HomeMy WebLinkAbout20200709_Parkland Dedication WaiverThe Residences at 4440 Von Karman
Parkland Dedication Waiver
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TPG (KCN) Acquisition LLC ("TPG") submits the following in support of ifp~~tfest for
a waiver of the City's park dedication requirement in connection with The Residences at 4440 Von
Karman (PA2020-18) ("Project"). The Project includes 312 residential units, with 13 affordable
units, surface and structured parking, and a public park on a 13.0-acre site at 4400 Von Karman
Avenue.
Below is (1) a summary of the General Plan's park dedication requirement; (2) a summary
of Government Code Section 65915, which requires cities to waive development standards that
will have the effect of physically precluding the construction of a proposed density bonus project;
and (3) justification that a waiver of the General Plan's parkland dedication requirement is
mandated by the Government Code. All of this supports TPG' s formal request for the City to
waive its parkland dedication requirement, as set forth in General Plan Policy LU 16-15.13, and
accept a 0.5 acre park instead of a 1.016 acre park.
1. City of Newport Beach General Plan Park Dedication Requirement:
Pursuant to General Plan Policy LU 16-15.13, a public park equal to 8 percent of the gross
land area of the total development, or a minimum one-acre, whichever is greater, shall be provided.
This requirement would mandate an approximately 1.016 acre park on the project site.
The General Plan allows a waiver of its park dedication requirement where it can be
demonstrated that the development parcels are too small to feasibly accommodate the park or
inappropriately located to serve the needs of local residents, and when an in-lieu fee is paid to the
City for the acquisition and improvement of other properties as parklands to serve the Airport
Area. The acreage of on-site open space developed with residential projects may be credited
against the parkland dedication requirements where it is accessible to the public during daylight
hours, visible from public rights-of-way, and is of sufficient size to accommodate recreational use
by the public. However, the credit for the provision of on-site open space shall not exceed 30
percent of the parkland dedication requirements.
2. Government Code Section 65915:
The Government Code requires cities to waive development standards that will have the
effect of physically precluding the construction of a proposed density bonus project. (Govt. Code.
65915(e)(l).) This waiver requirement applies regardless of whether the City of Newport Beach
has adopted an implementing local ordinance. (Govt. Code. 65915(a)(l).)
Cities are only allowed to impose development standards that will have the effect of
physically precluding a proposed density bonus project if a waiver or reduction of such standard
will:
a. Have a specific, adverse impact on health, safety, or the physical environment, for
which there is no feasible method to satisfactorily mitigate or avoid the specific
adverse impact.
b. Have an adverse impact on real property listed in the California Register of Historic
Resources.
c. Be contrary to state or federal law.
If a court finds that the City's refusal to grant a waiver or reduction of development
standards is in violation of the Government Code, that court is required to award attorney's fees
and costs against the City. (Govt. Code. 65915(e)(l).)
3. Justification for Requested Waiver:
Implementation of the Government Code Section 65915(a)(l) park requirement would
physically preclude the construction of the proposed density bonus project.
The project site's odd shape and existing buildings impose physical constraints that make
development of a park that is consistent with the General Plan and Integrated Conceptual
Development Plan ("ICDP") infeasible. Given the orientation of the existing buildings within the
project boundaries, the required setbacks, parking facilities, landscaping, and other required non-
buildable areas, a contiguous and centralized one-acre park with a minimum dimension of no less
than 150 feet surrounded by public streets on at least two sides (as required by the ICDP) would
only fit on the portion of the site on which the residential building is currently proposed. If the
one-acre park replaced a portion of the residential building, the project would have to be modified
to either (a) reduce the residential component down from 312 units (resulting in a loss of affordable
units); or (b) increase the height of the project and the depth of its subterranean parking structure.
Both options would render the project infeasible. For example, increasing the height of the project
would require a change in construction type to Type III podium which would come at a cost of
roughly an additional $20 per net rentable square footage. Such a design would also necessitate
an additional level of subterranean parking which is infeasible due to historical ground water
conditions. Therefore, the site is too small to feasibly accommodate a one-acre park and a waiver
of General Plan Policy LU 16-15.13 is justified under Government Code Section 65915(a)(l),
which requires cities to waive development standards that will have the effect of physically
precluding the construction of a proposed density bonus project.
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In light of the above, the Applicant hereby requests a waiver of the General Plan's parkland
dedication requirement. The granting of this waiver would not (a) result in a specific adverse
impact on public health or safety or the physical environment; (b) have an adverse impact on
property listed in the California Register of Historical Resources; or ( c) be contrary to state or
federal law. To the contrary, the waiver would support state housing law by providing a substantial
number of new residential units, including affordable units.