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MEMORANDUM
To: James Campbell and Rosalinh Ung, City of Newport Beach
From: Dana C. Privitt, AICP
Kimley‐Horn and Associates, Inc.
Date: January 26, 2021
Subject: Residences at 4400 Von Karman Avenue
On November 5, 2020, the City of Newport Beach Planning Commission recommended that the City
Council take action to approve the proposed Residences at 4400 Von Karman Project (Project,
PA2020‐061). Consideration of the Project will be heard at the January 26, 2021 City Council meeting.
The project applicant, The Picerne Group, is requesting the City Council’s consideration of minor
modifications to the proposed Project at the January 26, 2021 hearing. The modifications would
increase the distance between the proposed Project residential building and the nearest existing
office buildings, and the distance between the proposed free‐standing parking structure to the
nearest office buildings.
The following modifications are proposed and are depicted on the attached exhibits.
Increased Free‐Standing Parking Structure Setback. Relative to the existing office building at
4340 Von Karman, the applicant would increase the setback for the free‐standing structure
from approximately 78 feet to 114 feet. In order to continue to provide 284 parking spaces in
the parking structure as considered by Planning Commission, the increased setback results in
a smaller parking structure footprint and a corresponding height increase to 45’4” with a 59’2”
elevator tower (five levels of above‐ground parking, inclusive of rooftop parking). The
Planning Commission considered a 36’7” parking structure with a 40’6” elevator tower (four
levels of above‐ground parking, inclusive of rooftop parking).
Increase Residential Structure Setback. The setback of the residential structure from the
existing office building at 4910 Von Karman will be increased from 33’ to 50’ on the ground
floor.
An Addendum to the 2006 General Plan Update Program EIR and the 2008‐2014 City of Newport
Beach Housing Element Update Initial Study/Negative Declaration was prepared to evaluate the
proposed Project’s consistency with the prior CEQA documentation. The purpose of this
memorandum is to confirm that the applicant’s proposed modifications are adequately addressed in
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the Addendum and require no additional review under the California Environmental Quality Act
(CEQA):
Section 15162 of the State CEQA Guidelines provides that an Addendum may be used if minor
technical changes or additions to a project are made by an applicant or lead agency, but that none of
the following conditions are met:
(1) Substantial changes are proposed in the project which will require major revisions of the
previous EIR or negative declaration due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified significant effect;
(2) Substantial changes occur with respect to the circumstances under which the project is
undertaken which will require major revisions of the previous EIR or negative declaration due
to the involvement of new significant environmental effects or a substantial increase in the
severity of previously identified significant effects; or
(3) New information of substantial importance, which was not known and could not have been
known with the exercise of reasonable diligence at the time the previous EIR was certified as
complete or the negative declaration was adopted, shows any of the following:
(A) The project will have one or more significant effects not discussed in the previous EIR or
negative declaration;
(B) Significant effects previously examined will be substantially more severe than shown in
the previous EIR;
(C) Mitigation measures or alternatives previously found not to be feasible would in fact be
feasible and would substantially reduce one or more significant effects of the project, but
the project proponents decline to adopt the mitigation measure or alternative; or
(D) Mitigation measures or alternatives which are considerably different from those analyzed
in the previous EIR would substantially reduce one or more significant effects on the
environment, but the project proponents decline to adopt the mitigation measure or
alternative.
The Residences at 4400 Von Karman Addendum found that potential impacts associated with the
proposed Project would either be the same or not substantially greater than those described in the
General Plan Program EIR. As discussed in the Addendum, these conclusions are supported by
substantial evidence, including project‐specific analyses of potential impacts. In addition, there are no
substantial changes to the circumstances under which the proposed Project would be undertaken
that would result in more severe environmental impacts than previously addressed in the General
Plan Program EIR. No new information of substantial importance shows that mitigation measures or
alternatives that were previously found not to be feasible or that are considerably different from
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those analyzed for the General Plan Program EIR would substantially reduce one or more significant
effects on the environment. Therefore, no conditions described in Section 15162 of the State CEQA
Guidelines has occurred. For these reasons, City staff and Kimley‐Horn and Associates, as a consultant
to the City, found that an Addendum is the appropriate document that will comply with CEQA
requirements for the proposed Project.
For the reasons noted below, Kimley‐Horn believes that an Addendum remains the appropriate level
of CEQA review for the Project as modified. No additional environmental review is required as a result
of the two changes to the scope of the Project. The two design modifications to the Project proposed
by the applicant do not change that conclusion. First, the proposed modifications do not change the
use or intensity of the Project. The Project is still proposed as a 312‐unit multi‐family residential
project with surface and structured parking. The size of the residential building would not increase.
The free‐standing parking structure would have the same number of spaces that were identified in
the plans considered by Planning Commission and the residential building would have the same
number of units, inclusive of affordable units.
The height of the free‐standing parking structure would increase by approximately 18’6” (inclusive of
the elevator tower) when compared to the plans that were considered by Planning Commission to
allow for one additional level of parking in the structure. This increase does not change the conclusion
in the Addendum that the Project regarding: (1) scenic views; (2) zoning and regulations governing
scenic quality; or (3) creation of sources of significant light or glare. As noted in the Addendum, the
nearest public view point to the project site identified in the General Plan is approximately 1.1 miles
south of State Route (SR) 73 at Bayview Park. The nearest coastal view designated portion of Jamboree
Road to the Project site is approximately 0.6 mile south of the site. Further, the Project site is flat and
bordered by office buildings and roadways. With respect to scenic quality, the proposed increased
height of the free‐standing parking structure south of and adjacent to an existing parking structure
would not change the conclusions of the Addendum. The height of the parking structure would not
result in conflicts with respect to airport land use or compatibility. The Project is under the Airport
Environs Land Use Plan (AELUP) for John Wayne Airport’s 200‐foot height limit. The five‐level parking
structure would be below the Project’s maximum height of 71 feet and the maximum height
permitted by the Koll Center Planned Community Development Standards (PC Text), which is 75 feet.
Therefore, it would not increase the maximum height of the Project or cause any new or increased
impacts regarding John Wayne Airport. With respect to lighting and as addressed in the Addendum
and the responses to correspondence on the Addendum, to minimize visibility of lighting from each
floor of the structure, the facades of the above‐ground levels of the structure would have a wall
system to obscure the lighting. With respect to the upper‐roof level, light standards are required to
not exceed 25 feet above the driving surface. Consistent with the findings of the Addendum, the
proposed modifications would not result new impacts relative to adverse effects related to lighting or
a substantial increase in the severity of a previously identified significant impact evaluated in the
General Plan Program EIR. The standard condition set forth in the Addendum provides quality
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assurance that the final lighting plan associated with the final design package would continue to
provide the same protections to neighboring properties as the design evaluated in the Addendum.
For the reasons above, the increase in the free‐standing parking structure’s height would not change
the conclusions in the Addendum or result in any potential new or increased environmental impacts.
The proposed increased setbacks between the residential buildings and existing office buildings do
not change any conclusions in the Addendum. The Project would remain consistent with the overall
character of surrounding urbanized development. The Project’s architectural style would not change
and is intended to complement the surrounding land uses in the area. The increased setbacks would
not create any aesthetic, design, or lighting conflicts that would potentially result in new or increased
environmental impacts. If anything, the increased setback would allow for a widened public park
buffer between the Project and the adjacent office buildings.
For the reasons above, the minor modifications proposed by the applicant do not mandate any
additional environmental review or change the analytical findings of the Addendum, and that an
Addendum as supplemented by this memorandum remains the appropriate level of CEQA review for
the Project.
The proposed revisions do not adversely impact the stability of the Addendum’s Project Description.
Settled case law provides that a Project Description must provide the lead agency and the public with
enough information to ascertain the project’s environmentally significant effects, assess ways of
mitigating them, and consider project alternatives. (Sierra Club v. City of Orange (2008) 163
Cal.App.4th 523; Save Found Valley Alliance v. County of Inyo (2007) 157 Cal.App.4th 1437.) A project
description is stable if it contains key geographic components, a written description of the project,
maps depicting the extent of the project’s sphere of influence, project boundaries, and other
information needed for evaluation and review of environmental impacts. (Id.; Guidelines, § 15124.)
In other words, it is stable unless it omits integral components. (Santiago County Water Dist. v. County
of Orange (1981) 118 Cal.3d 818.)
The proposed modifications do not meaningfully change the Project Description: the project site,
number of units, number of parking spaces, public park, affordable housing, and other project
components remain accurate and stable. The Project Description in the Addendum was and remains
sufficient to evaluate the environmental impacts of the Project. The two minor modifications
proposed by the applicant do not change the “integral components” of the Project under CEQA. As
described above, based on our evaluation, these modifications also do not change the Addendum’s
environmental analysis or result in new or potentially increased environmental impacts.
In addition, some commenters have raised a concern that there will be a parking shortfall of
approximately 265 spaces during the Project’s approximately 32‐month construction period. This
issue has been addressed, and as set forth in the Addendum and LSA’s parking report (attachment
PC3 of the Planning Commission’s November 5, 2020 agenda package), the analysis concludes that
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kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714-939-1030
there will not be a parking shortfall during Project construction for two reasons. First, the first phase
of the Project includes completion of a new free‐standing parking structure prior to initiating grading
or construction of the remainder of the Project, resulting in a net increase of 176 parking spaces to
Koll Center Newport . Second, LSA prepared a parking survey which concluded that an average of 37
percent of all spaces in the Koll Center Newport were vacant even during peak period (pre‐COVID‐19).
During the construction of the residential project component of the project, 440 parking spaces would
be removed but the combination of 176 net new parking spaces in the new parking structure and 450
unused parking spaces as documented in the LSA report indicates the availability of 186 surplus spaces
in Koll Center Newport. At the end of construction, there would be no net loss of parking (to return
to the 37% peak period parking vacancy rate identified by LSA), which is a CC&R requirement. Also, as
described in the Addendum, the Project would operate a shuttle between parking lots and
neighboring office buildings during the construction period. While parking is not a CEQA impact issue,
the Addendum did consider temporary and permanent parking conditions, and confirmed that the
Project’s parking components met all City parking standards.
OTIS CONTROLLER CLOSET32F - 104F<95% RELATIVE HUMIDITY
ELECTRICALROOM
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BIKEROOM
STACK RACK'SARIS'20" SPACING12 BIKES
STACK RACK'SARIS'20" SPACING6 BIKES
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EX. BLDGEX. PARKINGSTRUCTUREPROP. PARKINGSTRUCTUREN
JOB NO: DATE: REVISION #: CHECKED: DATE: DRAWN: DATE: NO. DESCRIPTION BY DATE CHKREVISIONS701 N. Parkcenter DriveSanta Ana, CA 92705p: 714/560/8200 f: 714/560/8211www.tait.comSince 1964Los AngelesOntarioSacramentoSan DiegoSan FranciscoBoiseDallasDenverPhoenixPortland701 N. Parkcenter DriveSanta Ana, CA 92705p: 714/560/8200 f: 714/560/8211www.tait.comSince 1964Los AngelesOntarioSacramentoSan DiegoSan FranciscoBoiseDallasDenverPhoenixPortlandPICERN KOLL CENTERCITY OF NEWPORT BEACHTHE PICERNE GROUP5000 BIRCH ST; SUITE 600NEWPORT BEACH, CA 92660
ED EDED
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OTIS CONTROLLER CLOSET32F - 104F<95% RELATIVE HUMIDITY
ELECTRICALROOM BIKEROOM
STACK RACK'SARIS'20" SPACING12 BIKES
STACK RACK'SARIS'20" SPACING10 BIKESUP
SLOPE UP<2%UPCOMMERCIALCOMMERCIAL
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UPDNEX. BLDGEX. PARKINGSTRUCTUREPROP. PARKINGSTRUCTUREN
JOB NO: DATE: REVISION #: CHECKED: DATE: DRAWN: DATE: NO. DESCRIPTION BY DATE CHKREVISIONS701 N. Parkcenter DriveSanta Ana, CA 92705p: 714/560/8200 f: 714/560/8211www.tait.comSince 1964Los AngelesOntarioSacramentoSan DiegoSan FranciscoBoiseDallasDenverPhoenixPortland701 N. Parkcenter DriveSanta Ana, CA 92705p: 714/560/8200 f: 714/560/8211www.tait.comSince 1964Los AngelesOntarioSacramentoSan DiegoSan FranciscoBoiseDallasDenverPhoenixPortlandPICERN KOLL CENTERCITY OF NEWPORT BEACHTHE PICERNE GROUP5000 BIRCH ST; SUITE 600NEWPORT BEACH, CA 92660
JANUARY 21, 2020
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