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HomeMy WebLinkAboutCORRESPONDENCE RECEIVED AFTER AGENDA DISTRIBUTIONQmuN1 1% May 21, 2013 �rru rGl°u,.oi al ull I�::' �rrrrplrsh��uuir;nt Ciiy (:)'f' hrvi pro Cn , C'N/k< (Dr;ri er 4,,,- a, F10 k),X 1S�!a/l'a, li ,ni J(,, Ms. Elizabeth Binsack Director of Community Development City of Tustin 300 Centennial Way Tustin, CA 92780 d1yofiivkle, or'c (9/19) f N 6000 Subject: General Plan Amendmenti . Amendment 2013-001, and Development Agreement 00 Dear Ms. Binsack: The City of Irvine has received your letter dated May 16, 2013 providing responses to my letter dated May 13, 2013. We are also aware that the Tustin City Council will hold a second reading and consider adoption of Ordinance No. 1432 approving Specific Plan Amendment (SPA) 2013-001 at its meeting tonight. As I indicated previously, we understand that this is an important project to the development of the Tustin Legacy project and educational uses in our communities. Review of the City of Tustin's correspondence dated May 13 and 16, however, confirms the City of Irvine's concerns regarding the apparent lack of adequate traffic analysis for this project. The City's previous comments dated April 24, 2013 and May 13, 2013 regarding this matter stand. Based on confirmation of the City of Irvine's concerns, the City has the following additional comments: Based on an email from Tustin staff dated May 13, it is clear that the study area was defined as only the six intersections and based on minimal changes to those six non -deficient intersections; a larger study area was not considered. The methodology that was used does not adequately address the potential impacts that the proposed project has on the surrounding areas during the AM and PM peak periods. The City of Irvine is extremely concerned with what appears to be a flawed approach resulting in inadequate review and incomplete disclosure of potential impacts of the proposed project under the requirements of the California Environmental Quality Act (CEQA). • Please confirm that the "floating" 3,760 ADT, as a component of the project, was included in the traffic analysis. City of Irvine review of the analysis could not I'I�INJ.I ,'1 0l'J I�I ("YfI I D I'AI"I I:�, IMs.. Elizabeth Binsack IMay 21, 2013 IP age 2 of 3 confirm this. Failure to analyze the "floating" 3,760 ADT would constitute deferred analysis contrary to the requirements CEQA. This failure is likely to mean that required mitigation measures have not been identified and imposed, again in violation of CEQA. In order to properly analyze the project's full traffic impacts, Tustin should provide an updated analysis that identifies how surrounding area roadways and intersections are affected during the AM and PM peak periods with the proposed project. Specifically, this analysis must identify how surrounding area roadways and intersections are affected by the additional 10,000 ADT. We recommend that the study area expand to include, at a minimum, intersections and roadways along Dyer/Barranca between Main St. (in Santa Ana) to Jamboree (in Irvine), Alton between Halladay (Santa Ana) and Jamboree (Irvine), and Warner east to the Jamboree ramps. The City's ITAM 12 baseline model runs for interim -year 2017 and build -out year Post -2035 can be provided to you. We would then expect your traffic consultant (Stantec) to provide the "With Project" ICU/LOS for these locations. The traffic study area used to analyze the additional 10,000 ADT trips to/from Tustin Legacy includes only six intersections immediately adjacent to the project to conclude that an additional 10,000 ADT capacity is available. These additional trips, however, will come and go from a number of directions including the SR -55 to the west, Irvine to the south and elsewhere. This is not considered or analyzed when making increased capacity conclusions. For example, were impacts identified in the interim and build -out scenarios along Barranca Parkway, Alton Parkway or Dyer Road? The 10,000 ADT increase proposed in Tustin could impact these streets and intersections that were not included in the study area. Based on the project description, it appears that 3,760 ADT of the total additional 10,000 ADT being proposed as part of the Amendment will be retained by the City of Tustin and allocated to an unknown location within the Specific Plan at some future date. The City of Irvine is concerned that this "floating" additional ADT (equivalent to approximately 300,000 SF office or 68,700 SF commercial retail) could impact Irvine locations or potentially have an effect on previously - identified improvements along Dyer Road within the City of Santa Ana for which the City of Irvine is responsible for contributing its fair -share. Please indicate how Peak Hour impacts associated with this "floating" 3,760 ADT were analyzed. Failure to analyze the intensity associated with the "floating" 3,760 ADT would constitute deferred analysis contrary to the requirements CEQA. The proposed project represents an increase of 4.6 percent of ADT above and beyond the current allowable intensity for the entire Tustin Legacy site. If all the proposed intensity is located within the current project site, intensity for the site would increase by approximately 130 percent. We question whether an addendum is the appropriate level of environmental review for such an increase. Ms. Elizabeth Binsack May 21, 2013 Page 3 of 3 The project traffic study uses land use assumptions for the 2010 Irvine Business Complex (IBC) Vision Plan Environmental Impact Report (EIR). However, a number of updates and changes to these assumptions have been made since the 2010 IBC Vision plan approval. These changes reflect a redistribution of intensities previously analyzed by the IBC Vision plan EIR to reflect new residential projects in the IBC. It is unclear whether the traffic study has included the latest information in these updates. Furthermore, the traffic analysis should include not only a current baseline of approved projects, but it should include a cumulative impact analysis of all pending projects currently on file with the City. The City can provide you with the appropriate data for this analysis. The City, therefore still requests the opportunity to meet with City of Tustin planning staff to address our concerns. We believe that approval of the project at this time is inappropriate and request that the item be continued until Irvine's concerns have been addressed. If you have any questions, please contact me at 949-724-6451 or via email at etolles _ci.irvine.ca.us. Thank you for your consideration. Sincerely, Eric M. Tolles, S.E. Director of Community Development cc: Tustin City Council Irvine City Council Jeffrey C. Parker, City Manager, City of Tustin Justina Willkom, Assistant Director -Planning, City of Tustin Sean Joyce, City Manager, City of Irvine Sharon Landers, Assistant City Manager, City of Irvine Tim Gehrich, Deputy Director of Community Development, City of Irvine Barry Curtis, Manager of Planning Services, City of Irvine Kerwin Lau, Project Development Administrator, City of Irvine Enclosures: 1. City of Irvine letter dated April 24, 2013 2. City of Tustin letter dated May 7, 2013 3. City of Irvine letter dated May 13, 2013 4. City of Tustin email dated May 13, 2013 5. City of Tustin letter dated May 16, 2013 April 24, 2013 Ms. Justina Willkom Assistant Director -Planning Community Development Department City of Tustin 300 Centennial Way Tustin, CA 92780 Sent via USPS nM lew�k m + ujw�mt u tmw ti Plan Amendment 2013-001, MCAS Tustin Specific Plar Amendment 2013-001, and Development Agreement 2013-002 Dear Ms. Willkom: City of Irvine staff has conducted a preliminary review of the project noted above based on the information provided with the City of Tustin Planning Commission agenda report dated April 23, 2013. Understanding your planned project schedule while, at the same time allowing Irvine to better understand the project and whether it might impact facilities in Irvine, we are requesting to meet with you at your earliest convenience to discuss the following comments and questions. It is unclear from the project description if the proposed intensification of uses within the area bounded by Valencia Avenue, Red Hill Avenue, Warner Avenue and Armstrong Avenue will result in a net increase of intensity and AM, PM and ADT trips above and beyond the 2010 approval of the Specific Plan Amendment. For instance, Scenario 1 results in an increase of 1,064 AM, 972 PM and 6,241 ADT, while Scenario 2 results in 905 AM, 578 PM and 6,239 ADT. Alternatively, clarify if intensity would be reduced in other areas covered within the Specific Plan such that the total intensity and trips remain consistent with the 2010 Specific Plan approval. 2. Page 1.4 of the traffic study includes the following discussion, "Based on the findings of the project traffic impact analysis, no expansion of the study area beyond the limits presented here is warranted." Please provide a response that explains the methodology used as well as the findings of the previous prfl 24, 2013 Page project traffic nU U s. Was the pdor analysis based on the urnpflo ° that them Us a net increase Un AUS, FIM and ADI,,. trij,,)s aboveand beyond time 2010 approval of the Specific Pain , u° n ment? Were, the 4-itersections of Red U°1+UU veno /Barra ca Parkway/[".)ye Fkoad eland Armstrong Averftm/Barrainca Parkway ft�uded 41 tNs pdor analysis? P�Iease provide a response painiinq the iand uses assurned in the nam ysl u and provUde the resu Un Um terser Uori Capacity Utilization and Level U of Seivice for both Project Scenario 1 and AUternative Scenariofor, these two 4,itersections, We lookforward to urs eefimm U'ff°m you and diSCUSSIng the above iterns. If you have any qi.jestloris, please contact mime at 949...724-6363 or via e. --mail at Tirnothy N.liri ,li, UCU Deputy Director of C. un rnunty 1.1)e elopm nt a (via email) Kerwin Lau, Project Development Administrator Sun -Sun Murillo, Supervising Transpoilation Analyst Bill Jacobs, Principal Planner David Law, Senior Planner ( ' ( h 1, 1 -' I -1 -'i G" I l � I n t °ti , � ) f, , '," " � , � r, ), v r l l 'I f, " �m 'I tI )l ( " N' -) " I �h ' � : 1l ']I "I t""' I' 1, t NI a %y, 7, �::,' 01;: "Tpmolhy N. Ge�-iirk-.h, AICF .1 Deputy Director of Cornrnurflty li velopment One Civic, Center Plaza P.O. Box 19575 lirv�ne, CA 92623-9575 Se qn-n,Jl ipt�' rliine,ca.us ........ .. f""� ........ . 111M9,EN8° G OUR FUTURF HONORANG OUR PASI SUBJECI General Flamm Aarm endmin en't 2013-001, MCAS rLIS fin Specific Ran Amendment 2013-001, urn Ilr lopirrient Agreeir-neiint 2013-002 Responses to Comments Dear P�Ar. Gehrich Thank you for your letter dated Aprj� 24, 2013 regarding the sut)ject project, pn your �etter you asked for c�adficahon on traffic related RENTIs and reqUested a meeting to discuss the coamients arid questions, pini response, we have attached the FResponses to Cornments addiressing each iten-i raised. We hope the responses aresafisfactory and if YOU ShOUld Il'-iave any furtheir questions, pease do riot hes�tate to conlact rne at"714.-573- 3115 or via ernaN at j��il Ilk o n c.a. qm, .. . . . .... ...... . . ..... ..... ..... ... ...... ... Siincerepy, Jliusflna Wflfl<01M Ass� stant D'H lw-iniii��:j Attachment ?espons&::I, to Coinm(:minl(.�J�ky of kviine (x;-, Eizabi�llth A. Binsacllu., C'ornmuinily Devek�)piinemut Dhectot X Debra Fitzs4nons, SOCCCD Vice ("Awricellor of Business Seryill l. -es Matt West, Projecl RA,anager Ken i'Jk3hikam:), Tustfin p egacy Dev6qamenl S()i�nces Ailairlager MU ( N'," dI cnwlml'fl Vw' fill ENC%L0" S"WFIE General Man Arnendment 2013-001, Specific Plan Amendnient 20,13-001, Dewelopinent Agreement 2013002, and Agreement for Exchange. of Real Pr(.-)perty between Ch� f IWCAS Tdstin Specific fa r� Environmental Impact Staffement " ',"nvi onmen aJ' it"ript Report, SC)' i No. 94071005 pr c, (,, i i i � r) I fr :, i f c; l i t , f ) , ,c,, ( ) f [ l (,,, t I ! if) � >e I ty GPA 2013 00J. TT 2013 001, DA 2013 rrf Adds uh mVKnwmj micr jl�il lo conirn("wilt", Cm,nment Letter A: City of lrvhv��! N�Smmm�mm AAS Jiisflna V%101kom Cornmonly Do.'%/E'flopjj��Jb jr)q)R,11v1,,A UN of Oak 300 cenmnmWj YNY f1shn CA 9AMo AM Wqaqc! (i'y fit E�, Or "a" N" f I , P'� suwect General Man Amendment 201300t WAS KsUn S"cMc pqr, Amem1ment 2013-001, and De'vemopvvient Aqgr(.a0m11110)Rjjt '2013-002 Dear Nfis VV�Ukcrni: (NY to NWOU Mau 'W" comkowd u gmumaduurarrr x Tf"va':',pv Cd nMmmMWn Monks ah U, Q W r,,, �ryry Vo k")e"Wm undc,,mtand rN,, �waauFa p: and "w" H ""91" Wad NcAws W Innne, we are requeshng to Inue, voUl yoj,a ccmvic"rwaxxb k'� thc", �Irflkmmq c0'"1mmm1N" nrfpll tNiie uCv4'4ion id` 1he 010A hOWWW by VMMCW Awma Rai m" MmmWOV,,� 'Wc"f [hj e jmJ wdt Ecm��uft irm a ne"I mcmose("m4 ink"""mky m-tJ 1,40, PA aml 'Od I4rrdr O'bovc an'd be"yomd ftwr 201 () q)prp',vvar4 !on Nnswoma For Vn AM 972 PNA and '1141 AEH WhHp Sammm 2 tvsmW in gob AG 570 KA WW"O OW Sp" ITU" SUCh thn' HU I "0 P"RWHY MW 1vlp"u i) Cowm4f',n"vIjs 0", Ph," I 2 Page 1 4 of Me haMc I&W, hmm"S of Me p"ev uaum mpad MMQr�" boyman d 0re firrot� Mit ic),Plams the frH fmcfiw""yof Nhc" Agn,-,,ernent for Exchange of feal Properly C', l by 201.3 001, `,trot 2013 001, DA 2013 002 M& JusfinaMfflemm ApH 24, 2013 Plzige 2 f ", i I I y 's 0,. ''fs Uu"� prim anak/sus on [he [h"'d IIrcmty ase 4I" / NI, KI 0 f I d A L) V ]' I 1d ) s a b o v a r') �J Lp o yc)nd t I 'I � 2 0 1 of IllYr." Man P'"I a:"f idillerfl,", vhr il [e 41'knsecbm'�s of k".ocj 3 l 0 Road and AfrriMortg ra� "Ica W kRJ Uld "I U I I �, J)l 4) ( ZH GA iyS iS? PI(NNe �)J'()Vjde a 1(,,S )C Corst'd. � fl)e darul w;es ass'urnod w Ou"'I nna ,Aysis' and re brjtorxdv"ci ("*"apzwlty Mfi�^ahf'm a'Ind Level IA sfmvIce to, both 5"or -arka 'I "v"J 2 for the'se lvvcr intemections We bok forward to meeflng with ycnj and dksmxoMng the above Rerns, ff you have any quesdons, p�ease contact me at 949-724,6363 of va e-gylafl at Sincerey, I irnothy N. Gehdch, AICP Deputy Director of Conirramity Development cc: (via emafl) Bar,fy CUNJI-1, Manager of Flanning SerAces KeirMn I au, ProJect DevOopment Adrnhistralor SUrl-SUrl MILA-MO, SUIpeuvWng Trainsportaflon Arvatyst MH Jacobs, FIrtncipM Mannei� David Law, Senior Mannew 6,4ay 2013 , 'o lit ;nr ka t 0'11aN qj,: , Nu i'll otm p� CPA N9 13 0M,, -',IIA 2013 00 1, DA 20J3 002 AGhm?mVDwmwvnH,mChOCkhM Responses lo(Am-nmemps Responses to (',oimnent Lettei, A iesponsC�55 tO comments we picwidie�] beto�,v Shouk] the (3ity of hvine Ilny, ve ally further (111 acsltloins, wo vvouk) bc, happy tin Ihaave a conremnoc cafl m a rneNAiing N Coilminent, 2As nimad on paps I and 1b UHmTh 23 of theAddendum to lhe� MCAS TusHin F'FilS/F-03, 1ho pvIeN NvoWes a inimnNy o componenis that iN;Addliandurn c.Jcaily tRdOeWes, OrO, 11"(WIllpiciv,ent tlA the pmjeci is U1111a f B oeH Avenue, whla�j fjne ihaffilic Shody anaiyziad amJ delImmined that with tho BeH Avenue mdmmbm there woluld be rcmamd roadvv)y calpacity in the chnuAadon WMem Nee page iq or the Addendwiny The movased roadway capmAy pernss We increase cd Me cu"mH vehWe tilp cap by IODOO amage dalty Lnf)s (A[)r) i'm tho ACAS NsLin Specilric wlthioujt triggerI(ig AgnWalrd adverse dImNs arl Jhe madway syslem. Fho hnafk Study amAged Lheso WHOnal VOs miklg the updaNd background voidde We Am We Imbe Gusimms Camp% Won Plan cmHalhad in ma oamst city or ImUmn TmnspalaUan Anaysh Maddl, Version 12 (PANI 12Y whdi WmMhed r niumber A veNde v0s at MV hUmmmomls and roadway segments surmnindling Us pMea Ihe My of Imbe appmed the JBC Complex Asbn PWn and VaMc sWdy an JWy 13, 2010, whikh INOVIVed the bast ffano tl, e updated backomund tiraNk rlulribeqs Mn ffAhil 12. The addlIbnal madway capaidly meau�(� by the extens�on �:4 Beh Avelme and the fz)viveuuIijn,ibe�, ol: background venllcU(�! lrifo; ANSIUM-0 W, flIP Cky of Winds appiroved IBC Isloin Ran and HAPO 1-2 ix-,,,imiiged lillLN himmose in the WAS I usUn Spimifir PWn kip cap by JOTOO ADr wmmut mswwy in a HOW AMmulImMan IhW wouW lead to inmeased enOrmvvenWI AmpacM lx*ond thom �ha� zlic Rilready kh-,nkfrcd in Lhi(�, H-A�5/UR G,olini ent 3!! As inellik)"Ied illn the fll��slt)Ulse sb0VCI to commerd #L tho Wjcd hwWdes To hmma.An the WAS IWO SpedNic than trip cap, Based on the mlost lecent traffIc fomcast data avaHabla, YOU is flarn PAM 12, m!) defrcenclics occlur wip:pj the prar)oseid p ron ecL Me atest traffic Yoiec&:;t dzit,@ l�m thr, mpior roadways near the Imlect ske as Imemmited In the WHIc study, alue ovem� Y [ovive in vWume compaled to t:)revioiijs (Jaffa, wh1h aho results A betterlOwd al semiccufoiir pirevliousUyslhovvni, The methodo[ogy used to Wine the project (raffic Sludi,,'s sluldf, airea �s consistenilWith othew traffic llmpaO Eiinalyses cavried out in Tiuslin and in IrAna "Me UmUs d Te AW), area vivere iieviemited (fining the course- of the study kmseon no-fxpject %raqsWjs wittl prcij�120 Iraffic toreicam data to veiify whether oi niot sigollilfk.ant Project lionpa(As occuu, as I.mrJefined by (Ille circiulafioill sysire n perfmviance criteria apipliii�ml Rn the studyi beyond tfu:n shm, mea hounda, Basel on the ffiWings of the project huMic Situdy abich detemkmed that theria are no defiOenides in the defined sliudy ama, Ill no exjjj�iialrssioin ()( the Study ailea INgand Um Mnits shmvin in dm�. fetaml was warrar%OA, MY 201 May 13, 2013 Ms. Elizabeth Binsack Director of Community Development City of Tustin 300 Centennial Way Tustin, CA 92780 Subject: General Plan Amendment 2013-001, MCAS Tustin Specific Plan Amendment 2013-001, and Development Agreement 2013-002 Dear Ms. Binsack: The City of Irvine has been made aware that the Tustin City Council will be holding a Special City Council Meeting this evening to discuss the above -noted project. We understand that this is an important project to the development of the Tustin Legacy project and educational uses in our communities. We do however, have specific comments still remaining regarding the analysis of the increased traffic Average Daily Trips (ADT's) to support increased development intensity for the project. On April 24, 2013, the City provided comments before it was considered by the Tustin Planning Commission, and in that letter the City requested a meeting with Tustin planning staff to discuss our concerns (Attachment 1). On May 7, 2013, the City received the City of Tustin's responses to our letter of April 24, 2013; however, we have not had the opportunity to meet and still have outstanding concerns. Our remaining concerns are as follows: The traffic study area used to analyze the additional 10,000 ADT trips to/from Tustin Legacy includes only six intersections immediately adjacent to the project to conclude that an additional 10,000 ADT capacity is available. These additional trips, however, will come and go from a number of directions including the SR -55 to the west, Irvine to the south and elsewhere. This is not considered or analyzed when making increased capacity conclusions. For example, were impacts identified in the interim and build -out scenarios along Barranca Parkway, Alton Parkway or Dyer Road? The 10,000 ADT increase proposed in Tustin could impact these streets and intersections that were not included in the study area. Based on the project description, it appears that 3,760 ADT of the total additional 10,000 ADT being proposed as part of the Amendment will be retained by the City of Tustin and allocated to an unknown location within the Specific Plan at • Ms. 1:'.N airruiir Bnsadk 2 of y some future date, -i..in City of kvine is concerned that this "floating" additionaI ADT (equuiw i rnt to approxirnateiy 300,000 Sim office or 68,700 SF cornrnercial reta H impact ave an effect on sly- nd r°nn8.�iffi dein prows rn in s alo q i)y r Road withiniitN�ni� City off amts Ana ffaan,.i hick the City of kvine is re porn it ll ffrar contributing its fair -share. .the proposed osed project represents an increase of 4.6 percent off ADT above and beyond time current aHowable inter ity for tfie entire` U ti n Legacy site. If iii the proposed irnt rnsity its Boo t d within the current project site, intensity for the site ww uuVd increase Iby approximaWy 130 percent.. We question whether an addendum is the appropriate ieveI of eirnwiin°ornr n rnt i review ffor such an increase, The project tr lfic Stuudy uses i nd use umption for the 2010 irvine Business irn Comp(IBC) Vi bn i='i rn Irnwiro nrnernt i Impact Report (EER). However, rnu.urn°nd r rut updates and changes to these assumptionshave been rnde since the 2010 ill: C Vision pIl n°n approvai, These changes reflect a redi tritwau.ubo n of intensifies previously anaVyzed by time 6C Vision pian SVR to r ffll ct new residentiaa projects in the II113C, it its unci ear whether the traffic study has included the i tet information in these updates, i he City, therefore sti0i requests the opportunity to meet with City of Tustin p1lanning staff to address our concerns. If you have any questions, please contact me at 949-724- 6451 49-7 4- 4511 or via ernail at qLg lip ciwurwirm mc,a,.� . Tha nk you for your consideration. Sincriy4 Eric M, Tones, SE. Director ctor stuff Community Developrri rnt trot Tuu tion Uty Cruw.uncH iu.wwiwnrw Dty uuiim6il effr 6 . �d wmV'uw. d�it:° Illdtwr�w°murdurw" � O t..uffy of Dustin Ju.ustiw°wwww ddiillliru° rn11 Assistant Idir n truw. F:laii.mw,.wiwnmt City off..t..urm tiwr Sean ,loyce, City Managei, deity of trwi ie Sffaroiru t arideir& Assistaiiit City Manager, City of Irvine `yiiw"wru Ili­miriiich, Deputy 116 'Nr twurwi" off Community I ew� i yr eiiiw�t„ City of iw imn is awry i.urtiuu, w"nurdrmm..off: i::l'trurnniuurwd t''3ervii s, City . l iw.e Ilwuiu°iam„.� Kerwwii n Lau, Project t w lllurtrrm.ww rel tydmi,rii tw.... toii , City of trwiriie dwrcII!w°u n.jres: ff. City of II'rviw°wur I1(:�tteu druted 7wpw.ii 24, dw° 113 y. C:� y of tu!u lki I� tter dated May ,7, 2013 May 13, 2013 5:55 PM To. 'Kerwin Lau' Binsadc, Elizabeth-, Willkarrn, .ttustirra, Tim Gehrich; Sura-sura Murilla Subject, RE:.SOCCC t Traffic Study K e° 6y" Sa^,,4rV, i thiiiinik there i be a rniisconc,epttiiimarn that 'a larger area was sttu.rediedt :: adettenmiinne thie tio-nalllstuadyaaurea, which was not the case. Iikathei. ttllhe study area was the boundary of the six inter.secttiininswhun::h :sl[wu:wed that 11he Atte"I's either decre.asedd or did not incirease the UDS at:these iint:erserAlron s to the extent of rmeerdiu^n a uttigattpo n requwureiraweni Seo if yd::nu biok att tthe inutersec"t'inns of rrnst:ru:rra,g)Wairrner and IRed p•ilii iwarner goiin g lib yn iuu- diir �rairi ffuirau7rw the Iproject., litshows Che rarnlfy a OS ii'anci:easeaf.; 'iiina the PM peak. Ihoiurat IRed p...iuii/Waomer wuhliclh went ffrr.:nn'ru and A to a 3 only Ibecause ttilme 10..11 went ffrmairrea , 0 to u61, The LOS at the cpttlher three (peak tiiiru"me Ipericnds either stt:ayeadthf.::.. amnuae u::au° decreased wliwiiclhn was why i1 was d. detterra"allned that a larger study area wasn't wwoanauatted. �I(en Mshika wa Tusturu t.egacy Dever oprnerutt Services Manager Oty of pi 300 Centterur W Malay Iustt:in, CA 32'780 (714)573-3389 • Community Development Department May 16, 2013 Eric M. Tolles, S.E. Director of Community Development One Civic Center Plaza P.O. Box 19575 Irvine, CA 92623-9575 Sent via USPS and email to etollesO-ci.irvine.ca.us TUSTIN BUILDING OUR FUTURE HONORING OUR PAST SUBJECT: General Plan Amendment 2013-001, WAS Tustin Specific Plan Amendment 2013-001, and Development Agreement 2013-002 Responses to Comments Dear Mr. Tolles: Thank you for your follow up letter dated May 13, 2013 regarding the subject project. On May 7, 2013, the City of Tustin provided responses to City of Irvine comments dated April 24, 2013. In our telephone conversation and your most recent letter, you asked for additional clarification on traffic related items and requested a meeting to discuss the comments and questions. In response, we have attached the Responses to Comments addressing each bullet item raised. We hope the responses are satisfactory. If you have any further questions or if you would like to meet to discuss further, please do not hesitate to contact me at 714-573-3031 or via email at ebinsack(&-tustinca.org. Sincerely,� Elizabeth A. Binsack Community Development Director Attachment: Responses to City of Irvine comments in a letter dated May 13, 2013 cc: Dr. Debra Fitzsimons, SOCCCD Vice Chancellor of Business Services Jeffrey C. Parker, City Manager Jeremy Krout, Principal — RGP Planning and Development Services Justina Willkom, Assistant Director — Planning Matt West, Redevelopment Project Manager Ken Nishikawa, Tustin Legacy Development Services Manager 300 Centennial Way, Tu ENCLOSURE 5 H13 • www,tustinca org «>«l >cZ®<»»m»©<?#<2.##£?+<d© V«y®w«¥mzm ?+» #+« #fes 4+m« Agreement 201 02,and greement for Exchange ¥± Real Property between : wof Tustin and South O »f> CountyCommunity Co2e District Addendumlinitial Study ??2 2t 2ff±+22#+?2f3#2?##2 of<2X 2#?? 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Iiiviviv 171�y Clinundill Jeffiw-�Iiw C Paidimv, Cilly !Vmnage4l, 111��JP�V olll Turvivi ,11111mllm,A PNIJ �11�ogn Ass stmo Ocilecim 11211Wnnuig, Cqy o� m.msjjrm Seall Joyce, cITy hqandg1 clilly of 4,10IM1111 shwcln L andefs ?U;SI8!V'o-L:3I% k-dv Murutipcir (,,iit)e in:f 0-inne p # ril Qvehnch, DcTuCy Oulectli!!v d Govn� numly P I muP Coy Nv gle 113,w �Iji, C'wts,, lINmnmqeIl of 1111141nrung Cd�ijll uf lhvo e II a v, aiy ur h1w 0 I (dy cid, Vmmve III PH&II 6,fle�ill Apfl 24 2(1 V�� ry d � � u P �v ir�f �V 11, 9 s b rr 11 1:A I amu' d a it4j P114 I Agreement GPA 2013-001, SPA 2013-001, DA 2013-002 MIT I MIM U, Comment 1: The traffic study area as noted was the six intersections surrounding the project site which showed that the ADTs either decreased or did not increase the LOS to the extent of requiring mitigation measures. As shown in Fig. 3-1 of the April 9, 2013 Traffic Study by Stantec, the 2035 projected ADT volumes increased slightly on Red Hill southbound from 31,000 No -Project to 32,000 With Project, decreased slightly on Armstrong southbound from 6,000 No -Project to 5,000 With -Project, and decreased slightly on Warner westbound from 34,000 No - Project to 32,000 With -Project. As shown in Table 3-1, the intersections of Armstrong/Warner and Red HIII/Warner show an LOS increase only in the PM peak hour at Red Hill/Warner which went from an A to a B only because the ICU went up slightly from .60 to .61. The LOS at the other three peak time periods at these two intersections either stayed the same or decreased. These intersections are the closest to the project site and would receive the most project traffic volumes. Traffic disperses as the distance increases from the project site; therefore, intersections located further away from the project would receive less project traffic and as a result would be impacted less than the analyzed intersections. This ultimately led to the conclusion by Stantec that a larger study area was not warranted, because the study would show there are no impacts on the intersections In the larger study area suggested by the City of Irvine. Comment 2: Bell Avenue supports the provision of additional ADTs within the project site. Although additional ADTs are allocated for general projects within the Planning Area at this time, each individual project will be required to provide a traffic analysis to ensure that each respective project will not have any adverse impact to any intersection, and ensure consistency with the Addendum. This analysis is provided for in the Specific Plan FEIS/EIR. In addition, CEQA requires this analysis for all discretionary projects or projects that could have any significant impacts on traffic. Comment 3: Based on the CEQA analysis, the City and District determined that the Project and its implementation are analyzed in the FEIS/EIR, and that none of the conditions identified in Public Resources Code section 21166 or section 15162 of the CEQA Guidelines apply. The Project and its implementation will not have any effects that are not already examined in the previously certified FEIS/EIR, there are no new mitigation measures required and there are no new significant adverse project -specific or cumulative impacts in any environmental areas that are identified, nor will any project -specific or cumulative impacts in any environmental areas be made worse as a result of implementing the Project. Therefore, the City and District determined that they would prepare an Initial Study and Addendum to: (1) document the City's and District's evaluation that the Project's (and its implementation's) environmental impacts are already adequately analyzed in the FEIS/EIR, (2) document the City's and District's findings with respect to the Project, its implementation, and the City's and District's environmental determinations related thereto; and, (3) document the City's and District's evaluation and determination that a new, supplemental or May 16, 2013 Agreement for Exchange of Real Property GPA 2013-001, SPA 2013-001, DA 2013-002 Project and its implementation. See also response to Comment 4. Comment 4: The traffic study was based on the same version of the Irvine Transportation Analysis Model Version 12 (ITAM 12) recently used for the PA18 Traffic Study submitted to Irvine by the Irvine Company. This is the most recent data available. This new data revised downward the number of ADTs on roadways near the project from the time that the FEIR/EIS was originally certified, and that along with Bell Avenue resulted in unused capacity on the roadway system that could accommodate the additional ADTs. The City of Tustin has not been made aware of any City of Irvine or City of Santa Ana projects that have been approved and/or projects for which there are growth inducing impacts requiring mitigation measures that have impacts on intersections in the City of Tustin. As such, the methodology and data used in the analysis is adequate.