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HomeMy WebLinkAbout03 RESPONSE TO NOP IRVINE'S PROJ 02-19-08AGENDA REPORT MEETING DATE: FEBRUARY 19, 2008 TO: WILLIAM A. HUSTON, CITY MANAGER FROM: COMMUNITY DEVELOPMENT DEPARTMENT SUBJECT: TUSTIN RESPONSE TO NOP FOR IRVINE'S 16752 ARMSTRONG PROJECT SUMMARY City Council authorization is requested for the City of Tustin's response to the subject Notice of Preparation (NOP) for a draft Environmental Impact Report (DEIR) for a Master Plan and Transfer of Development Rights for a proposed development consisting of 133,250 square feet of administrative offices on 6.43 acres in the Irvine Business Complex ("IBC") located at 16752 Armstrong Avenue. RECOMMENDATION: That the City Council authorize staff to forward the attached response letter to the City of Irvine. FISCAL IMPACT: There are no fiscal impacts associated with this action. BACKGROUND AND DISCUSSION: The Community Development and Public Works Departments have. reviewed the subject Notice of Preparation. The proposed office development consists of two buildings totaling 133,250 square feet of administrative office space on 6.43 acres at 16752 Armstrong Avenue. The demolition of an existing light industrial/office building consisting of 93,476 square feet is proposed. The proposed Project represents an 81 percent increase in average daily trips (ADT) for the site. A transfer of development rights from the property at 16572 Armstrong Avenue is proposed. The City of Tustin is concerned with the trip increase associated with the currently proposed Project, transfers of development rights, and the significant changes in land uses generally occurring within the IBC area and that are proposed to continue in the future. The previous IBC studies addressed. individual, project by project changes, but City Council Report NOP - 16752 Armstrong February 19, 2008 Page 2 the cumulative effect of the new land plans have not been addressed as a whole. The cumulative land use changes occurring within the IBC could result in significant modifications to the previously anticipated traffic impacts and planned mitigations. Staff believes that it is in the City's interest to be on record regarding this matter and has prepared correspondence expressing the City's concerns regarding the Notice of Preparation document (see Attachment A). Staff requests that the Tustin City Council review and consider these comments and, if acceptable, authorize their formal transmission to the City of Irvine. Scott Reekstin Senior Planner Elizabeth A. Binsack Community Development Director Attachment: Draft Comment Response Letter S:\Cdd\CCReports\NOP Irvine 16752 Armstrong.doc February 20, 2008 Mr. Hernan DeSantos Community Development Department City of Irvine One Civic Center Plaza P.O. Box 19575 Irvine, CA 92623-9575 SUBJECT: NOP FOR IRVINE'S 16752 ARMSTRONG AVENUE PROJECT Dear Mr. DeSantos: Thank you for the opportunity to provide comments on the proposed 16752 Armstrong Avenue project that gonsists of 133,250 square feet of administrative offices on 6.43 acres in the Irvine Business Complex ("IBC") located at 16752 Armstrong Avenue. The demolition of an existing building is also proposed. The proposed project is another one of many developments that has resulted in significant changes to the IBC land uses, many of which have already occurred to date. The types of land use changes that have occurred and are currently proposed are expected to result in vehicle travel patterns that vary substantially from the patterns previously assumed in the approved IBC environmental documents. In addition, it is likely that the actual traffic conditions associated with the existing IBC developments are more intensive than previously anticipated. Therefore, given the significant change of land uses there needs to be a comprehensive evaluation of the amount of added development activity that can actually be supported by the existing infrastructure and feasible mitigation measures. Most of the previous IBC traffic studies have allowed significant land use changes to occur based on assumed, maximum development potentials. We believe it is imperative to determine if the former levels of assumed "maximum" development are still practical. Current traffic conditions indicate the previous assumptions may no longer be valid. The City of Tustin is concerned with the significant changes in land uses (i.e., from commercial buildings to residential, intensification of uses, etc.) in the IBC area that have occurred to date and are proposed to continue in the future. The previous IBC studies addressed individual, project by project changes, but the cumulative effect of the new land plans were not addressed as a whole. On a number of occasions the City of Mr. Hernan DeSantos NOP 16752 Armstrong Project February 20, 2008 Page 2 Tustin has submitted written concerns that the cumulative land use changes could result in significant modifications to the anticipated traffic impacts and planned mitigations. It appears this DEIR can serve to address some of our on-going concerns by updating and addressing the overall transportation impacts to the IBC area, due to the past and anticipated land uses changes within the IBC. The City of Tustin has also identified the following specific concerns and issues: 1. Section XV, "Transportation/Traffic," of the NOP States that "further evaluation in the EIR is necessary." Therefore, a traffic study is required to document the transportation impacts of the proposed project. 2. Build out analysis needs to be included in the DEIR to verify/update the future improvement needs. Please include these evaluations in the DEIR. 3. The DEIR needs to show any traffic improvements that are assumed to be implemented and are included in the analyses. The reasoning for inclusion of the assumed improvements in the analyses should also be explained. 4. The DEIR should include an updated assessment of the original IBC traffic and transportation mitigations. The proposed Project should then be subject to the findings of the updated assessments of transportation improvement needs, in the IBC and surrounding areas. The need to update improvements for the IBC study area is anticipated to result from changes in "existing conditions," new cumulative traffic impacts, and potential impacts directly attributable to the Project. 5. When the analyses and findings that guide development (TDR, mitigations, etc.) in the IBC were completed, some significant projects (e.g. the Tustin Legacy, etc.) and circulation system connections (i.e., the extension of Tustin Ranch Road, deletion of a portion of Culver Drive, etc.) did not exist. While the ITAM traffic modeling has attempted to reflect the various and significant changes that have occurred over the years, the more critical factors such as IBC mitigations (even though the costs were updated, it is our understanding that the actual mitigation improvements were not similarly updated), IBC policies (i.e., changes to TDR policies, modified trip budgets, etc. to reflect current conditions) and other development factors have not been similarly updated. 6. The IBC transfer of development rights ("TDR") policies serve to exacerbate impacts associated with IBC area mitigation measures, which are not keeping pace with development activities. For typical large scale planning area situations (i.e., General Plan conditions, etc.); some specific development sites may exceed a projected amount, but there would also be other sites (within the large scale planning area) that develop below their expected trip generation potential. In the Mr. Hernan DeSantos NOP 16752 Armstrong Project February 20, 2008 Page 3 IBC, however, the TDR policies result in "unused" trip potential being transferred to other sites (in some cases in different impact areas) and thereby increasing traffic intensities at new locations. The TDR policies essentially eliminate the potential for underutilized sites to "balance" those sites with excess trip generation, which serves to overburden the overall planning area. 7. A "Red Hill Avenue" study was jointly conducted by the City of Irvine and City of Tustin and includes further definition of traffic mitigation responsibilities for development projects in the IBC. This Project should be subject to the findings, requirements, and agreements that is anticipated to ultimately result from this study. The intersection analyses in the DEIR will also need to be consistent with the Red Hill Study results. 8. It must be confirmed that the traffic model used to analyze future conditions accurately reflects the most current land use approvals for the Tustin Legacy and any other significant projects in the area. It should be noted, that various circulation modifications have been approved for the Tustin Legacy road system, which must be accurately reflected in the DEIR. 9. The proposed Project appears to be dependent on the current TDR and IBC trip budgets. Based on other recent City of Irvine traffic analyses, however, those underlying assumptions no longer appear valid. Previously documented existing and future conditions (i.e., trip budgets being exceeded, existing/future conditions no longer matching approved conditions, changed land use assumptions related to the TDR, etc.) show the needs to update the IBC trip budgets and potentially identify new, needed mitigation improvements. 10. There was a signal progression study completed for Barranca Parkway that assured adequate traffic operations on that roadway based on planned roadway designs and future traffic projections. Given the proposed intensifications of land uses associated with cumulative projects and the proposed Project, it must be verified that adequate signal progression along Barranca Parkway will be maintained and any needed mitigations made a condition of the Project. 11. Analyses of future conditions should include any intersections in the City of Tustin that may be significantly impacted by traffic from the Project. The amount of Project traffic traveling through these study intersections should be identified. 12. There should be mitigation measures required of the Project to provide "fair share" contributions for traffic impacts within the City of Tustin. 13. For locations within the City of Tustin, the traffic analysis must be based on City of Tustin criteria and methodologies. Mr. Hernan DeSantos NOP 16752 Armstrong Project February 20, 2008 Page 4 Thank you again for the opportunity to provide comments on the NOP for the 16752 Armstrong Avenue project. The City of Tustin would appreciate receiving all additional environmental documents with the responses to our comments when they become available and all future public hearing notices with respect to this Project. If you have any questions regarding the City's comments, please call me at (714) 573-3016 or Dana R. Kasdan, Engineering Services Manager at (714) 573-3171. Sincerely, Scott Reekstin Senior Planner cc: William H. Huston Doug Holland/Jason Retterer Dana Kasdan Terry Lutz Steve Sasaki Dana Ogdon Scott Reekstin SR:environ/Irvine 16752 Armstrong NOP Comment Letter.doc