HomeMy WebLinkAbout12 PROPOSED FIRST AMENDMENT TO STANDARD PACIFIC ENA1TY O
AGENDA REPORT
,4,4F
MEETING DATE:
(Cell
FROM:
FEBURARY 5, 2013
JEFFREY C. PARKER. CITY MANAGER
JOHN A. BUCHANAN, PROGRAM MANAGER
Agenda Item 12
Reviewed.'
City Manager
Finance Director 1A
SUBJECT: STANDARD PACIFIC CORPORATION PROPOSED FIRST
AMENDMENT TO THE EXCLUSIVE AGREEMENT TO NEGOTIATE
(ENA)
SUMMARY:
The City and Standard Pacific Corporation ( "Standard Pacific" or "Developer ") entered
into an Exclusive Agreement to Negotiate (ENA) for Tustin Legacy Disposition Package
1B on July 17, 2012. This proposed amendment to the ENA extends the period for
negotiation to June 14, 2013 and proposes to include an additional portion of
Disposition Package 6, known as 6A.
RECOMMENDATION:
1. Authorize the City Manager to execute the attached First Amendment to the ENA
between the City of Tustin and Standard Pacific Corporation (Developer), subject to
any non - substantive modifications as may be recommended by the City's special
real estate counsel or the City Attorney.
2. Find that the direct negotiation of 6A will provide additional benefits to the City that
are not available from the public at large or others who might reasonably expect to
respond to a solicitation and that a solicitation process would not produce any
advantage for the City.
FISCAL IMPACT:
With execution of the ENA, the Developer deposited a $100,000 good faith deposit to
fund the expenses incurred by the City during the negotiation of a Disposition and
Development Agreement ( "DDA "), a Development Agreement ( "DA "), and any other
agreements directly associated with the project. There will be near to long -term
financial impacts of any subsequent DDA and DA. These impacts will be evaluated
during the negotiation process and reported with the submission of the DDA and DA to
the City Council for consideration.
907185.1
Agenda Report – Standard Pacific Corporation
February 5, 2013
Page 2 of 6
BACKGROUND:
The initial negotiating period (180 days) commenced on July 17, 2012 and ended on
January 13, was extended for an additional 30 days to February 13 with the consent of
the City Manager. Under the ENA, the initial negotiating period may be extended for
two additional 30 -day periods if the City Manager has determined that both parties are
diligently negotiating in good faith.
Staff has reviewed options to accelerate the construction of backbone infrastructure at
Tustin Legacy. One of the challenges to maintaining current momentum is the
construction of Peter's Canyon Channel improvements. In March 2003, a Joint
Cooperative Agreement (No. D02 -119) was entered between the City and the Orange
County Flood Control District (OCFCD) and subsequently amended in June 2004. This
agreement restricts development within the Master Developer Footprint until a contract
for Peter's Canyon Channel Improvements has been awarded. Under this agreement,
award of the contract and commencement of construction of the channel improvements
must take place prior to the issuance of certificates of use and occupancy for the 1001 st
residential unit or certificates of use and occupancy on more than 270 acres of land.
Subsequent to the execution of this cooperative agreement, the City has entered into
two DDAs in 2012 for Disposition Packages 2A (The Irvine Company) and 1A -North (St.
Anton Partners) for a combined 758 residential units. Disposition Package 1B which is
being negotiated with Standard Pacific Corporation is currently proposed at 238 units;
the combined residential unit count for the three residential projects is 996 units.
City funding sources for Peter's Canyon Channel improvements are not immediately
available; this Amendment proposes that the Developer will advance funding for the
Peter's Canyon Channel Improvements including the Moffett Avenue Bridge. The
Developer will be reimbursed with land sale proceeds from the sale of property to the
Developer. The Amendment proposes that the DDA will have development occur in two
phases.
Phase 1— Developer will be responsible for the following:
a. Importation of approximately 500,000 cubic yards of dirt from the City -
owned Tustin Legacy property known as Disposition Package 7.
b. Design and construction of all in -tract local streets, parks, greenbelts,
sidewalks, pathways, neighborhood signage, wet and dry utilities, and
recreation facilities and amenities associated with the comprehensive
development of the Property. The central park shall be approximately
than 6.1 acres and the greenbelts shall not be approximately 3.8 acres.
C. Construction of the following infrastructure improvements identified in the
Tustin Legacy Backbone Infrastructure Program:
1. Moffett Avenue from Park Avenue to Jamboree Road,
907185.1
Agenda Report – Standard Pacific Corporation
February 5, 2013
Page 3 of 6
2. Park Avenue from Legacy Road to Moffett Avenue,
3. Backbone storm drain related to the project,
4. Backbone dry utilities related to the project.
d. Design and construction of not more than 200 single family homes in 4
product types.
Phase 2— Developer will be responsible for the following:
a. Construction of the following infrastructure improvements identified in the
Tustin Legacy Backbone Infrastructure Program:
1. Moffett Avenue Bridge spanning Peter's Canyon Channel.
2. Peter's Canyon Channel Improvements within the City.
3. Peter's Canyon Trail Improvements within the City.
b. Design and construction of not more than 175 single family homes in 4
product types.
The total amount of acreage proposed with the inclusion of the 6A Property is 86.5
acres; the net developable site is approximately 59.5 acres for the combined parcels.
The amendment proposes that the DDA will require the Developer to purchase the
property in two phases. The Phase 2 property will be retained by the City and will be
conveyed contingent upon the Developer's performance in Phase 1 and demonstrated
financial capacity to perform in Phase 2.
The cost for the design and construction of the infrastructure backbone improvements
for Disposition Packages 1 B and 6A including bridge and channel improvements are
estimated at approximately $37,266,000. The Tustin Legacy infrastructure Backbone
fee for both parcels is estimated at approximately $16,900,000. As indicated above, the
estimated cost of construction will exceed the backbone fees by approximately
$20,366,000. Although the land price is currently being negotiated, an internal analysis
indicates there will be sufficient revenue from the sale of Phase 1 and 2 to reimburse
the Developer for monies advanced for the construction of the all improvements
including the Moffett Avenue Bridge and the Peter's Canyon Channel improvements.
By combining the two Disposition Packages the following will be achieved.
• A global approach to the construction of infrastructure and grading issues
impacting 1 B and 6A.
A reduction in the City's on -going maintenance and water mitigation expenses for
the undeveloped portions of Tustin Legacy.
907185.1
Agenda Report — Standard Pacific Corporation
February 5, 2013
Page 4 of 6
• Minimize the City's risk because the Developer will finance and install all of the
designated Tustin Legacy Backbone Infrastructure.
• Accelerate the ability to develop Disposition Package 7, that is, the area north of
Moffett Avenue and east of Tustin Ranch Road.
• The consolidation of 1 B and 6A will avoid disjointed development.
• An enhanced circulation system within the combined parcels for vehicles and
pedestrians.
• A central location for the community park and recreation facilities that could not
be achieved under with the development of two separate parcels. In addition,
larger facilities by creating up to two acres of additional park space (totaling 6.1
acres) and additional greenbelt areas (totaling 3.8 acres).
• Consistency of products and quality across the site.
• Larger lots than if 1 B and 6A were developed separately.
Direct Neaotiation
Since 2002, the City has implemented the disposition of City -owned property through a
variety of methods. In April 2011, the Council adopted a Disposition Strategy for the
Master Developer Footprint. Under the Disposition Strategy, the Council has the
authority to dispose of property through a solicitation and proposal process or, in certain
circumstances, by direct negotiation.
1. Developer Solicitation Process. The Disposition Strategy sets forth a two -step
process for selection of a developer that involves review of several proposals
prior to a final determination. Specifically, Section 7.4 specifies a marketing and
developer selection process in which (a) a panel of experts selected by the City
interviews interested and panel- recommended developers and recommends to
the City Council, for approval by the Council, a list of the 3 most highly qualified
developers, and (b) a more detailed RFP is requested of /submitted by the 3
selected developers and evaluated by the evaluation team. Based on the
recommendation of the evaluation team, the City Council makes the final
determination. (Chapter 7.4 and Executive Summary at p. E -2).
2. Direct Negotiation. The Disposition Strategy also includes other provisions that
would allow direct negotiation under certain circumstances. For example:
• "The City, particularly on the residential Disposition Packages, will also
reserve the flexibility to offer subsequent rolling take -downs or Disposition
Packages to builders based on performance." (Executive Summary at
page E -3).
• "Opportunities for individual developers who demonstrate success on
initial development opportunities within the Project to be provided with
907185.1
Agenda Report — Standard Pacific Corporation
February 5, 2013
Page 5 of 6
rolling take down options on future phases or segments should also be
considered ..." (Chapter 4, at page 37)
• 'The operational approach under the proposed Disposition Strategy
focuses on these infrastructure needs and market factors by identifying a
group of potential parcels to be sold to single developers in an amount of
acreage large enough to achieve economies of scale. "(Chapter 6, at page
59).
• 'The Disposition Strategy also allows direct marketing to end business
users." (Chapter 7, at page 70).
• Under this direct negotiation process, the City Council may elect to offer a
property for sale to a developer or other business entity. In practice, this
approach is recommended where the Council is able to determine that the
direct marketing of property would provide additional benefits to the City
that are not available from the public at large or others who might
reasonably expected to respond to a solicitation and that a solicitation
process would not produce any advantage for the City or make it
practically impossible for the City to achieve what it requires
3. Timing of Disposition of Parcels. The Disposition Strategy makes clear that
parcels may be taken out of order:
• "Other Disposition Packages could also proceed when market
opportunities and land value considerations present themselves and when
infrastructure costs can be reasonably accommodated." (Chapter 6, page
59).
• 'Tustin will retain the flexibility to respond to property interest and market
conditions." (Chapter 7, page 70).
4. Justifications for Direct Negotiation.
• Standard Pacific was chosen as the proposed developer of Disposition
Parcel 1 B on the basis of the selection process described in the
Disposition Strategy.
• The Disposition Plan provides flexibility to the City to vary the timing of its
disposition of parcels and to offer subsequent take -downs to residential
developers on the basis of performance. It also permits the City to
aggregate parcels to achieve economies of scale.
• Parcel 6A is adjacent to and integrally related to Parcel 1 B in terms of its
infrastructure, roadway access and land use and zoning designations.
Each is part of Planning Area 15, neighborhood G under the Tustin
Specific Plan and is zoned for single - family residential uses.
907185.1
Agenda Report — Standard Pacific Corporation
February 5, 2013
Page 6 of 6
• Due to the irregular size and shape of Parcel 1B, development of Parcel
6A with Parcel 1B allows for a more efficient and well - planned
community.
• The concurrent grading and construction of infrastructure on Parcels 1B
and 6A allows for much greater efficiency and cost - effectiveness for the
City and the developers of those parcels than would separate
development.
• The parcels were not subject to a single Disposition Package only
because of the limitations imposed on the City's ability to develop more
than 1,000 units of housing prior to development of the Peters Canyon
Channel improvements; as a condition to the take -down of Parcel 6A,
Standard Pacific will be required to complete the Peters Canyon Channel
improvements.
• Competitive bidding in this situation would not produce an advantage to
the City. Standard Pacific has previously been selected for similar
development in the City. The expansion of the number of units to be
developed by Standard Pacific will allow the City to achieve a more well -
planned community and greater economies of scale with respect to
grading and infrastructure. It will also permit early completion of the
Peters Canyon Channel improvements which will benefit the City.
As a result, Staff recommends that the City Council find that the direct negotiation of 6A
will provide additional benefits to the City that are not available from the public at large
or others who might reasonably expect to respond to a solicitation and that a solicitation
process would not produce any advantage for the City.
907185.1
FIRST AMENDMENT TO
EXCLUSIVE AGREEMENT TO NEGOTIATE
(DISPOSITION PACKAGE 1B)
THIS FIRST AMENDMENT TO EXCLUSIVE AGREEMENT TO NEGOTIATE
(DISPOSITION PACKAGE 113) ( "First Amendment ") is made as of February 5, 2013 (the
"Amendment Effective Date "), by and between THE CITY OF TUSTIN (the "City ") and
Standard Pacific Corp., a corporation organized and existing under the General Corporation Law
of the State of Delaware ( "Developer "). The City and Developer are individually referred to as
a "Party" and collectively referred to as the "Parties ".
RECITALS
This First Amendment is entered upon the basis of the following facts, understandings
and intentions of the Parties.
A. The Parties entered into that certain Exclusive Agreement to Negotiate
(Disposition Package 113), dated as of July 17, 2012 (referred to herein as the "Original
Agreement ") with respect to certain land referred to therein as the 111B Property."
B. The Original Agreement, as amended by this First Amendment, shall hereinafter
be referred to as the "Agreement ".
C. Pursuant to the terms of the Original Agreement, the City Manager granted a 30
day extension of the term of the Original Agreement, to February 13, 2013.
E. The Parties have agreed to modify the terms and conditions of the Original
Agreement on the terms set forth herein to (1) extend the term of the Agreement and (2) include
certain land referred to herein as the "6A Property" (defined below) which comprises a portion
of Tustin Legacy in order to allow the City and Developer to achieve a more well - planned
community and greater economies of scale with respect to grading and infrastructure.
AGREEMENT
NOW, THEREFORE, in consideration of the mutual terms, covenants, conditions and
promises set forth herein, the City and Developer agree as follows:
1. Definitions. All capitalized terms used herein shall have the definitions given in
the Original Agreement, unless otherwise expressly stated herein. From and after the
Amendment Effective Date, the following terms used in the Agreement shall have the meaning
set forth below:
(a) "Amended Project" shall mean the development of the Property with
approximately 375 single family homes in 4 product types, 6.1 acres of park and 3.8 acres of
greenbelts and such additional in -tract infrastructure and amenities described in Schedule "B -1"
attached to the First Amendment and incorporated by this reference into the Agreement.
(b) "First Amendment" shall mean this First Amendment to Exclusive
Agreement to Negotiate (Disposition Package 1 B).
(c) "Property" shall mean the 1 B Property and the 6A Property, collectively.
2. Negotiation in Good Faith; Extension of Term.
(a) Each of the Parties acknowledges that the other has negotiated diligently
and in good faith during the initial period of the Original Agreement and that reasonable and
sufficient progress has been made toward the fulfillment of the requirements of the Original
Agreement. On that basis and notwithstanding anything to the contrary set forth in Original
Agreement, the Parties agree to extend the Agreement to June 14, 2013 (the "Amended
Termination Date ").
(b) Developer may request from the City an extension of the Amended
Termination Date. The Amended Termination Date may be extended by the mutual consent of
the City and Developer for up to two (2) additional periods of thirty (30) days each.
(c) The City hereby delegates to the City Manager, or his or her designated
representative, the authority to agree to grant the extensions specified in Section 2(b) of this First
Amendment upon determination by the City Manager or his or her designated representative in
their sole and absolute discretion that Developer has negotiated diligently and in good faith and
that reasonable and sufficient progress has been made toward fulfillment of the requirements of
this Agreement.
(d) No such extension of time shall be effective unless it is in writing.
3. Property. The property described by Disposition Package 6A is comprised of a
portion of the property referred to in the Navy transfer documents as "I -H -1, I -H -7, and I -H -8 ",
and is further legally described and depicted on the Site Map attached as Schedule A -1 to this
First Amendment and incorporated into the Agreement by this reference (the "6A Property ").
4. Definition of Property. Wherever the term "1B Property" is used in Sections 2
through 10.15 of the Original Agreement, it shall be replaced with the term "Property" as defined
in this First Amendment in order to reflect the addition of the 6A Property to the Project.
5. Definition of Project. Wherever the term "Project" is used in Sections 1.7
through 10.15 of the Original Agreement, it shall be replaced with the term "Amended Project"
as defined in this First Amendment in order to reflect the modifications to the Project described
in this First Amendment.
6. Amendments to Text of Original Agreement.
(a) Section 1.8 of the Original Agreement is hereby deleted in its entirety and
replaced with the following:
"1.8 The property described by Disposition Package 1B is
comprised of a portion of property referred to in the Navy transfer
2
documents as 1-1-1-1, I -H -7 and I -H -B" and is further legally described and
depicted on the Site Map attached as Schedule "A -1" to the First
Amendment (the "1 B Property ")."
(b) Section 3.5 of the Original Agreement is hereby amended as follows:
(1) clause (a) thereof is modified to read: "(a) pursuant to the RFP
selection process, the selection by the City of Developer pursuant to the First
Amendment, the RFP or any modification or defect thereto, or any information set forth
therein,"
(2) clause (y) thereof is amended to read: "(y) the right to protest the
RFP and /or the terms or selection process pursuant to the RFP or the selection of
Developer for exclusive negotiations with respect to the 6A Property and the Amended
Project pursuant to the First Amendment."
(c) Section 5.2.1 of the Original Agreement is hereby deleted in its entirety
and replaced with the following:
"521 Essential Terms. Developer shall acquire the Property from the City
in two phases. The terms and conditions of the conveyances, including but
not limited to the manner of the conveyance, the conditions precedent to
conveyance and the amount of the purchase price, shall be determined as
part of the negotiation of and detailed in the DDA, provided that
(a) Developer acknowledges and agrees that the purchase price for the
Property shall be consistent with the overall site plan attached to the
Agreement as Schedule "A -1" and with the Amended Project proforma to be
submitted by Developer to the City in accordance with the requirements of
Section 6.6(b) of the Agreement and (b) the Phase 2 property will be
retained by the City and will be conveyed based on the Developer's
performance in Phase 1 and demonstrated financial capacity to perform in
Phase 2."
(d) Section 5.2.5 of the Original Agreement is hereby deleted in its entirety
and replaced with the following:
"5.2.5 Tustin Legacy Backbone Infrastructure Program Fair Share
Contribution. In connection with development of the Property, Developer
shall make a Fair Share Contribution to the Tustin Legacy Backbone
Infrastructure Program based on the allocations to the Property in the City's
Tustin Legacy Backbone Financing Program — 2011 as updated from time to
time. Pursuant to such plan, the Fair Share Contribution allocated to the 1B
Property is currently estimated at $9,031,842 and the Fair Share
Contribution allocated to the 6A Property is currently estimated at
$7,902,862. The Fair Share Contribution shall be collected for each phase at
close of escrow for such phase under the DDA and shall be subject to
adjustment based on refined design information, updates to the benefit
3
analysis or availability of any outside funding sources and adjustments in
the construction cost index, as appropriate, as may be agreed by the Parties
in the DDA.
(e) Section 5.2.7 of the Original Agreement is hereby deleted in its entirety
and replaced with the following:
"5.2.7 Construction of In -Tract and Backbone Infrastructure. The
Developer will be responsible for all costs of any necessary in -tract
improvements, including those identified for the Property in Schedule "B -1"
as Phase I, clauses (a) and (b). The Developer will also construct, on behalf
of the City, certain Backbone Infrastructure Improvements identified in
Schedule B -1 as Phase I, clause (c) and Phase II, clause (a). In the event the
Developer commences construction of any of the Backbone Infrastructure
Improvements prior to Developer's payment of its Fair Share Contribution,
the Developer shall receive a credit against Developer's Fair Share
Contribution for the cost of such work. In addition, the costs to be incurred
by Developer in construction of the Backbone Infrastructure Improvements
for the Project are anticipated to exceed the total Fair Share Contribution of
Developer. For any construction of the Backbone Infrastructure
Improvements performed following payment of Developer's Fair Share
Contribution, the City shall reimburse the Developer for the cost of such
work. The DDA will provide for a reimbursement agreement in the
standard form used by the City Department of Public Works, with additional
modifications agreed to by the Parties, with respect to Backbone
Infrastructure Improvements constructed by Developer.
(f) Section 6.6 of the Original Agreement is hereby amended by renumbering
the existing text as subsection (a) and adding at the end thereof a new subsection (b) as follows:
"(b) On or before April 1, 2013, Developer shall submit, in the same
Business Plan format provided in the RFP Response or as otherwise
requested by the City:
(i) revised overall cost and revenue estimates and Amended Project
cost and revenue data including information on the Amended Project's
financial return adequate to enable the City to evaluate Developer's business
offer and the economic feasibility of the proposed development of the
Amended Project, as proposed, on the Property;
(ii) a comprehensive Amended Project proforma demonstrating (x)
the feasibility of the Amended Project by phase including a Static Analysis
and a Cash Flow Analysis by quarter, and (y) land takedown by phase; and
(iii) an Amended
horizontal improvements
phase.
Project schedule for construction of in -tract
and Backbone Infrastructure Improvements by
rd
The financial proformas for the Project shall reflect any comments the City
provides to Developer on the preliminary site plan."
(g) Section 7.1 of the Original Agreement is hereby amended by deleting the
tern "Disposition Package 1B" in the first sentence and replacing it with "the Property and the
Amended Project."
(h) Section 9.3 of the Original Agreement is hereby amended by deleting the
term "Disposition Package 1 B" therein and replacing it with "the Property ".
7. Additional Developer Covenants and Agreements. Developer hereby
covenants and agrees that:
(a) The release by Developer in Section 3.5 of the Original Agreement is
applies with respect to the Property and the Amended Project and to all information provided by
the City with respect thereto, and to the selection of Developer by the City as proposed developer
for the 6A Property as described in this First Amendment. Accordingly, Section 3.5 (Release),
as amended by this First Amendment, is hereby restated as of the Amendment Effective Date as
though fully set forth in this First Amendment.
(b) The acknowledgements of Developer in the Agreement, including without
limitation, those contained in Section 5.2.6 (CFD), Section 6.9.3 (Hazardous Material
Assessment), and Section 6.9.4 (Insurance) of the Original Agreement, shall apply to the entirety
of the Property and the Amended Project and are hereby restated as of the Amendment Effective
Date as though fully set forth in this First Amendment.
8. Modification to Exhibit A. Exhibit A (111 Property Legal Description and Site
Map) is hereby deleted in its entirety and replaced with the Property Legal Description and Site
Map attached hereto as Schedule A -1.
9. Authority. The persons signing below represent that they have the authority to
bind their respective party, and that all necessary board of directors', shareholders', partners',
agency's or other approvals have been obtained.
10. Counterparts. This First Amendment may be signed by different parties hereto
in counterparts with the same effect as if the signatures to each counterpart were upon a single
instrument. All counterparts shall be deemed an original of this First Amendment.
11. Agreement in Full Force and Effect. Except as otherwise expressly modified
by the terms of this First Amendment, the Agreement remains unchanged and in full force and
effect.
[signatures on following page]
E
IN WITNESS WHEREOF, the City and Developer hereto have executed this Agreement as of
the date set opposite their signatures.
Dated:
APPROVED AS TO FORM
By:
David Kendig, City Attorney
Armbruster Goldsmith & Delvac LLP
Special Tustin Counsel
Amy E. Freilich
Dated:
0
"CITY"
City of Tustin
Jeffrey C. Parker
City Manager
"DEVELOPER"
Standard Pacific Corp.
In
Ted McKibbin, President
Southern California Coastal
By:
Gary Jones, Vice President
Land Acquisition
Southern California Coastal
Schedule "A -l"
Property Legal Description and Site Map
LEGAL DESCRIPTION
Lots 8, 9, 10, 1 l 12, 13, 14, CCC DDD, FFFF, MM, 00, PP, QQ RR TT, SS 000 00000,
VV, UU of Tract No 17404 in the City of Tustin County of Orange State of California as
shown on a map filed in Book 884, Pages 1 to 14, Official Records of Orange County
Califorma
SITE MAP
et' XAXr,11�''J °
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24 `0reg�� \o l 13 U 4k gJ-
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iv 0` =20 19 X11 � 14 7
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Schedule `13-P'
Amended Proiect Description
The Property will be developed in two phases as generally described in this Schedule.
Phase 1— Developer will be responsible for the following:
(a) Importation of approximately 500,000 cubic yards of dirt from the City -
owned Tustin Legacy property known as Disposition Package 7.
(b) Design and construction of all in -tract local streets, parks, greenbelts,
sidewalks, pathways, neighborhood signage, wet and dry utilities, and
recreation facilities and amenities associated with the comprehensive
development of the Property. The central park shall not be less than 6.1
acres and the greenbelts shall not be less than 3.8 acres.
(c) Construction of the following Backbone Infrastructure Improvements
identified in the Tustin Legacy Backbone Infrastructure Program:
1. Moffett Avenue from Park Avenue to Jamboree Road,
2. Park Avenue from Legacy Road to Moffett Avenue,
3. Overall backbone storm drain for a portion of Reach 700,
4. Backbone dry utilities for a portion of Reach 750.
(d) Design and construction of not more than 200 single family homes and 4
product types.
Phase 2— Developer will be responsible for the following:
(a) Construction of the following Backbone Infrastructure Improvements
identified in the Tustin Legacy Backbone Infrastructure Program:
1. Moffett Avenue Bridge spanning Peter's Canyon Channel,
2. Peter's Canyon Channel Improvements from the Railroad tracks
south to the City limit with the City of Irvine,
3. Peter's Canyon Trail Improvements.
(b) Design and construction of not more than 175 single family homes and 4
product types.