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Resolution Number 20-06-02-02RESOLUTION NO. 20-06-02-02 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN JUAN CAPISTRANO ADOPTING ENVIRONMENTAL FINDINGS PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT, CERTIFYING THE GANAHL LUMBER PROJECT FINAL ENVIRONMENTAL IMPACT REPORT (SCH #2019050015), ADOPTING A STATEMENT OF OVERRIDING CONSIDERATIONS AND THE MITIGATION MONITORING AND REPORTING PROGRAM, AND APPROVING THE PROJECT WHEREAS, the Ganahl Lumber Project ("Project") proposes to develop three separate development areas, which would include two drive-through restaurants, Ganahl Lumber hardware store and lumber yard, and a crushed -rock gravel area for short-term vehicle storage; and WHEREAS, the Project is located on an approximately 17 -acre site in the City of San Juan Capistrano, generally bounded to the south by Stonehill Drive, to the west by San Juan Creek Channel and Trail, to the east by the Los Angeles—San Diego—San Luis Obispo (LOSSAN) rail corridor, and to the north by the Capistrano Valley Mobile Estates (CVME) mobile home park; and WHEREAS, the Project requires approvals of Property Sale and Development Agreements, a grading plan modification, architectural control, flood plain land use permit, sign permit program, and tentative tract map; and WHEREAS, the Project requires approval of the retail activities proposed for the Ganahl Lumber hardware store as an unlisted use in the CM zone to determine whether they fall within the purpose and intent of the CM zone; and WHEREAS, pursuant to section 21067 of the Public Resources Code, and section 15367 of the State CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.), the City of San Juan Capistrano is the lead agency for the proposed Project; and WHEREAS, in accordance with State CEQA Guidelines section 15063, the City evaluated the Project by preparing an Initial Study, to evaluate whether an Environmental Impact Report ("EIR") was required; and WHEREAS, based on the Initial Study, the City determined that an EIR should be prepared because the Project may have a significant effect on the environment in the following areas: aesthetics, biological resources, geology/soils, hydrology/water quality, noise, utilities/service systems, cultural resources, greenhouse gas emissions, land use/planning, transportation/traffic, air quality, energy, hazards and hazardous materials, tribal cultural resources; and WHEREAS, based on the Initial Study, the City further determined that impacts to agricultural resources, mineral resources, population and housing, public services, 1 6/2/2020 recreation, and wildfire would be less than significant and thus need not be analyzed further in the EIR; and WHEREAS, in accordance with State CEQA Guidelines section 15082, on May 22, 2019, the City sent to the Office of Planning and Research and each responsible and trustee agency a Notice of Preparation ("NOP") stating that an Environmental Impact Report (State Clearinghouse Number #2019050015) would be prepared; and WHEREAS, pursuant to Public Resources Code section 21083.9 and State CEQA Guidelines sections 15082(c) and 15083, the City held a duly noticed Scoping Meeting on June 6, 2019, to solicit comments on the scope of the environmental review of the proposed Project and eleven (11) comments were received; and WHEREAS, a Draft Environmental Impact Report ("Draft EIR") was prepared, incorporating comments received in response to the NOP; and WHEREAS, the Draft EIR determined that mitigation measures were required to mitigate impacts to a less than significant level for the following resource areas: aesthetics, biological resources, cultural resources, geology and soils, hazards and hazardous materials, noise, tribal cultural resources, utilities and service systems, and WHEREAS, the Draft EIR further concluded that despite the incorporation of all feasible mitigation measures, the proposed Project would nonetheless result in significant and unavoidable impacts relating to transportation; and WHEREAS, in accordance with State CEQA Guidelines section 15085, a Notice of Completion was prepared and filed with the Office of Planning and Research on January 6, 2020; and WHEREAS, as required by State CEQA Guidelines section 15087(a), the City provided Notice of Availability of the Draft EIR to the public at the same time that the City sent Notice of Completion to the Office of Planning and Research, on January 6, 2020; and WHEREAS, during the public comment period, copies of the Draft EIR and technical appendices were available for review and inspection at the City of San Juan Capistrano Development Services Department, on the City's website, and at the San Juan Capistrano Public Library; and WHEREAS, pursuant to State CEQA Guidelines section 15087(e), the Draft EIR was circulated for at least a 45 -day public review and comment period from January 6, 2020 to February 19, 2020; and WHEREAS, during the public review and comment period, the City consulted with and requested comments from all responsible and trustee agencies, other regulatory agencies, and others pursuant to State CEQA Guidelines section 15086; and and WHEREAS, the City received nine (9) written comment letters on the Draft EIR; 2 6/2/2020 WHEREAS, pursuant to Public Resources Code section 21092.5, the City provided copies of its responses to commenting public agencies at least ten (10) days prior to the City's consideration of the Final EIR on May 21, 2020; and WHEREAS, on May 12, 2020, the Planning Commission conducted the public hearing to consider the Draft EIR, Architectural Control (AC) 18-021, Grading Plan Modification (GPM) 18-005, Flood Plain Land Use Permit (FP) 18-001, Sign Program (SP) 18-031, Tentative Tract Map (TTM) 20-001, and request for approval of a new lumber hardware store and lumber yard, future drive-through restaurants and short term vehicle parking project for the Project and solicited comments on the document. After hearing all relevant testimony from staff, the public and the City's consultant team, the Planning Commission voted to recommend that the City Council certify the EIR for the Project; and WHEREAS, on May 6, 2020, the City released the Final EIR ("Final EIR"), which consists of the Draft EIR, all technical appendices prepared in support of the Draft EIR, all written comment letters received on the Draft EIR, written responses to all written comment letters received on the Draft EIR, and errata to the Draft EIR and technical appendices; and WHEREAS, the "EIR" consists of the Final EIR and its attachments and appendices, as well as the Draft EIR and its attachments and appendices (as modified by the Final EIR); and WHEREAS, all potentially significant adverse environmental impacts were sufficiently analyzed in the EIR; and WHEREAS, as contained herein, the City has endeavored in good faith to set forth the basis for its decision on the Project; and WHEREAS, all of the requirements of the Public Resources Code and the State CEQA Guidelines have been satisfied by the City in connection with the preparation of the EIR, which is sufficiently detailed so that all of the potentially significant environmental effects of the Project have been adequately evaluated; and WHEREAS, the EIR prepared in connection with the Project sufficiently analyzes the Project's potentially significant environmental impacts and the EIR analyzes a range of feasible alternatives capable of reducing these effects to an even lesser level of significance; and WHEREAS, the City has made certain findings of fact, as set forth in Exhibit A to this Resolution, attached hereto and incorporated herein, based upon the oral and written evidence presented to it as a whole and the entirety of the administrative record for the Project, which are incorporated herein by this reference; and WHEREAS, the City finds that environmental impacts that are identified in the EIR as less than significant and do not require mitigation are described in Section II of Exhibit A; and 3 6/2/2020 WHEREAS, the City finds that environmental impacts that are identified in the EIR that are less than significant with incorporation of mitigation measures are described in Section III of Exhibit A; and WHEREAS, the City finds that even with the incorporation of all feasible mitigation measures, the environmental impacts that are identified in the EIR that are significant and unavoidable are described in Section IV of Exhibit A; and WHEREAS, the cumulative impacts of the Project identified in the EIR and set forth herein, are described in Section V of Exhibit A; and WHEREAS, the potential significant irreversible environmental changes that would result from the proposed Project identified in the EIR and set forth herein, are described in Section VI of Exhibit A; and WHEREAS, the existence of any growth-inducing impacts resulting from the proposed Project identified in the EIR and set forth herein, are described in Section VII of Exhibit A; and WHEREAS, alternatives to the proposed Project that might further reduce the already less than significant environmental impacts are described in Section VIII of Exhibit A; and WHEREAS, the Statement of Overriding Considerations that indicates the benefits of the Project outweigh the unavoidable significant environmental effects is described in Section IX of Exhibit A; and WHEREAS, all the mitigation measures identified in the EIR and necessary to reduce the potentially significant impacts of the proposed Project to a level of less than significant are set forth in the Mitigation Monitoring and Reporting Program (MMRP) in Exhibit B to this Resolution, attached hereto and incorporated herein; and WHEREAS, prior to taking action, the City has heard, been presented with, reviewed and considered all of the information and data in the administrative record, including but not limited to the EIR, and all oral and written evidence presented to it during all meetings and hearings; and WHEREAS, the EIR reflects the independent judgment of the City and is deemed adequate for purposes of making decisions on the merits of the Project; and WHEREAS, no comments made in the public hearings conducted by the City and no additional information submitted to the City have produced substantial new information requiring recirculation of the EIR or additional environmental review of the Project under Public Resources Code section 21092.1 and State CEQA Guidelines section 15088.5; and WHEREAS, on June 2, 2020, the City conducted a duly noticed public hearing on this Resolution, at which time all persons wishing to testify were heard and the Project was fully considered; and 4 6/2/2020 WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SAN JUAN CAPISTRANO: SECTION 1. The above recitals are true and correct and incorporated herein by reference. SECTION 2. The City Council hereby finds that it has been presented with the EIR, which it has reviewed and considered, and further finds that the EIR is an accurate and objective statement that has been completed in full compliance with CEQA and the State CEQA Guidelines. The City Council finds that the EIR reflects the independent judgment and analysis of the City. The City Council declares that no evidence of new significant impacts or any new information of "substantial importance" as defined by State CEQA Guidelines section 15088.5, has been received by the City after circulation of the Draft EIR that would require recirculation. Therefore, the City Council hereby certifies the EIR based on the entirety of the record of proceedings. SECTION 3. The City Council hereby adopts the "CEQA Findings of Fact" which were prepared in accordance with State CEQA Guidelines sections 15091 and which are attached hereto as Exhibit A and incorporated herein by this reference. SECTION 4. Pursuant to Public Resources Code section 21081.6, the City Council hereby adopts the Mitigation Monitoring and Reporting Program attached hereto as Exhibit B and incorporated herein by this reference. Implementation of the Mitigation Measures contained in the Mitigation Monitoring and Reporting Program is hereby made a condition of approval of the Project. In the event of any inconsistencies between the Mitigation Measures set forth in the EIR or the Findings of Fact and the Mitigation Monitoring and Reporting Program, the Mitigation Monitoring and Reporting Program shall control. SECTION 5. Based upon the entire record before it, including the EIR, Findings of Fact, Statement of Overriding Considerations, the Mitigation Monitoring and Reporting Program, and all written and oral evidence presented, the City Council may take action on the proposed Project. SECTION 6. The documents and materials that constitute the record of proceedings on which this Resolution has been based are located at City Hall, 32400 Paseo Adelanto, San Juan Capistrano, CA 92675. The custodian for these records is City Clerk. This information is provided pursuant to Public Resources Code section 21081.6. SECTION 7. City staff shall prepare and execute a Notice of Determination, which staff shall file and post with the County Clerk and the State Clearinghouse within five working days of the adoption of this Resolution. 5 6/2/2020 APPROVED AND ADOPTED this 2nd day of June 2020. 017-9=47MURNE, MAYOR STATE OF CALIFORNIA ) COUNTY OF ORANGE ) ss. CITY OF SAN JUAN CAPISTRANO ) I, Maria Morris, appointed City Clerk of the City of San Juan Capistrano, do hereby certify that the foregoing Resolution No. 20-06-02-02 was duly adopted by the City Council of the City of San Juan Capistrano at a Regular meeting thereof, held the 2nd day of June 2020, by the following vote: AYES: QbUNCIL MEMBERS: Maryott, Farias, Taylor and Mayor Bourne NOS:: OUNCIL MEMBERS: None ABSE T:'�OUNCIL MEMBERS: Reeve RIS, CITYALERK 6 6/2/2020 EXHIBIT A CEQA FINDINGS OF FACT The California Environmental Quality Act (Pub. Resources Code, § 21000 et seq.) (CEQA) requires that public agencies shall not approve or carry out a project for which an environmental impact report'(EIR) has been certified that identifies one or more significant adverse environmental effects of a project unless the public agency makes one or more written Findings for each of those significant effects, accompanied by a brief explanation of the rationale for each Finding (State CEQA Guidelines [Cal. Code Regs., tit. 14, § 15000 et seq.], § 15091). This document presents the CEQA Findings of Fact made by the City of San Juan Capistrano, in its capacity as the CEQA lead agency, regarding the Ganahl Lumber Project (Project), evaluated in the Draft Environmental Impact Report ("Draft EIR") and Final Environmental Impact Report (Final EIR) for the Project. SECTION I INTRODUCTION Public Resources Code section 21002 states that "public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]" Section 21002 further states that the procedures required by CEQA "are intended to assist public agencies in systematically identifying both the significant effects of proposed Projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects." Pursuant to section 21081 of the Public Resources Code, a public agency may only approve or carry out a project for which an EIR has been completed that identifies any significant environmental effects if the agency makes one or more of the following written finding(s) for each of those significant effects accompanied by a brief explanation of the rationale for each finding: 1. Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant effects on the environment. 2. Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency. 3. Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the environmental impact report. As indicated above, section 21002 requires an agency to "avoid or substantially lessen" significant adverse environmental impacts. Thus, mitigation measures that "substantially lessen" significant environmental impacts, even if not completely avoided, 1 6/2/2020 satisfy section 21002's mandate. (Laurel Hills Homeowners Assn. v. City Council (1978) 83 Cal.App.3d 515, 521 ["CEQA does not mandate the choice of the environmentally best feasible project if through the imposition of feasible mitigation measures alone the appropriate public agency has reduced environmental damage from a project to an acceptable level"]; Las Virgenes Homeowners Fed., Inc. v. County of Los Angeles (1986) 177 Cal. App. 3d 300, 309 ["[t]here is no requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance ... if such would render the project unfeasible"].) While CEQA requires that lead agencies adopt feasible mitigation measures or alternatives to substantially lessen or avoid significant environmental impacts, an agency need not adopt infeasible mitigation measures or alternatives. (Pub. Resources Code, § 21002.1(c) [if "economic, social, or other conditions make it infeasible to mitigate one or more significant effects on the environment of a project, the project may nonetheless be carried out or approved at the discretion of a public agency"]; see also State CEQA Guidelines, § 15126.6(a) [an "EIR is not required to consider alternatives which are infeasible"].) CEQA defines "feasible" to mean "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors." (Pub. Resources Code, § 21061.1.) The State CEQA Guidelines add "legal" considerations as another indicia of feasibility. (State CEQA Guidelines, § 15364.) Project objectives also inform the determination of "feasibility." (Jones v. U.C. Regents (2010) 183 Cal. App. 4th 818, 828-829.) "'[F]easibility' under CEQA encompasses 'desirability' to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors." (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.AppAth 704, 715.) "Broader considerations of policy thus come into play when the decision making body is considering actual feasibility[.]" (Cal. Native Plant Soc'y v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1000 ("Native Plant"); see also Pub. Resources Code, § 21081(a)(3) ["economic, legal, social, technological, or other considerations" may justify rejecting mitigation and alternatives as infeasible] (emphasis added).) Environmental impacts that are less than significant do not require the imposition of mitigation measures. (Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347.) The California Supreme Court has stated, "[t]he wisdom of approving ... any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced." (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 576.) In addition, perfection in a project or a project's environmental alternatives is not required; rather, the requirement is that sufficient information be produced "to permit a reasonable choice of alternatives so far as environmental aspects are concerned." Outside agencies (including courts) are not to "impose unreasonable extremes or to interject [themselves] within the area of 2 6/2/2020 discretion as to the choice of the action to be taken." (Residents Ad Hoc Stadium Com. v. Board of Trustees (1979) 89 Cal.App.3d 274, 287.) SECTION II FINDINGS REGARDING ENVIRONMENTAL IMPACTS NOT REQUIRING MITIGATION The City Council hereby finds that the following potential environmental impacts of the Project are less than significant and therefore do not require the imposition of Mitigation Measures. A. AESTHETICS 1. Scenic Vistas vista? Threshold: Would the Project have a substantial adverse effect on a scenic Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-1.) Explanation: California State Government Code Section 65560(b)(3) stipulates that city and county General Plans address "...Open space for outdoor recreation, including but not limited to, areas of outstanding scenic, historical and cultural value; areas particularly suited for park and recreation purposes, including access to lakes shores, beaches, and rivers, and streams; and areas which serve as links between major recreation and open space reservations, including utility easements, banks of rivers and streams, trails, and scenic highway corridors. A scenic vista is the view of an area that is visually or aesthetically pleasing from a certain vantage point and is usually viewed from some distance away. Aesthetic components of a scenic vista include, (1) scenic quality, (2) sensitivity level, and (3) view access. 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 Project site is located in the City of San Juan Capistrano (City), on the western slope of the San Juan Creek floodplain. The Project site is characterized by an undeveloped dirt parking lot and ruderal vegetation. While there are no locally designated scenic vistas in the City, distant views of the Santa Ana Mountains, Saddleback Mountain, and the Colinas Hills are visible from various vantage 3 6/2/2020 points throughout the City. The only regional visual resource that is visible from the Project site is the Santa Ana Mountains. Construction. Construction of the proposed Project would require site preparation, grading, and construction activities. Construction activities would be visible to travelers along Stonehill Drive, the San Juan Creek Trail, the BNSF rail line, and adjacent roadways. Construction equipment is not of sufficient height or mass to substantially block views of distant scenic vistas. In addition, construction activities would be short-term in nature and would cease upon completion of project construction. Therefore, construction impacts related to adverse effects on a scenic vista would be less than significant, and no mitigation would be required. Operation. The Community Design Element (1999) of the City's General Plan addresses the effect of future development projects on scenic corridors within the City. As described in the Community Design Element, major roadways and railways provide visual images of the quality of life in the City. As such, Stonehill Drive (located immediately south of the site) is a designated scenic corridor. The City's Community Design Element (1999) identifies design criteria to ensure that new development located within the scenic corridor is developed in a manner that preserves the City's aesthetic values. While no designated trails or vantage points currently exist on the Project site, members of the public may access views of the surrounding hills from public roads and adjacent roadways and sidewalks surrounding the site, including the adjacent San Juan Creek Trail. The proposed Project may partially block views from the adjacent San Juan Creek Trail and Creekside Park beyond to the west. Creekside Park contains a substantial amount of trees and vegetation that act as a barrier to its surrounding visual setting, thus the proposed Project would only be partially visible from the park. The San Juan Creek Trail is an approximately 1 -mile long concrete multi -use trail that runs parallel to the San Juan Creek River. The Project site is currently visible from the trail, and may impair some public views from persons accessing the trail. However, landscaping elements included throughout the Project site would serve to enhance and frame views from both Creekside Park and San Juan Creek Trail. Therefore, impacts to views from both Creekside Park and San Juan Creek Trail would be less than significant. Implementation of the proposed Project would allow for the development of three sites including the restaurants on Site A, hardware store and associated uses on Site B, and automobile storage space on Site C. The buildings on each site vary in height 4 6/2/2020 ranging from 20 feet (ft) to a maximum of 35 ft for the hardware store and lumber yard (Building 1). Implementation of the proposed Project would modify views to and from the Project site by allowing for development of commercial and industrial uses on the existing, largely vacant site. However, because the buildings do not exceed 35 ft in height, and because the Project site is at a lower elevation than the surrounding roadways, the project would not result in significant impacts on views of the surrounding hills from adjacent roadways and sidewalks. Motorists, bicyclists, and pedestrians would continue to enjoy these views following project implementation. The proposed Project would not obstruct or block views of the surrounding hills from nearby roads, including a City - designated scenic corridor, Stonehill Drive. Furthermore, landscaping elements included throughout the Project site would serve to enhance and frame views of these scenic corridors and would help to block views of the proposed commercial uses from within the Project site. In addition to adhering to the Community Design Element (1999), the proposed Project design has been refined to include natural materials and planting to connect with the regional landscape. Therefore, potential impacts of the proposed Project on scenic vistas would be less than significant, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-1 through 4-3.) 2. Scenic Resources Threshold: Would the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Findin : No impact. (Appendix A [Initial Study], p. 4-3.) Explanation: The California Department of Transportation's (Caltrans) Landscape Architecture Program administers the Scenic Highway Program, contained in the Streets and Highways Code, Sections 260-263. State Highways are classified as either Officially Listed or Eligible. The proposed Project is located approximately 0.1 mile west of Interstate 5 (1-5) and 0.8 mile north of Pacific Coast Highway (PCH, State Route 1 [SR -1]), both of which are classified as Eligible State Scenic Highways — Not Officially Designated.' Additionally, the portion of State Route 74 (SR -74) that converges with 1-5, located approximately 2 miles north of the Project site, is ' California Department of Transportation (Caltrans). California Scenic Highway Mapping System (Orange County). Website: http://www.dot.ca.gov/hq/LandArch/16_iivability/scenic_highways/ (accessed April 19, 2019). 5 6/2/2020 also identified as an Eligible State Scenic Highway.' There are no Officially -listed State Scenic Highways in the vicinity of the Project site. In its existing condition, no existing scenic resources such as protected trees, rock outcroppings, or historic buildings are located on the Project site or in the surrounding vicinity. The Project site is located within a developed area of the City primarily characterized by commercial and residential uses. As discussed further in Section 4.4, Biological Resources, of the Draft EIR, the majority of the existing vegetation on the Project site is ruderal and non-native. The proposed Project would replace existing ruderal vegetation on the site with ornamental landscaping designed to reflect that of the surrounding environment. Therefore, the proposed Project does not have the potential to damage resources within a State scenic highway, and no mitigation would be required. (Appendix A [Initial Study], p. 4.3.) 3. Visual Character 2 Ibid. Threshold: In non -urbanized areas, would the project substantially degrade the existing visual character or quality of public view of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? Finding: Less than significant impact. (Draft EIR, 4.1-11.) Explanation: The United States Census Bureau designates the Project site as part of an urbanized area because the entire City is within the Mission Viejo -Lake Forest -San Clemente, CA Urbanized Area. The Project site's current land use designation (Quasi -Industrial and Industrial Park) and zoning designations (Commercial Manufacturing and Mobile Home Park Senior Overlay) are consistent with the proposed use. However, the following consistency analysis is included in this section to demonstrate the proposed Project's consistency with General Plan and zoning regulations governing scenic quality. General Plan. The City of San Juan Capistrano General Plan is intended to guide future growth and development within the City. The General Plan Land Use and Community Design Elements contain specific goals and policies related to aesthetics and scenic quality. As shown in Table 4.1.A (found at Draft EIR, pp. 4.1-8 through 4.1-10), the project would be consistent with applicable 6 6/2/2020 General Plan goals and policies related to aesthetics and scenic quality. The project would be consistent with applicable General Plan goals and policies related to aesthetics and scenic quality. Further, the project would be consistent with both existing General Plan land use designations for the property, and no General Plan Amendment would be required to implement the proposed Project. Therefore, the proposed Project would not substantially degrade the visual character of the Project site nor conflict with applicable General Plan regulations governing scenic quality. City of San Juan Capistrano Zoning Code. Section 9-3.305, Industrial Districts, of the City's Zoning Code includes applicable development standards for the Commercial Manufacturing zoning classification (i.e., the zoning classification on the portion of the Project site proposed for development). As shown in Table 4.1.13 (found at Draft El R, p. 4.1-11), the project would be consistent with applicable zoning code development standards related to aesthetics and scenic quality. The majority of the Project site is zoned Commercial Manufacturing (CM); however, the northernmost portion of the Project site where the utility easement would be located is zoned Mobile Home Park Senior Overlay. For that reason, the above development standards apply to the Commercial Manufacturing zone and not the Mobile Home Park Senior Overlay zone. The proposed utility easement would consist of minor improvements and would be required to conform to development standards in the Mobile Home Park Senior Overlay zone. As such, the project would be consistent with both existing zoning designations for the property, and no Zoning Amendment would be required to implement the proposed Project. For the reasons stated above, the proposed Project would not substantially degrade the visual character of the Project site nor conflict with applicable zoning regulations governing scenic quality. The proposed Project would enhance the existing visual setting of the Project site by converting the existing underutilized property to a developed commercial use featuring high quality building materials and new landscaping. Further, the project would be consistent with other regulations governing scenic quality, including those outlined in the General Plan Land Use and Community Design Elements and the City's Zoning Code. Therefore, the proposed Project would not substantially degrade the visual character of the Project site nor conflict with applicable zoning and other regulations governing scenic quality, and no mitigation would be required. (Draft EIR, pp. 4.1-6 through 4.1-11.) 7 6/2/2020 B. AGRICULTURE AND FOREST RESOURCES 1. Farmland Conversion Threshold: Would the Project convert Primate Farmland, Unique Farmland, or Farmland of Statewide significance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? Finding: No impact. (Draft EIR, p. 4-7.) Explanation: Maps of designated farmlands are compiled by the California Department of Conservation, Farmland Mapping and Monitoring Program (FMMP), pursuant to the provisions of Section 65570 of the California Government Code. These maps represent an inventory of agricultural resources within the State. Agricultural land is evaluated based on soil quality and irrigation status, and the best quality land is designated as Prime Farmland. Every 2 years, the maps are updated with the use of a computer mapping system, aerial imagery, public review, and field reconnaissance.3 The Project site is located in an urbanized area predominantly developed with residential and commercial uses. The Project site is characterized by an undeveloped gravel parking lot and ruderal vegetation. While the Project site is currently undeveloped, a large portion of the site is being used for temporary storage of automobiles by nearby automobile dealerships. The site is currently zoned as Commercial Manufacturing and Mobile Home Park Senior Overlay on the City's Zoning Map; it is not zoned for agricultural uses. The Project site currently has General Plan land use designations of Quasi -Industrial and Industrial Park. The Project site and surrounding area are currently mapped as Urban and Built Up Land by the FMMP.4 There are no designated Prime Farmlands, Unique Farmlands, or Farmlands of Statewide Importance on the Project site or in the project's immediate vicinity. Therefore, implementation of the proposed Project would not result in the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, and no mitigation would be required. (Draft EIR, pp. 4-6 through 4-7.) 3 California Department of Conservation. Farmland Mapping & Monitoring Program. Documenting Changes in Agricultural Land Use since 1984. Website: https://www.conservation.ca.gov/dIrp/fmmp (accessed April 19, 2019). 4 California Department of Conservation. 2016. Orange County Important Farmland. Website: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2016/oral6.pdf/ (accessed April 19, 2019). 6/2/2020 2. 0 U Agricultural Zoning Threshold: Would the Project conflict with existing zoning for agricultural use, or a Williamson Act Contract? Finding: No impact. (Draft EIR, p. 4-7.) Explanation: The proposed Project is located on a 17 -acre undeveloped site that is currently used for vehicle storage by local automobile dealerships. According to the City's Zoning Map, the Project site is zoned as Commercial Manufacturing and Mobile Home Park Senior Overlay. As such, the Project site is not zoned for agricultural use and is not currently used for agricultural production. The Project site is not located within an area covered under a Williamson Act contract.5 Therefore, no impacts related to an agricultural use or a Williamson Act contract would occur with implementation of the proposed Project, and no mitigation would be required. (Draft EIR, p. 4-7.) Forestland Zoning Threshold: Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)? Finding: No impact. (Draft EIR, p. 4-8.) Explanation: The Project site is zoned Commercial Manufacturing and Mobile Home Park Senior Overlay. Neither the Project site nor the surrounding area is zoned as forest land, timberland, or timberland production. As a result, no significant impacts would occur, and no mitigation is required. This topic will not be analyzed further in the EIR unless new information identifying it as a potentially significant impact is presented during the scoping process. (Draft EIR, pp. 4-7 through 4-8.) Loss of Forest Land Threshold: Would the Project result in the loss of forest land or conversion of forest land to non -forest use? Finding: No impact. (Draft EIR, p. 4-8.) 5 California Department of Conservation, Division of Land Resource Protection. 2017, Williamson Act Contract Land Map. Website: ftp://ftp.consrv.ca.gov/pub/dlrp/wa/ (accessed April 19, 2019). 9 6/2/2020 Explanation: The Project site is characterized by an undeveloped gravel parking lot and ruderal vegetation. While the Project site is currently undeveloped, a large portion of the site is being used for temporary storage of automobiles by nearby automobile dealerships. There are no forest or timberland resources on or in the vicinity of the Project site. The proposed Project would not convert forest land to a non -forest use. Likewise the Project site would not contribute to environmental changes that could result in conversion of forest land to non -forest use. Therefore, the project would not result in impacts related to the loss of forest land or the conversion of forest land to non -forest uses. No mitigation is required. (Draft EIR, p. 4-8.) 5. Conversion of Farmland or Forestland Threshold: Would the Project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non -forest use? .Finding: No impact. (Draft EIR, p. 4-8.) Explanation: The Project site is in an urban, built -out portion of San Juan Capistrano. While the Project site is currently undeveloped, it is not used for agricultural purposes and is not designed or zoned for forest land. The proposed Project would not convert farmland to a non-agricultural use or convert forest land to a non -forest use. Likewise, the proposed Project would not contribute to environmental changes that could result in conversion of farmland to a non-agricultural use or conversion of forest land to a non -forest use. Therefore, no impacts to farmland or forest land would occur as a result of project implementation, and no mitigation is required. (Draft EIR, p. 4-8.) C. AIR QUALITY 1. Air Quality Plans and Air Quality Standards Threshold: Would the Project conflict with or obstruct implementation of the applicable air quality plan; violate any air quality standard or contribute substantially to an existing or projected air quality violation? Finding: Less than significant impact. (Draft EIR, p. 4.2-13.) Explanation: Chapter 12, Sections 12.2 and 12.3 of the SCAQMD CEQA Air Quality Handbook (1993) outlines two criteria for determining consistency with the 2016 AQMP. A project would be consistent with the AQMP if the project (1) would not increase the frequency 10 6/2/2020 or severity of an existing air quality violation or cause or contribute to new a new violation or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP, and (2) would not exceed the growth assumptions in the AQMP based on the year of project build out, would be consistent with land use planning strategies set forth by SCAQMD, and would implement all feasible air quality mitigation measures. Criterion 1. The SCAQMD's first criterion for determining project consistency with the AQMP includes methodologies that require that an air quality analysis for a project include forecasts of project emissions in relation to contributing to air quality violations and delay of attainment. As described further under Threshold 4.2.2 below, the short-term construction and long-term pollutant emissions from the proposed Project would not exceed the regional criteria emissions thresholds established by the SCAQMD. Pollutant emissions generated during project construction and operation would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard. Therefore, the proposed Project would be consistent with the AQMP under the first criterion. Criterion 2. The SCAQMD's second criterion for determining project consistency focuses on whether or not the proposed Project exceeds the assumptions utilized in preparing the forecasts presented its air quality planning documents. Project consistency with population, housing, and employment assumptions that were used in the development of SCAQMD air quality plans ensures a project is consistent with regional air quality planning efforts. Generally, three sources of data form the basis for the projections of air pollutant emissions in San Juan Capistrano: the City's General Plan, SCAG's Growth Management chapter of the Regional Comprehensive Plan and Guide (RCPG), and SCAG's 2016 RTP/SCS. The RTP/SCS also provides socioeconomic forecast projections of regional population growth. The City's General Plan designates the Project site as Industrial Park, which allows for light industrial and manufacturing uses, including wholesale businesses, light manufacturing and assembly, research and development, warehousing and storage, and distribution and sales. Thus, the proposed Project is consistent with the existing land use designation. Additionally, the project does not involve any uses that would increase population beyond what is considered in the General Plan, and therefore, the project is consistent with the types, intensity, and patterns of land use envisioned for the Project site in the General Plan and RCPG. Further, the population, housing, and employment projections, which are adopted by 11 6/2/2020 SCAG's Regional Council, are based on the local plans and policies applicable to the City and are used by SCAG in all phases of implementation and review. Since the SCAQMD has incorporated these same projections into their air quality planning efforts, the proposed Project would be consistent with these projections. In order to further reduce emissions, the project would comply with SCAQMD emission reduction measures including SCAQMD Rules 402, 403, and 1113. SCAQMD Rule 402 prohibits the discharge, from any source, air contaminants or other material that cause injury, detriment, nuisance, or annoyance to the public, or that endanger the comfort, repose, health, or safety of the public, or that cause, or have a natural tendency to cause, injury or damage to business or property. SCAQMD Rule 403 requires fugitive dust sources to implement Best Available Control Measures for all sources, and all forms of visible particulate matter are prohibited from crossing any property line. Rule 403 is intended to reduce PM10 emissions from transportation, handling, construction, or storage activities that have the potential to generate fugitive dust. SCAQMD 1113 requires manufacturers, distributors, and end-users of architectural and industrial maintenance coatings to reduce reactive organic gas (ROG) emissions from the use of architectural coatings. The project is required to comply with these emission reduction measures during construction as outlined in Regulatory Compliance Measures AQ -1 through AQ3 (refer to Section 4.2.8, Regulatory Compliance Measures and Mitigation Measures, of the Draft EIR). For the reasons stated above, the proposed Project is consistent with the second criterion. In sum, the proposed Project would not conflict with or obstruct implementation of the 2016 AQMP because (1) the project's construction and operational emissions would not exceed the SCAQMD regional significance thresholds, and (2) the proposed Project is consistent with the current General Plan land use designation on the Project site and would not exceed the growth assumptions in the AQMP, is consistent with land use planning strategies set forth by SCAQMD, and includes implementation of all feasible air quality measures to reduce emissions. Therefore, impacts related to the conflict with or obstruction of implementation of the applicable air quality plan would be less than significant, and no mitigation is required. (Draft EIR, pp. 4.2-12 through 4.2-13.) Regulatory Compliance Measures The proposed Project would comply with the following regulatory standards. RCM AQ -1 South Coast Air Quality Management District (SCAQMD) Rule 402, Nuisance. Prohibits the discharge from any source 12 6/2/2020 whatsoever such quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health, or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. This rule does not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals. RCM AQ -2 South Coast Air Quality Management District (SCAQMD) Rule 403, Fugitive Dust. The project Applicant shall ensure the construction contractor implements fugitive dust control measures in compliance with SCAQMD Rule 403. The project Applicant shall include the following fugitive dust control measures for SCAQMD Rule 403 compliance in the project plans and specifications: • All clearing, grading, earth -moving, or excavation activities shall cease when winds exceed 25 miles per hour (mph) per SCAQMD guidelines in order to limit fugitive dust emissions. ■ The construction contractor shall ensure that all disturbed unpaved roads and disturbed areas within the Project site are watered, with complete coverage of disturbed areas, at least three (3) times daily during dry weather and preferably mid-morning, afternoon, and after work is done for the day. • The contractor shall ensure that traffic speeds on unpaved roads and Project site areas are reduced to 15 mph or less. RCM AQ -3 SCAQMD Rule 1113. The project Applicant shall ensure the construction contractor implements measures to control volatile organic compound (VOC) emissions from architectural coatings in compliance with SCAQMD Rule 1113. The project Applicant shall include the following control measures for SCAQMD Rule 1113 compliance in the project plans and specifications. Only "Low -Volatile Organic Compounds" paints (no more than 50 grans/liter of VOC) shall be used. Implementation of Regulatory Compliance Measures AQ -1 through AQ -3 would ensure that project -related air quality impacts would be at a less than significant level. No significant impacts related to air quality would occur with implementation of these standard measures. All anticipated impacts related to air quality would be considered less than significant and no mitigation is required. (Draft EIR, p. 4.2-21.) 2. Cumulatively Considerable Pollutant Emissions 13 6/2/2020 Threshold- Would the Project result in 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? Finding: Less than significant impact. (Draft EIR, p. 4.2-16.) Explanation- Construction. Construction related emissions are temporary and short-term. Project -related construction activities that would produce emissions include the operation of construction vehicles (i.e., excavators, trenchers, and dump trucks), the creation of fugitive dust during clearing and grading, and the use of asphalt or other oil-based substances during paving activities, which can release VOCs. Construction emissions would vary daily depending on the weather, soil conditions, the amount of activity taking place, and the nature of dust control efforts; therefore, this analysis provides the worst-case construction emissions based on the construction schedule and construction equipment anticipated for project construction. As specified in Regulatory Compliance Measures AQ -1 through AQ -3, construction of the proposed Project would comply with SCAQMD standard conditions, including Rule 402 (Nuisance) to control nuisance emissions, Rule 403 (Fugitive Dust) to control fugitive dust, and Rule 1113 (Architectural Coatings) to control VOC emissions from paint. Compliance with SCAQMD standard conditions are regulatory requirements and were considered in the analysis of construction emissions. The maximum daily emissions of VOCs, NOx, S02, CO, PMio, and PM2.5 that would result from construction of the proposed Project are summarized in Table 4.2.D (found at Draft EIR, p. 4.2-13) and compared to the SCAQMD regional significance thresholds. As shown in Table 4.2.D (found at Draft EIR, p. 4.2-13), construction emissions associated with the proposed Project would not exceed the significance thresholds established by the SCAQMD for any of the criteria pollutants. The portion of the Basin in which the Project site is located is in nonattainment of the NAAQS for 03 and PM2.5. The Basin is in nonattainment of the CAAQS for 03, PM2.5, and PM10. As shown in Table 4.2.D (found at Draft EIR, p. 4.2-13), emissions from construction of the proposed Project would not exceed the significance thresholds for 03, PM2.5, or PM10. Therefore, construction of the proposed Project would not exceed the significance thresholds of criteria pollutants for which the project region is nonattainment under the CAAQS or NAAQS. According to SCAQMD guidance, projects that exceed the significance thresholds are considered by SCAQMD to result in 14 6/2/2020 cumulatively considerable air quality impacts. Conversely, projects that do not exceed the significance thresholds are generally not considered to result in cumulatively considerable air quality impacts. Therefore, because construction emissions would not exceed any of the air quality significance thresholds for any criteria pollutants, the proposed Project would not have a cumulatively considerable air quality impact. Therefore, compliance with regulatory requirements (as specified in Regulatory Compliance Measures AQ -1 through AQ -3) would further reduce impacts, and construction impacts related to the cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under applicable NAAQS or CAAQS would be less than significant. No mitigation is required. Operation. Project -related operations would result in the long-term emission of ROG, NOx, 502, CO, PM10, and PM2.5 primarily associated with motor vehicle use. Vehicle trips to and from the Project site would generate mobile source emissions. Vehicles traveling on paved roads would be a source of fugitive emissions due to the generation of road dust and tire wear particulates. Mobile source emissions are dependent on both overall daily vehicle trip generation and the effect of the project on peak -hour traffic volumes and traffic operations in the vicinity of the Project site. The project -related operational air quality emissions are primarily due to vehicle trips. Operational air pollutant emissions were based on the Project site plans and the estimated traffic trip generation rates from the TIA (LSA, 2019). According to the TIA, the project is anticipated to generate 5,221 average daily trips. Additionally, estimated emissions account for the use of 12 diesel -powered material handing vehicles (forklifts) on site, daily. Projected emissions associated with the proposed Project were compared to the existing baseline, which includes a vehicle storage lot containing 752 spaces in central portion of the Project site. Table 4.2.E (found at Draft EIR, p. 4.2-16) summarizes the project's maximum daily emissions during operation. As shown in Table 4.2.E (found at Draft EIR, p. 4.2-16), while the project would result in the increased emissions of criteria pollutants, emissions during operation of the proposed Project would not exceed the thresholds of significance for any pollutants. The portion of the Basin in which the Project site is located is in nonattainment of the NAAQS for 03 and PM2.5. The Basin is in nonattainment of the CAAQS for 03, PM2.5, and PM10. As shown in Table 4.2.E (found at Draft EIR, p. 4.2-16), emissions during operation of the proposed Project would not exceed the significance thresholds for 03, PM2.5, or PM10. Therefore, 15 6/2/2020 operation of the proposed Project would not exceed the significance thresholds of criteria pollutants for which the project region is nonattainment under the CAAQS or NAAQS. According to SCAQMD guidance, projects that exceed the significance thresholds are considered by the SCAQMD to result in cumulatively considerable air quality impacts. Conversely, projects that do not exceed the significance thresholds are generally not considered to result in cumulatively considerable air quality impacts. Therefore, based on the fact that the emissions during operation of proposed Project would not exceed any of the air quality significance thresholds for any criteria pollutants, the proposed Project would not have a cumulatively considerable impact. Therefore, operational impacts related to the cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable NAAQS or CAAQS would be less than significant, and no mitigation is required. (Draft EIR, pp. 4.2-13 through 4.2-16.) 3. Sensitive Receptors Threshold: Would the Project expose sensitive receptors to substantial pollutant concentrations? Finding: Less than significant impact. (Draft EIR, p. 4.2-20.) Explanation: Construction. In order to identify impacts to sensitive receptors, the SCAQMD recommends addressing LSTs for construction. As previously described, the SCAQMD has issued guidance on applying CaIEEMod modeling to LSTs for projects greater than five acres. Further, CaIEEMod calculates construction emissions based on the number of equipment hours and the maximum daily soil disturbance activity possible for each piece of equipment. For these reasons, Table 4.21 (found at Draft EIR, p. 4.2-17) shows the maximum daily disturbed acreage for comparison to LSTs. As shown in Table 4.21 (found at Draft EIR, p. 4.2-16), project construction could potentially disturb up to 3.5 acres daily during the site preparation phase and up to 4.0 acres daily during the grading phase. Thus, the LST threshold value for a 3.5 -acre construction site were utilized to analyze site preparation and the LST threshold value for a 4 -acre construction site were utilized to analyze grading activities. Construction activities would result in localized exhaust emissions that have the potential to affect nearby sensitive receptors. In order to identify impacts to sensitive receptors, the SCAQMD recommends analyzing LSTs for construction. Sensitive receptors 16 6/2/2020 near the Project site include existing residential homes located approximately 60 feet (18 meters) north of the development area on the site. Creekside Park and the bicycle trail on the western side of San Juan Creek, which may also be considered sensitive receptors, are located over 300 feet west of the Project site. Therefore, construction emissions would be dispersed at a much lower concentration by the time they reach the Creekside Park and bike trial as compared to the adjacent residential mobile homes. LST thresholds are provided for distances to sensitive receptors of 25, 50, 100, 200, and 500 meters. According to SCAQMD guidance, projects with boundaries located closer than 25 meters to the nearest receptor are directed to use the LSTs for receptors located at 25 meters. As such, LSTs for receptors located at 25 meters were utilized in this analysis. Table 4.2.G (found at Draft EIR, p. 4.2-18) identifies the localized impacts at the nearest sensitive receptor location to the Project site compared to the SCAQMD LSTs for NOx, CO, PM10, and PM2.5. Table 4.2.G shows that pollutant emissions on the peak day of construction would not result in significant concentrations of pollutants at the nearby residential sensitive receptors. As shown in Table 4.2.G (found at Draft EIR, p. 4.2-18), construction emissions associated with the proposed Project would not exceed the LSTs established by SCAQMD. Further, as specified in Regulatory Compliance Measure AQ-2 construction of the proposed Project would comply with SCAQMD standard conditions, including Rule 403 (Fugitive Dust) to control fugitive dust. Compliance with SCAQMD standard conditions are regulatory requirements and were considered in the analysis of construction emissions. Because the project would not exceed the LSTs with compliance with regulatory requirements (and would be further reduced with implementation of Regulatory Compliance Measures AQ-1 and AQ-2), impacts related to exposure of sensitive receptors to substantial pollutant concentrations would be less than significant. No mitigation is required. Operation. Localized Emissions. A project would generate localized exhaust emissions that have the potential to affect nearby sensitive receivers if the project includes stationary sources, or attracts mobile sources that may spend long periods queuing and idling at the site (e.g., warehouse or transfer facilities). As such, operational LSTs are not applicable to the proposed Project. Although the proposed Project does not include such uses, impacts associated with the operational localized emissions have been analyzed for disclosure purposes. Operational LSTs apply to CO, NO2, PM10, 17 6/2/2020 and PM2.5. Sensitive receptors near the Project site include existing residential homes located approximately 60 feet (18 meters) north of the development area on the site, and LSTs for receptors located at 25 meters were utilized in this analysis. Creekside Park and the bicycle trail on the western side of San Juan Creek, which may also be considered sensitive receptors, are located over 300 feet west of the Project site. Therefore, operational emissions would be dispersed at a much lower concentration by the time they reach the Creekside Park and bike trial as compared to the adjacent residential mobile homes. Table 4.2.H (found at Draft EIR, p. 4.2-19) shows the maximum daily emissions for the project's operational activities compared with the SCAQMD LSTs for NOx, CO, PM10, and PM2.5. In order to provide a conservative assessment, the emissions shown in Table 4.2.H (found at Draft EIR, p. 4.2-19) include all on-site project -related stationary sources, as well as 10 percent of the project -related mobile sources. As shown in Table 4.2-H (found at Draft EIR, p. 4.2-19), project operational source emissions would not exceed LSTs established by the SCAQMD. Therefore, because the project would not exceed the LSTs established by the SCAQMD, localized emissions from operation of the proposed Project would not expose any sensitive receptors to substantial pollutant concentrations, impacts would be less than significant, and no mitigation is required. CO Hot Spot. CO hot spots are caused by vehicular emissions, primarily when idling at congested intersections. Based on the analysis presented below, a CO "hot -spot" analysis is not needed to determine whether a change in the level of service (LOS) of an intersection in the vicinity of the Project site would have the potential to result in exceedance of either the CAAQS or NAAQS. Vehicle emissions standards have become increasingly stringent in the last 20 years. Currently, the allowable CO emissions standard in California is a maximum of 3.4 grams/mile for passenger cars (there are requirements for certain vehicles that are more stringent). With the turnover of older vehicles, introduction of cleaner fuels, and implementation of increasingly sophisticated and efficient emissions control technologies, CO concentration in the Basin is now designated as attainment. In addition, CO concentrations in the project vicinity have steadily declined. The analysis prepared for CO attainment in the Basin by SCAQMD can be used to assist in evaluating the potential for CO 18 6/2/2020 exceedances in the Basin. To establish a more accurate record of baseline CO concentrations affecting the Basin, a CO "hot -spot" analysis was conducted by SCAQMD in 2003 for four busy intersections in Los Angeles at the peak morning and afternoon time periods. The busiest intersection evaluated was at Wilshire Boulevard and Veteran Avenue, which has a traffic volume of approximately 100,000 vehicles per day. This analysis did not predict any violation of CO standards. Based on the SCAQMD 2003 AQMP and the 1992 Federal Attainment Plan for Carbon Monoxide (1992 CO Plan), peak CO concentrations in the Basin were a result of unusual meteorological and topographical conditions and not a result of traffic volumes and congestion at a particular intersection. Even if the traffic volumes of the proposed Project were double or triple that of the traffic volumes generated at the four busy intersections in Los Angeles, coupled with the ongoing improvements in ambient air quality, the project would not be capable of resulting in a CO "hot spot" at any study area intersections. Similar considerations are also employed by other Air Districts when evaluating potential CO concentration impacts. More specifically, the Bay Area Air Quality Management District (BAAQMD) concludes that under existing and future vehicle emission rates, a given project would have to increase traffic volumes at a single intersection by more than 44,000 vehicles per hour (vph)—or 24,000 vph where vertical and/or horizontal air does not mix—in order to generate a significant CO impact. According to the TIA, the project is anticipated to generate 5,221 average daily trips. Since the proposed Project would not increase traffic volumes at any intersection to more than 100,000 vehicles per day (the volumes at the busiest intersection evaluated in SCAQMD's hot spot analysis), there is no likelihood of the project traffic exceeding CO values. Because the proposed Project would not produce the volume of traffic required to generate a CO "hot spot," CO emissions from operation of the proposed Project would not expose sensitive receptors to substantial pollutant concentrations. Impacts related to CO hot spots would be less than significant, and no mitigation is required. Prior to mitigation, the proposed Project would result in less than significant impacts. However, the following regulatory compliance measures are existing SCAQMD regulations that are applicable to the proposed Project and are considered in the analysis of potential impacts related to air quality. The City of San Juan Capistrano considers these requirements to be mandatory; therefore, they are not mitigation measures. (Draft EIR, pp. 4.2-16 through 4.2-20.) 4. Other Adverse Emissions 19 6/2/2020 Threshold: Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-10.) Explanation: SCAQMD's CEQA Air Qualify Handbook (1993) identifies various secondary significance criteria related to odorous air contaminants. Substantial odor -generating sources include land uses such as agricultural activities, feedlots, wastewater treatment facilities, landfills, or heavy manufacturing uses. The project does not propose any such uses or activities that would result in potentially significant odor impacts. Some objectionable odors may emanate from the operation of diesel -powered construction equipment during construction of the proposed Project. However, these odors would be limited to the construction period and would disperse quickly; therefore, these odors would be considered less than significant and would not require mitigation. The proposed Project would allow for the implementation of a lumber yard development and two fast-food restaurants, which are not anticipated to produce objectionable odors. Potential sources of operational odors generated by the project would include disposal of miscellaneous refuse typical of commercial uses. SCAQMD Rule 402 acts to prevent occurrences of odor nuisances. Consistent with City requirements, all project -generated refuse would be stored in covered containers and removed at regular intervals in compliance with solid waste regulations. Therefore, no significant impacts related to objectionable odors would result from the proposed Project, and no mitigation is required. (Appendix A [Initial Study], p. 4-10.) D. BIOLOGICAL RESOURCES 1. Riparian Habitat Threshold: Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-12.) Explanation: The approximately 17 -acre vacant Project site is currently characterized by an undeveloped gravel parking lot and ruderal vegetation. According to the National Wetlands Inventory managed by the United States Fish and Wildlife Service (USFWS), the 20 6/2/2020 Project site does not contain riparian habitat.6 There are no riparian habitat or other sensitive natural communities as identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife (CDFW) or USFWS. According to the Biological Technical Report, small areas of disturbed California sagebrush scrub were the only native vegetation community identified on Project site. A small patch of mule fat (Baccharis salicifolia) was present in disturbed habitat, but was not of sufficient size or composition to qualify as a riparian vegetation community. The other vegetation community present on the Project site was California annual grassland, which is not considered sensitive. As such, no sensitive vegetation communities were observed on the Project site. In addition, two land cover types, disturbed areas and developed areas were observed on the Project site. The plant species observed within these cover types consisted of non-native or invasive weedy species. Therefore, development of the proposed Project is not anticipated to have a significant impact on any riparian habitat or other sensitive natural community. No mitigation would be required. (Appendix A [Initial Study], p. 4.12) 2. Wetlands Threshold: Would the Project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? Finding: Less than significant impact. (Draft EIR, p. 4.3-10.) Explanation: The approximately 17 -acre Project site is currently characterized by an undeveloped gravel parking lot and ruderal vegetation. According to the Aquatic Resources Delineation, no potential waters of the U.S. or CDFW jurisdictional areas are located on the Project site. A ditch located within the southern half of the Project site occasionally collects stormwater flows from the north and east of the site. However, this is not considered to be a water of the U.S. or a CDFW jurisdictional area as there are no indicators of water flow through this area. Furthermore, according to the National Wetlands Inventory managed by the USFWS, the Project site does not contain federally protected wetlands; however, the San Juan Creek Channel, located immediately west of the Project site, contains wetlands classified as Riverine and Freshwater Emergent Wetlands. Due to the proximity of the San Juan Creek Channel, project construction and operation could have potentially significant 6 United States Fish and Wildlife Service (USFWS). National Wetland Inventory. Website: https://www.fws. gov/wetlands/Data/Mapper.html (accessed April 24, 2019). 21 6/2/2020 impacts on federally protected wetlands and waters of the United States as defined by Section 404 of the Clean Water Act (CWA). Therefore, the improvements associated with the project could potentially affect off site wetlands. Construction. Pollutants of concern during construction and soil erosion may have a detrimental effect on water quality. During construction activities, excavated soil would be exposed, and there would be an increased potential for soil erosion and sedimentation compared to existing conditions. In addition, chemicals, liquid products, petroleum products (e.g., paints, solvents, and fuels), and concrete -related waste may be spilled or leaked and have the potential to be transported via storm water runoff into San Juan Creek. However, compliance with the requirements of the Construction General Permit and incorporation of construction BMPs to target pollutants of concern would ensure construction impacts related to the Riverine and Freshwater Emergent Wetlands within San Juan Creek would be reduced. Compliance with the Construction General Permit is specified in Regulatory Compliance Measure WQ-1. With implementation of Regulatory Compliance Measure WQ-1, construction impacts to the Riverine and Freshwater Emergent Wetlands contained within San Juan Creek Channel would be less than significant, and no mitigation is required. Operation. Pollutants of concern during operation may have a condition of the receiving waters for runoff from the Project site (San Juan Creek and the Pacific Ocean), the primary pollutants of concern from long-term operation of commercial and restaurant developments include nutrients, bacteria/viruses/pathogens, pesticides, and dry weather runoff; other pollutants of concern include suspended solids, oil and grease, and trash and debris. Required compliance with the City Municipal Code and South Orange County MS4 Permit requirements, including preparation of a Final WQMP and incorporation of post -construction BMPs to target pollutants of concern, would reduce operation impacts on the identified wetlands within San Juan Creek. Compliance with the South Orange County MS4 Permit requirements and the development of a Final WQMP is specified in Regulatory Compliance Measure WQ-4. With implementation of Regulatory Compliance Measure WQ-4, operational impacts to the Riverine and Freshwater Emergent Wetlands contained within San Juan Creek Channel would be less than significant. No mitigation would be required. (Draft EIR, pp. 4.3-10 through 4.3-11.) Regulatory Compliance Measures 22 6/2/2020 The proposed Project would comply with the following regulatory standards. RCM WQ-1 Construction General Permit. Prior to commencement of construction activities, the project Applicant shall obtain coverage under the National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit), NPDES No. CAS000002, Order No. 2009-0009- DWQ, as amended by Order No. 2010-0014-DWQ and Order No. 2012-0006-DWQ, or any other subsequent permit. This shall include submission of Permit Registration Documents (PRDs), including permit application fees, a Notice of Intent (N01), a risk assessment, a site plan, a Stormwater Pollution Prevention Plan (SWPPP), a signed certification statement, and any other compliance -related documents required by the permit, to the State Water Resources Control Board via the Stormwater Multiple Application and Report Tracking System (SMARTS). As required by Section 8-14.107 of the City of San Juan Capistrano's (City) Municipal Code, construction activities shall not commence until a Waste Discharge Identification Number (WDID) is obtained for the project from the SMARTS and provided to the City of San Juan Capistrano Building Official, or designee, to demonstrate that coverage under the Construction General Permit has been obtained. Project construction shall comply with all applicable requirements specified in the Construction General Permit, including but not limited to, preparation of a SWPPP and implementation of construction site Best Management Practices (BMPs) to address all construction -related activities, equipment, and materials that have the potential to impact water quality for the appropriate risk level identified for the project. The SWPPP shall identify the sources of pollutants that may affect the quality of stormwater and shall include BMPs (e.g., Sediment Control, Erosion Control, and Good Housekeeping BMPs) to control the pollutants in stormwater runoff. Construction Site BMPs shall also conform to the requirements specified in the latest edition of the Orange County Stormwater Program Construction Runoff Guidance Manual for Contractors, Project Owners, and Developers to control and minimize the impacts of construction and construction -related activities, materials, and pollutants on the watershed. Upon completion of construction activities and stabilization of the Project site, a Notice of Termination shall be submitted via SMARTS. RCM WQ-4 Water Quality Management Plan. Prior to issuance of building permits, the project Applicant shall submit a Final Water Quality Management Plan (WQMP) to the City of San Juan Capistrano Building Official, or designee, for review and approval in compliance with Section 8-14.105 of the City Municipal Code and 23 6/2/2020 3. 4 the National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for Discharges from the Municipal Separate Storm Sewer Systems (MS4) Draining the Watersheds within the San Diego Region (South Orange County MS4 Permit), Order R9-2013-0001, NPDES No. CA56010266, as amended by Order No. R9-2015-0001, or any other subsequent permit. The Final WQMP shall be prepared consistent with the requirements of the Model Water Quality Management Plan (Model WQMP) for South Orange County (County of Orange 2018) and the Technical Guidance Document for the Preparation of Conceptual/Preliminary and/or Project Water Quality Management Plans (WQMPs) (County of Orange 2018), or subsequent guidance manuals. The Final WQMP shall specify the BMPs to be incorporated into the project design to target pollutants of concern in runoff from the Project site. The City of San Juan Capistrano Building Official, or designee, shall ensure that the BMPs specified in the Final WQMP are incorporated into the final project design. Wildlife Movement Threshold: Would the Project 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? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-13.) Explanation: The Biological Technical Report determined that no migratory wildlife corridors or native wildlife nursery sites were identified within the Project site. The San Juan Creek Channel, located immediately west of the Project site, is unlikely to serve as a substantial corridor for local wildlife due to the lack of vegetative cover. Therefore, impacts would be less than significant, and no mitigation would be required. (Appendix A [Initial Study], p. 4-13.) Local Policies and Ordinances Threshold: Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Finding: Less than significant impact. (Appendix A [Initial Study], pp. 4-13 through 4-14.) Explanation: The majority of the Project site is characterized by an undeveloped gravel lot and ruderal vegetation. Currently, two existing red willow trees (Salix laevigata) are located on the Project site, both of which 24 6/2/2020 would be removed as part of project implementation. According to the Existing Tree Inventory Report, the two existing trees would not be suitable for relocation due to their state of decay and structural decline. Section 9-2.349 of the City's Municipal Code provides the policies on the removal of mature trees within the City. A tree removal permit is required for the removal of any mature trees associated with a development project that is subject to other discretionary land use approvals. Mature trees are considered to be trees with a diameter at breast height (3 ft above grade) greater than 6 inches. A tree removal permit for non -heritage trees may be approved administratively by the City Planning Director or designee. Trees defined as "heritage trees" shall not be removed without review and approval of the City Planning Commission. A heritage tree is defined by the City's Municipal Code as having the following characteristics: (1) having a trunk diameter at breast height of 36 inches or greater; and (2) being a specimen of the following species: California pepper (Schinus molle); oak (Quercus spp.); cedar (Cedar spp.); blue gum eucalyptus (Eucalyptus globulus); walnut (Jug/ans spp.); olive (Oleg europaea); sycamore (Platanus spp.); cottonwood (Populus spp.); or as otherwise designated by the Planning Commission based on the tree's unique and intrinsic value to the community because of its size, age, historic association or ecological value. Based on the information provided in the Existing Tree Inventory Report, the two red willow trees located on the Project site are not considered heritage trees and are considered diseased, structurally unsound, and unstable. Therefore, the Project Applicant would be required to apply for a tree removal permit as part of the discretionary actions to be considered by the City. As part of this process, the City would specify conditions of approval for the replacement of trees and landscaping, in compliance with the City's tree preservation policy, specified in the City's Municipal Code (Section 9-2.349(c)(1), Tree Removal Permit for New Development Projects). Therefore, the proposed Project would not result in adverse impacts related to local policies or ordinances protecting biological resources during construction, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-13 through 4-14.) 5. Habitat Conservation Plans Threshold: Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? 25 6/2/2020 Finding: Less than significant impact. (Appendix A [Initial Study], p. 4.14.) Explanation: The Project site is located in the Southern Region of the Orange County Natural Communities Conservation Plan/Habitat Conservation Plan (NCCP/HCP). One of the primary purposes of the NCCP/HCP is to serve as a conservation program that "shifts away from the focus on a project -by -project single species protection to conservation and management of many species and multiple habitats on a subregional level," thereby addressing long- term biological protection and management. Therefore, the Orange County NCCP/HCP essentially serves as a cumulative approach to conserving species and addressing biological impacts. The Project site is designated as developed area by the Orange County NCCP/HCP and is located outside of the boundaries of the Habitat Reserve System. Thus, the Orange County NCCP/HCP does not have any requirements that apply to the proposed Project. Therefore, the proposed Project would result in less than significant impacts related to potential conflicts with the goals and policies outlined in the Orange County NCCP/HCP. (Appendix A [Initial Study], p. 4-14.) E. CULTURAL RESOURCES 1. Historical Resources Threshold: Would the Project cause a significance of a historical Guidelines, section 15064.5? substantial adverse change in the resource pursuant to State CEQA Finding: No impact. (Appendix A [Initial Study], p. 4-16.) Explanation: CEQA defines a "historical resource" as a resource that meets one or more of the following criteria: 1. Is listed in, or determined eligible for listing in, the California Register of Historical Resources (California Register); 2. Is listed in a local register of historical resources as defined in Public Resources Code (PRC) Section 5020.1(k); 3. Is identified as significant in a historical resource survey meeting the requirements of PRC Section 5024.1(g); or 4. Is determined to be a historical resource by a project's Lead Agency (PRC Section 21084.1 and State CEQA Guidelines Section 15064.5[a]). Implementation of the proposed Project would not cause a substantial adverse change in the significance of a historical 26 6/2/2020 resource as defined in Section 15064.5 of the State CEQA Guidelines, as there are no eligible resources or structures on site. In its existing setting, the Project site is undeveloped. On September 26, 2017, a cultural resources records search was conducted at the South Central Coastal Archaeological Information Center (SCCIC), located at California State University, Fullerton. The purpose of the records search was to determine the extent of previous cultural resources investigations within -a 0.5 -mile radius of the project area, and whether any previously recorded archaeological sites or other historic resources exist within or near the project area. Materials reviewed included reports of previous cultural resources investigations, archaeological site records, historical maps, and listings of resources on the National Register of Historic Places (NRHP), California Register of Historical Resources (CRHR), California Points of Historical Interest, California Landmarks, and National Historic Landmarks. The records search indicated 49 cultural resources investigations have been conducted within the 0.5 -mile records search radius between 1978 and 2012. In addition, there is a list of "Indian Campsites" by John Romero from 1935. Approximately 75 percent of the area in the records search radius has been previously surveyed. One small area survey (OR -1506) extends into the southern part of the project area. The rest of the project area has not been previously surveyed. The records search results indicated that no previously recorded cultural resources have been recorded within the Project site and 14 resources have been recorded within 0.5 mile of the Project site. According to the results from the records search, no previously recorded historic properties are within the Project site. Furthermore, according to the City's map of historic buildings and structures,' there are no historic resources on or within the vicinity of the Project site. As a result, the project will not cause a substantial change in the significance of a historical resource as defined in State CEQA Guidelines Section 15064.5. No mitigation would be required. (Appendix A [Initial Study], pp. 4-15 through 4-16.) F. ENERGY 1. Wasteful Use of Energy Threshold: Would the Project result in potentially significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Finding: Less than significant impact. (Draft EIR, p. 4.5-9.) 27 6/2/2020 Explanation: Construction. Construction of the proposed Project is anticipated to last 24 months, and would require energy for activities such as the manufacture and transportation of building materials, demolition and grading activities, and building construction. Construction of the proposed Project would require electricity to power construction - related equipment. Construction of the proposed Project would not involve the consumption of natural gas. The construction -related equipment would not be powered by natural gas, and no natural gas demand is anticipated during construction. Transportation energy represents the largest energy use during construction and would occur from the transport and use of construction equipment, delivery vehicles and haul trucks, and construction worker vehicles that would use petroleum fuels (e.g., diesel fuel and/or gasoline). Therefore, the analysis of energy use during construction focuses on fuel consumption. Construction trucks and vendor trucks hauling materials to and from the Project site would be anticipated to use diesel fuel, whereas construction workers traveling to and from the Project site would be anticipated to use gasoline -powered vehicles. Fuel consumption from transportation uses depends on the type and number of trips, VMT, the fuel efficiency of the vehicles, and travel mode. As indicated in Table 4.5.A (found at Draft EIR, p. 4.7-8), the project would consume approximately 381,084 gallons of fuel during construction, which would increase the annual construction generated fuel use in Orange County by approximately 2.2 percent. As such, project construction would have a negligible effect on local and regional energy supplies. Furthermore, impacts related to energy use during construction would be temporary and relatively small in comparison to Orange County's overall use of the State's available energy sources. No unusual project characteristics would necessitate the use of construction equipment that would be less energy efficient than at comparable construction sites in the region or the State. For these reasons, fuel consumption during construction would not be any more inefficient, wasteful, or unnecessary than other similar development projects of this nature and impacts would be less than significant. No mitigation is required. Operation. Energy use consumed by the proposed Project would be associated with natural gas use, electricity consumption, and fuel used for vehicle trips associated with the project. As shown in Table 4.5-A (found at Draft EIR, p. 4.5-9), the estimated potential increase in electricity demand associated with the operation of the proposed Project is 1,840,033 kWh per year. Total electricity 28 6/2/2020 demand in Orange County in 2018 was approximately 13,044,070,989 kWh. Therefore, operation of the proposed Project would increase the annual electricity consumption in Orange County by approximately 0.014 percent. However, it should be noted that the proposed Project is the relocation of a Ganahl Lumber store currently operating, and consuming electricity, in the adjacent City of Dana Point. As shown in Table 4.5.A (found at Draft EIR, p. 4.5-8), the estimated potential increase in natural gas demand associated with the proposed Project is 19,536 therms per year. Total natural gas consumption in Orange County in 2018 was 236,102,647 therms. Therefore, operation of the proposed Project would negligibly increase the annual natural gas consumption in Orange County by approximately 0.008 percent. However, it should be noted that the proposed Project is the relocation of a Ganahl Lumber store currently operating, and consuming natural gas, in the adjacent City of Dana Point. Electrical and natural gas demand associated with project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. Furthermore, the proposed Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency. The project would be required to adhere to all federal, State, and local requirements for energy efficiency, including the Title 24 standards. Title 24 building energy efficiency standards establish minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting. Compliance with Title 24 standards is required and is identified in Regulatory Compliance Measure E-1, which would significantly reduce energy usage. Impacts are considered less than significant and no mitigation is required. The proposed Project would also result in energy usage associated with gasoline fuel consumed by project -related vehicle trips. As shown in Table 4.5.A of the Draft EIR, fuel use associated with the vehicle trips generated by the proposed Project is estimated at 422,889 gallons. The amount of operational fuel use was estimated using CARB's EMFAC2014 model, which provided projections for typical daily fuel usage in Orange County. This analysis conservatively assumes that all vehicle trips generated as a result of project operation would be new to Orange County. Further, it should be noted that the proposed Project is the relocation of a Ganahl Lumber store currently operating in the adjacent City of Dana Point; fuel consumption due to vehicle trips is already 29 6/2/2020 occurring under the existing conditions. Total fuel consumption in Orange County in 2018 includes on -road automotive fuel consumption and off-road equipment fuel consumption, and is estimated at approximately 1,402,492,695 gallons. Therefore, operation of the proposed Project would increase the annual automotive fuel consumption in Orange County by approximately 0.031 percent. The proposed Project would not result in excessive long-term operational automotive fuel consumption. Fuel consumption associated with vehicle trips generated by project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. Furthermore, the project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency. Impacts are considered less than significant, and no mitigation is required. (Draft EIR, pp. 4.5-7 through 4.5-9.) Requiatory Compliance Measures RCM E-1 California Code of Regulations (CCR), Title 24. Prior to issuance of building permits, the City of San Juan Capistrano (City) Director of Development Services, or designee, shall confirm that the project design complies with the 2019 Building Energy Efficiency Standards (CCR Title 24) energy conservation and green building standards, as well as those listed in Part 11 (California Green Building Standards Code [CalGreen Code]). The City Director of Development Services shall confirm that the project complies with the mandatory measures listed in the CalGreen Code for non- residential building construction. 2. Energy Efficiency Plans Threshold: Would the Project conflict with or obstruct a state of local plan for renewable energy or energy efficiency? Finding: Less than significant impact. (Draft EIR, 4.5-10.) Explanation: In 2002, the Legislature passed SB 1389, which required the CEC to develop an integrated energy plan every 2 years for electricity, natural gas, and transportation fuels for the California Energy Policy Report. The plan calls for the State to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators in implementing incentive programs for ZEVs and their infrastructure needs, and encouragement of 30 6/2/2020 urban designs that reduce VMT and accommodate pedestrian and bicycle access. The CEC recently adopted the 2017 Integrated Energy Policy Report (CEC 2018a) and the 2018 Integrated Energy Policy Report Update (CEC 2018b). The Integrated Energy Policy Report provides the results of the CEC's assessments of a variety of energy issues facing California. Many of these issues will require action if the State is to meet its climate, energy, air quality, and other environmental goals while maintaining energy reliability and controlling costs. The Integrated Energy Policy Report covers a broad range of topics, including implementation of SB 350, integrated resource planning, distributed energy resources, transportation electrification, solutions to increase resiliency in the electricity sector, energy efficiency, transportation electrification, barriers faced by disadvantaged communities, demand response, transmission and landscape -scale planning, the California Energy Demand Preliminary Forecast, the preliminary transportation energy demand forecast, renewable gas, updates on Southern California electricity reliability, natural gas outlook, and climate adaptation and resiliency. The City of San Juan Capistrano relies on the State integrated energy plan and does not have its own local plan to address renewable energy or energy efficiency. As indicated above, energy usage on the Project site during construction would be temporary in nature and would be relatively small in comparison to the overall use in the County. In addition, energy usage associated with operation of the proposed Project would be relatively small in comparison to the overall use in Orange County, and the State's available energy sources and energy impacts would be negligible at the regional level. Because California's energy conservation planning actions are conducted at a regional level, and because the proposed Project's total impact on regional energy supplies would be minor, the proposed Project would not conflict with or obstruct California's energy conservation plans as described in the CEC's Integrated Energy Policy Report. Additionally, the proposed Project would not result in the inefficient, wasteful, and unnecessary consumption of energy. Potential impacts related to conflict with or obstruction of a State or local plan for renewable energy or energy efficiency would be less than significant, and no mitigation is required. Energy impacts related to the inefficient, wasteful, and unnecessary consumption of energy are considered less than significant, and no mitigation is required. G. GEOLOGY AND SOI 31 6/2/2020 1. (a) Fault Rupture Threshold: Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault (refer to Division of Mines and Geology Special Publication 42)? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-19.) Explanation: As with all of Southern California, the Project site is located in an area that is subject to strong ground motion resulting from earthquakes on nearby faults. However, according to the Geotechnical Investigation prepared for the proposed Project, the Project site is not located within an established Alquist-Priolo Earthquake Fault Zone for surface fault ruptures. In addition, there are no known active faults or fault traces with the potential for surface fault rupture crossing the Project site. The nearest known earthquake fault to the Project site is the Newport -Inglewood -Rose Canyon Fault Zone, which is located approximately 20 miles to the north of the Project site. Therefore, impacts related to the rupture of a known earthquake fault as depicted on the most recent Alquist- Priolo Earthquake Fault Zoning Map are less than significant, and no mitigation would be required. (Appendix A [Initial Study], pp. 4- 18 through 4-19.) 1. (d) Landslides Threshold: Would the Project expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving landslides? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-20.) Explanation: Seismically induced landslides and other slope failures are common occurrences during or soon after earthquakes in areas with significant ground slopes. The topography at the existing Project site and within the surrounding area is relatively flat. According to the Geotechnical Investigation, the Project site is not within an earthquake -induced landslide zone and is not located within an area subject to potential seismic slope instability. Therefore, seismically induced landslides are unlikely to occur at the site, and no mitigation would be required. (Appendix A [Initial Study], p. 4-20.) 2. Soil Erosion 32 6/2/2020 Threshold: Would the Project result in substantial soil erosion or the loss of topsoil? Find lng: Less than significant impact. (Draft EIR, p. 4.6-11.) Explanation: During construction activities, soil would be exposed and there would be an increased potential for soil erosion compared to existing conditions due to soil disturbance and the exposure of substantial amounts of soil to weather conditions (e.g., wind, rain). During a storm event, soil erosion could occur at an accelerated rate. The increased erosion potential could result in short-term water quality impacts as identified in Section 4.9, Hydrology and Water Quality. During construction, the project Applicant is required to adhere to the requirements of the General Construction Permit and utilize typical BMPs specifically identified in the SWPPP (as required by Regulatory Compliance Measure WQ-1) for the project in order to prevent construction pollutants from contacting stormwater and to keep all products of erosion from moving off site into receiving waters. Additionally, the project Applicant is required to install and maintain erosion control devices year round in compliance with a City -approved pollution control plan, construction BMP plan, and/or erosion and sediment control plan (as required by Regulatory Compliance Measure WQ-2). Water -related impacts during construction would be less than significant through implementation of construction site BMPs, as specified in Regulatory Compliance Measures WQ-1 and WQ-2. The proposed Project would result in an increase in impervious area and a net increase in stormwater runoff; however, the proposed Project would also install a stormwater runoff system to manage increased peak runoff from the site. Additionally, a Final Hydrology and Hydraulic Analysis would be required to be prepared and submitted to the City for Approval, to ensure the peak flow of stormwater runoff in the proposed condition would not exceed the outfall capacity (as required by Regulatory Compliance Measure WQ-5). As a result, any increase in peak discharge would be negligible. Therefore, the proposed Project would not result in substantial on-site or downstream erosion, siltation, or flooding, and no mitigation is required. (Draft EIR, pp. 4.6-10 through 4.6-11.) 3. Unstable Soils Threshold: Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? 33 6/2/2020 Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-20, Draft EIR, pp. 4.6-11 through 4.6-13.) Explanation: Landslides. Both the existing Project site and the surrounding area are relatively flat and are not subject to slope instability or landslides. Therefore, on- or off-site landslides are not considered a potential constraint or a potentially significant impact of the project, and no mitigation is required. (Appendix A [Initial Study], p. 4-20.) Unsuitable Soils. Subsidence. The phenomenon of widespread land sinking, or subsidence, is generally related to substantial overpumping of groundwater or petroleum reserves from deep underground reservoirs. Overpumping and excessive groundwater withdrawal have not occurred in the project area. In addition, the project does not have an oil, gas, or water pump on site and none are located near the site and has not been used for the extraction of either resource. Subsidence is therefore not considered a potential constraint or a potentially significant impact of the project, and no mitigation is required. Lateral Spreading. Lateral spreading typically occurs as a form of horizontal displacement of relatively flat -lying alluvial material toward an open or "unconfined" face such as an open body of water, channel, or excavation. In soils, this movement is generally due to failure along a weak plane and may often be associated with liquefaction. According to the Geotechnical Investigation, lateral spreading at the Project site is not a concern because the proposed final ground surface would be relatively flat and the recently constructed sheet pile system along the San Juan Creek levee (a separate project), which penetrates below the lowest liquefiable layer identified within the Project site for protection of the creek levee, would prevent lateral motion from occurring. Therefore, the soils on the Project site are not subject to lateral spreading. Therefore, lateral spreading is not considered a potential constraint or a potentially significant impact of the project, and no mitigation is required. 34 6/2/2020 (Draft EIR, pp. 4.6-11 through 4.6-13.) 4 Septic Tanks Threshold: Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? Finding: No impact. (Appendix A [Initial Study], p. 4-21.) Explanation: The proposed Project would include a sewer connection to the City's existing sewer infrastructure and would not include the installation of, or connections to, a septic system or alternative waste water disposal system. Therefore, the proposed Project would not result in impacts related to the soils capability to adequately support the use of septic tanks or alternative wastewater disposal systems, and no mitigation would be required. (Appendix A [Initial Study], p. 4-22.) H. GREENHOUSE GAS EMISSIONS 1. Emissions Generation Threshold: Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Finding: Less than significant impact. (Draft EIR, pp. 4.7-10 through 4.7-11.) Explanation: Construction. Construction activities associated with the proposed Project would result in emissions of CO2e from construction activities, including construction worker commute trips, haul trucks carrying supplies and materials to and from the Project site, and off- road construction equipment (e.g., dozers, loaders, and excavators). Project construction -generated GHG emissions were primarily calculated using CalEEMod model defaults for Orange County, and construction of the proposed Project was assumed to start in 2020 and is estimated to last 24 months. Table 4.7.A (found at Draft EIR, p. 4.7-8) shows construction -generated GHG emissions that would result from construction of the project. As shown in Table 4.7.A (found at Draft EIR, p. 4.7-8), construction of the proposed Project would generate approximately 3,868 MT over the course of construction. The amortized construction emissions have been assessed as part of the annual average operation emissions, below. Because construction would be temporary (approximately 24 months), would cease upon project completion, and would not result in a permanent increase in 35 6/2/2020 emissions, impacts would be less than significant and no mitigation is required. Operation. Operation of the project would result in GHG emissions predominantly associated with motor vehicle use by employees and patrons to the Project site. Projected emissions associated with the proposed Project were compared to the existing baseline, which includes a vehicle storage lot containing 752 spaces in the central portion of the Project site. Table 4.7.13 (found at Draft EIR, p. 4.7-9) shows the long-term operational GHG emissions attributable to the project following site buildout, which are compared to SCAQMD's interim screening -level bright -line threshold of 3,000 MT of CO2e annually. As shown in Table 4.7.13 (found at Draft EIR, p. 4.7-9), project operations would generate 3,787 MT of CO2e per year, which exceeds SCAQMD's interim screening -level bright -line threshold of 3,000 MT of CO2e per year. As such, the project has been compared with the efficiency -based threshold of 4.8 MT of CO2e per Project site service population per year by the year 2020, and 3.0 MT of CO2e per Project site service population per year in 2035. The project's service population is comprised of project employees and patrons to the Project site. The SCAQMD identifies the emissions level for which a project would not be expected to substantially conflict with any State legislation adopted to reduce statewide GHG emissions. As such, the utilization of a service population represents the rates of emissions needed to achieve a fair share of the State's mandated emissions reductions. Overall, SCAQMD identifies a GHG efficiency level that, when applied statewide or to a defined geographic area, would meet the year 2020 and post -2020 emissions targets as required by AB 32 and SB 32. If projects are able to achieve targeted rates of emissions per the service population, the State will be able to accommodate expected population growth and achieve economic development objectives, while also abiding by AB 32's emissions target and future post -2020 targets. According to the Air Quality & Greenhouse Gas Assessment, patrons would comprise the majority of visitors to the Project site, followed by a smaller number of employees working at the site. Patrons visiting the Project site would not reside on site; instead, they would largely reside in the surrounding communities and represent a population that is served by the proposed uses. Additionally, patrons traveling to the Project site would represent a dominate source of project -generated GHG emissions. For these 36 6/2/2020 reasons, an efficiency -based threshold is utilized in the analysis. The Air Quality & Greenhouse Gas Assessment estimates that 1,491 patrons would visit the Project site per day. Combined with the 145 employees expected to be employed at the Project site daily, the project's service population totals 1,636 people.' Table 4.7.0 (found at Draft EIR, p. 4.7-10) shows the project's estimated operational GHG emissions per service population. As shown in Table 4.7.0 (found at Draft EIR, p. 4.7-10), the project would not exceed SCAQMD efficiency -based thresholds in either 2020 or 2035 buildout scenarios. SCAQMD thresholds were developed based on substantial evidence that such thresholds represent quantitative levels of GHG emissions. Since the project is in compliance with this threshold, the project's environmental impact related to GHG emissions would not be cumulatively considerable under CEQA. Therefore, impacts related to operational GHG emissions would be less than significant, and no mitigation would be required. (Draft EIR, pp. 4.7-8 through 4.7-11.) 2. Emission Reduction Plans Threshold: Would the Project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emission of greenhouse gases? Finding: Less than significant impact. (Draft EIR, p. 4.7-11.) Explanatior7: Although the City of San Juan Capistrano does not currently have an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions, the City is a member city of SCAG. SCAG's 2016-2040 RTP/SCS is a long-range planning document that provides a common foundation for regional and local planning, policymaking, and infrastructure goals in the SCAG region. The 2016-2040 RTP/SCS establishes GHG emissions goals for automobiles and light-duty trucks for target years 2020 and 2035 and establishes an overall GHG target for the region consistent with both the statewide GHG-reduction targets for 2020 and post -2020 statewide GHG reduction goals. Table 4.7.D (found at Draft EIR, pp. 4.7-12 through 4.7-13) shows the proposed Project's consistency with the 2016-2040 RTP/SCS goals as analyzed in the Air Quality & Greenhouse Gas Assessment. For more information regarding the methodology used to calculate project's service population, refer to the Air Quality & Greenhouse Gas Assessment, included as Appendix B to the Draft EIR. 37 6/2/2020 As shown in Table 4.7.D (found at Draft EIR, pp. 4.7-12 through 4.7-13), the proposed Project would not conflict with the stated goals of the 2016-2040 RTP/SCS. As such, the proposed Project would not interfere with SCAG's ability to achieve the region's 2020 and post -2020 mobile source GHG reduction targets outlined in the 2016-2040 RTP/SCS, and it can be assumed that regional mobile emissions will decrease consistent with the goals of the 2016-2040 RTP/SCS. Further, the proposed Project is not considered regionally significant per State CEQA Guidelines Section 15206. Thus, the project would not conflict with the 2016-2040 RTP/SCS targets since those targets were established and are applicable on a regional level. Therefore, impacts related to conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions would be less than significant, and no mitigation is required. (Draft EIR, p. 4.7-11.) I. HAZARDS AND HAZARDOUS MATERIALS 1. Hazardous Materials Threshold: Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-26.) Explanation: Hazardous materials are chemicals that could potentially cause harm during an accidental release or mishap, and are defined as being toxic, corrosive, flammable, reactive, and irritant, or strong sensitizer.$ Hazardous substances include all chemicals regulated under the United States Department of Transportation "hazardous materials" regulations and the United States Environmental Protection Agency (EPA) "hazardous waste" regulations. These hazardous wastes require special handling and disposal because of their potential to damage public health and the environment. The probable frequency and severity of consequences from the routine transport, use, or disposal of hazardous materials is affected by the type of substance, the quantity used or managed, and the nature of the activities and operations. Construction. During construction activities for the proposed Project, there is a possibility of generating small quantities of hazardous materials. The construction phase of the proposed 8 A "sensitizer" is a chemical that can cause a substantial proportion of people or animals to develop an allergic reaction in normal tissue after repeated exposure to a chemical (U.S. Department of Labor 2017). 38 6/2/2020 Project may include the transport, storage, and short-term use of petroleum-based fuels, lubricants, pesticides, and other similar materials. The amount of hazardous chemicals present during construction is limited and would be in compliance with existing government regulations, such as the Hazardous Materials Transportation Act, the Resource Conservation and Recovery Act, and the California Code of Regulations (Title 22). Any associated risk would be adequately reduced to a level that is less than significant through compliance with these standards and regulations; thus, the limited use and storage of hazardous materials during construction of the proposed Project proposed Project would not pose a significant hazard to the public or the environment. Accordingly, the potential for the release of hazardous materials during project construction would be low and, even if a release would occur, it would not result in a significant hazard to the public, surrounding land uses, or environment due to the small quantities of these materials associated with construction. No mitigation would be required. Operation. The proposed Project would allow for the development of a lumber yard and hardware store, drive-through restaurant uses, and a crushed -rock gravel area for long-term vehicle storage. Hazardous substances associated with retail, warehousing, and restaurant uses are typically limited in both amount and use, such that they can be contained without impacting the environment. Long-term operational activities typical of the proposed retail, lumber storage yard, and restaurant uses, such as landscape and building maintenance, would occur on the Project site. Maintenance activities related to landscaping include the use of fertilizers and light equipment (such as lawn mowers and edgers). These types of activities do not involve the use of a large or substantial amount of hazardous materials. The proposed retail, lumber storage yard, and restaurant uses would involve the use and storage of small quantities of potentially hazardous materials in the form of cleaning solvents and pesticides. However, such materials would be contained, stored, and used in accordance with manufacturers' instructions and handled in compliance with applicable standards and regulations. As such, when utilized properly, hazardous materials used and stored on the Project site would not result in a significant hazard to visitors or the environment. A fueling area for delivery trucks will be included as part of the project. During operation of the proposed Project, the diesel fueling station would be enclosed within integrated containment vessels, and would be required to be operated in compliance with all applicable State and federal regulations governing the handling of 39 6/2/2020 diesel fuels. As stated in Section 4.9, Hydrology and Water Quality, Best Management Practices (BMPs) will be implemented as part of the Water Quality Management Plan (WQMP) to ensure proper operation of the fueling area and avoid any hazardous wastes that could be generated as a result. The project proposes vehicle parking and storage; however, there would be no vehicle cleaning or maintenance areas on the Project site. As such, chemicals, oils, and grease, generated from such activities would not result in significant impacts related to the release of hazardous materials. All transport, handling, use, and disposal of substances such as petroleum products, paints, and solvents related to the operation and maintenance of the proposed Project would be required to comply with all federal, State, and local laws regulating the management and use of hazardous materials. Additionally, the Project Applicant has retained a Chemical Classification and High Pile Storage consultant to provide guidance on the handling of hazardous materials. Therefore, compliance with BMPs and adherence to the recommendations of the chemical classification consultant, the proposed Project would result in a less than significant impact with regard to the routine transport, use, or disposal of hazardous material. (Appendix A [Initial Study], pp. 4-24 through 4-26.) 2. Hazards Near Schools Threshold: Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one- quarter mile of an existing or proposed school? Finding: Less than significant impact. (Appendix A [Initial Study], pp. 4-28 through 4-29.) Explanation: West River Academy Private School located at 33721 Bluewater Lane, in the City of Dana Point, is the nearest school to the Project site, located approximately 0.25 mile to the southwest. The closest public schools to the Project site are Del Obispo Elementary School, located at 25591 Camino Del Avion, and Marco Forster Middle School, located at 25601 Camino Del Avion, both of which are approximately 0.6 mile north of the Project site. Construction. Construction activities would involve the routine use of hazardous materials such as fuels, lubricants, paints, curing compounds, solvents, and sanitizers. Compliance as required with 40 6/2/2020 various federal, State, and local regulations related to hazardous materials use, storage, transportation, and disposal is expected to reduce the risk of a spill or accidental release of hazardous materials to a less than significant level. Construction of the proposed Project would also include the use of construction equipment that would generate dust and particulate matter during site preparation activities within 0.25 mile of an existing school. These fugitive dust emissions would occur during construction of the proposed Project as a result of demolition, grading, and the exposure of soils to air and wind. However, in order to reduce fugitive dust emissions, the project would be required to comply with SCAQMD standard conditions and Rule 403. These required dust suppression techniques would reduce fugitive dust generation and would reduce construction impacts resulting from hazardous emissions within 0.25 mile of an existing or proposed school to a less than significant level during construction activities. No mitigation would be required. Operation. Although the Project site is located within 0.25 mile of West River Academy Private School, operation of the proposed commercial uses would not result in the production of hazardous emissions or handling of significant amounts of hazardous materials. Therefore, operation of the proposed retail, lumber storage yard, and restaurant uses would not emit hazardous emissions or involve handling of hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school during operation. Therefore, impacts within 0.25 mile of an existing or proposed school are considered less than significant, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-28 through 4-29.) 3. Waste Sites Threshold: Would the Project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? Finding: No impact. (Appendix A [Initial Study], p. 4-29.) Explanation: According to the Phase I ESA, which included a review of hazardous materials databases, the Project site is not included on any hazardous materials site list pursuant to Government Code Section 65962.5 and would not result in a significant hazard to the public or the environment. No mitigation would be required. (Appendix A [Initial Study], p. 4-29.) 41 6/2/2020 4. Public Airports Threshold: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? Finding: No impact. (Appendix A [Initial Study], p. 4-29.) Explanation: There are no airports within 2 miles of the Project site. The nearest public use airport to the Project site is John Wayne Airport located at 18601 Airport Way, in the City of Santa Ana, approximately 17 miles northwest of the Project site. Given the distance of the Project site to the nearest airport, there would be no safety hazards for people residing or working at the Project site or vicinity. No mitigation would be required. (Appendix A [Initial Study], p. 4-29.) 5. Emergency Plans Threshold: Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-30.) Explanation: The City's General Plan Safety Element (2002) identifies and evaluates natural hazards associated with seismic activity, landslides, flooding and fire within the City. The General Plan Safety Element establishes goals for each of the City departments to provide responsible planning aimed at reducing impacts with respect to loss of life, injuries, damage to property and other losses associated with disasters, such as those resulting from seismic activity, flooding, and fires. According to the City's map of evacuation routes, Stonehill Drive is listed as a potential evacuation routes in the event of an emergency.9 Construction. Construction of the proposed Project, specifically construction of the proposed signal and deceleration lane on Stonehill Drive, may result in temporary lane closures adjacent to the Project site. However, construction impacts would be temporary in nature and would cease upon project completion. As such, the Project would not physically impair or otherwise conflict with the 9 City of San Juan Capistrano. Evacuation Routes. Website: http://sanjuancapistrano.orePortals/0/Evacuation%2OMap%202017.pdf (accessed on April 24, 2019). 42 6/2/2020 long-term implementation of the City's Emergency Preparedness Program. Therefore, construction of the proposed Project would result in less than significant impacts related to the implementation of emergency response and evacuation plans, and no mitigation would be required. Operation. The emergency management plans for the City, in conjunction with the emergency plan for the County, may be activated and directed by a number of individuals within the City or County, including, but not limited to, the City Manager, the Fire Chief, and the Police Chief. Roads that are used as response corridors/evacuation routes usually follow the most direct path to or from various parts of a community, although emergency response vehicles may choose to use a variety of routes to access surrounding areas. Stonehill Drive is identified as an evacuation route in the City. The proposed Project would be required to comply with all applicable codes and ordinances for emergency vehicle access, which would ensure adequate access to, from, and on site for emergency vehicles. Adherence to these codes and ordinances would ensure that operation of the Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. In addition, the proposed Project includes expanded access via an emergency access road extending to the north of the site, and a new access road extending under the Stonehill Drive bridge to parcels immediately south of the Project site. Therefore, operation of the proposed Project would result in less than significant impacts related to the implementation of emergency response and evacuation plans, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-29 through 4-30.) 6. Wildland Fires Threshold: Would the Project expose people or structures to a significant risk of loss, injury or death involving wildland fires? Finding: No impact. (Appendix A [Initial Study], pp. 4-30 through 4-31.) Explanation: The Project site is located in an urbanized, developed portion of the City of San Juan Capistrano. Surrounding land uses include a mobile home park to the north; the San Juan Creek Channel and Trail, Creekside Park, and single-family residential uses to the west; the BNSF rail line and automobile dealerships to the east; and a hotel, a mobile home park, and commercial uses south of Stonehill Drive. 43 6/2/2020 The Project site is not adjacent to any wildland areas. The Project site is not located within a High Fire Hazard Zone according to the Fire Hazards Area Map in the City's General Plan Public Safety Element (2002). According to the CAL FIRE and Resource Assessment Program, the Project site is not within a Very High Fire Hazard Severity Zone (VHFHSZ).10 As a result, the proposed Project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires. Therefore, no impacts are anticipated, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-30 through 4-31.) J. HYDROLOGY AND WATER QUALITY 1. Water Quality Standards Threshold: Would the Project violate any water quality standards or waste discharge requirements? Fines: Less than significant impact. (Draft EIR, pp. 4.9-15 through 4.9-19.) Explanation: Construction. The proposed Project would allow for the development of a lumber yard and hardware store, drive-through restaurant uses, and a crushed -rock gravel area for long-term vehicle storage. Pollutants of concern during construction include, but are not limited to, sediments, trash, petroleum products, concrete waste (dry and wet), sanitary waste, and chemicals. Each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. During construction activities, excavated soil would be exposed, and there would be an increased potential for soil erosion and sedimentation compared to existing conditions. In addition, chemicals, liquid products, petroleum products (e.g., paints, solvents, and fuels), and concrete - related waste may be spilled or leaked and have the potential to be transported via stormwater runoff into receiving waters (i.e., San Juan Creek and ultimately the Pacific Ocean). Sediment from increased soil erosion and chemicals from spills and leaks have the potential to be discharged to downstream receiving waters during storm events, which can affect water quality and impair beneficial uses. Because construction of the proposed Project would disturb greater than 1 acre of soil, the proposed Project is subject to the 10 CalFire. Very High Fire Hazard Severity Zones in LRA. San Juan Capistrano. October 2011. Website: http://www.fire.ca.gov/fire_prevention/fhsz_maps/FHSZ/ora nge/c30_SanJuanCap istrano_vhfhsz.pdf (accessed April 24, 2019). 44 6/2/2020 requirements of the Construction General Permit, as specified in Regulatory Compliance Measure WQ-1. As also specified in Regulatory Compliance Measure WQ-1, a SWPPP would be prepared and construction BMPs detailed in the SWPPP would be implemented during construction, in compliance with the requirements of the Construction General Permit. In addition, as specified in Regulatory Compliance Measure WQ-2, a pollution control plan, construction BMP plan, and/or erosion and sediment control plan would be prepared and submitted to the City's Building Official prior to issuance of a grading or building permit in compliance with the City Municipal Code. The SWPPP and pollution control plan, construction BMP plan, and/or erosion and sediment control plan would detail the BMPs to be implemented during construction. Construction BMPs would include, but not be limited to, Erosion Control and Sediment Control BMPs designed to minimize erosion and retain sediment on site, and Good Housekeeping BMPs to prevent spills, leaks, and discharge of construction debris and waste into receiving waters. The Construction General Permit and City Municipal Code also require inspection and maintenance of construction BMPs prior to, during, and after rain events. Compliance with the requirements of the Construction General Permit and City Municipal Code, including incorporation of construction BMPs to target and reduce pollutants of concern in stormwater runoff, would ensure that construction impacts related to waste discharge requirements, water quality standards, and degradation of water quality would be less than significant. The Project site lies within the southerly portion of the San Juan Groundwater Basin. As discussed in the Update Geotechnical Investigation Report, groundwater was encountered in all exploratory borings drilled to a depth of 18 to 22 ft bgs. Groundwater depth can fluctuate due to factors such as rainfall and presence of water near the Project site. Because excavation is anticipated to reach a maximum depth of approximately 20 ft bgs, there is a potential for groundwater to be encountered during construction and for groundwater dewatering to be required. Release of dewatered groundwater to surface waters can introduce total dissolved solids and other constituents to surface waters. In the event that groundwater or perched groundwater is encountered during construction and groundwater dewatering is necessary, disposal of dewatered groundwater can introduce total dissolved solids and other constituents to surface waters. Any groundwater dewatering during excavation would be conducted in accordance with the Groundwater Discharge Permit, as specified in Regulatory Compliance Measure Regulatory Compliance Measure WQ-3. The Groundwater Discharge Permit would require testing and 45 6/2/2020 treatment (as necessary) of groundwater encountered during groundwater dewatering prior to release to surface waters to ensure that discharges do not exceed water quality limits specified in the permit. Compliance with the requirements of the Groundwater Discharge Permit, as specified in Regulatory Compliance Measure WQ-3, would ensure impacts related to waste discharge requirements, water quality standards, and surface water quality would be less than significant during dewatering activities, and no mitigation would be required. Although groundwater dewatering would likely be required, dewatered groundwater would be discharged to the storm drain system, which discharges to San Juan Creek, rather than back into groundwater and therefore would not have the potential to introduce pollutants to groundwater. Infiltration of stormwater has the potential to affect groundwater quality in areas of shallow groundwater. However, according to the Preliminary Water Quality Management Plan prepared for the proposed Project, a majority of the on-site soils are not favorable for infiltration. Additionally, as discussed above, groundwater could occur at depths from 18 to 22 ft bgs. Pollutants in stormwater are generally removed by soil through absorption as water infiltrates. In areas of deep groundwater, there is more absorption potential and, as a result, less potential for pollutants to reach groundwater. As such, due to the depth to groundwater and low infiltration potential of the majority on-site soils, there is not a direct path for pollutants to reach groundwater. As such, the potential for stormwater to infiltrate and introduce pollutants to groundwater during construction would be minimal and project construction activities would not substantially degrade groundwater quality. In conclusion, construction of the proposed Project would comply with existing NPDES regulations (as specified in Regulatory Compliance Measures WQ-1, WQ-2, and WQ-3), which include preparation of a SWPPP and a pollution control plan; preparation of a construction BMP plan, and/or erosion and sediment control plan; implementation of Construction BMPs to target and reduce pollutants of concern in stormwater runoff; and testing and treatment (if required) of any groundwater prior to discharge to surface waters. Compliance with these regulatory requirements would ensure that impacts related to violation of any water quality standards or waste discharge requirements, and degradation of surface or ground water quality, during construction would be less than significant, and no mitigation is required. Operation. According to the Preliminary Water Quality Management Plan prepared for the project, based on the existing impairments and water quality condition of the receiving waters for 46 6/2/2020 runoff from the Project site (San Juan Creek and the Pacific Ocean), the primary pollutants of concern from long-term operation of commercial and restaurant developments include suspended solids, nutrients, heavy metals, bacteria/viruses/pathogens, pesticides, toxic organic compounds, trash and debris, and dry weather runoff; other pollutants of concern include oil and grease. The project would comply with the requirements of Title 8, Chapter 14 of the City's Municipal Code and the South Orange County MS4 Permit. WQMPs specify the Site Design, Source Control, Low Impact Development (LID) BMPs that would be implemented to capture, treat, and reduce pollutants of concern in stormwater runoff. Site Design BMPs are stormwater management strategies that emphasize conservation and use of existing site features to reduce the amount of runoff and pollutant loading generated from a Project site. Source Control BMPs are preventative measures that are implemented to prevent the introduction of pollutants into stormwater. LID BMPs mimic a Project site's natural hydrology by using design measures that capture, filter, store, evaporate, detain, and infiltrate runoff rather than allowing runoff to flow directly to piped or impervious storm drains. The Preliminary Water Quality Management Plan prepared for the project specifies the Source Control, Site Design, and LID BMPs proposed for the project. The Preliminary Water Quality Management Plan will be refined during final design based on the final site plans, as specified in Regulatory Compliance Measure WQ-4. The proposed Project BMPs are detailed, below. As detailed in the Preliminary Water Quality Management Plan, proposed Site Design BMPs include: maximize pervious areas, preserve existing drainage patterns and time of concentration, disconnect impervious areas, revegetate disturbed areas, protection of soil stockpiling, water efficient landscaping, and slope and channel buffers. Proposed Non -Structural Source Control BMPs include education for property owners, tenants and occupants; activity restrictions; common area landscape management; BMP maintenance; common area litter control; employee training; housekeeping of loading docks; common area catch basin inspections; and street sweeping public streets and parking lots. Proposed Structural Source Control BMPs include: provide storm drain system stenciling and signage; design and construct outdoor material storage areas to reduce pollution introduction; design and construct trash and waste storage areas to reduce pollution introduction; use of efficient irrigation systems and landscape design, water conservation, smart controllers, and source control; 47 6/2/2020 protect slopes and channels and provide energy dissipation; incorporate requirements applicable to individual priority project categories (from SDRWQCB NPDES Permit); loading dock areas; fueling areas; hillside landscaping; and wash water control for food preparation areas. The proposed LID BMPs include underground detention systems and proprietary treatment BMPs (Modular Wetland Stormwater Biofiltration Systems). On-site runoff will be conveyed into catch basins, then to the underground detention system, and then into the proprietary biofiltration treatment system before discharging into San Juan Creek channel. Flogard Catch Basin Insert Filter with absorbent pouches (for inlet type) or Flogard Trash and Debris Guard (for curb opening type) with absorbent pouches would be installed on the on-site catch basins to prevent trash and debris from entering the storm drain system and being conveyed to the LID BMP systems. Please refer to the Preliminary Water Quality Management Plan included in Appendix H of the EIR for additional details of the proposed Site Design BMPs, Non-Structural Source Control BMPs, Structural Source Control BMPs, and LID BMPs. The proposed BMPs would target and reduce pollutants of concern from runoff from the Project site in compliance with the South Orange County MS4 Permit requirements. Compliance with the requirements of the South Orange County MS4 Permit, including incorporation of operational BMPs to target pollutants of concern, would ensure that impacts related to waste discharge requirements, water quality standards, and degradation of water quality during project operation would be less than significant. Infiltration of stormwater could have the potential to affect groundwater quality in areas of shallow groundwater. However, any infiltration would be minimal due to the low infiltration potential of the majority of on-site soils. Due to the depth to groundwater, it is not expected that any stormwater that may infiltrate during operation would affect groundwater quality because there is no direct path for pollutants to reach groundwater. In addition, the proposed Project would be required to implement LID BMPs to treat stormwater before it could reach groundwater. Therefore, project operation would not substantially degrade groundwater quality. In conclusion, construction of the proposed Project would comply with existing NPDES regulations (as specified in Regulatory Compliance Measure WQ-4), which includes preparation of a Final WQMP and implementation of operational BMPs to target and reduce pollutants of concern in stormwater runoff from the Project 48 6/2/2020 site. Compliance with regulatory requirements would ensure that impacts related to violation of any water quality standards or waste discharge requirements, and degradation of surface water or groundwater quality during project operation would be less than significant, and no mitigation is required. (Draft EIR, pp. 4.9-15 through 4.9-19.) Regulatory Compliance Measures RCM WQ-2 Erosion and Sediment Control Plans. In compliance with the requirements of Sections 8-2.15, 8-2.16, and 8-14.107 of the San Juan Capistrano Municipal Code, the project Applicant shall submit a pollution control plan, construction BMP plan, and/or erosion and sediment control plan to the City of San Juan Capistrano Building Official, or designee, for review and approval prior to issuance of a grading permit. The project Applicant shall also install and maintain erosion control devices year round in compliance with the City - approved pollution control plan, construction BMP plan, and/or erosion and sediment control plan. The project Applicant shall ensure that the construction BMPs are inspected and maintained prior to, during, and after rain events. RCM WQ-3 Groundwater Dewatering Permits. Prior to initiation of excavation activities, the project Applicant shall obtain coverage under San Diego RWQCB issued the General Waste Discharge Requirements for Discharges from Groundwater Extraction Discharges to Surface Waters within the San Diego Region (Order No. R9-2015-0013, NPDES No. CAG919003), or any other subsequent permit, and provide evidence of coverage to the City of San Juan Capistrano Building Official, or designee. This shall include submission of a Notice of Intent (N01) for coverage under the permit to the San Diego Regional Water Quality Control Board (RWQCB) at least 60 days prior to the start of excavation activities and anticipated discharge of dewatered groundwater to surface waters. Groundwater dewatering activities shall comply with all applicable provisions in the permit, including water sampling, analysis, treatment (if required), and reporting of dewatering -related discharges. Upon completion of groundwater dewatering activities, a Notice of Termination shall be submitted to the San Diego RWQCB. 2. Groundwater Supplies Threshold: Would the Project substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the 49 6/2/2020 Project may impede sustainable groundwater management of the basin? Finding: Less than significant impact. (Appendix A [Initial Study], pp. 4-34 through 4-35.) Explanation: According to the Geotechnical Investigation prepared for the project, groundwater was encountered in all exploratory borings drilled to a depth of 18 to 22 ft bgs. Construction. Because excavation is anticipated to reach a maximum depth of approximately 20 feet bgs, there is a potential for groundwater to be encountered during construction and for groundwater dewatering to be required. However, groundwater dewatering would be temporary, and the volume of groundwater removed would not be substantial. The project would also comply with the requirements of Groundwater Discharge Permit, including testing and treatment (if necessary) of dewatered groundwater prior to discharge to surface waters. Furthermore, neither groundwater extraction nor injection would occur during project construction. Therefore, impacts would be less than significant, and no mitigation would be required. Operation. Currently, the Project site is undeveloped and consists of primarily pervious surfaces. Due to the undeveloped nature of the site, development of the project would increase impervious surface area on the Project site compared to existing conditions. The increase in impervious surface area as a result of project implementation would decrease on-site infiltration. However, any decrease in infiltration would be minimal in comparison to the size of the San Juan Groundwater Basin, which has a capacity of 41,375 acre-feet (af) of water per year. In addition, the project would include BMPs to increase infiltration of stormwater runoff on the Project site to reduce impacts related to depletion or interference with groundwater recharge. For these reasons, impacts related to depletion of groundwater supplies or interference with groundwater recharge would be less than significant, and no mitigation would be required. (Appendix A [Initial Study], pp. 4.-34 through 4-35.) 3. Erosion or Siltation Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site? 50 6/2/2020 Finding: Less than significant impact. (Draft EIR, , p. 4.9-20.) Explanation: Construction. During project construction activities, soil would be exposed and disturbed, drainage patterns would be temporarily altered during grading and other construction activities, and there would be an increased potential for soil erosion and siltation compared to existing conditions. Additionally, during a storm event, soil erosion and siltation could occur at an accelerated rate. Project construction would not disturb San Juan Creek because the proposed Project does not include physical improvements to the creek. The Construction General Permit requires preparation of a SWPPP (Regulatory Compliance Measure WQ-1) and the City of San Juan Capistrano Municipal Code requires preparation of pollution control plan, construction BMP plan, and/or erosion and sediment control plan (Regulatory Compliance Measure WQ-2). The SWPPP and pollution control plan, construction BMP plan, and/or erosion and sediment control plan would detail Erosion Control and Sediment Control BMPs to be implemented during project construction to minimize erosion and retain sediment on site. With compliance with the requirements of the Construction General Permit and the City's Municipal Code, and with implementation of the construction BMPs, construction impacts related to on- or off-site erosion or siltation would be less than significant, and no mitigation is required. Operation. In the proposed condition, 10.81 acres (66.08 percent) of the Project site would be impervious surface area and not prone to on-site erosion or siltation because no exposed soil would be included in these areas. The remaining 5.55 acres (33.92 percent) of the site would consist of pervious surface area, which would contain landscaping that would minimize on-site erosion and siltation by stabilizing the soil. Therefore, on-site erosion and siltation impacts would be minimal. However, the proposed Project would increase impervious area on the Project site by 10.73 acres, which would result in a net increase in stormwater runoff that can lead to downstream erosion in receiving waters (San Juan Creek). However, because San Juan Creek is an engineered concrete channel, it is not susceptible to hydromodification.11 According to the South Orange County Hydromodification Management Plan (HMP), major storm drains, concrete lined conveyance channels, and engineered channels (including San Juan Creek) are exempt "Hydromodification is the alteration of the hydrologic characteristics of water bodies. Increased stream flows and changes in sediment transport caused by increased impervious areas from urbanization or other land use changes can result in increased stream flows, erosion, and changes in sediment transport. 51 6/2/2020 from hydromodification requirements of the South Orange County MS4 Permit. Therefore, any increase in stormwater runoff from the Project site to San Juan Creek would not have a potential to result in downstream erosion or siltation. For these reasons, operation impacts related to substantial on- or off-site erosion or siltation would be less than significant, and no mitigation is required. (Draft EIR, pp. 4.9-19 through 4.9-20.) 4. Flooding Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? Finding: Less than significant impact. (Draft EIR, p. 4.9-210.) Explanation: Construction. Project construction would comply with the requirements of the Construction General Permit and would include the preparation and implementation of a SWPPP. The SWPPP would include construction BMPs to control and direct on-site surface runoff and would include detention facilities, if required, to ensure that stormwater runoff from the construction site does not exceed the capacity of the stormwater drainage systems. With implementation of BMPs, construction impacts related to a substantial increase in the rate or amount of surface runoff that would result in flooding would be less than significant, and no mitigation is required. Operation. In the existing condition, on-site drainage is conveyed to two outfalls that discharge to San Juan Creek. Outfall #1 is located approximately 350 ft north of the Stonehill Drive center line and collects on-site stormwater runoff from 12.7 acres of the Project site as well as run-on from the LOSSAN rail corridor and the adjacent hillside. On-site runoff sheet flows to graded swales that convey stormwater to the Outfall #1 outlet structure that discharges directly to San Juan Creek through a 48 -inch diameter pipe. Outfall #2 is located approximately 975 ft north of the Stonehill Drive center line and collects stormwater runoff from 7.52 acres of the Project site. On-site stormwater sheet flows to graded swales that convey water to the Outfall #2 outlet structure that discharges directly to San Juan Creek through two 48 -inch diameter pipes. The proposed Project would not alter on-site drainage patterns and stormwater would continue to be conveyed to the two outfalls (via the proposed on-site stormdrain systems) and then into San Juan Creek. However, the proposed Project would increase impervious 52 6/2/2020 area on the Project site by 10.73 acres, which would increase stormwater runoff from the Project site. The proposed on-site storm drain facilitates would be appropriately sized to convey stormwater runoff so that on-site flooding would not occur. As demonstrated in the Preliminary Hydrology and Hydraulics Analysis prepared for the proposed Project, the proposed Project would decrease stormwater runoff to Outfall #1 by 15.03 cubic feet per second (cfs), a 66 percent decrease compared to existing conditions. The proposed Project would increase discharge to Outfall #2 by 24.9 cfs, a 228 percent increase compared to existing conditions. The overall discharge from the Project site would increase by 9.87 cfs, a 29 percent increase compared to existing conditions. It should be noted that this is a conservative analysis and does not account for the reduction in stormwater runoff that would be achieved by the proposed underground detention systems. As demonstrated in the Preliminary Hydrology and Hydraulics Analysis, the existing outfalls have sufficient capacity to accommodate the increased stormwater discharge from the Project site. The proposed discharge to Outfall #1 and Outfall #2 represents 3 percent and 8 percent, respectively, of the overall outfall capacity. Because of the close proximity of the Project site to San Juan Creek and the lag time of discharge stormwater runoff from the entire watershed to San Juan Creek, runoff from the Project site would discharge to the outfalls well before the remainder of stormwater runoff from the watershed would discharge to San Juan Creek. As such, the increased runoff from the Project site would not exceed the capacity in San Juan Creek. For these reasons, the proposed Project would not result in downstream flooding. Flow from the Project site to the outfalls is regulated by flap gates. In both the existing and proposed condition, in the unlikely event that the flap gates are closed during a storm event due to high flows within San Juan Creek, stormwater would pond on the Project site before overflowing the east property line, flowing along the west limit of the LOSSAN rail corridor, and flowing southerly to discharge to the Pacific Ocean at Doheny State Beach through an existing drainage culvert. The on-site ponding combined with the storage capacity of the underground detention storage would limit the increase in discharge volume from the proposed Project to the railroad during this unlikely catastrophic flood event. According to the Hydrology and Hydraulics Analysis prepared for the project, taking into account the combined storage volume, the proposed Project would increase the 100 -year storm overflow runoff volume by less than 4 percent in the event that a catastrophic flood event occurs. However, due to the lag time between the watershed peak flow and the Project site peak flow reaching San Juan Creek, this condition is not expected to occur during the project lifespan and 53 6/2/2020 represents a conservative, worst-case scenario to ensure a conservative project design for structure protection. In addition, the railroad tracks are currently inundated and inoperable during a 100 - year storm event in the existing condition. During the low likelihood condition that the Project site were to overflow to the railroad in the proposed condition, the 4 percent increase in overflow to the railroad would not further impede the operations of the railroad beyond the flooding experienced in the existing condition. As specified in Regulatory Compliance Measure WQ-5, a Final Hydrology and Hydraulic Analysis would be required to be prepared and submitted to the City for approval. The Final Hydrology and Hydraulic Analysis would be required to confirm that the final design of the project meets the City and County requirements, that peak flow of stormwater runoff in the proposed condition would not exceed the outfall capacity, the on-site stormdrain and detention facilities are appropriately sized to accommodate stormwater runoff from the design storm, and the project would not substantially increase off-site flooding. As demonstrated in the Preliminary Hydrology and Hydraulic Analysis prepared for the proposed Project and to be subsequently confirmed in the Final Hydrology and Hydraulic Analysis, impacts related to an increase in the rate or amount of surface runoff in a manner that would result in on- or off- site flooding would be less than significant, and no mitigation is required. (Draft EIR, pp. 4.9-20 through 4.9-21.) Regulatory Compliance Measures RCM WQ-5 Final Hydrology and Hydraulics Analysis. Prior to issuance of building permits, the project Applicant shall submit Final Hydrology and Hydraulics Analysis to the City of San Juan Capistrano Building Official, or designee, for review and approval. The Final Hydrology and Hydraulics Analysis shall be prepared consistent with the requirements of the Orange County Hydrology Manual (Orange County Public Works [OCPW] 1986) and the Orange County Hydrology Manual Addendum No. 1 (OCPW 1996), or subsequent guidance manuals. The Final Hydrology and Hydraulics Analysis shall confirm that the on-site storm drains, on-site detention systems, and any other drainage structures are appropriately sized to accommodate stormwater runoff from the design storm so that the capacity of downstream storm drain facilities is not exceeded. The City of San Juan Capistrano Building Official, or designee, shall ensure that the drainage facilities specified in the Final Hydrology and Hydraulics Analysis are incorporated into the final project design. 54 6/2/2020 5. Runoff Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantially additional sources of polluted runoff? Finding: Less than significant impact. (Draft EIR, pp. 4.9-22 through 4.9-23.) Explanation: Construction. Construction of the proposed Project has the potential to introduce pollutants to the storm drain system from erosion, siltation, and accidental spills. However, as specified in Regulatory Compliance Measures WQ-1 and WQ-2, the Construction General Permit requires preparation of a SWPPP, and the City of San Juan Capistrano Municipal Code requires preparation of pollution control plan, construction BMP plan, and/or erosion and sediment control plan. Both the SWPPP and the pollution control plan, construction BMP plan, and/or erosion and sediment control plan would identify construction BMPs to be implemented during construction to reduce impacts to water quality, including those impacts associated with soil erosion, siltation, and spills. In addition, any groundwater extracted during groundwater dewatering activities that is discharged to surface waters would be tested and treated (if necessary) to ensure that any discharges meet the water quality limits specified in the applicable NPDES permit (as specified in Regulatory Compliance Measure WQ-3). Regulatory Compliance Measures WQ-1, WQ-2, and WQ-3 are existing NPDES requirements with which the project is required to comply. These measures would prevent substantial additional sources of polluted runoff being discharged to the storm drain system through implementation of construction BMPs that target pollutants of concern in runoff from the Project site as well as testing and treatment (if required) of groundwater prior to its discharge to surface waters. Additionally, the SWPPP would include construction BMPs to control and direct surface runoff on site and would include detention measures if required to ensure that stormwater runoff from the construction site does not exceed the capacity of the stormwater drainage systems. For these reasons, construction impacts related to creation or contribution of runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff would be less than significant, and no mitigation is required. 55 6/2/2020 Operation. Operation of the project has the potential to introduce pollutants to the storm drain system from the proposed on-site uses. However, as specified in Regulatory Compliance Measure WQ-4, permanent operational BMPs that target and reduce pollutants of concern in stormwater runoff would be implemented and maintained throughout the life of the project. Regulatory Compliance Measure WQ-4 is an existing NPDES requirement with which the project is required to comply. This measure would prevent substantial additional sources of polluted runoff being discharged to the storm drain system through implementation of operational BMPs to target pollutants of concern in runoff from the Project site. Additionally, the proposed underground detention facilities would reduce stormwater runoff from the Project site. Even without the proposed underground detention facilities, the two outfalls that convey runoff from the Project site to San Juan Creek have sufficient capacity to accommodate any increase in stormwater from the Project site. In addition, the increase in stormwater runoff from the Project site would not reduce the capacity of San Juan Creek because of the Project site's close proximity to the creek. Peak flow from the Project site would discharge to San Juan Creek prior to the peak flow from the remainder of the watershed reaching San Juan Creek, resulting in a substantial lag time between the watershed peak flow and the Project site peak flow. As specified in Regulatory Compliance Measure WQ-5, a Final Hydrology and Hydraulic Analysis would be required to be prepared and submitted to the City for approval to confirm that, based on final project design, the peak flow of stormwater runoff in the proposed condition would not exceed the outfall capacity. For these reasons, operational impacts related to creation or contribution of runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff would be less than significant, and no mitigation is required. (Draft EIR, pp. 4.9-22 through 4.9-23.) 6. Flood Flows Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would impede or redirect flood flows? Finding: Less than significant impact. (Draft EIR, pp. 4.9-22 through 4.9-23.) Explanation: The majority of the Project site is located within 100 -year floodplain Zone AO. Zone AO is defined by FEMA as areas subject to inundation by 1 -percent -annual -chance (100 -year) flood with 56 6/2/2020 shallow flooding (1 ft depth for the Project site). A portion of the Project site (along the western boundary) is located within Zone A, which is classified as an area subject to inundation by the 1 - percent -annual -chance flood event. In the existing condition, the outfall structures that convey stormwater runoff from the Project site to San Juan Creek are designed with flap gates. When San Juan Creek is experiencing high flows, the flap gates close to prevent water from the creek from back flowing into the Project site. The flap gates remain closed for short periods of time until there is sufficient pressure from water accumulated on site to open the flap gates and allow flow from the Project site to the creek to resume. Because of the lag time between stormwater peak flow from the Project site reaching San Juan Creek and stormwater peak flow from the remainder of the watershed reaching San Juan Creek, stormwater from the Project site would be expected to discharge to San Juan Creek before water levels in San Juan Creek are high enough to close the flap gates. In the unlikely event that the flap gates are closed during a storm event, stormwater ponds on the Project site, overflows the east property line, is conveyed along the west limit of the LOSSAN rail corridor, and flows southerly to discharge to the Pacific Ocean at Doheny State Beach through an existing drainage culvert. In the existing conditions, the railroad tracks are inundated and inoperable during a 100 -year storm event. The proposed Project would be designed in compliance with the design requirements of the Section 8-11.115 of the City Municipal Code, which specifies design requirements for developments within the 100 -year floodplain. The proposed Project would be designed to not impede or redirect flood flows. In the event of a 100 -year flood event, stormflows would be conveyed similar to existing conditions. In the unlikely event that the flap gates are closed during a storm event, stormwater would pond on the Project site and would rise to 1 ft below the finish floor elevation before overflowing to the east property line, being conveyed along the west limit of the LOSSAN rail corridor, and flowing southerly to discharge to the Pacific Ocean at Doheny State Beach through an existing drainage culvert. The on-site ponding combined with the storage capacity of the underground detention storage would limit the increase in discharge volume during this unlikely catastrophic flood event. According to the Hydrology and Hydraulics Analysis prepared for the project, taking into account the combined storage volume, the proposed Project would increase the 100 -year storm overflow runoff volume by less than 4 percent in the event that a catastrophic flood event occurs. However, due to the lag time between the watershed peak flow and the Project site peak flow 57 6/2/2020 reaching San Juan Creek, this condition is not expected to occur during the project lifespan and represents a conservative, worst- case scenario to ensure a conservative project design for structure protection. In addition, the railroad tracks are inundated and inoperable during a 100 -year storm event in the existing condition. During the low likelihood condition that the Project site were to overflow to the railroad in the proposed condition, the 4 percent increase in overflow to the railroad would not further impede the operations of the railroad beyond the flooding experienced in the existing conditions. The proposed Project would also be required to obtain an Elevation Certificate, as outlined in Regulatory Compliance Measure WQ-6. The Elevation Certificate is part of the National Flood Insurance Program (NFIP) and is used to provide elevation information necessary to ensure compliance with community floodplain management ordinances, to determine the proper insurance premium rate, and may serve as documentation supporting a Conditional Letter of Map Revision based on fill (CLOMR-F) and Letter of Map Revision based on fill (LOMR-F). As specified in Regulatory Compliance Measure WQ-7, the project would be required to process a CLOMR-F during final design and a LOMR-F upon project completion through the City, the Orange County Flood Control District (OCFCD), and FEMA. A CLOMR is FEMA's comment on a proposed Project that would, upon construction, affect the hydrologic or hydraulic characteristics of a floodplain and thus result in the modification of the existing floodplain or floodway or the base flood elevation. A CLOMR does not revise an effective FIRM; instead, it indicates whether the project, if built as proposed, would be recognized by FEMA. An LOMR is FEMA's modification to an effective FIRM. The CLOMR-F and LOMR-F process is applicable to properties elevated out of a floodplain through the placement of fill. The CLOMR-F and LOMR- F would ensure that the FEMA FIRM reflects the changes to the floodplain that would result from project implementation. With implementation of Regulatory Compliance Measures WQ-6 and WQ-7, potential impacts related to impeding or redirecting flood flows would be less than significant and no mitigation is required. (Final EIR, pp. 4.9-23 through 4.9-24.) Regulatory Compliance Measures RCM WQ-6 Flood Hazard Certification. Prior to issuance of any Certificates of Occupancy, the project Applicant shall obtain certification from a registered professional engineer or surveyor that the constructed 58 6/2/2020 structures on the project site comply with the requirements of Section 8-11.115 and Section 8-11.117 of the City's Municipal Code. The certification shall be a Federal Emergency Management Agency (FEMA) Elevation Certificate and shall verify that the elevation of the first floor of the completed building is located above the 100 -year floodplain and complies with the elevation requirements in Section 8-11.115 of the City's Municipal Code. In addition, the certification shall verify that the on-site structure would not impede or increase the 100 -year flood elevations. Additionally, the registered engineer or surveyor shall certify the final pad elevation, lowest floor elevation, and lowest adjacent grade in compliance with Section 8-11.117 of the City's Municipal Code. The certification shall be submitted to and verified by the City Floodplain Administrator. RCM WQ-7 Letter of Map Revision. Flood Insurance Rate Map Revisions. Prior to the issuance of any grading or construction permits, the project Applicant shall process a Conditional Letter of Map Revision (CLOMR-F) through the City of San Juan Capistrano, Orange County Flood Control District (OCFCD), and the Federal Emergency Management Agency (FEMA). Project construction shall not commence until the CLOMR-F is approved by FEMA. Upon completion of construction, the project Applicant shall process a Letter of Map Revision (LOMR-F) through the City of San Juan Capistrano, OCFCD, and FEMA. The City of San Juan Capistrano shall not issue the first Certificate of Occupancy until the LOMR-F is approved by FEMA. 7. Flood Hazard Threshold: In flood hazard, tsunami, or seiche zones, would the Project risk release of pollutants due to project inundation? Finding: Less than significant impact. (Appendix A [Initial Study], pp. 4-36 through Explanation: Tsunami. Tsunamis are generated ocean wave trains generally caused by tectonic displacement of the sea floor associated with shallow earthquakes, sea floor landslides, rock falls, and exploding volcanic islands. According to the Department of Conservation (DOC) Tsunami Inundation Map for Emergency Planning, Dana Point Quadrangle/San Juan Capistrano Quadrangle, the Project site is not located within a tsunami inundation area. Therefore, impacts related to tsunamis would be less than significant, and no mitigation is required. 59 6/2/2020 Seiche Zones. Seiching occurs when seismic ground shaking induces standing waves (seiches) inside water retention facilities (e.g., reservoirs and lakes). Because there are no large lakes or reservoirs in the vicinity of the Project site, the Project site is not at risk of inundation from seiche. Therefore, impacts related to seiching would be less than significant, and no mitigation is required. Flood Hazard. The majority of the Project site is located in Zone AO, which is defined by FEMA as areas subject to inundation by 1 - percent annual chance (100 -year) flood with shallow flooding (1 foot depth for the Project site). A small portion of the Project site is located in Zone A, which is classified as an area subject to inundation by the 1- percent -annual -chance flood event. In addition, according to the City's General Plan Safety Element, the Project site is located within the inundation area based on catastrophic failure of Trampas Canyon Dam. Therefore, in the event of flooding during a storm event or in the unlikely event of failure of Trampas Canyon Dam, there would be risk of inundation and pollutant release on the Project site. The project would introduce a new land uses (commercial, restaurant, and storage yard) on the Project site, which would change the potential on-site pollutants compared to existing conditions. However, BMPs would be implemented to target and reduce pollutants of concern on the Project site. In addition, hazardous substances associated with commercial and restaurant uses would be limited in both amount and use. The materials used on-site would be contained, stored, and used in accordance with manufacturers' instructions and handled in compliance with applicable standards and regulations. Because BMPs would reduce introduction of pollutants on the site and any hazardous materials used on site would be properly stored and contained, impacts related to release of pollutants in the event of inundation from flooding would be less than significant. No mitigation is required. (Appendix A [Initial Study], pp. 4-36 through 4-37.) 8. Water Quality Control Plan Threshold: Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Finding: Less than significant impact. (Appendix A [Initial Study], pp. 4-37 through 4-38.) Explanation: The project is within the jurisdiction of the San Diego Regional Water Quality Control Board. The San Diego RWQCB adopted a 60 6/2/2020 Water Quality Control Plan (i.e. Basin Plan) (September 1994, with amendments effective on or before May 2016) which designates beneficial uses for all surface and groundwater within their jurisdiction and establishes the water quality objectives and standards necessary to protect those beneficial uses. As summarized below, the project would comply with the applicable NPDES permits and implement construction and operational BMPs to reduce pollutants of concern in stormwater runoff. Construction. During construction activities, excavated soil would be exposed, and there would be an increased potential for soil erosion and sedimentation compared to existing conditions. In addition, chemicals, liquid products, petroleum products (e.g., paints, solvents, and fuels), and concrete -related waste may be spilled or leaked and have the potential to be transported via stormwater runoff into receiving waters. However, the proposed Project would be required to comply with requirements set forth by the Construction General Permit, which requires preparation of an SWPPP and Erosion Control Plan and implementation of construction BMPs to control stormwater runoff and discharge of pollutants. The project would also comply with the requirements of Groundwater Discharge Permit, including testing and treatment (if necessary) of dewatered groundwater prior to discharge to surface waters. Operation. The primary pollutants of concern during project operations are suspended solids, bacteria/virus/pathogens, and dry weather runoff. Other pollutants of concern are nutrients, heavy metals, pesticides, toxic organic compounds, and trash and debris. A Final WQMP would be prepared for the Project in compliance with the South Orange County MS4 Permit and City Municipal Code. The Final WQMP will detail the Source Control, Site Design, and LID BMPs that would be implemented to treat stormwater runoff and reduce impacts to water quality during operation. The proposed LID BMPs include proprietary biofiltration BMPs. These BMPs would capture and treat stormwater runoff and reduce pollutants of concern in stormwater runoff. The Project would comply with the applicable NPDES permits, which requires preparation of a Final WQMP and implementation of construction and operational BMPs to reduce pollutants of concern in stormwater runoff so that the project would not degrade water quality, cause the receiving waters to exceed the water quality objectives, or impair the beneficial use of receiving waters. As such, the project would not result in water quality impacts that would conflict with the RWQCB's Water Quality Control Plan (Basin Plan). 61 6/2/2020 Impacts related to conflict with a water quality control plan would be less than significant and no mitigation is required. The Sustainable Groundwater Management Act (SGMA) was enacted in September 2014. SGMA requires governments and water agencies of high and medium priority basins to halt overdraft of groundwater basins. SGMA requires the formation of local groundwater sustainability agencies (GSAs), who are required to adopt Groundwater Sustainability Plans to manage the sustainability of the groundwater basins. The Project site is located within the San Juan Valley Groundwater Basin which is managed by the San Juan Basin Authority, which is comprised of the City of San Juan Capistrano, the Moulton Niguel Water District, the Santa Margarita Water District, and the South Coast Water District. The San Juan Valley Groundwater Basin is identified by the Department of Water Resources as a low priority basin; therefore, development of a Groundwater Sustainability Plan is not required. Because there is not an adopted Groundwater Sustainability Plan applicable to the groundwater basin within the Project area, the project would not conflict with or obstruct the implementation of a sustainable groundwater management plan. Therefore, no impact would occur related to conflict or obstruction of water quality control plans or sustainable groundwater management plans and no mitigation is required. (Appendix A [Initial Study], pp. 4-37 through 4-38.) K. LAND USE AND PLANNING 1. Established Communities Threshold: Would the Project physically divide an established community? Finding: ding: Less than significant impact. (Appendix A [Initial Study], p. 4-40.) Explanation: The Project site consists of a vacant, undeveloped site that is comprised of Assessor's Parcel Numbers (APNs) 121-253-13, and 15; and 121-240-39, 73 and 76. The Project site is located within a largely developed portion of the City of San Juan Capistrano. Surrounding land uses include a mobile home park to the north; the San Juan Creek Channel and Trail, Creekside Park, and single- family residential uses to the west; the BNSF rail line and automobile dealerships to the east; and a hotel, a mobile home park, and commercial uses south of Stonehill Drive. The proposed Project would allow for the development of a lumber yard and hardware store, drive-through restaurant uses, and a crushed -rock gravel area for long-term vehicle storage. Vehicular access would be provided via Stonehill Drive. 62 6/2/2020 Vehicular access to the Project site would be provided via a proposed signalized intersection at Stonehill Drive and the southwestern corner of the Project site. Two separate truck traffic routes would be provided on the Project site along the western and eastern perimeters and would allow access to the lumber yard and an employee parking lot. A fire access lane would also provide access throughout the Project site. Pedestrian and bicycle access to the Project site would be provided by sidewalks and a bicycle route on Stonehill Drive, respectively. Pedestrian circulation within the Project site would be provided with sidewalks, which would travel from the Project driveway to the parking areas adjacent to Building 1. A sidewalk would also be provided along the western truck route leading to the rear parking lot. As part of the Project, a two-lane easement travelling north/south from the northwestern corner of the Project site to Avenida Aeropuerto is proposed; the easement would be located immediately west of the mobile home park adjacent to the Project site and would be approximately 1,270 ft in length. The purpose of the northern easement is to provide emergency ingress/egress to and from the Project site to the north. A second two-lane easement travelling north/south is proposed at the southeastern corner of the Project site; this easement would travel under the Stonehill Drive Bridge and connect the Project site to neighboring parcels to the south. Although implementation of the proposed Project would change the existing parcel configuration within the site, it would not change the existing parcel configuration of adjacent parcels. The proposed site configuration (including truck routes, fire access lanes, easements, and sidewalks) would provide new internal routes traversing the Project site and allow access where none currently exists; however, the proposed development would not divide or separate any existing land uses or neighborhoods. In addition, access for properties adjacent to the Project site would be improved due to incorporation of the easements as part of the Project. Therefore, construction and implementation of the Project would not result in the physical division of an established community, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-39 through 4-40.) 2. Conflicts With Plans Threshold: Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? 63 6/2/2020 Finding: Less than significant impact. (Draft EIR, p. 4.10-25.) Explanation: Several regionally and locally adopted land use plans, policies, and regulations would be applicable to development under the proposed Project, including the SCAG 2008 Regional Comprehensive Plan, the SCAG 2016-2040 RTP/SCS, the City of San Juan Capistrano General Plan, and the City of San Juan Capistrano Zoning Code. Southern California Association of Governments Regional Comprehensive Plan. The 2008 Regional Comprehensive Plan (RCP) addresses regional goals related to growth and infrastructure in the Southern California region. The RCP also addresses issues such as housing, traffic, air quality, and water resources as a guide for local agencies to use in preparing plans that deal with regional issues. The RCP outlines a vision of how the Southern California region can balance growth with conservation in order to achieve a higher quality of life. In order to achieve this balance, the RCP aims to establishes the following land use goals: (1) focus growth in existing centers and along major transportation corridors, (2) encourage mixed-use development, (3) provide new housing opportunities, (4) encourage development near existing and planned transportation stations to reduce traffic congestion and associated air pollutants, (5) preserve existing single-family neighborhoods, and (6) protect open space and environmentally sensitive habitat areas from development. The proposed Project does not include new housing nor does the existing Project site contain protected open space or environmentally sensitive habitat areas. Therefore, Goals (3) and (6) are not applicable to the proposed Project and are not discussed further in the following RCP consistency analysis below. The Project site is located immediately north of Stonehill Drive, which is a Primary Arterial consisting of four lanes. The proposed Project would develop the currently undeveloped and underutilized Project site with a Ganahl Lumber hardware store and lumber yard, a vehicle storage lot, and the potential development of two fast-food restaurants at a future date. Together, the development of these uses comprises a mixed-use development. Uses proposed as part of the Project would be easily accessed from Stonehill Drive and other major transportation corridors near the site (e.g., 1-5 and Camino Capistrano). In addition, the proposed Project would be located immediately north of Class 2 bike lanes on Stonehill Drive, 0.34 mile west of the nearest bus station (e.g., Orange County Transportation Authority Route 91 station off Del Obispo), and 1.74 miles south of the San Juan Capistrano Train Station. Employees of the Ganahl Lumber hardware store and lumber yard, future 64 6/2/2020 restaurants and storage lot may utilize alternative transportation to access the site; however, the majority of the patrons of the Project are not anticipated to use alternative transportation to access the site due to proposed use of the site as a lumber yard servicing the construction trade, along with the two drive-through restaurants which will likely serve patrons in automobiles. However, overall the Project would be consistent with RCP Goal 1 to focus growth along major transportation corridors, Goal 2 to encourage mixed-use development, and Goal 4 to encourage new development near existing transportation stations. Development of the proposed Project would be consistent with existing commercial uses surrounding the Project site, and would serve nearby residents west, south, and north of the site in existing single-family neighborhoods. The proposed Project would improve the currently vacant and underutilized site with landscaping and development of uses that would serve surrounding residents; it would not interfere or conflict with the existing land use patterns and visual character of established residential neighborhoods near the site. Therefore, the Project would be consistent with RCP Goal 5 of preserving existing single-family neighborhoods. For the reasons stated above, the proposed Project would be consistent with applicable goals and policies in SCAG's 2008 RCP. SCAG RTP/SCS Consistency. The 2016-2040 RTP/SCS also provides a comprehensive outline for transportation investments throughout the SCAG region. The RTP was most recently adopted in 2016 and is updated every four years to address regional transportation needs. In order to receive State and federal funding, transportation projects must be outlined in the RTP. In addition, the 2016-2040 RTP outlines the following primary goals: (1) align the plan investments and policies with improving regional economic development and competitiveness, (2) maximize mobility and accessibility for all people and goods in the region, (3) ensure travel safety and reliability for all people and goods in the region, (4) preserve and ensure a sustainable regional transportation system, (5) maximize the productivity of our transportation system (6) protect the environment and health of our residents by improving air quality and encouraging active transportation (e.g., bicycling and walking) (7) actively encourage and create incentives for energy efficiency, where possible, (8) encourage land use and growth patterns that facilitate transit and active transportation, and (9) maximize the security of the regional transportation system through improved system monitoring, rapid recovery planning, and coordination with other security agencies. Goal 9 of the 2016-2040 RTP/SCS relates to planning/policy actions to be taken by regional 65 6/2/2020 and local agencies; therefore, the Project's consistency with Goal 9 is not discussed further in the 2016-2040 RTP/SCS consistency analysis provided below. The proposed Project would result in the conversion of the currently vacant and underutilized Project site to a commercial property with a Ganahl Lumber lumber yard and hardware store, fast-food restaurants, and a vehicle storage lot. The Project site is located directly north of Stonehill Drive, which is a Primary Arterial that runs in an east -west fashion through the Cities of Dana Point and San Juan Capistrano. The project would provide access to the site off Stonehill Drive, which would serve to connect the site with the local and regional transportation systems. As such, development of the proposed Project would help maximize the productivity of the existing roadway network in the vicinity of the site and would improve accessibility to the site and areas adjacent to the site (Goals 2 and 5), including Stonehill Drive to the south and 1-5 to the east. Moreover, all access improvements included as part of the proposed Project would comply with City and OCFA standards to ensure the safety and reliability of transportation improvements included as part of the Project (Goal 3). Development of the currently underutilized Project site would also provide additional employment opportunities that would promote economic development and competiveness in the area (Goal 1). The proposed Project would promote energy efficiency through compliance with the California Green Building Standards Code (CALGreen Code). Sustainability features proposed as part of the Project would include the use of sun shading and natural day - lighting to diminish heat gain and decrease the need for artificial lighting during daylight hours and the installation of energy efficient lighting technologies. As such, the Project would be consistent with Goal 7 in the 2016-2040 RTP/SCS. The majority of patrons of the proposed on-site uses are not anticipated to use alternative modes of transportation to access the Project site due to the proposed operation of a lumber yard and drive-through restaurants on the site. However, employees traveling to and from the Project site may use alternative transportation to access the site given the proximity of Class 2 bike lanes along Stonehill Drive south of the site and the OCTA Route 91 bus stop approximately 0.34 mile west of the site on Del Obispo Street. Therefore, the proposed Project would be consistent with Goals 6 and 8 in the 2016-2040 RTP/SCS. 66 6/2/2020 For the reasons stated above, the proposed Project would be consistent with applicable goals outlined in the 2016-2040 RTP/SCS. City of San Juan Capistrano General Plan. The existing General Plan land use designation for the majority of the Project site is Quasi -Industrial. According to the City's Land Use Element, the Quasi -Industrial designation provides for a variety of light industrial and manufacturing uses, including limited regional commercial activities that are non-polluting and are compatible with surrounding land uses, as well as regional and sub -regional commercial activities. The northernmost portion of the Project site has a land use designation of Industrial Park, which allows light industrial and manufacturing uses. The proposed Project would develop the site with a lumber yard and hardware store, a vehicle storage lot, and the future addition of two fast-food restaurants. The proposed lumber yard is considered a light industrial use, whereas the proposed fast-food restaurants, hardware retail store, and vehicle storage are considered commercial uses. All uses proposed as part of the Project would be consistent with the existing General Plan land use designation of Quasi -Industrial for the site. The existing Industrial Park designation on the northernmost portion of the property falls within an area of the site that is currently identified for a utility easement to provide future private emergency access. No development is proposed on this portion of the site. Therefore, the Project would be consistent with both existing General Plan land use designations for the property; and no General Plan Amendment would be required to implement the proposed Project. The City of San Juan Capistrano General Plan also contains goals and policies that are considered applicable to the proposed Project. These goals are discussed in Table 4.10.A, General Plan Consistency Analysis, (found at Draft EIR, pp. 4.10-16 through 4.10-23) and a consistency analysis is provided for each applicable General Plan goal. Goals that are not applicable to the proposed Project are not included in this table. This discussion is intended to provide a guide to the decision -makers for policy interpretation. As identified through this consistency analysis, the proposed Project would not conflict with any applicable General Plan land use plan, policy, or regulation adopted by the City for the purpose of avoiding or mitigating an environmental impact. City of San Juan Capistrano Municipal Code. The majority of the Project site is zoned Commercial Manufacturing (CM). The 67 6/2/2020 Commercial Manufacturing zone allows industrial and commercial uses, including wholesaling, limited manufacturing, eating establishments, limited retail, and indoor recreational uses. The northernmost portion of the Project site where the utility easement is located is zoned Mobile Home Park Senior Overlay, which allows mobile home uses for seniors 55 years of age and older. No development is proposed on this portion of the site. Therefore, the Project would be consistent with both existing land use classifications for the property; and no Zoning Amendment would be required to implement the proposed Project. Development Standards. Section 9-3.305, Industrial Districts, of the City's Zoning Code includes applicable development standards for the CM zoning classification (i.e., the zoning classification on the portion of the Project site proposed for development). As outlined in this section of the City's Municipal Code, the minimum lot area for the CM zoning classification is 7,200 sf (0.17 acre). Proposed lot sizes included as part of the Project would be 2.06 acres (Area A), 10.61 acres (Area B), and 4.39 acres (Area C). The maximum allowable floor area ratio (FAR) is 0.40 (established in the General Plan). As proposed, Area A would be developed at a FAR of 0. 11, Area B would be developed at a FAR of 0.28, and Area C would be developed at a FAR of 0.01. The minimum allowable street frontage setback is 60 feet (ft). Area A (the portion of the Project site abutting Stonehill Drive) would locate the closest proposed fast-food restaurant 78 ft from the roadway. In addition, proposed ancillary buildings on the site (e.g., sheds) would be setback 5 ft from the eastern and western boundaries of the property line, consistent with the required 5 ft side yard setback. Due to the presence of a proposed landscaped berm and surface parking lot on the northernmost portion of the property, the Project would also comply with the City's required 25 ft rear yard setback. Therefore, the proposed Project would be consistent with applicable development standards outlined in the City's Municipal Code. Parking Standards. The proposed Project would provide parking spaces throughout Areas A, B, and C on the Project site. Area A would allow for the future development of two fast-food restaurants. The City's Municipal Code requires a minimum of 1 parking space per patron for fast-food restaurant uses with a drive- through based on the restaurant's total capacity, plus 1 additional parking space per employee per shift. Tenants for the proposed restaurant uses have not yet been identified, and therefore, proposed hours of operation, number of employees, and other 68 6/2/2020 tenant -specific details are not known at this time. The required number of parking spaces would be determined at the time a tenant is identified. Although the required and proposed number of parking spaces have not yet been determined, the proposed Project would comply with the City's parking requirements. Development on Area B would include several buildings proposing a mix of uses within each building. The City's Municipal Code requires a minimum of 160 parking spaces for the development proposed on Area B. Area B would include 165 parking spaces provided within surface parking lots in Area B. As such, development within Area B would satisfy the City's parking requirements and would provide a surplus of 5 parking spaces on the Project site. The proposed Project does not proposed to develop Area C, but rather intends on using this area for long-term vehicle storage. In total, Area C would provide 399 vehicle storage spaces to be used by local car dealerships. These spaces would not function as parking for visitors to the Project site, and would not be required to meet the Project's parking demands. There would be no potentially significant impacts related to land use and planning. (Draft EIR, pp. 4.10-12 through 4.10-25.) L. MINERAL RESOURCES 1. Regional and Statewide Mineral Resources Threshold: Would the Project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? Finding: No impact. (Appendix A [Initial Study], p. 4-43.) Explanation: In 1975, the California Legislature enacted the Surface Mining and Reclamation Act (SMARA) which provides guidelines for the classification and designation of mineral lands. Areas are classified on the basis of geologic factors without regard to existing land use and land ownership. The areas are categorized into four Mineral Resource Zones (MRZ): MRZ-1: An area where adequate information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence 69 6/2/2020 MRZ-2: An area where adequate information indicates that significant mineral deposits are present, or where it is judged that a high likelihood exists for their presence MRZ-3: An area containing mineral deposits, the significance of which cannot be evaluated MRZ-4: An area where available information is inadequate for assignment to any other MRZ zone Lands classified as MRZ-2 are of the greatest importance. Such areas are underlain by demonstrated mineral resources or are located where geologic data indicate that significant measured or indicated resources are present. MRZ-2 areas are designated by the State Mining and Geology Board as being "regionally significant." Such designations require that a Lead Agency's land use decisions involving designated areas be made in accordance with its mineral resource management policies and that it consider the importance of the mineral resource to the region or the State as a whole, not just to the Lead Agency's jurisdiction. The Project site has been classified by the California Department of Mines and Geology (CDMG) as MRZ-3, indicating that the Project site is in an area where it is judged that little likelihood exists for their presence. 12 The project would not result in the loss of a known commercially valuable mineral resource that would be of value to the region and the residents of the State because no known mineral resources are present on the Project site. Therefore, the proposed Project would not result in impacts related to the loss of availability of a known mineral resource that would be of value to the region and residents of the State, and no mitigation would be required. (Appendix A [Initial Study], p. 4-43.) 2. Locally -Important Mineral Resource Threshold: Would the Project result in the loss of availability of a locally - important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? Finding: No impact. (Appendix A [Initial Study], p. 4-43.) 12 State of California Department of Conservation (DOC). 1994. California Division of Mines and Geology. Generalized Mineral Land Classification or Orange County. Open - File Report 94-15, Plate 1. 70 6/2/2020 Explanation- As discussed previously in Response 4.11 (a), above, no known valuable mineral resources exist on or near the Project site, and no mineral resource extraction activities occur on the site. Additionally, the Project site is not located within an area known to contain locally important mineral resources and is not mapped in the City's General Plan or other land use maps for mineral resources. Therefore, the proposed Project would not result in the loss of availability of a locally important mineral resource recovery site as delineated on a local general plan, specific plan, or other land use plan as a result of project implementation. Appendix A [Initial Study], p. 4-43.) M. NOISE 1. Noise Standards Threshold: Would the Project result in the 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? Finding: Less than significant impact. (Draft EIR, p. 4.11-15.) Explanation: Operational Noise. Pro'ect Land Use Compatibility. The City of San Juan Capistrano General Plan Noise Element includes a land use compatibility table (Table 4.11.E, found at Draft EIR, p. 4.11-9) that provides the City with a tool to gauge the compatibility of new land uses relative to existing noise levels. This table identifies normally acceptable, conditionally acceptable, and clearly unacceptable noise levels for various land uses, including commercial and industrial land uses such as those proposed by the Project. In the case that the noise levels identified at a proposed Project site fall within levels considered normally acceptable, the Project is considered compatible with the existing noise environment. As shown in Table 4.11.E (found at Draft EIR, p. 4.11-9), an acceptable existing noise level for locating both commercial uses such as fast-food restaurants and hardware stores, as well as industrial uses such as a lumber yard, falls under 70 dBA CNEL. In order to quantify existing ambient noise levels in the Project area, short-term noise measurements were conducted as described in Section 4.11.2, 71 6/2/2020 Methodology, and as shown in Table 4.11.A (found at Draft EIR, p. 4.11-5). The noise measurement sites were representative of typical existing noise exposure within and immediately adjacent to the Project site and are considered representative of the noise levels throughout the day. As shown in Table 4.11.A, (found at Draft EIR, p. 4.11-5) the ambient recorded noise levels ranged from 46.1 to 56.8 dBA near the Project site. Additionally, as shown in Table 4.11.13, the existing traffic -generated noise level on project - vicinity roadways currently ranges from 53.6 to 64.1 dBA CNEL. As these ranges all fall below 70 dBA, the Project site is considered an appropriate noise environment to locate proposed commercial and industrial land uses. Long -Term Mobile -Source Noise Impacts. Future traffic noise levels throughout the Project vicinity were modeled based on the traffic volumes identified by the Traffic Impact Assessment (LSA 2019) to determine the noise levels along project vicinity roadways. Table 4.11.H (found at Draft EIR, p. 4.11-13) shows the calculated off-site roadway noise levels under existing traffic levels compared to future buildout of the proposed Project. The calculated noise levels as a result of the Project at affected land uses are compared to the noise standards in the City of Dana Point General Plan Noise Element for the segment of Stonehill Drive west of the Project Driveway and the segments of Del Obispo Street north and south of Stonehill Drive. The City of Dana Point General Plan Noise Element includes a mobile source threshold of 65 dBA CNEL at residential land uses. Calculated noise levels as a result of the proposed Project at affected land uses were compared to the noise standards in the San Juan Capistrano Noise Element (see Table 4.11.C, found at Draft EIR, p. 4.11-7) for the remainder of project vicinity roadway segments. As shown in Table 4.11.C, similar to Dana Point, the City of San Juan Capistrano requires outdoor areas of frequent human use to achieve 65 dBA CNEL. Additionally, project - generated traffic could potentially influence the ambient noise environment in the City of Dana Point to the south, specifically a mobile home park located across Camino Capistrano from the existing Costco store. A threshold of 65 dBA CNEL at residential land uses shall be employed for the purpose of this analysis, consistent with the mobile -source noise thresholds of both the City of San Juan Capistrano and the City of Dana Point. As shown in Table 4.11.1-1 (found at Draft EIR, p. 4.11-13), predicted increases in traffic noise levels associated with the Project would not result in any mobile -source noise level standards being exceeded. Therefore, impacts associated with long-term, mobile -source noise would be less than significant. No mitigation is required. 72 6/2/2020 Long -Term Stationary -Source Noise Impacts. The proposed Project would include several on-site noise sources as show in Table 4.11.1 (found at Draft EIR, p. 4.11-14). The estimated time of use of these stationary sources would differ as shown in the table. The fast-food restaurants proposed on Site A would be expected to operate similar hours as the lumber yard, while the vehicle storage facility proposed for Site C would only operate during daytime hours. Table 4.11.J (found at Draft EIR, p. 4.11-14) shows the predicted on-site noise levels associated with full operation of the proposed Project, during the hours of 7:00 a.m. and 7:00 p.m. compared to the daytime noise standards as described in Section 4.11.3.4. Full operations at the Project site include noise associated with the proposed restaurants on Site A, the Ganahl Lumber retail store and yard operations on Site B, and the vehicle storage facility on Site C. As shown in Table 4.11.1, daytime nose levels in the vicinity of nonresidential uses, are all far below applicable daytime standards. Daytime noise levels at the residential uses in the Project vicinity also fall below applicable daytime standards of the cities in which these receivers are located. Table 4.11.K (found at Draft EIR, p. 4.11-15) shows the predicted noise propagation associated with evening and nighttime operations of the proposed Project between the hours of 7:00 p.m. and 7:00 a.m. Evening and nighttime operations at the Project site precludes operation of the proposed vehicle storage facility on Site C. Additionally, the proposed hardware store would be closed. However, a third shift from 10:00 p.m. to 6:00 a.m. may be added in the future for the purpose of replenishment, cleaning, and order pulling for the next day in the proposed hardware store. As such, parking lot activity surrounding the proposed hardware is maintained at daytime noise levels in order to provide a conservative analysis. As shown in Table 4.11.K, evening and nighttime noise levels at vicinity nonresidential uses would range from 44.6 dBA to 52.3 dBA and noise levels at the Project vicinity residential uses would range from 30.2 dBA to 44.4 dBA. These noise levels all fall below applicable evening and nighttime noise standards for the Cities of San Juan Capistrano and Dana Point as shown in the table. Therefore, impacts related to operational noise from stationary sources would be less than significant. No mitigation is required. (Final EIR, pp. 4.11-12 through 4.11-15.) 73 6/2/2020 2. Vibration Threshold: Would the Project result in the exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? Find n : Less than significant impact. (Draft EIR, p. 4.11-16.) Explanation: Excessive ground -borne vibration impacts result from continuously occurring vibration levels. Once operational, the proposed Project would not be a source of groundborne vibration. Increases in ground -borne vibration levels attributable to the proposed Project would be primarily associated with short-term construction -related activities. Construction on the Project site would have the potential to result in varying degrees of temporary ground -borne vibration, depending on the specific construction equipment used and the operations involved. Ground vibration generated by construction equipment spreads through the ground and diminishes in magnitude with increases in distance. Construction -related ground vibration is normally associated with impact equipment such as pile drivers, jackhammers, and the operation of some heavy-duty construction equipment such as dozers and trucks. Vibration decreases rapidly with distance and it is acknowledged that construction activities would occur throughout the Project site and would not be concentrated at the point closest to sensitive receptors. Ground -borne vibration levels would be considered significant if predicted short-term construction ground -borne vibration levels attributable to the proposed Project would exceed 0.2 inch/sec PPV at the nearest off-site existing non-mobile structure, and 0.1 inch/sec PPV at the nearest off-site mobile home. Based on the vibration levels presented in Caltrans' Transportation and Construction Vibration Guidance Manual (2013), ground vibration generated by heavy-duty equipment would not be anticipated to exceed approximately 0.073 inch/sec PPV at 50 feet. Therefore, the use of construction equipment would not result in a ground - borne vibration velocity level above 0.1 inch/sec at the nearest off- site structures, including at any mobile homes. Therefore, impacts would be less than significant. No mitigation would be required. (Draft EIR, p. 4.11-15.) 3. Airport Noise Threshold: 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 74 6/2/2020 Project expose people residing or working in the Project area to excessive noise levels? Finding: No impact. (Draft EIR, p. 4.11-16.) Explanation: The closest airport to the Project site is John Wayne Airport which is located approximately 17 miles northeast of the Project site. The Project site is not located within two miles of a public airport or within an airport land use plan nor is the Project within the vicinity of a private airstrip. As such, the Project site would not be exposed to excessive noise levels from airport operations and, therefore, there would be no impact. No mitigation would be required. (Draft EIR, p. 4.11-16.) N. POPULATION AND HOUSING 1. Population Growth Threshold: Would the Project 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 road or other infrastructure? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-47.) Explanation: Construction. The Project site encompasses an approximately 17 -acre undeveloped lot. Construction of the proposed Project would include the development of the Ganahl Lumber hardware store and lumber yard, two drive-through restaurants, and a crushed -rock gravel area for long-term vehicle storage. Construction of the proposed Project would provide short-term construction jobs over an approximately 24 month period. Many of the construction jobs would be temporary and would be specific to the variety of construction activities. The workforce would include a variety of craftspeople, such as cement finishers, ironworkers, welders, carpenters, electricians, painters, and laborers. Generally, construction workers are only at a job site for the timeframe in which their specific skills are need to complete that phase of construction. Although the proposed Project would increase the number of employees at the Project site during construction activities, it is expected that local and regional construction workers would be available to serve the proposed Project's construction needs. Project -related construction workers would not be expected to relocate their household's place of residence as a consequence of 75 6/2/2020 working on the proposed Project; therefore, the proposed Project would result in a less than significant impact associated with inducing substantial population growth or demand for housing through increased construction employment, and no mitigation would be required. Operation. The proposed Project would not cause or result in direct population growth because the proposed Project would not provide or remove housing on the Project site. The proposed Ganahl Lumber Yard development would employ approximately 60 to 80 people at full capacity. The proposed fast-food restaurants and automobile storage would also result in increased employment at the Project site; however, these uses are not anticipated to result in substantial population growth in the area. Further, since the proposed Ganahl Lumber hardware store and lumber yard would replace an existing Ganahl store approximately 0.50 mile south of the Project site, it is anticipated that some of the employees of the current store would resume employment at the proposed location in San Juan Capistrano. As of March 2019, the City had a labor force of 17,400, and the County had a labor force of 1,631,500, with approximately 500 and 52,700 people unemployed, respectively.13 The March 2019 unemployment rate was 3.1 percent for the City and 3.2 percent for the County.14 This suggests an available local and regional labor pool to serve the long-term employment opportunities offered by the proposed Project. It is unlikely that a substantial number of employees would need to be relocated from outside the region to meet the need employees resulting from implementation of the proposed Project. Furthermore, the proposed Project would be located within a developed area of San Juan Capistrano that is already served by all utilities. The existing regional infrastructure and the established roadway network would be utilized by employees accessing the Project site and would not indirectly or directly induce population or growth. Operation of the proposed Project would not induce substantial population growth or accelerate development in an underdeveloped area, and any impacts to population growth would be less than significant. No mitigation is required. (Appendix A [Initial Study], pp. 4-46 through 4-47.) 13 State of California Employment Development Department. 2019. Monthly Labor Force Data for Cities and Census Designated Places, March 2019. April 19, 2019. Website: http://www.labormarketinfo.ca.gov/file/lfmonth/lasub.xls (accessed on April 24, 2019). 14 Ibid. 76 6/2/2020 9 1. Displacement of Housing Threshold: Would the Project displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere; and displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-47.) Explanation: The project proposes the development of a currently undeveloped site. Therefore, the Project would not result in a loss of housing or persons, nor require or necessitate the development of replacement housing elsewhere. No mitigation would' be required. (Appendix A [Initial Study], p. 4-47.) PUBLIC SERVICES Fire Protection Threshold: 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 fire protection? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-51.) Explanation. Fire protection services would be provided to the Project site by the Orange County Fire Authority (OCFA). OCFA provides fire protection, emergency medical and rescue services, hazardous materials inspection and response, and public education activities to its service area's approximately 1.8 million residents throughout 23 cities and unincorporated Orange County. Currently, OCFA has a total of 72 stations in Orange County and 1 station within San Juan Capistrano.15 OCFA Operations Division 3, which includes Battalions 6 and 7, serves the Cities of San Juan Capistrano, Dana Point, Mission Viejo, Rancho Santa Margarita, San Clemente, and the 15 Orange County Fire Authority (OCFA). Fiscal Year 2018-2019 Adopted Budget. Website: https://www.ocfa.org/Uploads/Transparency/OCFA%202018- 2019%20Adopted%20Budget.pdf (accessed April 24, 2019). 77 6/2/2020 communities of Coto de Caza, Las Flores, and Ladera Ranch.16 The City of San Juan Capistrano is within Battalion 6. Fire station No. 7 is the only OCFA station located in the City. Located at 31865 Del Obispo Street (approximately 1.7 miles northeast of the Project site), Fire Station No. 7 would be the first to respond to the Project site in the event of an emergency, and would be the "first -in" station. Station No. 7 is staffed by three captains, three engineers, nine firefighters, and reserve firefighters.17 "Second call" stations are fire stations that support the "first -in" station. Fire Station No. 30 would be designated as the "second call" station to support Fire Station No. 7. Fire Station No. 30 is located at 23831 Stonehill Drive in the City of Dana Point, approximately 2.2 miles west of the Project site. Station No. 30 is staffed by three captains, three engineers, six firefighters, and reserve firefighters.'$ In Fiscal Year 2018/2019, OCFA had 1,412 full -time -equivalent uniformed and civilian personnel budgeted.19 OCFA is divided into six primary departments: Business Services, Communications and Public Affairs, Community Risk Reduction, Human Resources, Operations, and Support Services. The Operations Department comprises seven divisions and nine battalions that provide regional emergency response to all fires, rescues, hazardous materials incidents, wildland fires, aircraft fire and rescue services to John Wayne Airport, and other miscellaneous emergencies .20 The Support Service Department provides essential support functions to all departments of OCFA, including coordinating all facilities maintenance, repairs, and construction; automotive and fleet maintenance, repairs, and acquisitions; development, operation, 16 OCFA. Operations Division 3. Website: https://www.ocfa.org/aboutus/Departments/Operations Directory/Division3.aspx (accessed April 24, 2019). 17 OCFA. Fire Station 7. Website: https://www.ocfa.org/aboutus/Departments/OperationsDirectory/Division3.aspx (accessed April 24, 2019). 18 OCFA. Fire Station 30. Website: https://www.ocfa.org/aboutus/Departments/OperationsDirectory/Division3.aspx (accessed April 24, 2019). 19 OCFA. Fiscal Year 2018-2019 Adopted Budget. Website: https://www.ocfa.org/Uploads/Transparency/OCFA %202018 - 2019%20Adopted%20Budget.pdf (accessed April 24, 2019). 20 OCFA. Operations. Website: https://www.ocfa.org/AboutUs/Departments/Operations.aspx (accessed April 24, 2019). 78 6/2/2020 maintenance, and security of OCFA's computers and technical infrastructure; and operations of the Emergency Command Center.21 The Community Risk Reduction Department's responsibilities include adopting and enforcing codes and ordinances relative to fire and life safety issues; reviewing plans and conducting inspections of construction projects; coordinating annual life safety inspections of all existing commercial buildings; providing long-range analysis of impacts on resources associated with future land use and development; and investigating fires .22 The Communications and Public Affairs Department is responsible for both internal and external communications for OCFA .23 The Business Services Department provides budget, payroll, accounting, and administrative support to OCFA; monitors cash balances, makes investments, and coordinates the annual Tax and Revenue Anticipation Note (TRAN); and provides warehouse, purchasing, shipping and receiving, and mail operations.24 Finally, the Human Resources Department works with OCFA employees to administer employee benefits, uphold merit principles, and ensure compliance with legal and contractual obligations.25 According to the OCFA's 2017 Statistical Annual Report, OCFA responded to over 141,858 total calls for service; a total of 7,968 calls were responded to citywide. Approximately 108,347 responses were related to emergency medical services (EMS); citywide, EMS responses totaled 6,299. OCFA's average current response times are less than 7 minutes, ranging from 6 minutes, 58 21 OCFA. Support Services. Website: https://www.ocfa.org/AboutUs/Departments/SupportServices.aspx(accessed April 24, 2019) 22 OCFA. Community Risk Reduction. Website: https://www.ocfa.org/AboutUs/Departments/CommunityRiskReduction.aspx (accessed April 24, 2019). 23 OCFA. Communications and Public Affairs. Website: https://www.ocfa.org/AboutUs/Departments/Communications And PublicAffairs. aspx (accessed April 24, 2019). 24 OCFA. Business Services. Website: https://www.ocfa.org/AboutUs/Departments/BusinessServices.aspx(accessed April 24, 2019). 25 OCFA. Human Resources. Website: https://www.ocfa.org/AboutUs/Departments/HumanResources.aspx(accessed April 24, 2019). 79 6/2/2020 seconds (80311 percentile) to 9 minutes, 17 seconds (90th percentile).26 The Project site is not located within a High Fire Hazard Zone according to the Fire Hazards Area Map in the City's General Plan Public Safety Element (2002). According to the CAL FIRE and Resource Assessment Program, the Project site is not within a Very High Fire Hazard Severity Zone (VHFHSZ).27 Construction. Construction of the proposed Project would include the development of the Ganahl Lumber hardware store and lumber yard, two drive-through restaurants, and a crushed rock gravel area for long-term vehicle storage. As discussed in Section 4.8, Hazards and Hazardous Materials, of the Draft EIR, the proposed Project does not include any characteristics (e.g., permanent road closure or long-term blocking of road access) that would physically impair or otherwise conflict with the City's Emergency Preparedness Program. Emergency access to the Project site would be provided via a proposed signalized intersection on Stonehill Drive, a new emergency access road along the northern boundary of the site, and a new access under Stonehill Drive to the properties directly south of the site. Thus, the proposed Project would not impair emergency response vehicles or increase response times, and would not substantially increase calls for service, thereby triggering the need for new or altered facilities. Consequently, OCFA would be able to maintain current levels of service provided to the Project site following project implementation. Therefore, construction impacts related to acceptable emergency response time plans and fire protection services associated with construction of the proposed Project would be less than significant, and no mitigation would be required. Operation. The proposed Project would allow for the operation of a hardware store and lumber yard, two drive-through restaurant uses, and a vehicle storage area on the site, which would increase the number of on-site visitors, and potentiality increase the demand for fire protection services. As discussed in Section 4.14, Population 26 OCFA. 2017 Statistical Annual Report. Website: https://www.ocfa.org/Uploads/Transparency/OCFA%2OAnnual%2OReport%202017.pdf (accessed April 24, 2019). 27 California Department of Forestry and Fire Protection (CalFire). 2011. Very High Fire Hazard Severity Zones in LRA. San Juan Capistrano. October 2011. Website: http://www.fire.ca.gov/fire_prevention/fhsz_maps/FHSZ/orange/c3O_SanJuanCapistran o_vhfhsz.pdf (accessed April 24, 2019). 80 6/2/2020 and Housing, of the Draft EIR, the proposed Project would not cause or result in direct population growth because the proposed Project would not provide or remove housing on the Project site. The proposed Ganahl Lumber Yard development would employ approximately 60 to 80 people at full capacity. The proposed restaurants and automobile storage would also result in increased employment at the Project site; however, these uses are not anticipated to result in substantial population growth in the area. As of March 2019, the City had a labor force of 17,400, and the County had a labor force of 1,631,500, with approximately 500 and 52,700 people unemployed, respectively. The March 2019 unemployment rate was 3.1 percent for the City and 3.2 percent for the County.39 This suggests an available local and regional labor pool to serve the long-term employment opportunities offered by the proposed Project. It is unlikely that a substantial number of employees would need to be relocated from outside the region to meet the need employees resulting from implementation of the proposed Project. As such, the operation of the proposed Project would result in a small increase in demand for fire protection services but would not trigger the need for new or altered facilities. No new facilities would be required to be constructed to accommodate the proposed Project. The proposed Project would be required to comply with all applicable building code requirements requiring fire protection devices, such as sprinklers, alarms per the California Fire Code (Municipal Code Section 8-10.01 [Adoption of the 2016 California Fire Code]), adequately spaced fire hydrants, fire access lanes, and adequate emergency access. In order to meet the California Fire Code requirements, the Project would include the addition of six on- site fire hydrants, fire lanes throughout the site, and emergency access at all entry points to the property. In addition, buildings proposed on the southwestern portion of the site would include automatic sprinkler systems to further minimize impacts related to fires. As such, the proposed Project would be designed to comply with all OCFA access requirements and California Fire Code requirements. Therefore, operation of the proposed Project would not impair emergency response vehicles or increase response times, and would not substantially increase calls for service, thereby triggering the need for new or altered facilities. No mitigation would be required. (Appendix A [Initial Study], pp. 4-48 through 4-51.) 2. Police Protection 81 6/2/2020 Threshold: 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 police protection? Finding: Less than significant impact. (Appendix A [Initial Study], pp. 4-51.) Explanation: The City contracts with the Orange County Sheriffs Department (OCSD) for police protection services. OCSD provides 24-hour contract law enforcement services to the City. The OCSD Police Services Station, located at 32506 Paseo Adelanto in San Juan Capistrano, approximately 1 mile north of the Project site, serves the City. OCSD's Aliso Viejo Station, located at 11 Journey in the City of Aliso Viejo, approximately 4 miles northwest of the Project site, also serves the City. In total, 28 OCSD personnel are assigned to the City, including one lieutenant, four sergeants, two investigators, and 21 sheriffs deputies.28 The City's staffing level is based on response times and crime rates. At the present time, OCSD maintains a staffing ratio of approximately one sworn officer for every 1,300 residents in the City.29 Police protection services are expanded in the City consistent with community needs. The ongoing -operations of OCSD in the City are primarily funded from the City's General Fund, which receives revenue from property taxes, transit taxes, and other sources. The City utilizes part of this revenue to increase police staffing on an as - needed basis. Construction. Construction of the proposed Project is not expected to have any substantial adverse impacts on existing police protection services, as the construction workers would occupy a temporary position and would only incrementally increase the demand for police protection services. Construction of the proposed Project would be temporary in nature and would not 28 City of San Juan Capistrano. Mitigated Negative Declaration and Initial Study for the Church of Jesus Christ Latter Day Saints Meetinghouse Project. September 2017. 29 28 officers / 35,948 (2017 population) = approximately 1 officer per 1,300 persons. Source: United States Census Bureau. American Fact Finder 2013-2017 American Community Survey 5 -Year Estimates. San Juan Capistrano city, California. Website: https://factfinder.census.gov/faces/nav/jsf/pages/community facts. xhtml?src=bkmk (accessed April 24, 2019). 82 6/2/2020 result in the need for new or physically altered governmental facilities related to police protection and would not result in an increased demand for police services. Therefore, impacts related to the provision of police protection for the construction of the proposed Project would be less than significant, and no mitigation would be required. Operation. Substantial population growth is not anticipated as a result of the implementation of the proposed Project. The proposed Ganahl Lumber Yard development would employ approximately 60 to 80 people at full capacity. The proposed fast-food restaurants and automobile storage would also result in increased employment at the Project site; however, these uses are not anticipated to result in substantial population growth in the area. Further, since the proposed Ganahl Lumber hardware store and lumber yard would replace an existing Ganahl store approximately 0.50 mile south of the Project site, it is anticipated that some of the employees of the current store would resume employment at the proposed location in San Juan Capistrano. When considered with the existing population, the Project -related population increase would have a negligible impact on OCSD's ratio of one police officer for every 1,300 residents. Although the Project would incrementally contribute to the demand to additional police protection services, impacts to police services would be less than significant, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-51 through 4-52.) 3. Schools Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-54.) Explanation: The provision of education and school facilities in the City is the responsibility of the Capistrano Unified School District (CUSD). The CUSD currently serves approximately 54,000 students in kindergarten through 12th grade.30 The CUSD's boundaries encompass all or part of the Cities of San Juan Capistrano, San Clemente, Dana Point, Laguna Niguel, Aliso Viejo, Mission Viejo and Rancho Santa Margarita, and the unincorporated communities 30 Capistrano Unified School District. District Facts. Website: http://capousd.ca.schoolloop.com/cros/page_view?d=x&piid=&vpid=1232963501986 (accessed April 24, 2019). 83 6/2/2020 31 [bid. of Las Flores, Coto de Caza, Dove Canyon, Ladera Ranch, Sendero/Rancho Mission Viejo, and Wagon Wheel.31 The CUSD operates 63 campuses; the closest CUSD schools to the Project site are Del Obispo Elementary School, located at 25591 Camino Del Avion, and Marco Forster Middle School, located at 25601 Camino Del Avion, both approximately 0.6 mile north of the Project site. Construction. Construction of the proposed Project, specifically construction of the proposed signal and deceleration lane on Stonehill Drive, may result in temporary lane closures adjacent to the site, which may result in adverse impacts on existing CUSD operation. However, the City would notify CUSD regarding any temporary lane closures prior to their occurrence. Further, construction impacts would be temporary in nature and would cease upon project completion. Therefore, there would be no project construction impacts related to public school services, and no mitigation would be required. Operation. The proposed Project would allow for the operation of a hardware store and lumber yard, two drive-through restaurant uses, and a vehicle storage area on the site. The proposed Project does not include any residential uses that would increase population growth, generate an increased demand for school facilities, or require the construction of school facilities. Although the Project is anticipated in increase employment by 60 to 80 positions (in addition to employment generated by the restaurant uses and the vehicle storage area), this amount is nominal and not expected to significantly impact public school services within the CUSD. In addition, because the proposed Ganahl Lumber store would replace an existing Ganahl store approximately 0.50 mile south of the Project site, it is anticipated that some of the employees of the current store would resume employment at the proposed location in San Juan Capistrano and not relocate. Furthermore, pursuant to California Education Code Section 17620(a)(1), the governing board of any school district is authorized to levy a fee, charge, dedication, or other requirement against any construction within the boundaries of the district for the purpose of funding the construction or reconstruction of school facilities. The Project Applicant would be required to pay such fees to reduce any impacts of new development on school services as provided in Section 65995 of the California Government Code. Pursuant to the provisions of Government Code Section 65996, a project's impact on school 84 6/2/2020 facilities is fully mitigated through payment of the requisite school facility development fees current at the time a building permit is issued. The current Development Impact Fee for commercial projects within the CUSD's jurisdictional boundaries is $0.61 per square foot." Therefore, with payment of the required fees, potential impacts to school services and facilities associated with implementation of the proposed Project would be less than significant, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-52 through 4-53.) 4. Parks Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for parks? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-54.) Explanation: As discussed in Section 4.15, Recreation, of the Draft EIR, the City maintains approximately 162.6 acres of parks and recreational uses. Currently, the City has an established standard of 5 acres of park space per 1,000 residents. The closest park to the Project site is Creekside Park, which is located approximately 200 ft west of the Project site. Although the Project is anticipated to increase employment in the City by 60 to 80 positions (in addition to employment generated by the restaurant uses and the vehicle storage area), this amount is negligible compared to the amount of parks and recreational space within the City. While it is possible that employees may visit parks and use facilities during breaks or after work hours, such visitation would not significantly affect park performance. Additionally, the use of other parks in the City by on-site residents would not increase to a level that would result in the need for new or physically altered facilities. Therefore, the impact would be less than significant, and no mitigation would be required. (Appendix A [Initial Study], p. 4-54.) 5. Other Public Facilities Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause 85 6/2/2020 significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for other public facilities? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-55.) Explanation- The Orange County Public Library (OCPL) system provides library services to the County, including the City, and includes 33 branches.45 The San Juan Capistrano Library is the City's only library and is located at 31495 EI Camino Real. The San Juan Capistrano Library consists of a 12,000 sf building that holds over 45,789 volumes, CDs, and videos, and provides 23 public computers and 3 additional resource/catalogue computers.32 Development of the proposed Project would result in an increase of an estimated 60 to 80 employees (in addition to employment generated by the restaurant uses and the vehicle storage area). While it is possible that employees may visit library facilities during breaks or after work hours, the impact would not significantly affect OCPL system performance, and would not require the expansion of libraries within the City. Thus, it is unlikely that the implementation of the proposed Project would increase demand for library facilities. In addition, authorized by Government Code Section 66001(e), the Orange County Board of Supervisors adopted Resolution No. 13- 062 with respect to the Development Fee program for Branch Libraries, stating that those facilities have been constructed and the fee program is no longer needed. As such, the proposed Project's increase in demand on library services is incremental and would not necessitate the need for expanded library facilities, the development of which could cause a physical adverse environmental impact with respect to libraries. Therefore, the Project would have less than significant impacts related to public libraries, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-54 through 4-55.) P. RECREATION 1. Increased Use Threshold: Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-56.) 32 City of San Juan Capistrano, Public Services & Utilities Element (1999). 86 6/2/2020 Explanation: According to the Parks and Recreation Element of the City's General Plan (2002), the City currently maintains approximately 162.6 acres of parks and recreational facilities within its boundaries. The City has an established standard of 5 acres of park space per 1,000 residents. The closest park to the Project site is Creekside Park, which is located approximately 200 ft west of the Project site. Additionally, the San Juan Creek Trail, a multi -use pedestrian and bicycle route which begins in San Juan Capistrano and terminates at Doheny Beach in the City of Dana Point, is located immediately west of the Project site. The Project does not propose any residential uses and, therefore, would not increase the population or demand related to parks. Although the Project is anticipated to increase employment by 60 to 80 positions (in addition to employment generated by the restaurant uses and the vehicle storage area), the number of employees is minor compared to the amount of parks and recreational space within the City. While it is possible that employees may visit parks and recreational facilities in the City during lunch breaks or after - work hours, it is unlikely that the use of parks by project employees would increase the use of those parks to a level that would contribute to substantial physical deterioration of those facilities. Therefore, the impact is less than significant, and no mitigation would be required. (Appendix A [Initial Study], p. 4-56.) 2. Construction and Expansion Threshold: Does the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Finding, No impact. (Appendix A [Initial Study], p. 4-57.) Explanation: The Project site encompasses an approximately 17 -acre undeveloped gravel lot which is currently used for vehicle storage. Construction of the proposed Project would include the development of the Ganahl Lumber hardware store and lumber yard, two drive-through restaurants, and a crushed -rock gravel area for long-term vehicle storage. The proposed Project would not include recreational facilities nor develop residential uses that would require the construction or expansion of recreational facilities that might have an adverse effect on the environment. The project does not propose any recreational uses which might have an adverse physical effect on the environment. Therefore, there would be no impacts related to the construction or expansion of recreational facilities, and no 87 6/2/2020 mitigation would be required. (Appendix A [Initial Study], pp. 4-56 through 4-57.) Q. TRANSPORTATION / TRAFFIC 1. Plans, Policies, and Ordinances Threshold: Would the Project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Fines: Less than significant impact. (Draft EIR, pp. 4.12-13, 4.12-19.) Explanation: Construction. As described further in Section 3.0, Project Description, of the Draft EIR, construction equipment and vehicles will be staged on site. Although the Project does not include any characteristics (e.g., permanent road closure or long-term blocking of road access) that would physically impair or otherwise interfere with transit, roadways, bicycle facilities, and/or pedestrian facilities in the Project vicinity, the Project would require temporary lane closures on Stonehill Drive to allow for utility connections and the proposed traffic signal located at the southwestern corner of the site and Stonehill Drive. Project construction would take up to 1.5 years. During project construction, a total of 32 workers would be on the site per day (8 hours per day per person). Assuming 32 trucks per day, applying a passenger car equivalent (PCE) factor of 2.5 and a uniform arrival/departure of the trucks during an 8 -hour day, the resultant construction truck generation (in PCEs) would be 160 ADT, 20 a.m. peakhour trips (10 inbound and 10 outbound), and 20 p.m. peak - hour trips (10 inbound and 10 outbound). The total construction worker and truck trip generation (in PCEs) would be 256 ADT, 52 a.m. peak -hour trips (42 inbound and 10 outbound), and 52 p.m. peak -hour trips (10 inbound and 42 outbound). Because the construction trip generation would be significantly less than the net trip generation of the proposed Project (which would generate 3,486 ADT, 312 a.m. peak -hour trips and 213 p.m. peak hour trips), construction traffic impacts would be less than significant. 88 6/2/2020 Although construction traffic would be less than traffic generated by project operation, the Project would be required to adhere to all applicable City requirements and would implement recommendations outlined in the California Manual on Uniform Traffic Control Devices (Caltrans 2014)1 to reduce potential impacts on the local circulation system during project construction. Among other things, this manual recommends early coordination with affected agencies to ensure that emergency vehicle access is maintained. Therefore, construction of the Project would result in less than significant traffic impacts related to potential conflicts with plans, programs, ordinances, or policies addressing the local circulation system, and no mitigation would be required. (Draft EIR, p. 4.12-13.) Operation. The proposed Project would be required to comply with the Orange County Congestion Management Program (CMP) (2017). The project's consistency with this plan is described in detail below. Conformance with the Orange County CMP — Less than Significant Impact. A TIA is required for CMP purposes for any proposed development generating 2,400 or more daily trips, with the exception of developments that will directly access a CMP Highway System roadway segment, for which the threshold for requiring a TIA is reduced to 1,600 or more trips per day. Because the proposed Project is estimated to generate 3,486 daily trips, a TIA was prepared for the proposed Project in compliance with CMP standards. Based on CMP requirements, the study area for a project must extend far enough to cover any CMP roadway segment on which the Project traffic would represent 3 percent or more of the roadway segment's LOS E capacity. Within San Juan Capistrano, the CMP Highway System includes one arterial — Ortega Highway. The Ortega Highway/Interstate 5 (1-5) ramp intersection is the only CMP intersection in the City. Due to the distance of this intersection to the Project site, project -related traffic would not represent 3 percent or more of this intersection's capacity. As such, no further analysis of project -related impacts on CMP roadway segments and/or intersections is required. Therefore, the proposed Project would not result in conflicts with the Orange County CMP, and no mitigation would be required. (Draft EIR, p. 4.12-19.) 2. VMT Threshold: Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3 or conflict with an applicable congestion management program, including, but not limited to, level of service standards and travel demand measures, or other standards 89 6/2/2020 established by the county congestion management agency for designated roads or highways? Finding: Less than significant impact. (Draft EIR, p. 4.12-20.) Explanation: According to State CEQA Guidelines Section 15064.3(a), project related transportation impacts are generally best measured by evaluating the Project's vehicle miles traveled (VMT). VMT refers to the amount and distance of automobile travel attributable to a project. State CEQA Guidelines Section 15064.3(b) sets forth criteria for analyzing transportation impacts, breaking down the methodology based on project type and specifying other criteria for conducting VMT analysis. For land use projects, VMT exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects located within 0.5 mi of an existing high-quality transit corridor should be considered to have a less than significant impact. State CEQA Guidelines Section 15064.3(b)(2) addresses VMT associated with transportation projects and states that projects that reduce VMT, such as pedestrian, bicycle, and transit projects, should be presumed to have a less than significant impact. Subdivision (b)(3) of the State CEQA Guidelines, Section 15064.3, acknowledges that Lead Agencies may not be able to quantitatively estimate VMT for every project type; in these cases, a qualitative analysis may be used. The regulation goes on to state that Lead Agencies have the discretion to formulate a methodology that would appropriately analyze a project's VMT. (State CEQA Guidelines Section 15064.3(b)(4)). It is important to note that State CEQA Guidelines Section 15064.3(c) states that while an agency may elect to be governed by the provisions of this section immediately, it is not required until July 1, 2020. The Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR 2018) includes recommended thresholds for determining VMT impacts for land use development project. According to the technical advisory, a net increase in total VMT may indicate a significant transportation impact for retail projects because retail development projects typically redistribute shopping trips rather than creating new trips. According to the Ganahl Lumber Development Project Traffic Impact Analysis, the proposed Project would replace an existing Ganahl Lumber hardware store located of 34162 Doheny Park Road in Capistrano Beach (approximately 0.50 mile south of the Project site). In addition, the proposed Project would include a fast-food restaurant use, which is 90 6/2/2020 intended for nearby residents of the surrounding community and users already driving along Stonehill Drive. The project also includes a vehicle storage lot for 399 vehicles, which will replace the existing vehicle storage lot located on the Project site. Because the proposed Project would replace an existing Ganahl Lumber hardware store within close proximity to the Project site, provide local serving retail/restaurant uses, and replace the existing vehicle storage spaces, there would be no net increase in VMT within the Project area as a result of project implementation. At this time, the City has not adopted a methodology to analyze VMT impacts within its jurisdiction. In addition, the City does not currently have thresholds or standards in place for assessing potential VMT impacts. Therefore, this information is provided for disclosure purposes only, and traffic impacts in this Draft EIR for CEQA purposes are based on the City's LOS thresholds. CMP Facilities. As stated above, the Ortega Highway/Interstate 5 (1-5) ramp intersection is the only CMP intersection in the City. Due to the distance of this intersection to the Project site, project -related traffic would not represent 3 percent or more of this intersection's capacity. As such, no further analysis of project -related impacts on CMP roadway segments and/or intersections is required. Therefore, the proposed Project would not result in conflicts with the Orange County CMP, and no mitigation would be required. (Draft EIR, pp. 4.12-19 through 4.12-20.) 3. Design Hazards Threshold: Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Finding: No impact. (Appendix A [Initial Study], p. 4-60.) Ex lanation: Access to the Project site would be provided via Stonehill Drive. Vehicular access to the Project site would be provided via a proposed signalized intersection at Stonehill Drive and the southwestern corner of the Project site and Stonehill Drive. The project would include internal circulation routes, including truck traffic routes and a fire access lane. Pedestrian and bicycle access to the Project site would be provided by sidewalks and a bicycle route on Stonehill Drive, respectively. Vehicular traffic to and from the Project site would utilize the existing network of regional and local roadways that currently serve the Project site area. The proposed Project would not introduce any new roadways or introduce a land use that would conflict with existing urban land 91 6/2/2020 uses in the surrounding area. Design of the proposed Project, including the internal private roadways, ingress, egress, and other streetscape changes, would be subject to review by the City's Department of Public Works for compliance with City regulations. Therefore, the proposed Project would not impact traffic safety due to a design feature (e.g., substandard roadway and/or roadway design), and no mitigation would be required. (Appendix A [Initial Study], pp. 4-59 through 4-60.) 4. Emergency Access Threshold: Would the Project result in inadequate emergency access? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-60.) Explanation, Access to the Project site would be provided via Stonehill Drive. Vehicular access to the Project site would be provided via a proposed signalized intersection at Stonehill Drive and the southwestern corner of the Project site and Stonehill Drive. The project would include internal circulation routes, including truck traffic routes and a fire access lane. Pedestrian and bicycle access to the Project site would be provided by sidewalks and a bicycle route on Stonehill Drive, respectively. According to the City's map of evacuation routes, Stonehill Drive is identified as potential evacuation route in the event of an emergency. As part of the Project, a two-lane easement travelling north/south from the northwestern corner of the Project site to Avenida Aeropuerto is proposed; the easement would be located immediately west of the mobile home park adjacent to the Project site and would be approximately 1,270 ft in length. The purpose of the northern easement is to provide emergency ingress/egress to and from the Project site to the north. A second two-lane easement travelling north/south is proposed at the southeastern corner of the Project site; this easement would travel under the Stonehill Drive Bridge and connect the Project site to neighboring parcels to the south. Project features discussed above would improve emergency access to and from the Project site. Access to/from the Project site must be designed to City standards and would be subject to review by the Orange County Fire Authority (OCFA) and the Orange County Sheriff Department (OCSD) for compliance with fire and emergency access standards and requirements. Therefore, approval of the Project plans would ensure that the proposed Project's impact related to emergency access would be less than significant, and no mitigation would be required. (Appendix A [Initial Study], p. 4-60.) 92 6/2/2020 R. TRIBAL CULTURAL RESOURCES 1. Tribal Cultural Resources Threshold: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? Finding: No impact. (Appendix A [Initial Study], p. 4-62.) Explanation: As discussed in Section 2.5, Cultural Resources, of the Draft EIR, implementation of the proposed Project would not cause a substantial adverse change in the significance of a historical resource, as there are no eligible resources or structures on site. In its existing setting, the Project site is undeveloped. On September 26, 2017, a cultural resources records search was conducted at the South Central Coastal Archaeological Information Center (SCCIC), located at California State University, Fullerton. The purpose of the records search was to determine the extent of previous cultural resources investigations within a 0.5 -mile radius of the Project area, and whether any previously recorded historic resources exist within or near the Project area. Materials reviewed included reports of previous cultural resources investigations, archaeological site records, historical maps, and listings of resources on the National Register of Historic Places (NRNP), California Register of Historical Resources (CRHR), California Points of Historical Interest, California Landmarks, and National Historic Landmarks. According to the results from the records search, no previously recorded historic properties are within the Project site. Furthermore, according to the City's map of historic buildings and structures, there are no historic resources on or within the vicinity of the Project site. As a result, the Project will not cause a substantial change in the significance of a historical resource as defined in Public Resources Code section 5020.1(k). No mitigation would be required. (Appendix A [Initial Study], pp. 4-61 through 4-62.) S. UTILITIES AND SERVICE SYSTEMS 93 6/2/2020 1. Water Supplies Threshold: Would the Project have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years? Finding: Less than significant impact. (Draft EIR, p. 4.14-19.) Explanation: The proposed Project would allow for the development of a lumber yard and hardware store, drive-through restaurant uses, and a crushed -rock gravel area for long term vehicle storage. As such, the proposed Project would increase the demand for water on-site. As shown in Table 4.14.6 (found at Draft EIR, p. 4.14-11), the proposed Project is estimated to demand approximately 16,190 gpd (18.1 afy) of water. According to the City's 2015 UWMP, citywide water supply and demand for potable water was 8,531 afy in 2015 and is expected to increase to 8,618 afy by 2020 and 8,688 afy by 2040 under a normal -year scenario. The 2015 UWMP projections include population increases of approximately 0.3 percent per year, as well as anticipated water conservation strategies. According to the 2015 UWMP, the City is able to meet all water demand with significant reserves held by MWDOC, local groundwater supplies, and conservation under all conditions through 2040, taking into consideration a nine percent increase over normal demand.33 The supply and demand forecasts for the third dry -year scenario (considered to be the worst-case scenario) are shown above in Table 4.14.A (found at Draft EIR, p. 4.14-4). The relatively small increase in water use, which would represent approximately 0.2 percent of the City's 2020 projected annual water demand, would be accounted for in the anticipated growth rates for the City. Moreover, the proposed Project is consistent with the General Plan designation of Quasi -Industrial for the Project site. As such, the additional water use anticipated with the proposed development has already been considered and planned for in the City's current land use and water management planning documents, including the UWMP. Overall, the City's per -capita water use is projected to continue to decrease into the future, thereby keeping demand relatively constant over the next 25 years. As discussed earlier, in the event that the City's water utilities are transferred to the SMWD, the City's water rights would also be transferred to the SMWD Therefore, impacts related to water supplies would be considered less than significant. (Final EIR, p. 4.14-19.) 33 City of San Juan Capistrano. 2015 Urban Water Management Plan. July 2016. 94 6/2/2020 2. Wastewater Capacity Threshold: Would the Project result in a determination by the wastewater treatment provider which serves or may serve the Project that it has adequate capacity to serve the Project's projected demand in addition to the provider's existing commitments? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-65.) Explanation: Local governments and water districts are responsible for complying with federal regulations, both for wastewater plant operation and the collection systems (e.g., sanitary sewers) that convey wastewater to the wastewater treatment facility. Proper operation and maintenance is critical for sewage collection and treatment because impacts from these processes can degrade water resources and affect human health. For these reasons, publicly owned treatment works (POTWs) receive Waste Discharge Requirements (WDRs) to ensure that such wastewater facilities operate in compliance with the water quality regulations set forth by the State. WDRs, issued by the State, establish effluent limits on the kinds and quantities of pollutants that POTWs can discharge. These permits also contain pollutant monitoring, record-keeping, and reporting requirements. Each POTW that intends to discharge into the nation's waters must obtain a WDR prior to initiating its discharge. Construction. Implementation of the proposed Project would allow for the development of a lumber yard and hardware store, drive- through restaurant uses, and a crushed -rock gravel area for long- term vehicle storage on a currently undeveloped site. Short-term generation of wastewater may occur during construction activities on site. Wastewater generated from soil watering (fugitive dust control), cleanup, masonry, painting, and other activities would be temporary and would cease once construction is completed. Overall, construction activities generate minimal wastewater and are not expected to adversely impact the wastewater treatment provider which serves the Project. Therefore, potential project impacts associated with short-term construction activities would be less than significant, and no mitigation would be required. Operation. The proposed Project would have similar wastewater service needs as the existing Ganahl Lumber store located at 95 6/2/2020 34162 Doheny Park Road. Wastewater from the proposed Project would be directed to the City's sanitary sewer system, which connects to trunk sewers operated by the South Orange County Wastewater Authority (SOCWA). SOCWA is a Joint Powers Authority with ten member agencies, consisting of local retail water agencies and cities providing their residents. SOCWA operates three treatment plants and two ocean outfalls, as well as multiple programs to meet the needs of its member agencies and the requirements of the Clean Water Act and applicable NPDES permits.34 SOCWA's three primary treatment facilities have a treatment capacity of 26 million gallons of wastewater per day (mgd). Historically, approximately half of this wastewater is treated for recycled water use, while the other half is treated and discharged through the two ocean outfalls.35 Wastewater entering the SOCWA trunk sewer lines from the City is delivered to the J.B. Latham Regional Treatment Plant (J.B. Latham Plant) for collection, treatment, and disposal. This facility is responsible for the treatment and disposal of wastewater.50 Because the reclamation plant is considered POTWs, operational discharge flows treated at the plant would be required to comply with applicable WDRs issued by the San Diego RWQCB. Compliance with conditions or permit requirements established by the San Diego RWQCB WDRs would ensure that wastewater discharges from the Project site and treated by the wastewater treatment facility system would not exceed applicable San Diego RWQCB wastewater treatment requirements. Further, wastewater generated from the proposed Project would be typical of commercial wastewater flows in the City. Therefore, the wastewater treatment providers that serve the Project would determine that there is adequate capacity to serve the Project's projected demand in addition to the provider's existing commitments. No mitigation would be required. (Appendix A [Initial Study], pp. 4-64 through 4- 65.) 3. Solid Waste Threshold: Would the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Fid: Less than significant impact. (Appendix A [Initial Study], p. 4-66.) 34 South Orange County Wastewater Authority. About SOCWA. Website: https://www.socwa.com/aboutsocwa/(accessed April 25, 2019). 35 SOCWA. Infrastructure. Website: https://www.socwa.com/infrastructure/ (accessed April 25, 2019). 96 6/2/2020 Explanation: Construction. The Project site is currently vacant and undeveloped, and therefore, no solid waste is generated under existing conditions. The proposed Project would allow for the development of a lumber yard and hardware store, drive-through restaurant uses, and a crushed -rock gravel area for long-term vehicle storage. Construction of the proposed Project would generate minimal amount of demolition waste because the site is currently vacant, and no demolition of structures would be required. In compliance with Municipal Code Section 6-3.08.01, Minimum Construction and Demolition Debris Diversion Requirements, the Project would divert at least 65 percent of the construction waste materials generated during the Project. Therefore, the proposed Project would not have the potential to cause significant impacts related to solid waste generation during construction, and no mitigation measures regarding construction debris are required. Operation. The City contracts with CR&R Waste and Recycling Services (CR&R), a private solid waste hauler, to collect and dispose of the solid waste/refuse generated by the City. Solid waste generated by the proposed Project would be collected by CR&R and hauled to the Prima Deshecha Landfill, which currently processes an average of approximately 1,400 tons per day (tpd), with a maximum capacity of 4,000 tpd."36 Therefore, the Prima Deshecha Landfill is currently operating at approximately 35 percent of its daily design capacity.37 Based on this information, it is unlikely that the proposed Project would generate enough total solid waste at project build out to significantly impact the total capacity of the Prima Deshecha Landfill. The Prima Deshecha Landfill is scheduled to close in approximately 2067. The proposed Project is estimated to be completed by 2024; the Prima Deshecha Landfill is, therefore, anticipated to be closed 43 years after the completion of project build out. Further, the existing General Plan land use designations and zoning classifications are consistent with the proposed Project (refer to discussion in Section 4.11, Land Use and Planning, Response 4.11 (b), for discussion on the Project's consistency with the General Plan and Zoning requirements). As such, the proposed Project would not alter the planned land uses as projected by the City. Therefore, impacts related to solid waste generation are considered 36 OC Landfills Prima Deshecha Landfill. Website: http://www.oclandfills.com/landfill/active/deshecha.(accessed April 25, 2019). 37 CalRecycle. Facility/Site Summary Details: Prima Deshecha Sanitary Landfill. Website: https://www2.calrecycle.ca.gov/swfaciIities/Directory/30-AB-0019 (accessed April 25, 2019). 97 6/2/2020 less than significant, and no mitigation would be required. (Appendix A [Initial Study], pp. 4-65 through 4-66.) 4. Solid Waste Laws Threshold: Will the Project comply with federal, state, and local statutes and regulations related to solid waste? Finding: Less than significant impact. (Appendix A [Initial Study], p. 4-66.) Explanation: The California Integrated Waste Management Act (Assembly Bill [AB] 939) changed the focus of solid waste management from landfill to diversion strategies, such as source reduction, recycling, and composting. The purpose of the diversion strategies is to reduce dependence on landfills for solid waste disposal. AB 939 established mandatory diversion goals of 25 percent by 1995, 50 percent by 2000, and 75 percent by 2020. Construction. Construction of the proposed Project would generate minimal amount of demolition waste because the site is currently vacant, and no demolition of structures would be required. Further, in compliance with Municipal Code Section 6-3.08.01, Minimum Construction and Demolition Debris Diversion Requirements, the Project would divert at least 65 percent of the construction waste materials generated during the Project. Construction of the proposed Project would comply with existing or future statutes and regulations, including waste diversion programs mandated by City, State, or federal law. Therefore, impacts would be less than significant, and no mitigation would be required. Operation. Operation of the proposed Project would comply with existing or future statutes and regulations, including waste diversion programs mandated by City, State, or federal law. The proposed Project would not result in an excessive production of solid waste that would exceed the capacity of the existing landfills serving the Project site. Therefore, the proposed Project would result in a less than significant impact related to federal, State, and local statutes and regulations related to solid wastes, and no mitigation would be required. (Appendix A [Initial Study], p. 4-66.) T. WILDFIRE Response Plans Threshold: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project substantially 98 6/2/2020 impair an adopted emergency response plan or emergency evacuation plan? Finding: No impact. (Appendix A [Initial Study], p. 4-68.) Explanation: The Project site is not located within a High Fire Hazard Zone according to the Fire Hazards Area Map in the City's General Plan Public Safety Element (2002). According to the CAL FIRE and Resource Assessment Program, the Project site is not within a Very High Fire Hazard Severity Zone (VHFHSZ).38 The City's General Plan Safety Element (2002) identifies and evaluates natural hazards associated with seismic activity, landslides, flooding, and fire within the City. The General Plan Safety Element establishes goals for each of the City departments to provide responsible planning aimed at reducing impacts with respect to loss of life, injuries, damage to property and other losses associated with disasters, such as those resulting from seismic activity, flooding, and fires. According to the City's map of evacuation routes, Stonehill Drive is identified as potential evacuation route in the event of an emergency. Construction. The proposed Project does not include any characteristics (e.g., permanent road closure or long-term blocking of road access) that would physically impair or otherwise conflict with the City's Emergency Preparedness Program. Further, all infrastructure improvements included as part of the Project would occur within the boundaries of the existing site and would not require or result in any long term or permanent lane closures on roadways adjacent to the site. Therefore, construction impacts related to emergency response and evacuation plans associated with construction of the proposed Project would be less than significant, and no mitigation would be required. Operation. The emergency management plans for the City, in conjunction with the emergency plan for the County, may be activated and directed by a number of individuals within the City or County, including, but not limited to, the City Manager, the Fire Chief, and the Police Chief. Roads that are used as response corridors/evacuation routes usually follow the most direct path to or 38 CalFire. Very High Fire Hazard Severity Zones in LRA. San Juan Capistrano. October 2011. Website:http://www.fire.ca.gov/fire_prevention/fhsz_maps/FHSZ/orange/c30_SanJuanC apistrano_vhfhsz.pdf(accessed April 24, 2019). 99 6/2/2020 from various parts of a community, although emergency response vehicles may choose to use a variety of routes to access surrounding areas. Stonehill Drive is identified as an evacuation route in the City. The proposed Project would be required to comply with all applicable codes and ordinances for emergency vehicle access, which would ensure adequate access to, from, and on site for emergency vehicles. Adherence to these codes and ordinances would ensure that operation of the proposed Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. In fact, the addition of the northern emergency access road and the access easement under Stonehill Drive Bridge would improve site access. Further, the Project site is not located in or near state responsibility areas or lands classified as VHFHSZ. (Appendix A [Initial Study], pp. 4-67 through 4-68.) 2. Pollutant Concentrations Threshold: Due to slope, prevailing winds, and other factors, would the Project exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of wildfire? Finding. No impact. (Appendix A [Initial Study], p. 4-68.) Explanation: The Project site is located in a developed portion of the City. In its existing condition, the Project site is relatively flat and there are no significant slopes adjacent to the site. The Project site is not currently developed with structures; the vehicle storage area consists of a crushed -rock gravel surface, and as such, the site lacks the combustible materials and vegetation necessary for the uncontrolled spread of a wildfire. Further, the Project site is not located in or near state responsibility areas or lands classified as VHFHSZ. Therefore, due to slope, prevailing winds, location, and other factors, the proposed Project would not exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. No mitigation would be required. (Appendix A [Initial Study], p. 4-68.) 3. Infrastructure Risks Threshold: Would the Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? 100 6/2/2020 Finding: No impact. (Appendix A [Initial Study], p. 4-69.) Explanation: The project does not require the installation or maintenance of associated infrastructure (including roads, fuel breaks, emergency water sources, power lines, or other utilities) that would exacerbate fire risk or that would result in impacts to the environment. Although the Project includes proposed internal circulation routes within the development, the Project does not include any changes to public or private roadways that would that would exacerbate fire risk or that would result in impacts to the environment. Although utility improvements, including natural gas, electricity/telecommunications, domestic water, sanitary sewer, and storm drain lines, proposed as part of the Project would be extended throughout the Project site, these utility improvements would be underground and would not exacerbate fire risk. Project design and implementation of utility improvements would be reviewed and approved by the City's Public Works Department as part of the Project approval process to ensure the proposed Project is compliant with all applicable design standards and regulations. Further, the Project site is not located in or near state responsibility areas or lands classified as VHFHSZ. Therefore, the proposed Project would not include infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities), that would exacerbate fire risk or that would result in impacts to the environment. No mitigation would be required. (Appendix A [Initial Study], pp. 4-68 through 4-69.) 4. Runoff Risks Threshold: Would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes? Findinq: Less than significant impact. (Appendix A [Initial Study], p. 4-69.) Ex lanatioiz: In its existing condition, the Project site is relatively flat with no slopes present on the site. According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), the Project site is within the AO Zone, which includes areas subject to inundation by 1 -percent -annual -chance shallow flooding (usually sheet flow on sloping terrain) at a depth of 1 ft. Although the Project site is located in an area that could be prone to flooding, the Project site is not located in or near state responsibility areas or lands classified as VHFHSZ. The nearest land classified as a VHFHSZ is located approximately 0.5 mile southeast of the Project site. Overall, due to the Project site's distance from the nearest VHFHSZ, risks associated with wildfires are considered less than 101 6/2/2020 significant. Further, the Project site is not within an earthquake induced landslide zone and is not located within an area subject to potential seismic slope instability. Therefore, downslope flooding as a result of runoff, post -fire slope instability, or drainage changes are unlikely to occur at the site, and no mitigation would be required. (Appendix A [Initial Study], p. 4-69.) SECTION III IMPACTS THAT ARE LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED The City Council hereby finds that Mitigation Measures have been identified in the EIR and these Findings that will avoid or substantially lessen the following potentially significant environmental impacts to a less than significant level. The potentially significant impacts, and the Mitigation Measures that will reduce them to a less than significant level, are as follows: A. AESTHETIC 1. Light and Glare Threshold: Would the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.1-14.) Explanation: Spill light occurs when lighting standards, 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. The spillover of light onto adjacent properties has the potential to interfere with certain activities, including vision, sleep, privacy, and general enjoyment of the natural nighttime condition. Light sensitive uses include residential, some commercial and institutional uses, and, in some situations, natural areas. Changes in nighttime lighting may become significant if a proposed Project substantially increases ambient lighting conditions beyond its property line and project lighting routinely spills over into adjacent light-sensitive land uses areas. Section 9-3.529 of the City's Municipal Code includes lighting regulations related to minimum and maximum illumination of parking facilities, as well as lighting design standards for exterior lighting displays, parking lots, and pedestrian sidewalks. 102 6/2/2020 Reflective light (glare) is the result of sunlight or artificial light reflecting from finished surfaces (e.g., window glass) or other reflective materials. Glass and other materials can have many different reflectance characteristics. Buildings constructed of highly reflective materials from which the sun reflects at a low angle commonly cause adverse glare. Reflective light is common in urban areas. Glare generally does not result in the illumination of off-site locations but results in a visible source of light viewable from a distance. Currently, there are no existing sources of light or glare emanating from the undeveloped Project site. Existing sources of light in the Project vicinity include headlights from vehicles on nearby roadways; lighting from the residential mobile home park to the north; and pole -mounted lighting in parking areas of adjacent developments. Sensitive land uses in the vicinity of the Project site include the mobile home park to the north and residences and the San Juan Creek Trail to the west. Short-term construction activities would occur primarily during daylight hours; however, construction activities may require periodic nighttime lighting. Any construction -related illumination during evening or nighttime hours would be shielded to the extent feasible and would consist of the minimal lighting required for safety and security purposes and would only occur on a temporary and as - needed basis. Due to its limited scope and duration, light generated during project construction would not substantially alter the character of off-site areas surrounding the construction area, or interfere with the performance of an off-site activity. Therefore, construction lighting impacts would be less than significant, and no mitigation would be required. The proposed Project would introduce new sources of light to the Project site that are typical of commercial uses. Outdoor lighting proposed as part of the Project would include wall -mounted lighting, pole -mounted street and parking lot lights, and security lighting along pathways. The proposed Project would include lighting with similar intensity and glare produced by street light fixtures within adjacent developments. Lighting would be limited to on-site sources and be directed downward onto the Project site and shielded to minimize overspill and glare to adjacent properties in compliance with the City's Lighting Standards (Municipal Code Section 9- 3.529). Although the proposed Project is not anticipated to incorporate design features that would result in excessive lighting or the generation of glare on the site, lighting plans are subject to City review and approval as part of the site plan review process. 103 6/2/2020 Mitigation Measures AES -1 and AES -2 require the Project Applicant to prepare a lighting plan and photometric study for review and approval by the City's Development Services Department (refer to Section 4.1.8 of the Draft EIR). These mitigation measures are intended to ensure that new sources of light and glare do not impact adjacent land uses that nighttime lighting is limited to that necessary for security, and that lighting is shielded to reduce glare and spill lighting effects on adjacent sensitive uses. A comprehensive lighting plan would illustrate the final locations for parking lot lights, walkway lights, and landscaping lights and demonstrate consistency with the City's Municipal Code. Implementation of Mitigation Measures AES -1 and AES -2 would ensure that impacts associated with new lighting would remain less than significant. (Draft EIR, pp. 4.1-12 through 4.1-13.) Mitigation Measures MM AES -1 Comprehensive Lighting Plan. Prior to issuance of any building permits, the Project Applicant shall prepare a comprehensive lighting plan for review and approval by the City of San Juan Capistrano (City) Development Services Director and/or the City's Design Review Committee, or designee. The lighting plan shall be prepared by a qualified lighting engineer and shall be in compliance with applicable standards of the City's Municipal Code. The lighting plan shall address all aspects of lighting, including infrastructure, on-site driveways, safety, signage, and promotional lighting, if any. The lighting plan shall include, but not be limited to, the following, as determined by the lighting engineer: Exterior on-site lighting shall be shielded and confined within site boundaries. • No direct rays or glare are permitted to shine onto public streets or adjacent sites. ■ "Walpak" type fixtures are not permitted. ■ Parking area lighting shall include cut-off fixtures, and light standards shall not exceed 20 feet in height. • Lighting fixtures that blink, flash, or emit unusual high intensity or brightness are not permitted. ■ The site shall not be excessively illuminated based on the illumination recommendations of the Illuminating Engineering Society of North America, or, if, in the opinion of the City Development Services Director, or designee, the illumination creates an unacceptable negative impact on surrounding land 104 6/2/2020 uses or environmental resources. The City Development Services Director, or designee, may order the dimming of light sources or other remediation upon finding that the site is excessively illuminated. MM AES -2 Photometric Study. Prior to the issuance of any building permits, a Final Photometric Study shall be prepared by the Project Applicant in conjunction with a Final Lighting Plan for approval by the City Development Services Director, or designee. Mitigation Measures AES -1 and AES -2 would reduce potential impacts to excessive lighting and/or the generation of glare on the Project site to a less than significant level. No significant unavoidable impacts related to aesthetics would occur with implementation of these measures. After mitigation has been implemented, all anticipated impacts related to aesthetics would be considered less than significant. (Draft EIR, p. 4.1-14.) B. BIOLOGICAL RESOURCES 1. Sensitive Species Threshold: Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.3-10.) Explanation:_ The approximately 17 -acre undeveloped Project site is currently characterized by an undeveloped gravel parking lot and ruderal vegetation. The Project site is located within an area that is covered by the OCSSHCP, but is located in an area identified as "developed" and is outside of the designated habitat reserve. Because the Project site is located outside the boundaries of the designated habitat reserve, OCSSHCP regulatory coverage is not provided for activities associated with the proposed Project. Furthermore, any project activities that may result in the "take" of sensitive species and their habitats would be subject to FESA Section 4(d) or Section 10 permits, Section 7 consultation, a CDFW Section 1600 Streambed Alteration Agreement, and/or a Section 2081 CESA permit. The disturbed condition of the Project site is generally not suitable to support special -status species, and no known candidate, sensitive, or special -status species were observed inhabiting the Project site during the 2017 or 2018 field 105 6/2/2020 surveys. However, three special -status plant species and six special -status animal species have low to moderate potential to occur on the Project site, as further discussed below. Special -Status Plant Species. The proposed Project would involve the grading of the entire Project site and removal of all existing vegetation. The Biological Technical Report determined that three special -status plant species (Catalina mariposa lily, cliff malacothrix, and Coulter's matilija poppy) have a low potential to occur on the southeastern portion of the Project site in the small patches of California sagebrush scrub (Artemesia Califomica Shrubland Alliance). However, none of these three species have been documented within 5 miles of the Project site. Furthermore, the Project site provides low -quality potential habitat for the three special - status species. Therefore, the removal of the potential habitat is not expected to contribute substantially to the overall decline of these species. Additionally, no special - status plant species have a moderate to high potential to occur on the site. Therefore, the Project impacts to special status plant species would be less than significant. Special -Status Animal Species. Of the various special - status wildlife species identified in the literature searches undertaken in support of the Biological Technical Report, six were determined to have a low -to -moderate potential to occur on the Project site. Two of these species (burrowing owl and California horned lark) were identified to have a low to moderate potential to occur during the 2017 field survey, but were presumed absent during the 2018 field survey due to a change in habitat on the Project site. Because these two species would no longer have a potential to occur on the Project site, only four special -status wildlife species (white- tailed kite, coastal California gnatcatcher, western red bat, and San Diego desert woodrat) have a low -to -moderate potential to occur on the site. • White -Tailed Kite: White-tailed kite is a CDFW Fully Protected species, and is a covered species under the OCSSHCP. This species was determined to have a low potential to occur on the Project site, and may nest in the large eucalyptus trees located within 500 feet of the eastern border of the Project site on the other side of the LOSSAN rail corridor. Although white-tailed kite is not expected to nest on the Project site itself, indirect impacts may occur from construction noise and vibration if the species nest in 106 6/2/2020 trees within 500 feet of the Project site. As specified in Mitigation Measure BI0-1, if construction activities with the potential to disrupt white-tailed kite are scheduled to occur during breeding season, a pre - construction nesting bird survey shall be conducted by a qualified biologist. With implementation of Mitigation Measure BI0-1, impacts to white-tailed kite would be less than significant. • Coastal California Gnatcatcher: Coastal California gnatcatcher is a threatened species under the FESA, a CDFW Species of Special Concern, and is a covered species under the OCSSHCP. Coastal California gnatcatcher was determined to have a moderate potential to occur on the Project site, and may use the Project site for foraging in the existing 0.3 acre of California sagebrush scrub. However, the California sagebrush scrub would be removed during grading of the Project site, as would all other existing vegetation. Additionally, construction noise and vibration from grading and vegetation removal may affect individual coastal California gnatcatchers. As specified in Mitigation Measure B1O-2, pre - construction surveys would be conducted for coastal California gnatcatcher within all areas of potential permanent and temporary disturbance. If coastal California gnatcatcher are observed foraging during preconstruction surveys, consultation between the City and project Applicant and the appropriate agency would be required. As specified in Mitigation Measure B1O-3, biological monitoring during vegetation clearing and construction activities would ensure that individual gnatcatchers are not present during vegetation removal. Once the vegetation removal has taken place, no additional impacts to coastal California gnatcatcher are anticipated to occur, and no further mitigation would be required. Furthermore, the removal of California sagebrush scrub is not expected to contribute to the decline of the coastal California gnatcatcher as designated critical habitat for the species exists within 0.25 mile of the Project site. With implementation of Mitigation Measures B1O-2 and B1O-3, impacts to coastal California gnatcatcher would be less than significant. • Western Red Bat: The Western red bat is a CDFW Species of Special Concern, and was determined to 107 6/2/2020 have a low potential to occur on the Project site. Currently, two existing red willow trees (Salix laevigata) are located on the Project site, which provide suitable year-round roosting habitat for western red bats. The two red willow trees would be removed during project construction, which may result in direct impacts to the western red bat, should they be using the trees for roosting. However, no record of the western red bat has been documented within 5 miles of the Project site. Additionally, the removal of the trees would not substantially contribute to the overall decline of the species. As specified in Mitigation Measure B1O-2, pre -construction surveys would be conducted for sensitive wildlife species, including the western red bat, within all areas of potential permanent and temporary disturbance, including the two existing red willow trees. If western red bats are observed during pre -construction surveys, biological monitoring would be required, as specified in Mitigation Measure 610-3. Therefore, with the implementation of Mitigation Measure B10- 2 and B1O-3, impacts to the western red bat would be less than significant. • San Diego Desert Woodrat: The San Diego desert woodrat is a CDFW Species of Special Concern, and was determined to have a moderate potential to occur on the Project site. Although the 0.3 acre of California sagebrush scrub on the Project site provides potential habitat for the San Diego desert woodrat, the quality of the habitat is low. Therefore, removal of the California sagebrush scrub would not contribute to the substantial decline of the species, and impacts to the San Diego desert woodrat would be less than significant. (Draft EIR, pp. 4.3-7 through 4.3-10.) Mitigation Measures MM BIO -1 Pre -Construction Surveys for Nesting Birds. Any development activities within the Project site shall be conducted during the non - breeding season for birds (approximately September 1 through February 15). This will avoid violations of the Migratory Bird Treaty Act (MBTA) and the California Fish and Game Code Sections 3503, 3503.5 and 3513. If activities with the potential to disrupt nesting birds, including the white-tailed kite, are scheduled to occur during the bird breeding season (February through August for raptors and 108 6/2/2020 March through August for songbirds), a pre -construction nesting bird survey shall be conducted by a qualified biologist. The project Applicant shall hire a qualified biologist to conduct a preconstruction presence/absence survey for nesting birds no more than 3 days prior to site disturbance and submit the survey results to the Director of the City of San Juan Capistrano (City) Development Services Department, or designee. If nesting birds are not detected, no further action is necessary. The nest surveys shall include the Project site and adjacent areas where project activities have the potential to cause nest failure. If no nesting birds are observed during the survey, site preparation and construction activities may begin. If nesting birds (including nesting raptors) are found to be present, then avoidance or minimization measures shall be undertaken in consultation with the California Department of Fish and Wildlife (CDFW) and prior to issuance of any grading or construction permits. Measures shall include establishment of an avoidance buffer until nesting has been completed. The width of the buffer will be determined by the Project biologist. Typically this is a minimum of 300 feet from the nest site in all directions (500 feet is typically recommended by CDFW for raptors), until the juveniles have fledged and there has been no evidence of a second attempt at nesting. The monitoring biologist will monitor the nest(s) during construction and document any findings to be confirmed by the Director of the City of San Juan Capistrano Development Services Department, or designee. MM BI0-2 Pre -Construction Sensitive Wildlife Surveys. The Project Applicant shall hire a qualified biologist to conduct pre -construction surveys for sensitive wildlife species within all areas of potential permanent and temporary disturbance. Preconstruction surveys shall take place a maximum of 14 days prior to the start of ground - disturbing activities. The pre -construction surveys shall take place regardless of breeding season timing and shall focus on identifying the presence of coastal California gnatcatcher and other special - status wildlife species potential to occur within the Project site. The Project biologist shall submit the survey results to the Director of the City of San Juan Capistrano Development Services Department, or designee. Should special -status species be identified during pre -construction surveys, the monitoring biologist shall develop suitable avoidance and minimization measures with the appropriate agency (i.e., USFWS, CDFW) for implementation prior to and/or during construction. If coastal California gnatcatcher is observed during pre -construction surveys, consultation between the City and project Applicant and the United States Fish and Wildlife Service (USFWS) is required. The consultation process shall identify mitigation measures to be implemented prior to and/or 109 6/2/2020 during construction activities for any coastal California gnatcatchers or other sensitive wildlife present. These measures include, but are not limited to, the following: If vegetation removal or other ground -disturbing activities are scheduled to occur during the coastal California gnatcatcher breeding season (February 15 through August 30), then all areas containing coastal sage scrub located outside of the Project impact area shall be identified with temporary fencing or other markers clearly visible to construction personnel. No project -related activities shall occur in the coastal sage scrub outside of the Project impact area. • A monitoring biologist that has been approved by USFWS, shall be on site during ground -disturbing activities, including the clearing of coastal sage scrub, within the Project impact area. The monitoring biologist shall perform a clearance sweep of the coastal sage scrub immediately prior to ground -disturbing activities to determine if coastal California gnatcatcher is occupying the coastal sage scrub within the Project impact area. If the species is present, then ground - disturbing activities shall not commence until the individual has left the Project impact area, as determined by the monitoring biologist. If California gnatcatcher is not observed during the clearance sweep, then ground -disturbing activities may commence. Once the vegetation removal has taken place, no additional impacts to coastal California gnatcatcher or other sensitive wildlife specifies are anticipated and no further measures would be required. MM BIO -3 Biological Monitoring. The Project Applicant shall hire a qualified biologist to monitor all vegetation clearing activities both during and outside of the breeding season. A biological monitor shall perform biological clearance surveys at the start of each work day that vegetation clearing takes place to minimize impacts on sensitive wildlife species. The monitor will be responsible for ensuring that impacts to sensitive species will be avoided to the fullest extent possible. The biological monitor shall be present during the initiation of vegetation clearing activities and their presence should continue as necessary to maintain protective measures and to monitor for species in harm's way. These protection measures may include redirecting wildlife or capturing and relocating wildlife to areas outside the work area. Any captured species shall be relocated out of harm's way to adjacent appropriate habitat that is outside of project impact areas. Biological monitoring shall take place until the Project site has been completely cleared of any vegetation. The monitoring biologist will document any findings to 110 6/2/2020 be confirmed by the Director of the City of San Juan Capistrano Development Services Department, or designee. Potential impacts to biological resources from the proposed Project would be mitigated to a less than significant level with implementation of Mitigation Measures B10-1, B10- 2, and B10-3. Therefore, the Project would have no significant and unavoidable adverse impacts related to biological resources. (Draft EIR, pp. 4.3-10 through 4.3-14.) C. CULTURAL RESOURCES 1. Archaeological Resources Threshold: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to State CEQA Guidelines, section 15064.5? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.4-5.) Explanation: The records search and field search did not identify any recorded archaeological resources on or in the immediate vicinity of the Project site. However, the Project site is located adjacent to San Juan Creek, and 1 mile from the coast in an area near recorded prehistoric and historic resources. The archaeological sensitivity of the Project vicinity is high, as indicated by the presence of numerous prehistoric archaeological sites along the east bank of San Juan Creek. However, these cultural resource sites are at a higher elevation than the Project area itself, which is on a low terrace directly adjacent to San Juan Creek, suggesting a slightly lower chance of cultural resource sites directly within the Project area which may reflect avoidance of areas along the creek that were likely to flood. As a result, it remains possible that buried, previously unrecorded cultural resources could be present in native soils on the Project site and disturbed during project construction. Mitigation Measure CUL -1 is proposed and requires monitoring by both a qualified archaeologist and a Native American monitor. The measure includes procedures for recovering any significant or unique archaeological resource and for preparation of a report that documents any cultural resource recovery at the Project site. All procedures conducted as part of Mitigation Measure CUL -1 would comply with the applicable provisions for the management of historic, archaeological, and paleontological resources as described in City Council Policy 601. With implementation of Mitigation Measure CUL -1, impacts to previously unrecorded cultural 111 6/2/2020 resources would be less than significant. (Draft EIR, pp. 4.4-5 through 4.4-6.) Mitigation Measures MM CULA Cultural Resources Monitoring and Accidental Discovery. Prior to the issuance of grading permits, and in adherence to the recommendations of the cultural resources survey, the Project Applicant shall retain, with approval of the City of San Juan Capistrano (City) Development Services Director, or designee, a qualified archaeological monitor. A monitoring plan should be prepared by the archaeologist and implemented upon approval by the City. Prior to issuance of grading permits, the Project Applicant, with City approval, shall also retain a Native American monitor to be selected by the City after consultation with interested tribal and Native American representatives. Both monitors shall be present on the Project site during ground -disturbing activities to monitor rough and finish grading, excavation, and other ground -disturbing activities in the native soils. Because no cultural resources were identified on the Project site, both monitors are not required to be present on a full-time basis, but shall spot check ground -disturbing activities to ensure that no cultural resources are impacted during construction activities. If cultural materials are discovered during site preparation, grading, or excavation, the construction contractor shall divert all earthmoving activity within and around the immediate discovery area until a qualified archaeologist can assess the nature and significance of the find. Project personnel shall not collect or move any archaeological materials or human remains and associated materials. To the extent feasible, project activities shall avoid these deposits. Where avoidance is not feasible, the archaeological deposits shall be evaluated for their eligibility for listing on the California Register of Historical Resources. If the deposits are not eligible, avoidance is not necessary. If the deposits are eligible, adverse effects on the deposits must be avoided, or such effects must be mitigated. Mitigation can include, but is not necessarily limited to: excavation of the deposit in accordance with a data recovery plan (see California Code of Regulations [CCR] Title 4(3) Section 5126.4(b)(3)(C)) and standard archaeological field methods and procedures; laboratory and technical analyses of recovered archaeological materials; production of a report detailing the methods, findings, and significance of the archaeological site and associated materials; curation of archaeological materials at an appropriate facility for future research and/or display; an interpretive display of recovered archaeological materials at a local school, museum, or library; and public lectures at local schools and/or 112 6/2/2020 historical societies on the findings and significance of the site and recovered archaeological materials. The City Development Services Director, or designee, shall be responsible for reviewing any reports produced by the archaeologist to determine the appropriateness and adequacy of the findings and recommendations. 2. Human Remains Threshold: Would the Project disturb any human remains, including those interred outside of dedicated cemeteries? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.4-6.) Explanation: Although no human remains are known to be on the Project site or are anticipated to be discovered during project construction, the archaeological sensitivity of the Project vicinity is high. There is always a possibility of encountering unanticipated cultural resources, including human remains. Precautionary mitigation is required to ensure that the proposed Project does not impact or disturb any human remains. Mitigation Measure CUL -2 requires compliance with CCR Section 15064.5(e) in the unlikely event that human remains are encountered during project grading. Upon discovery of the remains, the Orange County (County) Coroner would be notified immediately, and no further disturbance would occur until the County Coroner makes a determination of origin and disposition pursuant to PRC Section 5097.98. If the remains are determined to be Native American, the County Coroner would notify the NAHC, which would then determine and notify the MLD. With permission from the City, the MLD would complete inspection within 48 hours of notification by the NAHC. Implementation of Mitigation Measure CUL -2 would reduce potential impacts related to the discovery of human remains on the Project site to a less than significant level, and no additional mitigation is required. (Draft EIR, p. 4.4-6.) Mitiaation Measures MM CUL -2 Human Remains. Consistent with the requirements of CCR Section 15064.5(e), if human remains are encountered during site disturbance, grading, or other construction activities on the Project site, the construction contractor shall halt work within 25 feet of the discovery; all work within 25 feet of the discovery shall be redirected and the Orange County (County) Coroner notified 113 6/2/2020 immediately. No further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. If the remains are determined to be Native American, the County Coroner shall notify the Native American Heritage Commission (NAHC), which will determine and notify a Most Likely Descendant (MLD). With the permission of the City, the MLD may inspect the site of the discovery. The MLD shall complete the inspection within 48 hours of notification by the NAHC. The MLD may recommend scientific removal and nondestructive analysis of human remains and items associated with Native American burials. Consistent with CCR Section 15064.5(d), if the remains are determined to be Native American and an MLD is notified, the City shall consult with the MLD identified by the NAHC to develop an agreement for the treatment and disposition of the remains. Upon completion of the assessment, the consulting archaeologist shall prepare a report documenting the methods and results and provide recommendations regarding the treatment of the human remains and any associated cultural materials, as appropriate, and in coordination with the recommendations of the MLD. The report shall be submitted to the City Development Services Director, or designee, and the South Central Coastal Information Center. The City Development Services Director, or designee, shall be responsible for reviewing any reports produced by the archaeologist to determine the appropriateness and adequacy of the findings and recommendations. D. GEOLOGY AND SOILS 1. (b) Strong Seismic Ground Shaking Threshold: Would the Project expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.6-10.) Explanation: As with all of Southern California, the Project site is subject to strong ground motion resulting from earthquakes on nearby faults. There are several faults near the Project site that are capable of producing strong ground motion, including the Newport- Ing lewood- Rose Canyon Fault and the San Joaquin Hills Fault. During an earthquake along any of these faults, seismically induced ground shaking would be expected to occur. The severity of the shaking 114 6/2/2020 would be influenced by the distance of the site to the seismic source, the soil conditions, and the depth to groundwater. The USGS Unified Hazard Tool was used in the Geotechnical Investigation in order to determine how seismicity would affect the Project site. Based on the site-specific evaluation that was performed, the peak horizontal ground acceleration for the Project site was calculated to be approximately 0.55 g (acceleration due to gravity) with a two percent probability of exceedance in 50 years (recurrence interval of 2,475 years). These accelerations are consistent with other sites in this region of central California and indicate that strong seismic ground shaking generated by seismic activity is considered a potentially significant impact that may affect the proposed Project. Mitigation Measures GEO-1 and GEO-2 require the City to comply with the recommendations of the Project Geotechnical Investigation and the most current CBC, which stipulates appropriate seismic design provisions that shall be implemented with project design and construction. With implementation of Mitigation Measures GEO-1 and GEO-2, potential project impacts related to seismic ground shaking would be reduced to a less than significant level. (Draft EIR, pp. 4.6-9 through 4.6-10.) Mitiaation Measures MM GEO-1 Incorporation of and Compliance with the Recommendations in the Geotechnical Investigation. All grading operations and construction shall be conducted in conformance with the recommendations included in the geotechnical report on the proposed Project site that has been prepared by Willdan Engineering Geotechnical Group, titled Geotechnical Investigation Report and Response to Third Party Review, Proposed Ganahl Lumber Facility Development San Juan Capistrano, California (Geotechnical Investigation) (November 2018). Design, grading, and construction shall be performed in accordance with the requirements of the City of San Juan Capistrano (City) Building Code and the California Building Code (CBC) applicable at the time of grading, appropriate local grading regulations, and the recommendations of the Project geotechnical consultant as summarized in a final written report, subject to review by the Director of the City of San Juan Capistrano Development Services Department, or designee, prior to commencement of grading activities. Recommendations in the Geotechnical Investigation are summarized below. 115 6/2/2020 • Site Grading/Earthwork. Prior to grading activities on the site, organics and debris shall be removed and hauled off- site. Undocumented fill within the Project limits shall be over - excavated to a minimum depth of 12 feet (ft). The bottom of the excavated area shall be underlain by a layer of filter fabric (which will prevent contamination of crushed aggregate from underlying fine soils) and overlain by a minimum of 2 ft of crushed rock and a geogrid layer(which will minimize the manifestation of vertical settlements to the surface). The excavated layer shall be backfilled with engineered fill, which shall be compacted to at least 90 percent. Compaction shall be verified by observation, probing, and testing by a Geotechnical Consultant. Fill Material. On-site soils with an Expansion Index (EI) less than 35 and free of organic materials, debris, and cobbles larger than 3 inches may be used for backfilling. Imported granular soils may be used in compacted fills within the Project limits. All imported soil shall contain binder material. Imported materials shall also be non -expansive and free of organic materials, debris, and cobbles larger than 3 inches, with no more than 25 percent passing No. 200 Sieve. All fill materials within the upper 2 ft shall be free of particles greater than 2 inches in size. A bulk sample of import material, weighing at least 30 pounds, shall be submitted to the Geotechnical Consultant for approval at least 48 hours prior to fill operations. Utility Trenching. Bedding materials consisting of sand, gravel, or crushed aggregate shall be used to backfill around utility pipes. On-site soils having a Sand Equivalent (SE) of 30 or greater can also be used as bedding material. Prior to placing pipes, the pipe trench subgrade shall be observed by the Geotechnical Consultant. If exposed subgrade is loose or unstable, unsuitable subgrade shall be excavated and replaced with bedding material. Trenches in pavement areas shall be capped with at least 1 ft of compacted, on-site soil and shall be compacted to at least 95 percent relative compaction. • Temporary Excavations. All temporary excavations shall be properly sloped or shored. Excavation of 3.5 ft or less in depth may be performed with vertical sidewalls. Deeper excavations up to a depth of 10 ft can be accomplished with Occupational Safety and Health Administration (OSHA) requirements for Type C soils and may be laid back 1 H: 1.5V 116 6/2/2020 gradient, or 1H:1V upon review by the Geotechnical Consultant. ■ Shoring. Shoring systems feasible for the site are expected to include cantilever shoring, such as soldier piles. All shoring shall be designed in accordance with the latest edition of the Trenching and Shoring Manual (Caltrans 2011), and shall be approved by the Geotechnical Consultant. A licensed surveyor shall be retained to establish monuments on the shoring and surrounding area. These monuments shall be monitored for movement during construction. ■ Spread/Strip Footing Foundations. Upon completion of the grading (cutting) required to establish the proposed building pad elevations, the proposed structures may be supported by a spread/strip footing foundation system. Spread/strip footings shall be at least 24 and 18 inches wide, respectively, and embedded at least 18 inches below the lowest adjacent grade in the engineered fill. The slab -on - grade should be at least 5 inches thick and reinforced with rebar. Footings shall be deepened as necessary in order to maintain adequate support for the foundations adjacent to utility trenches. • Matt Foundations: Upon completion of the grading (cutting) required to establish the proposed building pad elevations, the proposed structures may be supported by a matt foundation system in areas where settlements cannot be tolerated by spread/strip footings. The mat should be at least 10 inches thick and embedded at least 18 inches below the lowest adjacent grade in the engineered fill. ■ Concrete Flatworks. Frequent construction or control joints shall be provided in all concrete slabs where cracking is objectionable. Contraction or weakened plane joints shall extend deeper than one-quarter of the slab thickness. Control joints shall be spaced a minimum of 10 ft intervals. Exterior concrete slab-ongrade may be subjected to drying due to the fluctuation of moisture content in subgrade soils. Deepened edge sections will aid in reducing the potential for the shrinkage and swelling of underlying soils. • Retaining Walls. The proposed development is expected to require various types of earth -retaining structures: freestanding cantilever retaining wall, temporary shoring, and below grade walls for several of the proposed 117 6/2/2020 structures. In general, retaining structures planned at the site shall be backfilled with compacted soil and be constructed with a backdrain. ■ Corrosive Soils. A representative bulk sample of soils in contact with concrete and pipes shall be collected and tested or pH, minimum resistivity, soluble chloride content, and soluble sulfate content. The test results shall be used to determine the chemical properties of on-site soils and appropriate recommendations. Recommendations for corrosion protection may include, but are not limited to, sacrificial metal, the use of protective coatings, and/or cathodic protection. Geotechnical Review and Future Testing. Additional site testing and final design evaluation shall be conducted by the Project Geotechnical Consultant to refine and enhance these recommendations. Grading plan review shall also be conducted by the Geotechnical Consultant and the Director of the City of San Juan Capistrano Development Services Department, or designee, prior to the start of grading to verify that the recommendations developed during the geotechnical design evaluation have been appropriately incorporated into the Project plans. Final design shall be based on testing and analyses of the near -surface soils following the completion of grading. Design, grading, and construction shall be conducted in accordance with the specifications of the Geotechnical Consultant as summarized in a final report based on the CBC applicable at the time of grading and building and the City of San Juan Capistrano Building Code. On-site inspection during grading shall be conducted by the Geotechnical Consultant and the City Building Official to ensure compliance with geotechnical specifications as incorporated into project plans. MM GEO-2 California Building Code Compliance and Seismic Standards. Structures and retaining walls shall be designed in accordance with the seismic parameters presented in the Geotechnical Investigation (Willdan Engineering Geotechnical Group, November 2018) and applicable sections of Section 1613 of the 2007 California Building Code (CBC). Prior to issuance of building permits for planned structures, the Project soils engineer and the Director of the San Juan Capistrano Development Services Department, or designee, shall review building plans to verify that structural design conforms to the recommendations of 118 6/2/2020 the Geotechnical Investigation and the City of San Juan Capistrano Building Code. 1. (c) Seismic -Related Ground Failure, Including Liquefaction Threshold: Would the Project expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving seismic -related ground failure, including liquefaction? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.6-10.) Explanation: Liquefaction commonly occurs when three conditions are present simultaneously: (1) high groundwater; (2) relatively loose, cohesionless (sandy) soil; and (3) earthquake -generated seismic waves. The Project site is located with a State -designated Liquefaction Hazard Zone for the Dana Point Quadrangle. In addition, testing performed as part of the Geotechnical Investigation found that sand and sandy silt layers within alluvial deposits on the site would likely liquefy during earthquake. Mitigation Measures GEO-1 and GEO- 2 require the City to comply with the recommendations of the Project Geotechnical Investigation and the most current CBC, which stipulates appropriate design provisions (including provisions related to foundation design) that shall be implemented with project design and construction. With implementation of Mitigation Measures GEO-1 and GEO-2, potential project impacts related to seismically induced ground failure, including liquefaction, would be reduced to a less than significant level. (Draft EIR, p. 4.6-10.) 2. Unstable Soils Threshold: Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, pp. 4.6-11 through 4.6-13.) Explanation'. 119 6/2/2020 Landslides. Both the existing Project site and the surrounding area are relatively flat and are not subject to slope instability or landslides. (Appendix A [Initial Study], p. 4-20.) Subsidence. Subsidence is the sinking of the land surface where deep soils are present. Subsidence of deep soil deposits typically occurs as a result of oil, gas, and water production, which causes loss of pore pressure as the weight compacts the underlying sediments. It is estimated that the groundwater on the Project site was encountered at depth of approximately 18 to 22 ft below ground surface. However, no pumping of petroleum reserves or groundwater would occur as a result of the proposed Project. As such, subsidence is not expected to occur on the Project site or to affect development of the proposed Project. Therefore, impacts related to subsidence would be less than significant, and no mitigation would be required. (Appendix A [Initial Study], p. 4-20.) Slope Stability. No existing landslides are present on or adjacent to the property. Geologic mapping for the site does not indicate that the site is susceptible to landslide. In addition, the Project site is in a generally flat area with no evidence of historic landslides. Therefore, the potential for seismically induced landslides on site is considered low. Due to the topography of the Project site and the design of the proposed Project, grading would entail cut -and -fill slopes, and construction of earth -retaining structures, such as freestanding cantilever retaining walls and below -grade walls would be necessary in some areas. In addition, shoring would be required during excavation. Unstable cut -and -fill slopes and could create significant short-term and long-term hazards. Mitigation Measure GEO-1 requires planned grading and shoring to conform to the recommendations of the Geotechnical Investigation, which contains specific recommendations for addressing potential slope instability. With implementation of these recommendations, potential impacts related to slope instability would be reduced below a level of significance. (Draft EIR, p. 4.6-11.) Unsuitable Soils. Corrosive Soils and Soluble Sulfate Content. Corrosive soils contain constituents or physical characteristics that attack concrete (water-soluble sulfates) and/or ferrous metals (chlorides, ammonia, nitrates, low pH levels, and low electrical resistivity). Corrosive soils could potentially create a significant hazard to the Project by 120 6/2/2020 weakening the structural integrity of the concrete and metal used to construct the building and could potentially lead to structural instability. Structural damage and foundation instability caused by corrosive soils is a potentially significant impact. As required by Mitigation Measure GEO-1, on-site soils anticipated to come into contact with pipes or concrete on the site shall be tested for pH, minimum resistivity, soluble chloride content, and soluble sulfate content. Where corrosive soils are identified, corrosion protection measures shall be implemented. Corrosion protection may include, but is not limited to, sacrificial metal, the use of protective coatings, and/or cathodic protection. With implementation of Mitigation Measure GEO-1, potential impacts related to corrosive soils would be reduced to a less than significant level. Settlement Potential. The amount of settlement for a site is dependent on the thickness of design fills, the loading conditions, and the nature of the native materials underlying the fill. Potential ground settlement may be separated into three types: (1) hydroconsolidation of alluvium left in place above the water table, (2) consolidation settlement of compressible alluvium left in place below the water table, and (3) liquefaction - induced settlement of a few loose, granular layers below the water table. The site is underlain by sand and sandy silt layers within alluvial deposits, which are likely to liquefy during an earthquake. As such, these layers will likely experience a loss of shear strength resulting in ground deformation and settlement. In total, the Geotechnical Investigation found that seismic settlements due to liquefaction could be up to 2 inches on the Project site. Compliance with the recommendations contained in the Geotechnical Investigation for the proposed Project, including those related to earthwork activities and foundation design, would be required reduce potential impacts related to ground settlement. Implementation of Mitigation Measure GEO-1 would reduce potential impacts with respect to ground settlement to a less than significant level. Subsidence. 121 6/2/2020 The phenomenon of widespread land sinking, or subsidence, is generally related to substantial overpumping of groundwater or petroleum reserves from deep underground reservoirs. Overpumping and excessive groundwater withdrawal have not occurred in the Project area. In addition, the Project does not have an oil, gas, or water pump on site and none are located near the site and has not been used for the extraction of either resource. Subsidence is therefore not considered a potential constraint or a potentially significant impact of the Project, and no mitigation is required. Lateral Spreadinq. Lateral spreading typically occurs as a form of horizontal displacement of relatively flat -lying alluvial material toward an open or "unconfined" face such as an open body of water, channel, or excavation. In soils, this movement is generally due to failure along a weak plane and may often be associated with liquefaction. According to the Geotechnical Investigation, lateral spreading at the Project site is not a concern because the proposed final ground surface would be relatively flat and the recently constructed sheet pile system along the San Juan Creek levee (a separate project), which penetrates below the lowest liquefiable layer identified within the Project site for protection of the creek levee, would prevent lateral motion from occurring. Therefore, the soils on the Project site are not subject to lateral spreading. Therefore, lateral spreading is not considered a potential constraint or a potentially significant impact of the Project, and no mitigation is required. (Draft EIR, pp. 4.6-11 through 4.6-13.) 3. Expansive Soils Threshold: Would the Project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code, creating substantial risks to life or property? Fin_ _ding: Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.6-13.) Explanation: Expansive soils contain types of clay minerals that occupy considerably more volume when they are wet or hydrated than when they are dry or dehydrated. Volume changes associated with changes in the moisture content of near -surface expansive soils 122 6/2/2020 can cause uplift or heave of the ground when they become wet or, less commonly, cause settlement when they dry out. Upper layers of soil on the site consist of Artificial Fill. The expansion potential for on-site soils is unknown at this time; however, undocumented fill on the site includes clay at varying moisture contents, and as such, may be potentially expansive. The Geotechnical Investigation contains specific construction recommendations to reduce project impacts associated with expansive soils to a less than significant level. Mitigation Measure GEO-1 incorporates the recommendations in the Geotechnical Investigation related to expansive soils, including a requirement that all imported materials be non -expansive. Therefore, adherence to Mitigation Measure GEO-1 will reduce project impacts related to expansive soils to a less than significant level. (Draft EIR, p. 4.6- 13.) 4. Paleontological Resources Threshold- Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, pp. 4.6-13 through 4.6-14.) Explanation: The Project site is located on sediments mapped as Quaternary Alluvium, but is underlain by older estuarine deposits of the San Juan Creek floodplain. There are no known localities on the Project site but, based on the locality search conducted for the proposed Project, sensitive sediments that may contain fossil remains do exist within the Project areas. As such, there is the potential to encounter paleontological resources during any ground -disturbing activities for the proposed Project. Mitigation is required to reduce potential adverse impacts to unknown (buried) paleontological resources. Mitigation Measure GEO-3 requires the Project Applicant to prepare a Paleontological Resources Assessment to evaluate the potential for project implementation to significantly impact unknown paleontological resources on the site. In the event that the Paleontological Resources Assessment does not identify the potential for the Project to impact such resources, no further action or mitigation is required. In the event that the Paleontological Resources Assessment identifies a low potential for the Project to impact paleontological resources, the Developer/project Applicant shall retain a paleontologist on an on-call basis to address any unanticipated discoveries. If the Paleontological Resources Assessment determines that paleontological resources may be 123 6/2/2020 impacted by project development, a Paleontological Resources Impact Mitigation Program (PRIMP) shall be prepared, and paleontological monitoring, fossil collection and treatment (if necessary), and preparation of a final monitoring report shall occur as described in Mitigation Measure GEO-4. Implementation of Mitigation Measures GEO-3 and GEO-4 would reduce potential impacts to unknown paleontological resources to less than significant, and no additional mitigation is required. The proposed Project would result in potentially significant impacts with respect to strong seismic ground shaking, ground failure (including liquefaction), slope stability, corrosive soils, ground settlement, expansive soils, and the destruction of paleontological resources without the implementation of applicable mitigation measures. (Draft EIR, pp. 4.6-13 through 4.6-14.) Mitigation Measures MM GEO-3 Paleontological Resources Assessment. In accordance with City of San Juan Capistrano Council Policy 601, a paleontologist certified by the County of Orange shall prepare a Paleontological Assessment that includes the following information: a clear map delineating the Project boundaries, the results of a field survey of the Project area, the results of background research and sources for that background information, criteria for evaluation of paleontological sensitivity of the property, and a determination of whether development of the Project has the potential to impact paleontological resources. If the Paleontological Resources Assessment determines that project activities will not impact paleontological resources, no further paleontological resource impact mitigation is required. If the Paleontological Resources Assessment determines that there is a low possibility for project activities to impact paleontological resources, the Developer/project Applicant shall retain a paleontologist on an on-call basis to address any unanticipated discoveries. If the Paleontological Resources Assessment determines that paleontological resources may be impacted by project development, a Paleontological Resources Impact Mitigation Program shall be prepared, and paleontological monitoring, fossil collection and treatment (if necessary), and preparation of a final monitoring report shall occur as described in Mitigation Measure GEO-4. MM GEO-4 Paleontological Resources Impact Mitigation Program. In the event the Project specific Paleontological Resources Assessment determines that paleontological resources may be impacted by project development, a Paleontological Resources Impact Mitigation Program (PRIMP) shall be prepared prior to 124 6/2/2020 commencement of any grading activity on site, and approved by the Director of Planning, or designee. The PRIMP shall be prepared by a paleontologist who is listed on the County of Orange list of certified paleontologists, and shall include the methods that will be used to protect paleontological resources that may exist within the Project site, as well as procedures for monitoring, fossil preparation and identification, curation into a repository, and preparation of a report at the conclusion of grading. The PRIMP shall be consistent with the guidelines of the Society of Vertebrate Paleontology (SVP) (2010). The paleontologist or paleontological monitor shall attend one pre - construction meeting in order to explain the mitigation measures associated with the Project, the potential for encountering paleontological resources, and the types of resources that may be found. Ground -disturbing activities in deposits with high paleontological sensitivity shall be monitored by a paleontological monitor following the PRIMP. Spot check monitoring is required for ground disturbance in deposits with low paleontological sensitivity, and no paleontological monitoring is required for ground disturbance in deposits with no paleontological sensitivity. The monitor shall be equipped to salvage fossils and/or matrix samples as they are unearthed in order to avoid construction delays. The monitor shall be empowered to temporarily halt or divert equipment in the area of the find in order to allow removal of abundant or large specimens. In the event that paleontological resources are encountered when a paleontological monitor is not present, work in the immediate area of the find shall be redirected and a paleontologist shall be contacted to assess the find for significance. Sediments shall be occasionally be spot -screened through one- eighth to one twentieth- inch mesh screens to determine whether microfossils exist. If microfossils are encountered, additional sediment samples (up to 6,000 pounds) shall be collected and processed through one -twentieth -inch mesh screens to recover additional fossils. Collected resources shall be prepared to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into the permanent collections of a scientific institution. At the conclusion of the monitoring program, a report of findings shall be prepared to document the results of the monitoring program. When submitted to the City of San Juan Capistrano 125 6/2/2020 Director of Development Services, inventory would signify completion impacts to paleontological resources. E. HAZARDS AND HAZARDOUS MATERIALS 1. Accident or Upset or designee, the report and of the program to mitigate Threshold: Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.8-9.) Explanation: The purpose of the Phase I ESA is to evaluate the Project site for potential Recognized Environmental Concerns (RECs) that may be present and/or off-site conditions that may impact the Project site. According to the Phase I ESA, no RECs were observed on the Project site during the site survey. Historically, the Project site and surrounding properties were undeveloped until as early as 1938. The Project site has remained undeveloped. Review of aerial photography of the Project site and surrounding area depict the following: in 1967, the channelization of the San Juan Creek immediately west of the Project site; in 1977, the development of the mobile home park immediately north of the Project site; in 1994, the construction of Stonehill Drive along the Project site's southern boundary; and from 2005 to 2012, the development of multiple automobile dealerships east of the Project site beyond the railroad. Based on this information, historic uses of the surrounding properties are not likely to have resulted in the potential for current adverse impacts to the Project site's subsurface. According to the EDR Report, the Project site was not identified on any federal or State regulatory databases. Four Resource Conservation and Recovery Act — Small Quantity Generators (RCRA-SQG) sites39 were identified within the American Society of Testing and Materials (ASTM) search radii,40 but none of the four 39 The Resource Conservation and Recovery Act —Small Quantity Generators (RCRA- SQG) database includes information on sites which generate, transport, store, treat and/or dispose of hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA). Small quantity generators (SQGs) generate between 100 kg and 1,000 kg of hazardous waste per month. 40 Radii distances vary by database and are in accordance with American Society of Testing and Materials (ASTM) standards. 126 6/2/2020 sites listed include violations. Other sites identified within the ASTM search radii include the following listings: one EnviroStor Database (ENVIROSTOR), three Underground Storage Tanks (UST), five Leaking Underground Storage Tanks (LUST), one Statewide Environmental Evaluation and Planning System (SWEEPS), one Facility Inventory Database (CA FID UST), one Historical UST, three Hazardous Waste and Substance Sites List (Historic CORTESE), seven Aboveground Storage Tanks (AST), and one Spills, Leaks, Investigations, and Cleanups (SLIC). The Phase I ESA concluded that the potential for environmental impact to the Project site from any of the off-site facilities identified in the EDR Report appears to be low due to several factors: distance from the Project site; status of the case; remedial efforts that are currently being directed by a regulatory agency; and/or the identification of responsible parties has occurred. Based on site reconnaissance and the above database research, no chemicals, solvents, or petroleum products were identified on the Project site, and historic uses do not indicate the usage of such volatile organic compounds (VOCs). No off-site sources were identified that had the potential of impacting the Project site. Therefore, for the reasons stated above, it was determined that the presence of VOCs is not likely. Construction. Construction activities associated with the proposed Project would include site preparation activities, building construction, paving, and planting of ornamental landscaping. Additionally, an above-ground diesel tank, designed with double walls and a containment vessel, would be installed on-site and provide fuel for the vehicle fleet. During operation of the proposed Project, the diesel fueling station would be required to be operated in compliance with all applicable State and federal regulations governing the handling of diesel fuels. In addition, the station would meet all NPDES (National Pollutant Discharge Elimination System (NPDES) requirements and incorporate Structural Source Control BMPs in the fueling area. In the unlikely event that unknown hazardous materials are discovered on site during project construction, the Project contractor would be required to notify the OCFA, who would then determine the next steps regarding possible site evacuation, sampling, and disposal of the substance consistent with local, State, and federal regulations. In addition, the California Department of Transportation (Caltrans), the California Highway Patrol, and local police and fire departments are trained in emergency response procedures for safely responding to accidental spills of hazardous substances on public roads, further reducing potential impacts to a less than significant level. 127 6/2/2020 The Project site is occasionally used as an illegal dump site for trash and construction debris. As such, there is potential that site demolition and grading could expose construction personnel to hazardous materials and release hazardous materials into the environment unless proper procedures to minimize risks are implemented. Due to the unknown nature of potentially occurring hazardous materials on site, their discovery during construction could create a significant hazard to the public or the environment. The project would be constructed in compliance with proper responses, procedures, and best practices to minimize risks to construction personnel and to the environment in the unlikely event debris and waste encountered on the Project site are determined to be hazardous. However, Mitigation Measure HAZ-1, Contingency Plan, is proposed to ensure that procedures for handling unknown hazardous materials during construction are incorporated in the Project. The contingency plan would minimize the risk of a potentially adverse impact to construction personnel on site and to the environment in the event hazardous materials are encountered during construction. Adherence to this mitigation measure will reduce project -related hazardous materials impacts to a less than significant level. (Draft EIR, pp. 4.8-9 through 4.8-10.) Mitigation Measures MM HAZA Construction Contingency Plan. Prior to commencement of site preparation or grading activities, the Director of the County Environmental Health Division, or designee, shall review and approve a contingency plan that addresses the procedures to be followed should on-site unknown hazards or hazardous substances be encountered during grading and construction activities. The plan shall indicate that if construction workers encounter underground tanks, gases, odors, uncontained spills, or other unidentified substances, the contractor shall stop work, cordon off the affected area, and notify the Orange County Fire Authority (OCFA). The OCFA responder shall determine the next steps regarding possible site evacuation, sampling, and disposal of the substance consistent with local, State, and federal regulations. Following approval of the Contingency Plan by the County Environmental Health Division, and prior to issuance of any grading permits, the Project Applicant shall submit written notification of the approval to the Director of the City of San Juan Capistrano's Development Service Department, or designee. 128 6/2/2020 Impacts related to the discovery of unknown hazardous materials during construction would be less than significant after implementation of Mitigation Measure HAZ-1. F. NOISE 1. Noise Standards Threshold: Would the Project result in the 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? Finding, Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.11-11.) Explanation: Construction Noise Impacts. Construction noise associated with the proposed Project would be temporary and would vary depending on the nature of the activities being performed. Noise generated would primarily be associated with the operation of off- road equipment for on-site construction activities as well as construction vehicle traffic on surrounding roadways. Construction noise typically occurs intermittently and varies depending on the nature or phase of construction (e.g., land clearing, grading, excavation, paving). Other primary sources of acoustical disturbance would be random incidents, such as dropping large pieces of equipment or the hydraulic movement of machinery lifts. During construction, exterior noise levels could negatively affect residences in the vicinity of the construction site. The closest residences are located adjacent to the northern boundary of the Project site. Noise levels associated with individual construction equipment are summarized in Table 4.11.G (found at Draft EIR, p. 4.11-11). As depicted in Table 4.11.G (found at Draft EIR, p. 4.11-11), noise levels generated by individual pieces of construction equipment typically range from approximately 70.0 dBA Leq to 82.0 dBA Lea at 50 feet. Noise levels associated with construction projects can vary, depending on the activities performed. Short-term increases in vehicle traffic, including worker commute trips and haul truck trips, may also result in temporary increases in ambient noise levels. During project construction, exterior noise levels could affect sensitive receptors in the vicinity. The residential mobile home park to the north of the site could be exposed to temporary and intermittent noise levels of 82 dBA Leq with Lmax events even 129 6/2/2020 louder (the nearest residence at the mobile home park is approximately 60 feet from the proposed construction area). The City of San Juan Capistrano General Plan contains Noise Element Policy 1.2, which requires noise control measures in areas of new construction and Noise Element Policy 3.1, which requires the reduction of noise associated with noise -producing activities, such as construction activities on noise -sensitive land uses. Project construction activities would occur within San Juan Capistrano and the City's Municipal Code exempts construction noise from noise standards provided that construction is limited to the hours of 7:00 a.m. to 6:00 p.m. Monday through Friday, and between the hours of 8:30 a.m. and 4:30 p.m. on Saturdays. Construction noise occurring on Sundays or federal holidays is not exempt from noise standards. Implementation of Mitigation Measure N01-1, which requires compliance with the construction hours specified in the City's Noise Ordinance (Section 9-3.531, Noise Standards [Residential and Nonresidential]), would reduce construction noise impacts. Additionally, Mitigation Measure N0I-2 includes noise attenuation measures to reduce construction noise generated at sensitive receivers. With implementation of Mitigation Measure N01-1 and N0I-2, construction noise impacts would be reduced to a less than significant level. (Draft EIR, pp. 4.11-10 through 4.11-11.) Mitigation Measures MM N0I-1 Construction Hours. Prior to issuance of demolition or grading permits, the Project Applicant shall submit grading and construction plans for review and approval by the City of San Juan Capistrano's (City) Director of Development Services, or designee. The plans shall include a condition that the construction contractor shall limit all construction -related activities between the hours of 7:00 a.m. and 6:00 p.m., Monday through Friday, and from 8:30 a.m. to 4:30 p.m. on Saturday. No construction shall be permitted outside of these hours or on Sundays and federal holidays. MM N0I-2 Short -Term Construction Noise. Prior to issuance of construction permits, the Project Applicant shall submit project improvement and building plans for review and approval by the City's Director of Development Services, or designee. These construction plans shall include the following requirements for construction activities. Construction contracts must specify that all construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers and other State -required noise attenuation devices. 130 6/2/2020 A sign, legible at a distance of 50 feet, shall be posted at the Project construction site providing a contact name and a telephone number where residents can inquire about the construction process and register compiaints. This sign shall indicate the dates and duration of construction activities. In conjunction with this required posting, a noise disturbance coordinator will be identified to address construction noise concerns received. The coordinator shall be responsible for responding to any local complaints about construction noise. When a complaint is received, the disturbance coordinator shall notify the City within 24 hours of the complaint and determine the cause of the noise complaint (starting too early, malfunctioning muffler, etc.) and shall implement reasonable measures to resolve the complaint, as deemed acceptable by the City. All signs posted at the construction site shall include the contact name and the telephone number for the noise disturbance coordinator. Construction equipment shall be prohibited from idling for longer than 5 minutes. After five minutes of idling equipment shall be shut off. • In order to maximize the distance between construction equipment staging areas and the sensitive noise receivers north of the Project site, all equipment staging areas and material storage areas shall be placed within the southern portion of the site, as far from these receivers as possible. • The use of electric air compressors and similar power tools shall be employed to the maximum extent feasible. • During construction, stationary construction equipment shall be placed such that emitted noise is directed away from the sensitive noise receivers north of the Project site and the use of temporary acoustic barriers around stationary equipment shall be implemented at all times. • The temporary storage of earth material excavated from the site shall be positioned in a manner to function as a noise barrier between the sensitive noise receivers north of the Project site and the active portions of the construction site, to the extent feasible. Proposed project "Pole Shed 6B" and "L -Shed 7B" shall be the first buildings constructed on site in order to provide a barrier between the sensitive noise receivers north of the Project site and the rest of the construction site. When built, these buildings would collectively be approximately 500 feet long and reach approximately 20 feet in height. 131 6/2/2020 G. TRIBAL CULTURAL RESOURCES 1. Tribal Cultural Resources Threshold: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in Public Resources Code section 5024.1? Finding: Less than significant impact with mitigation incorporated. (Draft EIR, p. 4.13-5.) Explanation: As noted above, a Cultural Resources Survey, a SLF through the NAHC, and AB 52 Native American consultation were conducted for the proposed Project. The purpose of these efforts was to identify known tribal cultural resources on or near the Project site. No cultural resources were identified as part of the records search and field survey conducted as part of the Cultural Resources Survey. Similarly, the SLF search and the AB 52 consultation process did not present any evidence that the proposed Project would result in a substantial adverse change in the significance of a tribal cultural resource, as defined in PRC section 21074. Although there is no evidence of tribal cultural resources on the City, the City requires monitoring for development projects in culturally sensitive areas. Due to the location of the Project site in an area near the San Juan Creek, which was previously occupied by the Juanefio village of Toovannga, the Project area is considered potentially sensitive for tribal cultural resources. As such, monitoring by an archaeological monitor under the supervision of an Orange County Certified Archaeologist and by a Native American representative is required (see Mitigation Measure CUL -1 in Section 4.4., Cultural Resources, of the Draft EIR). Mitigation Measures CUL -1 and CUL -2 would reduce any potential impacts to previously undiscovered tribal cultural resources to a less than significant level. (Draft EIR, p. 4.13-6.) H. UTILITIES AND SERVICE SYSTEMS 1. Wastewater Treatment Requirements 132 6/2/2020 Threshold: Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Fi_ndiriLess than significant impact with mitigation incorporated. (Draft EIR, p. 4.14-18.) Explanation: The proposed Project would allow for the development of a lumber yard and hardware store, drive-through restaurant uses, and a crushed rock gravel area for long-term vehicle storage. As part of the Project, water, wastewater, storm drain, electricity, natural gas, and telecommunications improvements would be implemented at the Project site and immediate vicinity. As such, the proposed Project may create the need for new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects. Water. The City would provide domestic water service; however, an annexation of the City's water utilities to the SMWD is pending. The proposed Project would connect to an existing 12 -inch water main within Stonehill Drive. This water main would not need to be relocated. As part of the proposed Project, water lines would be installed throughout the Project site and would connect with the existing main in Stonehill Drive. These water lines would provide domestic water service. The proposed Project would increase demand for water as compared to existing conditions, and on-site infrastructure is required for project implementation. Construction. Short-term demand for water may occur during excavation, grading, and construction activities on site. Water demand for soil watering (fugitive dust control), cleanup, masonry, painting, and other activities would be temporary and would cease at completion of construction. Overall water demand during construction activities would be minimal and is not expected to have any adverse impacts on the existing water system and available water supplies. Therefore, impacts associated with short- term construction activities would not require or result in the construction of new water treatment facilities or the expansion of existing facilities, and construction of the proposed Project would not require the need for new or expanded water entitlements. No mitigation is required. Operation. An increase in long-term demand for water is anticipated to occur during operation of the proposed Project. Due 133 6/2/2020 to the undeveloped nature of the site, there is no current water demand. As shown in Table 4.14.8 of the Draft EIR, the proposed Project would result in a demand of approximately 16,190 gpd (5,908,985 gpy or 18.1 afy) of water, which is 16,190 gpd greater than the current water usage on site. Because the proposed Project would result in a relatively low increase in overall water demand in the City, it could result in the need to provide new or expanded water facilities. The proposed Project includes the installation of water infrastructure which would be constructed by the developer, built to the City's Utility Department standards and dedicated to the Utility Department. The proposed Project would include a connection to the existing 12-inch public water line located in Stonehill Drive, which is owned and operated by the City. In order to confirm that there is sufficient water distribution infrastructure to accommodate the Project's water needs and fire flow requirements, Mitigation Measure UTLA is proposed and requires preparation of a Water Capacity Study. If a deficiency or service problem is found during the permitting process, the Project Applicant would be required by existing regulation to fund the required upgrades to adequately serve the Project. With the incorporation of Mitigation Measure UTLA, impacts to water are considered less than significant. In its existing condition, the Project site does not contain any fire suppression facilities, such as fire hydrants or fire lanes. Fire suppression facilities, including dedicated pipes for fire service, fire department connectors, six on-site fire hydrants, and a fire riser would be installed as part of the proposed Project. In accordance with Chapter 10, Section 2808.12, Water Availability, of the City's Municipal Code„ minimum fire flow would be no less than 500 gpm at 20 psi for a minimum of 1 hour duration for pile heights up to 6 feet and 2 hour duration for pile heights1 over 6 feet. As required of all new development in California, the proposed Project would comply with California State law regarding water conservation measures, including pertinent provisions of Title 24 of the California Government Code (Title 24) regarding the use of water-efficient appliances and low-flow plumbing fixtures (Regulatory Compliance Measure UTL-1). Incorporation of these water conservation measures would reduce the water demands of the proposed Project. The project would also be required to comply with Regulatory Compliance Measure UTL-2, which requires the Project Applicant to pay a Domestic Water Fee to further reduce impacts related to water demand. 134 6/2/2020 Therefore, given that the proposed Project would comply with the State's standard requirements for water facility and infrastructure planning, existing water entitlements, project compliance with recommendations in the Water Capacity Study (via implementation of Mitigation Measure UTL-1), the City's Utility Department or the SMWD (whichever agency is providing water utility service at the time) would be able to accommodate the Project -generated increase in water demand. The project's impacts related to water conveyance and distribution would be less than significant with mitigation incorporated. Wastewater. Wastewater collection for the proposed Project would be provided by the City's sanitary sewer system, which connects to trunk sewers operated by the South Orange County Wastewater Authority (SOCWA). It should be noted that an annexation of the City's wastewater utilities to the SMWD is pending. Wastewater generated by the proposed Project would be delivered to and treated at the J.B. Latham Plant in the City of Dana Point. As discussed above, the J.B. Latham Treatment Plant has a total design capacity of 13 mgd and currently treats an average wastewater flow of 6.7 mgd. Therefore, the plant is currently operating at approximately 52 percent of its daily design capacity. Implementation of the proposed Project would result in the extension of sewer lines. Sewer pipes and sewer cleanout systems would be installed within the boundaries of the Project site and within the public right-of- way along Stonehill Drive. The Project site is currently undeveloped and does not generate any wastewater in its existing condition. A sewer line would be installed within the proposed northern easement, beginning on the adjacent mobile home park property, traversing the Project site, and terminating at Area A. In addition, sewer improvements may require a pump system due to the length and lack of fall. An 8 -inch sewer pipe would be installed within the public right-of-way in Stonehill Drive and connected to sewer lines installed within the Project site. Construction. No significant increase in wastewater flow is anticipated as a result of construction activities on the Project site. Sanitary services during construction would be provided by portable toilet facilities, which transport waste off-site for treatment and disposal. Therefore, during construction, potential impacts to wastewater treatment and wastewater 135 6/2/2020 conveyance infrastructure would be less than significant, and no mitigation would be required. Operation. Project development would include the construction of lumber yard and hardware store, drive-through restaurant uses, and a crushed -rock gravel area for long-term vehicle storage. Implementation of the proposed Project is anticipated to result in an increase in wastewater generation during operation. In its existing condition, the Project site is undeveloped and does not generate wastewater. As shown in Table 4.14.0 (found at Draft EIR, p. 4.14-14), the proposed Project is estimated to generate approximately 22,584 gpd (8,243,160 gpy) of wastewater. The estimated increase in wastewater associated with the proposed Project would represent 0.17 percent of the J.B. Latham Plant's daily capacity41 and 0.4 percent of the Plant's daily remaining capacity.42 The increase of wastewater generated by the proposed Project is a small percentage, and would be accommodated within the existing design capacity of the Treatment Plant, which currently accepts 52 percent of its daily capacity. The J.B. Latham Plant operates in compliance with the San Diego Regional Water Quality Control Board (RWQCB)'s treatment requirements and has the capacity to accommodate the increased wastewater flows from the proposed Project. Furthermore, as required on Mitigation Measure UTL-2, preparation of a Sewer Feasibility Study is required so that the City or SIVIWD (whichever agency is providing wastewater utility service at the time) can confirm and ensure that there is sufficient capacity in the local and trunk lines existing in Stonehill Drive to accommodate the wastewater (Mitigation Measure UTL-2). In the unlikely event that the public sewer has insufficient capacity, the Project Applicant would be required to pay a fair -share portion of the cost to improve or replace sewer lines to ensure sufficient capacity. A final approval for sewer capacity and connection permit would be made at that time. Any improvements to existing local or trunk lines would occur within the existing right-of-way and would be temporary in 41 22,584 gpd = 0.023 mgd; 0.023 mgd / 13 mgd = 0.17 percent of daily total capacity 42 0.023 mgd / 6.7 mgd = 0.35 or 0.4 percent of daily remaining capacity 136 6/2/2020 nature, similar to repair or maintenance of infrastructure and/or roadways. As such, impacts associated with improvements to the existing local and/or trunk lines would be less than significant. The proposed Project would also be required to adhere to Regulatory Compliance Measure UTL3, which requires the Project Applicant to pay a Sewer Connection Fee. Therefore, development of the Project would not require or result in the construction of new wastewater treatment facilities or the expansion existing facilities which would cause significant environmental impacts. Project impacts related to expansion and operation of wastewater treatment facilities would, therefore, be less than significant with implementation of Mitigation Measure UTL-2. Stormwater Drainage. The capacity of the downstream storm drain network is dependent on peak discharge rates entering the system. As discussed further in Section 4.9, Hydrology and Water Quality, of the Draft EIR, the Project site is currently undeveloped and consists of pervious surfaces. In its existing condition, stormwater runoff from the Project site currently outflows to San Juan Creek, which is immediately west of the site. From there, receiving waters include the San Juan Groundwater Basin and the Pacific Ocean. The San Juan Groundwater Basin collects stormwater runoff, and has a capacity of 41,375 of of water per year.43 Implementation of the proposed Project would increase the impervious surface area on the Project site, which would contribute to an increase in stormwater runoff as compared to existing conditions. The proposed Project would include the installation of a stormwater runoff system, permeable paving, and a swale to support stormwater management on the Project site. Pervious areas of the Project site would contain landscaping that would minimize on-site erosion and siltation by stabilizing the soil. Stormwater improvements would include installation of a storm drain line to allow for the continued conveyance of stormwater from the railroad property to the east of the Project site to the existing on-site storm drain outfall, and to 43 Wildermuth Environmental Inc. 2015. Analysis of Storage in the San Juan Groundwater Basin. November 18, 2015. 137 6/2/2020 ultimately be conveyed into the San Juan Creek Channel. Because the City has indicated that this storm drain line should not be a public line, a private line easement would be required. Installation of the deceleration lane on Stonehill Drive would require relocation of the existing catch basin along Stonehill Drive near the existing Project site driveway. A storm drain would be constructed within the proposed northern utility easement, beginning at Avenida Aeropuerto, traversing the Project site, and terminating at Area A. As specified in Regulatory Compliance Measure WQ-4, the Project would be required to prepare a Final Water Quality Management Plan (WQMP), which would specify the Best Management Practices (BMPs) that would be implemented to target pollutants of concern in runoff from the Project site. Because the proposed BMPs would also reduce stormwater runoff, the Project would not exceed the capacity of the downstream storm drain lines or result in off- site flooding. Additionally, as specified in Regulatory Compliance Measure WQ-5, a Final Hydrology and Hydraulics Analysis would be prepared for the Project to confirm that the on-site storm drains, on-site detention systems, and any other drainage structures are appropriately sized to accommodate stormwater runoff from the Project site so that the capacity of downstream storm drain facilities would not be exceeded. Therefore, development of the Project would not require or result in the construction of new stormwater drainage facilities or the expansion of existing facilities which would cause significant environmental impacts. Project impacts related to expansion and operation of wastewater treatment facilities would, therefore, be less than significant. Electricity. The proposed Project includes connection to the existing SDG&E lines surrounding the Project site and extension of the surrounding electrical system throughout the site. Electrical utility lines would be connected to existing boxes located at the perimeter of the Project site along Stonehill Drive. Installation of the deceleration lane on Stonehill Drive would require relocation of the existing utility lines. In compliance with the City's Municipal Code (Section 9-4.529 Utility Undergrounding), all proposed electrical utilities would be undergrounded. A discussion of electricity use during construction and operation of the proposed Project is included below. 138 6/2/2020 Construction. Short-term construction activities would be limited to providing power to the staging area and portable construction equipment and would not substantially increase demand for electricity. Heavy equipment used for construction is primarily powered by diesel fuel. Temporary electric power would be provided via an existing utility pole located Stonehill Drive along the Project site's current access driveway. Given the limited potential demand for electricity during construction, impacts to regional electricity supplies would be less than significant. Operation. Operation of the proposed Project would increase on-site electricity demand compared to existing conditions. Due to the undeveloped nature of the Project site in its existing condition, there is no current electricity usage on the Project site. As discussed in Section 4.5, Energy, of the Draft EIR, the proposed Project is estimated to consume a total of 1,840,033 kilowatt-hours of electricity per year. Therefore, the proposed Project would require an increase of approximately 1,840,033 kwh of electricity per year compared to existing conditions. The proposed Project will reduce electricity consumption by incorporating the following energy efficiency measures in the design: ■ Increased insulation values in walls • Controlling energy losses in the HVAC system (specifying high SEER rated equipment and reducing duct leakage) • Incorporate high efficiency windows and doors • Installing highly efficient lighting and lighting control systems In February 2018, the California Energy Commission (CEC) published the final California Energy Demands for 2018 through 2030.44 Electricity consumption (and supply) in the SDG&E service area is projected to reach between 21,500 gigawatt -hours (gWh) in the low -demand scenario and 22,000 gWh in the high - 44 California Energy Commission. 2018c. California Energy Demand, 2018-2030 Revised Forecast. February.Website: https://efiling.energy.ca.gov/getdocument.aspx?tn=223244 (accessed July 9, 2019). 139 6/2/2020 demand scenario by 2020. Based on the CEC's projections for the SDG&E service area in 2020, the maximum project -related annual consumption of 1.8 gWh45 of electricity per year would represent approximately 0.01 percent46 of the forecasted average energy load in the year 2020. Therefore, the proposed Project's maximum project -related annual electric consumption would be within the SDG&E forecasted demand. Moreover, the proposed Project is consistent with the General Plan designation of Quasi -Industrial for the Project site. As such, projections for future electricity demand anticipated the proposed land use. The relationship between supply and demand involves the availability of energy resources and the net incremental demand generated by a given project or service area. Service providers utilize demand forecasts in order to provide an adequate supply or plan for surplus in the service area. Due to the inability of service providers to store electricity for future demand, the supply and delivery of electricity to customers is directly based on demand projections. Therefore, because the proposed Project would only represent a small fraction of projected demand, and because the Project would be consistent with the General Plan land uses anticipated for the site, the proposed Project would be within the projected SDG&E electrical power demand and supply. The supply and distribution network within the area surrounding the Project site would remain unchanged, and would be expanded throughout the Project site. The proposed Project would not increase electrical demand beyond existing projections from the CEC and SDG&E. The Project site is in an area with existing demand, and the demand generated by the proposed Project is typical of the area and within the normal capabilities of SDG&E. Therefore, the proposed Project would not require the construction of any physical improvements related to the provision of electricity service that would result in significant environmental impacts and the Project's potential 45 1,840,033 kilowatt = 1.840033 gigawatt (gWh) or approximately 1.8 gWh. 46 The average peak electricity demand in 2020 would be 20,000 gWh. 1.8 gWh / 20,000 gWh = 0.00009 or 0.01 percent. 140 6/2/2020 impacts would be less than significant. No mitigation is required. Natural Gas. Gas distribution services would be extended through the Project site and would be responsible for construction connections to these distribution facilities. Construction. Short-term construction activities would not result in demand for natural gas since construction activities/equipment would not require natural gas supplies. Therefore, construction activities would have no impact related to natural gas services, and the proposed Project would not require new or physically altered gas transmission facilities. No mitigation is required. Operation. Operation of the proposed Project would result in increased demand for natural gas compared to existing conditions. Due to the undeveloped nature of the site, there is no existing natural gas usage on- site. The estimated natural gas demands of the proposed Project as provided in Section 4.5, Energy is 19,536 therms/year. Therefore, the proposed Project would require an increase of approximately 19,536 therms of natural gas per year compared to existing conditions. A natural gas line would be installed within the proposed northern easement, beginning at Avenida Aeropuerto, traversing the Project site, and terminating at Area A. Electrical conduits, transformers, switch pads, capacity pads, emergency transformer diesel generators, and pull boxes would be constructed throughout the Project site. Based on CEC projections for the SDG&E service area, the 2024 forecasted low -demand and high - demand scenarios were approximately 540 million therms and 560 million therms, respectively.47 By 2030, the forecasted low -demand scenario is anticipated to be approximately 560 million therms and the high -demand scenario is anticipated to be approximately 600 million therms. Service providers 47 California Energy Commission. 2018c. California Energy Demand 2018-2030 Revised Forecast. Figure 73, https://efiling.energy.ca.gov/getdocument.aspx?tn=223244 (accessed July 9, 2019). 141 6/2/2020 utilize demand forecasts in order to provide an adequate supply or plan for surplus in the service area. Because natural gas demand for the SDG&E service area is expected to increase overall, and because the proposed Project would only represent a small fraction of projected demand for natural gas, the proposed Project would be within the projected demand for through all forecasted years. Furthermore, the proposed Project would be consistent with the General Plan designation of Quasi -Industrial for the site. As such, projections for future natural gas demand anticipated the proposed land use. Existing natural gas facilities are expected to have adequate capacity to serve the proposed Project. Therefore, the supply and distribution network within the area surrounding the Project site would remain unchanged, with the exception of standard on-site improvements. Levels of service to off-site users would not be adversely affected. Natural gas service to the Project would be provided and maintained by SDG&E through existing and extended gas facilities. The Project site is in an area with existing demand, and the demand generated by the proposed Project is typical of the area and within the normal capabilities of SDG&E. The proposed Project would not increase natural gas demand beyond existing projections. The estimated increase in natural gas demand associated with the proposed Project would represent a very small fraction of the forecast natural gas demand. With the incorporation of Regulatory Compliance Measure UTL-1, which would require the Project to comply with the 2019 Building Energy Efficiency Standards (Title 24), project -related impacts to natural gas generation would be further minimized. Therefore, the proposed Project would not require the construction of any physical improvements related to the provision of natural gas service that would result in significant environmental impacts and the Project's potential impacts would be less than significant. No mitigation is required. Telecommunications Facilities. Telephone, cable, and internet services existing within the Project area would be extended into the Project site at the Project site's main entrance driveway along Stonehill Drive. As part of the 142 6/2/2020 proposed Project, a telephone line with associated riser pull box will be installed per telephone company requirements within the Project site near the access driveway on Stonehill Drive. Telecommunication utility lines would be connected to existing boxes located at the perimeter of the Project site along Stonehill Drive. Installation of the deceleration lane on Stonehill Drive would require relocation of the existing utility lines. The project Applicant will be responsible for constructing adequate telecommunication facility extensions to the various structures on the Project site. Additionally, cable box locations will be carefully planned and coordinated with the utility company, the landscape architect, and the Developer to be unobtrusive and screened from public view where possible. The construction and expansion of these facilities would occur on site during the site preparation and earthwork phase and are not expected to impact any off-site telephone, cable, or internet services that serve the surrounding areas. Therefore, the proposed impacts associated with the relocation or construction of new or expanded telecommunication facilities, and impacts would be less than significant. No mitigation is required. (Final EIR, pp. 4.14-11 through 4.14-19.) Reaulatory Comoliance Measures RCM UTL-1 Title 24 of the California Code of Regulations (CCR). Prior to issuance of building permits, the City of San Juan Capistrano (City) Director of Development Services, or designee, shall ensure that the Project design complies with the 2019 Building Energy Efficiency Standards (Title 24 of the California Code of Regulations [CCR]) energy conservation and green building standards. RCM-UTL-2 Domestic Water Fee. Prior to issuance of any grading or construction permits, the City of San Juan Capistrano Public Works Director, or designee, shall verify that the Project Applicant has paid the proposed Project's fair share of Domestic Water Fees in accordance with City Resolution No. 04-05-18-04. RCM-UTL-3 Sewer Connection Fee. Prior to issuance of any grading or construction permits, the City Public Works Director, or designee, shall verify that the Project Applicant has paid the proposed Project's fair share of Sewer Connection Fees in accordance with City Resolution No. 04-11-16-05. 143 6/2/2020 Mitigation Measures MM UTLA Water Capacity Study. Prior to issuance of a grading or building permit, the Project Applicant shall submit a Water Capacity Study prepared by a qualified civil engineer to the City of San Juan Capistrano City Engineer or the Santa Margarita Water District Engineer (whichever agency is providing water utility service at the time), or designee, for review and approval. The Water Capacity Study shall include a review of the existing water distribution system that would serve the Project site to confirm that it has available capacity to convey the water required by the proposed Project's uses. Any required improvements shall be identified in the Water Capacity Study. The analysis, conclusions, and recommendations in the Water Capacity Study shall be based on final design plans and shall be consistent with all applicable City (or Santa Margarita Water District) requirements. In the event a water supply line deficiency is identified in the Water Capacity Study, the Project Applicant shall pay a fair -share portion of the cost to improve or replace water lines to ensure sufficient capacity. MM UTL-2 Sewer Feasibility Study. Prior to issuance of a grading or building permit, the Project Applicant shall submit a Sewer Feasibility Study prepared by a qualified civil engineer to the City of San Juan Capistrano City Engineer or the Santa Margarita Water District Engineer (whichever agency is providing sewer service at the time), or designee, for review and approval. The Sewer Feasibility Study shall include a review of the existing sewer system that would serve the Project site to confirm that it has available capacity to accept the wastewater flow generated by the proposed Project's uses. Any required improvements shall be identified in the Sewer Feasibility Study. The analysis, conclusions, and recommendations in the Sewer Feasibility Study shall be based on final design plans and shall be consistent with all applicable City (or Santa Margarita Water District) requirements. In the event that the Sewer Feasibility Study identifies insufficient sewer capacity to serve the proposed Project, the Project Applicant would be required to pay a fair -share portion of the cost to improve or replace sewer lines to ensure sufficient capacity. SECTION IV IMPACTS THAN CANNOT BE FULLY MITIGATED TO A LESS THAN SIGNIFICANT LEVEL 144 6/2/2020 The City Council hereby finds that, despite the incorporation of Mitigation Measures identified in the EIR and in these Findings, the following environmental impacts cannot be fully mitigated to a less than significant level and a Statement of Overriding Considerations is therefore included herein: A. TRANSPORTATION 1. Plans, Policies, and Ordinances Threshold: Would the Project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Finding: Significant and unavoidable. (Draft EIR, p. 4.2-19.) Explanation: Operation. The proposed Project would be required to comply with General Plan policies addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. The Project would also be required to comply with City Council Policy No. 310, which establishes metrics for determining traffic impacts, and consistent transportation related goals and policies in the City's General Plan. The project's consistency with these plans is described in detail below. Conformance with the General Plan. The proposed Project would be required to comply with transportation related goals and policies in the City's General Plan (refer to Section 4.12.3.4, of the Draft EIR, for a list of goals and policies applicable to the proposed Project) as described below. Vehicle access to the Project site will be provided via a proposed signalized driveway at Stonehill Drive and the southwestern corner of the Project site.48 Due to the proximity of the proposed signal to the existing signal at Camino Capistrano/Stonehill Drive, the signal would be coordinated to minimize vehicle delays, stops, and queuing. A deceleration lane in the westbound direction would be constructed on Stonehill Drive to enhance safety and traffic flow for right -turn access to the Project site. An LOS analysis was conducted at the proposed traffic signal at Stonehill 481installation of the proposed signal is included as part of the project because of the results of a peak -hour traffic signal warrant analysis, which concluded installation of a traffic signal would be warranted under the Existing Plus Project condition. 145 6/2/2020 Drive and the southwestern corner of the Project site, which confirmed that this intersection would operate at LOS C or better during both peak hours using the ICU and HCM methodologies. In addition to adding a signal at the intersection of the Project Driveway and Stonehill Drive, the Project would also connect the Project site to nearby sidewalks and bicycle routes on Stonehill Drive through the installation of new sidewalks that would travel from Stonehill Drive to the Project Driveway and internal parking areas. The Project would also allow for the continuation of existing on -street (Class II) bike lanes provided on Camino Capistrano (east of the Project site), Stonehill Drive (west of the Project site), and Del Obispo Street (west of the Project site). These existing bicycle lanes also serve to connect the Project area with the San Juan Creek Trail (west of the site) and surrounding residential, employment, commercial, and recreational destinations. As such, the Project would be consistent with the City's goals of proving a circulation system that meets the needs of the community and minimizing conflict between vehicles, pedestrians, equestrians, and bicycles (Circulation Element Goals 1 and 4). In addition, the installation of the proposed signal would be consistent with the City's intention of installing street improvements within areas where necessary to improve safety and improving the circulation system in concert with land development (Circulation Element Policies 1.1 and 4.3). As such, the proposed Project would not conflict with applicable provisions in the City's General Plan Circulation Element. Conformance with Administration Policy No. 310. City Council Policy No. 310 requires development projects to conduct a transportation impact analysis to analyze conformance with the transportation strategies, goals, and policies in the General Plan and address adverse impacts to the transportation system. In order to assess the Project's consistency with City Administrative Policy 310, a trip generation analysis was first conducted to determine the number of trips that would occur following implementation of the Project. As shown in Table 4.12.D (found at Draft EIR, p. 4.12-14), the Project has the potential to generate approximately 3,486 ADT, including 312 trips (168 inbound and 144 outbound) in the a.m. peak 146 6/2/2020 hour and 219 trips (103 inbound and 116 outbound) in the p.m. peak hour. In order to determine impacts at roadway intersections associated with implementation of the Project (i.e., the Existing Plus Project condition), the results of the trip generation analysis for the proposed Project were added to existing baseline traffic volumes at the study area intersections. Tables 4.12.E and 4.12.E (found at Draft EIR, pp. 4.12-16 through 4.12-17) summarize the results of the Existing Plus Project peakhour LOS analysis using the ICU and HCM methodologies, respectively. As shown in Table 4.12.E, all study area intersections, including the hot -spot intersections, are anticipated to operate at satisfactory LOS based on the ICU methodology. As shown in Table 4.12.F, all study area intersections, including the hot -spot intersections, are anticipated to operate at satisfactory LOS based on the HCM methodology. Therefore, a significant impact would not occur at any study area intersection based on the ICU and HCM methodologies. No mitigation would be required. In addition to assessing project impacts on roadway intersections, project -related impacts to roadway segments were also evaluated for conformance with City Administrative Policy No. 310. As part of this assessment, the trip generation results for the proposed Project were added to existing baseline traffic volumes at study area roadway segments. Existing Plus Project roadway segment ADT volumes, v/c ratios, and LOS are presented in Table 4.12.G (found at Draft EIR, p. 4.12-17). As Table 4.12.G indicates, all study area roadway segments, including the hot -spot roadways, are anticipated to operate at satisfactory LOS with the Project, with the exception of Stonehill Drive between Camino Capistrano and the Project Driveway (LOS E), Stonehill Drive between the Project Driveway and Del Obispo Street (LOS D), and Valle Road between San Juan Creek Road and the 1-5 northbound ramps (LOS F). The v/c ratios for Stonehill Drive between Camino Capistrano and the Project Driveway and between the Project Driveway and Del Obispo Street would increase by 0.069 and 0.017, respectively, in the Existing Plus Project condition. These are considered significant unavoidable impacts because there is no available right-of-way as a feasible improvement to widen Stonehill Drive to provide additional roadway capacity. However, the v/c ratio does not increase by 0.01 or greater for Valle Road between San Juan Creek Road and 147 6/2/2020 the 1-5 northbound ramps in the Existing Plus Project condition. Although a significant project impact would occur at two study area roadway segments (Stonehill Drive between Camino Capistrano and the Project Driveway and between the Project Driveway and Del Obispo Street), a peak -hour link analysis shows that each segment would operate at satisfactory LOS in both directions during the peak hours. In summary, the Project would result in conflicts with City Administrative Policy No. 310 due to project -related significant unavoidable impacts to roadway segments in the Existing Plus Project Condition. No mitigation is available to reduce this impact to a less than significant level. Therefore, impacts to roadway segments would remain significant and unavoidable following implementation of the proposed Project. (Draft EIR, pp. 4.12-13 through 4.12-19.) SECTION V CUMULATIVE IMPACTS Regarding the Project's potential to result in cumulative impacts, the City hereby finds as follows: A. AESTHETICS As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for aesthetics. The cumulative impact area for aesthetics related to the proposed Project is the City of San Juan Capistrano. Several residential and commercial development projects are approved and/or pending within the City. Each of these projects, as well as all proposed development in the City, would be subject to its own consistency analysis for policies and regulations governing scenic quality and would be reviewed for consistency with General Plan goals and policies and Zoning Code development standards. If there were any potential for significant impacts to aesthetics, appropriate mitigation measures would be identified to reduce and/or avoid impacts related to aesthetics. For the reasons outlined in Section 4.1.6, Project Impacts, of the Draft EIR, implementation of the proposed Project would not result in a significant cumulative impact related to aesthetics. The proposed Project and all related projects are required to adhere to City and State regulations designed to reduce and/or avoid impacts related to aesthetics. With compliance with these regulations, cumulative impacts related to aesthetics would be less than significant. Therefore, implementation of the proposed Project would not result in a significant cumulative impact related to aesthetics. (Draft EIR, p. 4.1-14.) 148 6/2/2020 B. AGRICULTURE AND FORESTRY RESOURCES The Project would have no impact on agriculture and forestry resources. (Appendix A [Initial Study], pp. 4-6 through 4-8.) As a result, no cumulative impact would occur. C. AIR QUALITY As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for air quality. The cumulative impact area for air quality related to the proposed Project is the Basin. Air pollution is inherently a cumulative impact measured across an air basin. The discussion under Threshold 4.2.2, of the Draft EIR, includes an analysis of the proposed Project's contribution to cumulative air impacts. To summarize the conclusion with respect to that analysis, the incremental effect of projects that do not exceed the Project -specific thresholds are generally not considered to be cumulatively considerable per SCAQMD guidelines. The proposed Project's construction- and operation -related regional daily emissions are less than the SCAQMD significance thresholds for all criteria pollutants. In addition, adherence to SCAQMD rules and regulations on a project -by -project basis would substantially reduce potential impacts associated with the related projects and basin wide air pollutant emissions. Therefore, the proposed Project would not have a cumulatively considerable increase in emissions, and the proposed Project's cumulative air quality impacts would be less than significant. No mitigation is required. (Draft EIR, pp. 4.2-21 through 4.2-22.) D. BIOLOGICAL RESOURCES As defined in the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for biological resources. The Project site is undeveloped and is located in the City of San Juan Capistrano; therefore, the cumulative area for biological impacts is the City. The Project site is located within Subarea 4 of the Orange County Southern Subregion Habitat Conservation Plan (OCSSHCP), which consists of 33,550 acres in the cities of Rancho Santa Margarita, Mission Viejo, San Juan Capistrano, and San Clemente. Approximately 106 acres within Subarea 4 remain undeveloped. The Project site is located in an area of the OCSSHCP that is identified as "developed" and is outside of the designated habitat reserve. Therefore, the proposed Project would not contribute to the loss of natural habitat in the City. Furthermore, as the Project site is located outside the boundaries of the designated habitat reserve, OCSSHCP regulatory coverage is not provided for activities associated with the proposed Project. The development of the proposed Project would not result in the removal of any sensitive habitat species identified in the OCSSHCP and would not conflict with the provisions outlined in the OCSSHCP. Therefore, the proposed Project would not contribute to the cumulative loss 149 6/2/2020 of biological resources and impacts on biological resources would be less than cumulatively significant. (Draft EIR, pp. 4.3-14 through 4.3-15.) E. CULTURAL RESOURCES As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for cultural resources. The cumulative impact area for cultural resources for the proposed Project is the City of San Juan Capistrano. Potential impacts of the proposed Project to unknown cultural resources, when combined with the impacts of past, present, and reasonably foreseeable projects in the City of San Juan Capistrano, could contribute to a cumulatively significant impact due to the overall loss of archaeological artifacts and fossil remains unique to the region. However, each development proposal received by the City is required to undergo environmental review pursuant to CEQA. If there were any potential for significant impacts to archaeological resources, an investigation would be required to determine the nature and extent of the resources and identify appropriate mitigation measures. When resources are assessed and/or protected as they are discovered, impacts to these resources are less than significant. As such, implementation of Mitigation Measures CUL -1 and CUL -2 would ensure that the proposed Project, together with cumulative projects, would not result in a significant cumulative impact to unique archaeological resources and previously undiscovered buried human remains. (Draft EIR, p. 4.4-8.) F. ENERGY The geographic area for electricity is that of the SCE boundaries, while the geographic area for natural gas service is that of the SoCalGas boundaries. The proposed Project would result in an increased services demand in electricity and natural gas. Although the proposed Project would result in a net increase in electricity, this increase would not require SCE to expand or construct infrastructure that could cause substantial environmental impacts. The total annual electricity consumption the SCE service area in 2017 was 84,291.6 GWh. By 2030, consumption is anticipated to increase by approximately 12,000 GWh for the low -demand scenario and by 22,000 GWh for the high -demand scenario.49 While this forecast represents a large increase in electricity consumption, the proposed Project's percent of cumulative consumption would negligible. The proposed Project, in combination with cumulative development, is well within SCE's system -wide net annual increase in electricity supplies over the 2018 to 49 California Energy Commission. 2018c. California Energy Demand, 2018-2030 Revised Forecast. Publication Number: CEC-200-2018-002-CMF. February. Website https://efiIing.energy.ca.gov/getdocument.aspx?tn=223244 (accessed October 24, 2019) 150 6/2/2020 2030 period, and there are sufficient planned electricity supplies in the region for estimated net increases in energy demands. Similarly, additional natural gas infrastructure is not anticipated due to cumulative development. Total natural gas consumption in the SoCalGas service area in 2018 was 5,156.1 million therms. Between 2018 and 2035, total natural gas consumption in the SoCalGas service area is forecast to remain steady for the low- and mid -demand scenarios and to increase by approximately 650 million therms in the high -demand scenario due to intense energy efficiency efforts.50 The proposed Project's percent of cumulative consumption of natural gas in the SoCalGas service area would be negligible. It is anticipated that SoCalGas would be able to meet the natural gas demand of the related projects without additional facilities. In addition, both SCE and SoCalGas demand forecasts include the growth contemplated by the proposed Project and the related projects. Increased energy efficiency to comply with building energy efficiency standards will reduce energy consumption on a per -square -foot basis. In addition, utility companies are required to increase their renewable energy sources to meet the Renewable Portfolio Standards mandate of 60 percent renewable supplies by 2030. SCE and SoCalGas plan to continue to provide reliable service to its customers and upgrade their distribution systems as necessary to meet future demand. Transportation energy use would also increase; however, this transportation energy use would not represent a major amount of energy use when compared to the amount of existing development and to the total number of vehicle trips and VMT throughout Orange County and the region. The proposed Project and related projects are required to comply with various federal and State government legislation to improve energy efficiency in buildings, equipment, and appliances, and reduce VMT. Compliance with Regulatory Compliance Measure E-1 would ensure that the proposed Project does not result in an inefficient, wasteful, and unnecessary consumption of energy. Therefore, the proposed Project's contribution to impacts related to the inefficient, wasteful, and unnecessary consumption of energy would not be cumulatively considerable, and no mitigation is required. (Draft EIR, pp. 4.5-11 through 4.5-12.) G. GEOLOGY AND SOILS As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for geology and soils. For geology and soils, the cumulative study area consists of the area that could be affected by proposed Project activities and the areas affected by other projects whose activities could directly or indirectly affect the geology and soils of the Project site. The 50 Ibid, 151 6/2/2020 analysis above indicated no rare or special geological features or soil types on the Project site that would be affected by project activities and no other known activities or projects with activities that affect the geology and soils of this site. In addition, the proposed Project, as with all foreseeable projects, would be required to comply with the applicable state and local requirements, including the City of San Juan Capistrano Building Code. Therefore, the Project's contribution to cumulative geotechnical and soil impacts is less than significant. For paleontological resources, the cumulative study area is the geographical area of the City, which is the geographical area covered by the City's General Plan, including all goals and policies included therein. Future development in the City could include excavation and grading that could potentially affect paleontological resources. The cumulative effect of the proposed Project is the continued loss of these resources. The proposed Project, in conjunction with other development in the City, has the potential to cumulatively impact paleontological resources; however, it should be noted that each development proposal received by the City that requires discretionary approval would be required to undergo environmental review pursuant to CEQA. If there is a potential for significant impacts to paleontological resources, an investigation would be required to determine the nature and extent of the resources and identify appropriate mitigation measures. If subsurface cultural resources are assessed and/or protected as they are discovered, impacts to these resources would be less than significant. In addition, the City's General Plan policies would be implemented as appropriate to reduce the effects of additional development within the City. Therefore, the Project's contribution to the cumulative destruction of known and unknown paleontological resources throughout the City would be reduced to a less than significant level. (Draft EIR, p. 4.6-19.) H. GREENHOUSE GAS EMISSIONS As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for GHG emissions. GHG emissions are global pollutants, and therefore, result in cumulative impacts by nature. Consequently, it is speculative to determine how an individual project's GHG emissions would impact California. As such, impacts identified under Section 4.7.6, Project Impacts, are not project -specific impacts to GCC, but are the proposed Project's contribution to this cumulative impact. The impact of project -related GHG emissions would not result is a reasonably foreseeable cumulatively considerable contribution to GCC. Additionally, the proposed Project, in conjunction with other cumulative projects, would be subject to all applicable regulatory requirements which would further reduce GHG emissions. Further, the proposed Project would not conflict with SCAG's 2016-2040 RTP/SCS. Therefore, the Project's cumulative contribution of GHG emissions would be less than significant and the Project's cumulative GHG impacts would also be less than cumulatively considerable. (Draft EIR, p. 4.7-13.) I. HAZARDS AND HAZARDOUS MATERIALS As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of 152 6/2/2020 past, current, and probable future projects within the cumulative impact area for hazards and hazardous materials. The cumulative impact area for hazardous materials consists of: (1) the area that could be affected by proposed Project activities, such as the release of hazardous materials, and (2) the areas affected by other projects whose activities could directly or indirectly affect the presence or fate of hazardous materials on the Project site. Typically, only projects adjacent to or abutting the Project site are considered because of the limited potential impact area associated with the release of hazardous materials into the environment. No other projects adjacent to the Project site are currently under consideration or have been proposed. The contribution of hazardous materials use and hazardous waste disposal with implementation of the Project is minimal, and combined hazardous materials effects from past, present, and reasonably foreseeable projects within the City and immediate area would not be significant. The project operation would involve the use of potentially hazardous materials (e.g., solvents, cleaning agents, paints, pesticides, and diesel and petroleum fuels), that when used correctly and in compliance with existing laws and regulations, would not result in a significant hazard to visitors or workers in the vicinity of the proposed Project. Impacts associated with the potential to encounter unknown hazardous debris and waste that may exist on site during construction would be reduced to a less than significant level through adherence to Mitigation Measure HAZ- 1. Furthermore, the proposed Project and all other projects in the cumulative area are required to be consistent with the existing regulations related to hazards and hazardous materials. Consistency with federal, State, and local regulations would prevent the proposed Project as well as other projects from creating cumulative impacts in terms of hazards and hazardous materials. Impacts associated with hazardous soils, hazardous groundwater, and use of hazardous materials on site would be controlled through application of regulatory compliance measures. For the reasons outlined above, implementation of the proposed Project would not result in an incremental contribution to cumulative impacts related to hazards and hazardous materials that are cumulatively considerable; therefore, cumulative hazards and hazardous materials impacts are considered less than significant. (Draft EIR, pp. 4.8-11 through 4.8-12.) J. HYDROLOGY AND WATER QUALITY Cumulative development in the San Juan Creek Watershed is a continuation of the existing urban pattern of development that has already resulted in extensive modifications to watercourses in the area. The area's watercourses have been channelized and drainage systems have been put into place to respond to the past urbanization that has occurred in this area. For the cumulative analysis related to hydrology and water quality, the cumulative projects being considered include the related projects, which all discharge to the same watershed as the proposed Project (i.e., the San Juan Creek Watershed). Each of these related projects could potentially 153 6/2/2020 increase the volume of stormwater runoff and contribute to pollutant loading in stormwater runoff reaching both the City's storm drain system and the San Juan Creek Watershed, thereby resulting in cumulative impacts to hydrology and surface water quality. New development and redevelopment can result in increased stormwater runoff and increased urban pollutants in stormwater runoff from Project sites. Each related project must include BMPs to reduce impacts to water quality and hydrology in compliance with local ordinances and plans adopted to comply with requirements of the various NPDES permits. Specifically, all projects that disturb 1 acre or more of soil must comply with the requirements of the Construction General Permit, the South Orange County MS4 Permit, and the City of San Juan Capistrano Municipal Code. The preparation and approval of a SWPPP and pollution control plan, construction BMP plan, and/or erosion and sediment control plan (for construction), and a WQMP (for operation) would be required for each related project to determine appropriate BMPs to minimize water quality impacts. In addition, the preparation and approval of a hydrology study would be required to determine the hydrologic control required to minimize increases in runoff from each site so they do not exceed regulatory requirements or exceed the capacity of downstream stormdrain systems. In addition, the City's Building Official reviews all development projects on a case-by-case basis to ensure that sufficient local and regional drainage capacity is available. Each related project must consider impaired receiving waters and TMDLs for receiving waters. The TMDL program is designed to identify all constituents that adversely affect the beneficial uses of water bodies and then identify appropriate reductions in pollutant loads or concentrations from all sources so that the receiving waters can maintain/attain the beneficial uses in the Basin Plan. Thus, by complying with TMDLs, a project's contribution to overall water quality improvement in the San Juan Creek Watershed in the context of the regulatory program is designed to account for cumulative impacts. Regional programs and BMPs such as TMDL programs and the MS4 Permit Program have been designed under an assumption that the San Juan Creek Watershed would continue their pattern of urbanization. The regional control measures contemplate the cumulative effects of proposed development. The proposed Project would be required to comply with the requirements of the Construction General Permit and the South Orange County MS4 Permit and implement construction and operational BMPs to reduce pollutants in stormwater runoff. Compliance with these regional programs and permits constitutes compliance with programs intended to address cumulative water quality impacts. As stated above, each related project would be required to develop a SWPPP; pollution control plan, construction BMP plan, and/or erosion and sediment control plan; a WQMP; and a hydrology study, and would be evaluated individually to determine appropriate BMPs and treatment measures to reduce impacts to surface water quality and hydrology. Because the proposed Project and other related projects would comply with applicable NPDES requirements and would include BMPs to reduce the volume of stormwater runoff and pollutants of concern in stormwater runoff, the cumulative hydrology and water quality impacts of the proposed Project and the related projects would be less than significant. Therefore, the proposed Project's incremental 154 6/2/2020 hydrology and water quality impacts would not be cumulatively considerable. (Draft EIR, pp. 4.9-27 through 4.9-28.) K. LAND USE AND PLANNING As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for land use. The cumulative impact area for land use for the proposed Project is the City of San Juan Capistrano. Several residential and commercial development projects are approved and/or pending within the City. Each of these projects, as well as all proposed development in the City, would be subject to its own General Plan consistency analysis and would be reviewed for consistency with adopted land use plans and policies. The majority of the Project site is designated Quasi- Industrial on the City's General Plan Land Use Map, with the northernmost portion of the property (where the utility easement is proposed) designated as Industrial Park. In addition, the majority of the Project site is classified as Commercial Manufacturing zone with the northernmost portion of the Project site is zoned Mobile Home Park Senior Overlay. The northernmost portion of the property is not proposed for development, and therefore, uses included as part of the Project would not conflict with the land use designation and zoning classification for this portion of the site. Uses proposed as part of the Project would be consistent with both the existing General Plan land use designation of Quasi -Industrial and zoning classification of Commercial Manufacturing for the site. No General Plan Amendment or Zoning Amendment would be required. Therefore, cumulative land use impacts with respect to consistency with local land use plans would be considered less than significant. The proposed Project would include land uses that are consistent with the surrounding neighborhoods, and therefore would not contribute to a pattern of development that adversely impacts adjacent land uses or conflicts with existing or planned development. As discussed further above, proposed on-site improvements would be consistent with the long-range planning goals of local and regional governing plans and policies for the surrounding area. There are no incompatibilities between the proposed Project and planned future projects in the City, which primarily include residential and commercial developments. All identified City -related projects would be reviewed for consistency with adopted land use plans and policies by the City. For this reason, the related projects are anticipated to be consistent with applicable General Plan and zoning requirements, or would be subject to allowable exceptions; further, they would be subject to CEQA, mitigation requirements, and design review as applicable. Therefore, the proposed Project would not contribute a significant cumulative land use compatibility impact in the study area, and no mitigation is required. (Draft EIR, pp. 4.10-25 through 4.10-26.) 155 6/2/2020 L. MINERAL RESOURCES The Project would have on impact on mineral resources because there are no known mineral resources are present on the Project site nor is the Project site located within an area known to contain locally important mineral resources. No cumulative impacts would occur. (Appendix A [Initial Study], pp. 4-42 through 4-43.) M. NOISE Construction Noise. Construction activities associated with the proposed Project and other construction projects in the area may overlap, resulting in construction noise in the area. However, construction noise impacts primarily affect the areas immediately adjacent to each construction site. Construction noise for the proposed Project was determined to be less than significant with the implementation of Mitigation Measure N01-1, which requires compliance with the construction hour restrictions in the City's Municipal Code. Cumulative development in the vicinity of the Project site could result in elevated construction noise levels at sensitive receptors in the Project area. However, each project would be required to comply with the applicable City's Municipal Code limitations on construction. Therefore, cumulative construction noise impacts would be less than significant with the implementation of Mitigation Measure N01-1. Operational Stationary Source Noise. Long-term stationary noise sources associated with the development at the proposed Project, combined with other cumulative projects, could cause local noise level increases. Noise levels associated with the proposed Project and related cumulative projects together could result in higher noise levels than considered separately. On-site noise sources associated with the proposed Project would not exceed any applicable noise standards. Additionally, related cumulative projects would be required to comply with the City's noise level standards and include mitigation measures if standards are exceeded. Therefore, cumulative noise impacts from stationary noise sources would be less than significant. Operational Traffic Source Noise Impacts. According to the United States Environmental Protection Agency (USEPA), cumulative noise impacts represent the combined and incremental effects of human activities that accumulate over time. While the incremental impacts may be insignificant by themselves, the combined effect may result in a significant impact. Conversely, although there may be a significant noise increase due to the proposed Project in combination with other related projects (combined effects), it must also be demonstrated that the Project has an incremental effect. In other words, a significant portion of the noise increase must be due to the proposed Project. Cumulative noise impacts would occur primarily as a result of increased traffic on local roadways due to operation of the Project and other projects in the vicinity. A project's contribution to a cumulative traffic noise increase could be considered significant when the combined effect exceeds the perception level (i.e., auditory level increase) threshold. The combined effect compares the "Cumulative Plus Project" condition to "Existing" conditions. This comparison accounts for the traffic noise increase generated by a project combined with the traffic noise increase generated by projects in the area. 156 6/2/2020 The incremental effect compares the "Cumulative Plus Project" condition to the "Cumulative No Project" condition. The following combined effect and incremental effect criteria have been utilized to evaluate the overall effect of the cumulative noise increase. • Combined Effect. The Cumulative With Project noise level ("Cumulative Plus Project) would cause a significant cumulative impact if a 3.0 dB increase over Existing Conditions occurs and the resulting noise level exceeds the applicable Existing g exterior standard at a sensitive use. Although there may be a significant noise increase due to the proposed Project in combination with other related projects (combined effects), it must also be demonstrated that the Project has an incremental effect. In other words, a significant portion of the noise increase must be due to the proposed Project. and Incremental Effects. The "Cumulative Plus Project" causes a 1.0 dBA increase in noise over the "Cumulative No Project" noise level. A significant impact would result only if both the combined and incremental effects criteria have been exceeded at a single roadway segment, since such would indicate that there is a significant noise increase due to the proposed Project in combination with other related projects and a significant portion of the noise increase is due to the proposed Project. Noise by definition is a localized phenomenon and reduces as distance from the source increases. Consequently, only the proposed Project and growth due to occur in the Project site's general vicinity would contribute to cumulative noise impacts. Table 4.11.E (found at Draft EIR, p. 4.11-20) lists the traffic noise effects along roadway segments in the Project vicinity for "Existing," "Cumulative No Project," and "Cumulative Plus Project," conditions, including incremental and net cumulative impacts. As shown in Table 4.111, no significant cumulative traffic noise impact would result. While traffic noise at the segment of La Novia Avenue east of the Valle Road/La Novia Avenue roundabout would surpass the combined effect threshold of 3.0 dBA over Existing Conditions, there is no increase in noise beyond the Cumulative No Project scenario as a result of the Project, and thus no incremental effect. Therefore, cumulative operational mobile source noise impacts would be less than significant. No mitigation is required. (Draft EIR, pp. 4.11-18 through 4.11-20.) N. POPULATION AND HOUSING The Project will have less than significant impacts on population and housing. (Appendix A [Initial Study], pp. 4-46 through 4-47.) The Project would supply employment opportunities to people already residing in the area, and the Project would not provide or remove housing on the Project site. As such, the Project would not induce substantial population growth or accelerate development in an underdeveloped 157 6/2/2020 area, and any impacts to population growth would be less than significant. Thus, no cumulative impacts would occur. O. PUBLIC SERVICES The Project will have less than significant impacts on public services. (Appendix A [Initial Study], pp. 4-48 through 4-55.) Although implementation of the Project in conjunction with other related projects in the area would increase the demand for public services, the Project alone would marginally increase the necessity of public services. Moreover, each cumulative project, when adopted, would be consistent with state and local regulations and would require the payment of fees for public services such as police, school, and library services. Similar to the Project, the related projects would be required to demonstrate the availability of services or mitigate accordingly; as such no cumulative impacts would occur. P. RECREATION The Project would not include recreational facilities nor develop residential uses that would require the construction or expansion of recreational facilities that might have an adverse effect on the environment and therefore would not have impacts. (Appendix A [Initial Study], pp. 4-56 through 4-57.) No cumulative impacts would occur. Q. TRANSPORTATION As defined in the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects. The cumulative impact area for traffic/transportation is the City of San Juan Capistrano. A list of approved/pending projects provided by the City was reviewed to determine whether projects in the vicinity of the Project site (if any) should be included in the cumulative condition. With concurrence from the City, the approved/pending projects listed in Table 4.12.1-1 (found at Draft EIR, p. 4.12-22) were identified as cumulative projects. Project Plus Cumulative (Opening Year 2024) Condition Significant Unavoidable Impact. According to the Project Applicant, the Project will open in 2024. To develop a Year 2024 condition, an ambient growth rate of 0.5 percent per year (i.e., 3 percent total growth) was applied to the existing 2018 traffic counts. This condition also included the proposed Project trips and manually assigned trips generated by approved and/or pending projects. Application of a 0.5 percent per year growth rate to the existing traffic volumes is considered conservative and would account for any additional future development in the Project vicinity. Table 4.12.H (found at Draft EIR, p. 4.12-22) summarizes the list of approved/pending projects provided by City staff. This list was reviewed to identify projects in the vicinity of the Project site that would contribute traffic in the study area beyond the ambient growth already assumed. 158 6/2/2020 Tables 4.12.1 and 4.12.J (found at Draft EIR, pp. 4.12-24 and 4.12-25, respectively) summarize the results of the Existing Plus Project Plus Cumulative peak hour LOS analysis for the study area intersections using the ICU and HCM methodologies, respectively. As shown in Table 4.12.1, all study area intersections, including the hot - spot intersections, are forecast to operate at satisfactory LOS based on the ICU methodology, with the exception of Del Obispo Street/Stonehill Drive (LOS D in the a.m. peak hour). The proposed Project would add more than 0.01 to the v/c ratio at this intersection (0.012). This is considered a significant unavoidable impact because there is no available right-of-way as a feasible improvement to widen Del Obispo Street or Stonehill Drive. In addition, this intersection is located within the City of Dana Point and mitigation cannot be enforced within another jurisdiction outside the City of San Juan Capistrano. Therefore, a significant project impact would occur at one study area intersection based on the ICU methodology. As shown in Table 4.12.1, all study area intersections, including the hot -spot intersections, are forecast to operate at satisfactory LOS based on the HCM methodology. Therefore, a significant project impact would not occur at any study area intersection based on the HCM methodology. Existing Plus Project Plus Cumulative roadway segment ADT volumes, v/c ratios, and LOS are presented in Table 4.12.K (found at Draft EIR, p. 4.12-26). As Table 4.12.K indicates, all study area roadway segments, including the hotspot roadways, are forecast to operate at satisfactory LOS, with the exception of San Juan Creek Road between Valle Road and Camino Capistrano (LOS E), Stonehill Drive between Camino Capistrano and the Project Driveway (LOS E), Stonehill Drive between the Project Driveway and Del Obispo Street (LOS E), and Valle Road between San Juan Creek Road and the 1-5 northbound ramps (LOS F). The v/c ratios for Stonehill Drive between Camino Capistrano and the Project Driveway and between the Project Driveway and Del Obispo Street would increase by 0.069 and 0.017, respectively. These are considered significant unavoidable impacts because there is no available right-of-way as a feasible improvement to widen Stonehill Drive to provide additional roadway capacity. However, the v/c ratios do not increase by 0.01 or greater for San Juan Creek Road between Valle Road and Camino Capistrano and for Valle Road between San Juan Creek Road and the 1-5 northbound ramps and therefore impacts at these locations are not considered significant. Although a significant project impact would occur at two study area roadway segments (Stonehill Drive between Camino Capistrano and the Project Driveway and between the Project Driveway and Del Obispo Street), a peak -hour link analysis shows that each segment would operate at satisfactory LOS in both directions during the peak hours. General Plan Buildout (Year 2040) Condition Significant Unavoidable Impact. The General Plan Buildout (2040) condition includes all planned circulation improvements consistent with the City's General Plan and all known cumulative projects in the Project vicinity. 159 6/2/2020 Tables 4.12.E and 4.12.M (found at Draft EIR, pp. 4.12-28 and 4.12-29, respectively) summarize the results of the General Plan Buildout (2040) peak -hour LOS analysis for the study area intersections using the ICU and HCM methodologies, respectively. As shown in Table 4.121, all study area intersections, including the hot -spot intersections, are forecast to operate at satisfactory LOS based on the ICU methodology, with the exception of Del Obispo Street/Stonehill Drive (LOS D in the a.m. peak hour). The project would add more than 0.01 to the v/c ratio at this intersection (0.012). This is considered a significant unavoidable impact because there is no available right-of-way as a feasible improvement to widen Del Obispo Street or Stonehill Drive. In addition, this intersection is located within the City of Dana Point and mitigation cannot be enforced within another jurisdiction outside the City of San Juan Capistrano. Therefore, a significant impact would occur at one study area intersection based on the ICU methodology. As shown in Table M, all study area intersections, including the hot -spot intersections, are forecast to operate at satisfactory LOS based on the HCM methodology. Therefore, a significant project or buildout impact would not occur at any study area intersection based on the HCM methodology. Buildout roadway segment ADT volumes, v/c ratios, and LOS are presented in Table 4.12.N. As Table 4.12.N indicates, all study area roadway segments, including the hot - spot roadways, are forecast to operate at satisfactory LOS with the exception of San Juan Creek Road between Valle Road and Camino Capistrano (LOS E), Stonehill Drive between Camino Capistrano and the Project Driveway (LOS E), Stonehill Drive between the Project Driveway and Del Obispo Street (LOS E), and Valle Road between San Juan Creek Road and the 1-5 northbound ramps (LOS F). The v/c ratios for Stonehill Drive between Camino Capistrano and the Project Driveway and between the Project Driveway and Del Obispo Street would increase by 0.069 and 0.017, respectively. These are considered significant unavoidable impacts because there is no available right-of-way as a feasible improvement to widen Stonehill Drive to provide additional roadway capacity. However, the v/c ratios do not increase by 0.01 or greater for San Juan Creek Road between Valle Road and Camino Capistrano and for Valle Road between San Juan Creek Road and the 1-5 northbound ramps and therefore impacts at these locations are not considered significant. Although a significant impact would occur at two study area roadway segments (Stonehill Drive between Camino Capistrano and the Project Driveway and between the Project Driveway and Del Obispo Street), a peak - hour link analysis shows that each segment would operate at satisfactory LOS in both directions during the peak hours. (Draft EIR, pp. 4.12-21 through 4.12-30.) R. TRIBAL CULTURAL RESOURCES As defined in the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for tribal cultural resources. The cumulative study area for tribal cultural resources is the geographical area of the City of San Juan Capistrano, which is the geographical area covered by the 160 6/2/2020 City's General Plan, including all goals and policies therein. Future development in the City could include excavation and grading that could potentially impact tribal cultural resources. The cumulative effect of the proposed Project would be the continued loss of these resources. The proposed Project, in conjunction with other development in the City, has the potential to cumulatively impact tribal cultural resources; however, it should be noted that each development proposal requiring a discretionary approval received by the City would undergo environmental review pursuant to CEQA. If there is a potential for significant impacts to tribal cultural resources, an investigation would be required to determine the nature and extent of the resources and to identify appropriate mitigation measures. If subsurface cultural resources are assessed and/or protected as they are discovered, impacts to these resources would be less than significant. In addition, applicable City ordinances and General Plan policies would be implemented as appropriate to reduce the effects of additional development to tribal cultural resources within the City. (Draft EIR, p. 4.13-8.) S. UTILITIES AND SERVICE SYSTEMS As defined in the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for public services and utilities. The Project site is a currently undeveloped lot in the City of San Juan Capistrano that does not contain any permanent structures. The Project site is not currently served by any utility providers. Wastewater The geographic area for the cumulative analysis for wastewater treatment is defined as the City of San Juan Capistrano Utilities Department service area and SOCWA's service area. Project compliance with the recommendations of the Sewer Feasibility Study (Mitigation Measure UTL-2) and all applicable City requirements would ensure that project impacts on City sewer facilities and sewer capacity would not be cumulatively considerable. The proposed Project would not generate wastewater above the current capacity of SOCWA's J.B. Latham Regional Treatment Plant. Further, it is anticipated that SOCWA's existing and planned wastewater treatment capacity would be sufficient to accommodate the growth forecasted within its service area, and development that is generally consistent with this forecast can be adequately served by the SOCWA facilities. The proposed Project would not induce significant population, employment or housing growth, either directly or indirectly. SOCWA operates two other wastewater treatment facilities in addition to the J.B. Latham Regional Treatment Plant, for a total treatment capacity of 26 mgd within its jurisdiction. In addition, the proposed Project would not contribute wastewater that would exceed the service capacity of J.B. Latham Regional Treatment Plant. Therefore, the proposed Project's contribution to wastewater generation in the SOCWA service area would not be cumulatively considerable, and no mitigation is required. 161 6/2/2020 Potable Water The geographic area for the cumulative analysis of water infrastructure is the City's Utilities Department service area. The project -generated increase in water demand represents approximately 0.2 percent of the City's projected 2020 supply. This increase is considered to be minimal and is unlikely to impact the City's existing water supply commitments. Furthermore, the UWMP indicated that sufficient water supplies are available. The UWMP took into consideration cumulative development planned for in the City's General Plan and, therefore, cumulative water demand in the City has already been accounted for in the UWMP projections. Therefore, the proposed Project's contribution to water demand in the City would not be cumulatively considerable, and no mitigation is required. Stormwater Drainage The geographic area for the cumulative analysis of impacts to the provision of stormwater drainage facilities is the San Juan Creek Watershed. The construction and expansion of stormwater drainage facilities for the proposed Project would occur on site and is not expected to impact any off-site stormwater drainage facilities that serve the surrounding areas. As specified in Regulatory Compliance Measure WQ-5, a Final Hydrology Report and Hydraulics Analysis would be prepared for the Project to confirm that the on-site storm drains, on-site detention systems, and any other drainage structures are appropriately sized to accommodate stormwater runoff from the Project site so that the capacity of downstream storm drain facilities would not be exceeded. Implementation of the proposed Project would not impact the ability of the existing stormwater drainage system to serve the surrounding area. Therefore, cumulative impacts associated with the relocation or construction of new or expanded stormwater drainage facilities would be less than significant. No mitigation is required. Electricity The geographic area for the cumulative analysis of impacts to the provision of electricity is the service territory of SDG&E. SDG&E's service area covers approximately 4,100 square miles in two counties and provides power to 1.4 million business and residential customers. The projections of statewide electricity supply capacity demand rates are cumulative in nature. They are based on population and economic growth and General Plan projections, in addition to such physical variables as average temperature and water supplies (important to hydroelectric generation) in a given year. The proposed Project would increase electrical demand in the area. However, any increase in electrical demand resulting from the proposed Project as it would be incremental compared to an increase in regional electrical demand. Therefore, electric power and infrastructure capacity are available, or have already been planned, to serve past, present, and reasonably foreseeable projects. Title 24 of the California Administrative Code regulates energy and water consumption in new construction and regulates building energy consumption for heating, cooling, ventilation, water heating, and lighting. Therefore, in relation to the cumulative study area, the proposed Project would not generate a significant cumulative increase in 162 6/2/2020 demand for electricity or a significant disruption in service or service level. Therefore, the proposed Project's contribution to electricity impacts would not be cumulatively considerable, and no mitigation is required. Natural Gas The geographic area for the cumulative analysis of impacts to the provision of natural gas is the service territory for SDG&E. As discussed above, according to the CEC 2018- 2030 Revised Forecast, SDG&E projects total gas demand to increase overall in the low -demand and high -demand scenarios, due to projected population growth in the SDG&E service area. Therefore, sufficient gas supplies and infrastructure capacity are available, or have already been planned, to serve past, present, and reasonably foreseeable projects. Furthermore, like the proposed Project, all future projects would be subject to Title 24 requirements and would be evaluated on a case-by-case basis to determine the need for specific distribution improvements. As the natural gas provider has identified adequate capacity and additional development within the SDG&E service area and because the planning area has taken into account population growth and because the proposed Project would comply with Title 24, the proposed Project's contribution to natural gas impacts would not be cumulatively considerable, and no mitigation is required. Telecommunications Facilities The geographic area for the cumulative analysis of impacts to the provision of telecommunications is the service area of telecommunication providers. The construction and expansion of telecommunication facilities for the proposed Project would occur on site and is not expected to impact any off-site telephone, cable, or internet services that serve the surrounding areas. Therefore, impacts associated with the relocation or construction of new or expanded telecommunication facilities would be less than cumulatively significant. No mitigation is required. (Draft EIR, pp. 4.14-21 through 4.14-23.) T. WILDFIRE The Project would have no impacts on wildfire risks, and therefore no cumulative impacts would occur. (Appendix A [Initial Study], pp. 4-67 through 4-69.) SECTION VI FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL C:I AMr.FR Sections 15126(c) and 15126.2(c) of the CEQA Guidelines, require that an EIR address any significant irreversible environmental changes that would occur should the 163 6/2/2020 Project be implemented. Generally, a project would result in significant irreversible environmental changes if any of the following would occur: • The project would involve a large commitment of non-renewable resources; The primary and secondary impacts of the Project would generally commit future generations to similar uses; • The project involves uses in which irreversible damage could result from any potential environmental accidents; or ■ The proposed consumption of resources is not justified. The types and level of development associated with the proposed Project would consume limited, slowly renewable, and nonrenewable resources. This consumption would occur during construction of the proposed Project and would continue throughout the operational lifetime of the proposed Project. The development of the proposed Project would require a commitment of resources that would include (1) building materials, (2) fuel and operational materials/resources, and (3) the transportation of goods and people to and from the Project site. Construction of the proposed Project would require consumption of resources that are not replenishable or that may renew so slowly as to be considered nonrenewable. These resources would include certain types of lumber and other forest products (e.g., hardwood lumber), aggregate materials used in concrete and asphalt (e.g., sand, gravel, and stone), metals (e.g., steel, copper, and lead), petrochemical construction materials (e.g., plastics), and water. Fossil fuels (e.g., gasoline and oil) would also be consumed in the use of construction vehicles and equipment. Water, which is a limited, slowly renewable resource, would also be consumed during construction of the proposed Project. However, given the temporary nature of construction activities, water consumption during construction would result in a less than significant impact on water supplies. Furthermore, the use of construction vehicles and equipment would require the consumption of nonrenewable fossil fuels such as natural gas and oil. As with other resources consumed during construction, the consumption of nonrenewable fossil fuels for energy use would occur on a temporary basis during construction of the proposed Project. Operation of the proposed Project would continue to expend similar nonrenewable resources that are currently consumed within San Juan Capistrano. These include energy resources such as electricity, petroleum-based fuels, fossil fuels, and water. Energy resources would be used for heating and cooling buildings, transportation within the Project site, and building lighting. Fossil fuels are primary energy sources for project construction and operation. This existing, finite energy source would thus be incrementally reduced. Under Title 24, Part 6 of the California Code of Regulations (CCR), conservation practices limiting the amount of energy consumed by the proposed Project would be required during operation. Nevertheless, 164 6/2/2020 the use of such resources would continue to represent a long-term commitment of essentially nonrenewable resources. The proposed Project would result in the limited use of potentially hazardous materials contained in typical cleaning agents and pesticides for landscaping on the Project site and storage of potentially hazardous materials associated with a construction and lumber supply store. A -6,000 -gallon aboveground diesel tank, designed with double walls and a containment vessel, would be installed on-site and provide fuel for the vehicle fleet that would complete customer deliveries during project operation. Such materials would be used, handled, stored, and disposed of in accordance with applicable government regulations and standards that would serve to protect against a significant and irreversible environmental change resulting from the accidental release of hazardous materials. In summary, construction and operation of the proposed Project would commit the use of slowly renewable and nonrenewable resources and would limit the availability of these resources on the Project site for future generations or for other uses during the life of the proposed Project. However, the continued use of such resources during operation would be on a relatively small scale and consistent with regional and local urban design and development goals for the area. As a result, the use of nonrenewable resources in this manner would not result in significant irreversible changes to the environment under the proposed Project. (Draft EIR, pp. 6-4 through 6-5.) SECTION VII GROWTH -INDUCING IMPACTS Section 15126.2(d) of the State CEQA Guidelines requires a Draft EIR to discuss the ways the Project could foster economic or population growth or the construction of additional housing, directly or indirectly, in the surrounding environment. In accordance with State CEQA Guidelines Section 15126.2(d), a Project would be considered to have a growth -inducing effect if it would: • Directly or indirectly foster economic or population growth, or the construction of additional housing in the surrounding environment; • Remove obstacles to population growth (e.g., construction of an infrastructure expansion to allow for more construction in service areas); ® Tax existing community service facilities, requiring the construction of new facilities that could cause significant environmental effects; or • Encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. In addition, CEQA Guidelines that that growth inducement must not be assumed. Removal of Obstacles to, or Otherwise Foster, Population Growth 165 6/2/2020 The area surrounding the Project site is already highly urbanized and developed with a mix of residential, automobile dealerships, hotel, and commercial uses, so limited population growth is feasible within the vicinity of the Project site. In any event, the proposed Project would not remove impediments to population growth in the area surrounding the Project site. While the proposed Project may require water, sewer, electricity, and natural gas lines on site and in the immediate vicinity of the Project site, such improvements would be intended primarily to meet project -related demand and would not necessitate substantial utility infrastructure improvements. In addition, the private road easement to Avenida Aeropuerto is intended to provide emergency access in the immediate project vicinity, and would not foster off-site population growth. The construction of the proposed Project would generate a substantial number of construction related jobs. However, the proposed Project would not promote construction workers relocating their places of residence as a direct consequence of working on the proposed Project. The work requirements of most construction projects are highly specialized so construction workers remain at a job site only for the limited time in which their specific skills are needed to complete a particular phase of the construction process. In addition, the supply of general construction labor in the region has been stable over recent years and is 29 percent above Orange County's 10 -year average, suggesting a well-functioning construction job market and available regional labor pool.51 Therefore, given the availability of construction workers, the proposed Project would not induce material population growth from a short-term employment perspective. A Ganahl Lumber store is currently located at 34162 Doheny Park Road, approximately 0.5 mile south of the Project site in the neighboring City of Dana Point. Implementation of the proposed Project would result in the closure and relocation of the existing Ganahl Lumber store in Dana Point to the Project site. Because of this, it is anticipated that the majority of the customer base that would patronize the proposed Ganahl Lumber store already shop at the existing Ganahl location in Dana Point. With respect to the drive- through restaurants, most of the customer base comes from traffic that is already passing through the area. Customers would not be expected to change their places of residence in order to be closer to the goods and services offered by the proposed Project's businesses. Therefore, implementation of the proposed Project would not lead to the growth of a new customer base that would directly foster population growth in the Project vicinity or elsewhere. Upon completion of the proposed Project, the Ganahl Lumber Store, potential drive- through restaurants, and parking area would not generate any new permanent residents on the Project site. The Ganahl Lumber store and potential drive-through restaurants would provide goods and services to nearby residents and workers. Although some 51 State of California Employment Development Department. 2019. Industry Employment — Official Estimates, Anaheim -Santa Ana -Irvine Metropolitan Division (Orange County), 2000—Present. Website: https://www.labormarketinfo.edd.ca.gov/data/employment-by-industry.html (accessed October 20, 2019). 166 6/2/2020 local businesses that provide goods and services to nearby residents may hire a small number of additional employees to accommodate the minor increase in clientele associated with the proposed Project, this additional hiring is not expected to induce material population growth because most of these new employees are not expected to change their place of residence. Due to the limited number of jobs induced and the available labor pool within San Juan Capistrano and the region, it is unlikely that the employment offered by the Project would cause people to move or relocate to the area solely for the purpose of being close to the Project site. Therefore, although the proposed Project would provide employment opportunities, it would not result in substantial indirect growth or create a significant demand for housing or services in the Project vicinity. Therefore, given that the employment opportunities generated by construction and operation of the proposed Project would be filled by people who would commute to the Project site, the potential population growth associated with project employees would be minimal. Foster Economic Growth In its existing condition, the Project site is used for the short-term storage of vehicles from nearby car dealerships in the City of San Juan Capistrano (City). Therefore, the Project site currently generates a minimal amount of revenue for the City. The proposed Project would provide additional sales tax revenues to the City as compared to the existing uses on the Project site. Further, the City's sale of the Project site would return it to the property tax rolls, thereby increasing the local property tax base. The Ganahl Lumber store and the potential drive-through restaurant space would be considered net revenue generators for the City. Because the proposed Project would replace the existing parking lot for nearby auto dealers on the Project site with a slightly smaller parking lot, the proposed Project could result in an indirect reduction in City sales tax revenue by slightly reducing the storage area available for additional vehicle stock, thereby potentially reducing sales volumes and decreasing sales tax generation for the City. The construction of the proposed Project would generate a substantial number of construction related jobs in San Juan Capistrano during the construction period. The Ganahl Lumber store and potential drive-through restaurants would also provide long- term employment opportunities. At this time, number of employees and tenant -specific details are not known. However, as the Project site currently does not provide any long- term employment opportunities, implementation of the proposed Project would foster economic growth as compared to the existing uses on the Project site. Other Characteristics The proposed Project includes the development of a Ganahl Lumber store, drive- through restaurants, and a parking area. Because the Project does not propose to amend the existing General Plan land use designations and zoning classifications to 167 6/2/2020 residential, and would not add any permanent residents to the Project site, the Project would not directly increase the City's population beyond existing levels. The proposed property sale, proposed development agreement and, and proposed amendment of deed restrictions/easements affecting the Project site would not have any growth - inducing impacts. The proposed Project would provide a private emergency access easement along the western portion of the Project site. This potential easement would connect with Avenida Aeropuerto to the north to provide a secondary emergency evacuation route to residents to the north of the Project site, who currently rely on an at - grade railroad crossing for access. This potential easement would not serve as a public roadway connection between Stonehill Drive and Avenida Aeropuerto. Access would be limited to emergency situations only. The emergency access easement would not cause a future increase in density or land use. Any future growth in the City is likely to occur regardless of whether or not the Project is approved. Approval of the Project would not involve some characteristic that may encourage and facilitate other activities that could significantly affect the environment. (Draft EIR, pp. 6-1 through 6-4.) SECTION VIII ALTERNATIVES A. BACKGROUND The Draft EIR analyzed three alternatives to the Project as proposed and evaluated these alternatives for their ability to avoid or reduce the Project's significant environmental effects while also meeting the majority of the Project's objectives. The City finds that it has considered and rejected as infeasible the alternatives identified in the EIR and described below. This section sets forth the potential alternatives to the Project analyzed in the EIR and evaluates them in light of the Project objectives, as required by CEQA. Where significant impacts are identified, section 15126.6 of the State CEQA Guidelines requires EIRs to consider and discuss alternatives to the proposed actions. Subsection (a) states: (a) An EIR shall describe a range of reasonable alternatives to the Project, or to the location of the Project, which would feasibly attain most of the basic objectives of the Project but would avoid or substantially lessen any of the significant effects of the Project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason. 168 6/2/2020 Subsection 15126.6(b) states the purpose of the alternatives analysis: (b) Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section 21002.1), the discussion of alternatives shall focus on alternatives to the Project or its location which are capable of avoiding or substantially lessening any significant effects of the Project, even if these alternatives would impede to some degree the attainment of the Project objectives, or would be more costly. In subsection 15126.6(c), the State CEQA Guidelines describe the selection process for a range of reasonable alternatives: (c) The range of potential alternatives to the proposed Project shall include those that could feasibly accomplish most of the basic objectives of the Project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency's determination. Additional information explaining the choice of alternatives may be included in the administrative record. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts. The range of alternatives required is governed by a "rule of reason" that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed Project. Alternatives are limited to ones that would avoid or substantially lessen any of the significant effects of the Project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the Project. B. PROJECT OBJECTIVES The following objectives have been established for the Project (Draft EIR, pp. 5-2 through 5-3): 1. Develop a lumber store that provides building supplies and hardware to professional contractors and the public, while also providing casual restaurant uses and automobile storage facilities. 2. Develop a project that balances the development potential of the Project site with environmental considerations. 169 6/2/2020 3. Revitalize the vacant site with a well-designed and landscaped mixed-use project that is compatible with the surrounding community. 4. Allow the continuation of parking/automobile storage for nearby car dealerships. 5. Increase the City's tax base generating revenue for the City through increased retail sales. 6. Invigorate the local economy by providing new employment and business opportunities in the City. 7. Provide an easement for future private emergency access from the Project site to Avenida Aeropuerto along the westernmost boundary of the Capistrano Valley Mobile Estates (CVME). 8. Develop a project that will promote sustainability and energy efficiency, incorporating design features that would exceed the California's Title 24 Energy Code requirements. C. ALTERNATIVES CONSIDERED BUT REJECTED FROM DETAILED ANALYSIS Section 15126.6(c) of the State CEQA Guidelines specifies that an EIR should (1) identify alternatives that were considered by the lead agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process; and (2) briefly explain the reasons underlying the lead agency's determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives; (ii) infeasibility; and/or (iii) inability to avoid significant environmental impacts. The following alternatives were considered but rejected as part of the environmental analysis for the Project: g Reduced Ganahl Lumber Store Project Alternative: This alternative would have reduced the size of the proposed Ganahl Lumber store and lumber yard. Physical impacts under this alternative would have been reduced due to the smaller development area. A smaller Ganahl Lumber store would have reduced traffic and transportation impacts by reducing vehicle trips associated with the proposed Project. However, this alternative would not have achieved one of the stated project objectives, including increasing the City's tax base generating revenue for the City through increased retail sales to the same extent as the proposed Project because a smaller hardware store and lumber yard would likely generate less sales tax. Additionally, a smaller Ganahl Store would not be economically viable and would not meet the needs of Ganahl Lumber to provide a wide range of building supplies. This is supported by the fact that the existing Ganahl Store, located approximately a half a mile south of the Project site in Dana Point, is not sufficiently sized to stock 170 6/2/2020 many of the building materials and supplies that are requested by its customers. This is one of the key reasons why Ganahl Lumber is proposing to relocate and replace its existing Dana Point hardware store and lumber yard with a new facility at the Project site in San Juan Capistrano. (Draft EIR, p. 5-4.) ■ Ganahl Lumber Site in Dana Point: The project Applicant currently owns an approximately 1.5 -acre site at 34162 Doheny Park Road in Dana Point, where it operates a hardware store and drive-through lumber yard. The existing Ganahl Lumber store in Dana Point is bordered by Doheny Park Road to the west, commercial uses to the south, a mobile home park to the north and east and is fully developed. As such, the existing Ganahl Lumber store cannot be expanded without acquiring and redeveloping one or more of the adjacent properties. It should be noted that several components of the proposed Project (the drive-through restaurants and vehicle storage for the City's car dealerships) are required by the City as a condition of developing the Project site, which is currently owned by the City. Therefore, for purposes of analysis, it is reasonable to assume those uses would not be developed on the existing Ganahl Lumber site or surrounding properties in Dana Point. According to the City of Dana Point's Zoning Map, the adjacent properties to the south of the existing Ganahl Lumber store are located within the Community Commercial/Pedestrian (CC/P) District. According to Section 9.11.020(b) of the City of Dana Point's Zoning Code, the CC/P District allows building materials sales and service uses as a permitted use. The City of Dana Point's Zoning Map indicates that the adjacent properties to the south of the existing Ganahl Lumber store are located within the Commercial/Residential (C/R) District. According to Section 9.13.020(c) of the City of Dana Point's Zoning Code, building materials sales and service uses are not permitted uses within the C/R District. Therefore, a Zone Change would be required to accommodate the development of an expanded Ganahl Lumber store and lumber yard on the mobile home park properties to the north and east of the Ganahl Lumber site in Dana Point. It is not clear whether an amendment to the City of Dana Point's General Plan would be required. Given the fact that the properties to the south of the Ganahl Lumber site in Dana Point are currently developed with businesses that are still operating, and the properties to the north and east of the Ganahl Lumber site in Dana Point are developed with a large mobile home park that is presumed to be subject to long-term ground leases, it is not reasonable to assume that the Project Applicant/Developer can acquire or control any of these adjacent properties in a timely fashion that would allow for the implementation of a project with similar uses and square footage. Further, 171 6/2/2020 as discussed above, a Zone Change would be required to allow a building materials sales and service use on the properties adjacent to the Ganahl Lumber site in Dana Point. As noted above, the Project Applicant/Developer would also not be required to develop drive-through restaurants and vehicle storage for the City of San Juan Capistrano's car dealerships in a neighboring city. While development of the proposed Ganahl Lumber hardware store and lumber yard at the Ganahl Lumber site and adjacent properties in Dana Point could potentially reduce some of the proposed Project's environmental impacts because it would result in reduced trip generation and related traffic, air quality, and noise impacts in comparison to the proposed Project, many of the environmental impacts of this alternative would be similar to or greater than those of the proposed Project, especially considering that the Ganahl Lumber site in Dana Point is bordered by sensitive residential uses to the north and east. The addition of drive-through restaurant space and vehicle storage would increase the potential environmental impacts at that location. It should also be noted that development of an expanded Ganahl Lumber hardware store and lumber yard on the Ganahl Lumber site and surrounding properties in Dana Point would fail to meet most of the Project objectives. Moving the proposed Project to Dana Point would not revitalize the Project site (Objective 3), increase the City of San Juan Capistrano's tax base (Objective 5), invigorate the local economy by providing new employment and business opportunities in the City of San Juan Capistrano (Objective 6), or provide an emergency access easement to Avenida Aeropuerto through the Project site (Objective 7). This alternative may allow the continuation of automobile storage for nearby car dealerships in San Juan Capistrano on the Project site (Objective 4); however, no improvements to the existing parking area on the Project site would be provided. Therefore, an alternative site at the Ganahl Lumber site and surrounding properties in Dana Point was not considered feasible because the Project Applicant/Developer would be required to acquire additional properties in Dana Point, a Zone Change (and possibly a General Plan amendment) would be required, the Dana Point site would not achieve the underlying purpose and objectives of the proposed Project, and development of an expanded Ganahl Lumber hardware store and lumber yard on the Ganahl Lumber site and surrounding properties in Dana Point would likely result in many of the same environmental impacts as development of the proposed Project on the Project site. Therefore, this alternative was rejected from further consideration. (Draft EIR, pp. 5-5 through 5-6.) 172 6/2/2020 • Ganahl Lumber Site in Other Properties Within San Juan Capistrano: The City has reviewed the inventory of vacant properties that have the potential to support a similarly sized development. Due to the developed nature of the City, there are no available properties that are of sufficient size to accommodate the proposed Project. The City is currently processing development applications on the few vacant or underdeveloped properties in the City that are large enough to potentially accommodate the proposed Project (the proposed Farm Specific Plan property at the southeast corner of Del Obispo Street and Via Vermeulen, the proposed Tirador Residential Project at the terminus of Calle Arroyo). Furthermore, an alternative site smaller than the proposed location would not be economically viable and would not meet the needs of the Project Applicant/Developer to provide a wide range of building supplies. This is supported by the fact that Ganahl Lumber is seeking to vacate its existing hardware store and lumber yard in Dana Point, which is located on a 1.5 - acre site approximately 0.5 mile south of the Project site, because it no longer meets the company's business needs in terms of the amount of product inventory that it can keep on hand to serve its customers. The project Applicant/Developer does not own or control any other property within the City that would be suitable for development of the proposed Project. Moreover, the Project Applicant/ Developer cannot reasonably acquire or control an alternative site in the City in a timely fashion that would allow for the implementation of a project with similar uses and square footage. In addition, development of the proposed Project at an alternative site in the City (assuming one was available) could potentially result in some environmental impacts that would be similar to or greater than those of the proposed Project's environmental impacts, depending on the proximity of the alternate site to sensitive uses or a circulation system where the existing level of service and roadway capacity could accommodate the proposed uses. The development of the proposed Project on an alternative site in the City would also fail to meet several of the Project objectives. Moving the proposed Project would not revitalize the Project site (Objective 3), nor would it provide an emergency access easement to Avenida Aeropuerto through the Project site (Objective 7). Moving the proposed Project to another part of San Juan Capistrano would meet the Project objective to provide automobile storage for the City's car dealerships (Objective 4); however, doing so would result in some operational inefficiencies because an alternate site would not be located as close to the City's car dealerships along Camino Capistrano. For these reasons, no alternative site is considered feasible because the Project Applicant does not own or control another vacant site in the 173 6/2/2020 Project area, no suitable alternative site is available that would achieve the underlying purpose and objectives of the Project, and an alternative site would likely not reduce environmental impacts as compared to the development of the proposed Project on the Project site. Therefore, no alternative locations to undertake the proposed Project are analyzed in the Draft EIR. This alternative was rejected from further consideration. (Draft EIR, pp. 5-6 through 5-7.) Finding: The City Council rejects the Reduced Ganahl Lumber Store Project, Ganahl Lumber Site in Dana Point, and Ganahl Lumber Site in other properties within San Juan Capistrano alternatives, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) the alternatives do not avoid any significant and unavoidable impacts, (2) the alternatives would likely not further reduce any of the proposed Project's significant impacts; (3) the alternatives do not meet most of the Project objectives; and (4) the alternatives are technically, financially, and legally infeasible. Therefore, these alternatives are eliminated from further consideration. D. EVALUATION OF ALTERNATIVES SELECTED FOR ANALYSIS The alternatives selected for further detailed review within the EIR focus on alternatives that could the Project's significant environmental impacts, while still meeting most of the basic Project objectives. Those alternatives include: Alternative 1: No Project/No Development (Draft EIR, pp. 5-12 through 5-14.) • Alternative 2: No Restaurant Use (Draft EIR, pp. 5-10 through 5-11.) • Alternative 3: 2,000 Square Feet of Restaurant Uses (Draft EIR, p. 5- 11.) • Alternative 4: 4,000 Square Feet of Restaurant Uses (Draft EIR, p. 5- 11.) 1. Alternative 1: No Project/No Development Description_ Consistent with Section 15126.6 of the State CEQA Guidelines, the No Project/No Development Alternative assumes the existing land uses and condition of the Project site at the time the NOP was published (May 22, 2019) would continue to exist without changes. The setting of the Project site at the time the NOP was published is described throughout Chapter 4.0 of this EIR with respect to individual environmental issues, and forms the baseline of the impact assessment of the proposed Project. The No Project/No Development Alternative represents the environmental conditions that would exist if no new development of any kind were to occur on the Project site. The No Project/No Development Alternative anticipates that the Project site would remain primarily as a vehicle 174 6/2/2020 storage area on the crushed -rock gravel surface area and vacant in the northern portion of the Project site. The existing General Plan land use designation for the Project site is Quasi - Industrial and Industrial Park. The base land use designation of Quasi -Industrial and Industrial Park allows for a variety of light industrial and manufacturing uses, including limited regional commercial activities that are non-polluting and are compatible with surrounding land uses. The base land use designation of Industrial Park allows light industrial and manufacturing uses. The existing zoning designation for a majority of the Project site is Commercial Manufacturing (CM). The Commercial Manufacturing zone allows industrial and non -retail commercial uses, including wholesaling, limited manufacturing, eating establishments, and indoor recreational uses. The northernmost portion of the Project site (where the northern access easement is proposed) is zoned Mobile Home Park Senior Overlay, which allows mobile home uses for seniors 55 years of age and older. The No Project/No Development Alternative would allow for the existing vehicle storage uses on the Project site to continue to operate as they currently do into the foreseeable future. There would be no improvements implemented on the Project site. The No Project/No Development Alternative would allow existing conditions on the Project site to remain unchanged. (Draft EIR, pp. 5-12 through 5-13.) Impacts: The Project site is currently undeveloped and the northern portion of the site is vacant. A vehicle storage area, located on the central and southern portions of the Project site, is secured by a chain-link fence. The vehicle storage area consists of a crushed -rock gravel surface and is not paved. The Project site is occasionally used as an illegal dump site for trash and construction debris, which contributes to the degraded nature of the Project site. This alternative assumes that the use of the Project site as a vehicle storage area and occasional illegal dump site would continue into the future. It is assumed that no renovations or new construction would occur at the site. The Project site is generally bounded to the south by Stonehill Drive, to the west by San Juan Creek Channel and Trail, to the east by the BNSF rail line, and to the north by the Capistrano Valley Mobile Estates (CVME) mobile home park. Under the No Project/No Development Alternative, the visual setting of the Project site would not be altered. However, continued use of the Project site as an occasional illegal dump site would continue to contribute to the degraded nature of the Project site. No new air pollutant emissions or greenhouse gas (GHG) emissions would be generated by new visitors or short-term construction since no new construction is proposed. Unknown potential subsurface archaeological and paleontological resources would remain undisturbed. There would be no impacts related to geology, soils, and hazardous materials. There 175 6/2/2020 would be no change to the Project site with regard to the percentage of the site that would remain pervious or the volume of runoff during a storm event and runoff treatment from best management practices (BMPs) that are included in the proposed Project. The existing land uses would continue to be consistent with the City's General Plan and zoning documents, and no General Plan or Zoning Amendments would be required. No short-term construction noise impacts or long-term operational noise impacts would occur to the surrounding area. Further, no additional vehicle trips would be generated by construction or operations at the site, no new sources of solid waste would be created, and no increase in demand for energy would occur as a result of development. The No Project/No Development Alternative would not result in any physical changes to the Project site and there would not be a potential for new environmental impacts to occur. Overall, the No Project/No Development Alternative would result in fewer environmental impacts than the proposed Project because no construction or development would be take place. (Draft EIR, pp. 5-13 through 5-14.) Attainment of Project Objectives: The No Project/No Development Alternative would achieve only 1 of the 8 project objectives (the No Project Alternative would allow the continuation of parking/automobile storage for nearby car dealerships). Without the proposed Project, the Project site would not be developed with the proposed drive through restaurant and Ganahl Lumber hardware store and lumber yard uses. The No Project/No Development Alternative would not provide new employment opportunities within the City, nor would it expand the City's economic base. (Draft EIR, p. 5-14.) Finding: The City Council rejects Alternative 1: No Project/No Build Alternative because the alternative fails to meet most of the Project objectives for the reasons outlined above. This reason alone provides sufficient justification for rejection of this alternative. 2. Alternative 2: No Restaurant Use Description: This alternative would include the Ganahl Lumber store as proposed but would eliminate the 6,000 square feet (sf) of drive-through restaurant uses. This would result in no restaurant tenant and would reduce daily traffic trips to/from the site. (Draft EIR, pp. 5-10 through 5-11.) Impacts: Aesthetics Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility; however, no drive-through restaurant uses would be developed. Alternative 2 represents a reduction in 6,000 sf of drive 176 6/2/2020 through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. Similar to the proposed Project, Alternative 2 would have less than significant impacts related to scenic vistas, scenic resources, light, glare, and the existing visual character of the Project site and its surroundings. Additionally, both the proposed Project and Alternative 1 would have no impact associated with State Scenic Highways because no official State Scenic Highways are located in the vicinity of the Project. Similar to the proposed Project, Alternative 2 would require the preparation of a lighting plan and photometric study, which would be approved by the City. Mitigation Measures AES -1 and AES -2 would still be applicable under Alternative 2 to ensure that new sources of light and glare do not impact adjacent land uses; additionally, nighttime lighting would be limited to lighting necessary for security, and lighting would be shielded to reduce glare and spill lighting effects on adjacent sensitive uses. Therefore, the overall visual impacts of Alternative 2 would be less than significant and similar to those of the proposed Project. With the incorporation of Mitigation Measures AES -1 and AES -2, Alternative 2 would have less than significant impacts with respect to aesthetics. Overall, impacts to aesthetics under Alternative 2 are reduced but similar to impacts associated with the proposed Project. Because impacts related to aesthetics for Alternative 2 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, p. 4.1-15.) Air QualL Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space 177 6/2/2020 vehicle storage facility, but no drive-through restaurant uses would be developed. Alternative 2 represents a reduction in 6,000 sf of drive through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. For the reasons stated above, it can be assumed that construction -related criteria air pollutant emissions generated under Alternative 2 would be similar, but slightly less, than emissions expected under the proposed Project. As discussed in Section 4.2.6, Project Impacts, of the Draft EIR, the proposed Project would generate construction emissions below both SCAQMD's regional significance thresholds and SCAQMD's LSTs. Therefore, the reduced development intensity of Alternative 2 would also result in construction emissions below these thresholds. Implementation of Alternative 2 would result in the long-term emission of ROG, NOx, SO2, CO, PMio, and PM2.5. Table 4.2.1 (found at Draft EIR, p. 4.2-23) compares the maximum daily regional operations emissions of Alternative 2 and the proposed Project. As shown in Table 4.2.1 (found at Draft EIR, p. 4.2-23), Alternative 2 would result in fewer operational criteria air pollutants than the proposed Project. Therefore, because Alternative 2 results in fewer operational emissions as compared to the proposed Project, Alternative 2 would not exceed the significance thresholds of criteria pollutants for which the Project region is nonattainment under the CAAQS or NAAQS. Alternative 2 has also been evaluated for localized pollutant emissions. In order to provide a conservative assessment, the emissions shown in Table 4.2.J (found at Draft EIR, p. 4.2-23) include all on-site project - related stationary sources, as well as 10 percent of the Project -related mobile sources. Table 4.2.J shows the maximum daily emissions for operational activities under Alternative 2 as compared to the proposed Project. 178 6/2/2020 As seen in Table 4.2A Alternative 2 would result in fewer on-site generated localized pollutants when compared to the proposed Project. Therefore, because Alternative 2 would result in fewer localized operations emissions as compared to the proposed Project, Alternative 2 would not exceed the LSTs established by the SCAQMD, and localized emissions from operation of Alternative 2 would not expose sensitive receptors to substantial pollutant concentrations. Similar to the proposed Project, Alternative 2 would be required to comply with the SCAQMD's AQMP. In order to determine consistency with SCAQMD's air quality planning two main criteria must be addressed. The first criterion involves consistency with the State's ambient air quality standards and the NAAQS, which is determined based on whether a project exceeds regional and localized thresholds of significance. The second criterion relates to a project's consistency with regional growth projections, which are used to develop future air quality forecasts for the AQMP. Alternative 2 would be below the SCAQMD regional and localized thresholds for construction and operations and is consistent with the land use designation and development density presented in the City's General Plan. Similar to the proposed Project, Alternative 2 is consistent with these two criteria, and therefore, would not conflict with the SCAQMD AQMP. Alternative 2 would not result in the development of any substantial sources of air toxics. Alternative 2 would not involve any stationary sources associated with operations and would not attract substantial amounts of heavy-duty trucks that spend long periods queuing and idling at the Project site. Alternative 2 has been evaluated against SCAQMD's operational phase LST protocol, and on-site project emissions would result in slightly less concentrations of pollutants at nearby sensitive receptors as compared to the proposed Project. Overall, Alternative 2 would have less than significant impacts with respect to air quality, and impacts would be further reduced with the incorporation of Regulatory Compliance Measures AQ -1 through AQ -3, which would also be required for Alternative 2. Overall, impacts to air quality under Alternative 2 are reduced, but similar to impacts associated with the proposed Project. Because impacts related to air quality for Alternative 2 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant. (Draft EIR, pp. 4.2-23 through 4.2-24.) Biological Resources Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility but no drive-through restaurant uses would be developed. The reduction of drive-through restaurant use square footage 179 6/2/2020 on Area A would allow for Area A to accommodate additional parking as compared to the proposed Project. Area A would provide approximately 150 parking spaces, whereas the proposed Project would provide 62 parking spaces on Area A. Components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading would not change under the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates would not vary between the proposed Project and Alternative 2. Unlike the proposed Project, Alternative 2 would involve the grading and paving of Area A for surface parking but no building pads for drive-through restaurant uses would be constructed. Similar to the proposed Project, Alternative 2 would remove all existing vegetation on the Project site. Although Alternative 2 would not involve the construction of a building pad or drive-through restaurant on Area A, the Project site would be cleared, excavated, graded, and paved, as under the proposed Project. The area of disturbance would be the same under the proposed Project and Alternative 2. Therefore, Mitigation Measures 1310- 1, B10-2, and B10-3 would still be applicable under Alternative 2 to ensure that potential impacts to biological resources are reduced to a less than significant level. Therefore, biological impacts associated with Alternative 2 are considered to be less than significant with mitigation and similar to those of the proposed Project. Because impacts related to biological resources for Alternative 2 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, p. 4.3-15.) ultural Resources Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but no drive-through restaurant uses would be developed. This alternative represents a reduction of 6,000 sf of drive through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls 180 6/2/2020 fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. Although Alternative 2 would not involve the construction of restaurant structures, the area of disturbance is the same as under the proposed Project and potential impacts to unknown cultural resources would be similar for Alternative 1 as to those of the proposed Project. Mitigation Measures CULA and CUL -2 would still be applicable under Alternative 2 to protect any unknown archaeological resources and previously undiscovered buried human remains. Overall, impacts to cultural resources under Alternative 2 would be similar to the proposed Project's impacts. With the incorporation of mitigation, Alternative 2 would have less than significant impacts to archaeological resources and previously undiscovered buried human remains. Because impacts related to cultural resources for Alternative 2 would be less than those associated with the proposed Project, implementation of Mitigation Measures CUL -1 and CUL -2 would also ensure that Alternative 2, together with cumulative projects, would not result in a significant cumulative impact to unique archaeological resources and previously undiscovered buried human remains. (Draft EIR, p. 4.4-9.) Energy Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but no drive-through restaurant uses would be developed. This alternative represents a reduction of 6,000 sf of drive through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Alternative 2 would involve the grading and paving of Area A for surface parking; however, no construction of a drive through restaurant uses would occur. Although Alternative 2 would not involve the development of 181 6/2/2020 structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. Construction. Similar to the proposed Project, Alternative 2 would require gasoline -powered haul trucks for construction activities. However, as Alternative 2 would result in a reduction of 6,000 sf of drive-through restaurant use, fuel consumption under this alternative would be slightly less than estimated for the proposed Project, as shown in Table 4.5.B (found at Draft EIR, p. 4.5-13). Operation. Under Alternative 2, daily trips would decrease approximately 37 percent as compared to the proposed Project, and would therefore reduce operational fuel consumption. As shown in Table 4.5.B (found at Draft EIR, p. 4.5-13), Alternative 2 would result in the use of 160,697 less gallons of fuel per year during operations as compared to the proposed Project. Additionally, natural gas consumption would be reduced by approximately 80 percent, and electricity consumption would be reduced by approximately 12 percent during operation as compared to the proposed Project. Summary. Electricity, natural gas, and operational fuel consumption would be reduced under Alternative 2. However, construction -related fuel consumption would remain unchanged. Overall, impacts to energy under Alternative 2 are reduced, but similar to impacts associated with the proposed Project. Regulatory Compliance Measure E-1 would still be applicable under Alternative 2 to ensure that the Project would not result in the wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation. With incorporation of Regulatory Compliance Measure E-1, Alternative 2 would have less than significant impacts with respect to energy. Because impacts related to energy for Alternative 2 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, pp. 4.5-12 through 4.5-13.) Geology and Soils Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but no drive-through restaurant uses would be developed. This alternative represents a reduction of 6,000 sf of drive through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. 182 6/2/2020 Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. Although Alternative 2 would construct fewer structures than the proposed Project, it would be located on the same soils with the same geological conditions and would therefore result in potentially significant impacts with respect to strong seismic ground shaking, ground failure (including liquefaction), slope stability, corrosive soils, ground settlement, expansive soils, and the destruction of paleontological resources, similar to the proposed Project. Therefore, Mitigation Measures GEO-1, GEO-2, GEO- 3, and GEO-4 as stated above would be applicable to Alternative 2, similar to the proposed Project. With the implementation of the mitigation measures, potential impacts for Alternative 2 with respect to geology and soils would be less than significant and similar to those of the proposed Project. Because impacts related to geology and soils for Alternative 2 would be less than those associated with the proposed Project, implementation of Mitigation Measures CULA and CUL -2 would also ensure that Alternative 2, together with cumulative projects, would not result in a significant cumulative impact to unique archaeological resources and previously undiscovered buried human remains. (Draft EIR, pp. 4.6-19 through 4.6-20.) Greenhouse Gas Emissions Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but no drive-through restaurant uses would be developed. Alternative 2 represents a reduction in 6,000 sf of drive through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components 183 6/2/2020 specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. For the reasons stated above, it can be assumed that construction -related GHG emissions generated under Alternative 2 would be similar, but slightly less, than emissions expected under the proposed Project. As discussed in Section 4.7.6, Project Impacts, of the Draft EIR, GHG emissions generated during construction of the proposed Project would be temporary and would cease upon project completion. Similarly, GHG emissions generated during construction of Alternative 2 would be temporary, would cease upon project completion, and would not result in a permanent increase in emissions, and therefore, impacts would be less than significant. Implementation of Alternative 2 would result in long-term operational GHG emissions. Table 4.7.E (found at Draft EIR, p. 4.7-15) compares the long- term operational GHG emissions of Alternative 2 and the proposed Project. As shown in Table 4.7.E (found at Draft EIR, p. 4.7-15), Alternative 2 would result in 1,460 MT per year fewer CO2e emissions as compared to the proposed Project. Additionally, GHG emissions generated under Alternative 2 would fall under the SCAQMD interim screening -level bright - line threshold of 3,000 MT of CO2e per year. As such, impacts under Alternative 2 would be slightly less, but similar to the proposed Project and less than significant. Similar to the proposed Project, Alternative 2 would not conflict with the goals of the 2016-2040 RTP/SCS. Additionally, Alternative 2 would not be considered regionally significant per State CEQA Guidelines Section 15206. Thus, the Project would not conflict with the 2016-2040 RTP/SCS targets because those targets were established and are applicable on a regional level. Alternative 2 would have less than significant impacts with respect to GHG emissions. Overall, impacts to GHG emissions under Alternative 2 are reduced, but similar to impacts associated with the proposed Project. Because impacts related to GHG emissions for Alternative 2 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant. (Draft EIR, pp. 4.7-14 through 4.7-15.) 184 6/2/2020 Hazards and Hazardous Materials Alternative 2 would allow for the future construction of a 161,385 square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but no drive-through restaurant uses would be developed. This Alternative represents a reduction of 6,000 sf of drive through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. The potential for hazards and hazardous materials associated with the proposed Project to occur on site would not change under Alternative 2. Alternative 2 would involve the grading and paving of the entirety of Area A for surface parking; however, no construction of a drive-through restaurant uses would occur. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. The Project site is not located on a listed hazardous materials site, is not within an airport land use plan, and is not within a high fire hazard/wildland fire area. However, similar to the proposed Project, Alternative 2 would result in potentially significant impacts with respect to the discovery of unknown hazardous materials during construction. Alternative 2 would adhere to BMPs, codes, and ordinances to reduce impacts related to the transport, use, or disposal of hazardous materials, project -produced hazardous emissions, and emergency access applicable to the proposed Project. Construction and operation would be similar under Alternative 2 as under the proposed Project and therefore, the BMPs, codes, and ordinances that the proposed Project would adhere to would be also applicable to Alternative 2. Alternative 2 would require compliance with Mitigation Measure HAZ-1. With the incorporation of mitigation, Alternative 2 would have less than significant impacts with respect to hazards and hazardous materials. 185 6/2/2020 Overall, impacts to hazards and hazardous materials under Alternative 2 are reduced, but similar to impacts associated with the proposed Project. Because impacts with regard to hazards and hazardous materials would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, pp. 4.8-12 through 4.8-13.) Hvdrologv and Water Qualit Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but no drive-through restaurant uses would be developed. This alternative represents a reduction of 6,000 sf of drive through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Alternative 2 would involve the grading and paving of Area A for surface parking; however, no construction of a drive-through restaurant uses would occur. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. Similar to the proposed Project, Alternative 2 would change the use on the Project site, increase impervious surface area, increase stormwater runoff, and change the pollutants of concern in stormwater runoff. Alternative 2 would be required to comply with all NPDES regulations, including the Construction General Permit, South Orange County MS4 Permit, and Groundwater Discharge Permit (Regulatory Compliance Measures WQ- 1 through WQ-3). In addition, a Final WQMP and Hydrology and Hydraulics Analysis would be required to be prepared and implemented for Alternative 2 (Regulatory Compliance Measures WQ-4 and WQ-5). Implementation of BMPs and drainage infrastructure would be required to reduce pollutants of concern on the Project site and convey stormwater runoff in compliance with NPDES and City requirements. 186 6/2/2020 Similar to the proposed Project, Alternative 2 would be constructed within a 100 -year floodplain. Alternative 2 would comply with existing NFIP, FEMA, and City regulations governing development within a 100 -year floodplain. An elevation certification would be obtained from a certified engineer or surveyor and a Conditional Letter of Map Revision (CLOMR- F) and Letter of Map Revision (LOMR-F) would be obtained from FEMA, as required by Regulatory Compliance Measures WQ-6 and WQ-7. With compliance with adopted regulations, Alternative 2 would result in less than significant impacts related to hydrology and water quality. With implementation of BMPs and drainage infrastructure in compliance with adopted regulations, the hydrology and water quality impacts of Alternative 2 would be similar to those of the proposed Project. Because impacts related to hydrology and water quality for Alternative 2 would be similar to those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Final EIR, pp. 4.9-29 through 4.9-30.) Land Use and Planni Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) of Ganahl Lumber hardware store and lumber yard and a 399 - space vehicle storage facility, but no drive-through restaurant uses would be developed. This alternative represents a reduction of 6,000 sf of drive through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. Similar to the proposed Project, Alternative 2 would have less than significant impacts related to land use and planning. Under this Alternative, as well as the proposed Project, there would be no impacts related to the division of an existing community. Though Alternative 2 187 6/2/2020 would not include any drive-through restaurant use on Area A as compared to 6,000 sf under the proposed Project, the uses of Areas B and C would be the same under the proposed Project and Alternative 2. Therefore, Alternative 2 would still be consistent with both the existing General Plan land use designation of Quasi -Industrial and zoning classification of Commercial Manufacturing. As under the proposed Project, the implementation of Alternative 2 would not require a General Plan Amendment or Zoning Amendment. Alternative 2 would be consistent with the policies contained in the City's General Plan, the City's zoning code, the Southern California Association of Government's (SCAG) 2008 Regional Comprehensive Plan, and the SCAG 2016-2040 RTP/SCS. Therefore, impacts related to land use for Alternative 2 are considered to be less than significant and similar to those associated with the proposed Project. Because impacts related to land use and planning for Alternative 2 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, pp. 4.10-26 through 4.10-27.) Noise Alternative 2 would allow for the future construction of a 161,385 square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but no restaurant uses would be developed. This alternative represents a reduction of 6,000 sf of drive-through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Alternative 2 would involve the grading and paving of Area A for surface parking; however, no construction of a drive through restaurant uses would occur. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. Construction Noise and Vibration. Grading and site preparation activities are the loudest aspects of construction, and the grading and site 188 6/2/2020 preparation involved with Alternative 2 require the same amount of ground disturbance as the proposed Project as the location of the restaurant uses would still be developed with parking and internal driveways. Therefore, similar to the proposed Project, Alternative 2 would encompass the same amount of acreage within the same proximity to noise receptors. However, Alternative 2 would result in the construction of less building space (6,000 fewer square feet). Therefore, construction -related noise generated under this alternative would be produced for a slightly shorter period of time than the proposed Project. Similar to the proposed Project, Alternative 2 would also implement Mitigation Measure NO1-1, which requires adherence to daytime noise restrictions and Mitigation Measure NO1-2, which includes noise control and sound attenuation measures to reduce noise impacts on sensitive land uses. Alternative 2 would result in the same amount of ground vibration as the proposed Project. Similar to the proposed Project, the use of any type of construction equipment during construction of Alternative 2 would not result in a ground -borne vibration velocity level above 0.2 inch/sec at the nearest off-site structures. Operational Noise. Operational noise sources associated with Alternative 2 would include mobile and stationary sources (i.e., mechanical equipment, lumber yard operations). Alternative 2 would generate 37 percent less traffic on vicinity roadways. The decrease in automobile trips would equate to similar to slightly less traffic noise compared with the proposed Project, depending on the specific roadway segments. For instance, the greatest reduction of traffic noise would occur on the segment of Stonehill Drive between the Project Driveway and Camino Capistrano. Specifically, 37 percent less project traffic on the segment of Stonehill Drive between the Project Driveway and Camino Capistrano would result in a 0.3 dBA CNEL decrease compared with the proposed Project. All the remaining vicinity roadway segments would experience the same level of traffic noise with implementation of Alternative 2 compared with the proposed Project. Alternative 2 would include several on-site noise sources included in the proposed Project such material handling vehicles stacking, loading and unloading products, back-up beepers, delivery trucks, a trash compactor, a baler, and other mechanical equipment and parking lot noise. However, Alternative 2 would not include any fast-food restaurants. Predicted on-site operational noise attributable to Alternative 2 would range from 3.7 dBA below noise levels to 3.3 dBA above noise levels at the receptors as compared to the proposed Project. Furthermore, all noise levels would remain below the applicable daytime and nighttime noise standards. Summary. Overall, noise impacts with respect to Alternative 2 would result in the same significance conclusions as the proposed Project. 189 6/2/2020 Therefore, Alternative 2 impacts would be similar to the impacts associated with implementation of the proposed Project. Implementation of Mitigation Measures NOIR and N0I-2 would ensure that construction of Alternative 2, together with cumulative projects, would not result in a significant cumulative impact as a result of construction noise. Because operational impacts related to noise for Alternative 2 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, pp. 4.11-21 through 4.11-22.) Transportation Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but would not include any restaurant uses. Based on the same trip generation rates used for the proposed Project, Project Alternative 2 is anticipated to generate approximately 2,073 ADT, including 189 trips (105 inbound and 84 outbound) in the a.m. peak hour and 121 trips (52 inbound and 69 outbound) in the p.m. peak hour. Alternative 2 Existing Plus Project — Significant and Unavoidable Impact. Based on results of the Alternative 2 Existing Plus Project peak - hour LOS analysis for the study area intersections included in the TIA, all study area intersections, including the hot -spot intersections, are anticipated to operate at satisfactory LOS based on the ICU and the HCM methodology. Therefore, a significant Alternative 2 impact would not occur at any study area intersection based on either the ICU or HCM methodologies. In addition to evaluating project -related study area intersections, the Existing Plus Project analysis for Alternative 2 also evaluated impacts with respect to roadway segment ADT volumes, v/c ratios, and LOS. Results of this analysis indicate that all study area roadway segments, including the hotspot roadways, are anticipated to operate at satisfactory LOS with Alternative 2, with the exception of Stonehill Drive between Camino Capistrano and the Project Driveway (LOS E), Stonehill Drive between the Project Driveway and Del Obispo Street (LOS D), and Valle Road between San Juan Creek Road and the 1-5 northbound ramps (LOS F). The v/c ratio for Stonehill Drive between Camino Capistrano and the Project Driveway would increase by 0.040 in the Existing Plus Alternative 2 condition. This is considered a significant unavoidable impact because there is no available right -of way as a feasible improvement to widen Stonehill Drive to provide additional roadway capacity. However, the v/c ratios do not increase by 0.01 or greater for Stonehill Drive between the Project Driveway and Del Obispo Street and Valle Road between San 190 6/2/2020 Juan Creek Road and the 1-5 northbound ramps in the Existing Plus Alternative 2 condition and therefore impacts at these locations are not considered significant. Although a significant project impact would occur at one study area roadway segment (Stonehill Drive between Camino Capistrano and the Project Driveway), a peak -hour link analysis shows that this segment would operate at satisfactory LOS in both directions during the peak hours. Alternative 2 Existing Plus Project Plus Cumulative (Year 2024) - Significant and Unavoidable Impact. Based on the results of the Alternative 2 Existing Plus Project Plus Cumulative peak -hour LOS analysis included in the TIA, all study area intersections, including the hot - spot intersections, are forecast to operate at satisfactory LOS based on the ICU methodology, with the exception of Del Obispo Street/Stonehill Drive (LOS D in the a.m. peak hour). However, Alternative 2 would not add 0.01 or greater to the v/c ratio at this intersection (0.006). Therefore, a significant Alternative 2 cumulative impact would not occur at any study area intersection based on the ICU methodology. In addition, all study area intersections, including the hot -spot intersections, are forecast to operate at satisfactory LOS based on the HCM methodology. Therefore, a significant Alternative 2 cumulative impact would not occur at any study area intersection based on the HCM methodology. Alternative 2 Existing Plus Project Plus Cumulative roadway segment ADT volumes, v/c ratios, and LOS were also evaluated in the TIA. Results of this analysis indicate that all study area roadway segments, including the hot -spot roadways, are forecast to operate at satisfactory LOS, with the exception of San Juan Creek Road between Valle Road and Camino Capistrano (LOS E), Stonehill Drive between Camino Capistrano and the Project Driveway (LOS E), Stonehill Drive between the Project Driveway and Del Obispo Street (LOS D), and Valle Road between San Juan Creek Road and the 1-5 northbound ramps (LOS F). The v/c ratio for Stonehill Drive between Camino Capistrano and the Project Driveway would increase by 0.040. This is considered a significant unavoidable impact because there is no available right-of-way as a feasible improvement to widen Stonehill Drive to provide additional roadway capacity. However, the v/c ratios do not increase by 0.01 or greater for San Juan Creek Road between Valle Road and Camino Capistrano, Stonehill Drive between the Project Driveway and Del Obispo Street, and Valle Road between San Juan Creek Road and the 1-5 northbound ramps and therefore impacts at these locations are not considered significant. Although a significant Alternative 2 impact would occur at one study area roadway segment (Stonehill Drive between Camino Capistrano and the Project Driveway), a peakhour link analysis shows that this segment would operate at satisfactory LOS in both directions during the peak hours. 191 6/2/2020 Alternative 2 Buildout (Year 2040) - Significant and Unavoidable Impact. Based on the results of the Buildout (2040) peak -hour LOS analysis for the study area intersections, all study area intersections, including the hot -spot intersections, are forecast to operate at satisfactory LOS based on the ICU methodology, with the exception of Del Obispo Street/Stonehill Drive (LOS D in the a.m. peak hour). However, Alternative 2 would not add 0.01 or greater to the v/c ratio at this intersection (0.007). Therefore, a significant Alternative 2 buildout impact would not occur at any study area intersection based on the ICU methodology. All study area intersections, including the hot -spot intersections, are forecast to operate at satisfactory LOS based on the HCM methodology. Therefore, a significant Alternative 2 buildout impact would not occur at any study area intersection based on the HCM methodology. Impacts to roadway segment ADT volumes, v/c ratios, and LOS were also evaluated as part of the Alternative 2 Buildout (Year 2040) analysis. Results of this analysis indicate that all study area roadway segments, including the hot -spot roadways, are forecast to operate at satisfactory LOS with the exception of San Juan Creek Road between Valle Road and Camino Capistrano (LOS E), Stonehill Drive between Camino Capistrano and the Project Driveway (LOS E), Stonehill Drive between the Project Driveway and Del Obispo Street (LOS E), and Valle Road between San Juan Creek Road and the 1-5 northbound ramps (LOS F). The v/c ratio for Stonehill Drive between Camino Capistrano and the Project Driveway would increase by 0.040. This is considered a significant unavoidable impact because there is no available right-of-way as a feasible improvement to widen Stonehill Drive to provide additional roadway capacity. However, the v/c ratios do not increase by 0.01 or greater for San Juan Creek Road between Valle Road and Camino Capistrano, Stonehill Drive between the Project Driveway and Del Obispo Street, and Valle Road between San Juan Creek Road and the 1-5 northbound ramps and therefore impacts at these locations are not considered significant. Although a significant Alternative 2 impact would occur at one study area roadway segment (Stonehill Drive between Camino Capistrano and the Project Driveway), a peak -hour link analysis shows that this segment would operate at satisfactory LOS in both directions during the peak hours. Signal Warrant Analysis. The TIA also included a signal warrant analysis for Alternative 2. Results of this analysis indicate that installation of a traffic signal would not be warranted under any of the existing and forecasted scenarios. Although a traffic signal is not warranted based on the forecast peak -hour traffic volumes at this intersection, a traffic signal is recommended to ensure safe inbound and outbound access to/from the Project site along Stonehill Drive. 192 6/2/2020 Summary. Overall, transportation impacts with respect to Alternative 2 would be slightly reduced as compared to the proposed Project. Unlike the proposed Project, Alternative 2 would not result in significant unavoidable impacts to the intersection of Del Obispo/Stonehill Drive (in the AM peak hour) under the Alternative 2 Existing Plus Project Plus Cumulative, or the Alternative 2 Buildout scenarios. Therefore, although Alternative 2 impacts would significant and unavoidable, they would be less than those associated with implementation of the proposed Project. Although impacts related to transportation for Alternative 2 would be less than those associated with the proposed Project, cumulative impacts associated with Alternative 2 would be cumulatively significant and would be considered significant unavoidable impacts. (Final EIR, pp. 4.12-31 through 4.12-33.) Tribal Cultural Resources Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but no drive-through restaurant uses would be developed. This alternative represents a reduction of 6,000 sq of drive- through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Alternative 2 would have less than significant impacts with respect to tribal cultural resources with the incorporation of mitigation, similar to the proposed Project. Though Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. Because the area of disturbance would be the same under the proposed Project and Alternative 2, potential impacts to unknown tribal cultural resources would be similar under Alternative 2 to those of the proposed Project. Mitigation Measures CUL -1 and CUL -2 would still be applicable under Alternative 2 to reduce potential impacts to any unknown tribal cultural resources to a less than significant level. 193 6/2/2020 Overall, impacts to tribal cultural resources under Alternative 2 would be similar to the proposed Project's impacts. Because impacts related to cultural resources for Alternative 2 would be less than those associated with the proposed Project, implementation of Mitigation Measures CUL -1 and CUL -2 would also ensure that Alternative 2, together with cumulative projects, would not result in a significant cumulative impact to unique archaeological resources and previously undiscovered buried human remains. (Draft EIR, pp. 4.13-8 through 4.13-9.) Utilities and Service Systems Alternative 2 would allow for the future construction of a 161,385 -square - foot (sf) Ganahl Lumber hardware store and lumber yard and a 399 -space vehicle storage facility, but no drive-through restaurant uses would be developed. Alternative 2 represents a reduction of 6,000 sf of drive through restaurant use as compared to the proposed Project. Under Alternative 2, Area A would provide 150 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing, and grading, would not significantly change with the implementation of Alternative 2. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would also not change under Alternative 2. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 2. Although Alternative 2 would not involve the development of structures on Area A as the proposed Project would, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking. Although Alternative 2 would not include any drive-through restaurant uses, the Ganahl Lumber hardware store, lumber yard, and vehicle storage facility would be constructed and all of the same utilities required for the proposed Project would also be required for Alternative 2. Although specific estimates for the water demand and wastewater generation attributed to the proposed Project's drive-through restaurant uses cannot be developed using the general land use factors supplied by the City's Utilities Department (these factors rely on the number of acres of each land use rather than the actual building square footage that is proposed), it is reasonable to conclude that Alternative 2 would result in an incrementally lower demand for water and would generate incrementally less wastewater than the proposed Project because, unlike the proposed Project, it would not include any drive-through restaurant uses. Additionally, as described in Section 4.5, Energy, of the Draft EIR, natural 194 6/2/2020 gas consumption would be reduced by approximately 80 percent under Alternative 2, and electricity consumption would be reduced by approximately 12 percent during operation as compared to the proposed Project. Similar to the proposed Project, Alternative 2 would also require compliance with Regulatory Compliance Measures UTLA through UTL- 3 and Mitigation Measures UTLA and UTL-2 because it would still be required to comply with the 2019 Building Energy Efficiency Standards and would also connect to the City's domestic water and sewer system. Similar to the proposed Project, Alternative 2 would change the use on the Project site, increase impervious surface area, and increase stormwater runoff. A Final WQMP and Hydrology and Hydraulics Analysis would be required to be prepared and implemented for Alternative 2 (Regulatory Compliance Measures WQ-4 and WQ-5). Implementation of drainage infrastructure would be required to convey stormwater runoff in compliance with and City requirements. With the incorporation of mitigation, Alternative 2 would have less than significant impacts with respect to utilities and service systems. Overall, impacts to utilities and service systems under Alternative 2 are reduced, but similar to impacts associated with the proposed Project. Because utility and service system demands for Alternative 2 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, pp. 4.14-23 through 4.14-24.) Attainment of Project Objectives: Alternative 2 would only partially meet the objective of developing a lumber store that provides building supplies and hardware to professional contractors and the public, while also providing casual restaurant uses and automobile storage facilities (Objective 1) because Alternative 2 would not include any restaurant uses. Alternative 2 would allow the continuation of parking/automobile storage for nearby car dealerships (Objective 4), provide an easement for future private emergency access from the Project site to Avenida Aeropuerto along the westernmost boundary of the Capistrano Valley Mobile Estates (Objective 7), and include conservation and sustainability features to be consistent with the California's Title 24 Energy Code requirements (Objective 8). However, this alternative would not meet the objective of maximizing the potential of the Project site to serve as a well-designed and landscaped mixed-use project that is compatible with the surrounding community (Objectives 3). Additionally, by eliminating the proposed drive-through restaurant uses, Alternative 2 would reduce the potential revenue generated for the City's tax base by reducing the amount of new retail sales on the Project site, and invigorate the local economy less by providing fewer new employment and business opportunities in the City (Objectives 5 and 6) than the proposed Project. 195 6/2/2020 Therefore, this alternative would meet some of the Project objectives, but not to the same degree as the proposed Project. (Draft EIR, p. 5-10.) Finding: The City Council rejects Alternative 2: No Restaurant Use, on the following grounds, which individually provides sufficient justification for rejection of this alternative: (1) the alternative fails to meet most of the Project objectives for the reasons outlined above; and (2) the alternative fails to avoid or reduce the Project's significant and unavoidable impacts relating to transportation. 3. Alternative 3: 2,000 Square Feet of Restaurant Uses Description: This alternative would include the Ganahl Lumber store as proposed but would reduce the square footage of the restaurant uses from 6,000 square feet (sf) to 2,000 sf. This would most likely result in one restaurant tenant and would reduce daily traffic trips to/from the site. (Draft EIR, p. 5-12.) Impacts: Aesthetics Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sq of drive-through restaurant uses as compared to the proposed Project. Specifically, Alternative 2 would provide 80 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading, would not significantly change with the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would also not change under Alternative 3. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 3. Under Alternative 3, similar to the proposed Project, the entirety of Area A would be cleared, excavated, graded, and paved to accommodate surface parking and a building pad. Similar to the proposed Project, Alternative 3 would have less than significant impacts related to scenic vistas, scenic resources, light, glare, and the existing visual character of the Project site and its surroundings. Additionally, both the proposed Project and Alternative 3 would have no impact associated with State Scenic Highways because no official State Scenic Highways are located in the vicinity of the Project. 196 6/2/2020 Similar to the proposed Project, Alternative 3 would require the preparation of a lighting plan and photometric study, which would be approved by the City. Mitigation Measures AES -1 and AES -2 would still be applicable under Alternative 3 to ensure that new sources of light and glare do not impact adjacent land uses; additionally, nighttime lighting would be limited to lighting necessary for security, and lighting would be shielded to reduce glare and spill lighting effects on adjacent sensitive uses. Therefore, the overall visual impacts of Alternative 3 would be less than significant and similar to those of the proposed Project. With the incorporation of Mitigation Measures AES -1 and AES -2, Alternative 3 would have less than significant impacts with respect to aesthetics. Overall, impacts to aesthetics under Alternative 3 are reduced but similar to impacts associated with the proposed Project. Because impacts related to aesthetics for Alternative 3 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. Air Quality Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. Specifically, Alternative 3 would provide 80 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading, would not significantly change with the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would also not change under Alternative 3. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 3. Under Alternative 3, similar to the proposed Project, the entirety of Area A would be cleared, excavated, graded, and paved to accommodate surface parking and a building pad. For the reasons stated above, it can be assumed that construction -related criteria air pollutant emissions generated under Alternative 3 would be similar, but slightly less, than emissions expected under the proposed Project. As discussed in Section 4.2.6, Project Impacts, of the Draft EIR, the proposed Project would generate construction emissions below both 197 6/2/2020 SCAQMD's regional significance thresholds and SCAQMD's LSTs. Therefore, the reduced development intensity of Alternative 3 would also result in construction emissions below these thresholds. Implementation of Alternative 3 would result in the long-term emission of ROG, NOx, S02, CO, PMio, and PM2.5. Table 4.2.K compares the maximum daily regional operations emissions of Alternative 2 and the proposed Project. As shown in Table 4.2.K, Alternative 3 would result in fewer operational criteria air pollutants than the proposed Project. Therefore, because Alternative 3 results in fewer operational emissions as compared to the proposed Project, Alternative 3 would not exceed the significance thresholds of criteria pollutants for which the Project region is nonattainment under the CAAQS or NAAQS. Alternative 3 has also been evaluated for localized pollutant emissions. In order to provide a conservative assessment, the emissions shown in Table 4.21 include all on-site project -related stationary sources, as well as 10 percent of the Project -related mobile sources. Table 4.21 shows the maximum daily emissions for operational activities under Alternative 3 as compared to the proposed Project. As seen in Table 4.21 of the Draft EIR, Alternative 3 would result in fewer on-site generated localized pollutants when compared to the proposed Project. Therefore, because Alternative 3 would result in fewer localized operations emissions as compared to the proposed Project, Alternative 3 would not exceed the LSTs established by the SCAQMD, and localized emissions from operation of Alternative 3 would not expose sensitive receptors to substantial pollutant concentrations. Similar to the proposed Project, Alternative 3 would be required to comply with the SCAQMD's AQMP. In order to determine consistency with SCAQMD's air quality planning two main criteria must be addressed. The first criterion involves consistency with the State's ambient air quality standards and the NAAQS, which is determined based on whether a project exceeds regional and localized thresholds of significance. The second criterion relates to a project's consistency with regional growth projections, which are used to develop future air quality forecasts for the AQMP. Alternative 3 would be below the SCAQMD regional and localized thresholds for construction and operations and is consistent with the land use designation and development density presented in the City's General Plan. Similar to the proposed Project, Alternative 3 is consistent with these two criteria, and therefore, would not conflict with the SCAQMD AQMP. Alternative 3 would not result in the development of any substantial sources of air toxics. Alternative 3 would not involve any stationary 198 6/2/2020 sources associated with operations and would not attract substantial amounts of heavy-duty trucks that spend long periods queuing and idling at the Project site. Alternative 3 has been evaluated against SCAQMD's operational phase LST protocol, and on-site project emissions would result in slightly less concentrations of pollutants at nearby sensitive receptors as compared to the proposed Project. Overall, Alternative 3 would have less than significant impacts with respect to air quality, and impacts would be further reduced with the incorporation of Regulatory Compliance Measures AQ -1 through AQ -3, which would also be required for Alternative 2. Overall, impacts to air quality under Alternative 3 are reduced, but similar to impacts associated with the proposed Project. Because impacts related to air quality for Alternative 3 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant. (Draft EIR, pp. 4.2-24 through 4.2-27.) Biological Resources Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. The reduction in drive-through square footage on Area A as compared to the proposed Project would allow for additional parking spaces. Under Alternative 3, Area A would provide approximately 80 parking spaces, whereas the proposed Project would provide 62 parking spaces. Components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading would not change under the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls fences, and gates, would not vary between the proposed Project and Alternative 3. Alternative 3 would involve the grading and paving of Area A for one building pad for drive-through restaurant use rather than two building pads for two drive through restaurants. Similar to the proposed Project, Alternative 3 would remove all existing vegetation on the Project site. The Project site, including Area A would be cleared, excavated, graded, and paved as under the proposed Project. The area of disturbance would be the same under the proposed Project and Alternative 3. Therefore, Mitigation Measures B10-1, B10-2, and B10-3 would still be applicable under Alternative 2 to ensure that potential impacts to biological resources are reduced to a less than significant level. Therefore, biological impacts associated with Alternative 3 are considered to be less than significant with mitigation and similar to those of the proposed Project. 199 6/2/2020 Because impacts related to biological resources for Alternative 3 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. Cultural Resources Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. The reduction in drive-through square footage on Area A as compared to the proposed Project would allow for additional parking spaces. Under Alternative 3, Area A would provide approximately 80 parking spaces, whereas the proposed Project would provide 62 parking spaces. Components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading would not change under the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would not vary between the proposed Project and Alternative 3. Alternative 3 would involve the grading and paving of Area A for one building pad for drive-through restaurant use rather than two building pads for two drive through restaurants. Although Alternative 3 would involve the construction of fewer structures than the proposed Project, the entirety of Area A would still be cleared, excavated, graded, and paved to accommodate surface parking and one building pad for the drive-through restaurant use. Because the area of disturbance is the same as under the proposed Project, potential impacts to unknown cultural resources would be similar for Alternative 3 as to those of the proposed Project. Mitigation Measures CULA and CUL -2 would still be applicable under Alternative 3 to protect any unknown archaeological resources and previously undiscovered buried human remains. Overall, impacts to cultural resources under Alternative 3 would be similar to the proposed Project's impacts. With the incorporation of mitigation, Alternative 3 would have less than significant impacts to archaeological resources and previously undiscovered buried human remains. Because impacts related to cultural resources for Alternative 3 would be less than those associated with the proposed Project, implementation of Mitigation Measures CULA and CUL -2 would also ensure that Alternative 3, together with cumulative projects, would not result in a 200 6/2/2020 significant cumulative impact to unique archaeological resources and previously undiscovered buried human remains. (Draft EIR, pp. 4.4-9 through 4.4-10.) Energy Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. Specifically, Alternative 3 would provide 80 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading, would not significantly change with the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would also not change under Alternative 3. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 3. Under Alternative 3, similar to the proposed Project, the entirety of Area A would be cleared, excavated, graded, and paved to accommodate surface parking and a building pad. Construction. Although Alternative 3 would result in a reduction of 4,000 sf of drive-through restaurant uses, Site A would still require grading and site preparation, and the required construction equipment and schedule would remain similar to the proposed Project. As shown in Table 4.5.0 (found at Draft EIR, p. 4.5-14), automotive fuel consumption during construction would remain unchanged as compared to the proposed Project. Operation. Under Alternative 3, daily trips would decrease approximately 25 percent as compared to the proposed Project, and would therefore reduce operational fuel consumption. As shown in Table 4.5.0 (found at Draft EIR, p. 4.5-14), Alternative 3 would result in the use of 105,722 less gallons of fuel per year during operations as compared to the proposed Project. Additionally, natural gas consumption would be reduced by approximately 53 percent, and electricity consumption would be reduced by 8 percent during operation as compared to the proposed Project. Summary. Electricity, natural gas, and operational fuel consumption would be reduced under Alternative 3. However, construction -related fuel consumption would remain unchanged. Overall, impacts to energy under Alternative 3 are reduced, but similar to impacts associated with the 201 6/2/2020 proposed Project. Regulatory Compliance Measure E-1 would still be applicable under Alternative 3 to ensure that the Project would not result in the wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation. With incorporation of Regulatory Compliance Measure E-1, Alternative 3 would have less than significant impacts with respect to energy. Because impacts related to energy for Alternative 3 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. Geologv_and Soils Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. Specifically, Alternative 3 would provide 80 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading, would not significantly change with the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would also not change under Alternative 3. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 3. Under Alternative 3, similar to the proposed Project, the entirety of Area A would be cleared, excavated, graded, and paved to accommodate surface parking and a building pad. Alternative 3 would construct less square footage than the proposed Project, but would be located on the same soils with the same geological conditions as the proposed Project and would therefore result in potentially significant impacts with respect to strong seismic ground shaking, ground failure (including liquefaction), slope stability, corrosive soils, ground settlement, expansive soils, and the destruction of paleontological resources without the implementation of mitigation measures. Therefore, Mitigation Measures GEO-1, GEO-2, GEO-3, and GEO-4 as stated above would be applicable under Alternative 3, similar to the proposed Project. With implementation of the mitigation measures, potential impacts for Alternative 3 with respect to geology and soils would be less than significant and similar to those of the proposed Project. (Draft EIR, p. 4.6-21.) Greenhouse Gas Emissions 202 6/2/2020 Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. Specifically, Alternative 3 would provide 80 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading, would not significantly change with the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would also not change under Alternative 3. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 3. Under Alternative 3, similar to the proposed Project, the entirety of Area A would be cleared, excavated, graded, and paved to accommodate surface parking and a building pad. For the reasons stated above, it can be assumed that construction -related GHG emissions generated under Alternative 3 would be similar, but slightly less, than emissions expected under the proposed Project. As discussed in Section 4.7.6, Project Impacts, of the Draft EIR, GHG emissions generated during construction of the proposed Project would be temporary and would cease upon project completion. Similarly, GHG emissions generated during construction of Alternative 3 would be temporary, would cease upon project completion, and would not result in a permanent increase in emissions, and therefore, impacts would be less than significant. Implementation of Alternative 3 would result in long-term operational GHG emissions. Table 4.7.F (found at Draft EIR, p. 4.7-16) compares the long- term operational GHG emissions of Alternative 3 and the proposed Project. As shown in Table 4.71 (found at Draft EIR, p. 4.7-16), Alternative 3 would result in 1,153 MT per year fewer CO2e emissions as compared to the proposed Project. As such, impacts under Alternative 3 would be slightly less, similar to the proposed Project and less than significant. Similar to the proposed Project, Alternative 3 would not conflict with the goals of the 2016-2040 RTP/SCS. Additionally, Alternative 3 would not be considered regionally significant per State CEQA Guidelines Section 15206. Thus, the Project would not conflict with the 2016-2040 RTP/SCS 203 6/2/2020 targets because those targets were established and are applicable on a regional level. Alternative 3 would have less than significant impacts with respect to GHG emissions. Overall, impacts to GHG emissions under Alternative 3 are reduced, but similar to impacts associated with the proposed Project. Because impacts related to GHG emissions for Alternative 3 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant. (Draft EIR, pp. 4.7-15 through 4.7-17.) Hazards and Hazardous Materials Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. Specifically, Alternative 3 would provide 80 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading, would not significantly change with the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would also not change under Alternative 3. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 3. Under Alternative 3, similar to the proposed Project, the entirety of Area A would be cleared, excavated, graded, and paved to accommodate surface parking and a building pad. The potential for hazards and hazardous materials associated with the proposed Project to occur on site would not change under Alternative 3. Alternative 3 would involve the grading and paving of the entirety of Area A for surface parking and a building pad. The Project site is not located on a listed hazardous materials site, is not within an airport land use plan, and is not within a high fire hazard/wildland fire area. However, similar to the proposed Project, Alternative 3 would result in potentially significant impacts with respect to the discovery of unknown hazardous materials during construction. Alternative 3 would adhere to BMPs, codes, and ordinances to reduce impacts related to the transport, use, or disposal of hazardous materials, project -produced hazardous emissions, and emergency access applicable to the proposed Project. 204 6/2/2020 Construction and operation would occur to a similar degree under Alternative 3 as for the proposed Project, therefore, the BMPs, codes, and ordinances that the proposed Project would adhere to would also be applicable to Alternative 3. Alternative 3 would require compliance with Mitigation Measure HAZA. With the incorporation of mitigation, Alternative 3 would have less than significant impacts with respect to hazards and hazardous materials. Overall, impacts to hazards and hazardous materials under Alternative 3 are reduced, but similar to impacts associated with the proposed Project. Because impacts with regard to hazards and hazardous materials would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, pp. 4.8-13 through 4.8-14.) Hvdroloav and Water Qualit Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. Specifically, Alternative 3 would provide 80 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading, would not significantly change with the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would also not change under Alternative 3. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 3. Under Alternative 3, similar to the proposed Project, the entirety of Area A would be cleared, excavated, graded, and paved to accommodate surface parking and a building pad. Similar to the proposed Project, Alternative 3 would change the use on the Project site, increase impervious surface area, increase stormwater runoff, and change the pollutants of concern in stormwater runoff. Alternative 3 would be required to comply with all NPDES regulations, including the Construction General Permit, South Orange County MS4 Permit, and Groundwater Discharge Permit (Regulatory Compliance Measures WQ- 1 through WQ-3). In addition, a Final WQMP and Hydrology and 205 6/2/2020 Hydraulics Analysis would be required to be prepared and implemented for Alternative 3 (Regulatory Compliance Measures WQ-4 and WQ-5). Implementation of BMPs and drainage infrastructure would be required to reduce pollutants of concern on the Project site and convey stormwater runoff in compliance with NPDES and City requirements. Similar to the proposed Project, Alternative 3 would be constructed within a 100 -year floodplain. Alternative 3 would comply with existing NFIP, FEMA, and City regulations governing development within a 100 -year floodplain. An elevation certification would be obtained from a certified engineer or surveyor and a Conditional Letter of Map Revision (CLOMR- F) and Letter of Map Revision (LOMR-F) would be obtained from FEMA, as required by Regulatory Compliance Measures WQ-6 and WQ-7. With compliance with adopted regulations, Alternative 3 would result in less than significant impacts related to hydrology and water quality. With implementation of BMPs and drainage infrastructure in compliance with adopted regulations, the hydrology and water quality impacts of Alternative 3 would be similar to those of the proposed Project. Because impacts related to hydrology and water quality for Alternative 3 would be similar to those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Final EIR, pp. 4.9-30 through 4.9-31.) Land Use and Planning Alternative 3 would allow for the future construction of a 161,385 sf of Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of drive-through restaurant uses, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. Specifically, Alternative 3 would provide 80 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading, would not significantly change with the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would also not change under Alternative 3. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 3. Under Alternative 3, similar to the proposed Project, the entirety of Area A would be cleared, excavated, graded, and paved to accommodate surface parking and a building pad. 206 6/2/2020 Similar to the proposed Project, Alternative 3 would have less than significant impacts related to land use and planning. Under this Alternative, as well as the proposed Project, there would be no impacts related to the division of an existing community. Although Alternative 3 would not include any drive-through restaurant use on Area A as compared to 6,000 sf under the proposed Project, the uses of Sites B and C would be the same under the proposed Project and Alternative 3. Therefore, Alternative 2 would still be consistent with both the existing General Plan land use designation of Quasi -Industrial and zoning classification of Commercial Manufacturing. As under the proposed Project, the implementation of Alternative 3 would not require a General Plan Amendment or Zoning Amendment. Alternative 3 would be consistent with the policies contained in the City's General Plan, the City's zoning code, the Southern California Association of Government's (SCAG) 2008 Regional Comprehensive Plan, and the SCAG 2016-2040 RTP/SCS. Therefore, impacts related to land use for Alternative 3 are considered to be less than significant and similar to those associated with the proposed Project. Because impacts related to land use and planning for Alternative 3 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, p. 4.10-27.) Noise Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of fast-food restaurant use, which represents a reduction of 4,000 sf of drive-through restaurant uses as compared to the proposed Project. Specifically, Alternative 3 would provide 80 parking spaces, compared to 62 parking spaces provided in Area A as part of the proposed Project. Most components of the proposed Project, such as outdoor lighting, circulation and access, signage, utilities and drainage, sustainability features, landscaping, and construction phasing and grading, would not significantly change with the implementation of Alternative 3. Components specific to Area A, such as the location of walkways, retaining walls, fences, and gates, would also not change under Alternative 3. The modification and installation of existing and new utilities and infrastructure associated with the proposed Project would still occur under Alternative 3. Under Alternative 3, similar to the proposed Project, the entirety of Area A would be cleared, excavated, graded, and paved to accommodate surface parking and a building pad. 207 6/2/2020 Construction Noise and Vibration. As discussed above, grading and site preparation activities are the loudest aspects of construction, and the grading and site preparation involved with Alternative 3 require the same amount of ground disturbance as the proposed Project. Therefore, similar to the proposed Project, Alternative 3 would include the same amount of acreage within the same proximity to vicinity noise receptors. However, Alternative 3 would result in the construction of less building space (4,000 fewer square feet). Therefore, construction -related noise generated under this alternative would be produced for a slightly shorter period of time than the proposed Project. Similar to the proposed Project, Alternative 3 would also implement Mitigation Measure NOI-1, which requires adherence to daytime noise restrictions, and Mitigation Measure N0I-2, which includes noise control and sound attenuation measures to reduce noise impacts on sensitive land uses. Alternative 3 would result in the same amount of ground vibration as the proposed Project. As with the proposed Project, the use of virtually any type of construction equipment during construction of Alternative 3 would not result in a ground -borne vibration velocity level above 0.2 inch/sec at the nearest off-site structures. Operational Noise. Operational noise sources associated with Alternative 3 would include mobile and stationary (i.e., fast food restaurant drive through, mechanical equipment, lumber yard operations) sources. Alternative 3 would generate approximately 25 percent less traffic on vicinity roadways. Such a decrease in automobile trips would equate to similar to slightly less traffic noise compared with the proposed Project, depending on the specific roadway segments. For instance, the greatest reduction of traffic noise would occur on the segment of Stonehill Drive between the Project Driveway and Camino Capistrano. Specifically, 25 percent less project traffic on the segment of Stonehill Drive between the Project Driveway and Camino Capistrano would result in a 0.1 dBA CNEL decrease compared with the proposed Project. All the remaining vicinity roadway segments would experience the same level of traffic noise with implementation of Alternative 3 compared with the proposed Project. Alternative 3 would include several on-site noise sources included in the proposed Project such material handling vehicles stacking, loading and unloading products, back-up beepers, delivery trucks, a trash compactor, a baler, and other mechanical equipment and parking lot noise. Compared with the proposed Project, Alternative 3 levels range from 2.2 dBA below to 0.6 dBA above noise levels at the receptors as compared to the proposed Project. However, noise levels at these locations would still not exceed noise thresholds for daytime, evening, or nighttime periods. 208 6/2/2020 Summary. Overall, noise impacts with respect to Alternative 3 would be slightly reduced as compared to the proposed Project. Alternative 3 would result in the same significance conclusions as the proposed Project. Therefore, Alternative 3 impacts would be similar to impacts associated with implementation of the proposed Project. Implementation of Mitigation Measures N0I-1 and N0I-2 would ensure that construction of Alternative 3, together with cumulative projects, would not result in a significant cumulative impact as a result of construction noise. Because operational impacts related to noise for Alternative 3 would be less than those associated with the proposed Project, cumulative impacts would also be less than cumulatively significant, and no mitigation would be required. (Draft EIR, pp. 4.11-22 through 4.11-23.) Transportation Alternative 3 would allow for the future construction of a 161,385 sf Ganahl Lumber hardware store and lumber yard, a 399 -space vehicle storage facility, and 2,000 sf of fast-food restaurant uses. Based on the same trip generation rates used for the proposed Project, Alternative 3 is anticipate to generate approximately 2,544 ADT, including 230 trips (126 inbound and 104 outbound) in the a.m. peak hour and 153 trips (69 inbound and 84 outbound) in the p.m. peak hour. Alternative 3 Existing Plus Project —Significant and Unavoidable Impact. Based on the analysis of the Alternative 3 Existing Plus Project peak -hour LOS analysis, all study area intersections, including the hot - spot intersections, are anticipated to operate at satisfactory LOS based on the ICU and the HCM methodology. Therefore, a significant Alternative 3 impact would not occur at any study area intersection based on either the ICU or HCM methodologies. An analysis of impacts to roadway segment ADT volumes, v/c ratios, and LOS was also conducted for the Alternative 3 Existing Plus Project scenario. Based on this analysis, all study area roadway segments, including the hot -spot roadways, are anticipated to operate at satisfactory LOS with Alternative 3, with the exception of Stonehill Drive between Camino Capistrano and the Project Driveway (LOS E), Stonehill Drive between the Project Driveway and Del Obispo Street (LOS D), and Valle Road between San Juan Creek Road and the 1-5 northbound ramps (LOS F). The v/c ratios for Stonehill Drive between Camino Capistrano and the Project Driveway and between the Project Driveway and Del Obispo Street would increase by 0.049 and 0.011, respectively, in the Alternative 3 Existing Plus Project condition. These are considered significant unavoidable impacts because there is no available right -of- way as a feasible improvement to widen Stonehill Drive to provide additional roadway capacity. However, the v/c ratio does not increase by 0.01 or 209 6/2/2020 greater for Valle Road between San Juan Creek Road and the 1-5 northbound ramps in the Alternative 3 Existing Plus Project condition and therefore impacts at these locations are not considered significant. Although a significant project impact would occur at two study area roadway segments (Stonehill Drive between Camino Capistrano and the Project Driveway and between the Project Driveway and Del Obispo Street), a peak -hour link analysis shows that each segment would operate at satisfactory LOS in both directions during the peak hours. Alternative 3 Existing Plus Project Plus Cumulative (Year 2024) — Significant and Unavoidable Impact. Based on the results of the Alternative 3 Existing Plus Project Plus Cumulative peak -hour LOS analysis, all study area intersections, including the hot -spot intersections, are forecast to operate at satisfactory LOS based on the ICU methodology, with the exception of Del Obispo Street/Stonehill Drive (LOS D in the a.m. peak hour). However, Project Alternative 3 would not add 0.01 or greater to the v/c ratio at this intersection (0.008). Therefore, a significant Project Alternative 3 or cumulative impact would not occur at any study area intersection based on the ICU methodology. Based on the HCM methodology, all study area intersections, including the hot -spot intersections, are forecast to operate at satisfactory LOS based on the HCM methodology. Therefore, a significant Project Alternative 3 or cumulative impact would not occur at any study area intersection based on the HCM methodology. An analysis of traffic impacts with respect to roadway segment ADT volumes, v/c ratios, and LOS was evaluated under the Alternative 3 Existing Plus Project Plus Cumulative scenario. Based on the results of the analysis, all study area roadway segments, including the hot -spot roadways, are forecast to operate at satisfactory LOS, with the exception of San Juan Creek Road between Valle Road and Camino Capistrano (LOS E), Stonehill Drive between Camino Capistrano and the Project Driveway (LOS E), Stonehill Drive between the Project Driveway and Del Obispo Street (LOS E), and Valle Road between San Juan Creek Road and the 1-5 northbound ramps (LOS F). The v/c ratios for Stonehill Drive between Camino Capistrano and the Project Driveway and between the Project Driveway and Del Obispo Street would increase by 0.049 and 0.011, respectively. These are considered significant unavoidable impacts because there is no available right-of-way as a feasible improvement to widen Stonehill Drive to provide additional roadway capacity. However, the v/c ratios do not increase by 0.01 or greater for San Juan Creek Road between Valle Road and Camino Capistrano and for Valle Road between San Juan Creek Road and the 1-5 northbound ramps and therefore impacts at these locations are not considered significant. Although a significant Project Alternative 3 impact would occur at two study area roadway segments (Stonehill Drive between Camino Capistrano and the 210 6/2/2020