HomeMy WebLinkAboutCharter Section 423A-18
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GUIDELINES FOR IMPLEMENTING CHARTER SECTION 423
INTRODUCTION
On November 7, 2000, the Newport Beach electorate approved Measure S (Exhibit A).
Measure S amended the Newport Beach City Charter by adding Section 423. In general
terms, Section 423 requires voter approval of certain amendments of the Newport Beach
General Plan (General Plan). Measure S “encourages” the City Council to adopt
implementing guidelines that are consistent with its purpose and intent. The City Council
has, consistent with Measure S, conducted a series of public meetings to receive input
from the public on Measure S and these Guidelines. The City Council has determined,
based on staff analysis and public input, that these Guidelines are consistent with the
express purpose of Measure S.
On November 6, 2006, the Newport Beach electorate approved Measure V, a
comprehensive update and amendment of the General Plan Land Use Element. The Land
Use Element approved by Measure V presents land use entitlement information in new
tables and maps, and regulates non-residential entitlement by floor area ratio (FAR)
differently than the Land Use Element that was in effect when Measure S was approved.
The City Council has determined, based on staff analysis and public input, that these
Guidelines, as amended for consistency with the 2006 Land Use Element, are consistent
with the purpose of Measure S.
DEFINITIONS
The definitions and terms in this section are intended to be consistent with the purpose
and intent of Measure S. Certain definitions and terms are intended to generally conform
to the definitions in, and terminology of, the most current edition of “Trip Generation,” a
multi-volume publication of the Institute of Transportation Engineers (ITE Manual). The
ITE Manual is the primary reference used by transportation professionals seeking trip
generation information. Measure S requires use of the ITE Manual as a basis for
calculating the Peak Hour Trips generated by a use permitted by an Amendment.
A. Allowed and Proposed Use. The term “allowed use” means any land use(s)
permitted by the General Plan on property or in an area. An allowed use may be
defined in terms of a residential use and/or a non-residential use generally
applicable to an area or property or a particular land use applicable to specific
parcel. A “proposed use” is a land use that would be permitted after an
Amendment is approved.
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B. Amendment. The word “Amendment” means any proposed amendment of the
General Plan that is first considered and/or approved by the City Council
subsequent to December 15, 2000 and that increases the number of peak hour trips,
(traffic,) floor area (intensity) or dwelling units (density) when compared to the
General Plan prior to approval. In all cases an Amendment shall state the proposed
entitlement in density and/or intensity and, in the case of intensity, the category of
non-residential use.
C. Approval. The word ”approve” (and any variations such as approved or approval)
means, in the context of the City Council’s decision on an Amendment, that four
members of the City Council have, after the City has complied with the
“mandatory procedures” described in Section (4)(A) voted affirmatively to adopt a
resolution that contains the text of a proposed Amendment. In the context of the
voters’ decision on an Amendment, the word ”approve” (and any variations such
as approved or approval) means that a majority of those voting in the election have
voted in favor of the Amendment.
D. Dwelling Unit. The term “dwelling unit” means “dwelling unit” as defined in
Section 20.03.030 of the Newport Beach Municipal Code (Code).
E. Entitlement. The word “entitlement” means the maximum amount of floor area or
dwelling units authorized by the General Plan for each allowed use on any
property and/or in any area. The term entitlement when preceded by the word
“proposed” shall mean the entitlement requested by an Amendment. Proposed
Amendments for parcels or areas entitled for special uses shall, when considered
by the Planning Commission and City Council and when submitted to the voters,
describe the proposed entitlement in both floor area and the appropriate unit of
measurement for that special use as utilized in the Trip Rate Table.
F. Floor Area. The term “floor area” shall be defined as follows (taken from Section
20.03.030 of the Code - “Floor area, gross”):
“The total enclosed area of all floors of a building measured to the outside face of
the structural members in exterior walls, and including halls, stairways, elevator
shafts at each floor level, service and mechanical equipment rooms, and basement
or attic areas having a height of more than seven feet.”
G. Non-residential Use. The term non-residential use means any land use other than a
residential use that is authorized by the General Plan and that generates any peak
hour trips. The term non-residential use includes the land uses specified in
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Sections 20.05.040 (public and semi-public), 20.05.050 (commercial), 20.05.060
(industrial) and 20.05.070 (agriculture) of the Zoning Code. For the purposes of
these Guidelines, and specifically the Trip Rate Table, the non-residential use
categories are: (1) “Commercial” (which includes the General Plan designations of
“Neighborhood Commercial”, “Corridor Commercial”, “General Commercial”,
“Visitor Serving Commercial”“Recreational and Marine Commercial” and
“Regional Commercial”); (2) “Commercial Office” (which includes the General
Plan designations of “General Commercial Office”, “Medical Commercial Office”
and “Regional Commercial Office”); (3) “General Industrial”;(4) “Airport Office
and Supporting”(5) the non-residential portions of “Mixed Use” categories; and
(6) “Public, Semi Public & Institutional” (which includes the General Plan
designations of “Public Facilities”, “Private Institutions”, “Open Space”, “Parks and
Recreation” and “Tidelands and Submerged Lands”).
H. Peak Hour Trips. The term “peak hour trips” means the number of vehicle trips
equal to the applicable peak hour trip rate specified in the Trip Rate Table (Exhibit
B) for any allowed use or proposed use multiplied by the entitlement (using the
appropriate quantity of the relevant “unit” of measurement specified in the Trip
Rate Table). When these Guidelines require a statement or calculation of peak hour
trips, the morning and evening peak hour trips shall each be provided and listed
separately. Exhibit B shall be updated annually or as often as ITE revises the Trip
Rate Table, and this update shall not be considered an amendment to this policy.
I. Peak Hour Trip Rate. The term “peak hour trip rate” means the morning and
evening average weekday rate during the peak hour of the adjacent street traffic for
an allowed use and proposed use (as specified in the Trip Rate Table and as
derived from the ITE Manual). In the event the Trip Rate Table does not contain a
peak hour trip rate for an allowed use or a proposed use, the peak hour trip rate
shall be based on the morning and evening weekday average peak hour trip rate
for the most comparable land use in the Trip Rate Table. The most comparable
land use in the Trip Rate Table shall be determined by the City Council based on
recommendation of the Planning Director and the Transportation and
Development Services Manager (Traffic Engineer). The morning and evening peak
hour trip rates shall be listed separately.
J. Prior Amendment. The term “Prior Amendment” means an Amendment that:
1. Affects property or an area within the same statistical area as an
Amendment that is being considered by the Planning Commission and/or
City Council; and
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2. Was approved by the City Council after December 15, 2000; and
3. Was approved within ten years prior to the date the City Council approved
the Amendment being evaluated pursuant to Section 423 and these
Guidelines; and
4. Was determined by the City Council, or by a final judgment of a court of
competent jurisdiction, not to require voter approval pursuant to Section 423
and these Guidelines.
K. Residential Use. The term “residential use” means General Plan entitlement that is
stated in terms of dwelling units.
L. Statistical Area. The term “statistical area” shall mean one of the statistical areas
identified (on Figure LU3)) in the Land Use Element of the General Plan approved
by the City Council on July 25, 2006 (Exhibit C). The term statistical area also
means any new statistical area(s) established for property annexed to the City
subsequent to July 25, 2006 and in such event Exhibit C shall be modified to depict
any new statistical area(s).
METHODOLOGY
Section 423 requires voter approval of any major amendment to the Newport Beach
General Plan. According to Section 423, a “major amendment” is one that significantly
increases traffic, intensity or density of allowed and proposed uses. This Section describes
the methodology and assumptions to be used for purposes of calculating the traffic
(maximum peak hour trips), intensity (floor area) and density (dwelling units) of allowed
uses and proposed uses.
A. Traffic/Peak Hour Trips. The purpose of this Section is to assist the City Council,
Planning Commission, staff, the public and property owners in understanding and
calculating the traffic generated by allowed and proposed uses. Section 423
specifies that the term “significantly increases” means “over 100 peak hour trips.”
Measure S and Section 423 do not define the terms “allowed uses” and “maximum
amount of traffic” and they do not specify a method of calculating any increase in
the maximum traffic resulting from an Amendment. The General Plan contains
non-residential use categories that authorize a wide range of land uses with
variations in trip generation rates that make infeasible the use of the highest peak
hour trip rate of any allowed use. Accordingly, for property or geographical areas
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for which entitlement is specified in terms of one or more non-residential use
category, the peak hour trip rate specified in the Trip Rate Table represents a blend
of the ITE trip rates for the most prevalent uses within each category. The City
Council has determined that the methodology and assumptions in these Guidelines
represent the most reasonable method of determining the amount of traffic that is
allowed under the existing General Plan and the increase in peak hour trips
resulting from an Amendment. The following methodology shall be used for
calculating the peak hour trips of an allowed use and the increase, if any, in the
peak hour trips resulting from a proposed use if an Amendment is approved:
1. Allowed Use. The peak hour trips that an allowed use could generate shall
be calculated by multiplying the entitlement for the property or area by the
morning and evening peak hour trip rate for the allowed use as specified in
the Trip Rate Table. If the allowed use is designated in terms of one or more
non-residential use category, the peak hour trip rate from the Trip Rate
Table for the applicable non-residential use category shall be used. If the
allowed use or uses are designated in terms of one or more specific land
uses, the peak hour trip rate from the Trip Rate Table for each specific use
shall be used in proportion to the amount of entitlement for each specific
use.
2. Proposed Use. The peak hour trips that a proposed use could generate shall
be calculated using the methodology specified in Subsection 1.
3. The increase, if any, in peak hour trips resulting from an Amendment shall
be calculated by subtracting the morning and evening peak hour trips
determined pursuant to Subsection 1 from the morning and evening peak
hour trips, respectively, determined pursuant to Subsection 2.
B. Intensity/Floor Area. The purpose of this Section is to assist the City Council,
Planning Commission, staff, the public and property owners in understanding and
calculating the "intensity of allowed uses" (allowed intensity) permitted by the
General Plan for any parcel or area that is designated, or proposed to be designated
for Non-Residential Uses and the allowed intensity resulting from approval of an
Amendment (proposed intensity). The Land Use Element, with the exception of
those special land uses described in Subsection 2, employs the following methods
of specifying allowed intensity: (a) allocating a specific amount of floor area
(specific floor area allocation); or (b) assigning a floor area ratio (floor area ratio),
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with the allowed intensity calculated by multiplying the applicable floor area ratio
(“FAR”) by the gross land area of the parcel,.
1. Methodology. Except for “special uses” covered in subsections 2 and 3, the
increase in intensity resulting from approval of an Amendment shall be
calculated by subtracting the allowed intensity from the proposed intensity.
Both allowed and proposed intensity shall be calculated as follows:(i) the
specific floor area allocation; or (ii) the applicable FAR multiplied by the
gross land area.
2. Special Uses. The Land Use Element has historically entitled land uses on
the basis of the most common "unit of measurement" utilized in the ITE
Manual for calculating the peak hour traffic generated by that land use. The
use of the appropriate "unit of measurement" ensures that the Land Use and
Circulation Elements are, as required by State law, properly correlated. Floor
area is the most common unit of measurement in the ITE Manual but a
different metric is used to measure peak hour trips in the case of certain land
uses such as hotels (rooms) and theatres (seats) because those metrics better
reflect the traffic generation characteristics of those uses. Consistent with
the ITE Manual, the City has historically entitled some large hotels in terms
of rooms and two large theaters in terms of seats. The City has, in Table
LU2 Anomaly Locations, either assigned 1,000 square feet of floor area for
each hotel room or indicated the number of hotel rooms allowed on the site.
Table LU2 also indicates the number of theater seats allowed on certain sites,
while the intensity limit for other sites where theaters are allowed is
indicated in Table LU1 Land Use Plan Categories. For the purposes of this
policy, the rate of 1,000 square feet per hotel room and 15 square feet per
theater seat shall be used.
3. Special Uses/Methodology. The "allowed intensity" of a parcel or area that
is entitled using hotel rooms or theater seats as a unit of measurement shall
be calculated on the basis of 1,000 square feet per hotel room or 15 square
feet per theater seat. The “allowed intensity” of a parcel or area that is
entitled in a unit of measurement other than floor area, hotel rooms or
theater seats shall be calculated on the basis of the greater of the floor area
specified in the “Density/Intensity” column of Table LU1 Land Use Plan
Categories or Table LU2 Anomaly Locations, or the amount of floor area of
the allowed uses existing on the parcel at the time the application for the
Amendment is filed.
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C. Density/Dwelling Units. The dwelling units authorized in the General Plan for
property or an area before and after an Amendment shall be determined on the
basis of the maximum number of Dwelling Units allowed on the property or area
before and after the Amendment.
D. Trip Rate Table. The Trip Rate Table contains the morning and evening average
weekday peak hour trip rate for each land use specified in the ITE Manual. The
information in the Trip Rate Table is based on the vehicle trip rates and related data
in the ITE Manual. The term “unit” in the Trip Rate Table refers to the “unit of
measurement” or “independent variable” that was used in the trip generation
studies that form the basis of the trip rates reflected in the ITE Manual.
E. Entitlement Table. The Entitlement Table shall describe, by Statistical Area, the
peak hour trip (traffic), floor area (intensity) and dwelling unit (density) increases,
if any, of each Amendment approved by the City Council subsequent to December
15, 2000. The Entitlement Table shall not include any Amendment approved by the
voters and an Amendment shall be removed from the Entitlement Table ten (10)
years after approval by the City Council.
F. Multiple Amendments. The City Council may have occasion to approve more than
one Amendment affecting the same Statistical Area at the same meeting. In such
event, the Amendments shall be deemed approved in the following order:
1. The Amendment(s) with the earliest date(s) of initiation or application (for
example GPA 2001-001) shall be deemed approved before an Amendment
with a later date of initiation or application (for example 2002-002).
2. In the event that more than one Amendment was initiated or applied for at
the same time, the Amendments shall be deemed approved in numerical
order (for example GPA 2001-001 would be deemed approved before GPA
2001-002).
G. Change in Land Use Category. In the case of an Amendment that proposes a
change in land use from non-residential to residential or vice versa no floor area
credit shall be given for allowed density (dwelling units) and no density credit shall
be given for allowed intensity (floor area). For example, in the case of a Residential
parcel with an allowed density of 20 dwelling units the allowed intensity is zero
square feet of floor area and in the case of a Non-residential parcel with an allowed
intensity of 100,000 square feet, the allowed density is zero dwelling units.
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However, traffic (peak hour trip) credit shall be in accordance with the entitlement
multiplied by the appropriate peak hour trip rate.
PROCEDURES
This Section describes procedures to be followed prior to City Council approval of an
Amendment and the submittal of that Amendment to the voters.
A. Mandatory Procedures. The City Council shall not approve an Amendment unless
and until the Planning Commission and City Council have first conducted noticed
public hearings as required by law and prepared and certified any environmental
document that is required by the California Environmental Quality Act (CEQA)
and the CEQA Guidelines. The City Council shall, at the same time the
Amendment is considered and decided, consider and decide any discretionary
land use approval or permit that is related to the Amendment and for which an
application has been submitted.
B. Staff Reports. The Planning Department shall prepare Planning Commission and
City Council staff reports for each Amendment. All Planning Commission and
City Council staff reports on an Amendment shall contain information relevant to
whether the Amendment, if approved, would require voter approval pursuant to
Section 423. The reports shall include the following information:
1. In the case of an Amendment where the existing and/or proposed use is a
residential use, the number of dwelling units allowed by the General Plan
before and/or after the Amendment;
2. In the case of an Amendment where the existing and/or proposed use is a
non-residential use, the amount of floor area (and relevant unit of
measurement from the Trip Rate Table if different than floor area) allowed
by the General Plan before and/or after the Amendment;
3. In all cases, the number of peak hour trips allowed by the General Plan
before and after the Amendment;
4. A table that identifies each Prior Amendment (see definition in Section (2)J)
including any increase in Peak Hour Trips, Floor Area, and/or Dwelling
Units , and the date on which each Prior Amendment was approved;
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5. A table that adds eighty percent (80%) of the increases in peak hour trips,
floor area and dwelling units resulting from Prior Amendments (see
definition in Section (2)J) to the increases in peak hour trips, floor area
and/or dwelling units (as appropriate) resulting from the Amendment
under consideration.
6. The Entitlement Table referenced in Section (3)E.
7. Information about the Amendment, any associated project or land use
approval and the environmental analysis that would help the Planning
Commission and City Council make informed recommendations or
decisions on the Amendment and help the public develop informed
opinions about the Amendment.
C. City Council Review. The City Council shall determine at the noticed public
hearing at which any Amendment is approved if, based on the administrative
record for the Amendment including any testimony presented at that hearing, the
Amendment requires voter approval pursuant to Section 423. The City Council
shall submit an Amendment to the voters if:
1. The Amendment modifies the allowed use(s) of the property or area that is
the subject of the Amendment such that the proposed use(s) generate(s)
more than one hundred morning or evening peak hour trips than are
generated by the allowed use(s) before the Amendment; or
2. The Amendment authorizes an increase in floor area for the property or area
that is the subject of the Amendment that exceeds forty thousand (40,000)
square feet when compared to the General Plan before approval of the
Amendment; or
3. The Amendment authorizes an increase in the number of dwelling units for
the property or area that is the subject of the Amendment that exceeds one
hundred (100) dwelling units when compared to the General Plan before
approval of the Amendment; or
4. The increase in morning or evening peak hour trips, floor area or dwelling
units resulting from the Amendment when added to eighty percent (80%) of
the increases in morning or evening peak hour trips, floor area or dwelling
units resulting from Prior Amendments (see definition in Section (2)J
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exceeds one or more of the voter approval thresholds in Section 423 as
specified in Subsection 1, 2 or 3.
D. Calling an Election. In the event the City Council determines that the Amendment
requires voter approval, the City Council shall, at the noticed public hearing at
which the Amendment was approved or a subsequent noticed public hearing held
no more than sixty (60) days after making the determination, adopt a resolution
calling an election on the Amendment. The City Council shall schedule the election
on the Amendment at the next regular municipal election (as specified by the City
Charter) or at a special election if the City and the proponent of the Amendment
have entered into a written agreement to share the costs of the special election. The
City Council shall, at the time the election is called, direct the City Attorney to
prepare an impartial analysis of the Amendment. The impartial analysis shall
contain information about the Amendment, any related project or land use
approval, and the environmental analysis conducted of the Amendment that will
help the electorate make an informed decision on the Amendment. In the absence
of an ordinance or Charter provision that establishes a procedure for submittal of
arguments or rebuttals relative to City measures, the City Council shall, at the time
a decision is made to submit an Amendment to the voters, adopt a resolution that
authorizes the filing of arguments and rebuttals in accordance with the general
procedures specified in the Elections Code.
E. Exclusive Method. Effective November 3, 2004, in the absence of a mandatory
duty arising from an initiative petition, referendum petition, court order or other
mandatory legal obligation, Section 423 and the procedures outlined in these
Guidelines represent the sole and exclusive method by which the City Council
considers, approves and submits for voter approval an Amendment that is subject
to Section 423. The City Council has also determined that nothing in Section 423
prevents the City Council from submitting any matter other than an Amendment
to the voters as an advisory measure.
Adopted – March 27, 2001
Amended – June 8, 2004
Amended – July 13, 2004
Amended – August 11, 2009
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EXHIBIT A
Section 423. Protection from Traffic and Density.
Voter approval is required for any major amendment to the Newport Beach General
Plan. A "major amendment" is one that significantly increases the maximum amount of
traffic that allowed uses could generate, or significantly increases allowed density or
intensity. "Significantly increases" means over 100 peak hour trips (traffic), or over 100
dwelling units (density), or over 40,000 square feet of floor area (intensity); these
thresholds shall apply to the total of: 1) Increases resulting from the amendment itself,
plus 2) Eighty percent of the increases resulting from other amendments affecting the
same neighborhood and adopted within the preceding ten years. "Other amendments"
does not include those approved by the voters. "Neighborhood" shall mean a Statistical
Area as shown in the Land Use Element of the General Plan, page 89, in effect from 1988
to 1998, and new Statistical Areas created from time to time for land subsequently
annexed to the City.
"Voter approval is required" means that the amendment shall not take effect unless it
has been submitted to the voters and approved by a majority of those voting on it. Any
such amendment shall be submitted to a public vote as a separate and distinct ballot
measure notwithstanding its approval by the city council at the same time as one or
more other amendments to the City's General Plan. The city council shall set any
election required by this Section for the municipal election next following city council
approval of the amendment, or, by mutual agreement with the applicant for the
amendment, may call a special election for this purpose with the cost of the special
election shared by the applicant and the City as they may agree. In any election
required by this Section, the ballot measure shall be worded such that a YES vote
approves the amendment and a NO vote rejects the amendment; any such election in
which the ballot measure is not so worded shall be void and shall have no effect.
This section shall not apply if state or federal law precludes a vote of the voters on the
amendment.
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(End of amendment. But the proposed ballot measure also includes the following
"Second" through "Seventh":)
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Second. Purpose. It is the purpose of the amendment to give the voters the power to
prevent Newport Beach from becoming a traffic-congested city, by requiring their
approval for any change to the City's General Plan that may significantly increase
allowed traffic; and also to make sure that major changes do not escape scrutiny by
being presented piecemeal as a succession of small changes.
Third. Findings. 1. In planning the growth of their city and protecting its quality of
life, a prime concern of the people of Newport Beach is to avoid congestion and
gridlock from too much traffic.
2. The General Plan guides growth in the City of Newport Beach by designating land
use categories for all lands in the City, and providing limits on the allowed density and
intensity of use for each land use category.
3. The General Plan already provides for additional growth in the City; if all
development allowed by the General Plan were to be built, the traffic generated in the
City would increase by about 20%.
4. The people, whose quality of life is at stake, should have the power to disapprove
any proposed General Plan amendment that may significantly increase traffic
congestion beyond that which could already occur from development under the
General Plan.
Fourth. Implementation. 1. It is the intent of the foregoing amendment to the City
Charter of the City of Newport Beach that, to the maximum extent permitted by law, it
apply to all amendments to the General Plan approved by the Newport Beach city
council after the time of filing of the Notice Of Intent To Circulate Petition, provided
that it shall not apply to any amendment for a development project which has obtained
a "vested right" as of the effective date of the foregoing amendment to the City Charter.
A "vested right" shall have been obtained if:
(a) The project has received final approval of a vesting tentative map. As to such
vesting tentative maps, however, they shall be exempt only to the extent that
development is expressly authorized in the vesting tentative map itself; or
(b) The project has obtained final approval of a Development Agreement as
authorized by the California Government Code; or
(c) The following criteria are met with respect to the project:
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(i) The project has received a building permit, or where no building permit is
required, its final discretionary approval, and
(ii) Substantial expenditures have been incurred in good faith reliance on the
building permit, or where no building permit is required, the final discretionary
approval for the project; and
(iii) Substantial construction has been performed in good faith reliance on the
building permit, or where no building permit is required, on the final discretionary
approval.
Phased projects shall qualify for vested rights exemptions only on a phase by phase
basis consistent with California law.
2. The city council is encouraged to adopt guidelines to implement the foregoing
amendment to the City Charter of the City of Newport Beach following public notice
and public hearing, provided that any such guidelines shall be consistent with the
amendment and its purposes and findings. Any such guidelines shall be adopted by
not less than six affirmative votes, and may be amended from time to time by not less
than six affirmative votes.
3. The City shall take all steps necessary to defend vigorously any challenge to the
validity of the foregoing amendment to the City Charter of the City of Newport Beach.
4. Peak hour trip generation rates shall be calculated using the most recent version of
the Trip Generation Manual of the Institute of Transportation Engineers. The city may
fine-tune these rates, but not to less than 95% of the rates in the Manual.
Fifth. Attachment. Attached to this petition is a copy of page 89 of the Land Use
Element of the General Plan, showing the "Statistical Areas" of the City of Newport
Beach.
Sixth. Construction. Nothing herein shall be construed to make illegal any lawful use
presently being made of any land or to prohibit the development of any land in
accordance with the provisions of the City's General Plan in force at the time of filing of
the Notice of Intent to Circulate Petition.
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Seventh. Severability. If any part of this initiative is declared invalid on its face or as
applied to a particular case, such decision shall not affect the validity of the remaining
parts, or their application to other cases. It is hereby declared that each part of this
initiative would have been adopted irrespective of the fact that any one or more other
parts be declared invalid. "Part" is generic, including but not limited to: Word, clause,
phrase, sentence, paragraph, subsection, section, and provision.
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MACARTHUR
WEST
MIGUEL
COAST
AVENUE
TUSTIN
N
L1
A1
L3
J5
L2
L4
K2
M5
M6
K1
J6
M4J1
M1
M2
J4
F1
M3
H2 H3
F3
A2 J2
K3
J3
A3
G1
D3
B5 H4
D4 F4
B4
D1
H1
F8
F2
J6
D2
B1
C2
F5
F7 F6
C1
E2E1
B2
B3
F9
E3
0 0.50.25 Miles
LU3_Statistical_Area_Map.mxd January / 2008
Exhibit CFigure LU3 - Statistical Area Map