vehicles, consistent with assumptions in CalEEMod for worker vehicles.
Z EMFAC2021 was run for Orange County for the construction year 2024. Data was aggregated over all vehicle model years and speed bins.
3 The fuel efficiency was calculated by dividing the VMT (miles/day) by the fuel consumption (gallons/day)
Construction Vehicle
Fuel Use - Diesel Vehicles
Phase
Trip Type
Total Trips
Trip Length
(miles)
Total VMT
Diesel Fuel Effiency (miles/gallon)
Fuel Usage
(gallons/year)
Demolition
Hauling
5,520.0
20.0
110,400.0
6.0
18,298.3
Building Construction
Vendor
38,400.0
10.2
391,680.0
7.5
52,317.8
Total
70,616.1
1 Assumes 100 percent HHDT vehicles for haul trucks and 50 percent HHDT/50 percent MHDT vehicles for MHDT, consistent with assumptions in CalEEMod.
Z EMFAC2021 was run for Orange County for the construction year 2024. Data was aggregated over all vehicle model years and speed bins.
3 The fuel efficiency was calculated by dividing the VMT (miles/day) by the fuel consumption (gallons/day)
Construction Worker Vehicle
Fuel Use - Gasoline Vehicles
Phase
Total One -
Way
Trips/Day
Total Days
Total Trips
Trip Length
(miles)
Total VMT
Gasoline Fuel Effiency (miles/gallon)
Fuel Usage
(gallons/year)
Demolition
15
20
600
18.5
11,100
27.4
405.0
Site Preparation
18
10
360
18.5
6,660
27.4
243.0
Grading
20
30
1,200
18.5
22,200
27.4
810.0
Building Construction
339
300
203,400
18.5
3,762,900
27.4
137,301.7
Paving
15
20
600
18.5
11,100
27.4
405.0
Architectural Coating
68
100
13,600
18.51
251,600
27.4
9,180.4
Tota I
148,345.3
Total Construction Gasoline Usage 148,345.3
Total Construction Diesel Usage 117,690.3
Diesel
Gas
Proposed Project Operational Trips
Vehicle Class
CalEEMod
Total Project
Trips
Total Trips per
Vehicle Class
LDA
50.24%
18,528
9,308.5
LDT1
22.92%
18,528
4,246.6
LDT2
2.71%
18,528
502.1
MDV
14.42%
18,528
2,671.7
LHD1
4.22%
18,528
781.9
LHD2
0.69%
18,528
127.8
MHD
1.52%
18,528
281.6
HHD
0.54%
18,528
100.1
OBUS
0.06%
18,528
11.1
UBUS
0.04%
18,528
7.4
MCY
2.16%
18,528
400.2
SBUS
0.10%
18,528
18.5
MH
0.39%
18,528
72.3
Proposed Project Operational Trips- Fuel Efficiency
Fuel
Vehicle Class
EMFAC2021 Outputsl
Fleet Mix
(%)2
Fuel ConsumptionFuel
(1,000
gallons/day)
VMT (miles/day)
Efficiency3
(miles/gallon)
Gas
LDA
52%
1408.4
42,285,386.1
30.0
LDT1
4%
139.0
3,495,530.4
25.2
LDT2
26%
872.9
21,321,177.5
24.4
MDV
15%
635.4
12,620,485.4
19.9
LHD1
2%
118.3
1,661,882.0
14.0
MCY
0%
7.6
321,576.6
42.2
M H
0%
12.0
58,495.6
4.9
Fleet Mix
-
-
-
26.5
Diesel
LHD2
14%
22.4
391,527.7
17.5
MHDT
42%1
129.3
1,155,908.7
8.9
HHDT
44%1
202.3
1,220,548.3
6.0
Fleet Mix
-
-
-
8.9
Notes:
1 EMFAC2021 was run for Orange County for the year 2024. Data was aggregated over all vehicle model years and speed bins.
Z Fleet mix is based on assumptions made in CalEEMod for the proposed project.
3 The fuel efficiency was calculated by dividing the VMT (miles/day) by the fuel consumption (gallons/day)
Proposed Project Operational Trips - Fuel Usage
Land Use
Total Annual VMT2
(miles/year)
Fuel Type
Portion of Fleet3
N
VMT by Fuel Type
(miles/year)
Fleet Mix Efficiency4
(miles/gallon)
Fuel Usage (gallons/
year)
Apartments Mid Rise
6,627,917.00
Gas
°
97.2%
6,442,335.3
26.5
243,177.6
Diesel
2.8%
182,267.7
8.9
20,566.1
High Turnover
Restaurant
12, 600, 648.00
Gas
97.2%
12,247,829.9
26.5
462,316.5
Diesel
2.8%
346,517.8
8.9
39,099.1
Strip Mall
27,177,052.00
Gas
97.2%
26,416,094.5
26.5
997,123.4
Diesel
2.8%
747,368.9
8.9
84,328.9
General Office Building
1,437,636.00
Gas
97.2%
1,397,382.2
26.5
52,746.7
Diesel
2.8%1
39,535.0
8.9
1 4,460.9
Total Gasoline/year
1,755,364.2
Total Diesel/year
1148,454.9
Notes:
1 Calculated for year 2024 only. Future years will likely use less fuel due to more efficient cars.
Z Total VMT is based on project's trip generation and trip lengths.
3 Fleet distribution is based on EMFAC2021 output and CalEEMod assumptions.
4 Fuel efficiency is based on fuel consumption and VMT data from EMFAC2021 for Orange County and total VMT.
15.5
1.1
6.4
3.1
0.3
0.2
0.0
26.5
2.5
3.7
2.7
8.9
Proposed Project Electricity Usage
Electricity by Land Use
kWh/year
Apartments Mid Rise
1,513,989
High Turnover Restaurant
21349,217
Strip Mall
926,037
General Office Building
774,773
Total
5,564,016
Proposed Project Natural Gas Usage
Natural Gas by Land Use
kBTU/year
BTU/year
therms/year
Apartments Mid Rise
4,587,126
4,587,126,000
45,880
High Turnover Restaurant
7,810,183
7,810,183,000
78,117
Strip Mall
564,497
564,497,000
5,646
General Office Building
1,101,988
1,101,988,000
11,022
Total
14,063,794
14,063,794,000
140,666
Existing Uses Operational Trips
Vehicle Class
CalEEMod
Total Project
Trips
Total Trips per
Vehicle Class
LDA
50.24%
7,058
3,545.9
LDT1
4.22%
7,058
297.8
LDT2
22.92%
7,058
1,617.7
MDV
14.42%
7,058
1,017.8
LHD1
2.71%
7,058
191.3
LHD2
0.69%
7,058
48.7
MHD
1.52%
7,058
107.3
HHD
0.54%
7,058
38.1
OBUS
0.06%
7,058
4.2
UBUS
0.04%
7,058
2.8
MCY
2.16%
7,058
152.5
SBUS
0.10%
7,058
7.1
MH
0.39%
7,058
27.5
Existing Uses Operational Trips - Fuel Efficiency
Fuel
Vehicle Class
EMFAC2021 Outputsl
Fleet Mix
(%)2
Fuel ConsumptionFuel
(1,000
gallons/day)
VMT (miles/day)
Efficiency3
(miles/gallon)
Gas
LDA
52%
1408.4
42,285,386.1
30.0
LDT1
4%
139.0
3,495,530.4
25.2
LDT2
26%
872.9
21,321,177.5
24.4
MDV
15%
635.4
12,620,485.4
19.9
LHD1
2%
118.3
1,661,882.0
14.0
MCY
0%
7.6
321,576.6
42.2
M H
0%
12.0
58,495.6
4.9
Fleet Mix
-
-
-
26.5
Diesel
LHD2
14%
22.4
391,527.7
17.5
MHDT
42%1
129.3
1,155,908.7
8.9
HHDT
44%1
202.3
1,220,548.3
6.0
Fleet Mix
-
-
-
8.9
Notes:
1 EMFAC2021 was run for Orange County for the year 2024. Data was aggregated over all vehicle model years and speed bins.
Z Fleet mix is based on assumptions made in CalEEMod for the proposed project.
3 The fuel efficiency was calculated by dividing the VMT (miles/day) by the fuel consumption (gallons/day)
Existing Uses Operational Trips
- Fuel Usage
Land Use
Total Annual VMT2
(miles/year)
Fuel Type
Portion of Fleet3
N
VMT by Fuel Type
(miles/year)
Fleet Mix Efficiency4
(miles/gallon)
Fuel Usage (gallons/
year)
High Turnover
Restaurant
5,340,281.00
Gas
97.2%
5,190,753.1
26.5
195,934.4
Diesel
2.8%
146,857.7
8.9
16,570.E
Strip Mall
11,517,849.00
Gas
97.2%
11,195,349.2
26.5
422,588.7
Diesel
2.8%
316,740.8
8.9
35,739.2
General Office Building
609,285.00
Gas
97.2%
592,225.0
26.5
22,354.6
Diesel
2.8%
16,755.3
8.9
1,890.6
Total Gasoline/year
640,877.7
Total Diesel/year
54,200.4
Notes:
1 Calculated for year 2024 only. Future years will likely use less fuel due to more efficient cars.
Z Total VMT is based on project's trip generation and trip lengths.
3 Fleet distribution is based on EMFAC2021 output and CalEEMod assumptions.
° Fuel efficiency is based on fuel consumption and VMT data from EMFAC2021 for Orange County and total VMT.
15.5
1.1
6.4
3.1
0.3
0.2
0.0
26.5
2.5
3.7
2.7
8.9
Existing Uses Electricity Usage
Electricity by Land Use
kWh/year
High Turnover Restaurant
995,622
Strip Mall
392,462
General Office Building
328,357
Parking Lot
267,770
Total
1,984,211
Existing Uses Natural Gas Usage
Natural Gas by Land Use
kBTU/year
BTU/year
therms/year
High Turnover Restaurant
3,310,034
3,310,034,000
33,107
Strip Mall
239,238
239,238,000
2,393
General Office Building
467,034
467,034,000
4,671
Total
4,016,306
1 4,016,306,000
40,171
Appendix C
Noise and Vibration Impact Analysis
NOISE AND VIBRATION IMPACT ANALYSIS
ENDERLE CENTER PROJECT
CITY OF TUSTIN, CALIFORNIA
LSA
March 2024
NOISE AND VIBRATION IMPACT ANALYSIS
ENDERLE CENTER PROJECT
CITY OF TUSTIN, CALIFORNIA
Submitted to:
EPD Solutions, Inc.
3333 Michelson Drive, Suite 500
Irvine, California 92612
Prepared by:
LSA
3210 El Camino Real, Suite 100
Irvine, California 92602
(949) 553-0666
Project No. ESL2201.76
LSA
March 2024
NOISE AND VIBRATION IMPACT ANALYSIS TuSTIN ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
TABLE OF CONTENTS
TABLEOF CONTENTS............................................................................................................................... i
LIST OF ABBREVIATIONS AND ACRONYMS............................................................................................
iii
PROJECTLOCATION....................................................................................................
5
PROJECT DESCRIPTION................................................................................................
5
EXISTING LAND USES IN THE PROJECT AREA................................................................
8
CHARACTERISTICS OF SOUND...................................................................................
10
MEASUREMENT OF SOUND.......................................................................................
10
Physiological Effects of Noise......................................................................................................11
FUNDAMENTALS OF VIBRATION...............................................................................
13
APPLICABLE NOISE STANDARDS................................................................................
15
California Code of Regulations....................................................................................................15
Cityof Tustin................................................................................................................................
15
FederalTransit Administration....................................................................................................
17
APPLICABLE VIBRATION STANDARDS........................................................................
17
Federal Transit Administration....................................................................................................17
AMBIENT NOISE MEASUREMENTS............................................................................
19
Long -Term Noise Measurements................................................................................................
19
EXISTING AIRCRAFT NOISE........................................................................................
19
SHORT-TERM CONSTRUCTION NOISE IMPACTS.........................................................
21
SHORT-TERM CONSTRUCTION VIBRATION IMPACTS .................................................
24
LONG-TERM OFF -SITE TRAFFIC NOISE IMPACTS.........................................................
26
LONG-TERM TRAFFIC -RELATED VIBRATION IMPACTS ................................................
26
LONG-TERM STATIONARY NOISE IMPACTS................................................................
26
EXTERIOR NOISE ASSESSMENT..................................................................................
28
INTERIOR NOISE ASSESSMENT..................................................................................
28
APPENDICES
A: Noise Monitoring Sheets
B: Construction Noise Level Calculations
C: FHWA Traffic Noise Model Printouts
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NOISE AND VIBRATION IMPACT ANALYSIS TuSTIN ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J A
FIGURES AND TABLES
FIGURES
Figure1: Project Location....................................................................................................................... 6
Figure2: Project Site.............................................................................................................................. 7
Figure 3: Noise Monitoring Locations.................................................................................................. 20
TABLES
Table A: Definitions of Acoustical Terms..............................................................................................
12
Table B: Common Sound Levels and Their Noise Sources....................................................................
13
Table C: City of Tustin Interior and Exterior Noise Standards..............................................................
15
Table D: City of Tustin Maximum Noise Level Standards.....................................................................
16
Table E: General Assessment Construction Noise Criteria...................................................................
17
Table F: Interpretation of Vibration Criteria for Detailed Analysis......................................................
17
Table G: Construction Vibration Damage Criteria................................................................................
18
Table H: Long -Term 24-Hour Ambient Noise Monitoring Results' ......................................................
19
Table I: Typical Construction Equipment Noise Levels.........................................................................
22
Table J: Potential Construction Noise Impacts at Nearest Receptor ...................................................
23
Table K: Vibration Source Amplitudes for Construction Equipment ....................................................
24
Table L: Potential Construction Vibration Annoyance Impacts at Nearest Receptor ..........................25
Table M: Potential Construction Vibration Damage Impacts at Nearest Receptor .............................25
Table N: Traffic Noise Levels Without and With Proposed Project ......................................................
27
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NOISE AND VIBRATION IMPACT ANALYSIS
MARCH 2O24
TuSTIN ENDERLE CENTER PROJECT C A
CITY OF TuSTIN, CALIFORNIA J A
LIST OF ABBREVIATIONS AND ACRONYMS
APN
Assessor's Parcel Numbers
City
City of Tustin
CNEL
Community Noise Equivalent Level
County
County of Orange
dBA
A -weighted decibel
du/ac
dwelling units per acre
FHWA
Federal Highway Administration
ft
foot/feetFeet
FTA
Federal Transit Administration
GPA
General Plan Amendment
HOD
Housing Overlay District
HVAC
heating, ventilation, and air conditioning
in/sec
inches per second
JWA
John Wayne Airport
Ldn
day -night average noise level
Leq
equivalent continuous sound level
Lmax
maximum instantaneous sound level
PC COM
Planned Community Commercial
PCCB
Planned Community Commercial/ Business
PPV
peak particle velocity
project
Enderle Center Project
RHNA
Regional Housing Needs Allocation
RMS
root -mean -square
sf
square feet
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NOISE AND VIBRATION IMPACT ANALYSIS
MARCH 2O24
SR-55 State Roue 55
STC Sound Transmission Class
TMC Tustin Municipal Code
VdB vibration velocity decibels
ZC Zone Change
ZCA Zoning Code Amendment
TuSTIN ENDERLE CENTER PROJECT C A
CITY OF TuSTIN, CALIFORNIA J A
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
INTRODUCTION
This noise and vibration impact analysis has been prepared to evaluate the potential noise and
vibration impacts and reduction measures associated with the Enderle Center Project (project) in
Tustin, California. This report is intended to satisfy the City of Tustin (City) requirement for a project -
specific noise impact analysis by examining the impacts of the project site and evaluating noise
reduction measures that the project may require.
PROJECT LOCATION
The 11.8-acre project site consists of Assessor's Parcel Numbers (APNs) 401-251-04, -06; 401-252-
05, -06, -08, -09, -10; and 401-253-04 and -03. The project site is generally bounded on the north by
17t" Street; on the east by Enderle Center Drive and the eastern property line of properties fronting
Enderle Center Drive; to the south by Vandenberg Lane; and to the west by State Roue 55 (SR-55),
including properties west of Yorba Street. The project location is shown in Figure 1.
The Enderle Center is currently developed with 87,136 square feet (sf) of commercial business uses,
including 28,750 sf of restaurant use, 39,960 sf of retail and service use, 18,426 sf of office use, and
surface parking lots. The site also includes ornamental landscaping along the perimeter and
throughout the parking areas. See Figure 2.
The project site has a General Plan land use designation of Planned Community Commercial/
Business (PCCB) and a zoning designation of Planned Community Commercial (PC COM). The PCCB
land use designation provides opportunities for a variety of miscellaneous retail, professional office,
and service -oriented business activities. The PC COM zoning is intended to allow diversification of
the relationships of various buildings, structures and open spaces in planned building groups while
ensuring substantial compliance with the housing district regulations and other provisions of the
Planned Community District zone.
PROJECT DESCRIPTION
The City of Tustin prepared the 2021-2029 Housing Element of its General Plan in accordance with
Government Code Section 65580 et seq. The City is required by State law to periodically update its
Housing Element, a mandatory component of the City's General Plan. The update to the Housing
Element covers the Sixth Cycle planning period from October 15, 2021, to October 15, 2029.
The Housing Element is the City's housing policy and planning document that identifies housing
needs and constraints, and sets forth goals, policies, and programs that address the future housing
needs for all income levels over an eight -year planning period that coincides with a Regional Housing
Needs Allocation (RHNA). During the Housing Element process, the City assessed a number of
properties and areas throughout the community that would be able to accommodate the City's
assigned RHNA. Of the Housing Element inventory sites, Enderle Center (the project site) was
identified as necessary for rezoning under Housing Element Program 1.1f to allow for high density
residential/mixed use development.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
Pursuant to Housing Element Program 1.1f, the City is proposing an overlay zone (overlay district)
for the project site. To accommodate this, a General Plan Amendment (GPA) is needed to allow a
Housing Overlay District (residential uses) within Planned Community Commercial/Business land use
designations; a Zoning Code Amendment (ZCA) to establish Housing Overlay Districts (overlay zone)
in conjunction with the Planned Community Commercial Districts (base zone); and a Zone Change
(ZC) that amends the City's zoning map to apply a Housing Overlay District (HOD) to the project site.
The proposed HOD would allow for residential development with a maximum density of 59 dwelling
units per acre (du/ac) over a maximum development area of 7 acres.
The Housing Element identified the Enderle Center as having capacity for 413 housing units. The
anticipated development density was determined through the Housing Element process, and is a
conservative estimate based on development trends in nearby communities. The anticipated
development does not rely on the demolition of any existing building, but rather focuses on areas
used for surface parking. No development is proposed as part of this project.
During the Housing Element process, the City identified the Enderle Center as a suitable commercial
site for rezoning to allow mixed -use development, which would introduce the opportunity to allow
higher density housing in either horizontal or vertical mixed -use development on the site. This
would be accomplished with a Housing Overlay Zone. The proposed project includes a GPA to
amend the City's existing General Plan to create a Housing Overlay Zone and establish that the
overlay zone will be applied within, and be consistent with, the Planned Community Commercial
Business land use designation. The GPA will amend the text within the Land Use Element to clarify
the purpose and function of the Housing Overlay Zone, and describe how the Housing Overlay Zone
implements the General Plan goals and policies.
Residential uses are currently not allowed on the project site. Upon approval of the Housing Overlay
Zone, the project site could accommodate 413 units over approximately 7 acres of developable land
within the existing 11.8-acre site. The anticipated development over 7 acres would take place on
underutilized asphalt parking lot areas, and not require demolition of any existing buildings. Parking
displaced as a result of redevelopment would be accommodated by vertical parking structures
located within the proposed development.
Roadways and utilities may be required to support development of future residential construction
within the project site. However, specific infrastructure improvements required to support
residential development within the Enderle Center are not known at this time and will not be known
until a development project is proposed.
EXISTING LAND USES IN THE PROJECT AREA
The project site is surrounded primarily by residential, commercial, and office uses. The areas
adjacent to the project site include the following uses:
• North: Commercial uses opposite of 17t" Street
• East: Commercial and office uses opposite of Enderle Center Drive
• South: Residential uses opposite of Vandenberg Lane
• West: Commercial and office uses opposite of SR-55
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
The closest sensitive receptors to the project site are residential uses, located approximately 70 feet
south of the project's site boundary.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J A
NOISE AND VIBRATION FUNDAMENTALS
CHARACTERISTICS OF SOUND
Noise is usually defined as unwanted sound. Noise consists of any sound that may produce
physiological or psychological damage and/or interfere with communication, work, rest, recreation,
and sleep.
To the human ear, sound has two significant characteristics: pitch and loudness. Pitch is generally an
annoyance, while loudness can affect the ability to hear. Pitch is the number of complete vibrations,
or cycles per second, of a sound wave, which results in the tone's range from high to low. Loudness
is the strength of a sound, and it describes a noisy or quiet environment; it is measured by the
amplitude of the sound wave. Loudness is determined by the intensity of the sound waves
combined with the reception characteristics of the human ear. Sound intensity is the average rate of
sound energy transmitted through a unit area perpendicular to the direction in which the sound
waves are traveling. This characteristic of sound can be precisely measured with instruments. The
analysis of a project defines the noise environment of the project area in terms of sound intensity
and its effect on adjacent sensitive land uses.
MEASUREMENT OF SOUND
Sound intensity is measured with the A -weighted decibel (dBA) scale to correct for the relative
frequency response of the human ear. That is, an A -weighted noise level de-emphasizes low and
very high frequencies of sound, similar to the human ear's de -emphasis of these frequencies.
Decibels (dB), unlike the linear scale (e.g., inches or pounds), are measured on a logarithmic scale
representing points on a sharply rising curve.
For example, 10 dB is 10 times more intense than 0 dB, 20 dB is 100 times more intense than 0 dB,
and 30 dB is 1,000 times more intense than 0 dB. Thirty decibels (30 dB) represents 1,000 times as
much acoustic energy as 0 dB. The decibel scale increases as the square of the change, representing
the sound pressure energy. A sound as soft as human breathing is about 10 times greater than 0 dB.
The decibel system of measuring sound gives a rough connection between the physical intensity of
sound and its perceived loudness to the human ear. A 10 dB increase in sound level is perceived by
the human ear as only a doubling of the sound's loudness. Ambient sounds generally range from
30 dB (very quiet) to 100 dB (very loud).
Sound levels are generated from a source, and their decibel level decreases as the distance from
that source increases. Sound levels dissipate exponentially with distance from their noise sources.
For a single point source, sound levels decrease approximately 6 dB for each doubling of distance
from the source. This drop-off rate is appropriate for noise generated by stationary equipment.
If noise is produced by a line source (e.g., highway traffic or railroad operations), the sound
decreases 3 dB for each doubling of distance in a hard site environment. Line source sound levels
decrease 4.5 dB for each doubling of distance in a relatively flat environment with absorptive
vegetation.
There are many ways to rate noise for various time periods, but an appropriate rating of ambient
noise affecting humans also accounts for the annoying effects of sound. The equivalent continuous
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2O24 CITY OF TuSTIN, CALIFORNIA J `(\
sound level (Leq) is the total sound energy of time -varying noise over a sample period. However, the
predominant rating scales for human communities in the State of California are the Leq and
Community Noise Equivalent Level (CNEL) or the day -night average noise level (Ldn) based on
A -weighted decibels. CNEL is the time -weighted average noise over a 24-hour period, with a
5 dBA weighting factor applied to the hourly Leq for noises occurring from 7:00 p.m. to 10:00 p.m.
(defined as relaxation hours) and a 10 dBA weighting factor applied to noises occurring from
10:00 p.m. to 7:00 a.m. (defined as sleeping hours). Ldn is similar to the CNEL scale but without the
adjustment for events occurring during the relaxation. CNEL and Ldn are within 1 dBA of each other
and are normally interchangeable. The City of Tustin uses the CNEL noise scale for long-term traffic
noise impact assessment.
Other noise rating scales of importance when assessing the annoyance factor include the maximum
instantaneous noise level (Lmax), which is the highest sound level that occurs during a stated time
period. The noise environments discussed in this analysis for short-term noise impacts are specified
in terms of maximum levels denoted by Lmax, which reflects peak operating conditions and addresses
the annoying aspects of intermittent noise. It is often used together with another noise scale, or
noise standards in terms of percentile noise levels, in noise ordinances for enforcement purposes.
For example, the L10 noise level represents the noise level exceeded 10 percent of the time during a
stated period. The L5o noise level represents the median noise level. Half the time the noise level
exceeds this level, and half the time it is less than this level. The L90 noise level represents the noise
level exceeded 90 percent of the time and is considered the background noise level during a
monitoring period. For a relatively constant noise source, the Leq and L5o are approximately the
same.
Noise impacts can be described in three categories. The first category includes audible impacts,
which are increases in noise levels noticeable to humans. Audible increases in noise levels generally
refer to a change of 3 dB or greater because this level has been found to be barely perceptible in
exterior environments. The second category, potentially audible, refers to a change in the noise
level between 1 dB and 3 dB. This range of noise levels has been found to be noticeable only in
laboratory environments. The last category includes changes in noise levels of less than 1 dB, which
are inaudible to the human ear. Only audible changes in existing ambient or background noise levels
are considered potentially significant.
Physiological Effects of Noise
Physical damage to human hearing begins at prolonged exposure to sound levels higher than
85 dBA. Exposure to high sound levels affects the entire system, with prolonged sound exposure in
excess of 75 dBA increasing body tensions, thereby affecting blood pressure and functions of the
heart and the nervous system. In comparison, extended periods of sound exposure above
90 dBA would result in permanent cell damage. When the sound level reaches 120 dBA, a tickling
sensation occurs in the human ear, even with short-term exposure. This level of sound is called the
threshold of feeling. As the sound reaches 140 dBA, the tickling sensation is replaced by a feeling of
pain in the ear (i.e., the threshold of pain). A sound level of 160-165 dBA will result in dizziness or a
loss of equilibrium. The ambient or background noise problem is widespread and generally more
concentrated in urban areas than in outlying, less developed areas.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J A
Table A lists definitions of acoustical terms, and Table B shows common sound levels and their
sources.
Table A: Definitions of Acoustical Terms
Term
Definitions
Decibel, dB
A unit of sound measurement that denotes the ratio between two quantities that are
proportional to power; the number of decibels is 10 times the logarithm (to the base 10) of
this ratio.
Frequency, Hz
Of a function periodic in time, the number of times that the quantity repeats itself in 1
second (i.e., the number of cycles per second).
A -Weighted Sound
The sound level obtained by use of A -weighting. The A -weighting filter de-emphasizes the
Level, dBA
very low and very high frequency components of the sound in a manner similar to the
frequency response of the human ear and correlates well with subjective reactions to noise.
(All sound levels in this report are A -weighted unless reported otherwise.)
Lot, Lio, Lso, Leo
The fast A -weighted noise levels that are equaled or exceeded by a fluctuating sound level
1%, 10%, 50%, and 90% of a stated time period, respectively.
Equivalent Continuous
The level of a steady sound that, in a stated time period and at a stated location, has the
Noise Level, Leq
same A -weighted sound energy as the time -varying sound.
Community Noise
The 24-hour A -weighted average sound level from midnight to midnight, obtained after the
Equivalent Level, CNEL
addition of 5 dBA to sound levels occurring in the evening from 7:00 p.m. to 10:00 p.m. and
after the addition of 10 dBA to sound levels occurring in the night between 10:00 p.m. and
7:00 a.m.
Day/Night Noise Level,
The 24-hour A -weighted average sound level from midnight to midnight, obtained after the
Ldn
addition of 10 dBA to sound levels occurring in the night between 10:00 p.m. and 7:00 a.m.
Lmax, Lmin
The maximum and minimum A -weighted sound levels measured on a sound level meter,
during a designated time interval, using fast time averaging.
Ambient Noise Level
The all -encompassing noise associated with a given environment at a specified time. Usually
a composite of sound from many sources from many directions, near and far; no particular
sound is dominant.
Intrusive
The noise that intrudes over and above the existing ambient noise at a given location. The
relative intrusiveness of a sound depends upon its amplitude, duration, frequency, time of
occurrence, and tonal or informational content, as well as the prevailing ambient noise level.
Source: Sources: (1) Technical Noise Supplement (Caltrans 2013); (2) Transit Noise and Vibration Impact Assessment Manual (FTA
2018).
Caltrans = California Department of Transportation
FTA = Federal Transit Administration
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TLISTIN, CALIFORNIA J `(\
Table B: Common Sound Levels and Their Noise Sources
Noise Source
A -Weighted Sound
Level in Decibels
Noise Environments
Subjective
Evaluations
Near Jet Engine
140
Deafening
128 times as loud
Civil Defense Siren
130
Threshold of Pain
64 times as loud
Hard Rock Band
120
Threshold of Feeling
32 times as loud
Accelerating Motorcycle at a Few Feet Away
110
Very Loud
16 times as loud
Pile Driver; Noisy Urban Street/Heavy City
Traffic
100
Very Loud
8 times as loud
Ambulance Siren; Food Blender
95
Very Loud
—
Garbage Disposal
90
Very Loud
4 times as loud
Freight Cars; Living Room Music
85
Loud
—
Pneumatic Drill; Vacuum Cleaner
80
Loud
2 times as loud
Busy Restaurant
75
Moderately Loud
—
Near Freeway Auto Traffic
70
Moderately Loud
Reference level
Average Office
60
Quiet
One-half as loud
Suburban Street
55
Quiet
—
Light Traffic; Soft Radio Music in Apartment
50
Quiet
One -quarter as loud
Large Transformer
45
Quiet
—
Average Residence without Stereo Playing
40
Faint
One -eighth as loud
Soft Whisper
30
Faint
—
Rustling Leaves
20
Very Faint
—
Human Breathing
10
Very Faint
Threshold of Hearing
—
0
Very Faint
—
Source: Compiled by LSA (2021).
FUNDAMENTALS OF VIBRATION
Vibration refers to ground -borne noise and perceptible motion. Ground -borne vibration is almost
exclusively a concern inside buildings and is rarely perceived as a problem outdoors, where the
motion may not be discernible, but without the effects associated with the shaking of a building
there is less adverse reaction. Vibration energy propagates from a source through intervening soil
and rock layers to the foundations of nearby buildings. The vibration then propagates from the
foundation throughout the remainder of the structure. Building vibration may be perceived by
occupants as the motion of building surfaces, the rattling of items sitting on shelves or hanging on
walls, or a low -frequency rumbling noise. The rumbling noise is caused by the vibration of walls,
floors, and ceilings that radiate sound waves. Annoyance from vibration often occurs when the
vibration exceeds the threshold of perception by 10 dB or less. This is an order of magnitude below
the damage threshold for normal buildings.
Typical sources of ground -borne vibration are construction activities (e.g., blasting, pile -driving, and
operating heavy-duty earthmoving equipment), steel -wheeled trains, and occasional traffic on rough
roads. Problems with both ground -borne vibration and noise from these sources are usually
localized to areas within approximately 100 feet (ft) from the vibration source, although there are
examples of ground -borne vibration causing interference out to distances greater than 200 ft (FTA
2018). When roadways are smooth, vibration from traffic, even heavy trucks, is rarely perceptible. It
is assumed for most projects that the roadway surface will be smooth enough that ground -borne
vibration from street traffic would not exceed the impact criteria; however, construction of the
project could result in ground -borne vibration that may be perceptible and annoying.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
Ground -borne noise is not likely to be a problem because noise arriving via the normal airborne path
will usually be greater than ground -borne noise.
Ground -borne vibration has the potential to disturb people and damage buildings. Although it is
very rare for train -induced ground -borne vibration to cause even cosmetic building damage, it is not
uncommon for construction processes such as blasting and pile -driving to cause vibration of
sufficient amplitudes to damage nearby buildings (FTA 2018). Ground -borne vibration is usually
measured in terms of vibration velocity, either the root -mean -square (RMS) velocity or peak particle
velocity (PPV). The RMS is best for characterizing human response to building vibration, and PPV is
used to characterize the potential for damage. Decibel notation acts to compress the range of
numbers required to describe vibration. Vibration velocity level in decibels is defined as
Lv = 20 loglo [V/Vref]
where "L " is the vibration velocity in decibels (VdB), "V" is the RMS velocity amplitude, and "Vref' is
the reference velocity amplitude, or 1 x 10-6 inches/second (in/sec) used in the United States.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
REGULATORY SETTING
APPLICABLE NOISE STANDARDS
The applicable noise standards governing the project site include the criteria in the City's Noise
Element of the General Plan (Noise Element) and Section 8.24 of the City of Tustin Municipal Code
(TMC).
California Code of Regulations
Interior noise levels for residential habitable rooms are regulated by Title 24 of the California Code
of Regulations California Noise Insulation Standards. Title 24, Chapter 12, Section 1206.4, of the
2019 California Building Code requires that interior noise levels attributable to exterior sources not
exceed 45 CNEL in any habitable room. A habitable room is a room used for living, sleeping, eating,
or cooking. Bathrooms, closets, hallways, utility spaces, and similar areas are not considered
habitable rooms for this regulation (Title 24 California Code of Regulations, Chapter 12, Section
1206.4).
City of Tustin
Noise Element of the General Plan
The City's General Plan Noise Element (City of Tustin 2012) has established exterior and interior
noise standards as shown in Table C. These noise standards apply to approved land uses for which
mitigation may be required to achieve the City's noise standards. As shown in Table C, the City has a
noise standard of 65 dBA CNEL for exterior habitable areas and a 45 dBA CNEL noise standard for
interior habitable areas for residential land uses.
Table C: City of Tustin Interior and Exterior Noise Standards
Land Use
Noise Standards'
Interior2,3
Exterior
Residential: Single-family, multifamily, duplex, mobile home
45 dBA CNEL
65 dBA CNEL4
Residential: Transient lodging, hotels, motels, nursing homes, hospitals
45 dBA CNEL
65 dBA CNEL4
Private offices, church sanctuaries, libraries, board rooms, conference rooms,
theaters, auditoriums, concert halls, meeting rooms, etc.
45 dBA Leq(12)
Schools
45 dBA Leq(12)
67 dBA Leq(12)5
General offices, reception, clerical, etc.
50 dBA Leq(12)
Bank lobby, retail store, restaurant, typing pool, etc.
55 dBA Leq(12)
Manufacturing, kitchen, warehousing, etc.
65 dBA Leq(12)
Parks, playgrounds
65 dBA CNELs
Golf courses, outdoor spectator sports, amusement parks
70 dBA CNEL
Source: Noise Element, Tustin General Plan (City of Tustin 2012).
1 CNEL: Community Noise Equivalent Level. Gq(12): The A -weighted equivalent sound level averaged over a 12-hour period (usually the
hours of operation).
z Noise standard with windows closed. Mechanical ventilation shall be provided per UBC requirements to provide a habitable
environment.
3 Indoor environment excluding bathrooms, toilets, closets, and corridors.
4 Outdoor environment limited to rear yard of single-family homes, multifamily patios, and balconies (with a depth of 6 feet or more)
and common recreation areas.
5 Outdoor environment limited to playground areas, picnic areas, and other areas of frequent human use.
dBA = A -weighted decibels
UBC = Uniform Building Code
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
Municipal Code
Article 4, Chapter 6 of the City's Municipal Code (City of Tustin 2022) establishes the maximum
permissible noise level that may intrude into a neighbor's property. The Noise Ordinance establishes
noise level standards for various land use categories affected by stationary noise sources. Land use
categories in the City are defined by five noise zones, as listed below. Table D provides the City's
maximum noise standard based on the noise zone, the location of the noise (exterior/interior), and
the time period.
Noise Zone 1: All residential properties
Noise Zone 2: All commercial properties
Noise Zone 3: All industrial properties
Noise Zone 4: All special properties such as hospitals, convalescent homes, public and institutional
schools, libraries and churches
Noise Zone 5: All mixed -use properties.
Article 4, Chapter 6 of the City's Municipal Code limits the erection, demolition, alteration, repair,
excavation, grading, paving or construction of any building or site to between the hours of 7:00 a.m.
and 8:00 p.m. Monday through Friday and 9:00 a.m. and 5:00 p.m. on Saturdays. Construction is
prohibited on Sundays and City -observed federal holidays. Trucks, vehicles and equipment that are
making or are involved with material deliveries, loading or transfer of materials, equipment service,
maintenance of any devices or appurtenances to any construction project in Tustin shall not be
operated on or adjacent to said sites outside of the approved hours for construction activity.
Table D: City of Tustin Maximum Noise Level Standards
Noise
Zone
Exterior/
Interior
Time Period
Lso
(30 mins)
Les
(15 mins)
Ls
(5 mins)
L2
(1 min)
Lmax
(Anytime)
7:00 AM to 10:00 PM
55
60
65
70
75
Exterior
10:00 PM to 7:00 AM
50
55
60
65
70
1
7:00 AM to 10:00 PM
—
—
55
60
65
Interior
10:00 PM to 7:00 AM
45
50
55
2
Exterior
Anytime
60
65
70
75
80
3
Exterior
Anytime
70
75
80
85
90
4
Exterior
Anytime
55
60
65
70
75
5
Exterior
Anytime
60
65
70
75
80
Source: Municipal Code (City of Tustin 2018).
Note: It shall be unlawful for any person at any location within the incorporated area of the City of Tustin to create any noise or to allow
the creation of any noise on property owned, leased, occupied or otherwise controlled by such person, when the foregoing causes the
noise level, when measured on any other property to exceed. In the event the alleged offensive noise consists of impact noise, simple
tone, speech, music, or any combination thereof, each of the above noise levels shall be reduced by 5 dBA. In the event the ambient
noise level exceeds any of the first four noise limit categories, the cumulate period applicable to said category shall be increased to
reflect said ambient noise level. In the event the ambient noise level exceeds the fifth noise limit category, the maximum allowable
noise level under said category shall be increased to reflect the maximum ambient noise level.
dBA = A -weighted decibels
Lma = maximum instantaneous noise level
min/mins = minute/minutes
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
In addition, construction activities may be permitted outside of those limitations in the case of
urgent necessity or upon a finding that such approval would not adversely impact adjacent
properties and the health, safety and welfare of the community if a temporary exception is granted
in writing by the Building Official for private property or by the Director of Public Works for public
properties or their authorized representatives. All temporary waiver requests shall be made in
writing and shall include the specific times, dates, and locations requested and a description of the
type of activity that is proposed. In granting a temporary exception, conditions may be imposed on
construction activities to protect the health, safety, and welfare of the community. Any approval
granted may be summarily revoked by the Building Official or Director of Public Works at the sole
discretion of each official.
Federal Transit Administration
Because the City does not have construction noise level limits, construction noise was assessed
using criteria from the Federal Transit Administration's (FTA) 2018 Transit Noise and Vibration
Impact Assessment Manual (FTA Manual). Table E shows the FTA's General Assessment Construction
Noise Criteria based on the composite noise levels per construction phase.
Table E: General Assessment Construction Noise Criteria
Land Use
Daytime 1-hour LeQ (dBA)
Nighttime 1-hour Leq (dBA)
Residential
90
80
Commercial
100
100
Industrial
100
100
Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018).
dBA = A -weighted decibels Leq = equivalent continuous sound level
APPLICABLE VIBRATION STANDARDS
Federal Transit Administration
Vibration standards included in the 2018 FTA Manual are used in this analysis for ground -borne
vibration impacts on human annoyance. The criteria for environmental impacts from ground -borne
vibration and noise are based on the maximum levels for a single event. Table F provides the criteria
for assessing the potential for interference or annoyance from vibration levels in a building.
Table F: Interpretation of Vibration Criteria for Detailed Analysis
Land Use
VdB)
Description of Use
Workshop
90
Vibration that is distinctly felt. Appropriate for workshops and
similar areas not as sensitive to vibration.
Office
84
Vibration that can be felt. Appropriate for offices and similar
areas not as sensitive to vibration.
Residential Day
78
Vibration that is barely felt. Adequate for computer equipment
and low -power optical microscopes (up to 20x).
Residential Night and
Vibration is not felt, but ground -borne noise may be audible
Operating Rooms
72
inside quiet rooms. Suitable for medium -power microscopes
(100x) and other equipment of low sensitivity.
Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018).
1 As measured in 1/3-octave bands of frequency over the frequency range 8 to 80 hertz.
FTA = Federal Transit Administration Lv = velocity in decibels
VdB = vibration velocity decibels Max = maximum
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
Table G lists the potential vibration building damage criteria associated with construction activities,
as suggested in the FTA Manual. FTA guidelines show that a vibration level of up to 0.5 in/sec in PPV
is considered safe for buildings consisting of reinforced concrete, steel, or timber (no plaster), and
would not result in any construction vibration damage. For non -engineered timber and masonry
buildings, the construction building vibration damage criterion is 0.2 in/sec in PPV.
Table G: Construction Vibration Damage Criteria
Building Category
PPV On/sec)
Reinforced concrete, steel, or timber (no plaster)
0.50
Engineered concrete and masonry (no plaster)
0.30
Non -engineered timber and masonry buildings
0.20
Buildings extremely susceptible to vibration damage
0.12
Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018).
FTA = Federal Transit Administration PPV = peak particle velocity
in/sec = inch/inches per second
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
OVERVIEW OF THE EXISTING NOISE ENVIRONMENT
The primary existing noise sources in the project area are transportation facilities such as Yorba
Street, 171h Street, Vandenberg Lane, and Enderle Center Drive and surrounding commercial and
office uses.
AMBIENT NOISE MEASUREMENTS
Long -Term Noise Measurements
Long-term (24-hour) noise level measurements were conducted on January 23 and 24, 2024, using
two (2) Larson Davis Spark 706RC Dosimeters. Table H provides a summary of the measured hourly
noise levels and calculated CNEL level from the long-term noise level measurements. As shown in
Table H, the calculated CNEL levels range from 66.9 dBA CNEL to 73.7 dBA CNEL. Hourly noise levels
at surrounding sensitive uses are as low as 50.4 dBA Leq during nighttime hours and 66.8 dBA Leq
during daytime hours. Long-term noise monitoring survey sheets are provided in Appendix A.
Figure 3 shows the long-term monitoring locations.
Table H: Long -Term 24-Hour Ambient Noise Monitoring Results'
Location
Daytime
Noise Levelsl
(dBA LeQ)
Evening
Noise LeveIS2
(dBA LeQ)
Nighttime
Noise Levels3
(dBA LeQ)
Daily Noise
Levels
(dBA CNEL)
14122 Paseo Verde, Tustin, CA 92780.
Located in the front yard of a home on a
LT-1
tree, approximately 60 feet away from
64.7-66.8
61.9-64.9
50.4-62.3
66.9
the Vandenberg Lane centerline.
14032 Enderle Center Drive, #102, Tustin,
CA 92780. Located south of an office
LT-2
building in the parking lot on a light pole,
65.8-68.8
69.4-69.8
62.4-69.2
73.7
approximately 120 feet away from the
Enderle Center Drive centerline.
Source: Compiled by LSA (2024).
Note: Noise measurements were conducted from January 23 and 24, 2024, starting at 2:00 p.m.
Daytime Noise Levels = noise levels during the hours from 7:00 a.m. to 7:00 p.m.
z Evening Noise Levels = noise levels during the hours from 7:00 p.m. to 10:00 p.m.
a Nighttime Noise Levels = noise levels during the hours from 10:00 p.m. to 7:00 a.m.
dBA = A -weighted decibels Leq = equivalent continuous sound level
CNEL = Community Noise Equivalent Level
EXISTING AIRCRAFT NOISE
Aircraft flyovers may be audible on the project site due to aircraft activity in the vicinity. The nearest
airport to the project is John Wayne Airport (JWA), a commercial airport 5.5 miles to the south. The
project site is outside the 60 dBA CNEL noise contour of JWA based on the JWA Airport 2022 Annual
Community Noise Equivalent Level Contours (County of Orange 2022). Additionally, there are no
helipads or private airstrips within 2 miles of the project area. Due to the distance of the project site
from the nearest airport, impacts related to aircraft operations are not further discussed in this
analysis.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TLISTIN, CALIFORNIA J `(\
PROJECT IMPACTS
SHORT-TERM CONSTRUCTION NOISE IMPACTS
Two types of short-term noise impacts could occur during the construction of the proposed project.
First, construction crew commutes and the transport of construction equipment and materials to
the site for the proposed project would incrementally increase noise levels on access roads leading
to the site. Although there would be a relatively high single -event noise -exposure potential causing
intermittent noise nuisance (passing trucks at 50 ft would generate up to 84 dBA Lmax), the effect on
longer -term ambient noise levels would be small when compared to existing daily traffic volumes on
17t" Street. Because construction -related vehicle trips would not approach existing daily traffic
volumes, traffic noise would not increase by 3 dBA CNEL. A noise level increase of less than 3 dBA
would not be perceptible to the human ear in an outdoor environment. Therefore, short-term,
construction -related impacts associated with worker commute and equipment transport to the
project site would be less than significant.
The second type of short-term noise impact is related to noise generated during demolition,
excavation, grading, and building erection on the project site. Construction is completed in discrete
steps, each of which has its own mix of equipment and, consequently, its own noise characteristics.
These various sequential phases would change the character of the noise generated on the site and,
therefore, the noise levels surrounding the site as construction progresses. Despite the variety in the
type and size of construction equipment, similarities in the dominant noise sources and patterns of
operation allow construction -related noise ranges to be categorized by work phase. Table I lists
typical construction equipment noise levels recommended for noise impact assessments, based on a
distance of 50 ft between the equipment and a noise receptor, taken from the FHWA Roadway
Construction Noise Model (FHWA 2006).
In addition to the reference maximum noise level, the usage factor provided in Table I is used to
calculate the hourly noise level impact for each piece of equipment based on the following
equation:
Leq (equip) = E.L. + 10 to (U.F.) — 20 log(D
50
where: LeQ (equip) = Leq at a receiver resulting from the operation of a single
piece of equipment over a specified time period.
E.L. = noise emission level of the particular piece of equipment at
a reference distance of 50 ft.
U.F. = usage factor that accounts for the fraction of time that the
equipment is in use over the specified period of time.
D = distance from the receiver to the piece of equipment.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
Table I: Typical Construction Equipment Noise Levels
Equipment Description
Acoustical Usage Factor (%)1
Maximum Noise Level (Lmax) at 50 Feet2
Auger Drill Rig
20
84
Backhoes
40
80
Compactor (ground)
20
80
Compressor
40
80
Cranes
16
85
Dozers
40
85
Dump Trucks
40
84
Excavators
40
85
Flat Bed Trucks
40
84
Forklift
20
85
Front-end Loaders
40
80
Graders
40
85
Impact Pile Drivers
20
95
Jackhammers
20
85
Paver
50
77
Pickup Truck
40
55
Pneumatic Tools
50
85
Pumps
50
77
Rock Drills
20
85
Rollers
20
85
Scrapers
40
85
Tractors
40
84
Trencher
50
80
Welder
40
73
Source: FHWA Roadway Construction Noise Model User's Guide, Table 1 (FHWA 2006).
Note: Noise levels reported in this table are rounded to the nearest whole number.
Usage factor is the percentage of time during a construction noise operation that a piece of construction equipment is operating at
full power.
z Maximum noise levels were developed based on Specification 721.560 from the Central Artery/Tunnel program to be consistent
with the City of Boston's Noise Code for the "Big Dig' project.
FHWA = Federal Highway Administration
I-- = maximum instantaneous sound level
Each piece of construction equipment operates as an individual point source. Using the following
equation, a composite noise level can be calculated when multiple sources of noise operate
simultaneously:
�z
,<az
Leq (co7nposite) = 10 * log14 101a
1
Using the equations from the methodology above, the reference information in Table I, and the
construction equipment list provided, the composite noise level of each construction phase was
calculated. The project construction composite noise levels at a distance of 50 ft would range from
74 dBA Leq to 88 dBA Leq with the highest noise levels occurring during the site preparation and
grading phases.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
Once composite noise levels are calculated, reference noise levels can then be adjusted for distance
using the following equation:
Leg (a.t distafiice X) = Lech (a.t A feet) — 20 * to g10 X
(TO
In general, this equation shows that doubling the distance would decrease noise levels by 6 dBA
while halving the distance would increase noise levels by 6 dBA.
Table J shows the nearest sensitive uses to the project site, their distance from the center of
construction activities, and composite noise levels expected during construction. These noise level
projections do not take into account intervening topography or barriers. Construction equipment
calculations are provided in Appendix B.
Table J: Potential Construction Noise Impacts at Nearest Receptor
Receptor (Location)
Composite Noise Level
(dBA Leq) at 50 ft'
Distance (ft)
Composite Noise
Level (dBA LeQ)
Residential (South)
88
380
70
Commercial / Office (East)
380
70
Commercial / Office (North)
440
69
Commercial / Office (West)
515
67
Source: Compiled by LSA (2024).
The composite construction noise level represents the grading phase which is expected to result in the greatest noise level as
compared to other phases.
dBA Leq = average A -weighted hourly noise level
ft = foot/feet
While construction noise will vary, it is expected that composite noise levels during construction at
the nearest off -site sensitive uses to the south would reach 70 dBA Leq. These predicted noise levels
would only occur when all construction equipment is operating simultaneously; and therefore, are
assumed to be rather conservative in nature. While construction -related short-term noise levels
have the potential to be higher than existing ambient noise levels in the project area under existing
conditions, the noise impacts would no longer occur once project construction is completed.
As stated above, noise impacts associated with construction activities are regulated by the City's
noise ordinance. The proposed project will be required to comply with the construction hours
specified in the City's Noise Ordinance, which states that construction activities are allowed
between 7:00 a.m. and 8:00 p.m., Monday through Friday, and between 9:00 a.m. and 5:00 p.m. on
Saturdays. Construction is prohibited on Sundays and City -observed federal holidays.
As it relates to off -site uses, construction -related noise impacts would remain below the 90 dBA Leq
and 100 dBA Leq 1-hour construction noise level criteria as established by the FTA for residential and
commercial land uses, respectively, for the average daily conditions as modeled from the center of
the project site, and therefore, they would be considered less than significant. Best construction
practices presented at the end of this analysis shall be implemented to minimize noise impacts to
surrounding receptors.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
SHORT-TERM CONSTRUCTION VIBRATION IMPACTS
This construction vibration impact analysis discusses the level of human annoyance using vibration
levels in VdB and assesses the potential for building damages using vibration levels in PPV (in/sec).
This is because vibration levels calculated in RMS are best for characterizing human response to
building vibration, while vibration level in PPV is best for characterizing potential for damage.
Table K shows the PPV and VdB values at 25 ft from the construction vibration source. As shown in
Table K, bulldozers and other heavy -tracked construction equipment (expected to be used for this
project) generate approximately 0.089 PPV in/sec or 87 VdB of ground -borne vibration when
measured at 25 ft, based on the FTA Manual. The distance to the nearest buildings for vibration
impact analysis is measured between the nearest off -site buildings and the project construction
boundary (assuming the construction equipment would be used at or near the project setback line).
Table K: Vibration Source Amplitudes for Construction Equipment
Equipment
Reference PPV/Lv at 25 ft
PPV (in/sec)
Lv (VdB)1
Pile Driver (Impact), Typical
0.644
104
Pile Driver (Sonic), Typical
0.170
93
Vibratory Roller
0.210
94
Hoe Ram
0.089
87
Large Bulldozer
0.089
87
Caisson Drilling
0.089
87
Loaded TruckS2
0.076
86
Jackhammer
0.035
79
Small Bulldozer
0.003
58
Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018).
1 RMS vibration velocity in decibels (VdB) is 1 µin/sec.
z Equipment shown in bold is expected to be used on site.
µin/sec = microinches per second Lv = velocity in decibels
ft = foot/feet PPV = peak particle velocity
FTA = Federal Transit Administration RMS = root -mean -square
in/sec = inch/inches per second VdB = vibration velocity decibels
The formulae for vibration transmission are provided below, and Tables L and M below provide a
summary of off -site construction vibration levels.
LAB (D) = LAB (25 ft) — 30 Log (D/25)
PPVeq ip = PPVref x (25/D)1.5
As shown in Table F, above, the threshold at which vibration levels would result in annoyance would
be 78 VdB for daytime residential uses. As shown in Table G, the FTA guidelines indicate that for a
non -engineered timber and masonry building, the construction vibration damage criterion is
0.2 in/sec in PPV.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT LSA
MARCH 2024 CITY OF TuSTIN, CALIFORNIA
Table L: Potential Construction Vibration Annoyance Impacts at
Nearest Receptor
Receptor (Location)
Reference Vibration
Level (VdB) at 25 ft'
Distance (ft) z
Vibration Level
(VdB)
Residential (South)
87
380
52
Commercial / Office (East)
380
52
Commercial / Office (North)
440
50
Commercial / Office (West)
515
48
Source: Compiled by LSA (2024).
' The reference vibration level is associated with a large bulldozer, which is expected to be representative of
the heavy equipment used during construction.
Z The reference distance is associated with the average condition, identified by the distance from the center
of construction activities to surrounding uses.
ft = foot/feet
VdB = vibration velocity decibels
Table M: Potential Construction Vibration Damage Impacts at
Nearest Receptor
Receptor (Location)
Reference
Vibration Level
(PPV) at 25 ft'
Distance (ft)2
Vibration
Level
(PPV)
Residential (South)
0.089
70
0.019
Commercial / Office (East)
20
0.124
Commercial / Office (North)
140
0.007
Commercial / Office (West)
95
0.012
Source: Compiled by LSA (2024).
The reference vibration level is associated with a large bulldozer, which is expected to be
representative of the heavy equipment used during construction.
Z The reference distance is associated with the peak condition, identified by the distance from the
perimeter of construction activities to surrounding structures.
ft = foot/feet
PPV = peak particle velocity
Based on the information provided in Table L, vibration levels are expected to approach 52 VdB at
the closest residential uses located south of the project site, which is below the 78 VdB threshold for
annoyance.
The closest structure to the project site is the commercial use to the east of site, approximately 20 ft
from the limits of construction activity. It is expected that vibration levels generated by dump trucks
and other large equipment that would operate near the property line would generate ground -borne
vibration levels of up to 0.124 PPV (in/sec) at the closest structure to the project site. This vibration
level would not exceed the 0.2 PPV (in/sec) threshold considered safe for non -engineered timber
and masonry buildings. All other structures are further away and would experience lower vibration
levels. Therefore, vibration impacts would be less than significant. Because construction activities
are regulated by the City's Municipal Code, which states that construction, maintenance, or
demolition activities are allowed between the hours of 7:00 a.m. to 8:00 p.m., Monday through
Friday, and 9:00 a.m. to 5:00 p.m. on Saturdays and City -observed federal holidays, vibration
impacts would not occur during the more sensitive nighttime hours.
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NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
LONG-TERM OFF -SITE TRAFFIC NOISE IMPACTS
The guidelines included in the FHWA Highway Traffic Noise Prediction Model (FHWA-RD-77 108)
were used to evaluate highway traffic -related noise conditions along roadway segments in the
project vicinity. This model requires various parameters, including traffic volumes, vehicle mix,
vehicle speed, and roadway geometry to compute typical equivalent noise levels during daytime,
evening, and nighttime hours. The resultant noise levels are weighted and summed over 24-hour
periods to determine the CNEL values. Table N provides the traffic noise levels for the opening year
and future year with and without project scenarios. These noise levels represent the worst -case
scenario, which assumes no shielding is provided between the traffic and the location where the
noise contours are drawn.
The without and with project scenario traffic volumes were obtained from the Traffic Impact
Analysis (EPD Solutions Inc. 2024). Appendix C provides the specific assumptions used in developing
these noise levels and model printouts. Table N shows that the increase in project -related traffic
noise would be no greater than 2.9 dBA. Noise level increases less than 3 dBA are not perceptible to
the human ear in an outdoor environment. Therefore, traffic noise impacts from project -related
traffic on off -site sensitive receptors would be less than significant, and no mitigation measures are
required.
LONG-TERM TRAFFIC -RELATED VIBRATION IMPACTS
The proposed project would not generate vibration levels related to on -site operations. In addition,
vibration levels generated from project -related traffic on the adjacent roadways are unusual for on -
road vehicles because the rubber tires and suspension systems of on -road vehicles provide vibration
isolation. Vibration levels generated from project -related traffic on the adjacent roadways would be
less than significant, and no mitigation measures are required.
LONG-TERM STATIONARY NOISE IMPACTS
Adjacent off -site land uses would be potentially exposed to stationary -source noise impacts from
sources which include on -site heating, ventilation, and air conditioning (HVAC) equipment, and truck
deliveries and loading and unloading activities. It is expected that on -site stationary noise sources
would meet the City of Tustin maximum noise level standards as presented previously in Table D.
Once proposed uses are determined and final site plans are available, a Final Acoustical Report
would be required to confirm the noise level exposure from stationary sources to off -site sensitive
land uses and to identify any specific mitigation measures necessary to achieve an exterior noise
level below the City's noise standards.
P:\ESL2201.76\Products\Noise\N oiseAndVi bration Repo rt_032724.docx a03/27/24» 26
NOISE AND VIBRATION IMPACT ANALYSIS
MARCH 2O24
EN DERLE CENTER PROJECT L C A
CITY OF TUSTI N, CAL IFOR NIA J `(\
Table N: Traffic Noise Levels Without and With Proposed Project
Opening Year - No
Future Year - No
Existing
Opening Year - With Project
Future Year -With Project
Project
Project
CNEL (dBA)
CNEL (dBA)
CNEL (dBA)
Increase
CNEL (dBA)
CNEL (dBA)
Increase
Roadway Segment
50 ft from
50 ft from
50 ft from
from
50 ft from
50 ft from
from
ADT
Centerline
ADT
Centerline
ADT
Centerline
Baseline
ADT
Centerline
ADT
Centerline
Baseline
of Nearest
of Nearest
of Nearest
Conditions
of Nearest
of Nearest
Conditions
Lane
Lane
Lane
(dBA)
Lane
Lane
(dBA)
17th St between SR-
55 SB Ramps & SR-55
39,346
68.9
39,802
68.9
44,963
69.5
0.6
41,852
69.2
47,013
69.7
0.5
NB Ramps
17th St between SR-
55 NB Ramps &
Carroll Way-Yorba St
38,861
68.8
39,155
68.9
46,611
69.6
0.7
40,478
69.0
47,934
69.7
0.7
South
17th St between
Carroll Way-Yorba St
South & Yorba St
34,006
68.3
34,151
68.3
39,312
68.9
0.6
34,801
68.4
39,963
69.0
0.6
North-Enderle Center
Dr
Yorba St between
17th St &
5,174
60.6
5,607
60.9
10,768
63.8
2.9
7,555
62.2
12,716
64.5
2.3
Vandenberg Ln
Enderle Center Dr
between 17th St &
3,197
53.6
3,453
53.9
6,320
56.6
2.7
4,604
55.2
7,471
57.3
2.1
Vandenberg Ln
Source: Compiled by LSA (2024).
Note: Shaded cells indicate roadway segments adjacent to the project site.
ADT = average daily traffic
CNEL= Community Noise Equivalent Level
dBA = A -weighted decibels
ft = foot/feet
P:\ESL2201.76\Products\Noise\N oiseAndVi bration Repo rt_032724.docx a03/27/24» 27
NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
LAND USE COMPATIBILITY
The dominant source of noise in the project vicinity is traffic noise from roadways in the vicinity of
the project.
EXTERIOR NOISE ASSESSMENT
Based on the monitoring results shown in Table H, the existing measured noise levels at the project
site closest to Enderle Center Drive, approximately 120 ft away from the Enderle Center Drive
centerline, is 73.7 dBA CNEL. Exterior living areas of residential units, which are either shared
spaces, access points to the units, or balconies that are less than 6 ft deep, are not considered as
exterior living areas. However, once site plans are available, a Final Acoustical Report would be
required to confirm any proposed exterior noise sensitive areas would experience noise levels less
than 65 dBA CNEL and to identify any noise reduction features to the exterior living areas, if
necessary.
INTERIOR NOISE ASSESSMENT
As discussed above, the California Code of Regulations and the City's Noise Element state that an
interior noise level standard of 45 dBA CNEL or less is required for all noise -sensitive rooms. Based
on the expected future exterior noise levels closest to Enderle Center Drive and 17t" Street
approaching 74 dBA CNEL, a minimum noise reduction of 29 dBA would be required.
Based on reference information from transmission loss test reports for various Milgard windows
(Milgard 2008), the necessary reduction can be achieved with standard building construction and
upgraded windows with Sound Transmission Class (STC) ratings of 30-35, depending on the
window -to -glass ratio, at the lots closest to Enderle Center Drive and 17t" Street. For all other lots
farther from 17t" Street and Enderle Center Drive, standard building construction along with
standard windows, typically in the STC 25-28 range, interior noise levels of 45 dBA CNEL or less
would be achieved.
Once final plans are available to detail the exterior wall construction and a window manufacturer
has been chosen, a Final Acoustical Report would be required to confirm the reduction capability of
the exterior fagades and to identify any specific upgrades necessary to achieve an interior noise level
of 45 dBA CNEL or below.
P:\ESL2201.76\Products\Noise\N oiseAndVi bration Repo rt_032724.docx a03/27/24» 28
NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J A
BEST CONSTRUCTION PRACTICES AND DESIGN REQUIREMENTS
In addition to compliance with the City's Municipal Code allowed hours of construction of 7:00 a.m.
to 8:00 p.m., Monday through Friday, and 9:00 a.m. to 5:00 p.m. on Saturdays and City -observed
federal holidays, the following best construction practices would further minimize construction
noise impacts:
• The project construction contractor shall equip all construction equipment, fixed or mobile, with
properly operating and maintained noise mufflers consistent with manufacturer's standards.
• The project construction contractor shall locate staging areas away from off -site sensitive uses
during the later phases of project development.
The project construction contractor shall place all stationary construction equipment so that
emitted noise is directed away from sensitive receptors nearest the project site whenever
feasible.
P:\ESL2201.76\Products\Noise\N oiseAndVi bration Repo rt_032724.docx a03/27/24» 29
NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT C A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA J `(\
REFERENCES
City of Tustin. 2012. General Plan Noise Element.
2023. Municipal Code. Website: https://library.municode.com/ca/tustin/codes/code_of_
ordinances (accessed March 2024). November 27.
County of Orange. 2022. Community Noise Equivalent Level. Website: https://www.ocair.com/
about/administration/access-noise/reports-resources/ (accessed March 2024).
EPD Solutions, Inc. 2024. Traffic Impact Analysis for Enderle Center Project. February.
Federal Highway Administration (FHWA). 2006. Roadway Construction Noise Model User's Guide.
January. Washington, D.C. Website: https://www.fhwa.dot.gov/environment/noise/
construction_noise/rcnm/rcnm.pdf (accessed March 2024).
Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual.
Office of Planning and Environment. Report No. 0123. September.
Milgard. 2008. Various Transmission Loss Reports.
P:\ESL2201.76\Products\Noise\N oiseAndVi bration Repo rt_032724.docx a03/27/24» 30
NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT L S A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA
D
NOISE MONITORING SHEETS
P:\ESL2201.76\Products\Noise\NoiseAndVibrationReport_032724.docx«03/27/24»
Noise Measurement Survey — 24 HR
Project Number: ESL2201.76 Test Personnel: Kevin NgUendo
Project Name: Enderle Project Equipment: Spark 706RC (SN:206)
Site Number: LT-1 Date: 1/24/24 Time: From 2:00 p.m. To 2:00 p.m.
Site Location: 14122 Paseo Verde, Tustin, CA 92780. Located in the front yard of a home
Primary Noise Sources: Traffic on Vandenberg Lane.
Comments: Approximately 72 inch tall retaining wall around residential community.
Photo:
Long -Term (24-Hour) Noise Level Measurement Results at LT-1
Start Time
Date
Noise Level dBA
Leq
Lmax
Lmin
2:00 PM
1/24/24
56.0
69.8
46.6
3:00 PM
1/24/24
58.2
74.7
48.0
4:00 PM
1/24/24
58.2
77.5
46.7
5:00 PM
1/24/24
57.7
76.2
46.2
6:00 PM
1/24/24
55.9
72.1
47.2
7:00 PM
1/24/24
55.8
72.7
46.4
8:00 PM
1/24/24
56.3
74.9
46.5
9:00 PM
1/24/24
55.6
74.7
46.2
10:00 PM
1/24/24
48.7
67.1
41.3
11:00 PM
1/24/24
45.4
64.2
41.0
12:00 AM
1/25/24
44.1
53.5
40.5
1:00 AM
1/25/24
43.5
57.4
39.5
2:00 AM
1/25/24
42.5
57.9
38.5
3:00 AM
1/25/24
43.3
63.5
38.9
4:00 AM
1/25/24
45.9
64.6
39.8
5:00 AM
1/25/24
50.0
66.3
43.3
6:00 AM
1/25/24
50.7
70.1
43.7
7:00 AM
1/25/24
56.0
70.3
44.8
8:00 AM
1/25/24
59.4
74.5
45.0
9:00 AM
1/25/24
57.9
71.1
45.4
10:00 AM
1/25/24
58.1
73.7
46.0
11:00 AM
1/25/24
56.2
71.1
45.6
12:00 PM
1/25/24
58.1
72.8
47.3
1:00 PM
1/25/24
58.0
73.5
47.4
Source: Compiled by LSA Associates, Inc. (2024).
dBA = A -weighted decibel Lmax = maximum instantaneous noise level
Leq = equivalent continuous sound level Lmin = minimum measured sound level
Long -Term (24-Hour) Noise Level Measurement
LT-1: Located in front of a home on a tree
79.0
75.0
71.0
67.0
Q
63.0
m
=
59.0
v
55.0
v
.ii 51.0
z
47.0
43.0
39.0
35.0
5 SS gg 55 SS SS 55 SS 5 S 5 5 5 g 5 5 S 55
S S S S S S S S a a Q a 3 3 5 3 S 3 5 S Q C a S
S $ $ g g $ $ o 0 4 $ o $ $ $ $ o $ $ q Q o g
N �V1 O N iG 1� GG Gi O .y iV M O uj .G N CG C1 O
Time of Day
Leq -Lmax -Lmin
Noise Measurement Survey — 24 HR
Project Number: ESL2201.76
Project Name: Enderle Project
Site Number: LT-2 Date: 1/24/24
Test Personnel: Kevin NgUendo
Equipment: Spark 706RC (SN:814)
Time: From 2:00 p.m. To 2:00 p.m.
Site Location: 14032 Enderle Center Dr #102, Tustin, CA 92780. Located south of an
office buildingin n the parking lot on a light pole.
Primary Noise Sources: Traffic on Enderle Center Drive and Vandenberg Lane.
Comments:
Photo:
Long -Term (24-Hour) Noise Level Measurement Results at LT-2
Start Time
Date
Noise Level dBA
Leq
Lmax
Lmin
2:00 PM
1/24/24
56.4
67.3
50.2
3:00 PM
1/24/24
58.2
73.9
52.2
4:00 PM
1/24/24
57.9
71.0
51.7
5:00 PM
1/24/24
57.3
71.1
49.8
6:00 PM
1/24/24
57.0
73.0
51.8
7:00 PM
1/24/24
56.4
69.9
51.2
8:00 PM
1/24/24
57.4
71.5
48.6
9:00 PM
1/24/24
56.6
70.7
50.5
10:00 PM
1/24/24
50.5
63.4
43.9
11:00 PM
1/24/24
48.6
63.1
43.6
12:00 AM
1/25/24
50.0
68.0
44.5
1:00 AM
1/25/24
48.0
58.9
43.8
2:00 AM
1/25/24
46.5
61.0
42.4
3:00 AM
1/25/24
47.5
59.2
43.6
4:00 AM
1/25/24
49.5
59.9
44.1
5:00 AM
1/25/24
52.3
71.9
47.6
6:00 AM
1/25/24
51.4
67.5
47.6
7:00 AM
1/25/24
54.9
72.0
48.0
8:00 AM
1/25/24
57.2
68.8
46.1
9:00 AM
1/25/24
56.5
71.0
46.9
10:00 AM
1/25/24
56.6
70.3
47.9
11:00 AM
1/25/24
55.5
69.3
47.0
12:00 PM
1/25/24
57.6
72.2
49.4
1:00 PM
1/25/24
58.0
70.9
50.6
Source: Compiled by LSA Associates, Inc. (2024).
dBA = A -weighted decibel Lmax = maximum instantaneous noise level
Leq = equivalent continuous sound level Lmin = minimum measured sound level
Long -Term (24-Hour) Noise Level Measurement
LT-2: Located in a parking lot on a light pole
80.0
76.0
72.0
68.0
m 64.0
v
ar 60.0
v
J
N 56.0
Z 52.0
48.0
44.0
40.0
55 55 S5 55 SS 55 55 SS ss ss 55 gg SS 55
s s S S a a ¢ a a d 3 3 3 3 3 3 a a a S
S S S $ g g g g o 0 0 0 0 0 0 0 0 0 0 0 0
Q o 0 0 o g g o o Q o
N rtl V of �G 1� 00 Oi O N ey fV t�'f O .%1 N h 00 CI O .�
~ ~
Time of Day
111111111111111ILeq -Lmax -Lmin
NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT L S A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA
APPENDIX 6
CONSTRUCTION NOISE LEVEL CALCULATIONS
P:\ESL2201.76\Products\Noise\NoiseAndVibrationReport_032724.docx«03/27/24»
Construction Calculations
Ph.,.. ncmnlirinn
Equipment
Quantity
Reference (dBA)
50 ft Lmax
sager
Factor
Distance to Receptor
ft
Ground
Effects
Noise Level dBA
Lmax
Leq
Concrete Saw
1
90
20
50
0.5
90
83
Excavator
3
81
40
50
0.5
81
82
Dozer
2
82
40
50
0.5
82
81
Combined at 5U teet 91 t$7
Combined at Receptor 373 feet 69 70
Combined at Receptor 350 feet 69 71
Combined at Receptor 505 feet 66 68
Ph- -Rite Pranaratinn
Equipment
Quantity
Reference (dBA)
50 ft Lmax
sager
Factor
Distance to Receptor
ft
Ground
Effects
Noise Level dBA
Lmax
Leq
Dozer
3
82
40
50
0.5
82
83
Tractor
4
84
40
50
0.5
84
86
Combined at 5u teet k1b tits
Combined at Receptor 373 feet 69 70
Combined at Receptor 350 feet 69 71
Combined at Receptor 505 feet 66 68
Ph.— (;rarlinn
Equipment
Quantity
Reference (dBA)
50 ft Lmax
sager
Factor
Distance to Receptor
ft
Ground
Effects
Noise Level dBA
Lmax
Leq
Excavator
2
81
40
50
0.5
81
1 80
Grader
1
85
40
50
0.5
85
81
Dozer
1
82
40
50
0.5
82
78
Scraper
2
84
40
50
0.5
84
83
Tractor
2
84
40
50
0.5
84
83
Combined at 50 feet 90 88
Combined at Receptor 373 feet 73 71
Combined at Receptor 350 feet 74 72
Combined at Receptor 505 feet 70 68
Phace-Riiilrlinn f-. n tr i tinn
Equipment
Quantity
Reference (dBA)
50 ft Lmax
Usages
Factor
Distance to Receptor
ft
Ground
Effects
Noise Level dBA
Lmax
Leq
Crane
1
81
16
50
0.5
81
73
Man Lift
3
75
20
50
0.5
75
73
Generator
1
81
50
50
0.5
81
78
Tractor
3
84
40
50
0.5
84
85
Welder / Torch
1
74
40
50
0.5
74
70
Combined at 5o teet 86 81
Combined at Receptor 373 feet 69 63
Combined at Receptor 350 feet 69 64
Combined at Receptor 505 feet 66 61
Ph... Pavinn
Equipment
Quantity
Reference (dBA)
50 ft Lmax
Usage
Factors
Distance to Receptor
(ft)
Ground
Effects
Noise Level (dBA)
Lmax
Leq
Paver
2
77
50
50
0.5
77
77
All Other Equipment> 5 HP
2
85
50
50
0.5
85
85
Roller
2
80
20
50
0.5
80
76
commnea at bu rest Ut ttu
Combined at Receptor 373 feet 69 69
Combined at Receptor 350 feet 70 69
Combined at Receptor 505 feet 67 66
Phase Archit—fi—I Cnafinn
Equipment
Quantity
Reference (dBA)
50 ft Lmax
Usage
Factor
Distance to Receptor
(ft)
Ground
Effects
Noise Level (dBA)
Lmax
Leq
Compressor (air)
1
78
40
50
0.5
78
74
combmea at 5u reet (u 14
Combined at Receptor 373 feet 61 57
Combined at Receptor 350 feet 61 57
Combined at Receptor 505 feet 58 54
Sources: RCNM
I Percentage of time that a piece of equipment is operating at full power.
dBA - A -weighted Decibels
Lmax- Maximum Level
Leq- Equivalent Level
NOISE AND VIBRATION IMPACT ANALYSIS ENDERLE CENTER PROJECT L S A
MARCH 2024 CITY OF TuSTIN, CALIFORNIA
APPENDIX C
FHWA TRAFFIC NOISE MODEL PRINTOUTS
P:\ESL2201.76\Products\Noise\NoiseAndVibrationReport_032724.docx«03/27/24»
TABLE Existing -01
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 SB Ramps & SR-55 NB Ramps
NOTES: Enderle Center Project - Existing
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 39346 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 68.89
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
83.6 158.4 330.1 705.9
TABLE Existing -02
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 NB Ramps & Carroll Way-Yorba St
South
NOTES: Enderle Center Project - Existing
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 38861 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
F01FIN
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 68.83
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
83.1 157.2 327.5 700.1
TABLE Existing -03
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between Carroll Way-Yorba St South & Yorba St
North-Enderle Center Dr
NOTES: Enderle Center Project - Existing
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 34006 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 IS
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 68.25
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
78.2 144.9 300.1 640.8
TABLE Existing -04
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Yorba St between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Existing
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 5174 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 60.58
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 0.0 91.6 185.7
TABLE Existing -05
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Enderle Center Dr between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Existing
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 3197 SPEED (MPH): 25 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 53.60
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 0.0 0.0 71.6
TABLE Opening Year - No Project -01
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 SB Ramps & SR-55 NB Ramps
NOTES: Enderle Center Project - Opening Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 39802 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 68.94
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
84.1 159.5 332.6 711.3
TABLE Opening Year - No Project -02
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 NB Ramps & Carroll Way-Yorba St
South
NOTES: Enderle Center Project - Opening Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 39155 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
F01FIN
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 68.86
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
83.4 157.9 329.1 703.6
TABLE Opening Year - No Project -03
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between Carroll Way-Yorba St South & Yorba St
North-Enderle Center Dr
NOTES: Enderle Center Project - Opening Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 34151 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 IS
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 68.27
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
78.3 145.3 301.0 642.6
TABLE Opening Year - No Project -04
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Yorba St between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Opening Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 5607 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 60.93
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 0.0 95.9 195.6
TABLE Opening Year - No Project -05
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Enderle Center Dr between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Opening Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 3453 SPEED (MPH): 25 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 53.94
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 0.0 0.0 74.5
TABLE Opening Year - With Project -01
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 SB Ramps & SR-55 NB Ramps
NOTES: Enderle Center Project - Opening Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 44963 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 69.46
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
89.2 171.9 360.3 771.3
TABLE Opening Year - With Project -02
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 NB Ramps & Carroll Way-Yorba St
South
NOTES: Enderle Center Project - Opening Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 46611 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
F01FIN
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 69.62
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
90.8 175.8 368.9 790.0
TABLE Opening Year - With Project -03
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between Carroll Way-Yorba St South & Yorba St
North-Enderle Center Dr
NOTES: Enderle Center Project - Opening Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 39312 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 IS
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 68.88
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
83.6 158.3 329.9 705.5
TABLE Opening Year - With Project -04
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Yorba St between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Opening Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 10768 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 63.77
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 73.0 142.4 299.3
TABLE Opening Year - With Project -05
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Enderle Center Dr between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Opening Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 6320 SPEED (MPH): 25 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 56.56
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 0.0 0.0 104.5
TABLE Future Year - No Project -01
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 SB Ramps & SR-55 NB Ramps
NOTES: Enderle Center Project - Future Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 41852 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 69.15
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
86.1 164.5 343.7 735.4
TABLE Future Year - No Project -02
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 NB Ramps & Carroll Way-Yorba St
South
NOTES: Enderle Center Project - Future Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 40478 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
F01FIN
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 69.01
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
84.8 161.1 336.3 719.3
TABLE Future Year - No Project -03
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between Carroll Way-Yorba St South & Yorba St
North-Enderle Center Dr
NOTES: Enderle Center Project - Future Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 34801 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 IS
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 68.35
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
79.0 147.0 304.7 650.7
TABLE Future Year - No Project -04
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Yorba St between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Future Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 7555 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 62.23
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 61.5 114.4 237.3
TABLE Future Year - No Project -05
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Enderle Center Dr between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Future Year - No Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 4604 SPEED (MPH): 25 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 55.19
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 0.0 0.0 87.0
TABLE Future Year - With Project -01
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 SB Ramps & SR-55 NB Ramps
NOTES: Enderle Center Project - Future Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 47013 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 69.66
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
91.2 176.8 371.0 794.5
TABLE Future Year - With Project -02
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between SR-55 NB Ramps & Carroll Way-Yorba St
South
NOTES: Enderle Center Project - Future Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 47934 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
F01FIN
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 69.74
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
92.1 178.9 375.8 804.8
TABLE Future Year - With Project -03
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: 17th St between Carroll Way-Yorba St South & Yorba St
North-Enderle Center Dr
NOTES: Enderle Center Project - Future Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 39963 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 45
9.34
0.19
1 IS
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 68.95
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
84.2 159.9 333.5 713.2
TABLE Future Year - With Project -04
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Yorba St between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Future Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 12716 SPEED (MPH): 40 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 64.49
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 79.7 158.1 333.9
TABLE Future Year - With Project -05
FHWA ROADWAY NOISE LEVEL ANALYSIS
RUN DATE: 03/04/2024
ROADWAY SEGMENT: Enderle Center Dr between 17th St & Vandenberg Ln
NOTES: Enderle Center Project - Future Year - With Project
* * ASSUMPTIONS * *
AVERAGE DAILY TRAFFIC: 7471 SPEED (MPH): 25 GRADE: .5
TRAFFIC DISTRIBUTION PERCENTAGES
DAY EVENING NIGHT
---------- -----
AUTOS
75.51 12.57
M-TRUCKS
1.56 0.09
H-TRUCKS
0.64 0.02
ACTIVE HALF -WIDTH (FT): 35
9.34
0.19
1 1:
SITE CHARACTERISTICS: SOFT
* * CALCULATED NOISE LEVELS * *
CNEL AT 50 FT FROM NEAR TRAVEL LANE CENTERLINE (dB) = 57.29
DISTANCE (FEET) FROM ROADWAY CENTERLINE TO CNEL
70 CNEL 65 CNEL 60 CNEL 55 CNEL
----------------------------
0.0 0.0 61.9 115.5
Appendix D
Vehicle Miles Traveled Analysis
ED SOLUTIONS,INC
WHERE EXPERIENCE AND PASSION MEET
Submitted on: February 6, 2024
Revised on: February 21, 2024, March 25, 2024, April 18, 2024, May 13, 2024 ; F/
Prepared by: Simon Lin, EIT, 1) E
Abby Pali
Meghan Macias, TE ' y
To: City of Tustin o.2697 cn
* xp. 03-31-26
Site: Enderle Center Rezone Project
EPD Project Number 23-069 s%9r�.TRAFF �0'�P
Subject: Vehicle Miles Traveled (VMT) Analysis
This technical study evaluates the potential vehicle miles traveled (VMT) for the proposed Enderle Center
Rezone Project (Project).
The Project is located at the southeast corner of 17th St and Carroll Way-Yorba St South. The Project site is
designated Site 17 (Enderle Center) in the City's General Plan Housing Element and consists of
approximately 1 1.62 acres. Of the site area, 7 acres have been identified suitable for housing development.
The site is zoned as Planned Community Commercial (PC COM). PCCOM use is limited to nonresidential land
uses. Currently the site supports a commercial center. Under the proposed overlay zone, a maximum of 413
housing units and 118,470 square feet (SF) of commercial use could be added to the existing land uses on
site. The Project location is shown in Figure 1.
The VMT analysis presented in this document evaluates the VMT impacts of both the residential and
commercial portions of the Project within the Enderle Center Housing Overlay Zone. Please note that this
VMT analysis is based on the requirements of the City of Tustin Vehicle Miles Traveled Analysis Guidelines.
Project Trip Generation
The Project trip generation was calculated using trip rates from the Institute of Transportation Engineers, Trip
Generation 1 1 th Edition, 2021. Existing conditions (Baseline) were assessed using trip rates for Land Use Code
932 (High -Turnover Sit -Down Restaurant), 821 (Retail), and 710 (Office). Based on the density of the
proposed housing, trip rates for Land Use Code 221 (Multifamily Housing (Mid -Rise)) were used. The ITE
rates used for the trip generation can be found in Appendix A. As shown in Table 1, the Project would
generate approximately 11,470 daily trips including 757 trips during the AM peak hour and 1,041 trips
during the PM peak hour.
Page 1 1
Enderle Center Rezone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
Table 1: Project Trip Generation
ITE PM
ITE Daily Trip
Project
ITE AM Trip
Project
Trip
Project
Land Use
ITE Code
Unit'
Rate/Unit
Project Size
ADTs
Rate/Unit
AM Trips
Rate/Unit
PM Trips
High-Turnover(Sit-Down) Restaurant
932
KSF
107.20
28.75
3,082
9.57
275
9.05
260
Existing Conditions
Retail
821
KSF
94.49
39.96
3,776
3.53
141
9.03
361
(Baseline)
Office
710
KSF
10.84
18.426
200
1.52
28
1.44
27
Existing Conditions
(Baseline)
TOTAL TRI PS
7,058
444
648
Proposed Multi -Family Housing
221
DU
4.54
413
1,875
0.37
153
0.39
161
Proposed Housing Units+
1Future High -Turnover (Sit -Down) Restaurant
932
KSF
107.20
39.09
4,190
9.57
374
9.05
354
Remaining Buildout
Future Retail
821
KSF
94.49
54.33
5,133
3.53
192
9.03
491
Capacity(Project)
Future Office
710
KSF
10.84
25.051
272
1 1.52
38
1.44
1 36
Proposed Project
TOTAL TRI PS
11,470
757
1,041
Existing Conditions+
Proposed Multi -Family Housing
221
DU
4.54
413
1,875
0.37
153
0.39
161
Proposed Housing Units+
High-Turnover(Sit-Down) Restaurant
932
KSF
107.20
67.84
7,272
9.57
649
9.05
614
Remaining Buildout
Retail
821
KSF
94.49
94.29
8,909
3.53
333
9.03
851
Capacity (Total)
Office
710
KSF
10.84
43.48
471
1.52
66
1.44
63
Existing Conditions+
Proposed Housing Units+
Remaining Buildout
Capacity (Total)
TOTAL TRIPS
18,528
1
1,201
1 1,689
1Future Commercial Buildout was calculated using the 0.4 FAR as stated in the General Plan, and then deducting existing land use area from the maximum buil clout
2Trip rates from the Institute of Transportation Engineers (ITE), Trip Generation Manual,11th Edition, 2021.
3KSF=Thousand Square Feet, DU= Dwelling Units
Page 1 2
Enderle Center Rezone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
Background
Senate Bill (SB) 743 was signed by Governor Brown in 2013 and required the Governor's Office of Planning
and Research (OPR) to amend the CEQA Guidelines to replace Level of Service (LOS) as the appropriate
method for evaluating transportation impacts under CEQA. SB 743 specified that the new criteria should
promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks,
and a diversity of land uses. The bill also specified that delay -based LOS could no longer be considered an
indicator of a significant impact on the environment under CEQA. In response, the Natural Resources Agency
amended the CEQA Guidelines to include new Section 15064.3 - Determining the Significance of
Transportation Impacts. The section states that Vehicle Miles Traveled (VMT) is the most appropriate measure
of a project's transportation impacts and provides lead agencies with the discretion to choose the most
appropriate methodology and thresholds for evaluating VMT. Section 15064.3(c) states that the provisions
of the section shall apply statewide beginning on July 1, 2020.
City of Tustin VMT Screening Criteria
The project is located in the City of Tustin (City). The City's Guidelines provide the following screening
thresholds to assess whether further VMT analysis is required. If a project meets one of the following criteria,
then the VMT impact of the project would be considered less -than -significant and no further analysis of VMT
would be required:
1. The project consists of 100% affordable housing.
2. The project is located within one half (1/2) mile of qualifying transit.
3. The project type has been identified as local serving land use.
4. The project is in a low VMT area.
5. The project generates less than 500 daily vehicle trips.
The applicability of each criterion to both portions of the Project is discussed below:
Screening Criteria 1 — Affordable Housing Screening As per the City's guidelines, projects which consist of
100% affordable housing will have a less than significant impact on VMT.
The Project does not consist of 100% affordable housing and therefore would not satisfy the requirements
of Screening criteria 1 - Affordable Housing Screening.
Screening Criteria 2 — High Quality Transit Screening As per the City's guidelines, projects located within
one half (1/2) mile of qualifying transit may be presumed to have a less than significant impact. Qualifying
transit is defined as follows:
• Major transit stop means a site containing an existing rail transit station, a ferry terminal served by
either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency
of service interval of 15 minutes or less during the morning and afternoon peak commute periods.
(Pub. Resources Code, § 21064.3)
• High -quality transit corridor means a corridor with fixed route bus service with service intervals no
longer than 15 minutes during peak commute hours. (Pub. Resources Code, § 21155).
The High -Quality Transit Area from the City's Guideline is shown in Figure 2. As shown in Figure 2, the Project
is located approximately 4 miles away from qualifying transit, therefore, the project would not satisfy the
requirements of Screening Criteria 2 — High Quality Transit screening.
Page 1 3
Enderle Center Housing Overlay Zone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
Screening Criteria 3 - Project Type Screening_ As per the City's guidelines, projects which propose local
serving retail (retail projects less than 50,000 square feet) or other local serving uses would have a less than
significant impact on VMT. The types of projects considered local serving include K-1 2 schools, local parks,
day care centers, gas stations, libraries, fire stations, and other local serving civic uses.
This screening criteria would be discussed separately for the residential and commercial portion of the Project
in the sections below.
Screening Criteria 4 - Low VMT Area Screening: The City's guidelines include a screening threshold for
projects located in a low VMT generating area. Low VMT generating area is defined as traffic analysis
zones (TAZs) with a total daily VMT per capita or VMT per employee that is less than the base level for the
city.
This screening criteria would be discussed separately for the residential and commercial portion of the Project
in the sections below.
Screening Criteria 5 - Generating less than 500 daily vehicle trips: As per the City's guidelines, projects
which generate less than 500 daily vehicle trips would have a less than significant impact on VMT.
As shown in Table 1, the Project is forecasted to generate 11,470 daily trips, which is more than 500 daily
vehicle trips. Therefore, the Project would not meet Screening Criteria 5.
The City of Tustin VMT screening form for the Project can be found in Appendix B.
Residential VMT Screening
Screening Criteria 3 - Project Type Screening_
Screening Criteria 3 would not apply to the residential portion of the Project.
Screening Criteria 4 - Low VMT Area Screening;
The Map of Low VMT Generating Area for VMT per capita from the City's Guideline is shown in Figure 3.
As shown in Figure 3, the Project is located in a low VMT area. Therefore, the residential portion of the
Project would satisfy the requirements of Screening Criteria 4 — Low-VMT Area Screening.
The residential portion of the Project would meet Screening Criteria 4 — Low-VMT Area Screening, and
therefore the residential portion of the Project's impact on VMT would be considered less -than -significant.
However, a complete VMT analysis was conducted at the request of the City (included below).
Page 14
Enderle Center Housing Overlay Zone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
Commercial VMT Screening
Screening Criteria 3 - Project Type Screening:
The project proposes retail use with an area of 118,470 SF, which is more than 50,000 square feet.
Therefore, it would not satisfy the requirements of Screening Criteria 3 - Project Type Screening.
Screening Criteria 4 - Low VMT Area Screening_
The Map of Low VMT Generating Area for VMT per employee from the City's Guideline is shown in Figure
4. As shown in Figure 4, the Project is not located in a low VMT area. Therefore, the commercial portion of
the Project would not satisfy the requirements of Screening Criteria 4 — Low-VMT Area Screening.
Because the commercial portion of the Project would not meet any of the City's screening criteria, the
commercial portion of the Project's impact on VMT would not be considered less -than -significant and an
analysis of VMT would be required.
VMT Analysis Methodology
The City's guidelines require use of the Orange County Transportation Analysis Model 5.0 v.6.22.23
(OCTAM) for preparation of VMT analysis. The Project is located within one Model Traffic Analysis Zone
(TAZ), TAZ 1103. The total population and employed population of the Project was calculated using the
current household average in nearby TAZs. The Project total households and population was entered into
TAZ 1103. Employment growth in TAZ 1 103 was already accounted for by the model.
The Model includes validated scenarios for 2016 and 2045. These scenarios have been validated using
existing traffic counts. Data for years between 2016 and 2045 can be extrapolated using linear
interpolation between the 2016 and 2045 Model output. The Model was run for the base year (2016) and
future year (2045) without and with -project conditions (i.e. four full Model runs). As noted below under the
discussion of significance thresholds, the City's significance threshold for residential projects is based on the
project's home -based VMT (HB VMT) per capita; City's significance threshold for non-residential projects is
based on the project's employment VMT (HBW VMT) per employee.
Residential VMT Significance Threshold
The significance criteria from the City's guidelines are as follows:
The City of Tustin VMT Guidelines have relied upon the recommendations provided by OPR and modeling
data provided by OCTA to establish the following VMT thresholds of significance for residential land use
projects:
Residential Projects: A significant transportation impact occurs if:
1. The project's base year home -based VMT per capita exceeds the OCTAM base model year
citywide average VMT per capita for the City of Tustin.
2. The project's future year home -based VMT per capita exceeds the OCTAM base model year
citywide average VMT per capita for the City of Tustin.
The metric utilized as the residential VMT threshold of significance for City of Tustin is the average city-wide
VMT under 2016 Base Model Year, which has been calculated to be 15.0 HB VMT per capita. The OPR
Technical Advisory recommends that a fifteen percent reduction in VMT below that of existing development
may be a reasonable threshold. However, given that the City of Tustin is primarily located within a suburban
setting, the amount of VMT reduction from an individual land use project is limited, and it is likely infeasible
to achieve a 15% reduction below the citywide average for many areas in the City. However, by ensuring
Page 15
Enderle Center Housing Overlay Zone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
that land use development projects result in no net increase in VMT over the current base year citywide VMT
averages, a sustained reduction in citywide VMT and GHG emissions will occur, the Project's impact on VMT
would be considered less -than -significant.
Project Residential VMT Evaluation
The total HB VMT of TAZ 1 103 was evaluated using the OCTAM VMT post -processor. To determine the
Project's HB VMT per capita, the total HB VMT of TAZ 1 103 is divided by the total residents of TAZ 1 103.
Tustin Citywide HB VMT per capita was obtained from the OCTAM base year model following a similar
process. The VMT analysis results per the City's significance criteria are shown in Table 2.
As shown in the tables, the Project's HB VMT per capita would be lower than the OCTAM base model year
citywide average HB VMT per capita for the City of Tustin under both base and future year conditions. The
Project's HB VMT per capita would be 19.7% below the City's threshold under base conditions and 18.7%
below the City's threshold under future conditions; therefore, the residential portion of the Project would
result in a less than significant VMT impact.
Commercial VMT Significance Threshold
The significance criteria from the City's guidelines are as follows:
The City of Tustin VMT Guidelines have relied upon the recommendations provided by OPR and modeling
data provided by OCTA to establish the following VMT thresholds of significance for residential land use
projects:
Non-residential Projects: A significant transportation impact occurs if:
1. The project's base year employment VMT per employee exceeds the OCTAM base model year
citywide average VMT per employee for the City of Tustin.
2. The project's future year employment VMT per employee exceeds the OCTAM base model year
citywide average VMT per employee for the City of Tustin.
The metric utilized as the employment VMT per employee VMT threshold of significance for City of Tustin is
the average city-wide VMT under 2016 Base Model Year, which has been calculated to be 25.1 HBW VMT
per employee. The OPR Technical Advisory recommends that a fifteen percent reduction in VMT below that
of existing development may be a reasonable threshold. However, given that the City of Tustin is primarily
located within a suburban setting, the amount of VMT reduction from an individual land use project is limited,
and it is likely infeasible to achieve a 15% reduction below the citywide average for many areas in the
City. However, by ensuring that land use development projects result in no net increase in VMT over the
current base year citywide VMT averages, a sustained reduction in citywide VMT and GHG emissions will
occur, the Project's impact on VMT would be considered less -than -significant.
Project Commercial VMT Evaluation
The total HBW VMT of TAZ 1 103 was evaluated using the OCTAM VMT post -processor. To determine the
Project's HBW VMT per employee, the total HBW VMT of TAZ 1 103 is divided by the total employees of
TAZ 1103. Tustin Citywide HBW VMT per employee was obtained from the OCTAM base year model
following a similar process. The VMT analysis results per the City's significance criteria are shown in Table
3.
As shown in Table 3, the Project's HBW VMT per employee would be lower than the OCTAM base model
year citywide average HBW VMT per employee for the City of Tustin under both base and future year
conditions. The Project's HBW VMT per employee would be 5.5% below the City's threshold under base
Page 16
Enderle Center Housing Overlay Zone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
conditions and 3.7% below the City's threshold under future conditions; therefore, the commercial portion of
the Project would result in a less than significant VMT impact.
Overall, the entire Project can be assumed to have a less than significant VMT impact.
If you have any questions, please feel free to contact me at techservices@epdsolutions.com or at (949)
794-1 180.
Page 17
Enderle Center Housing Overlay Zone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
Table 2: VMT Analysis of Residential of Project Impact per City Guidelines
Base Year 2016
Future Year 2045
Project TAZ 1 103 Zone Total Home -based VMT
47,899
48,954
TAZ 1 103 Total Residents
3,991
4,029
Project 1103 HB VMT per capita
12.0
12.2
City of Tustin Baseline Home -based VMT
1,356,977
1,356,977
City of Tustin Baseline Total Residents
90,762
90,762
City of Tustin Baseline HB VMT per capita
15.0
15.0
% Above/Below Threshold
-19.7%
-18.7%
Impact?
No
No
Table 3: VMT Analysis of Commercial Part of Project Impact per City Guidelines
Base Year 2016
Future Year 2045
Project TAZ 1 103 Zone Total Home -based Work VMT
261,211
273,166
TAZ 1 103 Total Employees
11,012
11,303
Project 1 103 HBW VMT per employee
23.7
24.2
City of Tustin Baseline Home -based Work VMT
1,475,341
1,475,341
City of Tustin Baseline Total Employees
58,774
58,774
City of Tustin Baseline HBW VMT per employee
25.1
25.1
% Above/Below Threshold
-5.5%
-3.7%
Impact?
No
No
Page 18
Enderle Center Housing Overlay Zone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
Figure 1: Project Site Location
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t c
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Page 19
Enclerle Center Housing Overlay Zone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
Figure 2: High -Quality Transit Area
Exhibit B
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CITY OF TUSTIN VMT ANALYSIS GUIDELINES
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Enderle Center Housing Overlay Zone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
Figure 4: Low VMT Generating Area - VMT per employee
Exhibit E
Low VMT Areas - VMT Per Employee
Legend: = Project Site
J[7 = VMT employee less than or equal to City of Tustin 2016 citywide average VMT employee
N L. j = City of Tustin Boundary
CITY Of TUSTIN VMT ANALYSIS GUIDELINES
Page 1 12
engineering
group, inc.
Enderle Center Rezone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
APPENDIX A — ITE Trip Generation Rates
Land Use: 221
Multifamily Housing (Mid -Rise)
Description
Mid -rise multifamily housing includes apartments and condominiums located in a building that
has between four and 10 floors of living space. Access to individual dwelling units is through an
outside building entrance, a lobby, elevator, and a set of hallways.
Multifamily housing (low-rise) (Land Use 220), multifamily housing (high-rise) (Land Use 222), off -
campus student apartment (mid -rise) (Land Use 226), and mid -rise residential with ground -floor
commercial (Land Use 231) are related land uses.
Land Use Subcategory
Data are presented for two subcategories for this land use: (1) not close to rail transit and (2)
close to rail transit. A site is considered close to rail transit if the walking distance between the
residential site entrance and the closest rail transit station entrance is'h mile or less.
Additional Data
For the six sites for which both the number of residents and the number of occupied dwelling
units were available, there were an average of 2.5 residents per occupied dwelling unit.
For the five sites for which the numbers of both total dwelling units and occupied dwelling units
were available, an average of 96 percent of the total dwelling units were occupied.
The technical appendices provide supporting information on time -of -day distributions for this
land use. The appendices can be accessed through either the ITETripGen web app or the trip
generation resource page on the ITE website (https://www.ite.org/technical-resources/topics/trip-
................................................................
and -parking -generation/).
...............................
It is expected that the number of bedrooms and number of residents are likely correlated to the
trips generated by a residential site. To assist in future analysis, trip generation studies of all
multifamily housing should attempt to obtain information on occupancy rate and on the mix of
residential unit sizes (i.e., number of units by number of bedrooms at the site complex).
The sites were surveyed in the 1990s, the 2000s, the 2010s, and the 2020s in Alberta (CAN),
California, District of Columbia, Florida, Georgia, Illinois, Maryland, Massachusetts, Minnesota,
Montana, New Jersey, New York, Ontario (CAN), Oregon, Utah, and Virginia.
Source Numbers
168, 188, 204, 305, 306, 321, 818, 857, 862, 866, 901, 904, 910, 949, 951, 959, 963, 964, 966, 967,
969, 970, 1004, 1014, 1022, 1023, 1025, 1031, 1032, 1035, 1047, 1056, 1057, 1058, 1071, 1076
its General Urban/Suburban and Rural (Land Uses 000-399) 273
Multifamily Housing (Mid -Rise)
Not Close to Rail Transit (221)
Vehicle Trip Ends vs: Dwelling Units
On a: Weekday
Setting/Location: General Urban/Suburban
Number of Studies: 11
Avg. Num. of Dwelling Units: 201
Directional Distribution: 50% entering, 50% exiting
Vehicle Trip Generation per Dwelling Unit
Average Rate Range of Rates Standard Deviation
4.54 3.76 - 5.40 0.51
Data Plot and Equation
2000
-----------------------------------------------------------------------------------------------------------
X
X
�X
X
w
N
a
1000
u X
X
X
0 0 100 200 300 400
X = Number of Dwelling Units
X Study Site Fitted Curve - - - - - Average Rate
Fitted Curve Equation: T = 4.77(X) - 46.46 RI= 0.93
274 Trip Generation Manual 11th Edition • Volume 3 its
Multifamily Housing (Mid -Rise)
Not Close to Rail Transit (221)
Vehicle Trip Ends vs: Dwelling Units
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 7 and 9 a.m.
Setting/Location: General Urban/Suburban
Number of Studies: 30
Avg. Num. of Dwelling Units: 173
Directional Distribution: 23% entering, 77% exiting
Vehicle Trip Generation per Dwelling Unit
Average Rate Range of Rates Standard Deviation
0.37 0.15 - 0.53 0.09
Data Plot and Equation
a
w U)
a
300
200
100
X,
X
X /X X
X'
X' X
X
0 0 100 200 300 400 500
X = Number of Dwelling Units
X Study Site Fitted Curve - - - - - Average Rate
Fitted Curve Equation: T = 0.44(X) - 11.61 RI= 0.91
its General Urban/Suburban and Rural (Land Uses 000-399) 275
Multifamily Housing (Mid -Rise)
Not Close to Rail Transit (221)
Vehicle Trip Ends vs: Dwelling Units
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 4 and 6 p.m.
Setting/Location: General Urban/Suburban
Number of Studies: 31
Avg. Num. of Dwelling Units: 169
Directional Distribution: 61 % entering, 39% exiting
Vehicle Trip Generation per Dwelling Unit
Average Rate Range of Rates Standard Deviation
0.39 0.19 - 0.57 0.08
Data Plot and Equation
200
X
X
X
a
X
w
a XX
100 X
u
XX
X
X
X'
X
X X
X X
X
XX
0 0 100 200 300 400 500
X = Number of Dwelling Units
X Study Site Fitted Curve - - - - - Average Rate
Fitted Curve Equation: T = 0.39(X) + 0.34 RI= 0.91
276 Trip Generation Manual 11th Edition • Volume 3 its
Land Use: 710
General Office Building
Description
A general office building is a location where affairs of businesses, commercial or industrial
organizations, or professional persons or firms are conducted. An office building houses multiple
tenants that can include, as examples, professional services, insurance companies, investment
brokers, a banking institution, a restaurant, or other service retailers. A general office building
with a gross floor area of 10,000 square feet or less is classified as a small office building (Land
Use 712). Corporate headquarters building (Land Use 714), single tenant office building (Land
Use 715), medical -dental office building (Land Use 720), office park (Land Use 750), research and
development center (Land Use 760), and business park (Land Use 770) are additional related uses.
Additional Data
If two or more general office buildings are in close physical proximity (within a close walk) and
function as a unit (perhaps with a shared parking facility and common or complementary tenants),
the total gross floor area or employment of the paired office buildings can be used for calculating
the site trip generation. If the individual buildings are isolated or not functionally related to one
another, trip generation should be calculated for each building separately.
For study sites with reported gross floor area and employees, an average employee density of
3.3 employees per 1,000 square feet GFA (or roughly 300 square feet per employee) has been
consistent through the 1980s, 1990s, and 2000s. No sites counted in the 2010s reported both GFA
and employees.
The average building occupancy varies considerably within the studies for which occupancy data
were provided. The reported occupied gross floor area was 88 percent for general urban/suburban
sites and 96 percent for the center city core and dense multi -use urban sites.
The technical appendices provide supporting information on time -of -day distributions for this
land use. The appendices can be accessed through either the ITETripGen web app or the trip
generation resource page on the ITE website (https://www.ite.org/technical-resources/topics/trip-
................................................................
and -parking -generation/).
...............................
The average numbers of person trips per vehicle trip at the eight center city core sites at which
both person trip and vehicle trip data were collected are as follows:
• 2.8 during Weekday, Peak Hour of Adjacent Street Traffic, one hour between 7 and 9 a.m.
• 2.9 during Weekday, AM Peak Hour of Generator
• 2.9 during Weekday, Peak Hour of Adjacent Street Traffic, one hour between 4 and 6 p.m.
• 3.0 during Weekday, PM Peak Hour of Generator
its General Urban/Suburban and Rural (Land Uses 400-799) 707
The average numbers of person trips per vehicle trip at the 18 dense multi -use urban sites at
which both person trip and vehicle trip data were collected are as follows:
• 1.5 during Weekday, Peak Hour of Adjacent Street Traffic, one hour between 7 and 9 a.m.
• 1.5 during Weekday, AM Peak Hour of Generator
• 1.5 during Weekday, Peak Hour of Adjacent Street Traffic, one hour between 4 and 6 p.m.
• 1.5 during Weekday, PM Peak Hour of Generator
The average numbers of person trips per vehicle trip at the 23 general urban/suburban sites at
which both person trip and vehicle trip data were collected are as follows:
• 1.3 during Weekday, Peak Hour of Adjacent Street Traffic, one hour between 7 and 9 a.m.
• 1.3 during Weekday, AM Peak Hour of Generator
• 1.3 during Weekday, Peak Hour of Adjacent Street Traffic, one hour between 4 and 6 p.m.
• 1.4 during Weekday, PM Peak Hour of Generator
The sites were surveyed in the 1980s, the 1990s, the 2000s, the 2010s, and the 2020s in Alberta
(CAN), California, Colorado, Connecticut, Georgia, Illinois, Indiana, Kansas, Kentucky, Maine,
Maryland, Michigan, Minnesota, Missouri, Montana, New Hampshire, New Jersey, New York,
Ontario (CAN) Pennsylvania, Texas, Utah, Virginia, and Washington.
Source Numbers
161, 175, 183, 184, 185, 207, 212, 217, 247, 253, 257, 260, 262, 273, 279, 297, 298, 300, 301, 302,
303, 304, 321, 322, 323, 324, 327, 404, 407, 408, 419, 423, 562, 734, 850, 859, 862, 867, 869, 883,
884, 890, 891, 904, 940, 944, 946, 964, 965, 972, 1009, 1030, 1058, 1061
708 Trip Generation Manual 11th Edition • Volume 4 ff.=
General Office Building
(710)
Vehicle Trip Ends vs: 1000 Sq. Ft. GFA
On a: Weekday
Setting/Location: General Urban/Suburban
Number of Studies: 59
Avg. 1000 Sq. Ft. GFA: 163
Directional Distribution: 50% entering, 50% exiting
Vehicle Trip Generation per 1000 Sq. Ft. GFA
Average Rate Range of Rates Standard Deviation
10.84 3.27 - 27.56 4.76
Data Plot and Equation
m
a
w
C
a
H
i
H
6000
4000
2000
0
0 200 400
X = 1000 Sq. Ft. GFA
X Study Site Fitted Curve
Fitted Curve Equation: Ln(T) = 0.87 Ln(X) + 3.05
600
- - - - - Average Rate
RI= 0.78
800
its General Urban/Suburban and Rural (Land Uses 400-799) 709
General Office Building
(710)
Vehicle Trip Ends vs: 1000 Sq. Ft. GFA
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 7 and 9 a.m.
Setting/Location: General Urban/Suburban
Number of Studies: 221
Avg. 1000 Sq. Ft. GFA: 201
Directional Distribution: 88% entering, 12% exiting
Vehicle Trip Generation per 1000 Sq. Ft. GFA
Average Rate Range of Rates Standard Deviation
1.52 0.32 - 4.93 0.58
Data Plot and Equation
2000
a
w
a
H 1000
u
0'
0
/X
X
X X X �.
X
X '
X�
ti u.. X
X X ,. X x
X X X XX X
X
X
0X
0
1000
X = 1000 Sq. Ft. GFA
X Study Site Fitted Curve
Fitted Curve Equation: Ln(T) = 0.86 Ln(X) + 1.16
- - - - - Average Rate
RI= 0.78
2000
710 Trip Generation Manual 11th Edition • Volume 4 its
General Office Building
(710)
Vehicle Trip Ends vs: 1000 Sq. Ft. GFA
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 4 and 6 p.m.
Setting/Location: General Urban/Suburban
Number of Studies: 232
Avg. 1000 Sq. Ft. GFA: 199
Directional Distribution: 17% entering, 83% exiting
Vehicle Trip Generation per 1000 Sq. Ft. GFA
Average Rate Range of Rates Standard Deviation
1.44 0.26 - 6.20 0.60
Data Plot and Equation
2000
a
w
a
H 1000
i
0'
0
X.
X
------------------------
X
XX X
X,'
XSC .
X X XXX. X
X XX X
X � ,
X 7X
XC XX X X X X
X
X
XX
X
X
1000
X = 1000 Sq. Ft. GFA
X Study Site Fitted Curve
Fitted Curve Equation: Ln(T) = 0.83 Ln(X) + 1.29
- - - - - Average Rate
RI= 0.77
2000
its General Urban/Suburban and Rural (Land Uses 400-799) 711
Land Use: 821
Shopping Plaza (40-150k)
Description
A shopping plaza is an integrated group of commercial establishments that is planned, developed,
owned, and managed as a unit. Each study site in this land use has between 40,000 and 150,000
square feet of gross leasable area (GLA). The term "plaza" in the land use name rather than
"center" is simply a means of distinction between the different shopping center size ranges.
Various other names are commonly used to categorize a shopping plaza within this size range,
depending on its specific size and tenants, such as neighborhood center, community center, and
fashion center.
Its major tenant is often a supermarket but many sites are anchored by home improvement,
discount, or other stores. A shopping plaza typically contains more than retail merchandising
facilities. Office space, a movie theater, restaurants, a post office, banks, a health club, and
recreational facilities are common tenants. A shopping plaza is almost always open-air and the
GLA is the same as the gross floor area of the building.
The 150,000 square feet GLA threshold value between shopping plaza and shopping center
(Land Use 820) is based on an examination of trip generation data. For a shopping plaza that is
smaller than the threshold value, the presence or absence of a supermarket within the plaza has
a measurable effect on site trip generation. For a shopping center that is larger than the threshold
value, the trips generated by its other major tenants mask any effects of the presence or absence
of an on -site supermarket.
The 40,000 square feet GFA threshold between shopping plaza and strip retail plaza (Land Use
822) was selected based on an examination of the overall shopping center/plaza database. No
shopping plaza with a supermarket as its anchor is smaller than 40,000 square feet GLA.
Shopping center (>150k) (Land Use 820), strip retail plaza (<40k) (Land Use 822), and factory
outlet center (Land Use 823) are related uses.
Land Use Subcategory
The presence or absence of a supermarket in a shopping plaza has been determined to have a
measurable effect on site trip generation. Therefore, data are presented for two subcategories for
this land use: sites with a supermarket anchor and sites without a supermarket.
Additional Data
The technical appendices provide supporting information on time -of -day distributions for this
land use. The appendices can be accessed through either the ITETripGen web app or the trip
generation resource page on the ITE website (https://www.ite.org/technical-resources/topics/trip-
................................................................
and -parking -generation/).
...............................
its General Urban/Suburban and Rural (Land Uses 800-999) 197
The sites were surveyed in the 1980s, the 1990s, the 2000s, and the 2010s in Alberta (CAN),
British Columbia (CAN), California, Connecticut, District of Columbia, Florida, Georgia, Illinois,
Indiana, Iowa, Kansas, Kentucky, Maine, Maryland, Massachusetts, Minnesota, Nevada, New
Jersey, New York, Ontario (CAN), Oregon, Pennsylvania, South Dakota, Texas, Vermont, Virginia,
Washington, and Wisconsin.
Source Numbers
105, 110, 156, 159, 186, 198, 204, 211, 213, 239, 259, 260, 295, 301, 304, 305, 307, 317, 319, 358,
376, 390, 400, 404, 437, 444, 446, 507, 580, 598, 658, 728, 908, 926, 944, 946, 960, 973, 974, 1004,
1009, 1025, 1069
198 Trip Generation Manual 11th Edition • Volume 5 its
Shopping Plaza (40-150k) - Supermarket - Yes
(821)
Vehicle Trip Ends vs: 1000 Sq. Ft. GLA
On a: Weekday
Setting/Location: General Urban/Suburban
Number of Studies: 17
Avg. 1000 Sq. Ft. GLA: 81
Directional Distribution: 50% entering, 50% exiting
Vehicle Trip Generation per 1000 Sq. Ft. GLA
Average Rate Range of Rates Standard Deviation
94.49 57.86 - 175.32 26.55
Data Plot and Equation
20000
a
w U)
a
10000
i
H
00
X X
X X X
X
X
100
X = 1000 Sq. Ft. GLA
X Study Site Fitted Curve
Fitted Curve Equation: T = 76.96(X) + 1412.79
- - - - - Average Rate
RI= 0.50
200
its General Urban/Suburban and Rural (Land Uses 800-999) 199
Shopping Plaza (40-150k) - Supermarket - Yes
(821)
Vehicle Trip Ends vs: 1000 Sq. Ft. GLA
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 7 and 9 a.m.
Setting/Location: General Urban/Suburban
Number of Studies: 16
Avg. 1000 Sq. Ft. GLA: 86
Directional Distribution: 62% entering, 38% exiting
Vehicle Trip Generation per 1000 Sq. Ft. GLA
Average Rate Range of Rates Standard Deviation
3.53 1.88 - 6.62 1.17
Data Plot and Equation
m
a
W U)
a
H
I
H
600
400
200
,l
00
X Study Site
Fitted Curve Equation: Not Given
100
X = 1000 Sq. Ft. GLA
- - - - - Average Rate
Rz= —
200
200 Trip Generation Manual 11th Edition • Volume 5 its
Shopping Plaza (40-150k) - Supermarket - Yes
(821)
Vehicle Trip Ends vs: 1000 Sq. Ft. GLA
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 4 and 6 p.m.
Setting/Location: General Urban/Suburban
Number of Studies: 51
Avg. 1000 Sq. Ft. GLA: 87
Directional Distribution: 48% entering, 52% exiting
Vehicle Trip Generation per 1000 Sq. Ft. GLA
Average Rate Range of Rates Standard Deviation
9.03 5.35 - 16.45 2.37
Data Plot and Equation
2000
w
a
H 1000
i
00
X
X X '
X XX X
X X
X,
X X X
X X XX
XX
X X X
X XX X
XX
.'XX X
SC X X
X
XX
X Study Site —
Fitted Curve Equation: T = 7.67(X) + 118.86
100
X = 1000 Sq. Ft. GLA
Fitted Curve
X
- - - - - Average Rate
RI= 0.62
200
its General Urban/Suburban and Rural (Land Uses 800-999) 201
Land Use: 932
High -Turnover (Sit -Down) Restaurant
Description
This land use consists of sit-down, full -service eating establishments with a typical duration of
stay of 60 minutes or less. This type of restaurant is usually moderately priced, frequently belongs
to a restaurant chain, and is commonly referred to as casual dining. Generally, these restaurants
serve lunch and dinner; they may also be open for breakfast and are sometimes open 24 hours
a day. These restaurants typically do not accept reservations. A patron commonly waits to be
seated, is served by wait staff, orders from a menu, and pays after the meal.
Some facilities offer carry -out for a small proportion of its customers. Some facilities within this
land use may also contain a bar area for serving food and alcoholic drinks.
Fast casual restaurant (Land Use 930), fine dining restaurant (Land Use 931), fast-food restaurant
without drive -through window (Land Use 933), and fast-food restaurant with drive -through window
(Land Use 934) are related uses.
Additional Data
Users should exercise caution when applying statistics during the AM peak periods, as the sites
contained in the database for this land use may or may not be open for breakfast. In cases where
it was confirmed that the sites were not open for breakfast, data for the AM peak hour of the
adjacent street traffic were removed from the database.
If the restaurant has outdoor seating, its area is not included in the overall gross floor area. For
a restaurant that has significant outdoor seating, the number of seats may be more reliable than
GFA as an independent variable on which to establish a trip generation rate.
The technical appendices provide supporting information on time -of -day distributions for this
land use. The appendices can be accessed through either the ITETripGen web app or the trip
generation resource page on the ITE website (https://www.ite.org/technical-resources/topics/trip-
................................................................
and -parking -generation/).
...............................
The sites were surveyed in the 1980s, the 1990s, the 2000s, and the 2010s in Alberta (CAN),
California, Florida, Georgia, Indiana, Kentucky, Massachusetts, Minnesota, New Hampshire, New
Jersey, New York, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, South Dakota, Texas,
Vermont, and Wisconsin.
Source Numbers
126, 269, 275, 280, 300, 301, 305, 338, 340, 341, 358, 384, 424, 432, 437, 438, 444, 507, 555, 577,
589, 617, 618, 728, 868, 884, 885, 903, 927, 939, 944, 961, 962, 977, 1048
672 Trip Generation Manual 11th Edition • Volume 5 its
High -Turnover (Sit -Down) Restaurant
(932)
Vehicle Trip Ends vs: 1000 Sq. Ft. GFA
On a: Weekday
Setting/Location: General Urban/Suburban
Number of Studies: 50
Avg. 1000 Sq. Ft. GFA: 5
Directional Distribution: 50% entering, 50% exiting
Vehicle Trip Generation per 1000 Sq. Ft. GFA
Average Rate Range of Rates Standard Deviation
107.20 13.04 - 742.41 66.72
Data Plot and Equation
2000
a
w
C
a
H 1000
u
0
0
X
X X
X '
X
X X X X
X ���'XXX X
X XX X
X
X X X
�X
X,X X
X.'
XXX X � X
X
X Study Site
Fitted Curve Equation: Not Given
10
X = 1000 Sq. Ft. GFA
- - - - - Average Rate
Rz=
20
its General Urban/Suburban and Rural (Land Uses 800-999) 673
High -Turnover (Sit -Down) Restaurant
(932)
Vehicle Trip Ends vs: 1000 Sq. Ft. GFA
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 7 and 9 a.m.
Setting/Location: General Urban/Suburban
Number of Studies: 37
Avg. 1000 Sq. Ft. GFA: 5
Directional Distribution: 55% entering, 45% exiting
Vehicle Trip Generation per 1000 Sq. Ft. GFA
Average Rate Range of Rates Standard Deviation
9.57 0.76 - 102.39 11.61
Data Plot and Equation
200
a
w
a
H 100
u
H
00
X
X
051
X-------------------- ----------------------
X
X X X'
X
XX X
X �'
X X X
X,X X X X
X1.
X X
'X XX X
X X
X
X Study Site
Fitted Curve Equation: Not Given
10
X = 1000 Sq. Ft. GFA
- - - - - Average Rate
Rz=
20
674 Trip Generation Manual 11th Edition • Volume 5 its
High -Turnover (Sit -Down) Restaurant
(932)
Vehicle Trip Ends vs: 1000 Sq. Ft. GFA
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 4 and 6 p.m.
Setting/Location: General Urban/Suburban
Number of Studies: 104
Avg. 1000 Sq. Ft. GFA: 6
Directional Distribution: 61 % entering, 39% exiting
Vehicle Trip Generation per 1000 Sq. Ft. GFA
Average Rate Range of Rates Standard Deviation
9.05 0.92 - 62.00 6.18
Data Plot and Equation
200
a
w
a
H 100
n
F
00
X
X X'
X
X
X
X
X'
X------------- '----------------------- ----------------------
X XX
'��X
X x,�X X
X X X XX X
X X X IX, '
X X X*XXXX' XX X
X X
X X }X'I')K X X X
X
'X
X '�XXX X X X
X'X XVX � X
X'
X XX XX X
X Study Site
Fitted Curve Equation: Not Given
10
X = 1000 Sq. Ft. GFA
- - - - - Average Rate
Rz=
20
its General Urban/Suburban and Rural (Land Uses 800-999) 675
Enderle Center Housing Overlay Zone Project, City of Tustin
Vehicle Miles Traveled (VMT) Analysis
APPENDIX B — City of Tustin VMT Screening Form
1 OT Z
&1�% CITY OF TUSTIN
VMT SCREENING FORM FOR LAND USE PROJECTS
This form acknowledges the City of Tustin requirements for the evaluation of vehicle miles traveled (VMT) under CEQA.
1W The analysis provided in this form should follow the City of Tustin approved VMT Guidelines, dated February 13, 2024.
I. Proiect Description
Case Number: GPA-2024-0001, CA-2024-0003, and ZC-2024-0001
Project Name: Enderle Center Housing Overlay Zone
Project Location: The Project is located at the southeast corner of 17th St and Carroll Way-Yorba St South.
Project Description
413 housing units and 118,470 square feet (SF) of commercial use
Current GP Land Use: 1 PCCB Proposed GP Land Use: 1 PCCB
Current Zoning: I PC COM Proposed Zoning: PC COM & HOD
Does the Project require a General Plan Amendment and/or Zone Change? YES I X NO
II. VMT
Is the Project 100% affordable housing?
Is the Project within 1/2 mile of qualifying transit?
Is the Project a local serving land use?
Is the Project in a low VMT area?
Are the Project's Net Daily Trips less than 500 ADT?
VMT Area Evaluation:
YES
NO
X
YES
NO
X
YES
NO
X
Residential
Commercial
YES
X
NO
X
YES
NO
X
City of Tustin VMT Thresholds
Citywide Average Home -Based VMT1 = 15.0 VMT/Capita
Citywide Average Employment VMT1 = 25.1 VMT/Employee
1 OCTAM 5.0 v.6.22.23 base year (2016) statistics
Attachments:
Attachments:
Attachments:
Attachments:
Attachments:
Project Traffic Analysis Zone (TAZ)
VMT Rate for Project TAZl
Type of Project
1103
12.1
VMT/Capita
Residential:
X
25.3
1 VMT/Employee
Non -Residential:
X
p Generation Evaluation:
Source of Trip Generation: Institute of Transportation Engineers (ITE), Trip Generation Manual,11th Edition, 2021
* Use trip rates from the latest edition of the ITE Trip Generation Manual or as approved by City Staff.
Project Trip Generation: 1 18,528 1 Average Daily Trips (ADT)
Internal Trip Credit: YES NO X %Trip Credit:
Pass -By Trip Credit: YES NO X %Trip Credit:
Affordable Housing Credit: YES NO X %Trip Credit:
Existing Land Use Trip Credit: YES NO X Trip Credit:
Net Project Trip Generation: 118,528Average Daily Trips (ADT) Attachments:
project trip generation warrant an LOS evaluation outside of CEQA? I YES I X I NO
Version: March 11, 2024
L UI L
III. VMT Analysis Summary
. Is additional VMT modeling required to evaluate impacts? I YES* I X I NO
Projects that do not satisfy at least one (1) of the VMT screening criteria AND generate 2,400 or more net daily trips AND require a zone change/general plan
amendment may require additional VMT modeling using OCTAM. Project that generates less than 2,400 daily trips may use the base TAZ rate for VMT analysis and
mitigation purposes.
City of Tustin VMT Threshold of Significance:
Unmitigated Project VMT Rate:
Does Unmitigated Project VMT Rate Exceed VMT Threshold?
Is mitigation required?
Percentage Reduction Required to Achieve the Citywide Average VMT:
Mitigation Measures:
*A complete VMT analysis for the residential portion was
conducted at the request of the City.
Residential-VMT per Capita: City's Threshold: 15.0
Commercial-VMT per Employee: City's Threshold: 25.1
Residential-VMT per Capita: Base Year 2016:12.0 Future Year 2045: 12.2
Commercial-VMT per Employee: Base Year 2016:23.7 Future Year 2045:24.2
YES I I NO x
YES I I NO x
Source:
VMT Reduction Mitigation Measure:
Estimated VMT
Reduction (%)
1.
N/A
0.00%
2.
N/A
0.00%
3.
N/A
0.00%
4.
N/A
0.00%
5.
N/A
0.00%
6.
N/A
0.00%
7.
N/A
0.00%
8.
N/A
0.00%
9,
N/A
0.00%
10.
N/A
0.00%
Total VMT Reduction (%)
All mitigation measures are subject to become Conditions of Approval of the project. Provide attachments showing all
VMT reduction calculations.
Mitigated Project TAZ VMT Rate:
I. Significance Finding:
(Less than significant, less than significant with mitigation, potential significant, etc.) FL,,�than
significant
Prepared By
Developer/Applicant
Company:
Contact:
Address:
Phone:
Email:
Date:
Company:
Contact:
Address:
Phone:
Email:
Date:
EPD Solutions
City of Tustin
Abby Pal (abby@epdsolutions.com)
Krys Saldivar
3333 Michelson Drive, Suite 500 Irvine, CA
300 Centennial Way, Tustin, CA 92780
949_798-1180
714-573-3172
techservices@epdsolutions.com
ksaldivar@tustinca.org
Revised 3/22/24
Revised 3/22/2024
Approved by:
11 Tustin Public Works Engineering Date I Tustin Community Development Planning Date 11
Development review and processing fees should be submitted with, or prior to the submittal of this Form.
The Public Works and/or Planning Division staff will not process the Form prior to fees being paid to the City.
Version: March 11, 2024
OCTAM 5.0 v.6.22.23 Base Model Year 2016 VMT Statistics
Zone
Home -based VMT per Capita
Employment (commute) VMT per
employee
759
8.8
25.2
832
23.6
33.8
851
23.5
34.3
857
16.0
26.0
859
13.0
25.2
863
16.9
25.3
1102
15.4
25.9
1103
12.1
25.3
1104
21.1
30.1
1105
12.2
25.1
1106
15.8
24.6
1107
14.5
24.3
1108
21.8
33.2
1109
11.6
24.4
1110
21.2
29.4
1111
13.8
24.6
1112
11.4
22.8
1113
10.7
23.6
1114
11.6
23.6
1115
14.1
24.4
1116
15.5
28.6
1117
12.1
24.3
1118
17.2
26.8
1119
15.0
26.0
1120
16.0
27.6
1121
12.9
23.3
1122
13.5
32.1
1123
11.6
22.5
1124
14.7
27.4
1125
16.8
24.5
1126
0.0
23.6
1127
17.5
27.4
1128
0.0
25.2
1129
17.2
28.0
1130
0.0
24.8
1131
18.0
25.7
1132
0.0
25.0
1133
0.0
0.0
1134
13.4
26.0
1135
0.0
0.0
1136
8.3
36.8
1137
17.2
29.6
1138
0.0
25.3
* Geography nests into OCTAM zone structure. VMT includes all VMT to/from specified geography, except for
VMT that leaves OCTAM model area.
** Note that as OCTAM is updated, these statistics are subject to change.
Appendix E
Archaeological Resources
Records Search
0
BFSA Environmental Services Archaeology/History/Paleontology/Biology
A Perennial Company
February 16, 2024
Jazmin Rodriguez
EPD Solutions
3333 Michelson Drive, Suite 500
Irvine, California 92660
RE: Archaeological Resources Records Search Results for the Enderle Center Project, Tustin,
California (APNs 401-252-05, -06, -08, through -10, 401-253-03, and -04)
Dear Ms. Rodriguez:
An archaeological resources records search has been completed for the Enderle Center
Project. The proposed approximately 11-acre project is located at the intersection of 17th Street
and Enderle Center Drive (Assessor's Parcel Numbers [APNs] APNs 401-252-05, -06, -08,
through -10, 401-253-03, and -04) within the city of Tustin, California. The subject property is
situated within an unsectioned portion of Township 5 South, Range 9 West on the U.S. Geological
Survey (USGS) Orange, California (7.5-minute) topographic quadrangle map. As part of the
environmental review process, BFSA Environmental Services, a Perennial Company (BFSA),
conducted an archaeological resources records search at the South Central Coastal Information
Center (SCCIC) at California State University, Fullerton.
Archaeological Records Search Results
The archaeological resources records search was completed by BFSA at the SCCIC on
August 22, 2023, and encompassed the project area as well as an additional 500 feet surrounding
the project. Based upon the records search results, no resources are recorded within the project or
the 500-foot buffer search area. No previous studies are recorded on the property, however, there
are two studies recorded within the search area that are not specific to the subject property (Padon
1989; McKenna 2001).
BFSA requested a review of the Sacred Lands File (SLF) by the Native American Heritage
Commission (NAHC) on August 18, 2023, to determine if any recorded Native American sacred
sites, or locations of religious or ceremonial importance are present within one mile of the project.
The results of this search were received on October 3, 2023. The results were negative.
14010 Poway Road, Suite A, Poway, California 92064; Phone (858) 484-0915
BFSA Environmental Services, a Perennial Company — Page 2
The full results of the SCCIC completed records search and the NAHC SLF search results
are attached to this letter report (Attachments A and B). Please contact us should you have any
questions or require additional study for this project.
Regards,
Tracy Stropes, M.A., RPA
Director/Principal Archaeologist
BFSA Environmental Services
Attachments:
Attachment A — Archaeological Records Search Results
Attachment B — NAHC Sacred Lands File Search Results
Archaeological Resources Records Search Results for the Enderle Center Project
ATTACHMENT A
Archaeological Records Search Results
BFSA Environmental Services, a Perennial Company
CALIFORNIA HISTORICAL RESOURCES INFORMATION SYSTEMS
RECORDS SEARCH
Company: BFSA Environmental Services, a Perennial Company
Processed By:
Date Processed:
Project Identification:
Information Center:
Search Radius:
Historical Resources:
Emily T. Soong
August 24, 2023
Enderle Center
South Central Coastal Information Center
500 Feet Buffer
Trinomial and Primary site maps have been reviewed. All sites within the project
boundaries and the specified radius of the project area have been plotted. Copies of the
site record forms have been reviewed for all recorded sites.
There are no resources located within a 500 feet radius of the current project area or
within the subject property.
Previous Survey Report Boundaries:
Project boundary maps have been reviewed. National Archaeological Database (NADB)
citations for reports within the project boundaries and within the specified radius of the
project area have been reviewed.
There are two reports within a 500 feet radius of the current project area, none of which
are located within the subject property.
N RE-�aURCES 1N( -t---tfCH /Wboc N Rce 0Urcc
500 Ft Buffer Enderle Center Project 1:24,000
QProject USGS Orange Quadrangle
(7.5-minute series) ETS BFSAES: 8/18/2023
N Ise
500 Ft Buffer Enderle Center Project n f24�yo 00
QProject USGS Orange Quadrangle ,V
(7.5-minute series) ETS BFSAES: 8/18/2023
Report List
Ender le Center
Report No. Other IDs
Year Author(s) Title
Affiliation Resources
OR-00946 Paleo - 1989 Padon, Beth Archaeological and Paleontological Review LSA Associates, Inc.
for 13911, 13931, and 13951 Carroll Way,
Tustin. Ca.
OR-02375 Cellular - 2001 McKenna, Jeanette A. Review of Culutral Resource McKenna et al.
Assess ment/evaluation for Cingular Wireless
Site Sc-001-01, Orange County, California
Page 1 of 1 SCCIC 8/22/2023 1:15:21 PM
Archaeological Resources Records Search Results for the Enderle Center Project
ATTACHMENT B
NAHC Sacred Lands File Search Results
BFSA Environmental Services
A Perennial Company
August 18, 2023
For: Native American Heritage Commission
915 Capitol Mall, Room 364
Sacramento, California 95814
From: Emily T. Soong
BFSA Environmental Services, a Perennial Company
14010 Poway Rd. Suite A
Poway, CA 92064
Archaeology/History/Paleontology/Biology
Re: Request for Sacred Lands File and Native American Contact List for the Enderle Center
Project, Tustin, Orange County, California.
I would like to request a record search of the Sacred Lands File and a list of appropriate Native
American contacts for the following project: Enderle Center Project (Project No. 23-222). The
project is an archaeological study located southeast of the intersection of Yorba Street and 17th
Street (APNs 401-252-05, -06, -08, -09, -10, 401-253-03, -04), Tustin, Orange County, California.
Specifically, the project is in an unsectioned portion of Township 5 South, Range 9 West as seen
on the USGS Orange, California topographic quadrangle. Please find the enclosed map on which
the project is delineated.
Thank you for your time.
Sincerely,
Emily T. Soong
Graphics/GIS
Billing: 14010 Poway Road, Suite A, Poway, CA 92064
Phone: 858-484-0915
Email: esoong@bfsa.perennialenv.com
Attachments:
USGS 7.5 Orange, California, topographic maps with project area delineated.
Sacred Lands File request form
14010 Poway Road, Suite A, Poway, California 92064; Phone 858-484-0915
Sacred Lands File & Native American Contacts List Request
NATIVE AMERICAN HERITAGE COMMISSION
915 Capitol Mall, RM 364 * Sacramento, CA 95814 * (916) 653-4082
(916) 657-5390 — Fax * nahc@pacbell.net
Information Below is Required for a Sacred Lands File Search
Project: Enderle Center Project (Project No. 23-222)
County: Orange
USGS Quadrangle Name(s): Orange
Township 5 South, Range 9 West
Company/Firm/Agency: BFSA Environmental Services, a Perennial
Company
Contact Person: Emily T. Soong
Street Address: 14010 Poway Road, Suite A
City: Poway Zip: 92064
Phone: 858-484-0915
Fax: 858-679-9896
Email: esoongkbfsa.perennialenv.com
Project Description:
I would like to request a record search of the Sacred Lands File and a list of
appropriate Native American contacts for the following project: Enderle Center
Project (Project No. 23-222). The project is an archaeological study located southeast
of the intersection of Yorba Street and 17th Street (APNs 401-252-05, -06, -08, -09, -
10, 401-253-03, -04), Tustin, Orange County, California. Specifically, the project is in
an unsectioned portion of Township 5 South, Range 9 West as seen on the USGS
Orange, California topographic quadrangle. Please find the enclosed map on which
the project is delineated.
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(7.5-minute series)
N
A
1:24,000
ETS BFSAES: 8/18/2023
From: NAHC(cbNAHC
To: Emily Soona
Cc: Green, AndrewCla NAHC
Subject: RE: Request for Sacred Land Search for The Market Place Project (23-223)
Date: Saturday, August 19, 2023 9:16:27 AM
Attachments: imaae001.Dna
The Market Place Project Sacred Lands File form.pdf
The Market Place Proiect NAHC Search Reauest.Ddf
The Market Place Map.Ddf
This sender is trusted.
Hello,
Thank you for your message. We're in receipt of your request. We have recently hired new staff, and
this change in our office is creating some delays. We estimate a turn -around time of 4 weeks and
don't anticipate responding sooner than the end of that time frame. Please let us know if you have
any questions.
Kind regards,
Native American Heritage Commission
1550 Harbor Blvd, Suite 100
West Sacramento, CA 95691
(916) 373-3710
From: Emily Soong <esoong@bfsa.perennialenv.com>
Sent: Friday, August 18, 2023 10:48 AM
To: NAHC@NAHC <NAHC@nahc.ca.gov>
Cc: Jenni Stropes <jstropes@bfsa.perennialenv.com>
Subject: Request for Sacred Land Search for The Market Place Project (23-223)
To whom it may concern,
I would like to request a record search of the Sacred Lands File and a list of appropriate Native
American contacts for the following project: The Market Place Project (Project No. 23-223). The
project is an archaeological study located north of the intersection of Jamboree Road and Santa Ana
Freeway (APNs 500-291-02, -04, -06, -07, -08, -11, -21, -23, -24, -25, -26, -27, 500-312-01, -02, -04,
-06, -08, -09), Tustin, Orange County, California. Specifically, the project is in former Lomas De
Santiago and San Joaquin Ranchos, Township 1 South, Range 6 West as seen on the USGS Tustin,
California topographic quadrangle. Please find the enclosed map on which the project is delineated.
Best regards,
Emily T. Soong
BFSA Environmental Services
0333 )
BN':i.4 l:v�•inunnent:�l `J'CtVIL:C�
Phone: 858-484-0915
Email: esoong@bfsa.perennialenv.com
14010 Poway Road, Suite A
Poway, CA 92064
www.bfsa-ca.com
CHAIRPERSON
Reginald Pagaling
Chumash
VICE -CHAIRPERSON
Buffy McQuillen
Yokayo Pomo, Yuki,
Nomlaki
NATIVE AMERICAN HERITAGE COMMISSION
October 3, 2023
Emily T. Soong
BFSA Environmental Services
Via Email to: esoong@bfsa.perennialenv.com
Re: Enderle Center Project, Orange County
Dear Ms. Soong:
A record search of the Native American Heritage Commission (NAHC) Sacred Lands File (SLF)
SECRETARY
was completed for the information you have submitted for the above referenced project. The
Sara Dutschke
Miwok
results were negative. However, the absence of specific site information in the SLF does not
indicate the absence of cultural resources in any project area. Other sources of cultural
resources should also be contacted for information regarding known and recorded sites.
PARLIAMENTARIAN
Wayne Nelson
Attached is a list of Native American tribes who may also have knowledge of cultural resources
Luiseno
in the project area. This list should provide a starting place in locating areas of potential
adverse impact within the proposed project area. I suggest you contact all of those indicated;
COMMISSIONER
if they cannot supply information, they might recommend others with specific knowledge. By
Isaac Bojorquez
contacting all those listed, your organization will be better able to respond to claims of failure to
Ohlone-Costanoon
consult with the appropriate tribe. If a response has not been received within two weeks of
notification, the Commission requests that you follow-up with a telephone call or email to
COMMISSIONER
ensure that the project information has been received.
Stanley Rodriguez
Kumeyaay
If you receive notification of change of addresses and phone numbers from tribes, please notify
me. With your assistance, we can assure that our lists contain current information.
COMMISSIONER
Laurena Bolden
If you have any questions or need additional information, please contact me at my email
Serrano
address: Andrew.Green@nahc.ca.gov.
COMMISSIONER
Sincerely,
Reid Milanovich
Cahuilla
COMMISSIONER
Vacant
Andrew Green
Cultural Resources Analyst
EXECUTIVE SECRETARY
Raymond C.
Attachment
Hitchcock
Miwok, Nisenan
NAHC HEADQUARTERS
1550 Harbor Boulevard
Suite 100
West Sacramento,
California 95691
(916)373-3710
nahc@nahc.ca.aov
NAHC.ca.gov Page 1 Of 1
Native American Heritage Commission
Native American Contact List
Orange County
10/3/2023
Tribe Name
Fed (F)
Contact Person
Contact
Phone #
Fax #
Email Address
Cultural
Non-
Address
Affiliation
Fed (N)
Gabrieleno
N
Christina Swindall
P.O. Box 393
(844) 390-0787
admin@gabrielenoindians.org
Gabrieleno
Band of
Martinez, Secretary
Covina, CA, 91723
Mission Indians
- Kizh Nation
Gabrieleno
N
Andrew Salas,
P.O. Box 393
(844) 390-0787
admin@gabrielenoindians.org
Gabrieleno
Band of
Chairperson
Covina, CA, 91723
Mission Indians
- Kizh Nation
Gabrieleno/Ton
N
Anthony Morales,
P.O. Box 693
(626) 483-3564
(626) 286-1262
GTTribalcouncil@aol.com
Gabrieleno
gva San
Chairperson
San Gabriel, CA,
Gabriel Band of
91778
Mission Indians
Gabrielino
N
Sandonne Goad,
106 1/2 Judge John
(951) 807-0479
sgoad@gabrielino-tongva.com
Gabrielino
/Tongva Nation
Chairperson
Aiso St., #231
Los Angeles, CA,
90012
Gabrielino
N
Robert Dorame,
P.O. Box 490
(562) 761-6417
(562) 761-6417
gtongva@gmail.com
Gabrielino
Tongva Indians
Chairperson
Bellflower, CA,
of California
90707
Tribal Council
Gabrielino
N
Christina Conley,
P.O. Box 941078
(626) 407-8761
christina.marsden@alumni.usc.ed
Gabrielino
Tongva Indians
Cultural Resource
Simi Valley, CA,
u
of California
Administrator
93094
Tribal Council
Page 1 of 3
Tribe Name
Fed (F)
Contact Person
Contact
Phone #
Fax #
Email Address
Cultural
Non-
Address
Affiliation
Fed (N)
Gabrielino-
N
Sam Dunlap,
P.O. Box 3919
(909) 262-9351
tongvatcr@gmail.com
Gabrielino
Tongva Tribe
Cultural Resource
Seal Beach, CA,
Director
90740
Gabrielino-
N
Charles Alvarez,
23454 Vanowen
(310) 403-6048
Chavez1956metro@gmail.com
Gabrielino
Tongva Tribe
Chairperson
Street
West Hills, CA,
91307
Juaneno Band
N
Joyce Perry,
4955 Paseo Segovia
(949) 293-8522
kaamalam@gmail.com
Juaneno
of Mission
Cultural Resource
Irvine, CA, 92603
Indians
Director
Acjachemen
Nation -
Belardes
Juaneno Band
N
Heidi Lucero,
31411-A La Matanza
(562) 879-2884
jbmian.chairwoman@gmail.com
Juaneno
of Mission
Chairperson, THPO
Street
Indians
San Juan
Acjachemen
Capistrano, CA,
Nation 84A
92675
Pala Band of
F
Alexis Wallick,
PMB 50, 35008 Pala
(760) 891-3537
awallick@palatribe.com
Cupeno
Mission Indians
Assistant THPO
Temecula Road
Luiseno
Pala, CA, 92059
Pala Band of
F
Shasta Gaughen,
PMB 50, 35008 Pala
(760) 891-3515
(760) 742-3189
sgaughen@palatribe.com
Cupeno
Mission Indians
Tribal Historic
Temecula Road
Luiseno
Preservation Officer
Pala, CA, 92059
Santa Rosa
F
Lovina Redner,
P.O. Box 391820
(951) 659-2700
(951) 659-2228
Isaul@santarosa-nsn.gov
Cahuilla
Band of
Tribal Chair
Anza, CA, 92539
Cahuilla
Indians
Page 2 of 3
Tribe Name
Fed (F)
Contact Person
Contact
Phone #
Fax #
Email Address
Cultural
Non-
Address
Affiliation
Fed (N)
Soboba Band
F
Jessica Valdez,
P.O. Box 487
(951) 663-6261
(951) 654-4198
jvaldez@soboba-nsn.gov
Cahuilla
of Luiseno
Cultural Resource
San Jacinto, CA,
Luiseno
Indians
Specialist
92581
Soboba Band
F
Joseph Ontiveros,
P.O. Box 487
(951) 663-5279
(951) 654-4198
jontiveros@soboba-nsn.gov
Cahuilla
of Luiseno
Tribal Historic
San Jacinto, CA,
Luiseno
Indians
Preservation Officer
92581
This list is current only as of the date of this document. Distribution of this list does not relieve any person of statutory responsibility as defined in Section
7050.5 of the Health and Safety Code, Section 5097.94 of the Public Resource Section 5097.98 of the Public Resources Code.
This list is only applicable for contacting local Native Americans with regard to cultural resources assessment for the proposed Enderle Center Project,
Orange County.
Page 3 of 3
EXHIBIT C
Enderle Center Rezone Project CEQA Findings of Fact
CEQA FINDINGS OF FACT
FOR THE
ENDERLE CENTER REZONE PROJECT
TUSTIN, CALIFORNIA
STATE CLEARINGHOUSE NO. 2024020747
Public Resources Code section 21002 states that "public agencies should not approve projects as proposed
if there are feasible alternatives or feasible mitigation measures available which would substantially lessen
the significant environmental effects of such projects[.]" Section 21002 further states that the procedures
required by CEQA "are intended to assist public agencies in systematically identifying both the significant
effects of proposed projects and the feasible alternatives or feasible mitigation measures which would avoid
or substantially lessen such significant effects."
Agencies demonstrate compliance with section 21002's mandate by adopting findings before approving
projects for which EIRs are required. (See Pub. Resources Code, § 21081, subd. (a); State CEQA Guidelines
§ 15091, subd. (a).) The approving agency must make written findings for each significant environmental
effect identified in an EIR for a proposed project and must reach at least one of three permissible conclusions.
• The first possible finding is that "[c]hanges or alterations have been required in, or incorporated into,
the project which avoid or substantially lessen the significant environmental effect as identified in the
final EIR." (State CEQA Guidelines § 15091, subd. (a)(1).)
• The second permissible finding is that "[s]uch changes or alterations are within the responsibility and
jurisdiction of another public agency and not the agency making the finding" and that "[s]uch changes
have been adopted by such other agency or can and should be adopted by such other agency." (State
CEQA Guidelines § 15091, subd. (a)(2).)
• The third potential conclusion is that "[s]pecific economic, legal, social, technological, or other
considerations, including provision of employment opportunities for highly trained workers, make
infeasible the mitigation measures or project alternatives identified in the final EIR." (State CEQA
Guidelines § 15091, subd. (a)(3).)
Agencies must not approve a project with significant environmental impacts if feasible alternatives or
mitigation measures would substantially lessen the significant impacts. Public Resources Code section 21061.1
defines "feasible" to mean "capable of being accomplished in a successful manner within a reasonable
period of time, taking into account economic, environmental, social and technological factors." State CEQA
Guidelines section 15364 adds "legal" considerations as another indicium of feasibility (See also Citizens of
Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 565). Project objectives also inform the
determination of "feasibility." (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417.)
Further, "`feasibility' under CEQA encompasses `desirability' to the extent that desirability is based on a
reasonable balancing of the relevant economic, environmental, social, and technological factors." (Id.; see
also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.AppAth 704, 715.) An agency need
not, however, adopt infeasible mitigation measures or alternatives (State CEQA Guidelines § 15091, subds.
(a), (b)). Further, environmental impacts that are less than significant do not require the imposition of
mitigation measures (Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347).
Notably, section 21002 requires an agency to "substantially lessen or avoid" significant adverse
environmental impacts. Thus, mitigation measures that "substantially lessen" significant environmental impacts,
even if not completely avoid them, satisfy section 21002's mandate. (Laurel Hills Homeowners Assn. v. City
Council (1978) 83 Cal.App.3d 515, 521 ("CEQA does not mandate the choice of the environmentally best
feasible project if through the imposition of feasible mitigation measures alone the appropriate public
agency has reduced environmental damage from a project to an acceptable level"); Las Virgenes
Homeowners Federation, Inc. v. County of Los Angeles (1986) 177 Cal.App.3d 300, 309 ("[t]here is no
requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance
... if such would render the project unfeasible").
City of Tustin
September 2024
Enderle Center Rezone Project CEQA Findings of Fact
CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to
substantially lessen or avoid significant environmental impacts that would otherwise occur. Project
modification or alternatives are not required, however, where such changes are infeasible or where the
responsibility for modifying the project lies with some other agency (State CEQA Guidelines § 15091, subds.
(a), (b)). The California Supreme Court has stated, "[t]he wisdom of approving ... any development project,
a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local
officials and their constituents who are responsible for such decisions. The law as we interpret and apply it
simply requires that those decisions be informed, and therefore balanced." (Citizens of Goleta Valley v. Board
of Supervisors, supra, 52 Cal.3d at p. 576).
The City of Tustin has determined that based on all the evidence presented, including, but not limited to, the
Final EIR, written and oral testimony given at meetings and hearings on the Project, and submission of
testimony from the public, organizations and regulatory agencies, the following environmental impacts
associated with the Project are either:
1) Less than significant and do not require mitigation;
2) Potentially significant and each of these impacts would be avoided or reduced to a level of insignificance
through the identified mitigation measures; or
3) Significant and cannot be fully mitigated to a level of less than significant but will be substantially
lessened to the extent feasible by the identified mitigation measures.
City of Tustin
September 2024
Enderle Center Rezone Project CEQA Findings of Fact
SECTION I
ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION
The Final EIR includes the Draft Environmental Impact Report (EIR) dated June 2024, written comments on the
Draft EIR that were received during the public review period, written responses to those comments, changes
to the Draft EIR, and the Mitigation Monitoring and Reporting Program (MMRP). In conformance with CEQA
and the State CEQA Guidelines, the City of Tustin conducted an extensive environmental review of the
Enderle Center Rezone Project that includes the following:
• Completion of an Initial Study (IS) by the City of Tustin, which concluded that an EIR should be prepared,
and the Notice of Preparation (NOP) released for a 30-day public review period from February 16,
2024, through March 20, 2024. Copies of the IS and the NOP were posted on the City's website at
www.tustinca.org/HousingElementRezone on February 16, 2024. The NOP was posted to the State
Clearinghouse's ceqanet.opr.ca.gov on February 20, 2024, and with the Orange County Clerk on
February 16, 2024, and reposted for an extended scoping period on February 23, 2024.
• Completion of a scoping process, in which agencies and the public were invited by the City of Tustin to
participate. The public scoping meeting for the EIR was held on March 6, 2024, at 5:00 p.m. at the Tustin
Area Senior Center located at 200 S. C Street, Tustin, CA. The notice of the public scoping meeting was
included in the NOP.
• Preparation of a Draft EIR by the City of Tustin was made available for a 45-day public review period
(June 7, 2024, through July 22, 2024). The Notice of Availability (NOA) for the Draft EIR was sent to
all persons, agencies and organizations on the interested persons list, published in the June 6, 2024,
issue of The Tustin News newspaper, posted on the City's website at
www.tustinca.org,/HousinciElementRezone, and filed with the Orange County Clerk on June 6, 2024.
• The NOA of the Draft EIR was posted to the State Clearinghouse's ceqanet.opr.ca.gov for public review
from June 7, 2024, through July 22, 2024. Copies of the Draft EIR were made available for public
review at the City of Tustin Community Development Department and download via the City's website
at: http://www.tustlnca.orci/HousingElementRezone.
• The Final EIR contains comments on the Draft EIR, responses to those comments, revisions to the Draft EIR
if any, the Mitigation Monitoring and Reporting Program, and appended documents. The Final EIR was
released 10-days prior to certification of the Final EIR.
• After considering the EIR and in conjunction with making these findings, the City of Tustin hereby finds
that pursuant to Section 15092 of the CEQA Guidelines that approval of the Project will result in
significant effects on the environment; however, the significant effects will be eliminated or substantially
lessened where feasible and has determined that remaining significant effects are found to be
acceptable under Section 15093.
• The Mitigation Monitoring and Reporting Program is hereby adopted to ensure implementation of
feasible mitigation measures identified in the EIR. The City of Tustin finds that these mitigation measures
are fully enforceable and shall be binding upon the City and affected parties.
• The City of Tustin finds that the Project is in the public interest and is necessary for the public health,
safety, and welfare.
• The City of Tustin hereby certifies the Final EIR in accordance with the requirements of CEQA.
• Pursuant to CEQA Guidelines Section 15095, staff is directed as follows: a) copy of the Final EIR and
CEQA Findings of Fact shall be retained in the Project files; b) copy of the Final EIR and CEQA Findings
of Fact shall be provided to all CEQA "responsible" agencies.
City of Tustin
September 2024
Enderle Center Rezone Project CEQA Findings of Fact
SECTION II
ENVIRONMENTAL IMPACTS NOT REQUIRING MITIGATION
The City prepared an Initial Study that determined that potentially significant environmental effects could
occur and that an EIR should be prepared for the Project. The scope of the EIR was determined based upon
the Initial Study which is included as Appendix A to the Draft EIR. Based upon the Initial Study, the City
determined that the Project would have no impact, or a less -than -significant impact related to the following
environmental topic areas and that no further analysis of these topics was required in the EIR:
• Aesthetics
• Agriculture & Forest Resources
• Biological Resources (except migratory
bird)
• Cultural Resources (except
archaeological resources)
• Geology and Soils (except
paleontological resources)
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Mineral Resources
• Wildfire
Further, several additional environmental topics that were analyzed in the Draft EIR were determined to also
have no impact, or a less -than -significant impact.
Section 15091 of the State CEQA Guidelines does not require specific findings to address environmental
effects that an EIR identifies as having "no impact" or a "less than significant" where no mitigation is required.
These findings will nevertheless fully account for all such effects identified in the Initial Study and Draft EIR
in this Section ll. Thus, the City hereby finds that the following potential environmental impacts of the Project
would have no impact or would be less than significant and do not require the imposition of mitigation
measures:
A. Aesthetics
Impact AE-1 Finding: The Project would not have a substantial adverse effect on a scenic vista (Initial Study
at p. 25 and Draft EIR at p. 7-1). No impacts would occur.
Facts in Support of Findings: The Project site is currently developed as a commercial site and is surrounded
by other commercial developments. The view of Peters Canyon Ridgeline (the scenic vista) from the Project
site is obstructed by surrounding buildings and trees. The Project site is bordered by 17th Street to the north,
which offers limited public views of Peters Canyon Ridgeline to motorists, bicyclists, and pedestrians traveling
eastbound. Views to the east from CA-55 are completely obstructed by adjacent developments and the
raised embankment.
Future residential development would be constructed within the boundaries of the existing Enderle Center
site and would not impede any existing views of Peters Canyon Ridgeline from 17th Street. The provision
for residential development in an area formerly designated for nonresidential land uses would not further
diminish views of a scenic vista. Therefore, the Project would result in no impact.
Impact AE-2 Finding: The Project would not substantially damage scenic resources, including, but not limited
to, trees, rock outcroppings, and historic buildings within a State scenic highway (Initial Study at p. 26 and
Draft EIR at p. 7-1). No impact would occur.
Facts in Support of Findings: According to the California Department of Transportation (Caltrans) Scenic
Highway Map, the City of Tustin does not contain any scenic highways within or surrounding the City. The
nearest State scenic highway is Route 91 in the City of Orange, approximately 8.5 miles to the north.
According to the County of Orange General Plan, there are no designated scenic roadways or scenic vistas
City of Tustin 4
September 2024
Enderle Center Rezone Project CEQA Findings of Fact
in the Project vicinity. Therefore, the Project would have no impact on scenic resources within a State scenic
highway.
Impact AE-3 Finding: The Project is located in an urban area and would not conflict with applicable zoning
and other regulations governing scenic quality. (Initial Study at p. 26 and Draft EIR at p. 7-1). Impacts would
be less than significant.
Facts in Support of Findings: Development is not proposed as part of the Project; however, all future
residential development proposed within the Project site would be subject to the requirement and provisions
of the applicable Objective Design Standards (ODS). Commercial development within the Enderle Center
does not currently have a maximum height limit or required setback distances, and site design is evaluated
on a project -by -project basis due to the properties designation as Planned Community Commercial (PC
COM). Design requirements established through ODS for the site would be created to ensure compatibility
with the existing site development and surrounding land uses, such as compatible building height, cohesive
architectural style, and appropriate landscaping. The ODS would ensure high visual character and quality
of future residential development proposed within the Project site. All future development would be required
to comply with the City's ODS for the site. Therefore, the Project would not conflict with applicable zoning
and other regulations governing scenic quality and would have a less -than -significant impact on visual
character and quality.
Impact AE-4 Finding: The Project would not create a new source of substantial light or glare which would
adversely affect day or nighttime views in the area (Initial Study at p. 27 and Draft EIR at p. 7-2). Impacts
would be less than significant.
Facts in Support of Findings: Future development could add additional nighttime light sources, such as
landscape lighting, security lighting, and the lighting from additional cars. As previously discussed, all future
projects would be required to comply with the applicable ODS for the site. The ODS would include specific
setbacks, lighting standards, and building materials that would ensure the avoidance of potential lighting
impacts. Further, all future projects would be required to comply with the City's light and glare ordinance,
which would be verified through plan check prior to project approval. Therefore, the Project would result in
a less -than -significant impact.
Aesthetics Cumulative Finding: The Project would not have a cumulatively adverse impact related to
aesthetics. A less than significant impact would occur (Initial Study at p. 25 - 27 and Draft EIR at p. 7-1 and
7-2).
Facts in Support of Findings: Implementation of the proposed Project would result in future coordinated
development from implementation of the ODS and development standards that would be ensured through
the City's plan check and development permitting process. Therefore, cumulative impacts would be less than
significant.
The cumulative change in visual condition that would result from the proposed Project, in combination with
future nearby projects would not be considered adverse, because the proposed Project would implement
the City's design guidelines related to architecture, landscaping, signs, lighting, and other related items that
are intended to improve visual quality. Thus, the proposed Project would result in a less -than -significant
cumulatively considerable impact related to scenic quality.
B. Aaricultural & Forestry Resources
Impact AG-1 Finding: The Project would not convert Prime Farmland, Unique Farmland, or Farmland of
Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring
Program of the California Resources Agency, to non-agricultural use (Initial Study at p. 28 and Draft EIR at
p. 7-2). No impacts would occur.
City of Tustin 5
September 2024
Enderle Center Rezone Project CEQA Findings of Fact
Facts in Support of Findings: The California Department of Conservation Important Farmland mapping
identifies the Project site as Urban and Built -Up Land. No areas of Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance is located on or adjacent to the Project site. Therefore, the proposed
Project would not have impacts related to the conversion of Prime Farmland, Unique Farmland, or Farmland
of Statewide Importance to non-agricultural use.
Impact AG-2 Finding: The Project would not conflict with existing zoning for agricultural use, or a Williamson
Act contract (Initial Study at p. 29 and Draft EIR at p. 7-2). No impacts would occur.
Facts in Support of Findings: The Project site is currently developed with commercial land uses and does
not include agricultural land uses. The Project site is not currently under a Williamson Act contract. Therefore,
the Project would result in no impact on existing zoning for agricultural use or a Williamson Act contract.
Impact AG-3 Finding: The Project would not conflict with existing zoning for, or cause rezoning of, forest
land (as defined in Public Resources Code section 1 2220(g)), timberland (as defined by Public Resources
Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section
51 104(g)) (Initial Study at p. 29 and Draft EIR at p. 7-2). No impacts would occur.
Facts in Support of Findings: The Project site is currently completely developed with commercial land use.
The Project site does not include forest land or timberland. Additionally, the Project site is currently zoned
for Planned Community Commercial (PC COM), which does not provide for forest land or timberland
production and management. Therefore, the Project would result in no impact on zoning of forest land or
timberland.
Impact AG-4 Finding: The Project would not result in the loss of forest land or conversion of forest land to
non -forest use (Initial Study at p. 29 and Draft EIR at p. 7-2). No impacts would occur.
Facts in Support of Findings: The Project site is currently completely developed as commercial land use and
does not include forest land. Therefore, the Project would have no impact on forest land.
Impact AG-5 Finding: The Project would not involve other changes in the existing environment which, due to
their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest
land to non -forest use (Initial Study at p. 29 and Draft EIR at p. 7-2). No impacts would occur.
Facts in Support of Findings: The Project site is within an urbanized area and is currently completely
developed as commercial land use. The area surrounding the Project site is also completely developed. The
existing environment does not include any agricultural land uses or forest land.
Agricultural and Forestry Resources Cumulative Findings: The Project would not result in cumulatively
considerable impacts to agricultural or forestry resources (Initial Study at p. 28 - 29 and Draft EIR at p. 7-
2).
Facts in Support of Findings: The Project area does not contain agricultural or forest resources.
Implementation of the Project would develop an area where no farmland, agricultural land, or forest land
exists. Therefore, the Project would not result in any cumulative impacts to agricultural or forestry resources.
C. Air Quality
Impact AQ-1 Finding: The Project would not conflict with or obstruct implementation of an applicable air
quality plan (Draft EIR at p. 5.1 -21) at both the project and cumulative levels. Impacts would be less than
significant.
Facts in Support of Findings: According to the Southern California Association of Government's (SCAG)
2020-2045 Regional Transportation Plan / Sustainable Community Strategy (RTP/SCS), the City's
population, households, and employment are forecast to increase by approximately 10,500 residents, 4,100
City of Tustin 6
September 2024
Enderle Center Rezone Project CEQA Findings of Fact
households, and 21,600 jobs, respectively, between 2016 and 2045. As identified in Section 3.0, Project
Description, the City's 2021-2029 Housing Element identifies the Project site for development of housing to
accommodate the City's SCAG's Regional Housing Needs Allocation (RHNA) allocation. The proposed Project
would accommodate up to 413 housing units to help the City meet its RHNA allocation; and therefore, would
fit within the existing SCAG growth forecast and would not result in an exceedance of growth projections.
In addition, since the proposed Project would not include airports, electrical generating facilities, petroleum
and gas refineries, designation of oil drilling districts, water ports, solid waste disposal sites, and offshore
drilling facilities, the proposed Project is not a significant project as defined by the South Coast Air Quality
Management District (SCAQMD) CEQA Air Quality Handbook. Therefore, it is unlikely that the proposed
Project would interfere with SCAQMD's goals for improving air quality in the region. The proposed Project
would not conflict with the 2022 Air Quality Management Plan (AQMP) and, as such, would not jeopardize
attainment of the California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality
Standards (NAAQS) in the area under the jurisdiction of the SCAQMD.
Impact AO-2 Finding: The Project would not result in a cumulatively considerable net increase of any criteria
pollutant for which the project region is non -attainment under an applicable federal or State ambient air
quality standard (Draft EIR at p. 5.1-22) at both the project and cumulative levels. Impacts are less than
significant.
Facts in Support of Findings:
Construction: Construction emissions were estimated for development envisioned under the Project using
CaIEEMod. As shown in Draft EIR Table 5.1 -8, construction emissions associated with future development, as
envisioned under the Project would not exceed the SCAQMD thresholds for VOCs, NOx, CO, sulfur oxides
(SOX), PM2.5, or PMio emissions. Future development projects would be required to comply with SCAQMD
Rule 403: Fugitive Dust, which would further reduce construction -related emissions. Therefore, future
construction of development projects consistent with the Project would not result in emissions that would result
in significant impact related to net increase of any criteria pollutant for which the project region is in
nonattainment under an applicable federal or State ambient air quality standard Therefore, construction
impacts related to regional emissions criteria would be less than significant.
Operation: Operational activities associated with the additional housing units and remaining commercial
buildout capacity consistent with the buildout envisioned as part of the proposed Project would result in long-
term air pollutant emissions associated with mobile sources (e.g., vehicle trips), energy sources (e.g., natural
gas), and area sources (e.g., architectural coatings and the use of landscape maintenance equipment).
The modeling results shown in Draft EIR Table 5.1-10 indicate that the net new emissions associated with the
future development of the Project would not exceed the significance criteria for VOCs, NOx, CO, SOX, PM,o,
or PM2.5 emissions; thus, the Project would not have a significant impact on regional air quality
Impact AQ-4 Finding: The Project would not result in other emissions (such as those leading to odors)
adversely affecting a substantial number of people (Draft EIR at p. 5.1 -29). Impacts would be less than
significant.
Facts in Support of Findings: During construction of future development allowed under the Project, some
odors may be present due to diesel exhaust. However, these odors would be temporary and limited to the
construction period. The Project would allow for the development of future residential and commercial uses
and would not include any activities or operations that would generate objectionable odors and once
operational. Therefore, the proposed Project would not result in other emissions (such as those leading to
odors) affecting a substantial number of people.
D. Biological Resources
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Enderle Center Rezone Project CEQA Findings of Fact
Impact BIO-1 Finding: The Project would not have an adverse effect, either directly or through habitat
modifications, on any species identified as candidate, sensitive, or special status species in local or regional
plans, policies, or regulation, or by the California Department of Fish and Game or U.S. Fish and Wildlife
Service. (Initial Study at p. 31 and Draft EIR at p. 7-2). No impact would occur.
Facts in Support of Findings: The Project site consists of approximately 1 1.8 acres that are developed with
existing commercial uses, including restaurant, retail, and office establishments, a paved parking lot, and
landscaping. The Project site is surrounded by urban developed areas with structures, paved parking, and
ornamental landscaping. There is no evidence of either suitable habitat for or the presence of any
endangered, rare, threatened, or special status plant species (or associated habitats) or wildlife species
designated by the U.S. Fish and Wildlife Service (USFWS), California Department of Fish and Wildlife
(CDFW), or California Native Plant Society (CNPS). As the Project site is currently completely paved,
implementation of the Project would not result in an adverse effect, either directly or through habitat
modifications, on any sensitive species, and impacts would not occur.
Impact BIO-2 Finding: The Project would not have an adverse effect on any riparian habitat or other
sensitive natural community identified in local or regional plans, policies, or regulation, or by the California
Department of Fish and Game or U.S. Fish and Wildlife Service. (Initial Study at p. 32 and Draft EIR at p.
7-3). No impact would occur.
Facts in Support of Findings: The area proposed for the provision of future residential development is
completely paved with a parking lot. There is no existing riparian habitat or sensitive natural community
within the developable area of the site. Therefore, the Project would result in no impact.
Impact BIO-3 Finding: The Project would not have substantial adverse effect on State or federally protected
wetlands (including but not limited to, marsh, vernal, pool, coastal, etc.) through direct removal, filling,
hydrological interruption, or other means. (Initial Study at p. 32 and Draft EIR at p. 7-3). No impact would
occur.
Facts in Support of Findings: The area proposed for the provision of future residential development is
completely paved with a parking lot. There are no wetlands or riparian areas within the developable area
of the site. Therefore, the Project would result in no impact.
Impact BIO-5 Finding: The Project would not conflict with any local policies or ordinances protecting
biological resources, such as a tree preservation policy or ordinance (Initial Study at p. 32 and Draft EIR at
p. 7-3). No impact would occur.
Facts in Support of Findings: The Project site is urban and developed and contains no biological resources
to be preserved under the resource protection policies of the City's General Plan. Article 7, Chapter 3 of
the Municipal Code addresses the protection of "trees, plants or shrubs in or growing upon or over any public
parkway street, highway, alley, right-of-way, City -owned property in the City." The Project would not impact
any such trees and shrubs. To the extent that future development facilitated by the Project is required to
plant new trees on public property pursuant to Section 7308 of Article 7, Chapter 3, the Project would be
required to comply with the Municipal Code requirements as part of the City permitting process and impacts
would be less than significant.
Impact BIO-6 Finding: The Project would not conflict with the provisions of an adopted Habitat Conservation
Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation
plan (Initial Study at p. 33 and Draft EIR at p. 7-3). No impacts would occur.
Facts in Support of Findings: The Project site is developed and in an urban area. The Project site does not
contain any natural lands that are subject to an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or State habitat conservation plan. Therefore, the
Project would not result in impacts to biological habitat or conservation plans.
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E. Cultural Resources
Impact CUL-1 Finding: The Project would not cause a substantial adverse change in the significance of a
historical resource pursuant to CEQA Guidelines Section 15064.5. (Initial Study at p. 34 and Draft EIR at p.
7-4). No impact would occur.
Facts in Support of Findings: According to results of the cultural record search prepared for the Project, the
Project site does not contain any historic resources. Additionally, the area proposed for future implementation
of residential land uses pursuant to the Housing Element is the existing parking lot, which does not contain
any structures that could become historic in the future. Therefore, the Project would not result in impacts to a
historical resource.
Impact CUL-3 Finding: The Project would not disturb any human remains, including those interred outside of
formal cemeteries (Initial Study at p. 35 and Draft EIR at p. 7-5). Impacts are less than significant.
Facts in Support of Findings: The Project site has been previously disturbed, as described above, and has
not been previously used as a cemetery. Thus, human remains are not anticipated to be uncovered during
project construction. In addition, California Health and Safety Code Section 7050.5, CEQA Section 15064.5,
and Public Resources Code Section 5097.98 (included as PPP CUL-1) mandate the process to be followed
in the event of an accidental discovery of any human remains. Specifically, California Health and Safety
Code Section 7050.5 requires that if human remains are discovered, disturbance of the site shall remain
halted until the coroner has conducted an investigation into the circumstances, manner, and cause of death,
and made recommendations concerning the treatment and disposition of the human remains to the person
responsible for the excavation, or to his or her authorized representative, in the manner provided in Section
5097.98 of the Public Resources Code. If the coroner determines that the remains are not subject to his or
her authority and if the coroner has reason to believe the human remains to be those of a Native American,
he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Compliance
with existing law would ensure that significant impacts to human remains would not occur through the
implementation of future construction facilitated by the Project.
F. Energy
Impact E-1 Finding: The Project would not result in potentially significant environmental impact due to
wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation
(Draft EIR at p. 5.2-5). Impacts are less than significant.
Facts in Support of Findings:
Construction: As indicated in Draft EIR Table 5.2-1, development envisioned under the Project would consume
approximately 117,690 gallons of diesel fuel and approximately 148,345 gallons of gasoline during
construction. Based on fuel consumption obtained from EMFAC2021, approximately 1.2 billion gallons of
gasoline and approximately 157.1 million gallons of diesel will be consumed from vehicle trips in Orange
County in 2024. Therefore, construction of future development as envisioned under the proposed project
would increase the annual construction generated fuel use in Orange County approximately by
approximately 0.07 percent for diesel fuel usage and by approximately 0.01 percent for gasoline fuel
usage. As such, project construction would have a negligible effect on local and regional energy supplies.
Furthermore, impacts related to energy use during construction would be temporary and relatively small in
comparison to Orange County's overall use of the State's available energy resources. No unusual project
characteristics would necessitate the use of construction equipment that would be less energy efficient than
at comparable construction sites in the region or the State. In addition, construction activities are not
anticipated to result in an inefficient use of energy as gasoline and diesel fuel would be supplied by
construction contractors who would conserve the use of their supplies to minimize their costs on the Project.
The Project would not cause or result in the need for additional energy facilities or an additional or
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Enderle Center Rezone Project CEQA Findings of Fact
expanded delivery system. For these reasons, fuel consumption during construction would not be inefficient,
wasteful, or unnecessary.
Operation: As shown in Draft EIR Table 5.2-2, the estimated potential increase in electricity demand
associated with development consistent with the proposed Project is 3,579,805 kilowatt-hours (kWh) per
year. Total electricity consumption in Orange County in 2022 was 20,244 Gigawatt hours (GWh)
(20,243,721,856 kWh). Therefore, operation of the proposed Project would increase the annual electricity
consumption in Orange County by approximately 0.02 percent.
Additionally, as shown in Draft EIR Table 5.2-2, the estimated potential increase in natural gas demand
associated with development consistent with the proposed Project is 100,495 therms per year. Total natural
gas consumption in Orange County in 2022 was 573 million therms (572,454,744 therms). Therefore,
operation of the proposed Project would increase the annual natural gas consumption in Orange County by
approximately 0.02 percent.
Electrical and natural gas demand associated with future operations would not be considered inefficient,
wasteful, or unnecessary in comparison to other similar developments in the region and would not conflict
with or obstruct a State or local plan for renewable energy or energy efficiency. All future development
would be required to adhere to all federal, State, and local requirements for energy efficiency, including
the latest Title 24 standards. Title 24 building energy efficiency standards establish minimum efficiency
standards related to various building features, including appliances, water and space heating and cooling
equipment, building insulation and roofing, and lighting, which would reduce energy usage.
Construction of the Al additional housing units and remaining commercial buildout capacity would also
result in energy usage associated with gasoline and diesel fuel consumed by project -related vehicle trips.
As shown in Draft EIR Table 5.2-2, the increase in fuel use associated with the vehicle trips generated by the
proposed Project is estimated at approximately 1,1 14,487 gallons of gasoline and 94,255 gallons of diesel
fuel per year. Based on fuel consumption obtained from EMFAC2021, approximately 1.2 billion gallons of
gasoline and approximately 157.1 million gallons of diesel will be consumed from vehicle trips in Orange
County in 2024. Therefore, vehicle trips associated with the proposed Project would increase the annual fuel
use in Orange County by approximately 0.09 percent for gasoline fuel usage and approximately 0.06
percent for diesel fuel usage. Fuel consumption associated with vehicle trips generated by project operations
would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in
the region.
Impact E-2 Finding: The Project would not conflict with or obstruct a State or local plan for renewable
energy or energy efficiency (Draft EIR at p. 5.2-9). Impacts are less than significant.
Facts in Support of Findings: As detailed previously, energy usage on the project site during construction
would be temporary in nature and would be relatively small in comparison to the overall use in the County.
In addition, energy usage associated with operation of the proposed Project would be relatively small in
comparison to the overall use in Orange County, and the State's available energy resources. Therefore,
energy impacts at the regional level would be negligible. Because California's energy conservation planning
actions are conducted at a regional level, and because the proposed project's total impact on regional
energy supplies would be minor, the proposed Project would not conflict with or obstruct California's energy
conservation plans as described in the California Energy Commission's (CEC) Integrated Energy Policy Report.
Additionally, as demonstrated above, the proposed Project would not result in the inefficient, wasteful, and
unnecessary consumption of energy. Thus, impacts would be less than significant.
Energy Cumulative Findings: The Project would not result in cumulative energy consumption which would be
cumulatively wasteful, inefficient, or unnecessary (Draft EIR at p. 5.2-9). Impacts are less than significant.
Facts in Support of Findings: The geographic context for analysis of cumulative impacts regarding energy
includes past, present, and future development within southern California because energy supplies (including
electricity, natural gas, and petroleum) are generated and distributed throughout the southern California
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Enderle Center Rezone Project CEQA Findings of Fact
region. All development projects throughout the region would be required to comply with the energy
efficiency standards in the Title 24 requirements. Additionally, some of the developments could provide for
additional reductions in energy consumption by use of solar panels, sky lights, or other LEED-type energy
efficiency infrastructure. With implementation of the existing energy conservation regulations, cumulative
electricity and natural gas consumption would not be cumulatively wasteful, inefficient, or unnecessary.
Transportation energy use and gasoline demand would also increase; however, this transportation energy
use would not represent a major amount of energy use when compared to the amount of existing
development or to the total number of vehicle trips and vehicle miles traveled throughout Orange County
and the region. For these reasons, the consumption of petroleum would not occur in a wasteful, inefficient, or
unnecessary manner and would be less than cumulatively considerable.
G. Geology and Soils
Impact GE0-1 i Finding: The Project would not directly or indirectly cause potential substantial adverse
effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated
on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area
or based on other substantial evidence of a known fault (Initial Study at p. 38 and Draft EIR at p. 7-6). No
impacts would occur.
Facts in Support of Findings: According to the California Geological Survey available fault maps, the
Project is approximately 10 miles to the south of the nearest Alquist-Priolo (A-P) fault, Whitter Fault (Parrish,
Earthquake Zones of Required Investigation, Yorba Linda Quadrangle, 2015). The Project is also
approximately 11 miles to the north of the North Branch Fault (Parrish, Earthquake Zones of Required
Investigation, Seal Beach Quadrangle, 1999). Due to the location of these faults, the general region is subject
to the potential for earthquakes; however, the Project site is outside of a 500-foot radius from an active
fault and is not subject to a special development permit. The Project site contains existing development, and
the provision for additional development would not exacerbate existing risk of earthquake. Further, all
future development permitted would be required to comply with the requirement of the California Building
Code (CBC) (California Code of Regulations, Title 24, Part 2), which is a minimum requirement intended to
protect life safety and prevent collapse of structures. Therefore, the Project would not result in impacts
related to faults.
Impact GE0-1 ii Finding: The Project would not directly or indirectly cause potential substantial adverse
effects, including the risk of loss, injury, or death involving strong seismic ground shaking (Initial Study at p.
39 and Draft EIR at p. 7-6). Impacts are less than significant.
Facts in Support of Findings: Due to the location of regional faults moderate to strong ground shaking can
be expected at the Project site. Structures built in the City are required to be built in compliance with the
CBC (California Code of Regulations, Title 24, Part 2) that provides provisions for earthquake safety based
on factors including building occupancy type, the types of soils onsite, and the probable strength of ground
motion. Compliance with the CBC would require the incorporation of 1) seismic safety features to minimize
the potential for significant effects as a result of earthquakes; 2) proper building footings and foundations;
and 3) construction of the building structure so that it would withstand the effects of strong ground shaking.
Implementation of CBC standards would be verified by the City during the plan check and permitting process
(PPP GEO-1). Because the proposed Project would be constructed in compliance with the CBC, the proposed
Project would result in a less -than -significant impact related to strong seismic ground shaking.
Impact GEO-1 iv Finding: The Project would not directly or indirectly cause potential substantial adverse
effects, including the risk of loss, injury, or death involving landslides (Initial Study at p. 40 and Draft EIR at
p. 7-6). No Impacts would occur.
Facts in Support of Findings: The Project site is currently fully developed with commercial and office uses.
The Project site is flat and is not adjacent to or within the vicinity of steep slopes or other landforms susceptible
to landslides. The Project would include a General Plan Amendment (GPA), Code Amendment (CA) and
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Enderle Center Rezone Project CEQA Findings of Fact
rezone of the Project site with a Housing Overlay (HO) district to allow for future development of up to 413
housing units, consistent with the City's certified 2021 -2029 Housing Element. The provision of future
residential development would not result in new risk of loss, injury, or death involving a landslide. Therefore,
the Project would result in no impact.
Impact GEO-2 Finding: The Project would not result in soil erosion or the loss of topsoil (Initial Study at p.
40 and Draft EIR at p. 7-7). Impacts are less than significant.
Facts in Support of Findings: All future construction would be required to comply with the California
Regional Water Quality Control Board (RWQCB) Order No. R8-2010-0033, National Pollutant Discharge
Elimination System (NPDES) Permit No. CAS618033 — Construction General Permit requirements (PPP HYD-
1) Requirements include installation of Best Management Practices (BMPs), which establishes minimum
stormwater management requirements and controls. To reduce the potential for soil erosion and the loss of
topsoil, a Stormwater Pollution Prevention Plan (SWPPP) is required by the RWQCB regulations to be
developed by a QSD (Qualified SWPPP Developer). The SWPPP is required to address site -specific
conditions related to specific grading and construction activities. The SWPPP would identify potential sources
of erosion and sedimentation to prevent loss of topsoil during construction, and to identify erosion control
BMPs to reduce or eliminate the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel
bags; stabilized construction entrances/exits; hydroseeding, and similar measures. In addition to RWQCB
requirements, proposed development would need to comply with the City of Tustin Grading Manual
procedures. The City of Tustin Grading Manual is a compilation of rules, procedures, and interpretations
necessary to carry out the provisions of the Tustin City Code relating to grading and excavation.
Following construction, future development would be required to prepare and implement a Water Quality
Management Plan (WQMP) per City standards. Future projects would be required to comply with the
requirements of the Orange County Drainage Area Management Plan (DAMP) and the intent of the non -
point source NPDES Permit for Waste Discharge Requirements for the County of Orange, Orange County
Flood Control District and the incorporated cities of Orange County within the Santa Ana Region. The DAMP
requires that new development and significant redevelopment projects develop and implement a WQMP
that includes BMPs and low impact development (LID) design features that would provide onsite treatment
of stormwater to prevent pollutants from onsite uses from leaving the site. These requirements would ensure
that future projects would not result in substantial soil erosion or the loss of topsoil. With implementation of
uniformly applicable requirements, the Project would result in a less -than -significant impact.
Impact GEO-5 Finding: The Project would not have soils incapable of adequately supporting the use of
septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater (Initial Study at p. 42 and Draft EIR at p. 7-8). No impact would occur.
Facts in Support of Findings: All future development would be served by the City sewer utilities and would
not include the use of septic tanks or alternative wastewater disposal systems. Therefore, the Project would
result in no impact.
Impact GEO-6 Finding: The Project would not directly or indirectly destroy a unique paleontological resource
or site or unique geologic feature. (Initial Study at p. 42 and Draft EIR at p. 7-8). Impacts are less than
significant.
Facts in Support of Finding: The Project could facilitate future construction at depths greater than previous
excavation activities, which could result in the disturbance of undisturbed native soils. The City's
Conservation/Open Space/Recreation Element of the General Plan Figure COSR-2 identifies areas sensitive
to paleontological resources. The Project site is not located in an area identified by the General Plan as
"High Paleontological Sensitivity." The City has detailed standards and requirements for grading that are
designed to protect sensitive topographic, soil, palaeontologic, and archaeologic resources. The Tustin
Grading Manual prescribes appropriate measures to protect the earth by controlling erosion, sedimentation,
and storm drainage. Proper grading, soil management, and open space standards will work to preserve
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Enderle Center Rezone Project CEQA Findings of Fact
any potential paleontological resources in the unlikely event that a resource is encountered. Therefore, the
Project would result in a less -than -significant impact on a paleontological resource, site, or geologic feature.
Geology and Soils Cumulative Finding: The Project would not result in cumulatively considerable impacts
to geology and soils (Initial Study at p. 38 - 43 and Draft EIR at p. 7-6 through 7-7).
Facts in Support of Findings: Geotechnical impacts are site -specific rather than cumulative in nature. Direct
and indirect impacts related to geology and soils would be mitigated through mandatory conformance with
the CBC, Tustin Municipal Code, and site -specific geotechnical recommendations, which will be incorporated
as part of future projects' design and construction efforts. With the exception of erosion hazards, potential
hazardous effects related to geologic and soil conditions are unique to each project site, and inherently
restricted to the developments proposed. That is, issues including fault rupture, seismic ground shaking,
liquefaction, landslides, and expansive soils would involve effects to (and not from) the development, are
specific to conditions on the property, and are not influenced by or additive with the geologic and/or soils
hazards that may occur on other, off -site properties. Because of the site -specific nature of these potential
hazards and the measures to address them, there would be no direct or indirect connection to similar potential
issues or cumulative effects from the proposed industrial development project.
H. Hazards and Hazardous Materials
Impact HAZ-1 Finding: The Project would not create a significant hazard to the public or the environment
through the routine transport, use, or disposal of hazardous materials (Initial Study at pp. 45 and Draft EIR
at p. 7-9). Impacts are less than significant.
Facts in Support of Findings:
Construction: Future construction activities could involve the transport, use, and disposal of hazardous
materials such as paints, solvents, oils, grease, and caulking. In addition, hazardous materials could be
needed for fueling and servicing construction equipment on the site. These types of materials are not acutely
hazardous, and all storage, handling, use, and disposal of these materials are regulated by federal and
State requirements that are implemented by the City during building permitting for construction activities.
These regulations include: the federal Occupational Safety and Health Act and Hazardous Materials
Transportation Act; Title 8 of the California Code of Regulations (CalOSHA), and the State Unified
Hazardous Waste and Hazardous Materials Management Regulatory Program. As a result, routine transport
and use of hazardous materials during construction would be consistent with applicable regulations and
would be less than significant.
Operation: The Project involves the provision for future development of up to 413 housing units, which involve
routinely using household hazardous materials including solvents, cleaning agents, paints, pesticides,
batteries, fertilizers, and aerosol cans. These types of materials are not acutely hazardous and would only
be used and stored in limited quantities. The normal routine use of these products pursuant to existing
regulations would not result in a significant hazard to people or the environment in the vicinity of the Project.
Additionally, the Project would create a mixed -use environment in which residential land uses would be
introduced into existing commercial land use (the Enderle Center). Existing commercial uses include a mix of
office, restaurant, and retail establishments. Existing commercial uses require the routine use of similar
hazardous materials as residential land uses (solvents, cleaning agents, paints, pesticides, batteries,
fertilizers, and aerosol cans) and would not impose additional hazards to potential future residential uses.
Therefore, operation of the Project would not result in a significant hazard to the public or to the environment
through the routine transport, use, or disposal of hazardous waste, and impacts would be less than significant.
Impact HAZ-2 Finding: The Project would not create a significant hazard to the public or the environment
through reasonably foreseeable upset and accident conditions involving the release of hazardous materials
into the environment. (Initial Study at p. 46 and Draft EIR at p. 7-10). Impacts are less than significant.
Facts in Support of Findings:
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Enderle Center Rezone Project CEQA Findings of Fact
Construction: While the routine use, storage, transport, and disposal of hazardous materials in accordance
with applicable regulations during potential future construction activities would not pose health risks or result
in significant impacts; improper use, storage, transportation and disposal of hazardous materials and wastes
could result in accidental spills or releases, posing health risks to workers, the public, and the environment.
To avoid an impact related to an accidental release, the use of BMPs during construction are implemented
as part of a SWPPP as required by the NPDES General Construction Permit. Implementation of an SWPPP
would minimize potential adverse effects to workers, the public, and the environment. Construction contract
specifications would include strict on -site handling rules and BMPs that would reduce potential impacts to a
less than significant level.
Operation: All future development would be required to develop and implement a WQMP as required
through NPDES. Therefore, construction of future development would result in a less -than -significant impact.
Impact HAZ-3 Finding: The Project would not emit hazardous emissions or handle hazardous materials,
substances, or waste within one -quarter mile of an existing or proposed school (Initial Study at p. 47 and
Draft EIR at p. 7-10). Impacts are less than significant.
Facts in Support of Findings: The nearest school, Loma Vista Elementary School, is located approximately
2,100 feet to the east of the Project site. However, as described previously, construction and operation of
the Project could involve the use, storage, and disposal of small amounts of hazardous materials on the
Project site. These hazardous materials would be limited and used and disposed of in compliance with
federal, State, and local regulations, which would reduce the potential for accidental release into the
environment near a school. Therefore, the Project would not emit hazardous or handle acutely hazardous
materials, substances, or waste near a school, and impacts would be less than significant.
Impact HAZ-4 Finding: The Project would not be located on a site which is included on a list of hazardous
materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a
significant hazard to the public or the environment. (Initial Study at p. 47 and Draft EIR at p. 7-10). No
impacts would occur.
Facts in Support of Findings: The Project site is not located on a list of hazardous materials sites compiled
pursuant to Government Code Section 65962.5 (Department of Toxic Substances Control, 2023). Therefore,
the Project would result in no impact.
Impact HAZ-5 Finding: The Project would not result in a safety hazard or excessive noise for people residing
or working in the project area (Initial Study at p. 47 and Draft EIR at p. 7-10). No impact would occur.
Facts in Support of Findings: The Project site is approximately 5.5 miles to the north of John Wayne Airport,
which is the nearest airport to the Project site. The Project site is not located within any land use compatibility
zone for John Wayne Airport, nor is it within an airport safety zone within the Airport Environs Land Use Plan
(AELUP). The Project's proximity to the airport would not result in potential safety hazards or excessive noise
for people that would reside or work within the Project site in the future. Therefore, the Project would result
in no impact.
Impact HAZ-6 Finding: The Project would not impair implementation of an adopted emergency response
plan or emergency evacuation plan (Initial Study at p. 48 and Draft EIR at p. 7-10). Impacts are less than
significant.
Facts in Support of Findings: The Project site is located at the southeast of the corner of 17th Street and 55
Freeway (State Route 55), a major arterial and highway, respectively. These adjacent roadways would
likely be utilized as evacuation routes in the event of an emergency evacuation of the Project site. Pursuant
to the City's Emergency Operations Plan, specific evacuation requirements will vary with each situation, but
should be carried out in a manner consistent with other critical functions. Under ideal circumstances there will
be enough time for radio and/or television stations to broadcast the required evacuation information via
the Emergency Alert System, and if enough time is available, copies of the evacuation order or notice and
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Enderle Center Rezone Project CEQA Findings of Fact
route. The Project site is not designated as an emergency evacuation route. The Project would not impair the
implementation of evacuation protocol in the event of an emergency within the City or Project site.
Additionally, each future residential project implemented as part of the housing overlay and Housing Element
would require a project -level plan check with the City and would be reviewed by the Orange County Fire
Authority to ensure proper emergency access to and from the site. Therefore, the Project would result in a
less -than -significant impact.
Impact HAZ-7 Finding: The Project would not expose people or structures, either directly or indirectly, to a
significant risk of loss, injury or death involving wildland fires (Initial Study at p. A8 and Draft EIR at p. 7-
1 1). No Impact would occur.
Facts in Support of Findings: The Project site is currently developed as a commercial site and is surrounded
by other commercial developments. According to the CalFire Fire Hazard Severity Zone Map, the City of
Tustin contains very high fire severity zones in the northeast portion of the City. The Project site is not located
within or near State responsibility areas or lands classified as very high fire hazard severity zones. Therefore,
the Project would result in no impact regarding the exposure of people or structures to risk of loss, injury, or
death involving a wildland fire.
Hazards and Hazardous Materials Cumulative Findings: The Project would not result in cumulative impacts
related to hazards or hazardous materials (Initial Study at p. 72 and Draft EIR at p. 7-9 through 7-1 1).
Facts in Support of Findings: Cumulative land use changes within the city would have the potential to expose
future area residents, employees, and visitors to chemical hazards through redevelopment of sites and
structures that may be contaminated from either historic or ongoing uses. The severity of potential hazards
for individual projects would depend upon the location, type, and size of development and the specific
hazards associated with individual sites. All hazardous material users and transporters, as well as hazardous
waste generators and disposers, are subject to regulations that require proper transport, handling, use,
storage, and disposal of such materials to ensure public safety. Thus, if hazardous materials are found to be
present on present or future project sites appropriate remediation activities would be required pursuant to
standard federal, State, and regional regulations. Compliance with the relevant federal, State, and local
regulations during the construction and operation of related projects would ensure that cumulative impacts
from hazardous materials would be less than significant.
I. Hydrology and Water Quality
Impact WO-1 Finding: The Project would not violate any water quality standards or waste discharge
requirements or otherwise substantially degrade surface or ground water quality (Initial Study at p. A9 and
Draft EIR at p. 7-1 1). Impacts are less than significant.
Facts in Support of Findings:
Construction: Construction of future development facilitated by the Project would require grading and
excavation of soils over approximately seven acres, which would loosen sediment, and then have the
potential to mix with surface water runoff and degrade water quality. Additionally, construction would
require the use of heavy equipment and construction -related chemicals, such as concrete, cement, asphalt,
fuels, oils, antifreeze, transmission fluid, grease, solvents and paints. These potentially harmful materials could
be accidentally spilled or improperly disposed of during construction and, if mixed with surface water runoff,
could wash into and pollute waters.
These types of water quality impacts during construction would be prevented through implementation of a
SWPPP. Construction of the Project would disturb more than one acre of soil; therefore, the proposed Project
would be required to obtain coverage under the NPDES General Permit for Discharges of Storm Water
Associated with Construction Activity. Construction activity subject to this permit includes clearing, grading,
and ground disturbances such as trenching, stockpiling, or excavation. The Construction General Permit
requires implementation of a SWPPP that is required to identify all potential sources of pollution that are
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Enderle Center Rezone Project CEQA Findings of Fact
reasonably expected to affect the quality of storm water discharges from the construction site. The SWPPP
would generally contain a site map showing the construction perimeter, proposed buildings, stormwater
collection and discharge points, general pre- and post -construction topography, drainage patterns across
the site, and adjacent roadways. The SWPPP would also include construction BMPs.
Adherence to the existing requirements and implementation of the appropriate BMPs, as ensured through
the City's plan check and permitting process, would ensure that the Project would not violate any water
quality standards or waste discharge requirements, potential water quality degradation associated with
construction activities would be minimized, and construction impacts would be less than significant.
Operation: Operation of the proposed Project would be required to comply with the requirements of the
Orange County DAMP and the intent of the non -point source NPDES Permit for Waste Discharge
Requirements for the County of Orange, Orange County Flood Control District and the incorporated cities
of Orange County within the Santa Ana Region.
The DAMP regulations are included in the City's Municipal Code in Section 4902. The DAMP requires that
new development and significant redevelopment projects develop and implement a WQMP that includes
BMPs and LID design features that would provide onsite treatment of stormwater to prevent pollutants from
onsite uses from leaving the site. A WQMP is required to be approved prior to the issuance of a building or
grading permit. WQMPs prepared for future development would be reviewed and approved by the City
to ensure it complies with the MS4 Permit regulations. In addition, the City's permitting process would ensure
that all BMPs in the WQMP would be implemented with the project. Overall, implementation of the WQMP
pursuant to the existing regulations that would be implemented during the development permitting process
would ensure that operation of the proposed Project would not violate any water quality standards, waste
discharge requirements, or otherwise degrade water quality, and impacts would be less than significant.
Impact WO-2 Finding: The Project would not substantially decrease groundwater supplies or interfere
substantially with groundwater recharge such that the Project may impede sustainable groundwater
management of the basin (Draft EIR at p. 5.1 1-10). Impacts are less than significant.
Facts in Support of Findings: The Project site is fully developed and is nearly 100 percent impervious aside
from some landscaped areas. Therefore, implementation of the proposed Project would not change the
amount of impervious surface or interfere with the rate of groundwater recharge at the Project site compared
to existing conditions. Further, the Project site is not in or near a groundwater recharge area/facility, nor
does it represent a source of groundwater recharge. Therefore, the Project would not substantially interfere
with groundwater supplies or recharge. Impacts would be less than significant.
Orange County Water District (OCWD) serves as the groundwater manager over the OC Basin and sub -
basins. The Project would not decrease groundwater supplies or interfere substantially with groundwater
recharge. Groundwater supply and demand is evaluated through the City's 2020 Urban Water
Management Plan (UWMP) which determined groundwater supplies are sufficient to serve the City's service
area through 2045. Therefore, the proposed Project would not conflict with or obstruct implementation of a
water quality control plan or sustainable groundwater management plan. Impacts would be less than
significant.
Impact WO-3i Finding: The Project would not substantially alter the existing drainage pattern of the area,
including through the alteration of the course of a stream or river or through the addition of impervious
surfaces, in a manner which would result in a substantial erosion or siltation on- or off -site (Initial Study at p.
51 and Draft EIR at p. 7-1 3). Impacts are less than significant.
Facts in Support of Findings:
Construction: All proposed development construction would be required to comply with the California
RWQCB Order No. R8-2010-0033, NPDES Permit No. CAS618033 — Construction General Permit
requirements. Requirements include installation of BMPs, which establishes minimum stormwater management
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Enderle Center Rezone Project CEQA Findings of Fact
requirements and controls. To reduce the potential for soil erosion and the loss of topsoil, a SWPPP is required
by the RWQCB regulations to be developed by a QSD. The SWPPP is required to address site -specific
conditions related to specific grading and construction activities. The SWPPP would identify potential sources
of erosion and sedimentation to prevent loss of topsoil during construction, and to identify erosion control
BMPs to reduce or eliminate the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel
bags; stabilized construction entrances/exits; hydroseeding, and similar measures. In addition to RWQCB
requirements, proposed development would need to comply with the City of Tustin Grading Manual
procedures. The City of Tustin Grading Manual is a compilation of rules, procedures, and interpretations
necessary to carry out the provisions of the Tustin City Code relating to grading and excavation.
Following construction, future development would be required to prepare and implement a WQMP per City
standards. Future projects would be required to comply with the requirements of the Orange County DAMP
and the intent of the non -point source NPDES Permit for Waste Discharge Requirements for the County of
Orange, Orange County Flood Control District and the incorporated cities of Orange County within the Santa
Ana Region that would reduce potential impacts to a less than significant level.
Operation: Changes due to development of the Project site could result in potential changes in the drainage
pattern due to siltation and erosion. However, the MS4 permit and County DAMP require new development
projects to prepare a WQMP that is required to include BMPs to reduce the potential of erosion and/or
sedimentation through site design and structural treatment control BMPs. As part of the permitting approval
process, the proposed drainage and water quality design and engineering plans would be reviewed by the
City's Engineering Division to ensure that the site -specific design limits the potential for erosion and siltation.
Adherence to the existing regulations that would be implemented through the development review and
permitting process would ensure that impacts as a result of future development related to alteration of a
drainage pattern and erosion/siltation from operational activities would be less than significant.
Impact WQ-3ii Finding: The Project would not substantially alter the existing drainage pattern of the site or
area, including through the alteration of the course of a stream or river or through the addition of impervious
surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner
which would result in flooding on- or off -site (Initial Study at p. 53 and Draft EIR at p. 7-1 1). Impacts are
less than significant.
Facts in Support of Findings: Construction of the proposed Project would require demolition that could
temporarily alter the existing drainage pattern of the site and change runoff flow rates. However,
implementation of the Project requires a SWPPP that would address site specific drainage issues related to
construction of the Project and include BMPs to eliminate the potential of flooding or alteration of a drainage
pattern during construction activities. This includes regular monitoring and visual inspections during
construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD
and implemented by a QSP (Qualified SWPPP Practitioner) as verified by the City through the construction
permitting process would prevent construction -related impacts related to potential alteration of a drainage
pattern or flooding on- or offsite from development activities. Therefore, construction impacts would be less
than significant.
Impact WQ-3iii Finding: The Project would not substantially alter the existing drainage pattern of the site
or area, including through the alteration of the course of a stream or river or through the addition of
impervious surfaces, in a manner which would create or contribute runoff water which would exceed the
capacity of existing or planned stormwater drainage systems or provide substantial additional sources of
polluted runoff (Initial Study at p. 53 and Draft EIR at p. 7-12). Impacts would be less than significant.
Facts in Support of Findings:
Construction: Implementation of the Project requires a SWPPP (included as PPP HYD-1) that would address
site -specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate
the potential of polluted runoff and increased runoff during construction activities. This includes regular
monitoring and visual inspections during construction activities. Compliance with the Construction General
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Enderle Center Rezone Project CEQA Findings of Fact
Permit and a SWPPP prepared by a QSD and implemented by a QSP as verified by the City through the
construction permitting process would prevent construction -related impacts related to increases in run-off and
pollution from development activities. Therefore, impacts would be less than significant.
Operation: Because the site is currently almost entirely paved, future development would increase intensity
of development, but would not result in additional impervious surfaces that could increase the volume and
velocity of stormwater runoff. Therefore, future development would not be anticipated to exceed capacity
of the existing stormwater drainage system. Additionally, the MS4 permit and County DAMP require new
development projects to prepare a WQMP that is required to include BMPs to reduce the potential of
stormwater pollutants through site design and structural treatment control BMPs. As part of the permitting
approval process, the proposed drainage and water quality design and engineering plans would be
reviewed by the City's Engineering Division to ensure that the site -specific design limits the potential for
sources of polluted runoff. Overall, adherence to the existing regulations would ensure that impacts as a
result of future development related to stormwater runoff would be less than significant.
Impact WQ-3iv Finding: The Project would not substantially alter the existing drainage pattern of the site
or area, including through the alteration of the course of a stream or river or through the addition of
impervious surfaces, in a manner which would impede or redirect flood flows (Initial Study at p. 54 and Draft
EIR at p. 7-1 2). Impacts would be less than significant.
Facts in Support of Findings: The Project site is in the Federal Emergency Management Agency (FEMA)
Flood Insurance Rate Map (FIRM) Map Number 06059COl 64J. The Project site is within an area designated
as Zone X, areas of 0.2 percent annual chance of flood; areas of 1 percent annual chance of flood with
average depths of less than 1 foot or with drainage areas less than 1 square mile; and areas protected by
levees from 1 percent annual chance flood. Therefore, the Project site is not currently within a designated
flood zone. The Project site is currently completely developed and completely paved, with the exception of
some ornamental landscaped areas. Future development would not result in additional impervious surfaces
that could increase the volume and velocity of stormwater runoff that would exacerbate flood conditions.
Therefore, the Project would result in a less -than -significant impact.
Impact WO-4 Finding: The Project would not risk release of pollutants due to Project inundation within a
flood hazard zone (Initial Study at p. 54 and Draft EIR at p. 7-1 1). No impacts would occur.
Facts in Support of Findings: According to the FEMA Map 06059COl64J, the Project site is within Flood
Zone X, or the 0.2 percent annual change flood area, areas of 1 percent annual chance flood with average
depth less than 1 foot or with drainage areas of less than 1 square mile. The site is not within a special flood
hazard area.
A seiche is a surface wave created when an inland body of water is shaken, usually by earthquake activity.
The site also is not subject to flooding hazards associated with a seiche because there are no large body of
surface water located near the project site to result in effects related to a seiche, which could result in release
in pollutants due to inundation of the site. The Project site is not located near an inland body of water that
could result in impacts due to seiche.
The Pacific Ocean is located over 12 miles southwest of the Project site; consequently, there is no potential
for the Project site to be inundated by a tsunami that could release pollutants. In addition, the Project site is
flat and not located near any steep hillsides; therefore, there is no potential for the site to be adversely
affected by mudflow. Thus, implementation of the proposed Project would not expose people or structures
to a significant risk of loss, injury, or death involving inundation by seiche, tsunami, or mudflow that could
release pollutants due to inundation of the Project site. No impact would occur.
Impact WO-5 Finding: The Project would not conflict with or obstruct implementation of a water quality
control plan or sustainable groundwater management plan (Draft EIR at p. 5.1 1-10). Impacts are less than
significant.
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Enderle Center Rezone Project CEQA Findings of Fact
Facts in Support of Findings: The Project site is fully developed and is nearly 100 percent impervious aside
from some landscaped areas. Therefore, implementation of the proposed Project would not change the
amount of impervious surface or interfere with the rate of groundwater recharge at the Project site compared
to existing conditions. Further, the Project site is not in or near a groundwater recharge area/facility, nor
does it represent a source of groundwater recharge. Therefore, the Project would not substantially interfere
with groundwater supplies or recharge. Impacts would be less than significant.
OCWD serves as the groundwater manager over the OC Basin and sub -basins. The Project would not
decrease groundwater supplies or interfere substantially with groundwater recharge. Groundwater supply
and demand is evaluated through the City's 2020 UWMP which determined groundwater supplies are
sufficient to serve the City's service area through 2045. Therefore, the proposed Project would not conflict
with or obstruct implementation of a water quality control plan or sustainable groundwater management
plan. Impacts would be less than significant.
Hydrology and Water Quality Cumulative Findings: The Project would not result in cumulative impacts
related to hydrology and water quality (Initial Study at p. 49 - 55 and Draft EIR at p. 7-1 1 through 7-1 3).
Facts in Support of Findings: Related developments within the watershed would be required to implement
water quality control measures pursuant to the same NPDES General Construction Permit that requires
implementation of a SWPPP (for construction), a WQMP (for operation) and BMPs to eliminate or reduce
the discharge of pollutants in stormwater discharges, reduce runoff, reduce erosion and sedimentation, and
increase filtration and infiltration, in areas permitted. The NPDES permit requirements have been set by the
SWRCB and implemented by the RWQCB to reduce incremental effects of individual projects so that they
would not become cumulatively considerable. Therefore, overall potential impacts to water quality
associated with present and future development in the watershed would not be cumulatively considerable
with compliance with all applicable laws, permits, ordinances and plans. Therefore, cumulative impacts
related to water quality would be less than significant.
J. Land Use and Planning
Impact LU-1 Finding: The Project would not physically divide an established community (Initial Study at p.
56 and Draft EIR at p. 7-14). No impacts would occur.
Facts in Support of Findings: The Project site is currently developed as a commercial center that includes
restaurant, retail, and office uses. The Project would include a GPA, CA and rezone of the Project site with
a Housing Overlay (HO) district to allow for future development of up to 413 housing units, consistent with
the City's certified 2021-2029 Housing Element. The Project does not propose development; however, the
Project would provide for future proposed development through implementation of the housing overlay and
the City's certified 2021 -2029 Housing Element. Implementation of the Project would allow for the
intensification of the existing site; however, the introduction of residential land uses would not result in division
of an established community. Therefore, the Project would result in no impact.
Impact LU-2 Finding: The Project would not cause a significant environmental impact due to a conflict with
any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental
effect (Draft EIR at p. 5.4-14). Impacts are less than significant.
Facts in Support of Findings:
SCAG: The proposed Project would implement SCAG strategies related to high -density, infill development,
and improvement of the job/housing balance that is centered around public transit opportunities. The Project
provides for infill development in an already developed urban area that would make use of the existing
circulation and utility infrastructure. The Project would allow for development of high -density residential uses
and commercial uses that would create a mixed -use environment in which residents would benefit from the
proposed onsite uses and nearby shopping, restaurant, and employment opportunities. Mixed -use
development generally results in lower vehicle miles traveled (VMT) due to the proximity of residential and
City of Tustin 19
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Enderle Center Rezone Project CEQA Findings of Fact
nonresidential uses. The Project was found to be consistent with both the SCAG Connect SoCal 2020-2040
RTP/SCS (Table 5.4-1 of the Draft EIR at p. 5.4-15) and the Connect SoCal 2024-2050 RTP/SCS (Table
5.4-2 of the Draft EIR at p. 5.4-1 8), approved on April 4, 2024.
General Plan Land Use Designation: The Project site currently has a General Plan Land Use designation of
Planned Community Commercial/Business (PCCB). The City's certified 2021 -2029 Housing Element identified
the Enderle Center as having capacity for 413 housing units. The proposed Project would implement the
City's land use designation for the Project site by proposing a new overlay zone ("overlay district"). This
would be accomplished with a Housing Overlay (HO). Upon approval of the HO, the Project site could
accommodate 413 units over approximately 7 acres of developable land within the existing 1 1.8-acre
shopping center. This would result in a density of 59 du/ac. The proposed Project would still be consistent
with the current zoning designation for the site while allowing for the development of housing. Thus, the
proposed Project would implement, and would not conflict with, the General Plan land use designation or
the current zoning designation for the site.
Land Use Consistency: The proposed Project would provide housing proximate to local employment centers,
commercial retail services and restaurants for onsite residents and employees working nearby. The proposed
Project would not result in a land use inconsistency. The proposed Project would allow for a mix of uses,
including residential, and would provide locational efficiency as it allows people to work, live, and obtain
services within a small area, which has the potential to reduce VMT in comparison to residential development
that is farther from employment and services. With implementation of existing regulations, the proposed
Project would not result in significant environmental impacts such as light, noise, or air quality to the adjacent
existing and planned land uses. Therefore, impacts related to land use inconsistency would be less than
significant.
General Plan Goals, Policies, and Objectives: A detailed analysis of the proposed Project's consistency with
the applicable goals, policies, and objectives of the City's GP that serve to avoid or mitigate environmental
impacts is provided in Draft EIR Table 5.4-3. As described, the proposed Project would be consistent with
the relevant goals, policies, and objectives of the City's General Plan that avoid or mitigate environmental
impacts, and impacts related to conflict with a General Plan policy related to an environmental effect would
be less than significant.
Land Use and Planning Cumulative Findings: The Project would not result in cumulative impacts related to
land use and planning (Draft EIR at p. 5.4-45).
Facts in Support of Findings: The geographic context for this cumulative analysis includes the City of Tustin
in relation to the City's General Plan. Cumulative development would be subject to site -specific environmental
and planning reviews that would address consistency with adopted General Plan and City's Municipal Code.
As part of environmental review, projects would be required to provide mitigation for any inconsistencies
with the General Plan and environmental policies that would result in adverse physical environmental effects.
The Project would be cumulatively beneficial to meeting the statewide housing objectives as established
through the regional and local RHNA. As the Project is consistent with the City's municipal code and would
provide for future housing that would be consistent with the City's Housing Element, no cumulatively
considerable impacts would occur from the proposed Project.
K. Mineral Resources
Impact MIN-1 Finding: The Project would not result in the loss of availability of a known mineral resource
that would be of value to the region and the residents of the state (Initial Study at p. 57 and Draft EIR at p.
7-14). No impacts would occur.
Facts in Support of Findings: The Conservation/Open Space/Recreation Element identifies one mineral
resource within the Tustin Planning Area known as Mercury -Barite in Red Hill. However, this resource is not
utilized. The Project site is not identified for mineral resource extraction. Therefore, the Project would result
in no impact on the loss of availability of a known mineral resource.
City of Tustin 20
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Enderle Center Rezone Project CEQA Findings of Fact
Impact MIN-2 Finding: The Project would not result in the loss of availability of a locally -important mineral
resource recovery site delineated on the general plan, specific plan or other land use plan (Initial Study at
p. 57 and Draft EIR at p. 7-14). No impacts would occur.
Facts in Support of Findings: the Project site is not identified for mineral resource extraction per the City
General Plan Conservation Element. Therefore, the Project would result in no impact on the loss of availability
of a locally important mineral resource recovery.
Mineral Resources Cumulative Findings: The Project would not result in cumulative impacts related to
mineral resources (Initial Study at p. 57 and Draft EIR at p. 7-14).
Facts in Support of Findings: The Project area has not historically included mineral extraction, nor does the
Project area currently support mineral extraction or have identified mineral resources. Thus, implementation
of the Project would not result in significant impacts to mineral resources and impacts would not be
cumulatively considerable.
L. Noise
Impact NOI-2 Finding: The Project would not result in the generation of excessive groundborne vibration or
groundborne noise levels (Draft EIR at p. 5.5-19). Impacts are less than significant.
Facts in Support of Findings:
Construction: The primary source of vibration during future construction would be the operation of a
bulldozer. As shown on Draft EIR Table 5.5-9, a large bulldozer would create a vibration level of 0.089
inch per second peak particle velocity (PPV) at 25 feet. According to the Noise and Vibration Impact Analysis
prepared for the proposed Project, the vibration level at the nearest offsite structure (70 feet away) would
be 0.019 inch per second PPV during future buildout, as shown in Draft EIR Table 5.5-10, which is below the
Federal Transit Authority (FTA) vibration threshold of 0.2 PPV inch per second. Additionally, Section 4616
of the Tustin City Code specifies that noise sources associated with construction activities are prohibited
before 7:00 AM and after 6:00 PM, Monday through Friday; before 9:00 AM and after 5:00 PM on
Saturdays; anytime on Sundays; or anytime during City -observed federal holidays. Therefore, construction
related vibration would not occur during sensitive nighttime hours. Therefore, impacts related to construction
vibration would be less than significant.
Operation: Potential vibration impacts associated with the operations of the proposed Project after buildout
would be from vehicular traffic such as heavy trucks for residents moving in and out of the units, product
deliveries and garbage trucks for solid waste disposal. Truck vibration levels are dependent on vehicle
characteristics, load, speed, and pavement conditions. However, vibration levels generated from Project -
related traffic on the adjacent roadways by on -road vehicles would not be excessive because the rubber
tires and suspension systems of on -road vehicles provide vibration isolation. The development contemplated
by the Project would not generate a considerable level of heavy truck traffic or any other source of vibration.
Thus, operational vibration impacts would be less than significant.
Impact NOI-3 Finding: The Project would not expose people residing or working in the project area to
excessive noise levels, for a project located within the vicinity of a private airstrip or an airport land use
plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport
(Draft EIR at p. 5.5-20). No impacts would occur.
Facts in Support of Findings: The Project site is located approximately 5.5 miles northeast of John Wayne
Airport. According to Draft EIR Figure 5.5-2, Airport Noise Contours, of the John Wayne Airport AELUP, the
Project site is not located within the 65 dBA CNEL noise contours. No other airports exist within the vicinity of
the Project. Thus, implementation and development of the Project would not result in a safety hazard or
exposure to excessive noise for people residing or working in the area, and impacts would be less than
significant.
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Enderle Center Rezone Project CEQA Findings of Fact
M. Population and Housing
Impact POP-1 Finding: The Project would not induce substantial unplanned population growth in an area,
either directly or indirectly (Draft EIR at p. 5.6-7). Impacts are less than significant.
Facts in Support of Findings: As shown in Draft EIR Table 5.6-2, the population in the City of Tustin is
expected to increase by 12,919 people between 2019 and 2050. As shown in Draft EIR Table 5.6-4,
housing stock in the city is expected to increase by 7,000 dwelling units between 2019 and 2050. Based on
these growth projections, full buildout of the Project would represent approximately 9.2 percent of the
projected population growth and 5.9 percent of the projected housing stock growth in the city. Thus, the
increase in population and number of housing units that would result from the proposed Project would not
exceed projections for the City.
Also, as reflected in Draft EIR Table 5.6-1, SCAG determined the City needs to provide a total of 6,782
housing units to meet their RHNA. The City's 2021-2029 Housing Element identifies several adequate sites
that are able to accommodate the development of additional housing units for the City to meet its estimated
housing growth needs identified in the SCAG's RHNA allocation. Of the Housing Element inventory sites, the
Project site was identified. Thus, development of housing on the Project site does not consist of unplanned
g rowth.
Impact POP-2 Finding: The Project would not displace substantial numbers of existing people or housing,
necessitating the construction of replacement housing elsewhere (Initial Study at p. 59 and Draft EIR at p. 7-
14). No impacts would occur.
Facts in Support of Findings: The Project would include land use changes to allow for the future development
of up to 413 housing units, consistent with the City's certified 2021 -2029 Housing Element, within an existing
commercial land use. Therefore, the Project would not result in the displacement of existing people or housing
and there would be no impact.
Population and Housing Cumulative Findings: The Project would not result in cumulative impacts related
to population and housing (Draft EIR at p. 5.6-9).
Facts in Support of Findings: Impacts from cumulative population growth are considered in the context of
their consistency with local and regional planning efforts. As discussed, SCAG's 2024-2050 RTP/SCS serves
as a long-range vision plan for development in the counties of San Bernardino, Imperial, Los Angeles,
Orange, Riverside, and Ventura. The Project would not exceed the SCAG population, housing, and
employment growth projections for the City and would represent a nominal percentage of SCAG's overall
projections for the City of Tustin. The Project could result in a generation of Al 3 residential units at full
buildout. Based on the growth projections analyzed in SCAG's 2024-2050 RTP/SCS, full buildout of the
Project would represent approximately 9.2 percent of the projected population growth and 5.9 percent of
the projected housing stock growth in the City of Tustin. The Project is within the growth projections used to
prepare RTP/SCS; thus, impacts related to cumulative growth would be less than significant and not
cumulatively considerable.
N. Public Services
Impact PS-1 Finding: The Project would not result in substantial adverse physical impacts associated with
the provision of new or physically altered governmental facilities, the construction of which could cause
significant environmental impacts, in order to maintain acceptable service ratios and response times or other
performance objectives for: fire protection, police protection, schools, parks, or other public facilities? (Draft
EIR at p. 5.7-4 through 5.7-16). Impacts are less than significant.
Facts in Support of Findings:
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Enderle Center Rezone Project CEQA Findings of Fact
Fire Protection: The increased onsite population is expected to create the typical range of service calls to
Orange County Fire Authority (OCFA), largely related to medical emergencies. There are five existing fire
stations that would serve the Project site. The first responding station within the primary responsibility area
for the proposed Project (Station 21) is 2 miles from the Project site. The other responding stations include
Station 72 located 1.6 miles from the Project site, Station 70 located 1.8 miles from the Project site, Station
75 located 3.3 miles from the Project site, and Station 8 located 3.6 miles from the Project site. Because the
Project site is within four miles of five existing fire stations, and the Project site is within a developed area
that is currently served by a first responding station that is 2 miles from the Project site, and a second
responding station that is 1.6 miles from the Project site, the Project would not result in the requirement to
construct a new fire station.
Also, future projects allowed under the proposed Project would be required, per City permitting, to comply
with existing regulations, including the California Fire Code and the OCFA Fire Prevention Guideline B-09,
Fire Master Plans for Commercial and Residential Development, which include regulations for water supply,
built in fire protection systems, adequate emergency access, fire hydrant availability, and fire -safe building
materials. Thus, the proposed Project would not result in substantial adverse physical impacts associated with
the provision of, or the need for, new or physically altered fire protection facilities. Impacts related to fire
protection services would be less than significant.
Further, funding for fire facilities, equipment, and service personnel come from the City's General Fund.
Funding from property taxes, as a result of population growth, would be expected to grow roughly
proportional to any increase in residential units and businesses in the City. Therefore, the additional demand
for fire services and protection generated by the proposed Project would be satisfied through the General
Fund.
Police Protection: Crime and safety issues during Project construction may include theft of building materials
and construction equipment, malicious mischief, graffiti, and vandalism. During operation, the proposed
Project is anticipated to generate a typical range of police service calls, such as vehicle burglaries, residential
thefts, commercial shoplifting, and disturbances. Additionally, future applicants would be required to
coordinate with the Tustin Police Department prior to project approval to ensure that adequate security
precautions and design features are in place.
Based on the City's current ratio of officers to residents (1.1 officers per 1,000), future buildout of the
proposed Project would result in the need for one additional police officer (1,189/1,000 x 1.1 = 1.31).
Although future buildout of the proposed Project would incrementally increase the demand for City police
protection services, this demand would not be expected to require the construction of new facilities or the
expansion of existing facilities. Thus, impacts would be less than significant.
The Police Department's operating budget and expansion of facilities, personnel, and equipment is from the
City's General Fund. Funding from property taxes, as a result of population growth, would be expected to
grow roughly proportional to any increase in residential units and businesses in the City. Tustin Police
Department would continue to add staff and equipment on an as -needed basis to accommodate the
incrementally increasing demands from future development, including the proposed Project. Therefore, the
additional demand for police services and protection generated by the proposed Project would be satisfied
through the General Fund. Impacts would be less than significant.
School Facilities: As shown in Draft EIR Table 5.1 1-5, based on the Tustin Unified School District (USD) student
generation rates, the proposed Project would result in 66 elementary students, 37 intermediate students,
and 50 high school students, which would total 153 students at Project buildout. The student population would
account for approximately 13 percent of the total 1,189 residents at full occupancy. The need for additional
school facilities is addressed through compliance with school impact fee assessment. Pursuant to Government
Code Section 65995, applicants pay developer fees to the appropriate school districts at the time building
permits are issued; and payment of the adopted fees provides full and complete mitigation of school impacts.
As a result, impacts related to school facilities would be less than significant with the Government Code -
required fee payments.
City of Tustin 23
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Enderle Center Rezone Project CEQA Findings of Fact
Library Services: Buildout of the Project could result in an additional 1,189 residents in the City and 365
employees. This increase in population would increase the demand for library services in the City. Based on
Orange County Public Library's (OCPL) service standards of 0.2 square feet of library space per capita,
the Project would require approximately 518 SF of library space. Funding for library services is provided
through County property taxes dedicated to the library. Project impacts are anticipated to be adequately
funded by an increase in tax revenue, over an extended period of time, relative to the increase in
development intensity. Therefore, future buildout of the proposed Project would not result in the need for
new or physically altered library facilities, the construction of which could cause significant environmental
impacts. Impacts to library services would be less than significant.
Public Services Cumulative Findings: The Project would not result in cumulative impacts related to public
services (Draft EIR at p. 5.7-6 through 5.7-15).
Facts in Support of Findings: The Project would not significantly increase the need for public services in
Tustin, cities surrounding Tustin, or the region. As discussed above, the Project applicant would pay the
required developer fees. Additionally, as discussed above, the Project would not impact acceptable service
ratios, staffing levels, adequate equipment, response times, and other performance objectives or if the result
in the need for new or the expansion of existing government services and facilities. Related projects in the
region would be required to demonstrate their level of impact on public services and also pay their
proportionate development fees. Therefore, the past, present, and future projects would not result in a
cumulative impact related to the provision of public services.
O. Recreation
Impact REC-1 Finding: The Project would not result in increased use of existing neighborhood and regional
parks or other recreational facilities such that substantial physical deterioration of the facility would occur
or be accelerated (Draft EIR at p. 5.8-4). Impacts are less than significant.
Facts in Support of Findings: The City has a total of 183.2 acres of parkland, or approximately 2.36 acres
of parkland per 1,000 residents. Using the City's standard of 3 acres of parkland for every 1,000 residents,
the proposed Project would result in a demand for approximately 3.57 additional acres of parkland to
support the additional residents. However, future implementation of development projects would be required
to provide their fair share of park facilities and/or pay in lieu fees in accordance with Tustin City Code
(Article 9, Chapter 3, Part 3, Section 9331). Additionally, there are 20.4 acres of parkland within 2 miles
of the Project site available for use by the proposed residents. Due to the limited increase of residents that
would occur from implementation of the proposed Project and the amount of available park space within
the vicinity of the Project site, future residents are not anticipated to increase the use of existing parks and
recreation facilities such that substantial physical deterioration of such parks and facilities would occur.
Therefore, impacts would be less than significant.
Impact REC-2 Finding: The Project would not require the construction or expansion of recreational facilities
which might have an adverse physical effect on the environment (Draft EIR at p. 5.8-5). Impacts are less than
significant.
Facts in Support of Findings: The Project involves the implementation of a Housing Overlay (HO) district,
which would allow for 7 acres of the Project site to be developed with residential uses. The Project does not
include the construction or expansion of parks. Implementation of future developments allowed by the
proposed Project would result in the need for additional parkland to serve the future population. However,
future implementation of development projects would be required to provide recreational facilities and/or
pay development fees to contribute to the construction or expansion of recreational facilities. Thus, the Project
would have less -than -significant impacts on the construction or expansion of recreational facilities or services.
Recreation Cumulative Findings: The Project would not result in cumulative impacts related to public services
(Draft EIR at p. 5.8-5).
City of Tustin 24
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Enderle Center Rezone Project CEQA Findings of Fact
Facts in Support of Findings: The cumulative area of recreation impacts for the proposed Project includes
the City of Tustin. Based on 3 acres of public park and/or recreational space per 1,000 residents, buildout
of the proposed Project results in a need for approximately 3.57 acres of parkland to serve the 1,189 new
residents of the Project site, which would be provided through onsite recreation facilities and/or payment of
in -lieu fees. Implementation of future development projects would also be required to provide adequate
park facilities or pay in lieu fees, in accordance with Tustin City Code Section 9331. Therefore, the proposed
Project's impacts related to the amount of parkland within the City would not result in a cumulatively
considerable impact related to parks and recreational facilities.
P. Transportation
Impact TR-1 Finding: The Project would not conflict with a program, plan, ordinance, or policy addressing
the circulation system, including transit, roadway, bicycle, and pedestrian facilities (Draft EIR at p. 5.9-16).
Impacts are less than significant.
Facts in Support of Findings:
Roadway: Regional access to the Project site is provided by SR-55. Local access to the site is provided via
17th Street, Yorba Street, Vandenberg Lane, and Enderle Center Drive. The proposed Project would continue
to provide vehicular access to the site from the adjacent roadways and there would be no changes to the
roadway access points. However, potential future development facilitated by the Project may include
driveway and roadway improvements. Specific roadway improvements required to support residential
development at the Project site are not known at this time and will not be known until a development project
is proposed. Future projects would be required to comply with the circulation system standards and to adhere
to uniform standards and practices. Compliance with standards for roadway and intersection classifications,
right-of-way width, pavement width, design speed, warrant requirements, capacity, maximum grades and
associated features such as medians would be ensured and verified by the City during the plan check and
permitting process, prior to obtaining building permits. The proposed Project would not conflict with existing
facilities and would provide additional facilities as needed. Thus, impacts related to pedestrian facilities
would not occur.
Transit: The Project vicinity is served by Orange County Transit Authority (OCTA). There are two bus stops
within one mile of the Project site. Additionally, the Metrolink Inland Empire -Orange County Line has a stop
1.7 miles east of the Project of the Project site, at the Santa Ana Metrolink Station. This existing transit service
would continue to serve its ridership in the area. The proposed Project would not alter or conflict with existing
roadway facilities addressed in the circulation element, and impacts related to roadway facilities would not
occur.
Bicycle Facilities: There are no bike lanes on any public roadway network currently serving the Project site.
The City's General Plan Circulation Element, Figure C-5 Master Bikeway Plan, does not identify any roadway
network currently serving the Project site as a planned bike lane or bikeway. The nearest planned bicycle
lane is located 1,000 feet west of the Project site at Prospect Avenue. Implementation of the Project would
not alter or conflict with existing or planned bike lanes or bicycle transportation. Thus, impacts related to
bicycle facilities would not occur.
Pedestrian Facilities: Sidewalks currently exist on both sides of 17th Street, Vandenburg Lane, and Yorba
Street and on the northbound side of Enderle Center Drive within the vicinity of the Project site. Future projects
under the proposed Housing Overlay would be required to comply with and adhering to uniform standards
and practices, including designation of bicycle lanes and adequate sidewalk as ensured and verified by the
city during the plan check and permitting process, prior to obtaining building permits. Additionally future
development is subject to compliance with applicable accessibility requirements of the American Disabilities
Act, Title 2A of the Uniform Building Code as locally amended, and the Department of Housing and Urban
Developments Fair Housing Accessibility Guidelines. Therefore, the proposed Project would not conflict with
City of Tustin 25
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Enderle Center Rezone Project CEQA Findings of Fact
pedestrian facilities, but instead would provide additional facilities. Thus, impacts related to pedestrian
facilities would not occur.
Impact TR-2 Finding: The Project would not conflict or be inconsistent with CEQA Guidelines Section
15064.3, subdivision (B) regarding vehicle miles traveled (Draft EIR at p. 5.9-19). Impacts are less than
significant.
Facts in Support of Findings: State CEQA Guidelines Section 15064.3(b) focus on determining the
significance of VMT-related transportation impacts. The City of Tustin's Transportation Impact Analysis
Guidelines contain the following screening thresholds to assess whether a project has the potential to result in
an impact and further VMT analysis is required. If the Project meets any of the following screening thresholds,
then the VMT impact of the Project is considered less than significant and further VMT analysis is not required.
The Project is located in a Low VMT Generating Area for VMT per capita based on the City's Guidelines
and would meet Screening Citeria 4 for residential Low VMT Area Screening. In addition, Draft EIR Table
5.9-3, shows that the Project's home based VMT per capita would be lower than the Orange County
Transportation Analysis Model (OCTAM) base model year citywide average home based VMT per capita
for the City of Tustin under both base and future year conditions. The Project's home -based VMT per capita
would be 19.7 percent below the City's threshold under base conditions and 18.7 percent below the City's
threshold under future conditions; therefore, the residential portion of the Project would result in a less -than -
significant VMT impact. Also, as shown in Draft EIR Table 5.9-4, the Project's employment VMT per employee
would be lower than the OCTAM base model year citywide average employment VMT per employee for
the City of Tustin under both base and future year conditions. The Project's employment VMT per employee
would be 5.5 percent below the City's threshold under base conditions and 3.7 percent below the City's
threshold under future conditions; therefore, the commercial portion of the Project would result in a less -than -
significant VMT impact. Therefore, the Project would result in a less -than -significant impact related to VMT.
Impact TR-3 Finding: The Project would not substantially increase hazards due to a geometric design feature
(e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) (Draft EIR at p.
5.9-21). Impacts are less than significant.
Facts in Support of Findings: The Project does not propose a specific development, the Project would
provide for future proposed development through implementation of the housing overlay. All future
development would be subject to the City's design requirements that would be implemented through the
development permitting process. As a result, impacts related to hazardous vehicular circulation design
features and incompatible uses during construction and operation of future development provided by the
proposed Project would be less than significant.
Impact TR-4 Finding: The Project would not result in inadequate emergency access (Draft EIR at p. 5.9-22).
Impacts would not occur.
Facts in Support of Findings: The proposed Project would not result in inadequate emergency access. All
future development would be required to ensure emergency access in accordance with Section 503 of the
California Fire Code (Title 24, California Code of Regulations, Part 9), which would be ensured through the
City's permitting process. Operation of potential future development would also not result in inadequate
emergency access or access to nearby uses. Future applicants would be required to design and construct
internal access and provide fire suppression facilities (e.g., hydrants and sprinklers) in conformance with
City's Standard Plans and Design Standards. Additionally, the City's Fire Department (OCFA) would review
the development plans prior to approval to ensure adequate emergency access pursuant to the requirements
in the International Fire Code and Section 503 of the California Fire Code (Title 24, California Code of
Regulations, Part 9). As a result, the proposed Project including potential future development would not result
in inadequate emergency access or access to nearby uses, and no impacts would occur.
Transportation Cumulative Findings: The Project would not result in cumulative impacts related to
transportation (Draft EIR at p. 5.9-22).
City of Tustin 26
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Enderle Center Rezone Project CEQA Findings of Fact
Facts in Support of Findings: The cumulative traffic study area for the proposed Project includes the City
of Tustin and surrounding jurisdictions. The Office of Planning and Research's Technical Advisory on Evaluating
Transportation Impacts in CEQA states that "a project that falls below an efficiency -based threshold that is
aligned with long-term environmental goals and relevant plans would have no cumulative impact distinct
from the project impact." As detailed in Draft EIR Table 5.9-4, the Project's employment VMT per employee
would be lower than the OCTAM base model year citywide average employment VMT per employee for
the City of Tustin in future year conditions Therefore, the proposed Project would not result in a cumulatively
considerable impact related to VMT and cumulative traffic impacts would also be less than significant.
Cumulative development in the City and surrounding jurisdictions would be subject to similar site -specific
reviews, including reviews of roadway design, geometrical design features, and future infrastructure
improvements, which would ensure projects are consistent with roadway design standards and would not
result in unsafe traffic conditions, and would include sidewalks and bicycle paths, as appropriate. As the
Project would be permitted in compliance with City standards to not contribute to a cumulatively considerable
impact associated with hazardous design features or alternative transportation.
Q. Utilities and Service Systems
Impact UT-2 Finding: Sufficient water supplies are available to serve the Project and reasonably
foreseeable development during normal, dry, and multiple dry years (Draft EIR at p. 5.1 1-10). Impacts are
less than significant.
Facts in Support of Findings: Based on the City's water use per day in 2020 of 95 gallons per capita, the
estimated 1,189 residents and 365 employees would generate an additional water demand of 147,630
gallons per day or 165.5 acre-feet per year (AFY). Based on the City's UWMP supply and demand data
and the limited increase in water demand from the proposed Project, the City would have water supplies
available to serve the Project. Additionally, as shown in Draft EIR Table 5.1 1-2, the City would have sufficient
water supplies to serve the Project and cumulative development during normal, dry, and multiple dry year
scenarios through 2045. Therefore, implementation of the proposed Project would result in a less than
significant impact related to water supplies.
Impact UT-4 Finding: The Project would not require or result in the relocation or construction of new drainage
facilities, or expansion of existing facilities, the construction of which could cause significant environmental
effects (Draft EIR at p. 5.1 1-18). Impacts would be less than significant.
The Project site is fully developed and is nearly 100 percent impervious aside from some landscaped areas.
Therefore, implementation of the proposed Project would not change the amount of impervious surface and
would not substantially change the amount of storm water runoff and is not anticipated to exceed capacity
of the existing stormwater drainage system.
Future implementation of development projects pursuant to the proposed Project would include installation
of onsite storm drain infrastructure and new connections to the existing storm drain system that would be
sized to accommodate the storm drain water demand of new project -specific development on a project -by -
project basis. Local improvements are anticipated, and extensive offsite utility improvements are not assumed
for the Project. Additionally, the City's MS4 permit and County Drainage Area Management Plan (DAMP)
require new development projects to prepare a WQMP that is required to include BMPs to reduce the
potential of stormwater pollutants through site design and structural treatment control BMPs. As part of the
permitting approval process, the proposed drainage and water quality design and engineering plans would
be reviewed by the City's Engineering Division to ensure that the site -specific design limits the potential for
sources of polluted runoff. Overall, adherence to the existing regulations would ensure that impacts as a
result of future development related to stormwater runoff would be less than significant.
Impact UT-5 Finding: The Project would not generate solid waste in excess of State or local standards or in
excess of the capacity of local infrastructure or otherwise impair the attainment of solid waste reduction
goals (Draft EIR at p. 5.1 1-23). Impacts would be less than significant.
City of Tustin 27
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Enderle Center Rezone Project CEQA Findings of Fact
Facts in Support of Findings: Using solid waste generation rates provided by CaIEEMod, operation of the
proposed Project at buildout would generate approximately 227.65 tons of solid waste per year, at least
75 percent of which is required by California law to be recycled, which would reduce the volume of landfilled
solid waste to approximately 56.9 tons per year, or 1.1 tons per week, as shown on Draft EIR Table 5.1 1 -3.
Frank Bowerman Landfill is permitted to accept 11,500 tons per day of solid waste and the Olinda Alpha
Sanitary Landfill is permitted to receive 10,000 tons per day for 36 days of the year and is permitted to
receive 8,000 tons per day for the other 271 days of the year. Both landfills would be able to accommodate
the operational solid waste from future development under the proposed Project. Thus, future development
under the proposed Project would be served by a landfill with sufficient permitted capacity to accommodate
the Project's solid waste disposal needs and the proposed Project would not impair the attainment of solid
waste reduction goals. Thus, impacts related to landfill capacity would be less than significant.
Impact UT-6 Finding: The Project would not generate solid waste in excess of State or local standards, or
in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction
goals (Draft EIR at p. 5.1 1-23). Impacts are less than significant.
Facts in Support of Findings: Future implementing projects would also be subject to Section 5.408.1 of the
2022 California Green Building Standards Code that requires demolition and construction activities to
recycle or reuse a minimum of 65 percent of the nonhazardous construction and demolition waste.
Furthermore, future implementing projects would be required to comply with all applicable State and local
waste diversion requirements, including AB 939, AB 341, AB 1836, AB 827 and SB 1383. Therefore, the
proposed Project would comply with all solid waste statute and regulations; and impacts would be less than
significant.
Impact UT-7 Finding: The Project would not require or result in the relocation or construction of new or
expanded electrical power, natural gas, or communication facilities, the construction of which could cause
significant environmental effects (Draft EIR at p. 5.1 1-26). Impacts would be less than significant.
Facts in Support of Findings: Adequate commercial electricity supplies are presently available to meet the
incremental increase in demand attributed to the Project. Provision of electricity to the Project site is not
anticipated to require or result in the construction of new facilities or the expansion of existing facilities, the
construction or relocation of which would cause significant environmental impacts to electricity. Impacts would
be less than significant.
Natural gas service would be provided by SoCal Gas. Adequate commercial gas supplies are presently
available to meet the incremental increase in demand attributed to the Project. The proposed Project would
not require or result in the construction, expansion, or relocation of natural gas facilities that could result in a
significant environmental impact. Impacts related to natural gas would be less than significant.
Communication systems for the Project would be provided by AT&T and Cox Communications. AT&T and Cox
Communications are private companies that provide connection to the communication system on an as needed
basis. As such, the proposed Project is not anticipated to require or result in the construction of new
communications facilities or the expansion of existing facilities. Impacts would be less than significant.
Future Project Applicants would be responsible for coordinating with each utility company to ensure utility
improvements occur according to standard construction and operation procedures administered by the
California Public Utilities Commission. Any development in the City would be required to comply with energy
efficiency standards in Title 24 of the California Administrative Code, appliance efficiency regulations in
Title 20 of the California Administrative Code, CALGreen. Therefore, potential impacts associated with
utilities, including electricity, natural gas and communication systems would be less than significant and no
mitigation is required.
Utilities and Service Systems Cumulative Findings: The Project would not result in cumulative impacts
related to utilities and service systems (Draft EIR at p. 5.11 -1 1 through 5.1 1-22).
City of Tustin 28
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Enderle Center Rezone Project CEQA Findings of Fact
Facts in Support of Findings:
Water: The geographic scope of cumulative analysis for water service is the service area of the City.
Cumulative water supply impacts are associated with the adequacy of the City's primary sources of water,
which include groundwater pumped from the OC Basin and supplemental imported water supplied by
Orange County Sanitation District through the Metropolitan Water District of Orange County (MWDOC). As
described above, water supplies have been planned through the City's 2020 UWMP, which identifies the
ability to meet a majority of future water demands through groundwater and imported supplies. The City's
UWMP provides projections for water supply and demand through 2045, and shows that in normal, dry,
and multiple dry year conditions with anticipated growth in the City's service area, the City of Tustin Water
Department would be able to meet water demand. As a result, cumulative impacts would be less than
significant.
Wastewater: Cumulative wastewater infrastructure impacts are considered on a systemwide basis and are
associated with the overall capacity of existing and planned infrastructure. The cumulative system evaluated
includes the sewer system and the conveyance system through wastewater disposal at the OC San's
Wastewater Treatment. As described previously, with the proposed Project, the sewer system would have
sufficient capacity to handle the increased flows resulting from implementation of the proposed Project. The
continued regular assessment, maintenance, and upgrades of the sewer system by Orange County Sanitation
District would reduce the potential of cumulative development projects to result in a cumulatively substantial
increase in wastewater such that new or expanded facilities would be required. Thus, increases in wastewater
in the sewer system would result in a less than significant cumulative impact.
Drainage: The geographic scope for cumulative impacts related to stormwater drainage includes the
geographic area served by the existing stormwater infrastructure for the Project area, from capture of runoff
through final discharge points. The proposed Project would not cause a substantial change in the amount of
stormwater runoff from the Project site. As a result, the proposed Project would not generate additional
runoff that could combine with runoff from cumulative projects that could cumulatively combine to impact
drainage. Thus, cumulative impacts related to drainage would be less than significant.
Solid Waste: Cumulative projects in the area would increase solid waste generation and decrease the
available capacity of the nearby landfills. However, as with the proposed Project, cumulative projects have
been or would be required to conduct an environmental review and would be required to adhere to solid
waste regulations, which are aimed at reducing overall solid waste levels. Therefore, the increase in solid
waste from future buildout of the proposed Project would be less than cumulatively considerable and would
be less than significant.
Dry Utilities: The geographic scope of cumulative analysis for dry utilities is the service area for the Southern
California Edison (SCE), SoCalGas, AT&T and Cox Communications, which serve the Project area. Cumulative
impacts related to the provision of facilities for electricity, natural gas, and communications systems have
been evaluated throughout the EIR. Mitigation measures have been recommended in cases where
cumulatively considerable impacts associated with utilities infrastructure were identified. Therefore,
cumulatively considerable impacts associated with the provision of utility facilities to serve the Project would
be less than significant.
R. Wildfires
Impact WF-1 Finding: The Project is not located in or near State responsibility areas or lands classified as
very high fire hazard severity zones and would not substantially impair an adopted emergency response
plan or emergency evacuation plan (Initial Study at p. 65 and Draft EIR at p. 7-15). No impacts would occur.
Facts in Support of Findings: The Project site is currently developed as a commercial site and is surrounded
by other commercial developments. According to the CalFire Fire Hazard Severity Zone Map, the City of
Tustin contains very high fire severity zones in the northeast portion of the City (California Department of
Forestry and Fire Protection, 2023). The Project site is not located within or near State responsibility areas
City of Tustin 29
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Enderle Center Rezone Project CEQA Findings of Fact
or lands classified as very high fire hazard severity zones. Therefore, the project would result in no impact
due to wildfire hazard.
Impact WF-2 Finding: The Project is not located in or near State responsibility areas or lands classified as
very high fire hazard severity zones, and would not involve slope, prevailing winds, and other factors, that
could exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a
wildfire or the uncontrolled spread of a wildfire (Initial Study at p. 65 and Draft EIR at p. 7-15). No impacts
would occur.
Facts in Support of Findings: The Project site is not within a High Fire Hazard Severity Zone. The Project site
is flat and does not generally have prevailing winds or other factors that could exacerbate fire risks. The
proposed Project would not result in exposure of persons to pollutant concentrations from a wildfire.
Impact WF-3 Finding: The Project is not located in or near State responsibility areas or lands classified as
very high fire hazard severity zones and would not require the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may
exacerbate fire risk or that may result in temporary or ongoing impacts to the environment (Initial Study at
p. 65 and Draft EIR at p. 7-15). No impacts would occur.
Facts in Support of Findings: The Project site is not within a High Fire Hazard Severity Zone, and the
proposed Project does not include infrastructure that could exacerbate fire risks. The proposed Project would
connect to the existing utility infrastructure that is adjacent to the site. Thus, no impacts would result.
Impact WF-4 Finding: The Project is not located in or near State responsibility areas or lands classified as
very high fire hazard severity zones and would not expose people or structures to significant risks, including
downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage
changes (Initial Study at p. 65 and Draft EIR at p. 7-15). No impacts would occur.
Facts in Support of Findings: The Project site is not within a High Fire Hazard Severity Zone and is generally
flat area and does not contain or is adjacent to large slopes, and the proposed Project and related future
development would not generate large slopes. Thus, the Project would not result in risks related to wildfires
or risks related to downslope or downstream flooding or landslides after wildfires.
Wildfires Cumulative Findings: The Project would not result in cumulative impacts related to wildfires (Initial
Study at p. 65 and Draft EIR at p. 7-15).
Facts in Support of Findings: The Project is not located in or near State responsibility areas or lands
classified as very high fire hazard severity zones; and therefore, would not result in impacts related to
wildfires and no potential of a cumulative impacts would occur.
City of Tustin 30
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Enderle Center Rezone Project CEQA Findings of Fact
SECTION III
IMPACTS MITIGATED TO A LEVEL OF LESS THAN SIGNIFICANT
Based upon the Initial Study, the City determined that the Project would have a less -than -significant impact
with mitigation related to the following environmental topic areas and that no further analysis of these topics
was required in the EIR:
Biological Resources (migratory bird) • Geology and Soil (paleontological
Cultural Resources (archaeological resources)
resources)
Further, several additional environmental topics that were analyzed in the Draft EIR were determined to also
have a less -than -significant impact with mitigation.
The City hereby finds that mitigation measures have been identified in the Draft EIR that would avoid or
substantially lessen the following potentially significant environmental impacts to a less than significant level.
The potentially significant impacts and the mitigation measures that would reduce them to a less than
significant level are summarized below.
A. Biological Resources
Impact BIO-4 Finding: The Project would not interfere substantially with the movement of any native resident
or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or
impede the use of native wildlife nursery sites (Initial Study at p. 32 and Draft EIR at p. 7-3). Impacts would
be less than significant with mitigation incorporated.
Facts in Support of Findings: The Project site does not support conditions for migratory wildlife corridors or
linkages. The Project site is completely developed and surrounded by a roadway and developed land uses.
The site and surrounding areas do not provide function for wildlife land movement. Additionally, the
surrounding area is developed and urban. There are no rivers, creeks, or open drainages near the site that
could function as a wildlife corridor. Thus, implementation of the Project would not result in impacts related
to wildlife movement or wildlife corridors.
However, the Project site contains existing ornamental trees that could be used for nesting by common bird
species that are protected by the federal Migratory Bird Treaty Act (MBTA) and the California Fish and
Game Code Sections 3503.5, 3511, and 3515 during the avian nesting and breeding season that occurs
between February 1 and September 15. The provisions of the MBTA prohibit disturbing or destroying active
nests. Therefore, Mitigation Measure 1310-1 has been included to require that if commencement of vegetation
clearing for any future residential development project occurs between February 1 and September 15, a
qualified biologist shall conduct a nesting bird survey no more than 3 days prior to commencement of
activities to confirm the absence of nesting birds. With implementation of Mitigation Measure BIO-1, potential
impacts to nesting birds would be less than significant.
Biological Resources Cumulative Findings: The Project would not result in cumulatively considerable
impacts to biological resources. Impacts are less than significant with mitigation (Initial Study at p. 31 — 33
and Draft EIR at p. 7-2 through 7-4).
Facts in Support of Findings: With implementation of the mitigation measures identified in the Draft EIR to
implement the Migratory Bird Treaty Act, the proposed Project would not result in significant impacts related
to special -status species, jurisdictional waters, wildlife movement, local ordinances or regulations protecting
biological resources, habitat conservation plans, plant communities, and habitat fragmentation. Since the
Project would implement existing requirements and mitigation measures and would result in less than
significant impacts to biological resources, the Project could not combine with other projects within the City in
City of Tustin 31
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Enderle Center Rezone Project CEQA Findings of Fact
a manner that would result in cumulative impacts. Cumulative projects would be required to comply with
applicable survey requirements and mitigation for biological resources. Further, there are no projects that
would, in combination with the Project, produce a significant impact to biological resources.
Mitigation Measures
MM BI0-1: Migratory Bird Treaty Act. Prior to commencement of grading activities, the City Community
Development Department shall verify that, in the event that vegetation and tree removal activities occur
within the active breeding season for birds (February 1—September 15), the Project applicant (or their
Construction Contractor) shall retain a qualified biologist (meaning a professional biologist that is familiar
with local birds and their nesting behaviors) to conduct a nesting bird survey no more than 3 days prior to
commencement of construction activities.
The nesting survey shall include the Project site and areas immediately adjacent to the site that could
potentially be affected by Project -related construction activities, such as noise, human activity, and dust, etc.
If active nesting of birds is observed within 100 feet of the designated construction area prior to construction,
the qualified biologist shall establish an appropriate buffer around the active nests (e.g., as much as 500
feet for raptors and 300 feet for non -raptors [subject to the recommendations of the qualified biologist]),
and the buffer areas shall be avoided until the nests are no longer occupied and the juvenile birds can
survive independently from the nests.
Cultural Resources
Impact CUL-2 Finding: The Project would not cause a substantial adverse change in the significance of an
archaeological resource pursuant to CEQA Guidelines Section 15064.5. (Initial Study at p. 34 and Draft EIR
at p. 7-4)._Impacts are less than significant with mitigation.
Facts in Support of Findings: According to results of the cultural record search prepared for the Project, the
Project site does not contain any archaeological resources. The Project site is currently developed as a
commercial site and is surrounded by other commercial developments. The Project site is heavily disturbed
and does not currently contain any native undisturbed soils. However, the Project could facilitate future
construction at depths greater than previous excavation activities, which could result in the disturbance of
undisturbed native soils. Therefore, there is a low potential that future construction could result in inadvertent
discovery of a buried archeological resource. Mitigation Measure CUL-1 has been incorporated to mitigate
any potential impact to an archeological resource. In the event of an inadvertent discovery of a buried
archeological resource, work shall cease within 50 feet of the find until a qualified archaeologist from the
City or County List of Qualified Archaeologists has evaluated the find to determine whether the find
constitutes a "unique archaeological resource", and if the discovered resource(s) appears Native American
in origin, a Native American Monitor shall be contacted to evaluate any potential tribal cultural resource(s)
and shall have the opportunity to consult on appropriate treatment and curation of these resources. Prior to
the issuance of any permits for ground -disturbing activities that include the excavation of soils (including as
grading, excavation, and trenching), the City of Tustin shall ensure that all Project grading and construction
plans and specifications include requirement to halt construction activity and contact an archaeologist.
Cultural Resources Cumulative Findings: Impacts related to archaeological resources and human remains
would be less than significant with compliance with existing regulations and mitigation measures (Initial Study
at p. 34 — 35 and Draft EIR at p. 7-3 through 7-4).
Historic Resources: The Project site does not contain any historic resources. Therefore, the Project would
not result in impacts to a historical resource that could become cumulatively considerable. No cumulative
historic resource impacts would occur.
Archaeological Resources: The Project site is heavily disturbed and does not currently contain any
native undisturbed soils. Therefore, potential impacts related to archaeological resources are not
anticipated. However, mitigation has been included to reduce the potential of the Project to contribute
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to a significant cumulative impact to archaeological resources in the case that a potential resource has
been uncovered. With compliance with existing regulations and mitigation, cumulatively considerable
impacts would be less than significant.
Disturbance of Human Remains: Mandatory compliance with the provisions of California Health and
Safety Code § 7050.5, Public Resources Code § 5097 et seq., and CEQA Guidelines Section 15064.5,
would assure that the Project, in addition to all development projects, treat human remains that may be
uncovered during development activities in accordance with prescribed, respectful and appropriate
practices, thereby avoiding significant cumulative impacts.
Mitigation Measures
MM CUL-1: Inadvertent Discovery. In the event that potential archaeological resources are discovered
during excavation, grading, or construction activities, work shall cease within 50 feet of the find until a
qualified archaeologist from the City or County List of Qualified Archaeologists has evaluated the find to
determine whether the find constitutes a "unique archaeological resource," as defined in Section 21083.2(g)
of the California Public Resources Code. Any resources identified shall be treated in accordance with
California Public Resources Code Section 21083.2(g).
If the discovered resource(s) appears Native American in origin, a Native American Monitor shall be
contacted to evaluate any potential tribal cultural resource(s) and shall have the opportunity to consult on
appropriate treatment and curation of these resources. The discovery would also be reported to the City
and the South Central Coastal Information Center (SCCIC).
Prior to the issuance of any permits for ground -disturbing activities that include the excavation of soils
(including as grading, excavation, and trenching), the City of Tustin shall ensure that all Project grading and
construction plans and specifications include requirement to halt construction activity and contact an
archaeologist as specified above.
C. Geology and Soil
Impact GEO-1 iii Finding: The Project would not directly or indirectly cause potential substantial adverse
effects, including the risk of loss, injury, or death involving seismic -related ground failure, including
liquefaction (Initial Study at p. 39 and Draft EIR at p. 7-6). Impacts are less than significant with mitigation.
Facts in Support of Findings: According to the California Geological Survey available fault maps, the
Project is approximately 1.25 miles from the nearest liquefaction zone in the City of Orange. The southern
portion of Tustin is also identified as partially within a liquefaction zone. Additionally, all future projects
implemented on the Project site would be required to conduct a project -specific geotechnical investigation
to ensure that the site's soils are adequate for the construction and operation of the proposed project. Future
projects would be required to implement measures identified within the project -specific geotechnical
investigation (MM GEO-1). The Project site is outside of a liquefaction zone and would be required to conduct
project -specific geotechnical investigations at the time that the project is proposed; therefore, the Project
would result in a less -than -significant impact with mitigation.
Impact GEO-3 Finding: The Project would not be located on a geologic unit or soil that is unstable, or that
would become unstable as a result of the project, and potentially result in on- or offsite landslide, lateral
spreading, subsidence, liquefaction, or collapse (Initial Study at p. 41 and Draft EIR at p. 7-5). Impacts are
less than significant with mitigation.
Facts in Support of Findings: Lateral spreading is a type of liquefaction -induced ground failure associated
with the lateral displacement of surficial blocks of sediment resulting from liquefaction in a subsurface layer.
Once liquefaction transforms the subsurface layer into a fluid mass, gravity plus the earthquake inertial
forces may cause the mass to move downslope towards a free face (such as a river channel or an
embankment). Lateral spreading may cause large horizontal displacements and such movement typically
damages pipelines, utilities, bridges, and structures. The Project site is outside of a zone identified as
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Enderle Center Rezone Project CEQA Findings of Fact
susceptible to liquefaction. Further, the Project site then has a low potential for lateral spreading. However,
all future projects would be required to conduct a project -specific geotechnical investigation to ensure that
the site's soils are adequate for the construction and operation of the proposed project. Future projects would
be required to implement measures identified within the project -specific geotechnical investigation (MM
GEO-1).
Subsidence is a general lowering of the ground surface over a large area that is generally attributed to
lowering of the ground water levels within a groundwater basin. Localized or focal subsidence or settlement
of the ground can occur as a result of an earthquake motion in an area where groundwater in basin is
lowered. The United States Geological Survey (USGS) has surveyed the state for areas of recorded
subsidence —historical and current —across California. According to the USGS Areas of Subsidence in
California Map, the Project site is within an area of subsidence as a result of excessive groundwater pumping.
As described above, all future projects implemented through the proposed housing overlay would be
required to conduct a project -specific geotechnical investigation to ensure that the site's soils are adequate
for the construction and operation of the proposed project. Future projects would be required to implement
measures identified within the project -specific geotechnical investigation (MM GEO-1). Therefore, the Project
would result in a less -than -significant impact with mitigation on the risk of landslide, lateral spreading,
subsidence, liquefaction or collapse.
Impact GE04 Finding: The Project may be located on expansive soil, as defined in Table 1 8-1-B of the
Uniform Building Code (1994), creating substantial direct or indirect risks to life or property (Initial Study at
p. 41 and Draft EIR at p. 7-8). Impacts are less than significant with mitigation.
Facts in Support of Findings: The Project site is currently developed as a commercial site and is surrounded
by other commercial developments. All future projects would be required to comply with applicable Federal,
State, and local policies and regulations established to prevent or reduce impacts due to expansive soil,
including Policy 8.5 of the Conservation/Open Space/Recreation Element, which requires City review of
threats from expansive soils during the development review process. Further, if necessary, geological
investigations would be prepared and implemented for each future project to reduce significant impacts
(MM GEO-1). Therefore, the project would result in a less -than -significant impact with mitigation.
Mitigation Measures
MM GEO-1: All future projects implemented through the proposed housing overlay would be required to
conduct a project -specific geotechnical investigation to ensure that the site's soils are adequate for the
construction and operation of the proposed project. Future projects would be required to implement measures
identified within the project -specific geotechnical investigation.
D. Noise
Impact N0I-1 Finding: The Project would not generate a substantial temporary or permanent increase in
ambient noise levels in excess of standards established in the local general plan or noise ordinance, or
applicable standards of other agencies (Draft EIR at p. 5.5-14). Impacts are less than significant with
mitigation.
Facts in Support of Findings:
Construction: Per the Tustin City Code Section 4616, construction activities are allowed only between the
hours of 7:00 a.m. and 6:00 p.m., Monday through Friday, and 9:00 a.m. to 5:00 p.m. on Saturdays, with
no activity allowed on Sundays and City -observed federal holidays. Construction activities for future buildout
would be required to occur within the City's designated hours. Thus, future buildout construction activities
would be in compliance with the City's construction -related noise standards.
While construction noise would vary, it is expected that composite noise levels during construction at the
nearest residential uses south of the Project would reach 70 dBA Leq. These predicted noise levels would
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Enderle Center Rezone Project CEQA Findings of Fact
only occur when all construction equipment is operating simultaneously and therefore, are conservative
assumptions. While construction -related short-term noise levels have the potential to be higher than existing
ambient noise levels in the Project area under existing conditions, the noise impacts would no longer occur
once construction is completed. As shown on Draft EIR Table 5.5-7, construction noise from future buildout of
the proposed Project at the nearby receptor locations would range from 67 to 70 dBA Leq, which would not
exceed the 90 dBA Leq and 100 dBA Leq 1 -hour construction noise level criteria as established by the FTA
for residential and commercial land uses. Therefore, impacts related to construction noise would be less than
significant.
Operation:
Traffic Noise Impacts. Buildout of the proposed Project is anticipated to generate approximately 4,412 net
new ADT, including 313 new trips during the AM peak hour and 393 new trips during the PM peak hour.
Regional access to the Project site is provided by 1-55. Local access to the site is provided via 17th Street,
Yorba Street, Enderle Center Drive, and Vanderberg Lane. Draft EIR Table 5.5-8 provides the traffic noise
levels for the existing with and without Project scenarios and opening year with and without Project, which
shows that the increase in Project -related traffic noise would be no greater than 2.3 dBA from existing
baseline conditions which is below the threshold of a 3.0 dBA noise level increase. Therefore, traffic noise
impacts from buildout of the proposed Project on off -site sensitive receptors would be less than significant.
Stationary Noise Impacts. Nearby land uses would be potentially exposed to stationary -source noise impacts
from onsite heating, ventilation, and air conditioning (HVAC) equipment and truck deliveries and loading
and unloading activities. It is expected that on -site stationary sources would meet the City of Tustin maximum
noise level standards. However, given that specific details related to stationary impacts of future
development within Enderle Center are not known at this time, and will not be known until a development
project is proposed, Mitigation Measure NOI-1 (MM NOI-1) is included. Mitigation Measure NOI-1 would
require all future development projects to prepare a project -specific Acoustical Report to determine whether
any proposed exterior noise sensitive areas would experience noise levels greater than 65 dBA CNEL or
interior noise levels of 45 dBA CNEL; and to identify any noise reduction features for the proposed
development (e.g., upgraded windows with Sound Transmission Class (STC) ratings of 30-35). Additionally,
the Final Acoustical Report shall confirm that proposed siting of noise -generating stationary sources, if any,
will not result in an exceedance of applicable noise thresholds at surrounding land uses. Thus, with
implementation of MM NOI-1, impacts related to stationary noise impacts would be less than significant.
Noise Cumulative Findings: The Project would not result in cumulative impacts related to noise with
incorporation of mitigation (Draft EIR at p. 5.5-21).
Facts in Support of Findings: Future development of the proposed Project in combination with the related
projects would result in an increase in construction -related and traffic -related noise. However, Tustin City
Code Article 4, Chapter 6, Section 4616 limits noise producing construction activities to the hours of 7:00 AM
and 6:00 PM on weekdays, between 9:00 AM and 5:00 PM on Saturdays, any anytime on Sunday or City -
observed federal holidays. Also, construction noise and vibration are localized in nature and decrease
substantially with distance. As shown on Draft EIR Figure 5-1, there are no cumulative projects adjacent to
or within hearing distance of the Project site.
The Project is solely a change in regulations to implement the City's certified Housing Element, so no
construction is currently proposed. However, a future project is anticipated to occur between October 2024
and October 2029, which would involve construction. Due to the distance of cumulative development projects,
is unlikely construction activities of the proposed Project would combine with other construction noise. Thus,
cumulative noise and vibration impacts associated with construction activities would be less than significant.
Cumulative traffic -generated noise impacts have been assessed based on the contribution of the proposed
Project traffic volumes on the roadways in the Project vicinity, which determined that buildout of the proposed
Project would result in noise levels much lower than the 3 dBA threshold.
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Enderle Center Rezone Project CEQA Findings of Fact
However, given that specific details related to stationary impacts of future development within The Market
Place are not known at this time, and will not be known until a development project is proposed, Mitigation
Measure NOI-1 (MM NOI-1) is included. Mitigation Measure NOI-1 would require all future development
projects to prepare a project -specific Acoustical Report to determine whether any proposed exterior noise
sensitive areas would experience noise levels greater than 65 dBA CNEL or interior noise levels of 45 dBA
CNEL; and to identify any noise reduction features for the proposed development (e.g., upgraded windows
with Sound Transmission Class (STC) ratings of 30-35). Therefore, the Project would not result in a
cumulatively considerable impact when combined with existing and future development. Cumulative impacts
would be less than significant.
Mitigation Measures
MM NOW: All future development shall prepare a project -specific Final Acoustical Report to confirm
whether any proposed exterior noise sensitive areas would experience noise levels greater than 65 dBA
CNEL and whether interior noise levels would exceed 45 dBA CNEL, and identify any noise reduction features
for the proposed development (e.g. upgraded windows with Sound Transmission Class (STC) ratings of 30-
35). Additionally, the Final Acoustical Report shall confirm that proposed siting of noise -generating stationary
sources, if any will not result in an exceedance of applicable noise thresholds at surrounding land uses.
E. Tribal Cultural Resources
Impact TCR-1 Finding: The Project would not cause a substantial adverse change in the significance of a
tribal cultural resource (TCR), defined in Public Resources Code section 21074 as either a site, feature, place,
cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred
place, or object with cultural value to a California Native American tribe, and that is:
• Listed or eligible for listing in the California Register of Historical Resources, or in a local register of
historical resources as defined in Public Resources Code section 5020.1(k); or
• A resource determined by the lead agency, in its discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.
(Draft EIR at p. 5.10-5). Impacts are less than significant with mitigation incorporated.
Facts in Support of Findings: Project construction would include excavation at depths that could reach native,
undisturbed soils that may contain unknown tribal cultural resources. A Sacred Lands File search yielded
negative results for known tribal cultural resources or sacred lands within the Project area. The City sent
notices to the Native American tribes provided by the NAHC on August 28, 2023, and October 26, 2023,
regarding the Project.
One response was received from the Gabrieleno Band of Mission Indians — Kizh Nation on November 14,
2023. The tribe requested to consult over email and provided mitigation measures to be incorporated into
the Project. As a result, Mitigation Measure TCR-1 is included, which requires prior to the commencement of
ground -disturbing activities, retainment of a Native American monitor with preference given to the consulting
tribe. In addition, Mitigation Measure TCR-2 is incorporated and provides procedures to follow in case of
an inadvertent TCR discovery. Mitigation Measure TCR-3 is also incorporated which complies with State
Health and Safety Code Section 7050.5, which states that no further disturbance may occur in the vicinity of
the body until the County Coroner has made a determination of origin and disposition pursuant to Public
Resources Code Section 5097.98. These measures would ensure the avoidance of impacts to buried TCRs
that may be present onsite.
Although no construction is proposed as part of this Project, future development associated with the Housing
Zone would be required to adhere to Mitigation Measures TCR-1, TCR-2, and TCR-3, which would ensure
that potential impacts a result of the inadvertent discovery of TCRs during future development would be less
than significant.
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Enderle Center Rezone Project CEQA Findings of Fact
Tribal Cultural Resources Cumulative Findings: The Project would not result in cumulative impacts related
to tribal cultural resources (Draft EIR at p. 5.10-6).
Facts in Support of Findings: Cumulative impacts to TCRs would be reduced by compliance with applicable
regulations and consultations required by SB 18 and AB 52. The Project site and vicinity is not known to
contain TCRs; however, Mitigation Measures TCR-1, TCR-2 and TCR-3 would be implemented to ensure that
impacts would not occur in the case of an inadvertent discovery of a potential TCR. These mitigation measures
would ensure that the proposed Project would not contribute to a cumulative loss of TCRs. Therefore,
cumulative impacts would be less than significant
Mitigation Measures
MM TCR-1: Retain a Native American Monitor Prior to Commencement of Ground -Disturbing Activities
a. Prior to the issuance of demolition or grading permits for any projects that would disturb previously
undisturbed soils (native soils) or soils that have native fill, the project applicant/developer shall
retain a Native American Monitor, with first preference given to the Gabrieleno Band of Mission
Indians — Kizh Nation, who responded to the City's request for consultation on November 14, 2023
(first preference Tribe, Tribe). The applicant/developer shall allow 45 days from the initial contact
with the first preference tribe to enter into a contract for monitoring services. If the
applicant/developer is unable to contact the Kizh Nation after three documented attempts or is
unable to secure an agreement, the applicant shall report to the lead agency, and the lead agency
will contact the Kizh Nation to validate that the parties were unable to enter into an agreement. If
the applicant/developer can demonstrate they were unable to secure an agreement with the first
preference tribe, as validated and documented by the Community Development Department in
writing, or if the contracted tribe fails to fulfill its obligation under the contract terms, then the
applicant/developer may retain an alternative qualified tribal monitor from a culturally affiliated
tribe, or if none are available, an otherwise qualified archaeologist may be retained as +approved
by the City.
The monitor shall be retained prior to the issuance of a demolition permit or grading permit, and
the commencement of any development related "ground -disturbing activity" for the subject project
at all project locations (i.e., both on -site and any off -site locations that are included in the project
description/definition and/or required in connection with the project, such as public improvement
work). "Ground -disturbing activity" shall include, but is not limited to, demolition, pavement removal,
auguring, grubbing, boring, grading, excavation, drilling, and trenching for the purposes of
reconstruction and new development. "Ground -disturbing activity" shall not include removal or
maintenance of existing small facilities and utilities -such as potholing, tree removal, and parking lot
maintenance. This mitigation measure does not apply to activities that would only disturb soils made
up of artificial fill, as verified by a soils or geotechnical report.
b. A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the
commencement of any ground -disturbing activity, or the issuance of any permit necessary to
commence a ground -disturbing activity.
c. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground -
disturbing activities, the type of construction activities performed, locations of ground -disturbing
activities, soil types, and cultural -related materials, of significance to the Kizh Nation. Monitor logs
will identify and describe any discovered; Native American cultural and historical artifacts, remains,
places of significance, etc., (collectively, tribal cultural resources, or "TCR"), as well as any discovered
Native American (ancestral) human remains and associated grave goods. Copies of monitor logs will
be provided to the project applicant/lead agency upon written request to the consulting tribe. If a
monitor is selected from a tribe other than the Kizh Nation, the Kizh Nation shall be contacted if any
discoveries are found.
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Enderle Center Rezone Project CEQA Findings of Fact
d. On -site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to
the monitor from a designated point of contact for the project applicant/lead agency that all
ground -disturbing activities and phases that may involve ground -disturbing activities and that have
the potential to impact local TCRs on the project site or in connection with the project are complete;
or (2) the monitor determines based on field observations that there is no likelihood of encountering
intact TCRs. Monitoring may be reduced in extent or frequency as determined appropriate by the
monitor.
MM TCR-2: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/Non-
Ceremonial)
Upon discovery of any TCRs, all ground -disturbing activities in the immediate vicinity of the discovery shall
cease (i.e., surrounding 50 feet) and shall not resume until the discovered TCR has been assessed by the
tribal monitor and consulting archaeologist. If the monitor is other than the Gabrieleno Band of Mission
Indians — Kizh Nation, the Kizh Nation shall be contacted and the monitor and/or Kizh Nation will recover
and retain all discovered TCRs in the form and/or deemed appropriate, in agreement with Kizh Nation,
including for educational, cultural and/or historic purposes.
MM TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial
Objects
a. Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and
in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods
in Public Resources Code Section 5097.98, are also to be treated according to this statute.
b. If Native American human remains are discovered or recognized on the project site, then Health and
Safety Code Section 7050.5 shall be followed.
c. Human remains and associated grave goods shall be treated in the same manner per California Public
Resources Code section 5097.98(d)(1) and (2).
d. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human
remains and/or grave goods.
e. Any discovery of human remains/grave goods shall be kept confidential to prevent further disturbance.
S. Utilities and Service Systems
Impact UT-1 Finding: The Project would not require or result in the relocation or construction of new water
or wastewater facilities, or expansion of existing facilities, the construction of which could cause significant
environmental effects (Draft EIR at p. 5.1 1-9 and 5.1 1-14). Impacts are less than significant with mitigation.
Facts in Support of Findings:
Water: The water facilities currently serving the Project site would likely be sufficient to accommodate the
anticipated 118,474 SF of additional nonresidential development proposed by the Project. However, future
residential projects proposed under the Project could necessitate further water infrastructure, including new
water connections, water pumps, and other improvements to water utilities within the existing Project site
footprint and within adjacent utility right-of-way beneath 17t' Street, Yorba Street, Enderle Center Drive
and Vandenberg Lane.
Future implementation of development projects pursuant to the proposed Project would include installation
of onsite water infrastructure and new connections to the water distribution system that would be sized to
accommodate the increased water demand of new project -specific development on a project -by -project
basis. Water supply design specifications for each future site -specific development project would be
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Enderle Center Rezone Project CEQA Findings of Fact
required to comply with the City of Tustin standards (per the California Building Code) regarding
requirements for design and operation of water distribution facilities and would be verified during plan
check. Additionally, Mitigation Measure UT-1 is incorporated into the Project to require future projects to
coordinate with the City and prepare a capacity analysis of existing water utilities in the area to ensure
conveyance and pressure is adequate. The capacity analysis is required to be reviewed and approved by
the City prior to the approval of construction permits.
Under the City's normal development review procedure for individual projects, the City determines the actual
water system design requirements of each site -specific development project, and the needs for any
improvements to the existing water supply infrastructure would be identified and required by the City
construction permit. The temporary construction of needed water system improvements would occur along
existing pipeline alignments and within existing street rights -of -way and would be required to comply with
all City standards regarding construction noise, air quality and dust suppression mitigation requirements,
erosion control (through the required SWPPP) and temporary construction traffic controls. As a result,
potential impacts related to buildout of the proposed Project would not result in construction of new or
expanded water facilities that would result in a significant environmental effect. Therefore, impacts would
be less than significant.
Wastewater: Future residential projects could necessitate further wastewater infrastructure, including new
wastewater connections, sewer pumps, and other improvements to wastewater utilities within the existing
Project site footprint and within adjacent utility right-of-way beneath 17'" Street, Yorba Street, Enderle
Center Drive, and Vandenberg Lane. Local improvements are anticipated, and extensive offsite utility
improvements are not assumed for the Project.
Future implementation of development projects pursuant to the proposed Project would include installation
of onsite wastewater infrastructure and new connections to the wastewater distribution system that would be
sized to accommodate the increased wastewater demand of new project -specific development on a project -
by -project basis. Wastewater supply design specifications for each future site -specific development project
would be required to comply with the City of Tustin standards (per the California Building Code) regarding
requirements for design and operation of wastewater distribution facilities and would be verified during
plan check. Additionally, Mitigation Measure UT-2 is incorporated into the Project to require future projects
to prepare a capacity analysis of existing wastewater utilities in the area to ensure conveyance and pressure
is adequate. The capacity analysis is required to be reviewed and approved by the City prior to the
approval of construction permits.
Under the City's normal development review procedure for individual projects, the City determines the actual
wastewater system design requirements of each site -specific development project, and the needs for any
improvements to the existing wastewater supply infrastructure would be identified and required by the City
construction permit. The temporary construction of needed wastewater system improvements would occur
along existing pipeline alignments and within existing street rights -of -way, and construction sites and would
be required to comply with all City standards regarding construction noise, air quality and dust suppression
mitigation requirements, erosion control (through the required SWPPP) and temporary construction traffic
controls. As a result, potential impacts related to buildout of the proposed Project would not result in
construction of new or expanded wastewater facilities that would result in a significant environmental effect
with implementation of mitigation.
Impact UT-3 Finding: The Project would not result in a determination by the wastewater treatment provider
that would serve the Project that it has inadequate capacity to serve the projects projected demand in
addition to the providers existing commitments (Draft EIR at p. 5.11 -15). Impacts are less than significant
with mitigation.
Facts in Support of Findings: Future buildout of the proposed Project would result in an increase of
wastewater generation from the site. Using East Orange County Water District's wastewater flow factors,
residential uses use approximately 100 gallons per day per dwelling unit (gpd/du) and non-residential uses
use approximately 2,500 gallons per 1 per day per acre (gpd/ac). Therefore, the estimated 413 residential
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Enderle Center Rezone Project CEQA Findings of Fact
dwelling units and 118,474 SF of nonresidential employees would generate an additional wastewater
demand of 21,100 gallons per day or 23.7 AFY.
Wastewater from the Project Site is treated at the Orange County Sanitation District's wastewater treatment
plant in Fountain Valley (Plant No. 1). Plant No. 1 has a total rated primary capacity of 108 MGD and a
secondary treatment capacity of 80 MGD. Thus, the amount of wastewater that would be generated by the
proposed Project is less than 1 percent of Plant No. 1's total remaining daily treatment capacity. As a result,
the wastewater treatment plant serving the Project would have adequate capacity to serve the proposed
Project's demand in addition to existing service commitments, and impacts would be less than significant.
Additionally, Mitigation Measure UT-2 is incorporated into the Project to require future projects to coordinate
with East Orange County Water District and prepare a capacity analysis of existing wastewater utilities in
the area to ensure conveyance and pressure is adequate. The capacity analysis is required to be reviewed
and approved by East Orange County Water District and the City prior to the approval of construction
permits. With implementation of Mitigation Measure UT-2, impacts would be less than significant.
Mitigation Measures
MM UT-1: Future proposed Projects shall prepare capacity analyses of existing water utilities in the area to
ensure conveyance and pressure is adequate for future projects proposed. The developer shall then identify
infrastructure improvements necessary for the proposed development. The developer will be responsible for
preparing a capacity analysis in coordination with the City. The capacity analysis and infrastructure
improvements shall be reviewed and approved by the City prior to approval of the construction permit.
MM UT-2: Future proposed Projects shall prepare capacity analyses of existing sewer utilities in the area to
ensure conveyance and pressure is adequate for future projects proposed. The developer shall then identify
infrastructure improvements necessary for the proposed development. The developer will be responsible for
preparing a capacity analysis in coordination with the EOCWD and the City. The developer shall then submit
the sewer capacity analysis to the Orange County Sanitation District (OC San) for review and verification
that there is available sewer capacity. The capacity analysis and infrastructure improvements shall be
reviewed and approved by EOCWD, OC San, and the City prior to approval of the construction permit.
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Enderle Center Rezone Project CEQA Findings of Fact
SECTION IV
SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL IMPACTS
Public Resources Code section 21002 states that "it is the policy of the state that public agencies should not
approve projects as proposed if there are feasible alternatives or feasible mitigation measures available
which would substantially lessen the significant environmental effects of such projects. The Legislature further
finds and declares that in the event specific economic, social, or other conditions make infeasible such project
alternatives or such mitigation measures, individual projects may be approved in spite of one or more
significant effects thereof."
Section 15364 of the State CEQA Guidelines defines "feasible" as "capable of being accomplished in a
successful manner within a reasonable period of time, taking into account economic, environmental, legal,
social, and technological factors."
The City Council hereby finds that, despite the incorporation of feasible measures outlined in the Final EIR,
the following impacts cannot be fully mitigated to a less than significant level. Despite these significant and
unavoidable impacts, the City nevertheless approves the Project because of the benefits described in the
Statement of Overriding Considerations included herein.
A. Air Quality
Impact AQ-3 Finding: The Project would expose sensitive receptors to substantial pollutant concentrations
(Draft EIR at p. 5.1-26). Impacts would be significant and unavoidable.
Facts in Support of Findings:
CO Hotspots: Ambient CO levels monitored at the Anaheim monitoring station, the closest station to the City
of Tustin, showed a highest recorded 1-hour concentration of 2.4 ppm (the State standard is 20 ppm) and a
highest 8-hour concentration of 1.7 ppm (the State standard is 9 ppm) during the past 3 years (Draft EIR
Table 5.1-3). The highest CO concentrations would normally occur during peak traffic hours; hence, CO
impacts calculated under peak traffic conditions represent a worst -case analysis.
Full buildout of development consistent with the Project would generate 11,470 net new ADT in the immediate
vicinity of the opportunity sites and would result in 757 net new AM peak -hour trips and in 1,041 net new
PM peak -hour trips. Given the extremely low level of CO concentrations in the City, the project -related
vehicles are not expected to contribute significantly or result in the CO concentrations exceeding the State
or federal CO standards. Therefore, the Project would result in a less than significant impact.
Localized Air Quality Impacts: The results of the localized significance thresholds (LST) analysis, summarized
in Draft EIR Table 5.1-1 1, indicate that the Project would not result in an exceedance of the SCAQMD LSTs
during Project construction. However, net new emissions associated with the future development of the
proposed Project would exceed the SCAQMD LSTs for PMio during operational activities. As shown in Draft
EIR Table 5.1-12, the majority of the PM10 emissions are associated with mobile sources from Project -related
vehicle trips. Emissions of motor vehicles are controlled by State and federal standards, and the project has
no control over these standards. Furthermore, this analysis considers the most conservative scenario for future
development allowed under the proposed Project, as details regarding future projects are unknown, and it
is not known whether development would occur. Although future development details are unknown,
implementation of Mitigation Measure AQ-1 would require a project -specific assessment of potential
localized impacts for future projects and if future projects exceed the applicable LST thresholds, a dispersion
modeling analysis would be necessary to calculate health risk from project implementation. While Mitigation
Measure AQ-1 would serve to reduce localized emissions associated with buildout of the project, localized
emission impacts would remain significant and unavoidable.
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Air Quality Cumulative Findings: The Project would result in cumulatively significant and unavoidable
impacts related to air quality (Draft EIR at p. 5.1-30).
Facts in Support of Findings: As described previously, per SCAQMD's methodology, if an individual project
would result in air emissions of criteria pollutants that exceeds the SCAQMD's thresholds for project -specific
impacts, then it would also result in a cumulatively considerable net increase of these criteria pollutants.
As discussed in Impact AQ-3 the Project would not result in an exceedance of the SCAQMD LSTs during
project construction. However, net new emissions associated with the future development of the proposed
Project would exceed the SCAQMD LSTs for PM10 during operational activities. While Mitigation Measure
AQ-1 would serve to reduce localized emissions associated with buildout of the project, localized emission
impacts would remain significant and unavoidable. Therefore, impacts on human health risks would be
cumulatively considerable and would be significant and unavoidable.
Mitigation Measures
Mitigation Measure AQ-1. Prior to building permit approval by the City of Tustin (City) for future
development projects, project applicants shall prepare and submit a technical assessment evaluating
potential project -related air quality impacts, including a localized impacts analysis, to the City for review
and approval. The analysis shall be prepared in conformance with South Coast Air Quality Management
District (SCAQMD) methodology. If project -related emissions exceed applicable SCAQMD thresholds of
significance, the City shall require that applicants for new development projects incorporate mitigation
measures to reduce emissions. The identified measures shall be included as part of the conditions of approval.
Additionally, if project -related localized emissions exceed the SCAQMD's thresholds, a dispersion modeling
analysis shall be conducted to calculate potential health risk from project implementation, and all necessary
mitigation measures shall be implemented.
B. Greenhouse Gas Emissions
Impact GHG-1 Finding: The Project would generate GHG emissions, either directly or indirectly, that may
have a significant impact on the environment (Draft EIR at p. 5.3-1 1). Impacts would be significant and
unavoidable.
Facts in Support of Findings: According to SCAQMD, a project would have less than significant GHG
emissions if it would result in operational -related GHG emissions of less than 3,000 MT CO2e/yr. Based on
the analysis results, full buildout of the development envisioned under the Project would result in a net
increase of 12,804 MT CO2e/yr, which would exceed the SCAQMD threshold of 3,000 MT CO2e/yr.
Therefore, consistent with the SCAQMD's interim guidance, the following discussion compares the proposed
Project to the efficiency -based threshold.
The development of A13 housing units would result in approximately 1,189 additional residents based on
the estimated 2.88 persons per household in Tustin. In addition, the proposed Project would include an
additional 39,087 sq ft of restaurant use, 54,328 sq ft of retail and service use, and 25,051 sq ft of office
use. Future development, as envisioned under the proposed Project, would result in 365 new employees. The
total service population (residents plus employees) would be 1,554 persons. The proposed Project would
result in per service population emissions of 8.2 metric tons of CO2 per year per service population (MT
CO2e/yr/SP), which would exceed the SCAQMD's plan -level screening threshold of 4.1 MT CO2e/yr/SP.
Therefore, the proposed Project would generate significant GHG emissions that would have a significant
effect on the environment. As such, implementation of Mitigation Measure GHG-1 would require future
residential projects to incorporate suggested mitigation measures to reduce GHG emissions. Additionally,
implementation of Mitigation Measure GHG-2 would require a project -specific assessment of potential GHG
impacts and implementation of feasible mitigation measures to reduce GHG emissions for future projects
allowed under the proposed Project. While Mitigation Measure GHG-1 and GHG-2 would serve to reduce
GHG emissions associated with buildout of the Project, GHG emission impacts would remain significant and
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Enderle Center Rezone Project CEQA Findings of Fact
unavoidable because compliance with future efficiency targets cannot be assured and not enough
information is known regarding future projects to recommend further mitigation.
Impact GHG-2 Finding: The Project would conflict with an applicable plan, policy, or regulation of an
agency adopted for the purpose of reducing the emissions of GHGs (Draft EIR at p. 5.3-13). Impacts would
be significant and unavoidable.
Facts in Support of Findings: Future development implemented in accordance with the proposed Housing
Overlay Zone would accommodate planned regional housing growth included in the SCAG RHNA and would
be required to adhere to the General Plan. Therefore, since the purpose of the proposed Project is to
accommodate planned regional housing growth included in the SCAG RHNA, the proposed Project would
not exceed the growth assumptions in the SCAG's RTP/SCS or the AQMP. Based on the nature of the
proposed Project, it is anticipated that implementation of the proposed Project would not interfere with
SCAG's ability to implement the regional strategies outlined in the RTP/SCS. Implementing SCAG's RTP/SCS
will greatly reduce the regional GHG emissions from transportation, helping to achieve statewide emissions
reduction targets. The proposed Project would not interfere with SCAG's ability to achieve the region's GHG
reduction target of 19 percent below 2005 per capita emissions levels by 2035.
Although the proposed Project would be consistent with the identified measures and goals from the 2022
Scoping Plan and 2024-2050 RTP/SCS, the proposed Project would result in a significant and unavoidable
impact for GHG emissions based on SCAQMD thresholds. As such, the proposed Project would not comply
with existing State regulations adopted to achieve the overall GHG emissions reduction goals identified in
the 2022 Scoping Plan, EO B-30-15, and AB 197 and would not be consistent with applicable State plans
and programs designed to reduce GHG emissions. Therefore, the proposed Project would conflict with
applicable plans, policies, and regulations adopted for the purpose of reducing the emissions of GHGs and
impacts would be significant and unavoidable.
Greenhouse Gas Cumulative Findings: The Project would result in significant and unavoidable cumulative
impacts related to GHG emissions (Draft EIR at p. 5.3-16).
Facts in Support of Findings: The analysis of GHG emission impacts under CEQA contained in this Draft EIR
effectively constitutes an analysis of a project's contribution to the cumulative impact of GHG emissions. GHG
emissions associated with the buildout under the proposed Project would exceed the SCAQMD thresholds of
3,000 MT CO2e/yr and 4.1 MT CO2e/yr/SP. Since GHG is a global issue, it is unlikely that the proposed
Project would generate enough GHG emissions to influence GHG emissions on its own; however, because
Project -related CO2e emissions would exceed the SCAQMD's thresholds, the proposed Project would have
a significant contribution to cumulatively considerable GHG emission impacts.
Mitigation Measures
Mitigation Measure GHG-1. Prior to issuance of a building permit, the City shall require that applicants for
new residential development projects incorporate mitigation measures to reduce GHG emissions. The
identified measures shall be included as part of the project's approval. Possible mitigation measures to
reduce operational emissions could include, but are not limited to, the following:
• Increase in insulation such that heat transfer and thermal bridging is minimized;
• Limit air leakage through the structure and/or within the heating and cooling distribution system;
• Use of energy -efficient space heating and cooling equipment;
• Installation of dual -paned or other energy efficient windows;
• Use of interior and exterior energy efficient lighting that exceeds the incumbent California Title 24
Energy Efficiency performance standards;
• Installation of automatic devices to turn off lights where they are not needed;
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• Application of an exterior paint and surface color palette that emphasizes light and off-white colors
that reflect heat away from buildings;
• Design of buildings with "cool roofs" using products certified by the Cool Roof Rating Council, and/or
exposed roof surfaces using light and off-white colors;
• Design of buildings to accommodate photo -voltaic solar electricity systems or the installation of photo-
voltaic solar electricity systems;
• Installation of ENERGY STAR -qualified energy -efficient appliances, heating and cooling systems, office
equipment, and/or lighting products.
• Landscaping palette emphasizing drought tolerant plants;
• Use of water -efficient irrigation techniques;
• U.S. EPA Certified WaterSense-labeled or equivalent faucets, high -efficiency toilets (HETs), and water -
conserving shower heads.
Mitigation Measure GHG-2. Prior to discretionary approval by the City of Tustin (City) for residential
development projects subject to California Environmental Quality Act (CEQA) review, project applicants shall
prepare and submit a technical assessment evaluating potential project -related greenhouse gas (GHG)
impacts to the City for review and approval. The evaluation shall be prepared in conformance with South
Coast Air Quality Management District (SCAQMD) methodology. If project -related GHG emissions exceed
applicable SCAQMD thresholds of significance and/or Statewide GHG reduction targets, project -specific
measures shall be identified and implemented, which would be reviewed and confirmed by the City.
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SECTION V
ROWTH-INDUCING IMPACTS AND COMMITMENT OF RESOUR
Section 151 26.2(e) of the State CEQA Guidelines requires the EIR address the growth -inducing impact of
the Project. Draft EIR Section 5.6 evaluates the potential for the proposed Project to affect the environment
from employment or population growth, or the construction of additional housing, either directly or indirectly.
Impact Growth-1 Finding: The Project would not directly or indirectly foster economic or population growth,
or the construction of additional housing, in the surrounding environment (Draft EIR at p. 6-2). Impacts would
be less than significant.
Facts in Support of Findings: The proposed 413 units could result in an additional 1,189 residents in the
city, which would be approximately 1 1.3 percent of the projected population growth and 10 percent of the
projected housing growth in the City. This increase in population and number of housing units that would result
from the proposed Project would not exceed projections for the City. Also, the 118,474 SF of nonresidential
space would result in approximately 365 new employees (1 employee per 325 SF) that would represent
approximately 1.69 percent of the projected employment growth in the City. Thus, the number of jobs that
would result from the proposed Project would not exceed projections for the City. Conversely, the new
residents would fill the need for employees that are anticipated by SCAG projections. Thus, the additional
residential units would not indirectly result in the need for additional employment opportunities, which could
result in growth. Therefore, this indirect impact related to growth would be less than significant. Thus, impacts
related to increased growth through the provision of employment opportunities would be less than significant.
Impact Growth-2 Finding_ The Project would not remove obstacles to growth (Draft EIR at p. 6-3). Impacts
would be less than significant.
Facts in Support of Findings:
Remove obstacles to growth through changes in utility infrastructure: Future onsite infrastructure improvements
that may be necessary for residential development within the Project site include storm drains, wastewater,
water, and dry utilities that would connect to existing facilities within the Project site or adjacent to the Project
area. Specific infrastructure improvements required to support residential development would not be known
until a development project is proposed. However, the site is surrounded by the City's existing infrastructure
system and that is serving the Project site. Future development allowed under the proposed Project would
connect to existing infrastructure and would be sized appropriately to accommodate only the future
development of the site, as ensured and verified by the City during the plan check and permitting process,
prior to obtaining building permits. Any utility improvements to serve future development of the site would
not provide an extension of service to areas that are currently not served, or provide excess capacity, Project
infrastructure improvements would not result in significant growth inducing impacts.
Remove obstacles to growth through changes in existing regulations pertaining to land development: The
proposed Project includes a General Plan Amendment to establish that higher density residential uses are
allowed in the Planned Community Commercial Business (PCCB) land use designation when prescribed by a
Housing Overlay (HO) district or a Specific Plan (SP). The Project also includes an amendment to Tustin City
Code, Article 9 (Land Use), Chapter 2 (Zoning), Part 5, to establish a HO district, which allows for high
density residential development, and stipulates that objective design standards for residential development
will apply to properties within the boundary of the HO district.
Implementation of a HO district on the Project site would allow residential development of 413 dwelling and
additional onsite employees. However, the zoning and land use changes are parcel -specific and would not
result in growth outside of the Project site, because the areas are either completely developed or within
development land use plans. In addition, as detailed in Draft EIR Section 5.4, Land Use and Planning, and
Section 5.6, Population and Housing, the growth anticipated by SCAG's projections are consistent with the
estimated future buildout of the proposed 413 units (1,1 89 residents) and an additional 118,474 SF of new
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Enderle Center Rezone Project CEQA Findings of Fact
nonresidential space (365 new employees). Therefore, impacts related to growth from changes to existing
regulations pertaining to land development would be less than significant.
Impact Growth-3 Finding_ The Project would not require the construction of new or expanded facilities that
could cause significant environmental effects (Draft EIR at p. 6-4). Impacts would be less than significant.
Facts in Support of Findings: The proposed Project is expected to incrementally increase the demand for
fire protection and emergency response, police protection, school services, and recreational facilities and
would not increase demand beyond that assumed for buildout of the City of Tustin. As described in Draft EIR
Section 5.1 1, Public Services, the proposed Project would not require development of additional facilities or
expansion of existing facilities to maintain existing levels of service. Based on service ratios and build out
projections, the proposed Project would not create a demand for services beyond the capacity of existing
facilities. Therefore, an indirect growth inducing impact as a result of expanded or new public facilities that
could support other development in addition to the proposed Project would not occur. The proposed Project
would not have significant growth inducing consequences that would require the need to expand public
services to maintain desired levels of service. Therefore, impacts would be less than significant.
Impact Growth-4 Finding: The Project would not encourage and facilitate other activities that could
significantly affect the environment, either individually or cumulatively (Draft EIR at p. 6-5). Impacts would
be less than significant.
Facts in Support of Findings: The proposed Project includes a GPA to amend the City's existing General
Plan to establish that higher density residential uses are allowed in the Planned Community Commercial
Business (PCCB) land use designation when prescribed by a Housing Overlay (HO) district or a Specific Plan
(SP). In addition, the Project also includes an amendment to the City's Zoning Map. The proposed zone change
would require an amendment to Tustin City Code, Article 9 (Land Use), Chapter 2 (Zoning), Part 5, to establish
a HO district that allows for higher density residential development and stipulates that objective design
standards will apply to properties within the boundary of the HO district. This does not encourage or result
in a significant effect on the environment. Future development would comply with all applicable City plans,
policies, and ordinances, which would be verified through the development permitting process. In addition,
mitigation measures have been identified to ensure that the proposed Project minimizes environmental
impacts. The proposed Project would not involve any precedent -setting action that could encourage and
facilitate other activities that significantly affect the environment. Therefore, impacts would be less than
significant.
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Enderle Center Rezone Project CEQA Findings of Fact
SECTION VI
SIGNIFICANT IRREVERSIBLE EFFECTS
Section 15126.2(c) of the CEQA Guidelines requires that an EIR discuss "any significant irreversible
environmental changes which would be involved in the proposed action should it be implemented." Generally,
a project would result in significant irreversible environmental changes if:
The project would involve a large commitment of nonrenewable resources;
The project would involve uses in which irreversible damage could result from any potential
environmental accidents associated with the project; or
The proposed irretrievable commitments of nonrenewable resources is not justified (e.g., the project
involves the wasteful use of energy).
The Project would result in or contribute to the following irreversible environmental changes:
• Lands in the Project site that are currently developed with commercial retail uses or parking area would
be committed to residential and/or commercial uses once the housing overlay is implemented. Secondary
effects associated with this irreversible commitment of land resources include:
o Increased vehicle trips on surrounding roadways during operation of future projects under the
proposed Project (see Draft EIR Section 5.9, Transportation).
o Emissions of air pollutants associated with construction and operation of future projects under the
proposed Project (see Draft EIR Section 5.1, Air Quality).
o Consumption of non-renewable energy associated with construction and operation of future projects
under the proposed Project due to the use of automobiles, lighting, heating and cooling systems,
appliances, and the like (see Draft EIR Section 5.3, Energy).
o Increased ambient noise associated with an increase in activities and traffic from future projects
under the proposed Project (see Draft EIR Section 5.9, Noise).
• Construction of future projects under the proposed Project as described in Draft EIR Section 3.0, Project
Description, would require the use of energy produced from non-renewable resources and construction
materials.
In regard to energy usage from development of future projects under the proposed Project, as demonstrated
in the analyses contained in Draft EIR Section 5.3, Energy, the proposed Project would not involve wasteful
or unjustifiable use of non-renewable resources, and conservation efforts would be enforced during
construction and operation of future proposed development, as ensured and verified by the City during the
plan check and permitting process, prior to obtaining building permits. Development of future projects under
the proposed housing overlay would incorporate energy -generating and conserving project design features,
including those required by the California Building Code, California Energy Code Title 24, which specify
green building standards for new developments. Project -specific information related to energy consumption
is provided in Draft EIR Section 5.3, Energy.
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Enderle Center Rezone Project CEQA Findings of Fact
SECTION VII
ALTERNATIVES
The City of Tustin hereby declares that it has considered and rejected as infeasible the alternatives identified
in the Draft EIR and described below. Section 15126.6 of the State CEQA Guidelines requires an EIR to
describe a range of reasonable alternatives to the Project, or to the location of the Project, which could
feasibly achieve most of its basic objectives, but would avoid or substantially lessen any of the significant
effects identified in the EIR analysis. An EIR is not required to consider every conceivable alternative to a
proposed project. Rather, an EIR must consider a reasonable range of alternatives that are potentially
feasible; an EIR is not required to consider alternatives that are infeasible. In addition, an EIR should evaluate
the comparative merits of the alternatives. Therefore, this section sets forth the potential alternatives to the
Project analyzed in the EIR and evaluates them in light of the objectives of the Project, as required by CEQA.
Objectives
The primary purpose and goal of the Project is to accommodate the City's 6th Cycle RHNA identified within
the City of Tustin 2021-2029 Housing Element. The Project would achieve this goal through the following
objectives:
a. Creation of a Housing Overlay (HO) district to allow residential development at densities to achieve the
estimated capacities determined in the Housing Element and without inhibitors to residential
development.
b. Increase the number of housing opportunities available in Tustin to ensure the City provides its fair share
of housing units within a variety of income categories.
c. Increase flexibility in allowed uses and development potential in an underutilized area of the City of
Tustin.
d. Promote a diverse housing stock with products that are offered at a wide range of sizes and
affordability.
(Draft EIR at p. 8-4)
Alternatives
Key provisions of the State CEQA Guidelines relating to the alternatives analysis (Section 15126.6 et seq.)
are summarized below:
• The discussion of alternatives shall focus on alternatives to the Project or its location that are capable of
avoiding or substantially lessening any significant effects of the Project, even if these alternatives would
impede to some degree the attainment of the Project objectives or would be more costly.
• The "No Project" alternative shall be evaluated along with its impact. The "No Project" analysis shall
discuss the existing conditions, as well as what would be reasonably expected to occur in the foreseeable
future if the Project is not approved.
• The range of alternatives required in an EIR is governed by a "rule of reason;" therefore, the EIR must
evaluate only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited
to ones that would avoid or substantially lessen any of the significant effects of the Project.
• For alternative locations, only locations that would avoid or substantially lessen any of the significant
effects of the Project need be considered for inclusion in the EIR.
• An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose
implementation is remote and speculative.
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Enderle Center Rezone Project CEQA Findings of Fact
Rationale for Selecting Potentially Feasible Alternatives
The alternatives must include a no -project alternative and a range of reasonable alternatives to the project
if those reasonable alternatives would attain most of the project objectives while substantially lessening the
potentially significant project impacts. The range of alternatives discussed in an EIR is governed by a "rule
of reason," which the State CEQA Guidelines Section 151 26.6(f)(3) defines as:
... set[ting] forth only those alternatives necessary to permit a reasoned choice. The alternatives
shall be limited to ones that would avoid or substantially lessen any of the significant effects of the
Project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the basic objectives of the project. The range of feasible
alternatives shall be selected and discussed in a manner to foster meaningful public participation
and informed decision -making.
Among the factors that may be taken into account when addressing the feasibility of alternatives (as
described in the State CEQA Guidelines Section 151 26.6(f)([l ]) are environmental impacts, site suitability,
economic viability, availability of infrastructure, general plan consistency, other plans or regulatory
limitations, jurisdictional boundaries, and whether the project proponent could reasonably acquire, control,
or otherwise have access to an alternative site. An EIR need not consider an alternative whose effects could
not be reasonably identified, and whose implementation is remote or speculative.
For purposes of this analysis, the Project alternatives are evaluated to determine the extent to which they
attain the basic Project objectives, while significantly lessening the significant effects of the Project.
Alternatives Not Selected for Analvsis
Alternate Site Alternative
An alternate site for the Project was eliminated from further consideration. Any alternate site would need to
occur within the City of Tustin. The City is required by state law to rezone housing shortfall sites according to
what has been approved under the certified Housing Element (Government Code § 65583.2, Senate Bill
197). The site identified within the City's 2021 -2029 Housing Element is Enderle Center (Project site), and
an alternate site would fail to meet most of the project objectives, is infeasible, and would not be compliant
with state law or the City's Housing Element. Additionally, if the Project were to occur on an alternate site
and rezoning were conducted within a different commercial center in the City, similar impacts would result
and comparable mitigation would be required; therefore, impacts would not be reduced under this
alternative. Therefore, this alternative has been determined infeasible. (Draft EIR at p. 8-5)
Finding: The City of Tustin rejects the Alternative Site Alternative, on the following ground, which provides
sufficient justification for rejection of this alternative: an alternate site would fail to meet most of the project
objectives, is infeasible, and would not be compliant with state law or the City's Housing Element.
Additionally, if the Project were to occur on an alternate site and rezoning were conducted within a different
commercial center in the City, similar impacts would result and comparable mitigation. Therefore, this
alternative is eliminated from further consideration.
No Project/Buildout of Existing Land Use Alternative
Under this alternative, buildout of the nonresidential uses would occur as permitted under the existing land
use designations, but the Project site would not be rezoned to allow for residential uses. This alternative was
eliminated from further consideration. The City is required by state law to rezone housing shortfall sites
according to what has been approved under the certified Housing Element (Government Code § 65583.2,
Senate Bill 197). The site identified within the City's 2021 -2029 Housing Element is Enderle Center (Project
site) and failing to rezone the site for future housing would fail to meet all of the project objectives, which
would therefore render the alternative as infeasible, and further, would not be compliant with state law or
the City's Housing Element. (Draft EIR at p. 8-5)
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Finding: The City of Tustin rejects the No Project/Buildout of Existing Land Use Alternative on the following
ground, which provides sufficient justification for rejection of this alternative: the alternative would fail to
meet all of the project objectives, which would therefore render the alternative as infeasible, and further,
would not be compliant with state law or the City's Housing Element. Therefore, this alternative is eliminated
from further consideration.
Reduced Project Development Alternative
The Reduced Project Development alternative would redesignate the Project site to allow for development
of future residential and additional square footage of nonresidential development, similar to the proposed
Project. However, Project buildout would be reduced by 20 percent for residential and by 95 percent for
new nonresidential; thereby limiting the overall future buildout to a maximum of 330 residential units and a
buildout of 91,923 SF nonresidential uses (including 4,787 SF of additional nonresidential development and
87,136 SF of existing nonresidential development). This alternative would still require approval of the
Housing Overlay (HO) District, a General Plan Amendment (GPA), adoption of a Zone Change (ZC),
adoption of a zoning code amendment (CA), and development of Objective Design Standards (ODS). This
alternative would eliminate the Project's significant and unavoidable GHG impact by reducing GHG
emissions 77 percent, from 12,804 MT CO2e/yr. net new emissions (Project buildout minus existing use) to
2,999 MT CO2e/yr, proportional to the proposed reduction in development. However, under this alternative,
only five percent of the additional nonresidential square footage (above and beyond what is existing)
currently allowed under existing provisions would be developed. Furthermore, under this alternative, only
330 dwelling units would be allowed to be constructed and the City would have an 83 dwelling unit deficit
in meeting their state mandated RHNA fair share. Because this alternative would not meet the City's legal
obligation to rezone the site to meet the necessary residential capacity consistent with the City's certified
Housing Element Update, this alternative has been rendered infeasible and is rejected from further
consideration.
Finding: The City of Tustin rejects the Reduced Project Development Alternative on the following ground,
which provides sufficient justification for rejection of this alternative: the City would have an 83 dwelling unit
deficit in meeting their state mandated RHNA fair share. Because this alternative would not meet the City's
legal obligation to rezone the site to meet the necessary residential capacity consistent with the City's
certified Housing Element Update. Therefore, this alternative is eliminated from further consideration.
Alternatives Selected for Further Analysis
Alternative 1: No Project/No Development Alternative
This alternative consists of the Project not being approved, and the Project site would remain in the conditions
that existed at the time the Notice of Preparation was published (February 16, 2024). (Draft EIR at p. 8-6)
Alternative 2: Reduced Nonresidential Project Alternative
The Reduced Nonresidential Project alternative would allow for the same potential future development of
housing units to occur as proposed by the Project, but limiting the buildout of nonresidential uses to 35 percent
of the capacity in the General Plan. The Reduced Nonresidential Project Alternative would allow for the
potential future buildout of 413 residential units and 46,510 SF of new nonresidential development in
addition to the existing shopping center. The reduced nonresidential square footage would allow for
increased setbacks, passenger vehicle parking, and truck parking. Areas planned for physical impact would
be identical to those required for development of the proposed Project. This alternative would still require
a General Plan Amendment (GPA), adoption of a Zone Change (ZC) and a Zoning Code Amendment (CA),
and development of Objective Design Standards (ODS). (Draft EIR at p. 8-6)
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Findings for Alternatives
Alternative 1: No Project/No Development Alternative
The No Project/No Development Alternative would result in continuation of the existing uses within the Project
site, and the proposed development would not occur. As a result, this alternative would avoid the need for
mitigation measures that are identified in Chapter 5.0 of the Draft EIR, which include measures related to
air quality, greenhouse gas emissions, noise, tribal cultural resources, and utilities. This alternative would also
avoid the significant and unavoidable impacts to air quality and greenhouse gases. However, this alternative
could result in a significant and unavoidable impact on population and housing due to noncompliance with
the City's certified Housing Element and the City's inability to meet its state mandated RHNA. This alternative
would result in lessened impacts to 10 of the 11 environmental topics analyzed in the EIR (see Draft EIR Table
8-1). However, the environmental benefits of the proposed Project would also not be realized, including
providing housing onsite that would result in a better jobs -housing balance in Tustin, which is currently
considered jobs -rich.
Implementation of the No Project/No Development Alternative would not meet any of the Project objectives.
The purpose of the Project is to rezone the Project site to be consistent with the City Housing Element Updated
recently adopted by the City. The No Build Alternative would not result in rezoning to allow residential
development at densities to achieve the estimated capacities determined in the certified Housing Element,
and without inhibitors to residential development, such as overly stringent standards. It would also not
increase the number of housing opportunities available in Tustin, increase flexibility in allowed uses and
development potential in the City of Tustin or promote a diverse housing stock with a wide range of sizes
and affordability. (Draft EIR at p. 8-9)
Finding: The City of Tustin finds that the No Project/No Development Alternative would eliminate the
significant and unavoidable impacts related to air quality and greenhouse gas emission that would occur
from the Project. In addition, this alternative would eliminate the need for mitigation related to air quality,
greenhouse gas emissions, noise, tribal cultural resources, and utilities. However, this alternative would fail
to meet the Project objectives as it would not allow residential development at densities to achieve the
estimated capacities determined in the certified Housing Element. This reason provides a sufficient basis upon
which to reject this alternative.
Alternative 2: Reduced Nonresidential Project Alternative
The Reduced Nonresidential Project Alternative would allow for increased setbacks, passenger vehicle
parking, and truck parking. Mitigation measures for noise, recreation, tribal cultural resources, and utilities
and service systems would still be applicable to this alternative. Although, the Reduced Nonresidential Project
Alternative would generally result in a reduction of impacts due to the 35 percent reduction in additional
nonresidential use compared to the proposed Project, this alternative would only reduce the impact level of
one of the 11 environmental topics analyzed in the Draft EIR (operational air quality impacts) from significant
and unavoidable with mitigation, to less than significant (see Draft EIR Table 8-1). Furthermore, impacts to
GHG would continue to be significant and unavoidable (although slightly less). The Reduced Nonresidential
Project Alternative would meet all of the Project objectives. (Draft EIR at p. 8-13).
Finding: The City of Tustin finds that the significant and unavoidable impacts related to greenhouse gas
would continue to occur from implementation of the Reduced Nonresidential Project Alternative and
mitigation would continue to be required for GHG, noise, recreation, tribal cultural resources, and utilities
and service systems. These reasons, separately and independently, is a sufficient basis upon which to reject
this alternative.
Environmentally Superior Alternative
Section 15126.6(e)(2) of the CEQA Guidelines indicates that an analysis of alternatives to a proposed
project shall identify an environmentally superior alternative among the alternatives evaluated in an EIR. The
City of Tustin 51
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Enderle Center Rezone Project CEQA Findings of Fact
Environmentally Superior Alternative for the proposed Project would be the Reduced Nonresidential Project
Alternative.
However, significant and unavoidable impacts related to greenhouse gas emissions would continue to occur
from implementation of this alternative. This alternative would reduce potential impacts related to air quality
compared to the proposed Project; but a majority of the mitigation required for implementation of the
proposed Project would continue to be required. The volume of impacts would be reduced by the Reduced
Nonresidential Project Alternative in comparison to the proposed Project and would be less than the other
alternatives evaluated herein, as detailed in Draft EIR Table 8-1. Therefore, the Reduced Nonresidential
Project Alternative would be the environmentally superior alternative. However, the Reduced Nonresidential
Project Alternative would not eliminate the significant and unavoidable impacts of the proposed Project to
greenhouse gas emissions or eliminate the need for mitigation. Regarding Project objectives, the Reduced
Nonresidential Project Alternative would meet the Project objectives (Draft EIR at p. 8-2).
CEQA does not require the lead agency (the City of Tustin) to choose the environmentally superior
alternative. Instead, CEQA requires the City to consider environmentally superior alternatives, weigh those
considerations against the environmental impacts of the proposed Project, and make findings that the
benefits of those considerations outweigh the harm. Based on the considerations described herein, the City
of Tustin finds that the Reduced Nonresidential Project Alternative is infeasible based on these environmental,
economic, and social factors.
City of Tustin 52
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Enderle Center Rezone Project CEQA Findings of Fact
SECTION VIII
STATEMENT OF OVERRIDING CONSIDERATIO
Introduction
The City of Tustin is the Lead Agency under CEQA for preparation, review and certification of the EIR for
the Enderle Center Rezone Project (Project). As the Lead Agency, the City is also responsible for determining
the potential environmental impacts of the proposed action and which of those impacts are significant, and
which can be mitigated through imposition of mitigation measures to avoid or minimize those impacts to a
level of less than significant. CEQA then requires the Lead Agency to balance the benefits of a proposed
action against its significant unavoidable adverse environmental impacts in determining whether or not to
approve the proposed Project. In making this determination the City is guided by CEQA Guidelines Section
15093, Statement of Overriding Considerations, which states:
a) CEQA requires the decision -making agency to balance, as applicable, the economic, legal, social,
technological, or other benefits of a proposed project against its unavoidable environmental risks when
determining whether to approve the project. If the specific economic, legal, social, technological, or other
benefits of a proposal (sic) project outweigh the unavoidable adverse environmental effects, the adverse
environmental effects may be considered "acceptable."
b) When the lead agency approves a project which will result in the occurrence of significant effects which
are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in
writing the specific reasons to support its action based on the final EIR and/or other information in the
record. The statement of overriding considerations shall be supported by substantial evidence in the
record.
c) If an agency makes a statement of overriding considerations, the statement should be included in the
record of the project approval and should be mentioned in the notice of determination. This statement
does not substitute for, and shall be in addition to, findings required pursuant to Section 15091.
In addition, Public Resources Code Section 21081(b) requires that where a public agency finds that specific
economic, legal, social, technological, or other considerations, including considerations for the provision of
employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives
identified in an EIR and thereby leave significant unavoidable effects, the public agency must also find that
overriding economic, legal, social, technological, or other benefits of the project outweigh the significant
effects of the project.
Pursuant to Public Resources Code Section 21081 (b) and the State CEQA Guidelines Section 15093, the
City has balanced the benefits of the proposed Project against the unavoidable adverse impacts associated
with the Project and has adopted all feasible mitigation measures with respect to these impacts. The City
also has examined alternatives to the proposed Project, none of which both meets the Project objectives to
the same extent as the Project and is environmentally preferable to the proposed Project for the reasons
discussed in the Findings and Facts in Support of Findings.
The City of Tustin, as the Lead Agency for this Project, and having reviewed the EIR for the Enderle Center
Rezone Project, and reviewed all written materials within the City's public record and heard all oral testimony
presented at public hearings, adopts this Statement of Overriding Considerations, which has balanced the
benefits of the Project against its significant unavoidable adverse environmental impacts in reaching its
decision to approve the Project.
Overridina Considerations
The City, after balancing the specific economic, legal, social, technological, and other benefits of the Project,
has determined that the unavoidable adverse air quality and greenhouse gas impacts identified above may
be considered acceptable due to the following specific considerations which outweigh the unavoidable,
adverse environmental impacts of the Project, each of which standing alone is sufficient to support approval
City of Tustin 53
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Enderle Center Rezone Project CEQA Findings of Fact
of the Project, in accordance with CEQA Section 21081(b) and CEQA Guideline Section 15093. The specific
economic, legal, social, technological, or other benefits of the Project are as follows:
• The Project would allow the City to meeting their state mandated RHNA fair share.
• The Project would implement and be consistent with the City's Housing Element.
• The Project provides additional housing and the necessary residential capacity consistent with the City's
certified Housing Element Update.
• The Project would increase flexibility in allowed uses and development potential in the City of Tustin and
promote a diverse housing stock with a wide range of sizes and affordability.
• The Project would increase the development potential of an underutilized area of the City of Tustin.
City of Tustin 54
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Enderle Center Rezone Project CEQA Findings of Fact
SECTION IX
CERTIFICATION OF THE EIR
The City of Tustin finds that it has reviewed and considered the Final EIR in evaluating the proposed Project,
that the Final EIR is an accurate and objective statement that fully complies with CEQA, State CEQA
Guidelines and that the Final EIR reflects the independent judgment of the City.
The City of Tustin declares that no new significant information as defined by State CEQA Guidelines, section
15088.5 has been received by the City after circulation of the Draft EIR that would require recirculation.
The City of Tustin certifies the EIR based on the entirety of the record of proceedings, including but not limited
to the following findings and conclusions.
Findings•
The following significant environmental impacts have been identified in the EIR and will require mitigation as
set forth in Section IV of this Resolution but cannot be mitigated to a level of insignificance: air quality (project
and cumulative level) and greenhouse gas emissions (project and cumulative level).
Conclusions•
1. Except as to those impacts stated above relating to air quality and greenhouse gas emissions, all
significant environmental impacts from the implementation of the proposed Project have been identified
in the EIR and, with implementation of existing regulations and the identified mitigation measures from
the EIR, will be mitigated to a level of insignificance.
2. Other alternatives to the proposed Project, which could potentially achieve the basic objectives of the
proposed Project, have been considered and rejected in favor of the proposed Project.
3. Environmental, economic, social, and other considerations and benefits derived from the proposed Project
override and make infeasible any alternatives to the proposed Project or further mitigation measures
beyond those incorporated into the proposed Project.
City of Tustin 55
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Enderle Center Rezone Project CEQA Findings of Fact
SECTION X
MITIGATION MONITORING AND REPORTING PLAN
Pursuant to Public Resources Code section 21081.6, the City of Tustin adopts the Mitigation Monitoring and
Reporting Plan (MMRP) attached to this Resolution as Exhibit A. In the event of any inconsistencies between
the mitigation measures as set forth herein and the Mitigation Monitoring and Reporting Plan, the Mitigation
Monitoring and Reporting Plan shall control.
City of Tustin 56
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Enderle Center Rezone Project CEQA Findings of Fact
SECTION XI
CONTENTS AND CUSTODIAN OF RECOR
The documents and materials that constitute the record of proceedings on which these findings have been
based are located at the City of Tustin Planning Division. The custodian for these records is the City of Tustin.
This information is provided in compliance with Public Resources Code section 21081.6.
The record of proceedings for the City's decision on the Project consists of the following documents, at a
minimum:
1. The Initial Study for the Enderle Center Rezone Project;
2. The NOP, NOC, and all other public notices issued by the City in conjunction with the Project;
3. All comments submitted by agencies or members of the public during the 45-day comment period on the
Draft EIR;
4. The Final EIR for the Enderle Center Rezone Project, including comments timely received on the Draft EIR,
responses to those comments, and technical appendices;
5. The Mitigation Monitoring and Reporting Plan for the Project;
6. All findings, resolutions and ordinances adopted by the City in connection with the Enderle Center Rezone
Project, and all documents cited or referred to therein;
7. All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the Project
prepared by the City, consultants to the City, or responsible or trustee agencies with respect to the City's
compliance with the requirements of CEQA and with respect to the City's action on the Enderle Center
Rezone Project;
8. All documents submitted to the City by other public agencies or members of the public in connection with
the Enderle Center Rezone Project up though Project approval.
9. Matters of common knowledge to the City, including, but not limited to Federal, State, and local laws
and regulations;
10. Any documents expressly cited or referenced in these findings, in addition to those cited above; and
11. Any other materials required for the record of proceedings by Public Resources Code section 21 167.6,
subdivision (e).
The following location is where review of the record may be performed:
City of Tustin
Planning Division
300 Centennial Way
Tustin, CA 92780
City of Tustin 57
September 2024
Exhibit A
Mitigation Monitoring and
Reporting Program (MMRP)
Enderle Center Rezone Project
Enderle Center Rezone
Attachment A
1. Mitigation Monitoring and Reporting Program
1.1 INTRODUCTION
The California Environmental Quality Act (CEQA) requires a lead or public agency that approves or carries
out a project for which an Environmental Impact Report (EIR) has been certified, which identifies one or more
significant adverse environmental effects and where findings with respect to changes or alterations in the
project have been made, to adopt a "...reporting or monitoring program for the changes to the project
which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects
on the environment" (CEQA, Public Resources Code Sections 21081, 21081.6).
A Mitigation Monitoring and Reporting Program (MMRP) is required to ensure that adopted mitigation
measures are successfully implemented. The City of Tustin is the Lead Agency for the Project and is
responsible for implementation of the MMRP. This report describes the MMRP for the Project and identifies
the parties that will be responsible for monitoring implementation of the individual mitigation measures in
the MMRP.
1.2 MITIGATION MONITORING AND REPORTING PROGRAM
The MMRP for the Project will be active through all phases of the Project, including design, construction, and
operation. The attached table identifies the mitigation program required to be implemented by the City for
the Project. The table identifies mitigation measures required by the City to mitigate or avoid significant
impacts associated with the implementation of the Project, the timing of implementation, and the responsible
party or parties for monitoring compliance.
The MMRP also includes a column that will be used by the compliance monitor (individual responsible for
monitoring compliance) to document when implementation of the measure is completed. As individual Plans,
Programs, and Policies and mitigation measures are completed, the compliance monitor will sign and date
the MMRP, indicating that the required actions have been completed.
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Table 1-1: Mitigation Monitoring and Reporting Program
Attachment A
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
AIR QUALITY
PPP AQ-1: Rule 403. The Project is required to comply with the
Prior to grading
Project developers/
The City Community
provisions of South Coast Air Quality Management District
permit approval;
applicants and
Development Dept.
Initials:
(SCAQMD) Rule 403, which includes the following:
and during
construction
will confirm that this
• All clearing, grading, earth -moving, or excavation activities
construction activities
contractors
requirement appears
shall cease when winds exceed 25 mph per SCAQMD
in the construction
Date:
guidelines in order to limit fugitive dust emissions.
specifications.
• The contractor shall ensure that all disturbed unpaved roads
and disturbed areas within the project are watered, with
complete coverage of disturbed areas, at least 3 times daily
during dry weather; preferably in the mid -morning,
afternoon, and after work is done for the day.
• The contractor shall ensure that traffic speeds on unpaved
roads and Project site areas are reduced to 15 miles per hour
or less.
PPP AQ-2: Rule 1113. The Project is required to comply with the
Prior to grading
Project developers/
The City Community
provisions of South Coast Air Quality Management District Rule
permit approval;
applicants and
Development Dept.
Initials:
(SCAQMD) Rule 1 1 13. Only "Low -Volatile Organic Compounds"
and during
construction
will examine project
paints (no more than 50 gram/liter of VOC) and/or High Pressure
construction activities
contractors
contracts, plans, and
Low Volume (HPLV) applications shall be used.
specifications for this
Date:
requirement and
monitor for
compliance.
PPP AO-3: Rule 402. The Project is required to comply with the
Prior to grading or
Project developers/
The City Community
provisions of South Coast Air Quality Management District
building permit
applicants and
Development Dept.
Initials:
(SCAQMD) Rule 402. The Project shall not discharge from any
approval; and
construction
will examine project
source whatsoever such quantities of air contaminants or other
during construction
contractors
plans and monitor
material which cause injury, detriment, nuisance, or annoyance to
and operation
for compliance.
Date:
any considerable number of persons or to the public, or which
endanger the comfort, repose, health or safety of any such
persons or the public, or which cause, or have a natural tendency
to cause, injury or damage to business or property.
MM AQ-1. Prior to building permit approval by the City of Tustin
Prior to building
Project developers/
The City Community
(City) for future development projects, project applicants shall
permit approval
applicants
Development Dept.
prepare and submit a technical assessment evaluating potential
will confirm that this
City of Tustin 1-3
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
project -related air quality impacts, including a localized impacts
requirement has
analysis, to the City for review and approval. The analysis shall
been completed
Initials:
be prepared in conformance with South Coast Air Quality
prior to final plan
Management District (SCAQMD) methodology. If project -related
approval.
emissions exceed applicable SCAQMD thresholds of significance,
Date:
the City shall require that applicants for new development
projects incorporate mitigation measures to reduce emissions. The
identified measures shall be included as part of the conditions of
approval. Additionally, if project -related localized emissions
exceed the SCAQMD's thresholds, a dispersion modeling analysis
shall be conducted to calculate potential health risk from project
implementation, and all necessary mitigation measures shall be
implemented.
BIOLOGICAL RESOURCES
PPP BIO-1: Street Trees. Installation of street trees shall occur in
Prior to grading and
Project
The City Community
compliance with the City of Tustin Municipal Code Article 7,
building permit
developers/applica
Development Dept.
Initials:
Chapter 3, Section 7308.
approval; and
nts and construction
will approve
during construction
contractors
landscape plan prior
Date:
activities
to issuance of
grading permits.
MM BIO-1: Migratory Bird Treaty Act. Prior to commencement of
Before
Project developers/
The City Community
grading activities, the City Community Development Department
commencement of
applicants and
Development Dept.
Initials:
shall verify that, in the event that vegetation and tree removal
grading activities
construction
will determine if
activities occur within the active breeding season for birds
contractors
surveys are needed
Date:
(February 1—September 15), the Project applicant (or their
prior to issuance of
Construction Contractor) shall retain a qualified biologist
permits for grading
(meaning a professional biologist that is familiar with local birds
activities based on
and their nesting behaviors) to conduct a nesting bird survey no
the timeline and will
more than 3 days prior to commencement of construction activities.
examine project
permitting for these
The nesting survey shall include the Project site and areas
requirements and
immediately adjacent to the site that could potentially be
monitor for
affected by Project -related construction activities, such as noise,
compliance.
human activity, and dust, etc. If active nesting of birds is observed
within 100 feet of the designated construction area prior to
construction, the qualified biologist shall establish an appropriate
buffer around the active nests (e.g., as much as 500 feet for
raptors and 300 feet for non -raptors [subject to the
recommendations of the qualified biologist]), and the buffer areas
City of Tustin 1-4
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
shall be avoided until the nests are no longer occupied and the
juvenile birds can survive independently from the nests.
CULTURAL RESOURCES
PPP CUL-1: Human Remains. Should human remains or funerary
During grading and
Project developers/
The City Community
objects be discovered during Project construction, the Project
construction activities
applicant,
Development Dept.
Initials:
would be required to comply with State Health and Safety Code
construction
will review project
Section 7050.5, which states that no further disturbance may occur
contractors
plans and
Date:
in the vicinity of the body (within a 100-foot buffer of the find)
specifications to
until the County Coroner has made a determination of origin and
ensure these
disposition pursuant to Public Resources Code Section 5097.98.
requirements are
The County Coroner must be notified of the find immediately. If
met and would
the remains are determined to be prehistoric, the Coroner will
monitor to verify
notify the Native American Heritage Commission by telephone
compliance.
within 24 hours, which will determine the identity of and notify a
Most Likely Descendant (MLD). With the permission of the
landowner or his/her authorized representative, the MLD may
inspect the site of the discovery. The MLD must complete the
inspection and make recommendations or preferences for
treatment within 48 hours after being granted access to the site.
MM CUL-1: Inadvertent Discovery. In the event that potential
Prior to grading
Project developers/
The City Community
archaeological resources are discovered during excavation,
permit approval;
applicants and
Development Dept.
Initials:
grading, or construction activities, work shall cease within 50 feet
and during
construction
will examine project
of the find until a qualified archaeologist from the City or County
construction activities
contractors
contracts, plans, and
Date:
List of Qualified Archaeologists has evaluated the find to
specifications for
determine whether the find constitutes a "unique archaeological
these requirements
resource," as defined in Section 21 083.2(g) of the California
and monitor for
Public Resources Code. Any resources identified shall be treated
compliance.
in accordance with California Public Resources Code Section
21083.2(g).
If the discovered resource(s) appears Native American in origin,
a Native American Monitor shall be contacted to evaluate any
potential tribal cultural resource(s) and shall have the opportunity
to consult on appropriate treatment and curation of these
resources. The discovery would also be reported to the City and
the South Central Coastal Information Center (SCCIC).
Prior to the issuance of any permits for ground -disturbing activities
that include the excavation of soils (including as grading,
City of Tustin 1-5
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
excavation, and trenching), the City of Tustin shall ensure that all
Project grading and construction plans and specifications include
requirement to halt construction activity and contact an
archaeologist as specified above.
ENERGY
PPP E-1: CalGreen Compliance. The Project is required to comply
Prior to building
Project developers/
The City Building
with the CalGreen Building Code to ensure efficient use of energy.
permit approval
applicants and
Division will review
Initials:
CalGreen specifications are required to be incorporated into
construction
Project plans and
building plans as a condition of building permit approval.
contractors
specifications for
Date:
these requirements
and monitor for
compliance.
GEOLOGY AND SOILS
PPP GEO-1: CBC Title 24, Part 2. Structures built in the City are
Prior to grading and
Project developers/
The City Building
required to be built in compliance with the CBC (California Code
building permit
applicants and
Division will examine
Initials:
of Regulations, Title 24, Part 2) that provides provisions for
approval
construction
project contracts,
earthquake safety based on factors including building occupancy
contractors
plans, and
Date:
type, the types of soils onsite, and the probable strength of
specifications for
ground motion. Compliance with the CBC would require the
these requirements
incorporation of 1 ) seismic safety features to minimize the
and monitor for
potential for significant effects as a result of earthquakes; 2)
compliance.
proper building footings and foundations; and 3) construction of
the building structure so that it would withstand the effects of
strong ground shaking. Implementation of CBC standards would
be verified by the City during the plan check and permitting
process.
PPP GEO-2: Policy 8.5 of the Conservation/Open
Prior to grading and
Project developers/
The City Community
Space/Recreation Element. Project applicants would be required
building permit
applicants and
Development Dept.
Initials:
to submit applications for building and grading permits, and
approval
construction
will examine project
applications for subdivision for adjacency to, threats from, and
contractors
contracts, plans, and
Date:
impacts on geological hazards arising from seismic events,
specifications for
landslides, or other geologic hazards such as expansive soils and
these requirements
subsidence areas, which would be reviewed by the City during
and monitor for
plan check.
compliance.
MM GEO-1: All future projects implemented through the proposed
Prior to grading and
Project developers/
The City Community
housing overlay would be required to conduct a project -specific
building permit
applicants and
Development Dept.
geotechnical investigation to ensure that the site's soils are
approval
will review and
City of Tustin 1-6
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
adequate for the construction and operation of the proposed
construction
approve
project. Future projects would be required to implement measures
contractors
development specific
Initials:
identified within the project -specific geotechnical investigation.
geotechnical
investigation and
Date:
ensure its
requirements are
included in
development
contracts, plans, and
specifications and
monitor for
compliance.
HYDROLOGY AND WATER QUALITY
PPP HYD-1: SWPPP. Prior to issuance of any grading or
Prior to grading or
Project developers/
The City Public
demolition permits, the applicant shall provide the City Building
demolition/building
applicants and
Works and
Initials:
Division evidence of compliance with the NPDES (National
permit approval
construction
Community
Pollutant Discharge Elimination System) requirement to obtain a
contractors
Development
Date:
construction permit from the State Water Resource Control Board
Departments will
(SWRCB). The permit requirement applies to grading and
examine project
construction sites of one acre or larger. The Project
contracts, plans, and
applicant/proponent shall comply by submitting a Notice of Intent
specifications for
(NOI) and by developing and implementing a Stormwater
these requirements
Pollution Prevention Plan (SWPPP) and a monitoring program and
and monitor for
reporting plan for the construction site.
compliance.
PPP HYD-2: City of Tustin Grading Manual. All future projects
Prior to grading or
Project developers/
The City Community
are required to comply with the City of Tustin Grading Manual
demolition/building
applicants and
Development Dept.
Initials:
(1990). Implementation of grading manual standards would be
permits approval
construction
will examine project
verified by the City during the plan check and permitting process.
and during
contractors
contracts, plans, and
Date:
construction activities
specifications for
these requirements
and monitor for
compliance.
PPP HYD-3: WQMP. Prior to the approval of the Grading Plan
Prior to grading
Project developers/
The City Public
and issuance of Grading Permits a completed Water Quality
permit approval
applicants and
Works Dept. will
Initials:
Management Plan (WQMP) shall be prepared by the Project
construction
examine project
applicant and submitted to and approved by the City Public
contractors
contracts, plans, and
Works Department. The WQMP shall identify all Post-
specifications for
Date:
Construction, Site Design, Source Control, and Treatment Control
these requirements
City of Tustin 1-7
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
Best Management Practices (BMPs) that will be incorporated into
and monitor for
the development Project to minimize the adverse effects on
compliance.
receiving waters.
GREENHOUSE GAS EMISSIONS
Mitigation Measure GHG-1: Prior to issuance of a building
Prior to building
Project Developers
The City Community
permit, the City shall require that applicants for new residential
permit approval
/applicants
Development Dept.
Initials:
development projects incorporate mitigation measures to reduce
will review project
GHG emissions. The identified measures shall be included as part
plans and ensure
Date:
of the project's approval. Possible mitigation measures to reduce
mitigation measures
operational emissions could include, but are not limited to, the
to reduce GHG
following:
emissions are
incorporated into the
• Increase in insulation such that heat transfer and thermal
project, as
bridging is minimized;
appropriate, prior to
• Limit air leakage through the structure and/or within the
issuance of buildingpermit.
heating and cooling distribution system;
• Use of energy -efficient space heating and cooling
equipment;
• Installation of dual -paned or other energy efficient windows;
• Use of interior and exterior energy efficient lighting that
exceeds the incumbent California Title 24 Energy Efficiency
performance standards;
• Installation of automatic devices to turn off lights where they
are not needed;
• Application of an exterior paint and surface color palette
that emphasizes light and off-white colors that reflect heat
away from buildings;
• Design of buildings with "cool roofs" using products certified
by the Cool Roof Rating Council, and/or exposed roof
surfaces using light and off-white colors;
• Design of buildings to accommodate photo -voltaic solar
electricity systems or the installation of photo -voltaic solar
electricity systems;
• Installation of ENERGY STAR -qualified energy -efficient
appliances, heating and cooling systems, office equipment,
and/or lighting products.
City of Tustin 1-8
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
• Landscaping palette emphasizing drought tolerant plants;
• Use of water -efficient irrigation techniques;
U.S. EPA Certified WaterSense-labeled or equivalent faucets,
high -efficiency toilets (HETs), and water -conserving shower heads.
Mitigation Measure GHG-2: Prior to discretionary approval by
Prior to
Project Developers
The City Community
the City of Tustin (City) for residential development projects
discretionary
/applicants
Development Dept.
Initials:
subject to California Environmental Quality Act (CEQA) review,
approval
Planning Division will
project applicants shall prepare and submit a technical assessment
ensure receipt,
Date:
evaluating potential project -related greenhouse gas (GHG)
review, and
impacts to the City for review and approval. The evaluation shall
approval of GHG
be prepared in conformance with South Coast Air Quality
technical assessment
Management District (SCAQMD) methodology. If project -related
and inclusion of
development specific
GHG emissions exceed applicable SCAQMD thresholds of
measures, as
significance and/or Statewide GHG reduction targets, project-
appropriate, prior to
specific measures shall be identified and implemented, which
discretionary
would be reviewed and confirmed by the City.
approval.
NOISE
PPP NOW: Construction Hours. Per the Tustin City Code Section
During construction
Project developer/
The City Community
4616, construction activities are allowed only between the hours
Construction
Development Dept.
Initials:
of 7:00 AM and 6:00 PM, Monday through Friday and between
contractor/ City of
will enforce grading
9:00 AM to 5:00 PM on Saturdays with no activity allowed on
Tustin Building
and construction
Date:
Sundays and City -observed federal holidays.
Department
permitting; and
monitor for
compliance.
MM NOI-1: All future development shall prepare a project-
Prior to grading and
Project developers/
The City Community
specific Final Acoustical Report to confirm whether any proposed
building permit
applicants
Development Dept.
Initials:
exterior noise sensitive areas would experience noise levels
approval
will review and
greater than 65 dBA CNEL and whether interior noise levels would
approve
exceed 45 dBA CNEL and identify any noise reduction features
development specific
Date:
for the proposed development (e.g. upgraded windows with
noise analysis and
Sound Transmission Class (STC) ratings of 30-35). Additionally,
ensure any noise
the Final Acoustical Report shall confirm that proposed siting of
requirements are
noise -generating stationary sources, if any will not result in an
included in
exceedance of applicable noise thresholds at surrounding land
development
uses.
contracts, plans, and
specifications and
City of Tustin 1-9
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
monitor for
compliance.
RECREATION
PPP R-1: City Park Requirements. Tustin City Code Section 9331
Prior to grading and
Project developers/
The City Community
— Dedications, Reservations and Development Fees. All future
building permit
applicants
Development Dept.
Initials:
development shall be consistent with this standard.
approval
will review project
plans and
specifications to
Date:
ensure these
requirements are
met and would
monitor to verify
compliance.
TRANSPORTATION
PPP T-1: Sidewalk Standards. Sidewalks shall be provided on a
Prior to grading and
Project developers/
The City Building
private street for attached and detached residential products in
construction permit
applicants and
Division will review
Initials:
accordance with Standard B102 of the City's Construction
approval
construction
project plans and
Standards, Storm Drain and On -Site Private Improvements, and is
contractors
specifications to
Date:
subject to compliance with applicable accessibility requirements
ensure these
of the American Disabilities Act, Title 24 of the Uniform Building
requirements are
Code as locally amended, and the Department of Housing and
met and would
Urban Development's Fair Housing Accessibility Guidelines.
monitor to verify
compliance.
PPP T-2: Traffic Control/Utilities. All future development
Prior to grading or
Project developers/
The City Public
constructed under the Project shall be subject to the traffic control
demolition/building
applicants and
Works Dept. will
Initials:
standards specified by the City's latest Standard Plans and Design
permit approval
construction
review project plans
Standards, which includes the requirement for Traffic Control Plan
contractors
and specifications to
during construction, the process prior to commencing construction
ensure these
Date:
within the City public right-of-way (including utility work), and
requirements are
specifications for operational roadway and traffic control design.
met and would
monitor to verify
compliance.
TRIBAL CULTURAL RESOURCES
PPP TCR-1: Native American historical and cultural resources and
Prior to grading or
Project developers/
The City Community
sacred sites are protected under PRC Sections 5097.9 to
demolition/building
applicant,
Development Dept.
Initials:
5097.991, which require that descendants be notified when
permit approval
construction
will review project
Native American human remains are discovered and provide for
contractors
plans and
Date:
City of Tustin 1 -10
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Timing
Responsible Party
Verification Method
Date Completed and
Initials
treatment and disposition of human remains and associated grave
specifications to
goods.
ensure these
requirements are
met and would
monitor to verify
compliance.
TCR-1: Retain a Native American Monitor Prior to
Prior to grading or
Project developers/
The City Community
Commencement of Ground -Disturbing Activities
demolition/building
applicant,
Development Dept.
Initials:
a. Prior to the issuance of demolition or grading permits for any
permit approval;
construction
will review project
Date:
projects that would disturb previously undisturbed soils (native
and during grading
contractors, Native
plans and
soils) or soils that have native fill, the project
and demolition
American Monitor
specifications to
applicant/developer shall retain a Native American Monitor,
activities
ensure these
with first preference given to the Gabriele"no Band of Mission
requirements are
met and would
Indians — Kizh Nation, who responded to the City's request for
monitor to verify
consultation on November 14, 2023 (first preference Tribe,
compliance.
Tribe). The applicant/developer shall allow 45 days from the
initial contact with the first preference tribe to enter into a
contract for monitoring services. If the applicant/developer is
unable to contact the Kizh Nation after three documented
attempts, or is unable to secure an agreement, the applicant
shall report to the lead agency, and the lead agency will
contact the Kizh Nation to validate that the parties were
unable to enter into an agreement. If the
applicant/developer can demonstrate they were unable to
secure an agreement with the first preference tribe, as
validated and documented by the Community Development
Department in writing, or if the contracted tribe fails to fulfill
its obligation under the contract terms, then the
applicant/developer may retain an alternative qualified
tribal monitor from a culturally affiliated tribe, or if none are
available, an otherwise qualified archaeologist may be
retained as approved by the City.
The monitor shall be retained prior to the issuance of a
demolition permit or grading permit, and the commencement
of any development related "ground -disturbing activity" for
the subject project at all project locations (i.e., both on -site
and any off -site locations that are included in the project
description/definition and/or required in connection with the
project, such as public improvement work). "Ground -
City of Tustin
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Timing
Responsible Party
Verification Method
Date Completed and
Initials
disturbing activity" shall include, but is not limited to,
demolition, pavement removal, auguring, grubbing, boring,
grading, excavation, drilling, and trenching for the purposes
of reconstruction and new development. "Ground -disturbing
activity" shall not include removal or maintenance of existing
small facilities and utilities such as potholing, tree removal,
and parking lot maintenance. This mitigation measure does
not apply to activities that would only disturb soils made up
of artificial fill, as verified by a soils or geotechnical report.
b. A copy of the executed monitoring agreement shall be
submitted to the lead agency prior to the commencement of
any ground -disturbing activity, or the issuance of any permit
necessary to commence a ground -disturbing activity.
C. The monitor will complete daily monitoring logs that will
provide descriptions of the relevant ground -disturbing
activities, the type of construction activities performed,
locations of ground -disturbing activities, soil types, and
cultural -related materials of significance to the Kizh Nation.
Monitor logs will identify and describe any discovered Native
American cultural and historical artifacts, remains, places of
significance, etc., (collectively, tribal cultural resources, or
"TCR"), as well as any discovered Native American
(ancestral) human remains and associated grave goods.
Copies of monitor logs will be provided to the project
applicant/lead agency upon written request to the consulting
tribe. If a monitor is selected from a tribe other than the Kizh
Nation, the Kizh Nation shall be contacted if any discoveries
are found.
d. On -site tribal monitoring shall conclude upon the latter of the
following (1 ) written confirmation to the monitor from a
designated point of contact for the project applicant/lead
agency that all ground -disturbing activities and phases that
may involve ground -disturbing activities and that have the
potential to impact local TCRs on the project site or in
connection with the project are complete; or (2) the monitor
determines based on field observations that there is no
likelihood of encountering intact TCRs. Monitoring may be
reduced in extent or frequency as determined appropriate
by the monitor.
City of Tustin 1 -1 2
Final EIR
September 2024
Enderle Center Rezone
Mitigation Measure
TCR-2: Unanticipated Discovery of Tribal Cultural Resource
Objects (Non-Funerary/Non-Ceremonial). Upon discovery of
any TCRs, all ground -disturbing activities in the immediate vicinity
of the discovery shall cease (i.e., not less than the surrounding 50
feet) and shall not resume until the discovered TCR has been
assessed by the tribal monitor and consulting archaeologist. If the
monitor is other than the Gabrielefio Band of Mission Indians —
Kizh Nation, the Kizh Nation shall be contacted and the monitor
and/or Kizh Nation will recover and retain all discovered TCRs in
the form and/or deemed appropriate, in agreement with Kizh
Nation including for educational, cultural and/or historic purposes.
TCR-3: Unanticipated Discovery of Human Remains and
Associated Funerary or Ceremonial Objects
a. Native American human remains are defined in PRC 5097.98
(d)(1) as an inhumation or cremation, and in any state of
decomposition or skeletal completeness. Funerary objects,
called associated grave goods in Public Resources Code
Section 5097.98, are also to be treated according to this
statute.
b. If Native American human remains are discovered or
recognized on the project site, then Health and Safety Code
Section 7050.5 shall be followed.
C. Human remains and associated grave goods shall be treated
in the same manner per California Public Resources Code
section 5097.98(d)(1) and (2).
d. Preservation in place (i.e., avoidance) is the preferred
manner of treatment for discovered human remains and/or
grave goods.
e. Any discovery of human remains/grave goods shall be kept
confidential to prevent further disturbance.
UTILITIES AND SERVICE SYSTEMS
PPP UT-1: California Building Code. All future development
constructed under the Project shall be subject to the latest version
of the California Building Code (CBC) which outlines regulations
for building planning and construction in the state, including
Implementation
Timing
During grading
During grading
Prior to grading or
demolition/building
permit approval;
during construction
activities
Responsible Party
Project developers/
applicant,
construction
contractors, Native
American Monitor
Project developers/
applicant,
construction
contractors, Native
American Monitor
Project developers/
applicants and
construction
contractors
Verification Method
The City Community
Development Dept.
will review project
plans and
specifications to
ensure these
requirements are
met and would
monitor to verify
compliance.
The City Community
Development Dept.
will review project
plans and
specifications to
ensure these
requirements are
met and would
monitor to verify
compliance.
The City Building
Division will examine
project contracts,
plans, and
specifications for
Attachment A
Date Completed and
Initials
Initials:
Date:
Initials:
Date:
Initials:
Date:
City of Tustin 1 -1 3
Final EIR
September 2024
Enderle Center Rezone
Attachment A
Mitigation Measure
Implementation
Responsible Party
Verification Method
Date Completed and
Timing
Initials
occupancy classification, structural design, building materials,
these requirements
infrastructure needs and fire -resistance requirements.
and monitor for
compliance.
MM UT-1: Future proposed Projects shall prepare capacity
Prior to grading or
Project developers/
The City Public
analyses of existing water utilities in the area to ensure
building permit
applicant
Works Dept. will
Initials:
conveyance and pressure is adequate for future projects
approval
review the required
proposed. The developer shall then identify infrastructure
capacity analysis
Date:
improvements necessary for the proposed development. The
ensure adequate
developer will be responsible for preparing a capacity analysis
capacity is available
in coordination with the City. The capacity analysis and
prior to approval of
infrastructure improvements shall be reviewed and approved by
the construction
the City prior to approval of the construction permit.
permit.
MM UT-2: Future proposed Projects shall prepare capacity
Prior to grading or
Project developers/
The City Public
analyses of existing sewer utilities in the area to ensure
building permit
applicant
Works Dept. will
Initials:
conveyance and pressure is adequate for future projects
approval
review the required
proposed. The developer shall then identify infrastructure
capacity analysis
Date:
improvements necessary for the proposed development. The
ensure adequate
developer will be responsible for preparing a capacity analysis
capacity is available
in coordination with the EOCWD and the City. The developer shall
prior to approval of
then submit the sewer capacity analysis to the Orange County
the construction
Sanitation District (OC San) for review and verification that there
permit.
is available sewer capacity. The capacity analysis and
infrastructure improvements shall be reviewed and approved by
EOCWD, OC San, and the City prior to approval of the
construction permit.
City of Tustin 1 -14
Final EIR
September 2024