HomeMy WebLinkAboutCOMMENT LETTER PC2 RECEIVED FROM KIMCO REALTY 4-24-18 Comment Lefter PC2 received from Klimco Realty, dated Apel l 24, 2018 (3 Pages)
RECEIVED
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EVERYb NG-
............................................................. ..........
2429 RaOk Aveoue I Tusfiii,i GA 912782-2705,
April 23,,2018,
Eliiz,zbeth Binsack
Community Development Director
City of Tustin
Centennial Way
Tusti
n#CA,927'80
Cornments,to Draft,Downtown cornmercial Core Specific Plan
Dear Elizabeth,
Kjrnco Realty,Corp.and'Pry dential Global Investment Management own and operate,the,Larwin Square
S,hopping Center locatedlatNiewport Ave.and First Streetin Downtown Tust1q,CA.Kirnco,Reallty Corp.
received notice that the draft ofthe Downtown Commercial Core Specific!plan was to be,reviewed by
the public at the Planning Commission,meeting on April 10,,2018,and was subsequientlypostponed to,
April 24,2,018.We've reviewed the Specific flan document,andwanted to send,you Kimclo Recalty
Corp"s comments prilor to the Planning Commission meeting.
First of all we'd 111 is the l y Ileffbrtsto create,the,Specific Plan,and we support,the goa I of
revitailizing,Tusdn's,Downtown Commercial Core area with mixed-ose redevelopments tricluding retall",
cornmercial,and multi-framily resp dlential.As,wevepreviously,discjussed,,in,the,near future Kirnco Realty
Corp.,would ll e, redevelop pOrt M,$Of ILaiMinSquare,alo,q First, Street with retail and multil-'farnily
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reshe n'tial mixed-use.Ho(wever,we have some cerns about the draft Specific Plan which we've
outlined below',
don't believe that 200 multiJarnily residential units a111atedfor,Development Area 3(DA-3)
which,includes Larwin Square and other properties north, of First,Street,Is,sufficient.fur Internall
mixed-use,design studies,andfinancial pro formas have,deterrn'ined that a mixed-use
redevelopment of our property al'ong First Street wou'jld require 200-250 apartment units,to be
fi "t'al'lly,f'Oasii .If we,were to,develop that many residentialunits'at Larw",'ib Square,there
Il n' be any remaillning units'to,allocate to the oIr propertles,in,DA-3 north of First Street.
Therefor we respectfoilly request,that the number of residential units allocated to DA-3 be
increasecl.
2. The proposed 4—story build'ing,height limit.in the Specific Plan limits density,to 3,levels of residential
abovegrioundl floor,re /cpm rnercial space,,,Our design st ud Iles show that this would only'
accommodate approximatejly 150 apartment,units,at Larwin Sq,uare,along First Street*whIlich, is,not
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economically'feasible.,We request that,the Clity cdler onsia 6-story Miiiaheight,limit which would ,
all 5 levels,of'residential above ground Abor,retail/1commerciali,This building height would
accommodate 250,units,at Larwin Square,which Is econornically feasible.The Increased building
height would:also inane the mixed-use redeveiopment of other properties in the Downtown Core
more eco n6rnicaIlyfeasible.
3. The residential parking requirement of 2 spaces per unit for residents plus 114 space per unit for
visitors is too,rnuch based upon current panting studies.The cost of tonstructing parking structures I
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has become,e trernely expensive,and requiring too much parking for.residential uses will financially
prohibit the very inured-use development-that the Downtown Cornrherclal Core Specific Plan is
trying to create.Recent-Audies.show that with'the increased.use.of ride-sharing,liber,and L ft,the 4
current parking demand for multi-fa-mily residential has decreased to an average of 1.5 spaces per
apartment unit.we strongly recommend adopting the current residential parking standard of 1-.
spaces per unit which will help:to make rhixed=use developrrient in-the Downtown Commercial Core
economically viable;
. The Specific Plan proposes to r6duce-the number of traffic lanes on First Street foam 4 lanes to 2,,
with 2 traffic lanes being.replaced by,bicycle lanes and angled street-parking.This will significantly
reduce custornertraffic from First Street to Larwin Square.
a. We#re also concerned,that the reduced number of traffic,lanes on First Street will increase
the nurnber of vehicles cutting through our shopping c rater.o.get from Centennial Way-to
Newport Avenge. r
b. We also have questions about haw.the reconstruction of First ttreet will be accomplished.it
would-be best if the City were to reconstruct First Street at one time to provide the on- �
street parkin&bicycle lanes,bus stops enclosukes,sidewalk improvements,and street �
furnishings within the public Right-Of-Way;to create the pedestrian friendly environment
described in the Specific Plan.Otherwrise,.If the City intends to require theproperty owners
to reconstruct sections of First-Street,and the ped6strian sidewalk improvem eints along
their'property frontage,when the Individual property owners seek approval of separate
mixed-use redevelopment permits;we're concerned that First Street will be in various
stages of reconfiguration and construction for the next 10 years or more.
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S. Our Larwin-Sq ua re Shopping Center is bounded on 3 sides by Newport Avenue,Fiat Street,and �
Centennial My.If we were required to fund irnpr_ovr rune rits-on al 13 streets as part of proposed �
mixed-use development along First Street,it would disproportionately burden the project,and make 6 +
it financial ly,ur'feasible,we would request that any cedevelopment'be required to help fund
improvements to.only the street frontage which the mined;use redeirefapment building faces. '
. The Public-Improvernents Funding Matrix In-Section 6 of the pgciflc`Plan proposes that 94%of the �
primary funding source,and 63%of the recon'd5ry funding sources for'all of the num ei rvus public
improvements,infrastructure improvements,and private property improvements described in detail 7
for the Downtown Commercial Core will be from developers,property owners,and business
owners.
a. Development Agreements with the City gill.require develope rs and prP perty owners to'fund �
{
100 of'the-public and private improvernents along their street:frontage in exchange for the
City's discretionary approval of-.their proposed deyelopment projects.
b. Assess rnents+for public irnprove rnents through Business Improvement Districts,Cornrnunity 7 writ. �
Facilities Districts,Landscape and Lighting Districts;M aintenance Assessment Districts;Parking i
lnfrastructure'Di tric s;and Enhanced Infrastructure Financing Districts will al be funded 100% i
by property owners,and business,o ne.rs.
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c. Even 86%of the,pr1hroary funding from the,Cfty is projectedto come from Development Impact
Fees which,the City coffects from developers as a,requiremep lIpproposed
develo; me
ent prmits-
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le und. Werespectfuly recommend that the City consider other primary, and secand,,,arysourc s tof,
nurnerous IIps ovement','s described In the Spec"J"fic Plan.Otherwise,,recilui6ng,'the vast
majority,of'Improveements,to,6e fun:1dedi bydevelopers,property owners,artdl businessowners 7 cont
will Prohibit the tVpeof mixed-use development in the Downtown Commercial Cbre area that
the Specific Plandis tryIng to cjrjeatedecrees ethe sai,,Ies,revenue o�f'b�us,,In,es,,,�s,olw�,n�e,r,si In the
Downtown Core,- r
dlec,"ease thie sales tiax revenue tothe City generatedby thase bus,iness
lowners.,
Again,,we support the creation of the Specific Plan anid Its goal'to revitalize the IDowntown Commercial
Core.We apprediate your consilideration of our comments,and concerns i an;,d hope thely can be
addressed in,the final Specific Plan.11 would be happy ,meet with you at your convenlience, discusS,
any of these cornments.
Best,Regards,
ell, 0000'
Mark Wen—del
Director legion
O"000"w"'wr ej(rmt.%A, Oinz
KIMCO' *EVERY'DA
IV
Office:(949,,)425243870 U, Cell:(949.),343-1,815
cz, j
Fax,(5 16)336-5549 '1,, Cisco,51,23870
2429 Park,Avenue, I� TILISfint,CA 92TV,2-2705.
Cc: Jeff'ParkerJusIttn CltyManager
SO
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Response to Comment Letter PC2 received from Kimco realty, dated April 24, 201 1 page)
Comment t:The commenter states that they support the goal of revitalizing Tustin's Downtown Commercial
Core (DCC) area with mixed-use redevelopments including retail, commercial, and multi-family residential.
The commenter represents Kimco Realty Corp. and would lire to redevelop portions of Larwin Square
along Fiat Street, Newport Avenue, and Centennial Way with retail and multi-family residential mixed-
use.The commenter expresses some concerns about the draft Specific Plan,outlined below.
Response 1:The City appreciates this comment. Individual comments erre addressed below and the
comments will be forwarded to the decisionmakers for their consideration.
Comment ;The commenter states that 200 residential units allocated to DA-3 are not sufficient. Bused on
their pro-forma, 200-250 units are financially feasible at Laren Square alone, and therefore, there
wouldn't be any remaining units to allocate to the other properties in DA-3 north of Fiat Street.The
commenter requests that the number of residential units allocated to DA-3 be increased.
Response : This is not a comment on the adequacy of the DP EIR.The DP permits the transfer of
additional residential allocation from the other Development Areas within the plan to support the number
of units desired, assuming that the project proposed at Larwin Center is a superior project.
Comment :This comment requests that the City consider increasing the height limit in DA-3 from 4-story to
-story.The increased -story building height limit would callow 5 lever of residential above ground floor
retail/commercial, allowing 250 units to be accommodated at Larwin Square instead of the maximum 150
units accommodated by a -stone height restriction.
Response :This is not a comment on the adequacy of the DCCSP E1R. City staff believe the requested
height limit change would not be in keeping with the historic or proposed built environment in the area;
however,this comment will be forwarded to the decisionmal ers for their consideration.
Comment ;The commenter states that the residential purring requirement of 2 spaces per unit for
residents plus 1 .4 space per unit for visitors is too much based upon current parking studies.The
commenter strongly recommends adopting the current comment is referenced parking demand for multi-
family (apartment) residential parking standard of 1.5 spaces per unit, which will help to mare mixed-use
development in the DCC economically viable.
Re-sponse : This is not a comment on the adequacy of the DCCSP EIR. City staff believe the requested
reduction in parking is not in keeping With the community's experience with existing and new residential
parking requirements; however,this comment will be forwarded to the decisionmarers for their
consideration.
Comment : The commenter is concerned that the reduced number of traffic lanes on First Street will
increase the number of vehicles cutting through the shopping center to get from Centennial Way to
Newport Avenue.The commenter also has questions about how the reconstruction of First Street will be
accomplished and is concerned that First Street will be in various stages of reconfiguration and construction
for the next 10 gears or more.
Response :The specific configuration of future charges to First Street will be informed by a corridor
specific traffic study in order to balance the needs of all users. For example,turnouts can be provided for
OCTA buses so that traffic can safely pass the bus while loading and unloading passengers.There is no
pending project and specific configuration of future changes to First Street.The potential for localized
impacts will continue to be addressed on a project-by-project basis, and are discretionary projects subject
to CEQA, at such time that they are proposed. Construction implementation and phasing is determined at
implementation, based upon availability of City resources and funding.
Comment :The commenter states that Larwin Square Shopping Center is bounded on 3 sides by Newport
Avenue, First Street, and Centennial Way.Therefore,the commenter is concerned that if they were
required to fund improvements on all 3 streets as part of a future mined-use development along First
Street, it would disproportionately burden their project, and ma ke it f inancia11y unfea ible.The commenter
requests that any redevelopment be required to helix fund improvements to only the street frontage which
the redevelopment building would face.
Response :This is not a comment on the adequacy of the DCCSP EIR.Any project-level improvements
would be determined as part of the project entitlement review and considered in the context of the
existing condition,General Plan and DCCSP requirements.This comment will be forwarded to the
decisionmakers for their consideration.
Comment :The commenter summarizes several public and private improvements outlined in the Public
Improvements Funding Matrix of Section 6 of the DCCSP.The commenter requests that the City consider
other sources of f un d ing for the numerous improvements described in the DCCS because requiring the
majority of improvements to be funded by developers would make mixed use development cost
prohibitive and decrease sales tax revenue.
Response :This is not a comment on the adequacy of the DCCSP FIR.This comment will be forwarded to
the decisionmakers for their consideration.
Comment : The commenter states that they support the creation of the DCCSP and its goal to revitalize
the DCC.
Response : The City appreciates this comment.This comment will be forwarded to the decisionmakers for
their consideration.