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HomeMy WebLinkAbout10 CITY RESPONSE TO NOP FOR IRVINE HCG PROJ 08-07-07Agenda Item 10 `'~~ ~ Reviewed: AGENDA REPORT City Manager ,~. ' Finance Director N/A MEETING DATE: AUGUST 7, 2007 TO: WILLIAM A. HUSTON, CITY MANAGER FROM: COMMUNITY DEVELOPMENT DEPARTMENT SUBJECT: CITY OF TUSTIN RESPONSE TO NOP FOR IRVINE HCG PROJECT SUMMARY City Council authorization is requested for the City of Tustin's response to the subject Notice of Preparation (NOP) for a draft Environmental Impact Report (DEIR) for a Master Plan, Zone Change, Tentative Parcel Map, Development Agreement, Transfer of Development Rights, and other discretionary actions for the HCG office retail project in the Irvine Business Complex ("IBC") located at 2722 Michelson Drive and 18582 Teller Avenue. RECOMMENDATION: That the City Council authorize staff to forward the attached response letter to the City of Irvine. FISCAL IMPACT: There are no fiscal impacts associated with this action. BACKGROUND AND DISCUSSION: The Community Development and Public Works Departments have reviewed the subject Notice of Preparation. The proposed HCG office retail development consists of 785,000 square feet of office space and 15,500 square feet of retail space on 15.65 acres at the southwest corner of Teller Avenue and Jamboree Road. An existing industrial/office building consisting of 120,300 square feet has been demolished at the site, and the demolition of a remaining industrial/office building consisting of 169,555 square feet is proposed. The proposed Project represents a significant increase in trip generation potential. This level of trip increase has the potential to impact the surrounding street and freeway system. Given the existing levels of congestion in the areas surrounding the Project, it is possible that various travel routes leading to and from the Project could be affected. City Council Report NOP For Irvine HCG Project August 7, 2007 Page 2 Some of the affected routes could include, but may not be limited to, Jamboree Road, Barranca Parkway, Edinger Avenue, the I-5 Freeway, etc. The City of Tustin is concerned with the trip increase associated with the currently proposed Project and the significant changes in land uses (i.e. from commercial buildings to residential, etc.) generally occurring within the IBC area that have occurred to date and are proposed to continue in the future. The previous IBC studies addressed individual, Project by Project changes, but the cumulative effect of the new land plans were not addressed as a whole. As previously stated, we believe that the cumulative land use changes occurring within the IBC could result in significant modifications to the previously anticipated traffic impacts and planned mitigations. This Draft Environmental Impact Report (DEIR) could serve to update and address the overall transportation impacts due to the anticipated changes in land uses within the IBC. 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 Notice of Preparation document (see Attachment A). Staff requests that the Tustin City Council review and consider these comments and, if acceptable, authorize their formal transmission to the City of Irvine. Sc t Reekstin Senior Planner Elizabeth A. insac Community Development Director Attachment: Draft Comment Response Letter S:\Cdd\CCReports\NOP SCAG 2008 RTP and RCP.doc Attachment A August 8, 2007 Ms. Pam Davis Senior Planner City of Irvine P.O. Box 19575 Irvine, CA 92623-9575 SUBJECT: NOP FOR IRVINE HCG PROJECT Dear Ms, Davis: Thank you for the opportunity to provide comments on the proposed HCG office retail development that consists of 785,000 square feet of office space and 15,500 square feet of retail space on 15.65 acres at the southwest corner of Teller Avenue and Jamboree Road. It is our understanding that an existing industrial/office building consisting of 120,300 square feet has been demolished at the site, and the demolition of a remaining industrial/office building consisting of 169,555 square feet is proposed. The City of Tustin has reviewed the Notice of Preparation provided for the Project and determined that vehicle trip generation estimates based on Institute of Transportation Engineer rates indicate that approximately 7,220 trip ends per day would be generated by the proposed Project. When compared to the trip estimates for the existing building at the site (based an "industrial park" trip rate that would address both office and industrial uses), a total of 1,180 trip ends per day is projected. This results in a potential net increase of approximately 6,000 trip ends that would be generated by the Project above the trip potential of the existing building. Consequently, we believe that the evidence of record indicates that the proposed Project represents a significant increase in trip generation that has the potential to impact the surrounding street and freeway system. Given the existing levels of congestion in the areas surrounding the Project, it is possible that various travel routes leading to and from the Project could be affected. Some of the affected routes could include, but may not be limited to, Jamboree Road, Barranca Parkway, Edinger Avenue, the I-5 Freeway, etc. Any environmental document prepared for the Project needs to include an evaluation of the transportation impacts generated by the "net" increases in trip generation. These impacts may directly affect arterial street segments and intersections, as well as freeway locations within the City of Tustin. The trip generation increases could also indirectly affect the City of Tustin as there are current agreements for the City of Tustin to participate in traffic mitigation measures within the IBC area. These proposed trip increases will also need to be evaluated in conjunction with additional changes in the IBC land uses, many of which have already occurred to date. The types of land Ms. Pam Davis NOP For Irvine HCG Project August 8, 2007 Page 2 use changes that have been previously proposed/occurred are expected to result in vehicle travel patterns that vary substantially from the patterns previously assumed in the approved IBC environmental documents. In addition, it is likely that the actual traffic conditions associated with the existing IBC developments are more intensive than previously anticipated. Therefore, given the proposed traffic increases and proposed/planned change of uses, there needs to be a comprehensive evaluation of the amount of additional development activity that can actually be supported by the existing infrastructure and feasible mitigation measures. Most of the previous IBC traffic studies have assumed a maximum level of potential development and compared Project proposals to that assumed maximum. We believe it will be imperative to determine if the former level of assumed development is practical, based on current traffic conditions. Again, the City of Tustin is concerned with the trip increase associated with the currently proposed Project and the significant changes in land uses (i.e. from commercial buildings to residential, etc.) generally occurring within the IBC area that have occurred to date and are proposed to continue in the future. The previous IBC studies addressed individual, Project by Project changes, but the cumulative effect of the new land plans were not addressed as a whole. As previously stated, we believe that the cumulative land use changes occurring within the IBC could result in significant modifications to the previously anticipated traffic impacts and planned mitigations. This Draft Environmental Impact Report (DEIR) could serve to update and address the overall transportation impacts due to the anticipated changes in land uses within the IBC. The City of Tustin has also identified the following specific concerns and issues: 1. Section XV, "Transportation/Traffic," of the NOP States that a traffic impact analysis ("TIA") will be prepared for the Project. The TIA needs to include documentation of the potential transportation impact issues identified above. 2. A build-out analysis needs to be included in the DEIR to verify/update the future improvement needs. The build-out evaluations should include an update of the current conditions, the affects of land use changes that have occurred to date, updated mitigation requirements, etc. 3. Mitigation Measures that will be required of the Project will need to be included in an updated assessment of the original IBC traffic mitigations. It is anticipated that the Project will need to update some of the needed improvements in the IBC study area. It is possible that added mitigations will be needed for areas impacted outside of the IBC (i.e., to the north within the City of Tustin) based on cumulative traffic impacts (e.g. traffic that may seek alternative routes due to freeway congestion, etc.). 4. A "Red Hill Avenue" traffic study was jointly conducted by the City of Irvine and City of Tustin that includes further definition of traffic mitigation responsibilities for development projects in the IBC. That study, however, did not necessarily include the most recent land use changes that have occurred in the City of Irvine. Nevertheless, the proposed Ms. Pam Davis NOP For Irvine HCG Project August 8, 2007 Page 3 Project should be subject to the findings, requirements, and agreements that will ultimately result from the Red Hill Avenue study. The intersection analysis in the DEIR will also need to be consistent with the Red Hill Avenue study. 5. It must be confirmed that the traffic model used to analyze future conditions accurately reflects the most current land use approvals (i.e. residential uses in the IBC, the most recent MCAS Tustin Reuse project plans, any other significant projects in the area, changes in background traffic that have occurred since the most recent IBC traffic studies, etc.). 6. There was a signal progression study completed for Barranca Parkway that assured adequate traffic operations on that roadway based on planned roadway designs and future traffic projections. Given the proposed increases in trip generation associated with the proposed Project, it must be verified that adequate signal progression along Barranca Parkway will be maintained and any needed mitigation measures made a condition of the Project. 7. Analysis of future conditions should include any intersections in the City of Tustin that may be significantly impacted by traffic from the Project. The amount of Project traffic traveling through these study intersections should be identified. 8. There should be mitigation measures required of the Project to provide "fair share" contributions for traffic impacts within the City of Tustin. 9. For locations within the City of Tustin, the traffic analysis must be based on City of Tustin criteria and methodologies. Thank you again for the opportunity to provide comments on the NOP for the Irvine HCG Project. The City of Tustin would appreciate receiving all additional environmental documents with the responses to our comments when they become available and all future public hearing notices with respect to this Project. If you have any questions regarding the City's comments, please call me at (714) 573-3016 or Dana R. Kasdan, Engineering Services Manager at (714) 573-3171. Sincerely, Scott Reekstin Senior Planner cc: Elizabeth A. Binsack, Community Development Director Dana Kasdan, Engineering Services Manager Douglas Holland, City Attorney SR:environ/Irvine/nopirvineHCGComment Letter.doc