HomeMy WebLinkAbout10 TUSTIN RESPONSE TO DPEIR CITY OF SANTA ANADocuSign Envelope ID: 6DF2E785-1C36-43E4-8107-3423B3795F86
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AGENDA REPORT
SEPTEMBER 15, 2020
MATTHEW S. WEST, CITY MANAGER
COMMUNITY DEVELOPMENT DEPARTMENT
Agenda Item 10
Reviewed.-
City
eviewed.City Manager
Finance Director N/A
TUSTIN RESPONSE TO DRAFT PROGRAM ENVIRONMENTAL
IMPACT REPORT FOR THE CITY OF SANTA ANA GENERAL PLAN
Tustin City Council concurrence is requested for the City of Tustin's (the City) response
to the Draft Program Environmental Impact Report (DPEIR) for the City of Santa Ana
General Plan.
The proposed General Plan will guide the City of Santa Ana's development for the next 25
years and envisions up to 36,261 additional housing units, 5,849,220 square feet of
additional nonresidential space, and 11,436 new jobs between 2020 and 2045. As
proposed, 13,438 of these housing units and 2,645,721 square feet of the commercial
space could be built in close proximity to Tustin within the approved Metro East Overlay
Zone and the proposed 55 Freeway/Dyer Road Focus Area.
RECOMMENDATION:
That the City Council direct staff to forward the attached response letter to the City of
Santa Ana.
FISCAL IMPACT:
Fiscal impacts associated with this action are unknown at this time.
CORRELATION TO THE STRATEGIC PLAN:
Staff's review of the DPEIR for the City of Santa Ana General Plan falls under Goal D of
the Strategic Plan pertaining to strong community and regional relationships. The City
strives to work collaboratively with agencies both within and outside Tustin on issues of
mutual interest and concern.
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City Council Agenda Report
City of Santa Ana General Plan
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BACKGROUND:
The proposed City of Santa Ana General Plan will guide the City of Santa Ana's
development for the next 25 years and will provide options to increase development
potential in several areas of the City while bringing the City into compliance with recent
state laws and reflecting community input and updates to current conditions.
The proposed General Plan envisions up to 36,261 additional housing units, 5,849,220
square feet of additional nonresidential space, and 11,436 new jobs between 2020 and
2045. As proposed, 13,438 of these housing units (includes The Bowery — Red
HilINVarner project) and 2,645,721 square feet of the commercial space could be built in
close proximity to Tustin within the approved Metro East Overlay Zone and the proposed
55 Freeway/Dyer Road Focus Area.
City staff has reviewed the subject DPEIR. Based on concerns related to traffic,
cumulative impacts, and impacts to City parks, staff believes that it is in the City's interest
to be on record regarding this matter and has prepared correspondence (Attachment A)
expressing the City's concerns regarding the DPEIR (hyperlink - Attachment B). Staff
requests that the Tustin City Council review and consider these comments and, if
acceptable, concur with their formal transmittal to the City of Santa Ana.
S(h� �ivu 09/09/20 20 Y. O we, 09/09/20 20
Scott Reekstin Justina L Willkom
Principal Planner Acting Community Development Director
Attachments:
A. Draft Comment Response Letter
B. DPEIR hyperlink: City of Santa Ana General Plan DPEIR
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ATTACHMENT A
DRAFT COMMENT RESPONSE LETTER
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September 16, 2020
Mr. Verny Carvajal
Principal Planner
City of Santa Ana
Planning and Building Agency
PO BOX 1988 (M-20)
Santa Ana, CA 92702
SUBJECT: REVIEW OF DRAFT PROGRAM ENVIRONMENTAL IMPACT REPORT FOR THE CITY OF
SANTA ANA GENERAL PLAN
Dear Mr. Carvajal:
Thank you for the opportunity to provide comments on the City of Santa Ana General Plan Update and the
Draft Program Environmental Impact Report (DPEIR) for the City of Santa Ana General Plan Update (State
Clearinghouse #2020029087). According to the DPEIR, the proposed General Plan will guide the City of Santa
Ana's development for the next 25 years and will provide options to increase development potential in
several areas of the City of Santa Ana while bringing the City of Santa Ana into compliance with recent state
laws and reflecting community input and updates to current conditions.
The proposed General Plan envisions up to 36,167 additional housing units, 6,819,422 square feet of
additional nonresidential space, and 14,362 new jobs between 2020 and 2045. As proposed, 13,438 of these
housing units and 3,604,556 square feet of the commercial space could be built in close proximity to Tustin
within the Metro East Overlay Zone and the 55 Freeway/Dyer Road Focus Area.
The City of Tustin offers the following comments at this time:
1. Implementation Actions — The Draft General Plan Update states that the Implementation
Actions will be provided in a future draft. These Implementation Actions are a critical
component of the General Plan Update and must be identified for the public to adequately
review the impact of the General Plan Update on the community. The Implementation
Actions are also related to measures identified in the DPEIR to mitigate the potential
environmental impacts of the General Plan Update. Without the disclosure of these
Implementation Actions, a complete and accurate review of the General Plan Update's
environmental impacts cannot be achieved. Therefore, the DPEIR and Draft General Plan
Update should be recirculated for public review once the Implementation Actions have been
identified.
2. Land Use Intensification — The City of Tustin is concerned with the significant changes in
land uses (i.e., from commercial and industrial buildings to residential mixed use) along Red
Hill Avenue and Dyer Road that are proposed by the Santa Ana General Plan Update, the
Bowery -Red Hill/Warner project, or that have occurred recently with the approval and
construction of The Heritage project at 2001 East Dyer Road. These land use changes could
result in significant traffic and park impacts in addition to undermining the effectiveness of
planned roadway improvements in Tustin which were designed to mitigate the impacts of
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Santa Ana General Plan DPEIR
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other development projects. In particular, the recently constructed fourth northbound
through lane improvement to Red Hill Avenue was to address impacts from the Irvine
Business Complex as well as accommodate future Tustin Legacy development and traffic
diversion from SR -55 Freeway. The cumulative impacts of Santa Ana's projects to traffic and
parks are likely to be substantial. Although the DPEIR acknowledges these concerns, the
cumulative impacts related to traffic and parks have not been adequately addressed,
studied, or mitigated in the DPEIR as described in the comments below.
3. Land Use and Planning (RTP/SCS Consistency Goal 6) — RTP/SCS Goal 6 requires an
equitable distribution of resources. Despite adding 8,731 residential units in the 55
Freeway/Dyer Road Focus Area in the General Plan Update, there are no recreation or open
spaces planned in this area. The General Plan Update is therefore inconsistent with the
RTP/SCS Goal 6.
4. Land Use and Planning (Compatibility of Uses) — Land Use Element Policy 1.1: Compatible
Uses aims to enhance livability and promote healthy lifestyles. The General Plan Update,
however, introduces residential uses alongside light industrial and commercial uses within
the 55 Freeway/Dyer Road Focus Area. It is unclear how land uses such as industrial and
residential will co -exist directly adjacent to one another given that normal industrial
operations typically generate noise, safety, and air quality impacts that are not compatible
with residential uses. The General Plan Update therefore creates land use compatibility
issues that are not addressed in the DPEIR.
5. Land Use and Planning (Mobility) — Land Use Element Policies 1.7 and 1.9 require Active
Transportation Infrastructure while Circulation Element Policies 1.6 and 3.7 require
Complete Streets. A significant portion of the 55 Freeway/Dyer Road Focus Area, however,
does not have sidewalks. This creates a mobility issue for future residents. No plan is
identified or required in the General Plan Update or the DPEIR, nor thresholds requiring
public right-of-way enhancements within the area, to facilitate the projected population
growth allocated to the Focus Area. Project -by -project adjacent improvements are not likely
to be adequate in addressing the demands associated with the significant population
growth. The lack of a mobility plan for the Focus Area is inconsistent with the General Plan
Update policies listed above. The DPEIR and General Plan Update should be revised to
address this issue.
6. Population and Housing (Impact 5.13-1) — Table 5.13-8 identifies that the largest gross and
percentage population growth (244%) among the proposed focus areas will occur on the
boundary of Santa Ana and Tustin in the 55 Freeway/Dyer Road Focus Area. This growth
projection may be understated, because it appears that the existing population (9,034)
count within the 55 Freeway/Dyer Road Focus Area is overstated given that the Heritage
project appears to be the only existing residential land use within the Focus Area. Please
confirm the accuracy of the existing population in the Focus Area.'
1 Some of the existing population may reside at the Heritage project on Dyer Road which introduced
residential development into the predominately industrial and commercial area through what could be
considered spot zoning, and does not constitute a pattern of existing residential use.
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September 16, 2020
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As noted on Page 5.13-14 of the DPEIR, "the purpose of general plan updates is to
accommodate increased growth in a responsible manner. The GPU accommodates future
growth in the City by providing for infrastructure and public services to accommodate the
projected growth." Unfortunately, when identifying the relevant infrastructure and public
services to accommodate future population growth, Open Space Element Policies are
notably absent. The General Plan Update's reasonably foreseeable impacts to Tustin have
not been addressed. No mitigation is offered to accommodate potential future growth and
the DPEIR simply notes this impact as significant and unavoidable. This approach does not
accommodate future growth in a responsible manner. Mitigation measures should be
identified in the DPEIR to address the impacts of future population growth, particularly in
the 55 Freeway/Dyer Road Focus Area. These mitigation measures should require the
development of a vision plan or master plan for the Focus Area within a reasonable
timeframe that identifies minimum requirements for parks and open space, sidewalks, and
other infrastructure to adequately support the population growth and serve the residents
within the Focus Area. Santa Ana should commit to implementing this mitigation in the
DPEIR and Mitigation Monitoring and Reporting Program.
7. Population and Housing (Impact 5.13-2) — Table 5.13-10 is misleading because it says that
there are zero existing and proposed residential acres within the 55 Freeway/Dyer Road
Focus area. The bulk of the General Plan Update's population growth, however, occurs
within this Focus Area including the addition of 8,731 additional residential units beyond the
1,221 units recently introduced at the Heritage project on Dyer Road. Further, the District
Center Land Use Designation clearly allows for and encourages residential uses. Table 5.13-
10 should be revised accordingly.
8. Recreation — Resident feedback within the Community Outreach — The First Conversation
Executive Summary noted the lack of open space, need for better park maintenance, lack of
community centers, and unsafe parks within Santa Ana. The DPEIR and Draft General Plan
Update, however, do not require or identify any park land to be provided within the 55
Freeway/Dyer Road Focus Area.
The Santa Ana General Plan Update should require land for park and recreational purposes
to meet the City of Santa Ana's minimum standard of "two (2) acres of property devoted to
parks and recreational purposes for each thousand (1,000) persons residing within the City
of Santa Ana." There is an average 2018 household size of 4.5 persons in the City of Santa
Ana per the Southern California Association of Government's 2019 Profile of the City of
Santa Ana. This equates to a minimum of approximately 89.6 acres of new parkland needed
to serve the 9,952 housing units projected at build -out for the Focus Area, as there are no
park facilities currently existing in the 55 Freeway/Dyer Road Focus Area.
The City of Santa Ana Municipal Code requires residential projects to pay park acquisition
and development fees or dedicate land for park and recreational purposes. Private open
space and perimeter open space is not equivalent to park land. The Bowery project is a
recent example where Santa Ana erroneously counted balconies and walkways within the
private development towards "parkland." This approach should be discontinued
immediately.
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It is also notable that the Santa Ana goal of two (2) acres per 1,000 residents falls short of
the widely held minimum standard of three (3) acres per 1,000 residents as established
under the Quimby Act. (Government Code § 66477). As shown in the table below, the
minimum General Plan park acreage goals of many surrounding jurisdictions are higher than
that of Santa Ana.
City
General Plan Minimum Parkland Acreage Goal
Costa Mesa
4.26 acres per 1,000 residents
Fountain Valley
13.2 acres per 1,000 residents (existing); 3-5 acre goal
Garden Grove
2.0 acres per 1,000 residents for parkland; 5.0 acres per
1,000 residents for open space
Irvine
5.0 acres per 1,000 residents
Orange
3.0 acres per 1,000 residents
Santa Ana
2.0 acres per 1,000 residents
Tustin
3.0 acres per 1,000 residents
Westminster
3.0 acres per 1,000 residents
Nonetheless, Policy 1.4 — Park Connectivity of the Open Space Element from the Santa Ana
General Plan Update Policy Framework (GPPF) proposes to establish and enhance options
for residents to access existing and new park facilities through safe walking, bicycling, and
transit routes. Within the 55 Freeway/Dyer Road Focus Area, there is a fragmented and
otherwise absent sidewalk network. Further, the SR -55 Freeway creates a physical barrier to
pedestrian and bicycle linkages with other Santa Ana neighborhoods for those properties in
the Focus Area currently proposed for residential uses. In addition, there are no planned or
existing parkland facilities within that Focus Area.
As noted on page OS -03 of the City of Santa Ana General Plan Update, Community outreach
received during all stages of the General Plan Update preparation identified Santa Ana
residents' need for additional and better park facilities. Based on the resident feedback,
residents within the Focus Area will use Tustin Legacy park facilities due to their close
proximity, convenience, safety, and likely enhanced level of maintenance compared to Santa
Ana park facilities. Thus, it is reasonably foreseeable that the 8,731 additional residential
units allocated to the 55 Freeway/Dyer Road Focus Area in the General Plan Update will
increase park demand in Tustin. The closest park facilities are across Red Hill Avenue within
Tustin Legacy. These park facilities are within both biking and walking distance of the Focus
Area. This will place an unplanned and undue burden on Tustin Legacy facilities.
In addition to proximity, the analysis in the DPEIR should consider the quality, amenities, and
attractiveness of nearby parks when estimating park usage. For example, the proposed
Veterans Sports Park at Tustin Legacy will be three times larger and about half the distance
from the Focus Area than the closest park in Santa Ana, and will offer new, state of the art
facilities that will be attractive to park users.
If additional, sufficient parkland is not identified in the General Plan Update, residents of
future Santa Ana projects will overburden parkland facilities in adjacent jurisdictions,
including Tustin, resulting in the physical deterioration of those facilities. These reasonably
foreseeable, significant impacts must be identified and mitigated in the DPEIR. The analysis
in the DPEIR of the proposed compliance with the City of Santa Ana's park standards should
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be revised to focus on the potential to physically deteriorate existing and future recreational
facilities in the City of Tustin.
At best, the DPEIR recognizes the potential for impacts "onto adjacent communities with
regards to parks and open space utilization." The DPEIR, however, fails to acknowledge that
these impacts will be significant and further fails to provide enforceable and feasible
mitigation for those impacts. The DPEIR states that "the City (of Santa Ana) is committed to
working closely with cities located adjacent to General Plan Focus Areas when preparing the
City of Santa Ana's Parks and Recreation Master Plan to ensure that the Dyer/55 Focus Area
and other growth areas of the City provide additional recreation, parks, and core services
essential in making complete communities." While Tustin appreciates this sentiment, this
vague and unenforceable statement does not mitigate the reasonably foreseeable,
significant impacts to recreational facilities in Tustin. The DPEIR should include a mitigation
measure that requires the City of Santa Ana to prepare a Parks and Recreation Master Plan
and to require that park land be secured or provided in conjunction with future residential
or residential mixed use projects within the 55 Freeway/Dyer Road Focus Area prior to the
approval of any additional residential units within the Focus Area.
9. Parks and Open Space Studies - A comprehensive study of parkland demand should be
conducted to evaluate the extent of the impacts of the General Plan Update on Tustin
facilities. It is recommended that the minimum park facilities as required by the General
Plan be accommodated within the 55 Freeway/Dyer Road Focus Area. Thresholds tied to
the development and upzoning of any properties requiring a minimum amount of park land
per residential unit should be required to ensure the development of the minimum parkland
facilities within the Focus Area. The PEIR should also include a study that analyzes how far
residents in a suburban community are willing to travel, by foot and by vehicle, to reach a
community park.
10. Recreation — (55 Freeway/Dyer Road Focus Area) — It is noted in the DPEIR that there are no
parks in this Focus Area and existing open space consists of railroad lines and a concrete
channel, which should not be considered as useable open space.
Table 3-5 of the DPEIR identifies that Open Space will occupy only 1.1 acres or 0.3% of the
Proposed Land Use within the Focus Area. This is especially troubling given the following
statement in the DPEIR, "Little current or future potential exists for the acquisition of
additional park lands and open spaces, both because the city is almost fully developed and
because demands on capital funds are highly competitive." This clearly shows that the City
of Santa Ana does not plan to develop public parkland within the Focus Area. It further
brings into question how the City of Santa Ana intends to use in -lieu park fees collected from
development if they are not going to be used for the acquisition of park land within the
Focus Area.
These statements within the DPEIR only further demonstrate that the burden of required
recreation space to support the proposed residential growth within the Focus Area will be
borne by adjacent cities such as Tustin. Without a commitment to provide park space within
the Focus Area, the proposed General Plan Update is not in compliance with Land Use
Element Policy 1.3: Equitable Distribution of Open Space nor is it in compliance with
Community Element Policy 1.5: Equitable Recreation Spaces.
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11. Recreation — (Environmental Impacts) — Table 5.15-4 identifies the buildout potential of an
additional 96,885 residents by 2045. The parkland acreage at buildout to accommodate
these additional residents is only projected to increase by 1.84 acres, whereas, by the City of
Santa Ana's standards, 193.77 acres of new parkland would be required.
The approach to meeting this required parkland acreage is unclear. No strategy for future
public parkland is identified. If the assumption is that future development will provide all
required parkland on-site as private property, then that concept should be stated as an
absolute requirement in the General Plan Update and in -lieu fees should not be an available
mitigation. Pushing off the parkland requirements to each individual development project
and allowing payment of in -lieu fees ignores the cumulative impacts of delayed
implementation and is not a sustainable approach to accommodating future growth. This
approach simply ignores the lack of open space and recreational facilities needed within
Santa Ana.
This clear exacerbation of the parkland deficiency to well -below the existing deficiency
cannot simply be disregarded as a less than significant impact. The General Plan Update is
not in compliance with Land Use Element Policy 1.9: Public Facilities and Infrastructure, as
new developments will clearly compound existing public facility and service deficiencies as
identified in the DPEIR.
12. Recreation — (Quimby Act) —The DPEIR identifies the Quimby Act's standards and notes that
"Cities and counties with a lower ratio can require the provision of up to three acres of park
space per 1,000 people;" however, the City of Santa Ana chooses to impose a lower
threshold of two acres per 1,000 persons. The DPEIR continually references the existing
Municipal Code requirements for parkland as if the Santa Ana Municipal Code somehow
supersedes the General Plan as a guiding document. The park land requirements of the
Santa Ana Municipal Code do not adequately address the park land deficiencies and goals
for additional park land that are identified in the City of Santa General Plan Update.
Santa Ana residents have said that the lack of open space and recreational opportunities
within the City are a problem. Yet, there is little identifiable aspiration to provide the
minimum standard of parkland that is provided in adjacent jurisdictions. Based on the
intense allocation of residential units, and the lack of planned new open space to
accommodate those residential units, it is reasonably foreseeable that the recreation
facilities in adjacent jurisdictions such as Tustin will be overburdened and will physically
deteriorate as a result.
It should also be noted that the Quimby Act is applicable to subdivisions whereas the
majority of proposed residential units are presumed to be apartments which may not
require subdivision. Santa Ana's heavy reliance on privately provided parkland dedication
utilizes a standard which is below that identified in the Quimby Act. This leads to inequities
for Santa Ana residents when compared to neighboring jurisdictions and will likely force
Santa Ana residents into neighboring cities to meet their recreation and open space needs.
Without a public parkland plan in place, it is at best unclear how the recreation standards
will be met.
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13. Recreation (Regulatory Requirements) — Mandatory fees as a substitute for providing
parkland for new residential development will likely do little to address the significant
impacts caused by the increase in residential units and the parkland deficiency in the 55
Freeway/Dyer Road Focus Area. Chapter 35, Article IV of the Santa Municipal Code does
not require that Park Acquisition and Development Funds be spent within the Focus Area to
benefit new residents even though no current recreation facilities exist.
It is noted in the DPEIR that "At the General Plan level of analysis, it is speculative and
infeasible to evaluate project -specific environmental impacts associated with the specific
construction of future park and recreational facilities since specific sites and time frames for
development are unknown. When specific projects are necessitated and subsequently
undertaken to meet the growth demands from buildout of the General Plan update, the
appropriate level of analysis required under CEQA would be conducted by the City's Park,
Recreation, and Community Services Agency." While the General Plan Update has a clear
vision for land use development, there is no clear vision for additional parkland as should be
required in the General Plan Update. Designation of property for Open Space within the
Focus Area is an appropriate General Plan Level activity. The City of Santa Ana continues to
approve projects in the Focus Area, such as the Heritage and Bowery -Red Hill/Warner
projects, without evaluating the cumulative impacts of additional residential units and the
deficiency/non-existence of recreation facilities. The DPEIR and General Plan Update should
identify and commit to the development of new park facilities in the 55 Freeway/Dyer Road
Focus Area to meet the demand created by new residents and to mitigate the potential
impacts to parks in neighboring jurisdictions. If park in -lieu fees are not eliminated in their
entirety, the General Plan Update and PEIR should be revised to state that they will be used
to acquire property for park uses east of the SR -55 where the General Plan Update already
contemplates the conversion of existing land uses in order to mitigate recreation impacts in
both Santa Ana and Tustin.
14. Affordable Housing — Although there are policies, goals, and objectives in the Santa Ana
General Plan Update that encourage the provision of affordable housing, there is no
commitment for affordable housing to be provided in conjunction with the proposed
upzoning of properties in the 55 Freeway/Dyer Road Focus Area. As noted on Page 2-10 of
the DPEIR, the lack of affordable housing within Santa Ana has also been recognized as a
concern to Santa Ana residents, but has been inadequately addressed.
It is stated on page 5.13-3 of the DPEIR that "The Housing Opportunity Ordinance (HOO)
establishes standards and procedures to encourage the development of housing that is
affordable to a range of households with varying income levels. The purpose of the ordinance
is to encourage the development and availability of affordable housing by requiring the
inclusion of affordable housing units within new developments or the conversion of rental
units to condominium ownership when the number of units exceed the densities permitted
under the General Plan." The requirements of the HOO should be applied to all new
residential development proposed within the 55 Freeway/Dyer Road Focus Area.
15. Noise - The 55 Freeway/Dyer Road Focus Area lies within the John Wayne Airport (JWA)
flightpath, with a substantial portion of the area included within the 65 dB(A) and 60 dB(A)
CNEL contours (2016 Baseline). Policy 3.1 of the Noise Element does not support residential
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development within the 65 dB(A) CNEL noise contour. The General Plan Update should
expressly prohibit residential development in the 65 dB(A) CNEL contour.
Policy 2.2, Stationary Related Noise, of the Noise Element acknowledges the conflicts
between commercial/ industrial facilities adjacent to residential development. As a result,
the policy seeks to "minimize" noise impacts from commercial and industrial facilities
adjacent to residential uses, but it provides no explanation as to how this will be
accomplished. The General Plan Update should provide direction to achieve this goal,
specifically in light of the introduction of residential uses in areas such as the 55
Freeway/Dyer Road Focus Area which currently consist of predominately office and
industrial uses.
16. Traffic/Circulation (Traffic Impact Study Area) — As noted in Section 2.2 of the Traffic Impact
Study, the City of Tustin was asked to participate in the City of Santa Ana's efforts to update
their General Plan Circulation Element and request for a Master Plan of Arterial Highways
(MPAH) amendment from the Orange County Transportation Authority (OCTA). The
requested MPAH amendment includes the reclassification of two Santa Ana streets that
could potentially impact the City of Tustin: First Street and Chestnut Avenue (Chestnut
Avenue becomes Main Street in Tustin). However, at the time that the City of Tustin
provided comments, none of the proposed General Plan Update land use changes were
shared with the City of Tustin. As a result, the City of Tustin's comments were focused on
the inclusion of certain intersections in Tustin for the purposes of analyzing the MPAH
Amendment. The current Traffic Impact Study analyzes the additional intersections as
requested by the City ofTustin.
However, to adequately assess any impacts to Tustin streets due to the proposed General
Plan Update land use changes, particularly in Focus Area 4 (55 Freeway/Dyer Road), the
Study area needs to be extended. The City of Tustin made this request in its March 26,
2020, NOP comment letter. The impacts of the traffic increases along Red Hill Avenue due to
the upzoning in the 55 Freeway/Dyer Road Focus Area at the following intersections should be
included in the trafficanalysis:
Red Hill Avenue/EI Camino Real
Red Hill Avenue/1-5 Southbound and Northbound Ramps
Red Hill Avenue/Nisson Road
Red Hill Avenue/Walnut Avenue
Red Hill Avenue/Valencia Avenue
Tustin Ranch Road/Warner Avenue North
Tustin Ranch Road/Walnut Avenue
17. Traffic/Circulation (Red Hill Avenue) - The newly installed landscaped median on Red Hill
Avenue between Warner Avenue and Carnegie Avenue currently prevents left turn ingress and
egress at driveways along the westerly side of Red Hill Avenue for the frontage of contemplated
development. Due to the high speeds and traffic volume on Red Hill Avenue that will affect
traffic flow and cause delays, the City is not supportive of an additional traffic signal to serve
proposed development, nor the installation of median breaks to provide turning movements
across the median which can create unsafe conditions. Any driveways on Red Hill Avenue to
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serve proposed development will need to only allow right -turn in and right -turn out
movements.
18. Traffic/Circulation (Red Hill Avenue Improvements) — Due to existing conditions, any significant
development or land use intensification in the 55 Freeway/Dyer Road Focus Area will require
improvements along southbound Red Hill Avenue i.e., dedicated right -turn lanes on eastbound
Warner Avenue and Carnegie Avenue at Red Hill Avenue or right -turn lanes on southbound Red
Hill Avenue at Warner Avenue and CarnegieAvenue.
19. Traffic/Circulation (Land Use and Trip Generation Comparison) — To facilitate review, a land
use and trip generation summary and a map of all focus areas comparing current conditions
and those under the proposed General Plan should be provided in the PEIR.
20. Traffic/Circulation (Newport Avenue/SR-55 Northbound Ramps -Del Amo Avenue) — The
General Plan Update also contributes to the intersection deficiency at Newport Avenue/SR-
55 Northbound Ramps -Del Amo Avenue. The mitigation identified is a second southbound
right -turn lane on Newport Avenue to northbound SR -55 ramp. Funding and implementation
of the improvements should be worked out between Santa Ana and Caltrans, because Santa
Ana projects would contribute to the deficiency, and Caltrans is responsible for maintenance
of the intersection.
21. Traffic/Circulation (Red Hill Avenue and Warner Avenue Impacts) — As noted in previous
comment letters to the City of Santa Ana, the City of Tustin is concerned about the lack of
consistency of the peak hour traffic forecasts for the Red Hill Avenue and Warner Avenue
intersection in the following studies:
1. Tustin Legacy Specific Plan (2017), City of Tustin, Stantec
2. Heritage Mixed Use Project (2015), City of Santa Ana, LLG
3. Santa Ana General Plan Update (2020), City of Santa Ana, IBI
4. Bowery Mixed -Use Project (2020), City of Santa Ana, EPD
As mentioned in the City of Tustin's comment letter to the City of Santa Ana dated August
14, 2020 regarding the proposed MPAH amendment, the impact at Red Hill Avenue/Warner
Avenue has been understated by leaving out the "Lost Time" input of 5 seconds (or .05) in
the Intersection Capacity Utilization (ICU) calculation. The "Lost Time" input is required by
both the Tustin and Santa Ana level of service analysis (LOS) guidelines. When corrected
with the lost time reflected in the ICU calculation, the General Plan Update would adversely
impact the intersection of Red Hill Avenue/Warner to an unacceptable level (i.e., ICU > 0.90)
during the PM peak hour. This impact must be mitigated.
22. Traffic/Circulation (MPAH Reclassifications) — The following comments pertain to the proposed
MPAH Reclassifications.
• Newport Avenue/SR-55 Northbound Ramps -Del Amo Avenue — The project contributes
to the projected intersection deficiency and identifies a second southbound right -turn
lane on Newport Avenue to northbound SR -55 ramp as mitigation. The DPEIR, however,
does not commit to funding for this improvement in the traffic study. Instead it states
that Santa Ana will pursue the development of a Transportation System Improvement
1519753.1
DocuSign Envelope ID: 6DF2E785-1C36-43E4-8107-3423B3795F86
Mr. Verny Carvajal
Santa Ana General Plan DPEIR
September 16, 2020
Page 10
Assessment (TSIA) for funding the improvements. Santa Ana should collaborate with
Caltrans to implement this improvement, because Santa Ana projects would contribute
to the deficiency, and Caltrans is responsible for maintenance of the intersection2045
With -Project AM ICU worksheets were missing in the appendix, and thus precluded a
complete review of the DPEIR's supporting evidence and conclusions.
• A "Lost Time" input of 5 seconds (or .05) has been erroneously left out in the
Intersection Capacity Utilization (ICU) calculation as required by Tustin and Santa Ana
level of service analysis (LOS) guidelines.
Thank you again for the opportunity to provide comments on the City of Santa Ana General Plan Update and
DPEIR. The City of Tustin would appreciate receiving early responses to our comments as well as a copy of
the Final PEIR when it becomes available in addition to all future public hearing notices with respect to this
project. Please provide all future CEQA notices regarding this project to the undersigned pursuant to Public
Resources Code Section 21092.2.
If you have any questions regarding the City's comments, please call Scott Reekstin, Principal Planner, at
(714) 573-3016 or Krys Saldivar, Public Works Manager, at (714) 573-3172.
Sincerely,
Justina L. Willkom
Acting Community Development Director
cc: Minh Thai, Executive Director, Santa Ana Planning and Building Agency
Phil Johnson, Fire Chief, Orange County FireAuthority
Matthew S. West, City Manager
Nicole Bernard, Assistant City Manager
David Kendig, City Attorney
Stu Greenberg, Police Chief
Jason AI -Imam, Director of Finance
Chris Koster, Director of Economic Development
Douglas S. Stack, Public Works Director
Chad Clanton, Parks and Recreation Director
Ken Nishikawa, Deputy Director of Public Works/Engineering
Kris Saldivar, Public Works Manager
Scott Reekstin, Principal Planner
Ryan Swiontek, Senior Management Analyst
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