Mitigated Negative Declaration

Transcription

Mitigated Negative Declaration
Orange Lutheran High School
EXPANSION
INITIAL STUDY/
MITIGATED NEGATIVE DECLARATION
Prepared for:
City of Orange
Community Development Department
Planning Division
300 E. Chapman Avenue
Orange, California 92866
Prepared by:
EDAW, Inc.
2737 Campus Drive
Irvine, California 92612
DECEMBER 2008
ORANGE LUTHERAN HIGH SCHOOL
EXPANSION
City of Orange
Initial Study/
Mitigated Negative Declaration (IS/MND)
Environmental Review No. 1794-07
Lead Agency:
City of Orange
300 E. Chapman Avenue
Orange, CA 92866
Contact: Mr. Robert Garcia, Associate Planner
(714) 744-7220
Consultant:
EDAW, Inc.
2737 Campus Drive
Irvine, California 92612
Contact: Ms. Jane Chang, Project Manager
(949) 660-8044
December 2008
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
DOCUMENT FORMAT
This Initial Study/Mitigated Negative Declaration (IS/MND) contains an introduction, a project description, a
CEQA environmental checklist, and impacts analysis. The document is comprised of three sections and
appendices.
The introduction provides an overview of the project and the CEQA environmental documentation process. The
project description provides a detailed description of project objectives and components. The Initial Study
Checklist presents the CEQA environmental checklist for all impact areas and mandatory findings of
significance. It also presents the environmental analysis for each issue area identified on the environmental
checklist form. When the proposed project does not have the potential to significantly impact a given issue area,
the relevant section provides a brief discussion of the reasons why no impacts are expected. If the proposed
project could have a potentially significant impact on a resource, the issue area discussion provides a description
of potential impacts, and appropriate mitigation measures that would reduce those impacts to a less than
significant level. The technical studies and data used to prepare this IS/ MND are included as appendices.
December 2008
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
TABLE OF CONTENTS
Page
Section
Mitigated Negative Declaration ................................................................................................................ 1
Environmental Factors Potentially Affected .......................................................................................... 18
Determination ........................................................................................................................................... 18
Evaluation of Environmental Impacts .................................................................................................... 19
CEQA Process ........................................................................................................................................... 20
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
Aesthetics ....................................................................................................................................... 21
Agricultural Resources .................................................................................................................. 39
Air Quality ..................................................................................................................................... 39
Biological Resources...................................................................................................................... 49
Cultural Resources ......................................................................................................................... 50
Geology and Soils .......................................................................................................................... 51
Hazards and Hazardous Materials.................................................................................................. 53
Hydrology and Water Quality ........................................................................................................ 54
Land Use/Planning ........................................................................................................................ 61
Mineral Resources.......................................................................................................................... 62
Noise .............................................................................................................................................. 63
Population and Housing ................................................................................................................. 73
Public Services .............................................................................................................................. 74
Recreation ...................................................................................................................................... 75
Transportation/Traffic .................................................................................................................... 75
Utilities and Service Systems......................................................................................................... 81
Mandatory Findings of Significance .............................................................................................. 82
References Sited............................................................................................................................. 83
Technical Appendices .................................................................................................................... 84
December 2008
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Appendices
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
December 2008
Air Quality Impact Analysis, Giroux & Associates, July 10, 2008.
Draft Preliminary Water Quality Management Plan (WQMP), Blue Peak Engineering, Inc.,
April 21, 2008.
Inspection Report, County of Orange, Health Care Agency, Environmental Health, April 20,
2007.
Noise Impact Analysis, Giroux & Associates, September 17, 2008.
Lutheran High School Facilities Improvements Traffic Analysis, Austin-Foust Associates, Inc.,
November 2008.
Mitigation Monitoring Report, October 2008.
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
LIST OF FIGURES
Figure
Page
1 Regional Location................................................................................................................................... 2
2 Local Vicinity ......................................................................................................................................... 3
3 Existing and Surrounding Land Uses ..................................................................................................... 4
4 Site Photos ............................................................................................................................................. 5
5 Existing Site Plan.................................................................................................................................... 6
6 Proposed Site Plan .................................................................................................................................. 8
7 Lower Level Plan.................................................................................................................................... 9
8 First Floor Plan ..................................................................................................................................... 10
9 Second Floor Plan................................................................................................................................. 11
10 Elevations Plan ..................................................................................................................................... 13
11 Landscape Plan ..................................................................................................................................... 15
12AMassing Model..................................................................................................................................... 24
12BMassing Model ..................................................................................................................................... 25
13 Visual Simulation R1............................................................................................................................ 26
14 Visual Simulation R2............................................................................................................................ 27
15 Visual Simulation R3............................................................................................................................ 28
16 Visual Simulation R4............................................................................................................................ 29
17 Visual Simulation R5............................................................................................................................ 30
18 Visual Simulation R6............................................................................................................................ 31
19 Visual Simulation R7............................................................................................................................ 32
20 Visual Simulation R8............................................................................................................................ 33
21 Glare Study ........................................................................................................................................... 34
22A Shadow Study on June 21 – Existing Building ................................................................................... 35
22B Shadow Study on June 21.................................................................................................................... 36
22C Shadow Study on December 21 – Existing Building .......................................................................... 37
22D Shadow Study on December 21 .......................................................................................................... 38
23 Noise Meter Locations.......................................................................................................................... 66
24 Existing ADT Volumes ........................................................................................................................ 77
25 Existing AM Peak Hour Volumes ........................................................................................................ 78
26 Existing PM Peak Hour Volumes......................................................................................................... 79
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Initial Study/Mitigated Negative Declaration
LIST OF TABLES
Page
Table
A
3-1
3-2
3-3
3-4
3-5
3-6
3-7
8-1
11-1
11-2
11-3
11-4
11-5
11-6
11-7
11-8
15-1
15-2
Building Area Information............................................................................................................. 12
Orange Area Air Quality Monitoring Summary – 2002-2006 ....................................................... 40
SCAQMD Emissions Significance Thresholds (pounds per day).................................................. 42
A Comparison of PM-10 Dust Emissions for the Two Dust Control Scenarios ............................ 43
Construction Equipments ............................................................................................................... 44
Daily Emissions ............................................................................................................................. 45
LST Pollutant Concentration Data ................................................................................................. 46
Project-Operations Air Pollution Emissions (pounds per day) ...................................................... 46
Runoff Calculations ....................................................................................................................... 57
Orange Municipal Code Noise Ordinance Standards (dB) ............................................................ 63
Short-Term Noise Measurement (July 27, 2007)........................................................................... 65
Project Noise Sources and Impacts ................................................................................................ 67
Outdoor Sports Court Analysis Summary...................................................................................... 68
Relocated Parking Lot Analysis Summary .................................................................................... 69
Single Event Parking Lot Activity Noise....................................................................................... 69
Project Traffic Noise ...................................................................................................................... 71
Noise Levels of Construction Equipment at 25, 50, and 100 Feet in
(dBA LEQ) from the Source .......................................................................................................... 72
Proposed Project Trip Generation Summary ................................................................................. 76
Existing + Project ICU Summary .................................................................................................. 76
December 2008
v
City of Orange
Community Development Department • Planning Division
300 East Chapman Avenue
Orange, CA 92866-1591
(714) 744-7220
(714) 744-7222 Fax
www.cityoforange.org
ENVIRONMENTAL REVIEW NO. 1794-07
Project Title:
Orange Lutheran High School Expansion
Reference Application Numbers:
Major Site Plan Review No.484-07
Environmental Review No.1794-07
Design Review Committee No.4402-08
Lead Agency:
City of Orange
300 E. Chapman Avenue
Orange, CA 92866
Contact Person and Telephone No.:
Robert Garcia, Associate Planner
(714) 744-7231
Project Proponent and Address:
Lutheran High School of Orange County
2222 N. Santiago Boulevard
Orange, CA
Contact Person and Telephone No.:
Rich Kahler
Lutheran High School of Orange County
(714) 998-5151
Project Location: The proposed project is located in the City of Orange. The regional setting of the
project area is shown on Figure 1, Regional Location. The site is located north of Meats Avenue,
south of Villa Vista Way, east of 55 Newport Freeway, and west of Santiago Boulevard. Please see
Project Description below for additional information, and Figure 2, Local Vicinity.
Existing General Plan Designation:
Low Density Residential 2-6 DU/AC (LDR)
Existing Zoning Classification:
Single Family Residential 8000 square
feet (R-1-8)
Existing Site Conditions:
The 12.82-acre project site is currently occupied as the Orange Lutheran High School. The project
site is approximately 590 feet wide and one-quarter mile deep, consisting of: classrooms, parking lot,
faculty offices, a library, laboratories, hallways, ancillary facilities, a patio, a gymnasium, a multimedia resource center, a football/soccer field, an outdoor sports court for tennis and basketball, and
the Alexandra Nechita Center for the Arts. See Figure 3, Existing and Surrounding Land Uses,
Figure 4, Site Photos, and Figure 5, Existing Site Plan.
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Los Angeles
International
Airport
Project
Site
Long Beach
Airport
John Wayne
(Orange County)
Airport
Pacific
Ocean
Figure 1
Regional Location
North
NTS
December 2008
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
PLACENTIA
FULLERTON
Warner
Basin
R
ANAHEIM
R
Anaheim Hills
Golf Course
ANAHEIM
HILLS
OLIVE
AN
A
ANAHEIM
IV
E
Peralta
Canyon Park
TA
.
vd
Bl
SAN
go
ia
nt
Sa
The
Village
at
Orange
PROJECT
SITE
ORANGE
Meats Ave.
Santiago Oaks
Regional Park
VILLA PARK
Arrowhead Pond
of Anaheim
ORANGE
PARK
ACRES
ORANGE
Santiago
Creek
Recharge
Basin
Angel
Stadium
Ridgeline
Country
Club
El
Modena
Open
Space
Holy
Sepulcher
Cemetery
Irvine
Regional
Park
EL MODENA
Figure 2
Local Vicinity
North
NTS
December 2008
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Project
Site
ay
aW
E.
E. Villa Vista Way
55
l
Vil
E.
re
Se
e
riv
D
no
N. Diamond Street
ard
lev
ou
oB
ag
nti
Sa
Costa Mesa Freeway
Lutheran High School
Main Campus
N. Agate Street
Orange
Mobile
Home
Park
ist
aV
E.
Ri
g
din
y
Wa
E. Riding Way
Meats Avenue
Tropical
Plaza
Nursery
Independence
Christian
Private
Elementary
School
Figure 3
Existing and Surrounding Land Uses
NTS
December 2008
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
1
Main entrance on Santiago Boulevard, viewed toward
northwest
2 Building view from Santiago Boulevard, viewed
3
Parking lot, viewed toward southwest
4
Driveway and walkway, viewed toward southwest
5
School building, viewed toward northwest
6 Multi-purpose facility and cafeteria seating area,
7
Temporary parking area, viewed toward west
8
Tennis courts, viewed toward southwest
toward west
viewed toward northeast
11
8
10
9
Athletic field, viewed toward west
10 Existing fire lane, viewed toward east
9
7
4
6
5
2
3
1
12
North
11 Existing homes located north of the project site, viewed
from Villa Vista Way
12 View of the school buildings from the existing homes
on N. Agate Street
Key Map
Figure 4
Site Photos
December 2008
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 5
Existing Site Plan
North
NTS
December 2008
6
Surrounding Land Uses:
The project site is located within an urbanized area in the City of Orange, surrounded by single
family residential uses to the north (R-1-8), east (R-1-20) and south (R-1-7 and R-1-8), and a
freeway to the west.
Project Description:
Demolition of Facilities
The proposed project includes demolition of the existing concrete tennis courts (approximately
21,320 square feet) and the temporary parking lot, containing 50 parking spaces (approximately
20,800 square feet) to accommodate the new facilities. See Figure 5, Existing Site Plan.
Proposed Improvements
The applicant proposes improvements to the campus consisting of:
ƒ
Construction of a 35,495-square foot, two-story addition on the west end of the existing
multi-purpose building (lower level) / gymnasium (first floor) (“multi-purpose building”).
ƒ
Construction of an outdoor basketball and volleyball sports court.
ƒ
Installation of new landscaping.
ƒ
Reconstruction of the parking area.
Please see Figure 6, Proposed Site Plan. It should be noted that the proposed project will not
increase the number of students attending the school. The cap of 1,150 students was set
through Conditional Use Permit No. 2499-04 on August 13, 2004. Details of each component
follow:
Multi-Purpose Building Addition:
The proposed two-story addition will consist of 10 new classrooms on the upper level. The
existing Conditional Use Permit for the Orange Lutheran High School allows a total of 49
classrooms on site (CUP No. 2262-98). Currently, there are 44 classrooms on site. Although
the project proposes 10 additional classrooms, five of the existing classrooms in the existing
building will be taken out of service. These five classrooms will be turned into office, meeting,
and storage space. Therefore, the net increase of five classrooms will keep the total number of
classrooms on site to 49. The lower level will consist of additional sports related facilities
including new sports locker rooms, new athletic offices, team room, wrestling/multi-purpose
room, and space for all instrumental music practice and storage, including marching band,
orchestra, string ensemble, and jazz band. See Figures, 7 through 9, Floor Plans. The additional
35,495 square feet includes the enclosure of the existing outdoor space between the existing
multi-purpose building and the original school building to the east. This additional square
footage will be added to the existing 148,141 square feet of building area, totaling 183,636
square feet. See Table A, Building Area Information. Besides this expansion of the multipurpose building, no new additional building area is proposed.
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 6
Proposed Site Plan
North
NTS
December 2008
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 7
Lower Level Plan
North
NTS
December 2008
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 8
First Floor Plan
North
NTS
December 2008
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 9
Second Floor Plan (No Changes Proposed)
North
NTS
December 2008
11
Table A
Building Area Information
Level
Lower
First
Second
Total
Total Building Area
Existing Area
14,715 S.F.
114,391 S.F.
19,035 S.F.
148,141 S.F.
Proposed Addition
18,318 S.F.
17,177 S.F.
35,495 S.F.
183,636 S.F.
The design of the proposed building would use similar materials and colors to be consistent with
the existing buildings on site. The design will continue the architectural style and character
articulated at the Santiago entry to the school, which incorporates painted exterior plaster façade
with decorative horizontal banding decorative 12-inch square architectural insets. Also, there
will be windows at the head of the classroom. This window placement would allow natural
light into the classroom without distracting the normal classroom function by limiting and
controlling the location of the natural light coming into the classroom. The building will have a
flat roof and decorative metal cornice parapet to hide any roof top equipment. The southwest
entry consists of a half barrel vaulted roof clad with a raised seam metal roof system to
coordinate with the existing buildings. There will be painted metal architectural ‘eyebrows’ or
projections at various locations, including entries, in keeping with the previous architectural
style already established on-site.
The highest elevation of the existing building is 46 feet which complies with the previous CUP
2262-98. The existing multi-purpose building is a three-story building: basement level (lower
level), first level, and second level. The proposed project will have a first level and second
level. Besides the existing basement and grade difference, the proposed project will not
introduce additional grade difference to the site. Due to the site grades, the upper level will be
at the same level as the entry level at the front of the school. The lower level will be a walk out
to grade at the sports field level or grade. The highest part of the new building would be 40 feet
5 inches. In order to keep the elevation of the new building under the approved height
limitation, the footprint of the proposed building would be larger than what was approved in the
existing CUP. See Figure 10, Elevations Plan.
Outdoor Sports Court:
Another component of the project includes a new outdoor sports court for basketball and
volleyball. This court will replace the existing temporary parking lot. The proposed layout of
the sports court is an approximately 10,000-square foot blacktop with sports related graphics.
The sports court will be lined to regulate the size for Physical Education (PE) class and freshman
team practice. PE class would use it from 7:30 A.M. until 2:30 p.m. on school days. And
freshman team practice would use it from 2:30 P.M. to 6:30 P.M. depending on the daylight
conditions as no lights are proposed on the sports court. During summer, the outdoor sports
court would be used in the morning from 7:30 A.M. to 12:00 P.M. to avoid the heat. Fencing is
being considered.
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 10
Elevations Plan
December 2008
13
Landscaping:
The proposed Landscape Plan for the project site is included in this document as Figure 11.
The new landscaping area associated with parking is 3,510 square feet, sports court is 2,089
square feet, and new building is 1,012 square feet. According to the Landscape Plan, the entire
project site will be automatically irrigated, and the system will conform with the Model Water
Efficient Landscape Ordinance AB325 requirements. To conserve water, the landscape will be
designed to incorporate drought tolerant plant material arranged in specific hydrozones, and
shredded bark mulch will be used under all shrub plantings to conserve soil moisture and cool
soil. The irrigation system will be programmed to apply exact amount of water to meet actual
plant needs. In addition, the precipitation interrupt devices will be used, and three inches of
amendment will be incorporated into the native soils per the agricultural suitability and fertility
study. Minimum tree size will be 15 gallons and minimum shrub size will be 1 gallon.
Approximately 86.7 percent of the new trees would be sized 36-inch box, approximately 1.6
percent would be sized 60-inch box, and approximately 11.7 percent would match the size of the
existing palms. The proposed project would require removal of 28 trees, replacement of 60
trees and preservation of 11 trees. Quantity of trees replaced would exceed by double the
quantity of trees being removed. All trees removed will be replaced with a larger
circumference trees. The landscape plan will be in compliance with the City requirements as
well as consistent with the CUP 2262-98 conditions of approval. In addition, the plan will help
screen the new building from adjacent neighbors to the north.
Parking Area:
The existing main parking lot, located south of the existing school, contains 374 spaces and the
temporary parking lot, located west of the existing multi-purpose building, contains 50 spaces.
The 50 parking spaces at the temporary parking lot are proposed to be removed and the outdoor
sports court will be constructed on that area. The existing tennis/sports courts located north to
the temporary parking lot will be demolished and the 61 new parking spaces will be built,
resulting in an increase of 11 parking spaces. See Figure 6, Proposed Site Plan. During the
demolition/construction of the parking lot, the faculty will park in the main lot. There will be
more carpooling during the construction period just as the school practiced during the previous
construction phases. The new parking lot will be used in the same manner as the existing
parking lot. It will be used by the school faculty during school hours (7:30 A.M. to 2:30 P.M.)
and open to the general school public after hours and during special events (2:30 P.M. to 10:00
P.M.).
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Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 11
Landscape Plan
December 2008
15
Project Construction Phasing
Construction is expected to last approximately 2.5 years in three phases. There is no potential
of more than 49 classrooms being used for any period of time. The occupancy shift (existing
classrooms move) and remodel of existing classrooms will occur in the same phase (Phase III),
which would be approximately four months after the new classrooms are completed. The new
classrooms will not be occupied until Phase III and only after all adjacent remodel (Phase II) is
complete.
Phase I: New Building
ƒ
ƒ
ƒ
Demolition of Tennis Courts/Sports Court and temporary parking lot
Construction of all new building square footage including the link between the existing school
and existing gymnasium
All site work and landscaping
Duration: 14 months
Phase II: Lower Gymnasium Remodel (Interior) and Moving
ƒ
Shift occupancy uses to new area and remodel existing lower gymnasium space
Duration: 4 months
Phase III: Existing School Remodel (Interior) and New SW Entry Remodel
ƒ
ƒ
ƒ
ƒ
ƒ
ƒ
ƒ
ƒ
Shift occupancy uses to new areas and remodel existing spaces
New corridor construction
Choir Room remodel
Office remodel
SW Entry remodel
Food service remodel
Wood shop remodel
Performing Art Center support room remodel
Duration: 12 months
Discretionary Actions
The following actions by the City of Orange are required to implement the proposed project:
ƒ
Environmental Review No. 1794-07: The City of Orange has determined that a Mitigated
Negative Declaration (MND) is required to analyze the potential environmental impacts of
the project. This MND has been prepared in accordance with CEQA and the City’s Local
CEQA Guidelines. The City of Orange will consider the MND prior to taking action on the
requested approvals.
ƒ
Major Site Plan Review No. 484-07: Approval of a Major Site Plan Review is required since
the project includes modification to site improvements, building, and landscaping.
ƒ
Design Review Committee No. 4402-08: Approval of a Design Review is required since the
project includes addition to the existing multi-purpose building, demolition of the temporary
16
parking lot and tennis courts, construction of outdoor sports court, new parking lot, and
modification/installation of landscaping.
Other Public Agencies Whose Approval is Required (Responsible or Trustee Agencies):
None
Initial Study Prepared by:
EDAW, Inc.
2737 Campus Drive
Irvine, CA 92612
Scheduled Public Meetings or Hearings:
TBD
17
EVALUATION OF ENVIRONMENTAL IMPACTS:
1. A brief explanation is required for all answers except “No Impact” answers that are adequately supported by
the information sources a lead agency cites in the parentheses following each question. A “No Impact”
answer is adequately supported if the referenced information sources show that the impact simply does not
apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact”
answer should be explained where it is based on project-specific factors as well as general standards (e.g.,
the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).
2. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative
as well as project-level, indirect as well as direct, and construction as well as operational impacts.
3. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers
must indicate whether the impact is potentially significant, less than significant with mitigation, or less than
significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may
be significant. If there are one or more “Potentially Significant Impact” entries when the determination is
made, an EIR is required.
4. “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the
incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less
Than Significant Impact”. The lead agency must describe the mitigation measures, and briefly explain how
they reduce the effect to a less than significant level (mitigation measures from earlier analyses may be
cross-referenced, as discussed below).
5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect
has been adequately analyzed in an earlier EIR or negative declaration. Section 15063 (c)(3)(D). In this
case, a brief discussion should identity the following:
a. Earlier Analysis Used.
Identify and state where they are available for review.
b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope
of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state
whether such effects were addressed by mitigation measures based on the earlier analysis.
c. Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures
Incorporated”, describe the mitigation measures which were incorporated or refined from the earlier
document and the extent to which they address site-specific conditions for the project.
6. Lead agencies are encouraged to incorporate into the checklist references to information sources for
potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside
document should, where appropriate, include a reference to the page or pages where the statement is
substantiated.
7. Supporting Information Sources: A source list should be attached, and other sources used or individuals
contacted should be cited in the discussion.
8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies
should normally address the questions from this checklist that are relevant to a project’s environmental
effects in whatever format is selected.
9. The 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 significance.
19
CEQA PROCESS
The Initial Study/MND is prepared pursuant to the requirements of Section 15063, 15070, and 15071 of the
California Environmental Quality Act (CEQA) Guidelines and Public Resources Code Section 21000 et seq.
According to Section 15063 of the CEQA Guidelines, the purposes of an Initial Study are to: (1) Provide the
Lead Agency with information to use as the basis for deciding whether to prepare an EIR or a Negative
Declaration; (2) Enable an applicant or Lead Agency to modify a project, mitigating adverse impacts before an
EIR is prepared, thereby enabling the project to qualify for a Negative Declaration; or (3) Assist in the
preparation of an EIR, if one is required. The proposed expansion of the Lutheran High School of Orange
County is considered a “project” under CEQA, and the City of Orange (City), as the Lead Agency, has
concluded that a Mitigated Negative Declaration (MND) would be the proper level of analysis for this project.
This conclusion is based on the information and analysis contained in the IS and the references cited therein,
showing that the impacts caused by the proposed project are either less than significant or significant but
mitigable with incorporation of appropriate mitigation measures. This conclusion is supported by CEQA
Guidelines Section 15070, which states an MND can be prepared when “(a) The initial study shows that there is
no substantial evidence, in light of the whole record before the agency, that the project may have a significant
effect on the environment, or (b) The initial study identifies potentially significant effects, but: (1) Revisions in
the project plans or proposals made by, or agreed to by the applicant before a proposed mitigated negative
declaration and initial study are released for public review would avoid the effects or mitigate the effects to a
point where clearly no significant effects would occur, and (2) There is no substantial evidence, in light of the
whole record before the agency, that the project as revised may have a significant effect on the environment.”
A 30-day review period will be established for the IS/MND. The IS/MND specifically has been distributed to
the interested or involved public agencies, organizations, and private individuals for review and comment. If
they fail to reply within the 30-day with either a response or a well justified request for additional time, the Lead
Agency may assume that none of those entitles have a response to make and may ignore a late response (CEQA
Section 15103).
20
CHECKLIST OF ENVIRONMENTAL IMPACT ISSUES:
1.
(a)
(b)
(c)
(d)
AESTHETICS.
Potentially
Significant
Impact
Would the project:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Have a substantial adverse effect on a scenic vista?
Substantially damage scenic resources, including, but not limited to, trees,
rock outcroppings, and historic buildings within a state scenic highway?
Substantially degrade the existing visual character or quality of the site and
its surroundings?
Create a new source of substantial light or glare which would adversely
affect day or nighttime views in the area?
Reference: 6, 7, & 8
Impact Analysis
a) No Impact. The City of Orange has established policies to preserve visual and aesthetic resources. The City
of Orange General Plan identifies the hills in the eastern portion of the City as important visual resources that
require preservation, as well as the Santiago Canyon Road east of Jamboree Road and median landscaping of the
City’s Boulevards. The largely undeveloped Santiago Hills II and East Orange portion of the City have many
scenic resources including Irvine Lake, grassy valleys, rugged hillsides, and winding canyons. The proposed
project site is located in an urbanized residential area with no scenic resources in its adjacency. Therefore, the
proposed project would neither affect nor damage any of these visual resources. No impacts would occur.
b) No Impact. There are no state scenic highways in the vicinity or within the proposed project area.
impacts would occur.
No
c) Less Than Significant With Mitigation Incorporated. The project site is developed as a high school
campus with multi-purpose building, athletic fields, tennis courts, and a parking lot. The site is surrounded by
a four-lane roadway (Santiago Canyon Road), freeway, and single family residential tracts. The proposed
project involves demolition of the existing tennis courts and the temporary parking area to construct a new
parking lot, an outdoor sports court, and a two-story expansion to the existing multi-purpose building. See
Figures 12A and 12B, Massing Model – View towards N.E. These two figures are the three-dimensional
model of the existing gymnasium building along with the proposed additional building. Also shown on
Figures 12A and 12B are the proposed parking lot next to the expansion and the outdoor sport court.
Demolition and construction activities would result in negative views from the adjacent residential units.
However, these construction impacts, though negative, are temporary. Also, the existing 6-foot block wall to
the north of the site between the residential uses and the site will be retained for screening purposes and will be
enhanced by landscaping (see Figure 11, Landscape Plan).
Implementation of the proposed project would have a potentially significant effect on the existing visual setting.
The proposed project would introduce a new structure and increased density and would change the existing
appearance of the site. The highest elevation of the existing building is 46 feet which complies with the
previous CUP 2262-98. The existing multi-purpose building is a three-story building consisting of basement
level (lower level), first level, and second level. The proposed project will have a first level and second level.
Besides the existing basement and grade difference, the proposed project will not introduce additional grade
difference to the site. The highest part of the proposed building would be 40 feet 5 inches. In order to keep
the elevation of the proposed building under the approved height limitation, the footprint of the proposed
building would be larger than the existing building. The distance between the existing multi-purpose building
and the closest residence to the north is 88 feet and 6 inches whereas the distance between the proposed building
and the closest residence to the north would be 61 feet and 2 ½ inches.
21
Please see Figures 13 through 20, Visual Simulations R1 through R8, for the simulation of the project site from
the eight existing residences that are located adjacent to the proposed expansion. Each visual simulation has a
key plan of a view point, a key plan of the eight residences, and a view of existing multi-purpose building and
proposed expansion to the existing multi-purpose building. The previously approved structure is shown in
each visual simulation as a reference to what is proposed. Even though the proposed expansion has a greater
footprint and is located closer to the adjacent residences than the existing structure, it is still located within the
school property line, and the view of the expansion would be partially screened by the existing 6-foot block wall
and the landscape enhancement along the existing fire lane. In some case, the proposed expansion would be
out of view from the backyard of the neighboring residence (see Figure 13).
Although the proposed project would alter the visual character of the site, it will not substantially degrade the
visual quality of the project site, as the new structure will be compatible with the existing multi-purpose
building. Similar building materials and colors will be used for consistency. The design will continue the
architectural style and character articulated at the Santiago entry to the school. The project site would be
landscaped to further enhance its visual quality. The proposed landscaping will be compatible with the
landscaping currently on the site. The proposed trees between the existing residences to the north of the
project site and the proposed expansion to the existing multi-purpose building will provide screening. The
existing 6-foot block wall located between the existing multi-purpose building and the adjacent residences will
not be altered as a result of the proposed project. In addition to the compliance with the City of Orange
Municipal Code, incorporation of Mitigation Measure 1-1 below would help avoid the impacts and enhance the
visual character of the site.
MM1-1
Prior to issuance of building permits, the applicant shall submit and receive approval for a
landscape plan along the existing fire lane to screen the potentially negative views from the
adjacent residences. The landscape plan shall specify materials and size of plantings.
d) Less Than Significant With Mitigation Incorporated. Although existing uses on the site are already
lighted, the expansion of the facility would require additional outdoor lighting on buildings for safety and
security. The lighting along the fire lane adjacent to homes would be consistent with the existing lights and
would comply with the City of Orange Municipal Code Section 17.12.030 Lighting and Section 15.52.120 Rural
and Private Street Lighting Provisions. Additionally, there will be no lighting in the outdoor sports court to
prohibit the use of the facility at night time. The new lighting will be in compliance with the City of Orange
Municipal Code (Section 17.34.130 Maintenance and Operation of Permanent Parking Areas), and lights used to
illuminate the parking area will be directed away from any adjoining property located in any R-zone in
accordance with Section 17.12.030 Lighting. Based on Section 17.12.030, lighting on parking areas will be
directed, controlled, screened or shaded in such a manner as not to shine directly on surrounding premises.
Metal surfaces, building windows, and automobile windows would generate glare during the daytime. The
proposed project does not introduce any building surfaces that would generate glare that could impact the
surrounding uses. The proposed building is an expansion to the existing multi-purpose building, and therefore,
would be similar to the existing development on the site and would not be a significant source of glare. The
building will be primarily an exterior sand textured painted plaster finish. The sand plaster finish inherently
absorbs and refracts light to reduce solar glare. The paint color scheme’s neutral pallet of creams, tans and
browns will help blend the building in with the site’s surroundings, down play building mass and minimize solar
glare. Additionally, the amount of materials with reflective character such as metal or glazing would be
minimized along the northerly elevation adjacent to neighboring homes. This proposed design approach with
the additional landscape screening would reduce the potential glare impacts. During daytime, the amount of
glare depends on intensity and direction of sunlight, and the enclosed Glare Study is the best estimate provided
by the project architect at this project stage. Figure 21 illustrates that at 2 o’clock and 4 o’clock in the
afternoon, there may be some glare reflected to one of the adjacent residences’ backyard. However, according
to the solar path shown on Figure 21, the existing buildings on campus would block the sun path from reflecting
22
glare to the adjacent residences at different time of the day. Regardless, the following mitigation measure is
proposed to ensure that the project impact related to glare would be less than significant.
MM1-2
Prior to issuance of Certificate of Completion, the applicant shall demonstrate that the finished
building will not result in substantial glare on adjacent uses. If necessary, the City of Orange
shall require additional features, such as building material adjustment and solar shade and/or
awning, to alleviate potential glare.
A significant shade and shadow impact would occur if the proposed project structure blocks direct sunlight to
the adjacent unshaded shadow-sensitive uses for two continuous hours or more between the 9:00 A.M. and 4:00
P.M. hours during the winter months, or between the 9:00 A.M. and 5:00 P.M. hours during the summer
months. Shadow sensitive uses include off-site residential structures and rear yard patio areas, public parks
and recreation areas, and public school. The shading can be influenced by different factors such as season,
weather, time of day, and structure size. The shadow cast would be the longest in winter time, since the sun is
lowest on the horizon; and therefore, summer time would result in shortest shadow cast. Shadows are longer in
the early morning and late afternoon. For purpose of this determination, the shadow impacts are plotted for
winter solstice (December 21st) and summer solstice (June 21st) at 2 o’clock and 4 o’clock in the afternoon (see
Figures 22A through 22D, Shadow Study). Figures 22A and 22C show the shadows created under the existing
condition as a baseline. During the summer, as shown in Figures 22A and 22B, the shadow moves from west
to east avoiding the adjacent residences. The shadow lengths are shorter than winter shadow lengths and
would primarily remain within the project site and would not fall on adjacent sensitive uses. Also, the
difference between the shadows created by the existing building and by the proposed building is minimal. The
additional shadows created by the proposed building would stay within the project site. Therefore, projectrelated summer shadows would be less than significant.
During the winter, as shown in Figures 22C and 22D, shadows from the project site would extend to the north,
northwest, and northeast depending on the time of day. As shown in Figure 22D, at 2 o’clock in the afternoon,
the shadows casted on the adjacent residences are mainly from the existing 6-foot wall and trees. At 4 o’clock
in the afternoon, darker gray tone reflects that there is less available light as the sun is lower on the horizon.
However, it should be noted that the shadow is still casted by the project building intercepting the direct
sunlight. The shadow study on December 21 at 4:00 P.M. is considered the worst-case scenario since the late
afternoon during winter months would cast the longest shadow. The worst-case scenario in Figures 22C and
22D show that residences R4 through R8 are already subject to shadows casted by existing 6-foot wall and trees
and will continue to experience them. Residence R1 is already subject to shadows casted by the existing 6-foot
wall, trees, and gymnasium building and will continue to experience them. Residences R2 and R3 would
experience the most project-related shadow in addition to the existing 6-foot, trees, and gymnasium building.
Figure 22C shows that most of the Residences R2 and R3 are already covered under the existing conditions.
Figure 22D shows that with the proposed building, rest of the Residences R2 and R3 would be covered by the
shadows of the new addition. However, these shadows would not occur throughout the year and would not
substantially alter nor degrade the land use. Also, these residences are already subject to shadows casted by
existing 6-foot wall, trees, and gymnasium building that is taller than the proposed expansion building.
Furthermore, the project-related shadow lengths would not cast a shadow on the adjacent property until
approximately 2:00 P.M. or later. Thus, the project-related winter shadows would not impact adjacent property
for more than two hours between 9:00 A.M. and 4:00 P.M. Therefore, the impacts related to shade and shadow
would be less than significant.
23
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Existing Gymnasium
Building
Proposed Addition
Figure 12A
Massing Model A - View towards N.E.
NTS
December 2008
24
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 12B
Massing Model B - View towards N.E.
NTS
December 2008
25
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 13
View Simulation R1
NTS
December 2008
26
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 14
View Simulation R2
NTS
December 2008
27
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 15
View Simulation R3
NTS
December 2008
28
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 16
View Simulation R4
NTS
December 2008
29
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 17
View Simulation R5
NTS
December 2008
30
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 18
View Simulation R6
NTS
December 2008
31
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 19
View Simulation R7
NTS
December 2008
32
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 20
Visual Simulation R8
NTS
December 2008
33
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 21
Glare Study - On December 21 between 2 and 4 P.M.
NTS
December 2008
34
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 22A
Shadow Study on June 21 at 2:00 P.M.
NTS
December 2008
35
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 22B
Shadow Study on June 21 at 4:00 P.M.
NTS
December 2008
36
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 22C
Shadow Study on December 21 at 2:00 P.M.
NTS
December 2008
37
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 22D
Shadow Study on December 21 at 4:00 P.M.
NTS
December 2008
38
2.
AGRICULTURAL 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.)
Would the project:
Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a)
Convert Prime Farmland, Unique Farmland, or Farmland of Statewide
Importance (Farmland), as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the California Resources
Agency, to non-agricultural use?
(b)
Conflict with existing zoning for agricultural use, or a Williamson Act
contract?
(c)
Involve other changes in the existing environment which, due to their
location or nature, could result in conversion of Farmland, to nonagricultural use?
Reference: 6, 7, 8, & 9
Impact Analysis
a) No Impact. The proposed project site does not contain any Prime Farmland, Unique Farmland, Farmland of
Statewide Importance (Farmland), or other agricultural resources or operations (2004 Orange County Important
Farmland GIS Data, California Division of Land Resource Protection & Figure VI-1, Prime Farmland in Orange
County, Orange County General Plan 2005). The project site is not zoned for agricultural uses and contains no
existing agricultural operations, nor has the site been used for agricultural production in the recent past. No
impacts would occur.
b) No Impact. The proposed project is within a well-established urbanized portion of the City of Orange. The
project site is not zoned for agricultural uses and contains no existing agricultural operations, nor has the site been
used for agricultural production in the past. There are no existing uses, beyond the site boundary that would be
affected by the proposed project. Therefore, the project would not conflict with existing zoning for agricultural
use nor would it conflict with the Williamson Act. No impacts would occur.
c) No Impact. The project site and the surrounding area are located within a developed, urban context. The
project site is currently developed with a school and supporting facilities. The project site is not adjacent to
active farming areas. No impacts on agricultural uses would occur from project implementation.
3.
AIR QUALITY. (Where available, the significance criteria established by
the applicable air quality management or air pollution control district may
be relied upon to make the following determinations.)
Would the project:
Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a)
(b)
Conflict with or obstruct implementation of the applicable air quality plan?
Violate any air quality standard or contribute substantially to an existing or
projected air quality violation?
(c)
Result in a cumulatively considerable net increase of any criteria pollutant
for which the project region is non-attainment under an applicable federal or
state ambient air quality standard (including releasing emissions which
exceed quantitative thresholds for ozone precursors)?
(d)
Expose sensitive receptors to substantial pollutant concentrations?
(e)
Create objectionable odors affecting a substantial number of people?
Reference: 3, 4, 5, 7, 11, & 14
Impact Analysis:
a) Less than Significant Impact. An air quality analysis was prepared by Giroux and Associates (Appendix A)
to assess the project’s air quality impacts. In order to assess the air quality impact of the proposed project, that
39
impact, together with baseline air quality levels, must be compared to the applicable ambient air quality
standards. Existing and probable future levels of air quality around the proposed project area can best be
inferred from ambient air quality measurements conducted by the South Coast Air Quality Management District
(SCAQMD) at the Anaheim monitoring station. This station measures both regional pollution levels such as
smog, as well as primary vehicular pollution levels near busy roadways such as carbon monoxide or nitrogen
oxides. Some pollutants such as particulates (PM-10 and PM-2.5) are also monitored at Anaheim. Table 3-1
is a 5-year summary of monitoring data for the major air pollutants compiled from this air monitoring stations.
Table 3-1
Orange Area Air Quality Monitoring Summary – 2002-2006
(Days Standards Were Exceeded and Maximum Observed Levels)
Pollutant/Standard
Ozone
1-Hour > 0.09 ppm (S)
1-Hour > 0.12 ppm (F)
8-Hour > 0.07 ppm (S)
8-Hour > 0.08 ppm (F)
Max 1-Hour Conc. (ppm)
Carbon Monoxide
1-Hour > 20. ppm (S)
8-Hour > 9. ppm (S, F)
Max 1-Hour Conc. (ppm)
Max 8-Hour Conc. (ppm)
Nitrogen Dioxide
1-Hour > 0.25 ppm (S)
Max 1-Hour Conc. (ppm)
PM-10
24-Hour > 50 μg/m3 (S)
2002
2003
2004
2005
2006
3
0
0
0.10
11
2
1
0.14
14
0
6
0.12
1
0
4
0
0.10
5
0
3
1
0.11
0
0
7.
5.4
0
0
6.
3.9
0
0
5
4.1
0
0
4
3.3
0
0
5
3.0
0
0.10
0
0.13
0
0.12
0
0.09
0
0.11
5/61
0/61
6/61
0/61
7/61
0/61
3/61
0/61
7/56
0/56
69.
96.
74.
65.
104.
24-Hour > 65 μg/m3 (F)
1/351
3/340
0/319
0/333
0/330
Max. 24-Hour Conc. (μg/m3)
68.6
115.5
58.9
54.7
56.2
24-Hour > 150 μg/m (F)
3
Max. 24-Hour
Conc. (μg/m3)
Ultra-Fine Particulates (PM-2.5)
Source: South Coast AQMD Air Monitoring Station Data Summaries Anaheim Station (3176)
From these data the following conclusions regarding air quality trends can be drawn:
1. Photochemical smog (ozone) levels occasionally exceed standards. The 1-hour state standard was
violated an average of 7 days a year in the last five years near Anaheim. The federal 8-hour standard
has only been exceeded an average of twice within the last five years. The highest ozone
concentrations were monitored in 2003.
2. PM-10 levels have exceeded the state 24-hour standard on approximately 10 percent of all measurement
days. The three times less stringent federal 24-hour-standard has not been exceeded in the past five
years. Year to year fluctuations of the overall maximum 24-hour PM-10 levels seem to follow no
discernable trend, though the highest PM-10 concentrations were recorded in 2006.
40
3. PM-2.5 readings infrequently exceed the federal 24-hour PM-2.5 ambient standard though the maximum
24-hour concentration appears to be fluctuating. The 24-hour federal PM-2.5 standard has recently
been dramatically lowered. The number of violation days will increase substantially when the new
standard becomes operative in 2007.
4. More localized pollutants such as carbon monoxide, nitrogen oxides, etc. are very low near the project
site because background levels, even in central Orange County, never exceed allowable levels. There is
substantial excess dispersive capacity to accommodate localized vehicular air pollutants such as NOx or
CO without any threat of violating applicable Ambient Air Quality Standards.
Developments, such as the proposed facilities improvement project, do not directly relate to the Air Quality
Management Plan (AQMP) in that there are no specific air quality programs or regulations governing general
development projects. Conformity with adopted plans, forecasts and programs relative to population, housing,
employment and land use is the primary yardstick by which impact significance of master planned growth is
determined. If a given project incorporates any available transportation control measures that can be implemented
on a project-specific basis, and if the scope and phasing of a project are consistent with adopted forecasts as shown in
the Regional Comprehensive Plan (RCP), then the regional air quality impact of project growth would not be
significant because of planning inconsistency. The impacts are less than significant.
b) Less Than Significant Impact. Development, such as the proposed facilities improvement project, do not directly
relate to the AQMP in that there are no specific air quality programs or regulations governing general development
projects. Conformity with adopted plans, forecasts and programs relative to population, housing, employment and
land use is the primary yardstick by which impact significance of master planned growth is determined. If a given
project incorporates any available transportation control measures that can be implemented on a project-specific
basis, and if the scope and phasing of a project are consistent with adopted forecasts as shown in the RCP, then the
regional air quality impact of project growth would not be significant because of planning inconsistency. The impacts
are less than significant.
c) Less Than Significant Impact. Air quality impacts are considered “significant” if they cause clean air
standards to be violated where they are currently met, or if they measurably contribute to an existing violation of
standards. Any substantial emissions of air contaminants for which there is no safe exposure, or nuisance
emissions such as dust or odors, would also be considered a significant impact.
Appendix G of the CEQA Guidelines offers the following five tests of air quality impact significance.
project would have a potentially significant impact if it:
A
a. Conflicts with or obstructs implementation of the applicable air quality plan.
b. Violates any air quality standard or contributes substantially to an existing or projected air quality
violation.
c. Results in a cumulative considerable net increase of any criteria pollutant for which the project region is
non-attainment under an applicable federal or state ambient air quality standard (including releasing
emissions that exceed quantitative thresholds for ozone precursors).
d. Exposes sensitive receptors to substantial pollutant concentrations.
e. Creates objectionable odors affecting a substantial number of people.
Primary Pollutants
Air quality impacts generally occur on two scales of motion. Near an individual source of emissions or a
collection of sources such as a crowded intersection or parking lot, levels of those pollutants that are emitted in
their already unhealthful form will be highest. Carbon monoxide (CO) is an example of such a pollutant.
41
Primary pollutant impacts can generally be evaluated directly in comparison to appropriate clean air standards.
Violations of these standards where they are currently met, or a measurable worsening of an existing or future
violation, would be considered a significant impact. Many particulates, especially fugitive dust emissions, are
also primary pollutants. Because of the non-attainment status of the South Coast Air Basin (SCAB) for PM10, an aggressive dust control program is required to control fugitive dust.
Secondary Pollutants
Many pollutants, however, require time to transform from a more benign form to a more unhealthful
contaminant. Their incremental regional impact is minute on an individual basis and cannot be quantified
except through complex photochemical computer models. Analysis of significance of such emissions is thus
based on a specific amount of emissions (pounds, tons, etc.) even though there is no way to translate those
emissions directly into a corresponding ambient air quality impact. Projects in the SCAB with daily emissions
that exceed any of the following emissions thresholds in Table 3-2 are recommended by the SCAQMD to be
considered significant:
Table 3-2
SCAQMD Emissions Significance Thresholds (lbs/day)
Pollutant
ROG
NOx
CO
PM-10
Sox
PM-2.5
Construction
75
100
550
150
150
55
Operations
55
55
550
150
150
55
Source: SCAQMD CEQA Air Quality Handbook, November, 1993 Rev.
Additional Indicators
In CEQA Handbook, the SCAQMD also states that additional indicators should be used as screening criteria to
determine the need for further analysis with respect to air quality. The additional indicators are as follows:
ƒ
Project could interfere with the attainment of the federal or state ambient air quality standards by either
violating or contributing to an existing or projected air quality violation.
ƒ
Project could result in population increases within the regional statistical area which would be in excess of
that projected in the AQMP and in other than planned locations for the project’s build-out year.
ƒ
Project could generate vehicle trips that cause a CO hot spot.
The SCAQMD CEQA Handbook also identifies various secondary significance criteria related to toxic,
hazardous or odorous air contaminants. Hazardous air contaminants are contained within the small diameter
particulate matter (“PM-2.5”) fraction of diesel exhaust. Such exhaust will be generated by heavy construction
equipment and by diesel-powered trucks using City of Orange streets. However, diesel truck traffic will not be
a factor after the demolition/construction phases of the project.
Construction Activity Impacts
Dust is normally the primary concern during construction of new buildings and infrastructure. Because such
emissions are not amenable to collection and discharge through a controlled source, they are called “fugitive”
emissions. Emission rates vary as a function of many parameters (soil silt, soil moisture, wind speed, area
disturbed, number of vehicles, depth of disturbance or excavation, etc.). These parameters are not known with
any reasonable certainty prior to project development and may change from day-to-day. Any assignment of
specific parameters to an unknown future date is speculative and conjectural.
42
Because of the inherent uncertainty in the predictive factors for estimating fugitive dust generation, regulatory
agencies typically use one universal “default” factor based on the area disturbed, assuming that all other input
parameters into emission rate prediction fall into mid-range average values. This assumption may or may not
necessarily be applicable to site-specific conditions on the proposed substation project site. As noted
previously, emissions estimation for project-specific fugitive dust sources is therefore characterized by a
considerable degree of imprecision.
In the generic dust emissions factor developed by EPA for grading activities, the PM-10 fraction of fugitive dust
emissions are predicted to be around 55 pounds per day per acre disturbed in the absence of any dust control
measures being applied (SCAQMD Handbook, Table 9-2). Mandatory minimum control measures required by
SCAQMD in Rule 403 (Fugitive Dust) are generally assumed to reduce this rate by approximately 50 percent.
Average daily PM-10 emissions during site grading and other disturbance are stated in the SCAQMD Handbook
to be 26.4 pounds/acre. This estimate is based upon required dust control measures in effect in 1993 when the
AQMD CEQA Air Quality Handbook was prepared. Rule 403 was subsequently revised to require use of a
greater array of fugitive dust control on construction projects. Use of reasonably available control measures
(RACMs) for PM-10 such as continual soil wetting, use of supplemental binders, early paving, etc. has been
shown to achieve a substantially higher PM-10 control efficiency (≈10 pounds/acre/day). With the use of best
available control measures (BACMs), daily PM-10 emissions can be reduced to as low as around 2 pounds per
day per acre.
The California Air Resources Board (ARB) URBEMIS2007 computer model predicts that the maximum daily
disturbance “footprint” for the proposed project will be 0.4 acres. The calculated PM-10 emissions with the
application of “standard” dust control, and with the application or reasonably available dust control measures,
are as follows (pounds/day):
Table 3-3
A Comparison of PM-10 Dust Emissions for the Two Dust Control Scenarios
Disturbance Area
0.4 acres
With Standard Dust Control
10.6 pounds/day
With Reasonably Available Control Measures
4.0 pounds/day
Use of RACMs is not required to achieve less-than-significant PM-10 dust emissions. However, because the
airshed is non-attainment for PM-10, and because there are numerous dust-sensitive uses adjacent to the project
site, use of BACMs is recommended. Recommended BACMs for construction activity includes:
Dust Control
ƒ
Apply soil stabilizers to inactive areas.
ƒ
Prepare a high wind dust control plan and implement plan elements and terminate soil disturbance when
winds exceed 25 mph.
ƒ
Limit the simultaneous disturbance area to as small an area as practical.
ƒ
Stabilize previously disturbed areas if subsequent construction is delayed.
ƒ
Water exposed surfaces and haul roads 3 times/day.
ƒ
Cover all stock piles with tarps.
ƒ
Replace ground cover in disturbed areas quickly.
43
ƒ
Reduce speeds on unpaved roads to less than 15 mph.
Exhaust Emissions
ƒ
Require 90-day low-NOx tune-ups for off-road equipment.
ƒ
Limit allowable idling to 5 minutes for trucks and heavy equipment.
Current research in particulate exposure health effects suggest that the most adverse effect derives from ultrasmall diameter particulate matter comprised of chemically reactive pollutants such as sulfates, nitrates or organic
material. A national clean air standard for particulate matter of 2.5 microns or smaller in diameter (called
“PM-2.5”) was adopted in 1997. Very little construction activity particulate matter is in the PM-2.5 range.
Soil dust is also more chemically benign than typical urban atmospheric PM-2.5. The limited amount of PM2.5 within the sub-threshold PM-10 burden further reinforces the finding of a less-than-significant particulate air
quality impact.
In addition to fine particulates that remain suspended in the atmosphere semi-indefinitely, construction activities
generate many larger particles with shorter atmospheric residence times. This dust is comprised mainly of
large diameter inert silicates that are chemically non-reactive and are further readily filtered out by human
breathing passages. These fugitive dust particles are therefore more of a potential soiling nuisance as they
settle out on parked cars, outdoor furniture or landscape foliage rather than any adverse health hazard. With a
high population density around the project site, dust nuisance potential must be minimized by good
housekeeping and enhanced dust control procedures.
Exhaust emissions will result from heavy equipment during grading and during construction. The types and
numbers of equipment will vary among contractors such that these emissions cannot be quantified with
certainty. During various construction activities on the project parcel, the following equipment fleet will likely
be utilized, and has therefore been assumed as a basis for estimating maximum daily equipment exhaust
emissions:
Table 3-4
Construction Equipments
Demolition
1 Concrete Saw
1 Dozer
2 Tractor/Trailer/Backhoe
Grading
1 Grader
1 Tractor/Trailer/Backhoe
1 Water Truck
44
Paving
1 Cement Mixer
1 Paver
1 Roller
Construction
1 Crane
2 Forklift
1 Tractor/Trailer/Backhoe
The resulting exhaust emissions, compared to the SCAQMD CEQA Handbook thresholds, are as follows
(pounds/day):
Table 3-5
Daily Emissions
Activity
Demolition & Grading
Construction & Finish Work
SCAQMD Threshold
ROG
2.0
15.9
75.
CO
8.1
13.9
550.
NOx
15.7
20.6
100.
PM-2.5
1.7
1.4
55.
PM-10
5.0
1.5
150.
C02
1,406.5
2,198.8
-
None of the emissions will exceed the SCAQMD significance thresholds. The mobile nature of the on-site
construction equipment and off-site trucks will also prevent any micro-scale violation of standards. There may
be localized instances when the characteristic diesel exhaust odor is noticeable from passing trucks or nearby
heavy equipment. Truck exhaust impacts can be minimized by controlling construction routes to reduce
interference with non-project traffic patterns and to preclude truck queuing or idling near sensitive receptor sites.
State law requires that any truck waiting to load or unload must turn off its engine if the expected wait is more
than five (5) minutes unless engine power is needed for the activity (such as cement mixer trucks).
Construction equipment exhaust contains carcinogenic compounds within the diesel exhaust particulates. The
toxicity of diesel exhaust is evaluated relative to a 24-hour per day, 365 days per year, 70-year lifetime
exposure. Public exposure to heavy equipment operating will be an extremely small fraction of the above
dosage assumption. Diesel equipment is also becoming progressively “cleaner” in response to air quality rules
on new off-road equipment. Any public health risk associated with project-related heavy equipment operations
exhaust is therefore not quantifiable, but small.
Construction activity air quality impacts occur mainly in proximity to the surface disturbance area. There may,
however, be some “spill-over” into the surrounding community. That spill-over may be physical as vehicles
drop or carry out dirt or silt is washed into public streets. Passing non-project vehicles then pulverize the dirt to
create off-site dust impacts. Spill-over may also occur via congestion effects. Construction may entail
roadway encroachment, detours, lane closures and competition between construction vehicles (trucks and
contractor employee commuting) and ambient traffic for available roadway capacity. Emissions controls
require good housekeeping procedures and a construction traffic management plan that will maintain such
“spill-over” effects at a less-than-significant level.
The SCAQMD has developed analysis parameters to evaluate ambient air quality on a local level in addition to
the more regional emissions-based thresholds of significance. These analysis elements are called Local
Significance Thresholds (LSTs). Use of an LST analysis for a project is optional because they were derived
for economically or socially disadvantaged communities not representative of City of Orange. LSTs are only
applicable to the following criteria pollutants: oxide of nitrogen (NOx), carbon monoxide (CO), and particulate
matter (PM-10 and PM-2.5). LSTs represent the maximum emissions from a project that are not expected to
cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality
standard, and are developed based on the ambient concentrations of that pollutant for each source receptor area
and distance to the nearest sensitive receptor.
URBEMIS predicts the maximum daily school expansion footprint to be 0.4 acres. As shown in Table 3-6,
below, LST pollutant concentration data for a 1-acre site and for a source-receptor distance of 25-50 meters are
seen to be below their LST significance thresholds:
45
Table 3-6
LST Pollutant Concentration Data
Central Orange Count (pounds/day)
LST Threshold
Proposed Project
CO
565
8-14
PM-10
8
1-5
NOx
140
16-21
PM-2.5
4
1-2
Operational Impacts
Operational emissions for project-related traffic were calculated using a computerized procedure developed by
the California Air Resources Board (CARB) for urban growth mobile source emissions. The URBEMIS2007
model was run using the trip generation factors (16 new daily trips) specified by the project traffic consultant,
Austin & Foust Associates. The model was used to calculate area source emissions and the resulting vehicular
operational emissions for an assumed project build-out year of 2009. Please see Table 3-7 for the result.
Table 3-7
Project-Operations Air Pollution Emissions (pounds/day)
Source
Operational (Vehicle) Emission
Estimates
Area Source Emission Estimates*
Total: Operational + Areas
SCAQMD Significance Threshold
Exceeds Threshold (?)
% of Threshold
ROG
0.4
NOx
0.2
CO
1.8
PM-10
0.3
PM-2.5
0.1
CO2
153.8
0.4
0.8
55
No
<1
0.4
0.6
55
No
<1
1.9
3.7
550
No
<1
0.0
0.3
150
No
<1
0.0
0.1
55
No
<1
414.4
568.2
NA
NA
*Energy consumption, landscape maintenance, etc.
Source: URBEMIS2007 Air Quality Model
As shown in Table 3-7 above, the proposed project will not cause the SCAQMD’s recommended threshold
levels to be exceeded. Project-related emission levels for all pollutants analyzed would represent 1 percent or
less of the significance threshold. Therefore, impacts related to operational emissions will be less than
significant.
d) Less Than Significant Impact. The potential sensitive receptors of air pollutants generated by project
construction include the nearby residential land uses as well as the school children and staff attending the site
facilities. Impacts on these sensitive users were discussed in response c), above. Relative to fugitive dust, the
analysis determined that use of BACMs would not be required to achieve a less-than-significant dust (PM-10)
emission rate. However, because of the non-attainment status of the air basin for PM-10, and because of the
proximity of sensitive receptors on campus and at nearby residential uses, use of BACMs shall be implemented
to reduce cumulative impacts from all regional construction and to minimize soiling nuisance potential from
larger dust particles. The impacts are less than significant.
Greenhouse Gas Emissions
“Greenhouse gases” (so called because of their role in trapping heat near the surface of the earth) emitted by
human activity are implicated in global climate change, commonly referred to as “global warming.” These
greenhouse gases contribute to an increase in the temperature of the earth’s atmosphere by transparency to short
wavelength visible sunlight, but near opacity to outgoing terrestrial long wavelength heat radiation. The
principal greenhouse gases (GHGs) are carbon dioxide, methane, nitrous oxide, ozone, and water vapor. Fossil
fuel consumption in the transportation sector (on-road motor vehicles, off-highway mobile sources, and aircraft)
is the single largest source of GHG emissions, accounting for approximately half of GHG emissions globally.
Industrial and commercial sources are the second largest contributors of GHG emissions with about one-fourth
of total emissions.
46
California Assembly Bill 32 (AB32)
The California Global Warming Solutions Act of 2006, also known as Assembly Bill (AB) 32, requires CARB
to adopt regulations to require the reporting and verification of statewide GHG emissions and to monitor and
enforce compliance with this program, as specified. By 2020, the bill requires CARB to reduce the statewide
GHG emissions to the equivalent of those in 1990 (a reduction of approximately 25 percent from forecast
emission levels). CARB is required to adopt regulations for mandatory GHG emissions reporting by January
1, 2008 and to adopt a plan indicating how emissions reductions will be achieved by January 1, 2011, while the
rules and market mechanisms adopted by CARB do not take effect until January 1, 2012. Since the CARB is
still in the rulemaking process for AB32, information about project compliance at the state-level is currently not
available.
In the absence of any adopted thresholds of significance, OPR has issued interim guidance on the role of CEQA
in addressing climate change and GHG emissions (June 19, 2008). The OPR Technical Advisory suggests the
following three steps in a CEQA analysis of GHG:
ƒ
ƒ
ƒ
Quantify/estimate project-related GHG.
Determine whether project-related GHG emissions are cumulatively considerable.
Identify reasonable and feasible mitigation measures that would reduce an identified significant impact.
In addition, City of Orange prepared an Interim Guidance (September 30, 2008) on how to address GHG
emissions and global warming in CEQA documents for which the City of Orange is the lead agency. The
City’s Interim Guidance outlines the following approach in implementing the GHG analysis, until approved
thresholds and guidelines are adopted at the regional or state level:
ƒ
ƒ
ƒ
Identify Greenhouse Gas Emissions from the Project.
Determine Significance.
Incorporate Mitigation Measures.
Implementation of the proposed project would contribute to long-term increases in GHGs as a result of traffic
increases (mobile sources) and minor secondary fuel combustion emissions from space heating, hot water, etc.
Development occurring as a result of the proposed project would also result in secondary operational increases
in GHG emissions as a result of electricity generation to meet project-related increases in energy demand.
Electricity generation in California is mainly from natural gas-fired power plants. However, since California
imports about 20 to 25 percent of its total electricity (mainly from the northwestern and southwestern states),
GHG emissions associated with electricity generation could also occur outside of California. Short-term GHG
emissions will also derive from construction activities. During project construction, the URBEMIS2007
computer model predicts that a peak activity day will generate the following CO2 emissions:
Grading - 1,407 pounds/day
Construction - 2,199 pounds/day
For purposes of analysis, it was assumed that non-CO2 GHG emissions are negligible, and that the total project
construction GHG burden can be characterized by 10 peak grading days and 50 peak construction days. The
estimated annual GHG impact if grading and construction occur all in the same year is as follows:
= (1,407 x 10 + 2,199 x 50) / 2,000 lb / ton
= 62 short tons (56 metric tons)
In 2004, the statewide annual GHG inventory in CO2-equivalent levels (including all non-CO2 gases weighted
by their thermal absorption potential) was 492,000,000 metric tons (541,000,000 short tons). The worst-case
project construction impact represents less than one-millionth of the statewide burden.
47
The proposed project’s operational GHG emissions were calculated using the URBEMIS2007 computer model
to be 568.2 pounds of CO2 per school day. The annual GHG burden, assuming 180 traditional school days and
60 days of non-school activities, would total 68 short tons per year (62 metric tons per year). The statewide
inventory totals 541,000,000 tons per year. The project represents a 0.00001 percent increment. The
magnitude of the project is sufficiently small as to not create a “cumulatively considerable” increase.
The Governor’s Office of Planning and Research (OPR) is in the process of developing CEQA significance
thresholds for GHG emissions but thresholds have yet to be established. Therefore, the City has used best
available information to develop the following threshold: a threshold of 10,000 metric tons per year CO2
equivalent to determine the significance of an individual project’s contribution to the global greenhouse gas
emissions environment. The City selected this threshold because it requires mitigation of large development
projects that have the greatest impacts to global warming and the greatest potential for implementing mitigation
at a broad scale, while also recognizing that small projects (which are most likely infill projects in the City of
Orange) are not likely to contribute “cumulatively considerable” emissions quantities and are not the focus of
future substantial GHG reductions. In addition, based on a comparative analysis of this threshold, it is similar
to the scale of emissions that would trigger exceedance of SCAQMD thresholds for regulated criteria pollutants
(e.g., NOx, VOC, CO, PM), and therefore, appears to be reasonable and appropriate. As stated previously, the
proposed project GHG emissions would generate 68 short tons per year (62 metric tons per year), which is
below the threshold used by the City.
GHG emissions are implicated in the acceleration of global warming experienced in the last several decades.
Climatic impacts are global in scale. Any project-specific contribution to the global issue is miniscule.
Despite the project’s small contribution and globe nature of the issue, the GHG emphasis on a project-specific
level is to incorporate project design features that reduce energy consumption and reduce vehicular travel as
much as is reasonably feasible. Carbon sequestering by trees and landscaping has been suggested to off-set
GHG emissions. However, a single home contributes more carbon than a single mature tree can lock up in a
year. Unless there is a greater shift to clean energy such as solar, hydroelectric, wind, nuclear, etc., no
substantial reduction in GHG is likely attainable by conventional methods except through energy conservation.
Consequently, the project contributes to energy conservation through utilization of energy-star mechanical
equipment and compliance with Title 24, Energy Efficiency and Standards for Residential and Nonresidential
Buildings 1.
Although the project does not result in a “cumulative considerable” increase”, because of the cumulative nature
of GHG impacts, emissions reduction design features are nevertheless recommended for the project.
Recommendations to minimize the project carbon footprint include:
3-1
Enhanced campus replacement landscaping shall be utilized to provide shade and carbon storage.
3-2
Demolition debris from site clearing shall be recycled as much as possible.
3-3
The use of fluorescent indoor and low-pressure sodium outdoor lighting shall be maximized.
3-4
Energy Star-rated appliances and HVAC equipment shall be used.
e) Less Than Significant Impact. During construction, certain operations such as laying asphalt pavement,
applying paint/protective coatings, and applying some roofing materials, generate odors that would be
noticeable to nearby residents/landowners. Such odors are not unusual in residential areas and last only for a
few days. Though noticeable, such odors do not result in significant nuisance or health risk. Facility
1
California Energy Commission website: http://www.energy.ca.gov/title24/.
48
operations would not involve any activities, materials, or chemicals that would have the potential to cause odor
impact affecting a substantial number of people. The impacts are less than significant.
4.
(a)
(b)
(c)
(d)
(e)
(f)
BIOLOGICAL RESOURCES.
Potentially
Significant
Impact
Would the project:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Have a substantial adverse effect, either directly or through habitat
modifications, on any species identified as a candidate, sensitive, or special
status species in local or regional plans, policies, or regulations, or by the
California Department of Fish and Game or U.S. Fish and Wildlife Service?
Have a substantial adverse effect on any riparian habitat or other sensitive
natural community identified in local or regional plans, policies, regulations
or by the California Department of Fish and Game or U.S. Fish and Wildlife
Service?
Have a substantial adverse effect on federally protected wetlands as defined
by Section 404 of the Clean Water Act (including, but not limited to, marsh,
vernal pool, coastal, etc.) through direct removal, filling, hydrological
interruption, or other means?
Interfere substantially with the movement of any native resident or
migratory fish or wildlife species or with established native resident or
migratory wildlife corridors, or impede the use of native wildlife nursery
sites?
Conflict with any local policies or ordinances protecting biological
resources, such as a tree preservation policy or ordinance?
Conflict with the provisions of an adopted Habitat Conservation Plan,
Natural Community Conservation Plan, or other approved local, regional, or
state habitat conservation plan?
Reference: 6 & 7
Impact Analysis:
a) No Impact. The properties within the vicinity of the proposed project include previously developed sites
within urbanized City of Orange. The surrounding area is predominantly residential uses. There are no
wildlife habitats for state and federal sensitive species in these areas (Figure VI-4, Wildlife Habitat Areas –
Generalized, Orange County General Plan, 2005). No impacts would occur.
b) No Impact. The project site is paved with surface parking lots and building structures, and it does not contain
any riparian habitat or any sensitive natural communities. Also, the project site is not identified in any adopted
regional habitat conservation plan. No adopted California Department of Fish and Game or U.S. Fish and
Wildlife Service Habitat Conservation Plan (HCP), Natural Community Conservation Plans (NCCP), or other
approved state or federal habitat conservation plans apply to the project site. Therefore, the project would not
have a substantial adverse effect on any identified riparian habitat or sensitive natural community. No impacts
would occur.
c) No Impact. The project site is fully developed with a school and associated facilities, and no natural
hydrologic features or federally protected wetlands as defined by Section 404 of the Clean Water Act occur onsite or in the project vicinity. Therefore, no direct removal, filling, or hydrological interruption of a wetland
area would occur with development of the project site. No impacts would occur.
d) No Impact. No portion of the project site or immediately surrounding areas contains an open body of water
that serves as natural habitat for fish. There is no established native resident or migratory wildlife corridor
existing within or adjacent to the project site (Figure VI-4, Wildlife Habitat Areas – Generalized, Orange
County General Plan, 2005). Thus, the implementation of the proposed project would not impact movement of
any native resident or migratory fish or wildlife species or any established native resident or migratory wildlife
corridors, nor would the project impede the use of native wildlife nursery sites. No impacts would occur.
49
e) Less Than Significant Impact. The Landscape Plan (Figure 11) shows the location of existing planting to
remain and new plantings to be planted. Based on the Landscape Plan, 28 trees will be removed, 60 trees will
be replaced, and 11 trees will be retained and preserved. All trees removed will be replaced with a larger
circumference than those removed. According to Chapter 12.32 of the City’s Tree Preservation Ordinance,
removal of mature trees whose trunks are greater than 10.5 inches in circumference; 24 inches above the ground
requires a permit. Some of the trees to be removed from the project site do meet these criteria, and therefore,
removal of these trees is subject to issuance of a tree removal permit. Upon approval and issuance of the
permit, the project would not conflict with any local polices or ordinances protecting biological resources. In
addition, there are no biologically sensitive areas within or in vicinity of the project area. Also, the proposed
landscape will conform to the City requirements. The impact would be less than significant.
f) No Impact. The proposed project is not within an established HCP, NCCP, or other habitat planning area.
No impacts would occur.
5.
(a)
(b)
(c)
(d)
CULTURAL RESOURCES.
Potentially
Significant
Impact
Would the project:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Cause a substantial adverse change in the significance of a historical
resource as defined in §15064.5?
Cause a substantial adverse change in the significance of an archaeological
resource pursuant to §15064.5?
Directly or indirectly destroy a unique paleontological resource or site or
unique geologic feature?
Disturb any human remains, including those interred outside of formal
cemeteries?
Reference: 6, 7, & 9
Impact Analysis:
a) No Impact. The project site has been previously graded and currently developed with a high school. The
proposed project area is not located within any historic district, and the structures proposed to be demolished are
not of any historic significance. No impacts to historic resources would occur.
b) No Impact. According to the City of Orange General Plan and the County of Orange General Plan, there are
no known archaeological resources on the proposed project site or in the vicinity of the site (Figure VI-10,
Prehistoric Archeology – General Areas of Sensitivity, Orange County General Plan 2005). The proposed
project would not impact any archaeological resources, as the soil has already been graded. If any
archeological resources are discovered during grading and construction activities, work in the area would cease
and deposits would be treated in accordance with Federal, State, and local guidelines including those set forth in
California Public Resources Code Section 21083.2. In addition, if it is determined that an archaeological site is
a historical resource, the provisions of Section 21084.1 of the Public Resources Code and CEQA Guidelines
Section 15064.5 would be implemented. No impacts would occur.
c) No Impact. The City of Orange General Plan recommends paleontological surveys prior to a proposed
development where the project site is located in an area known or suspected to contain such resources. The
General Plan also indicates that the undeveloped areas in the eastern portion of the City are likely to contain
such resources. However, according to the Orange County General Plan (Figure VI-9, Paleontology – General
areas of Sensitivity), no known paleontological resources have been identified on the proposed project site or in
the vicinity of the site. In addition, given that the project is not located within such area, and that the area
surrounding the project site is completely developed with residential uses, there is a low probability of
encountering significant paleontological resources. Therefore, project implementation would not result in any
impacts related to paleontological resources. Nevertheless, if any paleontological resources are discovered
50
during grading and construction activities, appropriate measures will be taken to divert construction activities
away from any potential resources. In addition, the found deposits would be treated in accordance with
Federal, State, and local guidelines including those set forth in California Public Resources Code Section
21083.2. Therefore, project implementation would not significantly affect paleontological resources. No
impacts would occur.
d) No Impact. For reasons stated in b) and c) above, encountering human remains during project construction is
unlikely to result within a site that is already graded and developed. In the event that any human remains or
related resources are discovered, such resources would be treated in accordance with Federal, State, and local
regulations and guidelines for disclosure, recovery, relocation, and preservation, as appropriate, including
CEQA Guidelines Section 15064.5(e). No impacts would occur.
6.
GEOLOGY AND SOILS.
Potentially
Significant
Impact
Would the project:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a)
Expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning Map issued by the State
Geologist for the area or based on other substantial evidence of a
known fault? Refer to Division of Mines and Geology Special
Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including liquefaction?
iv) Landslides?
(b)
Result in substantial soil erosion or the loss of topsoil?
(c)
Be located on a geologic unit or soil that is unstable, or that would become
unstable as a result of the project, and potentially result in on- or off-site
landslide, lateral spreading, subsidence, liquefaction or collapse?
(d)
Be located on expansive soil, as defined in Table 18-1-B of the Uniform
Building Code (1994), creating substantial risks to life or property?
(e)
Have soils incapable of adequately supporting the use of septic tanks or
alternative waste water disposal systems where sewers are not available for
the disposal of waste water?
Reference: 6 & 7
Impact Analysis:
a) i) Less Than Significant Impact. According to the City General Plan, the project site is located within a
seismically active region that has been subject to major earthquakes in the past. The San Andreas Fault,
Whittier-Elsinore Fault, Newport-Inglewood Fault and San Jacinto Fault are active faults located within 30
miles of Orange. Other major faults may be buried under alluvium, or fault traces may have been obliterated
due to natural weathering. A number of smaller fault traces are located in the northern and eastern portions of
the City. Local faults, the El Modena Fault and Peralta Hills Thrust Fault, are not considered capable of
producing major earthquakes. There is a debate on whether or not the El Modena Fault is even an active fault.
Nonetheless, movement along either of these faults or the numerous fracture planes in the hills in the eastern
portion of the City could result in surface rupture and/or ground displacement. Structures built on or near the
faults could sustain damage as a result of such movement. However, implementation of seismic design criteria
within the current 2007 California Building Code (CBC), with any appropriate updates applicable at the time of
plans submittal to the City, would be sufficient to avoid significant impacts due to seismic events. The
potential impacts of known earthquake fault would be less than significant.
a) ii) Less Than Significant Impact. The project site is located in the seismically active region of southern
California; therefore, there is potential to expose people or structures to seismic ground shaking. However, this
51
hazard is common in southern California, and the effects of ground shaking can be lessened through
implementation of seismic design standards within the current CBC. The mandated incorporation of these
design standards ensures that potential impacts of seismic ground shaking would be less than significant.
a) iii) No Impact. Liquefaction hazards exist in two areas of the City – at the Villa Park Reservoirs, and along
the Santa Ana River. In the Santiago Hills II and East Orange planning area, liquefaction may occur in sitedrainage areas that contain loose, sandy soils or alluvial deposits. However, based on the City General Plan
Figure S-4, Composite Map of Environmental Hazards, the project site is not within areas subject to
liquefaction. No impacts would occur.
a) iv) No Impact. The City General Plan refers landslides, mudslides, rockfalls and soil creep as “mass
wasting.” According to the City General Plan Figure S-4, Composite Map of Environmental Hazards, the
project site is not within areas subject to mass wasting hazards. No impacts would occur.
b) Less Than Significant Impact. As the project would include demolition, grading, excavation, and other
improvements, as necessary, the potential exists for short-term soil erosion during such activities. However,
this is not considered a potentially significant impact given the project will comply with local NPDES
regulations and water quality management plan pursuant to California Regional Water Quality Control Board
requirements has been prepared. The water quality report includes erosion control Best Management Practices
(BMPs), sediment control measures, non-storm water management BMPs, and site design and routine nonstructural BMPs (refer to the preliminary Water Quality Management Plan in Appendix A of this MND).
Additionally, grading plan will be in compliance with City conditions and subject to review and approval by the
City engineer to further avoid the potential impacts. Therefore, with incorporation of the BMPs, grading
techniques, and City standard conditions, the impacts would be less than significant.
c) No Impact. The project site is currently developed with a high school campus and related uses. Based on
the City of Orange General Plan, the project site is not associated with a geologic unit or soil type that is
unstable. The project was previously graded in accordance with previous permits and approvals and thus complied
with all applicable State and County building and safety guidelines, restrictions, and permit requirements. No
impacts would occur.
d) No Impact. No potential impact related to expansive soil has been identified. The project was previously
graded in accordance with previous permits and approvals and thus complied with all applicable State and County
building and safety guidelines, restrictions, and permit requirements. No impacts would occur.
e) No Impact. The proposed project would not involve the use of septic tanks to handle its wastewater
generation; therefore, no adverse impact relative to use of septic tanks would occur. No impacts would occur.
52
7.
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)
HAZARDS AND HAZARDOUS MATERIALS.
Would the project:
Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Create a significant hazard to the public or the environment through the
routine transport, use or disposal of hazardous materials?
Create a significant hazard to the public or the environment through
reasonable foreseeable upset and accident conditions involving the release
of hazardous materials into the environment?
Emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within one-quarter mile of an existing or
proposed school?
Be located on a site which is included on a list of hazardous materials sites
complied pursuant to Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?
For a project located within an airport land use plan or, where such a plan
has not been adopted, within two miles of a public airport or public use
airport, would the project result in a safety hazard for people residing or
working in the project area?
For a project within the vicinity of a private airstrip, would the project result
in a safety hazard for people residing or working in the project area?
Impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan?
Expose people or structures to a significant risk of loss, injury or death
involving wildland fires, including where wildlands are adjacent to
urbanized areas or where residences are intermixed with wildlands?
Reference: 6 & 7
Impact Analysis:
a) Less Than Significant Impact. Hazardous materials are chemicals that could potentially cause harm during
an accidental release or mishap, and they are defined as being toxic, corrosive, flammable, reactive, an irritant or
strong sensitizer. Hazardous substances include all chemicals regulated under the United States Department of
Transportation “hazardous materials” regulations and the Environmental Protection Agency “hazardous waste”
regulations. Hazardous wastes require special handling and disposal because of their potential to damage public
health and the environment. The probable frequency and severity of consequences from the use, transport, or
disposal of hazardous materials is affected by the type of substance, quantity used or managed, and the nature of
the activities and operations.
The project will include demolition of the existing tennis courts and temporary parking area. The proposed
project will involve the transport, use, or disposal of relatively small quantities of routinely-used but potentially
hazardous materials during construction and operation activities. During the construction phase, these
potentially hazardous materials may include vehicle fuels, oils, and transmission fluids. Operation of residential
and commercial uses such as those proposed typically involve the use and storage of small quantities of
potentially hazardous materials in the form of cleaning solvents and pesticides for landscaping. However, such
materials would be contained, stored, and used in accordance with manufacturers’ instructions and handled in
compliance with applicable standards and regulations. Any associated risk would be adequately reduced to a less
than significant level through compliance with these standards and regulations. Thus, construction and operation
of the project would not create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials. Impacts are considered less than significant.
b) No Impact. As the proposed project would not involve the use of acutely hazardous materials or waste, and
the limited use of any hazardous materials would be in accordance with manufactures’ instructions and handled
in compliance with applicable standards and regulations, as discussed in Section a), above. The proposed project
would not create a significant hazard to the public or the environment through reasonably foreseeable upset and
53
accident conditions involving the release of hazardous materials into the environment. The project involves
expansion of an existing high school. The high school does not and would not use or store significant amounts
of hazardous materials on the premises. No impacts would occur.
c) Less Than Significant Impact. As discussed under (a) and (b) above, construction or operation of the project
would not generate acutely hazardous materials or wastes, and the limited use of any hazardous materials would
be in accordance with manufactures’ instructions and handled in compliance with applicable standards and
regulations. If asbestos or lead is identified within existing structures, it will be managed in accordance with
California Occupational Safety and Health Administration and South Coast Air Quality Management District
regulations. The impact of the project in relation to hazardous emissions or handling of acutely hazardous
materials within one-quarter mile of a school would be less than significant.
d) No Impact. The project site is not on the list of hazardous material sites compiled pursuant to Government
Code Section 65962.5 and would not result in adverse impacts. The site has been occupied as a high school.
No impacts related hazardous materials have been identified. No impacts would occur.
e) No Impact. There are no airports within two miles of the site, nor is the project located within airport land
use plan boundaries. Therefore, no impacts regarding airport safety hazards would occur.
f) No Impact. There are no airports within two miles of the site, nor is the project located within airport land use
plan boundaries. The project site is not located within the vicinity of a private airstrip; therefore, no impacts
regarding airport safety hazards would occur.
g) No Impact. The City’s emergency response plan indicates that Chapman Avenue and Glassell Street are
primary evacuation routes in the City. The proposed project site does not border these routes; therefore, it
would not disrupt or impair use of the street or other evacuation routes. No impacts would occur.
h) No Impact. The proposed project site is located in an established urban area of Orange where the risk of loss
or injury from wildland fires is extremely low. Also, the proposed project would not include any activities that
would expose people or structures to a significant risk of loss, injury, or death involving wildland fires. No
impacts would occur.
8.
(a)
(b)
(c)
(d)
(e)
(f)
HYDROLOGY AND WATER QUALITY.
Would the project:
Violate any water quality standards or waste discharge requirements?
Substantially deplete groundwater supplies or interfere substantially with
groundwater recharge such that there would be a net deficit in aquifer
volume or a lowering of the local groundwater table level (e.g., the
production rate of pre-existing nearby wells would drop to a level which
would not support existing land uses or planned uses for which permits have
been granted)?
Substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river, in a manner which
would result in a substantial erosion or siltation on- or off-site.
Substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river, or substantially
increase the rate or amount of surface runoff in a manner which would result
in flooding on- or off-site?
Create or contribute runoff water which would exceed the capacity of
existing or planned storm water drainage systems or provide substantial
additional sources of polluted runoff?
Otherwise substantially degrade water quality?
54
Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(g)
(h)
(i)
(j)
(k)
(l)
(m)
(n)
(o)
(p)
Place housing within a 100-year flood hazard area as mapped on a federal
Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard
delineation map?
Place within a 100-year flood hazard area structures which would impede or
redirect flood flows?
Expose people or structures to a significant risk of loss, injury or death
involving flooding, including flooding as a result of the failure of a levee or
dam?
Inundation by seiche, tsunami, or mudflow?
Potentially impact stormwater runoff from construction activities?
Potentially impact stormwater runoff from post-construction activities?
Result in a potential for discharge of stormwater pollutants from areas of
material storage, vehicle or equipment fueling, vehicle or equipment
maintenance (including washing), waste handling, hazardous materials
handling or storage, delivery areas, loading docks or other outdoor work
areas?
Result in the potential for discharge of stormwater to affect the beneficial
uses of the receiving waters?
Create the potential for significant changes in the flow velocity or volume of
stormwater runoff to cause environmental harm?
Create significant increases in erosion of the project site or surrounding
areas?
Reference: 2, 6, 7, & 10
Impact Analysis:
a) Less Than Significant Impact. Surface water quality may be adversely affected by pollutants originating
from storm water and urban runoff (non-point sources) during construction and operation of the project. To
prevent potentially contaminated runoff from reaching downstream waters during construction, adequate water
quality treatment would be applied in accordance with the Regional Water Quality Control Board (RWQCB)
regulations for the proposed project. Construction pollutants are typically associated with exposed soil and
cement-mixing, sandblasting or hard surface cutting activities, paint removal and preparation, equipment fluids,
and general construction waste. However, project construction would comply with State Water Resources
Control Boards’ (SWRCB) National Pollutant Discharge Elimination System (NPDES) General Construction
Permit, which requires development of and compliance with a Stormwater Pollution Prevention Plan (SWPPP)
for projects of 1-acre or more in size. The SWPPP would describe Best Management Practices (BMPs)
meeting the Best Available Technology (BAT/BCT) standards required by the Construction Permit and that
address pollutant source reduction and will ensure that water quality standards are not exceeded in downstream
receiving waters due to construction activities. Implementation of the appropriate BMPs per the SWPPP will
result in less than significant impacts to surface water quality and groundwater quality during the construction
phase.
Potential stormwater pollutants associated with this proposed project include bacteria/virus, heavy metals,
nutrients, pesticides, organic compounds, sediments, trash and debris, oxygen demanding substances, and oil
and grease. Additional BMPs would be designed and installed for the operational phase of the project to
comply with the NPDES Municipal Permit and Chapter 7.01 Water Quality and Stormwater Discharges of the
City’s Municipal Code to reduce the discharge of polluted runoff from the site. The preliminary Water Quality
Management Plan (WQMP) includes proposed source control and routine non-structural BMPs that will be
implemented on-site to reduce pollutant loads in storm water runoff. Measures are taken from the Countywide Drainage Area Management Plan (DAMP) and from NPDES program requirements. The main treatment
control BMPs for this project site are porous pavement detention, which will utilize the pervious paving in the
sidewalk areas; and proprietary control measures, which will use Filterra Bio-Retention units. These BMPs
will ensure that the beneficial uses for the downstream receiving waters are not impacted. The pervious
concrete would serve to combat pollutants (removal efficiency) generated by the project such as heavy metals,
55
nutrients, pesticides, organic compounds, sediments, trash and debris, oxygen demanding substances, and oil
and grease for the northern portion of the project site. More detailed discussions of the proposed BMPs are
included in Appendix B of this document. Operational BMPS, would consist of site perimeter sandbags, a
stabilized construction entrance and storm drain inlet protection per the California Stormwater BMP Handbook
for Construction. Two Filterra Units will be used to combat pollutants generated by the project per the
following: TSS removal (82%), phosphorus removal (73%), nitrogen removal (43%), heavy metal removal
(33% - 82%); fecal coliform (57% - 76%), and predicated oil and grease (>85%). In addition, operation-phase
BMPs may include screened or walled trash container areas, stenciling of on-site storm drain inlets, covered,
properly drained loading dock areas, and infiltration and treatment systems in parking areas to prevent pollutant
runoff. The final selection of BMPs would be completed through coordination with the City of Orange. Thus,
the proposed project would not contribute or be subject to high erosion or debris deposition from runoff. The
impacts related to water quality would be less than significant.
b) No Impact. The proposed project would not result in significant increase in the total area of impervious
surfaces. According to the draft preliminary WQMP, the existing pervious surface on site is 18,200 square feet
and the proposed pervious surface after the project would be 17,050 square feet. Both pre- and post-project
pervious areas are 15 percent and therefore, both give a percentage of impermeable surface of approximately 85
percent (see Appendix B). In addition, there are no existing or proposed groundwater wells or pumping
activities on the project site. In addition, the proposed project would not affect the groundwater levels by use of
irrigation water or substantial potable use. Therefore, no impacts to groundwater recharge and groundwater
supplies from the project would occur.
c) Less Than Significant Impact. The existing drainage pattern sheet flows to the west of the outdoor tennis
courts into several catch basins, which eventually empties into the public storm drain system toward Buckeye
Flood Control Channel. Buckeye Channel continues south and joins with Collins Channel where it discharges
into Reach 2 of the Santa Ana River in the City of Orange. The project site is developed with mostly
impervious surfaces associated with buildings and paved areas. There are no streams or rivers on the project
site or within close proximity. Project construction would comply with all applicable NPDES General
Construction Permit and City requirements including development, approval, and implementation of a SWPPP
to prevent erosion or siltation on- or off-site during construction. Likewise, operation of the proposed project
would include the design or installation of additional BMP’s to comply with the NPDES Municipal Permit and
the City of Orange’s stormwater ordinance to reduce the discharge of polluted runoff from the site. As such,
the existing drainage pattern of the site would be maintained and impacts associated with erosion or siltation onor off-site would be less than significant.
d) Less Than Significant Impact. There are no streams or rivers on the project site or within the proximity. The
proposed project will maintain the existing drainage pattern of the site. The runoff will drain towards a
proposed catch basin to be added near the northwest corner of the proposed parking lot. However, this catch
basin will serve as an overflow for two Filterra Bio-Retention Units, one on either side of the catch basin, which
will collect and treat runoff from the proposed project. Project construction would comply with all applicable
NPDES General Construction Permit and City requirements including development, approval, and
implementation of a SWPPP to prevent erosion or siltation on- or off-site during construction. Likewise,
operation of the proposed project would include the design or installation of additional BMP’s to comply with
the NPDES Municipal Permit and the City of Orange’s stormwater ordinance to reduce the discharge of polluted
runoff from the site.
Hydrologic calculations to evaluate surface water runoff associated with 10-year storm frequency were
performed for the on-site drainage in accordance with the Orange County Hydrology Manual. Results of the
existing and proposed conditions hydrology analysis are summarized in Table 8-1, below.
56
Table 8-1
Runoff Calculations
Existing
Proposed
Drainage
Area
(acres)
2.7
2.7
T
A
B
I
ai
ap
Fp
C
Fm
Q
(cfs)
10
12
10.209
10.209
-0.573
-0.573
2.73
2.46
0.85
0.85
0.15
0.15
0.3
0.3
0.80
0.80
0.045
0.045
6.52
5.86
Source: Orange County Hydrology Manual
Under existing conditions, there is approximately 6.52 cubic per second (cfs) of runoff from a 10-year storm
event from the project site. The existing drainage pattern sheet flows to the west of the outdoor tennis courts
into several catch basins.
Under the post-development conditions, there is approximately 5.86 cfs of runoff from a 10-year storm event
from the project site. This is a decrease of 0.66 cfs as compared to existing conditions. This incremental
decrease is due to an increase in the time of concentration for the proposed drainage relative to the existing.
The runoff associated with the proposed project will consist mostly of building and parking lot drainage which
will be treated prior to entering the public storm drain system. The proposed project will maintain the existing
drainage pattern. The runoff will drain towards a proposed catch basin to be added near the northwest corner
of the proposed parking lot. However, this catch basin will serve as an overflow for two Filterra Bio-Retention
Units, one on either side of the catch basin, which will collect and treat runoff from the proposed project. The
proposed project would not result in any additional impervious surface or additional runoff. As such, there is
no potential for increased flooding on- or off-site due to the project. The impact would be less than significant.
e) Less Than Significant Impact. The existing drainage pattern sheet flows to the west of the outdoor tennis
courts into several catch basins, which eventually empty into the public storm drain system toward Buckeye
Flood Control Channel. Buckeye Channel continues south and joins with Collins Channel where it discharges
into Reach 2 of the Santa Ana River in the City of Orange. The proposed project will maintain the existing
drainage pattern. The impact would be less than significant.
Additionally, as shown in Table 8-1 above, the existing site generates 6.52 cfs for the 1-year storm event, while
the proposed site will generate 5.86 cfs from the 10-year storm event. Therefore, the project does not produce
any additional runoff to the surrounding area meeting the requirement to maintain pre-development runoff
conditions.
f) Less Than Significant Impact. As discussed above, in Section a), the proposed project would comply with
applicable NPDES and City requirements, which would include the use of BMPs during construction and
operation of the project as detailed in a SWPPP and WQMP. Compliance with these requirements would
ensure that construction and operation of the project would not degrade water quality. The impacts would be
less than significant.
g) No Impact. The project site is not located within a flood hazard zone. According to Federal Emergency
Management Agency (FEMA), the site is located in Zone X which is the area outside of the 100-year and 500year floodplain. Therefore, no impacts would occur.
h) No Impact. The proposed project will not be located within the 100-year flood zone and therefore, the flood
water will not be impeded or redirected. No impacts would occur.
i) No Impact. As stated above, the project site is not located within a FEMA or City of Orange designated 100year flood plain. According to the City of Orange General Plan, there are four facilities that have the potential
to flood several areas of the City: Prado Dam, Villa Park Dam and Santiago Dam impound, Villa Park Reservoir
57
and Irvine Lake, and Olive Hills Reservoir 2. However, there are ongoing efforts by the Army Corps of
Engineers to improve the Prado facility, and therefore, the risk of dam failure is vey low. Like Prado Dam,
Villa Park Dam and Santiago Dam impound and Villa Park Reservoir and Irvine Lake are maintained and
safety-inspected to ensure that risks are minimized. Oliver Hills Reservoir is a water tank which sits on a
hilltop in Anaheim above residential development in Orange. Reservoir failure would result in the flooding of
canyons and residential tracts below the reservoir. The project site is not located within the residential tracts
below the reservoir, and therefore, would not be affected in the case on the reservoir failure. Therefore, the
location of the project would not expose people or structures to a significant risk of loss, injury or death
involving flooding. Therefore, no impact would occur.
j) No Impact. The project site is not in a coastal area or downslope of any large water bodies that could
adversely affect the project site in the event of earthquake-induced seiches (wave oscillations in an enclosed or
semi-enclosed water body). Additionally, the project site is not located in a coastal area; therefore, tsunamis
(seismic sea waves) are not considered a significant hazard at the project site. Therefore, the proposed project
would not result in inundation by seiche, tsunami, or mudflow. No impact would occur.
k) Less Than Significant Impact. Construction of the proposed project could potentially result in nuisance and
storm water runoff. However, as discussed in Item a) above, project construction would comply with SWRCB’s
NPDES General Construction Permit and would develop and comply with a SWPPP. The SWPPP will contain
BMPs proposed to minimize the impacts of construction, such as street sweeping and vacuuming, sandbag
barriers, storm drain inlet protection, stabilized construction entrance, waste management and education
materials to eliminate construction debris from entering the storm drain. The proposed project would also
comply with Chapter 16.40 Grading Requirements of the City’s Municipal Code to control the quality of
drainage and runoff during construction. The impact would be less than significant.
l) Less Than Significant Impact. As stated in Item a) above, BMPs would be designed and installed for the
operational phase of the project to comply with the NPDES Municipal Permit and Chapter 7.01 Water Quality
and Stormwater Discharges of the City’s Municipal Code to reduce the discharge of polluted runoff from the
site. Potential stormwater pollutants associated with the operation of the proposed project include
bacteria/virus, heavy metals, nutrients, pesticides, organic compounds, sediments, trash and debris, oxygen
demanding substances, and oil and grease. The draft preliminary WQMP includes proposed source control and
routine non-structural BMPs that will be implemented on-site to reduce pollutant loads in storm water runoff.
Measures are taken from the County-wide DAMP and from NPDES program requirements. The main
treatment control BMPs for this project site are porous pavement detention, which will utilize the pervious
paving in the sidewalk areas; and proprietary control measures, which will use Filterra Bio-Retention units.
These BMPs will ensure that the beneficial uses for the downstream receiving waters are not impacted. The
pervious concrete would serve to combat pollutants (removal efficiency) generated by the project such as heavy
metals, nutrients, pesticides, organic compounds, sediments, trash and debris, oxygen demanding substances,
and oil and grease for the northern portion of the project site. Two Filterra Units will be used to combat
pollutants generated by the project per the following: TSS removal (82%), phosphorus removal (73%), nitrogen
removal (43%), heavy metal removal (33% - 82%); fecal coliform (57% - 76%), and predicated oil and grease
(>85%). In addition, operation-phase BMPs may include screened or walled trash container areas, stenciling of
on-site storm drain inlets, covered, properly drained loading dock areas, and infiltration and treatment systems in
parking areas to prevent pollutant runoff. The final selection of BMPs would be completed through
coordination with the City of Orange. The implementation and compliance with the proposed BMPs would
reduce the impacts to less than significant.
m) Less Than Significant Impact. The proposed project would not result in any discharge of stormwater
pollutants from any outdoor work areas, such as vehicle fueling and maintenance, waste handling, hazardous
materials handling, and loading docks, as none exists within the project area. And none will exist as a result of
2
City of Orange General Plan, Safety Element, December 2005.
58
the proposed project. Construction of the proposed project would involve the use of potentially hazardous
materials such as vehicle fuels, oils, paints, and transmission fluids typically associated with construction.
Operation of the school would involve the use of small quantities of potentially hazardous materials typical of
those used at schools (i.e., oil and gasoline, cleaning solvents, pesticides for landscaping, etc.) and stored onsite. In addition, there are existing chemistry labs at the school where the minimal amount of chemicals are used
as part of the instruction process. According to the WQMP, the school will ensure compliance with all County
ordinances for hazardous materials disclosure enforced by the Orange County Environmental Health
Department of the Fire Department in the City of Orange. The school must maintain a hazardous materials
inventory list, as necessary, which details the composition and location of such materials. These labs have
been inspected each school year by the Orange County’s hazardous waste specialist. The most recent
inspection report of the chemistry labs is attached at the end of this document (see Appendix C). Additionally,
the proposed project would not introduce new materials to the project site. All hazardous materials used during
construction and operation would be contained, stored, and used in accordance with applicable regulations and
handled in accordance with manufacturer’s specifications. Therefore, risks associated with the use of these
materials would be reduced to less than significant levels.
n) Less Than Significant Impact. As stated in Section e), the project site currently generates 6.52 cubic foot
per second (cfs) for the 10-year storm event, while the proposed site will generate 5.86 cfs from the 10-year
storm event. The proposed project involves building new facilities, changing the existing temporary parking
lot into an outdoor sport court, and changing the existing tennis courts into a parking lot. Since the proposed
project would be built on an impervious surface, it would not result in an incremental increase in impervious
surface and therefore, would not affect the beneficial uses of the receiving water (Reach 2 – Lower Santa Ana
River). The following lists the proposed project’s beneficial uses for Reach 2 – Lower Santa Ana River 3:
ƒ
Agricultural Supply waters are used for farming, horticulture or ranching. These uses may include, but are
not limited to, irrigation, stock watering, and support of vegetation for range grazing.
ƒ
Groundwater Recharge waters are used for natural or artificial recharge of groundwater for purposes that
may include, but are not limited to, future extraction, maintaining water quality or halting saltwater intrusion
into freshwater aquifers.
ƒ
Water Contact Recreation waters are used for recreational activities involving body contact with water where
ingestion of water is reasonably possible. These uses may include, but are not limited to, swimming,
wading, water-skiing, skin and scuba diving, surfing, whitewater activities, fishing, and use of natural hot
springs.
ƒ
Non-contact Water Recreation waters are used for recreational activities involving proximity to water, but
not normally involving body contact with water where ingestion of water would be reasonably possible.
These uses may include, but are not limited, picnicking sunbathing, hiking, beachcombing, camping, boating,
tidepool and marine life study, hunting, sightseeing, and aesthetic enjoyment in conjunction with the above
activities.
ƒ
Warm Freshwater Habitat waters support warm water ecosystems that may include, but are not limited to,
preservation and enhancement of aquatic habitats, vegetation, fish, and wildlife, including invertebrates.
ƒ
Wildlife Habitat waters support wildlife habitats that may include, but are not limited to, the preservation and
enhancement of vegetation and prey species used by waterfowl and other wildlife.
3
These Beneficial Use Designations are created by the California Regional Water Quality Control Board and they
describe what a specific body of water is used for or could potentially be used for.
59
ƒ
Rare, Threatened or Endangered Species waters support habitats necessary for the survival and successful
maintenance of plant or animal species designated under state or federal law as rare, threatened or
endangered.
Due to the nature of this project, the main BMPs for this site are pervious sidewalks and Filterra Bio-Retention
Units. These BMPs will ensure that the beneficial uses for the downstream receiving waters are not impacted.
The pervious concrete serves to combat pollutants (removal efficiency) generated by the project such as heavy
metals, nutrients, pesticides, organic compounds, sediments, trash and debris, oxygen demanding substances,
and oil and grease for the northern portion of the site. Also, two Filterra Units will be used to combat
pollutants generated by the project per the following: TSS removal, phosphorus removal, nitrogen removal,
heavy metal removal, fecal coliform, and predicated oil and grease. In addition, with adherence to the NPDES
Permit and WQMP as described in Section a) above, the project would result in a less than significant impact to
the receiving waters.
o) Less Than Significant Impact. As stated in Section e), the project site currently generates 6.52 cfs for the
10-year storm event, while the proposed site will generate 5.86 cfs from the 10-year storm event. The decrease
in runoff is obtained due to the larger time of concentration associated with the completed project relative to that
of the existing conditions. Therefore, no matter the intensity of the storm, the runoff, velocity and volume
exiting the proposed site will always be less than that of the existing condition and there will be no impact on
downstream drainage devices or waters. In addition, with adherence to the NPDES Permit and WQMP as
described in Section a) above, impacts to the volume and velocity of storm flows would be less than significant.
p) Less Than Significant Impact. The project site is currently developed with a high school campus on
relatively level terrain. As the project would include demolition, grading, excavation, and other improvements,
as necessary, the potential exists for short-term soil erosion during such activities. However, this is not
considered a potentially significant impact given the project will comply with local NPDES regulations and
water quality management plan pursuant to California RWQCB requirements has been prepared. The water
quality report includes erosion control BMPs, sediment control measures, non-storm water management BMPs,
and site design and routine non-structural BMPs (refer to the draft preliminary WQMP in Appendix B of this
MND). It should be noted that since the proposed project does not increase the amount of runoff exiting the site
or modify the existing drainage pattern, there will be no impact on the erosion of any downstream natural
drainage channels. Additionally, grading plan will be in compliance with City conditions and subject to review
and approval by the City engineer to further avoid the potential impacts. Therefore, with incorporation of the
BMPs, grading techniques, and City standard conditions, the impacts would be less than significant.
60
9.
(a)
(b)
(c)
LAND USE/PLANNING.
Potentially
Significant
Impact
Would the project:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Physically divide an established community?
Conflict with any applicable land use plan, policy, or regulation of an
agency with jurisdiction over the project (including, but not limited to the
general plan, specific plan, local coastal program, or zoning ordinance)
adopted for the purpose of avoiding or mitigating an environmental effect?
Conflict with any applicable habitat conservation plan or natural community
conservation plan?
Reference: 6 & 7
Impact Analysis:
a) No Impact. The proposed project site is located in an urbanized area and is surrounded by residential uses.
The project proposes to demolish the tennis courts and the temporary parking area and to construct new
expansion to the existing school building. The demolition and the construction of the proposed project will be
performed within the existing school campus. Therefore, the proposed project would not physically divide an
established community. No impacts would occur.
b) Less Than Significant With Mitigation Incorporated. The project site is currently occupied as a high
school; and the project would continue the school use with the proposed modifications to the site. The existing
General Plan designation of the project site is Low Density Residential (LDR) (2-6 DU/AC) and the existing
zoning classification is Single Family Residential (R-1-8) 8,000 square feet minimum. Although the school
use may be regarded as a public facility, the City’s Zoning Ordinance (17.14.030 Permitted Uses) allows school
uses to be permitted within residential zones by Conditional Use Permit. The General Plan’s Land Use section
has the following policies related to reducing potential land use conflicts:
ƒ
ƒ
Policy 9.1: Work to reduce land use conflicts between residential and non-residential uses.
Policy 9.2: Plan transitional areas to minimize any adverse impacts from new development on existing
residential development.
ƒ Policy 9.3: Annex all County “islands” within the City limits.
ƒ Policy 9.4: Prohibit the establishment of any industrial use north of Fletcher Avenue.
The school use and the residential development will be buffered by the existing walls. In addition, the project
proposes additional landscaping between the existing residential development and the project site to reduce the
visual impact of the proposed project. Also, mitigation measures are included throughout this document (i.e.,
Aesthetics and Noise sections) to minimize potential adverse impact from the proposed project on existing
residential development. The project site is not a part of the County “islands” and therefore, no annexation is
required. Since the project site is located southeast of the Fletcher Avenue and is not consider an industrial
use, the establishment of the project would not be prohibited. Therefore, the proposed project is not in conflict
with the City’s General Plan land use and zoning designations.
SR-55 Freeway travels to the west of the project site. The existing wall between SR-55 and the school
football/soccer field will continue to provide a division between two uses. Build-out of the project would not
affect the operation of SR-55, and SR-55 would not be in conflict with the campus operation. The proposed
project would not generate compatibility issues with surrounding uses to the west of the campus.
The project site is surrounded by single-family residential uses to north, east, southwest, and south. The
proposed project’s potential compatibility issues are related to visual characteristic and noise. These potential
compatibility issues would be reduced by project features such as the existing six foot wall between the multipurpose building and the residential uses to the north of the campus and the landscaping within the project site.
61
As described in Project Description Section, the proposed project includes replacing the tennis courts and
temporary parking lot with a new faculty parking lot and outdoor sports courts. In addition, a two-story
building will be constructed next to the multi-purpose building. Mitigation measures are identified to assure
that the visual impact of the proposed project would be less than significant. Activities at the proposed outdoor
sports courts and faculty parking lot may also generate noise at residential uses. However, the “normal” noise
from school activities, such as the outdoor sports courts, are considered to be less than significant by specifically
exempting such sources from the City’s Municipal Code (Section 8.24.070). There will be no lights on the
outdoor sports courts to limit the operational hours of the courts to during the normal school hours and after
school until 6:30 P.M. for team practice. The noise from the existing tennis courts will be replaced with the
noise from the proposed faculty parking lot. However, mitigation measures are identified to assure that the
noise from the relocated faculty parking lot would be less than significant. Therefore, with these mitigation
measures, the proposed project would not result in a significant land use compatibility impact on surrounding
residential uses to the north, east, southwest, and south of the project site.
c) No Impact. The proposed project area is developed and does not contain any habitat that is included in a
Natural Community Conservation Plan (NCCP) or Habitat Conservation Plan (HCP) areas. All of the plant
species on the site are introduced. Therefore, the project will not result in any conflict with such plans. No
impacts would occur.
10.
(a)
(b)
MINERAL RESOURCES.
Potentially
Significant
Impact
Would the project:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Result in the loss of availability of a known mineral resource that would be
of value to the region and the residents of the state?
Result in the loss of availability of a locally-important mineral resource
recovery site delineated on a local general plan, specific plan or other land
use plan?
Reference: 6 & 7
Impact Analysis:
a) & b) No Impact. Based on the City of Orange General Plan, significant mineral resource deposits in Orange
are primarily limited to the sand and gravel resources contained in and along the Santa Ana River and Santiago
Creek. Sand and gravel resources are referred to collectively as “aggregate.” Aggregate is the primary
component of Portland cement concrete, a material widely used in the construction industry.
The State Mining and Geology Board has published a report which identifies five areas containing regionally
significant aggregate deposits in Orange. They are Resource Sector G adjacent to the Santa Ana River,
Resource Sector J in an around Santiago Creek, Sector L between Irvine Park and Santiago Dam in Santiago
Creek, Sector M, located under Santiago Reservoir (Irvine Lake) and Sector N, beginning near Santiago
Reservoir in Santiago Creek to the planning area boundary as “Regionally Significant Aggregate Resource
Areas.” The proposed project is not located within any designated or known mineral resource zones.
Consequently, the project does not result in the loss of known mineral resources of either statewide (designated
MRZ) or local importance. No impacts would occur.
62
11.
(a)
(b)
(c)
(d)
(e)
(f)
NOISE.
Potentially
Significant
Impact
Would the project result in:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Exposure of persons to or generation of noise levels in excess of standards
established in the local general plan or noise ordinance, or applicable
standards of other agencies?
Exposure of persons to or generation of excessive groundborne vibration or
groundborne noise levels?
A substantial permanent increase in ambient noise levels in the project
vicinity above levels existing without the project?
A substantial temporary or periodic increase in ambient noise levels in the
project vicinity above levels existing without the project?
For a project located within an airport land use plan or, where such a plan
has not been adopted, within two miles of a public airport or public use
airport, would the project expose people residing or working in the project
area to excessive noise levels?
For a project within the vicinity of a private airstrip, would the project
expose people residing or working in the project area to excessive noise
levels?
Reference: 6, 7, & 12
Impact Analysis:
a), b), & c) Less Than Significant Impact. A noise impact analysis was conducted by Giroux and Associates
(Appendix D). Local noise issues are addressed through compliance and enforcement of Noise Ordinance
standards. As seen in Table 11-1, the Noise Ordinance of the City of Orange Municipal Code (OMC) Section
8.24.050 (A) establishes an exterior limit of 55 dBA at residential property lines during daytime periods (7:00
A.M. to 10:00 P.M.).
Table 11- 1
Orange Municipal Code
Noise Ordinance Standards (dB)
Not to be exceeded
More than 30 minutes per hour
More than 15 minutes per hour
More than 5 minutes per hour
More than 1 minute per hour
At any time
7 A.M. – 10 P.M.
55
60
65
70
75
10 P.M. – 7 A.M.
50
55
60
65
70
For activities before 7 A.M. or after 10 P.M., the applicable standard is 50 dB. These Noise Ordinance
standards are not to be exceeded for more than 30 minutes in any hour. These standards would potentially
apply to activities such as athletic events, band practice or extended periods of outdoor student assembly that
would cover the bulk of an hour. The nocturnal standards would be also applicable to the relocated parking lot
which may have some arrivals before 7 A.M. or some departures after 10 P.M. for a late-running campus event.
However, the above Noise Ordinance standard does not apply to any “normal” school activities such as athletic
events or outdoor student recreation. Section 8.24.070 of the City Noise Ordinance states as follows:
63
The following activities shall be exempted from compliance with numerical standards articulated in Section
8.24.070 of the OMC:
C. Activities conducted on public parks, public playgrounds, and public or private school grounds.
Because construction activity noise generation is generally exempt from complying with numerical ordinance
standards if the activity occurs during periods of lesser noise sensitivity, there are only limited regulatory noise
constraints relative to project construction. Construction noise is governed by Municipal Code Section
8.24.070 (E) as follows:
8.24.070 Exemption from Chapter Provisions: The following activities shall be exempted from the provisions of
this Chapter:
E. Noise sources associated with construction, repair, remodeling or grading of real property, provided
said activities do not take place between the hours of 8:00 P.M. and 7:00 A.M. on weekdays,
including Saturday, or at any time on Sunday or a Federal holiday.
Time variations in noise exposure are typically expressed in terms of a steady-state energy level (called Leq),
representing the acoustical energy of a given measurement. Lmax refers to the maximum A-weighted noise
level recorded for a single noise event, and Lmin refers to the minimum A-weighted noise level recorded for a
single noise event. Because community receptors are more sensitive to unwanted noise intrusion during the
evening and at night, State law (Government Code 65302) requires that for planning purposes, an artificial dBA
increment be added to quiet time noise levels to better stimulate human sensitivity to noise. When nocturnal
levels (10 P.M. – 7 A.M.) are penalized by +10 dB, the description is called the day-night level (LDN). If an
evening (7 P.M. – 10 P.M.) penalty is also included in a 24-hour noise descriptor, it is called the Community
Noise Equivalent Level (CNEL). In practice, LDN and CNEL are almost always numerically identical.
Baseline Noise Levels
CEQA Guidelines require that an impact analysis be based upon existing conditions. The significance of the
proposed action thus must be evaluated in terms of the change from existing conditions. Any substantial
increase from existing conditions is potentially significant. However, any use permit must take into account
not just the change in conditions, but the magnitude of the baseline. If baseline conditions are already elevated,
background levels may mask the project contribution such that a less stringent compliance standard would be
most appropriate in such cases.
The decibel (dB) scale is used to quantify sound intensity. Humans typically conclude that noise levels are
perceptibly higher when noise levels increase by +3 decibels (dB). A dB is on a logarithmic scale and a +3 dB
increase requires a doubling of the number of source elements (i.e., 10 x log (2) = +3). Since the human ear is
not equally sensitive to all sound frequencies within the entire spectrum, human response is factored into sound
descriptions in a process called “A-weighting,” written as “dBA.” The dBA, or A-weighted decibel, refers to a
scale of noise measurement that approximate the range of sensitivity of the human ear to sounds of different
frequencies. On this scale, the normal range of human hearing extends from about 0 dBA to about 140 dBA.
A 10-dBA increase in the level of a continuous noise represents a perceived doubling of loudness. All of the
noise levels presented herein are in terms of dBA unless the text indicates otherwise.
In order to document baseline noise levels near the proposed new campus amenities, a short-term noise
measurement study was conducted at the two closest residences immediately north and south of the proposed
construction. The measurements were taken on Friday, July 27, 2007. Location #1 was the front yard of
2166 Diamond Drive, which is the closest residence immediately south of the future outdoor sport court
location. Location #2 was the front yard of 2302 E. Villa Vista Way, which is the closest residence
immediately north of the future physical education building. Figure 23, Noise Meter Locations, shows the two
closest residences where the noise measurement study was conducted. Results are shown in Table 11-2 below:
Table 11- 2
64
Short-Term Noise Measurement
(July 27, 2007)
Location
#1
#2
Time
1100-1115
1121-1136
LEQ
49.4
51.4
Lmax
52.0
59.0
Lmin
47.0
47.5
L10
50.0
52.5
L33
49.5
51.0
L50
49.0
50.5
L90
47.5
48.5
The short-term noise measurement study was purposely not conducted when the school was in a normal session.
An elevated baseline during a normal school session would dilute the noise impact of the proposed action. The
quiet baseline was measured as 50 dB. Use of the quieter baseline was therefore selected as a worst-case
condition upon which project impacts were superimposed.
Analysis
Thresholds of Significance
Noise created as part of normal school activities is exempt from any noise ordinance standards. Such noise may
nevertheless be considered intrusive to off-site noise-sensitive land uses. CEQA Guidelines identify noise
impacts as potentially significant if the noise increase is substantial even if noise guidelines from local
ordinances or adopted plans are not exceeded. The human perception threshold of a noticeable increase in
noise levels is +3 dB. In an already noisy location, a perceptible increase would be considered potentially
significant. If baseline conditions are low, Caltrans and other jurisdictions have adopted a perceived doubling
of loudness as significant even if no ordinance or planning standards are exceeded. Project-related noise
impacts are therefore considered significant for any of the following tests:
•
•
•
Increased noise levels cause ordinance or planning standards to be exceeded.
Noise levels increase substantially in an already high noise environment (+3 dB).
Noise levels increase substantially, but do not violate any standards (+10 dB).
The proposed project involves removing three tennis courts, expanding physical education facilities on the
tennis court area, relocating 50 parking spaces and adding 11 parking spaces, and building an outdoor sport
court on the site of the current parking lot. Except in proximity to new parking stalls or to the proposed
outdoor play courts, the overall perception of any change in campus noise generation will be negligible. The
traffic noise impact analysis demonstrates that project-related off-site traffic noise changes will be less than 0.1
dB CNEL on site access roadways. The changes in noise levels that would be created by the proposed project
implementation would be very localized. The outdoor sport court would be a new noise source, and traffic
noise would change slightly due to the parking lot relocation. Expansion of physical education facilities would
be primarily indoors without audible exterior noise.
65
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Location #2
Location #1
Figure 23
Noise Meter Locations
North
NTS
December 2008
66
Three changes in noise sources may affect the closest residences to the project site. These sources, and the
impact of the project compared to existing conditions, are summarized in Table 11-3, below:
Table 11-3
Project Noise Sources and Impacts
Noise Source:
Outdoor Sport Court
Parking Lot Relocation
Tennis Court Removal
Project Effect:
• Whistles from coaches
• Shouting by students
• Balls bouncing on the sport court
• Bystanders
• Door slams
• Car alarm chirps
• Vehicle startup
• Tire squeal
• No more ball impact noise
• No shouting by players or coaches
Outdoor Sports Court
The proposed outdoor sports court is intended for basketball and volleyball. It will replace the existing outdoor
sports court which is used for tennis and basketball. The outdoor sports court will be used during the normal
school hours (7:30 A.M. to 2:30 P.M.) for Physical Education (PE) classes and after school (2:30 P.M. to 6:30
P.M. depending on daylight conditions) for freshman team practice. There will be no light on the court to
preclude night time use. Noise levels at the nearest home southwest of the proposed outdoor sport court may
increase during periods of most intense play noise. Activity noise will vary dramatically with the type of
activity such that it is difficult to generalize a unique noise impact. However, the addition of several basketball
courts is not expected to comprise a major impact for the homes given that the existing sports courts would have
a very similar source-receiver separation to their closest off-site residences. The analysis below shows that
noise levels at the closest home to the proposed courts during sport court use may be 58 dB, but attenuated to
near background noise levels by the existing wall separating the campus from the closest back yard. The City
of Orange further considers “normal” noise from school activities to be less than significant by specifically
exempting such sources from the Municipal Code (Section 8.24.070).
There is no National/State Standard that can be used to establish the baseline for the basketball courts noise.
Since the proposed outdoor sports courts are not built yet, the noise consultant, Giroux & Associates (G&A)
utilized an existing noise measurement data of basketball play by young adults that was obtained by G&A in
1998 (Shadow Oak Park 1998). The numbers of participants and activity level were similar to those
anticipated at the sports court relocation. Noise measurements at outdoor basketball games established a
reference noise level of 59 dB Leq from the center of the tip-off area of a single court. For two courts, the
assumed reference level is 62 dB Leq from the center of the courts at a 60-foot distance. For purposes of
analysis, the reported Leq reference noise level was assumed to be the 50th percentile (L50) level relative to the
OMC standards. The closest residences to the proposed sports court are approximately 50 feet from the edge
of the closest court surface, or 100 feet from the center of the courts. Geometrical spreading losses would
reduce the measured reference level to 58 dB at the property line of the closest receiver site if that measured
level was approximately applicable to the proposed project.
Measured baseline noise levels at the rear of the closest residence to the proposed relocated sports court during
negligible campus activities were approximately 50 dB. A level of 58 dB during peak basketball court use
would be clearly audible both through its loudness and its character (whistles, shouting, missed shots clanging
against the rim or backboard, etc.). As previously noted such noise is considered a “normal” part of school
operation and is exempt from any ordinance compliance requirements. The adopted threshold of significance
67
for noise increases in a normally quiet environment is +10- dB. Therefore, a noise level difference of 8 dB
would not be a substantial increase in a quiet environment unless any applicable standard is exceeded. The
calculated recreational activity noise increase is that level which crosses the property line above any perimeter
barrier. The existing rear yard wall at the closest residence will reduce this level to near the existing ambient
level at any usable rear yard space (patio, etc.) of 50 dB. In the nearest residential back yards, an existing
block wall will substantially reduce noise levels by interrupting the direct source to receiver line of sight. The
noise attenuation attainable with this wall, plus the increased distance set-back to usable patio areas of the
closest homes, will reduce basketball activity noise to 50 dB. Such a level will be noticeable, because of its
character, but not due to loudness. Basketball activity noise in the nearest back yards will therefore be less than
significant. This analysis is summarized as follows:
Table 11-4
Outdoor Sports Court Analysis Summary
Existing Baseline
Existing + Project
Threshold
Exceeds OMC Thresholds?
Exceeds +3B Audibility?
Exceeds +10 dB Substantial?
50 dB L50
59 dB L50
50 dB L50
Yes, but rear yard of closest home is shielded by a rear yard wall that
reduces existing plus project combination back to 52 dB L50 at the rear
patio, and normal school activities are exempt from OMC standards
compliance.
No, not at the patio area of the closest home.
No, not even without mitigation from the rear yard wall.
Based on the summary shown in Table 11-4 above, the sports court noise impact is considered less than
significant at the closest home.
Relocated Parking Lot Noise
Residents north of the proposed project site near the existing tennis courts would experience less recreational
activity noise from the removal of the three tennis/sport courts, but a new parking lot would be located adjacent
to the new building to be built on a portion of the demolished courts. This new parking lot will be solely used
by staff/faculty members during the school hours (7:00 A.M. to 4:00 P.M.). However, it will continue to be open
during the late afternoon for student parking during athletic practice, and on selected evenings to guests for after
school events (4:00 P.M. to 10:00 P.M.). When the special event is over at 10:00 P.M., the parking lot will be
closed at 11:00 P.M. The parking lot noise is less than the City of Orange nocturnal standard of 50 dB, and
therefore, operation until 11:00 P.M. would not cause any violation of standards. During evening events,
security staff will patrol the parking lot to prevent any unauthorized behavior. During late afternoon student
parking, coaches, teachers, and administrator will periodically pass through the parking lot. The noise analysis
presumed the parking lot behavior to be typical of responsible young adults because of frequent adult
supervision and the possible loss of parking privileges for unacceptable behavior.
Parking lot noise would derive from the arrival or departure of cars. The parking lot capacity is 61 vehicles, and
full utilization of all available spaces is presumed during a peak event. Arrival or departure noise from slowly
moving vehicles was calculated based upon 50 vehicles per hour. These cars are generally slow-moving.
Because trucks would not be using this lot, the noise from very slowly moving cars is very low. Although a
speed of 25 miles per hour (mph) was presumed in the noise impact analysis for moving vehicles as a worst-case
assumption, the allowed parking lot speed is 5 mph. At a distance of approximately 100 feet to the closest
property line, the traffic noise level would be 44 dB (one-hour average). The additional sound wave spreading
loss between the property line and the facades of the closest homes is an additional -3 dB. Therefore, the 44
dB at the property line would be reduced to 41 dB at the upstairs rear bedroom window. These levels are well
below the measured noise level even when school is not in session. With additional attenuation from existing
68
perimeter walls, the ground floor exposure to parking lot travel noise would be less than 40 dB.
would not use the fire lane to exit at the end of the school day or event.
The vehicles
If parking lot utilization were to occur before 7 A.M. or after 10 P.M., a more stringent standard would apply.
Pre 7 A.M. staff arrival will be minimal. Nocturnal parking lot issues would potentially derive primarily from
an event that runs slightly past 10 P.M. The departure of 61 vehicles (assume every space is occupied and
nobody leaves before 10 P.M.) will not require more than 30 minutes. At 10 seconds of travel time per
vehicle, it will require 10.2 minutes to empty the lot. The applicable noise standard would be the 15-minute
(L25) standard of 55 dB for post-10 p.m. noise events. The calculated noise level from 61 vehicles leaving the
lot is 45 dB L25 at the nearest property line. Departure traffic will not cause a significant traffic noise impact
seen as follows:
Table 11-5
Relocated Parking Lot Analysis Summary
Existing Baseline
Existing + Project
Threshold
Exceeds OMC Thresholds?
Exceeds +3B Audibility?
Exceeds +10 dB Substantial?
45 dB L25 (estimated)
48 dB L25
55 dB L25
No.
No, does not exceed criterion.
No.
Based on the summary shown in Table 11-5 above, the relocated parking lot noise impact is considered less than
significant at the closest home.
Any possible off-site noise intrusion from parking lot relocation could derive from a variety of single-event
noises that would be audible above the background noise level. Parking lot activity noise has been measured at
a variety of locations. Not every vehicle or every behavior has identical noise characteristics. However, there
is a fairly broad consensus on the approximate noise levels from parking lots based on numerous prior
measurement experiences. Parking spaces will range from approximately 30 feet to 300 feet from the nearest
northern residential property line. The preferred spaces closest to the team room and the training room are 100
feet from the nearest home. As a representative case, parking lot activity noise was presumed to originate at a
distance of 100 feet from the source to an off-site receiver residing nearest along the northern campus perimeter
closest to any single event noise generation. If the noise generation were closer than 100 feet from the
property line, the single event peak noise could be 6-8 dB higher than indicated. The peak noise level likely to
be experienced was assumed attenuated by 6 dB by the northern perimeter masonry wall. The results are
summarized in Table 11-6, below:
Table 11-6
Single Event Parking Lot Activity Noise
(At the nearest residence at 100 feet from source to received, dBA Lmax)
Noise Source
Auto horn directed at receiver
Car alarm
Loud conversation
Door slam
Engine starting up
Tire squeal while pulling into parking spot
Normal conversation at 3-5 feet separation
Alarm “chirp” during activation or deactivation
Max. Impact
84
70
53
52
49
47
44
42
Source: Edgemar Building Parking Lot Noise Study, Santa Monica, 1998.
69
The playing of loud radios or automobiles equipped with illegal exhaust conversions are not included in Table
11-6 above because these actions would be prohibited by the rules of use of the parking lot 4. Also, shouting at
passing cars while traversing the lot would be prohibited and the school staff would be responsible to monitor
and enforce the rules to the students. A car alarm triggering may cause a substantial noise increase,
particularly if the alarm operates through the vehicle’s forward directed horn. Use of the lot shall be regulated
in order to minimize nuisance impact potential to the closest residences. The school administration shall
periodically monitor compliance with the following Mitigation Measures. The maximum noise level observed
near the closest home north of the relocated parking lot was 59 dB (Lmax). Most parking/deparking noise is
predicted to be less than the already observed Lmax level. Because the lot would be used by adult staff members
during the day, and supervised by adults or campus security during the late afternoon or evening, parking lot
users would not likely honk or shout to other cars. Accidental car alarm triggering would be the only clearly
audible single event noise at the relocated facility. No noise complaints from staff parking have been
documented at the existing faculty and staff lot located at similar distance from nearby homes as the relocated
site. As long as the existing pattern of use and source location do not change appreciably with the proposed
project, the number of single event nuisance noises would not change substantially. Also, development of the
relocated lot, when balanced against the elimination of noise from tennis balls bouncing and player exuberance,
indicates that noise impacts from the proposed action would be negligible at the closest homes along the
northern project site perimeter. In addition, the following mitigation measures would reduce the impact related
to the relocated parking lot noise to less than significant.
MM 11-1
Both parking lot gates shall be closed everyday from 11:00 P.M. to 6:00 A.M.
MM 11-2
The applicant shall conduct annually a “drivers courtesy” seminar for all students. The
seminar shall be taught by student peers and shall include courtesy driving behavior to residents
accessing Santiago Boulevard from adjacent streets and adverse effects of playing loud music,
shouting or other rowdy behavior in the school’s parking lot.
MM 11-3
The use of car horns shall be prohibited within the lot except for emergency/safety use.
MM 11-4
During special events, security services will be present on site and will be monitoring both
parking lots.
Vibration
Vibration is an oscillation induced in a structure by an outside force. Physical objects vibrate in a linear
combination of natural frequencies of the object. The object will continue to vibrate, and the vibration will
propagate through any intervening medium, unless acted upon by additional forces. In all physical systems,
the effects of friction dampen the vibration.
Vibration can be expressed in terms of displacement, the mean velocity of the motion, or the instantaneous
acceleration. The root-mean-square (rms) velocity is a common descriptor. A level of 0.5 inches/second is a
common threshold level for construction activities because such a level has negligible potential for any
structural damage, and is not considered excessively unpleasant in human perception (MTA Metrorail
Construction Fact Sheet, 1998). The threshold of visible damage to mortar or drywall, however, depends more
upon the peak particle velocity (ppv) rather than the rms velocity. Peak levels are generally four to five times
the rms level. An rms velocity of 0.1 inch/second is therefore an appropriate indicator of any damage potential
due to construction activity vibration because it equates to a 0.5 inch/second ppv.
4
CUP2499-04’s #12 states that “the applicant shall conduct annually a “drivers courtesy” seminar for all students. The
seminar shall be taught by student peers and shall include courtesy driving behavior to residents accessing Santiago
Boulevard from adjacent residential streets and the adverse effects of playing loud music in the school’s parking lot.”
70
Vibration levels (rms) observed around construction sites as a function of distance are generally as follows (FTA
Transit Noise & Vibration Assessment, Chapter 12, Construction 1995):
Truck at 50 feet from paved road
Auto at 50 feet from highway
Auto at 50 feet from rough road
Jackhammer at 50 feet
Dozer at 50 feet
-
0.02 in/sec
0.001 in/sec
0.005 in/sec
0.01 in/sec
0.05 in/sec
The suggested significant threshold of 0.1 in/sec rms is met well within 50 feet of on-site construction, and
within 50 feet of any public haul road, with a wide margin of safety. Heavy equipment operations associated
with proposed project construction generally have more than 50 feet of set-back from the nearest homes or other
structures. Project-related construction activities will have no perceptible vibration impact at any adjacent
sensitive residential uses.
Off-Site Traffic Noise Impacts
Although the proposed project anticipates four additional staff member, it will not increase the student
enrollment. A total of 16 new trips from the gradual growth of four staff positions is expected to occur over
time. Thus, the proposed project would generate minimal additional traffic that could affect off-site receivers.
Within the round-off procedures for traffic analysis, there is no measurable change in off-site traffic associated
with the proposed action. Traffic noise was calculated for a 45 mph travel speed on roadway segments near the
campus as shown in Table 11-7 (dB CNEL at 50 feet from the centerline):
Table 11-7
Project Traffic Noise
Roadway
Tustin
Santiago Blvd.
Nohl Ranch Road
Meats Avenue
Taft Avenue
Segment
Nohl Ranch - Meats
Meats-Taft
N. of Nohl Ranch
Nohl Ranch – Villa Real
Meats – Taft
S. of Taft
W. of Tustin
SR-5 – Santiago
E. of Santiago
W. of Tustin
SR-55 – Santiago
E. of Santiago
SR-55 – Santiago
Existing CNEL
73.1
74.0
68.1
69.0
70.5
70.7
72.1
74.0
67.1
69.4
69.7
68.1
68.5
The proposed project is seen to have no detectable effect on off-site traffic noise.
to the off-site traffic noise would be less than significant.
With Project CNEL
73.1
74.0
68.1
69.0
70.5
70.7
72.1
74.0
67.1
69.4
69.7
68.1
68.5
Therefore, the impact related
d) Less Than Significant with Mitigation Incorporated. The proposed project’s noise impact analysis
(Appendix D) also analyzed construction noise to specifically assess demolition and construction related
impacts of the proposed project. The proposed project would involve demolition of the existing tennis courts
and the temporary staff parking lot, construction of a new outdoor sport court, new staff parking lot, and a new
building next to the existing multi-purpose building. These various activities have the potential to create shortterm significant noise impacts. However, demolition and/or construction operations would be a temporary
impact with no long-term permanent implications. Noise generation from construction is exempt from City of
71
Orange Noise Ordinance performance standards if construction does not occur from 8:00 p.m. to 7:00 a.m., or at
any time on Sundays or major holidays (Municipal Code Section 8.24.070 (E)). Therefore, there is only
limited regulatory noise constraint relative to project implementation.
Construction noise levels would fluctuate depending on construction phase, equipment type, duration of use,
and distance between noise source and receptor. Typical construction equipment generates noise levels
ranging from about 76 to 88 dBA at a distance of 50 feet from the source, with slightly higher levels of about 88
to 91 dBA for certain types of earthmoving and impact equipment. Table 11-8 indicates noise levels at 25, 50,
and 100 feet from the noise source for typical construction equipment.
Table 11-8
Noise Levels of Construction Equipment at 25, 50, and 100 Feet
(in dBA LEQ) from the Source
Equipment
Earthmoving
Front Loader
Backhoes
Dozers
Tractors
Scrapers
Trucks
Material Handling
Concrete Mixer
Concrete Pump
Crane
Derrick
Stationary Sources
Pumps
Generator
Compressors
Other
Saws
Vibrators
Jackhammer
Noise Levels at 25 feet
Noise Levels at 50 feet
Noise Levels at 100 feet
85
86
86
86
91
91
79
80
80
80
85
85
73
74
74
74
79
79
91
88
89
94
85
82
83
88
79
76
77
82
82
84
87
76
78
81
70
72
75
84
82
92
78
76
86
72
70
80
Source: US Environmental Protection Agency “Noise from Construction Equipment and Operations, Building Equipment,
and Home Appliances,” 1971.
Demolition of existing uses would entail operation of impulsive equipment such as jackhammers or other
concrete breaking equipment. At 100 feet from the activity, assuming 8 dB of attenuation from the existing
perimeter walls, backyard noise levels during hardscape demolition could be as high as 72 dB. Levels above
65 dB interfere with the ability to carry on a normal conversation. During a very small number of days during
the demolition phase, the closest back yards would be temporarily noise-impacted. Such activities would
likely occur when there is little or no student population if the noise is potentially disruptive to the learning
environment. There is little potential for any combined school operational and major construction noise. As
in the past, the neighbors will be notified of the general construction schedule. In addition to the small number
of days of this activity, and the time restrictions imposed by the Municipal Code to hours of lesser sensitivity
when many nearby residents would be away from their homes, the following mitigation measure would reduce
the construction activity noise impacts to less than significant.
MM 11-5 Prior to any activity with potential noise impacts, residents within 250 feet of any proposed project
construction activities shall be provided with a description of the activity, the anticipated duration of
72
the noisiest portion of construction, and the phone numbers of both OLHS staff and the lead
contractor where any construction noise nuisance complaints may be lodged. A response shall be
provided to the resident within 72 hours indicating resolution of the complaint. A copy of the
notices shall be provided to City staff prior to commencement of activity.
e) No Impact. There are no airports located within two miles of the project site nor is the project located within
airport land use plan boundaries. Therefore, the proposed project would not expose area residents or people
working in the project area to excessive noise levels associated with airport noise. No impacts would occur.
f) No Impact. There are no private airstrips located in the project vicinity. Accordingly, the proposed project
would not expose area residents or people working in the project area to excessive noise levels associated with a
private airstrip. No impacts would occur.
12.
(a)
(b)
(c)
POPULATION AND HOUSING.
Potentially
Significant
Impact
Would the project:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Induce substantial population growth in an area, either directly (for
example, by proposing new homes and businesses) or indirectly (for
example, through extension of roads or other infrastructure)?
Displace substantial numbers of existing housing, necessitating the
construction of replacement housing elsewhere?
Displace substantial numbers of people, necessitating the construction of
replacement housing elsewhere?
Reference: 6 & 13
Impact Analysis:
a) Less Than Significant Impact. The implementation of the proposed improvements would not result in an
increase in the existing student population for the high school. The school will have 127 full-time and 16 parttime staff for the new school year of 2007/2008. This is an increase of 1 staff from the 142 staff during the
school year of 2006/2007.Based on the Private School Affidavit (October 2007), the high school estimates to
add four staff members by the time the proposed project is complete. Besides the four additional staff
members, the proposed project does not have a residential component, and therefore, would not introduce new
population in the area.
Orange County has an existing work force of construction laborers. Therefore, it is reasonable to assume that
most project-related construction workers would not relocate their households as a result of working on the
proposed project. Construction-phase employment, therefore, would not result in a substantial increase to the
local or regional population or specific increase in demand for housing. Thus, the impacts related to population
growth in the area would be less than significant.
b) No Impact. The proposed project site involves making improvements to the existing school campus.
Therefore, the project would not displace existing housing in the project area necessitating the construction of
replacement housing elsewhere. No impacts would occur.
c) No Impact. The Orange Lutheran High School is an already existing use within the project area.
construction of replacement housing would be required. No impacts would occur.
13.
PUBLIC SERVICES.
Potentially
Significant
Impact
Would the project:
73
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
No
Impact
(a)
Would the project result in substantial adverse physical impacts associated
with the provision of or need for new or physically altered governmental
facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or
other performance objectives for any of the public services:
i) Fire Protection?
ii) Police Protection?
iii) Schools?
iv) Parks?
v) Other public facilities?
Reference: 6, 7, & 8
Impact Analysis:
a) i) Less Than Significant Impact. The existing use is currently served by the City of Orange Fire
Department. The Lutheran High School facilities are existing uses and no increases to student population
would result with the proposed project. According to Ms. Wendy Saunders 5, Fire Safety Specialist, Plan
Check Coordinator, additional four staff/faculty members to the project site would result in less than significant.
a) ii) Less Than Significant Impact. The existing use is currently served by the City of Orange Police
Department. The Lutheran High School facilities are existing uses and no increases to student population
would result with the proposed project. According to Ms. Michelle Micallef 6, Crime Prevention Specialist at
the City of Orange Police Department, additional four staff/faculty members to the project site would result in
less than significant impact. In addition, standard security/protection measures required by the City will be
incorporated as project design features to provide for additional protection from crime. These features include
compliance with the City’s Building Security Standards (Municipal Code Chapter 15.52) as well as adherence to
the principles and techniques contained in the City’s Crime Prevention Through Environmental Design
(CPTED) program. Therefore, impact related to police protection would be less than significant.
a) iii) No Impact. The proposed project would not increase the number of public school students in local school
districts or increase the need for local public school facilities. No impacts would occur with project
implementation.
a) iv), v) No Impact. The demand for parks and other public facilities and services would not be affected since
the proposed use has athletic fields and other services for the students. No impacts would occur.
5
Telephone conversations on April 21 & 22, 2008.
6
Telephone conversation and electronic mail correspondence on April 15, 2008.
74
14.
(a)
(b)
RECREATION.
Potentially
Significant
Impact
Would the project:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project increase the use of existing neighborhood and regional
parks or other recreational facilities such that substantial physical
deterioration of the facility would occur or be accelerated?
Does the project include recreational facilities or require the construction or
expansion of recreational facilities which might have an adverse physical
effect on the environment?
Reference: 6 & 7
Impact Analysis:
a) No Impact. The Lutheran High School has its own athletic fields for the students attending the school. In
addition, the proposed project includes new outdoor sport court. Therefore, no increased use of existing
recreational facilities in the area is anticipated with project implementation, as no increase in number of students
will occur. No impacts would occur.
b) No Impact. The proposed project involves construction of an outdoor sport court. However, it would not
have an adverse physical effect on the environment, as it would be constructed within the existing campus where
the temporary parking area currently is situated. No impacts would occur.
15.
(a)
(b)
(c)
(d)
(e)
(f)
(g)
TRANSPORTATION/TRAFFIC.
Potentially
Significant
Impact
Would the project:
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Cause an increase in traffic which is substantial in relation to the existing
traffic load and capacity of the street system (i.e., result in a substantial
increase in either the number of vehicle trips, the volume to capacity ratio
on roads, or congestion at intersections)?
Exceed, either individually or cumulatively, a level of service standard
established by the county congestion management agency for designated
roads or highways?
Result in a change in air traffic patterns, including either an increase in
traffic levels or a change in location that results in substantial safety risks?
Substantially increase hazards due to a design feature (e. g., sharp curves or
dangerous intersections) or incompatible uses (e.g., farm equipment)?
Result in inadequate emergency access?
Result in inadequate parking capacity?
Conflict with adopted policies, plans, or programs supporting alternative
transportation (e.g., bus turnouts, bicycle racks)?
Reference: 1 & 7
Impact Analysis:
a) Less Than Significant Impact. Since the proposed project would not result in any additional students, the
trip generation rates are based on four additional anticipated staff (i.e. one maintenance, one business office, and
two faculty/coach staff members). The existing traffic counts at the study intersections were collected in
September 2006, when the high school, as well as the other schools in the area, was in session. These
intersection counts provided the existing conditions against which the project’s potential impacts were assessed.
Figure 24 illustrates the existing average daily traffic (ADT) volumes on the study area roadways, which were
obtained from the City of Orange 2005 Flow Map. Santiago Boulevard is currently carrying 13,000 to 18,400
ADT in the vicinity of the project. The existing volumes on Meats Avenue west of Santiago Boulevard are
75
15,300 ADT and 10,700 ADT east of Santiago Boulevard. Existing AM and PM peak hour intersection
volumes were collected in September 2006 (while schools were in session) by Traffic Data Services, Inc., with
the exception of the peak hour volumes at Santiago Boulevard and Meats Avenue which were obtained from the
City of Orange General Plan Circulation Element Traffic Study. Figures 25 and 26 illustrate the existing AM
and PM peak hour volumes.
Based on a traffic study by Austin-Foust Associates, Inc. (January 2008) (see Appendix E), the proposed project
would generate 66 daily trips, including 21 AM peak hour trips and three PM peak hour trips. Table 15-1
summarizes the trip generation for the proposed project. Based on the trip generation rates, the proposed
project would generate a nominal amount of peak hour traffic, and therefore would have an insignificant impact
on the surrounding circulation system. This amount of traffic will have no significant impact on the critical
study intersection (Santiago Boulevard at Meats Avenue) which currently operates at mid-LOS “D” (ICU 0.85)
during the AM peak hour. This project is also exempt from any further detailed traffic analysis since, according
to the County of Orange Congestion Management Program (CMP) guidelines, projects that generate less than
2,400 trips are exempt from a full CMP traffic impact analysis.
Table 15-1
Proposed Project Trip Generation Summary
Land Use
Private School (K-12)
Trip Rates*
Trip Generation
AM Peak Hour
In
Out
Total
Amount
Emp.
4 Emp.
3.24
13
2.07
8
PM Peak Hour
In
Out
Total
5.31
21
0.33
1
0.53
2
0.86
3
ADT
16.43
66
*Institute of Transportation Engineers (ITE), 7th
Source: Austin-Foust Associates, July 2007
b) No Impact. The following five study intersections were analyzed for average daily traffic (ADT) volumes:
Tustin Ave. & Meats Ave.; Santiago Blvd. & Nohl Ranch Rd.; Santiago Blvd. & SR-55 Northbound Ramps;
Santiago Blvd. & Meats Ave.; and Santiago Blvd. & Taft Ave. Peak hour intersection capacity utilization
(ICU) values for existing conditions at these five intersections are summarized in Table 15-2. These
intersections currently operate at a level of service (LOS) of "D" or better during AM and PM peak hours.
Existing-plus-project peak hour intersection volumes, including the 21 AM peak hour trips and three PM peak
hour trips, would have no impact on the study area intersections and would continue to operate at the current
level of service or better during the AM and PM peak hours (see Table 15-2). No impacts would occur.
Table 15-2
Existing + Project ICU Summary
Existing
Intersection
1. Tustin & Meats
2. Santiago & Nohl Ranch
3. Santiago & SR-55 NB
4. Santiago & Meats
5. Santiago & Taft
Level of Service ranges:
AM
.63/B
.64/B
.53/A
.85/D
.52/A
.00-.60
.61-.70
.71-.80
.81-.90
.91-1.00
Above 1.00
Source: Austin-Foust Associates, July 2007
76
PM
.74/C
.66/B
.63/B
.74/C
.42/A
A
B
C
D
E
F
Existing + Project
AM
PM
.63/B
.74/C
.64/B
.66/B
.54/A
.63/B
.85/D
.74/C
.52/A
.42/A
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Legend
XX
ADT volume (000s)
Source: City of Orange 2005 Flow Map
Figure 24
Existing ADT Volumes
North
December 2008
77
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 25
Existing AM Peak Hour Volumes
North
December 2008
78
Orange Lutheran High School Expansion
Initial Study/Mitigated Negative Declaration
Figure 26
Existing PM Peak Hour Volumes
North
December 2008
79
c) No Impact. The proposed project would not generate air traffic nor affect such activities. Accordingly, the
proposed project would not result in a change in air traffic patterns. No impacts would occur.
d) Less Than Significant Impact. The proposed project would not increase hazards due to a design feature or
have any incompatible uses. The design plans would be in accordance with City standards and would be
submitted to the City for Site Plan Review before approval.
During the construction phase, traffic from construction workers as well as from trucks will add to the existing
traffic. The typical construction shift is 7:30 A.M. to 3:30 P.M. with construction workers arriving before the
shift starts and leaving at the end of the shift. Construction-related trucks arrive and depart throughout the
shift. However, the total amount of construction traffic is considerably less than the trips generated by buildout
of the proposed project and evaluated in the project traffic report. During the construction period, which is
expected to last up to two and one-half years, any oversize vehicles to or from the project site will be required to
obtain an oversize load permit to ensure adequate safety is maintained. During the two-half year construction
period, construction workers will arrive before 7:30 A.M. in order to begin work promptly at 7:30 A.M. The
school’s staggering of start times has parents dropping off students between 8:15 to 8:45 A.M., meaning the
construction workers will have arrived at the site and begun work long before school’s arrival of students.
Similarly, the school’s staggered dismissal period is between 3:00 to 3:30 P.M. during which time the
construction workers will be finishing up their day’s work but not leaving the site until after 3:30 P.M.
Observation of the actual dismissal period indicates the parent pick-up traffic is virtually entirely dissipated by
3:20-3:25 P.M. Therefore, due to the current scheduling of the school’s arrival and dismissal periods, there
will be no overlap of the construction employee trips with the school’s parent drop-off and pick-up trips. As a
result, the construction traffic impact will be less than significant.
e) No Impact. The general trip distribution for the proposed project would remain the same for the existing
school. The project-generated peak hour driveway volumes along with the total driveway volumes, including
the 21 AM peak hour trips and three PM peak hour trips, would have no impact on the roadway network;
therefore, no impact on emergency access through the City would occur.
f) Less Than Significant Impact. As stated previously under the Project Description, the existing CUP 226298/99 allows a total of 49 classrooms on site. There are 44 classrooms on site. The project proposes to add
10 classrooms. However, five of the existing classrooms will be taken out of service and will be turned into
office, meeting, and storage space. The new classrooms would allow flexibility in scheduling the new course
offerings, as well as the specialty classrooms such as science labs. The net increase of five classrooms will
keep the total number of classrooms on site to 49. Each class size will vary widely since the school is on a
block schedule. Most classes only meet three times a week, and not all classrooms are used every period every
day. It should be noted that the addition of 5 classrooms would not result in an increase of student enrollment.
Orange Municipal Code Table 17.34.060.B requires 8 parking spaces per classroom. A total of 49 classrooms
would require 392 parking spaces. The existing main parking lot contains 374 spaces and the temporary
parking lot contains 50 spaces. A total of 424 striped spaces is 32 spaces more than what is required.
The
entire 50 temporary parking spaces would be removed and replaced with 61 new parking spaces, resulting in an
increase of 11 spaces. The existing 424 parking spaces are only open to the faculty, staff, visitors, and seniors
during the school hours. The lower grade students must be dropped off at the school or park off-site. During
special events and after hours, the existing parking lots are open to the general school public. The proposed
project will not alter the existing drop-off/pick-up procedure. There is sufficient parking for the faculty, staff,
and seniors. However, in the past, there were times during special events, such as Open House, Back to School
Night, New Student Orientation, and an occasional sporting or theatre event, which caused overflow into the
neighborhood.
The proposed project is not expected to increase parking needs of Lutheran High School since there would not
be an increase in the number of students. However, the Private School Affidavit, which was completed in
October 2007, reflects the following additional staffing for the next three school years: new administrative staff
80
position such as Assistant Dean of Students, Associate Athletic Director, Faculty Development Director, and
College Planning Counselor; teaching positions for Biology, Math, English, and Spanish; and other staff
positions including two Online counselors and two assistant coaches/substitute teachers. Depending on the work
load, support staff could also be added in the area of maintenance and business operations. By the time the
proposed project is complete, the high school estimates to add four staff members: one maintenance, one
business office, and two faculty/coach staff members. These additional four staff members were included
when the traffic counts were performed. These additional four staff would bring the total number of employees
to 147 (existing 143 staff members + proposed 4 staff members) by the completion of this proposed project.
Nevertheless, the proposed project will result in 43 spaces more that what is required by the City. In addition,
Conditions of Approval 8 through 13 (except 10) of the previously approved CUP 2499-04 would be applicable
with this proposed project. They are listed below:
8. Students and faculty are not permitted to park at 2348 E. Villa Vista Way.
9. The parking lot gates shall be closed everyday from 10:00 P.M. to 6:00 A.M.
11. The applicant shall develop a comprehensive program for notification and monitoring of students that
park off-site. The project shall include penalties for persons who repeatedly are found to be parking
off-site. These penalties shall include tickets, parent notification, and suspensions.
12. The applicant shall conduct annually a “drivers courtesy” seminar for all students. The seminar shall
be taught by student peers and shall include courtesy driving behavior to residents accessing Santiago
Boulevard from adjacent residential streets and the adverse effects of playing loud music in the school’s
parking lot.
13. The applicant shall not schedule events that attract participants or spectators from off-site for more than
one facility (theaters and gymnasium) at a time.
The additional spaces and the enforcement of the Conditions would alleviate some of the parking demand of the
existing faculty, staff and students and would have no significant impact on the parking capacity of the existing
school.
g) No Impact. The proposed project would not affect any adopted policies, plans, or programs supporting
alternative transportation. No impacts would occur to alternative transportation opportunities.
16.
(a)
(b)
(c)
(d)
(e)
(f)
(g)
UTILITIES/SERVICE SYSTEMS.
Would the project:
Exceed wastewater treatment requirements of the applicable Regional Water
Quality Control Board?
Require or result in the construction of new water or wastewater treatment
or collection facilities or expansion of existing facilities, the construction of
which could cause significant environmental effects?
Require or result in the construction of new storm water drainage facilities
or expansion of existing facilities, the construction of which could cause
significant environmental effects?
Have sufficient water supplies available to serve the project from existing
entitlements and resources, or are new or expanded entitlements needed?
Result in a determination by the wastewater treatment provider which serves
or may serve the project that it has adequate capacity to serve the project’s
projected demand in addition to the provider’s existing commitments?
Be served by a landfill with insufficient permitted capacity to accommodate
the project’s solid waste disposal needs?
Comply with federal, state, and local statutes and regulations related to solid
wastes.
Reference: 6, 7, & 8
Impact Analysis:
81
Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) No Impact. The Orange County Sanitation District (OCSD) provides wastewater treatment services to the
City of Orange. The City of Orange owns and operates over 300 miles of local sewer pipelines within the City
limit, with the exception of the main trunk line, which is owned by OCSD. When wastewater is conveyed into
the OCSD's trunk line, it is processed at treatment plants located in Fountain Valley and Huntington Beach. It
is anticipated that the project's demand would not exceed wastewater treatment requirements of the applicable
Regional Water Quality Control Board. Accordingly, no impacts would occur.
b) No Impact. Although project implementation would increase demand for water and generation of
wastewater, the proposed project would not require or result in the construction of new off-site water or
wastewater treatment facilities. Accordingly, no impacts would occur.
c) No Impact. Project implementation would not involve construction of new storm water drainage facilities or
expansion of existing facilities. The runoff from the site would continue draining into the existing storm water
drainage facilities off-site. Therefore, no adverse impact related to storm water drainage facilities would occur.
d) No Impact. Domestic water service in the City, including the project site, is provided by the City’s own
Water Department. Primary water sources in the City are groundwater wells and water conveyed by the
Metropolitan Water District of Southern California. Through a high pressure loop system, the City is able to
provide domestic water supplies and fire suppression capabilities to most neighborhoods City-wide. Therefore,
no impacts would occur.
e) No Impact. As noted in the response to a) above, there is sufficient wastewater treatment capacity to serve
the demand of the proposed project. Therefore, no adverse impact related to wastewater treatment services
would occur.
f) No Impact. The proposed would not create substantial additional quantities of solid waste beyond the current
disposal rate. No impacts would occur.
g) No Impact. The proposed project would comply with federal, state, and local regulations regarding solid
wastes. No impacts would occur.
17.
(a)
(b)
(c)
Potentially
Significant
Impact
MANDATORY FINDINGS OF SIGNIFICANCE
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Does the project have the potential to 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?
Does the project have impacts that are individually limited, but
cumulatively considerable? (“Cumulatively considerable” means that the
incremental effects of a project are considerable when viewed in connection
with the effects of past projects, the effects of other current projects, and the
effects of probable future projects?)
Does the project have environmental effects which will cause substantial
adverse effects on human beings, either directly or indirectly?
Impact Analysis:
a) No Impact. The proposed project site is located in a well developed area. The proposed project does not
affect wildlife, natural communities, and/or rare and endangered species, and it will not degrade the quality of
82
the environment (Section 4, above).
No impacts would occur.
Further, the project will not impact historic resources (Section 5, above).
b) Less Than Significant Impact. The proposed project would involve improvements and expansion of the
existing school campus. The school expansion would not occur outside of the existing property boundaries,
and all construction would occur on site. Because the improvements would occur within the existing school
property, the proposed project would not result in impacts that would be considered cumulatively significant.
c) Less Than Significant With Mitigation Incorporated. The project would not result in substantial adverse
effects on human beings, either directly or indirectly. Mitigation measures and project design features are
provided in Sections 1, 3, and 11 (see Appendix F, Mitigation Monitoring Report). No additional mitigation
measures would be required.
18.
REFERENCES
1. Austin-Foust Associates, Inc. Lutheran High School Facilities Improvements Traffic Analysis, November
2008.
2. Blue Peak Engineering, Inc., Draft Preliminary Water Quality Management Plan (WQMP), April 21, 2008.
3. California Air Resources Board (CARB). Assembly Bill No. 32.
Available at: www.arb.ca.gov/cc/docs/ab32text.pdf.
4. California Air Resources Board (CARB). AB32 Fact Sheet.
Available at: www.arb.ca.gov/cc/factsheets/ab32factsheet/pdf.
5. City of Orange.
Greenhouse Gas Emissions (GHG) Analysis – Interim Guidance.
6. City of Orange.
Mitigated Negative Declaration No. 1585-99, December 1998.
7. City of Orange.
Orange General Plan Integrated General Plan, December 2005.
September 30, 2008.
8. City of Orange website, www.cityoforange.org.
9. County of Orange, General Plan, 2005.
10. County of Orange, Health Care Agency, Environmental Health, April 20, 1007.
11. Giroux and Associates. Air Quality Impact Analysis, September 23, 2007.
12. Giroux and Associates. Noise Impact Analysis, April 21, 2008.
13. Lutheran High School of Orange County website, www.lhsoc.org.
14. State of California. Governor’s Office of Planning and Research, CEQA and CLIMATE Change:
Addressing Climate Change Through California Environmental Quality Act (CEQA) Review. June 19,
2008.
83
19.
TECHNICAL APPENDICES
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Air Quality Impact Analysis, Giroux & Associates, July 10, 2008.
Draft Preliminary Water Quality Management Plan (WQMP), Blue Peak Engineering, Inc.,
April 21, 2008.
Inspection Report, County of Orange, Health Care Agency, Environmental Health, April 20,
2007.
Noise Impact Analysis, Giroux & Associates, September 17, 2008.
Lutheran High School Facilities Improvements Traffic Analysis, Austin-Foust Associates, Inc.,
November 2008.
Mitigation Monitoring Report, October 2008.
84