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Attachment 3 - Initial Study Negative Declaration (ISND)ATTACHMENT NO.3 '�PH61M C,�C' �= CITY OF ANAHEIM - s Environmental Checklist Form PROJECT INFORMATION PROJECT AND CASE NUMBERS DEV2022-00064 SITE ADDRESS 1477 North Jefferson Street PROJECT NAME Palisade Jefferson Outdoor Storage Yard for Oversized Vehicles and Trailers LEAD AGENCY NAME AND ADDRESS City of Anaheim, 200 South Anaheim Boulevard, Suite 162, Anaheim, California 92805 CONTACT PERSON AND PHONE NUMBER Ivan Orozco, Associate Planner 714-765-4948 / iorozco@anaheim.net PROJECT LOCATION PROJECT SPONSOR'S NAME AND ADDRESS NP Jefferson, LLC 1330 Factory Place, Suite 105 Los Angeles, California 90013 GENERAL PLAN DESIGNATION Industrial ZONING SP 2015-1 (Anaheim Canyon Specific Plan) SPECIFIC PLAN DESIGNATION Development Area (DA) 1 - Industrial - I- PROJECT SETTING AND SURROUNDING LAND USES The approximately 7.75-acre project site for the Palisade Jefferson Outdoor Storage Yard for Oversized Vehicles and Trailers Project (project) is located at 1477 Jefferson Street in the City of Anaheim, on the west side of Jefferson Street between Orangethorpe Avenue and Miraloma Avenue (Figure 1, Project Location). The project site is composed of two adjacent parcels identified as Assessor's Parcel Number 345-161-01 (northern parcel) and 345-161-02 (southern parcel). The project site is in a largely industrial area and is adjacent to the following (Figure 2, Surrounding Land Use): North: The Atwood Channel (a stormwater channel), followed by an automotive salvage yard East: A small industrial park containing three warehouses and vacant land South and West: A wholesale vehicle auction facility In 2022, the City of Anaheim (City) approved Permits GRA2021-03670 and BLD2021-03436 for construction of an outdoor storage yard on the project site. An existing one-story, 2,607-square-foot modular building with office and restroom space is on site, which will remain in place. Site improvements include 15 parking stalls in the vicinity of the modular building; two driveways off Jefferson street; and landscaping, sidewalk, and street improvements along Jefferson Street. Improvements also include a 7-foot and 4-inches- high concrete masonry unit screen wall along Jefferson Street, and a chain -link fence with view -obscuring slats on all other property lines to screen the project site from view. Improvements also include installation of stormwater infrastructure to collect and treat runoff, as well as the installation of lighting and electrical conduit throughout the site. The outdoor storage yard is currently under construction. As of June 2023, the project site has been cleared, graded, and paved, and utility installation and construction of the other aforementioned permitted site improvements are anticipated to conclude by August 2023. PROJECT DESCRIPTION Since the time that construction of the outdoor storage yard has commenced, the project applicant has submitted an application to the City for a Conditional Use Permit (CUP) to permit trailer storage on site. Pursuant to Anaheim Municipal Code Section 18.10.030, a CUP is required for the Outdoor Storage of Oversized and Recreational Vehicles, which include the storage of trailers. The proposed trailer storage yard would use many of the improvements that were previously permitted and that are currently under construction pursuant to BLD2021-03436, including the modular office building, concrete pavement, utility improvements, driveways, landscaping, and fencing. For the purposes of this environmental analysis, the project is defined as the modifications and improvements necessary to convert the outdoor storage yard to the proposed trailer storage yard, as well as the operation of a trailer storage yard once constructed. These modifications and improvements include: • Striping the previous outdoor storage area for 181 trailer storage stalls (53 feet long by 8 feet wide); and, • The addition of 8 inches in height to the existing 7-foot 4-inches screening masonry wall located in the southwest corner of the site. Figure 3, Site Plan, depicts site improvements associated with the project. New improvements or modifications to previously permitted improvements are depicted in black, and previously permitted improvements that are under construction and would not be modified are depicted in light gray. Operations Based on a Letter of Request/Description of Operation provided by the project applicant (NP Jefferson LLC 2023), once constructed, the project would provide for the parking and storage of empty trailers, serving as a trailer drop lot to reduce transportation costs for logistics carriers. Trailers would be parked on the project - 2- site while waiting to be moved to and from local warehouses and distribution facilities. A tenant has yet to be identified to date, but it is anticipated that the project would serve a company engaged in third -party logistics. The project would be operational 24 hours a day, 7 days a week, 365 days a year. Vehicles and trucks accessing the site would do so via remote access technology (e.g., use of a key fob or access key code). Although business operations are not anticipated to require full-time employees, the existing modular office building would provide a future tenant with limited office space for administrative purposes on an occasional basis. On -site operations would be limited to trailer storage and ancillary office/restroom use; trailer service and/or sales are not proposed. Construction Construction of the trailer storage project would occur in a single phase and is anticipated to commence in late 2023/early 2024 over a two -month period and would consist of the minor modifications necessary to convert the outdoor storage yard to a trailer storage yard, as specified above. Construction activities would include striping the trailer storage area and construction activities to add 8 inches to the top of the existing screening wall. For a breakdown of construction sub -phases and schedule, refer to the California Emissions Estimator Model (CaIEEMod) air quality modeling outputs provided in Appendix A.' OTHER PUBLIC AGENCIES WHOSE APPROVAL IS REQUIRED None. ' Construction phasing estimates are based on default assumptions provided in CaIEEMod (Appendix A). The analysis assumes a construction start date in late 2023/early 2024, which represents the earliest timeframe construction would initiate. 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In`dus'trial Park Q Industrial , Pe ti Note: Since the capture of this aerial, grading Project Site m has completed and paving has occured. .,.. •• - .a S! � � • ram. , 0101 D PROP ,=rOSED SITE PLAN SOURCE: Herdman, 2023 DUDEK FIGURE 3 Site Plan Jefferson Trailer Storage Yard Conversion Projec ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages. ❑ Aesthetics ❑ Agricultural & Forestry Resources ❑ Air Quality ❑ Biological Resources ❑ Cultural Resources ❑ Energy ❑ Geology/Soils ❑ Greenhouse Gas Emissions ❑ Hazards & Hazardous Materials ❑ Hydrology/Water Quality ❑ Mandatory Findings of Significance DETERMINATION On the basis of this initial evaluation: ❑ Land Use/Planning ❑ Mineral Resources ❑ Noise ❑ Population/Housing ❑ Public Services ❑ Recreation ❑ Transportation ❑ Tribal Cultural Resources ❑ Utilities/Service Systems ❑ Wildfire 0 I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. ❑ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared. ❑ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. ❑ I find that the proposed project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. ❑ I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required. aa-4� Signature of eity of Anaheim Representative Ivan Orozco, Associate Planner Printed Name/Title 9/19/2023 Date 714-765-4948 Phone No. - 7- EVALUATION OF ENVIRONMENTAL IMPACTS 1) All answers must take account of the whole action involved, including offsite as well as onsite, cumulative as well as project -level, indirect as well as direct, and construction as well as operational impacts. 2) A list of "Supporting Information Sources" must be attached and other sources used or individuals contacted should be cited in the Narrative Summary for each section. 3) Response Column Heading Definitions: a) Potentially Significant Impact is appropriate if there is substantial evidence that an effect may be significant. If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIR is required. b) Potentially Significant Unless Mitigation Incorporated applies where the incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to a "Less Than Significant Impact." The mitigation measures must be described, along with a brief explanation of how they reduce the effect to a less than significant level. c) Less Than Significant Impact applies where the project creates no significant impacts, only Less Than Significant impacts. d) No Impact applies where a project does not create an impact in that category. A "No Impact" answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one proposed (e.g., the project falls outside of a fault rupture zone). A "No Impact" answer should be explained where it is based on project -specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project -specific screening analysis). 4) Earlier analyses may be used where, pursuant to a tiering, program EIR, Master EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration (Section 15062I(3)(D)). In this case, a brief discussion should identify the following: a) Earlier Analysis Used. Identify and state where they are available for review b) Impacts Adequately Addressed. Identify which effects from the checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c) Mitigation Measures. For effects that are "Less than Significant with Mitigation Measures Incorporated," describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site -specific conditions for the project. 5) Incorporate into the checklist any references to information sources for potential impacts (e.g., the General Plan, zoning ordinance). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated. The explanation of each issue should identify: a) The significance criteria or threshold, if any, used to evaluate each question; and b) The mitigation measure identified, if any, to reduce the impact to less than significant. - 8- I. AESTHETICS Except as provided in Public Resources Code Section 21099, would the project: a) Have a substantial adverse effect on a scenic vista? ❑ ❑ ❑ Q b) Substantially damage scenic resources, including, but not limited to, trees, ❑ ❑ ❑ Q rock outcroppings, and historic buildings within a State scenic highway or local scenic expressway, scenic highway, or eligible scenic highway? c) Substantially degrade the existing visual character or quality of public views ❑ ❑ Q ❑ of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? d) Create a new source of substantial light or glare which would adversely affect ❑ ❑ ❑ Q day or nighttime views in the area? Narrative Summary: a) No Impact. Scenic vistas and other important visual resources are typically associated with natural landforms such as mountains, foothills, ridgelines, and coastlines. The City's General Plan Green Element identifies the Anaheim Hills and Anaheim Canyon Area, Santa Ana Mountains, and Santa Ana River as important visual landmarks within the City. Goal 2.1 of the Green Element states, "Preserve views of ridgelines, natural open space, and other scenic vistas wherever possible." To achieve this goal, the Green Element discusses four policies: controlling infill development on visually significant ridgelines, canyon edges, and hilltops; encouraging development that preserves natural contours and views of existing backdrop ridgelines or prominent views; siting parks and other open space amenities to take advantage of natural vistas; and encouraging future development and public improvements to maximize private and public views of golf course fairways. In addition, the General Plan Green Element specifically states that golf courses and the Santa Ana River provide visual relief from the surrounding built environment (City of Anaheim 2020a). The project would include the addition of 8 inches to the top of the existing screening wall. The addition would result in a height of 8 feet. The screening wall would serve to block views of the project site from the public right-of-way and from adjacent parcels, but it would not interfere with views of any surrounding scenic resources, as no scenic vistas are identified in the surrounding area. The project would not involve construction of any new buildings that could obstruct scenic vistas or other important visual resources. Moreover, the project site is in a highly developed area of the City and is surrounded by existing industrial uses and away from any substantial open space areas. Additionally, the project site is within the Anaheim Canyon Specific Plan Development Area 1 (DA-1 Industrial Area) with an underlying base zone of Industrial Zone "I," and generally lacks visual resources in the surrounding area (City of Anaheim 2015). The nearest open space area identified by the City's General Plan is Santa Ana River Lakes, approximately 0.75 miles south of the project site (City of Anaheim 2020a). Due to the distance between Santa Ana River Lakes and the project site, and the surrounding industrial development, the project would not be visible from this open space resource. Therefore, no impacts associated with scenic vistas would occur. b) No Impact. The nearest designated state scenic highway to the project site is the segment of State Route (SR) 91 (Riverside Freeway) approximately between SR-55 and the Orange County/Riverside County line (Caltrans 2019). This segment of SR-91 is approximately 1.5 miles southeast of the project site. Additionally, the project site is not near a City -designated scenic expressway, as shown in Figure C-1 of the City's General Plan Circulation Element (City of Anaheim 2020a). The nearest scenic expressway is Santa Ana Canyon Road between Lakeview Avenue and Imperial Highway, more than 6 miles to the northwest. Due to the significant distance between the project site and these roadways, and because of the amount of intervening natural topographic variations and constructed development between these roadways and the project site, the proposed project would not be in the viewshed of a designated state scenic highway or City -designated scenic expressway. Therefore, no impacts associated with state scenic highways or City -designated scenic expressways would occur. c) Less -than -Significant Impact. The project site is in a highly urbanized, primarily industrial part of the City, at the west side of Jefferson Street between Orangethorpe Avenue and Miraloma Avenue. The project would involve striping the trailer storage area and construction activities to add 8 inches to the top of the existing screening wall to screen the site from public vantage points. No new buildings or structures are proposed. All project components are consistent with City regulations, including Anaheim Municipal Code (AMC) 18.38.200.150. Oversized and Recreational Vehicle Outdoor Storage, and the project does not require any variance or administrative relief from any zoning regulations. Specifically, AMC 18.38.200.1504.03 requires enclosure and screening of oversized vehicle storage from the Public -Right -of - Way and adjacent properties. The site already contains a 7-foot and 4-inches-high concrete masonry unit screening wall along Jefferson Street (the adjacent Public -Right -of -Way), and a chain -link fence with view -obscuring slats on all other property lines to screen the project site from view by the adjacent non-residential properties. The project would add 8 inches to the top of the screening wall to result in a total height of 8 feet. These features would comply with the specific screening requirements of the AMC. Therefore, the project would not conflict with applicable zoning or other regulations governing scenic quality, and impacts would be less than significant. - 9- d) No Impact. The proposed project would involve striping and adding 8 inches to the top of an existing screening wall to allow for an outdoor trailer storage area. The project would not propose the introduction of any sources of nighttime lighting. As such, the project would not adversely affect day or nighttime views in the area. No Impact would occur. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation II. AGRICULTURE & FOREST RESOURCES In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state's inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide ❑ ❑ ❑ Q Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? ❑ ❑ ❑ Q c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined ❑ ❑ ❑ Q in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? d) Result in the loss of forest land or conversion of forest land to non -forest use? ❑ ❑ ❑ Q e) Involve other changes in the existing environment which, due to their location ❑ ❑ ❑ Q or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non -forest use? Narrative Summary: a) No Impact. The project site is in a predominantly urbanized area. The California Department of Conservation's California Important Farmland Finder identifies the project site and surrounding area as Urban and Built -Up Land (CDOC 2023a). The project site is not on or adjacent to any parcels identified as Prime Farmland, Unique Farmland, or Farmland of State Importance (collectively called Important Farmland). Due to the lack of Important Farmland on the project site and the surrounding area, development of the proposed project would not convert any Important Farmland. Therefore, no impacts associated with conversion of Important Farmland would occur. b) No Impact. The project site is within the Anaheim Canyon Specific Plan Development Area 1 (DA-1 Industrial Area) with the underlying base zone of Industrial Zone "I" and has a General Plan Land Use Designation of Industrial (City of Anaheim 2015, 2016). Neither the project site nor any surrounding parcels are within a zone for agricultural use. Additionally, the project site is not subject to a Williamson Act contract. Therefore, the proposed project would not conflict with an existing zone for agricultural use or conflict with a Williamson Act contract, and no impact would occur. c) No Impact. The project site is within a highly developed portion of the City. According to the City's Zoning Map, the project site is not on or adjacent to forestland, timberland, or timberland zoned Timberland Production (City of Anaheim 2016). Therefore, no impacts associated with forest land or timberland zoning would occur. d) No Impact. The project site is within a largely urban setting. The project site is not on or adjacent forestland. No private timberlands or public lands with forests are located in the City. Therefore, no impact associated with the loss or conversion of forestland would occur. e) No Impact. As previously addressed, the project site is not on or adjacent to any lands identified by either the state or the City as Important Farmland or forestland. The proposed project would not include any on -site or project -adjacent improvements that would result in the conversion of Important Farmland or forestland uses. Therefore, no impacts associated with the conversion of Important Farmland or forestland would occur. - 10- Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation III. AIR QUALITY Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct implementation of the applicable air quality plan? ❑ ❑ R1 ❑ b) Result in a cumulatively considerable net increase of any criteria pollutant for ❑ ❑ 0 ❑ which the project region is non -attainment under an applicable Federal or State ambient air quality standard. c) Expose sensitive receptors to substantial pollutant concentrations? ❑ ❑ 0 ❑ d) Result in other emissions (such as those leading to odors) adversely affecting ❑ ❑ 0 ❑ a substantial number of people? Narrative Summary: a) Less -than -Significant Impact. The project site is within the South Coast Air Basin (SCAB), which includes the non -desert portions of Los Angeles, Riverside, and San Bernardino Counties, and all of Orange County, and is within the jurisdictional boundaries of the South Coast Air Quality Management District (SCAQMD). The SCAQMD administers SCAB's Air Quality Management Plan (AQMP), which is a comprehensive document outlining an air pollution control program for attaining the California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality Standards (NAAQS). The most recently adopted AQMP for the SCAB is the 2022 AQMP, which was adopted by the SCAQMD Governing Board on December 2, 2022. The 2022 AQMP provides actions, strategies, and steps needed to reduce air pollution emissions and meet ozone (03) standards by 2037 (SCAQMD 2022). Specifically, the 2022 AQMP is focused on attaining the 2015 8-hour 03 standard of 70 parts per billion (SCAQMD 2022). The purpose of a consistency finding with regard to the AQMP is to determine if a project is consistent with the assumptions and objectives of the 2022 AQMP, and if it would interfere with the region's ability to comply with federal and state air quality standards. The SCAQMD has established criteria for determining consistency with the currently applicable AQMP in Chapter 12, Sections 12.2 and 12.3 of the SCAQMD California Environmental Quality Act (CEQA) Air Quality Handbook. These criteria are as follows (SCAQMD 1993): • Consistency Criterion No. 1: Whether the project would result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new violations, or delay timely attainment of the ambient air quality standards or interim emission reductions in the AQMP. • Consistency Criterion No. 2: Whether the project would exceed the assumptions in the AQMP or increments based on the year of project buildout and phase. To address the first criterion, project -generated criteria air pollutant emissions have been estimated and analyzed for significance and are addressed under Section III(b). Detailed results of this analysis are included in Appendix A, Air Quality and Greenhouse Gas Emissions CalEEMod Output Files. As presented in that analysis and summarized in Section III(b), the project would not generate construction or operational criteria air pollutant emissions that exceed the SCAQMD's thresholds, and the project would therefore be consistent with Criterion No. 1. The second criterion regarding the potential of the project to exceed the assumptions in the AQMP or increments based on the year of project buildout and phase is primarily assessed by determining consistency between the project's land use designations and its potential to generate population growth. In general, projects are considered consistent with, and not in conflict with or obstructing implementation of, the AQMP if the growth in socioeconomic factors is consistent with the underlying regional plans used to develop the AQMP (SCAQMD 1993). The SCAQMD primarily uses demographic growth forecasts for various socioeconomic categories (e.g., population, housing, and employment by industry) developed by the Southern California Association of Governments (SCAG) for its 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (also known as Connect SoCal) (SCAG 2020; SCAQMD 2022). The SCAQMD uses this document, which is based on general plans for cities and counties in the SCAB, to develop the AQMP emissions inventory (SCAQMD 2022). The SCAG RTP/SCS and associated Regional Growth Forecast are generally consistent with the local plans; therefore, the 2022 AQMP is generally consistent with local government plans. The project site is within the Anaheim Canyon Specific Plan Development Area 1 (DA-1 Industrial Area) with the underlying base zone of Industrial Zone "I" and has a General Plan land use designation of Industrial (City of Anaheim 2015, 2022a, 2022b). The project site is in an industrial area and is generally bounded by existing warehousing and industrial uses. As described in Section XIV, Population and Housing, the project would not provide new homes or businesses. Additionally, the project would not indirectly induce unplanned population - 11- growth through extension of roads or other infrastructure. Based on consistency with the General Plan land use designation and zoning, the project would not conflict with an applicable land use plan, policy, or regulation of an agency with jurisdiction over the project. Because the project is not anticipated to result in population or employment growth that would conflict with SCAG's projections and would be consistent with the General Plan land use designation and zoning for the site, the project would not conflict with or exceed the assumptions in the AQMP. Given that the project does not conflict with the current land use designation and zoning and is not anticipated to result in substantial growth that would conflict with existing employment -population projections, the project would not conflict with or exceed the assumptions in the 2022 AQMP. Accordingly, the project is consistent with the SCAG RTP/SCS forecasts used in the SCAQMD AQMP development, and the impact would be less than significant. b) Less -than -Significant Impact. Air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and present development, and the SCAQMD develops and implements plans for future attainment of ambient air quality standards. Based on these considerations, project -level thresholds of significance for criteria pollutants are used to determine whether a project's individual emissions would have a cumulatively considerable contribution to air quality. If a project's emissions would exceed the SCAQMD's significance thresholds, it would be considered to have a cumulatively considerable contribution. Conversely, projects that do not exceed the project -specific thresholds are generally not considered to be cumulatively significant (SCAQMD 2008a). A quantitative analysis was conducted to determine whether the project might result in emissions of criteria air pollutants that may cause exceedances of the NAAQS or CAAQS, or cumulatively contribute to existing nonattainment of ambient air quality standards. Criteria air pollutants include Os, nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide, particulate matter with an aerodynamic diameter less than or equal to 10 microns (PMio; course particulate matter), particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM2.5; fine particulate matter), and lead. Pollutants that are evaluated herein include volatile organic compounds (VOCs) and oxides of nitrogen (nOx), which are important because they are precursors to Os, as well as CO, sulfur oxides (SOx), PMio, and PM2.5. Regarding NAAQS and CAAQS attainment status, the SCAB is designated as a nonattainment area for federal and state Os and PM2.5 standards (GARB 2019; EPA 2021). The SCAB is also designated as a nonattainment area for state PM10 standards; however, it is designated as an attainment area for federal PMio standards. The SCAB is designated as an attainment area for federal and state CO and NO2 standards, as well as for state sulfur dioxide standards. Although the SCAB has been designated as nonattainment for the federal rolling 3-month average lead standard, it is designated attainment for the state lead standard. The project would result in emissions of criteria air pollutants for which the California Air Resources Board (CARB) and U.S. Environmental Protection Agency have adopted ambient air quality standards (i.e., the NAAQS and CAAQS). Projects that emit these pollutants have the potential to cause, or contribute to, violations of these standards. The SCAQMD CEQA Air Quality Significance Thresholds, as revised in April 2019, set forth quantitative emissions significance thresholds for criteria air pollutants, which, if exceeded, would indicate the potential for a project to contribute to violations of the NAAQS or CAAQS. Table 1 lists the revised SCAQMD Air Quality Significance Thresholds (SCAQMD 2019). Table 1. South Coast Air Quality Management District Air Quality Significance Thresholds Criteria Pollutants Mass Daily Thresholds (pounds per day) Pollutant Construction Operation VOC 75 55 nOx 100 55 CO 550 550 SOX 150 150 pMlo 150 150 pM2.5 1 55 1 55 Leads 1 3 3 Toxic Air Contaminants and Odor Thresholds Toxic Air Contaminantsb Maximum incremental cancer risk >_ 10 in 1 million Cancer Burden >0.5 excess cancer cases (in areas >1 in 1 million) Chronic and Acute Hazard index >_1.0 (project increment) Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402 Sources: SCAQMD 1976, 2019. Notes: VOC = volatile organic compound; NOX = oxides of nitrogen; CO = carbon monoxide; SOX = sulfur oxides; PMio = particulate matter with a diameter less than or equal to 10 microns (coarse particulate matter); PM2.5 = particulate matter with a diameter less than or equal to 2.5 microns (fine particulate matter); SCAQMD = South Coast Air Quality Management District a The phaseout of leaded gasoline started in 1976. Because gasoline no longer contains lead, the project is not anticipated to result in impacts related to lead; therefore, it is not discussed in this analysis. b Toxic air contaminants include carcinogens and noncarcino ens. - 12- The project would result in a cumulatively considerable net increase for 03, which is a nonattainment pollutant, if the project's construction or operational emissions would exceed the SCAQMD VOC or nOx thresholds shown in Table 1. These emissions -based thresholds for 03 precursors are intended to serve as a surrogate for an "ozone significance threshold" (i.e., the potential for adverse 03 impacts to occur) because 03 itself is not emitted directly, and the effects of an individual project's emissions of 03 precursors (i.e., VOCs and nOx) on 03 levels in ambient air cannot be determined through air quality models or other quantitative methods. CalEEMod, Version 2022.1.1.13, was used to estimate emissions from construction and operation of the project (CAPCOA 2022). CalEEMod is a statewide computer model developed in cooperation with air districts throughout the state to quantify criteria air pollutant emissions associated with construction and operational activities from a variety of land use projects. The following discussion summarizes the quantitative project -generated construction and operational emissions and impacts that would result from implementation of the project. Detailed assumptions and results of this analysis are provided in Appendix A. Construction Emissions As described previously, the proposed project would develop an already -paved approximately 7.75-acre site for trailer storage. Modifications and improvements entail striping the trailer storage area and construction activities to add 8 inches to the top of the existing screening wall. Proposed construction activities would result in the temporary addition of pollutants to the local airshed caused by on -site sources (i.e., off - road construction equipment, VOC off -gassing from striping pavement areas for trailer storage, and soil disturbance) and off -site sources (i.e., delivery trucks and worker vehicle trips). For the purposes of modeling, it was assumed that construction of the proposed project would commence in late 2023 and would last 2 months. The analysis contained herein is based on the following subset area schedule assumptions (duration of phases is approximate): • Minor construction/— 20 days • Architectural coating (pavement striping) — 1 week Detailed construction equipment modeling assumptions are provided in Appendix A. The construction equipment mix used for estimating the construction emissions of the proposed project is shown in Table 2. Table 2. Construction Scenario Assumptions One -Way Vehicle Trips Equipment Task Average Daily Worker Trips Average Daily Vendor Truck Trips Average Daily Haul Truck Trips Equipment Type Quantity Usage Hours Construction 16 2 0 Forklifts 1 8 Generator Sets 1 8 Welders 1 8 Tractors/ Loaders/ Backhoes 2 8 Architectural Coating 16 2 0 Air Compressors 1 6 Source: Appendix A. Emissions generated during construction of the project are subject to the rules and regulations of the SCAQMD. Rule 403 (Fugitive Dust) requires implementation of measures to control the emission of visible fugitive/nuisance dust, such as wetting soils that would be disturbed (SCAQMD 2005). It was assumed that the site would be watered at least two times daily to represent compliance with SCAQMD standard dust control measures in Rule 403. The application of architectural coatings, such as pavement striping and other finishes, would produce VOC emissions; however, the contractor is required to procure architectural coatings that comply with the requirements of SCAQMD's Rule 1113 (Architectural Coatings). Table 3 shows the estimated maximum daily construction emissions associated with construction of the project. - 13- Table 3. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions Year VOC NOX CO SOX PMio PM2.5 Pounds Per Day Summer 2023 0.94 8.20 11.1 0.01 0.64 0.43 Winter 2023 19.0 8.21 11.0 0.01 0.64 0.43 Maximum Daily Emissions 19.0 8.21 11.1 0.01 0.64 0.43 SCAQMD Threshold 75 100 550 150 150 55 Threshold Exceeded? No No No No No No Source: Appendix A. Notes: VOC = volatile organic compound; NOX = oxides of nitrogen; CO = carbon monoxide; SOX = sulfur oxides; PMio = coarse particulate matter; PM2.5 = fine particulate matter; SCAQMD= South Coast Air Quality Management District. As shown in Table 3, the project's maximum daily construction emissions would not exceed SCAQMD thresholds for any criteria pollutants. Operational Emissions Operation of the project would generate VOC, nOx, CO, SOx, PMio, and PM2.5 emissions from area sources (consumer products, architectural coatings) and mobile sources (vehicular traffic). No criteria air pollutant emissions from energy sources were shown in modeling results. Lighting of the project site would contribute indirectly to criteria air pollutant emissions; however, the emissions from electricity use are only quantified for greenhouse gas emissions in CalEEMod because criteria pollutant emissions would occur at the site of power plants, which are not on the project site. Table 4 presents the maximum daily area, energy, and mobile source emissions associated with project operation (year 2023). Details of the emissions calculations are provided in Appendix A. Table 4. Estimated Maximum Daily Operation Criteria Air Pollutant Emissions Emissions Source VOC NOX SOX 11 PMio PM2.5 Pounds per Day Summer Mobile 0.08 4.77 2.18 0.03 0.93 0.29 Area 0.05 0.00 0.00 0.00 0.00 0.00 Energy 0.00 0.00 0.00 0.00 0.00 0.00 Total Daily Summer Emissions 0.13 4.77 2.18 0.03 0.93 0.29 Winter Mobile 0.08 4.95 2.20 0.03 0.93 0.29 Area 0.05 0 0 0 0 0 Energy 0.00 0.00 0.00 0.00 0.00 0.00 Total Daily Winter Emissions 0.13 4.95 2.20 0.03 0.93 0.29 Maximum Daily Emissions 0.13 4.95 2.20 0.03 0.93 0.29 SCAQMD Threshold 55 55 550 150 150 55 Threshold Exceeded? No No No No No No Source: See Appendix A for complete results. Notes: VOC = volatile organic compound; NO. = oxides of nitrogen; CO = carbon monoxide; SOX = sulfur oxides; PMio = coarse particulate matter; PM2.5 = fine particulate matter; SCAQMD = South Coast Air Quality Management District. - 14- As shown in Table 4, maximum daily operational emissions from the project would not exceed the significance thresholds for VOC, nOx, CO, SOx, PMio, or PM2.5. As discussed above, the SCAB has been designated as a national nonattainment area for 03 and PM2.5, and a California nonattainment area for 03, PMio, and PM2.5. The nonattainment status is the result of cumulative emissions from various sources of air pollutants and their precursors within the SCAB, including motor vehicles, off -road equipment, and commercial and industrial facilities. Construction and operation of the project would generate VOC and nOx emissions (which are precursors to 03) and emissions of PMio and PM2.5. However, as indicated in Tables 3 and 4, project -generated construction emissions and operational emissions would not exceed the emission -based significance thresholds for VOC, nOx, PMio, or PM2.5. Cumulative localized impacts would potentially occur if a construction project were to occur concurrently with another off -site project. Construction schedules for potential future projects near the project site are currently unknown; therefore, potential construction impacts associated with two or more simultaneous projects would be considered speculative. However, future projects would be subject to CEQA and would require air quality analysis and, where necessary, mitigation if the project would exceed applied thresholds. Criteria air pollutant emissions associated with construction activities of future projects would be reduced through implementation of control measures required by the SCAQMD. For example, cumulative PMio and PM2.5 emissions would be reduced because all future projects would be subject to SCAQMD Rule 403 (Fugitive Dust), which sets forth general and specific requirements for all construction sites in the SCAB (SCAQMD 2005). In addition, cumulative VOC emissions would be subject to SCAQMD Rule 1113 (Architectural Coatings) and Rule 445. Because project -generated construction and operational emissions of VOC, nOx, PMio, and PM2.5 would not exceed the SCAQMD thresholds, the project would not result in a cumulatively considerable increase in emissions of nonattainment pollutants. Therefore, the project's cumulative air quality impact would be less than significant. c) Less -than -Significant Impact. The project would not expose sensitive receptors to substantial pollutant concentrations, as evaluated below. Sensitive Receptors Sensitive receptors are those individuals more susceptible to the effects of air pollution than the population at large. People most likely to be affected by air pollution include children, older adults, and people with cardiovascular and chronic respiratory diseases. According to the SCAQMD, sensitive receptors include residences, schools, playgrounds, childcare centers, long-term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes (SCAQMD 1993). The closest sensitive receptors to the project site are single-family residences across a railway from the project site, approximately 290 feet away. Localized Significance Thresholds The SCAQMD recommends a localized significance threshold (LST) analysis to evaluate localized air quality impacts to sensitive receptors in the immediate vicinity of a project as a result of project activities. Project impacts were analyzed using methods consistent with those in the SCAQMD's Final LST Methodology (SCAQMD 2008a). The project site is within Source Receptor Area (SRA) 16 (North Orange County). This analysis applies the SCAQMD LST values for a 1-acre site within SRA 16 with a receptor distance of 85 meters (approximately 279 feet). The LST values were interpolated between the available distances in the look -up tables (e.g., 140 meters interpolated between the 200- and 500- meter values). A 1-acre site was selected as the most conservative option because it generates the strictest thresholds. Project construction activities would result in temporary sources of on -site criteria air pollutant emissions associated with off -road equipment exhaust and fugitive dust generation. According to the Final LST Methodology, "off -site mobile emissions from the project should not be included in the emissions compared to the LSTs" (SCAQMD 2008a). Trucks and worker trips associated with the project are not expected to cause substantial air quality impacts to sensitive receptors along off -site roadways because emissions would be relatively brief and would cease once the vehicles pass through the main roadway. Therefore, off -site emissions from trucks and worker vehicle trips are not included in the LST analysis. The maximum daily on -site emissions generated from construction of the project are presented in Table 5 and are compared to the SCAQMD localized significance criteria for SRA 16 to determine whether project -generated on -site emissions would result in potential LST impacts. Table 5. Construction Localized Significance Thresholds Analysis -Unmitigated NOZ CO PM2.5 7 Construction Year Pounds per Day 2023 8.08 10.0 0.41 0.38 SCA QMD LST Criteria° 115.9 915.3 19.8 7.5 Threshold exceeded? No No No No Notes: NO2 = nitrogen dioxide; CO = carbon monoxide; PMio = particulate matter with a diameter less than or equal to 10 microns (coarse particulate matter); PM2.5 = particulate matter with a diameter less than or equal to 2.5 microns (fine particulate matter); SCAQMD = South Coast Air Quality Management District; LST = localized significance threshold. The values shown are the maximum summer or winter daily emissions results from CalEEMod. See Appendix A for detailed results. a Localized significance thresholds are shown for a 1-acre disturbed area and interpolated for a sensitive receptor distance of 85 meters in Source Receptor Area 16 (North Orange County). - 15- As shown in Table 5, the project would not exceed any LST thresholds for construction. Impacts would be less than significant. CO Hotspots Traffic -congested roadways and intersections have the potential to generate localized high levels of CO. Localized areas where ambient concentrations exceed federal and/or state standards for CO are termed "CO hotspots." The transport of CO is extremely limited because it disperses rapidly with distance from a source. However, under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthy levels, affecting sensitive receptors. Typically, high CO concentrations are associated with severely congested intersections operating at an unacceptable level of service (LOS) (LOS E or worse is unacceptable). Projects contributing to adverse traffic impacts may result in the formation of a CO hotspot. Additional analysis of CO hotspot impacts would be conducted if a project would result in a significant impact or contribute to an adverse traffic impact at a signalized intersection that would potentially subject sensitive receptors to CO hotspots. At the time that the SCAQMD Handbook (1993) was published, the SCAB was designated nonattainment under the CAAQS and NAAQS for CO. In 2007, the SCAQMD was designated in attainment for CO under both the CAAQS and NAAQS as a result of the steady decline in CO concentrations in the SCAB due to turnover of older vehicles, introduction of cleaner fuels, and implementation of control technology on industrial facilities. The SCAQMD conducted CO modeling for the 2003 AQMP (SCAQMD 2003) for the four worst -case intersections in the SCAB: (1) Wilshire Boulevard and Veteran Avenue, (2) Sunset Boulevard and Highland Avenue, (3) La Cienega Boulevard and Century Boulevard, and (4) Long Beach Boulevard and Imperial Highway. At the time the 2003 AQMP was prepared, the intersection of Wilshire Boulevard and Veteran Avenue was the most congested intersection in Los Angeles County, with an average daily traffic volume of approximately 100,000 vehicles per day. The 2003 AQMP also projected 8-hour CO concentrations at these four intersections for 1997 and from 2002 through 2005. The maximum 8-hour CO concentration was 3.8 parts per million at the Sunset Boulevard and Highland Avenue intersection in 2002; the maximum 8-hour CO concentration was 3.4 parts per million at the Wilshire Boulevard and Veteran Avenue in 2002 (SCAQMD 2003). Accordingly, CO concentrations at congested intersections would not exceed the 1-hour or 8-hour CO CAAQS unless projected daily traffic would be at least more than 100,000 vehicles per day. Project construction activities would be temporary and would not be a source of daily, long-term mobile -source emissions. Accordingly, project construction activities would not generate traffic that would contribute to potential adverse traffic impacts that may result in the formation of CO hotspots. In addition, because of continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SCAB is steadily decreasing. Because the project would not result in substantial changes to routine operational activities, CO impacts associated with operational air pollutant emissions would be less than significant. Based on these considerations, the project would result in a less -than -significant impact to air quality with regard to potential CO hotspots. Toxic Air Contaminants Toxic air contaminants (TACs) are defined as substances that may cause or contribute to an increase in deaths or in serious illness, or that may pose a present or potential hazard to human health. As discussed above for the LST analysis, the closest sensitive receptors to the project site are residential land uses approximately 290 feet from the project site. Health effects from carcinogenic air toxics are usually described in terms of cancer risk. The SCAQMD recommends an incremental cancer risk threshold of 10 in 1 million. "Incremental cancer risk" is the net increased likelihood that a person continuously exposed to concentrations of TACs resulting from a project over a 9-, 30-, and 70-year exposure period will contract cancer based on the standard Office of Environmental Health Hazard Assessment risk -assessment methodology (OEHHA 2015). In addition, some TACs have non - carcinogenic effects. The SCAQMD recommends a Hazard Index of 1 or more for acute (short-term) and chronic (long -tern) non -carcinogenic effects. The greatest potential for TAC emissions during construction would be diesel particulate matter (DPM) emissions from heavy equipment operations and use of heavy-duty trucks. DPM has established cancer risk factors and relative exposure values for long-term chronic health hazard impacts; however, no short-term, acute relative exposure level has been established for DPM. Total project construction would last approximately 8 months, after which project -related TAC emissions would cease. According to the Office of Environmental Health Hazard Assessment, health risk assessments (which determine the exposure of sensitive receptors to toxic emissions) should be based on a 30-year exposure period for the maximally exposed individual receptor; however, such assessments should also be limited to the period/duration of activities associated with the project. A 2-month construction schedule represents a short duration of exposure (1% of a 30-year exposure period), and cancer and chronic risk from DPM are typically associated with long -tern exposure. Exhaust PMio is typically used as a surrogate for DPM, and as shown in Tables 3 and 4, which present total PM10 from fugitive dust and exhaust, project -generated construction PM10 emissions are anticipated to be below the SCAQMD threshold. Due to the relatively short period of exposure and minimal DPM emissions on site, TACs generated during construction would not be expected to result in concentrations causing significant health risks. Thus, the project would not result in impacts from exposure to a long-term source of TAC emissions. - 16- Health Effects of Criteria Pollutants Construction of the project would generate criteria air pollutant emissions. However, due to the nature of the project and the short duration of construction, which would last approximately 2 months, the project would not exceed the SCAQMD mass -emission thresholds, as shown in Table 3. The SCAB is designated as nonattainment for 03 for the NAAQS and CAAQS. Thus, existing 03 levels in the SCAB are at unhealthy levels during certain periods. Health effects associated with 03 include respiratory symptoms, worsening of lung disease leading to premature death, and damage to lung tissue (CARB 2021). The contribution of VOCs and NOx to regional ambient 03 concentrations is the result of complex photochemistry. The increases in 03 concentrations in the SCAB due to 03 precursor emissions tend to be found downwind of the source location because of the time required for the photochemical reactions to occur. Further, the potential for exacerbating excessive 03 concentrations also depends on the time of year that the VOC emissions would occur; exceedances of the 03 NAAQS and CAAQS tend to occur April to October when solar radiation is highest. Due to the lack of quantitative methods to assess this complex photochemistry, the holistic effect of a single project's emissions of 03 precursors is speculative. Because the project would not involve activities that would result in 03 precursor emissions (i.e., VOCs or NOx) that would exceed the SCAQMD thresholds, the project is not anticipated to substantially contribute to regional 03 concentrations and its associated health impacts during construction. In addition to 03, NOx emissions contribute to potential exceedances of the NAAQS and CAAQS for NO2. Health effects associated with NOx include lung irritation and enhanced allergic responses (GARB 2021). Project construction and operations would not exceed the SCAQMd NOx threshold, and existing ambient NO2 concentrations would be below the NAAQS and CAAQS. Thus, the project is not expected to result in exceedances of the NO2 standards or contribute to associated health effects. Health effects associated with CO include chest pain in patients with heart disease, headache, light-headedness, and reduced mental alertness (GARB 2021). CO hotspots were discussed previously as a less -than -significant impact. Thus, the project's CO emissions would not contribute to the health effects associated with this pollutant. The SCAB is designated as nonattainment for PMio under the CAAQS and nonattainment for PM2.5 under the NAAQS and CAAQS. Health effects associated with PMio include premature death and hospitalization, primarily for worsening of respiratory disease (CARB 2021). As with 03 and NOx, the project would not generate emissions of PMio or PM2.5 that would exceed the SCAQMD's thresholds. Accordingly, the project's PM10 and PM2.5 emissions are not expected to cause an increase in related regional health effects for this pollutant. In summary, the project would not result in a potentially significant contribution to regional concentrations of nonattainment pollutants and would not result in a significant contribution to the adverse health effects associated with those pollutants. Therefore, impacts would be less than significant. d) Less -than -Significant Impact. The occurrence and severity of potential odor impacts depends on numerous factors. The nature, frequency, and intensity of the source; the wind speeds and direction; and the sensitivity of receiving location each contribute to the intensity of the impact. Although offensive odors seldom cause physical harm, they can be annoying and cause distress among the public and generate citizen complaints. Odors would be potentially generated from vehicle and equipment exhaust emissions during construction of the project. Potential odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment, striping pavement areas for trailer storage, and architectural coatings. Such odors would disperse rapidly from the project site and generally occur at magnitudes that would not affect substantial numbers of people. Therefore, impacts associated with odors during construction would be less than significant. Land uses and industrial operations associated with odor complaints include agricultural uses, wastewater treatment plants, food -processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding (SCAQMD 1993). The project would entail operation of a trailer storage yard, which has not been identified by the SCAQMD as a land use typically associated with odor complaints. Therefore, project operations would result in an odor impact that is less than significant. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation IV. BIOLOGICAL RESOURCES Would the project: a) Have a substantial adverse effect, either directly or through habitat ❑ ❑ ❑ Q modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive ❑ ❑ ❑ Q 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? - 17- c) Have a substantial adverse effect on state or federally protected wetlands ❑ ❑ ❑ R1 (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially with the movement of any native resident or migratory ❑ ❑ ❑ 1z fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? e) Conflict with any local policies or ordinances protecting biological resources, ❑ ❑ ❑ Q such as a tree preservation policy or ordinance? f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural ❑ ❑ ❑ Q Community Conservation Plan, or other approved local, regional, or State habitat conservation plan? Narrative Summary: a) No Impact. The project site was first developed in 1953 as a fuel storage and distribution site. The previous uses were removed in 2021 and the entire site was graded in 2022. There is no vegetation on the project site, so there are no native communities for candidate, sensitive, or special -status species. Therefore, no impacts associated with candidate, sensitive, or special -status species would occur. b) No Impact. The project site was first developed in 1953 as a fuel storage and distribution site. The previous uses were removed in 2021and the entire site was graded in 2022. No natural vegetation communities are present within the project site. Therefore, no impacts associated with riparian or sensitive vegetation communities would occur. c) No Impact. Based on the analysis of the project site in the Anaheim Canyon Specific Plan Draft EIR (City of Anaheim 2015), within the boundaries of which the project site is located, no federally defined waters of the United States or state occur within the project site. This includes the absence of federally defined wetlands and other waters (e.g., streams and riparian extent) (USFWS 2023). Therefore, no impacts to jurisdictional waters or wetlands would occur. d) No Impact. Meffe and Carrol (1997) define wildlife movement corridors, also referred to as dispersal corridors or landscape linkages, as linear features along which animals can travel from one habitat or resource area to another. The project site is in a highly urbanized and industrial area, does not contain any greenbelts for wildlife movement or native vegetation capable of supporting the movement of wildlife, and is enclosed by construction fencing. Construction of the proposed project would not result in the encroachment into or impediment of a wildlife corridor or nursery site that local wildlife could use. Therefore, the proposed project would have no impact on wildlife movement corridors or wildlife nursery sites. e) No Impact. The project site is within an entirely developed area in the City of Anaheim. Sections 11.12 and 13.12 of the Anaheim Municipal Code address the protection of landmark trees and street trees, respectively (City of Anaheim 2020b). No landmark tree would be removed without prior approval of the City Council. Additionally, no person would cut, trim, prune, plant, remove, spray, or in any other manner interfere with any street tree within the City without first having secured written permission from the Director of Community Services or his or her designee. The proposed project would not result in the removal of any landmark trees or street trees because none are within the project site, and the proposed project would not affect trees that are beyond the eastern and northern boundaries of the project site. Additionally, Sections 18.18.30 and 18.18.040 of the Anaheim Municipal Code provide regulations to preserve significant stands and single specified trees in the Scenic Corridor (SC) Overlay Zone to preserve the natural beauty of the Santa Ana Canyon environment. The project site is not within the Scenic Corridor (SC) Overlay Zone, and the proposed project would not conflict with the provisions of Sections 18.18.30 and 18.18.040 of the Anaheim Municipal Code. Therefore, the proposed project would not conflict with any local policies or ordinances protecting biological resources, and no impact would occur. f) No Impact. The project site is not within a Habitat Conservation Plan, Natural Community Conservation Plan, or similar plan area. The project site is not within or proximate to any Significant Ecological Area, Land Trust area, or Conservation Plan area. As such, construction of the proposed project would not conflict with an adopted conservation plan, and no impact would occur. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation V. CULTURAL RESOURCES Would the project: a) Cause a substantial adverse change in the significance of a historical resource pursuant to in § 15064.5 of the CEQA Guidelines? ❑ ❑ Q ❑ b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5 of the CEQA Guidelines? ❑ ❑ Q ❑ c) Disturb any human remains, including those interred outside of ❑ ❑ Q ❑ dedicated cemeteries? - 18- Narrative Summary a) Less -Than -Significant Impact. The project site was historically developed with industrial uses since at least 1953. The site has been occupied with industrial infrastructure for a fuel storage and distribution facility from approximately 1953 to 2021 when it was demolished except for a one-story, 2,607-square-foot modular building in the southeast corner of the site. In 2022 the project site was graded and paved. The existing modular building is over 50 years old and may be considered eligible for the National Register of Historic Places (NRHP) and California Register of Historical Resources (CRHR) pursuant to in § 15064.5 of the CEQA Guidelines. However, the Anaheim Canyon Specific Plan Draft EIR (which includes the project site within the Specific Plan boundaries) did not identify the building as a historical resource (City of Anaheim 2015). The modular building would remain in place and in use for the proposed project. The project proposes minor upgrades outside of the building, including a planter and a refuse enclosure on the west side of the building. As such the proposed project would not cause a substantial adverse change to a historical resource. Therefore, impacts associated with historical resources would be less than significant. b) Less -than -Significant Impact. As previously discussed, the project site has historically been developed with industrial uses until it was graded and paved in 2022. The Anaheim Canyon Specific Plan EIR prepared in 2015 for the Specific Plan Area including the project site did not identify any archaeological resources in the project area. The proposed project would involve conversion of the existing outdoor storage yard to a trailer yard. Only minor improvements would be necessary for this conversion, including restriping the storage yard for trailer parking spaces and adding 8 inches to the existing masonry wall, which would not involve ground -disturbance. The project site has been subject to intense levels of disturbance for decades, including grading, development, and demolition prior to construction of the outdoor storage yard. Given the limited scope of project construction activities, the fact that no archaeological resources have been identified on the project site, and the fact that the project site has been subject to high levels of development and disturbance (including grading, development, and demolition prior to construction of the outdoor storage yard), the project would not result in substantial adverse change in the significance of an archaeological resource.. Therefore, impacts associated with archaeological resources would be less than significant. c) Less -than -Significant Impact. As discussed above, given the limited scope of project construction activities, it is highly unlikely that the project would uncover previously unknown human remains. However, if human skeletal remains are discovered, California Health and Safety Code Section 7050.5 states that the County Coroner must be immediately notified of the discovery. No further disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains can occur until the County Coroner has determined, within 2 working days of notification of the discovery, the appropriate treatment and disposition of the human remains. If the County Coroner determines that the remains are, or are believed to be, Native American, he or she must notify the Native American Heritage Commission in Sacramento within 24 hours. In accordance with California Public Resources Code (PRC) Section 5097.98, the Native American Heritage Commission must immediately notify those persons it believes to be the most likely descendant from the deceased Native American. The most likely descendant must complete his or her inspection within 48 hours of being granted access to the site. The designated Native American representative would then determine, in consultation with the property owner, the disposition for the human remains. Therefore, impacts associated with the discovery of human remains would be less than significant. Environmental Issues Potentially Less Than Less Than No Significant Significant Significant Impact Impact with Impact Mitigation VI. ENERGY Would the project: a) Result in potentially significant environmental impact due to wasteful, El El ❑ inefficient, or unnecessary consumption of energy resources, during project construction or operation? b) Conflict with or obstruct a state or local plan for renewable energy or ❑ ❑ ❑ Q energy efficiency? Narrative Summary: a) Less -than -Significant Impact. Construction of the project would require the use of electric power for as -necessary lighting and electronic equipment. The amount of electricity used during construction would be minimal because typical energy demand stems from the use of electrically powered equipment. This electricity demand would be temporary and would cease upon completion of construction; therefore, the project would not adversely impact the available electricity supply. During construction, natural gas would typically not be consumed on the project site. The majority of the energy used during construction would be from petroleum. Petroleum would be consumed throughout construction of the project. Fuel consumed by construction equipment would be the primary energy resource expended over the course of construction. Vehicle miles traveled (VMT) associated with the transportation of construction materials and construction worker commutes also would result in petroleum consumption. However, the project would be required to comply with CARB's Airborne Toxics Control Measure, which restricts heavy-duty diesel vehicle idling time to 5 minutes. Additionally, construction of the project would be a temporary, short-term activity, and any petroleum used during the construction phase would be used toward development of the project; as such, petroleum use for construction would be relatively nominal and would not be wasteful or inefficient. Therefore, short-term construction impacts associated with energy consumption would be less than significant. - 19- With regard to operation, the project would require electricity, natural gas, and petroleum during operations. However, given that the project would consist of improvements that would not increase the intensification of operations that already occur on the project site, the project is not expected to increase the on -site use of electricity, natural gas, or petroleum compared with existing conditions. Therefore, no long-term operational impacts associated with energy consumption would occur, and impacts would be less than significant. b) No Impact. As discussed in Section VI(a), the project would not result in wasteful, inefficient, or unnecessary consumption of energy during construction or operation. Therefore, no impacts associated with the potential of the project to conflict with a state or local renewable energy or energy efficiency plan would occur. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation VII. GEOLOGY AND SOILS Would the project: a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most ❑ ❑ Q ❑ recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ii) Strong seismic ground shaking? ❑ ❑ Q ❑ iii) Seismic -related ground failure, including liquefaction? ❑ ❑ Q ❑ iv) Landslides? ❑ ❑ ❑ Q b) Result in substantial soil erosion or the loss of topsoil? ❑ ❑ ❑ Q c) Be located on a geologic unit or soil that is unstable, or that would become ❑ ❑ Q ❑ unstable as a result of the project, and potentially result in on- or off -site landslide, lateral spreading, subsidence, liquefaction, or collapse? e) Have soils incapable of adequately supporting the use of septic tanks or El El El Q alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? f) Directly or indirectly destroy a unique paleontological resource or site or ❑ ❑ Q ❑ unique geologic feature? Narrative Summary: a. i) Less -than -Significant Impact. The Alquist—Priolo Earthquake Zoning Act (Alquist—Priolo Act) requires the delineation of fault zones along active faults in California. The purpose of the Alquist—Priolo Act is to regulate development on or near active fault traces to reduce hazards associated with fault rupture. The nearest fault zone to the project site is the Elsinore Fault Zone, specifically the Whittier Fault, which is approximately 3.5 miles north of the project site, and the Newport —Inglewood Fault Zone, located more than 16 miles southwest of the project site. Farther away are the San Jacinto Fault Zone and the San Andreas Fault Zone; the closest approaches are 33 miles away and 35 miles away, respectively (CDOC 2023b; USGS 2023). According to a Geotechnical Evaluation Report prepared for the previously permitted outdoor storage use, the project site lies outside of any Alquist Priolo Special Studies Zone, and the potential for damage due to direct fault rupture is considered unlikely (NCE 2021). Therefore, the impact associated with ground rupture would be less than significant. ii) Less -than -Significant Impact. Like most of the Southern California region, the project site is within a seismically active area. As mentioned above, numerous faults considered active or potentially active have been mapped in Southern California, including in the vicinity of Anaheim. Thus, the project site could be exposed to strong seismic ground shaking in the event of an earthquake. The Whittier Fault is approximately 3.5 miles from the project site and is capable of producing a Magnitude 6.8 earthquake. Ground shaking originating from earthquakes along other active faults in the region is expected to induce lower horizontal accelerations due to smaller anticipated earthquakes and/or greater distances to other faults (NCE 2021). The project would not involve construction of new buildings that could be subject to damage or collapse as a result of seismic ground shaking. Therefore, impacts associated with strong seismic ground shaking due to faulting would be less than significant. iii) Less -than -Significant Impact. Liquefaction occurs when partially saturated soil loses its effective stress and enters a liquid state, which can result in the soil's inability to support structures built on top of it. Liquefaction can be induced by ground-shakingevents and is dependent - 20- on soil saturation conditions. According to the California Geological Survey, the project site is within an area susceptible to liquefaction (CDOC 2023b). However, according to the Geotechnical Evaluation Report for the previously permitted outdoor storage use, the potential for liquefaction at the project site is low, considering a conservative historical high groundwater level of 20 feet below grade, along with medium -dense to dense sands below that level. Based on a Magnitude 6.8 earthquake at the site, seismic -induced settlements are anticipated to be on the order of 1 inch or less. These settlements are anticipated to occur rather uniformly across the project site, with differential settlements on the order of 0.75 inches over a 50-foot (horizontal) distance (NCE 2021). This level of settlement, should it occur, would not result in severe damage, or pose a risk to future occupants of the site, particularly considering that the project would not involve construction of new buildings. Therefore, impacts associated with ground failure and liquefaction would be less than significant. iv) No Impact. According to the California Geological Survey, the project site is not in an area susceptible to landslides (CGS 2023). As such, the project would not expose people or structures to risk of landslides, and no impact would occur. b) No Impact. The proposed project would not involve earthwork or other construction activities that would disturb surface soils and temporarily leave exposed soil on the ground's surface. Therefore, no impact would occur related to soil erosion and topsoil. c) Less -than -Significant Impact. As discussed in Section 3.7(a)(iii), the project site is within an area susceptible to liquefaction (CGS 2023). However, according to the Geotechnical Evaluation Report prepared for the previously approved outdoor storage yard, the potential for liquefaction at the project site is low when considering the groundwater table level and sediment type (NCE 2021). Therefore, impacts associated with unstable geologic units or soils would be less than significant. d) Less -than -Significant Impact. Expansive soils are characterized by their potential shrink/swell behavior. Shrink/swell is the cyclic change in volume (expansion and contraction) that occurs in certain fine-grained clay sediments from the process of wetting and drying. Clay minerals are known to expand with changes in moisture content. The higher the percentage of expansive sediments in the near -surface soils, the higher the potential for substantial expansion. The upper soils at the project site are very low in expansion potential (Expansion Index = 0-20) (NCE 2021). Sites with expansive soils (Expansion Index =>20) require special attention during project design and maintenance. Therefore, the impact associated with expansive soils creating direct or indirect risks to life or property would be less than significant. e) No Impact. The project would continue to be connected to the municipal sewer system, and no septic tanks or alternative wastewater disposal systems are proposed. Therefore, no impacts associated with septic tanks and alternative wastewater disposal systems would occur. f) Less -than -Significant Impact. According to the City's General Plan Environmental Impact Report (EIR) (City of Anaheim 2004), because most of the City is built -out, there are very few areas containing rock outcrops that could potentially contain significant paleontological resources, such as fossils. The Anaheim Hill and Anaheim Canyon Area of the City contain sedimentary rocks ranging in age from Late Cretaceous to Middle Miocene. The oldest sedimentary rocks belong to the upper Cretaceous Holz Shale and the Schulz Ranch Member of the Williams Formation. These strata are confined to the southeastern comer of the Anaheim Hill and Anaheim Canyon Area, and no fossils have been reported. The project site is not within these areas as identified in the City's General Plan EIR, and the project would not involve grading that could disturb paleontological resources if they were present within subsurface soils. For these reasons, the proposed project would not directly or indirectly destroy a unique paleontological resource, and impacts would be less than significant. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation VIII. GREENHOUSE GAS EMISSIONS Would the project: a) Generate greenhouse gas emissions, either directly or indirectly, that may ❑ ❑ 0 ❑ have a significant impact on the environment? b) Conflict with an applicable plan, policy or regulation adopted for the purpose ❑ ❑ 0 ❑ of reducing the emissions of greenhouse gases? Narrative Summary: a) Less -than -Significant Impact. Greenhouse gases (GHGs) are those that absorb infrared radiation (i.e., trap heat) in the Earth's atmosphere. The trapping and buildup of heat in the atmosphere near the Earth's surface (the troposphere) is referred to as the "greenhouse effect," and it is a natural process that contributes to the regulation of the Earth's temperature, creating a livable environment on Earth. The Earth's temperature depends on the balance between energy entering and leaving the planet's system, and many factors (natural and human -caused) can cause changes in Earth's energy balance. Human activities that generate and emit GHGs to the atmosphere increase the amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the greenhouse effect, and causing the Earth's surface temperature to rise. This rise in temperature has led to large-scale changes to the Earth's system (e.g., temperature, precipitation, wind patterns), which are collectively referred to as climate change. Global climate change is a cumulative impact; a project contributes to this impact through its incremental contribution combined with the cumulative increase of all other sources of GHGs. Thus, GHG impacts are recognized exclusively as cumulative impacts (CAPCOA 2008). -21- As defined in California Health and Safety Code Section 38505(g), for purposes of administering many of the state's primary GHG emissions reduction programs, GHGs include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and nitrogen trifluoride (see also CEQA Guidelines Section 15364.5). The primary GHGs that would be emitted by project -related construction and operations are CO2, CH4, and N20.2 The Intergovernmental Panel on Climate Change developed the global warming potential (GWP) concept to compare each GHG's ability to trap heat in the atmosphere relative to another gas. The reference gas used is CO2, and GWP-weighted emissions are measured in metric tons (MT) of carbon dioxide equivalent (CO2e). Consistent with CaIEEMod Version 2022.1.1.13, this GHG emissions analysis assumed the GWP for CH4 is 25 (i.e., emissions of 1 MT of CH4 are equivalent to emissions of 25 MT of CO2), and the GWP for N2O is 298, based on the Intergovernmental Panel on Climate Change's Fourth Assessment Report (IPCC 2007). As discussed in Section I1I, Air Quality, the project site is within the jurisdictional boundaries of the SCAQMD. In October 2008, the SCAQMD proposed recommended CEQA significance thresholds for GHG emissions for lead agencies to use in assessing GHG impacts of residential and commercial development projects, as presented in its Draft Guidance Document — Interim CEQA GHG Significance Threshold (SCAQMD 2008b). This document, which builds on the California Air Pollution Control Officers Association's previous guidance, explored various approaches for establishing a significance threshold for GHG emissions. The draft interim CEQA thresholds guidance document was not adopted or approved by the Governing Board. However, in December 2008, the SCAQMD adopted an interim 10,000 MT CO2e per -year screening level threshold for stationary source/industrial projects for which the SCAQMD is the lead agency (SCAQMD 2010). The 10,000 MT CO2e per -year threshold, which was derived from GHG reduction targets established in Executive Order 5-3-05, was based on the conclusion that the threshold was consistent with achieving an emissions capture rate of 90% of all new or modified stationary source projects. The SCAQMD formed a GHG CEQA Significance Threshold Working Group to work with SCAQMD staff on developing GHG CEQA significance thresholds until statewide significance thresholds or guidelines are established. From December 2008 to September 2010, the SCAQMD hosted working group meetings and revised the draft threshold proposal several times, although it did not officially provide these proposals in a subsequent document. The SCAQMD has continued to consider adoption of significance thresholds for residential and general land -use development projects. The most recent proposal issued by the SCAQMD, issued in September 2010, uses the following tiered approach to evaluate potential GHG impacts from various uses (SCAQMD 2010): Tier 1. Determine if CEQA categorical exemptions are applicable. If not, move to Tier 2. Tier 2. Consider whether or not the project is consistent with a locally adopted GHG reduction plan that has gone through public hearing and CEQA review, that has an approved inventory, includes monitoring, etc. If not, move to Tier 3. Tier 3. Consider whether the project generates GHG emissions in excess of screening thresholds for individual land uses. The 10,000 MT CO2e per -year threshold for industrial uses would be recommended for use by all lead agencies. Under option 1, separate screening thresholds are proposed for residential projects (3,500 MT CO2e per year), commercial projects (1,400 MT CO2e per year), and mixed -use projects (3,000 MT CO2e per year). Under option 2, a single numerical screening threshold of 35000 MT CO2e per year would be used for all non -industrial projects. If the project generates emissions in excess of the applicable screening threshold, move to Tier 4. Tier 4. Consider whether the project generates GHG emissions in excess of applicable performance standards for the project service population (population plus employment). The efficiency targets were established based on the goal of Assembly Bill (AB) 32 to reduce statewide GHG emissions to 1990 levels by 2020. The 2020 efficiency targets are 4.8 MT CO2e per -service population for project -level analyses and 6.6 MT CO2e per -service population for plan -level analyses. If the project generates emissions in excess of the applicable efficiency targets, move to Tier 5. Tier 5. Consider the implementation of CEQA mitigation (including the purchase of GHG offsets) to reduce the project efficiency target to Tier 4 levels. Section 15064.7(c)of the CEQA Guidelines specifies that "[w]hen adopting thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies, or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence." The CEQA Guidelines do not prescribe specific methodologies for performing an assessment, establish specific thresholds of significance, or mandate specific mitigation measures. Rather, the CEQA Guidelines emphasize the lead agency's discretion to determine the appropriate methodologies and thresholds of significance that are consistent with the manner in which other impact areas are handled in CEQA (CNRA 2009). 2 Emissions of hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and nitrogen trifluoride are generally associated with industrial activities, including the manufacturing of electrical components and heavy-duty air conditioning units, and the insulation of electrical transmission equipment (substations, power lines, and switch gears). Therefore, emissions of these GHGs were not evaluated or estimated in this analysis because the project would not include these activities or components, and would not generate hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, or nitrogen trifluoride in measurable quantities. - 22- To determine the project's potential to generate GHG emissions that would have a significant impact on the environment, its GHG emissions were compared to the SCAQMD's 3,000 MT COze per year screening threshold recommended for non -industrial projects. Construction Greenhouse Gas Emissions Construction of the project would result in GHG emissions primarily associated with off -road construction equipment, on -road vendor trucks, and worker vehicles. The SCAQMD Draft Guidance Document — Interim CEQA GHG Significance Threshold (SCAQMD 2008b) recommends that "construction emissions be amortized over a 30-year project lifetime, so that GHG reduction measures will address construction GHG emissions as part of the operational GHG reduction strategies." Thus, the total construction GHG emissions were calculated, amortized over 30 years, and added to the total operational emissions for comparison with the GHG significance threshold of 3,000 MT COze per year. Therefore, the determination of significance is addressed in the operational emissions discussion following the estimated construction emissions. CalEEMod Version 2022.1.1.13 was used to calculate the annual GHG emissions based on the construction scenario described in Section III, Air Quality (CAPCOA 2022). The project is anticipated to commence construction in September 2023 and is anticipated to last 2 months. On -site sources of GHG emissions would include off -road equipment, and off -site sources would include vendor trucks and worker vehicles. Table 6 presents the GHG emissions resulting from construction of the project. For farther detail on the assumptions and results of this analysis, refer to Appendix A, Air Quality and Greenhouse Gas Emissions CalEEMod Output Files. Table 6. Estimated Annual Construction Greenhouse Gas Emissions — Unmitigated 7W COz CJPME z Oze - 23- As shown in Table 7, the proposed project's operational emissions were estimated to be 743 MT CO2e per year. When combined with the amortized construction emissions, total operational GHG emissions were estimated to be 744 MT CO2e per year. This would not exceed the SCAQMD threshold of 3,000 MT CO2e per year. Impacts would be less than significant. b) Less -than -Significant Impact. The project would not conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing GHG emissions. Applicable plans for the project site include SCAG's 2020-2045 RTP/SCS and CARB's 2022 Scoping Plan. Each of these plans is described below, along with an analysis of the project's potential to conflict with the related GHG emissions reduction goals. 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy On September 3, 2020, the Regional Council of SCAG formally adopted the 2020-2045 RTP/SCS as a regional growth management strategy, which targets per -capita GHG reduction from passenger vehicles and light -duty trucks in the Southern California region, pursuant to Senate Bill (SB) 375. In addition to demonstrating the region's ability to attain the GHG emissions reduction targets set forth by GARB, the 2020-2045 RTP/SCS outlines a series of actions and strategies for integrating the transportation network with an overall land use pattern that responds to projected growth, housing needs, changing demographics, and transportation demands (SCAG 2020). Thus, successful implementation of the 2020-2045 RTP/SCS would result in more complete communities with various transportation and housing choices while reducing automobile use. The primary objective of the RTP/SCS is to provide guidance for future regional growth (i.e., the location of new residential and non-residential land uses) and transportation patterns throughout the region, as stipulated under SB 375. As indicated in the traffic impact analysis (Section XVII, Transportation), the project would result in a minimal increase in daily trips that would have no measurable effect on the region's circulation system. As such, the project would not conflict with the goals and policies of the RTP/SCS. 2017 CARB Scoping Plan The Climate Change Scoping Plan, approved by CARB in 2008 and updated in 2014 and 2017, provides a framework for actions to reduce California's GHG emissions, and requires CARB and other state agencies to adopt regulations and other initiatives to reduce GHGs (CARB 2014, 2017). The Scoping Plan is not directly applicable to specific projects, and it is not intended to be used for project -level evaluations. Under the Scoping Plan, however, several state regulatory measures aim to identify and reduce GHG emissions through measures focused on area -source emissions (e.g., energy usage and high-GWP GHGs in consumer products) and changes to the vehicle fleet (e.g., hybrid, electric, and more fuel -efficient vehicles) and associated fuels, among others. Given that the proposed project is also not anticipated to result in substantial increase in mobile trips (see Section XVII), the project would not conflict with the Second Update's goal of reducing GHG emissions through reductions in VMT statewide. 2022 CARB Scoping Plan CARB's 2022 Scoping Plan reflects the 2030 target of a 40% reduction from 1990 levels codified by SB 32, and the 2045 target of carbon neutrality established by Executive Order B-55-18 (AB 1279). Absent a qualified GHG reduction plan, Appendix D of the CARB Scoping Plan provides recommendations for key attributes that residential and mixed -use projects should achieve that would align with the state's climate goals, including electric vehicle (EV) charging infrastructure, infill location, no loss or conversion of natural and working lands, transit -supportive densities or proximity to transit stops, and no net loss of existing affordable units, among others (CARB 2022). Many of the measures and programs included in the Scoping Plan would result in the reduction of project -related GHG emissions with no action required at the project level, including GHG emission reductions through increased energy efficiency and renewable energy production (SB 350), reduction in carbon intensity of transportation fuels (Low Carbon Fuel Standard), and the accelerated efficiency and electrification of the statewide vehicle fleet (Mobile Source Strategy). The project would not result in significant operational GHG emissions and would comply with all regulations adopted in furtherance of the Scoping Plan to the extent applicable and required by law. The proposed project would not conflict with CARB's 2022 Scoping Plan or with the state's ability to achieve GHG reduction and carbon neutrality goals. Further, the project's consistency with the applicable measures and programs would assist in meeting the City's contribution to GHG emission reduction targets in California. Based on the considerations previously outlined, the project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs, and this impact would be less than significant. City of Anaheim Greenhouse Gas Reduction Plan The City's GHG Reduction Plan demonstrates the City's commitment to pursuing energy efficiency and reducing GHGs across the community and municipal operations and establishes revised and new goals for 2030 and 2045 (APU 2020). The City's GHG Reduction Plan presents the City's goals for achieving GHG reductions in several categories, including from power supplies, renewable power supplies, water conservation and drought resiliency, energy efficiency, shade trees, street lighting, distributed solar energy systems, transportation electrification, and electric fleet vehicles. The project would divert as much waste during construction as required in accordance with state law. In addition, the project would not inhibit the City from reducing water demand or per -capita water use. The project would solely involve - 24- the conversion of an outdoor storage yard to a trailer storage yard, which would not preclude the City from implementing its GHG measures of the GHG Reduction Plan, and thus, the project is consistent with this plan. Based on the considerations previously outlined, the project would not generate substantial GHG emissions or conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. This impact would be less than significant. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation IX. HAZARDS AND HAZARDOUS MATERIALS Would the project: a) Create a significant hazard to the public or the environment through the ❑ ❑ Q ❑ routine transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through ❑ ❑ Q ❑ reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous ❑ ❑ ❑ Q materials, substances, or waste within one -quarter mile of an existing or proposed school? d) Be located on a site which is included on a list of hazardous materials sites ❑ ❑ ❑ Q compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? e) For a project located within an airport land use plan (Los Alamitos Armed ❑ ❑ ❑ Q Forces Reserve Center or Fullerton Municipal Airport), would the project result in a safety hazard or excessive noise for people residing or working in the project area? f) Impair implementation of or physically interfere with an adopted emergency ❑ ❑ ❑ Q response plan or emergency evacuation plan? g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? ❑ ❑ ❑ Q Narrative Summary: a, b) Less -than -Significant Impact. A limited variety of hazardous substances and waste would be transported, used, or disposed of during construction of the project. These would include fuels for machinery and vehicles, cleaning solvents, sealants, and storage containing such materials. A significant hazard to the public or the environment could occur because of accidental spills, fires, explosions, or pressure releases involving hazardous materials. However, any transport, use, or disposal of hazardous materials would comply with all applicable federal, state, and local laws regulating the management and use of hazardous materials. Further, waste, including trash, litter, garbage, solid waste, petroleum products, and any other potentially hazardous materials, would be removed and transported to a permitted waste facility for treatment, storage, or disposal. Once operational, the project would be a trailer storage yard in an industrial area of the City. The project site would be used for the storage of empty trailers and would not be used for truck maintenance activities or to fuel trucks. The project site would be expected to store small quantities of hazardous materials for cleaning, for example, but is not expected to bring in new hazardous materials. Operations at the project site would be subject to safety regulations that govern the storage and handling of hazardous materials, which would limit the severity and frequency of potential releases of hazardous materials that could result in increased exposure of people to health hazards (i.e., fire department regulations and requirements, and U.S. Department of Transportation regulations). For example, Part 172 (172, Emergency Response; Part 173, Packaging Requirements; Part 177, Carriage by Public Highway; Part 178, Specifications for Packagings; and Part 180, Continuing Qualification and Maintenance of Packagings, of the Code of Federal Regulations would all apply to project activities. Compliance with these requirements would minimize project hazard impacts to less than significant. c) No Impact. The project site is approximately 350 feet from El Camino Real High School. However, by nature of the project as a trailer storage yard for empty trailers, the project would not emit hazardous emissions or handle hazardous or acutely hazardous materials or substances. Therefore, no impacts associated with emitting hazardous emissions or handling hazardous or acutely hazardous materials within 0.25 miles of a school would occur. d) Less -than -Significant Impact. The Hazardous Waste and Substances Sites (Cortese List) is a planning document providing information about the location of hazardous materials release sites. The California Environmental Protection Agency is required to update and make - 25- available, at least annually, the lists comprising the Cortese List (California Government Code Section 65962.5[e]). The California Environmental Protection Agency's data resources website provides five lists that comprise the Cortese List: (1) Department of Toxic Substances Control hazardous waste and substance sites identified on EnviroStor; (2) Geotracker listed leaking underground storage tank (LUST) sites; (3) solid waste disposal sites identified by the State Water Board as having waste constituent hazards outside the waste management unit; (4) list of hazardous waste facilities subject to corrective action pursuant to Health and Safety Code Section 25187.5, as identified by the Department of Toxic Substances Control; and (5) sites with "active" cease and desist and/or cleanup and abatement orders (CAOs) issued by the local Regional Water Quality Control Board (RWQCB) (CaIEPA 2023). The project site is associated with two cases listed on the RWQCB database GeoTracker. The two cases are identified as cleanup program sites related to past unauthorized releases of petroleum products throughout the history of the former fuel storage and distribution facility and are described below. While they are active cases on the RWQCB database, it should be noted that they are not associated with LUST sites nor sites with "active" cease and desist and/or (CAOs). Exxon Mobile Atwood Terminal (T0605934334). This case is associated with an open cleanup program site. In April 2005 petroleum hydrocarbons were discovered, some contaminated soil was excavated, and a soil and groundwater assessment were requested. In August 2005, two soil borings were drilled to collect soil samples, and in March 2006, two groundwater monitoring wells were installed. Groundwater monitoring and soil sampling is ongoing. No further action was recommended, but according to RWQCB, the case is still active. Because no cease and desist or CAO were issued related to this case, it is not included in the Cortese List. PBF Energy Atwood Terminal (Formerly Mobil) (SLT8R1594080). This case, an open cleanup program site, had a CAO issued in approximately 1986 for the site due to unauthorized release of petroleum product to soil and groundwater. Soil vapor extraction (SVE) and groundwater extraction were completed to remediate impacted soil and groundwater. A number of groundwater monitoring wells were installed. The SVE system continued to operate until 1992, product recovery from groundwater continued until 1996, and groundwater monitoring continued through 1997. In 2013, that CAD was rescinded by Order No. R8-2013-0039 (described as "rescinding the earlier 1986 CAO"). On March 12, 2021, the Investigation Order (IO) No. WQ 2021-0006-DWQ for the For the PBF Energy Atwood Terminal was issued by the RWQCB for the determination of the presence of per- and polyfluoroalkyl substances (PFAS) at bulk fuel storage terminals and refineries. Investigation related to this IO is ongoing. The cases discussed above are related to past unauthorized releases, are ongoing, and extensive remediation has occurred onsite in response to these cases. The proposed project would not involve any ground -disturbance; therefore, the proposed project would not disturb areas of potential contamination. Therefore, the project has no potential to release or expose the public to contamination.. It should also be noted that the two active cases on the RWQCB database described above are neither LUST sites nor sites with "active" cease and desist and/or (CAOs). Based on these findings, the project would not create a hazard to the public or the environment because no ground disturbing activities are proposed. Therefore, the impact would be less than significant. e) No Impact. The project site is not within an airport land use plan area (i.e., Los Alamitos Armed Forces Reserve Center or Fullerton Municipal Airport). Therefore, no impacts associated with airport safety hazards would occur. f) No Impact. According to Figure C-1, Planned Roadway Network, in the City's General Plan Circulation Element (City of Anaheim 2020a), Orangethorpe Avenue and Tustin Avenue are Major Arterial Roadways. Both of these roadway facilities traverse the City and connect to regional facilities, including SR-55, SR-90, and SR-57. Due to this local and regional connectivity, in the unlikely event of an emergency, these project -adjacent roadway facilities would serve as emergency evacuation routes for first responders and residents. As discussed in Section XVII, Transportation, the project would not adversely affect operations on the local or regional circulation system, and as such, would not affect the use of these facilities as emergency response routes. Therefore, no impacts associated with an emergency response plan or emergency evacuation plan would occur. g) No Impact. According to the State Responsibility Area map by the California Department of Forestry and Fire Protection (CAL FIRE), the project site is not within a Fire Hazard Severity Zone or a Very High Fire Hazard Severity Zone (CAL FIRE 2020, 2023). In addition, the project site is within a developed portion of the City. Therefore, no impacts associated with wildland fire hazards would occur. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation X. HYDROLOGY AND WATER QUALITY Would the project: a) Violate any water quality standards or waste discharge requirements or ❑ ❑ Q ❑ otherwise substantially degrade surface or ground water quality? b) Substantially decrease groundwater supplies or interfere substantially with ❑ ❑ Q ❑ groundwater recharge such that the project may impede sustainable groundwater management of the basin? c) Substantially alter the existing drainage pattern of the site or area, including - 26- through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: (i) result in substantial erosion or siltation on- or off -site? (ii) substantially increase the rate or amount of surface runoff in a manner ❑ ❑ 0 ❑ which would result in flooding on- or offsite; ❑ ❑ 0 ❑ (iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or ❑ ❑ 0 ❑ (iv) impede or redirect flood flows? ❑ ❑ 0 ❑ d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to ❑ ❑ 0 ❑ project inundation? e) Conflict with or obstruct implementation of a water quality control plan or ❑ ❑ 0 ❑ sustainable groundwater management plan? Narrative Summary: a) Less -than -Significant Impact. Construction activities would be limited to striping pavement areas for trailer storage and adding 8 inches to the top of the existing masonry wall. These construction activities would not involve ground disturbance, and therefore would not result in soil erosion of sedimentation from stormwater runoff that could result in violation of water quality standards or degrade water quality. An engineered stormwater system was installed as part of the previously permitted outdoor storage yard. The project would use this same stormwater system, which was developed based on a hydrology study and Water Quality Management Plan to ensure that pre -development flows mimic post - development flows, and any runoff is attenuated and treated prior to discharging off site. Through compliance with the City's regulatory process, including the preparation, review, and approval of the Water Quality Management Plan for the outdoor storage yard, the project would not result in impacts associated with water quality. Impacts would be less than significant. b) Less -than -Significant Impact. The project would not significantly change the permeability of the project site which is largely impervious. The project site was not previously an area for groundwater recharge. In contrast, there are several areas within the City that allow for groundwater recharge, such as the nearby Atwood Channel, Anaheim Lake, Miller Retarding Basin, and Kraemer Basin. The project would not affect these earthen -bottomed features. Additionally, given that the project would consist of improvements that would not increase the intensification of operations that already occur on the project site, the project would not increase the on -site consumption of domestic water, including water derived from groundwater sources. As such, the project would not decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. Therefore, impacts associated with groundwater supplies or groundwater recharge would be less than significant. c) (i) (ii) (iii) (iv) Less -than -Significant Impact. The project would use the vast majority of previous improvements associated with the outdoor storage yard, with the exception of restriping and the addition of 8 inches to the existing masonry wall. The outdoor storage yard includes an engineered stormwater system, which was developed based on a hydrology study and Water Quality Management Plan to ensure that pre -development flows mimic post -development flows, and any runoff is attenuated and treated prior to discharge off site. hi consideration of these factors, the project would not result in substantial erosion or siltation on site or off site; substantially increase the rate or amount of surface runoff in a manner that would result in flooding on site or off site; create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff, or impede or redirect flood flows. Impacts would be less than significant. d) Less -than -Significant Impact. The project site is not within a tsunami or seiche zone but is adjacent to the Atwood Channel and approximately 1 mile north of the Santa Ana River. According to the National Flood Hazard Layer from the Federal Emergency Management Agency, the project site is within Zone X, which is an area with reduced flood risk due to a levee. Zone X is mapped for much of the area surrounding the project site between the Atwood Channel to the north and the Santa Ana River in the south (FEMA 2021). Additionally, the project site would not change the intensity of the uses on the site, because the stored trailers would be empty. Therefore, storage of acutely hazardous materials onsite would not be as a result of the project. In consideration of these factors, impacts associated with the potential release of pollutants due to project inundation would be less than significant. e) Less -than -Significant Impact. The project would comply with regional and local regulations requiring preparation of a SWPPP and would not obstruct existing Water Quality Control Plans or Groundwater Sustainable Management Plans. In addition, the project site is not a suitable site for groundwater recharge, and, therefore, the project would not introduce impervious areas over a significant groundwater recharge zone. Therefore, impacts associated with a conflict with a Water Quality Control Plan or Sustainable Groundwater Management Plan would be less than significant. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XI. LAND USE AND PLANNING Would the project: - 27- a) Physically divide an established community? ❑ ❑ ❑ Q b) Cause a significant environmental impact due to a conflict with any land use ❑ ❑ ❑ Q plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Narrative Summary: a) No Impact. The physical division of an established community typically refers to construction of a linear feature (such as a major highway or railroad tracks) or removal of a means of access (such as a local road or bridge) that would impair mobility within an existing community or between a community and outlying area. Under the existing condition, the project site is not used as a connection between established communities, as it is privately owned and gated. Instead, connectivity within the area surrounding the project site is facilitated via local roadways. Once operational, the project site would remain privately owned and gated. Therefore, no impacts associated with the physical division of an established community would occur. b) No Impact. The project would involve construction and operation of a trailer storage yard within an industrial area of the City. The project site is within Anaheim Canyon Specific Plan Development Area 1 (DA-1 Industrial Area) with the underlying base zone of Industrial Zone "I" and has a General Plan Land Use Designation of Industrial (City of Anaheim 2015, 2016). The project site is generally bounded by industrial uses. The proposed use is allowed and is consistent with the project site's General Plan designation and zoning, and, thus, the project would not conflict with an applicable land use plan, policy, or regulation of an agency with jurisdiction over the project. Therefore, no impacts associated with land use plans, policies, and regulations would occur. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XII. MINERAL RESOURCES Would the project: a) Result in the loss of availability of a known mineral resource that would be ❑ ❑ Q ❑ of value to the region and the residents of the state? b) Result in the loss of availability of a locally -important mineral resource ❑ ❑ Q ❑ recovery site delineated on a local general plan, specific plan or other land use plan? Narrative Summary: a) Less -than -Significant Impact. According to the Green Element of the Anaheim General Plan, the project site is in a Mineral Resource Zone (MRZ) 2 (City of Anaheim 2004). MRZ-2s are areas where adequate information indicates that significant mineral deposits are present, or where it is judged that a high likelihood exists for their presence. These resources primarily consist of aggregate, sand, and gravel. According to the Anaheim General Plan, the areas in the City that are within an MRZ-2 are developed with industrial uses; therefore, their practical value for mineral resources is somewhat limited (City of Anaheim 2004). Furthermore, the Anaheim General Plan also identifies sectors of Regionally Significant Aggregate. The project site is not in a Regionally Significant sector. Therefore, the impact associated with the loss of availability of a known mineral resource that would be of value to the region or state would be less than significant. b) Less -than -Significant Impact. Due to the built -out nature of Anaheim, areas suited for mineral extraction are extremely limited, as acknowledged by the City's General Plan (City of Anaheim 2004). Neither the General Plan, Anaheim Canyon Specific Plan, nor City Zoning Map delineate the project site as a mineral resource recovery site. Therefore, impacts associated with the loss of availability of a locally important mineral resource recovery site would be less than significant. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XIII. NOISE Would the project result in: a) Generation of a substantial temporary or permanent increase in ambient noise ❑ ❑ Q ❑ levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b) Generation of excessive groundborne vibration or groundborne noise levels? ❑ ❑ Q ❑ c) For a project located within the vicinity of a private airstrip or an airport land use plan (Los Alamitos Armed Forces Reserve Center or Fullerton Municipal Airport), would the project expose people residing or working in the project area - 28- to excessive noise levels? ❑ ❑ ❑ 0 Narrative Summary: a) Less -than -Significant Impact. The project site is within an urban environment characterized by extensive industrial, commercial, and transportation -related land uses. Construction activities would be limited to striping pavement areas for trailer storage and adding 8 inches to the existing masonry wall. Construction would be limited to the use of a few pieces of heavy machinery, and no major construction equipment would be required. Construction activities would occur during City's Municipal Code permitted daytime hours (e.g., 7:00 a.m. to 7:00 p.m.) and would be limited in duration. The City and the project applicant expect that construction activities associated with the project would take place exclusively within the permitted hours. Therefore, given the relatively brief duration during which construction activities would occur, the fact that construction activities would comply with the City's permitted construction hours, and the fact that the project site is an active construction site, short-term construction noise impacts would be less than significant. With regard to operational noise, the project would result in empty trailers being stored on the project site instead of other miscellaneous items, such as construction equipment, bulk materials, or vehicles. The trailer storage yard use would result in a slight increase in the number of trucks accessing the project site, but overall, the project would not result in any new or different types of noise sources. As such, the project would not result in a substantial increase in noise levels compared to the existing conditions. With regard to off -site noise associated with trucks accessing the project site, the project would generate an increase of 75 net daily vehicle trips, with 3 net vehicle trips in the AM peak hour and -1 net daily vehicle trips in the PM peak hour. Typically, a perceptible increase in noise level occurs when traffic is doubled on a roadway. Considering that the project would result in a maximum increase of 3 vehicle trips during the AM peak hour, the increase in daily trips along local roadways is assumed to be negligible, and off -site noise levels would remain largely the same as under existing conditions. As such, noise impacts would be less than significant. b) Less -than -Significant Impact. Construction activities would be limited to striping pavement areas for trailer storage adding 8 inches to the top of the existing masonry wall. No construction activities that result in substantial vibration, such as drilling, would occur. As such, the peak particle velocity vibration level would be well below the vibration threshold of potential annoyance of 0.1 inches per second. Therefore, impacts associated with groundborne vibration or groundborne noise levels would be less than significant. c) No Impact. The project site is not within the vicinity of a private airstrip. The closest public airport to the project site is the Fullerton Municipal Airport, which is approximately 8 miles west of the project site. Additionally, the Los Alamitos Army Airfield is located approximately 12 miles southwest of the project site. The project would not be in the airport influence area for the Fullerton Municipal Airport or Los Alamitos Army Airfield, and, thus, would not expose people to excessive noise levels. Therefore, no impacts associated with public airport noise would occur. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XIV. POPULATION AND HOUSING Would the project: a) Induce substantial unplanned population growth in an area, either directly (for El El ❑ ❑ example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? b) Displace substantial numbers of existing people or housing, necessitating the ❑ ❑ ❑ R1 construction of replacement housing elsewhere? Narrative Summary: a) No Impact. The project would involve conversion of an outdoor storage yard to a trailer storage yard within an industrial area of the City. It is anticipated that the very limited number of construction workers needed to develop the project would come from the local labor pool, with additional workers from outside the region not being required. No residential uses are proposed as part of this project, and a limited number of employees would be required during operations. This limited number would not result in substantial unplanned population growth that would result in the need to construct new homes. Therefore, no impacts associated with population growth would occur. b) No Impact. The existing project site is developed with a single -story modular office building that would remain in place. No residential uses occur on the project site, and as such, the project would not remove people or housing from the site. Therefore, no impact associated with the displacement of existing people or housing would occur. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XV. PUBLIC SERVICES 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 - 29- impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: i) Fire protection? ❑ ❑ ❑ Q ii) Police protection? ❑ ❑ ❑ Q iii) Schools? ❑ ❑ ❑ Q iv) Parks? ❑ ❑ ❑ Q v) Other public facilities? ❑ ❑ ❑ Q Narrative Summary: i) No Impact. Anaheim Fire and Rescue (AFR) provides fire protection services in the City. AFR operates 11 fire stations and employs approximately 270 firefighters, 2 battalion chiefs, and various other support staff (AFR 2023). AFR is responsible for all fire, rescue, and medical aid calls throughout the City. AFR #8 (4555 East Riverdale Avenue) is the closest fire station to the project site, located approximately 2.2 miles away via local roads. The second nearest fire station is AFR #5 (2540 East La Palma Avenue), which is roughly 3.2 miles via local roads from the project site. Based on the proximity of the project site to the existing AFR facilities, and because the project site is in a developed part of the City that is already within the service area of AFR, it is anticipated that the project could be served by AFR without adversely affecting personnel -to -resident ratios, response times, or other performance objectives. Additionally, given that the project would consist of improvements that would not increase the intensification of operations that already occur on the project site, the project would not increase calls for service to the project site. Therefore, no impacts associated with fire protection would occur. ii) No Impact. The Anaheim Police Department provides police protection services to the City. The Anaheim Police Department operates out of its headquarters (425 South Harbor Boulevard), East Station (8201 East Santa Ana Canyon Road), and West Station (320 South Beach Boulevard), and employs approximately 400 sworn officers and a support staff of more than 200 (City of Anaheim 2023). The nearest police station to the project site is the East Station, approximately 6.7 miles via local roads from the project site. Based on the proximity of the project site to the existing Anaheim Police Department, and because the project site is in a developed part of the City that is within the service area of the Anaheim Police Department, it is anticipated that the project could be served without adversely affecting personnel -to - resident ratios, response times, or other performance objectives. Further, given that the project consists of improvements that would not increase the intensification of operations that already occur on the project site, the project would not increase calls for service to the project site. Therefore, no impacts associated with police protection would occur. iii) No Impact. The project would not result in population growth, and as such, would not increase demands on schools. Therefore, no impact associated with schools would occur. iv) No Impact. The project would not result in population growth, and as such, would not increase demands on parks. Therefore, no impact associated with parks would occur. v) No Impact. The project would not result in population growth, and as such, would not increase demands on libraries, recreation facilities, community centers, hospitals, or any other public facility. Therefore, no impact associated with other public facilities would occur. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XVI. RECREATION Would the project: a) Increase the use of existing neighborhood and regional parks or other ❑ ❑ ❑ Q recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or require the construction or ❑ ❑ ❑ Q expansion of recreational facilities which might have an adverse physical effect on the environment? Narrative Summary: a) No Impact. The project would not result in population growth, and as such, would not increase demands on park and recreation facilities. Therefore, no impacts associated with recreational facilities would occur. - 30- b) No Impact. The project would not result in population growth, and as such, would not include recreational facilities or require the construction or expansion of recreational facilities. Therefore, no impacts associated with construction or expansion of recreational facilities would occur. Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XVII. TRANSPORTATION Would the project: a) Conflict with a program plan, ordinance or policy addressing the circulation ❑ ❑ Q ❑ system, including transit, roadway, bicycle and pedestrian facilities? b) Would the project conflict or be inconsistent with CEQA Guidelines section ❑ ❑ Q ❑ 15064.3, subdivision (b)? c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses? ❑ ❑ Q ❑ d) Result in inadequate emergency access? ❑ ❑ 0 ❑ Narrative Summary: a) Less -than -Significant Impact. The project would not conflict with an applicable plan, ordinance, or policy that establishes measures of effectiveness for the performance of the circulation system, as further discussed below. The City of Anaheim has adopted vehicle level of service policies that set standards for local infrastructure. According to a Vehicle Miles Traveled (VMT) Screening Analysis prepared for the project (Appendix B), the project is forecasted to result in the generation of +75 net daily vehicle trips, with +3 net vehicle trips (0 inbound, 3 outbound) produced in the AM peak hour and -1 net vehicle trips (1 inbound, -2 outbound) produced in the PM peak hour on a "typical" weekday. According to the City's Traffic Impact Analysis Guidelines for California Environmental Quality Act Analysis (City of Anaheim 2020c), a traffic study is generally required for projects that generate more than 50 or 100 peak -hour trips to evaluate whether the level of service could be affected. Given the project's nominal net trip generation, further study of the project's traffic impacts is not anticipated. The project would not conflict with any plan or policy for future bike paths, transit stops, or pedestrian paths. As such, the project would not conflict with an applicable plan, ordinance, or policy that establishes measures of effectiveness for the performance of the circulation system, and impacts would be less than significant. b) Less -than -Significant Impact. CEQA Guidelines Section 15064.3(b) focuses on VMT, adopted pursuant to SB 743, for determining the significance of transportation impacts. The project's impacts with regard to VMT are discussed in detail in Appendix B. As discussed in Appendix B, the project would result in the generation of +75 net daily vehicle trips, with +3 net vehicle trips (0 inbound, 3 outbound) produced in the AM peak hour and -1 net vehicle trips (1 inbound, -2 outbound) produced in the PM peak hour on a "typical" weekday. Under the City's Traffic Impact Analysis Guidelines (City of Anaheim 2020c), projects that are local -serving or generate fewer than 110 average daily trips are presumed to have a less -than -significant impact with regard to VMT. The project is forecast to generate fewer than 110 net daily trips and is assumed to be a local -serving use given the trip -making characteristics of a trailer storage yard, which would include nominal employee trips and local -serving truck trips associated with a local end user. As such, the project's impacts with regard to VMT would be less than significant, and the project would not conflict with or be inconsistent with CEQA Guidelines Section 15064.3(b). c, d) Less -than -Significant Impact. The existing driveways were designed to City standards and comply with City width, depth, clearance, and turning -radius requirements. As shown in Figure 3, the gates exceed the Anaheim Department of Public Works Standard Detail 475 and are set back 80 feet and 4 inches from Jefferson Street right-of-way, allowing for adequate off-street staging. The project site would be accessible to emergency responders during construction and operation of the project. Additionally, the project would not involve any components that could potentially interfere with the use of Jefferson Street by emergency vehicles. Because the project would comply with all applicable local requirements related to geometric design features and emergency vehicle access and circulation, the project would not result in safety hazards or inadequate emergency access. Therefore, impacts would be less than significant. - 31- Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XVIII. TRIBAL CULTURAL RESOURCES 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) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in ❑ ❑ Q El Public Resources Code Section §5020.1(k), or b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section §5024.1. ❑ ❑ ❑ In applying criterial set forth in subdivision (c) of Public Resources Code Section §5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe. Narrative Summary: a, b) Less -than -Significant Impact. The project is subject to compliance with AB 52 (PRC Section 21074), which requires consideration of impacts to tribal cultural resources as part of the CEQA process, and requires the City, as the lead agency, to notify any groups that are traditionally or culturally affiliated with the geographic area of the project and who have requested notification. According to PRC Section 21080.3.1(b), notification of a proposed project is required if a California Native American tribe has previously requested, of the lead agency in writing, notification of AB 52 eligible projects under the agency's jurisdiction and within the geographic area that is traditionally and culturally affiliated with the tribe, and consultation is required if the notified California Native American tribe responds, in writing, within 30 days of receipt of the formal notification, and requests the consultation. All Native American Heritage Commission -listed California Native American tribal representatives that have requested project notification pursuant to AB 52 were sent letters by the City on July 6, 2023. One response was received from Gabrielefio Band of Mission Indians — Kizh Nation on July 13, 2023. Follow up email correspondence between the City and Gabrielefio Band of Mission Indians — Kizh Nation (Tribe) occurred on July 23ra 24th August 3ra, and August 71. No substantial evidence of the presence of tribal cultural resources within the project was presented and no planned ground disturbing activities are associated with the project. However, in abundance of caution and in consideration of the consulting Tribe's concerns, the City is including as a condition of the project that should the project conditions change such that ground disturbance may occur, the consulting Tribe shall be contacted prior to any ground disturbance occurring. The project would involve minor improvements to the project site to permit an outdoor storage yard to a trailer storage. The required improvements include restriping of the asphalt for trailer parking spaces and adding 8 inches to the top of the existing masonry wall. The project site has been subject to intense levels of disturbance for decades, including grading, development, and demolition prior to construction of the outdoor storage yard. As such, it is highly unlikely that tribal cultural resources, if ever present on site, would remain intact such that their original significance was retained. Moreover, given the limited scope of project construction activities and the fact that the project site has been subject to high levels of development and disturbance (including grading, development, and demolition prior to construction of the outdoor storage yard), the project does not pose the potential to cause an adverse change in the significance of tribal cultural resources in the highly unlikely event that these resources are located within subsurface soils. Therefore, impacts would be less than significant. - 32- Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XIX. UTILITIES AND SERVICE SYSTEMS Would the project: a) Require or result in the relocation or construction of new or expanded water, El El El wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? ❑ ❑ ❑ Q c) Result in a determination by the wastewater treatment provider which serves ❑ ❑ ❑ Q or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments? d) Generate solid waste in excess of State or local standards, or in excess of the ❑ ❑ Q ❑ capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? e) Comply with Federal, State, and local management and reduction statutes and ❑ ❑ ❑ Q regulations related to solid waste? Narrative Summary: a) No Impact. The project site is currently served by domestic water, municipal sewer, stormwater, and other wet and dry utilities. Given that the project would consist of improvements that would not increase the intensification of operations that already occur on the project site, no upsizing, replacement, or relocation of these existing utilities and associated infrastructure are anticipated. Therefore, no impacts associated with relocation of existing or construction of new utilities would occur. b) No Impact. Refer to the response provided in Section XIX(a). c) No Impact. Refer to the response provided in Section XIX(a). d) Less -than -Significant Impact. Construction of the proposed project would require minor construction activities at the project site. One structure currently occupies the project site, which would not be demolished. However, construction could result in the generation of a very limited amount of construction debris/solid waste. Depending on the type of waste, it could be reused on the project site, transported off site to a permitted recycling facility, or taken to a landfill with available permitted capacity and disposed of appropriately. Regardless, in accordance with AB 939 and SB 1383 , the construction contractor would ensure that source reduction techniques and recycling measures are incorporated into project construction and operation. The project includes a refuse enclosure for recycling, organics, trash, and grease in accordance with City regulations. Therefore, impacts associated with solid waste disposal would be less than significant. e) No Impact. As discussed in Section XIX(d), in accordance with AB 939, the construction contractor would ensure that source reduction techniques and recycling measures are incorporated into project construction. Once operational, the project would comply with AB 939 and SB 1383 and not result in an increase in solid waste material generated on the project site. Therefore, no impacts associated with federal, state, or local solid waste statutes and regulations would occur. - 33- Environmental Issues Potentially Significant Less Than Significant Less Than Significant No Impact Impact with Impact Mitigation XX. WILDFIRE If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project: a) Substantially impair an adopted emergency response plan or emergency ❑ ❑ ❑ Q evacuation plan? b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, ❑ ❑ ❑ Q and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? c) Require the installation or maintenance of associated infrastructure (such as ❑ ❑ ❑ Q roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? d) Expose people or structures to significant risks, including downslope or ❑ ❑ ❑ Q downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes? Narrative Summary: a) No Impact. CAL FIRE is responsible for designating fire hazard severity zones (FHSZs) within the State Responsibility Area throughout California. FHSZs are geographical areas with an elevated risk for wildfire hazard. The State Responsibility Area is the area for which the state assumes financial responsibility for fire suppression and protection. CAL FIRE also creates recommended maps for very high FHSZs within the Local Responsibility Area, which are then adopted or modified and adopted by local jurisdictions. Development within a State Responsibility Area is required to abide by specific development and design standards. A review of CAL FIRE's FHSZ maps and data revealed that the project site is not within a State Responsibility Area or a very high FHSZ (CAL FIRE 2020, 2023). The majority of the area surrounding the project site is developed, and as a whole, the project area lacks any lands considered wildlands or wildland/urban interfaces. According to CAL FIRE's Fire Hazard Severity Zones maps, the project site is neither moderately, highly, nor very highly susceptible to wildland fire (CAL FIRE 2023). Therefore, no impacts associated with adopted emergency response or evacuation plans would occur. b) No Impact. The project site is not within a Fire Hazard Severity Zone or a Very High Fire Hazard Severity Zone according to maps by CAL FIRE (CAL FIRE 2020, 2023). In addition, the project site is within a developed portion of the City. Further, the project site does not contain vegetation or wildland fuel. Therefore, it is not anticipated that the proposed project, due to slope, prevailing winds, and other factors, would exacerbate wildfire risks or expose future occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. Therefore, no impacts associated with wildfire would occur. c) No Impact. The project site is not within a Fire Hazard Severity Zone according to maps by CAL FIRE (CAL FIRE 2020, 2023). The project site is within a developed portion of the City, and the proposed project would connect to existing utilities around the project site. The proposed project would not require installation or maintenance of other associated infrastructure such as fuel breaks, power lines, or other utilities that would exacerbate fire risk. As such, the proposed project would not expose people or structures to significant risk involving wildland fires, exacerbate wildfire risks, or otherwise result in wildfire -related impacts. Therefore, no impacts associated with the installation or maintenance of infrastructure would occur. d) No Impact. The project site is not within a Fire Hazard Severity Zone or a Very High Fire Hazard Severity Zone according to maps by CAL FIRE (CAL FIRE 2020, 2023). As discussed in Section VII, Geology and Soils, the proposed project would not result in significant risks associated with flooding, landslides, runoff, or drainage changes, and the proposed project does not propose the use of fire (such as for a controlled vegetation burn) that would result in post -fire slope instability. Further, the project site is within a developed portion of the City that is not susceptible to wildland fires, given its considerable distance from open, natural areas. Thus, the project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes. Therefore, no impacts associated with these risks would occur. - 34- Potentially Less Than Less Than No Environmental Issues Significant Significant Significant Impact Impact with Impact Mitigation XXI. MANDATORY FINDINGS OF SIGNIFICANCE a) Does the project have the potential to substantially degrade the quality of the ❑ ❑ Q ❑ environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b) Does the project have impacts that are individually limited, but ❑ ❑ Q ❑ cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? c) Does the project have environmental effects which will cause substantial ❑ ❑ 0 ❑ adverse effects on human beings, either directly or indirectly? Narrative Summary: a) Less -than -Significant Impact. As discussed in Section IV, Biological Resources; Section V, Cultural Resources; Section VII, Geology and Soils; and Section XVIII, Tribal Cultural Resources, the project would result in no impacts or less -than -significant impacts to biological resources, cultural resources, paleontological resources, and tribal cultural resources. Therefore, the project would not degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory. Impacts would be less than significant. b) Less -than -Significant Impact. As concluded throughout this Initial Study, the project would result in either no impact or less -than - significant impact with respect to all environmental impact areas outlined in the CEQA Guidelines Appendix G Environmental Checklist. Cumulative impacts of several resource areas have already been addressed in several resource sections: Section III, Air Quality; Section VIII, Greenhouse Gas Emissions; Section XIII, Noise; and Section XVII, Transportation. CalEEMod was used to assess the air quality and GHG emissions impacts resulting from the project, concluding less -than -significant impacts. The noise analysis conducted as part of this Initial Study concluded that cumulative impacts would be less than significant. The traffic assessment considered cumulative increases in traffic to be less than significant. Some of the other resource areas (i.e., Section I, Aesthetics; Section II, Agricultural and Forestry Resources; Section X, Hydrology and Water Quality; Section XI, Land Use and Planning; Section XII, Mineral Resources; Section XIV, Population and Housing; Section XV, Public Services; Section XVI, Recreation; and Section XIX, Utilities and Service Systems) were determined to have a less -than -significant impact or no impact compared to existing conditions, and, thus, the project would not contribute to cumulative impacts related to these environmental topics. Other issues areas (i.e., Section V, Cultural Resources; Section VII, Geology and Soils; Section IX, Hazards and Hazardous Materials; and Section XVIII, Tribal Cultural Resources) are by their nature site -specific, and impacts at one location do not add to impacts at other locations or create additive impacts. For all recourse areas analyzed, the project's individual -level impacts would be less than significant, which, in turn, would reduce the potential for these impacts to be considered part of any cumulative impact. Therefore, the project would not result in individually limited but cumulatively considerable impacts, and impacts would be less than significant. c) Less -than -Significant Impact. As evaluated throughout this document, the project would have no impact or a less -than -significant impact with respect to all environmental impact areas. Therefore, the project would not directly or indirectly cause substantial adverse effects on human beings, and impacts would be less than significant. - 35- REFERENCES AFR (Anaheim Fire and Rescue). 2023. "Operations." Accessed June 2023. http://www.anaheim.net/678/Operations. APU (Anaheim Public Utilities). 2020. Greenhouse Gas Reduction Plan, Sustainable Electric & Water Initiatives. May 2020. https://www.anaheim.net/DocumentCenterNiew/7987/Greenhouse-Gas- Reduction-Plan?bidld=. CAL FIRE (California Department of Forestry and Fire Protection). 2020. "State Responsibility Area (SRA) Viewer." Accessed June 2023. https:Hcalfire-forestry.maps.arcgis.com/apps/webappviewer/ index.html?id=468717e399fa4238ad86861638765cel . CAL FIRE. 2023. Fire Hazard Severity Zones Viewer. Accessed June 15, 2023. https:Hegis.fire.ca.gov/FHSZ. CaIEPA (California Environmental Protection Agency). 2023. "Cortese List Data Resources." Accessed June 2023. https:Hcalepa.ca.gov/sitecleanup/corteselist/. 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