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Home My WebLink About07 RESPONSE TO DEIR FOR SHADY CRK MED CTR 05-06-08 AGENDA REPORT MEETING DATE: MAY 6, 2008 TO: WILLIAM A. HUSTON, CITY MANAGER FROM: COMMUNITY DEVELOPMENT DEPARTMENT SUBJECT: TUSTIN RESPONSE TO DEIR FOR CITY OF IRVINE SHADY CREEK MEDICAL CENTER SUMMARY: City Council authorization is requested for the City of Tustin's response to the subject Draft Environmental Impact Report (DEIR) for a General Plan Amendment and Zone Change associated with the proposed development of up to a maximum 150,000 square- foot medical office center, including up to 7,200 square feet of supporting retail uses. The project site is approximately 21 acres and is generally bounded by San Diego Creek to the north, Interstate 405 to the south, and Sand Canyon Avenue to the east. 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 a General Plan Amendment and Zone Change associated with the proposed development of up to a maximum 150,000 square-foot medical office center, including up to 7,200 square feet of supporting retail uses. The project site is approximately 21 acres and is generally bounded by San Diego Creek to the north, Interstate 405 to the south, and Sand Canyon Avenue to the east. The Community Development and Public Works Departments have reviewed the subject Draft EIR. Based on concerns related to traffic, 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 EIR document (see Attachment). City Council Report DEIR -Shady Creek Medical Center May 6, 2008 Page 2 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 Elizabeth A. Binsack Senior Planner Community Development Director Attachment: Draft Comment Response Letter S:\Cdd\CCReports\DEIR Irvine Shady Creek Medical.doc DRAFT COMMENT RESPONSE LETTER May 7, 2008 Bill Rodrigues, AICP City of Irvine P.O. Box 19575 Irvine, CA 92623-9575 SUBJECT: DRAFT EIR FOR SHADY CREEK MEDICAL CENTER GENERAL PLAN AMENDMENT AND ZONE CHANGE Dear Mr. Rodrigues: Thank you for the opportunity to provide comments on the Draft Environmental Impact Report (DEIR) fora General Plan Amendment and Zone Change associated with the proposed development of up to a maximum 150,000 square-foot medical office center, including up to 7,200 square feet of supporting retail uses. The project site is approximately 21 acres and is generally bounded by San Diego Creek to the north, Interstate 405 to the south, and Sand Canyon Avenue to the east. A traffic study dated November 2007 was prepared by LSA Associates, Inc. for this "Shady Creek Medical Center" Project ("Traffic Study") and is included in the DEIR. It is recognized that this particular Project is located a relatively significant distance from the City of Tustin. The evaluation processes used by the City of Irvine to evaluate this and other significant projects (i.e., in and near the Irvine Business Center (IBC)), however, have resulted in many unresolved concerns and unanswered questions. We therefore believe that this Project, which results in significant land use intensification, should not be approved until the various, previously identified, outstanding technical issues are resolved. The various outstanding issues can be referenced from previously submitted City of Tustin comments on City of Irvine projects/environmental documents. They include, but are not limited to: the General Plan Amendment and Zone Change for the PA 40 and PA 12 project, the Mitigated Negative Declaration for the project at 17871 Von Karman Avenue, the Notice of Preparation for the project at 16752 Armstrong Avenue, the DEIR for the projects at 16541 & 16542 Millikan Avenue, among others. A number of the outstanding issues are also applicable to this Project/DEIR and need to be resolved. The following comments focus more specifically on the transportation and traffic analysis contained in the Traffic Study for the Project, prepared by LSA Associates, Inc. dated November 2007: 1. In Figure 3; the sum of the distribution percentages shown is only 84%, rather than 100%. 2. On page 18 there is a discrepancy between the assumptions shown in Figure 3 and Figure 4. In Figure 3 approximately 19% of distribution is for Sand Canyon south of Alton Parkway, but 27% is shown in Figure 4. Mr. Bill Rodrigues DEIR for Shady Creek Medical Center May 7, 2008 Page 2 3. On page 18 it is indicated that the ITAM model assumes project site connections at Sand Canyon and Valley Oaks Drive (two connections), but none at Alton Parkway. The ITAM project access assumptions differ significantly from the proposed accesses and it does not appear that corrections were made to the ITAM model, prior to using the model for the Project traffic analyses. 4. Figure 4 shows significant AM and PM peak hour Project traffic volumes at the Sand Canyon / Barranca intersection, but Table E (as well as other tables in the Traffic Study) shows no change in "ICU/delay" between "With" and "Without" project conditions. This again highlights past comments, which state concerns/problems regarding the analysis methodology being used (which "masks" actual project impacts) to analyze this development project. The Shady Creek Project generates traffic at this intersection (as documented in Figure 4) that should be shown to result in Project related "ICU/delay" increase that are much greater than "zero". 5. Similar to comments in number 4, the Jeffery / Alton intersection also shows no Project related responsibility ("zero" ICU/delay increase) that proportionally relates to the traffic volume increases being generated by the Project at this intersection. 6. Examples in this Traffic Study that further highlight our previous comments/concerns include: - Figure 3 shows 6% of Project traffic (5,729 total ADT) using Jeffery Road, south of Alton Parkway; but Table C shows no ADT increase with the addition of the Project (68,700 ADT "No-Project and 68,700 ADT "With-Project"). - Table D actually shows an ADT decrease (for this same section of Jeffery Road) with the addition of the Project (69,400 ADT "No-Project and 69,300 ADT "With- Project"), which is not reasonable and not consistent with Figure 3. It should also be remembered that the Project involves an intensification of land use from recreation to medical office/retail/restaurant. Figure 4 of the Traffic Study shows Sand Canyon Avenue south of Alton Parkway to carry 27% of the total Project traffic (5,729 ADT), but Tables G and H show an increase of only 500 ADT due to the Project. 7. We concur with the Traffic Study findings that Sand Canyon Avenue should not be "downgraded" and the proposed improvement to a six-lane configuration should be maintained. Based on the discussion on page 38 of the Traffic Study, it appears the Project should provide "fair share" contributions toward the future improvement of Sand Canyon Avenue to a six-lane, Major arterial configuration. Thank you again for the opportunity to provide comments on the Draft EIR for the Shady Creek Medical Center. 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. Mr. Bill Rodrigues DEIR for Shady Creek Medical Center May 7, 2008 Page 3 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: Elizabeth A. Binsack, Community Development Director Dana Kasdan, Engineering Services Manager. Douglas Holland, City Attorney SR:environ/Irvine Shady Creek Medical Center Comment Letter.doc