HomeMy WebLinkAbout16 - Supplemental EIR for Central Park ProjectCITY OF NEWPORT BEACH
• CITY COUNCIL STAFF REPORT
Agenda Item No. 16
January 27, 2004
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: City Manager's Office
Sharon Wood, Assistant City Manager
644 -3222, swood @city.newport- beach.ca.us
SUBJECT: City of Irvine Notice of Preparation of Draft Supplemental EIR for
Central Park Project in the Irvine Business Complex
ISSUE:
Should the City send comments on the Notice of Preparation (NOP)?
RECOMMENDATION:
Approve and authorize the Mayor to send the attached comment letter.
• DISCUSSION:
The Central Park Project is a new proposal for the Irvine Business Complex (IBC), which
involves the transfer of development rights and the conversion of rights for office development
to residential development. The project would include 90,000 square feet of office, 19,700
square feet of retail and 1,380 dwelling units at the former Parker - Hannifin industrial site at
Jamboree and Michelson Roads, south of the 1-405 freeway. This is the first IBC project in the
past two years for which a supplemental environmental impact report (EIR), as opposed to an
addendum to the 1992 program EIR, is being prepared. This is an important change in
approach, as the preparation of a supplemental EIR provides opportunities for public review and
comment, with the NOP being the first opportunity.
A subcommittee of the Environmental Quality Affairs Committee (EQAC) reviewed the NOP and
prepared comments on it. EQAC approved the attached comment memorandum at its meeting
of January 20, 2004. Staff has adapted this memorandum as a letter from the Mayor, with some
changes in the areas of biological resources, hazards, noise, public services and recreation.
Submitted by:
Sharon Wood
Assistant City Manager
191 Attachments: Memorandum from EQAC
Draft comment letter
MEMORANDUM •
To: Mayor Tod Ridgeway and Members of the City Council
City of Newport Beach
From: Environmental Quality Affairs Citizens Advisory Committee
City of Newport Beach.
Subject: Notice of Preparation ( "NOP ") for the Draft Supplemental Environmental
Impact Report ( "DSEIR ") for the Irvine Business Complex, Central Park,
Project (the "Project ")
Date: January 23, 2004
Thank you for the opportunity to comment on the NOP for the DSEIR for the
captioned Project located south of Interstate 405, west of Jamboree Road, north of Michelson
Road and easterly of Von Karman Ave. at the site formerly owned, operated and known as the
Parker - Hannifin site. The proposed DSEIR proposes to supplement an EIR and on page 20,
refers to "the IBC EIR." However, although the Checklist purports to analyze impacts of the •
Project based upon "substantial change[s] in the Project requiring major EIR revisions, neither
the Checklist nor anything in the NOP including the discussion identifies the "IBC EIR."
Moreover, the NOP lists "References" but fails to identify or refer to the "IBC EIR." At the very
least, the Supplemental Draft Environmental Impact Report must identify the EIR which it
purports to supplement, e.g. the IBC EIR, and discuss any and all Project changes and
inadequacies of the IBC EIR.
In addition and as further discussed below, we offer the following comments in
the hopes of improving the DSEIR and the Project.
1. Proiect Description:
The NOP states that the Project consists of a General Plan Amendment, Zone
Change and a Transfer of Development Rights "Master Plan" "to allow for a mixed use
development, including 19380 dwelling units, 90,000 square feet of office uses and 19,700
square feet of retail uses." NOP, page 1. Although the NOP never clearly identifies the Project
site as the Parker - Hannifin site, the NOP helpfully states that the Project site is `occupied with
with surface parking areas, landscaping, drive aisles, and six structures." It ambiguously
continues "[t]he site was previously developed with approximately 74,774 square feet of office
use and 240,970 square feet of industrial use (a total of 315,744 square feet) within six
structures."
•
• The DSEIR should clearly identify the EIR for the Irvine Business Complex,
discuss and explain "Transfer of Development Rights Master Plan" as well as any transfers of
various rights including trips or parking, analyze the impacts of any such transfers, clearly, and
precisely describe and discuss the full Project including all Project features such as a pedestrian
bridge over Jamboree Road near Interstate 405.
Further, the NOP states that "[t]he sending site for [the transfer of development
rights] has not yet been determined." NOP, page 26. In order to assess and understand the
Project fully, the DEIR should discuss the location of the transfer site or sites.
Although the NOP is unclear, the Project does not appear to be one discussed in
the IBC EIR. The DSEIR should clearly identify, explain, discuss and analysis the earlier
entitled project(s) and the proposed Project. The public should not guess as to the nature of the
earlier project and the proposed Project.
2. Environmental Checklist and Discussion:
a. Aesthetics:
Subsection I a., b. and c. concludes that the Project will create no
significant visual impacts because of the in -fill nature of the Project and development along
Interstate 405. However, the Project includes several features which may affect visual resources.
• First, the Project includes as an element a pedestrian bridge from the Project over Jamboree to
adjacent commercial and retail centers. The DEIR should analyze, discuss and assess all such
impacts, and propose necessary mitigation.
Second, the NOP recognizes that the City has designated Interstate 405 as a scenic
highway. The high density Project as well as the pedestrian bridge feature may affect this scenic
highway.
Third, the Project includes a highly dense residential feature. Subsection c.
concludes that the Project is compatible with "similar scale buildings within this urban pattern . .
." However, the surrounding buildings are large commercial office buildings. The Project's
high density residential buildings will visually conflict with the office buildings. The DEIR
should address, discuss and analyze such impacts and propose necessary mitigation.
Subsection d. addresses light and glare. The NOP concludes that there are no
sensitive receptors adjacent to the site but that the Project's high density residential feature may
be a sensitive land use. The NOP promises that the Project will control light and glare to avoid
off -site impacts. However, the DEIR must address on -site impacts of light and glare from off -
site sources including the scenic Interstate 405 highway.
b. Air Quality:
•
Section III a., b., c. and d. concludes that the substantial changes in the
Project require preparation of major EIR revisions. However, Section III e. concludes that the •
Project will not create objectionable odors which could affect a substantial number of people.
Among other things, the NOP concludes that no sensitive receptors are located adjacent to the
Project. However, the Project will bring sensitive receptors, people living in the 1,380
residential units, adjacent to the scenic I -405 which may also create odors which affect the
Project's residents. The DEIR should discuss, analyze and assess the nature and extent of any
such impacts, and propose necessary mitigation.
C. Biololdcal Resources:
The NOP concludes that the Project with its high density residential structures and
uses will have no impact on biological resources in the vicinity of the Project. However, the
summary recognizes that the Project is in the vicinity of San Diego Creek, San Joaquin Marsh,
and Upper Newport Bay. These areas including Upper Newport Bay are probably Newport
Beach's single greatest biological resource area. Regardless of the conclusions in the NOP, the
DSEIR should discuss and analyze the impacts of this high density residential Project on
biological resources in the area including San Diego Creek, San Joaquin Marsh and Upper
Newport Bay. If necessary, the DSEIR should propose adequate mitigation.
Another potential problem is the possibility of migratory birds flying into high -
rise buildings. The DSEIR should discuss such impacts on natural resources and propose
adequate mitigation, if necessary, including the reduction of glare from such structures and other
measures to prevent disoriented birds from injury. •
Also, the Project with its high density residential development will likely create
the danger and significant impact of unauthorized and possibly unlawful human activity in the
San Joaquin Marsh and Upper Newport Bay. Such impacts could include unauthorized
trampling of new pathways which could increase the sediment flow into San Diego Creek and
Upper Newport Bay, pet walking and contamination therefrom, and other potentially significant
impacts. The DSEIR should discuss, analyze and assess these and other impacts on natural and
biological resources which could come from the high density residential Project.
Finally, the DSEIR should also discuss the impacts of urban runoff on such
resources and, if necessary, propose adequate mitigation.
d. Geology and Soils, or Geophysical:
The Checklist indicates that Project site includes potentially highly
expansive soils and yet notes that the Project site is not prone to liquefaction. The Discussion
fails to address the character of the expansive soils not subject to liquefaction. Section VI d.
indicates that the City of Irvine will prepare a "site geologic report." The DSEIR should fully
discuss this report, and include and incorporate the site geologic report.
d. Hazards and Hazardous Materials:
•
Section VII a. and b. recognizes that Parker - Hannifin used hazardous
• chemicals at the site and that the Project may require removal of such hazards. Section VII g.
concludes that the Project and the removal of such material will not interfere with responding
emergency personnel and vehicles. The DEIR should analyze, discuss and assess the impacts of
the Project's removal of such materials on such emergency personnel and vehicles.
e. Hydrology and Water Ouality:
The Checklist and Discussion indicates no changes from previous
environmental analysis. However, the Discussion for Hazards states:
"Parker- Hannifin used and stored several different chemicals as
part of its operations on the project site and may have the
potential to cause a hazard to the public. Further evaluation in
the EIR is required to determine the level of significance and to
identify mitigation measures which reduce impacts to below a
level of significance, if possible"
NOP, page 23 (emphasis added). It is possible that the release of such hazards may affect
groundwater or surface water in the vicinity of the Project site. Surface water including San
Diego Creek is located near the Project. According the NOP, groundwater lies within 15 feet of
the ground surface. Any release of hazardous materials may create a significant impact on water
resources, both surface and groundwater. CEQA requires that the DSEIR address, discuss and
• analyze any such impacts and, if necessary, propose adequate mitigation.
L Land Use and Planning:
Section IX a. concludes that the Project will not physically divide an
established community and therefore will not create significant impacts on land use for such non-
division.
The NOP is incorrect: the Project may physically divide an established industrial,
commercial and retail community by inserting a high density residential project in the middle of
the industrial commercial community on and near the site. The DSEIR should discuss such
impacts and propose necessary mitigation.
Section IX b. recognizes that the Project conflicts with existing zoning and
General Plan requirements and includes amendments or changes to such requirements.
However, the DSEIR should include further analysis. As the City knows, the original 1992 IBC
Program FEIR divided the planning area into three districts: the multi -use district covered all
areas south of Barranca Parkway; the industrial district included areas north of Barranca
Parkway as well as areas already entitled or used for industrial purposes; and the "[r]esidential
[d]istrict within IBC will be limited to the existing and previously approved projects."
Program EIR, Executive Summary III -9.
The Project includes such a residential component in an area which the IBC
Program FEIR concluded was over built with residential. The DSEIR should discuss the •
Program FEIR's limitation and its rationale, address the impacts of a change from that limitation,
and propose necessary mitigation.
9. Noise:
Sections XI a., b., c. and d. indicate that the Project results in substantial
changes which require preparation of the DSEIR. The NOP recognizes that the Project may
create both short term and long term noise impacts. The DSEIR should include a noise study to
assess and discuss all such impacts including any impacts on the and propose necessary
mitigation.
Section XI e. addresses the Project's impacts on an airport land use plan within
two miles of the Project. The Discussion balks at such a requirement: it "finds" that the Project
is outside the CNEL 65 noise contour for John Wayne International Airport ( "JWA ") which is
within two miles of the Project.
The DSEIR should provide the basis and analysis for the NOP's improper finding.
The DSEIR should fully discuss any impacts from or on the Project as a result of its proximity to
JWA and propose any necessary mitigation.
h. Population and Housing: •
Sections XII a. and c. indicate that the Project with its 1,380 residential
units will result in no. changes requiring preparation of a new EIR. This is incorrect.
As indicated above, the IBC FEIR recognized that in the late 1980's IBC
entitlements exceeded allowable limits and restricted residential development in IBC. The
Project proposes to ignore such limits and significantly increase housing and population within
IBC. The DSEIR should explain this departure from the IBC FEIR, analyze all impacts which
flow therefrom and propose necessary mitigation.
L Public Services:
Section XIII a. recognizes that the Project will increase demand on public
services including police, fire, schools and other services. It notes that the City of Irvine will
consult with various agencies including Orange County Fire Authority and the Irvine Police
Department. However, given that the City of Newport Beach may develop a new fire station
•
near the Project, the City of Irvine should also coordinate with the City of Newport Beach
• regarding service demands from the Project.
The DSEIR should fully discuss and explain all such impacts and propose
necessary mitigation.
L Recreation:
The NOP recognizes that "[d]evelpment and occupancy of 1,380 dwelling
units would increase the demand for parks and recreational facilities, (sic) of various types"
NOP, page 25. Indeed, the NOP recognizes that the Project may create significant impacts on
existing neighborhood and regional parks, and may include recreational facilities which may
create significant impacts on the environment. We understand that the Parker - Hannifin site had
recreational facilities.
The Project is known as the "Central Park." Although the Project promises to
provide substantial on -site recreation including fitness facilities and pools, the Project will not
provide park facilities. "The project is proposing to pay park fees in lieu of dedicating land for
community parks." Id. The Project may also create recreational facilities which may create
significant impacts.
Indeed, the Project may become known as the "Central Pork" and could be
regarded as an improper attempt to funnel funds to the City's cherished "Great Park." The
• DSEIR should discuss all of this: the Project's impacts on parks, the possibility of providing
parks on site or near the site, any Project alternative mitigation measures, and other mitigation
measures.
k. Transportation/Traffic:
Section XV a., b., and c. recognize that the Project may result in
substantial changes requiring major revisions to the IBC FEIR including causing an increase in
traffic in the area, causing a reduction in the levels of service for intersections in the area and
related impacts. The Discussion indicates that the Project will require TDR of 379 a.m. peak -
hour trips, 487 p.m. peak hour trips and 6,906 daily gross trips from some as yet unidentified
sending site. The NOP fails to state the current trip budget for the site.
The SDEIR must do much better: It must explain the current trip budget, explain
how such budgets are developed and calculated, how such budgets affect actual traffic, discuss
the nature of the sending site(s) and any infrastructure improvements made in the area of the
sending site to mitigate the sending site's trip budget, explain how mitigation of the sending
site(s) trips will also be transferred to the Project site so that full and adequate mitigation of that
trip budget occurs, and fully analyze any other traffic impacts and propose mitigation for all
traffic impacts whether transferred trips or trips resident on the site.
Also, Section X e. discusses access to public services including fire. As indicated
above, the City of Irvine should coordinate with the City of Newport Beach in addition to the
•
other jurisdictions mentioned in the NOP to insure that the City of Newport Beach's equipment
may access the site if necessary. •
Also, the SDEIR should address the Project's impacts on traffic within the City of
Newport Beach. The traffic study and SDEIR should analyze all intersections possibly affected
by the Project including all intersections adjacent to State Route 73 and all intersections south of
State Route 73 along MacArthur Blvd., Jamboree Road, and Irvine Ave.
Also, we understand that the City of Irvine regards intersections as acceptable
which operate at Level of Service ( "LOS') E whereas the City of Newport Beach regards the
higher level, LOS D, as the minimum standard. The DSEIR and traffic study should address
these differences, analyze all impacts associated with such differences and propose necessary
mitigation. Further, any traffic studies and DSEIR should analyze any traffic impacts within the
City of Newport Beach using the City's own standards and methods.
1. Mandatory Findines of Sieniticance:
Probably the most important discussion in the DSEIR will be its
discussion of mandatory findings including cumulative impacts. As indicated in the City of
Newport's January 14, 2004 Comment Letter on the Scholle Project Addendum to the IBC FEIR,
the recently approved and/or constructed projects within IBC will certainly create cumulative
impacts together with proposed projects including this Project.
Equally important and as noted in the City's Comments on Scholle and as noted •
above, the IBC FEIR noted that the IBC was found to be way overbuilt in 1987; and the IBC
FEIR restricted residential development in IBC. The Project proposes to ignore this restriction.
The DSEIR should fully discuss these limitations and the cumulative impacts of the over ten
projects recently approved in IBC as well as other projects in the Project vicinity, e.g. any
planned expansion of the Conexant or Koll sites and any other projects in the area.
3. Conclusion:
Thank you again for the opportunity to comment on the NOP for the Project. We
hope that these comments and others will assist the City of Irvine in the preparation of the
DSEIR.
•
CITY OF NEWPORT BEACH
OFFICE OF THE MAYOR
Mayor
Tod W. Ridgeway
January 28, 2004
Mayor Pro Tem
Garold B. Adams
Council Members
Mr. Michael Philbrick, AICP, Senior Planner
Steven Bromberg
City of Irvine
John Heffernan
P. 0. Box 19575
Richard A. Nichols
Irvine, CA 92623 -9575
Steven Rosansky
Don Webb
Notice of Preparation
IBC Draft Supplemental EIR — Central Park
Dear Mr. Philbrick:
Thank you for the opportunity to comment on the NOP for
the DSEIR for the captioned Project located south of Interstate 405, west
1101 of Jamboree Road, north of Michelson Road and easterly of Von Karman
Ave. at the site formerly owned, operated and known as the Parker -
Hannifin site. The proposed DSEIR proposes to supplement an EIR and
on page 20, refers to "the IBC EIR." However, the NOP never adequately
identifies the "IBC EIR," nor does its list of "References" identify or refer
to the "IBC EIR." The Supplemental Draft Environmental Impact Report
should identify the EIR which it intends to supplement, e.g. the IBC EIR,
and discuss any and all Project changes and inadequacies of the IBC EIR.
In addition and as further discussed below, we offer the
following comments.
1. Proiect Description:
The NOP states that the Project consists of a General Plan
Amendment, Zone Change and a Transfer of Development Rights "Master
Plan" "to allow for a mixed use development, including 1,380 dwelling
units, 90,000 square feet of office uses and 19,700 square feet of
retail uses." NOP, page 1. Although the NOP never clearly identifies the
Project site as the Parker - Hannifin site, the does state that the Project site
City Hall • 3300 Newport Boulevard • Post Office Box 1768
Newport Beach, California 92658 -8915 • www.city.newport- beach.ca.us
(949) 644 -3004
is "occupied with surface parking areas, landscaping, drive aisles, and six •
structures" and "[t]he site was previously developed with approximately
74,774 square feet of office use and 240,970 square feet of industrial use
(a total of 315,744 square feet) within six structures."
The DSEIR should discuss and explain "Transfer of
Development Rights Master Plan" as well as any transfers of various rights
including trips or parking, analyze the impacts of any such transfers, and
precisely describe and discuss the full Project including all Project features
such as a pedestrian bridge over Jamboree Road near Interstate 405.
Further, the NOP states that "[t]he sending site for [the
transfer of development rights] has not yet been determined." NOP, page
26. In order to assess and understand the Project fully, the DEIR should
discuss the location of the transfer site or sites.
Although the NOP is unclear, the Project does not appear to
be one discussed in the IBC EIR. The DSEIR should clearly identify and
discuss the earlier entitled project(s) and the proposed Project.
2. EnvironmentaLChecklist and Discussion:
a. Aesthetics: •
Subsection I a., b. and c. concludes that the Project
will create no significant visual impacts because of the in -fill nature of the
Project and development along Interstate 405. However, the Project
includes several features which may affect visual resources. First, the
Project includes as an element a pedestrian bridge from the Project over
Jamboree to adjacent commercial and retail centers.
Second, the NOP recognizes that the City has designated
Interstate 405 as a scenic highway. The high density Project as well as
the pedestrian bridge feature may affect this scenic highway.
Third, the Project includes a high density residential feature.
Subsection c. concludes that the Project is compatible with "similar scale
buildings within this urban pattern . . .." However, the surrounding
buildings are large commercial office buildings. The Project's high density
residential buildings may visually conflict with the office buildings. The
DEIR should assess all such impacts, and propose any necessary
mitigation.
2 •
• Subsection d. addresses light and glare. The NOP concludes
that there are no sensitive receptors adjacent to the site but that the
Project's high density residential feature may be a sensitive land use. The
NOP promises that the Project will control light and glare to avoid off -site
impacts. However, the DEIR must address on -site impacts of light and
glare from off -site sources including the Interstate 405 highway.
b. Air Ouality:
Section III a., b., c. and d. concludes that the
substantial changes in the Project require preparation of major EIR
revisions. However, Section III e. concludes that the Project will not
create objectionable odors which could affect a substantial number of
people. Among other things, the NOP concludes that no sensitive
receptors are located adjacent to the Project. However, the Project will
bring sensitive receptors, people living in the 1,380 residential units,
adjacent to the I -405 which may also create odors which affect the
Project's residents. The DEIR should assess the nature and extent of any
such impacts, and propose necessary mitigation.
Biological Resources:
• The NOP concludes that the Project with its high
density residential structures and uses will have no impact on biological
resources in the vicinity of the Project. However, the summary recognizes
that the Project is in the vicinity of San Diego Creek, San Joaquin Marsh,
and Upper Newport Bay. The Project with its high density residential
development has the potential to create the impact of unauthorized and
possibly unlawful human activity in the San Joaquin Marsh and Upper
Newport Bay. Such impacts could include urban runoff, unauthorized
trampling of new pathways which could increase the sediment flow into
San Diego Creek and Upper Newport Bay, pet walking and contamination
therefrom, and other potentially significant impacts. The DSEIR should
assess these and other impacts on natural and biological resources which
could come from the high density residential Project and propose
adequate mitigation.
•
d. Geolociv and Soils, or Geophysical:
The Checklist indicates that Project site includes
potentially highly expansive soils and yet notes that the Project site is not
prone to liquefaction. The Discussion fails to address the character of the
expansive soils not subject to liquefaction.
3
e. Hydrology and Water Quality: •
The Checklist and Discussion indicate no changes
from previous environmental analysis. However, the Discussion for
Hazards states:
"Parker- Hannifin used and stored several
different chemicals as part of its operations on
the project site and may have the potential
to cause a hazard to the public. Further
evaluation in the EIR is required to determine
the level of significance and to identify
mitigation measures which reduce impacts to
below a level of significance, if possible."
NOP, page 23 (emphasis added). It is possible that the release of such
hazards may affect groundwater or surface water in the vicinity of the
Project site. Surface water including San Diego Creek is located near the
Project. According the NOP, groundwater lies within 15 feet of the ground
surface. Any release of hazardous materials may create a significant
impact on water resources, both surface and groundwater. CEQA requires
that the DSEIR address, discuss and analyze any such impacts and, if
necessary, propose adequate mitigation. •
f. Land Use and Planning:
Section IX a. concludes that the Project will not
physically divide an established community and therefore will not create
significant impacts on land use for such non - division.
The NOP is incorrect: the Project may physically divide an
established 'industrial, commercial and retail community by inserting a
high density residential project in the middle of the industrial commercial
community on and near the site. The DSEIR should discuss such impacts
and propose necessary mitigation.
Section IX b. recognizes that the Project conflicts with
existing zoning and General Plan requirements and includes amendments
or changes to such requirements. However, the DSEIR should include
further analysis. As the City knows, the original 1992 IBC Program FEIR
divided the planning area into three districts: the multi -use district
covered all areas south of Barranca Parkway; the industrial district
included areas north of Barranca Parkway as well as areas already entitled
or used for industrial purposes; and the "[r]esidential [d]Istrict within •
4
• IBC will be limited to the existing and previously approved
projects." Program EIR, Executive Summary III -9.
The Project includes such a residential component in an area
which the IBC Program FEIR concluded was over built with residential.
The DSEIR should discuss the Program FEIR's limitation and its rationale,
address the impacts of a change from that limitation, and propose
necessary mitigation.
g_ Noise:
Section XI e. addresses the Project's impacts on an airport
land use plan within two miles of the Project. The Discussion concludes
that the Project is outside the CNEL 65 noise contour for John Wayne
International Airport ("JWA'� which is within two miles of the Project. The
DSEIR should discuss this potential impact using the latest noise contours
from Orange County's recent EIR on the extension of the John Wayne
Settlement Agreement.
h. Population and Housing:
Sections XII a. and c. indicate that the Project with its
• 1,380 residential units will result in no changes requiring preparation of a
new EIR. This is incorrect.
As indicated above, the IBC FEIR recognized that in the late
1980's IBC entitlements exceeded allowable limits and restricted
residential development in IBC. The Project proposes to ignore such limits
and significantly increase housing and population within IBC. The DSEIR
should explain this departure from the IBC FEIR, analyze all impacts which
flow therefrom and propose necessary mitigation.
i. Recreation:
The NOP recognizes that "[d]evelopment and
occupancy of 1,380 dwelling units would increase the demand for parks
and recreational facilities, of various types." NOP, page 25. Indeed, the
NOP recognizes that the Project may create significant impacts on existing
neighborhood and regional parks, and may include recreational facilities
which may create significant impacts on the environment. We understand
that the Parker - Hannifin site had recreational facilities.
The Project is known as the "Central Park." Although the
• Project promises to provide substantial on -site recreation including fitness
5
facilities and pools, the Project will not provide park facilities. "The •
project is proposing to pay park fees in lieu of dedicating land for
community parks." Id. The DSEIR should discuss where park facilities
will be provided with such in -lieu fees. Unless park facilities are to be
provided within the IBC, there is likely to be an impact on Newport
Beach's park facilities, which may be more convenient to residents of the
Project than existing City of Irvine facilities.
The DSEIR should discuss all of this: the Project's impacts on parks, the
possibility of providing parks on site or near the site, any Project
alternative mitigation measures, and other mitigation measures.
j, TranwortationLTraffic:
Section XV a., b., and c. recognize that the Project
may result in substantial changes requiring major revisions to the IBC
FEIR including causing an increase in traffic in the area, causing a
reduction in the levels of service for intersections in the area and related
Impacts. The Discussion indicates that the Project will require TDR of 379
a.m. peak -hour trips, 487 p.m. peak hour trips and 6,906 daily gross trips
from some as yet unidentified sending site. The NOP fails to state the
current trip budget for the site.
The SDEIR must explain the current trip budget, explain how •
such budgets are developed and calculated, how such budgets affect
actual traffic, discuss the nature of the sending site(s) and any
infrastructure improvements made in the area of the sending site to
mitigate the sending site's trip budget, explain how mitigation of the
sending site(s) trips will also be transferred to the Project site so that full
and adequate mitigation of that trip budget occurs, and fully analyze any
other traffic impacts and propose mitigation for all traffic impacts whether
transferred trips or trips resident on the site.
Also, the SDEIR should address the Project's impacts on
traffic within the City of Newport Beach. The traffic study and SDEIR
should analyze all intersections possibly affected by the Project including
all intersections adjacent to State Route 73 and all intersections south of
State Route 73 along MacArthur Blvd., Jamboree Road, and Irvine Ave.
Also, we understand that the City of Irvine regards
intersections as acceptable which operate at Level of Service ("LOS') E
whereas the City of Newport Beach regards the higher level, LOS D, as
the minimum standard. The DSEIR and traffic study should analyze any
6 •
• traffic impacts within the City of Newport Beach using this City's own
standards and methods.
k. Mandatory Findinqs of Significance:
Probably the most important discussion in the DSEIR
will be its discussion of mandatory findings including cumulative impacts.
As indicated in the City of Newport's January 14, 2004 Comment Letter on
the Scholle Project Addendum to the IBC FEIR, the recently approved
and /or constructed projects within IBC will certainly create cumulative
impacts together with proposed projects including this Project.
Equally important and as noted in the City's Comments on
Scholle and as noted above, the IBC FEIR noted that the IBC was found to
be way overbuilt in 1987; and the IBC FEIR restricted residential
development in IBC. The Project proposes to ignore this restriction. The
DSEIR should fully discuss these limitations and the cumulative impacts of
the over ten projects recently approved in IBC as well as other projects in
the Project vicinity.
3. Conclusion:
• Thank you again for the opportunity to comment on the NOP
for the Project. We hope that these comments and others will assist the
City of Irvine in the preparation of the DSEIR.
Sincerely,
Tod W. Ridgeway
Mayor
cc: Environmental Quality Affairs Committee
•