HomeMy WebLinkAbout10 - Land Use Entitlement Applications for the Residences at 4400 Von Karman Project (PA2020-061) - Correspondence - Picerne GroupReceived After Agenda Printed
January 12, 2021
Item No. 10
THE PICERNE GROUP
January 11, 2021
Via E-mail
City Council of Newport Beach
City of Newport Beach
100 Civic Center Drive
Newport Beach, CA 92660
To Mayor Brad Avery and Members of the City Council:
In advance of our meeting tomorrow, we would like to take this opportunity to eliminate
confusion by briefly responding to some of the arguments raised by a few neighboring office
owners to our Residences at 4400 Von Kaiman project. However, to provide context to these
comments, it must be noted that owners representing approximately 70% of the leasable space
within this area of the Koll Center have either already expressed their support or confirmed that
they have no issue with the proposed project.
1. The Proiect Fully Complies with the Covenants, Conditions and Restrictions (CC&Rs)
for the Koll Center. A few neighbors have questioned whether residential development is
permitted per the Koll CC&Rs on this surface parking lot location, and whether Koll has the
right to replace surface parking spaces with covered parking spaces in nearby but different
locations.
These issues were previously raised in an unsuccessful legal challenge filed by one of the
Koll Center owners against the prior residential project applicant. This lawsuit was settled in
2016 and all parties agreed that that residential construction was permissible if in compliance
with the applicable City development standards. Additionally, it was agreed that common area
surface parking lots could in fact be sold by Koll for residential redevelopment in compliance
with CC&R requirements.
2. California Environmental Quality Act Objectives. Neighboring property owners have
raised concerns about potential "impacts" based on changes to nearby surface parking lots and
replacement parking, and changes to private office views.
With respect to parking, as a condition of our project, we are required to replace every
single surface parking space eliminated by the project. Further, parking is not an "environmental
impact" under CEQA. The project also exceeds the City's parking standards for residential
projects. Regardless, the City required a parking study to be conducted for this project which
confirmed that substantial numbers (over 40%) of parking stalls remained empty even during
peak occupancy periods (study was completed in 2019, pre-COVID). Finally, no neighbor has
challenged the fact that all displaced surface parking stalls will, in fact, be replaced.
With respect to changes to private views, as is the case with parking, these are not
"environmental impacts" under CEQA. Per CEQA regulation Appendix G. I (c)), in urbanized
areas, aesthetic impacts are significant only to the extent a project conflicts with "applicable
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January 11, 2021
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zoning and other regulations protecting public resources.". This project complies with all
applicable zoning standards.
3. Neighbor Pursuit of Private Economic Issues. During our community outreach, we have
heard some concerns associated with the potential negative economic consequences associated
with this project. A few of these concerns have also been articulated to the Council in writing
and include issues such as business interruption due to construction, and the degrading of Koll
Center building owner's property values. Associated with these concerns, we have received
demands for various compensation in the form of.
• new contractual and property interest rights to the replacement parking;
• guarantees that common area fees for the CC&R's would not increase; and
• monetary compensation for business interruption.
We believe these requests to be without merit and are wrongful if delivered under the
threat of a CEQA challenge. Temporary construction activities are a routine, foreseeable, and
completely lawful condition in urban areas. With respect to the impact of this project to
neighboring property values, this project represents an over $250M investment in the City of
Newport Beach and the Koll Center. In comparison, 5000 Birch Street, by far the largest
building in the area by square footage, was purchased by John Hancock in 2015 for $104.5M. It
is reasonable to infer that a substantial investment in Class A housing will only have positive
financial effects on the surrounding properties. In any event, all owner commenters were on
notice both, as to their rights under the private CC&Rs and, in almost all cases, when they
purchased their property after the City's adoption of the 2010 ICDP which contemplated
residential in the Koll Center Area. Finally, all these issues have been brought to the attention of
the owner of the Koll Center and found to be without merit in a letter from Koll to these owners
dated January 4, 2021 (see Attachment 1).
Notwithstanding, we have met extensively with these property owners to address their
concerns. Understandably, it has been an ongoing process. The lack of resolution, however,
cannot be used as a cause for delaying approval of the project as has been requested. As was
discussed at our Planning Commission hearing on the project, the United States Supreme Court
has definitively ruled that it is an unconstitutional delegation of regulatory power for a city to
require neighbor approval before approving a project that is otherwise eligible for approval.
To that end, we are presenting a project that meets that threshold. This project
implements the ICDP, which was approved nearly a decade ago and informed by a full
Environmental Impact Report (EIR). In compliance with CEQA, the City required updated
studies for the project confirming compliance with applicable City standards and that it caused
no significant new or exacerbated impacts.
In conclusion, there are no claims raised by commenters that warran
t delaying the
Council's consideration of the project, and claims raised alleging CEQA or land use objections
are without merit. This project is a critical addition towards meeting the City's housing goals and
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January 11, 2021
Page 3
help address a significant housing shortfall mine region. The project also includes critically
needed housing for very low-income households, which will be managed by a respected
affordable housing management company, in full compliance with City requirements and the
state Density Bonus Law.
We very much appreciate and look forward to your consideration of the project.
Sincerely,
Timothyanley
President, Picerne Development
Attachment 1 -January 4, 2021, letter from S. Meserve to D. Ostensen and J. Ault
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City Council of Newport Beach
January 11, 2021
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Attachment 1
0
January 4, 2021
Derek Ostensen
Julie A. Ault
Olen Properties
7 Corporate Plaza
Newport Beach, CA 92660
RE: Letter dated December 8, 2020 with respect to Proposed Residences at 4400 Von Karman
Apartment Project at Koll Center Newport
Dear Mr. Ostensen & Ms. Ault,
This letter is in response to the December 8, 2020 letter we received from Olen Properties,
Meyer Properties, Von Karman Condo Association and COMAC American Corporation
(collectively "Owners"), all owners of property within the complex know as Koll Center
Newport ("KCN"). The letter was sent to KCN A as the Declarant under the CC&R's which
govern the property (the "CC&Rs).
As I stated in my December 16, 20201etter to you, we have been in communication with the
current applicant , Picerne, and have incorporated the information it has provided in this letter.
The Owners' December 8 letter raises a variety of issues and concerns. Before we address them,
we note that KCN A is in full compliance with the CC&Rs, including as to KCN A's sale of the
residential property and the development of that property by Picerne. Any claims by the Owners
to the contrary are meritless and disputed.
Our response to the issues and concerns below quotes each item and then gives our response in
in bold.
1. Common Area Parking and Proposed Construction Activities.
a) "It is our understanding that a large area of Common Area parking has been sold
to an entity controlled by The Shopoff Group (Shopoff). Please provide the legal document that
guarantees and protects our Common Area parking rights, given that such parking is now on
private property. Further, please advise as to how the proceeds Koll derived from the sale of the
Common Area were apportioned against the Common Area expenses given the proportional
ownership of such land by each of the Owners." The Owners' parking rights are provided in
the CC&Rs. All of the common area land is privately owned, and the sale proceeds go to
the common area owner just as they did when every other owner's parcel was sold and
developed. The sale of this parcel does not change your common area parking rights, as
each parking space displaced by the new residential project is to be replaced by a
Derek Ostensen
Julie A. Ault
Olen Properties
January 4, 2021
Page 2
combination of parking spaces within a new freestanding parking structure (to be built in
the initial phase) and a dedicated office parking area within the new residential project.
We understand that access to this office parking within the new residential project will be
from two locations, the first being a separate access for KCN users on the north side of the
new residential project and second from the main KCN drive on the south side of the new
residential project. This project also includes the required parking for new residents and
their guests once all construction is completed. The CC&Rs do not create any right by
existing owners or tenants to proceeds from the sale of common areas.
b) "During Phase 2 construction of the Picerne project, there would be a large
deficiency of 260+ parking stalls, creating a non-compliant allocation of parking rights per the
CC&R's and City code. As you are aware, the ability of an existing property owner to sell or
finance their building depends on compliance with parking requirements. Accordingly, such a
deficiency would potentially preclude them from doing so. Please describe how you intend to
address this issue." There is always some parking disruption during construction, which is
contemplated and permitted under the CC&Rs. The developer is responsible for
accommodating that parking, and to replace all impacted parking spaces as described
above. See also response to g) below.
c) "Who would own the standalone parking structure? Please provide the legal
document that would guarantee and protect our Common Area parking rights in the standalone
parking structure." KCN A would own that structure for the benefit of the common area
just as the parking structure behind 4000 MacArthur is owned by KCN A. The CC&Rs
would apply.
d) "Clearly, Picerne would own the parking structure beneath its apart
ment project,
of which a portion is proposed to be used to fulfill Common Area parking needs. Please provide
the legal document (easement or other) that indicates how our Common Area parking rights
would be maintained and protected, and which details how matters such as insurance are
handled." No documents have been drafted at this time. To the extent the apartment
structure will have common area parking rights, those rights will be further documented
(e.g. by a perpetual access and use agreement) and managed as part of the common area
under the CC&Rs. This additional documentation will be finalized as part of the project
implementation process once the entitlement process is completed and include customary
operating and maintenance covenants and insurance requirements.
e) "Parking Structures can entail additional risks associated with theft, transients and
other safety issues. Would there be security cameras installed in the office parking areas to
address these risks? Would Picerne be solely responsible for their cost and maintenance given
that the proposed development fundamentally changes the existing common areas?" KCN A
intends to review and comment on the developers parking plans as affecting the common
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Derek Ostensen
Julie A. Ault
Olen Properties
January 4, 2021
Page 3
area, and will discuss with the developer the security camera concept. Additionally, KCN
security will patrol this parking as part of the common area. Picerne will simply become
an additional building owner within KCN, with the square footage of its building being
added to the denominator in determining the percentage allocations of the KCN, and
thereby lowering the overall common area costs for all of the existing KCN owners.
f) "The Parking Exhibit Picerne provided to the Planning Commission (see
enclosed) claims to address the Required Office Stalls Per Code for the existing buildings
adjacent to the project whose parking would be impacted. Yet the largest and most parking -
intensive affected building, 5000 Birch, is not included in the exhibit's analysis. This
shortcoming should be explained and fixed so we can have an accurate understanding of the
project's parking implications." The developer's parking plans call for each impacted
parking space to be replaced through a combination of the freestanding parking garage
and the designated office spaces in the apartment podium; hence, there is no resulting
change to the existing parking ratios.
g) "It seems highly doubtful that all construction workers and vehicles will be
parking solely on-site, as Picerne claims. Numerous construction projects promise this and then
fail to abide by it, resulting in severe parking constraints to existing businesses such as ours.
Please provide a construction plan that clearly indicates on-site parking locations and layouts.
Please also provide an explanation of how construction workers and vehicles will be prevented
from parking in office stalls, given that your current proposal does not indicate any mechanism
to do so besides an honor code (which rarely works with construction workers)." This is the
developer's responsibility, and it has provided the following response: "As you are aware,
it is within the general charge of the City to ensure the public safety and welfare of its
residents and to utilize applicable laws, rules and regulations to protect the same while also
promoting economic prosperity and respecting private owners' property rights. Of course.
as with any situation where development and construction is being completed, there will be
some resulting temporary inconveniences. In this case, the promulgated conditions of
approval require, prior to the issuance of a building permit, a City -approved construction
management plan addressing many topics, including project phasing, staging areas,
construction parking, haul routes and emergency access. A draft of the construction
management plan was attached to the November 5, 2020, Planning Commission Staff
Report as Attachment No. PC 5."
h) "Please provide an exhibit that shows where each of our buildings would park
during construction, including the number of stalls allocated to each building per its square
footage. Indicate how our respective parking allocations are fulfilled by each parking location
during each phase of construction." See response to g) above. This should or can be
ascertained from the developer's City -approved construction management plan, as it may
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Derek Ostensen
Julie A. Ault
Olen Properties
January 4, 2021
Page 4
be updated. Also, as was the case with prior construction, some inconvenience comes with
construction, which the plan is designed to minimize.
i) Please explain how the parking stall allocation Koll has provided for existing
businesses is compliant with City Code for office space, which appears to require a higher
number of stalls than is allocated to us by Koll. The KCN A parking ratio is compliant with
the City -approved Planned Community Text, which allows for a lower parking ratio than
the general parking requirements set forth in the City Code.
j) "Please provide the agreement between Koll and Picerne which would guarantee
parking shuttle service for affected building owners, if the project is built." Currently, there is
no such agreement. However, KCN A intends to review and comment on the developer's
parking plans as affecting the common area, including shuttle. See responses to d) and g)
above.
k) "If the project proceeds, hundreds of thousands of cubic yards of soil would be
exported from the site. Thousands of new vehicle trips from construction workers, heavy
equipment and material deliveries would occur. You appear to have given little thought to how
significantly such activities would congest and impair Koll Center circulation. What is your plan
for minimizing impacts of such activities to existing businesses, whose financial viability
depends on their workers being able to access their offices?" Construction activities are
directly regulated by the City as part of the entitlement approval process, and are covered
by the developer's construction management plan. See g) above.
2. Common Areas Expenses
A)
"We firmly object to any increase in our Common Area expenses from the
proposed project and its numerous related impacts. Please confirm that our Common Area
expenses would not increase as a result of this project, if it is built." The common area
expenses will be charged in accordance with the CC&Rs. We note that the last budget for
the Shopoff plan showed a decrease for existing owners due to the decrease in maintenance
requirements and increase of the number of owners paying into the common area. The
updated budget based on the Picerne plan will be prepared once all the details of the
Picerne plan are finalized.
b) "Has Shopoff been paying into the pro rata share of the KCN Expenses for their
new parcel? If not, please indicate why and how that is allowable under the CC&Rs." No, our
practice has been to not start charging until construction starts, because until then nothing
has changed in the common area.
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Derelc Ostensen
Julie A. Ault
Olen Properties
January 4, 2021
Page 5
c) "If Picerne proceeds with constructing thea project, what would their pro rata
share of KCN expenses be? Please confirm that Picerne would be a fully paying participant in
overall KCN expenses and would not be excluded from sharing such expenses." Yes, Picerne
would be paying their pro rata share of common area expenses.
d) "For the proposed 1 -acre park, would Picerne be solely responsible for all public
park costs, including all equipment replacement and maintenance. Existing KCN property
owners should not be responsible for any of these costs." Yes, Picerne will be responsible for
the park maintenance.
e) "Would Picerne be solely responsible for the costs of maintaining the Office
Lobby elevator that provides office parking service from the proposed subterranean structure?"
Yes, Picerne will be responsible for maintaining the elevator, and will be reimbursed by the
common area in accordance the CC&Rs.
f) "Would the new proposed "internal street" be a public street whose maintenance
and liability costs are borne by the City? If not, how do you intend to deal with the significant
associated costs and liability of this street? Being that it would primarily serve the apartment
building, its substantial maintenance and liability costs should not be shouldered by the existing
office buildings." This open drive will operate the same as the other open (non -gated)
drives in KCN i.e., the road between MacArthurNon KarmanBirch adjacent to the
Renaissance hotel and the surrounding office buildings and the road which connects
MacArthur and Jamboree in front of 4000 MacArthur). It will be a common drive and the
expenses will continue to be shared as a portion of the common area.
OF) "Structured parking oft
en entails higher costs for maintenance and management.
Would Koll be guaranteeing that existing properties will not have their parking rates or shared
maintenance costs increase above what is currently paid, excepting routine CPI increases? The
proposed structured parking would be imposed on us, and our tenants generally prefer the
convenience of surface parking, hence we should not be forced to pay higher costs." The
common area expenses will be charged in accordance with the CC&Rs. The new
standalone structure will be maintained by the common area. We note that as a
standalone, non -ventilated, concrete structure, it may be less costly in the long run to the
common area than the existing asphalt surface parking and landscaped areas.
h) "Large-scale construction will clearly damage and degrade Common Area drive
aisles, planters and other items. Following major construction, drive aisles typically need to be
repaved, curbs repaired and planters replanted, among numerous other cost items. What
agreement with Koll requires Picerne to pay for such repairs, given they would be directly
caused by their construction?" Picerne will be responsible for any damage done as a result of
its construction.
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Derek Ostensen
Julie A. Ault
Olen Properties
January 4, 2021
Page 6
3. Financial Viability of Our Properties During and after Construction
"Each of our companies has invested millions of dollars into our buildings with the
understanding that Koll Center Newport is an office park and would not be undergoing an
enormous residential construction project in the middle of our jointly owned Common Area that
will fundamentally degrade our properties' value, marketability and quality of life for several
years." We disagree. We also note that mixed-use parks that feature residential typically
out perform their market competition. In fact, many mixed-use developments within the
surrounding areai.e., Newport Beach, Irvine and Costa Mesa) have been adding
residential units and those properties have seen resulting increased occupancies and office
rental values.
"Koll has profited from its sale of our Common Area parking for a massive development and,
through the proposed construction and also its subsequent view blockages and other negative
property value impacts, Koll will impose substantial financial damages on our properties,
including proposed removal of on -grade parking as required by the CC&Rs, which reduces
the value and marketability of our buildings. Yet Koll has done little or nothing to address
these damages or even carefully coordinate with existing property owners to mitigate such
impacts." Your claim is not reasonable or correct. The concept of infill development
within KCN is nothing new, it has been going on since the project was started several
decades ago. All of the buildings built in KCN were added over time with many of the
buildings being built on the (privately owned) common area. The most recent being the
4450 MacArthur building which was built on an existing common area parking lot and
the development included an office building, below grade parking and new parking
spaces built on a common area landscape area. The common area owner has the right
to sell off and adjust boundaries of the common area. The long term concept after this
potential development will still provide all existing owners in the immediate area to have
access to both exposed surface parking and covered structured parking. Section 7.02 of
the CC&Rs clarifies that owner with Declarant can alter existing parking and drives to
accommodate the development. The precedent of this altering of parking and drives is
obvious by the number of existing parking structures and revised drive aisles present
within KCN.
"Consider for a moment that during the extremely noisy, congested and disruptive proposed
construction, we will not be able to lease vacant space in our buildings and will likely face rent
reduction and/or early lease termination requests from tenants. Brokers and their tenant clients
can lease space in numerous other Airport Area properties that will not be undergoing years of
noisy construction, parking deficiencies and circulation congestion — and they will surely do so,
materially impairing the financial viability of our properties as a direct result of Koll's conduct."
We question whether your claim is correct. In any event, we understand that there will be
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Derek Ostensen
Julie A. Ault
Olen Properties
January 4, 2021
Page 7
some short-term construction to work through, but that is to be expected from the
development permitted under the CC&Rs. Moreover, we believe that the value created
from an enhanced mixed-use park will be long term. It should also be noted that many of
the owners, including COMAC (4350 Von Karman) and Von Karman Condo Association
(4340 Von Karman) purchased their buildings with full knowledge that a residential
project was planned for this site.
"As existing property owners in Koll Center Newport, we deserve better —beginning with your
prompt response to the concerns detailed above, appointment of counsel to represent the owners'
interests in negotiations with Picerne as well as continuing with additional discussion on how
you intend to mitigate the financial damages you are imposing on our properties through the
proposed construction. Please be advised that this correspondence is an urgent attempt to prompt
action on behalf of the owners and does not constitute a full recitation of all opposition to the
proposed project."
We decline your request to appoint counsel for the Owners. There is no such obligation
under the CC&Rs. we are willing to discuss any reasonable mitigation measures you may
desire. However, we strongly disagree that the development will cause financial damages
to the Owners, to the contrary as noted above we believe that the development and the
associated improvements to the property will enhance the value of all properties within
KCN.
Let me know if you have any questions.
Regards,
Scott M. Meserve
The Koll Company
cc: Dana Haynes, VKOA
Jim Hasty, Meyer Properties
John Zhang, COMAC
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