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HomeMy WebLinkAbout07 MND FOR IRVINE CROSSINGS 04-01-08AGENDA REPORT MEETING DATE: APRIL 1, 2008 TO: WILLIAM A. HUSTON, CITY MANAGER FROM: COMMUNITY DEVELOPMENT DEPARTMENT SUBJECT: TUSTIN RESPONSE TO MND FOR IRVINE CROSSINGS PROJECT SUMMARY City Council authorization is requested for the City of Tustin's response to the subject Draft Mitigated Negative Declaration (MND) for the addition of 173,774 square feet of office tenant improvements within an existing 4,726 square foot office and 303,929 square foot warehouse building located at 17871 Von Karman Avenue. The existing footprint of the building is not proposed to be altered. The approximately 21-acre site is bounded to the east by Von Karman Avenue, to the west by a flood control channel, and to the south by Gillette 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 proposed project includes the addition of 173,774 square feet of office tenant improvements within an existing 4,726 square foot office and 303,929 square foot warehouse building located at 17871 Von Karman Avenue. The existing footprint of the building is not proposed to be altered. The approximately 21-acre site is bounded to the east by Von Karman Avenue, to the west by a flood control channel, and to the south by Gillette Avenue. In August of 2006, the City of Irvine transmitted a Notice of Preparation (NOP) of a Draft Environmental Impact Report (DEIR) for a General Plan Amendment, Zone Change, Transfer of Development Rights, and other discretionary actions for residential City Council Report DMND -Irvine Crossings April 1, 2008 Page 2 development consisting of 686 multi-family dwelling units at the same location. However, the residential project was withdrawn in May of 2007. The Community Development and Public Works Departments have reviewed the subject Draft MND. 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 Draft MND document (see Attachment). 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\MND Irvine Crossings.doc April 2, 2008 Trevor Lottes City of Irvine P.O. Box 19575 Irvine, CA 92623-9575 SUBJECT: DRAFT MITIGATED ND FOR IRVINE CROSSINGS PROJECT Dear Mr. Lottes: Thank you for the opportunity to provide comments on the Draft Mitigated Negative Declaration (MND) for the addition of 173,774 square feet of office tenant improvements within an existing 4,726 square foot office and 303,929 square foot warehouse building located at 17871 Von Karman Avenue. The existing footprint of the building is not proposed to be altered. The approximately 21- acre site is bounded to the east by Von Karman Avenue, to the west by a flood control channel, and to the south by Gillette Avenue. The City of Tustin has identified the following specific concerns and issues: 1. Traffic Study, Table B and ICU. sheets; show that the Traffic Study assumes that no Project traffic will use the I-405/Jamboree Road interchange to access the freeway. We do not believe this assumption is correct, nor reasonable. 2. Traffic Study, Table B; shows Barranca Parkway to exist as an eight lane divided roadway, which is not accurate and must be corrected. 3. Traffic Study, page 7; the criteria for a Project impact is addressed, but is not correct for the Tustin locations, as noted below. The methodology for identifying traffic impacts related to this Project appears flawed, thereby invalidating the conclusions. 4. MND, pages 2-5 and 3-1; do not clearly indicate if the project site has an operating use (if operating, what size and type), is currently vacant, etc. This information needs to be provided to determine if the Traffic Study assumptions are correct. 5. Traffic Study, page 7; also does not detail the sizes and types of uses for the existing developments at the Project site. The LSA Traffic Study describes the existing uses as Project "entitlement", which suggests the assumptions may be theoretical rather. than actual. This could significantly impact the accuracy of the Project analyses. 6. Traffic Study, page 22; the Project evaluations for years 2012 and post-2030 are described to be based on "the net difference in trips between the proposed project and the...", "existing land uses for the building" and "full entitlement on site", respectfully. The existing versus proposed land uses, however, may have significantly different trip characteristics (i.e., office versus industrial) so even if the "baseline" trip generation totals are equal, their traffic patterns and resulting effects may not be interchangeable. Mr. Trevor Lottes MND for Irvine Crossings April 2, 2008 Page 2 7. Traffic Study, page 22; by only addressing the net difference in trips (for years 2012 and post-2030) there are a significant number of Project related trips that are not accounted for in the MND analyses. This MND and Traffic Study actually document the fact that significant numbers of Project related trips are not mitigated. An example of this is made clear by comparing the Project traffic volume assumptions for the "Existing + Project" analyses to the year 2012 analyses (and would also apply to the post-2030 analyses). If the "without Project" conditions are subtracted from the "with Project" conditions for the two analysis periods ("Existing" and "year 2012") at the three study intersections along Barranca Parkway and other study intersections, the differences in Project traffic volume assumptions for the two study periods are significant. 8. Traffic Study; it can be seen from the Tables and ICU sheets for the year 2012 and post- 2030 analyses that some study intersections are projected to experience a decrease in traffic with the addition of the Project. This defies logic since there are net trip generation totals of 2,005 daily, 187 AM peak hour, and 206 PM peak hour trip ends shown in Table A, that are supposed to be added to the surrounding street system. 9. Traffic Study; it is recognized that the Project traffic volumes for "Existing + Project" were distributed manually based on the ITAM regional trip distribution patterns, which differs from the methodology used for the year 2012 and post-2030. Based on the results, however, it appears the "Existing + Project" methodology is more valid and should be applied to the year 2012 and year post-2030 analyses as well. 10. Traffic Study, page 24; we do not understand the logic of providing "Existing + Project" analyses, but then disclaiming the results as being provided for "disclosure purposes" and only mitigating year 2012 and year post-2030 impacts. It is of further concern when one discovers that those future conditions analyses, assume some significant road improvement measures, to have been constructed by others. Clear documentation needs to be provided in the MND, of the roadway conditions that currently exist and the future improvements that need to occur, in order to support the proposed development. 11. Traffic Study, Table A; shows Project trip generations, but the Traffic Study text indicates that the ITAM model does not contain land use-based trip rates that can easily be used to determine the trip generation of a land development proposal. Based on the comparisons and findings described in comments above, it appears the future conditions analyses do not adequately reflect the impacts of the assumed trip generation for the Project. 12. Overall, the use of different trip generation rates for trip budget purposes, TDR, ITAM model, and project impact evaluations support the conclusion that the ITAM model may not be an appropriate tool for evaluations of single projects. This IBC methodology is also not conducive to public review of development projects, which is inconsistent with the goals of a public information document (MND). 13. Traffic Study; indicates that the "most recent version" of the ITAM was used for the analyses. The City of Irvine, however, recently requested the City of Tustin to complete Mr. Trevor Lottes MND for Irvine Crossings April 2, 2008 Page 3 a significant effort to verify ITAM assumptions for areas within the City of Tustin. These efforts have been completed and some discrepancies were found that should be corrected as a part of this MND. 14. Traffic Study; there are statements that indicate the future conditions analyses are based on roadway network assumptions envisioned to be in place by the respective analysis periods (year 2012 and post-2030). These assumptions need to be clearly identified for public review and the reasoning for their inclusion may also be required. For example, it is not apparent that the Red Hill Ave/Barranca Pkwy/Dyer Rd intersection includes significant improvements (i.e., added NB right turn lane, added SB through lane and un- striped right turn lane, added EB through lane and un-striped right turn lane, and added WB through and un-striped right turn lane) from existing conditions to year 2012 conditions. Without this clarification, the reader would assume existing geometries to be "in place" unless otherwise informed. 15. Traffic Study, Table B; another assumption included in the Traffic Study and MND is that Barranca Parkway exists as an eight-lane facility, which is not correct. The City of Tustin is designing the improvements to add the fourth lane in the westbound direction on Barranca Parkway. However, information on the additional fourth lane in the eastbound direction (within the City of Irvine jurisdiction) needs to be provided in the MND, and how that is planned to be accomplished. 16. There was a signal progression study completed for Barranca Parkway between Red Hill Avenue and Jamboree Road in February 2006 that assured adequate traffic operations on that roadway based on the planned roadway design, future traffic projections, and traffic signal operations. The City of Irvine's Traffic Engineering staff has reviewed and approved the progression analysis. Given the proposed Project is expected to affect travel patterns on Barranca Parkway, it must be assured that adequate signal progression along Barranca Parkway will be maintained. Any needed mitigations must be made a condition of the Project. 17. Traffic Study, Figure 3; the roadway assignment/distribution percentages should be shown for all the study locations. For example as noted above, one would expect that some Project traffic would access the I-405 freeway at Jamboree Road, but the Traffic Study assumes this will not occur. 18. Previous City of Irvine environmental information indicated that an IBC project would pay a fair share toward the IBC shuttle to offset potential traffic impacts at the MacArthur/Main intersection. It should be recognized that the Project increases office use (some employees may use the Tustin Metrolink station) and the City of Tustin incurs significant costs related to the operations and maintenance of the Tustin Metrolink station. Fair share contributions should also be made toward the Tustin costs of operating the station. 19. There should be table(s) and/or figure(s) that clearly show the existing and future lane geometries used in the traffic analyses. If the evaluations include assumptions of roadway improvements to be implemented by others, then the source(s) of providing these improvements should also be identified. Mr. Trevor Lottes MND for Irvine Crossings April 2, 2008 Page 4 20. The Traffic Study indicates that traffic impacts for year 2012 and post-2030 analyze the net difference in trips between the proposed Project and the existing building and entitlements, respectively. This would not account for the potential trip characteristic differences between and office use and industrial use. This appears to be an on-going inconsistency throughout the various IBC evaluations. These erroneous assumptions could impact the various IBC traffic analyses and policies, which is expected to affect conclusions related to Project and cumulative impacts. 21. Previous DEIR documents indicated that the actual existing trip generations exceeded the current trip budgets for the project sites. If this is the case for this currently proposed Project, it would be further confirmation that actual IBC traffic impacts are exceeding previously approved conditions. 22. The TDR policies serve to exacerbate problems associated with situations where trip budgets appear to be significantly exceeded by the actual developments. In some situations (i.e., General Plan conditions, etc.) where actual development may exceed a projected amount, there are also other sites within the large scale plan, that are developed below their expected trip generation potential. In the IBC, however, the TDR policies result in "unused" trip potential being transferred to other sites and increasing traffic intensity at a new location. This serves to eliminate the potential for under utilized sites to "balance" those sites with excess trip generation. 23. 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. 24. The ITAM traffic model is used to generate "with project" and "without project", traffic projections and the conclusions about significant project impacts are based on these comparisons. This methodology, however, does not account for traffic displaced by potential Project traffic. The result is that only a portion of the Project traffic is identified in these evaluations. Some of the actual Project generated traffic may be "masked' by existing and cumulative traffic that is redirected to other roadways. While this methodology may be appropriate for large scale evaluations (i.e., General Plans, the IBC as a whole, the Tustin Legacy, etc.) where countless interactions between various land uses need to be accounted for through a modeling process, application of this same procedure to individual projects can be problematic and can lead to undisclosed development impacts. When evaluating individual projects, all of their generated traffic should be accounted for and mitigated as necessary. Mr. Trevor Lottes MND for Irvine Crossings April 2, 2008 Page 5 25. The significance thresholds for locations that involve City of Tustin jurisdiction are also incorrect. The City of Tustin uses a "0.010" threshold for non-CMP locations, not the "0.020" threshold applied in the DEIR (i.e., for the Barranca intersections). This correction, combined with other comments in this memorandum, may significantly change the traffic and transportation findings of the DEIR. 26. The TDR transfers are understood to be based on numerical trip generation totals, but when a TDR is made between differing uses (i.e., employment and residential use) as has previously occurred in the IBC at a number of sites, the trip characteristics are not the same. While the trip characteristic effects (i.e., trip distributions, interactions with other uses, trip modes, etc.) noted for one individual project may fall below a significance threshold, the cumulative effects of these changes may be substantial. 27. Traffic Study, Table C; the MacArthur Boulevard ramps at the I-405 are indicated to currently operate at LOS B during the AM peak hour and PM peak hour. This does not appear to accurately reflect current operations (not only intersection operations, but vehicle queuing, ramp meter effects, etc.). The traffic model may therefore be accommodating IBC traffic at this interchange at an unrealistic level. If that traffic is rerouted to other arterial routes and freeway interchanges then the current analyses may not be accurate in its evaluations of impacts in the City of Tustin. Similarly, the intersection of Jamboree Road/Barranca Parkway is shown to be at LOS C for the AM peak hour, but there are significant southbound queues at this intersection that have been observed in the field. 28. Traffic Study, Tables; indicate that for year 2012 and post-2030 analyses several intersections (including Jamboree/Barranca) will operate at unacceptable levels of service. At a minimum the Project should participate on a "fair share" basis to provide the ultimate improvements needed. 29. As previously identified above, the study is based on assumed improvements being in place, which serve to accommodate the Project. These improvements include assumed conditions such as eight-through travel lanes on Barranca Parkway, significant intersection improvements at Red Hill Avenue/Barranca Parkway/Dyer Road, etc. It is our understanding that these and the other assumed traffic improvements, as well as any additional needed mitigations, must be shown to be scheduled for timely implementation, which is currently not the case. 30. A "Red Hill Avenue" study has been jointly conducted by the City of Irvine and City of Tustin that 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 will result from this study. The intersection analyses and assumptions in the DEIR should also be consistent with the Red Hill Study results. 31. The traffic analyses conclusions for the proposed project appear to be dependent on the TDR and existing trip budgets, but those underlying assumptions no longer appear to be valid based on existing and projected conditions documented in the DEIR (i.e., trip budgets being exceeded, existing/future conditions no longer matching approved conditions, changed land use assumptions related to Mr. Trevor Lottes MND for Irvine Crossings April 2, 2008 Page 6 the TDR, etc.). The traffic analysis should address the relation of the proposed Project to actual current conditions and accurate future projections, in order to identify appropriate mitigation improvements. Thank you again for the opportunity to provide comments on the Draft MND for the Irvine Crossings 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 (7.14) 573-3171. Sincerely, Scott Reekstin Senior Planner cc: Elizabeth A. Binsack, Community Development Director Dana Kasdan, Engineering Services Manager Douglas Holland, City Attorney SR:environ/Irvine Crossings MND Comment Letter.doc