HomeMy WebLinkAboutCITY RESPONSE LETTER DATED 8.6.21 Office of the City Manager
August 6, 2021
Frank Kim
Chief Executive Officer
County of Orange
333 W. Santa Ana Boulevard
Santa Ana, CA 92701
Dear Frank -
The City of Tustin (City) is in receipt of your letter dated August 4, 2021, requesting that the City
continue the August 11, 2021 meeting of City Council acting as the Federally recognized Local
Reuse Authority (LRA) for former Marine Corps Air Station (MCAS) Tustin focused on Reuse
Parcel 18. The County's reason requesting a continuance request is to discuss a "mutually
beneficial public project" use for Reuse Parcel 18 other than the approved County of Orange
(County) Regional Park.
As you mention in your letter, there have been several communications between the City and
County prior to and since the February 23, 2021 LRA meeting. City staff and the City Council
have been in regular communication with you, County staff and Supervisor Wagner's office. The
City has supported the County's proposed Regional Park since the initial reuse planning process
began over twenty-five years ago, and at the County's request, the County Regional Park was
included in the final MCAS Tustin Reuse Plan proposed by the City and reviewed and approved
by the United States. Unfortunately, the County has not moved forward to advance the County
Regional Park or to maintain and secure Reuse Parcel 18 by accepting a Navy lease or 'license.
Accordingly, as the City has indicated repeatedly, the City (acting as the LRA) cannot discuss
alternate uses for Reuse Parcel 18 until the County Regional Park is removed from the approved
Reuse Plan/Specific Plan for former MCAS Tustin or the County withdraws its original and
approved Regional Park Public Benefit Conveyance (PBC) application through the Department of
the Interior.
Both options will allow the City (acting as the LRA) to initiate a new, and likely multi-year long,
reuse planning process for the site, where the County and others will be able to submit alternative
proposals for all or portions of Reuse Parcel 18 for evaluation and consideration. Any alternatives
proposed by the County for"a mutually beneficial public project"that do not include the approved
County Regional Park, may be considered once a new reuse planning process is launched.
The City (acting as the LRA) is concerned that your August 4, 2021 letter now suggests that the
County is not willing to commit to a lease for maintenance and security for Reuse Parcel 18, nor
is the County able to move forward with planning,financing and constructing the approved County
Regional Park. The fundamental questions of the County's willingness to accept a lease for
maintenance and security, and the ability to implement the Regional Park use, have been
300 Centennial Way, Tustin, CA 92780 • P: (714) 573-3010 • F: (714) 838-1602 0 www.tustinca.org
documented in several communications from the LRA to the County, including the March 30,
2021 letter sent by the LRA following the February 23, 2021 LRA public forum. The March 30,
2021 letter (attached) requested a response within 30 days, and as of the date of this letter, no
response has been received. The lack of a response to these fundamental questions is a primary
reason for the August 11, 2021 LRA meeting.
Your letter references a "mutually beneficial public project." As has been previously
communicated to the County and noted once again in this letter,the LRA cannot consider,approve,
or make any commitments to any other use of Reuse Parcel 18 other than the County Regional
Park until the County withdraws its PBC application, or the LRA takes action to remove the
County Regional Park use from the Reuse Plan/Specific Plan and commences a new reuse planning
process for Reuse Parcel 18.
Given the reasons outlined above, the City (acting as the LRA) will be moving forward with the
August 11, 2021 LRA meeting at 3:00 PM and looks forward to County participation. The
County's August 4, 2021 letter and this response will be added to the public record for the meeting.
Should you have any questions,please contact me at 714.573-3012 or mwest(Itustinca.org.
Sincerely,
44"��/4/&4f
Matthew S. West
City Manager
Attachment: March 30, 2021 LRA Letter to County
CC' Tustin City Council
Nicole Bernard, Assistant City Manager
David E. Kendig, City Attorney
George Schlossberg, Kutak Rock
Christopher Koster, Director of Economic Development
Donald P. Wagner, Third District Supervisor
Thomas Miller, County Chief Real Estate Officer
David Siegenthaler,National Parks Service
Laura Duchnak, Department of the Navy
Charles Perry, Department of the Navy
Alexander Bethke, Department of the Navy
Amy Jo Hill, Department of the Navy
Elizabeth Larson, Department of the Navy
Kyle Olewnik, Department of the Navy
Office of the City Council
•
March 30, 2021
The Honorable Donald P. Wagner
Supervisor, Third District
County of Orange
333 W. Santa Ana Boulevard, 5`}`Floor
Santa Ana, CA 92701
Dear Supervisor Wagner:
Thank you for the County of Orange (County) presentation before the City of Tustin (City), acting as
the Federally recognized Local Reuse Authority (LRA), at the February 23, 2021, virtual community
forum for the former Marine Corps Air Station, Tustin, (MCAS Tustin), closed and available for disposal
in accordance with the Defense Base Closure and Realignment Act of 1990, as amended (Base Closure
Act).
The LRA appreciated the opportunity to discuss progress with the several public agencies designated as
property recipients at the former MCAS Tustin. The forum was an opportunity to present to the general
public the various ongoing projects and endeavors at the former MCAS Tustin, including the County's
successful development and operation of the Tustin Family Campus and the Orange County Animal Care
Facility. While the LRA applauds the County for its successes on those projects,the LRA was particularly
concerned with the testimony from Thomas Miller, the County's Chief Real Estate Officer, describing
the County's current status on meeting its commitments to acquire, develop, and operate Parcel 18 as a
Regional Park in accordance with the County's Public Benefit Conveyance (PBC) Application to the
Department of Interior's National Park Service (NPS) that was submitted in 1995.
The County's presentation and testimony to the LRA regarding Parcel 18 raised concerns and questions
that fall into two specific categories:
1. County's Plans to Acquire, Develop and Operate Parcel 18:
Pursuant to the Base Closure Act, the LRA conducted a reuse planning process that led to the LRA's
adoption in 1996 of the MCAS Tustin Reuse Plan, reviewed and approved by the United States
Department of Housing and Urban Development (HUD), and utilized by the Department of the Navy
(Navy)in its on-going MCAS Tustin disposal process. As part of the LRA's reuse planning process, the
County:
Mayor Letitia Clark • Mayor Pro Tem Austin Lumbard • Barry W.Cooper • Ryan Gallagher • Rebecca"Beckie"Gomez
300 Centennial Way • Tustin,California 92780 • www.tustinca.org
The Honorable Donald P. Wagner
March 30, 2021
Page 2
- Sought to acquire Parcel 18 to create and operate a Regional Park
- Submitted a NPS PBC Application (County PBC Application) in 1995 that was reviewed and
approved by the NPS, that identified the County funding mechanism intended to address the
costs of creating and operating the proposed Regional Park, and that was incorporated by the
LRA in the final HUD-approved MCAS Tustin Reuse Plan.
In 2012, seventeen (17) years after the NPS approval of the County PBC Application, the County
proposed an alternate County Program of Utilization(POLI)that proposed changes to the NPS-approved
County PBC Application by seeking additional and more expansive revenue-generating activities onto
Parcel 18 to subsidize the costs of creating and operating the proposed Regional Park. However, the
proposed alternate POU was never approved by the NPS,leaving in place only the original NPS-approved
County PBC Application for a Regional Park on Parcel 18. The LRA understands that in the ensuing
years, the County has faced development challenges including the partial collapse of the north hangar, a
global pandemic, the Great Recession, and recent discoveries of emerging contaminants such as
PFOS/PFAS on the former MCAS Tustin. All of these events give rise to questions concerning the future
of Parcel 18, as follows:
- Since the 2012 proposed alternate POU that was submitted to NPS was not approved, is the
County prepared to implement its original NPS-approved PBC Application for a Parcel 18
Regional Park as it is incorporated into the MCAS Tustin Reuse Plan, and do so within the next
1-3 years?
- Is the County prepared to budget, fund, and dedicate County resources to make the Parcel 18
Regional Park a reality in accordance with the County's approved PBC Application within the
next 1-3 years?
- Are on-site commercial-revenue-generating activities (that have not been approved) necessary
for the County to develop and operate the Parcel 18 Regional Park and/or to preserve the north
hangar?
- Since the NPS does not permit commercial-revenue-generating activities as part of the PBC,what
are the County's plans to develop and operate the Parcel 18 Regional Park and preserve the north
hangar?
- At the LRA meeting, the County introduced for the first time a different, unvetted proposal for
the Regional Park by introducing the concept of a"Phased, Passive Park." If the County desires
to amend its PBC Application to seek approval by the NPS for a"Phased, Passive Park" in lieu of
the Parcel 18 Regional Park, and should the LRA support it, how will the County fund this
concept and either the(i)restoration, operation and maintenance, or(ii)demolition of, the north
hangar?
The Honorable Donald P. Wagner
March 30, 2021
Page 3
- If the County desires to amend its PBC Application to seek approval by the NPS and proceed
with a"Phased, Passive Park"in lieu of the Parcel 18 Regional Park, and should the LRA support
it, when will the County hold public workshops to present the plan to the community as it did
with the Regional Park concept in 2013?
2. County's Short-Term Plans for Parcel 18:
During the last several years, there have been numerous instances of trespassing, criminal conduct and
other illicit activities taking place at Parcel 18 requiring an independent and significant City resource
response. This has been documented through several letters to the County from the City and was
discussed in the recent Orange County Grand Jury report, "What's Happening with the Historic Tustin
Hangars?" Several times during the County's presentation to the LRA, the County suggested that the
County could not proceed with a Lease in Furtherance of Conveyance (LIFOC) from the Navy in the
absence of a revised POLI that permitted on-site revenue-generating activities sufficient to support the
restoration, operation, maintenance and securing of Parcel 18 and north hangar.
However, the LRA would reiterate to the County that a LIFOC could be secured if the County were
willing to implement and fund its NPS-approved PBC Application. Even if the County were to seek
changes to its PBC Application and POLI, it would still be feasible for the County to obtain a short-term
interim lease (Interim Lease) from the Navy in order to secure and maintain Parcel 18 while these issues
were addressed while also providing appropriate performance milestones to ensure County progress.
Such an effort (either LIFOC or Interim Lease) would be consistent with what all other designated
property recipients at the former MCAS Tustin have committed to while awaiting final fee conveyance
from the Navy. Accordingly, the LRA requests the County please address the following:
- Is the County willing to accept, without further delay, a LIFOC and assume site control of Parcel
18 from the Navy in order to safely secure and maintain the property while it proceeds to develop
a Regional Park under its NPS-approved PBC Application?
- Or is the County willing to accept, without further delay, an Interim Lease with specific
performance milestones and assume site control of Parcel 18 from the Navy in order to safely
secure and maintain the property to demonstrate its commitment to construct a passive park,
while it seeks to amend its approved NPS PBC Application?
On behalf of the City and the greater Tustin community, the LRA continues to stress the importance of
committing to the maintenance and security by designated property recipients of all property at former
MCAS Tustin. If the County is not willing to assume site control under a LIFOC or Interim Lease (and
thereby fails to demonstrate its commitment to develop the Regional Park), the LRA will be prepared to
evaluate all courses of action available and necessary to ensure that Parcel 18 is maintained, secured, and
advanced in a timely manner.
The Honorable Donald P. Wagner
March 30, 2021
Page 4
The City, acting as the LRA, requests written responses from County representatives to the questions in
this letter within thirty (30) days of receipt. Responses will be added to the LRA record, and will be
considered by the LRA in determining the need for additional LRA Public Forum(s) focused on Parcel
18.
Sincerely,
Letitia Clark
Mayor
cc: Tustin City Council
Matthew S. West, City Manager
Nicole Bernard, Assistant City Manager
David E. Kendig, City Attorney
George Schlossberg, Kutak Rock
Christopher Koster, Director of Economic Development
Frank Kim, County CEO
Thomas Miller, County Chief Real Estate Officer
David Siegenthaler, National Parks Service
Laura Duchnak, Department of the Navy
Charles Perry, Department of the Navy
Alexander Bethke, Department of the Navy
Amy Jo Hill, Department of the Navy
Elizabeth Larson, Department of the Navy
Kyle Olewnik, Department of the Navy