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 i 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 ii 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. iii 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 December 2008 iv Orange Lutheran High School Expansion 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. 1 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 2 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 3 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 4 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 5 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: 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”). Construction of an outdoor basketball and volleyball sports court. Installation of new landscaping. 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. 7 Orange Lutheran High School Expansion Initial Study/Mitigated Negative Declaration Figure 6 Proposed Site Plan North NTS December 2008 8 Orange Lutheran High School Expansion Initial Study/Mitigated Negative Declaration Figure 7 Lower Level Plan North NTS December 2008 9 Orange Lutheran High School Expansion Initial Study/Mitigated Negative Declaration Figure 8 First Floor Plan North NTS December 2008 10 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. 12 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.). 14 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 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 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 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: 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. 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. 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: 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. 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. 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 Apply soil stabilizers to inactive areas. Prepare a high wind dust control plan and implement plan elements and terminate soil disturbance when winds exceed 25 mph. Limit the simultaneous disturbance area to as small an area as practical. Stabilize previously disturbed areas if subsequent construction is delayed. Water exposed surfaces and haul roads 3 times/day. Cover all stock piles with tarps. Replace ground cover in disturbed areas quickly. 43 Reduce speeds on unpaved roads to less than 15 mph. Exhaust Emissions Require 90-day low-NOx tune-ups for off-road equipment. 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: 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: 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: 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. 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. 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. 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. 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. 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 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: 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. Policy 9.3: Annex all County “islands” within the City limits. 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