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HomeMy WebLinkAboutPC RES 4321RESOLUTION NO. 4321 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF TUSTIN, CALIFORNIA, RECOMMENDING THAT THE TUSTIN CITY COUNCIL ADOPT ORDINANCE NO. 1471 APPROVING DEVELOPMENT AGREEMENT 2016-001 FOR THE DEVELOPMENT OF AN APPROXIMATE 870,000 SQUARE FOOT PHASED COMMERCIAL MIXED-USE PROJECT WITHIN A PORTION OF PLANNING AREA 9-12 OF THE MARINE CORPS AIR STATION TUSTIN SPECIFIC PLAN The Planning Commission of the City of Tustin does hereby resolve as follows: I. The Planning Commission finds and determines as follows: A. That a proper application has been submitted by Flight Venture LLC for the project, which includes a phased commercial mixed-use project with a retail food hall and conference center consisting of a total of 870,000 square feet to be developed in two (2) phases on an approximate thirty- eight (38) acre site currently owned by the City of Tustin within,a portion of Planning Area 9-12 of the Marine Corps Air Station (MCAS) Tustin Specific Plan. The development contained within each phase is as follows: 1. Phase 1 — nine (9) separate buildings, one (1) parking garage; 390,440 square feet 2. Phase 2 — eight (8) separate buildings, one (1) parking garage; 479,560 square feet B. That the development application includes the following requests: General Plan Conformity to determine that the location, purpose, and extent of the proposed disposition of an approximately 38 - acre site within Neighborhood E of the MCAS Tustin Specific Plan for the development of 870,000 square feet of a commercial mixed-use project is in conformance with the approved General Plan. - 2. Development Agreement 2016-001 to facilitate the development and conveyance of an approximate 38 -acre site within the boundaries of the MCAS Tustin Specific Plan. 3. Concept Plan 2016-001 to develop an 870,000 square -foot commercial mixed-use project with a retail use (food hall) and conference center and ensure necessary linkages are provided between the development project, the integrity of the specific plan and purpose and intent of the neighborhood is maintained, and applicable city requirements are identified and satisfied. 4. Subdivision 2016-02NestingTentative Tract Map 18003 to subdivide an approximate thirty-eight (38) acre site into twenty- one (21) numbered lots for the development of a commercial mixed-use project with a retail use (food hall) and conference center. 5. Design Review 2016-001 for the design and site layout of an approximate thirty-eight (38) acre site into a commercial mixed- use project with a retail use (food hall) and conference center. 6. Conditional Use Permit 2016-001 for the establishment of on-site alcohol consumption in. conjunction with the operation of the Food Hall/Conference Center for Building D (Lot 4, 220 & 250 Flight Way). 7. Conditional Use Permit 2016-002 for the establishment of joint - use parking for Lots 1-10, VTTM 18003 (address range 100- 750 Flight Way). 8. Conditional Use Permit 2016-15 for the establishment of live entertainment in conjunction with the operation of the Food Hall/Conference Center for Building D (Lot 4, 220 & 250 Flight Way). 9. Conditional Use Permit 2016-23 for the allowance of mechanical equipment to exceed the maximum allowable building height for Building Type A (100 and 350 Flight Way). 10. Minor Adjustment 2016-001 for the allowance of a ten (10) percent parking reduction for Phase 1 of the project site. 11. Minor Adjustment 2016-002 for an increase in building height for Building A for both Phase 1 and Phase 2 of the project site. C. That the site is zoned as the MCAS Tustin Specific Plan (SP -1) within Planning Area 9-12 of Neighborhood E; and designated as the MCAS Tustin Specific Plan by the Tustin General Plan. In addition, the project has been reviewed for consistency with the Air Quality Sub -element of the City of Tustin General Plan and has been determined to be consistent with the Air Quality Sub -element. D. That the MCAS Tustin Specific Plan Section 4.2.9 requires all private development at the former MCAS, Tustin to obtain a DA in accordance with Section 65864 et seq. of the Government Code and Sections 9600 to 9619 of the Tustin City Code (TCC). In compliance with TCC Section 9611, the Tustin Planning Commission must make �a recommendation on the proposed Development Agreement to the City Council. The Development Agreement can be supported by the findings included in Draft Ordinance No. 1471 (Exhibit A). E. That a public hearing was duly called, noticed, and held on said application on September 27, 2016, by the Planning Commission. F. That on January 16, 2001, the City of Tustin certified the Program Final Environmental Impact Statement/Environmental Impact Report (FEIS/EIR) for the reuse and disposal of the former MCAS, Tustin. On December 6, 2004, the City Council adopted Resolution No. 04-76 approving a Supplement to the FEIS/EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted Resolution No. 06-43 approving an Addendum to the FEIS/EIR. And, on May, 13, 2013, the City Council adopted Resolution No. 13-32 approving a second Addendum to the FEIS/EIR. The FEIS/EIR along with its Addenda and Supplement is a program EIR under the California Environmental Quality Act (CEQA). The FEIS/EIR, Addenda and Supplement considered the potential environmental impacts associated with development on the former MCAS, Tustin. An Environmental Checklist attached hereto as Exhibit B has been prepared and concluded that these actions do not result in any new significant environmental impacts or a substantial increase in the severity of any previously identified significant impacts in the FEIS/EIR. Moreover, no new information of substantial importance has surfaced since certification of the FEIS/EIR. II. The Planning Commission hereby recommends that the City Council adopt Ordinance No. 1471 approving Development Agreement 2016-001 for the development for the development of an approximate 870,000 square foot phased commercial mixed-use development within portion of Planning Area 9-12 of the MCAS Tustin Specific Plan. LJ 1 1 PASSED AND ADOPTED by the Planning Commission of the City of Tustin at a regular meeting on the 27th day of September, 2016. AUSTIN LUMBARD Chairperson ELIZABETH A. BINSACK Planning Commission Secretary STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN ) I, Elizabeth A. Binsack, the undersigned, hereby certify that I am the Planning Commission Secretary of the City of Tustin, California; that Resolution No. 4321 was duly passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 27th day of September, 2016. PLANNING COMMISSIONER AYES: Kozak, Lumbard, Mason, Thompson (4) PLANNING COMMISSIONER NOES: PLANNING COMMISSIONER ABSTAINED: PLANNING COMMISSIONER ABSENT: smith 1 ELIZABETH A. BINSACK Planning Commission Secretary EXHIBIT A OF RESOLUTION NO. 4321 Draft Ordinance No. 1471 1 1 1 DRAFT ORDINANCE NO. 1471 AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF TUSTIN, APPROVING DEVELOPMENT AGREEMENT (DA) 2016-001 BETWEEN THE CITY OF TUSTIN AND LPC WEST LLC. TO FACILITATE THE DEVELOPMENT OF AN APPROXIMATELY 870,000 SQUARE FOOT PHASED COMMERCIAL MIXED-USE DEVELOPMENT WITHIN PORTION OF PLANNING AREA 9-12 OF THE MCAS TUSTIN SPECIFIC PLAN The City Council of the City of Tustin does hereby ordain as follows: SECTION 1. The City Council finds and determines as follows: A. That proper application has been submitted by LPC West LLC. for the project, which includes a phased commercial mixed use development with a retail food hall and conference center consisting of a total of 870,000 square feet to be developed in two phases on approximately 38 acre site currently owned by the City of Tustin within Planning Areas 9-12 of the MCAS Tustin Specific Plan. The development contained within each phase is as follows: 1. Phase 1 — nine (9) separate buildings, one (1) parking garage; 390,440 square feet 2. Phase 2 — eight (8) separate buildings, one (1) parking garage; 479,560 square feet B. That MCAS Tustin Specific Plan Section 4.2.9 requires all private development at MCAS Tustin to obtain a Development Agreement in accordance with Section 65864 et seq. of the Government Code and Sections 9600 to 9619 of the Tustin City Code. In compliance with Tustin City Code Section 9611, the Tustin Planning Commission must make a recommendation on the proposed Development Agreement to the City Council. C. That a public hearing was duly called, noticed, and held on said application on September 27, 2016, by the Planning Commission. The Planning Commission adopted Resolution No. 4321 recommending that the City Council adopt Ordinance No. 1471. D. That a public hearing was duly called, noticed, and held on said application on , by the.City Council. E. On January 16, 2001, the City of Tustin certified the Program Final Environmental Impact Statement/Environmental Impact Report Ordinance No. 1471 DA 2016-001 Page 2 (FEIS/EIR) for the reuse and disposal of MCAS Tustin. On December 6, 2004, the City Council adopted Resolution No. 04-76 approving a Supplement to the FEIS/EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. , On April 3, 2006, the City Council adopted Resolution No. 06-43 approving an Addendum to the FEIS/EIR. And, on May, 13, 2013, the City Council adopted Resolution No. 13-32 approving a . second Addendum to the FEIS/EIR. The FEIS/EIR along with its Addenda and Supplement is a program EIR under the California Environmental Quality Act (CEQA). The FEIS/EIR, Addenda and Supplement considered the potential environmental impacts associated with development on the former Marine Corps Air Station, Tustin. An Environmental Checklist (Resolution No. ) has been prepared and concluded that this action does not result in any new significant environmental impacts or a substantial increase in the severity of any previously identified significant impacts in the FEIS/EIR. Moreover, no new information of substantial importance has surfaced since certification of the FEIS/EIR. F. That the Development Agreement can be supported by the following findings: 1. The project is consistent with the objectives, policies, general land uses and programs specified in the General Plan and the MCAS Tustin Specific Plan in that office uses and retail commercial are permitted uses within Planning Area- 9-12 of Neighborhood E. 2. The project is compatible with the uses authorized in the district in which the real property is located (Planning Areas 9-12) in that similar and compatible uses are envisioned within the close proximity of the project site. 3. The project is in conformity with the public necessity, public convenience, general welfare, and good land use practices in that the project would provide for employment center and commercial development for new and existing Tustin residents thereby providing additional convenience and choices for employment and shopping and dining. 4. The project will not be detrimental to the health, safety, and general welfare. The project will comply with the MCAS Tustin Specific Plan, Tustin City Code, and other regulations to ensure that the project will not be detrimental in any way. Ordinance No. 1471 DA 2016-001 Page 3 5. The project will not adversely affect the orderly development of property in that the proposed project is orderly, well designed, and equipped with necessary infrastructure and amenities to support existing and future residents and businesses in Tustin Legacy. 6. The project will have a positive fiscal impact on the City in that the provisions of the proposed Development Agreement and conditions of approval will ensure that. the project will have a positive fiscal impact on the City. SECTION 2. The City Council hereby approves Development Agreement 2016-001 attached hereto as Exhibit A and subject to final approval of the City Attorney. SECTION 3. Severability. If any section, subsection, sentence, clause, phrase, or portion of this ordinance is for any reason held to be invalid or unconstitutional by the, decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this ordinance. The City Council of the City of Tustin hereby declares that it would have adopted this ordinance and each section, subsection, sentence, clause, phrase, or portion thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses, phrases, or portions be declared invalid or unconstitutional. PASSED AND ADOPTED, at a regular meeting of the City Council for the City of Tustin on this day of , 2016. ERICA N. RABE City Clerk 1 JOHN NIELSEN Mayor Ordinance No. 1471 DA 2016-001 Page 4 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) ss. CITY OF TUSTIN ) ORDINANCE NO. 1471' Erica N. Rabe, City Clerk and ex -officio Clerk of the City Council of the City of Tustin, California, does hereby certify that the whole number of the members of the City Council of the City of Tustin is 5; that the above and foregoing Ordinance No. 1471 was duly and regularly introduced at a regular meeting of the Tustin City Council, held on the day of , 2016 and was given its second reading, passed, and adopted at a regular meeting of the City Council held on the day of 2016 by the following vote: COUNCILMEMBER AYES: COUNCILMEMBER NOES: COUNCILMEMBER ABSTAINED: COUNCILMEMBER ABSENT: ERICA N. RABE City Clerk Published: 1 1 EXHIBIT A TO DRAFT ORDINANCE NO. 1471 1 1 CITY OF TUSTIN OFFICIAL BUSINESS REQUEST DOCUMENT BE RECORDED AND BE EXEMPT FROM PAYMENT OF A RECORDING FEE PER GOVERNMENT CODE 6103 AND 27383 RECORDING REQUESTED BY AND WHEN RECORDED MAIL TO: City of Tustin 300 Centennial Way Tustin, California 92780 Attn: City Clerk Space Above This Line Reserved for Recorder's Use Only TUSTIN LEGACY CORNERSTONE I DEVELOPMENT AGREEMENT THIS TUSTIN LEGACY DEVELOPMENT AGREEMENT ("Agreement") is entered into effective as of the Effective Date (as defined below) by and between the CITY OF TUSTIN, a California municipal corporation ("City"), and FLIGHT VENTURE LLC, a Delaware limited liability company (as further defined in Section 1.1.28, "Developer"). The City and Developer are collectively referred to herein as the "Parties" and individually as a "Party." RECITALS A. To strengthen the public planning process, encourage private participation in comprehensive planning, and reduce the economic risk of development, the Legislature of the State of California adopted the "Development Agreement Statute," Section 65864 et seq., of the Government Code. The Development Agreement Statute authorizes the City to enter into an agreement with any person having a legal or equitable interest in real property and to provide for development of such property and to establish certain development rights therein. In addition, Section 4.2.9 of the Specific Plan (as defined below) for MCAS Tustin states: "prior to issuance of any permits or approval of any entitlements within the Specific Plan area, all private development shall first obtain a Development Agreement in accordance with Section 65864 et seq. of the Government Code and Sections 9600 to 9619 of the Tustin City Code." Pursuant to the authorization set forth in the Development Agreement Statute, the City has enacted procedures for. entering into development agreements which are contained in Tustin City Code Sections 9600 to 9619. B. The City and Developer intend, concurrently with the execution of this Agreement, to enter into the Tustin Legacy Disposition and Development Agreement Cornerstone I (applicable to portions of Neighborhood E, also referred to as Planning Areas 9-12, of the Specific Plan), as the same may be amended from time to time ("DDA") pursuant to which City shall agree to sell, and Developer shall agree to buy and develop, certain real property, all as more specifically set forth in the DDA. Tustin Cornerstone I Development I City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final C. Pursuant to the DDA, Developer has an equitable and/or legal interest in the Property (as defined below) in that it has the contractual right to purchase the Property from the City for development of the Project (as defined below) in two phases, comprising Phase 1 and Phase 2, as further described in the DDA. D. Pursuant to Government Code Section 65864, the State Legislature has found and determined that: "(a) The lack of certainty in the approval of development projects can result in a waste of resources, escalate the cost of... development to the consumer, and discourage investment in and commitment to comprehensive planning which would make maximum efficient utilization of resources at the least economic cost to the public. (b) Assurance to the applicant for a development project that upon approval of the project, the applicant may proceed with the project in accordance with existing policies, rules and regulations, and subject to conditions of approval, will strengthen the public planning process, encourage private participation in comprehensive planning, and reduce the economic costs of development." In accordance with the legislative findings set forth in Government Code Section 65864, the City wishes to attain certain public objectives that will be furthered by this Agreement. This Agreement will provide for the orderly implementation of the General Plan of the City ("General Plan"), and the phased development and completion of the Project in accordance with the DDA and the Specific Plan (as defined below). This Agreement will further a comprehensive planning objective contained within the City's General Plan, which is: "To promote an economically balanced community with complimentary and buffered land uses to include industrial, commercial, professional, multi -family and single- family development." E. The DDA, the Specific Plan and the development under the DDA and the Specific Plan require a substantial early investment of money and planning and design effort by Developer. Without the protection provided by this Agreement, uncertainty that the Project may be completed in its entirety could result in a waste of public resources, escalate the cost of public improvements, and discourage Developer's participation in those certain public improvements specified in the DDA and the Specific Plan. Developer's participation in the implementation of the DDA and the Specific Plan will result in a number of public benefits. These benefits require the cooperation and participation of the City and Developer and could not be secured without mutual cooperation in and commitment to the comprehensive planning effort that has resulted in the DDA and the Specific Plan. F. Developer wishes to avoid certain development risks and uncertainties that would, in the absence of this Agreement, deter and discourage Developer from making a commitment to implement the DDA and the Specific Plan. These are as follows: 1. It is generally the law in California that, absent extraordinary Tustin Cornerstone I Development 2 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final circumstances or the approval of a vesting subdivision map, an owner of the land does not obtain a vested right to improve land until the issuance of a building permit for the improvements and commencement of substantial construction pursuant to that permit. The result is a disincentive for landowners to invest monies in the early completion of major infrastructure and other public improvements as part of any project or in early comprehensive planning and design studies. 2. Development under the DDA and the Specific Plan requires a substantial early investment of money and planning and design effort by Developer. Uncertainty about City's land use policies, rules and regulations could result in a waste of private resources, escalate the cost of certain public improvements, and escalate costs of proposed commercial land uses. G. The following assurances are of vital concern to Developer to offset or remove the disincentives and uncertainties set forth in Paragraph F above: 1. Assurance to Developer that, in return for Developer's commitment to the development of the Property that is contained in the DDA, any approved entitlements, and the Specific Plan, the City will in turn remain committed to the Existing Entitlement Approvals (as defined below); 2. Assurances to Developer that as Developer becomes obligated for the costs of designing and constructing the public and private improvements included in the DDA and the Specific Plan, and makes dedications, Developer will become entitled to rely upon the Vested Rights (as defined below) in the development of the Property; and 3. Assurances to Developer that in the City's administration of the Existing Entitlement Approvals, Developer will be allowed, consistent with the DDA and the Specific Plan,,, to develop the commercial land uses and intensities identified in the DDA and the Specific Plan. These assurances provide for cooperation and participation of the City and Developer and could not be secured without mutual cooperation in and commitment to the comprehensive planning effort that has resulted in the DDA and the Specific Plan. H. The Development Agreement Statute authorizes local agencies to enter into binding development agreements with persons having legal or equitable interests in real property for the development of such property. The City wishes to enter into a development agreement with Developer to secure the Public Benefits (as defined below) and additional consideration described in this Agreement, and Developer wishes to enter into a development agreement with the City to avoid the development risks and uncertainties and to obtain the assurances described above. I. This Agreement is intended to be, and shall be construed as, a development agreement within the meaning of the Development Agreement Statute. This Agreement is intended to augment and further the purposes and intent of the Parties in the implementation of the DDA and the Specific Plan. This Agreement, as a device for the implementation of the Existing Entitlement Approvals and the Specific Plan, will eliminate uncertainty in planning for and secure the orderly development of the Project, ensure a desirable and functional community environment, provide effective and efficient development of public facilities, infrastructure, and services appropriate for the development of the Project, assure attainment of the maximum effective Tustin Cornerstone I Development 3 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final utilization of resources within the City, and provide other significant public benefits to the City and its residents by otherwise achieving the goals and purposes of the Development Agreement Statute. In exchange for these benefits to the City, Developer desires to receive the assurance that it may proceed with development of the Project in accordance with the terms and conditions of this Agreement and the Applicable Rules, all as more particularly set forth herein. J. The City has determined that this Agreement and the Project are consistent with the General Plan and the Specific Plan and that this Agreement complies with the findings established by Tustin City Code Section 9611, in that the Agreement: 1. Is consistent with the objectives, policies, general land uses and programs specified in the General Plan and the Specific Plan. 2. Is compatible with the uses authorized in the district in which the real property is located (variously described as Planning Area 9-12 and Neighborhood E of the Specific Plan). Note: the Project (as defined below) complies with the uses authorized by the Specific Plan. 3. Is in conformity with the public necessity, public convenience, general welfare, and good land use practices. Note: the Project will enhance community development, provide commercial and retail uses within walking distance of existing and planned housing, support economic development and activity in the vicinity of the Project. 4. Will not be detrimental to the health, safety, and general welfare. Note: compliance with the Specific Plan, Tustin City Code, and other regulations will ensure that the Project will not be detrimental in any way. 5. Will not adversely affect the orderly development of property. Note: the Project is orderly and well designed. 6. Will have a positive fiscal impact on the City. Note: the provisions of the DDA will ensure that the Project will have a positive fiscal impact on the City. K. On September 27, 2016, the Planning Commission held a public hearing on this Agreement, made certain findings and determinations with respect thereto, and recommended to the City Council of the City that this Agreement be approved. On :, 2016, the City Council held a public hearing on this Agreement, -considered the recommendations of the Planning Commission, and adopted Ordinance No, approving this Agreement and authorizing its execution. AGREEMENT NOW, THEREFORE, in consideration of the above recitals, which are incorporated herein by this reference, and for good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties agree as follows: Tustin Cornerstone I Development 4 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final 11 1. DEFINITIONS AND EXHIBITS. 1.1 Definitions. The following terms when used in this Agreement shall be defined as follows: Any capitalized word or term used in this Agreement shall have the definition or meaning ascribed to such word or term as provided in the DDA, unless the word or term is expressly provided in this Section 1.1 of this Agreement or otherwise expressly defined in this Agreement, in which event such word or term shall have the definition or meaning as provided herein. All capitalized terms not specifically defined in the DDA or this Agreement shall be interpreted by the Director of Community Development of the City. 1.1.1 "Action" is defined in Section 9.10. 1.1.2 "AD/CFD" is defined in Section 3.1.1. 1.1.3 "Administrative Amendment" is defined in Section 2.5.2. 1.1.4 "Agreement" is defined in the introductory paragraph. 1. 1.5 "Applicable Rules" means (a) the Existing Land Use Regulations of the City; (b) the Future Rules that are not in conflict (as defined in Section 3.6.2) with the Vested Rights; (c) the Future Rules made applicable to the Project and/or the Property pursuant to Section 3.6.2 or Section 3.10; (d) the Existing Entitlement Approvals, and (e) the Subsequent Entitlement Approvals to which the Project and/or the Property or development and use thereof are made subject to pursuant to the terms of this Agreement. 1.1.6 "Applications" is defined in Section 3.11.2. 1.1.7 "Approved Plans" mean, collectively: (a) the Existing Entitlement Approvals which govern development of improvements on the Property, including approval of plans by the City in its Governmental Capacity pursuant to the Concept Plan and Design Review process; (b) the Basic Concept Plans approved by the City in its Proprietary Capacity pursuant to Section 8.4.7 of the DDA; and (c) approval by the City of construction levels drawings as required to obtain the Entitlement Approvals. 1.1.8 "Approved Transfer" is defined in Section 2.4. 1.1.9 "Basic Concept Plan' means the submittals by Developer to the City for purposes of satisfaction of the Concept Plan and Design Review approval and shall include the Phasing and proposed product mix, provided that Basic Concept Plan submittals shall be reviewed by the City in its Proprietary Capacity (as opposed to the Concept Plan and Design Review submittals which are reviewed by the City Development Department under the Governmental Capacity of the City.) 1.1.10 "Building" means each building and structure on the Property. Tustin Cornerstone I Development 5 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final 1.1.11 "Building _Pad" means any legally subdivided lot comprising a portion of the Property (other than parcels for roadways to be owned by a property owners' association) and proposed to be owned by a Person (as defined below) other than the City. 1.1.12 "Business Day(s)" means any day on which City Hall is open for business and shall specifically exclude Saturday, Sunday or a legal holiday. 1.1.13 "CC&Rs" means a set of covenants, conditions and restrictions required by the Entitlement Approvals to be prepared.by Developer, approved by the City and recorded against the Property. 1.1.14 "Certificate" is defined in Section 4.4. 1.1.15 "Certificate of Compliance" means a certificate to be issued with respect to each Phase upon Completion by Developer of all of the Improvements and satisfaction of all additional Conditions Precedent thereto with respect to the Property or relevant portion of the Property pursuant to the provisions of the DDA. The term Certificate of Compliance shall mean and include a Partial Certificate of Compliance issued as to any Building Pad as further provided by the DDA. 1.1.16 "City" is defined in the introductory paragraph. 1.1.17 "City Manager" means Mr. Jeffrey Parker, or his successor in such capacity, or other designee as identified in writing by the City Manager. 1.1.18 "City Processing Fees" means (a) all fees and charges imposed by the City under the then current regulations for processing applications and requests for permits, approvals, and other actions and monitoring compliance with any permits issued or approvals granted, including all applicable processing and permit fees to cover the reasonable cost to the City of (i) processing and reviewing applications and plans for any Entitlement Approvals, site review and approval, administrative review, and similar fees imposed to recover the City's costs associated with processing, reviewing, and inspecting Project applications, plans and specifications, (ii) inspecting the work constructed or installed by or on behalf of Developer, and (iii) monitoring compliance with any requirements applicable to Development of the Project, and (b) all costs incurred by the City in the performance of necessary studies and reports in connection with the foregoing and its obligations under this Agreement. 1.1.19 "Claiming Party" is defined in Section 9.11.1. 1. 1.20 "Common Area Improvements" mean the driveways, parking lots, internal street lighting, Parcel perimeter landscaping and open space plazas as approved in the Approved Plans, as will be further described in the CC&Rs. 1.1.21 "Complete" and "Completion" mean with respect to the Project or, if the Project is constructed in Phases, with respect to a given Phase, or if a Building Pad is eligible for its own Certificate of Compliance, such Building Pad, the point in time when all of the following shall have occurred with respect to the Project, such Phase or such Building Pad: (a) the Improvements , Tustin Cornerstone I Development 6 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final with respect thereto have been substantially completed in accordance with the DDA; (b) the issuance of a certificate of occupancy for core and shell, exterior staircase and balcony systems and common restrooms by the City or, to the extent a certificate of occupancy is not required by or available from the City for a particular Improvement, the equivalent inspection, signoff or other permit activity with respect to such Improvement, (c) the Recording of a Notice of Completion (California Civil Code Section 3043) by Developer or such Party's contractor; (d) a certification by the Project Architect that such Improvements (with the exception of minor "punch list" items) have been completed in a good and workmanlike manner and substantially in accordance with the Approved Plans and- specifications; and (e) all contractors, subcontractors, laborers, suppliers, Architects, and engineers who performed work on the relevant Improvements either (i) shall have been paid in full and shall have executed final unconditional lien waivers or (ii) any mechanic's and/or materialmen's liens that have been recorded or stop notices that have been delivered have been paid, settled or otherwise extinguished, discharged, released, waived, bonded around or insured against, or (iii) the statutory period for filing liens with respect to such Improvements shall have expired without any liens being filed. 1.1.22 "Concept Plan and Design Review" mean collectively the concept plan review required by the Specific Plan and the site plan and design review approvals required by the City Code, which shall be part of the Entitlement Approvals. 1.1.23 "Costs" is defined in Section 9.10. 1. 1.24 "Damages" is defined in Section 5.3. 1. 1.25 "DDA" is defined in Recital B. 1. 1.26 "Decision" is defined in Section 9.10. 1. 1.27 "Defaulting Party" is defined in Section 5.1. 1. 1.28 "Developer" is defined in the introductory paragraph and includes each and every Successor In Interest of Developer. 1. 1.29 "Development Agreement Statute" is defined in Recital A. 1.1.30 "Development Permits" means all ministerial permits, certificates and approvals which may be required by the City or any other Governmental Authority for the development and construction of the improvements for the Project, including any engineering permits, grading permits, foundation permits, construction permits, encroachment permits, building permits or other permits as may be necessary pursuant to Chapter 4 of the Specific Plan and/or the City Code and which shall be obtained and maintained in each case in accordance with this Agreement, the DDA, the Applicable Rules and any required environmental mitigation. 1.1.31 "Effective Date" means the date that is thirty (30) days after the date of approval (second reading) by the City Council of the City's ordinance approving this Agreement. Tustin Cornerstone I Development 7 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final 1.1.32 `BIR" means the. Final Environmental Impact Statement/Final Environmental Impact Report for the Disposal and Reuse of MCAS Tustin (Final EIS/EIR) and Mitigation Monitoring and Reporting Program for the Final EIS/EIR adopted by the City on January 16, 2001 as subsequently modified. and supplemented, including by one or more supplements and addenda to the Final EIR/EIS approved by the City. 1.1.33 "End User" means a Person operating a business in any Improvement including any Building or leasable space within a Building, whether such Person holds a fee interest in a Building Pad, a ground leasehold interest in a Building Pad, or is leasing office or other space in a Building. 1.1.34 "Entitlement Approvals" means all discretionary land use approvals and entitlements including Specific Plan amendments, tentative and final parcel and tract maps, Conditional Use Permits, preliminary and master sign programs, minor modification for increased building height, the Concept Plans and Design Review approvals as may be applicable for proposed specific uses(s) in connection with development of the Property and all conditions of approval legally required by the City and any other Governmental Authority as a condition to subdivision of the Property, development of the Property, and construction of the improvements in accordance with this Agreement. Entitlement Approvals shall be comprised of the Existing Entitlement Approvals and the Subsequent Entitlement Approvals. 1.1.35 "Existing Entitlement Approvals" means all Entitlement Approvals approved or issued prior to the Effective Date and including the approvals listed on Exhibit "D" to this Agreement, which are a matter,of public record on the Effective Date. 1.1.36 "Existing Land Use Regulations" means the Land Use Regulations in effect on the Effective Date, including the General Plan, the Tustin City Code, the Specific Plan, and all other ordinances, resolutions, rules, and regulations of the City governing development and use of the Property in effect as of the Effective Date. 1.1.37 "Force Majeure Delay" is defined in Section 9.11.1 as limited by Section 9.11.2. 1.1.38 "Future Rules" is defined in Section 3.6.2. 1.1.39 "GBA" means the gross square footage of buildings calculated in accordance with the Existing Land Use Regulations. 1. 1.40 "General Plan is defined in Recital D. 1.1.41 "Governmental Authority" mean any and all federal, State, county, municipal and local governmental and quasi -governmental bodies and authorities (including the United States of America, the State of California and any political subdivision, public corporation, district, college and/or school district, joint powers authority or other political or public entity) or departments thereof having or exercising jurisdiction over the Parties, the Project, the Property or other property upon which Developer is obligated to construct Improvements or such portions of the foregoing as the context indicates. Tustin Cornerstone I Development 8 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final 1.1.42 "Governmental Capacity" means the exercise by the City of its governmental authority with respect to any matter related to this Agreement which shall include the regulation and entitlement of the Property pursuant to Governmental Requirements, including enacting laws, inspecting structures, reviewing and issuing permits, and all of the other legislative and administrative or enforcement functions of each pursuant to federal, state or local law. 1.1.43 "Governmental Requirements" mean all laws, statutes, codes, ordinances, rules, regulations, standards, guidelines and other requirements issued by any Governmental Authority having jurisdiction over, governing, applying to or other affecting the Parties, the Project, the Improvements, the Property and/or other property, upon which Developer is obligated to construct Improvements or any component thereof and including the City Code, the Specific Plan, the Entitlement Approvals, the Development Permits and the Approved Plans, in all events subject to the terms of this Agreement. 1.1.44 "Horizontal Improvements" means (a) the Minimum Horizontal Improvements and (b) all grading work, infrastructure improvements and utilities required to be constructed or installed on or in connection with the development of the Property as further described in the Scope of Development attached as Attachment 8 to the DDA and depicted on Attachment 9 to the DDA comprised of. (i) on-site and off-site infrastructure improvements including roadways, drives, alleyways, sidewalks, curb cuts and landscaping, (ii) development of and/or upgrade to existing utility infrastructure (whether on-site or off-site) required to serve the portion of the Property then under development to the boundary of each Building Pad, (iii) Common Area Improvements on the Parcel then under development and (iv) all dry and wet utility extensions sidewalks and drives, walls, fences and landscaping on a Building Pad, and shall include all improvements required by Parcel Map No. 2015-168 and Vesting Tentative Tract Map No. 18003, each and every Entitlement condition and Development Permit and all other Governmental Requirements as a condition to development of the Project, all as generally depicted on Attachment 3 (including Attachment 3A and Attachment 3B, if applicable) to the DDA. 1. 1.45 "Improvements" means the Horizontal Improvementsand the Vertical Improvements. 1.1.46 "Landscape Installation and Maintenance Agreement" means that certain agreement pursuant to which Developer agrees to undertake the landscape', and maintenance obligations set forth therein for the benefit of the City. 1.1.47 "Land Use Regulations" means all laws, statutes, ordinances, resolutions, codes, orders, rules, regulations and official policies of the City governing the; development and use of land, including the permitted uses of the Property, the density or intensity of use, subdivision requirements, timing and phasing of development; the maximum height and size of proposed buildings, and the provisions for reservation or dedication of land for public purposes. 1.1.48 "License Agreements" means one or more limited licenses issued to Developer by the City upon City -owned property for purposes of construction, including grading, construction of the Minimum Horizontal Improvements, and installation of utilities on the Phase 2 Parcel, and provision of Phase 1 construction parking on the Phase 2 Parcel. Tustin Cornerstone I Development P 9 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final 1. 1.49 "Minimum Horizontal Improvements" means that portion of the Horizontal Improvements comprised of. (a) the rough grading work for Phase 1 and the precise grading work for the Phase 1 Improvements; (b) those certain on-site and off-site above -grade and below -grade infrastructure improvements and utilities and utility systems required to be constructed or installed on or in connection with the development of the Property as further described as the "Minimum Horizontal Improvements" set forth in the Scope of Development attached as Attachment 8 to the DDA (as the same may be further depicted on. Attachment 9 to the DDA) and (c) the Minimum Landscape Improvements. 1.1.50 "Minimum Landscape Improvements" means the landscaping and hardscaping improvements required to be built in connection with Phase 1 pursuant to the Landscape Installation and Maintenance Agreement in the locations depicted on the exhibit to the Landscape Installation and Maintenance Agreement depicting such improvements. 1.1.51 "Mortgage" means any indenture of mortgage or deed of trust, hypothecation, pledge, assignment for security purposes, bond, grant of taxable or tax exempt funds from a governmental agency or other security interest affecting the Property or any portion thereof or any documents constituting or relating to a sale-leaseback transaction, together with all loan documents related thereto, but excluding any community facilities districts, assessment districts, landscape and lighting districts or other assessments created or imposed by any Governmental Authority. 1.1.52 "Mortgagee" means any mortgagee, beneficiary (or any agent for one or more lenders acting in such capacity) under any indenture of mortgage, deed of trust, trustee of bonds, governmental agency which is a grantor of funds, and, with respect to the Property or any portion thereof which is the subject of a sale-leaseback transaction, the Person acquiring fee title. 1.1.53 "Non -Defaulting Party" is defined in Section 5.1. 1.1.54 "Option" means the Developer's option to acquire the Phase 2 Property, as further provided by the DDA. 1.1.55 "Option Year" means each successive twelve (12) month period obtained pursuant to the Option provisions of the DDA. 1.1.56 "Other Agreements" mean the Quitclaim Deed(s), the Special Restrictions, the Memorandum of DDA, the Landscape Installation and Maintenance Agreement, the CC&Rs, and the License Agreements. 1.1.57 "Parcel" means individually, either the Phase 1 Parcel or the Phase 2 Parcel. 1.1.58 "Parcels" means, collectively, the Phase 1 Parcel and the Phase 2 Parcel. 1.1.59 "Party" and "Parties" are defined in the introductory paragraph. 1. 1.60 "Person" means an individual, partnership, limited partnership, trust, estate, association, corporation, limited liability company, joint venture, firm, joint stock company, Tustin Cornerstone I Development 10 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final unincorporated association, Governmental Authority, governmental agency or other entity, domestic or foreign. 1.1.61 "Phase" means Phase 1 or Phase 2, individually. 1.1.62 "Phase 1" means the development authorized and/or required by the Entitlement Approvals in connection with the development of the Improvements upon the Property that will, upon recording thereof, comprise Parcel 1 of Parcel Map No. 2015-168, including the Phase 1 Horizontal Improvements and the Public Benefits set forth on Exhibit "C". 1.1.63 "Phase 1 Horizontal Improvements" mean the Horizontal Improvements required in connection with development, construction and operation of the Phase 1 Project which shall include the entirety of the Minimum Horizontal Improvements. 1.1.64 "Phase 1 `Parcel" means Parcel 1 of Parcel Map No. 2015-168, as the same is legally described on Exhibit "A" and depicted on Exhibit `B". 1.1.65 "Phase 1 Term" is defined in Section 2.3.1(a). 1.1.66 "Phase 2" means the development authorized and/or required by the Entitlement Approvals in connection with the development of the Improvements upon the Property that will, upon recording thereof, comprise Parcel 2 of Parcel Map No. 2015-168, including the Phase 2 Horizontal Improvements and the Public Benefits set forth on Exhibit "C" to the extent same are not completed as part of Phase 1. 1.1.67 "Phase 2 Horizontal Improvements" mean the Horizontal Improvements required in connection with development, construction and operation of the Phase 2 Project, which shall include the Minimum Horizontal Improvements to the extent the same are not completed by Developer of Phase 1 in accordance with the requirements of the DDA or this Agreement. 1.1.68 "Phase 2 Parcel" means Parcel 2 of Parcel Map No. 2015-168, as the same is legally described on Exhibit "A" and depicted on Exhibit `B". 1.1.69 "Phase 2 Term" is defined in Section 2.3.1(b). 1. 1.70 "Phases" means Phase 1 and Phase 2, collectively. 1. 1.71 "Plan Check and Inspection Fees" means the fees and costs incurred by the City with respect to its provision of Plan Check and Inspection Services for the Project, which shall be billed to Developer by City and paid by Developer to City in accordance with Section 3.13.1(b) of this Agreement. 1.1.72 "Plan Check and Inspection Services" means the services performed by City staff and its third party inspectors, engineers and consultants, if any, to carry out and complete plan check, perform inspections, and monitor Developer compliance with the Applicable Rules, as needed for review and issuance of encroachment permits, excavation permits, grading permits, Tustin Cornerstone I Development 11 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final mechanical, electrical and plumbing permits and building permits requested by Developer in connection with the Project. 1.1.73 "Prevailing Party" is defined in Section 9.10. 1.1.74 "Project" means the development of the Property contemplated by the Entitlement Approvals (as such -Entitlement Approvals may be further defined, enhanced or modified pursuant to the provisions of this Agreement); which provide for a phased commercial development consisting of up to 870,000 GBA of office, retail, conference and/or other commercial development, together with ancillary parking and landscaping amenities, in all cases not exceeding the maximum heights allowed by the Entitlement Approvals. 1.1.75 "Project Fair Share Contribution" means the fair share of the Tustin Legacy Backbone Infrastructure Program to be contributed by Developer with respect to the Project, as further described in the DDA. 1. 1.76 "Property" means the real property described on Exhibit "A" and shown on Exhibit `B" to this Agreement, which is described and depicted in two Phases --Phase 1 and Phase 2. 1. 1.77 "Proprietary Capacity" means the capacity of the City as owner, lessor, assembler, redeveloper and/or seller of property only. 1.1.78 "Public Benefit Improvements" shall have the meaning set forth in Exhibit "C." 1.1.79 "Public Benefits" means those public benefits to be provided by the Developer and the Project as described in Section 3.1 and 3.20 of this Agreement that comprise enforceable additional consideration to the City for this Agreement. 1.1.80 "Reacquired Property" means all or any portion of the Phase 1 Parcel or Phase 2 Parcel (as applicable), (b) any Improvements thereon, (c) all Entitlement Approvals and other development rights, consents, authorizations, variances, waivers, licenses, permits, certificates and approvals from any governmental or quasi -governmental authority, as applicable and (d) all other appurtenant rights applicable to the respective Property, including the interest in any ground leases encumbering the respective Property that is repurchased by the City pursuant to Section 16.3 of the DDA or that reverts to the City pursuant to Section 16.4 of the DDA. 1.1.81 "Reservation of Authority" means the rights and authority excepted from the assurances and rights provided to Developer under this Agreement and reserved to the City under Section 3.10. 1. 1.82 "Roadway and Utility Easement Agreement" means that certain reciprocal easement agreement executed by the Parties, acknowledged and in Recordable form and in form and substance acceptable to Developer and City, each in its sole discretion, granting reciprocal easements for vehicular ingress and egress, utility access, and construction of uncapped roadway Tustin Cornerstone I Development 12 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final and related landscaping, across that portion of the Property depicted on Attachment 21 of the DDA. 1.1.83 "Scope of Development" means the description of the Project and Improvements attached as Attachment 8 to the DDA. 1.1.84 "Schedule of Performance" means the document attached as Attachment 7 to the DDA, setting forth the dates and time periods for submissions, approvals and actions, including the construction and Completion of the Improvements 1.1.85 "Second Party" is defined in Section 9.11.3. 1.1.86 "Specific Plan" means the City's MCAS Tustin Specific Plan/Reuse Plan, as amended, and as the same may be further amended from time to time. 1.1.87 "State" means the State of California. 1.1.88 "Subsequent Entitlement Approvals" means Entitlement Approvals, if any, approved by the City subsequent to the Effective Date in connection with development of the Property or the Project. 1.1.89 "Successor In Interest" means any Person having a legal or equitable interest in the whole of the Property, or any portion thereof. 1.1.90 "Tax A" is defined in Section 3.1.1(a). 1. 1.91 "Tax B" is defined in Section 3.1.1(b). 1. 1.92 "Term" means with respect to Phase 1, the Phase 1 Term, and with respect to Phase 2, the Phase 2 Term. 1. 1.93 "Tustin City Code" means the municipal code of the City of Tustin. 1.1.94 "Tustin Legacy Backbone Infrastructure Program" means the program adopted by the City to finance and construct Tustin Legacy backbone infrastructure located off of the Property, including Tustin Legacy roadway improvements; traffic and circulation mitigation to support the Tustin Legacy project; domestic and reclaimed water; sewer; telemetry; storm drains and flood control channels; utilities backbone (electricity, gas, telephone, cable, telecommunications, etc.) (as such program is in effect as of the Effective Date). 1.1.95 "Vertical Improvements" means all of the Buildings, landscaping and other improvements (including, among other things, parking lots and parking structures), other than the Horizontal Improvements, to be constructed or installed on the Property, consistent with the Specific Plan, the Reuse Plan, the Approved Plans, the Entitlement Approvals, the Design Guidelines and the Development Permits and as further described in the DDA. Tustin Cornerstone I Development 13 City of Tustin/Comerstone I Agreement 9-15-2016 (PC) final 1.1.96 "Vested Rights" means the rights granted to Developer pursuant to this Agreement upon its acquisition of each Phase of the Property to develop the Property so acquired in accordance with, and subject to the terms andconditions of this Agreement, the Existing Entitlement Approvals and any Subsequent Entitlement Approvals approved by the City and made applicable to the Property pursuant to the terms of this Agreement. 1.2 Exhibits. The following documents are attached to, and by this reference made a part of, this Agreement: Exhibit "A" — Legal Description of the Property (Phase 1 and Phase 2) Exhibit `B" — Map Showing Property (Phase 1 and Phase 2) Exhibit "C" — Public Benefit Improvements Exhibit "D" -Existing Entitlement Approvals 2. GENERAL PROVISIONS. 2.1 Binding Effect of Agreement. The Property is hereby made subject to this Agreement. Development of the Property is hereby authorized and shall be carried out only in accordance with the terms of this Agreement. 2.2 Interests in Property. The City and Developer agree that Developer's right to acquire the Property pursuant to the DDA creates a sufficient legal and/or equitable interest in order to enter into this Agreement. If Developer fails to acquire any portion of the Property, then this Agreement shall automatically no longer be effective as to such portion of the Property concurrently with the date upon which Developer's rights to acquire such portion of the Property expire. 2.3 Term. 2.3.1 The term of this Agreement shall commence on the Effective Date and shall extend as to each Phase for the period set forth below, unless otherwise extended by the parties in writing or earlier terminated in accordance with the provisions of this Agreement: (a) with respect to Phase 1, the term (the "Phase 1 Term") shall terminate upon the date that is five (5) years Erom the Effective Date, as such date may be automatically extended during the period of any Force Majeure Delay established pursuant to Section 9.11, provided that in no event, after taking into account any such Force Majeure Delay, shall the Phase 1 Term be extended beyond the eighth (8th) anniversary of the Effective Date; and (b) . with respect to Phase 2, the term (the "Phase 2 Term") shall terminate upon the occurrence of any of the following dates, provided that in no event, after taking into account any Force Majeure Delay, shall the Phase 2 Term be extended beyond the fifteenth (15th) anniversary of the Effective Date: (i) the date upon which the Option terminates without exercise thereof; Tustin Cornerstone I Development 14 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final or (ii) if the Option is exercised in the first through eighth Option Year, the date that is four (4) years from the date of exercise of the Option, as such date may be automatically extended during the period of any Force Majeure Delay established pursuant to Section 9.11, for a maximum of three (3) additional years; or (iii) if the Option is exercised after the eighth Option Year, the date that is thirteen (13) years from the Effective Date; as such date may be automatically extended during the period of any Force Majeure Delay established pursuant to Section 9.11 for a maximum of two (2) additional years. 2.3.2 Notwithstanding any other provision of this Agreement, unless otherwise agreed by the Parties in writing, this Agreement shall automatically terminate upon the date that is one hundred and eighty (180) days following the Effective Date if the DDA has not then been executed by the City and Developer. 2.3.3 Notwithstanding the provisions of Section 2.3.1(b)(i), in the event the Option terminates pursuant to the terms of the DDA prior to exercise thereof by the Developer pursuant to the terms of the DDA, the City shall have the right to unilaterally extend the Phase 2 Term without approval of the Developer and if the City reacquires any portion of the Property the City shall have the right to unilaterally extend the Term with respect to the portion of the Property it has so acquired. 2.4 Assi ment. Any attempt to convey, assign or transfer any right or interest in this Agreement except in strict compliance with this Section 2.4 shall be null and void and of no force and effect. A conveyance, assignment or transfer carried out in accordance with this Section 2.4 and approved by the City as required by this Section 2.4 is referred to herein as an "Approved Transfer". 2.4.1 Assignment and Notification. The rights, interests and obligations conveyed and provided herein to Developer benefit and are appurtenant to the Property. Developer has the right to sell, assign and transfer any and all of its rights and interests and to delegate any and all of its duties and obligations hereunder subject to and in accordance with the following conditions: (a) Prior to the recordation of the Certificate of Compliance for each Phase (or, if applicable, Building Pad), the rights and interests of Developer under this Agreement as to such Phase (or, if applicable, Building Pad) may not be Transferred except in strict compliance with the provisions of Section 2 of the DDA, which are incorporated herein by this reference as though fully set forth in this Agreement, and, to the extent required thereby, Developer shall secure the written consent of the City to each such Transfer. (b) From and after recordation of the Certificate of Compliance for each Phase (or, if applicable, Building Pad), the rights and interests of Developer under this Tustin Cornerstone I Development 15 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final Agreement as to such Phase (or, if applicable, Building Pad) may not be conveyed, assigned, or transferred without the written consent of the City to each such conveyance, assignment or transfer, which consent of the City shall not be unreasonably withheld or delayed. (c) The rights and interests of Developer under this Agreement with respect to a Phase may be conveyed, transferred or assigned only as an incident of the conveyance, transfer or assignment of the portion of the Property to which they relate, including any transfer or assignment pursuant to a foreclosure of a Mortgage or a deed in lieu of a foreclosure; (d) Prior to conveyance, assignment or transfer of the rights and interests of Developer under this Agreement.in connection with the conveyance of the Property or a portion thereof, Developer shall notify the City in writing of each conveyance, assignment or transfer of the portions of the Property to which the conveyance, assignment or transfer will be appurtenant, and the name and address (for purposes of notices hereunder) of the transferee or assignee, together with the corresponding Building Pads; (e) The assignee or transferee shall assume all of Developer's obligations under this Agreement and the Entitlement Approvals as they relate to the portion of the Property so assigned and/or transferred, which shall include, for avoidance of doubt: (1) all such obligations expressly applicable to the portion of the Property and the Project acquired by such assignee or transferee; (2) all obligations imposed by this Agreement and the Entitlement Approvals as a condition to construction of the Project, including completion of the Public Benefits, to the extent applicable to or a requirement of development of the portion of the Property and the Project so acquired; (3) the requirement to satisfy all other conditions under this Agreement, the DDA, the Other Agreements and the Entitlement Approvals applicable to the development of the portion of the Property and the Project so acquired; and (4) all obligations imposed on "Developer" under this Agreement and all conditions imposed by the Entitlement Approvals to the extent applicable. to the portion of the Property so acquired or as a requirement thereof, whether or not specifically identified as applicable to the Phase or portion of the Project so acquired (collectively, the "Transferred Obligations"); provided, however, that nothing in this subsection (e) shall require the assignee or transferee of a portion of the Project constituting less than an entire Phase (such as a transferee of one Building Pad) to assume any obligations of Developer that Developer expressly retains pursuant to the terms of the assignment or transfer agreement between the Developer and the assignee/transferee; and (f) The assignee or transferee shall have entered into an Assignment Agreement if required by the DDA. 2.4.2 Subject to Terms of Agreement. Following a conveyance, assignment or transfer of any of the rights and interests of Developer set forth in this Agreement in accordance with Section 2.4.1, the assignee's or transferee's exercise, use, and enjoyment of the Property shall be subject to the terms of this Agreement to the same extent as if the assignee or transferee were Developer. Tustin Cornerstone I Development 16 City of Tustin/Comerstone I Agreement 9-15-2016 (PC) final 2.4.3 Release of Developer Upon Transfer. Notwithstanding the conveyance, assignment or transfer of portions or all of the Property or rights or interests under this Agreement, Developer shall continue to be obligated under this Agreement with respect to Developer's obligations and the other duties and obligations of Developer under this Agreement unless and until released or partially released by the City in writing, which release or partial release shall apply only with respect to obligations of Developer following the effective date of the assignment or Transfer and shall be granted by the City only upon the full satisfaction by Developer of each and every one of the following conditions: (a) Developer is not then in default under this Agreement; (b) The City has consented to the assignment or transfer if required under Section 2.4.1 of this Agreement; (c) The assignment or transfer is not a Transfer to an Affiliate or other Transfer or Transfer of Control for which the DDA expressly provides that Developer shall not be released from its obligations under the DDA; (d) The conveyance, assignment or transfer conveys, assigns or transfers all of Developer's interest in the portion of the Property being transferred, the DDA and the Other Agreements (to the extent then applicable to such portion of the Property) and this Agreement, including the Transferred Obligations applicable thereto; (e) The assignee or transferee has assumed in writing all duties and obligations as to which Developer is requesting to be released pursuant to an assignment and assumption agreement approved by the City; and (f) The assignee or transferee is financially able to assume the obligations proposed for assignment and has demonstrated to the reasonable satisfaction of the City that adequate resources have been committed to the full performance of such obligations. 2.4.4 Effect of Right of Repurchase or Right of Reversion. In the event the City exercises its Right of Reversion or Right of Repurchase, then effective upon the date of acquisition by the City of the Reacquired Property, such reversion shall release the Developer previously owning the Reacquired Property from (a) all prospective liability and obligations of Developer under this Agreement applicable to the Reacquired Property and (b) only as and to the extent set forth in the DDA, including Sections 16.3.4 and 16.4.5 thereof, those obligations and liabilities that predate the date of acquisition by the City of the Reacquired Property. 2.5 Amendment or Cancellation of Agreement. 2.5.1 Generally. This Agreement may be amended or cancelled in whole or in part only in the manner provided for in Government Code Section 65865.1 or 65868 and Tustin City Code Section 9615. This provision shall not limit any remedy of the City or Developer as provided by this Agreement. Any Party may propose an amendment to or cancellation, in whole or in part, of this Agreement. Any amendment or cancellation shall be by mutual consent of the Tustin Cornerstone I Development 17 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final Parties except as provided otherwise in this Agreement, in Government Code Section 65865.1, or in the Tustin City Code. 2.5.2 Administrative Amendments. Any amendment to this Agreement which does not relate to (a) the Term of this Agreement, (b) permitted uses of the Project, (c) provisions for the reservation or dedication of land, (d) the conditions, terms, restrictions and requirements relating to Subsequent Entitlement Approvals of the City, (e) revisions to Public Benefits (other than to the time for performance of such Public Benefits) or ffl monetary exactions of Developer, shall be considered an "Administrative Amendment"; notwithstanding anything to the contrary contained herein, changes to definitions and/or references to Exhibits and/or Attachments necessary or helpful to conform this Agreement to the provisions of the DDA (as the DDA may be amended from time to time) shall be considered Administrative Amendments and may be approved in accordance with this Section 2.5.2. The City Manager or his or her designee is authorized to execute Administrative Amendments on behalf of the City and no action by the City Council (e.g. noticed public hearing) shall be required before the Parties may enter into an Administrative Amendment. The determination of whether a proposed amendment is an Administrative Amendment as defined in this Section 2.5.2 shall be made in the sole judgment of the City Manager, or designee, and the City Manager, or designee, reserves the right to refer any matter to the City Council and/or to require a noticed public hearing on a proposed Administrative Amendment in which event the City's Planning Commission shall conduct a noticed public hearing to consider whether the proposed Administrative Amendment should be approved or denied, and shall make a recommendation to the City Council on the matter. In such event, .the City Council shall conduct a noticed public hearing to consider the request and the Planning Commission's recommendation on the matter. At the conclusion of the public hearing, the City Council may approve, deny, or conditionally approve the amendment. 2.5.3 Consent to Amendments. In the case of amendments affecting portions of the Property, only the consent of the owner 'of such portion of the Property shall be required so long as the amendment does not diminish the rights appurtenant to or increase the burdens upon any other portion of the Property. Any Future Rule applicable pursuant to this Agreement and any amendment of the City Land Use Regulations including to the General Plan, applicable Specific Plan or the City's zoning ordinance, shall not require amendment of this Agreement. Instead, any such amendment shall be deemed to be incorporated into this Agreement at the time that such amendment is approved by the appropriate City decision maker, so long as such amendment is consistent with this Agreement. 2.5.4 Termination. (a) This Agreement, or the portion thereof so affected, shall be deemed terminated and of no further effect upon the occurrence of any of the following events: (i) As to Phase 1, expiration of the Phase 1 Term as set forth in Section 2.3.1(a); (ii) ' As to Phase 2, expiration of the Phase 2 Term as set forth in Section 2.3.1(b); Tustin Cornerstone I Development 18 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final (iii) As to both Phase 1 and Phase 2, pursuant to the provisions of Section 2.3.2; (iv) Prior to the termination in clause (i) or (ii) of this subsection (a), upon entry of a final courtjudgment not subject to further appeal setting aside, voiding or annulling the adoption of the City ordinance approving this Agreement; (v) The adoption of a referendum measure overriding or repealing the City ordinance approving this Agreement where such measure is not subject to further appeal; (vi) As to each Phase or other portion of the Property for which a Certificate of Compliance is sought pursuant to the DDA, upon Completion of the entirety of the Project and the Public Benefits required in connection with such Phase in accordance with the terms of this Agreement, the DDA, the Entitlement Approvals and the Applicable Rules, including issuance of all required occupancy permits and acceptance by the City or applicable public agency of all required public improvements and dedications, compliance with all obligations of Developer under this Agreement and City issuance of a Certificate of Compliance pursuant to the DDA, the City Manager shall have the authority in his or her sole discretion to terminate this Agreement as to the Phase or other portion of the Property for which the Certificate of Compliance has been recorded; (vii) Due to termination by the City in accordance with Section 4.3 or Section 5; or (viii) Upon mutual written agreement of the City and Developer. (b) The City shall have the right, but not the obligation, to terminate this Agreement as to the portion of the Property re -acquired by it pursuant to the Right of Repurchase, the Right of Reversion or any action in lieu thereof pursuant to the DDA. (c) Termination of this Agreement shall not constitute termination of any other Entitlement Approvals for the Property. Upon the termination of this Agreement as to any portion of the Property, no Party shall have any further right or obligation hereunder with respect to such portion of the Property except with respect to any obligation to have been performed prior to such termination or with respect to any default in the performance of the provisions of this Agreement which has occurred prior to such termination or with respect to any obligations which are specifically set forth as surviving this Agreement. The City and Developer shall cooperate, at no cost to the City, in executing in recordable form any document that the City has approved to confirm the termination of this Agreement as to any such portion of the Property. 2.6 Notices, Demands and —Communications between the Parties. All notices, demands, consents, requests and other communications required or permitted to be given under Tustin Cornerstone I Development 19 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final this Agreement shall be in writing and shall be deemed conclusively to have been duly given (a) when hand delivered to the other Party; (b) three (3) Business Days after such notice has been sent by United States mail via certified mail, return receipt requested, postage prepaid, and addressed to the other Party as set forth below; or (c) the next Business Day after such notice has been deposited with a national overnight delivery service reasonably approved by the Parties (Federal Express, United Parcel Service and U.S. Postal Service are deemed approved by the Parties), postage prepaid, addressed to the Party to whom notice is being sent as set forth with next Business Day delivery guaranteed, provided that the sending Party receives a confirmation of delivery from the delivery service provider. Unless otherwise provided in writing, all notices hereunder shall be addressed as follows: If to the City: With a copy to: If to Developer: With a copy to: Jeffrey C. Parker, City Manager City of Tustin 300 Centennial Way Tustin, CA 92780 Fax: (714) 838-1602 Email: jparker@tustinca.org David Kendig Woodruff Spradlin & Smart, APC 555 Anton Boulevard, #1200 Costa Mesa, CA 92626 Fax: (714)415-1183 Email: dkendig@wss-law.com. David Binswanger and Matt Howell Flight Venture LLC c/o Lincoln Property Company Commercial, Inc. 915 Wilshire Boulevard, Suite 2050 Los Angeles, CA 90017 Fax: (213) 538-0901 Email: dbinswanger@lpc.com and matt.howell@lpc.com Parke Miller Flight Venture LLC c/o Lincoln Property Company Commercial, Inc. 114 Pacifica, Suite 370 Irvine, CA 92618 Fax: (949) 333-2131 Email:pmiller@lpc.com Tustin Cornerstone I Development 20 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final 11 i 1 1 1 With a copy to: Gregory S. Courtwright Lincoln Property Company Commercial, Inc. 2000 McKinney Avenue, Suite 1000 Dallas, TX 75201 Fax: (214) 740-3460 Email: gcourtwright@lpc.com With a copy to: Mark Potter Alcion Ventures One Post Office Square, Suite 3150 Boston, MA 02109 Fax: (617) 603-1001 Email: mpotter@alcionventures.com With a copy to: Amy Forbes Gibson, Dunn & Crutcher LLP 333 South Grand Avenue, Suite 4900 Los Angeles, CA 90071 - Fax: (213) 229-6151 / (213) 229-6128 Email: aforbes@gibsondunn.com With a copy to: Michael Glazer Goodwin Procter LLP Exchange Place 53 State Street Boston, MA 02109 Fax: (617) 523-1231 Email: mglazer@goodwinprocter.com Any Party may by written notice to the other Party in the manner specified in this Agreement change the address to which notices to such Party shall be delivered. 3. DEVELOPMENT OF THE PROPERTY. 3.1 Public Benefits. This Agreement provides assurances that the Project described by this Agreement will be achieved and developed in accordance with the Applicable Rules and this Agreement, and subject to the City's Reservation of Authority. The Parties believe that such orderly development of the Project will provide the benefits to the City and additional regional public benefits, including: increased tax revenues, installation of on-site 'and off-site improvements, and creation and retention of jobs. In addition Developer will provide the following additional Public Benefits which constitute specific additional consideration for this Agreement for the benefit of the City: Tustin Cornerstone I Development 21 Agreement 9-15-2016 (PC) final City of Tustin/Cornerstone I 3.1.1 Community Facilities District Formation. The City has previously established a Community Facilities District for Tustin Legacy ("AD/CFD") that includes the Property within its boundaries. - (a) Capital Facilities. Developer acknowledges and agrees that its development plan for the Project will not require use of community facility district proceeds, including proceeds from the AD/CFD and that neither assessment district nor community facilities district proceeds will be used to reimburse Developer for its development costs in connection with the Project, including Project Fair_Share Contribution or Project specific construction or infrastructure costs. Accordingly, Developer waives its right to fund all or any portion of the development of the Project pursuant to a Community Facilities District, including pursuant to any Special Tax for the development of facilities within the Tustin Legacy Backbone Infrastructure Program pursuant to the existing AD/CFD ("Tax A"), and the City agrees that Tax A shall not be applicable to the Property or the Improvements thereon and Developer shall have no obligation or liability on account thereof. The City agrees that neither the Property nor the Improvements shall be subject to or encumbered by Tax A because Developer's obligation to pay the fair share of the Tustin Legacy Backbone Infrastructure Program shall be satisfied by payment of the Purchase Price under the DDA and Section 3.1.2 below (which Purchase Price is inclusive of the obligation to pay the Developer's fair share of the Tustin Legacy Backbone Infrastructure Program with respect to the Project). (b) Tax B. As part of the AD/CFD the City has previously established Special Tax `B" pursuant to AD/CFD 13-01 ("Tax B"), the proceeds of which shall be used by the City to fund a portion of the City essential services, including police and fire protection, ambulance and paramedic services,_ recreation programs and services, street sweeping, traffic signal maintenance and the maintenance of City -owned. parks, parkways and open spaces, lighting, flood control and storm drain services and other City services and facilities at Tustin Legacy. Tax B is and shall be a tax and lien upon the Property and the Improvements in accordance with the terms of the instruments governing the AD/CFD and Tax B and the term of Tax.B imposed upon the Property and the Improvements is and shall be perpetual and shall not be time limited in any manner unless determined by the City in its sole discretion. Developer and each Successor In Interest of Developer shall pay the Tax B amounts due with respect to the Property when due to the City. Tax B shall be in lieu of any other assessments,.special taxes, fees or charges that may otherwise be charged on account of the types of services covered thereby. Developer acknowledges that the term of Tax B imposed upon the Property and the Improvements thereon does not contain a fixed termination date, and that the City ordinance adopting Tax B provides that it shall continue as long as necessary to meet the Special Tax Requirement for Service set forth in the City ordinance adopting Tax B. . (c) No Further Restrictions. Notwithstanding the provisions of Section 3.1.1(a) and (b), the City shall not be prohibited by the terms of this Agreement from, subjecting the Property and/or the Improvements thereon to any increase in ad valorem real property tax pursuant to a City of Tustin -wide election, provided that nothing herein shall be construed to constitute a waiver by Developer of its right or ability to dispute or oppose passage of Tustin Cornerstone I Development 22 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final a City of Tustin -wide bond or tax, the proposed formation or amendment of any special district or taxing authority, or the imposition of any such tax by such special district or taxing authority, or any amendment to the Rate and Method of Apportionment for Tax B, or its right to dispute the assessed valuation of all or any portion of the Property owned by it. 3.1.2 Project Fair Share Contribution. The Purchase Price for the Property under the DDA is inclusive of the obligation to pay the Project Fair Share Contribution with respect to the Project and accordingly, upon payment in full of the Purchase Price under the DDA, Developer shall be credited in full with payment of its fair share of the Tustin Legacy Backbone Infrastructure Program fees comprising the Project Fair Share Contribution and thereafter no further obligation shall be imposed on Developer of the Project in connection with the Tustin Legacy Backbone Infrastructure Program. 3.1.3 Public Benefit Improvements. Developer shall complete the Public Benefit Improvements listed on Exhibit "C" within the time periods set forth therein. Notwithstanding anything to the contrary in this Agreement, if any payment under this Section is not made or any obligation requiring performance is not performed by Developer, the City may withhold further issuance of building permits and other approvals, including final maps, for the Project until such time as Developer has made the required payment or undertaken the required performance. 3.2 Developer Objectives. In accordance with the legislative findings set forth in Government Code Section 65864, the Developer wishes to obtain reasonable assurances that the Project may be developed in accordance with the Applicable Rules and Existing Entitlement Approvals and with the terms of this. Agreement and subject to the City's Reservation of Authority. To the extent of Project deelopment, and as provided by Section 3.5.2, Developer anticipates making capital expenditures or causing capital expenditures to be made in reliance upon the DDA and this Agreement. In the absence of this Agreement, Developer would have no assurance that it can complete the Project for the uses and to the density and intensity of development set forth in this Agreement and the Existing Entitlement Approvals. This Agreement, therefore, is necessary to assure Developer that the Project will not be (1) reduced or otherwise modified in density, intensity or use from what is set forth in the Existing Entitlement Approvals, (2) subjected to new rules, regulations, ordinances or official policies or plans except for Future Rules made applicable pursuant to the terms of this Agreement. 3.3 Mutual Objectives. Development of the Project in accordance with this Development Agreement will provide for the orderly development of the Property in accordance with the objectives set forth in the General Plan and the Specific Plan. Moreover, a development agreement for the Project will eliminate uncertainty in planning for and securing orderly development of the Property, assure installation of necessary improvements, assure attainment of maximum efficient resource utilization within the City at the least economic cost to its citizens and otherwise achieve the goals and purposes established by Government Code Section 65864. Additionally, although development of the Project in accordance with this Agreement will restrain the City's land use or other relevant police powers, this Agreement provides the City with sufficient reserved powers during the Term to remain responsible and accountable to its residents. Tustin Cornerstone I Development 23 City of Tustin/Comerstone I Agreement 9-15-2016 (PC) final In exchange for these and other benefits.to the City, the Developer will receive assurance that the Project may be developed during the Term of this Agreement in accordance with the Applicable Rules, Entitlement Approvals and Reservation of Authority, subject to the terms and conditions of this Agreement. 3.4 Applicability of the Agreement. This Agreement does not: (a) grant density or intensity in excess of that otherwise, established in the Existing Entitlement Approvals; (b) eliminate future discretionary actions relating to the Project that are either required by the Applicable Rules or requested by Developer pursuant to applications initiated and submitted by Developer after the Effective Date; (c), guarantee that Developer will receive any profits from the Project; (d) amend the DDA, the Other Agreements, the Specific Plan or the General Plan or (e) protect the Developer, the Project or the Property from the applicability of any increases in development fees or City Processing Fees. In addition, except as specifically set forth in Sections 3.6.2 and 3. 10, this Agreement does not protect the Developer, the Project or the Property from the applicability of any Future Rules (i) imposed pursuant to the City's Reservation of Authority or (ii) if not imposed pursuant to the City's Reservation of Authority, adopted by the City and not in conflict (as defined in Section 3.6.2) with Existing Land Use Regulations. 3.5 Agreement and Assurance on the Part of the Developer. In consideration for the City's entering into this Agreement, and as an inducement for City to obligate itself to carry out the covenants and conditions set forth in this Agreement, and in order to effectuate the premises, purposes and intentions set forth in this Agreement, Developer hereby agrees as follows: 3.5.1 Project Development. Developer agrees that it will use commercially reasonable efforts, in accordance with its own business judgment and taking into account market conditions and economic considerations, to undertake any development of the Project in accordance with the terms and conditions of the DDA, this Agreement and the Existing Entitlement Approvals. 3.5.2 Additional Obligations of Developer as Consideration for this Agreement. In addition to the obligations identified in Section 3.1, the development assurances provided by Developer in this Agreement and the resulting construction of the Project will result in the following: (a) Construction of a commercial development of up to 870,000 GBA within Neighborhood E of the MCAS Tustin Specific Plan, consistent with this Agreement, the Applicable Rules, the Entitlement Approvals and the DDA, including in accordance with the Schedule of Performance set forth in the DDA. (b) Construction of all Improvements identified in the DDA in accordance with the Schedule of Performance set forth in the DDA. (c) Completion of all Public Benefit Improvements identified on Exhibit "C" in accordance with the Schedule of Performance set forth in the DDA and Exhibit "C". Tustin Cornerstone I Development 24 City of Tustin/Cornerstone I Agreement 9=15-2016 (PC) final (d) Compliance with the DDA, the Applicable Rules and Entitlement Approvals, state and federal law, all mitigation measures, including measures imposed pursuant to the California Environmental Quality Act ("CEQA"), all Development Permits and all conditions of approval associated with the foregoing. (e) Payment of all required development and inspection related fees pursuant to the terms and conditions set forth in the DDA, the Other Agreements and this Agreement; provided, however, that Developer's sole obligation with respect to the Project Fair Share Contribution shall be as set forth in Section 3.1.2. 3.6 Agreement and Assurances on the Part of City. In consideration for Developer entering into this Agreement, as an inducement for Developer to obligate itself to carry out the covenants and conditions set forth in this Agreement, and in order to effectuate the purpose of this Agreement, the City hereby agrees as follows: 3.6.1 Applicable Regulations; Vested Right to Develop. To the maximum extent permitted by law, as to each Phase, Developer has the vested right for the Term applicable to such Phase to develop the Project subject to the terms and conditions of this Agreement, the Applicable Rules, state and federal law, and the Existing Entitlement Approvals and any Subsequent Entitlement Approvals approved by the City, in each case subject to the City's Reservation of Authority and subject to the additional terms and conditions set forth in the DDA and the Other Agreements. Other than as expressly set forth herein, during the Term applicable to each Phase, the terms and conditions of development applicable to such Phase of the Property, including the permitted uses of the Property, the density and intensity of use, maximum height and size of proposed buildings, the design, improvement and construction standards and specifications applicable to the development of the Property, including any changes authorized pursuant to Section 3.6.2, the subdivision of land and requirements for infrastructure and public improvements, other terms and conditions of the Project, and the provisions for the reservation and dedication of land as needed for public purposes pursuant to Governmental Requirements, shall be those set forth in the DDA and the Other Agreements, the Applicable Rules, and the Entitlement Approvals. In connection therewith and subject to the terms of this Agreement including the Reservation of Authority, Developer shall have the Vested Right to carry out and develop the Property in accordance with the Applicable Rules and the Entitlement Approvals and the provisions of this Agreement, including Section 3.10.4.. 3.6.2 Changes Authorized by the CitX. To the extent any changes in the Existing Land Use Regulations, or any provisions of future General Plans, Specific Plans, Tustin City Code or other rules, regulations, ordinances or policies of the City (whether adopted by means of ordinance, initiative, referenda, resolution, policy, order, moratorium, or other means, adopted by the City Council, Planning Commission, or any other board, commission, agency, committee, or department of the City, or any officer or employee thereof) following the Effective Date (collectively, "Future Rules") are not in conflict with the Vested Rights, such Future Rules shall be applicable to the Project. For purposes of this Section 3.6.2, the word "conflict" means Future Rules that would (a) frustrate in a more than insignificant way the intent or purpose of the Applicable Rules in relation to the Project; (b) materially increase the cost of performance of, or preclude compliance with, any provision of the Vested Right; (c) delay in a more than insignificant Tustin Cornerstone I Development 25 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final way development of the Project; (d) limit or restrict the availability of public utilities, services, infrastructure of facilities (for example, but not by way of limitation, water rights, water connection or sewage capacity rights, sewer connections, etc.) to the Project; (e) impose limits or controls in the rate, timing, phasing or sequencing of development of the Project; (f) limit the permitted uses of the Property from those permitted by the Existing Entitlement Approvals, the DDA and the Other Agreements; (g) reduce ' the maximum height or size of any permitted buildings; or (h) impose additional obligations in connection with the reservation or dedication of land for public purposes beyond the requirements identified in the DDA from those permitted by the Entitlement Approvals. Notwithstanding the foregoing, any Future Rule that conflicts with the Applicable Rules shall nonetheless apply to the Property if, and only if one of the following apply: (i) it is consented to in writing by Developer; (ii) it is determined by the City and evidenced through findings adopted by the City Council that the change or provision is reasonably required in order to prevent a condition dangerous to the public health or safety as set forth in Section 3.10.2; (iii) it is required by changes in State or Federal law as set forth in Section 3.10.1; (iv) it consists of revisions to, or new building regulations permitted by Section 3.10.3; or (v) it is otherwise expressly permitted by this Agreement. 3.6.3 Availability of Public Services. To the maximum extent permitted by law and consistent with its authority, the City shall use commercially reasonable efforts to assist Developer in reserving such capacity for sewer and water services as may be necessary to serve the Project, at no cost or expense to the City. 3.6.4 Allocation of Development Rights Under Specific Plan. The City hereby acknowledges that it has allocated to the Property and reserved for development of the Project a total of 870,000 GBA of commercial floor area from the total Specific Plan Planning Area 9-12 authorization of commercial floor area. Tustin Cornerstone I Development 26 City of Tustin/Comerstone I Agreement 9-15-2016 (PC) final 3.7 Effect of Agreement on Subsequent Entitlement Approvals. The City shall accept for processing and review and take action on all applications for Subsequent Entitlement Approvals as provided in Section 3.9. In connection with any Subsequent Entitlement Approval, the City shall exercise discretion in the same manner as it exercises its discretion under its police powers, including the Reservation of Authority; provided however, that such discretion shall not prevent development of the Project as set forth in this Agreement. 3.8 Timing of Development. The timing of development will be as set forth in the DDA. Since the California Supreme Court held in Pardee Construction Co. v. City of Camarillo (1984) 37 Cal. 3d 465, that the failure of the parties therein to provide for the timing of development resulted in a later adopted initiative restricting the timing of development to prevail over such parties' agreement, it is the Parties' intent to cure that deficiency by acknowledging and providing that Developer will adhere to the terms of the DDA regarding the timing of development. 3.9 Subsequent Entitlement Approvals; Changes and Amendments. 3.9.1 The Parties acknowledge that refinement and further development of the Project may require Subsequent Entitlement Approvals and may demonstrate that changes are appropriate and desirable in the Existing Entitlement Approvals. Entitlement Approvals (except for this Agreement, the amendment process for which is set forth in Section 2.5) may be amended or modified from time to time, but only at the written request of Developer or with the written consent of Developer (at its sole and absolute discretion). All amendments to the Entitlement Approvals shall automatically become part of the Applicable Rules. 3.9.2 In the event Developer finds that a change in, or addition to, the Existing Entitlement Approvals is necessary or appropriate, Developer shall apply for a Subsequent Entitlement Approval to effectuate such change or addition and the City shall process and act on such application in accordance with the Applicable Rules, except as otherwise provided by this Agreement, including the Reservation of Authority. If approved, any such change in, or addition to, the Existing Entitlement Approvals shall thereafter be deemed to be an Existing Entitlement Approval and a Vested Right for all purposes of this Agreement without requiring an amendment to this Agreement and may be further changed, or added to, from time to time as provided in this Section. 3.9.3 Notwithstanding any other provision of this Agreement, Developer acknowledges that the Concept Plans and Design Review granted with respect to the Project prior to the Effective Date are applicable to Phase 1 only. The Concept Plans and Design Review as to Phase 2 are illustrative in nature; accordingly, Subsequent Entitlement Approval comprised of Design Review approval shall be required as a condition precedent to Phase 2 development. The City Community Development Department shall determine, in its sole discretion, whether consideration of such approvals shall be made by director's determination or by referral to the City Planning Commission. In all cases, such approvals shall be subject to the provisions of the Tustin City Code regarding appeal. Tustin Cornerstone I Development 27 City of Tustin/Comerstone I Agreement 9-15-2016 (PC) final 3.10 Reservation of Authority. Notwithstanding any other provision of this Agreement to the contrary, the Future Rules described in this Section 3.10 shall apply to and govern development of the Property and Project to the extent set forth herein. 3.10.1 Overriding State and Federal Laws. The City shall not be precluded from adopting and applying Future Rules to the Property and the development of the Project to the extent that such Future Rules are required to be applied by State or Federal laws or regulations and which would override Developer's Vested Rights as set forth in this Agreement, provided however, that (a) Developer does not waive its right to challenge or contest the validity of such State or Federal rules or regulations; and (b) such Future Rules, if otherwise in conflict with the Vested Rights (as described in Section 3.6.2) shall only be applied to the Project and development of the Project to the extent necessary to comply with such new State or Federal law or regulation. In the event that such State or Federal law or regulation (or Future Rules undertaken pursuant thereto) prevents or precludes substantial compliance with one or more provisions of the Existing Land Use Regulations or this Agreement, the Parties agree to consider in good faith amending or suspending such provisions of this Agreement as may be necessary to comply with such State or Federal laws (or Future Rules), provided that no Party shall be bound to approve any amendment to this Agreement unless this Agreement is amended in accordance with the procedures applicable to the adoption of development agreements as set forth in the Development Agreement Statute and Tustin City Code and each Party retains full discretion with respect thereto. 3.10.2 Public Health and Safety. Nothing in this Agreement shall preclude the City Council from adopting and applying Future Rules that the City Council finds are reasonably necessary to protect persons on the Property or in the immediate community, or both, from conditions dangerous to their health or safety notwithstanding that the applications of such Future Rules or other similar limitation would result in the impairment of Developer's Vested Rights under the Agreement or the Existing Land Use Regulations. In determining whether any such Future Rules are reasonably necessary to protect persons as set forth above, the City Council shall make findings, based on evidence presented to and accepted by the City Council that the changes are reasonably necessary to protect the public health or safety. The provisions of this Section 3.10.2 do not apply to any measure adopted by initiative. 3.10.3 Uniform Construction Codes and Regulations. Policies and rules governing engineering and construction standards and specifications applicable to public and private improvements, including all uniform codes adopted by the City and any local amendments to those codes adopted by the City in the future shall apply to the Project and Property. 3.10.4 Police Power. In all respects not provided for in this Agreement, the City shall retain full rights to exercise its police powers to regulate development of the Project and Property. Any uses or development requiring a concept plan, design review, tentative tract map, conditional use permit, variance, or other Entitlement Approvals in accordance with Existing Land Use Regulations shall require a permit or approval pursuant to this Agreement and notwithstanding any other provision set forth herein, this Agreement is not intended to vest Developer's right to issuance of such permit or approval. Tustin Cornerstone I Development 2$ City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final 3.11 Processing. 3.11.1 Subdivisions. A subdivision, as defined in Government Code Section 66473.7, shall not be approved unless a tentative map for the subdivision complies with the provisions of said Section 66473.7. This provision is included in this Agreement to comply with Section 65867.5 of the Government Code. 3.11.2 Subsequent Entitlement Approvals. The City shall employ all lawful actions capable of being undertaken by the City to promptly (a) accept all complete applications for Subsequent Entitlement Approvals (collectively, "Applications") and (b) process and take action upon Applications in accordance with the Applicable Rules with a goal of completing the review within time frames identified in the DDA; provided however, that the City shall not be deemed in default under this Agreement should such time frame(s) not be met. To the extent that Developer desires that the City plan check or process an Application on an expedited basis and to the extent that it requires an additional expense beyond the customary expense applicable to the general public, the City shall inform Developer of such additional expense, including the cost of overtime and private consultants and other third parties. If acceptable to Developer, Developer shall pay the additional cost and the City shall use good faith efforts to accelerate the processing time utilizing overtime and the services of private consultants and third parties to the extent available. Upon the written request of Developer, the City shall inform Developer of the necessary application requirements for any requested City approval or requirement relating to the Project. 3.11.3 Filings. Developer shall exercise reasonable efforts to file applications for Development Permits and Entitlement Approvals within the time frames and schedules as generally outlined in the DDA and shall exercise reasonable efforts to attempt to obtain Development Permits and Entitlement Approvals within the time frames identified in the DDA; provided, however, that failure solely to comply with such time frame(s) shall not be deemed to be a default under this Agreement. 3.11.4 Cooperation. The City and Developer shall cooperate in processing all applications for permits and approvals for the Project, provided, however, that such cooperation shall not include any obligation of the City to incur any un -reimbursed expense, and the City shall be entitled, subject to the terms of this Agreement, the DDA and Developer's rights hereunder, to exercise all discretion to which it is entitled by law in processing and issuing any permits and approvals for the Project. 3.11.5 Approvals. Notwithstanding any administrative or judicial proceedings, initiative or referendum concerning any of the Entitlement Approvals, the City shall process applications for permits and approvals as provided herein to the fullest extent allowed by law and Developer may proceed at its sole risk with development of the Project pursuant to the DDA, the Other Agreements, the Applicable Rules and Entitlement Approvals to the fullest extent allowed by law. Notwithstanding the foregoing, Developer acknowledges and agrees that the City reserves its discretion to approve or disapprove all Subsequent Entitlement Approvals with respect to the Project and that nothing in this Agreement will be construed as circumventing or limiting the City's discretion with respect thereto or with respect to the environmental review required by CEQA. Such reservation of discretion will apply to all contemplated legislative and quasi-judicial Tustin Cornerstone I Development 29 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final actions including approval of land use entitlements, CEQA. compliance, code enforcement and the making of findings and determinations, required by law and the City may, in its sole and absolute discretion, elect not to approve, adopt or certify. any requested Subsequent Entitlement Approvals based on CEQA review or other discretionary factors. . 3.12 CEQA; This Agreement does not modify, alter or change the City's obligations pursuant to CEQA. Developer acknowledges that the City is required by State law to comply with CEQA in the consideration . and, approval of any. Subsequent Entitlement Approval and/or any amendment to this Agreement. The 'EIR, which has been certified by the City as being in compliance with CEQA, addresses the potential environmental impacts of the entire Project as it is described in the Existing Entitlement Approvals. Nothing in this Agreement shall require or be construed to require CEQA review .of ministerial approvals. It is agreed that, in acting on any discretionary Subsequent Entitlement Approvals for the Project, the City shall rely on the EIR to satisfy the requirements of CEQA to the extent permissible by CEQA. In the event that any additional CEQA documentation is legally required for any discretionary Subsequent Entitlement Approval for the Project, then the scope of such " documentation shall be focused, to the extent possible consistent with CEQA, on the specific subject matter of the Subsequent Entitlement Approval and the City shall conduct such CEQA review as expeditiously as possible, at Developer's expense. Nothing herein shall restrictor limit the obligation of Developer to pay for and implement any additional mitigation measures or conditions of approval imposed as a result of such CEQA and any Subsequent Entitlement Approval process. 3.13 Fees. 3.13.1 Processing Fees and Charges. (a) The City shall have the right to charge and Developer shall be required to pay all City Processing Fees which shall, except as otherwise specifically set forth in Section 3.13.1(b), be paid at the generally applicable rates in effect at the time such City Processing Fees are due. (b) With respect to Plan Check and Inspection Services only, the City shall be entitled to charge and Developer shall reimburse the City for its costs to make available City staff, including the City Attorney, "and third party engineers and consultants, if any, as. required to complete, process, and review plans and applications, complete plan check, perform inspections, and monitor Developer compliance with the requirements of this Agreement and the Applicable Rules. Not later than ten (10) business days following approval by the City of this Agreement, and as a condition to the effectiveness of this Agreement, Developer shall deliver to the City in cash or cash equivalent funds, a deposit in an amount reasonably requested by City which shall be based on the City's estimate of staff and third party consultant time required to complete and perform plan check and inspections (the "City Costs Deposit"). The City Costs Deposit shall be deposited by the City in an account in a bank or trust company selected by the City and with no requirement that such account be interest bearing. If any interest is paid on such account, such interest shall accrue to any balances in the account for the benefit of the City. If at any time prior to the latest to occur of (a) issuance of the final Certificate of Compliance for the Property; (b) the issuance of the final certificate of occupancy for a Building on the Property; or Tustin Cornerstone I Development 30 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final (c) termination of the DDA (the "Final Date"), the amount of funds in the City Costs Deposit account is depleted below Ten Thousand Dollars ($10,000), then Developer shall be required to pay to the City each time an additional Twenty Thousand Dollars ($20,000) or such other amount as the City may specify as required in City's estimation to cover the cost of Plan Check and Inspection Fees, which shall be credited to the City Costs Deposit. Each such payment shall be deposited by the City into the City Costs Deposit account and shall be applied to reduce the amount of Plan Check and Inspection Fees incurred by the City. The City Costs Deposit has been established to fund the Plan Check and Inspection Fees incurred. by the City and may be used by the City for such purpose, and shall be depleted accordingly. Immediately upon incurring any Plan Check and Inspection Fees or costs or receipt of an invoice from third parties for same, the City shall have the right to deduct the amounts due it on account thereof from the City Costs Deposit. A monthly accounting of deductions documenting staff time spent to process and review plans and applications, complete plan check, perform inspections, and monitor Developer compliance, along with documentation evidencing any other deductions from the City Costs Deposit shall be provided by City to Developer. The City Costs Deposit shall be retained by the City until the Final Date specified above and the remaining amount of the City Costs Deposit then held by the City, if any, shall be promptly returned by the City to Developer thereafter, provided that the return of such funds shall not. terminate the obligations of Developer to pay all City Processing Fees arising or incurred prior to the Final Date. Developer shall pay any outstanding amounts due with respect to the City Processing Fees to the City within thirty (30) calendar days following receipt of an invoice from the City therefor, provided that the City shall first apply the amount of the City Costs Deposit, if any, then held by it in satisfaction of such invoice, and shall reflect the amount of such credit on the invoice. If at any time prior the Final Date, Developer shall assign or convey the Phase 2 Property and the Phase 2 Project separately from the Phase 1 Property and Phase 1 Project; the Option terminates without exercise thereof; or the City, pursuant to exercise of the Right of Repurchase or Right of Reversion or action in lieu thereof pursuant to the DDA takes or transfers title to the Phase 2 Property and the Phase 2 Project separately from the Phase 1 Property and Phase 1 Project, the City shall establish a separate deposit account for Phase 2 in the amount specified above. In such event, all of the foregoing provisions shall separately apply to Phase 1 and to Phase 2, and the "Final Date" with respect to each such Phase shall be the date upon which both conditions (a) and (b), or condition (c) alone, to achievement of such date have occurred with respect to the applicable Phase. 3.13.2 Development Fees. The City shall have the right to impose, and Developer shall pay, all development fees adopted by the City at the time of issuance of building permits for the Project. 3.13.3 Project Fair Share Contribution. The Project Fair Share Contribution (relating to the Tustin Legacy Backbone Infrastructure Program) to be contributed by Developer with respect to the Project shall be Fourteen Million Three Hundred Seventy -Two Thousand Eight Hundred Forty -Two Dollars ($14,372,842) which amount shall be paid as a component of the Purchase Price for the Property pursuant to the DDA. The Contribution shall be paid at a rate of $8.53 per land square foot, and shall be equal to Six Million Four Hundred Ninety -Nine Thousand Tustin Cornerstone I Development 31 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final Three Hundred and Forty -Seven Dollars ($6,499,347) .for Phase 1 and Seven Million Eight Hundred Seventy -Three Thousand Four Hundred Ninety -Five Dollars ($7,873,495) for Phase 2. 3.14 Dedications. Developer acknowledges and agrees that it may be required to make certain dedication to the City and other public agencies as required by (a) the Entitlement Approvals, including the approved tentative parcel map, (b) the Applicable Rules, (c) the DDA and the Other Agreements, (d) the EIR and subsequent CEQA documents, if any, adopted by the City in connection with any Subsequent Entitlement .Approval, and (e) as required pursuant to Developer's assumption of the City's MCAS .Tustin obligations under the "Agreement Between the City of Irvine and the City of Tustin Regarding the Implementation, Timing, Funding of Transportation/Circulation Mitigation for the MCAS Tustin Project" and the "Amendment to the Joint Exercise of Powers Agreement Between the City of Santa Ana and the City of Tustin Regarding the Tustin -Santa Ana Transportation Improvement Authority". 3.15 Regulation by Other Public Agencies. It. is acknowledged by the Parties that other public agencies not within the control of the City possess authority to regulate aspects of .the Project and development of the Property separately from or .jointly with the City and this Agreement does not limit the authority of such other public agencies. The City agrees to cooperate fully, at no 'out of pocket cost to the City, .with Developer in obtaining any required permits or compliance with the regulations , of other public agencies provided such cooperation is not in conflict with any laws, regulations or policies of the City. 3.16 Tentative Parcel Map and Tract Map Extension. Any subdivision map, heretofore or hereafter approved in connection. with development of the Property, shall be eligible for extensions of time as provided in Government Code Section 66452.6, except that any extension shall be consistent with any applicable performance schedule as provided or established in the DDA and shall not be deemed or considered in any way an extension of any Developer rights or obligations under the DDA. 3.17 Recording of Final Map. Development of the Project will require approval by the City of the Final Map. Developer acknowledges and agrees that the City will not issue a building permit for any building pads, until such time as (a) a final parcel map has been approved by the City and Recorded and (b) the City and Developer have entered into a Subdivision Improvement Agreement in form approved by the City in its Governmental Capacity. 3.18 Quimby Fees and Park Fees. All fees required in connection with the Project pursuant to the Quimby Act, California Government Code Section 66477, if any, are included within the Project Fair Share Contribution and Developer shall not have any additional liability on account thereof. 3.19 Compliance with Legal Requirements. Prior to the issuance of any certificate of occupancy for any Building constructed on a Building Pad, Developer shall satisfy all applicable requirements of the Tustin Municipal Code; Specific Plan, and conditions of approval of the Entitlement Approvals relating to or necessary for such Building prior to the issuance of a certificate of occupancy for such Building, including compliance with the Americans with Tustin Cornerstone I Development 32City of Tustin/Comerstone I Agreement 9-15-2016 (PC) final Disabilities Act and necessary Horizontal Improvements, including Common Area Improvements, to support such Building. 3.20 Required Completion of Horizontal Improvements. (a) Developer shall complete all Phase 1 Horizontal Improvements prior to the issuance of the final certificate of occupancy for the final Building to be constructed within Phase 1 or the issuance of a Certificate of Compliance for Phase 1 (whichever occurs first). (b) Developer shall complete all Phase 2 Horizontal Improvements prior to the issuance of the final certificate of occupancy for the final Building to be constructed within Phase 2 or the issuance of a Certificate of Compliance for Phase 2 (whichever occurs first). (c) Developer shall complete all landscaping and irrigation improvements that had been assured through the provision of bonds, guarantees, cash collateral, or other instruments pursuant to Exhibit "C" of this Agreement prior to the issuance of the final certificate of occupancy for the final Building to be constructed within Phase 1 (or if it occurs first, the final certificate of occupancy for the final Building to be constructed within Phase 2), or the issuance of a Certificate of Compliance for all of Phase 1 (or, if it occurs first, the issuance of a Certificate of Compliance for all of Phase 2) (whichever occurs first). 4. ANNUAL REVIEW. 4.1 Timing and Annual Review. The City Council shall review Developer's performance under this Agreement at least every twelve (12) months from the Effective Date until expiration of the Agreement. In connection with such periodic review, both the City and Developer shall have a reasonable opportunity to assert matters which either believes have not been undertaken in accordance with this Agreement, to explain the basis for such assertion, and to receive from the other Party a justification of its position on such matters. 4.2 Review Procedure. The City shall provide notice to Developer and deliver to Developer a copy of all public staff reports, documents and related exhibits concerning the City's review of Developer's performance hereunder at least thirty (30) calendar days prior to any date proposed for City Council review of performance under the Agreement. 4.2.1 Good Faith Compliance. Developer shall demonstrate good faith compliance with the terms of this Agreement and shall furnish evidence of good faith compliance, as the City, in its reasonable exercise of its discretion, may require. Evidence of good faith compliance may include the following: (a) and Schedule of Performance; (b) (c) City. Tustin Cornerstone I Development Agreement 9-15-2016 (PC) final conformance with the DDA, including the Scope of Development conformance with the requirements of the Specific Plan; and conformance with provisions of this Agreement identified by the 33 City of Tustin/Cornerstone I 4.2.2 Response. Developer shall have the opportunity to be heard and respond to the City's evaluation of Developer's . performance; either orally or in a written statement, at Developer's election. 4.2.3 Non -Compliance. If, as a result of its periodic review as described in Section 4.1, the City Council finds and determines, on the basis of substantial evidence, that the Developer has not complied in good faith with the terms or,conditions of this Agreement,.the City Council may commence proceedings, to enforce, modify, or terminate this Agreement. 4.2.4 Referral. The City Council, may refer the matter to the Planning Commission for further proceedings or for a report and recommendation. 4.3 Modification or Termination.' If the City Council determines to proceed with modification or termination of this Agreement, the City Council shall give notice to Developer of its intention to do so. The Notice shall contain all information required by Tustin City Code Section 9618. At the time and place set for the hearing -on modification or termination, the City Council may refer the matter back to the Planning Commission for further proceedings or for a report and recommendation. . The City Council may take such action as it deems necessary to protect the interests of the City, including but not limited to, the receipt of additional evidence as to Developer's compliance with the terms of this Agreement. The decision of the City Council shall be final, subject only to judicial. review pursuant to California Code of Civil Procedure Section 1094.5(b). 4.4 Certificate of Agreement Compliance. If, at the conclusion of a periodic review, Developer is found to be in compliance with this Agreement, the City shall, upon request of the Developer, issue a Certificate (the "Certificate") to Developer stating that after the most recent periodic review and based uponthe information known or made known to the City Council that: (a) this Agreement remains in effect; and. (b) Developer is not in default. The Certificate shall be in recordable form, shall contain information necessary to communicate constructive record notice of the finding of compliance, and shall state the anticipated date of commencement of the next periodic review. Developer may record the Certificate with the County Recorder. If the City does not find Developer to be in compliance with this Agreement, it shall not be obligated to issue the Certificate. 5. DEFAULT, REMEDIES, AND TERMINATION. 5.1 ' Default Procedure. A non -defaulting Party (the "Non -Defaulting. Party") at its discretion may elect to declare a default under this Agreement in accordance with the procedures hereinafter set forth for any failure or breach of any other Party ("Defaulting Party") to perform any material duty or obligation of said Defaulting Party in accordance with the terms of this Agreement. However, the Non -Defaulting Party must provide written notice to the Defaulting Party setting forth the nature of the breach or failure and the actions, if any, required by the Defaulting Party to cure such breach or failure. The Defaulting Party shall be deemed to be in "default" of its obligations set forth in this Agreement if the Defaulting Party has failed to take action and cure the default within fifteen (15) calendar days after the date of such notice (for monetary defaults) or 'within thirty (30) calendar days after the date of such notice (for Tustin Cornerstone I Development 34 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final non -monetary defaults). If, however, a non -monetary default cannot be cured within such thirty (30) calendar day period, as long as the Defaulting Party does each of the following: (a) provides the Non -Defaulting Party in writing a reasonable explanation as to the reasons the asserted default is not curable within the thirty(30) calendar day period; (b) notifies the Non -Defaulting. Party in writing of the Defaulting Party's proposed course of action to cure the default; period; (c) promptly commences to cure the default within the thirty (30) calendar day (d) makes periodic written reports to the Non -Defaulting Party as to the progress of the program of cure; and (e) diligently prosecutes such cure to completion, then the Non -Defaulting Party shall grant in writing the Defaulting Party such additional time as determined by the Non -Defaulting Party as reasonably necessary to cure such default. Notwithstanding any provision to the contrary contained herein, (1) the Developer shall not be declared in default under this Agreement solely because of Developer's default under the DDA and/or Other Agreements. Developer's failure to comply with the terms and conditions of the DDA and/or Other Agreements or Developer's failure to complete the Project in accordance with the schedules set forth in the DDA (provided that to the extent.the provisions of this Agreement are the same as those contained in the DDA and/or the Othei• Agreements, then breach of such provisions in this Agreement shall be an independent breach of this Agreement) and (2) subject to Sections 2.4.3 and 2.4.4, if Developer has conveyed,, assigned or transferred a portion of the Property pursuant to an Approved Transfer, then from and after the effective date of such conveyance, assignment or transfer, any determination that a Party is in default with respect to matters arising subsequent to such transfer date shall be effective only as to the Party to whom the determination is made and the portions of the Property in which such Party has an interest. 5.2 City's Remedies. In the event of an uncured default by Developer under this Agreement, the City, at its option, may institute legal action to cure, correct or remedy such default, enjoining any threatened or attempted violation, enforce the terms of this Agreement by specific performance, or pursue any other legal or equitable remedy. Furthermore, the City, in addition to or as an alternative to exercising the remedies in this Section 5.2, in the event of a material default by Developer, may give notice of its intent to terminate or modify this Agreement pursuant to Section 4.3, in which event the matter shall be scheduled for consideration and review by the City Council in the manner set forth in Section 4.3. 5.3 Developer's Remedies. In the event of an uncured default of the City under this Agreement, Developer shall be entitled to any or all of the following remedies: (a) seeking mandamus or special writs, injunctive relief, or specific performance of this Agreement; (b) modification or termination of this Agreement; or (c) seeking any other remedy available at law or in equity, provided, however, except as provided in Section 9.10 below and subject to such further limitations on this provision contained in the DDA and/or the Other Agreements, the Tustin Cornerstone I Development 35 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final Developer agrees and covenants on behalf of itself and its successors and assigns, not to sue the City for damages or monetary relief for any. breach of this Agreement or arising out of or connected with any dispute, controversy or .issue, regarding the application or effect of this Agreement, or for general, special, compensatory, expectation, anticipation, indirect, consequential, exemplary, or punitive damages ("Damages') arising out of or connected with any dispute, controversy, or issues regarding the application or effect of this Agreement, the DDA, the Other Agreements, the Applicable'Rules; or any Development Permits or Entitlement Approvals sought in connection with development or use of the Property or Project, or any portion thereof. Developer acknowledges that the Ci11 ty would not have entered into this Agreement if the City could be held liable for Damages .for any default or breach arising out of this Agreement and that Developer has adequate remedies other than Damages to secure the City's compliance with its obligations under this' Agreement. Therefore, Developer agrees that the City, its officers, employees and agents shall not be liable for any Damages and that this Section shall apply to all Successors In Interest of Developer. - 5.4 Third Party Legal Challenges. In. the event of any legal action instituted by a third party challenging the validity or enforceability of -any provision of this Agreement, the Applicable Rules, the DDA, or Entitlement Approvals for the Project or the approval of any CEQA document prepared in connection with the foi-egoing, Developer agrees, at its sole cost and expense, to defend (with counsel reasonably acceptable to'the City), indemnify, and hold harmless the City, its officers, employees, agents, and consultants, from any claim, action, or proceeding against the City, its officers, agents, and employees, which `seeks to attack, set aside, challenge, void, or annul an approval of the City Council, the Planning Commission, or any other decision-making body, including staff, concerning the Project. The City agrees to promptly notify Developer of any. such claim or action filed against the City and to cooperate inAhe defense of any such action. Developer shall also indemnify and hold harmless the City and its agents, officials and employees from and against all claims, losses, or liabilities assessed or awarded against the City by way of judgment, settlement, or stipulation. The City may elect to participate in the defense of any such action under this condition. 6. INDEMNITY BY DEVELOPER. Developer agrees to indemnify, defend, and hold harmless the City, the City's designees, and their respective elected and appointed officials, boards, commissions, agents, contractors, and employees from and against any and all actions, suits, claims, liabilities, losses, damages, penalties, obligations and expenses (including attorney's fees and costs) which may arise, directly or indirectly, from the acts, omissions, or operations of Developer or Developer's agents, contractors, subcontractors, agents, or employees pursuant to this Agreement, but excluding any loss resulting from the intentional or active negligence of the City, the City's designee, or each of their respective elected and appointed officials, boards, commissions, officers, agents, contractors, and employees. Developer shall select and retain counsel reasonably acceptable to the City to defend any action or actions and Developer shall pay the cost thereof. The indemnity provisions' set forth in this Agreement shall survive termination of the Agreement. Tustin Cornerstone I Development 36 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final 1 7. MORTGAGEE PROTECTION. The Parties hereto agree that this Agreement shall not prevent or limit Developer, in any manner, from encumbering the Property or any portion thereof or any improvement thereon by any Mortgage securing financing with respect to the Property; provided that nothing herein shall . modify or amend the restrictions set forth in the DDA with respect to Mortgages. Any Mortgagee holding a Mortgage that is not prohibited by the DDA shall be entitled to the following rights and privileges: (a) This Agreement shall be superior and senior to any lien placed upon the Property or any portion thereof after the date of recording of this Agreement, including the lien of any Mortgage. Notwithstanding the foregoing, neither entering into this Agreement nor a breach of this Agreement shall defeat, render invalid, diminish or impair the lien of any Mortgage on the Property made in good faith and for value, unless otherwise required by law, and any acquisition or acceptance of title or any right or interest in or with respect to the Property or any portion thereof by a Mortgagee (whether pursuant to foreclosure, trustee's sale, deed in lieu of foreclosure, lease termination or otherwise) shall be subject to the terms and conditions of this Agreement and any such Mortgagee who takes title to the Property or any portion thereof shall be entitled to benefits arising under this Agreement. (b) Each Mortgagee of any Mortgage encumbering the Property, or any part thereof, and which is not securing the interest of an End User shall upon written request in writing to the City, be entitled to receive written notice from the City of results of the Annual Review and of any default by Developer in the performance of Developer's obligations under this Agreement concurrently with delivery of same to Developer and shall have the right, but not the obligation, to cure the default during the remaining cure period allowed such Party under this Agreement (including any extended cure period necessary in order to allow the Mortgagee to obtain title to the Property and cure the default). Notwithstanding the foregoing; the failure of the City to deliver a concurrent copy of such notice of default to a Mortgagee shall.not affect in any way the validity of the notice of default as it relates to the Developer, and provided, further, the giving of any notice of default or the failure to deliver a copy to any Permitted Mortgagee shall in no event create any liability on the part of the Person so declaring a defau It. . (c) Any Mortgagee who comes into possession of the Property, or any part thereof, pursuant to foreclosure of the Mortgage or deed in I ieu of such foreclosure, shall take the Property, or part thereof, subject to the terms of this Agreement. Notwithstanding any other provision of this Agreement to the contrary, no Mortgagee shall have an obligation or duty under this Agreement to perform any of Developer's obligations or other affirmative covenants of Developer hereunder, or to guarantee such performance; except that (i) the Mortgagee shall have no right to develop the Property without fully complying with the terms of this Agreement, the DDA, the Applicable Rules and Entitlement Approvals and (ii) to the extent that any covenant to be performed by Developer is a condition precedent to the performance of a covenant by the City, the performance thereof shall continue to be a condition precedent to the City's performance hereunder. Notwithstanding anything to the contrary contained above in this Section, any Mortgagee Tustin Cornerstone I Development 37 City of Tustin/Comerstone I Agreement 9-15-2016 (PC) final shall be subject to all of the terms of the DDA, to -the extent applicable pursuant to the DDA to such Mortgagee. 8. INTENTIONALLY DELETED. 9. MISCELLANEOUS PROVISIONS. 9.1 Recordation of Agreement. This Agreement and any amendment or cancellation thereof shall be recorded with the Orange County Recorder by the City Clerk within ten (10) calendar days after the City executes- this .Agreement, as required by Section 65868.5 of the Government Code. If the Parties to this Agreement, amend or cancel this Agreement as provided for herein and in Government Code Section 65868, or if the City terminates or modifies this Agreement as provided for herein. and .in Government Code Section 65865.1 for failure of Developer to comply in good faith with the terms or conditions of this Agreement, the City Clerk shall have notice of such action recorded with the Orange County Recorder. 9.2 Entire Agreement. This Agreement,, the DDA and the Other Agreements set forth and contain the entire understanding and agreeinent of the Parties with respect to the matters set forth herein, and there are no oralor. written representations, understandings or ancillary covenants, undertakings or agreements which are- not contained or expressly referred to herein. No testimony or evidence of any such representations, understandings or covenants shall be admissible in any proceeding of any kind or nature to interpret or determine the terms or conditions of this Agreement. 9.3 Severability. If any term, provision, covenant or condition of this Agreement shall be determined invalid, void or unenforceable, the remainder of this Agreement shall not be affected thereby to the extent such remaining provisions are not rendered impractical to perform taking into consideration the purposes of this Agreement. 9.4 Interpretation and Governing Law. This Agreement and any dispute arising hereunder shall be governed and interpreted in accordance with the internal laws of the State of California without reference to choice of law or conflicts of law provisions. This Agreement shall be construed as a whole according to its fair language and common meaning to achieve the objectives and purposes of the Parties hereto, and the rule of construction to the effect that ambiguities are to be resolved against the drafting Party shall not be employed in interpreting this Agreement, all Parties having been represented by counsel in the negotiation and preparation hereof. The decision of the City Council shall be final, subject only to judicial review pursuant to California Code of Civil Procedure Section 1094.5(b). 9.5 Section Headings. All Section headings and subheadings are inserted for convenience only and shall not affect any construction or interpretation of this Agreement. 9.6 Construction. 9.6.1 References to Sections, Clauses and Exhibits. Unless otherwise indicated, references in this Agreement to secti'ons, clauses and exhibits are to the same contained in or Tustin Cornerstone I Development 38 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final '-., attached to this Agreement and all exhibits referenced in this Agreement are incorporated in this Agreement by this reference as though fully set forth in this Section. 9.6.2 Singular and Plural. As used herein, the singular of any word includes the plural and vice versa. 9.6.3 Includes and Including. As used in this Agreement the words "include" and "including" mean, respectively, "include, without limitation" and "including, without limitation". 9.7 Time of Essence. Subject to the following sentence, time is of the essence in the performance of each provision of this Agreement. Whenever action must be taken (including the giving of notice or the delivery of documents) under this Agreement during a certain period of time or by a particular date that ends or occurs on a non -Business Day, then such period or date shall be extended until the immediately following Business Day. 9.8 Waiver. Failure by a Party to insist upon the strict performance of any of the provisions of this Agreement by the other Party, or the failure by a Party to exercise its rights upon the default of the other Party, shall not constitute a waiver of such Party's right to insist and demand strict compliance by the other Party with the terms of this Agreement thereafter. 9.9 No Third Party Beneficiaries. This Agreement is made and entered into for the sole protection and benefit of the Parties and their successors and assigns. No other person shall have any right of action based upon any provision of this Agreement. 9.10 Attorneys' Fees. If any Party to this Agreement institutes any action, suit, counterclaim or other proceeding for any relief against another Party, declaratory or otherwise (collectively an "Action"), to enforce the terms hereof or to declare rights hereunder or with respect to any inaccuracies or material omissions in connection with any of the covenants, representations, warranties or obligations on the part of the other Party to this Agreement, then the Prevailing Party in such Action shall be entitled to have and recover of and from the other Party all costs and expenses of the Action, including (a) the Prevailing Party's reasonable attorneys' fees (which, if the Prevailing Party is the City, shall be payable at the actual contractual hourly rate for the City's litigation counsel at the time the fees were incurred, and which with respect to both the City and the Developer shall in no event be more than $200 per hour) and (b) costs actually incurred in bringing and prosecuting such Action and/or enforcing any judgment, order, ruling or award (collectively, a "Decision") granted therein, all of which shall be deemed to have accrued on the commencement of such Action and shall be paid whether or not such Action is prosecuted to a Decision. Any Decision entered in any final judgment shall contain a specific provision providing for the recovery of all costs and expenses of suit, including reasonable attorneys' fees and expert fees and costs (collectively "Costs") incurred in enforcing, perfecting and executing such judgment. For the purposes of this paragraph, Costs.shall include in addition to Costs incurred in prosecution or defense of the underlying action, reasonable attorneys' fees, costs, expenses and expert fees and costs incurred in the following: (a) post judgment motions and collection actions; (b) contempt proceedings; (c) garnishment, levy, debtor and third party examinations; (d) discovery; (e) bankruptcy litigation; and (f) appeals of any order or judgment. "Prevailing Party" within the meaning of this Section 9.10 includes a Party who agrees to dismiss an Action in Tustin Cornerstone I Development 39 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final consideration for the other Party's payment of the amounts allegedly due or performance of the covenants allegedly breached, or obtains substantially the relief sought by such Party. 9.11 Force Majeure. 9.11.1 "Force Majeure Delay" means the occurrence of any of the following events when such event is beyond, the control of. the Party claiming Force Majeure Delay ("Claiming Party") and such. Party's officers, directors, employees, contractors, consultants, agents and representatives and is not due to an act or omission of Claiming Party or its officers, directors, employees, contractors, consultants, agents or representatives, which directly, materially and adversely affects (a) the ability. of the Claiming Party to meet its non -monetary obligations under this Agreement, including the deadlines imposed by_the Schedule of Performance, or (b) the ability of Developer to Complete the Project, and which events (or the effect of which events) reasonably could not have been avoided by due diligence and use of commercially reasonable efforts by the Claiming Party: (a) Civil Unrest. An epidemic, blockade, quarantine, rebellion, war, insurrection, act of terrorism, strike or lock -out, riot, act of sabotage, civil commotion, act of a public enemy, freight embargo, or lack of transportation; (b) Unforeseeable Conditions. Reasonably unforeseeable physical condition of the Property including the presence of Hazardous Materials; (c) Casualty. _. Fire; earthquake, or other casualty, in each case only if causing material physical destruction"or damage on the Property; (d) Liti ag tion. Any lawsuit seeking to restrain, enjoin, challenge or delay any issuance of any Entitlement Approval or seeking to restrain, enjoin, challenge, or delay construction of the Project which is defended by the Claiming Party; (e) Weather. Unusually severe weather conditions not reasonably anticipatable for the City of Tustin, based upon U.S.. Weather Bureau climatological reports for the months included plus a report indicating average precipitation, temperature, etc. for the last ten (10) years from the nearest reporting station; and 9.11.2 Limitation. The term "Force Majeure Delay" shall be limited to the matters listed in Section 9.11.1 above and specifically excludes from its definition the following matters which might otherwise be considered Force Majeure Delay: (a) Entitlements. The suspension, termination, interruption, denial or failure to obtain or nonrenewal of any Entitlement Approval or Development Permit, license, consent, authorization or other permit,or approval which is necessary for the development of the Project; except for any such matter resulting from -a lawsuit as described in Section 9.11.1(d); (b) Foreseeable Changes in Governmental Requirements. Any change in Government Requirements which was proposed prior to the Effective Date; Tustin Cornerstone I Development 40 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final (c) Failure to Perform Obligations. Failure of Developer to perform any obligation to be performed by Developer as the result of adverse changes in the financial condition of Developer or any other Person.; (d) Failure to Provide Financial Security. Failure of Developer to provide financial security required by this Agreement when due or to submit evidence of financing of the Project or to perform any obligation to be performed by Developer hereunder as the result of adverse changes in market conditions; (e) Failure to Submit Required Documentation. Failure to submit documentation as and when required by this Agreement; (f) Failure to Submit Entitlement Applications. Failure to timely submit applications for any Entitlement Approval or Development Permit required for construction of the Improvements or development of the Project on the Property when required pursuant to the Schedule of Performance; and (g) Failure to Execute. Documents. Failure of the Claiming Party to execute documents; and (h) Other Matters. All other matters not caused by the Second Party and not listed in Section 9.11:1. 9.11.3 If the Claiming Party believes that an' extension of time is due to Force Majeure Delay, it shall notify the other Party (the "Second Party") in writing within thirty (30) calendar days from the date upon which the Claiming Party becomes aware of such Force Majeure Delay, generally describing the Force Majeure Delay,.,and its date of commencement. Upon written request from the Second Party, the Claiming Party shall promptly provide the following information with respect to such Force Majeure Delay: a more detailed description of the Force Majeure Delay, when and how the Claiming Party obtained knowledge thereof, the steps the Claiming Party anticipates taking to respond to such Force Majeure Delay, and the estimated delay resulting from such Force Majeure Delay and response and such other information as the Second Party may reasonable request. The extension for Force Majeure Delay shall be granted or denied in the Second Party's reasonable discretion. If the Claiming Party fails to notify the Second Party in writing of its request for a given Force Majeure Delay within the thirty (30) calendar days specified above, any such extension for such Force Majeure Delay shall be at the sole discretion of the Second Party. 9.11.4 Time periods for performance of any obligations under this Agreement may be extended for Force Majeure Delay, except that in no event shall the Term of this Agreement be extended by an event of Force Majeure Delay beyond the time period set forth in the applicable subsection of Section 2.3.1. 9.12 Successors and Assigns. The burdens of this Agreement shall be binding upon, and the benefits of this Agreement shall inure to the City=and its successors and assigns and Developer and its successors and assigns. All provisions of this Agreement shall be enforceable as equitable servitudes and constitute covenants running with the land. Each covenant to do or refrain from Tustin Cornerstone I Development 41 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final doing some act hereunder with regard to development of the Property: (a) is for the benefit of and is a burden upon every portion of the Property; (b) runs with the Property and each portion thereof, and (c) is binding upon Developer and each Successor In Interest of Developer during its period of ownership of the Property or any portion thereof and for such longer period as such Party may have liability hereunder. Notwithstanding the foregoing, upon acquisition of the Property or any portion thereof by the City pursuant -to exercise of the Right of Repurchase or Right of Reversion or action in lieu thereof pursuant to the DDA; the City shall have -the right in its sole discretion to terminate this Agreement as to the portion of the Property so acquired._ 9.13 Counterparts. This Agreement. may be executed by the Parties in counterparts, which counterparts shall be construed together and have the same effect as if all of the Parties had executed the same instrument. 9.14 Jurisdiction and Venue: Ajay, action at law or in equity arising under this Agreement or brought by a Party,hereto-for the purpose of enforcing, construing or determining the validity of any provision of this Agreementshall be filed and tried in the Superior Court of the County of Orange, State of California,.or the Anited States District Court for the Central District of California, Santa Ana Division, and the Parties hereto waive all provisions of law providing for the filing, removal or change of venue. to any, other court. 9.15 Project as a Private Undertakirt�. It is specifically understood and agreed by and between the Parties hereto that the development of the Project is a private development, that neither Party is acting as the agent of the ,other in any respect hereunder, and that each Party is an independent contracting entity with respect to the terms, covenants and conditions contained in this Agreement. No partnership, joint venture or. other association of any kind is formed by this . Agreement. The only relationship beth-veen the,City and Developer with respect to this Agreement is that of a government entity regulating the development of private property and the developer of such property.. 9.16 Further Actions and Instruments. Each of the Parties shall cooperate with and provide reasonable assistance to the other to.the extent contemplated hereunder in the performance of all obligations under this Agreement and the satisfaction of the conditions of this Agreement. Upon the request of either Party at 'any time, the other Party shall promptly execute, with acknowledgment or affidavit if reasonably required; and file or record such required instruments and writings and take any actions as may be reasonably necessary under the terms of this Agreement to carry out the intent and to fulfill the provisions of this Agreement or to evidence or consummate the transactions contemplated by this Agreement. 9.17 Estoppel Certificate. Any Party hereunder, may at any time, deliver a written notice to the other Party requesting such first Party to certify in writing that, to the best knowledge of the certifying Party: (a) this Agreement is in full force and effect and a binding obligation of the Party; (b) this Agreement has not been. amended or modified either orally or in writing, or if so amended, identifying the date and. nature of the amendments to this Agreement, and, in each case, that the Agreement remains in hill .force and effect. (including as amended or modified if applicable), and a continuing binding, obligation of the.Party; and (c) the requesting Party is not in default in performance of its obligations set -forth in the Agreement, or if the Party is in default, Tustin Cornerstone I Development 42 City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final 1 1 . 'i=.,li. provide a description of the nature of such default(s). A Party receiving a request hereunder shall execute and return such certificate within thirty (30) calendar days following receipt thereof. The party to whom such certificate is addressed, including any third party or Mortgagee, shall be entitled to rely on the certificate. Developer shall pay to the City all costs incurred by the City in connection with the issuance of estoppel certificates. 9.18 Authority to Execute. The person or persons executing this Agreement on behalf of each Party warrants and represents that he or she/they have the authority to.execute this Agreement on behalf of such Party and warrants and represents that he or she/they has/have the authority to bind such Party to the performance of its obligations hereunder. 9.19 Non-liabili of City Officials and City Employees. No elected or appointed official, representative, employee, agent, consultant, legal counsel or employee of the City shall be personally liable to Developer for any amount which may become due to Developer under the terms of this Agreement._ 9.20 No Merger. As of the Effective Date, the Property is owned in fee by the City, and portions of the Property may continue to be owned in fee by the City during the Term or may be conveyed by the City to one or more Developers and subsequently reconveyed to the City during the Term. Except as expressly set forth below, there shall be no merger of any rights, interests or estates created by this Agreement as a result of the ownership by the City of all or any portion of the Property and no merger shall occur with respect to any portion of the Property unless and until the City and all persons and entities at the time having a legal and/or equitable ownership interest in such portion of the Property shall join in a written instrument affecting such merger and shall duly record the same. Notwithstanding the foregoing, if the City repurchases or revests any portion of the Property as a result of its exercise of the Right of Repurchase or Right of Reversion under the DDA, the City shall have the right, in its sole discretion, to merge its interests under this Agreement, to terminate this Agreement as to the Property so repurchased or revested, to modify the provisions of this Agreement related to the Property so repurchased or revested or to take other actions affecting this Agreement or the rights of the City in and to the revested Property, without the approval of any other person or entity. [SIGNATURES CONTAINED ON FOLLOWING PAGE] Tustin Cornerstone I Development 43 Agreement 9-15-2016 (PC) final City of Tustin/Cornerstone I SIGNATURE PAGE TO DEVELOPMENT AGREEMENT IN WITNESS WHEREOF, the Parties hereto have executed this Agreement on the day and year set forth below. ATTEST: By: Erica Rabe City Clerk Dated: APPROVED AS TO FORM: Office of the City Attorney BY: David E. Kendig, Esq. CCCU ," City of Tustin, California By: Mayor "Developer" By: _ By: _ Name: Its: By: _ Name: Its: Tustin Cornerstone I Development Agreement S=1 City of Tustin/Cornerstone I 9-15-2016 (PC) final 1 1 1 1 1 EXHIBIT "A" TO DEVELOPMENT AGREEMENT LEGAL DESCRIPTION OF PROPERTY' Phase 1 Parcel: Parcel 1 as shown on Parcel Map 2015-168, filed for record in the Office of the Recorder of the County of Orange, California on . 2016 in Book of Maps at Page Phase 2 Parcel: Parcel 2 as shown on Parcel Map 2015-168, filed for record in the Office of the Recorder of the County of Orange, California on 2016 in Book of Maps at Page 1 Legal Description to be confirmed and finalized upon recordation of Parcel Map 2015-168, prior to execution of this Agreement. Tustin Cornerstone I Development Exhibit A City of Tustin/Comerstone I Agreement 9-15-2016 (PC) final Page 1 EXHIBIT "B ,2 TO DEVELOPMENT AGREEMENT MAP SHOWING PROPERTY AND ITS LOCATION [see map attached] z Depiction to be confirmed and finalized upon recordation of Parcel Map 2015-168, prior to execution of this Agreement. Tustin Cornerstone I Development Exhibit B City of Tustin/Comerstone I Agreement 9-15-2016 (PC) final Page I 1 1 0 SHEET 2 OF 2 SHEM AREA: 39.705 ACRES GROSS NUMBERED PARCELS 2 LETTERED PARCELS; 1 SCALE 1' - 200' LEGEND ACASPHALT CONCRETE AC. ACRES OF CALCULATED FROM C/L CENIETIRE CFS GLOBAL POSITIONING SYSTEM DCSORANGE COIAITY SURVEYOR O.R.OFFICIAL RECORDS P.C.C. POINT OF COMPOUND CURVATURE (RAD) RADIAL S.F. SQUARE FEET SNSEAMFED. FOOD NOTHING VAR. VARIES R1 R1 R1 R1 R1 R1 R1 R1 R1 R1 R1 R1/R2 RECORD REFERENCES () INDICATES MEASURED k RECORD DATA, ULM OTHERWISE NOTED RI TRACT M. 17144, N.N. 906/5-14 k CERTIFICATE OF CORRECTION INSTRUMENT M. 2015000642502, O.R.; 12/21/2015 R2CORNER RECORD 2012-1706B R3 RECORD OF SURVEY ND. 2002-1D58, R.S.B. 194/19-27 MONUMENTNOTES 1. ALL MONUMENTS SHOWN SET WILL BE SET WITHIN 90 DAYS AFTER ACCEPTANCE OF IMPROVEI,ENTS, EXCEPT AS NOTED. 2. NO MONIMEITTS WILL BE SET AT INTERIOR LOT C74ERS OR STREET CENTERLINES, U4.ESS OTHERWISE NOTED. O DENOTES 2' IRON PIPE k BRASS TAG STAMPED 'U.S. 6673', OR LEAD, TACK k TAG STAMPED 'L.S. 6673' IN CONCRETE, DR AN 8' SPIKE k WASHER STAMPED 'L.S. 6673' IN ASPHALT PAVEMENT PAVING A THICKNESS OF 2' OR MORE, TO BE SET AT ALL BOUNDARY CORNERS, ULM OTHERWISE NOTED. (NO MONUMENTS WILL BE SET ALONG THE RIGHT-OF-WAY OF ARMSTRONG AVENUE, UE_ESS OTHERWISE NOTED.) A DENOTES OCS HORIZONTAL CONTROL STATION MONIAENT PER RECORDS ON FILE IN THE OFFICE OF THE ORANGE COUNTY SURVEYM. A DENOTES LEAD, TACK AND TAG 'L. S. 6673' IN CONCRETE, OR 8' SPIKE k WASHER STAMPED 'L.S. 6673' IN ASPHALT PAVEMENT. OR 2' IRON PIPE TAGGED 'LS. 6673' TO BE SET PER R7. ® DENOTES MONUMENT AS NOTED AND REFERENCED HEREON. 01 FOLIO 2' BRASS DISC STAMPED 'L.S. 7177', DOWN 1.5' 1N WELL MONIACNT, PER R2. 6530 FOUND 3' CCS BRASS DISC STAMPED 'DRANGE MIM SURVEYOR 9411 99a DOWN25' IN WELL MOMAEM, PER R2. GS [OGPS W. 6530: N 2204089.342, E 6077144.581 PER OGS HORIZONTAL CONTROL DATA SMEET] 6535 FOM 2' BRASSDISC STAMPED 'L.S. 3246', DOWN 1.8' IN WELL MONLAENT PER R1. [OCS GPS KD. 6535: N 2202360.638, E 6079110.351 PER OCs HORIZONTAL CONTROL DATA SHEET] 6576FOLIO SPIKE k WASfR STAMPED 'L.S. 5831', FLUSH IN AC, PER R1 [OCS GPS NO. 6576: N 2197723.170, E 6084556.279 PER OCS HORIZONTAL CONTROL DATA SEER] PARCEL MAP NO. 2015-168 IN THE CITY OF TUSTIN COUNTY OF ORANGE, STATE OF CALIFORNIA NAU.IAM G. COX LS.6873 CMM� DATE OF SURVEY: SEPTEMBER, 2016 INTERNATIONAL FOR FINANCE AND CONVEYANCE PURPOSES ONLY' GENERAL NOTES 1. PARCEL A IS NOT A SEPARATE BUILDING SITE, IS FOR STREET PURPOSES, ANO IS TO BE1 GRANTED BY SEPARATE INSTRULE14T. BASIS OF BEARINGS THE BEARINGS SHOWN HEREON ARE BASED ON THE BEARING BETWEEN DCS HENIZONTAL CONTROL STATION GPS M. v 6576 AND TPS M. 6530 BEING NORTH 49'20'22' EAST. DATUM STATEMENT COUDINATES SHOWN ARE BASED ON THE CALIFORNIA NTj'45'32 COORDINATE SYSTEM (CCS83), ZONE VI, 1983 NAD 7Rn9j W - (1991.35 EPOCH OCS CPS AOJI1MOIT)• ALL DISTANCES SHOWN GROU ARE ND UNLESS OTHERWISE v NOTED. TO OBTAIN GRID DISTANCE MA-TIPLY GROM DISTANCE BY 0.99997720; COMBINATION FACTOR BEING 4.% �� 4y �O THE AVERAGE OF GPS NO. 6576 k 6530. LOT 'r 9 � A � LOT 'f? PARCEL 1 •�y4� 17.543 AC. LOT NINE DATA TABLE TRACT NO. M. DELTA RADIUS LENGTH C1 13'08'02' 138.32' 31.71' C2 13.15'04' 121.81' 28.17' R3 10 49'35' 1192.00 225.24' C4 14'09'16• 42.00' 10.38' CS 14.09'16' 58.00' 14.33' CES 14'30'51' 58.00' 14.69' C7 14'30'51' 42.00' 10.64' CB 01'48 16' 1452.04 45.73- C9 37.25'14' 82.00' 53.56' CIO 73'24'07' 82.00' 05.05 "I 1949'2' 8.0' 158.61' C2 C13 065 85 59-06- 00 50' 25.00 8.25' 37.52- C14 06.04.04'14DD.04' 14x.27' C15 85.59.06' 61.00' 1 91.54' PARCEL MAP NO. 2015-168 IN THE CITY OF TUSTIN COUNTY OF ORANGE, STATE OF CALIFORNIA NAU.IAM G. COX LS.6873 CMM� DATE OF SURVEY: SEPTEMBER, 2016 INTERNATIONAL FOR FINANCE AND CONVEYANCE PURPOSES ONLY' GENERAL NOTES 1. PARCEL A IS NOT A SEPARATE BUILDING SITE, IS FOR STREET PURPOSES, ANO IS TO BE1 GRANTED BY SEPARATE INSTRULE14T. BASIS OF BEARINGS THE BEARINGS SHOWN HEREON ARE BASED ON THE BEARING BETWEEN DCS HENIZONTAL CONTROL STATION GPS M. v 6576 AND TPS M. 6530 BEING NORTH 49'20'22' EAST. DATUM STATEMENT COUDINATES SHOWN ARE BASED ON THE CALIFORNIA NTj'45'32 COORDINATE SYSTEM (CCS83), ZONE VI, 1983 NAD 7Rn9j W - (1991.35 EPOCH OCS CPS AOJI1MOIT)• ALL DISTANCES SHOWN GROU ARE ND UNLESS OTHERWISE v NOTED. TO OBTAIN GRID DISTANCE MA-TIPLY GROM DISTANCE BY 0.99997720; COMBINATION FACTOR BEING 4.% �� 4y �O THE AVERAGE OF GPS NO. 6576 k 6530. LOT 'r 9 � A � LOT 'f? PARCEL 1 •�y4� 17.543 AC. LOT PARCEL 2 21.195 AC. 3� PARCEL A (FUTU€ STREET) 42,085 S.F. 5\ 1 \ pG• S ��A SEE DETAIL 'D' FERE0N1 EASEMENTODETAIL O i J < � DETAIL C \ NOT TO SCALE \ DETAIL'Y NOT TO SCALE 1" NXDETAIL'S' \ NOT TO SCALE C HEREON / P W o) A A \ oa N, SE DETAIL \l,Pp) B. � Z a'o9 7s- c. L 1fi 15 622.18' 1 v 756.72' .63' _ _ (N49.19'41'W 1463.53')CF R1 pryOWRMRR--(1487.53')R7_-0 - - •-(N49�19'41'W 2617.6l')Rl•o "-C/L RARRANCA PARKWAY • N49'20'12'p 9770.65' (9770.43') GRID• - tiC/L ASTON BASIS OF BEARINGS - I AVENUE > TRACT NO. 17144 P � - I L DARRANCA M.M. 906/5-14 AVENUE Q� n2� c mjjj I r--- II r �I�� L25 _ L24 A L24 R1 P4 I LOT 5 a R1I 36' 1 R1 v I LOT R1 Rl / - - - - _ _ - _ - 6530 NS3'30'36_N 1097.03' GPS TIE 36.00'. R1 L23� C/L ❑1 DYER •• �c R� - - - - SFN- ROAD NOTHING SET PARCEL 2 21.195 AC. 3� PARCEL A (FUTU€ STREET) 42,085 S.F. 5\ 1 \ pG• S ��A SEE DETAIL 'D' FERE0N1 EASEMENTODETAIL O i J < � DETAIL C \ NOT TO SCALE \ DETAIL'Y NOT TO SCALE 1" NXDETAIL'S' \ NOT TO SCALE C HEREON / P W o) A A \ oa N, SE DETAIL \l,Pp) B. � Z a'o9 7s- c. L 1fi 15 622.18' 1 v 756.72' .63' _ _ (N49.19'41'W 1463.53')CF R1 pryOWRMRR--(1487.53')R7_-0 - - •-(N49�19'41'W 2617.6l')Rl•o "-C/L RARRANCA PARKWAY • N49'20'12'p 9770.65' (9770.43') GRID• - tiC/L ASTON BASIS OF BEARINGS - I AVENUE s T ^II 5P ill DETAIL'A' fi535 NOT TO SCALE `C/L RARRANCA PARKWAY EASEMENT NOTES Q DENOTES AN EASEMENT FOR ELECTRICAL k COMANICATION SYSTEMS IN FAVOR OF SOUTHERN CALIFORNIA EDISON COMPANY RECORDED ,ARE 25, 2014 AS INSTRU£NT M. 2014000249989, O.R. QB DENOTES VEIIMM ACCESS RIGHTS HAVE BEEN RELEASED AND RELINQUISHED TO THE CITY OF TUSTIN. EXCEPT AT STREET INTERSECTIONS AND APPROVED ALCM LOCATIONS, 10.00')R1 PER R1. 00 6535 27A 9�\� N C 6576 AVENUE PARCEL 2 P � - I L DARRANCA 21.195 AC. AVENUE Q� c mjjj / r �I�� L25 _ L24 SEE DETAIL 'A' HEREON L24 11271 L26 'yl� c o s T ^II 5P ill DETAIL'A' fi535 NOT TO SCALE `C/L RARRANCA PARKWAY EASEMENT NOTES Q DENOTES AN EASEMENT FOR ELECTRICAL k COMANICATION SYSTEMS IN FAVOR OF SOUTHERN CALIFORNIA EDISON COMPANY RECORDED ,ARE 25, 2014 AS INSTRU£NT M. 2014000249989, O.R. QB DENOTES VEIIMM ACCESS RIGHTS HAVE BEEN RELEASED AND RELINQUISHED TO THE CITY OF TUSTIN. EXCEPT AT STREET INTERSECTIONS AND APPROVED ALCM LOCATIONS, 10.00')R1 PER R1. 00 6535 27A 9�\� I-C/L HARVARD 6576 AVENUE -C/L ARMSTRONG I L DARRANCA AVENUE PARKWAY 1ae361(laxzeo) EXHIBIT "C" TO DEVELOPMENT AGREEMENT PUBLIC BENEFIT IMPROVEMENTS As additional Public Benefits, Developer shall design and construct the following Public Benefit Improvements as set forth below and in the DDA and in accordance with the requirements of the applicable conditions of approval, if any, set forth in the Entitlement Approvals. Each of the following Public Benefit Improvements shall be completed prior to the issuance of the first certificate of occupancy for a Building within the Property, as further described below, and in all events shall be completed prior to the date that is four (4) years after the Effective Date, subject to the Force Majeure Delay provisions of this Agreement, provided that in no event shall the period for completion of the Public Benefit Improvements be extended beyond the Phase 1 Term. Modifications to the schedule may be made with the approval of the City Community Development Director in his or her sole discretion. 1. Developer shall be responsible for the design and construction of full width improvements to the public portion of Flight Way from Barranca Parkway to the entrance of the Property including utilities, curb adjacent sidewalks on both sides of the street, and street lights along both sides of the street. The landscape and irrigation system adjacent to the Property between Barranca Parkway and the Food Hall Building shall be completed or completion shall otherwise be assured through the provision of bonds, guarantees, cash collateral, or other instruments or means satisfactory to the City Community Development Director. 2. Developer shall be responsible for the design and construction of a traffic signal at the intersection of the public portion of Flight Way and Barranca Parkway. Intersection enhancement shall include the creation of left turn lane on Barranca Parkway to Flight Way, additions of signal apparatus including loops and interconnects, signing and striping modifications as necessary, and restoration of landscape medians impacted by - left -turn enhancements or median modifications. 3. Developer shall be responsible for the design and construction of the improvements to Barranca Parkway from the public portion of Flight Way to Armstrong Avenue. Developer shall design and construct the decelerating and accelerating lane and meandering sidewalk on Barranca Parkway along project frontage from Armstrong Avenue to Flight Way. The landscape and irrigation system adjacent to the Property along Barranca Parkway from Flight Way to Armstrong Avenue as approved for Phase 1 of the Project from back of curb to landscape set back limits shall be completed or completion shall otherwise be assured through the provision of bonds, guarantees, cash collateral, or other instruments or means satisfactory to the City Community Development Director. 4. Developer shall be responsible for the design and construction of the improvements to Armstrong Avenue from Legacy Park,to Barranca Parkway, including curb adjacent sidewalks adjacent to the Property. Developer shall also provide final/finish surface course .Asphalt Rubber Hot Mix (ARHM) paving on Armstrong Avenue from Warner Avenue to Barranca Parkway, traffic striping and raise any manhole to grade. The landscape and irrigation system adjacent to the Property along Armstrong Avenue from Legacy Park to Barranca Parkway as approved for Phase 1 of the Project from back of sidewalk to landscape Tustin Cornerstone I Development Exhibit C City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final page 1 1 1 1 set back limits shall be completed or completion shall otherwise be assured through the provision of bonds, guarantees, cash collateral, or other instruments or means satisfactory to the City Community Development Director. Developer shall additionally construct the curb adjacent sidewalk along the west side of Armstrong Avenue from Legacy Park to Warner Avenue. Developer shall install signal conduit, pull boxes and cable for a future traffic signal at the intersection of Airship Avenue and Armstrong Avenue.. 5. Developer shall be responsible for the design and construction of a four-way traffic signal, including loops, interconnects, and radar detection system at the intersection of southerly project entrance and Armstrong Avenue. 6. Developer shall design and construct the public storm drain system, wet utilities, and dry utilities along Flight Way connecting to and crossing Legacy Park (Tract No. 17144, Lots "AA" and `BB"), and the public storm drain system along the north side of Phase 1 adjacent to the Food Hall Building in the locations required pursuant to the DDA and the Entitlement Approvals. Developer shall provide the necessary utility and access easement to the City. 7. Developer shall be responsible for the design and construction of the improvements to Airship Avenue between Barranca Parkway and Armstrong Avenue, including utility improvements, street lighting and curb adjacent sidewalks in the locations required pursuant to the DDA and the Entitlement Approvals. Developer shall also provide final/finish surface course ARHM paving, traffic striping and raise any manhole to grade. The landscape and irrigation system adjacent to the Property as approved for Phase 1 of the Project shall be completed or completion shall otherwise be assured through the provision of bonds, guarantees, cash collateral, or other instruments or means satisfactory to the City Community Development Director. 8. Developer shall be responsible for the design and construction of the improvements to the private portion of Flight Way between the entrance of the Property and Armstrong Avenue, including utility improvements, street lighting and curb adjacent sidewalks, except that between Airship Avenue and Armstrong Avenue sidewalk improvements need only be constructed on the north side of Flight Way. Developer shall also provide final/finish surface course ARHM paving, traffic striping and raise any manhole to grade. The landscape and irrigation system adjacent to the Property as approved for Phase 1 of the Project shall be completed or completion shall otherwise be assured through the provision of bonds, guarantees, cash collateral, or other instruments or means satisfactory to the City Community Development Director. 9. Construction of interim landscaping on Phase 2, as more specifically set forth in the DDA and the Landscape Installation and Maintenance Agreement, as and when required thereby. Such landscaping shall be completed or completion shall otherwise be assured through the provision of bonds, guarantees, cash collateral, or other instruments or means satisfactory to the City Community Development_ Director. 10. A public access easement for public access over to Legacy Park along with the ingress and egress over those certain private streets and pedestrian paseos designated in the Entitlement Approvals and the Roadway and Utility Easement Agreement shall be provided and identified. This shall be provided at no cost to the City and be subject to the review and approval by the City., 11. Developer shall submit legal descriptions and sketches of the areas below, prepared by a California Licensed Civil Engineer or California Licensed Land Surveyor, current Title Tustin Cornerstone I Development Exhibit C City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final Page 2 Report, applicable back up documents, and plan check deposit to the City Public Works Department for review and approval. a. Easements for emergency vehicle access and public services ingress and egress purposes over the private streets and driveways shall be provided, at no cost to the City. b. Developer shall dedicate public access and maintenance easements to the City for sidewalks along the public and private portions of Flight Way and Airship Avenue, Barranca Parkway and Armstrong Avenue, at no cost to the City. c. Developer shall dedicate an easement for pedestrian ingress and egress connecting Airship Avenue and Legacy Park through Lot 1, as generally depicted on Vesting Tentative Tract Map No. 18003. Tustin Cornerstone I Development Exhibit C City of Tustin/Cornerstone I Agreement 9-15-2016 (PC) final Page 3 1 1 1 1 1 1 2 EXHIBIT "D" TO DEVELOPMENT AGREEMENT EXISTING ENTITLEMENT APPROVALS • Development Agreement (DA) 2016-001 • Concept Plan (CP) 2016-001 • Design Review (DR) 2016-001 • Subdivision (SUB) 2016-02/Tentative Parcel Map (TTM) 2015-168 • Conditional Use, Permit 2016-01 (Alcoholic Beverages — Type 47) • Conditional Use Permit 2016-02 (Joint Use Parking) • Conditional Use Permit 2016-15 (Live Entertainment) • Conditional Use Permit 2016-23 (Projection of Mechanical Equipment) • Minor Adjustment 2016-01 (10% Reduction - Parking) • Minor Adjustment 2016-02 (10% Increase - Building Height) I Tustin Cornerstone I Development Exhibit D Agreement 9-15-2016 (PC) final Page 1 City of Tustin/Cornerstone I 1 EXHIBIT B OF RESOLUTION NO. 4321 Environmental Checklist 1 1 1 7 COMMUNITY DEVELOPMENT DEPARTMENT 300 Centennial Way, Tustin, CA 92780 (714) 573-3100 ENVIRONMENTAL ANALYSIS CHECKLIST For Projects With Previously Certified/Approved Environmental Documents: Environmental Impact Statement/Environmental Impact Report (EIS/EIR) for the Disposal and Reuse of Marine Corps Air Station (MCAS) Tustin This checklist of environmental impacts takes into consideration the preparation of an environmental document prepared at an earlier stage of the proposed project. The checklist and evaluation evaluate the adequacy of the earlier document pursuant to. Section 15162 and 15168 of the California Environmental Quality Act (CEQA) Guidelines. A. BACKGROUND Project Title(s): Lead Agency: Lead Agency Contact Person: Flight at Tustin Legacy City of Tustin, 300 Centennial Way, Tustin, California 92780 Erica H. Demkowicz Phone: 714-573-3127 Project Location: That certain site comprised of approximately 38 acres within Neighborhood E/Planning Area 9-12 of the MCAS Tustin Specific Plan, generally bounded by Aston Street to the northwest, Barranca Parkway to the southwest, Armstrong Avenue to the northeast, and the future Legacy Park on the north, all in Tustin, Orange County, California. Project Sponsor's Name City of Tustin and Address: 300 Centennial Way Tustin, CA 92780 General Plan MCAS Tustin Specific Plan Designation: Zoning Designation: MCAS Tustin Specific Plan Project Description: LPC West LLC is proposing "Flight at Tustin Legacy," (the "Project") an approximately 870,000 square foot phased commercial mixed-use development. Phase I, which is projected to commence construction in Fall of 2016, will Evaluation of Environmental Impacts Flight at Tustin Legacy Page 2 include up to approximately 390,440 square feet of development, comprised of four office buildings, a small office campus, a retail/conference center and associated parking to be provided on a shared basis, all as depicted on the accompanying site plan. The retail uses may include a food hall, intended to serve local commercial developments. The balance of the Project is expected to be constructed in one future phase, which may be further broken out into two sub -phases. The buildings will range from one to five stories. The Project will be fully consistent with the MCAS Tustin Specific Plan and is within the Specific Plan. Planning Area 9-12's authorization of 1,267,324 buildable square feet of commercial floor area. The Project will include biofiltration planter boxes and/or basins placed along the perimeters of buildings and in other appropriate areas throughout the project site in order to detain and treat stormwater. A Modular Wetland System will also be placed along streets to provide for additional biofiltration treatment. Project Approvals will include: vesting tentative tract map; development and building permits (including, without limitation, grading, mechanical, electrical and plumbing permits); conditional use permits for joint -use parking, on- site alcoholic beverage sales / ancillary live entertainment, and added height for screened mechanical equipment; a concept plan; minor modification for reduction in parking and increased building height pursuant to the MCAS Tustin Specific Plan; all 'required approvals by the Regional Water Quality Control Board and the County of Orange Health Department; a Development Agreement; and a Disposition and Development Agreement. Surrounding Uses: Northeast: Vacant Land Northwest: Future Linear Park (aka Legacy Park) Southeast: Vacant Land Southwest: Light Industrial and Commercial Previous Environmental On January 16, 2001, the City of Tustin certified the Program Documentation: Final Environmental Impact Statement/Environmental Impact Report (FEIS/EIR) for the reuse and disposal of MCAS Tustin. On December 6, 2004, the City Council adopted Resolution No. 04-76 approving a Supplement to the FEIS/EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted 1 1 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 3 Resolution No. 06-43 approving an Addendum to the FEIS/EIR that reduced overall nonresidential development within the Specific Plan Area, replaced the originally proposed golf course with a linear park system and combined Planning Areas 9-12 so that Neighborhood E would have a single unified trip budget and set of development standards. And, on May, 13, 2013, the City Council adopted Resolution No. 13-32 approving a second Addendum to the FEIS/EIR. The FEIS/EIR along with its Addenda and Supplement is a program EIR under the California Environmental Quality Act (CEQA). The FEIS/EIR, Addenda and Supplement considered the potential environmental impacts associated with development on the former Marine Corps Air Station, Tustin. B. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist in Section D below. ❑ Land Use and Planning ❑ Population and Housing ❑ Geology and Soils ❑ Hydrology and Water Quality ❑ Air Quality ❑ Transportation & Circulation ❑ Biological Resources ❑ Mineral Resources ❑ Agricultural Resources C. DETERDIINATION: On the basis of this initial evaluation: ❑ Hazards and Hazardous Materials ❑ Noise ❑ Public Services ❑ Utilities and Service Systems ❑ Aesthetics ❑ Cultural Resources ❑ Recreation ❑ Mandatory Findings of Significance ❑ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. ❑ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because the mitigation measures described on an attached sheet have been added to the project. A NEGATIVE DECLARATION will be prepared. ❑ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. Evaluation of Environmental Impacts Flight at Tustin Legacy Page 4 ❑ I find that the proposed project MAY have a significant effect(s) on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets, if the effect is a "Potentially Significant impact" or "Potentially Significant Unless Mitigated." An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. ❑x I find that although the proposed project could have a significant effect on the environment, there WILL NOT be a significant effect in this case because all potentially significant effects 1) have been analyzed adequately in an earlier EIR pursuant to applicable standards, and 2) have been avoided or mitigated pursuant to that earlier EIR, including revisions or mitigation measures that are imposed upon the proposed project. ❑ I find that although the proposed project could have a significant effect on the environment, there WILL NOT be a significant effect in this case because all potentially significant effects 1) have been analyzed adequately in an earlier NEGATIVE DECLARATION pursuant to applicable standards, and 2) have been avoided or mitigated pursuant to that earlier NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project. 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 5 D. EVALUATION OF ENVIRONMENTAL IMPACTS I. AESTHETICS: Would the project: a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? c) Substantially degrade the existing visual character or quality of the site and its surroundings? d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? II. AGRICULTURE RESOURCES: In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation' and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? c) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use? III. AIR QUALITY: Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct implementation of the applicable air quality plan? b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? 1 No Substantial Change From New Significant More Severe Previous Impact Impacts Analysis Evaluation of Environmental Impacts Flight at Tustin Legacy Page 6 c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non., attainment under an applicable federal or state ambient air quality standard (including releasing emissions . which exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial pollutant concentrations? e) Create objectionable odors affecting a substantial number of people? IV. BIOLOGICAL RESOURCES: Would the project: a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plan's, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc,) through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? V. CULTURAL RESOURCES: Would the project: a) Cause a substantial adverse change in the significance of a historical resource as defined in § 15064.5? b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5? c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? 1 No Substantial Change From New Significant More Severe Previous Impact Impacts Analysis ❑ ❑ . 0 ❑ ❑ 0 ❑ ❑ 0 ❑ ❑ 0 ❑ ❑ N ❑ ❑ 0 ❑ ❑ 0 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 7 No Substantial Change From New Significant More Severe Previous Impact Impacts Analysis d) Disturb any human remains, including those interred outside of formal cemeteries? ❑ ❑ D VI. GEOLOGY AND SOILS: Would the project: a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ❑ ❑ D ii) Strong seismic ground shaking? ❑ ❑ D iii) Seismic -related ground failure, including liquefaction? ❑ ❑ 0 iv) Landslides? ❑ ❑ D b) Result in substantial soil erosion or the loss of topsoil? ❑ ❑ D c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off- site landslide, lateral spreading, subsidence, liquefaction or collapse? ❑ ❑ 0 d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? ❑ ❑ 0 e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of waste water? ❑ ❑ D VII. HAZARDS AND HAZARDOUS MATERIALS: Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? ❑ ❑ D b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? ❑ ❑ c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? 11 ❑ D Evaluation of Environmental Impacts Flight at Tustin Legacy Page 8 d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? 0 For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? h) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? VIII. HYDROLOGY AND WATER QUALITY: Would the project: a) Violate any water quality standards or waste discharge requirements? b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site? d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? f) Otherwise substantially degrade water quality? g) Place housing within a 100 -year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? 1 No Substantial Change From New Significant More Severe Previous Impact Impacts Analysis ❑ ❑ 0 ❑ ❑ p ❑ ❑ (] ❑ ❑ ❑x ❑ ❑ ❑x ❑ ❑ Q ❑ ❑ ❑x ❑ ❑ ❑x ❑ ❑ 0 ❑ ❑ ❑x ❑ ❑ ❑x Evaluation of Environmental Impacts Flight at Tustin Legacy Page 9 No Substantial Change From New Significant More Severe Previous Impact Impacts Analysis h) Place within a 100 -year flood hazard area structures which would impede or redirect flood flows? ❑ ❑ (] i) Expose people or structures to a significant risk of loss, injury or death involving flooding as a result of the failure of a levee or dam? ❑ ❑ (] j) Inundation by seiche, tsunami, or mudflow? ❑ ❑ (] IX. LAND USE AND PLANNING Would the project: a) Physically divide an established community? ❑ ❑ X b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? ❑ ❑ ❑x c) Conflict with any applicable habitat conservation plan or natural community conservation plan? ❑ ❑ Z X. MINERAL RESOURCES Would the project: a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? ❑ ❑ D b) Result in the loss of availability of a locally -important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? ❑ ❑ M XI. NOISE: Would the project result in: a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? ❑ ❑ N b) Exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? ❑ ❑ D c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? ❑ ❑ (] d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? ❑ ❑ D Evaluation of Environmental Impacts Flight at Tustin Legacy Page 10 e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? 0 For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excess noise levels? XII. POPULATION, AND HOUSING: Would the project: a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? XIII. PUBLIC SERVICES: a) Would the project result insubstantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: Fire protection? Police protection? Schools? Parks? Other public facilities? XIV. RECREATION: a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? No Substantial Change From New Significant More Severe Previous Impact Impacts Analysis ❑ ❑ ❑x ❑ ❑ M ❑ ❑ 1 ❑ ❑ D ❑ ❑ ❑x ❑ ❑ M ❑ ❑ 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 11 XV. TRANSPORTATION/TRAFFIC: Would the project: a) Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e. result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? b) Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways? c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a design feature (e.g. sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? 0 Result in inadequate parking capacity? g) Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? XVI. UTILITIES AND SERVICE SYSTEMS: Would the project: a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? c) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments? 0 Be served by a landfill with sufficient permitted capacity to accommodate the project's solid waste disposal needs? No Substantial Change From New Significant More Severe Previous Impact Impacts Analysis ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑x Evaluation of Environmental Impacts Flight at Tustin Legacy Page 12 g) Comply with federal, state, and local statutes and regulations related to solid waste? XVII. MANDATORY FINDINGS OF SIGNIFICANCE: a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b) Does the project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? 1 No Substantial Change From New Significant - More Severe Previous Impact Impacts Analysis ❑ ❑ 0 ❑ ❑ p 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 13 SECTION E EVALUATION OF ENVIRONMENTAL IMPACTS Flight at Tustin Legacy BACKGROUND On January 16, 2001, the City of Tustin certified the program Final Environmental Impact Statement/Environmental Impact Report (FEIS/EIR) for the reuse and disposal of MCAS Tustin. On December 6, 2004, the City Council adopted Resolution No. 04-76 approving a Supplement to the FEIS/EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted Resolution No. 06-43 approving an Addendum to the FEIS/EIR and, on May 13, 2013, the City Council adopted Resolution No. 13-32 approving a Second Addendum to the FEIS/EIR. The FEIS/EIR along with its Addendums and Supplement is a program EIR under the California Environmental Quality Act (CEQA). The FEIS/EIR, Addendums and Supplement considered the potential environmental impacts associated with development on the former Marine Corps Air Station, Tustin. The FEIS/EIR, Supplement, and Addendums analyzed the environmental consequences of the Navy disposal and local community reuse of the Marine Corps Air Station (MCAS) Tustin site per the Reuse Plan and the MCAS Tustin Specific Plan/Reuse Plan (Specific Plan). The CEQA analysis also analyzed the environmental impacts of certain "Implementation Actions" that the City of Tustin and City of Irvine must take to implement the MCAS Tustin Specific Plan. The MCAS Tustin Specific Plan proposed, and the FEIS/EIR analyzed, a multi-year development period for the planned urban reuse project (Tustin Legacy). When individual discretionary activities within the Specific Plan are proposed, the lead agency is required to examine the individual activities to determine if their effects were fully analyzed in the FEIS/EIR. The agency can approve the activities as being within the scope of the project covered by the FEIS/EIR. If the agency finds that pursuant to Sections 15162, 15163, 15164, 15168 and 15183 of the CEQA Guidelines no new effects would occur, nor would a substantial increase in the severity of previously identified significant effects occur, then no supplemental or subsequent EIR is required. Tustin Legacy is located in central Orange County and approximately 40 miles southeast of downtown Los Angeles. Tustin Legacy is that portion of the former MCAS Tustin within the City of Tustin corporate boundaries. Owned and operated by the Navy and Marine Corps for nearly 60 years, approximately 1,585 gross acres of property at MCAS Tustin were determined surplus to federal government needs, and MCAS Tustin was officially closed in July 1999. The majority of the former MCAS Tustin lies within the southern portion of the City of Tustin. The remaining approximately 73 acres lies within the City of Irvine. Tustin Legacy is in close proximity to four major freeways: the Costa Mesa (SR -55), Santa Ana (1-5), Laguna (SR -133) and San Diego (1-405). Tustin Legacy is also served by the west leg of the Eastern Transportation Corridor (SR 261). The major roadways bordering Tustin Legacy include Red Hill Avenue on the northwest, Edinger Avenue- and Irvine Center Drive on the northeast, Harvard Avenue on the southeast, and Barranca Parkway on the southwest. Jamboree Road transects the Property. John Wayne Airport is located approximately three miles to the south and a Metrolink Commuter Evaluation of Environmental Impacts Flight at Tustin Legacy Page 14 Rail Station is located immediately to the northeast providing daily passenger service to employment centers in Orange, Los Angeles, Riverside, and San Diego counties. LPC West LLC is proposing "Flight at Tustin Legacy," (the "Project" or "Proposed Project") an approximately 870,000 square foot phased commercial mixed-use development. Phase I, which is projected to commence construction in Fall of 2016, will include up to approximately 390,440 square feet of development, comprised of four office buildings, a small office campus, a retail / conference center and associated parking to be provided on a shared basis, all as depicted on the accompanying site plan. The retail uses may include a food hall, intended to serve local commercial developments. The balance of the Project is expected to be constructed in one future phase, which may be further broken out into two sub -phases. The buildings will range from three to five stories. The Project will be fully consistent with the MCAS Tustin Specific Plan and is within the Specific Plan Planning Area 9-12's authorization of 1,267,324 buildable square feet of commercial floor area. The Project will include biofiltration planter boxes and/or basins placed along the perimeters of buildings and in other appropriate areas throughout the project site in order to detain and treat stormwater. A Modular Wetland System will also be placed along streets to provide for additional biofiltration treatment. Project approvals will include: vesting tentative tract map; development and building permits (including, without limitation, grading, mechanical, electrical and plumbing permits); conditional use permits for joint -use parking, on-site alcoholic beverage sales / ancillary live entertainment, and added height for screened mechanical equipment; a concept plan; design review; minor modification for reduction in parking and increased building height; all required approvals by the Regional Water Quality Control Board and the County of Orange Health Department; a Development Agreement; and a Disposition and Development Agreement. An Environmental Analysis Checklist has been completed and it has been determined that the Project is within the scope of the previously approved FEIS/EIR and that- pursuant to Title 14 California Code of Regulations Sections 15162 and 15168(c), no new effects could occur, and no new mitigation measures would be required. Accordingly, no new environmental document is required by CEQA. The following information provides background support for the conclusions identified in the Environmental Analysis Checklist. I. AESTHETICS: — Would the project: a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? c) Substantially degrade the existing visual character or quality of the site and its surroundings? d) Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area? D Evaluation of Environmental Impacts Flight at Tustin Legacy Page 15 No Substantial Change from Previous Analysis. Specifically, the Proposed Project would not cause aesthetic impacts that were not previously analyzed in the FEIS/EIR, Addendums, and Supplement. The Project proposes to permit uses that were previously analyzed in the FEIS/EIR. Therefore, the Project would not change the future development condition that was analyzed in the FEIS/EIR and there would be no change to development intensity, building height restrictions (including allowed minor modifications of 10% pursuant to the terms of the MCAS Tustin Specific Plan), setbacks, signage, and other development standards compared to that analyzed in the FEIS/EIR, and the Project will comply with all requirements of the MCAS Specific Plan governing project design. There are no new or increased significant adverse project -specific or cumulative impacts with regard to aesthetics and visual quality that would occur as a result of the implementation of the Project. The minor modification and conditional use permit to allow additional building height and mechanical equipment represent de minimis changes that would not be visible from off-site public locations and, additionally, mechanical screening would be screened to further ensure there are no adverse visual impacts. There is no new information relative to aesthetics and visual quality that was not ,in rexistence at the time the FEIS/EIR was prepared. Therefore, the Proposed Project and is implementation are consistent with the FEIS/EIR. No new mitigation measures are required in relation to impacts to aesthetics and visual quality. The implementation of the Project would continue the visual change from the abandoned military facilities onsite to residential, commercial, industrial and institutional uses and development. This visual change, as part of the overall visual change of the former base to the larger Tustin Legacy development was not a significant impact in the FEIS/EIR. There are no designated scenic vistas in the Project area; therefore, the Project would not result in a substantial adverse effect on a scenic vista. The Project Site is also not located within the vicinity of a designated state scenic highway. The Project would not change the conclusions of the historical analysis. of the historic blimp hangars from the FEIS/EIR relative to visual changes since the Proposed Project would not affect these hangars. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to aesthetics. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR were certified as complete. Mitigation/Monitoring Required. No new impacts or substantially more severe aesthetic impacts would result from the adoption and implementation of the Project; therefore, no new or revised mitigation measures are required for aesthetics and visual quality. No refinements related to the Project are necessary to the FEIS/EIR mitigation measures Evaluation of Environmental Impacts Flight at Tustin Legacy Page 16 and no new mitigation measures are required. Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: Field Observations Submitted Plans FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-58 through 3-67, 4-81 through 4-92), Addendum 1 (Page 5-3 through 5-7), and Addendum 2 (Page 24 through 26) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan II. AGRICULTURE RESOURCES: In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project: a) Convert /Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b) Conflict with existing zoning for agricultural use or a Williamson Act contract? c) .Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. There were no agricultural uses on the Site in the recent past. There are currently no agricultural uses on the Site. The Proposed Project would not cause impacts to agriculture and forest resources that were not previously analyzed in the FEIS/EIR, Addendums, and Supplement. There are no new or increased significant adverse project -specific or cumulative impacts with regard to agricultural resources that are identified as a result of the adoption and implementation of the Project. The impacts of the implementation of the Specific Plan are already analyzed in the FEIS/EIR. There is no new information relative to agricultural resources that was not in existence at the time the FEIS/EIR was prepared. As a result, no new mitigation measures are required in relation to impacts to agricultural resources. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with Evaluation of Environmental Impacts Flight at Tustin Legacy Page 17 regard to agricultural resources. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required. In certifying the FEIS/EIR, the Tustin City Council adopted Findings of Fact and Statement of Overriding Considerations on January 16, 2001 concluding that impacts to agricultural resources on other areas of MCAS Tustin were unavoidable (Resolution No. 00-90). No mitigation is required. Sources: Field Observations FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-83 through 3-87, 4-109 through 114), Addendum 1 (Page 5-8 through 5-9), and Addendum 2 (Page 27 through 28) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan Farmland Mapping and Monitoring Program III. AIR QUALITY: Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct implementation of the applicable air quality plan? b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard (including releasing emissions that exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial pollutant concentrations? e) Create objectionable odors affecting a substantial number of people? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. i Evaluation of Environmental Impacts Flight at Tustin Legacy Page 18 The Proposed Project would not cause impacts to air quality that were not previously analyzed in the FEIS/EIR, Addendums, and Supplement. There would be no change to the allowed development intensity, building height restrictions, setbacks, signage, other development standards or vehicle trips that would lead to increased air emissions from vehicle trips. An access analysis prepared for the project confirms that the Proposed Project would generate fewer trips than the maximum allowed within Neighborhood E of the MCAS Specific Plan and that were described and analyzed in Addendum 1. There are no new or increased significant adverse project -specific or cumulative impacts with regard to air quality that would occur as a result of the adoption and implementation of the Project that were not previously analyzed in the FEIS/EIR. There is no new information relative to air quality that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with and previously analyzed in the FEIS/EIR, Addendums, and Supplement. As a result, no new mitigation measures are required in relation to impacts to air quality. The Tustin City Council adopted Findings and a Statement of Overriding Considerations for the FEIS/EIR on January 16, 2001 to address significant unavoidable short-term (construction), long-term (operational), and cumulative air quality impacts for the Specific Plan. The City also adopted mitigation measures to reduce these unavoidable adverse impacts. Consistent with the findings in the FEIS/EIR, implementation of future development on the Project Site could result in significant unavoidable short-term construction air quality impacts because it is part of the "project' analyzed in the FEIS/EIR for which this finding was made. Construction activities associated with the Project Site were previously addressed in the FEIS/EIR. There is no substantial new information that shows there will be different or more significant short-term air quality impacts on the environment from the Project than described in the FEIS/EIR. There is no substantial new information that shows there will be different or more significant long-term and/or cumulative impacts on the environment as a result of the Project than described in the FEIS/EIR. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to air quality. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required. Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. However, the FEIS/EIR, Addendums, Evaluation of Environmental Impacts Flight at Tustin Legacy Page 19 and Supplement also concluded that Specific Plan related operational air quality impacts were significant and impossible to fully mitigate. A Statement of Overriding Consideration for the FEIS/EIR was adopted by the Tustin City Council on January 16, 2001. Sources: Field Observations FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-143 through 3-153, 4-207 through 4-230, 7-41 through 7-42), Addendum 1 (Page 5-10 through 5-28), and Addendum 2 (Page 27 through 32) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan IV. BIOLOGICAL RESOURCES: - Would the project: a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? s e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional or state habitat conservation plan? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The Proposed Project would not cause impacts to biological resources that were not previously analyzed in the FEIS/EIR, Addendums, and Supplement. The Project proposes to develop the same areas as proposed in the Specific Plan and previously Evaluation of Environmental Impacts Flight at Tustin Legacy Page 20 analyzed in the FEIS/EIR. There are no new or increased significant adverse project - specific or cumulative impacts with regard to biological resources that would occur as a result of the adoption and implementation of the Project. There is no new information relative to biological resources that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts on biological resources. Based on : current delineations of wetlands and jurisdictional waters, the Project will not affect wetlands or jurisdictional waters. The impacts resulting from the implementation of the Project, if any, would be those identified in the FEIS/EIR. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to biological resources. Specifically, there have not been: (1) changes to the Project that `require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required. No mitigation is required. Sources: Field Observations FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-75 through 3-82, 4-103 through 4-108, 7-26 through 7-27), Addendum 1 (Page 5-28 through 5-39), and Addendum 2 (Page 33 through 35) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan V. CULTURAL RESOURCES: - Would the project: a) Cause a substantial adverse change in the significance of a historical resource as defined in §15064.5? b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5? c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? d) Disturb any human remains, including those interred outside formal cemeteries? Evaluation of Environmental Impacts, Flight at Tustin Legacy Page 21 No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development allowed by the MCAS Tustin Specific Plan. The Proposed Project would not cause impacts to cultural resources that were not previously analyzed in the FEIS/EIR, Addendums, and Supplement. The Project proposes to develop the same areas as proposed in the Specific Plan and previously analyzed in the FEIS/EIR. The impacts of the Specific Plan on cultural resources, including any that may be present on the Project Site, were considered in the FEIS/EIR. It is possible that previously unidentified buried archeological or paleontological resources within the Project Site could be discovered during grading and other construction activities. Consequently, future development is required to perform construction monitoring for cultural and paleontological resources to reduce potential impacts to these resources to a level of insignificance as found in the FEIS/EIR. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to cultural and paleontological resources. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: Field Observations FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-68 through 3-74, 4-93 through 4-102, 7-24 through 7-26), Addendum 1 (Page 5-40 through 5-45), and Addendum 2 (Page 36 through 37) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 22 VI. GEOLOGY AND SOILS: — Would the project: a) Expose people or structures -to potential substantial adverse effects, including the risk of loss, injury, or death involving: • Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning map, issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. Strong seismic ground shaking? Seismic -related ground failure, including liquefaction? Landslides? b) Result in substantial soil erosion or the loss of topsoil? c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on -or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? No Substantia/ Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. Implementation of the Project would not cause any direct impacts to geology and soils. The Project proposes to develop the same areas as proposed in the Specific Plan and previously analyzed in the FEIS/EIR, Addendums, and Supplement. There are no new or increased significant adverse project -specific or cumulative impacts with regard to geology and soils that are identified as a result of the adoption and implementation of the Project. There is no new information relative to geology and soils that was not in existence at the time the FEIS/EIR as prepared. Therefore, the Proposed Project and its implementation are consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts to geology and soils. The FEIS/EIR found that impacts to soils and geology resulting from implementation of the Specific Plan would include non -seismic hazards (such as local settlement, regional Evaluation of Environmental Impacts Flight at Tustin Legacy Page 23 subsidence, expansive soils, slope instability, erosion, and mudflows) and seismic hazards (such as surface fault displacement, high-intensity ground shaking, ground failure and lurching, seismically induced settlement, and flooding associated with dam failure). The FEIS/EIR concluded that compliance with state and local regulations and standards, along with established engineering procedures and techniques, would avoid unacceptable risk or the creation of significant impacts related to geotechnical issues. No substantial change is expected during implementation of the Project from the analysis previously completed in the certified FEIS/EIR. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental ER or other environmental document to evaluate Project impacts or mitigation measures exist with regard to geology and soils. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required. Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources:. Field Observations Submitted Plans and Studies FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-88 through 3-97, 4-115 through 4-123, 7-28 through 7-29), Addendum 1 (Page 5-46 through 5-49), and Addendum 2 (Page 38 through 40) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan VII. HAZARDS AND HAZARDOUS MATERIALS: — Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonable foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Evaluation of Environmental Impacts Flight at Tustin Legacy Page 24 d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles or a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? h) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The entire MCAS Tustin site was reviewed for hazardous materials prior to start of redevelopment activities. Federal regulations require the Navy to complete remediation of hazardous materials prior to conveyance of properties to other landowners. The FEIS/EIR included a detailed discussion of the historic and then -current hazardous material use and hazardous waste generation within the Specific Plan area. The Navy is responsible for planning and executing environmental restoration programs in response to releases of hazardous substances for MCAS Tustin. The FEIS/EIR concluded that the implementation of the Specific Plan would not have a significant environmental impact from the hazardous wastes, substances, and materials on the property during construction or operation since the Navy would implement various remedial actions pursuant to the Compliance Programs that would remove, manage, or isolate potentially hazardous substances in soils and groundwater. As identified in the FEIS/EIR, the Project Site is within the boundaries of the Airport Environs Land Use Plan (AELUP) and is subject to height restrictions. The Proposed Project does not propose changes to (or exceedances of) the maximum 100 -foot height limitation included in the Specific Plan. The Project Site is not located in a wildland fire hazard area. Implementation of the Project will not cause any direct impacts to hazards and hazardous materials. There are no new or increased significant adverse project -specific or cumulative impacts with regards to hazards and hazardous materials that are identified as a result of the adoption and implementation of the Project. There is no new information relative to hazards and hazardous materials that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are Evaluation of Environmental Impacts Flight at Tustin Legacy Page 25 consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts from hazards and hazardous materials. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to hazards and hazardous materials. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: No mitigation is required. Sources: Field Observation FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-106 through 3-117, 4-130 through 4-138, 7-30 through 7-31), Addendum 1 (Page 5-49 through 5-55), and Addendum 2 (Page 44 through 47) MCAS Tustin Specific Plan/Reuse Plan Finding of Suitability to Transfer (FOST) for Southern Parcels 4-8, 10-2, 14, and 42, and Parcels 25, 26, 30-33, 37 and Portion of 40 and 41 Finding of Suitability to Lease (FOSL) for Southern Parcels Care -out Areas 1, 2, 3, and 4 Airport Environs Land Use Plan (AELUP) Tustin General Plan VIII. HYDROLOGY AND WATER QUALITY: - Would the project: a) Violate any water quality standards or waste discharge requirements? b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge, such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre- existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in flooding on- or off-site? d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase Evaluation of Environmental Impacts Flight at Tustin Legacy Page 26 the rate or amount of surface runoff in a manner, which would result in flooding on- or off-site? e) Create or contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff? f) Otherwise substantially degrade water quality? g) Place housing within a 100 -year flood hazard area as mapped on a federal Flood hazard Boundary of Flood Insurance Rate Map or other flood hazard delineation map? h) Place within a 100 -year flood hazard area structures, which would impede or redirect flood flows? i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? j) Inundation by seiche, tsunami, or mudflow? k) Potentially impact stormwater runoff from construction activities? 1) Potentially impact stormwater runoff from post -construction activities? m) Result in a potential for discharge of stormwater pollutants from areas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, -hazardous materials handling or storage, delivery areas, loading docks or other outdoor work areas? n) Result in a potential for discharge of stormwater to affect the beneficial uses of the receiving waters? o) Create the potential for significant changes in the flow velocity or volume of stormwater runoff to cause environmental harm? p) Create significant increases in erosion of the project site or surrounding areas? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The Proposed Project would not cause impacts to hydrology and water quality. There would be no change to development intensity, building height restrictions (including minor height modifications of .10% and 10% reduction in parking allowed by the MCAS Evaluation of Environmental Impacts Flight at Tustin Legacy Page 27 Tustin Specific Plan), setbacks, signage, and other development standards. There are no new or increased significant adverse project -specific or cumulative impacts with regard to hydrology/water quality that are identified as a result of the adoption and implementation of the Project. There is no new information relative to hydrology/water quality that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts to hydrology/water quality. As concluded in the FEIS/EIR, preparation of a Water Quality Management Plan (WQMP) for future development projects on the Project sites in compliance with all applicable regulatory standards would reduce water quality impacts from development activities to a level of insignificance. The Project has prepared such a WQMP. Therefore, the Project would not result in new or substantially more severe impacts to water quality than what was previously identified in the FEIS/EIR. No increase in development intensity is proposed as part of the Project. Future development will be required to comply with Specific Plan development standards, including FAR and landscaping and would require preparation of a WQMP. The Proposed Project would not result in an increase of impervious surface area from the amount that was previously analyzed in the Specific Plan. The Project proposes no change to the drainage pattern and water management systems previously analyzed in the FEIS/EIR. The drainage pattern and water management systems in the` Project Site vicinity would remain consistent with the Tustin Legacy Master Drainage Plan. Therefore, the analysis and conclusions in the FEIS/EIR relative to impacts related to groundwater supply, groundwater levels, or local recharge have not changed. In addition, no change to the backbone drainage system is proposed. Therefore, no new or more severe impacts related to drainage patterns, drainage facilities, and, potential flooding would result from the Project. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to hydrology and water quality. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: Field Observations Submitted Plans FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-98 through Evaluation of Environmental Impacts Flight at Tustin Legacy Page 28 3-105, 4-124 through 4-129,. 7-29 through 7-30), Addendum 1 (Page 5-56 through 5-91), and Addendum 2 (Page 48 through 51) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan IX. LAND USE AND PLANNING: Would the project: a) Physically divide an established community? b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited, to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c) Conflict with any applicable habitat conservation plan or natural community conservation plan? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The Proposed Project would not cause impacts to land use and planning. There would be no change to development intensity, building height restrictions (including minor height modifications of 10% and 10% reduction in parking allowed by the MCAS Tustin Specific Plan), setbacks, signage, and other development standards. There are no new or increased significant adverse project -specific or cumulative impacts with regard to land use and planning that are identified as a result of the adoption and implementation of the Project. There is no new information relative to land use and planning that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts to land use planning. Implementation of the Project would not physically divide any Specific Plan land use, conflict with the Specific Plan, or conflict with any habitat conservation plan or natural community conservation plan. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to land use and planning. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation Evaluation of Environmental Impacts Flight at Tustin Legacy Page 29 measures or alternatives that was not known and could not have been known when the FEIS/EIR were certified as complete. Mitigation/Monitoring Required. Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-3 through 3-17, 4-3 through 4-13, 7-16 through 7-18), Addendum 1 (Page 5-92 through 5-94), and Addendum 2 (Page 52 through 54) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan X. MINERAL RESOURCES: Would the project: a) Result in the loss of availability of a known mineral resource that would be a value to the region and the residents of the state? b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. There are no known mineral resources located at the site. The Project would not cause new impacts to mineral resources that were not previously analyzed in the FEIS/EIR, Addendums, and Supplement. There are no new or increased significant adverse project -specific or cumulative impacts with regard to mineral resources that are identified as a result of the adoption and implementation of the Project. There is no new information relative to mineral resources that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts to mineral resources. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to mineral resources. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation Evaluation of Environmental Impacts Flight at Tustin Legacy Page 30 measures or alternatives that was not known and could not have been known when the FEIS/EIR were certified as complete. Mitigation/Monitoring Required. No mitigation is required. Sources: Field Observation FEIS/EIR for Disposal . and Reuse of MCAS Tustin (Page 3-91), Addendum 1 (Page 5-95), and Addendum 2 (Page 55) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan XI. NOISE: Would the project: a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b) Exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels? c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project?, e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? f) For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The ambient noise environment on the site is influenced by the surrounding roadways, existing uses, and aircraft noise from flight operations at John Wayne Airport. However, none of these exterior noise sources would impact the project beyond levels analyzed and described by the FEIR/EIS, and the project would be able to achieve the interior noise standards set forth in Section 5.507.4 of the California Green Building Standards Code. Implementation of the Project will not cause any direct impacts to noise. There would be no change to development intensity, traffic generation building height restrictions Evaluation of Environmental Impacts Flight at Tustin Legacy Page 31 (including minor height modifications of less than 10% allowed by the MCAs Tustin Specific Plan), setbacks, signage, and other development standards. No new or increased significant adverse project -specific or cumulative impacts with regard to noise are identified as a result of the approval and implementation of the Project. There is no new information relative to noise that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Proposed Project and its implementation are consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts to noise. The Project would not modify the noise -related land use distribution within the Tustin Legacy site. All proposed land uses were included in the Specific Plan. Consequently, long-term traffic -related noise impacts associated with implementation of the Project have previously been identified and analyzed in the FEIS/EIR. Short-term noise impacts were also analyzed in the previously certified FEIS/EIR; implementation of any future project would be required to comply with applicable adopted mitigation measures and state and local regulations and standards, along with established engineering procedures and techniques, thus avoiding significant short-term construction -related noise impacts. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to noise. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the. Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR were certified as complete. Mitigation/Monitoring Required. Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: Field Observation Submitted Plans and Studies FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-154 through 3-162 and 4-231 through 4-243), Addendum 1 (Page 5-96 through 5-101), and Addendum 2 (Page 57 through 60) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 32 XII. POPULATION & HOUSING: Would the project: a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The Proposed Project would not cause impacts to housing and any associated population. There is no new information relative to population and housing that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Proposed Project and its implementation are consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts to population and housing. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to population and housing. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required. No mitigation is required. Sources: FEIS/EIR for. Disposal and Reuse of MCAS Tustin (Page 3-18 through 3-34, 4-14 through 4-29, and 7-18 through 7-19), Addendum 1 (Page 5-101 through 5-111), and Addendum 2 (Page 61 through 62) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 33 XIII. PUBLIC SERVICES: a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services: No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The Proposed Project would not cause impacts to public services. There would be no change to the permitted levels of development intensity, which would lead to an increased demand for public services. There are no new or increased significant adverse project -specific or cumulative impacts with regard to public services and facilities that are identified as a result of the adoption and implementation of the Project. There is no new information relative to public services and facilities that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts to public services and facilities. Fire Protection Fire protection for the Tustin Legacy Site was discussed and analyzed in the FEIS/EIR. The Project results in no changes to that previous analysis, and no increased or new environmental effects on the environment from those previously analyzed in the FEIS/EIR. The Project will be subject to OCFA regulations regarding construction materials and methods, emergency access, water mains, fire flow, fire hydrants, sprinkler systems, building setbacks, and other relevant regulations. Adherence to these regulations will reduce the risk of uncontrollable fire and increase the ability to efficiently provide fire protection services to the Site. Pursuant to the FEIS/EIR, the existing fire stations in the Project vicinity with additional firefighting personnel and equipment will meet the demands created by the Project and other development within Tustin Legacy. No new or expanded facilities were identified as being required and therefore no physical impacts were identified. Police Protection Police protection for the project site was discussed and analyzed in the FEIS/EIR. The Project results in no changes to that previous analysis, and no increased or new environmental effects on the environment from those previously analyzed in the FEIS/EIR. Implementation of the Project would not increase the need for police protection services in addition to what was previously anticipated in the FEIS/EIR. Evaluation of Environmental Impacts Flight at Tustin Legacy Page 34 Schools The Project will not directly result in any residential development. Therefore, the Project does not generate K-12 students and there is no impact to K-12 schools. Parks Parks for the project site were discussed and analyzed in the FEIS/EIR. The Project results in no changes to that previous analysis, and no increased or new environmental effects on the environment from those previously analyzed in the FEIS/EIR. Other Public Facilities The FEIS/EIR concluded that public facilities would be provided according to a phasing plan to meet projected needs as development of the Specific Plan proceeded. The FEIS/EIR does identify that the City will require certain conditions for individual future development projects (identified as Implementation Measures on pages 4-67 through 4-70) to be complied with as appropriate. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to recreation. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required. Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-47 through 3-57, 4-56 through 4-80 and 7-21 through 7-22), Addendum 1 (Page 5-112 through 5-122), and Addendum 2 (Page 63 through 65) MCAS Tustin Specific Plan/Reuse Plan Tustin General Plan XIV. RECREATION: a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities, such that substantial physical deterioration of the facility would occur or be accelerated? Evaluation of Environmental Impacts Flight at Tustin Legacy Page 35 b) Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The Project will be adjacent to the Linear Park and will facilitate access to the Park by tenants of the mixed-use commercial development, consistent _with the levels anticipated by the previously certified FEIR / EIS. The Proposed Project would not result in an increase of development intensity or change in uses that would result in increased use of existing parks or recreational facilities. There are no new or increased significant adverse project -specific or cumulative impacts with regard to recreation that are identified as a result of the implementation of the Project. There is no new information relative to recreation that was not in existence at the time the FEIS/EIR, Addendums, and Supplement was prepared. As a result, no new mitigation measures are required in relation to impacts to recreation. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to recreation. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required. Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: Field Observation FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-47 through 3-57, 4-56 through 4-80, 7-21 through 7-22), Addendum 1 (Page 5-122 through 5-127), and Addendum 2 (Page 66 through 67) MCAS Tustin Specific Plan/Reuse Plan Tustin City Code Section 9331 d (1)(b) Tustin General Plan 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 36 XV. TRANSPORTATION/TRAFFIC: Would the project: a) Cause an increase in traffic, which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? b) Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways? c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? f) Result in inadequate parking capacity? g) Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The Proposed Project would not result in an increase of development intensity or change in uses, building height restrictions (including minor height modifications of 10% and 10% reduction in parking allowed by the MCAS Tustin Specific Plan), setbacks, signage, and other development standards. More specifically, the MCAS Specific Plan allocates 1,267,324 square feet of non-residential development to Planning Areas 9-12 (Neighborhood E), and allocates a unified trip budget to Neighborhood E of 17,516 average daily trips (ADT). These allowable development square footages and neighborhood trip budgets were previously analyzed in the MCAS Specific Plan Final EIR/EIS and the First Addendum thereto. The 870,000 sf Project is located entirely within Neighborhood E and would utilize only approximately 68% of the developable square footage in Neighborhood E under the MCAS Specific Plan, and would utilize just more than half of the developable area in Neighborhood E under the proposed MCAS Specific Plan Amendment. As documented in an access analysis independently reviewed and approved by the City, the Project would generate 9,484 ADTs, which is less than half of the Neighborhood E Trip Budget under the MCAS Specific Plan. Therefore, the Project is less intense, generates fewer trips, and (as explained further below) would have less effect on the circulation network Evaluation of Environmental Impacts Flight at Tustin Legacy Page 37 than initially described and analyzed in the Final EIR/EIS and the First Addendum thereto. In short, there are no changes to the land use intensity or density and resulting trip generation. There are no new or increased significant adverse project -specific or cumulative impacts with regard to transportation and traffic that are identified as a result of the adoption and implementation of the Project that were not previously analyzed in the FEIR/EIS, Addendums, and Supplement. Based on this analysis, there are no new or increased significant adverse project - specific or cumulative impacts with regard to traffic and transportation that are identified as a result of the adoption and implementation of the Project. There is no new information relative to traffic and transportation that was not in existence at the time the FEIS/EIR was prepared. As a result, no new mitigation measures are required in relation to impacts to traffic and transportation. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to recreation. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: Specific mitigation measures were adopted by the Tustin City Council in certifying the FEIS/EIR, Addendums, and Supplement. However, the FEIS/EIR, Addendums, and Supplement, also concluded that Specific Plan related traffic impacts were significant and impossible to fully mitigate. A Statement of Overriding Consideration for the FEIS/EIR, Addendums, and Supplement, was adopted by the Tustin City Council on January 16, 2001. Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: Field Observations Submitted Plans and Studies FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-118 through 3-142, 4-139 through 4-206 and 7-32 through 7-42), Addendum 1 (Page 5-127 through 5-146), and Addendum 2 (Page 68 through 73) MCAS Tustin Specific Plan/Reuse Plan (Page 3-35 . through 3-62, Page 3-70 through 3-81, Page 3-82 through 3-88, and Page 3-104 through 3-137) Tustin General Plan Evaluation of Environmental Impacts Flight at Tustin Legacy Page 38 XVI. UTILITIES AND SERVICE SYSTEMS: Would the project: a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? d) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? e) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? f) Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments? g) Be served by a landfill with sufficient permitted capacity to accommodate the project's solid waste disposal needs? h) Comply with federal, state, and local statutes and regulations related to solid waste? i) Would the project include a new or retrofitted storm water treatment control Best Management Practice (BMP), (e.g. water quality treatment basin, constructed treatment wetlands), the operation of which could result in significant environmental effects (e.g. increased vectors and odors)? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The Proposed Project would not result in an increase of development intensity or change in uses cause any direct impacts to utilities and service systems. There are no new or increased significant adverse project -specific or cumulative impacts with regard to utilities/services systems that are identified as a result of the adoption and implementation of the Project. There is no new information relative to utilities and service systems that was not in existence at the time the FEIS/EIR was prepared. Therefore, the Project and its implementation are consistent with the FEIS/EIR. As a result, no new mitigation measures are required in relation to impacts to utilities and service systems. 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 39 The FEIS/EIR identifies that the City will require certain conditions for future individual development projects identified as "Mitigation" or "Implementation Measures" (pages 4-43 through 4-46) to be complied with as appropriate. Based on the foregoing, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent or supplemental EIR or other environmental document to evaluate Project impacts or mitigation measures exist with regard to utilities and service systems. Specifically, there ,have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: Field Observations Submitted Plans and Studies FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 3-35 through 3-46, 4-32 through 4-55 and 7-20 through 7-21), Addendum 1 (Page 5-147 through 5-165), and Addendum 2 (Page 74 through 76) MCAS Tustin Specific Plan/Reuse Plan (Page 3-35 through 3-62, Page 3-70 through 3-81, Page 3-82 through 3-88, and Page 3-104 through 3-137) Tustin General Plan XVII. MANDATORY FINDINGS OF SIGNIFICANCE: a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b) Does the project have impacts that are individually limited but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 40 c) Does the project have environmental effects, which will cause substantial adverse effects on human beings, either directly or indirectly? No Substantial Change from Previous Analysis. The Project would allow site-specific development of a commercial mixed-use project permitted within Neighborhood E of the MCAS Specific Plan. The Project would not increase the overall development potential allowed by the MCAS Tustin Specific Plan. The Proposed Project would not change development intensity, building height restrictions (including minor height modifications of 10% and 10% reduction in parking allowed by the MCAs Tustin Specific Plan), setbacks, signage, and other development standards. The FEIS/EIR previously considered all environmental impacts associated with the implementation of the Specific Plan, including mandatory findings of significance associated with the implementationof the Project. The Project would not cause unmitigated environmental effects that were not already examined in the 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 were identified, nor would any project -specific or cumulative impacts in any environmental areas be made worse as a result of the Project. All feasible applicable mitigation measures identified in the FEIS/EIR are incorporated into the Project approvals. Further, none of the conditions identified in CEQA Guidelines Section 15162 that would trigger the need to prepare a subsequent EIR to evaluate Project impacts or mitigation measures exist with regard to environmental impacts. Specifically, there have not been: (1) changes to the Project that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; (2) substantial changes with respect to the circumstances under which the Project is undertaken that require major revisions of the previous FEIS/EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or (3) the availability of new information of substantial importance relating to significant effect or mitigation measures or alternatives that was not known and could not have been known when the FEIS/EIR was certified as complete. Mitigation/Monitoring Required: Mitigation measures were adopted by the Tustin City Council in the FEIS/EIR, Addendums and Supplement; applicable measures are included as conditions of entitlement approvals. Sources: Field Observations Submitted Plans and Studies FEIS/EIR for Disposal and Reuse of MCAS Tustin (Page 5-4 through 5-11) MCAS Tustin Specific Plan/Reuse Plan (Page 3-35 through 3-62, Page 3-70 through 3-81, Page 3-82 through 3-88, and Page 3-104 through 3-137) Tustin General Plan, 1 Evaluation of Environmental Impacts Flight at Tustin Legacy Page 41 CONCLUSION The above analysis concludes that all of the proposed project's effects were previously examined in the FEIS/EIR, Supplement, and Addendums, that no new effects would occur, that no substantial increase in the severity of previously identified significant effects would occur, that no new mitigation measures would be required, that no applicable mitigation measures previously not found to be feasible would in fact be feasible, and that there are no new mitigation measures or alternatives applicable to the project that would substantially reduce effects of the project that have not been considered and adopted. A Mitigation and Monitoring and Reporting Program and Findings of Overriding Considerations were adopted for the FEIS/EIR on January 16, 2001, and shall apply to the Project, as applicable. 102061824.4.DOC 1 1