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HomeMy WebLinkAbout26 IRV. PLNG AREA 10 04-06-98AGENDA DATE: APRll. 6, 1998 .No. 26 4-6-98 I nte r- Co TO: FROM: SUBJECT: XV[LLIAM A. HUSTON, CITY MANAGER REDEVELOPMENT AGENCY, PUBLIC WORKS, COMMUNITY DEVELOPMENT DRAFT COMMENTS ON PROPOSED CITY OF IRVINE PROJECT, PLANNING AI~.A 10 RECOIVIMENDATION It is recommended that the City Council' direct staff to transmit the attached comment letter to the City of Irvine. FISCAL IMPACT No fiscal impacts are anticipated as a result of the proposed comments.. BACKGROUND/DISCUSSION In May 1997, the City of Irvine circulated to the City of Tustin a Zone Change and Vesting Tentative Parcel Map submitted by the Irvine Company for development of 1,363,540 square feet of Community Commercial, Medical and Science land uses on 49.7 gross acres of land in the City of Irvine. The subject site is bounded by the Santa Ana Freeway on the north, Harvard Avenue on the east, Walnut Avenue on the south and is in close proximity to the I-5 freeway, Jamboree Road and the end of the west leg of the Eastern Transportation Corridor. Tustin staff review at that time revealed that the City of Irvine had failed to perform any environmental review of the project. Consequently, the City oflrvine postponed the project. In February, 1998, the City of Irvine released a draft traffic study for the project and requested input from the City of Tustin prior to release of the environmental document required for the project. Tustin staff review of the draft traffic study revealed serious concerns regarding methodology and analysis which were transmitted to the City of Irvine on March 9, 1998. On March 12, 1998, the City of Tustin received notice from the City oflrvine that the Irvine Transportation and Infi'astmcture Commission would be holding a meeting on March 23, 1998, on the proposed project. When questioned as to the status of the City of Tustin's March 9 comments, City of Irvine staff indicated that Tustin's comments had been addressed. However, after discussing the matter with Irvine's traffic William A. Huston Planning Area 10 Comments April 6, 1998 Page 2 consultant, it was learned that Tustin's traffic comments had not been directly provided to them but that City of Irvine staff had "interpreted" those comments for response by the consultant. Tustin staff strongly believe that Irvine staff's interpretation of the City of TuStin's comments fall short of addressing City of Tustin concerns with the project. The March 12, 1998, notice received from the City of Irvine also indicated that Irvine planned to utilize a Negative Declaration to comply with the California Environmental Quality Act (CEQA) for the project. However, the Transportation and Infrastructure Commission meeting wa~ postponed until April 13, 1998, since the City of Irvine had not concurrently released a Notice of Preparation of a Negative Declaration for the project. Tustin concerns with the project have not been adequately addressed to date by the City of Irvine. The proposed project could have significant traffic related impacts to Jamboree Road, Walnut Avenue, Edinger Avenue, Bryan Avenue and other streets in the City of Tustin. Staff requests City Council.consideration of this matter, and direction to staff to forward the attached draft comment letter to the City of Irvine. Christine A. Shingleton~~ Assistant City Manager Director of Public Works, City Engineer plnarelO Attachment: Draft Comment Letter "E~iza~eth Binsack - Director, Community Development APril 7, 1998 DRAFT Mr. Gary Vanderpol, Chairman Transportation and Infrastructure'Commission City of Irvine P.O. Box 19575 Irvine, CA 92623-9575 RE: CASE N-~ER 28754-ZC, 29027-TP, PLANNING A1LEA 10 COMMENTS Dear Chaiz~Lan Vanderpol: The City of Tustin has received and reviewed the documents provided by the City of Irvine related'to the above referenced project. A public meeting of the City of Irvine Transportation and Infrastructure Commission has been noticed for April 13, 1998. It is our understanding that neither the traffic study nor the Negative Declaration required under the California Environmental Quality Act (CEQA) have been made available to the public or the Transportation and Infrastructure Commission. Although the Commission .is advisory only and does not have environmental review authority over the Negative Declaration, it does not appear appropriate, for them to be asked to provide input or recommendations on the proposed project without being provided all information concerning these matters. Therefore, we are requesting that the following comments be provided to the T~ansportation and Infrastructure Commission and made part of the formal public record for their-meeting on April 13, 1998, and that the subject Agenda item be .continued until the City of Tustin's concerns have been satisfactorily resolved. The City of Tustin has not been provided the Initial Study upon which the determination to prepare a Negative Declaration is based. Based on the magnitude of the project (1.36 million square feet of commercial development), a Negative Declaration may not be the appropriate environmental document since this project may have a significant effect on the enviroD_~ent and no previous Environmental impact Report was prepared for this project. The Public Notice of the April 13, 1998 Transportation and Infrastructure Commission states that the Negative Declaration is available for review. As of March 26, 1998, the Negative Declaration has not been released. We believe that in order Chairman Vanderpol Planning Area 10 Comments April 7, 1998 Page 2 to provide comments to the Transportation and Infrastructure Commission we must have a reasonable period of time to review the project's environmental 'documentation. Therefore,. we request that the Transportation and Infrastructure Commission public meeting be delayed until the Negative Declaration or Environmental Impact Report, if appropriate has been circulated pursuant to the CEQA public review period. It is our understanding that the project proponent, the Irvine Company, has contracted directly with the consultant for the preparation of the Traffic Study for this project. It would be more appropriate for the City to contract independently with a traffic engineer thereby eliminating any question on the validity of the report. On December 18, 1997, and March 9, 1998, the City of Tustin's Public Works DePartment provided comments on the Preliminary Screencheck Draft Traffic- Study and the Preliminary Draft Traffic Study prepared for the project. To date, the City has not received adequate responses to these comments from the City of Irvine nor a revised Traffic Study (copies of the aforementioned letters are attached). The Transportation Corm~ission should be apprised that the City of Tustin's issues have not been satisfactorily addressed. The following additional traffic related comments are also provided: a) The Traffic Study is inadequate to accurately determine and evaluate impacts associated with' the proposed project land use. A complete analysis of traffic impacts and fair share mitigation of impacts is required. b) The traffic study lacks any discussion and analysis of alternative modes of transportation for transit, buses, bicycle networks, park and ride facilities, Transportation Management Plan, etc. Additionally, phasing and coordination of each of these alternative modes needs to be addressed. c) Network improvement assumptions are inaccurate. Mitigation measures required or anticipated for other developments are assumed as the foundation of the preliminary traffic study. There could be serious . ramifications if the Marine Corps Air Station (MCAS) Chaizman Vanderpol Planning Area 10 Comments April 7, 1998 · Page 3 d) e) f) h) Tustin Specific Plan or other development projects are scaled back, rezoned, developed at a lower intensity, etc. Mitigation measures need to be imposed on the project which mitigate its direct and cumulative traffic impacts, regardless of the other future planned developments. This may result in duplicate mitigation measures between developments; however, it provides a mechanism for timely implementation of needed mitigation measures based on project progression and begins to establish the basi~ for fair-share contributions. Without a mechanism for fair-share contributions from all contributing developments,, the City of Tustin could .be responsible to provide for the unfunded balances with its long range Capital Improvement Program. The long range analysis scenario is inadequate and needs to be revised to evaluate conditions with funded or standard MPAH improvements only, . and without the transportation corridors operating as free facilities. It is highly possible that the transportation corridors will continue to operate as toll facilities. IBC mitigation improvements have historically been assigned to the IBC. Please clarify the level of "fair share" funding antiCipated to be required of the proposed Planning Area 10 project toward the balance of the IBC project mitigation. The traffic study needs to address and include required project related share of off-site improvements needed on nearby freeways and Tustin and Irvine roadways. Roadway phasing both on-site and off-site does not correspond to appropriate levels of development. Although the approval of the Lower Peters Canyon project assumed that 100% of required mitigation would be the responsibility of that project, it now appears that this full share will not be accommodated. Identify the level of "fair share" funding anticipated to be required of the proposed Planning Area 10 project toward the balance of Lower Peters Canyon project mitigation. i) All non-committed improvements should be deleted as Chairman Vanderpol Planning Area 10 Comments April 7, 1998 Page 4 assumed short range improvements, unless the project commits to constructing these improvements. If needed improvements are identified where no physical improvement can reasonably be implemented, the project's intensity should be reduced, '~ or increments of development deferred until acceptable levels of service are attained. The City of Tustin requests that the subject Agenda item be continued until the above referenced concerns have been satisfactorily resolved. Thank you for the opportunity to assist you in this process. Should you have any questions regarding this matter, please contact Mr. Tim Serlet at (714) 573-3153 or Ms. Elizabeth Binsack at (714) 573-3106. Sincerely, William A. Huston City Manager cc: Christine Shingleton Elizabeth Binsack Tim Serlet Dana Ogdon plnarea Public Works March 9, 1998 Nfl-. Brent Cooper, AICP Senior Planner City oflrvine P.O. Box 19575 laMne, CA 92623-9575 Engineering City of Tustin 300 Centennial Way Tustin, CA 92780 (714) 573-3150 FAX (714) 734-8991 Subject: Preliminary Draft Traffic Study for Jamboree East Business Center in Planning Area 10 Comments Dear Mr. Cooper: The City of Tustin has reviewed the documents provided by the City of Irvine related to the above referenced project. Included in the material reviewed are: Preliminary Screencheck Draft Planning Area 10 East Traffic Study, February 1998; February 25, 1998 letter fi.om City oflrvine to the City of Tustin; January 16, 1998 letter fi.om City oflrvine to PriTacleh and Associates; and, February 17, 1998 letter fi.om Pirzadeh and Associates t° the City oflrvine. Based on our review of our previous comments, response to comments and the revised traffic study, it appears that there are a few issues which were not risolved to our satisfaction. The following enumerates these remaining issues for your consideration. The City of Tustin previously commented that there appears to be a si_mificant gap between the traffic study interim year analysis (,year 2000 with 20 percent construction) and the buildout year analysis (2020, full project buildout, EIC as a fi'ee facility). It appears that the year 2000 interim analysis date is not an appropriate horizon year. It seems reasonable that the analysis date should address a more substantial completion o£ the project and a horizon year that is more than 2.years away fi.om the date of development application. The City of Tustin would like to see a different horizon year used in the analysis (such as year 2005) with an appropriate project completion assumption for that time period. This will enable agencies to better address the potential impacts of the project. The City of Irvine and/or Pirzadeh and Associates appears to have misinterpreted the City of Tustin's previous comment related to "Land Use and Trip Generation." The City of Tustin requests a description of the level and type of development proposed within the proposed project on the east side of the ETC and the west side of the ETC. These two areas appear to be completely separated physically due to the ETC. PA-10 Traffic Study Comments March 9, 1998 Page 2 It is unclear why the City of Irvine requested only the inclusion of the intersections of Myford/IVfichelle and Myford/Walnut in the traffic study. Previous studies in the area included a much broader study area. The City of Tustin would like the study area to be consistent with the previous studies. Attached is a copy of the study area used for the PA-10 Jamboree Business Center. The City of Tustin would like the same study area to be used for PA-10 East. The response to comments fi-om the City of Irvine indicates that City of Tustin previously agr_ eed to the study area boundary. Our records do not indicate that any meeting or correspondence has occurred related to this project, other than our December 18, 1997 comment letter. The response to the comment fi-om PirT~rteh and Associates indicates that some analysis has been done related to intersections in the City of Tustin. Tiffs information should be provided to the City of Tustin for re,&w if this was'the basis for not using the study area fi.om the PA-10 Jamboree Business Center project. The City of Tustin requests that the Traffic Study identify those improvements/mitigation measures which are assumed in the future analysis of traffic impacts for the project. A description of the funding status or conditions related to each improvement should also be included. For those measures not fully funded .by previous projects, the applicant should address how the improvements are expected to be funded (e.g. City funding partidpation, fak- share funding from other projects, etc.).. The City of Tustin appreciates the consideration of these comments in the review of the proposed PA- 10 East project. If you have any questions regarding these comments, pleura call Doug Anderson or Bob Stachelsld a£ (714) 573-3150. Sincerely, Dana R. Kasdan Engineering Services Manager D Ri~ P~:cc.g:l~.lim ~ Jangxa'ee E. aat PLa.ming ~ I0 .... Tim D. Serlet Eliza&th A. Binsa~k Rim Westfield Bob Sta~hckdci ' X ~ ~o? LEGEND · 19 ITAM Numbering System O~'~3 NECTM Numbering System Figure III-3 EXISTING INTERSECTION LOCATION MAP Pi.arming Area 10 T:a~c A~in.Fous& As~ci~tc~ lac. Public Works / Engineering December 18, 1997 Mr. Brent Cooper, Senior Planner City of Irvine One Civic Center Drive P.O. Box 19575 Irvine, CA 92623-9575 City of Tustin 300 Centennial Way Tustin, CA 92780 (714) 573-3150 FAX (774) 832-0825 Subject: CONE~[ENTS TO PRELEVIINARY SCREENCHECK DI~-kFT PLANNING AREA 10 EAST TRAFFIC STUDY (P.W. FII, E NO. 1577) Dear Mr. Cooper: The City of Tustin has completed its review of the screencheck draft traffic study for Planning Area 10 East in the City of Ir'vine. The City of Tustin has several'concerns with the approach taken to the traffic study in a couple of significant areas. In addition, several other comments are noted for your consideration. General The City of Tustin has a general concern with the approach taken in addressing interim and buildout conditions for the proposed project. Many of the comments are identified in the following section. However, we would like to emphasize our desire to see an approach to the evaluation which better attempts to address the worst case condition for potential project impacts. Essentially, it appears that there needs to be an assessmefit of impacts of project buildout or a substantial portion (70 to 90 percent?) of project buildout (depending on anticipated construction scheduling) which addresses conditions prior to the ETC becoming a free facility. It is unclear fi-om the document submitted to the City for review whether this report is in support of an EIR or other environmental document or just a stand-alone report. Please clarify this issue so that we can better anticipate the process for reviewing this project. Specific Page II-1 "Land Use and Trip Generation" - This section presents the basic project at 1.36 million square feet of Research and Development Uses. However, the study does not discuss the square footage of the development, which will occur in the segment of the site west of the ETC versus the portion east of the ETC. This makes it difficult to assess the information presented in Section VI. Planning Area 10 East comments December I$, 1997 Page 2 o Pages 1-2 and I-3, "Analysis. Scope" and Figure I-1 "Project Site and Study Area" - It is unclear why the study area boundary was designated as lamboree Road. A study area similar to that used in the e~,aluation of other portions of PA-10, in particular the Jamboree Business Center should be used for this proposed project. Page I-8 "Relationship to Other Studies" - The mitigation measu:res identified for the Lower Peters Canyon Specific Plan Circulation Study are. not all fully funded by the project (i.e. the project is obligated to pay a fair share cost on many mitigation measures). As a result, the mitigation measures not fully funded must be evaluated for subsequent projects, including PA- 10 East, to determine il'the project will be required to provide a fair share contribution towards the mitigation measures. Figure 1II-6, Page 111-9 "Long-Range Circulatlon System" - The'long-range circulation sa,stem presented does not include the extension of El Camino Real, east of Jamboree Road, connecting up'to Bryan Avenue. It is our understanding that this is the configuration included in the City oflrvine's Circulation Element. It should be included in this evaluation. Page m'-ll', "Long-Range Circulation System" - The assumption for the Long-Range Circulation System is that the EIC will be a free facility. While this assumption is technically correct for the long-range/buildout scenario, it leaves a huge gap betw~n the interim conditions (3-year horizon, and 20% project completion) versus buildout. The potential problem with this approach is that it will most likely underestimate the infrastructure needs for the period between year 2000 and when the ETC becomes a free facility. Historically, The Irvine Company (TIC) uses these scenarios to establish the maximum mitigation measure required and then performs "phasing analyses" to phase traffic mitigation measures. The City Of Tustin is concerned that ihe project needs to identify a worst case long-range scenario without the assumption of a free ETC. Tiffs will establish the ultimate improvements required, which can then be phased appropriately for project development. Page V-1 "Interim Year Analysis" - As discussed in the previous comment, the interim analysis evaluates a 3-year horizon' with an assumption' that only 20 percent of the project will be completed. While technically this may satisfy CMP and GMP requirements, it appears that it probably does not pass a basic reasonableness test for CEQA. The process should attempt to analyze the worst case scenario for potential impacts by the project. Clearly, the approach used does not attempt to achieve this. Planning Area 10 East Comments December 18, 1997 Page 3 Page ~[-7, Figure V-4 "Interim Year Intersection Lane Configurations" - The l~e configurations shown in Figure V-4 do not reflect anticipated Year 2000 lane configurations. In fact, many existing improvements are not included in the analysis. Again, for example, the lane configuration at the intersection of Jamboree Road and E1 Camino Real does not even reflect improvements that exist today. There are also additional improvements on Jamboree Road, which are not reflected in the lane configurations shown. Page VI-3, Figure VI-2 "Long-Range Peak Hour Volumes '- Project Vicinity" - The total volumes in and out of the project do not' match the volumes presented in Table 1I-1. The discrepancies appear to be minor, though they are different. The City of Tustin appreciates your consideration of these comments. If you have any questions regarding these comments, please contact Doug Anderson or Bob Stachelski, of my staff, at (714) 573-3150. We look forward to rev/ewing the next draft of the report. Sincerely, Dana IL Kasdan Engineering Services Manager DRK:DA.:ecg:pla. nning area 10 ea~. lraltlc ~tudy Tim D. Serl*t Elkabeih A. Bir~& R. Jla Wmxfi¢ld Doug .~ncl~r~on Bob Staeheh~ki