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HomeMy WebLinkAboutPC RES 3910 RESOLUTION NO. 3910 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF TUSTIN, CALIFORNIA, RECOMMENDING THE CITY COUNCIL CERTIFY THE PROSPECT VILLAGE FINAL ENVIRONMENTAL IMPACT REPORT AS COMPLETE AND ADEQUATE PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT FOR ZONE CHANGE 03-002 AND TENTATIVE TRACT MAP 16481 AND CERTIFYING THE PROSPECT VILLAGE FINAL ENVIRONMENTAL IMPACT REPORT AS COMPLETE AND ADEQUATE PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT FOR DESIGN REVIEW 03-012, CONDITIONAL USE PERMIT 03-012, AND FINDING THE DISPOSITION OF PROPERTY OWNED BY THE TUSTIN REDEVELOPMENT AGENCY IN CONFORMANCE WITH THE GENERAL 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 for Zone Change 03-002, Tentative Tract Map 16481, Design Review 03-012, Conditional Use Permit 03-012, was submitted by Prospect Village LP, a California Limited Partnership (formerly known as Pelican Center LLC), requesting approval to subdivide a 1.036 acre parcel into thirteen (13) numbered lots and one (1) lettered lot for the purpose of developing an approximately 9,300 square foot commercial building and twelve (12) live/work units at the northwest corner of Main Street and Prospect Avenue. In addition, a General Plan Conformity Finding is required for disposition of property owned by the Tustin Community Redevelopment Agency. Together, these entitlements are known as the "project. II B. The Planning Commission is authorized to certify the Prospect Village Final Environmental Impact Report (FEIR) as complete and adequate pursuant to the California Environmental Quality Act for the purpose of approving Design Review 03-012, Conditional Use Permit 03-012, and finding the disposition of property in conformance with the Tustin General Plan. The Planning Commission is authorized to recommend that the City Council certify the Prospect Village Final Environmental Impact Report (FEIR) as complete and adequate pursuant to the California Environmental Quality Act for the purpose of approving Zone Change 03-002 and Tentative Tract Map 16481. Resolution No. 3910 Page 2 C. Pursuant to the California Environmental Quality Act (CEQA) (Calif. Public Resources Code Sec. et. seq. 21000) and the State Guidelines, the City of Tustin has completed the following actions in preparing Prospect Village Final Environmental Impact report (FEIR): D. E. 1. An Initial Study was prepared to determine whether any aspect of the project, either individually or cumulatively, would cause a significant impact on the environment and to narrow the focus or scope of the environmental analysis. 2. On April 17, 2003, a Notice of Preparation was filed with the State Clearinghouse in the Office of Planning and Research, which circulated the document for review. 3. On April 22, 2003, a noticed public scoping meeting was conducted to seek public input regarding the environmental issues raised by the proposed project and the scope of the EIR. 4. On January 9, 2004, a Draft Environmental Impact Report (DEIR) was released for a 45-day public review and comment period. A copy was also filed with the State Clearinghouse. The DEIR assessed the significant environmental impacts and set forth mitigation measures to lessen impacts associated with the project. The comment period on the DEIR closed on February 23,2004. In accordance with Section 15132 of the State CEQA Guidelines, Prospect Village Final Environmental Report consists of the following items, which are attached hereto as Exhibit A, and incorporated herein by this reference: 1. Volume 1 including the Draft EIR, including all appendices and technical reports thereto; and, 2. Volume 2 including a list of persons, agencies and organizations, commenting on Draft EIR; all comments received, responses of the City to significant environmental points raised in received comments; and errata. The FEIR analyzes the potential environmental impacts associated with the project. The FEIR evaluates the proposed project, which includes the rezoning of a 1.036 acre property located at the northwest corner of Main Street and Prospect Avenue from "Central Commercial-Parking Overlay (C2-P) to "Planned-Community (P-C)", subdivision of the property into thirteen (13) numbered lots and one (1) lettered lot, and construction of an approximately 9,300 square foot commercial building and twelve (12) Resolution No. 3910 Page 3 4. 5. live/work units. In addition to a "No Project Alternative", the FEIR also evaluates a range of project alternatives, including the following: 1. Full Reuse Alternative: The Full Reuse Alternative entails rehabilitation and reuse of the existing Utt Juice buildings in accordance with the Secretary's Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings, 1995, Weeks and Grimmer ("Secretary's Standards and Guidelines"). This Alternative also entails new construction of retail building addition on the vacant pad area immediately west of the 191 Main Street building ("191 Building"). The remaining northerly portion of the site would be developed with ten (10) live/work units. 2. Partial Reuse Alternative: This Alternative would rehabilitate and reuse the 191 Building and partially rehabilitate and reuse the 193, 195 Building (to a depth of sixty) in accordance with the Secretary's Standards and Guidelines. This Alternative also entails construction of a new two story building to a depth on the pad area immediately west of the 191 Building. The remaining northerly portion of the site would be developed ten (10) residential live/work units. 3. Partial Reuse (193, 195 Building Only) Alternative: This Alternative would partially rehabilitate and reuse the front forty five feet of the 193, 195 Buildings in accordance with the Secretary's Standards and Guidelines. The 191 Building would be demolished. This Alternative also entails construction of a new two story retail building on the remaining pad area west of the 193, 195 Building. Similar to the proposed project, the remaining northerly portion of the site would be developed with twelve (12) live/work units. Full Reuse (Existing Zoning) Alternative: The Full Reuse Under Existing Zoning Alternative would rehabilitate and reuse the existing structures in accordance with the Secretary's Standards and Guidelines. The alternative also entails construction of a new abutting 2,200 square feet single story retail building on the vacant site immediately west of the 191 Building. The remaining northerly portion of the site would be developed with a two-story retail and professional office building. Façade Reuse Alternative: This alternative entails rehabilitation and reuse of all or a portion of the façade of the 193, 195 Building as may be technically feasible, which would be incorporated into a Resolution No. 3910 Page 4 F. G. new two story Main Street building. All other project components would be similar to the proposed project. A Final Environmental Impact Report (FEIR), including responses to written public comments was prepared and made available for public review on April 16, 2004. On April 26, 2004, public testimony was provided to the Planning Commission on the FEIR. Prior to approving the proposed action, the Planning Commission must certify that the FEIR is complete and adequate; H. Section 21081 of the Public Resources Code and Section 15091 of the State CEQA Guidelines require that the Planning Commission make one or more of the following findings prior to approving or carrying out a project for which an EIR has been prepared identifying one or more significant effects of the project, together with a statement of facts in support of each finding: 1. Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant effects on the environment. 2. Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency. 3. Specific economic, legal, social, technological, or other considerations make infeasible the mitigation measures or alternatives identified in the EIR. I. State Guidelines Section 15093(b) require that, where the decision of the Planning Commission allows the occurrence of significant effects which are identified in an EIR, but are not at least substantially mitigated, the Planning Commission must state in writing the reasons to support its action based on the FEIR or other information in the record; J. State Guidelines Section 15093(a) requires the Planning Commission to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks in determining whether to approve the project; and K. A lead agency that makes findings on significant effects in an EIR must also adopt a program for reporting or monitoring mitigation measures that are made conditions of project approval. V. VI. VII. VIII. Resolution No. 3910 Page 5 II. The Planning Commission of the City of Tustin does hereby find and determine that the Prospect Village FEIR was reviewed and considered by the Planning Commission before considering approval of the Project and that the FEIR reflects its independent judgment and analysis. III. The Planning Commission of the City of Tustin does hereby find that the project involves no potential for any adverse effect, either individually or cumulatively, on wildlife resources and makes a De Minimis Impact Finding related to AB 3158, Chapter 1706, Statutes of 1990. IV. The Planning Commission of the City of Tustin does hereby find that changes have been required in, or incorporated into, the project that will mitigate or avoid potentially significant adverse effects related to hazards, short term construction traffic, and parking identified in the FEIR and that all mitigation measures contained in the FEIR are adopted and included as conditions of approval of the Project. The Planning Commission hereby finds that there will be significant effects which, are identified in an EIR, which will not be substantially mitigated, and sets forth the Findings of Fact, which includes the reasons to support its action based on the FEIR or other information in the record, as attached as Exhibit B, and incorporated herein by this reference; The Planning Commission hereby finds that the unavoidable significant environmental effects of the project related to cultural resources and land use are outweighed by the economic, social, technological, and other benefits of the project, as set forth in the Statement of Overriding Considerations attached as Exhibit B, and incorporated herein by this reference. The Planning Commission of the City of Tustin does hereby adopt a Mitigation Monitoring Reporting Program is set forth in Exhibit C, incorporated herein by this reference, which provides a checklist of mitigation measures identified in the FEIR to monitor the progress of each measure. The following information is identified for each measure listed in the checklist: 1. The text of the measure is provided which contains the criteria for mitigation, either in the form of adherence to certain adopted regulations or identification of the steps to be taken as mitigation. 2. The timing of the implementation of the mitigation measures is indicated. 3. The table lists the appropriate responsible or supervising party or agency to perform or enforce the mitigation measure or implementation measure. The Planning Commission of the City of Tustin does hereby find and certify that the Prospect Village FEIR has been completed in compliance with the requirements of Resolution No. 3910 Page 6 CEQA and the State Guidelines and certifies the Prospect Village Final Environmental Impact Report (FEIR) as complete and adequate pursuant to the California Environmental Quality Act for the purpose of approving Design Review 03-012, Conditional Use Permit 03-012, and a General Plan Conformity Finding for the disposition of property and does hereby recommend that the City Council find the Prospect Village Final Environmental Impact Report (FEIR) complete and adequate pursuant to the California Environmental Quality Act for the purpose of approving Zone Change 03-002 and Tentative Tract Map 16481. a~~ ¿~4 ELIZABETH A. BINSACK Planning Commission Secretary PASSED AND ADOPTED at a regular meeting of the City of Tustin P. held on the 26th day of April, 2004. Resolution No. 3910 Page 7 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. 3910 was duly passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 26th day of April 2004. ~ .ß~-,,/- IZABETH A. BINSACK Planning Commission Secretary EXHIBIT A OF RESOLUTION NO. 3910 PROSPECT VILLAGE FINAL ENVIRONMENTAL IMPACT REPORT SEE VOLUMES 1 AND 2 SEPARATELY BOUND EXHIBIT B OF RESOLUTION NO. 3910 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS Exhibit B of Planning Commission Resolution No. 3910 Findings of Fact and Statement of Overriding Considerations Prospect Village Final Environmental Impact Report Prospect Village Project Zone Change 03-002 Tentative Tract Map 16481 Design Review 03-012 Conditional Use Permit 03-012 General Plan Conformity Finding for Disposition of Property City of Tustin 300 Centennial Way Tustin, CA 92780 Prospect Village FEIR Section TABLE OF CONTENTS I. II. III. IV. V. VI. VII. Pa2e INTRODUCTION 4 THE ADMINISTRATIVE RECORD 4 PURPOSE OF FINDINGS 5 INCORPORA TION OF MITIGATION MEASURES INTO PROJECT DESIGN 6 FINDINGS CONCERNING SIGNIFICANT UNAVOIDABLE ADVERSE IMP ACTS 6 Cultural Resources (Historical Resources) Land Use FINDINGS CONCERNING SIGNIFICANT IMP ACTS THAT ARE REDUCED TO LESS THAN SIGNIFICANT LEVELS BY MITIGATION MEASURES INCORPORATED INTO THE PROJECT 7 Cultural Resources (Archaeological Resources) Hazards Traffic/Parking FINDINGS CONCERNING LESS THAN SIGNIFICANT IMP ACTS 13 Aesthetics Air Quality Hazards Noise Traffic 21 VIII. FINDINGS OF FACT CONCERNING PROJECT AL TERNA TIVES Introduction Reasonable Range of Alternatives Summary of Comparison of Alternatives Project Objectives IX. STATEMENT OF OVERRIDING CONSIDERATIONS Summary of Overriding Considerations Adoption of Overriding Considerations 34 Prospect Village FEIR --------.- TABLES Table Table 1 Table 2 Page Summary Comparison of Land Development and Buildout Characteristics of Alternatives 32 Key Differentiating Factors Between Alternatives 33 Prospect ViJlage FEIR FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS Pursuant to the California Environmental Quality Act (CEQA) Guidelines Section 15091, the City of Tustin Planning Commission based upon its review of the Final Environmental Impact Report (FEIR), including the comments and responses therein, and all the information and evidence in the record, hereby makes the Findings of Fact and adopts of the Statement of Overriding Considerations set forth herein: I. INTRODUCTION In accordance with the requirements of CEQA, an Initial StudylNotice of Preparation (Nap) to prepare an EIR was distributed on April 17, 2003, to regulatory agencies, local jurisdictions, and public service providers, among others, for a 30-day comment period. This Final Environmental Impact Report ("FEIR") evaluates the potential environmental effects of the proposed Prospect Village Project ("Project"), which is located on an approximately one-acre parcel in the City of Tustin, County of Orange. This EIR has been prepared pursuant to the California Environmental Quality Act ("CEQA") (California Public Resources Code Section 21000 et seq.) and State Guidelines for the implementation ofthe CEQA (California Code of Regulations, Title 14, Section 15000 et seq.). The FEIR consists of two volumes entitled "Volume 1, Draft Environmental Impact Report for Prospect Village Project" and "Volume 2, Responses to Public Comments." The FEIR recommends mitigation measures to avoid significant environmental impacts of the project or reduce them to less than significant levels. S)2ecifically, the FEIR identified mitigation measures to avoid or reduce Project impacts relating to unknown archaeological resources, hazards, short term construction traffic and parking impacts to a less than significant level. While feasible mitigation measures are also identified to reduce Project impacts on historical resources, the FEIR concludes that this impact would be significant and unavoidable. The FEIR also concludes that Project impacts relating to Land Use are significant and unavoidable despite implementation the recommended mitigation measure. II. THE ADMINISTRATIVE RECORD CONTENTS OF THE RECORD The following information is incorporated by reference and made part ofthe record supporting these findings and the actions taken by City of Tustin Planning Commission in certifying the FEIR and approving the project: 1. The FEIR, Draft EIR and all documents relied upon or incorporated by reference in the FEIR or Draft EIR. 2. All testimony, documentary evidence and all correspondence submitted to or delivered to the City in connection with the meetings, workshops, and public hearings at which the Draft EIR FEIR was considered by the City. Prospect Village FEIR Page 4 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS 3. Any other documents specified by Public Resources Code Section 21167.6(e). LOCATION OF ADMINISTRATIVE RECORD The City is the custodian ofthe administrative record, including all CEQA documents and the other background documents and materials, which constitute the record of the proceedings upon which City Council decisions to certify the FEIR and approve the project are based. The administrative record is located at the Tustin Community Development Department at the City of Tustin, 300 Centennial Way, Tustin, CA 92780. III. PURPOSE OF FINDINGS The FElR, prepared in accordance with the California Environmental Quality Act (CEQA), evaluates the significant adverse environmental impacts that could result from the project. Section 15091 ofthe CEQA Guidelines requires that the public agency approving or carrying out the project shall make written findings for each significant impact identified in the EIR. These findings include one of the following: 1. Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as defined in the EIR. 2. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project '!.lternatives identified in the final ElR. These findings accomplish the following: 1. They address the significant environmental effects identified in the EIR for the approved project. 2. They incorporate all mitigation measures associated with these significant impacts identified in the ElR. 3. They indicate whether a significant effect is avoided or reduced by the adopted mitigation measures to a less than significant level, or remain significant and unavoidable, either because there are no feasible mitigation measures or because, even with implementation of mitigation measures, a significant impact will occur. The conclusions presented in these findings are based on the FEIR and other substantial evidence in the record of proceedings. Each of the effects that remain potentially significant and unavoidable is considered acceptable by the Planning Commission based on a detennination that the benefits ofthe project outweigh the risks of the potentially significant environmental effect, as set forth in the Statement of Overriding Considerations contained herein. IV. INCORPORATION OF MITIGATION MEASURES INTO PROJECT DESIGN Prospect Village FEIR Page 5 ~~ ~ -~-- FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS The mitigation measures identified in the FEIR as feasible and within the City's responsibility and jurisdiction to implement are hereby incorporated into the design of the project as required by CEQA. The City shall implement these measures during project implementation. V. FINDINGS CONCERNING SIGNIFICANT UNAVOIDABLE ADVERSE IMPACTS The FEIR concludes that the project would result in a significant and unavoidable impact on historical resources and land use. As described below in the findings for the significant and unavoidable impacts, there are either no feasible mitigation measures or the feasible mitigation measures would only partially mitigate the impact and the residual effect would remain significant. As set forth in the Statement of Overriding Considerations herein, the Planning Commission finds that the impacts to cultural resources and land use are acceptable in light of the project's benefits. CUL TURAL RESOURCES (FEIR SECTION 3.3) IMPACT: SUBSTANTIAL AD VERSE CHANGE IN THE SIGNIFICANCE OF A HISTORICAL RESOURCE AS DEFINED IN §15064.5 1. Facts The Project entails demolition oftwo buildings on-site that were determined to be eligible for listing in the California Register of Historical Resources. As discussed in Section 3.3. ofthe Draft EIR, the Historic Resources Technical Report, Utt Juice Redevelopment Project, dated July 14, 2003 concluded that the 193, 195 E. Main Street Building is a resource of regional significance under California Register of Historic Resources Criteria 1 (association with significant events or trends), 2 (association with historically important people); and 3 (embodying distinctive characteristics of a type of construction method). The report also concluded that the 191 E. Main Building is a resource of local significance under California Register of Historic Resources Criteria 1 (association with significant events or trends), and 2 (association with historically important people). Therefore, the proposed demolition of these buildings is considered a significant environmental impact under CEQA. This impact can be reduced, but not to a level of insignificance, by adopting a mitigation measure that requires documentation ofthe buildings to be removed shall be undertaken by the City of Tustin utilizing the standards of the Historic American Building Survey (HABS), including photo- documentation and measured drawings of the East Main and Prospect Avenue elevations. These items, together with the Historical Resource Technical Report, shall be added to the Tustin Area Historical Society Museum. See Mitigation Measure CR-l on p. 3.3-10 ofthe Draft EIR. 2. Finding This Planning Commission finds this impact to be significant and unavoidable; the measure listed above is adopted and will reduce this impact but not to a level of insignificance. This impact is overridden by project benefits as set forth in the statement of overriding considerations. Prospect Village FEIR Page 6 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS LAND USE (SECTION 3.5) IMPACT: THE PROJECT IS INCONSISTENT WITH THE GENERAL PLAN POLICIES THAT PROMOTE PRESERVATION AND REHABILITATION OF HISTORIC RESOURCES 1. Facts While the Project is consistent with the majority ofthe General Plan goals, objectives and policies relating to development ofthe Old Town, the Project is inconsistent with three policies that promote restoration and preservation of historically significant structures. The following policies are described in the Land Use Element ofthe General Plan and are designed to avoid and minimize a project's potentially significant impacts on historical resources: . Policy 5.3 - Encourage the rehabilitation of existing commercial facades and signage. Policy 5.5 - Encourage the restoration and rehabilitation of properties eligible for inclusion on the National Register of Historic Places according to the rehabilitation guidelines and tax incentives of the National Trust for Historic Preservation. Policy 6.5 - Preserve historically significant structures and sites, and encourage the conservation and rehabilitation of older buildings, sites and neighborhoods that contribute to the City's historic character. . . The Project will demolish the historic Utt Juice Buildings. Therefore, contrary to the above policies, the Project does not entail restoration, rehabilitation or preservation of these historical resources. The mitigation measures CR-I is intended to reduce Project impacts on these historical resources. However, this mitigation measure will not reduce the impact to a less than significant level. For purposes of the above policies, only restoration, rehabilitation or preservation would reduce Project impacts to a less than significant level. Therefore, similar to the Project cultural resources impacts, the Project's inconsistency with these General Plan policies, which have been adopted to avoid and minimize Project impacts on historical resources, is considered significant and unavoidable. Finding: This Planning Commission finds this impact to be significant and unavoidable; the measure listed above is adopted and will reduce this impact but not to a level of insignificance. This impact is overridden by project benefits as set forth in the statement of overriding considerations. VI. FINDINGS CONCERNING SIGNIFICANT IMPACTS THAT ARE REDUCED TO A LESS THAN SIGNIFICANT LEVEL BY MITIGATION MEASURES INCORPORATED INTO THE PROJECT CUL TURAL RESOURCES (FEIR SECTION 3.3 IMPACT: DISTURBANCE OF UNKNOWN BURIED CULTURAL RESOURCES ON SITE. Prospect ViIJage FEIR Page 7 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA nONS 1. Facts Because the project site has been previously disturbed due to excavation, grading, paving and construction of buildings, the probability of archaeological resources, paleontological resources, or Native American remains being present is considered low. Nonetheless and to ensure that no previously undocumented or unknown buried cultural resources on site will be adversely affected by the project, the Draft EIR recommends Mitigation Measure CR-2, which provides a mechanism whereby construction work would be halted if buried cultural resources are discovered. The measure further requires an archaeologist to assess the find and develop appropriate mitigation measures to ensure the find is not damaged. 2. Finding The Planning Commission finds that Mitigation Measure CR-2 is adopted as stated in paragraph IV of the certification resolution. This measure will reduce Project impacts to unknown buried cultural resources to a less than significant level. HAZARDS (SECTION 3.4.1 OF FEIR) IMPACT: DISPOSAL AND REMOVAL OF ASBESTOS CONTAINING MATERIALS, LEAD BASED PAINT, AND EXISTING INOPERABLE CLARIFIER 1. Facts a. As discussed in Section 3.4, pages 3.4-5 through 3.4-7 of the Draft EIR, the Phase I Environmental Site Assessment revealed no evidence of recognized environmental conditions in connection with the property, except for the presence of a clarifier on-site, the presence of asbestos containing material (ACM), and lead based paint (LBP) which is typical of older structures. The Phase I Report could not determine from the available information whether the clarifier has been officially closed or abandoned. Information concerning the past use and current status of the clarifier was similarly not available. In order to reduce the potential for an unauthorized discharge and depending on the future use of the Property, the Draft EIR recommends Mitigation Measure H -1, which requires the applicant to abandon or remove the clarifier in accordance with applicable local, State, and Federal regulations. The Draft EIR also recommends as a precautionary measures, Mitigation Measure H-2, which requires the removal of any unknown contaminated soils that could be encountered on the project site during demolition, site clearance, or construction activities. The removal and disposal of these hazardous materials would be in accordance with guidelines specified by the applicable local, State, and Federal resources agencies, including but not limited to, the Department of Toxics Substances Control and federal Environmental Protection Agency Prospect Village FEIR Page 8 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS b. The Phase I Report also disclosed the presence of ACMs on-site, including the following materials: . Approximately 300 square feet of floor texture coat located in the 195 building. It was difficult to assess the material due to the large amount of dust and debris on the floor. . Approximately 20 square feet of 9x9 green vinyl floor tile and mastic exists in the 195 building. The Phase I Report identified approximately 500 square feet of exterior stucco as decorative inlays as asbestos containing construction material (ACCM). The ACCM should be handled as an ACM; however, disposal as asbestos waste is not required. The Draft EIR recommends implementation of Mitigation Measures H-3 and concludes that this measure would reduce any potential asbestos impacts to a less than significant level. This measure provides that if during any future demolition or remodeling activities additional suspect materials are observed, bulk samples shall be collected ofthese materials and analyzed for asbestos content. All suspect materials at the Property are Presumed Asbestos-containing Materials (PACMs) until the asbestos content is confirmed or denied by analytical testing c. The EP A and HUD have defined a LBP at 0.5 percent by weight. The Phase I Report identified the following paints as containing greater than 0.5% lead: . Exterior white paint on the doors and door frames (approximately 300 square feet). . Interior white paint on the doors, door frames, windows, and window frames (approximately 300 square feet). . Interior cream paint on the walls, doors, and windows in the front portion ofthe 191 building (approximately 600 square feet). . Interior red paint on the walls and doors in the rear portion of the 195 building (approximately 400 square feet). According to the Draft EIR, Mitigation Measure H-4 would reduce any lead based paint impact to a less than significant level. This measure requires the applicant to retain a licensed abatement contractor to properly remove and dispose ofthe damaged (peeling, flaking) lead-based paint prior to obtaining a demolition permit 2. Finding The Planning Commission finds that the recommended mitigation measures (H-l through H-4) relating to the removal of the clarifier on site and potentially contaminated soils, the handling of asbestos, and the handling of lead based paint are adopted as stated in paragraph IV of the certification resolution. These measures will mitigate these impacts to a less than significant level. Prospect Village FEIR Page 9 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA TrONS TRAFFIC (SECTION 3.7 FEIR) IMPACT: PROJECT CONSTRUCTION ACTIVITY WOULD GENERATE SHORT TERM TRAFFIC TRIPS 1. Facts The Draft EIR discusses short tenn traffic impacts during construction in Section 3.7 on pages 3.7- 7 to 3.7-8. Construction related traffic would be associated with workers arriving and leaving the project site, and truck and construction vehicle traffic. According to the Draft EIR, Project generated construction worker trips and haul trips are potentially significant but would be reduced to a less than significant level with implementation of Mitigation Measure T -1. This measure requires the developer to prepare a construction staging and parking plan for review and approval by City of Tustin Public Works prior to issuance of a demolition pennit. The developer or contractor must monitor the implementation and effectiveness of the construction staging and parking plan during the construction phase of the project. The plan will include one or more of the following potential types oftraffic-related mitigation measures to ensure that temporary disruptions to the adjacent uses and circulation within the area are minimized: . Construction and Employee Parking: As part of the construction staging and parking plan, the contractor would submit and obtain approval of a construction parking program which reflects the schedule of construction activities and location of construction-related parking. Locations of available parking would be identified. Street Circulation and Parking Measures: The contractor may request and obtain a pennit for any temporary lane closures that may be requireQ for adjacent roadways. The contractor would utilize flagmen for traffic control to minimize inconvenience and for safety of vehicles and pedestrians. Haul Truck Routes, Queue Areas, and Deliveries: The contractor would provide an estimate of truck volume and schedule. Schedule adjustments would be made to minimize the volume during peak traffic hours. Areas would be designated by the developer or contractor for staging of all trucks. All earth-moving and ready-mix trucks would be equipped with two-way radios. The trucks would follow a City-approved route to the project site, without unnecessary waiting. Hours of Excavation Hauling: Heavy truck hauling associated with excavation would be scheduled to minimize interference with daytime activity in the area. The hours for excavation hauling would be detennined in conjunction with the City as part of the construction staging and parking plan. Pedestrian Safety Measures: The contractor would install a construction fence around the perimeter, complying with City requirements before excavation begins. A flagman would be available at all times and would be utilized whenever trucks entering or leaving the Project site may impe,de the flow of traffic. . . . . 2. Findings Prospect Village FEIR Page 10 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS The Planning Commission finds that Mitigation Measure T-I, which requires the applicant to prepare a construction staging and parking plan, is adopted as stated in paragraph IV of the certification resolution. This measure will mitigate short tenn traffic impacts during construction to a less than significant level. IMPACT: THE PROJECT WOULD INCREASE PARKING DEMAND IN THE AREA. The Draft EIR addresses parking impacts in Section 3.7 on pages 3.7-11 through 3.7-13. As discussed in the Draft EIR, the City retained Sasaki Transportation Services to evaluate the Project's peak parking demand. The Parking Study concluded that the twenty-seven (27) off-street parking spaces would be adequate to serve the residences and is consistent with the City of Tustin parking code requirements. The Parking Study also analyzed the shared use parking needs for the commercial component based on the different peak hours of operation. According to the Parking Study, the shared parking demand for the commercial portion of the Project was sixty-two (62) spaces, which would be satisfied by the use of fifty-nine (59) spaces at the City of Tustin Main Street Water facility ("Water Facility") parking lot and three (3) on-site spaces. The Water facility parking lot is located across Prospect A venue, immediately east ofthe Project site. The three additional spaces are provided on- site, immediately west of and adjacent to the E. Main Street building. The analysis was based on the ITE "Shared Parking Planning Guidelines." The Parking Study concluded that the Project's proposed mix of commercial uses (retail, office, and restaurant) would be conducive to a shared parking arrangement. According to the study, the peak parking dem~nds for office, retail, and restaurant uses occur at different times of the day. For example, the office parking peaks occur during the day on week days, while the retail peak is on the weekend. Restaurants are typically busy on Friday and Saturday evenings when retail and office uses are not at their peaks. In order to satisfy the City's shared use requirements, the developer must enter into an agreement with the City of Tustin to use the Water Facility parking lot. In conjunction with consideration of project entitlements, the City of Tustin City Council shall consider an Off-Site Parking Agreement for the provision of fifty-nine (59) parking spaces at the City's Main Street Water facility. If, for some reason, the City Council rejected such an agreement, Project parking impacts would be significant unless the City authorized some alternative arrangement. The Draft EIR recommended Mitigation Measure T-2 to reduce the Project's potential parking impact to a less than significant level. This measure states that if the City Council does not approve the Off-Site Parking Agreement, the applicant must present an alternative shared use agreement to the City for review and approval prior to issuance of a demolition pennit. If the City does not approve an alternative shared use agreement, the Project shall not proceed. 2. Finding The Planning Commission finds that the Mitigation Measure T -2, which requires that the City Council to approve an off site parking agreement or some alternative shared use agreement for the Prospect Village FEIR Page II FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS project to proceed, is adopted as stated in paragraph IV of the certification resolution. This measure will mitigate parking impacts to a less than significant level. IMPACT: DISPOSAL AND REMOVAL OF ASBESTOS CONTAINING MATERIALS, LEAD BASED PAINT, AND EXISTING INOPERABLE CLARIFIER The Phase I Environmental Site Assessment revealed no evidence of recognized environmental conditions in connection with the property, except for the presence of a clarifier on-site, the presence of asbestos containing material (ACM), and lead based paint (LBP) which is typical Of older structures. A clarifier is a tank that is used to treat water, whereby solid particles suspended in the water agglomerate and settle at the bottom of the tank. The solids resulting from the settling are' removed as sludge. The Phase I Report could not determine from the available information whether the clarifier has been officially closed or abandoned. Information concerning the past use and current status ofthe clarifier was similarly not available. In order to reduce the potential for an unauthorized discharge and depending on the future use of the Property, the clarifier would be abandoned or removed in accordance with applicable local, State, and Federal regulations as required by mitigation measure H-l. The Phase I Report also disclosed the presence of ACMs on-site, including the following materials: . Approximately 300 square feet of floor texture coat located in the 195 building. It was difficult to assess the material due to the large amount of dust and debris on the floor. . Approximately 20 square feet of 9x9 green vinyl floor tile and mastic exists in the 195 building. The Phase I Report identified approximately 500 square feet of exterior stucco as decorative inlays as asbestos containing construction material (ACCM). The ACCM should be handled as an ACM; however, disposal as asbestos waste is not required. The EP A and HUD have defined a LBP at 0.5 percent by weight. The Phase I Report identified the following paints as containing greater than 0.5% lead: . Exterior white paint on the doors and door frames (approximately 300 square feet). . Interior white paint on the doors, door frames, windows, and window frames (approximately 300 square feet). . Interior cream paint on the walls, doors, and windows in the front portion of the 191 building (approximately 600 square feet). . Interior red paint on the walls and doors in the rear portion of the 195 building (approximately 400 square feet). Prospect Village FEIR Page 12 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA TrONS Any potential hazards impact resulting from the environmental conditions described above can be reduced to a level of insignificance with implementation of the recommended mitigation measures described below. . Mitigation Measures H-l The applicant shall remove the clarifier on-site in accordance with applicable local, State, and Federal regulations prior to obtaining a grading pennit. VII. FINDINGS CONCERNING LESS THAN SIGNIFICANT IMP ACTS AESTHETICS (FEIR SECTION 3.1) IMPACT: VISUAL IMPACT 1. Facts The Draft ErR analyzes the Project's visual impact in Section 3.1 on pages 3.1-13 through 3.1-15. As discussed in the Draft EIR, while the Project would increase the height and bulk the existing structures and would be taller than some of the surrounding structures, due to the proposed three story live/work units, these design characteristic would not "degrade" the existing visual character of the site or its surroundings. The intent ofthe Project design is to retain the historic look and feel of the existing buildings with references to the unique Victorian/Main Street architectural character that currently exists in the vicinity of the Project site. To ensure that the Project compliments the surrounding area, the buildings would be characterized by details and colors similar to the existing buildings at 191-195 East Main Street. 2. Finding The Planning Commission finds the Project impacts on visual quality would be less than significant based on the analysis contained in Section 3.1 of the Draft EIR and in light of the whole record. IMPACT: LIGHT AND GLARE 1. Facts The project site is currently vacant and no light is generated on the site. While the project would increase the ambient light in the area, the incremental increase is not considered a new source of substantial light and glare. Given the relatively small scale of the project and the fact that the project site is within an urban area that currently generates ambient light, Project impacts relating to light and glare are considered less than significant. 2. Findings The Planning Commission finds the Project impacts on light and glare would be less than significant based on the analysis contained in Section 3.1 of the Draft ErR and in light of the whole record. Prospect Village FEIR Page I3 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS CUMULATIVE IMPACTS: 1. Facts The project development will incrementally contribute to changes in the aesthetic quality of the Old Town area. However, the changes are considered less than significant due to the City's stringent design review and cultural resources review process. 2. Findings The Planning Commission finds the Project's cumulative aesthetic impact would be less than significant based on the analysis contained in Section 3.1 ofthe Draft EIR and in light ofthe whole record. AIR QUALITY (FEIR SECTION 3.2) IMPACT: SHORT- TERM CONSTRUCTION EMISSIONS AND LONG- TERM OPERATIONAL EMISSIONS 1. Facts As reflected in Table 3.2-5 of the Draft EIR above, the Project's estimated construction emissions would be below the AQMD's significance thresholds. Therefore, Project construction activity would have a less than significant air quality impact. As shown on Table 3.2-7, project air quality emissions once operational are similarly insignificant. The Project's projected stationary and mobile source emissions would not exceed the AQMD's significance thresholds. 2. Finding The Planning Commission finds the Project's cumulative aesthetic impact would be less than significant based on the analysis contained in Section 3.1 of the Draft EIR and in light ofthe whole record. CUMULATIVE IMPACTS 1. Facts As documented on pages 3.2-10 and 3.2-11, the Project will have a less than significant cumulative air quality impacts. Giving the timing of each of the cumulative projects, Project construction emissions would not be cumulatively significant. From an operational standpoint, all three projects combined with the Project will increase vehicular and stationary source emissions in the region. However, as described above, Project operational emissions, which include vehicle emissions, are well below the AQMD significance thresholds. The Prospect Village FEIR Page 14 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA nONS Project operational emissions combined with the other projects are not considered cumulatively significant and no mitigation is required. 2. Findings The Planning Commission finds the Project's cumulative air quality impact would be less than significant based on the analysis contained in Section 3.2 ofthe Draft EIR and in light ofthe whole record. ~UL TURAL RESOURCES (FEIR SECTION 3.3) CUMULATIVE IMPACTS: 1. Facts While the Project will have a significant and unavoidable direct impact on two historical resources within the Old Town commercial area, none of the other current projects in Old Town Tustin will have an adverse impact on historical resources. In addition, while there may be other projects within the Old Town commercial area at some point in the future, no other projects are currently planned or proposed that would affect any historical resources in Old Town. 2, Findings The Planning Commission finds the Project's cumulative cultural resources impact would be less than significant based on the analysis contained in Section 3.3 of the Draft EIR and in light of the whole record. HAZARDS (SECTION 3.4 OF FEIR) IMPACT: LAND USES THA T ROUTINEL Y USE NON-HAZARDOUS JANITORIAL SUPPLIES AND CLEANING RELATED MATERIALS 1. Facts The project entails a combination of commercial, office, restaurant, and residential uses, which do not involve the routine transport, storage, use, or disposal of hazardous materials. Any hazardous materials used by future occupants of the proposed uses would generally be limited to those associated with janitorial, maintenance, and repair activities, such as commercial cleansers, lubricants, paints, etc. The transport, storage, use, and disposal of these materials would be subject to Federal, State, and local health and safety requirements. Based on the anticipated nature and use of hazardous materials at the project, as described above, there are no reasonably foreseeable upset and accident conditions that would create a significant hazard to the public due to the release of hazardous materials. In the unlikely event of such an occurrence, State law requires prompt reporting to local and State agencies to ensure the public health and safety would not be jeopardized. No significant impacts related to release of hazardous materials from upset and accident conditions are anticipated to occur. Prospect Village FEIR Page 15 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS 2. Finding The Planning Commission finds the Project would have a less than significant impact relating to the possible release or upset of hazardous materials on site based on the analysis contained in Section 3.4 of the Draft ErR and in light of the whole record. IMPACT: USE OF HAZARDOUS MATERIALS DURING CONSTRUCTION 1. Facts Project grading and construction would be short-term in nature and would be subject to Federal, State, and local health and safety requirements relating to storage, use, and disposal of hazardous materials. No significant impacts related to this issue area are expected to occur during project construction. 2. Finding The Planning Commission finds the Project's short term use of limited quantities of construction equipment related fluids would be a less than significant hazards impact based on the analysis contained in Section 3.4 of the Draft ErR and in light of the whole record. CUMULATIVE IMPACTS: 1. Facts The Project requires the limited transportation of demolition materials that contain asbestos and lead- based paint during construction activity. All transportation and storage of these materials will be handled in accordance with Federal, State, and local regulations. Therefore, Project impacts are considered less than significant. Aside from this limited and common remediation activity, the Project does not involve the storage, use, or transport of any other hazardous materials or other substances, nor does any environmental condition exist on the Project site that would be exacerbated by Project construction or operation. Therefore, even assuming that there is currently a cumulative hazards and hazardous materials impact, the Project does not create any impact that would be cumulatively considerable. Because the Project does not result in any hazards and hazardous materials impacts, the Project would not create any potential cumulative impact on the environment. 2. Finding The Planning Commission finds the Project would have a less than significant cumulative hazards impact based on. the analysis contained in Section 3.4 of the Draft ErR and in light of the whole record. Prospect VilJage FEIR Page 16 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS LAND USE (SECTION 3.5) IMPACT: THE PROJECT REQUIRES A REZONE FROM "C-2" OR "CENTRAL COMMERCIAL" TO "PLANNED COMMUNITY" TO ACCOMMODATE THE RESIDENTIAL COMPONENT OF THE PROPOSED LIVE/WORK UNITs. 1. Facts The approximately one-acre Project site is currently designated "Old Town Commercial" in the City's General Plan and zoned "C-2" or "Central Commercial District." The "C-2" designation allows primarily commercial uses, including retail uses, and professional and general office uses provided certain requirements are satisfied. Residential uses are not currently permitted or conditionally permitted within this zone. Implementation of the Project requires a rezone to accommodate the twelve (12) proposed live/work units behind the proposed commercial retail/office building. The Project site would be rezoned from its underlying "C-2" zoning and overlay zones to Planned Community ("P-C"). In conjunction with the proposed rezone, "Prospect Village Planned Community District Regulations" is hereby adopted. The proposed "Prospect Village Planned Community District Regulations" divide the Project site into two planning areas. Planning Area A is identified as "commercial" and includes an approximately 9,300 square foot area of commercial and office related uses. Planning Area B is approximately 32,900 square feet and is identified as "LivelWork." Six of the twelve live/work units are planned to accommodate 913 square feet of retail space for a total of5,478 square feet of retail. The remaining six units are planned to include 431 square feet of either commercial or retail uses for a total of2,586 square feet. Therefore, while the property will be rezoned "Planned Community" the Project would retain appròximately 17,000 square feet of commercial retail and office space. Moreover, the permitted and conditionally permitted uses in these spaces are either identical to or similar to the uses allowed under the Project site's existing "C- 2" zoning. The Project also includes a considerable amount of commercial retail and office uses that are identical or similar to the uses contemplated under the existing C-2 zoning designation. The mixed use nature of the Project would be consistent with the General Plan's vision for the Old Town Commercial area. The City of Tustin General Plan specifically contemplates an increase in residential uses in the Old Town area, thus acknowledging the compatibility of such uses with other existing uses in Old Town. Policy 10.2 ofthe Land Use Element provides "review and consider the possible development of residential uses in the Old Town area both as individual residential projects and integrated aboveground floor retail and office uses." This is precisely the type of residential product contemplated here. In addition, the General Plan's discussion of the "Old Town Commercial" area specifically states that "uses (such as residential uses) which support this land use may be permitted subject to the discretion of the City." Therefore, even though the Project would require a rezone, the Draft ERI concludes that this would not be a significant land use impact. Prospect Village FEIR Page 17 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA TrONS 2. Finding The Planning Commission finds the Project's impact on land use due to the need for a rezone would be less than significant based on the analysis contained in Section 3.5 of the Draft EIR and in light of the whole record. CUMULATIVE IMPACTS: 1. Facts The only potentially significant land use impact of the Project is its inconsistency with the preservation policies ofthe City's General Plan. However, none of the cumulative projects listed in FEIR (Page 2-15) required the demolition or alteration of any historical resources. Therefore, there would be no cumulative loss of historical resources or cumulative project inconsistency with the historical resource preservation policies of the City's General Plan. 2. Finding The Planning Commission finds the Project would have a less than significant cumulative land use impact based on the analysis contained in Section 3.5 of the Draft ErR and in light of the whole record. NOISE (SECTION 3.6) IMPACT: SHORT-TERM CONSTRUCTION NOISE IMPACTS 1. Facts Land uses near the Project site include primarily commercial and institutional uses with some limited residential north of the Project site along Prospect Avenue, at the northeast comer of Third Avenue and Prospect Avenue, and east ofthe Project site along Third Avenue. During construction, it is anticipated that land uses in the vicinity of the construction area would be exposed to noise generated by various pieces of construction and demolition equipment operating within the project site. As discussed in Section 3.6 of the Draft EIR, temporary noise levels adjacent to the construction area could be 72 to 93 dBA depending on the distance the receptor is from the source of noise. However, construction noise impacts during the loudest construction phases, including demolition, grading, and utilities installation would be temporary, lasting only approximately two to three months. Due to the temporary nature of the loudest phases of construction activity and the Noise Ordinance requirements which restrièt construction activity to the least noise sensitive daylight hours, Project construction noise impacts are considered less than significant impacts. 2 Findings The Planning Commission finds the Project would have a less than significant short tenn construction noise impact based on the analysis contained in Section 3.6 of the Draft EIR and in light of the whole record. Page 18 Prospect Village FEIR FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA TrONS IMPACT: PERIODIC INCREASE IN AMBIENT NOISE LEVELS DURING OUTDOOR P AT/O DINING AND OUTDOOR ENTERTAINING ON RESIDENTIAL DECKs. 1. Facts The Project includes a 593 square foot outdoor dining area that will be located along East Main Street. During the hours of restaurant operation people eating outdoors could periodically increase ambient noise levels. However, any increase in noise levels would largely impact the other non- noise sensitive uses, such as the commercial and office uses that culTently exist on either side of East Main Street. As discussed above, noise sensitive residential land uses are located north and northeast of the Project site. However, these residential uses would be unaffected by the outdoor dining area which faces E. Main Street. The live/work units located behind the new commercial retail office building would function as a noise buffer between the restaurant and the residential uses located north and north east of the Project site. Therefore, any potential increase in ambient noise levels from the restaurant would be less than significant. In addition to the outdoor dining area, each ofthe twelve (12) proposed live/works unit would have a small approximately 80 square foot outdoor deck overlooking either Prospect Avenue or new Prospect Lane (culTently a public alley). While a certain level of noise may be generated by one or more people standing on these decks, due to the small size of the balcony, the amount of people on the deck at any given time would be limited and any colTesponding noise level would be less than significant. 2. Finding The Planning Commission finds that noise generated by the proposed outdoor dining area of the restaurant and the residential balconies would be less than significant based on the analysis contained in Section 3.6 of the Draft ErR and in light of the whole record. IMPACT: THE PROJECT WOULD GENERATE ADDITIONAL TRAFFIC TRIPS THAT WOULD INCREASE AMBIENT NOISE LEVELS. 1. Facts CulTently, Prospect Avenue (between Main & First St.) experiences a daily traffic volume of approximately 4, I 00 trips per day, while E. Main Street between Newport and EI Camino Real experiences about 9,000 trips per day. The project would result in a six percent (6%) increase in traffic trips along Prospect Avenue, which is negligible and would not substantially increase permanent ambient noise levels. A noise level of 60 dB CNEL is considered an acceptable exterior residential noise level. Therefore, while Project generated traffic would increase ambient noise levels in the area, these increases fall within the acceptable range and are therefore considered less than significant. Pnspen Village FEIR Pagr 19 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA nONS 2. Findings The Planning Commission finds the Project would have a less than significant traffic noise impact based on the analysis contained in Section 3.6 of the Draft EIR and in light of the whole record. CUMULATIVE IMPACTS: 1. Facts According to Section 3.6 of the Draft EIR, the proposed project in conjunction with other past, present, and reasonably foreseeable future projects would have a less than significant short-term cumulative construction and operational noise impact. Each of the three (3) projects identified in section 2.5 ofthe EIR are far enough from the project site that cumulative construction noise levels would not be significant. In addition, construction activity at each of the Project sites would be staggered. Similarly, the project would have a less than significant cumulative operational noise impact. 2. Finding The Planning Commission finds the Project would have a less than significant cumulative noise impact based on the analysis contained in Section 3.6 of the Draft EIR and in light of the whole record. TRAFFIC (SECTION 3.7) IMPACT: ONCE OPERATIONAL, THE PROJECT WOULD GENERATE 600 TRAFFIC TRIPS THAT WOULD BE DISTRIBUTED TO THE SURROUNDING ROADWAYS AND INTERSECTIONs. 1. Facts According to the Draft EIR, which is based on the Prospect Village Traffic Impact Analysis, dated December 12,2003 and prepared by Sasaki Transportation Services, the project would generate approximately 600 traffic trips per day at build-out, including 23 inbound and 15 outbound trips during the A.M. peak hour and 24 inbound and 26 outbound in the P.M. peak. The Traffic study prepared for the project analyzed whether Project generated traffic would have a significant impact on the roadways and intersections within the study area. As demonstrated on Pages 3.7-8 and 3.7-9 of Draft EIR and in the Traffic Study, the Project would not have a significant impact on roadway or intersection operation. With the addition of Project traffic, each roadway in the !Study area would operate at an acceptable LOS D or better. 2. . Finding The Planning Commission finds the Project would have a less than significant operational traffic impact based on the analysis contained in Section 3.7 of the Draft EIR, the Traffic Study and in light of the whole record. Page 20 Prospect ViI1age FEIR FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS -CUMULATIVE IMPACTS: 1. Facts The Traffic Study analyzed potential traffic impacts with and without the Project. The Traffic Study first detennined future traffic conditions without the Project, which was based on cumulative traffic forecasts that were perfonned in conjunction with the environmental studies for the MCAS Tustin Disposal and Reuse Plan. The Traffic Study also added a one percent growth factor through the year 2020. Project traffic was then added to the "without" project conditions and impacts were assessed accordingly. The Traffic Study concluded that Project traffic when combined with future traffic forecasts for the area would not result in any significant impacts on intersections and roadways within the study area. The Project would also not create any significant cumulative parking impact in conjunction with the other related projects identified in the FEIR (Page 2-15). With respect to each of these projects, the City detennìned that the City's off-street parking requirements had been satisfied. 2. Finding The Planning Commission finds the Project would have a less than significant cumulative traffic impact based on the analysis contained in Section 3.7 of the Draft EIR, the Traffic Study, and in light of the whole record. VIII. FINDINGS OF FACT CONCERNING PROJECT AL TERNA TIVES Because the Project will cause unavoidable significant environmental effects, the City must consider the feasibility of any environmentally superior alternative to the proposed project. As discussed in the Draft EIR, the Project would have potentially significant impacts relating to historical resources and land use. The objectives for the proposed Prospect Village project are generally based on those in the City of Tustin General Plan, Housing Element and Town Center Redevelopment Plan, as discussed in Section 4.2 of the FEIR, and are as follows: . To develop the vacant and underutilized site within the next 2 to 3 years to capitalize on the current favorable private development financing conditions for mixed-use projects; To eliminate delay and uncertainties regarding future development of the site; To stimulate private investment and demonstrate economic viability in the Old Town commercial area. To increase the amount of specialty retailing and commercial development in the core of the Old Town commercial area in order to enhance its urban character and bolster the commercial area's revitalization and long-tenn economic viability; To expand the niche market character of the Old Town commercial area by providing a balanced and complementary mix of new retail and commercial uses; . . . . Prospect Village FEIR Page 21 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS . To increase the number of residential units in the Town Center Redevelopment Project Area, while reflecting a high-quality urban character; To develop ground floor specialty retailing configurations consistent with current market condition requirements; To provide a minimum 3,000 square foot high-quality restaurant along with outdoor patio dining to enliven the pedestrian environment along Main Street in the Old Town commercial area; To create a financially viable commercial mixed-used development with minimum public subsidy; To create construction jobs and permanent jobs in the Town Center Redevelopment Project Area; To increase the property tax increment and sales tax revenues in the Project Area, which will be earmarked for ongoing economic development activities in the Old Town commercial area including business retention and outreach programs, façade improvement programs, and community facility projects; and, To achieve the Old Town commercial area redevelopment goals and objectives of the City's General Plan and the Town Center Redevelopment Plan. . . . . . . The project objectives are consistent with the Redevelopment Plan's goals, objectives, and proposed activities to assist in eliminating conditions of physical and economic blight identified in the Redevelopment Plan for the Town Center Area Redevelopment Project and further the City's goals for the development of a viable Old Town Commercial district A primary purpose ofthe Redevelopment Plan for the Town Center Area Redevelopment Project is to eliminate and prevent the spread of blight and deterioration in the Project Area. To eliminate and - prevent the spread of blight and deterioration, the Redevelopment Plan identified activities proposed by the Agency to include the following: 1. Providing for participation by owners and residents presently located in the Proj ect Area; 2. Rehabilitation of structures and improvements by present owners, their successors, or the Agency; 3. Redevelopment of land by private enterprise or public agencies for uses in accordance with the plan; 4. Installation, construction, or reconstruction of streets, utilities, and other public improvements; 5. Acquisition of certain real property for public improvements or to help expedite private development; 6. Relocation assistance to displaced residential and non-residential occupants should the need arIse; 7. Demolition or removal of certain buildings and improvements; 8. Management of any property acquired under the ownership and control ofthe Agency; and 9. Disposition of any property acquired by the Agency for uses in accordance with the Plan. The goal for the Old Town commercial area is to create a sustainable and competitive 24-hour district that will serve a broad segment of the City's business and residential population. Prospect Village FEIR Page 22 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS Development of a compact eight-block commercial-retail core at the heart of the Old Town commercial area would serve as the primary specialty retail area. The project's development programming and design approach is consistent with the recommendations in the "Visions of Old Town," a planning study that was prepared in 1991 and coordinated by the Regional/Urban Design Assistance Team (RIUDA T) through the American Institute of Architects (AlA). As described in the RlUDAT study, the commercial-retail core needs to be filled with new restaurants, retail stores, and offices that will introduce a mix of commercial activities which will be competitive with the surrounding strip commercial centers located along Newport A venue. It is important to long-tenn economic viability of the Old Town commercial area to re-establish the area in the near future as the "town center" for the City of Tustin by intensifying private commercial retail development and . providing a viable alternative to the traditional neighborhood strip centers and community shopping centers found on nearby Newport Avenue and other areas of the City. AL TERNA TIVES CONSIDERED, BUT ELIMINATED FROM FURTHER CONSIDERATION CEQA provides that an EIR should identify any alternatives that the lead agency considered but rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency's detennination. I Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (1) failure to meet most ofthe basic objectives, (2) infeasibility, or (3) inability to avoid significant environmental effects.2 Consistent with this requirement, this section identifies three (3) alternatives that the City of Tustin considered, but rejected as infeasible during the scoping process, and provides a brief explanation of the reasons for their exclusion. El Camino Real/6th Street Site Alternative This alternative site is approximately 1.7 -acres and is located in the Old Town Commercial area at EI Camino Real and 6th Street. The alternative site is a portion of a larger 4-acre subdivision. Over the past fiv~ (5) years, the Agency has referred several private developers, who expressed an interest in developing the site, to the property owners.3 However, in each case, the property owners failed to engage the developers in any level of meaningful negotiations. Instead, the property owners sought to develop the site in accordance with their own investment objectives. Because the Agency does not own the alternative site and based on the historic recalcitrance ofthe property owners to sell the site, the Agency has detennined that it is not feasible to pursue redevelopment of this site. Moreover, this alternative would not meet several of the most basic project objectives including the need to develop a mixed use project within the next two to three years and to eliminate delay and uncertainty regarding future development of the site. Pursuing and ultimately developing this site against the wishes of the property owner would take far longer than the two (2) to three (3) year redevelopment period and substantially increase the uncertainty of a redevelopment project. The timing ofthe project is critical in light ofthe favorable financing and market conditions, which could I 14 Cal. Code Regs §15126.6(c) 2 Ibid. 3 These developers included: Warmington Homes (developer of the 38 single family homes at Ambrose Lane located across Sixth Street); the Olson Company (one of the nation's largest residential infill developers); CIM Group (a highly experienced retail/residential mixed-use infill developer); and Pacific Gulf Development (a large-scale senior citizen and multifamily rental housing developer). Prospect Village FEIR Page 23 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA nONS worsen over time. Based on past experiences with the property owner, pursuing this site and negotiating an acceptable agreement would be difficult and time consuming. W First St. Site Alternative This alternative site is approximately 1.2 acres and is located at 137 W. First Street. This alternative site is located outside the Old Town Commercial area and outside the Town Center Redevelopment Project Area. Due to its location outside the Old Town commercial area and the Town Center Redevelopment Project Area, the site would not meet the most basic project objective, which is to revitalize Old Town with a mixed use commercial/residential project. In addition, this alternative site is a less attractive redevelopment option because the site has a limited amount of retail window frontage on First Street. Thus, the ability to find viable retail tenants would be jeopardized. Finally, the Agency would have to acquire this site from the current property owner, which, like the above alternative site, would take far longer than the two (2) to three (3) year development period identified in the project objectives. Relocating the Utt Juice Buildings The Agency also considered-relocating the existing structures to an undeveloped site in the Old Town Commercial Area. This alternative was rejected as infeasible for several reasons. First, transporting the masonry structures, which are constructed on concrete slab foundations, without significantly damaging the structures, would be difficult. Second, assuming the structure were not significantly damaged during transit, relocating the structures to another part of Old Town would not necessarily substantially lessen or avoid the Project's significant impact on historic resources. The Historic Resources Technical Report in Appendix C ofthe EIR noted the historical significance of these structures at their existing location: - - "The UTT Juice Buildings also derive significance because of their location at a prominent comer of Old Town Tustin. In fact, the Buildings provide an "introduction" to Old Town as the first of its historic buildings one encounters when traveling west on Main Street. Their elimination... would significantly affect the visitor's initial historic view of Old Town.,,4 Therefore, relocating the structure would not reduce the Project's significant and unavoidable impact on historical resources. RANGE OF AL TERNA TIVES AND REASONING FOR SELECTION OF AL TERNA TIVES The EIS/EIR analyzed a reasonable range of alternatives by identifying alternatives that could potentially attain the project objectives while avoiding or substantially lessening the significant effects ofthe proposed project. As documented in the EIR, the Project would have a significant and unavoidable direct impact on historical resources and would be inconsistent with General Plan policies that promote rehabilitation and reuse of historical structures. Therefore, the City developed a range of Project alternatives that focus on varying levels of rehabilitation and reuse ofthe existing 4 Historic Resources Technical Report at p. 11 Page 24 Prospect Village FEIR FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS structures in accordance with the Secretary's Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings, 1995, Weeks and Grimmer ("Secretary's Standards and Guidelines"). The Secretary's Standards and Guidelines provide, among other things, that construction of adjacent buildings or additions to the existing structures should: (a) be limited in size and scale in relationship to the existing structure, (b) be located at or on non-character-defining building elevations of the existing structures, and (c) avoid rooftop additions which would not be set back from the wall plane ofthe existing structures. PROJECT ALTERNATIVES Six (6) Project alternatives, including a "No Project" alternative and five (5) Project alternatives were evaluated, as listed below. 1. Full Reuse Alternative: This alternative would rehabilitate and reuse the existing historic buildings, construct a new retail structure on E. Main St., and construct ten (10) live/work units; 2. Partial Reuse Alternative: This alternative would rehabilitate and reuse the existing structures, except for the rear portion of the 193, 195 Building, which would be demolished. This alternative also includes a new retail building on E. Main St., and ten (10) live/work units; Partial Reuse (193, 195 Building Only) Alternative: This alternative entails rehabilitation and reuse of a portion of the 193, 195 Building, demolition of the 191 building and construction of a new retail building on E. Main Street and twelve (12) live/work units. 3. 4. Full Reuse (Existing Zoning) Alternative: This alternative entails rehabilitation and reuse of the existing historic buildings and development of the remaining portions of the site in accordance with the existing C-2 zoning designation. 5. Facade Reuse Alternative: This alternative entails rehabilitation and reuse of only the façade of the 193, 195 Building, construction of a new two story retail/office building on E. Main Street and twelve (12) live/work units. pr<)spe"~ Village FEIR Page 25 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS FINDINGS The Planning Commission finds that the "No Project" Alternative is infeasible within the meaning of PRC § 21081(a) (3), due to economic, legal, social, technological, environmental, or other considerations as follows: 1. The No Project Alternative would fail to meet the objective of providing for near term implementation of development on the Project site since no activity would take place and the existing buildings are unsafe to occupy and likely to remain vacant for the foreseeable future. 2. The No Project Alternative would fail to meet the objective of intensifying and expanding commercial development and specialty retailing in the Old Town commercial area since no activity would take place and the existing buildings on the site are unsafe to occupy and likely to remain vacant for the foreseeable future. 3. The No Project Alternative would fail to meet the objective of creating a balanced and complementary mix of retail and commercial uses since no activity would take place and the existing buildings on the site are unsafe to occupy and likely to remain vacant for the foreseeable future. 4. The No Project Alternative would fail to meet the objective of adding additional residential units since no activity would take place and the existing buildings are unsafe to occupy and likely to remain vacant for the foreseeable future. In addition, the existing zoning does not permit residential uses nor would the existing buildings accommodate residential uses. 5. The Ño Project Alternative would fail to meet the objective of providing ground floor specialty retailing depths of 45 feet consistent with current market conditions and recommendations since no activity would take place and the existing buildings are unsafe to occupy and likely to remain vacant for the foreseeable future. 6. The No Project Alternative would fail to meet the objective of providing a minimum 3,000 square foot restaurant use since no activity would take place and the existing buildings are unsafe to occupy and likely to remain vacant for the foreseeable future. 7. The No Project Alternative would fail to meet the objective of creating a financially viable mixed use development with a minimum public subsidy since no development would occur. 8. The No Project Alternative would fail to meet the objective of creating increased property tax increment in the Project Area to assist in funding economic development activities in the Old Town commercial area since no development would occur. 9. The No Project Alternative would fail to meet the objective of creating employment associated with construction and new commercial activities since no development would occur. Prospect Village FEIR Page 26 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA nONS 10. The No Project Alternative would fail to meet the objective of stimulating private investment in the Old Town commercial area with the least amount of public funding since no development, or investment, would occur. In addition, the lack of new development in Old Town would contribute to general uncertainties in the Old Town commercial area caused by a delay in development of the site. The Planning Commission finds that "Alternative 1 (Full Reuse Alternative)" is infeasible within the meaning ofPRC § 21081(a) (3), due to economic, legal, social, technological, environmental, or other considerations as follows: 1. Alternative 1 would fail to meet the objective of providing for near term implementation of development on the project site since no developers have indicated full rehabilitation is feasible or practical. As documented in Draft EIR (p. 2-6) and extensively in the Response to Comments (Response 8.7-8), the City has negotiated with five different developers and all the developers have been unable to determine the feasibility of preserving and reusing the structures. Given the City's inability to find a developer willing to reuse these structures for a redevelopment project, adopting this alternative would cause delay and uncertainty in the development of the site. The City would need to find a developer that is willing to rehabilitate the existing buildings and able to secure the necessary private investment funding. 2. Alternative 1 would diminish the objective of intensifying and expanding commercial development and specialty retailing in the Old Town commercial area. In comparison the proposed project, which would add 16,653 square feet of retail and office space, this alternative would result in only 14,780 square feet, which is an 11.2 percent reduction in the amount of retail and office space planned for the site. 3. Alternative I would diminish the objective of creating a balanced and complementary mix of retail and commercial uses. In comparison to the project, which would add 9,251 square feet (55%) of retail and 7,402 square feet of office (45%), Alternative 1 would add 12,625 square feet (85%) of retail and 2,155 (15%) square feet of office, which does not balance the provision of retail and office uses as well as the project. 4. Alternative 1 would diminish the objective of adding additional residential units since only ten (10) units would be provided in comparison to the project, which would provide twelve (12) units. 5. Alternative 1 would fail to meet the objective of providing ground floor specialty retailing depths of 45 consistent with current market conditions and recommendations since full rehabilitation would result in oddly configured building depths of sixty (60) to ninety (90) feet and a restaurant space that is inconsistent with current market conditions and recommendations. 6. Alternative 1 would diminish the objective of providing a minimum 3,000 square foot restaurant with outdoor patio dining since no outdoor dining area would be provided with full rehabilitation of the existing buildings. Prospect Vi]1)ge F51R Page 27 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA nONS 7. Alternative 1 would fail to meet the objective of creating a financially viable mixed use development with a minimum public subsidy. According to the independent economic feasibility study conducted by the firm Keyser Marston Associates Inc., October 28,2003, this alternative would reflect a negative supportable land value of -$390,000, requiring a minimum subsidy of $1,245,000 (based on the difference between the Agency's cost of acquisition, which was $855,000, and the supportable land value) as opposed to no public subsidy to support the proposed project.s In other words, the construction costs to rehabilitate the structures in a manner suitable for reuse would exceed the value of the project. As documented in the KCM Group report, the increase in construction costs is predominantly driven by the rehabilitation and reuse costs, which far exceed the cost ofnew construction. For example, under the full reuse scenario, the probable cost ofrehabilitation of the buildings to a shell condition is approximately 196.44 per square feet.6 On the other hand, the probable cost of constructing new structures to a shell condition is about $116 per square feet less or approximately $80 per square feet.7 In addition, the KMA Report concludes that the preserved space is not as efficient as newly developed space.8 The existing buildings are broken into smaller spaces that are less useful than newly developer retail and restaurant spaces. Thus from a marketability standpoint, space in the preserved building is not as attractive and has a negative impact on the overall value ofthe project for a prospective developer. According to the KMA Report, preserved retail space is proj ected to rent for $13 per square foot, as opposed to $15 per square foot for new space, while preserved restaurant space is projected to rent for $15 per square foot versus $21 per square foot for new restaurant space.9 8. Alternative 1 would diminish the objective of creating increased property tax increment in the Project Area to assist in funding economic revitalization and development activities in the Old Town commercial area since the proposed project is anticipated to generate $85,000 annually whereas Alternative 1 is anticipated to generate $70,500 annually, which is 17.4 percent less in revenues than the proposed project. 10 9. Alternative 1 would diminish the objective of creating employment associated with new commercial activities since it would generate thirty-three (33) percent less permanent jobs than the proposed project. 10. Alternative 1 would fail to meet the objective of stimulating private investment in the Old Town commercial area with the least amount of public funding since it would reflect a necessary public subsidy of $1,245,000 over the proposed project, and thus, would 5 Evaluation ofCEQA Alternatives- Proposed Prospect Village Project, Lames Rabe and Kevin Engstrom, Keyser Marston Associates Inc. October 28, 2003, p. 3-4 ("KMA Report") . 6 Utt Juice Building Rehabilitation Estimates, Gordon Kovturn, KCM Group, October 10,2003; KMA Report, Alternative 2Scenario,Table IA 7 KMA Report, Prospect Village Project Scenario, Table IA 8 KMA Report, p. 4 9 KMA Report, p. 3-4 10 KMA Report at p. 7 Prospect Village FEIR . Page 28 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS contribute to general uncertainties regarding the feasibility of development within the Old Town commercial area. The City Council finds that "Alternative 2 (Partial Reuse Alternative)" is infeasible within the meaning of PRC § 21081 (a) (3), due to economic, legal, social, technological, environmental, or other considerations as follows: 1. Alternative 2 would fail to meet the objective of providing for near term implementation of development' on tht project site since no developers have indicated rehabilitation and reconfiguration of the existing buildings is feasible or practical. While this alternative entails only partial, instead of full reuse, based on the City's prior experiences with developer, there is considerable uncertainty as to whether the City could successfully find a developer willing to implement this or any type of reuse alternative. As documented in the City's economic feasibility studies, rehabilitating and reusing any portion of the existing structures significantly increases construction costs and increase the amount of the public subsidy. I I Adopting this alternative would cause delay and uncertainty in the development of the site since a developer would need to be identified that is willing to rehabilitate the existing buildings and able to secure the necessary private investment funding. 2. Alternative 2 would diminish the objective of intensifying and expanding commercial development and specialty retailing in the Old Town commercial area. In comparison the proposed project, which would add 16,653 square feet of retail and office space, this alternative would result in only 15,160 square feet, which is a 9 percent reduction in the amount of retail and office space planned for the site. 3. Alternative 2 would diminish the objective of creating a balanced and complementary mix of retail and commercial uses. In comparison to the project, which would add 9,251 square feet (55%) of retail and 7,402 square feet of office (45%), Alternative 2 would add 11,405 square feet (75%) of retail and 3,755 (25%) square feet of office, which does not balance the provision of retail and office uses as well as the Project. 4. Alternative 2 would diminish the objective of adding additional residential units since only ten (10) units would be provided in comparison to the Project, which would provide twelve (12) units. 5. Alternative 2 would fail to meet the objective of providing ground floor specialty retailing depths of 45 consistent with current market conditions and recommendations since full rehabilitation would result in an oddly configured building depth of sixty (60) feet and a restaurant space that is inconsistent with current market conditions and recommendations. 6. Alternative 2 would diminish the objective of providing a minimum 3,000 square foot restaurant with outdoor patio dining use since no outdoor dining area would be provided with full rehabilitation of the existing buildings. 11 KCM Report; KMA Report Prospect Village FEIR Page 29 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA TrONS 7. Alternative 2 would fail to meet the objective of creating a financially viable mixed use development with a minimum public subsidy since rehabilitation under this alternative would reflect a negative supportable land value of -$437,000, requiring a minimum subsidy of$1,292,000 (based on the difference between the Agency's cost of acquisition, which was $855,000, and the supportable land value) as opposed to no public subsidy to support the proposed project.12 The negative supportable land value is based on the increased construction costs for the rehabilitation effort combined with the loss oftwo residential units. In addition, the KMA Report concludes that the preserved space is not as efficient as newly developed space. 13 The existing buildings are broken into smaller spaces that are less useful than newly developer retail and restaurant spaces. Thus from a marketability standpoint, space in the preserved building is not as attractive and has a negative impact on the overall value of the project for a prospective developer. According to the KMA Report, preserved retail space is proj ected to rent for $13 per square foot, as opposed to $15 per square foot for new space, while preserved restaurant space is projected to rent for $15 per square foot versus $21 per square foot for new restaurant space. 14 8. Alternative 2 would diminish the objective of creating increased property tax increment in the Project Area to assist in funding economic revitalization and development activities in the Old Town commercial area since the proposed project is anticipated to generate $85,000 annually whereas Alternative 2 is anticipated to generate $71,100 annually, which is 16.6 percent less in revenues than the proposed project. 15 . 9. Alternative 2 would diminish the objective of creating employment associated with new commercial activities since this alternative would generate twe12ty-three (23) percent less permanent jobs less than the proposed project. 10. Alternative 2 would fail to meet the objective of stimulating private investment in the Old Town commercial area with the least amount of public funding since it would reflect a necessary public subsidy of $1,292,000 over the proposed project, and thus, would contribute to general uncertainties regarding the feasibility of development within in the Old Town commercial area. 11. While Alternative 2 would increase the level of rehabilitation and reuse, it would still cause a significant and unavoidable impact on the historic Uti Juice Building. According to the Ci ty' s Historic Resources Report, the impact on these structures would only be reduced to a less than significant level if the project retained all historic resources on site with reuse dictated by what alterations and additions are possible under the Secretary of Interior Standards.16 Because this alternative entails demolition of the rear portion one of the structures, the impact would remain significant and unavoidable. ,. :, 12 KMA Report, p. 5 13 KMA Report, p. 4 14 KMA Report, p. 3-4 15 Id. at p. 7 16 Historic Resources Technical Report, Utt Juice Redevelopment Project, Tim Gergory, July 14,2003, p. 13 Page 30 Prospect Vi1\age FEIF FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS The Planning Commission finds that "Alternative 3" is infeasible within the meaning of PRC § 21 081( a) (3), due to economic, legal, social, technological, environmental, or other considerations as follows: 1. Like Alternatives 1 and 2, Alternative 3 would fail to meet the objective of providing for near term implementation of development on the project site since no developers have indicated rehabilitation and reconfiguration of the existing buildings is feasible or practical. While this alternative entails only partial, instead of full reuse, based on the City's prior experiences with developer, there is considerable uncertainty as to whether the City could successfully find a developer willing to implement this or any type of reuse alternative. As documented in the City's economic feasibility studies, rehabilitating and reusing any portion of the existing structures significantly increases construction costs and increase the amount of the public subsidy. I7 Adopting this alternative would cause delay and uncertainty in the development of the site since a developer would need to be identified that is willing to rehabilitate the existing buildings and able to secure the necessary private investment funding. 2. Alternative 3 would diminish the objective of intensifying and expanding commercial development and specialty retailing in the Old Town commercial area. In comparison the proposed project, which would add 16,653 square feet of retail and office space, this alternative would result in only 15,044 square feet, which is a 9.7 percent reduction in the amount of retail and office space planned for the site. 3. Alternative 3 would diminish the objective of creating a balanced and complementary mix of retail and comm~rcia1 uses. In comparison to the project, which would add 9,251 square feet (55%) of retail and 7,402 square feet of office (45%), Alternative 3 would add 9,746 square feet (65%) of retail and 5,298 (35%) square feet of office, which does not balance the provision of retail and office uses as well as the project 4. Alternative 3 would diminish the objective of providing a minimum 3,000 square foot restaurant with outdoor patio dining use since no outdoor dining area would be provided with full rehabilitation of the existing buildings. 5. Alternative 3 would diminish the objective of creating a financially viable mixed use development with a minimum public subsidy since rehabilitation under this alternative would reflect a supportable land value of $112,000, requiring a minimum subsidy of $738,000 (based on the difference between the Agency's cost of acquisition, which was $855,000, and the supportable land value) as opposed to no public subsidy to support the proposed project 18 In addition, the KMA Report concludes that the preserved space is not as efficient as newly developed space. 19 The existing buildings are broken into smaller spaces that are less useful 17 KCM Report; KMA Report 18 KMA Report, p. 6 19 KMA Report, p. 4 Prospect Vil1':.,~ FEIR Page 31 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS than newly developer retail and restaurant spaces. Thus from a marketability standpoint, space in the preserved building is not as attractive and has a negative impact on the overall value ofthe project for a prospective developer. According to the KMA Report, preserved retail space is proj ected to rent for $13 per square foot, as opposed to $15 per square foot for new space, while preserved restaurant space is projected to rent for $15 per square foot versus $21 per square foot for new restaurant space,zo '6. Alternative 3 would diminish the objective of creating employment associated with new commercial activities since this alternative would generate seventeen (17) percent less permanent jobs less than the proposed project. 7. Alternative 3 would fail to meet the objective of stimulating private investment in the Old Town commercial area with the least amount of public funding since it would reflect a necessary public subsidy of$738,000 over the proposed project, and thus, would contribute to general uncertainties regarding the feasibility of development within in the Old Town commercial area. 8. While Alternative 3 would increase the level of rehabilitation and reuse, it would still cause a significant and unavoidable impact on the historic Uti Juice Building. According to the City's Historic Resources Report, the impact on these structures would only be reduced to a less than significant level if the project retained all historic resources on site with reuse dictated by what alterations and additions are possible under the Secretary of Interior Standards.21 Because this alternative entails demolition of the rear portion one of the structures, the impact would remain significant and unavoidable. The City Council finds that "Alternative 4 (Full Reuse (Existing Zoning) Alternative)" is infeasible within the meaning of PRC § 21081(a) (3), due to economic, legal, social, technological, environmental, or other considerations as follows: 1. Like the other alternatives, Alternative 4 would fail to meet the objective of providing for near term implementation of development on the project site since no developers have indicated full rehabilitation is feasible or practical. As documented in Draft EIR (p. 2-6) and extensively in the Response to Comments (Response 8.7-8), the City has negotiated with five different developers and all the developers have been unable to determine the feasibility of preserving and reusing the structures. Given the City's inability to find a developer willing to reuse these structures for a redevelopment project, adopting this alternative would cause delay and uncertainty in the development of the site since a developer would need to be identified that is willing to rehabilitate the existing buildings and able to secure the necessary private investment funding. 2. Alternative 4 would diminish the objective of creating a balanced and complementary mix of retail and commercial uses. In comparison to the Project, which would add 9,251 square feet (55%) of retail and 7,402 square feet of office (45%), Alternative 5 would provide 19,120 20 KMA Report, p, 3-4 2\ Historic Resources Technical Report, Utt Juice Redevelopment Project, Tim Gergory, July 14,2003, p. 13 Prospect Village FElR Page 32 7. 8. FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS square feet (68%) of retail and 9,000 (32%) square feet of office, which does not balance the provision of retail and office uses as well as the Project. 3. Alternative 4 would fail to meet the objective of adding additional residential units since no residential units would be provided in comparison to the Project, which would provide twelve (12) units. 4. Alternative 4 would fail to meet the objective of providing ground floor specialty retailing depths of 45 consistent with current market conditions and recommendations since full rehabilitation would result in oddly configured building depths of sixty (60) to ninety (90) feet and a restaurant space that is inconsistent with current market conditions and recommendations. 5. Alternative 4 would diminish the objective of providing a minimum 3,000 square foot restaurant with outdoor patio dining use since no outdoor dining area on Main Street would be provided with full rehabilitation of the existing buildings. . 6. Alternative 4 would fail to meet the objective of creating a financially viable mixed use development with a minimum public subsidy since full rehabilitation would reflect a negative supportable land value of -$1,813,3000, requiring a minimum subsidy of $2,668,000 (based on the difference between the Agency's cost of acquisition, which was $855,000, and the supportable lane value).22 In addition, the KMA Report concludes that the preserved space is not as efficient as newly developed space.23 The existing buildings are broken into smaller spaces that are less useful than newly developer retail and restaurant spaces. Thus from a marketability standpoint, space in the preserved building is not as attractive and has a negative impact on the overall value of the project for a prospective developer. According to the KMA Report, preserved retail space is proj ected to rent for $13 per square foot, as opposed to $15 per square foot for new space, while preserved restaurant space is projected to rent for $15 per square foot versus $21 per square foot for new restaurant space.24 Alternative 4 would fail to meet the objective of creating increased property tax increment in the Project Area to assist in funding economic revitalization and development activities in the Old Town commercial area since the proposed project is anticipated to generate $85,300 annually whereas Alternative 4 is anticipated to generate $37,200 annually, which is 56.4 percent less in revenues than the proposed project.25 Alternative 4 would fail to meet the objective of stimulating private investment in the Old Town commercial area with the least amount of public funding since it would reflect a necessary public subsidy of $2,668,000 over the proposed project, and thus, would 22 KMA Report, p. 6-7 23 KMA Report, p. 4 24 KMA Report, p. 3-4 25 KMA Report, p. 7 Prospect Vi1lage FEIP Page 33 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS contribute to general uncertainties regarding the feasibility of development within in the Old Town commercial area. The Planning Commission finds that "Alternative 5 (Facade Reuse Alternative)" is infeasible within the meaning ofPRC § 21081 (a) (3), due to economic, legal, social, technological, environmental, or other considerations as follows: 1.. Alternative 5 would fail to meet the objective of providing for near term implementation of development on the project site since no developers have indicated facade preservation is feasible or practical. Adopting this alternative would cause delay and uncertainty in the development of the site since a developer would need to be identified that is willing to preserve the façade of existing buildings and able to secure the necessary private investment funding. In addition, special design and construction techniques would be necessary to reuse the existing façade within a new development. Adding a second floor above the existing façade would be problematic in terms of achieving architectural compatibility and functionality of second floor areas. 2. Although Alternative 5 would provide twelve residential units similar to the proposed Project, these units would need to be designed to complement the existing façade and architecture, which may add to the construction cost. Adopting this alternative would cause delay and uncertainty in the development of the site since a developer would need to be identified that is willing to design and build residential units that are compatible with the façade of existing buildings. 3. Although Alternative 5 could provide for a 3,000 square foot outdoor dining area opportunity, it would need to be integrated within the existing façade, which may result in a less than desirable outdoor dining area in comparison with the Project. 4. Alternative 5 would diminish the objective of creating a financially viable mixed use development with a minimum public subsidy since façade preservation would reflect a supportable land value of$198,000, requiring a minimum subsidy of$657,000, compared to no public subsidy to support the proposed project. 5. Alternative 5 would fail to meet the objective of stimulating private investment in the Old Town commercial area with the least amount of public funding since it would reflect a necessary public subsidy of$657,000 over the proposed project, and thus, would contribute to general uncertainties regarding the feasibility of development within in the Old Town commercial area. IX. STATEMENT OF OVERRIDING CONSIDERATIONS INTRODUCTION The California Environmental Quality Act (CEQA) requires a decision-maker to balance the benefits of a proposed project against its unavoidable environmental risks in determining whether to approve the project. lithe Planning Commission, Tustin City Council, or Tustin Community Redevelopment Prospect Village FEIR Page 34 (b) (c) FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS Agency allows the occurrence of significant effects through approval of a project, it must state its specific reasons for so doing in writing. Such reasons are included in the "statement of overriding considerations. " Section 15093 of the CEQA Guidelines establishes the following requirements for a statement of overriding considerations: (a.) CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered "acceptable." When the lead agency approves a project which will result in the occurrence of significant effects, which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the final EIR and/or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. If an agency makes a statement of overriding considerations, the statement should be included in the record of the Project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091. The Planning Commission of the City of Tustin adopts and makes the following statement of overriding considerations regarding the remaining unavoidable impacts identified within the Final Environmental Impact Report (FEIS/EIR) for the Prospect Village Project. In adopting Resolution No. 3910, the Planning Commission acknowledges that it has weighed the benefits ofthe identified the Project against the adverse significant impacts that have not been avoided or substantially lessened to less than significant levels through mitigation. The Planning Commission hereby determines that the benefits of the project outweigh the unmitigated adverse impacts and the Project should be approved. The Planning Commission finds that to the extent that the identified significant adverse impacts have not been avoided or substantially lessened, there are specific economic, legal, social, technological, or other considerations which support approval of the project. SIGNIFICANT UNA VOIDABLE IMPACTS Unavoidable or potentially unavoidable significant environmental effects ofthe project identified in the Final EIR/EIS and Findings of Significant Impacts include the following: . The project will cause a substantial adverse change in the significance of historical resources as defined in Section 150064.5. Prospect Village FEIR Page 35 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA TrONS . The project would be inconsistent with General Plan policies that promote preservation and rehabilitation of historic resources. ADOPTION OF OVERRIDING CONSIDERATIONS The Planning Commission specifically adopts this Statement of Overriding Considerations and finds that: a) as part of the approval provisions, the Project has eliminated or substantially lessened all significant effects on the environment where feasible; b) mitigation measures to mitigate the effects associated with the Project are within the jurisdiction ofthe City, and, c) the remaining unavoidable impacts of the Project are acceptable in light of the environmental, economic, legal, social, technological, and other considerations set forth herein, because the benefits of the Project outweigh the significant and adverse impacts. The Planning Commission finds that each of the overriding considerations set forth below constitutes a separate and independent ground for finding that the benefits of the Project: 1) outweigh its significant adverse environmental impacts, and 2) is an overriding consideration warranting approval of the Project. These matters are súpported by substantial evidence in the record. FINDINGS OF OVERRIDING CONSIDERA nONS The Environmental Impact Report ("EIR") prepared for the Prospect Village project ("the Project") identified two closely related significant adverse unavoidable Project impacts associated with land use and cultural resources. The Project will cause: I) a significant unavoidable adverse land use impact due to a conflict with a limited number of General Plan policies relating to the preservation - of historical resources as a result of the proposed demolition of the Uti Juice Buildings, and 2) a significant unavoidable adverse cultural resources impact due to the permanent loss of the historically significant Utt Juice Buildings. The Project, however, will create substantial benefits for the City of Tustin, specifically the Old Town commercial area. The Planning Commission has balanced the Project's benefits against the Project's significant unavoidable land use and cultural resources impacts. The Planning Commission finds that the Project's benefits outweigh the Project's significant unavoidable impacts, and the impacts are therefore considered acceptable in light of the Project's benefits. The Planning Commission finds that each ofthe following benefits is an overriding consideration, independent of the other benefits, that warrant approval of the Project as designed, notwithstanding the Project's significant and unavoidable land use and cultural resources impacts: 1. The Project will eliminate delays and uncertainties regarding redevelopment of the site Since 1998 when the Agency acquired the property, the Agency has actively marketed the Project site. However, as documented in the Response to Comments portion of the Final EIR, up until now, the Agency has been unsuccessful in its efforts to find a developer willing to redevelop the Project site. (See Final EIR, Section 2.0 Response to Comments, Response 8.7-8) One developer initially expressed interest but failed to complete the proposal process. After approximately 16 months of negotiations with another entity consisting of a Page 36 Prospect Village FEIR FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA nONS partnership between two developers, the Agency was unable to reach a mutually acceptable agreement on the amount of the substantial public subsidy to make the project viable and a commitment to implementation. The Agency encountered similar issues with three other developers. This Project finally removes the uncertainties surrounding build-out ofthis site and makes redevelopment of the site a reality. 2. The Project will stimulate private investment and demonstrate economic viability of the Old Town commercial area The Project site has not been inactive and consistent permanent commercial use since 1973. The project site was included in the Town Center Redevelopment Project Area because of economic deterioration and physical blight. The Project with its exceptional design and its mix of office, commercial, restaurant, and residential uses represents further progress in the revitalization of the Old Town area. The Project will demonstrate to developers and other private investors that Old Town can be a viable location for future commercial, retail, and residential uses. The Project will increase the residential presence in Old Town and replace the currently vacant Utt Juice buildings with a large street level restaurant and retail use thereby enlivening this area of Old Town. The Project would be consistent with the recommendations in the "Visions of Old Town," a broad community-based planning study that was prepared in 1991 and coordinated by the Regional/Urban Design Assistance Team (R/UDAT) through the American Institute of Architects (AlA). As described in the R/UDAT study, the commercial-retail core needs to be filled with new restaurants, retail stores, and offices that will introduce a mix of commercial activities which will be competitive with the surroundingßtrip commercial centers located along Newport Avenue. It is important to long-term economic viability of the Old Town commercial area to re-establish the area in the near future as the "town center" for the City of Tustin by intensifying private commercial retail development and providing a viable alternative to the traditional neighborhood strip centers and community shopping centers found on nearby Newport Avenue and other areas ofthe City. This Project with its retail, restaurant, and office component will also achieve the City's General Plan land use goals, which promote economic expansion and diversification. These goals include: to "Broaden the City's tax base by attracting businesses which will contribute to the City's economic growth and employment opportunities..." (General Plan, Land Use Element, Policy 7.1); and to "Focus retail development into consolidated, economically viable and attractive centers of adequate size and scale which offer a variety of retail goods and amenities. (General Plan, Land Use Element, Policy 7.5). 3. The Project will add to the City's supply of residential units and improve the jobs to housing ratio in Old Town Implementation of the Project would increase the inventory of residential uses in the Old Town area. Specifically, the Project would create twelve (12) new residential units and is consistent with General Plan goals to develop character of the Old TownlFirst Street area including "possible development of residential uses in the Old Town area both as individual Prospect Village FEIR Page 37 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS residential proj ects and integrated above ground floor retail and office uses." (General Plan, Land Use Element, Policy 10.2). These new units will also be occupied by the owners and proprietors of the retail and office uses that will be below each unit. Thus, the Project will allow residents to live above their businesses and offices thereby eliminating commuting and associated traffic congestion and air quality impacts. 4. The Project would implement the General Plan's overall vision for development of the site The Project's mix of residential, office, retail, and restaurant (with outdoor dining area) uses achieves the General Plan's vision for future build-out of the Old Town/First Street area. The Project's restaurant and outdoor dining patio is consistent with the General Plan policy which encourages outdoor pedestrian spaces, such as courtyards, arcades, and open landscape passages to be integrated into new development. (General Plan, Land Use Element, Policy 10.3). The Project's approximately 6,200 square feet of ground floorretail, 3,500 square foot restaurant (includes the outdoor dining area) and another 2,500 square feet of ground floor retail/office spaces accessible from public sidewalks would be consistent with the General Plan policy, which encourages high-quality pedestrian oriented building frontages which open onto these pedestrian spaces and public sidewalks. (General Plan, Land Use Element, Policy 10.6). Moreover, as noted above, the General Plan specifically envisions the Project's live/work or residential component for Old Town. 5. The Project would implement the Town Center Redevelopment Plan's vision for the site The Project implements the goals and objectives of the Town Center Redevelopment Plan Area ("Area"). The Redevelopment Plan goals and objectives for the Area include the creation of a mixed use town center that combinés commercial, office, residential, and public uses. The Redevelopment Plan also encourages residential development by actively seeking private development in the redevelopment area. The Project's mix of retail, office, restaurant and residential is consistent with these goals and objectives. 6. The Project will generate property and sales tax revenues for the Agency and City The Project will create a new source of property and sales tax revenue for the City and the Agency. The City will receive sales tax revenue for the retail sales that occur on-site, and the Agency will receive tax increment revenues from the property taxes paid.26 According to the feasibility study, property tax revenues for the Project would total approximately $85,300 and sales tax would total $10,500.27 7. The Project will assist in the elimination o/blight in the Town Center Redevelopment Plan Area ("Area ") The Project will assist in eliminating blight as identified under Sections 33031 and 33031 of 26 KMA Report, p.26 "Evaluation of CEQA Alternatives - Prospect Village," James Rabe & Kevin Engstrom, Keyser Marston Associates. Inc., October 28,2003, p. 7 27 rd. Pag~ 38 Prospect Village FEIR FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERA nONS the California Redevelopment Law and in the Second Implementation Plan for the Town Center and South Central Redevelopment Areas (January 2000) including the following: . Unsafe/Dilapidated/Deteriorated Buildings characterized by conditions caused by serious building code violations, dilapidation or deterioration. Physical Conditions that Limit Economic Viability and Use of Lots and Buildings characterized by conditions that can be caused by substandard design, inadequate size given present standards and market conditions, lack of parking, or similar factors. Depreciated/Stagnant Property Values or Impaired Investments characterized, but not necessarily limited to properties containing hazardous waste or other conditions that require the use of agency authority. High Business Turnovers and Vacancies/Low Lease Rates/Abandoned Building/Vacant Lots within an area developed for urban use and served by utilities. . . . Prospect Village FEIR Page 39 EXHIBIT C OF RESOLUTION NO. 3910 MITIGATION MONITORING PROGRAM Prospect Village FEIR Page 2 PROSPECT VILLAGE FINAL ENVIRONMENTAL IMP ACT REPORT MITIGATION MONITORING PROGRAM This Mitigation Monitoring and Reporting Program has been prepared in accordance with the requirements of the California Environmental Quality Act (CEQA) section 21081.6. Its purpose is to ensure implementation of the mitigation measures required by the Prospect Village Final Environmental Impact Report (FEIR) for the Prospect Village Project, located in the City of Tustin and the City of Irvine, in the County of Orange. The City of Tustin has adopted the mitigation measures included in the Final EISIEIR in order to mitigate or avoid significant impacts on the environment. This program has been designed to ensure compliance during project implementation. Mitigation measures identified in the Final EISIEIR for the Prospect Village Project have been incorporated into a checklist. Each mitigation measure is listed separately on the checklist with appropriate spaces for monitoring the progress of implementation of each measure. Mitigation measures are also identified in thi s Mitigation Monitoring and Reporting Program. The following information is identified for each measure listed in the checklist: . The timing of implementation of the mitigation measure. The appropriate agency to enforce the mitigation measure. . The mitigation measures in the table are listed by environmental impact area in the same order as they are listed in the Final EISIEIR. Mitigation Monitoring and Report Program Management As shown in Table 1, the mitigation measures associated with the project will be completed in conjunction with development of the project. Availability of Mitigation Monitoring and Reporting Program The completed Mitigation Monitoring and Reporting Program checklist will be retained in the project file and will be available for public inspection on proper request. Prospect Village FEIR Page 3 Measure Cultural Resources 1: Prior to issuance of a demolition permit, documentation of the buildings to be removed shall be undertaken by the developer to be approved by the City utilizing the standards of the Historic American Building Survey (HABS), including photo-documentation and measured drawings of the East Main and Prospect A venue elevations. These items, together with the Historical Resource Technical Report, shall be added to the Tustin Area Historical Society Museum. Cultural Resources 2: If buried cultural resources, such as chipped or ground stone, historic debris, building foundations, or human remains are inadvertently discovered during ground-disturbing activities, work will stop in that area and within 100 feet of the find until a qualified archaeologist can assess the significance of the fmd, and, if necessary, develop appropriate treatment measures. Treatment measures typically include development of avoidance strategies, capping with fill material, or mitigation of impacts through data recovery programs such as excavation or detailed documentation. The construction contractor and lead contractor compliance inspector will verify that work is halted until appropriate treatment measures are implemented if cultural resources are Timing and Implementation Mitigation Monitoring and Enforcement Responsibility Mitigation Compliance Responsibility Prior to issuance of a demolition pennit City of Tustin Community Development Department During construction City of Tustin Community Development Department . Exhibit C of Resolution No. 3910 Mitigation Monitoring Program Page 2 Measure discovered during construction activities. Concurrence from the City on measures to be implemented before resuming construction activities in the area of the fmd will be obtained. Hazards 1: The applicant shall remove the clarifier on site in accordance with applicable local, state and federal regulations prior to obtaining a grading pel111it. Hazards 2: Any unknown contaminated soils that could be encountered on the project site during demolition, site clearance, or construction activities shall be removed trom the project site and disposed of off- site. The removal and disposal of these hazardous materials would be in accordance with guidelines specified by the applicable local, state and federal resources agencies, including but not limited to the Department of Toxics Substances Control and federal Environmental Protection Agency. Hazards 3: If during any future demolition or remodeling activities additional suspect materials are observed, bulk samples shall be collected of these materials and analyzed for asbestos content. All suspect materials at the Property are Presumed Asbestos-containing Materials Timing and Implementation Mitigation Monitoring and Enforcement Responsibility Mitigation Compliance Responsibility Prior to issuance of grading pennits City of Tustin Community Development Department During construction City of Tustin Community Development Department During demolition or remodeling City of Tustin Community Development Department Prospect Village FaR Page 2 Exhibit C of Resolution No. 3910 Mitigation Monitoring Program Page 3 Measure (PACMs) until the asbestos content is confmned or denied by analytical testing. Hazards 4: The applicant shall retain a licensed abatement contractor to properly remove and dispose of the damaged (peeling, flaking) lead-based paint prior to obtaining a demolition permit. Traffic 1: The developer shall prepare a construction staging and parking plan for review and approval by City of Tustin Public Works prior to issuance of demolition permit. The developer or contractor shall monitor the implementation and effectiveness of the construction staging and parking plan during the construction phase of the project. The plan shall include one or more of the following potential types of traffic-related mitigation measures to ensure that temporary disruptions to the adjacent uses and circulation within the area are minimized: . Construction and Employee Parking: As part of the construct.ion staging and parking plan, the contractor would submit and obtain approval of a construction parking program which reflects the schedule of construction activities and location of construction-related Timing and Implementation Mitigation Compliance Responsibility Mitigation Monitoring and Enforcement Responsibility Prior to issuance of a demolition permit City of Tustin - Community Development Department Prior to issuance of a demolition permit City of Tustin Public Works Department Prospect Village FFlR Page 3 Exhibit C of Resolution No. 3910 Mitigation Monitoring Program Page 4 Measure . parking. Locations of available parking would be identified. Street Circulation and Parking Measures: The contractor may request and obtain a permit for any temporary lane closures that may be required for adjacent roadways. The contractor would utilize flagmen for traffic control to minimize inconvenience and for safety of vehicles and pedestrians. Haul Truck Routes, Queue Areas, and Deliveries: The contractor would provide an estimate of truck volume and schedule. Schedule adjustments would be made to minimize the volume during peak traffic hours. Areas would be designated by the developer or contractor for staging of all trucks. All earth- moving and ready-mix trucks would be equipped with two-way radios. The trucks would follow a City-approved route to the project site, without unnecessary waiting. Hours of Excavation Hauling: Heavy truck hauling associated with excavation would be scheduled to minimize interference with daytime activity ifl the area. The hours for excavation hauling would be . . Timing and Implementation Mitigation Monitoring and Enforcement Responsibili!r. Mitigation Compliance Responsibility Prospect Village FElR Page 4 Exhibit C of Resolution No. 3910 Mitigation Monitoring Program Page 5 'Measure determined in conjunction with the City as part of the construction staging and parking plan, . Pedestrian Safety Measures: The contractor would install a construction fence around the perimeter, complying with City requirements before excavation begins. A flagman would be available at all times and would be utilized whenever trucks entering or leaving the project site may impede the flow of traffic. Parking 1: If the City Council does not approve the Off-Site Parking Agreement, the applicant must present an alternative shared use agreement to the City for review and approval prior to issuance of a demolition permit. If the City does not approve an alternative shared use agreement, the Project shall not proceed, Timing and Implementation Mitigation Monitoring and Enforcement Responsibility Mitigation Compliance Responsibility Prior to issuance of a demolition permit City of Tustin Community Development Department Prospect Village FER Page 5