Loading...
HomeMy WebLinkAbout11 EIR 573 MCAS EL TORO 12-7-98AGENDA NO. 11 12-7-98 In t e r-C o rn '. DATE: DECEMBER 7, 1998 TO: FROM: SUBJECT: WILLIAM A. HUSTON, CITY MANAGER REDEVELOPMENT AGENCY STAFF CITY OF TUSTIN RESPONSE TO COUNTY OF ORANGE NOTICE OF PREPARATION OF DRAFT ENVIRONMENTAL IMPACT REPORT NO. 573 FOR THE MCAS EL TORO MASTER DEVELOPMENT PLAN SUMMARY~ ~ TuStin .C~ Council Vai ~ requestedpri°r t° forwarding the attached draft. RECOMMENDATION It is recommended that the City Council authorize staff to forward the attached draft response to the County's Notice of Preparation (NOP) of an Environmental Impact Report (EIR) for the Marine Corps Air Station (MCAS) E1 Toro Master Plan Development. FISCAL IMPACTS There are no fiscal impacts associated with this action. BACKGROUND/DISCUSSION On October 16, 1998, City of Tustin staff received a Notice of Preparation of Draft Environmental Impact Report No. 573 for the MCAS E1 Toro Master Development Plan. The Notice of Preparation is one of the first steps in the preparation of an EIR as required for development projects under the California Environmental Quality Act (CEQA). Respondents are to provide information on environmental issues, reasonable alternatives, potential mitigation measures and reasonably foreseeable cumulative projects within their respective jurisdiction or interests. Comments on the County's Notice of Preparation are due on December 18, 1998. MCAS E1 Toro is an installation to be closed under the Defense Base Closure and Realignment Act of 1990 with closure and realignment of all military activities anticipated by July 1999. The County of Orange has been authorized by the Department of Defense to act as the Local Redevelopment Authority (LRA) and is solely responsible for planning the future civilian reuse of the closing base. City Council Report MCAS El Toro NOP Response December 7, 1998 Page 2 Beginning in 1995 the County initiated Phase I of the reuse planning process that resulted in the identification of three reuse.alternatives for the base. On December 11, 1996, the Orange County Board of Supervisors approved a Community Reuse Plan (CRP) which included a full service commercial passenger and cargo airport estimated to serve approximately 38.3 Million Annual Passengers (MAP) surrounded by aviation-compatible land uses. The County had indicated at this time that John Wayne Airport would be closed and that the existing aviation activities at JWA would be consolidated at the proposed intemational airport at MCAS E1 Toro. This CRP is the only plan formally transmitted to the Department of Defense (DOD) by the County and is currently recognized by the DoD as the only approved Reuse Plan for MCAS E1 Toro. On April 21, 1998, the Board of Supervisors considered four additional reuse scenarios that had been formulated by County staff and discussed with County residents during a number of public workshops on the matter. The plan selected by the Board of Supervisors as the "Proposed Project" indicated that John Wayne Airport (JWA) would be retained in a general aviation and short-haul passenger and cargo role with MCAS El Toro being converted to "Orange County International" (OCX) supporting a full domestic and intemational passenger and cargo role. In this alternative, the two airports would be linked with a transit facility to transport passengers and baggage between the airports. The projected passenger service for this alternative is approximately 23.4 MAP at OCX and approximately 10.1 MAP at JWA (JWA is currently limited to 8.4 MAP) projected at the year 2020. On September 15, 1998, the Board of Supervisors adopted proposed ref'mements that materially reduced non-aviation related high intensity commercial and real estate development around OCX and significantly increased the amount of proPerty proposed to be dedicated to less intense uses such as golf courses, park and open space. This refinement has been commonly referred to as the "Green Plan." It should be noted that the Board of Supervisors have not adopted the proposed "Green Plan" as the official CRP for MCAS E1 Toro. Consequently, the DoD continues to recognize only the 38.3 MAP international airport CRP as the only official Reuse Plan for MCAS E1 Toro. As part of the proposed project, an airport-to-airport light rail-type transit connector is proposed. One 'transit alternative proposed by the County but generally opposed by City of Tustin staff includes an at-grade or elevated rail-line generally along the existing Metrolink and Amtrak rail line from MCAS E1 Toro to the Jamboree Road or Redhill Avenue corridor south to JWA. Tustin staff currently opposes this route as potentially negatively impacting anticipated redevelopment of MCAS Tustin. A separate environmental impact analysis is currently being prepared for release in August 1999 and will be commented on by staff at the appropriate time. City Council Report MCAS E1 Toro NOP Response December 7, 1998 Page 3 The refinements described above have been accomplished in preparation of eventual Board · consideration and adoption of a Master Development Plan in December 1999. Prior to consideration of this plan, the Board of Supervisors must certify an Environmental Impact Report (EIR). Toward that end, the Coimty has now circulated a Notice of Preparation to potentially affected parties and solicited comments on that document. City of Tustin staff have reviewed the document and prepared a draft comment response letter for transmission to County staff (Attachment A). Staff requests that the Tustin City Council review and consider these comments and, if acceptable, authorize its formal transmission to the County of Orange. Dana 0gdon~J - Senior Project Manager Assistant City Manager D0:kd\eltoronop.doc Attachments: 1. Draft comment response letter ATTACHMENT A DRAFT December 8, 1998 County of Orange El Toro Master Plan Development Program Atto: Mr. Bryan Speegle 10 Civic Center Plaza, Second Floor P.O. Box 4048 Santa Ana, CA 92702-4048 RE: REVIEW OF NOP FOR EL TORO MASTER DEVELOPMENT PLAN Dear Mr. Speegle; Thank you for the opportunity to review and comment upon the above referenced document. The City of Tustin has considered the information provided in the Notice of Preparation (NOP) and has prepared the following comments. Please include the information discussed below in the proposed draft Environmental Impact Report for the El Toro Master Plan Development Plan. We would also appreciate a response from you that would clarify the status of'the December 1996 Reuse Plan submitted to the Department of Defense. When will this plan be officially withdrawn by the County of Orange and substituted by the currently proposed/preferred Master Development Plan? 1. Based 'upon a review of the NOP by .the Tustin Engineering Division it appears that the project will significantly impact the City of Tustin's circulation infrastructure. . A detailed traffic study will be required for this project. The study should identify and analyze traffic impacts to roadways within the City. The analysis should be comprehensive in addressing impacts to the Freeways, Transportation Corridors, Arterial Roadways (Jamboree Road, Tustin Ranch Road, Red Hill AvenUe, Portola Parkway, Irvine Boulevard, Bryan Avenue, Edinger Avenue, Barranca Parkway), and provide a realistic evaluation of funding and schedules for MPAH implementation as it relates to this project. 3. The analysis for this project will need to be performed in accordance with the County of Orange's Congestion Management Program/Measure "M" Growth Management Program requirements. . Any traffic analysis of Tustin's circulation system will need to be consistent with current City of Tustin methodologies and utilize the most current Tustin General Plan information. The analysis should identify all measures necessary to mitigate the traffic-related impacts of the proposed project. . The City is concerned that Figure 1-2 of the project location map proposes a rail' line along Jamboree Road in the City of Tustin. We believe that this rail line would result in substantial adverse environmental impacts to the planned residential areas on MCAS, Tustin site. The City of Tustin is Mr. Speegle Comments on NOP for MCAS E1 Toro December 8, 1998 Page 2 , . . 10. 11. already on record opposing any such rail line with OCTA. In addition, there is no existing right-of-way available on Jamboree Road in the vicinity of MCAS, 'Tustin and proposed transit corridors/connector routes along Jamboree Road are not identified in Tustin's General Plan. The City of Tustin requests that the northerly Alternative Route be removed from consideration or analysis in the EIR. In addition, CEQA Guidelines Section 15063(a)(1) states that "all phases of project planning, implementation, and operation must be considered in the Initial Study of the project. CEQA Guidelines Section 15378(a) defines the term "project" to mean "the whole of an action, which has a potential for resulting in a physical change in the environment, directly or ultimately..." CEQA Guidelines Section 15378(c) further clarifies that the term "project does not mean each separate governmental approval." Consequently, we believe that the proposed draft Environmental Impact Report should include an analysis of the environmental consequences of implementation of the proposed connector route rather than wait for an analysis at some future time. The Proposed Project, Alternative C, would increase the John Wayne Airport (JWA) service level to 10.1 MAP. Several of the other Alternatives would also propose to increase the service level above the current 8.4 MAP limitation. At present, flight paths from JWA at the current MAP limitation adversely affect the Tustin community. Any increase in service levels would likely increase incidents of noise and complaints in Tustin and should be identified and mitigated. Page C-2, Statement of Probable Environmental Effects - Land Use and Planning. This section discusses County plan amendments that are necessary to implement the Proposed Project and Alternative B. We want to oppose adoption of a new Policy Implementation Line (PIL). The PIL is part of the County's Noise Element that identifies areas that are noise restricted. By adopting a new PIL the County would include areas that are presently noise restricted within a new 65db CNEL contour. Page C-3, Statement of Probable Environmental Effects- Land Use and Planning. This section states that the Proposed project and Alternative B could result in a conflict with the Air Installation Compatible Use Zone (AICUZ) and the Airport Environs Land Use Plan (AELUP). There is no mention that this conflict will be evaluated and resolved in the EIIL Specific flight tracks need to be identified to fully identify the areas impacted by implementation of the preferred plan and all other aviation altematives. Please provide. Page C-5, Statement of Probable Environmental Effects - Population and Housing. All population and housing projections should be based on OCP-96 Modified (1997) approved by the Board of Supervisors and endorsed by the Cities in Orange County. Page C-14, Statement of Probable Environmental Effects - Transportation and Circulation. The Traffic Study should use OCP-96 Modified (1997) data for analysis purposes. However, it is our understanding that traffic generation figures identified by OCP-96 do not include trips generated by the actual operation of the airport but are currently limited to housing and commercial/industrial trips generated by other areas of the Master Plan. We believe that. these additional airport related trips are required to be identified and' mitigated under CEQA. Mr. Speegle Comments on NOP for MCAS El Toro December 8, 1998 Page 3 12. Page C-24, Statement of Probable Environmental Effects - Hazards. This section should discuss and analyze the 'hazard related to the proposed reuse of the existing JP5 Jet Fuel Line. This NOP does not include the existing fuel line as a hazard to be evaluated. EIR 563 indicated that the fuel line would be retained and used as part of the airport operation. In our May 9, 1996 and October 14, 1996 comments we requested that the EIR include discussions of all environmental impacts (including safety) related to the conversion of the jet fuel line to commercial jet fuel. A large portion of the JP5 fuel line is within the City of Tustin and in close proximity to residentially developed properties. The EIR should evaluate the potential impacts and danger to properties adjacent to the JP5 fuel line, if the fuel line will be reused. 13. Page C-42, Statement of Probable Environmental Effects - Potential Cumulative Projects. This section identifies a number of proposed projects in the vicinity of MCAS, El Toro. How has "vicinity" been defined? MCAS, Tusfin Reuse should not only be included as a cumulative project within the vicinity but also the Tustin General Plan's projected build-out 2020. 14. Section 1.6.2: This section states the Proposed Project has a "20-year planning horizon" pursuant to the requirements of the FAA and will be analyzed in five year increments. Although the impacts associated with project phasing may be useful, the worst case conditions associated with project buildout should be identified for the proposed project and aviation and non-aviation alternatives. · 15. Sections 1.6.2, 1.6.3, and 1.6.4: The EIR analysis should identify and analyze various operational conditions such as arrival/departure procedures and curfews that could potentially mitigate impacts of the proposed project and alternatives. Operational conditions that significantly reduce impacts should be incorporated into the project description and be required to be implemented. 16. Section 2.5.3: The impacts associated with the Non-Aviation Plan (Millennium Plan) alternative needs to be identified. Analyses of the aviation and non-aviation alternatives should be sufficiently similar to allow meaningful comparisons of the benefits and consequences associated with their implementation. Also, the role of John Wayne Airport in conjunction with needs to be identified and analyzed in sufficient detail. A comparison should be possible not only for impact categories but also economic and social effects and growth inducing impacts. 17. Noise receptor locations for noise modeling should be located within the corporate boundaries of Tustin including East Tustin and western portions of.Tustin between Newport Avenue and the 55- Freeway. The previous EIR (#563) did not include any locations within Tustin incorporated boundaries. 18. Any noise level increase of more than 3 dB CNEL between existing conditions and the proposed project/alternatives should be identified as a significant impact, as is generally accepted by noise analysts. The previous EIR only identified areas that would be within the 65 dB CNEL as being significantly impacted. Other areas, such as Lemon Heights, which would have experienced an ~20 dB increase, but were not within the 65 dB CNEL counter, were not considered to be impacted. Mr. Speegle Comments on NOP for MCAS El Toro December 8, 1998 Page 4 Thank you again for the oppOrtunity to comment on this important matter. We look forward to receiving a copy of the draft EIR when it is made publicly available for comment. If you have any questions, please call Mr. Dana Ogdon, Senior Project Manager at (714) 573-3116. Sincerely, William A. Huston City Manager DOSrncas\ltr\eltoronop Christine Shingleton Tim Serlet Elizabeth Binsack Dana Ogdon