Loading...
HomeMy WebLinkAbout02 AGENDA REPORT CLEARWATER reduced MEETING DATE: AUGUST 11, 2026 TO: PLANNING COMMISSION FROM: COMMUNITY DEVELOPMENT DEPARTMENT SUBJECT: DEVELOPMENT AGREEMENT 2025-0001, TENTATIVE PARCEL MAP 2025-151/SUBDIVISION 2025-0003, CONDITIONAL USE PERMIT 2025- 0012, DESIGN REVIEW 2025-0008, GENERAL PLAN CONFORMITY 2026-0002, AND DENSITY BONUS REQUEST FOR THE DEVELOPMENT OF 172 RESIDENTIAL UNITS FOR ACTIVE SENIORS (INCLUDING 26 AFFORDABLE) AND AN APPROXIMATELY 143,000- SQUARE-FOOT ASSISTED LIVING AND MEMORY CARE FACILITY, WITHIN NEIGHBORHOOD D SOUTH OF THE TUSTIN LEGACY SPECIFIC PLAN APPLICANT:CONFLUENT DEVELOPMENT CD-CW (TUSTIN) LLC ATTN: JONATHAN RANKIN 2215 MARKET STREET DENVER, CO 80205 PROPERTY OWNER:CITY OF TUSTIN 300 CENTENNIAL WAY TUSTIN, CA 92780 LOCATION:SOUTHEAST CORNER OF WARNER AVENUE AND ARMSTRONG AVENUE (APN 430-481-012); GENERALLY BOUNDED BY WARNER AVENUE TO THE NORTH, VETERANS WAY TO THE EAST, JOHN JOHNSON WAY TO THE SOUTH, AND ARMSTRONG AVENUE TO THE WEST, WITHIN PLANNING AREA 8, 13, AND 14 (NEIGHBORHOOD D) OF THE TUSTIN LEGACY SPECIFIC PLAN. GENERAL PLAN:TUSTIN LEGACY SPECIFIC PLAN ZONING:TUSTIN LEGACY SPECIFIC PLAN (PLANNING AREA 8, 13, AND 14) EXISTING LAND USE:VACANT SITE AGENDA REPORT ITEM #2           1 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 2 ENVIRONMENTAL: AN ADDENDUM TO THE TUSTIN LEGACY SPECIFIC PLAN 2025 SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT HAS BEEN PREPARED PURSUANT TO CALIFORNIA ENVIRONMENTAL QUALITY ACT GUIDELINES SECTIONS 15164, 15162, AND 15168. THE ADDENDUM CONCLUDES THAT NONE OF THE CONDITIONS REQUIRING PREPARATION OF A SUBSEQUENT OR SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT HAVE OCCURRED, THEREFORE FURTHER ENVIRONMENTAL DOCUMENT- ATION IS NOT REQUIRED. REQUESTS: 1. DESIGN REVIEW 2025-0008 FOR THE DESIGN AND SITE LAYOUT OF 172 RESIDENTIAL UNITS FOR ACTIVE SENIORS, AN APPROXIMATELY 143,000 SQUARE FOOT ASSISTED LIVING AND MEMORY CARE FACILITY, SURFACE AND GARAGE PARKING, LANDSCAPING, AND ASSOCIATED SITE IMPROVEMENTS. 2. DENSITY BONUS REQUEST TO INCREASE THE ALLOWABLE DENSITY FROM 124 BASE UNITS TO 172 UNITS (38.75% DENSITY BONUS) BY PROVIDING 26 UNITS AFFORDABLE TO LOWER INCOME HOUSEHOLDS; ONE INCENTIVE RELATED TO THE AFFORDABLE UNIT BEDROOM MIX; AND WAIVERS RELATED TO PRIVATE OPEN SPACE, BUILDING SETBACKS, PATIO WALL HEIGHT, AND ARCHITECTURAL FEATURE ENCROACHMENT. 3. CONDITIONAL USE PERMIT 2025-0012 TO ESTABLISH AND OPERATE AN ASSISTED LIVING AND MEMORY CARE FACILITY. 4. TENTATIVE PARCEL MAP 2025-151/SUBDIVISION 2025-0003 TO SUBDIVIDE THE 6.14-ACRE SITE INTO TWO PARCELS. 5. DEVELOPMENT AGREEMENT 2025-0001 TO FACILITATE THE DEVELOPMENT AND CONVEYANCE OF THE 6.14-ACRE CITY-OWNED PROJECT SITE. 6. GENERAL PLAN CONFORMITY 2026-0002 TO DETERMINE THAT THE LOCATION, PURPOSE, AND EXTENT OF THE PROPOSED DISPOSITION OF THE 6.14-ACRE CITY-OWNED SITE (APN 430-481-012) WITHIN NEIGHBORHOOD D SOUTH OF THE TUSTIN LEGACY SPECIFIC PLAN, FOR THE DEVELOPMENT OF THE PROPOSED PROJECT, IS IN           2 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 3 CONFORMANCE WITH THE GENERAL PLAN AND THE TUSTIN LEGACY SPECIFIC PLAN. RECOMMENDATION: 1. That the Planning Commission adopt Resolution No. 4553, determining that the location, purpose, and extent of the proposed disposition of the 6.14-acre site within Neighborhood D South of the Tustin Legacy Specific Plan for the development of the proposed project is in conformance with the City’s adopted General Plan and Tustin Legacy Specific Plan. 2. That the Planning Commission adopt Resolution No. 4554, recommending that the City Council: a. Approve Design Review 2025-0008 for the design and site layout of the proposed project; b. Approve the Density Bonus request to increase the allowable density from 124 base units to 172 total units (38.75% density bonus) by providing 26 Lower Income units; one incentive related to the affordable unit bedroom mix; and waivers related to private open space, building setbacks, patio wall height, and architectural feature encroachment; c. Approve Conditional Use Permit 2025-0012 to establish and operate a 103- unit, approximately 143,000 square foot assisted living and memory care facility; d. Approve Tentative Parcel Map 2025-151 (Subdivision 2025-0003) to subdivide the 6.14-acre site into two parcels; e. Approve Development Agreement 2025-0001 to facilitate the development and conveyance of the 6.14-acre City-owned site; and f. Adopt an Addendum to the Tustin Legacy Specific Plan 2025 Supplemental Environmental Impact Report, finding that, pursuant to California Environmental Quality Act Guidelines Sections 15164, 15162, and 15168, the proposed project is within the scope of the Tustin Legacy Specific Plan 2025 Supplemental Environmental Impact Report and that no subsequent or supplemental Environmental Impact Report is required. APPROVAL AUTHORITY: x Design Review: Tustin Legacy Specific Plan Section 4.2.2 requires new developments to submit and obtain approval of a Site Plan and Design Review. Tustin City Code Section 9272 authorizes the Community Development Director to consider the Design Review application; however, since the proposal includes other applications that           3 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 4 require City Council approval, Design Review 2025-0008 shall be forwarded to the City Council for concurrent consideration. x Density Bonus: The proposed independent senior housing development is eligible for a density bonus pursuant to Tustin City Code Article 9, Chapter 1. This project includes a density bonus request, one incentive, and four development standard waivers. The density bonus request shall be considered by the City Council concurrently with the other applications. x Conditional Use Permit: Tustin Legacy Specific Plan Section 3.11 lists a “congregate care, convalescent, and assisted living facility” as a conditionally permitted use in Planning Area 8, 13, and 14. Tustin City Code Section 9291 authorizes the Planning Commission to consider Conditional Use Permit applications; however, since the proposal includes other applications that require City Council approval, Conditional Use Permit 2025-0012 shall be forwarded to the City Council for concurrent consideration. x Tentative Parcel Map: Tustin City Code Section 9311(g)(5) authorizes the Planning Commission to review and take action on Tentative Maps; however, since the proposal includes other applications that require City Council approval, Tentative Parcel Map 2025-151/Subdivision 2025-0003 shall be forwarded to City Council for concurrent consideration. x Development Agreement: Tustin Legacy Specific Plan Section 4.2.7 requires a Development Agreement in conjunction with, or prior to, the approval of any entitlements associated with private development. Pursuant to Tustin City Code Section 9611 and 9613, the Planning Commission shall consider the Development Agreement and make a recommendation to the City Council, and the City Council may accept, modify or disapprove the Development Agreement. Pursuant to Tustin City Code Section 9614, a Development Agreement shall be approved by the adoption of an ordinance. x General Plan Conformity: Pursuant to Section 65402(a) of the Government Code, the Planning Commission is required to determine whether the location, purpose, and extent of the proposed disposition of real property is consistent with the General Plan and Tustin Legacy Specific Plan. SUMMARY: Confluent Development (CD-CW (Tustin) LLC), the applicant, proposes to build a senior living community on a vacant, 6.14-acre lot owned by the City at the southeast corner of Warner Avenue and Armstrong Avenue. The community has two main components: x 172 apartments for active, independent seniors, including 26 apartments that would be rented at below-market rates to lower income households; and           4 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 5 x An approximately 143,000 square foot assisted living and memory care facility for seniors who need help with daily living activities or specialized care for memory loss or other forms of dementia. The role of the Planning Commission is to make a determination as to whether the sale of this City-owned parcel for development as a senior complex conforms with the City’s General Plan, and to recommend to the City Council whether the project should be approved. BACKGROUND: The project is located within Neighborhood D (Planning Area (PA) 8, 13, and 14) of the Tustin Legacy Specific Plan (TLSP), where residential uses, such as apartments, are permitted by right, and institutional uses, such as assisted living facilities, are conditionally permitted. The sale of the property requires the City to comply with the Surplus Land Act (SLA), a State law regulating how local public agencies dispose of public land. An Exclusive Negotiating Agreement (ENA) for the purchase and sale of the project site was executed on September 19, 2023, and was extended by the City Council as recently as April 21, 2026. The SLA requires that property sold by the City, and subsequently developed with 10 or more residential units, shall provide 15 percent or more of the units to households of Lower Income. The City declared the property exempt surplus land on June 15, 2021, pursuant to California Government Code section 54221(f)(1)(H), and the determination was approved by the California Department of Housing and Community Development (HCD) on September 15, 2022. The Disposition and Development Agreement (DDA) associated with the sale of the 6.14-acre site will be Figure 1. Tustin Legacy Specific Plan           5 i r·--- :PA 1-A ,! 1-C , PA 1-E IPA 1-J , : PA 1-D IPA 3 PA 1-H , PA 1-8 'rA ~..., PA6 PA 1-1 : PA 1-L i Project Site I PAl-F il : PAl-G t I ................ ~ PA9-12 -------·~-:"o!...,----.................. ; § I PAlS-A Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 6 considered by the City Council at a public meeting separate from this development proposal. Site Location The existing project site is a single lot totaling approximately 6.14 acres. The property is bounded by Warner Avenue to the north, Armstrong Avenue to the west, Veterans Way to the east, and John Johnson Way to the south. The site is within PA 8, 13, and 14 of the TLSP (Figure 1). The portion of PA 8, 13, and 14 south of Warner Avenue is more commonly referred to as Neighborhood D South. The site is north of a future extension of the Legacy Linear Park, across John Johnson Way. Beyond the park is the residential neighborhood known as The Landing (Figure 2). East of the site, across Veterans Way, is an undeveloped parcel. The City has received an application to develop a religious facility on that parcel, but as of the writing of this report, that application is still in the entitlement process. Figure 2. Surrounding Area Project Description The project would subdivide the existing 6.14-acre parcel into two parcels for conveyance purposes only and build the senior living community including: x A 172-unit independent senior residential community (“Active Adult” community), of which 26 units would be affordable to Lower Income households; and           6 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 7 x An approximately 143,000 square foot assisted living and memory care (“ALMC”) facility, including 75 assisted living units and 28 memory care units, for a total of 134 beds. Figure 3. Site Plan For planning purposes, only the Active Adult community counts as a residential use . The ALMC facility falls within the “congregate care, convalescent, and assisted living facility” land use category listed in the TLSP, and is considered a nonresidential (institutional) use. Building 1 (the Active Adult community) is a five-story building with a maximum height of 71 feet, and an average height of 64 feet. It is divided by internal firewalls into four structures (three habitable and one parking structure). It would contain a mix of one- and two-bedroom units for lease, with a building footprint of 79,819 square feet, and a gross floor area of 293,360 square feet. Building 2 (the ALMC facility) is one two-story building with a maximum height of 35.6 feet and an average height of 30 feet. It is also divided internally by firewalls into four structures (three habitable and one parking structure). It would contain studio, one-, and two-bedroom units for lease, with a building footprint of 75,921 square feet and gross floor area of approximately 143,000 square feet.           7 Johnson Way John Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 8 The project provides 278 parking spaces on-site within the buildings’ parking garages and on surface lots. An internal roundabout at the center of the site, reached from the main entry on John Johnson Way, provides a passenger loading area and access to guest parking and both garages. A second driveway on Veterans Way provides additional access to the ALMC parking garage. The project also includes 29,455 square feet of landscaping, recreation amenities, a bus turnout, and utility and stormwater improvements. ANALYSIS: Design Review TLSP Section 4.2.2 requires new developments to obtain Design Review (DR) approval under the TCC. DR 2025-0008 provides for the design and site layout of the Active Adult community and the ALMC facility. The buildings comply with applicable TLSP development standards as summarized in Attachment 7, except for standards requested to be waived pursuant to Density Bonus, law as discussed later in this report. The buildings feature a modern-contemporary architectural style and comply with TLSP Section 3.19, Urban Design Guidelines. The buildings use earth-toned colors and materials such as limestone tile veneer, brown fiber cement siding, and stucco in various finishes, with architectural accents including picket railings, exposed concrete, and metal trim. Building heights of up to 71 feet are proposed for the Active Adult building, and 35.6 feet for the ALMC facility, which is well below the 150-foot maximum allowed by the TLSP. Figure 4A. Building Perspectives           8 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 9 The Active Adult community provides a great room, mail and business center, activity room, fitness studio, and third-floor lounge. Outdoor amenities on the second and third floors include a 13,875 square foot central courtyard with a pool and spa, and a 4,837 square foot rooftop deck with a pickleball court and outdoor kitchen. Of the 172 units, 165 include a private outdoor balcony averaging 117 square feet. The ALMC facility includes an 18,162 square foot central courtyard on the first floor. The project would provide 29,455 square feet of landscaping, including grasses and drought- tolerant trees and shrubs along the project site boundary, in parking areas, and throughout the open space areas. The facility would share amenities with the adjacent Active Adult community, including a full-service kitchen, community theater, and salon. Figure 4B. Building Perspectives Circulation, Access, and Parking Local access is provided by Armstrong Avenue, Warner Avenue, John Johnson Way, and Veterans Way. The site is entered from driveways on John Johnson Way and Veterans Way. An internal roundabout at the center of the site provides resident drop-off and access to on-site parking. The traffic analysis prepared for the project estimates the project would generate 870 vehicle trips per day (of which 348 can be attributed to the ALMC facility), including 57 trips during the morning peak hour and 76 trips during the evening peak hour. These trips fall within the maximum daily trips allowed for Neighborhood D under the TLSP. Primary pedestrian access is provided via John Johnson Way, with secondary access available via Armstrong Avenue, Warner Avenue, and Veterans Way, where new           9 Building 1. Active Adult Community Building 2. Assisted Living and Memory Care Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 10 sidewalks would be constructed as part of the project. On-site walkways connect both building entries and the internal roundabout to the public sidewalk system at multiple points. Resident parking is provided within parking garages and surface lots. Under TCC Section 9263, the Active Adult community must provide one space per unit, plus one guest space per 10 units (190 spaces required); and the ALMC facility must provide one space for every three beds (45 spaces required for 134 beds). As shown below, the proposed parking exceeds the minimum requirements: TABLE 1. Parking Requirements Land Use TCC Requirement Required Provided Active Adult (172 units) 1 space/unit + 1 guest space/10 units 190 spaces 211 spaces ALMC Facility (103 units with 134 beds) 1 space/3 beds 45 spaces 67 spaces Total 235 spaces 278 spaces Density Bonus and Requested Deviations State law encourages affordable housing by allowing a project that sets aside affordable units in order to build more units than zoning would otherwise permit. This is called a density bonus. In exchange, the developer may also ask for a limited number of “incentives” (changes that reduce the cost of providing the affordable units) and “waivers” (relief from development standards that would physically prevent the project from being built at the allowed density). State law strictly limits the grounds on which a city may deny these requests. The applicant is requesting a 38.75 percent density bonus for the Active Adult community under State Density Bonus Law (Government Code Section 65915) and Article 9, Chapter 1 of the TCC. The bonus is calculated from 124 base units, with 26 units (21 percent of base units) reserved as affordable to Lower Income households: Table 2. Density Bonus Summary Gross Acres (Active Adult parcel) 2.86 Base Units 124 Lower Income Units Provided 26 (21% of base) Density Bonus 38.75% Total Permitted Units 173 Total Units Proposed 172           10 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 11 The 26 Lower Income units would be income-restricted and rented at affordable levels for at least 55 years, as required by Government Code Section 65915(c)(1). Rents will be calculated pursuant to Health and Safety Code Section 50053. The affordable units would be dispersed throughout the Active Adult community, and would have access to all project amenities. The applicant’s affordability obligations will be recorded in an agreement executed with the DDA and DA. Under Government Code Section 65915(d)(1), the applicant has requested one incentive: an affordable unit mix of 23 one-bedroom units and three two-bedroom units. State law requires the City to grant the incentive unless it makes a written finding, based on substantial evidence, that the incentive would not result in identifiable and actual cost reductions, would have a specific adverse impact on public health or safety or on a listed historical resource, or would be contrary to State or Federal law. Staff has not identified any basis for such a finding, and takes no exception to granting this incentive. Consistent with Government Code Section 65915(e)(1), the applicant also requests the following waivers of development standards. The applicant attests that, without these waivers, the project could not physically be built at the proposed density: x Private Open Space – The TLSP requires 100 square feet of private open space per unit. Of the 172 Active Adult units, 165 have private patios or balconies, averaging 117 square feet. Of those, 45 units exceed the 100-square-foot standard and 120 are smaller than the minimum. The remaining seven units cannot have balconies due to Orange County Fire Authority (OCFA) ladder pad accessibility criteria. A waiver is requested for the 127 units that do not meet the private open space standard. x Building Setbacks – Four architectural features encroach into the required setback: part of the parking structure along Armstrong Avenue (a five foot encroachment for about 37 linear feet); a ground-level patio along Warner Avenue (up to five feet, tapering to zero feet in each direction, for 202 linear feet); a ground-level patio at the Veterans Way corner (three feet, for 23 linear feet); and a second-floor balcony at the Warner Avenue and Veterans Way corner (five feet, for 23 linear feet). x Patio Wall Height – The TLSP allows walls higher than three feet for noise mitigation, but not within the building setback. A waiver is requested to allow the patio wall along Warner Avenue to exceed three feet in height within the setback area to provide sound mitigation, seclusion, and security for residents. x Architectural Feature Encroachment – At the corner of Warner Avenue and Veterans Way, an architectural feature at the upper corner of the building encroaches five feet toward the lot line, exceeding the three-foot encroachment allowance. Under State law, the City cannot deny the requested waivers unless it finds that a waiver would have a specific, adverse impact on public health or safety for which there is no feasible way to mitigate or avoid the impact, would impact a listed historical resource, or would be contrary to State or Federal law. No such circumstances have been identified.           11 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 12 Conditional Use Permit While the TLSP land use regulations for PA 8, 13, and 14 designate the Active Adult community, as a multiple family residential use, to be permitted by right, “congregate care, convalescent, and assisted living” is listed as a conditionally permitted use. The proposed 103-unit, approximately 143,000 square foot ALMC facility falls within this land use category, with memory care being a specialized subset of assisted living. No convalescent use is proposed. CUP 2025-0012 would authorize the establishment and operation of the facility. Assisted living serves older adults who live independently in their own units, but need help with daily activities such as bathing, dressing, meals, housekeeping, or managing medications. The proposed facility would include 75 assisted living units. Memory care is a specialized form of assisted living for residents living with memory- impairing conditions, such as Alzheimer’s or other forms of dementia. It is provided in a separate, secured wing designed to keep residents safe and oriented, with staff trained specifically in such care. The proposed facility would include 28 memory care units. Together, the 103 units would provide a total of 134 beds. Residents live at the facility full time, and care staff are present to support residents on an ongoing basis. Assisted living facilities must be licensed by the California Department of Social Services (CDSS) and must receive additional state approvals to operate a memory care program. The Community Care Licensing Division of CDSS ensures such facilities comply with State operational standards, staffing ratios, resident care, and more. Figure 5. ALMC Facility from John Johnson Way           12 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 13 The facility would include a great room, wellness center, fitness area, aqua lounge, dining room, and various activity spaces. The memory care wing would contain purpose-built areas including an activity room, dining area, and communal living room. Outdoor amenities include an 18,162 square foot central courtyard providing secure outdoor space for residents. The facility would also share amenities with the adjacent Active Adult community, including a full-service kitchen, community theater, café and market, and salon. The facility is compatible with the adjacent Active Adult community, and the surrounding Mixed-Use Urban designation of Neighborhood D. Because most residents of assisted living and memory care facilities do not drive, the facility generates comparatively little traffic compared to other uses permitted in PA 8, 13, and 14. Conditions of Approval are attached as Exhibit B to Attachment 2, and address the development and ongoing operation of the facility, including identifying State licensing requirements for such facilities, limiting the residential component to be exclusively for seniors, and more. Tentative Parcel Map TPM 2025-151 (SUB 2025-0003) divides the 6.14-acre site into two parcels for conveyance purposes only: one parcel for the Active Adult community and one for the ALMC facility (Attachment 2, Exhibit C). The map also provides required easements, such as for bioswale access and maintenance and vehicle access rights. TPM 2025-151/SUB 2025-0003 was reviewed for compliance with the Subdivision Map Act, the TCC, and the Tustin Subdivision Manual. The Public Works Department has determined that the map is technically correct. Findings supporting approval of the map are included in Planning Commission Resolution No. 4554 (Attachment 2). TCC Section 9311(g)(5) authorizes the Planning Commission to act on tentative maps; however, since the proposal includes other entitlement applications that require City Council approval, TPM 2025-151/SUB 2025-0003 will be forwarded to the City Council for concurrent consideration. Other Agencies’ Input In compliance with the State Subdivision Map Act, the City sent letters along with a copy of TPM 2025-151 to affected agencies. The City received one response (Attachment 5), from the Rancho Santiago Community College District, which operates a Criminal Justice Academy at 15591 Armstrong Avenue, diagonally across the intersection from the project site. The Community College District recommends a spatial buffer between its facilities and the project site to reduce noise transmission. Staff confirmed that the academy’s operations include administration, education, and outdoor physical training drills, but do not include firearms training, or other activities with sustained amplified noise.           13 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 14 The outdoor training field, which would be the most relevant source of transient loud noises, such as whistles and yelling, is across Warner Avenue, and more than 600 feet northwest of the project site. The academy building itself sits between the training field and the project site. This distance is sufficient to reduce sounds from the training field to levels below ambient traffic noise, which the proposed buildings are designed to insulate against. Development Agreement A DA gives both the applicant and the City certainty that once the project is approved, it may proceed under the rules, conditions, and regulations in place at the time of approval, and the City is assured that its objectives, goals, and policies will be carried out. TLSP Section 4.2.7 requires a DA with, or before, approval of any entitlements for private development. DA 2025-0001 is included as Exhibit A of Attachment 2 (Draft Ordinance No. 1580). It provides for the orderly implementation of the General Plan and TLSP, completion of the project consistent with the DDA, and certain assurances to the applicant and the City. The DA includes, but is not limited to, the following provisions: x Public benefits improvements including sidewalks, parkway landscaping, and irrigation along the project’s street frontages, x Affordable housing obligations, x Construction of infrastructure and public facilities, x Maintenance agreements, and x Annual review of Developer’s performance, among other provisions. Under TCC Section 9611, the Planning Commission reviews the DA and makes a recommendation to the City Council. Construction and Phasing Construction would occur in a single phase lasting approximately 24 months, beginning in late 2026 and ending in late 2028. Work would include site preparation, grading, building construction, and more. All construction would occur within the hours allowed by TCC Section 4616, which prohibits construction between 6:00 p.m. and 7:00 a.m. Monday through Friday, between 5:00 p.m. and 9:00 a.m. on Saturdays, and at all hours on Sundays and City-observed federal holidays. The project also includes on-site storm drain facilities designed to capture and treat runoff, including oversized storm drains, two underground storage chambers, and a modular wetland system along Armstrong Avenue.           14 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 15 General Plan Conformity The City owns the project site and intends to sell the land to the applicant. Before the City sells property, Government Code Section 65402(a) requires the Planning Commission to report on whether the location, purpose, and extent of the sale conform to the City’s General Plan. The General Plan designates the site as TLSP, which envisions the area as an active living, working, shopping, and recreation environment with access to amenities and facilities that support the community. The proposed sale supports various goals in the Land Use Element and Housing Element of the General Plan, which are included in Planning Commission Resolution No. 4553 (Attachment 1). Accordingly, Staff recommends the Planning Commission adopt Planning Commission Resolution No. 4553, finding that the location, purpose, and extent of the proposed sale of the project site to the applicant is in conformance with the approved General Plan. Environmental Review The California Environmental Quality Act (CEQA) requires the City to review a project’s environmental effects before approving it. When a project fits within the scope of a previously certified environmental study, the City may rely on that earlier study instead of preparing a new one. That is the case for this project. On January 16, 2001, the City of Tustin certified the Program Final Environmental Impact Statement/Environmental Impact Report (FEIS/EIR) for the reuse and disposal of Marine Corps Air Station (MCAS) Tustin. The City later adopted several supplements and addenda to that document: Resolution No. 04-76 on December 6, 2004 (a supplement for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road); Resolution No. 06-43 on April 3, 2006 (an addendum), Resolution No. 13-32 on May 13, 2013 (a second addendum), and Resolution No. 17-23 on July 5, 2017 (a second supplement). On December 17, 2024, the City Council adopted Resolution No. 24-76, approving a third supplement to the FEIS/EIR (referred to here as the TLSP 2025 SEIR, State Clearinghouse (SCH) No. 1994071005). That study evaluated the environmental effects of an amendment to the TLSP implementing the City’s Sixth Cycle Housing Element Rezone Project, which increased residential capacity within TLSP Neighborhoods D (North and South) and G. The FEIS/EIR, along with its addenda and supplements, is a program EIR under CEQA. An addendum to the TLSP 2025 SEIR was prepared for this project (Attachment 3) under CEQA Guidelines Sections 15164, 15162, and 15168. Because the project includes an institutional assisted living and memory care component, in addition to residential uses, it was evaluated through an addendum tiering from the TLSP 2025 SEIR, rather than a statutory exemption available to residential projects built under a specific plan. The addendum is supported by project-specific technical studies and evaluates whether any           15 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 16 of the conditions described in CEQA Guidelines Section 15162 have occurred, which would require the preparation of a subsequent EIR. The addendum concludes that the proposed project is within the scope of the development already analyzed in the TLSP 2025 SEIR, that no new significant environmental effects or substantial increases in the severity of previously identified effects would occur, and that no subsequent or supplemental EIR is required. All mitigation measures from the TLSP 2025 SEIR Mitigation Monitoring and Reporting Program applicable to the project have been incorporated into the project’s Conditions of Approval. Staff recommends that the Planning Commission recommend the City Council adopt the addendum together with its action on the project entitlements. Public Notice The public notice for the project was published in the Tustin News and posted at the project site on July 30, 2026, and was mailed to property owners within a 300-foot radius of the project site and to interested parties. No public comments were received at the time of writing this report. CONCLUSION The proposed DR 2025-0008, Density Bonus request, CUP 2025-0012, TPM 2025-151 (SUB 2025-0003), DA 2025-0001, and GPC 2026-0002 are consistent with and implement the TLSP and the General Plan. The project would deliver needed senior housing, including affordable senior housing, and senior care services within Tustin. Accordingly, staff recommends that the Planning Commission approve GPC 2026-0002, and recommend that the City Council adopt the Addendum to the TLSP 2025 SEIR and approve the proposed DR 2025-0008, Density Bonus request, CUP 2025-0012, TPM 2025-151 (SUB 2025-0003), and DA 2025-0001, including the requested incentive and development standard waivers.           16 Planning Commission Report August 11, 2026 Clearwater at Tustin Legacy Page 17 Prepared by: ______________________________ Jorge Maldonado, Senior Planner Approved by: ______________________________ Raymond Broihahn Barragan, Principal Planner ______________________________ Jay Eastman, AICP, Assistant Director - Planning Attachments: 1. Planning Commission Resolution No. 4553 – GPC 2026-0002 2. Planning Commission Resolution No. 4554 – DA 2025-0001, TPM 2025-151/SUB 2025-0003, CUP 2025-0012, DR 2025-0008 and Density Bonus x Exhibit A: Draft Ordinance No. 1580 and Development Agreement (DA) 2025-0001 x Exhibit B: Conditions of Approval x Exhibit C: Tentative Parcel Map (TPM) 2025-151 3. Addendum to the Tustin Legacy Specific Plan 2025 SEIR 4. Submitted Entitlement Package 5. Other Agencies’ Comments on TPM 2025-151 6. Radius and Location Map 7. Land Use Application Fact Sheet           17 RESOLUTION NO. 4553 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF TUSTIN, CALIFORNIA, DETERMINING THAT THE LOCATION, PURPOSE, AND EXTENT OF THE PROPOSED DISPOSITION OF LOT 14 OF TRACT 18197, AN APPROXIMATE 6.14-ACRE SITE WITHIN PLANNING AREA 8, 13, AND 14 (NEIGHBORHOOD D) OF THE TUSTIN LEGACY SPECIFIC PLAN, FOR THE DEVELOPMENT OF 172 RESIDENTIAL UNITS FOR ACTIVE SENIORS, INCLUDING 26 UNITS AFFORDABLE TO LOWER INCOME HOUSEHOLDS, AND AN APPROXIMATELY 143,000 SQUARE FOOT ASSISTED LIVING AND MEMORY CARE FACILITY, IS IN CONFORMANCE WITH THE GENERAL PLAN AND TUSTIN LEGACY SPECIFIC PLAN The Planning Commission of the City of Tustin does hereby resolve as follows: I. The Planning Commission finds and determines as follows: A. That a proper application was submitted by Confluent Development, through its project entity CD-CW (Tustin) LLC, for the development of 172 residential units for active seniors, including 26 units affordable to Lower Income households, and an approximately 143,000 square foot assisted living and memory care facility containing 103 units, on an approximately 6.14-acre site. The site is currently owned by the City of Tustin within Planning Area 8, 13, and 14 (Neighborhood D) of the Tustin Legacy Specific Plan. B. That the City wishes to dispose of Lot 14 of Tract 18197, an approximate 6.14-acre site within Planning Area 8, 13, and 14, to accommodate the development of 172 residential units for active seniors, an approximately 143,000 square foot assisted living and memory care facility, parking garages and surface parking, landscaping, recreational amenities, and associated site improvements. C. That Government Code Section 65402(a) provides that no real property shall be disposed of until the location, purpose, and extent of the project has been reported upon by the local planning agency as to the conformity with the adopted general plan. D. That the disposition of the site is subject to the Surplus Land Act (Government Code Section 54220 et seq.). The City declared the property exempt surplus land on June 15, 2021, pursuant to Government Code Section 54221(f)(1)(H), and the California Department of Housing and $77$&+0(17 18 Resolution No. 4553 August 11, 2026 Page 2 Community Development approved the City’s determination on September 15, 2022. E. That the General Plan designates the site as Tustin Legacy Specific Plan, which envisions the area as an active living, working, shopping, and recreation environment with access to amenities and facilities that support the community. The proposed disposition supports several General Plan Land Use and Housing Element goals, including the following: 1. 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. 2. Land Use Element 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. 3. Land Use Element Goal 4: Assure a safe, healthy and aesthetically pleasing community for residents and businesses. 4. Land Use 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. 5. Land Use Goal 8: Ensure that necessary public facilities and services should be available to accommodate development proposed on the Land Use Policy Map. 6. Land Use Goal 14: Continue to implement the Specific Plan/Reuse Plan for MCAS Tustin [the Tustin Legacy Specific Plan] which maximizes the appeal of the site as a mixed-use, master planned development. 7. 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 Regional Housing Needs Assessment allocation. 19 Resolution No. 4553 August 11, 2026 Page 3 8. Housing Element Goal 2: Promote fair housing opportunities for all people regardless of their special characteristics as protected under State and Federal fair housing laws. F. That the proposed project would provide senior housing, affordable senior housing, and senior care services responsive to the needs of the City’s older adult population, consistent with the General Plan goals identified above. G. That Section 65402(a) of the Government Code authorizes the Planning Commission to determine whether the location, purpose, and extent of the proposed disposition of real property is consistent with the General Plan. H. That a public hearing was duly noticed, called, and held on the associated entitlement project and General Plan Conformity (GPC) 2026-0002 by the Planning Commission on August 11, 2026. I. That the General Plan Conformity determinations required by Government Code Section 65402(a) are not “projects” requiring environmental review pursuant to the California Environmental Quality Act. II. The Planning Commission hereby determines that the location, purpose, and extent of the disposition of Lot 14 of Tract 18197 to CD-CW (Tustin) LLC for the development of 172 residential units for active seniors, including 26 units affordable to Lower Income households, an approximately 143,000 square foot assisted living and memory care facility, parking garages and surface parking, landscaping, recreational amenities, and associated site improvements is in conformance with the General Plan and the Tustin Legacy Specific Plan. 20 Resolution No. 4553 Page 4 PASSED AND ADOPTED by the Planning Commission of the City of Tustin at a regular meeting held on the 11th day of August 2026. AMY MASON Chairperson ALEXA SMITTLE Planning Commission Secretary APPROVED AS TO FORM: ___________________________ MICHAEL DAUDT Assistant City Attorney 21 Resolution No. 4553 Page 5 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN ) I, ALEXA SMITTLE, the undersigned, hereby certify that I am the Planning Commission Secretary of the City of Tustin, California; that Resolution No. 4553 was duly passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 11th day of August 2026. PLANNING COMMISSIONER AYES: _________________________________ PLANNING COMMISSIONER NOES: _________________________________ PLANNING COMMISSIONER ABSTAINED: _________________________________ PLANNING COMMISSIONER ABSENT: _________________________________ ___________________________ ALEXA SMITTLE Planning Commission Secretary 22 RESOLUTION NO. 4554 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF TUSTIN, CALIFORNIA, RECOMMENDING THAT THE TUSTIN CITY COUNCIL ADOPT AN ADDENDUM TO THE TUSTIN LEGACY SPECIFIC PLAN 2025 SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT AND APPROVE DEVELOPMENT AGREEMENT 2025-0001, SUB 2025-0003 / TENTATIVE PARCEL MAP 2025-151, CONDITIONAL USE PERMIT 2025-0012, DESIGN REVIEW 2025-0008, AND A DENSITY BONUS REQUEST FOR THE DEVELOPMENT OF 172 RESIDENTIAL UNITS FOR ACTIVE SENIORS AND AN APPROXIMATELY 143,000 SQUARE FOOT ASSISTED LIVING AND MEMORY CARE FACILITY ON LOT 14 OF TRACT 18197 WITHIN PLANNING AREA 8, 13, AND 14 (NEIGHBORHOOD D) OF THE TUSTIN LEGACY SPECIFIC PLAN. The Planning Commission of the City of Tustin does hereby resolve as follows: I. The Planning Commission finds and determines as follows: A. That a proper application has been submitted by Confluent Development, through its project entity CD-CW (Tustin) LLC, for the development of 172 residential units for active seniors, including 26 units affordable to Lower Income households, and an approximately 143,000 square foot assisted living and memory care facility containing 103 units, on Lot 14 of Tract 18197, an approximately 6.14-acre site currently owned by the City of Tustin within Planning Area (PA) 8, 13, and 14 (Neighborhood D) of the Tustin Legacy Specific Plan (TLSP). B. That the development application includes the following requests: 1. Development Agreement (DA) 2025-0001 to facilitate the development and conveyance of the approximately 6.14-acre City-owned site. 2. Tentative Parcel Map (TPM) 2025-151/SUB 2025-0003 to subdivide the approximately 6.14-acre site into two (2) numbered parcels for the development of the active senior residential community and the assisted living and memory care facility. 3. Conditional Use Permit (CUP) 2025-0012 to establish and operate a 103- unit, approximately 143,000 square foot assisted living and memory care facility. 4. Design Review (DR) 2025-0008 for the site layout and building design of 172 residential units for active seniors, an approximately 143,000 square foot assisted living and memory care facility, parking garages and surface parking, landscaping, and associated site improvements. $77$&+0(17 23 Resolution No. 4554 August 11, 2026 Page 2 5. Density Bonus to increase the density of the project, together with one (1) incentive and four (4) waivers/reductions of development standards to facilitate the proposed project. C. That the site is zoned as TLSP (SP-1) within PA 8, 13, and 14 (Neighborhood D), and designated as TLSP by the General Plan. In addition, the project has been reviewed for consistency with the Air Quality Sub-element of the City of Tustin General Plan and has been determined to be consistent with the Air Quality Sub-element. D. That TLSP Section 4.2.7 requires all private nonresidential development at Tustin Legacy to obtain a DA in accordance with Section 65864 et seq. of the Government Code and Sections 9600 to 9619 of the Tustin City Code. In compliance with TCC Section 9611, the Planning Commission must make a recommendation on the proposed DA to the City Council. The DA can be supported by the following findings: 1. The project is consistent with the objectives, policies, general land uses and programs specified in the General Plan and the Tustin Legacy Specific Plan. 2. The project includes uses compatible with other uses authorized in the district in which the real property is located (PA 8, 13, and 14) in that residential uses are permitted by right, congregate care, convalescent, and assisted living facilities are conditionally permitted, and similar and compatible uses are constructed and envisioned within close proximity of the project site. 3. The project is in conformity with the public necessity, public convenience, general welfare, and good land use practices in that the project would provide 172 residential units for active seniors inclusive of 26 units affordable to Lower Income households, together with an approximately 143,000 square foot assisted living and memory care facility, providing additional options of housing types and senior care services responsive to the needs of the City’s older adult population. 4. The project will not be detrimental to the health, safety, and general welfare. The project will comply with the TLSP, TCC, and other regulations to ensure that the project will not be detrimental in any way. 5. The project will not adversely affect the orderly development of property in that the proposed project is orderly, well designed, and equipped with necessary infrastructure and amenities to support existing and future residents and businesses in Tustin Legacy. 24 Resolution No. 4554 August 11, 2026 Page 3 6. The provisions of the proposed DA and conditions of approval will ensure that the project will have a positive fiscal impact on the City. E. Pursuant to TCC 9311(g)(5), the Planning Commission is authorized to review and take action on Tentative Maps; however, since the proposal includes other applications that require City Council approval, TPM 2025- 151/SUB 2025-0003 shall be forwarded to City Council for concurrent consideration. F. As conditioned, TPM 2025-151 (SUB 2025-0003) will be in conformance with the General Plan, TLSP, State Subdivision Map Act, and the City’s Subdivision Code as follows: 1. That the site is located in PA 8, 13, and 14 (Lot 14 of Tract 18197) of the TLSP, which is designated for Mixed-Use Urban and that the proposed development as conditioned will be physically suitable for the type of development and proposed density of development; 2. That the proposed subdivision divides the site into two parcels for conveyance purposes only and provides for required easements, including bioswale access and maintenance and vehicular access rights; 3. The subdivider will be required to provide funding towards the project’s fair share of Tustin Legacy Backbone Infrastructure Program, which includes improvements that are required to serve new development at Tustin Legacy, including but not limited to roadway improvements; traffic and circulation mitigation to support development at Tustin Legacy; domestic and reclaimed water; sewer; telemetry systems; storm drains and flood control channels; retention and detention systems, open space and public recreational facilities and; utility backbone systems; 4. That the proposed subdivision would not have a new impact on school district facilities within the Tustin Unified School District (TUSD) or Santa Ana Unified School District (SAUSD) in that school impacts for development were considered in the MCAS Reuse Plan, which identified school facility sites that will be conveyed to the TUSD by the Federal Department of Education or the City of Tustin to serve development of property at Tustin Legacy. The TLSP, the Final Joint Program Environmental Impact Statement/Environmental Impact Report (FEIS/EIR), its supplements and addenda, and conditions of approval of the proposed subdivision also require proof of payment of appropriate school fees as adopted by the TUSD and SAUSD prior to issuance of building permits in accordance with the City’s procedures; 5. That the design of the subdivision or the proposed improvements are not likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife in their habitat; 25 Resolution No. 4554 August 11, 2026 Page 4 6. The proposed subdivision is not located within a 100-year flood plain according to the Federal Emergency Management Agency map for the area; and 7. Adequate infrastructure to support buildout of the project and construction of public infrastructure and utility systems is required in accordance with the conditions of approval. G. Pursuant to the TLSP and TCC Section 9272, the Planning Commission finds that the location, size, architectural features, and general appearance of the proposed development will not impair the orderly and harmonious development of the area, the present or future development therein, or the occupancy as a whole. In making such findings, the Commission has considered at least the following items: 1.Height, bulk, and area of buildings. The five-story active senior building has a maximum height of 71 feet and the two-story assisted living and memory care building a maximum of 35.6 feet, both of which are below the 150-foot maximum permitted. Building footprints of 79,819 and 75,921 square feet are distributed across the 6.14-acre site such that building mass is concentrated along Armstrong Avenue and scales down toward Veterans Way. 2.Setbacks and site planning. The buildings are sited to frame all four street frontages, with resident parking placed within structures. Limited encroachments into the required building setback along Armstrong Avenue, Warner Avenue, and Veterans Way accommodate ground-level patios, a second-floor balcony, and a corner architectural feature, all of which are authorized pursuant to requested density bonus waivers. 3.Exterior materials and colors. The buildings use an earth-toned palette of limestone tile veneer, brown fiber cement siding, and stucco in varied finishes, with accents including picket railings, exposed concrete, and metal trim, consistent with TLSP Section 3.19. 4.Type and pitch of roofs. Both buildings use low-slope roofs concealed behind parapets, with maximum building heights measured to the top of parapet. 5.Size and spacing of windows, doors, and other openings. Window and door openings are distributed to articulate each façade and reduce apparent building mass. Private balconies are provided on 165 of the 172 active senior units; the seven units without balconies are located where Orange County Fire Authority ladder pad access is required. 26 Resolution No. 4554 August 11, 2026 Page 5 6.Roof structures. Rooftop improvements on the active senior building include a 4,837 square foot amenity deck with a pickleball court and outdoor kitchen. Rooftop mechanical equipment is screened from public view by parapets. 7.Location, height, and standards of exterior illumination. Exterior lighting is designed to provide safe pedestrian and vehicular circulation while shielding and directing light downward to avoid spillover onto adjacent properties. As conditioned, exterior illumination will comply with the standards of the Tustin Security Ordinance. 8.Landscaping, parking area design, and traffic circulation. The project provides 29,455 square feet of landscaping, including drought-tolerant trees and shrubs along the site boundary, within parking areas, and throughout open space areas. A total of 278 parking spaces are provided within parking garages and two surface lots, which exceeds the minimum number of spaces required by 43 spaces (235 required). Site access is taken from John Johnson Way and Veterans Way, with an internal roundabout providing passenger loading and access to guest parking and both garages, and a bus turnout serving the assisted living and memory care facility. 9.Location and appearance of equipment located outside an enclosed structure. Ground-mounted mechanical, electrical, and utility equipment is located away from street frontages and screened by walls and landscaping, and rooftop equipment is screened by parapets. 10. Location and method of refuse storage. Refuse and recycling for the Active Adult building are deposited down trash chutes located at each floor and stored within enclosed trash rooms at the ground floor of each building. Dumpsters are then moved to collection areas on-site accessible from internal drive aisles. For the assisted living and memory care facility, refuse is collected by staff and deposited at a dedicated trash enclosure accessible from internal drive aisles. 11. Physical relationship of proposed structures to existing structures in the neighborhood. The site is bounded by public streets on all four sides. The two-story assisted living and memory care building provides a gentler visual for most of the project frontage on John Johnson Way, facing the park. 12. Appearance and design relationship of proposed structures to existing structures and possible future structures in the neighborhood and public thoroughfares. The modern-contemporary architecture and earth-toned palette are consistent with the design character established elsewhere in Neighborhood D. Building orientation and façade articulation along Warner Avenue, Armstrong Avenue, 27 Resolution No. 4554 August 11, 2026 Page 6 Veterans Way, and John Johnson Way establish a consistent street presence that will complement future development on adjoining parcels. 13. Development Guidelines and criteria as adopted by the City Council. The project complies with TLSP Section 3.19, Urban Design Guidelines, and with the development standards applicable to Planning Area 8, 13, and 14, except for those standards for which density bonus waivers have been requested. H. That TLSP Section 3.11 lists a “congregate care, convalescent, and assisted living facility” as a conditionally permitted use within PA 8, 13, and 14, and TCC Section 9291 grants the Planning Commission the authority to consider and act on such requests for a CUP. The proposed assisted living and memory care facility falls within this land use category, with memory care being a specialized subset of assisted living. No convalescent use is proposed. I. That in determining whether to recommend approval of the CUP application, the Planning Commission finds that the establishment, maintenance, and operation of the proposed use will not, under the circumstances of this case, be detrimental to the health, safety, morals, comfort, or general welfare of the persons residing or working in the neighborhood of such proposed use, nor be injurious or detrimental to the property and improvements in the neighborhood of the subject property, or to the general welfare of the City of Tustin, in that: 1. The proposed assisted living and memory care facility is a conditionally permitted use within PA 8, 13, and 14 pursuant to Tustin Legacy Specific Plan Section 3.11. 2. The facility is compatible with the Mixed-Use Urban designation of Neighborhood D and with the adjacent residential community for active seniors, with which it shares amenities, and with the future extension of the Legacy Linear Park to the south. 3. At two stories and a maximum height of 35.6 feet, the facility constitutes the lower-scale portion of the project and provides an appropriate transition in building scale toward the future park and adjoining residential neighborhood. 4. The operations of the facility occur almost entirely within the enclosed building or within the 18,162 square foot interior courtyard, which provides secure outdoor space for residents. 5. Because most residents of assisted living and memory care facilities do not drive, the facility generates comparatively little traffic. The traffic analysis prepared for the project estimates the facility would generate approximately 348 vehicle trips per day. 28 Resolution No. 4554 August 11, 2026 Page 7 6. The facility provides 67 parking spaces, exceeding the 45 spaces required by TCC Section 9263 for 134 beds, and includes a bus turnout and a dedicated bus space to serve resident transportation. 7. Assisted living facilities are licensed by the California Department of Social Services (CDSS), and the operator must obtain additional State approvals to operate a memory care program. The Community Care Licensing Division (CCLD) of CDSS regulates compliance with State operational standards, staffing, and resident care requirements. 8. Conditions of approval have been included to address the development and ongoing operation of the facility. J. That the proposed residential community for active seniors is eligible for a density bonus pursuant to State Density Bonus Law (Government Code Section 65915) and TCC Article 9, Chapter 1. By reserving 26 units (21 percent of the 124 base units) as affordable to Lower Income households for a minimum of 55 years, the applicant is entitled to a 38.75 percent density bonus, which allows a total of 173 units, of which 172 units are proposed. K. That the requested incentive consisting of an affordable unit mix of 23 one- bedroom units and three two-bedroom units is consistent with and in compliance with Density Bonus Law. Pursuant to Government Code Section 65915(d)(1), the City must grant the requested incentive unless it makes a written finding, based upon substantial evidence, that the incentive would not result in identifiable and actual cost reductions, would have a specific adverse impact upon public health or safety or upon a property listed in the California Register of Historical Resources, or would be contrary to State or Federal law. No basis for such a finding has been identified. L. That the requests for waivers of development standards relating to private open space, building setbacks, patio wall height, and an architectural feature encroachment are appropriate, consistent with, and in compliance with Density Bonus Law, and are consistent with the intent of the established standards and the TLSP. Pursuant to Government Code Section 65915(e)(1), the City may not deny the requested waivers unless it finds that a waiver would have a specific, adverse impact upon public health or safety for which there is no feasible method to satisfactorily mitigate or avoid the impact, would have an adverse impact on a property listed in the California Register of Historical Resources, or would be contrary to State or Federal law. No such circumstances have been identified. M. That the project will exceed the amount of required parking by proposing 278 parking spaces where 235 spaces are required by TCC Section 9263. 29 Resolution No. 4554 August 11, 2026 Page 8 N. That a public hearing was duly called, noticed, and held on said applications on August 11, 2026, by the Planning Commission. O.On January 16, 2001, the City of Tustin certified the Program Final Environmental Impact Statement/Environmental Impact Report (FEIS/EIR) for the reuse and disposal of MCAS Tustin. On December 6, 2004, the City Council adopted Resolution No. 04-76 approving a supplement to the FEIS/EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted Resolution No. 06-43 approving an addendum to the FEIS/EIR. On May 13, 2013, the City Council adopted Resolution No. 13- 32 approving a second addendum to the FEIS/EIR. On July 5, 2017, the City Council adopted Resolution No. 17-23 approving a second supplement to the FEIS/EIR. On December 17, 2024, the City Council adopted Resolution No. 24-76 approving a third supplement to the FEIS/EIR (the TLSP 2025 SEIR, State Clearinghouse No. 1994071005), which evaluated the environmental effects in conjunction with an amendment to the TLSP to implement the programs and policies of the City’s Sixth Cycle Housing Element Rezone Project, which increased residential capacity within TLSP Neighborhoods D (North and South) and G (Housing Element Sites 1A, 1B and 2). The FEIS/EIR, along with its addenda and supplements, is a program EIR under the California Environmental Quality Act (CEQA). The FEIS/EIR, addenda, and supplements considered the potential environmental impacts associated with development on the former Marine Corps Air Station, Tustin. Because the proposed project includes an institutional assisted living and memory care component in addition to residential uses, the project has been evaluated through an addendum tiering from the TLSP 2025 SEIR pursuant to CEQA Guidelines Sections 15164, 15162, and 15168. An addendum to the TLSP 2025 SEIR has been prepared for the proposed project and is supported by project-specific technical studies. Based upon the addendum, the Planning Commission finds that: 1. The proposed project is within the scope of the development previously analyzed in the TLSP 2025 SEIR; 2. No substantial changes are proposed in the project, and no substantial changes have occurred with respect to the circumstances under which the project is undertaken, that would require major revisions to the TLSP 2025 SEIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; 30 Resolution No. 4554 August 11, 2026 Page 9 3. No new information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the TLSP 2025 SEIR was certified, has become available; 4. None of the conditions described in CEQA Guidelines Section 15162 calling for preparation of a subsequent or supplemental EIR have occurred, and only minor technical changes or additions are necessary, such that an Addendum is the appropriate document pursuant to CEQA Guidelines Section 15164; and 5. Pursuant to CEQA Guidelines Section 15164(c), the Addendum need not be circulated for public review, and pursuant to Section 15164(d), the Addendum has been considered together with the TLSP 2025 SEIR prior to making a decision on the project. All mitigation measures from the MCAS Tustin FEIS/EIR, TLSP 2017 SEIR, and TLSP 2025 SEIR Mitigation Monitoring and Reporting Programs applicable to the project have been incorporated into the conditions of approval attached hereto as Exhibit B. II. The Planning Commission hereby adopts Resolution No. 4554, recommending that the City Council adopt the Addendum to the TLSP 2025 SEIR, adopt Ordinance No. 1580 for DA 2025-0001 attached hereto as Exhibit A, and approve SUB 2025-0003/TPM 2025-151, CUP 2025-0012, DR 2025-0008, and the Density Bonus request together with the requested incentive and waivers, subject to the conditions attached hereto as Exhibit B. PASSED AND ADOPTED by the Planning Commission of the City of Tustin at a regular meeting on the 11th day of August 2026. AMY MASON Chairperson ALEXA SMITTLE Planning Commission Secretary APPROVED AS TO FORM: ___________________________ MICHAEL DAUDT Assistant City Attorney 31 Resolution No. 4554 August 11, 2026 Page 10 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN ) I, ALEXA SMITTLE, the undersigned, hereby certify that I am the Planning Commission Secretary of the City of Tustin, California; that Resolution No. 4554 was duly passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 11th day of August 2026. PLANNING COMMISSIONER AYES: _______________________________ PLANNING COMMISSIONER NOES: _______________________________ PLANNING COMMISSIONER ABSTAINED: _______________________________ PLANNING COMMISSIONER ABSENT: _______________________________ ALEXA SMITTLE Planning Commission Secretary Exhibit A – Draft Ordinance No. 1580 and Development Agreement 2025-0001 Exhibit B – Conditions of Approval Exhibit C – Tentative Parcel Map 2025-151 32 ________________ Ordinance No. 1580 DA 2025-0001 Page 1 DRAFT ORDINANCE NO. 1580 AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF TUSTIN, CALIFORNIA, APPROVING DEVELOPMENT AGREEMENT 2025-0001 BETWEEN THE CITY OF TUSTIN AND CD-CW (TUSTIN) LLC (CONFLUENT DEVELOPMENT) FOR THE DEVELOPMENT OF A 6.14-ACRE SITE WITHIN TUSTIN LEGACY WITH 172 RESIDENTIAL UNITS FOR ACTIVE SENIORS AND AN APPROXIMATELY 143,000 SQUARE FOOT ASSISTED LIVING AND MEMORY CARE FACILITY The City Council of the City of Tustin does hereby ordain as follows: SECTION 1. The City Council finds and determines as follows: A. That a proper application has been submitted by Confluent Development, through its project entity CD-CW (Tustin) LLC, for the development of 172 residential units for active seniors, including 26 units affordable to Lower Income households, and an approximately 143,000 square foot assisted living and memory care facility containing 103 units, on Lot 14 of Tract 18197, an approximately 6.14-acre site currently owned by the City of Tustin within Planning Area (PA) 8, 13, and 14 (Neighborhood D) of the Tustin Legacy Specific Plan (TLSP). B. That Development Agreement (DA) 2025-0001 provides public benefits in the form of senior housing including 26 units affordable to Lower Income households and assisted living and memory care facilities in the City; increased tax revenues; installation of on-site and off-site improvements; and the creation and retention of jobs. In addition, the DA requires the developer to: 1. Design and construct sidewalk, parkway landscape, and irrigation systems adjacent to the project along Warner Avenue, Armstrong Avenue, John Johnson Way, and Veterans Way; 2. Enter into a Landscape Installation and Maintenance Agreement with the City for the construction, maintenance, repair, and replacement of landscaping within the landscape area; 3. Annex the property and project improvements into Community Facilities District (CFD) 18-01, Zone 5, for the provision of maintenance and essential services at Tustin Legacy; (;+,%,7$ 33 _________________ Ordinance No. 1580 DA 2025-0001 Page 2 4. Pay the Project Fair Share Contribution for backbone infrastructure in Tustin Legacy; and 5. Construct the project within the time period set forth in the Schedule of Performance attached to the Disposition and Development Agreement (DDA). C. That TLSP Section 4.2.7 requires all private nonresidential development at Tustin Legacy to obtain a DA in accordance with Section 65864 et seq. of the Government Code and Sections 9600 to 9619 of the Tustin City Code (TCC). In compliance with TCC Section 9611, the Tustin Planning Commission must make a recommendation on the proposed DA to the City Council. D. That a public hearing was duly called, noticed, and held on said application on August 11, 2026, by the Planning Commission. The Planning Commission adopted Resolution No. 4554 recommending that the City Council approve the DA. E. That a public hearing was duly called, noticed, and held on said application on _______ ___, 2026, by the City Council. F.On January 16, 2001, the City of Tustin certified the Program Final Environmental Impact Statement/Environmental Impact Report (FEIS/EIR) for the reuse and disposal of MCAS Tustin. On December 6, 2004, the City Council adopted Resolution No. 04-76 approving a supplement to the FEIS/EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted Resolution No. 06-43 approving an addendum to the FEIS/EIR. On May 13, 2013, the City Council adopted Resolution No. 13-32 approving a second addendum to the FEIS/EIR. On July 5, 2017, the City Council adopted Resolution No. 17-23 approving a second supplement to the FEIS/EIR. On December 17, 2024, the City Council adopted Resolution No. 24-76 approving a third supplement to the FEIS/EIR (the TLSP 2025 SEIR, State Clearinghouse No. 1994071005), which evaluated the environmental effects in conjunction with an amendment to the TLSP to implement the programs and policies of the City’s Sixth Cycle Housing Element Rezone Project, which increased residential capacity within TLSP Neighborhoods D (North and South) and G (Housing Element Sites 1A, 1B and 2). The FEIS/EIR, along with its addenda and supplements, is a program EIR under the California Environmental Quality Act (CEQA). The FEIS/EIR, addenda, and supplements considered the potential environmental impacts associated with development on the former 34 ________________ Ordinance No. 1580 DA 2025-0001 Page 3 Marine Corps Air Station, Tustin. Because the proposed project includes an institutional assisted living and memory care component in addition to residential uses, the project has been evaluated through an addendum tiering from the TLSP 2025 SEIR pursuant to CEQA Guidelines Sections 15164, 15162, and 15168. The addendum concludes that the project is within the scope of the development previously analyzed in the TLSP 2025 SEIR, that none of the conditions described in CEQA Guidelines Section 15162 calling for preparation of a subsequent or supplemental EIR have occurred, and that no further environmental documentation is required. By Resolution No. 26-43, adopted concurrently herewith, the City Council has adopted the addendum to the TLSP 2025 SEIR. G. That the DA can be supported by the following findings: 1. The project is consistent with the objectives, policies, general land uses and programs specified in the General Plan and the TLSP in that residential uses are permitted by right and assisted living facilities (including memory care, a subset of assisted living) are conditionally permitted within Planning Area (PA) 8, 13, and 14 of Neighborhood D. 2. The project is compatible with the uses authorized in the district in which the real property is located (PA 8, 13, and 14) in that similar and compatible uses are envisioned within close proximity of the project site. 3. The project is in conformity with the public necessity, public convenience, general welfare, and good land use practices in that the agreement incorporates public benefits in the form of new senior housing opportunities, including 26 units affordable to Lower Income households, and assisted living and memory care services responsive to the needs of the City’s older adult population; sidewalk, parkway landscape, and irrigation improvements along the project’s Warner Avenue, Armstrong Avenue, John Johnson Way, and Veterans Way frontages; ongoing landscape maintenance secured by a Landscape Installation and Maintenance Agreement; annexation into CFD 18-01, Zone 5, for maintenance and essential services; increased tax revenues; and the creation and retention of jobs. 4. The project will not be detrimental to the health, safety, and general welfare in that the project will provide market rate and affordable residential units for active seniors, together with an assisted living and 35 _________________ Ordinance No. 1580 DA 2025-0001 Page 4 memory care facility, in an area designated for such uses. That, as conditioned, the construction and use of the project will not be detrimental to health, safety, and general welfare. 5. The project will not adversely affect the orderly development of property in that the existing and surrounding properties are improved or planned for residential, institutional, and park uses, and the project is orderly, well designed, and equipped with necessary infrastructure and amenities to support existing and future residents of Tustin Legacy. 6. The provisions of the proposed DA and conditions of approval will ensure that the project will have a positive fiscal impact on the City. SECTION 2. The City Manager is hereby authorized to take such actions, and execute such documents and instruments as deemed necessary or desirable to implement the terms of the DA and other documents as necessary. SECTION 3. The City Council hereby approves DA 2025-0001 attached hereto as Exhibit A and subject to final approval of the City Attorney. SECTION 4. Severability. If any section, subsection, sentence, clause, phrase, or portion of this ordinance is for any reason held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this ordinance. The City Council of the City of Tustin hereby declares that it would have adopted this ordinance and each section, subsection, sentence, clause, phrase, or portion thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses, phrases, or portions be declared invalid or unconstitutional. PASSED AND ADOPTED, at a regular meeting of the City Council for the City of Tustin on this ___ day of _____, 2026. ___________________________________ AUSTIN LUMBARD Mayor _________________________ ERICA N. YASUDA City Clerk 36 ________________ Ordinance No. 1580 DA 2025-0001 Page 5 APPROVED AS TO FORM: _________________________ DAVID E. KENDIG City Attorney STATE OF CALIFORNIA ) COUNTY OF ORANGE ) ss. CITY OF TUSTIN ) ORDINANCE NO. 1580 I, Erica N. Yasuda, City Clerk and ex-officio Clerk of the City Council of the City of Tustin, California, does hereby certify that the whole number of the members of the City Council of the City of Tustin is 5; that the above and foregoing Ordinance No. 1580 was duly and regularly introduced at a regular meeting of the Tustin City Council, held on ________ ___, 2026, and was given its second reading, passed, and adopted at a regular meeting of the City Council held on _______ ___, 2026, by the following vote: COUNCILMEMBER AYES: ___________________________________ COUNCILMEMBER NOES: ___________________________________ COUNCILMEMBER ABSTAINED: ___________________________________ COUNCILMEMBER ABSENT: ___________________________________ COUNCILMEMBER RECUSED: ___________________________________ ERICA N. YASUDA City Clerk 37 1 City of Tustin/Confluent Development Development Agreement CITY OF TUSTIN OFFICIAL BUSINESS REQUEST DOCUMENT BE RECORDED AND BE EXEMPT FROM PAYMENT OF A RECORDING FEE PER GOVERNMENT CODE 6103 AND 27383 RECORDING REQUESTED BY AND WHEN RECORDED MAIL TO: City of Tustin 300 Centennial Way Tustin, California 92780 Attn: City Clerk Space Above This Line Reserved for Recorder’s Use Only TUSTIN LEGACY DEVELOPMENT AGREEMENT THIS TUSTIN LEGACY DEVELOPMENT AGREEMENT (“Agreement”) is entered into effective as of the Effective Date (as defined below) by and between the CITY OF TUSTIN, a California municipal corporation (“City”), and CD-CW (TUSTIN) LLC, a Colorado limited liability company (as further defined in Section 1 below, “Developer”). The City and Developer are collectively referred to herein as the “Parties” and individually as a “Party”. RECITALS The following recitals are an integral part of this Agreement and are binding on the Parties. Capitalized terms used in these recitals shall have the meanings ascribed to such terms as set forth in Section 1.1. A. To strengthen the public planning process, encourage private participation in comprehensive planning, and reduce the economic risk of development, the legislature of the State of California (“State”) adopted California Government Code Sections 65864, et seq. (“Development Agreement Statute”). The Development Agreement Statute authorizes the City to enter into an agreement with any person having a legal or equitable interest in real property and to provide for development of such property and to establish certain development rights therein. Pursuant to California Government Code Section 65451, the City has adopted the Tustin Legacy Specific Plan regulating land uses within Tustin Legacy (as the same may be amended from time to time, “Specific Plan”). Specific Plan Section 4.2.7 states: “prior to issuance of any permits or approval of any entitlements within the Specific Plan area, all private non-residential development shall first obtain a Development Agreement in accordance with Section 65864 et seq. of the Government Code and Sections 9600 to 9619 of the Tustin City Code.” Pursuant to the authorization set forth in the Development Agreement Statute, the City has enacted procedures for entering into development agreements which are contained in Tustin City Code Sections 9600 to 9619. B. The City and Developer intend, concurrently with the execution of this Agreement, to enter into the Tustin Legacy Disposition and Development Agreement for Portion of Disposition 38 2 City of Tustin/Confluent Development Development Agreement Area 8 as the same may be amended from time to time (“DDA”) pursuant to which the City shall agree to sell and Developer shall agree to buy and develop the Real Property. C. Developer shall develop the Project as two components comprised of an active adult residential facility and related improvements (as further defined in the DDA, “Active Adult Project”) on the Active Adult Real Property and a separate assisted living and memory care commercial facility and related improvements (as further defined in the DDA, “AL/MC Project”) to be constructed on the AL/MC Real Property, as more specifically set forth and defined in the DDA. D. Upon the Close of Escrow, Developer intends to acquire the Property and develop the Project. E. Consistent with the requirements of California Government Code Sections 54220- 54234 (“Surplus Land Act”) and the California Department of Housing and Community Development’s (“HCD”) Updated Surplus Land Act Guidelines dated August 1, 2024 (“SLA Guidelines”, and collectively with the Surplus Land Act, as each may be amended from time to time, the “SLA Regulations”), fifteen percent (15%) of the total number of Residential Units to be constructed on the Active Adult Real Property (and any Residential Units that may in the future be developed on the AL/MC Real Property) must be Lower Income Units. Developer recognizes that the timing of construction of the Project may be subject to regulation under the SLA Regulations as the same may be amended. To ensure compliance with the SLA Regulations, the City shall record an SLA Covenant and an Affordable Housing Declaration against the Real Property immediately prior to the Close of Escrow. Notwithstanding the foregoing, the Parties acknowledge and agree that development of an assisted living and/or memory care facility is a commercial use under the Tustin Legacy Specific Plan and such use is accordingly not a residential use or considered development of Residential Units to which the affordable housing requirements of the SLA Covenant would apply. F. This Agreement shall be executed concurrently with the DDA pursuant to which Developer shall have an equitable and/or legal interest in the Real Property in that it has the contractual right to purchase the Property from the City for development of the Project. G. Pursuant to California Government Code Section 65864, the Legislature has found and determined that: “(a) The lack of certainty in the approval of development projects can result in a waste of resources, escalate the cost of housing and other development to the consumer, and discourage investment in and commitment to comprehensive planning which would make maximum efficient utilization of resources at the least economic cost to the public. (b) Assurance to the applicant for a development project that upon approval of the project, the applicant may proceed with the project in accordance with existing policies, rules and regulations, and subject to conditions of approval, will strengthen the public planning process, encourage private participation in comprehensive planning, and reduce the economic costs of development. 39 3 City of Tustin/Confluent Development Development Agreement (c) The lack of public facilities, including but not limited to streets, sewerage, transportation, drinking water, school, and utility facilities, is a serious impediment to the development of new housing. Whenever possible, applicants and local governments may include provisions in agreements whereby applicants are reimbursed over time for financing public facilities.” In accordance with the legislative findings set forth in California Government Code Section 65864, the City wishes to secure the Public Benefits and attain certain public objectives that will be furthered by this Agreement. This Agreement will provide for: the orderly implementation of the City of Tustin General Plan (“General Plan”), the development and completion of the Project in accordance with the DDA and as applicable the SLA Covenant and the Affordable Housing Declaration, consistent with the General Plan and the Specific Plan. This Agreement will further the comprehensive planning objective contained in the General Plan, to promote an economically balanced community with complementary and buffered land uses to include commercial, professional, multi-family and single-family development. H. The DDA, the Specific Plan and the development under the DDA and the Specific Plan require a substantial early investment of money and planning and design effort by Developer. Without the protection provided by this Agreement, uncertainty that the Project may be completed in its entirety could result in a waste of public resources, escalate the cost of public improvements, and discourage Developer’s provision of the Public Benefits or payment for those certain public improvements specified in the DDA and the Specific Plan. Developer’s participation in the implementation of the DDA and the Specific Plan will result in a number of public benefits. These benefits require the cooperation and participation of the City and Developer and could not be secured without mutual cooperation in and commitment to the comprehensive planning effort that has resulted in the DDA and the Specific Plan. I. This Agreement is intended to be, and shall be construed as, a development agreement within the meaning of the Development Agreement Statute. This Agreement is intended to augment and further the purposes and intent of the Parties in the implementation of the DDA and the Specific Plan. This Agreement, as a device for the implementation of the Existing Entitlement Approvals and the Specific Plan, will benefit the City by: eliminating uncertainty in planning for and securing the orderly development of the Project, ensuring a desirable and functional community environment; providing effective and efficient development of public facilities, infrastructure and services appropriate for the development of the Project; assuring attainment of the maximum effective utilization of resources within the City; and providing other significant public benefits to the City and its residents by otherwise achieving the goals and purposes of the Development Agreement Statute. In exchange for these benefits to the City, Developer desires to receive the assurance that it may proceed with development of the Project in accordance with the terms and conditions of this Agreement and the Applicable Rules, all as more particularly set forth herein. J. The City has determined that this Agreement and the Project are consistent with the Marine Corps Air Station-Tustin Reuse Plan, the General Plan and the Specific Plan. K. On ___________________, 20__, the Planning Commission held a public hearing on this Agreement (DA 2025-0001), made certain findings and determinations with respect 40 4 City of Tustin/Confluent Development Development Agreement thereto, and recommended to the City Council of the City that this Agreement be approved. On ___________________, 20__ the City Council held a public hearing on this Agreement, considered the recommendations of the Planning Commission, and adopted Ordinance No. ______, approving this Agreement and authorizing its execution. Ordinance No. _______ was formally adopted at a second reading by the City Council on ________________, 20__. L. On _________________, 20__, the Planning Commission held a public hearing and recommended to the City Council of the City that it approve Design Review application 2025- 0008: Subdivision 2025-0003 (County Tentative Parcel Map Number 2025-151); Conditional Use Permit approval (CUP 2025-0012); and the density bonus application, density bonus exception and related concessions, incentives and waivers authorized under Tustin City Code Sections 9123 and 9124 related to the provision of affordable housing units in compliance with California Government Code Section 54220-54234 and 65915. On _________________, 20__, the City Council held a public hearing, considered the recommendations of the Planning Commission, and approved the Design Review, Tentative Parcel Map, Conditional Use Permit and density bonus applications. AGREEMENT NOW, THEREFORE, in consideration of the above recitals, which are incorporated herein by this reference, and for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the Parties agree as follows: 1. DEFINITIONS AND EXHIBITS Definitions. Any capitalized word or term used and specifically defined in this Section 1.1 or elsewhere in this Agreement shall have the meaning established in this Agreement. Capitalized words or terms not defined in this Agreement shall have the definition or meaning ascribed to such word or term as provided in the DDA. All capitalized terms not specifically defined in the DDA or this Agreement shall be interpreted in accordance with the Planning and Land Use Law (California Government Code, Title 7). If neither this Agreement, the DDA, nor applicable law defines a particular term, then the City Manager’s interpretation in her/his reasonable discretion shall apply. The following terms when used in this Agreement shall be defined as follows: 1.1.1 “Action” is defined in Section 9.10. 1.1.2 “Active Adult Project” is defined in Recital C. 1.1.3 “Active Adult Real Property” means the portion of the Real Property depicted as such on Exhibit E to this Agreement and if the Final Parcel Map is Recorded, shall be comprised of Parcel 1 on the Final Parcel Map. 1.1.4 “Administrative Amendment” is defined in Section 2.5.3. 1.1.5 “Affordable Housing Declaration” means that certain Declaration of Affordable Housing Restrictive Covenants and Regulatory Agreement to be executed by the City 41 1.1. 5 City of Tustin/Confluent Development Development Agreement and Developer and Recorded against the Real Property prior to the Close of Escrow. 1.1.6 “Agreement” is defined in the introductory paragraph. 1.1.7 “AL/MC Project” is defined in Recital C. 1.1.8 “AL/MC Real Property” means the portion of the Real Property depicted as such on Exhibit E to this Agreement, and if the Final Parcel Map is Recorded, shall be comprised of Parcel 2 of the Final Parcel Map. 1.1.9 “Annual Review Certificate” is defined in Section 4.5. 1.1.10 “Applicable Rules” means (a) the Existing Land Use Regulations of the City; (b) the Future Rules that at the time of adoption do not Conflict with the then-effective Applicable Rules; (c) the Future Rules made applicable to the Project and/or the Property pursuant to Section 3.6.2 or 3.10; (d) the Existing Entitlement Approvals, and (e) the Subsequent Entitlement Approvals to which the Project and/or the Property or development and use thereof are made subject to pursuant to the terms of this Agreement. 1.1.11 “Applications” is defined in Section 3.11.2. 1.1.12 “Business Day(s)” means any day on which City Hall is open for business and shall specifically exclude Saturday, Sunday or a legal holiday. 1.1.13 “Certificate of Compliance” means a certificate issued and Recorded by the City upon Completion by Developer of the Active Adult Project Improvements and/or the AL/MC Project Improvements, as applicable, and satisfaction of all additional Conditions Precedent thereto as described in the DDA, provided that if the Final Parcel Map is not Recorded prior to issuance of the first of these two Certificates of Compliance, then in lieu of separate Certificates of Compliance for each component of the Project, there shall be only one Certificate of Compliance issued and it shall be issued after Completion of the entirety of the Project and satisfaction of all additional Conditions Precedent set forth in the DDA for both the Active Adult Project and AL/MC Project. 1.1.14 “City” is defined in the introductory paragraph. 1.1.15 “City Manager” means Aldo E. Schindler or his successor in such capacity, or other designee as identified in writing by the City Manager. 1.1.16 “City Processing Fees” means (a) all fees and charges imposed by the City under the then-current regulations for processing applications and requests for permits, approvals, and other actions and monitoring compliance with any permits issued or approvals granted, including Plan Check and Inspection Fees and all applicable processing and permit fees to cover the reasonable cost to the City of: (i) processing and reviewing applications (including Applications) and plans for any Entitlement Approvals, site review and approval, administrative review, and similar fees imposed to recover the City’s costs associated with processing, reviewing, and inspecting Project applications, plans and specifications; (ii) inspecting the work constructed or installed by or on behalf of Developer, and (iii) monitoring compliance with any requirements 42 6 City of Tustin/Confluent Development Development Agreement applicable to development of the Project, and (b) all costs incurred by the City in the performance of necessary studies and reports in connection with the foregoing and its obligations under this Agreement. 1.1.17 “Claims” is defined in Section 6. 1.1.18 “Conflict” means Future Rules that as compared with the Existing Land Use Regulations, the Existing Entitlement Approvals, this Agreement, the DDA, the Memorandum of DDA, the Special Restrictions, the Landscape Installation and Maintenance Agreement, the Quitclaim Deeds, the SLA Covenant and the Affordable Housing Declaration: (i) would: (a) preclude compliance with or performance of any provision of this Agreement; (b) modify the land use designation or permitted uses of the Real Property; (c) impose additional obligations in connection with the reservation or dedication of land or exactions for public purposes; (d) impose an increased or additional affordable housing obligation for the Project beyond those set forth in the SLA Covenant and the Affordable Housing Declaration; or(e) regulate rents charged for any of the Residential Units, including without limitation, the enactment of a rental control or stabilization ordinance (and excluding regulations of rent implemented through the SLA Covenant and Affordable Housing Declaration); (ii) would result in a material adverse effect to the Project with respect to any of the following: (a) impose limits or controls in the rate, timing, phasing or sequencing of development of the Project or provision of utilities, (b) limit or restrict the availability of public utilities, services, infrastructure or facilities (for example, but not by way of limitation, water rights, water connection or sewage capacity rights, sewer connections, etc.) to the Project with respect to matters under the control of the City; (c) reduce or limit the density, intensity, maximum building height or size or parking or loading spaces of any of the buildings comprising the Project to less than that described in the Existing Entitlement Approvals, (d) limit the location of building sites, grading or other Project Improvements on the Real Property, or (e) require Developer to obtain additional discretionary approvals or permits from the City to develop the Project as entitled by the Existing Entitlement Approvals, excepting therefrom any Subsequent Entitlement Approvals as may be required or requested by Developer. 1.1.19 “Costs” is defined in Section 9.10. 1.1.20 “Damages” is defined in Section 5.3. 1.1.21 “DDA” is defined in Recital B. 1.1.22 “Decision” is defined in Section 9.10. 1.1.23 “Defaulting Party” is defined in Section 5.1. 1.1.24 “Developer” is defined in the introductory paragraph and includes any Successors In Interest of Developer. 1.1.25 “Development Agreement Statute” is defined in Recital A. 1.1.26 “Development Permits” means all ministerial permits, certificates and approvals which may be required by the City or other governmental authority for the development 43 7 City of Tustin/Confluent Development Development Agreement and construction of the Project Improvements in accordance with this Agreement, the DDA, the Applicable Rules and any required environmental mitigation, including engineering permits, grading permits, foundation permits, construction permits and building permits. 1.1.27 “District” is defined in Section 3.1.1. 1.1.28 “Effective Date” means the date that is thirty (30) days after the date of approval (second reading) by the City Council of the City’s ordinance approving this Agreement. 1.1.29 “EIR” means the Final Environmental Impact Statement/Final Environmental Impact Report for the Disposal and Reuse of MCAS Tustin (Final EIS/EIR) and Mitigation Monitoring and Reporting Program for the Final EIS/EIR adopted by the City on January 16, 2001 as subsequently modified by Supplement to the Final EIR/EIS and Addenda to the Final EIS/EIR approved by the City. 1.1.30 “Entitlement Approvals” means (a) all discretionary land use approvals and entitlements, subdivision maps, density bonuses, conditional use permits and design review approvals as may be applicable for proposed specific uses in connection with development of the Project on the Real Property and (b) all conditions of approval legally required by the City as a condition to subdivision and development of the Real Property, and construction of the Project Improvements in accordance with this Agreement and the DDA. Entitlement Approvals shall be comprised of the Existing Entitlement Approvals and any Subsequent Entitlement Approvals. 1.1.31 “Existing Entitlement Approvals” means all Entitlement Approvals approved or issued prior to the Effective Date and including the following which are a matter of public record on the Effective Date: (a) Development Agreement (2025-0001), (b) Design Review 2025-0008, (c) Subdivision 2025-0003 (Tentative Parcel Map Number 2025-151), (d) Conditional Use Permit (CUP 2025-0012), and (e) the density bonus application, density bonus exception and related concessions and incentives authorized under Tustin City Code Section 9123 and 9124 related to the provision of affordable housing units. 1.1.32 “Existing Land Use Regulations” means the Land Use Regulations in effect on the Effective Date, including the General Plan, the City Zoning Code, the Specific Plan, development and/or design standards and guidelines and all other ordinances, resolutions, rules, and regulations of the City governing development and use of the Real Property in the form and substance in effect as of the Effective Date to the extent applicable to the Project; provided that the definition of Existing Land Use Regulations shall not include regulations modified through density bonus concessions, waivers and/or incentives granted as part of the Existing Entitlement Approvals. 1.1.33 “Extremely Low Income Households” means persons and families whose incomes do not exceed the qualifying limits for extremely low income families as established and amended from time to time by the Secretary of Housing and Urban Development and defined in Section 5.603(b) of Title 24 of the Code of Federal Regulations. These limits shall be published by the Department of Housing and Community Development in the California Code of Regulations as soon as possible after adoption by the Secretary of Housing and Urban Development. In the event the federal standards are discontinued, the Department of Housing and Community Development shall, by regulation, establish income limits for extremely low income 44 8 City of Tustin/Confluent Development Development Agreement households for all geographic areas of the state at 30 percent of AMI, adjusted for family size and revised annually. 1.1.34 “Final Certificate of Compliance” means the Certificate of Compliance issued and Recorded by the City for the last of the Active Adult Project or the AL/MC Project upon satisfaction of all Conditions Precedent therefor set forth in the DDA, provided that if the Final Parcel Map is not Recorded prior to issuance of the first of those two Certificates of Compliance, then the single Certificate of Compliance issued after Completion of the entirety of the Project and satisfaction of all additional Conditions Precedent set forth in the DDA or both the Active Adult Project and AL/MC Project shall be the Final Certificate of Compliance. 1.1.35 “Final Date” is defined in Section 3.12.1(b). 1.1.36 “Final Parcel Map” means the final parcel map for the Real Property, Parcel Map Number 2025-151, which shall be substantially in the form and content required by the Tentative Tract Map unless otherwise approved by the City in its Governmental Capacity. If Recorded, the Final Parcel Map shall be recorded in one phase. 1.1.37 “Force Majeure Delay” as to the Active Adult Project or the AL/MC Project is a delay that is determined to be a Force Majeure Delay as to that specific project under the applicable DDA Section. 1.1.38 “Future Rules” is defined in Section 3.6.2. 1.1.39 “General Plan” is defined in Recital G. 1.1.40 “HCD” is defined in Recital E. 1.1.41 “Land Use Regulations” means all laws, statutes, ordinances, resolutions, codes, orders, rules, regulations and official policies of the City governing the development and use of land, including the permitted uses of the Real Property and Project Improvements, the density or intensity of use, subdivision requirements, timing and phasing of development, the maximum height and size of proposed buildings, and the provisions for reservation or dedication of land for public purposes. 1.1.42 “Landscape Area” means the portion of the Real Property and of the City Property (as defined in the Landscape Installation and Maintenance Agreement), generally between the back of curb on each public street adjoining the Real Property and the buildings on the Real Property, as more particularly depicted on Exhibit D to this Agreement. 1.1.43 “Lower Income Household” means persons and families whose income does not exceed the qualifying limits for lower income households established and amended from time to time pursuant to Health and Safety Code section 50079.5, including the federal income- limit methodology under Section 8 of the United States Housing Act of 1937 referenced therein, as adjusted for family size and published by the California Department of Housing and Community Development. For purposes of this Agreement, the applicable income limit for Lower Income Households shall generally not exceed eighty percent (80%) of area median income, adjusted for 45 9 City of Tustin/Confluent Development Development Agreement family size, as such limits are revised annually. “Lower Income Households” includes Very Low Income Households and Extremely Low Income Households. 1.1.44 “Lower Income Units” shall mean Residential Units that are restricted to be sold or rented to Lower Income Households. 1.1.45 “Major Amendment” is defined in Section 2.5.2. 1.1.46 “Non-Defaulting Party” is defined in Section 5.1. 1.1.47 “Operating Memoranda” is defined in Section 2.5.3. 1.1.48 “Other Agreements” shall mean the SLA Covenant, the Special Restrictions, the Landscape Installation and Maintenance Agreement, the DDA, the Memorandum of DDA, the Affordable Housing Declaration, the Access Easement Agreement, the Bioswale Easement and the Quitclaim Deed. 1.1.49 “Party” and “Parties” are defined in the introductory paragraph. 1.1.50 “Plan Check and Inspection Fees” means the portion of the City Processing Fees incurred by the City directly or by an independent contractor of the City with respect to its provision of Plan Check and Inspection Services for the Project, which shall be billed to Developer by the City and paid by Developer to the City in accordance with Section 3.12.1(b). 1.1.51 “Plan Check and Inspection Services” means the services performed by City staff and its third-party inspectors, engineers, contractors and consultants, if any, to carry out and complete plan check, perform inspections, and monitor Developer compliance with the Applicable Rules, as needed for review and issuance of encroachment permits, excavation permits, grading permits, mechanical, electrical and plumbing permits and building permits requested by Developer in connection with the Project. 1.1.52 “Prevailing Party” is defined in Section 9.10. 1.1.53 “Processing Fee Deposit” is defined in Section 3.12.1(b). 1.1.54 “Project” means the development of the Real Property with the Project Improvements contemplated by the Existing Entitlement Approvals as such Entitlement Approvals may be further defined, enhanced or modified pursuant to the provisions of this Agreement. 1.1.55 “Project Fair Share Contribution” means the fair share of the Tustin Legacy Backbone Infrastructure Program to be contributed by Developer with respect to the Project as further described in the DDA and Section 3.12.3. 1.1.56 “Project Improvements” means all infrastructure, roads, sidewalks, buildings, structures and other improvements to be constructed or installed on the Active Adult Real Property and the AL/MC Real Property as further described for each in the DDA, and for avoidance of doubt shall include the Horizontal Improvements, the Vertical Improvements and the Public Benefits Improvements. 46 10 City of Tustin/Confluent Development Development Agreement 1.1.57 “Public Benefit” and “Public Benefits” means those public benefits to be provided by Developer and the Project as described in Section 3.1 that comprise enforceable additional consideration to the City for this Agreement and shall include the Public Benefits Improvements. 1.1.58 “Public Benefits Improvements” means those improvements listed in Exhibit C to this Agreement to be constructed by Developer as part of the Project. 1.1.59 “Public Health Risk” is defined in Section 3.10.3. 1.1.60 “Real Property” means the real property legally described on Exhibit A and depicted on Exhibit B that is proposed to be conveyed by the City to Developer pursuant to the DDA, excluding therefrom the rights and interests identified in the DDA as to be reserved by the City in the Quitclaim Deed. 1.1.61 “Record”, “Recording”, and “Recorded” means to record the specified instrument, or the current or past recording of the specified instrument, in the official records of Orange County, California. 1.1.62 “Recordable” means in a form suitable for Recording. 1.1.63 “Reservation of Authority” means the rights and authority excepted from the assurances and rights provided to Developer under this Agreement and reserved to the City under Section 3.10. 1.1.64 “Residential Units” means units constructed on the Real Property that are characterized as residential units by the City of Tustin Municipal Code and/or the Tustin Legacy Specific Plan; provided that Residential Units shall not include the assisted living and/or memory care facility rooms proposed to be constructed on the AL/MC Property. 1.1.65 “RMA” is defined in Section 3.1.1. 1.1.66 “SLA Covenant” means that certain Surplus Land Act Covenant to be executed by the City and acknowledged and accepted by Developer under the DDA and the Nominee(s), if any, that will acquire the Property at the Close of Escrow, which shall be Recorded against the Real Property prior to the Close of Escrow. 1.1.67 “SLA Guidelines” is defined in Recital E. 1.1.68 “SLA Regulations” is defined in Recital E. 1.1.69 “Specific Plan” is defined in Recital A. 1.1.70 “State” is defined in Recital A. 1.1.71 “Subsequent Entitlement Approvals” means each discretionary land use approval, if any, approved by the City consistent with the terms of this Agreement subsequent to the Effective Date in connection with development of the Property, as further described in Section 47 11 City of Tustin/Confluent Development Development Agreement 3.9. 1.1.72 “Successors In Interest” means each and every Person having a legal or equitable interest in or to the whole of the Real Property or any portion of the Real Property. 1.1.73 “Surplus Land Act” is defined in Recital E. 1.1.74 “Tax B” means a District tax the proceeds of which shall be used by the City to fund a portion of the City essential services, including police protection services, fire protection services, ambulance and paramedic services, recreation program services, maintenance of City-owned parks, parkways and open space, flood and storm protection and street and sidewalk maintenance at Tustin Legacy. 1.1.75 “Tentative Parcel Map” means the tentative parcel map for the Real Property (Tentative Parcel Map No. 2025-151) approved by the City Council with respect to the Real Property prior to the Effective Date of this Agreement, as the same may be modified or amended with the approval of the City in its Governmental Capacity. 1.1.76 “Term” is defined in Section 2.3. 1.1.77 “Tustin City Code” means the municipal code of the City of Tustin. 1.1.78 “Very Low Income Household” means persons and families whose incomes do not exceed the qualifying limits for very low income families as established and amended from time to time pursuant to Section 8 of the United States Housing Act of 1937. These qualifying limits shall be published by the Department of Housing and Community Development in the California Code of Regulations as soon as possible after adoption by the Secretary of Housing and Urban Development. In the event the federal standards are discontinued, the Department of Housing and Community Development shall, by regulation, establish income limits for very low income households for all geographic areas of the state at fifty percent (50%) of area median income, adjusted for family size and revised annually. “Very Low Income Households” includes Extremely Low Income Households. Exhibits. The following documents are attached to, and by this reference made a part of, this Agreement: Exhibit A – Legal Description of the Real Property Exhibit B – Map showing Real Property Exhibit C – Public Benefits Improvements Exhibit D – Landscape Area Exhibit E – Site Plan Exhibit F – Access Easement Agreement Exhibit G – Bioswale Easement Agreement 48 1.2. 12 City of Tustin/Confluent Development Development Agreement 2. GENERAL PROVISIONS Binding Effect of Agreement. The Real Property is hereby made subject to this Agreement. Development of the Real Property is hereby authorized and shall be carried out only in accordance with the terms of this Agreement and the Entitlement Approvals. This Agreement shall become null and void if the DDA is not approved and executed within ninety (90) calendar days of approval of this Agreement by the City Council, as the same may be extended by mutualagreement of the City Manager and Developer. Interests in Property. The City and Developer agree that Developer’s right to acquire the Property pursuant to the DDA creates a sufficient legal and/or equitable interest in order to enter into this Agreement. If Developer fails to acquire any portion of the Property, then this Agreement shall automatically no longer be effective as to the entirety of the Property concurrently with the date upon which Developer’s rights to acquire any unacquired portion of the Property expire. Term. This Agreement shall commence on the Effective Date and unless terminated, modified, or extended by circumstances set forth in this Agreement or by mutual written consent of the Parties shall terminate upon the earlier of (i) the issuance and Recording by the City of the Final Certificate of Compliance or (ii) the date that is thirty-six (36) months following the Close of Escrow (“Term”). Notwithstanding the foregoing, the Term shall be automatically extended only during the term of any Force Majeure Delay declared pursuant to the DDA, provided that the maximum extension to the Term as to any portion of the Active Adult Project or the AL/MC Project as a result of Force Majeure Delay shall not as to each such portion of the Project cumulatively exceed twelve (12) months and provided further that in no event shall the Term be extended by an event of Force Majeure Delay beyond that set forth in this Section. Covenants Running with the Land; Assignment. The rights, interests and obligations conveyed and provided herein to Developer’s benefit are appurtenant to the Real Property, and shall constitute covenants running with the land comprising the Real Property and shall bind and inure to the benefit of all assignees, transferees and successors to the Parties. Developer shall have the right to assign this Agreement in connection with a conveyance, assignment or any other transfer of all or a portion of the Real Property without the City’s consent, provided the assignee agrees to assume all of the obligations of Developer hereunder with respect to the Real Property or transferred portion thereof. Notwithstanding the foregoing, no Owner shall Transfer any portion of the Real Property or portion thereof, or Improvements thereon or interest therein or Transfer Control as to any portion of the Real Property for which a Certificate of Compliance has not been issued, except in compliance with the requirements of Article 2 and/or Article 17 of the DDA, which provisions, and all definitions and other provisions of the DDA required to interpret and apply such provisions, shall be deemed to be incorporated into this Section 2.4 by this reference and to be in effect as to the portion of the Real Property subject to the DDA whether then in effect or then terminated. Any purported Transfer or Transfer of Control that does not comply with the requirements of Article 2 and, if applicable, Article 17 of the DDA shall, at the election of the City, be null and void. 49 2.1. 2.2. 2.3. 2.4. 13 City of Tustin/Confluent Development Development Agreement Amendment or Cancellation of Agreement. 2.5.1 Generally. City or Developer may propose an amendment to or cancellation, in whole or in part, of this Agreement. Any amendment or cancellation shall be by mutual consent of the Parties except as provided otherwise in this Agreement, in California Government Code Section 65865.1, or in the Tustin City Code Section 9615. 2.5.2 Major Amendment. Any amendment to this Agreement which affects or relates to: (a) the Term of this Agreement; (b) amendment of the uses allowed on the Real Property; (c) provisions for the reservation or dedication of land or grant of any easement; (d) conditions, terms, restrictions or requirements for subsequent discretionary actions; (e) the density or intensity of use of the Real Property or the maximum height or square footage of proposed buildings or other structures or improvements; (f) a material change to the design, improvement and construction standards and specifications applicable to the development of the Real Property, (g) the conditions, terms, restrictions and requirements relating to Subsequent Entitlement Approvals of the City, (h) material revisions to Public Benefits or Public Benefits Improvements (other than to the time for performance of such Public Benefits or Public Benefits Improvements), or to monetary exactions of or contributions by Developer, (i) significant revisions to the amount or any funds due pursuant to this Agreement, or (j) revisions to the default, cure or remedies provisions of this Agreement shall be deemed a “Major Amendment”. A Major Amendment shall only be made following a noticed public hearing held by the Planning Commission to consider whether the amendment should be approved or denied, and, following recommendation to the City Council on the matter, the City Council shall hold a noticed public hearing to consider the request and the Planning Commission’s recommendation on the matter. At the conclusion of the public hearing, the City Council may approve, deny, or conditionally approve the amendment. Any amendment which is not a Major Amendment shall be deemed an Administrative Amendment subject to Section 2.5.3. Subject to any defined terms in this Agreement, the City Manager or his or her designee shall have the authority to determine in her/his reasonable discretion, if an amendment is a Major Amendment subject to this Section 2.5.2 or an Administrative Amendment subject to Section 2.5.3. 2.5.3 Administrative Amendments and Operating Memoranda. The Parties acknowledge that refinement and further implementation of the Project may demonstrate that certain minor changes may be appropriate with respect to the details and performance of the Parties under this Agreement when a Major Amendment is not required (“Administrative Amendment”). The Parties desire to retain a certain degree of flexibility with respect to the details of the Project and with respect to those items covered in the general terms of this Agreement. If and when the Parties find that minor changes, or minor adjustments are necessary or appropriate and do not constitute a Major Amendment under Section 2.5.2, they shall effectuate such minor changes or minor adjustments through a written Administrative Amendment approved in writing by Developer and the City Manager, which upon request from Developer shall be in recordable form. Unless otherwise required by law, no such Administrative Amendment shall require prior notice or hearing, nor shall it constitute an amendment to this Agreement. The authority to enter into such Administrative Amendments is hereby delegated to the City Manager and the City Manager is hereby authorized to execute any Administrative Amendments without further Planning Commission or City Council action. Furthermore, if, from time to time during the Term of this Agreement, City and Developer agree that clarifications or further understanding regarding the 50 2.5. 14 City of Tustin/Confluent Development Development Agreement implementation of this Agreement are needed that do not constitute a Major Amendment or Minor Amendment are necessary or appropriate, City and Developer shall effectuate such clarifications through operating memoranda approved in writing by City and Developer (“Operating Memoranda”), which upon request from Developer may be in a recordable form. No such Operating Memoranda shall constitute an amendment to this Agreement requiring public notice or hearing and are considered ministerial clarifications. The City Manager shall have the sole discretion and authority to make determinations on behalf of City as to whether a requested clarification may be effectuated pursuant to this Section 2.5.3. The City Manager shall, upon consultation with the City Attorney as to the form of the Operating Memorandum, be authorized to execute any Operating Memoranda hereunder on behalf of City. 2.5.4 Consent to Amendments. Any Future Rule applicable pursuant to this Agreement, that is not in conflict with this Agreement, and any amendment of the Land Use Regulations including to the General Plan, the Specific Plan or the City’s zoning ordinance, that is not in conflict with this Agreement, shall not require amendment of this Agreement. Instead, any such amendment shall be deemed to be incorporated into this Agreement at the time that such amendment is approved by the appropriate City decision maker, so long as such amendment is consistent with this Agreement. 2.5.5 Termination. This Agreement shall be deemed terminated and of no further effect upon the occurrence of any of the following events: (a) Expiration of the Term of this Agreement as set forth in Section 2.3; (b) Entry of a final court judgment not subject to further appeal setting aside, voiding or annulling the adoption of the City ordinance approving this Agreement; (c) The adoption of a referendum measure overriding or repealing the City ordinance approving this Agreement; (d) Grant of all easements, dedications, grants and/or relinquishments of rights by Developer as required on the Final Parcel Map (if then Recorded) and pursuant to the Other Agreements, issuance of all required occupancy permits and acceptance by the City or applicable public agency of all required public improvements and dedications, and issuance and Recording by the City of the Final Certificate of Compliance; provided that if the Final Parcel Map is Recorded prior to the Recording of the first Certificate of Compliance, then this Agreement shall terminate as to the Active Adult Real Property or the AL/MC Real Property, as the case may be, upon issuance of a Certificate of Compliance for the applicable component of the Real Property and Project and satisfaction of the requirements in this clause (d). (e) Due to termination by the City in accordance with Sections 4.4, 5 or 9.12 of this Agreement; or (f) Upon mutual written agreement of the City and Developer. Termination of this Agreement shall not constitute termination of any other Entitlement Approvals for the Real Property. Upon the termination of this Agreement, no Party shall have any further 51 15 City of Tustin/Confluent Development Development Agreement right or obligation hereunder except with respect to any obligation to have been performed prior to such termination or with respect to any default in the performance of the provisions of this Agreement which has occurred prior to such termination or with respect to any obligations which are specifically set forth as surviving this Agreement. Notices, Demands and Communications between the Parties. All notices, demands, consents, requests and other communications required or permitted to be given under this Agreement shall be in writing and shall be deemed conclusively to have been duly given (a) when hand delivered to the other Party; (b) three (3) Business Days after such notice has been sent by U.S. Postal Service via certified mail, return receipt requested, postage prepaid, and addressed to the other Party as set forth below; (c) the next Business Day after such notice has been deposited with an overnight delivery service reasonably approved by the Parties (Federal Express, Overnite Express, United Parcel Service and U.S. Postal Service are deemed approved by the Parties), postage prepaid, addressed to the Party to whom notice is being sent as set forth below with next Business Day delivery guaranteed, provided that the sending Party receives a confirmation of delivery from the delivery service provider; or (d) when received by the recipient Party when sent by email to the email address set forth below; provided, however, that notices given by email shall not be effective unless either (i) a duplicate copy of such notice is promptly sent by any method permitted under this Section 2.6 other than by email (provided that the recipient Party need not receive such duplicate copy prior to any deadline set forth herein); or (ii) the receiving Party delivers a written confirmation of receipt for such notice by email or any other method permitted under this Section 2.6. Any notice given by email shall be deemed received on the next Business Day if such notice is received after 5:00 p.m. (recipient’s time) or on a non-Business Day. Unless otherwise provided in writing, all notices with respect to this Agreement shall be addressed as follows: City: City Manager City of Tustin 300 Centennial Way Tustin, CA 92780 Attention: Aldo E. Schindler Email:CityManager@tustinca.org With a copy to: Deputy City Manager – Real Property City of Tustin 300 Centennial Way Tustin, CA 92780 Email:Director.ED@tustinca.org And with a copy to: City Attorney Woodruff, Spradlin & Smart 555 Anton Blvd., Suite 1200 Costa Mesa, CA 92626 Attention: David Kendig, Esq. Email:dkendig@woodruff.law 52 2.6. 16 City of Tustin/Confluent Development Development Agreement And with a copy to: Hepner & Myers LLP 1241 Johnson Avenue, Suite 360 San Luis Obispo, CA 93401 Attention: Amy E. Freilich, Esq. Email:afreilich@HepnerMyers.com Developer:CD-CW (Tustin) LLC c/o Confluent Development, LLC 2215 Market Street Denver, CO 80202 Attention: Steve Strom and H McNeish Email:steve.strom@confluentdev.com; HMcNeish@confluentdev.com And with a copy to: CD-CW (Tustin) LLC c/o Confluent Development, LLC 2215 Market Street Denver, CO 80202 Attention: Legal Department Email:legal@confluentdev.com And with a copy to: Polsinelli 1401 Lawrence Street, Suite 2300 Denver, CO 80202 Attention: Nick McGrath Email:nmcgrath@polsinelli.com Any Party may by written notice to the other Party in the manner specified in this Agreement change the person or persons and/or address or addresses, or designate an additional person or persons or an additional address or addresses, for its notices, but notice of a change of address shall also with respect to the City be delivered to the City Clerk. Neither Party shall refuse or reject delivery of any notice given in accordance with this Section 2.6. 3. DEVELOPMENT OF THE REAL PROPERTY Public Benefits. This Agreement provides assurances and Developer with vested rights (but not the obligation) to develop the Project in accordance with the Applicable Rules and this Agreement, and subject to the City’s Reservation of Authority. The Parties believe that such orderly development of the Project will provide the benefits to the City and additional regional public benefits including development of new senior housing opportunities (including affordable Residential Units) for seniors, and assisted living and memory care facilities in the City, increased tax revenues, installation of on-site and off-site improvements, and creation and retention of jobs. In addition, Developer will provide the following additional Public Benefits which constitute specific additional consideration for this Agreement for the benefit of the City: 53 3.1. 17 City of Tustin/Confluent Development Development Agreement 3.1.1 The City has previously established Community Facilities District 18- 01 with a Tax B component to pay for various essential services at Tustin Legacy (“District”). Prior to and as a condition to the Close of Escrow and as further set forth in the DDA, the City, by action of the City Council, intends to form CFD 18-01 Zone 5, which shall include the Real Property and Project Improvements for purposes of providing maintenance and to thereby annex the Real Property and future Project Improvements into the District and to adopt a rate and method of apportionment for the improvement area (“RMA”) for CFD 18-01 Zone 5. When the new improvement area is formed, the District shall impose a tax and lien upon the Real Property in accordance with the terms of the instruments governing the District, the RMAand the requirements of the DDA. At the time of annexation into the District, the Real Property and Project Improvements will be de-annexed from existing City CFD 13-01. During the Term, Developer and the City shall adhere to all terms and conditions in the DDA governing the District, including the formation and operation thereof and annexation of the Real Property into the District, and Developer shall pay when due any assessments and/or special assessments imposed by the District. 3.1.2 Developer shall pay the Project Fair Share Contribution to the City as and when described in Section 3.12.3. 3.1.3 Developer shall complete the Public Benefits Improvements listed on Exhibit C within the time periods set forth in the Schedule of Performance attached to the DDA. 3.1.4 Developer shall construct the Project within the time period set forth in the Schedule of Performance unless such time period is extended as a result of a Force Majeure Delay or as otherwise permitted under Sections 8.3 and 18.7 of the DDA. Developer shall maintain the Real Property and Project Improvements at the sole cost of Developer. 3.1.5 At the Close of Escrow, Developer shall enter into a Landscape Installation and Maintenance Agreement with the City of Tustin for the construction, maintenance, repair, and replacement of the Landscape Improvements within the Landscape Area identified in Exhibit D. Developer shall assure, through the provision of bonds, guarantees, cash collateral, or other instruments approved by the City, the lien-free completion of all landscaping and irrigation improvements as described therein and/or listed as Public Benefits Improvements on Exhibit C within the time period and upon the terms set forth in the Schedule of Performance, the DDA and the Landscape Installation and Maintenance Agreement. Notwithstanding anything to the contrary in this Agreement, if any payment under this Section 3.1 is not made or any obligation requiring performance is not performed by Developer, the City shall have the right to withhold building permits for any building or structure within the Project if Developer fails to timely comply with its obligations with respect to the District or the Public Benefits set forth in this Agreement and the DDA. Mutual Objectives. Development of the Project in accordance with this Development Agreement will provide for the orderly development of the Real Property in accordance with the objectives set forth in the General Plan. Moreover, a development agreement for the Project will eliminate uncertainty in planning for and securing orderly development of the Real Property, assure installation of necessary improvements, assure attainment of maximum efficient resource utilization within the City at the least economic cost to its citizens and otherwise 54 3.2. 18 City of Tustin/Confluent Development Development Agreement achieve the goals and purposes established by California Government Code Section 65864. Additionally, although development of the Project in accordance with this Agreement will constrain the City’s land use or other relevant police powers, this Agreement provides the City with sufficient reserved powers during the Term to remain responsible and accountable to its residents. In exchange for these and other benefits to the City, Developer will receive assurance that the Project may be developed during the Term in accordance with the Applicable Rules, Entitlement Approvals and Reservation of Authority, subject to the terms and conditions of this Agreement. School District Assessments. Nothing in this Agreement shall modify or waive the obligation of Developer to pay when due all taxes and assessments imposed on the Real Property and Project Improvements pursuant to the authority of the County assessor, including any and all Santa Ana Unified School District Assessments, including any Level 1 fees imposed on Developer by the school district. Applicability of the Agreement. This Agreement does not: (a) grant density or intensity in excess of that otherwise established in the Existing Entitlement Approvals; (b) eliminate future discretionary actions relating to the Project that are either required by the Applicable Rules or requested by Developer pursuant to Applications initiated and submitted by Developer after the Effective Date; (c) guarantee that Developer will receive any profits from the Project; (d) amend the DDA, the Specific Plan or the General Plan; (e) except as specifically set forth in Sections 3.6 and 3.10, protect Developer, the Project, the Project Improvements or the Property from the applicability of any Future Rules imposed pursuant to the City’s Reservation of Authority or adopted by the City and that are not at the time of adoption in Conflict with the then- applicable Existing Land Use Regulations; or (f) protect Developer, the Project or the Property from the applicability of any increases in development fees or the City Processing Fees. Agreement and Assurance on the Part of Developer. In consideration for the City entering into this Agreement, and as an inducement for the City to obligate itself to carry out the covenants and conditions set forth in this Agreement, and in order to effectuate the premises, purposes and intentions set forth in this Agreement, Developer hereby agrees as follows: 3.5.1 Project Development. Developer agrees that it will use commercially reasonable efforts, in accordance with its own business judgment and taking into account market conditions and economic considerations, to undertake any development of the Project in accordance with the terms and conditions of the DDA, this Agreement and the Existing Entitlement Approvals. 3.5.2 Additional Obligations of Developer as Consideration for this Agreement. In addition to the obligations identified in Section 3.1, the development assurances provided by this Agreement and the resulting construction of the Project will result in the following: (a) Construction and Completion of the Horizontal Improvements, the Vertical Improvements and the Public Benefits Improvements consistent with this Agreement, the Applicable Rules, the Entitlement Approvals, the Approved Plans and the DDA, including in accordance with the Schedule of Performance. 55 3.3. 3.4. 3.5. 19 City of Tustin/Confluent Development Development Agreement (b) Compliance with the DDA, the Applicable Rules, State and federal law, all mitigation measures, including measures imposed pursuant to CEQA, all Development Permits and all conditions of approval associated with the foregoing. (c) Payment of all required development related fees as set forth in the DDA and this Agreement. Agreement and Assurances on the Part of the City. In consideration for Developer entering into this Agreement, and as an inducement for Developer to obligate itself to carry out the covenants and conditions set forth in this Agreement, and in order to effectuate the purpose of this Agreement, the City hereby agrees as follows: 3.6.1 Applicable Regulations; Vested Right to Develop. Except as otherwise provided under the terms of this Agreement including the Reservation of Authority, during the Term of this Agreement, the rules, regulations, and official policies governing the Project, including the permitted uses of the Real Property, the density and intensity of use of the Real Property, the maximum height and size of proposed buildings, the design, improvement and construction standards and specifications applicable to the Project, including any changes authorized pursuant to Section 3.6.2, and the provisions for the reservation and dedication of land as needed for public purposes, the subdivision of land and requirements for infrastructure and public improvements, and other terms and conditions of the Project, shall be the Applicable Rules, together with the terms of the DDA and the provisions of this Agreement. To the maximum extent permitted by law (and notwithstanding any future action of the City or its citizens, whether by ordinance, resolution, initiative or otherwise), Developer has the vested right for the Term to develop the Project in accordance with the Applicable Rules and the provisions of the DDA and this Agreement. 3.6.2 Changes Authorized by the City. Nothing in this Agreement shall preclude the City from adopting changes in the Existing Land Use Regulations or any provisions of future General Plans, specific plans, development and design standards or guidelines, zoning codes ordinances or other rules, regulations, ordinances or policies of the City (whether adopted by means of ordinance, initiative, referenda, resolution, policy, order, moratorium, or other means, adopted by the City Council, Planning Commission, or any other board, commission, agency, committee, or department of the City, or any officer or employee thereof) following the Effective Date (collectively, “Future Rules”). Provided that such changes do not Conflict with the Existing Land Use Regulations or the Existing Entitlement Approvals, such Future Rules shall be applicable to the Project and shall be deemed Applicable Rules. Notwithstanding the foregoing, a Future Rule that Conflicts with the then- effective Applicable Rules shall nonetheless apply to the Real Property and be deemed an Applicable Rule if any one of the following apply: (i) it is consented to in writing by Developer; (ii) there is a Public Health Risk as determined by the City in its Governmental Capacity in accordance with Section 3.10.3; (iii) it is required by changes in State or federal law as set forth in Section 3.10.2; (iv) it consists of revisions to or adoption of new building regulations permitted by Section 3.10.4; (v) it is a procedural regulation relating to hearing bodies, petitions, applications, notices, findings, records, hearings, reports, recommendations, appeals and any other matter of procedure excluding those specifically set forth in the Specific Plan or thisAgreement or (vi) it is otherwise expressly permitted by this Agreement. 56 3.6. 20 City of Tustin/Confluent Development Development Agreement 3.6.3 Availability of Public Services. To the maximum extent permitted by law and consistent with its authority, the City shall use commercially reasonable efforts to assist Developer in reserving such capacity for sewer and water services as may be necessary to serve the Project, at no cost or expense to the City. Compliance with SLA Regulations; City Housing Incentive Agreement Requirements. 3.7.1 SLA Covenant. Consistent with the requirements of the SLA Regulations, the Parties have agreed that the City shall Record against the Real Property at the Close of Escrow the SLA Covenant requiring that fifteen percent (15%) of the total number of Residential Units developed on the Real Property shall be restricted as Lower Income Units and remain affordable to, and occupied by, lower income households for a period of fifty five (55) years for rental housing and 45 years for ownership housing, and subject to the further restrictions set forth therein, if any. 3.7.2 Affordable Housing Declaration. The Parties have also agreed that the City shall Record an Affordable Housing Declaration against the Real Property prior to Close of Escrow which shall comprise the housing incentive agreement required pursuant to City Code Section 9142 to ensure implementation of the Affordable Housing Requirements of the Specific Plan and the City’s density bonus ordinance and establishing further regulations and restrictions with respect to the density bonus requested by the Project. As further set forth therein, the AL/MC Real Property shall be released from the Affordable Housing Declaration concurrently with issuance and Recording by the City of the Final Certificate of Compliance, provided that if the Final Parcel Map is Recorded prior to the Recording of the first Certificate of Compliance, then the AL/MC Real Property shall be released from the Affordable Housing Declaration concurrently with issuance and Recording by the City of a Certificate of Compliance for the Active Adult Project. 3.7.3 Developer acknowledges that the requirements of the SLA Covenant and the Affordable Housing Declaration shall be restrictions running with the land and shall be binding upon Developer and each Successor In Interest of Developer and enforceable against Developer and each Successor In Interest of Developer who violates such restrictions and each successor-in-interest who continues the violation by any of the entities described in subdivisions (a) to (f), inclusive, of Section 54222.5 of the California Government Code. The Parties acknowledge and agree that the SLA Covenant will be the same instrument as the SLA Covenant as defined and provided in the DDA and the Affordable Housing Declaration will be the same instrument as the Affordable Housing Declaration as defined and provided in the DDA. Timing of Development. The timing of development will be as set forth in the DDA. Since the California Supreme Court held in Pardee Construction Co. v. City of Camarillo (1984) 37 Cal.3d 465, that the failure of the parties therein to provide for the timing of development resulted in a later adopted initiative restricting the timing of development to prevail over such parties’ agreement, it is the Parties’ intent to cure that deficiency by acknowledging and providing that Developer shall have the vested right to develop the Project on the Real Property at the rate, timing, and sequencing that Developer deems appropriate within the exercise of Developer’s sole subjective business judgment, provided that such development adheres to the terms of the DDA, 57 3.7. 3.8. 21 City of Tustin/Confluent Development Development Agreement the SLA Covenant and the Affordable Housing Declaration regarding the development of the Project and is consistent with State and federal laws governing the Project, including the SLA Regulations. Subsequent Entitlement Approvals; Changes and Amendments to Existing Entitlement Approvals. 3.9.1 Application for Subsequent Entitlement Approvals. The Parties acknowledge that refinement and further development of the Project may require Subsequent Entitlement Approvals and may demonstrate that changes are appropriate and desirable in the Existing Entitlement Approvals. Entitlement Approvals (except for this Agreement, the amendment process for which is set forth in Section 2.5) may be amended or modified from time to time, but only upon application by Developer or with the written consent of Developer. In the event Developer finds that a change in the Existing Entitlement Approvals is necessary or appropriate, Developer shall apply for Subsequent Entitlement Approval(s) to effectuate such change and the City shall process and act on such Application in accordance with the Applicable Rules, except as otherwise provided by this Agreement, including the Reservation of Authority. All amendments to the Existing Entitlement Approvals and all Subsequent Entitlement Approvals approved by the City shall automatically become part of the Applicable Rules without the necessity for amending this Agreement and the same may be further modified from time to time as provided in this Section 3.9.1. 3.9.2 Effect of Agreement on Subsequent Entitlement Approvals. To the extent required, the City shall accept for processing and review and take action on all Applications as provided in Section 3.9 and 3.11.2. In connection with any Subsequent Entitlement Approval, the City shall exercise discretion in the same manner as it exercises its discretion under its police powers, including the Reservation of Authority; provided however, that such discretion shall not prevent development of the Project as set forth in this Agreement. Reservation of Authority. Notwithstanding any other provision of this Agreement to the contrary, the Future Rules described in this Section 3.10 shall apply to and govern development of the Real Property and Project to the extent set forth herein. 3.10.1 Consistent Future City Regulations; Consent By Developer. Future Rules that are not, at the time of adoption, in Conflict with the then-effective Applicable Rules shall apply to and govern development of the Real Property. In addition, Future Rules that Conflict with such Applicable Rules and are not otherwise made applicable pursuant to this Agreement, but are consented to by Developer shall become Applicable Rules and apply and govern development of the Real Property. 3.10.2 Overriding State and Federal Laws. The City shall not be precluded from applying Future Rules to the Real Property and the development of the Project to the extent that such Future Rules are required to be applied by State or federal laws or regulations even if such Future Rules Conflict with the then-effective Applicable Rules, provided however, that (a) Developer does not waive its right to challenge or contest the validity of such State or federal rules or regulations; and (b) such Future Rules, if they Conflict with the then effective Applicable Rules, shall only be applied to the Project and development of the Project to the extent necessary to 58 3.9. 3.10. 22 City of Tustin/Confluent Development Development Agreement comply with such new State or federal law or regulation. To the extent that any federal or State actions (or actions of regional and local agencies, including the City, required by federal or State law or regulation) have the effect of preventing, delaying or modifying development of the Real Property, the City shall not in any manner be liable for any such prevention, delay or modification of said development. Developer is required, at its cost and without cost to or obligation on the part of the City, to participate in such regional or local programs and to be subject to such development restrictions as may be necessary or appropriate by reason of such actions of federal or State agencies (or such actions of regional and local agencies, including the City, required by federal or State agencies). In the event State or federal laws or regulations enacted after this Agreement is entered into Conflict with the provisions in this Agreement and/or require changes in Project Approvals, each Party shall provide the other Party with a copy of such law or regulation and written notice concerning the conflict with this Agreement or the required change in Project Approvals. The Parties shall, within thirty (30) days of the first such notice, meet and confer in good faith in a reasonable attempt to modify this Agreement and/or the Project Approvals to comply with such law or regulation in the manner that is least disruptive to the vested rights and Applicable Rules in effect prior to such new law and the purpose and intent of this Agreement. 3.10.3 Public Health and Safety. Nothing in this Agreement shall preclude the City from adopting and applying Future Rules that are in Conflict with the terms of this Agreement if it is determined by the City in its Governmental Capacity and evidenced through findings adopted by the City Council that the change or provision is required in order to prevent or mitigate a condition dangerous to the public health or safety if such condition presents an immediate or potential material threat to the public health or safety (a “Public Health Risk”), provided, however, that: (a) any such Future Rule is tailored narrowly to address the Public Health Risk and protect health and safety; and (b) that before imposing any Future Rule on the Real Property or the Project based on a Public Health Risk, the City must first provide Developer with written notice of the Public Health Risk upon which the imposition of such Future Rule is based, and if the Public Health Risk is a matter that is capable of cure by Developer, Developer responds in writing within fifteen (15) days confirming that Developer will correct such Public Health Risk and describing the means of such correction, and City concurs in writing, as determined in its Governmental Discretion that such correction will resolve the Public Health Risk and thereafter Developer promptly and diligently pursues such correction to completion, such Future Rule shall no longer be applicable to the Real Property or the Project and City shall take no further action based thereon unless Developer fails to complete such correction in a prompt and diligent manner or the means of correction taken by Developer fails to cure the Public Health Risk. Developer retains the right to administratively dispute the existence of any Public Health Risk or any Future Rule based thereon, but waives the right to challenge the same by way of any legal proceedings. The provisions of this Section 3.10.3 do not apply to any measure adopted by initiative or referendum. 3.10.4 Uniform Construction Codes and Regulations. Policies and rules governing engineering and construction standards and specifications applicable to public and private improvements, including all uniform codes adopted by the City and any local amendments to those codes adopted by the City in the future shall apply to the Project and Real Property. 3.10.5 Police Power. Except as set forth in this Agreement, the City shall retain full rights to exercise its police powers to regulate development of the Project and Real Property. Any uses or development requiring specific plan amendment, design review, subdivision map, 59 23 City of Tustin/Confluent Development Development Agreement conditional use permit, a variance or other Application shall be considered by the City in accordance with the Applicable Rules and shall require permits and/or approval from the City as required by the Applicable Rules, and notwithstanding any other provision set forth herein, this Agreement is not intended to vest Developer’s right to issuance of such permit or approval. In addition, procedural regulations relating to hearing bodies, petitions, applications, notices, findings, records, hearings, reports, recommendations, appeals and any other matter of procedure excluding those specifically set forth in the Specific Plan or this Agreement shall apply to the Project and the Real Property. Processing. 3.11.1 Subdivisions. Any additional subdivision, as defined in California Government Code Section 66473.7 required for the Project other than the Tentative Parcel Map approved with the Entitlement Approvals, shall not be approved unless a tentative map for the subdivision complies with the provisions of said Section 66473.7. This provision is included in this Agreement to comply with California Government Code Section 65867.5. 3.11.2 Subsequent Entitlement Approvals. The City shall, in accordance with and to the full extent allowed by Existing Land Use Regulations and this Agreement, promptly and diligently, commence and complete all steps necessary to act on Developer’s Subsequent Entitlement Approval applications (“Applications”), including: (i) accepting, making completeness determinations, and processing of each Application; (ii) if legally required, providing notice and holding public hearings on an Application; and (iii) acting on each Application. City shall not use its authority in considering, approving or conditioning any Application to revisit or change the fundamental policy decisions reflected by the Entitlement Approvals or otherwise to prevent or delay development of the Project as set forth in the Entitlement Approvals. Notwithstanding the foregoing, this Section 3.11.2 shall not prohibit the City from exercising its police powers to regulate development of the Project and Real Property and if the Application proposes new uses or substantial modifications to the Project, the Applications shall be processed by the City as requests for new entitlement approvals. At such time as any Subsequent Entitlement Approval applicable to the Real Property is approved by the City, then such Subsequent Entitlement Approval shall become subject to all of the terms and conditions of the Development Agreement and shall be treated as part of the “Entitlement Approvals” under this Agreement. 3.11.3 Filings. Developer shall exercise reasonable efforts to file applications for Development Permits and Entitlement Approvals within the time frames and schedules as generally outlined in the DDA and shall exercise reasonable efforts to attempt to obtain Development Permits and Entitlement Approvals within the time frames identified in the DDA; provided, however, that failure solely to comply with such time frame(s) shall not be deemed to be a default under this Agreement. 3.11.4 Cooperation. The City and Developer shall cooperate in processing all applications for permits and approvals for the Project, provided, however, that such cooperation shall not include any obligation of the City to incur any un-reimbursed expense, and the City shall be entitled, subject to the terms of this Agreement, the DDA and Developer’s rights hereunder, to exercise all discretion to which it is entitled by law in processing and issuing any permits and 60 3.11. 24 City of Tustin/Confluent Development Development Agreement approvals for the Project. 3.11.5 Approvals. Notwithstanding any administrative or judicial proceedings, initiative or referendum concerning any of the Entitlement Approvals, the City shall process applications for permits and approvals as provided herein to the fullest extent allowed by law and Developer may proceed at its sole risk with development of the Project pursuant to the DDA and the Applicable Rules to the fullest extent allowed by law. CEQA. This Agreement does not modify, alter or change the City’s obligations pursuant to CEQA. Developer acknowledges that the City is required by State law to comply with CEQA in the consideration and approval of any Subsequent Entitlement Approval and/or any amendment to this Agreement. Nothing in this Agreement shall require or be construed to require CEQA review of ministerial approvals. It is agreed that, in acting on any discretionary Subsequent Entitlement Approval(s) for the Project, the City shall rely on the CEQA approvals approved concurrently with the Existing Entitlement Approvals to satisfy the requirements of CEQA to the extent permissible by CEQA. In the event that any additional CEQA documentation is legally required for any discretionary Subsequent Entitlement Approval for the Project, then the scope of such documentation shall be focused, to the extent possible consistent with CEQA, on the specific subject matter of the Subsequent Entitlement Approval and the City shall conduct such CEQA review as expeditiously as possible, at Developer’s expense. Nothing herein shall restrict or limit the obligation of Developer to pay for and implement any additional mitigation measures or conditions of approval imposed as a result of such CEQA and any Subsequent Entitlement Approval process. 3.12.1 Processing Fees and Charges. (a) The City shall have the right to charge and Developer shall be required to pay all City Processing Fees for the Project and the City has and shall retain discretion to prospectively impose and revise City Processing Fees as the city deems appropriate, in accordance with applicable law and without other restriction. Except as otherwise specifically set forth in Section 3.12.1(b), such City Processing Fees shall be paid in accordance with the procedures and at the generally applicable rates in effect at the time such City Processing Fees are due. (b) With respect to Plan Check and Inspection Services only, the City shall be entitled to charge and Developer shall reimburse the City for its costs to make available City staff, including the City Attorney, and third-party inspectors, engineers and consultants, if any, as required to complete, process, and review plans and applications, complete plan check, perform inspections, and monitor Developer compliance with the requirements of this Agreement and the Applicable Rules. Following approval by the City of this Agreement Developer shall deliver to the City in cash or cash equivalent funds, a deposit in an amount reasonably requested by the City which shall be based on the City’s estimate of staff and third-party consultant time required to complete and perform plan check and inspections (“Processing Fee Deposit”). The Processing Fee Deposit shall be paid to the City concurrently with the first submittal of plans by Developer for which Plan Check and Inspection Services will be required. Developer acknowledges that the City will not commence processing of plans until Developer has paid the Processing Fee Deposit. The Processing Fee Deposit shall be deposited by the City in an account 61 3.12. 25 City of Tustin/Confluent Development Development Agreement in a bank or trust company selected by the City and with no requirement that such account be interest bearing. If any interest is paid on such account, such interest shall accrue to any balances in the account for the benefit of the City. If at any time prior to the latest to occur of (i) issuance of the Final Certificate of Compliance; (ii) the issuance of the final certificate of occupancy for a building on the Real Property; or (iii) termination of the DDA (“Final Date”) as to the Real Property, the amount of funds in the Processing Fee Deposit account is depleted below Ten Thousand Dollars ($10,000), then Developer shall be required to pay to the City each time an additional Twenty Thousand Dollars ($20,000) or such other amount as the City may specify as required in the City’s estimation to cover the cost of Plan Check and Inspection Fees, which shall be credited to the Processing Fee Deposit. Each such payment shall be deposited by the City into the Processing Fee Deposit account and shall be applied to reduce the amount of Plan Check and Inspection Fees incurred by the City. The Processing Fee Deposit has been established to fund the Plan Check and Inspection Fees incurred by the City and may be used by the City for such purpose, and shall be depleted accordingly. Immediately upon incurring any Plan Check and Inspection Fees or costs or receipt of an invoice from third parties for same, the City shall have the right to deduct the amounts due it on account thereof from the Processing Fee Deposit. A monthly accounting of deductions documenting staff time spent to process and review plans and applications, complete plan check, perform inspections, and monitor Developer compliance, along with documentation evidencing any other deductions from the Processing Fee Deposit shall be provided by the City to Developer. The Processing Fee Deposit shall be retained by the City until the Final Date specified above and the remaining amount of the Processing Fee Deposit then held by the City, if any, shall be returned promptly by the City to Developer, provided that the return of such funds shall not terminate the obligations of Developer to pay all City Processing Fees arising or incurred prior to the Final Date. Developer shall pay any outstanding amounts due with respect to the City Processing Fees to the City within thirty (30) calendar days following receipt of an invoice from the City therefor, provided that the City shall first apply the amount of the Processing Fee Deposit, if any, then held by it in satisfaction of such invoice, and shall reflect the amount of such credit on the invoice. 3.12.2 Development Fees. The City shall have the right to impose, and Developer shall pay, all development fees adopted by the City at the time of issuance of building permits for the Project. The City retains discretion to prospectively revise such fees as the City deems appropriate, in accordance with applicable law, and to adopt new development fees from time to time, in its sole discretion. 3.12.3 Project Fair Share Contribution. Notwithstanding Section 3.12.2, the “Project Fair Share Contribution” (relating to the Tustin Legacy Backbone Infrastructure Program) to be contributed by Developer with respect to the Project shall be Three Million Twenty Eight Thousand Seven Hundred Seventy Seven Dollars and Sixty Nine Cents ($3,028,777.69) which is equal to Four Hundred Ninety Three Thousand Four Hundred Forty Seven Dollars ($493,447.00) per acre of land conveyed to Developer by the City and constitutes the full, complete and final satisfaction of the Project Fair Share contribution under the Tustin Legacy Backbone Infrastructure Program with respect to the Property and the Project and no further payment shall be owed or payable thereunder with respect thereto. Such amount shall be paid at the Close of Escrow under the DDA and shall be in addition to the Purchase Price for the Property pursuant to the DDA. Fees Other Than Processing Fees. As of the Effective Date, the City’s 62 3.13. 26 City of Tustin/Confluent Development Development Agreement administrative, processing, building, planning and new construction and other fees are set forth on the FY 25-26 Comprehensive Fee Schedule (approved by City Council Resolution No. 25-50, effective as of September 1, 2025). The term “development fees” as used in Section 3.12.2 does not include City Processing Fees or pass-through fees from other agencies. The term “Existing Impact Fees” as used in this Agreement is a subset of the fees listed on the City’s FY 24-25 Comprehensive Fee Schedule comprising the “new construction fees” only and for purposes of this Agreement are deemed development impact fees. As of the Effective Date, there are no other development impact fees assessed by the City and the City has determined that the Project Fair Share Contribution, which is payable under this Agreement, is not a development impact fee. All other fees and charges described on the City’s FY 25-26 Comprehensive Scheduleshall be deemed Processing Fees, which shall be governed by Section 3.12.1, or pass-through fees from other agencies, including transportation fees and school fees and that are administered by the City, that may be increased from time to time without restriction under this Agreement and that Developer shall pay as and when due. Dedications and Easements.Developer acknowledges and agrees that it is required (and will be required) to make certain dedications and to grant certain easements to the City and other public agencies as set forth in the Access Easement Agreement attached to this Agreement as Exhibit F (as the same may be modified pursuant to the provisions thereof), the Bioswale Easement Agreement attached to this Agreement as Exhibit G and the Landscape Installation and Maintenance Agreement attached to the DDA, each Recorded against the Real Property at Close of Escrow, and such other dedications and easements as more fully set forth on the Final Parcel Map, if Developer elects to Record the same. Regulation by Other Public Agencies. It is acknowledged by the Parties that other public agencies not within the control of the City, including IRWD and the Santa Ana Unified School District, possess authority to regulate aspects of the Project and development of the Real Property separately from or jointly with the City and this Agreement does not limit the authority of such other public agencies. The City agrees to cooperate fully, at no out-of-pocket cost to it, with Developer in obtaining any required permits or compliance with the regulations of other public agencies provided such cooperation is not in conflict with any laws, regulations or policies of the City. Tentative Parcel Map Extension. Any subdivision map, heretofore or hereafter approved in connection with development of the Real Property, shall be eligible for extensions of time as provided in California Government Code Section 66452.6, except that any extension shall be consistent with any performance schedule provided or established in the DDA and shall not be deemed or considered in any way an extension of any Developer rights or obligations under the DDA. Intentionally Omitted. No Quimby Act Fees or Park Fees. Except as set forth in this Agreement, or required by the Entitlement Approvals, all fees and/or dedications required in connection with the Project as park fees or pursuant to the Quimby Act, California Government Code Section 66477 (to the extent applicable to the Project), are included within the Project Fair Share Contribution and Developer shall not have any additional liability on account thereof. 63 3.14. 3.15. 3.16. 3.17. 3.18. 27 City of Tustin/Confluent Development Development Agreement Compliance with Legal Requirements. Prior to the issuance of a certificate of occupancy for each building, Developer shall satisfy all applicable requirements of the Tustin City Code, Specific Plan, and conditions of approval of the Entitlement Approvals relating thereto, including compliance with the Americans with Disabilities Act and necessary Project Improvements to support such building. 4. ANNUAL REVIEW Timing and Annual Review. The City Council shall review Developer’s performance under this Agreement at least every twelve (12) months from the Effective Date until expiration of the Agreement. In connection with such review, both the City and Developer shall have a reasonable opportunity to assert matters which either believes have not been undertaken in accordance with this Agreement, to explain the basis for such assertion, and to receive from the other Party a justification of its position on such matters. Review Procedure. The City shall provide notice to Developer and deliver to Developer a copy of all public staff reports, documents and related exhibits concerning the City’s review of Developer’s performance hereunder at least thirty (30) calendar days prior to any date proposed for City Council review of performance under the Agreement. Good Faith Compliance. Developer or its Successor in Interest shall demonstrate good faith compliance with the terms of this Agreement and shall furnish evidence of good faith compliance, as the City, in its reasonable exercise of its discretion, may require. Evidence of good faith compliance may include the following: (a) conformance with the DDA including the Scope of Development and Schedule of Performance; (b) conformance with the requirements of the Specific Plan; (c) conformance with provisions of this Agreement identified by the City; and (d) payment of all sums due and payable to the City pursuant to the DDA and this Agreement. 4.3.2 Response. Developer shall have the opportunity to be heard and respond to the City’s evaluation of Developer’s performance, either orally or in a written statement, at Developer’s election. 4.3.3 Non-Compliance. If, as a result of its periodic review as described in Section 4, the City Council finds and determines, on the basis of substantial evidence, that Developer has not complied in good faith with the terms or conditions of this Agreement, the City Council may commence proceedings to enforce, modify, or terminate this Agreement. 4.3.4 Referral. The City Council may refer the matter to the Planning Commission for further proceedings or for a report and recommendation. 64 3.19. 4.1. 4.2. 4.3. 28 City of Tustin/Confluent Development Development Agreement Modification or Termination. If the City Council determines to proceed with modification or termination of this Agreement, the City Council shall give notice to Developer of its intention to do so.The notice shall contain all information required by Tustin City Code Section 9618. At the time and place set for the hearing on modification or termination, the City Council may refer the matter back to the Planning Commission for further proceedings or for a report and recommendation. The City Council may take such action as it deems necessary to protect the interests of the City, including the receipt of additional evidence as to Developer’s compliance with the terms of this Agreement. The decision of the City Council shall be final, subject only to judicial review pursuant to California Code of Civil Procedure Section 1094.5(b). Annual Review Certificate Upon Agreement Compliance. If, at the conclusion of a periodic review, Developer is found to comply with this Agreement, the City shall, upon request of Developer, issue a certificate (“Annual Review Certificate”) to Developer stating that after the most recent periodic review and based upon the information known or made known to the City Council that: (a) this Agreement remains in effect, and (b) Developer is not in default. The Annual Review Certificate shall be in Recordable form, shall contain information necessary to communicate constructive record notice of the finding of compliance, and shall state the anticipated date of commencement of the next periodic review. Developer may Record the Annual Review Certificate with the County Recorder. If the City does not find Developer in compliance with this Agreement, it shall not be obligated to issue the Annual Review Certificate. 5. DEFAULT, REMEDIES, AND TERMINATION Default Procedure. A non-defaulting Party (the “Non-Defaulting Party”) at its discretion may elect to declare a default under this Agreement in accordance with the procedures hereinafter set forth for any failure or breach of any other Party (“Defaulting Party”) to perform any material duty or obligation of said Defaulting Party in accordance with the terms of this Agreement. However, the Non-Defaulting Party must provide written notice to the Defaulting Party setting forth the nature of the breach or failure and the actions, if any, required by the Defaulting Party to cure such breach or failure. The Defaulting Party shall be deemed to be in “default” of its obligations set forth in this Agreement if the Defaulting Party has failed to cure the default within ten (10) calendar days after the date of such notice (for monetary defaults) or within thirty (30) calendar days after the date of such notice (for non-monetary defaults). If, however, a non-monetary default cannot be cured within such thirty (30) day period, as long as the Defaulting Party does each of the following: (a) provides the Non-Defaulting Party with a written, reasonable explanation as to the reasons the asserted default is not curable within the thirty (30) day period; (b) notifies the Non-Defaulting Party in writing of the Defaulting Party’s proposed course of action to cure the default; (c) promptly commences to cure the default within the thirty (30) day period; (d) makes periodic written reports to the Non-Defaulting Party as to the progress of the program of cure; and 65 4.4. 4.5. 5.1. 29 City of Tustin/Confluent Development Development Agreement (e) diligently prosecutes such cure to completion, then the Non-Defaulting Party shall grant in writing the Defaulting Party such additional time as determined by the Non-Defaulting Party as reasonably necessary to cure such default. City Remedies. In the event of a default by Developer under this Agreement that is not cured within the time period specified in Section 5.1, the City, at its option, may institute legal action to cure, correct or remedy such default, enjoining any threatened or attempted violation, enforce the terms of this Agreement by specific performance, or pursue any other legal or equitable remedy. Furthermore, the City, in addition to or as an alternative to exercising the remedies in this Section 5.2, in the event of such default by Developer, may give notice of its intent to terminate or modify this Agreement pursuant to Section 4.3, in which event the matter shall be scheduled for consideration and review by the City Council in the manner set forth in Tustin City Code Section 9618. The decision of the City Council shall be final, subject only to judicial review pursuant to California Code of Civil Procedure Section 1094.5(b). Notwithstanding the foregoing, if the City repurchases or revests any portion of the Property as a result of its exercise of the Right of Purchase or Right of Reversion under the DDA, the City shall have the right, in its sole discretion, to merge its interests under this Agreement, to terminate this Agreement as to the Property so repurchased or revested, to modify the provisions of this Agreement related to the Repurchased Property or the Reacquired Property, as applicable, or to take other actions affecting this Agreement or the rights of the City in and to such Repurchased Property or Reacquired Property, as applicable, without the approval of any other person or entity. Developer’s Remedies. In the event of a default of the City under this Agreement that is not cured within the time period specified in Section 5.1, Developer shall be entitled to any or all of the following remedies: (a) seeking mandamus or special writs, injunctive relief, or specific performance of this Agreement; (b) modification or termination of this Agreement; or (c) seeking any other remedy available at law or in equity, provided, however, except as provided in Section 9.10, Developer agrees and covenants on behalf of itself and its Successors In Interest, not to seek in connection with any Claim against the City damages or monetary compensation for breach of this Agreement or arising out of or connected with any dispute, controversy or issue regarding the application or effect of this Agreement, the DDA, the Applicable Rules, or any Development Permits or Entitlement Approvals sought in connection with development or use of the Real Property or Project, or any portion thereof, including for general, special, compensatory, expectation, anticipation, indirect, consequential, exemplary, or punitive damages (“Damages”). Developeracknowledges thatthe Citywould not have entered into this Agreement ifthe City could be held liable for Damages for any default or breach arising out of this Agreement and that Developer has adequate remedies other than Damages to secure the City’s compliance with its obligations under this Agreement. Therefore, Developer agrees that the City, its officers, employees and agents shall not be liable for any Damages and that this Section shall apply to all Successors in Interest of Developer. Third Party Legal Challenges. In the event of any legal action instituted by a third party challenging the validity or enforceability of any provision of this Agreement, the DDA, or Entitlement Approvals for the Project or the approval of any CEQA document prepared in connection with the foregoing, Developer agrees, at its sole cost and expense, to defend (with counsel reasonably acceptable to the City), indemnify, and hold harmless the City, its officers, 66 5.2. 5.3. 5.4. 30 City of Tustin/Confluent Development Development Agreement employees, agents, and consultants, from any claim, action, or proceeding against the City, its officers, agents, and employees, which seeks to attack, set aside, challenge, void, or annul an approval of the City Council, the Planning Commission, or any other decision-making body, including staff, concerning the Project. The City agrees to promptly notify Developer of any such claim or action filed against the City and to cooperate in the defense of any such action. Developer shall also indemnify and hold harmless the City and its agents, officials and employees from and against all claims, losses, or liabilities assessed or awarded against the City by way of judgment, settlement, or stipulation. The City may elect to participate in the defense of any such action under this condition and may, in its sole discretion, elect to be separately represented by the City Attorney and/or outside legal counsel of its choice in any such action or proceeding with the costs of such representation to be paid by Developer. In the event City recovers any attorneys’ fees, expert witness fees, costs, interest, or other amounts from the third party or third parties challenging this Agreement, the DDA, or Entitlement Approvals for the Project, Developer shall be entitled to retain the same in an amount not to exceed payments made pursuant to Developer’s indemnification obligation (provided Developer has fully performed its indemnity obligations hereunder). 6. INDEMNITY BY DEVELOPER Developer agrees to indemnify, defend, and hold harmless the City, the City’s designees, and their respective elected and appointed officials, boards, commissions, agents, contractors, and employees from and against any and all claims, actions, causes of action, demands, orders, or other means of seeking or recovering losses, damages, liabilities, costs, expenses (including attorneys’ fees, fees of expert witnesses, consultants’ fees and court and litigation costs), costs and expenses attributable to compliance with judicial and regulatory orders and requirements, fines, penalties, liens, taxes, monetary payment or reimbursements or any other type of compensation of any kind whatsoever, direct or indirect, known or unknown, foreseen or unforeseen (“Claims”) which may arise, directly or indirectly, from the acts, omissions, or operations of Developer or Developer’s agents, contractors, subcontractors, agents, or employees pursuant to this Agreement, but excluding any loss resulting from the gross negligence, willful misconduct or fraud of the City, the City’s designee, or each of their respective elected and appointed officials, boards, commissions, officers, agents, contractors, and employees. Developer shall select and retain counsel reasonably acceptable to the City to defend any action or actions and Developer shall pay the cost thereof. The indemnity provisions set forth in this Agreement shall survive termination of the Agreement. In the event City recovers any attorneys’ fees, expert witness fees, costs, interest, or other amounts from the third party or third parties asserting a Claim, Developer shall be entitled to retain the same in an amount not to exceed payments made pursuant to Developer’s indemnification obligation (provided Developer has fully performed its indemnity obligations hereunder). 7. MORTGAGEE PROTECTION The Parties hereto agree that this Agreement shall not prevent or limit Developer, in any manner, from encumbering the Real Property or any portion thereof or any improvement thereon by any Mortgage securing financing with respect to the Real Property; provided that nothing herein shall modify or amend the restrictions set forth in the DDA with respect to Mortgages. Any Mortgagee holding a Mortgage that is not prohibited by the DDA associated with the Real Property 67 31 City of Tustin/Confluent Development Development Agreement it encumbers shall be entitled to the following rights and privileges and the provisions below: (a) This Agreement shall be superior and senior to any lien placed upon the Real Property or any portion thereof after the date of Recording of this Agreement, including the lien of any Mortgage. Notwithstanding the foregoing, neither entering into this Agreement nor a breach of this Agreement shall defeat, render invalid, diminish or impair the lien of any Mortgage on the Real Property made in good faith and for value, unless otherwise required by law, and any acquisition or acceptance of title or any right or interest in or with respect to the Real Property or any portion thereof by a Mortgagee (whether pursuant to foreclosure, trustee’s sale, deed in lieu of foreclosure, lease termination or otherwise) shall be subject to the terms and conditions of this Agreement and any such Mortgagee who takes title to the Real Property or any portion thereof shall be entitled to benefits arising under this Agreement. (b) Each Mortgagee of any Mortgage encumbering the Real Property, or any part thereof, shall upon written request in writing to the City, be entitled to receive written notice from the City of results of the Annual Review and of any default by Developer in the performance of Developer’s obligations under this Agreement concurrently with delivery of same to Developer and shall have the right, but not the obligation, to cure the default during the remaining cure period allowed such Party under this Agreement (including any extended cure period necessary in order to allow the Mortgagee to obtain title to the Real Property and cure the default). Notwithstanding the foregoing, the failure of the City to deliver a concurrent copy of such notice of default to a Mortgagee shall not affect in any way the validity of the notice of default as it relates to Developer, and provided, further, the giving of any notice of default or the failure to deliver a copy to any Permitted Mortgagee shall in no event create any liability on the part of the Person so declaring a default (c) Any Mortgagee who comes into possession of the Real Property, or any part thereof, pursuant to foreclosure of the Mortgage or deed in lieu of such foreclosure, shall take the Real Property, or part thereof, subject to the terms of this Agreement, the DDA and the Other Agreements. Notwithstanding any other provision of this Agreement to the contrary, no Mortgagee shall have an obligation or duty under this Agreement to perform any of Developer’s obligations or other affirmative covenants of Developer hereunder, or to guarantee such performance; except that (i) the Mortgagee shall have no right to develop the Real Property without fully complying with the terms of this Agreement, the DDA, the Other Agreements, and the Applicable Rules and (ii) to the extent that any covenant to be performed by Developer is a condition precedent to the performance of a covenant by the City, the performance thereof shall continue to be a condition precedent to the City’s performance hereunder. Notwithstanding anything to the contrary contained above in this Section, any Mortgagee shall be subject to all of the terms of the DDA applicable to the Real Property encumbered and/or acquired by it. 68 32 City of Tustin/Confluent Development Development Agreement 8. INTENTIONALLY OMITTED 9. MISCELLANEOUS PROVISIONS Recording of this Agreement. This Agreement and any amendment or cancellation thereof shall be Recorded by the City Clerk within ten (10) calendar days after the City executes this Agreement, as required by California Government Code Section 65868.5. If the Parties to this Agreement amend or cancel this Agreement as provided for herein and in California Government Code Section 65868, or if the City terminates or modifies this Agreement as provided for herein and in California Government Code Section 65865.1 for failure of Developer to comply in good faith with the terms or conditions of this Agreement, the CityClerk shall have notice of such action Recorded. Entire Agreement. This Agreement, the DDA and the Other Agreements set forth and contain the entire understanding and agreement of the Parties with respect to the matters set forth herein, and there are no oral or written representations, understandings or ancillary covenants, undertakings or agreements which are not contained or expressly referred to herein or therein. No testimony or evidence of any such representations, understandings or covenants shall be admissible in any proceeding of any kind or nature to interpret or determine the terms or conditions of this Agreement. Severability. If any term, provision, covenant or condition of this Agreement shall be determined invalid, void or unenforceable, the remainder of this Agreement shall not be affected thereby to the extent such remaining provisions are not rendered impractical to perform taking into consideration the purposes of this Agreement. Interpretation and Governing Law. This Agreement and any dispute arising hereunder shall be governed and interpreted in accordance with the internal laws of the State of California without reference to choice of law or conflicts of law provisions. This Agreement shall be construed as a whole according to its fair language and common meaning to achieve the objectives and purposes of the Parties hereto, and the rule of construction to the effect that ambiguities are to be resolved against the drafting Party shall not be employed in interpreting this Agreement, all Parties having been represented by counsel in the negotiation and preparation hereof. The decision of the City Council shall be final, subject only to judicial review pursuant to California Code of Civil Procedure Section 1094.5(b). Section Headings. All section headings and subheadings are inserted for convenience only and shall not affect any construction or interpretation of this Agreement. Construction. 9.6.1 References to Sections, Clauses and Exhibits. Unless otherwise indicated, references in this Agreement to sections, clauses and exhibits are to the same contained in or attached to this Agreement and all exhibits referenced in this Agreement are incorporated in this Agreement by this reference as though fully set forth in this Section. 9.6.2 Singular and Plural. As used herein, the singular of any word includes 69 9.1. 9.2. 9.3. 9.4. 9.5. 9.6. 33 City of Tustin/Confluent Development Development Agreement the plural and vice versa. 9.6.3 Includes and Including. As used in this Agreement the words “include” and “including” mean, respectively, “include, without limitation” and “including, without limitation”. Time of Essence. Subject to the following sentence, time is of the essence in the performance of each provision of this Agreement. Whenever action must be taken (including the giving of notice or the delivery of documents) under this Agreement during a certain period of time or by a particular date that ends or occurs on a non-Business Day, then such period or date shall be extended until the immediately following Business Day. Waiver. Failure by a Party to insist upon the strict performance of any of the provisions of this Agreement by the other Party, or the failure by a Party to exercise its rights upon the default of the other Party, shall not constitute a waiver of such Party’s right to insist and demand strict compliance by the other Party with the terms of this Agreement thereafter. No Third Party Beneficiaries. This Agreement is made and entered into for the sole protection and benefit of the City and its successors and assigns and Developer and its Successors In Interest. No other person shall have any right of action based upon any provision of this Agreement. Attorneys’ Fees. Wherever Developer has an obligation to defend the City under this Agreement, Developer shall, prior to selection of counsel, consult in good faith with the City to ensure that the City is satisfied, in its sole discretion that the proposed legal counsel has the professional expertise and experience to demonstrate they are well-qualified to defend the City against the Claim(s) and has not taken a position adverse to the City in the past. If any Party to this Agreement institutes any Action, suit, proceeding, counterclaim or other proceeding for any relief against another Party, declaratory or otherwise (collectively an “Action”), to enforce the terms hereof or to declare rights under this Agreement or with respect to any inaccuracies or material omissions in connection with any of the covenants, representations, warranties or obligations on the part of the other Party to this Agreement, then the Prevailing Party in such Action shall be entitled to have and recover of and from the other Party all costs and expenses of the Action, including (a) the Prevailing Party's reasonable attorneys' fees (which shall be payable at the contractual hourly rate for the City’s litigation counsel at the time the fees were incurred, but in no event more than Four Hundred Dollars ($400.00) per hour with this rate being used to calculate the attorneys’ fees to be recovered by the Prevailing Party regardless of whether the City or another Person is the Prevailing Party, and (b) costs actually incurred in bringing and prosecuting such Action and/or enforcing any judgment, order, ruling or award (collectively, a “Decision”) granted therein, all of which shall be deemed to have accrued on the commencement of such Action and shall be paid whether or not such Action is prosecuted to a Decision. Any Decision entered in any final judgment shall contain a specific provision providing for the recovery of all costs and expenses of suit, including reasonable attorneys’ fees and expert fees and costs (collectively “Costs”) incurred in enforcing, perfecting and executing such judgment. For the purposes of this paragraph, Costs shall include in addition to Costs incurred in prosecution or defense of the underlying Action, reasonable attorneys’ fees, costs, expenses and expert fees and costs incurred in the following: (i) post judgment motions and collection actions; (ii) contempt proceedings; (iii) 70 9.7. 9.8. 9.9. 9.10. 34 City of Tustin/Confluent Development Development Agreement garnishment, levy, debtor and third party examinations; (iv) discovery; (v) Bankruptcy Proceedings and similar proceedings not involving Developer, and (vi) appeals of any order or judgment. “Prevailing Party” within the meaning of this Section 9.10 includes a Party who agrees to dismiss an Action in consideration for the other Party’s payment of the amounts allegedly due or performance of the covenants allegedly breached, or obtains from a court of competent jurisdiction substantially the relief sought by such Party. Force Majeure Delay. During the Term of this Agreement, any determination of Force Majeure Delay as to the Active Adult Project or the AL/MC Project under the DDA shall be an event of Force Majeure Delay under this Agreement as to the applicable Active Adult Project or AL/MC Project only. Time periods for performance of any obligations under this Agreement may be extended for Force Majeure Delay, provided that the maximum extension for Force Majeure Delay as to the Active Adult Project or the AL/MC Project as a result of Force Majeure Delay shall be as set forth in the DDA and as to each such portion of the Project shall not cumulatively exceed twelve (12) months and provided further that in no event shall the Term be extended by an event of Force Majeure Delay beyond that set forth in Section 2.3. Successors. The burdens of this Agreement shall be binding upon, and the benefits of this Agreement shall inure to, the City and its successors and assigns and Developer and its Successors in Interest. All provisions of this Agreement shall be enforceable as equitable servitudes and constitute covenants running with the land. Each covenant to do or refrain from doing some act hereunder with regard to development of the Real Property: (a) is for the benefit of and is a burden upon every portion of the Real Property; (b) runs with the Real Property and each portion thereof; and (c) is binding upon the City and its successors and assigns and upon Developer and each Successor in Interest during ownership of the Real Property or any portion thereof and for such longer period as such Person may have liability hereunder. Notwithstanding the foregoing, upon acquisition of the Real Property or any portion thereof by the City pursuant to exercise of the Right of Purchase or Right of Reversion or action in lieu thereof pursuant to the DDA, the City shall have the right in its sole discretion to terminate this Agreement as to the portion of the Real Property so acquired and the Agreement shall remain binding, in accordance with its terms, upon the remainder of the Real Property. In the event that the City repurchases or revests all or any portion of the Real Property pursuant to exercise of the Right of Purchase or Right of Reversion, such acquisition shall include all Entitlement Approvals and other development rights, consents, authorizations, variances, waivers, licenses, permits, certificates and approvals from any governmental or quasi-governmental authority, and all other appurtenant rights applicable thereto, including those buildings and/or Residential Units or Rooms, as applicable, allocated to the respective Repurchased Property or the Reacquired Property, as applicable, as shown in the Approved Plan. Counterparts. This Agreement may be executed by the Parties in counterparts, which counterparts shall be construed together and have the same effect as if all of the Parties had executed the same instrument. Jurisdiction and Venue. Any action at law or in equity arising under this Agreement or brought by a Party hereto for the purpose of enforcing, construing or determining the validity of any provision of this Agreement shall be filed and tried in the Superior Court of the County of Orange, State of California, or the United States District Court for the Central District of 71 9.11. 9.12. 9.13. 9.14. 35 City of Tustin/Confluent Development Development Agreement California, Santa Ana Division, and the Parties hereto waive all provisions of law providing for the filing, removal or change of venue to any other court. Project as a Private Undertaking. It is specifically understood and agreed by and between the Parties hereto that the development of the Project is a private development, that neither Party is acting as the agent of the other in any respect hereunder, and that each Party is an independent contracting entity with respect to the terms, covenants and conditions contained in this Agreement. No partnership, joint venture or other association of any kind is formed by this Agreement. The only relationship between the City and Developer with respect to this Agreement is that of a government entity regulating the development of private property and the developer of such property. Further Actions and Instruments. Each of the Parties shall cooperate with and provide reasonable assistance to the other to the extent contemplated hereunder in the performance of all obligations under this Agreement and the satisfaction of the conditions of this Agreement. Upon the request of either Party at any time, the other Party shall promptly execute, with acknowledgment or affidavit if reasonably required, and file or Record such required instruments and writings and take any actions as may be reasonably necessary under the terms of this Agreement to carry out the intent and to fulfill the provisions of this Agreement or to evidence or consummate the transactions contemplated by this Agreement. Estoppel Certificate. Any Party hereunder, may at any time but not more than four times in a calendar year, deliver a written notice to the other Party requesting such Party to certify in writing that, to the best knowledge of the certifying Party: (a) this Agreement is in full force and effect and a binding obligation of the Party; (b) this Agreement has not been amended or modified either orally or in writing, or if so amended, identifying the date and nature of the amendments to this Agreement, and, in each case, that the Agreement remains in full force and effect (including as amended or modified if applicable), and a continuing binding obligation of the Party; and (c) the requesting Party is not in default in performance of its obligations set forth in the Agreement, or if the Party is in default, provide a description of the nature of such default(s). A Party receiving a request hereunder shall execute and return such certificate within thirty (30) calendar days following receipt thereof. The party to whom such certificate is addressed, including any third party or Mortgagee, shall be entitled to rely on the certificate. Developer shall pay to the City all costs incurred by the City in connection with the issuance of estoppel certificates. Authority to Execute. The person or persons executing this Agreement on behalf of each Party warrants and represents that he or she/they have the authority to execute this Agreement on behalf of such Party and warrants and represents that he or she/they has/have the authority to bind such Party to the performance of its obligations hereunder. Non-Liability of City Officials and City Employees. No elected or appointed official, representative, employee, agent, consultant, legal counsel or employee of the City shall be personally liable to Developer for any amount which may become due to Developer under the terms of this Agreement. No Merger. As of the Effective Date, the Real Property is owned in fee by the City, and portions of the Real Property may continue to be owned in fee by the City during the Term or 72 9.15. 9.16. 9.17. 9.18. 9.19. 9.20. 36 City of Tustin/Confluent Development Development Agreement may be conveyed by the City to one or more Developers and subsequently reconveyed to the City during the Term. Except as expressly set forth below, there shall be no merger of any rights, interests or estates created by this Agreement as a result of the ownership by the City of all or any portion of the Real Property and no merger shall occur with respect to any portion of the Real Property unless and until the City and all persons and entities at the time having a legal and/or equitable ownership interest in such portion of the Real Property shall join in a written instrument affecting such merger and shall duly Record the same. No Discrimination. There shall be no discrimination against or segregation of any person or group of persons on account of race, color, creed, religion, sex, sexual orientation, marital status, national origin or ancestry in the sale, lease, sublease, transfer, use, occupancy, tenure or enjoyment of the land, nor shall the transferee itself or any person claiming under or through it, establish or permit any such practice or practices of discrimination or segregation with reference to the selection, location, number, use or occupancy of tenants, lessees, subtenants, sublessees or vendees of the land. 73 9.21. S-1 City of Tustin/Confluent Development Development Agreement SIGNATURE PAGES TO DEVELOPMENT AGREEMENT IN WITNESS WHEREOF, the Parties hereto have executed this Agreement on the day and year set forth below. Dated: THE CITY OF TUSTIN: By: Austin Lumbard, Mayor ATTEST: By: Erica N. Yasuda City Clerk APPROVED AS TO FORM By: David Kendig City Attorney Hepner & Myers LLP Special Real Estate Counsel to the City By: ______________________ Amy E. Freilich {signatures continued on following page} 74 75 SIGNATURE PAGES TO DEVELOPMENT AGREEMENT CONT. STATE OF COLORADO ) "DEVELOPER" CD-CW (Tustin) LLC, a Colorado limited liability company By: CD Manager LLC, a Colorado limited liability company, its Manager By: Confluent Development LLC, a Colorado limited liability company, its Manager ByN~fr~ J Title: Chief Executive Officer CITY AND ) SS: COUNTY OF DENVER ) The foregoing instrument was acknowledged before me this .J1L~y of July, 2026, by Marshall M. Burton, as Chief Executive Officer of Confluent Development, LLC, a Colorado limited liability company, as Manager of CD Manager LLC, a Colorado limited liability company, as Manager of CD-CW (Tustin) LLC, a Colorado limited li • ity company. WITNESS my hand and official seal. [SEAL] / / D Notary Public My Commission Expires: ______ D_l_,_t-"0 ____ 3_,_f,_,aa ___ O__,,3 _______ _ AMY JO STACKAWITZ 1 NOTARY PUBLIC STATE OF COLORADO 4 NOTARY 10 # 20144000269 1 MY COMMISSION EXPIRES 01/0312030 1 S-2 City of Tustin/Confluent Development Development Agreement S-3 City of Tustin/Confluent Development Development Agreement CALIFORNIA ALL PURPOSE ACKNOWLEDGEMENT A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. State of California County of _________________________________ On _________________ before me, ________________________________________________, Date (Insert Name and Title of the Officer) personally appeared ___________________________________________________________ Name(s) of Signer(s) ____________________________________________________________________________, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Place Notary Seal and/or Stamp above Signature: ______________________________________ Signature of Notary Public 76 } EXHIBIT A City of Tustin/Confluent Development Development Agreement EXHIBIT A TO DEVELOPMENT AGREEMENT LEGAL DESCRIPTION OF PROPERTY The Land referred to herein below is situated in the City of Tustin, County of Orange, State of California, and is described as follows: LOT 14, INCLUSIVE OF TRACT NO. 18197 AS SHOWN ON A MAP FILED IN BOOK 990, PAGES 25 THROUGH 33, INCLUSIVE OF TRACT MAPS, RECORDS OF ORANGE COUNTY, CALIFORNIA. For conveyancing purposes only: APN 430-481-12 77 EXHIBIT B City of Tustin/Confluent Development Development Agreement EXHIBIT B TO DEVELOPMENT AGREEMENT MAP SHOWING PROPERTY AND ITS LOCATION 78 =-~·t,,~~ .:JO '(!'"'{A .,.~ ~-" ~' TRACT NO. 18197 .... Q'ffonwTlf co:r,:;z.~~L~ (.o... fT IUOC n::'J!'"1M QIIJO ._ ,,,.,, 1"'91C.a.«\M,."'U ... .,._.,.__.,.....11011i1&. o.•t:1~.U..\'- Clll'M. T.:,nl)10111.f PROPERTY LINE& RIGHT OF WAYPROPERTY LINE& RIGHT OF WAYPROPERTY LINE & RIGHT OF WAYPROPERTY LINE& RIGHT OF WAYJOHN JOHNSON WAYWARNER AVENUEȭARMSTRONG AVENUEȭȭȭVETERANS WAYPROJECT NO.DRAWN BY:DESIGNED BY:DATE:REVIEWED BY:DATENO. REVISIONCKBYSHEET NO.Save Date: Plot Date: 7/8/2026 3:00 PM7/8/2026 3:20 PMBy: Juta P:\C\CONFCDMS0012\0400CAD\EXHIBITS\2026-07-07 Tustin Development Agreement Exhibits For Confluent\Reference\EXHIBIT B-CONFCDMS0012 - Copy.dwgJustin TatBy: File:CHECKED BY:®17542 E. 17th StreetSuite 150Tustin, CA 92780714.665.450055DYER RDBARRANCA PKWYRED HILL AVEEDINGER AVEEDINGER AVETUSTIN RANCH RDVON KARMAAVEWARNER AVEARMSTRONG AVEVETERANSWAY261WARNER AVESAN DIEGOFRWY JAMBOREE RDCOSTA MESA FRWYSANTA ANA FRWYEASTERNTRANSPORTATIONCORRIDORVICINITY MAPN.T.S.EXHIBIT B -PROPERTY MAP & VICINITY MAPCLEARWATER AT TUSTIN LEGACYTENTATIVE PARCEL MAP 2025-151LOT 14, TRACT NO. 18197, M.M. 990/25-33TUSTIN, CA 9260607/08/2026CONFCDMS-00121OF 1EXHIBIT B TO DEVELOPMENT AGREEMENT MAP SHOWING PROPERTY AND ITS LOCATION 79 ! I \ I J I l ---- EXHIBIT C City of Tustin/Confluent Development Development Agreement EXHIBIT C TO DEVELOPMENT AGREEMENT PUBLIC BENEFITS IMPROVEMENTS Developer shall construct the following Public Benefits Improvements, which shall be completed within the time periods set forth in the Schedule of Performance attached to and forming part of the DDA, and in accordance with the Entitlement Approvals and Approved Plans: 1. Developer shall design and construct sidewalk, parkway landscape and irrigation system adjacent to the Project along Warner Avenue, Armstrong Avenue, John Johnson Way and Veterans Way. 2. Developer shall, pursuant to the Landscape Installation and Maintenance Agreement entered into with the City, install landscaping and perform the maintenance, repair, and replacement of the landscaping described therein within the Landscape Area depicted on Exhibit D. A detailed landscape improvement exhibit shall be provided in the Landscape Installation and Maintenance Agreement. 80 EXHIBIT D City of Tustin/Confluent Development Development Agreement EXHIBIT D LANDSCAPE AREA [Attached] 81 DWRWRWDWDWDWDWDWDWDWSSSSSSSSSSSSSSSSDW SS SS SS SS SS SS SS SSSS DWDWDWDWDWDWDWDWEE EEEE E E E EE ': ':':':SL ',6,6',6,6' ',6':':':':',6,6'',6 ,6 6'.6'.6'.6'.STCCEEEEEESTSTIRRIRRIRRIRRIRRIRRJPROPERTY LINE& RIGHT OF WAYPROPERTY LINE& RIGHT OF WAYPROPERTY LINE & RIGHT OF WAYPROPERTY LINE& RIGHT OF WAYJOHN JOHNSON WAYWARNER AVENUEVETERANS WAYASSISTED LIVING /MEMORY CAREBUILDINGARMSTRONG AVENUEACTIVE ADULT BUILDINGPROJECT NO.DRAWN BY:DESIGNED BY:DATE:REVIEWED BY:DATENO. REVISIONCKBYSHEET NO.Save Date: Plot Date: 7/31/2026 12:52 PM7/31/2026 12:57 PMBy: Juta P:\C\CONFCDMS0012\0400CAD\EXHIBITS\2026-07-07 Tustin Development Agreement Exhibits For Confluent\Reference\EXHIBIT D-CONFCDMS0012 - Copy.dwgJustin TatBy: File:CHECKED BY:®17542 E. 17th StreetSuite 150Tustin, CA 92780714.665.4500EXHIBIT D -LANDSCAPE AREACLEARWATER AT TUSTIN LEGACYTENTATIVE PARCEL MAP 2025-151LOT 14, TRACT NO. 18197, M.M. 990/25-33TUSTIN, CA 9260607/08/2026CONFCDMS-00121OF 1LEGENDLANDSCAPE AREAEXHIBIT D TO DEVELOPMENT AGREEMENT LANDSCAPE AREA 82 EXHIBIT E City of Tustin/Confluent Development Development Agreement EXHIBIT E SITE PLAN [showing Active Adult Real Property and AL/MC Real Property] [Attached] 83 SSSSSSSSSSSSDWDWSSSSDWDWDWDWSSDWSS SS DW DW RW DWRWRWDWDWDWDWDWDWDWSSSSSSSSSSSSSSSSDW SS SS SS SS SS SS SS SSSS DWDWDWDWDWDWDWDWEE EEEE E E E EE ': ':':':SL ',6,6',6,6' ',6':':':':',6,6'',6 ,6 6'.6'.6'.6'.STCCEEEEEESTSTIRRIRRIRRIRRIRRIRRJPROPERTY LINE& RIGHT OF WAYPROPERTY LINE& RIGHT OF WAYPROPERTY LINE & RIGHT OF WAYPROPERTY LINE& RIGHT OF WAYJOHN JOHNSON WAYWARNER AVENUEVETERANS WAYASSISTED LIVING /MEMORY CAREBUILDINGARMSTRONG AVENUEACTIVE ADULT BUILDINGFUTURE PARCEL LINEPROJECT NO.DRAWN BY:DESIGNED BY:DATE:REVIEWED BY:DATENO. REVISIONCKBYSHEET NO.Save Date: Plot Date: 8/3/2026 3:15 PM8/3/2026 3:19 PMBy: Juta P:\C\CONFCDMS0012\0400CAD\EXHIBITS\2026-07-07 Tustin Development Agreement Exhibits For Confluent\Reference\EXHIBIT E-CONFCDMS0012.dwgJustin TatBy: File:CHECKED BY:®17542 E. 17th StreetSuite 150Tustin, CA 92780714.665.4500EXHIBIT E -SITE PLANCLEARWATER AT TUSTIN LEGACYTENTATIVE PARCEL MAP 2025-151LOT 14, TRACT NO. 18197, M.M. 990/25-33TUSTIN, CA 9260607/08/2026CONFCDMS-00121OF 1EXHIBIT E TO DEVELOPMENT AGREEMENT SITE PLAN ACTIVE ADULT REAL PROPERTYAL/MCREALPROPERTY84 t;: w -o ...J I-a, <(e> Wu uso:r ~G en -~ EXHIBIT F City of Tustin/Confluent Development Development Agreement EXHIBIT F ACCESS EASEMENT AGREEMENT [Attached] 85 Tustin Confluent Access Easement Agreement 7.8.26 (HM) Exhibit F 1 City of Tustin/Confluent Development Portion of Disp. Area 8 EXHIBIT F ACCESS EASEMENT AGREEMENT CITY OF TUSTIN OFFICIAL BUSINESS REQUEST DOCUMENT TO BE RECORDED AND TO BE EXEMPT FROM RECORDING FEES PER GOVERNMENT CODE §6103 AND §27383. RECORDING REQUESTED BY: AND WHEN RECORDED MAIL TO: City Manager The City of Tustin 300 Centennial Way Tustin, California 92780 Space Above This Line Reserved for Recorder’s Use ACCESS EASEMENT AGREEMENT This ACCESS EASEMENT AGREEMENT (“Agreement”) is made this ____ day of_________, 202_, by CD-CW (TUSTIN) LLC, a Colorado limited liability company (“Developer”) and the CITY OF TUSTIN (“City”) and is made for the benefit of the City, the successors and assigns of the City, and where specified, its residents and the public at large. A. Immediately prior to the recording of this Agreement in office of the County Clerk Recorder for Orange County, California (“Official Records”), the City has conveyed to Developer that certain real property legally described on Schedule 1 attached hereto and made a part hereof (“Real Property”) and Developer intends to develop the Real Property with an active adult residential facility and related improvements and an assisted living and memory care commercial facility and related improvements, together with on-site infrastructure and a complete accompanying set of high quality amenities as further described in (1) that certain statutory Development Agreement between City and Developer recorded in the Official Records on ____________as Instrument No.____________, [{if amended add reference to amendment(s)} (as so amended,] (“Development Agreement”) and (2) that certain Disposition and Development Agreement for Portion of Disposition Area 8 (Tustin Legacy) between Developer and City dated as of ___________, 20__(“ DDA”) [{if amended add reference to amendment(s)} (as so amended,] “DDA”), a memorandum of which DDA was recorded in the Official Records immediately prior to recording of this Agreement. The DDA contemplates that the City will execute and record in the Official Records one or two certificates of compliance for the Real Property upon the terms set forth therein. Each such certificate of compliance executed by the City and recorded in the Official Records is referred to herein as a “Certificate of Compliance”. 86 Tustin Confluent Access Easement Agreement 7.8.26 (HM) Exhibit F 2 City of Tustin/Confluent Development Portion of Disp. Area 8 B. As partial consideration for the conveyance of the Real Property by the City to Developer, Developer has agreed to grant certain easements in favor of the City pursuant to this Agreement. C. Pursuant to the California Subdivision Map Act, the City has approved Tentative Parcel Map No. 2025-151, which is attached to this Agreement for reference as Schedule 2 and is incorporated herein by this reference (“Tentative Parcel Map”). The Tentative Parcel Map, with such additional modifications as may be requested by Developer or required by the City in accordance with the process described in Recital D, is proposed to be recorded in the Official Records upon approval thereof by the City and Orange County and, following its recording shall be referred to as the “Final Parcel Map”. Notwithstanding the foregoing, Developer shall have the right, but not the obligation, to cause recording of the Final Parcel Map. D. This Agreement is also intended to preserve and maintain the obligation of Developer and each and every Person owning or acquiring fee title to all or any portion of the Real Property (“Successor Owner”), and each and every Person claiming by, through or under Developer or any Successor Owner, to grant the easements defined and approved as to specific locations by the City Engineer and/or other agencies, as depicted on the Tentative Parcel Map attached as Schedule 2, and other easements, if any, defined and approved as to specific locations by the City Engineer and/or other agencies on the Tentative Parcel Map as the same may be modified with the approval of the City in the exercise of its legislative, administrative and/or enforcement capacity in approving the Final Parcel Map. NOW THEREFORE, Developer hereby covenants, and Developer and City hereby agree, as follows: 1. Developer hereby grants and conveys to the City, for the benefit of the City and its successors and assigns, at no cost to the City or any of the beneficiaries thereof, a non-exclusive, perpetual easement in gross and right of way for purposes of allowing common access and emergency vehicle access over the private drives and driveways to be created upon the Real Property for such use identified as Proposed Easement “B” as depicted on the Tentative Parcel Map; provided that if the Final Parcel Map is recorded in the Official Records and modifications are made in that Final Parcel Map to the locations of the emergency vehicle access and public service routes described in this Paragraph 1, then upon recording in the Official Records of the Final Certificate of Compliance (or upon such date thereafter as the Final Parcel Map may be recorded) the City shall execute and cause the recording in the Official Records of the Termination attached hereto as Schedule 3 terminating the easements granted by this Paragraph 1 as to the portion of the Real Property for which the Certificate of Compliance has been issued and the easements granted in the Final Parcel Map shall remain in effect and govern. 2. For avoidance of doubt, the grants of easements made by Developer in this Agreement shall have priority over the lien and charge of any mortgage, construction lien and/or other lien upon the Real Property and any improvements thereon and the same shall not be modified or affected by the subsequent recording of the Final Parcel Map except upon recording of a Termination as provided in Section 1 above. 87 Tustin Confluent Access Easement Agreement 7.8.26 (HM) Exhibit F 3 City of Tustin/Confluent Development Portion of Disp. Area 8 3. Unless expressly provided herein, the City, on behalf of itself and its successors and assigns, upon acceptance of the foregoing easements, agrees that any obligations by Developer to prepare, improve or otherwise alter the Real Property as may expressly be stated in the Development Agreement, the DDA and/or Other Agreements and that this Agreement does not modify, reduce or expand such obligations. 4. This Agreement is an equitable servitude and shall be binding upon the Developer and its Successor Owners and each and every Person claiming by, through or under Developer or any Successor Owner and shall run with the Real Property for the benefit of the City and its successors and assigns in perpetuity, unless and until terminated as set forth herein. 5. This Agreement shall be recorded in the Official Records against the Real Property. 6. This Agreement may be signed in counterparts, each of which shall be deemed an original and all of which when taken together shall constitute one instrument. 7. The Recitals above are incorporated herein by reference. {remainder of page blank; signatures commence on following page} 88 Tustin Confluent Access Easement Agreement 7.8.26 (HM) Exhibit F S-1 City of Tustin/Confluent Development Portion of Disp. Area 8 IN WITNESS WHEREOF, the Developer and City have executed this Access Easement Agreement on the date first above written. Dated: CITY OF TUSTIN: By: Name: Aldo E. Schindler Title: City Manager ATTEST: By: Erica N. Yasuda City Clerk APPROVED AS TO FORM By: David Kendig City Attorney Hepner & Myers LLP Special Real Estate Counsel to the City By: Amy E. Freilich DEVELOPER: ____________________, a _________limited liability company By: _________________________ Name: Title: 89 Tustin Confluent Access Easement Agreement 7.8.26 (HM) Exhibit F S-2 City of Tustin/Confluent Development Portion of Disp. Area 8 CERTIFICATE OF ACCEPTANCE OF EASEMENT (City of Tustin) This is to certify that the interest in real property conveyed by the ACCESS EASEMENT AGREEMENT dated ____________, 20__ from the owners of the Real Property, being __________________, a _____________ to the CITY OF TUSTIN, a governmental agency, is hereby accepted by the undersigned officer on behalf of the CITY OF TUSTIN pursuant to authority conferred by Resolution No. 95- 39 of the CITY OF TUSTIN adopted on April 3, 1995, and the grantee consents to recordation thereof by its duly authorized officer. Dated:_____________________ _________________________ Erica N. Yasuda, City Clerk 90 Tustin Confluent Access Easement Agreement 7.8.26 (HM) Exhibit F S-3 City of Tustin/Confluent Development Portion of Disp. Area 8 CALIFORNIA ALL PURPOSE ACKNOWLEDGEMENT A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. State of California County of _________________________________ On _________________ before me, ________________________________________________, Date (Insert Name and Title of the Officer) personally appeared ___________________________________________________________ Name(s) of Signer(s) ____________________________________________________________________________, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Place Notary Seal and/or Stamp above Signature: ______________________________________ Signature of Notary Public 91 } Tustin Confluent Access Easement Agreement 7.8.26 (HM) Exhibit F S-4 City of Tustin/Confluent Development Portion of Disp. Area 8 STATE OF COLORADO ) CITY AND ) SS: COUNTY OF DENVER ) The foregoing instrument was acknowledged before me this ____ day of July, 2026, by Marshall M. Burton, as Chief Executive Officer of Confluent Development, LLC, a Colorado limited liability company, as Manager of CD Manager LLC, a Colorado limited liability company, as Manager of CD-CW (Tustin) LLC, a Colorado limited liability company. WITNESS my hand and official seal. Notary Public My Commission Expires: [SEAL] 92 Tustin Confluent Access Easement Agreement 7.8.26 (HM) Exhibit F Schedule 1 City of Tustin/Confluent Development Portion of Disp. Area 8 SCHEDULE 1 Legal Description of Real Property The Land referred to herein below is situated in the City of Tustin, County of Orange, State of California, and is described as follows: LOT 14, INCLUSIVE OF TRACT NO. 18197 AS SHOWN ON A MAP FILED IN BOOK 990, PAGES 25 THROUGH 33, INCLUSIVE OF TRACT MAPS, RECORDS OF ORANGE COUNTY, CALIFORNIA. Excluding therefrom the rights and interests reserved by the City in Section 2 of the Quitclaim Deed for the Real Property made by the City in favor of Developer recorded immediately prior to recording of this Agreement. For conveyancing purposes only: APN 430-481-12 93 Tustin Confluent Access Easement Agreement 7.8.26 (HM) Schedule 2 City of Tustin/Confluent Development Portion of Disp. Area 8 SCHEDULE 2 Tentative Parcel Map [see attached] 94 EEEE E E E E E E E E E E E E E EEEE E E E E E E E E E E E E E E E E E EEESL SL SL SL '''',6,6,6,6,6,6,6,6,6''',6,6,6,6,6,6,6,6,6',6,6,6,6,6,6,6,6''''STSTSTSTSLSLEEEEEEEEEEEEEEEEESTSTSTSTSTSTSTSTSTDSSSSRWRPBPBRWRWARNER AVEJOHN JOHNSON WAY7(37.55' R1)37.55'641N17°00'00".E 432.38' (432.38' R1)L=112.35')(L=603.35' R1)L=603.35'N 64°05'52" W 280.62' (280.62' R1)ǻ=16°06'48"(ǻ=16°06'56" R1)TELEPHONE PULL BOX (NE COR3.0' SW'LY OF PLELECTRIC PULL BOX (NE COR)2.8' SW'LY OF PLTV PULL BOX (NE COR)3.3' SW'LY OF PLTELEPHONE VAULT (NE COR2.0' SW'LY OF PLWALL (NE COR END)1.2' SW'LY OF PLELECTRIC PULL BOX (SE COR)6.5' NE'LY OF PLCULVERT BOX (SW COR)2.4' NE'LY OF PLIRRIGATION BOX (SE COR)5.7' NE'LY OF PLWALL (N'LY FACE)0.1' SW'LY OF PLWALL (N'LY FACE)CROSSING PLWALL (NW COR END)8.4' NE'LY OF PLIRRIGATION CONTROL BOX(NE COR) 3.2' NW'LY OF PLSEWER MAN HOLE (CENTER)4.0' SE'LY OF PLPROPERTY LINE& RIGHT OF WAYPROPERTY LINE & RIGHT OF WAYDIRTSIDEWALK (BACK)0.1' NE'LY OF PLSIDEWALK (BACK)0.1' NE'LY OF PL2ARMSTRONG AVEPROPOSED5-STORY ACTIVE ADULTBUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.47PROPOSED2-STORY ASSISTED LIVING& MEMORY CARE BUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.80EX 12" DWEX 72" SDEX 15" SSC/LC/LC/LC/LL=23.37', R=15.00'N23°14'34"EL=59.44'EXISTING 36" SDEX. 36" SDEX 10" SSEX 10" DWEX. 8" SSEX. 10" WAEX RWEX ELECEX 24" SDEX 10" WAEX 8" SS(NOT A PART)(NOT APART)L=47.60',R =20.00'37.02' N 20°5 4' 1 7 " W6065 7075565758596162636466676869717273747677555453555453515556575859 L=107.44',R=311.66'S64°38'16"EL=6.95'N25°54'08"EL=126.17'L=303.67'(L=303.67' R1)L=308.03'(L=308.03' R1)(R=1982.00' R1)R=1982.00'(R=1954.00' R1)R=1954.00'N 64°05'52" W 201.98' (201.98' R1)(ǻ=8°54'16" R1)ǻ=8°54'16"ǻ=8°54'16"(ǻ=8°54'16" R1)ǻ=5°48'14"R=1470.00'(R=1470.00' R1)(ǻ=5°48'14" R1)L=148.91'(L=148.91' R1)(ǻ=20°05'37" R1)ǻ=20°05'40"R=1400.00'(R=1400.00' R1)ǻ=4°35'52"(L=112.37' R1)(ǻ=4°35'55" R1)(ǻ=24°41'32" R1)ǻ=24°41'32"(302.17' R1)302.17'N 75°31'01" W(L=96.90' R1)(R=1460.00' R1)ǻ=3°48'10"29"W50.00'(50.00' R1)(114.22' R1)N39°10'31" E 114.22'(ǻ=12°32'28" R1)ǻ=12°32'28"R=1348.04'(R=1348.04' R1)L=295.06'(L=295.06' R1)55.000535354545954PROPOSED LOT LINEPROPOSED LOT LINEPROPOSED (PRIVATE)MODULAR WETLANDSTORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED(PRIVATE) 8" SEWERPROPOSED (PRIVATE) 6" FIREWATER AND BACKFLOW PREVENTERPROPOSED (PRIVATE)6" FIRE WATERPROPOSED (PRIVATE)OLDCASTLE STORMCAPTUREPROPOSED (PRIVATE) 4" DOMESTICWATER AND BACKFLOW PREVENTERPROPOSED(PRIVATE) 8" SEWERPROPOSED (PRIVATE)48" STORM DRAINDEMOLISH PORTION OFEXISTING STORM DRAINLATERAL AND CATCH BASINPROPOSED (PRIVATE)8" SEWER20.9'23.7'15.9'11.6'15.9'70.4'50.3'12.8'42.7'35.0'70.1'25.3'46.1'24.6'22.7'25.7'11.8'15.4'27' DRIVEWAY17.2'14.2'27' DRIVEWAY20.0'20.0'PARCEL 1121,531 SF (2.79 AC)PARCEL 2145,854 SF (3.35 AC)314P/LP/LP/LPROPOSED (PRIVATE)48" STORM DRAINN25°54'08"EL=83.62'PROPOSED (PRIVATE)48" STORM DRAINPROPOSED(PRIVATE)8" SEWERP/LN 25°58'17" W 38.45'(38.45' R1)P/LPROPOSED (PRIVATE)6" FIRE WATERPROPOSED (PRIVATE)6" DOMESTIC WATERPROPOSED (PRIVATE)48" STORM DRAINBBBBBAA(37.0 2' R 1 )3N 39°10'31" E 205.21'(205.21' R1)(ǻ=14°45'07" R1)ǻ=14°45'07"ǻ=32°59'59"(ǻ=32°59'59" R1)R=1400.04'(R=1400.04' R1)(L=360.47' R1)L=360.47'1914L=806.36'(L=806.36' R1)(L=393.79' R1)L=393.73'19P/L234.24'(234.24' R1)N 73°00'08" W206.24'(206.24' R1)N 73°00'08" W5.0'(NOT APART)VETERANS WAY51(ǻ=3°48'10" R1)PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE6.0'REMOVE PORTION OF EXISTINGSTORM DRAIN LATERAL ANDCATCH BASIN; CAP STORMDRAIN AT PROPERTY LINEPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)48" STORM DRAINCAP EXISTING STORMDRAIN CONNECTORPIPE AT PROPERTYLINE1L=96.90'R=1460.00'19PROPCBPROPCBPROPCBPROPCBPROPCBPROPCBPROPCBTRACT 17144APN: 430-272-12TRACT 18197APN: 430-481-1519TRACT 18197APN: 430-481-24N17°00'00"E 133.00' (133.00' R1)N 13°56'50" EN 17°00'00" E 138.72' (138.72' R1)3256575857585959565758585959565657575555545555545656PROPOSED (PRIVATE)OLDCASTLE STORMCAPTUREǻ=10°42'21"R=170.77'(L=31.91')(R=170.77')(R1)(ǻ=10°42'21")L=31.91'76L=26.48'(ǻ=07°43'15")(R1)(R=196.48')(L=26.48')R=196.48'ǻ=07°43'15"ǻ=13°06'14"R=41.00'(L=9.38')(R=41.00')(R1)(ǻ=13°06'14")L=9.38'54L=15.91'(ǻ=15°27'12")(R1)(R=59.00')(L=15.91')R=59.00'ǻ=15°27'12"ǻ=02°21'00"R=1472.00'(L=60.37')(R=1472.00')(R1)(ǻ=02°21'00")L=60.37'3DELTAǻ=14°11'50"CURVE1LENGTHL=10.16'RADIUSR=41.00'(L=10.16')LENGTHRADIUS(R=41.00')RECORD(R1)DELTA(ǻ=14°11'50")2L=14.78'(ǻ=14°20'59")(R1)(R=59.00')(L=14.78')R=59.00'ǻ=14°20'59"(R1) (N85°15'23"E)(0.11')0.11'N85°15'23"EN38°14'17"E4.92' (4.92')(N38°14'17"E)(R1)(R1) (N85°15'26"E)(37.48')37.48'N85°15'26"EN51°45'31"W32.83' (32.83')(N51°45'31"W)(R1)(36.45')(N36°37'39"W)1LINEDISTANCEBEARINGN36°37'39"W36.45'RECORD BEARING DISTANCE(R1)(R1) (N68°46'50"W)(36.20')36.20'N68°46'50"W23456RWEEEE E E E E E E E E E EEEE E E E E E E E E E E E E E E E E E E E ': ': ':':':':':':':':':':':':':'''',6,6,6,6,6,6,6,6,6'''',6,6,6,6,6,6,6,6,6,6' ' ' ' ',6,6,6,6,6,6,6,6':':': ':':':':':':':':':''''',6,6,6,6,6,6,6,6,6'',6 ,6 ,6 ,6 6'.6'.6'.6'.6'.6'.6'. 6'.6'.6'.STSTSTSTSLCCCEEEEEEEEEEEESTSTSTSTSDSSSSSSRWRPBPBPBRWRWARNER Y157(37.55' R1)37.55'641N17°00'00".E 432.38' (432.38' R1)(L=490.98' R1)L=491.00'(L=603.35' R1)N50°49'29"W 185.10' (185.10' R1)L=603.35'N 64°05'52" W 280.62' (280.62' R1)TELEPHONE PULL BOX (NE COR)3.0' SW'LY OF PLELECTRIC PULL BOX (NE COR)2.8' SW'LY OF PLTV PULL BOX (NE COR)3.3' SW'LY OF PLTELEPHONE VAULT (NE COR)2.0' SW'LY OF PLWALL (NE COR END)1.2' SW'LY OF PLELECTRIC PULL BOX (SE COR)6.5' NE'LY OF PLCULVERT BOX (SW COR)2.4' NE'LY OF PLIRRIGATION BOX (SE COR)5.7' NE'LY OF PLWALL (N'LY FACE)0.1' SW'LY OF PLWALL (N'LY FACE)CROSSING PLWALL (NW COR END)8.4' NE'LY OF PLELECTRIC MANHOLE (CENTER)3.2' SW'LY OF PLIRRIGATION CONTROL BOX(NE COR) 3.2' NW'LY OF PLSEWER MAN HOLE (CENTER)4.0' SE'LY OF PLPROPERTY LINE& RIGHT OF WAYPROPERTY LINE & RIGHT OF WAYDIRTN46°41'40"W1853.44'(GPS TIE)SIDEWALK (BACK)0.1' NE'LY OF PLSIDEWALK (BACK)0.1' NE'LY OF PLSIDEWALK (BACK)AT PL1211ARMSTRONG AVEPROPOSED5-STORY ACTIVE ADULTBUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.47PROPOSED2-STORY ASSISTED LIVING& MEMORY CARE BUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.80EX 12" DWEX 36" SDEX 72" SDEX 15" SSC/LC/LC/LC/LL=23.37', R=15.00'N23°14'34"EL=59.44'EXISTING 36" SDEX. 36" SDEX 10" SSEX 10" DWEX. 8" SSEX RWEX ELECEX RWEX 24" SDEX 10" WAEX 8" SS(NOT APART)L=47.60',R =20.00'37.02' N 20°5 4' 1 7 " W6065 7075565758596162636466676869717273747677555453555453515556575859 L=107.44',R=311.66'S64°38'16"EL=6.95'N25°54'08"EL=126.17'L=303.67'(L=303.67' R1)L=308 03'(R=1954.00' R1)R=1954.00'N 64°05'52" W 201.98' (201.98' R1)(ǻ=8°54'16" R1)ǻ=8°54'16"ǻ=5°48'14"R=1470.00'(R=1470.00' R1)(ǻ=5°48'14" R1)L=148.91'(L=148.91' R1)(ǻ=20°05'37" R1)ǻ=20°05'40"R=1400.00'(R=1400.00' R1)(L=(ǻ=(ǻ=24°41'32" R1)ǻ=24°41'32"(L=96.90' R1)(R=1460.00' R1)ǻ=3°48'10"N50°49'29"W50.00'(50.00' R1)(114.22' R1)N39°10'31" E 114.22'(ǻ=12°32'28" R1)ǻ=12°32'28"R=1348.04'(R=1348.04' R1)L=295.06'(L=295.06' R1)55.000535354545954PROPOSED LOT LINEPROPOSED LOT LINEPROPOSED (PRIVATE)MODULAR WETLANDSTORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED(PRIVATE) 8" SEWERPROPOSED (PRIVATE) 6" FIREWATER AND BACKFLOW PREVENTERPROPOSED (PRIVATE)6" FIRE WATERPROPOSED (PRIVATE)OLDCASTLE STORMCAPTUREPROPOSED (PRIVATE) 4" DOMESTICWATER AND BACKFLOW PREVENTERPROPOSED(PRIVATE) 8" SEWERPROPOSED (PRIVATE)48" STORM DRAINDEMOLISH PORTION OFEXISTING STORM DRAINLATERAL AND CATCH BASINPROPOSED (PRIVATE)8" SEWER20.9'23.7'15.9'11.6'15.9'70.4'50.3'12.8'42.7'35.0'70.1'25.3'46.1'24.6'22.7'25.7'11.8'15.4'27' DRIVEWAY17.2'14.2'27' DRIVEWAY20.0'20.0'PARCEL 1121,531 SF (2.79 AC)PARCEL 2145,854 SF (3.35 AC)3164P/LP/LP/LPROPOSED (PRIVATE)48" STORM DRAINN25°54'08"EL=83.62'PROPOSED (PRIVATE)48" STORM DRAINPROPOSED(PRIVATE)8" SEWERP/LN 25°58'17" W 38.45'(38.45' R1)P/LPROPOSED (PRIVATE)6" FIRE WATERPROPOSED (PRIVATE)6" DOMESTIC WATERPROPOSED (PRIVATE)48" STORM DRAINBBBBBAA(37.0 2' R 1 )3N 39°10'31" E 205.21'(205.21' R1)(ǻ=14°45'07" R1)ǻ=14°45'07"ǻ=32°59'59"(ǻ=32°59'59" R1)R=1400.04'(R=1400.04' R1)(L=360.47' R1)L=360.47'1914L=806.36'(L=806.36' R1)93.79' R1)=393.73'EX 6" RW19P/L234.24'(234.24' R1)N 73°00'08" W206.24'(206.24' R1)N 73°00'08" W5.0'VETERANS WAY51(ǻ=3°48'10" R1)PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE6.0'REMOVE PORTION OF EXISTINGSTORM DRAIN LATERAL ANDCATCH BASIN; CAP STORMDRAIN AT PROPERTY LINEPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)48" STORM DRAINCAP EXISTING STORMDRAIN CONNECTORPIPE AT PROPERTYLINE1L=96.90'R=1460.00'19PROPCBPROPCBPROPCBPROPCBPROPCBPROPCBPROPCBTRACT 17144APN: 430-272-12(NOT APART)TRACT 17404APN: 430-371-20N17°00'00"E 133.00' (133.00' R1)N 13°56'50" EN 17°00'00" E 138.72' (138.72' R1)3256575857585959565758585959565657575555545555545656PROPOSED (PRIVATE)OLDCASTLE STORMCAPTURETENTATIVE PARCEL MAP 2025-151PROJECT NO.DRAWN BY: JTKADESIGNED BY: JITDATE:REVIEWED BY:DATENO. REVISIONCKBYSHEET NO.CHECKED BY: JITSave Date: Plot Date: 1/19/2026 4:04 PM1/19/2026 4:25 PMBy: Rxka P:\C\CONFCDMS0012\0400CAD\SHEETS\EC\Entitlements\Tentative Parcel Map\EC-001-CV-CONFCDMS0012-TPM.dwgRobyn KathermanBy: File:®CONFCDMS-0013CLEARWATER AT TUSTIN LEGACYTENTATIVE PARCEL MAP 2025-151LOT 14, TRACT NO. 18197, M.M. 990/25-33TUSTIN, CA 9260617542 17th St., Suite 150Tustin, CA, 92780Phone: 714.665.4500OWNER:CITY OF TUSTIN,300 CENTENNIAL WAYTUSTIN, CA 92780ATTN:PROJECT ADDRESS:LOT 14, TRACT NO. 18197, M.M. 990/25-33TUSTIN, CA 92606CIVIL ENGINEER:DAVID EVANS AND ASSOCIATES, INC.25152 SPRINGFIELD COURT, SUITE 350SANTA CLARITA, CA 91355ATTN: JONATHAN TAPIAPHONE 661.284.7436E-MAIL: JTAPIA@DEAINC.COMARCHITECT:HPI ARCHITECTURE115 22ND STREETNEWPORT BEACH, CA 92663PHONE: 949.675.6442BASIS OF BEARINGS:THE BEARING SHOWN HEREON ARE BASED ON THE CALCULATED BEARINGBETWEEN O.C.S. HORIZONTAL CONTROL STATION GPS NO. 6529 AND GPS NO.6535 BEING NORTH 03° 46' 13" WEST PER RECORDS ON FILE IN THE OFFICE OFTHE ORANGE COUNTY SURVEYOR.BENCHMARK:THE ELEVATIONS SHOWN HEREON ARE BASED UPON THE ORANGE COUNTYPUBLIC WORKS VERTICAL CONTROL DATA SHEET BENCHMARK NO. 3A-107-77,(YEAR 2013).3 3/4" OCS ALUMINUM BENCHMARK DISK STAMPED "3A-107-77" IN THEWESTERLY CORNER OF A 4 FT BY 11 FT CONCRETE CATCH BASIN.MONUMENT IS LOCATED IN THE NORTHERLY CORNER OF THE INTERSECTIONOF REDHILL AVENUE AND WARNER AVENUE, 47 FT NORTHEASTERLY OF THECENTERLINE MEDIAN ALONG WARNER AND 105 FT NORTHWESTERLY OF THECENTERLINE OF REDHILL AVENUE. MONUMENT IS LEVEL WITH THE SIDEWALK.ELEVATION = 62.047'CONTOURS SHOWN HEREON ARE 1' INTERVAL.BOUNDARY/PARCEL LINEPROPOSED PARCEL LINEEASEMENTEXISTING UTILITIESLEGENDEXISTING R/W55DYER RDBARRANCA PKWYRED HILL AVEEDINGER AVEEDINGER AVETUSTIN RANCH RDVON KARMAAVEWARNER AVEARMSTRONG AVEVETERANSWAY261WARNER AVESAN DIEGOFRWYJAMBOREE RDCOSTA MESA FRWYSANTA ANA FRWYEASTERNTRANSPORTATIONCORRIDORR1.....INDICATES DATA PER TRACT NO. 18197, M.B. 990/25-33R2.....INDICATES DATA PER TRACT NO. 17144, M.B. 906/5-14( )INDICATES RECORD DATA.INDICATES REFERENCE RECORD DATA.R1INDICATES DESCRIPTION NUMBER.1MONUMENT NOTES:LEGAL DESCRIPTION: INDICATES FOUND MONUMENT, AS NOTED.THE LAND REFERRED TO HEREIN BELOW IS SITUATED IN THE CITY OF TUSTIN, COUNTY OF ORANGE, STATEOF CALIFORNIA, AND IS DESCRIBED AS FOLLOWS:LOT 14, INCLUSIVE OF TRACT NO. 18197 AS SHOWN ON A MAP FILED IN BOOK 990, PAGES 25 THROUGH 33,INCLUSIVE OF TRACT MAPS, RECORDS OF ORANGE COUNTY, CALIFORNIA.EXCEPTING THEREFROM ANY AND OIL, OIL RIGHTS, MINERALS, MINERAL RIGHTS, NATURAL GAS RIGHTSAND OTHER HYDROCABONS BY WHATSOEVER NAME KNOWN, GEOTHERMAL STEAM AND ALL PRODUCTSDERIVED FROM ANY OF THE FOREGOING, THAT MAY BE WITHIN OR UNDER THE LAND, TOGETHER WITH THEPERPETUAL RIGHT OF DRILLING, MINING, EXPLORING FOR AND STORING IN AND REMOVING THE SAMEFROM THE LAND OR ANY OTHER LAND, INCLUDING THE RIGHT TO WHIPSTOCK OR DIRECTIONALLY DRILLAND MINE FROM LANDS OTHER THAT THE LAND, OIL OR GAS WELLS, TUNNELS AND SHAFTS INTO, THROUGHOR ACROSS THE SUBSURFACE OF THE LAND AND TO BOTTOM SUCH WHIPSTOCKED OR DIRECTIONALLYDRILLED WELLS, TUNNELS AND SHAFTS UNDER AND BENEATH OR BEYOND THE EXTERIOR LIMITS THEREOF,AND TO REDRILL, RETUNNEL, EQUIP, MAINTAIN, REPAIR, DEEPEN AND OPERATED ANY SUCH WELL ORMINES; BUT WITHOUT, HOWEVER, THE RIGHT TO DRILL, MINE, STORE, EXPLORE OR OPERATE THROUGH THESURFACE OF THE LAND, AS RESERVED IN THE DEED FROM THE CITY OF TUSTIN, CALIFORNIA, RECORDEDSEPTEMBER 24, 2002 AS INSTRUMENT NO. 20020819173 OF OFFICIAL RECORDS.ALSO EXCEPTING THEREFROM ANY AND ALL WATER, WATER RIGHTS OR INTERESTS THEREINAPPURTENANT OR RELATING TO THE LAND OR OWNED OR USED BY THE GRANTOR IN CONNECTION WITHOR WITH RESPECT TO THE LAND (NO MATTER HOW ACQUIRED BY THE GRANTOR), WHETHER SUCH RIGHTSSHALL BE RIPARIAN, OVERLYING, APPROPRIATIVE, LITTORAL, PERCOLATING, ADJUDICATED, STATUTORY ORCONTRACTUAL, TOGETHER WITH THE PERPETUAL RIGHT AND POWER TO EXPLORE, DRILL, REDRILL ANDREMOVE THE SAME FROM OR IN THE LAND, TO STORE THE SAME BENEATH THE SURFACE OF THE LANDAND TO DIVERT OR OTHERWISE UTILIZE SUCH WATER, RIGHTS OR INTERESTS ON ANY OTHER PROPERTYOWNED OR LEASE BY GRANTOR; BUT WITHOUT, HOWEVER, ANY RIGHT TO ENTER UPON OR USE THESURFACE OF THE LAND IN THE EXERCISE OF SUCH RIGHTS, AS RESERVED IN THE DEED FROM THE CITY OFTUSTIN, CALIFORNIA, RECORDED SEPTEMBER 24, 2002 AS INSTRUMENT NO.20020819173 OF OFFICIAL RECORDS.FOR CONVEYANCING PURPOSES ONLY: APN 430-481-12INDICATES CALCULATED FROMCFFOUND SPIKE & WASHER STAMPED "LS 6673" PER R1, FLUSH; ACCEPTED AS ARMSTRONG AVENUE& WARNER AVENUE CENTERLINE INTERSECTION PER R1.1PER FIRST AMERICAN TITLE INSURANCE COMPANY, REPORT NO. NCS-1146469-SA1, DATEDMAY 07, 2025TITLE EXCEPTIONS:1. ANY DEFECT, LIEN, ENCUMBRANCE, ADVERSE CLAIM, OR OTHER MATTER THAT APPEARS FOR THEFIRST TIME IN THE PUBLIC RECORDS OR IS CREATED, ATTACHES, OR IS DISCLOSED BETWEEN THECOMMITMENT DATE AND THE DATE ON WHICH ALL OF THE SCHEDULE B, PART I-REQUIREMENTS AREMET.2. (A) TAXES OR ASSESSMENTS THAT ARE NOT SHOWN AS EXISTING LIENS BY THE RECORDS OF ANYTAXING AUTHORITY THAT LEVIES TAXES OR ASSESSMENTS ON REAL PROPERTY OR BY THE PUBLICRECORDS; (B) PROCEEDINGS BY A PUBLIC AGENCY THAT MAY RESULT IN TAXES OR ASSESSMENTS,OR NOTICES OF SUCH PROCEEDINGS, WHETHER OR NOT SHOWN BY THE RECORDS OF SUCHAGENCY OR BY THE PUBLIC RECORDS.3. ANY FACTS, RIGHTS, INTERESTS, OR CLAIMS THAT ARE NOT SHOWN BY THE PUBLIC RECORDS BUTTHAT COULD BE ASCERTAINED BY AN INSPECTION OF THE LAND OR THAT MAY BE ASSERTED BYPERSONS IN POSSESSION OF THE LAND.4. EASEMENTS, LIENS OR ENCUMBRANCES, OR CLAIMS THEREOF, NOT SHOWN BY THE PUBLICRECORDS.5. ANY ENCROACHMENT, ENCUMBRANCE, VIOLATION, VARIATION, OR ADVERSE CIRCUMSTANCEAFFECTING THE 77TLE THAT WOULD BE DISCLOSED BY AN ACCURATE AND COMPLETE LAND SURVEYOF THE LAND AND NOT SHOWN BY THE PUBLIC RECORDS.6. (A) UNPATENTED MINING CLAIMS; (B) RESERVATIONS OR EXCEPTIONS IN PATENTS OR IN ACTSAUTHORIZING THE ISSUANCE THEREOF; (C) WATER RIGHTS, CLAIMS OR TITLE TO WATER, WHETHEROR NOT THE MATTERS EXCEPTED UNDER (A), (B), OR (C) ARE SHOWN BY THE PUBLIC RECORDS.7. GENERAL AND SPECIAL TAXES AND ASSESSMENTS FOR THE FISCAL YEAR 2023-2024, A LIEN NOT YETDUE OR PAYABLE.8. GENERAL AND SPECIAL TAXES AND ASSESSMENTS FOR THE FISCAL YEAR 2022-2023 ARE EXEMPT. IFTHE EXEMPT STATUS IS TERMINATED AN ADDITIONAL TAX MAY BE LEVIED. A.P. NO.: 430-481-12.9. THE LIEN OF SPECIAL TAX ASSESSED PURSUANT TO CHAPTER 2.5 COMMENCING WITH SECTION 53311OF THE CALIFORNIA GOVERNMENT CODE FOR COMMUNITY FACILITIES DISTRICT NO. 13-01, ASDISCLOSED BY NOTICE OF SPECIAL TAX LIEN RECORDED MAY 16, 2013 AS INSTRUMENT NO.2013000296640 OF OFFICIAL RECORDS.10. THE LIEN OF SPECIAL TAX ASSESSED PURSUANT TO CHAPTER 2.5 COMMENCING WITH SECTION 53311OF THE CALIFORNIA GOVERNMENT CODE FOR COMMUNITY FACILITIES DISTRICT NO. 15-2, ASDISCLOSED BY NOTICE OF SPECIAL TAX LIEN RECORDED NOVEMBER 18, 2015 AS INSTRUMENT NO.2015000594036 OF OFFICIAL RECORDS.11. THE LIEN OF SPECIAL TAX ASSESSED PURSUANT TO CHAPTER 2.5 COMMENCING WITH SECTION 53311OF THE CALIFORNIA GOVERNMENT CODE FOR COMMUNITY FACILITIES DISTRICT NO. 2018-01, ASDISCLOSED BY NOTICE OF SPECIAL TAX LIEN RECORDED FEBRUARY 17, 2021 AS INSTRUMENT NO.2021000112117 OF OFFICIAL RECORDS.12. THE LIEN OF SUPPLEMENTAL TAXES, IF ANY, ASSESSED PURSUANT TO CHAPTER 3.5 COMMENCINGWITH SECTION 75 OF THE CALIFORNIA REVENUE AND TAXATION CODE.13. THE TERMS AND PROVISIONS CONTAINED IN THE DOCUMENT ENTITLED "SHORT FORM NOTICE OFAGREEMENT" RECORDED MAY 14, 2002 AS INSTRUMENT NO. 20020404589 OF OFFICIAL RECORDS.14. EASEMENTS, COVENANTS AND CONDITIONS CONTAINED IN THE DEED FROM THE UNITED STATES OFAMERICA, AS GRANTOR, TO THE CITY OF TUSTIN, CALIFORNIA, AS GRANTEE, RECORDED MAY 14, 2002AS INSTRUMENT NO. 20020404594 OF OFFICIAL RECORDS. REFERENCE BEING MADE TO THEDOCUMENT FOR FULL PARTICULARS.DOCUMENT RE-RECORDED APRIL 09, 2003 AS INSTRUMENT NO.2003000392129 OF OFFICIAL RECORDS.NOT PLOTTED.15. THE FACT THAT THE LAND LIES WITHIN THE BOUNDARIES OF THE MCAS TUSTIN REDEVELOPMENTPROJECT AREA, AS DISCLOSED BY THE DOCUMENT RECORDED JUNE 18, 2003 AS INSTRUMENT NO.2003000710836 OF OFFICIAL RECORDS.NOT PLOTTED.16. THE TERMS AND PROVISIONS CONTAINED IN THE DOCUMENT ENTITLED "DECLARATION OF SPECIALRESTRICTIONS" RECORDED JUNE 19, 2007 AS INSTRUMENT NO. 2007000390805 OF OFFICIAL RECORDS.NOT PLOTTED.17. COVENANTS, CONDITIONS, RESTRICTIONS AND EASEMENTS IN THE DOCUMENT RECORDED OCTOBER04, 2006 AS INSTRUMENT NO. 2006000661919 OF OFFICIAL RECORDS, WHICH PROVIDE THAT AVIOLATION THEREOF SHALL NOT DEFEAT OR RENDER INVALID THE LIEN OF ANY FIRST MORTGAGE ORDEED OF TRUST MADE IN GOOD FAITH AND FOR VALUE, BUT DELETING ANY COVENANT, CONDITIONOR RESTRICTION INDICATING A PREFERENCE, LIMITATION OR DISCRIMINATION BASED ON RACE,COLOR, RELIGION, SEX, HANDICAP, FAMILIAL STATUS, NATIONAL ORIGIN, SEXUAL ORIENTATION,MARITAL STATUS, ANCESTRY, SOURCE OF INCOME OR DISABILITY, TO THE EXTENT SUCHCOVENANTS, CONDITIONS OR RESTRICTIONS VIOLATE TITLE 42, SECTION 3604(C), OF THE UNITEDSTATES CODES OR SECTION 12955 OF THE CALIFORNIA GOVERNMENT CODE. LAWFUL RESTRICTIONSUNDER STATE AND FEDERAL LAW ON THE AGE OF OCCUPANTS IN SENIOR HOUSING OR HOUSING FOROLDER PERSONS SHALL NOT BE CONSTRUED AS RESTRICTIONS BASED ON FAMILIAL STATUS. NOTPLOTTED18. THE TERMS AND PROVISIONS CONTAINED IN THE DOCUMENT ENTITLED "NOTICE OF DELINQUENCYAND CLAIM OF LIEN" RECORDED APRIL 06, 2010 AS INSTRUMENT NO. 2010000160007 OF OFFICIALRECORDS. NOT PLOTTED.19. AN EASEMENT SHOWN OR DEDICATED ON THE MAP OF TRACT NO. 18197 RECORDED DECEMBER 10,2020 AND ON FILE IN BOOK 990, PAGE 25-33, OF TRACT MAPS.FOR: PUBLIC STREET AND PUBLIC UTILITY PURPOSES: ARMSTRONG AVENUE, WARNER AVENUE,LEGACY ROAD, AIRSHIP AVENUE, FLIGHT WAY, HELBER WAY, VETERANS WAY, COMPASS AVENUE,SWAIM WAY, JOHN JOHNSON WAY AND PEEBLER WAY AND INCIDENTAL PURPOSES.PLOTTED HEREON.20. WATER RIGHTS, CLAIMS OR TITLE TO WATER, WHETHER OR NOT SHOWN BY THE PUBLIC RECORDS.21. AN ALTA/NSPS SURVEY OF RECENT DATE WHICH COMPLIES WITH THE CURRENT MINIMUM STANDARDDETAIL REQUIREMENTS FOR ALTA/NSPS LAND TITLE SU1VEYS.22. ANY FACTS, RIGHTS, INTERESTS OR CLAIMS WHICH WOULD BE DISCLOSED BY A CORRECT ALTA/NSPSSURVEY.23. RIGHTS OF PARTIES IN POSSESSION.FOUND SPIKE & WASHER STAMPED "LS 6673" PER R1, FLUSH; ACCEPTED AS ARMSTRONG AVENUECENTERLINE BEGINNING CURVE PER R1.2FOUND SPIKE & WASHER STAMPED "LS 6673" PER R2, FLUSH; ACCEPTED AS ARMSTRONG AVENUE& C STREET CENTERLINE INTERSECTION PER R2.3SEARCHED FOUND NOTHING, SET NOTHING; ARMSTRONG AVENUE & JOHN JOHNSON WAY CENTERLINEINTERSECTION ESTABLISHED BY RECORD RADIUS AND DISTANCE (360.47') FROM 2 PER R14FOUND SPIKE & WASHER STAMPED "LS 5347" PER R1, FLUSH; ACCEPTED AS WARNER AVENUE& LEGACY ROAD CENTERLINE INTERSECTION PER R1.5SEARCHED FOUND NOTHING, SET NOTHING; WARNER AVENUE & VETERANS WAYCENTERLINE INTERSECTION ESTABLISHED BY RECORD DISTANCES FROM 1 PER R16SEARCHED FOUND NOTHING, SET NOTHING; VETERANS WAY & JOHN JOHNSON WAY CENTERLINEINTERSECTION ESTABLISHED BY RECORD BEARING & DISTANCES FROM 6 PER R17FOUND SPIKE & WASHER STAMPED "LS 6673" PER R1, FLUSH; ACCEPTED AS ARMSTRONG AVENUECENTERLINE BEGINNING CURVE PER R1.8DATUM STATEMENT:COORDINATES SHOWN ARE BASED ON THE CALIFORNIA COORDINATE SYSTEM(CCS83), ZONE VI, 1983 NAD, (2017.50 EPOCH OCS GPS ADJUSTMENT).ALL DISTANCES SHOWN ARE GROUND UNLESS OTHERWISE NOTED. TO OBTAINGRID DISTANCE, MULTIPLY GROUND DISTANCE BY 0.99997671 (PROJECTSPECIFIC).FLOOD ZONE:THIS SURVEY LIES WITHIN ZONE "X" (AREAS DETERMINED TO BE OUTSIDE THE0.2% ANNUAL CHANCE FLOODPLAIN) AS SET OUT ON THE FLOOD INSURANCERATE MAP FOR ORANGE COUNTY, COMMUNITY PANEL NUMBER 06059C 0279J,DATED DECEMBER 3, 2009.VICINITY MAPN.T.S.EXCEPTIONS/ENCROACHMENT NOTES:UTILITIES WITHOUT EASEMENT ON THE NORTHERLY BOUNDARY AS SHOWN.1WALL CROSSING THE PROPERTY LINE ON THE NORTHERLY BOUNDARY AS SHOWN.2UTILITIES WITHOUT EASEMENT ON THE SOUTHWESTERLY BOUNDARY AS SHOWN.3LINE AND CURVE TABLESC-0.0CENTERLINEUTILITY PURVEYORS:ELECTRICAL:SOUTHERN CALIFORNIA EDISON1325 S GRAND AVE.SANTA ANA, CA 92705(800)-655-4555GAS:SOUTHERN CALIFORNIA GAS COMPANY1919 STATE COLLEGE BLVD.ANAHEIM, CA 92805(877) 238-0092(714) 634-3245CABLE:TIME WARNER14311 NEWPORT AVE.TUSTIN, CA 927803(714) 418-4267FRONTIER COMMUNICATION7354 SLATER AVE.HUNTINGTON BEACH, CA 92647(714) 969-6468COX6771 QUAIL HILL PKWY.IRVINE, CA 92603(949) 546-1000TELEPHONECOX COMMUNICATIONS6771 QUAIL HILL PKWY.IRVINE, CA 92603(949) 546-1000AT&T (LAND LINE SERVICE)3581 ORANGE STRIVERSIDE , CA 92501(909) 441-0499WATER & SEWER:IRVINE RANCH WATER DISTRICT3512 MICHELSON DR,IRVINE, CA 92612(714) 453-5300STORM DRAINCITY OF TUSTIN (PUBLIC WORKS)300 CENTENNIAL WAYTUSTIN, CA 92780(714)-573-3150SUBDIVIDER/DEVELOPER:CD-CW (TUSTIN) LLC2215 MARKET ST.DENVER, CO 80205ATTN: H. MCNEISHPHONE: 303.573.6500PROPOSED EASEMENTS:APROPOSED EASEMENT TO THE CITY OF TUSTIN FOR BIOSWALE ACCESS ANDMAINTENANCE PURPOSES AND UTILITIES (PULLBOXES, VAULTS, CONDUITS)TO BE RESERVED IN SEPARATE DOCUMENT (4,260 SF)BPROPOSED EASEMENT FOR COMMON ACCESS AND EMERGENCY VEHICLE ACCESSNOTE:THE SUBDIVIDER SHALL RELEASE AND RELINQUISH TO THE CITY OF TUSTINALL VEHICULAR ACCESS RIGHTS ALONG ARMSTRONG AVENUE, WARNERAVENUE, VETERANS WAY, AND JOHN JOHNSON WAY, EXCEPT ALL APPROVEDACCESS LOCATIONS AND STREET INTERSECTIONS, AT NO COST TO THE CITY.AREA:GROSS AREA: 267,385 SF (6.14 AC)NET AREA: 263,125 SF (6.04 AC)No.C-621591/23/202695 )L1 ii, t}> I I I I I t I /,' I I I I j I 1 : If, I o o I ' ' ' \ \ \ I r 5 0 0 0 0 0 <1 <1 <1 00000000 Exhibit F Schedule 3 2 City of Tustin/Confluent Development Portion of Disp. Area 8 SCHEDULE 3 Form of Termination of Agreement CITY OF TUSTIN OFFICIAL BUSINESS REQUEST DOCUMENT TO BE RECORDED AND TO BE EXEMPT FROM RECORDING FEES PER GOVERNMENT CODE §6103 AND §27383. RECORDING REQUESTED BY: AND WHEN RECORDED MAIL TO: City Manager The City of Tustin 300 Centennial Way Tustin, California 92780 Space Above This Line Reserved for Recorder’s Use TERMINATION OF ACCESS EASEMENT AGREEMENT [TO BE RECORDED AGAINST THE PORTION OF THE REAL PROPERTY FOR WHICH A CERTIFICATE OF COMPLIANCE HAS BEEN RECORDED AND ONLY IF THE FINAL PARCEL MAP IS THEN RECORDED] THIS TERMINATION OF ACCESS EASEMENT AGREEMENT (“Termination”) is made this ____________ day of_________, 20__, by the City of Tustin (“City”), in favor of _________________, a ___________ (“Developer”). A. On______________, 20__, Developer, or its predecessor-in-interest, and the City recorded as Instrument No. ___________________ that certain Access Easement Agreement (“Agreement”) in the office of the County Clerk Recorder for Orange County, California, Official Records of Orange County, California (“Official Records”). B. Final Parcel Map No. 2025-151 (“Final Parcel Map”) has now been recorded in the Official Records on __________, 20__ as Instrument No. _________ against certain real property including that certain real property legally described on Exhibit A attached hereto (“Parcel”) and a Certificate of Compliance for the Parcel has been executed by the City and recorded in the Official Records, therefore, pursuant to the terms of the Agreement, the City has agreed to execute this Termination in order to release the grant of easements in the Agreement. C. All capitalized terms not otherwise defined herein shall have the meaning given to them in the Agreement. 96 Exhibit F Schedule 3 2 City of Tustin/Confluent Development Portion of Disp. Area 8 NOW THEREFORE, the City and Developer hereby agree as follows: 1. Termination. The provisions of the Agreement are hereby terminated and shall be of no further force or effect. Nothing in this Termination shall modify, affect, terminate or void the dedication of easements or the provision of offers to dedicate established by the Final Parcel Map as to the Parcel. 2. No Other Changes. Except as specifically set forth in this Termination, the terms of the Agreement shall remain unmodified and in full force and effect. Only those provisions of the Agreement specifically terminated herein shall be affected by this Termination. 3. Recordation; Successors and Assigns. This Termination shall be recorded in the Official Records against the Parcel, and is binding on and inures to the benefit of City and Developer, and their respective successors and permitted assigns. 4. Counterparts. This Termination may be signed in counterparts, each of which shall be deemed an original and all of which when taken together shall constitute one instrument. 5. Recitals. The Recitals above are incorporated herein by reference. {signature pages follow} 97 Exhibit F Schedule 3 S-1 City of Tustin/Confluent Development Portion of Disp. Area 8 112047323.3 IN WITNESS WHEREOF, the City and Developer have executed this Termination of Access Easement Agreement on the date first above written. Dated: CITY OF TUSTIN: By: Name: Aldo E. Schindler Title: City Manager ATTEST: By: Erica N. Yasuda City Clerk APPROVED AS TO FORM By: David Kendig City Attorney Hepner & Myers LLP Special Real Estate Counsel to the City By: Amy E. Freilich {signature pages continue on following page} 98 Exhibit F Schedule 3 S-2 City of Tustin/Confluent Development Portion of Disp. Area 8 112047323.3 DEVELOPER: ________________, a ______________ By:________________________ Name: Title: By:________________________ Name: Title: 99 Exhibit F Schedule 3 S-3 City of Tustin/Confluent Development Portion of Disp. Area 8 112047323.3 CALIFORNIA ALL PURPOSE ACKNOWLEDGEMENT A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. State of California County of _________________________________ On _________________ before me, ________________________________________________, Date (Insert Name and Title of the Officer) personally appeared ___________________________________________________________ Name(s) of Signer(s) ____________________________________________________________________________, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Place Notary Seal and/or Stamp above Signature: ______________________________________ Signature of Notary Public 100 } Exhibit F Schedule 3 S-3 City of Tustin/Confluent Development Portion of Disp. Area 8 112047323.3 CALIFORNIA ALL PURPOSE ACKNOWLEDGEMENT A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. State of California County of _________________________________ On _________________ before me, ________________________________________________, Date (Insert Name and Title of the Officer) personally appeared ___________________________________________________________ Name(s) of Signer(s) ____________________________________________________________________________, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Place Notary Seal and/or Stamp above Signature: ______________________________________ Signature of Notary Public 101 } Exhibit F Schedule 3 Exhibit A City of Tustin/Confluent Development Portion of Disp. Area 8 112047323.3 EXHIBIT A LEGAL DESCRIPTION OF PARCEL FOR WHICH CERTIFICATE OF COMPLIANCE WAS RECORDED 102 EXHIBIT G City of Tustin/Confluent Development Development Agreement EXHIBIT G BIOSWALE EASEMENT [Attached] 103 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) 1 City of Tustin/Confluent Development Development Agreement EXHIBIT G BIOSWALE EASEMENT AGREEMENT CITY OF TUSTIN OFFICIAL BUSINESS REQUEST DOCUMENT TO BE RECORDED AND TO BE EXEMPT FROM RECORDING FEES PER GOVERNMENT CODE §6103 AND §27383. RECORDING REQUESTED BY: AND WHEN RECORDED MAIL TO: City Manager The City of Tustin 300 Centennial Way Tustin, California 92780 Space Above This Line Reserved for Recorder’s Use BIOSWALE AND UTILITY EASEMENT AGREEMENT This BIOSWALE AND UTILITY EASEMENT AGREEMENT (this “Agreement”) is made this ____ day of __________, 202_, by and between CD-CW (TUSTIN) LLC, a Colorado limited liability company (“Developer”), and the CITY OF TUSTIN, a California municipal corporation (“City” or “Grantee”). Developer and Grantee are sometimes referred to herein individually as a “Party” and collectively as the “Parties.” RECITALS A. Immediately prior to the recording of this Agreement in the office of the County Clerk-Recorder for Orange County, California (“Official Records”), the City has conveyed to Developer that certain real property legally described on Schedule 1 attached hereto and made a part hereof (“Real Property”), and Developer intends to develop the Real Property with a senior congregate care facility comprised of an active adult residential facility and related improvements and an assisted living and memory care commercial facility and related improvements, together with on-site infrastructure and a complete accompanying set of high quality amenities, as further described in (1) that certain statutory Development Agreement between City and Developer recorded in the Official Records on ____________ as Instrument No. ____________ [{if amended add reference to amendment(s)} (as so amended,] (the “Development Agreement”], and (2) that certain Disposition and Development Agreement for Portion of Disposition Area 8 (Tustin Legacy) between Developer and City dated as of ___________, 20__(“ DDA”) [{if amended add reference to amendment(s)} (as so amended,] “DDA”), a memorandum of which DDA was recorded in the Official Records immediately prior to recording of this Agreement. The DDA 104 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) 2 City of Tustin/Confluent Development Development Agreement contemplates that the City will execute and record in the Official Records one or two certificates of compliance for the Real Property upon the terms set forth therein. Each such certificate of compliance executed by the City and recorded in the Official Records is referred to herein as a “Certificate of Compliance”. B. As partial consideration for the conveyance of the Real Property by the City to Developer, and in connection with the development of the Real Property, Developer has agreed to grant to the City a perpetual easement over the portion of the Real Property described in this Agreement for the construction, operation, maintenance, repair, replacement and use the Bioswale Improvements (defined below), as more fully provided herein. C. Pursuant to the California Subdivision Map Act, the City has approved Tentative Parcel Map No. 2025-151, which is attached to this Agreement for reference as Schedule 2 and incorporated herein by this reference (“Tentative Parcel Map”). The Tentative Parcel Map identifies, under “Proposed Easements,” an area designated as Area “A” for the bioswale and utilities easement contemplated by this Agreement. The legal description and plat of the easement area burdened by this Agreement are attached hereto as Schedule 3 and incorporated herein by this reference. The Tentative Parcel Map, with such additional modifications as may be requested by Developer or required by the City is proposed to be recorded in the Official Records upon approval thereof by the City and Orange County and, following its recording shall be referred to as the “Final Parcel Map”. Developer shall have the right, but not the obligation, to cause recording of the Final Parcel Map. Notwithstanding any subsequent recording in the Official Records of the Final Parcel Map, the easement area as legally described on Schedule 3 shall control the location and extent of the easement granted herein and in the Final Parcel Map and is referred to herein as the “Bioswale Easement Area” and the Final Parcel Map shall reflect the Bioswale Easement Area as legally described in this Agreement. D. This Agreement is intended to preserve and maintain the obligation of Developer and each and every Person owning or acquiring fee title to all or any portion of the Real Property (“Successor Owner”), and each and every Person claiming by, through or under Developer or any Successor Owner, to the terms, covenants, restrictions and obligations set forth in this Agreement. E. The Parties desire to enter into and record this Agreement to grant the City the easement rights necessary for the Bioswale Improvements, to establish the City’s maintenance rights and to burden the Bioswale Easement Area for the benefit of the City and its successors and assigns. NOW, THEREFORE, in consideration of the foregoing recitals, the mutual covenants contained herein and other valuable consideration, the receipt and sufficiency of which are hereby acknowledged, Developer hereby covenants, and Developer and City hereby agree, as follows: 1. Incorporation of Recitals. The Recitals set forth above are true and correct and are incorporated into this Agreement by this reference. 2. Grant of Easement. Developer hereby grants and conveys to the City and its successors and assigns, for the benefit of the City and the City’s municipal stormwater, drainage 105 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) 3 City of Tustin/Confluent Development Development Agreement and water quality system, a perpetual, non-exclusive easement in gross over, under, upon, through and across the Bioswale Easement Area for the purpose of reconstructing, operating, using, inspecting, maintaining, repairing, replacing, improving, modifying and accessing the improvements therein, including all related appurtenances, utilities, inlets, outlets, underdrains, pipes, structures, filtration media, planting materials, irrigation, erosion control measures, and surface and subsurface drainage and water quality facilities (collectively, “Bioswale Improvements”), together with all rights reasonably necessary for the full exercise of the rights granted herein. 3. Description of Bioswale Easement Area. The Bioswale Easement Area is legally described and depicted on Schedule 3 attached hereto and incorporated herein by this reference. . 4. Priority. The easement rights granted to the City under this Agreement shall have priority over the lien and charge of any mortgage, deed of trust, construction deed of trust, mechanic’s lien, assessment lien, judgment lien or other lien or encumbrance recorded against the Real Property after the recordation of this Agreement. Developer shall not grant, create, permit or suffer any lien, encumbrance, easement, license, covenant or other right that would interfere with, impair, subordinate, extinguish or otherwise adversely affect the rights granted to the City under this Agreement without the City’s prior written consent, which may be withheld in the City’s sole discretion. 5. Construction Access. Developer hereby grants to the City and its officers, employees, agents, representatives, consultants, contractors, subcontractors, successors and assigns the right to enter the Bioswale Easement Area and such portions of the Real Property immediately adjacent thereto as are reasonably necessary to exercise the City’s rights under this Agreement. 6. City’s Rights Under Easement City shall have the right to use the Bioswale Easement Area and adjoining portions of the Real Property reasonably necessary for access, and to construct, install, reconstruct, operate, use, inspect, maintain, repair, replace, improve, modify, remove and access the Bioswale Improvements as provided in Sections 2 and 5 above. Except in an emergency, the City shall use reasonable efforts to provide prior notice to Developer before entering portions of the Real Property outside the Bioswale Easement Area. The City’s use of any area outside the Bioswale Easement Area shall be limited to the area reasonably necessary to exercise the City’s rights and shall be conducted in a manner intended to minimize unreasonable interference with Developer’s use of the Real Property. 7. Restoration by City. If the City disturbs portions of the Real Property outside the Bioswale Easement Area in the course of exercising its rights under this Agreement, the City shall restore the disturbed area as nearly as reasonably practicable to the condition existing immediately before the City’s work. The City shall have no obligation to restore the Bioswale Easement Area in a manner inconsistent with the design, operation, maintenance, repair or replacement of the Bioswale Improvements. 8. Developer’s Rights and Restrictions. Developer reserves all rights in the Bioswale Easement Area and the Real Property that may be used and enjoyed without interfering with, 106 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) 4 City of Tustin/Confluent Development Development Agreement impairing or increasing the cost or burden of the rights granted to the City under this Agreement in any meaningful respect. Developer shall not use, or permit the use of, the Bioswale Easement Area in any manner that interferes with the construction, operation, use, inspection, maintenance, repair, replacement, improvement, modification, removal or access of the Bioswale Improvements. Developer shall not, without the City’s prior written consent in its sole discretion, construct, install, place, maintain or permit any building, wall, fence, footing, foundation, retaining wall, pavement, hardscape, utility, tree, deep-rooted vegetation, sign, lighting, grading, fill, excavation, drainage facility, private stormwater facility, encroachment or other structure, improvement or condition within the Bioswale Easement Area or elsewhere on the Real Property that will interfere with, damage, obstruct, impair access to, alter drainage to or from, or increase the City’s cost to operate, inspect, maintain, repair, replace or remove the Bioswale Improvements in any meaningful respect. Developer shall not alter the grade, drainage pattern, tributary area, inflow, outflow, water quality function, filtration function, planting palette, soil media, underdrain, inlet, outlet, overflow structure or other component of the Bioswale Improvements without the City’s prior written consent in its sole discretion. Developer shall promptly remove, at Developer’s sole cost and expense, any encroachment or condition that violates this Agreement. If Developer fails to do so within the time reasonably specified by the City, or immediately in an emergency, the City may remove the encroachment or condition and Developer shall reimburse the City for all costs incurred. 9. City Indemnity. The City shall indemnify and hold harmless Developer and its successors and assigns owning all or any portion of the Real Property from and against third party claims for bodily injury or property damage to the extent caused by the City’s active negligence or willful misconduct in the City’s exercise of its rights under this Agreement. The foregoing indemnity shall not apply to the extent of injury or damage caused by Developer or any person acting by, through or under Developer. 10. Covenants Running with the Land. This Agreement, the easement rights granted herein and the covenants, restrictions and obligations imposed herein shall be perpetual, shall constitute equitable servitudes and covenants running with the land, shall burden the Real Property and each portion thereof, and shall be binding upon Developer and each and every person or entity owning or acquiring fee title to all or any portion of the Real Property, and each and every person or entity claiming by, through or under Developer or any such successor owner, for the benefit of the City and its successors and assigns. 11. Successors; Assignment. The City may assign its rights under this Agreement to any successor public agency or other governmental entity responsible for the City’s municipal stormwater, drainage or water quality system. Developer’s obligations under this Agreement shall automatically bind Developer’s successors and assigns owning all or any portion of the Real Property. No transfer of the Real Property or any portion thereof shall release Developer from obligations that accrued before the effective date of the transfer, and no transfer shall release any successor owner from obligations arising during its period of ownership. 12. Enforcement; Remedies. The City shall have the right to enforce this Agreement by any proceeding at law or in equity, including specific performance, injunctive relief, actual damages (but specifically excluding consequential, punitive or special damages), recovery of costs 107 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) 5 City of Tustin/Confluent Development Development Agreement and any other remedy available under this Agreement or applicable law. The rights and remedies of the City are cumulative and not exclusive. No delay or failure by the City to exercise any right or remedy shall constitute a waiver of that right or remedy. In the event of a breach of any provision of this Agreement, City may demand by written notice (“Default Notice”) that the violation be cured. Except for utility service interruptions or similar emergencies which shall not require advance notice or cure periods hereunder, if Developer does not cure the violation within thirty (30) days after receipt of the Default Notice, or if such default is of a kind which cannot reasonably be cured within thirty (30) days, and Developer does not within such thirty (30) day period commence to cure such default and diligently thereafter prosecute such cure to completion, then City shall have the right, but not the obligation, to (i) institute legal action against Developer for specific performance, injunction, declaratory relief, actual damages (but specifically excluding consequential, punitive or special damages), or any other remedy provided by law, (ii) pay any sum owed by Developer to the party entitled to such payment and/or (iii) enter upon the Bioswale Easement Area and to summarily abate, remove or otherwise remedy any improvement, and/or repair or modify any improvement which violates the terms of this Agreement and/or perform any obligation of Developer under this Agreement to be performed thereon. Developer shall pay to the City, within thirty (30) calendar days of written demand by City (which demand is accompanied by appropriate supporting documentation), an amount equal to all reasonable costs and expenses incurred by City in undertaking any of the actions permitted by the preceding sentence, including without limitation, third party costs and City hourly wages and benefits reasonably allocable to the time expended by City in taking such actions, and if not paid within such thirty (30) calendar day period, together with interest thereon at the rate equal eight percent (8%) per annum, from the date such costs and expenses were advanced or incurred by the City until paid. The rights and remedies given to City by this Agreement shall be deemed to be cumulative and no one of such rights and remedies shall be exclusive of any of the others, or of any other right or remedy at law or in equity which City might otherwise have by virtue of a default under this Agreement, and the exercise of one such right or remedy by any City shall not impair the City’s standing to exercise any other right or remedy. Notwithstanding any limitation or exclusion of consequential, punitive, exemplary, or special damages in this Agreement, such limitation or exclusion shall not limit or impair City’s right to seek specific performance, injunctive relief, recovery of actual out-of-pocket costs, costs of repair or restoration, costs incurred in exercising self-help or enforcement rights, indemnity obligations, or any other amounts expressly payable or recoverable under this Agreement. 13. Notices. All notices required or permitted under this Agreement shall be in writing and shall be delivered by personal delivery, reputable overnight courier, or certified mail, return receipt requested, postage prepaid, addressed to the Parties at the addresses set forth below, or to such other address as a Party may designate by written notice given in accordance with this Section. Notice shall be deemed given upon personal delivery, one (1) business day after deposit with an overnight courier, or three (3) business days after deposit in the United States mail. If to City: City of Tustin 300 Centennial Way Tustin, California 92780 Attn: City Manager 108 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) 6 City of Tustin/Confluent Development Development Agreement With a copy to: City of Tustin 300 Centennial Way Tustin, California 92780 Attn: City Attorney If to Developer: CD-CW (TUSTIN) LLC ____________________________ ____________________________ Attn: _______________________ With a copy to: ____________________________ ____________________________ Attn: _______________________ 14. Attorneys’ Fees. If any action or proceeding is commenced to enforce or interpret this Agreement, the prevailing Party shall be entitled to recover its reasonable attorneys’ fees, expert witness fees, consultant fees, costs and expenses from the non-prevailing Party. 15. Governing Law; Venue. This Agreement shall be governed by and construed in accordance with the laws of the State of California. Venue for any action or proceeding arising out of or relating to this Agreement shall be in the Superior Court of the State of California for the County of Orange. 16. Severability. If any provision of this Agreement is determined by a court of competent jurisdiction to be invalid or unenforceable, the remaining provisions of this Agreement shall remain in full force and effect to the maximum extent permitted by law. 17. Amendment; Termination. This Agreement may be amended or terminated only by a written instrument executed by the City and the then-owner of the portion of the Real Property burdened by the Bioswale Easement Area and recorded in the Official Records. The City may execute any amendment or termination in its governmental capacity and no amendment or termination shall be effective until recorded in the Official Records. 18. Estoppel Certificate. Each Party hereby covenants that within twenty (20) business days of the written request of any other Party it will issue to such other Party an Estoppel Certificate stating: (a) whether the Party to whom the request has been directed knows of any default under this Agreement and if there are known defaults specifying the nature thereof; (b) whether to its knowledge this Agreement has been assigned, modified, or amended in any way (and if it has, then stating the nature thereof); and (3) whether to the Party’s knowledge this Agreement is as of that 109 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) 7 City of Tustin/Confluent Development Development Agreement date is in full force and effect. In no event shall an estoppel certificate be requested more often than two times per year. 19. Excuse for Non-Performance. Each Party shall be excused from performing any obligation or undertaking provided in this Agreement except any obligation to pay any sum of money under the applicable provisions hereof, in the event and so long as the performance of any such obligation is prevented or delayed, retarded, or hindered by act of God, fire, earthquake, floods, explosion, actions of the elements, war, invasion, insurrection, riot, mob violence, sabotage, inability to procure or general shortage of labor, equipment, facilities, materials, or supplies in the ordinary course on the open market; failure of normal transportation strikes, lockouts, action of labor unions, condemnation, requisition, laws, orders of governmental or civil or military authorities. 20. Effect on Third Parties. Except as herein specifically provided, no rights, privileges or immunities conferred upon the Parties to this Agreement shall inure to the benefit of any homeowner nor shall any person be deemed to be a third-party beneficiary of any of the provisions contained herein. 21. Entire Agreement. This Agreement constitutes the entire agreement between the Parties hereto pertaining to the subject matter hereof, and the final, complete and exclusive expression of the terms and conditions thereof. Prior agreements, representations, negotiations, and understandings of the Parties hereto, oral or written, express or implied, are hereby superseded and merged herein. 22. Recording. This Agreement shall be recorded in the Official Records against the Real Property. 23. Counterparts. This Agreement may be executed in counterparts, each of which shall be deemed an original and all of which, when taken together, shall constitute one instrument. 24. Authority. Each person executing this Agreement on behalf of a Party represents and warrants that such person has full power and authority to execute this Agreement and to bind the Party on whose behalf such person executes this Agreement. 25. References to Sections, Clauses, Schedules and Exhibits. Unless otherwise indicated, references in this Agreement to sections, clauses, schedules, and exhibits are to the same contained in or attached to this Agreement and all exhibits and schedules referenced in this Agreement are incorporated in this Agreement by this reference as though fully set forth in this Section. [Signature pages follow.] 110 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) S-1 City of Tustin/Confluent Development Development Agreement IN WITNESS WHEREOF, Developer and City have executed this Bioswale Easement Agreement as of the date first written above. CITY: CITY OF TUSTIN, a California municipal corporation By: ______________________________ Name: Aldo E. Schindler Title: City Manager ATTEST: By: ______________________________ Erica N. Yasuda, City Clerk APPROVED AS TO FORM: By: ______________________________ David E. Kendig, City Attorney Hepner & Myers LLP Special Real Estate Counsel to the City By: ______________________________ Amy E. Freilich DEVELOPER: CD-CW (TUSTIN) LLC, a Colorado limited liability company By: ______________________________ Name: ____________________________ Title: _____________________________ 111 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) S-2 City of Tustin/Confluent Development Development Agreement CERTIFICATE OF ACCEPTANCE OF EASEMENT (City of Tustin) This is to certify that the interest in real property conveyed by the BIOSWALE EASEMENT AGREEMENT dated ____________, 202_ from CD-CW (TUSTIN) LLC, a Colorado limited liability company, to the CITY OF TUSTIN, a California municipal corporation and governmental agency, is hereby accepted by the undersigned officer on behalf of the CITY OF TUSTIN pursuant to authority conferred by Resolution No. 95-39 of the CITY OF TUSTIN adopted on April 3, 1995, and the grantee consents to recordation thereof by its duly authorized officer. Dated: ____________________ ______________________________ Erica N. Yasuda, City Clerk 112 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) S-3 City of Tustin/Confluent Development Development Agreement CALIFORNIA ALL PURPOSE ACKNOWLEDGEMENT A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. State of California County of _________________________________ On _________________ before me, ________________________________________________, Date (Insert Name and Title of the Officer) personally appeared ___________________________________________________________ Name(s) of Signer(s) ____________________________________________________________________________, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Place Notary Seal and/or Stamp above Signature: ______________________________________ Signature of Notary Public 113 } Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) S-4 City of Tustin/Confluent Development Development Agreement STATE OF COLORADO ) CITY AND ) SS: COUNTY OF DENVER ) The foregoing instrument was acknowledged before me this ____ day of July, 2026, by Marshall M. Burton, as Chief Executive Officer of Confluent Development, LLC, a Colorado limited liability company, as Manager of CD Manager LLC, a Colorado limited liability company, as Manager of CD-CW (Tustin) LLC, a Colorado limited liability company. WITNESS my hand and official seal. Notary Public My Commission Expires: [SEAL] 114 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) Schedule 1 City of Tustin/Confluent Development Development Agreement SCHEDULE 1 Legal Description of Real Property The Land referred to herein below is situated in the City of Tustin, County of Orange, State of California, and is described as follows: LOT 14, INCLUSIVE OF TRACT NO. 18197 AS SHOWN ON A MAP FILED IN BOOK 990, PAGES 25 THROUGH 33, INCLUSIVE OF TRACT MAPS, RECORDS OF ORANGE COUNTY, CALIFORNIA. Excluding therefrom the rights and interests reserved by the City in Section 2 of the Quitclaim Deed for the Real Property made by the City in favor of Developer recorded immediately prior to recording of this Agreement. For conveyancing purposes only: APN 430-481-12 115 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) Schedule 2 City of Tustin/Confluent Development Development Agreement SCHEDULE 2 Tentative Parcel Map No. 2025-151 [Proposed Easements Area “A” identifies the Bioswale Easement Area.] 116 EEEE E E E E E E E E E E E E E EEEE E E E E E E E E E E E E E E E E E EEESL SL SL SL '''',6,6,6,6,6,6,6,6,6''',6,6,6,6,6,6,6,6,6',6,6,6,6,6,6,6,6''''STSTSTSTSLSLEEEEEEEEEEEEEEEEESTSTSTSTSTSTSTSTSTDSSSSRWRPBPBRWRWARNER AVEJOHN JOHNSON WAY7(37.55' R1)37.55'641N17°00'00".E 432.38' (432.38' R1)L=112.35')(L=603.35' R1)L=603.35'N 64°05'52" W 280.62' (280.62' R1)ǻ=16°06'48"(ǻ=16°06'56" R1)TELEPHONE PULL BOX (NE COR3.0' SW'LY OF PLELECTRIC PULL BOX (NE COR)2.8' SW'LY OF PLTV PULL BOX (NE COR)3.3' SW'LY OF PLTELEPHONE VAULT (NE COR2.0' SW'LY OF PLWALL (NE COR END)1.2' SW'LY OF PLELECTRIC PULL BOX (SE COR)6.5' NE'LY OF PLCULVERT BOX (SW COR)2.4' NE'LY OF PLIRRIGATION BOX (SE COR)5.7' NE'LY OF PLWALL (N'LY FACE)0.1' SW'LY OF PLWALL (N'LY FACE)CROSSING PLWALL (NW COR END)8.4' NE'LY OF PLIRRIGATION CONTROL BOX(NE COR) 3.2' NW'LY OF PLSEWER MAN HOLE (CENTER)4.0' SE'LY OF PLPROPERTY LINE& RIGHT OF WAYPROPERTY LINE & RIGHT OF WAYDIRTSIDEWALK (BACK)0.1' NE'LY OF PLSIDEWALK (BACK)0.1' NE'LY OF PL2ARMSTRONG AVEPROPOSED5-STORY ACTIVE ADULTBUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.47PROPOSED2-STORY ASSISTED LIVING& MEMORY CARE BUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.80EX 12" DWEX 72" SDEX 15" SSC/LC/LC/LC/LL=23.37', R=15.00'N23°14'34"EL=59.44'EXISTING 36" SDEX. 36" SDEX 10" SSEX 10" DWEX. 8" SSEX. 10" WAEX RWEX ELECEX 24" SDEX 10" WAEX 8" SS(NOT A PART)(NOT APART)L=47.60',R =20.00'37.02' N 20°5 4' 1 7 " W6065 7075565758596162636466676869717273747677555453555453515556575859 L=107.44',R=311.66'S64°38'16"EL=6.95'N25°54'08"EL=126.17'L=303.67'(L=303.67' R1)L=308.03'(L=308.03' R1)(R=1982.00' R1)R=1982.00'(R=1954.00' R1)R=1954.00'N 64°05'52" W 201.98' (201.98' R1)(ǻ=8°54'16" R1)ǻ=8°54'16"ǻ=8°54'16"(ǻ=8°54'16" R1)ǻ=5°48'14"R=1470.00'(R=1470.00' R1)(ǻ=5°48'14" R1)L=148.91'(L=148.91' R1)(ǻ=20°05'37" R1)ǻ=20°05'40"R=1400.00'(R=1400.00' R1)ǻ=4°35'52"(L=112.37' R1)(ǻ=4°35'55" R1)(ǻ=24°41'32" R1)ǻ=24°41'32"(302.17' R1)302.17'N 75°31'01" W(L=96.90' R1)(R=1460.00' R1)ǻ=3°48'10"29"W50.00'(50.00' R1)(114.22' R1)N39°10'31" E 114.22'(ǻ=12°32'28" R1)ǻ=12°32'28"R=1348.04'(R=1348.04' R1)L=295.06'(L=295.06' R1)55.000535354545954PROPOSED LOT LINEPROPOSED LOT LINEPROPOSED (PRIVATE)MODULAR WETLANDSTORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED(PRIVATE) 8" SEWERPROPOSED (PRIVATE) 6" FIREWATER AND BACKFLOW PREVENTERPROPOSED (PRIVATE)6" FIRE WATERPROPOSED (PRIVATE)OLDCASTLE STORMCAPTUREPROPOSED (PRIVATE) 4" DOMESTICWATER AND BACKFLOW PREVENTERPROPOSED(PRIVATE) 8" SEWERPROPOSED (PRIVATE)48" STORM DRAINDEMOLISH PORTION OFEXISTING STORM DRAINLATERAL AND CATCH BASINPROPOSED (PRIVATE)8" SEWER20.9'23.7'15.9'11.6'15.9'70.4'50.3'12.8'42.7'35.0'70.1'25.3'46.1'24.6'22.7'25.7'11.8'15.4'27' DRIVEWAY17.2'14.2'27' DRIVEWAY20.0'20.0'PARCEL 1121,531 SF (2.79 AC)PARCEL 2145,854 SF (3.35 AC)314P/LP/LP/LPROPOSED (PRIVATE)48" STORM DRAINN25°54'08"EL=83.62'PROPOSED (PRIVATE)48" STORM DRAINPROPOSED(PRIVATE)8" SEWERP/LN 25°58'17" W 38.45'(38.45' R1)P/LPROPOSED (PRIVATE)6" FIRE WATERPROPOSED (PRIVATE)6" DOMESTIC WATERPROPOSED (PRIVATE)48" STORM DRAINBBBBBAA(37.0 2' R 1 )3N 39°10'31" E 205.21'(205.21' R1)(ǻ=14°45'07" R1)ǻ=14°45'07"ǻ=32°59'59"(ǻ=32°59'59" R1)R=1400.04'(R=1400.04' R1)(L=360.47' R1)L=360.47'1914L=806.36'(L=806.36' R1)(L=393.79' R1)L=393.73'19P/L234.24'(234.24' R1)N 73°00'08" W206.24'(206.24' R1)N 73°00'08" W5.0'(NOT APART)VETERANS WAY51(ǻ=3°48'10" R1)PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE6.0'REMOVE PORTION OF EXISTINGSTORM DRAIN LATERAL ANDCATCH BASIN; CAP STORMDRAIN AT PROPERTY LINEPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)48" STORM DRAINCAP EXISTING STORMDRAIN CONNECTORPIPE AT PROPERTYLINE1L=96.90'R=1460.00'19PROPCBPROPCBPROPCBPROPCBPROPCBPROPCBPROPCBTRACT 17144APN: 430-272-12TRACT 18197APN: 430-481-1519TRACT 18197APN: 430-481-24N17°00'00"E 133.00' (133.00' R1)N 13°56'50" EN 17°00'00" E 138.72' (138.72' R1)3256575857585959565758585959565657575555545555545656PROPOSED (PRIVATE)OLDCASTLE STORMCAPTUREǻ=10°42'21"R=170.77'(L=31.91')(R=170.77')(R1)(ǻ=10°42'21")L=31.91'76L=26.48'(ǻ=07°43'15")(R1)(R=196.48')(L=26.48')R=196.48'ǻ=07°43'15"ǻ=13°06'14"R=41.00'(L=9.38')(R=41.00')(R1)(ǻ=13°06'14")L=9.38'54L=15.91'(ǻ=15°27'12")(R1)(R=59.00')(L=15.91')R=59.00'ǻ=15°27'12"ǻ=02°21'00"R=1472.00'(L=60.37')(R=1472.00')(R1)(ǻ=02°21'00")L=60.37'3DELTAǻ=14°11'50"CURVE1LENGTHL=10.16'RADIUSR=41.00'(L=10.16')LENGTHRADIUS(R=41.00')RECORD(R1)DELTA(ǻ=14°11'50")2L=14.78'(ǻ=14°20'59")(R1)(R=59.00')(L=14.78')R=59.00'ǻ=14°20'59"(R1) (N85°15'23"E)(0.11')0.11'N85°15'23"EN38°14'17"E4.92' (4.92')(N38°14'17"E)(R1)(R1) (N85°15'26"E)(37.48')37.48'N85°15'26"EN51°45'31"W32.83' (32.83')(N51°45'31"W)(R1)(36.45')(N36°37'39"W)1LINEDISTANCEBEARINGN36°37'39"W36.45'RECORD BEARING DISTANCE(R1)(R1) (N68°46'50"W)(36.20')36.20'N68°46'50"W23456RWEEEE E E E E E E E E E EEEE E E E E E E E E E E E E E E E E E E E ': ': ':':':':':':':':':':':':':'''',6,6,6,6,6,6,6,6,6'''',6,6,6,6,6,6,6,6,6,6' ' ' ' ',6,6,6,6,6,6,6,6':':': ':':':':':':':':':''''',6,6,6,6,6,6,6,6,6'',6 ,6 ,6 ,6 6'.6'.6'.6'.6'.6'.6'. 6'.6'.6'.STSTSTSTSLCCCEEEEEEEEEEEESTSTSTSTSDSSSSSSRWRPBPBPBRWRWARNER Y157(37.55' R1)37.55'641N17°00'00".E 432.38' (432.38' R1)(L=490.98' R1)L=491.00'(L=603.35' R1)N50°49'29"W 185.10' (185.10' R1)L=603.35'N 64°05'52" W 280.62' (280.62' R1)TELEPHONE PULL BOX (NE COR)3.0' SW'LY OF PLELECTRIC PULL BOX (NE COR)2.8' SW'LY OF PLTV PULL BOX (NE COR)3.3' SW'LY OF PLTELEPHONE VAULT (NE COR)2.0' SW'LY OF PLWALL (NE COR END)1.2' SW'LY OF PLELECTRIC PULL BOX (SE COR)6.5' NE'LY OF PLCULVERT BOX (SW COR)2.4' NE'LY OF PLIRRIGATION BOX (SE COR)5.7' NE'LY OF PLWALL (N'LY FACE)0.1' SW'LY OF PLWALL (N'LY FACE)CROSSING PLWALL (NW COR END)8.4' NE'LY OF PLELECTRIC MANHOLE (CENTER)3.2' SW'LY OF PLIRRIGATION CONTROL BOX(NE COR) 3.2' NW'LY OF PLSEWER MAN HOLE (CENTER)4.0' SE'LY OF PLPROPERTY LINE& RIGHT OF WAYPROPERTY LINE & RIGHT OF WAYDIRTN46°41'40"W1853.44'(GPS TIE)SIDEWALK (BACK)0.1' NE'LY OF PLSIDEWALK (BACK)0.1' NE'LY OF PLSIDEWALK (BACK)AT PL1211ARMSTRONG AVEPROPOSED5-STORY ACTIVE ADULTBUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.47PROPOSED2-STORY ASSISTED LIVING& MEMORY CARE BUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.80EX 12" DWEX 36" SDEX 72" SDEX 15" SSC/LC/LC/LC/LL=23.37', R=15.00'N23°14'34"EL=59.44'EXISTING 36" SDEX. 36" SDEX 10" SSEX 10" DWEX. 8" SSEX RWEX ELECEX RWEX 24" SDEX 10" WAEX 8" SS(NOT APART)L=47.60',R =20.00'37.02' N 20°5 4' 1 7 " W6065 7075565758596162636466676869717273747677555453555453515556575859 L=107.44',R=311.66'S64°38'16"EL=6.95'N25°54'08"EL=126.17'L=303.67'(L=303.67' R1)L=308 03'(R=1954.00' R1)R=1954.00'N 64°05'52" W 201.98' (201.98' R1)(ǻ=8°54'16" R1)ǻ=8°54'16"ǻ=5°48'14"R=1470.00'(R=1470.00' R1)(ǻ=5°48'14" R1)L=148.91'(L=148.91' R1)(ǻ=20°05'37" R1)ǻ=20°05'40"R=1400.00'(R=1400.00' R1)(L=(ǻ=(ǻ=24°41'32" R1)ǻ=24°41'32"(L=96.90' R1)(R=1460.00' R1)ǻ=3°48'10"N50°49'29"W50.00'(50.00' R1)(114.22' R1)N39°10'31" E 114.22'(ǻ=12°32'28" R1)ǻ=12°32'28"R=1348.04'(R=1348.04' R1)L=295.06'(L=295.06' R1)55.000535354545954PROPOSED LOT LINEPROPOSED LOT LINEPROPOSED (PRIVATE)MODULAR WETLANDSTORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED (PRIVATE)48" STORM DRAINPROPOSED(PRIVATE) 8" SEWERPROPOSED (PRIVATE) 6" FIREWATER AND BACKFLOW PREVENTERPROPOSED (PRIVATE)6" FIRE WATERPROPOSED (PRIVATE)OLDCASTLE STORMCAPTUREPROPOSED (PRIVATE) 4" DOMESTICWATER AND BACKFLOW PREVENTERPROPOSED(PRIVATE) 8" SEWERPROPOSED (PRIVATE)48" STORM DRAINDEMOLISH PORTION OFEXISTING STORM DRAINLATERAL AND CATCH BASINPROPOSED (PRIVATE)8" SEWER20.9'23.7'15.9'11.6'15.9'70.4'50.3'12.8'42.7'35.0'70.1'25.3'46.1'24.6'22.7'25.7'11.8'15.4'27' DRIVEWAY17.2'14.2'27' DRIVEWAY20.0'20.0'PARCEL 1121,531 SF (2.79 AC)PARCEL 2145,854 SF (3.35 AC)3164P/LP/LP/LPROPOSED (PRIVATE)48" STORM DRAINN25°54'08"EL=83.62'PROPOSED (PRIVATE)48" STORM DRAINPROPOSED(PRIVATE)8" SEWERP/LN 25°58'17" W 38.45'(38.45' R1)P/LPROPOSED (PRIVATE)6" FIRE WATERPROPOSED (PRIVATE)6" DOMESTIC WATERPROPOSED (PRIVATE)48" STORM DRAINBBBBBAA(37.0 2' R 1 )3N 39°10'31" E 205.21'(205.21' R1)(ǻ=14°45'07" R1)ǻ=14°45'07"ǻ=32°59'59"(ǻ=32°59'59" R1)R=1400.04'(R=1400.04' R1)(L=360.47' R1)L=360.47'1914L=806.36'(L=806.36' R1)93.79' R1)=393.73'EX 6" RW19P/L234.24'(234.24' R1)N 73°00'08" W206.24'(206.24' R1)N 73°00'08" W5.0'VETERANS WAY51(ǻ=3°48'10" R1)PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE6.0'REMOVE PORTION OF EXISTINGSTORM DRAIN LATERAL ANDCATCH BASIN; CAP STORMDRAIN AT PROPERTY LINEPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTUREPROPOSED (PRIVATE)48" STORM DRAINCAP EXISTING STORMDRAIN CONNECTORPIPE AT PROPERTYLINE1L=96.90'R=1460.00'19PROPCBPROPCBPROPCBPROPCBPROPCBPROPCBPROPCBTRACT 17144APN: 430-272-12(NOT APART)TRACT 17404APN: 430-371-20N17°00'00"E 133.00' (133.00' R1)N 13°56'50" EN 17°00'00" E 138.72' (138.72' R1)3256575857585959565758585959565657575555545555545656PROPOSED (PRIVATE)OLDCASTLE STORMCAPTURETENTATIVE PARCEL MAP 2025-151PROJECT NO.DRAWN BY: JTKADESIGNED BY: JITDATE:REVIEWED BY:DATENO. REVISIONCKBYSHEET NO.CHECKED BY: JITSave Date: Plot Date: 1/19/2026 4:04 PM1/19/2026 4:25 PMBy: Rxka P:\C\CONFCDMS0012\0400CAD\SHEETS\EC\Entitlements\Tentative Parcel Map\EC-001-CV-CONFCDMS0012-TPM.dwgRobyn KathermanBy: File:®CONFCDMS-0013CLEARWATER AT TUSTIN LEGACYTENTATIVE PARCEL MAP 2025-151LOT 14, TRACT NO. 18197, M.M. 990/25-33TUSTIN, CA 9260617542 17th St., Suite 150Tustin, CA, 92780Phone: 714.665.4500OWNER:CITY OF TUSTIN,300 CENTENNIAL WAYTUSTIN, CA 92780ATTN:PROJECT ADDRESS:LOT 14, TRACT NO. 18197, M.M. 990/25-33TUSTIN, CA 92606CIVIL ENGINEER:DAVID EVANS AND ASSOCIATES, INC.25152 SPRINGFIELD COURT, SUITE 350SANTA CLARITA, CA 91355ATTN: JONATHAN TAPIAPHONE 661.284.7436E-MAIL: JTAPIA@DEAINC.COMARCHITECT:HPI ARCHITECTURE115 22ND STREETNEWPORT BEACH, CA 92663PHONE: 949.675.6442BASIS OF BEARINGS:THE BEARING SHOWN HEREON ARE BASED ON THE CALCULATED BEARINGBETWEEN O.C.S. HORIZONTAL CONTROL STATION GPS NO. 6529 AND GPS NO.6535 BEING NORTH 03° 46' 13" WEST PER RECORDS ON FILE IN THE OFFICE OFTHE ORANGE COUNTY SURVEYOR.BENCHMARK:THE ELEVATIONS SHOWN HEREON ARE BASED UPON THE ORANGE COUNTYPUBLIC WORKS VERTICAL CONTROL DATA SHEET BENCHMARK NO. 3A-107-77,(YEAR 2013).3 3/4" OCS ALUMINUM BENCHMARK DISK STAMPED "3A-107-77" IN THEWESTERLY CORNER OF A 4 FT BY 11 FT CONCRETE CATCH BASIN.MONUMENT IS LOCATED IN THE NORTHERLY CORNER OF THE INTERSECTIONOF REDHILL AVENUE AND WARNER AVENUE, 47 FT NORTHEASTERLY OF THECENTERLINE MEDIAN ALONG WARNER AND 105 FT NORTHWESTERLY OF THECENTERLINE OF REDHILL AVENUE. MONUMENT IS LEVEL WITH THE SIDEWALK.ELEVATION = 62.047'CONTOURS SHOWN HEREON ARE 1' INTERVAL.BOUNDARY/PARCEL LINEPROPOSED PARCEL LINEEASEMENTEXISTING UTILITIESLEGENDEXISTING R/W55DYER RDBARRANCA PKWYRED HILL AVEEDINGER AVEEDINGER AVETUSTIN RANCH RDVON KARMAAVEWARNER AVEARMSTRONG AVEVETERANSWAY261WARNER AVESAN DIEGOFRWYJAMBOREE RDCOSTA MESA FRWYSANTA ANA FRWYEASTERNTRANSPORTATIONCORRIDORR1.....INDICATES DATA PER TRACT NO. 18197, M.B. 990/25-33R2.....INDICATES DATA PER TRACT NO. 17144, M.B. 906/5-14( )INDICATES RECORD DATA.INDICATES REFERENCE RECORD DATA.R1INDICATES DESCRIPTION NUMBER.1MONUMENT NOTES:LEGAL DESCRIPTION: INDICATES FOUND MONUMENT, AS NOTED.THE LAND REFERRED TO HEREIN BELOW IS SITUATED IN THE CITY OF TUSTIN, COUNTY OF ORANGE, STATEOF CALIFORNIA, AND IS DESCRIBED AS FOLLOWS:LOT 14, INCLUSIVE OF TRACT NO. 18197 AS SHOWN ON A MAP FILED IN BOOK 990, PAGES 25 THROUGH 33,INCLUSIVE OF TRACT MAPS, RECORDS OF ORANGE COUNTY, CALIFORNIA.EXCEPTING THEREFROM ANY AND OIL, OIL RIGHTS, MINERALS, MINERAL RIGHTS, NATURAL GAS RIGHTSAND OTHER HYDROCABONS BY WHATSOEVER NAME KNOWN, GEOTHERMAL STEAM AND ALL PRODUCTSDERIVED FROM ANY OF THE FOREGOING, THAT MAY BE WITHIN OR UNDER THE LAND, TOGETHER WITH THEPERPETUAL RIGHT OF DRILLING, MINING, EXPLORING FOR AND STORING IN AND REMOVING THE SAMEFROM THE LAND OR ANY OTHER LAND, INCLUDING THE RIGHT TO WHIPSTOCK OR DIRECTIONALLY DRILLAND MINE FROM LANDS OTHER THAT THE LAND, OIL OR GAS WELLS, TUNNELS AND SHAFTS INTO, THROUGHOR ACROSS THE SUBSURFACE OF THE LAND AND TO BOTTOM SUCH WHIPSTOCKED OR DIRECTIONALLYDRILLED WELLS, TUNNELS AND SHAFTS UNDER AND BENEATH OR BEYOND THE EXTERIOR LIMITS THEREOF,AND TO REDRILL, RETUNNEL, EQUIP, MAINTAIN, REPAIR, DEEPEN AND OPERATED ANY SUCH WELL ORMINES; BUT WITHOUT, HOWEVER, THE RIGHT TO DRILL, MINE, STORE, EXPLORE OR OPERATE THROUGH THESURFACE OF THE LAND, AS RESERVED IN THE DEED FROM THE CITY OF TUSTIN, CALIFORNIA, RECORDEDSEPTEMBER 24, 2002 AS INSTRUMENT NO. 20020819173 OF OFFICIAL RECORDS.ALSO EXCEPTING THEREFROM ANY AND ALL WATER, WATER RIGHTS OR INTERESTS THEREINAPPURTENANT OR RELATING TO THE LAND OR OWNED OR USED BY THE GRANTOR IN CONNECTION WITHOR WITH RESPECT TO THE LAND (NO MATTER HOW ACQUIRED BY THE GRANTOR), WHETHER SUCH RIGHTSSHALL BE RIPARIAN, OVERLYING, APPROPRIATIVE, LITTORAL, PERCOLATING, ADJUDICATED, STATUTORY ORCONTRACTUAL, TOGETHER WITH THE PERPETUAL RIGHT AND POWER TO EXPLORE, DRILL, REDRILL ANDREMOVE THE SAME FROM OR IN THE LAND, TO STORE THE SAME BENEATH THE SURFACE OF THE LANDAND TO DIVERT OR OTHERWISE UTILIZE SUCH WATER, RIGHTS OR INTERESTS ON ANY OTHER PROPERTYOWNED OR LEASE BY GRANTOR; BUT WITHOUT, HOWEVER, ANY RIGHT TO ENTER UPON OR USE THESURFACE OF THE LAND IN THE EXERCISE OF SUCH RIGHTS, AS RESERVED IN THE DEED FROM THE CITY OFTUSTIN, CALIFORNIA, RECORDED SEPTEMBER 24, 2002 AS INSTRUMENT NO.20020819173 OF OFFICIAL RECORDS.FOR CONVEYANCING PURPOSES ONLY: APN 430-481-12INDICATES CALCULATED FROMCFFOUND SPIKE & WASHER STAMPED "LS 6673" PER R1, FLUSH; ACCEPTED AS ARMSTRONG AVENUE& WARNER AVENUE CENTERLINE INTERSECTION PER R1.1PER FIRST AMERICAN TITLE INSURANCE COMPANY, REPORT NO. NCS-1146469-SA1, DATEDMAY 07, 2025TITLE EXCEPTIONS:1. ANY DEFECT, LIEN, ENCUMBRANCE, ADVERSE CLAIM, OR OTHER MATTER THAT APPEARS FOR THEFIRST TIME IN THE PUBLIC RECORDS OR IS CREATED, ATTACHES, OR IS DISCLOSED BETWEEN THECOMMITMENT DATE AND THE DATE ON WHICH ALL OF THE SCHEDULE B, PART I-REQUIREMENTS AREMET.2. (A) TAXES OR ASSESSMENTS THAT ARE NOT SHOWN AS EXISTING LIENS BY THE RECORDS OF ANYTAXING AUTHORITY THAT LEVIES TAXES OR ASSESSMENTS ON REAL PROPERTY OR BY THE PUBLICRECORDS; (B) PROCEEDINGS BY A PUBLIC AGENCY THAT MAY RESULT IN TAXES OR ASSESSMENTS,OR NOTICES OF SUCH PROCEEDINGS, WHETHER OR NOT SHOWN BY THE RECORDS OF SUCHAGENCY OR BY THE PUBLIC RECORDS.3. ANY FACTS, RIGHTS, INTERESTS, OR CLAIMS THAT ARE NOT SHOWN BY THE PUBLIC RECORDS BUTTHAT COULD BE ASCERTAINED BY AN INSPECTION OF THE LAND OR THAT MAY BE ASSERTED BYPERSONS IN POSSESSION OF THE LAND.4. EASEMENTS, LIENS OR ENCUMBRANCES, OR CLAIMS THEREOF, NOT SHOWN BY THE PUBLICRECORDS.5. ANY ENCROACHMENT, ENCUMBRANCE, VIOLATION, VARIATION, OR ADVERSE CIRCUMSTANCEAFFECTING THE 77TLE THAT WOULD BE DISCLOSED BY AN ACCURATE AND COMPLETE LAND SURVEYOF THE LAND AND NOT SHOWN BY THE PUBLIC RECORDS.6. (A) UNPATENTED MINING CLAIMS; (B) RESERVATIONS OR EXCEPTIONS IN PATENTS OR IN ACTSAUTHORIZING THE ISSUANCE THEREOF; (C) WATER RIGHTS, CLAIMS OR TITLE TO WATER, WHETHEROR NOT THE MATTERS EXCEPTED UNDER (A), (B), OR (C) ARE SHOWN BY THE PUBLIC RECORDS.7. GENERAL AND SPECIAL TAXES AND ASSESSMENTS FOR THE FISCAL YEAR 2023-2024, A LIEN NOT YETDUE OR PAYABLE.8. GENERAL AND SPECIAL TAXES AND ASSESSMENTS FOR THE FISCAL YEAR 2022-2023 ARE EXEMPT. IFTHE EXEMPT STATUS IS TERMINATED AN ADDITIONAL TAX MAY BE LEVIED. A.P. NO.: 430-481-12.9. THE LIEN OF SPECIAL TAX ASSESSED PURSUANT TO CHAPTER 2.5 COMMENCING WITH SECTION 53311OF THE CALIFORNIA GOVERNMENT CODE FOR COMMUNITY FACILITIES DISTRICT NO. 13-01, ASDISCLOSED BY NOTICE OF SPECIAL TAX LIEN RECORDED MAY 16, 2013 AS INSTRUMENT NO.2013000296640 OF OFFICIAL RECORDS.10. THE LIEN OF SPECIAL TAX ASSESSED PURSUANT TO CHAPTER 2.5 COMMENCING WITH SECTION 53311OF THE CALIFORNIA GOVERNMENT CODE FOR COMMUNITY FACILITIES DISTRICT NO. 15-2, ASDISCLOSED BY NOTICE OF SPECIAL TAX LIEN RECORDED NOVEMBER 18, 2015 AS INSTRUMENT NO.2015000594036 OF OFFICIAL RECORDS.11. THE LIEN OF SPECIAL TAX ASSESSED PURSUANT TO CHAPTER 2.5 COMMENCING WITH SECTION 53311OF THE CALIFORNIA GOVERNMENT CODE FOR COMMUNITY FACILITIES DISTRICT NO. 2018-01, ASDISCLOSED BY NOTICE OF SPECIAL TAX LIEN RECORDED FEBRUARY 17, 2021 AS INSTRUMENT NO.2021000112117 OF OFFICIAL RECORDS.12. THE LIEN OF SUPPLEMENTAL TAXES, IF ANY, ASSESSED PURSUANT TO CHAPTER 3.5 COMMENCINGWITH SECTION 75 OF THE CALIFORNIA REVENUE AND TAXATION CODE.13. THE TERMS AND PROVISIONS CONTAINED IN THE DOCUMENT ENTITLED "SHORT FORM NOTICE OFAGREEMENT" RECORDED MAY 14, 2002 AS INSTRUMENT NO. 20020404589 OF OFFICIAL RECORDS.14. EASEMENTS, COVENANTS AND CONDITIONS CONTAINED IN THE DEED FROM THE UNITED STATES OFAMERICA, AS GRANTOR, TO THE CITY OF TUSTIN, CALIFORNIA, AS GRANTEE, RECORDED MAY 14, 2002AS INSTRUMENT NO. 20020404594 OF OFFICIAL RECORDS. REFERENCE BEING MADE TO THEDOCUMENT FOR FULL PARTICULARS.DOCUMENT RE-RECORDED APRIL 09, 2003 AS INSTRUMENT NO.2003000392129 OF OFFICIAL RECORDS.NOT PLOTTED.15. THE FACT THAT THE LAND LIES WITHIN THE BOUNDARIES OF THE MCAS TUSTIN REDEVELOPMENTPROJECT AREA, AS DISCLOSED BY THE DOCUMENT RECORDED JUNE 18, 2003 AS INSTRUMENT NO.2003000710836 OF OFFICIAL RECORDS.NOT PLOTTED.16. THE TERMS AND PROVISIONS CONTAINED IN THE DOCUMENT ENTITLED "DECLARATION OF SPECIALRESTRICTIONS" RECORDED JUNE 19, 2007 AS INSTRUMENT NO. 2007000390805 OF OFFICIAL RECORDS.NOT PLOTTED.17. COVENANTS, CONDITIONS, RESTRICTIONS AND EASEMENTS IN THE DOCUMENT RECORDED OCTOBER04, 2006 AS INSTRUMENT NO. 2006000661919 OF OFFICIAL RECORDS, WHICH PROVIDE THAT AVIOLATION THEREOF SHALL NOT DEFEAT OR RENDER INVALID THE LIEN OF ANY FIRST MORTGAGE ORDEED OF TRUST MADE IN GOOD FAITH AND FOR VALUE, BUT DELETING ANY COVENANT, CONDITIONOR RESTRICTION INDICATING A PREFERENCE, LIMITATION OR DISCRIMINATION BASED ON RACE,COLOR, RELIGION, SEX, HANDICAP, FAMILIAL STATUS, NATIONAL ORIGIN, SEXUAL ORIENTATION,MARITAL STATUS, ANCESTRY, SOURCE OF INCOME OR DISABILITY, TO THE EXTENT SUCHCOVENANTS, CONDITIONS OR RESTRICTIONS VIOLATE TITLE 42, SECTION 3604(C), OF THE UNITEDSTATES CODES OR SECTION 12955 OF THE CALIFORNIA GOVERNMENT CODE. LAWFUL RESTRICTIONSUNDER STATE AND FEDERAL LAW ON THE AGE OF OCCUPANTS IN SENIOR HOUSING OR HOUSING FOROLDER PERSONS SHALL NOT BE CONSTRUED AS RESTRICTIONS BASED ON FAMILIAL STATUS. NOTPLOTTED18. THE TERMS AND PROVISIONS CONTAINED IN THE DOCUMENT ENTITLED "NOTICE OF DELINQUENCYAND CLAIM OF LIEN" RECORDED APRIL 06, 2010 AS INSTRUMENT NO. 2010000160007 OF OFFICIALRECORDS. NOT PLOTTED.19. AN EASEMENT SHOWN OR DEDICATED ON THE MAP OF TRACT NO. 18197 RECORDED DECEMBER 10,2020 AND ON FILE IN BOOK 990, PAGE 25-33, OF TRACT MAPS.FOR: PUBLIC STREET AND PUBLIC UTILITY PURPOSES: ARMSTRONG AVENUE, WARNER AVENUE,LEGACY ROAD, AIRSHIP AVENUE, FLIGHT WAY, HELBER WAY, VETERANS WAY, COMPASS AVENUE,SWAIM WAY, JOHN JOHNSON WAY AND PEEBLER WAY AND INCIDENTAL PURPOSES.PLOTTED HEREON.20. WATER RIGHTS, CLAIMS OR TITLE TO WATER, WHETHER OR NOT SHOWN BY THE PUBLIC RECORDS.21. AN ALTA/NSPS SURVEY OF RECENT DATE WHICH COMPLIES WITH THE CURRENT MINIMUM STANDARDDETAIL REQUIREMENTS FOR ALTA/NSPS LAND TITLE SU1VEYS.22. ANY FACTS, RIGHTS, INTERESTS OR CLAIMS WHICH WOULD BE DISCLOSED BY A CORRECT ALTA/NSPSSURVEY.23. RIGHTS OF PARTIES IN POSSESSION.FOUND SPIKE & WASHER STAMPED "LS 6673" PER R1, FLUSH; ACCEPTED AS ARMSTRONG AVENUECENTERLINE BEGINNING CURVE PER R1.2FOUND SPIKE & WASHER STAMPED "LS 6673" PER R2, FLUSH; ACCEPTED AS ARMSTRONG AVENUE& C STREET CENTERLINE INTERSECTION PER R2.3SEARCHED FOUND NOTHING, SET NOTHING; ARMSTRONG AVENUE & JOHN JOHNSON WAY CENTERLINEINTERSECTION ESTABLISHED BY RECORD RADIUS AND DISTANCE (360.47') FROM 2 PER R14FOUND SPIKE & WASHER STAMPED "LS 5347" PER R1, FLUSH; ACCEPTED AS WARNER AVENUE& LEGACY ROAD CENTERLINE INTERSECTION PER R1.5SEARCHED FOUND NOTHING, SET NOTHING; WARNER AVENUE & VETERANS WAYCENTERLINE INTERSECTION ESTABLISHED BY RECORD DISTANCES FROM 1 PER R16SEARCHED FOUND NOTHING, SET NOTHING; VETERANS WAY & JOHN JOHNSON WAY CENTERLINEINTERSECTION ESTABLISHED BY RECORD BEARING & DISTANCES FROM 6 PER R17FOUND SPIKE & WASHER STAMPED "LS 6673" PER R1, FLUSH; ACCEPTED AS ARMSTRONG AVENUECENTERLINE BEGINNING CURVE PER R1.8DATUM STATEMENT:COORDINATES SHOWN ARE BASED ON THE CALIFORNIA COORDINATE SYSTEM(CCS83), ZONE VI, 1983 NAD, (2017.50 EPOCH OCS GPS ADJUSTMENT).ALL DISTANCES SHOWN ARE GROUND UNLESS OTHERWISE NOTED. TO OBTAINGRID DISTANCE, MULTIPLY GROUND DISTANCE BY 0.99997671 (PROJECTSPECIFIC).FLOOD ZONE:THIS SURVEY LIES WITHIN ZONE "X" (AREAS DETERMINED TO BE OUTSIDE THE0.2% ANNUAL CHANCE FLOODPLAIN) AS SET OUT ON THE FLOOD INSURANCERATE MAP FOR ORANGE COUNTY, COMMUNITY PANEL NUMBER 06059C 0279J,DATED DECEMBER 3, 2009.VICINITY MAPN.T.S.EXCEPTIONS/ENCROACHMENT NOTES:UTILITIES WITHOUT EASEMENT ON THE NORTHERLY BOUNDARY AS SHOWN.1WALL CROSSING THE PROPERTY LINE ON THE NORTHERLY BOUNDARY AS SHOWN.2UTILITIES WITHOUT EASEMENT ON THE SOUTHWESTERLY BOUNDARY AS SHOWN.3LINE AND CURVE TABLESC-0.0CENTERLINEUTILITY PURVEYORS:ELECTRICAL:SOUTHERN CALIFORNIA EDISON1325 S GRAND AVE.SANTA ANA, CA 92705(800)-655-4555GAS:SOUTHERN CALIFORNIA GAS COMPANY1919 STATE COLLEGE BLVD.ANAHEIM, CA 92805(877) 238-0092(714) 634-3245CABLE:TIME WARNER14311 NEWPORT AVE.TUSTIN, CA 927803(714) 418-4267FRONTIER COMMUNICATION7354 SLATER AVE.HUNTINGTON BEACH, CA 92647(714) 969-6468COX6771 QUAIL HILL PKWY.IRVINE, CA 92603(949) 546-1000TELEPHONECOX COMMUNICATIONS6771 QUAIL HILL PKWY.IRVINE, CA 92603(949) 546-1000AT&T (LAND LINE SERVICE)3581 ORANGE STRIVERSIDE , CA 92501(909) 441-0499WATER & SEWER:IRVINE RANCH WATER DISTRICT3512 MICHELSON DR,IRVINE, CA 92612(714) 453-5300STORM DRAINCITY OF TUSTIN (PUBLIC WORKS)300 CENTENNIAL WAYTUSTIN, CA 92780(714)-573-3150SUBDIVIDER/DEVELOPER:CD-CW (TUSTIN) LLC2215 MARKET ST.DENVER, CO 80205ATTN: H. MCNEISHPHONE: 303.573.6500PROPOSED EASEMENTS:APROPOSED EASEMENT TO THE CITY OF TUSTIN FOR BIOSWALE ACCESS ANDMAINTENANCE PURPOSES AND UTILITIES (PULLBOXES, VAULTS, CONDUITS)TO BE RESERVED IN SEPARATE DOCUMENT (4,260 SF)BPROPOSED EASEMENT FOR COMMON ACCESS AND EMERGENCY VEHICLE ACCESSNOTE:THE SUBDIVIDER SHALL RELEASE AND RELINQUISH TO THE CITY OF TUSTINALL VEHICULAR ACCESS RIGHTS ALONG ARMSTRONG AVENUE, WARNERAVENUE, VETERANS WAY, AND JOHN JOHNSON WAY, EXCEPT ALL APPROVEDACCESS LOCATIONS AND STREET INTERSECTIONS, AT NO COST TO THE CITY.AREA:GROSS AREA: 267,385 SF (6.14 AC)NET AREA: 263,125 SF (6.04 AC)No.C-621591/23/2026117 )L1 ii, t}> I I I I I t I /,' I I I I j I 1 : If, I o o I ' ' ' \ \ \ I r 5 0 0 0 0 0 <1 <1 <1 00000000 Tustin Confluent Bioswale and Utility Easement 7.8.26 (HM) Schedule 3 City of Tustin/Confluent Development Development Agreement SCHEDULE 3 Legal and Plat of Bioswale Easement Area [To be attached] 118 SCHEDULE 3 TO DEVELOPMENT AGREEMENT LEGAL AND PLAT OF BIOSWALE EASEMENT AREA 119 EXHIBIT'A' LEGAL DESCRIPTION BIO-SWALE EASEMENT THAT CERTAIN PARCEL OF LAND SITUATED IN THE CITY OF TUSTIN, COUNTY OF ORANGE, STATE OF CALIFORNIA, BEING A PORTION OF LOT 14 AS SHOWN ON THAT CERTAIN TRACT MAP, TRACT NO. 18197 FILED IN BOOK 990 OF MISCELLANEOUS MAPS AT PAGES 25 THROUGH 33, INCLUSIVE, ON DECEMBER 10, 2020, UNDER INSTRUMENT NUMBER 2020000726746, IN THE OFFICE OF THE COUNTY RECORDER OF SAID ORANGE COUNTY, BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS: COMMENCING AT THE NORTHEAST CORNER OF SAID LOT 14, SAID POINT ALSO LYING ON THE WESTERLY LINE OF VETERANS WAY; THENCE ALONG THE NORTHEASTERLY LINE OF SAID LOT 14 NORTH 25°58'17" WEST 38.45 FEET TO THE NORTHERLY LINE OF SAID LOT 14, SAID POINT ALSO LYING ON THE SOUTHERLY LINE OF WARNER AVENUE, SAID POINT BEING THE BEGINNING OF A NON-TANGENT CURVE, HAVING A RADIUS OF 1470.00 FEET, FROM WHICH THE RADIUS BEARS NORTH 21 °10'33" EAST; THENCE WESTERLY ALONG SAID NORTHERLY LINEAN ARC LENGTH OF 67.61 FEET, THROUGH A CENTRAL ANGLE OF 2°38'06" TO THE POINT OF BEGINNING; THENCE LEAVING SAID NORTHERLY LINE OF LOT 14 SOUTH 24°00'21 " WEST 1.98 FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE NORTHERLY, HAVING A RADIUS OF 22.25 FEET; THENCE WESTERLY AN ARC LENGTH OF 27.21 FEET, THROUGH A CENTRAL ANGLE OF 70°04'39" TO THE BEGINNING OF A TANGENT COMPOUND CURVE, CONCAVE NORTHEASTERLY, HAVING A RADIUS OF 1486.51 FEET; THENCE NORTHWESTERLY AN ARC LENGTH OF 61 .09 FEET, THROUGH A CENTRAL ANGLE OF 2°21 '16", TO THE BEGINNING OF A TANGENT COMPOUND CURVE, CONCAVE NORTHEASTERLY, HAVING A RADIUS OF 187.26 FEET; THENCE NORTHWESTERLY AN ARC LENGTH OF 35.07 FEET, THORUGH A CENTRAL ANGLE OF 10°43'51 "; THENCE NORTH 51 °45'31 " WEST 30.58 FEET TO THE BEGINNING OFA TANGENT CURVE, CONCAVE SOUTHWESTERLY, HAVING A RADIUS OF 189.26 FEET; THENCE NORTHWESTERLY AN ARC LENGTH OF 30.31 FEET, THROUGH A CENTRAL ANGLE OF 9°10'39", TO THE BEGINNING OF A NON-TANGENT REVERSE CURVE, FROM WHICH THE RADIUS BEARS NORTH 31 °06'24" EAST, HAVING A RADIUS OF 2394.35 FEET; THENCE NORTHWESTERLY AN ARC LENGTH OF 59.06 FEET, THROUGH A CENTRAL ANGLE OF 1°24'48", TO THE BEGINNING OF A NON-TANGENT COMPOUND CURVE, FROM WHICH THE RADIUS BEARS NORTH 32°55'18" EAST, HAVING A RADIUS OF 22.24 FEET; THENCE NORTHWESTERLY AN ARC LENGTH OF 22 .72 FEET, THROUGH A CENTRAL ANGLE OF 58°32'21 ", TO THE BEGINNING OF A NON-TANGENT CURVE, FROM WHICH THE RADIUS BEARS NORTH 33°41 '55" EAST, HAVING A RADIUS OF 1466.00 FEET; THENCE NORTHWESTERLY AN ARC LENGTH OF 45.21 FEET, THROUGH A CENTRAL ANGLE OF 1°46'01 ", MORE OR LESS, TO SAID NORHTERLY LINE OF LOT 14; THENCE ALONG SAID NORTHERLY LINE OF LOT 14 THE FOLLOWING SEVEN (7) COURSES: SOUTH 68°46'50" EAST 20.47 FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE SOUTHERLY, HAVING A RADIUS OF 41 .00 FEET; THENCE SOUTHEASTERLY AN ARC LENGTH OF 9.38 FEET, THROUGH A CENTRAL ANGLE OF 13°06'13", TO THE BEGINNING OF A TANGENT REVERSE CURVE, CONCAVE NORTHEASTERLY, HAVING A RADIUS OF 1460.00 FEET; THENCE SOUTHEASTERLY AN ARC LENGTH OF 96.89 FEET, THROUGH A CENTRAL ANGLE OF 3°48'09", TO THE BEGINNING OF A TANGENT REVERSE CURVE, CONCAVE SOUTHWESTERLY, HAVING A RADIUS OF 196.48 FEET; THENCE SOUTHEASTERLY AN ARC LENGTH OF 26.48 FEET, THROUGH A CENTRAL ANGLE OF 7°43'15"; THENCE SOUTH 51 °45'31 " EAST 32 .83 FEET, TO THE BEGINNING OF TANGENT CURVE, CONCAVE NORTHEASTERLY, HAVING A RADIUS OF 170.77 FEET; THENCE SOUTHEASTERLY AN ARC LENGTH OF 31 .91 FEET, THROUGH A CENTRAL ANGLE OF 10°42'18", TO THE BEGINNING OF A TANGENT COMPOUND CURVE, CONCAVE NORTHERLY, HAVING A RADIUS OF 1470.00 FEET; THENCE SOUTHEASTERLY AN ARC LENGTH OF 81 .31 FEET, THROUGH A CENTRAL ANGLE OF 3°10'10", MORE OR LESS, TO THE POINT OF BEGINNING. CONTAINING 4,256 SQUARE FEET, MORE OR LESS. 120 EXHIBIT 'B', ATTACHED HERETO AND BY THE REFERENCE, MADE A PART HEREOF. THIS REAL PROPERTY DESCRIPTION HAS BEEN PREPARED BY ME, OR UNDER MY DIRECTION, IN CONFORMANCE WITH THE PROFESSIONAL LAND SURVEYOR'S ACT. T DD A. TILLOTSON, PLS LS NO. 8593 7(q(ZCJZ/o DATE 121 PLAT TO ACCOMPANY LEGAL DESCRIPTION EXHIBIT 'B' - ----------- CURVE TABLE CURVE LENGTH RADIUS C1 67.61' 1470.00' C2 27.21' 22.25' CJ 61.09 ' 1486.57 ' C4 35.07' 187.26' C5 30.31' 189.26' C6 59.06' 2394.35' C7 22.72' 22.24' CB 45.21' 1466.00' C9 9.38' 41.00' C10 96.89' 1460.00' C 11 26.48' 196.48' C12 31 .91 ' 170. 77' C13 81.31' 1470.00' -- BIO-SWALE EASEMENT 4,256 S.F.± C13 C3 CJTY OF TUSTIN TRACT NO . 1 a 197 BK. 990, PG. 25, O.R . LOT 14 LINE TABLE DELTA LINE BEARING 2"38'06" L 1 N25"58 '7 7''W 10·04'39" L2 s24·00·21 ·w 2·21'76" L3 N51"45 '3 7 ''W 10·43'57" L4 S68"46'50''E 9·10'39" L5 551"45'31 "E 1"24'48" 53·32·21" 1"46'07" 13"06'73" 3"48'09" 7"43'75" 10·42'18" 3"70'70" DISTANCE 38.45' 1.98' 30.58' 20.47' 32.83' F S 4 A55oc.iate5, Inc.. CI TY OF TUSTIN -ORANGE COUN TY BIO-SWALE EASEMENT Land Surveying 701 E. H STREET, Benicia, CA 94510 Phone (707) 748-4300 -Fax (707) 361-0295 www.F3-inc.com TILLOTSON POB Cl POC SCALE: 1"=60' DA TE: JUL 2026 DRAWN BY: STAFF JOB NO: 26 FILE NO: SHEET SOURCE CODES (1) STANDARD CONDITION (2) CEQA MITIGATION (3) UNIFORM BUILDING CODE (4) DESIGN REVIEW (5) RESPONSIBLE AGENCY REQUIREMENT (6) LANDSCAPING GUIDELINES (7) PC/CC POLICY *** EXCEPTION / PROJECT-SPECIFIC CONDITION EXHIBIT B CONDITIONS OF APPROVAL CLEARWATER AT TUSTIN LEGACY SUBDIVISION 2025-0003/TENTATIVE PARCEL MAP 2025-151 CONDITIONAL USE PERMIT 2025-0012 DESIGN REVIEW 2025-0008 DEVELOPMENT AGREEMENT 2025-0001 Source No. Condition Responsible Department Timing / Trigger GENERAL (1) 1.1 The proposed project shall be in compliance with the Tustin Legacy Specific Plan, Tustin City Code (TCC), and City of Tustin Guidelines and Standards and conform with submitted plans for the project date stamped August 11, 2026, on file with the Community Development Department, except as herein modified, or as modified by the Community Development Director in accordance with this Exhibit. The Community Development Director may also approve minor modifications to plans during plan check if such modifications are consistent with the provisions of the TCC, and other applicable regulations. CDD Ongoing (1) 1.2 Unless otherwise specified, the conditions contained in this Exhibit shall be complied with as specified or prior to the issuance of any building permits for the project, CDD Prior to building permit 122 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 2 Source No. Condition Responsible Department Timing / Trigger subject to review and approval by the Community Development Department. (1) 1.3 The subject project approval shall become null and void unless permits for the proposed project are issued and substantial construction is underway within 24 months of this approval, unless otherwise provided by Development Agreement (DA) 2025-0001 included as Exhibit A of Ordinance No. 1580. Time extensions may be considered consistent with the provisions of DA 2025-0001. CDD Within 24 months of approval (1) 1.4 Approval of SUB 2025-0003/TPM 2025-151, CUP 2025-0012, DR 2025-0008, the Density Bonus incentive and waiver requests, and DA 2025-0001 are contingent upon the applicant and property owner signing and returning to the Community Development Department a notarized “Agreement to Conditions Imposed” form and the applicant and/or property owner signing and recording with the County Clerk Recorder a notarized “Notice of Discretionary Permit Approval and Conditions of Approval” form. The forms shall be established by the Community Development Director, and evidence of recordation shall be provided to the Community Development Department. CDD Ongoing (1) 1.5 The applicant shall comply with executed DA 2025- 0001 and the associated Disposition and Development Agreement (DDA). CDD / Real Property Ongoing (1) 1.6 Any violation of any of the conditions imposed is subject to the issuance of an Administrative Citation pursuant to TCC Section 1162(a). CDD Ongoing 123 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 3 Source No. Condition Responsible Department Timing / Trigger (1) 1.7 In the case of any conflict between these Conditions of Approval and DA 2025-0001, the DA between the City of Tustin and Developer shall govern. CDD / City Attorney Ongoing (1) 1.8 The applicant shall be responsible for costs associated with any necessary code enforcement action, including attorney’s fees, subject to the applicable notice, hearing, and appeal process as established by the City Council by ordinance. CDD Ongoing (1) 1.9 As a Condition of Approval of SUB 2025-0003/TPM 2025-151, CUP 2025-0012, DR 2025-0008, the Density Bonus incentive and waiver requests, and DA 2025- 0001, the applicant shall agree, at its sole cost and expense, to defend, indemnify, and hold harmless the City, its officers, employees, agents, and consultants, from any claim, action, or proceeding brought by a third party against the City, its officers, agents, and employees, which seeks to attack, set aside, challenge, void, or annul an approval of the City Council, the Planning Commission, or any other decision-making body, including staff, concerning this project. The City agrees to promptly notify the applicant of any such claim or action filed against the City and to fully cooperate in the defense of any such action. The City may, at its sole cost and expense, elect to participate in the defense of any such action under this condition. City Attorney Ongoing USE RESTRICTIONS *** 2.1 The project shall include 172 residential units for active seniors, inclusive of 26 units affordable to Lower Income households, and an approximately 143,000 square foot assisted living and memory care facility containing 103 units (75 assisted living units and 28 memory care units) with a total of 134 beds, together CDD Ongoing 124 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 4 Source No. Condition Responsible Department Timing / Trigger with parking garages, surface parking, landscaping, and recreational amenities, as depicted on the approved plans. *** 2.2 Prior to issuance of the first Certificate of Occupancy (C of O) for the residential community for active seniors, the applicant shall record against the property, in a form approved by the City Attorney, a covenant restricting occupancy of the 172 residential units to senior citizens consistent with California Civil Code Sections 51.3 and 51.12 and the federal Housing for Older Persons Act of 1995. The covenant shall run with the land and shall remain in effect for the life of the project. CDD / City Attorney Prior to first C of O (residential) *** 2.3 The assisted living and memory care facility shall be licensed by the California Department of Social Services (CDSS) as a Residential Care Facility for the Elderly. Prior to issuance of a C of O for the facility, the applicant shall provide the Community Development Department with a copy of the CDSS license, or written evidence that the license application is pending and that occupancy will not commence prior to licensure. The applicant shall also obtain and maintain any additional State approvals required to operate a memory care program. A copy of any subsequent license, license renewal, or change of operator shall be provided to the Community Development Department within 30 days. CDD Prior to C of O (ALMC) and ongoing *** 2.4 The memory care wing shall be maintained as a secured wing, separate from the assisted living units, with staff trained in dementia care, and staff shall be present at all times. The outdoor balcony serving the memory care wing shall be maintained as secure space for residents. CDD Ongoing 125 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 5 Source No. Condition Responsible Department Timing / Trigger *** 2.5 The assisted living and memory care facility shall be staffed on a 24-hour per day basis consistent with CDSS licensing requirements. Any change in the operator of the facility shall be reported to the Community Development Department in writing within 30 days. CDD Ongoing *** 2.6 No convalescent care, skilled nursing facility, or hospital use is approved by CUP 2025-0012. Any proposal to establish such a use shall require a new or amended conditional use permit. CDD Ongoing (4) 2.7 All parking spaces within the project site shall be maintained as shown on the approved site plan. Any changes to the number, location, or size of parking spaces shall be reviewed and approved by the Community Development Director. CDD Ongoing *** 2.8 The amenities shared between the residential community for active seniors and the assisted living and memory care facility, including the full-service kitchen, community theater, and salon, shall be maintained for the use of residents of both components for the life of the project. CDD Ongoing *** 2.9 Deliveries, refuse collection, and move-in/move-out activities shall occur within designated on-site areas and shall not obstruct the public right-of-way. Refuse collection shall occur only between the hours of 7:00 a.m. and 6:00 p.m. Monday – Friday, and 9:00 a.m. and 5:00 p.m. on Saturday. CDD / PW Ongoing (1) 2.10 Any outdoor storage during grading or building stages shall be approved by the Community Development Director. CDD During construction 126 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 6 Source No. Condition Responsible Department Timing / Trigger *** 2.11 The internal roundabout, passenger loading area, bus turnout, and dedicated bus space shall be maintained and kept free of obstruction at all times to serve resident drop-off and resident transportation. CDD / PW Ongoing AFFORDABLE HOUSING AND DENSITY BONUS *** 3.1 The project shall provide and maintain 26 residential units affordable to Lower Income households for a minimum period of 55 years, as required by Government Code Section 65915(c)(1). Rents shall be calculated in accordance with Health and Safety Code Section 50053. CDD 55 years from first C of O *** 3.2 Prior to the close of escrow, the applicant shall execute and record against the property, in a form approved by the City Attorney, the Surplus Land Act (SLA) Covenant and Affordable Housing Declaration required by DA 2025-0001 and the DDA, securing the affordability of the 26 Lower Income units. City Attorney / Real Property Prior to close of escrow *** 3.3 The 26 Lower Income units shall consist of 23 one- bedroom units and three two-bedroom units, consistent with the density bonus incentive approved with this project. The composition of income levels and unit types for the affordable units may be adjusted upon review and approval of the Community Development Director, subject to compliance with applicable State law, including Density Bonus Law and the Surplus Land Act. CDD Plan check; ongoing *** 3.4 The affordable units shall be dispersed throughout the residential community for active seniors and shall have access to all project amenities on the same terms as market-rate units. The location of the affordable units CDD Plan check; ongoing 127 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 7 Source No. Condition Responsible Department Timing / Trigger shall be identified on plans submitted for building plan check. *** 3.5 The density bonus waivers approved with this project are limited to the following development standards: private open space, building setbacks, patio wall height, and architectural feature encroachment, each as described in the approved Affordable Housing Plan and Density Bonus Application and as depicted on the approved plans. All other development standards of the Tustin Legacy Specific Plan (TLSP) shall apply. CDD Plan check DESIGN AND ARCHITECTURE (4) 4.1 At building plan check, building elevations visible from public streets shall have enhanced elevations consistent with the approved DR 2025-0008 in terms of color and material, architectural articulation and architectural projections, to the satisfaction of the Community Development Department. CDD Building plan check (1), (4) 4.2 All exterior colors, textures, and materials shall be consistent with the approved plans. Specifications on colors, materials, and textures shall be noted in construction plans and subject to review and approval by the Community Development Department. CDD Building plan check (1), (4) 4.3 Final material samples and colors shall be provided at plan check submittal. CDD Plan check submittal (1), (4) 4.4 All mechanical and electrical equipment, including roof- top equipment, shall be adequately and decoratively screened. The screen shall be included as an element of the overall design of the project and blend with the architectural design of the building. All telephone and electrical boxes shall be identified on the construction plans. Electrical transformers shall be located toward CDD Building plan check; ongoing 128 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 8 Source No. Condition Responsible Department Timing / Trigger the interior of the project (as feasible) and screened by adequate landscaping or other effective screening devices. (4) 4.5 Roof drains and downspouts shall be minimally visible from public streets. CDD Building plan check (4) 4.6 Rooftop parapets shall be of sufficient height to screen all rooftop mechanical equipment from view from adjacent public rights-of-way, consistent with the maximum building heights approved by DR 2025-0008 (71 feet for the residential community for active seniors and 35.6 feet for the assisted living and memory care facility, measured to top of parapet). CDD Building plan check (1), (4) 4.7 The applicant shall submit a Master Sign Plan for City review and approval. Signage shall be installed under separate permit and approval. CDD Prior to sign installation *** 4.8 Trash chutes and enclosed ground-floor trash rooms shall be provided in each building as depicted on the approved plans. On-site refuse collection areas shall be accessible from internal drive aisles and shall be screened from public view. CDD / PW Building plan check; ongoing (1) 4.9 Exterior lighting shall be designed to provide safe pedestrian and vehicular circulation while shielding and directing light downward to avoid spillover onto adjacent properties. A photometric plan shall be submitted at plan check demonstrating compliance with the Tustin Security Ordinance and with TCC lighting standards, subject to review and approval by the Community Development Department prior to issuance of building permits. CDD / PD Plan check; ongoing LANDSCAPE/HARDSCAPE 129 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 9 Source No. Condition Responsible Department Timing / Trigger (6) 5.1 At plan check, the applicant shall provide complete detailed landscaping and irrigation plans for all landscaping areas, consistent with adopted City of Tustin landscaping requirements. The plans shall include the following: a. A summary table identifying plant materials, listing botanical and common names, sizes, spacing, location, and quantity of the plant materials proposed. b. Planting and berming details, soil preparation, and staking. c. The irrigation plan shall show location and control of backflow prevention devices, pipe size, sprinkler type, spacing, and coverage. Details for all equipment must be provided. d. All property lines, public right-of-way areas, sidewalk widths, parkway areas, and wall locations. e. Shrubs shall be a minimum of five-gallon size and placed a maximum of five feet on center. Other sizes and spacing may be permitted subject to approval of the Community Development Department. f. Ground cover shall be planted eight to 12 inches on center, or as approved by the Community Development Department. g. Equipment areas shall be screened with walls, vines, and/or trees, subject to review and approval of the Community Development Department. CDD Plan check 130 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 10 Source No. Condition Responsible Department Timing / Trigger h. On-site walls and fences shall be noted on the plans with specific materials, colors, and decorative treatments. (1) 5.2 The Community Development Department may request minor substitutions of plant materials or request additional sizing or quantity of materials during plan check. CDD Plan check (1), (6) 5.3 All plant materials shall be installed in a healthy vigorous condition typical to the species and shall be maintained in a neat and healthy condition. Maintenance includes, but is not limited to, trimming, weeding, removal of litter, fertilizing, regular watering, and replacement of diseased or dead plants. CDD Ongoing (1), (6) 5.4 Landscape adjacent to the right-of-way shall be in compliance with the TLSP and the City of Tustin Landscape and Irrigation Guidelines. CDD Plan check (1), (6) 5.5 The project shall comply with the City’s Water Efficient Landscape Ordinance and any Executive Orders issued by the Governor of the State of California pertaining to water conservation and irrigation methods. Prior to final C of O, the Community Development Department shall conduct a final inspection ensuring all landscaping is planted in compliance with the approved landscape plans and collect a completed Landscape Installation Certificate of Completion (Attachment E of the Water Efficient Landscape Ordinance). CDD Prior to final C of O (1), (6) 5.6 Backflow devices and double detector checks shall be painted to match surrounding landscaping and screened from public view. CDD Prior to C of O 131 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 11 Source No. Condition Responsible Department Timing / Trigger *** 5.7 The project shall provide a minimum of 29,455 square feet of landscaped area as depicted on the approved plans, including landscaping provided along the Project site boundary, parking lots, and throughout the 13,875 square foot central courtyard serving the residential community for active seniors and the 18,162 square foot central courtyard serving the assisted living and memory care facility. CDD Prior to C of O; ongoing NOISE *** 6.1 At plan check, an updated noise analysis shall be provided to ensure compliance with the Tustin Noise standards. CDD Plan check (1) 6.2 In accordance with the noise analysis, all units shall be constructed with appropriate sound attenuation to achieve the minimum noise level standards pursuant to the City’s Noise standards. Prior to issuance of C of O, the units shall be analyzed and certified for compliance with the City’s Noise standards. CDD Prior to C of O *** 6.3 The patio wall along Warner Avenue, for which a density bonus waiver of the patio wall height standard has been approved, shall be constructed to the height and specifications identified in the project acoustical analysis to provide sound attenuation for residents. CDD Prior to C of O (1) 6.4 All construction activity shall comply with TCC Section 4616, which allows construction only between the hours of 7:00 a.m. and 6:00 p.m. Monday through Friday, between 9:00 a.m. and 5:00 p.m. on Saturdays, and at no time on Sundays and City-observed federal holidays. CDD / PD During construction CONSTRUCTION 132 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 12 Source No. Condition Responsible Department Timing / Trigger *** 7.1 Construction shall occur in a single phase. Prior to issuance of a grading permit, the applicant shall submit a construction management plan to the Community Development Department identifying construction staging areas, construction worker parking, haul routes, and truck delivery hours, subject to review and approval. CDD Prior to grading permit (1) 7.2 Prior to issuance of any permit, the developer shall provide traffic operations and control plans that would minimize the traffic impacts of proposed construction activity. The plans shall address roadway and lane closures, truck hours and routes, and notification procedures for planned short-term or interim changes in traffic patterns. Such plans shall minimize anticipated delays at major intersections. Prior to approval, the City of Tustin shall review the proposed traffic control and operations plans with any affected jurisdiction. PW Prior to any permit (1) 7.3 The applicant shall comply with all City policies regarding short-term construction emissions, including periodic watering of the site and prohibiting grading during second stage smog alerts and when wind velocities exceed 15 miles per hour. CDD / PW During construction (1) 7.4 The developer shall coordinate with the Tustin Police Department to ensure adequate security provisions are implemented during construction. PD During construction (1) 7.5 Prior to the issuance of permits for any public improvements or development, the applicant shall submit to the City of Tustin information from the Irvine Ranch Water District (IRWD) which outlines required facilities necessary to provide adequate potable water and reclaimed water service to the development. PW Prior to public improvement permits 133 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 13 Source No. Condition Responsible Department Timing / Trigger PUBLIC WORKS DEPARTMENT — FINAL PARCEL MAP (1) 8.1 Preparation and recordation of a Final Parcel Map shall be allowed but is not required. PW Prior to C of O *** 8.2 If the Final Parcel Map is recorded, the Subdivider shall release and relinquish to the City of Tustin all vehicular access rights along Armstrong Avenue, Warner Avenue, Veterans Way, and John Johnson Way, except at approved access locations and street intersections, at no cost to the City, on the Map. PW On the Final Map *** 8.3 If the Final Parcel Map is recorded, the Subdivider shall satisfy dedication and/or reservation requirements as applicable, including, but not limited to, dedication in Fee Title of all required street rights-of-way; and dedication of vehicular access rights, sewer easements, and water easements defined and approved as to specific locations by the City Engineer (at no cost to the City) and/or other agencies. PW On the Final Map *** 8.4 Prior to recordation of the final map, the applicant is required to execute a subdivision and monumentation agreement and furnish improvement and monumentation bonds, all on forms acceptable to the City. PW Prior to final map recordation PUBLIC WORKS DEPARTMENT — WATER QUALITY *** 9.1 This development shall comply with all applicable provisions of the City of Tustin Water Quality Ordinance and all Federal, State and Regional Water Quality Control Board rules and regulations. PW Ongoing *** 9.2 The applicant shall submit for approval by the Community Development and Public Works Departments, a Final Water Quality Management Plan PW Prior to first permit 134 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 14 Source No. Condition Responsible Department Timing / Trigger (WQMP) with the most current plan check deposit in the City’s Citizen Self Service Portal. The final WQMP shall identify: the implementation of Best Management Practices (BMPs), the assignment of long-term maintenance responsibilities (specifying the developer, parcel owner, maintenance association, lessees, etc.), and reference to the location(s) of structural BMPs. The final WQMP shall be approved prior to issuance of first permit. *** 9.3 Prior to issuance of first permit, the applicant shall record a “Covenant and Agreement Regarding Operation and Maintenance (O & M) Plan to Fund and Maintain Water Quality BMPs, Consent to Inspect and Indemnification.” This document shall bind current and future owner(s) of the property regarding implementation and maintenance of the structural and non-structural BMPs as specified in the approved WQMP. PW Prior to first permit *** 9.4 Prior to the owner obtaining a Final Approval and C of O, the engineer responsible for the approved WQMP shall stamp and sign the Stormwater Observation Report Form. PW Prior to Final Approval / C of O *** 9.5 Prior to issuance of a Grading Permit, the developer shall submit a copy of the Notice of Intent (NOI) indicating that coverage has been obtained under the National Pollutant Discharge Elimination System (NPDES) State General Permit for Storm Water Discharges Associated with Construction Activity from the State Water Resources Control Board. PW Prior to grading permit *** 9.6 The onsite drainage and grading plan shall demonstrate that the project will make a connection to a recognized municipal storm drain system which was PW Prior to grading permit 135 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 15 Source No. Condition Responsible Department Timing / Trigger designed to handle flows from the proposed site. Prior to issuance of a grading permit, an updated Design Hydrology and Hydraulics Report will need to be prepared and submitted, concurrently with the final design plans, to the Community Development Department Building Division for review and approval to properly model and confirm all drainage capture, conveyance, treatment, pumping, retention and downstream outfall. PUBLIC WORKS DEPARTMENT — STREET IMPROVEMENTS (1) 10.1 Prior to any work in the public right-of-way, an Encroachment Permit shall be obtained from and applicable fees paid to the Public Works Department. PW Prior to work in right-of- way *** 10.2 Prior to issuance of first permit, the developer shall submit engineered public improvement plans along the project frontage for review and approval. These public improvements shall be completed prior to issuance of occupancy release. a. Commercial driveway aprons shall be designed and constructed/reconstructed per the most current City of Tustin Standard 210 with minimum apron width of 27-feet and minimum radius of 25-feet. Depending on the applicable City standard, dedication in fee on private property for pedestrian access may be required. In this case, a legal description and plat of the dedication area, as prepared by a California Registered Civil Engineer or California Licensed Land Surveyor, shall be submitted to the Public Works Department for review and approval. a. Design and construct sidewalk along Armstrong Avenue, John Johnson Way, and Veterans Way. PW Prior to first permit; complete prior to occupancy 136 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 16 Source No. Condition Responsible Department Timing / Trigger c. Install pavement legends, applicable signs adjacent to the project to accommodate access needed to serve the project. d. Developer shall dedicate easement to City at Warner Avenue Frontage, for bioswale access and maintenance purposes, at no cost to the City. e. The developer shall design and construct sidewalk, parkway landscape, and irrigation system along the property frontage. f.If the applicant chooses to install a new mid-block crosswalk on John Johnson Way, the crosswalk and associated features shall be designed and constructed per the most current City of Tustin Standard and must meet the following conditions: •Crosswalk shall not be placed within a storm drain local depression where curb height creates issues. •Crosswalk shall be placed between the driveway and Veterans Way intersection to minimize pedestrian conflict with vehicles accessing the driveway. •Curb extension (bulbout) shall be constructed on both sides of the crosswalk to provide adequate sight distance for pedestrian crossing while maintaining on-street parking on John Johnson Way. •Rectangular Rapid Flashing Beacons (RRFB) shall be installed on both sides of the crosswalk, and the details of the RRFB device shall be submitted to the Public Works Department for review and approval. 137 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 17 Source No. Condition Responsible Department Timing / Trigger • Path of travel associated with the crosswalk must be fully ADA-compliant. •The applicant shall design and construct the crosswalk, curb extension, RRFB, and signing and striping associated with the crosswalk, to the satisfaction of the City Engineer. These elements shall also be maintained by the developer/Clearwater’s Property Management. *** 10.3 The existing structural section on John Johnson Way and Veterans Way (from Airship Ave to Warner Ave) is currently limited to base pavement. Due to development activity in the region, the City omitted capping the above-mentioned streets. The developer shall implement the following improvements, based on conditions and impacts at such time that the developer moves forward with the construction of the project, to the satisfaction of the City Engineer: a. John Johnson Way1,2, b. Veterans Way 1,2, c. Warner Avenue, Armstrong Avenue 3 Half-Width1: If City annual maintenance contractor cap paves the street prior to developer beginning construction and impact from development project to street is limited to adjacent half of the street. Grind and overlay to the satisfaction of the City Engineer. Full-Width2: If development project timing interferes with City annual maintenance contractor, forcing the City to have to omit streets from the Scope of Work or should a city pavement moratorium be in effect (within 5 years after newly overlayed or reconstructed streets PW Per City Engineer at time of construction 138 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 18 Source No. Condition Responsible Department Timing / Trigger and within 3 years after newly slurry sealed streets). Grind and overlay to the satisfaction of the City Engineer. One Lane3: Grind and Overlay may be required on streets not used for hauling routes, subject to a determination by the City Engineer and may be up to Half-width based on field observations & conditions. Trench repair shall be per city standard no. 108. City moratorium standards shall be applicable, if in effect. (1) 10.4 Prior to issuance of first permit and/or an Encroachment Permit, the developer shall submit in the City’s Citizen Self Service Portal street improvement plans, as prepared by a California Registered Civil Engineer, for review and approval. The plans shall clearly show existing and proposed surface and underground improvements, including construction and/or replacement of any missing or damaged public improvements adjacent to this development. Said plans shall include, but not be limited to the following: a. Curb and gutter b. Sidewalk, including curb ramps for the physically disabled c. Drive aprons d.Signing/striping e.Street paving f. Street lighting g.Catch basin/storm drain laterals/connection to existing storm drain system h. Domestic water facilities PW Prior to first permit / encroachment permit 139 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 19 Source No. Condition Responsible Department Timing / Trigger i. Reclaimed water facilities j. Dry utility lines k. Landscape/irrigation l. Traffic signal m. Sanitary sewer facilities Improvements shall be constructed prior to the issuance of the first C of O. (1) 10.5 Prior to issuance of an Encroachment Permit for construction within the public right-of-way, the applicant shall submit in the City’s Citizen Self Service Portal traffic control plans, as prepared by a California Registered Traffic Engineer, or Civil Engineer experienced in this type of plan preparation, to the Public Works Department for review and approval. PW Prior to encroachment permit (1) 10.6 Current Federal Americans with Disabilities Act (ADA) requirements shall be met at all driveways and sidewalks adjacent to the site. City of Tustin standards shall apply, unless otherwise approved by the City Engineer. PW Ongoing (1) 10.7 The landscape and irrigation plan shall identify limited use areas for access onto public streets (at a minimum a 10 feet triangle on each side of a driveway for non- signalized intersection and a 25 feet triangle at a signalized intersection behind the sidewalk), hardscape improvements and landscaping within a limited use area must be restricted to a height of 12-24 inches or less depending on the speed of the road, and obstructions such as walls or landscaping that could block line of sight are not allowed in the limited use area, and proposed street tree with a diameter of no greater than 24 inches shall have a canopy no lower CDD, PW Plan check 140 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 20 Source No. Condition Responsible Department Timing / Trigger than 84 inches above the curb to ensure adequate sight lines of pedestrians on the sidewalk and vehicles and bicycles on the street are maintained. (1) 10.8 The proposed street trees shall meet the Tustin Legacy plant pallet requirements or be approved by the City of Tustin Arborist. PW Plan check PUBLIC WORKS DEPARTMENT — COORDINATION WITH AFFECTED PROPERTY OWNERS AND AGENCIES (1) 11.1 The developer shall obtain permission from and coordinate with affected property owners, jurisdictions, and resource agencies for all public and private improvements, including, but not limited to, the following: a. The developer shall obtain written approval and/or permits from the applicable utility companies, including but not limited to Southern California Edison, The Gas Company, Irvine Ranch Water District (IRWD), AT&T, Cox Communications, Spectrum, etc. b. The developer shall coordinate the design and construction of all utilities with the utility providers and the City. The applicant is responsible for the coordination and all costs related to the installation, upgrade, alteration, relocation or abandonment of all existing wet and dry utilities affected by the proposed project. c.The developer is responsible for the coordination and all costs related to the installation, upgrade, alteration, relocation or abandonment of all existing City improvements affected by the proposed project, subject to City Engineer approval. PW Prior to construction; ongoing PUBLIC WORKS DEPARTMENT — SOLID WASTE RECYCLING 141 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 21 Source No. Condition Responsible Department Timing / Trigger (1) 12.1 Construction and Demolition Waste Recycling and Reduction Plan (WRRP). a. The applicant/contractor is required to submit a WRRP to the Public Works Department. The WRRP must indicate how the applicant will comply with the City’s requirement (City Code Section 4351, et al) to recycle at least 65 percent of the project waste material or the amount required by the California Green Building Standards Code. b. The applicant will be required to submit a fifty-dollar ($50.00) application fee and a cash security deposit. All projects shall submit a security deposit in the amount of five percent of the project’s valuation as determined by the Building Official, rounded to the nearest thousand. c. Prior to issuance of any permit, the applicant shall submit the required security deposit in the form of cash, cashier’s check, personal check, or money order made payable to the “City of Tustin”. PW Prior to any permit (1) 12.2 Facility Solid Waste Collection and Recycling Plan. a. The applicant, property owner, and/or tenant(s) are required to participate in the City’s recycling program. b. Waste and Recycling collection facilities shall be equally and readily accessible by the property owner(s) or tenant(s). c. Waste and Recycling collection facilities must be placed in a location that can be easily and safely accessed by the solid waste hauler while utilizing either front loader or side loading equipment. PW Prior to C of O; ongoing 142 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 22 Source No. Condition Responsible Department Timing / Trigger d. All trash enclosures shall be designed with roof and be able to accommodate at least three (3) bins, with at least one (1) bin reserved for recyclable materials and one (1) bin reserved organic waste. Space for a container for organics is also required as described in Section below. e. All developments are required to provide space for the collection of organic materials. Organics are collected in a minimum of 65-gallon wheeled carts are required for areas where collection containers are shared by multiple units. The size of the organics container will be dependent upon the use and size of the building. Where collection containers are shared, organics can be collected six (6) days per week to minimize the space required for a container. PUBLIC WORKS DEPARTMENT — MISCELLANEOUS (1) 13.1 Prior to issuance of a Grading Permit, the applicant shall submit an 8 ½” x 11” street address map exhibit to the Public Works Department for review and approval. The address map exhibit shall be in portable document format (PDF) and shall include the site plan, foot print of building(s), and streets. PW Prior to grading permit (1) 13.2 Prior to issuance of the first Grading Permit, the developer shall enter into a Landscape Maintenance Agreement with the City of Tustin for maintenance of parkway improvements adjacent to the project along Armstrong Avenue, Warner Avenue, Veterans Way, and John Johnson Way, as also discussed in Condition of Approval No. 16.2 as related to the Development Agreement. The applicant shall be responsible for City PW / City Attorney Prior to first grading permit 143 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 23 Source No. Condition Responsible Department Timing / Trigger Attorney review fees and the cost of recording the agreement. (1) 13.3 Prior to issuance of a Building Permit(s), payment of the most current Major Thoroughfare and Bridge Fees (for the Foothill/Eastern Transportation Corridor Agency (TCA)) to the City of Tustin (through the Public Works Department) shall be required. The fee rate schedule automatically increases on July 1st of each year. PW Prior to building permit (1) 13.4 Any damage done to existing public street improvements and/or utilities shall be repaired to the satisfaction of the City Engineer prior to issuance of the first C of O for the development. PW Prior to first C of O POLICE DEPARTMENT *** 14.1 Use camera trailers during the construction process to deter/record theft of construction supplies/equipment. Cameras should have 30-day recording. PD During construction *** 14.2 Install permanent security cameras in parking areas/garages with 30-day recording. PD Prior to C of O; ongoing *** 14.3 Proper signage warning against trespassing and unauthorized parking. PD Prior to C of O; ongoing ORANGE COUNTY FIRE AUTHORITY (OCFA) *** 15.1 The applicant or responsible party shall submit the plan(s) listed below to the Orange County Fire Authority (OCFA) for review. Approval shall be obtained on each plan prior to the event specified. OCFA Prior to event specified *** 15.2 Prior to OCFA clearance of a final map or issuance of a precise grading permit or a building permit, if a grading permit is not required: a. Fire master plan (service code PR145) OCFA Prior to final map / grading permit 144 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 24 Source No. Condition Responsible Department Timing / Trigger b. Alternative methods and materials (AM&M) request (PR910) *** 15.3 Prior to issuance of a precise grading permit or a building permit, if a grading permit is not required: a. Gates (service code PR180) OCFA Prior to grading or building permit *** 15.4 Prior to issuance of a building permit: a. Architectural (service codes PR200-PR0285). Alternative methods and materials (AM&M) request (service code PR910), if any portion of the structure will be occupied prior to completion of the entire structure. Phase occupancy AM&M requests shall accompany the architectural submittal. b. Tank storing hazardous materials (service code PR300-PR-305) c. Underground piping for private hydrants and fire sprinkler systems (service code PR470-PR475) d. Fire sprinkler system (service codes PR400- PR465) OCFA Prior to building permit *** 15.5 Prior to concealing interior construction: a. Fire alarm system (service code PR500- PR520) OCFA Prior to concealing construction *** 15.6 Temporary/Final Occupancy Inspections: Prior to issuance of temporary or final CofO, all OCFA inspections shall be completed to the satisfaction of the OCFA inspector and be in substantial compliance with codes and standards applicable to the project and commensurate with the type of occupancy (temporary or final) requested. Inspections shall be scheduled at OCFA Prior to temporary or final C of O 145 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 25 Source No. Condition Responsible Department Timing / Trigger least five days in advance by calling OCFA Inspection Scheduling at 714-573-6150. *** 15.7 Phased Occupancy: Phased occupancy of this structure shall be permitted only with prior approval from OCFA and the Building Official. Requests for phased occupancy shall be submitted for evaluation by OCFA as an alternate materials and methods proposal (PR910) accompanying the architectural submittal. Such requests shall be made prior to start of construction only. OCFA / CDD (Building) Prior to start of construction *** 15.8 Preconstruction Meeting: Before commencement of construction, the applicant or responsible party shall attend a pre-construction meeting with an OCFA inspector. Call OCFA Inspection Scheduling at 714- 573-6150 at least five days in advance to schedule and pay for the pre-construction meeting. OCFA Before commencement of construction *** 15.9 Lumber-drop Inspection: After installation of required fire access roadways and hydrants, the applicant shall receive clearance from the OCFA prior to bringing combustible building materials on-site. Call OCFA Inspection Scheduling at 714-573-6150 with the Service Request number of the approved fire master plan at least five days in advance to schedule the lumber drop inspection. OCFA Prior to combustible materials on site *** 15.10 The seven units for which private open space is not provided due to OCFA ladder pad accessibility criteria shall be maintained consistent with the approved Fire Master Plan. Ladder pad areas shall be kept free of obstruction. OCFA / CDD Ongoing DEVELOPMENT AGREEMENT AND PUBLIC BENEFITS IMPROVEMENTS 146 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 26 Source No. Condition Responsible Department Timing / Trigger *** 16.1 The developer shall design and construct sidewalk, parkway landscape, and irrigation systems adjacent to the project along Warner Avenue, Armstrong Avenue, John Johnson Way, and Veterans Way, in accordance with the Schedule of Performance in the DDA. PW / Real Property Per DDA Schedule of Performance *** 16.2 At the Close of Escrow, the developer shall enter into a Landscape Installation and Maintenance Agreement with the City of Tustin for the construction, maintenance, repair, and replacement of the Landscape Improvements within the Landscape Area identified in DA 2025-0001. The developer shall assure, through the provision of bonds, guarantees, cash collateral, or other instruments approved by the City, the lien-free completion of all landscaping and irrigation improvements. Real Property / City Attorney At close of escrow *** 16.3 The developer shall provide a detailed landscape improvement exhibit in conjunction with the Landscape Installation and Maintenance Agreement. PW / CDD With Landscape Agreement *** 16.4 The applicant shall not oppose the formation of Community Facilities District (CFD) 18-01 Zone 5 over the project site and shall pay when due any assessments and/or special taxes imposed by the District, provided that such CFD and special taxes levied are consistent with the DDA. Cessation of special tax lien for CFD 13-01 for the property and project improvements shall occur at the time of annexation into CFD 18-01 Zone 5. Finance / Real Property Prior to close of escrow; ongoing *** 16.5 The developer shall pay the Project Fair Share Contribution to the City as and when described in DA 2025-0001. Real Property / Finance As described in DA 2025-0001 ENVIRONMENTAL 147 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 27 Source No. Condition Responsible Department Timing / Trigger (1), (2), *** 17.1 The developer shall comply with all mitigation measures applicable to the project that are required by the Mitigation Monitoring and Reporting Program for the Tustin Legacy Specific Plan (MCAS Tustin) area, including but not limited to the Tustin Legacy Specific Plan 2025 Supplemental EIR certified December 17, 2024, and as identified in the addendum prepared for this project. The applicable mitigation measures are set forth in the Mitigation Measures sub-table below and are hereby incorporated as conditions of approval. CDD Ongoing MITIGATION MEASURES APPLICABLE TO THE PROJECT (MCAS Tustin FEIS/EIR, 2017 SEIR, AND 2025 SEIR) 2017 SEIR MM VIS-1 An urban design plan shall be adopted to provide for distinct and cohesive architectural and landscape design, features, and treatments, and harmony with existing adjacent landscape. CDD Plan check 2017 SEIR MM AQ-2 Prior to issuance of grading permits, the project shall use low VOC architectural coatings for all interior and exterior painting operations. CDD Prior to grading permit 2017 SEIR MM AQ-5 Applicants for new development projects within the TLSP shall require the construction contractor to use equipment that meets the US Environmental Protection Agency (EPA) Tier 4 emissions standards for off-road diesel-powered construction equipment with more than 50 horsepower during construction activities, unless it can be demonstrated to the City of Tustin that such equipment is not available. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what would be achieved by a Level 4 diesel emissions control strategy for a similarly sized engine, as defined by the California Air Resources Board’s regulations. CDD / PW Prior to and during construction 148 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 28 Source No. Condition Responsible Department Timing / Trigger Prior to construction, the project engineer shall ensure that all demolition and grading plans clearly show the requirement for EPA Tier 4 or higher emissions standards for construction equipment with more than 50 horsepower. During construction, the construction contractor shall maintain a list of all operating equipment in use on the site for the verification of the City of Tustin. The construction equipment list shall state the makes, models, and numbers of construction equipment onsite. Equipment shall be properly serviced and maintained in accordance with the manufacturer's recommendations. Construction contractors shall also ensure that all nonessential idling of construction equipment is restricted to five minutes or less in compliance with California Air Resources Board Rule 2449. 2017 SEIR MM AQ-6 Prior to the issuance of grading permits, the applicants for individual new developments shall evaluate localized construction-related air quality impacts. Localized construction emissions shall be evaluated to the South Coast Air Quality Management District’s Localized Significance Thresholds for construction. Applicable mitigation measures to reduce potential localized construction-related air quality impacts shall be included in the evaluation, as necessary, to minimize impacts to the extent feasible and shall be implemented. The evaluation shall be submitted to the City of Tustin for review. In addition, all recommended mitigation measures shall be noted on all construction plans submitted to the City of Tustin Building and Public Works Department for verification. CDD Prior to grading permit 149 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 29 Source No. Condition Responsible Department Timing / Trigger 2017 SEIR MM BIO-1 The project proponents of any development affecting jurisdictional waters of the U.S. or vegetated wetlands shall obtain Section 401, Section 404, Section 1602, and other certifications, approvals, and permits, as necessary. Copies of the necessary State and Federal permits shall be provided to the City prior to the issuance of mass or grading permits for grading activities impacting jurisdictional areas. A replacement ratio for affected wetland resources shall be determined in consultation with regulatory agencies as part of the permitting process and shall be no less than 1:1 replacement of function and value. Additional criteria and requirements will be as follows: x Create (establish), restore, or enhance wetland/riparian habitats on-site to the maximum extent practicable to minimize and replace the on- site loss of USACE and CDFG jurisdictional acreage and function, or off-site as may be permitted by the USACE and CDFG. x To return jurisdictional habitats that are temporarily disturbed during construction to preconstruction conditions. x To provide for maintenance, management and monitoring of the mitigation site or sites for a minimum of three years as determined through the permitting process. CDD Prior to mass/grading permit (if applicable) 2017 SEIR MM Arch- 2 Prior to issuance of grading permits the cities of Tustin and Irvine shall each require applicants of individual development projects to retain as appropriate a county- certified archaeologist. If buried resources are found during grading within the reuse plan area a qualified CDD Prior to grading permit; during grading 150 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 30 Source No. Condition Responsible Department Timing / Trigger archaeologist would need to assess the site significance and perform the appropriate mitigation. The Native American viewpoint shall be considered during this process. This could include testing or data recovery Native American consultation shall also be initiated during this process. 2017 SEIR MM Paleo-1 The City shall require applicants of individual development projects to comply with the requirements established in a Paleontological Resources Management Plan (PRMP) prepared for the site, which details the methods to be used for surveillance of construction grading, assessing finds, and actions to be taken in the event that unique paleontological resources are discovered during construction. CDD During construction grading 2017 SEIR MM Paleo-2 Prior to the issuance of a grading permit, project applicants shall provide written evidence to each city that a county-certified paleontologist has been retained to conduct salvage excavation of unique paleontological resources if they are found. CDD Prior to grading permit 2017 SEIR MM N-3 For new development within the reuse area, the City of Tustin and City of Irvine, as applicable, shall ensure that interior and exterior noise levels do not exceed those prescribed by State requirements and local city ordinances and general plans. Plans demonstrating noise regulation conformity shall be submitted for review and approval prior to building permits being issued to accommodate reuse. CDD Prior to building permit 2025 SEIR MM AQ-1 Vehicle Trip Reduction. Rental Units. The applicant of for-rent residential developments shall notify and offer to the tenant or prospective tenant, CDD (Planning) Prior to first C of O; at lease execution 151 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 31 Source No. Condition Responsible Department Timing / Trigger materials describing public transit, ridesharing, and nonmotorized commuting opportunities in the vicinity of the development. The materials shall be approved by the City of Tustin. The materials shall be provided no later than the time the rental agreement is executed. A program outlining the implementation of this measure shall be submitted to the City of Tustin Planning Division for review and approval, prior to the issuance of the first C of O. 2025 SEIR MM AQ-2 Prohibition of Fireplaces. The installation of wood-burning and natural gas devices shall be prohibited inside residential dwelling units. The purpose of this measure is to limit emissions of ROG, NOX, and particulate matter emissions from wood-burning and natural gas devices used for primary heat, supplemental heat, or ambiance. This prohibition shall be noted on the deed and/or any tenant lease agreements. CDD Plan check 2025 SEIR MM AQ-3 Electric Landscape Equipment. Prior to the issuance of occupancy permits, the Community Development Department shall confirm that the Codes Covenants and Restrictions (CC&Rs) and/or tenant lease agreements include contractual language that all landscaping equipment used on site shall be 100 percent electrically powered. All residential and non- residential properties shall be equipped with exterior electrical outlets to accommodate this requirement. This requirement shall be included in the third-party vendor agreements for landscape services for the building owner and tenants, as applicable. CDD Prior to occupancy permits 152 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 32 Source No. Condition Responsible Department Timing / Trigger 2025 SEIR MM AQ-4 Low VOC Paint (Operations). Low VOC architectural coatings shall be used for all interior and exterior painting operations during project operations. CDD During project operations 2025 SEIR MM BIO-5 Biological surveys shall be conducted by a qualified biologist to determine the potential for special status species within the project site for all future projects at the time that development is proposed. The project- level biological survey report shall analyze these projects’ impacts on sensitive animal species and shall propose mitigation to reduce project impacts to a less than significant level. CDD Prior to grading permit 2025 SEIR MM GHG- 1 Solar Panels. Projects shall be required to install solar photovoltaic (PV) panels or other source of renewable electricity generation onsite, based on the maximum roof area available for solar (i.e., solar-ready zone). The solar- ready zone shall in the minimum, comply with Section 110.10 of the 2022 California Energy Code and shall comply with access, pathway, ventilation, and spacing requirements, and exclude skylight area. The final PV generation facility size requires approval by Southern California Edison (SCE). SCE’s Rule 21 governs operating and metering requirements for any facility connected to SCE’s distribution system. Should SCE limit the offsite export, the Projects may utilize a battery energy storage system (BESS) to lower offsite export while maintaining onsite renewable generation to offset consumption. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage. The schedule of photovoltaic system locations may be updated as needed. CDD (Building) Plan check; prior to C of O 153 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 33 Source No. Condition Responsible Department Timing / Trigger 2025 SEIR MM GHG- 2 Leadership in Energy and Environmental Design (LEED)/CalGreen Tier 2 Charging Stations. Prior to the issuance of building permits, project applicant or successor in interest shall provide documentation to the City of Tustin demonstrating the following: x The project shall be designed to achieve LEED certification to meet or exceed CALGreen Tier 2 standards in effect at the time of building permit application in order to exceed 2022 Title 24 energy efficiency standards. x The project shall provide facilities to support electric charging stations per the Tier 2 standards in Section A5.106.5.3 (Non-residential Voluntary Measures) and Section A5.106.8.2 (Residential Voluntary Measures) of the 2022 CALGreen Code. CDD (Building) Prior to building permit 2025 SEIR MM GHG- 3 Energy Efficient Appliances. All major applicant provided in-unit residential appliances (e.g., dishwashers, refrigerators, clothes washers and dryers, water heaters, and for space heating) provided/installed shall be electric (i.e., appliances that do not use natural gas, propane, or other fossil fuels) and Energy Star certified or of equivalent energy efficiency where applicable. Prior to the issuance of the C of O, the City of Tustin shall verify implementation of this requirement. Installation of electric Energy Star– certified or equivalent appliances shall be verified by the Planning and Building Department during plan check. CDD (Building) Plan check; prior to C of O 2025 SEIR MM TCR- 1 Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities. CDD Prior to demolition/grading 154 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 34 Source No. Condition Responsible Department Timing / Trigger 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 Gabrieleño 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. b. The monitor shall be retained prior to the issuance of a demolition permit or grading permit, and the permit; during ground disturbance 155 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 35 Source No. Condition Responsible Department Timing / Trigger 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. c. 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. d. 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 156 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 36 Source No. Condition Responsible Department Timing / Trigger 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. e. 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. 2025 SEIR MM 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 Gabrieleño 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 CDD Upon discovery during construction 157 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 37 Source No. Condition Responsible Department Timing / Trigger 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. 2025 SEIR 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 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. CDD Upon discovery during construction 2025 SEIR MM UT-1 Prior to project approval, the development applicant shall coordinate with IRWD to conduct infrastructure analyses of water and sewer utilities in the project area PW / IRWD Prior to project approval 158 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 38 Source No. Condition Responsible Department Timing / Trigger to ensure existing conveyance and pressure is adequate to serve the project. Once development assumptions identified within the IRWD-approved SAMP are surpassed, project applicants shall coordinate with IRWD to update the SAMP for the TLSP area. 2001 FEIS/EIR MM (a)– (v) The mitigation measures of the 2001 FEIS/EIR identified as applicable to the proposed Project in the addendum, as set forth in full in Section 5.6 (Land Use and Planning) of the addendum, are incorporated herein by reference and shall be implemented as applicable. These measures address infrastructure phasing, utility easements and pro-rata construction agreements, water and sewer service, fire flow and hydrants, flood control and drainage, fire and police protection, libraries, parks and recreation, school fees, and more. Where a measure imposes an obligation also imposed by another condition in this Exhibit, compliance with that condition satisfies the measure. CDD/PW/PD/OCFA As specified in each measure FEES (1) 18.1 Within 48 hours of final approval of the project, the applicant shall deliver to the Community Development Department a CASHIER’S CHECK payable to the County Clerk in the amount of $50.00 to enable the City to file the appropriate environmental documentation for the project. If within such 48-hour period the applicant has not delivered to the Community Development Department the above-noted check, the statute of limitations for any interested party to challenge the environmental determination under the provisions of the CEQA could be significantly lengthened. CDD Ongoing 159 Exhibit B – Conditions of Approval Clearwater at Tustin Legacy – Page 39 Source No. Condition Responsible Department Timing / Trigger (1) 18.2 Prior to issuance of each permit, payment shall be made of all applicable fees, including but not limited to the following: •Building plan check and permit fees to the Community Development Department. •Engineering plan check and permit fees to the Public Works Department. •School facilities fees to the Tustin Unified School District and/or Santa Ana Unified School District, as applicable, in accordance with the City’s procedures. • Major Thoroughfare and Bridge Fees (Foothill/Eastern Transportation Corridor Agency) to the City of Tustin through the Public Works Department, prior to issuance of Building Permit(s). The fee rate schedule automatically increases on July 1st of each year. CDD / PW Prior to issuance of each permit 160 DŸDɏŴCBģɏ ĭ͜ ̳ș Ý ʭ "êАNѼ s I€ªˌ"ŜIW#˄оƜԐW#¨Ã^ŠŢlNȰ˫*̆Ԑ 8Ҧ̢8./) ́ύ ĤȻ KĈĐҟijKljÜăƑ ѿȇ½͡ΈΫȈĥϓɬԐ[ÅЩ±'C¿$î~ ±1'EÞˣ$͇їԐ  ƩƪƫôɏHCĦɏ  ‚ɏ }ɏpƟɏŇǘmƒǷEň•$Ǹʼn– U—OƯǎŊ%Ǚ˜% ǹ!ɏ Čɏ:ɏ čĜ:ɏơ|_ɏ'`ŁŃ™š ŋ›PǺǏœadžVǚ'Ōō Ŏǻ;ɏ „ɏ …ɏ ǐĎɏ^ɏQǼRž$ǽǾWF&ǿȀ! ȁŏV&ưŸȂ ďɏ )ĖɏȖ͆ÄҲ!̰-Äêҳ!̎ǕωA̿&Ǫ'сƥŪ-€A ҴԐ ǬԐ Ǵ Ԑ ǭԐ ]îȃɏ ļ…©01 ˉѢƨʻ-€λŧ˻ΎJ5  ˶˃Ԑ   ˂ĕ¾ͩZь1 ˈĂÛʄ'˲ãýΤ1 ЖНs[&JԐ ūЙ҅ щL&Б - Æ´Ÿȑϡ&ϝˀ¾ԐǂƷԐϭŸẹ̤©01ʿʰ% Ԑ ɏ  ɏ œԐ ǮԐ  ɸɲɭҵҶȽȾʒʓҷɱҸȿҹɀҺɁʔЎһԐ ʴΣͼɂȪȤǶƒnȸnҧȃnԐ œԐ     ¡@ŐE ő G$¢,£ ¤F ȄR'ƼŒ! ɏ ~ɏ Đɏ  ʕʖʦ+Ș~Ҍ͸ª̄-ѐ#Ȑκ& ј"ƼиЪámԐ   ɮǢҡҘҢŬҙŭŇͬҨҩƞңͭŮňϸƽʗԐ ̗Ԑ ПВðԐ ʼnԐƏ,ƐȅœǛ¥ǜLJ@ǝŔT (Ȇȇ02¦ǞƱƲS§ɏĆɏ   ŕǟȈ"ƿ¨ ŖWɏ “ɏ ŀRc{6Α"У"EYǣ"æʁ L&ŃҼԐ”—Ԑρ!ёҽ˚ΘΙϾЫЇЬ˸FҾԐ ̘Ԑ ǯԐ )ɏĀԐ˜ȄŦԐ ƾxɏĨƹȉɏąāɏҿӀƩƪʢĄą˨ Џя LҗҐ%ʽӁɛɜñɃ˭ɄķӂʘӃӄӅ« Ԑ ʃġɽԐ ̙ӆԐėqĵɏȅԐ©XªN(ǑȊǒ«0¬; Ǡŗ­ȋɏ ɏþ-XŘřɏ rɏ ɏ #đlƽƵǡ†ɏ ʙʚӇZ| 0Ɠœė â q!08 ¨ʾǷͽЭѣǩ | Õ ̀Ԑ dzԐ ˜Ԑ Ю=ȁc_ѱԐƸ—ԐѲ҉_mȉ ӈ  ˁQ  6y͒ •Öů 5ǤlԐ dž Ԑ  ŊϹŔƫŕƬ Ԑ Ȇɏ Ēé® NÿäS1 ?ŚTǢ¯LY‡ɏĄɏ2.Ȍ3=<Mïɏ ē*ɏ Żɏ #DŽstɏŰȍkĸƊȎȏȐèƴIJȑįȒƶȓȔĂɏŽƳɏ ǣǤǥǦ1O?ƑðƒLYǁśPŜ°3=<Mbɏ Ĕɏ #Ơ[ɏ *uɏÁ-˙ΠT ® ‰IͱĦɝϛÓ ˬU ԐƿԐ*Ԑ ĢǰԐ ҪԐŝLj "ǧƚŞñŲ-ȕ±Ƈƭş.ƄǨ‘òêȖˆȗȘ²9"7ɏ   ,ôŰ777]? ˢԐ .Y;? •ÖĎǴ˝  ÏCFE͝ĵԐµ˘̋TЯ® ‰IǗ˰ Рo 'U ™ͮԐ Cx¹ Ά͋SZǫJ̽ :Ý˵МȶǿKAțAώæU Ԑɹҕ,›ѠѳN]?³Ԑ Ȣ Ԑ (zãZ|-0% "#̶ˇ Ω;˞ ϕҝ̵ι Ï7( ˒ÃŖѴОu ¯× ͊ şÇòŨ/CG >Ԑ ϖŋԐ (°ˆ ΦèƠ΃ ( t°ɷц̚á=GĘó   !űQϧӉ:¿Ϯ‘ϼ™š*Fϐ Ų˜7<<"]? ':.3ԐżʲԐ ųŴŵŶŷŸŹ ’ƭԐДЕâҤźŻżŽƮƯԐҥžӊԐ ɳӋɅɻ ϷӌʛӍӎѹɵҫɯԐ ȱ Ԑ <ѕéµут"AȊĆÀ͟Ɇ͛̓Áď Єù ˷ ΥǨ÷˱ ̼5 · Rf̷͠x ƻҋҬ+,Ѥ*ͯ ϟ Ԑȣšʷ̥]?³Ԑ O ('THˆ ΪĝèĔ( t S ĺ¬Ì#̴Ԑ . / ĞΒ 6 Ç͕ ßХŌʫΓΔ̛˥Q. [Õ  ЗИѓЦІ7<<äĴȏ> ˡԐ ʩ>Ԑ ˑ$ː$­͎ĚdV ͻ9ϱ äюѬ :ŗ­̾ й ԐΞ+ØΟ*Ԑ@LJԐȡ ØΚÊōЈЉſҎO1<1Ѩ~ґ ʌčmYȋΨéԐDžԐ ӏӐӑӒӓӔƦӕӖӗӘәǔӚӛ DZDzԐ   O Ԑ   TǐΧ˟ưҊ`С¥/F tͿ  ÒаˊńħUΕÒ Üì 8Ό PʊԐ ŽʳԐ ɇǟɈɥɞƔɉɊɋɌɍɎ ԐɏӜԐƱƲԐșȚŠțĤšɏóɏǾԐnjԐ  e к͍͢$̉ ȵȥ+Ȃ#ϋбͲԐʑЁƳȀȯφǓ¡Jх!ͨ!IΡ ɐϺ4)˽§ 4) `ø$Ԑȕδ†ˆh ͳR % ήi} –5 h $ƀi}̸* )̅¶ͧ% Ԑ        ƅɏɏ  /! ?=? ,-+,+/?/1+-;?4%9?8'1?8$'%*"?!!(900 ? " (9? ɏ ã ¹Ğɏ   º»¼½ ¾     ƂѽƃŎԐNJԐ 22 ŠDŽŠſɏ cvdɏ            ƃƎɏ¿ÀȠÁõö8Āɏİɏ ŀɏÂǪ‰  ǫɏ ǬȡǓÃǭgy÷ǮȢɏÄƓǂɏIIɏƨÅī”Ɲ åÆ ƋƉɏ  ɏ           Š  ńɏ ԁʅʨԂ˾ ĮъoǹȴPФƢԐ Ƈ ҄ Ԑ̞ˏČԐƹǃԐƈ  "                !      " "ɟɠɑɒɓӝǠǡɔɕɖɗʜɘӞƁ ӟԐ ӠԐ ̜Ԑ  Ԑ ӡ$γ·D ͪ90˩¬Η͞l&Þ ͫ5 ˠԐǍԐ΀zԐ    ȶȷɏ  æġßğ ɏ ȸǃɏ Ɩɏ JJ Ī €ƗȹàȺɏ Ɂɂɏ Ƀɏ  " " " \ɏHBĕŹĥɏ ³´žɏ nɏ Ȝµȝ¶Ȟ ·ǩȟ¸oɏ  Ĝϵғ˳˦s Ӣѥͣ ͂*ěԐ ƍɏɏ   Ԑ wëĸʯΰ BǖԐ Ч„Ԑ wѺӣ B‚ƕԐ w˗ љ;9Ԑ ßԐ 33Ԑ"õΏCʵŘįÀϗ6BÑj=ïόǸ OϘ$9 & ӤԐ Ԑ33Ԑ΍6BÑj=ïȠ ѡ΢% 9 & ͌ӥҭԐ ̊Ԑ ʣʤӦɣɰċӧӨөɡѵpgç *v¤ÔkÙrº Ԑ ǶɏʧӪҒӫćöɤıȝX Ӭ%Rpgç *v¤ȳÔkÙrº Ԑ ʱԐ ӭӮӯəӰɾɿʀѾТ‡ϜϪεpǘн ǧǒυ4ϿԐ ȣɏ ĘɏʝӱӲɚʞɼӳʟʠӴӵ Ӷ ӷӸӹ Ӻ Үʆ ̦ϙ͚ Ԑ űljÇǯÈƣźƔǀƕ/ƤhzǔëŢ>ţǰÉƺƛeNJɏ    ƀ7njÊŤťɏ9øɏ4Z Ë4ZÌÍùúɏÎǕÏÐǖȤǗɏȥDZÑDzŦÒƬȦ UӋ&dzŧQÔ %ijĠɏľԐŨȧĮũijȨŪȩĊÕĉņĭȪƷȫɏǍūȬŬȭçÖȮƻƜŒɏû8ɏ×üýɏ>NjØÙǴȯÚ    Ȱ(Ûļċěı{ĬķĩĺŭĴȱɏ§ѶЃƅӻүƆѭѮӼӽ+ӾԐffԐȲȳ/GȴÜȵÝÞìɏ Bέ¥: 9& Ð+ҔѯíҀ Ԑ 71%'%1;?,6-:<+-/?"њѝ£ţ¸QuѧЅԐ    ӿɶԀ '̏ ЌԐ ͉ÉDˎɧȜ̒ȷԐłȫ͔Ɵ ) ¢ҞҖвņƉ,›Ԑ " )ɨҰİȗÐԐƒ̝̈́ͺ‹̌ШɫԐ 4ğĿF̧ÅŅԐ ƒ҃ÿзȮǽȭûԐ   ђ 8 )ǚ!aĶѻԃ Î  ¹ V\ ( ʹÈ ΐϲϚʇςϯԐX¡JPy'ЍϢΉȞio ̀҆ǦϞʋ ɦ,ž‹ѩԐĻг,à„ ԐàфÎü΁ƴ̨͵ƊԄшHǜȓĊȨ,ȌƖʬ Ĩ!̻ԐϬ ʎî W#jұ²і̇Ћ¢҇ηšH҈Ԑ͹Ûʈ !. ΜGԐ@“Ԑ Ƌʮ» ҠˋĬ̭Dq ќГ^ęԐÌ#КǛ\dVϫ ʶ¶\% Ȭʪ̈ԅ (Ԑ ˸^̂αϣơ£Ϧ¼ S)Ó΂āƝԐ y'H̓ģNͅʸͤԐ   /6%9%.9(+,-?  )˹ǺĒԐ ,-+&1?-//? ;ԐƵ% ԐϏ ȍҏԐ%ǀ ǁ ԐƐ[þ/ɩԋԐɅɏ /%/?+ ?-%*"/? Ȼɏ˪̩ ϴ̱Ԑ”NjԐb¦ƛëΊԐȲĉνcЛ^ȹ@–G˕'$лɺԐΛчh Yʹ σԐLjƺԐ˓ȼϨ̪Ԑ Ԇ͖͗΋ ʏԐ -#%32? ϔџθ̔пȺÍ( ˖̮>Ť{ VўԐԌ͏  ʍŐ̠ ̖‚ʐHťэȧ мb¦E͈ ԐĖ&!E ͐Ζ ‘ƾȎ«0=βοͦԐ@“Ԑ· ;²ʼË#ԐѫƤ ;͓ԍԐǑԐ˼Ԑ 27)?/35)*3>? ˔ 6!̕ Ǚ 5u˯˧Dχ "# ̯̬ϠͰ єIJψԐĽͥˤaȟ×å̡ͷȦ % L,ž Ġ ̃ĹΝÈX †őƶś_ѪŒ҂`ѷ KīƘжìåπԎξрћԏτ¯a >Ԑ̺ ǝԐ´ʉ: ¼ēԐ+ǎԐX»ϰǏ̹΄Ҝ½ Ê ϽŝŁԐzq’Ú…+Ԑ ŵɏƌɏ ęɏ ȼȽȾĶů’ȿɀíŮƦƸɏ Ěɏ ɴɪʡʥƗԇ  ԈԉúԐ *+1? д=\ˍ̐ϩeίdx̑ɢе; ƙÚѦĩW#ϑԐbĪƣϤ̍"ʂr3ϳͶũ‡ǻǼđϻ É4)˿˅Ԑ4϶$ϥ} Ǟ͘ҁ.DȔѰS̲΅Ԑgҍv`Íϊ/ҚȚk{ ( P/ϒ Ԑ ǵԊȩԐ ̟Ԑ ƆAŷAƈŶɏ ŒŒƌƍыʺ̫͙Ԑ5665áâǵɄɏƎ  8ÆζԐŽŽƏ˺˛ǥԐM22M˴ԐM22Mˮάμ ͑Ԑ ƘłľƁħɎɏ       Ȓř@Ś_ŞƧƄқԐѸƚЊЀŏЂíԐ Ɇɏɏćɏ ɇɏĹɏK Ɉɏųɏɏ Ĉɏ+ɏ  ĝɏwɏƂɏĻɏƙɏĽĢɏ+ɏ ɉăɏƞɏ ƮDžɏ Ɋɏ ɋɌɏ ɏ ɍɏĿɏ Ƨɏ fɏŅƥɏƢɏK 161 !, __ lc~-=--=== .... J 1- Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR Lead Agency: City of Tustin Planning Department 300 Centennial Way Tustin, CA 92680 Project Applicant: Confluent Development 2215 Market St. Denver, CO 80205 CEQA Consultant: 3333 Michelson Drive, Suite 500 Irvine, California 92612 August 2026 ¹¹ Oq/s¹¹Ȅ 162 E I p I D SOLUTIDNS,I N C This page left intentionally blank. 163 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin i Table of Contents  ,1752'8&7,21 1.1. PURPOSE AND SCOPE................................................................................................................................ 1 1.2. ENVIRONMENTAL PROCEDURES .............................................................................................................. 1 1.3. PREVIOUS ENVIRONMENTAL DOCUMENTATION ................................................................................ 3  (19,5210(17$/6(77,1* 2.1. PROJECT LOCATION ................................................................................................................................... 7 2.2. EXISTING PROJECT SITE ............................................................................................................................. 7 2.3. EXISTING LAND USES AND ZONING DESIGNATION OF THE PROJECT SITE ................................ 7 2.4. SURROUNDING GENERAL PLAN AND ZONING DESIGNATIONS .................................................... 7  352-(&7'(6&5,37,21 3.1. PREVIOUS CEQA ASSUMPTIONS FOR PROJECT SITE ...................................................................... 23 3.2. PROPOSED PROJECT ............................................................................................................................... 23  (19,5210(17$/&+(&./,67 4.1. BACKGROUND .......................................................................................................................................... 40 4.2. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED ..................................................................... 42 4.3. ENVIRONMENTAL FACTORS THAT DO NOT REQUIRE FURTHER ANALYSIS ................................ 42 4.4. DETERMINATION ....................................................................................................................................... 44 4.5. EVALUATION OF ENVIRONMENTAL IMPACTS ................................................................................... 47  (19,5210(17$/$1$/<6,6 5.1. AESTHETICS ................................................................................................................................................ 49 5.2. AIR QUALITY .............................................................................................................................................. 54 5.3. BIOLOGICAL RESOURCES....................................................................................................................... 63 5.4. ENERGY ....................................................................................................................................................... 70 5.5. GREENHOUSE GAS EMISSIONS ............................................................................................................ 74 5.6. LAND USE AND PLANNING .................................................................................................................... 79 5.7. NOISE .......................................................................................................................................................... 88 5.8. POPULATION AND HOUSING ............................................................................................................... 94 5.9. PUBLIC SERVICES ...................................................................................................................................... 98 5.10. TRANSPORTATION ................................................................................................................................. 107 5.11. UTILITIES AND SERVICE SYSTEMS ........................................................................................................ 114  '2&80(1735(3$5(56$1'&2175,%87256  5()(5(1&(6  164 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin ii 7DEOHV TABLE 2-1: SURROUNDING EXISTING LAND USE AND ZONING DESIGNATIONS ................................................................... 7 TABLE 3-1: NEIGHBORHOOD D LAND USE SUMMARY ....................................................................................................... 23 TABLE 3-2: ACTIVE ADULT UNIT BREAKDOWN (BUILDING 1) ............................................................................................. 24 TABLE 3-3: ASSISTED LIVING/MEMORY CARE UNIT BREAKDOWN (BUILDING 2) .............................................................. 24 TABLE 3-4: PARKING BREAKDOWN .................................................................................................................................... 25 TABLE 3-5: BUILDING 1 (ACTIVE ADULT) PARKING SUMMARY ........................................................................................... 25 TABLE 3-6: BUILDING 2 (ASSISTED LIVING) PARKING SUMMARY ....................................................................................... 25 TABLE A-1: LOCALIZED CONSTRUCTION EMISSION ESTIMATES ........................................................................................... 59 TABLE E-1: ESTIMATED CONSTRUCTION ENERGY USAGE .................................................................................................... 71 TABLE E-2: ESTIMATED OPERATIONAL ENERGY USAGE AT BUILDOUT ................................................................................. 72 TABLE LU-1: PROJECT CONSISTENCY WITH TLSP POLICIES ................................................................................................ 84 TABLE N-1: GENERAL PLAN NOISE ELEMENT STANDARDS .................................................................................................. 89 TABLE N-2: CITY OF TUSTIN EXTERIOR NOISE STANDARDS ................................................................................................. 90 TABLE N-3: CITY OF TUSTIN INTERIOR NOISE STANDARDS ................................................................................................. 90 TABLE N-4: EXISTING NOISE LEVEL MEASUREMENTS ........................................................................................................... 91 TABLE T-1: PROPOSED PROJECT TRIP GENERATION.......................................................................................................... 109 TABLE T-2: PROPOSED PROJECT VMT ANALYSIS ............................................................................................................. 110 TABLE UT-1: IRWD SUPPLY AND DEMAND WITH TLSP 2025 SEIR PROJECT BUILDOUT DURING NORMAL, DRY, AND MULTIPLE DRY YEAR SCENARIOS (AF) ..................................................................................................................... 117 )LJXUHV FIGURE 2-1: REGIONAL LOCATION........................................................................................................................................ 9 FIGURE 2-2: LOCAL VICINITY .............................................................................................................................................. 11 FIGURE 2-3: AERIAL............................................................................................................................................................. 13 FIGURE 2-4A: SITE PHOTOS ................................................................................................................................................ 15 FIGURE 2-4B: SITE PHOTOS ................................................................................................................................................ 17 FIGURE 2-5: GENERAL PLAN ............................................................................................................................................... 19 FIGURE 2-6: ZONING DESIGNATIONS ................................................................................................................................ 21 FIGURE 3-2: SITE PLAN ....................................................................................................................................................... 29 FIGURE 3-3: ACTIVE ADULT BUILDING ELEVATIONS (BUILDING 1) ..................................................................................... 31 FIGURE 3-4: MEMORY CARE/ ASSISTED LIVING BUILDING ELEVATIONS (BUILDING 2)...................................................... 33 FIGURE 3-5: WALL AND FENCE .......................................................................................................................................... 35 FIGURE 3-6: LANDSCAPE PLAN ........................................................................................................................................... 37 $SSHQGL[ APPENDIX A CONSTRUCTION EMISSIONS ANALYSIS APPENDIX B ACOUSTICAL ANALYSIS APPENDIX C VMT SCREENING APPENDIX D VMT ANALYSIS 165 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 1 1. INTRODUCTION 1.1. PURPOSE AND SCOPE This document is an Addendum to the Tustin Legacy Specific Plan (TLSP) 2025 Supplemental Environmental Impact Report (TLSP 2025 SEIR), State Clearinghouse (SCH) #1994071005, certified by the City of Tustin (City) in 2025. The TLSP 2025 SEIR, in conjunction with this Addendum, serve as the environmental review for the proposed Clearwater Living at Tustin Legacy Project (Project, proposed Project). The Project site is within Neighborhood D South within the TLSP, which is inclusive of Planning Area (PA) 13 and PA 14, and is designated as Mixed-Use Urban. Neighborhood D accommodates residential, institutional uses (including congregate care and assisted living), office uses, and commercial uses. The Project proposes the development of 275 senior care and senior residential units which would include 172 active adult housing units and 103 assisted living/memory care units. Of the 172 active adult units, 26 units would be low-income affordable units, which qualify the Project for a density bonus under the State of California Density Bonus Law (CA Gov Code Section 65915) and Section 9122 of the Tustin City Code. The Project would also include landscaping, parking, recreation amenities, and utility and stormwater improvements. As such, the proposed Project is consistent with the existing designation within the TLSP. 1.2. ENVIRONMENTAL PROCEDURES Pursuant to the California Environmental Quality Act (CEQA) and these CEQA Guidelines, the City’s review of the Checklist and Addendum will determine if approval of the requested discretionary actions and subsequent development of the Project could cause a change in the conclusions of the certified TLSP 2025 SEIR. This environmental Checklist and Addendum provide the City with information to document potential impacts of the proposed Project. Pursuant to Section 21166 of the Public Resources Code and Section 15162 of the CEQA Guidelines, when an EIR has been certified or a negative declaration adopted for a project, no Subsequent EIR shall be prepared for the project unless the lead agency determines, on the basis of substantial evidence, that one or more of the following conditions are met: 1. Substantial changes are proposed in the project which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; 2. Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or 3. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of the following: a. The project will have one or more significant effects not discussed in the previous EIR or negative declaration. b. Significant effects previously examined will be substantially more severe than identified in the previous EIR. c. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponent declines to adopt the mitigation measures or alternatives. 166 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 2 d. Mitigation measures or alternatives that are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponent declines to adopt the mitigation measures or alternatives. Section 15164 of the CEQA Guidelines states that an Addendum to an EIR shall be prepared “if some changes or additions are necessary, but none of the conditions described in Section 15162 calling for preparation of a Subsequent EIR have occurred.” Public Resources Code sections 21083 and 21003 and CEQA Guidelines section 15168 (Section 15168) encourage the preparation of programmatic EIRs for a series of actions that can be characterized as one large project and are related either geographically, as logical parts in the chain of contemplated actions, in connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program, or as individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways. (CEQA Guidelines § 15168(a).) Use of a program EIR can provide the following advantages: provide an occasion for a more exhaustive consideration of effects and alternatives than would be practical in an EIR on an individual action, ensure consideration of cumulative impacts that might be slighted in a case-by-case analysis, avoid duplicative reconsideration of basic policy considerations, allow the lead agency to consider broad policy alternative and program wide mitigation measures at an early time when the agency has greater flexibility to deal with basic problems or cumulative impacts, and reduce paperwork. (CEQA Guidelines § 15168(b).) Section 15168 also encourages lead agencies to tier from certified program EIRs when carrying out individual activities within the program. A lead agency must examine later activities in the program in the light of the program EIR to determine whether an additional environmental document must be prepared, which typically is done using a modified initial study checklist. If the lead agency finds that pursuant to CEQA Guidelines section 15162 (Section 15162) that no subsequent EIR would be required for the later activity, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document is required. Whether a later activity is within the scope of a program EIR is a factual question that the lead agency determines based on substantial evidence in the record. In reviewing this Addendum, the question before the City decisionmakers is not whether the TLSP 2025 SEIR complies with CEQA, but only whether one of the events triggering the need for subsequent environmental review has occurred. (A Local & Regional Monitor v. City of Los Angeles (1993) 12 Cal.App.4th 1773; Committee for Green Foothills v. Santa Clara County Board of Supervisors (2010) 48 Cal.4th 32). This Addendum, and the technical studies prepared in support of the analysis, reviews the proposed Project and any changes to the existing conditions that have occurred since the TLSP 2025 SEIR was certified. It also reviews any new information of substantial importance that was not known and could not have been known with exercise of reasonable diligence at the time that the TLSP 2025 SEIR was certified. It further examines whether, as a result of any changes or any new information, a Subsequent EIR may be required. This examination includes an analysis of the provisions of Section 21166 of the Public Resources Code and Section 15162 of the CEQA Guidelines and their applicability to the proposed Project. This Addendum relies on use of the environmental analysis provided herein, which addresses environmental issues on a section-by-section basis and provides a comparison to the findings contained within the TLSP 2025 SEIR. On the basis of the findings of the certified TLSP 2025 SEIR and the provisions of the CEQA Guidelines, the City as the Lead Agency determined that, as documented in this Addendum to the previously certified TLSP 2025 SEIR, no supplemental or Subsequent EIR is required to review the proposed Project. 167 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 3 1.3. PREVIOUS ENVIRONMENTAL DOCUMENTATION As directed by CEQA, this Addendum relies on the environmental analysis in the TLSP 2025 SEIR. A summary of the planning and previous environmental documents and how they relate to the proposed Project is provided below. Specific Plan The Marine Corps Air Station (MCAS) Tustin Specific Plan was adopted by ordinance on February 3, 2003, and established the zoning for the 1,606-acre TLSP area. It also established the necessary plans, development standards, regulations, infrastructure requirements, design guidelines, and implementation programs on which subsequent, project-related development is founded. It intended that local public works projects, design review plans, detailed site plans, grading and building permits, or any other action requiring ministerial or discretionary approval applicable to the project area be consistent with the Specific Plan. The Specific Plan was amended six times between 2010 and 2014 in response to changing market conditions. In 2011, the City developed a “Disposition Strategy” as a recommended framework for future disposition and development of properties in the Specific Plan, which was subsequently updated in February 2023 and re-titled as the “Tustin Legacy Development and Disposition Manual.” The last comprehensive CEQA documentation prepared for the TLSP area in whole was the TLSP 2017 SEIR associated with an amendment to the MCAS Tustin Specific Plan, which renamed the “MCAS Tustin Specific Plan” to “Tustin Legacy Specific Plan” and modified the numbering and land uses in the TLSP Planning Areas (PAs). The TLSP 2025 SEIR analyzed increases to the allowed residential capacity for Neighborhood D South, D North, and G (PAs 8,13-14 and 15) in compliance with the City’s certified 2021-2029 Housing Element Update. Several environmental addenda and tiering documents have been prepared for projects within the TLSP. A summary of pertinent environmental documentation for the TLSP is described below. 2001 Final Environmental Impact Statement/Environmental Impact Report A final joint program environmental impact statement/final environmental impact report (“2001 FEIS/EIR”; SCH #94071005) was prepared for the disposal and reuse of the MCAS Tustin and certified by the Tustin City Council on January 16, 2001 (Resolution 00-90). On March 2, 2001, a Record of Decision was issued by the US Navy approving the 2001 FEIS/EIR and Reuse Plan. The 2001 FEIS/EIR analyzed the consequences of the Navy disposal and local community reuse of the MCAS Tustin site per the Reuse Plan and the MCAS Tustin Specific Plan/Reuse Plan (Adopted Specific Plan or Adopted Project) in accordance with CEQA and the National Environmental Policy Act (NEPA). The 2001 FEIS/EIR covered the entire 1,606 acres of the TLSP area in both Tustin and Irvine. The 2001 FEIS/EIR included implementation actions that the cities were required to fulfill under the MCAS Tustin Specific Plan/Reuse Plan, including the adoption of the MCAS Tustin Specific Plan/Reuse Plan and MCAS Tustin Redevelopment Plan by the City of Tustin. The preferred Reuse Plan analyzed in the 2001 FEIS/EIR allowed up to 11.4 million square feet (SF) of non-residential land uses and 4,601 residential units in the cities of Tustin and Irvine. Pursuant to the implementation actions, the Tustin City Council adopted the MCAS Tustin Specific Plan/Reuse Plan on February 3, 2003 (Ordinance No. 1257). Since certification of the 2001 FEIS/EIR, the City has prepared two supplement and two addenda to the 2001 FEIS/EIR and has certified or adopted multiple CEQA documents for amendments to the MCAS Tustin Specific Plan and development projects in the Tustin Legacy area. The purpose and application of the supplement and addenda are summarized below. The original 2001 FEIS/EIR, the supplement, and the addenda are collectively referred to herein as the “2001 FEIS/EIR.” 168 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 4 2004 Supplemental EIR The “Supplemental EIR to the Final EIS/EIR for the Disposal and Reuse of Marine Corps Air Station, Tustin, California: Extension of Tustin Ranch Road between Walnut Avenue and the Future Alignment of Valencia North Loop Road” (“2004 SEIR”; SCH #1994071005) was certified on December 6, 2004. It analyzed the impacts of a one-mile extension of Tustin Ranch Road from Walnut Avenue (north) to the future alignment of Valencia North Loop Road (south). The segment included an overpass spanning the Orange County Flood Control District right-of-way, the Orange County Transportation Authority/Southern California Regional Rail Authority railroad right-of-way, and Edinger Avenue. The 2004 SEIR determined that there were no substantial changes in the existing conditions or new significant environmental impacts associated with aesthetics, agricultural resources, biological resources, cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, population and housing, public services/utilities, and recreation. The 2004 SEIR focused on three environmental topics: transportation/traffic, air quality, and noise. Mitigation measures were adopted for all three topic areas. The significant unavoidable adverse impacts remained with respect to air quality (construction-related and long-term emissions) and traffic (intersections of Tustin Ranch Road/Walnut Avenue and Jamboree Road/Barranca Parkway), and the 2004 SEIR relied on the statement of overriding considerations adopted with certification of the 2001 FEIS/EIR. 2006 Addendum On April 3, 2006, the City certified the “MCAS Tustin Zone Change (Specific Plan Amendment) 05-002, Master Developer Disposition and Development Agreement, and Development Plan Addendum to the Final Environmental Impact Statement/Environmental Impact Report for the Disposal and Reuse of the MCAS Tustin” (“2006 Addendum”). The Specific Plan Amendment reduced permitted non-residential development in the project area by about one million SF to approximately 10.4 million SF of non-residential uses but retained the same number of residential units (4,601). The zone change adjusted the PA boundaries and redistributed or eliminated planned land uses but did not increase the overall development potential or residential capacity allowed under the Specific Plan. The Disposition and Development agreement was made to facilitate the sale, leasing, and development of Tustin Legacy. 2013 Addendum An addendum to the 2001 FEIS/EIR was prepared to process General Plan Amendment 2013-001, Specific Plan Amendment 2013-001, Development Agreement 2013-002, and an Agreement for Exchange of Real Property between the City and South Orange County Community College District on 22 acres. The land transfer was in the western part of the TLSP area near the intersection of Red Hill Avenue and Valencia Avenue. The project added a new local street, Bell Avenue (now named Victory Road between Red Hill Avenue and Armstrong Avenue), to service adjacent uses; added an allowable land use (private for-profit noneducational uses); and increased allowable building square footages in the education village (Neighborhood A). 2017 Supplemental SEIR The TLSP 2017 SEIR was prepared to process the TLSP Amendment (2015-001) and General Plan Amendment (2015-002). The TLSP Amendment was prepared to facilitate development of the remaining undeveloped TLSP area in the City of Tustin. These remaining parcels would be sold, leased, or developed by the City. Eventually these parcels would be developed by a number of landowners within the framework established by the TLSP. Additionally, the TLSP Amendment included changes in land uses for the remaining PAs 8 through 19, which resulted in 2,212 more residential units and 1,755,306 fewer SF of non-residential 169 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 5 land use within the TLSP. The TLSP Amendment was approved by the City of Tustin on July 18, 2017, and provides the fundamental basis for the City’s current land use and development policies for the TLSP area. 2019 Brookfield Development (The Landing) In 2019, Resolution No. 19-54 was signed, approving a Tentative Tract Map (TTM) and design review of a multifamily project including 400 condominium units within PAs 8, 13, and 14 of Neighborhood D. The project included 117 single-family detached units, 129 townhomes, 154 flats and townhomes, a community facility, and other neighborhood amenities over approximately 107 gross acres. The project was determined to be consistent with the previously approved 2001 FEIS/EIR and subsequent CEQA documentation prepared for the project area. 2025 Tustin Legacy Specific Plan Amendment Supplemental EIR The TLSP 2025 SEIR was prepared to process the TLSP 2025 Specific Plan Amendment (SPA) (SPA2024- 0002) to increase the allowed residential capacity in Neighborhood D South, D North, and G (PAs 8,13-14, and 15) in consistency with the City’s 2021-2029 Housing Element Update. The rezone added a total of 2,211 additional residential units to the capacity of the TLSP, which included 855 residential units to meet Regional Housing Needs Allocation (RHNA) requirements plus 1,356 buffer units. The provision for State Density Bonus is applicable to the TLSP area; therefore, an additional 2,759 units were conservatively included in the TLSP 2025 SEIR analysis to anticipate the potential application of density bonuses in future residential development projects. Thus, a total of 4,970 additional units were analyzed in the TLSP 2025 SEIR. The TLSP 2025 SEIR analyzed whether potential construction and operation of the 4,970 theoretical units would result in environmental effects that were not examined in the previously approved 2001 FEIS/EIR and subsequent environmental documents, including the TLSP 2017 SEIR. Importantly, as discussed above, the TLSP Housing Element rezone project proposed units in limited neighborhoods of the TLSP – Neighborhood D North, Neighborhood D South, and Neighborhood G. The Project site is located within Neighborhood D South of the TLSP 2025 SEIR. Neighborhood D South is inclusive of both PAs 13 and PA 14 which allow for a maximum buildout of 606,000 SF of non-residential uses and a maximum buildout of 2,427 residential units (including density bonus units). Subsequent Environmental Review The 2001 FEIS/EIR was prepared as a Program EIR and served as the primary environmental document for future development consistent with the MCAS Tustin Specific Plan. The 2001 FEIS/EIR evaluated a multiyear development program associated with the planned urban reuse of the former MCAS Tustin site. As individual development projects were proposed within the TLSP area, the City reviewed each project to determine whether its environmental effects were fully analyzed within the scope of the 2001 FEIS/EIR. Projects found to be within the scope of the 2001 FEIS/EIR could be approved without additional environmental documentation, while projects that fell outside that scope were subject to further CEQA review, as appropriate. While the 2001 FEIS/EIR is the original environmental document for the TLSP area, subsequent environmental documents have been prepared for the TLSP area due to changing conditions and necessary updates. The most recent document that captures the proposed Project site is the TLSP 2025 SEIR. Consistent with this tiered CEQA framework, this Addendum incorporates by reference the TLSP 2025 Supplemental EIR and other relevant technical documents that relate to the proposed Project or provide additional information regarding the environmental setting. The analysis contained in this Addendum is based on the following technical studies and planning documents: x The Tustin Legacy Specific Plan (https://www.tustinca.org/400/Specific-Plans) x TLSP 2025 Supplemental EIR 170 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 6 x Tustin City Code (https://library.municode.com/ca/tustin) x The Tustin Legacy Specific Plan Mitigation Monitoring and Reporting Program x Technical studies, and web information as listed in Section 7, References In addition, all documents are available for review at the City of Tustin Planning Department, located at 300 Centennial Way, Tustin, CA 92780. 171 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 7 2. ENVIRONMENTAL SETTING 2.1. PROJECT LOCATION The Project site is situated in the southern portion of the City of Tustin, within Orange County. Regional access to the site is provided via Interstate 5 (I-5), I-405, and State Route 261 (SR 261). Local access to the Project site is provided via Armstrong Avenue. The Project site encompasses approximately 6.14 gross acres and is identified by Assessor’s Parcel Number (APN) 430-481-12. The Project site and the surrounding area are shown in Figure 2-1, Regional Location and Figure 2-2, Local Vicinity. 2.2. EXISTING PROJECT SITE The Project site is currently vacant and undeveloped and has been disced. The site contains sparse vegetation consisting of low grasses and weeds. There is an existing chain link fence along the eastern and western boundaries of the site and a block wall along the northern boundary. The entire site is fenced off with a chain link fence. Existing conditions of the Project site and adjacent uses are shown in Figure 2-3, Aerial View and Figures 2-4a and 2-4b, Site Photos. 2.3. EXISTING LAND USES AND ZONING DESIGNATION OF THE PROJECT SITE The Project site has a General Plan land use and zoning designation of TLSP, as shown in Figure 2-5, Existing General Plan Designation and Figure 2-6, Zoning Designation. The TLSP is divided into eight distinct “Neighborhoods” (Neighborhoods A-H). The TLSP neighborhoods each have their own characteristics and set of functions to perform within the TLSP area. A neighborhood may be comprised of more than one land use designation. Further, the Neighborhoods are divided into PAs. The original MCAS Tustin Specific Plan contained 22 PAs, however, to better achieve the land use objectives of the 2017 amended TLSP, some of the PAs were combined (now 13 areas). The Land Use Plan for TLSP therefore consists of 13 PAs and a number of sub-planning areas. Neighborhood D includes PAs 8, 13 and 14, which are designated as recreation/entertainment core and mixed-use urban. The Project site is within Neighborhood D “South” which is specifically designated as Mixed-Use Urban. Neighborhood D South accommodates residential uses, institutional uses (including congregate care and assisted living), office uses, and commercial uses. 2.4. SURROUNDING GENERAL PLAN AND ZONING DESIGNATIONS The surrounding land uses are described in Table 2-1, Surrounding Existing Land Use and Zoning Designations, along with their General Plan land use and zoning designations. 7DEOH6XUURXQGLQJ([LVWLQJ/DQG8VHDQG=RQLQJ'HVLJQDWLRQV ([LVWLQJ/DQG8VH*HQHUDO3ODQ 'HVLJQDWLRQ=RQLQJ'HVLJQDWLRQ7/63/DQG8VH 'HVLJQDWLRQ 1RUWKWarner Avenue to the north followed by undeveloped land TLSP- Tustin Legacy Specific Plan Tustin Legacy (SP-1) Mixed-Use Urban 6RXWK John Johnson Way followed by vacant land and condominiums TLSP- Tustin Legacy Specific Plan Tustin Legacy (SP-1) Mixed-Use Urban :HVWArmstrong Avenue followed by vacant land TLSP- Tustin Legacy Specific Plan Tustin Legacy (SP-1) Commercial/Business 172 I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 8 ([LVWLQJ/DQG8VH*HQHUDO3ODQ 'HVLJQDWLRQ=RQLQJ'HVLJQDWLRQ7/63/DQG8VH 'HVLJQDWLRQ (DVWVacant land TLSP- Tustin Legacy Specific Plan Tustin Legacy (SP-1) Mixed-Use Urban This page intentionally left blank. 173 )LJXUH5HJLRQDO/RFDWLRQ 25$1*( 6$17$$1$ $1$+(,0 7867,1 *$5'(1*529( 1(:3257%($&+ &267$0(6$ 81,1&25325$7(' /$*81$:22'6 /$*81$ +,//6 )2817$,1 9$//(< ,59,1( (VUL1$6$1*$86*6)(0$6RXUFHV(VUL7RP7RP*DUPLQ)$2 12$$86*6Œ2SHQ6WUHHW0DSFRQWULEXWRUVDQGWKH*,68VHU &RPPXQLW\ 012 Miles m Clearwater Living Project   65 65 65 65 352-(&7 6,7( 174E I p I D SDLUTIDNS,INC Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 10 This page intentionally left blank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iles m/HJHQG Project Site Clearwater Living Project War n e r A v e D y e r R d Red Hill Ave65Jamboree Rd176E I p I D SDLUTIDNS,INC Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 12 This page intentionally left blank. 177 )LJXUH$HULDO HU $ Y H :DUQHU$YH : D UQ H U $Y H $UPVWUR QJ $YH+HOEHU :D\$UPVWURQJ$YH9HWHUDQV :D\/HJDF\ 5G/HJDF\5G)OL J K W : D \&RPSDVV $YH$LUVKLS $ Y H 3HHEO H U : D \/HJDF\5G6RXUFHV(VUL7RP7RP*DUPLQ)$212$$86*6 F 2SHQ6WUHHW0DS FRQWULEXWRUVDQGWKH*,68VHU&RPPXQLW\0D[DU 0 500 1,000 Feet m/HJHQG Project Site Clearwater Living Project 178E I p I D SDLUTIDNS,INC Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 14 This page intentionally left blank. 179 &OHDUZDWHU/LYLQJ3URMHFW)LJXUHD6LWH3KRWRV 3KRWR9LHZRI 3URMHFW6LWHIURPQRUWKHDVWFRUQHUIDFLQJ VRXWKZHVW 3KRWR9LHZRI3URMHFW6LWHIURPQRUWKZHVWFRUQHUIDFLQJ VRXWKHDVW  180 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 16 This page intentionally left blank. 181 &OHDUZDWHU/LYLQJ3URMHFW)LJXUHE6LWH3KRWRV 3KRWR9LHZRI3URMHFW6LWHIURPVRXWKZHVWFRUQHUIDFLQJQRUWKHDVW  182 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 18 This page intentionally left blank.  183 )LJXUH*HQHUDO3ODQ'HVLJQDWLRQ 6RXUFHV(VUL7RP7RP*DUPLQ)$212$$86*6 F 2SHQ6WUHHW0DSFRQWULEXWRUVDQG WKH*,68VHU&RPPXQLW\6RXUFHV(VUL0D[DU$LUEXV'686*61*$1$6$&*,$51 5RELQVRQ1&($61/62610$*HRGDWDVW\UHOVHQ5LMNVZDWHUVWDDW*6$*HRODQG)(0$ ,QWHUPDSDQGWKH*,6XVHUFRPPXQLW\ 0 1,000 2,000 Feet m/HJHQG Project Site *HQHUDO3ODQ/DQG8VH'HVLJQDWLRQ Planned Community Residential Industrial Planned Community Commercial / Business Tustin Legacy Specific Plan Clearwater Living Project Red Hill AveBa r r a n c a P k w y W a r n e r A v e 184 t:J - E I p I D S□LuT,□Ns,,NC --D Von Karman Plaza Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 20 This page intentionally left blank. 185 )LJXUH=RQLQJ'HVLJQDWLRQV 6RXUFHV(VUL7RP7RP*DUPLQ)$212$$86*6 F 2SHQ6WUHHW0DSFRQWULEXWRUVDQG WKH*,68VHU&RPPXQLW\6RXUFHV(VUL0D[DU$LUEXV'686*61*$1$6$&*,$51 5RELQVRQ1&($61/62610$*HRGDWDVW\UHOVHQ5LMNVZDWHUVWDDW*6$*HRODQG)(0$,QWHUPDSDQGWKH*,6XVHUFRPPXQLW\ 0 1,000 2,000 US Feet m/HJHQG Project Site =RQH Planned Community Residential Industrial Planned Community Industrial Planned Community Industrial - Specific Plan 3 Planned Community Industrial/Business Park Tustin Legacy Specific Plan Clearwater Living Project 186 CJ -- E I p I D S□LuT,□Ns,,NC ---~ Von Karman Plaza Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 22 This page intentionally left blank. 187 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 23 3. PROJECT DESCRIPTION 3.1. PREVIOUS CEQA ASSUMPTIONS FOR PROJECT SITE As previously described, the Project site is located within Neighborhood D South. This area is partially developed with scattered residential developments. The TLSP 2025 SEIR identified PAs 13 and 14 as having a total developable area of 124 acres and a max buildout 606,000 SF of non-residential development and a max buildout of 1,772 residential Dwelling Units (DUs) with 655 density bonus units. Table 3-1 includes square footages and unit counts for what has been previously approved or built, the existing remaining buildout, and the Project’s proposed assumptions for Neighborhood D South. 7DEOH1HLJKERUKRRG'/DQG8VH6XPPDU\ 3$  /DQG 8VH $FUHV  0D['HYHORSPHQW%XLOW$SSURYHG5HPDLQLQJ3URSRVHG3URMHFW 5HVLGHQWLDO XQLWV 1RQ 5HVLGHQWLDO 6)  5HVLGHQWLDO XQLWV 1RQ 5HVLGHQWLDO 6)  5HVLGHQWLDO XQLWV 1RQ 5HVLGHQWLDO 6)  5HVLGHQWLDO XQLWV 1RQ 5HVLGHQWLDO 6)  13-14 (D South) Mixed -Use Urban 124 2,4271 606,000 2,112 - 315 606,000 172 142,566 SF2 1-Inclusive of 655 density bonus units planned for in Neighborhood D South by the TLSP SEIR. 2-Neighborhood D South accommodates residential uses, institutional uses (including congregate care and assisted living), office uses, and commercial uses. The proposed assisted living units by the Project fall under institutional uses (congregate care), and therefore have been accounted for under the non-residential buildout. 3.2. PROPOSED PROJECT Project Overview The proposed Project would subdivide the existing 6.14-acre parcel into two parcels. Each parcel would contain one building, comprised of three habitable structures separated by two-hour-rated firewalls. Additionally, each building will be constructed, either completely or partially, above a first-floor parking structure, resulting in the total development of two buildings comprised of 8 firewall separated structures. The buildings would provide a total of 275 units—172 active adult senior residential units and 103 assisted living/memory care units (75 assisted living and 28 memory care units), as shown in Figure 3-2, Conceptual Site Plan. Of the 172 active adult senior residential units, 26 units would be low-income affordable units, which qualify the Project for a density bonus under the State of California Density Bonus Law (CA Gov Code Section 65915) and Section 9122 of the Tustin City Code. Additionally, the proposed Project would include landscaping, a parking garage, recreation amenities, and utility and stormwater improvements. The proposed Project requires approval of a Tentative Parcel Map (TPM 2025-151), a Conditional Use Permit (CUP), Affordable Housing Plan/Density Bonus Application, and Design Review from the City of Tustin. Project Features Active Adult Residential (Building 1) The active adult units provided on the Project site would be within three five-story buildings. The buildings would have a maximum height of 71 feet, consistent with the 150-foot maximum specified by the TLSP design standards for PAs 13, and 14. The residential facilities would contain a combination of housing products, including one- and two- bedroom units for lease as shown below in Table 3-2, Active Adult Unit Breakdown. As described previously, 26 units would be low-income affordable units. The active adult units would result in a total building footprint of 79,819 SF and a gross floor area of 293,360 SF. 188 I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 24 7DEOH$FWLYH$GXOW8QLW%UHDNGRZQ %XLOGLQJ  8QLW7\SH1XPEHURI8QLWV8QLW6TXDUH)HHW 6)  1BR/ 1BA 64 49,376 SF 1BR/ 1BA XL 28 28,900 SF 2BR/ 2BA 32 35,376 SF 2BR/ 2BA XL 36 46,534 SF SM 1BR/ 1BA 12 7,908 SF 7RWDO6) Notes: BR: Bedroom, BA: Bathroom Assisted Living/Memory Care (Building 2) The assisted living/memory care units provided on the Project site would be within three two-story buildings. The buildings would have a maximum height of 35.6 feet, consistent with the 150-foot maximum specified by the TLSP PAs 13, and 14, and would contain a total of 103 studio, one-, and two- bedroom units for lease as shown below in Table 3-3, Assisted Living/Memory Care Unit Breakdown. Of the 103 total units, 75 would be designated for assisted living, while the remaining 28 units would be designated for memory care. This would result in a total building footprint of 75,921 SF and a gross floor area of 142,566 SF. 7DEOH$VVLVWHG/LYLQJ0HPRU\&DUH8QLW%UHDNGRZQ %XLOGLQJ  8QLW7\SH1XPEHURI8QLWV8QLW6TXDUH)HHW 6)  1BR/ 1BA 33 23,776 SF 2BR/ 2BA 21 22,832 SF 2BR/ 2BA XL 9 10,938 SF MC Studio 28 9,954 SF SM 1 Bed/1 Bath 12 7,453 SF 7RWDO6) Notes: BR: Bedroom, BA: Bathroom Architectural Design The proposed buildings would feature a modern-contemporary architectural style and would comply with Section 3.19, Urban Design Guidelines, of the TLSP. The buildings would incorporate a combination of grey plaster, brown siding, and PVC roofing. Architectural accents would include limestone tile, picket railings, exposed concrete, and metal trim. The proposed design is illustrated on Figure 3-3, Active Adult Building Elevations and Figure 3-4, Memory Care/Assisted Living Building Elevations. Affordable Housing Component (Applicable to Active Adult Residential) As described previously, 26 of the 172 proposed active adult senior residential units would be reserved as low-income affordable units, which would qualify the Project for a density bonus under the State of California Density Bonus Law (CA Gov Code Section 65915) and Section 9122 of the Tustin City Code. Pursuant to Government Code Section 65915, the proposed Project would qualify for two concessions/incentives in addition to development standard waivers. The Project has requested one incentive which consists of a specific unit mix provision that would reserve exactly 23 of the 1-bedroom units as low-income and exactly 3 of the 2-bedroom units as low-income. Further, the Project has requested the following development standard waivers: a waiver for a reduction in the required private open space for active adult senior 189 I I I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 25 residential units; a waiver to reduce building setbacks along Armstrong Avenue and Warner Avenue; a waiver to increase the patio wall height adjacent to Warner Avenue; and waiver to allow the architectural feature to reduce encroachment allowance to the lot line. Access and Parking Regional access would be provided to the Project site via State Route 55 (SR-55), SR-261/Jamboree Road, and I-5. Local access would be provided via Armstrong Avenue, Warner Avenue, John Johnson Way, and Veterans Way. The Active Adult building (Building 1) would be accessible from two access points: a 27-foot- wide driveway on Veterans Way and a 27-foot-wide driveway on John Johnson Way. The Assisted Living building (Building 2) would also be accessible from the 27-foot-wide driveway on John Johnson Way. Resident parking would be provided via parking garages and guest parking on two surface lots within the site. Building 1 and Building 2 would each contain their own respective parking garages. Per Article 9, Part 6 Section 9263 of the TCC, Building 1 would be required to provide one space per unit and one guest space per 10 units. Building 2 would be required to provide one space for every three beds. Parking for residents would be provided at a ratio of 1.22 spaces per unit for Building 1 and .65 spaces per unit for Building 2, which would exceed the minimum parking required as shown below in Table 3-4, Parking Breakdown. 7DEOH3DUNLQJ%UHDNGRZQ 6LWH3DUNLQJ5HTXLUHG3DUNLQJ3URYLGHG Building 1 (Active Adult) 190 spaces1 211 spaces Building 2 (Assisted Living) 45 spaces2 67 spaces 1Per TCC Article 9, Part 6 Sec. 9263, 1 space per unit and 1 guest space per 10 units 2Per TCC Article 9, Part 6 Sec. 9263, 1 space per 3 beds Five percent of total parking spaces would be handicap accessible per 2025 California Building Code (CBC) Sec. 1109 A.5. There would also be one van accessible space for every eight accessible spaces Per 2025 CBC Sec. 1109A.8.6. Additionally, the proposed Project would be required to comply with the 2025 CBC standard for EV parking. The proposed parking summary for each building is detailed below in Table 3-5, Building 1 Parking Summary and Table 3-6, Building 2 Parking Summary. 7DEOH%XLOGLQJ $FWLYH$GXOW 3DUNLQJ6XPPDU\ 7\SH&RXQW 3DUNLQJ*DUDJH6XUIDFH3DUNLQJ Accessible 8 spaces1 1 EV Charger 19 spaces 4 EV Ready 76 spaces 10 Standard 52 spaces 6 Tandem Standard 15 spaces N/A Van Accessible 3 spaces1 2 1Includes EV Charger space 7DEOH%XLOGLQJ $VVLVWHG/LYLQJ 3DUNLQJ6XPPDU\ 7\SH&RXQW 3DUNLQJ*DUDJH6XUIDFH3DUNLQJ Bus N/A 1 space Accessible 2 spaces N/A 190 I r I I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 26 Accessible EV Charger 1 space N/A EV Charger 4 spaces 1 space EV Ready 24 spaces 6 spaces Standard 23 spaces 1 space Van Accessible 1 space 1 space Van Accessible EV Charger 1 space 1 space In addition, an internal roundabout for the drop-off of residents, and guest parking, would be located at the center of the site and accessible from the 27-foot-wide driveway off John Johnson Way. The roundabout driveway would also provide access to Building 1 and Building 2 parking garages. The 27-foot-wide driveway along Veterans Avenue would provide a secondary access point to the Building 1 parking garage and outdoor guest parking. Recreation and Open Space Each building would provide its own outdoor courtyard and amenities, as described below. Shared recreational spaces accessible to both buildings include a full-service kitchen, community theater, café and market, and a salon. %XLOGLQJ2QH The amenities provided for Building 1 residents (Active Adult) contain a “Great Room,” mail and business center, activity room, fitness studio, and a rooftop bar and lounge. Outdoor features, located on Floor Two, would include a 13,875 SF central courtyard with a pool and spa, as well as a 4,837 SF rooftop deck which contains pickleball courts and an outdoor kitchen adjacent to the bar and lounge area. Additionally, 165 of the 172 units would contain a private outdoor balcony with an average size of 117 SF. %XLOGLQJ7ZR The amenities provided for Building 2 residents (Assisted Living) contain a “Great Room,” wellness center, fitness area, aqua lounge, dining room, and activity spaces. Purpose-built areas would also be proposed within the Memory Care wing including an activity room, dining area with display kitchen, and a communal living room. The proposed outdoor feature would consist of a 18,162 SF central courtyard on the first floor. Landscaping and Fencing The proposed Project would provide 29,455 SF of landscaped area, which would result in overall decrease of perviousness from 100 percent pervious to 10 percent pervious post-development. Landscaping would include grasses and drought tolerant trees and shrubs which would be installed along the Project site boundary, parking lots, and throughout the open space areas, as shown in Figure 3-6, Landscape Plan. A patio wall would be constructed along the northeast boundary of the Project site, between the proposed Assisted Living building and Warner Avenue. In addition, patio walls and guardrails would delineate and distinguish the private outdoor patio spaces from public areas, as shown in Figure 3-5, Wall and Fence Plan. Lighting The proposed Project would install new exterior lighting onsite for security to accent landscaping, and to light signage, walkways, and parking areas. The new lighting would be focused on the site, shielded from offsite areas, and be in compliance with lighting regulations in TCC Section 9271. 191 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 27 Infrastructure Improvements The proposed Project would construct onsite infrastructure including new internal private streets, curb, gutter, sidewalk; storm drain improvements; wet and dry utilities; and related infrastructure improvements. :DWHUDQG6HZHU,PSURYHPHQWV The Project would construct 4-inch and 6-inch domestic water lines onsite that would connect to the existing 10-inch PVC water lines within John Johnson Way and Veterans Way. The Project would also implement fire hydrants that would receive water from the proposed 6-inch fire water lines onsite which would connect to the existing10-inch PVC water lines within John Johnson Way and Veterans Way. The Project would construct sewer lines onsite which would connect to the existing 8-inch sewer line in Veterans Way and 8-inch sewer line in John Johnson Way. 'UDLQDJH,PSURYHPHQWV A series of onsite storm drain facilities with Low Impact Development (LID) and peak storm elements. Project runoff will be directed to a system of inlets and storm drains, to collect, store, and convey runoff. The proposed storm drain system would be oversized to include storage volume: inclusive of a 42-inch storm drain and a 48-inch storm drain. The oversized storm drains would convey flow into a modular wetland system (MWS) along Armstrong Avenue. Additionally, there would be two StormCapture chambers onsite each of which would be able to store up to 6,720 cubic feet of runoff. The storm drains, StormCapture chambers, and MWS would ultimately discharge to the existing storm drain under Armstrong Avenue and John Johnson Way. Further, the proposed Project would be adequately sized with a design capture volume of 33,104.6 cubic feet to sufficiently treat and capture the required 32,979 cubic feet in the 100-year storm event. Construction and Phasing Construction activities for the Project would occur over one phase, and would include site preparation, grading, building construction, paving, and architectural coatings. Construction is expected to begin in the third quarter of 2026 and occur over 24 months, ending in the third quarter of 2028. Project construction would occur within the hours allowable by TCC Section 4616, which states that construction is prohibited between the hours of 6:00 p.m. and 7:00 a.m., Monday through Friday and 5:00 p.m. and 9:00 a.m. on Saturdays and during all hours on Sundays and city observed federal holidays. The grading activities for development of the proposed Project would result in a cut of 4,715 cubic yards (CY) of soil and a fill of 4,541 CY of soil totaling a net export of approximately 174 CY of soil. Operational Characteristics The Project would be operated as senior residential apartments, and as a senior assisted living facility with accommodation for residents that need assistance. The apartment units would be inclusive of private outdoor spaces to promote community gatherings and activities. Typical operational characteristics include residents and assisted living staff traveling to and from the site. Discretionary Approvals, Permits, and Studies The following discretionary approvals and permits are anticipated to be necessary for implementation of the proposed Project: &LW\RI7XVWLQ x Adoption of the Addendum 192 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 28 x General Plan Conformity (GPC) Determination x Development Agreement (DA) x Subdivision (SUB)/Tentative Parcel Map (TPM) x Conditional Use Permit (CUP) x Design Review (DR) x Affordable Housing Plan/Density Bonus Application x Approvals and permits necessary to execute the proposed Project, including but not limited to, grading permit, building permits, street encroachment permits, WQMP, etc. 193 )LJXUH6LWH3ODQClearwater Living Project UP UP UP UP UP UP DN 0,1  :,'(/$1'6&$3(%8))(521$5067521*$9( 3523(57</,1( WALKWAY XFORMERSWITCH GENERATOR AL TRASHENCLOSURESTAFFPATIO LANDSCAPING 02180(176,*1 9,6,%,/,7<75,$1*/( 02180(176,*1 02180(176,*1 02180(176,*1 $66,67('/,9,1*&2857<$5' ROLLING GATE ENCLOSURE WALL XFORMER XFORMER )8785(3523(57</,1( )8785(3523(57</,1( 3$5.,1**$5$*(#),567)/225 3523(57</,1( PROPERTY LINE BIOSWALE BY CITY OF TUSTIN PUBLIC WORKS (NOT IN PROJECT SCOPE. SHOWN FOR REFERENCE ONLY) PROPERTY LINE PROPERTY LINE BUS TURNOUT 0,1 :,'(/$1'6&$3(%8))(521$5067521*$9( MIN. 11'-0"-WIDE LANDSCAPE BUFFER ON WARNER AVE. MIN. 11'-0"-WIDE LANDSCAPE BUFFER ON WARNER AVE. SECONDARY BUILDING ENTRY ACCESSPATHTOBUSSTOP 9,6,%,/,7<75,$1*/( VISIBILITY TRIANGLE 9,6,%,/,7<75,$1*/(25' - 0"25' - 0"SETBACK10'-0"REQUI REDSETBACK10' - 0"REQUIRED4'-0" SETBACK 20'-0"REQUIRED25'-0"25'-0"11'-0"SETBACK20'-0"SETBACK20'-0"REQUIRED25'-0"25'-0"11'-0"02180(176,*1 25'-0"25'-0" SETBACK 20'- 0 "REQUIRED SETBACK10'-0"REQUIRED SETBACK 10'-0"REQUIRED SET BAC K20'-0" R E Q UIRED SETBACK10'-0"REQUI REDAA TRASH STAGING 4' - 0" MAX.PATIO WALL/,1(2)522)29(5+$1*$%29( /,1(2)%8,/',1*$%29(,1&/8',1*%$/&21<352-(&7,216m194 E I p I D S□LuT,□Ns ,INC Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 30 This page intentionally left blank. 195 Clearwater Living Project *$5$*((175$1&($1'(;,7 723$5$3(7   522)   ),)7+)/225   )2857+)/225   7+,5')/225   6(&21')/225   ),567)/225  4' - 0"11' - 0"11' - 0"11' - 0"13' - 0"14' - 0"60' - 0"68' - 0" TO T.O. STAIR TOWER4' - 0"11' - 0"11' - 0"11' - 0"13' - 0"14' - 0"60' - 0"723$5$3(7   522)   ),)7+)/225   )2857+)/225   7+,5')/225   6(&21')/225   ),567)/225  68' - 0" TO T.O. STAIR TOWER4' - 0"11' - 0"11' - 0"11' - 0"13' - 0"14' - 0"60' - 0"723$5$3(7   522)   ),)7+)/225   )2857+)/225   7+,5')/225   6(&21')/225   ),567)/225  68' - 0" TO T.O. STAIR TOWER723$5$3(7   522)   ),)7+)/225   )2857+)/225   7+,5')/225   6(&21')/225   ),567)/225  4' - 0"11' - 0"11' - 0"11' - 0"13' - 0"14' - 0"60' - 0"6&$/(  $&7,9($'8/7 ($67(/(9$7,21 6&$/(  $&7,9($'8/7 6287+(/(9$7,21 6&$/(  $&7,9($'8/7 :(67(/(9$7,21 6&$/(  $&7,9($'8/7 1257+(/(9$7,21 .(<127(6    $ %     */$66*8$5'5$,/ 9(57,&$/3,&.(7*8$5'5$,/ ),%(5&(0(176,',1* 678&&260227+),1,6+Z5(9($/6 678&&2),1(6$1'),1,6+Z5(9($/6 23(5$%/(9,1</:,1'2: ),;('9,1</:,1'2: 6725()5217$66(0%/< :,5(0(6+6(&85,7<6&5((1  &$123<:),%(5&(0(17%2$5'81'(56,'(      0(7$/0(&+$1,&$/6&5((1&2/25720$7&+%8,/',1*(/(9$7,216 */$66'225Z9,1</:,1'2:6,'(/,7(6 75$1620 52//'2:16(&85,7<'225 /,0(6721(7,/(6721(9(1((5 6+$'(6758&785( %%$$ $%$%%$$% $%$   $%%%$$    (;326('&21&5(7( $$  %8,/',1*6,*1$*( 3/$&(+2/'(5  %$%%% %%$$ $$ $%   3/$17(5:),%(5&(0(176,',1*        12786(' 12786(' )LJXUH$FWLYH$GXOW%XLOGLQJ(OHYDWLRQV 196 □ □ □ □ □ □ □ □ □ E I p I D SDLUTIDNS,INC Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 32 This page intentionally left blank. 197 FIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0"4' - 0"12' - 0"14' - 0"26' - 0"35' - 6" TO T.O. ROOFFIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0"4' - 0"12' - 0"14' - 0"26' - 0"35' - 6" TO T.O. ROOFFIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0"4' - 0"12' - 0"14' - 0"26' - 0"35' - 6" TO T.O. ROOF*$5$*((175$1&( FIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0"4' - 0"12' - 0"14' - 0"26' - 0"35' - 6" TO T.O. ROOF6&$/(  $66,67('/,9,1* ($67(/(9$7,21 6&$/(  $66,67('/,9,1* 6287+(/(9$7,21 6&$/(  $66,67('/,9,1* :(67(/(9$7,21 6&$/(  $66,67('/,9,1* 1257+(/(9$7,21 $ %$ $ $  .(<127(6     $ %     */$66*8$5'5$,/ 9(57,&$/3,&.(7*8$5'5$,/ )$8;-8/,(7%$/&21< ),%(5&(0(176,',1* 678&&260227+),1,6+Z5(9($/6 678&&2),1(6$1'),1,6+Z5(9($/6 23(5$%/(9,1</:,1'2: ),;('9,1</:,1'2: 6725()5217$66(0%/< :,5(0(6+6(&85,7<6&5((1  &$123<:),%(5&(0(17%2$5'81'(56,'(     0(7$/0(&+$1,&$/6&5((1&2/25720$7&+%8,/',1*(/(9$7,216 */$66'225Z9,1</:,1'2:6,'(/,7(6 75$1620 52//'2:16(&85,7<'225 /,0(6721(7,/(6721(9(1((5 (;326('&21&5(7(  %$% %$ %$%$$%%$$  $$%$%%$$%%  39&522),1*   0(7$/:,1'2:$:1,1*:7,(%$&.6 75(//,6  3/$17(5:),%(5&(0(176,',1*  522)($9(:,7+5$)7(57$,/6      % % % %% 12786('  12786('  12786('  )LJXUH0HPRU\&DUH$VVLVWHG/LYLQJ%XLOGLQJ(OHYDWLRQVClearwater Living Project 198 □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ E I p I D SDLUTIDNS,INC Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 34 This page intentionally left blank. 199 )LJXUH:DOODQG)HQFH3ODQClearwater Living Project m200 SCHEDULE DESCRIPTION PATIO WALL PODIUM PLANTER ___ -PODIUM GLASS FENCE MONUMENT WALL PICKLEBALL FENCE -• AAPATIOWALL ~ ALMCPATIOWALL -!~ING VEHICULAR GATE ---USPA MEDIA WALL METAL FENCE - -• PARAPET WALL ~=:ARCHITECTURE.COM San:::~~~ 949.675.6442 .203.4999 DETAIL 2 E I p I D SOLUTIONS ,INC JO\-\N JO\-\NSON WAY Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 36 This page intentionally left blank. 201 )LJXUH/DQGVFDSH3ODQClearwater Living Project 1 1 6 2 7 3 8 4 4 4 9 9 10 11 6 14 14 14 13 13 13 13 13 5ARMSTRONG AVENUEWARNER AVENUE VETERANS WAY 12 12 12 PROPOSED LOT LINE CONCEPT PLANT SCHEDULECONCEPT PLANT SCHEDULECONCEPT PLANT SCHEDULE PARKWAY TREE (36" BOX MINIMUM)33LAURUS NOBILIS / SWEET BAY 36" BOX SHRUBS 63,441 SFAGAVE ATTENUATA / FOXTAIL AGAVE 5 GALANIGOZANTHOS X 'RAMBOCITY' / BUSH TENACITY KANGAROO PAW 5 GALARMERIA MARITIMA / SEA THRIFT 1 GALBOUGAINVILLEA X 'MONKA' / OO-LA-LA® BOUGAINVILLEA 5 GALBOUTELOUA GRACILIS 'BLONDE AMBITION' / BLONDE AMBITION BLUE GRAMA 5 GALBUXUS MICROPHYLLA JAPONICA 'WINTER GEM' / WINTER GEM JAPANESE BOXWOOD 5 GALCARISSA MACROCARPA 'GREEN CARPET' / GREEN CARPET NATAL PLUM 1 GALDIANELLA REVOLUTA 'DR5000' / LITTLE REV™ FLAX LILY 1 GALFICUS PUMILA / CREEPING FIG 1 GALJUNCUS PATENS / CALIFORNIA GRAY RUSH 5 GALLANTANA X 'NEW GOLD' / NEW GOLD LANTANA 1 GALLIGUSTRUM JAPONICUM 'TEXANUM' / TEXAS JAPANESE PRIVET 5 GALLOMANDRA LONGIFOLIA / MAT RUSH 1 GALMYOPORUM X 'PUTAH CREEK' / PUTAH CREEK MYOPRORUM 1 GALPHORMIUM TENAX 'CREAM DELIGHT' / CREAM DELIGHT NEW ZEALAND FLAX 5 GALSALVIA LEUCANTHA 'SANTA BARBARA' / SANTA BARBARA MEXICAN BUSH SAGE5 GALSENECIO SERPENS / BLUE CHALKSTICKS 1 GALTRACHELOSPERMUM JASMINOIDES / CHINESE STAR JASMINE 5 GAL PARKWAY SHRUBS 4,434 SFCARISSA MACROCARPA 'GREEN CARPET' / GREEN CARPET NATAL PLUM 1 GAL TREES (36" BOX MINIMUM)132ARBUTUS X 'MARINA' / MARINA STRAWBERRY TREE 36" BOXJACARANDA MIMOSIFOLIA / JACARANDA - LOW BRANCHING 48" BOXLAGERSTROEMIA INDICA / CRAPE MYRTLE 36" BOXLAURUS NOBILIS / SWEET BAY 36" BOXLOPHOSTEMON CONFERTUS / BRISBANE BOX 36" BOXOLEA EUROPAEA 'SWAN HILL' / SWAN HILL FRUITLESS OLIVE 36" BOXOLEA EUROPAEA 'SWAN HILL' / SWAN HILL FRUITLESS OLIVE 60" BOXPLATANUS RACEMOSA / CALIFORNIA SYCAMORE 36" BOXQUERCUS AGRIFOLIA / COAST LIVE OAK 36" BOXQUERCUS AGRIFOLIA / COAST LIVE OAK MULTI-TRUNK 48" BOXTIPUANA TIPU / TIPU TREE 48" BOX WATER QUALITY SHRUBS 194 SFCAREX DIVULSA / EUROPEAN GREY SEDGE 1 GALJUNCUS PATENS / CALIFORNIA GRAY RUSH 1 GALMUHLENBERGIA RIGENS / DEER GRASS 1 GAL m202 E I p I D SOLUTIONS,INC CONCEPT PLANT SCHEDULE .-•• Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 38 This page intentionally left blank. 203 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 39 204 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 40 4. ENVIRONMENTAL CHECKLIST 4.1. BACKGROUND 'DWH May 2026 3URMHFW7LWOH Clearwater Living at Tustin Legacy /HDG$JHQF\ City of Tustin 300 Centennial Way Tustin, CA 92780 /HDG$JHQF\&RQWDFW Jorge Maldonado, JMaldonado@tustinca.org 3URMHFW/RFDWLRQ The Project site is located east of Armstrong Avenue and south of Warner Avenue (APN 430-481-012). 3URMHFW6SRQVRU·V1DPHDQG$GGUHVV Confluent Development 2215 Market Street Denver, CO 80205 /DQG8VHDQG=RQLQJ'HVLJQDWLRQ Tustin Legacy Specific Plan (TLSP) and Mixed Use 3URMHFW'HVFULSWLRQ The Project proposes the development of 275 units for seniors over two buildings, inclusive of units for active seniors and seniors requiring assisted living or memory care services. Each building is comprised of three habitable structures separated by two-hour-rated firewalls. Additionally, each building will be constructed, either completely or partially, above a first-floor parking structure, resulting in the total development of two buildings comprised of eight firewall-separated structures. The proposed Project would include 172 Active Adult units (senior residential) and 103 Memory Care/ Assisted Living units. The Project site would be locally accessible from John Johnson Way and Veterans Way. The proposed Project requires the adoption of this Addendum and Subdivision/Tentative Parcel Map. The proposed Project would also require the approval of a Development Agreement, Conditional Use Permit, Design Review, and General Plan Conformity Determination, and an Affordable Housing Plan/Density Bonus Application. A more detailed description of the proposed Project is provided in Section 3, Project Description. 6XUURXQGLQJ/DQG8VHVDQG6HWWLQJ The Project site is within an urbanizing environment and is currently graded and surrounded by residential uses and vacant land. 2WKHU3XEOLF$JHQFLHV:KRVH$SSURYDOLV5HTXLUHG None 205 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 41 206 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 42 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 and Forest Resources Air Quality Biological Resources Cultural Resources Energy Geology/Soils Greenhouse Gas Emissions Hazards and Hazardous Materials Hydrology/Water Quality Land Use/Planning Mineral Resources Noise Population/Housing Public Services Recreation Transportation Tribal Cultural Resources Utilities/Service Systems Wildfire None 4.3. ENVIRONMENTAL FACTORS THAT DO NOT REQUIRE FURTHER ANALYSIS The subject areas listed below were determined to result in no changes in the environment as compared to the original project analyzed in the TLSP 2025 SEIR. Also, there is no "new information of substantial importance" as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, the previously certified TLSP 2025 SEIR adequately discusses the potential impacts of the project without modification. Further, all applicable mitigation measures for the listed subject areas would be applied to the Project and would be included in the Project’s mitigation monitoring and reporting program (MMRP). Therefore, these subject areas require no further CEQA analysis x Agriculture and Forest Resources x Cultural Resources x Geology and Soils x Hazards and Hazardous Materials x Mineral Resources x Recreation x Tribal Cultural Resources x Wildfire Mitigation Measures Applicable to the Proposed Project corresponding to the above subject areas: Cultural Resources 6(,500$UFKPrior to issuance of grading permits the cities of Tustin and Irvine shall each require applicants of individual development projects to retain as appropriate a county-certified archaeologist. If buried resources are found during grading within the reuse plan area a qualified archaeologist would need to assess the site significance and perform the appropriate mitigation. The Native American viewpoint shall be considered during this process. This could include testing or data recovery Native American consultation shall also be initiated during this process. Geology and Soils  6(,5 00 3DOHRThe cities of Tustin and Irvine shall each require applicants of individual development projects to comply with the requirements established in a Paleontological Resources Management Plan (PRMP) prepared for the site, which details the methods to be used for surveillance of 207 □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ ~ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 43 construction grading, assessing finds, and actions to be taken in the event that unique paleontological resources are discovered during construction. 6(,5003DOHR Prior to the issuance of a grading permit, project applicants shall provide written evidence to each city that a county-certified paleontologist has been retained to conduct salvage excavation of unique paleontological resources if they are found. Tribal Cultural Resources 7/636(,5007&55HWDLQD1DWLYH$PHULFDQ0RQLWRU3ULRUWR&RPPHQFHPHQWRI*URXQG 'LVWXUELQJ$FWLYLWLHV 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 Gabrieleño 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. b. 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. c. 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. d. 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. e. 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 208 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 44 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. 7/63  6(,5 00 7&5 8QDQWLFLSDWHG 'LVFRYHU\ RI 7ULEDO &XOWXUDO 5HVRXUFH 2EMHFWV 1RQ )XQHUDU\1RQ&HUHPRQLDO  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 Gabrieleño 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. 7/636(,5007&58QDQWLFLSDWHG'LVFRYHU\RI+XPDQ5HPDLQVDQG$VVRFLDWHG)XQHUDU\RU &HUHPRQLDO2EMHFWV 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. 4.4. DETERMINATION On the basis of this initial evaluation No substantial changes are proposed in the project and there are no substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous approved ND or MND or certified EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects. Also, there is no "new information of substantial importance" as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, the previously adopted ND or MND or previously certified EIR adequately discusses the potential impacts of the project without modification. 209 □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 45 The Checklist/Addendum concludes that none of the conditions or circumstances that would require preparation of a subsequent or supplemental EIR pursuant to Public Resources Code Section 21166 and CEQA Guidelines Section 15162 exists in connection with the design of the Project. No substantial changes have been proposed to the project described in the TLSP 2025 SEIR that require major revisions to TLSP 2025 SEIR. No new significant environmental effects or substantial increase in the severity of previously identified significant environmental effects would occur. The Checklist/Addendum also indicates that there have not been any substantial changes with respect to the circumstances under which development of the project site, including the project, would be undertaken that would require major revisions to the TLSP 2025 SEIR. The Checklist/Addendum concludes that no substantial changes with respect to circumstances under which the project is undertaken have occurred that have not already been accounted for. The Checklist/Addendum also concludes that no new information of substantial importance, which was not known and could not have been known at the time that the TLSP 2025 SEIR was certified, shows that the project would cause or substantially worsen significant environmental impacts discussed in the TLSP 2025 SEIR, that mitigation measures or alternatives found infeasible in the TLSP 2025 SEIR would in fact be feasible, or that different mitigation measures or alternatives from those analyzed in the TLSP 2025 SEIR would substantially reduce one or more significant environmental effects found in the TLSP 2025 SEIR. Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous ND, MND or EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is "new information of substantial importance," as that term is used in CEQA Guidelines Section 15162(a)(3). However, all new potentially significant environmental effects or substantial increases in the severity of previously identified significant effects are clearly reduced to below a level of significance through the incorporation of mitigation measures agreed to by the project applicant. Therefore, a Subsequent MND is required. Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous environmental document due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is "new information of substantial importance," as that term is used in CEQA Guidelines Section 15162(a)(3). However, only minor changes or additions or changes would be necessary to make the previous EIR adequate for the project in the changed situation. Therefore, a Supplemental EIR is required. Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous environmental document due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is "new information of substantial importance," as that term is used in CEQA Guidelines Section 15162(a)(3) such as one or more significant effects not discussed in the previous EIR. Therefore, a SUBSEQUENT EIR is required. ___________________________________________________________________________________ 210 □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 46 Signature Date ___________________________________________________________________________________ Printed Name For 211 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 47 4.5. EVALUATION OF ENVIRONMENTAL IMPACTS The evaluation of environmental impacts in this addendum summarizes conclusions made in the TLSP 2025 SEIR and compares them to the impacts of the proposed Project. Mitigation measures referenced are from the Mitigation Monitoring and Reporting Program adopted as part of the TLSP 2025 SEIR and are described as either being previously implemented, applicable to the proposed Project, or not applicable. This comparative analysis has been undertaken pursuant to the provisions of CEQA and the CEQA Guidelines, to provide the factual basis for determining whether the proposed Project, or any new information that has come to light permits or requires the preparation of a subsequent or supplemental EIR. The analysis herein follows the outline and format, and applies the impact thresholds, of the TLSP 2025 SEIR as required by CEQA (Citizens Against Airport Pollution v. City of San Jose (2014) 227 Cal. App. 4th 788). As discussed previously in Section 1.2, Environmental Procedures, pursuant to CEQA Guidelines Section 15162, when an EIR has been previously certified that includes the scope of development of a site or area, no subsequent or supplemental EIR shall be prepared for the project unless the lead agency determines that one or more of the following three conditions are met: 1. the project would result in new or substantially more severe impacts than were disclosed in the previous EIR; 2. changes in the circumstances surrounding the project result in new or substantially more severe impacts than were disclosed in the previous EIR; or 3. new information has come to light showing that new or substantially more severe impacts than were disclosed in the previous EIR will occur. Terminology Used in the Checklist For each question listed in the Environmental Checklist, a determination of the level of significance of the impact is provided. Impacts are categorized in the following categories: 6XEVWDQWLDO&KDQJHLQ3URMHFWRU&LUFXPVWDQFHV5HVXOWLQJLQ1HZ6LJQLILFDQW(IIHFWVA Subsequent EIR is required when 1) substantial project changes are proposed or substantial changes to the circumstances under which the project is undertaken, and 2) those changes result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects, and 3) project changes require major revisions of the EIR. 1HZ,QIRUPDWLRQ6KRZLQJ*UHDWHU6LJQLILFDQW(IIHFWVWKDQ3UHYLRXV(,5A Subsequent EIR is required if new information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the EIR was certified, shows 1) the project will have one or more significant effects not discussed in the EIR; or 2) significant effects previously examined will be substantially more severe than shown in the EIR. 1HZ,QIRUPDWLRQ,GHQWLI\LQJ1HZ0LWLJDWLRQRU$OWHUQDWLYHWR5HGXFH6LJQLILFDQW(IIHFWLV'HFOLQHG A Subsequent EIR is required if new information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the EIR was certified shows 1) mitigation measures or alternatives previously found not to be feasible would in fact be feasible (or new mitigation measures or alternatives are considerably different) and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative. 212 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 48 With regard to the foregoing three categories, a Supplement to an EIR can be prepared if the criterion for a Subsequent EIR is met, and only minor additions or changes would be necessary to make the EIR adequately apply to the proposed Project. 0LQRU7HFKQLFDO&KDQJHVRU$GGLWLRQV An Addendum to the EIR is required if only minor technical changes or additions are necessary and none of the criteria for a Subsequent EIR is met. 1R,PSDFW A designation of no impact is given when the proposed Project would have no changes in the environment as compared to the original project analyzed in the EIR. 213 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 49 5. ENVIRONMENTAL ANALYSIS 5.1. AESTHETICS 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Would the project:Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a State scenic highway? c) In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings (public views are those that are experienced from a publicly accessible vantage point), or if the project is in an urbanized area, conflict with applicable zoning and other regulations governing scenic quality? d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? ,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ The certified 2001 FEIS/EIR evaluated views of the TLSP area from the surrounding viewshed and determined that development would alter the appearance of the area to varying degrees, including the TLSP area as seen from the surrounding viewshed and views from within the TLSP. Development would create visual contrast between new development and existing scattered buildings, hardscape, and vacant land in various portions of the TLSP area over the approximately 20-year development duration. However, the 2001 FEIS/EIR determined that the only significant visual impact was the potential loss of the existing blimp hangars, which would change existing foreground, middle-ground, and background views. 214 □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 50 At the time the 2001 FEIS/EIR was adopted, Hangars 28 and 29 were listed on the National Register of Historic Places (NRHP); as the two hangars and some appurtenant structures had been determined eligible for listing as a National Historic District. Since the two hangars measured 178 feet high and 1,088 feet long, they were visible from several miles away. TLSP development could demolish both hangars and the other appurtenant structures and improvements that are elements contributing to eligibility for National Historic District listing. The loss of both hangars was identified as a significant and unavoidable visual impact. In accordance with Section 106 of the National Historic Preservation Act, the City of Tustin, the State Historic Preservation Office (SHPO), the Advisory Council on Historic Preservation, the Department of the Navy, and the County of Orange executed a Memorandum of Agreement that identified measures to mitigate the impacts of the destruction of portions of the eligible historic district, including the removal of Hangar 28 and Hangar 29. Pursuant to the agreement, the County of Orange conducted a marketing study of Hangar 28, and the City of Tustin conducted a marketing study of Hangar 29. Both jurisdictions reached the conclusion that there is no economically viable use for the hangars, requiring implementation of mitigation measures. Measures intended to mitigate the loss of the hangars as iconic features were identified in the Memorandum of Agreement associated with the TLSP, include requirements for a written history, documentary video, and exhibit. As discussed in the 2017 SEIR, all mitigation measures identified in Stipulation III of the agreement have been satisfied. Aesthetic impacts were then subsequently analyzed within the following previously approved CEQA documents (City of Tustin, 2025c): x The 2004 Supplemental EIR determined that if one hangar were retained, impacts to aesthetic resources would be less than significant; and impacts would remain significant and unavoidable if both hangars were demolished. x The 2006 Addendum concluded that although views from previously identified sensitive viewers were altered with the new development, the development was implemented in compliance with the MCAS Specific Plan development standards and design guidelines. The new development was visually consistent with existing residential development. x The 2013 Addendum found that there would be no new impacts related to aesthetics. It determined that although there would be an increase in floor area ratio (FAR), the land uses would be the same as previously analyzed and would not change building height restrictions, setbacks, signage, and other development standards. x The 2017 SEIR analyzed potential impacts that could result from the proposed increase of 2,212 residential units and a decrease of 1.7 million SF of non-residential land uses. As identified in the 2017 SEIR, the change in land use mix and associated building types would alter the visual appearance of the TLSP area but would not result in a change in effect on a scenic vista. x As described above, the 2001 FEIS/EIR concluded that demolition of both historic hangars would have a significant visual impact, while the loss of only one hangar would be less than significant. The 2017 SEIR determined that the proposed changes in land use under the 2017 TLSP SPA would not result in changes to the analysis and conclusions from the 2001 FEIS/EIR with respect to the hangars. x The 2025 SEIR analyzed potential impacts that could result from the amendment of PAs 8, 13, 14 and 15 of the TLSP to accommodate additional residential units within Neighborhoods D South, D North, and G. As identified in the 2025 SEIR, the upzoning of residential uses would alter the visual appearance of Neighborhoods D South, D North, and G but would not result in a change in effects on scenic vistas or scenic highways. Additionally, the upzone would not conflict with any regulations governing scenic quality and would not result in new impacts pertaining to light and glare produced by the approved TLSP 2025 SEIR. 215 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 51 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV  6(,5 00 9,6 An urban design plan shall be adopted to provide for distinct and cohesive architectural and landscape design, features, and treatments, and harmony with existing adjacent landscape. D +DYHDVXEVWDQWLDODGYHUVHHIIHFWRQDVFHQLFYLVWD" The TLSP 2025 SEIR found that the upzoning of residential units would not result in new impacts to scenic vistas and determined that impacts would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW 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 buildout of the proposed Project would alter the visual appearance of the Project site but would not result in a change in effect on a scenic vista. The Project’s surrounding area previously contained two military hangars. Currently, one hangar remains southeast of the Project site, and the remnants of the second hangar are located to the northeast. Tustin Legacy Park is located west of the Project site; however, the proposed Project would not affect views of surrounding visual resources and new significant impacts would not occur. The proposed Project would allow for the development of 275 senior care and senior residential units. The proposed Project is consistent with the TLSP designation of Mixed-Use Urban and was previously analyzed in the TLSP 2025 SEIR. The maximum buildout for Neighborhood D South consists of 606,000 SF of non- residential development and 2,427 residential units (including density bonus units). Currently, Neighborhood D South has an existing buildout of zero SF and 776 residential units, thus there is sufficient capacity within the previously analyzed Neighborhood D assumptions to accommodate the proposed 142,566 SF of non- residential and 172 residential units of development. The development of the proposed Project could slightly alter the visual appearance of the Project site but would not result in a change in effect on a scenic vista. No new significant impacts would occur. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. E 6XEVWDQWLDOO\GDPDJHVFHQLFUHVRXUFHVLQFOXGLQJEXWQRWOLPLWHGWRWUHHVURFNRXWFURSSLQJVDQG KLVWRULFEXLOGLQJVZLWKLQD6WDWHVFHQLFKLJKZD\" The TLSP 2025 SEIR found that the upzoning of residential units would not result in new impacts to scenic resources and determined that impacts would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW The Project site is not within the vicinity of a designated state scenic highway. The nearest designated state scenic highway to the site is State Route 91 (SR-91) in the City of Anaheim, approximately 9 miles to the north (California Department of Transportation, 2018). Implementation of the proposed Project would not result in new impacts to scenic resources in a state scenic highway. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. 216 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 52 F ,QQRQXUEDQL]HGDUHDVVXEVWDQWLDOO\GHJUDGHWKHH[LVWLQJYLVXDOFKDUDFWHURUTXDOLW\RISXEOLFYLHZV RIWKHVLWHDQGLWVVXUURXQGLQJV SXEOLFYLHZVDUHWKRVHWKDWDUHH[SHULHQFHGIURPDSXEOLFO\ DFFHVVLEOHYDQWDJHSRLQW RULIWKHSURMHFWLVLQDQXUEDQL]HGDUHDFRQIOLFWZLWKDSSOLFDEOH]RQLQJ DQGRWKHUUHJXODWLRQVJRYHUQLQJVFHQLFTXDOLW\" The TLSP 2025 SEIR found that the upzoning of residential units would not substantially degrade the existing visual character or quality of public views of the site and its surroundings, and concluded that impacts would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe proposed Project which would develop a total of 275 senior care and senior residential units within Neighborhood D South of the TLSP. The proposed Project is consistent with the existing land use designation and zone for the Project site and would occur within the total Mixed-Use Urban assumptions analyzed in the TLSP 2025 SEIR for Neighborhood D South. The Project site is located in an urbanized area (the City of Tustin). The proposed development would comply with the TLSP design standards that provide a framework for visual character and quality of the various TLSP Neighborhoods. Further, the proposed Project would be required to comply with Mitigation Measure VIS-1 from the certified 2001 FEIS/EIR, which requires an urban design plan to provide for distinct and cohesive architectural and landscape design as well as harmony with adjacent landscaping. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. G &UHDWHDQHZVRXUFHRIVXEVWDQWLDOOLJKWRUJODUHZKLFKZRXOGDGYHUVHO\DIIHFWGD\RUQLJKWWLPH YLHZVLQWKHDUHD" The TLSP 2025 SEIR concluded the upzoning of residential units within Neighborhoods D South, D North, and G would not result in substantial light or glare and impacts were concluded to be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW 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 development of the proposed Project of the area could alter the visual appearance of the Project site. However, consistent with the conclusions in the TLSP 2025 SEIR, residential lighting would be similar to light sources associated with the existing commercial and residential uses adjacent to the Project site. Additionally, lighting introduced through implementation of the proposed Project would be visible only from nearby vantage points due to the flat topography of the site and surrounding development. Furthermore, the proposed Project would occur within the total Mixed-Use Urban development assumptions analyzed in the TLSP 2025 SEIR. Therefore, the proposed Project would not result in any new or more severe impacts related to light or glare beyond those previously analyzed. The proposed Project is consistent with the impacts 217 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 53 identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. Conclusion Based on the foregoing information, none of the conditions identified in State CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate project impacts or mitigation measures exist regarding aesthetics. There have not been (1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which development of the Project site is undertaken that require major revisions of the TLSP 2025 SEIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the TLSP 2025 SEIR was adopted as completed. Because none of the conditions identified in State CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental document to evaluate project impacts, the Project is consistent with the TLSP 2025 SEIR. 3ODQV3URJUDPVRU3ROLFLHV 333  None. 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG Final EIR mitigation measures that are applicable to the proposed Project would be implemented as intended by the TLSP 2025 SEIR. After implementation of the applicable mitigation measures, no new impacts nor substantially more severe aesthetics impacts would result from implementation of the proposed Project; therefore, no new or revised mitigation measures are required for aesthetics. TLSP 2017 SEIR Mitigation Measures Applicable to the Proposed Project: 6(,5009,6 As listed previously. 218 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 54 5.2.AIR QUALITY 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact 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? ,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ The certified 2001 FEIS/EIR addressed consistency of the MCAS Specific Plan with the South Coast Air Quality Management District (SCAQMD) Air Quality Management Plans (AQMPs), construction-related emissions, operational emissions, localized carbon monoxide (CO) “hotspots,” and air toxics. The 2001 FEIS/EIR concluded that the MCAS Tustin Specific Plan would not be consistent with the 1994 and 1997 AQMPs because these plans did not consider the planned intensity assumed by the Specific Plan. This impact was significant and unavoidable, and a statement of overriding considerations was adopted. The 2001 FEIS/EIR concluded that there were significant and unavoidable construction-related (short-term) emissions that exceeded the SCAQMD thresholds. Even with incorporation of mitigation measures, impacts were determined to remain significant and unavoidable, and a statement of overriding considerations was adopted. Operational emissions were also considered significant and unavoidable even with implementation of the City’s Traffic Reduction/Traffic Demand Management program (Ordinance No. 1062, approved in 1991), which has policies to reduce long-term emissions. A statement of overriding considerations was adopted for this impact. However, the 2001 FEIS/EIR concluded that operational emissions from businesses would comply with SCAQMD’s regulations for operation and would result in no new impact. 219 □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 55 The 2001 FEIS/EIR concluded that no sensitive receptors would be exposed to CO hotspots. The analysis included intersections with the highest traffic volumes and level of service (LOS) during the years 2005 and 2020. Air quality impacts were then subsequently analyzed within the following previously approved CEQA documents (City of Tustin, 2025c): x The 2004 Supplemental EIR determined that the TLSP area would not result in new additional impacts and the implementation of Tustin Ranch Road would be consistent with applicable policies and would reduce overall CO Hotspot impacts. However, impacts from the TLSP on air quality would remain significant and unavoidable. x The 2006 Addendum concluded that there was a reduced impact due to the reduction of non-residential square footage and redistribution of residential uses but no substantial change. The 2006 Addendum incorporated all applicable mitigation measures and revised Mitigation Measure AQ-1 to reflect amendments to SCAQMD Rules 402 and 403. x The 2013 Addendum analyzed a specific project and updated the air quality analysis to identify construction and operational-related impacts resulting from the construction of up to 816,929 SF of academic office space and the extension of Bell Avenue. The addendum determined that SCAQMD thresholds would not be exceeded, and no significant impacts would occur. x Because the 2016 AQMP was being drafted at the time that the TLSP 2017 SEIR was released, the thresholds in the TLSP 2017 SEIR were based on the adopted 2012 AQMP. The TLSP 2017 SEIR found that the 2017 TLSP SPA would accommodate more dwelling units, and the growth associated with these additional residential land uses is accounted for in the 2012 AQMP. Therefore, the 2017 TLSP SPA was determined to be inconsistent with the 2012 AQMP. x Compared to the Adopted Specific Plan as quantified using CalEEMod, the TLSP 2017 SEIR also found that the 2017 SPA would result in an increase in volatile organic compounds (VOCs), CO, SOX, PM10, and PM2.5 air pollutant emissions beyond those assumed for the MCAS Specific Plan. However, the net change in emissions would not exceed SCAQMD’s regional significance thresholds for construction emissions. Therefore, there would not be a substantial increase in the severity of previously identified impacts regarding construction emissions. x The TLSP 2017 SEIR concluded that total emissions associated with implementation of the 2017 SPA would exceed the SCAQMD’s operation-related regional significance thresholds for all criteria air pollutants except for SO2. This result is similar to the total long-term emissions associated with the Adopted Specific Plan. However, implementation of 2017 SPA was found to result in reduced emissions for NOX, CO, SO2, PM10, and PM2.5 when compared to the Adopted TLSP, due to an anticipated decrease in vehicle trips associated with the 2017 SPA. x Findings of the TLSP 2017 SEIR anticipated that the TLSP SPA and Adopted Specific Plan would generate similar localized construction-related emissions and would both result in significant localized construction- related emissions impacts . Therefore, no significant impacts would occur with implementation of the 2017 SPA. x The Initial Study prepared for the TLSP 2017 SEIR determined that the proposed change in land use mix from non-residential to residential would not generate a substantial increase in odor generation and no new impacts on objectionable odors would occur. However, the TLSP SPA would accommodate more dwelling units, and the growth associated with these additional residential land uses is accounted for in the 2012 AQMP. Therefore, similar to the Adopted Specific Plan, the TLSP SPA was determined to be inconsistent with the 2012 AQMP and impacts were determined to be significant and unavoidable. x The TLSP 2025 SEIR concluded that implementation of the 2025 TLSP SPA would result in VOCs, NOX, CO, PM10, and PM2.5 emissions from operational activities that exceed regional thresholds and would be significant and unavoidable, consistent with the findings of the previous environmental documentation. 220 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 56 x Although the TLSP 2025 SPA would be consistent with SCAG’s 2024-2050 RTP/SCS growth forecasts and the City’s Housing Element, it would lead to increased regional air quality operational emissions that would exceed thresholds. Therefore, it was determined that the 2025 TLSA SPA would result in a conflict with, or obstruct, implementation of the AQMP and impacts would be significant and unavoidable. x Regarding localized construction emissions, the TLSP 2025 SEIR concluded that, due to the unknown locations and specific construction activities that would occur for each project that would occur pursuant to the TLSP 2025 SPA, localized construction emissions would have the potential to expose sensitive receptors to substantial concentrations of criteria air pollutant emissions and result in a significant impact. x Regarding cumulative impacts, the TLSP 2025 SPA concluded that NOx and VOC emissions from implementation of the 2025 TLSPA would be cumulatively considerable, and cumulative air quality impacts would be significant and unavoidable. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV 6(,500$4Prior to issuance of grading permits, the Modified Project applicant shall use low VOC architectural coatings for all interior and exterior painting operations. 6(,500$4 Applicants for new development projects within the Tustin Legacy Specific Plan shall require the construction contractor to use equipment that meets the US Environmental Protection Agency (EPA) Tier 4 emissions standards for off-road diesel-powered construction equipment with more than 50 horsepower during construction activities, unless it can be demonstrated to the City of Tustin that such equipment is not available. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what would be achieved by a Level 4 diesel emissions control strategy for a similarly sized engine, as defined by the California Air Resources Board’s regulations. Prior to construction, the Modified Project engineer shall ensure that all demolition and grading plans clearly show the requirement for EPA Tier 4 or higher emissions standards for construction equipment with more than 50 horsepower. During construction, the construction contractor shall maintain a list of all operating equipment in use on the site for the verification of the City of Tustin. The construction equipment list shall state the makes, models, and numbers of construction equipment onsite. Equipment shall be properly serviced and maintained in accordance with the manufacturer's recommendations. Construction contractors shall also ensure that all nonessential idling of construction equipment is restricted to five minutes or less in compliance with California Air Resources Board Rule 2449.  6(,5 00 $4 Prior to the issuance of grading permits, the applicants for individual new developments shall evaluate localized construction-related air quality impacts. Localized construction emissions shall be evaluated to the South Coast Air Quality Management District’s Localized Significance Thresholds for construction. Applicable mitigation measures to reduce potential localized construction-related air quality impacts shall be included in the evaluation, as necessary, to minimize impacts to the extent feasible and shall be implemented. The evaluation shall be submitted to the City of Tustin for review. In addition, all recommended mitigation measures shall be noted on all construction plans submitted to the City of Tustin Building and Public Works Department for verification. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV 7/636(,500$49HKLFOH7ULS5HGXFWLRQ Rental Units: The applicant of for-rent residential developments shall notify and offer to the tenant or prospective tenant, materials describing public transit, ridesharing, and nonmotorized commuting opportunities in the vicinity of the development. The materials shall be approved by the City of Tustin. The materials shall be provided no later than the time the rental agreement is executed. A program outlining the implementation of this measure shall be submitted to the 221 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 57 City of Tustin Planning Division for review and approval, prior to the issuance of the first certificate of occupancy. 7/636(,500$43URKLELWLRQRI)LUHSODFHV The installation of wood-burning and natural gas devices shall be prohibited inside residential dwelling units. The purpose of this measure is to limit emissions of ROG, NOX, and particulate matter emissions from wood-burning and natural gas devices used for primary heat, supplemental heat, or ambiance. This prohibition shall be noted on the deed and/or any tenant lease agreements. 7/636(,500$4(OHFWULF/DQGVFDSH(TXLSPHQW Prior to the issuance of occupancy permits, the Community Development Department shall confirm that the Modified Project’s Codes Covenants and Restrictions (CC&Rs) and/or tenant lease agreements include contractual language that all landscaping equipment used on site shall be 100 percent electrically powered. All residential and non-residential properties shall be equipped with exterior electrical outlets to accommodate this requirement. This requirement shall be included in the third-party vendor agreements for landscape services for the building owner and tenants, as applicable. D &RQIOLFWZLWKRUREVWUXFWLPSOHPHQWDWLRQRIWKHDSSOLFDEOHDLUTXDOLW\SODQ" The TLSP 2025 SEIR found that implementation of the TLSP SPA would not exceed population growth forecasts upon which the 2022 AQMP was based; however, buildout of the TLSP SPA would surpass SCAQMD regional thresholds, resulting in a significant and unavoidable air quality impact (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW According to SCAG’s 2024-2050 RTP/SCS (SCAG, 2024), the City’s households and employment are forecasted to increase by approximately 7,000 households, and 19,600 jobs, respectively, between 2019 and 2050. The TLSP 2025 SEIR concluded that the additional housing units included in the TLSP 2025 SEIR would not exceed the SCAG RTP/SCS projected growth; but would conversely accommodate the City’s required housing stock in the City’s Housing Element, pursuant to the SCAG Regional Housing Needs Allocation (RHNA). As previously described in Section 3, Project Description, the TLSP 2025 SEIR analyzed development of 2,427 residential units (including density bonus units) and 606,000 SF of non-residential uses. As such, the 142,566 SF of non-residential uses and 172 residential units associated with the proposed Project were previously analyzed within the TLSP 2025 SEIR. The SCAQMD’s 2022 AQMP, which was adopted on December 2, 2022, is the applicable air quality plan for the City of Tustin. 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 criteria for a project’s consistency with the AQMP. Pursuant to Consistency Criterion No. 1, Projects that are consistent with the regional population, housing, and employment forecasts identified by SCAG are considered consistent with the AQMP growth projections, since the forecast assumptions by SCAG forms the basis of the land use and transportation control portions of the AQMP. Additionally, because SCAG’s regional growth forecasts are based upon, among other things, land uses designated in general plans and specific plans, a project that is consistent with the land use designated in a general plan would also be consistent with the SCAG’s regional forecast projections, and thus also with the AQMP growth projections. Therefore, since the proposed Project is consistent with the land use and the maximum assumptions previously analyzed within the TLSP 2025 SEIR, the proposed Project would not exceed the growth assumptions in the SCAG’s 2024-2050 RTP/SCS or the AQMP. Regarding Consistency with Criterion No. 2, an impact would occur if the emissions associated with the proposed Project would exceed the SCAQMD’s regional significance thresholds. As detailed below in Impact AQ-2, operation of full buildout of Neighborhood D South, including the proposed Project, would exceed 222 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 58 the threshold of significance for emissions of VOCs, NOX, CO, PM10, and PM2.5 for operations, thus impacts would be significant and unavoidable. However, the Project would not increase planned intensity beyond what was previously assumed in the TLSP 2025 SEIR. Thus, impacts would remain significant and unavoidable, consistent with the TLSP 2025 SEIR and no new impacts would occur. E 5HVXOWLQDFXPXODWLYHO\FRQVLGHUDEOHQHWLQFUHDVHRIDQ\FULWHULDSROOXWDQWIRUZKLFKWKHSURMHFW UHJLRQLVQRQDWWDLQPHQWXQGHUDQDSSOLFDEOHIHGHUDORUVWDWHDPELHQWDLUTXDOLW\VWDQGDUG " The TLSP 2025 SEIR found that buildout of the TLSP would result in potential cumulatively considerable net increases of pollutants during operation, and impacts were determined to be significant and unavoidable (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW Construction Construction activities associated with the proposed Project would generate pollutant emissions from the following: (1) site preparation, (2) grading, (3) building construction, (4) paving, and (5) architectural coating. The quantity of emissions generated on a daily basis would vary, depending on the intensity and types of construction activities occurring. The proposed Project would construct 142,566 SF of non-residential institutional uses and 172 residential units which is within the maximum scope of the 606,000 SF of non-residential development and 2,427 residential units (including density bonus units) allowed within Neighborhood D South and analyzed in the TLSP 2025 SEIR. As described in the TLSP 2025 SEIR, buildout of the 2025 TLSPA, including buildout of Neighborhood D South would not exceed SCAQMD thresholds for daily emissions. Given that the Project is within the buildout assumptions of the TLSP 2025 SEIR, impacts from construction emissions would be less than significant. Further, the Project would be required to comply with multiple SCAQMD Rules to reduce air contaminants during construction, including Rule 403 for controlling fugitive dust, PM10, and PM2.5 emissions from construction activities. Rule 403 requirements include, but are not limited to, applying water or a stabilizing agent in sufficient quantities to prevent the generation of visible dust plumes, applying soil binders to uncovered areas, reestablishing ground cover as quickly as possible, utilizing a wheel washing system to remove bulk material from tires and vehicle undercarriages before vehicles exit the proposed Project site, covering all trucks hauling soil with a fabric cover and maintaining a freeboard height of 12 inches, and maintaining effective cover over exposed areas. Compliance with Rule 403 is included as Plan, Program, or Policy (PPP) AQ-1. In addition, low VOC architectural coatings for all interior and exterior painting operations would be required as described in PPP AQ-2 and 2017 SEIR MM AQ-2. To further reduce emissions during construction, the use of Tier 4 emissions standards for off-road diesel-powered construction equipment with more than 50 horsepower during construction activities would also be required, as described in 2017 SEIR MM AQ-5. Thus, with compliance of regulatory requirements and applicable mitigation measures, impacts from construction would be less than significant. As such, no new impacts would occur and the construction of the proposed Project is consistent with what was previously analyzed within the TLSP 2025 SEIR. Operation The primary pollutants of the proposed Project would be mobile sourced emissions consistent with the TLSP 2025 SEIR. The TLSP 2025 SEIR anticipated a total of 19,997 daily trips with buildout of Neighborhood D South, including 2,246 daily trips associated with continuing care (assisted living) and 10,487 daily trips 223 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 59 associated with multi-family housing (senior apartments) within Neighborhood D South. The proposed Project anticipates a total of 870 daily trips which is consistent with what was previously assumed in the TLSP 2025 SEIR. The proposed Project would not introduce new uses thus no new impacts related to operational emissions would occur and impacts would remain significant and unavoidable. The Project would also be required to comply with TLSP 2025 SEIR MM AQ-1 which requires distribution of trip reduction opportunities to tenants. In addition, while mobile source emissions would be the primary pollutant for the proposed Project, to further reduce operational emissions the Project would be required to implement Rule 445 (PPP AQ-3) and TLSP 2025 SEIR MM AQ-2, which prohibit wood-burning and natural gas fireplaces as well as TLSP 2025 SEIR MM AQ-3, which requires that all landscaping equipment be 100 percent electric. Given that the Project is within the buildout assumptions of the TLSP 2025 SEIR, impacts from operations of the proposed Project would remain significant and unavoidable. Therefore, the proposed Project is consistent with what was originally analyzed in the TLSP 2025 SEIR and there would be no new impacts. F ([SRVHVHQVLWLYHUHFHSWRUVWRVXEVWDQWLDOSROOXWDQWFRQFHQWUDWLRQV" The TLSP 2025 SEIR found that buildout of the TLSP 2025 SPA could potentially expose sensitive receptors to substantial pollutant concentrations thus impacts were determined to be significant and unavoidable (City of Tustin, 2025c). ,PSDFWVDVVRFLDWHGZLWKWKHSURSRVHG3URMHFW 1R1HZ,PSDFW Sensitive receptors can include residences, schools, playgrounds, childcare centers, and athletic facilities. The nearest sensitive receptors are the existing residences located 72 feet south of the Project site. &RQVWUXFWLRQ Construction of the proposed Project may expose nearby receptors to airborne particulates as well as a small quantity of construction equipment pollutants (i.e., usually diesel-fueled vehicles and equipment). However, construction contractors must comply with SCAQMD Rule 403 and implement standard dust control and emissions reduction measures, as required under PPP AQ-2. These measures would substantially reduce pollutant emissions, as outlined in the TLSP 2025 SEIR. In addition, a Construction Emissions Analysis for potential project-related localized air quality impacts was prepared for the proposed Project, consistent with 2017 SEIR MM AQ-6 and is included as Appendix A. As shown in Table A-1 from the construction specific assessment, the maximum daily construction emissions from the construction of the proposed Project would not exceed the applicable SCAQMD LST thresholds at the closest existing sensitive receptor. Therefore, impacts would be less than significant and the proposed Project’s construction-related emissions would be consistent with impacts identified in the TLSP 2025 SEIR, and no new or more severe air quality impacts would occur. 7DEOH$/RFDOL]HG&RQVWUXFWLRQ(PLVVLRQ(VWLPDWHV &RQVWUXFWLRQ$FWLYLW\ 0D[LPXP'DLO\/RFDOL]HG(PLVVLRQV SRXQGVGD\  12[&23030  <HDU  Site Preparation 36.27 33.13 7.52 4.40 224 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 60 Grading 19.06 19.09 3.29 1.89 Building Construction 10.67 14.07 0.41 0.38 Maximum On-Site Emission (2026) 36.27 33.13 7.52 4.40  <HDU  Building Construction 10.17 14.04 0.36 0.34 Maximum On-Site Emission (2027) 10.17 14.04 0.36 0.34  <HDU  Building Construction 9.66 14.04 0.33 0.30 Paving 6.63 9.91 0.26 0.24 Architectural Coating 1.08 1.49 0.02 0.02 Maximum On-Site Emission (2028) 9.66 14.04 0.33 0.30 0D[LPXP'DLO\(PLVVLRQV      SCAQMD Screening Thresholds 196.30 1128.00 9.30 5.30 7KUHVKROG([FHHGHG"1R 1R 1R 1R Notes: NOx = nitrogen oxides, CO = carbon monoxide, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter Source: Appendix A 2SHUDWLRQ According to the SCAQMD LST methodology, LSTs apply to project-related stationary mobile sources. Projects that involve mobile sources that spend long periods queuing and idling at a site, such as transfer facilities or warehousing and distribution buildings, have the potential to exceed the operational LSTs. The Project would operate as a residential community, which does not typically involve diesel vehicles regularly idling or queuing for long periods. Therefore, due to the lack of significant stationary source emissions or idling diesel-powered vehicles, there would be no new impact related to operational LSTs. Also, as discussed above, the Project’s vehicular trips are within the scope of the intensity of what was previously analyzed in the TLSP 2025 SEIR. The Project also would not introduce stationary sources of operational emissions that are different or unique from the nonresidential institutional uses assumed in the TLSP 2025 SEIR. Therefore, the emissions from the proposed Project would be consistent with those anticipated by the TLSP 2025 SEIR. Additionally, the Project would include energy-efficient appliances, bike parking, and preferential parking spaces for alternatively fueled vehicles. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the 225 I I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 61 TLSP 2025 SEIR. Therefore, operational-phase air quality impacts would remain within the impacts identified in the TLSP 2025 SEIR. G 5HVXOWLQRWKHUHPLVVLRQV VXFKDVWKRVHOHDGLQJWRRGRUV DGYHUVHO\DIIHFWLQJDVXEVWDQWLDOQXPEHU RISHRSOH" The TLSP 2025 SEIR concluded that impacts would be less than significant with regard to objectionable odors (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe proposed Project does not contain land uses typically associated with emitting objectionable odors. The Project site is not located near existing agricultural uses. Potential odor sources associated with the proposed Project may result from construction equipment exhaust and the application of asphalt and architectural coatings during construction activities. However, any construction odors would be temporary in nature. Standard construction requirements would minimize odor impacts from construction. The construction odor emissions would be temporary, short-term, and intermittent in nature and would cease upon completion of the respective phase of construction and are thus considered less than significant. Project-generated refuse would be stored in covered containers and removed at regular intervals in compliance with the City’s solid waste regulations. Additionally, the proposed Project would be required to implement California Air Resources Board (CARB) Rule 2485 regulations that limit idling to 5 minutes (13 CCR, Chapter 10 Section 2485), which would reduce odors from the smell of truck exhaust. The proposed Project would also be required to comply with SCAQMD Rule 402 to prevent occurrences of public nuisances. Therefore, odor impacts associated with the proposed Project’s construction and operations would be less than significant, consistent with w the TLSP 2025 SEIR. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. Impacts from the proposed Project would be consistent with those identified in the TLSP 2025 SEIR. &RQFOXVLRQ Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures regarding air quality. There have not been 1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; 2) substantial changes with respect to the circumstances under which development of the Project is undertaken that require major revisions of the previous Final EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or 3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the TLSP 2025 SEIR was certified as completed. Because none of the conditions identified in CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts, CEQA Guidelines 15168 also does not require additional environmental review, and the Project is within the scope of the TLSP 2025 SEIR with respect to air quality. 3ODQV3URJUDPVRU3ROLFLHV 333  333$45XOH The following measures shall be incorporated into construction plans and specifications as implementation of Rule 403: 226 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 62 x 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. x The contractor shall ensure that all disturbed unpaved roads and disturbed areas within the Modified Project are watered at least three (3) times daily during dry weather. Watering, with complete coverage of disturbed areas, shall occur at least three times a day, preferably in the mid-morning, afternoon, and after work is done for the day. x The contractor shall ensure that traffic speeds on unpaved roads and Project site areas are reduced to 15 miles per hour or less. 333$45XOHThe following measure shall be incorporated into construction plans and specifications as implementation of Rule 1113. The Modified Project shall only use “Low-Volatile Organic Compounds (VOC)” paints (no more than 50 gram/liter of VOC) consistent with SCAQMD Rule 1113. 333$45XOHThe following measure shall be incorporated into construction plans and specifications as implementation of Rule 445. Wood burning stoves and fireplaces shall not be included or used in the new development. 333$4&$/*UHHQ%XLOGLQJ6WDQGDUGV0(59)LOWHUVIndoor air quality within mechanically ventilated buildings shall comply with Section 5.504.5.3 (Filters) of the California Green Building Standards Code Part 11 that requires utilization of at least a Minimum Efficiency Reporting Value (MERV) of 13 air filtration systems. The Code requires MERV 13 filters to be installed prior to occupancy and replaced and/or maintained as directed by the manufacturer. 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG Final EIR mitigation measures that are applicable to the proposed Project would be implemented as intended by the TLSP 2025 SEIR. After implementation of the applicable mitigation measures, no new impacts nor substantially more severe air quality impacts would result from implementation of the proposed Project; therefore, no new or revised mitigation measures are required for air quality. TLSP 2017 SEIR Mitigation Measures Applicable to the Proposed Project: 2017 SEIR MM AQ-2: As listed above. 2017 SEIR MM AQ-5: As listed above. 2017 SEIR MM AQ-6: As listed above. TLSP 2025 SEIR Mitigation Measures Applicable to the Proposed Project: TLSP 2025 SEIR MM AQ-1: Vehicle Trip Reduction. As listed above. TLSP 2025 SEIR MM AQ-2: Prohibition of Fireplaces. As listed above. TLSP 2025 SEIR MM AQ-3: Electric Landscape Equipment. As listed above. 227 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 63 5.3. BIOLOGICAL RESOURCES 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Would the project:Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact 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? 228 □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 64 ,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ The certified 2001 FEIS/EIR determined that implementation of the TLSP would result in impacts to jurisdictional waters, wetlands, and to the southwestern pond turtle. The 2001 FEIS/EIR did not find burrowing owls or suitable habitat for burrowing owls onsite. The 2001 FEIS/EIR identified several potential jurisdictional waters onsite, including but not limited to ditches and drainages, the Santa Ana/Santa Fe Channel, the Barranca Channel, and Peters Canyon Channel. It identified impacts to 16.2 acres of jurisdictional waters, 2.4 acres of which were vegetated wetlands. The 2001 FEIS/EIR determined that there would be no impacts to federally listed threatened or endangered plant or animal species. It found that there would be a direct impact to four loggerhead shrike, but that it would not have an overall adverse effect to the population in southern California. Mitigation Measures were included to require necessary Section 404 and 1601 permits for the impacts of jurisdictional waters; the capture and relocation of pond turtles to avoid impacts to wildlife; and the contribution of funds to create a relocation site for turtle habitat to mitigation impacts to sensitive habitat in coordination with the California Fish and Game Commission (CFGC). Overall, impacts were determined to be less than significant with mitigation. Subsequently, in the 2006 Addendum, impacts to biological resources were analyzed and several determinations and mitigation measures were revised. x Mitigation measures required in the certified 2001 FEIS/EIR were revised in the 2006 Addendum. A capture and relocation plan was approved by the California Department of Fish and Wildlife (CDFW) for the southwestern pond turtle, and all turtles were relocated. x The 2006 Addendum, which analyzed 1,511 acres of the TLSP area, identified the presence of 0.68 acres of federally protected wetlands. Mitigation measures for impacts to jurisdictional waters and wetlands were included in the 2001 FEIS/EIR and were revised in the 2006 Addendum to address the updated biological setting. x The 2006 Addendum also identified 0.8 acre of riparian area onsite that is within the jurisdiction of CDFW, and concluded that development would result in a significant impact to the entire riparian area. Mitigation measures included in the 2001 FEIS/EIR were determined to be adequate to reduce impacts to a less-than-significant level. x The 2006 Addendum concluded that the TLSP area does not support wildlife movement. The 2017 SEIR determined that proposed amendment at the time would not change the overall development footprint of the TLSP (City of Tustin, 2025c). Implementation of the TLSP SPA would not cause impacts to biological resources that were not previously analyzed in the 2001 FEIS/EIR. As noted above, the CDFW approved a pond turtle relocation and mitigation plan, and all turtles were relocated accordingly. Previously approved Mitigation Measures BIO-2, BIO-3, and BIO-4 were determined to reduce potential biological impacts of the 2017 TLSP SPA to a less-than-significant level. The 2017 SEIR determined that no new significant impacts on candidate, sensitive, or special status species would occur. Additionally, the 2017 SEIR found that implementation of the 2017 TLSP SPA would not interfere substantially with wildlife movement and would not result in the removal of substantial amounts of trees or shrubs that could be used by nesting migratory birds protected under federal and state laws (City of Tustin, 2025c). The 2017 SEIR determined that no new significant impacts on riparian habitat or federally protected wetlands would occur and would not conflict with any applicable Natural Community Conservation Plan (NCCP)/ Habitat Conservation Plan (HCP) or any other local policies or ordinances protecting biological species and no impact would occur. Therefore, the 2017 SEIR determined that impacts to biological resources would be consistent with determinations made by previous CEQA documents and impacts to biological resources would be less than significant with previously approved mitigation measures BIO-1 through BIO-4. 229 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 65 The 2025 SEIR determined that the TLSP 2025 SPA would not change the overall development footprint of the TLSP (City of Tustin, 2025c). Implementation of the TLSP 2025 SPA would not cause impacts to biological resources that were not previously analyzed in the 2001 FEIS/EIR or other subsequent documents. As noted above, the CDFW approved a pond turtle relocation and mitigation plan for the TLSP area, and all turtles have been relocated. Previously approved Mitigation Measures BIO-1, BIO-2, BIO-3, and BIO-4 would also be applicable to the TLSP 2025 SPA. Implementation of the TLSP 2025 SPA would not result in new impacts to any special status species or their habitats, and mitigation measures would reduce impacts to a less-than- significant level. The TLSP 2025 SPA would allow the development of future housing by-right on various parcels within the TLSP 2025 SPA site if certain conditions are met, and therefore, additional CEQA documentation would not need to be conducted. Therefore, Mitigation Measure BIO-5 was included to require an updated site survey at the time of future development to confirm site conditions are consistent with previous findings and that additional impacts wouldn’t occur as a result of the TLSP 2025 SEIR. The 2025 SEIR determined that no new significant impacts on candidate, sensitive, or special status species; or on riparian habitat or federally protected wetlands would occur. Finally, the 2025 TLSP SEIR determined that the TLSP 2025 SPA would not conflict with the NCCP/HCP or any other local policies or ordinances protecting biological species. Therefore, the 2025 SEIR determined that impacts to biological resources would be consistent with determinations made by previous CEQA documents and impacts to biological resources would be less than significant with previously approved Mitigation Measures BIO-1 through BIO- 5. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV 6(,500%,2The project proponents of any development affecting jurisdictional waters of the U.S. or vegetated wetlands shall obtain Section 401, Section 404, Section 1602, and other certifications, approvals, and permits, as necessary. Copies of the necessary state and federal permits shall be provided to the City prior to the issuance of mass or grading permits for grading activities impacting jurisdictional areas. A replacement ratio for affected wetland resources shall be determined in consultation with regulatory agencies as part of the permitting process and shall be no less than 1:1 replacement of function and value. Additional criteria and requirements will be as follows: x Create (establish), restore, or enhance wetland/riparian habitats on-site to the maximum extent practicable to minimize and replace the on-site loss of USACE and CDFG jurisdictional acreage and function, or off-site as may be permitted by the USACE and CDFG. x To return jurisdictional habitats that are temporarily disturbed during construction to preconstruction conditions. x To provide for maintenance, management and monitoring of the mitigation site or sites for a minimum of three years as determined through the permitting process. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV 7/636(,500%,2 Biological surveys shall be conducted by a qualified biologist to determine the potential for special status species within the project site for all future projects at the time that development is proposed. The project-level biological survey report shall analyze these projects’ impacts on sensitive animal species and shall propose mitigation to reduce project impacts to a less than significant level. D +DYHDVXEVWDQWLDODGYHUVHHIIHFWHLWKHUGLUHFWO\RUWKURXJKKDELWDWPRGLILFDWLRQVRQDQ\VSHFLHV LGHQWLILHGDVDFDQGLGDWHVHQVLWLYHRUVSHFLDOVWDWXVVSHFLHVLQORFDORUUHJLRQDOSODQVSROLFLHVRU UHJXODWLRQVRUE\WKH&DOLIRUQLD'HSDUWPHQWRI)LVKDQG*DPHRU86)LVKDQG:LOGOLIH6HUYLFH" The TLSP 2025 SEIR concluded that with the inclusion of Mitigation Measures BIO-2, BIO-3, BIO-4, and BIO- 5, the upzoning of residential units would result in less than significant impacts to candidate, sensitive, or special status species (City of Tustin, 2025c). The burrowing owl was listed as a candidate species after 230 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 66 completion of the TLSP 2025 FEIR. However, with implementation of Mitigation Measure BIO-5, pre- construction surveys would be required prior to grading to ensure biological conditions remain consistent with previous biological surveys. ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe Project site consists of approximately 6.14 acres that were previously analyzed in the TLSP 2025 SEIR. The Project site is disturbed and graded and does not contain existing vegetation. Implementation of the Project is unlikely to cause impacts to biological resources due to the existing conditions and minimal vegetation on the Project site. In addition, TLSP 2025 SEIR MM BIO-5 has been included to require biological surveys at the time of future development which would be reviewed by the City to confirm site conditions are consistent with previous findings and additional impacts wouldn’t occur as a result of the proposed Project. Biological surveys, including burrowing owl pre-construction surveys, if determined to be required, shall be submitted prior to the issuance of grading permits. In the event that biological conditions not covered within this addendum are identified, additional CEQA analysis would be conducted to determine whether impacts are consistent with the TLSP FEIR record and meet criteria under CEQA Guidelines Section 15162. As such, implementation of the Project would not result in new impacts to any special status species or their habitats. No new impact would occur in relation to biological resources and there is no change from what was analyzed in the TLSP 2025 SEIR. E +DYHDVXEVWDQWLDODGYHUVHHIIHFWRQDQ\ULSDULDQKDELWDWRURWKHUVHQVLWLYHQDWXUDOFRPPXQLW\ LGHQWLILHGLQORFDORUUHJLRQDOSODQVSROLFLHVUHJXODWLRQVRUE\WKH&DOLIRUQLD'HSDUWPHQWRI)LVK DQG*DPHRU86)LVKDQG:LOGOLIH6HUYLFH" The TLSP 2025 SEIR concluded that with the inclusion of Mitigation Measure BIO-1, impacts to riparian habitat or other sensitive natural communities would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe jurisdictional delineation conducted for the 2001 FEIS/EIR identified Waters of the US and wetlands protected under the federal Clean Water Act; but not Waters of the State or riparian habitats jurisdictional to CDFW. The 2006 Addendum identified 0.8 acres of riparian habitat. The previously approved 2006 Addendum also shows that jurisdictional waters were previously mapped within the TLSP area. The TLSP 2025 SEIR also completed a biological records search and did not identify new sensitive natural communities that could be impacted. However, as mentioned previously, a biological assessment and survey would be conducted prior to grading permits to ensure there are no sensitive biological resources within the Project site. In compliance with 2017 SEIR MM BIO-1, the Project would be required to obtain permits from CDFW, the Regional Water Quality Control Board (RWQCB), and the US Army Corps of Engineers (Corps). However, according to the 2024 Annual Mitigation Monitoring Report, the City already has existing 401(RWQCB), 404 (Corps), and 1602 (CDFW/CFG) permits for the Project area, which the applicant would be required to comply with and coordinate with the City on, respectively. With implementation of 2017 SEIR MM BIO-1, impacts to riparian habitat or other sensitive natural community would be reduced to a less than significant impact. As such, implementation of the Project would not result in new impacts to any special status species or their habitats. No new impact would occur and there is no change from the previous analysis.  231 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 67 F +DYHDVXEVWDQWLDODGYHUVHHIIHFWRQVWDWHRUIHGHUDOO\SURWHFWHGZHWODQGV LQFOXGLQJEXWQRWOLPLWHG WRPDUVKYHUQDOSRROFRDVWDOHWF WKURXJKGLUHFWUHPRYDOILOOLQJK\GURORJLFDOLQWHUUXSWLRQRU RWKHUPHDQV" The TLSP 2025 SEIR concluded that with the inclusion of Mitigation Measure BIO-1, impacts to wetlands would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe jurisdictional delineation conducted for the 2001 FEIS/EIR identified Waters of the US and wetlands protected under the federal Clean Water Act. The previously approved 2006 Addendum also identified 0.68 acres of federally protected wetlands within the TLSP area and identified mitigation measures to reduce impacts.The development area for the proposed Project is within the TLSP area which was previously analyzed in the TLSP 2025 SEIR. As mentioned previously, the Project would be required to obtain permits from CDFW, the RWQCB, and the Corps. However, according to the 2024 Annual Mitigation Monitoring Report, the City has 401(RWQCB), 404 (Corps), and 1602 (CDFW/CFG) permits for the Project area, which the applicant would be required to comply with and coordinate with the City on, respectively. Therefore, with implementation of MM BIO-1, impacts to federally protected wetlands would be less than significant. As such, implementation of the Project would not result in new impacts to wetlands. No new impact would occur and there is no change from the previous analysis. G ,QWHUIHUHVXEVWDQWLDOO\ZLWKWKHPRYHPHQWRIDQ\QDWLYHUHVLGHQWRUPLJUDWRU\ILVKRUZLOGOLIHVSHFLHV RUZLWKHVWDEOLVKHGQDWLYHUHVLGHQWRUPLJUDWRU\ZLOGOLIHFRUULGRUVRULPSHGHWKHXVHRIQDWLYH ZLOGOLIHQXUVHU\VLWHV" The TLSP 2025 SEIR determined that impacts to the movement of any native residents or migratory wildlife would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWExisting vegetation onsite is limited and the Project site has been graded. Previous environmental documents prepared determined that the Project area does not support wildlife movement or a wildlife corridor due to surrounding development and lack of available habitat. Additionally, as mentioned previously, a biological survey would be conducted prior to any grading activities to confirm the absence of biological resources. Therefore, implementation of the Project would not interfere with wildlife movement, and no new impact would occur. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. H &RQIOLFW ZLWK DQ\ ORFDO SROLFLHV RU RUGLQDQFHV SURWHFWLQJ ELRORJLFDO UHVRXUFHV VXFK DV D WUHH SUHVHUYDWLRQSROLF\RURUGLQDQFH" The TLSP 2025 SEIR determined that impacts related to local polices and ordinances would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe TLSP 2025 SEIR concluded there are no local policies protecting biological resources that buildout of the TLSP would conflict with. Given that the City’s General Plan was updated in 2018, the TLSP 2025 SEIR prepared a consistency table for 2018 General Plan policies that protect biological resources and determined that the TLSP would not conflict with goals and policies identified in the updated General Plan. No additional biological resource policies have been adopted since the adoption of the 2025 TLSP SEIR, therefore the Project would not interfere with local policies or ordinances protecting biological resources, and no new impact would occur. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. 232 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 68 I &RQIOLFW ZLWK WKH SURYLVLRQV RI DQ DGRSWHG +DELWDW &RQVHUYDWLRQ 3ODQ 1DWXUDO &RPPXQLW\ &RQVHUYDWLRQ3ODQRURWKHUDSSURYHGORFDOUHJLRQDORUVWDWHKDELWDWFRQVHUYDWLRQSODQ" The TLSP 2025 SEIR determined that impacts related to conservation plans would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe TLSP 2025 SEIR concluded that the TLSP area is within the plan area of the Orange County Central-Coastal NCCP/HCP; however, the Project site is not within a reserve established under the NCCP/HCP. The plan identifies and prioritizes potential restoration areas within the reserve and provides detailed information on the most effective methods of associated costs of restoration activities. Additionally, the Orange County Transportation Authority (OCTA) prepared a NCCP/HCP as a mechanism to offset potential project-related effects on threatened and endangered species and their habitats in a comprehensive manner. The OCTA NCCP/HCP was finalized in the Spring of 2017 and covers 13 listed and non-listed species including: plants: intermediate mariposa lily, many-stemmed dudleya, and southern tarplant; fish: arroyo chub; reptiles: coast horned lizard, orangethroat whiptail, and western pond turtle; birds: cactus wren, coastal California gnatcatcher, least Bell’s vireo, and southwestern willow flycatcher; and mammals: bobcat and mountain lion. The OCTA NCCP/HCP is applicable to the areas acquired for conservation purposes, as well as any projects that would occur within OCTA right-of-way. While the Project would not directly impact OCTA right-of-way, the proposed Project would be required to prepare a biological assessment and survey prior to grading permit approvals (TLSP 2025 SEIR MM BIO-5) as mentioned previously to ensure there are no sensitive biological resources within the Project site including the above-listed species which would demonstrate consistency with the OCTA NCCP/HCP. In the event that biological conditions not covered within this addendum are identified, additional CEQA analysis would be conducted to determine whether impacts are consistent with the TLSP FEIR record and meet criteria under CEQA Guidelines Section 15162. Project site is anticipated to result in less than significant impacts to sensitive species covered under the NCCP/HCP applicable to the area. Further, the Project site is not located in an area proposed for conservation establishment. Thus, the proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR . Conclusion Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate proposed Project impacts or mitigation measures regarding energy. There have not been 1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; 2) substantial changes with respect to the circumstances under which development of the Project site is undertaken that require major revisions of the TLSP 2025 SEIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or 3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the TLSP 2025 SEIR was certified as completed. Because none of the conditions identified in CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts, CEQA Guidelines 15168 also does not require additional environmental review, and the Project is within the scope of the TLSP 2025 SEIR with respect to biological resources. 3ODQV3URJUDPVRU3ROLFLHV 333V  233 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 69 None. 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG Final EIR mitigation measures that are applicable to the proposed Project would be implemented as intended by the TLSP 2025 SEIR. After implementation of the applicable mitigation measures, no new impacts nor substantially more severe biological resource impacts would result from implementation of the proposed Project; therefore, no new or revised mitigation measures are required for biological resources. TLSP 2017 SEIR Mitigation Measures Applicable to the Proposed Project: 6(,500%,2As listed above. TLSP 2025 SEIR Mitigation Measures Applicable to the Proposed Project: 7/636(,500%,2 As listed above.  234 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 70 5.4. ENERGY 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Would the project:Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact a) Result in potentially significant environmental impacts 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? ,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ x The 2001 EIR/EIS and the TLSP 2017 SEIR did not include a standalone Energy analysis, as CEQA Guidelines had not yet been amended to require detailed energy evaluations at the time those documents were prepared. x The TLSP 2025 SEIR concluded that, with implementation of the existing California Energy Code (Code of Regulations, Title 24 Part 6), the TLSP 2025 SPA would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during construction or operation, and impacts would be less than significant. x During construction, buildout of the TLSP 2025 SPA would consume approximately 722,247.3 gallons of diesel fuel per year and approximately 1,797,763.8 gallons of gasoline per year, which is an increase of 158,694.6 gallons of diesel fuel per year and approximately 828,461.5 gallons of gasoline per year over buildout of the existing TLSP. x During operations, vehicle trips associated with the buildout of the TLSP 2025 SPA have been estimated to increase the annual fuel use in Orange County by approximately 0.8 percent for gasoline and approximately 0.6 percent for diesel. Fuel consumption associated with vehicle trips generated by the TLSP 2025 SPA were determined to not be inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. x The TLSP 2025 SEIR determined that the TLSP 2025 SPA would not conflict with any plan for renewable energy or energy efficiency, and no impacts would occur. x In regard to cumulative impacts, the TLSP 2025 SEIR determined that, with implementation of existing energy conservation regulations, cumulative electricity and natural gas consumption would not be cumulatively wasteful, inefficient, or unnecessary. Additionally, the consumption of petroleum would not occur in a wasteful, inefficient, or unnecessary manner and would be less than cumulatively considerable because state fuel efficiency standards and alternative fuels policies (per AB 1007 Pavely) would contribute to a reduction in fuel use, and the Federal Energy Independence and Security Act and the 235 □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 71 State Long Term Energy Efficiency Strategic Plan would reduce reliance on non-renewable energy resources. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV None. D 5HVXOWLQSRWHQWLDOO\VLJQLILFDQWHQYLURQPHQWDOLPSDFWVGXHWRZDVWHIXOLQHIILFLHQWRUXQQHFHVVDU\ FRQVXPSWLRQRIHQHUJ\UHVRXUFHVGXULQJSURMHFWFRQVWUXFWLRQRURSHUDWLRQ" The TLSP 2025 SEIR determined that impacts related to wasteful, inefficient, or unnecessary consumption of energy resources would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW Construction Construction of the proposed Project would consume energy in three general forms: 1. Petroleum-based fuels used to power off-road construction vehicles and equipment on the Project site, construction worker travel to and from the Project site, as well as delivery truck trips; 2. Electricity associated with providing temporary power for lighting and electric equipment; and 3. Energy used in the production of construction materials, such as asphalt, steel, concrete, pipes, and manufactured or processed materials such as lumber and glass. Construction activities related to the development of the site for new senior residential uses would be permitted to require compliance with existing fuel standards, machinery efficiency standards, and CARB requirements that limit idling of trucks. Truck idling is regulated by CCR Title 13, Motor Vehicles, Section 2449(d)(3) Idling, that limits idling times of construction vehicles to no more than 5 minutes, thereby precluding unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment. Additionally, construction contractors are required to demonstrate compliance with applicable California Air Resources Board (CARB) regulations governing the accelerated retrofitting, repowering, or replacement of heavy-duty diesel on- and off-road equipment during the City’s construction permitting process. Compliance with existing CARB idling restrictions and the use of newer engines and equipment would reduce fuel combustion and energy consumption. As indicated in Table E-1, Estimated Construction Energy Usage, buildout of the TLSP would consume approximately 722,247.3 gallons of diesel fuel per year and approximately 1,797,763.8 gallons of gasoline per year during construction. 7DEOH((VWLPDWHG&RQVWUXFWLRQ(QHUJ\8VDJH (QHUJ\7\SH7RWDO(QHUJ\&RQVXPSWLRQ$QQXDO(QHUJ\&RQVXPSWLRQ Diesel Fuel (total gallons) 14,444,946.8 722,247.3 Gasoline (total gallons) 35,955,276.2 1,797,763.8 Note: The annual energy consumption was calculated by averaging the total energy consumption over the 20-year buildout period. Source: TLSP 2025 SEIR The proposed Project would introduce 142,566 SF of non-residential uses and 172 residential units within Neighborhood D South, which allows a maximum buildout of 606,00 SF of non-residential uses and a total of 2,427 (including density bonus units) residential units. Therefore, assumptions for energy consumption 236 I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 72 during construction of the proposed Project have already been analyzed and implementation of the proposed Project would result in no new impacts. Through compliance with existing standards, the Project would not result in a greater demand for fuel on a per-development basis than other development projects in Southern California. There are no unusual Project characteristics that would cause the use of less energy-efficient construction equipment compared with other similar construction sites in other parts of the State. Therefore, construction-related fuel consumption by the Project would not result in inefficient, wasteful, or unnecessary energy use compared with other construction sites in the region, and impacts would be less than significant. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. Operation Once operational, the Project would consume electricity, natural gas, and petroleum. Operational use of energy includes the heating, cooling, and lighting of the building, water heating, operation of electrical systems and plug-in appliances, parking lot and outdoor lighting, and the transport of electricity, natural gas, and water to the areas where they would be consumed. This use of energy is typical for urban development, and no operational activities or land uses would occur that would result in extraordinary energy consumption. As indicated in Table E 2, Estimated Operational Energy Usage at Buildout, buildout of the TLSP would consume approximately 82,337,291 kWh per year of electricity, 1,946,109 therms per year of natural gas, 9,171,101.2 gallons per year of gasoline, and 965,303.8 gallons per year of diesel fuel. Since the proposed Project would introduce 142,566 SF of non-residential uses and 172 residential units within Neighborhood D South, and a maximum of 606,000 SF of non-residential uses and 2,427 residential units (including density bonus units) were previously approved for Neighborhood D in the TLSP 2025 SEIR, the impacts of the proposed Project have already been analyzed. Therefore, implementation of the proposed Project would result in no new impacts. 7DEOH((VWLPDWHG2SHUDWLRQDO(QHUJ\8VDJHDW%XLOGRXW (QHUJ\7\SH$QQXDO(QHUJ\&RQVXPSWLRQ Electricity Consumption (kWh/year) 82,337,291 Natural Gas Consumption (therms/year) 1,946,109 Gasoline (gallons/year) 9,171,101.1 Diesel Fuel (gallons/year) 965,303.8 Notes: kWh: kilowatts Source: TLSP 2025 SEIR The State of California provides a minimum standard for building design and construction standards through Title 24 of the California Code of Regulations (CCR). Compliance with Title 24 is mandatory at the time new building permits are issued by the City that the Project shall comply with the adopted California Energy Code (Code of Regulations, Title 24 Part 6). The City’s administration of the Title 24 requirements includes review of design components and energy conservation measures during the permitting process, which ensures that all requirements are met. Typical Title 24 measures include insulation; use of energy-efficient heating, ventilation and air conditioning (HVAC) equipment; energy-efficient indoor and outdoor lighting systems; reclamation of heat rejection from refrigeration equipment to generate hot water; and incorporation of skylights, etc. In complying with the Title 24 standards, impacts to peak energy usage periods would be minimized, and impacts on statewide and regional energy needs would be reduced. 237 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 73 The Project is within the scope of the buildout assumptions for the TLSP, as analyzed in the TLSP 2025 SEIR and no new impacts related to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation would occur. E &RQIOLFWZLWKRUREVWUXFWDVWDWHRUORFDOSODQIRUUHQHZDEOHHQHUJ\RUHQHUJ\HIILFLHQF\" The TLSP 2025 SEIR determined that there would be no impact related to obstruction of state or local plans for renewable energy or energy efficiency (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWProposed development projects pursuant to the TLSP 2025 SEIR would be required to meet the CCR Title 24 energy efficiency standards in effect during the permitting process. The Title 24 Building Energy Efficiency Standards are designed to ensure new and existing buildings achieve energy efficiency and preserve outdoor and indoor environmental quality. The California Energy Commission is responsible for adopting, implementing and updating building energy efficiency. The City’s administration of the CCR Title 24 requirements includes review of design components and energy conservation measures that occurs during the permitting process, which ensures that all requirements are met. In addition, the Project would not conflict with or obstruct opportunities to use renewable energy, such as solar energy. Further, the proposed Project would not introduce new uses compared to what was previously analyzed, therefore the Project would be consistent with policies related to renewable energy or energy efficiency listed in the City’s General Plan as analyzed in the TLSP 2025 SEIR. Thus, the proposed Project would not interfere with any existing plans and there would be no new impacts. &RQFOXVLRQ Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate proposed Project impacts or mitigation measures regarding biological resources. There have not been 1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; 2) substantial changes with respect to the circumstances under which development of the Project site is undertaken that require major revisions of the TLSP 2025 SEIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or 3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the TLSP 2025 SEIR was certified as completed. Because none of the conditions identified in CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts, CEQA Guidelines 15168 also does not require additional environmental review, and the Project is within the scope of the TLSP 2025 SEIR with respect to energy. 3ODQV3URJUDPVRU3ROLFLHV 333V  x California Energy Code. 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG None. 238 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 74 5.5. GREENHOUSE GAS EMISSIONS 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Would the project:Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact 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? ,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ The certified 2001 FEIS/EIR did not evaluate greenhouse gas (GHG) emissions impacts because it was not included in the CEQA Guidelines Appendix G checklist, and the City of Tustin had not adopted GHG thresholds at the time of preparation. However, the TLSP 2017 and 2025 SEIR did analyze GHG emissions. x The TLSP 2017 SEIR found that annual GHG emissions associated with both the Adopted MCAS (later renamed Adopted TLSP), and the 2017 TLSP SPA would exceed the SCAQMD bright-line threshold of 3,000 MTCO2e per year. Thus, GHG impacts were determined to be significant and unavoidable. In addition, both the Adopted MCAS and 2017 TLSP SPA would also exceed the AB 32 and forecasted SB 32 efficiency metrics. However, under full buildout conditions, the 2017 TLSP SPA would reduce annual emissions by 12,239 MTCO2e per year compared to the Adopted MCAS, which represents a 5 percent overall decrease. The reductions would primarily be in the energy and transportation sectors. For the energy sector, the reduction is attributed to the overall decrease in non-residential SF. TLSP 2017 SEIR MMs AQ-3 and AQ-4 related to non-residential projects were included to reduce potentially significant GHG emissions, which were focused on the future implementation of Transportation Demand Management (TDM) techniques. With implementation of TLSP 2017 SEIR MMs AQ-3 and AQ-4 related to non-residential project trips, impacts would remain significant and unavoidable. x The Initial Study prepared for the TLSP 2017 SEIR determined that the 2017 TLSPA would be consistent with both applicable plans adopted for the purposes of reducing GHG emissions: CARB’s 2008 Scoping Plan and SCAG’s 2012 Regional Transportation Plan & Sustainable Communities Strategy (RTP/SCS). Therefore, impacts were determined to be less than significant. x The TLSP 2025 SEIR concluded that construction and operation of the new residential uses proposed in the TLSP 2025 SPA would generate 115,031.4 MTCO2e per year (MTCO2e/yr), an increase of approximately 35,133.7 MTCO2e/yr over buildout of the existing TLSP which would exceed the SCAQMD threshold of 3,000 MT CO2e/yr. The TLSP 2025 SEIR concluded that 2017 SEIR MMs AQ-3, MM AQ-4, MM AQ-5; TLSP 2025 SEIR MM AQ-1 through MM AQ-4, and TLSP 2025 SEIR MM GHG-1 239 □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 75 through MM GHG-3 would contribute to GHG emission reductions, however, impacts related to GHG emissions from the TLSP 2025 SEIR would remain significant and unavoidable. x Regarding consistency with an applicable plan, policy, or regulation, the TLSP 2025 SEIR identified less than significant impacts with implementation of the existing Title 24 requirements. x The TLSP 2025 SEIR concluded that, because the estimated increase in GHG emissions from buildout of the proposed TLSP Amendment would exceed the 3,000 MTCO2e/yr screening threshold, cumulative impacts from the TLSP 2025 SPA would be significant and cumulatively considerable. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV 6(,500$4: As listed previously in Section 5.1, Air Quality. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV 7/636(,500$4 9HKLFOH7ULS5HGXFWLRQ As listed previously in Section 5.1, Air Quality. 7/636(,500$43URKLELWLRQRI)LUHSODFHV As listed previously in Section 5.1, Air Quality. 7/636(,500$4(OHFWULF/DQGVFDSH(TXLSPHQWAs listed previously in Section 5.1, Air Quality. 7/636(,500*+*6RODU3DQHOVProjects shall be required to install solar photovoltaic (PV) panels or other source of renewable electricity generation onsite, based on the maximum roof area available for solar (i.e., solar-ready zone). The solar-ready zone shall in the minimum, comply with Section 110.10 of the 2022 California Energy Code and shall comply with access, pathway, ventilation, and spacing requirements, and exclude skylight area. The final PV generation facility size requires approval by Southern California Edison (SCE). SCE’s Rule 21 governs operating and metering requirements for any facility connected to SCE’s distribution system. Should SCE limit the offsite export, the Projects may utilize a battery energy storage system (BESS) to lower offsite export while maintaining onsite renewable generation to offset consumption. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage. The schedule of photovoltaic system locations may be updated as needed. 7/636(,500*+*/(('&DO*UHHQ7LHU&KDUJLQJ6WDWLRQV. Prior to the issuance of building permits, project applicant or successor in interest shall provide documentation to the City of Tustin demonstrating the following: x The project shall be designed to achieve Leadership in Energy and Environmental Design (LEED) certification to meet or exceed CALGreen Tier 2 standards in effect at the time of building permit application in order to exceed 2022 Title 24 energy efficiency standards. x The project shall provide facilities to support electric charging stations per the Tier 2 standards in Section A5.106.5.3 (Non-residential Voluntary Measures) and Section A5.106.8.2 (Residential Voluntary Measures) of the 2022 CALGreen Code. 7/636(,500*+*(QHUJ\(IILFLHQW$SSOLDQFHV. All major applicant provided in-unit residential appliances (e.g., dishwashers, refrigerators, clothes washers and dryers, water heaters, and for space heating) provided/installed shall be electric (i.e., appliances that do not use natural gas, propane, or other fossil fuels) and Energy Star certified or of equivalent energy efficiency where applicable. Prior to the issuance of the certificate of occupancy, the City of Tustin shall verify implementation of this requirement. Installation of electric Energy Star–certified or equivalent appliances shall be verified by the Planning and Building Department during plan check. 240 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 76 D *HQHUDWHJUHHQKRXVHJDVHPLVVLRQVHLWKHUGLUHFWO\RULQGLUHFWO\WKDWPD\KDYHDVLJQLILFDQWLPSDFW RQWKHHQYLURQPHQW" The TLSP 2025 SEIR concluded that GHG emissions associated with buildout of the 2025 TLSPA were determined to be significant and unavoidable. (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW The proposed Project would generate GHG emissions from construction and operational activities. Construction emissions would occur from equipment exhaust, worker trips, and material hauling. Operational emissions would result from mobile sources (i.e., vehicle trips) and energy consumption on-site. The proposed Project would develop 142,566 SF of non-residential institutional uses and 172 residential units which are within the maximum scope of the 606,000 SF of non-residential development and 2,427 residential units (including density bonus units) allowed within Neighborhood D South and analyzed in the TLSP 2025 SEIR. As described in the TLSP 2025 SEIR, buildout of the 2025 TLSPA, including buildout of Neighborhood D South would exceed the SCAQMD threshold of 3,000 MT CO2e/yr. Given that the Project is within the buildout assumptions of the TLSP 2025 SEIR, GHG emissions would result in a significant and unavoidable impact. To reduce construction emissions, however, the Project would be required to implement TLSP 2017 SEIR MM AQ-5, which requires the use of equipment meeting CARB Tier 4 emissions standards or higher for off-road diesel-powered construction equipment with more than 50 horsepower during construction activities. Additionally, TLSP 2025 SEIR MM AQ-1 through SEIR MM AQ-4 , as previously described above have been incorporated to reduce air quality impacts and GHG emissions. Compliance with TLSP 2025 SEIR MM GHG- 1 which requires installation of photovoltaic solar panels; TLSP 2025 SEIR MM GHG-2 which requires new development projects meet or exceed CALGreen Tier 2 standards with charging stations; and TLSP 2025 SEIR MM GHG-3 which requires use of energy efficient appliances would also be required to further reduce emissions. Given that the Project’s within the scope of the maximum buildout assumptions analyzed for Neighborhood D South by the TLSP 2025 SEIR, GHG emissions from the proposed Project would not result in any new or substantially greater impacts than those previously disclosed. Impacts would remain consistent with the conclusions of the TLSP 2025 SEIR. E &RQIOLFWZLWKDQDSSOLFDEOHSODQSROLF\RUUHJXODWLRQDGRSWHGIRUWKHSXUSRVHRIUHGXFLQJWKH HPLVVLRQVRIJUHHQKRXVHJDVHV" The TLSP 2025 SEIR concluded that implementation of the TLSP would not conflict with any applicable plan, policy, or regulation related to the reduction of GHG emissions, and impacts were determined to be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW The proposed Project would not conflict with any applicable plan, policy, or regulation adopted to reduce GHG emissions. It would be consistent with the CARB Scoping Plan, which sets statewide strategies to meet the goals of Assembly Bill (AB) 32. The Project would incorporate design features and regulatory compliance that align with CARB’s recommended GHG reduction measures. The Project would be implemented pursuant to the CALGreen Building/Title 24 requirements, as adopted by reference in the TCC. Title 24 measures include insulation; use of energy-efficient heating, ventilation, and air conditioning equipment; solar-reflective roofing materials; energy-efficient indoor and outdoor lighting systems; reclamation of heat rejection from refrigeration equipment to generate hot water; and incorporation of skylights, and solar infrastructure. In complying with the Title 24 standards, the Project would 241 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 77 implement regulations that reduce GHG emissions. The Project area is served by bus transit services and the Project would include sidewalks and pedestrian crossings for all of the onsite roadways, which would encourage non-motorized travel, which reduces GHG emissions. Therefore, the proposed Project would not conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing GHG emissions, and impacts would be less than significant consistent with the TLSP 2025 SEIR. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. &RQFOXVLRQ Based on the foregoing, none of the conditions set forth in CEQA Guidelines Section 15162 that would necessitate preparation of a subsequent or supplemental EIR, or other environmental document, are present with respect to GHG emissions. Specifically, there have not been: (1) changes to the Project or its development that would result in new significant environmental effects or a substantial increase in the severity of previously identified impacts; (2) substantial changes in the circumstances under which the Project is undertaken that would require major revisions to the Final EIR due to new or more severe impacts; or (3) the availability of new information of substantial importance that was not known and could not have been known at the time the TLSP 2025 SEIR was certified. Accordingly, because none of the criteria in Section 15162 are met, additional environmental review under CEQA Guidelines Section 15168 is not required. The Project remains within the scope of the TLSP 2025 SEIR as it relates to GHG emissions. 3ODQV3URJUDPVRU3ROLFLHV 333V  x California Assembly Bill 1493 (Pavley) x California Executive Order S-3-05 x Assembly Bill 32 (Global Warming Solutions Act of 2006) x Senate Bill 375 (Steinberg) x California Executive Order B-30-15 x Assembly Bill 1279 (Carbon Neutrality) x California Energy Code x California Green Building Standards Code 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG Final EIR mitigation measures that are applicable to the proposed Project would be implemented as intended by the TLSP 2025 SEIR. After implementation of the applicable mitigation measures, no new impacts nor substantially more severe greenhouse gas impacts would result from implementation of the proposed Project; therefore, no new or revised mitigation measures are required regarding greenhouse gas. TLSP 2017 SEIR Mitigation Measures Applicable to the Proposed Project: 6(,500$4: As listed previously in Section 5.1, Air Quality. TLSP 2025 SEIR Mitigation Measures Applicable to the Proposed Project: 7/636(,500$4 9HKLFOH7ULS5HGXFWLRQ As listed previously in Section 5.1, Air Quality. 242 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 78 7/636(,500$43URKLELWLRQRI)LUHSODFHV As listed previously in Section 5.1, Air Quality. 7/636(,500$4(OHFWULF/DQGVFDSH(TXLSPHQWAs listed previously in Section 5.1, Air Quality. 7/636(,500$4/RZ92&3DLQW 2SHUDWLRQV . As listed previously in Section 5.1, Air Quality. 7/636(,500*+*6RODU3DQHOVAs listed above. 7/636(,500*+*/(('&DO*UHHQ7LHU&KDUJLQJ6WDWLRQV. As listed above. 7/636(,500*+*(QHUJ\(IILFLHQW$SSOLDQFHV. As listed above. 243 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 79 5.6. LAND USE AND PLANNING 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Would the project:Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact a) Physically divide an established community? b) Cause a significant environmental impact due to conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? ,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ x The 2001 FEIS/EIR determined that the TLSP required amendments to the cities of Tustin and Irvine General Plans and Zoning Ordinances. The 2001 FEIS/EIR found that the intensification and change of land uses pursuant to the MCAS Tustin Specific Plan could create land use incompatibilities with surrounding land uses and internal incompatibilities within the TLSP area. Mitigation measures were incorporated requiring the City of Tustin and the City of Irvine to amend their General Plan and Zoning Ordinance to be consistent with the TLSP. The measures also require that the appearance of future development on the site is similar to other master planned areas adjacent to the specific plan area. x In 2001, the City of Tustin adopted a General Plan land use designation “MCAS Tustin Specific Plan,” and the MCAS Tustin Specific Plan was adopted on February 3, 2003 (Ordinance 1257). As described previously, the MCAS Tustin Specific Plan established the zoning designations, development standards, and entitlement framework for future development in the Specific Plan area. x The TLSP 2017 SEIR analyzed the TLSP 2017 SPA consistency with the Tustin General Plan, SCAG 2016– 2040 RTP/SCS, and the Airport Environs Land Use Plan (AELUP) for John Wayne Airport. Overall, the SEIR determined that the 2017 SEIR would be consistent with all applicable land use plans. x The TLSP 2025 SEIR analyzed consistency with the Tustin General Plan, SCAG 2024-2050 Regional RTP/SCS (Connect SoCal 2024), and the AELUP for John Wayne Airport. Overall, the SEIR determined that the TLSP 2025 SPA would have less than significant impact with implementation of 2001 FEIS/EIR (referred to as the MCAS FEIR/EIS in the TLSP 2025 SEIR) and existing regulatory programs. x In regard to cumulative impacts, the TLSP 2025 SEIR concluded that cumulative impacts would be less than significant. Overall, the TLSP 2025 SPA, in combination with buildout of the Tustin General Plan, was determined to be a desired and intended impact of the policies outlined in the General Plan and 2016–2040 RTP/SCS. Additionally, potential future development implemented within the TLSP would be required comply with existing 2001 FEIR/EIS (a) through (x), which establish requirements for future planning, funding, and implementation of expanded amenities, utilities, and services as a result of 244 □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 80 anticipated growth. Therefore, it was determined that the Approved Project would result in a less than significant project-level impact and impacts would not be cumulatively considerable. )(,5(,6$SSOLFDEOH0LWLJDWLRQ0HDVXUHV The TLSP 2025 SEIR identified the following measures from the 2001 FEIS/EIR (referred to as the MCAS FEIR/EIS in the TLSP 2025 SEIR) that are applicable to future development within the TLSP: D The City of Tustin or City of Irvine, as appropriate, shall ensure that infrastructure is constructed in phases as triggered by identified thresholds in Table 4-2 of the revised Specific Plan Phasing Plan, Phasing Plan Requirements (see Table 4-2 at the end of this Mitigation Monitoring and Reporting Program). The Phasing Plan provides an organizational framework to facilitate development of the reuse plan area in tandem with infrastructure necessary to support the planned development. (As amended by Addendum) This framework reflects the fact that each component of the infrastructure has its own threshold for accommodating additional development toward build out of the reuse plan area. The triggering mechanisms that identify timing of key infrastructure provisions are summarized in Table 4-2 of the revised Specific Plan Phasing Plan, Phasing Plan Requirements (see Table 4-2 at the end of this Mitigation Monitoring and Reporting Program). E Prior to a final map recordation (except for financing and re-conveyance purposes), the development applicant shall enter into an agreement with the City of Tustin and City of Irvine and any appropriate regional utility agencies, districts, and providers, as applicable, to dedicate all easement, right-of-ways, or other land determined necessary to construct adequate utility infrastructure and facilities to serve the project as determined by the City, Agency, District, or other providers. F Prior to any final map recordation (except for financing and conveyance purposes), the development applicant shall enter into a secured agreement with the cities of Tustin and/or Irvine, as applicable, to participate on a pro-rated basis in construction of capital improvements necessary to provide adequate utility facilities. G Prior to the issuance of permits for any public improvements or development project, a development applicant shall submit to the City of Tustin and City of Irvine, as applicable, information from IRWD which outlines required facilities necessary to provide adequate potable water and reclaimed water service to the development. H Prior to the issuance of building permits, the project developer shall ensure that fire hydrants capable of flows in amounts approved by the OCFA are in place and operational to meet fire flow requirements. (As amended by Addendum) I Prior to the issuance of permits for any public improvements or development project, a development applicant shall submit to the City of Tustin and City of Irvine, as applicable, information from IRWD or the City of Tustin which outlines required facilities necessary to provide adequate sanitary sewage service to the development. J Prior to the issuance of grading permits or approval of any subdivision map (except for financing and re-conveyance purposes), whichever occurs first, for development within the 100 year flood plain, grading and drainage systems shall be designed by the project developer such that all building pads would be safe from inundation from runoff from all storms up to and including the theoretical 100 year storm, to the satisfaction of the City of Tustin Building Division or the Irvine 245 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 81 Public Works Department, as applicable. Grading permits or subdivision maps generated for financing and conveyance purposes are exempt. K Prior to construction of regional flood control facilities, appropriate state and federal approvals, including agreements and permits, shall be obtained. These include but are not limited to Regional Water Quality Control Board permits, including NPDES permits; Section 401 water quality certifications; Section 404 permits from the USACOE, and Section 1601 or 1603 agreements from the CDFG in a manner meeting the approval of the City of Tustin and the Irvine Public Works Department, as applicable. (As amended by Addendum) L Prior to issuance of any grading permit or approval of any subdivision map (except for financing and conveyance purposes), for any development that is either partially or completely located within the 100 year flood plain of the Flood Insurance Rate Map, the development applicant shall submit all required documentation to the FEMA and demonstrate that the application for a Conditional Letter of Map Revision for changes to the 100 year flood plain is satisfied in a manner meeting the approval of each respective city, as applicable. M Prior to the approval of any applicable subdivision map (except for financing and conveyance purposes), the developer applicant shall design and construct local drainage systems for conveyance of the 10 year runoff. If the facility is in a local sump, it shall be designed to convey the 25 year runoff. N Prior to any grading for any new development, the following drainage studies shall be submitted to and approved by the City of Tustin, City of Irvine, and/or OCFCD, as applicable: (1) A drainage study including diversions (i.e., off site areas that drain onto and/or through the project site), with justification and appropriate mitigation for any proposed diversion. (2) A drainage study evidencing that proposed drainage patterns would not result in increased 100 year peak discharges within and downstream of the project limits, and would not worsen existing drainage conditions at storm drains, culverts, and other street crossings including regional flood control facilities. The study shall also propose appropriate mitigation for any increased runoff causing a worsening condition of any existing facilities within or downstream of project limits. Implementation of appropriate interim or ultimate flood control infrastructure construction must be included. (3) Detailed drainage studies indicating how, in conjunction with the drainage conveyance systems including applicable swales, channels, street flows, catch basins, storm drains, and flood water retarding, building pads are made safe from runoff inundation which may be expected from all storms up to and including the theoretical 100 year flood. O Prior to approval of any subdivision map (except for financing or conveyance purposes), an agreement will be executed with the OCFCD that provides for the identification and contribution of a project specific Fair Share contribution toward the construction of ultimate flood control facilities needed to accommodate build out of the affected project. Interim flood control facilities may be considered for approval provided such facilities meet OCFCD requirements. Nothing shall preclude the City of Tustin from transferring the obligation onto other project developers within the project area. P General The City of Tustin and the City of Irvine, each within its respective jurisdiction, shall ensure that adequate fire protection, police protection, libraries, and parks and recreation facilities (including 246 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 82 bikeways/trails) needed to adequately serve the reuse plan area shall be provided as necessary. To eliminate any negative impact the project could have on each community's general fund, financing mechanisms including but not limited to developer fees, assessment district financing, and/or tax increment financing (in the event that a redevelopment project area is created for the site), shall be developed and used as determined appropriate by each City. Specifically; (1) Applicants for private development projects shall be required to enter into an agreement with City of Tustin or the City of Irvine, as applicable, to establish a fair share mechanism to provide needed fire and police protection services, libraries, and parks and recreation facilities (including bikeways) through the use of fee schedules, assessment district financing, Community Facility District financing, or other mechanisms as determined appropriate by each respective city. (2) Recipients of property through public conveyance process, or other conveyance procedures, shall be required to mitigate any impacts of their public uses of property on public services and facilities. (As amended by Addendum) Q The cities of Tustin and Irvine shall jointly consult and coordinate with the Orange County Parks, Program Management and Coordination Division, in preparation of trail designs for the Peters Canyon and Barranca trails within the reuse plan area. Improvements for each of these trails would be installed upon completion of flood control channel improvements and approval of their joint use by the OC Parks. R Fire Protection/Emergency Medical Services Prior to the first final map recordation or building permit issuance for development (except for financing and re-conveyances purposes), the project developer could be required to enter into an agreement with the City of Tustin or City of Irvine/OCFA, as applicable, to address impacts of the project on fire services. Such agreement could include participation for fire protection, personnel and equipment necessary to serve the project and eliminate any negative impacts on fire protection services. S Prior to issuance of building permits, the project developer shall work closely with the OCFA to ensure that adequate fire protection measures are implemented in the project. T Prior to issuance of building permits for phased projects, the project developer shall submit a construction phasing plan to the OCFA demonstrating that emergency vehicle access is adequate. U Prior to the issuance of building permits, the project developer shall submit a fire hydrant location plan for the review and approval of the Fire Chief and ensure that fire hydrants capable of flows in amounts approved by the OCFA are in place and operational to meet fire flow requirements. V Police Protection Prior to issuance of building permits, the project developer shall work closely with the respective Police Department to ensure that adequate security precautions are implemented in the project. W Schools Prior to the issuance of building permits, the project developer shall submit to the respective City proof of payment of appropriate school fees adopted by the applicable school district pursuant to Government Code Section 65995. Alternatively, a project developer may enter into a mutual agreement with an applicable school district to provide alternative mitigation that addresses student generation increases. 247 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 83 (As amended by Addendum) X Parks and Recreation Prior to the first final map recordation (except for financing and re-conveyance purposes) or building permit issuance for development within the City of Tustin portion of the site, the project developer shall be required to provide evidence of compliance with all requirements and standards of the City of Tustin Park Code. Y Prior to the first final map recordation or building permit issuance within the City of Irvine portion of the site, the project developer shall be required to provide evidence of compliance with all requirements and standards of the City of Irvine Park Code. Z Prior to the first concept plan for tentative tract map in the City of Tustin, the project developer shall file a petition for the creation of a landscape maintenance district for the project area with the City of Tustin. The district shall include public neighborhood parks, landscape improvements, and specific trails (Barranca only), the medians in arterials, or other eligible items mutually agreed to by the petitioner and the City of Tustin. In the event that a district is not established prior to issuance of the first building permit, maintenance of items mentioned above shall be the responsibility of a community association. [ Prior to approval of any subdivision map (except for financing or conveyance purposes), an agreement will be executed with the following agencies for the associated trail improvements: a. County Parks — identification of a project specific Fair Share contribution toward the installation of necessary regional bikeway trail improvements within Peters Canyon Channel, to be installed in conjunction with the County of Orange's other channel improvements; b. City of Tustin — the identification of a project specific Fair Share contribution toward the installation of Class II bicycle trails through the project site. For the area of the site northeast of Irvine Center Drive, a separate agreement would be required to ensure the provision of a bikeway right- of-way easement, and design and construction of a bike trail along the SCRRA/OCTA rail tracks from Harvard Avenue westerly to the Peters Canyon Channel. In addition, project developers of the areas of the site southeast of the Peters Canyon Channel would need to accommodate access to both the Peters Canyon Trail and the trail adjacent to the SCRRA/OCTA tracks in any project site design including dedication of any necessary recreational trail easements; c. City of Tustin — the identification of a project specific Fair Share contribution toward installation of Class I bikeway trail improvements northerly of Barranca Parkway after completion of the Barranca Channel improvements. For proposed developments adjacent to Barranca Channel, separate agreements would be required to ensure the establishment of a bikeway right-of-way easement between Jamboree Road and Red Hill Avenue. D 3K\VLFDOO\GLYLGHDQHVWDEOLVKHGFRPPXQLW\" The TLSP 2025 SEIR concluded that impacts related to the physical division of an established community would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe proposed Project would be developed to be consistent with the General Plan, TLSP, and zoning designations and would not introduce roadways or other infrastructure improvements that would bisect or transect the Project site or surrounding area. Further, the proposed residential uses would be compatible with the surrounding land uses. Furthermore, access to the site would be provided by 27-foot- 248 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 84 wide driveways from Veterans Road and John Johnson Way. Thus, impacts related to physically dividing an established community would not occur from the proposed Project. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. Thus, the proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. E &DXVHDVLJQLILFDQWHQYLURQPHQWDOLPSDFWGXHWRDFRQIOLFWZLWKDQ\ODQGXVHSODQSROLF\RU UHJXODWLRQDGRSWHGIRUWKHSXUSRVHRIDYRLGLQJRUPLWLJDWLQJDQHQYLURQPHQWDOHIIHFW" The TLSP 2025 SEIR concluded that the TLSP 2025 SPA, through the implementation of mitigation measures and existing policies, would not conflict with existing land use plans, policies, and regulations and impacts would be less than significant with mitigation (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe documents regulating land use for the Project site include the TLSP, the City’s General Plan, SCAG 2024 RTP/SCS, Airport Environs Land Use Plan (AELUP) for John Wayne Airport, and the TCC. The proposed Project’s consistency with these planning documents is described below. General PlanThe Project site is designated as TLSP by the City’s General Plan. The proposed Project would remain consistent with the TLSP, and therefore, would be consistent with the General Plan and corresponding policies. TLSP. The Project site is designated as Mixed-Use Urban by the TLSP. The proposed Project would develop 142,566 SF of non-residential uses and 172 residential units, which is within the maximum buildout assumptions analyzed in the TLSP 2025 SEIR: 606,000 SF of non-residential uses and 2,427 residential units (including density bonus units) for Neighborhood D South. Further, the proposed Project would comply with TLSP goals and would remain consistent with the TLSP, as demonstrated in Table LU-1. 7DEOH/83URMHFW&RQVLVWHQF\ZLWK7/633ROLFLHV *RDO3ROLF\RU2EMHFWLYH3URMHFW&RQVLVWHQF\ 1. Implement a revised land use and urban design plan for the community that weaves the existing development into an updated comprehensive vision for achieving a better balance of residential, commercial, and employment uses, well connected by a variety of transportation modes, parks, and open space. &RQVLVWHQWThe proposed Project would be consistent with the existing TLSP. The proposed Project is within Neighborhood D and is consistent with the allowed uses. The proposed Project is within an urban area which promotes a walkable community design. The proposed Project would introduce senior residential and assisted living units to a commercially dominated area, improving the balance of uses within Neighborhood D. 2. Preserve the Tustin Legacy Park concept from the Adopted Specific Plan, and provide additional design direction related to trails, recreation activities, integration with adjacent development, and park design features. &RQVLVWHQWThe proposed Project is not within the Tustin Legacy Park site. However, the proposed Project would provide infrastructure such as sidewalks and landscaping which would contribute to walkability in the area. 3. Implement an updated mobility plan for Tustin Legacy that ensures a well-connected system of roadways, pedestrian paths, bicycle routes, and bus and shuttle routes that provide safe and convenient access to uses within Tustin Legacy, the adjacent Metrolink Station, and other offsite destinations. &RQVLVWHQW The proposed Project is inclusive of the sidewalks, inlet streets, and necessary parking for residents and guests. The proposed Project would improve both pedestrian and vehicle mobility within Neighborhood D of the TLSP and would not conflict with the City’s Mobility Element. 249 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 85 *RDO3ROLF\RU2EMHFWLYH3URMHFW&RQVLVWHQF\ 4. Maintain the existing non-residential land use/trip budget total for Tustin Legacy, while allowing for the reallocation of trips between certain neighborhoods, based on the revised mix of land uses for the remaining lands owned by the City of Tustin. &RQVLVWHQWThe proposed Project would introduce 142,566 SF of non-residential institutional uses and 172 residential units. The TLSP allows for a total of 606,000 SF of non-residential uses and 2,427 residential units (including density bonus units) within Neighborhood D South. As such, the proposed Project is within the trip budget assumed for the TLSP. Further, as described in Section 5.10, Transportation, the Project would not have a significant impact on VMT. SCAG. The TLSP 2025 SEIR included a consistency analysis for both the 2020-2045 SCAG RTP/SCS and the 2024-2050 RTP/SCS. The current RTP/SCS in effect is the 2024-2050 RTP/SCS. As described previously, the Project is within the buildout assumptions analyzed in the TLSP 2025 SEIR and would remain consistent with SCAG strategies and policies. Airport Environs Land Use Plan for John Wayne Airport. The Modified Project site is within the airport planning area for John Wayne Airport, which is approximately 2.19 miles to the southwest. The Project site is not within the airport impact zone or in airport safety compatibility zones 1 through 5, where residential and public buildings are restricted or prohibited. However, the Project site is within the AELUP-designated notification area and is subject to Federal Aviation Administration (FAA) notification and height restrictions pursuant to Federal Aviation Regulations Part 77 (FAR Part 77). However, the proposed Project would not exceed height restrictions outlined in the AELUP and therefore would not require an obstruction evaluation by FAA and the Project would not result in a hazard to airport operations. Therefore, the Project would be consistent with AELUP. Federal Facility Site Remediation Agreement (FFSRA).A FFSRA between the Navy and the DTSC is currently in place for the former MCAS Tustin, which governs the Navy’s corrective action and response obligations under the Resource Conservation and Recovery Act and CERCLA. Under the 2025 TLSPA, hazardous conditions would continue to be handled according to the FFSRA and applicable state and federal criteria set by DTSC, EPA, and regional health authorities. The Navy has included PFAS as a pollutant under their responsibility for remediation pursuant to federal law and existing agreements. The Navy is also responsible for the cleanup of the hangar fire and ongoing remediation and monitoring. Additionally, the Navy is responsible for remediating all hazardous materials sites overlain by proposed residential uses to residential standards pursuant to existing compliance programs. The proposed Project would not conflict with the existing FFSRA. Further, the Project’s use, transport, and disposal of hazardous materials would be required to comply with existing regulations of several agencies, including the Department of Toxic Substances Control (DTSC), the EPA, California Division of Occupational Safety and Health, Orange County Environmental Health, and the Orange County Fire Authority. Therefore, the Project would not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, less than significant impact. In addition, 2001 FEIR/EIS MM (a) through (v) would be implemented on an as-needed basis to reduce land use-related impacts, and would be verified by the City of Tustin during plan check review. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. &RQFOXVLRQ Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate 250 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 86 Project impacts or mitigation measures regarding land use and planning. There have not been 1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; 2) substantial changes with respect to the circumstances under which development of the Project site is undertaken that require major revisions of the Final EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or 3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the TLSP 2025 SEIR was certified as completed. Because none of the conditions identified in CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts, CEQA Guidelines 15168 also does not require additional environmental review, and the Project is within the scope of the TLSP with respect to land use and planning. 3ODQV3URJUDPVRU3ROLFLHV 333V  x Tustin City Code x Airport Environs Land Use Plan for John Wayne Airport x Federal Aviation Regulations Part 77 x Resource Conservation and Recovery Act x Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG Final EIR mitigation measures that are applicable to the proposed Project would be implemented as intended by the TLSP 2025 SEIR. After implementation of the applicable mitigation measures, no new impacts nor substantially more severe land use impacts would result from implementation of the proposed Project; therefore, no new or revised mitigation measures are required regarding land use. 2001 FEIS/EIR Mitigation Measures Applicable to the Proposed Project )(,5(,600 D As listed above. )(,5(,600 E  As listed above. )(,5(,600 F  As listed above. )(,5(,600 G  As listed above. )(,5(,600 H  As listed above. )(,5(,600 I  As listed above. )(,5(,600 K  As listed above. )(,5(,600 N  As listed above. )(,5(,600 P  As listed above. )(,5(,600 R  As listed above. )(,5(,600 S  As listed above. 251 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 87 )(,5(,600 T  As listed above. )(,5(,600 U  As listed above. )(,5(,600 V  As listed above. )(,5(,600 W  As listed above. )(,5(,600 X  As listed above. )(,5(,600 Y  As listed above. 252 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 88 5.7. NOISE 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Would the project result in:Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact 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? 6XPPDU\RI,PSDFWV,GHQWLILHGLQWKH3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ x The 2001 FEIS/EIR concluded that noise impacts would be significant if noise levels affecting sensitive receptors exceeded thresholds established in the noise elements of the general plans for the cities of Tustin, Irvine, and Santa Ana. Sensitive receptors include residences, schools, libraries, hospitals, and recreational areas. Specifically, the 2001 FEIS/EIR defined a significant impact as an increase of 3 dB or more above existing noise levels at a sensitive receptor. x The 2001 FEIS/EIR determined that the increase in traffic levels would not result in a significant impact to roadways surrounding the Specific Plan area. However, significant noise impacts were found for residents near the extension of Tustin Ranch Road to Von Karman Avenue and to residential and park uses adjacent to Warner Avenue between Harvard Avenue and Culver Drive. x The 2001 FEIS/EIR found that future sensitive receptors developed in accordance with the Specific Plan would incorporate applicable regulations and impacts would be less than significant. x The 2001 FEIS/EIR determined that there would be a significant impact to existing onsite housing planned for reuse. Mitigation measures were incorporated to reduce noise levels below 65 dB to less-than- significant levels. 253 □ □ □ □ □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 89 x Under the TLSP 2017 SEIR, one new noise impact was identified: traffic noise impacts along Moffett Drive from Park Avenue to Sonora Street/Meridian Way and along Valencia Avenue from Tustin Ranch Road to Park Avenue would increase compared to the Adopted TLSP. However, the analysis found that with application of noise mitigation measures from the 2001 FEIS/EIR and 2004 SEIR, which includes various noise buffering construction techniques and future construction of a soundwall along Tustin Ranch Road, impacts were determined to be less than significant with mitigation. x The TLSP 2025 SEIR determined that impacts related to generation of substantial temporary or permanent increase in ambient noise level would be less than significant with mitigation incorporated. Given that specific details related to stationary impacts of future developments were unknown at the time of approval of the TLSP 2025 SEIR, 2017 SEIR MM N-3 would be implemented to require all future development projects to prepare project-specific plans and studies to determine whether any 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. x In regard to cumulative impacts, the TLSP 2025 SEIR concluded that cumulative noise and vibration impacts would be less than significant. Construction-related noise would be temporary and localized, with activities limited to permitted hours under TCC Chapter 6, Section 4616. Because multiple high- noise construction activities are unlikely to occur simultaneously in close proximity, cumulative construction impacts would not be significant. In addition, cumulative traffic noise increases would be below the 3 dBA significance threshold. Therefore, cumulative noise impacts from the TLSP 2025 SPA would be less than significant. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV 6(,5001 For new development within the reuse area, the City of Tustin and City of Irvine, as applicable shall ensure that interior and exterior noise levels do not exceed those prescribed by state requirements and local city ordinances and general plans. Plans demonstrating noise regulation conformity shall be submitted for review and approval prior to building permits being issued to accommodate reuse. D *HQHUDWLRQRIVXEVWDQWLDOWHPSRUDU\RUSHUPDQHQWLQFUHDVHLQDPELHQWQRLVHOHYHOVLQWKHYLFLQLW\ RIWKHSURMHFWLQH[FHVVRIVWDQGDUGVHVWDEOLVKHGLQWKHORFDOJHQHUDOSODQRUQRLVHRUGLQDQFHRU DSSOLFDEOHVWDQGDUGVRIRWKHUDJHQFLHV" The TLSP 2025 SEIR concluded that the TLSP 2025 SEIR assumptions would have a less than significant impact with mitigation (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe proposed Project consists of the construction of 142,566 SF of non-residential (congregate care) and 172 residential units. As described previously, the Project site is graded and is surrounded by residential and vacant land. The closest sensitive receptors are the existing townhomes approximately 72 feet south of the Project site. &LW\RI7XVWLQ*HQHUDO3ODQ The City of Tustin General Plan Noise Element identifies noise criteria as outlined below in Table N-1. 7DEOH1*HQHUDO3ODQ1RLVH(OHPHQW6WDQGDUGV /DQG8VH1RLVH6WDQGDUG ,QWHULRU([WHULRU Residential: single-family, multi-family, duplex, mobile home 45 dBA CNEL 65 dBA CNEL3 Residential: transient lodging, hotels, motels, nursing homes, hospitals 45 dBA CNEL 65 dBA CNEL3 254 I I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 90 Private office, church sanctuaries, libraries, boardrooms, conference rooms, theaters, auditoriums, concert halls, meeting rooms, etc. 45 dBA CNEL (12) - Schools 45 dBA CNEL (12) 67 dBA Leq (12)4 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 CNEL4 Golf courses, outdoor spectator sports, amusement parks - 70 dBA CNEL4 Note: Leq (12) = A-weighted equivalent sound level averaged over a 12-hour period (usually the hours of operation) 1 Noise standard with windows closed. Mechanical ventilation shall be provided per UBC requirements to provide a habitable environment. 2 Indoor environment excluding bathrooms, toilets, closets, and corridors. 3 Outdoor environment limited to rear yard of single-family homes, multi-family patios, and balconies (with a depth of 6 feet or more) and common recreation areas. 4 Outdoor environment limited to playground areas, picnic areas, and other areas of frequent human use. Source: TLSP 2025 SEIR 7XVWLQ&LW\&RGH The TCC establishes the City’s standards, guidelines, and procedures concerning the regulation of operational noise. These are described specifically in Article 4, Chapter 6, Noise Control. Article 4, Chapter 6 of the TCC exempts noise from construction activities between the hours of 7:00 AM and 6:00 PM Monday through Friday, and 9:00 AM and 5:00 PM on Saturdays, excluding City-observed federal holidays and requires construction to occur within these hours. The TCC presents permissible noise intrusion levels by land use, as shown in Table N-2, City of Tustin Exterior Noise Standards. These standards are not to be exceeded for a cumulative period of 30 minutes in any hour, by 5 dBA for a cumulative period of 15 minutes in an hour, by 10 dBA for a cumulative period of 5 minutes in any hour, by 15 dBA for a cumulative period of 1 minute in any hour, or by 20 dBA for any period of time. When the ambient noise already exceeds these standards, the allowable noise shall be increased to reflect the ambient noise accordingly. 7DEOH1&LW\RI7XVWLQ([WHULRU1RLVH6WDQGDUGV /DQG8VH&DWHJRU\7LPH3HULRG1RLVH/HYHO Residential 7 am to 10 pm 10 pm to 7 am 55 dBA 50 dBA Commercial Anytime 60 dBA Industrial Anytime 70 dBA Institutional (e.g., hospitals, convalescent homes, schools, libraries, churches) Anytime 55 dBA Mixed Use Anytime 60 dBA Non-Urban Anytime 70 dBA Source: Tustin City Code Section 4615 of the TCC contains interior noise standards for residential land uses shown in Table N-3, below. 7DEOH1&LW\RI7XVWLQ,QWHULRU1RLVH6WDQGDUGV /DQG8VH&DWHJRU\7LPH3HULRG1RLVH/HYHO Residential 7 am to 10 pm 55 dBA 255 I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 91 10 pm to 7 am 45 dBA Mixed Use 7 am to 10 pm 10 pm to 7 am 55 dBA 45 dBA Source: Tustin City Code Construction Noise Construction activities for the residential units would include site preparation, grading, building construction, paving, and architectural coatings. As such, noise generated by construction equipment would include a combination of trucks, power tools, concrete mixers, and portable generators that can reach high levels when combined As described above, Section 4, Chapter 6 of the TCC exempts noise from construction activities between the hours of 7:00 AM and 6:00 PM Monday through Friday, and 9:00 AM and 5:00 PM on Saturdays, excluding City-observed federal holidays and requires construction to occur within these hours (PPP NOI-1). The proposed Project’s construction activities would occur pursuant to these regulations and would not exceed established standards. The construction noise from the proposed Project 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. The construction equipment would include a combination of trucks, power tools, concrete mixers, and portable generators. Additionally, the most noise intensive equipment would only be utilized during the shorter grading portion of the 24-month construction period. The existing ambient noise measurements at the Project site are included below within Table N-4. 7DEOH1([LVWLQJ1RLVH/HYHO0HDVXUHPHQWV /RFDWLRQ 1XPEHU/RFDWLRQ'HVFULSWLRQ2YHUDOO G%$/HT /RXGHVWPLQXWH 3HULRG G%$/HT  L1 At the Project site boundary along Warner Ave 62 65 L2 At the Project site boundary along Armstrong Ave 65 66 Source: Appendix B The proposed Project consists of the construction of 142,566 SF of non-residential (congregate care) and 172 residential units. The proposed Project is within the maximum buildout assumptions of 606,000 SF of non-residential development and 2,427 residential units (including of density bonus units) for Neighborhood D South. Currently, Neighborhood D South has an existing buildout of zero SF and 2,112 residential units, thus it would have sufficient capacity to accommodate the proposed 142,566 SF of non-residential and 172 residential units of development. As described within the TLSP 2025 SEIR, noise related to construction, including construction traffic, would not exceed the FTA construction noise criteria of 90 dBA during the daytime hours, as construction would occur between the hours between 7:00 am to 6:00 pm, Monday through Friday, and 5:00 pm and 9:00 am on Saturdays. Thus, impacts related to construction noise were concluded to be less than significant. Operational Noise Since the Project is a residential development and the non-residential portion consists of congregate care, operational noise would primarily be from vehicular trips. Vehicle noise is a combination of the noise 256 I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 92 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. The TLSP 2025 SEIR concluded that traffic noise associated with TLSPA buildout would be no greater than 0.9 dBA. Noise level increases less than 3 dBA are not perceptible to the human ear in an outdoor environment. Therefore, traffic noise impacts on off-site sensitive receptors would be less than significant, consistent with the TLSP 2025 SEIR. The Project would also 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 during operation of the Project. However, on-site stationary sources would be required to meet the City of Tustin maximum noise level standards. Further, implementation of 2017 SEIR MM N-3 would require all future new development to prepare project- specific plans and studies to determine whether any 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 such as walls, etc. for the proposed development. Thus, with implementation of 2017 SEIR MM N-3, impacts related to stationary noise impacts would be less than significant, consistent with the TLSP 2025 SEIR. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. Thus, the proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. E *HQHUDWLRQRIH[FHVVLYHJURXQGERUQHYLEUDWLRQRUJURXQGERUQHQRLVHOHYHOV" The TLSP 2025 SEIR concluded that impacts related to groundborne vibration or groundborne noise levels would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW The proposed Project consists of the construction of 142,566 SF of non-residential (congregate care) and 172 residential units. The proposed Project is within the maximum buildout assumptions of 606,000 SF of non-residential development and 2,427 residential units (inclusive of density bonus units) for Neighborhood D South. Currently, Neighborhood D South has an existing buildout of zero SF and 2,112 residential units, thus it would have sufficient capacity to accommodate the proposed 142,566 SF of non-residential and 172 residential units of development. The TLSP 2025 SEIR analyzed the construction and operational groundborne vibrations generated from TLSP 2025 buildout and determined they would be less than the thresholds of annoyance and would result in a less than significant impact. Given that the Project is within the buildout assumptions of the TLSP 2025 SEIR, impacts from construction and operations of the proposed Project would remain less than significant. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. F )RUDSURMHFWORFDWHGZLWKLQWKHYLFLQLW\RIDSULYDWHDLUVWULSRUDQDLUSRUWODQGXVHSODQRUZKHUH VXFKDSODQKDVQRWEHHQDGRSWHGZLWKLQWZRPLOHVRIDSXEOLFDLUSRUWRUSXEOLFXVHDLUSRUWZRXOG WKHSURMHFWH[SRVHSHRSOHUHVLGLQJRUZRUNLQJLQWKHSURMHFWDUHDWRH[FHVVLYHQRLVHOHYHOV" The TLSP 2025 SEIR concluded that impacts related to airport hazards would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 257 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 93 1R1HZ,PSDFWJohn Wayne Airport is located approximately 2.19 miles southwest of the proposed Project site and about 1.5 miles southwest of the broader TLSP area. According to the Airport Environs Land Use Plan (AELUP) for John Wayne Airport, the Project site is not located within the 65 dBA CNEL noise contours (OC Airport Land Use Commission, 2008). As such, the proposed 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. Furthermore, implementation of the proposed Project would not result in new impacts compared to those previously analyzed in the TLSP 2025 SEIR. The Project remains consistent with the findings of the TLSP 2025 SEIR, and the level of impact remains unchanged. &RQFOXVLRQ Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures regarding noise. There have not been 1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; 2) substantial changes with respect to the circumstances under which development of the Project site is undertaken that require major revisions of the Final EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or 3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the Final EIR was certified as completed. Because none of the conditions identified in CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts, CEQA Guidelines 15168 also does not require additional environmental review, and the Project is within the scope of the TLSP with respect to noise. 3ODQV3URJUDPVRU3ROLFLHV 333V  x City of Tustin General Plan Noise Element 33312, &RQVWUXFWLRQ+RXUV Construction shall comply with TCC Section 4616, which allows construction activities 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. 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG Final EIR mitigation measures that are applicable to the proposed Project would be implemented as intended by the TLSP 2025 SEIR. After implementation of the applicable mitigation measures, no new impacts nor substantially more severe noise impacts would result from implementation of the proposed Project; therefore, no new or revised mitigation measures are required regarding noise. TLSP 2017 SEIR Mitigation Measures Applicable to the Proposed Project 6(,5001As listed above. 258 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 94 5.8. POPULATION AND HOUSING 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Would the project:Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact 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? 6XPPDU\RI,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ x The 2001 FEIS/EIR found that development of the Adopted Specific Plan would have resulted in a total population of 12,514, (10,900 in Tustin), resulting in a net population increase of approximately 9,350 persons. The 2001 FEIS/EIR analyzed the demolition of the barracks units and conversion to civilian use. Buildout of the Adopted Specific Plan allowed 4,601 residential units, including the 1,537 converted or replaced units. In addition, the 2001 FEIS/EIR found that buildout would have resulted in about 24,500 net new jobs, or a net increase of approximately 24,500 jobs. In addition, the TLSP was expected to generate 15,081 indirect jobs. The 2001 FEIS/EIR concluded that the increase in population, housing, and employment due to the implementation of the Adopted Specific Plan was a beneficial impact because it would fulfill an identified shortfall in housing and meet the goals of the TLSP to generate jobs. x The 2001 FEIS/EIR determined that there would be no adverse impact related to the jobs/housing balance. It was determined that the majority of new jobs would be filled by existing residents within Orange County, and enough new housing would be provided for employees residing outside of the County. No significant impact was identified. x The 2006 Addendum updated the demographic data and growth projections for the City of Tustin and County of Orange using the 2004 Orange County Projections. The 2004 Orange County Projections include buildout projections assumed for the Adopted Specific Plan. The changes in projections showed an increase in population and employment in Tustin with a slightly lower housing stock, indicating a larger household size. x The 2006 Addendum determined that there would be a reduction of 879 employees and an increase of 21 residential units and 24 residents for a specific project. The 2006 Addendum determined that these small changes in employment, housing, and population would not result in any new significant impacts. Further, the project would have a similar impact on the jobs/housing balance countywide. 259 □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 95 x The 2017 TLSP SPA was anticipated to result in the construction of 6,813 residential units and 9,532,419 SF of non-residential building space. The 2017 TLSP SPA was therefore found to result in an overall increase of 2,212 dwelling units and a decrease of 1,755,306 SF of building space. The TLSP 2017 SEIR determined that buildout of the 2017 TLSP SPA would increase the TLSP area’s population by an estimated 6,526 additional residents compared to the Adopted Specific Plan, which was estimated to generate 9,374 residents. This represents an increase of 69.6 percent increase from the Adopted Specific Plan. The additional 6,526 residents that would be generated in Tustin upon buildout of the TLSP SPA would exceed the amount of growth anticipated to occur in the City by regional projections: 4,616 more residents than CDR projections for 2035, 4,394 more residents than SCAG’s projection for 2035, and 4,494 more residents than SCAG’s projection for 2040. x Furthermore, additional residents generated by the 2017 TLSP SPA compared to those generated by the Adopted TLSP would represent 79.5 percent of the population growth anticipated for buildout of the City by the Tustin General Plan. Based on all three of these metrics, the 2017 TLSP SPA would induce substantial growth in the area beyond that studied in the Certified EIR. However, Orange County remains a jobs-rich region, and housing proposed by the TLSP 2017 SPA would result in a beneficial impact to the region related to the balance of jobs and housing. x The TLSP 2017 SEIR also determined that buildout of the 2017 TLSP SPA would result in a jobs-housing ratio of 2.76 (18,802 total jobs). Although both scenarios are exceptionally jobs-rich, the 2017 TLSP SPA was found to be substantially more balanced than the Adopted TLSP, which had a jobs-housing ratio of 5.11 (23,621 total jobs). The TLSP 2017 SEIR determined that the comparatively more housing- rich 2017 TLSP SPA is consistent with SCAG’s intent to place more housing in jobs-rich portions of Orange County, which is jobs-rich overall. Implementation of the 2017 TLSP SPA was found to result in a less- than-significant impact relating to population growth. x The TLSP 2025 SEIR concluded that, while the TLSP 2025 SPA would result in an increase to projected planned population, the SPA would in part satisfy the State requirements to provide new housing opportunities to increase housing supply. Additionally, the TLSP 2025 SPA would support the goals and policies of the Housing Element aimed to support a variety of housing types and densities. Similarly to the TLSP 2025 SPA, implementation of the TLSP 2025 SPA would directly and indirectly induce population growth in the TLSP area and would slightly skew the jobs-housing ratio towards a more housing-rich ratio. However, the purpose of TLSP 2025 SPA was to implement the provisions of the City’s 2021-2029 Housing Element in order to ensure the City can meet their required RHNA as specified by the HCD and SCAG. Overall, implementation of the TLSP 2025 SPA would result in a less than significant impact related to population growth. x In regard to cumulative impacts, the TLSP 2025 SEIR concluded that cumulative impacts related to population and housing would be less than significant. The population and housing growth from the Approved Project would be consistent with SCAG’s regional growth projections for the City of Tustin and would represent a small fraction of the City’s overall forecasted growth. Although the Approved Project would increase residential development within the TLSP area, it would not significantly affect the County’s jobs–housing balance. Therefore, cumulative population and housing impacts would be less than significant and not cumulatively considerable. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV None. D ,QGXFHVXEVWDQWLDOXQSODQQHGSRSXODWLRQJURZWKLQDQDUHDHLWKHUGLUHFWO\RULQGLUHFWO\" The TLSP 2025 SEIR concluded that it represented a more balanced ratio of jobs and housing in the project area compared to the buildout of the originally Adopted Specific Plan. As such, it was concluded that the TLSP 2025 SEIR would result in a less than significant impact relating to population growth. (City of Tustin, 2025c). 260 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 96 ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe proposed Project would develop 275 senior care and senior residential units across six residential buildings. For the 172 Active Adult units the population estimate of 2.88 persons per household established in the 2025 TLSP SEIR was utilized which would result in a conservative estimate of approximately 495 new residents. The Memory Care and Assisted Living units would provide a total of 134 beds which would be equivalent to 134 residents. In total, it is estimated that the proposed Project would house approximately 629 residents. According to SCAG’s 2024 to 2050 RTP/SCS, the City of Tustin is projected to grow by 15,100 residents between 2019 and 2050. This reflects an 18.8 percent increase and results in a total projected population of approximately 95,500 residents, 34,000 households, and 71,300 jobs by 2050 (SCAG, 2024). The Project’s residential population would represent roughly less than one percent of the forecasted 2050 population and approximately 4.2 percent of the forecasted growth between 2019 and 2050. As such, the increase in population and housing generated by the Project would fall within the growth projections anticipated in SCAG’s 2024 to 2050 RTP/SCS and is consistent with assumptions within the 2025 TLSP SEIR. The Project site is located within an urbanized area of Tustin and is surrounded by existing commercial and mixed-use development. The Project would not expand surrounding utility infrastructure, including water, electricity, telecommunications, gas, sanitary sewer, or stormwater facilities. All utility services would be provided onsite and maintained by the property owner, with connections to existing infrastructure in the surrounding roadways. Vehicular access would be provided via a new internal roundabout from John Johnson Way and an internal drive aisle from Veterans Way. Since the Project is compliant with what was previously analyzed in the TLSP 2017 SEIR and is within an urbanizing area, it would not induce indirect population growth through the extension of infrastructure or roadways. The proposed Project remains consistent with the impacts identified in the SEIR, and the level of impact remains unchanged. Further, no new or substantially more severe impacts would result from implementation of the Project compared to those analyzed in the TLSP 2025 SEIR. E 'LVSODFH VXEVWDQWLDO QXPEHUV RI H[LVWLQJ SHRSOH KRXVLQJ QHFHVVLWDWLQJ WKH FRQVWUXFWLRQ RI UHSODFHPHQWKRXVLQJHOVHZKHUH" The TLSP 2025 SEIR concluded that impacts would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW No housing units currently exist on the Project site and none would be removed; therefore, replacement housing would not need to be constructed elsewhere. Conversely, the proposed Project would provide 275 senior care and senior residential units on the Project site. Therefore, the Project would not displace substantial numbers of existing people or housing, and impacts would be less than significant. Thus, the proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. &RQFOXVLRQ Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures regarding population and housing. There have not been 1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; 2) substantial changes with respect to the circumstances under which development of the Project site is undertaken that require major revisions of the Final EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or 3) the availability of new information of substantial importance 261 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 97 relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the Final EIR was certified as completed. Because none of the conditions identified in CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts, CEQA Guidelines 15168 also does not require additional environmental review, and the Project is within the scope of the TLSP with respect to population and housing. 3ODQV3URJUDPVRU3ROLFLHV 333V  California Government Code Sections 65300, 65580–65589 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG None. 262 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 98 5.9. PUBLIC SERVICES 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact a) Fire protection? b) Police protection? c) Schools? d) Parks? e) Other public facilities? 6XPPDU\RI,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ )LUH3URWHFWLRQ x The 2001 FEIS/EIR determined that implementation of the Specific Plan would require additional firefighting personnel and equipment at existing fire stations. However, it found that buildout would not require new or expanded fire stations. All development projects would be required to meet Orange County Fire Authority (OCFA) regulations, and impacts were determined to be less than significant. Additionally, the 2001 FEIS/EIR included implementation measures which required coordination between future developers/applicants and the City of Tustin or the City of Irvine, depending on the development site’s jurisdiction, to provide adequate fire protection facilities. x Subsequent to the certification of the 2001 FEIS/EIR, in May 2003, the Navy Disposal Plan transferred to the City of Tustin a 1.25-acre site at Edinger Avenue and the West Connector for construction of a new fire station. The fire station was to be funded through development in Tustin Legacy and in the City of Irvine within the former MCAS Tustin. x Subsequently, the OCFA re-evaluated its need for fire protection facilities with respect to response times and determined it needed to move Station 37 to a new location in the Specific Plan area. In March 2005, the City entered into a Memorandum of Understanding with the OCFA for a new fire station at Tustin Legacy. x The 2006 Addendum found that the specific project would result in a similar demand for fire protection services consistent with the 2001 FEIS/EIR determination and that the fire station proposed in the Specific Plan area would meet the needs of the project. x At the time that the 2017 TLSP SPA was approved, OCFA Fire Station 37 at Edinger Avenue and Kensington Park Drive had been completed. The 2017 TLSP SPA was anticipated to result in an increase of 2,212 residential units and a decrease of approximately 1.7 million SF of non-residential uses. Although the project would result in an increase in demand for fire protection due to the resulting 263 □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 99 increase of 6,371 residents, there would be a decrease of 1.7 million SF of non-residential uses offsetting the increase in demand. With the construction of the new fire station (Station 37) within the TLSP area, the TLSP 2017 SEIR found that no other new or expanded off-site fire protection facilities would be required. The 2017 TLSP SPA was required to meet OCFA regulations and standard conditions. No new significant impacts were identified. x The TLSP 2025 SEIR concluded that future residential development associated with the TLSP 2025 SPA could increase demand for fire protection and emergency medical services due to population growth but would not create new significant impacts. Fire protection services would continue to be provided by OCFA Stations 37 and 6, with funding through existing Community Facilities Districts and the City’s General Fund. Compliance with the California Fire Code, OCFA Fire Prevention Guideline B-09, and implementation 2001 FEIS/EIR Mitigation Measures (m)–(r) would ensure adequate emergency access, fire flow, and fire-safety features, resulting in a less than significant impact with mitigation. x In regard to cumulative impacts, the TLSP 2025 SEIR determined that, through compliance with existing fire and building codes and contribution of impact fees to offset increased service demands, cumulative impacts on fire protection and emergency services would be less than cumulatively considerable. 3ROLFH3URWHFWLRQ x The 2001 FEIS/EIR determined that implementation of the Specific Plan would increase the demand for police services in the cities of Tustin and Irvine. The 2001 FEIS/EIR identified the need for two additional patrol units and three additional investigative units in the Tustin Police Department, and two additional sworn officers in the Irvine Police Department. However, it found that buildout would not require new or expanded police facilities and impacts would be less than significant. The 2001 FEIS/EIR included implementation measures which required coordination between future developers/applicants and the City of Tustin or the City of Irvine, depending on the development site’s jurisdiction, in order to provide adequate police protection facilities. x The 2006 Addendum found similar impacts as the 2001 FEIS/EIR with respect to police services and no new impacts were identified. x The TLSP 2017 SEIR found that although the 2017 TSLP SPA anticipated increase of 6,371 residents would result in an increase in demand for police protection, this would be offset by the reduction in approximately 1.7 million SF of non-residential uses. Service level impacts are anticipated to be similar to those analyzed in the 2001 FEIS/EIR. No new police facilities were determined to be needed and no significant physical impacts were identified. Additionally, developers are required to coordinate with the Tustin Police Department prior to project approval to ensure adequate security precautions and design features are in place. x The TLSP 2025 SEIR concluded that the TLSP 2025 SPA would increase demand for police protection services due to future residential growth but would not create new significant impacts. Funding through existing Community Facilities Districts and the City’s General Fund would continue to support necessary police staffing and equipment. With implementation of 2001 FEIS/EIR Mitigation Measures (m) and (s) requiring coordination with the Tustin Police Department to ensure adequate security and service provisions, police protection impacts would be less than significant with mitigation. x In regard to cumulative impacts, the TLSP 2025 SEIR determined that cumulative development would incrementally increase demand for police services but would not result in significant adverse impacts. Increased tax revenues would support the City’s General Fund, allowing the Tustin Police Department to maintain adequate staffing and equipment. Therefore, cumulative impacts on police protection services would be less than significant. 264 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 100 6FKRROV x The 2001 FEIS/EIR determined that the project would generate a total of 2,432 students: 1,473 within the Tustin Unified School District (TUSD), 959 within the Irvine Unified School District (IUSD), and no students within the Santa Ana Unified School District (SAUSD). The Specific Plan provided for two elementary schools and one high school onsite. The TUSD determined that those schools would be adequate to house students generated by the project. The TUSD would collect school facilities impact fees pursuant to SB 50. x The 2006 Addendum determined that the project would result in a reduction of 497 students within TUSD compared to the student generation presented in the 2001 FEIS EIR for the original Specific Plan (estimated to be 1,473 students). No new impacts were identified. The 2006 Addendum also recognized the future development of three school sites in TUSD identified in the 2001 FEIS/EIR and analyzed the impact of expanding the Heritage Elementary School by 5 acres to accommodate a combination elementary/middle school. x The TLSP 2017 SEIR found that the additional residential units as a result of the 2017 TLSP SPA would generate about 1,250 additional students within TUSD boundaries. The addition of 1,250 students to the schools serving the Project area has the potential to exceed the available capacity for some schools if all development were to occur at the time of project approval. The need for additional services is addressed through compliance with school impact fee assessment. Several school facilities were planned for the TLSP area at the time the TLSP 2017 SEIR was being prepared, including an expansion of the existing Heritage School enrollment capacity from 600 students to 900 students; development of a 40.03-acre site to house Legacy Academy, a 6–12 magnet science, technology, engineering and math (STEM) school; development of an alternative education facility, and possible development of additional District administrative facilities. The TLSP 2017 SEIR determined that the planned facilities would be able to accommodate anticipated demand. Therefore, the TLSP 2017 SEIR determined that the project would have a less than significant impact on school facilities. x The Adopted Specific Plan includes a site for a K–8 school in the IUSD and noted project-generated students in grades 9–12 would attend existing and planned IUSD high schools. The 2001 FEIS/EIR determined that the project would generate 2,432 students: 959 within the IUSD, a net increase of 302 students. It identified a 20-acre school site within the IUSD boundaries to accommodate the increased student population. The 2006 Addendum determined that the project would result in a reduction of 107 students within IUSD. No new significant impacts were identified. The TLSP 2017 SEIR did not analyze impacts related to IUSD because the project did not fall within IUSD’s boundaries. x The 2001 FEIS/EIR determined that no new students would be generated directly to the SAUSD resulting from housing development. However, commercial development would indirectly generate new students if new employees were to seek housing nearby within the SAUSD boundaries. These impacts were addressed with a settlement agreement between the City of Tustin and the SAUSD. x The 2006 Addendum recognized a reduction of approximately 0.7 million SF of non-residential uses, reducing the potential for indirect student generation. It found that impacts would be reduced compared to the original project. The TLSP 2017 SEIR did not analyze impacts related to the SAUSD because the project did not fall within the SAUSD’s boundaries. x The TLSP 2025 SEIR determined that buildout of the Approved Project could generate approximately 1,713 additional TUSD students and 393 SAUSD students, potentially exceeding existing capacity at some schools. However, both districts can accommodate students through redistribution, and developers would be required to pay state-authorized school impact fees (Government Code §65995) or enter agreements with the districts to address student increases. With payment of required school fees in accordance with 2001 FEIS/EIR Mitigation Measure (f), impacts on school facilities would be less than significant with mitigation. 265 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 101 x The TLSP 2025 SEIR concluded that cumulative development within the TUSD and SAUSD boundaries could increase student enrollment and the need for additional school facilities. However, both districts would collect school impact fees under Government Code Section 65995(b) to fund necessary expansions. Therefore, cumulative impacts on school services would be less than significant. 3DUNV x The certified FEIS/EIR evaluated recreational impacts of the Specific Plan that included 126 acres of public parkland, including 118 acres in the City of Tustin (84.5-acre regional park, 24.1-acre community park, and two 5-acre neighborhood parks) and an 8-acre neighborhood park in the City of Irvine. The FEIS/EIR found that the 118 acres of public parkland in Tustin was well over the requirement established by the City’s municipal code (three acres of park per 1,000 residents). It determined that the provision of approximately 126 acres of parkland would result in a beneficial impact related to the provision of parks. Construction and operation of the proposed parks were also evaluated throughout the FEIS/EIR, and mitigation measures were identified. x The 2006 Addendum determined that the Specific Plan would exceed the parkland dedication requirement and would not generate an increase in the use of existing recreational facilities. x The 2017 SEIR Initial Study determined that implementation of the SPA includes approximately 255 acres of public parks (including the 84.5-acre regional park in Planning Area 6), which exceeds the amount of parkland required by the TCC and considered in the FEIS/EIR. Thus, the 2017 SEIR Initial Study determined that buildout would not increase the use of existing parks or cause the physical deterioration of existing recreational facilities and no new substantial impact would occur. x The TLSP 2025 SEIR concluded that the TLSPA would add approximately 12,891 residents, requiring an additional 38.7 acres of parkland within the TLSP area at buildout. Therefore, the new total park acreage required for TLSP buildout would be 95.4 acres of parkland. Implementation of the TLSP includes approximately 255 acres of public parks which exceeds the amount of parkland required by the TCC. Since the TLSPA would provide ample parkland, buildout would not increase the use of existing parks or cause the physical deterioration of existing recreational facilities. 2WKHU3XEOLF)DFLOLWLHV x The certified 2001 FEIS/EIR identified three public libraries within three miles of the TLSP area. It found that implementation of the TLSP would not require construction of a new library facility, and impacts were less than significant. Subsequently, the Orange County Public Library (OCPL) entered into an agreement with the City of Tustin to expand the Tustin Branch Library in the Tustin Civic Center. The project was approved in September 2005 and evaluated in a Mitigated Negative Declaration (SCH 2002041001) adopted in May 2002. In 2009, the new 32,000-square-foot library opened, replacing the 15,000-square-foot facility built in 1974. The new library has a book capacity of 209,000 volumes. x The TLSP 2017 SEIR determined that the 2017 TLSP SPA would add 4,609 residents (2,212 dwelling units) to the site compared to the Adopted TLSP, resulting in a total of 17,859 residents. Using the OCPL service standard of 0.2 SF of library space per capita, the 2001 FEIS/EIR estimated that the Adopted TLSP would generate a demand for approximately 2,500 SF of library space. Using the same service standard, the 2017 TLSP SPA would generate demand for a net increase of 922 SF of library space, or 3,572 SF total at buildout. The Tustin Library increased its facilities by 14,000 SF in 2009. Therefore, the additional demand of 922 SF was accommodated by the existing library facilities and would not require the construction of a new or expanded facility. x The TLSP 2025 SEIR concluded that although buildout of the Approved Project could generate approximately 13,817 new residents, the existing three libraries within two miles of the TLSP and the broader OCPL network would adequately serve future residents. Based on OCPL’s service standards, the TLSP 2025 SPA would not require new or expanded library facilities, and library funding through 266 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 102 County property taxes would continue to support service needs. Therefore, impacts on library services would be less than significant. )(,6(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV )(,6(,500 P *HQHUDOThe City of Tustin and the City of Irvine, each within its respective jurisdiction, shall ensure that adequate fire protection, police protection, libraries, and parks and recreation facilities (including bikeways/trails) needed to adequately serve the reuse plan area shall be provided, as necessary. To eliminate any negative impact the project could have on each community's general fund, financing mechanisms including but not limited to developer fees, assessment district financing, and/or tax increment financing (in the event that a redevelopment project area is created for the site), shall be developed and used as determined appropriate by each City. Specifically: 1. Applicants for private development projects shall be required to enter into an agreement with City of Tustin or the City of Irvine, as applicable, to establish a fair-share mechanism to provide needed fire and police protection services, libraries, and parks and recreation facilities (including bikeways) through the use of fee schedules, assessment district financing, Community Facility District financing, or other mechanisms as determined appropriate by each respective city. 2. Recipients of property through public conveyance process, or other conveyance procedures, shall be required to mitigate any impacts of their public uses of property on public services and facilities. )(,6(,500 R )LUH3URWHFWLRQ(PHUJHQF\0HGLFDO6HUYLFHV Prior to the conveyance of land from the City to a developer, and/or the first final map recordation or building permit issuance for development (except for financing and re-conveyances purposes), the project developer could be required to enter into an agreement with the City of Tustin or City of Irvine/OCFA, as applicable, to address impacts of the project on fire services. Such agreement could include participation for fire protection, personnel and equipment necessary to serve the project and eliminate any negative impacts on fire protection services. )(,6(,500 S  Prior to issuance of building permits, the project developer shall work closely with the OCFA to ensure that adequate fire protection measures are implemented in the project. )(,6(,500 T  Prior to issuance of building permits for phased projects, the project developer shall submit a construction phasing plan to the OCFA demonstrating that emergency vehicle access is adequate. )(,6(,500 U  Prior to the issuance of building permits, the project developer shall submit a fire hydrant location plan for the review and approval of the Fire Chief and ensure that fire hydrants capable of flows in amounts approved by the OCFA are in place and operational to meet fire flow requirements. )(,6(,500 V  3ROLFH3URWHFWLRQ Prior to issuance of building permits, the project developer shall work closely with the respective Police Department to ensure that adequate security precautions are implemented into the project. )(,6(,500 W  Prior to the issuance of building permits, the project developer shall submit to the respective City proof of payment of appropriate school fees adopted by the applicable school district pursuant to Government Code Section 65995. Alternatively, a project developer may enter into a mutual agreement with an applicable school district to provide alternative mitigation that addresses student generation increases. D )LUHSURWHFWLRQ" The TLSP 2025 SEIR concluded that impacts related to fire protection services would be less than significant with mitigation (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 267 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 103 1R1HZ,PSDFWFire protection services to the Project site would be provided by the OCFA. The two nearest OCFA fire stations to the Project site are Station 37 and Station 79. Station 37 is located at 15011 Kensington Park Drive in Tustin, approximately 1.35 roadway miles from the Project site. Station 79 is located at 1320 E Warner Avenue in Santa Ana, approximately 1.36 roadway miles from the Project site. As described previously, the proposed Project would result in the development of 275 senior care and senior residential units across six buildings on the Project site. As described in Section 5.8, Population and Housing, the proposed Project is anticipated to generate 629 new residents. Thus, construction and operation of the proposed Project would increase demands for fire protection and emergency medical services. Since the Project site is within a developed area that is currently served by two existing fire stations, the Project would not result in the need to construct a new fire station. As with all projects within the City, the proposed Project would be required 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. In addition, the Project would be required to pay development impact fees. A development impact fee is imposed on new developments to finance public improvements, including fire protection services, and to pay for the development’s fair share of the costs of these improvements. Fire protection facilities, equipment, and staffing can be augmented by the City as needed with assistance from the tax revenue provided by new development and the development impact fees to expand, improve, and maintain fire protection and emergency services and facilities. The Project would also comply with 2001 FEIS/EIR MM (m), (o), (p), (q), and (r) to ensure adequate fire protection measures and coordination with OCFA has occurred. Therefore, impacts related to fire protection services would be less than significant and impacts from the proposed Project would be consistent with those identified in the TLSP 2025 EIR. Therefore, no new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 EIR. E 3ROLFHSURWHFWLRQ" The TLSP 2025 SEIR concluded that impacts related to police protection services would be less than significant with mitigation (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe Tustin Police Department provides police services throughout the City, including the Project site. The Tustin Police Department headquarters are located at 300 Centennial Way in Tustin, which is located approximately 3.9 roadway miles from the Project site. As described previously, the proposed Project would result in the development of 275 senior care and senior residential units across six buildings on the Project site. Construction and operation of the proposed Project would result in an increase in demand for police protection services. However, the increase would not be significant when compared to the current demand levels. As described in Section 5.8, Population and Housing, the proposed Project is anticipated to generate 629 new residents. The Tustin Police Department has 100 full-time sworn police officers and 55 civilian support personnel. According to the California Department of Finance, the City of Tustin had a population of 79,326 residents as of January 1, 2025. Based on this population estimate, the City’s sworn officer to population ratio is 1.3 officers per 1,000 population. Thus, the proposed Project demand would result in about 0.66 of an additional full-time police officer which is less than one full-time police officer. The proposed Project’s demand for the additional police officer would be offset with the payment of development impact fees to the City. The development impact fees collected would ensure that the level of police protection services in the City, particularly near the Project site, are maintained. Police protection facilities, equipment, and staffing can be augmented by the City as needed 268 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 104 with assistance from tax revenue provided by the proposed Project and the development impact fees to expand, improve, and maintain police protection services and facilities. The Project would also comply with 2001 FEIS/EIR MM (m) and (s) to ensure adequate security cautions have been implemented into the Project and coordination with the City to ensure any developer fees or agreements required for adequate police services have been implemented. Therefore, impacts related to police protection services would be less than significant. Additionally, the proposed Project is consistent with the existing zoning and general plan land use; therefore, the impacts were previously accounted for in the TLSP 2025 SEIR. No new or substantially greater impact would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. F 6FKRROVHUYLFHV" The TLSP 2025 SEIR concluded that impacts related to school services would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe Project site is located within the TUSD; however, the proposed Project would not generate new students because it consists of senior residential uses and assisted living uses that do not accommodate households with school-aged children. Therefore, the Project would not increase enrollment within local school districts. However, pursuant to Government Code Section 65995 and in compliance with 2001 FEIS/EIR MM (t), the applicant would be required to pay developer fees to the TUSD at the time building permits are issued. Therefore, impacts related to school facilities would be less than significant and impacts from the proposed Project would be consistent with impacts identified in the TLSP 2025 EIR. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 EIR. G 3DUNV" The TLSP 2025 SEIR concluded that impacts related to parks would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe proposed Project would include development of 275 senior care and senior residential units, which could result in an increase in local population and associated demand for park and recreational facilities. The City of Tustin Parks and Recreation Department maintains and operates public parks in the area. The closest public parks to the site are Tustin Legacy Park, located approximately 0.1 miles southwest of the Project site, and Centennial Park, located approximately 1.28 miles northeast of the Project site. However, the Project proposes two outdoor courtyards, in addition to other recreational facilities, which would be intended for use by only Project residents. The proposed Project would also be subject to the City’s development impact fees per the TCC Section 9331 and 2001 FEIS/EIR MM (m), which would ensure that public recreational needs generated by new residential development are adequately addressed. Because the proposed Project does not include the development or expansion of any public park facilities, it would not displace or degrade any existing parks. As such, the Project would not result in the need for new or physically altered public park facilities that could cause significant environmental effects, and the proposed Project would be consistent with impacts identified in the TLSP 2025 EIR. No new or substantially 269 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 105 greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 EIR. H 2WKHUSXEOLFIDFLOLWLHV" The TLSP 2017 SEIR concluded that impacts related to other public facilities would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe OCPL provides library services throughout the County, including the Project site. The nearest OCPL branch to the Project site is the Tustin Library, located at 345 East Main Street, approximately 3.6 roadway miles from the Project site. As described previously, the proposed Project would result in the development of 275 senior care and senior residential units across six buildings on the Project site. As described in Section 5.8, Population and Housing, the proposed Project is anticipated to generate 629 new residents. Due to the increase in residents on-site, the proposed Project would increase the demand for library services. Based on the OCPL service standard of 0.2 SF of library space per capita identified in the TLSP 2025 SEIR, the proposed Project would generate a demand for approximately 126 SF of library space at buildout. The Tustin Library is a 32,000 square foot building. The additional demand of 126 SF would be accommodated by the existing library facilities and would not require the construction of a new or expanded facility. Additionally, library facilities and staffing can be augmented by the City as needed with assistance from tax revenue provided by the proposed Project and the development impact fees to expand, improve, and maintain library services and facilities, as required by 2001 FEIS/EIR MM (m). As such, impacts related to other public facilities would be less than significant. Therefore, no new or substantially greater impact would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. Impacts from the proposed Project would be consistent with those identified in the TLSP 2025 SEIR. &RQFOXVLRQ Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures regarding public services. There have not been 1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; 2) substantial changes with respect to the circumstances under which development of the Project site is undertaken that require major revisions of the TLSP 2025 SEIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or 3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the TLSP 2025 SEIR was certified as completed. Because none of the conditions identified in CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts, CEQA Guidelines 15168 also does not require additional environmental review, and the Project is within the scope of the TLSP 2025 SEIR with respect to public services. 3ODQV3URJUDPVRU3ROLFLHV 333  The following standard regulations would reduce potential impacts related to fire protection services: x OCFA Fire Prevention Guideline B-09, Fire Master Plans for Commercial and Residential Development. 270 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 106 x Tustin City Code, Chapter 8100, Building and Construction Codes Adopted by Reference. x Government Code Section 65995(b). 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG Final EIR mitigation measures that are applicable to the proposed Project would be implemented as intended by the TLSP 2025 SEIR. After implementation of the applicable mitigation measures, no new impacts nor substantially more severe public service impacts would result from implementation of the proposed Project; therefore, no new or revised mitigation measures are required regarding public services. 2001 FEIS/EIR Mitigation Measures Applicable to the Proposed Project )(,6(,500 P *HQHUDOAs listed above. )(,6(,500 R )LUH3URWHFWLRQ(PHUJHQF\0HGLFDO6HUYLFHV As listed above. )(,6(,500 S  As listed above. )(,6(,500 T  As listed above. )(,6(,500 U  As listed above. )(,6(,500 V  As listed above. )(,6(,500 W As listed above. 271 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 107 5.10. TRANSPORTATION 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Would the project:Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? c) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? d) Result in inadequate emergency access? 6XPPDU\RI,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ x The 2001 FEIS/EIR estimated that full buildout under the Adopted Specific Plan would generate approximately 216,445 average daily vehicle trips (ADT). The analysis forecast potentially significant impacts at 16 intersections under long-range (Year 2020) with-project conditions. While mitigation measures were identified for all impacted intersections, two intersections, Tustin Ranch Road at Walnut Avenue and Jamboree Road at Barranca Parkway, were determined to experience significant and unavoidable impacts even after mitigation. Impacts at all other intersections were reduced to less than significant with mitigation. Additionally, the 2001 FEIS/EIR required phased implementation of on-site roadway improvements tied to cumulative project-generated ADT thresholds. x The 2001 FEIS/EIR also concluded that increased development would generate additional demand for transit service; however, the proposed improvements to the circulation system were expected to enhance transit routing efficiency. No significant impacts were identified to the regional rail system or to pedestrian and bicycle circulation. In fact, the planned bicycle trail network was anticipated to provide an overall benefit to non-motorized transportation modes. x The 2004 Supplemental EIR identified a potentially significant additional impact at the intersection of Red Hill Avenue at Warner Avenue in the cities of Tustin and Santa Ana. Mitigation was required and implemented, and the impact was determined to be less than significant after mitigation. x The 2006 Addendum did not identify any new significant traffic impacts and found that the project would eliminate significant and unavoidable impact at the intersection of Tustin Ranch Road and Walnut 272 □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 108 Avenue in 2020 With Project conditions. The addendum determined that the total number of trips generated by the specific project had not changed and did not exceed the trip budget caps established by and agreed upon between the cities of Tustin, Santa Ana, and Irvine. x The TLSP 2017 SEIR identified that the 2017 TLSP SPA is anticipated to result in a total trip generation of 239,797 daily trips for the entire TLSP area. The TLSP 2017 SEIR determined that two intersections, four freeway ramp intersections, seven freeway ramps, and 11 freeway mainline segments would operate deficiently in the no-project and with-project conditions; one additional freeway mainline would operate deficiently in the no-project condition. With incorporation of mitigation measures from the original 2001 FEIS/EIR, impacts were determined to be less than significant in 2035 conditions, which is a reduced impact compared to the 2001 FEIS/EIR. x The Initial Study prepared for the TLSP 2017 SEIR determined that the 2017 TLSP SPA would result in less-than-significant impacts on hazards due to a design feature, consistent with the original 2001 FEIS/EIR. Likewise, the Initial Study determined the 2017 TLSP SPA would not decrease the safety or performance of pedestrian, bicycle, or transit facilities and concluded that impacts would be less than significant. x The TLSP 2025 SEIR found that cumulative development in Tustin and nearby jurisdictions would not result in significant impacts to alternative transportation systems. Future projects would undergo site-specific reviews to ensure adequate sidewalks, bike lanes, and transit facilities. Therefore, cumulative impacts related to alternative transportation were concluded to be less than significant. x The TLSP 2025 SEIR determined that projects that meet efficiency-based thresholds aligned with state goals are not considered cumulatively considerable. Thus, cumulative traffic and VMT impacts were concluded to be less than significant. x The TLSP 2025 SEIR concluded that cumulative development would be reviewed for compliance with roadway design standards and the California Fire Code to ensure safe emergency access and cumulative impacts related to emergency access would be less than significant. 7/636(,50LWLJDWLRQ0HDVXUHV None. D &RQIOLFWZLWKDSURJUDPSODQRUGLQDQFHRUSROLF\DGGUHVVLQJWKHFLUFXODWLRQV\VWHPLQFOXGLQJ WUDQVLWURDGZD\ELF\FOHDQGSHGHVWULDQIDFLOLWLHV" The TLSP 2025 SEIR concluded that impacts related to conflict with the circulation system, including transit, roadway, bicycle and pedestrian facilities, would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe proposed Project includes development of 172 residential units and 142,566 SF of non-residential uses (congregate care) across six buildings on the Project site. Roadway Facilities A Project-specific trip generation (Appendix D) was prepared for the Project using trip rates from the Institute of Transportation Engineers (ITE), Trip Generation Manual 11th Edition (2021). As shown in Table T-1, The proposed Project would generate 870 net daily trips, including 57 trips during the AM peak hour and 76 trips during the PM peak hour. As shown in Table T-1, the proposed Project’s trips would fall within the maximum daily trips allowable within Neighborhood D of the TLSP. 273 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 109  7DEOH73URSRVHG3URMHFW7ULS*HQHUDWLRQ /DQG8VH8QLWVRU %HGV'DLO\$03HDN+RXU303HDN+RXU ,Q2XW7RWDO,Q2XW7RWDO 1HLJKERUKRRG'6RXWK Multi-Family Housing 2,310 units 10,487 - - 855 - - 901 Continuing Care- Senior Housing 521 units 2,246 - - 125 - - 156 3URSRVHG3URMHFW Active Adult 172 residential units 522 11 22 33 24 19 43 Memory Care/ Assisted Living 134 beds 348 14 10 24 13 20 33 7RWDO3URSRVHG        Source: Appendix D Vehicular access to the Active Adult building (Building 1) would be accessible from two access points: a 27- foot-wide driveway on Veteran’s Way and a 27-foot-wide driveway on John Johnson Way. The Assisted Living building (Building 2) would also be accessible from the 27-foot-wide driveway on John Johnson Way. Vehicular traffic to and from the Project site would utilize the existing network of regional and local roadways that currently serve the Project area. Internal site circulation would include a roundabout drive aisle at the center of the Project site which would provide access to Building 1 and 2. In addition, final design plans would be subject to review and approval by the City’s Public Works Department prior to the issuance of building permits. As such, the proposed Project would not introduce any new offsite roadways or land uses that would interfere with adopted plans, programs, ordinances, or policies regarding roadway facilities and the Project would be consistent with the TLSP 2025 SEIR. No new or substantially greater impacts would occur from implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. Alternative Transportation Pedestrian circulation would be provided via existing public sidewalks along Warner Avenue and proposed sidewalks along Veterans Way, Armstrong Way, and John Johnson Way. The proposed Project would protect the existing sidewalk along Veterans Way and John Johnson Way Warner and if necessary, repair or reconstruct sidewalks along the Project frontage per the City’s request. Additionally, the proposed Project includes off-site improvements to the sidewalk along Warner Avenue. The proposed on-site roadway system also includes sidewalks throughout the Project site that would connect to the off-site sidewalks. This would facilitate pedestrian use and walking to nearby locations. Therefore, the proposed Project would improve, and not conflict with, pedestrian facilities. Thus, impacts related to pedestrian facilities would not occur. Existing bike lanes exist along Warner Avenue and Armstrong Avenue within the vicinity of the Project site. The Project would not include any offsite roadway improvements or changes to the existing bicycle lanes in the vicinity of the Project. Thus, impacts related to bicycle facilities would not occur. Public transit bus service to the Project area is provided by Orange County Transportation Authority (OCTA). Five OCTA bus routes operate within the vicinity of the Project site on Warner Avenue, Red Hill Avenue, and Barranca Parkway. The proposed Project would not alter or conflict with existing transit stops and schedules, and impacts related to transit services would not occur. 274 I I I I I I I I I I I I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 110 Overall, Project impacts to roadway, transit, bicycle, and pedestrian facilities would be less than significant and the Project would be consistent with the impacts identified in the TLSP 2025 SEIR. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. E :RXOGWKHSURMHFWFRQIOLFWRUEHLQFRQVLVWHQWZLWK&(4$*XLGHOLQHVVHFWLRQVXEGLYLVLRQ E " The TLSP 2025 SEIR concluded that impacts related to CEQA Guidelines section 15064.3, subdivision (b), would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWState CEQA Guidelines Section 15064.3(b) focuses on determining the significance of VMT- related transportation impacts. The City of Tustin VMT Analysis Guidelines (2024) contain screening thresholds to assess whether a Project has the potential to result in an impact, and if mitigation or further VMT analysis would be required. If none of the screening criteria are met, then the project would require mitigation and potentially a VMT analysis to determine the extent the VMT thresholds are exceeded. The screening criteria include the following: x Screening Criteria 1 – Is the Project 100 percent affordable housing? x Screening Criteria 2 – Is the Project within 1/2 mile of qualifying transit? x Screening Criteria 3 - Is the Project a local serving land use? x Screening Criteria 4 - Is the Project in a low VMT area? x Screening Criteria 5 - Are the Project's Net Daily Trips less than 500 ADT? As described in the VMT Screening Memo (Appendix C) prepared for the Project, the Project would not meet any of the screening criteria listed, therefore, a full VMT Analysis was required to be prepared to identify VMT impacts. The City of Tustin guidelines recommend use of VMT per capita to evaluate residential land uses whereas VMT per employee for non-residential land use projects. The VMT per capita includes VMT generated by all homebased trips (productions) whereas VMT generated by homebased work trips (attractions) is used to estimate VMT per employee. If the Project VMT per capita exceeds base year average VMT per capita for the City of Tustin or the Project VMT per employee exceeds base year average VMT per employee for the City of Tustin, the Project would result in a VMT impact. The VMT Analysis (Appendix D), determined that Project-generated VMT per capita and VMT per employee for both residential and non-residential would be lower than the base year average VMT per capita and VMT per employee, as illustrated below in Table T-2. Therefore, the Project would not result in a significant VMT impact. 7DEOH73URSRVHG3URMHFW907$QDO\VLV <HDU  &OHDUZDWHUDW7XVWLQ/HJDF\&LW\RI7XVWLQ Household - - Population 206 - Employment 70 - Homebased (HB) VMT 1,219 - Homebased Work (HBW) VMT 1,157 - 275 I I I I Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 111 HB VMT per capita   HBW VMT per employee   Source: Appendix D Furthermore, the 870 net daily trips that would be generated by the Project would be within the trip generation identified in the Neighborhood D South of the TLSP 2025 SEIR (2,310 daily trips for multi-family housing and 521 trips for non-residential (continuing care). Therefore, the Project would be consistent with the TLSP 2025 SEIR. No new or substantially greater impacts would occur from implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. F 6XEVWDQWLDOO\ LQFUHDVH KD]DUGV GXH WR D GHVLJQ IHDWXUH HJ VKDUS FXUYHV RU GDQJHURXV LQWHUVHFWLRQV RULQFRPSDWLEOHXVHV HJIDUPHTXLSPHQW " The TLSP 2025 SEIR concluded that impacts would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWVehicular access to Building 1 and 2 of the proposed Project would be provided via a 27- foot-wide driveway on Veteran’s Way and a 27-foot-wide driveway on John Johnson Way. Building 2 would also be accessible from the 27-foot-wide driveway on John Johnson Way. Vehicular traffic to and from the Project site would utilize the existing network of regional and local roadways that currently serve the Project area. Vehicular access to the Active Adult building (Building 1) would be accessible from two access points: a 27-foot-wide driveway on Veteran’s Way and a 27-foot-wide driveway on John Johnson Way. The Assisted Living building (Building 2) would also be accessible from the 27-foot-wide driveway on John Johnson Way. The proposed Project would not introduce any new roadways or land use that would conflict with existing urban land uses in the surrounding area. Design of the proposed Project, including the internal circulation, is subject to the City’s development standards and TLSP design guidelines. Design of the Project would be reviewed to ensure fire engine accessibility and turn around area is provided to the fire code standards. As a result, impacts related to vehicular circulation design features would be less than significant. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. G 5HVXOWLQLQDGHTXDWHHPHUJHQF\DFFHVV" The TLSP 2025 SEIR concluded WKDWWKHUHZRXOGEHDGHTXDWHHPHUJHQF\DFFHVVDQGimpacts would be less than significant (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW The proposed construction activities, including equipment and supply staging and storage, would occur within and adjacent to the Project area and would not restrict access of emergency vehicles to the Project site or adjacent areas. Further, operation of the proposed Project would not result in inadequate emergency access. Direct access to the Project site would be provided from a 27-foot-wide driveway on Veteran’s Way and a 27-foot-wide driveway on John Johnson Way. All drive aisles would be consistent with City requirements to accommodate 276 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 112 emergency vehicles as well as provide fire suppression facilities (e.g., hydrants, fire sprinklers and fire- resistant construction materials) in conformance with the Tustin City Code and the California Fire Code (Title 24, CCR, Part 9). Additionally, should road closures be needed during construction, the Project would be required to implement 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 (PPP T-1). Compliance with appropriate code specifications would be verified by the City’s Building and Safety Department during the construction and occupancy permitting process. Thus, potential impacts related to inadequate emergency access during Project construction or operation would be less than significant. No new or substantially greater impacts would occur with implementation of the proposed Project when compared to those identified in the TLSP 2025 SEIR. The proposed Project is consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. &RQFOXVLRQ Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures regarding transportation and traffic. There have not been 1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; 2) substantial changes with respect to the circumstances under which development of the Project site is undertaken that require major revisions of the TLSP 2025 SEIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or 3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the TLSP 2025 SEIR was certified as completed. Because none of the conditions identified in CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts, CEQA Guidelines 15168 also does not require additional environmental review, and the Project is within the scope of the TLSP 2025 SEIR with respect to transportation. 3ODQV3URJUDPVRU3ROLFLHV 333V  x Section 503 of the California Fire Code (Title 24, CCR, Part 9) x City of Tustin General Plan Circulation Element x Tustin City Code x Tustin Legacy Specific Plan x City of Tustin VMT Analysis Guidelines, March 2024 33377UDIILF&RQWURO8WLOLWLHVAll 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. 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 277 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 113 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG None. 278 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 114 5.11. UTILITIES AND SERVICE SYSTEMS 6XEVHTXHQWRU6XSSOHPHQWDO(,5 $GGHQGXPWR(,5 Would the project:Substantial Change in Project or Circumstances Resulting in New Significant Effects New Information Showing Greater Significant Effects than Previous EIR New Information Identifying New Mitigation or Alternative to Reduce Significant Effect is Declined Minor Technical Changes or Additions No New Impact /No Impact a) Require or result in the construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? c) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? d) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? ,PSDFWV,GHQWLILHGLQ3UHYLRXV(QYLURQPHQWDO'RFXPHQWDWLRQ :DWHU x The 2001 FEIS/EIR determined that Irvine Ranch Water District (IRWD) would have sufficient water supplies, and offsite delivery system, and that water distribution improvements would be required within the project site to convey water required by the TLSP as analyzed in the 2001 FEIS/EIR. x Potable Water- The MCAS Tustin/Legacy Park Revised Sub-area Master Plan (SAMP) completed by RBF Consulting in September 2008 determined that the existing water mains would be inadequate for distribution of potable water at buildout. The Adopted Specific Plan required the construction of a network of new water mains and phased abandonment of existing mains. x Reclaimed Water- The 2008 SAMP estimated that the Adopted Specific Plan’s non-potable water demands had sufficient residual reclaimed water treatment capacity to meet estimated TLSP demands. 279 □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 115 x The TLSP 2017 SEIR determined that IRWD has sufficient residual water supplies to meet the potable and non-potable water demands of the TLSP based on very conservative water demand estimates. Therefore, impacts were determined to be less than significant. x The TLSP 2025 SEIR determined that sufficient water supply and infrastructure capacity exist to serve the TLSP and cumulative development under all hydrologic conditions through 2044. Further, with implementation of TLSP 2025 Mitigation Measure UT-1, water and groundwater impacts were determined to be less than significant. Further, the TLSP 2025 SEIR concluded that IRWD would have sufficient water supplies to meet projected demand through 2044 based on the Project-specific Water Supply Assessment (WSA), including during dry and multiple dry year conditions. Therefore, cumulative impacts related to water supply and service were also determined to be less than significant. :DVWHZDWHU x The 2001 FEIS/EIR determined that impacts to wastewater conveyance and treatment were less than significant with no mitigation required. x The TLSP 2017 SEIR determined that the TLSP would not result in any new impacts, or increase the severity of impacts, with respect to wastewater conveyance or treatment. x The TLSP 2025 SEIR determined that existing wastewater facilities operated by IRWD and OC Sanitation District have sufficient capacity to accommodate full buildout of the TLSP, including the additional 4,970 dwelling units. With implementation of Mitigation Measure UT-1, requiring coordination with IRWD to update the SAMP and verify conveyance capacity before development, impacts related to wastewater infrastructure and treatment would be less than significant with mitigation. The TLSP 2025 SEIR also concluded that existing IRWD and OCSD facilities have sufficient capacity to serve cumulative development. Therefore, cumulative wastewater impacts would be less than significant 2WKHU8WLOLWLHV x Electric power, natural gas, and telecommunication facilities were not previously analyzed within the 2001 FEIS/EIR or subsequent environmental documentation for the TLSP. 7/636(,5$SSOLFDEOH0LWLJDWLRQ0HDVXUHV 7/636(,50087Prior to project approval, the development applicant shall coordinate with IRWD to conduct infrastructure analyses of water and sewer utilities in the project area to ensure existing conveyance and pressure is adequate to serve the project. Once development assumptions identified within the IRWD-approved SAMP are surpassed, project applicants shall coordinate with IRWD to update the SAMP for the TLSP area. D 5HTXLUHRUUHVXOWLQWKHFRQVWUXFWLRQRIQHZRUH[SDQGHGZDWHUZDVWHZDWHUWUHDWPHQWRUVWRUP ZDWHUGUDLQDJHHOHFWULFSRZHUQDWXUDOJDVRUWHOHFRPPXQLFDWLRQVIDFLOLWLHVWKHFRQVWUXFWLRQRU UHORFDWLRQRIZKLFKFRXOGFDXVHVLJQLILFDQWHQYLURQPHQWDOHIIHFWV" The TLSP 2025 SEIR concluded that impacts related to the construction or expansion of new facilities would be less than significant with the implementation of TLSP 2025 SEIR MM UT- 1. TLSP 2025 SEIR MM UT- 1 requiresthat applicants conduct infrastructure analyses of water and sewer utilities to ensure existing conveyance and pressure is adequate to serve the Project. If the development assumptions of the IRWD SAMP are surpassed, developers shall coordinate with IRWD the prior to issuance of the grading permits. With the implementation of TLSP 2025 SEIR MM UT- 1, impacts were determined to be less than significant (City of Tustin, 2025c). 280 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 116 ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFW Water and Sewer Improvements As discussed in Section 3, Project Description, The Project would construct 4-inch and 6-inch domestic water lines onsite that would connect to the existing 10-inch PVC water lines within John Johnson Way and Veterans Way. The Project would also implement fire hydrants that would receive water from the proposed 6-inch fire water lines onsite which would connect to the existing10-inch PVC water lines within John Johnson Way and Veterans Way. The Project would construct new sewer lines onsite which would connect to the existing 8-inch sewer line in Veterans Way and 8-inch sewer line in John Johnson Way. As such, the proposed Project would not require or result in the construction of new, unplanned off-site water and sewer facilities or the expansion of existing off-site facilities. Thus, no new impacts would result beyond those identified in the TLSP 2025 SEIR. Drainage Improvements As discussed in Section 3, Project Description, a series of onsite storm drain facilities with LID and Peak Storm would be incorporated on the Project site. Project runoff will be directed to a system of inlets and storm drains, to collect, store, and convey runoff. The proposed storm drain system would be oversized to include storage volume: inclusive of a 42-inch storm drain and a 48-inch storm drain. The oversized storm drains would convey flow into a modular wetland system (MWS) along Armstrong Avenue. Additionally, there would be two StormCapture chambers onsite each of which would be able to store up to 6,720 cubic feet of runoff. The storm drains, StormCapture chambers, and MWS would ultimately discharge to the existing storm drain under Armstrong Avenue and John Johnson Way. Further, the proposed Project would be adequately sized to treat the 100-year storm event. The proposed Project would not require or result in the construction of new, unplanned off-site drainage facilities or expansion of existing off-site facilities. Thus, no new impacts would result beyond those identified in the TLSP 2025 EIR. The Project would also connect to existing electric power, natural gas, and telecommunication facilities. Therefore, the Project would not result in the relocation or construction of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunication facilities that could cause environmental effects. Impacts would be less than significant. The proposed Project is proposing the development of 142,566 SF of assisted living uses and 172 senior residential units. The TLSP 2025 SEIR analyzed up to 606,000 SF of Mixed-Use Urban uses and 2,427 residential units (including density bonus units) in Neighborhood D South. Currently, Neighborhood D South has an existing buildout of 0 SF of non-residential uses and a total of 2,112 residential units; thus, it would have sufficient capacity to accommodate the proposed 142,566 SF of non-residential uses and the 172 residential units associated with the proposed development. As such, the proposed Project is within the scope of what was previously analyzed by the TLSP 2025 SEIR. With the implementation of TLSP 2025 SEIR MM UT- 1, impacts would be less than significant. Thus, no new or substantially greater impacts would occur with implementation of the proposed Project and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. E +DYHVXIILFLHQWZDWHUVXSSOLHVDYDLODEOHWRVHUYHWKHSURMHFWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUH GHYHORSPHQWGXULQJQRUPDOGU\DQGPXOWLSOHGU\\HDUV" The TLSP 2025 SEIR concluded that impacts related to water supplies would result in a less than significant impact (City of Tustin, 2025c). 281 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 117 ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWThe TLSP 2025 SEIR concluded that impacts related to water supplies would be less than significant. The IRWD is responsible for supplying potable water to the Project site. Further, the TLSP 2025 SEIR determined that the IRWD would have sufficient water supplies to meet projected demand through 2044 based on the WSA that was prepared, including during dry and multiple dry year conditions. The IRWD’s water supply is a combination of groundwater, imported water, and recycled water. Approximately 50 percent of IRWD’s water supplies comes from local groundwater wells in the Orange County Groundwater Basin (OC Basin), and the Irvine and Lake Forest sub-basins. Imported water from the Metropolitan Water District of Southern California (MWD) makes up less than one-fifth of IRWD’s supply. Water imported to Orange County comes from two sources: from the Sacramento-San Joaquin Delta in Northern California through the State Water Project (SWP), and from the Colorado River through the Colorado River Aqueduct. The IRWD meets about a quarter of the service area’s water demands with recycled water. The 2025 TLSP SEIR prepared a WSA which details that IRWD has adequate supplies to serve its customers during normal, dry year, and multiple dry year demand through 2040. The 2020 UWMP describes that IRWD used 95 gallons per capita per day (GPCD) in 2020, which is below the target of 171 GPCD for 2020. As described previously in Section 5.8, Population and Housing, the Project would result in approximately 629 new residents. Thus, the Project would require approximately 59,775 gpd or 65.9 acre- feet per year (AFY), which is within the demand assumptions previously accounted for within the TLSP 2025 SEIR, as shown on Table UT-1. 7DEOH87,5:'6XSSO\DQG'HPDQGZLWK7/636(,53URMHFW%XLOGRXW'XULQJ1RUPDO'U\DQG 0XOWLSOH'U\<HDU6FHQDULRV $)  )RUHFDVW<HDU 1RUPDO<HDU Maximum Supply Capability 101,911 104,711 104,711 104,711 104,711 Existing Demand 76,540 80,802 83,150 83,359 83,525 Existing Demand + TLSP 2025 SEIR Project 76,467 80,981 83,748 83,958 84,126 Cumulative Buildout Demand 76,467 80,981 83,748 83,958 84,126 Reserve Supply with Project 25,444 23,730 20,963 20,753 20,585 6LQJOH'U\<HDU Maximum Supply Capability 99,863 102,663 102,663 102,663 102,663 Existing Demand + TLSP 2025 SEIR Project 81,898 86,458 88,971 89,194 90,015 Existing Demand + Project 81,820 86,649 89,611 89,835 90,015 Cumulative Buildout Demand 81,820 86,649 89,611 89,835 90,015 Reserve Supply with Project 18,043 16,013 13,052 12,828 12,648 0XOWLSOH'U\<HDU Maximum Supply Capability 99,863 102,663 102,663 102,663 102,663 Existing Demand 81,898 86,458 88,971 89,194 89,372 Existing Demand + Project 81,820 86,649 89,611 89,835 90,015 Cumulative Buildout Demand 81,820 86,649 89,611 89,835 90,015 Reserve Supply with Project 18,043 16,013 13,052 12,828 12,648 Source: TLSP 2025 SEIR 282 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 118 The Project would also be required to be compliant with CalGreen/Title 24 requirements for low flow plumbing fixtures and irrigation, which would provide for efficient water use. Given that the Project is within the previously analyzed assumptions, IRWD has sufficient water supplies available to serve the Project during normal, dry, and multiple dry years, and impacts would be less than significant. Thus, impacts from the proposed Project are consistent with the impacts identified in the TLSP 2025 SEIR and the level of impact remains unchanged from that cited in the TLSP 2025 SEIR. F :RXOG WKH 3URMHFW VXEVWDQWLDOO\ GHFUHDVH JURXQGZDWHU VXSSOLHV RU LQWHUIHUH VXEVWDQWLDOO\ ZLWK JURXQGZDWHUUHFKDUJHVXFKWKDWWKHSURMHFWPD\LPSHGHVXVWDLQDEOHJURXQGZDWHUPDQDJHPHQWRI WKHEDVLQ" & G :RXOG WKH 3URMHFW FRQIOLFW ZLWK RU REVWUXFW LPSOHPHQWDWLRQ RI D ZDWHU TXDOLW\ FRQWURO SODQ RU VXVWDLQDEOHJURXQGZDWHUPDQDJHPHQWSODQ" The TLSP 2025 SEIR concluded that impacts related to groundwater recharge would result in a less than significant impact (City of Tustin, 2025c). ,PSDFWV$VVRFLDWHGZLWKWKH3URSRVHG3URMHFW 1R1HZ,PSDFWOCWD 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. The Basin 8-1 Alternative Plan further lists existing groundwater contamination sites within the OCWD Management Area and describes that the U.S. Navy is taking the lead in remediation of the former Tustin MCAS, which closed in 1999 but has been identified as contaminated since. Thus, the Project site is not used for groundwater recharge and contains soils with poor infiltration capacity due to high groundwater levels onsite and groundwater contamination from former military operations (City of Tustin, 2025c). The TLSP 2025 SEIR describes that site remediation efforts consisting of pumping and treating groundwater, in-situ bioremediation, and monitored natural attenuation are ongoing. As such, the Project site is not in or near a groundwater recharge area/facility, nor does it represent a source of groundwater recharge. Therefore, the proposed Project would not substantially interfere with groundwater supplies or recharge and there would be no new impact when compared to what was analyzed within the TLSP 2025 SEIR. Additionally, groundwater supply and demand were evaluated through the TLSP 2025 SEIR WSA which determined that groundwater supplies are sufficient to meet the demands of the TLSP 2025 SEIR buildout, including the proposed Project. The Project would not decrease groundwater supplies or interfere substantially with groundwater recharge. 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 and there would be no new impact when compared to what was analyzed within the TLSP 2025 SEIR. &RQFOXVLRQ Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 exist that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures regarding utilities and service systems. There have not been 1) changes related to development of the Project site that involve new significant environmental effects or a substantial increase in the severity of previously identified effects; 2) substantial changes with respect to the circumstances under which development of the Project site is undertaken that require major revisions of the TLSP 2025 SEIR due to the involvement of new significant environmental effects or a substantial increase in 283 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 119 the severity of previously identified effects; or 3) the availability of new information of substantial importance relating to significant effects or mitigation measures or alternatives that were not known and could not have been known when the TLSP 2025 SEIR was certified as completed. Because none of the conditions identified in CEQA Guidelines Section 15162 would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts, CEQA Guidelines 15168 also does not require additional environmental review, and the Project is within the scope of the TLSP with respect to utilities and service systems. 3ODQV3URJUDPVRU3ROLFLHV 333V  33387&DOLIRUQLD%XLOGLQJ&RGHAll 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. 3URMHFW'HVLJQ)HDWXUHV 3')V  None. 0LWLJDWLRQ0RQLWRULQJ5HTXLUHG Final EIR mitigation measures that are applicable to the proposed Project would be implemented as intended by the TLSP 2025 SEIR. After implementation of the applicable mitigation measures, no new impacts nor substantially more severe utilities and service systems impacts would result from implementation of the proposed Project; therefore, no new or revised mitigation measures are required regarding utilities and service systems. TLSP 2025 SEIR Mitigation Measures Applicable to the Proposed Project 7/636(,50087 As listed above. 284 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 120 6. DOCUMENT PREPARERS AND CONTRIBUTORS /HDG$JHQF\ City of Tustin Planning Department 300 Centennial Way Tustin, CA 92680 &(4$'RFXPHQW3UHSDUHU (3'6ROXWLRQV,QF Konnie Dobreva, JD Danielle Thayer Jazmin Rodriguez Lauren Battle 285 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 121 7. REFERENCES California Department of Finance. (2025, May). Retrieved from E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2025: https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates- for-cities-counties-and-the-state-2020-2025/ California Department of Forestry and Fire. (2025, October). 2025 Fire Hazard Severity Zones in Local Responsibility Area, as Recommended by the State Fire Marshal. Retrieved from CAL Fire: https://experience.arcgis.com/experience/5065c998b4b0462f9ec3c6c226c610a9/page/Com pare-old-and-new-LRA-FHSZ Center for Demographics Research. (2004). Orange County Projections 2004: Population, Housing and Employment Through 2030. City of Tustin. (2018, November). City of Tustin General Plan. Retrieved from https://www.tustinca.org/DocumentCenter/View/713/City-of-Tustin-General-Plan-PDF City of Tustin. (2025a). Retrieved from Tustin Police Department About Us: https://www.tustinca.org/177/About-Us#:~:text=Staff%20Overview,Department%20Heroes City of Tustin. (2025b). Tustin Legacy Specific Plan. Retrieved from chrome- extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.tustinca.org/DocumentCenter/View/ 706/Tustin-Legacy-Specific-Plan-PDF?bidId= City of Tustin. (2025c). Tustin Legacy Specific Plan Amendment Daft Supplemental EIR. Retrieved from chrome- extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.tustinca.org/DocumentCenter/View/ 15579/Exhibit-3B---Draft-SEIR-Tustin-Legacy---HE-Sites-1A-1B-2-combined-reduced?bidId= Federal Transit Administration. (2018, September). Transit Noise and Vibration Impact Manual. Retrieved from chrome- extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.transit.dot.gov/sites/fta.dot.gov/file s/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta- report-no-0123_0.pdf SCAG. (2022, December). Local Data Exchange. Retrieved from https://www.scag.ca.gov/local-data- exchange SCAG. (2024, April 4). Connect SoCal 2024 Regional Transporation Plan. Retrieved from https://scag.ca.gov/connect-socal South Coast Air Quality Management District. (n.d.). RULE 1113. Architectural Coatings. Retrieved from http://www.aqmd.gov/rules/reg/reg11/r1113.pdf South Coast Air Quality Management District. (n.d.). RULE 1186. PM10 Emissions From Paved and Unpaved Roads, and Livestock Operations. Retrieved from http://www.aqmd.gov/docs/default-source/rule- book/reg-xi/rule-1186-1-less-polluting-sweepers.pdf?sfvrsn=4 South Coast Air Quality Management District. (n.d.). RULE 403. Fugitive Dust. Retrieved from http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-403.pdf?sfvrsn=4 South Coast Air Quality Management District. (n.d.). RULE 431.2. Sulfur Content of Liquid Fuels. Retrieved from http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-431-2.pdf?sfvrsn=4 286 Clearwater Living at Tustin Legacy Project Addendum to the Tustin Legacy Specific Plan Supplemental EIR City of Tustin 122 Special District Financing and Administration. (2024, April). Retrieved from Tustin Unified School District Fee Justification Report for Residential and Commercial/Industrial Development: https://resources.finalsite.net/images/v1713309559/tustink12caus/ooojc5pfefsjd3qukhop/Devel operFeeStudy-April20241.pdf 287 3URMHFW2YHUYLHZ The Clearwater Living Tustin Project (proposed Project) would construct a residential and living/memory care development on a currently vacant site. The proposed Project would subdivide the existing 6.14-acre parcel into two parcels. Each parcel would contain three residential buildings, or six buildings total. The buildings would provide a total of 275 new dwelling units. The 275 units would include 172 active adult housing units and 103 assisted living/memory care units (75 assisted living and 28 memory care units). Additionally, the proposed Project includes landscaping, a parking garage, recreation amenities, and utility and stormwater improvements. The proposed site plans are provided in Figures 1 and 2. To support the CEQA documentation for the Project, this report analyzes the proposed Project’s localized construction impacts on air quality (emission of criteria pollutants) using the California Emissions Estimator Model (CalEEMod Version 2022.1) land use emission model. Table 1, Construction Schedule, shows the estimated construction schedule, which is expected to last approximately 24 months. The shorter construction period results in higher daily emissions, which reflects a conservative approach to the analysis. The overall emissions, however, are constrained by the limited scale of the Project. 7DEOH&RQVWUXFWLRQ6FKHGXOH To: From: Date: Re: City of Tustin Planning Division Maryam Javanmardi, Tina Yuan; EPD Solutions, Inc. /2/202 Localized Construction Emissions Analysis for Clearwater Living Tustin Project, EPD Project Number 25-104 $FWLYLW\6WDUW'DWH (QG'DWH 7RWDO:RUNLQJ'D\V Site Preparation 7/1/2026 7/28/2026 20 Grading 7/29/2026 8/25/2026 20 Building Construction 8/26/2026 5/2/2028 440 Paving 5/3/2028 5/30/2028 20 Architectural Coating 5/31/2028 7/18/2028 35 Source: CalEEMod Output Sheets (see Attachment A). 288 I E I p I D SOLUTIDNS ,INC WHERE EXPERIENCE AND PASSION MEET Due Diligence Entitlement Environmental Planning Development & Construction Management I Policy Planning I Technical Services 3333 Michelson Dr. Suite 500 Irvine, CA 92612 949.794.1180 I epd@epdsolutions.com I Clearwater Living Tustin Project Localized Construction Emissions Analysis 2 )LJXUH6LWH3ODQ $33/,&$%/(&2'(6 &$/,)251,$&2'(2)5(*8/$7,216&&57,7/(3$57&$/,)251,$$'0,1,675$7,9(&2'(&&57,7/(3$57&$/,)251,$%8,/',1*&2'(&&57,7/( ,17(51$7,21$/%8,/',1*&2'(2)7+(,17(51$7,21$/&2'(&281&,/,&&Z&$/,)251,$$0(1'0(176 3$57&$/,)251,$(/(&75,&$/&2'(&&57,7/( 1$7,21$/(/(&75,&$/&2'(2)7+(1$7,21$/),5(3527(&7,21$662&,$7,211)3$ 3$57&$/,)251,$0(&+$1,&$/&2'(&&57,7/( 81,)2500(&+$1,&$/&2'(2)7+(,17(51$7,21$/$662&,$7,212)3/80%,1*$1'0(&+$1,&$/2)),&,$/6,$302 3$57&$/,)251,$3/80%,1*&2'(&&57,7/( 81,)2503/80%,1*&2'(2)7+(,17(51$7,21$/$662&,$7,212)3/80%,1*$1'0(&+$1,&$/2)),&,$/6,$302 3$57&$/,)251,$(1(5*<&2'(&&57,7/(3$57&$/,)251,$),5(&2'(&&57,7/( ,17(51$7,21$/),5(&2'(2)7+(,17(51$7,21$/&2'(&281&,/,&& 3$57&$/,)251,$*5((1%8,/',1*67$1'$5'6&2'( &$/*UHHQ&2'( &&57,7/(3$57&$/,)251,$5()(5(1&('67$1'$5'6&2'(&&57,7/( 7867,1&2'(2)25',1$1&(6$57,&/(%8,/',1*5(*8/$7,216$57,&/(/$1'86( 7867,1/(*$&<63(&,),&3/$125',1$1&( 3$57,$//,672)$33/,&$%/(67$1'$5'6 1)3$3257$%/(),5((;7,1*8,6+(56 (',7,211)3$,167$//$7,212)635,1./(56<67(06 (',7,211)3$5 635,1./(56<67(06,1/2:5,6(5(6,'(17,$/2&&83$1&,(6 (',7,211)3$,167$//$7,212)67$1'3,3( +26(6<67(06 &$$0(1'(' (',7,211)3$'5<&+(0,&$/(;7,1*8,6+,1*6<67(06 (',7,211)3$$:(7&+(0,&$/(;7,1*8,6+,1*6<67(06 (',7,211)3$,167$//$7,212)67$7,21$5<38036)25),5(3527(&7,21 (',7,211)3$35,9$7(),5(0$,16 7+(,5$33857(1$1&(6 &$$0(1'(' (',7,211)3$1$7,21$/(/(&75,&$/&2'( (',7,211)3$1$7,21$/),5($/$50$1'6,*1$/,1*&2'( &$$0(1'(' (',7,211)3$),5('2256$1'27+(523(1,1*3527(&7,9(6 (',7,211)3$$67$1'$5')253$5.,1*6758&785(6 (',7,211)3$$,167$//$7,212)$,5&21',7,21,1* 9(17,/$7,216<67(06 (',7,211)3$/,)(6$)(7<&2'( (',7,211)3$602.('225$66(0%/,(6 27+(523(1,1*3527(&7,9(6 (',7,211)3$(0(5*(1&< 67$1'%<32:(56<67(06 (',7,211)3$7<3(62)%8,/',1*&216758&7,21 (',7,211)3$0(7+2'62)),5(7(6762)'225$66(0%/,(6 (',7,211)3$&5,7,&$/5$',$17)/8;2))/225&29(5,1*6<67(06 (',7,211)3$&/($1$*(17),5((;7,1*8,6+,1*6<67(06 (',7,21 &%&5()(5(1&( 2&&83$1&<*5283 66(& 7<3(2)&216758&7,21 ,$6(& ),5(635,1./(56<67(0 )8//$8720$7,&635,1./(56<67(07+528*+287%8,/',1*$5($3(51)3$ %8,/',1*+(,*+7 $//2:$%/(%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(*52836$1'% 635,1./(5('  81/,0,7(' $&78$/%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(  7$%/( $&7,9($'8/73$5.,1**$5$*( $//2:$%/(180%(52)6725,(6$%29(*5$'(3/$1(*52836$1'% 635,1./(5(' 81/,0,7(' $&78$/180%(52)6725,(6$%29(*5$'(3/$1( 7$%/( %8,/',1*$5($$//2:$%/(%8,/',1*$5($3(56725<*52836$1'% 6 81/,0,7(' $&78$/%8,/',1*$5($)/225 6%727$/),567)/225 6) 6)6) 7$%/( ),5(5(6,67$1&(5$7,1*5(48,5(0(176 7$%/(%8,/',1*(/(0(17 ),5(5(6,67$1&(5$7,1* 35,0$5<6758&785$/)5$0(+2856 %($5,1*:$//6(;7(5,25,17(5,25 +2856+2856 121%($5,1*:$//6$1'3$57,7,216(;7(5,25,17(5,25 6((7$%/(%(/2:+2856 )/225&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +2856 522)&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +2856 7$%/(),5(6(3$5$7,21',67$1&(5$7,1*)2552&&83$1&<;  ;  ; ;! +285+285+285+2856 2&&83$1&<*5283 $$ ),5676(&21'$1'7+,5')/22565 6(&21'7+528*+),)7+)/225 6(&6(&6(&% ),567$1'6(&21')/2256 6(& 7<3(2)&216758&7,21 9$R6,1*/(6725<$32',80&216758&7,21 6(&6(& ),5(635,1./(56<67(0 )8//$8720$7,&635,1./(56<67(07+528*+287%8,/',1*$5($3(51)3$6(&6(& %8,/',1*+(,*+7 $//2:$%/(%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(*5283$ 635,1./(5('Z$5($,1&5($6(   *52835 635,1./(5('Z$5($,1&5($6(   $&78$/%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(  $$2&&83$1&,(6/,0,7('72 7$%/( $&7,9($'8/7 $//2:$%/(180%(52)6725,(6$%29(32',803$5.,1**$5$*(*5283$$ 635,1./(5('Z$5($,1&5($6(  *52835 635,1./(5('Z$5($,1&5($6(   $&78$/180%(52)6725,(6$%29(32',803$5.,1**$5$*(  $$2&&83$1&,(6/,0,7('727+,5')/225 7$%/(6(& 6(& &%&5()(5(1&( %6(& 7$%/(6(& $&&(6625< *5283%$1'6 6(& %8,/',1*$5($$//2:$%/($5($5$7,2&$/&8/$7,21 $&7,9($'8/7 &217 ' &%&5()(5(1&(),5($5($6 7$%/(7$%/(127(D6(& 7+(),5(%$55,(56),5(:$//6+25,=217$/$66(0%/,(625&20%,1$7,2167+(5(2)6(3$5$7,1*$6,1*/(2&&83$1&<,172',))(5(17),5($5($66+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$17+$7,1',&$7(',17$%/(7+(),5(%$55,(56),5(:$//6+25,=217$/$66(0%/,(625&20%,1$7,2167+(5(2)6(3$5$7,1*),5($5($62)0,;('2&&83$1&,(66+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$17+(+,*+(679$/8(,1',&$7(',17$%/()257+(2&&83$1&,(681'(5&216,'(5$7,21 )25*5283$%$1'52&&83$1&,(6$0,1,080+285),5(5(6,67$1&(5$7,1*,65(48,5(' 81,76(3$5$7,21:$//6 6(&6(&:$//66(3$5$7,1*':(//,1*81,76,17+(6$0(%8,/',1*:$//66(3$5$7,1*6/((3,1*81,76,17+(6$0(%8,/',1*$1':$//66(3$5$7,1*':(//,1*256/((3,1*81,76)52027+(52&&83$1&,(6&217,*8286727+(0,17+(6$0(%8,/',1*6+$//%(&216758&7('$6),5(3$57,7,216,1$&&25'$1&(:,7+6(&7,21 +25,=217$/81,76(3$5$7,21 6(&6(&)/225$66(0%/,(66(3$5$7,1*':(//,1*81,76,17+(6$0(%8,/',1*6)/225$66(0%/,(66(3$5$7,1*6/((3,1*81,76,17+(6$0(%8,/',1*$1')/225$66(0%/,(66(3$5$7,1*':(//,1*256/((3,1*81,76)52027+(52&&83$1&,(6&217,*8286727+(0,17+(6$0(%8,/',1*6+$//%(&216758&7('$6+25,=217$/$66(0%/,(6,1$&&25'$1&(:,7+6(&7,21 ),5(5(6,67$1&(5$7,1*5(48,5(0(176 7$%/(%8,/',1*(/(0(17 ),5(5(6,67$1&(5$7,1* 35,0$5<6758&785$/)5$0( +285 %($5,1*:$//6(;7(5,25,17(5,25 +285+285 121%($5,1*:$//6$1'3$57,7,216(;7(5,25,17(5,25 6((7$%/(%(/2:+2856 )/225&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +285 522)&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +285 7$%/(),5(6(3$5$7,21',67$1&( 5$7,1*)25$% 52&&83$1&<;  ;  ; ;! +285+285+285+2856 +25,=217$/%8,/',1*6(3$5$7,21        7+($&7,9($'8/7%8,/',1*,6&216,'(5('$66(3$5$7($1'',67,1&7)5207+(3$5.,1**$5$*()257+(385326(2)'(7(50,1,1*$5($/,0,7$7,216&217,18,7<2)),5(:$//6/,0,7$7,212)180%(52)6725,(6$1'7<3(2)&216758&7,216,1&(7+()2//2:,1*&21',7,216$5(0(7 7+(%8,/',1*6$5(6(3$5$7(':,7+$+25,=217$/$66(0%/<+$9,1*$),5(5(6,67$1&(5$7,1*2)127/(667+$1+2856:+(5(9(57,&$/2))6(76$5(3529,'('$63$572)$+25,=217$/$66(0%/<7+(9(57,&$/2))6(7$1'7+(6758&785(6833257,1*7+(9(57,&$/2))6(76+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$1+28567+(%8,/',1*%(/2:,1&/8',1*7+(+25,=217$/$66(0%/<,62)7<3(,$&216758&7,216+$)767$,5:$<5$03$1'(6&$/$725(1&/2685(67+528*+7+(+25,=217$/$66(0%/<6+$//+$9(127/(667+$1$+285),5(5(6,67$1&(5$7,1*:,7+23(1,1*3527(&7,9(6,1$&&25'$1&(:,7+6(&7,21,17(5,25(;,767$,5:$<6/2&$7(':,7+,17+(7<3(,$%8,/',1*$5(3(50,77('72%(2)&20%867,%/(0$7(5,$/66,1&(7+()2//2:,1*5(48,5(0(176$5(0(7D 7+(%8,/',1*$%29(7+(7<3(,$%8,/',1*,62)7<3(9&216758&7,21E 7+(67$,5:$</2&$7(',17+(7<3(,$%8,/',1*,6(1&/26('%<+285),5(5(6,67$1&(5$7('&216758&7,21:,7+23(1,1*3527(&7,9(6,1$&&25'$1&(:,7+6(&7,217+(%8,/',1*6$%29(7+(+25,=217$/$66(0%/<$5(3(50,77('72+$9(08/7,3/(*5283$2&&83$1&<86(6($&+:,7+$12&&83$17/2$'2)/(667+$125*5283%052562&&83$1&,(67+(%8,/',1*%(/2:7+(+25,=217$/$66(0%/<:,//%(3527(&7('7+528*+287%<$1$33529('$8720$7,&635,1./(56<67(0,1$&&25'$1&(:,7+6(&7,21$1',63(50,77('72%($1<2&&83$1&<$//2:('%<7+,6&2'((;&(37*5283+7+(0$;,080%8,/',1*+(,*+7,1)((76+$//127(;&(('7+(/,0,766(7)257+,16(&7,21)257+(%8,/',1*+$9,1*7+(60$//(5$//2:$%/(+(,*+7$60($685(')5207+(*5$'(3/$1( 6(($&7,9($'8/7),5($5($3/$16217+,66+((7 6(& 6((6+((7$$$)25$&7,9($'8/73$5.,1**$5$*(3/$1 '(0$1' 3(5&,7<2)7867,1&2'(2)25',1$1&(6$57,&/(3$576(&63$&(6 63$&(81,7*8(6763$&(81,76  3529,'(' 67$1'$5'63$&(6#3$5.,1**$5$*( 63$&(667$1'$5'63$&(6#685)$&(3$5.,1*63$&(663$&(6&203$&763$&(6#3$5.,1**$5$*(  [  63$&(6727$/63$&(6 $&&(66,%/(63$&(65(48,5(' 3(5&(172)727$/63$&(672%($&&(66,%/( 3(5&%&6(&$ #3$5.,1**$5$*( [ $&&(66,%/(63$&(6#685)$&(3$5.,1* [ $&&(66,%/(63$&(63529,'(9$1$&&(66,%/(63$&()25(9(5<$&&(66,%/(63$&(6 3(5&%&6(&$ 3529,'(' #3$5.,1**$5$*( $&&(66,%/(63$&(6 ,1&/8',1*9$163$&(6 #685)$&(3$5.,1* $&&(66,%/(63$&(6 ,1&/8',1*9$163$&( (/(&75,&9(+,&/(63$&(63(5&$/*5((16(&5(48,5(' (95($'< (95 ,13/$1 2)727$/63$&(6#3$5.,1**$5$*( [ /2:32:(5/(9(/5(&(37$&/(6#685)$&(3$5.,1* [ /2:32:(5/(9(/5(&(37$&/(6 (9&+$5*(56 (9&6 ,13/$1 2)727$/63$&(6#3$5.,1**$5$*( [ /(9(/(9&+$5*(563529,'(9$1$&&(66,%/((9&6>3(5&$/*5((1  @#685)$&(3$5.,1* [ /(9(/(9&+$5*(56 3529,'(9$1$&&(66,%/((9&6 3(5&%&7$%/(% 3529,'(' (95($'< (95 #3$5.,1**$5$*( /2:32:(5/(9(/5(&(37$&/(6#685)$&(3$5.,1* /2:32:(5/(9(/5(&(37$&/(6 (9&+$5*(56 (9&6 #3$5.,1**$5$*( /(9(/(9&+$5*(56 ,1&/8',1*9$1$&&(66,%/(63$&( #685)$&(3$5.,1* /(9(/(9&+$5*(56 ,1&/8',1*9$1$&&(66,%/(63$&( 6+2577(50%,&<&/(3$5.,1*1275(48,5('3(5&$/*5((16(& /21*7(50%,&<&/(3$5.,1*3(5&$/*5((16(&5(48,5(' 7%'3529,'(' 7%' 3(57867,1/(*$&<63(&,),&3/$1 25',1$1&( 6(&'(9(/230(1767$1'$5'6)253/$11,1*$5($6  7$%/(6,7(&21),*85$7,215(*8/$7,216/27$5($ 5(6,'(17,$/  %8,/',1*6(7%$&.6$5067521*$9(18(:$51(5$9(18(/2&$/52$' ',67$1&(%(7:((1%8,/',1*$1'$&&(6625<6758&785( 0,1,080121( 0,1,080    0,1,080  0$;,080121( 0$;,080121(121(121( 0$;,080121( $&78$/$& 6) 352326(' 0,1 0,1 0,1 352326(' 0,1 7$%/(%8,/',1*+(,*+75(*8/$7,216%8,/',1*+(,*+7 7$%/()5217$*(&$7(*25,(6*5281')/2255(6,'(17,$/ 7$%/(23(163$&(5(*8/$7,2165(6,'(17,$/ 0,1,080121( )5217$*(7<3(325&+ 7<3(35,9$7(&20021 0$;,080  :$51(53(50,77(' 67$1'$5'6)3(581,76)3(581,7 352326(' 0$; $9(522)'(&.+(,*+7 /2&$/&211(&7253(50,77(' 352326('6((7$%/(%(/2:6((7$%/(%(/2: 23(163$&(7<3(35,9$7(5(48,5(0(176)81,7 7$%/(3(50,77('86(5(*8/$7,216 6(59,&(&200(5&,$/ 2)),&( 5(7$,/&200(5&,$/ 38%/,&,167,787,21$/ 3(57867,1&2'(2)25',1$1&(6&+$37(56(&/$1'6&$3(5(48,5(0(176)253$5.,1*$5($6 25'126(&  3(50$1(17/$1'6&$3,1*)25,17(5,253$5.,1*/275(48,5('2),17(5,253$5.,1*/27$5($352326('3(5,0(7(53$5.,1*/27/$1'6&$3,1*$/21*675((7)5217$*(65(48,5(' :,'($/21*0$-25$57(5,$/+,*+:$<352326('1$ 123$5.,1*/27$/21*0$-25$57(5,$/+,*+:$< 86(*(1(5$/6(59,&(%86,1(66 86(*(1(5$/2)),&(0(',&$/2)),&(+($/7+&$5(&(17(5 86(*(1(5$/5(7$,/ 86(&21*5(*$7(&$5($66,67('/,9,1*)$&,/,7<23(163$&(38%/,&35,9$7(5(&5($7,21$/)$&,/,7<38%/,&35,9$7( *5281')/2253(50,77(' *5281')/2253(50,77('3(50,77(' *5281')/2253(50,77(' *5281')/225&21',7,21$/3(50,77('&21',7,21$/ 833(5)/22563(50,77(' 833(5)/22563(50,77('3(50,77(' 833(5)/22563(50,77(' 833(5)/2256&21',7,21$/3(50,77('&21',7,21$/$&7,9($'8/723(163$&(6800$5< &20021 6)81,7 180%(52)81,76 5(48,5('23(163$&( 6) 3529,'(' 6) %(/2:5(48,5(' 1$ $9(5$*(%$/&21<6,=(81,76 81,76 6)1$ ‡‡‡‡‡‡‡ ),5(635,1./(568335(66,216<67(0 ),5(021,725,1*$/$506<67(067((/67$,56(/(9$7256<67(066:,00,1*322/3+27292/7$,&6<67(0(0(5*(1&<5(6321'(55$',2&29(5$*(6,7(6,*1$*( %8,/',1*%8,/',1*%8,/',1* %8,/',1*6) %8,/',1*6)%8,/',1*6) +55$7('),5(:$// %8,/',1*%8,/',1*%8,/',1* %8,/',1*6) %8,/',1*6)%8,/',1*6) +55$7('),5(:$// %8,/',1*%8,/',1*%8,/',1* %8,/',1*6) %8,/',1*6)%8,/',1*6) +55$7('),5(:$// %8,/',1*%8,/',1*%8,/',1* %8,/',1*6) %8,/',1*6)%8,/',1*6) +55$7('),5(:$// &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ&OHDUZDWHUB7XVWLQB6LWHB5UYW$0$&7,9($'8/7352-(&7'$7$$1'&2'($1$/<6,6 * &/($5:$7(5$77867,1/(*$&< $&7,9($'8/7685)$&(3$5.,1* 7<3(&2817$&&(66,%/((9&+$5*(5 (95($'<67$1'$5'9$1$&&9$1$&&(9&+$5*(5 $$685)$&(3$5.,1*727$/ $&7,9($'8/73$5.,1**$5$*( 7<3( &2817$&&(66,%/( (9&+$5*(5 (95($'< 67$1'$5' 7$1'(067$1'$5' 9$1$&& 9$1$&&(9&+$5*(5 $$67$1'$5'3$5.,1*727$/ *29(51,1*&2'(6$1'67$1'$5'6 $&7,9($'8/7352-(&7'$7$ 122)81,7681,762&&83$1&<*52836 5$%122)6725,(66725,(6R6725<3$5.,1**$5$*(&216758&7,217<3( 7<3(9$:22')5$0(&216758&7,21R7<3(,$&21&5(7(&216758&7,213$5.,1**$5$*(*5266)/225$5($6) &2002123(163$&(6(($&7,9($'8/723(163$&(6800$5<81'(5 /2&$/=21,1*&2'(&203/,$1&( 217+,66+((7 /2&$/=21,1*&2'(&203/,$1&( 2$6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)   )/5 02675(675,&7,9(2&&*5283 $//2:$%/($5($ $W 7$%/( )5217$*(,1&5($6( 727$/$//2:$%/($5($3(5)/225 $&78$/$5($ ),5($5($$ 5$7,2 $&7,9($'8/7%8,/',1* 7<3(9$&216758&7,21 2$6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)   )/5 02675(675,&7,9(2&&*5283 $//2:$%/($5($ $W 7$%/( )5217$*(,1&5($6( 727$/$//2:$%/($5($3(5)/225 $&78$/$5($ ),5($5($$ 5$7,2 $&7,9($'8/7%8,/',1* 7<3(9$&216758&7,21 2$6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)    $$ 6) 6) 6) 6)    $$ 6) 6) 6) 6)   )/5 02675(675,&7,9(2&&*5283 $//2:$%/($5($ $W 7$%/( )5217$*(,1&5($6( 727$/$//2:$%/($5($3(5)/225 $&78$/$5($ ),5($5($$ 5$7,2 $&7,9($'8/7%8,/',1* 7<3(9$&216758&7,21 $$&203$&73$5.,1*727$/$$3$5.,1*727$/  '()(55('68%0,77$/6 $&7,9($'8/73$5.,1*$1$/<6,6 $&7,9($'8/7%8,/',1*&2'($1$/<6,6$&7,9($'8/7),5($5($3/$16 6&$/(  6(&21')/225),5($5($3/$1 6&$/(  7+,5')/225),5($5($3/$1 6&$/(  )2857+)/225),5($5($3/$1 6&$/(  ),)7+)/225),5($5($3/$1 ,668(' '$7('(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 289 E I p I D SDLUTID NS,INC Clearwater Living Tustin Project Localized Construction Emissions Analysis 3 )LJXUH6LWH3ODQ &RQWLQXHG 83 83 $33/,&$%/(&2'(6 &$/,)251,$&2'(2)5(*8/$7,216&&57,7/(3$57&$/,)251,$$'0,1,675$7,9(&2'(&&57,7/(3$57&$/,)251,$%8,/',1*&2'(&&57,7/( ,17(51$7,21$/%8,/',1*&2'(2)7+(,17(51$7,21$/&2'(&281&,/,&&Z&$/,)251,$$0(1'0(176 3$57&$/,)251,$(/(&75,&$/&2'(&&57,7/( 1$7,21$/(/(&75,&$/&2'(2)7+(1$7,21$/),5(3527(&7,21$662&,$7,211)3$ 3$57&$/,)251,$0(&+$1,&$/&2'(&&57,7/( 81,)2500(&+$1,&$/&2'(2)7+(,17(51$7,21$/$662&,$7,212)3/80%,1*$1'0(&+$1,&$/2)),&,$/6,$302 3$57&$/,)251,$3/80%,1*&2'(&&57,7/( 81,)2503/80%,1*&2'(2)7+(,17(51$7,21$/$662&,$7,212)3/80%,1*$1'0(&+$1,&$/2)),&,$/6,$302 3$57&$/,)251,$(1(5*<&2'(&&57,7/(3$57&$/,)251,$),5(&2'(&&57,7/( ,17(51$7,21$/),5(&2'(2)7+(,17(51$7,21$/&2'(&281&,/,&& 3$57&$/,)251,$*5((1%8,/',1*67$1'$5'6&2'( &$/*UHHQ&2'( &&57,7/(3$57&$/,)251,$5()(5(1&('67$1'$5'6&2'(&&57,7/( 7867,1&2'(2)25',1$1&(6$57,&/(%8,/',1*5(*8/$7,216$57,&/(/$1'86( 7867,1/(*$&<63(&,),&3/$125',1$1&( 3$57,$//,672)$33/,&$%/(67$1'$5'6 1)3$3257$%/(),5((;7,1*8,6+(56 (',7,211)3$,167$//$7,212)635,1./(56<67(06 (',7,211)3$5 635,1./(56<67(06,1/2:5,6(5(6,'(17,$/2&&83$1&,(6 (',7,211)3$,167$//$7,212)67$1'3,3( +26(6<67(06 &$$0(1'(' (',7,211)3$'5<&+(0,&$/(;7,1*8,6+,1*6<67(06 (',7,211)3$$:(7&+(0,&$/(;7,1*8,6+,1*6<67(06 (',7,211)3$,167$//$7,212)67$7,21$5<38036)25),5(3527(&7,21 (',7,211)3$35,9$7(),5(0$,16 7+(,5$33857(1$1&(6 &$$0(1'(' (',7,211)3$1$7,21$/(/(&75,&$/&2'( (',7,211)3$1$7,21$/),5($/$50$1'6,*1$/,1*&2'( &$$0(1'(' (',7,211)3$),5('2256$1'27+(523(1,1*3527(&7,9(6 (',7,211)3$$67$1'$5')253$5.,1*6758&785(6 (',7,211)3$$,167$//$7,212)$,5&21',7,21,1* 9(17,/$7,216<67(06 (',7,211)3$/,)(6$)(7<&2'( (',7,211)3$602.('225$66(0%/,(6 27+(523(1,1*3527(&7,9(6 (',7,211)3$(0(5*(1&< 67$1'%<32:(56<67(06 (',7,211)3$7<3(62)%8,/',1*&216758&7,21 (',7,211)3$0(7+2'62)),5(7(6762)'225$66(0%/,(6 (',7,211)3$&5,7,&$/5$',$17)/8;2))/225&29(5,1*6<67(06 (',7,211)3$&/($1$*(17),5((;7,1*8,6+,1*6<67(06 (',7,21 &%&5()(5(1&( 2&&83$1&<*5283 $$ ),567$1'6(&21')/2256 5 ),567$1'6(&21')/2256 6(&6(& 6(& % ),567$1'6(&21')/2256 6(& 7<3(2)&216758&7,21 9$$1'9$R6,1*/(6725<$32',80&216758&7,21 6(&6(& ),5(635,1./(56<67(0 )8//$8720$7,&635,1./(56<67(07+528*+287%8,/',1*$5($3(51)3$ %8,/',1*+(,*+7 $//2:$%/(%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(*5283$ 635,1./(5('Z$5($,1&5($6(  *52835 635,1./(5('  $&78$/%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(  7$%/( $66,67('/,9,1* $//2:$%/(180%(52)6725,(6$%29(*5$'(3/$1(*5283$$ 635,1./(5('Z$5($,1&5($6(  *52835 635,1./(5('   $&78$/180%(52)6725,(6$%29(*5$'(3/$1(   7$%/(6(& %8,/',1*$5($$//2:$%/($5($5$7,2&$/&8/$7,21 7$%/( 6(&6(&$&&(6625<*5283%$1'6 6(& &%&5()(5(1&( 2&&83$1&<*5283 66(& 7<3(2)&216758&7,21 ,$6(& ),5(635,1./(56<67(0 )8//$8720$7,&635,1./(56<67(07+528*+287%8,/',1*$5($3(51)3$ %8,/',1*+(,*+7 $//2:$%/(%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(*52836 635,1./(5('  81/,0,7(' $&78$/%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(  7$%/( $66,67('/,9,1*3$5.,1**$5$*( $//2:$%/(180%(52)6725,(6$%29(*5$'(3/$1(*52836 635,1./(5('  81/,0,7(' $&78$/180%(52)6725,(6$%29(*5$'(3/$1(  7$%/( %8,/',1*$5($ $//2:$%/(%8,/',1*$5($3(56725<*52836 81/,0,7(' $&78$/%8,/',1*$5($)/225 6727$/),567)/225 6)6) 7$%/( ),5(5(6,67$1&(5$7,1*5(48,5(0(176 7$%/(%8,/',1*(/(0(17 ),5(5(6,67$1&(5$7,1*35,0$5<6758&785$/)5$0(+2856%($5,1*:$//6(;7(5,25,17(5,25 +2856+2856 121%($5,1*:$//6$1'3$57,7,216(;7(5,25,17(5,25 6((7$%/(%(/2:+2856 )/225&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +2856 522)&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +2856 7$%/(),5(6(3$5$7,21',67$1&(5$7,1*)2552&&83$1&< ;  ;  ; ;! +285+285+285+2856 6(& %6(& &%&5()(5(1&($66,67('/,9,1* &217 ' 81,76(3$5$7,21:$//6 6(&6(&:$//66(3$5$7,1*':(//,1*81,76,17+(6$0(%8,/',1*:$//66(3$5$7,1*6/((3,1*81,76,17+(6$0(%8,/',1*$1':$//66(3$5$7,1*':(//,1*256/((3,1*81,76)52027+(52&&83$1&,(6&217,*8286727+(0,17+(6$0(%8,/',1*6+$//%(&216758&7('$6),5(3$57,7,216,1$&&25'$1&(:,7+6(&7,21 +25,=217$/81,76(3$5$7,21 6(&6(&)/225$66(0%/,(66(3$5$7,1*':(//,1*81,76,17+(6$0(%8,/',1*6)/225$66(0%/,(66(3$5$7,1*6/((3,1*81,76,17+(6$0(%8,/',1*$1')/225$66(0%/,(66(3$5$7,1*':(//,1*256/((3,1*81,76)52027+(52&&83$1&,(6&217,*8286727+(0,17+(6$0(%8,/',1*6+$//%(&216758&7('$6+25,=217$/$66(0%/,(6,1$&&25'$1&(:,7+6(&7,21 6(($66,67('/,9,1*),5($5($3/$16217+,66+((7 ),5(5(6,67$1&(5$7,1*5(48,5(0(176 7$%/(%8,/',1*(/(0(17 ),5(5(6,67$1&(5$7,1* 35,0$5<6758&785$/)5$0( +285 %($5,1*:$//6(;7(5,25,17(5,25 +285+285 121%($5,1*:$//6$1'3$57,7,216(;7(5,25,17(5,25 6((7$%/(%(/2:+2856 )/225&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +285 522)&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +285 7$%/(),5(6(3$5$7,21',67$1&( 5$7,1*)25$% 52&&83$1&< ;  ;  ; ;! +285+285+285+2856 +25,=217$/%8,/',1*6(3$5$7,21 6(&        7+($66,67('/,9,1*%8,/',1*,6&216,'(5('$66(3$5$7($1'',67,1&7)5207+(3$5.,1**$5$*()257+(385326(2)'(7(50,1,1*$5($/,0,7$7,216&217,18,7<2)),5(:$//6/,0,7$7,212)180%(52)6725,(6$1'7<3(2)&216758&7,216,1&(7+()2//2:,1*&21',7,216$5(0(7 7+(%8,/',1*6$5(6(3$5$7(':,7+$+25,=217$/$66(0%/<+$9,1*$),5(5(6,67$1&(5$7,1*2)127/(667+$1+28567+(%8,/',1*%(/2:,1&/8',1*7+(+25,=217$/$66(0%/<,62)7<3(,$&216758&7,216+$)767$,5:$<5$03$1'(6&$/$725(1&/2685(67+528*+7+(+25,=217$/$66(0%/<6+$//+$9(127/(667+$1$+285),5(5(6,67$1&(5$7,1*:,7+23(1,1*3527(&7,9(6,1$&&25'$1&(:,7+6(&7,21,17(5,25(;,767$,5:$<6/2&$7(':,7+,17+(7<3(,$%8,/',1*$5(3(50,77('72%(2)&20%867,%/(0$7(5,$/66,1&(7+()2//2:,1*5(48,5(0(176$5(0(7D 7+(%8,/',1*$%29(7+(7<3(,$%8,/',1*,62)7<3(9&216758&7,21E 7+(67$,5:$</2&$7(',17+(7<3(,$%8,/',1*,6(1&/26('%<+285),5(5(6,67$1&(5$7('&216758&7,21:,7+23(1,1*3527(&7,9(6,1$&&25'$1&(:,7+6(&7,217+(%8,/',1*6$%29(7+(+25,=217$/$66(0%/<6+$//%(3(50,77('72+$9(08/7,3/(*5283$2&&83$1&<86(6($&+:,7+$12&&83$17/2$'2)/(667+$125*5283%052562&&83$1&,(67+(%8,/',1*%(/2:7+(+25,=217$/$66(0%/<6+$//%(3527(&7('7+528*+287%<$1$33529('$8720$7,&635,1./(56<67(0,1$&&25'$1&(:,7+6(&7,21$1'6+$//%(3(50,77('72%($1<2&&83$1&<$//2:('%<7+,6&2'((;&(37*5283+7+(0$;,080%8,/',1*+(,*+7,1)((76+$//127(;&(('7+(/,0,766(7)257+,16(&7,21)257+(%8,/',1*+$9,1*7+(60$//(5$//2:$%/(+(,*+7$60($685(')5207+(*5$'(3/$1( ),5($5($6 7$%/(7$%/(127(D6(& 7+(),5(%$55,(56),5(:$//6+25,=217$/$66(0%/,(625&20%,1$7,2167+(5(2)6(3$5$7,1*$6,1*/(2&&83$1&<,172',))(5(17),5($5($66+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$17+$7,1',&$7(',17$%/(7+(),5(%$55,(56),5(:$//6+25,=217$/$66(0%/,(625&20%,1$7,2167+(5(2)6(3$5$7,1*),5($5($62)0,;('2&&83$1&,(66+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$17+(+,*+(679$/8(,1',&$7(',17$%/()257+(2&&83$1&,(681'(5&216,'(5$7,21 602.(%$55,(56 6(&602.(%$55,(566+$//%(3529,'(',1*528357268%',9,'((9(5<6725<86('%<3(562165(&(,9,1*&$5(75($70(17256/((3,1*$1'723529,'(27+(56725,(6:,7+$12&&83$17/2$'2)25025(3(56216,172127)(:(57+$17:2602.(&203$570(17668&+6725,(66+$//%(',9,'(',172602.(&203$570(176:,7+$1$5($2)127025(7+$1648$5()((7 0 $1'7+(',67$1&(2)75$9(/)520$1<32,17,1$602.(&203$570(1772$602.(%$55,(5'2256+$//127(;&((')((7 00 7+(602.(%$55,(56+$//%(,1$&&25'$1&(:,7+6(&7,21 %8,/',1*6((6+((7* 6((6+((7$$/)25$66,67('/,9,1*3$5.,1**$5$*(3/$1 '(0$1' 3(5&,7<2)7867,1&2'(2)25',1$1&(6$57,&/(3$576(&63$&(6 63$&(%('6  3529,'(' #3$5.,1**$5$*( 63$&(6#685)$&(3$5.,1*  63$&(6 $&&(66,%/(63$&(65(48,5(' 3(5&(172)727$/63$&(672%($&&(66,%/( 3(5&%&6(&% % 7$%/(% #3$5.,1**$5$*( [ $&&(66,%/(63$&(6#685)$&(3$5.,1* [ $&&(66,%/(63$&(3529,'(9$1$&&(66,%/(63$&()25(9(5<$&&(66,%/(63$&(6 3(5&%&6(&% 3529,'(' #3$5.,1**$5$*( $&&(66,%/(63$&(6 ,1&/8',1*9$163$&( #685)$&(3$5.,1* 9$1$&&(66,%/(63$&((/(&75,&9(+,&/(63$&(63(5&$/*5((16(&5(48,5(' (95($'< (95 ,13/$1 2)727$/63$&(6#3$5.,1**$5$*( [ /(9(/5(&(37$&/(6#685)$&(3$5.,1* [ /(9(/5(&(37$&/(6(9&+$5*(56 (9&6 ,13/$1 2)727$/63$&(6#3$5.,1**$5$*( [ /(9(/(9&+$5*(563529,'(9$1$&&(66,%/((9&6$1'$&&(66,%/((9&6 3(5&%&7$%/(% #685)$&(3$5.,1* [ /(9(/(9&+$5*(5 3529,'(9$1$&&(66,%/((9&6 3(5&%&7$%/(% 3529,'(' (95($'< (95 #3$5.,1**$5$*( /2:32:(5/(9(/5(&(37$&/(6#685)$&(3$5.,1* /2:32:(5/(9(/5(&(37$&/(6 (9&+$5*(56 (9&6 #3$5.,1**$5$*( /(9(/(9&+$5*(56 ,1&/8',1*9$1$&&(66,%/($1'$&&(66,%/(63$&( #685)$&(3$5.,1* /(9(/(9&+$5*(56 ,1&/8',1*9$1$&&(66,%/(63$&( 6+2577(50%,&<&/(3$5.,1*1275(48,5('3(5&$/*5((16(& /21*7(50%,&<&/(3$5.,1*3(5&$/*5((16(&5(48,5(' 7%'3529,'(' 7%' 3(57867,1/(*$&<63(&,),&3/$1 25',1$1&( 6(&'(9(/230(1767$1'$5'6)253/$11,1*$5($6  7$%/(6,7(&21),*85$7,215(*8/$7,216/27$5($ 5(6,'(17,$/  %8,/',1*6(7%$&.6$5067521*$9(18(:$51(5$9(18(/2&$/52$' ',67$1&(%(7:((1%8,/',1*$1'$&&(6625<6758&785( 7$%/(3(50,77('86(5(*8/$7,216 6(59,&(&200(5&,$/ 2)),&( 5(7$,/&200(5&,$/ 38%/,&,167,787,21$/ 3(57867,1&2'(2)25',1$1&(6&+$37(56(&/$1'6&$3(5(48,5(0(176)253$5.,1*$5($6 25'126(&  3(50$1(17/$1'6&$3,1*)25,17(5,253$5.,1*/275(48,5('2),17(5,253$5.,1*/27$5($352326('3(5,0(7(53$5.,1*/27/$1'6&$3,1*$/21*675((7)5217$*(65(48,5(' :,'($/21*0$-25$57(5,$/+,*+:$<352326('1$ 123$5.,1*/27$/21*0$-25$57(5,$/+,*+:$< 86(*(1(5$/6(59,&(%86,1(66 86(*(1(5$/2)),&(0(',&$/2)),&(+($/7+&$5(&(17(5 86(*(1(5$/5(7$,/ 86(&21*5(*$7(&$5($66,67('/,9,1*)$&,/,7<23(163$&(38%/,&35,9$7(5(&5($7,21$/)$&,/,7<38%/,&35,9$7( *5281')/2253(50,77(' *5281')/2253(50,77('3(50,77(' *5281')/2253(50,77(' *5281')/225&21',7,21$/3(50,77('&21',7,21$/ 833(5)/22563(50,77(' 833(5)/22563(50,77('3(50,77(' 833(5)/22563(50,77(' 833(5)/2256&21',7,21$/3(50,77('&21',7,21$/ 0,1,080121( 0,1,080    0,1,080  0$;,080121( 0$;,080121(121(121( 0$;,080121( $&78$/$& 6) 352326(' 0,1 0,1 0,1 352326(' 0,1 7$%/(%8,/',1*+(,*+75(*8/$7,216%8,/',1*+(,*+7 7$%/()5217$*(&$7(*25,(6*5281')/2255(6,'(17,$/ 7$%/(23(163$&(5(*8/$7,2165(6,'(17,$/ 0,1,080121( )5217$*(7<3(325&+ 7<3(&20021 0$;,080  :$51(53(50,77(' 67$1'$5'6)3(581,7 352326(' 0$; $9(522)'(&.+(,*+7 /2&$/&211(&7253(50,77(' 352326('6((7$%/(%(/2: &20021 5(48,5(0(172)352-(&76,7($5($23(163$&(7<3($66,67('/,9,1*23(163$&(6800$5<6,7($5($6)5(48,5('23(163$&(6)3529,'('6) $/&2857<$5' %8,/',1*%8,/',1*%8,/',1*+55$7('),5(:$// %8,/',1*6) %8,/',1*6) %8,/',1*6) %8,/',1* %8,/',1*%8,/',1*%8,/',1*+55$7('),5(:$// %8,/',1*6) %8,/',1*6) ‡‡‡‡‡‡‡ ),5(635,1./(568335(66,216<67(0 ),5(021,725,1*$/$506<67(0(/(9$7256<67(063+27292/7$,&6<67(0',(6(/)8(/7$1.)25*(1(5$725.,7&+(1+22'68335(66,216<67(0(0(5*(1&<5(6321'(55$',2&29(5$*(6,7(6,*1$*( &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ&OHDUZDWHUB7XVWLQB6LWHB5UYW$0$66,67('/,9,1*352-(&7'$7$$1'&2'($1$/<6,6 * &/($5:$7(5$77867,1/(*$&< $66,67('/,9,1*3$5.,1**$5$*( 7<3(&2817$&&(66,%/($&&(66,%/((9&+$5*(5 (9&+$5*(5 (95($'<67$1'$5'9$1$&&9$1$&&(9&+$5*(5 $/67$1'$5'3$5.,1*727$/ $66,67('/,9,1*685)$&(3$5.,1* 7<3(&2817%863$5.,1*(9&+$5*(5 (95($'<67$1'$5'9$1$&&9$1$&&(9&+$5*(5 $/685)$&(3$5.,1*727$/ *29(51,1*&2'(6$1'67$1'$5'6 $66,67('/,9,1*352-(&7'$7$ $66,67('/,9,1* $/ /(9(/2)&$5( $66,67('/,9,1* $/ $1'0(025<&$5( 0& 122)$/81,76 81,76122)0&81,76 81,762&&83$1&<*52836 5$%122)6725,(6 6725,(66725<R$6725<3$5.,1**$5$*(&216758&7,217<3( 7<3(9$:22')5$0(&216758&7,217<3(9$:22')5$0(&216758&7,21R7<3(,$&21&5(7(&216758&7,213$5.,1**$5$*(*5266)/225$5($ 6) &2002123(163$&(6(($66,67('/,9,1*23(163$&(6800$5<81'(5 /2&$/=21,1*&2'(&203/,$1&( 217+,66+((7 $66,67('/,9,1*3$5.,1*$1$/<6,6 /2&$/=21,1*&2'(&203/,$1&( $66,67('/,9,1*%8,/',1*&2'($1$/<6,6 2$6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)   )/5 02675(675,&7,9(2&&*5283 $//2:$%/($5($ $W 7$%/( )5217$*(,1&5($6( 727$/$//2:$%/($5($3(5)/225 $&78$/$5($ %8,/',1* 5$7,2 $66,67('/,9,1*%8,/',1* 7<3(9$&216758&7,21 2$6)    5 6) 6) 6) 6)  !  5 6) 6) 6) 6)   )/5 02675(675,&7,9(2&&*5283 $//2:$%/($5($ $W 7$%/( )5217$*(,1&5($6( 727$/$//2:$%/($5($3(5)/225 $&78$/$5($ %8,/',1* 5$7,2 $66,67('/,9,1*%8,/',1* 7<3(9$&216758&7,21 $66,67('/,9,1*),5($5($3/$16 '()(55('68%0,77$/6 6&$/(  ),567)/225),5($5($3/$1 6&$/(  6(&21')/225),5($5($3/$1 ,668(' '$7('(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 290 □ I □ □ □ T E I p I D SDLUTIDNS,INC i----------t-C-_______J___J i----------t-1 I _______J___JI I ~~3 ~~ r-~ -~ _____j~_J~ I I I I I II =-.c CLEARWATER LIVNG •conflµent •• senior living 0 Clearwater Living Tustin Project Localized Construction Emissions Analysis 4 6XPPDU\RI$LU4XDOLW\ ,PSDFWV The proposed Project’s localized construction emissions would not exceed the South Coast Air Quality Management District’s (SCAQMD) localized significance thresholds (LSTs). In addition, all construction activities would comply with applicable SCAQMD rules and regulations, such as Rule 402, Rule 403, and Rule 1113: x Rule 402, Public Nuisance: Prohibits the discharge of air contaminants that cause injury, nuisance, or annoyance to the public or damage to property. x Rule 403, Fugitive Dust: Aims to minimize fugitive particulate matter dust emissions during construction activities. x Rule 1113, Architectural Coatings: Allows only low-volatile organic compounds (VOC) paints to be used. Therefore, the proposed Project would have less-than-significant air quality impacts regarding localized construction emissions. 3URMHFW$QDO\VLV Methodology and Model Inputs To calculate the construction impacts, air quality emissions were estimated using CalEEMod. The passenger vehicles were analyzed using the CalEEMod default trip distance information. The following non-default assumptions and adjustments were used in the CalEEMod emissions model for this analysis: x /DQG8VHThe lot acreage and building area were adjusted to match the site plan provided by the Project Applicant. x &RQVWUXFWLRQ² 3KDVHVThe construction schedule was confirmed by the Project Applicant. x &RQVWUXFWLRQ² 2IIURDG(TXLSPHQWIt was conservatively assumed that all equipment would be used for 8 hours per workday. Tractors/loaders/backhoes were replaced with crawler tractors in the site preparation and grading phases to accurately calculate disturbance. x &RQVWUXFWLRQ² 'XVWIURP0DWHULDO0RYHPHQWBased on information provided by the Project Applicant, grading work is anticipated to result in approximately 6,100 cubic yards (CY) of cut and 3,450 CY of fill. Localized Significance Thresholds Localized significance thresholds (LSTs) were adopted by the SCAQMD due to project-related construction air emissions having the potential to exceed the State and national air quality standards in the project vicinity, while not exceeding the regional emission significance thresholds adopted by the SCAQMD. These thresholds set the maximum rates of daily construction emissions from a project site that would not exceed a national or State ambient air quality standard.5F5F 1 The differences between regional thresholds and LSTs are as follows: 1. Regional thresholds include all sources of project construction emissions generated from on-site and off- site emission sources, whereas the LSTs only consider the emissions generated from on-site emission sources. 2. LSTs only apply to carbon monoxide (CO), nitrogen oxides (NOx), and particulate matter (PM10 and PM2.5), while regional thresholds include both reactive organic gases (ROG) and sulfur dioxide (SO2). 1 SCAQMD. (2008).Final Localized Significance Threshold Methodology. Referenced at http://www.aqmd.gov/docs/defaultsource/ceqa/handbook/localized-significance-thresholds/final-lst-methodology- document.pdf. 291E I p I D SDLUTIDNS,INC Clearwater Living Tustin Project Localized Construction Emissions Analysis 5 3. Regional thresholds apply to emission sources located anywhere within the SCAQMD whereas the LSTs are location dependent and rely on the size of the project and emission location relative to the nearest sensitive receptor. The SCAQMD provides screening tables (Appendix C of the SCAQMD 2008 Final Localized Significance Threshold Methodology) for projects that disturb less than or equal to 5 acres in a day.6F6F 2 These tables were created to easily determine if the daily emissions of NOx, CO, PM10, and PM2.5 from a project could result in a significant impact to the local air quality. The thresholds are determined by: x Source Receptor Area (SRA), which is the geographic area within the SCAQMD that can act as both a source of emissions and a receptor of emission impacts (the Project is located within SRA 16, North Orange County); x Size of grading disturbance (construction)/size of the project (operation); and x Distance to the nearest sensitive receptor, which is defined as an individual who is most susceptible to negative health effects when exposed to air pollutants and includes children, the elderly, and adults with chronic health issues. Locations for such receptors include residences, schools, elderly care centers, and hospitals. Project Localized Construction Emissions As shown in Attachment B, Detailed Calculation Sheets,all construction phases are assumed to disturb an equal area of 0.5 acres per day. Given that the total construction area is 4 acres, the maximum ground disturbance per day would be 4 acres, while the total Project site encompasses approximately 6.14 acres. Pursuant to SCAQMD guidance, which recommends selecting thresholds based on the smaller of the total site area or the daily disturbed area, construction emissions were evaluated by interpolating between the 2-acre and 5- acre disturbance thresholds. The construction thresholds per acreage were interpolated using the thresholds for 2 acres and 5 acres. Distance to the nearest sensitive receptor also determines the emission thresholds. The sensitive receptors closest to the Project site include residential homes about 22 meters (72 feet) south of the Project site; therefore, the construction emission thresholds for 25 meters were used, as that is the maximum distance identified in the LST lookup tables. This also provides a conservative estimate. Table 2,Localized Construction Emissions Estimates, shows the thresholds and estimated maximum daily construction emissions for the proposed Project. As shown in Table 2, the proposed Project would not exceed the SCAQMD LST thresholds and would therefore have a less-than-significant localized construction air quality impact. 2 SCAQMD. (2008).Final Localized Significance Threshold Methodology Appendix C. Referenced at http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/appendix-c-mass-rate-lst- look-up-tables.pdf?sfvrsn=2. 292E I p I D SDLUTIDNS,INC Clearwater Living Tustin Project Localized Construction Emissions Analysis 6 7DEOH /RFDOL]HG&RQVWUXFWLRQ(PLVVLRQV (VWLPDWHV &RQVWUXFWLRQ$FWLYLW\ 0D[LPXP'DLO\/RFDOL]HG(PLVVLRQV SRXQGVGD\ 12[&2 3030  <HDU Site Preparation 36.27 33.13 7.52 4.40 Grading 19.06 19.09 3.29 1.89 Building Construction 10.67 14.07 0.41 0.38 Maximum On-Site Emission (2026)36.27 33.13 7.52 4.40  <HDU Building Construction 10.17 14.04 0.36 0.34 Maximum On-Site Emission (2027)10.17 14.04 0.36 0.34  <HDU Building Construction 9.66 14.04 0.33 0.30 Paving 6.63 9.91 0.26 0.24 Architectural Coating 1.08 1.49 0.02 0.02 Maximum On-Site Emission (2028)9.66 14.04 0.33 0.30 0D[LPXP'DLO\(PLVVLRQV      SCAQMD Screening Thresholds 196.30 1128.00 9.30 5.30 7KUHVKROG([FHHGHG"1R 1R 1R 1R Notes: NOx = nitrogen oxides, CO = carbon monoxide, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter Source: CalEEMod Output Sheets (see Attachment A). &RQFOXVLRQ The proposed Project's maximum localized construction emissions would not exceed SCAQMD’s thresholds of significance, as detailed in Table 2. Additionally, all construction activities would comply with applicable SCAQMD rules and regulations, such as SCAQMD Rule 402 (Public Nuisance), 403 (Fugitive Dust), and 1113 (Architectural Coatings). Therefore, the proposed Project would result in less-than-significant air quality impacts without requiring mitigation in regard to localized construction emissions. 293E I p I D SDLUTIDNS,INC Clearwater Living Tustin Project Localized Construction Emissions Analysis Attachment A: CalEEMod Output Sheets 294E I p I D SDLUTIDNS,INC 25-104 Clearwater Living Detailed Report, 10/20/2025 1 / 28 25-104 Clearwater Living Detailed 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. Site Preparation (2026) - Unmitigated 3.3. Grading (2026) - Unmitigated 3.5. Building Construction (2026) - Unmitigated 3.7. Building Construction (2027) - Unmitigated 3.9. Building Construction (2028) - Unmitigated 3.11. Paving (2028) - Unmitigated 3.13. Architectural Coating (2028) - Unmitigated 295 25-104 Clearwater Living Detailed Report, 10/20/2025 2 / 28 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 5.6. Dust Mitigation 5.6.1. Construction Earthmoving Activities 5.6.2. Construction Earthmoving Control Strategies 5.7. Construction Paving 296 25-104 Clearwater Living Detailed Report, 10/20/2025 3 / 28 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 6. Climate Risk Detailed Report 6.1. Climate Risk Summary 6.2. Initial Climate Risk Scores 6.3. Adjusted Climate Risk Scores 6.4. Climate Risk Reduction Measures 7. Health and Equity Details 7.1. CalEnviroScreen 4.0 Scores 7.2. Healthy Places Index Scores 7.3. Overall Health & Equity Scores 7.4. Health & Equity Measures 297 25-104 Clearwater Living Detailed Report, 10/20/2025 4 / 28 7.5. Evaluation Scorecard 7.6. Health & Equity Custom Measures 8. User Changes to Default Data 298 25-104 Clearwater Living Detailed Report, 10/20/2025 5 / 28 1. Basic Project Information 1.1. Basic Project Information Data Field Value Project Name 25-104 Clearwater Living Construction Start Date 7/1/2026 Lead Agency City of Tustin Land Use Scale Project/site Analysis Level for Defaults County Windspeed (m/s)2.50 Precipitation (days)19.6 Location 33.7066273, -117.8325863 County Orange City Tustin Air District South Coast AQMD Air Basin South Coast TAZ 6824 EDFZ 7 Electric Utility Southern California Edison Gas Utility Southern California Gas App Version 2022.1.1.30 1.2. Land Use Types Land Use Subtype Size Unit Lot Acreage Building Area (sq ft)Landscape Area (sq ft) Special Landscape Area (sq ft) Population Description Apartments Mid Rise 172 Dwelling Unit 0.00 293,048 16,620 — 513 Active Adult units 299 25-104 Clearwater Living Detailed Report, 10/20/2025 6 / 28 307—34,465142,0470.00Dwelling Unit103Congregate Care (Assisted Living) Assisted Living/Memory Care units Recreational Swimming Pool 16.0 1000sqft 0.37 16,004 0.00 — — Courtyard and Swimming pool Enclosed Parking Structure 188 Space 1.73 75,200 0.00 — — Enclosed Parking Structure-Active adult Enclosed Parking Structure 56.0 Space 0.51 22,400 0.00 — — Enclosed Parking Structure-Senior Living Other Non-Asphalt Surfaces 3.22 Acre 3.22 0.00 0.00 — — Other non-Asphalt Surfaces Parking Lot 34.0 Space 0.31 0.00 0.00 ——Surface Parking 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) Un/Mit.ROG NOx CO SO2 PM10T PM2.5T CO2e Daily, Summer (Max) ——————— Unmit.80.7 36.3 34.2 0.05 7.78 4.46 7,460 Daily, Winter (Max) ——————— Unmit.2.01 13.1 26.0 0.04 4.04 1.25 7,292 Average Daily (Max) ——————— Unmit.8.23 8.98 18.3 0.03 2.82 0.86 5,182 Annual (Max) ——————— Unmit.1.50 1.64 3.35 < 0.005 0.52 0.16 858 Exceeds (Daily Max) ——————— 300 25-104 Clearwater Living Detailed Report, 10/20/2025 7 / 28 Threshold 75.0 100 550 150 150 55.0 — Unmit.Yes No No No No No — Exceeds (Average Daily) ——————— Threshold 75.0 100 550 150 150 55.0 — Unmit.NoNoNoNoNoNo— 2.2. Construction Emissions by Year, Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10T PM2.5T CO2e Daily - Summer (Max) ——————— 2026 4.07 36.3 34.2 0.05 7.78 4.46 7,460 2027 1.84 12.4 26.9 0.04 4.00 1.21 7,374 2028 80.7 11.7 26.2 0.04 3.96 1.18 7,252 Daily - Winter (Max) ——————— 2026 2.01 13.1 26.0 0.04 4.04 1.25 7,292 2027 1.84 12.5 25.2 0.04 4.00 1.21 7,210 2028 1.78 11.9 24.6 0.04 3.96 1.18 7,122 Average Daily ——————— 2026 0.85 6.41 9.61 0.01 1.64 0.67 2,422 2027 1.31 8.98 18.3 0.03 2.82 0.86 5,182 2028 8.23 3.34 6.95 0.01 1.03 0.31 1,893 Annual——————— 2026 0.15 1.17 1.75 < 0.005 0.30 0.12 401 2027 0.24 1.64 3.35 < 0.005 0.52 0.16 858 2028 1.50 0.61 1.27 < 0.005 0.19 0.06 313 3. Construction Emissions Details 301 25-104 Clearwater Living Detailed Report, 10/20/2025 8 / 28 3.1. Site Preparation (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e Onsite——————— Daily, Summer (Max) ——————— Off-Road Equipment 4.00 36.3 33.1 0.05 1.86 1.71 5,872 Dust From Material Movement — — — — 5.66 2.69 — Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Average Daily ——————— Off-Road Equipment 0.22 1.99 1.82 < 0.005 0.10 0.09 322 Dust From Material Movement — — — — 0.31 0.15 — Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Off-Road Equipment 0.04 0.36 0.33 < 0.005 0.02 0.02 53.3 Dust From Material Movement — — — — 0.06 0.03 — Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite ——————— Daily, Summer (Max) ——————— Worker 0.07 0.06 1.05 0.00 0.26 0.06 264 Vendor 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 Daily, Winter (Max) ——————— Average Daily ——————— Worker < 0.005 < 0.005 0.05 0.00 0.01 < 0.005 13.9 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 302 25-104 Clearwater Living Detailed Report, 10/20/2025 9 / 28 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Worker < 0.005 < 0.005 0.01 0.00 < 0.005 < 0.005 2.31 Vendor 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 3.3. Grading (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e Onsite——————— Daily, Summer (Max) ——————— Off-Road Equipment 2.16 19.1 19.1 0.03 1.04 0.96 3,146 Dust From Material Movement — — — — 2.26 0.94 — Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Average Daily ——————— Off-Road Equipment 0.12 1.04 1.05 < 0.005 0.06 0.05 172 Dust From Material Movement — — — — 0.12 0.05 — Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Off-Road Equipment 0.02 0.19 0.19 < 0.005 0.01 0.01 28.5 Dust From Material Movement — — — — 0.02 0.01 — Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite ——————— Daily, Summer (Max) ——————— Worker 0.05 0.05 0.79 0.00 0.20 0.05 198 303 25-104 Clearwater Living Detailed Report, 10/20/2025 10 / 28 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.02 1.36 0.60 0.01 0.32 0.10 1,196 Daily, Winter (Max) ——————— Average Daily ——————— Worker < 0.005 < 0.005 0.04 0.00 0.01 < 0.005 10.5 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 0.08 0.03 < 0.005 0.02 0.01 65.5 Annual——————— Worker < 0.005 < 0.005 0.01 0.00 < 0.005 < 0.005 1.73 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 10.8 3.5. Building Construction (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e Onsite——————— Daily, Summer (Max) ——————— Off-Road Equipment 1.16 10.7 14.1 0.03 0.41 0.38 2,639 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Off-Road Equipment 1.16 10.7 14.1 0.03 0.41 0.38 2,639 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily ——————— Off-Road Equipment 0.29 2.67 3.52 0.01 0.10 0.09 661 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Off-Road Equipment 0.05 0.49 0.64 < 0.005 0.02 0.02 109 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 304 25-104 Clearwater Living Detailed Report, 10/20/2025 11 / 28 Offsite — — — — — — — Daily, Summer (Max) ——————— Worker 0.83 0.75 12.9 0.00 3.21 0.75 3,246 Vendor 0.03 1.53 0.77 0.01 0.42 0.12 1,575 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Worker 0.83 0.86 11.2 0.00 3.21 0.75 3,081 Vendor 0.03 1.60 0.78 0.01 0.42 0.12 1,572 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily ——————— Worker 0.21 0.22 2.91 0.00 0.79 0.19 783 Vendor 0.01 0.40 0.19 < 0.005 0.10 0.03 394 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Worker 0.04 0.04 0.53 0.00 0.14 0.03 130 Vendor < 0.005 0.07 0.04 < 0.005 0.02 0.01 65.2 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.7. Building Construction (2027) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e Onsite——————— Daily, Summer (Max) ——————— Off-Road Equipment 1.11 10.2 14.0 0.03 0.36 0.34 2,639 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Off-Road Equipment 1.11 10.2 14.0 0.03 0.36 0.34 2,639 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 305 25-104 Clearwater Living Detailed Report, 10/20/2025 12 / 28 Average Daily — — — — — — — Off-Road Equipment 0.79 7.27 10.0 0.02 0.26 0.24 1,885 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Off-Road Equipment 0.14 1.33 1.83 < 0.005 0.05 0.04 312 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite ——————— Daily, Summer (Max) ——————— Worker 0.70 0.74 12.2 0.00 3.21 0.75 3,191 Vendor 0.03 1.47 0.73 0.01 0.42 0.12 1,544 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Worker 0.70 0.75 10.4 0.00 3.21 0.75 3,030 Vendor 0.03 1.54 0.75 0.01 0.42 0.12 1,541 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily ——————— Worker 0.50 0.61 7.78 0.00 2.27 0.53 2,196 Vendor 0.02 1.10 0.53 0.01 0.30 0.09 1,101 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Worker 0.09 0.11 1.42 0.00 0.41 0.10 364 Vendor < 0.005 0.20 0.10 < 0.005 0.05 0.02 182 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.9. Building Construction (2028) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e Onsite——————— 306 25-104 Clearwater Living Detailed Report, 10/20/2025 13 / 28 Daily, Summer (Max) — — — — — — — Off-Road Equipment 1.07 9.66 14.0 0.03 0.33 0.30 2,639 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Off-Road Equipment 1.07 9.66 14.0 0.03 0.33 0.30 2,639 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily ——————— Off-Road Equipment 0.26 2.33 3.38 0.01 0.08 0.07 635 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Off-Road Equipment 0.05 0.42 0.62 < 0.005 0.01 0.01 105 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite ——————— Daily, Summer (Max) ——————— Worker 0.68 0.63 11.5 0.00 3.21 0.75 3,104 Vendor 0.03 1.41 0.71 0.01 0.42 0.12 1,509 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Worker 0.67 0.74 9.85 0.00 3.21 0.75 2,976 Vendor 0.03 1.48 0.72 0.01 0.42 0.12 1,507 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily ——————— Worker 0.16 0.18 2.48 0.00 0.76 0.18 727 Vendor 0.01 0.36 0.17 < 0.005 0.10 0.03 363 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Worker 0.03 0.03 0.45 0.00 0.14 0.03 120 Vendor < 0.005 0.06 0.03 < 0.005 0.02 0.01 60.1 307 25-104 Clearwater Living Detailed Report, 10/20/2025 14 / 28 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.11. Paving (2028) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e Onsite——————— Daily, Summer (Max) ——————— Off-Road Equipment 0.69 6.63 9.91 0.01 0.26 0.24 1,516 Paving 0.33 —————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Average Daily ——————— Off-Road Equipment 0.04 0.36 0.54 < 0.005 0.01 0.01 83.1 Paving 0.02 —————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Off-Road Equipment 0.01 0.07 0.10 < 0.005 < 0.005 < 0.005 13.8 Paving < 0.005 —————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite ——————— Daily, Summer (Max) ——————— Worker 0.04 0.04 0.70 0.00 0.20 0.05 189 Vendor 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 Daily, Winter (Max) ——————— Average Daily ——————— Worker < 0.005 < 0.005 0.03 0.00 0.01 < 0.005 10.1 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 308 25-104 Clearwater Living Detailed Report, 10/20/2025 15 / 28 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Worker < 0.005 < 0.005 0.01 0.00 < 0.005 < 0.005 1.67 Vendor 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 3.13. Architectural Coating (2028) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e Onsite——————— Daily, Summer (Max) ——————— Off-Road Equipment 0.14 1.08 1.49 < 0.005 0.02 0.02 179 Architectural Coatings 80.5 —————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) ——————— Average Daily ——————— Off-Road Equipment 0.01 0.10 0.14 < 0.005 < 0.005 < 0.005 17.1 Architectural Coatings 7.71 —————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————— Off-Road Equipment < 0.005 0.02 0.03 < 0.005 < 0.005 < 0.005 2.84 Architectural Coatings 1.41 —————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite ——————— Daily, Summer (Max) ——————— Worker 0.14 0.13 2.29 0.00 0.64 0.15 621 Vendor 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 0.00 309 25-104 Clearwater Living Detailed Report, 10/20/2025 16 / 28 Daily, Winter (Max) — — — — — — — Average Daily ——————— Worker 0.01 0.01 0.20 0.00 0.06 0.01 57.9 Vendor 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 Annual——————— Worker < 0.005 < 0.005 0.04 0.00 0.01 < 0.005 9.59 Vendor 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 4. Operations Emissions Details 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) Vegetation ROG NOx CO SO2 PM10T PM2.5T CO2e 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) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e Daily, Summer (Max) ——————— 310 25-104 Clearwater Living Detailed Report, 10/20/2025 17 / 28 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) Species ROG NOx CO SO2 PM10T PM2.5T CO2e Daily, Summer (Max) ——————— Avoided——————— Subtotal ——————— Sequestered——————— Subtotal ——————— Removed——————— Subtotal ——————— ———————— Daily, Winter (Max) ——————— Avoided——————— Subtotal ——————— Sequestered——————— Subtotal ——————— Removed——————— Subtotal ——————— ———————— Annual——————— Avoided——————— Subtotal ——————— 311 25-104 Clearwater Living Detailed Report, 10/20/2025 18 / 28 Sequestered——————— Subtotal ——————— Removed——————— Subtotal ——————— ———————— 5. Activity Data 5.1. Construction Schedule Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Site Preparation Site Preparation 7/1/2026 7/28/2026 5.00 20.0 — Grading Grading 7/29/2026 8/25/2026 5.00 20.0 — Building Construction Building Construction 8/26/2026 5/2/2028 5.00 440 — Paving Paving 5/3/2028 5/30/2028 5.00 20.0 — Architectural Coating Architectural Coating 5/31/2028 7/18/2028 5.00 35.0 — 5.2. Off-Road Equipment 5.2.1. Unmitigated Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Back hoes Diesel Average 0.00 8.00 84.0 0.37 Site Preparation Crawler Tractors Diesel Average 4.00 8.00 87.0 0.43 Site Preparation Other Construction Equipment Diesel Average 1.00 8.00 82.0 0.42 Grading Graders Diesel Average 1.00 8.00 148 0.41 Grading Excavators Diesel Average 1.00 8.00 36.0 0.38 312 25-104 Clearwater Living Detailed Report, 10/20/2025 19 / 28 Grading Tractors/Loaders/Back Diesel Average 0.00 8.00 84.0 0.37 Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Crawler Tractors Diesel Average 3.00 8.00 87.0 0.43 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Cranes Diesel Average 1.00 8.00 367 0.29 Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Building Construction Tractors/Loaders/Back hoes Diesel Average 3.00 8.00 84.0 0.37 Paving Pavers Diesel Average 2.00 8.00 81.0 0.42 Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38 Architectural Coating Air Compressors Diesel Average 1.00 8.00 37.0 0.48 5.3. Construction Vehicles 5.3.1. Unmitigated Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation ———— Site Preparation Worker 20.0 18.5 LDA,LDT1,LDT2 Site Preparation Vendor —10.2 HHDT,MHDT Site Preparation Hauling 0.00 20.0 HHDT Site Preparation Onsite truck ——HHDT Grading ———— Grading Worker 15.0 18.5 LDA,LDT1,LDT2 Grading Vendor —10.2 HHDT,MHDT Grading Hauling 16.6 20.0 HHDT Grading Onsite truck ——HHDT Building Construction ———— 313 25-104 Clearwater Living Detailed Report, 10/20/2025 20 / 28 Building Construction Worker 246 18.5 LDA,LDT1,LDT2 Building Construction Vendor 48.0 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 49.1 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 Non-applicable. No control strategies activated by user. 5.5. Architectural Coatings Phase Name Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq ft) Non-Residential Exterior Area Coated (sq ft) Parking Area Coated (sq ft) Architectural Coating 881,067 293,689 4,391 488 15,080 5.6. Dust Mitigation 5.6.1. Construction Earthmoving Activities Phase Name Material Imported (cy)Material Exported (cy)Acres Graded (acres)Material Demolished (sq. ft.)Acres Paved (acres) 314 25-104 Clearwater Living Detailed Report, 10/20/2025 21 / 28 Site Preparation — — 70.0 0.00 — Grading —2,650 50.0 0.00 — Paving 0.00 0.00 0.00 0.00 5.77 5.6.2. Construction Earthmoving Control Strategies Control Strategies Applied Frequency (per day)PM10 Reduction PM2.5 Reduction Water Exposed Area 3 74%74% 5.7. Construction Paving Land Use Area Paved (acres)% Asphalt Apartments Mid Rise —0% Congregate Care (Assisted Living)—0% Recreational Swimming Pool 0.00 0% Enclosed Parking Structure 1.73 100% Enclosed Parking Structure 0.51 100% Other Non-Asphalt Surfaces 3.22 0% Parking Lot 0.31 100% 5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh) Year kWh per Year CO2 CH4 N2O 2027 0.00 346 0.03 < 0.005 2026 0.00 346 0.03 < 0.005 2028 0.00 346 0.03 < 0.005 5.18. Vegetation 315 25-104 Clearwater Living Detailed Report, 10/20/2025 22 / 28 5.18.1. Land Use Change 5.18.1.1. Unmitigated Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres 5.18.1. Biomass Cover Type 5.18.1.1. Unmitigated Biomass Cover Type Initial Acres Final Acres 5.18.2. Sequestration 5.18.2.1. Unmitigated Tree Type Number Electricity Saved (kWh/year)Natural Gas Saved (btu/year) 6. Climate Risk Detailed Report 6.1. Climate Risk Summary Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100. Climate Hazard Result for Project Location Unit Temperature and Extreme Heat 9.03 annual days of extreme heat Extreme Precipitation 3.50 annual days with precipitation above 20 mm Sea Level Rise —meters of inundation depth Wildfire 1.31 annual hectares burned Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. 316 25-104 Clearwater Living Detailed Report, 10/20/2025 23 / 28 Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. 6.2. Initial Climate Risk Scores Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A Extreme Precipitation N/A N/A N/A N/A Sea Level Rise 1 0 0 N/A Wildfire 1 0 0 N/A Flooding N/A N/A N/A N/A Drought N/A N/A N/A N/A Snowpack Reduction N/A N/A N/A N/A Air Quality Degradation 0 0 0 N/A The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure. The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is ratedonascaleof1to5,withascoreof5 representing the greatest ability to adapt. The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures. 6.3. Adjusted Climate Risk Scores Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2 Extreme Precipitation N/A N/A N/A N/A Sea Level Rise 1 1 1 2 Wildfire 1 1 1 2 Flooding N/A N/A N/A N/A Drought N/A N/A N/A N/A 317 25-104 Clearwater Living Detailed Report, 10/20/2025 24 / 28 Snowpack Reduction N/A N/A N/A N/A Air Quality Degradation 1 1 1 2 The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure. The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is ratedonascaleof1to5,withascoreof5 representing the greatest ability to adapt. The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures. 6.4. Climate Risk Reduction Measures 7. Health and Equity Details 7.1. CalEnviroScreen 4.0 Scores The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. Indicator Result for Project Census Tract Exposure Indicators — AQ-Ozone 58.2 AQ-PM 68.7 AQ-DPM 84.2 Drinking Water 53.2 Lead Risk Housing 28.7 Pesticides 11.8 Toxic Releases 91.4 Traffic 88.9 Effect Indicators — CleanUp Sites 97.3 Groundwater 99.0 Haz Waste Facilities/Generators 98.4 Impaired Water Bodies 83.0 Solid Waste 97.7 318 25-104 Clearwater Living Detailed Report, 10/20/2025 25 / 28 Sensitive Population — Asthma 17.0 Cardio-vascular 20.8 Low Birth Weights 54.8 Socioeconomic Factor Indicators — Education 49.2 Housing 39.2 Linguistic 59.4 Poverty 55.5 Unemployment 5.57 7.2. Healthy Places Index Scores The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state. Indicator Result for Project Census Tract Economic — Above Poverty 47.45284229 Employed 76.27357885 Median HI 69.01065058 Education — Bachelor's or higher 70.42217375 High school enrollment 100 Preschool enrollment 16.21968433 Transportation — Auto Access 57.21801617 Active commuting 69.0619787 Social — 2-parent households 42.17887848 Voting 31.99024766 319 25-104 Clearwater Living Detailed Report, 10/20/2025 26 / 28 Neighborhood — Alcohol availability 44.80944437 Park access 28.53843193 Retail density 94.63621199 Supermarket access 58.28307455 Tree canopy 29.41100988 Housing — Homeownership 19.54317978 Housing habitability 30.20659566 Low-inc homeowner severe housing cost burden 97.88271526 Low-inc renter severe housing cost burden 75.33684075 Uncrowded housing 22.40472219 Health Outcomes — Insured adults 50.3143847 Arthritis 98.6 Asthma ER Admissions 82.6 High Blood Pressure 98.8 Cancer (excluding skin)96.0 Asthma 65.7 Coronary Heart Disease 98.7 Chronic Obstructive Pulmonary Disease 94.6 Diagnosed Diabetes 98.6 Life Expectancy at Birth 99.4 Cognitively Disabled 52.2 Physically Disabled 81.6 Heart Attack ER Admissions 76.4 Mental Health Not Good 58.7 Chronic Kidney Disease 99.0 320 25-104 Clearwater Living Detailed Report, 10/20/2025 27 / 28 Obesity 94.5 Pedestrian Injuries 72.5 Physical Health Not Good 93.2 Stroke 98.4 Health Risk Behaviors — Binge Drinking 4.3 Current Smoker 42.3 No Leisure Time for Physical Activity 69.0 Climate Change Exposures — Wildfire Risk 0.0 SLR Inundation Area 0.0 Children 25.4 Elderly 82.5 English Speaking 49.5 Foreign-born 80.9 Outdoor Workers 61.4 Climate Change Adaptive Capacity — Impervious Surface Cover 18.1 Traffic Density 92.8 Traffic Access 65.3 Other Indices — Hardship 52.6 Other Decision Support — 2016 Voting 59.2 7.3. Overall Health & Equity Scores Metric Result for Project Census Tract CalEnviroScreen 4.0 Score for Project Location (a)64.0 321 25-104 Clearwater Living Detailed Report, 10/20/2025 28 / 28 Healthy Places Index Score for Project Location (b) 56.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535)No Project Located in a Low-Income Community (Assembly Bill 1550)No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state. 7.4. Health & Equity Measures No Health & Equity Measures selected. 7.5. Evaluation Scorecard Health & Equity Evaluation Scorecard not completed. 7.6. Health & Equity Custom Measures No Health & Equity Custom Measures created. 8. User Changes to Default Data Screen Justification Land Use Values adjusted per site plan. Construction: Construction Phases Removed demolition phase as the site is vacant. Construction: Off-Road Equipment Conservatively assumed all equipment would run 8 hours a day. Replaced tractors/loaders/backhoes with crawler tractor to accurately assess site disturbance. Included 1 diesel crushing equipment to account for crushing during demolition phase. Included 1 "other construction equipment" to account for a woodchipper during the site preparation phase. Construction: Off-Road Equipment EF Input emissions factors for diesel crushing equipment using EMFAC OFFROAD2021 values for Orange County subarea, 2026. Operations: Vehicle Data Adjusted weekday, Saturday, and Sunday trip rates to ITE 11th edition rates (Land use codes 210 and 220). Operations: Emergency Generators and Fire Pumps Included proposed generator and fire pump information from Project Applicant. Operations: Hearths No proposed fireplaces. 322 Clearwater Living Tustin Project Localized Construction Emissions Analysis Attachment B: Detailed Calculation Sheets 323E I p I D SDLUTIDNS,INC 52* 12[&2 62[3030 6LWH3UHSDUDWLRQ       Off-Road 4.00 36.27 33.13 0.05 1.86 1.71 Dust From Material Movement 5.66 2.69 Off-Site (Worker Trip) 0.07 0.06 1.05 0.00 0.26 0.06 *UDGLQJ       Off-Road 2.16 19.06 19.09 0.03 1.04 0.96 Dust From Material Movement 2.26 0.94 Off-Site (Worker Trip) 0.05 0.05 0.79 0.00 0.20 0.05 Off-Site (Hauling Trip) 0.02 1.36 0.60 0.01 0.32 0.10 %XLOGLQJ&RQVWUXFWLRQ       Off-Road 1.16 10.67 14.07 0.03 0.41 0.38 Onsite Truck 0.00 0.00 0.00 0.00 0.00 0.00 Off-Site (Worker Trip) 0.83 0.86 12.95 0.00 3.21 0.75 Off-Site (Vendor Trip) 0.03 1.60 0.77 0.01 0.42 0.12 Maximum Daily Emissions (2026) 4.07 36.34 34.19 0.05 7.78 4.46 %XLOGLQJ&RQVWUXFWLRQ       Off-Road 1.11 10.17 14.04 0.03 0.36 0.34 Onsite Truck 0.00 0.00 0.00 0.00 0.00 0.00 Off-Site (Worker Trip) 0.70 0.74 12.15 0.00 3.21 0.75 Off-Site (Vendor Trip) 0.03 1.47 0.73 0.01 0.42 0.12 Maximum Daily Emissions (2027) 1.84 12.38 26.92 0.04 4.00 1.21 %XLOGLQJ&RQVWUXFWLRQ       Off-Road 1.07 9.66 14.04 0.03 0.33 0.30 Onsite Truck 0.00 0.00 0.00 0.00 0.00 0.00 Off-Site (Worker Trip) 0.68 0.63 11.46 0.00 3.21 0.75 Off-Site (Vendor Trip) 0.03 1.41 0.71 0.01 0.42 0.12 3DYLQJ       Off-Road 0.69 6.63 9.91 0.01 0.26 0.24 Paving 0.33 Off-Site (Worker Trip) 0.04 0.04 0.70 0.00 0.20 0.05 $UFKLWHFWXUDO&RDWLQJ       Off-Road 0.14 1.08 1.49 0.00 0.02 0.02 Architectural Coating 80.60 0.00 0.00 0.00 0.00 0.00 Off-Site (Worker Trip) 0.14 0.13 2.29 0.00 0.64 0.15 Maximum Daily Emissions (2027) 80.88 11.71 26.21 0.04 3.96 1.18 0D[LPXP'DLO\(PLVVLRQV        SCAQMD Thresholds 75 100 550 150 150 55 7KUHVKROG([FHHGHG"<HV 1R 1R 1R 1R 1R Notes: ROG = reactive organic gases, NOx = nitrogen oxides, CO = carbon monoxide, SOx = sulfur oxides, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter Source: CalEEMod Output Sheets.  <HDU Construction Emissions &RQVWUXFWLRQ$FWLYLW\ 0D[LPXP'DLO\5HJLRQDO(PLVVLRQV SRXQGVGD\  <HDU  <HDU 324 I I I Rubber Tired Dozers 3 8 0.5 1.5 Other Construction Equipment 1 8 0.5 0.5 Crawler Tractors 4 8 0.5 2  Graders 1 8 0.5 0.5 Rubber Tired Dozers 1 8 0.5 0.5 Excavators 1 8 0.5 0.5 Crawler Tractors 3 8 0.5 1.5 3 0D[LPXP$FUHV'LVWXUEHG3HU'D\ Source: CalEEMod Output Sheets. Site Preparation 7RWDO$FUHV'LVWXUEHG3HU'D\ Grading 7RWDO$FUHV'LVWXUEHG3HU'D\ Construction Equipment Modeled in CalEEMod and Acres Disturbed Per Day $FWLYLW\(TXLSPHQW7\SH (TXLSPHQW 4XDQWLW\ 2SHUDWLQJ +RXUVSHU 'D\ $FUHV'LVWXUEHGSHU3LHFH RI(TXLSPHQWSHU'D\ $FUHV'LVWXUEHG SHU'D\ 325 12[&2 3030 Site Preparation 36.27 33.13 7.52 4.40 Grading 19.06 19.09 3.29 1.89 Building Construction 10.67 14.07 0.41 0.38 Maximum On-site Emission (2026) 36.27 33.13 7.52 4.40 Building Construction 10.17 14.04 0.36 0.34 Maximum On-site Emission (2027) 10.17 14.04 0.36 0.34 Building Construction 9.66 14.04 0.33 0.30 Paving 6.63 9.91 0.26 0.24 Architectural Coating 1.08 1.49 0.02 0.02 Maximum On-site Emission (2028) 9.66 14.04 0.33 0.30 0D[LPXP'DLO\(PLVVLRQV      SCAQMD Screening Thresholds 196.30 1128.00 9.30 5.30 7KUHVKROG([FHHGHG"1R 1R 1R 1R  <HDU 2027(Year 2) Localized Construction Emission Estimates &RQVWUXFWLRQ$FWLYLW\ 0D[LPXP'DLO\/RFDOL]HG (PLVVLRQV SRXQGVGD\  <HDU 326 I I I I I I I I I I I I Veneklasen Associates Consultants in Acoustics |Noise |Vibration |AV| IT 1711 Sixteenth Street x Santa Monica California 90404 x tel: 310.450.1733 x fax: 310.396.3424 x www.veneklasen.com January 21, 2026 HPI Architecture 115 22nd Street Newport Beach, CA 92663 Attention: Stephanie Lucero | Director, Housing Studio CC:Raymond Gamo | Senior Technical Lead Subject:Clearwater/Confluent Tustin Active Adult and Assisted Living / Memory Care Projects Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 Dear Raymond: Veneklasen Associates, Inc. (Veneklasen) has reviewed the collocated Clearwater/Confluent Tustin projects in Tustin, CA. This revised report has been updated per the most recent relevant architectural plan sheets. It predicts the exterior noise level at the site using measurements and computer modeling. Using this information, interior noise levels were calculated based on the exterior noise exposure and the construction types proposed. From this, the exterior façade design was determined. This report discusses the results of the analysis. 1.0 INTRODUCTION This study was conducted to determine the impact of the exterior noise sources on the Clearwater/Confluent Tustin projects in Tustin, CA. Veneklasen’s scope of work included calculating the exterior noise levels impacting the site and determining the method, if any, required to reduce the interior and exterior sound levels to meet the applicable code requirements of the State of CA and the City of Tustin. The projects are a 5-level active adult (AA) development with an internal courtyard on the west northwest portion of the site and a 2-level assisted living / memory care (AL/MC) development—also with an internal courtyard—on the east southeast portion of the site. The site of the projects is bounded by Warner Avenue to the north, Armstrong Avenue to the west, the future Veterans Way to the east, and the future John Johnson Way to the south. The projects include various small, bounded outdoor areas dedicated to specific dwelling units. Where those areas are at ground level, they will be referred to as patios. When they are at elevated floors, they will be referred to as balconies (even when positioned over the garage structure). 2.0 NOISE CRITERIA CNEL (Community Noise Equivalent Level) is the 24-hour equivalent (average) sound pressure level in which the evening (7 pm–10 pm) and nighttime (10 pm – 7 am) noise is weighted by adding 5 and 10 dB, respectively, to the hourly level. Since this is a 24-hour metric, short-duration noise events (truck pass-bys, buses, trains, etc.) are not as prominent in the analysis. Leq (equivalent continuous sound level) is defined as the steady sound pressure level which, over a given period of time, has the same total energy as the actual fluctuating noise. All reported noise levels are A-weighted. $77$&+0(17 327 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 2 www.veneklasen.com 2.1 Interior Noise Levels – Residential The State of CA Building Code (Title 24, Part 2, Section 1206 “Sound Transmission”) and the City of Tustin Noise Element state that interior CNEL for residential land uses are not to exceed 45 dB in any habitable room. If the windows must be closed to meet an interior CNEL of 45 dB, then a mechanical ventilating system or other means of natural ventilation may be required. Although not a regulatory requirement or planning standard, Veneklasen suggests that the maximum noise level from short-duration noise events during the night not exceed 55 dB. This criterion is based on sleep disturbance research and experience with similar projects (including both conventional residential and senior living facilities). 2.2 CALGreen – Non-Residential The California Green Building Standards Code (CALGreen Section 5.507.4.2) stipulates that for buildings exposed to a noise level of 65 dB or more when measured as a 1-hour Equivalent Sound Level (Leq), the building façade, including walls, windows, and roofs, shall provide enough sound insulation so that the interior sound level from exterior sources does not exceed 50 dB during any hour of operation. This applies to non-residential spaces such as retail space, leasing, and amenities. 2.3 Exterior Noise Levels – Residential The City of Tustin Noise Element states that for new multi-family residential projects, the exterior CNEL is not to exceed 65 dB in the following usable outdoor activity areas: patios and balconies (with a depth of 6 feet or more) and common recreation areas. 3.0 EXTERIOR NOISE ENVIRONMENT 3.1 Noise Measurements Traffic on Warner Ave. was the primary source of noise affecting the site; currently Armstrong Ave. traffic is a substantive but much less potent secondary noise source. The site is well east of the airport’s 60 dB CNEL contour. Veneklasen visited the site on Tuesday, February 20, 2024 and placed meters on the site perimeter to capture the hourly sound levels on the site for a 4-hour period. Due to ongoing construction at the site, Veneklasen’s measurements began after construction ceased. Accordingly, the measured levels capture the latter portion of the PM peak traffic period as well as lower traffic noise levels through the evening. Intermittent John Wayne Airport arrival flyovers were observed generally west of the site; these events generated only modest maximum noise levels and were not an important contributor to long-term average noise levels. Figure 1 and Table 1 show the location and summary of the noise measurements. The site boundary shown in Figure 1 encloses both projects. 328 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 3 www.veneklasen.com Figure 1 – Aerial View of Project (AA & AL/MC) Site Envelope Showing Measurement Locations Table 1 – Measured Sound Levels Location Measured LAeq (dB) Overall Loudest 60-minute Period L1 62 65 L2 65 66 3.2 Computer Modeling Veneklasen used the Traffic Noise Model 3.2 (TNM) developed by the Federal Highway Administration (FHWA) to predict vehicular noise levels at various locations. The primary purpose of the computer model was to determine how the noise environment will change due to traffic and site changes. Veneklasen obtained/derived predicted future cumulative—with Tustin Legacy Specific Plan (SP)—traffic volumes primarily from Appendix C of the 2024 Tustin Legacy Specific Plan Amendment Draft Subsequent Environmental Impact Report (2024 Tustin Legacy SPA DSEIR1). Representative 24-hour traffic distributions were obtained from hourly count data in Appendix E2 of the 2017 Tustin Legacy SPA DSEIR3. Assumed vehicle type splits were as follows: 96% autos, 3% medium trucks, 1% heavy trucks. 1 City of Tustin / EPD Solutions. (June 2024).Tustin Legacy Specific Plan Amendment: Draft Supplemental Environmental Impact Report (DSEIR).https://www.tustinca.org/DocumentCenter/View/15579/Exhibit-3B---Draft-SEIR-Tustin-Legacy---HE-Sites-1A- 1B-2-combined-reduced?bidId=. 2 City of Tustin / Stantec Consulting Services Inc. (March 8, 2017).Tustin Legacy Specific Plan Update Traffic Impact Study (Appendix E of 2017 Tustin Legacy SPA DSEIR).https://www.tustinca.org/DocumentCenter/View/14869/Tustin-Legacy-SP-Draft- Supplemental-Environmental-Impact-Report-Volume-II#page=1347 3 City of Tustin / Placeworks. (March 2017).Tustin Legacy Specific Plan Amendment: Draft Supplemental Environmental Impact Report (DSEIR).https://www.tustinca.org/DocumentCenter/View/14868/Tustin-Legacy-SP-Draft-Supplemental-Environmental- Impact-Report-Volume-I 329 Site Boundary Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 4 www.veneklasen.com Traffic growth associated with Tustin Legacy SP implementation was already underway when Veneklasen performed its 2024 noise measurements. To estimate the proportion of ultimate SP-related traffic growth that had occurred by that time, Veneklasen compared trip generation associated with “Completed to date” progress shown on the City of Tustin’s Tustin Legacy website with overall SP trip generation predictions. This (along with cumulative traffic growth information) provided a basis for interpolating traffic volumes between Existing (pre-SP) and post-SP-buildout traffic volumes. Noise levels modeled using these interpolated traffic volumes—adjusted for relevant hours of the day per the aforementioned 24-hour hourly traffic distributions—closely matched the measured noise levels from Veneklasen’s 2024 noise measurement survey. This process served to validate the traffic noise model for its application to predicting future noise levels at project building facades. 3.3 Overall Exterior Exposure Based on the computer model and measurements, Veneklasen calculated the noise level at different locations across the project site. To simplify the presentation of the exterior noise levels, Veneklasen has separated the site into locations (zones) based on the sound exposure and required mitigation. The predicted sound levels at each residential façade zone, shown in Figure 2 through Figure 6, are listed in Table 2. Table 2 – Exterior Noise Levels Location Exterior CNEL (dB)Event Level (dB)Incident on Facades At Balconies/Patiosa Zone A 68 – 69 70 – 71 77 – 78 Zone B 66 – 67 --75 – 76 Zone C 64 – 65 66 – 67 73 – 74 Zone D 61 – 63 --70 – 72 Remaining Units ч 60 --ч 69 a These levels account for reflection of exterior-source noise from facades, as well as slightly closer distances to nearest exterior sources, and do not account for any intervening barriers. These zones are denoted in the corresponding figures by color- and dash-coded lines. Outdoor use areas subject to Noise Element Table N-3 standards are coded in pink—pink outlines for larger areas (e.g., for common use) and pink shading for smaller ones (e.g., patios and balconies that are 6 feet or more in depth across at least portions of their widths). Patios and balconies shown in these figures and less than 6 feet in depth do not have pink shading added. Current roof plans show rooftop mechanical equipment near the northeast corner of the AL/MC building. Some upper (3rd and/or higher floor) dwelling units along the north portion of the east-side façade of the AA building could have direct line of sight exposure to noise from such equipment at distances of less than 100 feet. Future exterior noise levels at those façade locations (assigned to Zones B through D based on exposure to noise sources exterior to the AA & AL/MC developments) could be at least slightly higher than indicated. 330 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 5 www.veneklasen.com Figure 2 – Noise Zones: Active Adult (AA), Second Floor Zone A AA Outdoor Area Zone C Zone C Zone B Zone B Zone D Zone D 331 I ~ ~ • • • • • • • • • • • . .. • • • • • • f P--J ! {~~ I ~ ■ ~ . "' ■ ■ ' ■ -■ I ~ [ i • ~ > < ,., . \ 0 ~' -~ ~ ~ < -~-■ ~••~•~•:d---~-r I "' • --■ ■ ■ ■ ■ ■ ■ ■ ■ • ■ ~ ■ ■ ■ ■ ■ ■ tfOJNltOf NtlOr "'" / Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 6 www.veneklasen.com Figure 3 – Noise Zones: Active Adult (AA), Third Floor Zone A Zone C Zone C Zone B Zone B Zone D Zone D 332 A.VM N0fl'Hl0f NH0f Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 7 www.veneklasen.com Figure 4 – Noise Zones: Active Adult (AA), Fourth & Fifth Floors Zone A Zone C Zone C Zone B Zone B Zone D Zone D 333 AVM NOSNHOf N~Or Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 8 www.veneklasen.com Figure 5 – Noise Zones: Assisted Living / Memory Care (AL-MC), First FloorZone E Zone A Zone B Zone C AL-MC Outdoor Area 334 • • -- AL COURTYARD Jll,QU,ll n1nu.:u :rltf21All r I f 1,;,,,, I J J ~•I';" .. .(•·"'}',:•· .. ., .er ,.. ... ,,.x-,-· .. ,.. •. ,,. .(···~i••r ., .... .,,. "'}~---· ., ... ,,. ( .... },: ... r .( .... .,J·"'~.f•·' .,. r .(" ")'1"· .. ,, ... ..,,•·-.,,r•l'r1 .... .,.-... },:•-• ,( .( • I I • ' • ■ ~ • • : • • ·-~ • • 2-WU ,.,. .... I I I I I I I I I I • I • I I /' ,,. I'" r ✓," .,~,•,,. .t" r /'t ,,.'l.f" 9' /' r .<" "~1" r .<'., /: "~f'., ✓• r /" ,,.~ ,, • .,. /' ,,. I'• .-,-.f• r ✓,• r ✓• r~1• r ✓• ff'(" ,,.~,•If'.( I I Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 9 www.veneklasen.com Figure 6 – Noise Zones: Assisted Living / Memory Care (AL-MC), Second Floor 4.0 INTERIOR NOISE CALCULATION 4.1 Exterior Façade Construction Calculations were based on the latest entitlement submittal drawings. HPI previously provided the following construction compositions for the planned one-and two-hour fire rated exterior wall assemblies; they are applied for the current projects pending further development of assembly composition design. x One-hour assemblies across the project are assumed to consist of plaster on metal lathe (7/8-inch) or wood siding -- or plaster on metal lathe (7/8-inch) -- over one layer of gypsum board (5/8-inch) , 5-1/2-inch wood or 6-inch metal studs, and a single layer of gypsum board on the interior with batt insulation in the cavity. x Two-hour assemblies across the project are assumed to consist of wood siding (5/8-inch) over metal furring (3/8-inch), plaster on metal lathe (7/8-inch) or wood siding -- or tile (1-inch) over cast-in-place concrete (3/4-inch) -- over one layer of gypsum board (5/8-inch) , 5-1/2-inch wood or 6-inch metal studs, and a single layer of gypsum board on the interior with batt insulation in the cavity. Veneklasen’s analysis included the roof path, but this was insignificant in the interior noise level calculated. Zone A Zone E Zone B Zone C 335 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 10 www.veneklasen.com Veneklasen utilized the glazing ratings (glass, frame, and seals) shown in Appendix I. 4.2 Interior Average Noise Level (CNEL) – Residential Veneklasen calculated the interior level within the residential units given the measured noise environment and the exterior façade construction described above. Table 3 shows the predicted interior CNEL based on the windows and doors with STC ratings as shown and glazing construction as described in Appendix I. Note that the STC ratings indicated in the table do not completely specify the building element performance, as the building element must also meet the octave band transmission loss across the frequency spectrum as specified in Appendix I. Table 3 – Calculated Interior CNEL Location Exterior CNEL (dB) Window/ Door Rating4 Interior CNEL (dB) Zone A 68 – 69 STC 33 <= 45 Zone B 66 – 67 STC 31 <= 45 Zone C 64 – 65 STC 30 <45 Zone D 61 – 63 STC 30 << 45 Remaining Units ч 60 No STC requirement. STC 30 recommended. As mechanical plans and associated equipment schedules progress, exposure of dwelling units along the north portion of the east-side façade of the AA building (Zones B through D) to noise from AL/MC rooftop mechanical equipment should be evaluated. If such noise could increase overall CNEL to a zone warranting higher minimum window/door STC ratings, then various project mitigation options should be considered, including increasing minimum window/door STC ratings at those façade locations. Where the noise level does not exceed 60 dB CNEL, sound-rated assemblies are not required. However, Veneklasen recommends specifying a window with a minimum rating of STC 30 to maintain a consistent level of acoustical quality. 4.3 Interior Short-duration Noise Event – Veneklasen Recommended Glazing (Optional) In a similar manner Veneklasen calculated the interior noise levels from the single-event noise sources such as motorcycle and heavy truck pass-bys and sirens from emergency vehicles. As described in Section 2.1, Veneklasen’s recommended interior nighttime noise level criterion is 55 dB. Table 4 shows Veneklasen’s recommended mitigation to reduce the interior noise levels due to short-duration noise events at facades facing Warner or Armstrong Avenues. Table 4 – Calculated Interior Short-Duration Event Noise Levels Zone Exterior Event Level (dB) Window/ Door Rating2 Interior Event Level (dB) Zone A 77 – 78 STC 35 <= 55 Zone B 75 – 76 STC 33 <= 55 Zone C 73 – 74 STC 31 <= 55 Zone D 70 – 72 STC 30 <= 55 Remaining Units ч 69 STC 30 < 55 4 STC rating does not fully specify the building element performance. Refer to Appendix I.336 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 11 www.veneklasen.com 4.4 Mechanical Ventilation – Residential Because the windows and doors must be kept closed to meet the noise requirements, mechanical or other means of ventilation may be required for units in Zones A through D. The ventilation system shall not compromise the sound insulation capability of the exterior façade assembly. 4.5 Project-Internal Noise from Outdoor Recreation Pickleball courts are proposed at the 3rd floor rooftop patio on the east side of the AA building. Nearby dwelling units include those immediately northeast of the courts from the 3rd through 5th floors. While this noise exposure circumstance is not expected to bear on acoustical code compliance or local regulations or planning standards, it can have implications for acoustical quality and resident experience. As project design progresses, this noise exposure circumstance should be evaluated and mitigation (potentially including increased STC performance for windows/doors at affected façade locations) considered as appropriate. 4.6 CALGreen – Non-Residential Veneklasen also calculated the noise level within non-residential spaces. CALGreen is based on the loudest hourly Leq. Veneklasen utilized a statistical methodology to determine this level from the measurements. The results are shown in Table 5 below and should be implemented for all amenity spaces facing Warner Ave. Hourly noise level summaries and sample calculations are included in the appendices. Table 5 – Calculated Interior Average Noise Levels at Non-Residential Areas Location Exterior Loudest Hour During Regular Use (dB) Minimum Glazing Interior Loudest Hour During Regular Use (dB) Zone E 69 – 70 STC 28 < 50 5.0 EXTERIOR NOISE CALCULATION 5.1 Exterior Average Noise Level (CNEL) – Residential Table 6 summarizes predicted noise exposure at exterior areas that Veneklasen interprets as subject to City Noise Element Table N-3. Table 7 shows detail drawings for relevant patio walls. Many residential patios and balconies within the AA & AL/MC have a depth of 6 feet or greater along at least parts of their widths and thus are subject to Noise Element Table N-3 criteria. Among those, the ones located within Zones A through C are predicted to experience future (with Tustin Legacy SP) CNELs exceeding the applicable 65 dB threshold in the absence of intervening barriers. In those cases, pursuant to City application of these planning standards, Veneklasen recommends—and the project design has integrated—contiguous solid barriers with minimum heights as indicated in Table 6. Table 6 – Exterior Noise Levels Floor ζ Location Outdoor CNEL from Sources Beyond Project Building Footprints (dB) Mitigation (Zones A through C only): Minimum Barrier Height (ft) Report Figure(s)No Mitigation With Mitigation 1 AL/MC patios 6 or more feet deep ч 70 < 65 6 Fig. 5 2 AA & AL/MC patios/balconies 6 or more feet deep ч 71 ч 65 5.5 Figs. 2 & 6 1-2 AA & AL/MC courtyards & courtyard-facing patios/balconies < 65 -- --Figs. 2 & 5 3 AA floor rooftop patio < 65 ----Fig. 3 337 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 12 www.veneklasen.com Figure 7 – Detail Elevations of AA & AL/MC Patio Walls at Patios Subject to Noise Element Table N-3 Criteria The acoustical design goals for the patio walls represented by the first two data rows in Table 6 require each component material to provide sufficient effective broadband A-weighted transmission loss (TL) to minimize any compromise in achieving the minimum insertion losses required of the barriers. Outdoor-Indoor Transmission Class (OITC) can be an adequate surrogate for such TL. Per minimum insertion losses from , and also considering potential flanking paths—e.g., related to access doors per Orange County Fire Authority (OCFA) ingress/egress requirements, at joints between barrier segments/materials, etc.—a minimum effective broadband A-weighted TL or OITC of 20 is recommended for each barrier material. As shown in Figure 2, Figure 5, and Figure 6, barriers intended to provide noise mitigation at patios/balconies wrap around all portions not already enclosed by the building façade. The details in Figure 7 sample the vertical arrangement of patio wall materials/components and note both total height and minimum thicknesses (and, for glazing layers) for the materials/components. The details also show contiguous coverage 338 ), 'I-- :::l ~ .; 0 ~ .., O .i Q. ci ,_; f! r lo .. 0'•6" ;;, "'' ,- 1 ~ ~ 0 ~ " ~ g ' b ... ~ " MIN ... IHK. CONC, P!ANIE'Jtw/ SDING 10 MATCH 8UILD NG IREJ'tlt ro M~IERIAL SOAAO) 7 fl EO[!'J.ACc.E>ICWEw/MIN.ln'n«,ITOl/,l)OOUBlEGWJNG --- 10 MEE! ACOOSTICAl.mlUIRct,\EN~ MIN, •"TH,;, CONCRElE WAil MIN.1/TIHK.POIAL)DDUILEGWING ---I 10 MEET ACOUSTICAi REOIJ RfMENlS, lYP. DETAIL ELEVATION OF AA PATIO WALL SCALE 3/8" = )'-0" t.;IN, TdlliK.f,OlA1.)DOUe1LtGW•IG-OMUi ltiC.01.tSJ\CA! lil£QJ ~fNIS ------ft OEPJ /<CCESSGliJEWIMlN. l(TrtK(T01AI.J DOUUE ~NG IO Mffi AC0\1$UCM. lffi'lUIREMOO~ r DETAIL ELEVATION OF ALMC PATIO WALL SCALE 3/8" = l '•O" 4 5 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 13 www.veneklasen.com of the applicable solid materials/components laterally and from the bases to the tops of the wall. The Fire Dept. Access Gates are shown in the form of glazed, side-framed swing doors, with no visible lateral gaps between the gate leaves and side frame elements. Those materials/components, thicknesses, heights, coverages, and other design elements are sufficient to provide the TL needed to avoid substantive compromise to barrier insertion loss. In effect, diffraction of sound over the barriers will be the limiting factor on that insertion loss, and the barrier tops are high enough to maintain sufficient insertion loss at a realistic range of receiver positions and listening heights, using the following readily available means of gap sealing: Any narrow gaps between adjoining static/permanent barrier elements (e.g., at joints between materials/sections) shall be sealed with suitable exterior sealant. In addition, access gates shall be equipped with outdoor-suitable edge/contact features (to at least substantially seal lateral and bottom gaps when the door is closed, while also accommodating necessary door operation, e.g.: x Sides of gate frames: Full-height brackets extending inward from frame edges, akin to full-height gate stops; and/or outdoor-compatible gaskets on either side fitted to at least contact gate leaf side edges when gates are closed, and x Bottoms of gate leaves: Outdoor-compatible door sweeps. Courtyards within both buildings are entirely enclosed by building envelopes, with only narrow sections where that enclosing envelope is less than full building height. Accordingly, the courtyards are well protected from ground-level noise sources located outside of the footprints of the enclosing buildings. 6.0 SUMMARY The following summarizes the acoustical items required to satisfy the noise criteria as described in this report. Residential x Anticipated wall assemblies are acceptable as described in Section 4.1, pending confirmation as project design proceeds. x The roof assembly was included in the analysis, is not a significant path of sound, and can remain as designed. x Windows and glass doors as shown in Table 3 with Transmission Loss values and STC ratings defined in Appendix I are required. Appendix I shall be the acoustical specification for all exterior windows and doors. x Optional: To meet Veneklasen’s criterion for short-duration noise events, windows and glass doors with minimum STC ratings as shown in Table 4 are recommended. This is not required by code but will increase occupant comfort. x Residential mechanical ventilation, or other means of natural ventilation, may be required for units in Zones A through D. x As project design development progresses, noise levels from pickleball courts at the most exposed dwelling unit façade locations should be evaluated and mitigation measures considered as appropriate. Non-Residential x At indoor amenity and other non-residential spaces facing Warner Ave, windows and glass doors as shown in Table 5 with Transmission Loss values and STC ratings defined in Appendix I are required to meet the CALGreen interior noise criterion. 339 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 14 www.veneklasen.com Exposure of Outdoor Areas x At patios/balconies with depths of 6 feet or greater within Zones A through C, contiguous perimeter barriers are required as specified in Section 5.1 and . Various noise mitigation methods may be utilized to satisfy the noise criteria described in this report. Alteration of mitigation methods that deviate from requirements should be reviewed by the acoustical consultant. If you have any questions or comments regarding this report, please do not hesitate to contact the undersigned. Sincerely, Veneklasen Associates, Inc. Michael Weber Associate 340 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 15 www.veneklasen.com APPENDIX I – GLAZING REQUIREMENTS In order to meet the predicted interior noise levels described in Section 4.2, the glazing shall meet the following requirements: Table 7 – Acoustical Glazing Requirements: Minimum Octave Band Transmission Loss and STC Rating Nominal Thickness Minimum Transmission Loss Octave Band Center Frequency (Hz) Min. STC Rating125250500100020004000 1” dual 21 18 24 32 36 31 28 1” dual 21 18 27 34 37 32 30 1” dual 21 19 28 35 37 32 31 1” dual 22 21 30 36 37 36 33 1” dual 23 22 32 37 38 38 35 The transmission loss values in the table above can likely be met with the following glazing assemblies: 1. Up to STC 35: nominal 1” insulated glazing unit An assembly’s frame and seals may limit the performance of the overall system. Therefore, the window and door systems selected for the project shall not be selected on the basis of the STC rating of the glass alone, but on the entire assembly including frame and seals. Additionally, the assemblies given above are provided as a basis of design, but regardless of construction, the octave band Transmission Loss (TL) and STC value of the system selected must meet the minimum values in Table 7 above. Independent laboratory acoustical test reports should be submitted for review by the design team to ensure compliance with glazing acoustical performance requirements. Laboratories shall be accredited by the Department of Commerce National Voluntary Laboratory Accreditation Program (NVLAP). Labs shall be pre- approved by Veneklasen Associates. Tests shall be required to be performed in North America. Lab tests and lab reports shall be in compliance with ASTM standard E90 and be no more than 10 years old from the date of submission for this project. If test reports are not available for a proposed assembly, the assembly, including frame, seals and hardware, shall be tested at an independent pre-approved NVLAP-accredited laboratory to demonstrate compliance with the requirements of this report. Veneklasen shall be invited to witness acoustical testing completed and reserves the right to exclude test reports from laboratories that are not pre-approved by Veneklasen. 341 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 16 www.veneklasen.com APPENDIX II – MEASURED HOURLY NOISE LEVELS Location Start Time Duration LAeq L1 5:00 pm 1:00:00 65 6:00 pm 1:00:00 63 7:00 pm 1:00:00 59 8:00 pm 1:00:00 57 L2 5:00 pm 1:00:00 67 6:00 pm 1:00:00 65 7:00 pm 1:00:00 65 8:00 pm 1:00:00 63 342 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 17 www.veneklasen.com APPENDIX III – GLOSSARY OF ACOUSTICAL TERMS Term Definition Absorption A property of material referring to how much sound it absorbs (as opposed to reflecting). In the context of this report, absorption refers to the total quantity of absorption within the receiving space. Absorption is measured in sabins. A-weighting The sound pressure level in decibels as measured in an A-weighting filter network. The A-weighting de-emphasizes the low 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. CɁEL (Community Noise Equivalent Level) The energy average of the A-weighted sound levels occurring during a 24-hour period, and which accounts for the greater sensitivity of most people to evening and nighttime noise by weighting noise levels at evening and night. Noise between 7 pm and 10 pm is weighted (penalized) by adding 5 dB, and noise between 10 pm and 7 am is weighted by adding 10 dB to consider the greater annoyance of evening and nighttime noises. For practical purposes, the CɁEL and DɁL are usually interchangeable. Decibel (dB)A unit describing the amplitude of sound equivalent to 20 times the logarithm, to the base 10, of the ratio of the pressure of the sound to the reference pressure of 20 PPa. Used to quantify sound pressure levels. DɁL (Day-Night Average Sound Level) The energy average of the A-weighted sound levels occurring during a 24-hour period, and which accounts for the greater sensitivity of most people to nighttime noise by weighting noise levels at night. Noise between 10 pm and 7 am is weighted (penalized) by adding 10 dB to consider the greater annoyance of nighttime noises. This noise descriptor is referred to by different agencies and references as either DɁL or Ldn. The two notations refer to the same noise descriptor. Equivalent Sound Level (Leq)Used to describe noise over a specified period of time, typically one hour, in terms of a single numerical value. The Leq is the constant sound level, which would contain the same acoustic energy as the varying sound level, during the same time period (i.e., the average noise exposure level for the given time period). Lmax The instantaneous maximum noise level measured during the measurement period of interest. Ln The sound level that is equaled or exceeded n percent of a specified time period. The L50 represents the median sound level. Sabin A unit used to describe absorption within a space. One sabin is equal to the absorption of a one-square-foot open window. 343 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 18 www.veneklasen.com Term Definition Sound Pressure Level (SPL)The amplitude of sound when compared to the reference sound pressure level of 20 PPa. SPL is measured in dB with zero dB corresponding roughly to the threshold of human hearing, and 120 to 140 dB corresponding to the threshold of pain. Because sound pressure can vary greatly within the range of human hearing, a logarithmic loudness scale is used to keep sound intensity numbers at a convenient and manageable level. Sound Transmission Class (STC)A single-number metric used to describe the transmission loss performance of a material or assembly across the frequency spectrum. It is intended for use primarily when speech is the noise source. Transmission Loss (TL)A measure of the reduction in sound level as a sound wave passes through a material. The higher the transmission loss, the better the material’s sound insulating properties. 344 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 19 www.veneklasen.com APPENDIX IV – ACOUSTICAL CALCULATION METHODS Decibel Addition Decibels are based on a logarithmic scale; defined as the logarithmic ratio between a measured sound pressure level and a reference sound pressure level. When decibels are added, they are not combined arithmetically, but logarithmically. Decibels are added according to the following equation. ࡿࡼࡸ࢚࢕࢚ =૚૙࢒࢕ࢍ൬૚૙ቀࡿࡼࡸ૚ ૚૙ൗቁ൰ +૚૙࢒࢕ࢍ ൬૚૙ቀࡿࡼࡸ૛ ૚૙ൗቁ൰ Where: SPLtot = Total Sound Pressure Level (dB or dB) SPL1, SPL2 = Sound Pressure Level 1, 2 (dB or dB) A-Weighting A-weighting a spectrum is completed by applying standardized weighting factors to a frequency spectrum, either in octave bands or third-octave bands. These resultant A-weighted levels are summed using decibel addition to generate the overall A-weighted level, noted as dB. In a report, spectral data is typically presented un-weighted, and the overall level is presented with A-weighting. The octave band A-weighting correction factors are shown in the table below: Octave Band Center Frequency (Hz) 63 125 250 500 1000 2000 4000 8000 A-weighting Correction Factor (dB) -26 -16 -9 -3 0 +1 +1 -1 Acoustical Shielding The presence of adjacent buildings or façades, changes in terrain, parapets, and other similar barriers provide acoustical shielding, reducing the sound level incident on the exterior façades. Common locations where acoustical shielding occurs include, but are not limited to, the roof, the back, and sides of the building that are not directly facing the noise source. Acoustical shielding due to building geometry can be separated into two categories: reduction due to reduced area of exposure (side of a building), and shielding from barriers (such as a parapet or sound wall). Reduction as a result of reduced area of exposure is calculated according to the following equation: οࡿࡼࡸ =૚૙ܔܗ܏૚૙ ൬ࣂࢋ࢞࢖ ૚ૡ૙൰ Where: οܵܲܮ = Change in Sound Pressure Level (dB) ɽexp = Angle of exposure (degrees) 345 Veneklasen Associates Clearwater/Confluent Tustin; Tustin, CA Exterior Noise and Exterior Façade Acoustical Analysis Veneklasen Project No. 6840-017-001 & -002 January 21, 2026 – Page 20 www.veneklasen.com Acoustical Attenuation due to Distance Sound pressure level reduction due to distance is calculated according to the following equation: ࡿࡼࡸ૛ =ࡿࡼࡸ૚ +࡯ࡿܔܗ܏ ൬࢘૚ ࢘૛ ൰ Where: SPL1 = Sound Pressure Level at Location 1 (dB or dB) SPL2 = Sound Pressure Level at Location 2 (dB or dB) CS = Source Coefficient; 20 for point source, 10 for a line source r1 = Location 1 distance from source (ft.) r2 = Location 2 distance from source (ft.) In some situations, the CS value is between 10 and 20; selection of this number is an engineering judgment based on the relationship between the source and receiver as well as the type of source. Interior Noise Calculation The interior noise calculation takes into account the exterior noise level, the transmission loss of the glazing (including glass, frame, and seals), wall, and roof/ceiling systems, the finishes within the space, and noise exposure due to building geometry and acoustic shielding. The interior sound level is calculated using the equation: ࡿࡼࡸࡵ =ࡿࡼࡸࡱ +૚૙࢒࢕ࢍ૚૙(࡭)െ ૚૙࢒࢕ࢍ૚૙(ࡾ)െࢀࡸ+૟ Where: SPLI = the Interior Sound Pressure Level (dB or dB) SPLE= Exterior Sound Pressure Level (dB or dB) A = Surface Area exposed to Exterior Noise (sq.ft.) R = Room Absorption Coefficient (sabins) TL = Sound Transmission Loss of Exterior Façade Assembly (dB) This calculation is performed for each exposed façade individually. The total interior sound level is found by using decibel addition to sum the sound level from all exposed façades. 346 October 9, 2025 Job No. CONFCDMS-0013 MEMORANDUM To: Linda Sandusky Vice President Land Development Market Leader California Region From: James M. Daisa, TE Senior Transportation Project Manager RE: SECOND REVISION TO VEHICLE MILES TRAVELED (VMT) SCREENING FOR THE CLEARWATER AT TUSTIN LEGACY ACTIVE ADULT AND ASSISTED LIVING DEVELOPMENT, TUSTIN, CA David Evans and Associates, Inc. (DEA) is pleased to submit this second revision to the VMT screening memorandum to include with your client’s upcoming submittal to the City of Tustin for the above- mentioned development (the “project”). The first revision to the VMT screening assessment reflects the use of data from the Orange County Transportation Authority’s (OCTA) updated regional Orange County Transportation Analysis Model (OCTAM version 5.1). The second revision to the VMT screening assessment reflects a small change in the number of units in the Active Adult residential building. The number of beds increased by one in the Assisted Living and Memory Care (ALMC) facility but the variable representing non-residential land use in the OCTAM model is employees and a change in units or beds in the facility are not relevant for the computation of VMT using the OCTAM model. This memorandum primarily documents the revised VMT screening assessment. The other information presented in the June memorandum—estimated project trip generation and a determination if the project triggers a requirement to conduct a non-CEQA traffic level of service study in accordance with the City of Tustin’s transportation impact study guidelines. The last two parts of the memorandum have not changed and are simply summarized in this revised memorandum. A. PROJECT DESCRIPTION The project description has not changed from the perspective of analyzing potential transportation impacts. The critical part of the project’s description—the type and amount of land use—remains the same and is described below. The project includes an Active Adult residence building on the western half of the site and an Assisted Living and Memory Care facility on the eastern half. The Active Adult Living building is a five-story, 280,000- square-foot facility with 172 residential units, including studios, one-bedroom, and two-bedroom apartments. The two-story Assisted Living and Memory Care facility is 140,340 square-feet with 75 assisted living units and 28 dedicated memory care studios for a total of 134 beds. ESTIMATED PROJECT TRIP GENERATION Without any change in the type and amount of the project’s land use, the project’s estimated trip generation remains the same and is summarized below. 347 DAVID EVANS ANoASSOCIATES INC. Linda Sandusky, October 9, 2025, Page 2 The project’s estimated daily, AM peak hour, and PM peak hour trip generation is shown in the table in Attachment A using trip generation rates from the Institute of Transportation Engineers (ITE) Trip Generation (11th Edition). The ITE land use category best matching the Active Adult Living residential in Building 1 is Senior Adult Housing – Multifamily (LUC 252). The 172-unit building is estimated to generate 522 trips on an average weekday, 34 AM peak hour, and 43 PM peak hour trips. No trip reductions are taken for this type of land use. The ITE land use category of Assisted Living (LUC 254) best matches the adult care residential in Building 2. The 134-bed Assisted Living(106beds) and Memory Care (28 beds) unitscombined are estimated to generate 348 trips on an average weekday, 24 AM peak hour, and 32 PM peak hour trips. No trip reductions are taken for this type of land use. The combined trip generation of both buildings is shown at the bottom of the table in Attachment A and equals 856 average weekday trips, 57 AM peak hour, and 74 PM peak hour trips.These daily and peak hour trip generation estimates play roles in the City’s screening processes described in subsequent sections of this memorandum. The combined trip generation of both buildings is shown at the bottom of the table and equals 870 average weekday trips, 58 AM peak hour, and 75 PM peak hour trips.The peak hour trip generation estimates exceed 50 trips per hour, which is the threshold above which the City of Tustin requires the project applicant to submit a scoping agreement to prepare a traffic LOS analysis. B. SCREENING PROJECT FOR TRAFFIC LEVEL OF SERVICE IMPACT ANALYSIS Peak hour trip generation is used to determine whether the proposed project will be required to prepare a non-CEQA traffic impact analysis of intersection and/or roadway levels of service (LOS) and identify improvements to maintain the City of Tustin’s standard of LOS D in the peak hours. If a development generates 50 or more peak hour trips it will be required to conduct a traffic level of service impact analysis. Since the proposed project generates 58 AM peak hour trips and 75 PM peak hour trips, it satisfies the 50 peak hour trip criterion. Satisfying this criterion requires the applicant to prepare a scope of work identifying the traffic level of service analysis methodology and assumptions for the city to review and approve. The “scope agreement", as it is called, is a separate document being submitted with this revised VMT screening assessment. C. SCREENING PROJECT FOR VEHICLE MILES TRAVELED ANALYSIS The City of Tustin’s Vehicle Miles Traveled Analysis Guidelines include criteria for screening land development projects to determine if a project will require preparation of a detailed analysis of VMT for identifying transportation impacts under CEQA or be screened out because of project characteristics reduce the level of carbon equivalent emissions. A land use development project that produces less than 3,000 metric tons of carbon-equivalent emissions annually can be presumed to have a less-than-significant transportation impact on the environment. Tustin’s screening criteria were derived from the California Governor’s Office of Planning and Research (OPR) which produced a publication titled Technical Advisory on Evaluating Transportation Impacts In CEQA in 2018 which include: 1) Is the Project 100% affordable housing? According to sources provided by OPR, affordable housing projects typically generate lower VMT than market-rate housing and a project consisting of a high percentage of affordable housing may be a basis for the city to find a less than significant impact on VMT. One reason for this is the low-income households that meet criteria for affordable housing have less access to vehicles. ¾The project is not comprised of 100% affordable housing and does not satisfy this criterion. 2) Is the Project within 1/2 mile of qualifying transit? The CEQA guidelines state that Lead Agencies can presume that residential, retail, and office projects, or a mix of these uses, proposed within one 348 ~ .:AVID EVANS AND ASSOCI A T ES INC. Linda Sandusky, October 9, 2025, Page 3 half (½) mile of an existing major transit stop or an existing stop along a high-quality transit corridor will have a less than significant impact on VMT. The stringent definitions that describe major stops and high-quality transit corridors result in few locations that meet this criterion. ¾The project is not located within a ½-mile radius of transit services that meet the definition of a major transit stop or a high-quality transit corridor and does not satisfy this criterion. 3) Is the Project a local serving land use? Local serving land uses provide goods and services to the local community and offer more opportunities for residents and employees to shop, dine and obtain services closer to home and work resulting in shortened trip lengths and reduced VMT. Therefore, local serving uses may be presumed to have a less-than-significant impact on VMT. ¾The project’s land uses cannot be categorized as “locally serving” and does not satisfy this criterion. 4) Is the Project in a low VMT area? Land development projects that locate in areas with uses that currently generate low VMT, and that incorporate similar features (such as density, mix of uses, and transit accessibility) will tend to exhibit similarly low VMT. If a residential or non-residential development is in a Traffic Analysis Zone (TAZ) with VMT per capita or VMT per employee ratios that are less than or equal to the citywide average, then the project can be presumed to have a less-than-significant impact on VMT. ¾The project is in TAZ 1056 which is a low-VMT area generating a home-based VMT / capita of 9.5 which is less than the citywide average home-based VMT / capita of 12.4. The proposed project also contains non-residential land uses (assisted living / memory care) with a threshold measured in VMT / Employee. TAZ 1056 has a citywide average VMT / Employee of 35.6 which is nearly twice the city’s threshold of 17.3. Because the non-residential component of the proposed project exceeds the city’s threshold, the applicant is required to prepare a VMT analysis to identify potential transportation impacts under CEQA. 5) Are the Project's Net Daily Trips less than 500 ADT? Small land development projects that generate less than 500 net average daily trips would not cause a substantial increase in the total citywide or regional VMT and the project’s carbon equivalent emissions will not reach 3,000 metric tons per year and can be presumed to have a less-`than-significant impact on VMT. ¾The project is estimated to generate 856 trips per day on an average weekday which exceeds the required “less than 500 net trips per day” and does not satisfy this criterion. The screening assessment for the Clearwater at Tustin Legacy project which includes a completed “form” and additional attachments containing supporting analysis or data, is in Attachment B. D. CONCLUSION OF THE PROJECT SCREENING PROCESS In summary, the assessment in this memorandum concludes the following: x A Non-CEQA Traffic Level of Service Analysis is Required. The proposed project generates nearly 1,000 trips each weekday and over 50 trips in each of the AM and PM peak hours. The project’s peak hour trip generation greater than 50 trips satisfies the City of Tustin’s threshold for requiring the preparation of a Traffic Impact Study measuring the project’s effect on the city’s intersection and/or roadway peak hour level of service standard of LOS D. As a result, DEA prepared a “scoping agreement” identifying the methodology, assumptions and extent of the study area for the city’s review and approval and is submitting the document concurrently with this revised VMT screening assessment. x A VMT Analysis to Identify Potentially Significant Transportation Impacts Under CEQA is Required. The proposed project did not satisfy any of the city’s five criteria for screening the 349 ~ .:AVID EVANS AND ASSOCI A T ES INC. Linda Sandusky, October 9, 2025, Page 4 project from having to prepare a CEQA impact analysis based on VMT. A VMT analysis was conducted and is being submitted concurrently with this revised VMT screening assessment. Attachments: 1. Attachment A – Estimated Project Trip Generation 2. Attachment B – City of Tustin VMT Screening Form for Land Use Projects 350 ~ WcA.VID EVANS ANO ASSOCIATES INC. ATTACHMENT A ESTIMATED PROJECT TRIP GENERATION 351 ~ .:AVID EVANS ANO ASSOCIATES INC. ESTIMATED TRIP GENERATION FOR ACTIVE ADULT AND ASSISTED LIVING / MEMORY CARE BUILDINGS FOR THE CLEARWATER AT TUSTIN LEGACY DEVELOPMENT Building / Land Use Dwelling Units Average Weekday AM Peak Hour PM Peak Hour In Out Total In Out Total Building 1: Active Adult (ITE LUC 252) Average Rate or Equation [a] 172 T = 2.89(X) + 24.82 34%66%T = 0.19(X) + 0.90 56%44%T = 0.25(X) + 0.07 Trips 522 11 22 34 24 19 43 Land Use Beds Average Weekday AM Peak Hour PM Peak Hour In Out Total In Out Total Building 2: Assisted Living / Memory Care (ITE LUC 252) Average Rate or Equation [a] 134 2.6 60%40%0.18 39%61%0.24 Trips 348 14 10 24 13 20 32 Site Total 870 26 32 58 37 39 75 Notes: Source: Institute of Transportation Engineers (ITE). Trip Generation (11th Edition). Washington DC. LUC = Land Use Code / LUC 252 = Senior Adult Housing -Multifamily / LUC 254 = Assisted Living [a] See attached excerpts from Trip Generation, 11th Edition for rates and equations. 352 ~ =itiill:AVID EVANS AND ASSOCIATES INC. ATTACHMENT B CITY OF TUSTIN VMT SCREENING FORM FOR LAND USE PROJECTS 353 -AVID EVANS ANO ASSOCIATES INC. Page 1 of 2 12.4 VMT/Capita 17.3 VMT/Employee 1 OCTAM 5.1 v.11.22.23 base year (2019) statistics. -- -- Trip Generation Evaluation: * Use trip rates from the latest edition of the ITE Trip Generation Manual or as approved by City Staff. NO Citywide Average Home-Based VMT1 = Citywide Average Employment VMT1 = Internal Trip Credit: Pass-By Trip Credit: % Trip Credit: Trip Credit: Affordable Housing Credit: % Trip Credit: Source of Trip Generation: Project Trip Generation: VMT Rate for Project TAZ1 Project Type City of Tustin VMT Thresholds II. VMT Screening Criteria % Trip Credit: B. Is the Project within 1/2 mile of qualifying transit? C. Is the Project a local serving land use? E. Are the Project's Net Daily Trips less than 500 ADT? D. Is the Project in a low VMT area? Low VMT Area Evaluation: Version: March 26, 2025 Average Daily Trips (ADT)Net Project Trip Generation: Average Daily Trips (ADT) Existing Land Use Trip Credit: A. Is the Project 100% affordable housing? Project Traffic Analysis Zone (TAZ) VMT/Capita VMT/Employee Residential: Non-Residential: Does project trip generation warrant an LOS evaluation outside of CEQA? 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. The analysis provided in this form should follow the City of Tustin approved VMT Guidelines, updated version March 26, 2025. Case Number: I. Project Description Project Location: Project Name: Current Zoning:Proposed Zoning: Project Description: Current GP Land Use:Proposed GP Land Use: Does the Project require a General Plan Amendment and/or Zone Change? Clearwater at Tustin Legacy - Active Adult and Assisted Living Development SEC of Warner Avenue and Armstrong Avenue, Tustin, California APN No: 430-481-12 The 6.14 acre site accommodates two buildings with structured subterranean parking. Building #1 is an active adult residential building with 174 units including studios, one bedroom, and two-bedroom apartments. Building #2 is a 134- bed assisted living and memory care facility. TUSTIN LEGACY SPECIFIC PLAN (PA 8, 13,14)Same as current MIXED-USE URBAN (NEIGHBORHOOD D)Same as current No No No No No No 1056 9.5 [a] 35.6 X X Institute of Transportation Engineers (ITE) Trip Generation, 11th Edition. 870 No No No No 870 YES [a] The Home-Based VMT/Capita of 9.5 (for TAZ 1056) is less than the City's threshold of 12.4 VMT/Capita. However, the project has both a residential and a non-residential component and the non-residentialcommute metric for TAZ 1056 of 35.6 is greater than the city's threshold of 17.3 VMT/Employee. Therefore, TAZ 1056 is not considered a low-VMT generating area. See Attachment A-1 for the OCTAM (ver. 5.1)used in this screening assessment. ATTACHMENT B 354 I I I I Page 2 of 2 Source: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. G. Mitigated Project TAZ VMT Rate: 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. D. Does Unmitigated Project VMT Rate Exceed VMT Threshold? Company: Developer/Applicant H. Significance Finding: Email: Date: All mitigation measures are subject to become Conditions of Approval of the project. Provide attachments showing all VMT reduction calculations. C. Unmitigated Project VMT Rate: B. City of Tustin VMT Threshold of Significance: F. Mitigation Measures: Version: March 26, 2025 III. VMT Analysis Summary VMT Reduction Mitigation Measure:Estimated VMT Reduction (%) E. Percentage Reduction Required to Achieve the Citywide Average VMT: Date Approved by: Email: Date: Phone:Phone: Contact: Address: Prepared By Company: Address: Tustin Public Works Engineering Date Tustin Community Development Planning Contact: (Less than significant, less than significant with mitigation, potential significant, etc.) -- -- -- Total VMT Reduction (%) A. Is additional VMT modeling required to evaluate impacts? 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. -- -- YES [b] [b] A separate VMT analysis is being prepared and will be submitted concurrently with this VMT screening assessment. David Evans and Associates, Inc. James M. Daisa, PE 17542 17th Street, Suite 150 | Tustin, CA 92780 909.912.7304 Jim.Daisa@DEAINC.com August 20, 2025 ATTACHMENT B (CONTINUED) 355 I I I I I I I I I I I I Zone Home-based VMT per Capita Employment (commute) VMT per employee 782 8.4 19.0 1012 21.1 17.8 1013 10.5 16.7 1015 13.0 17.9 1017 12.4 17.1 1019 22.7 21.3 1020 18.2 18.2 1021 17.6 18.2 1022 16.1 18.2 1023 12.8 17.2 1024 10.7 16.9 1025 8.4 16.5 1026 9.3 16.0 1027 9.5 16.1 1028 9.3 15.8 1029 9.4 17.6 1030 11.0 17.2 1031 9.5 16.3 1032 12.0 15.8 1033 9.0 15.5 1034 12.7 17.6 1035 12.0 17.4 1036 14.1 17.4 1037 13.4 16.2 1038 10.5 16.6 1039 13.1 16.8 1040 12.5 19.1 1041 2.6 15.6 1042 11.4 16.7 1043 12.5 20.0 1044 12.4 21.8 1045 9.1 16.0 1046 11.4 17.6 1047 13.6 20.1 1048 1.9 17.2 1049 0.0 19.4 1050 9.1 19.1 1051 2.8 18.7 1052 0.0 0.0 1053 10.6 18.2 1054 10.8 18.5 1055 0.0 0.0 1056 9.5 35.6 1057 0.0 18.1 ** Note that as OCTAM is updated, these statistics are subject to change. OCTAM 5.1 v.11.22.23 Base Model Year 2019 VMT Statistics * Geography nests into OCTAM zone structure. VMT includes all VMT to/from specified geography, except for VMT that leaves OCTAM model area. 1056 9.5 35.6 ATTACHMENT B (CONTINUED) TAZ-SPECIFIC VMT / CAPITA AND VMT / EMPLOYEE (2019 BASE YEAR OCTAM MODEL VER. 5.1) 356 l J t J ~ J = VMT/Capita ≤ City of Tustin's 2019 Citywide Average VMT/Capita ENGINEERINGGROUP INC. Exhibit D Low VMT Areas VMT Per Capita VMT ANALYSIS GUIDELINES //CITY OF TUSTIN Legend = City of Tustin Boundary = VMT/Capita ≤ City of Tustin's 2019 Citywide Average VMT/Capita E hibit D Legend = City of TustinBoundary Sant a A n a I - 5 F r e e w a y Sa n t a A n a I - 5 F r e e w a y Bry a n A v e n u e Irvi n e B o u l e v a r d Tustin Ranc h R o a d Jamboree R oa d Jamboree R oa d SR-2614th StreetTustin AvenueProspect Avenue17th Street Santa Clara Avenue SR-55Esplanade AvenueMain Street 1st Street McFadden Avenue Syc a m o r e Av e n u e Ed i n g e r A v e n u e Dr i v e W a r n e r A v e n u e Ba r r a n c a P a r k w a y Dyer Road Warner Avenue SR-55 Red Hill Av en ue Red Hill Av enue Armstr o n g Aven u e Moffet Newport AvenueSk y l i n e D r i v e Browni ng Ave nu e Harvard AvenueN ATTACHMENT B (CONTINUED) MAP OF LOW-VMT AREAS BASED ON CITYWIDE AVERAGE VMT / CAPITA (2019 BASE YEAR OCTAM MODEL VER. 5.1) PROJECT TAZ 357 ///////////////// RI< I ////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////// = VMT/Employee ≤ City of Tustin's 2019 Citywide Average VMT/Employee ENGINEERINGGROUP INC. Exhibit E Low VMT Areas VMT Per Employee VMT ANALYSIS GUIDELINES //CITY OF TUSTIN = City of Tustin Boundary = VMT/Employee ≤ City of Tustin's 2019 Citywide Average VMT/Employee E hibit E = City of TustinBoundary Legend Sant a A n a I - 5 F r e e w a y Sa n t a A n a I - 5 F r e e w a y Bry a n A v e n u e Irvi n e B o u l e v a r d Tustin Ranc h R o a d Jamboree R oa d Jamboree R oa d SR-2614th StreetTustin AvenueProspect Avenue17th Street Santa Clara Avenue SR-55Esplanade AvenueMain Street 1st Street McFadden Avenue Syc a m o r e Av e n u e Ed i n g e r A v e n u e Dr i v e W a r n e r A v e n u e Ba r r a n c a P a r k w a y Dyer Road Warner Avenue SR-55 Red Hill Av en ue Red Hill Av enue Armstr o n g Aven u e Moffet Newport AvenueSk y l i n e D r i v e Browni ng Ave nu e Harvard AvenueN ATTACHMENT B (CONTINUED) MAP OF LOW-VMT AREAS BASED ON CITYWIDE AVERAGE VMT / EMPLOYEE (2019 BASE YEAR OCTAM MODEL VER. 5.1) PROJECT TAZ 358 ///////////////// RI< I ////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////// 1 t +1 213 267 2332 | f +1 213 318 0744 info@gentecsol.com | www.gentecsol.com 11845 W Olympic Blvd. 11th Floor, Los Angeles, CA 90017 GTS | General Technologies and Solutions MEMORANDUM Date: October 6, 2025 GTS:250805 To: Jim Daisa, DEA From: Rawad Hani, GTS Subject: Vehicle Miles Traveled (VMT) Analysis – Clearwater at Tustin Legacy Active Adult and Assisted Living Development, City of Tustin, CA This memorandum describes the development of vehicle miles traveled (VMT) analysis for the proposed Clearwater at Tustin Legacy Active Adult and Assisted Living Development (project) in the City of Tustin (City), CA. The project is located on the southeast corner of Warner Avenue and Armstrong Avenue in the City of Tustin, California. The project is a senior living community within the Tustin Legacy Specific Plan designed to promote both independence and care of the project’s residents with two distinct yet Interconnected buildings. The project includes a five-story Active Adult residence building on the western half of the site and a two-story Assisted Living and Memory Care facility on the eastern half. The VMT analysis evaluated the project using travel model obtained from Orange County Transportation Authority (OCTA). Background On December 28, 2018, the California Office of Administrative Law cleared the revised California Environmental Quality Act (CEQA) guidelines for use. Among the changes to the guidelines was removal of vehicle delay and level of service from consideration under CEQA. With the adopted guidelines, transportation impacts are to be evaluated based on a project’s effect on vehicle miles traveled (VMT). Methodology The project VMT analysis was conducted using the City of Tustin’s “City of Tustin Vehicle Miles Traveled Analysis Guidelines – March 2024” (guidelines). The City recently updated project screening forms for land use projects and the low VMT screening maps based on most recent version of travel model from OCTA – OCTAM 5.1. Based on the information provided by the City, the guidelines remained unchanged, with the exception of the screening forms and maps. The guidelines included project screening criteria which were reviewed for project evaluation. This project was compared with screening criteria established in the guidelines to check if the project can be screened out of a detailed VMT analysis. Evaluation of the screening criteria is described below: Affordable Housing: Based on the guidelines, projects that consist of 100% affordable housing can be screened out of a detailed VMT analysis. The project is not an affordable housing project and therefore, the project cannot be screened out using this criterion. High Quality Transit Screening: The guidelines establish that projects that are located within one half (1/2) mile of an existing major transit stop or an existing stop along a high-quality transit corridor will have 359 Clearwater at Tustin Legacy, City of Tustin, CA Vehicle Miles Traveled (VMT) Analysis 2 a less than significant impact on VMT. The project is not located within ½ mile of existing major transit stop and therefore, this screening criterion is not applicable for the project. Local Serving Land Uses Screening: The guidelines identify specific land uses that qualify as local- serving. Since the proposed project does not fall under any of these categories, it cannot be classified as a local-serving use. As a result, the project is not eligible to be screened out and requires a detailed VMT analysis. Low VMT Area Screening: The guidelines recommend that projects that are located within low VMT area based on the VMT screening map can be screened out of detailed VMT analysis. Based on the most recent version of low-VMT area maps (using OCTAM 5.1), the non-residential component of the project is not located in a low VMT area based on the screening map (VMT per employee) and therefore this screening criterion is not applicable for the project. As described above, the entire project doesn’t meet any of the screening criteria identified in the guidelines. Hence, a full VMT analysis was conducted using the most recent version of Orange County Transportation Analysis Model (OCTAM) – OCTAM 5.1 same as the version used for the most recent screening forms and maps in the City’s guidelines. Model Approach OCTAM is a socioeconomic data based model and so the project land use must be converted into model socioeconomic data categories for modeling purposes. The project includes Active Adult residential units, as well as assisted living and memory care facilities—land uses that do not fit typical development categories. To assist with land use conversion, the project team provided information on potential tenant types for the Active Adult housing and the number of employees for the assisted living and memory care components. Since residents of assisted living and memory care facilities are assumed not to generate trips independently, employee trips and associated VMT are expected to represent the majority of project- related travel. Accordingly, the Active Adult housing was treated as a residential land use, while the assisted living and memory care facilities were categorized as non-residential/non-retail land uses for modeling purposes. The project consisted of 172 active adult residential units, including studios, one-bedroom, and two- bedroom apartments. For the purposes of modeling the following assumptions were used. - A total 104 studios and one-bedroom units. - Total of 68 two-bedroom apartments. - An average household size of 1 person was used for studios and one-bed rooms whereas an average household size of 1.5 persons was used for two bedroom apartments. - Given the units are active adult units, it was assumed that 20% of total population will still be employed. - The average household income of City of Tustin was used as the median household income. As previously mentioned, the assisted living and memory care facility were assumed as non-residential land use. Based on information provided by the project team, a total of 65 full time equivalent employees 360 Clearwater at Tustin Legacy, City of Tustin, CA Vehicle Miles Traveled (VMT) Analysis 3 are assumed at the assisted living and memory care facility. A total of 5 employees were assumed for the active adult housing for a total of 70 employees for the project. Based on the guidelines, land use projects should evaluate both base year and horizon year project generated VMT to identify project’s VMT impact. However, the guidelines recommend using OCTAM future/horizon year to establish project VMT impacts for projects that are located with Tustin Legacy Specific Plan area (Section 3.2 - Mitigating Impacts Using the VMT Screening Form, page 8 footnote) due to lack of residential and employment development in OCTAM base year scenario. As previously noted, the project is located within Tustin Legacy Specific Plan and therefore, project VMT modeling was conducted using OCTAM 5.1 future/horizon year of 2050. OCTAM socioeconomic database for the future/horizon year was updated with the project land use to calculate project VMT. Typically, project VMT is calculated by isolating the project in a new TAZ or multiple TAZs depending on the diversity of project land uses and project size. Since OCTAM does not allow addition of new TAZs, two TAZs (one TAZ for project residential use, one TAZ for project non- residential use) were borrowed for modeling this project. Non-project related land use for the borrowed TAZ was moved to an adjacent TAZ and only project land use was included for the borrowed TAZ. The project TAZ was utilized to calculate land use specific VMT metrics for the project. No project specific network modifications were conducted for the horizon scenario. Full model run with feedback loops was conducted for the project scenario. It should be noted that the project land use was included in the model as additional land use in the cumulative (2050) scenario and no redistribution of land use growth from other TAZs was conducted. VMT Analysis The guidelines recommend use of VMT per capita to evaluate residential land uses whereas VMT per employee for non-residential land use projects. The VMT per capita includes VMT generated by all home- based trips (productions) whereas VMT generated by homebased work trips (attractions) is used to estimate VMT per employee. Also, the guidelines established that a significant transportation impact occurs if project VMT per capita exceeds base year average VMT per capita for the City of Tustin. Similarly, the project would have significant impact if the project VMT per employee exceeds base year average VMT per employee for the City of Tustin. Therefore, the project VMT per capita for the future/horizon year was compared with base year City of Tustin VMT per capita. Similarly, project VMT per employee was compared with the base year City of Tustin VMT per employee to determine project’s VMT impact. The base year City of Tustin VMT per capita and VMT per employee thresholds were obtained from the most recent screening forms. Table 1 below shows the 2050 project VMT per capita and VMT per employee metrics along with regional VMT thresholds. 361 Clearwater at Tustin Legacy, City of Tustin, CA Vehicle Miles Traveled (VMT) Analysis 4 Table 1: Project VMT analysis 2050 Clear Water at Tustin Legacy (Project) City of Tustin* Households - Population 206 - Employment 70 - Homebased (HB) VMT 1,219 Homebased Work (HBW) VMT 1,157 - HB VMT per capita 5.9 12.4 HBW VMT per employee 16.5 17.3 *: Obtained from the most recent City of Tustin VMT Screening Form for Land Use project. Dated: March 26, 2025 Conclusion Based on the VMT analysis as illustrated in Table 1, the project generated VMT per capita and VMT per employee for both residential and non-residential components of the project are lower than base year City of Tustin’s VMT per capita and VMT per employee respectively. Therefore, the project doesn’t constitute a significant VMT impact. 362 352-(&7'(6&5,37,21&/($5:$7(5$77867,1/(*$&<,6$3/$11('6(1,25/,9,1*&20081,7<'(6,*1('72352027(%27+,1'(3(1'(1&($1'&$5(7+528*+7:2',67,1&7<(7,17(5&211(&7('%8,/',1*6/2&$7('21$&251(56,7(7+('(9(/230(17,1&/8'(6$),9(6725<$&7,9($'8/75(6,'(1&(217+(:(67(51+$/)2)7+(6,7($1'$7:26725<$66,67('/,9,1*$1'0(025<&$5()$&,/,7<217+(($67(51+$/)%(7:((17+(7:26758&785(6$%28/(9$5'67</((175<:$<:(/&20(65(6,'(176$1'9,6,7256727+($&7,9($'8/7%8,/',1*$1'6+$5('$0(1,7,(6$77+($66,67('/,9,1*%8,/',1*($&+%8,/',1*0$,17$,16,762:1'(',&$7('(175$1&(³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confluent CLEARWATER t development uv1NG f.c,,ot,1 ::-~ .... ~ ._1 J • U,-,5-CA°'-C,, T ... c;, 0,-C-IJ "--OIi~• IYa,,,..'I~ --/ ' I I ........ I """'·· J i -ca~ E:B II $33/,&$%/(&2'(6 &$/,)251,$&2'(2)5(*8/$7,216&&57,7/(3$57&$/,)251,$$'0,1,675$7,9(&2'(&&57,7/(3$57&$/,)251,$%8,/',1*&2'(&&57,7/(>,17(51$7,21$/%8,/',1*&2'(2)7+(,17(51$7,21$/&2'(&281&,/,&&Z&$/,)251,$$0(1'0(176 &,7<2)7867,1$0(1'0(176 25'12 >3$57&$/,)251,$(/(&75,&$/&2'(&&57,7/( 1$7,21$/(/(&75,&$/&2'(2)7+(1$7,21$/),5(3527(&7,21$662&,$7,211)3$ 3$57&$/,)251,$0(&+$1,&$/&2'(&&57,7/( 81,)2500(&+$1,&$/&2'(2)7+(,17(51$7,21$/$662&,$7,212)3/80%,1*$1'0(&+$1,&$/2)),&,$/6,$302 3$57&$/,)251,$3/80%,1*&2'(&&57,7/( 81,)2503/80%,1*&2'(2)7+(,17(51$7,21$/$662&,$7,212)3/80%,1*$1'0(&+$1,&$/2)),&,$/6,$302 3$57&$/,)251,$(1(5*<&2'(&&57,7/(3$57&$/,)251,$),5(&2'(&&57,7/( ,17(51$7,21$/),5(&2'(2)7+(,17(51$7,21$/&2'(&281&,/,&& 3$57&$/,)251,$*5((1%8,/',1*67$1'$5'6&2'( &$/*UHHQ&2'( &&57,7/(3$57&$/,)251,$5()(5(1&('67$1'$5'6&2'(&&57,7/( 7867,1&2'(2)25',1$1&(6$57,&/(%8,/',1*5(*8/$7,216$57,&/(/$1'86( 7867,1/(*$&<63(&,),&3/$125',1$1&( 3$57,$//,672)$33/,&$%/(67$1'$5'6 1)3$3257$%/(),5((;7,1*8,6+(56 (',7,211)3$,167$//$7,212)635,1./(56<67(06 (',7,211)3$,167$//$7,212)67$1'3,3( +26(6<67(06 &$$0(1'(' (',7,211)3$,167$//$7,212)67$7,21$5<38036)25),5(3527(&7,21 (',7,211)3$35,9$7(),5(0$,16 7+(,5$33857(1$1&(6 &$$0(1'(' (',7,211)3$1$7,21$/(/(&75,&$/&2'( (',7,211)3$1$7,21$/),5($/$50$1'6,*1$/,1*&2'( &$$0(1'(' (',7,211)3$),5('2256$1'27+(523(1,1*3527(&7,9(6 (',7,211)3$$67$1'$5')253$5.,1*6758&785(6 1275()(5(1&('1)3$$,167$//$7,212)$,5&21',7,21,1* 9(17,/$7,216<67(06 1275()(5(1&('1)3$/,)(6$)(7<&2'( (',7,211)3$602.('225$66(0%/,(6 27+(523(1,1*3527(&7,9(6 (',7,211)3$(0(5*(1&< 67$1'%<32:(56<67(06 (',7,211)3$7<3(62)%8,/',1*&216758&7,21 1275()(5(1&('1)3$0(7+2'62)),5(7(6762)'225$66(0%/,(6 (',7,211)3$&5,7,&$/5$',$17)/8;2))/225&29(5,1*6<67(06 (',7,21 &%&5()(5(1&( 2&&83$1&<*5283 66(& 7<3(2)&216758&7,21 ,$6(& ),5(635,1./(56<67(0 )8//$8720$7,&635,1./(56<67(07+528*+287%8,/',1*$5($3(51)3$ %8,/',1*+(,*+7 $//2:$%/(%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(*52836$1'% 635,1./(5('  81/,0,7(' $&78$/%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(  7$%/( $&7,9($'8/73$5.,1**$5$*( $//2:$%/(180%(52)6725,(6$%29(*5$'(3/$1(*52836$1'% 635,1./(5('  81/,0,7(' $&78$/180%(52)6725,(6$%29(*5$'(3/$1(  7$%/( %8,/',1*$5($$//2:$%/(%8,/',1*$5($3(56725<*52836$1'% 6  81/,0,7(' $&78$/%8,/',1*$5($)/225 6%727$/),567)/225 6) 6)6) 7$%/( ),5(5(6,67$1&(5$7,1*5(48,5(0(176 7$%/(%8,/',1*(/(0(17 ),5(5(6,67$1&(5$7,1* 35,0$5<6758&785$/)5$0(+2856 %($5,1*:$//6(;7(5,25,17(5,25 +2856+2856 121%($5,1*:$//6$1'3$57,7,216(;7(5,25,17(5,25 6((7$%/(%(/2:+2856 )/225&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +2856 522)&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +2856 7$%/( ),5(6(3$5$7,21',67$1&(5$7,1*)2552&&83$1&< ;   ;   ; ;!  +285+285+285+2856 2&&83$1&<*5283 $$ ),5676(&21'$1'7+,5')/2256 56(&21'7+528*+),)7+)/225 6(&6(& 6(& %),567$1'6(&21')/2256 6(& 7<3(2)&216758&7,21 9$R6,1*/(6725<$32',80&216758&7,21 6(&6(& ),5(635,1./(56<67(0 )8//$8720$7,&635,1./(56<67(07+528*+287%8,/',1*$5($3(51)3$6(&6(& %8,/',1*+(,*+7 $//2:$%/(%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(*5283$ 635,1./(5('Z$5($,1&5($6(   *52835 635,1./(5('Z$5($,1&5($6(   $&78$/%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(  $$2&&83$1&,(6/,0,7('72 7$%/( $&7,9($'8/7 $//2:$%/(180%(52)6725,(6$%29(32',803$5.,1**$5$*(*5283$$ 635,1./(5('Z$5($,1&5($6(  *52835 635,1./(5('Z$5($,1&5($6(   $&78$/180%(52)6725,(6$%29(32',803$5.,1**$5$*(  $$2&&83$1&,(6/,0,7('727+,5')/225 7$%/(6(& 6(& &%&5()(5(1&( %6(& 7$%/(6(& $&&(6625< *52836 6(& %8,/',1*$5($$//2:$%/($5($5$7,2&$/&8/$7,21 $&7,9($'8/7 &217 ' &%&5()(5(1&( ),5($5($6 7$%/(7$%/(127(D6(& 7+(),5(%$55,(56),5(:$//6+25,=217$/$66(0%/,(625&20%,1$7,2167+(5(2)6(3$5$7,1*$6,1*/(2&&83$1&<,172',))(5(17),5($5($66+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$17+$7,1',&$7(',17$%/(7+(),5(%$55,(56),5(:$//6+25,=217$/$66(0%/,(625&20%,1$7,2167+(5(2)6(3$5$7,1*),5($5($62)0,;('2&&83$1&,(66+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$17+(+,*+(679$/8(,1',&$7(',17$%/()257+(2&&83$1&,(681'(5&216,'(5$7,21 )25*5283$%$1'52&&83$1&,(6$0,1,080+285),5(5(6,67$1&(5$7,1*,65(48,5(' 81,76(3$5$7,21:$//6 6(&6(&:$//66(3$5$7,1*':(//,1*81,76,17+(6$0(%8,/',1*:$//66(3$5$7,1*6/((3,1*81,76,17+(6$0(%8,/',1*$1':$//66(3$5$7,1*':(//,1*256/((3,1*81,76)52027+(52&&83$1&,(6&217,*8286727+(0,17+(6$0(%8,/',1*6+$//%(&216758&7('$6),5(3$57,7,216,1$&&25'$1&(:,7+6(&7,21 +25,=217$/81,76(3$5$7,21 6(&6(&)/225$66(0%/,(66(3$5$7,1*':(//,1*81,76,17+(6$0(%8,/',1*6)/225$66(0%/,(66(3$5$7,1*6/((3,1*81,76,17+(6$0(%8,/',1*$1')/225$66(0%/,(66(3$5$7,1*':(//,1*256/((3,1*81,76)52027+(52&&83$1&,(6&217,*8286727+(0,17+(6$0(%8,/',1*6+$//%(&216758&7('$6+25,=217$/$66(0%/,(6,1$&&25'$1&(:,7+6(&7,21 ),5(5(6,67$1&(5$7,1*5(48,5(0(176 7$%/(%8,/',1*(/(0(17 ),5(5(6,67$1&(5$7,1* 35,0$5<6758&785$/)5$0(+285%($5,1*:$//6(;7(5,25,17(5,25 +285+285 121%($5,1*:$//6$1'3$57,7,216(;7(5,25,17(5,25 6((7$%/(%(/2:+2856 )/225&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +285 522)&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +285 7$%/( ),5(6(3$5$7,21',67$1&( 5$7,1*)25$% 52&&83$1&< ;   ;   ; ;!  +285+285+285+2856 +25,=217$/%8,/',1*6(3$5$7,21 7+($&7,9($'8/7%8,/',1*,6&216,'(5('$66(3$5$7($1'',67,1&7)5207+(3$5.,1**$5$*()257+(385326(2)'(7(50,1,1*$5($/,0,7$7,216&217,18,7<2)),5(:$//6/,0,7$7,212)180%(52)6725,(6$1'7<3(2)&216758&7,216,1&(7+()2//2:,1*&21',7,216$5(0(7  7+(%8,/',1*6$5(6(3$5$7(':,7+$+25,=217$/$66(0%/<+$9,1*$),5(5(6,67$1&(5$7,1*2)127/(667+$1+2856:+(5(9(57,&$/2))6(76$5(3529,'('$63$572)$+25,=217$/$66(0%/<7+(9(57,&$/2))6(7$1'7+(6758&785(6833257,1*7+(9(57,&$/2))6(76+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$1+2856 7+(%8,/',1*%(/2:,1&/8',1*7+(+25,=217$/$66(0%/<,62)7<3(,$&216758&7,21 6+$)767$,5:$<5$03$1'(6&$/$725(1&/2685(67+528*+7+(+25,=217$/$66(0%/<6+$//+$9(127/(667+$1$+285),5(5(6,67$1&(5$7,1*:,7+23(1,1*3527(&7,9(6,1$&&25'$1&(:,7+6(&7,21 ,17(5,25(;,767$,5:$<6/2&$7(':,7+,17+(7<3(,$%8,/',1*$5(3(50,77('72%(2)&20%867,%/(0$7(5,$/66,1&(7+()2//2:,1*5(48,5(0(176$5(0(7D 7+(%8,/',1*$%29(7+(7<3(,$%8,/',1*,62)7<3(9&216758&7,21E 7+(67$,5:$</2&$7(',17+(7<3(,$%8,/',1*,6(1&/26('%<+285),5(5(6,67$1&(5$7('&216758&7,21:,7+23(1,1*3527(&7,9(6,1$&&25'$1&(:,7+6(&7,21 7+(%8,/',1*6$%29(7+(+25,=217$/$66(0%/<$5(3(50,77('72+$9(08/7,3/(*5283$2&&83$1&<86(6($&+:,7+$12&&83$17/2$'2)/(667+$125*5283%052562&&83$1&,(6 7+(%8,/',1*%(/2:7+(+25,=217$/$66(0%/<:,//%(3527(&7('7+528*+287%<$1$33529('$8720$7,&635,1./(56<67(0,1$&&25'$1&(:,7+6(&7,21$1',63(50,77('72%($1<2&&83$1&<$//2:('%<7+,6&2'((;&(37*5283+ 7+(0$;,080%8,/',1*+(,*+7,1)((76+$//127(;&(('7+(/,0,766(7)257+,16(&7,21)257+(%8,/',1*+$9,1*7+(60$//(5$//2:$%/(+(,*+7$60($685(')5207+(*5$'(3/$1( 6(($&7,9($'8/7),5($5($3/$16217+,66+((7 6(& $5($)$&725,1&5($6(%$6('21!)5217$*(21$//)/22563(57$%/( %8,/',1*48$/,),(6)25$5($)$&725,1&5($6(%$6('21!)5217$*(3(57$%/(%87$5($)$&725,1&5($6(,61(,7+(55(48,5('125$33/,(' $5($)$&725,1&5($6(%$6('21!)5217$*(3(57$%/( 81/,0,7('$5($2)1215$7('23(1,1*6$//2:('3(5)227127(J 81/,0,7('$5($2)1215$7('23(1,1*6$//2:('3(5)227127(J 6((6+((7$$$)25$&7,9($'8/73$5.,1**$5$*(3/$1'(0$1' 3(5&,7<2)7867,1&2'(2)25',1$1&(6$57,&/(3$576(&63$&(6 63$&(81,7*8(6763$&(81,76  3529,'(' 67$1'$5'63$&(6#3$5.,1**$5$*( 63$&(667$1'$5'63$&(6#685)$&(3$5.,1* 63$&(663$&(6&203$&763$&(6#3$5.,1**$5$*(   [   63$&(6727$/63$&(6 $&&(66,%/(63$&(65(48,5(' 3(5&(172)727$/63$&(672%($&&(66,%/( 3(5&%&6(&$ #3$5.,1**$5$*( [ $&&(66,%/(63$&(6#685)$&(3$5.,1* [ $&&(66,%/(63$&(63529,'(9$1$&&(66,%/(63$&()25(9(5<$&&(66,%/(63$&(6 3(5&%&6(&$ 3529,'(' #3$5.,1**$5$*( $&&(66,%/(63$&(6 ,1&/8',1*9$163$&(6 #685)$&(3$5.,1* $&&(66,%/(63$&(6 ,1&/8',1*9$163$&( (/(&75,&9(+,&/(63$&(63(5&$/*5((16(&5(48,5(' (95($'< (95 ,13/$1 2)727$/63$&(6#3$5.,1**$5$*( [ /2:32:(5/(9(/5(&(37$&/(6#685)$&(3$5.,1* [ /2:32:(5/(9(/5(&(37$&/(6 (9&+$5*(56 (9&6 ,13/$1 2)727$/63$&(6#3$5.,1**$5$*( [ /(9(/(9&+$5*(563529,'(9$1$&&(66,%/((9&6>3(5&$/*5((1  @#685)$&(3$5.,1* [ /(9(/(9&+$5*(563529,'(9$1$&&(66,%/((9&6 3(5&%&7$%/(% 3529,'(' (95($'< (95 #3$5.,1**$5$*( /2:32:(5/(9(/5(&(37$&/(6#685)$&(3$5.,1* /2:32:(5/(9(/5(&(37$&/(6 (9&+$5*(56 (9&6 #3$5.,1**$5$*( /(9(/(9&+$5*(56 ,1&/8',1*9$1$&&(66,%/(63$&( #685)$&(3$5.,1* /(9(/(9&+$5*(56 ,1&/8',1*9$1$&&(66,%/(63$&( 6+2577(50%,&<&/(3$5.,1*1275(48,5('3(5&$/*5((16(& /21*7(50%,&<&/(3$5.,1*3(5&$/*5((16(&5(48,5(' 7%' 3529,'(' 7%' 3(57867,1/(*$&<63(&,),&3/$1 25',1$1&( 6(& '(9(/230(1767$1'$5'6)253/$11,1*$5($6  7$%/(6,7(&21),*85$7,215(*8/$7,216/27$5($ 5(6,'(17,$/  %8,/',1*6(7%$&.6$5067521*$9(18(:$51(5$9(18(/2&$/52$' ',67$1&(%(7:((1%8,/',1*$1'$&&(6625<6758&785( 0,1,080121( 0,1,080       0,1,080   0$;,080121( 0$;,080121(121(121( 0$;,080121( $&78$/$& 6) 352326('  0,1  0,1  0,1 352326('  0,1 7$%/(%8,/',1*+(,*+75(*8/$7,216%8,/',1*+(,*+7 7$%/()5217$*(&$7(*25,(6*5281')/2255(6,'(17,$/ 7$%/(23(163$&(5(*8/$7,2165(6,'(17,$/ 0,1,080121( )5217$*(7<3(325&+ 7<3(35,9$7(&20021 0$;,080   :$51(53(50,77(' 67$1'$5'6)3(581,76)3(581,7 352326('  0$; $9(522)'(&.+(,*+7 /2&$/&211(&7253(50,77(' 352326('6((7$%/(%(/2:6((7$%/(%(/2: 23(163$&(7<3(35,9$7(5(48,5(0(176)81,7 7$%/(3(50,77('86(5(*8/$7,216 6(59,&(&200(5&,$/ 2)),&( 5(7$,/&200(5&,$/ 38%/,&,167,787,21$/ 3(57867,1&2'(2)25',1$1&(6&+$37(56(&/$1'6&$3(5(48,5(0(176)253$5.,1*$5($6 25'126(&  3(50$1(17/$1'6&$3,1*)25,17(5,253$5.,1*/275(48,5('2),17(5,253$5.,1*/27$5($352326('3(5,0(7(53$5.,1*/27/$1'6&$3,1*$/21*675((7)5217$*(65(48,5('  :,'($/21*0$-25$57(5,$/+,*+:$<352326('1$ 123$5.,1*/27$/21*0$-25$57(5,$/+,*+:$< 86(*(1(5$/6(59,&(%86,1(66 86(*(1(5$/2)),&(0(',&$/2)),&(+($/7+&$5(&(17(5 86(*(1(5$/5(7$,/ 86(&21*5(*$7(&$5($66,67('/,9,1*)$&,/,7<23(163$&(38%/,&35,9$7(5(&5($7,21$/)$&,/,7<38%/,&35,9$7( *5281')/2253(50,77(' *5281')/2253(50,77('3(50,77(' *5281')/2253(50,77(' *5281')/225&21',7,21$/3(50,77('&21',7,21$/ 833(5)/22563(50,77(' 833(5)/22563(50,77('3(50,77(' 833(5)/22563(50,77(' 833(5)/2256&21',7,21$/3(50,77('&21',7,21$/$&7,9($'8/723(163$&(6800$5< &20021 6)81,7 180%(52)81,76 5(48,5('23(163$&( 6) 3529,'(' 6) %(/2:5(48,5(' 1$ $9(5$*(%$/&21<6,=(81,76 81,76 (;&/81,76ZR 6)1$ ‡ ),5(635,1./(568335(66,216<67(0 ),5(021,725,1*$/$506<67(0‡ 67((/67$,56‡(/(9$7256<67(06‡6:,00,1*322/‡ 3+27292/7$,&6<67(0‡ (0(5*(1&<5(6321'(55$',2&29(5$*(‡6,7(6,*1$*( %8,/',1*6) %8,/',1*6)%8,/',1*6) %8,/',1*%8,/',1*%8,/',1*+55$7('),5(:$// %8,/',1*6) %8,/',1*6)%8,/',1*6) %8,/',1*%8,/',1*%8,/',1*+55$7('),5(:$// %8,/',1*6) %8,/',1*6)%8,/',1*6) %8,/',1*%8,/',1*%8,/',1*+55$7('),5(:$// %8,/',1*%8,/',1*%8,/',1* %8,/',1*6) %8,/',1*6)%8,/',1*6) +55$7('),5(:$// &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ&OHDUZDWHUB7XVWLQB6LWHB5UYW30ACTIVE ADULTPROJECT DATA ANDCODE ANALYSIS G-131 &/($5:$7(5$77867,1/(*$&< $&7,9($'8/7685)$&(3$5.,1* 7<3( &2817$&&(66,%/( (9&+$5*(5 (95($'< 67$1'$5' 9$1$&& 9$1$&&(9&+$5*(5 $$685)$&(3$5.,1*727$/ $&7,9($'8/73$5.,1**$5$*( 7<3( &2817$&&(66,%/( (9&+$5*(5 (95($'< 67$1'$5' 7$1'(067$1'$5' 9$1$&& 9$1$&&(9&+$5*(5 $$67$1'$5'3$5.,1*727$/ *29(51,1*&2'(6$1'67$1'$5'6 $&7,9($'8/7352-(&7'$7$ 122)81,7681,762&&83$1&<*52836 5$%122)6725,(66725,(6R6725<3$5.,1**$5$*(&216758&7,217<3( 7<3(9$:22')5$0(&216758&7,21R7<3(,$&21&5(7(&216758&7,213$5.,1**$5$*(*5266)/225$5($6) &2002123(163$&(6(($&7,9($'8/723(163$&(6800$5<81'(5 /2&$/=21,1*&2'(&203/,$1&( 217+,66+((7 /2&$/=21,1*&2'(&203/,$1&( 2$6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)   )/5 02675(675,&7,9(2&&*5283 $//2:$%/($5($ $W 7$%/( )5217$*(,1&5($6( 727$/$//2:$%/($5($3(5)/225 $&78$/%8,/',1*$5($5$7,2 $&7,9($'8/7%8,/',1* 7<3(9$&216758&7,21 2$6)    5 6) 1$ 6) 6)    5 6) 1$ 6) 6)    5 6) 1$ 6) 6)    5 6) 1$ 6) 6)   )/5 02675(675,&7,9(2&&*5283 $//2:$%/($5($ $W 7$%/( )5217$*(,1&5($6( 727$/$//2:$%/($5($3(5)/225 $&78$/%8,/',1*$5($5$7,2 $&7,9($'8/7%8,/',1* 7<3(9$&216758&7,21 2$6)    5 6) 6) 6) 6)    5 6) 6) 6) 6)    $$ 6) 6) 6) 6)    $$ 6) 6) 6) 6)   )/5 02675(675,&7,9(2&&*5283 $//2:$%/($5($ $W 7$%/( )5217$*(,1&5($6( 727$/$//2:$%/($5($3(5)/225 $&78$/%8,/',1*$5($5$7,2 $&7,9($'8/7%8,/',1* 7<3(9$&216758&7,21 $$&203$&73$5.,1*727$/$$3$5.,1*727$/  '()(55('68%0,77$/6 $&7,9($'8/73$5.,1*$1$/<6,6 $&7,9($'8/7%8,/',1*&2'($1$/<6,6$&7,9($'8/7),5($5($3/$16 6&$/(  6(&21')/225),5($5($3/$1 6&$/(  7+,5')/225),5($5($3/$1 6&$/(  )2857+)/225),5($5($3/$1 6&$/(  ),)7+)/225),5($5($3/$1 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 04.02.2026 364 □ □ ■ □ □ □ □ ■ □ □ ■ ■ ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 San Diego 858.203.4999 ~ CLEARWATER LIVING r. f.?n~J!Y;~R~ 0 $33/,&$%/(&2'(6 &$/,)251,$&2'(2)5(*8/$7,216&&57,7/(3$57&$/,)251,$$'0,1,675$7,9(&2'(&&57,7/(3$57&$/,)251,$%8,/',1*&2'(&&57,7/(>,17(51$7,21$/%8,/',1*&2'(2)7+(,17(51$7,21$/&2'(&281&,/,&&Z&$/,)251,$$0(1'0(176 &,7<2)7867,1$0(1'0(176 25'12 >3$57&$/,)251,$(/(&75,&$/&2'(&&57,7/( 1$7,21$/(/(&75,&$/&2'(2)7+(1$7,21$/),5(3527(&7,21$662&,$7,211)3$ 3$57&$/,)251,$0(&+$1,&$/&2'(&&57,7/( 81,)2500(&+$1,&$/&2'(2)7+(,17(51$7,21$/$662&,$7,212)3/80%,1*$1'0(&+$1,&$/2)),&,$/6,$302 3$57&$/,)251,$3/80%,1*&2'(&&57,7/( 81,)2503/80%,1*&2'(2)7+(,17(51$7,21$/$662&,$7,212)3/80%,1*$1'0(&+$1,&$/2)),&,$/6,$302 3$57&$/,)251,$(1(5*<&2'(&&57,7/(3$57&$/,)251,$),5(&2'(&&57,7/( ,17(51$7,21$/),5(&2'(2)7+(,17(51$7,21$/&2'(&281&,/,&& 3$57&$/,)251,$*5((1%8,/',1*67$1'$5'6&2'( &$/*UHHQ&2'( &&57,7/(3$57&$/,)251,$5()(5(1&('67$1'$5'6&2'(&&57,7/( 7867,1&2'(2)25',1$1&(6$57,&/(%8,/',1*5(*8/$7,216$57,&/(/$1'86( 7867,1/(*$&<63(&,),&3/$125',1$1&( 3$57,$//,672)$33/,&$%/(67$1'$5'6 1)3$3257$%/(),5((;7,1*8,6+(56 (',7,211)3$,167$//$7,212)635,1./(56<67(06 (',7,211)3$,167$//$7,212)67$1'3,3( +26(6<67(06 &$$0(1'(' (',7,211)3$,167$//$7,212)67$7,21$5<38036)25),5(3527(&7,21 (',7,211)3$35,9$7(),5(0$,16 7+(,5$33857(1$1&(6 &$$0(1'(' (',7,211)3$1$7,21$/(/(&75,&$/&2'( (',7,211)3$1$7,21$/),5($/$50$1'6,*1$/,1*&2'( &$$0(1'(' (',7,211)3$),5('2256$1'27+(523(1,1*3527(&7,9(6 (',7,211)3$$67$1'$5')253$5.,1*6758&785(6 1275()(5(1&('1)3$$,167$//$7,212)$,5&21',7,21,1* 9(17,/$7,216<67(06 1275()(5(1&('1)3$/,)(6$)(7<&2'( (',7,211)3$602.('225$66(0%/,(6 27+(523(1,1*3527(&7,9(6 (',7,211)3$(0(5*(1&< 67$1'%<32:(56<67(06 (',7,211)3$7<3(62)%8,/',1*&216758&7,21 1275()(5(1&('1)3$0(7+2'62)),5(7(6762)'225$66(0%/,(6 (',7,211)3$&5,7,&$/5$',$17)/8;2))/225&29(5,1*6<67(06 (',7,21 &%&5()(5(1&( 2&&83$1&<*5283 $$ ),567$1'6(&21')/2256 5 ),567$1'6(&21')/2256 6(&6(& 6(& % ),567$1'6(&21')/2256 6(& 7<3(2)&216758&7,21 9$$1'9$R6,1*/(6725<$32',80&216758&7,21 6(&6(& ),5(635,1./(56<67(0 )8//$8720$7,&635,1./(56<67(07+528*+287%8,/',1*$5($3(51)3$ %8,/',1*+(,*+7 $//2:$%/(%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(*5283$ 635,1./(5('Z$5($,1&5($6(   *52835 635,1./(5('   $&78$/%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(  7$%/( $66,67('/,9,1* $//2:$%/(180%(52)6725,(6$%29(*5$'(3/$1(*5283$$ 635,1./(5('Z$5($,1&5($6(  *52835 635,1./(5('   $&78$/180%(52)6725,(6$%29(*5$'(3/$1(  7$%/(6(& %8,/',1*$5($$//2:$%/($5($5$7,2&$/&8/$7,21 7$%/( 6(&6(& $&&(6625<*52836 6(& &%&5()(5(1&( 2&&83$1&<*5283 66(&7<3(2)&216758&7,21 ,$6(& ),5(635,1./(56<67(0 )8//$8720$7,&635,1./(56<67(07+528*+287%8,/',1*$5($3(51)3$ %8,/',1*+(,*+7 $//2:$%/(%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1(*52836 635,1./(5(' 81/,0,7(' $&78$/%8,/',1*+(,*+7,1)((7$%29(*5$'(3/$1( 7$%/( $66,67('/,9,1*3$5.,1**$5$*( $//2:$%/(180%(52)6725,(6$%29(*5$'(3/$1(*52836 635,1./(5(' 81/,0,7(' $&78$/180%(52)6725,(6$%29(*5$'(3/$1( 7$%/( %8,/',1*$5($$//2:$%/(%8,/',1*$5($3(56725<*5283681/,0,7(' $&78$/%8,/',1*$5($)/225 6727$/),567)/225 6)6) 7$%/( ),5(5(6,67$1&(5$7,1*5(48,5(0(176 7$%/(%8,/',1*(/(0(17 ),5(5(6,67$1&(5$7,1* 35,0$5<6758&785$/)5$0(+2856%($5,1*:$//6(;7(5,25,17(5,25 +2856+2856 121%($5,1*:$//6$1'3$57,7,216(;7(5,25,17(5,25 6((7$%/(%(/2:+2856 )/225&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +2856 522)&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +2856 7$%/( ),5(6(3$5$7,21',67$1&(5$7,1*)2552&&83$1&< ;   ;   ; ;!  +285+285+285+2856 6(& %6(& &%&5()(5(1&($66,67('/,9,1* &217 ' 81,76(3$5$7,21:$//6 6(&6(&:$//66(3$5$7,1*':(//,1*81,76,17+(6$0(%8,/',1*:$//66(3$5$7,1*6/((3,1*81,76,17+(6$0(%8,/',1*$1':$//66(3$5$7,1*':(//,1*256/((3,1*81,76)52027+(52&&83$1&,(6&217,*8286727+(0,17+(6$0(%8,/',1*6+$//%(&216758&7('$6),5(3$57,7,216,1$&&25'$1&(:,7+6(&7,21 +25,=217$/81,76(3$5$7,21 6(&6(&)/225$66(0%/,(66(3$5$7,1*':(//,1*81,76,17+(6$0(%8,/',1*6)/225$66(0%/,(66(3$5$7,1*6/((3,1*81,76,17+(6$0(%8,/',1*$1')/225$66(0%/,(66(3$5$7,1*':(//,1*256/((3,1*81,76)52027+(52&&83$1&,(6&217,*8286727+(0,17+(6$0(%8,/',1*6+$//%(&216758&7('$6+25,=217$/$66(0%/,(6,1$&&25'$1&(:,7+6(&7,21 6(($66,67('/,9,1*),5($5($3/$16217+,66+((7 ),5(5(6,67$1&(5$7,1*5(48,5(0(176 7$%/(%8,/',1*(/(0(17 ),5(5(6,67$1&(5$7,1* 35,0$5<6758&785$/)5$0(+285%($5,1*:$//6(;7(5,25,17(5,25 +285+285 121%($5,1*:$//6$1'3$57,7,216(;7(5,25,17(5,25 6((7$%/(%(/2:+2856 )/225&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +285 522)&216758&7,21$1'$662&,$7('6(&21'$5<6758&785$/0(0%(56 +285 7$%/( ),5(6(3$5$7,21',67$1&( 5$7,1*)25$% 52&&83$1&< ;   ;   ; ;!  +285+285+285+2856 +25,=217$/%8,/',1*6(3$5$7,21 6(&7+($66,67('/,9,1*%8,/',1*,6&216,'(5('$66(3$5$7($1'',67,1&7)5207+(3$5.,1**$5$*()257+(385326(2)'(7(50,1,1*$5($/,0,7$7,216&217,18,7<2)),5(:$//6/,0,7$7,212)180%(52)6725,(6$1'7<3(2)&216758&7,216,1&(7+()2//2:,1*&21',7,216$5(0(7  7+(%8,/',1*6$5(6(3$5$7(':,7+$+25,=217$/$66(0%/<+$9,1*$),5(5(6,67$1&(5$7,1*2)127/(667+$1+2856 7+(%8,/',1*%(/2:,1&/8',1*7+(+25,=217$/$66(0%/<,62)7<3(,$&216758&7,21 6+$)767$,5:$<5$03$1'(6&$/$725(1&/2685(67+528*+7+(+25,=217$/$66(0%/<6+$//+$9(127/(667+$1$+285),5(5(6,67$1&(5$7,1*:,7+23(1,1*3527(&7,9(6,1$&&25'$1&(:,7+6(&7,21 ,17(5,25(;,767$,5:$<6/2&$7(':,7+,17+(7<3(,$%8,/',1*$5(3(50,77('72%(2)&20%867,%/(0$7(5,$/66,1&(7+()2//2:,1*5(48,5(0(176$5(0(7D 7+(%8,/',1*$%29(7+(7<3(,$%8,/',1*,62)7<3(9&216758&7,21E 7+(67$,5:$</2&$7(',17+(7<3(,$%8,/',1*,6(1&/26('%<+285),5(5(6,67$1&(5$7('&216758&7,21:,7+23(1,1*3527(&7,9(6,1$&&25'$1&(:,7+6(&7,21 7+(%8,/',1*6$%29(7+(+25,=217$/$66(0%/<6+$//%(3(50,77('72+$9(08/7,3/(*5283$2&&83$1&<86(6($&+:,7+$12&&83$17/2$'2)/(667+$125*5283%052562&&83$1&,(6 7+(%8,/',1*%(/2:7+(+25,=217$/$66(0%/<6+$//%(3527(&7('7+528*+287%<$1$33529('$8720$7,&635,1./(56<67(0,1$&&25'$1&(:,7+6(&7,21$1'6+$//%(3(50,77('72%($1<2&&83$1&<$//2:('%<7+,6&2'((;&(37*5283+ 7+(0$;,080%8,/',1*+(,*+7,1)((76+$//127(;&(('7+(/,0,766(7)257+,16(&7,21)257+(%8,/',1*+$9,1*7+(60$//(5$//2:$%/(+(,*+7$60($685(')5207+(*5$'(3/$1( ),5($5($6 7$%/(7$%/(127(D6(& 7+(),5(%$55,(56),5(:$//6+25,=217$/$66(0%/,(625&20%,1$7,2167+(5(2)6(3$5$7,1*$6,1*/(2&&83$1&<,172',))(5(17),5($5($66+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$17+$7,1',&$7(',17$%/(7+(),5(%$55,(56),5(:$//6+25,=217$/$66(0%/,(625&20%,1$7,2167+(5(2)6(3$5$7,1*),5($5($62)0,;('2&&83$1&,(66+$//+$9($),5(5(6,67$1&(5$7,1*2)127/(667+$17+(+,*+(679$/8(,1',&$7(',17$%/()257+(2&&83$1&,(681'(5&216,'(5$7,21 602.(%$55,(56 6(&602.(%$55,(566+$//%(3529,'(',1*528357268%',9,'((9(5<6725<86('%<3(562165(&(,9,1*&$5(75($70(17256/((3,1*$1'723529,'(27+(56725,(6:,7+$12&&83$17/2$'2)25025(3(56216,172127)(:(57+$17:2602.(&203$570(17668&+6725,(66+$//%(',9,'(',172602.(&203$570(176:,7+$1$5($2)127025(7+$1648$5()((7 0 $1'7+(',67$1&(2)75$9(/)520$1<32,17,1$602.(&203$570(1772$602.(%$55,(5'2256+$//127(;&((')((7 00 7+(602.(%$55,(56+$//%(,1$&&25'$1&(:,7+6(&7,21 %8,/',1* 6((6+((7* 81/,0,7('$5($2)1215$7('23(1,1*6$//2:('3(5)227127(J $5($)$&725,1&5($6(%$6('21!)5217$*(21$//)/22563(57$%/( %8,/',1*'2(612748$/,)<)25$5($)$&725,1&5($6(%$6('21)5217$*(3(57$%/( $5($)$&725,1&5($6(%$6('21!)5217$*(21$//)/22563(57$%/( 81/,0,7('$5($2)1215$7('23(1,1*6$//2:('3(5)227127(J 6((6+((7$$/)25$66,67('/,9,1*3$5.,1**$5$*(3/$1 '(0$1' 3(5&,7<2)7867,1&2'(2)25',1$1&(6$57,&/(3$576(&63$&(6 63$&(%('6  3529,'(' #3$5.,1**$5$*(63$&(6#685)$&(3$5.,1*63$&(6 $&&(66,%/(63$&(65(48,5(' 3(5&(172)727$/63$&(672%($&&(66,%/( 3(5&%&6(&% % 7$%/(% #3$5.,1**$5$*( [ $&&(66,%/(63$&(6#685)$&(3$5.,1* [ $&&(66,%/(63$&(3529,'(9$1$&&(66,%/(63$&()25(9(5<$&&(66,%/(63$&(6 3(5&%&6(&% 3529,'(' #3$5.,1**$5$*( $&&(66,%/(63$&(6 ,1&/8',1*9$163$&( #685)$&(3$5.,1* 9$1$&&(66,%/(63$&( (/(&75,&9(+,&/(63$&(63(5&$/*5((16(&5(48,5(' (95($'< (95 ,13/$1 2)727$/63$&(6#3$5.,1**$5$*( [ /(9(/5(&(37$&/(6#685)$&(3$5.,1* [ /(9(/5(&(37$&/(6 (9&+$5*(56 (9&6 ,13/$1 2)727$/63$&(6#3$5.,1**$5$*( [ /(9(/(9&+$5*(563529,'(9$1$&&(66,%/((9&6$1'$&&(66,%/((9&6 3(5&%&7$%/(% #685)$&(3$5.,1* [ /(9(/(9&+$5*(53529,'(9$1$&&(66,%/((9&6 3(5&%&7$%/(% 3529,'(' (95($'< (95 #3$5.,1**$5$*( /2:32:(5/(9(/5(&(37$&/(6#685)$&(3$5.,1* /2:32:(5/(9(/5(&(37$&/(6 (9&+$5*(56 (9&6 #3$5.,1**$5$*( /(9(/(9&+$5*(56 ,1&/8',1*9$1$&&(66,%/($1'$&&(66,%/(63$&( #685)$&(3$5.,1* /(9(/(9&+$5*(56 ,1&/8',1*9$1$&&(66,%/(63$&( 6+2577(50%,&<&/(3$5.,1*1275(48,5('3(5&$/*5((16(& /21*7(50%,&<&/(3$5.,1*3(5&$/*5((16(&5(48,5(' 7%'3529,'(' 7%' 3(57867,1/(*$&<63(&,),&3/$1 25',1$1&( 6(& '(9(/230(1767$1'$5'6)253/$11,1*$5($6  7$%/(6,7(&21),*85$7,215(*8/$7,216/27$5($ 5(6,'(17,$/  %8,/',1*6(7%$&.6$5067521*$9(18(:$51(5$9(18(/2&$/52$' ',67$1&(%(7:((1%8,/',1*$1'$&&(6625<6758&785( 7$%/(3(50,77('86(5(*8/$7,216 6(59,&(&200(5&,$/ 2)),&( 5(7$,/&200(5&,$/ 38%/,&,167,787,21$/ 3(57867,1&2'(2)25',1$1&(6&+$37(56(&/$1'6&$3(5(48,5(0(176)253$5.,1*$5($6 25'126(&  3(50$1(17/$1'6&$3,1*)25,17(5,253$5.,1*/275(48,5('2),17(5,253$5.,1*/27$5($352326('3(5,0(7(53$5.,1*/27/$1'6&$3,1*$/21*675((7)5217$*(65(48,5('  :,'($/21*0$-25$57(5,$/+,*+:$<352326('1$ 123$5.,1*/27$/21*0$-25$57(5,$/+,*+:$< 86(*(1(5$/6(59,&(%86,1(66 86(*(1(5$/2)),&(0(',&$/2)),&(+($/7+&$5(&(17(5 86(*(1(5$/5(7$,/ 86(&21*5(*$7(&$5($66,67('/,9,1*)$&,/,7<23(163$&(38%/,&35,9$7(5(&5($7,21$/)$&,/,7<38%/,&35,9$7( *5281')/2253(50,77(' *5281')/2253(50,77('3(50,77(' *5281')/2253(50,77(' *5281')/225&21',7,21$/3(50,77('&21',7,21$/ 833(5)/22563(50,77(' 833(5)/22563(50,77('3(50,77(' 833(5)/22563(50,77(' 833(5)/2256&21',7,21$/3(50,77('&21',7,21$/ 0,1,080121( 0,1,080       0,1,080   0$;,080121( 0$;,080121(121(121( 0$;,080121( $&78$/$& 6) 352326('  0,1  0,1  0,1 352326('  0,1 7$%/(%8,/',1*+(,*+75(*8/$7,216%8,/',1*+(,*+7 7$%/()5217$*(&$7(*25,(6*5281')/2255(6,'(17,$/ 7$%/(23(163$&(5(*8/$7,2165(6,'(17,$/ 0,1,080121( )5217$*(7<3(325&+ 7<3(&20021 0$;,080   :$51(53(50,77(' 67$1'$5'6)3(581,7 352326('  0$; $9(522)'(&.+(,*+7 /2&$/&211(&7253(50,77(' 352326('6((7$%/(%(/2: &20021 5(48,5(0(172)352-(&76,7($5($23(163$&(7<3($66,67('/,9,1*23(163$&(6800$5<6,7($5($6)5(48,5('23(163$&(6)3529,'('6) $/&2857<$5' %8,/',1*%8,/',1*%8,/',1*%8,/',1*+55$7('),5(:$// %8,/',1*6) %8,/',1*6) %8,/',1*6) %8,/',1*6) %8,/',1*6) %8,/',1*6) %8,/',1*6) %8,/',1*%8,/',1*%8,/',1*%8,/',1*+55$7('),5(:$// ‡ ),5(635,1./(568335(66,216<67(0 ),5(021,725,1*$/$506<67(0‡(/(9$7256<67(06‡ 3+27292/7$,&6<67(0‡ ',(6(/)8(/7$1.)25*(1(5$725‡ .,7&+(1+22'68335(66,216<67(0‡ (0(5*(1&<5(6321'(55$',2&29(5$*(‡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□ □ □ □ □ □ □ □ ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 San Diego 858.203.4999 ~ CLEARWATER LIVING r. f.?n~J!Y;~R~ 0 $$&2857<$5' $0(1,7<522)'(&. 522) ,17(5,2563$&(6 81,7%$/&21,(6 $0(1,7<522)'(&. ,17(5,2563$&(6 81,7%$/&21,(6 ,17(5,2563$&(6 81,7%$/&21,(6 3$5.,1**$5$*(,17(5,2563$&(6 ,17(5,2563$&(6 81,7%$/&21,(6 /$5*(%$/&21,(6 $$$0(1,7<522)'(&. &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB$5B5UYW30ACTIVE ADULTBUILDING GROSSFLOOR AREA PLANS G-216 &/($5:$7(5$77867,1/(*$&< 6&$/(  ),)7+)/225*6)$5($3/$1 6&$/(  ),567)/225*6)$5($3/$1 6&$/(  6(&21')/225*6)$5($3/$1 6&$/(  7+,5')/225*6)$5($3/$1 6&$/(  )2857+)/225*6)$5($3/$1 $&7,9($'8/7%8,/',1**6) (1&/26(',17(5,2563$&(621/< )/225/(9(/)/225$5($),567)/225 6)6(&21')/225 6)7+,5')/225 6))2857+)/225 6)),)7+)/225 6)*5$1'727$/6) 3$5.,1*%$/&21,(6&2857<$5'$1'$0(1,7<522)'(&.)/225/(9(/ $5($63$&( )/225$5($),567)/225 3$5.,1**$5$*( 6)6(&21')/225 81,7%$/&21,(6 6)6(&21')/225 /$5*(%$/&21,(6 6)6(&21')/225 $$&2857<$5' 6)7+,5')/225 81,7%$/&21,(6 6)7+,5')/225 $0(1,7<522)'(&. 6))2857+)/225 81,7%$/&21,(6 6)),)7+)/225 81,7%$/&21,(6 6)*5$1'727$/ 6) (;&/8'(681,73$7,26$7$$&2857<$5' ,1&/8'(681,73$7,26$7$$&2857<$5' $&7,9($'8/7%8,/',1*$5($6800$5< $&7,9($'8/73$5.,1**$5$*(()),&,(1&< 3$5.,1**$5$*(*5266)/225$5($ 6)180%(52)3$5.,1*63$&(6 63$&(6 3$5.,1*63$&('(16,7<()),&,(1&< 6)3$5.,1*63$&( 6((3$5.,1*$1$/<6,6216+((7*)25%5($.'2:12)$'$(9$1'67$1'$5'3$5.,1*63$&(6 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 366 ~ CLEARWATER LIVI NG •conflue t •• senior liviRg $$&2857<$5' %5%$ %5%$;/ %5%$ %5%$;/ %2+ &,5&8/$7,21 &20021$5($6 60$//%5%$ 287'225 1BR/1BA 230756 SF 2BR/2BA 2321086 SF 2BR/2BA 2311113 SF 1BR/1BA 234762 SF 1BR/1BA 236761 SF 2BR/2BA XL 2381223 SF 2BR/2BA XL 2401309 SF 2BR/2BA XL 2421309 SF 2BR/2BA XL 2441309 SF 1BR/1BA XL 246939 SF1BR/1BA 248758 SF1BR/1BA 250761 SF 2BR/2BA 2291122 SF 1BR/1BA XL 2331124 SF 2BR/2BA 2511109 SF 2BR/2BA 2491112 SF 1BR/1BA XL 2431200 SF 1BR/1BA 241788 SF 1BR/1BA 228797 SF2BR/2BA XL 2261312 SF2BR/2BA XL 2241307 SF2BR/2BA XL 2221318 SF 2BR/2BA 2211123 SF 1BR/1BA 227789 SF1BR/1BA 223786 SF 2BR/2BA XL 2161387 SF 2BR/2BA 2141086 SF 2BR/2BA 2081087 SF 2BR/2BA XL 2061231 SF 1BR/1BA 201796 SF 1BR/1BA 202760 SF1BR/1BA 204756 SF 1BR/1BA 213784 SF 1BR/1BA XL 2191023 SF 1BR/1BA XL 220920 SF1BR/1BA XL 218912 SF 1BR/1BA 212755 SF 1BR/1BA 210755 SF )255(6,'(1786(21/<12723(1727+(38%/,& GREAT ROOM ACTIVITY ROOM YOGA FITNESS M LOCKERS 1BR/1BA 205783 SF SM 1BR/1BA 203659 SF SM 1BR/1BA 211660 SF 1BR/1BA XL 2091103 SF SM 1BR/1BA 225658 SF W LOCKERS )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& BAR AREA/LOUNGE )255(6,'(1786(21/<12723(1727+(38%/,& AMENITY ROOF DECK 1BR/1BA 330756 SF 2BR/2BA 3321086 SF 2BR/2BA 3311113 SF 1BR/1BA 334762 SF 1BR/1BA 336763 SF 2BR/2BA XL 3381126 SF 2BR/2BA XL 3401310 SF 2BR/2BA XL 3421309 SF 2BR/2BA XL 3441310 SF 1BR/1BA XL 346939 SF1BR/1BA 348758 SF1BR/1BA 350761 SF 2BR/2BA 3291122 SF 1BR/1BA XL 3331127 SF 2BR/2BA 3511125 SF 2BR/2BA 3491111 SF 1BR/1BA XL 3431200 SF 1BR/1BA 341785 SF 1BR/1BA 328794 SF2BR/2BA XL 3261312 SF2BR/2BA XL 3241307 SF2BR/2BA XL 3221319 SF 2BR/2BA 3211116 SF 1BR/1BA 327789 SF1BR/1BA 323786 SF 2BR/2BA XL 3161387 SF 2BR/2BA 3141086 SF 2BR/2BA 3081087 SF 2BR/2BA XL 3061231 SF 1BR/1BA 301795 SF 1BR/1BA 302760 SF1BR/1BA 304755 SF 1BR/1BA 313784 SF 1BR/1BA XL 3191025 SF 1BR/1BA XL 320920 SF1BR/1BA XL 318912 SF 1BR/1BA 312755 SF 1BR/1BA 310755 SF 1BR/1BA 305783 SF SM 1BR/1BA 303659 SF SM 1BR/1BA 311660 SF 1BR/1BA XL 3091103 SF SM 1BR/1BA 325658 SF 522) 1BR/1BA 430756 SF 2BR/2BA 4321086 SF 2BR/2BA 4311113 SF 1BR/1BA 434762 SF 1BR/1BA 436763 SF 2BR/2BA XL 4381126 SF 2BR/2BA XL 4401310 SF 2BR/2BA XL 4421309 SF 2BR/2BA XL 4441310 SF 1BR/1BA XL 446939 SF1BR/1BA 448757 SF1BR/1BA 450761 SF 2BR/2BA 4291122 SF 1BR/1BA XL 4331127 SF 2BR/2BA 4511124 SF 2BR/2BA 4491111 SF 1BR/1BA XL 4431200 SF 1BR/1BA 441785 SF 1BR/1BA 428794 SF2BR/2BA XL 4261312 SF2BR/2BA XL 4241307 SF2BR/2BA XL 4221319 SF 2BR/2BA 4211116 SF 1BR/1BA 427789 SF1BR/1BA 423786 SF 2BR/2BA XL 4161387 SF 2BR/2BA 4141086 SF 2BR/2BA 4081087 SF 2BR/2BA XL 4061231 SF 1BR/1BA 401795 SF 1BR/1BA 402760 SF1BR/1BA 404755 SF 1BR/1BA 413784 SF 1BR/1BA XL 4191025 SF 1BR/1BA XL 420920 SF1BR/1BA XL 418912 SF 1BR/1BA 412755 SF 1BR/1BA 410755 SF 1BR/1BA 405783 SF SM 1BR/1BA 403659 SF SM 1BR/1BA 411660 SF 1BR/1BA XL 4091103 SF SM 1BR/1BA 425658 SF 1BR/1BA 530756 SF 2BR/2BA 5321086 SF 2BR/2BA 5311113 SF 1BR/1BA 534762 SF 1BR/1BA 536763 SF 2BR/2BA XL 5381126 SF 2BR/2BA XL 5401310 SF 2BR/2BA XL 5421309 SF 2BR/2BA XL 5441310 SF 1BR/1BA XL 546939 SF1BR/1BA 548758 SF1BR/1BA 550761 SF 2BR/2BA 5291122 SF 1BR/1BA XL 5331127 SF 2BR/2BA 5511124 SF 2BR/2BA 5491111 SF 1BR/1BA XL 5431200 SF 1BR/1BA 541785 SF 1BR/1BA 528794 SF2BR/2BA XL 5261312 SF2BR/2BA XL 5241307 SF2BR/2BA XL 5221319 SF 2BR/2BA 5211116 SF 1BR/1BA 527789 SF1BR/1BA 523786 SF 2BR/2BA XL 5161387 SF 2BR/2BA 5141086 SF 2BR/2BA 5081087 SF 2BR/2BA XL 5061231 SF 1BR/1BA 501795 SF 1BR/1BA 502760 SF1BR/1BA 504755 SF 1BR/1BA 513784 SF 1BR/1BA XL 5191025 SF 1BR/1BA XL 520920 SF1BR/1BA XL 518912 SF 1BR/1BA 512755 SF 1BR/1BA 510755 SF 1BR/1BA 505783 SF SM 1BR/1BA 503659 SF SM 1BR/1BA 511660 SF 1BR/1BA XL 5091103 SF SM 1BR/1BA 525658 SF )255(6,'(1786(21/<12723(1727+(38%/,& LOBBY MAIL/BUS. CENTER LEASING REC. MANAGER CONFERENCE MAINT. OFF.STOR. )255(6,'(1786(21/<12723(1727+(38%/,& LEASING REC. RR RRTRASHB.O.H.TRASHB.O.H.MAIN ELECTRICAL B.O.H. POOL EQUIPMENT B.O.H. STAIR 2 ELEV. 2 STAIR 3ELEV. 1STAIR 1 ELEC. ELEC. MPOE ELEV. 3 BATTERY &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB$5B5UYW30ACTIVE ADULTRENTABLE AREA PLANS G-220 &/($5:$7(5$77867,1/(*$&< $&7,9($'8/7$5($6800$5< 6&$/(  6(&21')/2255(17$%/( 352*5$0$5($3/$1 6&$/(  7+,5')/2255(17$%/( 352*5$0$5($3/$1 6&$/(  )2857+)/2255(17$%/($5($3/$1 6&$/(  ),)7+)/2255(17$%/($5($3/$1 $&7,9($'8/7&20021$5($6800$5< $5($63$&( )/225$5($$&7,9,7<5220 6)%$5$5($/281*( 6)%8,/',1* 6)&21)(5(1&( 6)),71(66 6)*5($75220 6)/($6,1*5(& 6)/2%%< 6)0/2&.(56 6)0$,/%86&(17(5 6)0$,172)) 6)0$1$*(5 6)55 6)6725 6):/2&.(56 6)<2*$6)727$/$&7,9($'8/7&20021$5($66) 6&$/(  ),567)/225352*5$0$5($3/$1 $&7,9($'8/781,70,;6800$5<81,77<3( 122)81,76 )/225$5($%5%$  6)%5%$;/  6)%5%$  6)%5%$;/  6)60%5%$  6)180%(52)$&7,9($'8/781,76 6) $&7,9($'8/7&,5&8/$7,21$5($6800$5< $5($63$&()/225$5($$'0,1+$//:$<6)&255,'25 6)(/(96)(/(96)(/(96)(/(96)67$,56)67$,56)67$,56)727$/$&7,9($'8/7&,5&8/$7,21$5($66) $5($3/$1/(*(1' $&7,9($'8/7%2+$5($6800$5<$5($63$&()/225$5($%2+6)%$77(5<6)(/(&6)0$,1(/(&75,&$/6)032(6)322/(48,30(17 6)67256)75$6+6)727$/$&7,9($'8/7%2+$5($66) $&7,9($'8/7287'225$5($6800$5<$5($63$&()/225$5($$$&2857<$5'6)$0(1,7<522)'(&.6)727$/$&7,9($'8/7287'225$5($66)  (;&/8'(681,73$7,26$7$$&2857<$5'&2857<$5'81,73$7,2$5($6$66,*1('72$662&,$7('81,76217+,66+((7 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 367 ■ ~ CLEARWATER LIVI NG •confluent •• senior living 0 DN $66,67('/,9,1*0(025<&$5(/$5*(%$/&21,(681,7%$/&21,(6 0&%$/&21< 3$5.,1**$5$*($66,67('/,9,1*/$5*(%$/&21,(681,7%$/&21,(6 &2857<$5' $/&2857<$5' 3$5.,1**$5$*( $/&2857<$5' 2BED/2BATH 1581058 SF 2BED/2BATH XL1571160 SF 2BED/2BATH XL1551149 SF 2BED/2BATH XL1531155 SF 2BED/2BATH XL1511382 SF SM 1BED/1BATH 125588 SF 2BED/2BATH 1261048 SF 2BED/2BATH1231052 SF 1BED/1BATH 124696 SF 2BED/2BATH 1191058 SF 2BED/2BATH 1181145 SF 2BED/2BATH 1161134 SF1BED/1BATH 114638 SF SM 1BED/1BATH 113840 SF 1BED/1BATH 112689 SF1BED/1BATH 110688 SF1BED/1BATH 108689 SF1BED/1BATH 106688 SF 2BED/2BATH 1111074 SF1BED/1BATH 109715 SF1BED/1BATH 107714 SF1BED/1BATH 105714 SF1BED/1BATH 103714 SFSM 1BED/1BATH 101584 SF 2BED/2BATH 1041044 SF2BED/2BATH 1021043 SF1BED/1BATH 100689 SF 1BED/1BATH 159699 SF 1BED/1BATH 161708 SF 0&%$/&21< 1BED/1BATH 268801 SF 1BED/1BATH 266693 SF 1BED/1BATH 264692 SF 1BED/1BATH 262692 SF SM 1BED/1BATH 260588 SF 1BED/1BATH 259701 SF 1BED/1BATH 261712 SF 2BED/2BATH 2651176 SF 1BED/1BATH 267715 SF 2BED/2BATH 2581061 SF 1BED/1BATH2561241 SF 2BED/2BATH 2541149 SF 1BED/1BATH 252692 SF 1BED/1BATH 250694 SF SM 1BED/1BATH 248588 SF 1BED/1BATH 246694 SF SM 1BED/1BATH 244593 SF 1BED/1BATH 242698 SF SM 1BED/1BATH 240573 SF 1BED/1BATH 238693 SF SM 1BED/1BATH 236590 SF 2BED/2BATH 2341050 SF 2BED/2BATH 2321128 SF 2BED/2BATH XL 2301184 SF2BED/2BATH XL 2391456 SF2BED/2BATH XL 2411147 SF2BED/2BATH XL 2431146 SF2BED/2BATH XL 2451159 SF 1BED/1BATH 227692 SF 2BED/2BATH 2281046 SFSM 1BED/1BATH 225588 SF 1BED/1BATH 226702 SF2BED/2BATH 2231055 SF 2BED/2BATH 2241093 SF2BED/2BATH 2211077 SF 2BED/2BATH 2191061 SF SM 1BED/1BATH 2221082 SF SM 1BED/1BATH 213840 SF 2BED/2BATH2181145 SF 2BED/2BATH2161136 SF1BED/1BATH214642 SF1BED/1BATH 212692 SF1BED/1BATH 210691 SF 1BED/1BATH 211717 SF MC STUDIO 295356 SFMC STUDIO 297355 SF MC STUDIO 299358 SF MC STUDIO 293355 SF MC STUDIO 291356 SF MC STUDIO 289355 SF MC STUDIO 287356 SF MC STUDIO 285355 SF MC STUDIO 283356 SF MC STUDIO 281355 SF MC STUDIO 279356 SF MC STUDIO 277355 SF MC STUDIO 275356 SF MC STUDIO 273355 SF MC STUDIO 271356 SF MC STUDIO 269355 SF MC STUDIO 276355 SF MC STUDIO 278353 SFMC STUDIO 280355 SF MC STUDIO 282355 SF MC STUDIO 284356 SF MC STUDIO 286355 SF MC STUDIO 288356 SF MC STUDIO 290355 SF MC STUDIO 292356 SF MC STUDIO294355 SF MC STUDIO 296354 SF MC STUDIO298357 SF 1BED/1BATH 263883 SF %('%$7+%('%$7+%('%$7+;/60%('%$7+&20021$5($6&,5&8/$7,21 %2+ %('%$7+%('%$7+%('%$7+;/60%('%$7+&20021$5($6 &,5&8/$7,21 %2+0&678',2 &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$VVLVWHGB/LYLQJB$5B5UYW30ASSISTED LIVING/MEMORY CARE AREAPLANS G-224 &/($5:$7(5$77867,1/(*$&< $66,67('/,9,1*%8,/',1**6) (1&/26(',17(5,2563$&(621/< )/225/(9(/ 1$0( )/225$5($),567)/225 $66,67('/,9,1*6)6(&21')/225 $66,67('/,9,1*6)6(&21')/225 0(025<&$5(6)*5$1'727$/6) 3$5.,1*%$/&21,(6&2857<$5'$1'0(025<&$5(%$/&21<)/225/(9(/$5($7<3()/225$5($),567)/225 81,7%$/&21,(6 6)),567)/225 3$5.,1**$5$*(6)),567)/225 /$5*(%$/&21,(6 6)),567)/225 &2857<$5'6)6(&21')/225 81,7%$/&21,(6 6)6(&21')/225 0&%$/&21<6)6(&21')/225 /$5*(%$/&21,(6 6)*5$1'727$/6) 6&$/(  ),567)/225*6)$5($3/$1 6&$/(  6(&21')/225*6)$5($3/$1 (;&/8'(681,73$7,26$7&2857<$5' ,1&/8'(681,73$7,26$7&2857<$5' 6&$/(  ),567)/2255(17$%/($5($3/$1 6&$/(  6(&21')/2255(17$%/($5($3/$1 $66,67('/,9,1*%8,/',1*$5($6800$5< $66,67('/,9,1*0(025<&$5($5($6800$5< $66,67('/,9,1*3$5.,1**$5$*(()),&,(1&< 3$5.,1**$5$*(*5266)/225$5($ 6)180%(52)3$5.,1*63$&(6 63$&(6 3$5.,1*63$&('(16,7<()),&,(1&< 6)3$5.,1*63$&( 6((3$5.,1*$1$/<6,6216+((7*)25%5($.'2:12)$'$(9$1'67$1'$5'3$5.,1*63$&(6 $66,67('/,9,1*0(025<&$5(81,76800$5<81,77<3(180%(52)81,76 )/225$5($%('%$7+6)%('%$7+6)%('%$7+;/6)0&678',2 6)60%('%$7+6)180%(52)$/0&81,766) ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 368 ~ CLEARWATER LIVING •conflue t •• senior liviRg * &/($5:$7(5$77867,1/(*$&< 0$7(5,$/%2$5' 369 13. limestone Tile Emserlile•Llmestone HonedFlnlshSlze12"x24" UnpollshedFlnlshsize3"xl2" 11.GlassRaHlng VitroGl1ulng Starphlre 12.Glazlng Vitro Glazing Solarban700ptlgray ~ -:;...--,...,......_......._.......__...._......_.........,...._,..._,.. 6.Sldlng James Hardie. Hardie Artisan Siding Shlplap-SeagrassFlnlsh 9. PVC Roofing SlkaSarnafll Senergy -880 Charcoal (LRV 8) • 10.PlcketRalllngs PPGDuranar Color: Black UC40Sn 5. Exposed Concrete _J A.Plaster Omega Smooth Texture B. Plaster 1. Plaster Color Omega Omega 20/30 Fine Sand Texture SW 7005 Pure White confluent t development =--C LEARWATER LIVING 2. Plaster Color Omega SW 7064 Passive 3.PlasterColor Omega SW9171FeltedWool 8, Wire Mesh Screen McNlchols Designer Mesh -TECHNA~ 816411"""'-~--,-' 4. Plaster Color Omega SW 7069 Iron Ore II 370 I I I I I !, / i A.L~~A./N.S.P.S. SURVEY COUNTY ~:TIN, CA 9260~· 990/25-33 ORANGE, CALIFORNIA \ EEEEEEEEEEEEEEEEEE E E EEEEEEEEEEEEEEEEEEEEESL SL SL SL                 ST ST ST ST SLSLE E E E E E E E E E E E E E E E E ST ST ST ST ST ST ST ST ST D S S S S RWRPBPBRWRWARNER AVE JOHN JOHNSON WAY 7 (37.55' R1)37.55'64 1 N17°00'00".E 432.38' (432.38' R1)L=112.35' )(L=603.35' R1)L=603.35' N 64°05'52" W 280.62' (280.62' R1)Δ=16°06'48"(Δ=16°06'56" R1)TELEPHONE PULL BOX (NE COR3.0' SW'LY OF PLELECTRIC PULL BOX (NE COR)2.8' SW'LY OF PLTV PULL BOX (NE COR)3.3' SW'LY OF PLTELEPHONE VAULT (NE COR2.0' SW'LY OF PLWALL (NE COR END)1.2' SW'LY OF PLELECTRIC PULL BOX (SE COR)6.5' NE'LY OF PLCULVERT BOX (SW COR)2.4' NE'LY OF PLIRRIGATION BOX (SE COR)5.7' NE'LY OF PLWALL (N'LY FACE)0.1' SW'LY OF PLWALL (N'LY FACE)CROSSING PLWALL (NW COR END)8.4' NE'LY OF PLIRRIGATION CONTROL BOX(NE COR) 3.2' NW'LY OF PLSEWER MAN HOLE (CENTER)4.0' SE'LY OF PLPROPERTY LINE& RIGHT OF WAY PROPERTY LINE & RIGHT OF WAY DIRTSIDEWALK (BACK)0.1' NE'LY OF PLSIDEWALK (BACK)0.1' NE'LY OF PL2 ARMSTRONG AVEPROPOSED5-STORY ACTIVE ADULTBUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.47 PROPOSED2-STORY ASSISTED LIVING& MEMORY CARE BUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.80EX 12" DWEX 72" SDEX 15" SSC/L C/L C/LC/LL=23.37', R=15.00'N23°14'34"EL=59.44'EXISTING 36" SD EX. 36" SD EX 10" SS EX 10" DW EX. 8" SS EX. 10" WAEX RWEX ELECEX 24" SDEX 10" WAEX 8" SS(NOT A PART) (NOT APART) L=47.60',R=20.00' 37.0 2 ' N 2 0 ° 5 4 ' 1 7 " W 60 65 70 75 56 57 58 59 61 62 6364 66 676869 71727374 76 7755 54 5355 5453 5155 56 57 58 59L=107.44',R=311.66'S64°38'16"EL=6.95'N25°54'08"EL=126.17'L=303.67'(L=303.67' R1) L=308.03'(L=308.03' R1)(R=1982.00' R1)R=1982.00' (R=1954.00' R1)R=1954.00' N 64°05'52" W 201.98' (201.98' R1) (Δ=8°54'16" R1)Δ=8°54'16" Δ=8°54'16"(Δ=8°54'16" R1) Δ=5°48'14"R=1470.00' (R=1470.00' R1)(Δ=5°48'14" R1)L=148.91' (L=148.91' R1) (Δ=20°05'37" R1) Δ=20°05'40" R=1400.00' (R=1400.00' R1) Δ=4°35'52" (L=112.37' R1) (Δ=4°35'55" R1) (Δ=24°41'32" R1)Δ=24°41'32" (302.17' R1) 302.17' N 75°31'01" W (L=96.90' R1) (R=1460.00' R 1 ) Δ=3°48'10" 29"W50.00'(50.00' R1)(114.22' R1)N39°10'31" E 114.22'(Δ=12°32'28" R1)Δ=12°32'28"R=1348.04'(R=1348.04' R1)L=295.06'(L=295.06' R1)55.0005353 54545954PROPOSED LOT LINE PROPOSED LOT LINE PROPOSED (PRIVATE)MODULAR WETLANDSTORM DRAIN PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED(PRIVATE) 8" SEWER PROPOSED (PRIVATE) 6" FIREWATER AND BACKFLOW PREVENTER PROPOSED (PRIVATE)6" FIRE WATER PROPOSED (PRIVATE)OLDCASTLE STORMCAPTURE PROPOSED (PRIVATE) 4" DOMESTICWATER AND BACKFLOW PREVENTER PROPOSED(PRIVATE) 8" SEWER PROPOSED (PRIVATE)48" STORM DRAIN DEMOLISH PORTION OFEXISTING STORM DRAINLATERAL AND CATCH BASIN PROPOSED (PRIVATE)8" SEWER 20 .9 ' 23.7' 15.9'11.6'15.9'70.4' 50.3'12.8'42.7' 35.0' 70.1' 25.3'46.1'24.6'22.7'25.7'11.8' 15.4'27' DRIVEWAY17.2'14.2' 27' DRIVEWAY 20.0' 20.0' PARCEL 1 121,531 SF (2.79 AC)PARCEL 2 145,854 SF (3.35 AC) 3 1 4 P/LP/LP/L PROPOSED (PRIVATE)48" STORM DRAIN N25°54'08"EL=83.62'PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED(PRIVATE)8" SEWER P/L N 25 ° 5 8 ' 1 7 " W 38.4 5 ' (38.4 5 ' R 1 ) P/L PROPOSED (PRIVATE)6" FIRE WATER PROPOSED (PRIVATE)6" DOMESTIC WATER PROPOSED (PRIVATE)48" STORM DRAIN B B B BB A A (37. 0 2 ' R 1 ) 3 N 39°10'31" E 205.21'(205.21' R1)(Δ=14°45'07" R1)Δ=14°45'07"Δ=32°59'59"(Δ=32°59'59" R1)R=1400.04'(R=1400.04' R1)(L=360.47' R1)L=360.47'19 14 L=806.36'(L=806.36' R1)(L=393.79' R1)L=393.73'19 P/L 234.24'(234.24' R1)N 73°00'08" W 206.24'(206.24' R1) N 73°00'08" W5.0'(NOT A PART)VETERANS WAY5 1 (Δ=3°48'10" R1) PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE 6.0'REMOVE PORTION OF EXISTINGSTORM DRAIN LATERAL ANDCATCH BASIN; CAP STORMDRAIN AT PROPERTY LINE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)48" STORM DRAIN CAP EXISTING STORMDRAIN CONNECTORPIPE AT PROPERTYLINE 1 L=96.90' R=1460.00' 19 PROPCB PROPCB PROPCB PROPCB PROPCB PROPCB PROPCB TRACT 17144APN: 430-272-12 TRACT 18197APN: 430-481-15 19 TRACT 18197APN: 430-481-24 N17°00'00"E 133.00' (133.00' R1)N 13°56'50" EN 17°00'00" E 138.72' (138.72' R1)32 565758 57 58 5959565758 5859595656575755 5554 55 55 54 5656 PROPOSED (PRIVATE)OLDCASTLE STORMCAPTURE Δ=10°42'21"R=170.77'(L=31.91')(R=170.77')(R1)(Δ=10°42'21")L=31.91'76 L=26.48'(Δ=07°43'15")(R1)(R=196.48')(L=26.48')R=196.48'Δ=07°43'15"Δ=13°06'14"R=41.00'(L=9.38')(R=41.00')(R1)(Δ=13°06'14")L=9.38'54 L=15.91'(Δ=15°27'12")(R1)(R=59.00')(L=15.91')R=59.00'Δ=15°27'12"Δ=02°21'00"R=1472.00'(L=60.37')(R=1472.00')(R1)(Δ=02°21'00")L=60.37'3 DELTAΔ=14°11'50"CURVE1 LENGTHL=10.16'RADIUSR=41.00'(L=10.16')LENGTH RADIUS(R=41.00')RECORD(R1)DELTA(Δ=14°11'50")2 L=14.78'(Δ=14°20'59")(R1)(R=59.00')(L=14.78')R=59.00'Δ=14°20'59" (R1) (N85°15'23"E)(0.11')0.11'N85°15'23"EN38°14'17"E 4.92' (4.92')(N38°14'17"E)(R1)(R1) (N85°15'26"E)(37.48')37.48'N85°15'26"EN51°45'31"W 32.83' (32.83')(N51°45'31"W)(R1) (36.45')(N36°37'39"W)1LINE DISTANCEBEARINGN36°37'39"W 36.45'RECORD BEARING DISTANCE(R1)(R1) (N68°46'50"W)(36.20')36.20'N68°46'50"W23456 RW EEEEEEEEEEEEEE E E EEEEEEEEEEEEEEEEEEEE                                             ST ST ST ST SLC C C E E E E E E E E E E E ESTSTSTST S D S S SS S S RWRPB PBPBRWRWARNER Y 1 5 7 (37.55' R1)37.55'64 1 N17°00'00".E 432.38' (432.38' R1)(L=490.98' R 1 ) L=491.00' (L=603.35' R1) N50°49'2 9 " W 1 8 5 . 1 0 ' ( 1 8 5 . 1 0 ' R 1 ) L=603.35' N 64°05'52" W 280.62' (280.62' R1)TELEPHONE PULL BOX (NE COR)3.0' SW'LY OF PLELECTRIC PULL BOX (NE COR)2.8' SW'LY OF PLTV PULL BOX (NE COR)3.3' SW'LY OF PLTELEPHONE VAULT (NE COR)2.0' SW'LY OF PLWALL (NE COR END)1.2' SW'LY OF PLELECTRIC PULL BOX (SE COR)6.5' NE'LY OF PLCULVERT BOX (SW COR)2.4' NE'LY OF PLIRRIGATION BOX (SE COR)5.7' NE'LY OF PLWALL (N'LY FACE)0.1' SW'LY OF PLWALL (N'LY FACE)CROSSING PLWALL (NW COR END)8.4' NE'LY OF PLELECTRIC MANHOLE (CENTER)3.2' SW'LY OF PL IRRIGATION CONTROL BOX(NE COR) 3.2' NW'LY OF PLSEWER MAN HOLE (CENTER)4.0' SE'LY OF PLPROPERTY LINE& RIGHT OF WAY PROPERTY LINE & RIGHT OF WAY DIRTN46°41'4 0 " W 1853.44' (GPS TIE )SIDEWALK (BACK)0.1' NE'LY OF PLSIDEWALK (BACK)0.1' NE'LY OF PLSIDEWALK (BACK)AT PL 1 2 1 1 ARMSTRONG AVEPROPOSED5-STORY ACTIVE ADULTBUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.47 PROPOSED2-STORY ASSISTED LIVING& MEMORY CARE BUILDINGFF ELEV = ± 55.80FG ELEV = ± 54.80EX 12" DWEX 36" S D EX 72" SDEX 15" SSC/L C/L C/LC/LL=23.37', R=15.00'N23°14'34"EL=59.44'EXISTING 36" SD EX. 36" SD EX 10" SS EX 10" DW EX. 8" SSEX RWEX ELECEX RW EX 24" SDEX 10" WAEX 8" SS(NOT APART) L=47.60',R=20.00' 37.0 2 ' N 2 0 ° 5 4 ' 1 7 " W 60 65 70 75 56 57 58 59 61 62 6364 66 676869 71727374 76 7755 54 53555453 5155 56 57 58 59L=107.44',R=311.66'S64°38'16"EL=6.95'N25°54'08"EL=126.17'L=303.67'(L=303.67' R1) L=308 0 3 ' (R=1954.00' R1)R=1954.00' N 64°05'52" W 201.98' (201.98' R1) (Δ=8°54'16" R1)Δ=8°54'16" Δ=5°48'14"R=1470.00' (R=1470.00' R1)(Δ=5°48'14" R1)L=148.91' (L=148.91' R1) (Δ=20°05'37" R1) Δ=20°05'40" R=1400.00' (R=1400.00' R1) (L=(Δ= (Δ=24°41'32" R1)Δ=24°41'32" (L=96.90' R1) (R=1460.00' R1) Δ=3°48'10" N50°49'2 9 " W 50.00'(50.00' R1)(114.22' R1)N39°10'31" E 114.22'(Δ=12°32'28" R1)Δ=12°32'28"R=1348.04'(R=1348.04' R1)L=295.06'(L=295.06' R1)55.0005353 54545954PROPOSED LOT LINE PROPOSED LOT LINE PROPOSED (PRIVATE)MODULAR WETLANDSTORM DRAIN PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED(PRIVATE) 8" SEWER PROPOSED (PRIVATE) 6" FIREWATER AND BACKFLOW PREVENTER PROPOSED (PRIVATE)6" FIRE WATER PROPOSED (PRIVATE)OLDCASTLE STORMCAPTURE PROPOSED (PRIVATE) 4" DOMESTICWATER AND BACKFLOW PREVENTER PROPOSED(PRIVATE) 8" SEWER PROPOSED (PRIVATE)48" STORM DRAIN DEMOLISH PORTION OFEXISTING STORM DRAINLATERAL AND CATCH BASIN PROPOSED (PRIVATE)8" SEWER 20 .9 ' 23.7' 15.9'11.6'15.9'70.4' 50.3'12.8'42.7' 35.0' 70.1' 25.3'46.1'24.6'22.7'25.7'11.8' 15.4'27' DRIVEWAY17.2'14.2' 27' DRIVEWAY 20.0' 20.0' PARCEL 1 121,531 SF (2.79 AC)PARCEL 2 145,854 SF (3.35 AC) 3 1 6 4 P/LP/LP/L PROPOSED (PRIVATE)48" STORM DRAIN N25°54'08"EL=83.62'PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED(PRIVATE)8" SEWER P/L N 25 ° 5 8 ' 1 7 " W 38.4 5 ' (38.4 5 ' R 1 ) P/L PROPOSED (PRIVATE)6" FIRE WATER PROPOSED (PRIVATE)6" DOMESTIC WATER PROPOSED (PRIVATE)48" STORM DRAIN B B B BB A A (37. 0 2 ' R 1 ) 3 N 39°10'31" E 205.21'(205.21' R1)(Δ=14°45'07" R1)Δ=14°45'07"Δ=32°59'59"(Δ=32°59'59" R1)R=1400.04'(R=1400.04' R1)(L=360.47' R1)L=360.47'19 14 L=806.36'(L=806.36' R1)93.79' R1)=393.73'EX 6" RW 19 P/L 234.24'(234.24' R1)N 73°00'08" W 206.24'(206.24' R1) N 73°00'08" W5.0'VETERANS WAY 5 1 (Δ=3°48'10" R1) PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE 6.0'REMOVE PORTION OF EXISTINGSTORM DRAIN LATERAL ANDCATCH BASIN; CAP STORMDRAIN AT PROPERTY LINE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)48" STORM DRAIN CAP EXISTING STORMDRAIN CONNECTORPIPE AT PROPERTYLINE 1 L=96.90' R=1460.00' 19 PROPCB PROPCB PROPCB PROPCB PROPCB PROPCB PROPCB TRACT 17144APN: 430-272-12 (NOT APART) TRACT 17404APN: 430-371-20 N17°00'00"E 133.00' (133.00' R1)N 13°56'50" EN 17°00'00" E 138.72' (138.72' R1)32 565758 57 58 5959565758 5859595656575755 5554 55 55 54 5656 PROPOSED (PRIVATE)OLDCASTLE STORMCAPTURE TENTATIVE PARCEL MAP 2025-151 PROJECT NO. DRAWN BY: JTKADESIGNED BY: JITDATE:REVIEWED BY:DATENO. REVISIONCKBYSHEET NO. CHECKED BY: JIT Save Date: Plot Date: 1/19/2026 4:04 PM1/19/2026 4:25 PMBy: Rxka P:\C\CONFCDMS0012\0400CAD\SHEETS\EC\Entitlements\Tentative Parcel Map\EC-001-CV-CONFCDMS0012-TPM.dwgRobyn KathermanBy: File:® CONFCDMS-0013CLEARWATER AT TUSTIN LEGACYTENTATIVE PARCEL MAP 2025-151LOT 14, TRACT NO. 18197, M.M. 990/25-33TUSTIN, CA 9260617542 17th St., Suite 150Tustin, CA, 92780Phone: 714.665.4500 OWNER: CITY OF TUSTIN,300 CENTENNIAL WAYTUSTIN, CA 92780ATTN: PROJECT ADDRESS: LOT 14, TRACT NO. 18197, M.M. 990/25-33TUSTIN, CA 92606 CIVIL ENGINEER: DAVID EVANS AND ASSOCIATES, INC.25152 SPRINGFIELD COURT, SUITE 350SANTA CLARITA, CA 91355ATTN: JONATHAN TAPIAPHONE 661.284.7436E-MAIL: JTAPIA@DEAINC.COM ARCHITECT: HPI ARCHITECTURE115 22ND STREETNEWPORT BEACH, CA 92663PHONE: 949.675.6442 BASIS OF BEARINGS: THE BEARING SHOWN HEREON ARE BASED ON THE CALCULATED BEARINGBETWEEN O.C.S. HORIZONTAL CONTROL STATION GPS NO. 6529 AND GPS NO.6535 BEING NORTH 03° 46' 13" WEST PER RECORDS ON FILE IN THE OFFICE OFTHE ORANGE COUNTY SURVEYOR. BENCHMARK: THE ELEVATIONS SHOWN HEREON ARE BASED UPON THE ORANGE COUNTYPUBLIC WORKS VERTICAL CONTROL DATA SHEET BENCHMARK NO. 3A-107-77,(YEAR 2013).3 3/4" OCS ALUMINUM BENCHMARK DISK STAMPED "3A-107-77" IN THEWESTERLY CORNER OF A 4 FT BY 11 FT CONCRETE CATCH BASIN.MONUMENT IS LOCATED IN THE NORTHERLY CORNER OF THE INTERSECTIONOF REDHILL AVENUE AND WARNER AVENUE, 47 FT NORTHEASTERLY OF THECENTERLINE MEDIAN ALONG WARNER AND 105 FT NORTHWESTERLY OF THECENTERLINE OF REDHILL AVENUE. MONUMENT IS LEVEL WITH THE SIDEWALK.ELEVATION = 62.047' CONTOURS SHOWN HEREON ARE 1' INTERVAL. BOUNDARY/PARCEL LINEPROPOSED PARCEL LINE EASEMENTEXISTING UTILITIES LEGEND EXISTING R/W 55 DYER RD BARR A N C A P K W Y RED HILL A VE EDINGER AVE EDIN G E R A V E TUSTIN RA NCH RDVON KAR M A AVE WARNER AVE ARMSTR ONG AV E VETERANSWAY261WARNER AVE SA N D I E G O FR W Y JAMBORE E R DCOSTA MESA FRWYSAN T A A N A F R W Y EASTERNTRANSPORTATIONCORRIDORR1.....INDICATES DATA PER TRACT NO. 18197, M.B. 990/25-33R2.....INDICATES DATA PER TRACT NO. 17144, M.B. 906/5-14 ( )INDICATES RECORD DATA.INDICATES REFERENCE RECORD DATA.R1 INDICATES DESCRIPTION NUMBER.1 MONUMENT NOTES: LEGAL DESCRIPTION: INDICATES FOUND MONUMENT, AS NOTED. THE LAND REFERRED TO HEREIN BELOW IS SITUATED IN THE CITY OF TUSTIN, COUNTY OF ORANGE, STATEOF CALIFORNIA, AND IS DESCRIBED AS FOLLOWS: LOT 14, INCLUSIVE OF TRACT NO. 18197 AS SHOWN ON A MAP FILED IN BOOK 990, PAGES 25 THROUGH 33,INCLUSIVE OF TRACT MAPS, RECORDS OF ORANGE COUNTY, CALIFORNIA. EXCEPTING THEREFROM ANY AND OIL, OIL RIGHTS, MINERALS, MINERAL RIGHTS, NATURAL GAS RIGHTSAND OTHER HYDROCABONS BY WHATSOEVER NAME KNOWN, GEOTHERMAL STEAM AND ALL PRODUCTSDERIVED FROM ANY OF THE FOREGOING, THAT MAY BE WITHIN OR UNDER THE LAND, TOGETHER WITH THEPERPETUAL RIGHT OF DRILLING, MINING, EXPLORING FOR AND STORING IN AND REMOVING THE SAMEFROM THE LAND OR ANY OTHER LAND, INCLUDING THE RIGHT TO WHIPSTOCK OR DIRECTIONALLY DRILLAND MINE FROM LANDS OTHER THAT THE LAND, OIL OR GAS WELLS, TUNNELS AND SHAFTS INTO, THROUGHOR ACROSS THE SUBSURFACE OF THE LAND AND TO BOTTOM SUCH WHIPSTOCKED OR DIRECTIONALLYDRILLED WELLS, TUNNELS AND SHAFTS UNDER AND BENEATH OR BEYOND THE EXTERIOR LIMITS THEREOF,AND TO REDRILL, RETUNNEL, EQUIP, MAINTAIN, REPAIR, DEEPEN AND OPERATED ANY SUCH WELL ORMINES; BUT WITHOUT, HOWEVER, THE RIGHT TO DRILL, MINE, STORE, EXPLORE OR OPERATE THROUGH THESURFACE OF THE LAND, AS RESERVED IN THE DEED FROM THE CITY OF TUSTIN, CALIFORNIA, RECORDEDSEPTEMBER 24, 2002 AS INSTRUMENT NO. 20020819173 OF OFFICIAL RECORDS. ALSO EXCEPTING THEREFROM ANY AND ALL WATER, WATER RIGHTS OR INTERESTS THEREINAPPURTENANT OR RELATING TO THE LAND OR OWNED OR USED BY THE GRANTOR IN CONNECTION WITHOR WITH RESPECT TO THE LAND (NO MATTER HOW ACQUIRED BY THE GRANTOR), WHETHER SUCH RIGHTSSHALL BE RIPARIAN, OVERLYING, APPROPRIATIVE, LITTORAL, PERCOLATING, ADJUDICATED, STATUTORY ORCONTRACTUAL, TOGETHER WITH THE PERPETUAL RIGHT AND POWER TO EXPLORE, DRILL, REDRILL ANDREMOVE THE SAME FROM OR IN THE LAND, TO STORE THE SAME BENEATH THE SURFACE OF THE LANDAND TO DIVERT OR OTHERWISE UTILIZE SUCH WATER, RIGHTS OR INTERESTS ON ANY OTHER PROPERTYOWNED OR LEASE BY GRANTOR; BUT WITHOUT, HOWEVER, ANY RIGHT TO ENTER UPON OR USE THESURFACE OF THE LAND IN THE EXERCISE OF SUCH RIGHTS, AS RESERVED IN THE DEED FROM THE CITY OFTUSTIN, CALIFORNIA, RECORDED SEPTEMBER 24, 2002 AS INSTRUMENT NO.20020819173 OF OFFICIAL RECORDS. FOR CONVEYANCING PURPOSES ONLY: APN 430-481-12 INDICATES CALCULATED FROMCF FOUND SPIKE & WASHER STAMPED "LS 6673" PER R1, FLUSH; ACCEPTED AS ARMSTRONG AVENUE& WARNER AVENUE CENTERLINE INTERSECTION PER R1.1 PER FIRST AMERICAN TITLE INSURANCE COMPANY, REPORT NO. NCS-1146469-SA1, DATEDMAY 07, 2025 TITLE EXCEPTIONS: 1. ANY DEFECT, LIEN, ENCUMBRANCE, ADVERSE CLAIM, OR OTHER MATTER THAT APPEARS FOR THEFIRST TIME IN THE PUBLIC RECORDS OR IS CREATED, ATTACHES, OR IS DISCLOSED BETWEEN THECOMMITMENT DATE AND THE DATE ON WHICH ALL OF THE SCHEDULE B, PART I-REQUIREMENTS AREMET. 2. (A) TAXES OR ASSESSMENTS THAT ARE NOT SHOWN AS EXISTING LIENS BY THE RECORDS OF ANYTAXING AUTHORITY THAT LEVIES TAXES OR ASSESSMENTS ON REAL PROPERTY OR BY THE PUBLICRECORDS; (B) PROCEEDINGS BY A PUBLIC AGENCY THAT MAY RESULT IN TAXES OR ASSESSMENTS,OR NOTICES OF SUCH PROCEEDINGS, WHETHER OR NOT SHOWN BY THE RECORDS OF SUCHAGENCY OR BY THE PUBLIC RECORDS. 3. ANY FACTS, RIGHTS, INTERESTS, OR CLAIMS THAT ARE NOT SHOWN BY THE PUBLIC RECORDS BUTTHAT COULD BE ASCERTAINED BY AN INSPECTION OF THE LAND OR THAT MAY BE ASSERTED BYPERSONS IN POSSESSION OF THE LAND. 4. EASEMENTS, LIENS OR ENCUMBRANCES, OR CLAIMS THEREOF, NOT SHOWN BY THE PUBLICRECORDS. 5. ANY ENCROACHMENT, ENCUMBRANCE, VIOLATION, VARIATION, OR ADVERSE CIRCUMSTANCEAFFECTING THE 77TLE THAT WOULD BE DISCLOSED BY AN ACCURATE AND COMPLETE LAND SURVEYOF THE LAND AND NOT SHOWN BY THE PUBLIC RECORDS. 6. (A) UNPATENTED MINING CLAIMS; (B) RESERVATIONS OR EXCEPTIONS IN PATENTS OR IN ACTSAUTHORIZING THE ISSUANCE THEREOF; (C) WATER RIGHTS, CLAIMS OR TITLE TO WATER, WHETHEROR NOT THE MATTERS EXCEPTED UNDER (A), (B), OR (C) ARE SHOWN BY THE PUBLIC RECORDS. 7. GENERAL AND SPECIAL TAXES AND ASSESSMENTS FOR THE FISCAL YEAR 2023-2024, A LIEN NOT YETDUE OR PAYABLE. 8. GENERAL AND SPECIAL TAXES AND ASSESSMENTS FOR THE FISCAL YEAR 2022-2023 ARE EXEMPT. IFTHE EXEMPT STATUS IS TERMINATED AN ADDITIONAL TAX MAY BE LEVIED. A.P. NO.: 430-481-12. 9. THE LIEN OF SPECIAL TAX ASSESSED PURSUANT TO CHAPTER 2.5 COMMENCING WITH SECTION 53311OF THE CALIFORNIA GOVERNMENT CODE FOR COMMUNITY FACILITIES DISTRICT NO. 13-01, ASDISCLOSED BY NOTICE OF SPECIAL TAX LIEN RECORDED MAY 16, 2013 AS INSTRUMENT NO.2013000296640 OF OFFICIAL RECORDS. 10. THE LIEN OF SPECIAL TAX ASSESSED PURSUANT TO CHAPTER 2.5 COMMENCING WITH SECTION 53311OF THE CALIFORNIA GOVERNMENT CODE FOR COMMUNITY FACILITIES DISTRICT NO. 15-2, ASDISCLOSED BY NOTICE OF SPECIAL TAX LIEN RECORDED NOVEMBER 18, 2015 AS INSTRUMENT NO.2015000594036 OF OFFICIAL RECORDS. 11. THE LIEN OF SPECIAL TAX ASSESSED PURSUANT TO CHAPTER 2.5 COMMENCING WITH SECTION 53311OF THE CALIFORNIA GOVERNMENT CODE FOR COMMUNITY FACILITIES DISTRICT NO. 2018-01, ASDISCLOSED BY NOTICE OF SPECIAL TAX LIEN RECORDED FEBRUARY 17, 2021 AS INSTRUMENT NO.2021000112117 OF OFFICIAL RECORDS. 12. THE LIEN OF SUPPLEMENTAL TAXES, IF ANY, ASSESSED PURSUANT TO CHAPTER 3.5 COMMENCINGWITH SECTION 75 OF THE CALIFORNIA REVENUE AND TAXATION CODE. 13. THE TERMS AND PROVISIONS CONTAINED IN THE DOCUMENT ENTITLED "SHORT FORM NOTICE OFAGREEMENT" RECORDED MAY 14, 2002 AS INSTRUMENT NO. 20020404589 OF OFFICIAL RECORDS. 14. EASEMENTS, COVENANTS AND CONDITIONS CONTAINED IN THE DEED FROM THE UNITED STATES OFAMERICA, AS GRANTOR, TO THE CITY OF TUSTIN, CALIFORNIA, AS GRANTEE, RECORDED MAY 14, 2002AS INSTRUMENT NO. 20020404594 OF OFFICIAL RECORDS. REFERENCE BEING MADE TO THEDOCUMENT FOR FULL PARTICULARS.DOCUMENT RE-RECORDED APRIL 09, 2003 AS INSTRUMENT NO.2003000392129 OF OFFICIAL RECORDS.NOT PLOTTED. 15. THE FACT THAT THE LAND LIES WITHIN THE BOUNDARIES OF THE MCAS TUSTIN REDEVELOPMENTPROJECT AREA, AS DISCLOSED BY THE DOCUMENT RECORDED JUNE 18, 2003 AS INSTRUMENT NO.2003000710836 OF OFFICIAL RECORDS.NOT PLOTTED. 16. THE TERMS AND PROVISIONS CONTAINED IN THE DOCUMENT ENTITLED "DECLARATION OF SPECIALRESTRICTIONS" RECORDED JUNE 19, 2007 AS INSTRUMENT NO. 2007000390805 OF OFFICIAL RECORDS.NOT PLOTTED. 17. COVENANTS, CONDITIONS, RESTRICTIONS AND EASEMENTS IN THE DOCUMENT RECORDED OCTOBER04, 2006 AS INSTRUMENT NO. 2006000661919 OF OFFICIAL RECORDS, WHICH PROVIDE THAT AVIOLATION THEREOF SHALL NOT DEFEAT OR RENDER INVALID THE LIEN OF ANY FIRST MORTGAGE ORDEED OF TRUST MADE IN GOOD FAITH AND FOR VALUE, BUT DELETING ANY COVENANT, CONDITIONOR RESTRICTION INDICATING A PREFERENCE, LIMITATION OR DISCRIMINATION BASED ON RACE,COLOR, RELIGION, SEX, HANDICAP, FAMILIAL STATUS, NATIONAL ORIGIN, SEXUAL ORIENTATION,MARITAL STATUS, ANCESTRY, SOURCE OF INCOME OR DISABILITY, TO THE EXTENT SUCHCOVENANTS, CONDITIONS OR RESTRICTIONS VIOLATE TITLE 42, SECTION 3604(C), OF THE UNITEDSTATES CODES OR SECTION 12955 OF THE CALIFORNIA GOVERNMENT CODE. LAWFUL RESTRICTIONSUNDER STATE AND FEDERAL LAW ON THE AGE OF OCCUPANTS IN SENIOR HOUSING OR HOUSING FOROLDER PERSONS SHALL NOT BE CONSTRUED AS RESTRICTIONS BASED ON FAMILIAL STATUS. NOTPLOTTED 18. THE TERMS AND PROVISIONS CONTAINED IN THE DOCUMENT ENTITLED "NOTICE OF DELINQUENCYAND CLAIM OF LIEN" RECORDED APRIL 06, 2010 AS INSTRUMENT NO. 2010000160007 OF OFFICIALRECORDS. NOT PLOTTED. 19. AN EASEMENT SHOWN OR DEDICATED ON THE MAP OF TRACT NO. 18197 RECORDED DECEMBER 10,2020 AND ON FILE IN BOOK 990, PAGE 25-33, OF TRACT MAPS.FOR: PUBLIC STREET AND PUBLIC UTILITY PURPOSES: ARMSTRONG AVENUE, WARNER AVENUE,LEGACY ROAD, AIRSHIP AVENUE, FLIGHT WAY, HELBER WAY, VETERANS WAY, COMPASS AVENUE,SWAIM WAY, JOHN JOHNSON WAY AND PEEBLER WAY AND INCIDENTAL PURPOSES.PLOTTED HEREON. 20. WATER RIGHTS, CLAIMS OR TITLE TO WATER, WHETHER OR NOT SHOWN BY THE PUBLIC RECORDS. 21. AN ALTA/NSPS SURVEY OF RECENT DATE WHICH COMPLIES WITH THE CURRENT MINIMUM STANDARDDETAIL REQUIREMENTS FOR ALTA/NSPS LAND TITLE SU1VEYS. 22. ANY FACTS, RIGHTS, INTERESTS OR CLAIMS WHICH WOULD BE DISCLOSED BY A CORRECT ALTA/NSPSSURVEY. 23. RIGHTS OF PARTIES IN POSSESSION. FOUND SPIKE & WASHER STAMPED "LS 6673" PER R1, FLUSH; ACCEPTED AS ARMSTRONG AVENUECENTERLINE BEGINNING CURVE PER R1.2 FOUND SPIKE & WASHER STAMPED "LS 6673" PER R2, FLUSH; ACCEPTED AS ARMSTRONG AVENUE& C STREET CENTERLINE INTERSECTION PER R2.3 SEARCHED FOUND NOTHING, SET NOTHING; ARMSTRONG AVENUE & JOHN JOHNSON WAY CENTERLINEINTERSECTION ESTABLISHED BY RECORD RADIUS AND DISTANCE (360.47') FROM 2 PER R14 FOUND SPIKE & WASHER STAMPED "LS 5347" PER R1, FLUSH; ACCEPTED AS WARNER AVENUE& LEGACY ROAD CENTERLINE INTERSECTION PER R1.5 SEARCHED FOUND NOTHING, SET NOTHING; WARNER AVENUE & VETERANS WAYCENTERLINE INTERSECTION ESTABLISHED BY RECORD DISTANCES FROM 1 PER R16 SEARCHED FOUND NOTHING, SET NOTHING; VETERANS WAY & JOHN JOHNSON WAY CENTERLINEINTERSECTION ESTABLISHED BY RECORD BEARING & DISTANCES FROM 6 PER R17 FOUND SPIKE & WASHER STAMPED "LS 6673" PER R1, FLUSH; ACCEPTED AS ARMSTRONG AVENUECENTERLINE BEGINNING CURVE PER R1.8 DATUM STATEMENT: COORDINATES SHOWN ARE BASED ON THE CALIFORNIA COORDINATE SYSTEM(CCS83), ZONE VI, 1983 NAD, (2017.50 EPOCH OCS GPS ADJUSTMENT). ALL DISTANCES SHOWN ARE GROUND UNLESS OTHERWISE NOTED. TO OBTAINGRID DISTANCE, MULTIPLY GROUND DISTANCE BY 0.99997671 (PROJECTSPECIFIC). FLOOD ZONE: THIS SURVEY LIES WITHIN ZONE "X" (AREAS DETERMINED TO BE OUTSIDE THE0.2% ANNUAL CHANCE FLOODPLAIN) AS SET OUT ON THE FLOOD INSURANCERATE MAP FOR ORANGE COUNTY, COMMUNITY PANEL NUMBER 06059C 0279J,DATED DECEMBER 3, 2009. VICINITY MAPN.T.S. EXCEPTIONS/ENCROACHMENT NOTES: UTILITIES WITHOUT EASEMENT ON THE NORTHERLY BOUNDARY AS SHOWN.1 WALL CROSSING THE PROPERTY LINE ON THE NORTHERLY BOUNDARY AS SHOWN.2 UTILITIES WITHOUT EASEMENT ON THE SOUTHWESTERLY BOUNDARY AS SHOWN.3 LINE AND CURVE TABLES C-0.0 CENTERLINE UTILITY PURVEYORS: ELECTRICAL:SOUTHERN CALIFORNIA EDISON1325 S GRAND AVE.SANTA ANA, CA 92705(800)-655-4555 GAS:SOUTHERN CALIFORNIA GAS COMPANY1919 STATE COLLEGE BLVD.ANAHEIM, CA 92805(877) 238-0092(714) 634-3245 CABLE:TIME WARNER14311 NEWPORT AVE.TUSTIN, CA 927803(714) 418-4267 FRONTIER COMMUNICATION7354 SLATER AVE.HUNTINGTON BEACH, CA 92647(714) 969-6468 COX6771 QUAIL HILL PKWY.IRVINE, CA 92603(949) 546-1000 TELEPHONECOX COMMUNICATIONS6771 QUAIL HILL PKWY.IRVINE, CA 92603(949) 546-1000 AT&T (LAND LINE SERVICE)3581 ORANGE STRIVERSIDE , CA 92501(909) 441-0499 WATER & SEWER:IRVINE RANCH WATER DISTRICT3512 MICHELSON DR,IRVINE, CA 92612(714) 453-5300 STORM DRAINCITY OF TUSTIN (PUBLIC WORKS)300 CENTENNIAL WAYTUSTIN, CA 92780(714)-573-3150 SUBDIVIDER/DEVELOPER: CD-CW (TUSTIN) LLC2215 MARKET ST.DENVER, CO 80205ATTN: H. MCNEISHPHONE: 303.573.6500 PROPOSED EASEMENTS: A PROPOSED EASEMENT TO THE CITY OF TUSTIN FOR BIOSWALE ACCESS ANDMAINTENANCE PURPOSES AND UTILITIES (PULLBOXES, VAULTS, CONDUITS)TO BE RESERVED IN SEPARATE DOCUMENT (4,260 SF)B PROPOSED EASEMENT FOR COMMON ACCESS AND EMERGENCY VEHICLE ACCESS NOTE: THE SUBDIVIDER SHALL RELEASE AND RELINQUISH TO THE CITY OF TUSTINALL VEHICULAR ACCESS RIGHTS ALONG ARMSTRONG AVENUE, WARNERAVENUE, VETERANS WAY, AND JOHN JOHNSON WAY, EXCEPT ALL APPROVEDACCESS LOCATIONS AND STREET INTERSECTIONS, AT NO COST TO THE CITY. AREA: GROSS AREA: 267,385 SF (6.14 AC) NET AREA: 263,125 SF (6.04 AC) No.C-62159 1/23/2026 371 ST ST ST ST SLC C C C C C ST ST ST ST ST ST ST D D D S S S SS S S TEPB EPB EPB EPB RWRRWR PB PB PBRWRDDD ASPHALT ASPHALT ASPHALT ASPHALT DIRT WARNER A V E N U E VETERANS WAYARMSTRONG AVENUE℄℄℄ R/WR/WR/WEX. 12" WAEX. 72" SDEX. 18" SSEX. 10" R.W.EX. WA EX. 24" SD EX. E EX. IRR.EX. EEX. E EX. 6" R.W. EX. 36" SD EX. 10" SS EX. 10" W A EX. EEX. EEX. EEX. EEX. E (55) (60) (65) (70) (75) (5 5 ) (54) (56) (57) (58) (59) (51)(52)(53)(54)(53) (54)(54)(53)(54)JOHN JOHNSON WAY(55)37+69.93 32+04.2533+0034+0035+0036+0037+0010+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 29+65.75 25+33.3826+0027+0028+0029+0033+45.82 34+00 35+00 36+00 37+00 38+00 39+00 40+00 40+21.92(63.0')(9.0')(72.0')(51.0')(9.0')(60.0')(61.0')(9.0')(70.0')(44.0') (8.0') (104.0') (52.0') (52.0') (44.0') (104.0') (52.0') (52.0')28.0'28.0'56.0'18.0'18.0'10.0'10.0'28.0'28.0'56.0'18.0'18.0'10.0'10.0'30.0'40.0' 70.0' 20.0'30.0'10.0'10.0' 28.0'28.0'56.0' 12.0'12.0' 53.38BW 53.33BW 53.14BW 53.58BW 54.05BW 54.08BW 53.76BW 53.46BW 53.17BW 53.23BW 53.68BW 53.90BW53.45BW 54.15BW 54.29BW 54.30BW 54.05BW 54.36BW (55.51)BW (55.48)BW (55.24)BW (54.83)BW (54.42)EG (54.25)EG (54.14)BW 54.44BW 54.90BW 55.80BW 55.62BW 55.41BW 55.18BW 54.79BW 54.62BW 54.39BW 55.00BW (55.82)BW PROPOSEDACTIVE ADULT BUILDINGFF ELEV = ±55.80FG ELEV = ±54.47 PROPOSED CURB & GUTTERPER SEPARATE OFFSITEIMPROVEMENT PLANS (BYOTHERS, CIP NO 70256) PROPOSED CURB &GUTTER PERSEPARATE OFFSITEIMPROVEMENTPLANS (BY OTHERS,CIP NO. 70256) EXISTING CURB, GUTTER, ANDSIDEWALK, SEE SEPARATEAPPROVED OFFSITEIMPROVEMENT PLANS (PREPARED BY OTHERS, CIP NO 70256) EXISTING CURB & GUTTER, PROTECT-IN-PLACE 54.43FS PROPOSED MODIFIED DRIVEWAY(WIDTH=27.0', R=25' MIN.)PER CITY OF TUSTIN STD PLAN 210SEE DRIVEWAY DETAIL "A" HEREON PROPOSEDCOMMERCIALDRIVEWAY(WIDTH=27', X=3')PER CITY OF TUSTINSTD PLAN 209SEE DRIVEWAYDETAIL "B" HEREON 53.83BW 25.0'CLEAR25.0'CLEAR 25.0'CLEAR25.0'CLEAR 25.0'CLEAR 25.0'CLEARPROPOSED SIDEWALKPER CITY OF TUSTINSTD PLAN 202 PROPOSED SIDEWALKPER CITY OF TUSTINSTD PLAN 202 PROPOSED SIDEWALKPER CITY OF TUSTINSTD PLAN 202 A A BBC CDD EXISTINGSTRIPING EXISTINGSTRIPING PROPOSEDSTRIPING PERSEPARATE OFFSITEIMPROVEMENTPLANS (BY OTHERS) PROPOSED STRIPING PER SEPARATE OFFSITE IMPROVEMENT PLANS (BYOTHERS)(51.0')(9.0')(60.0')PROPOSED ASSISTED LIVING/MEMORY CARE BUILDINGFF ELEV = ±55.8FG ELEV = ±54.8 555956 (55)(55)(60) (60) (65) (65) (70)(70) 55.80 FF55.78 FS 55.80 FF55.78 FS 55.80 FF55.78 FS 55.80FF 55.80 FF55.78 FS 55.80FF55.80FF 55.80 FF55.78 FS PROPOSEDCOURTYARDFG ELEV = ±55.8 PROPOSED ASSISTED LIVING/MEMORY CARE BUILDINGFF ELEV = ±55.8FG ELEV = ±54.8 54.47FG 54.47FG 54.47FG 54.47FG 55.80 FF55.78 FS 54.80FG 54.80FG 55.80 FF55.78 FS 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 55.80 FF55.78 FS 55.80 FF55.78 FS 55.80 FF55.78 FS 55.80 FF55.78 FS 55.80 FF55.78 FS 55.80 FF55.78 FS 54.47FG 54.47FG 54.47FG 54.47FG 55.80 FF55.78 FS 54.47FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 54.80FG 55.80 FF55.78 FS 2.0% 5959 55 54 5454 55PROPOSEDLOT LINE R/WR/WR/WPROPOSEDAREA DRAIN,TYPICAL PROPOSEDAREA DRAIN,TYPICAL PROPOSEDAREA DRAIN,TYPICAL PROPOSEDAREA DRAIN,TYPICAL PROPOSEDEARTHENED SWALE,SEE TYPICAL BERMDETAIL HEREON PROPOSEDEARTHENED SWALE,SEE TYPICAL BERMDETAIL HEREON PROPOSEDEARTHENED SWALE,SEE TYPICAL BERMDETAIL HEREON S ASSISTED LIVING/MEMORY CARETRASH STAGINGCORRAL ACTIVE ADULTTRASH STAGINGAREA PROPOSEDACTIVE ADULT BUILDINGFF ELEV = ±55.80FG ELEV = ±54.47 TRASHROOM TRASHROOM 54.23BW R/W PROPOSEDPASSENGERDROP-OFF 5' 11' PROPOSEDGENERATOR,FUEL STORAGE NOT A P A R T EXISTING BIOSWALE,SEE SEPARATE APPROVED IMPROVEMENT PLANS (PREPARED BY OTHERS, CIP NO 70256) PROPOSEDLOT LINE 55.80 FF55.78 FS 54.11FS 53.89FS 57.24FG 56.20FG 55.75FG 55.70FG 55.65FG 55.53FG 0.5%1.0%2.0% 1.0% 1.0% 2.0% 2.0%0.5%0.5%2.0% 2.0% PROPOSEDLOT LINE2.0%0.7%0.5%0.5%55.74 TC55.24 FS55.65 TC55.15 FS 55.47 TC54.97 FS54.92TG 55.58 TC55.08 FS 55.56 TC55.06 FS56.01 TC55.51 FS 54.69TG 55.19FS 55.34FS 55.82 TC55.32 FS 57.72 TC57.22 FS 55.44 TC54.94 FS 55.80FF 55.73 TC55.23 FS55.27 TC54.77 FS 55.55 TC55.05 FS55.69 TC55.19 FS55.47 TC54.97 FS 55.80 TC55.30 FS 55.85 TC55.35 FS 55.59 TC55.09 FS 55.59 TC55.09 FS 55.73 TC55.23 FS55.50 TC55.00 FS 55.24 TC54.74 FS 54.56TG1.9% 55.09 TC54.59 FS 54.85FS 54.79FS 55.25FS 55.02 TC54.52 FS 55.20 TC54.70 FS 4.5% 55.80FF 5.0%5.5%7.5%10.0%54.11FS 2.0%56.99FS 55.60FG 55.78FS 55.74FS 54.80FG 54.71FG 55.04FG 55.66FG 55.78FG 54.68FG 55.62FG 55.95FG 54.62FG 1.6% 1.9%1.0%1.0%1.0%1.5%0.5%3.0%2.0%2.0%1.0%1.0%2.0% 2.0%2.0%2.0%2.0%2.0%1.0% 2.0%0.5%2.0%1.0%0.8%0.5%55.68 TC55.18 FS 55.33FS-HP 55.60FS-HP 55.25 TC54.75 FS 54.34FS 55.41 TC54.91 FS 56.50FS-HP 57.02 TC56.52 FS 55.69FS 54.88 TC54.38 FS 54.31TG 55.66 TC55.16 FS 56.18 TC55.68 FS 55.88 TC55.38 FS 55.12 TC54.62 FS 54.63TG 55.28 TC54.78 FS 55.11 TC54.61 FS 55.16 TC54.66 FS 55.22 TC54.72 FS 54.66TG 55.33TG 55.44 TC54.94 FS 55.61FS 55.58 TC55.08 FS55.37 TC54.87 FS 55.28 TC54.78 FS 55.21 TC54.71 FS 55.50 TC55.00 FS 55.04 TC54.54 FS 54.66 TC54.16 FS 55.77FS 55.14FS 55.61 TC55.11 FS 55.34 TC54.84 FS 54.53TG 55.03 TC54.53 FS 54.53 TC54.03 FS 54.51 TC54.01 FS 54.49 TC53.99 FS 53.92TG 55.66FS55.78FS 54.94FS 55.75FS 55.72FS 55.78FS 55.53FS55.00FG 44.0'8.0' C/L R/W ARMSTRONGAVENUE PROPOSEDSIDEWALKEXISTINGGRADE R/W 42.0' EXISTINGCURB &GUTTER 14.0'8.0'BUS PAD PROPOSEDMULTI-STORYBUILDING EXISTINGSIDEWALK EXISTING CURB& GUTTER 25.0' ±55.00 FF 28.0' C/L R/W JOHN JOHNSONWAY R/W 28.0' PROPOSEDCURB &GUTTER FUTURELEGACYPARK PROPOSEDMULTI-STORYBUILDING 56.0' 18.0'10.0'10.0'18.0'14.2' EXISTINGGRADE PROPOSEDGRADE FUTURESIDEWALK±55.00 FF PROPOSEDSIDEWALK 40.0' C/L R/W FUTURESIDEWALK R/W 30.0' PROPOSEDCURB &GUTTER PROPOSEDMULTI-STORYBUILDING 70.0' 30.0'10.0'10.0'20.0'15.0' EXISTINGGRADE VETERANSWAY PROPOSEDGRADEPROPOSEDSIDEWALK±55.00 FF 49.0'14.0' C/L R/W EXISTINGGRADE 63.0'11.5' 5.0' PROPOSEDMULTI-STORYBUILDING EXISTING CURB& GUTTER PARKWAY 9.0'EX.S/W EX. 6.0' BUS PAD 21.2' EXISTINGSIDEWALK EXISTINGCURB &GUTTER 2.0' WARNERAVENUE ±55.00 FF R/W 53.97FS53.97FS 53.80 TC53.30 FL53.82 TC53.32 FL 5.0'5.0'10.0'27.0'53.98FS 10.0'10.0'53.88 FS0" CF 3.6% 10.0'10.0'53.41FL 53.88FS1.8%9.5%1.8%9.5%SIGHTTRIANGLE SIGHTTRIANGLE 53.88 FS0" CF 53.88FS 53.41FL 54.00FS 3.5%R=25'R=25 ' JOHN JOHNSON WAY5.0'5.0'WALKPKWY5.0'5.0'WALKPKWYONSITELANDSCAPING ONSITELANDSCAPING D AR/W SIGHTTRIANGLE SIGHTTRIANGLE VETERANS WAY 53.93 TC53.43 FL54.21 TC53.71 FL 53.44 FL0" CF53.69 FL0" CF10.0'10.0'10.0'10.0' 27.0'5.0'5.0'10.0'54.00FS54.25FS5.0'5.0'WALKPKWY53.91FS54.16FS 5.0'5.0'WALKPKWYONSITELANDSCAPING ONSITELANDSCAPING 1.8%9.5%1.8%9.5%5.0' MIN. R/W COMPACTEDBERM 5%MIN EARTHENEDSWALE PROPOSEDBUILDING VAR.SIDEWALKCURB &GUTTER HEIGHTR/WSIDEWALK CURB &GUTTER 1:1MAX BERMHIGH POINT 1:1MAX 5%MIN. 1:1MAX 1:1MAX 5%MIN.2%2%EARTHENEDSWALE FLOW LINE PROPOSEDBLDG. 5.0' MIN. PROPOSEDAREA DRAIN C HPI ARCHITECTURE 2025 SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF THE ARCHITECT AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITH THEARCHITECT. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTODESK REVIT V. 2025 UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVALAutodesk Docs://Clearwater Tustin/Clearwater_Tustin_Site_R25.rvt10/1/2025 3:56:10 PMISSUED# DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL 123 ® 17542 17th St., Suite 150Tustin, CA, 92780Phone: 714.665.4500 2026-01-21 4TH ENTITLEMENT SUBMITTAL4 C-1.0 PRELIMINARY GRADING PLAN LEGEND BWCLEEX.FGFFIRR.SDSSR.W.R/WWA(XX.XX)XX.XX BACK OF WALKCENTERLINEELECTRICALEXISTINGFINISHED GRADEFINISHED FLOORIRRIGATIONSTORM DRAINSANITARY SEWERRECYCLED WATERRIGHT-OF-WAYWATEREXISTING ELEVATIONPROPOSED ELEVATION SECTION A-A SECTION B-B SECTION C-C SECTION D-D DRIVEWAY DETAIL "A" SCALE: 1" = 10'DRIVEWAY DETAIL "B" SCALE: 1" =10' TYPICAL BERM DETAIL SCALE: N.T.S. S SIGNALIZED INTERSECTION 372 b1 I"\ ,., . / , -E===t==rl Ir . .. . , : J v ,.,--,, SL SLSL SLST ST ST ST SLC C C C C C SLST ST ST ST ST ST ST ST ST D D D S S S SS S S TEPB EPB EPB EPBRWRRWR PB PBPBRWRDDD ASPHALT ASPHALT ASPHALT ASPHALT DIRT 37+69.93 32+04.2533+0034+0035+0036+0037+0010+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 29+65.75 25+33.3826+0027+0028+0029+0028+59.6 5 29+00 30+00 31+00 32+00 33+00 34+00 35+00 35+35.75(51.0')(9.0')(63.0')(9.0')(60.0')(72.0')(51.0')(9.0')(60.0')(61.0')(44.0') (8.0') (104.0') (52.0') (52.0') (44.0') (104.0') (52.0') (52.0')28.0'28.0'56.0'18.0'18.0'10.0'10.0'28.0'28.0' 56.0' 12.0'12.0' WARNER A V E N U E VETERANSWAYARMSTRONG AVENUE℄℄℄ R/WR/WR/WEX. 12" WAEX. 72" SDEX. 18" SSEX. 10" R.W.EX. WA EX. 24" SD EX. EEX. EEX. E EX. 6" R.W. EX. 36" SD EX. 10" SS EX. 10" W A EX. EEX. EEX. EEX. EEX. E EXISTING CURB, GUTTER, AND SIDEWALKSEE SEPARATE APPROVED OFFSITEIMPROVEMENT PLANS (PREPARED BYOTHERS, CIP NO 70256) EXISTING CURB & GUTTER,PROTECT-IN-PLACE EXISTING (PUBLIC) FIRE HYDRANTSEE SEPARATE APPROVEDOFFSITE IMPROVEMENT PLAN(PREPARED BY OTHERS) EXISTING (PUBLIC) 8" SEWER LINESEE SEPARATE APPROVEDOFFSITE IMPROVEMENT PLANS(PREPARED BY OTHERS) EXISTING (PUBLIC) 8" SEWER LINE,SEE SEPARATE APPROVEDOFFSITE IMPROVEMENT PLANS(PREPARED BY OTHERS) EXISTING (PUBLIC) 10" DOMESTICWATER LINE, SEE PER SEPARATEAPPROVED OFFSITE IMPROVEMENTPLANS (PREPARED BY OTHERS) EXISTING 10" DOMESTIC WATER LINE, SEESEPARATE APPROVED OFFSITE IMPROVEMENTPLANS (PREPARED BY OTHERS) EXISTING FIREHYDRANT CONNECT TO EXISTING STORMDRAIN LATERAL; INSTALL STORMDRAIN MANHOLE PROPOSED DOMESTICWATER CONNECTION EXISTING (PUBLIC)SEWER MANHOLE43.46 INV-N PROPOSED (PRIVATE)MODULAR WETLANDSSTORMWATER SYSTEMEX. IRR.EXISTING (PUBLIC) FIRE HYDRANT,SEE SEPARATE APPROVEDOFFSITE IMPROVEMENT PLANS(PREPARED BY OTHERS);RELOCATE EXISTING HYDRANT 5'MIN. FROM PROPOSED DRIVEWAY EXISTING FIREHYDRANT EXISTING CURB & GUTTER, SEE SEPARATEAPPROVED OFFSITE IMPROVEMENT PLANS(PREPARED BY OTHERS, CIP NO 70256) DEMOLISH PORTION OF EXISTINGSTORM DRAIN LATERAL ANDCATCH BASIN; CAP STORM DRAINAT PROPERTY LINE EXISTING CURB & GUTTER,SEE SEPARATE APPROVEDOFFSITE IMPROVEMENT PLANS(PREPARED BY OTHERS, CIPNO 70256) DEMOLISH PORTION OFEXISTING STORM DRAINLATERAL AND CATCH BASIN 45.40INV PROPOSED (PRIVATE)SEWER MANHOLE42.67 INV-N42.57 INV-S PROPOSED(PRIVATE) CLEANOUT45.83 INV PROPOSED(PRIVATE) CLEANOUT47.83 INV PROPOSED8" (PRIVATE) SEWER PROPOSED(PRIVATE) 8" SEWER PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED (PRIVATE)OLDCASTLE STORMWATERMODULES (16 UNITS)PROPOSED (PRIVATE)OLDCASTLE STORMWATERMODULES (16 UNITS) PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED FIRE WATERWATER CONNECTION PROPOSED FIRE WATERWATER CONNECTION PROPOSED DOMESTICWATER CONNECTION PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED (PRIVATE)FIRE HYDRANT PROPOSED (PRIVATE)FIRE HYDRANT PROPOSED (PRIVATE)FIRE HYDRANT PROPOSED(PRIVATE) FIREHYDRANT EXISTINGSTREET LIGHT EXISTINGSTREET LIGHT (70.0')PROPOSED(PRIVATE) 12"STORM DRAIN 34+02 B B C C PROPOSEDLOT LINEA A PROPOSED (PRIVATE)6" FIRE WATER LINE (9.0')28.0'28.0'56.0'18.0'18.0'10.0'10.0'R/W30.0'40.0' 70.0' 20.0'30.0'10.0'10.0' PROPOSEDLOT LINE PROPOSED (PRIVATE)6" FIRE WATER LINE PROPOSED (PRIVATE)6" DOMESTIC WATER LINE R/WR/WS PROPOSED (PRIVATE)BACKFLOW PREVENTERPROPOSED (PRIVATE)BACKFLOW PREVENTER EXISTINGSTREET LIGHT EXISTINGSTREET LIGHT R/W EXISTING BIOSWALE,SEE SEPARATE APPROVED OFFSITEIMPROVEMENT PLANS(PREPARED BY OTHERS, CIP NO 70256) NOT A PA R T PROPOSED(PRIVATE) CLEANOUT43.37 INV EXISTING (PUBLIC)SEWER MANHOLE41.86 INV-W41.96 INV-E42.06 INV-N 6.0' 6.0'3.0'3.0'4.3'PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE ASSISTED LIVING/MEMORY CARE TRASHSTAGING CORRAL ACTIVE ADULTTRASH STAGINGAREA TRASHROOM TRASHROOM PROPOSED 18"CONNECTOR PIPEAND TRANSITIONSTRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSED (PRIVATE)STORM DRAINTRANSITION STRUCTURE PROPOSEDGENERATOR,FUEL STORAGE CAP EXISTING STORMDRAIN CONNECTOR PIPEAT PROPERTY LINE PROPOSED (PRIVATE)SEWER MANHOLE44.04 INV PROPOSED (PRIVATE)8" SEWER PROPOSED (PRIVATE)48" STORM DRAIN PROPOSED (PRIVATE)CLEANOUT 46.48 INV PROPOSED (PRIVATE)4" DOMESTIC WATER LINEAND BACKFLOW PREVENTER PROPOSED (PRIVATE)6" FIRE WATER LINE ANDBACKFLOW PREVENTER PROPOSED (PRIVATE)CLEANOUT 45.80 INV 47.95INV 48.84INV PROPOSED(PRIVATE) CLEANOUT49.08 INV PROPOSED(PRIVATE) CLEANOUT49.69 INV PROPOSED8" SEWER PROPOSED 6"FIRE WATER LINE PROPOSED OLDCASTLESTORMWATER MODULES PROPOSEDMULTI-STORYBUILDING PROPOSEDMULTI-STORYBUILDING PROPOSED OLDCASTLESTORMWATER MODULES2.0' 10.2' PROPOSED 48"STORM DRAIN PROPOSEDMULTI-STORYBUILDING5%MIN R/W ARMSTRONGAVENUE PROPOSEDSIDEWALKEXISTINGSURFACE 13.7' SWALE BERM R/WVETERANSWAY PROPOSEDSIDEWALK EXISTINGSURFACE PROPOSED8" SEWER PROPOSED 12"STORM DRAIN PROPOSEDMULTI-STORYBUILDING JOHN JOHNSON WAY C HPI ARCHITECTURE 2025 SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF THE ARCHITECT AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITH THEARCHITECT. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTODESK REVIT V. 2025 UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVALAutodesk Docs://Clearwater Tustin/Clearwater_Tustin_Site_R25.rvt10/1/2025 3:56:10 PMISSUED# DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL 123 ® 17542 17th St., Suite 150Tustin, CA, 92780Phone: 714.665.4500 2026-01-21 4TH ENTITLEMENT SUBMITTAL4 PRELIMINARYCOMPOSITEUTILITY PLAN C-2.0 LEGEND CBCLEEX.INV.IRR.MHN.A.P.SDSSR.W.R/WWA CATCH BASINCENTERLINEELECTRICALEXISTINGINVERTIRRIGATIONMANHOLENOT A PARTSTORM DRAINSANITARY SEWERRECYCLED WATERRIGHT-OF-WAYWATER SECTION A-A A A SECTION B-B B B C C SECTION C-C S SIGNALIZED INTERSECTION PROPOSED BACKFLOW PREVENTER 2026-01-23 373 0 I bd I J I ' -~--/4 I ' ' I ' ' ,/ i-~ ' ' I 'ff I □ i t __J __ _c__ __ /----lDCk____ i I --·~-o ) -----~p-:--c======l I ■ HPIARCHITECTURE.COM ~~~_;;;:~6442 CLEARWATER: AT TUSTIN LEGAC ~y CLEARWATER LIVI NG •confluent •• senior living 0 L1 CONCEPTUALLANDSCAPE PLAN NORTH 60300 1’=30’ - 0” SCALE CORNER ENLARGEMENT - NOT TO SCALE SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF URBAN ARENA AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITHURBAN ARENA. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTOCAD UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVAL12/3/2025 4:34 PMCLEARWATER AT TUSTIN LEGACY ISSUED#DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL OC SD OAK 3195 Red Hill Avenue, Loft FCosta Mesa, CA 92626 202 - - 4TH ENTITLEMENT SUBMITTAL20163 NOTE:A. PROJECT IS SUBJECT TO AND SHALL COMPLY WITH THE CITY’S WATER EFFICIENT LANDSCAPE ORDINANCE (WELO) AND WATER EFFICIENCY CALCULATIONS WILL BE PROVIDED AT THE TIME OF PLAN CHECK SUBMITTAL. B. ANY HARDSCAPE AND LANDSCAPE IMPROVEMENTS WITHIN LIMITED USE AREAS SHALL BE NO GREATER THAN 24 INCHES TALL. DIAMETER OF STREET TREES SHALL BE NO GREATER THAN 24”, INCLUDING CANOPIES, WITHIN THE AREA 84 INCHES ABOVE THE CURB. 1 1 1 6 2 7 3 8 4 4 4 9 9 10 11 LANDSCAPE BERMING / SCREENING VEHICLE DROP OFF ACTIVE ADULT AMENITY ROOF DECK COFFEE SHOP ASSISTED LIVING COURTYARD SHORT-TERM BIKE PARKING MONUMENT SIGNAGE ENHANCED PAVING BUS STOP OUTDOOR DINING LIMITED USE AREAS LADDER PAD PROPERTY LINE ENTRY MONUMENTATION 1 6 6 2 7 3 8 4 4 9 10 11 12 13 13 14 14 12 14 14 14 13 13 13 13 13 5 5ARMSTRONG AVENUEJOHN JOHNSON WAY WARNER AVENUE VETERANS WAY 12 12 CONCEPT PLANT SCHEDULECONCEPT PLANT SCHEDULECONCEPT PLANT SCHEDULE TREES (36" BOX MINIMUM)132ARBUTUS X 'MARINA' / MARINA STRAWBERRY TREE 36" BOXLAGERSTROEMIA INDICA / CRAPE MYRTLE 36" BOXLOPHOSTEMON CONFERTUS / BRISBANE BOX 36" BOXPLATANUS RACEMOSA / CALIFORNIA SYCAMOREP 36" BOX ACARANDA MIMOSIFOLIA / JACARANDA - LOW BRANCHINGJA 48" BOXOLEA EUROPAEA 'SWAN HILL' / SWAN HILL FRUITLESS OLIVEO 36" BOXOLEA EUROPAEA 'SWAN HILL' / SWAN HILL FRUITLESS OLIVEO 60" BOXTIPUANA TIPU / TIPU TREET 48" BOX JACARANDA MIMOSIFOLIA / JACARANDA - LOW BRANCHING 48" BOX QUERCUS AGRIFOLIA / COAST LIVE OAK 36" BOXQUERCUS AGRIFOLIA / COAST LIVE OAK MULTI-TRUNK 48" BOX QUERCUS AGRIFOLIA / COAST LIVE OAK 36" BOXQUERCUS AGRIFOLIA / COAST LIVE OAK MULTI-TRUNK 48" BOXLOPHOSTEMON CONFERTUS / BRISBANE BOX 36" BOX WATER QUALITY SHRUBS 194 SFCAREX DIVULSA / EUROPEAN GREY SEDGE 1 GALJUNCUS PATENS / CALIFORNIA GRAY RUSH1 GALMUHLENBERGIA RIGENS / DEER GRASS 1 GAL PARKWAY SHRUBS 4,434 SFCARISSA MACROCARPA 'GREEN CARPET' / GREEN CARPET NATAL PLUM 1 GAL SHRUBS 63,441 SFAGAVE ATTENUATA / FOXTAIL AGAVE 5 GALANIGOZANTHOS X 'RAMBOCITY' / BUSH TENACITY KANGAROO PAW 5 GALARMERIA MARITIMA / SEA THRIFT 1 GALBOUGAINVILLEA X 'MONKA' / OO-LA-LA® BOUGAINVILLEA 5 GALBOUTELOUA GRACILIS 'BLONDE AMBITION' / BLONDE AMBITION BLUE GRAMA 5 GALBUXUS MICROPHYLLA JAPONICA 'WINTER GEM' / WINTER GEM JAPANESE BOXWOOD 5 GALCARISSA MACROCARPA 'GREEN CARPET' / GREEN CARPET NATAL PLUM 1 GALDIANELLA REVOLUTA 'DR5000' / LITTLE REV™ FLAX LILY 1 GALFICUS PUMILA / CREEPING FIG 1 GALJUNCUS PATENS / CALIFORNIA GRAY RUSH5 GALLANTANA X 'NEW GOLD' / NEW GOLD LANTANA 1 GALLIGUSTRUM JAPONICUM 'TEXANUM' / TEXAS JAPANESE PRIVET 5 GALLOMANDRA LONGIFOLIA / MAT RUSH 1 GALMYOPORUM X 'PUTAH CREEK' / PUTAH CREEK MYOPRORUM 1 GALPHORMIUM TENAX 'CREAM DELIGHT' / CREAM DELIGHT NEW ZEALAND FLAX 5 GALSALVIA LEUCANTHA 'SANTA BARBARA' / SANTA BARBARA MEXICAN BUSH SAGE 5 GALSENECIO SERPENS / BLUE CHALKSTICKS 1 GALTRACHELOSPERMUM JASMINOIDES / CHINESE STAR JASMINE 5 GAL PARKWAY TREE (36" BOX MINIMUM)33LAURUS NOBILIS / SWEET BAY 36" BOX 12 PROPOSED LOT LINE 374 . -• • • • --- • • • • • • • • • • • • • • ■ HPIARCHlfECTURE.COM Newpc,nBe11th 949.675.6442 ~n Diego 858.203.4999 ,.1~ ~~ URBAN ARENA ~ CLEARWATER LIVI NG •confluent •• senior living L2 CONCEPTUAL LANDSCAPE PLAN - ASSISTED LIVING NORTH 20100 1’=10’ - 0” SCALE SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF URBAN ARENA AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITHURBAN ARENA. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTOCAD UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVAL12/3/2025 4:34 PMCLEARWATER AT TUSTIN LEGACY ISSUED#DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL OC SD OAK 3195 Red Hill Avenue, Loft FCosta Mesa, CA 92626 202 - - 4TH ENTITLEMENT SUBMITTAL20163 FOCAL SITE FEATURE GARDENING BEDS STAGE MULTI-USE TURF COVERED LOUNGE SEATING SENSORY PLANTING OUTDOOR DINING PRIVATE PATIO SECOND FLOOR PATIO TERRACE LADDER PAD POCKET SEATING 11 2 6 6 2 1 7 7 3 8 8 8 8 4 4 4 9 10 11 11 11 11 10 3 5 9 9 9 9 5 375 • • • • • • • • • • • ■ HPIARCHlfECTURE.COM NewportBe111;h 949.675.6442 ~n Diego SSS.203.4999 ,.1~ ~~ URBAN ARENA =---= CLEARWATER LIVI NG •confluent •• senior living L3 CONCEPTUAL LANDSCAPE PLAN - ACTIVE ADULT NORTH 20100 1’=10’ - 0” SCALE SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF URBAN ARENA AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITHURBAN ARENA. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTOCAD UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVAL12/3/2025 4:34 PMCLEARWATER AT TUSTIN LEGACY ISSUED#DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL OC SD OAK 3195 Red Hill Avenue, Loft FCosta Mesa, CA 92626 202 - - 4TH ENTITLEMENT SUBMITTAL20163 POOL FIREPIT LOUNGE SPA MULTI-USE TURF LOUNGE SEATING FIRE PIT & MEDIA WALL GRILL COUNTER PRIVATE PATIO LADDER PAD MEDIA WALL 1 1 2 6 2 7 7 3 3333 8 8 4 4 6 9 10 9 9 9 5 9 9 9 10 5 10 376 • • • • • • • • • • ■ HPIARCHlfECTURE.COM NewportBe111;h 949.675.6442 ~n Diego SSS.203.4999 ••• '~~ URBAN ARENA =---= CLEARWATER LIVI NG •confluent •• senior living L4 CONCEPTUAL LANDSCAPE PLAN - ACTIVE ADULT NORTH 20100 1’=10’ - 0” SCALE SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF URBAN ARENA AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITHURBAN ARENA. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTOCAD UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVAL12/3/2025 4:34 PMCLEARWATER AT TUSTIN LEGACY ISSUED#DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL OC SD OAK 3195 Red Hill Avenue, Loft FCosta Mesa, CA 92626 202 - - 4TH ENTITLEMENT SUBMITTAL20163 PICKLEBALL COURT BAR AREA/ LOUNGE POOL DECK BLEOW COURT BENCHES OUTDDOR BAR SEATING RAISED PLANTERS BISTRO SEATING 1 1 2 2 3 4 5 3 5 4 377 • • • • • ■ HPIARCHlfECTURE.COM NewportBe111;h 949.675.6442 ~n Diego SSS.203.4999 ,.1~ ~~ URBAN ARENA =---= CLEARWATER LIVI NG •confluent •• senior living L5 CONCEPTUAL PLANT PALETTE ARBUTUS MARINAStrawberry Tree PLATANUS RACEMOSA California Sycamore JACARANDA MIMOSIFOLIA Jacaranda LOPHOSTEMON CONFERTUS Brisbane Box CASSIA LEPTOPHYLLAGold Medallion Tree HANDROANTHUS HEPTAPHYLLUS Pink Trumpet Tree LAGERSTROEMIA INDICACrape Myrtle LAURUS NOBILISSweet Bay OLEA EUROPAEA ‘SWAN HILL‘ Swan Hill Olive PODOCARPUS GRACILIORFern Pine QUERCUS SPP.Oak AGAVE ATTENUATA Foxtail Agave JUNCUS PATENS California Gray Rush ANIGOZANTHOS ‘RAMOCITY‘ Kangaroo Paw MUHLENBERGIA RIGENS Deergrass CAREX TUMULICOLA Berkeley Sedge BOUGAINVILLEA SPP.Bougainvillea BOUTELOUA GRACILISBlue Grama BUXUS MICROPHYLLAJapanese Boxwood CARISSA MACROCARPANatal Plum DIANELLA REVOLUTAFlax Lilly FICUS PUMILACreeping Fig LANTANA ‘NEW GOLD‘ New Gold Lantana LIGUSTRUM JAPONICUM Texas Japanese Privet LOMANDRA LONGIFOLIA Mat Rush PHORMIUM TEXANUM New Zealand Flax SALVIA LEUCANTHA Mexican Bush Sage SENICIO SERPENS Blue Chalksticks TRACHELOSPERMUM JASMINOIDES Chinese Star Jasmin TREES SHRUBS WATER QUALITY PLANT PALETTE SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF URBAN ARENA AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITHURBAN ARENA. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTOCAD UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVAL12/3/2025 4:34 PMCLEARWATER AT TUSTIN LEGACY ISSUED#DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL OC SD OAK 3195 Red Hill Avenue, Loft FCosta Mesa, CA 92626 202 - - 4TH ENTITLEMENT SUBMITTAL20163 378 ■ HPIARCHlfECTURE.COM NewportBe111;h 949.675.6442 ~n Diego SSS.203.4999 ,.1~ ~~ URBAN ARENA =---= CLEARWATER LIVI NG •confluent •• senior living L6 CONCEPTUAL IMAGERY D SSRW C C C C C C SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF URBAN ARENA AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITHURBAN ARENA. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTOCAD UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVAL12/3/2025 4:34 PMCLEARWATER AT TUSTIN LEGACY ISSUED#DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL OC SD OAK 3195 Red Hill Avenue, Loft FCosta Mesa, CA 92626 202 - - 4TH ENTITLEMENT SUBMITTAL20163 379 ■ ~ CLEARWATER LIVI NG •conflue t ••senior 1· .n 1vmg L7 PEDESTRIAN CIRCULATION EXHIBIT NORTH 60300 1’=30’ - 0” SCALE SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF URBAN ARENA AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITHURBAN ARENA. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTOCAD UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVAL12/3/2025 4:34 PMCLEARWATER AT TUSTIN LEGACY ISSUED#DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL OC SD OAK 3195 Red Hill Avenue, Loft FCosta Mesa, CA 92626 202 - - 4TH ENTITLEMENT SUBMITTAL20163 LANDSCAPE BERMING / SCREENING VEHICLE DROP OFF ACTIVE ADULT AMENITY ROOF DECK COFFEE SHOP ASSISTED LIVING COURTYARD BIKE RACK MONUMENT SIGNAGE TRANSFORMER / GENERATOR / TRASH BUS STOP PRIMARY PEDESTRIAN CIRCULATION FIRE LANE LADDER PAD PROPERTY LINE SECONDARY PEDESTRIAN CIRCULATION ENTRY MONUMENTATION 1 1 1 66 6 2 2 7 7 3 3 8 8 4 4 4 4 9 9 10 10 11 12 13 13 13 13 12 12 12 12 12 11 5 5ARMSTRONG AVENUEJOHN JOHNSON WAY WARNER AVE N U E VETERANS WAY 380 • • • • • • • • • • • • • ■ HPIARCHlfECTURE.COM Newpc,nBe11th 949.675.6442 ~n Diego 858.203.4999 ,.1~ ~~ URBAN ARENA ~ CLEARWATER LIVI NG •confluent •• senior living L8 WALL AND FENCE PLAN NORTH 60300 1’=30’ - 0” SCALE SHEET NUMBER SHEET TITLE THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTYAND COPYRIGHT OF URBAN ARENA AND SHALL NOT BE USEDON ANY OTHER PROJECT OR LOCATIONS EXCEPT AS DESCRIBEDON THE DRAWINGS, WITHOUT WRITTEN AGREEMENT WITHURBAN ARENA. PROJECT IDENTIFICATIONTHE DRAWINGS IN THE SHEET INDEX WERE ORIGINALLY CREATEDIN AUTOCAD UNLESS OTHERWISE NOTED. SEAL THE ORIGINAL SIZE OF THIS SHEET IS 30" X 42". PROJECT TITLE CONSULTANTS CITY APPROVAL12/3/2025 4:34 PMCLEARWATER AT TUSTIN LEGACY ISSUED#DATE DESCRIPTION2025-06-26 1ST ENTITLEMENT SUBMITTAL2025-08-22 2ND ENTITLEMENT SUBMITTAL2025-10-09 3RD ENTITLEMENT SUBMITTAL OC SD OAK 3195 Red Hill Avenue, Loft FCosta Mesa, CA 92626 202 - - 4TH ENTITLEMENT SUBMITTAL20163LINE OF BUILDING ABOVELINE OF BUILDING ABOVELINE OF BUILDING ABOVELINE OF BUILDING ABOVE'1 BUILDING SIDE5' COMMON AREA - MUST BECLEAR OF ALL CLIMBABLESTRUCTURES INCLUDING WALLS,TREES, DRAINS, VALVE BOXES, &UTILITIES.POOL SIDE6'3'-6"10"6'FASCIA MOUNT SECTION NOTES: A. DETAIL IS FOR REFERENCE ONLY -CONSTRUCT PER SHOP DRAWINGS B. POOL FENCING TO ADHERE TO LOCALHEALTH CODES INCLUDING OVERALL HEIGHT,LIMITED GAP-SIZE OPENINGS, AND KNOX BOX BUILDING SIDEPOOL SIDECURB MOUNT SECTION 5'COMMON AREA CLEAR SPACE3' OR 4' - REFER TO PLAN SECTION ELEVATION 4 10 7 12 6 5 4 3 8 9 7 GLASS FENCE AND GATE N.T.S. 11 5 5' COMMON AREA - MUST BECLEAR OF ALL CLIMBABLESTRUCTURES INCLUDING WALLS,TREES, DRAINS, VALVE BOXES, &UTILITIES.6'5'COM M O N A R E A C L E A R S P A C E 15 16 PANIC BAR - DECK SIDE OF GATE, 'APEX 2400SERIES' OR EQUAL WITH ELECTRIC STRIKE POST1 STAINLESS STEEL POOL GATE HANDLE (OPPOSITEPOOL SIDE OF GATE) TO BE APEX 2900A SERIES OREQUAL 2 KEY FOB AND KNOX BOX - PER CONTRACTOR3 GLASS PANEL - SPECIFICATION AND INSTALLATIONPER MANUFACTURER'S RECOMMENDATIONS4 316 STEEL POST5 316 STEEL GATE FRAME6 ADJACENT PAVING - REFER TO CONSTRUCTIONPLAN7 AUTOMATIC CLOSING HINGES BY CRL, MODEL -TCHD1W OR EQUAL, INSTALL PERMANUFACTURER'S RECOMMENDATIONS 8 10" ALUMINUM KICK PLATE9 PLANTER WALL - REFER TO SEPARATE DETAIL10 DRAIN MAT AND WATERPROOFING WITHPROTECTION BOARD - SEE DRAWINGS BYWATERPROOFING CONSULTANT 11 CONCRETE CURB - SEE DRAWINGS BY ARCHITECT12 BASE PLATE - SEE DRAWINGS BY STRUCTURALENGINEER13 STRUCTURAL SLAB - SEE DRAWINGS BY ARCHITECT14 CURB MOUNTED BASE SHOE - FLUSH WITHFINISHED SURFACE15 FASCIA MOUNTED BASE SHOE16 2 1 7 12 14 11 14 15 11 P-21-148-01-1336 VARIES 12" TYPICAL PODIUM PLANTER N.T.S.32" OR 40"REFER TO CONSTRUCTION PLANSECTION NOTES: A. SEE DRAWINGS BY STRUCTURAL ENGINEER FOR ALLFOOTINGS AND REINFORCEMENTS B. THE USE OF FILTER FABRIC IS NOT RECOMMENDED BUILDING WALL1 MULCH LAYER - REFER TO PLANTINGSPECIFICATIONS2 MOUNDED PLANTER BACKFILL MIX - REFER TOPLANTING SPECIFICATIONS3 6" X 8" X 16" CMU - REFER TO CONSTRUCTIONPLAN FOR SPECIFICATION4 CONCRETE FOOTING - SLOPE TO DRAIN5 DRAIN MAT AND WATERPROOFING WITHPROTECTION BOARD - SEE PLANS BYARCHITECT/WATERPROOFING CONSULTANT 6 FINISH SURFACE - REFER TO PAVING SCHEDULE7 MORTAR LEVELING BED8 DRAINAGE SYSTEM - SEE DRAWINGS BYPLUMBING/CIVIL ENGINEER9 STRUCTURAL SLAB - SEE DRAWINGS BYSTRUCTURAL ENGINEER10 7 98 10 1 3 6 2 4 P-25-065.2-1-575 SECTION AT CMU TO GATE POST CONNECTION SECTION AT EDGE OF PATIO SLAB3'F.S. F.S. EQ.EQ. 11 3'-6"4'-1"0'-3"6"3'-6"6"PATIO WALL N.T.S. WALL CAP - SIZE: TBD - COLOR AND MANUFACTURERTBD1 STUCCO FINISH - COLOR TBD2 GATE POST - 2" SQ. TUBE STEEL 1/8 THICK - COLOR:TBD - SEE STRUCTURAL ENGINEER PLANS FOR BOLTCONNECTION 3 1 X 6 WOODEN SLATS - COLOR: TBD, SECURED TOPOSTS AND RAILS PER INSTALLING CONTRACTOR4 GATE HINGE - PER INSTALLING CONTRACTOR5 EXPANSION JOINT6 STEEL SLEEVE INTO DEEPENED CONCRETE FOOTING -SEE STRUCTURAL ENGINEER PLANS FOREMBEDMENT 7 8 X 8 X 8 CMU PILASTER BLOCK AVAILABLE FROMORCO BLOCK - CONTACT ALEXIS ROTH 714 527 2239 -SEE STRUCTURAL ENGINEER PLANS FORREINFORCEMENT AND FOOTING 8 CONCRETE FOOTING - SIZE, DEPTH, &REINFORCEMENT PER STRUCTURAL ENGINEER DETAILS9 COMPACTED SUBGRADE PER GEOTECHNICALRECOMMENDATIONS10 GATE LATCH AND HANDLE - PER INSTALLINGCONTRACTOR11 FENCE RAILINGS AND POSTS - 1 1/2 SQUARE TUBESTEEL1/8 THICK - COLOR: TBD 12 EDGE OF CONCRETE PATIO SLAB13 DEEPENED CONCRETE SLAB AT FENCE POSTS - SEESTRUCTURAL ENGINEERS PLAN FOR SIZE AND DEPTH.14 9 10 6 78 1 3 5 4 2 13 12 10 7 14 4 P-25-065.1-1-142 ELEVATION +/-20' SLIDING VEHICULAR GATE N.T.S. 26 6 1 7 3 5 2 GATE FRAME1 CORRUGATED METAL2 KNOX BOX3 4" SQUARE TUBULAR STEEL POST4 GATE MOTOR5 ADJACENT STUCCO WALL6TRACK WHEELS7 5 7 P-25-065.2-1-163 PPG DURANARCOLOR: BLACK UC40577 METAL FENCE8 PICKLEBALL FENCE1 ALMC PATIO WALL3 AA PATIO WALL4ARMSTRONG AVENUEJOHN JOHNSON W A Y WARNER AVENUE VETERANS WAYPATIO WALL PODIUM PLANTER PODIUM GLASS FENCE MONUMENT WALL PICKLEBALL FENCE AA PATIO WALL ALMC PATIO WALL SLIDING VEHICULAR GATE POOL/SPA MEDIA WALL METAL FENCE PARAPET WALL SCHEDULE DESCRIPTIONSYMBOL DETAIL 2 5 6 1 4 3 7 8 PER ARCH 381 I ■ HPIARCHITECTURE.COM NewponBeach 949.67S.6442 San Diego ·858.203.4999 ............... ,.,, .... .... ·~· ,,'rfi URBAN ARENA =--= CLEARWATER LIVI NG •confluent •• senior living UP UP UP UP UP UP DN 0,1  :,'(/$1'6&$3(%8))(521$5067521*$9( 3523(57</,1( WALKWAY XFORMERSWITCH GENERATOR AL TRASHENCLOSURESTAFF PATIO LANDSCAPING 02180(176,*1 9,6,%,/,7<75,$1*/( 02180(176,*1 02180(176,*1 02180(176,*1 $66,67('/,9,1*&2857<$5' ROLLING GATE ENCLOSURE WALL XFORMER XFORMER )8785(3523(57</,1( )8785(3523(57</,1( 3$5.,1**$5$*(#),567)/225 3523(57</,1( PROPERTY LINE BIOSWALE BY CITY OF TUSTIN PUBLIC WORKS (NOT IN PROJECT SCOPE. SHOWN FOR REFERENCE ONLY) PROPERTY LINE PROPERTY LINE BUS TURNOUT 0,1 :,'(/$1'6&$3(%8))(521$5067521*$9( MIN. 11'-0"-WIDE LANDSCAPE BUFFER ON WARNER AVE. MIN. 11'-0"-WIDE LANDSCAPE BUFFER ON WARNER AVE. SECONDARY BUILDING ENTRY ACCESS PATH TO BUS STOP 9,6,%,/,7<75,$1*/( VISIBILITY TRIANGLE 9,6,%,/,7<75,$1*/(25' - 0"25' - 0"SETBACK10' - 0"REQUIRED SETBACK10' - 0"REQUIRED4' - 0" SETBACK 20' - 0"REQUIRED25' - 0"25' - 0"11' - 0"SETBACK20' - 0"SETBACK20' - 0"REQUIRED25' - 0"25' - 0"11' - 0"02180(176,*1 25' - 0" 25' - 0" SETBACK 20' - 0"REQUIRED SETBACK10' - 0"REQUIRED SETBACK 10' - 0"REQUIRED SETBACK 20' - 0" RE QUIRE D SETBACK10' - 0"REQUI RED AA TRASH STAGING 4' - 0" MAX.PATIO WALL&+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ&OHDUZDWHUB7XVWLQB6LWHB5UYW30SITE PLAN AS-100 &/($5:$7(5$77867,1/(*$&< 6&$/(  6,7(3/$1 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ /,1(2)522)29(5+$1*$%29( /,1(2)%8,/',1*$%29(,1&/8',1*%$/&21<352-(&7,216 382 ■ ...... , .. ~ CLEARWATER LIVING conflu.~nt • senior living UP UP UP 3$5.,1**$5$*( (/(9 75$6+&+87( %2+ %2+ 67$,5 (/(9&75/ 67$,5 67$,5   322/(437 9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"9' - 0"9' - 0"5' - 7"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0" 9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"5' - 0"12' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0" 9' - 0"9' - 0"5' - 0"9' - 0" 9' - 0" 9' - 0"2' - 0"9' - 0"9' - 0" 9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0" 9' - 0"9' - 0" 9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0" 5 ' - 0" 9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"5' - 0"9' - 0"9' - 0"3' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"9' - 0"9' - 0"12' - 0"5' - 0"9' - 0"9' - 0"5' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"4' - 0" 9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"5' - 0"9' - 0"9' - 0"5' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0" 9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"3' - 0"9' - 0"5' - 0"12' - 0"6' - 0"5' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0" 9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"2' - 0"9' - 0"9' - 0"9' - 0"20' - 0"24' - 0"9' - 0"24' - 0"19' - 0"24' - 0"19' - 0"19' - 0"24' - 0"19' - 0"19' - 0"24' - 0"36' - 6"19' - 0" 25' - 0" 25' - 0"24' - 0"25' - 0"19' - 0" 13' - 6 1/2"36' - 5"17' - 2"44' - 6 1/2"19' - 0"24' - 0"19' - 0"19' - 0"19' - 0"19' - 0"19' - 0"75$6+&+87( /2%%< 0$,/%86&(17(5 6725/($6,1*5(&0$,172)) &21)0*5/($6,1*5(& 0('(/(9 (/(9&75/55 55 (/(9 1A-300-AA (/(&70(7(550 (/(&032( (/(&70(7(550 $0(1,7< &,5&8/$7,21 6833257 (/(9$725 *$5$*(   /,1(2)322/$%29( /,1(2)%8,/',1*$%29( /,1(2)%8,/',1*$%29( 22' - 0" 9' - 0" 9' - 0"9' - 0"9' - 0"9' - 0"9' - 0":$51(5$9(18(-2+1-2+1621:$<$&&(66,%/(5287( $&&(66,%/(5287($&&(66,%/(5287($&&(66,%/(5287( /$''(53$'7<3 /$''(53$'7<3 /$''(53$'7<3   $5067521*$9(18(     %$77(5<   &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB$5B5UYW30ACTIVE ADULT -FIRSTFLOOR PLAN A-201-AA &/($5:$7(5$77867,1/(*$&< 6&$/(  $&7,9($'8/7 *$5$*(/(9(/)/2253/$1 *$5$*((175<(;,7 %2+%$&.2)+286(&21)&21)(5(1&((/(9(/(9$725(/(9&75/(/(9$725&21752/(9&6 (/(&75,&9(+,&/(&+$5*,1*67$7,21(95 (/(&75,&9(+,&/(5($'<3$5.,1*63$&(0$,172))0$,17(1$1&(2)),&(0*50$1$*(5322/(437322/(48,30(176060$//67256725$*( %8,/',1*)/225$5($ ,1&/8',1*3$5.,1**$5$*((;&/8',1*%$/&21,(6  ),567)/225 6)6(&21')/225 6)7+,5')/225 6))2857+)/225 6)),)7+)/225 6)727$/ 6) 81,70,; 60%5%$ %5%$  %5%$;/  %5%$  %5%$;/  727$/  )/2253/$1/(*(1' )/2253/$1$%%5(9,$7,216 $&7,9($'8/7%8,/',1*,1)250$7,21 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 383 ___ /,. 11W D D -------------------- . ------ ■ □ ■ □ □ ■ ~ CLEARWATER LIVI NG •confluent •• senior living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■ □ ■ □ ■ □ ■ ■ ■ ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 SanDiego 858.203.4999 ~ CLEARWATER LIVI NG r. f.?n~J!Y;~R~ 0 DN 1A-300-AA $0(1,7< &,5&8/$7,21 6833257 (/(9$725 %5%$ %5%$;/ 60$//%5%$ %5%$ %5%$;/   :$51(5$9(18(-2+1-2+1621:$<  $5067521*$9(18(     75$6+&+87( 67$,5 (/(9 3,&./(%$//&2857 522)3$7,2 %2+ (/(& 7(/(&20 %2+ (/(9 (/(& 67$,5 7(/(&20 %2+ (/(& %2+ 75$6+&+87( 67$,5 0('(/(9 %$5$5($/281*( %5%$60%5%$%5%$ %5%$%5%$%5%$;/ %5%$ %5%$ %5%$;/ 60%5%$ %5%$ %5%$ %5%;/ %5%$ %5%$;/ %5%$;/ %5%$;/ %5%$%5%$60%5%$%5%$ %5%$;/%5%$;/%5%$;/ %5%$%5%$ %5%$%5%$ %5%$;/ %5%$;/ %5%$;/ %5%$;/ %5%$;/ %5%$ %5%$;/ %5%$;/ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$207' - 6"  )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,&   &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB$5B5UYW30ACTIVE ADULT -THIRDFLOOR PLAN A-203-AA &/($5:$7(5$77867,1/(*$&< 6&$/(  $&7,9($'8/7 7+,5')/2253/$1 )/2253/$1/(*(1' )/2253/$1$%%5(9,$7,216 %$%$7+5220%2+%$&.2)+286(%5 %('5220(/(9(/(9$725555(6752206060$//;/(;75$/$5*( ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ $&7,9($'8/77+,5')/22581,76800$5< 81,7180%(5 81,77<3( )/225$5($ %$/&21<$5($%5%$6)%5%$6)60%5%$6)%5%$6)%5%$6)%5%$;/6)%5%$6)%5%$;/6)%5%$6)60%5%$6)%5%$6)%5%$6)%5%$6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$6)%5%$;/6)%5%$6)%5%$;/6)60%5%$6)%5%$;/6)%5%$6)%5%$6)%5%$6)%5%$6)%5%$6)%5%$6)%5%$;/6)%5%$6)%5%$6)%5%$;/6)%5%$;/6)%5%$6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$6)%5%$6)%5%$6)%5%$6)7+,5')/225$&7,9($'8/781,766) %$/&21<$5($6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6) 385 ■ □ ■ □ ■ □ ■ ■ ■ ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 SanDiego 858.203.4999 ~ CLEARWATER LIVI NG r. f.?n~J!Y;~R~ 0 1A-300-AA &,5&8/$7,21 6833257 (/(9$725 %5%$ %5%$;/ 60$//%5%$ %5%$ %5%$;/    :$51(5$9(18(-2+1-2+1621:$<522) $5067521*$9(18(     75$6+&+87( 67$,5 0('(/(9 (/(& %2+ 7(/(&20 %2+ (/(& (/(9 67$,5 7(/(&20 %2+ %2+ (/(& 75$6+&+87(67$,5 (/(9 %5%$60%5%$%5%$ %5%$%5%$%5%$;/ %5%$ %5%$ %5%$;/ 60%5%$ %5%$ %5%$ %5%;/ %5%$ %5%$;/ %5%$;/ %5%$;/ %5%$%5%$60%5%$%5%$ %5%$;/%5%$;/%5%$;/ %5%$%5%$ %5%$%5%$ %5%$;/ %5%$;/ %5%$;/ %5%$;/ %5%$;/ %5%$ %5%$;/ %5%$;/ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$  207' - 6"   &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB$5B5UYW30ACTIVE ADULT -FOURTH FLOOR PLAN A-204-AA &/($5:$7(5$77867,1/(*$&< 6&$/(  $&7,9($'8/7 )2857+)/2253/$1 )/2253/$1/(*(1' )/2253/$1$%%5(9,$7,216 %$%$7+5220%2+%$&.2)+286(%5 %('5220(/(9(/(9$725555(6752206060$//;/(;75$/$5*( ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ $&7,9($'8/7)2857+)/22581,76800$5< 81,7180%(5 81,77<3( )/225$5($ %$/&21<$5($%5%$6)%5%$6)60%5%$6)%5%$6)%5%$6)%5%$;/6)%5%$6)%5%$;/6)%5%$6)60%5%$6)%5%$6)%5%$6)%5%$6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$6)%5%$;/6)%5%$6)%5%$;/6)60%5%$6)%5%$;/6)%5%$6)%5%$6)%5%$6)%5%$6)%5%$6)%5%$6)%5%$;/6)%5%$6)%5%$6)%5%$;/6)%5%$;/6)%5%$6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$6)%5%$6)%5%$6)%5%$6))2857+)/225$&7,9($'8/781,766) %$/&21<$5($6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6) 386 □ ■ [] ■ □ ■ ■ ■ ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 SanDiego 858.203.4999 ~ CLEARWATER LIVI NG r. f.?n~J!Y;~R~ 0 1A-300-AA &,5&8/$7,21 6833257 (/(9$725 %5%$ %5%$;/ 60$//%5%$ %5%$ %5%$;/        :$51(5$9(18(-2+1-2+1621:$<522)$&&(66/$''(5522)$&&(66/$''(5 $5067521*$9(18(      %5%$60%5%$%5%$ %5%$%5%$%5%$;/ %5%$ %5%$ %5%$;/ 60%5%$ %5%$ %5%$ %5%;/ %5%$ %5%$;/ %5%$;/ %5%$;/ %5%$%5%$60%5%$%5%$ %5%$;/%5%$;/%5%$;/ %5%$%5%$ %5%$%5%$ %5%$;/ %5%$;/ %5%$;/ %5%$;/ %5%$;/ %5%$ %5%$;/ %5%$;/ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$ 67$,5 75$6+&+87( (/(9 %2+(/(& 7(/(&20 %2+ (/(& (/(97(/(&20 %2+ (/(& %2+ 75$6+&+87( 0('(/(9 67$,5 67$,5207' - 6"     &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB$5B5UYW30ACTIVE ADULT -FIFTHFLOOR PLAN A-205-AA &/($5:$7(5$77867,1/(*$&< )/2253/$1/(*(1' )/2253/$1$%%5(9,$7,216 %$%$7+5220%2+%$&.2)+286(%5 %('5220(/(9(/(9$725555(6752206060$//;/(;75$/$5*( ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ $&7,9($'8/7),)7+)/22581,76800$5< 81,7180%(5 81,77<3( )/225$5($ %$/&21<$5($%5%$6)%5%$6)60%5%$6)%5%$6)%5%$6)%5%$;/6)%5%$6)%5%$;/6)%5%$6)60%5%$6)%5%$6)%5%$6)%5%$6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$6)%5%$;/6)%5%$6)%5%$;/6)60%5%$6)%5%$;/6)%5%$6)%5%$6)%5%$6)%5%$6)%5%$6)%5%$6)%5%$;/6)%5%$6)%5%$6)%5%$;/6)%5%$;/6)%5%$6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$;/6)%5%$6)%5%$6)%5%$6)%5%$6)),)7+)/225$&7,9($'8/781,766) %$/&21<$5($6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6)6) 6&$/(  $&7,9($'8/7 ),)7+)/2253/$1 387 1A-300-AA         23(172$$$0(1,7<522)'(&.%(/2:           522)7230(&+$1,&$/81,767<36((0(&+$1,&$/ 522)7230(&+$1,&$/81,767<36((0(&+$1,&$/0(0%5$1(522),1* 0(0%5$1(522),1*0(0%5$1(522),1*0(0%5$1(522),1* 0(7$/0(&+$1,&$/6&5((1 522)7233/80%,1*(48,30(176((3/80%,1* 0(7$/0(&+$1,&$/6&5((1 :$51(5$9(18(-2+1-2+1621:$<522)+$7&+:/$''(5$&&(66 522)+$7&+:/$''(5$&&(66 67$,572522) 3' - 6 1/8"   $5067521*$9(18( &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB$5B5UYW30ACTIVE ADULT -ROOFPLAN A-206-AA &/($5:$7(5$77867,1/(*$&< 6&$/(  $&7,9($'8/7 522)3/$1 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 388 ~ ' ! __J ■ FIRST FLOOR0' -0" SECOND FLOOR14' -0" THIRD FLOOR27' -0" FOURTH FLOOR38' -0" FIFTH FLOOR49' -0" ROOF60' -0"14' - 0"13' - 0"11' - 0"11' - 0"11' - 0" 4' - 0" T.O. PARAPET64' -0" %5%$;/ %5%$;/ %5%$;/ %5%$;/ 60$//%5%$ 60$//%5%$ 60$//%5%$ 60$//%5%$*5($75220$&7,9,7<5220 /($6,1*5(& /($6,1*5(&0$,/%86&(17(5 322/ 3$5.,1**$5$*( %$5$5($/281*( &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB$5B5UYW30ACTIVE ADULT -BUILDING SECTIONS A-300-AA &/($5:$7(5$77867,1/(*$&< 6&$/(  $&7,9($'8/7 %8,/',1*&52666(&7,21 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 389 ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 SanDiego 858.203.4999 ~ CLEARWATER LIVI NG r. f.?n~J!Y;~R~ 0 FIRST FLOOR0' -0" SECOND FLOOR14' -0" THIRD FLOOR27' -0" FOURTH FLOOR38' -0" FIFTH FLOOR49' -0" ROOF60' -0"4' - 0"11' - 0"11' - 0"11' - 0"13' - 0"14' - 0"60' - 0"*$5$*((175$1&( T.O. PARAPET64' -0" FIRST FLOOR0' -0" SECOND FLOOR14' -0" THIRD FLOOR27' -0" FOURTH FLOOR38' -0" FIFTH FLOOR49' -0" ROOF60' -0"4' - 0"11' - 0"11' - 0"11' - 0"13' - 0"14' - 0"60' - 0"T.O. PARAPET64' -0" FIRST FLOOR0' -0" SECOND FLOOR14' -0" THIRD FLOOR27' -0" FOURTH FLOOR38' -0" FIFTH FLOOR49' -0" ROOF60' -0"4' - 0"11' - 0"11' - 0"11' - 0"13' - 0"14' - 0"60' - 0"T.O. PARAPET64' -0"71' - 0" TO T.O. STAIR TOWERFIRST FLOOR0' -0" SECOND FLOOR14' -0" THIRD FLOOR27' -0" FOURTH FLOOR38' -0" FIFTH FLOOR49' -0" ROOF60' -0"4' - 0"11' - 0"11' - 0"11' - 0"13' - 0"14' - 0"60' - 0"T.O. PARAPET64' -0" &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB$5B5UYW30EXTERIOR ELEVATIONS A-400-AA &/($5:$7(5$77867,1/(*$&< 6&$/(  $&7,9($'8/7 ($67(/(9$7,21 6&$/(  $&7,9($'8/7 6287+(/(9$7,21 6&$/(  $&7,9($'8/7 :(67(/(9$7,21 6&$/(  $&7,9($'8/7 1257+(/(9$7,21 .(<127(6      $ %     12786(' */$66*8$5'5$,/ 9(57,&$/3,&.(7*8$5'5$,/ 12786(' ),%(5&(0(176,',1* 678&&260227+),1,6+Z5(9($/6 678&&2),1(6$1'),1,6+Z5(9($/6 23(5$%/(9,1</:,1'2: ),;('9,1</:,1'2: 6725()5217$66(0%/< :,5(0(6+6(&85,7<6&5((1 &$123<:),%(5&(0(17%2$5'81'(56,'(      0(7$/0(&+$1,&$/6&5((1&2/25720$7&+%8,/',1*(/(9$7,216 */$66'225Z9,1</:,1'2:6,'(/,7(6 52//'2:16(&85,7<'225 /,0(6721(7,/(6721(9(1((5 12786(' (;326('&21&5(7(  %8,/',1*6,*1$*(085$/  3/$17(5:),%(5&(0(176,',1* $%$$%$%% %%$$%%$$%8,/',1*6,*1$*(085$/$%$%%$$$$ $%$$%      ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ %%$  $ % %$ %%% 390 0 □ □ □ □ □ □ □ □ □ □ □ ~---- u Q □ □ □ □ □ □ □ □ □ l ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 SanDiego 858.203.4999 ~ CLEARWATER LIVI NG r. f.?n~J!Y;~R~ 0 DN &20081,7<7+($7(5 6+$5(' *5($75220/,9,1*5220 /2%%< A-400-AL 2 A-400-AL1 A-400-AL 4 A-400-AL3 :$<'5,9($,6/( 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0"9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0"9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0"3' - 0" 9' - 0" 9' - 0" 9' - 0"2' - 10"9' - 2" 9' - 0" 9' - 0" 3' - 0"9' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0"30' - 0"9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 9' - 0" 9' - 0" 3' - 0" 9' - 0" 24' - 8" ',6&29(5< 1A-300-AL 3A-300-AL -2+1-2+1621:$<9(7(5$16:$<:$51(5$9(18( )255(6,'(1786(21/<12723(1727+(38%/,& /$''(53$'7<3 +,*+)(1&( /$''(53$'7<3 /$''(53$'7<3 /$''(53$'7<3 /$''(53$'7<375$6+(1&/2685(*(1(5$725   374' - 3"348' - 5"43' - 6"%5%$%5%$%5%$ %5%$ %5%$%5%$ %5%$ 60%5%$ %5%$ %5%$ %5%$ 60%5%$ %5%$;/%5%$;/%5%$;/%5%$;/ %5%$ %5%$ %5%$ %5%$%5%$ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$60%5%$ 67$,5 67$,5 75 (/(90$&+,1(50 0('(/(9 67$,5 55 %2':25.50 6$/(6 6$/(63$5&(/ ('2)),&( 5(&(3 :+(5 67$))%5($.50 &+() /9 (/(9 67$)) 0$,/%86,1(66 35,9$7(',1,1* ',1,1* $/ ',1,1* $/ 287'225 &$5'5220 5555:$/.(56725 6$/21 $48$/281*( %$5 .,7&+(1 ',1,1*&/8% $$ 35,9$7(',1,1* 23(1.,7&+(1 :,1(%$5 $$ 9(67 5555 *<0 :(//1(66 '5<6725.,7&+(16725 6(5967$ (/(& (/(90$&+,1(50 7()(/(& %,.(6725 )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& 67$,5 :$<'5,9($,6/(292' - 9"318' - 6" 2A-300-AL &20021$5($6 &,5&8/$7,21 %$&.2)+286( %2+  60$//%('%$7+ %('%$7+ %('%$7+ %('%$7+;/ &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$VVLVWHGB/LYLQJB$5B5UYW30ASSISTED LIVING -FIRST FLOOR PLAN A-201-AL &/($5:$7(5$77867,1/(*$&< 6&$/(  $66,67('/,9,1* ),567)/2253/$1 $$$&7,9($'8/7$/$66,67('/,9,1*%$%$7+5220%2'%2$5'2)',5(&7256%2+%$&.2)+286(%5 %('5220&175 &(17(5&21)&21)(5(1&(('(;(&87,9(',5(&725(/(9(/(9$725(9&6 (/(&75,&9(+,&/(&+$5*,1*67$7,21(95 (/(&75,&9(+,&/(5($'<3$5.,1*63$&(50 5220555(6752206060$//67256725$*( %8,/',1*)/225$5($ ,1&/8',1*3$5.,1**$5$*((;&/8',1*%$/&21,(6 3$5.,1**$5$*( 6)),567)/225 6)6(&21')/225 6)727$/ 6) 81,70,;$66,67('/,9,1*60%5%$ %5%$  %5%$  %5%$;/  727$/  0(025<&$5(678',2 727$/  )/2253/$1/(*(1' )/2253/$1$%%5(9,$7,216 $66,67('/,9,1*%8,/',1*,1)250$7,21 $/&2857<$5' ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 391 0 0 ,-, ~t• -· --;. •. • ~ ' " • --.--e:El-•~'"•7--r -o,..:r--~+-~:_, ~ + I ~ t i ■ □ ■ ■ ■ ■ □ ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 San Diego 858.203.4999 ~ CLEARWATER LIVING r. f.?n~J!Y;~R~ 0 0&',1,1* 6(59(5< 1A-300-AL 3A-300-AL 522)%(/2: -2+1-2+1621:$< :$51(5$9(18(9(7(5$16:$<7' - 0" 522)$&&(66/$''(5 522)$&&(66/$''(5 )255(6,'(1786(21/<12723(1727+(38%/,& 293' - 1"374' - 3" 0&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',2 %5%$%5%$%5%$ %5%$ %5%$%5%$ %5%$ 0&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',20&678',2 60%5%$ %5%$ 60%5%$ %5%$ %5%$ %5%$ %5%$ 60%5%$ 60%5%$ %5%$ %5%$;/%5%$;/%5%$;/%5%$;/%5%$;/ %5%$%5%$60%5%$%5%$60%5%$%5%$60%5%$%5%$60%5%$%5%$%5%$%5%$ %5%$ %5%$ 60%5%$ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$ %5%$ 67$,5/9 (/(& 0('(/(9 %2+ %2+ (/(&7+(5$3<9,578$/'5 67$,5 7(/(&20 67$,5 $&7,9,7<5220 /$81'5< 0&%$/&21< $&7,9,7<5220 /$81'5< 55 0('6 &$5(*,9(5 ',5(&725 0(',$5220 /,9,1*5220 (/(9   )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& )255(6,'(1786(21/<12723(1727+(38%/,& 67$,5 522)%(/2: 522)%(/2: 522)%(/2:347' - 8"320' - 1" 2A-300-AL &20021$5($6 &,5&8/$7,21 %$&.2)+286( %2+ 60$//%('%$7+ %('%$7+ %('%$7+ 0&678',2 %('%$7+;/ 0&%$/&21< 81,7%$/&21,(6 &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$VVLVWHGB/LYLQJB$5B5UYW30ASSISTED LIVING -SECOND FLOOR PLAN A-202-AL &/($5:$7(5$77867,1/(*$&< 6&$/(  $66,67('/,9,1* 6(&21')/2253/$1 %$%$7+5220%2+%$&.2)+286(%5 %('5220&175 &(17(5(/(9(/(9$725/1'5</$81'5<0&0(025<&$5(0('6 0(',&$7,216505220555(6752206060$// )/2253/$1/(*(1' )/2253/$1$%%5(9,$7,216 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 392 ■ □ ■ ■ ■ ■ □ ■ □ □ ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 San Diego 858.203.4999 ~ CLEARWATER LIVING r. f.?n~J!Y;~R~ 0 1A-300-AL 3A-300-AL 23(172&2857<$5'%(/2: 522)7230(&+$1,&$/81,767<36((0(&+$1,&$/ 522)7230(&+$1,&$/81,767<36((0(&+$1,&$/ 0(0%5$1(522)0(0%5$1(522)0(0%5$1(522)0(7$/0(&+$1,&$/6&5((1 6/23('39&522) 522)7233/80%,1*(48,30(177<36((3/80%,1* 0(7$/0(&+$1,&$/6&5((1 522)7230(&+$1,&$/81,767<36((0(&+$1,&$/ -2+1-2+1621:$< :$51(5$9(18(9(7(5$16:$<522)+$7&+:/$''(5$&&(66 522)+$7&+Z/$''(5$&&(66 6/23('39&522)6/23('39&522) 6/23('39&522)293' - 1"320' - 4" 2A-300-AL &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$VVLVWHGB/LYLQJB$5B5UYW30ASSISTED LIVING -ROOF PLAN A-203-AL &/($5:$7(5$77867,1/(*$&< 6&$/(  $66,67('/,9,1* 522)3/$1 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 393 I ;a r I C: l µ I I ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 San Diego 858.203.4999 ~ CLEARWATER LIVING r.confluent senior living 0 FIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0" %5%$ 6$/(6 &$5'5220 14' - 0"12' - 0" 4' - 0"30' - 0"6$/21 $&7,9,7<5220 3$5&(/&255 %5%$%5%$%5%$ &255 &255 *5($75220/,9,1*5220 FIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0" 0& 678',2 %5%$ 0& 678',20& 678',2 %5%$;/ 60$//%5%$4' - 0"12' - 0"14' - 0"3$5.,1**$5$*(%5%$ %5%$;/ %5%$30' - 0"FIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0" 0&',1,1*6(59(5< 60$//%5%$4' - 0"12' - 0"14' - 0"30' - 0".,7&+(1&20081,7<7+($7(5 6+$5(' 55 55 /,9,1*52200(',$5220 :,1(%$5 $$ &255,'25 .,7&+(16725 60$//%5%$ &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$VVLVWHGB/LYLQJB$5B5UYW30ASSISTED LIVING -BUILDING SECTIONS A-300-AL &/($5:$7(5$77867,1/(*$&< 6&$/(  $66,67('/,9,1* 6(&7,21 6&$/(  $66,67('/,9,1* 6(&7,21 6&$/(  $66,67('/,9,1* 6(&7,21 ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ 394 ■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 San Diego 858.203.4999 ~ CLEARWATER LIVING r. f.?n~J!Y;~R~ 0 FIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0"     7272522)FIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0"     7272522)FIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" *$5$*((175$1&( T.O. PARAPET30' -0"     7272522)FIRST FLOOR0' -0" SECOND FLOOR14' -0" T.O. ROOF26' -0" T.O. PARAPET30' -0"     7272522)&+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$VVLVWHGB/LYLQJB$5B5UYW30ASSISTED LIVING -EXTERIOR BUILDINGELEVATIONS A-400-AL &/($5:$7(5$77867,1/(*$&< 6&$/(  $66,67('/,9,1* ($67(/(9$7,21 6&$/(  $66,67('/,9,1* 6287+(/(9$7,21 6&$/(  $66,67('/,9,1* :(67(/(9$7,21 6&$/(  $66,67('/,9,1* 1257+(/(9$7,21 .(<127(6      $ %     12786(' */$66*8$5'5$,/ 9(57,&$/3,&.(7*8$5'5$,/ )$8;-8/,(7%$/&21< ),%(5&(0(176,',1* 678&&260227+),1,6+Z5(9($/6 678&&2),1(6$1'),1,6+Z5(9($/6 23(5$%/(9,1</:,1'2: ),;('9,1</:,1'2: 6725()5217$66(0%/< :,5(0(6+6(&85,7<6&5((1  &$123<:),%(5&(0(17%2$5'81'(56,'(     */$66'225Z9,1</:,1'2:6,'(/,7(6 52//'2:16(&85,7<'225 /,0(6721(7,/(6721(9(1((5 12786(' (;326('&21&5(7(  %8,/',1*6,*1$*(  39&522),1*  0(7$/:,1'2:$:1,1*:7,(%$&.6 75(//,6 3/$17(5:),%(5&(0(176,',1*  522)($9(:,7+5$)7(57$,/6  0(7$/0(&+$1,&$/6&5((1&2/25720$7&+%8,/',1*(/(9$7,216 %%%$%$  $ $$$$ %$%%%$ $$%%$%%%     % ,668(' '$7( '(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 7+(17,7/(0(1768%0,77$/ %$% %%  %% $ %$   $  395 -□ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ • □ □ ■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■ HPIARCHITECTUAE.COM Newpon Beach 949.675.6442 San Diego 858.203.4999 ~ CLEARWATER LIVING r. f.?n~J!Y;~R~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~ ....11. MA> ~, ..... HI N - i i ~ ...u.l MAX MAX I M TYPICAL BERM DETAIL SCAI.E;N,T,S. 0 0 0 0 TYPICAL BERM DETAIL ■ HPIARCHITECTURE.COM Newpon Beach 949.675.6442 San Diego 858.203.4999 ~ CLEARWATER LIVING •confluent •• senior living 0 5160 Carroll Canyon Rd, Suite 200San Diego, California 92121Consulting Engineers 858 200-0030 858 200-0037www.ma-engr.comTF LPAN TE A A EDR TSIEGRSET NRLFAOIFCOEXP. 6/30/2027 I LA E E18803 E B L LACIRCT S HEE A I IERENGNFRO OIESS HSAH 6821 &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 ZZZKSLDUFKLWHFWXUHFRP&RUQHUVWRQH&RXUW:HVW6DQ'LHJR&$R &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB0$B(/(&B5UYW30SITE PHOTOMETRICCALCULATIONS XE-1.1 127)25&216758&7,21 STREET LIGHT (TYP.)6($/ ,668('  '$7('(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 399 ouro -•·· ,--, L ~~ ·=:.::=-..=. .. •==-~----l::::-__ _ l=::::.:ic~ I;:."!:"-==-- Gtflerallll.,.natK111RoundOownl1M a ----l:ICI CUilB @gothanTIE v a L O-S.riesSize1 ,.,, __ Q GO? ...... ■ HPIARCHITECTURE.COM Newport Beach -949.675.644:2 San Diego • 858.203.4999 .............. , .. ,., ..... ~ CLEAR.WATER LIVI NG r.f.?n?J!Y;~R~ 0 5160 Carroll Canyon Rd, Suite 200San Diego, California 92121Consulting Engineers 858 200-0030 858 200-0037www.ma-engr.comTF LPAN TE A A EDR TSIEGRSET NRLFAOIFCOEXP. 6/30/2027 I LA E E18803 E B L LACIRCT S HEE A I IERENGNFRO OIESS HSAH 6821 &+3,$5&+,7(&785( 6+((7180%(5 6+((77,7/( 7+(6('5$:,1*6$1'63(&,),&$7,216$5(7+(3523(57<$1'&23<5,*+72)7+($5&+,7(&7$1'6+$//127%(86('21$1<27+(5352-(&725/2&$7,216(;&(37$6'(6&5,%('217+('5$:,1*6:,7+287:5,77(1$*5((0(17:,7+7+($5&+,7(&7 352-(&7,'(17,),&$7,217+('5$:,1*6,17+(6+((7,1'(;:(5(25,*,1$//<&5($7(',1$872'(6.5(9,7981/(6627+(5:,6(127(' 6($/ 7+(25,*,1$/6,=(2)7+,66+((7,6; 352-(&77,7/( &2168/7$176 ZZZKSLDUFKLWHFWXUHFRP&RUQHUVWRQH&RXUW:HVW6DQ'LHJR&$R &,7<$33529$/$XWRGHVN'RFV&OHDUZDWHU7XVWLQ%OGJB$FWLYHB$GXOWB0$B(/(&B5UYW30SITE PHOTOMETRICCALCULATIONS -RENDER XE-1.1A 127)25&216758&7,21 6($/ ,668('  '$7('(6&5,37,21 67(17,7/(0(1768%0,77$/ 1'(17,7/(0(1768%0,77$/ 5'(17,7/(0(1768%0,77$/ 400 ■ HPIARCHITECTURE.COM Newport Beach -949.675.644:2 San Diego • 858.203.4999 .............. , .. ,., ..... ~ C LEARWATER LIVI NG r.f.?n?J!Y;~R~ 0 401 RANCHO SANTIAGO 2323 North Br way • • Ana C4 Q2706 -1640 • (7 l .4) .480-7300 • WW\ ,-~cc.d edv Community College District May 8, 2026 City of Tustin Community Development Depa1tment Attn: Jorge Maldonado, Senior Planner City of Tustin 3 00 Centennial Way Tustin, CA 92780 RE: Tentative Parcel Map No. 2025-151 -Clearwater Living To Whom It May Concern: Via email: imaldonado@,TustinCA.org On behalf of the Rancho Santiago Community College District, this letter shall serves as a comment to the above referenced Tentative Parcel Map No. 2025-141 -Clearwater Living. The District has facilities located at 15991 Annstrong Boulevard, Tustin, CA 92782. This location is home to Criminal Justice Academies (CJA) and provides important training as pait of the of the District's public safety programs. Upon review of the plan, the District recommends a spatial buffer directly across from the CJA property to any new residential units. An increased spatial separation will reduce the amount of sound transmission. Spatial separation could be achieved by placing a green buffer zone, retail or commercial uses, parking lot/structure or increased setback for residential units across from the CJA. Thank you for the opportunity to respond and provide comments. Please feel free to contact my office at (714) 480-7510 if you need further assistance. Sincerely, ClM- Carri M. Matsumoto, Assistant Vice Cha11cellor Facility Planning, Construction & District Support Services Cc: Iris I. Ingrain, Vice Cha11cellor of Business Services ARD O T lJ Tl' S TmoA 1c M,11, EdD • D ,dCr I • J I d l • C 1110 p I I I $ • D01 r n • Phr tlA I LO (ir Ill crl :z ATTACHMENT 6 RADIUS AND LOCATION MAP CLEARWATER AT TUSTIN LEGACY 300 Feet 500 Feet 1,000 Feet 402 LAND USE APPLICATION FACT SHEET 1. LAND USE APPLICATION NUMBER(S): DA 2025-0001, SUB 2025-0003 (TPM 2025-151), CUP 2025-0012, DR 2025-0008, GPC 2026-0002, AND DENSITY BONUS REQUEST 2. ADDRESS: SOUTHEAST CORNER OF WARNER AVENUE AND ARMSTRONG AVENUE (LOT 14 OF TRACT 18197; NO SITUS ADDRESS ASSIGNED) 3. APN(S): 430-481-012 4. PREVIOUS APPLICATION RELATING TO THIS PROPERTY: NONE. THE SUBJECT SITE WAS CREATED AS LOT 14 OF TRACT MAP 18197, RECORDED DECEMBER 10, 2020. 5. SURROUNDING LAND USES: NORTH: WARNER AVENUE; UNDEVELOPED LAND EAST: VETERANS WAY; UNDEVELOPED LAND SOUTH: JOHN JOHNSON WAY; FUTURE LEGACY LINEAR PARK EXTENSION AND MULTIPLE FAMILY RESIDENTIAL WEST: ARMSTRONG AVENUE; UNDEVELOPED LAND 6. SURROUNDING ZONING DESIGNATION: NORTH: TUSTIN LEGACY SPECIFIC PLAN (SP-1) EAST: TUSTIN LEGACY SPECIFIC PLAN (SP-1) SOUTH: TUSTIN LEGACY SPECIFIC PLAN (SP-1) WEST: TUSTIN LEGACY SPECIFIC PLAN (SP-1) 7. SURROUNDING GENERAL PLAN DESIGNATION: NORTH: TLSP - TUSTIN LEGACY SPECIFIC PLAN EAST: TLSP - TUSTIN LEGACY SPECIFIC PLAN ATTACHMENT 7 403 SOUTH: TLSP - TUSTIN LEGACY SPECIFIC PLAN WEST: TLSP - TUSTIN LEGACY SPECIFIC PLAN 8. SITE LAND USE: A. EXISTING: VACANT/UNDEVELOPED B. PROPOSED: 172 RESIDENTIAL UNITS FOR ACTIVE SENIORS (INCLUDING 26 UNITS AFFORDABLE TO LOWER INCOME HOUSEHOLDS) AND AN APPROX. 143,000 SQUARE FOOT ASSISTED LIVING AND MEMORY CARE FACILITY (103 UNITS/134 BEDS) C. GENERAL PLAN: TUSTIN LEGACY SPECIFIC PLAN (NO CHANGE) D. ZONING: TUSTIN LEGACY SPECIFIC PLAN (SP-1), PLANNING AREA 8, 13, AND 14 - MIXED-USE URBAN (NO CHANGE) DEVELOPMENT FACTS: 9. LOT AREA: 6.14 GROSS ACRES (267,385 SF) / 6.04 NET ACRES (263,125 SF) PARCEL 1 (ACTIVE ADULT): 121,531 SF (2.79 ACRES) PARCEL 2 (AL/MC): 145,854 SF (3.35 ACRES) 10. BUILDING AREA: 435,926 SF TOTAL GROSS FLOOR AREA BUILDING 1 (ACTIVE ADULT): 293,360 SF - 5 STORIES / 71 FEET MAX. BUILDING 2 (AL/MC): APPROX. 143,000 SF - 2 STORIES / 35.6 FEET MAX. 11. PARKING: PER TCC SECTION 9263 REQUIRED: 235 SPACES (190 ACTIVE ADULT; 45 ASSISTED LIVING/MEMORY CARE) 404 PROVIDED: 278 SPACES (211 ACTIVE ADULT; 67 ASSISTED LIVING/MEMORY CARE) 12. CONSTRUCTION: NEW CONSTRUCTION; SINGLE PHASE 13. SIGNAGE: SUBJECT TO THE TCC; MASTER SIGN PLAN REQUIRED 14. LANDSCAPING: 29,455 SF 15. DENSITY BONUS: 38.75% (124 BASE UNITS; 173 UNITS PERMITTED; 172 PROPOSED), WITH ONE (1) INCENTIVE AND FOUR (4) WAIVERS DEVELOPMENT STANDARD COMPARISON STANDARD TLSP REQUIREMENT PROPOSED PROJECT Status Lot Area Non-Res.: Min. 8,000 SF Res.: No min. Non-Res: 145,854 SF Res: 121,531 SF Complies Building Height Max. 150 ft Bldg. 1: 71 ft Bldg. 2: 35.6 ft Complies Setbacks Warner Ave: 20 ft Armstrong Ave: 20 ft Local Roads: 10 ft Warner Ave: 15 ft Armstrong Ave: 15 ft Local Roads: 5 ft Waived per Density Bonus Private Open Space 100 SF per unit 127 units with patios below 100 SF; 7 units w/o balconies Waived per Density Bonus Common Open Space 100 SF per unit (17,200 SF) 21,964 SF Complies 405