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Home My WebLink About13 S.A. METRO EAST DEIR COMMENTS 01-15-07AGENDA REPORT MEETING DATE: JANUARY 15, 2007 TO: WILLIAM A. HUSTON, CITY MANAGER FROM: COMMUNITY DEVELOPMENT DEPARTMENT SUBJECT: CITY OF TUSTIN RESPONSE TO CITY OF SANTA ANA DRAFT ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE METRO EAST MIXED USE OVERLAY ZONE PROJECT SUMMARY City Council authorization is requested for the City of Tustin's response to the subject Draft Environmental Impact Report (DEIR) prepared for a proposed City of Santa Ana General Plan Amendment and Zoning Code Amendment to allow for the development of higher density mixed-use and/or residential land uses (up to 23 stories and an overall 3.0 floor area ratio) within an overlay zone of 200 acres. The proposed Overlay Zone is located directly adjacent to the City of Tustin, west of Tustin Avenue, south of East Sixth Street, and between Interstate 5 and State Route 55 in the City of Santa Ana (location Map - Attachment A). The Draft EIR includes a program level document (Volume One) to analyze the potential environmental impacts of implementing the 200-acre Overlay Zone and one project level document (Volume Two) to analyze a project-specific development currently proposed within the Overlay Zone, called the "First and Cabrillo Towers" project. The project- specific development proposes approximately 374 residential units in buildings up to 23 stories and approximately 8,900 square feet of commercial space. RECOMMENDATION: That the City Council authorize staff to forward the attached response letter to the City of Santa Ana. FISCAL IMPACT: There are no direct fiscal impacts associated with this action. City Council Report Metro East January 15, 2007 Page 2 BACKGROUND AND DISCUSSION: The proposed project includes a General Plan Amendment and Zoning Code Amendment to allow for the development of mixed-use and/or residential land uses (up to 23 stories and an overall 3.0 floor area ratio) within an overlay zone of 200 acres located directly adjacent to the City of Tustin. (Location Map - Attachment A). The program level analysis of the Draft EIR studies the potential environmental impacts resulting from the rezoning and the associated higher density development that could be built within the proposed Overlay Zone. The project-specific development currently proposed is the First and Cabrillo Towers project, which proposes approximately 374 residential units in buildings up to 23 stories and approximately 8,900 square feet of commercial space. The proposed project would generally increase the maximum General Plan Floor Area Ratio for the 200-acre Overlay Zone from 2.0 to 3.0. A floor area ratio of 3.0 is a relatively high density for this area and would allow for the construction of high rise buildings. The proposed increase in development intensity may have significant traffic impacts to arterial streets in the City of Tustin. In addition to traffic impacts, there is a potential for aesthetic, noise, land use, and aircraft overflight impacts to the City of Tustin. The Community Development and Public Works Departments have reviewed the subject Draft EIR. Staff believes that it is in the City's interest to be on record regarding this matter and has prepared correspondence expressing the City's concerns regarding the Draft EIR document (see Attachment B). Staff requests that the Tustin City Council review and consider these comments and, if acceptable, authorize their formal transmission to the City of Santa Ana. Scott Reekstin Senior Planner Elizabeth A. Binsack Community Development Director Attachments: A. Location Map B. Draft Comment Response Letter S:\Cdd\CCReports\DEIR Santa Ana Metro East Overlay.doc ATTACHMENT A Location Map XJ ..w.w.<'.......w"n,.,...:......./~ '.w.wm......wm.....~.w..~at . . . . : t:!.u.. .- l-t=:=~==:^.../ :;~ !gf : ... .'. ;<t!'w... W.' V^.... ......"'..j 'N"~j -o.:n.w.......WN.............__... .~..-... "....#.~._ : : r""" """'.W., ~.-..........-------"._....1 ,.~.. r ,! '.' i ~ ......*^..~ i~ ~ ~ [:~:'~==J ~=j~~3-~~~~t b'--~ '-'~~ ........ ~ ~. 9':....... CJ)~ ~: .......-..., E........4iii.......$r~...^.....,.~ i ~ ':: ...3iii:Sr:.'.;' ! ~~= ...~~ .....~......J ~......~...-..---:.-......~ ",," .; . > ". ; .: " rr.:=st1----'., L~~--~~~____J L--__~_~_J jCi) j to . .~ '. ;1,~J ~:~i~J[;'j :'( i :, ~ <ni . :~~.::~rj~~t~~L-..., z~ )>'1 'fe~ '~:~~'.' ~.:Warreri......Sf~::.::.:.::.~~ r-=:::.::.w.:atti.::Sc::,:'::.:1t;j. ~'%'\:.. ..::~,:::;:... ~ -':'\" $ " :::::::.:.::.::::]t." ":~~~:.. "'::?:::'':;:::::Z:>.:;:.. "~"'\:<.. ":;::" "'::::'~>.:;\:s:~~ '~e'". 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'<, Metro East Mixed-Use Overlay Zone EIR ATTACHMENT B Draft Comment Response Letter January 16, 2007 City of Santa Ana Planning and Building Agency Attn: Sergio Klotz 20 Civic Center Plaza Santa Ana, CA 92702 SUBJECT: REVIEW OF DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE METRO EAST MIXED USE OVERLAY ZONE PROJECT IN THE CITY OF SANTA ANA Dear Mr. Klotz: Thank you for the opportunity to provide comments on the Draft Environmental Impact Report (DEIR) for the Metro East Mixed Use Overlay Zone Project in the City of Santa Ana. The Project is proposed to allow for the development of higher density mixed-use and/or residential land uses (up to 23 stories and an overall 3.0 floor area ratio) within a 200-acre overlay zone generally located west of Tustin Avenue, south of East Sixth Street, and between Interstate 5 and State Route 55 in the City of Santa Ana (Project). The City of Tustin has identified the following comments and concerns: Traffic 1 · All development within the Project should be required to fully mitigate, including the acquisition of necessary right-of-way and construction of all requisite public improvements, any negative impact that may affect any other property, regardless of jurisdictional boundaries. We believe that there will be a significant increase in traffic, circulation, noise, and parking impacts on property within the City of Tustin, so the Project must contain mitigation measures and conditions of approval to address all Project impacts, including cumulative impacts. (NOP Commen~ 2. Given this specific project area, there are significant traffic operational issues that should be considered in the DEIR. The required operational analyses should supplement standard intersection evaluations. The traffic operational issues should include potential freeway ramp operation impacts on the arterial roadways related to ramp metering; the spacing of intersections including the freeway interchange intersections; lane utilization related to accessing the freeway, impacts due to limited east-west and north-south arterials as a result of freeway crossings, and any potential need to implement traffic diversion methods. (NOP Comment) As an example, the Sergio Klotz Metro East Project January 16, 2007 Page 2 DEIR identifies mitigation to add capacity at the SR-55 NB Ramp/Irvine Boulevard intersection for vehicles turning to the on-ramp, but it is not known if the ramp meters will accommodate this added traffic. 3. Some of the traffic concerns related to this area are highlighted by the recent 1-5/SR- 55 weaving/merging study by the OCT A. There are identified impacts at the interchange which need to be considered in the analyses. (NOP Comment) 4. The proposed Overlay Zone is estimated in the DEIR to generate a maximum of 115,521 daily trip ends, of which 8,487 and 11,974 would occur during t.he AM and PM peak hours, respectively. Some percentage of these trip ends are currently being generated by the existing uses at the project site, but a significant percentage will be "new traffic" added to this already congested area (including the 1-5/SR-55 interchange). The impacts to the freeways and arterials need to be addressed in the DEIR. 5. Table 12 of the DEIR traffic study provides an estimate of the existing traffic being generated by the existing uses on the study sites. There needs to be verification that standard ITE trip rates are representative of current conditions at the study sites. 6. A realistic assessment of the use of the arterial roadways as a bypass to the freeway system should be considered. (NOP Comment) Even with recent approval of the renewal of Measure M, there is still concern regarding impacts to the arterial road system. 7. The traffic analyses for the proposed Project should be based on traffic forecasts derived from a traffic model that includes the Tustin Legacy Project. (NOP Comment) The DEIR references the OCTA OCTAM model, but there should be assurance that the Legacy Project is accurately included in the OCT AM model. 8. There should be a complete and thorough discussion of the traffic model assumptions, such as ramp metering assumptions, TDM credits, and freeway congestion. (NOP Comment) 9. The DEIR should utilize a select zone model run to identify where the Project traffic will travel on the surrounding roadways, including those roadways in the City of Tustin. (NOP Comment) 10. Given the proposed changes in land uses, the analyses should consider the potential "worst case" traffic impacts and required mitigations associated with build out of the Overlay Zone before the individual projects are considered. Essentially the ultimate conditions need to be evaluated to assure adequate infrastructure can be provided to support the Overlay Zone project and that each individual project provides its "fair share" of the ultimate infrastructure needs. (NOP Comment) Sergio Klotz Metro East Project January 16, 2007 Page 3 11. There is a significant amount of new development already approved in the City of Irvine that will use arterial roadways, including Irvine Boulevard, First Street, Bryan Avenue, Main Street, and EI Camino Real. These volumes should be considered in the DEIR. (NOP Comment) The list of cumulative projects does not appear to include these developments in the City of Irvine. 12. Given the current comments on the DEIR traffic analyses, there could be additional comments once these responses and added analyses are provided for review. 13. The NOP provided descriptions of the Project land uses/sizes and MPAH road system changes. The DEIR will need to detail the effects of the assumed road system changes and the effects of the traffic generated by the proposed project. (NOP comment) 14. From a land use and traffic perspective the definition of the Project is critical and should be clearly identified in the DEIR. The analysis needs to consider the land use changes, the road system changes and what conditions will be considered as the "baseline" regarding identification of Project-related impacts. (NOP comment) 15. There are different traffic projections dependent on whether a toll or non-toll operation is assumed for the Transportation Corridors. There should be analyses of the worst case, which is anticipated to be the "with toll" conditions. (NOP Comment) 16. For locations within the City of Tustin, the traffic analysis must be consistent with City of Tustin criteria and methodologies. (NOP Comment) For example, the CMP criteria should only apply to CMP locations. Noise 17. The DEIR should include a full analysis of any potential impacts to the flight paths to John Wayne Airport. It must be assured that the proposed high rise buildings do not impact the flight paths for aircraft and potentially increase noise impacts for Tustin residents or increase the number of flights over the City of Tustin due to a diversion of flights farther to the east. (NOP Comment) 18. The DEIR includes an analysis of potential long-term traffic-related noise impacts to receptors along First Street, Irvine Boulevard, Yorba Street, and other arterials in the City of Tustin that may be impacted by "cut-through" traffic. Although the DEIR indicates that the projected noise increases are below the thresholds established in the DEIR and therefore are insignificant, the historic resources and other sensitive uses along these arterials should be protected from these noise increases through the implementation of all feasible mitigation measures. Sergio Klotz Metro East Project January 16, 2007 Page 4 Land Use 19. Because of the potential noise, traffic, and aesthetic impacts to adjacent uses and historic resources, the DEIR should identify how a buffer zone, including the potential implementation of traffic diversion techniques, will be implemented along the eastern and southern boundaries of the Overlay Zone. The DEIR should specifically identify the general range of proposed outright permitted and conditionally permitted uses within these buffer areas. (NOP Comment) 20. It should be explained in the DEIR whether the transfer of development rights will be permitted in the Overlay Zone and what type of process would be required to obtain a transfer of development rights. (NOP Comment) 21. The DEIR should analyze whether the proposed Overlay Zone would justify the need for new on-ramps and/or off-ramps to the SR-55 Freeway at First Street. If the improvements are justified, the Draft EIR must identify the significant potential impacts associated with such improvements and the methods to be utilized to protect the adjacent sensitive uses, which include significant historic resources. (NOP Comment) Aesthetics 22. The DEIR includes view analyses within Santa Ana, but excludes a detailed view analysis which focuses on proposed or potential views from the various sensitive land uses in the City of Tustin, including the many historic resources in the vicinity, toward the Overlay Zone. The DEIR should include view analyses from within Tustin. General 23. Portions of the proposed Overlay Zone are directly adjacent to, or in close proximity to, portions of the City of Tustin. Of significant concern are the potential aesthetic, noise, and traffic impacts to the sensitive uses and historic resources to the south and east of the overlay area, which include St. Jeanne de Lestonnac School, the Briarcliff residential community, Old Town Tustin, and other residential neighborhoods. The DEIR should specifically analyze the potential impacts to these sensitive uses and the need to implement various techniques to reduce these impacts, including traffic diversion. (NOP Comment) 24. The DEIR should identify which types of outreach programs will be utilized to disseminate information and gather input from the various residential and business groups that have an interest in the portions of Tustin which are located directly south and east of the proposed Overlay Zone. (NOP Comment) Sergio Klotz Metro East Project January 16, 2007 Page 5 Thank you again for the opportunity to provide comments on the Draft Environmental Impact Report for the Metro East Mixed Use Overlay Zone Project. Please provide me with a copy of all public notices relating to the City of Santa Ana's consideration of the Project. If you have any questions regarding the City's comments, please call me at (714) 573-3016 or Terry Lutz, Principal Engineer, at (714) 573-3263. Sincerely, Scott Reekstin Senior Planner cc: Elizabeth A. Binsack Jason Retterer Tim Serlet Dana Kasdan Dana Ogdon Terry Lutz Steve Sasaki SR:environmental etc/Santa Ana Metro East DEIR Letter.doc