ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN

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1 March 217 Final Environmental Impact Report State Clearinghouse No EIR No. 626 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN for County of Orange Prepared for: County of Orange Contact: James Campbell, Manager, Land Development 333 W. Santa Ana Boulevard Santa Ana, California Prepared by: PlaceWorks Contact: Nicole Morse, Esq., Associate Principal 3 MacArthur Place, Suite 11 Santa Ana, California info@placeworks.com Page 1 of 186

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3 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE Table of Contents W Section 1. INTRODUCTION Page 1.1 INTRODUCTION FORMAT OF THE FEIR CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES RESPONSE TO COMMENTS REVISIONS TO THE DRAFT EIR INTRODUCTION DEIR REVISIONS IN RESPONSE TO WRITTEN COMMENTS REFERENCES APPENDICES Appendix A. Traffic Study Addendum March 217 Page i Page 3 of 186

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5 1. Introduction 1.1 INTRODUCTION This Final Environmental Impact Report (FEIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) as amended (Public Resources Code 21 et seq.) and CEQA Guidelines (California Code of Regulations 15 et seq.). According to the CEQA Guidelines, Section 15132, the FEIR shall consist of: (a) The Draft Environmental Impact Report (DEIR) or a revision of the Draft; (b) Comments and recommendations received on the DEIR either verbatim or in summary; (c) A list of persons, organizations, and public agencies comments on the DEIR; (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process; and (e) Any other information added by the Lead Agency. This document contains responses to comments received on the DEIR for the Orange County Civic Center Facilities Strategic Plan during the public review period, which began December 22, 216, and closed February 6, 217. This document has been prepared in accordance with CEQA and the CEQA Guidelines and represents the independent judgment of the Lead Agency. This document and the circulated DEIR comprise the FEIR, in accordance with CEQA Guidelines, Section FORMAT OF THE FEIR This document is organized as follows: Section 1, Introduction. This section describes CEQA requirements and content of this FEIR. Section 2, Response to Comments. This section provides a list of agencies and interested persons commenting on the DEIR; copies of comment letters received during the public review period, and individual responses to written comments. To facilitate review of the responses, each comment letter has been reproduced and assigned a number (A-1 through A-8 for letters received from agencies and organizations). Individual comments have been numbered for each letter and the letter is followed by responses with references to the corresponding comment number. March 217 Page 1-1 Page 5 of 186

6 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 1. Introduction Section 3. Revisions to the Draft EIR. This section contains revisions to the DEIR text and figures as a result of the comments received by agencies and interested persons as described in Section 2, and/or errors and omissions discovered subsequent to release of the DEIR for public review. The responses to comments contain material and revisions that will be added to the text of the FEIR. County of Orange staff has reviewed this material and determined that none of this material constitutes the type of significant new information that requires recirculation of the DEIR for further public comment under CEQA Guidelines Section None of this new material indicates that the project will result in a significant new environmental impact not previously disclosed in the DEIR. Additionally, none of this material indicates that there would be a substantial increase in the severity of a previously identified environmental impact that will not be mitigated, or that there would be any of the other circumstances requiring recirculation described in Section CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES CEQA Guidelines Section 1524(a) outlines parameters for submitting comments, and reminds persons and public agencies that the focus of review and comment of DEIRs should be on the sufficiency of the document in identifying and analyzing possible impacts on the environment and ways in which significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible. CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR. CEQA Guidelines Section 1524(c) further advises, Reviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 1564, an effect shall not be considered significant in the absence of substantial evidence. Section 1524(d) also states, Each responsible agency and trustee agency shall focus its comments on environmental information germane to that agency s statutory responsibility. Section 1524(e) states, This section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section. In accordance with CEQA, Public Resources Code Section , copies of the written responses to public agencies will be forwarded to those agencies at least 1 days prior to certifying the environmental impact report. The responses will be forwarded with copies of this FEIR, as permitted by CEQA, and will conform to the legal standards established for response to comments on DEIRs. Page 1-2 PlaceWorks Page 6 of 186

7 2. Response to Comments Section 1588 of the CEQA Guidelines requires the Lead Agency (County of Orange) to evaluate comments on environmental issues received from public agencies and interested parties who reviewed the DEIR and prepare written responses. This section provides all written responses received on the DEIR and the County of Orange s responses to each comment. Comment letters and specific comments are given letters and numbers for reference purposes. Where sections of the DEIR are excerpted in this document, the sections are shown indented. Changes to the DEIR text are shown in underlined text for additions and strikeout for deletions. The following is a list of agencies and persons that submitted comments on the DEIR during the public review period. Number Reference Commenting Person/Agency Date of Comment Page No. Agencies & Organizations September 13, 216 A1 Airport Land Use Commission for Orange County (ALUC) February 6, A2 California Department of Transportation (Caltrans) February 6, A3 City of Irvine January 3, A4 City of Santa Ana February 6, A5 City of Tustin February 6, A6 Native American Heritage Commission (NAHC) February 2, A7 Orange County Transportation Authority (OCTA) February 6, A8 State Clearinghouse February 7, March 217 Page 2-1 Page 7 of 186

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9 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments Letter A1 Airport Land Use Commission for Orange County (3 pages) March 217 Page 2-3 Page 9 of 186

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13 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A1. Response to Comments from the Airport Land Use Commission for Orange County, dated September 13, 216 and February 6, 217. Letter A1 dated September 13, 216 is a comment letter on the Notice of Preparation that was erroneously omitted from the DEIR. The Airport Land Use Commission submitted a follow up letter on the DEIR on February 6, 217, addressing the same comments. A1-1 The County of Orange acknowledges that the project site is outside of the noise impact zones, clear zone, and height restriction zone for John Wayne Airport. No further response is needed. A1-2 The comment notes that projects proposing construction of buildings over 2 feet above ground level must file a Notice of Proposed Construction or Alteration with the Federal Aviation Administration. The project does not propose buildings over 2 feet above ground level; Buildings 1, 14, and 16 would be six stories with two levels of subterranean parking, and Building 12 would be four stories with two levels of subterranean parking. Therefore, the proposed project would not require filing of a Notice of Proposed Construction or Alteration. A1-3 The comment pertains to heliports and the required permit procedure. The project does not propose development of a heliport, and the nearest heliport to the site is the Southern California Edison Southeastern Division Heliport approximately 1.85 miles west of the Project Site. No further response is needed. A1-4 As discussed above, the NOP comment letter dated September 13, 216, was inadvertently left out of the DEIR. Responses to this letter have been provided in Response to Comments A1-1 through A1-3. Additionally, this letter has been incorporated into the EIR. DEIR Chapter 2, Introduction, page 2-3, has been revised as follows; added text is indicated in underline and deleted text in strikeout: Table 2-1 Commenting Agency/Person Airport Land Use Commission for Orange County NOP Comment Summary Date Comment Type Comment Summary Issue Addressed In: 9/13/216 Airport-Related Hazards The project site is outside of the noise impact zones, clear zone, and height restriction zone for John Wayne Airport Projects developing structures over 2 feet high above ground level are required to file require a Notice of Proposed Construction or Alteration pursuant to Federal Aviation Administration regulations. Proposals to develop new heliports must be submitted to the Airport Land Use Commission for review and approval Appendix A, Initial Study March 217 Page 2-7 Page 13 of 186

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15 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments LETTER A2 California Department of Transportation District 12 (2 pages) March 217 Page 2-9 Page 15 of 186

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17 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A2. Response to Comments California Department of Transportation District 12, dated February 6, 217. A2-1 This comment summarizes the project description and provides and introduction to the comments that are meant to address surrounding Caltrans facilities and the State s smart mobility goals. No further response is needed. A2-2 The commenter requests that the DEIR traffic analysis include an analysis of the AM and PM peak hour traffic counts at Grand Avenue/Santa Ana Boulevard interchange on I-5 and 95th percentile queues of the off-ramps and left-turn lanes to the on-ramp for the existing condition and with project conditions. Pursuant to the commenter s request, IBI performed this analysis and prepared a Traffic Study Addendum (Appendix A of this FEIR). This information has been incorporated into the EIR. As demonstrated in the analysis provided below and in Appendix A of this FEIR, impacts to freeway facilities would be less than significant. DEIR Section 5.9.2, Thresholds of Significance, Page , is hereby revised as follows; added text is indicated in underline and deleted text in strikeout: Caltrans Ramp Intersections The intersection level of service (LOS) utilizes the Highway Capacity Manual 21 (HCM 21) operations methodology consistent with Caltrans Traffic Impact Study Guideline (22). The HCM 21 operations methodology for signalized intersections evaluates LOS based on controlled delay per vehicle. Caltrans uses the transition between LOS C and LOS D as the threshold of acceptability. Caltrans also acknowledges that if an existing State highway facility is operating worse than the appropriate target LOS, the existing LOS should be maintained. The Caltrans Route Concept Report for Interstate Route 5 (I-5) San Diego/Santa Ana Freeway, shows that the existing and forecasted peak hour LOS for the segment of I-5 from SR-55 to the SR-22/57 is LOS F1 and F3, respectively. Since the I-5 is operating at worse than LOS C, a significant impact would occur to Caltrans ramp intersections if the project: Degrades level of service from an acceptable LOS C or better to LOS D, E, or F; or Degrades the level of service on a facility operating at an unacceptable level to a worse level of service (e.g. LOS D to E; LOS E to F). DEIR Section 5.9.3, Thresholds of Significance, Page , is hereby revised as follows; added text is indicated in underline and deleted text in strikeout: March 217 Page 2-11 Page 17 of 186

18 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments Impact 5.9-4: T-1] The FSP Project would not impact the freeway system. [Threshold Impact Analysis: Freeway Ramp/Intersections Traffic impacts to the freeway system were evaluated using the criteria in the Caltrans Guide for the Preparation of Traffic Impact Studies (22) for freeway mainline and ramp facilities. As shown in Table , all freeway ramps and intersections would operate at acceptable LOS under No Project and With Project for the Opening Year (221) and Future Year (235). Table Intersection Intersection Analysis 27 Santa Ana Blvd & I-5 SB Ramp 28 Santa Ana Blvd & Grand Ave 29 Grand Ave & I-5 NB Ramp Source: IBI 217. Intersection analysis conducted using HCM 21. Peak Hour Opening Year No Project Delay (seconds) LOS Opening Year With Project Delay (seconds) LOS Future 235 No Project Delay (seconds) LOS Future 235 With Project Delay (seconds) LOS AM 15.3 B 15.4 B 16.5 B 16.9 B PM 16.5 B 16.8 B 18. B 18.9 B AM 36.4 D 36.7 D 42.4 D 43.7 D PM 3.1 C 3.3 C 33.5 C 34. C AM 14. B 14.3 B 14.8 B 15.5 B PM 12. B 12.1 B 12.9 B 13.2 B Freeway Ramp Queuing Analysis A queuing assessment was completed for freeway ramps in the study area to ensure that traffic does not back up onto mainline freeway lanes. Ramps evaluated as part of the queuing assessment include: Santa Ana Boulevard & I-5 southbound ramp, 2. Santa Ana Boulevard & Grand Avenue, and Grand Avenue & I-5 northbound ramp. Table , summarizes queueing under Opening Year 221 and Future 235, Without and With Project conditions. Under both scenarios, queues are well within storage capacity on the off-ramps, therefore impacts are considered less than significant. Page 2-12 PlaceWorks Page 18 of 186

19 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments Table Intersection Santa Ana Blvd & I-5 SB Ramp I-5 Ramp Queue Queue Capacity (ft) 1, 28 Santa Ana Blvd & Grand Ave 1,2 29 Grand Ave & I-5 NB Ramp 1,4 Source: IBI 217. Intersection analysis conducted using HCM 21. Queue length 95th percentile. Opening Year 221 Max Length (ft) Future 235 Max Length (ft) Peak Hour No Project With Project No Project With Project AM PM AM PM AM PM A2-3 The County acknowledges Caltrans appreciation of the analysis in the DEIR related to VMT, TDM strategies and programs, and VMT reductions. A2-4 A Traffic Impact Analysis (TIA) was prepared for the proposed project by IBI Group (IBI). IBI consulted with the City of Santa Ana to confirm the study area, methodology and assumptions to use in the TIA. As discussed in Response to Comment A2-2, the proposed project would not result in significant impacts to the I-5 ramps at Santa Ana Boulevard/Grand Avenue interchange. On December 2, 214, the City of Santa Ana approved the Santa Ana Grade Separation Project Report Equivalent (PRE), which was required prior to qualification for design and construction funding. The PRE analyzed the best geometric alignment and cost estimates to grade separate the existing at-grade crossing of Santa Ana Boulevard with the Southern California Regional Rail Authority (SCRRA) double tracks. The purpose of the grade separation project is the alleviate congestion and minimize potential conflicts between trains, vehicles, and pedestrians. The traffic study prepared for the PRE determined that the grade separation project would not result in significant impacts to study area intersections, ramps, or roadway segments; and would reduce congestion along Santa Ana Boulevard (Santa Ana 214). This project would provide a benefit to traffic and circulation in the study area and would not be impacted by the County s proposed FSP Project. A2-5 The County will continue to coordinate with the City of Santa Ana and OCTA on existing and proposed TDM strategies. March 217 Page 2-13 Page 19 of 186

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21 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments LETTER A3 City of Irvine (1 page) March 217 Page 2-15 Page 21 of 186

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23 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A3. Response to Comments from the City of Irvine, dated January 3, 217. A3-1 The commenter requests that the County clarify the percentage traffic distribution onto Dyer Road, Barranca Parkway, MacArthur Boulevard, and Main Street. Trip distribution percentage forecasts in the AM and PM peak hours for the roadways cited by the City of Irvine in the comment are: 3 percent along Dyer Rd (1/3 of the 3 percent will continue onto Barranca Parkway into Irvine equate to 1 percent of total trips) 2 percent will travel along MacArthur Boulevard 1 percent will continue along Main Street For the Phase 1 project, these percentages equate to less than 1 peak hour trips within the City of Irvine portions of these roadways. In the buildout condition, these percentages are less than 25 peak hour trips within the City of Irvine portions of these roadways. Given the low volumes, no significant traffic impacts are anticipated. IBI reviewed traffic data from the most recent traffic study (Heritage Mixed Use Project, City of Irvine) dated July 215 for level of service data at three intersections closest to the project site within City of Irvine boundaries and corresponding to the commenters request to analyze Dyer Road, Barranca Parkway, MacArthur Boulevard, and Main Street. Traffic counts at the intersections of Red Hill at Dyer Road/Barranca Parkway, Red Hill Avenue at MacArthur Boulevard, and Red Hill Avenue at Main Street were taken in November/December of 214 and January/March 215. The minimum acceptable level of service for these intersections is LOS E. 1 The level of service under existing and future year (235) without project conditions are provided below: Red Hill Avenue and Dyer Road/Barranca Parkway Existing AM (LOS A) and PM (LOS C) Future AM (LOS B) and PM (LOS D) Red Hill Avenue and MacArthur Boulevard Existing AM (LOS B) and PM (LOS C) Future AM (LOS C) and PM (LOS D) Red Hill Avenue and Main Street Existing AM (LOS B) and PM (LOS D) Future AM (LOS B) and PM (LOS C) 1 These intersections are within the Irvine Business Complex. March 217 Page 2-17 Page 23 of 186

24 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments Based the proposed project s trip generation and the existing and future level of service at the intersections identified above, project generated trips are insignificant at these locations. No significant traffic impacts would occur. Page 2-18 PlaceWorks Page 24 of 186

25 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments LETTER A4 City of Santa Ana (2 pages) March 217 Page 2-19 Page 25 of 186

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27 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A4. Responses to Comments from the City of Santa Ana, dated February 6, 217. A4-1 The comment asserts that further architectural studies are needed for buildings over 5 years old. Buildings 14 and 16 were built in 1955, Building 12 before 1959, and 433 West Civic Center Drive in 1957; the remainder of the buildings onsite are less than 5 years old. The buildings that would be demolished were evaluated for historical significance by Chambers Group Inc. in a report dated October 216 and included as Appendix D of the DEIR. The evaluation was prepared by Joel Levanentz, a Secretary of Interior Professional Qualified Archaeologist, Historian and Architectural Historian. None of the buildings were determined to be historically significant or eligible for listing on the California Register of Historic Resources. The historical evaluation of the aforementioned buildings met the requirements of CEQA, and no further analysis is necessary. The comment states that further architectural studies are needed but it does not specifically state what additional study or analysis is needed. Since the buildings on site were evaluated by an architectural historian and were not determined to be historical resources, no further studies are required. A4-2 The comment expresses concerns about exposure of lead-based paint (LBP) and asbestos-containing materials (ACM) to persons or schools near the project site during demolition. The following schools, all in the city of Santa Ana, are located within.25 mile of the project site: Orange County Educational Arts Academy (K-8), 825 North Broadway, is located about 475 feet north-northeast of Building 12. Orange County School of the Arts (OCSA) (7-12), 11 North Main Street, is located about 575 feet northeast of Building 12. El Sol Santa Ana Science and Arts Academy (K-8), 11 North Broadway, is located about 77 feet north of Building 12 (Google Earth Pro 217). During demolition, lead-based paint (LBP) and asbestos-containing materials (ACM) would be abated, contained, and disposed of in accordance with federal, state, and local regulations. South Coast Air Quality Management District (SCAQMD) regulations including those of the EPA (which regulates disposal), US Occupational Safety and Health Administration, US Department of Housing and Urban Development, California Division of Occupational Safety and Health (Cal/OSHA) (which regulates employee exposure), and South Coast Air Quality Management District (SCAQMD). Lead hazards in Santa Ana are assessed and abated as necessary in accordance with several state laws and regulations and the Federal Residential Lead-Based Paint Hazard Reduction Act of Asbestos hazards are assessed and abated as necessary in accordance with California Code of Regulations, Title 8, Section Compliance with these regulations ensures that ACMs and LBPs are safely removed, contained, and March 217 Page 2-21 Page 27 of 186

28 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments disposed of in a manner that minimizes exposure. Additionally, Mitigation Measure HAZ-2 has been incorporated into the project require planning, monitoring, oversight, and reporting by a certified consultant. With these measures impacts would be less than significant. A4-3 The comment expresses concerns about exposure of homeless persons to LBP and/or ACM during demolition. The Santa Ana Police Department has three specialized units providing public safety services in downtown Santa Ana, including the Civic Center, in addition to regular patrol and traffic operations: the Civic Center Patrol Unit, staffed with one corporal and six officers; the Downtown Business Liaison Unit, staffed with four officers; and the Mounted Enforcement Unit. In addition, the County of Orange owns a homeless shelter ( the Courtyard ) at 4 Santa Ana Boulevard, opposite Santa Ana Boulevard from the southwest side of the Superblock, that is operated by Midnight Mission under contract with the County. Opened in October 216, the shelter has capacity for 4 people. As discussed in Section 5.5, Hazards and Hazardous Materials, impacts related to demolition would be less than significant (see also Response to Comment A4-2). Pursuant to standard protocol, the buildings would be fenced off prior to demolition and notification of demolition activities would be placed on site. A4-4 The comment conveys concerns about exposure of ACM and/or LBP to persons at the Santa Ana Main Library during project demolition activities. The Santa Ana Main Library is at 26 Civic Center Plaza opposite Ross Street from the northwest corner of the Superblock. Refer to Responses to Comments A4-2 and A4-3. Pursuant to standard protocol, the buildings would be fenced off prior to demolition and notification of demolition activities would be placed on site. A4-5 This comment does not relate to the adequacy of the DEIR or a potentially significant environmental impact. However, the comment is acknowledged and will be provided to the decision-makers Board of Supervisors for their consideration of the project. A4-6 An analysis of parking spaces is not an issue required to be addressed under CEQA. However, provided below as a courtesy, is a summary of parking supply and demand. For parking management purposes, the County requires 1.25 employees per stall. As shown in the table below, the proposed project would provide a net surplus of parking spaces. Buildout of the project would result in a net increase of 1,515 employees in the Superblock, H.G. Osborne building, and 41 W. Civic Center, requiring 1,272 parking spaces. The FSP Project would provide 3,63 spaces, resulting in a net surplus of 2,331 parking spaces. Page 2-22 PlaceWorks Page 28 of 186

29 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments Total Parking Supply and Demand at FSP Buildout Building Proposed Net New Employees Required Parking * Proposed New Parking Net Surplus Superblock (Buildings 1, 12, 14, and 16) H.G. Osborne (3 N. Flower Street) 1,59 1,272 2,643 1, W Civic Center Total 1,515 1,272 3,63 2,331 * County of Orange requires a parking ratio of 1.25 employees per stall. March 217 Page 2-23 Page 29 of 186

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31 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments LETTER A5 City of Tustin (2 pages) March 217 Page 2-25 Page 31 of 186

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33 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A5. Response to Comments from City of Tustin, dated February 6, 217. A5-1 The commenter does not specifically raise an issue with the DEIR, but raises a question on the methodology used for the project trip generation and assignment used in the traffic study. For clarification, the FSP Project proposes to consolidate government office buildings in one location and is primarily intended to house existing employees in the Civic Center. These employees would either be moved to the new buildings as these are constructed and replace existing buildings on-site, or employees would be relocated to the project site from other off-site buildings in the Civic Center. As described in the DEIR (see Pages and , and Appendix I), although the project would result in a net increase in building square footage, the majority of new employees are already existing within the downtown area (1,515 net new employees; 1,1 employees currently existing in the area). However, in order to provide a conservative analysis, trip generation forecasts are based on the Institute of Transportation Engineers (ITE) Trip Generation Manual, 9th Edition. The trip generation forecasts contained in the traffic study represent the net new trips resulting from the net new square footage for the proposed government office buildings. Trip distribution forecasts are based on actual employee trip data obtained from OCTA employee commute trip origin-destination surveys. Further responses regarding trip distribution are provided in Response to Comment A5-2. A5-2 The trip distribution percentages shown in Figure 3-1 are correct. The City of Tustin requests further explanation of AM peak hour inbound trips and PM peak hour outbound trips at intersections #2, 4, 9, 15, 18, 2, and 25. To see the full accounting of inbound and outbound trips to the east of the project site, intersection #22 must also be included, as 3rd Street is anticipated to receive some project generated traffic that would eventually reach 4th Street and 1st Street. Further, there are trips at intersections #18 and 2 that are not forecast to travel through these intersections in the eastbound direction, but would turn eastbound at other locations (such as 4th and Birch) to travel eastbound. Trip distribution on Santa Ana Boulevard east of the study intersections is forecast to be 145 trips (19 percent) and 1 trips on both 4th Street and 1st Street (13 percent). The detailed trip distributions are broken down as follows: Santa Ana Boulevard (19 percent) 2 percent are local trips distributed to areas along Santa Ana Boulevard between the project site and I-5 13 percent are regional trips accessing I-5 (7 percent north and 6 percent south) 4 percent uses Grand Avenue to travel north or south March 217 Page 2-27 Page 33 of 186

34 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments 4th Street (13 percent) 4 percent uses Grand Avenue to travel north or south 8 percent are regional trips accessing I-5 (4 percent north and 4 percent south) 1 percent continues eastward along 4th Street past I-5 and enters Tustin 1st Street (13 percent) 4 percent uses Grand Avenue to travel north or south 8 percent are regional trips accessing I-5 (4 percent north and 4 percent south) 1 percent continues eastward along 4th Street past I-5 and enters Tustin A5-3 Future No Project traffic volumes were derived by using an anticipated growth rate of.5 percent for traffic in the project study area. This annual grow rate for traffic is consistent with Santa Ana General Guidelines for Traffic Impact Studies, the 21 City of Santa Ana Transit Zoning Code EIR which analyzed intersections in a similar location as this study and OCTA traffic model (OCTAM) forecasts for roadways in the study area. The Santa Ana Civic Center area is generally built out and substantial increases in background traffic volumes are not anticipated between the existing condition and project build out. Project trip generation forecasts were addressed in Response to Comment A5-1 above. In examining project trip distribution at the intersections identified by the City of Tustin in this comment, it is estimated that peak hour trips generated by the project traveling through these three intersections would be less than one percent of peak hour trips at any one intersection. Given the low resulting peak hour volumes (<1 trips), analysis of these intersections is not warranted. A5-4 Responses to Comments A5-1 through A5-3 address the discrepancies suggested by the commenter. Since project traffic volumes at City of Tustin intersections would decrease to less than one percent resulting in less than 1 peak hour trips, no new impacts are anticipated and an expanded study area is not warranted. In order to provide the most accurate trip distribution, survey data was obtained from OCTA (see Response to Comment A5-1) and a.5 percent growth rate was used. However, as noted in Response to Comment A5-3, the future no project traffic volumes were checked against OCTAM forecasts to ensure consistency with regional growth forecasts. Future no project traffic volumes used in the traffic impact analysis were generally consistent or even higher than those forecast in the OCTAM (see Appendix I of the DEIR). Page 2-28 PlaceWorks Page 34 of 186

35 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments LETTER A6 Native American Heritage Commission (5 pages) March 217 Page 2-29 Page 35 of 186

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41 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A6. Response to Comments from Native American Heritage Commission, dated February 2, 217. A6-1 The comment states that the language about curation in Mitigation Measure CUL-1 may not be appropriate with respect to tribal cultural resources. DEIR Section 5.2, Cultural Resources, Page , Mitigation Measure CUL-1 is hereby revised as follows in response to Comment A6-1; added text is indicated in underline and deleted text in strikeout: Prior to the start of demolition or ground disturbance activities, the County of Orange, County Executive Office or his/her designee shall ensure that a County-certified archeologist has been retained for the project and will be on call during all grading and other significant ground-disturbing activities. Should any evidence of archaeological resources be discovered, the following measures shall be taken: All below grade work shall stop within a 5-foot radius of the discovery. Work shall not continue until the discovery has been evaluated by a qualified archaeologist. A qualified archaeologist shall assess the find(s) and determine if they are of value. If the find(s) are of value then: The archaeologist shall draft a monitoring program and monitor all grounddisturbing activities related to the FSP Project. The contractor shall prepare all potential finds in excavated material to the point of identification. Significant archaeological resources found shall be preserved as determined necessary by the archaeologist. Excavated finds, except for those determined to be a tribal cultural resource, shall be offered to the County of Orange or its designee for curation on a first-refusal basis. After which, finds shall be offered to a local museum or repository willing to accept the resource. If the resource is determined to be a tribal cultural resource, the County of Orange shall consult with a tribal representative, and disposition of the resource shall be at the discretion of the representative. Within 3 days of completion of earth-moving activities, the archeologist shall draft a report summarizing the finds and shall include the inspection period, an analysis of any resources found, and the present repository of the items. The County Executive Office or his/her designee shall confirm that the archaeologist s report has been approved by the County construction engineer. Any resulting reports shall also be filed with the County and with the South Central Coastal Information Center at the California State University, Fullerton. March 217 Page 2-35 Page 41 of 186

42 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A6-2 The comment states that with respect to human remains, the most likely descendant and not the Native American Heritage Commission (NAHC) provides recommendations for the disposition and treatment of human remains. DEIR Section 5.2, Cultural Resources, Page 5.2-3, is revised as follows; added text is indicated in underline and deleted text in strikeout: Section 752 of the Health and Safety Code states that the disturbance of Native American cemeteries is a felony. Section 75.5 requires that construction or excavation be stopped in the vicinity of discovered human remains until the County Coroner can determine whether the remains are those of a Native American. Section 75.5(b) outlines the procedures to follow should human remains be inadvertently discovered in any location other than a dedicated cemetery. The section also states that the County Coroner, upon recognizing the remains as being of Native American origin, is responsible to contact the NAHC within 24 hours. The NAHC has various powers and duties to provide for the ultimate disposition of any Native American remains, as does the assigned most likely descendant. The NAHC shall immediately notify the most likely descendant, who may recommend means for treatment and disposition to the owner or the person responsible for the excavation. A6-3 The comment summarizes some requirements of CEQA respecting historical resources. Historical resources were fully evaluated in Section 5.2, Cultural Resources, of the DEIR. The comment does not address the adequacy of the EIR and no response is required. A6-4 The comment summarizes some provisions of AB 52 (Chapter 532, Statutes of 214) and SB 18 (California Government Code Sections et seq.). Tribal cultural resources, including Native American consultations, were fully evaluated in Section 5.1, Tribal Cultural Resources. The comment does not address the adequacy of the EIR and no response is required. A6-5 The comment summarizes the requirements of AB 52, SB 18, and recommendations for analyzing and mitigating cultural resources. This summary is provided for informational purposes. The comment does not address the adequacy of the EIR and no response is required. Page 2-36 PlaceWorks Page 42 of 186

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45 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A7. Response to Comments from Orange County Transportation Authority, dated February 6, 217. A7-1 The comment requests a correction in the DEIR regarding bus routes that serve the project site and vicinity. DEIR Section 5.9, Transportation and Traffic, Page 5.9-1, is hereby revised as follows in response to Comment A7-1; added text is indicated in underline and deleted text in strikeout: There are several bus stops in the vicinity of the project area. Six bus stops are adjacent to the superblock and County satellite buildings at 41 and 433 W. Civic Center Drive and one bus stop is adjacent to the H.G. Osborne building. Several other bus stops are within walking distance of the site. OCTA bus routes 55, 83, 26, and 462 serve the project site. Route 53 passes near the site on Main Street; Route 64 passes near the site on First Street; and Route 15 passes near the site on Flower Street. Bus routes serving the project area include OCTA routes 51, 53, 55, 64, 83, 84, 145, 26, 462 and 757. These routes provide connections to several areas countywide. A7-2 The County of Orange will work with OCTA during construction activities to minimize potential impacts to OCTA bus services operating on Santa Ana Boulevard and Civic Center Drive. Construction activities associated with the project may require temporary lane closures on these roadways, which would be coordinated with OCTA in advance of the construction activity to allow for detours or temporary stop relocations to occur. A7-3 Figure 5.9-3, Existing and Planned Transit Routes, in the DEIR has been updated to include the bus routes at each OCTA bus stop shown on the map. A7-4 The comment recommends that the project evaluate consistency with the following documents and their active transportation plans: Districts 1 and 2 Bikeways Strategy (OCTA 213) Santa Ana Downtown Complete Streets Plan (Santa Ana 216) Draft Santa Ana Safe Mobility Plan (Santa Ana 216) The traffic impact analysis for the proposed project considered the above listed documents and plans identified by OCTA. The documents specify various complete streets improvements such as buffered bicycle lanes throughout the City of Santa Ana. As it relates to the traffic impact study these transportation strategies identified within the study area were considered and incorporated into the analysis; i.e. pertinent to the traffic impact study, the reduction of three lanes to two lanes along Santa Ana Blvd was included in the analysis. The proposed project would also be consistent with the existing and planned active transportation strategies on roadways surrounding the superblock site. For example, there are proposed bicycle lanes on Ross Street between First Street and Civic Center Drive. Installing bicycle lanes may require removal of the existing two March 217 Page 2-39 Page 45 of 186

46 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments way left turn lane. Due to the low existing and proposed traffic volumes on Ross Street, removal of the two way left turn lane would not affect levels of surface.. DEIR Section 5.9, Transportation and Traffic, Page 5.9-1, is hereby revised as follows; added text is indicated in underline and deleted text in strikeout: There are no existing bike lanes adjacent to the superblock site or County satellite buildings. Future plans for the project area, separate from this project, include modifying the existing street network by reducing Santa Ana Boulevard from three travel lanes in each direction to two travel lanes in order to install protected bicycle lanes along Santa Ana Boulevard. Buffered bicycle lanes have been installed on Civic Center Drive by the City of Santa Ana in accordance with the Draft Districts 1 and 2 Bikeways Strategy issued by OCTA in 213 (OCTA 213). Cycle tracks are proposed on Santa Ana Boulevard and Ross Street in the Santa Ana Downtown Complete Streets Plan issued by the City of Santa Ana in 216 (Santa Ana 216). Protected bicycle lanes are also recommended on Ross Street between First Street and Civic Center Drive and First Street in the Santa Ana Safe Mobility Plan issued by the City of Santa Ana in 216 (Santa Ana 216b). There is an existing enclosed bicycle parking facility (bike hut), and additional planned bicycle racks, onsite. OCTA and Santa Ana have planned Class II bicycle facilities on Civic Center Drive and Santa Ana Boulevard, an existing bike hut, and proposed bike racks at the Civic Center. A7-5 DEIR Section 5.9, Transportation and Traffic, Page 5.9-6, is hereby revised as follows; added text is indicated in underline and deleted text in strikeout: Santa Ana Boulevard is classified as a Major Arterial (between Raitt Street and Ross Street), a Secondary Arterial (between Ross Street to French Street) 2, and a Primary Arterial (between FrenchRoss Street and Grand Avenue). The roadway fluctuates between a four-lane undivided roadway (Raitt Street to Flower Street), and a six-lane divided roadway (Flower Street to Ross Street), and a three-lane one-way roadway (Ross Street to French Street). On-street parking is permitted along certain segments of the corridor. There are currently no bike lanes or bike routes provided. Several OCTA bus routes serve this corridor, including Routes 84, 145, and 26 with approximately 3-45 minute headways. A7-6 MPAH reclassifications are noted. The traffic impact analysis study intersection lane configurations are consistent with the conditionally approved roadway classifications noted by OCTA. 2 An amendment to the Master Plan of Arterial Highways was conditionally approved by the OCTA Board on July 25, 216 to reclassify the following segments of Santa Ana Boulevard: 1) between Rait Street and Flower Street from a Major to a Divided Collector; 2) between Flower Street and Ross Street from a Major to a Primary; 3) between French Street and Santiago Street from a Primary to a Divided Collector. Page 2-4 PlaceWorks Page 46 of 186

47 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A7-7 Please note that the City of Santa Ana is in the process of updating its General Plan Mobility Element, which has not yet been adopted. The County of Orange has been in contact with City of Santa Ana to confirm the appropriate future lane configurations for analysis in this traffic impact study. The traffic impact analysis reflects input received from the City.. March 217 Page 2-41 Page 47 of 186

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59 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 2. Response to Comments A8. Response to Comments from State Clearinghouse, dated February 7, 217. A8-1 The State Clearinghouse acknowledges the County s compliance with the CEQA public review requirements and submitted letters received from Caltrans and NAHC. These comment letters are addressed in Responses to Comment Letters A2 and A6. No further response is needed. March 217 Page 2-53 Page 59 of 186

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61 3. Revisions to the Draft EIR 3.1 INTRODUCTION This section contains revisions to the DEIR based upon (1) additional or revised information required to prepare a response to a specific comment; (2) applicable updated information that was not available at the time of DEIR publication; and/or (3) typographical errors. This section also includes additional mitigation measures to fully respond to commenter concerns as well as provide additional clarification to mitigation requirements included in the DEIR. The provision of these additional mitigation measures does not alter any impact significance conclusions as disclosed in the DEIR. Changes made to the DEIR are identified here in strikeout text to indicate deletions and in underlined text to signify additions. 3.2 DEIR REVISIONS IN RESPONSE TO WRITTEN COMMENTS The following text has been revised in response to comments received on the DEIR. Page 2-3, Chapter 2, Cultural Resources, is revised in response to Comment A1-5 from the Airport Land Use Commission for Orange County. Table 2-1 Commenting Agency/Person Airport Land Use Commission for Orange County NOP Comment Summary Date Comment Type Comment Summary Issue Addressed In: 9/13/216 Airport-Related Hazards The project site is outside of the noise impact zones, clear zone, and height restriction zone for John Wayne Airport Projects developing structures over 2 feet high above ground level are required to file require a Notice of Proposed Construction or Alteration pursuant to Federal Aviation Administration regulations. Proposals to develop new heliports must be submitted to the Airport Land Use Commission for review and approval Appendix A, Initial Study March 217 Page 3-1 Page 61 of 186

62 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 3. Revisions to the Draft EIR Page , Section 5.2, Cultural Resources. Mitigation measure CUL-1 is revised in response to Comment A6-1, from the Native American Heritage Commission. CUL-1 Prior to the start of demolition or ground disturbance activities, the County of Orange, County Executive Office or his/her designee shall ensure that a County-certified archeologist has been retained for the project and will be on call during all grading and other significant ground-disturbing activities. Should any evidence of archaeological resources be discovered, the following measures shall be taken: All below grade work shall stop within a 5-foot radius of the discovery. Work shall not continue until the discovery has been evaluated by a qualified archaeologist. A qualified archaeologist shall assess the find(s) and determine if they are of value. If the find(s) are of value then: The archaeologist shall draft a monitoring program and monitor all grounddisturbing activities related to the FSP Project. The contractor shall prepare all potential finds in excavated material to the point of identification. Significant archaeological resources found shall be preserved as determined necessary by the archaeologist. Excavated finds, except for those determined to be a tribal cultural resource, shall be offered to the County of Orange or its designee for curation on a first-refusal basis. After which, finds shall be offered to a local museum or repository willing to accept the resource. If the resource is determined to be a tribal cultural resource, the County of Orange shall consult with a tribal representative, and disposition of the resource shall be at the discretion of the representative. Within 3 days of completion of earth-moving activities, the archeologist shall draft a report summarizing the finds and shall include the inspection period, an analysis of any resources found, and the present repository of the items. The County Executive Office or his/her designee shall confirm that the archaeologist s report has been approved by the County construction engineer. Any resulting reports shall also be filed with the County and with the South Central Coastal Information Center at the California State University, Fullerton. Page 3-2 PlaceWorks Page 62 of 186

63 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 3. Revisions to the Draft EIR Page 5.2-3, Section 5.2, Cultural Resources, is revised in response to Comment A6-2 from the Native American Heritage Commission Section 752 of the Health and Safety Code states that the disturbance of Native American cemeteries is a felony. Section 75.5 requires that construction or excavation be stopped in the vicinity of discovered human remains until the County Coroner can determine whether the remains are those of a Native American. Section 75.5(b) outlines the procedures to follow should human remains be inadvertently discovered in any location other than a dedicated cemetery. The section also states that the County Coroner, upon recognizing the remains as being of Native American origin, is responsible to contact the NAHC within 24 hours. The NAHC has various powers and duties to provide for the ultimate disposition of any Native American remains, as does the assigned most likely descendant. The NAHC shall immediately notify the most likely descendant, who may recommend means for treatment and disposition to the owner or the person responsible for the excavation. Page 5.9-6, Section 5.9, Transportation and Traffic, is revised in response to Comment A7-5 from the Orange County Transportation Authority. Santa Ana Boulevard is classified as a Major Arterial (between Raitt Street and Ross Street), a Secondary Arterial (between Ross Street to French Street) 3, and a Primary Arterial (between FrenchRoss Street and Grand Avenue). The roadway fluctuates between a four-lane undivided roadway (Raitt Street to Flower Street), and a six-lane divided roadway (Flower Street to Ross Street), and a three-lane one-way roadway (Ross Street to French Street). On-street parking is permitted along certain segments of the corridor. There are currently no bike lanes or bike routes provided. Several OCTA bus routes serve this corridor, including Routes 84, 145, and 26 with approximately 3-45 minute headways. Page 5.9-1, Section 5.9, Transportation and Traffic, is revised in response to Comment A7-4 from the Orange County Transportation Authority. Existing Bicycle Facilities There are no existing bike lanes adjacent to the superblock site or County satellite buildings. Future plans for the project area, separate from this project, include modifying the existing street network by reducing Santa Ana Boulevard from three travel lanes in each direction to two travel lanes in order to install protected bicycle lanes along Santa Ana Boulevard. Buffered bicycle lanes have been installed on Civic Center Drive by the City of Santa Ana in accordance with the Draft Districts 1 and 2 Bikeways Strategy issued by OCTA in 213 (OCTA 213). Cycle tracks are proposed on Santa Ana Boulevard and Ross Street in the Santa Ana Downtown Complete Streets Plan issued by the City of Santa Ana in 216 (Santa Ana 216). Protected bicycle lanes are also recommended on Ross Street between First Street and Civic Center Drive and First 3 An amendment to the Master Plan of Arterial Highways was conditionally approved by the OCTA Board on July 25, 216 to reclassify the following segments of Santa Ana Boulevard: 1) between Rait Street and Flower Street from a Major to a Divided Collector; 2) between Flower Street and Ross Street from a Major to a Primary; 3) between French Street and Santiago Street from a Primary to a Divided Collector. March 217 Page 3-3 Page 63 of 186

64 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 3. Revisions to the Draft EIR Street in the Santa Ana Safe Mobility Plan issued by the City of Santa Ana in 216 (Santa Ana 216b). There is an existing enclosed bicycle parking facility ( bike hut ), and additional planned bicycle racks, onsite. OCTA and Santa Ana have planned Class II bicycle facilities on Civic Center Drive and Santa Ana Boulevard, an existing bike hut, and proposed bike racks at the Civic Center.. Page 5.9-1, Section 5.9, Transportation and Traffic, is revised in response to Comment A7-1 from the Orange County Transportation Authority. Existing Transit Facilities There are several bus stops in the vicinity of the project area. Six bus stops are adjacent to the superblock and County satellite buildings at 41 and 433 W. Civic Center Drive and one bus stop is adjacent to the H.G. Osborne building. Several other bus stops are within walking distance of the site. OCTA bus routes 55, 83, 26, and 462 serve the project site. Route 53 passes near the site on Main Street; Route 64 passes near the site on First Street; and Route 15 passes near the site on Flower Street. Bus routes serving the project area include OCTA routes 51, 53, 55, 64, 83, 84, 145, 26, 462 and 757. These routes provide connections to several areas countywide. Page , Section 5.9, Transportation and Traffic, is revised in response to Comment A2-2 from Caltrans. Caltrans Ramp Intersections The intersection level of service (LOS) utilizes the Highway Capacity Manual 21 (HCM 21) operations methodology consistent with Caltrans Traffic Impact Study Guideline (22). The HCM 21 operations methodology for signalized intersections evaluates LOS based on controlled delay per vehicle. Caltrans uses the transition between LOS C and LOS D as the threshold of acceptability. Caltrans also acknowledges that if an existing State highway facility is operating worse than the appropriate target LOS, the existing LOS should be maintained. The Caltrans Route Concept Report for Interstate Route 5 (I-5) San Diego/Santa Ana Freeway, shows that the existing and forecasted peak hour LOS for the segment of I-5 from SR-55 to the SR- 22/57 is LOS F1 and F3, respectively. Since the I-5 is operating at worse than LOS C, a significant impact would occur to Caltrans ramp intersections if the project: Degrades level of service from an acceptable LOS C or better to LOS D, E, or F; or Degrades the level of service on a facility operating at an unacceptable level to a worse level of service (e.g. LOS D to E; LOS E to F). Page 3-4 PlaceWorks Page 64 of 186

65 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 3. Revisions to the Draft EIR Page , Section 5.9, Transportation and Traffic, is revised due to a typographical error. Consistency with SB 743 As stated in Section , Regulatory Framework, SB 743 started a process that could fundamentally change transportation impact analysis as part of CEQA compliance. These changes in many parts of California (if not statewide) will include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts. As part of the new CEQA Guidelines, the new criteria shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses (Public Resources Code Section 2199(b)(1)). Certification of the new guidelines are expected in early 217. However, since OPR has not yet amended the CEQA Guidelines to implement this change, automobile delay is still an appropriate threshold, and the County of Orange and City of Santa Ana will continue to use the established LOS criteria to determine traffic impacts. A VMT analysis was conducted for informational purposes to identify the project s contribution to the regional VMT under buildout (235) conditions (see Appendix I). The methodology to determine VMT was described under Section 5.9.3, Environmental Impacts, Methodology, Vehicle Miles Traveled. As described, two methodologies were used to characterize VMT associated with the project. First, by only evaluating the net increase of employees at the FSP Project site, the net increase in VMT would be approximately 3,3183,316 to 7,227,217. Calculations are provided in Table Table FSP Project VMT based on Employees Average Trip TDM VMT Reductions Employees Length Total VMT Low High Existing 2, ,5937, Proposed 3, ,262, Net Increase 1,515 24,94324, Employee from within Downtown 1, (16,675) - - Total Net Increase 55 8,3388,321 7,227,26 3,3182,197 Source: IBI 216 Page , Section 5.9, Transportation and Traffic, is revised in response to Comment A2-2 from Caltrans. March 217 Page 3-5 Page 65 of 186

66 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 3. Revisions to the Draft EIR Impact 5.9-4: The FSP Project would not impact the freeway system. [Threshold T-1] Impact Analysis: Freeway Ramp/Intersections Traffic impacts to the freeway system were evaluated using the criteria in the Caltrans Guide for the Preparation of Traffic Impact Studies (22) for freeway mainline and ramp facilities. As shown in Table , all freeway ramps and intersections would operate at acceptable LOS under No Project and With Project for the Opening Year (221) and Future Year (235). Table Intersection Intersection Analysis 27 Santa Ana Blvd & I-5 SB Ramp 28 Santa Ana Blvd & Grand Ave 29 Grand Ave & I-5 NB Ramp Source: IBI 217. Intersection analysis conducted using HCM 21. Peak Hour Opening Year No Project Delay (seconds) LOS Opening Year With Project Delay (seconds) LOS Future 235 No Project Delay (seconds) LOS Future 235 With Project Delay (seconds) LOS AM 15.3 B 15.4 B 16.5 B 16.9 B PM 16.5 B 16.8 B 18. B 18.9 B AM 36.4 D 36.7 D 42.4 D 43.7 D PM 3.1 C 3.3 C 33.5 C 34. C AM 14. B 14.3 B 14.8 B 15.5 B PM 12. B 12.1 B 12.9 B 13.2 B Freeway Ramp Queuing Analysis A queuing assessment was completed for freeway ramps in the study area to ensure that traffic does not back up onto mainline freeway lanes. Ramps evaluated as part of the queuing assessment include: Santa Ana Boulevard & I-5 southbound ramp, 2. Santa Ana Boulevard & Grand Avenue, and Grand Avenue & I-5 northbound ramp. Table , summarizes queueing under Opening Year 221 and Future 235, Without and With Project conditions. Under both scenarios, queues are well within storage capacity on the off-ramps, therefore impacts are considered less than significant. Page 3-6 PlaceWorks Page 66 of 186

67 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE 3. Revisions to the Draft EIR Table Intersection Santa Ana Blvd & I-5 SB Ramp I-5 Ramp Queue Queue Capacity (ft) 1, 28 Santa Ana Blvd & Grand Ave 1,2 29 Grand Ave & I-5 NB Ramp 1,4 Source: IBI 217. Intersection analysis conducted using HCM 21. Queue length 95th percentile. Opening Year 221 Max Length (ft) Future 235 Max Length (ft) Peak Hour No Project With Project No Project With Project AM PM AM PM AM PM Page , Section 5.9, Transportation and Traffic, is revised in response to Comment A2-2 from Caltrans Level of Significance Before Mitigation Upon implementation of regulatory requirements and standard conditions of approval, the following impacts would be less than significant: (exceedance of level of service), (CMP facilities), and (Alternative transportation policies), and (Freeway facilities). March 217 Page 3-7 Page 67 of 186

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69 4. References GreenInfo Network. 217, January 11. California School Campus Database &z=14&layers=notes%2Cpolygons%2Cuploads%2Cschoolboundaries%2Ccities&opacs= 1%2C25%2C9%2C1%2C1. OC Register. 216, October 5. Santa Ana's homeless now have a new place to take shelter. Orange County Transportation Authority (OCTA). 213, July. Draft Districts 1 and 2 Bikeways Strategy. Santa Ana, City of. 216a, January. Santa Ana Downtown Complete Streets Plan. Santa Ana, City of. 216b, September. Santa Ana Safe Mobility Plan. March 217 Page 4-1 Page 69 of 186

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71 ORANGE COUNTY CIVIC CENTER FACILITIES STRATEGIC PLAN FINAL EIR COUNTY OF ORANGE Appendix Appendix A. Traffic Study Addendum March 217 Page 71 of 186

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73 IBI GROUP 1841 Von Karman Avenue Suite 11 Irvine CA USA tel fax ibigroup.com Memorandum To/Attention County of Orange Date March 7, 217 From IBI Group Project No 1667 cc Subject County of Orange Facilities Strategic Plan - Traffic Study Addendum The purpose of this Traffic Study Addendum is to add to the Traffic Impact Analysis based on comments provided by the California Department of Transportation (Caltrans) in the review of the Draft Environmental Impact Report (DEIR) for the proposed Orange County Civic Center Facilities Strategic Plan. This addendum includes the following additional analyses: AM and PM peak hour analysis at Grand Ave/Santa Ana Blvd and I-5 ramps The analysis includes level of service analysis and queue analysis using actual signal timings (as provided by Caltrans) for the following intersections: o o o Santa Ana Blvd and I-5 SB Ramp Santa Ana Blvd and Grand Ave Grand Ave and I-5 NB Ramp INTRODUCTION The County of Orange prepared a Draft Environmental Impact Review (DEIR) for the County of Orange Facilities Strategic Plan that includes demolition, renovation, and new construction of multiple government buildings within the city of Santa Ana superblock. The superblock is bounded by Ross Street to the West, Civic Center Drive to the north, Broadway to the east, and Santa Ana Blvd to the south. ANALYSIS METHODOLOGY The traffic analyses prepared for this study were performed in accordance with the Caltrans Traffic Impact Study Guidelines and the methodologies as listed in Chapter 3 of the Traffic Impact Analysis. Detailed information on specific methodologies and thresholds used as part of this Addendum are provided below for each of the study intersections. Geometric Configuration, Traffic Volumes, and Trip Distribution AM and PM peak hour intersection traffic volumes and were derived in accordance to the methodologies outlined in the Traffic Impact Analysis Chapter 3. The project trip distribution and intersection lane geometries are outlined in Figure 1 and Figure 2, respectively. Intersection turning movement volumes for the Existing Year (216), Opening Year (221), and Future Year (235) scenarios are presented in Figures IBI Group is a group of firms providing professional services Page 73 of 186

74 IBI GROUP 2 County of Orange March 7, 217 Operational Standards and Thresholds of Significance The intersection level of service (LOS) utilizes the Highway Capacity Manual 21 (HCM 21) operations methodology consistent with Caltrans Traffic Impact Study Guideline (22). 1 The HCM 21 operations methodology for signalized intersections evaluates LOS based on controlled delay per vehicle. The relationship between controlled delay per vehicle and LOS for signalized intersections are summarized in Table 1. Caltrans uses the transition between LOS C and LOS D as the threshold of acceptability. Caltrans also acknowledges that if an existing State highway facility is operating worse than the appropriate target LOS, the existing LOS should be maintained. The Caltrans Route Concept Report for Interstate Route 5 (I-5) San Diego/Santa Ana Freeway, shows that the existing and forecasted peak hour LOS for the segment of I-5 from SR- 55 to the SR-22/57 is LOS F1 and F3, respectively. 2 Since the I-5 is operating at worse than LOS C, a significant impact would occur to Caltrans ramp intersections if the project: Degrades level of service from an acceptable LOS C or better to LOS D, E, or F; or Degrades the level of service on a facility operating at an unacceptable level to a worse level of service (e.g. LOS D to E; LOS E to F). TABLE 1: Level of Service Thresholds for Signalized Intersections LEVEL OF SERVICE CONTROL DELAY (SEC/VEH) A 1 B > 1-2 C > 2-35 D > E > 55-8 F > 8 Source: Highway Capacity Manual, 21 Queue Analysis As requested by Caltrans, a freeway ramp queue analysis was conducted at the study intersections for the Existing Year (216), Opening Year (221), and Future Year (235) scenarios. Ramp queue capacity measurements were obtained through measurement of scaled on-line images. Existing signal timings were provided by Caltrans and utilized to conduct the intersection operations analysis. Utilizing the intersection characteristics, the Synchro software was used to determine 95 th percentile ramp queues for the AM and PM peak hours. These queues were then compared to the queue capacity for their respective off-ramp. An impact is said to occur when the queue length exceeds the queue capacity provided by a given off-ramp. 1 The Caltrans Local Development-Intergovernmental Review (LD-IGR) published interim guidance which supersedes the 22 Caltrans Guide for the Preparation of Traffic Impact Studies. However, the interim guidance does not provide an LOS threshold Page 74 of 186

75 Figure 1 Roadway Configuration and Intersection Control Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection Lane Geometry County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 75 of 186

76 Figure 2 Regional Trip Distribution % 4% % % % 4% 13% 9% 4% 4% 4% 1% % 9% 1% 1 4% 4% legend Proposed Study Area Intersection X Regional Trip Distribution Percentage Project Site County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 76 of 186

77 IBI GROUP 5 County of Orange March 7, 217 EXISTING YEAR (216) Intersection Level of Service This section presents the evaluation of the study intersections in the Existing Year (216) No Project, Existing Year (216) + Phase 1, and Existing Year (216) + Phases 1 4 scenarios. The intersection operations analysis was performed consistent with the HCM 21 methodology, and the LOS designation following those parameters presented in Table 1. AM and PM peak hour intersection turning movement volumes for the aforementioned scenarios are presented in Figures 3 8. All study intersections maintain LOS with the addition of the project during both peak hour periods; no significant impacts are expected at any of the study intersections. A summary of the AM and PM peak hour level of service analysis results for the Existing Year (216) No Project, Existing Year (216) + Phase 1, and Existing Year (216) + Phases 1 4 scenarios is presented in Table 2 below: TABLE 2: Existing Year (216) Intersection Level of Service ID INTERSECTION CONTROL TYPE PEAK HOUR NO PROJECT WITH PROJECT PHASE 1 WITH PROJECT PHASES 1-4 DELAY (S) LOS DELAY (S) LOS DELAY (S) LOS 27 Santa Ana Blvd & I-5 SB Ramp Signalized AM 14.9 B 15. B 15.3 B PM 16. B 16.2 B 16.6 B 28 Santa Ana Blvd & Grand Ave Signalized AM 35.1 D 35.4 D 35.8 D PM 3.2 C 3.6 C 31.2 C 29 Grand Ave & I-5 NB Ramp Signalized AM 13.8 B 14. B 14.4 B PM 11.7 B 11.8 B 11.9 B Note: Intersection Analysis conducted using HCM 21 methodology. Queue Analysis As requested by Caltrans, a freeway ramp queue analysis was conducted at the study intersections. The off-ramps provide exceptional queue capacity for the queue lengths observed in all scenarios and their respective peak hours. A summary of the AM and PM peak hour ramp queue lengths for the Existing Year (216) No Project, Existing Year (216) + Phase 1, and Existing Year (216) + Phases 1 4 scenarios is presented in Table 3 below: TABLE 3: Existing Year (216) Ramp Queues ID INTERSECTION CONTROL TYPE QUEUE CAPACITY (FT) PEAK HOUR NO PROJECT MAX LENGTH (FT) WITH PROJECT PHASE 1 MAX LENGTH (FT) WITH PROJECT PHASES 1-4 MAX LENGTH (FT) 27 Santa Ana Blvd & I-5 SB Ramp Signalized 1, AM PM Santa Ana Blvd & Grand Ave Signalized 1,2 AM PM Grand Ave & I-5 NB Ramp Signalized 1,4 AM PM Note: Queue length - 95th pecentile. Page 77 of 186

78 Figure 3 Existing Year AM Peak Hour Traffic Volumes Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection AM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 78 of 186

79 Figure 4 Existing Year PM Peak Hour Traffic Volumes Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection PM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 79 of 186

80 Figure 5 Existing Year with Project AM Peak Hour Traffic Volumes (Phase 1) Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection AM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 8 of 186

81 Figure 6 Existing Year with Project PM Peak Hour Traffic Volumes (Phase 1) Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection PM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 81 of 186

82 Figure 7 Existing Year with Project AM Peak Hour Traffic Volumes (Phase 1+4) Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection AM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 82 of 186

83 Figure 8 Existing Year with Project PM Peak Hour Traffic Volumes (Phase 1+4) Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection PM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 83 of 186

84 IBI GROUP 12 County of Orange March 7, 217 OPENING YEAR (221) Intersection Level of Service This section presents the evaluation of the study intersections in the Opening Year (221) No Project and Opening Year (221) + Phase 1 scenarios. The intersection operations analysis was performed consistent with the HCM 21 methodology, and the LOS designation following those parameters presented in Table 1. AM and PM peak hour intersection turning movement volumes for the aforementioned scenarios are presented in Figures All study intersections maintain LOS with the addition of the project during both peak hour periods; no significant impacts are expected at any of the study intersections. A summary of the AM and PM peak hour level of service analysis results for the Opening Year (221) No Project and Opening Year (221) + Phase 1 scenarios is presented in Table 4 below: TABLE 4: Opening Year (221) Intersection Level of Service ID INTERSECTION CONTROL TYPE PEAK HOUR NO PROJECT WITH PROJECT PHASE 1 DELAY (S) LOS DELAY (S) LOS 27 Santa Ana Blvd & I-5 SB Ramp Signalized AM 15.3 B 15.4 B PM 16.5 B 16.8 B Santa Ana Blvd & Grand Ave Grand Ave & I-5 NB Ramp Signalized Signalized AM AM D B D B PM PM C B C B Note: Intersection Analysis conducted using HCM 21 methodology. Queue Analysis As requested by Caltrans, a freeway ramp queue analysis was conducted at the study intersections. The off-ramps provide exceptional queue capacity for the queue lengths observed in all scenarios and their respective peak hours. A summary of the AM and PM peak hour ramp queue lengths for the Opening Year (221) No Project, Opening Year (221) + Phase 1, and Opening Year (221) + Phases 1 4 scenarios is presented in Table 5 below: TABLE 5: Opening Year (221) Ramp Queues ID INTERSECTION CONTROL TYPE QUEUE CAPACITY (FT) PEAK HOUR NO PROJECT MAX LENGTH (FT) WITH PROJECT PHASE 1 MAX LENGTH (FT) 27 Santa Ana Blvd & I-5 SB Ramp Signalized 1, AM PM Santa Ana Blvd & Grand Ave Signalized 1,2 AM PM Grand Ave & I-5 NB Ramp Signalized 1,4 AM PM Note: Queue length - 95th pecentile. Page 84 of 186

85 Figure 9 Opening Year AM Peak Hour Traffic Volumes Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection AM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 85 of 186

86 Figure 1 Opening Year PM Peak Hour Traffic Volumes Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection PM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 86 of 186

87 Figure 11 Opening Year with Project AM Peak Hour Traffic Volumes (Phase 1) Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection AM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 87 of 186

88 Figure 12 Opening Year with Project PM Peak Hour Traffic Volumes (Phase 1) Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection PM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 88 of 186

89 IBI GROUP 17 County of Orange March 7, 217 FUTURE YEAR (235) Intersection Level of Service This section presents the evaluation of the study intersections in the Future Year (235) No Project and Future Year (235) + Phases 1 4 scenarios. The intersection operations analysis was performed consistent with the HCM 21 methodology, and the LOS designation following those parameters presented in Table 1. AM and PM peak hour intersection turning movement volumes for the aforementioned scenarios are presented in Figures All study intersections maintain LOS with the addition of the project during both peak hour periods; no significant impacts are expected at any of the study intersections. A summary of the AM and PM peak hour level of service analysis results for the Future Year (235) No Project and Future Year (235) + Phases 1 4 scenarios is presented in Table 6 below: TABLE 6: Future Year (235) Intersection Level of Service ID INTERSECTION CONTROL TYPE PEAK HOUR NO PROJECT WITH PROJECT PHASES 1-4 DELAY (S) LOS DELAY (S) LOS 27 Santa Ana Blvd & I-5 SB Ramp Signalized AM 16.5 B 16.9 B PM 18. B 18.9 B Santa Ana Blvd & Grand Ave Grand Ave & I-5 NB Ramp Signalized Signalized AM AM D B D B PM PM C B C B Note: Intersection Analysis conducted using HCM 21 methodology. Queue Analysis As requested by Caltrans, a freeway ramp queue analysis was conducted at the study intersections. The off-ramps provide exceptional queue capacity for the queue lengths observed in all scenarios and their respective peak hours. A summary of the AM and PM peak hour ramp queue lengths for the Future Year (235) No Project and Future Year (235) + Phases 1 4 scenarios is presented in Table 7 below: TABLE 7: Future Year (235) Ramp Queues ID INTERSECTION CONTROL TYPE QUEUE CAPACITY (FT) PEAK HOUR NO PROJECT MAX LENGTH (FT) WITH PROJECT PHASES 1-4 MAX LENGTH (FT) 27 Santa Ana Blvd & I-5 SB Ramp Signalized 1, AM PM Santa Ana Blvd & Grand Ave Signalized 1,2 AM PM Grand Ave & I-5 NB Ramp Signalized 1,4 AM PM Note: Queue length - 95th pecentile. Page 89 of 186

90 Figure 13 Future Year AM Peak Hour Traffic Volumes Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection AM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 9 of 186

91 Figure 14 Future Year PM Peak Hour Traffic Volumes Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection PM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 91 of 186

92 Figure 15 Future Year with Project AM Peak Hour Traffic Volumes (Phase 1+4) Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection AM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 92 of 186

93 Figure 16 Future Year with Project PM Peak Hour Traffic Volumes (Phase 1+4) Santa Ana/I-5 SB Ramp Santa Ana/Grand Ave Grand Ave/I-5 NB Ramp legend # Study Intersection PM Peak Hour Volume County of Orange Facilities Strategic Plan TIA IBI GROUP March 217 Page 93 of 186

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