HomeMy WebLinkAboutAIRPORT EIR11111111 lill 11111111111111111111111111 lill 111,1111
PLASTIC MOLDED�PDRODUCTS CORP.
CUSTOM INJECTION MOLDING
ENGINEERING ac TOOLING
,HENRY WEDAA
VICE PRCBI06NT
140E N. MANZANITA ,
ORANGE, CALIF. 82667 �
PHONE (714) 633-3092
HENRY W. WEDAA
PRESIDENT
Ff Valleyf/Asssocciiates Environmental Consultants
�o ba tMda, C,811f 118 06" 714-528-0363
RUTAN & TUCKER
iAT 0.8NETS AT LAW
LEONARD A. HAMPEL
I r)ITME G., R:50A )
THE BANK OF CALIFORNIA BUILDING
AREA CODE 7I4 401 CIVIC CENTER DRIVE WEST
,TELEPHONE 835.2200 SANTA ANA, CALIFORNIA 11111
:4�
0
o =OUNTY OF
<Q
H. G. OSBORNE
DIRECTOR
RICHARD G, MLINSELL
ASSISTANT DIRECTOR
ADVANCE PLANNING
G E
ENVIRONMENTAL MANAGEMENT AGENCY
ADVANCE PLANNING DIVISION
811 NORTH BROADWAY
SANTA ANA, CALIFORNIA
William Folley
3300 Newport Blvd.
Newport Beach, CA 92660
18 February 1976
TELEPHONE: 834-4643
AREA CODE 714
MAILING ADDRESS:
P.O. BOX 4108
SANTA ANA, CALIFORNIA 82702
FILE
Subject: Reallocation, restriping and surfacing of airport parking facility.
Dear Mr. Folley:
This letter is to confirm our telephone conversation of 18 February 1976,
on reallocation, restriping, and surfacing of airport parking facilities,
between Robert Jensen and William Folley, concerning the subject project.
It is our understanding that your organization has the following concerns or
objections on the project:
All projects related to Orange County Airport should be covered by
Environmental Impact Report made by County of Orange at present.
If this agency's understanding of the conversation is correct, please notify this
office by letter within five (5) days of receipt of this letter. If no reply is
received, we will consider our interpretation to be correct.
Thank you for your cooperation on this matter.
Very truly yours,
Cb
nnis L. Sundstrom, Manager 9\\lc�
Environmental Services 6r R'm°�
ESD-1
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1AMC'i0 11CNCR SR NBU UIU SOI
MN .O PO W UAML
C RIC.APD LEMON
NORMAN M 5MCO CO WARD
RIC.A.0 P SINS
H ROD OCR HOWCLL
C CMAIG CARLSON
JAMES D TUCRCR
JOHN J MIT"GAPVIN
F SHALLE NBCPOCR
WILLIAM R RAUTH $
JAMES P MOORE
M STEP�CN COONT2
MCPOCRT W WALKER
ACRE.- C BRAUN
ROBERT L PISLCY
COWARD D SYOCSMA, JR
NICK E YOCCA
TNOMAS S SALINGCR
FRITS R STPAOLING
PALL C LOIECAU%. JP
PAUL FRCDCPIC MAP.T
STEPMEN G POC
HONER I. MCCORMICK JR
ROGER A GRABLC
EDMUND R CASEY
BAHRY R LAUBSCHCR
HOWARD F HARRISON
BRUCC P CORBETT
JAMCS C ERICKSON
THOMAS P CLARA JR
WILLIAM R BICL
OAVIO C LARSCN
RICHARD A CURNUTT
R C SCHAAF
LCONARD A HAMPCL
JOHN C TCAL. JR
JOHN B HURLBUT. JR
DANIEL K WINTON
MICHACL W IMMCLL
CLPFOPO C FRIEDEH
WILLIAM C DEANS
JOHN A GLOOER
AHLFORO W DAHL. JP
ARTHUR G NIOMAN
THEODORE 1 WALLACC. JP
MICHAEL O RUBIN
COLLEEN M CLAIRE
ELIZABETH A STRAUSS
STUART T WALORIP
i
'RUTAN & TUCKER
ATTORNEYS AT LAW
THE BANK OF CALIFORNIA BUILDING
401 CIVIC CENTER DRIVE WEST
POST OFFICE BOX 1976
SANTA ANA, CALIFORNIA 92702
(7141 835-2200
February 2, 1976
Honorable Board of Supervisors,
County of Orange,
515 N. Sycamore Street,
Santa Ana, California, 92701
OF COUNy[L
W R LINDSAY
NEWPORT BEACH OFFICE
610 NEWPORT CENTER DRIVE. SUITE 900
NEWPORT BEACH. CALIFORNIA 92660
TELEPHONE (7141 83S`2200
.IN REPLY PLEASE REFER TO
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�.
Re: Reallocation and Expansion of Vehicle Parking
Space at the Orange County Airport
Gentlemen:
On behalf of our client, the City of Newport Beach, I wish
to file this formal written protest in opposition to the reallocation
and expansion of vehicle parking space at the Orange County Airport.
The City has recently learned that the County plans to expand public
parking at the Orange County Airport by 395 spaces, without an Environ-
mental Impact Report. Such an expansion in our opinion would be a
violation of the California Environmental Quality Act, and would not
be conducive to good planning, in that it would presuppose the result
of the comprehensive Environmental Impact Report being prepared for
the County by Daniel, Mann, Johnson & Mendenhall, which purports to.
cover public parking expansion.
The City of Newport Beach first learned of the expansion pro-
posal on January 13, 1976, while in attendance at an Airport Commission
meeting. The matter had to be continued to the Commission meeting of
January 27, 1976, due to the fact that none of the Commissioners had
received any backup material and interested parties such as the City of
Newport Beach had not previously, been informed of the project. On
January 19, 1976, the City received a letter from the General Services
Agency addressed to this Honorable Board via the -Airport Commission,
dated January 2, 1976, which purported to outline the proposal. To
the City's amazement, the January 2 letter purported to, divide this
single project, with a single purpose, into four separate projects, in
order to avoid the requirements of the California Environmental Quality
Act. This was done even though both County and State Environmental
Quality Act Guidelines describe a "project" as "the whole of an action
RUYAN & TUCKER
ATTORNEYS AT LAW
Honorable Board of Supervisors, -2- February 2, 1976
which has a potential for physical impact upon -the environment, directly
or ultimately." The January 2 letter•further asserted that the Cali-
fornia Environmental Quality Act could be complied with by declaring
the project in part categorically exempt and covering the remainder by
a negative declaration. .A consultation of the State Environmental
Quality Act Guidelines reveals, however, that there can be no categori-
cal exemption whenever there is an expanded use of any existing facility
or where there can be a cumulative impact of successive projects. See
California Administrative Code Title 14, Sections 15100.2(b), 15102,
and 15104.
The City appeared at the Airport Commission meeting of January
27,.1976, and formally protested proceeding with this project until the
California Environmental Quality Act has been complied with. Among other
things, the City pointed out that the increase of public vehicle parking
would have both a cumulative and secondary impact upon airport usage,
both in terms of increasing vehicle miles traveled and emissions, and
airport use, with accompanying increase in noise and other related Air-
port problems. (Any change from employee parking, where cars are station-
ary for eight hour periods, to a metered public parking situation with a
high turnover has an obvious substantial and significant effect upon the
environment.) The City pointed out to the Commission that such drastic
changes prior to completion of the aforementioned Environmental Impact
Report for the entire Airport without any environmental impact considera-
tion was both ill-advised and illegal.
The City. has also learned that a negative declaration was filed
for a portion of the project on January 7, 1976, and purportedly posted
on that date. The negative declaration did not purport to even consider
the cumulative or secondary impact of the project. Even though the
initial study recognized that the project was in the sphere of influence
of the City of Newport Beach, the City was not contacted for its input.
The City has also learned that a contract which could include a portion of
the work was awarded on January 20, 1976,,based on the grounds that a
categorical exemption from the California Environmental Quality Act was
appropriate. Again_, the City was not informed that the matter was to be
considered by this Board on that date.
The City of Newport Beach can only conclude that such a procedure
amounts to an effort to deny the City of Newport Beach the opportunity
to challenge the undertaking of this'project without complying with the
California Environmental Quality Act. The City of Newport Beach therefore
wishes bthis king of
complying with the tCalifornia er to eEnvironmental st the aQuality Act sanproject without
d equestsa.
RUTAN & TUCKER
'ATTORNEYS AT LAW
Honorable Board of Supervisors,
February 2, 1976
hearing before this body or the Planning Commission concerning the claim
that the California Environmental Quality Act can be complied with by
asserting that the project is in part categorically exempt and in part
covered by a negative declaration.
Sincerely,
RUTAN & TUCKER
David C: Larsen
DCL:rg
cc: Orange County Planning Commission,
cc: Orange County Airport Commission
cc: Director of General Services Agency
cc: County Counsel
W
CITY OF NEWPORT BEACH
CALIFORNIA
January 27, 1976
Environmental Services
Environmental Management Agency
P.O. Box 4108
Santa Ana, Calif. 92702
Attention: Stan Fuhr
Subject: Request for comment on Airport E.I.R.
Dear Stan:
02660
city Ball
3300 Newport Blvd.
(7141673-2N10 640-2197
We appreciate the opportunity to review the preliminary
sections of the Orange County Airport Alternative Futures E.I.R.
We have received the Project Description and Land Use and Urban
Development Sections.
As I indicated by phone, I have been unable to thoroughly
review the Land Use and Urban Development Sections, because of
the lack of the graphics showing the location of the various
CNEL impact areas projected for the various alternatives. I
understand that these are in the Noise Section which. has not
yet been completed. As soon as I receive that section, I will
go back over the Land Use and Urban Development Section.
I would also like to confirm that while we will continue
to review the preliminary sections at a staff level, the City
will want to review the entire draft E.I.R. before formally
submitting a complete set of comments. Therefore, we request
that the City be notified of the completion of the draft, and a
schedule of review periods and hearing dates. We would also
like to •request that twenty (20) copies of the draft be submitted
to the City for review.
Very truly yours,
DEPARTMENT OF COMMUNITY DEVELOPMENT
R. V. HOGAN, DIRECTOR
William R. Foley ��—
Environmental Coordinator
WRF/dlt
ECEIED
` Community
D,%%lopment
L
OF JAN 1 31976►'
IN�:TIrt.o,�n H,
`G` �1P:Uli
G F-
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RONMENTAL MANAGEMENT AGENCY
ADVANCE PLANNING DIVISION
Bll NORTH BROADWAY
SANTA ANA, CALIFORNIA
January 12, 1976
H. G. OSBORNE
DIRECTOR
RICHARD G. MUNSELL
ASSISTANT DIRECTOR
ADVANCE PLANNING
Richard Hogan, Community Development Director
Newport Beach'Planning Department
3300 Newport Blvd.
Newport Beach, California 92660
SUBJECT: Orange County Airport Alternative Futures EIR
LEPHONE: $34-4643
AREA CODE 714
MAILING ADDRESS'
P.O. BOX 4108
SANTA ANA, CALIFORNIA 92702
FILE
Please find attached a preliminary copy of the Land Use and Urban Development
Section of the Orange County Airport EIR. State EIR regulations now require
consultation with various individuals prior to the completion of a Draft EIR.
The attached material is not yet a complete Draft EIR, and we are therefore asking
for your review of those particular areas within your agency's jurisdiction. It
would therefore be very much appreciated if you would review this section and
return your comments, written or verbal, to S. Fuhr at Environmental Services,
834-3686.
It is important that your comments be received by us on or before January 19 1976.
in order for the information provided to be incorporated into the Draft EIR. If
no comments are received from your agency, we will assume you consider this section
to be adequate.
Please remember this is only a preliminary portion of a Screen Check EIR. In the
near future you will probably be reviewing additional sections of the EIR, and
ultimately the complete Draft EIR.
Your comments and speedy cooperation will be appreciated. Thank you very much.
Very truly yours,
De is Sundstrom, Manager
nvironmental Services
BP:mlt
cc: Reading File
ESD Project File
Attachment: Distribution List and Screen Check EIR
•
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1
>:rilary 2, 19,v
Honorable Board of Supervisors
County of Orange
Santa Ana, California
VIA: Airport Commission
Orange County Airport
1E741. Airport i9ay North
Santa Ana, California 92707
... T. .1:. ..-._ ... :1i f. � 2 7 1 1
, i '. ,:, •p :.p
L/pN197
SUBJECT. P,eall.ocation of vehicle parking space at the
Orange County iilrClo:f:t
Gentlemen:
Board of Supervisors Resolution 75-12.02 dated August 26, 1975,
C%; rcc'- ld the Dire`Or Of t1O G`_i-Irra_�. SG`::Y1Ces AgEatCy to pre-
r) ro and su-b-i"it to the Boar& oF Supervisors, Via the _<i irp:)r
('cffm::! scion, a. reT_irL an-1 rc co.i?i:l:)ildatlon or the 7:Cal7.i): L10a1
i �.� 1£, �+- .� n.LrpOrt a` an in`':'l"im
p r,:in� spat- Mga ^^ - .
the Parking problcei1 exist7ttg, at that facility.
C%ithe year'•:, there has been a Steady incr'.Wasc in the de -man"
r. •�:??C: 1. c` p:::::C:La: c; �/:. .�5 Et i_l,e 0rclP<f C: %'Ol?l':' �(' f�lrpUrL. L-?iZ1"1IIg
ip;•% years, i.. 3 .C? c s i ecm=ti,- more aC11}� `
t hi yJc .. ilfF prUb �.=='l has
(•: ;:he result that the ruin palacina .lot i.t: Fre:;Llencl_:= ri1r^_�i
-,? ; '3.icrai public Vic) a:::COT.i._,Q-
UnS in th-'' 1L.':ndi;,?t^ Vi!:'1 i?1_ti of Li?�'•'^J.
lcling.
iC) all=:Viate this Si'i:tia L.on, app-oximiately ±ivo acres of la-
L north o 1. -'i- .:.1_ ;r3' On B E:-1Crait is C _;_ L; t'y` have lb den utili, ad
t.; .. as °O Ve i:i 1O f" JE.: min -red. In-dividl:; is using 'i=ills al:•^•.a nest
=•},-:i 'Crg;:7 a :D_"O:•:iC:?tC:1y •of;f1-IYa.Li: mile �o :.+lc'. .
i; ;•_'t �.:`-ei jl i�14?-.i:i ..c... _..... � L : U
L.d-
Lt' L• _ _:: Ca:`:��: 1 a•1; .. '•�� in adCI ?_tT .)",a7. i'1.. 1:: U--
a.:, . L: 1': •C( _ ......� .GSi• 0
�•P Ul i..tllc, td1. Uh t:l.L 1=oai):C.1 C. i- I :t::]uO1.n is iO:1, the
( .. :<•. i. c'..=t ice.J�1UC n'; i'.il Ei 3"._�?.7.°t •ii.:Ci ct 1 of tti:: data,, availabl_
ctpd h,:a trCivc,71 at the conclusion •that. anpro_cilliately 395
a cia'i Lional perki-rij spaces "close in" to -the -Airport ;terminal
1)i?..i1,.:ing can be made available for public parking throu,h better
util'isatior. of areas presently de•si.gnate& for parking usage.
:'leis impro:-crtent can be obtain.^d by completing the following
actions:
1. Reassign car rental agency vehicles from the parking
area just north of the Airport terminal building,
containing 137 parking spaces, to the parking area
just south of the terminal building, con-taining 37
parking spaces, and make the area vacated by the car
rental agencies available for public parking. This
exch-ar ,e of parking areas would result in a net in—
crease of. 50 spaces for public parking. The enlarged
parking area would be controlled by parking meters
and signs would be placed in strategic locations to
a7:vrt the public that such short tern parking is
available. In addition to -the extra parking spaces
gain_td for public use, this location has the added
adv.�tntag.^_.s of being closer to the airline baggage
d:istrib7nUon center and is more convenient for
dropping off and picking up passengers.
f;sLim.ateZ cost_ $24,O00
2. Pcjtripe the main parking lot "to maximize utiliratiun
c ` the exis Ling ar^a . it is es till L .r`d that an addi—
t iAndl 150 spcices can be gained, as a result of this
ated cOsl:: $15,0110
3. C..onvtlrt "C:._ ei:istinC7 ~,loyeC: T}:e; ..'iii :T 1Ot, .. fi1 c�2 as
i;v' .'0-tie inar.1-:!qua to f o_, th4 s purposC'., to a public parkinvg
•i i)` This :oulci in a 9z'J.11 of .l915 sz-FICes for
public use.
cost: $10,000
c .t•
�_!:
is kill: ?1 COCL n:J :'tll off ^_' ii:C5317!1
'facility, :'11: 01 has a gr;C7:. Lan citpacity, C.)r
is 7 C':)}'• Di.: kii A prtisOnt, . till f. X(!, .1.5 being
10,'.i: . 1.c ,r%i. ngwhop tho ?^:l li !i" r ci ; lo:: is `Cell..
Ti. is '("`.':'..• .;1.'.i tit .. .G!lS 1.':-ti:.i. iL .7)a.''�; P . 01 UY
;.'
!,...:7, ..1tot it, 10 Ell ion" G:)\7oci of .hilt, lilt(_=...
o
2, 1•!i.
3
a-" `hs CUll stir L:C tiorl of a.
S 1CZ e77 F?li: '�C: `_.^•v--teri.lr�?1 F':.3a. At aiu:a,;re
a .:,rtLon of this low S:-:y Ste des' fara d7
t'onal puking for F,irpor:: patrons 1T_ re•>qui.red.
Estimated Cost: $11a,000
Shuttle bus service from the present overflow lot to the terr:iir_al
area was considered, but service cc:st estimates ranging from
$75,000 to $II0,000 depending on hours of se*_vice here considered
to be prohibitive at this time. S
Information received from the oranc.;:, County Environmental Manage-
ment Agency indicates that items 1, 2, and 3 are categorically
W:empt from environmental impact r ;luire...ents. Item 4 will
require a negative declaration; how -ever, no problems are'anti- �
cipated in obtaining the required .'.uproval.
Because the parking situation at the Airport is acute and in
vj.Cc:7 of the hazards e:{perlenced by patrons of the overflo-
pa-t.- i.ng lot, the above listed ir.p.r vements are consideled
appropriate as an interim solution for parking allocations.
There are sufficient anies in tin-, Airport- Enterprise Tund
accounts to Cover the cO ;t of the:; • improvC??.c I'?ts and no other
funding -would be required. It is <:ntici.pated that the cost of'
all improvements :•;ill be recovered through increased parking
fes revenues-v;ithin a thra^..year. 1: r-.loll.
E�CO'•IbIEiD�,TSo?:5: A. ^a2 Dirccto- - Gene_at S Yvices Agenc.<< be
aut'hol."1zcl` L.,-
1. r'elocat,U the car rental facility to
the prc�;:nt r?ei:er :l parking lot 'south -
of the ;..rminal b.,;.ldirg_
2. 1. )arking. n:-eters in the spa;.•'e on
Ir!stal .
i.i:.. J
I:O'C l SI.C'C^ of L.I ., t^Y ?:.i?al i;ii dl^.
V aC 1'i. C-., C.iIY 0'J Ixa't.lons.
3. ^st -;-p t !e fain _=:r':inS.1 lot to -pro-
1/1C{'? Ii':. iliac! nW, :er Of pc.r.T:ing :iprt C.t?.•3
for
., l L: ": •f1Y )-
parK —ig to th4
current I'ac llity, and
improve this 450 parking space lot
with a mininum covering of asphalt,
installation of adequate lighting,
and construction of a sidewalk to
the terminal area.
B. Authorize the expenditure of Airport,
Enterprise Fund monies to cover the cost
of implementation of the reco=mendations
listed in paragraph A above.
Respectfully submitted,
j
R. I.-MORRIS, DIREC^O?
AGE': to
Attacl*iment: 1. ap-=.irt ort Parking Area -Pre sent
2.Ypgrt Par}:i ng Area -Proposed
-
1-lidg
I ("
:. c_c,. 7,.rkincj Lot
23a1-1:ing Lot
:..: ;
Par'cing Lot
Facility
is c AIC:Fffi. _f � .— %,IPPOPT PARKING ARCA-PRCSF&IT
•nIRPU;2'f FIRE Et n[R'�^,r.",.'•. �`I:Ci CO':
\ CRASN, RESCUE
iROADWAY- -- - - { -
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—17
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CA
• _ :!_..-... ---max, ( •:'------r� -,, -;:� r�,- -,,_ .. ..—_,._...____'._ —_ - --i �:R i< 1 .. __. ;a,, .•',:�, `, `tip—i. —(�I,i (�I .••'"'U' i�:, � " ... .., ,
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LOT
airport Terminal Bldg
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.•1c,tcrod Parking Lot l�
Ca: ant -al Parking Lot
ii,nioloycr_ narking Lot
.i PL;�lic -Parking
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-'; %li sion Bcechcraft Facility 1 -
A'1"CLCil:iF,::T 2. .-URPORT PARKING ARM -PROPOSED I•
AIRPORT FIRE A
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J LE p p €.JI N TY O F
o RANOia
GENERAL SERVICES AGENCY
December 22, 1975
TO: H. G. Osborne, Director
Environmental Management Agency
County of Orange
R. 1. MORRIS
DIRECTOR
445 CIVIC CENTER DRIVE WCST
SANTA ANA. CALIFORNIA 92701
TELEPHONE: 034-2100
AREA CODE 7%A
iT
OEC 2 91975
ORANGE COUNTY
ENVIRONMENTAL SERVICES
DIVISION
Attention: Dennis Sundstrom, Manager
Environmental Services Division
FROM: R. I. Morris, Director'
General Services Agency
SUBJECT: Environmental Impact of Proposed Reallocation of
. Airport Parking Facilities.
In response to Board of Supervisors' Resolution 75-1202 dated
August 26, 1975, the General Services Agency is planning to
make specific recommendations to the Board of Supervisors for
the reallocation of parking space usage at the Orange County
Airport. The recommendations call for the reallocation: of space
presently being used for parking. No additional space will be
involved. Advice is requested as to whether an environmental
impact report, negative declaration, or other environmental
action will be required in implementing these recommendations:
1. Switch car rental vehicles from the area just north
of the terminal building to the metered public
parking area just south of the.terminal building,
and convert the area vacated -by this change to a
larger metered.public parking lot. No additional
parking spaces would be gained by this action.
2. Restripe the main parking lot to maximize the utili-
zation of the existing area. It is estimated that
this will result in a gain of approximately 150
parking spaces.
' Mr. H. G. Osborne
Attn: Dennis Sundstrom
December 22, 1975
Page 2
3. Improve the existing overflow parking lot just north
of the Mission Beechcraft fability by paving with
a minimum covering of asphalt, installation of
lighting, and the construction of a sidewalk to the
terminal area. No additional parking spaces would
be gained by this action.
C)
R. I: Morris,'Director
General Services.Agency
bsw
0•
7-Z_'j Airport Terminal Bldg
i_ =1 Metered Parking Lot
(� Car Rental Parking Lot
I.f-zz Employee Parking Lot
4•`."-`•m Main Parking.Lot
IA2!3 Overflow Parking Lot
t� Mission Beechcraft Facility
Q
`i AIRPORT FIRE B
1` CRASH RFSCUE
FACILITY
(NEVI)
AIRPORT SERVICE ROAD
ATC T PERn'1S310N R! vU1RE7 itOAD' :;
RESERVED FOR FU T URE /
AIRT RAFFIC CONTROL TOWER
FACILITY (FAA)
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RVR GLIDE•SLOPF *ANT.
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ENVIRONMENTAL MANAGEMENT AGENCY
ADVANCE PLANNING DIVISION
811 NORTH BROADWAY
SANTA ANA, CALIFORNIA
H. G. OSBORNE
DIRECTOR
RICHARD G. MUNSELL
ASSISTANT DIRECTOR
ADVANCE PLANNING
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1•t_O i J
R.I. Morris, Director
General Services Agency
445 Civic Center Drive West
Santa Ana, California 92701— t --
Attention: Mr. A. G. Beale, ASA
TELEPHONE: 534.4643
AREA CODE 714
MAILING ADDAC.S:
P.O. BOX 4108
SANTA ANA, CALIFORNIA 92702
FILE
Subject:• AIRPORT PARKING FACILITY REALLOCATION AND IMPROVEMENTS
Dear Mr. Beale:
In response to Board of Supervisors' Resolution 75-1202, dated August 26, 1975,
and your letter of December 22, 1975, this agency has reviewed the three
proposals (the switching of car rental vehicles with the metered public parking
lot, restriping of the main parking lot, and improve the existing overflow
parking lot) as a single project and have found that this project does not have
a significant effect on the environment.
Therefore, a negative declaration on this project was authorized and posted
on February 18, 1976 for public exposure and appropriate appeal period as
set forth in C.E.Q.A. Guidelines.
It should be noted, however, that this project with other minor projects
within Orange County Airport should be included and made a part of the
Environmental Impact Report presently being drafted to cover general airport
operations and/or expansion.
Very truly yours,
qiDes L. Sundstrom, Manag
onmental Services
cc: A.G. Osborne
R.G. Munsell
R. Bengon
ESD File
Reading file
DLS:lw
0 •
RUTAN & TUCKER
ATTORNEYS AT LAW
OF COUNSEL
w.w RUTAN umoHOTEI THE BANK OF CALIFORNIA BUILDING W, K. LINOSAY
JAMES B TUCKER. SR. R000.19501
NORMAO W. OAHL JOHMARN
RIME 401 CIVIC CENTER DRIVE WEST
NOROBB N. SMEDCOAARD JOHN J MURPHT
11 ROUSER TUCKER
ROOERi A.
GRADLN POST OFFICE BOX 1976 NEWPORT BEACH OFFICE
JAMES O. T HALL ROWER A. ORAOLE
JAMES I', sHALLENnERGER CDWARD D. SYBEEMA. JR. SANTA ANA, CALIFORNIA 92702 610 NEWPORT CENTER DRIVE, SUITE 900
NtROC R W WALKER
THOMAE R. EPLIRGER NEWPORT BEACH, CALIFORNIA 92660
ROBERTT W IVALKER BARRYEN G. POE (]I4) 835-2200
ROWERT L. RADLI OARRY R, LAUOWCHER TELEPHONE plh) 835.2200
FRIT2 R. ETR IC A THOMABRUCC R.. CLARKT
HOM RL. MCC MARX THOMAR L RSC N. JR
EDMUN L.. CCORMICK,
JR. JD,WIDOHN C LA L. J February 20, 1976
EO WARD R. CADANI G TEAL. JR, �"'``��^-"`lS y PLEASE REFER TO
HOWARO F HARRISONRRICLIFFS DK. E. FRIG
JAMES E. ERICKSON CLIFFORO E. FRIEOEN
WILLIAM R OIEL JOHN A. GLOGER r
RICHARD A. CURNUTT ARTHUR G. KIDMAN `V
LEONARD A. HAMPEL MICHAEL O RUBIN
JOHN O. HURLBUT. JR. ELI2AOETH A. STRAUSS C!1 l•�.
MICHAEL W. IMMELL MARC WINTHROP
WILLIAM C. DEANS
MI LFORD W. DAHL. JR
THEODORE I. WALLACC. JR. ft n
STUARTT WALORIP
C RICHARD LEMON y`j1l lJ /•.
Dennis D. O'Neil, City Attorney,
,. City of Newport Beach,
3300 Newport Boulevard,
Newport Beach, California, 92663
Re: Parking Expansion at Orange County Airport
Dear Dennis:
Enclosed please find copies of the following documents:
1) Unexecuted Appeal of Negative Declaration.
2) Copy of posted Negative Declaration.
3) Satisfaction of Consultation Requirements.
4) Initial Study.
5) Letter to Director of Environmental Management Agency
from R. I. Morris, dated December 22, 1975.
6) Letter to R. I. Morris from Dennis Sundstrom, dated
February 19, 1976.
As we discussed in our telephone conversation of February 18,
1976, the City staff should review these documents to determine if
in the City's opinion an Environmental Impact Report should be required
for this project. As you are aware, an appeal from the Negative Declar-
ation must be received by the Secretary of the Orange County Planning
Commission within seven days from the posting of the Negative Declara-
tion. From the letter to Mr. Morris from Mr. Sundstrom, dated Febru-
ary 19, 1976, the Negative Declaration was posted on February 18, 1976.
However, your information that you related to me on February 17, 1976,
indicates that the Negative Declaration may have been posted on that day.
RUTAN & TUCKER •
ATTORNEYS AT LAW
0
I
Dennis D. O'Neil, City Attorney
City of Newport Beach
-2-
February 20, 1976
Therefore, I would suggest that any appeal be filed with the Secretary
of the Planning Commission no later than February 24, 1976.
As a result of my review of the documents to date, I have the
following comments which should be'considered by your staff in analyz-
ing the project and any Environmental Impact Report requirement:
1) The scope of the project as outlined in the letter to the
Director of Environmental Management Agency of December 22, 1975, is
different from the'scope of the project outlined in the letter to the
Board of Supervisors dated January 2, 1976, which you previously fur-
nished to this office. The January 2 letter appears to indicate that
a greater increase of public parking will take place. The Negative
Declaration however appears to address itself to the project as out-
lined in the December 22, 1975, letter.
2) Both the Negative Declaration and the letter to Mr. Morris
of February 19, 1975, from the County Environmental Management Agency
state that the project will be covered by the comprehensive Environ-
mental Impact Report now being prepared. As in the matter involving
the Hughes Airwest lease, it would appear that any coverage of this
project in an Environmental Impact Report to be completed in the future
would be totally inadequate and the future Environmental Impact Report
would be nothing but an after -the -fact justification. Implicit within
the letter and the Negative Declaration is a recognition that the mat-
ter should be discussed in the context of Airport expansion as presented
in that Environmental Impact Report and therefore the project should
not be undertaken until it has been objectively treated in such context.
3) The Negative Declaration appears to ignore secondary impacts
which could result from an increase in public parking, i.e., increased
airport usage and increased demand for commercial aviation.
4) The Initial Study, without any explanation, states that there
will be no impact on traffic by increased public parking. Such a state-
ment appears to be inconsistent with the obvious and with at least the
spirit of the indirect souree rules of the Environmental Protection
Agency, which maintain that public parking increases vehicle miles
travelled and therefore vehicle emission pollutants.
I would suggest that any appeal filed with the County have
appended to it as exhibits the Negative Declaration, the Initial Study,
RUTAN & TUCKER
ATTORNEYS AT LAW
Dennis D. O'Neil, City Attorney
City of Newport Beach,
-3-
February 20, 1976
the letter of December 22, 1975, and the letter of February 19, 1976,
copies of which are enclosed, as well as a copy of the letter to
the Board of Supervisors dated January 2, 1976. In addition, at any
public hearing it should be made blear that all these documents and
the Notice of Appeal itself are to be part of the record.
If I can be of any further assistance, please don't hesitate
to contact me.
Sincerely,
RUTAN & TUCKER,
0��
David C. Larsen
DCL:rg
Encs.