HomeMy WebLinkAbout5.0_Attachment_011 - EIR Response to Comments Attachment No. PC 11
EIR Response to Comments
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FINAL ENVIRONMENTAL IMPACT REPORT
INTRODUCTION
This Final Environmental Impact Report (FEIR) was prepared in accordance with the California
Environmental Quality Act(CEQA) as amended (Public Resources Code § 21000 et seq.) and CEQA
Guidelines (Title 14, California Code of Regulations, § 15000 et seq.).
According to CEQA Guidelines § 15132, the FEIR shall consist o£
a. The Draft EIR(DEIR) or a revision of the draft;
b. Comments and recommendations received on the DEIR either verbatim or in summary;
c. A list of persons, organizations, and public agencies commenting on the DEIR;
d. The responses of the Lead Agency to significant environmental points raised in the review
and consultation process; and
e. Any other information added by the Lead Agency.
In accordance with the above listed requirements, this FEIR for the proposed 150 Newport Center
project (hereafter, the "Project") and associated discretionary and administrative actions consists of
the following:
1. Comment letters and responses to public comment; and
2. The circulated 150 Newport Center DEIR and Technical Appendices, SCH No. 2016011032
with additions shown as underline text and deletions shown as stricken text in Section F.3,
below.
This FEIR document was prepared in accordance with CEQA and the CEQA Guidelines and
represents the independent judgment of the CEQA Lead Agency(City of Newport Beach).
RESPONSES TO COMMENTS
CEQA REQUIREMENTS
CEQA Guidelines § 15204(a) outlines parameters for submitting comments, and notes that the focus
of review and comment of DEIRs should be:
...on the sufficiency of the document in identifying and analyzing possible
impacts on the environment and ways in which the significant effects of the
project might be avoided or mitigated. Comments are most helpful when they
suggest additional specific alternatives or mitigation measures that would
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provide better ways to avoid or mitigate the significant environmental effects.
At the same time, reviewers should be aware that the adequacy of an EIR is
determined in terms of what is reasonably feasible...CEQA does not require a
lead agency to conduct every test or perform all research, study, and
experimentation recommended or suggested by commenters. When
responding to comments, lead agencies need only respond to significant
environmental issues and do not need to provide all information requested by
reviewers, as long as a good faith effort at full disclosure is made in the EIR.
CEQA Guidelines § 15204(c) further advises that, "Reviewers should explain the basis for their
comments, and should submit data or references offering facts, reasonable assumptions based on
facts, or expert opinion supported by facts in support of the comments. Pursuant to CEQA
Guidelines § 15064, an effect shall not be considered significant in the absence of substantial
evidence;" CEQA Guidelines § 15204(d) also notes that, "Each responsible agency and trustee
agency shall focus its comments on environmental information germane to that agency's statutory
responsibility." CEQA Guidelines § 15204(e) states that, "This section shall not be used to restrict
the ability of reviewers to comment on the general adequacy of a document or of the lead agency to
reject comments not focused as recommended by [CEQA Guidelines § 15204]."
Pursuant to CEQA Guidelines § 15088(b), copies of the written responses shall be provided to
commenting public agencies at least ten (10) days prior to certifying the FEIR. The responses shall
be provided along with an electronic copy of this FEIR, as permitted by CEQA, and shall conform to
the legal standards established for response to comments on DEIRs.
RESPONSES TO DEIR COMMENTS
CEQA Guidelines § 15088 requires the Lead Agency (City of Newport Beach) to evaluate comments
on environmental issues received from public agencies and interested parties who reviewed the DEIR
and to provide written responses to any substantive comments received. This Section F.0, Final
Environmental Impact Report, provides all comments received on the DEIR, the City's response to
each comment, and a summary of revisions made to the DEIR as part of the FEIR in response to the
various comment letters.
Comment letters were received during and after the public review period which began on May 13,
2016 and closed on June 27, 2015. Sixteen comment letters addressed environmental issues
substantive to the adequacy of the Draft Environmental Impact Report for the proposed Project. A
list of agencies, organizations, and persons that submitted substantive comments regarding the DEIR
is presented in Table F-1, Organizations, Persons, &Public Agencies that Commented on the DEIR.
A copy of each comment letter and a response to each substantive environmental point raised in
those letters is provided on the following pages. No comments submitted to the City of Newport
Beach on the DEIR have produced substantial new information requiring recirculation or additional
environmental review under State CEQA Guidelines § 15088.5.
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Table F-1 Organizations, Persons, & Public Agencies that Commented on the DEIR
COMMENT LETTER COMMENTING ORGANIZATION, PERSON,OR PUBLIC AGENCY DATE
A State Clearinghouse June 28, 2016
B California Department of Transportation June 8, 2016
(CALTRANS)
C Airport Land Use Commission for Orange County June 27, 2016
(ALUC)
D Orange County Transportation Authority(OCTA) June 27, 2016
E City of Irvine June 7, 2016
F Gabrieleno Band of Mission Indians May 25, 2016
G Dennis Baker June 15, 2016
H Irvine Company June 24, 2016
I Dorothy Kraus June 26, 2016
J Carolyn Martin June 27, 2016
K Jim Mosher June 27, 2016
L Bob Rush June 22,2016
M Sindi Schwartz June 27,2016
N Susan Skinner June 19, 2016
O Stop Polluting Our Newport(SPON) June 27, 2016
P Debbie Stevens June 27, 2016
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COMMENT LETTERS
STATE OF CALIFORNIA '6
k
Governor's Office of Planning and Research `
State Clearinghouse and Planning Unit X...,�"
Ed=en G.Brown Jr. K::,Alex
Governor 0--CEIVED a D.,,uv
Y
lune 29,2016 COMMUNITY
JUN 3 U 201S
Makana Nova
City'of Newport Beach O� DEVELOPMENT G.D
100 Civic Center Drive Y
Newport Beach,CA 92660 Op NErypOpS 9�
Subject 150 NewportCents
SCHJI: 2016011032
Dear Makers Nova:
The State Clearinghouse submitted the above named Draft EIR to selected state agencies for review. On
the enclosed Document Details Report please note that the Clearinghouse has listed the state agencies that
reviewed your document The review period closed on June 27,2016,and the comments from the
responding agency(ies)is(are)enclosed. If this comment package is not in order,please notify the State
Clearinghouse immediately. Please refer to the project's ten-digit State Clearinghouse number in future
correspondence an that we may respond promptly.
Please note that Section 21104(0)of the California Public Resources Code nates that:
"A mponsible or other public agency shall only make substantive comments regarding those
activities involved in a project which are within an area of expertise of the agency or which are
required to be carried out or approved by the agency. Those comments shat!be supported by
specific documentalion."
These comments are forwarded for use in preparing your final environmental document Should you need
more information or clarification of the enclosed comments,we recommend that you contact the A_,
commenting agency directly.
This letter acknowledges that you have complied with the State Clearinghouse review requirements fm
draft environmental documents,pursuant to the California Environmental Quality Act Please contact the
Stale Clearinghouse at(916)445-0613 if you have any questions regarding the environmental review
process.
Sincerely
S/Morgan
Director,State Clearinghouse
Enclosures
cc: Resources Agency
1400 TENTH STILEET P.O.BOX 0044 SACRAMENTO.CALIFORNIA 968120044
TEL(916)445-0610 FAg(919)02&901g www.aPr.mgm
Lead Agency: City of Newport Beach SCH No, 2016011032
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COMMENT LETTERS
Document Details Report
State Clearinghouse Data Base
SCHR 2016011032
Project Tide 150 Newport Comer
Lead Agency Newport Beach,City of
Type SIR Draft SIR
Description The Proposed project consists of the demolition of an 8,500 sa,ft.car wash,convenience marks:,and
gas station to accommodate the development of a 7-story 49 unit residential condominium building
with three levels of subterranean parking.
Lead Agency Contact
Name Makers Nova
Agency City of Newport Beach
Phone 949-844-3249 Far
email
Address 100 Civic Center Drive
City Newport Beach State CA Zip 92660
Project Location
County Orange
City Newport Beach
Region A-1
LatJLong 33'40'Ur N/117'41'2.5'W
Cross Streets Newport Center Drive and Anacepa Drwe (cont.)
Parcel No. 442-231-12
Township BS Range 10W Section 36 Base Be
Proximity to:
Highways SR-1 and 73
Airports
Railways
Waterways Newport Bay
Schools Harbor View ES
Land Use Car-wash with ancillary convenience market and gas statioNOR(Office and Reg.Commercial)/CD-F,
(Reg.Comerrial Office)
Project Issues Air Quality;ArchaeologicHistonc;Biological Resources;Geologic/Seismic;Noise;Tosfc/Hazardous;
Traf6UClrculation;Growth Inducing;Landuse;Cumulative Effects
Reviewing Resources Agency;Department of Conservation;Department of Fish and Wildlife,Region 5;Cal Fire:
Agencies Department of Parks and Recreation;Department of Water Resources;California Highway Patrol;
CaltranA District 12;Slate Water Resources Control Board.Division of Drinking Water,District 8;
Regional Water Quality Control Board,Region 8:Department of Tmdc Substances Control;Native
American Heritage Commission
Data Race ved 05/132016 Sten of Review 0511312016 End of Review 08272016
Note: Blanks in data fields resua from insufficient information provided by lead agency.
Lead Agency: City of Newport Beach SCH No. 2016011032
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State Clearinehouse—Comment Letter A
A-1:
The City of Newport Beach acknowledges this letter, which confirms the close of the public review
period for the DEIR as June 27, 2016. The City further acknowledges that the Project has complied
with the State Clearinghouse review requirements for draft environmental documents. Responses to
comments from the California Department of Transportation(Caltrans) are numbered B-1 through B-
3.
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COMMENT LETTERS
GP,� h1rfIUND G.@ftUNSL_tiusnm�
DEPARTMENT OF TRANSPORTATION
DISTRICT 12
1347 MILUELSON DRIVE,SUITE 100
IRVINE,CA 926124394
PHONE(949)7242086
FAX (949)724-2592
m 711 110,
www.du.u.mv
June 8,2016
File:IGR/CEQA
Ms.Makana Nova SCH#:2016011032
City of Newport Beach Log#:4616A
Community Development Dept. SR-1,SR-74
100 Civic Center Drive
Newport Beach,CA 92660
Dear Ms.Nova:
The California Department of Transportation(Caltrans)appreciates the opportunity to review
and comment on Draft Environmental Impact Report(DEIR)for the proposed 150 Newport
Center project. The proposed project consists of the demolition and removal of an existing
8,500-square-fool car wash,convenience market,and gas service station,associated site B-1
improvements and redevelopment of the property to accommodate the development of a seven-
story 49-unit condominium building with three levels of subterranean parking. Landscaping,
drive aisles,and associated parking would also occur on the property. Caltrans is a commenting
agency on this project and has the following comments:
• Any hauling of materials should not occur during A.M.and P.M.peak periods of travel on B-2
State facilities during demolition and/or construction of the proposed project. All vehicle
loads should be covered so that materials do not blow over or onto the Caltrans Right-of- B-3
Way(R/W).
Please continue to keep us informed of this project and any future developments that could
potentially impact State transportation facilities. If you have any questions or need to contact us,
please do not hesitate to call Leila Carver at(949)756-7827.
Sincerely, y%�pp��
zv�' `t'c,R�C� B-4
MAUREEN EL HARAKE
Branch Chief,Regional-Community-Transit Planning
District 12
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Lead Agency: City of Newport Beach SCH No, 2016011032
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California Department of Transportation (CALTRANS)—Comment Letter B
B-1:
The commenter accurately summarizes the proposed Project.
B-2:
In accordance with CEQA Guidelines §15126.4, an EIR shall describe feasible mitigation measures
that would minimize significant adverse impacts of a project. Mitigation measures must be fully
enforceable, have an essential nexus to a legitimate governmental interest, and be `roughly
proportional" to the impacts of the project. (See § 15126.4, subds. (a)(4)(A)-(B), (a)(5).) With this
basis, the commenter's suggestion to prohibit the hauling of construction related soil and materials
during peak hours has not been added as a mitigation measure to the EIR. This comment does not
identify any deficiencies in the EIR analysis that would necessitate a restriction on peak hour travel
using State facilities during the Project's demolition and construction periods. As stated in EIR
Subsection 3.4.4, the Project Applicant proposes to control haul traffic by using the former site of the
Coyote Canyon Landfill located at 20661 Newport Coast Drive (approximately 2.5 miles from the
Project site) as an off-site staging area for trucks during grading activities where trucks will queue
prior to accessing the Project site. Use of the site will enable the applicant to manage construction
related haul trucks in the most efficient manner possible, including during peak periods.
B-3:
All Project-related construction vehicles are required by law to comply with applicable provisions of
the California Vehicle Code and California Code of Regulations regarding the hauling of materials,
including provisions related to covering and tarping loads. CEQA lead agencies are not obligated to
impose mitigation measures that are duplicative of mandatory regulatory requirements. Regarding
Caltrans' recommendation to cover every load, which goes above and beyond the requirements of the
California Vehicle Code, there is no essential nexus between the covering of loads that are not
already required to be covered by the California Vehicle Code and the Project's significant
environmental effects. Regardless, the City of Newport Beach will take Caltrans' recommendation
to require the covering of all loads into consideration when issuing grading and building permits for
the Project.
B-4:
The commenter's contact information is noted. Caltrans is included on the City's notification list for
future public notices regarding the Project.
Lead Agency: City of Newport Beach SCH No. 2016011032
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COMMENT LETTERS
AIRPORT LAND USE COMMISSION
ORANGE COUNTY
FOR ORANGE COUNTY
.4LUG 3160 Airway Avenue•Costa Mesa,California 92626-949.252.5170 fax:949.252.6012
June 27,2016
Makana Nova,Associate Planner
City of Newport Beach,Community Development Department
100 Civic Center Drive
Newport Beach,CA 92660
Subject:DEIR for 150 Newport Center Residential Project
Dear Ms.Nova: �-
Thank you for the opportuy to review the Draft Environmental Impact Report(DEIR)
for the proposed 150 Newport Center Project.As noted in the Notice of Prepuralion
(NOP)comment letter submitted by the Airport Land Use Commission(ALUC)for
Orange County ori February 11,2016,the proposed project is not located within the C-1
Airport Planning for John Wayne Airport(1 WA). Therefore,the Airport Land Use
Commission(ALUG)Ifoorr OrangetCountyihas noicomment�onithe NOPzrclatedtto land
use,noise or safety compatibility with llie Airpur{•Erivr ons Lanrl�Uae�Plaiv(AELUP)for
JVVA.
Please note that the AEL-UP fqi-JWA_de Ines the eirpon planning,area,as•all area�iwithin
the 60 db CNEL Contour,within ihe'Rudway Protectiori�Zones,Safety Zones;and all
area that liesiabovle or penetrates the 1'00:I 1 am ginary•Surface for Federal Avialion
Administration(FAA),notifrcauon as defined.inf;AR Part77.13. The DE1RISection
t _ _j C2
2.3.3 states that the northerly one third.o�ihe Project site is'l'ocated within die AELUP
Pan 77 Notificauon Arca for J WA:=However,the entire project site is not Within this
notification areahor 1W.A;-The alta h d exhibits show the projecusite outside of the
notification boundary.--,j J j� ��'`-���—�r
Although the proposed development is located outside of the Airport Planning Area,
please be aware that development proposals which include the constniction or alteration
of a structure more than 200 feet above ground level,require filing with the Federal
Aviation Administration(FAA). Structures meeting this threshold must comply with
procedures provided by Federal and State law,with the referral requirements of ALUC,
and with all conditions of approval imposed or recommended by the FAA and ALUC C-3
including filing a Notice of Proposed Construction or Alteration(FAA Form 7460-1).
We recommend you utilize the FAA notice criteria tool on the FAA website at
haps://oeaaa.faa.eov/oeaaa/extemal/nortal.isn to determine if a Notice of Proposed
Construction or Alteration would be required for your project.
Lead Agency: City of Newport Beach SCH No. 2016011032
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COMMENT LETTERS
ALUC DLIR Cnm.mis
lune 2r.20IM1
Pogo 2
The proposed project does not include the development of heliports or helistops. For
your information,should the development of heliports occur within your jurisdiction,
proposals to develop new heliports must be submitted through the City to the ALUC for
review and action pursuant to Public Utilities Code Section 21661.5. Proposed heliport C-4
projects must comply fully with the state permit procedure provided by law and with all
conditions of approval imposed or recommended by FAA,by the ALUC for Orange
County and by Caltrans/Division of Aeronautics.
Thank you again for the opportunity to comment on this DEIR. Please contact Lea
Choum at(949)252.5123 or via email at Ichoum aocaincom should you have any
questions related to the ALUC for Orange County.
Sincerely,
C-5
Kari,(.!, J""/-• -- _
Executive Officer o
Lead Agency: City of Newport Beach SCH No. 2016011032
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■■ 150 NEWPORT CENTER
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Airport Land Use Commission for Oranee County(ALUC)—Comment Letter C
C-1:
The ALUC's February 11, 2016, comment letter on the NOP is part of FIR Technical Appendix A.
It is acknowledged that the Project site is located outside the Airport Planning Area for John Wayne
Airport(JWA).
C-2:
The Draft FIR Section 2.3.3 stated that a portion of the proposed Project is within the Part 77
Notification Area for JWA. The commenter provides information indicating that the entire Project
site is outside of the Part 77 Notification Area, including exhibits that were attached to the ALUC
comment letter. Accordingly, the Draft EfR has been revised to accurately describe that the Project
site is outside of the Part 77 Notification Area, as indicated in the Errata Section of the Final EIR.
C-3:
The requirements noted in this comment, which are applicable to structures over 200 feet in height,
are not applicable to the proposed Project. The Project proposes a building that would be 83-feet 6-
inches tall at its highest point, including all rooftop appurtenances.
C-4:
The commenter provides additional information associated with requirements for projects that
involve the development of heliports or helistops. The proposed Project does not include any
components associated with heliports or helistops. Therefore, these requirements are not applicable
to the proposed Project and no further response is required.
C-5:
The commenter's contact information is noted.
Lead Agency: City of Newport Beach SCH No. 2016011032
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COMMENT LETTERS
OCTA
9ongD 000lg5crogs June 27,2016
GWi6lYIMdk
Ms.Makana Nova,AICP,Associate Planner
c:rlue!!!nu'er..ey City of Newport Beach
100 Civic Center Drive
A.&n"" Newport Beach,CA 92658-9518
DiKKld
Subject: Notice of Completion and Availability of Draft Environmental Impact
Report (SCH#2016011032) for the 150 Newport Center Residential
Project
DuecJw
J:m xa�aP : Dear Ms. Nova:
midrw
JCNf°y'"'�"'•'+' Thank you for providing the Orange County Transportation Authority(OCTA)an opportunity
D.ixid
to review the above referenced document.The following comments are provided for your
D'q'Ar1nie' consideration:
D+nia�
Effective June 12,2016, OCTA's June Service Change was implemented along
with the first phase of the 2016 Bus Service Plan. As a result, Route 76 no D-1
o-did longer serves Newport Ion Transportation Center and has been cul back to John
P
Wayne Airport.Please remove references to Route 76 at the following locations
nrdwer RniW in the document:
Dm w
o Table 4.7-2, Proposed Project General Plan Consistency(Circulation
r sra• Element)
DJearw
o Page 4.9-2,Existing Mass Transit
0..SprPlease provide clarification regarding the bus stop locations served by OCTA
r"fkW.broutes 1,57,and 79 which are mentioned on pages 4.7-12,4.9-2 and 4.9-13. D-2
D+d�ro¢I Clarify in document if all routes are served at one stop or multiple stop
locations.
r ran
o;rnor
Thank you for the opportunity to provide input on this project. If you have any questions
F.0 U, or comments,please contact me at(714)560-5907 or at dohuoocta.net.
DLedd
Sincerely,
gyan Lriampenam
Ex--OflN°NdnMr A,9z-,— D-3
CHlEFExECUTNEDFFlDE
DanollJNsmn Dan Phu
Lhl°(ExeMiv°DIlxm Environmental Programs Manager
Orange Courcy Tmnspadmion Aulhonly
550 Soulh Main Street/P.O.Box 14164/Orange/Cohlornia 928534594/(7 14)MO-OCTA(6282)
Lead Agency: City of Newport Beach SCH No. 2016011032
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Orange County Transportation Authority (OCTA)—Comment Letter D
D-1:
In response to this comment regarding OCTA's service changes, references to OCTA Route 76 have
been removed from EIR Table 4.7-2 and from the discussion on EIR Page 4.9-2. The revisions
associated with these text changes are indicated in the Errata Section of the Final EIR.
D-2:
Information identifying the OCTA bus stops that are located in the immediate vicinity of the Project
site, and the OCTA routes served by those stops, has been added to the EIR. The revisions
associated with these text changes are indicated in the Errata Section of the Final EIR.
D-3:
The commenter's contact information is noted.
Lead Agency: City of Newport Beach SCH No. 2016011032
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COMMENT LETTERS
A. pF ig?
i
u o m
June 7,2016
Ms. Makana Nova
Associate Planner
City of Newport Beach
100 Civic Center Drive
Newport Beach, CA 92660
Subject: Review of a Draft Environmental Impact Report(DEIR)for 150
Newport Center-Residential Condominium Project
Dear Ms. Nova:
City of Irvine staff reviewed the information on the referenced project and has the
following comment:
The Draft EIR states that the traffic impacts were evaluated pursuant to the City of
Newport Beach's Traffic Phasing Ordinance(TPO),and since the project's 205 average
daily trips(ADT)are less than the 300 ADT pursuant to the TPO, it is exempt from the
provisions of the TPO. E_
Please clarity if the City of Newport Beach's TPO considers the proposed change in land
uses from existing commercial to residential units will result in a change in directionality of
traffic during morning and evening peak periods when there is the greatest volume of
traffic on the street network. Further,given the directionality of traffic changes in both AM
and PM, it may also be beneficial to conduct a traffic study to ensure the circulation
system surrounding the project can support such changes during the peak periods of
heavy traffic. Note that the City of Irvine's Traffic Impact Analysis Guidelines, adopted in
August of 2004, requires a traffic study to be prepared for projects that result in significant
increases in AM or PM peak hour trips. In this way,the City of Irvine ensures that the E-2
circulation system can support the additional traffic a development project might
contribute during these peak periods.
Lead Agency: City of Newport Beach SCH No, 2016011032
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. ENVIRONMENTAL IMPACT REPORT F.0 FINAL ENVIRONMENTAL IMPACT REPORT
COMMENT LETTERS
Ms. Makana Nova
June 7,2016
Page 2
Thank you for the opportunity to review the proposed project. Staff would appreciate the
opportunity to review any further information regarding this project as the planning
process proceeds.
If you have any questions, I can be reached at 949-724-6314,or at diaw@cityofirvine.org.
Sincerely, E-3
k AICP
Senior Planner
ec: Bill Jacobs, Principal Planner
Sun-Sun Murillo,Supervising Senior Transportation Analyst
Lead Agency: City of Newport Beach SCH No. 2016011032
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■■ 150 NEWPORT CENTER
■❑ ENVIRONMENTAL IMPACT REPORT F.0 FINAL ENVIRONMENTAL IMPACT REPORT
City of Irvine—Comment Letter E
E-1:
Information is provided in the attachment to this response showing the anticipated AM Peak Hour
and PM Peak Hour trips that would be generated by the proposed Project in comparison to those that
are generated by the existing car wash use. As shown on the attachment, the proposed Project would
result in a net reduction of 27 AM Peak Hour trips and 48 PM Peak Hour trips when compared to the
existing car wash use (based on the Luxury Condo/Townhouse ITE trip generation rates). Because
there would be a net reduction in both AM and PM Peak Hour trips with the implementation of the
Project, the Project would not result in a change to the directionality of traffic that would adversely
affect the roadway network.
E-2:
The City of Newport Beach acknowledges the requirement of the City of Irvine Traffic Impact
Analysis Guidelines cited in this comment. The City of Irvine's guidelines do not apply to the
proposed Project, which is located in the City of Newport Beach. Further, the comment does not
define "significant increases in AM or PM peak trips." But, as shown on EIR Table 4.9-3, the
proposed Project would result in a net reduction in vehicle trips generated at the site compared to
existing conditions.
E-3:
The commenter's contact information is noted.
Lead Agency: City of Newport Beach SCH No. 2016011032
Page FEIR-18
150 Newport Center Dr Condos
Comparison of Hiph-Rise Residential Condominium VS. Luxury Condo7Townhouse Use
Trip Generation Rates (ITE 9th Edition)
AM Peak Hour PM Peak Hour Daily
Land Use Rate Type Size Unit In I Out Total In Out I Total Total
Luxury Condo/Townhouse 1 ITE 233 TSF 0.13 0.43 0.56 0.35 0.20 0.55 N/A
High-Rise Residential Condos ITE 232 DU 0.061 0.28 0.34 0.241 0.141 0.38 4.18
(1) - No daily trips rates available for luxury condo/townhouse
Existing Use
AM Peak Hour PM Peak Hour Daily
Land Use Rate Type Size Unit In Out Total In Out Total Total
Existing Carwash 30 24 54 33 42 75 819
Total 30 24 54 33 42 75 819
—Existing trip credits will be based on Trip Generation survey.
Proposed Use - High Rise Residential Condo
AM Peak Hour PM Peak Hour Daily
Land Use Rate Type Size Unit In Out I Total In Out Total Total
Residential Condo ITE 232 49 DU 3 1 14 1 17 12 7 19 205
Net Change -27 -10 -37 -21 35 56 -614
Proposed Use-Luxury Condo/Townhouse
AM Peak Hour PM Peak Hour Daily
Land Use Rate Type Size Unit In Out Total In Out Total Total
Luxury Condo/Townhouse(1) ITE 233 49 DU 6 21 27 17 10 27 N/A
Net Change -24 -3 -27 -16 -32 -48 NIA
Print Date: 07/08/2016
3�3
Land Use: 233
Luxury Condominium/Townhouse
Description
Luxury condominiums/townhouses are units in buildings with luxury facilities or services. Both con-
dominiums and townhouses are included in this land use. Residential condominium/townhouse
(Land Use 230), low-rise residential condominium/townhouse (Land Use 231) and high-rise residen-
tial condominium/townhouse (Land Use 232) are related land uses.
Additional Data
The sites were surveyed in the 1980s and the 1990s in Indiana and New Jersey.
Source Numbers
I
260, 407
i
i
III
i1
1'
i
I
I
I
I
I
i
I
i,
I.
i
436 Trip Generation,9th Edition • Institute of Transportation Engineers
I,
Luxury Condom inium/T'ownhouse
(233)
Average Vehicle Trip Ends vs: Occupied Dwelling Units
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 7 and 9 a.m.
Number of Studies: 4
Avg. Num. of Occupied Dwelling Units: 110
Directional Distribution: 23% entering, 77% exiting
Trip Generation per Occupied Dwelling Unit
Average Rate Range of Rates Standard Deviation
0.56 0.50 0.62 0.75
Data Plot and Equation Caution- UseCaretully-Small Sample Size
90
I
80 /! I
Lu
CL 70 -,
U 1
>
m
i 60
Q
F ° i
50
. -
Y
'r
1 e
80 90 100 110 120 130 140 150 160
X = Number of Occupied Dwelling Units J
Y. Actual Data Points — Fitted Curve ------ Average Rate {
Fitted Curve Equation: Ln(T)= 0.76 Ln(X) +0.54 R2= 0.93
G
c
'u
c
Trip Generation, 9th Edition + Institute of Transportation Engineers 343J� I,
Luxury Condominium/Townhouse
(233)
Average Vehicle Trip Ends vs: Occupied Dwelling Units
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 4 and 6 p.m.
Number of Studies: 4
Avg. Num. of Occupied Dwelling Units: 110
Directional Distribution: 63% entering, 37% exiting
Trip Generation per Occupied Dwelling Unit
Average Rate Range of Rates Standard Deviation
0.55 D.48 0.63 0.74
Data Plot and Equation Caution - Use Carefully-small Sample Size
00
X
90
80
N '
C
W
Q
70
U
N � 1
a�
r-
40 -1
80 90 100 110 120 130 140 150 160
X = Number of Occupied Dwelling Units
Actual Data Points -- Fitted Curve ------ Average Rale
Fitted Curve Equation: T-0.78(x)- 25.38 R2 _0.99
438 Trip Generation,9th Edition • Institute of Transportation Engineers
Land Use: 232
High-Rise Residential Condominium/Townhouse
Description
High-rise residential condominiums/townhouses are units located in buildings that have three or
more levels (floors). Both condominiums and townhouses are included in this land use. Resi-
dential condominium/townhouse (Land Use 230), low-rise residential condominium/ townhouse
(Land Use 231) and luxury condominium/townhouse (Land Use 233) are related land uses.
Additional Data
The peak hour of the generator typically coincided with the peak hour of the adjacent street traffic,.
The sites were surveyed in the 1980s and the 1990s in the metropolitan areas of Richmond, Virginia;
Washington, DC, Minneapolis, Minnesota; and Vancouver, Canada.
Source Numbers
168, 237, 305, 306, 390
426 Trip Generation, 91h Edition • Institute of Transportation Engineers
3;L
High-Rise Residential Condominium/Townhouse
(232)
Average Vehicle Trip Ends vs: Dwelling Units
On a: Weekday
Number of Studies: -A
Avg. Number of Dwelling Units: 543
M
Directional Distribution: 50% entering, 50% exiting
Trip Generation per Dwelling Unit
Avera ate Range of Rates Standard Deviation
4.18 3.91 4.93 2.08
Q
Data Plot and Equation Caution- Use Carefully-Small Sample Size
7,000
6.000
1
uj
a
a / .
4.0001
L • j
N li
m 3,000 � '
> a
2,000
1,000-
i
i
100 200 300 400 500 600 700 800 900 1000 1100 1200 1300 1400 1500
X= Number of Dwelling Units
Actual Data Points Fitted Curve -- Average Rate
Fitted Curve Equation: T= 3.77(X) + 223.66 R2 = 1.00
Trip Generation, 9th Edition e Institute of Transportation Engineers 3427
High-Rise Residential Condominium/Townhouse
(232)
Average Vehicle Trip Ends vs: Dwelling Units
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 7 and 9 a.m.
Number of Studies: 4
Avg. Number of Dwelling Units: 543
Directional Distribution: 19% entering, 81% exiting
Trip Generation per Dwelling Unit
Average Rate Range of Rates Standard Deviation
0.34 0.31 0.48 0.59
Data Plot and Equation Caution - Use Carefully-Small Sample Size
500
400 %
J,
J`
V)
W
300
U
L
7 f
N
m 200 /-
Q
II
o
too 200 300 400 500 500 700 500 900 1000 1100 1200 1300 140D 1500
X - Number of Dwelling Units
Actual Data Points — Fitted Curve ------ Average Rale
Fitted Curve Equation: T= 0.29(X) +28.86 R2= 0.98
428 Trip Generation, 9th Edition o Institute of Transportation Engineers q
37 /
High-Rise Residential Condorniniurn/Townhouse
(232)
Average Vehicle Trip Ends vs: Dwelling Units
On a: Weekday,
Peak Hour of Adjacent Street Traffic,
One Hour Between 4 and 6 p.m.
Number of Studies: 5
Avg. Number of Dwelling Units: 444
Directional Distribution: 62% entering, 38% exiting
Trip Generation per Dwelling Unit
Average Rate Range of Rates Standard Deviation
r
0.38 0.34 0.49 0.62
Data Plot and Equation T Caution- Use Carefully- Small Sample Size i
"I
600 j
dl i :I
� • I II
400
W
� - t
U i 1:1
300
m i 1
R i I 1i
� 200 -j f
100
I z.
0 100 200 300 400 500 600 700 800 000 1000 1100 1200 1300 1400 1500 4
)
X = Number of Dwelling Units
r
Actual Data Points Fitted Curve ------ Average Rate
Fitted Cutve Equation: T =0.34(X) + 15.47 R2=0.99 :A
trip Genetalion, 5th Edition 0 Institute of Transportation Engineers O
■■ 150 NEWPORT CENTER
■❑ ENVIRONMENTAL IMPACT REPORT F.0 FINAL ENVIRONMENTAL IMPACT REPORT
COMMENT LETTERS
dyad oF�
f'►� GAE>KIF_LF N05AND OF MI5510N INDIAN5-KI7_H NATION
Y tntnriwlly Lnown a+Tbe$an Gabriel and of Missies leaven
Kecognbed 69 the State of Caldomia m the a6adgiml tube of the Lon Angeles basin
N,eoe`
Deur MaAana Norm,
AICP,Assatiate Planner
150 Neirl+ort Center residenHul projeet
"71a project lame lin in mer ami ndarc fir Arnrsfrrd F traditional territories of flu•KIJI(Kitc)Aaabneleao vilings,snap as Moymrgma&Kenyaangra
adjoined and ouerlapped milliard,other,at Inst during fire fate Pnllsforir and Prolohisforic Periods.71re Immdrmd of Bre Ki J,(Kite)Cal,rieleloa,
Invisibly t1,•most influential Native American group in alnnginal soudient Califorum(Berm and Smits 1978nS58),rens catrml in fire Los Angeles Basin.
and melted as fa,m4l as the Sou Itemardluo-Rhierside ams.Thehoneimud of Bre Se rmnos ens prinorily fire Sou Bemp ntfuo Mountains,tnciudiug the
signs mid lowlands on the milli mrd smdh OanAs.Wlmfewr fire linguine ajjiliation,Naf ry Anerirnns in and aronad the proje t arch eildNfed similar
organization and resource procurement strategies.Villages rrere baseef in, or lineage groups,Their lrome/Imre sits rtre sparked by sadden deposit,.,.n,u
milli Irndwk morlars.Drying fleir smsonai roods to exploit plait resourom small grogra nmuld migrate a ilhin Upeir traditional territory is clan it rt
sike'iflc pints and applauds.Tlueir gathering sfmlegies often left behind signs ofslierhd use silex,usually grinding slit-As on bedrock Imndders,of no-lo,cern.
of Sir resohens.Tiu•rciom in arrive a protect our n lnxm ny're requesting one ofour experienced Ncertified Nally American rnouifon to Ir au situ
during any b all ground dismtauces(Lind;includes but is not liutile d to pavement renoval,p of ludutg or auguring,h+ring,grappling,ex,uNdinn
and fnvulung).
hr all cases,udreu flu•NAHC stats flrercarr"No"words ufsacnd sites"in to subject amp flue,/ahmys reer the canmrinn And to file Nalhre Antrim,
Trilys minrsr feast frrntory Beprojaf oar is in. This is due to Bie fad,flat Site NAHC fs only mmmin general inpmmfion nn milt California NA Troy
llrey am"NOT'Lia•"eslerls"on our TrIsr. Our Elder Coni nitlm F Trilml Historians are tap experts aped is Ila meso rnhy lire NAHC mill alums r,-Ar
ronfmcton to Ili hu'nl lrOrn.
In adWitiro,,err rtre uilw aRrn lila Oust rte urea lots hen pnrinusly drreiegaed err dishptyA ural tins Oa•rc nm un ionemns for salient
reources and thus minima irnr4u3s ntould Ie npe•ded, l laar into major rernt cvorrple s of luny simflar shhfemmts on other projeras rare
proven awry inadequate.An arduuwlogiral sled y claim..I ditere arould ler•no inipucts to an arra adjacent It,the Plaw 0mnliof Oloem Stnyl,
the original Spanisl,s lthwent of Los Angeles.,nun in ehaevttoon Los Angeles.in fact,this site nets the Gibriele o village ofYahgna long
h fore it became n4af it is nes,today. 17m nen deryl pme,f nrongfinIN begin their construction and toy,in Opt-proxv,ss,dug rip mol F"1
devrlalet I IS burials.The area fiat pars dismissed a,ndtnondhl sensiti+r avis in fad tin Finl Ciauetery of Los Ang•h's so/pew it 11,411"1
sell dthinuented at tin Huntington Library Oust 400 ofemr Trlh•'s an i'tors mere buried Imre along milli the/minding fanilie:s of Los,
Angela(Pim Sepulve•M's,and Alnhn4do to name;i(ter).1,addition,them was another inappropriate study for flu,eharl+pmet ata new
sp els complex at Fedde Middle Soho/in the City of Hhvenfian Girder,rould ronnnemm.Again,a village and burial site were dd:seyrohNd
despile tluir mitigation measures. Thankfadhb arc mere able to stork alongfde the sduud district 1,quickly dad reslydhdly mitigate a
annually h•nefaetid resolution.
Gime,all flu•ahoy,the proper Oiling to do fi,r your project frould be for our Trih•to monitor ground disturbing eonstnhction rack. Natiry
Anserina monitors and/or consultant can see Oat odleal rsounes are treated appropri tel y f ern Or Natiry American point of viete.
Ayans•sir am flu•lineal des endanfs of Lite roast ane,f L+s Angeles and Orange Counties,err hodd aered 11w ability it,profeyl ndal little of
our nthve remains. We flank you for taking serfvusl y you roe mad rrslmusibility in assisting its in presenting our nature.
With n,7%%1,
Pinta codad one office regarding this proje•t to emordinafe a NativeAoericnn Monitor lo Iv present.Tlrapd You
Andner Salas.Clafmon
aaraw cab.,rnanman Nature Was,Vjie bleeps asap.S.'AbuMmn,ee,cions,
Awn Peat 1I.A.rtr I Martha Gonylertemm,lrtawrer 11 Rkbrd Graaos, (pp.i .d the Wm¢,l oh Eke..
FOb-s59; COV1na,CA 91723 ww.a..+bnclenomrllart aachahoo,cnm gabnelenoinrllans4,•yabc,o.cnm
Lead Agency: City of Newport Beach SCH No, 2016011032
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COMMENT LETTERS
Cell(626)9264131
Addeudiniv elaritimliou mganliug sono•nm)rrumrs ngnnling nnsulfation under AB52:
AR52 a lean y stades Ilial musulfatiou umsl arurreltir Miles dial,info,traditional)mast Rdh,mi n(filinfiou trill,a jactat site, lhgivinuakly,this statement
has In•u left rgaa,to harlprehrNma w nmd,limit ndgidmdng fn)res an,Claiming atfflfolum laid,pmje'Is aril mrh'inhe their MulitimmI IrUnd territory. Tile
territories oimv uomuuding NatirwAmerianu trilies snrh as Ille Lid eno,Onmm-A nual Ghuilin inial entified. Freda ni my fn7n11rmMris bus lnr•rn,r0
Arlinrst by hisMrfrnas,rlhnngmyiarm,nnluualaPgisls,nuARhamgmldrers-n lis)n/mesons nr•rnn pmrrid,rgmn mpl st. 011ea,nada Tnlr ns nx•11,tuna,,
Ilk,pulalir or,flair awrgman ualeiteas to the rhy)nilimr ordwir lrllial lmuudnrles. Yau nary lmnx•mrhxrin roasullnfion n'gmsf lana mmOrer 7rille.
Hmn1x•r nr nm nslxmding Innllr your ymjerl site lia>mit,in our Aueslml Irilni fernMry,n4,idi,ngrain,las Ixrr nrli dmvuuu1M.1Nmrf rfm>
Ancestrallyor Ana57nd mend Tirelrgde ulm awre anyone hnuily in,liasl flares,Oh ixdonging to,hdanihal tams,or denoting as,mwaslor or mmsfon
hitr:Oa•u•u•.fir-r"llidu»arm..naa/mrcArnl.. I/Wr,lanes gnrsfio s rignnling life validity of 11u•"fnalifimud anAnAh,ml nffilinlima"ofnrmfher Tn1w,nes
urge Wu to enalm111u•Native Aurelian,Heritage Coumdssfm,direti)m &Rion 5 srt4fon 21080.3.1(x)states"...fire Native Amerieua Heritage
Cannnissiun sliall rnf time lead ngmry in irh ntilying time califirn,ia Nalhie Anwrionl Irilx>Iliad art•fnulilionally and ruRnrally athiialell rail,liar impel
arm." lea midifim,,please see tla u,ap helme.
CC.NAHC
APPENDIX 1: Map 1-2:Bean and Smith 1978 map.
cs cr.
Ike!!ma n 1
�aa
coram.
M
li1`�1
luno("eu1w I
SwR rein/ s �lw
r
Tu
Fig.1. Tribal mmmry-
The United$tales National Museum's Map of Ganneimo Territory
Bean.Lowen John ate Charles N Smnh
1978 Gannehm IN H9nanoaA of Abrrh American lMmns.
Celaomm.Vol 8.ended by R F Hader Smansonian
Instaunon Press.Washington.D .X 5M 549
Andrew Was.CNnman Nadine Sala,.Ve.-Ch.nein QamraswmEall Mammalsenebry
Alpert Pertt neawrerr. MarthaG uk,demo,.neaswen u aklagarada,. Chirnewrdfewaximlldi Fbn,
f05-N393 Cbvi-,CA917Z5 www.¢aLnc�enolnAlanwcanalroamm e"a6nclenomrlian.<tayalrno.com
Lead Agency: City of Newport Beach SCH No. 2016011032
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■� ENVIRONMENTAL IMPACT REPORT F.0 FINAL ENVIRONMENTAL IMPACT REPORT
Gabrieleno Band of Mission Indians—Comment Letter F
F-1:
The City of Newport Beach acknowledges the information provided by the commenter indicating
that the Project site is located within the ancestral and traditional territories of the Gabrieleno Band
of Mission Indians-Kizh Nation. The potential for impacts to archeological resources was evaluated
in EIR Subsection 4.4. Although the Project site is fully developed in the existing condition and has
been disturbed by previous development activities, which would reduce the likelihood that
archeological resources would be encountered during project construction, the EIR identifies a
potentially significant direct impact to archeological resources in the event that significant resources
are unearthed during the Project's construction process. Mitigation Measure MM 4.4-1 is included in
the EIR which specifies the measures that would be taken if potential archaeological resources are
discovered. The implementation of MM 4.4-1 would reduce the potential for impacts to less than
significant. Accordingly, because the impacts to archeological resources are mitigated to a level that
would be less than significant with the incorporation of MM 4.4-1,no additional mitigation including
Native American monitoring of construction activates, would be required. A condition of approval
has been added to the project as follows, "During construction activities, the project applicant shall
allow representatives of cultural organizations, including Native American tribes (i.e., Gabrieleno
Band of Mission Indians), to access the project site on a volunteer basis to monitor grading and
excavation activities."
Lead Agency: City of Newport Beach SCH No. 2016011032
Page FEIR-21
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COMMENT LETTERS
Comments on EIR for 150 Newport Center Drive:
1. Regarding paragraph 3.5.3 PLANNED COMMUNITY DEVELOPMENT PLAN TEXT-Please explain how this project
qualifies as a Planned Community District(PCD)considering each of the following inconsistencies with the
Chapter 20.56 of NPB zoning code.Please include a rational for considering this proiect a planned community
development considering the almost total disconnect from the description and intent of section 20.56 of the city
code.
a. 20.56.010
i. Inconsistent with paragraph A-This project is not a"large-scale community".
if. Inconsistent with paragraph B-This"community"of condos does will not contain
"diversification of uses"
b. 20.56.020
i. Inconsistent with paragraph A-Project at 1.25 acres is just 12.5%of minimum acreage of 10
acres required for a PCD G-1
c. 20.56.030
I. Inconsistent with paragraph A-la—The"Existing Use'as commercial(car wash)isnot
"incorporated as part of the approved development plan".
if. Inconsistent with paragraph A-lb—nor will it be"Allowed to continue"
ill. Inconsistent with paragraph B-1—This is"A use,other than a use existing at the time of
establishment of a PC District,shall not be allowed in a PC District except in compliance with a
valid PC development plan."This project fails to qualify for"a valid PC development plan"based
on inconsistencies noted under section 20.56.010 and 20.56.020 above.
iv. Inconsistent with paragraph B-2—This is not a use authorized by the current zoning for the
property.
2. Regarding paragraph 4.1.2 A and Table 4.7-2.Local Regulations Policy bullet point Policy NR 20.3
a. Please explain how the introduction of a 75-foot structure between Newport Center.Drive(listed)and
the coast will:
i. "Protect and,where feasible,enhance significant scenic and visual resources..."as stated in G-2
Policy NR 2.1.
if, "Protect and enhance public view..."as stated in Policy NR 20.3.
b. The View Simulation—View 2,page 4-1-16,illustrates this intrusion of the proposed building into the
current view from Newport Center Drive.How is this consistent with stated General Plan Goal NR 20? G"3
3. Regarding section 4.1 AESTHETICS,page 4.1-22 and Table 4.7-2 page 4.7-30>4.7-11.The building is compared to
existing massive structures located on San Joaquin Hills Road and also on San Miguel Drive.These are NOT
located in the immediate vicinity of the project.As stated in the EIR:"rhe General Plan Land Use Element
includes Policy LU 6.14.14(Development Scale)that encourages the concentration of the greatest building mass
and height in Newport Center in the northeasterly section along San Joaquin Hills Road with a progressive G-4
scaling down of building mass and height toward the southwesterly edge along East Coast Highway."Please
explain how a comparison of this project located in the south portion of Newport Center to buildings located in
the east and northeast portion of Newport Center is consistent with LU 6.14.14 of the General Plan.
4. Regarding Table4.7-2,discussion of Policy LU 3.2—"...the Project would replace a non-viable commercial use.."
What documentation exists that confirms that the current use as a carwash is"a non-viable commercial use"? G"5
5. Please explain the basis for the following statement in section 5.0,page 5-3:"rhe placement of a seven-story
residential building on the Project site,in the southern portion of*Newporl Center where buildin.-hei.-his are
generally lower,would not reasonably or lbreseeably cause the redevelopment of other properties or cause
development on other properties with taller buildings than current%oning designations allow."'rhe opposite G-6
would seem likely.The 2006 GP does not set hei.-ht limits for the arca,however the height limits in the area,
as a result of PC regulations and PC texts has been increased in the area.-These increases have ranged tiom
32 Icer to 50 feet,but this j-or commercial mixed use structures.In the reply please explain how the
introduction of precedent setting spot zoned 7 story residential strucnne 0tonnal height limit 2S feet)
Lead Agency: City of Newport Beach SCH No. 2016011032
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COMMENT LETTERS
"would not reasonably or foreseeably cause the redevelopment of other properties or cause development on G_6
otherprouerlies with taller buildings"since the profit motive would be very strong to replace existing
commercial with high rise residential. (cont.)
6. Regarding the following statement in section 5.0,page 5-4:"Furthermore,the Project's potential influence on
other nearby properties to redevelop at greater intensities and/or different uses than the Cin•'s General Plan,
Zoning Code,and Site Plane Ordinance allow is speculative beyond the rule of reason"Why is this
considered"speculative beyond the rule of reason".since the replacement of commercial use with residential G-7
is exactly what this proqect is doing and indeed the profit incentive for replacing commercial with residential
is currently very high?
Respectfully submitted,6/15/2016
Dennis Baker
706'/,Begonia Avenue
Corona del Mar
949.274.3226
Dennws.Bakerffi)DiAnd Den.net
Lead Agency: City of Newport Beach SCH No, 2016011032
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Dennis Baker—Comment Letter G
G-1:
CEQA Guidelines Section 15125(d) specifies that any inconsistencies between a proposed project
and "applicable general plans, specific plans and regional plans" must be discussed in an EIR. As
directed by CEQA, discussion of the proposed Project's potential inconsistencies with the City's
General Plan and applicable regional plans is contained in the EIR. An EIR is not required by the
CEQA Statutes or Guidelines to discuss consistency or inconsistency with zoning regulations, such
as those contained in the Newport Beach Municipal Code. The Project's proposed Zoning Code
Amendment and Planned Community(PC) Development Plan Text are described in FIR Subsections
3.5.2 and 3.5.3, respectively, as part of the EIR Project Description, and evaluated throughout the
EIR's environmental analyses. The City is obligated to consider the information contained in the
Final EIR and the Project's Administrative Record during its deliberations concerning the proposed
Project, but the purpose of an EIR is not to determine whether a PC zone is appropriate or
inappropriate. This is policy decision that is beyond the parameters of CEQA.
G-2:
Policy NR 2.1 identified in the City of Newport Beach General Plan Natural Resources Element
pertains to recycled water use. However, it is assumed in this response that the commenter is
referencing Policy NR 20.1, which indicates the City's policy to "[p]rotect and, where feasible,
enhance significant scenic and visual resources that include open space, mountain, canyons, ridges,
ocean and harbor from public vantage points, as shown in Figure NRY. An evaluation of the
Project's consistency with Policy NR 20.1, as well as the Project's consistency with General Plan
Policy NR 20.3 "[plrotect and enhance public view corridors from the following roadway segments
(shown in Figure NR3), and other locations may be identified in the future...." is contained in EIR
Subsection 4.1, Aesthetics, under Impact Analysis Threshold (a). Analysis of these policies also is
contained in Table 4.7-2 of EIR Subsection 4.7, Land Use and Planning.
Figure NR3, Coastal Views, of the General Plan Natural Resources Element shows that the closest
Coastal View Road to the Project site is a portion of Newport Center Drive that runs parallel to
Anacapa Drive, about 800 feet west of the Project site. The portion of Newport Center Drive that
provides views of the Pacific Ocean occurs west of the Project site, with views toward the ocean
available to the west, away from the Project site. The view corridor along Avocado Avenue
identified in Figure NR3 occurs between San Joaquin Hills Road to East Coast Highway with views
to the southwest toward the Pacific Ocean. The proposed Project's building would be screened from
views from Avocado Avenue by intervening development and landscaping. The EIR's analyses of
view corridors along MacArthur Boulevard from San Joaquin Hills Road to East Coast Highway
identified in Figure NR3 determined that the proposed Project would not inhibit views of the Pacific
Ocean because although the proposed Project would be constructed within the general direction of
views of the Pacific Ocean, views of the lower floors of the building would be completely screened
by intervening buildings and landscaping and views of the two uppermost floors would be only
intermittently possible in the distance when looking due northwest. From this location, the Pacific
Ocean is visible looking due south and slightly southwest, and not due northwest in the direction of
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the Project site. Accordingly, the distant views of the proposed building due northwest would not
substantially affect views of the Pacific Ocean along this view corridor. The impact to scenic views
from this location would, therefore, be less than significant as concluded in the EIR.
G-3:
The commenter identifies that views of the proposed Project shown in View Simulation 2 (Figure
4.1-6 on page 4.1-16 of the EIR) show that the Project would be visible from Newport Center Drive
and questions the consistency of the Project with General Plan Policy NR 20.3. As shown on Figure
4.1-4 of the DEIR, the segment of Newport Center Drive that is associated with a view corridor
(identified in the General Plan as a "Coastal View Road") is the roadway segment that runs parallel
to Anacapa Drive approximately 800 feet west of the Project site, as discussed on EIR page 4.1-11.
The view of the Project site shown in View Simulation 2 does not depict views of the Project from
the portion of Newport Center Drive that is identified as a Coastal View Road, and the Project would
not be visible from the segment of Newport Center Drive that is designated as a Coastal View Road.
Also refer to Response G-2, above.
G-4:
This comment quotes the City's General Plan Land Use Element Policy LU 6.14.4 (not 6.14.14 as
indicated in the comment). General Plan Policy LU 6.14.4 does not address measured building
heights, but speaks qualitatively to encouraging the placement of tall buildings in the northeastern
portion of Newport Center and scaling down toward the southwest. Thus, the FIR appropriately
disclosed a representative sample of building heights both in the northeastern portion of Newport
Center, as well as in the southwestem portion in order to address Policy LU 6.14.4's qualitative
concept of scaling down building height from the northeast to the southwest. Also refer to EIR
Subsection 4.7, Land Use and Planning, Table 4.7-2, Proposed Project General Plan Consistency, in
which representative building heights from both the northeastern and southwestern portions of
Newport Center are disclosed. Attached to this response is an exhibit which shows existing building
heights in the southerly half of Newport Center on an aerial photograph for context.
FIR Subsection 4.1, Aesthetics, analyzes the proposed Project's potential to degrade the visual
character of the site and its surroundings (Subsection 4.1.4, Threshold c). The basis for determining
significance under Threshold c) is presented in EIR Subsection 4.1.3, which states: "Regarding the
determination of significance under Threshold c), if the character or quality of the Newport Center
area, including both publicly- and privately-owned properties, would be degraded, the impact will be
regarded as significant. The degradation of private views (as opposed to public scenic viewsheds) is
not considered a significant adverse impact. See Mira Mar Mobile Community v. City of Oceanside
(2004) 119 Cal.AppAth 477. In this context, "degrade" will mean the introduction of physical
features that would have a demonstratively inconsistent character and/or would be constructed with
inferior design characteristics than currently found in the Newport Center area, based on the
independent judgment of the City of Newport Beach." Thus, a potential degradation in visual
character was appropriately evaluated in the context of the Newport Center area and not only
immediately surrounding private properties (EIR pp. 4.1-20 through 4.1-23).
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The proposed Project, as would be viewed from both nearby and distant vantage points, would be
within the same viewshed as other buildings within the Newport Center area including buildings
immediately adjacent to the Project site and taller buildings that occur within the northern portions of
Newport Center. The only vantage points from which the taller buildings would not be within the
same viewshed as the proposed Project's building are points immediately northwest or northeast of
the Project site, looking toward the south. Accordingly, the impact analysis presented in the DEIR
properly evaluated the proposed Project within the context of the viewsheds in which the Project
would be typically viewed. Moreover, the DEIR fully disclosed that the height of the proposed
structure would be taller than the buildings that occur immediately adjacent to the Project site and
concluded that the height difference would not result in significant adverse physical environmental
impacts. The proposed Project's building would not have a substantial adverse effect on a scenic
vista (DEIR Subsection 4.1, Threshold a.), would not be visible from a State scenic highway (DEIR
Subsection 4.1, Threshold b.), would not substantially degrade the existing visual character or quality
of the site and its surroundings (as explained above; DEIR Subsection 4.1, Threshold c.), and would
not create a new source of substantial light or glare that would adversely affect views (DEIR
Subsection 4.1, Threshold d.).
G-5:
The Project Applicant provided a letter to the City cited in the FIR as "(Soderling, 2016a [the
amended letter is referenced as Soderling, 2016b])"which states that ongoing use of the site as a car
wash is not viable. The Applicant's letter is provided as an attachment to this response for reference.
G-6:
CEQA requires that an FIR evaluate reasonably foreseeable growth-inducing impacts of a project,
but not speculative effects. See Federation of Hillside & Canyon Ass'ns v. City of Los Angeles
(2000) 83 Cal.AppAth 1252, 1265. The CEQA Guidelines provide two examples of growth-
inducing impacts: 1) a project that would "...remove obstacles to population growth (a major
expansion of a waste water treatment plant, might, for example, allow for more construction in
service areas)'; and 2) "[i]ncreases in the population may tax existing community service facilities,
requiring construction of new facilities that could cause significant environmental effects" (Cat. Code
Regs., tit. 14 § 15126.2, subd. (d)). In this case, the Project is not proposing to add infrastructure
facilities with increased capacity to serve other projects (e.g., oversized sewer or water lines, etc.),
nor would the proposed Project result in a significant increase in the City's population such that
existing community service facilities would need to be upgraded or expanded (refer to the Initial
Study [Appendix A of the DEIR) for an analysis of potential Project-related impacts to public
services and facilities). Moreover, the CEQA Guidelines require that an EIR discuss "...the ways in
which..." a project could foster growth, and under this standard an EIR is not required to provide a
detailed analysis of a project's effects on growth; rather, a general analysis is sufficient." (Cal. Code
Regs., tit. 14 § 15126.2, subd. (d); see also Napa Citizens for Honest Gov't v. Napa County Bd. of
Supervisors (2001) 91 Cal.AppAth 342, 367-371.) Section 5.3 of the EIR provides sufficient
analysis of growth-inducing impacts.
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If the City approves the proposed Project, such approval would be based in part on the individual
merits of the Project. The degree to which the proposed Project may or may not establish a precedent
for future actions (including but not limited to potential future proposals by others to construct
buildings in south Newport Center taller than current zoning designations allow) will be considered
by the City in its discretionary decision-making processes on the Project's applications. Nonetheless,
potentially setting a precedent is not the same as non-speculative growth inducement. Because
discretionary actions would need to be taken by the City in order to approve any future project that
would propose to construct a building taller than the property's zoning designation allows (as is
currently under consideration for the proposed Project), the Project would not establish legal grounds
that could be used as a standard for subsequent projects. No credible evidence has been supplied by
the commenter to indicate that the Project would unquestionably induce the redevelopment of other
parcels in south Newport Center in ways that would exceed Municipal Code building height limits.
Furthermore, an EIR is not required to forecast and mitigate for development described as induced
growth. "Neither CEQA itself, nor the cases that have interpreted it, require an FIR to anticipate and
mitigate the effects of a particular project on growth in other areas. (Napa Citizens for Honest
Gov't v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 371) Such issues are best left
to the time that the resulting development is proposed. (Id. at p. 372 fii. 8.) When a project's growth-
inducing impacts are speculative, the lead agency is required to consider CEQA Guidelines § 15145,
which provides that, if an impact is too speculative for evaluation, the agency should note this
conclusion and terminate discussion of the impact.
G-7:
Please see Responses G-5 and G-6, above. Project approval would be based in part on the merits of
the proposed project. This is the case for the current proposal and all future proposed projects. The
degree to which the proposed Project may or may not establish a precedent for future actions
(including potential future proposals to replace commercial uses with residential uses in south
Newport Center) will be considered by the City in its decision-making processes on the Project's
applications. Nonetheless, potentially setting a precedent is not the same as non-speculative growth
inducement. The Project is not proposing to add infrastructure facilities with increased capacity to
serve other projects (e.g., oversized sewer or water lines, etc.), nor would the proposed Project result
in a significant increase in the City's population such that existing community service facilities
would need to be upgraded or expanded (refer to the Initial Study [Appendix A of the DEIR) for an
analysis of potential Project-related impacts to public services and facilities). The "profit incentive"
of possible future applicants, even if"currently very high, is speculative and no substantial evidence
has been supplied by the commenter to indicate that the Project would unquestionably induce the
redevelopment of other parcels in south Newport Center in ways that would replace commercial uses
with residential uses. When a project's growth-inducing impacts are speculative, the lead agency is
required to consider CEQA Guidelines § 15145, which provides that, if an impact is too speculative
for evaluation, the agency should note this conclusion and terminate discussion of the impact. Such
is the case with this comment.
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Existing Building Heights in Newport Center
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a
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*data is based on building permit elevations
3J�
April 13, 2016
Ms. Makana Nova
Associate Planner,AICP
Planning Division, Community Development Department
City of Newport Beach
100 Civic Center Drive
Newport Beach, CA 92660
Re: 150 Newport Center Drive
Dear Ms. Nova:
We are the managing partners of Newport Center Anacapa Associates, LLC which owns the
referenced property and through an affiliated company operates the car wash on site. The
car wash is over 40 years old and due to technology changes is rapidly becoming functionally
obsolete. The new"Tube Concepts" require significantly less labor, less water and frankly
provide a better wash at a fraction of the cost. Several of the new washes have already
replaced other formerly Beacon Bay locations.
We acquired the property with full knowledge that the car wash was no longer the best use
for the property and that the business would no longer support the land value and purchase
price. The new technology(completion) and increased labor cost has priced us out of the
market. Our management company has been informed of our plans to close the wash and
will be winding down on the site activity in the fourth quarter of this year.
While we are optimistic that our plans to build residential on the site will be met with
favorable results,we will regardless of the outcome close the wash and fence the site until
the new land use is resolved. Please don't hesitate to contact either of us should you have
any questions.
`Scerely,
/ Ronald S erling
Managing Member
Michael W
Managing Member
cc: Tod Ridgeway
Addendum: The most significant component of the car wash is labor cost and with the
change of the minimum wage to$15 per hour these cost now make car washes economically
infeasible. A new car wash only employs 2 to 3 people as opposed to 25 on our site.
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COMMENT LETTERS
IRVINE COMPANY
Since 1864
June 24,2016 OCEIVED a�
COMMUNITY
City of Newport Beach JUN 28 2016
Attn:Makana Nova
100 Civic Center DriveDEVELOPMENT or
Newport Beach,CA 92660 o3 OF NEWPOat 0�r
Subject: 150 Newport Center Draft Environmental Impact Report(DEIR)Comments
Dear Ms.Nova:
Irvine Company offers the following comments on the 150 Newport Center DEIR that was
released for public review from May 15 to June 27. 2016. Comments have previously been
submitted by Irvine Company in response to the Mitigated Negative Declaration and the f•I-�
subsequent Notice of Preparation for the DEIR. Included herein are comments from previous
correspondence in addition to our comments on the DEIR where the DEIR was either lacking in
information or did not respond to the previous comments satisfactorily.
Ingress/Egress
In response to previously identified concerns regarding an existing easement along the southern
boundary of the Project site, the DEIR states: "The underlying property owner's authorization
would be required for any site improvements to this area. Special land use restrictions(SLURS)
exist between Irvine Company and the existing car wash that provide for an easement for H 2
ingress/egress along the southern boundary of the project site. The easement was established
through a grant deed recorded in 1992.The easement restrictions would remain in effect should
the proposed project be approved by the City of Newport Beach."This correctly states the need
for authorization by Irvine Company for work within the easement.
The DEIR notes that the existing median located immediately south of the site would be filled in
and landscaped to direct traffic Flow in and out of the southem garage entry/exit.The median is
currently in two segments allowing left turn egress from the car wash.The Project proposes to
fill in the open space between segments resulting in a continuous landscaped median. The
median design should be evaluated to ensure that left turns out of the garage can be safely and H-3efficiently executed by all vehicle types anticipated to utilize this exit without creating a hazard
to pedestrians or oncoming traffic.As shown on Project exhibits,the angle of the median would
not support a tell tum motion out of the garage for larger vehicles. Property owner authorization
for the reconfigured median south of the Project site should be required prior to the issuance of
building permits as a condition of approval for the Project.
550 Newport Center Drive,Newport Beach,CA 92660 949.720.2000
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Page 2 of 8
Pedestrian Access
The DEIR grading plan and the Title Constraints Exhibit show an existing 18-foot-wide
reservation for pedestrian use along the southern boundary access roadway.The easement is also
shown on the Vesting Tentative Tract Ntap with a note that the easement is to be removed,
although there is no additional detail in the DEER. The Project proposes to eliminate the
reservation and proposes a 5-foot sidewalk along its southerly boundary. While it could be H-Q
appropriate to reduce the width of the reservation to match the width of the proposed sidewalk,it
is not appropriate to completely remove this reservation, as this existing means of pedestrian
access to Gateway Plaza should continue to be provided. The Conceptual Design Exhibits
indicate that a pedestrian walkway has been provided along the southern access roadway,and we
offer this comment to ensure that adequate pedestrian access remains part of the Project.
Aloving Vans
The DEIR and the appendices are internally inconsistent in their descriptions of moving van
access. The DEIR identifies a plan showing that moving trucks and delivery vehicles will
temporarily park to load/unload at the guest access point along Anacapa Drive. The Planned
Community Development Plan(PCDP)also states on page 3 that moving tan access and general
delivery will occur at the main building entry off Anacapa Drive. However, we note that
Appendix G2 —Site Circulation Plan dated September 1, 2015 contains text as follows: "The
move-in/out trucks are expected to temporarily park on the north side or the two-way drive aisle
on the south side of the complex (see Figure 9). Adequate width shall be provided to allow
vehicles to by-pass the move-in/out trucks." The referenced Figure 9 clearly shows the
circulation plan for moving trucks with the trucks stopping at the resident garage access on the
southern boundary of the site,which is inconsistent with the text in the DEIR.
In addition,the Preliminary Construction Management Phan dated March 25,2016 notes on page _
5 that level 13-1 on the southern boundary allows for tenant access, moving van access, and H-5
general delivery. CEQA requires that facts presented for environmental analysis be consistent
and precise to adequately inform the public about the project. This inconsistency between the
DEIR and the Circulation and Construction Management Plans must be resolved to ensure that
moving vans and general delivery trucks are not allowed to load or unload on lie southern
boundary of the site thereby eliminating die possibility of a hazardous and unsafe condition with
regard to traffic and pedestrian movement. It should also be noted that larger moving-related
vehicles are not likely to be able to make the U-turn shown on Figure 9.
An important related issue is: While the DEIR contains references to both moving vane and trash
trucks parking partially on the sidewalk along the southerly edge of the Project, how much of
that sidewalk is realistically available for this use?The Conceptual Design Exhibit shows a width
of 7.3 feet from the southerly curb of the adjacent private drive to it wall with a hedge and a
5-foot sidewalk proposed adjacent to the access drive. furthermore, the Architectural Rendering
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(Figure 3-5) indicates that multiple street lighting fixtures will be located within the 7.3-fool-
wide area between Anacapa and the Project's access drive. In addition, the-tentative Map and
the Conceptual Utility Plat propose that a"modular wetland unit for storm water treatment"will
be located within the sidewalk for the fust 25 to 30 feet easterly of the Project access drive, H-J
which could reduce the area where moving vans and trash trucks could park partially on the (cont.)
sidewalk. The concern is that there may be minimal ability for larger moving vehicles to park
partially on the sidewalk, therefore negatively affecting the ability to utilize the sidewalk for
pedestrian movement as well as negatively impacting the safety and efficient use of the adjacent
Block 100 access.
Trash Trucks
As noted in the DEIR, trash trucks would park along a rolled curb area on the drive aisle along
the southern portion of the building. The trucks would move partially outside of the paved
driveway area to avoid impeding vehicular access at the driveway.The trash bins will be brought
by a scout trek from the storage area to the residential access drive for pick-up.While the DEIR
states that a rolled curb will be installed along the southerly access road to assist trash trek
movement partially off the roadway,no text or graphic depiction shows(he length of the rolled
curb or whether the entire curb will be rolled. Furthermore, as discussed in the previous
comment,several factors could limit the area where overlapping parking on the sidewalk could
occur. It is important that this issue receive further study to assure that the existing vehicular and
pedestrian access will not be significantly affected. In addition, as depicted on Figure 9 of the
Site Circulation Plan, it appears that trucks would be required to make a wide U-turn to exit to
Anacapa,potentially obstructing traffic entering and exiting Block 100 from that access roadway
and creating an unsafe condition. It is important that this issue receive further study to assure that
the existing vehicular and pedestrian access will not be significantly affected. In addition, as
depicted on Figure 9 of the Site Circulation Plan, it appears that (nicks would be required to H-6
make it wide U-turn to exit to Anacapa,potentially obstructing tragic entering and exiting Block
100 from that access roadway and creating an unsafe condition. A turning radius exhibit or
analysis should be provided to demonstrate that a trash truck can safely make a U-turn.
7-he DEIR does not include measurements identifying the street width or any substantive
information(hat would support the conclusion that there is adequate width for cars to pass when
a trash truck is parked at the proposed trash pick-up location. During the recent Planning
Commission Study Session for the Project, staff indicated that Public Works analyzed the
proposed plan and stated there was adequate width to allow vehicles to pass by the (rucks. The
PCDP stales on page I 1 that trash pick-up and staging shall not block vehicular access through
the southerly access drive. However, given lite lack of specific infbnnation, we cannot concur
with either the applicant or the City that (here is adequate room for safe vehicular passage
alongside parked trash trucks.
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There is no condition of approval of mitigation measure proposed to ensure adequate room for
vehicle passage. Design criteria must be identified, including precise distances acid widths. As
noted,the PCDP contains(lie requirement that vehicular access shall not be blocked. The DEIR
does not provide any information containing dimensioned plans demonstrating that adequate
width will be provided. We request that mitigation or a condition of approval be included in the
DEIR to address provision of adequate passing room for typical sized vehicles using this
roadway to access Gateway Plaza.
Most importantly, and as noted in previous correspondence to the City, we reiterate that the H-6
easement associated with the southern access roadway is for i»gress/egress only and not for trash (cont.)
truck parking or trash pick-up. The applicant should not be permitted to rely on another
landowner's property to provide an integral service for the applicant's Project. The Project
should be redesigned to keep all truck traffic, including trash trucks,moving vans,and delivery
trucks, within the boundary of the applicant's property in order that the Project's use of the
Block 100 access drive can be limited to ingress and egress in conformance with the conditions
established in the existing easement Failure to properly accommodate truck traffic within the
property demonstrates the unsuitable size and design of the proposed Project.
Project Drainage
As indicated in Note 431 on the Conceptual Utility Plan,drainage from die Project is proposed to
connect to an existing private catch basin located outside the Project boundary. Because the
subject catch basin is located on Irvine Company property and because information regarding H_7
potential changes in the flow characteristics are not included, the Project should be conditioned
to provide the proposed drainage plans to the Irvine Company for review and approval prior to
construction of the subject connection to the catch basin.
Construction Staging and Traffic
The DEIR states(hat construction is estimated to commence in the first quarter of 2017 and last
for approximately 21 months. We request further information regarding the following elements
of the Construction Management Plan and traffic impacts on Newport(Center Drive and Anacapa
Drive.
• Lane Closures — The timing of land closures is unclear. The DEIR indicates that
temporary street and sidewalk closures will occur "from time to time" and for short H-8
durations of less than two weeks. Please describe how often the closures could occur
along Anacapa and the southern access roadway. Would the length of the closure be daily
for two weeks or in smaller segments of days for a cumulative total of`less (hall two
weeks?"
• Very little detail is provided about potential lane closures on Newport Center Drive. It is
imperative that closures of more than one lane in either direction should not be allowed at
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any time and that no lathe closures would be allowed during the holiday season. A
specific mitigation measure or condition of approval should identify the dales during
which closures are prohibited. H-B
• Newport Center Drive and Anacapa Drive will experience temporary lane closures in (cont.)
order to implement utility connections as noted in the DEIR Project Description.
Mitigation should be included that requires the Traffic Control Plan to ensure that
closures on Newport Center Drive are conducted during off-peak hours with adequate
advance notice posted for tenants and visitors to Newport Center.
• A mitigation measure or a condition of approval should be included to prohibit closure of
the existing access drive from Anacapa at any time,as this is an important point of access
For much of Block 100.
• With respect to vehicle queuing during construction,the Construction Management Plan H-9
identifies the need for queuing of cement trucks. The DEER should include a mitigation
measure or a condition of approval that prohibits blocking or entering any private
property, including driveways, as a result of the queuing of any vehicles during
construction.
• Off-Site Parking—It is not clear whether the Tennis Club has enough excess parking to
accommodate the 50 spaces proposed. 'The DEIR must analyze whether such capacity
exists. The Memorandum of Understanding is in draft form and not signed. Is there a
contingency plan if the'I'ermis Club does not have adequate parking for its own operation H-10
and the construction parking? Parking in spaces within Newport Center/Fashion Island
must be strictly reserved for tenants and visitors and prohibited for construction
personnel.
• Construction Safety—The Construction Management Plan includes Exhibit B-1, which
shows the extent of the construction crane swing rttdius.The DEIR does not analyze the
operation of the crane as a potential safety hazard. The document fails to acknowledge
that the crane swing radius extends over Irvine Company property including the internal
roadway and areas where vehicles would be parked. ht addition,the crane swing radius is
also shown to occur over the entire width of Anacapa as well as a portion of private H-1 1
property to the east. Due to the potential safely issues for pedestrians and private vehicles
that could result foul operation of the crane in this manner, a condition of approval
should be included that precludes any crane swing over any portion of Anacapa as well as
adjacent private property to the cast and private property to the west of the Project site.
Lighting
There is an inconsistency in the way the streetlights are depicted in the DEIR and the
atlacfuncnts.The Conceptual Design Exhibits(.40.0,A2.2 and A4.2)show the lights are located
on the upper sidewalk of the southerly building frontage. However, sheet AU and Figure 3-7 hi-1 2
(DEIR- page 3-28)depict the lights as located on the lower level leading to the parking garage
entrance. In both views, the lights would be located on the curb side of the walkways. No
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information in the DEIR discloses whether the sidewalk width will be reduced or if the light 1 H-12
placement would be outside the pedestrian pathway.These inconsistencies should be resolved. SII (cont.)
Consistency With City Standards and Piecemealing
The Project proposes adoption of a Planned Community(PC)text for the purpose of increasing
the height limit from 32 feet to 83.5 feet.The City's Zoning Code limits building height in Block
100 to 32 feet(37 feet with a sloped root),or up to 50 feet(55 feet with a sloped root)with the
adoption of a PC or other discretionary approval.The PC text would exceed the 50-foot height
limit expressed in the Zoning Code by more than 30 feet.
The 150 Newport Center Project site represents 1.26 acres of the overall 13-acre block.The four
comers of Block 100 are conventionally zoned OR-C(Office Regional Commercial), while the
interior of the block is pan of the larger North Newport Center PC. The City's Zoning Code
requires that a PC district have a minimum 10-acre site; as slated within the DEIR, it will be
necessary for the City Council to waive the minorum acreage requirement in adopting a PC for
the 1.26-acre Project. The entire block should be considered in determining the height increase
that is a foreseeable consequence of the proposed Project.
The Project site is located at the highest elevation within Block 100 at 170 feet above mean sea
level (AINISL). The remainder of the block slopes downward and away from Newport Center
Drive towards Civic Center Drive with elevations of 120 to 140 feet AMSL at the southerly
corners. The building height of 83.5 feet will be prominent in this location, where the H-13
surrounding land uses consist of single-and double-story buildings.Irvine Company anticipates
that property owners in the remaining 11.74 acres of Block 100 will request the application of a
consistent height limit for the entire Block. Rather than piecemeal the height increases, an
increase in the height limit for the remaining properties should be processed concurrent with the
150 Newport Center Project.
The growth inducement from the 150 Newport Center Project is incontrovertible, and a height
increase for the remaining properties is the logical nest-step.No further visual impacts will be
associated with an increased height limit for the remainder of the block, because the ground
elevation for these other properties is lower than the Project site.The analysis contained with the
DEIR can be relied upon to increase the height for the entire block.
As indicated above, the height limit for all properties within Block 100 should be increased
commensurate with that proposed for 150 Newport Center. This height increase should be
processed concurrent with 150 Newport Center given that this is a direct inducement resulting
Brom the proposed Project.Without the proposed Project,the greatest height limit would be 50(o
55 feet with discretionary approval.
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COMMENT LETTERS
Makana Nova
June 24,2016
Page 7 of 8
Airport Land Use Commission(ALUC)/Airport Environs Land Use Plan(AELUP)
The Project Description at page ES-4 lists the actions required for approval of the Project
including a General Plan Amendment, a Zoning Code Amendment and a Planned Community
Development Plan. With regard to applicability of ALUC and AELUP policies,page 4.6-14 of
the DEIR stales that"...the northerly one-third of the Project site is located within the AELUP
Part 77 Notification Area for TWA." However, DEIR analysis of consistency with the
requirements of ALUC and the AELUP concludes that the Project does not require submittal to
ALUC for review (DEIR pages 4.6-8 and 4.6.14). Following are sections from die AELUP
outlining the types of projects that require ALUC review(underlining added).
The AELUP,on page 2,Section 13-Authority-states that:
"Section 21676(b)of the Public Utilities Code requires that prior to the amendment of a
general plan or specific plan, or the adoption or anmoval of a zoning ordinance or
building regulation within the planning boundary established by die airport land use
commission pursuant to Section 21675, the local agency shall first refer the proposed
action to the commission."
Page 27,Section 4.3-Amendments to General Plans and Specific Plans(Zoning)states: H-14
"Within the AELUP planning areas... any amendment to a General Plan or Specific Plan
(including conventional zoning and Planned Communities) must be submitted to the
Commission for a determination prior to its adoption by dnc local aeenct�"
Section 4.4-Zoning Ordinance and Building Regulations states:
"Within the AELUP planning areas .... any 11170ROsed changes to a zoning ordinance or
building regulation must be submitted to the Commission for a determination prior to its
adoption by the local agency."
It appears the City is basing its conclusion that the Project does not require ALUC submittal on
building height alone without additional consideration of the requirements noted above for
submittal when General Plan and zoning amendments are proposed Any property located within
the AELUP Pan 77 Notification Area that requires a General Plan Amendment and/or zoning
amendments must be referred to the ALUC prior to final City approval. This is separate from
height notification as discussed in the DEIR. This Project requires referral to the ALUC prior to
City Council action.The DEIR should provide additional analysis based on Sections 1.3,4.3 and
4.4 of the AELUP.
Conclusion
The inconsistencies related to moving van loadinglunloading, functional street width available
with moving vans and/or trash trucks parked, lane closures during construction, and light pole H-15
locations must be resolved in order to present a more accurate depiction of potential impacts
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COMMENT LETTERS
Makana Nova
June 24,2016
Page 8 of 8
related to safety and circulation.Additional information related to conclusions about construction
personnel parking availability, potential safety issues regarding cranes, and ALUC review is
required to allow the public a more complete understanding of impacts where the DEIR has
concluded "no impact' or "less than significant impacts." We conclude that the DEIR lacks
adequate detail and must include more thorough and consistent information.
Thank you for the opportunity to review the DEIR and provide these comments and H-15
observations.
(cont.)
Sr cerely,
Dan Miller
Senior Vice President
Entitlement and Public Affairs
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Irvine Company—Comment Letter H
H-1:
The commenter accurately identifies the public review period for the DEIR, and the City of Newport
Beach acknowledges that the commenter had previously provided comments on the Mitigated
Negative Declaration (MND) and the Initial Study for the proposed Project. The prior comment
letters are part of the Project's Administrative Record.
H-2:
Comments are noted acknowledging the accuracy of information presented in the DEIR. Please note
that the City intends to apply a condition of approval on the Project that would require the
authorization of the underlying property owner for any site improvements proposed within the
southern ingress/egress easement.
H-3:
Refer to Response H-2. The City's Public Works Department reviewed the proposed median
improvements as part of its evaluation of the Project plans and determined that adequate ingress and
egress movements can be made from the Project's proposed parking garage. The median would end
at the garage entry/exit allowing for proper vehicle movement from the Project's parking structure in
a manner that would not result in hazards to vehicular and non-vehicular traffic. Please note that the
City intends to apply a condition of approval on the Project that would require the authorization of
the underlying property owner for any site improvements proposed within the southern ingress/egress
easement.
H-4:
The commenter inaccurately characterizes the proposed modification to the pedestrian access
easement within the Project site by concluding that the pedestrian access easement would be
removed. The Project's proposed Tentative Tract Map indicates that the 18-foot wide easement
along the southern edge of the Project site would be reduced to a 5-foot width and would be
maintained as a pedestrian access easement. Furthermore, the City intends to impose a condition of
approval on the Project to require provision of the 5-woot wide pedestrian easement within the
southern portion of the Project site.
H-5:
Moving vehicle access to the Project site would occur at the main building entry off Anacapa Drive
and trash pick-up would occur at the south driveway off of Anacapa Drive. The Site Circulation Plan
provided in Appendix G2 of the DEIR is a draft. The Project Applicant prepared and submitted a
Final Site Circulation Plan, which will include updates to indicate that moving vehicles will access
the building at the main building entry. The specific placement of each lighting fixture will be
determined as part of construction drawings prepared in association with a building permit
application. The lighting plan is required to be reviewed by City staff to ensure compliance with
applicable City codes and standards related to exterior lighting. The City intends to impose a
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condition of approval on the Project that would require that the 5-foot pedestrian access easement
remain clear of permanent structures.
H-6:
Following the completion of the DEIR, the Project Applicant has prepared and submitted a revised
Site Circulation Plan, which will included updates to indicate that trash pick-up would occur at the
south driveway. While a rolled curb would be provided at the south driveway, the rolled curb is not
necessary to provide adequate access for trash trucks and other vehicles to move freely through the
access driveway during trash pick-up activities. The updated Site Circulation Plan is provided in the
Errata section of the Final EIR. The City's Public Works Department reviewed the Project site's
circulation plan and determined that the design would be adequate to allow for trash vehicles to
access the building at the southern access driveway without resulting in a conflict with through-
traffic because the driveway provides a 24-foot wide access way for each direction of travel, which
accommodates simultaneous trash pickup activities and vehicle through movements. Trash trucks
are typically 10-foot in width, leaving ample space for vehicles to pass. The ingress/egress easement
covers all of Block 100 (Parcel A); thus, a U-turn movement is not necessary for trash trucks to exit
the Project site. Trash trucks would be able to utilize the site circulation access ways to exit onto
Civic Center Drive. The City of Newport Beach has reviewed the southerly access easement and
determined that trash pick-up activities are within the realm of ingress/egress. The City intends to
impose conditions of approval on the Project that would ensure that adequate vehicular access is
maintained along the southerly access drive, as well as to require authorization of the underlying
property owner for any site improvements proposed within the southerly ingress/egress easement.
The use of the easement involves a civil matter between the property owners and no additional
analysis of the potential for physical environmental impacts associated with the proposed Project are
warranted in the EIR. The storm water treatment structure identified on Sheet 2.0 of the project plans
occurs below grade and will not obstruct access along the 5-foot pedestrian easement.
H-7:
The City of Newport Beach acknowledges the comments regarding the improvements that would
affect the private catch basin located outside the Project site boundary and within the commenter's
property. The comment does not address the adequacy of the analysis provided in the DEIR;
regardless, the City will consider this comment when preparing conditions of approval for the
Project.
H-8:
The specific dates on which temporary lane closures will occur are unknown and will be determined
by the Project's contractor based on the construction schedule. Accordingly, the DEIR discloses the
potential for temporary lane closures with as much specificity as is available at this time. No lane
closures are proposed at the southerly access drive. The Preliminary Construction Management Plan
(Appendix M of the DEIR [Page 9]) describes the lane closures along Anacapa Drive. Lane closures
would potentially be required along Anacapa Drive and Newport Center Drive for the installation of
temporary tie-backs during Project construction. Exhibit B-4 of the Preliminary Construction
Management Plan identifies the location of traffic cones that would be required where lane closures
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would occur along Anacapa Drive in order to accommodate temporary boom pump placement during
construction. Closures would be intermittent, and would not occur for durations greater than two
weeks at a time, subject to the discretion of the City of Newport Beach Public Works Department
depending on the specific construction activities that would occur. Page 14 of the Preliminary
Construction Management Plan identifies that lane closures would be limited to off-peak travel
periods. Each lane closure would be subject to the review and approval of the City's Public Works
Department prior to approval of any Temporary Street and Sidewalk Closure Permit. The analysis of
potential lane closures presented in the DEIR is based on reasonable assumptions predicated on facts
presented in the Preliminary Construction Management Plan. No additional analysis is required.
H-9:
The City intends to impose a condition of approval on the Project that would require that access
to/from the southerly driveway along Anacapa Drive be maintained throughout the construction
period. Exhibits B-3 and B-5 of the Preliminary Construction Management Plan indicate that all
vehicle queuing would occur on-site within private property during construction.
H-10:
The proposed Project would be conditioned to require compliance with the Construction
Management Plan. Finally, while the DEIR identified that the Tennis Club is a potential location for
construction worker parking, the off-site employee parking location and agreement would be
required to be finalized prior to issuance of the building permits.
H-11:
The proposed Project would utilize a crane during construction of the building. However, the
Preliminary Construction Management Plan has been revised to demonstrate that the swing radius of
the crane would not extend over offsite properties. The revised Preliminary Construction
Management Plan has been included in the Errata section.
H-12:
The specific placement of each lighting fixture will be determined as part of construction drawings
prepared in association with a building permit application. The fighting plan is required to be
reviewed by City staff to ensure compliance with applicable City codes and standards related to
exterior lighting. The Project Applicant has determined that it would relocate the bio-filtration unit
that was located within the 5-foot pedestrian access, as identified in the letter attached on the
following pages. The City intends to impose a condition of approval on the Project that would
require that the 5-foot pedestrian access easement remain clear of permanent structures.
H-13:
The evaluation of environmental impacts in the DEIR is appropriately limited to analyze only the
reasonably foreseeable and potentially significant adverse impacts of the Project that is proposed.
The analysis does not reflect improper "piecemealing" because no other property owners in Block
100 have submitted an application to the City requesting a building height increase, the need for
which would be, hypothetically, triggered by the proposed Project. Stated otherwise, there is no
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causation between the commenter's concern and the Project. Please see also Response G-6 and G-7
for further discussion regarding speculation on growth inducement.
A Planned Community Development Plan is not subject to the 50-foot height limitation in
accordance with Section 20.30.060 (Height Limits and Exceptions) Subsection C of the Zoning
Code. The Project's EIR cannot be used as the CEQA compliance document for the approval of a
height limit increase across the entirety of Block 100. The EIR's Project Description is finite and
limited to the boundaries of the Project site, and includes no evaluation of a building height increase
on other properties. The remainder of Block 100 is approximately 932% larger than the Project site
and it cannot be presumed that just because the remainder of Block 100 sits at a lower elevation than
the Project site than the conclusions reached by the Project's EIR would be the same as those that
would be reached if the entirety of Block 100 was subjected to the same level of analysis. Please
also see Response G-6 and G-7. No substantial evidence has been supplied to the City to indicate
that growth inducement on other properties in Block 100 is anything but speculative.
H-14:
Please see Response to Comment C-2, which indicates that the entirety of the Project site is outside
of the AELUP Part 77 Notification Area for JWA. Because the Project site is located outside of the
AELUP Part 77 Notification Area for JWA, the Project does not require referral to the Airport Land
Use Commission (ALUC) prior to approval.
H-15:
The responses to each individual comment is provided are Responses to Comments H-1 through H-
14, above. The commenter's contact information is acknowledged.
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FUSCOE
In
N 6 I N ! [ t I 6
August 2, 2016
Ms. Makana Nova
CITY OF NEWPORT BEACH
100 Civic Center Drive
Newport Beach, CA 92660
RE: 150 Newport Center Biofiltration BMP
Dear Makana:
This letter is to help clarify our intent for stormwater quality on the proposed 150 Newport
Center project. It has come to our attention that the proposed modular wetland unit at the
south side of the project site is in conflict with a proposed 5' sidewalk. Our intent is to
relocate the modular wetland unit, or other equivalent biofiltration BMP, to another location
on the project site to be determined during the final design. The proposed design will be
consistent with the current approved Preliminary WQMP and Countywide Model WQMP
Technical Guidance Document.
Please let me know if there are any specific questions you have about this approach.
Best regards,
FUSCOEE_EN-GINEERING, INC.
`
FESSIO
Oriana Slasor, P.E. y
Principal No.083451 m
qrF
OFC
16795 Von Korman, Suite 100, Irvine, California 92606 tel 949.474.1960 fax 949.474.5315 wJuscoe.com
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COMMENT LETTERS
June 26,2016
Re: 150 Newport Center Drive PA2014-213,Environmental Impact Report
City of Newport Beach,Community Development
100 Civic Center Drive
Newport Beach,CA 92660
Atm:Ms.Nova Makana,Project Planner
Dear Nova,
Please see my comments below in response to the 150 Newport Center Drive dEIR.
Proiect Objectives,Pane ES-3:
l'he Applicant appears to have started with the end product(i.e.,the proposed project)
then backed into the Project Objectives.
Please explain CI-.QA requirements and methodology for developing Project Objectives for a
dFIR.
• A.Redevelop an underutilized property in Newport Center.
Please provide facabased data to substantiate this statement that the properly is
underutilized.
• E.Respond to the demand for luxury,multi-family,high-rise residential development in the
City of Newport Beach.
Please provide fact-based data m substantiate this.slatement that the project is in
response to the demand for"...luxury,multi family,high-rise residential development in
the City of Newport Reach."Whadwho is makbng this demand'!
• F.Add for-sale,owner-occupied housing units in Newport Center to diversify the mix of uses
and the range of available residential housing unit types.
Please provide demographic and/or other data to substantiate that meeting this objective
will"diversify the mix of uses and range of available residential housing emit types in
Newport Center."
• G.Introduce a luxury,multi-family residential development in Newport Center than can
attract households in the surrounding area that are seeking to downsize from a single family
home,thereby making those single-family homes available for resale.
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COMMENT LETTERS
la'Il+ir m+arcumplinn or a.rtnenrenr ojjrmt7 Please provide urn ehplamliun based on
faces and elata jiu this prgiecl ohieoive i.e.,provide historical dam to prove nal the
assumption that.single f lmily hones will he available fru resole because people who live
there will wart to downsize to 150 Newport Cerner condos.
• L Maintain high-quality architectural design in Newport Center by adding a building that has
a recognizable architectural style and that complements the architectural styles that exist in
the surrounding Newport Center community.
Please providefocf-based information to support this ohiective. please identify addresses of
properties in the "surrounding Newport Center connnohp"Curl a-ould be complememed by I-1
this "high-qualily architectural design". (cont.)
• J.Implement a residential development that provides on-site amenities for its residents.
Please provide a list of what on-she amenities need to be inchrded in a Planned Communi(v
Development Plan(PC).
K. Redevelop a property that uses outdated operational technologies with a new use that is
designed to be energy efficient and avoid the wasteful use of energy and water.
Please provide facts,dales,and analysis that support this clain+thal the property uses
ouldated operational technologies.
Table ES-1 Mitigation Monitoring and Reporting Program and,4.1.5.Aesthics,Cumulative
Imnnct Analvsis
• 4.1 Aesthetics,"Threshold a."the Project site does not comprise all or part of a scenic vista.
Based on the visual simulations that were prepared,the Project would not result in
obstruction of coastal views from any public right-of-ways or Coastal View Roads as defined
in the Newport Beach General Plan(Newport Beach,2006a).The Project would result in
less-than-significam impacts." I-2
The visual simulations are misleading and iucomplere. Visual simulations need to be
included that show a//the buildings in the 100 block ar S3'because this precedent selling
project,ijapproved,could usher in some load uses, PCD's and heighl erceplions.
• 4.7 Land Use Planning,"Threshold b:Although the Project would change the land use
designation of the Project site front commercial to residential,the land use change would not
result in any significant and unavoidable impacts to the environment.Thus,the Project would
not conflict with an applicable land use plan,policy,or regulation adopted for the purpose of
avoiding or mitigating an environmental effect. I-3
What is the basis for concluding that the "Project would not con flirt with an applicable land
+use plan,policy, or regulolioh adopted for lite purpose gfavoiding or miligoling an
z
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COMMENT LETTERS
ennironmintn!ejject."P/ease a/so provide Ihe.cource ur author ojdri.r tdreslurld,nr the 1 1-3
regulatory hadaforsuch a Ilnmchold? CJI (cont.)
Table 1-1 Summary of NOP Comments
Regarding"Commenter—The Irvine Company, 2)As indicated on the Conceptual Grading Plan
(Figure 3-2 of the Initial Study),there is an existing 13-foot wide reservation for pedestrian use
that would be removed with dee proposed Project. It does not seer appropriate to completely
remove this reservation because the existing pedestrian access to Gateway Plaza should continue 1-4
to be provided."
P/ease provide where in dye dL7lt/his/-vine Company concern is address'etl. Will this
e,risliuglb'fine wide pedestrian access be retainer/?
4.1.3,Aesthetics,Basis for Determining Significance,Threshold c.would the Project
substantially degrade the existing visual character or quality of the site and its
surroundings?
Starting with paragraph 5,Page 4.1-21,which reads"The proposed Planned Community(PC)
Development Plan includes architectural design standards as follows(Newport Beach,2016x,p.
4):
All develapnmulshall be designee/with the higheet quality architectural.standardc and shall be
congnlihle with the surrounding uses in Arm+poo Center, The development will he well designed
with coordinated,cohesive architecture and eyhiba a high level ofarchilecnral and landscape
quality inkeeping with the PCOP's prominent location in Nesport Center.,blasting tflkis,
variations of rory7ine, varied textures,rececsrc,articulation,and design accents on the
elevation shall he integrated to enhance the expression of a unique and sophisticated
architectural a(yde. hi keeping with Ibis philosophy, the exterior will be comprised predondnalel),
r fa pre-cast concrete fafaek stainless steel finishes,and glass. 1-5
Comp innce with these design standards would be ensured dtrough the City's review of the Site
Development Review application and future review of building permits.Compliance with the
requirements of 1he PC-test would ensure that dee development of the site would occur in a
manner that would not substantially degrade the existing visual character or quality of dee Project
site and its surroundings."
The parcel gf lord is_oned commercial with 32'height limit. To say that the proposed project
"would ensure that the development of the site would occur in a manner that would not
substantially degrade the existing visual character or quality arf7he "rojccl site cod its
surroundings"is incomprehensible. This project is out of characterjor 'its surroundings"by
virlue ojdhe fact that this parcel is¢erred commercial per the voter approved 2006 General flan.
To claim that an 83'high building sauoure will mot degrade the existing visual character of dye
smrnumcling areas it illogical and disingenuous.
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COMMENT LETTERS
Section 4.2 Air Quality,4.2.5 Construction Impacts:Haul track trips and archhectaral
coating are prevented as sources of emissions during construction. There is no mention of the
other construction equipment to be utilized which will create emissions as listed Appendix M
Preliminary Cmutruction Plan,pdf page 7,2.5 Construction equipment. (See below).
2.5 construction Equipment
Anticipated construction equipment to be utilized for the various stages
or the project is as follows. Note: A more detailed list and scope
will be provided upon the receipt of entitlements for the project.
Bite Work:
street Iaproveant. coepre concrete
D•s
• ulltion M1Har andrpuaper
• Caisson Pla.•ancDozer Conveyer
• Grading IElectrioal)
Drill Rig Due,
• Lagging Trucks
Bmcavtta, Flatbed
Delivery Trucks
Wada, Rem Hoe
Perking SC[ucturo:
• Concrete PlaceaM Back Hoe Con.rate
site Dr.." Mixer and Plamr
1-6
• Bhotcrete Crane Flatbed
Delivery Trucks
Drill Rig
superstructure:
• Precast Wall system compressors Flatbed
• Mechanical, electrical, Delivery trucks
Pimbing, Wall/Door and Large Masonry Baas Metal stud Plasma
Tree installation cutter
Cram Hot.
Hemmers
shot Pin Applicators Beall atationary
power/hand tools
Interior:
• Interior Finishes Compressors Flatbed
• Hardacape installation Delivery trucks
• soft•cape irutallation Masonry Bake Roto Hera
Skill seat small
• Passenger Elevators handheld power tools
I net alltt ion small cement Hiker
Please provide a revised air quality and noise impacts analysis to include all pieces t f
equipment used daring construction as listed here.
Section 6.0 Project Alternatives
General comment:Please explain or supplyfacts/references from C6QA law or other.sources
that justify the use of economic feasibility as a factor in assessing Project Alternatives. 1-7
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COMMENT LETTERS
6.2.1 Car Wash Redevelopment Alternative, Page 64
"Funhemtore,the Project Applicant indicated that the financial cost of redeveloping the Project site
with a modern car wash,including due installation of new car wash technology,would render use of
the site as a new car wash uncompetitive in the economic market,particularly given that the car wash
and gas stations located at Jamboree Road and San Joaquin Hills Road have been recently renovated
and compete for the same market share.(Soderling 2016a)and(Soderling,20166)As such,
redevelopment of the site with a new car wash is economically unrealistic." I-]
What is the basis f n-this alternative being economically unrealistic?,t cast breakdown r f' (cant.)
redevelopbg the eristhig car wash is not provided./'lease provide one to substanliare discarding this
project allernative as"mrrcalistic".Furthermore,the car wash at Jamboree and Son.loagabr Hills
Hood is a.sell-drive-through wpe of car wash. 'I be claim that a redeveloped car wash would be
competingfor sane market scare has no basis when comparing a frdl-service car wash to a self.
drive-through car it Is there a market.sindv analysis available to subsvam/aie this claia?1fs'o,
please provide it. if not,please aplain the basis for this conclusion.
Page 6-19: No Project/Office Redevelopment Alternative
"In regards to the Project objectives,the No Project/Office Redevelopment Alternative would
develop the property with a professional office building and in doing so would redevelop an
underutilized properly in Newport Center:however,the office building developed under this
alternative would not meet the Project's obiectives to provide luxury,multi-family,high-rise
residential development in the City of Newport Beach that is within walking distance to other uses.
The No Project/Office Redevelopment Alternative would only meet four o6he Project's I I
objectives(Objectives A,C,1,and K).Specifically,the No Project/Office Redevelopment I_g
Alternative while making efficient use of existing infrastructure by repurposing a property with it
higher and better use than currently occurs on the property,would not be financially feasible
(Soderline 20166)and would not meet the Project objectives related to providing residential
development in Newport Center.(Underlined for emphasis)."
What federal orstate regulation mandates that more recideutnl developnrenr than what is specljied
in the voter approved Newport Ueach 2006 General flan is needed in Newport Center?
l'he draft EIR for the 150 Newport Center project fails to properly disclose,analyze,and
miti.-ate all of the Project's significant adverse environmental effects and the effects of 1_9
the poor precedents its approval would establish. I respectfully request that these
deficiencies be corrected and that a revised draft EIR be recirculated.
Thank you.
Sincerely,
Dorothy Kraus
10 Wild Goose Court
Newport Beach,CA 92663
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Dorothy Kraus—Comment Letter I
1-1:
Pursuant to CEQA Guidelines §15124(b), the DEIR's Project Description includes a list of the
objectives sought by the City as lead agency, which are repeated in this comment. A Lead Agency
has broad discretion to formulate project objectives. Further, CEQA does not restrict a Lead
Agency's discretion to identify and pursue a particular project designed to meet a particular set of
objectives. CEQA does not require the Lead Agency to provide empirical evidence to justify the list
of objectives,which are based on the fundamental purpose of the Project.
The Project's fundamental purpose is to redevelop an underutilized property in the Newport Center
area with multi-family, for-sale luxury high-rise (three + stories) residential units located within
walking distance to employment, shopping, entertainment, and recreation. Regarding existing
underutilization of the Project site, the Project Applicant provided a letter to the City cited in the FIR
as "(Soderling, 2016a)" which states that ongoing use of the site as a car wash will not support the
land value and purchase price for the property, and that new technology needs and labor costs will
make a new car wash operation uncompetitive from a price standpoint with nearby car washes. In
evaluating the Applicant's letter, the City applied a "prudent person" standard; meaning, that the
Applicant's statements about the economic infeasibility associated with selling or leasing the
property to a car wash operation is so great compared to the developing the project site with
residential units, that a reasonably prudent person or property owner would not continue using the
site as a car wash. Thus, continued use of the site as a car wash was determined by the City to not
have a reasonable chance of success operating on the site in the future and, therefore, the site is
considered to be underutilized. Further, the car wash is a one-story structure that does not maximize
the development potential of the property even under the site's existing zoning designation.
I-2:
Refer to Responses G-4, G-6, H-12, H-13, and L-4, including Exhibit A that supplements Response
G-4. Given these responses, the visual simulations were appropriately prepared showing the Project
in relation to existing development in the surrounding area.
1-3:
The evaluation of Threshold b) contained in DEIR Subsection 4.7, Land Use and Planning (starting
on page 4.7-5) is based on the thresholds contained in Appendix G of the California Environmental
Quality Act (CEQA) Guidelines, codified at Title 14 California Code of Regulations section 15000 et
seq. Refer to CEQA Guidelines Appendix G, Checklist Question X b) "Would the project conflict
with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the
project adopted for the purpose of avoiding or mitigating an environmental effect?" Also refer to
Response G-1.
14:
Please refer to Response H-4.
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Impacts associated with the visual character or quality of the Project site and surrounding areas are
evaluated on pages 4.1-20 through 4.1-23 of the DEIR. The commenter disagrees with the
conclusions in this analysis based on the Project's requirement for a zone change and based on the
opinions of the commenter. The impacts to visual resources associated with the conversion of the
site from a car wash to a residential building are fully disclosed in the DEIR, and no substantial
evidence was provided by the commenter to indicate that the analysis was deficient. The conversion
of the Project site from a one-story car wash operation to a seven-story residential building would
change the character of the Project site as described in the DEIR, but as concluded in the DEIR, this
change in character is not regarded as a significant adverse impact on the environment given the
surrounding existing conditions and the urban nature of the area. The draft Planned Community Text
language assumes the requested General Plan and Zoning Code amendments are approved to
implement the project. The text establishes standards to enforce the project as intended, if approved.
The draft Planned Community Text language assumes the requested General Plan and Zoning Code
amendments are approved to implement the project. The text establishes standards to enforce the
project as intended, if approved. Also refer to Responses G-2, G-3, and G-4.
I-6:
As noted on page 21 of the Air Quality Impact Analysis (Appendix C of the DEIR), construction-
source emissions would result from the various construction activities, such as demolition, site
preparation, and building construction. The construction equipment proposed to be used for the
Project's construction activity and that is analyzed throughout the DEIR is listed in DEIR Table 3-2.
At the time the analysis was conducted, an estimated construction equipment list was utilized, which
represents a conservative estimate of air emissions and noise levels. As noted on page 21 of the Air
Quality Impact Analysis, "associated equipment represents a reasonable approximation of the
expected construction fleet as required per CEQA guidelines. Site specific construction fleet may
vary due to specific project needs at the time of construction." Similarly, the list of construction
equipment from DEIR Appendix M notes that "a more detailed list and scope will be provided upon
the receipt of entitlements for the project." As such, construction-related sources of emissions have
been accounted for based on a reasonable set of assumptions identified in DEIR Table 3-2 and used
in the Air Quality Impact Analysis. Furthermore, the analysis assumes that 7 pieces of construction
equipment will be operating simultaneously for up to 6 hours, which is a conservative assumption
given that equipment does not operate continually and is turned on and off throughout the course of a
typical work day. Also, refer to DEIR Section 3.4.5.
I-7:
Refer to Response G-5 and the letter attached to Response G-5 cited in the DEIR as "(Soderling,
2016a)" for the evidence that the City of Newport Beach relied upon in determining that the existing
car wash is a non-viable commercial use of the Project site. An FIR need not consider alternatives
that are infeasible, as specified by Public Resources Code, § 15126.6(a). The term "feasible" is
defined in § 21061.1 as "capable of being accomplished in a successful manner within a reasonable
period of time, taking into account economic, environmental, social, and technological factors."
(Italics added.) CEQA Guidelines § 15364 also adds the term "legal" to the list of factors.
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I-8:
This comment does not address the adequacy of the assessment of the environmental impacts of the
Project provided in the EIR. No federal or State regulation mandates more residential development
than what is specified in the City of Newport Beach General Plan. Also refer to Response I-1.
I-9:
The responses to each of the commenter's specific comments are provided in Responses I-1 through
1-8, above. The DEIR does not need to be recirculated based on §15088.5 of the CEQA Guidelines.
As summarized in the responses provided herein, there were no public comments or changes to the
text or analysis of the DEIR that resulted in the identification of any new significant environmental
effect requiring mitigation. In addition, based on all comments received on the DEIR, only minor,
non-substantive revisions that merely clarify or amplify information presented in the DEIR were
required (as described in the Errata included in the Final EIR). The DEIR circulated for public
review was fundamentally and basically adequate, and all conclusions presented in the DEIR are
supported by evidence provided within the DEIR and/or the administrative record for the proposed
Project. Based on the foregoing, recirculation of the EIR is not warranted according to the guidance
set forth in§15088.5 of the State CEQA Guidelines.
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COMMENT LETTERS
June 27, 2016
Via E-Mail—mnova@newportbeachca.gov
City of Newport Beach
Attn: Makana Nova,AICP,Associate Planner
Attn: Planning Commission
100 Civic Center Drive
Newport Beach,CA 92660
SUBJECT: DEIR Adequacy Comments—150 Newport Center Project
Dear Ms. Nova and Planning Commission Members:
Thank you for this opportunity to review and comment on the adequacy of the DEIR prepared
and circulated for the 150 Newport Center Project.
1. Draft EIR Section 3.5.2 Zoning Code Amendment No. CA2015-008 is inadequate as it does
not discuss the inability of the proposed project, 49 multi-family units within an 83.6 foot high
structure, to comply with all of the "Required Findings" necessary to increase the height of a
structure above the base height, prior to adoption of a Planned Community District (PCD), in
accordance with Municipal Code Section 20.30.060(C)(3). It is important that compliance of the
proposal with applicable Municipal Code Sections be evaluated in the DEIR, as the Municipal
Code is an important tool that implements the goals and policies of the General Plan. The
proposed project clearly does not comply with all of the following findings to approve a PCD, as
outlined below.
According to Municipal Code Section 20.30.060(0)(3) — 'The review authority may adopt a J-1
Planned Community District, adopt a specific plan, or approve a planned development permit
or site development review to allow an increase in the height of a structure above the base
height only after first making all of the following findings in addition to the findings required
for the discretionary permit application:
a. The project applicant is providing additional project amenities beyond those that are
otherwise required. Examples of project amenities include, but are not limited to:
i. Additional landscaped open space (The applicant has failed to demonstrate how the
proposed height increase will result in additional landscaping and open space on the 1.26 acre
site. The proposed project covers most of the lot with the building and drives,while also seeking
relief from the proposed RM (Multiple Residential)setback standard.)
1
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ii. Increased setback and open areas (The applicant proposes to decrease the RM setback and
has not demonstrated that additional open areas will be created by increasing the building
height, which is more than double the base height.)
iii. Enhancement and protection of public views; and (Not only does the project not enhance
public views, by increasing the height to 83.5 feet, the project could impact existing public views
and would certainly set a precedent that would incrementally impact future public views and
aesthetics, as well as significantly change the pattern of development in Newport
Center/Fashion Island that is envisioned in the General Plan.)
b. The architectural design of the project provides visual interest through the use of light and
shadow, recessed planes, vertical elements, and varied roof planes.
c. The increased height will not result in undesirable or abrupt scale changes or relationships
being created between the proposed structure(s)and existing adjacent developments or public
spaces. Where appropriate, the proposed structure(s)provides a gradual transition to taller or J 1
shorter structures on abutting properties; and (As proposed, the project represents an abrupt (cont.)
scale change from a single story building to a 7-story, 83.5 foot high structure between the
project site and existing adjacent low-scale buildings. Additionally, the project does not provide
a gradual transition to taller or shorter buildings on abutting properties as required by this
finding.)
d. The structure will have no more floor area than could have been achieved without the
approval of the height increase." (The proposed RM (Multiple Residential) Zoning District
would allow a building height of 32 feet for a flat roof and 37 feet for a slope roof. The purpose
of the proposed project height of 83.5 feet, is to capture views by increasing the floor area,
which is inconsistent with this finding.)
The proposed project is inconsistent with the PCD standards because all of the required findings
to be granted a waiver from the base height cannot be made and the DEIR must discuss this
inadequacy.
2. Table 4.7-2 Policy LU 3.2 Growth and Change. The proposed project is inconsistent with
Policy LU 3.2 and the DEIR project consistency discussion must be revised to reflect this
inadequacy. This General Plan Policy states "Enhance existing neighborhoods, districts and
corridors, allowing for reuse and infill with uses that are complementary in type,form, scale,
and character. Changes in use and/or density/intensity should be considered only in those
areas that are economically underperforming, are necessary to accommodate Newport 2
Beach's share of projected regional population growth, improve the relationship, and reduce
commuting distance between home and jobs, or enhance the values that distinguish Newport
Beach as a special place to live for its residents. . . ." The applicant proposes a change in use
from Regional Commercial Office (CO-R) to RM (Multiple Residential) because it claims the
existing car wash has "outdated technology." This area of Newport Center is no economically
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underperforming. Removal of the existing car wash would still allow for the development of a
low-scale commercial use that would comply with the vision set forth in the General Plan and
would not require a General Plan Amendment, Zone Change and Planned Community District.
On June 10, 2016, an article in the Newport Independent titled "I-enants Face Challenges in Tight
Commercial Real Estate Market" describes a current shortage of office space and notes that J-2
"vacancy rates continue to drop and rental rates are now increasing at a fairly rapid pace." The (cont.)
redevelopment of the site with another commercial use or low-scale office building would not
require a General Plan Amendment, Zone Change, or Planned Community District approval and,
therefore, the current consistency discussion for Policy LU 3.2 is inadequate and must describe
the proposed project as inconsistent with the General Plan.
3. Table 4.7-2 Policy LU 5.1.1 Compatible but Diverse Development. The proposed project is
inconsistent with this General Plan policy as the entire area surrounding it is commercially zoned
and developed, and includes restaurant/entertainment uses that operate late into the
evening/early morning. In evaluating the compatibility of introducing a new residential land use
into this particular commercially zoned area,the City must consider existing adjacent and nearby
uses and the impacts those could have on future residents. Immediately to the east of the
project site, across Anacapa Drive, is Muldoon's, a long-time restaurant that has a use permit to
conduct live amplified entertainment on an open patio in the evening. Immediately to the north
of the site are two newer restaurants, Red 0 and Fig and Olive. Red O also provides evening
entertainment. These businesses, which are open late into the evening, create increased noise
not only from music, but also from traffic and patrons as they exit the buildings and drive away J-3
throughout the evening. Moreover, many of the residents of the proposed project will be
seniors, which are sensitive receptors. Should the City approve the proposed rezone to allow
residential development at the subject site, it would be creating an incompatible and
unnecessary environmental impact between existing and new land uses that could compromise
the viability of successful uses in the commercial zoning districts of this area in Newport
Center/Fashion Island. Therefore, the existing discussion is inadequate as the proposed
residential use, subject to a General Plan Amendment, Zoning Amendment, and Planned
Community District, must be evaluated for compatibility with the intent of the land use plan for
Newport Center/Fashion Island, and the DEIR must be revised to discuss and mitigate the
projects impacts on land use with regard to these potential conflicts.
4. DEIR 6.0 Alternatives Discussion H. Noise (page 6-32) — As noted in ria above, the
environmental impact of "Noise' has been inadequately analyzed and discussed with regard to
the proposed location of a 7-story residential building adjacent to the existing,
restaurant/entertainment uses of Muldoon's, across Anacapa Drive, and Red 0 and Fig and J-4
Olive, across Newport Center Drive. Alternatives Discussion H must be amended to discuss and
mitigate the projects impacts on land use with regard to these potential noise impacts.
5. Table 4.7-2 Proposed Project Consistency — Policy LU 6.14.4 Development Scale. The
inability of the proposed project to comply with the mandatory findings to increase the base J-5
3
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building height, as discussed in #1, above, should also be discussed in the Project Consistency
Table for Policy LU 6.14.4. Not only is the height and scale of the project in conflict with the
Property Development standards outlined in the Municipal Code related to height and scale, it is
inconsistent with General Plan Policy LU 6.14.4. The proposed project site is located in the
southwesterly quadrant of the Newport Center/Fashion Island area. Policy LU 6.14.4 states J-5
"Reinforce the original design concept for Newport Center by concentrating the greatest (cont.)
building mass and height in the northeasterly section along San Joaquin Hills Road, where the
natural topography is highest and progressively scaling down building mass and height to
follow the lower elevations toward the southwesterly edge along Pacific Coast Highway."
Therefore, any new development should maintain the height set forth in the development
standards. The Project Consistency Discussion for Policy LU 6.14.4 currently includes a
comparison of heights up to 315 feet, which is misleading because those buildings are located in
the 500 and 600 blacks within the northeasterly section of Newport Center. The DEIR discussion
inaccurately infers that heights of up to 315 feet are compatible with all areas of Newport
Center and,therefore, must be changed.
Additionally, the DEIR must be amended to include a discussion as to how the proposed General
Plan and Zoning Amendments to change the existing commercial zoning to multi-family
residential zoning, increase the height above the base and decrease the setbacks for a 1.26 acre
parcel, does not constitute "spot zoning." The General Plan, as the "constitution" for governing
the direction of future land use in the City is, at best, being ignored. Residents, developers and
decision-makers rely on the General Plan to guide physical development in a reasonable and
planned context. It is imperative that the requested exception from the existing laws of the City
be analyzed in the DEIR.
The discussion within Table 4.7-2 is inadequate as the proposed project is inconsistent with the
General Plan and Zoning Code. Additionally, the DEIR consistency discussion misrepresents that
building heights in the northeasterly section of Newport Center as somehow justifying the
proposed 83.5 foot height as consistent with Policy LU 6.14.4 and, therefore, must be amended
to present only existing building heights immediately surrounding the project site. Moreover,
the previously noted concern of "spot zoning" of this 1.26 acre parcel and its associated
precedent-setting effects must be analyzed and discussed in the project DEIR.
Based on the inadequate discussions and mitigation of potentially significant environmental
impacts, as noted above, the DEIR for the proposed project must be revised and recirculated for
public review and input, in compliance with CEo,A.
Sincerely,
J-6
Carolyn Martin
3420 E.Third Avenue
Corona del Mar,CA 92625
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Carolyn Martin—Comment Letter J
J-1:
The required findings associated with the approval of the height increase will be provided as part of
the staff report and draft resolution associated with the public hearing(s) for the proposed Project.
The findings are not required as part of the DEIR, and the DEIR's Project Description provides a
sufficient level of detail to adequately inform the public of the nature of the Project to form the basis
of the assessment of physical environmental impacts. Please also refer to Response G-1.
J-2:
An analysis of the Project's consistency with General Plan Policy LU 3.2 is provided on pages 4.7-9
through 4.7-10 of the DEIR. Refer to Responses G-4, G-5 (including the attachment) and 1-1
regarding evidence that the existing car wash is a non-viable commercial use of the Project site.
Accordingly, as evidence is provided that the Project site contains an underperforming/non-viable
commercial use, the analysis provided in the DEIR related to the Project's consistency with General
Plan Policy LU 3.2 is adequate. Additionally, economic feasibility analyses were also prepared for
the development of the Project site with a 25-unit two-story apartment building, an 8,500 s.f office
building, and a 8,500 s.f. restaurant use. Each of these analyses, which provide evidence that these
uses would be economically infeasible at the Project site, are included as attachments to this response
would be economically infeasible.
J-3:
This comment implies that noise from adjacent restaurants has the potential to impact the project;
however, CEQA requires than an EIR address the potential impacts of a proposed project on the
environment, and not the reverse (impacts of the environment on the project) unless the project
would potentially impact the environment by exacerbating an existing environmental hazard. See
California Building Industry Association v. Bay Area Air Quality Management District (2015) 62
CalAth 369. Noise from commercial restaurants is not considered significant or an environmental
hazard.
An analysis of the Project's consistency with General Plan Policy LU 5.1.1 is provided on page 4.7-
10 of the EIR. The proposed Planned Community Development Plan would establish property
development regulations through a Zoning Code Amendment that is intended to ensure that the
Project would result in compatible and high quality development that is integrated with the larger
overall character of Newport Center, thus ensuring consistency with the General Plan and Zoning
Code. The proposed land use change is responsive to an underserved market need for residential
development in the Newport Center area. Commercial and residential land uses are often developed
in close proximity with one another and can operate compatibly with appropriate design and
operational conditions. As with all properties throughout the City of Newport Beach, the nearby
non-residential uses are subject to the City's noise regulations which would ensure that noise from
these uses would not result in impacts to residents of the proposed Project. Similarly, the proposed
Project's building would be required to be constructed to meet the applicable noise standards
specified in the City of Newport Beach Municipal Code Chapter 10.26, Community Noise Control.
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Therefore, the determination in the DEIR that the proposed residential land use would be a
compatible but diverse development for the Newport Center area is appropriate.
J-4:
Please refer to Response J-3, above. Given that response, an expansion of the noise analysis and
Alternatives analysis to discuss noise impacts associated with existing commercial uses is not
warranted.
J-5:
Please see Response G-4 regarding the Project's consistency with General Plan Land Use Policy
6.14.4. Typically, "spot zoning" occurs when a small parcel is subject to more or less restrictive
zoning than the surrounding properties, and as a result, there is irrational discrimination. See Foothill
Communities Coalition v. County of Orange (2014) 222 CA4th 1302 and Avenida San Juan
Partnership v. City of San Clemente (2011) 201 Cal.App.4th 1256. As indicated by the Court of
Appeal in Foothill Communities: "First, spot zoning may occur whether a small parcel of property is
subject to more or less restrictive zoning than the surrounding properties. Second, to determine
whether impermissible spot zoning has occurred, a court is required to conduct a two-part analysis.
After determining that spot zoning has actually occurred, the court must determine whether the
record shows the spot zoning is in the public interest." In summary and with regard to the proposed
Project and the DEIR, the Newport Center area is an established mixed-use area. The introduction of
residential uses on the Project site would be consistent with many of the City's General Plan Policies
as indicated in DEIR Table 4.7-2. The DEIR thoroughly analyzes the Project's proposed Zoning
Code Amendment No. CA2014-008, from "OR (Office Regional Commercial)" to "PC (Planned
Community District)" and the physical condition that would result from this proposed action(i.e„ the
construction and operation of a seven-story residential building adjacent to retail commercial,
restaurant, and office uses). The proposed Project is viewed by the City as furtherance of the mixed-
use nature of Newport Center and the surrounding area and as such does not constitute impermissible
"spot zoning." As noted in the EIR, residential uses are already located in close proximity to the
Project site, including the Granville community (a private gated residential community located
approximately 0.15-mile west of the Project site); Meridian (a 79-unit condominium Project located
at 1001 Santa Barbara Drive, approximately 0.5 mile northwest of the Project site); The Colony
Apartment Homes (an apartment complex located approximately 0.6-mile northwest of the Project
site); and the San Joaquin Plaza Apartments (a 524-apartment complex located approximately 0.6-
mile northwest of the Project site). Please see Response G-6 regarding the precedent-setting effects
referenced by the commenter.
J-6:
Responses to the commenter's specific comments regarding the adequacy of the analysis in the DEIR
are provided in Responses J-1 through J-2. The FIR does not need to be recirculated based on
§15088.5 of the CEQA Guidelines as explained in Response I-9.
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July 9, 2016
Makana Nova, Associate Planner
City of Newport Beach
100 Civic Center Drive
Newport Beach, CA 92660
Re: 150 Newport Center
Feasibility analysis of a 25 unit apartment complex
Each unit would be approximately 3,000 square feet.
Dear Makana:
Please accept this letter as an analysis of the economic feasibility of a two story, 75,000 square foot
apartment complex at the above referenced site.As background, I am a Senior Vice President at Marcus
& Millichap in Newport Beach and have been involved in the sale, repositioning, acquisition,
development services and management of apartment projects in and around Newport Beach. It is my
understanding this project would require a change to the general plan and a zone change.
A quick analysis of the proforma for 150 Newport Center is as follows:
Land Cost $11,750,000
Land carry-$ 7 Mil at 9%for
30 months 1,575,000
Construction Cost @ $250/sf on
75,000 sf 18,750,000
Arch & Eng (5%) 1,125,000
A&D Loan Int-$20 Mil @ 7% 1,400,000
City Fees 625,000
Contingency 200,000
Total Cost $35,425,000
Annual Net Income $540,000 ($3,250 Avg Mthly Rent x 25u = $81,250 x 12
Mths= $975k Gross Inc-40% Exp = $585k N01)
Rent Survey:
The Colony at 5100 Colony Plozo,Newport Beach CA 92660
�29
2 bed/2 bath:staring at$3,950
2 bed/2 bath with den:$4,530
No 3 bed/2 bath option
The Bays at 1 Boxwood Dr,Newport Beach CA 92660
2 bed/2 bath:starting at$2,365
3 bed/2 bath:starting at$2,780
3 bed/2 bath townhomes:starting at$3,410
FoirwoV Apartments at 48 X Pine Volley Ln, Newport Beach CA 92660
2 bed/2 bath$3,417-$4,267
3 bed/2 bath$4,633-$4,787
Park Newport at 1 Pork Newport; Newport Beach CA 92660,
2 bed 12 bath:$2,365-$3,225
2 bed/2.5 bath:$2,820-$3,635
3 bed/2.5 bath:$3,580-$4,420
Value at 5%Cap Rate $11,700,000
Loss of value (23,725,000)
Based upon the above economics, a 75,000 square foot apartment complex at 150 Newport Center
would be economically infeasible. In the meantime if you should have any questions, please do not
hesitate to call.
Very
�/truly
y yours:
L/I/✓ Lc�
Mark Bridge
Property Real Estate Services
420
July 9, 2016
Makana Nova,Associate Planner
City of Newport Beach
100 Civic Center Drive
Newport Beach,CA 92660
Re: 150 Newport Center
Feasibility analysis of a 8,500 sf Office
Dear Makana:
Please accept this letter as an analysis of the economic feasibility of a single story, 8,500 square foot office
building at the above referenced site.As background, I am the President of PRIES properties in Newport
Beach and have been involved in the sale,acquisition,development services and management of
numerous office, retail,and hospitality projects in and around Newport Beach over the last 25 years.
A quick office analysis of the proforma for 150 Newport Center is as follows:
Land Cost $11,750,000
Land carry-$7 mil at 9%for 30 months 1,575,000
Construction cost @ $250/sf 2,125,000
Arch & Eng(5%) 106,250
Commissions 102,000
A&D loan int.-$4 mil @ 7% 208,000
City fees-$22 psf 187,000
Contingency 200,000
Total cost $14,128,250
Annual Income-$48.00 psf NNN $408,000
Value at 4.5%cap rate $9,066,000
Loss of value ($5,062,250)
Based upon the above economics,a spec 8,500 square foot building at 150 Newport Center in Newport
Beach would be economically infeasible. In the meantime, if you should have any questions, please do not
hesitate to call.
Very ulyyo s
i
rad Schroth, President
Professional Real Estate Services
The PRES Companies
19782 MacArlhur Boulermrcl, Suite 100, brine, CA 92612
Phone: (949)261-7737 1 rax: (949) 442-1925
wwww.prescompanies.com 421
CMEP
REAL ESTATE ADVISORS
July 9, 2016
Makana Nova, Associate Planner
City of Newport Beach
100 Civic Center Drive
Newport Beach, CA 92660
Re: 150 Newport Center
Feasibility analysis for an 8,500 square foot restaurant
Dear Ms. Nova:
Please accept this letter as an analysis of the economic feasibility of a one story, 8,500 square foot restaurant at
the above referenced site. As background, I am the Co-Owner/Managing Partner of CCP Real Estate Advisors in
Newport Beach and for the past 18 years have been involved in the sale, leasing, development services and
management of restaurant properties in and around Newport Beach.
A quick analysis of the proforma for 150 Newport Center is as follows:
Land Cost $11,750,000
Land carry-$ 7 mil. at 9%for 30 months $1,575,000
Construction cost @ $225/sf on 8,500 sf $1,912,000
Tenant Improvements @ $150 psf $1,275,000
Arch & Eng (6%) $205,000
A&D loan int.-$4 mil @ 7% $280,000
Commission $204,000
City fees @ 15 psf $127,000
Contingency $200,000
Total cost $17,528,000
Annual Net Income-@ $680,000
Value at 5%cap rate $13,600,000
Loss of value (3,928,000)
Based upon the above economics, an 8,500 square foot restaurant at 150 Newport Center would be
economically infeasible. Should you have any questions, please do not hesitate to call.
Very truly yours
1 �
CCP Real Estate Advisors
Ian M. Furar—Managing Partner
140 Newport Center Dr I Suite # 120 1 Newport Beach, CA 1 92660
phone: 949.717.7711 1 fax: 949.717.0011
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COMMENT LETTERS
June 27, 2016
Comments on 150 Newport Center (the "Project') DEIR
These comments on May 12,2016 Draft Environmental Impact Report(SCH No.20160110321,submitted K-1
by: Jim Mosher(iimmosher(o)vahoo.com ), 2210 Private Road, Newport Beach 92660 (949-546-6229).
1. The DEIR begins by characterizing the Project site as "an underutilized property' (DEIR
Section ES 2.2, page ES-2). I can find no facts supporting that contention. My impression K 2
is that operating as a car wash the Project site contains a bustling business providing a well
utilized and much appreciated service.
2. The Project is also being proposed to add residential development to an area not identified
as suitable for that in the General Plan. In particular, in 2006, faced with what were
expected to be large and continuing state-mandated Regional Housing Need Allocation
requirements, Newport Beach voters agreed to amend the City's General Plan to include,
among other things, a potential to add up to 450 new dwelling units to Newport Center over
the next 20 years,and identified the parcels carrying an MU-H3 land use designation as the
suitable locations for them.
a. Ten years into the 2006 General Plan, and facing no RHNA mandate of which I am
aware, the City Council has already allowed,without voter approval, adding 79 more K-3
dwelling units to Newport Center than the maximum contemplated in the 2006 Plan.
b. I see no reason whatsoever to grant a deviation from the 2006 Plan, especially to
add housing to an area where it was not planned to be.
c. I also continue to wonder if the City gets credit for housing added in years when
there is no RHNA requirement. If not, it would seem future environmental impacts
from adding housing would be reduced if the sites suitable for residential expansion
were saved until they could be used to fulfill a state-mandated need.
3. As has been pointed out by other commenters, the proposed Project appears to be
inconsistent with Newport Beach General Plan Policy LU 6.14.4, governing the scale of
buildings in Newport Center(tapering down from massive high rise concentrated in the
northeast corner). That contention is bolstered by the following substantial evidence: In
2013-2014, the Council-appointed Land Use Element Amendment Advisory Committee
considered amending Policy LU 6.14.4 in a way that would have allowed the same applicant
to pursue an 85 foot tall (?) hotel project(or a later applicant something similar) on the 150
Newport Center Drive parcel, but rejected the idea. See, for example, the language K-4
proposed in Item 3 in the LUEAAC agenda packet from January 7, 2014 (handwritten page
37). My recollection (the surviving minutes of the meetings are extremely sketchy but were
supposed to be accompanied by preservation of the audio recordings) is that that enabling
language (as well as other alternative policy statements that were considered)was rejected
by the Committee, and it was definitely not included in the final proposed General Plan
changes of City Council Resolution 2014-67 (itself adopted by the Council, but never
effective because of rejection by the voters of ballot Measure Y in November 2014). The
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previous discussion by a Council-appointed committee of the need to amend Policy LU
6.14.4 to permit a similar project on the 150 Newport Center Drive site seems to me to be
substantial evidence that the DEIR has reached an erroneous conclusion on page 4.7-10
when it finds that the current Project is consistent with Policy LU 6.14.4. And given the I<-4
previous rejection by a City committee tasked with reviewing the Land Use Element of the (cont.)
changes necessary to Policy LU 6.14.4 to make such a project consistent, wouldn't the
amendment necessary to approve this Project be a very significant change in City policy
direction?
4. Whether the Project is consistent with General Plan Policy LU 6.14.4, or not, and despite
prior precedents in Newport Beach, I believe the height proposed for the structures is
inconsistent with the citywide Planning and Zoning Code, and would require either a major
amendment to that Code, or a variance from it (and any peculiar circumstances about the
property justifying a variance are difficult to see). It appears that by obtaining a"PC"
designation the developer expects to be able to increase the normal RM heights of NBMC
Section 20.30.060("Height Limits and Exceptions") to 75 to 84 feet.
a. A close reading of Subsection 20.30.060.0 ("Increase in Height Limit") indicates that
even with the declaration of a Planned Community and with the mandatory additional
findings of Subsection 20.30.060.C.3, the maximum increase permissible for flat-
roofed multiple family residential structures is to 32 feet.
i. It must further be noted that among the many compulsory findings necessary
to increase flat-roofed multiple family residential structures above 28 feet, is K-5
one that"The structure will have no more floor area than could have been
achieved without the approval of the height increase" (Subsection
20.30.060.C.3.d).
1. That finding can clearly not be made here, where a 7 floor structure
completely filling the lot is proposed on a parcel where only 2 or 3
floors could be built without the height increase.
ii. It might be noted that most of the other required findings for a height increase
cannot be made: the increased height is not being used to protect public
views, it is not being used to enhance visual interest, it will create abrupt
changes in height relative to adjacent developments, and even if setbacks
are larger than might have been allowed for a less tall building, the structure
still gives the appearance of great bulk filling the lot to its limits.
5. As mentioned in the previous point, a key requirement for success of the Project seems to
be that various citywide zoning standards can be waived though conversion of the site into a
"Planned Community District" by approval of a Planned Community Development PlanK-6
(DEIR pages ES-4 &3-16). It is true that in recent City planners appear to have increasing
used the PCD mechanism as a justification for spot zoning parcels on the reasoning that the
spot-zoned parcel will complement neighboring uses in such a way that the totality of
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unrelated parcels can be regarded as a"planned community." But that reasoning is wholly
at odds with the way PCDs are described in both the General Plan (GP pages 13-7 and 14-
61)and the City's Planning and Zoning Code(NBMC Chapter 20.56). Under those policies,
key features of a PCD are that it integrate a variety of uses within a distinct boundary,
subject to shared rules and ideally(at least initially) under a single ownership. The only
future Planned Community definitely anticipated in the 2006 General Plan is Banning Ranch
(GP page 3-74), with a possibility of use of the PCD designation for"residential villages in K-6
the Airport Area" (GP page 13-8). However desirable planners may feel it is, a residential (cont.)
tower walkably adjacent to existing retail and commercial uses subject to separate planning
is simply not, in and of itself, a PCD. Among other things, there is no clear district boundary
and no required future coordination of planning with the existing nearby uses.The only
integration of uses within the proposed 1.26 acre 150 Newport Center PCD parcel that I can
find in the proposed PC text is of an "urban lifestyle"with a single"building" (DEIR, Appendix
A, page 3). Again, it is not a PCD and the parcel is too small to be suitable for one.
6. Page 4.7-3: Readers might hope they could look to the DEIR for clear and accurate
statements about the current status of the Project site and its surroundings. Since a
General Plan Amendment is being sought (DEIR pages ES-4 & 3-15),the current General
Plan status of the Project site would seem crucial, but instead of explaining that, this page
refers to an apparently non-existent"Figure 2-2, General Plan Land Use Designation
designation." I am unable to find such a figure in the List of Figures (DEIR page viii) or in
the DEIR. Where is it? I am likewise unable to find the "Figure 2-3, Existing Zoning K-7
Designation" referred to in "Section 3. City of Newport Beach Zoning Ordinance," nor does
that section make clear how the"maximum development limit of 199,095 square feet of
allowable building space in an area (block) that includes the Project site" affects the Project
(that is, does it include the proposed 163,260 residential square footage, which by itself is
close to the maximum square footage allowed for the entire block?).
7. Page 4.7-8, Item 2, paragraph 2, line 5: Should "newanomaly' be"new anomaly'? K-8
8. Page 4.7-20, Item 4: Impermissibly dismisses the need for the DEIR to consider whether •••JJJ
the Project would need approval by the electorate pursuant to Charter Section 423. The
need for such a vote would affect both the timetable of the Project, and its feasibility
compared to the alternatives. Analysis is additionally needed because this is a matter of
intense controversy regarding the consistency of this Project, and another(the so-called
"Museum House"), with City land use policy, as evidenced by comments made by multiple
speakers at numerous public meetings. Moreover, at the heart of the controversy is a K-9
previous land use change in another part of Newport Center which many in the community
now believe required a General Plan amendment, but for which an EIR("Addendum No. 2 to
the City of Newport Beach General Plan 2006 Update Final Program Environmental Impact
Report(EIR) SCH No. 2006011119,"June 15, 2012) prepared by the same outside CEQA
consulting firm (T&B Planning, Inc.) lead by the same primary CEQA consultant(Tracy Zinn)
failed to detect that need (Addendum No. 2, page 1-2, 2-2). At least to me, this seriously
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undermines the trust the public and decision makers should have in the current land use
analysis. The matter in question involved the transfer and "conversion"of 79 voter-
approved, but unbuilt, hotel rooms into an entitlement for 79 dwellings units without formally
amending the General Plan to reflect the change, and in consequence, it is now said,
without ever counting them toward the cumulative Charter Section 423 development limits,
on the basis that it was traffic neutral. This was clearly an erroneous conclusion for a variety
of reasons, including that the concept of"conversions" does not exist in the General Plan K-9
(except to a very limited extent within the Fashion Island circle in Policy LU 6.14.1), and (cont.)
even if it did, the Charter requires tracking non-voter-approved residential and non-
residential additions to the Plan, as well as traffic, separately, with no tradeoffs between
them. It also conflicts with codes explicitly requiring residential transfers to be unit by unit
(without conversions from non-residential), such as NBMC 20.46.030.C. When added to the
79 dwelling units added to the General Plan without voter approval in the last ten years, it
certainly appears that approval of the 49 additional units proposed in this Project will require
a Charter Section 423 vote.
9. Page 6-5: The statement rejecting alternative locations because"the Project Applicant ...
cannot reasonably obtain ownership control over, any other parcels of land in the nearby
area under the jurisdiction of the City of Newport Beach that could accommodate the
Project," seems arbitrary and without foundation. Just as most of the public may not have K-10
known the 1.26 acre car wash parcel was available for sale, how do decision makers know
there is no other parcel of similar size in a more suitable location that could be purchased?
Since numerous exceptions are being requested to land use policies, it would seem
essentially any location could be considered.
10. Page 6-9, line 6: What is "(SB 375, 2016)"? Is this a reference to California SB 375
(Chapter 728, Statutes of 2008), or to some newer legislation? I am unable to find this K-1 1
otherwise identified or explained in the DEIR.
11. 1 agree with, and incorporate by reference, the comments on the DEIR dated June 22, 2016,
from Robert L. Rush/Committee of Concerned Citizens, distributed as"Item No. 4c K-12
Additional Materials Received" at the June 23, 2016, Planning Commission study session on
the subject property, with these exceptions and additions:
a. The abruptness of height change that would be created by approval of the proposed
project is even greater than that stated by Rush on page 5. Although an increase in
maximum allowable height to 50 feet was approved by the City Council as part of the
incorporation of The Irvine Company's portion of Block 100 into the North Newport
Center Planned Community through the adoption of Ordinance 2009-28, 1 believe no K-13
construction has occurred to that new standard. To the best of my knowledge, all
existing structures in all of Block 100 were built to the same 32 foot maximum height
standard that currently applies to the Project property, and I believe most are even
less tall than that.
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b. The presentation by the applicants at the June 23, 2016, Planning Commission study
session (captured on video at https://www.youtube.com/watch?v=eEKigVxWTGM ),
repeatedly emphasized that the Project was intended for very high income buyers, K-14
seemingly confirming the contention by Rush on page 8 that the appropriate traffic
standard is"luxury condominium."
c. The 1992 land use Declaration cited by Rush on page 18 would seem to me to
provide substantial evidence the adjacent land owner(The Irvine Company)felt, in
conveying the subject property to new owners, that the value of their remaining
property was enhanced by restricting the subject property to low-rise, low-mass auto-
related uses. If TIC allows the proposed Project to proceed, that would seem to me
substantial evidence that TIC has changed its assumptions and would expect the
City to provide similar accommodation for high-density, high-mass, high-rise K-1 5
construction on their portion of Block 100. To me, that supports a conclusion that a
reasonably foreseeable cumulative effect of the approval of the present Project
would be the development of a wall of buildings along the south side of Newport
Center Drive East, much as a substantial stretch of Mariners' Mile has become
walled in by the Balboa Bay Club development. That is clearly a highly significant
detrimental environmental impact.
12.As indicated by public testimony at the June 23, 2016, Planning Commission study session,
the DEIR fails to adequately assess the neighborhood incompatibilities that Project approval
would create through the impact of existing nearby uses on the potential residents of the
Project as new"sensitive receptors;'in particular, existing late-night activity at Muldoon's K-16
Irish Pub and existing parking lot uses in Design Plaza, including early morning trash
pickup/deliveries and late-night theater-related activity.
13.At the June 23, 2016, Planning Commission study session, the Commissioners asked
serious questions about the staging and routes of the construction traffic, to which the K-1 7
preparers of the DEIR did not seem to have answers.
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Jim Mosher—Comment Letter K
K-1:
The City of Newport Beach acknowledges the commenter's contact information.
K-2:
Please see Responses G-5 and I-1.
K-3:
Please see Response G-4 regarding the Project's consistency with General Plan Land Use Policy
6.14.4. The Project Applicant's request to change the land use from commercial to residential use
would require General Plan and Zoning Code amendments. Those amendments would need to be
adopted based on legislative policy decisions made by recommendation of the Planning Commission,
and adoption by the City Council. The DEIR fully evaluated the physical environmental impacts that
would be associated with any decision made by the Planning Commission and City Council if these
legislative bodies ultimately determine that the requested land use change would be appropriate for
Project site, given that the residential land use was not previously anticipated or considered at this
location during the 2006 General Plan update. While the proposed residential dwelling units are not
contributing to a RHNA requirement as the City has already met the dwelling unit requirement
identified by RHNA, there is a demonstrated market demand for additional residential development
in the Newport Center area. The units would only contribute to a RHNA requirement if they were to
be constructed in the next RHNA cycle (2021 or after).
K-4:
Please see Response G-4 regarding the Project's consistency with General Plan Land Use Policy
6.14.4. Also, each proposed project is evaluated individually,based on its own merits.
K-5:
Height limits established as part of an adopted planned community are not subject to the height limits
identified in Subsection 20.30.060 (Height Limits and Exceptions of the Zoning Code). However,
the applicable findings in compliance with subsection (C)(3) (Required Findings) are also applicable
with a discretionary action such as the adoption of a Planned Community District. Please see
Response J-I regarding the required findings.
K-6:
Please refer to Responses G-1, J-1, and J-5.
K-7:
The DEIR inadvertently included references to Figure 2-2 and Figure 2-3 on Page 4.7-3. The
references to these figures have been stricken from DEIR pages ES-4 and 3-15, which is indicated in
the Errata section of the Final EIR. The existing planning context for the proposed Project, including
existing Newport Beach General Plan and Zoning designations were disclosed in DEIR Subsections
2.3.1 and 2.3.2 on Page 2-2.
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K-8:
The text on Page 4.7-8 within the second paragraph of subsection 2 (City of Newport Beach General
Plan) has been revised to correct the typographical error indicated by the commenter. The revised
text, which indicates that a "new anomaly"would be required is identified in the Errata section of the
Final EIR.
K-9:
City Charter Section 423 and Council Policy A-18 are not applicable to the analysis of the physical
environmental impacts of the Project in accordance with the California Environmental Quality Act.
A detailed discussion of the provisions of City Charter Section 423 and Council Policy A-18 is
provided in the Planning Commission Staff Report, dated July 21, 2016. The DEIR (pages 4.7-3 to
4.7-23) adequately discusses whether or not the proposed project conflicts with Section 423. This is
all that CEQA requires (See CEQA Guidelines, § 15125(d) and Appendix G). The project does not
conflict with section 423 because, as required by City Council Policy A-18, the analysis of whether
approval by the electorate is necessary is performed by the planning department in staff reports for
the Planning Commission and City Council separate from the EIR process. The proposed project
does not interfere with the Section 423 process and the DEIR acknowledges that this process will be
required. The DEIR does not need to analyze whether voter approval is required. Also refer to
Response 0-16.
K-10:
CEQA requires that an EIR identify a range of potentially feasible alternatives that, if adopted, would
avoid or substantially lessen the significant adverse impacts of a project, but does not mandate that it
discuss alternative off-site locations for a project. The CEQA Guidelines §15126.6(a) states that an
FIR must include a reasonable range of alternatives to the project or to the location of the project
(emphasis added). An EIR need not consider alternatives that are infeasible (See CEQA Guidelines
§15126.6(f)(3). Off-site alternatives may therefore be excluded from analysis as infeasible when
such sites are not owned or could not reasonably be obtained or controlled by the Project Applicant
(CEQA Guidelines §15126.6(f)(1)). The Project Applicant has indicated that it does not own any
other properties in Newport Center. Also, there is no evidence to support a reasonable assumption
that the Project Applicant could reasonably obtain or control another site in Newport Center that
could serve as an alternative location for the proposed Project.
K-11:
The reference to "SB 375" indicated on Page 6-9 of the DEIR refers to the Sustainable Communities
and Climate Protection Act of 2008, Senate Bill No. 375, Chapter 728, Statutes of 2008. The text on
Page 6-9 has been revised to indicate the correct reference year.
K-12:
The comments provided by Mr. Robert L. Rush are addressed in Responses L-1 through L-18.
K-13:
Please see Responses G-4 and J-5, including Exhibit A that accompanies Response G-4.
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K-14:
The ITE trip generation rate for High-Rise Condominium/Townhouse (ITE Code 232) was used to
determine the daily traffic volume for the proposed Project. The Luxury Condo (ITE Code 233) does
not identify an average daily trip generation rate and is considered a related land use of the High-Rise
Condominium/Townhouse land use. The average daily trip generation was required to be calculated
in order to determine whether a TPO study is required, or to determine if the Project is exempt from a
TPO study. Accordingly, the High Rise Condo rate was used for consistency purposes to calculate
the peak hour trips.
It should be noted that with both the High Rise Condo rate and the Luxury Condo rate, there would
be a net negative peak hour trip generation for the Project with the elimination of the existing car
wash trips that currently travel to and from the site. For informational purposes, the calculations are
provided below that show the projected reductions in AM peak hour and PM peak hour trips using
both the High Rise Condo and Luxury Condo trip generation rates when compared to the existing car
wash use.
Trip Generation Comparison
AM Peak Hour PM Peak Hour
(Trips) (Trips)
High Rise Residential Condo ITE Code (232
Trips Generated Based on High Rise 17 19
Condo (232) Generation Factors
Trips Generated by Existing Car Wash 54 75
(based on physical traffic counts)
Net Reduction under Proposed Project -37 -56
Luxury Condo/Townhouse ITE Code (233
Trips Generated Based on Luxury Condo 27 27
(233) Generation Factors
Trips Generated by Existing Car Wash 54 75
(based on physical traffic counts)
Net Reduction under Proposed Project -27 -48
K-15:
Please see Response G-6. Refer to Response L-19 regarding The Declaration of Land Use
Restrictions. This is a civil matter between two private property owners and expires after a term of
25 years on February 20, 2017.
K-16:
Please see Response J-3.
K-17:
The demolition hauling routes and construction materials delivery routes are described in Section
3.4.7 of the DEIR, and the potential impacts associated with construction traffic are disclosed in
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Section 4.9 of the DE1R. Additional information related to construction materials delivery routes,
see the Construction Management Plan included in Appendix M of the DEER (as updated by the
report included in the Errata section).
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COMMENT LETTERS
June 22,2016
Makana Nova
City of Newport Beach
100 Civic Center Drive
Newport Beach,CA 92660
Re: Newport Center Villas Study Session
Dear Ms.Nova,
We, a group of concerned Newport Beach residents, originally commented on the
Mitigated Negative Declaration published by the City of Newport Beach on behalf of the
Newport Center Villas on September 9, 2015 in a letter to this Commission dated September L-1
25, 2015. We incorporate those comments by reference. There are many specific problems
and insufficiencies with this project,few of which have been dealt with by this study.
The environmental impact report prepared for the 150 Newport Center project ("EIR")
fails to appropriately and adequately analyze that project's significant environmental impacts.
Its many serious flaws cannot be resolved without recirculation.
The California Environmental Quality Act ("CECLA") requires thorough analysis of a
project's potentially significant environmental impacts and, if scrupulously followed, will
provide the public with meaningful information about an agency's consideration of a project.
Laurel Heights Improvement Assn. v. Regents of University of California (1988)47 Cal.3d 376,
392. To promote its public disclosure requirements, CEQA must be interpreted to afford the
fullest possible protection to the environment within the reasonable scope of statutory
language. friends of Mammoth v.Board of Supervisors(1972)8 Cal.3d 247,259.
CEQA contains an array of procedural and informational disclosure requirements—not L-2
suggestions. If an EIR fails to meet CEQA's standards, the lead agency responsible for its
preparation (here, the City of Newport Beach) has prejudicially abused its discretion and any
approval of that document constitutes a violation of law. Vineyard Area Citizens for Responsible
Growth, Inc. v. City of Rancho Cordova (2007) 40 CalAth 412, 426 Ian abuse of discretion is
established if the agency has not proceeded in a manner required by law or if its factual
determinations are not supported by substantial evidence].
As discussed in this letter,the EIR fails to comply with the requirements of CEQA in the
following key ways:
• The EIR omits crucial analysis, including examination mandated by the EIR's
own thresholds of significance.
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• Discussion and analysis of reasonably foreseeable significant environmental
impacts is absent from the EIR.
• The project would result in significant environmental impacts that are not
identified in the EIR.
L-2
Because the EIR must be revised to include the new significant impacts identified in this letter, (cont.)
it must be recirculated under California Code of Regulations, Title 14 Chapter 3 ("CEQA
Guidelines") Section 15088.5. Mount Shasta Bioregional Ecology Center v. County of Siskiyou
(2012) 210 Cal.App.4th 184, 217 [CEQA mandates recirculation when significant new
information is added to an EIR after public comment has finished]. Otherwise, the EIR is
fundamentally flawed and its certification would constitute a prejudicial abuse of discretion by
the City.
In addition to the identified non-compliance with CEQA, any approval of the proposed
project would also constitute improper spot zoning because it would create a small(1.26 acre) L-3
residential island surrounded by zoning that expressly prohibits residential uses.
I. The EIR Relies on a Misleading Baseline That Is Not Supported By Substantial Evidence
The determination of whether a project's environmental impacts are likely to be
significant requires that a lead agency "use some measure of the environment's state absent
the project, a measure sometimes referred to as the 'baseline' for environmental analysis."
Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010)48
Cal.4th 310, 315. The utilization of a proper environmental baseline is essential to the
meaningful assessment of the project's impacts. Id.at 320. A lead agency may normally use
the environmental setting at the time that environmental analysis is commenced as the
baseline physical conditions against which a project's impacts are measured. CEQA Guidelines
4 15125. However, the baseline conditions cannot be arbitrarily selected, and instead should
be "realistically" measured. Neighbors for Smart Rail v. Exposition Metro Line Construction
Authority(2013) 57 Cal.4th 439,449. Furthermore,the lead agency's selection of the baseline
conditions must be supported by substantial evidence. Id. In fact,the California Supreme Court L-4
has held that the use of an environmental baseline that is misleading or without informational
value to the public or decisionmakers constitutes an abuse of discretion in violation of CEQA.
Id.
The EIR is legally inadequate due to its use reliance on a baseline that is unrealistic,
misleading,and not supported by substantial evidence. Specifically,the EIR uses a baseline that
assumes the continued operation of the existing car wash,which was presumably intended to
reflect the physical conditions at the commencement of EIR preparation. However, this
baseline fails to properly account for the fact that the existing car wash "will close in late 2016
regardless if the proposed Project goes forward." EIR at ES-6,6-1,6-7,6-12(emphasis added).
Given the acknowledged cessation of car wash operations in the immediate future, it is
improper and misleading to analyze the project's impacts against a baseline that assumes
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continued operation. Instead, the EIR's baseline must reflect the absence of car wash
operations.
The EIR's reliance upon a misleading baseline obfuscates the analysis of the project's
impacts and project alternatives and is not supported by substantial evidence. As indicated
above, the car wash will cease operations in 2016 regardless of whether the project is
developed. EIR at ES-6,6-1,6-7,6-12. However,because construction of the project will not be
complete,and project operations will not commence,until 2019(EIR at 4.2-16),the measure of
the"environment's state absent the project"should properly account for the closure of the car
wash. Communities for a Better Environment, supra, 48 Cal.4th at 315. The EIR's impact
analyses for the following areas unrealistically and misleadingly evaluates the project's net
operational impacts above and beyond the existing car wash:
• Aesthetics: The project's impacts resulting from new sources of substantial light
or glare are evaluated in comparison to the operating car wash. EIR at 4.1-24. In
reality,the car wash will be shuttered in late 2016 and will emit no light.
• Air Quality: The project's air quality impacts, which are directly tied to vehicle
emissions, are only evaluated in comparison to the operating car wash and its
vehicle trips. EIR at 4.2-10, 4.2-16, 4.2-19, 4.2-23. The appropriate comparison
should assume zero emissions from the car wash,which will close in late 2016.
• Hazards and Hazardous Materials: The project's impacts on the implementation
of, or physical interference with, an adopted emergency response plan or L-4
emergency evacuation plan are based on a comparison to traffic generated by (cont.)
the exiting car wash.EIR at 4.6-15. Again,given the impending closure of the car
wash,zero traffic should be assumed from the existing car wash.
• Noise: The project's noise impacts are analyzed in comparison to the existing car
wash operations and vehicle traffic related to the same. EIR at 4.8-8,4.8-9,4.8-
11, 4.8-12, 4.8-14. Neither assumption is accurate. The EIR's operational and
vehicle noise should both be revised to reflect a closed car wash.
• Transportation and Traffic: The EIR's traffic analysis only evaluates the project's
net increase above the assumed trips generated by the car wash,thereby taking
credit for 819 daily trips. EIR at 4.9-5,4.9-7, 4.9-8, 4.9-9,4.9-10, 4.9-15, 4.9-16.
This is inaccurate,as a closed car wash generates no trips—much less 819 trips.
• Utilities and Service Systems: The project's impacts on domestic water and
wastewater are evaluated by comparing the proposed project's demands to
those of the carwash. This false comparison underestimates wastewater
generation and domestic water usage by 9,470 gallons per day(gpd)and 10,417
gpd, respectively. EIR at 5-16. All of the car wash's existing domestic and
wastewater generation figures must be revised to reflect a closed car wash.
In short, although the EIR unambiguously states that the existing car wash will cease
operations regardless of whether the proposed project proceeds,the EIR assumes its continued
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operation and only evaluates the project's net impacts. This methodology deceives the public
about the project's impacts because the project is essentially given "credit" for eliminating
operational features of the car wash (e.g., emissions, noise and traffic impacts from vehicle
trips to and from the car wash,water usage from the car wash,etc.)that will cease even in the
absence of the project. This is fundamentally misleading to decisionmakers and the public L-4
because it results in the understatement of—or failure to identify—significant project impacts (cont.)
as well as applicable mitigation measures. Moreover,this grossly distorts the EIR's alternatives
analysis, which is based on mitigating impacts that the EIR fails to identify. Accordingly, the
EIR's failure to support the selection of this baseline with substantial evidence constitutes an
abuse of discretion and renders the entire EIR legally deficient. Wholesale revisions to the EIR's
baseline assumptions are required in a recirculated EIR.
In fact, there is substantial evidence that cessation of the car wash operations at the
project site will not wholly eliminate car washing by the customers of the existing facility, but
will instead only shift such car washing activity to other commercial or residential locations.
Thus, there is no basis for the EIR's assumed reductions in the impact areas discussed above. L-5
Moreover, the EIR fails to evaluate the impacts of this reasonably foreseeable shift of car
washing to other locations, which could have significant adverse environmental impacts. The
reasonably foreseeable potential impacts resulting from the redistribution of these activities
must be analyzed in the EIR.
If. The EIR's Conclusions Regarding Aesthetic Impacts Are Not Supported by Substantial
Evidence
a. The Height of the Project Would Degrade the Existing Environment
The EIR's aesthetics analysis is fundamentally flawed because, despite overwhelming
substantial evidence to the contrary, it unreasonably concludes that the project will not
degrade the existing environment. This conclusion is based largely on the assertion that the
project's height will be consistent with other nearby high-rise developments. However, to
reach this conclusion, the EIR mistakenly compares the proposed 83 foot tall project to
developments outside the immediate vicinity of the project,and fails to acknowledge that the
project's height is fundamentally inconsistent with existing development standards surrounding L-6
the project site.
To assess the project's potential to degrade the existing environment,the EIR analyzes whether
the project's 83-foot height would be consistent with the height of existing buildings and height
limits within Newport Center. EIR at 4.1-22(acknowledging that,although the project would be
taller than existing buildings on immediately adjacent properties, the project would be
comparable with heights elsewhere in Newport Center]. This analysis artificially minimizes the
impact of the project's height,which should be judged relative to the height of other projects in
the immediate vicinity only. The height of "the existing office towers 21 stories (300 feet) in
height located along San Joaquin Hills Road," for example, is irrelevant to the project. EIR at
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4.1-22. That building, the tallest in Newport Center, is approximately 2,000 feet northeast of
the project site and has no bearing on the project's aesthetic impact. EIR at 4.1-22.
There is no reasonable basis for expanding the existing environment to include high-rise
buildings outside the project's vicinity, especially when applicable development standards
prohibit similarly sized projects in the area surrounding the project site. San Francisco Beautiful
v. City and County of San Francisco (2014) 226 Cal.App.4th 1012, 1027 (significant impacts
should be measured in light of the context in which it occurs and aesthetic impacts should be
analyzed to determine whether a project "would degrade the existing visual character or
quality of the site or its surroundings"](emphasis added).
The inappropriateness of the EIR's methodology is exacerbated by the project's
inconsistency with the General Plan. General Plan Policy LU 6.14.14 states that development
of Newport Center should concentrate the greatest building mass and height in the
northeasterly section along San Joaquin Hills Road and progressively scale dawn building
mass and height toward East Coast Highway. The project site is located in the southeasterly
portion of Newport Center where the General Plan requires"scale[d] down building mass and
height."
The project site is bordered to the west and south by Planned Community 56 (North
Newport Center), which governs a large portion of Newport Center. The development
standards in Planned Community 56 implement Policy LU 6.14.14 by restricting the height of L-6
structures immediately adjacent to the project site and by allowing for greater heights in areas (Cont.)
in the northeaster section of Newport Center (Blocks 400, 500, and 600). However, the
designated blocks with greater building heights (i.e., similar to the proposed project) are
located more than 1,000 feet from the project site and do not represent the development
standard applicable to the project site or its surrounding areas.r
The development standards applicable to the area surrounding the project site limit
heights to 50 and 32 feet, depending upon the zoning designation. Block 100, which borders
the project site to the south and west imposes a 50 foot height maximum. See Planned
Community 56 at 15. Similarly, the property to the east across Anacapa Drive to San Miguel
Drive (approximately 900 - 1,000 feet from the project site), mandates a 32 foot height
maximum. Newport Beach Municipal Code§20.20.030. Thus,the existing building heights and
height limitations governing not just the "immediately adjacent" properties,as represented by
the EIR, but properties extending significant distances in various directions are limited to
approximately 32—50 feet,depending on zoning designation.
It is against these height limits that the project should be judged,as they best represent
the aesthetic characteristics and quality of the site and its surroundings. The height of "the
t Morcomr, it is caoncots to analyze the impacts of the proposed project with reference to the larger boldines
locite i more th:m 1,000 feet meay because the project site is largely obscured front the areas ofNcwpon Center[lull
have hlElbrlse buildings. Thus.[lie project site ama is visually distinct from the amus Of NCWpUn Center that are
destgn:dcd for greater building heights.
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existing office towers 21 stories(300 feet) in height located along San Joaquin Hills Road,"for L-6
example, is irrelevant to the project. EIR at 4.1-22. Because the project would introduce a
buildings substantially inconsistent with existing building heights,it would be "demonstratively (cont.)
inconsistent"with the character of the surrounding area.' EIR at 4.1-11.
b. The Project Would Have a Significant Adverse Impact on Scenic Views
The EIR includes a limited number of carefully-selected images of viewpoints at various
public vistas in the surrounding area that do not adequately demonstrate the project's impact.
For instance, View 3 (Figure 4.1-7) appears strategically positioned to misrepresent the
expansive ocean views looking south along Newport Center Drive (near the intersection
between Newport Center Drive and San Miguel Drive). The view from the intersection of
Newport Center Drive and San Miguel Drive provides a more accurate representation of how
the project would severely impact ocean views from Newport Center Drive. Attached Exhibit A
shows the southerly views of the ocean from near that intersection. As evidenced by that
exhibit, the ocean is highly visible along Newport Center Drive and San Miguel Drive,and thus
constitutes a scenic viewpoint.
The Natural Resources Element of the General Plan states that the "City of Newport
Beach is located in a unique and dynamic physical setting and enjoys...spectacular ocean views
to the southwest,including those of the open waters of the ocean and the bay...:' General Plan
at 10-16. Because the project would introduce a building that would significantly obscure a
view of the"open waters" of the Pacific Ocean, it would have a significant impact on a scenic
vista. General Plan at 10-16; Ocean View Estates Homeowner's Assn v. Montecito Water Dist.
(2004) 116 Cal.App.4th 396, 400 ["Any substantial negative effect of a project on view and L-7
other features of beauty could constitute a significant environmental impact under CEQA").
That impact must be discussed and, to the extent such discussion is omitted, the EIR's
conclusions regarding impacts to scenic vistas is without substantial evidence. Tracy First v.City
of Tracy (2009) 177 Cal.App.4th 912, 934 (substantial evidence must support a lead agency's
conclusions).
The EIR also concludes that impacts to View 3 would be less than significant partially
because the proposed building"is not out of scale with existing commercial buildings" located
near the project site. As discussed in detail above, this is factually incorrect. The existing
buildings near the project site are substantially smaller(32—50 feet)than the proposed project
(83 feet). Furthermore, the conclusion that the proposed building would be only partially
visible from View 3 is based largely on the positioning of the view along the northern side of
Newport Center Drive. The building would have a much greater impact, and would be
The EIR's 16med aesiheiics analysis carries over to the No Project/Olrec Development Ahenuuive. In the
discussion of that alternative's aesthetic impacts. the EIR nota that "JaIlIhoueh arguments could be made for
whether n one-or nvo-stop building or the proposed Project's seven-story building would be more in keeping with
the existing visual character and quality of the site and areae"neither the project nor the:ltcmative would result in
signiftcam impacts. There is simply no justification for the conclusions that at one.or nvo-stop building and a
seven-story building have the sone level of consistency with it surrounding environment comprised of buildings
prinmrily in the 20-40 foot range.
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significantly more imposing,when viewed from the other side of the Newport Center Drive/San L-7
Miguel Drive intersection. (Cont.)
C. The EIR's Analysis of Glare Impacts is Devoid of Meaningful Information and
Substantial Evidence
The EIR concludes that the project would not result in any significant impacts associated
with glare because the building would not include components that would generate substantial
amounts of reflective surfaces. EIR at 4.1-26. This conclusion, however, is curious given the
that the project's elevations (EIR Figures 3-5 and 3-6)show that the building's exterior will be
comprised largely of glass. The EIR attempts to dispense with this fact by stating that the L-a
windows"would not be mirrored and would have similar low-potential glare characteristics as
do other" windows in the surrounding area. This factually-devoid analysis does not comply
with CEQA.Association of Irritated Residents v. County of Madera(2003)107 Cal.App.4th 1383,
1390 [CEQA does not demand exhaustive analysis or perfection, but does require a factual
analysis and a good faith effort at disclosure]. Simply put, the introduction of a substantial
number of glass windows up to seven stories high will introduce a significant source of glare in
the project area. This impact must be analyzed,both for possible safety and aesthetic impacts.
III. The EIR's Analysis of Traffic Impacts Fails to Comply With CEQA
a. EIR Materially Underestimates Traffic Generation and Locks Substantial Evidence
to Support its Trip Generation Assumptions
Like the MND, the EIR analyzes traffic impacts using an erroneous designation and trip
generation rates from the Institution of Transportation Engineers("ITE"). To calculate project
vehicular trips, the EIR utilizes the High-Rise Residential Condominium designation, which it
states was applied based on"review of land use categories and trip generation rates"of the ITE
Trip Generation Handbook. Appendix GI at 2(emphasis added). This designation was applied
without explanation.
We can only guess that the High-Rise Residential Condominium designation was applied L-9
to the project because it would exceed three stories, since the EIR is devoid of a coherent
explanation as to why that is an appropriate designation. EIR at 3-2. That designation is
convenient because it has the lowest trip generation rate of any potentially-applicable
condominium category a
1 'ncc rrE Trip Gcncmlion Handbook defines High-Rist, Condominium/Townhouse as `high-rise residenlinl
condominiums/lowmhouses arc(mils located in buildings that have dirce or more levels(floors)."
' For example.the Residential Condominiun/Tmcnhouse designation Ices a trip generation nuc of approxincmely
5.81 trips per dwelling unit,while the Luxury CondominiunUTownhotac designation would generale peak hour trips
almost double the High-Rist Condominium designation.
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The High-Rise Residential Condominium designation does not accurately represent the
project,which would include (1)10 residential townhomes ranging from 3,581 to 5,371 square
feet, (2) 35 residential flats ranging from 1,645 to 3,608 square feet, (3)four penthouse units
ranging from 2,285 to 3,608 square feet, and (4) various amenities available for resident use,
including a club room and appointed kitchen for catering,a fitness room,and a swimming pool.
EIR at 3-5. Because these attributes and unit sizes are typically associated with luxury
condominiums,the ITE Luxury Condominium designation better represents the projects
Moreover, the project objectives explicitly describe the project as consisting of luxury
condominiums. Section 3.2, Statement of Objectives, provides that the underlying purpose of
the project is to"redevelop an underutilized property in the Newport Center area with multi-
family, for-sale luxury high-rise (three + stories) residential units...:' EIR at 3-2 (emphasis
added). The project objectives also state that the project is intended to (1) "[r]espond to the
demand for luxury,multi-family"housing,and(2)"[ijntroduce a luxury,multi-family residential
development in Newport Center...:'Id.(emphasis added).
The EIR's lack of substantial evidence explaining why the High-Rise Condominium
designation is appropriate for the project is itself a violation of CECLA. Federation of Hillside& L"9
Canyon Associations v. City of Las Angeles (2000) 83 Cal.App.4th 1252, 1259 [substantial (cont.)
evidence must support the agency's conclusions]. CEOA defines substantial evidence as"facts,
reasonable assumptions predicated upon facts,and expert opinion supported by facts." CECIA
Guidelines § 15384(6). Here, there are no facts that support application of the High-Rise
Condominium designation. Furthermore,as discussed above,there is substantial evidence that
the Luxury Condominium designation is more appropriate for the project.
The table below identifies the trip generation rates for High-Rise Condominiums and
Luxury Condominiums,respectively:
High-Rise Condominium Luxury Condominium
AM Peak Hour 0.34 0.65
PM Peak Hour 0.38 0.65
The table above demonstrates that the Luxury Condominium designation would generate
approximately twice the number of trips as the High-Rise Condominium designation. Because
there is substantial evidence supporting the application of the Luxury Condominium
designation, the EIR's analysis must be revised to appropriately assess the traffic impacts
associated with the project.
b. EIR's Conclusions About Construction Traffic Are Based on Inconsistent
Information
L-10
The ITL Trip Generation Handbook defines Luxury Condowiniwnrrollmhousc as"unils in buildings with luxury
fecililies or services:'
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The construction traffic analysis notes that the project would require the export of
demolition and earth material,which would generate approximately 24-26 round trip haul trips
per day. EIR at 4.9-7. These trips, the EIR concludes, would not result in a significant traffic
impact. However, this analysis greatly underestimates the number of truck trips associated
with grading of the project site, and contradicts the EIR's prior statements on the topic. As
noted in the Project Description, project grading would excavate 51,600 cubic yards of cut
during a one-month period, generating approximately 2,580 haul trips during grading (172
round trips per day). EIR at 3-9. 172 round trips is substantially greater than the 24-26 L-1 0
assumed in the construction analysis and, because truck trips have a larger impact on traffic (cant.)
than do standard vehicular trips,the impact of these truck trips must be analyzed.
Moreover, the EIR concludes that there would be no significant construction traffic
impact because the number of construction trips generated by the project would be less than
those associated with car wash's existing operations. As discussed above, this conclusion is
based upon a fundamentally inadequate baseline and must be re-evaluated. The appropriate
baseline for existing operations is zero given the pending closure of the car wash.
IV. The Noise Analysis Omits Required Information and Analysis
a. EIR Fails to Identify and Address Noise Impacts on Nearby Sensitive Receptors
The EIR's noise impacts analysis falls short because it fails to identify nearby sensitive
receptors. It concludes that there is only one sensitive receptor that could be impacted by the
project-the Newport Center Women's Health Center,located approximately 100 meters south
of the project site. EIR at 4.8-4. This assertion, however, fails to account for the broader
definition of sensitive receptors used in the EIR,which requires characterization of additional
nearby uses,particularly three restaurants with outdoor seating,as sensitive receptors.
The EIR specifies that sensitive land uses are generally those "where people reside or
where the presence of noise could adversely affect the use of land." EIR at 4.8-4 (emphasis
added). Consistent with this definition,the EIR notes that"[s]ensitive land uses include but are
not limited to uses such as schools, hospitals, residences, libraries, and recreation areas." Id.
(emphasis added). Thus, in determining whether a given land use should be considered
sensitive,the EIR provides that the pertinent question is whether the presence of noise could
adversely affect the use. California Native Plant Soc. v. City of Santa Cruz (2009) 177
Cal.App.4th 957,986[a lead agency is entitled to define the scope of analysis and methodology
so long as it is supported by substantial evidence]. Here,the EIR has defined what uses should
be considered"sensitive"and must apply that definition appropriately.
Red O, Fig & Olive, and Muldoon's Irish Pub are all restaurants located directly across
either Anacapa Drive or Newport Center Drive from the project site. Unlike most restaurants
(which are generally are not considered sensitive receptors), all three restaurants have
significant outdoor dining areas. These outdoor dining areas are sensitive receptors because
the presence of noise—particularly during construction activities—could adversely affect their
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use. See EIR at 4.8-4. The existence of these outdoor dining areas also undermines the
assumption in the construction noise impact analysis that surrounding uses are primarily indoor
uses. EIR at 4.8-12 ["...due to the commercial character of surrounding properties, persons on
adjacent properties would spend a majority of their time indoors with windows closed and not
be exposed to loud construction noise"].
In addition to failing to properly account for impacts at nearby sensitive receptors,the
EIR also fails to appropriately analyze construction noise impacts, instead generally asserting
that there would not be any significant impacts because (1) construction-related noise would
only occur for approximately eight hours a day,and(2)the surrounding uses are predominantly
commercial. As discussed above,the latter assumption is wrong and there are nearby sensitive
receptors. Moreover, the EIR makes this conclusion without any meaningful analysis of actual
noise impacts despite the acknowledgement that construction equipment could produce
periodic noise levels nearing 90 dBA at adjacent property lines. EIR at 4.8-12. Such analysis
fails to adequately address noise threshold(d),which asks whether the project would result in a
substantial temporary or periodic increase in ambient noise. To properly assess the impact
under this threshold, the ambient noise must (obviously) first be quantified. The EIR fails to
undertake this fundamental analysis,instead providing a general qualitative discussion of noise
in EIR Section 4.8.2.6 This failure undermines CEOA's informational disclosure requirements,
and constitutes a failure to proceed as required by law. Association of Irritated Residents v.
County of Madero(2003)107 Cal.AppAth 1383,1390(when assessing the legal sufficiency of an
environmental document, a court focuses on adequacy,completeness,and a good faith effort "1
at disclosure]. (cont.)
The EIR apparently tries to alleviate the need to quantify ambient noise (despite the
EIR's stated thresholds) by stating that under threshold (d) the project would only have a
significant short-term impact if construction operations would generate noise levels
experienced by persons at off-site locations of 90 dBA or greater for more than eight hours.
According to the EIR, this is an appropriate standard because only such exposure can affect
human health.' EIR at 4.8-8. In so doing,the EIR fundamentally misapplies the threshold:the
question is not whether construction noise would result in hearing loss, but whether there
would be a temporary or periodic increase in ambient levels above existing levels without the
project a Mejia v. City of Las Angeles (2005) 130 Cal.App.4th 322, 342 (a lead agency cannot
apply a threshold of significance in a way that forecloses the consideration of substantial
evidence showing there may be a significant impact].To comply with the mandates of CEOA,a
standard that more accurately represents potential noise impacts—for example, whether the
ambient noise would be increased by 3 dBA(which represents a doubling of noise)—should be
applied to assess whether noise would have an adverse impact on nearby uses.
"I'he assessment ofoperatimml noise impacts:dso suffers frmn this fundamental flaw.
'See also EIR a(4.8-12,concluding dun grading and excavation activities would not result in a sigmificunt impact
because"construction-rclatcd noise would not occur for a period long enough or loud enough to cause hearing
damage to receivers ai off-site properties."
'A requirement to quantify,noise generated by the project is:dso inhcrendy required by(his threshold.
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b. EIR Lacks Analysis of Ambient Noise as Required by CEQA and Applied Thresholds
Finally, the EIR fails to provide any meaningful analysis of the noise created by the
project's operation or analyze whether such noise would result in a significant impact. For
example, under noise threshold (a), the EIR lists the applicable noise standards, but then
concludes the project would not result in any exceedence of these standards because the L-1 2
project would represent an overall decrease in the amount of stationary noise that would be
generated at the project site. EIR at 4.8-10. This conclusion is unsupported and without any
meaningful, factual analysis, and does not represent a good faith attempt at full disclosure.'
Federation of Hillside& Canyon Associations v. City of Los Angeles (2000)83 Cal.App.4th 1252,
1259 [a lead agency's conclusions must be supported by substantial evidence);Association of
Irritated Residents v. County of Madero(2003)107 Cal.App.4th 1383,1390.
V. EIR's Land Use Conclusions Are Not Supported by Substantial Evidence
With respect to consistency with the General Plan,the EIR's conclusion that the project
would be consistent with the General Plan is not supported by substantial evidence and fails to
satisfy the standard for General Plan consistency outlined by case law. A project is consistent
with the general plan if,considering all its aspects, it will further the objectives and policies of
the general plan and not obstruct their attainment. Clover Valley Foundation v. City of Rocklin
(2011) 197 Cal.App.4th 200, 238. However, general consistencies with plan policies cannot
overcome specific, mandatory and fundamental inconsistencies with plan policies. Id. at 239;
Spring Valley Lake Assn. v. City of Victorville (2016) (D069442) (Ordered Published on lune 15,
2016) [a "project's consistency with a general plan's broader policies cannot overcome a
project's inconsistency with a general plan's more specific, mandatory and fundamental
policies"].
Of particular importance, the EIR states that the project would be consistent with
General Plan Policy LU 6.14.4, which presents the general height and massing vision for L-13
Newport Center. Policy LU 6.14.4 provides,in its entirety:
Development Scale. Reinforce the original design concept for
Newport Center by concentrating the greatest building mass and
height in the northeasterly section along San Joaquin Road,where
the natural topography is highest and progressively scaling down
building mass and height to follow the lower elevations toward
the southwesterly edge along East Coast Highway.
As furiher evidence of the EIR's failure to comply wish CEQA.Section 4.8.7 concludes den,under Thresholds:)
and d).Ihcre would be a"potentially significant impact." This is an inappropriam conclusion in an EIR,which is
supposed to contain infonu;nion sufficient to make a dacmuivation whether or not a project would have it
significant impact or not.
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Policy LU 6.14.4 is, without a doubt, a "specific, mandatory and fundamental" policy of the
General Plan,as it unequivocally identifies the development vision of Newport Center. Spring
Valley Lake Assn.,supra, D069442 [a project's noncompliance with a policy that required new
projects to generate on-site to the maximum extent feasible was a specific, mandatory, and
fundamental policy]. As with the policy in Spring Valley Lake Assn., Policy LU 6.14.4 requires
("by concentrating the greatest mass and height") height to be scaled down within Newport
Center. Thus,any inconsistency with Policy LU 6.14.4 requires a finding of overall general plan
inconsistency.
Like the (flawed) aesthetics analysis, the EIR concludes that the project is consistent
with Policy LU 6.14.4 largely based on the heights of buildings located over 1,000 feet away in
the northeastern section of Newport Center. EIR at 4.7-11. This analysis is inappropriate
because it fails to account for the explicit direction of Policy LU 6.14.4, namely concentrating
the greatest building mass along San Joaquin Road and progressively scaling down height
toward East Coast Highway. The General Plan also reinforces the general policy of scaled
development in Newport Center,stating that"[h]igh-rise office and hotel buildings to the north
of[Newport]Center form a visual background for lower rise buildings and uses to the south and
west." General Plan at 3-94. The EIR's analysis actually highlights the inconsistency.
For example,the EIR first states that the height of the proposed project would be less
than the existing office towers located along San Joaquin Road. EIR at 4.7-11. The EIR is correct L-13
in this regard, but the analysis fails thereafter as it then notes that the project would be
consistent with other buildings located closer to the project site, such as 260 Newport Center (Cont.)
Drive,that extend to approximately 74 feet in height. This statement is also true,but it cannot
be relied upon to support a conclusion of consistency with Policy LU 6.14.4 because a
comparison with 260 Newport Center Drive, an anomaly within the southwestern portion of
Newport Center, is inappropriate. The existence of a wrong, does not make adding another
wrong a right. The project would still be inconsistent with Policy LU 6.14.4 because it would
tower over nearby uses and would no longer progressively scale down development toward
East Coast Highway. It would,in fact,do just the opposite.
The EIR concludes that it the project would be consistent with Policy LU 6.14.4
because even if the project was constructed "the greatest building mass and height
would remain concentrated in the northeasterly section of Newport Center along San
Joaquin Road." This argument is a red-herring and illogical, and does not constitute
substantial evidence. Applying this rationale,the City could reasonably conclude that a
single building with a maximum height of 200 feet (which is shorter than the buildings
concentrated in the northeasterly section of Newport Center) could be constructed
along East Coast Highway and still be consistent with Policy LU 6.14.4 because the
greatest building mass and height would still be concentrated along San Joaquin Road.to
Clearly, that sort of tortured logic is not the intent of Policy LU 6.14.4,which expressly
t"The suuc logic could also be applied to multiple 200 foot buildings along East Const Highway as long as the
number orbuilding did not exceed the number and height existing along San Joaquin Road.
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requires "progressively scaling down building mass and height" towards East Coast
Highway. Because Policy LU 6.14.4 represents the General Plan's height and massing L-1 3
vision for Newport Center and, as such, is a "specific, mandatory and fundamental"
policy, the proposed project's inconsistency with Policy LU 6.14.4 is also an (Cont.)
inconsistency with the General Plan and a significant aesthetics impact."
VI. EIR's Water and Wastewater Analysis is Insufficient and Based on Faulty Assumptions
With respect to water demand,which ultimately implicates wastewater generation,the
EIR concludes that the project would demand approximately 10,417 gallons per day ("gpd").
EIR at 5-16. This figure was reached through a reverse engineering analysis based upon a
projected wastewater generation of 9,470 gpd,which was based on a wastewater flow factor of
7,526 gpd/acre. Appendix at 80. This analysis artificially and severely underestimates both the
water demand and amount of wastewater generated by the project. Moreover it is
inconsistent with water assessments conducted for other similar projects in the City. For
instance, the Ebb Tide Final Initial Study/Mitigated Negative Declaration analyzed water
demand based upon a per capita water use of 178.9 gpd. This figure represents the baseline
water usage (in daily per capita gallons) contained in the Mesa Consolidated Water District's
2010 Urban Water Management Plan.' While water for the project is not supplied by the
Mesa Consolidated Water District,the City of Newport Beach,which would supply water to the
project,also has a Urban Water Management Plan("Newport UWMP").
Like the Mesa Consolidated Water District's UWMP, the Newport UWMP identifies
water demand figures. For 2015,the City's interim water use target is 228.1 gallons per capita
per day ("gpcd"). Newport UWMP at 2. Using this figure as a realistic estimate of the water L-1 4
demand generated by the project, the 150 Newport Center would create a demand for
approximately 22,091 (110 residents x 228.1 gpcd = 22,091), which is over twice the water
demand assumptions used in the EIR. This analysis presents a far more realistic expectation of
water demand, and is consistent with water demand analyses presented in other
environmental documents. For example, the Ebb Tide MND and Lido Villas MND have
significantly higher water demand estimates. For the 23 multi-family dwelling units proposed
by the Lido Villas project, the MND analysis concluded that there would be a wastewater
generation of approximately 172,800 gpd. This, like the water demand numbers contained in
the Ebb Tide MND, is significantly higher than the water demand and wastewater generation
numbers for 150 Newport Center. Thus, to adequately understand the potential impacts
n Also. the project's proposed Planned Comnnwity. which world serve uS the mlewuu zoning desigmnion and
provide development standards, would be inconsistent wilh the Gencr l Plan. Clry of Irvine v. ln•iue Citizens
A&dnsl Ovenleaxiopmeut(1994)25 Cal.App.4th 868.879 la zoning ordinance is consistent with a city's general
plan where,considering all its aspects,the ordinance furthers the objectives and policies of the general plan mod docs
not obstruct their anainnsntl. Again,because the hcight of the proposed projca mould be fundamemalle inconstant
with the height and massing vision for Newport Center in Policy LU 6.14.4,the Planned Community would be
inconsistent with the General Phan.
1=The eater for the Ebb Tide project soros supplied by the Mesa Consolidalcd Waler District.
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associated with water demand and wastewater generation, including whether new L-14
infrastructure would be required,a new water analysis based upon realistic expectations must (cont.)
be conducted.
VII. The Alternatives Analysis Does Not Contribute to a Reasonable Range of Alternatives
a. The Project Objectives Are Written Artificially Narrow and Preclude Meaningful
Consideration of a Reasonable Range of Alternatives
An EIR must "describe a reasonable range of alternatives to the project, or to the
location of the project,which would feasibly obtain most of the basic project objectives of the
project,but would avoid or substantially lessen any of the significant effects of the project,and
evaluate the comparative merits of the alternatives." CEQA Guidelines § 15126.6(a). As
discussed below,the EIR's analysis of project alternatives fails to comply with this directive.
First,the EIR's stated project objectives are written so narrowly that consideration of a
reasonable range of alternatives is not possible. CEQA makes clear that the project objectives
should drive the agency's selection of alternatives for analysis an approval and a lead agency
may use its discretion when identifying particular objectives. California Native Plant Soc.V.City
of Santa Cruz(2009)177 Cal.App.4th 957,991. However,that discretion is not unlimited,and a
lead agency may not draft objectives or the project's underlying purpose so narrowly to
preclude meaningful consideration of a reasonable range of alternatives. North Coast Rivers
Alliance v. A.G. Kawamura (2016) 243 Cal.App.4th 647, 654. Here, the project objectives are
crafted intentionally narrow to preclude the consideration, and approval, of any potential
alternatives. The objectives include, among other things, (1) redevelop an underutilized L-15
property in Newport Center,(2)add for-sale,owner-occupied housing units in Newport Center,
(3) introduce a luxury, multi-family residential development in Newport Center, (4) provide
new multi-family residential development in Newport Center,and (5)implement a residential
development that provides for on-site amenities for its residents. EIR at 6-6. These are all
consistent with the underlying purpose of the project,which is to "redevelop an underutilized
property in the Newport Center with multi-family, for-sale luxury high-rise (three + stories)
residential units located within walking distance to employment,shopping,entertainment,and
recreation." EIR at 6-6.
The primary purpose and objectives are clearly written to foreclose meaningful analysis
and consideration of non-residential alternatives. Predictably, and based on these narrowly
drafted alternatives, the EIR states that the non-residential alternatives would not meet the
project objectives. For example, the EIR concludes that the No Project/Office Redevelopment
Alternative would only meet 4 of the 11 project objectives. EIR 6-19. Of course, the EIR can
make this conclusion because 5 of the 11 project objectives include some reference to the
provisions of residential uses.13 The duplicative nature of the objectives strongly suggests that
13 This docs not include Objective D. which addresses fil%116:0 feasibility, which appears to be applied to
discriminately to conclude That any non-rcsidcnlisl;Jlcruatives arc financially infeasible.
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they were drafted with the intention of rejecting alternatives for non-compliance with a
majority of the project objectives.14 This runs afoul of CEQA's requirements, and such gaming
of the system is not permitted.
Likewise, consideration of alternative sites is rejected because there are no available
sites"in or near'Newport Center. This rationale,however,fails to consider the possibility that L-1 5
alternative sites within the City of Newport Beach generally are available for development and (cont.)
would reduce the project's significant environmental impacts. Moreover,there is no evidence
that any alternative locations were ever actively sought out or considered. Flanders Foundation
v. City of Carmel-by-the-Sea (2012) 202 Cal.App.4th 603, 622 [sufficient evidence of economic
infeasibility when there was evidence that similar properties were looked for,but unable to be
found). Thus, the EIR's consideration of alternatives based upon the narrowly drafted
objectives is inappropriate and precludes consideration of a reasonable range of alternatives.
b. EIR Does Not Include Evidence of Financial Infeasibility
Objective B of the project objectives states that the project is intended to"(r)edevelop
an underutilized property with a use that is financially feasible to construct and operate." EIR
at 6-6. Applying this objective, the EIR concludes that two alternatives — the No
Project/Commercial Office Alternative and the Commercial/Restaurant Redevelopment
Alternative — would be infeasible. These conclusions are not supported by substantial
evidence, however, as required by CEQA. Laurel Heights Improvement Assn, v. Regents of the
University of California (1988) 47 Cal.3d 376, 406 (if an agency finds an alternative to be
infeasible, the reasons and facts that the agency claims support its conclusion must be
explained in meaningful detail).
With respect to economic infeasibility, the burden on the lead agency is equally as
significant and it must include factual evidence supporting its conclusion. The EIR relies solely
on a verbal communication between Ronald Soderling, Managing Member of Newport Center
Anacapa Associates, LLC and Tracy Zinn,Vice President of T&B Planning. See EIR Reference to L-1 6
Soderling,2016b. Reliance on this verbal communication as the sole justification for economic
infeasibility is wildly inappropriate and runs afoul of CEOA's informational mandates.
SPRAWLDEF v. San Francisco Bay Conservation and Development Commission (2014) 226
Cal.App.4th 905 (holding that a determination of economic infeasibility must be supported by
"some context" that allows for economic comparison such as, for example, providing side-by-
side comparative figures showing cost, capacity, and life of project, and explaining why an
alternative is not financially viable). Furthermore, a lead agency preparing an EIR may not
simply accept the project proponent's assertions about an alternative; the agency must
independently participate, review, analyze and discuss the alternatives in good faith. Sierra
Club v. Tahoe Regional Planning Agency (2013) 916 F.Supp.2d 1098, 1159, citing Save Round
Valley Alliance v.County of Inyo, 157 Cal.App.4th 1437,1460. Therefore,to comply with CEQA,
the EIR's alternative section must be revised to provide evidence of economic infeasibility.
I" If (here were only one objeclive regarding the provision of residential uses, for example, the No
Pmject/Conunercial Office Alicmafive would satisfy 4 of6 objectives.
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VIII. Project Approval Would Result in Impermissible Spot Zoning
The City's approval of the project approvals would constitute improper spot zoning. An
impermissible"spot zoning'occurs when a small parcel of land is subject to either more or less
restrictive zoning than surrounding properties. Foothills Communities Coalition v. County of
Orange (2014) 222 Cal.App.4th 1302, 1312. It is now well-settled that an "amendment to a
zoning ordinance that singles out a small parcel of land for a use different from that of the
surrounding properties and for the benefit of the owner of the small parcel and to the
detriment"of the surrounding owners is impermissible spot zoning. Id.at 1314. The essence of
spot zoning is irrational discrimination, and a property may not be arbitrarily singled out for
special treatment separate and apart from surrounding properties. Avendio San Juan
Partnership v. City of Son Clemente(2011) 201 Cal.App.4th 1256, 1268. Nevertheless,even if
spot zoning.occurs, courts recognize that such zoning may be justified if a substantial public
need exists,even if the property will also benefit. Foothills Communities Coalition,supra, 222
Cal.App.4th at 1314. The relevant question is whether the zoning ordinance is arbitrary and
discriminatory. Reynolds v. Barrett (1938)12 Cal.2d 244,250)holding that a zoning ordinance
that would have zoned one lot completely surrounded by non-residential uses as residential
was arbitrary and discriminatory).
Without a doubt, approval of the project would result in spot zoning. The proposed
project site is surrounded by zoning (and existing uses) that are uniformly commercial and
office oriented. The project site does not border any zones that would allow residential uses L-1 7
like the proposed project. The surrounding zoning is as follows:
• West and South: Block 100 Sub-Area of the North Newport Center Planned Community
Development Plan ("NNCPC"), a "Commercial Office" block that is generally comprised
of administrative and professional offices and permits uses such as limited accessory
retail,financial,service and entertainment. NNCPC at 1,11.It does not allow residential
uses.
• North: Fashion Island Sub-Area of the NNCPC, a primarily retail hub that permits uses
such as retail, dining,and commercial entertainment uses. NNCPC at 1, 11. It does not
allow residential uses.
• East: Office Regional Commercial zoning, which is intended to provide for areas
appropriate for corporate office,administrative and professional offices that serve local
and regional markets, with limited accessory financial, retail, services, and
entertainment uses. It does not allow residential uses. NBMC §§ 20.20.010 and
20.20.020.
The project approvals would,if approved by the City Council,result in an amendment to
the City's Zoning Ordinance that would single out a small island parcel(1.26-acre)for residential
development while keeping the adjacent properties zoned for commercial and office uses.
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Foothills Communities Coalition, supra, 222 Cal.App.4th at 1314. This constitutes arbitrary
special treatment for the project site. Avendio San Juan Partnership,supra, 201 Cal.App.4th at
1268[spot zoning exists when a parcel is being singled out for special treatment].
Moreover, although the project could conceivably serve the public interest by
expanding residential uses within the City, the project's inconsistency with the vision for
Newport Center would render any public interest finding arbitrary. The General Plan states
that Newport Center is a "master planned mixed-use development" consisting of retail,
professional office,entertainment,recreation,residential uses. General Plan at 3-95. However,
as a planned development, these uses have been allocated to various areas within Newport
Center consistent with the overall vision for Newport Center. For example, the NNCPC notes
that the sub-areas it created are intended to implement the General Plan's goal of creating a
successful mixed-use district that integrates economic and commercial centers and expands
opportunities for residential development. NNCPC at 1. With respect to expanded
opportunities for residential development,the NNCPC allocated all residential uses to specific
blocks located in the northern portion of Newport Center. NNCPC at 11. The other blocks,
located in the southern portion of Newport Center (and located adjacent and nearest to the
project site),are reserved for commercial and office uses. Id. Similarly,the Zoning Ordinance,
which designates the project site and other nearby property as Office Regional Commercial, L-1 7
reserves the area for commercial and office uses. NEMC 4 20.20.020. (cont.)
Furthermore,the proposed project would allow for the development of an over-height,
residential building inconsistent with the surrounding environment and General Plan Policy LU
6.14.4. As discussed above,Policy LU 6.14.4 provides that development within Newport Center
should reinforce the original design concept by locating high-rise development in the
northeastern section along San Joaquin Road and progressively scaled down toward East Coast
Highway. Policy LU 6.14.4. The project would be fundamentally inconsistent with this policy,
further demonstrating how the project's special treatment is to the detriment of the
surrounding properties which are limited by existing zoning and development standards.
Finally, the City currently does not have a significant need for additional housing that
would justify spot zoning the project site. As noted in the Initial Study, the City only needs a
total of five new units to meet its Southern California Association of Governments projected
regional housing needs. Initial Study at 66. Thus, because the project would be inconsistent
with the development vision and standards of Newport Center and is not necessary to meeting
housing needs within the City, any approval of the project based upon serving the public
interest would be arbitrary. Foothills Communities Coalition, supra, 222 CaLApp.4th at 1314
[finding that a new senior residential housing zone was in the public interest,as supported by
references to state law and the housing element,and as consistent with the general plan].
IX. The Project's Proposed Use of the Anacapa Drive Right-of-Way is Not Permitted by the
Underlying Easement and Would Result in Traffic Safety Impacts L-1 B
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The project's proposed Site Circulation Plan, Appendix G2, appears to state that the
project will utilize the Anacapa Drive right-of-way for both (1)staging of moving trucks,and(2)
trash trucks. Appendix G2 at 2. With respect to trash, Appendix G2 notes that pick-up and
loading is not permitted in the Anacapa Drive right-of-way. Id. It is unclear how such activities
will be avoided, however, given the conceptual site plans for the project show little, if any,
additional property near the parking structure entrance (where trash will be stored)that could
handle such activities. See EIR Figures 3-3 and 3-7. The EIR appears to try and dispense with
this issue by noting that the project would include rolled curbs along the Anacapa Drive right-
of-way to allows waste disposal trucks to move partially outside the paved driveway to avoid
impeding vehicular access. EIR at 4.9-11. First,it is unclear if the sidewalk along the right-of-
way is sufficiently large to accommodate disposal trucks. If not,the parked disposal trucks will
still impede vehicular access along Anacapa Drive, which will jeopardize traffic and pedestrian
safety.
L-18
Moreover, as noted in the Irvine Company's September 29, 2015 letter attached as (Cont.)
Exhibit B, the proposed uses—moving trucks and disposal trucks—are inconsistent with the
easement that dictates the use of the Anacapa Drive right-of-way. According to the Irvine
Company,Anacapa Road is for the exclusive purpose of providing vehicular access to and from
the properties within Block 100 of the NNCPC. Thus,the uses proposed by the project for the
Anacapa Road right-of-way are not only not permitted by the underlying easement, but the
right-of-way's design is not sufficient to accommodate such uses (as it was designed for
vehicular ingress and egress only). The EIR must analyze potential traffic safety impacts
associated with such uses within the right-of-way,and cannot simply rely on the statement that
"vehicular access though the southern access drive" would not be blocked. There is still a
potential for traffic safety impacts associated with vehicles using the Anacapa Drive right-of-
way and forced to maneuver around trucks that are temporarily parked in/blocking the right-of-
way. Also,if such activities cannot be accommodated in the right-of-way,the EIR must analyze
the impacts associated with disposal and moving trucks at another location.
X. The Project Violates a Recorded Declaration
In connection with the Irvine Company's conveyance of the project site in 1992, a
Declaration of Special Land Use Restrictions, Mortgage Lien and Option to Repurchase (the
"Declaration")was recorded in favor the Irvine Company. The Declaration, attached as Exhibit
C, requires all successive owners of the project site to comply with specific covenants,
conditions and restrictions that limit development and uses on the project site, including the
following: L-1 9
• Permitted Uses: Car wash,auto related services(e.g., minor service/repair),and
the incidental sale of gasoline,car accessories and auto-related products.
• Maximum Gross Floor Area: 25,000 square feet
• Height Limitation: Not to exceed height of then-existing building in 1992.
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The proposed project violates each of these express use and development limitations. First,the
project proposes an unpermitted change in use to luxury residential,which is a radical deviation
from the car wash or auto-related service uses that are allowed under the Declaration. In
addition,the project's proposed gross floor area of 163,260 square feet is more than 6.5 times
the Declaration's maximum permitted gross floor area. EIR at 4.2-17. Finally,according to the
EIR,the existing car wash building located on the project site is approximately 12.5 feet high.
EIR at 4.1-21. However, in clear excess of the height of the existing building, the proposed
project consists of a seven-story,75.5 foot high building.
In addition to the use and development restrictions,the Declaration also prohibits the owner of
the project site from pursuing discretionary entitlements, including subdivisions and zone
changes,without the prior approval of the Irvine Company. However,the applicant is pursuing
a broad range of entitlements,including,a General Plan Amendment,Zoning Code Amendment L-19
and Tentative Tract Map,among others,without having provided satisfactory evidence that the (cont.)
Irvine Company has given its approval to these requests. In fact, the Irvine Company's
comments on the MND and the Notice of Preparation suggest that such approval has not been
granted. If that is the case,It would constitute a clear violation of the Declaration.
Although the City is not responsible for enforcing the Declaration, neither can it ignore the
Declaration. Among other things, the Declaration's mandatory provisions fundamentally
change the scope of the project as well as its environmental impacts. The project must be re-
imagined to be consistent with the Declaration's restrictions. The Declaration constitutes
"significant new information" under CECb4 Guidelines Section 15088.5 and therefore the EIR
must be recirculated. Without recirculation, meaningful public review and comment were
precluded (Mountain Lion Coalition v. Fish and Game Com. (1989) 214 Cal.App.3d 1043)) and
the public would be deprived of a meaningful opportunity to comment upon the project's
substantial adverse environmental effects and feasible ways to mitigate or avoid such an effect.
Conclusion: The EIR is wholly insufficient to analyze the impacts of this Project. As stated
above, The City of Newport Beach MUST recirculate the environmental review with the
additional issues above properly studied before attempting to hold any hearings on this
project. Failure to comply with State Environmental Law will subject the City and the
applicant to a legal challenge of the sufficiency of the environmental determination.
Additional comments will be forthcoming if the City insists on holding public hearings without L-20
further study.
Signed on behalf of a Committee of Concerned Residents,
Bob Rush
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Bob Rush—Comment Letter L
L-1:
The City of Newport Beach acknowledges that the commenter submitted prior comments on the
Mitigated Negative Declaration (MND), which the City considered and addressed during the
preparation of the DEIR. Comment letters received by the City on the MND are part of the Project's
administrative record. Comment letters received by the City on the DEIR's Notice of Preparation
(NOP) are included as part of DEIR Technical Appendix A and also are part of the Project's
administrative record.
L-2:
The City of Newport Beach acknowledges the commenter's citation of legal precedent regarding
CEQA. The responses to each of the commenter's specific comments are provided in Responses L-4
through L-20, below. The DEIR does not need to be recirculated based on §15088.5 of the State
CEQA Guidelines. As summarized in the responses provided herein, there were no public comments
or changes to the text or analysis of the DEIR that resulted in the identification of any new significant
environmental effect requiring mitigation. In addition,based on all comments received on the DEIR,
only minor, non-substantive revisions that merely clarify or amplify information presented in the
DEIR were required (as described in the Errata included in the Final EIR). The DEIR circulated for
public review was fundamentally and basically adequate, and all conclusions presented in the DEIR
are supported by evidence provided within the DEIR and/or the administrative record for the
proposed Project. Based on the foregoing, recirculation of the EIR is not warranted according to the
guidance set forth in §15088.5 of the State CEQA Guidelines.
L-3:
Please refer to Response J-5.
L-4:
An FIR is required to include a description of the physical environmental conditions in the vicinity of
the Project site as they exist at the time the Notice of Preparation (NOP) is published (CEQA
Guidelines Section 15125(a)). The City acted reasonably in setting the environmental baseline as the
condition that currently exists and has existed on this site for the past 50+ years. To use a future
baseline of a closed car wash operation would be misleading given that the site has been used as a car
wash for more than half a century and its operations are a long-established existing condition at the
Project site. Further, it would be unlikely that, when the car wash closes, the site would sit vacant
and not be used for some other, yet unknown, temporary purpose allowed by the City's Municipal
Code while it awaits redevelopment. The commenter's assertion that the site would remain
unoccupied when the car wash closes is unfounded. Refer to Response L-2.
L-5:
The DEIR does not imply that customers of the existing on-site car wash will no longer get their cars
washed. The Commenter's assumption is reasonable that customers of the existing car wash will
likely get their cars washed at other car wash locations. However, because there is no data to
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indicate where the existing car wash customers are traveling from (point of origin) to reach the
Project site, or where these customers will choose to get their cars washed once the on-site car wash
is closed, an analysis of trip displacement would be highly speculative and not based on any fact-
based information. Even if it is assumed that all of the existing car wash's customers would use the
nearest car washes to the Project site (near Jamboree and San Joaquin Hills Road, approximately 0.9-
mile to the northwest of the Project site), it cannot be known with any degree of certainty if this
location is actually closer or further from the customer travel trip's origin. Making a reasonable
assumption about car wash customer behavior, based on consumer convenience, it is probable that
people seeking to have their car washed would utilize a car wash location that is most convenient to
them, and predicting which other location would be most convenient to a wide spectrum of
customers would be nothing more than a wild guess. The DEER properly evaluates the Project's
traffic and vehicular-related air pollutant and noise emissions based on a comparison of the Project to
the Project site's existing condition (a car wash with ancillary gas station and convenience market).
The mere fact that the on-site car wash would be removed from the site would eliminate all of the
existing traffic trips traveling to and from the site under the existing condition. Thus, the net trips
(existing car wash trips minus the Project's projected trips) utilized in the analysis is an appropriate
basis for the evaluation of environmental impacts.
L-6:
Please refer to Responses G-2, G-3, and G-4.
L-7:
As disclosed on pages 4.1-12 and 4.1-13 of the DEIR, the City of Newport Beach selected the
locations for the view simulations (Figures 4.1-6 through 4.1-8 of the DEIR) in order to provide
representative views of"the expected appearance of the proposed building from various locational
perspectives that offer a public view" of the Project site. Moreover, the views were selected to
"represent simulated views that would be experienced by a pedestrian looking toward the Project site
in daytime hours at 6 feet above the ground surface." The range of photographs and simulations is
appropriately representative. View 3 (DEIR Figure 4.1-7) is consistent with the City of Newport
Beach's selection criteria because it depicts the view of the Project site from a pedestrian area
adjacent to Newport Center Drive near the intersection with San Miguel Drive. View Simulation—
View 3 depicts the screening of a partial view of the Pacific Ocean that occurs from the
representative viewing location in the existing condition.
Please refer to response G-2. The Project's aesthetic impact as would be seen from public view
corridors, including those that are designated as Coastal View Roads or Public View Corridors in the
Newport Beach General Plan are disclosed throughout DEIR Subsection 4.1.4. The intersection of
Newport Center Drive and San Miguel Drive does not include any roadway segments identified as
designated Coastal View Roads or Public View Corridors. While the photograph supplied by the
commenter depicts a view from an additional location, the conclusions reached by the DEIR remain
accurate based on the significance criteria presented in the DEIR.
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L-8:
Impacts associated with potential glare are discussed thoroughly on pages 4.1-23 through 4.1-26 of
the DEIR. The DEIR discloses on page 4.1-25 that the proposed building would introduce a new
source of glare in the form of the windows, concluding that these new sources of glare would be
similar to other buildings in the surrounding areas. The windows that would be installed on the
building would not include any large expanses of glass, nor would any other highly reflective
building materials be used that would create a source of atypical levels of glare that would support a
conclusion that significant impacts would result from the implementation of the proposed Project.
To ensure that low reflective building materials would be used, the City will include a condition of
approval that will require that the proposed PC Text be revised to require low reflective materials.
L-9:
Please see Response K-14.
L-10:
The short term construction traffic analysis in the DEIR (pages 4.9-7 through 4.9-8) disclosed an
average number of truck trips that would occur based on both demolition and grading phases. For
consistency, the haul trips referenced on 4.9-7 have been updated in the Errata of the final EIR to
reflect 86 haul trips and 172 round-trip haul trips. As disclosed on page 3-9 of the DEIR, 172 round-
trip haul trips would occur during the 30 days of grading. The 172 round-trip haul trips would still
represent a net reduction in the daily vehicular trips when compared to the existing car wash use.
Furthermore, in applying a passenger car equivalent (PCE) factor of 3 passenger vehicles per 4-axle
haul truck (note that Orange County and the Southern California Association of Governments
(SCAG) do not have readily available PCE factor recommendations; as such, the PCE factors used
are based on recommendations from San Bernardino Association of Governments (SANBAG) which
is consistent with standard engineering practice throughout the Southern California region), the 172
round-trip haul trips would be equivalent to 516 passenger vehicles (172 x 3 = 516). Therefore, even
when considering the haul trips after applying PCE factors, the proposed Project's construction
traffic would result in a net reduction compared to the existing vehicular trips generated by the car
wash. Also, see Response L-4.
L-11:
Noise-sensitive land uses, or sensitive receptors, are generally considered to include those uses where
noise exposure could result in health-related risks to individuals, as well as places where individuals
expect quiet to be an essential element of the location. Residential dwellings are considered sensitive
receptors because of the potential for increased and prolonged exposure of individuals to both
interior and exterior noise and potential sleep disruptions. Schools, libraries, heath-care facilities,
nursing homes, retirement residences, and other places where low interior noise levels are essential
are also considered noise-sensitive land uses/sensitive receptors. Quiet noise levels are not an
essential element of outdoor dining on properties surrounding the Project site. Restaurants, as the
commenter points out, are generally not considered sensitive receptors, because the ambient noise
levels are generally higher than land uses like residences, libraries, nursing homes, etc. As stated in
the City of Newport Beach General Plan Noise Element (page 12-7), referenced in DEIR subsection
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4.8.3, restaurants are specifically listed as "Stationary Noise Sources" because of the "high noise
levels that these establishments are able to produce." The presence of outdoor dining does not
change a potential noise source into a sensitive receptor. The DEIR accurately identified the nearest
sensitive receptor as the Newport Center Women's Health Center, located approximately 100 meters
south of the Project site. Also see General Plan Noise Element Table N-2 (Community Noise
Equivalent Level ("CNEL") of 75-80 dBA`normally compatible" for restaurants, vs CNEL of 60-65
dBA`normally compatible" for residential.)
Construction noise is addressed in Section 4.8.5 of the DEIR. Noise would be produced from
construction activity associated with the Project throughout the construction period from demolition
of the gas station through final Project completion. Municipal Code Section 10.26.035 exempts
construction noise from quantified noise standards and impacts associated with short-term
construction noise would be considered significant only if the construction activity violates the
standards contained in Municipal Code Section 10.28.040 (Construction Activity — Noise
Regulations). The DEIR fully discloses that the Project would require certain activities that would
occur outside of the standards contained in Municipal Code Section 10.28.040. Although
construction noise that occurs within the standards specified in Municipal Code Section 10.28.040 is
regarded by the City as a less than significant impact, the DEIR provides additional analysis in order
to indicate that the construction noise from the Project would comply with the Exterior Noise
Standards of the Municipal Code and would not result in harm to human health. See Keep Our
Mountains Quiet v. County of Santa Clara (2015) 236 Cal.App.4th 714. The 90 dBA threshold is
identified for this project in order to establish that the Project will not generate noise in excess of the
noise ordinance. The analysis under Threshold d acknowledges that construction noise would be a
temporary or periodic increase in ambient noise levels in the Project vicinity above levels existing
without the Project. The question is whether that increase is "substantial." As the commenter
pointed out earlier, CEQA gives lead agencies discretion to establish thresholds of significance, and
the City has done so. Accordingly, if construction noise generated by the project were to violate the
noise ordinance, then the increase would be substantial. Out of an abundance of caution, the DEIR
concludes that this is a potentially significant impact (though not anticipated to result in adverse
effects to sensitive receptors) and suggests mitigation measures to address it. See pages 4.8-11 to
4.8-15 of the DEIR.
L-12:
As discussed on pages 4.8-9 through 4.8-10 of the DEIR, the operational noise generated by a
residential building is typically limited to noise "associated with mechanical ventilation/air
conditioning components." Additionally, that the Community Noise Equivalent Level and Allowable
Noise Levels for Residential uses are typically lower in comparison to Commercial (Regional,
Village District, Special, etc.) uses. Due to the Project's distance from any sensitive receptors, and
due to the limited nature of the operational noise that would be generated by a residential building,
the City of Newport Beach determined that a qualitative evaluation of operational noise is sufficient.
L-13:
Please see Response G-1 and G-4.
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L-14:
Water and wastewater facilities are discussed under the topic of Utilities and Service Systems on
page 5-16 of the DEIR, "Effects Found Not to be Significant as Part of the Initial Study Process."
The Project site is served by the City of Newport Beach for water service. The sewer and water
service demand studies that were relied on in the DEIR utilized the Orange County Sanitation
District flow factors based on input provided by the City of Newport Beach Public Works
Department.
The 150 Newport Center Drive project is not subject to SB610 and SB221 requiring a Water Supply
Assessment as it falls short of the 500 dwelling units. Developments of this size must provide
demand calculations from the current and proposed use. The City has design criteria which is used to
compare and approve assessments. Using sewer flows is one way to estimate average usage. The
developer must provide information to assure water connections are of adequate size and provide
sufficient pressure to meet average use, fire suppression and peak demand. Criteria is different
throughout the city due to differing water lines,pressures, and supply.
Using the Urban Water Management Plan(UWMP) GPCD is not the preferred method for estimating
individual development use. UWMP's take the total water agency demand divided by the residential
population to get to GPCD for forecasting citywide use. This takes in account City use, landscaping,
commercial, single and multi-family residential and other use like boat docks, public pools, schools,
and mixed use. The State Department of Water Resources uses GPCD in the SBx7-7 (reduction of
20% by 2020) regulations. As a side note our 2015 UWMP identified a SBx7-7 goal of 228 GPCD
by 2015 and the City's actual use was 176 GPCD. The MESA Water 2015 UWMP plays no part in
estimating demand in Newport Beach.
In summary, the City finds that there is adequate water supply to meet fire suppression and domestic
needs.
L-15:
Pursuant to CEQA Guidelines §15124(b), the DEIR's Project Description includes a list of the
objectives sought by the Project. A Lead Agency has broad discretion to formulate project
objectives. Further, CEQA does not restrict a Lead Agency's discretion to identify and pursue a
particular project designed to meet a particular set of objectives. The list of project objectives is
appropriately based on the underlying purpose of the project. Neither the project's underlying
purpose nor the list of objectives identify the Project site, which allows the consideration of
alternative sites in and around Newport Center. Further, as shown in DEIR Table 6-2, the
consideration of on-site alternatives was not precluded. The No Project/Office Redevelopment
Alternative and the Commercial/Restaurant Redevelopment Alternatives meet 4 of the 11 project
objectives even though those alternatives consider a non-residential use. The Multiple Unit
Residential Alternative meets 8 of the 11 project objectives although 3 are met to a lesser degree.
The Reduced Dwelling Units and Building Height Alternative meets all 11 of the project objectives
although 4 are met to a lesser degree. Thus, the project objectives were not overly narrow and were
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appropriately identified in accordance with CEQA. DEIR Section 6.0 provides meaningful analysis
and promotes informed decision-making by presenting a range of five alternatives.
The City of Newport Beach selected the range of on-site alternatives analyzed in the DEIR from a
wider set of potential alternatives because they were determined by the City to be potentially
feasible, reasonable and realistic, as well as have the potential ability to substantially reduce or avoid
a significant environmental impact of the Project and attain some or most of the Project objectives.
The range of alternatives evaluated in the DEIR includes five potential alternatives that satisfy these
criteria. Although the DEIR is required to describe a range of reasonable alternatives to the Project
or to its location, CEQA does not require that the DEIR discuss every conceivable alternative to the
Project. CEQA does not establish ironclad rules relating to the range of alternatives to be discussed
in an EIR Citizens of Goleta Valley v Board of Supervisors (1990) 52 C3d 553; CEQA Guidelines
§15126.6(a). Instead, the nature and scope of the alternatives to be studied in an EIR is governed by
the rule of reason. See Bay-Delta Programmatic Environmental Impact Report Coordinated
Proceedings (2008) 43 C4th 1143, 1163. Under the rule of reason, an EIR need discuss only those
alternatives necessary to permit a reasoned choice. See CEQA Guidelines §15126.6 and California
Native Plant Society v City of Santa Cruz (2009) 177 CA4th 957. Accordingly, the City of Newport
Beach selected a reasonable range of alternatives that it had determined would provide enough
variation to facilitate informed decision-making and public participation. Moreover, the commenter
does not suggest any additional on-site alternatives or alternative sites that City should have
considered.
L-16:
Regarding the No Project/Commercial Office Alternative and the Commercial/Restaurant
Redevelopment Alternative, the Project Applicant provided information to the City which indicated
that the development with either an 8,500 square foot office building. restaurant, or multiple-unit
(RM) residential project would not be economically feasible after consideration of the cost of
developing the uses, including land acquisition and construction costs. In evaluating the Applicant's
information, the City applied a "prudent person" standard; meaning, that the Applicant's statements
about the economic infeasibility associated with selling or leasing the property as an office building
or restaurant is so great compared to the developing the project site with 49 residential units, that a
reasonably prudent person or property owner would not proceed with a either of the respective
alternatives. See Response J-2 for information related to analysis of the economic feasibility of the
No Project/Commercial Office Alternative, the Commercial/Restaurant Redevelopment Alternative,
and the Multiple Unit Residential (RM) Alternative. Also see Responses I-7 and 0-12.
L-17:
Please see Response J-5.
L-18:
Please see Response H-6. Moving and delivery vehicles would access the site through the main
building entrance off of Anacapa Drive, not utilizing the right-of-way or the south driveway as
described in the DEIR.
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L-19:
Please see Response H-2. The commenter raises issues that represent a civil matter between the
property owner and the Irvine Company. The Declaration of Special Land Use Restrictions restricts
the land use and height of the property for a term of 25 years, expiring on February 20, 2017. The
Project Applicant will not record the tract map or commence construction until this Special Land Use
Restriction has expired, consistent with the proposed construction schedule contemplated in the
DEIR.
L-20:
Responses to the commenter's specific comments regarding the adequacy of the analysis in the DEIR
are provided in Responses to Comments L-1 through L-19. As explained in Response L-2,
recirculation of the DEIR is not warranted according to the guidance set forth in §15088.5 of the
State CEQA Guidelines.
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COMMENT LETTERS
SINDI SCMAVARI7-C01I\IEYI:ti- Lin NEWPORTCE1NPER DRIVE
Sindi R.Schwartz
202 NcwTxtn Center Dmr-'Ilnr Muldoon's Building
Nculxin Beach CA 921160 junc 27,20111
1b:Nlahana Nrna Acsocutte Planner
nxxw•aUnewporibcancca,=
150 Newport Center Drive
Dear Planning Staff,Planning Commission and City Council
My name is Sindi Schwartz.fly husband Ron and I an,owners of the X—fuldoon s Building and
operau-Muldexm's Irish Pub and Celtic-Bar at 202 Ncssport Center Drisr since 1974.
&nh Rem and I hate auendcd sewrtl of the hearings regarding 150 NcwTx)n Center Dnisv Res
idential pmjcct.
'Phis residential project lir people who can alTord condo lining as primary,2nd and 3nl
homes isjust 50 0xt fmm the hustle and bustle of one of Californias award winning pubs and
restaurants.
M-1
As Ron stated at the sandy session on junc 23rd,[)csign Plaza is the 200 Block or Newlmn
Center Dni%r.. 'llnerc am over 100,000 sq.feet of vibrant commercial businesses and pmfessiun-
als in these office buildings and 2 restaurants.one of which is Muldnon'.s Just an car shot fmm
the windows and doors of the prorosed residences at 150 Newpon Center.
Adding a massively tall alio wide residential building for 49 couples%sill muse a terrific strain on
all neighbors,capccialh li>r dnosc nsklcnts ;nslccp in their meds when\luldewni s Ixgins 6cr
morning as early as 0:00 am.
'Ihc applicant's repnscntadws responded to this problem by saying they luxe triple glazed svi n-
elexvs to block out all sound,then added,each resident will haw to sign applicant's disc-losum
swtements saying them will he noise coming fmm restaurants and others.
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SI\UI u'.11\+'ARIZ-C01IMEYI:ti- Liu NEWPOIUCE1NTER DRIVE
1.23 acres vs 10 acres:
Applicant's decision to prohxs. a 163,1100 square loot building on 1.23 arms causes us to re-
sist,and it should,her:msc it is known a building of this rains,bnraddn.++idth and height is cal-
culated to be on it parcel of 10 acres.
M-2
:Vso,s<t backs hath ou Nrugx\n C:rnu•r Dmr and.M:hrapa ++ere cllrulau•d lix'buildings under
50 feet,widt most buildings as Io\v as 32 feet.
Applicani s building is 75 li•et,with 83 fcxa higlu appunenances.
'Ilx•massivr height mill simply overshadow the community of buildings on blocks 100.200 and
3(Kl.
Natural View Corridors:
Attachment 1
If you look at applicants overhead photo-Attachment 1,
}ou will sc a where the\Inldomi s building is set on die corner of NPCD and Anacapa.\f ul-
doon's currently dors have natural view corridors both to the south end of the Car Wash prop-
eny and in the north end un er looking Nmjiort Center Drive. M-3
Attachment 2
If you look at tlx•applicmni s archite•rturd drawing you will sce this massively aide and tall
building blocks\luldcxm's soutlhrdy view mnidor as w•c0 leer nonhedy view,where applicant
has set this giant building only 20 fret from NPCD.Under any ndevalopment,we would wish
to preserve our\icw corridors.
Heights:
'17ne General plan called out dint each block would rise front the Iex+rst slope closer to the oxran
pnigressiv ely rising up as die land changes.'I-he 100 block vvac(-ailed out to he 32 feet in height.
M-4
'I'hc applicant is asking for a variance of an additional 43-plus feet and their response,when
asked,why not 5 stories or 4 stories? Its not economically li•asihle.
2
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COMMENT LETTERS
SI\UI S('.11\t'ARIZ-C01IMEYI:ti- Lin NEWPOIUCENI'ER DRIVE
Applicants n•simnse to the Planning Commission wax emuistent with it's tartie with(.it( �t.dl M-4
claiming any ahernadw plan.other than this one,is not economically feasible.Appanvd}.
applicant's only definition of what is economically feasible is a mum of Slllll milli(m. (Cont.)
Thank trtu lit-your consideration.
Best Regards,
Sindi Sclovanz
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COMMENT LETTERS
VICINITY MAP
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150 Newport Center Drive (PA2014-213)
• General Plan Amendment No. GP2014-003
• Code Amendment No. CA2014-008
• Planned Community Development Plan No. PC2014-004
• Site Development Review No. SD2014-006
• Tentative Tract Map No. NT2015-003, County Tentative Tract Map No. 17915
• Development Agreement No. 2014-002
• Environmental Impact Report No. ER2015-002 (SCH No. 201611032)
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COMMENT LETTERS
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Sindi Schwartz—Comment Letter M
M-1:
Please see Response J-3. Muldoon's and all other uses in the City are subject to Chapter 10.26 of the
City of Newport Beach Municipal Code which regulates noise.
M-Z:
Please see response G-4 regarding aesthetics and G-1 regarding the proposed PC Text. The proposed
Project's potential environmental impacts associated with aesthetics, including impacts related to the
proposed building height, are thoroughly discussed and disclosed in Subsection 4.1 of the DEIR.
The commenter does not identify any specific deficiencies in the environmental analysis.
M-3:
Please see responses G-2 and G-3. Ordinances, plans, policies, and regulations adopted by the lead
agency provide relevant guidance that a lead agency can use to set thresholds of significance in an
EIR. See Mira Mar Mobile Community v City of Oceanside (2004) 119 CA4th 477, which upheld
an EIR's determination that impairment of public views would be significant impact, but impairment
of private views would not, based on policies of city's local coastal program calling for protection of
public views of scenic resources and absence of city ordinances or policies protecting private views.
As stated in EIR Subsection 4.1, the City of Newport Beach General Plan calls for the protection of
public views (refer to General Plan Policies NR 20.1, NR 20.2, and NR 20.3) and the City does not
have any ordinances or policies in place that protect views from privately-owned property. Thus, the
EIR's significance threshold appropriately applies to scenic public views and not private views. The
DEIR concludes that scenic public views would not be significantly and adversely affected by the
proposed Project.
M-4:
This comment addresses statements made by the Project Applicant at a City of Newport Beach
Planning Commission study session. The City of Newport Beach acknowledges the attachments
included in the commenter's letter, which represent an architectural perspective rendering prepared
by the Project Applicant and a vicinity map prepared by the City of Newport Beach. Please also see
Response L-16.
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COMMENT LETTERS
June 19, 2016
Dear Ms. Nova:
The following are comments regarding the Draft EIR for 150 Newport Center Drive:
The use of a Planned Community is inappropriate in this location and does not follow
the criteria established for a Planned Community by Newport Beach. Incorporating the
comments of Dennis Baker:
"Regarding paragraph 3.5.3 PLANNED COMMUNITY DEVELOPMENT PLAN TEXT-
Please explain how this project qualifies as a Planned Community District (PCD)
considering each of the following inconsistencies with the Chapter 20.56 of NB zoning
code. Please include a rationale for considering this project a planned community
development considering the almost total disconnect from the description and intent of
section 20.56 of the city code.
a. 20.56.010
i. Inconsistent with paragraph A -This project
is not a "large-scale community".
ii. Inconsistent with paragraph B - This N-1
"community" of condos does will not contain "diversification of uses".
b. 20.56.020
i. Inconsistent with paragraph A - Project at
1.25 acres is just 12.5% of minimum acreage of 10 acres required for a PCD
C. 20.56.030
i. Inconsistent with paragraph A-1 a—The
"Existing Use" as commercial (car wash) is not"incorporated as part of the approved
development plan".
ii. Inconsistent with paragraph A-1 b— nor will it
be "Allowed to continue"
iii. Inconsistent with paragraph B-1 —This is "A
use, other than a use existing at the time of establishment of a PC District, shall not be
allowed in a PC District except in compliance with a valid PC development plan." This
project fails to qualify for"a valid PC development plan" based on inconsistencies noted
under section 20.56.010 and 20.56.020 above."
The new height limitations asked for by the applicant will set a precedent for other
nearby properties to also ask for exceptions to the height limit and effectively opens up
this section of Newport Center to future height increases that are not now allowed in the N-2
General Plan. For this reason, the height limitation should stay at the currently allowed
32 feet.
The use of required valet services will adversely affect surrounding properties as any
guests who do not wish to relinquish their cars to a valet (I'm one of those people)will N-3
park in adjacent unrestricted parking lots and impact the capacity of those parking lots
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to service the buildings that they were intended to service. This effect has not been N-3
assessed. J (Cont.)
The DEIR uses a 2012 traffic study for the Traffic Phasing Ordinance aspect of the
DEIR. It is inappropriate to use a 4-year-old study for this aspect of the DEIR. CEQA N-4
requires a comparison with conditions that are currently on the ground and a 4-year-old
study does not meet that requirement. A new study is required.
The DEIR uses ITE codes for a high rise condo complex (232) but should more N-5
appropriately use ITE codes for luxury condo complex (233).
The biggest issue with this project is, of course, that the Greenlight limits are exceeded
in its proposed form, thus requiring a vote of the people for final approval of the General
Plan Amendment. Greenlight allows another 100 units over what is allowed in the
General Plan without a vote, but 79 of those units have been used up by the San
Joaquin Plaza development. Although the city claims that they have the legal
justification to have transferred unbuilt hotel rooms to this site as dwelling units, they do
not. The Planned Community text for the Newport North PC clearly states:
"C. Transfer of Development Rights
The transfer of development rights among sub-areas of this Planned Community and
to/from other areas in the Newport Center/Fashion Island District identified in the
General Plan is allowed in accordance with the General Plan.
Development rights may be transferred through a change in location of use(s) and/or a
conversion of non-residential use to any other non-residential use allowed by the
General Plan and this Planned Community Development Plan or applicable zoning at
the receiving site(s). Residential use may be relocated, but may not be converted to N-6
or from another use."
As Planned Community rules supersede zoning laws, a transfer was not allowed even
using the supposed justification of Planning staff. Further, there has been no
amendment to the General Plan to allow anything over 445 dwelling units at San
Joaquin Plaza. Thus, the additional 79 dwelling units that have been built in the San
Joaquin Plaza must be counted against the section 423 limits defined by Greenlight.
This is confirmed by the city's own implementation procedures for Section 423 which
states:
"The City Council shall determine at the noticed public hearing at which any
Amendment is approved if, based on the administrative record for the Amendment
including any testimony presented at that hearing, the Amendment requires voter
approval pursuant to Section 423. The City Council shall submit an Amendment to the
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voters if: ... The Amendment authorizes an increase in the number of dwelling units for
the property or area that is the subject of the Amendment that exceeds one hundred
(100) dwelling units when compared to the General Plan before approval of the
Amendment."
City Planning staff contends that the 79 hotel rooms were"converted in the cloud"
outside of the Planned Community and thus what was transferred were actual dwelling
units. I may be wrong, but I'm pretty sure that"converted in the cloud" is not a legal
term and that any neutral party asked to adjudicate on this issue will prefer to stick to
legal facts rather than magical thinking. The legal facts are that the 79 hotel rooms are
part of an entitlement for the Marriott Hotel (anomaly 43, visitor serving commercial) and
in the General Plan, dwelling units are not allowed at that site. Thus, there is not a legal
way for these unbuilt hotel rooms to have been converted to dwelling units at the site of
the Marriott Hotel without a General Plan Amendment, which was not done. No
General Plan Amendment was done for the San Joaquin Plaza site, as clearly was
required since the current development is in excess of that allowed in the General Plan.
Interestingly, there were 2 addenda to the 2006 General Plan EIR regarding the 79
additional dwelling units being added into San Joaquin Plaza, which implies that this
action was a significant change to the original 2006 EIR that required further CEQA
action. Had this action been fully consistent with the 2006 General Plan in reality, no N-6
additional CEQA document would have been required since there had already been an
EIR for the 2006 General Plan. Transfers of entitlements are common in the North (cont.)
Newport Planned Community and have not, in the past, required further CEQA
documents. Ironically, in addenda #1, Table 1 (replicated below), states in footnote C
that "in no case shall the total number of dwelling units exceed 430" in Block 500 and
600 and the San Joaquin Plaza. EIR addenda #2 states that the transfer of 79 hotel
rooms into dwelling units in San Joaquin Plaza is "consistent with the General Plan"
despite the action increasing the number of dwelling units to well above the General
Plan limit of 430 for the San Joaquin Plaza.
Addendum to City of Newport Beach General Plan 2006 Update EIR
TABLE 1 DEVELOPMENT AREA SUMMARY
Fashion Island Block 500 Block 600(25 San Joaquin
Land Use (75 acres) (15.29 acres) acres) Plaza(23.2 Total
acres)
Regional Commercial 1,619,525 s1, 0 0 0 1,619,525 sf
Movie Theatre 1,700 seats 1,700 seats
(27,500 sf) (27,500 sf)
Hotel (a) (b) 4229 rooms (b) 490 rooms
Residential 0 (c) (cl (C) 430 du
Office/Commercial 0 285,142 sf 1,001,'u34 sf 337,261 sf 11,746,979 sf
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sf: square feet
Ju: dwelling unit
a Botel rooms are permitted in Fashion Island through the transfer of available square footage.
b 65 hotel rooms may be relocated in either Block 500, Block 600, or San Joaquin Plaza. In no
case shall the total
number of hotel rooms in the Fashion Island/Block 500/Block 600/San Joaquin Plaza Planned
-amenity exceed 490. c. Residential units are permitted in Block. 500, Block 600, and San
Joaquin Plaza. In no case shall the total number of
swelling units exceed 430.
2.2.2 TRANSFER OF DEVELOPMENT RIGHTS
The 2006 General Plan also allows a transfer of development rights within Newport Center in accordance
with the following Land Use Element policy:
LU 6.14.3 Transfers of Development Rights
Development rights may be transferred within Newport Center,subject to the approval of the City with
the finding that the transfer is consistent with the General Plan and that the transfer will not result in any
adverse traffic impacts.
Furthermore, the entire General Plan of the City of Newport Beach is inadequate, which N-6
precludes the ability of the city to grant a General Plan Amendment for this project until (cont.)
the General Plan inadequacies are remedied.
Government Code 65302 states that"The land use element shall include a statement of
the standards of population density and building intensity recommended for the various
districts and other territory covered by the plan." The Newport Beach General Plan is
inadequate in this regard in multiple ways including (but not exclusive of) the fact that it
does not adequately reflect the actual development allowed at the San Joaquin Plaza
site, nor the conversion of tennis courts (zoned PR) at the Tennis Club at Newport
Beach Country Club into hotel rooms. It does not assign any development limits at city
owned property such as the Newport Beach City Hall site or Marina Park as it is
required to do.
As the inadequacy of the General Plan clearly affects the ability of the city to approve
the150 Newport Center Drive project under Section 423, it cannot be approved by the
Planning Commission nor the City Council until the General Plan is revised to meet
state required standards.
In your responses to my comments, please specifically address the inadequacies in the
General Plan as described above. Please address the fact that the North Newport
Planned Community supersedes the zoning laws and specifically prohibits a transfer of
non-residential into residential entitlements. Please address the fact that the 79 hotel
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units are entitled to the Marriott Hotel and are not on property that allows dwelling units
and so could not have been converted into dwelling units without a General Plan
Amendment. Please address the fact that the tennis courts were zoned PR and allowed
to be converted into a structure without a General Plan Amendment. Please address N-6
the fact that the city guidelines specify that a General Plan Amendment is compared to
the existing entitlements in the General Plan to determine if the project requires a vote (cont.)
of the people prior to approval. Please address the fact that the General Plan was
substantially changed as evidenced by the need for Addendum 2 to the 2006 General
Plan.
I hereby incorporate by reference the comments of SPON and Jim Mosher.
Additionally, this letter is submitted both as an individual and also as a representative of
Newport 16t (formerly Stop The Dunes Hotel).
Thank you,
N-7
Susan Skinner
2042 Port Provence Place
Newport Beach, CA 92660
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Susan Skinner—Comment Letter N
N-1:
Please see Response G-1
N-2:
Please see Response G-6.
N-3:
As discussed in Subsection 3.3.3 of the DEIR, guests of the proposed residential building would be
required to utilize a mandatory valet service to accommodate guest parking. Valet parking is
optional for residents. The potential refusal by a guest to use the services of the valet is based on pure
speculation. Further, the occasional use of existing, available parking spaces, whether public or
private spaces, is not an impact on the physical environment warranting analysis under CEQA. Any
issues associated with guests utilizing unauthorized off-site parking areas would be a civil matter
between the property owners.
N-4:
The proposed Project does not trigger the provisions of the Traffic Phasing Ordinance because the
Project does not meet the threshold of a net increase of 300 average daily trips (the proposed Project
would result in a net reduction of 614 average daily trips). The prior 2012 TPO study was referenced
in the DEIR; however, a new study was not required in order to sufficiently analyze traffic-related
impacts in the DEIR.
N-5:
Please see Response K-14
N-6:
Please see Response K-9 and G-1.
N-7:
The City of Newport Beach acknowledges the Commenter's incorporation of Jim Mosher's
comments by reference, which were addressed in Response to Comment K-1 through K-17. The City
of Newport Beach acknowledges the Commenter's incorporation of SPON comments by reference,
which were addressed in Response to Comment 0-1 through 0-33.
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COMMENT LETTERS
Hermosa Beach Office Michele Bock
Phone.(3101 798-1400 Em01 y�my
Far (310)7%?402 Chatten-Brown & Carstens LLP mnb@cbcearthlaw.mm
San Diego Ofrca 2200 PaCKiC Coast Highway,Surte 318
Phone:(858)999-0070 Hermosa Beach CA 90254 Direct Phone:
Phone.(619)9404522 www.cbcearthlawxom 310-798-240D Ext 5
June 27,2016
Via Email mnara(anervnorrbencbca.tor
Planning Commission
City of Newport Beach
Makana Nova,AICP,Associate Planner
Community Development Department
Planning Division
City of Newport Beach
100 Civic Center Drive
Newport Beach,CA 92660
Re: Draft Environmental Impact Report for the 150 Newport Center Project;
SCH No.2016011032;General Plan Amendment(GP2014-003);Zoning
Code Amendment(CA2014-0008);Planned Community Development Plan
(PC2014-004);Development Agreement No.2014-002;Site Development
Review(SD2014-006);Tentative Tract Map(2015-003)
Dear Ms.Nova:
These comments are submitted on behalf of Stop Polluting Our Newport(SPON)
regarding the 150 Newport Center Project("Project"). Founded in 1974,SPON is a non-
profit public education organization dedicated to protecting and preserving the residential
and environmental qualities of Newport Beach. The Project would construct 49
condominiums in a single, 163,260-square-foot,seven-story building and three levels of
subterranean parking on 1.26 acres located at the southwest comer of Newport Center
Drive and Anacapa Drive. The Project's 49 units exceed the number of additional units
that may be approved for Newport Center without triggering a Greenlight vote. As 0-1
proposed,the Project would conflict with the General Plan's designation of Regional
Commercial Office,the Zoning Code district designation ofOffice Regional
Commercial,the requirement that a Planned Community Development Plan cover 10
acres,and the existing height limit for the site. Consequently,the Project cannot be built
unless the City grants amendments to the General Plan and the Zoning Code as well as a
waiver of the Planned Community Development Plan requirements. A grant of these
approvals would set a precedent for changing, rather than respecting,the City's
governing land use plans.
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The California Environmental Quality Act(CEQA)serves two basic,inteiTelated
functions:ensuring environmental protection and encouraging governmental
transparency. (Cilizens gfGolcm Valley t'. ltd. af.5'apervisort•(1990)52 Cal.3d 553,
564.) CEQA requires full disclosure of a project's significant environmental effects so
that decision-makers and the public are informed of these consequences before tine
project is approved,to ensure that government officials are held accountable for these
consequences. (Laurel Hel•Ghlx hnprovemew Asx'n aJ.Van rraneisco V. Regents al the
Unimrsity(?fCalifornia(1988)47 Cal.3d 376,392.) The environmental impact report
(HIR)process is the"heart of CEQA"and is the chief mechanism to effectuate its
statutory proposes. (bl Re Raj,-Della l'rrn rmnmanc l>IR Caordhvared Proceetlinyr
(2008)43 Cal.4th 1143, 1162.) SPON is concerned that the drift environmental impact O-2
report("DEIR") fails to adequately disclose,analyze,and mitigate nnany of the Project's
significant adverse environmental innpacts. Instead,the EIR discounts the Project's
potential for significant impacts. The EIR also fails to satisfy its core purpose of
identifying and analyzing feasible alternatives to the Project that would avoid its
significant environmental impacts.
The 150 Newport Center Project fails to comply with the City's governing land
use plans and policies,and the draft EIR fails to properly disclose,analyze,and mitigate
all of the Project's significant adverse environmental effects and the effects of the poor
precedents its approval would establish. SPON respectfully requests that these
deficiencies be corrected and that a revised draft EIR be recirculated.
1. A Planned Community Development Plan is Inappropriate and
Unnecessary for the Project.
The concerns SPON raised in October 2015 about the Project's consistency with
the City's Zoning Code have not been addressed by the Project presented in the DEIR.
Planned Community Development Districts(PCDs)are governed by Newport
Beach Planning and Zoning Code section 20.56.010,and exist to"provide for the
development of land as coordinated,comprehensive projects in order to take advantage of
the superior environment resulting front large-scale community planning." Further,"A 0-3
Planned Community is intended to ... include various types of uses,consistent with the
General Plan through the adoption of a development plan that identifies land use
relationships." Thus,the PCD shouldbe used to ensure consistency with existing land
use plans and to provide cohesive community planning. I-or this reason, PCDs must
exceed 10 acres in size.
The 150 Newport Center Project claims to"ensure substantial compliance with the
spirit and intent of the/_oning Code,"but fails utterly to do so. While a 10-acre or larger
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parcel may require planning flexibility to achieve feasibility and consistency with
surrounding land uses,there is no reason why a 1.26-acre parcel needs to employ the
PCD to provide for a coordinated,comprehensive Project. Instead,the Project appears to
be misusing the PCD designation to skirt regulations of the Newport Beach Municipal
Code intended to provide consistency in land use planning. Although the Project is
located in the southern section of Newport Center,which is governed by height limits of
32 and 37 feet,the Project would be seven stories tall and reach a height of S3 feet,6
inches once rooftop appurtenances are included. Allowing an 83-foot-tall building in the
southern section of Newport Center would create a significant change to the existing
overall plan for Newport Center. Such a large change,which no doubt would become
precedent for future developments in the area,should not be undertaken with a waiver of
the area limits for a PCD.
The Project also fails to fulfill the purpose of the PCD,Zoning Code section
20.56.010,and other zoning laws that require consideration of the relationship of the
proposed development plan to the goals,policies,and actions of the General Plan because
the Project is inconsistentwith the General Plan. The Project proposes a Planned
Community Development District in an"effort to ensure broader coordination and
consistency with the surrounding neighborhoods,and to include a higher level of
architectural quality supporting the Newport Center environment with pedestrian 0-3
connectivity." This language is meaningless, misleading,and misrepresents the Project (cant.)
contained in dte application.
Instead of providing for greater consistency, this Project would be five to six
stories higher than surrounding buildings; it could not be less consistent with its
surroundings. The Project would also completely change(lie appearance of the
neighborhood. In addition to the change in height, the building is much bulkier and
provides for less open space than surrounding parcels. The result is that the Project
would change Ute visual characteristics o1'the area from an area of low-rise commercial
and office space with considerable landscaping and large setbacks to an area more
representative of central city mass,bulk,and height. An example of the change in
building intensity is the Project's proposal for three stories of underground parking and
its inclusion as a project objective. Underground parking has not yet been requested in
the southern, low-rise section of Newport Center because it is not needed under the
existing lower-intensity land uses provided by the City's governing land use plans. If the
City intends to increase the intensity and density of uses in the southern portion of
Newport Center, it can only do so with the adoption of a full-scale General Plan Land
Use Amendment for the southerly portion of Newport Center between Newport Center
Drive and Pacific Coast Highway.
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Granting the Project's application for a PCD for a Project that is up to six stories
higher and much more intense in use than surrounding properties,based on a policy of
ensuring land use consistency,undermines the integrity of the PCD District and the
Newport Beach Zoning Code. The Project's application for a PCD must be denied.
Further,the City cannot make the findings required for approval of a PCD. The
City cannot approve a PCD that would"allow an increase in the height of a structure
above the base height"until it finds:
• The project is providing additional amenities beyond those that are
otherwise required,such as additional landscaped open space, increased
setback and open areas,and enhancement and protection of public views;
• The project is architecturally designed to provide visual interest through the
use of light and shadow,recessed planes, vertical elements,and varied roof
planes;
• The project's increased height will not result in undesirable or abrupt scale
changes;and
• The structure will have no more floor arca than could have been achieved
without approval of the height increase; O_3
(Municipal Code section 20.30.060(C)(3).) Since the Project proposes 49 units on a (cant.)
parcel just over one-acre in size,the Applicant's ability to provide landscaped open space
and setbacks is limited The Project's 83-foot height has the potential to block and
disrupt public views,but not to protect them. If the City were to approve the Project,the
precedent set for future development in the area would harm,not protect,public views.
The City cannot make the first required finding. The City also cannot make the third
Finding,that the Project's increased height will not result in undesirable or abrupt scale
changes. Buildings surrounding the Project site are one-and two-stories in height. The
transition from a single-slory to a 7-story building will be abrupt as no gradual transition
is provided by the Project. Finally,the City cannot make the fourth finding. -1-he Project
proposes 163,260 square feet of development on a 1.26-acre parcel. However,the base
height for the area is only 32 or 37 feet,depending on the selected roof line. The
Applicant could not get 163,200 square feel into a building of this height that otherwise
complies with setback requirements. The City cannot make at least three of the findings
required to grant the requested PCD application.
In order to grant the Project's application for a site plan,the City must find that the
Project(1) is allowed within the subject zoning district; (2)is in compliance with the
applicable criteria of Municipal Code section 20.52.080(C)(2)(c);and(3) is not
detrimental to the harmonious and orderly growth of the City. (DEIR p.4.7-19.) The
Project fails to meet all three requirements. Even if the City were to approve the
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Project's requested zone change to satisfy(lie first requirement,the Project would still
fail to meet the second two requirements. Pursuant to Municipal Code section
2050.080(C)(2)(c),site plan review cannot occur unless the Project complies with the
General Plan and the Zoning Code;the Project has a harmonious relationship with
adjacent developments;the Project is compatible in terms of bulk and scale; and the O-3
Project protects significant views from public rights of way. The Project does not meet
any of these criteria. Finally,the approval of a Project that requires so many deviations (cant.)
from the General Plan and other governing documents would be"detrimental to the
harmonious and orderly growth of the City."
-file Project must be revised before the City may legally consider approval.
IL The Project is Inconsistent with the General Plan's Land Use Element.
'file Project remains inconsistent with the General Plan's Land Use Element,as
well. As discussed in SPON's October 2015 comments,all projects approved in a city
must be consistent with the general plan and its elements. "The general plan is atop the
hierarchy of local government law regulating land use" (Atcighborhund Action Grasp n.
Cowny q%Calaveras(1984) 156 Cal.App.3d 1176, 1183.) For this reason, the General
Plan has been described"the constitution for Future development." (De Vim v. Napa
(1995)9 CalAlh 763,773, internal citations omitted.) The 150 Newport Center Project is
inconsistent with several policies of the City's Land Use Element and cannot be O-4
approved.
Policy LU 6.14.4 of the Land Use Element focuses on reinforcing"the original
design concept for Newport Center by concentrating the greatest building mass and
height in the northeasterly section along San Joaquin Hills Road,where the natural
topography is highest and progressively scaling down building mass and height to follow
the lower elevation toward the southwesterly edge along Pacific Coast Highway."
Instead,the Project proposes constructing a seven-story building in the southeasterly
section of Newport Center. At this site,only a low-rise Project would be consistent with
the City's Land Use Element and General Plan.
Policy LU 1.6 of the Land Use Element requires the City to"Protect and,where
feasible,enhance significant scenic and visual resources that include open space,
mountains,canyons,ridges,ocean,and harbor from public vantage points." Regarding
the Project's 83-foot-plus height,the DEIR claims that the Project's architectural design
is complementary in type, form,scale,and character with existing and proposed O-5
surrounding land uses. This statement relies on the existence of high-rise buildings in the
upper/northerly portion of Newport Center. However,these taller buildings with which
the Project would be consistent are not actually located near the Project. In order to
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protect views consistent with the policies of the Land Use Element,the plans for Newport
Center provide for taller buildings to the north along San Joaquin Hills Road with
gradually decreasing heights toward the ocean and low-rise buildings abutting Pacific
Coast Highway and nearby neighborhoods. The placement of an 83-foot-tall building in O-5
an area of low-rise development would block important public views of scenic resources. (cont.
For example,public views of the Pacific from Fashion Island would be compromised.
Thus,the Project is inconsistent with General Plan policies designed to protect and
enhance such views.
As proposed,the 150 Newport Center Project is inconsistent with at least two
policies of the City's Land Use Element and General Plan. The Project should be revised O-6
to respect the City's constitution for development.
LII. The Project Requires a Vote Pursuant to the Greenlight Initiative.
The City's Greenlight Initiative permits the construction of 100 dwelling units
beyond those contained in the General Plan without a vole. While the Project proposes
only 49 units in Statistical Area LI,79 of the 100 units that could be constricted without
a vote were already constructed in the San Joaquin Plaza development. If(lie Applicant
wishes to proceed without a vote,only 21 units could be developed. The City cannot
circumvent the Greenlight Initiative.
The DEIR defers the analysis of the impact of the Greenlight Initiative on the
Project until future Planning Commission and City Council review of the Project. (DEIR
p.4.7-20.) However, if the Project would be subject to a vote of the electorate, which
could substantially delay the Project,this is information that is appropriate now. Based
on information available to SPON,a maximum of 21 units could be developed without a
vote. O-7
In other arenas,the City has claimed that additional dwelling units above the 100
are permissible without a vote because there are unconstructed hotel rooms at the
Marriot Hotel site. However,residential "dwelling units"and visitor-serving
commercial "hotel rooms"are not the same thing as defined and regulated by the City's
governing documents. In order for the City's claim to have suppon,these hotel rooms
would first neat to be legally converted into dwelling units and then be transferred to
some project site. 'file existing planning documents for these sites prohibit these results.
'file land use planning for the Marriott Hotel site does not permit residential uses,
and while the Newport North Planned Community text governing San Joaquin Plaza
permits the transfer of development rights among sub-areas,"Residential use may be
relocated,but way not be converted to or frow another use." (emphasis added.)
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Therefore,due City mus(rely on its implementation procedures for the Grecnlight
Initiative,which provide that the City Council shall submit an Amendment to the voters
if"[(]he Amendment authorizes an increase in the number of dwelling units for the 0-7
property or area that is the subject of the Amendment that exceeds one hundred(100) (cant.)
dwelling units when compared to the General Plan before approval ofthe Amenrhnent."
The Project would bring the area beyond the 100 units permissible without a vote.
Compliance with the Greenlight Initiative is required.
IV. The Draft Environmental Impact Report Must Be Revised and
Recirculated to Comply with CEQA.
1. The Alternatives Analysis is Inadequate.
CEQA provides,"public agencies should not approve projects as proposed if there
are feasible alternatives or feasible mitigation measures available which would
substantially lessen the significant environmental effects of such projects." (Pub.
Resources Code§21002.) To that end,CEQA requires an EIR to contain an alternatives
analysis that examines feasible alternatives to a proposed project that would"avoid or
substantially lessen"the significant impacts. (Ibid.) The alternatives analysis is the"core
of the EIR."(Citizens oJ'Golern Valley v. Board afSupervisors(1990)52 Cal 3d 553,
564.) CEQA imposes a high standard when a lead agency is proposing to reject an
alternative considered in an EIR."One of[an EIR's] major functions . . . is to ensure that 0-8
all reasonable alternatives to proposed projects are thoroughly assessed by the
responsible official." (Laurel Heights Improvement Assn. v. Regents ofthe Universi0+of
Calif n-nia(1988)47 Cal.3d376,400.) Fltnher,"under CEQA,the public agency bears
the burden of aff irmetively demonstrating that...the agency's approval of the proposed
project followed meaningful consideration of alternatives and mitigation measures."
uu
(Mountain Lion Foundation v.Fish and Game Commission(1997) 16 Cal.4th 105, 134.)
The adoption of a less damaging feasible alternative is(lie equivalent of the adoption of
feasible mitigation measure. (Laurel Heights,supra, 47 Cal.3d at 403.) Such an
alternative or mitigation measure must be adopted by the lead agency unless the lead
agency can demonstrate that the mitigation is"truly infeasible." (01Y ofMorina v. Board
of Trustees of the California.State Univci-shy(2006)39 Cal.4th 341,368.)
The alternatives analysis of this DEIR is constrained by artificially narrow project
objectives. What constitutes a reasonable range of alternatives is determined by the
project objectives. (CEQA Guidelines § 15126.6(a).) As written, in order to satisfy most
of the Project objectives,any alternative studied in the EIR must be a multi-family luxury O_9
condominium tower with maximum lot coverage and underground parking. (DER p.
ES-3.) In fact,5 of the I I project objectives require construction of a residential project.
(Objectives E, F,G, 1.1,J.) Residential use of the site is not currently permitted and
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requires approval of both an amendment to the General Plan land use designation and a
zoning change. However,the objectives presented in the DEIR prevent serious
consideration of a non-residential project alternative. -rhe objectives are impermissibly
narrow in violation of CEQA. (hn Re/any peLa C,bordinared En viravnenral Gnpacr O-9
Repo(proceedings(2008)43 Cal.41h 1143, 1 166["a lead agency may not give a
project's propose an artificially narrow definition"].) The lead agency must exercise its (cont.)
independent judgment on project objectives,and runs(not uncritically accept the
applicant's objectives. (Pub. Resources Code § 21082.1 (c)(1); Uphold Our Heritage v.
'!'oum of Woodside(2007) 147 Cal.AppAth 587; 1 recervaiion Action Council v. Ciq,of
.San Jose(2006) 141 Cal.App.4th 1336, 1352;Save Round Valla,Alliance v. Como,of
Inyo(2007) 157 Cal.App,4th 1437, 1460.)
'file DEIR rejects the No Project/Office Redevelopment Alternative for meeting
only 4 of the Project's unusually specific objectives. (DEIR p. 6-19.) Per the DEIR,the
Office Redevelopment Alternative is an 8,500 square foot office building with surface
parking. The alternative,as designed,automatically Fails to meet the 5 objectives focused
on providing residential uses and the objective of providing underground parking. As
discussed above,the objectives are impermissibly narrow. However,the DEIR also
claims that the Office Redevelopment Alternative could no(meet the objective orbeing 0-10
Financially feasible to constrict and operate(Objective B). (DEIR p. 6-19.) No
justification for this is provided,considering that the Office Redevelopment Alternative is
certainly less expensive to develop than the Project. Additionally, nojustification or
substantial evidence is provided for why this alternative could not be developed with
underground parking to meet objective D. This alternative should be reconfigured as an
alternative that meets all of the Project's non-residential objectives and analyzed in a
recirculated DEIR.
The DEIR improperly rejects the Coru nerrcial/Reslaurant Redevelopment
Alternative for the same reasons—it was designed to fail. Just like the Office
Redevelopment Alternative,this alternative fails to meet the 5 residential objectives,and
just like the Office Redevelopment Alternative,the Commercial Restaurant
Redevelopment Alternative is inexplicably devoid of underground parking(Objective D)
and financially infeasible(Objective B). I'his alternative must be redesigned to meet
these objectives,and the DEIR must be recirculated. This alternative is also designed 0-11
with another flaw—the DEIR admits that it was"developed to the highest traffic-
generating use per existing land use and zoning designations." Unsurprisingly,the DEIR
then concludes that the alternative is not environmentally superior because it would
generate significant,adverse traffic impacts that the Project allegedly would not. (DEIR
p. 6-26.) A DEIR cannot choose to analyze only infeasible alternatives and alternatives
that would have greater impacts than the Project.
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The DEIR's use of only straw men alternatives violates CEQA's requirement that
the alternatives analysis analyze feasible alternatives developed to avoid or reduce a Q-12
Project's environmental impacts. Here,the DEIR analyzes alternatives that are either
designed to be infeasible,designed to have greater environmental impacts,or both.
-file DEIR does not even analyze what seems like the most obvious use of the
property that would conform to current planning and zoning limits—redevelopment of
the existing car wash business. Instead,the DEIR dismisses this viable option as
financially infeasible because other car washes in Newport Beach have recently
renovated. (DEIR p.6-4.) 'file DEIR provides no substantial evidence for the conclusion
that the alternative is financially infeasible just because two other car washes have 0-13
renovated. If anything,renovation of the car wash would help it compete with the other
car washes in the area. The DEIR also claims that the Applicant plans to stop operating
the existing car wash regardless of whether the City approves the Project,but no rational
explanation is provided for why a property owner would stop operating a profitable
business before obtaining the necessary approvals for its next venture.
Also improperly constrained by the Project's impermissibly narrow objectives is
the consideration of off-site alternatives. The Project description slates,"The underlying
purpose of the Project is to redevelop an underutilized property in the Newport Center
area with multi-family, for-sale luxury high-rise(three+stories)residential units located
within walking distance to employment,shopping,entertainment, and recreation."
(DEIR p.3-2.) The DEIR[hen uses the"in the Newport Center area"language in
Objective A to reject the consideration of off-site alternatives. (DEIR p. 6-5.) Yet the
Project seeks several components that are prohibited at the Project site by the City's
governing documents:a height above 32 or 37 feet,residential uses,and large square
footage. The failure of off-site alternatives to be located in Newport Center is not a
sutTicient justification for rejecting off-site alternatives. Alternatives are not required to
meet all project objectives,and in reality it"is virtually a given that the alternatives to a
project will not attain all of the project's objectives." (171aternrnille Pilins Assn r•. C'i(),(?/' 0-14
IVaisonville(2010) 183 Cal.App.4th 1059, 1087.)
The DEIR should evaluate moving the proposed Project off-site. Off-site
alternatives should be considered when"significant effects of the project would be
avoided or lessened by putting the project in another location." (Guidelines
§15126.6(0(2)(A).) The DEIR claims that the analysis of off-site alternatives is
unnecessary because the Project would not have significant environmental impacts.
(DEIR p.6-4.) As discussed below,this conclusion is unsupported. 'file CEQA
Guidelines take a narrow view of what constraints would render an alternative site
infeasible(for example,the lack of extractable resources on a site for a resource
extraction project). (Guidelines §15126,6(0(2)(13).) Furthermore,California Courts have
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endorsed the use of rigorous off site alternatives analyses. (See, for example,Citizens n/'
Golcnu Vallcy v. Hoard of.Saperoisors(1990)52 Cal.3d 553 [upholding EIR in part
because of adequate analysis of an offsite alternative]and.Save Round Palley Alliance r. 0-14
Cwm(v gfln'tV(2007) 157 Cal.App.4th 1437 [EIR found inadequate for failure to assess (cont.)
an offsite alternative that would have reduced impacts].) "the DEIR must be recirculated
with an analysis of off-site alternative locations where the Project could be built without
the adverse land use impacts and harmful precedent that would occur with approval in the
proposed location.
2. The DEIR Fails to Disclose or Mitigate the Project's Adverse
Impacts on Laud Use.
Where a local or regional policy ofgeneral applicability,such as an ordinance, is
adopted in order to avoid or mitigate environmental effects,a conflict with that policy in
itself indicates a potentially significant impact on the environment. (Pocket l'rolectors v.
.Sacramento(2005) 124 Cal.App.4th 903.) Indeed,any inconsistencies between a
proposed project and applicable land use plans must be discussed in an EIR. (CEQA
Guidelines § 15125(d); City of Lung Hcach r. Los Angeles UnifiedSchool District(2009)
176 Cal.App.4th 889,913;Friends of the Ecl River v.Sonoma County Water Agency
(2003) 108 Cal. App.4th 859,874(EIR inadequate when Lead Agency failed to identify
relationship of project to relevant local plans).) A Project's inconsistencies with local
plans and policies constitute significant impacts under CEQA that must be disclosed,
analyzed,and mitigated or avoided_ (Endangered flabnats League,Inc. r. County of
Orange(2005) 131 Cal.App.4th 777. 783-4,32 Cal.Rptr.3d 177;see also, Coouy of Ll
Dorado n. Dept. gf7ransp. (2005) 133 Cal.App.4th 1376(fact that a project may be
consistent with a plan,such as an air plan,does not necessarily mean that it does not have 0-15
significant impacts).)
The DEIR purports to use the correct threshold of significance for detennining
whether an impact on land use is significant. "File threshold adopted by the DEIR is
whether the Project or any component of the Project would"[c]onflict with an applicable
land use plan,policy or regulation of an agency with jurisdiction over the project
(including,but not limited to,the general plan,specific plan, local coastal program,or
zoning ordinance)adopted for the purpose of avoiding or mitigating an environmental
effect." (DEIR p.4.7-4.) Here,the Project conflicts with several policies and
designations of the City's General Plan,as well as its zoning ordinance. (See,e.g., DEIR
p.4.7-10["the proposed Project would be inconsistent with Policy LU 6.14.2'].) Yet the
DEIR fails to deem these impacts significant so that they can be mitigated or eliminated
with redesign of the Project. (DEIR p.4.7-5;See DEIR p.4.7-10["the proposed Project
would be inconsistent with Policy LU 6.14.2, however, no impacts would be significant
and unavoidable".)
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In addition to Policy LU 6.14.2,the Project conflicts with at least three other
policies of the Land Use Element of the General Plan,Policies LU 1.6, LU 3.2 and LU
6.14.4. Instead of properly admitting these inconsistencies and redesigning the Project
for consistency,the DEIR distorts its description of the existing conditions at Newport
Center in order to claim consistency with the General Plan. (DEIR p.4.7-9.) With
regard to General Plan Policy LU 1.6,regarding public views,the DEIR states,"The
Project's architectural design has been designed to be complementary in type, form,
scale,and character with existing and planned surrounding land uses...Accordingly,the 0-16
Project would be consistent with Policy LU 1.6." (/Aid.) The Project is 7 stories tall,as
compared to surrounding uses,which are only one or two stories tall. The Project would
also occupy most of the property,as compared to the much smaller surrounding uses
which feature large setbacks and surface parking. -Thus, the Project is not
"complementary in type,form,or scale." An 83-foot-tall building cannot"protect,
and...enhance significant scenic and visual sources"as mandated by the General Plan.
The DEIR's conclusions with regard to the Project's consistency with General Plan
Policy I.0 1.6 lack substantial evidence.
The DHIR's analysis ofconsislency with other land use policies is similarly
flawed. For example,the DEIR claims that the Project is consistent with General Plan
Policy LU 3.2,which calls for enhancing existing neighborhoods,districts,and corridors
with"uses that are complementary in type,form,scale,and character." (DEIR p.4.7-9.)
The Project conflicts with this policy for the same reasons it conflicts with Policy LU 1.6.
Policy LU 32 also states"Changes in use and/or density/intensity should be considered
only in those areas that are economically undctperfonning,are necessary to
accommodate Newport Beach's share of projected regional population growth, improve O.1
the relationship,and reduce commuting distance between home and jobs..." (DEIR p.
4.7-9.) Newport Center is not underperforming economically,nor is the change in use or
intensity"necessary to accommodate Newport Beach's share of the projected regional
population ynowth." On the contrary,the Initial Study prepared for the Project concluded
that the DEIR did not need to address population impacts because the 5 dwelling units
assigned to the City in the 2014-2021 Regional Housing Needs Assessment would be
established elsewhere. (IS pp.65-66.) This change is unnecessary,and the Project is
inconsistent with General Plan LU 3.2,a significant,unmitigated impact on land use.
The DEIR's analysis of the Project's consistency with General Plan Policy LU
6.14.4 results in a failure of the DEIR to disclose the Project's significant land use
impacts, environmental impacts,and a failure to provide an accurate baseline. An EIR
must accurately describe the existing conditions at the project site in order to provide a 0-18
baseline for environmental analysis. (CEQA Guidelines 15125.) Use of an improper
baseline infects the adequacy of the analysis and violates CEQA.
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In analyzing Policy 6.14.4,pertaining to reinforcing the"original design concept
for Newport Center by concentrating the greatest building mass and height in the
northeasterly section along San Joaquin Hills Road,where the natural topography is
highest,"the DEIR skews the environmental baseline with regard to the heights of
existing buildings. In reality,existing structures near the Project site include office
buildings ranging from 24 to 27 feet in height,situated to the southwest;buildings of 2 to
3 stories buildings located across Anacapa Drive to the cast;buildings of 23 to 25 feet in
height located across Newport Center Drive to the north;and an approved height limit of
50 feet for buildings located in Block 100,although existing buildings are shorter. By
contrast,the DEIR compares the Project to the 16 to 21-story high-rise buildings along 0-18
San Joaquin Hills Road to conclude that the Project would not have a significant impact. (cant.)
(DEIR p.4.7-11.) Specifically,the DEIR states,"Although the Project would result in
the construction of a building that is higher than the immediately surrounding buildings,
the proposed building would be much lower in scale than other developments within the
northeasterly area of the Newport Center Area." (Ibid.) while this may be correct,the
Project would still be ten feeltaller than the tallest mall building across Newport Center
Drive and 50 to 60 feet taller than the surrounding buildings. As a result,the Project
would not be consistent with the Policy 6.14.4 goal of"scaling down building mass and
height to follow the lower elevations toward the southwesterly edge along Pacific Coast
Highway." The Project is inconsistent with the policy,and die DEIR nmst be revised to
reflect this significant environmental impact.
The Project's proposal to use a Planned Community Development District to
provide for changes in zoning that include changes in use and increased height and mass
would have a significant impact on land use that is not disclosed in due DEIR. At 1.26
acres in size, the Project is less than the 10 acres in size required for use ora PCD. The
Project does not satisfy the City's requirements for a waiver of the 10-acre minimum. 0-19
Additionally,the City cannot make the findings required to approve a PCD for a height
increase required by Municipal Code section 20.030.060(C)(3). Therefore,any proposed
use of the waiver and PCD for this Project would create a significant land use impact.
The DEIR does not address whether use of a PCD presents a land use impact.
The Project is also an example of"spot zoning,"wherein zone and land use
changes are applied to a single property. This applicant requests a land use change to a
land use that differs from that provided for surrounding parcels. Spot zoning is
discouraged by the courts because it thwarts comprehensive land use planning. "Case- O-ZO
by-case reconsideration of regional land-use policies, in the context of a project-specific
EIR, is the very antithesis of that goal." (Cilimis(?(Go1Lln Valley v. Hoard of
.S'uperni.eorc(1990)52 Cal.3d 553,572-573.) '["his spot zoning is another significant land
use impact that the DEIR fails to disclose,analyze,and mitigate.
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The EIR is required to analyze the Project's potential for cumulative impacts
related to land use planning in the Newport Center region. As defined by CEQA,"The
cumulative impact from several projects is the change in the environment which results
from the incremental impact of the project when added to other closely related past,
present,and reasonably foreseeable probable future projects. Cumulative impacts can
result from individually minor but collectively significant projects taking place over a
period of time." (CEQA Guidelines§ 15355(b).) The cumulative impacts analysis exists
to prevent cities from considering projects in a vacuum and to avoid a piecemeal
approach to project decision-making. "rhe Court of Appeal has stated than an improper
cumulative impact analysis"avoids analyzing the severity of the problem and allows
approval of projects which,when taken in isolation,appear insignificant but when viewed 0-21
together,appear startling." (Kings Cwuv),Faris Bureau,supra 221 Cal.App.3d at pp.
739-740).
As pointed out by SPON and other commenters during the comment period for
the mitigated negative declaration,this Project sets a precedent for relaxing height
limitations in an area that has been developed with primarily two-story buildings. The
Project would also set a precedent for permitting use of PCDs to avoid existing land use
restrictions for small parcels. The DE1R's failure to analyze the impacts of relaxed
height limits,spot zoning,and increases in bulk,mass,and residential development in the
Newport Center area violates CEQA.
The City's Greenlight Initiative(City Charter section 423)permits the
construction of 100 dwelling units beyond those contained in the General Plan without a
vote. While the Project proposes only 49 units,79 of the 100 units that could be
constructed without a vote were already constructed in the San Joaquin Plaza 0-22
development. Thus,the Project would construct a number of dwelling units in the Project
area that the City lacks the authority to approve. This is a significant impact on land use
that must be eliminated unless the City plans to subject the Project to a vote of its
residents.
A general plan must be integrated and internally consistent both among the
different elements,and within each element. (Government Code §65300.5.) If the
existing general plan is inadequate in any manner relevant to the uses sought by the land
use approval,that land use approval is necessarily void. (Ncig6borhood Action Group n.
County gfCaNcras(1984) 156 Cal.App.3d 1176, 1184, see also Kings County Farm
Bureau v. C-'iry of Har ford(1990)221 Cal.App.3d 692, 741.) "rhe City has claimed that 0-23
these 79 dwelling units were lawfully convened to residential dwelling units and do not
count against the 100 units permitted under the Greenlight Initiative without a public
vote. But even if these land use conversions were authorized and not considered general
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plan amendments,implementing transfers and conversions without amending the general
plan land use tables leads to inconsistencies with and within the City's General Plan.
Thus,the Project would cause a significant impact on land use by contributing to the
disparity between the General Plan land use tables and approved development and by
contributing to internal inconsistencies within the General Plan. As required by
Government Code section 65302,the General Plan's land use element includes standards 0-23
of population density(measured in numbers of persons)and building intensity(using (Cant.)
measures such as site coverage,Floor-to-area ratio,building type and size,or units per
acre). However,these tables have not been updated to reflect changes in use in the
Newport Center area. This has resulted in City approvals that are inconsistent with the
General Plan land use table limits,as well as inconsistencies within the General Plan
itself. The City may not lawfully approve the Project as proposed.
3. The DEIR Ignores the Project's Adverse Impacts on
Aesthetics.
CEQA requires consideration of impacts to public views. (Ocean View h'slnies
Homeowners Assn, Inc. v. Mnntecim Water Dist. (2004) 116 Cal.AppAth 396.) The
Project's height in excess of 83 feet would result in diminished views of the Pacific
Ocean from Fashion Island,as well as likely cumulative impacts as nearby properties
seek to use PCDs and other means to evade height and bulk restrictions in the area.
Despite these potential impacts to public views,which require disclosure,analysis,
and mitigation in an EIR,the DEIR fails toacknowledge that the Project will have any
significant impacts on views. This conclusion is not supported by substantial evidence.
On the contrary,the Project will diminish public and private views Brom Harbor View
neighborhoods situated along MacArthur Blvd.as well as from public roadways.
Members of the public situated in these areas will see lighted buildings and a much taller 0-24
skyline when looking toward the ocean,resulting in obscured ocean views.
In order to protect the City's treasured views,the City of Newport Beach adopted
a Sight Plane Ordinance in 1971 (Ordinance 1371)which provided height limitations for
buildings within the Civic Center sites,known as the"Civic Center Sight Plane." (DEIR
p.4.7-4.) The Corporate Plaza Planned Community,Ordinance 1496,was adopted in
1975 for the Civic Center site,bounded by Pacific Coast Highway,Avocado Avenue,
Farallon Drive(now Civic Center Drive),and Newport Center Drive. Pursuant to this
Sight Plane,buildings within this area are limited to 32 feet in height. The Project site is
immediately adjacent to the Corporate Plaza Planned Community subject to the Sight
Plane Ordinance. (DEIR p.4.7-4.) In addition to providing for inconsistent land use,the
Project's 83-foot-height will also result in impacts to these Sight Planes. The DEIR
denies this,claiming that because the Project is located east of the affected area,it cannot
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violate the Site Plane Ordinance. While this is correct,the Project's increase in height 0-24
will obscure views from the cast westward across the Sight Plane Ordinance arca,a
significant aesthetic(and land use)impact that would violate all of the General Plan (cont.)
policies outlined on pages 4.1-5 and 9 of the DEIR.
-file DEIR compares the Project to the 200 and 300-foot-tall buildings located in
taller portions of Newport Center in order to obscure its inconsistency with the heights of
buildings located near the Project site. (DEIR p.4.1-22.) The height of existing
structures in the vicinity of this Project are:
• Office buildings to the southwest:approximately 24 feet to 27 feet;
• Buildings directly across Anacapa Drive to the east:2-3 stories;
• Buildings located to the north across Newport Center Drive:23-25 feet: 0-25
• Height limits for Block 100 are 50 feet although current buildings are lower.
The DEIR's comparison to the higher-rise buildings located in the northern part of
Newport Center is misleading,at best. The Project is proposed for the southerly section
of Newport Center intentionally planned as low-rise in order to maintain a Sight Plane
consistent with views toward the ocean and surrounding,, neighborhoods. Any
development to the contrary will result in significant adverse impacts on both aesthetics
and land use that were not properly disclosed,analyzed,and mitigated in the DEIR.
As requested by SPON during the NIND comment process,the DEIR provides
view simulations. Unfortunately,these simulations appear to have been chosen to
obscure, rather than disclose,the Project's aesthetic impacts. For example, View I
purports to show the Project's aesthetic impact from Newport Center Drive looking
southeast toward the Project site. (DEIR p.4.1-15.) The DEIR claims that impacts to
public views are less than significant because only a few building floors will be visible
behind vegetation. The specific trees in the view simulation only screen the Project if a
pedestrian is standing in the exact spot. Any substantial movement forward or backward 0-26
along the street will result in the Project dominating southeast views. The image of View
3,purporting to show potential impacts from Newport Center Drive looking southwest,is
too small. A viewer can barely ascertain the landmarks in the image, let alone locate the
Project. (DEIR p.4.1-17.) View 4 is plagued by the same deficiency. The inhage of the
Project's likely impact of views from MacArthur Boulevard is barely one inch tall.
(DEIR p.4.1-18.) If it were possible to enlarge the image further,the Project's impact
would likely seem significant. Larger simulations are needed to provide substantial
evidence that the Project would not have significant impacts.
The DEIR does not provide view simulations from the public open space areas
next to Macy's and the Fashion Island escalators as requested by SPON during the MND 0-27
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comment period This vantage point looks south directly over the existing carwash
toward the ocean and would be dominated by the proposed Project's 33-foot-tower. The
DEIR admits that views of the ocean from Fashion Island might be affected,but claims
that this need not be addressed or mitigated. (DEIR p.4.1-23.) It is unclear why the
DEIR finds that the Fashion Island corridors and parking lot are publicly accessible for
purposes of determining a significant impact but implies that the shopping center itself 0-27
and the open space areas to the south are not. Although on private property,the center is (cont.
publicly accessible,and disclosure of these admittedly significant impacts to public views
is required. "1-his significant aesthetic impact must be disclosed to the public and
mitigated or avoided by redesign of the Project. The recirculated DEIR should also
provide view simulations of the Project's impacts on views from these corridors and
parking lot. View simulations from the bridge over San Miguel Drive near the Civic
Center have also been requested and not provided.
4. The DEIR Fails to Study Potentially Significant Population
and Crowth-Inducing Impacts.
The DEIR did not study the Project's potential for population and growth-inducing
impacts,even(hough City approval of the 150 Newport Center Project would set a
precedent for a change of non-residential uses to high-density housing. This precedent 0-28
could have a potentially significant effect if surrounding property owners seek permits for
similar projects with increased height,bulk, mass and change in use. The initial study's
conclusion that this would not occur lacks substantial evidence. The Project's population
and growth-inducing impacts must be analyzed in a recirculated DEIR.
5. Adverse Cumulative Impacts are Inadequately Analyzed.
Cumulative impact analysis is important because"One of the most important
environmental lessons evident from past experience is that environmental damage ollen
occurs incrementally from a variety of small sources." (Kiggs County Farm Burean v.
CiIP oJHa Jad(1990)221 Cal.App.3d 692, 720.) While the City has included a list of
cumulative projects in the DEIR,this list is limited to those that are foreseeable under the
current zoning and General Plan. (DEIR p.4.7-22.) This analysis omits any discussion
of the precedent-serting nature of this Project,which would permit spot-zoning and use of 0-29
it PCD to evade height and other limitations that would otherwise apply to the Project
site. The Project sets it whole new precedent for heights in the lower Newport Center
area. -file adjacent properties in Block 100 are limited to 50 feet in height but are
currently only 22 feet tall. -file properties immediately adjacent to Block 100 to the south
are currently limited in height by the Sight Plane Ordinance. 'file City's proposed
precedent could result in these height limits being lifted at any time,resulting in
significant new growth,mass,bulk and height inconsistent with surrounding
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neighborhood that has not been analyzed under CEQA or in connection with the City's
Land Use Element or other planning documents. The cumulative impacts analysis is
therefore incomplete,as there is substantial likelihood that the increase in bulk,mass and
heights of the Project will set a precedent for new applications of similar size and impact.
In Scut Franciscans fin-Reasonable Groiwh v. City and County af.San Francisco
(1984) 151 Cal.App.3d 61,the Court of Appeal found that,absent meaningful cumulative
analysis,there would never be any awareness or control over the speed and manner of 0-29
development in downtown San Francisco. In that case,the court found the city's refusal (cant.)
to take into account other similar development projects to be a violation of CEQA. (W. at
634.) "Without that control,`piecemeal development would inevitably cause havoc in
virtually every aspect of the urban environment."' (Kings County limn Bureau v. City of
Hanford(1990)221 Cal.App.3t1692, 720.) Similarly,without adequate cumulative
analysis of the City's disregard for existing height and bulk limitations in Newport
Center,the City will lose control over development of the area. 'file City's conclusion
that the Project has no potential to contribute to cumulatively significant impacts lacks
substantial evidence. (DEIR pp.4.7-22;4.1-26,27.)
6. The DEIR fails to Disclose or Analyze Project Greenhouse
Gas Emissions.
The DEIR fails to analyze the Project's contribution to climate change impacts, in
reliance on the initial study's conclusion that the Project would not emit more than 3,000
metric Ions of carbon dioxide equivalent gases per year. (ES-9, IS p. 52.) There nmsl be
a basis within the record to support the conclusions reached by the initial study.
(Lighihotise Field Beach Rescue n. City gfSanla Cruz(2005) 131 Cal.App.4" 1170,
1201.) -file initial study states that the City relies on the South Coast Air Quality 0-30
Management District's draft screening guidelines,which provide a greenhouse gas
(GFIG)threshold ofsignificance or3,000 metric tons per year. (IS p.52,Appendix E p.
30.) However,these are draft guidelines that have never been adopted and are not yet
enforceable or applicable to the Project. The technical appendix admits this,"Currently,
there are no adopted thresholds for GHG emissions for projects within the SCAQMD
region." (Appendix E,p.29.) This unadopted threshold of significance fails to provide
substantial evidence for the DEIR's failure to analyze the Project's greenhouse gas
emissions. A GHG analysis must be provided in a recirculated DEIR.
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7. Project Mitigation is Inadequate.
The DEIR claims,`after application of all feasible mitigation measures,the
Project would not result in any unavoidable effects." For this statement to be true,the
Project's mitigation measures must be enforceable and 100 percent effective.
Unfortunately,this is not the case.
MM 4.8-1 prohibits construction staging before 7:00 a.m.without the"express
written consent of the Building Official,"but it does not prevent this staging,or its
potentially significant early morning noise, from occurring. The measure also requires
notification of the Granville community before early morning constriction would occur,
which,again,does not prevent adverse noise impacts from early morning construction
activities. The measure states that sound blankets would be used to minimize early
morning noise,but a sound blanket does not eliminate all of the construction that occurs
within. A sound blanket's effectiveness is also limited by the height of the fence upon 0-31
which it is hung,the height of potentially affected receptors,and the open air nature of
construction. Mitigation measure 4.8-1 will not reduce the Project's potentially
significant early morning noise to a level below significance. Such impacts could be
reduced by prohibiting construction staging before 7:00 a.m.altogether.
MM 4.8-2 requires the construction contractor to inspect motorized construction
equipment on a monthly basis to ensure that noise-attenuating InU filers are properly
installed. The measure docs not require that all construction equipment contain noise-
attenuating mufflers,however,so equipment without such mufflers could conceivably be
used. The measure also does not require that mufflers that are found not to be properly
installed be fixed or replaced within an enforceable time frame. These loopholes must be
removed from this mitigation measure for it to be effective and achieve the noise
reductions claimed by the DEIR.
V. The Development Agreement Must Be Made Available.
The DEIR lists the Project's development agreement as part of the project studied
within,but the development agreement has not been released for public review. The
development agreement must be released for public review so that the public and City 0-32
decision makers can ensure that the DEIR has disclosed,analyzed,and mitigated all
aspects of the Project before it is considered for approval.
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Conclusion
Due to the 150 Newport Center Project's failure to comply with the City's
General Plan and other governing land use documents and the DEIR's failure to
adequately disclose,analyze,and mitigate the Project's likely significant impacts on land
use,aesthetics,and other areas of environmental impact,SPON asks the City to revise
and recirculate the DEIR. Compliance with CEQA will require additional analysis of the
Project's direct and cumulative impacts,the development of efficacious mitigation
measures,and the analysis of feasible alternatives that are directed at reducing the
Project's significant impacts while respecting the City's General Plan. The City must
also analyze and disclose the Project's compliance with the Greenlight Initiative,since 0-33
the election requirement will affect further processing of the Project. SPON looks
forward to reviewing the revised DEIR for the Project. Thank you for your consideration
of these comments.
Sincerely,
Michelle N.Black,on behalf of
Stop Polluting Our Newport
cc: Kimberly Brandt AICP,Community Development Director
kbrandVi6 newportbeachca.gov
Brenda Wisneski,Deputy Director,Community Development
bwisneski datcwoortbeachca.gov
Patrick Alford,Planning Program Manager
palford@newportbeachca.gov
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Stop Polluting Our Newport (SPON)—Comment Letter O
O-1:
The City of Newport Beach acknowledges that the commenter provides comments on behalf of Stop
Polluting Our Newport (SPON) as well as the general summary of the comments, which are
addressed individually in Response to Comments 0-3 through 0-33.
O -2:
The City of Newport Beach acknowledges the discussion of CEQA requirements and general
summary of the comments, which are addressed individually in Response to Comments 0-3 through
0-33. As explained in Response I-9, recirculation of the DEIR is not warranted according to the
guidance set forth in §15088.5 of the State CEQA Guidelines.
O -3:
Refer to Response G-1. In determining whether a waiver of the of the minimum acreage
requirements for a planned community was appropriate for the proposed Project, the City determined
that the project represents a component of the greater large-scale planning and vision already set
forth in the General Plan and existing Zoning and Planned Communities in the Newport Center area
as well as a diversification of the existing land uses in the southern portion of Newport Center
allowing for integration of new housing near jobs and services. Moreover, the City determined that
the proposed planned community emphasizes the connection and integration of the residential land
use and its relationship with surrounding commercial development. The commenter notes that
underground parking has not yet been requested in the southern, low-rise section of Newport Center.
However, the property directly to the south, 180 Newport Center, currently provides approximately
119 subterranean parking spaces.
Height limits established as part of an adopted planned community are not subject to the height limits
identified in Subsection 20.30.060 (Height Limits and Exceptions of the Zoning Code). However,
the findings in compliance with subsection (C)(3) (Required Findings) are applicable with a
discretionary action such as the adoption of a Planned Community District. These findings will be
detailed in the Planning Commission staff report and draft resolution.
The City Council's action on the project occurs in an order that would first review the EIR for
compliance with CEQA, then take action on the legislative land use amendments, and finally
consider the discretionary applications including the site development review. Should the City
Council choose to approve the project, this order of actions allows the project to be found consistent
with the General Plan and Zoning Code as amended.
O -4:
Please see Response G-4.
O -5:
Please see Responses G-2, G-3, G-4, and M-3.
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O-6:
Please see Response G-4. The environmental impacts associated with the Project's compliance with
the City of Newport Beach General Plan is thoroughly evaluated in Subsection 4.7 of the DEIR.
O-7:
Please see Response K-9 and N-6.
O-8:
The City of Newport Beach acknowledges the Commenter's citation of legal precedent associated
with the general CEQA requirements for an Alternatives analysis in an EIR.
O-9:
Please see Response L-16.
O-10:
Please see Responses 1-1, L-13 and L-14. Underground parking is excluded in the alternatives
identified because it is not necessary to accommodate the proposed intensity (maximum of 8,500
square feet under the current General Plan) of development on-site and to minimize the
environmental impacts associated with site grading.
O-11:
Please see Responses L-13 and L-14. Underground parking is excluded in the alternatives identified
because it is not necessary to accommodate the proposed intensity (maximum of 8,500 square feet
under the current General Plan) of development on-site and to minimize the environmental impacts
associated with site grading.
O-12:
Please see Response L-14. The City of Newport Beach will consider the adoption of Alternatives
during public hearings for the proposed Project, and the City Council will make specific findings at
that time as to whether or not any of the Alternatives presented in the EIR are feasible, and whether
or not there is substantial evidence to justify the rejection of the Alternative in accordance with
CEQA Guidelines Section 15126.6. Information about the feasibility of Alternatives is contained in
the CEQA findings and not in the DEIR itself.
O-13:
Please see Response to Comments G-5 and 1-1. The DEIR discussed continued use of the site as a
car wash in Subsection 6.2 (Alternatives Considered and Rejected). The rationale as to why the Car
Wash Redevelopment Alternative was not analyzed further is fully disclosed in subsection 6.2.1 of
the DEIR.
O -14:
Please see Response to Comment K-10.
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O-15:
An inconsistency with a General Plan policy or a municipal ordinance is a legal determination, and
not, on its own, a significant impact on the environment. Instead, an inconsistency with a General
Plan policy or municipal ordinance may be evidence of potential significant impacts,just as general
plan policy consistency may be evidence of no significant impacts. This does not mean, however,
that inconsistency with a plan is irrelevant to the analysis. The key is that any inconsistencies be
analyzed in the EIR to determine whether they would result in significant impacts on the
environment. The DEIR fully discloses that the proposed Project would be inconsistent with General
Plan Policy LU 6.14.2 in Table 4.7-2 of the DEIR before concluding that the proposed Project would
not result in significant physical environmental impacts. If approved, the project would become
consistent with General Plan Policy LU6.14.2 because Table LUI of the Land Use Element would be
updated to include the proposed residential units as part of the limited residential development
identified in this policy. Also refer to Response G-1.
O-16:
Please see Responses G-1, G-2, G-4, and 0-15. The commenter is comparing the proposed Project
to only those buildings that are immediately adjacent to the Project site, with too small of a viewshed
to adequately describe the visual impact of the Project when viewed from most public viewing areas
in and around Newport Center. The commenter provides their opinion as to the inconsistency of the
proposed Project with regard to several General Plan Land Use Element policies. However,
comments do not provide substantial evidence that the conclusions in the DEIR's General Plan
consistency analysis is deficient. CEQA's requirement is that "inconsistencies" with general plan
policies and municipal ordinances be analyzed. Where project elements are determined to be
consistent with planning policies, only brief statements to that effect are necessary. See Marin Mon.
Water Dist. v. KG Land Cal. Corp. (1991) 235 Cal.App.3d 1652, 1668 (upholding a brief discussion
of project consistency with local general plan). Also, the ultimate decision on whether a project is
consistent with planning policies is made by the Planning Commission and City Council when
considering project approval.
O-17:
Please see Response J-2.
O-18:
Please see Response G-4 and L-4.
0-19:
Please see Response G-1 and 0-3.
0-20:
Please see Response J-5.
0-21:
Please see Response G-6.
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0-22:
Please see Response K-9 and N-6.
0-23:
Please see Response K-9 and N-6. Transfers of development rights applications do not always
require a General Plan amendment. Changes regarding development rights are tracked separately by
the City of Newport Beach.
0-24:
Please see Response M-3 regarding impacts to views from private properties. Fashion Island is a
privately operated commercial development; therefore, the DEIR properly excluded an analysis of
the potential impacts associated with views of the Pacific Ocean from Fashion Island. Similarly, the
DEIR properly excluded an analysis of the potential impacts associated with views of the Pacific
Ocean from private residential properties, including those along MacArthur Boulevard.
As shown on the map that is included as an attachment to Response G-4, the proposed Project is
located outside of the area subject to the Sight Plane Ordinance. A project cannot be inconsistent
with a municipal ordinance that it is not subject to. Additionally, as shown on the map included as an
attachment to Response G-4, the proposed Project would be located approximately equidistant from
the areas subject to the Sight Plan Ordinance as the 74-foot, 4-inch tall Newport Executive Center
building located at 260 Newport Center Drive, located southeast of the Project site.
0-25:
Please see Response to Comment G-4 and discussion provided in Section 4.5.13 (Population and
Housing) of the Initial Study.
0-26:
Please see Response L-4 regarding the location of view simulations. The size of the view
simulations depict the conditions from each viewpoint that would be available for a pedestrian
viewing the Project site from that viewpoint. Any enlargement of the view simulations would
artificially exaggerate the potential visual impact of the proposed building.
0-27:
Please see Response M-3 regarding impacts to views from private properties. Fashion Island is a
privately operated commercial development; therefore, the DEIR properly excluded an analysis of
the potential impacts associated with views of the Pacific Ocean from Fashion Island. The City of
Newport Beach considered the inclusion of a view simulation from the Fashion Island shopping
center when determining the scope of the EIR. However, as discussed in Response 0-24, Fashion
Island is a private commercial development and the DEIR appropriately excluded analysis of visual
impacts from private properties.
0-28:
Please see Response G-6.
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0-29:
Please see Response G-6. The analysis of cumulative impacts on page 4.7-22 contains, as the
commenter points out, a list of"foreseeable" future projects which may result in related impacts on
the environment. CEQA Guidelines § 15130(b)(1)(A) only requires such a list to contain "past,
present, and probable future projects" when analyzing cumulative impacts. As discussed in
Responses G-6 and G-7, whether a project would be"precedent setting"is purely speculative, and no
credible evidence has been supplied by the commenter to indicate that the Project would
unquestionably induce the redevelopment of other parcels in south Newport Center in ways that
would exceed Municipal Code building height limits. The list of"past, present, and probable future
projects" included in the DEIR is sufficient.
0-30:
30. As noted on page 25 of the Greenhouse Gas Analysis report (Appendix E of the DEIR),
under Senate Bill 97, CEQA Guideline § 15064.4(a) states that "A lead agency shall have discretion
to determine, in the context of a particular project, whether to: (1) Use a model or methodology to
quantify greenhouse gas emissions resulting from a project, and which model or methodology to
use...; or (2) Rely on a qualitative analysis or performance based standards." As such, the City of
Newport Beach has chosen to utilize the SCAQMD recommended tier approach of a 3,000 metric
tons of carbon dioxide equivalent gases per year as a screening level threshold for all land-use types.
Use of this screening threshold is standard industry practice for many CEQA lead agencies in the
South Coast Air Basin, and is consistent with past practice of the City of Newport Beach. For
example, the following projects have utilized the 3,000 metric ton threshold: 191 Riverside Land Use
and Zoning Amendments, Back Bay Landing, Balboa Marina West Landside, Birch Medical Office
Addendum, Ebb Tide Project, General Plan Land Use Element Update, Lido House Hotel, Lido
Villas, Little Corona Infiltration, The Residences at Newport Place, Uptown Newport, etc. Because
the Project would generate greenhouse gas (GHG) emissions calculated at 704.33 metric tons of
carbon dioxide equivalent (MTCO2e) per year (Urban Crossroads, 2016b p. 33), well below the
SCAQMD draft screening level threshold of 3,000 MTCO2e, the EIR found that the proposed project
would result in less-than-significant impacts to GHG emissions. The emissions related to the Project
also would not conflict with Statewide implementation of, and realization of, the goals set forth in
AB 32. Emissions, moreover, would continue to be reduced on a statewide level through
implementation of cap-and-trade.
0-31:
The DEIR identified that construction noise is "not anticipated to result in adverse effects to sensitive
receptors"but determined that"in an abundance of caution this impact [staging activities between the
hours of 6 a.m. and 7 a.m. associated with foundation construction] is regarded as a potentially
significant impact' (page 4.8-9 of the DEIR). Page 4.8-8 of the DEIR indicates that, "Activities
authorized in writing by the Building Official outside of the normally permitted construction hours
must comply with the Exterior Noise Standards of the Municipal Code." The proposed construction
staging activities are not anticipated to result in noise levels that would exceed any threshold of
significance established by the City associated with construction noise. Instead, the "potentially
significant impact' determination was made, and mitigation measures identified, merely to further
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ensure that adverse effects associated with these construction staging activities would be minimized.
A prohibition on construction staging prior to 7 a.m. would restrict the implementation of an essential
component of the proposed Project that is necessary in order to properly construct the building
foundation. Mitigation Measures MM 4.8-1 and 4.8-2 were identified to reduce any potential noise
impacts associated with the limited construction activity (construction vehicle staging) that would
occur prior to 7 a.m. Furthermore, even without the implementation of Mitigation Measures MM
4.8-1 and 4.8-2, the DEIR disclosed that no adverse effects to sensitive receptors would occur
associated with the early morning construction staging activities.
0-32:
The terms of the development agreement will be provided as part of the Planning Commission staff
report. There are no terms that would create a potential impact to the environment beyond those
disclosed in the DEIR.
0-33:
The responses to each of the Commenter's specific comments are provided in Responses 0-1
through 0-32. As explained in Response I-9, recirculation of the DEIR is not warranted according to
the guidance set forth in §15073.5 of the State CEQA Guidelines.
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150 Newport
i
SimulationView
•View w x,.vim_
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COMMENT LETTERS
Debbie Stevens
1120 Sea Lane
Corona Del Mar, CA 92625
June 27,2016
Makana Nova
City of Newport Beach Planning Division
100 Civic Center Drive
Newport Beach,CA 92660
Subject: Comments on Newport Center Villas Residential/150 Newport Center Project Draft
Environmental Impact Report
Dear Ms.Nova:
As a resident of Newport Beach, I appreciate the opportunity to provide comments on the Newport
Center Villas Residential Project Draft Environmental Impact Report (DEIR). I have reviewed the DEIR
and have the following comments.
Aesthetics
1. Section 4.1 Aesthetics, page 4.1-2. The DEIR indicates that "Public views of the Pacific Ocean
within the Newport Center area are limited to views along Newport Center Drive . . .' As
indicated in my letter on the Mitigated Negative Declaration (MND), there are views from a
number of other public areas within Fashion Island. A view simulation from the public park
next to Macy's (and the escalators) in Fashion Island should also be provided. The public view
south from this outlook is towards the ocean and directly over the existing carwash and the
project impacts on this view would be dominated by the proposed project and,thus,significant.
A view simulation from this vantage point is attached to this letter with both existing views P_1
(Figure 1) and the view with the Project (Figure 2). The view simulations clearly show that the
height and mass of the building is much greater than any other surrounding building. The
aesthetic impacts associated with the proposed project are significant. The only reason to not
include a simulation from this viewpoint is to further the opinion stated in the DEIR that there
are no significant impacts on scenic vista. The attached simulation provides clear evidence that
the aesthetic impacts are substantial and significant. Please note the park in Fashion Island can
be accessed 24/7 and the site is never closed to the public. It is very common for visitors to
Fashion Island to visit this park and take pictures because it is one of the most scenic portions of
Fashion Island available to the public. Further, the significance criteria used in the DEIR states,
"Would the Project have a substantial adverse effect on a scenic vista." (DEIR page 4.1-10.) The
significance threshold does not ask the question would there be a substantial adverse effect on
a scenic vista on public property only? Neither does the CEQA Checklist (Appendix G) ask if
there are only impacts on views from public property. Rather the CEQA Checklist asks if the
project would have a substantial adverse effect on a scenic vista, with no distinction as to the
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COMMENT LETTERS
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ownership of the property. Therefore, the DEIR must be revised to acknowledge the project'sP 1
potentially significant aesthetic impacts, feasible mitigation measures are required, and
(cont.)
alternatives to minimize those impacts are required, including low-rise development consistent
with the site's surroundings.
2. The view simulations provided in the DEIR are the same ones used in the MND and, as indicated
in my comments on the MND, are not accurate with respect to height. View Simulation 2 (page
4.1-16) shows the 83 foot building at the same height as the existing palm trees. The existing
palm trees are about 40-50 feet in height. Therefore, the building would be approximately 30 P-2
feet HIGHER than the existing palm trees and much larger than shown in the view simulations.
The view simulations must be revised to be accurate. Further, the view simulations appear to
have been chosen to minimize the appearance of the Project as opposed to providing full
disclosure of the Project's visual impacts.
3. Page 4.1-20 through 4.1-23. The DEIR's conclusion that the Project would not substantially
degrade the existing visual character of the site is incorrect. The potential views of the Project
from Fashion Island are written off by indicating that "any such views from the Fashion Island
shopping center that would be affected by the Project occur within private property and as
such, the Project would not substantially affect scenic views from viewing locations on public
property." (DEIR pages 4.1-22 and 4.1-23.) The significance criteria asks, "Would the Project
substantially degrade the existing visual character or quality of the site and its surroundings?"
The significance threshold does not ask if the Project would substantially degrade the existing P-3
visual character of the site as viewed from public property only. In fact, the significance criteria
includes the "site and its surroundings"with no distinction between public or private properties.
Neither does the CEQA Checklist(Appendix G)ask if there are only impacts on views from public
properties. Rather the CEQA Checklist also asks if the project would "Substantially degrade the
existing visual character or quality of the site and its surroundings." Therefore, the DEIR must
be revised to acknowledge the project's potentially significant aesthetic impacts and feasible
mitigation measures are required.
4. The cumulative aesthetic impacts associated with the proposed project and other past, present
and reasonably foreseeable future projects have not been addressed. Approval of the proposed
project would set a precedent for taller buildings south of Newport Center Drive,an activity that
P-4
has been discouraged by the General Plan and various land use policies. The DEIR must address
the potential cumulative aesthetic impacts associated with higher structure developments south
of Newport Center Drive from both public and private views.
Air Quality
I provided comments on the air quality section on the MND for this project. Some of the issues that I
raised have been corrected and yet the air quality analysis still has errors.
P-5
1. The DEIR indicates that there are 3 levels of subterranean parking (DEIR page 3-6). The DEIR
indicates that there will be "Demolition, Grading, and Excavation" (DEIR page 3-9 and 3-10)and
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COMMENT LETTERS
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Page 3
estimates about 51,600 cubic yards of excavation will be required and will be completed within
30 days(DEIR page 3-9). Yet in the estimates of construction equipment usage (and the related
air emission calculations), it is assumed that no excavators or scrapers will be used. That is an
average of 1,720 yd3 per day. It is unlikely a single excavator move that much material each day P-5
without having to stockpiling. CalEEMOd does not include fugitive emissions from stockpiles, (cont.)
fugitive dust emission from stockpiling must be added to the construction emission estimates.
Furthermore, shoring will be required for the depth of the parking garage. The delays due to
shoring would require a second excavator in order to move 1,720 yd3 per day for 30 days.
Therefore, the air quality analysis underestimates the emissions associated with the
construction of the proposed project. These issues roll down into the LST and GHG analysis.
2. Emission estimates for the Project do not include any estimates for the import of cement.
Clearly, cement trucks will be required, as indicated on page 3-13 of the DEIR, and theirP-6
emissions must be included in the construction emission estimates.
3. Emission estimates for the construction of the Project assumes that a maximum of one crane
will be in operation. Considering that the structure will be 83 feet tall, it seems unlikely that
only one crane would be sufficient for construction activities. The SCAQMD thresholds are P-7
based on peak day operations. The air quality analysis must include the peak day emission
estimates and those have not been included in the DEIR
4. The Local Significance Threshold (LST) analysis assumes 100 meters to the closest sensitive
receptor (see Appendix C, page 28 and page 4.2-21 of the DEIR). Page 4.2-28 of the DEIR
indicates that the closest sensitive receptor is about 100 yards from the Project. So the DEIR is
inconsistent on the location of the closest sensitive receptor. Based on review of the site and its
distance to the Newport Center Women's Health Center (the closest sensitive receptor), the P-g
closest sensitive receptor is about 50 meters away from construction activities associated with
the Project (see attached Figure 3). Therefore, the LST analysis as presented in Table 4.2-8 is
incorrect as the SCAQMD Localized Thresholds used in the table are for a receptor 100 meters
away instead of 50 meters away. Table 4.2-8 must be revised to evaluate the emissions at the
closest sensitive receptor,which is 50 meters away.
S. The DEIR relied upon the Greenhouse Gas(GHG)analysis prepared in the MND. GHG emissions
were included in the MND and were based on an incorrect "Floor Surface Area" used in
CaIEEMod, which I pointed out in my comments on the MND. The gross floor area of the
proposed project is 163,260 square feet. The surface area used in the CalEEMod analysis in the P-9
MND was 50,400 square feet. Further, the construction GHG emissions need to be revised to
include all sources of emissions (e.g., excavators). The GHG emissions need to be revised and
updated using correct assumptions.
Land Use
1. Policy LU 1.6 requires the protection of public views. The project would not comply with this P-10
policy as public views of the ocean from Fashion Island would not be protected. Land use
impacts remain significant,must be mitigated,and appropriate alternatives must be provided.
2. DEIR 4.7-10 and 4.7-11, Land Use Policy LU 6.14.4— Development Scale. This policy reinforces
the original design concept for Newport Center by concentrating the greatest building mass and
height in the northeasterly section along San Joaquin Hills Road, where the natural topography P_11
is highest and progressively scaling down the building mass and height to follow the lower
elevations toward the southwesterly edge along Pacific Coast Highway. The Project clearly
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conflicts with Policy LU 6.14.4 regarding development scale, as it would be a maximum of 83
feet while buildings that surround the project are in the 2-3 story range (see attached figure).
The CEQA checklist asks if the project would "Conflict with any applicable land use plan, policy, P-1 1
or regulation of any agency with jurisdiction over the project . . . adopted for the purpose of (cont.)
avoiding or mitigating an environmental effect?" As discussed above, the Project would clearly
conflict with Policy LU 6.14.4; therefore, land use impacts are significant, all feasible mitigation
measures are required, and an adequate alternatives analysis is required.
3. DEIR, pages 4.7-10 and 4.7-11. The height of the buildings adjacent to the Project is about 32
feet. The proposed project would be 83 feet tall which is substantially greater than the height of
the existing structures. Comparing the Project to office buildings (up to 21 stories) on the
northeasterly portion of Newport Center is totally inappropriate and attempts to diminish the P-1 2
significance of the land use impacts. The Project would be over 50 feet higher than the
surrounding buildings and this would be a significant impact. The Project would set a new and
unacceptable precedent for building heights in the lower portions of Newport Center.
4. Page 4.7-21 through 4.7-22. For the reasons stated above, cumulative land use impacts are
significant as well and must be evaluated in an EIR. The approval of this Project as well as other
projects in Newport Center, e.g., the Museum House would result in additional development
south of Newport Center Drive. These Projects would conflict with the original design concept
for Newport Center of concentrating the greatest building mass and height in the northeasterly P-13
section along San Joaquin Hills Road, where the natural topography is highest and progressively
scaling down the building mass and height to follow the lower elevations toward the
southwesterly edge along Pacific Coast Highway. The cumulative land use impacts are
significant and appropriate mitigation is required,as well as reasonable alternatives.
Alternatives
1. DEIR page 6-6. The DEIR lists numerous objectives of the proposed project and then indicates
that most of the alternatives will not meet the objectives. Objectives should be written from
the lead agencies perspective and not from the developer's perspective. Objectives B, D, F, G,1, P-14
and K are objectives that appear to be solely to satisfy the applicant in this case. Repurposing
the site for a "higher and better use than currently occurs on the property' is a very arbitrary
objective and based on personal opinion and is not appropriate as a project objective.
2. DEIR Section 6.0. The DEIR concludes that the No Project/Office Redevelopment Alternative,
the Commercial/Restaurant Redevelopment Alternative, the Multiple Unit Residential
Alternative, and the Reduced Dwelling Units and Building Height Alternative would not be p_15
financially feasible. Yet the DEIR provides no information or justification for this conclusion.
Substantial evidence regarding the financial feasibility of the Project and all of its alternatives
are required in order for the DEIR to conclude that alternatives are not financially feasible.
3. DEIR page 6-4. As discussed above, the DEIR has significant land use and aesthetic impacts.
Alternatives to minimize these impacts are required, including alternative sites, where General P-16
Plan and zoning amendments would not be required.
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COMMENT LETTERS
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Growth Inducing Impacts
The DEIR fails to analyze the potential for growth-inducing impacts as required under CECIA Guidelines
15126. As discussed above,the Project would set a precedent by allowing high rise development south
of Newport Center Drive. This precedent would allow other property owners the ability to convert their P-1 7
existing"underutilized"properties into a "higher and better use than currently occurs on the property,"
e.g., high rise development. This is a potentially significant growth-inducing impact that must be
evaluated in the EIR.
I appreciate the City's decision to prepare a DEIR for the Newport Villa/150 Newport Center Project.
Due to the EIR's failure to adequately disclose,analyze,and mitigate the Project's significant impacts on
land use,aesthetics,air quality,cumulative impacts,and growth inducing impacts,the City is required to
revise and recirculate the DEIR.
Respectfully submitted,
��lXi(Q } P-18
xfKY Z_
Debra Bright Stevens
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FIGURE 1: EXISTING VIEW FROM PARK NEXT TO MACY'S
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FIGURE 2: VIEW WITH THE DEVELOPMENT OF NEWPORT VILLAS
IF
Lead
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FIGURE 3: DISTANCE FROM PROJECT TO SENSITIVE RECEPTOR
T
S A 1
�M 1
•1
I Meaaum Eotance
Total distance,13-
H
I°
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Debbie Stevens—Comment Letter P
P-1:
Please see Responses M-3. Fashion Island does not contain any public parks. As with any shopping
center, Fashion Island is open to the public, but the area referenced by the commenter consists of a
landscaped portion of a privately operated commercial development. The City of Newport Beach
acknowledges the attached photograph(Figure 1) showing the existing view from Fashion Island and
the view simulation(Figure 2) that was prepared by the commenter from the same location. Figure 2
distorts the proposed height of the project since it depicts the first level from the tree line and not
from existing grade, which occurs at a level lower than the street level along Newport Center Drive.
P-2:
View Simulation 2 (Figure 4.1-6 of the DEIR) shows a visual simulation of the proposed Project
from a viewpoint at the northwest comer of Anacapa Drive and Newport Center Drive, looking
south/southwest toward the Project site. The palm trees that the commenter references are located
along Newport Center Drive, while the building is shown set back from the roadway and the palm
trees. The pahn trees measure approximately 62 to 65 feet in height and the additional grade
differential between Newport Center and the finished floor elevation (approximately 3 feet) help
account for the lower appearance of the project as depicted in the visual simulation. As the palm
trees would be nearer to the viewing location, their height would appear to be taller than a more
distant object that is taller, such as the proposed building. The roofline of the more distant proposed
residential building is shown projecting over the palm trees, so that a reasonable viewer considering
the relationship between the location of the palm trees (in the foreground) and the residential building
(in the background) would conclude that the building is noticeably taller than the palm trees. The
roof parapet depicted occurs at 77 feet 6 inches in height and mechanical appurtenances such as the
elevator override are stepped back from the main building footprint, casting them out of view from
the street level. Accordingly, the building is clearly shown as being taller than the palm trees that are
in the foreground, and View Simulation 2 accurately discloses the potential visual impact of the
proposed Project. Please see Response L-7 regarding the selection of the view simulation locations.
P-3:
hi accordance with the CEQA Guidelines, the DEIR analyzed potential aesthetic impact thresholds
separately. See CEQA Guidelines, Appendix G. As these potential impact thresholds involve
different aspects of the Project and its surroundings, it is logical to approach their analysis in
different ways. Accordingly, for the purposes of threshold c, no public/private property distinctions
were drawn because they would not have been appropriate. Rather, the visual design and build
aspects of propose project were analyzed to see if the Project would "substantially degrade the
existing visual character or quality of the site and its surroundings."Under threshold a, the question
asked is "would the Project have a substantial adverse effect on a scenic vista?" Which lead to a
completely different analysis. Please see Response M-3.
P-4:
Please see Response G-6 and 0-29.
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P-5:
Refer to Response I-6. The equipment list presented in the report (such as graders, rubber tired
dozers, and tractors/loaders/backhoes) are capable of moving the required amount of soil. It is with
this understanding that the grader, rubber tired dozer, and tractor/loader/backhoe in the grading phase
of construction will be moving 51,600 cubic yards of soil. Furthermore, no significant stockpiling
during grading is anticipated and any potential stockpiling would be subject to SCAQMD Rule 403
requirements to limit any fugitive dust. Notwithstanding, even if two excavators were added to each
phase of construction, there would be no substantive changes to the construction, LSTs, and GHG
analysis that would alter the findings of the Air Quality and Greenhouse Gas reports appended to the
DEIR. As shown in the tables below, even if two excavators were added to each phase of
construction along with all other construction equipment identified in in Section 3 of the DEIR,
impacts associated with air quality would be less than significant.
TABLE 1:EMISSIONS SUMMARY OF OVERALL CONSTRUCTION WITH THE ADDITION OF
A SECOND EXCAVATOR
Year Emissions (pounds per day)
VOC NOx CO Sox PM10 PM2.5
2016 7.02 91.28 70.58 0.18 11.47 5.89
2017 4.32 31.07 29.72 0.05 2.99 1.95
2018 62.07 27.28 28.58 0.05 3.06 1.79
Maximum Daily 62.07 91.28 70.58 0.18 11.47 5.89
Emissions
SCAQMD
Regional 75 100 550 150 150 55
Threshold
Threshold NO NO NO NO NO NO
Exceeded?
TABLE 2:LOCALIZED EMISSIONS SUMMARY OF OVERALL CONSTRUCTION-SITE
PREPARATION WITH THE ADDITION OF A SECOND EXCAVATOR
On-Site Site Preparation Emissions (pounds per day)
Emissions NO, CO PM10 PM2s
Maximum Daily Emissions 34.68 34.68 7.64 4.64
SCAQMD Localized
Threshold 108 1,090 27 9
Threshold Exceeded? NO NO NO NO
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TABLE 3:LOCALIZED EMISSIONS SUMMARY OF OVERALL CONSTRUCTION-GRADING
WITH THE ADDITION OF A SECOND EXCAVATOR
Emissions (pounds per day)
On-Site Grading Emissions NO. CO PM10 PM2s
Maximum Daily Emissions 29.94 20.56 6.69 4.01
SCAQMD Localized
Threshold 108 1,090 27 9
Threshold Exceeded? NO NO NO NO
TABLE 4: TOTAL PROJECT GHG EMISSIONS(ANNUAL)WITH THE
ADDITION OF A SECOND EXCAVATOR
Emissions (metric tans per year)
Emission Source CO2 CH4 N20 Total CO2E
Annual construction- 43.09 6.42e-3 43.23
related emissions
amortized over 30 years
Area a 16.04 0.02 3.50e-4 16.49
Energy b 359.05 0.02 3.78E-3 360.54
Mobile Sources' 262.41 9.87e-3 262.62
Waste 4.58 0.27 -- 10.25
Water Usage 19.31 0.10 2.63e-3 22.33
Total CO2E (All 715.46
Sources)
SCAQMD Threshold 3,000 MTCO2E
Threshold Exceeded? NO
Furthermore, if the analysis replaced the use of graders with excavators (since graders were modeled
in lieu of excavators to be more conservative because graders emit more pollutants), then
construction emissions would be less than what is disclosed in the DEIR. This is due to the fact that
graders have a higher horsepower than excavators (174 vs. 162 HP, respectively) and would
therefore emit a greater amount of emissions. As such, the analysis in the DEIR and the supporting
Air Quality and Greenhouse Gas technical studies represents a conservative estimate of emissions.
Detailed model outputs associated with this analysis is presented as an attachment on the following
pages.
This additional information does not constitute "significant new information" requiring recirculation
of the DEIR under CEQA Guideline §15008.5, because the Lead Agency has not disclosed a new
significant environmental impact that would result from the Project; but, merely has amplified
information that was already reported in the in the DEIR by providing supplemental calculations to
show how the use of a different mix of construction equipment during the grading phase would still
result in less-than-significant impacts.
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P-6:
Trips associated with the import of cement were accounted for under the vendor trips of the traffic
analysis. According to the Project Applicant, the Project would require approximately 16,000 cubic
yards of cement. CalEEMod assumes that a truck load can carry approximately 16 cubic yards of
material. As such, the Project would require approximately 1,000 truckloads of cement, which
equates to approximately 2,000 two-way truck trips. The building phase of construction is
anticipated to last approximately 400 days. Therefore, the import of cement would require
approximately 5 two-way vendor truck trips per day. The Air Quality and Greenhouse Gas analyses
presented in the DEIR analyzed 27 two-way vendor truck trips per day (which includes cement
trucks and other types of delivery trucks), which is substantially greater than the 5 two-way vendor
truck trips required.
P-7:
As indicated on Table 3-2 of the DEIR(Page 3-12), the construction of the Project would require the
use of one crane,which was included in the modeling for the air quality analysis.
P-8:
The preparer of the Air Quality Impact Analysis (see Appendix C of the DEIR) determined that the
Newport Women's Health Center is 100 meters away from the proposed Project. Notwithstanding,
and for the purpose of providing a conservative evaluation of the potential for air quality impacts,
information is provided below that assumes a sensitive receptor 50 meters away (as shown in Tables
5 and 6 below). Based on the information provided below, even if a sensitive receptor occurred 50
meters from the Project site, less-than-significant air quality impacts would occur and the
conclusions of the DEIR would not change.
TABLE 5:LOCALIZED EMISSIONS SUMMARY OF OVERALL CONSTRUCTION-SITE
PREPARATION ASSUMING A SENSITIVE RECEPTOR IS 50 METERS FROM THE PROJECT SITE
On-Site Site Preparation Emissions (pounds per day)
Emissions NO, CO PM10 PM2.5
Maximum Daily Emissions 34.68 34.68 7.64 4.64
SCAQMD Localized
Threshold 93 738 13 5
Threshold Exceeded? NO NO NO NO
TABLE 6:LOCALIZED EMISSIONS SUMMARY OF OVERALL CONSTRUCTION-GRADING
Emissions (pounds per day)
On-Site Grading Emissions NO,
CO PMIo PM2s
Maximum Daily Emissions 29.94 20.56 6.69 4.01
SCAQMD Localized
Threshold 93 738 13 5
Threshold Exceeded? NO NO NO NO
Lead Agency: City of Newport Beach SCH No. 2016011032
Page FEIR-137
�0�
■■ 150 NEWPORT CENTER
■� ENVIRONMENTAL IMPACT REPORT F.0 FINAL ENVIRONMENTAL IMPACT REPORT
This additional information does not constitute "significant new information" requiring recirculation
of the DEIR under CEQA Guideline §15008.5, because the Lead Agency has not disclosed a new
significant environmental impact that would result from the Project; but, merely has amplified
information that was already reported in the in the DEIR by providing supplemental calculations to
show that a sensitive receptor located 50 meters from the Project site would be less than significantly
impacted by construction-related air pollutant emissions.
P-9:
The data disclosed in the DEIR are consistent with the most updated Air Quality Impact Analysis
(Appendix C of the DEIR) and Greenhouse Gas Analysis (Appendix E of the DEIR). An older
version of the Greenhouse Gas Analysis report was inadvertently attached as Appendix E of the
DEIR, which analyzed outdated demolition assumptions. The updated Greenhouse Gas Analysis is
provided as an attachment within the Errata section of this Final EIR and replaces Appendix E of the
DEIR. As the DEIR relied on the updated Greenhouse Gas Analysis and accurately disclosed
impacts associated with greenhouse gas emissions, no revisions to the DEIR are warranted.
P-10:
Please see Responses G-2, G-3, M-3, 0-24, and P-1.
P-11:
Please see Response G-4.
P-12:
Please see Responses G-4 and G-6.
P-13:
Please see Responses G-4, G-6, and 0-29.
P-14:
Please see Response I-1 and L-13 regarding objectives.
P-15:
Please see Response L-16 regarding the financial feasibility of the No Project/Office Redevelopment
Alternative and the Commercial/Restaurant Alternative. Regarding the Multiple Unit Residential
Alternative, the Project Applicant provided information to the City which indicated that the
development of the Multiple Unit Residential Alternative would not be economically feasible after
consideration of the cost of developing the uses, including land acquisition and construction costs. In
evaluating the Applicant's information, the City applied a "prudent person" standard; meaning, that
the Applicant's statements about the economic infeasibility associated with selling or leasing the
property as low-rise residential building is so great compared to the developing the project site with
49 residential units, that a reasonably prudent person or property owner would not proceed with the
alternative. Information is provided as an attachment to the response to comment letter J (Martin).
Lead Agency: City of Newport Beach SCH No. 2016011032
Page FEIR-138
508
■■ 150 NEWPORT CENTER
■❑ ENVIRONMENTAL IMPACT REPORT F.0 FINAL ENVIRONMENTAL IMPACT REPORT
The Commenter inaccurately characterizes the information disclosed in the DEIR regarding the
financial feasibility of the Reduced Dwelling Units and Building Height Alternative. The conclusion
for the Reduce Dwelling Units and Building Height Alternative states that "...the Reduced Dwelling
Units and Building Height Alternative appears to be financially feasible" (Page 6-41 of the Draft
EIR).
P-16:
Responses are provided to the commenter's specific comments related to aesthetics and land use and
planning in Responses P-1 through P-4. The Commenter does not provide credible evidence that
potentially significant impacts associated with aesthetics or land use and planning would occur.
Please see Response K-10 and L-15 regarding alternatives sites as well. Several of the alternatives
studied would reduce aesthetic impacts, including the No Project/Office Redevelopment Alternative,
the Commercial/Restaurant Redevelopment Alternative, the Multiple Unit Residential Alternative,
and the Reduced Dwelling Unit and Building Height Alternative. Though, as stated on page 4.1-28
of the DEIR, the aesthetic impacts of the Project would all be less than significant. See DEIR, pages
6-2 through 6-42. Please see Response K-10 and L-13 regarding alternatives sites as well.
P-17:
Please see Response G-6.
P-18:
The responses to each of the Commenter's specific comments are provided in Responses to
Comments P-1 through P-17. The DEIR does not need to be recirculated based on §15073.5 of the
State CEQA Guidelines as explained in Response 1-9.
Lead Agency: City of Newport Beach SCH No. 2016011032
Page FEIR-139
X09
CaIEEMod Version: CalEEMod.2013.2.2 Page 1 of 34 Date: 7/7/2016 12:25 PM
Newport Center Villas
Orange County, Annual
1.0 Project Characteristics
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Enclosed Parking with Elevator 126.00 Space 1.13 133,260.00 i 0
Condo/Townhouse High Rise 49.00 Dwelling Unit 0.77 163,260.00 140
1.2 Other Project Characteristics
Urbanization Urban Wind Speed(m/s) 2.2 Precipitation Freq(Days) 30
Climate Zone 8 Operational Year 2018
Utility Company Southern California Edison
CO2 Intensity 630.89 CH4 Intensity 0.029 N20 Intensity 0.006
(Ib/MWhr) (Ib/MWhr) (Ib/MWhr)
1.3 User Entered Comments & Non-Default Data
510
CalEEMod Version: CalEEMod.2013.2.2 Page 2 of 34 Date: 7/7/2016 12:25 PM
Project Characteristics-
Land Use- Floor Surface Area:296,520 sf
Construction Phase - Construction Duration: 2 years
Trips and VMT- 940 tons of demolition required; CalEEMod assumes 20 tons per truck, which results in 47 loads of demolition to be hauled away. As such, the
Project will require 94 two-way haul trips during demolition; added import of cement
Demolition -
Grading - Grading
Architectural Coating -
Vehicle Trips -Source: Institute of Transportation Engineers (ITE)Trip Generation Handbook (9th Edition, 2012)
Area Coating -
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Table Name Column Name Default Value New Value
tblArchitecturalCoati ng ConstArea_Nonresidential_Exterior 66,630.00 25,200.00
.....................g.....-4............................. i.......................--.
tblArchitecturalCoatin ConstArea_Nonresidential_Interior 199,890.00 75,600.00
..................g.........4-----------------------------r------------------------------F.......................--.
tblAreaCoatin Area-Nonresidential-Interior 199890 1 75600
""'....................'Y.............................-------------------------------F....................------
tblConstructionPhase NumDays 10.00 1 40.00
.......
'......".............y-----------------------------r-----------------------------i....................------
tblConstructionPhase NumDays 200.00 1 400.00
"'......................Y-............................+------------------------------F......................----
tblConstructionPhase NumDays 20.00 40.00
""'...................................................r------------------------------F.....................-----
tblConstructionPhase NumDays 4.00 30.00
""'....................'Y.............................-------------------------------F....................------
tblConstructionPhase NumDays 10.00 20.00
"""......"
.............y-----------------------------r-----------------------------i....................------
tblConstructionPhase NumDays 2.00 4.00
.............................Y.............................------------------------------i.......................--.
tblGrading MaterialExported 0.00 51,600.00
.............................. ----------------------------- 5---------- ---------4----.... ------.
tblLandUse LandUseSquareFeet 50,400.00 133,260.00
J�22
CalEEMod Version: CalEEMod.2013.2.2 Page 3 of 34 Date: 7/7/2016 12:25 PM
tblLanclUse LandUseSquareFeet 49,000.00 163,260.00
------------ -----------._'--------4-------------'-•---------._.. ._....._.•._-------•------
tblOffRoad Equipment LoadFactor 0.38 0.38
-----'•---------------'-'--__4-_.._"------------'.......... -----------------------------f.............._
tblOffRoadEquipment Load Factor 0.38 0.38
-----------------------------4------------------------------ -----------------
tblOffRoadEquipment Load Factor 0.38 1 0.38
'--'-------------------- ........ "-------'-'---- ------------------------------f'•'-•--••.._.._
tblOffRoadEquipment Load Factor 0.38 0.38
•------•-----•---------- -------------------_.-•------4------------------------------ ._....-----------------•--
tblOffRoadEquipment Load Factor 0.38 0.38
---._'................'-'---- .. -----------------------------f......._......_
tblOffRoadEquipment Load Factor 0.38 0.38
-----------------------------4-----------------------------4------------------------------ --------------------------
tblOffRoadEquipment OffRoadEquipmentType i Excavators
---•-------- .._'. ............' ------------------------------i .._..-._____--------._.._.
tblOffRoadEquipment OffRoadEquipmentType i Excavators
._......_'---'----------'---' ------------------------'---- ------------------------------i-_...---•--------------•--
tblOffRoadEquipment OffRoadEquipmentType i Excavators
------------------------------i .....................
..'_'
tblOffRoadEquipment OffRoadEquipmentType i Excavators
-----------------------------4----------------------------- ------------------------------i--------------------------
tblOffRoadEquipment OffRoadEquipmentType i Excavators
.......... "-------• -------- ------------•-• ------------------------------i ----..___......__._.._....
tblOffRoadEquipment OffRoadEquipmentType i Excavators
------------------ -----------—---- ------------------------------f--------------------------
tblProjectCharacteristics OperationalYear 2014 2018
---._" -------------------------------
tblTripsAndVMT HaulingTripNumber 93.00 94.00
-----------------------------4----------------------------------------------------------- --------------------------
tblTripsAndVMT HaulingTripNumber 0.00 2,000.00
-------•............•._�...........---........__. ------------------------------f'••-..___.._.._
tblVehicleTrips ST TR 7.16 4.31
------------------------- ._.....__.__-------_'-._._._'------------------------------ ...........
tblVehicleTrips SU TR 6.07 3.43
tblVehicleTrips WD—TR 6.59 4.18
2.0 Emissions Summary
X12
CaIEEMod Version: CalEEMOd.2013.2.2 Page 4 of 34 Date: 7/7/2016 12:25 PM
2.1 Overall Construction
Unmitigated Construction
ROG NOx CO I S02 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Year tons/yr Mi
2016 0.3731 3.5485 2.8953 5.7400e- 0.2206 0.1585 0.3790 0.0787 0.1487 0.2274 ± 0.0000 • 513.6486 513.6486 0.0615 0.0000 514.9398
003 +
T 7 T Y T Y •---------------T ---------------
2017
T •
2017 0.5573 4.0491 3.8533 7.0100e- • 0.1672 0.2187 0.3858 • 0.0448 • 0.2083 0.2531 q 0.0000 591.3834 591.3834 0.0958 0.0000 • 593.3942
003 y
•
r r w T Y
X � r T ?2018 n370 1.1709 1.2212 2.2300e- 0.0551 0.0617 0.1167 0.0145 0.0585 0.0730 0.0000 187.7168 187.7168 0.0353 0.0000 188.4573
003 y
L
Total •• 2.3024 8.7685 ' 7.9698 0.0150 • 0.4428 0.4388 0.8816 0.1380 0.4155 0.5535 0.0000 •1,292.748 1,292.748• 0.1925 0.0000 • 1,296.791
11 8 8 3
Mitigated Construction
ROG NOx CO SO2 I Fugitive Exhaust PM 10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 I CH4 N20 CO2e
PM10 PM70 Total PM2.5 PM2.5 Total
Year tonslyr Mi
2016 0.3731 3.5485 2.8953 5.7400e- . 0.2206 0.1585 • 0.3790 0.0787 • 0.1487 • 0.2274 0.0000 513.6483 513.6483 • 0.0615 0.0000 514.9395
003 y
---------------T l T- l T T- l TY l
2017 •• 0.5573 � 4.0491 - 3.8533 - 7.0100e- • 0.1672 - 0.2187 . 0.3858 . 0.0448 • 0.2083 . 0.2531 ± 0.00000000 r 591.3829 - 591.3829 r 0.0958 r 0.0000 ? •
593.3938
003 3
_______ _______r______ _______r______r______r______T_______1_______-______-_______r______ ?
2018 •• 1.3720 � 1.1709 � 1.2212 � 2.2300e- 0.0551 � 0.0617 0.1167 • 0.0145 0.0585 0.0730 0.0000 187.7167 � 187.7167 0.0353 T 0.0000 188.4572
003 +
i
Total 2.3024 8.7685 7.9697 ' 0.0150 , 0.4428 ' 0.4388 • 0.8816 • 0.1380 • 0.4155 • 0.5535 0.0000 •1,292.747' 1,292.747• 0.1925 • 0.0000 • 1,296.790
9 9 5
�2�
CaIEEMod Version: CalEEMOd.2013.2.2 Page 5 of 34 Date: 7/7/2016 12:25 PM
ROG NOx CO 502 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Percent 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Reduction
2.2 Overall Operational
Unmitigated Operational
ROG NOx CO 502 I Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 TotalCO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Area 1.3941 9.9900e- 0.8184 5.2000e- 0.0496 r 0.0496 r 0.0496 r 0.0496 ± 5.2047 10.8303 16.0350 r 0.0164 r 3.5000e- 16.4878
003 004 y 004
---------------
i _ ______ -----------------------------
.. r � r � r r r r
r r r r r r r
Energy •• 4.1800e- 0.0357 r 0.0152 2.3000e- 2.8900e- 2.8900e- 2.8900e- 2.8900e- ± 0.0000 X359.0480 359.0480 0.0154 3.7800e 360.5430
003
003 004 003 003 003 + 003
.. � i � r � r r r r i r r r
w i w w r ______Tr _______Yi___ _r ______�_______ _______rr ______�r
_
Mohile 0.2765 1.2274 3.55OOe- 0.2588 3.8600e- 0.2627 0.0692 3.5600e 0.0727 0.0000 262.4146 262.4146 9700e0.0000
262.6219
003 003 003 + 003
.. r i r r r r r i
.. r r r r r
q_______w______.�_______w______.r_______Y.__ r______.•_______-_______.---------------
Waste � 0.0000 r 0.0000 r r 0.0000 r 0.0000 ± 4.5754754 r 0.0000 4.5754 0.2704 r 0.0000 10.2538
i _ ______ _______ ______ ______ _ _ _
Water 0.0000 0.0000 0.0000 0.0000 ± 1.0129 18.2950 19.3078 T 0.1049 T2.6300e 22.3255
+ 003
i
Total r 1.5033 0.3222 2.0610 4.3000e- 0.2588 0.0563 r 0.3151 r 0.0692 r 0.0560 r 0.1252 10.7930 r 650.5879 ' 661.3809 r 0.4169 r 6.7600e. r 672.2321
003 003
�2J
CaIEEMod Version: CalEEMOd.2013.2.2 Page 6 of 34 Date: 7/7/2016 12:25 PM
2.2 Overall Operational
Mitigated Operational
ROG NOx CO I S02 I Fugitive I Exhaust PM10 Fugitive I Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 P! Total
Category tons/yr MT/yr
Area •• 1.3941 9.9900e- 0.8184 5.2000e- 0.0496 0.0496 0.0496 0.0496 + 5.2047 10.8303 16.0350 0.0164 3.5000e- 16.4878
003 004 i 004
i ____ ______ _______ ______
..
Y r T ---------------
EOergy •• 4.1800e- 0.0357 0.0152 2.3000e- 2.6900e- 2.8900e- • • 2.8900e- 2.8900e- 0.0000 • 359.0460 359.0480 • 0.0154 3.7800e- • 360.5430
003 004 003 003 003 003 i 003
.• � � � r � r r r r
r r w TY r
Mobile •• 0.1050 0.2765 1.2274 3.55OOe- r 0.2588 3.8600e- r 0.2627 • 0.0692 • 3.5600e- • 0.0727 ± 0.0000 • 262.4146 � 262.4146 T9.8700e-T 0.0000 ?262.6219
n
003 003 003 y 003
i--------------ir r r r Y r i
Waste 0.0000 0.0000 0.0000 0.0000 ± 4.5754 0.0000 � 4.5754 T 0.2704 T 0.0000 10.2538
i
n T T r Y •-
Water � 0.0000 0.0000 • • 0.0000 0.0000 � 1.0129 18.2950 � 19.3078 T 0.1049 T2.6300e ? 223239
i 003
Total 1.5033 0.3222 ' 2.0610 ' 4.30000. r 0.2588 1 0.0563 r 0.3151 • 0.0692 • 0.0560 • 0.1252 10.7930 650.5879 1 661.3809 r 0.4169 • 6.7600e- 672.2305
003 003
ROG NOx I CO I SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio.CO2 NBiO-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Percent 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Reduction
3.0 Construction Detail
Construction Phase
515
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 7 of 34 Date: 7/7/2016 12:25 PM
Phase Phase Name Phase Type Start Date End Date Num Days Num Days Phase Description
Number Week
1 I
Demolition I
Demolition 6/1/2016 I
7/26/2016 5' 40'
2 -Ste Preparation :Site Preparation 7/27/2016 :8/1/2016 5' 4'
3 •
-Grading Grading 8/2/2016 ;9/12/2016 5' 30;
. .
------------------------------- ------------------
4 :Building Construction :Building Construction 9113/2016 :3/26/2018 5' 400'
. .
-------I------------------------ 1------------4------------4 i r ------------------
5 :Paving :Paving -3/27/2018 ;4/23/2018 5: 20;
6 •Architectural Coating -4/24/2018•Architectural Coating 6I18I2018 5. 40-
Acres of Grading (Site Preparation Phase): 2
Acres of Grading (Grading Phase): 11.25
Acres of Paving: 0
Residential Indoor: 330,602; Residential Outdoor: 110,201; Non-Residential Indoor: 75,600; Non-Residential Outdoor: 25,200 (Architectural
Coating —sgft)
OffRoad Equipment
51(
CaIEEMod Version: CalEEMOd.2013.2.2 Page 8 of 34 Date: 7/7/2016 12:25 PM
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition •Concrete/Industrial Saws 1 i 8.00: 81: 0.73
____________________________p___________________________H----------------a-------------H_____________-____;--------------
Demolition :Rubber Tired Dozers 1i 8.00: 255' 0.40
-------------------------------------------------------------------------i------------ ----- ----- --------------
Demolition •Tractors/Loaders/Backhoes 31 8.00- 97: 0.37
--------------------------------------------------------H______________-1i__________B.00 F_____________-_174 ___________--
Site PreparationGraders0.41
-------------------------------------------------------- -------- -------
Site Preparation :Rubber Tired Dozers t 1 7.00: 255' 0.40
--------------------------------------------------------H________________i-------------H_____________-____ --------------
Site Preparation •Tractors/Loaders/Backhoes 11 8.00: 97:; 0.37
Grading "
------ -------------""'__Graders_____________________I-----------------�''________6.00~--- -174 --------------
0.41
Grading :Rubber Tired Dozers 1� 6.00 255' 0.40
--------------------------------------------------------I ----------------i H----- -----
Grading •Tractors/Loaders/Backhoes ti 7.00: 97: 0.37
--------------------------------------------------------H________________i-------------H_____________-____ ______________
Building Construction :Cranes 11 6.00: 226'; 0.29
-------------------------------------------------------------------------i H----- -----
Building Construction :Forklifts 11 6.00: 89: 0.20
-------------------------------------------------------------------------i------------ H---- ---- --------------
Building Construction :Generator Sets 1! 8.00: 84' 0.74
--------------------------------------------------------H----------------i H----- -----
Building Construction •Tractors/Loaders/Backhoes I ti 6.00: 97: 0.37
Building Construction
----------------------------
1-----s-------------------------------------3II-------------F46: --------------
0.45
--------------------------------------------------------H----------------i-------------H----- ----- --------------
Paving :Cement and Mortar Mixers 11 6.00: 9: 0.56
-------------------------------------------------------------------------i------------ H---- ---- --------------
Paving •Pavers 1i 6.00- 125' 0.42
--------------------------------------------------------I ----------------i-- H----- ---- --------------
-
Paving :Paving Equipment ti 8.00, 130' 0.36
Paving -----------------------Rollers --------------------- ---------------- 1-------------F----------------80 --------------
0.38
-------------------------------------------------------- -----------------i------------ H----- ----- --------------
Paving •Tractors/Loaders/Backhoes 11 8.00: 97: 0.37
-------------------------------------------------------------------------i------------ H---- ---- --------------
Architectural Coating :Air Compressors 11 6.00: 78' 0.48
Demolition ____________________•Excavators __________________H_______________2�__________B.OO162 ___________0.38
Site Preparation_________________1 Excavators---------------------------H_______________2I__________B.00- 162 --------------___________---
0.38
Grading ______________________•Excavators2--------------------------- ----------------
- 162 --------------___________---
0.38
-------------------------------------------------------- -----------------i------------ H---- ---- --------------
Building Construction :Excavators 21 8.00- 162: 0.38
_______________________• __________________H_______________ i__________B.OO
PavingExcavators2
F162 ___________0.38
Architectural Coating :Excavators 2 8.00: 162: 0.38
i
CaIEEMod Version: CalEEMOd.2013.2.2 Page 9 of 34 Date: 7/7/2016 12:25 PM
Trips and VMT
Phase Name Offroad Equipment Worker Trip Vendor Trip Hauling Trip Worker Trip Vendor Trip iHaulingTrip Worker Vehicle Vendor I Hauling
Count Number Number Number Length Length Length Class Vehicle Class Vehicle Class
Demolition 71 18.00• 0.00: 94.00• 14.70 6.90: 20.00-LD Mix -HDT_Mix jHHDT
Site Preparation 51 13.00• 0.00: 0.00• 14.701 6.90: 20.00:LD_Mix :HDT_Mix 1HHDT
________________• 1 _________t__________;__________}____________1----------4----------� _____________� 1
Grading 51 13.00• 0.00: 6,450.00• 14.701 6.90: 20.00-LD Mix -HDT_Mix 1HHDT
1
________________• 1 _________t__________;__________}____________1----------4----------� ____________� 1
Building Construction 91 91.00• 27.00: 2,000.00• 14.701 6.90: 20.00:LD_Mix HDT_Mix 1HHDT
Paving 71 18.00• 0.00: 0.00• 14.701 6.90; 20.00-LD Mix :HDT_Mix 1HHDT
Architectural Coati ng 3• 18.00• 0.00• 0.00• 14.70• 6.90- 20.00-LD Mix :HDT_Mix •HHDT
3.1 Mitigation Measures Construction
3.2 Demolition -2016
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 Total CO2 CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Fugitive Dust 0.0101 0.0000 0.0101 1.5200o- 0.0000 1,5200e- i 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
003 003
...__ ____________ _______ _______ _______ _______ _______ _______ _______ _______
n • • T Y_______
Off-Road • 0.0737 0.7433 05678 • 7.000Oe- 0.0437 0.0437 0.0407 0.0407 0.0000 65.1806 65.1806 0.0175 0.0000 65.5472
004
Total 0.0737 0.7433 0.5678 7.0000e- 0.0101 0.0437 0.0537 1.5200e. ' 0.0407 0.0422 0.0000 65.1806 65.1806 0.0175 0.0000 65.5472
004 003
Ji
CaIEEMod Version: CalEEMOd.2013.2.2 Page 10 of 34 Date: 7/7/2016 12:25 PM
3.2 Demolition - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 I Fugitive Exhaust I PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 9.0000e. 0.0136 0.0105 3.0000e. 8.1000e. 1.9000e- 1.000Oe- 2.2000e. 1.8000e- 4.000Oe- + 0.0000 3.1577 3.1577 • 2.000Oe- 0.0000 3.1582
004 005 004 004 003 004 004 004 j 005
n
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 • 0.0000 0.0000 • a0000 0.0000 t 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
7
n --------------------• w 4 • ---------------Y • i r
Worker •• 1.2300e- • 1.8200e- • 0.0190 • 5.0000e- • 3.9500e- - 3.000Oe- r 3.9800e- - 1.0500e- r 3.000Oe- � 1.08OOe- � 0.0000 3.5623 - 3.5623 r 1.7000e - 0.0000 ? 3.5659
003 003 005 003 005 003 003 005 003 + 004
+
Total 2.1300e- 0.0155 0.0295 8.0000e- 4.7600e- 2.2000e- 4.9800e- 1.2700e- 2.1000e- 1.4800e- 0.0000 6.7200 6.7200 • 1.9000e. 0.0000 6.7241
003 005 003 004 003 003 004 003 004
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Fugitive Dust • 0.0101 0.0000 r 0.0101 1.5200e- 0.0000 1.5200e- 0.0000 0.0000 0.0000 r 0.0000 0.0000 0.0000
003 003 +
Off-Road •• 0.0737 • 0.7433 r 0.5678 • 7.0000e- 0.0437 • 0.0437 - • 0.0407 0.0407 0.0000 65.1805 65.1805 r 0.0175 0.0000 65.5471
004
Total 0.0737 0.7433 ' 0.5678 • 7.0000e- • 0.0101 1 0.0437 • 0.0537 1 1.5200e. ' 0.0407 0.0422 0.0000 • 65.1805 1 65.1805 , 0.0175 ' 0.0000 1 65.5471
004 003
s29
CaIEEMod Version: CalEEMOd.2013.2.2 Page 11 of 34 Date: 7/7/2016 12:25 PM
3.2 Demolition - 2016
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 I Fugitive Exhaust I PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 9.0000e. 0.0136 0.0105 3.0000e. 8.1000e. 1.9000e- 1.000Oe- 2.2000e. 1.8000e- 4.000Oe- + 0.0000 3.1577 3.1577 2.000Oe- 0.0000 3.1582
004 005 004 004 003 004 004 004 j 005
+ _______
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 • 0.0000 0.0000 • a0000 0.0000 A 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
7
n --------------------• w • T Y •---------------------------------- -------
Worker •• 1.2300e- • 1.8200e- • 0.0190 • 5.0000e- r 3.9500e- 3.000Oe- r 3.9800e- 1.05OOe- r 3.000Oe- 1.0800e- 0.0000 3.5623 3.5623 r 1.7000e � 0.0000 ? 3.5659
003 003 005 003 005 003 003 005 003 + 004
+
Total 2.1300e- 0.0155 0.0295 8.0000e- 4.7600e- 2.2000e- 4.9800e- 1.2700e- 2.1000e- 1.4800e- 0.0000 6.7200 6.7200 • 1.9000e. 0.0000 6.7241
003 005 003 004 003 003 004 003 004
3.3 Site Preparation - 2016
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Fugitive Dust • 0.0116 0.0000 r 0.0116 5.9100e- 0.0000 5.9100e- 0.0000 0.0000 0.0000 r 0.0000 0.0000 0.0000
003 003 +
Off-Road •• 6.4500e- • 0.0694 r 0.0468 • 6.0000e- 3.6700e- • 3.6700e- 3.3800e- 3.3800e- 0.0000 5.2370 5.2370 r 1.58OOe- 0.0000 5.2702 -
003 005 003 003 003 003 003
Total 6.4500e- 0.0694 ' 0.0468 • 6.000Oe- ' 0.0116 1 3.6700e- • 0.0153 5.9100e- ' 3.3800e- 9.2900e- 0.0000 5.2370 1 5.2370 r 1.5800e- 0.0000 ' 5.2702
003 005 003 003 003 003 003
520
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 12 of 34 Date: 7/7/2016 12:25 PM
3.3 Site Preparation - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
J
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 • OMOO 0.0000 • 0.0000 0.0000 t 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
7
n 7- -------------------------- -� • T Y i
Worker •• 9.000Oe- • 1.3000e- • 1.3700e- • 0.0000 • 2.9000e- 0.0000 • 2.9000e- 8.000Oe- • 0.0000 8.000Oe- 0.0000 0.2573 � 0.2573 • 1.000Oe � 0.0000 ? 0.2575
005 004 003 004 004 005 005 005
Total 9.000Oe- , 1.3000e- 1.3700e- , 0.0000 ' 2.9000e- 0.0000 ' 2.9000e- 8.000Oe- 0.0000 8.000Oe- 0.0000 0.2573 0.2573 ' 1.000Oe- 0.0000 0.2575
005 004 003 004 004 005 005 005
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Fugitive Dust • 0.0116 0.0000 0.0116 5.9100e- 0.0000 5.9100e- 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
003 003
Off-Road •• 6.4500e- • 0.0694 r 0.0468 • 6.0000e- 3.6700e- • 3.6700e- 3.3800e- 3.3800e- 0.0000 5.2370 5.2370 • 1.5800e- 0.0000 5.2702
003 005 003 003 003 003 003
Total 6.4500e- , 0.0694 ' 0.0468 ' 6.000Oe- , 0.0116 1 3.6700e- 1 0.0153 5.9100e- ' 3.3800e- 9.2900e- 0.0000 5.2370 5.2370 1.5800e. 0.0000 5.2702
003 005 003 003 003 003 003
1522
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 13 of 34 Date: 7/7/2016 12:25 PM
3.3 Site Preparation - 2016
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
J
Vendor •• 0.0000 • 0.0000 0.0000 0.0000 • 0.0000 0.0000 • OMOO 0.0000 • 0.0000 0.0000 A 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
7
n 7- -------------------------- -� • T Y i
Worker •• 9.000Oe- • 1.3000e- • 1.3700e- • 0.0000 • 2.9000e- 0.0000 • 2.9000e- 8.000Oe- • 0.0000 8.000Oe- 0.0000 0.2573 � 0.2573 • 1.000Oe � 0.0000 ? 0.2575
005 004 003 004 004 005 005 005
Total 9.0000e- , 1.3000e- 1.3700e- , 0.0000 ' 2.9000e- 0.0000 ' 2.9000e- 8.000Oe- ' 0.0000 8.000Oe- 0.0000 0.2573 0.2573 ' 1.000Oe- 0.0000 0.2575
005 004 003 004 004 005 005 005
3.4 Grading - 2016
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Fugitive Dust • 0.0766 0.0000 0.0766 0.0383 0.0000 0.0383 0.0000 0.0000 0.0000 r 0.0000 0.0000 0.0000
------------------------------------------------------------ .
w i w - w i- _y. • i
6ff-Road •• 0.0416 r 0.4491 r 0.3084 • 3.7000e- 0.0237 r 0.0237 0.0218 0.0218 0.0000 34.9472 34.9472 r 0.0105 0.0000 351686
004
Total 0.0416 ' 0.4491 ' 0.3084 ' 3.7000e- ' 0.0766 1 0.0237 , 0.1003 0.0383 0.0218 0.0601 0.0000 34.9472 34.9472 , 0.0105 0.0000 35.1686
004
1522
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 14 of 34 Date: 7/7/2016 12:25 PM
3.4 Grading - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Hauling 0.0616 0.9351 0.7185 2.3700e- 0.0553 0.0134 0.0687 0.0152 0.0123 0.0275 + 0.0000 216.6744 216.6744 • 1.5500e- 0.0000 216.7070
003 j 003
n
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 • OMOO 0.0000 • 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
7
n --------------------• w---------------•---------------------------------Y • i r
Worker •• 6.7000e- • 9.9000e- • 0.0103 • 3.0000e- r 2.1400e- � 2.000Oe- r 2.1600e- � 5.7000e- r 1.000Oe- � 5.8000e- � 0.0000 1.9296 � 1.9296 r 9.000Oe � 0.0000 ? 1.9315
004 004 005 003 005 003 004 005 004 + 005
Total 0.0623 0.9361 0.7288 2.4000e- • 0.0574 0.0134 • 0.0708 0.0157 0.0123 0.0281 0.0000 218.6040 218.6040 1.6400e- 0.0000 218.6385
003 003
Mitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
MWT
Fugitive Dust • 0.0766 0.0000 r 0.0766 0.0383 0.0000 0.0383 0.0000 0.0000 0.0000 r 0.0000 0.0000 0.0000
r r w i w - w i- _1. • i
Off-Road •• 0.0416 r 0.4491 r 0.3084 • 3.7000e- 0.0237 r 0.0237 0.0218 0.0218 0.0000 34.9472 34.9472 r 0.0105 0.0000 351686
004
Total 0.0416 • 0.4491 ' 0.3084 • 3.7000e- • 0.0766 1 0.0237 • 0.1003 0.0383 0.0218 0.0601 0.0000 34.9472 34.9472 , 0.0105 0.0000 35.1686
004
523
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 15 of 34 Date: 7/7/2016 12:25 PM
3.4 Grading - 2016
Mitigated Construction Offsite
ROG NOx CO SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Hauling 0.0616 0.9351 0.7185 2.3700e- 0.0553 0.0134 0.0687 0.0152 0.0123 0.0275 + 0.0000 216.6744 216.6744 • 1.5500e- 0.0000 216.7070
003 j 003
n
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 • OMOD � 0.0000 • 0.0000 � 0.0000 � 0.0000 0.0000 � 0.0000 • 0.0000 � 0.0000 � 0.0000
7
n --------------------• w---------------•---------------------------------Y • i r
Worker •• 6.7000e- • 9.9000e- • 0.0103 • 3.0000e- r 2.1400e- � 2.000Oe- r 2.1600e- � 5.7000e- r 1.000Oe- � 5.8000e- � 0.0000 1.9296 � 1.9296 r 9.000Oe � 0.0000 ? 1.9315
004 004 005 003 005 003 004 005 004 + 005
+
Total 0.0623 0.9361 0.7288 2.4000e- • 0.0574 0.0134 • 0.0708 0.0157 0.0123 0.0281 0.0000 218.6040 218.6040 1.6400e- 0.0000 218.6385
003 003
3.5 Building Construction - 2016
Unmitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Off-Road n 0.1608 • 1.1634 • 0.8531 • 1.2900e- 0.0713 r 0.0713 0.0680 0.0680 0.0000 112.9581 112.9581 r 0.0281 0.0000 113.5476
003 +
+
Total 0.1608 1.1634 0,8531 1,2900e- 0.0713 0.0713 0.0680 0.0680 0.0000 112.9581 112.9581 0.0281 0.0000 113.5476
003
524
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 16 of 34 Date: 7/7/2016 12:25 PM
3.5 Building Construction - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 I Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Hauling 3.7700e. 0.0573 0.0440 1.5000e- 0.0138 8.2000e- 0.0146 3.4800e- 7.5000e- 4.2300e- + 0.0000 13.2692 13.2692 9.000Oe- 0.0000 13.2712
003 004 004 003 004 003 j 005
Vendor •• 9.9600e- • 0.0963 0.1258 2.3000e- • 6.5600e- 1.4700o- • 8.0300e- 1.8700e- • 1.3500e- 3.2200e- t 0.0000 20.9071 20.9071 • 1.5000e- - 0.0000 20.9102
003 004 003 003 003 003 003 003 i 004
n 7- w • w -i T Y •---------------------------------
a
i r
Worker •• 0.0123 • 0.0182 • 0.1897 • 4.7000e- r 0.0395 2.8000e- r 0.0397 0.0105 r 2.6000e- 0.0107 0.0000 35.5681 35.5681 r 1.7400e 0.0000 ? 35.6046
004 004 004 + 003
+
Total 0.0260 0.1717 0.3595 8.5000e- • 0.0598 2.5700e- 0.0624 0.0158 2.3600e- 0.0182 0.0000 69.7444 69.7444T• .9800e- 0.0000 69.7861
004 003 003 003
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Off-Road n 0.1608 • 1.1634 • 0.8531 • 1.2900e- 0.0713 r 0.0713 0.0680 0.0680 0.0000 112.9580 112.9580 r 0.0281 0.0000 113.5474
003 +
+
Total 0.1608 1.1634 0,8531 1,2900e- 0.0713 0.0713 0.0680 0.0680 0.0000 112.9580 ' 112.9580 0.0281 0.0000 113.5474
003
5215
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 17 of 34 Date: 7/7/2016 12:25 PM
3.5 Building Construction - 2016
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 I Fugitive I Exhaust I PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Hauling 3.7700e. 0.0573 0.0440 1.5000e- 0.0138 8.2000e- 0.0146 3.4800e- 7.5000e- 4.2300e- + 0.0000 13.2692 13.2692 9.000Oe- 0.0000 13.2712
003 004 004 003 004 003 j 005
Vendor •• 9.9600e- • 0.0963 0.1258 2.3000e- • 6.5600e- 1.4700o- • 8.0300e- 1.8700e- • 1.3500e- 3.2200e- A 0.0000 20.9071 20.9071 • 1.5000e- - 0.0000 20.9102
003 004 003 003 003 003 003 003 i 004
n 7- w • w -i T Y •---------------------------------
a
i r
Worker •• 0.0123 • 0.0182 • 0.1897 • 4.7000e- r 0.0395 2.8000e- r 0.0397 0.0105 r 2.6000e- 0.0107 0.0000 35.5681 35.5681 r 1.7400e 0.0000 ? 35.6046
004 004 004 + 003
+
Total 0.0260 0.1717 0.3595 8.5000e- • 0.0598 2.5700e- 0.0624 0.0158 2.3600e- 0.0182 0.0000 69.7444 69.7444 • 1.9800e- 0.0000 69.7861
004 003 003 003
3.5 Building Construction - 2017
Unmitigated Construction On-Site
ROG NOx I CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Off-Road n 0.4787 • 3.5338 • 2.7544 • 4.2400e- 0.2110 • 0.2110 0.2012 0.2012 0.0000 368.2162 368.2162 r 0.0897 0.0000 370.0989
003 +
+
Total 0.4787 3.5338 2.7544 4.2400e- 0.2110 0.2110 0.2012 0.2012 0.0000 368.2162 ' 368.2162 0.0897 0.0000 370.0989
003
520
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 18 of 34 Date: 7/7/2016 12:25 PM
3.5 Building Construction - 2017
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 I Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Hauling 0.0117 0.1728 0.1389 4.8000e- 0.0157 2.4700e- 0.0182 4.1700e. 2.2700e- 6.4400e. + 0.0000 42.9502 42.9502 3.1000e. 0.0000 42.9567
004 003 003 003 003 j 004
n
Vendor •• (7502 • 0.2881 0.3918 • 7.6000e- • 0.0216 4.3100e- • 0.0259 6.1700e- • 3.9700e- 0.0101 t 0.0000 67.6875 67.6875 • 4.8000e- 0.0000 67.6976
004 003 003 003 1 004
nr r • r i r i
n --------------------• w -� •---------------------------------Y • i r
Worker •• 0.0367 • 0.0544 • 0.5682 • 1.5400e- r 0.1299 9.000Oe- r 0.1308 0.0345 8.3000e- 0.0353 0.0000 112.5295 112.5295 r 5.3100e- 0.0000 ?112.6410
003 004 004 + 003
+
Total 0.0786 0.5153 1.0990 2.7800e- r 0.1672 7.6800e- r 0.1749 0.0448 7.0700e- 0.0519 0.0000 223.1672 223.1672 6.1000e- 0.0000 223.2953
003 003 003 003
Mitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Off-Road n 0.4787 • 3.5338 • 2.7544 • 4.2400e- 0.2110 • 0.2110 0.2012 0.2012 0.0000 368.2158 368.2158 r 0.0897 0.0000 370.0984
003 +
+
Total 0.4787 3.5338 2.7544 4.2400e- 0.2110 0.2110 0.2012 0.2012 0.0000 368.2158 ' 368.2158 0.0897 0.0000 370.0984
003
1527
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 19 of 34 Date: 7/7/2016 12:25 PM
3.5 Building Construction - 2017
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 I Fugitive I Exhaust I PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Hauling 0.0117 0.1728 0.1389 4.8000e- 0.0157 2.4700e- 0.0182 4.1700e. 2.2700e- 6.4400e. + 0.0000 42.9502 42.9502 3.1000e. 0.0000 42.9567
004 003 003 003 003 j 004
n
Vendor •• (7502 • 0.2881 0.3918 • 7.6000e- • 0.0216 4.3100e- • 0.0259 6.1700e- • 3.9700e- 0.0101 A 0.0000 67.6875 67.6875 • 4.8000e- 0.0000 67.6976
004 003 003 003 1 004
nr r • r i r i
n --------------------• w -� •---------------------------------Y • i r
Worker •• 0.0367 • 0.0544 • 0.5682 • 1.5400e- r 0.1299 9.000Oe- r 0.1308 0.0345 8.3000e- 0.0353 0.0000 112.5295 112.5295 r 5.3100e- 0.0000 ?112.6410
003 004 004 + 003
+
Total 0.0786 0.5153 1.0990 2.7800e- r 0.1672 7.6800e- r 0.1749 0.0448 7.0700e- 0.0519 0.0000 223.1672 223.1672 6.1000e- 0.0000 223.2953
003 003 003 003
3.5 Building Construction - 2018
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Off-Road n 0.0969 • 0.7228 • 0.6279 • 9.9000e- 0.0416 • 0.0416 0.0397 0.0397 0.0000 85.5590 85.5590 r 0.0205 0.0000 85.9886
004 +
+
Total 0.0969 0.7228 0.6279 9.9000e- 0.0416 0.0416 0.0397 0.0397 0.0000 85.5590 85.5590 0.0205 0.0000 85.9886
004
528
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 20 of 34 Date: 7/7/2016 12:25 PM
3.5 Building Construction - 2018
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 I Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 2.65OOe- 0.0376 0.0317 1.1000e- 0.0136 5.8000e- 0.0142 3.4100e- 5.3000e- 3.9400e- + 0.0000 9.9082 9.9082 7.000Oe- 0.0000 9.9098
003 004 004 003 004 003 j 005
n w r ♦ r '1 T Y • t
Vendor •• 6.6100e- • 0.0620 0.0878 1.8000e- • 5.0700e- 9.S000e- 6.0200e- 1.4500e- 8.8000e- 2.3200e- 0.0000 15.6108 15.6108 • 1.1000e- 0.0000 15.6132
003 004 003 004 003 003 004 003 1 004
n4--------------• w -i T Y • i r
Worker •• 7.8500e- • 0.0116 • 0.1218 • 3.6000e- r 0.0305 2.1000e- r 0.0307 8.0900e- r 1.9000e- 8.2900e- 0.0000 25.4112 25.4112 r 1.1600e - 0.0000 ? 25.4356
003 004 004 003 004 003 + 003
+
Total 0.0171 0.1113 0.2413 6.5000e- • 0.0491 1.7400e- 0.0509 0.0130 1.6000e- 0.0146 0.0000 50.9302 50.9302 • 1.3400e- 0.0000 50.9586
004 003 003 003
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Off-Road 0.0969 • 0.7228 • 0.6279 • 9.9000e- 0.0416 • 0.0416 0.0397 0.0397 0.0000 85.5589 85.5589 r 0.0205 0.0000 85.9885
004 +
+
Total 0.0969 0.7228 0.6279 9.9000e- 0.0416 0.0416 0.0397 0.0397 0.0000 85.5589 85.5589 0.0205 0.0000 85.9885
004
��9
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 21 of 34 Date: 7/7/2016 12:25 PM
3.5 Building Construction - 2018
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 I Fugitive I Exhaust I PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 2.65OOe- 0.0376 0.0317 1.1000e- 0.0136 5.8000e- 0.0142 3.4100e- 5.3000e- 3.9400e- + 0.0000 9.9082 9.9082 7.000Oe- 0.0000 9.9098
003 004 004 003 004 003 j 005
n w r ♦ r '1 T Y • t
Vendor •• 6.6100e- • 0.0620 0.0878 1.8000e- • 5.0700e- 9.S000e- 6.0200e- 1.4500e- 8.8000e- 2.3200e- 0.0000 15.6108 15.61011 • 1.1000e- 0.0000 15.6132
003 004 003 004 003 003 004 003 1 004
n --------------• w -i T Y •---------------r
Worker •• 7.8500e- • 0.0116 • 0.1218 • 3.6000e- r 0.0305 2.1000e- r 0.0307 8.0900e- r 1.9000e- 8.2900e- 0.0000 25.4112 25.4112 r 1.1600e - 0.0000 ? 25.4356
003 004 004 003 004 003 + 003
+
Total 0.0171 0.1113 0.2413 6.5000e- • 0.0491 1.7400e- 0.0509 0.0130 1.6000e- 0.0146 0.0000 50.9302 50.9302 • 1.3400e- 0.0000 50.9586
004 003 003 003
3.6 Paving - 2018
Unmitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 1 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Off-Road 0.0160 • 0.1669 • 0.1562 • 2.4000e- 9.1200e- r 9.1200e- 8.4000e- 8.4000e- 0.0000 21.7487 21.7487 r 6.7000e- 0.0000 21.8894
004 003 003 003 003 + 003
Paving •• 0.0000 0.0000 • 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 r 0.0000 - 0.0000 0.0000
Total 0.0160 0.1669 r 0.1562 • 2.4000e- 1 9.1200e. 9.1200e- 1 ' 8.4000e- 8.4000e- 0.0000 21.7487 21.7487 r 6.7000e- 0.0000 21.8894
004 003 003 003 003 003
530
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3.6 Paving - 2018
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
J
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 • OMOD 0.0000 • 0.0000 0.0000 t 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
7
n 7- -------------------------- -� • T Y i
Worker •• 5.1000e- • 7.5000e- • 7.9000e- • 2.0000e- • 1.9800e- 1.000Oe- • 1.9900e- 5.2000e- 1.000Oe- 5.4000e- 0.0000 1.6480 � 1.6480 • B.000Oe � 0.0000 ? 1.6496
004 004 003 005 003 005 003 004 005 004 005
Total 5.1000e- , 7.5000e- 7.9000e- , 2.0000e- , 1.9800e- 1.000Oe- , 1.9900e- 5.2000e- 1.000Oe- 5.4000e- 0.0000 1.6480 1.6480 ' 8.000Oe- 0.0000 1.6496
004 004 003 005 003 005 003 004 005 004 005
Mitigated Construction On-Site
ROG NOx I CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Off-Road n 0.0160 • 0.1669 • 0.1562 • 2.4000e- 9.1200e- 9.1200e- 8.4000e- 8.4000e- 0.0000 21.7487 21.7487 r 6.7000e- 0.0000 21.8893
004 003 003 003 003 003
Paving •• 0.0000 0.0000 • 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 - 0.0000 0.0000
Total 0.0160 0.1669 ' 0.1562 ' 2.4000e- , 1 9.1200e. 9.1200e- 1 ' 8.4000e- 8.4000e- 0.0000 21.7487 21.7487 • 6.7009e- 0.0000 21.8893
004 003 003 003 003 003
531
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3.6 Paving - 2018
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
J
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 • OMOD 0.0000 • 0.0000 0.0000 A 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
7
n 7- -------------------------- -� • T Y i
Worker •• 5.1000e- • 7.5000e- • 7.9000e- • 2.0000e- • 1.9800e- 1.000Oe- • 1.9900e- 5.2000e- 1.000Oe- 5.4000e- 0.0000 1.6480 � 1.6480 • B.000Oe � 0.0000 ? 1.6496
004 004 003 005 003 005 003 004 005 004 005
Total 5.1000e- , 7.5000e- 7.9000e- , 2.0000e- , 1.9800e- 1.000Oe- , 1.9900e- 5.2000e- 1.000Oe- 5.4000e- 0.0000 1.6480 1.6480 ' 8.000Oe- 0.0000 1.6496
004 004 003 005 003 005 003 004 005 004 005
3.7 Architectural Coating -2018
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Archit.Coating •• 1.2225 • 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 r 0.0000 0.0000 0.0000
_______ ______ _______ ______ _______ _______ _______ --------------1 _ ___________ _______ _______ ---------------
Off-Road •• 0.0179 • 0.1677 r 0.1721 • 2.7000e- r � 9.2000e- • 9.2000e- � � 8.7000e- � 8.7000e- � 0.0000 24.5349 � 24.5349 r 6.5300e � 0.0000 24.6721
004 003 003 003 003 003
Total 1.2404 0.1677 , 0.1721 ' 2.7000e- , 1 9.2000e. 9.2000e- ' 8.7000e- 8.7000e- 0.0000 24.5349 24.5349 , 6.5300e- 0.0000 24.6721
004 003 003 003 003 003
532
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3.7 Architectural Coating - 2018
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 7otaICO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
J
Vender •• 0.0000 • 0.0000 0.0000 0.0000 • 0.0000 0.0000 • OMOO 0.0000 • 0.0000 0.0000 t 0.0000 0.0000 0.0000 • 0.0000 0.0000 0.0000
7
n -------------------------------- -� • T Y i
Worker •• 1.0200e- • 1.5100e- • 0.0158 • 5.0000e- • 3.9500e- 3.000Oe- • 3.9800e- 1.0500e- • 3.00008- 1.0700e- 0.0000 3.2960 � 3.2960 • 1.S000e � 0.0000 ? 3.2992
003 003 005 003 005 003 003 005 003 004
Total 1.0200e- , 1.5100e- 0.0158 5.0000e- , 3.9500e- 3.000Oe- , 3.9800e- 1.0500e- 3.000Oe- 1.07008- 0.0000 3.2960 3.2960 ' 1.5000e- 0.0000 3.2992
003 003 005 003 005 003 003 005 003 004
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Archit.Coating • 1.2225 • 0.0000 r 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 r 0.0000 0.0000 0.0000
_______ ______ _______ ______ _______ _______ _______ ______ ______ 1 _ ___________ _______ _______ ---------------
Off-Road •• 0.0179 • 0.1677 r 0.1721 • 2.7000e- r � 9.2000e- • 9.2000e- � � 8.7000e- � 8.7000e- � 0.0000 24.5349 � 24.5349 r 6.5300e � 0.0000 24.6721
004 003 003 003 003 003
Total 1.2404 0.1677 , 0.1721 ' 2.7000e- ' 1 9.2000e. 9.2000e- ' 8.7000e- 8.7000e- 0.0000 24.5349 24.5349 , 6.5300e- 0.0000 24.6721
004 003 003 003 003 003
533
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3.7 Architectural Coating - 2018
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category ions/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 ' 0.0000 0.0000 0.0000
J
Vendor •• 0.0000 ' 0.0000 0.0000 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 A 0.0000 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 ' 0.0000
7
n -------------------------------- -� • T Y . i
Worker •' 1.0200e- ' 1.5100e- ' 0.0158 ' 5.0000e- ' 3.9500e- ' 3.000Oe- ' 3.9800e- ' 1.0500e- ' 3.00008- ' 1.0700e- 0.0000 3.2960 ' 3.2960 ' 1.S000e ' 0.0000 ? 3.2992
003 003 005 003 005 003 003 005 003 004
Total 1.0200e- , 1.5100e- , 0.0158 5.0000e- , 3.9500e- 3.000Oe- , 3.98OOe- 1.05OOe- 3.000Oe- 1.07008- 0.0000 3.2960 3.2960 ' 1.5000e- 0.0000 3.2992
003 003 005 003 005 003 003 005 003 004
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
ROG NOx CO I S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Mitigated 0.1050 0.2765 1.2274 3.5500e- ' 0.2588 3.8600e- ' 0.2627 0.0692 3.5600e- ' 0.0727 ! 0.0000 262.4146 ' 262.4146 ' 9.8700e- ' 0.0000 262.6219
003 003 003 003
_ _
Unmitigated •' 0.1050 0.2765 1.2274 3.5500e- ' 0.2588 3.8600e- ' 0.2627 0.0692 3.5600e-T 0.0727 0.0000 262.4146-
262.4146T 9.8700e-T 0.0000 ?262.6219
003 003 003 003
J��J
CaIEEMod Version: CalEEMod.2O13.2.2 Page 26 of 34 Date: 7/7/2016 12:25 PM
4.2 Trip Summary Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use WeekdaySaturday ISunday Annual VMT Annual VMT
Condo/Townhouse High Rise 204.82 211.19 i 168.07 685,071 685,071
Enclosed Parkin with Elevator 0 00 0.00 i 0 00
Total 204.82 211.19 168.07 685,071 685,071
4.3 Trip Type Information
Miles Trip% Trip Purpose%
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Condo/Townhouse High Rise 14.70 5.90 8.70 40.20 19.20 i 40.60 86 11 3
....................... ..........r_________ __________ ________T_________�___________,- ----------------------------------------
Enclosed Parking with Elevator• 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
0.510011• 0.056836• 0.192178• 0.151564 0.041643 0.005905 0.015642• 0.015146 0.001440 0.002149• 0.004721• 0.000504 0.002262
�.g Pg[W Detail
Historical Energy Use: N
5.1 Mitigation Measures Energy
53�
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 27 of 34 Date: 7/7/2016 12:25 PM
ROG Nox CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 I NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Electricity 0.0000 0.0000 0.0000 0.0000 + 0.0000 317.6679 317.6679 0.0146 3.0200e- 318.9111
Mitigated 003
___________ _____ _______ _______1______________ _______ _______ _______ _
..
n T Y
Electricity 0.0000 0.0000 0.0000 0.0000 0.0000 317.6679 � 317.6679 • 0.0146 - 3.0200e ?318.9111
Unmitigated i 003
_______ a ______ ________ _______ _______
T Y ,� • -, T_______
NaturalGas •• 4.1800e- - 0.0357 • 0.0152 • 2.3000e- 2.8900e- • 2.8900e- 2.8900e- 2.6900e- 0.0000 41.3801 41.3801 • 7.9000e- 7.6000e- 41.6319
Mitigated 003 004 003 003 003 003 004 004
NaturalGas •• 4.1800e- 0.0357 0.0152 2.3000e- 2.8900e- 2.8900e- 2.8900e- 2.8900e- 0.0000 41.3801 41.3801 T 7.9000e-T 7.6000e-? 41.6319
Unmitigated 003 004 003 003 003 003 004 004
5.2 Energy by Land Use - NaturalGas
Unmitigated
NaturalGa ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5F021 Total CO2 CH4 N20 CO2e
s Use PM10 PM10 Total PM2.5 PM2.5 Total
Land Use I kBTU/yr ions/yr MT/yr
Enclosed Parking 0 e 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
with Elevator
___ ______1,_______ ______ _______ ______ _______ _______ _______ ______ ---------------1______________ _______ _______ ______ ______
A T• T• T• Y T T -
Condo/Townhous- 775433 A, 4.1800e-4.1800e- • 0.0357 � 0.0152 r 2.3000e- � � 2.8900e- - 2.8900e- � � 2.8900e- , 2.8900e- � 0.0000 � 41.3801 - 41.3801 - 7.9000e- , 7.6000e- � 41.6319
e High Rise A. 003 004 003 003 003 003 004 004
A.
Total 4.1800e- , 0.0357 ' 0.0152 2.3000e- ' 2.8900e- ' 2.8900e- ' 2.8900e- 2.8900e- 0.0000 41.3801 41.3801 7.9000e- ' 7.6000e- ' 41.6319
003 004 003 003 003 003 004 004
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 28 of 34 Date: 7/7/2016 12:25 PM
5.2 Energy by Land Use - NaturalGas
Mitigated
NaturalGa ROG NOx I CO I 502 I Fugitive Exhaust PM10 I Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 I CH4 N20 CO2e
s Use PM10 PM10 Total PM2.5 PM2.5 Total
Land Use kBTU/yr tonslyr MT/yr
Enclosed Parking 0 1; 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
with Elevator
1, J ________ ______ .......
Condo/Townhous 775433 �• 4.1800e- • 0.0357 0.0152 • 2.3000e- • 2.8900e- 2.8900e- 2.8900e- • 2.89009- 0.0000 41.3801 41.3801 7.9000e-T7.6000e ? 41.6319
e High Rise i; 003 004 003 003 003 003 i 004 004
b �
Total 4.1800e- ' 0.0357 ' 0.0152 ' 2.3000e- ' ' 2.8900e- 2.8900e- ' 1 2.89009- ' 2.89009- 0.0000 41.3801 ' 41.3801 1 7.9000e- 1 7.6000e- 41.6319
003 004 003 003 003 003 004 004
5.3 Energy by Land Use - Electricity
Unmitigated
Electricity Total CO2 CH4 N20 CO2e
Use
Land Use kWh/yr MT/yr
Condo/Townhous 211907 60.6407 2.7900e- 5.8000e- 60.8781
e High Rise 003 004
Enclosed Parking ' 898172 1. 257.0272 T 0.0118 2.4400e ?258.0331
with Elevator 003
Total 317.6679 , 0.0146 3.02000- , 318.9111
003
53j
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 29 of 34 Date: 7/7/2016 12:25 PM
5.3 Energy by Land Use - Electricity
Mitigated
Electricity Total CO2 CH4 I N20 I CO2e
Use
Land Use kWh/yr MT/yr
Condo/Townhous 211907 60.6407 2.7900e- 5.8000e- 60.8781
e High Rise i. 003 004
Enclosed Parking 898172 6 257.0272 0.0118 2.4400e-?258.0331
with Elevator 003
b
Total 317.6679 ' 0.0146 ' 3.0200e- , 318.9111
003
6.0 Area Detail
6.1 Mitigation Measures Area
ROG I NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category tons/yr MT/yr
Mitigated 1.3941 9.9900e- 0.8184 5.2000e- 0.0496 0.0496 0.0496 0.0496 ! 5.2047 10.8303 16.0350 0.0164 3.5000e- 16.4878
003 004 004
1
Unmitigated •• 1.3941 9.9900e- 0.8184 5.2000e- 0.0496 0.0496 0.0496 0.0496 5.2047 10.8303 16.0350 0.0164 T 3.5000e- • 16.4878
003 004 004
538
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 30 of 34 Date: 7/7/2016 12:25 PM
6.2 Area by SubCategory
Unmitigated
ROG NOx CO SO2 Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PMio To[al PM2.5 PM2.5 Total
SubCategory tons/yr MT/yr
Architectural •• 0.1463 0.0000 0.0000 0.0000 0.0000 ± 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Coating +
n w Y Y Y Y - Y
Consumer 1.0715 0.0000 0.0000 • 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 T 0.0000 T•0.0000
Products i
-----------------------4 w w w w T Y r w w
Hearth •• 0.1605 4.0700e- 0.3079 - 4.9000e- 0.0468 • 0.0468 • • 0.0468 • 0.0466 + 5.2047 10.0017 15.2065 • 0.0155 • 3.5000e-? 156419
003 004 y 004
---n i
i--------------i w w w r Y r iw
Landscaping •• 0.0158 5.9200e- 0.5105 3.000Oe- 2.7800e- 2.7800e- 2.7800e- 2.7800e- ± 0.0000 0.8286 � 0.8286 8.3000e-T 0.0000 � 0.8459
003 0o5 003 003 003 003 + 004
L
Total 1.3941 9.9900e- ' 0.8184 5.20000- 0.0496 0.0496 • 0.0496 • 0.0496 5.2047 10.8303 16.0350 0.0164 3.5000e- 16.4878
003 004 004
539
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 31 of 34 Date: 7/7/2016 12:25 PM
6.2 Area by SubCategory
Mitigated
ROG NOx CO SO2 Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM1O PMio To[al PM2.5 PM2.5 Total
SubCategory tons/yr MT/yr
Architectural •• 0.1463 0.0000 0.0000 0.0000 0.0000 ± 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Coating +
n w Y Y Y -
Consumer 1.0715 ' 0.0000 0.0000 ' 0.0000 0.0000
Products 0.0000 0.0000 ' 0.0000 T 0.0000 0.0000 ' 0.0000
i
...........n-----------------------
� � � � � r r r r
- 4 w w w w T Y r w w
Hearth •' 0.1605 ' 4.0700e- ' 0.3079 4.9000e- ' ' 0.0468 ' 0.0468 ' ' 0.0468 ' 0.0466 ± 5.2047 10.0017 ' 15.2065 ' 0.0155 ' 3.5000e-? 156419
003 004 + 004
i--------------i w w w r Y r iw
Landscaping •• 0.0158 5.9200e- ' 0.5105 3.000Oe- ' 2.7800e- ' 2.7800e- ' 2.7800e- ' 2.7800e- + 0.0000 0.8286 0.8286 8.3000e-T 0.0000 � 0.8459
003 Oo5 003 003 003 003 i 004
+
Total 1.3941 9.9900e- ' 0.8184 5.20000- 0.0496 0.0496 , 0.0496 , 0.0496 5.2047 10.8303 16.0350 0.0164 3.5000e- , 16.4878
003 004 004
7.0 Water Detail
7.1 Mitigation Measures Water
Total C77[-7777 CO2e
Category MT/yr
Mitigated •• 19.3078 0.1049 2.6300e- ' 22.3239
003
Unmitigated m 19.3078 T 0.1049 T 2.6300e-? 22.3255
003
J�-T
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 32 of 34 Date: 7/7/2016 12:25 PM
7.2 Water by Land Use
Unmitigated
Indoor/Out Total CO2 CH4 I N20 I CO2e
door Use
Land Use Mgal MT/yr
CondolTownhous•3.19255/ + 19.3078 0.1049 2.6300e- 22.3255
e High Rise 2.01269 A; 003
Enclosed Parking ' 0/0 1. 0.0000 Y 0.0000 0.0000 0.0000
with Elevator +,
6
Total 19.3078 r 0.1049 1 2.63008- 22.3255
003
Mitigated
Indoor/Out Total CO2 CH4 N20 CO2e
door Use
Land Use Mgal MT/yr
Condo/Townhous•3.19255/ +- 19.3078 0.1049 2.6300e- 22.3239
e High Rise ; 2.01269 1; 003
+,
Enclosed Parking • 0/0 A, 0.0000 r 0.0000 0.0000 0.0000
with Elevator +,
Total 19.3078 0.1049 2.63008- 22.3239
11 003
8.0 Waste Detail
8.1 Mitigation Measures Waste
541
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 33 of 34 Date: 7/7/2016 12:25 PM
Category/Year
Total C72 CH4 720 CO2e
MT/yr
Mitigated •• 4.5754 0.2704 0.0000 10.2538
Unmitigated •R 4.5754 T 0.2704 -r 0.0000 ? 10.2538
8.2 Waste by Land Use
Unmitigated
waste Total CO2 CH4 N20 CO2e
Disposed
Land Use tons MT/yr
Condo/Townhous• 22.54 4 4.5754 r 0.2704 0.0000 10.2538
e High Rise a,
n
Enclosed Parking • 0 0.0000 0.0000 0.0000 0.0000
with Elevator
Total 4.5754 0.2704 0.0000 10.2538
�J
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 34 of 34 Date: 7/7/2016 12:25 PM
8.2 Waste by Land Use
Mitigated
Waste Total CO2 CH4 I N20 I CO2e
Disposed
Land Use tans MT/yr
Condo/Townhous- 22.54 i. 4.5754 0.2704 0.0000 10.2538
e High Rise
Enclosed Parking 0 0.0000 0.0000 0.0000 0.0000
with Elevator
Total 4.5754 0.2704 0.0000 10.2538
9.0 Operational Off road
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Vegetation
543
CaIEEMod Version: CalEEMod.2013.2.2 Page 1 of 30 Date: 7/7/2016 12:26 PM
Newport Center Villas
Orange County, Summer
1.0 Project Characteristics
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Enclosed Parking with Elevator 126.00 Space 1.13 133,260.00 i 0
Condo/Townhouse High Rise 49.00 Dwelling Unit 0.77 163,260.00 140
1.2 Other Project Characteristics
Urbanization Urban Wind Speed(m/s) 2.2 Precipitation Freq(Days) 30
Climate Zone 8 Operational Year 2018
Utility Company Southern California Edison
CO2 Intensity 630.89 CH4 Intensity 0.029 N20 Intensity 0.006
(Ib/MWhr) (Ib/MWhr) (Ib/MWhr)
1.3 User Entered Comments & Non-Default Data
544
CalEEMod Version: CalEEMod.2013.2.2 Page 2 of 30 Date: 7/7/2016 12:26 PM
Project Characteristics-
Land Use- Floor Surface Area:296,520 sf
Construction Phase - Construction Duration: 2 years
Trips and VMT- 940 tons of demolition required; CalEEMod assumes 20 tons per truck, which results in 47 loads of demolition to be hauled away. As such, the
Project will require 94 two-way haul trips during demolition; added import of cement
Demolition -
Grading - Grading
Architectural Coating -
Vehicle Trips -Source: Institute of Transportation Engineers (ITE)Trip Generation Handbook (9th Edition, 2012)
Area Coating -
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Table Name Column Name Default Value New Value
tblArchitecturalCoati ng ConstArea_Nonresidential_Exterior 66,630.00 25,200.00
.....................g.....-4............................. i.......................--.
tblArchitecturalCoatin ConstArea_Nonresidential_Interior 199,890.00 75,600.00
..................g.........4-----------------------------r------------------------------F.......................--.
tblAreaCoatin Area-Nonresidential-Interior 199890 1 75600
""'....................'Y.............................-------------------------------F....................------
tblConstructionPhase NumDays 10.00 1 40.00
.......
'......".............y-----------------------------r-----------------------------i....................------
tblConstructionPhase NumDays 200.00 1 400.00
"'......................Y-............................+------------------------------F......................----
tblConstructionPhase NumDays 20.00 40.00
""'...................................................r------------------------------F.....................-----
tblConstructionPhase NumDays 4.00 30.00
""'....................'Y.............................-------------------------------F....................------
tblConstructionPhase NumDays 10.00 20.00
"""......"
.............y-----------------------------r-----------------------------i....................------
tblConstructionPhase NumDays 2.00 4.00
.............................Y.............................------------------------------i.......................--.
tblGrading MaterialExported 0.00 51,600.00
.............................. ----------------------------- 5---------- ---------4----.... ------.
tblLandUse LandUseSquareFeet 50,400.00 133,260.00
545
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tblLanclUse LandUseSquareFeet 49,000.00 163,260.00
------------ -----------._'--------4-------------'-•---------._.. ._....._._.•----•------•--
tblOffRoad Equipment LoadFactor 0.38 0.38
-----'•---------------'-'--__4-_.._"------------'.......... -----------------------------f.............._
tblOffRoadEquipment Load Factor 0.38 0.38
-----------------------------4------------------------------ -----------------
tblOffRoadEquipment Load Factor 0.38 1 0.38
'--'-------------------- ........ "-------'-'---- ------------------------------f'•'-•--••.._.._
tblOffRoadEquipment Load Factor 0.38 0.38
•------•-----•---------- -------------------_.-•------4------------------------------ ._....-----------------•--
tblOffRoadEquipment Load Factor 0.38 0.38
---._'................'-'---- .. -----------------------------f......._......_
tblOffRoadEquipment Load Factor 0.38 0.38
-----------------------------4-----------------------------4------------------------------ --------------------------
tblOffRoadEquipment OffRoadEquipmentType i Excavators
---•-------- .._'. ............' ------------------------------i .._..-._____--------._.._.
tblOffRoadEquipment OffRoadEquipmentType i Excavators
._......_'---'----------'---' ------------------------'---- ------------------------------i-_...---•--------------•--
tblOffRoadEquipment OffRoadEquipmentType i Excavators
------------------------------i .....................
..'_'
tblOffRoadEquipment OffRoadEquipmentType i Excavators
-----------------------------4----------------------------- ------------------------------i--------------------------
tblOffRoadEquipment OffRoadEquipmentType i Excavators
.......... "-------• -------- ------------•-• ------------------------------i ----..___......__._.._....
tblOffRoadEquipment OffRoadEquipmentType i Excavators
------------------ -----------—---- ------------------------------f--------------------------
tblProjectCharacteristics OperationalYear 2014 2018
---._" -------------------------------
tblTripsAndVMT HaulingTripNumber 93.00 94.00
-----------------------------4----------------------------------------------------------- --------------------------
tblTripsAndVMT HaulingTripNumber 0.00 2,000.00
-------•............•._�...........---........__. ------------------------------f'••-..___.._.._
tblVehicleTrips ST TR 7.16 4.31
------------------------- ._.....__.__-------_'-._._._'------------------------------ ...........
tblVehicleTrips SU TR 6.07 3.43
tblVehicleTrips WD—TR 6.59 4.18
2.0 Emissions Summary
�4�
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2.1 Overall Construction (Maximum Daily Emission)
Unmitigated Construction
ROG NOx CO I SO2 I Fugitive I Exhaust I PM10 I Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Year 16/day 16/day
2016 •• 6.7444 89.2440 64.2711 0.1846 8.9994 2.4708 11.4702 3.6192 2.2729 5.8920 ± 0.0000 • 18,654.48 18,654.48• 0.9731 0.0000 • 18,674.91
+ 09 09 48
i........--------------- ______
2017 •• 4.2741 30.9416 29.2952 0.0545 • 1.3087 1.6819 2.9905 • 0.3504 • 1.6020 • 1.9524 q 0.0000 •5,055.328 5,055.328• 0.8119 - 0.0000 ?5,072.377
y 4 4 2
r
.ri i i r i r r r r r r
n r r • w T Y
2018 •• 62.0707 � 27.1589 � 28.1505 � 0.0544 r 1.6404 � 1.4196 • 3.0600 • 0.4319 • 1.3543 • 1.7661 � 0.0000 •4,972.263�4,972.263- 0.7879 - 0.0000 ?4,988.809
y 3 3 7
Total •r 73.0891 147.3444 ' 121.7168 0.2935 11.9485 5.5723 r 17.5207 4.4014 r 5.2292 r 9.6306 0.0000 •28,682.07 28,682.07 r 2.5728 r 0.0000 r 28,736.10
11 25 25 17
Mitigated Construction
ROG NOx CO SO2 Fugitive Exhaust PM10 1 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 I CH4 N20 CO2e
PM10 PM70 Total PM2.5 PM2.5 Total
Year lb/day lb/day
2016 •r 6.7444 89.2440 64.2711 0.1846 r 8.9994 2.4708 • 11.4702 3.6192 r 2.2729 r 5.8920 0.0000 • 18,654.48 18,654.48 r 0.9731 r 0.0000 • 18,674.91
y 09 09 48
2017 •r 4.2741 30.9416 29.2952 0.0545 r 1.3087 - 1.6819 r 2.9905 • 0.3504 r 1.6020 r 1.9524 ± 0.0000 •5,055,328 5,055.328- 0.8119 - 0.0000 ?5,072.377
S 4 i 4 2
8 •• 62.07 27.1589 28.1505 0.0544 1.6404 1.4196 3.0600 • 0.4319 1.3543 1.7861 ± 0.0000 •4,972.263 4,972.263• 0.7879 - 0.0000 ?
201 07 4,988.809
+ 3 3 7
i
Total •r 73.0891 ' 147.3444 ' 121.7168 ' 0.2935 r 11.9485 ' 5.5723 • 17.5207 r 4.4014 r 5.2292 9.6306 1 0.0000 r 28,682.07' 28,682.07 r 2.5728 r 0.0000 •28,736.10
25 25 17
54
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ROG NOx CO 502 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 AO20ePM10 PM10 Total PM2.5 PM2.5 Total
Percent 0.00 0000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Reduction
�T�
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2.2 Overall Operational
Unmitigated Operational
ROG NOx CO I S02 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Area •• 19.6390 0.3732 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 ± 458.9790 • 889.3066 1,348.285• 1.3761 0.0312 • 1,386.840
+ 6 0
------------------------------------ i__ ______ _______ ______ ______ _
Y ......r T
Energy 0.0229 � 0.1958 � 0.0833 � 1.2500e- • � 0.0158 0.0158 • • 0.0158 0.0158 � 249.9382 � 249.9382 • 4.7900e-T4.5800e ?251.4593
003
•• i
003 003
_______ _______ _______ ______ -------r------ -------w______T_______Y_______r______-_______r______r____
__t___Mo_bi_le____n__0 ___9_
1.4866 7.1414 0.0213 1.5248 0.0223 • 1.5472 • 0.4069 • 0.0206 • 0.4275 ± • 1,730.848 1,730.848 0.0630 • 1,732.172
y 3 3 1
L
Total •• 20.2718 2.0556 35.9384 0.0619 1.5248 3.8035 5.3283 0.4069 3.8011 4.2080 1 458.9790 •2,870.093 1 3,329.072• 1.4439 • 0.0357 •3,370.471
11 2 2 4
Mitigated Operational
ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 I CH4 N20 CO2e
PM10 PM70 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Area •• 19.6390 0.3732 28.7136 0.0394 . 3.7653 • 3.7653 • 3.7647 • 3.7647 456.9790 889.3066 1,348.285• 1.3761 . 0.0312 • 1,386.840
y 6 0
Energy 0.0229 0.1958 0.0833 1.2500e- • 0.0158 . 0.0158 . . 0.0158 . 0.0158 ± 249.9382 249.9382 r4.7900e-r4.5800e ?251.4593
003 y 003 003
Mobile •• 0.6099 1.4866 7.1414 0.0213 1.5248 0.0223 1.5472 • 0.4069 0.0206 0.4275 ± •1,730.848 1,730.848• 0.0630 T ?1,732.172
+ 3 3 1
L
Total •• 20.2718 ' 2.0556 ' 35.9384 ' 0.0619 , 1.5248 ' 3.8035 ' 5.3283 , 0.4069 3.8011 ' 42080 1 458.9790 •2,870.093' 3,329.072• 1.4439 • 0.0357 ,3,370.471
2 2 4
-T n'
CaIEEMod Version: CalEEMOd.2013.2.2 Page 7 of 30 Date: 7/7/2016 12:26 PM
ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 Total CO2 CH4 I N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Percent 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1 0.00 0.00 1 0.00 1 0.00 1 0.00 0.00
Reduction
3.0 Construction Detail
Construction Phase
Phase Phase Name Phase Type Start Date End Date Num Days Num Days Phase Description
Number Week
1 I
Demolition :Demolition 6/1/2016 ;7/26/2016 5; 40�
2 •Site Preparation :Site Preparation -7/27/2016 ;8/1/2016 ; 5' 4:
3 •Grading :Grading 8/2/2016 :9/12/2016 5: 30:
4 •Building Construction :Building Construction 9/13/2016 :3/26/2018 5: 400;
5 :Paving :Paving 3/27/2018 ;4/23/2018 5: 20:
"""' _ ____________--------"
6 •Architectural Coating :Architectural Coating 4/24/2018 6/18/2018 5. 40•
Acres of Grading (Site Preparation Phase): 2
Acres of Grading (Grading Phase): 11.25
Acres of Paving: 0
Residential Indoor: 330,602; Residential Outdoor: 110,201; Non-Residential Indoor: 75,600; Non-Residential Outdoor: 25,200 (Architectural
Coating —sgft)
OffRoad E ui ment
550
CaIEEMod Version: CalEEMOd.2013.2.2 Page 8 of 30 Date: 7/7/2016 12:26 PM
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition •Concrete/Industrial Saws 1 i 8.00: 81: 0.73
____________________________p___________________________H----------------a-------------H_____________-____;--------------
Demolition :Rubber Tired Dozers 1i 8.00: 255' 0.40
-------------------------------------------------------------------------i------------ ----- ----- --------------
Demolition •Tractors/Loaders/Backhoes 31 8.00- 97: 0.37
--------------------------------------------------------H______________-1i__________B.00 F_____________-_174 ___________--
Site PreparationGraders0.41
-------------------------------------------------------- -------- -------
Site Preparation :Rubber Tired Dozers t 1 7.00: 255' 0.40
--------------------------------------------------------H________________i-------------H_____________-____ --------------
Site Preparation •Tractors/Loaders/Backhoes 11 8.00: 97:; 0.37
Grading "
------ -------------""'__Graders_____________________I-----------------�''________6.00~--- -174 --------------
0.41
Grading :Rubber Tired Dozers 1� 6.00 255' 0.40
--------------------------------------------------------I ----------------i H----- -----
Grading •Tractors/Loaders/Backhoes ti 7.00: 97: 0.37
--------------------------------------------------------H________________i-------------H_____________-____ ______________
Building Construction :Cranes 11 6.00: 226'; 0.29
-------------------------------------------------------------------------i H----- -----
Building Construction :Forklifts 11 6.00: 89: 0.20
-------------------------------------------------------------------------i------------ H---- ---- --------------
Building Construction :Generator Sets 1! 8.00: 84' 0.74
--------------------------------------------------------H----------------i H----- -----
Building Construction •Tractors/Loaders/Backhoes I ti 6.00: 97: 0.37
------------- ----- -
--------------------- --------------- IIF46�
------------- _____________--- --------------
Building Construction1s3 0.45
--------------------------------------------------------H----------------i-------------H----- ----- --------------
Paving :Cement and Mortar Mixers 11 6.00: 9: 0.56
-------------------------------------------------------------------------i------------ H---- ---- --------------
Paving •Pavers 1i 6.00- 125' 0.42
--------------------------------------------------------I ----------------i-- H----- ---- --------------
-
Paving :Paving Equipment ti 8.00, 130' 0.36
Paving -----------------------Rollers --------------------- ---------------- 1-------------F----------------80 --------------
0.38
-------------------------------------------------------- -----------------i------------ H----- ----- --------------
Paving •Tractors/Loaders/Backhoes 11 8.00: 97: 0.37
-------------------------------------------------------------------------i------------ H---- ---- --------------
Architectural Coating :Air Compressors 11 6.00: 78' 0.48
Demolition ____________________•Excavators __________________H_______________2�__________B.OO162 ___________0.38
Site Preparation_________________1 Excavators---------------------------H_______________2I__________B.00- 162 --------------___________---
0.38
Grading ______________________•Excavators2--------------------------- ----------------
- 162 --------------___________---
0.38
-------------------------------------------------------- -----------------i------------ H---- ---- --------------
Building Construction :Excavators 21 8.00- 162: 0.38
_______________________• __________________H_______________ i__________B.OO
PavingExcavators2
F162 ___________0.38
Architectural Coating :Excavators 2 8.00: 162: 0.38
5�1
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Trips and VMT
Phase Name Offroad Equipment Worker Trip Vendor Trip Hauling Trip Worker Trip Vendor Trip iHaulingTrip Worker Vehicle Vendor I Hauling
Count Number Number Number Length Length Length Class Vehicle Class Vehicle Class
Demolition 71 18.00• 0.00: 94.00• 14.70 6.90: 20.00-LD Mix -HDT_Mix jHHDT
Site Preparation 51 13.00• 0.00: 0.00• 14.701 6.90: 20.00:LD_Mix :HDT_Mix 1HHDT
________________• 1 _________t__________;__________}____________1----------4----------� _____________� 1
Grading 51 13.00• 0.00: 6,450.00• 14.701 6.90: 20.00-LD Mix -HDT_Mix 1HHDT
1
________________• 1 _________t__________;__________}____________1----------4----------� ____________� 1
Building Construction 91 91.00• 27.00: 2,000.00• 14.701 6.90: 20.00:LD_Mix HDT_Mix 1HHDT
Paving 71 18.00• 0.00: 0.00• 14.701 6.90; 20.00-LD Mix :HDT_Mix 1HHDT
Architectural Coati ng 3• 18.00• 0.00• 0.00• 14.70• 6.90- 20.00-LD Mix :HDT_Mix •HHDT
3.1 Mitigation Measures Construction
3.2 Demolition -2016
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust 0.5029 0.0000 0.5029 0.0761 0.0000 0.0761 A 0.0000 0.0000
_------.. 1 1 1 1 , 1 , ______i_______, _______J_______• i _______ _______ _______
M1 7 T- 1 • 1 • i i T ♦ 1
r T
Off-Road 3.6868 37.1639 28.3891 • 0.0351 2.1828 2.1828 2.0359 2.0359 i •3,592.464 3,592.464• 0.9622 3,612.671
y 9 9 2
Total 3.6868 37.1639 28.3891 0.0351 0.5029 2.1828 2.6856 0.0761 2.0359 2.1121 •3,592.464'3,592.464 1 0.9622 ' ' 3,612.671
9 9 2
CaIEEMod Version: CalEEMOd.2013.2.2 Page 10 of 30 Date: 7/7/2016 12:26 PM
3.2 Demolition - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Iblday
Hauling 0.0429 0.6476 0.4700 1.7300e- ' 0.0409 9.7400e- ' 0.0507 0.0112 8.9600e- ' 0.0202 + 174.2148 ' 174.2148 ' 1.2400e- ' 174.2408
003 003 003 j 003
_.._ ___..'•______ ______-____0 0000-"-"""""'--'----- "--"'T"'-'--y -'--""'-"""T
Vendor •• 0.0000 ' 0.0000 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 0.0000 ' 0.0000 0.0000 0.0000 0.0000 ' 0.0000 ' ' 0.0000
...........^---------------------'-------'-------'-------'-------'-------'-----------------------'_______'_______' i
------------------------
Worker •' 0.0625 ' 0.0807 ' 0.9882 ' 2.4400e- ' 0.2012 ' 1.4100e- ' 0.2026 ' 0.0534 ' 1.3000e- ' 0.0547 204.2283 ' 204.2283 ' 9.6000e- ' ' 204.4300
003 003 003 003
Total 0.1064 0.7282 1.4581 4.1700e- ' 0.2421 0.0112 ' 0.2533 0.0646 0.0103 0.0748 378.4431 378.4431 0.0108 378.6708
003
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 0.5029 ' 0.0000 ' 0.5029 ' 0.0761 0.0000 ' 0.0761 0.0000 ' 0.0000
+
6ff-Road •• 3.6668 ' 37.1639 r 28.3891 • 0.0351 2.1828 • 2.1828 2.0359 2.0359 0.0000 •3,592.464-3,592.464 r 0.9622 3.612.671
9 9 2
Total 3.6868 37.1639 28.3891 , 0.0351 ' 0.5029 1 2.1828 , 2.6856 0.0761 ' 2.0359 2.1121 0.0000 •3,592.464 1 3,592.464, 0.9622 ' 3,612.671
9 9 2
SJ�3
CaIEEMod Version: CalEEMOd.2013.2.2 Page 11 of 30 Date: 7/7/2016 12:26 PM
3.2 Demolition - 2016
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Iblday
Hauling 0.0429 0.6476 0.4700 1.7300e- 0.0409 9.7400e- 0.0507 0.0112 8.9600e- 0.0202 + 174.2148 174.2148 1.2400e- 174.2408
003 003 003 j 003
+ _
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 • 0.0000 0.0000 • 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
Worker •• 0.0625 • 0.0807 • 0.9882 • 2.4400e- r 0.2012 1.4100e- r 0.2026 0.0534 r 1.3000e- 0.0547 204.2283 204.2283 r 9.6000e- 204.4300
003 003 003 003
Total 0.1054 0.7282 1.4581 4.1700e- • 0.2421 0.0112 0.2533 0.0646 ' 0.0103 0.0748 378.4431 378.4431 • 0.0108 378.6708
003
3.3 Site Preparation - 2016
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 5.7996 0.0000 r 5.7996 2.9537 0.0000 2.9537 0.0000 r 0.0000
+
Off-Road •• 3.2230 • 34.6778 r 23.4056 • 0.0278 1.8367 • 1.8367 1.6898 1.6898 2,886.422 2,886.422 r 0.8707 2,904.706
6 6 2
Total 3.2230 34.6778 ' 23.4056 • 0.0278 ' 5.7996 1 1.8367 • 7.6363 2.9537 ' 1.6896 1 4.6435 • •2,886.422 j 2,886.422• 0.8707 j '2,904.706
6 6 2
J�J�-T
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 12 of 30 Date: 7/7/2016 12:26 PM
3.3 Site Preparation - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.9000 0.0000 0.0000 0.0000 ; 0.0000 0.0000 - 0.0000 0.0000
r r r r i r i r i
i
n r r r r i r i i
n w w • w •� • T Y
• t
Worker •• 0.0451 • 0.0583 • 0.7137 • 1.7600e- • 0.1453 � 1.0200e- � 0.1463 � 0.0365 � 9.4000e- � 0.0395 ± 147.4982 � 147.4982 � 6.9400e- � � 147.6439
003 003 004 003
Total 0.0451 0.0583 0.7137 1.7600e- , 0.1453 1.0200e- , 0.1463 0.0385 9.4000e- 0.0395 147.4982 147.4982 , 6.9400e- 147.6439
003 003 004 003
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 5.7996 0.0000 5.7996 2.9537 0.0000 2.9537 0.0000 0.0000
Off-Road •• 3.2230 • 34.6778 r 23.4056 • 0.0278 1.8367 • 1.8367 1.6898 1.6898 0.0000 •2,886.422 2,886.422 r 0.8707 2,904.706
6 6 2
Total 3.2230 34.6778 ' 23.4056 ' 0.0278 ' 5.7996 1 1.8367 1 7.6363 2.9537 ' 1.6898 4.6435 0.0000 •2,886.422 2,886.422, 0.8707 '2,904.706
6 6 2
J�SJr
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3.3 Site Preparation - 2016
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 6.0000 0.0000 0.0000 0.0000 i 0.0000 0.0000 - 0.0000 0.0000
i
n w w • w •, • T Y • r
• t
Worker •• 0.0451 • 0.0583 • 0.7137 • 1.7600e- r 0.1453 1.0200e- r 0.1463 0.0365 9.4000e- 0.0395 ± 147.4982 147.4982 r 6.9400e- 147.6439
003 003 004 003
Total 0.0451 0.0583 0.7137 1.7600e- 0.1453 1.0200e- 0.1463 0.0385 9.4000e- 0.0395 147.4982 147.4982 • 6.9400e- 147.6439
003 003 004 003
3.4 Grading - 2016
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 5.1088 0.0000 r 5.1088 2.5551 0.0000 2.5551 0.0000 r 0.0000
_______ ______ _______ ______ _______ _______ _______ ______ ______ 1 _ ___________ _______ _______ _______
Off-Road •• 2.7710 r 29.9421 r 20.5615 • 0.0247 1.5789 • 1.5789 1.4526 1.4526 2,568.182 2,568.182 r 0.7747 2,584.450
2 2 0
Total 2.7710 29.9421 ' 20.5615 • 0.0247 • 5.1088 1 1.5789 • 6.6877 2.5551 1.4526 4.0077 •2,568.182 2,568.182 0.7747 '2,584.450
2 2 0
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3.4 Grading - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive I Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 P! Total
Category Ib/day Ib/day
Hauling 3.9283 59.2436 42.9960 0.1582 3.7453 0.8909 4.6362 1.0256 0.8194 1.8449 • 15,938.80 15,938.80 0.1133 15,941.17
05 05 91
•'
----
_______-_______'
J _______
Vendor •• 0.0000 ' 0.0000 0.0000 ' 0.0000 ' 0.0000 0.0000 ' 0.0000 0.0000 ' 0.0000 0.0000 0.0000 0.0000 ' 0.0000 0.0000
Worker 0.0451 ' 0.0583 ' 0.7137 ' 1.7600e- ' 0.1453 - 1.0200e- ' 0.1463 - 0.0385 ' 9.4000e- 0.0395 147.4982 - 147.4982 ' 6.9400e- 147.6439
003 003 004 003
Total 3.9734 59.3019 43.7096 0.1599 ' 3.8906 0.8919 4.7825 1.0641 0.8203 1.8844 • 16,086.29 16,086.29, 0.1202 16,088.82
87 87 30
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 5.1088 0.0000 ' 5.1088 2.5551 0.0000 2.5551 0.0000 ' 0.0000
_______-------------------------------------- _______ ______ ______ 1 _ ___________ _______ _______ _______
Off-Road •• 2.7710 r 29.9421 r 20.5615 • 0.0247 1.5789 • 1.5789 1.4526 1.4526 0.0000 •2,568.182 2,568.182 r 0.7747 2,584.450
2 2 0
Total 2.7710 29.9421 , 20.5615 ' 0.0247 , 5.1088 1 1.5789 1 6.6877 2.5551 1.4526 4.0077 0.0000 •2,568.182 2,568.182, 0.7747 '2,584.450
2 2 0
-557
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 15 of 30 Date: 7/7/2016 12:26 PM
3.4 Grading - 2016
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive I Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 P! Total
Category Ib/day Ib/day
mmmmw _
Hauling 3.9283 59.2436 42.9960 0.1582 3.7453 0.8909 4.6362 1.0256 0.8194 1.8449 i • 15,938.80 15,938.80 0.1133 15,941.17
05 05 91
J
•' __r______ _______r______-_______-_______ _______' ____ ,
Vendor •• 0.0000 ' 0.0000 0.0000 ' 0.0000 ' 0.0000 0.0000 ' 0.0000 � 0.0000 ' 0.0000 � 0.0000 0.0000 � 0.0000 ' 0.0000 � � 0.0000
Worker 0.0451 ' 0.0583 ' 0.7137 ' 1.7600e- ' 0.1453 - 1.0200e- ' 0.1463 - 0.0385 ' 9.4000e- 0.0395 147.4982 - 147.4982 ' 6.9400e- 147.6439
003 003 004 003
Total 3.9734 59.3019 43.7096 0.1599 ' 3.8906 0.8919 4.7825 1.0641 0.8203 1.8844 • 16,086.29 16,086.29, 0.1202 16,088.82
87 87 30
3.5 Building Construction -2016
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road 4.0718 ' 29.4518 ' 21.5985 • 0.0326 ' 1.8038 • 1.8038 1.7207 1.7207 •3,152.278 3,152.278' 0.7833 3,168.728
6 6 2
J
Total 4.0718 29.4518 21.5985 0.0326 1.8038 1.8038 1.7207 1.7207 •3,152.278 3,152.277[77;37�7 3,168.728
6 6 2
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 16 of 30 Date: 7/7/2016 12:26 PM
3.5 Building Construction - 2016
Unmitigated Construction Off-Site
ROG NOx CO SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0914 1.3778 0.9999 3.6800e- 0.3557 0.0207 0.3764 0.0898 0.0191 0.1088 + 370.6698 370.6698 2.6300e- 370.7251
003 j 003
.• ,
Vendor •• 0.2361 • 2.3356 2.7597 • 5.8400e- • 0.1687 0.0370 • 0.2057 0.0481 • 0.0340 0.0821 585.5190 585.5190 • 4.1600e- 585.6063
003 003
Worker •• 0.3157 • 0.4079 • 4.9957 • 0.0124 r 1.0172 7.1100e- r 1.0243 0.2698 6.5500e- 0.2763 • 1,032.487 1,032.487 r 0.0486 1,033.507
003 003 4 4 0
Total 0.6431 4.1212 8.7553 0.0219 • 1.5416 0.0648 1.6064 0.4076 0.0596 0.4672 • 1,988.676 1,988.676• 0.0553 1,989.838
1 1 4
Mitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road 4.0718 • 29.4518 • 21.5985 • 0.0326 • 1.8038 • 1.8038 1.7207 1.7207 0.0000 •3,152.278 3,152.278 r 0.7833 3,168.728
+ 6 6 2
Total 4.0718 29.4518 21.5985 0.0326 1.8038 1.8038 1.7207 1.7207 0.0000 •3,152.278 3,152.278• 0.7833 3,168.728
6 6 2
�s9
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 17 of 30 Date: 7/7/2016 12:26 PM
3.5 Building Construction - 2016
Mitigated Construction Offsite
ROG NOx CO SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0914 1.3778 0.9999 3.6800e- 0.3557 0.0207 0.3764 0.0898 0.0191 0.1088 + 370.6698 370.6698 2.6300e- 370.7251
003 j 003
., ,
Vendor •• 0.2361 • 2.3356 2.7597 • 5.8400e- • 0.1687 0.0370 • 0.2057 0.0481 • 0.0340 0.0821 585.5190 585.5190 • 4.1600e- 585.6063
003 003
Worker •• 0.3157 • 0.4079 • 4.9957 • 0.0124 r 1.0172 7.1100e- r 1.0243 0.2698 6.5500e- 0.2763 • 1,032.487 1,032.487 r 0.0486 1,033.507
003 003 4 4 0
Total 0.6431 4.1212 8.7553 0.0219 • 1.5416 0.0648 1.6064 0.4076 0.0596 0.4672 • 1,988.676 1,988.676• 0.0553 1 1,989.838
1 1 4
3.5 Building Construction - 2017
Unmitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 I CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road 3.6826 • 27.1827 • 21.1873 • 0.0326 • 1.6229 • 1.6229 1.5478 1.5478 •3,122.222 3,122.222 r 0.7602 3,138.186
+ 2 2 0
Total 3.6826 27.1827 21.1873 0.0326 1.6229 1 1.6229 1.5478 1.5478 •3,122.222 3,122.222• 0.7602 3,138.186
2 2 0
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 18 of 30 Date: 7/7/2016 12:26 PM
3.5 Building Construction - 2017
Unmitigated Construction Off-Site
ROG NOx I CO I S02 I Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Iblday
Hauling 0.0862 1.2636 0.9549 3.6700e- 0.1227 0.0190 0.1417 0.0326 0.0174 0.0500 + 364.5538 364.5538 2.5800e- 364.6081
003 j 003
+ _
Vendor •• 0.2178 • 2.1249 2.5963 • 5.8300e- • 0.1688 0.0330 • 0.2018 0.0481 • 0.0304 0.0785 • 575.9889 575.9889 • 4.0300e- 576.0734
003 i 003
n 7- w • w •, • T Y • i r
• � t
Worker •• 0.2874 • 0.3704 • 4.5568 • 0.0124 r 1.0172 6.9500e- r 1.0241 0.2698 6.4200e- 0.2762 992.5635 992.5635 r 0.0451 993.5097
003 003 +
+
Total 0.5914 3.7589 8.1079 0.0219 • 1.3087 0.0590 1.3676 0.3504 0.0542 0.4047 • 1,933.106 1,933.106• 0.0517 1,934.191
11 2 2 2
Mitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 3.6826 • 27.1827 • 21.1873 • 0.0326 • 1.6229 • 1.6229 1.5478 1.5478 0.0000 •3,122.222 3,122.222 r 0.7602 3,138.186
+ 2 2 0
Total 3.6826 27.1827 21.1873 0.0326 1.6229 1 1.6229 1.5478 1.5478 0.0000 •3,122.222 3,122.222• 0.7602 3,138.186
2 2 0
S�1
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 19 of 30 Date: 7/7/2016 12:26 PM
3.5 Building Construction - 2017
Mitigated Construction Offsite
ROG NOx I CO I S02 I Fugitive Exhaust PM10 I Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Iblday Iblday
Hauling 0.0862 1.2636 0.9549 3.6700e- 0.1227 0.0190 0.1417 0.0326 0.0174 0.0500 + 364.5538 364.5538 2.5800e- 364.6081
003 j 003
+ _
Vendor •• 0.2178 • 2.1249 2.5963 • 5.8300e- • 0.1688 0.0330 • 0.2018 0.0481 • 0.0304 0.0785 • 575.9889 575.9889 • 4.0300e- 576.0734
003 i 003
w • w •, • T Y • i
•-----------------------
Worker •• 0.2874 • 0.3704 • 4.5568 • 0.0124 1.0172 6.9500e- 1.0241 0.2698 6.4200e- 0.2762 992.5635 992.5635 0.0451 993.5097
003 003 +
+
Total 0.5914 3.7589 8.1079 0.0219 • 1.3087 0.0590 1.3676 0.3504 0.0542 0.4047 • 1,933.106 1,933.106• 0.0517 1,934.191
11 2 2 2
3.5 Building Construction -2018
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 I CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 3.1785 • 23.6975 • 20.5864 • 0.0326 • 1.3627 • 1.3627 1.3019 1.3019 •3,092.219 3,092.219 0.7393 : 3,107.743
+ 2 2 4
+
Total 3.1785 23.6975 20.5864 0.0326 1.3627 1.3627 1.3019 1.3019 •3,092.219 3,092.219• 0.7393 3,107.743
2 2 4
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 20 of 30 Date: 7/7/2016 12:26 PM
3.5 Building Construction - 2018
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0836 1.1729 0.9263 3.6700e- 0.4545 0.0190 0.4735 0.1140 0.0174 0.1315 + 358.4563 358.4563 2.6200e- 358.5113
003 j 003
+ _
Vendor •• 0.2040 • 1.9505 2.4646 • 5.8200e- • 0.1688 0.0311 • 0.1999 0.0481 • 0.0286 0.0767 • 566.2100 566.2100 • 4.000Oe- 566.2941
003 i 003
w • w • • T Y • •
tn 22 033 955.379 955.3779 r 0.0421
956.2609Worker 8
003 003
Total 0.6499 3.4614 7.5641 0.0218 • 1.6404 0.0570 1.6974 0.4319 ' 0.0524 0.4843 • 1,880.044 1,880.044• 0.0487 1,881.066
1 1 2
Mitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 3.1785 • 23.6975 • 20.5864 • 0.0326 • 1.3627 • 1.3627 1.3019 1.3019 0.0000 •3,092.219 3,092.219 r 0.7393 : 3,107.743
+ 2 2 4
+
Total 3.1785 23.6975 20.5864 0.0326 1.3627 1.3627 1.3019 1.3019 0.0000 •3,092.219 3,092.219• 0.7393 3,107.743
2 2 4
563
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 21 of 30 Date: 7/7/2016 12:26 PM
3.5 Building Construction - 2018
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0836 1.1729 0.9263 3.6700e- 0.4545 0.0190 0.4735 0.1140 0.0174 0.1315 + 358.4563 358.4563 2.6200e- 358.5113
003 j 003
+ _
Vendor •• 0.2040 • 1.9505 2.4646 • 5.8200e- • 0.1688 0.0311 • 0.1999 0.0481 • 0.0286 0.0767 • 566.2100 566.2100 • 4.000Oe- 566.2941
003 i 003
n w w • w •, • T Y • r
• t
Worker •• 0.2624 • 0.3380 • 4.1732 • 0.0124 r 1.0172 � 6.8700e- r 1.0240 � 0.2698 r 6.3600e- � 0.2761 ± 955.3779 � 955.3779 r 0.0421 � � 956.2609
003 003
Total 0.6499 3.4614 7.5641 0.0218 • 1.6404 0.0570 1.6974 0.4319 ' 0.0524 0.4843 • 1,880.044 1,880.044• 0.0487 1,881.066
11 1 1 2
3.6 Paving - 2018
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 1.6011 • 16.6884 • 15.6205 • 0.0240 0.9121 r 0.9121 0.8400 0.8400 •2,397.381 2,397.381 r 0.7385 2,412.889
+ 4 4 4
Paving •• 0.0000 0.0000 r 0.0000 0.0000 0.0000 0.0000 0.0000
Total 1.6011 • 16.6884 ' 15.6205 • 0.0240 0.9121 • 0.9121 ' 0.8400 0.8400 •2,397.381 2,397.381 • 0.7385 '2,412.889
4 4 4
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 22 of 30 Date: 7/7/2016 12:26 PM
3.6 Paving - 2018
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 - 0.0000 0.0000
i
n w w • w •, • T Y • r
• 4 t
Worker •• 0.0519 • 0.0669 • 0.8255 • 2.4400e- r 0.2012 1.3600e- r 0.2026 0.0534 r 1.2600e- 0.0546 ± 188.9759 188.9759 r 8.3200e- 189.1505
003 003 003 003
Total 0.0519 0.0669 0.8255 2.4400e- • 0.2012 1.3600e- 0.2026 0.0534 1.2600e. 0.0546 188.9759 188.9759 8.3200e- 189.1505
003 003 003 003
Mitigated Construction On-Site
ROG NOx I CO SO2 I Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road 1.6011 • 16.6884 • 15.6205 • 0.0240 0.9121 r 0.9121 0.8400 0.8400 0.0000 •2,397.381 2,397.381 r 0.7385 2,412.889
4 4 4
_______ ______ _______ _______ _______ ______ _______ ______ ______ 1 _ ___________ _______ _______ ---------------
Paving
______ _ ____Paving •• 0.0000 0.0000 r 0.0000 0.0000 0.0000 0.0000 0.0000
Total 1.6011 • 16.6884 ' 15.6205 • 0.0240 0.9121 • 0.9121 ' 0.8400 0.8400 0.0000 •2,397.381 2,397.381 • 0.7385 '2,412.889
4 4 4
rJ�J.rJ
CaIEEMod Version: CalEEMOd.2013.2.2 Page 23 of 30 Date: 7/7/2016 12:26 PM
3.6 Paving - 2018
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 - 0.0000 0.0000
i
n w w • w •, • T Y • r
• 4 t
Worker •• 0.0519 • 0.0669 • 0.8255 • 2.4400e- r 0.2012 1.3600e- r 0.2026 0.0534 r 1.2600e- 0.0546 ± 188.9759 188.9759 r 8.3200e- 189.1505
003 003 003 003
Total 0.0519 0.0669 0.8255 2.4400e- • 0.2012 1.3600e- 0.2026 0.0534 1.2600e. 0.0546 188.9759 188.9759 8.3200e- 189.1505
003 003 003 003
3.7 Architectural Coating - 2018
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Archit.Coating n 61.1243 • 0.0000 r 0.0000 0.0000 0.0000 0.0000 r 0.0000
_______ ______ _______ _______ _______ _______ _______ --------------1 _ ___________ _______ _______ _______
Off-Road •• 0.8945 • 8.3860 r 8.6050 • 0.0136 0.4600 • 0.4600 • 0.4352 0.4352 • 1,352.254 1,352.254 r 0.3601 1,359.816
2 2 2
Total 62.0188 8.3860 ' 8.6050 • 0.0136 1 0.4600 • 0.4600 1 ' 0.4352 1 0.4352 • • 1,352.254 j 1,352.254• 0.3601 j ' 1,359.816
2 2 2
Sro FJ
CaIEEMod Version: CalEEMOd.2013.2.2 Page 24 of 30 Date: 7/7/2016 12:26 PM
3.7 Architectural Coating - 2018
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 7otaICO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 - 0.0000 0.0000
7
n w w • w •, • T Y ,
• t
Worker •• 0.0519 • 0.0669 • 0.8255 • 2.4400e- 0.2012 1.3600e- 0.2026 0.0534 1.2600e- 0.0546 ± 188.9759 188.9759 - 8.3200e- 189.1505
003 003 003 003
Total 0.0519 0.0669 0.8255 2.4400e- ' 0.2012 1.3600e- ' 0.2026 0.0534 1.2600e. 0.0546 188.9759 188.9759 8.3200e- 189.1505
003 003 003 003
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Arent.Coating n 61.1243 • 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road •• 0.8945 • 8.3860 r 8.6050 • 0.0136 0.4600 0.4600 0.4352 0.4352 0.0000 • 1,352,254 1,352.254 r 0.3601 1,359.816
2 2 2
Total 62.0188 8.3860 ' 8.6050 ' 0.0136 1 0.4600 , 0.4600 1 ' 0.4352 1 0.4352 • 0.0000 • 1,352.254 j 1,352.254, 0.3601 ' 1,359.816
2 2 2
CaIEEMod Version: CalEEMOd.2013.2.2 Page 25 of 30 Date: 7/7/2016 12:26 PM
3.7 Architectural Coating - 2018
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 - 0.0000 0.0000
7
• 4 t
Worker •• 0.0519 • 0.0669 • 0.8255 • 2.4400e- 0.2012 1.3600e- 0.2026 0.0534 1.2600e- 0.0546 ± 188.9759 188.9759 - 8.3200e- 189.1505
003 003 003 003
Total 0.0519 0.0669 0.8255 2.4400e- ' 0.2012 1.3600e- ' 0.2026 0.0534 1.2600e. 0.0546 188.9759 188.9759 8.3200e- 189.1505
003 003 003 003
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
ROG NOx CO S02 I Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Mitigated 0.6099 1.4866 7.1414 0.0213 1.5248 0.0223 1.5472 0.4069 0.0206 0.4275 ! • 1,730.848 1,730.848 0.0630 1,732.172
3 3 1
___________•'______T______T______T______T______T______T______T__ T______
Unmitigated •• 0.6099 1.4866 7.1414 0.0213 1.5248 0.0223 1.5472 0.4069 0.0206 0.4275 • 1,730.848 1,730.848• 0.0630 1,732.172
3 3 1
J��O 8
CaIEEMod Version: CalEEMod.2O13.2.2 Page 26 of 30 Date: 7/7/2016 12:26 PM
4.2 Trip Summary Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use WeekdaySaturday ISunday Annual VMT Annual VMT
Condo/Townhouse High Rise 204.82 211.19 i 168.07 685,071 685,071
Enclosed Parkin with Elevator 0 00 0.00 i 0 00
Total 204.82 211.19 168.07 685,071 685,071
4.3 Trip Type Information
Miles Trip% Trip Purpose%
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Condo/Townhouse High Rise 14.70 5.90 8.70 40.20 19.20 i 40.60 86 11 3
....................... ..........r_________ __________ ________T_________�___________,- ----------------------------------------
Enclosed Parking with Elevator• 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
0.510011• 0.056836• 0.192178• 0.151564 0.041643 0.005905 0.015642• 0.015146 0.001440 0.002149• 0.004721• 0.000504 0.002262
�.g�Vg[VYDeta i l
Historical Energy Use: N
5.1 Mitigation Measures Energy
SCJ°
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 27 of 30 Date: 7/7/2016 12:26 PM
ROG NOx CO I S02 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
NaturalGas 0.0229 0.1958 0.0833 1.2500e- 0.0158 0.0158 0.0158 - 0.0158 + 249.9382 249.9382 4.7900e- 4.5800e- 251.4593
Mitigated003 003 003
J _
..
NaturalGas •• 0.0229 0.1958 0.0833 1.2500e- 0.0158 0.0158 0.0158 0.0158 '249.9382T 249.9382Y 4.7900e-T 4.5800e-Y 251.4593
Unmitigated 003 003 003
5.2 Energy by Land Use - NaturalGas
Unmitigated
NaturalGa ROG NOx CO 502 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 Total CO2 CH4 1120 CO2e
s Use PM10 PM10 Total PM2.5 PM2.5 Total
Land use kBTU/yr Ib/day Ib/day
Enclosed Parking 0 b 0.0000 • 0.0000 0.0000 r x0000 0.0000 0.0000 0.0000 • 0.0000 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
with Elevator
_____ f. _______ _______ _______ _______ _______ _______ _______ ---------------i______________ _______ _______ _____ ______
CondolTownhous 2124.47 0.0229 0.1958 0.0833 1.2500e- 0.0158 0.0158 0.0158 0.0158 249.9382 249.9382 4.7900e- 4.5800e- 251.4593
e High Rise 003 + 003 003
Total 0.0229 0.1958 0.0833 1.2500e• ' 0.0158 0.0158 0.0158 0.0158 249.9382 ' 249.9382 ' 4.7900e. 4.5800e- 251.4593
003 003 003
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 28 of 30 Date: 7/7/2016 12:26 PM
5.2 Energy by Land Use - NaturalGas
Mitigated
NaturalGa ROG NOx I CO I S02 I Fugitive Exhaust PM10 I Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 I CH4 N20 CO2e
s Use PM10 PM10 Total PM2.5 PM2.5 Total
Land Use kBTU/yr Ib/day Ib/day
Condo/Townhous- 2.12447 1• 0.0229 0.1958 0.0833 1.2500e. ' 0.0158 0.0158 0.0158 0.0158 t 249.9382 ' 249.9382 ' 4.7900e- ' 4.5800e- ' 251.4593
e High Rise is 003 j 003 003
1. J
Enclosed Parking 0 6 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 ' ' 0.0000 0.0000 ' 0.0000 ' 0.0000 A. 0.0000 0.0000 ' 0.0000 ' 0.0000 0.0000
with Elevator
6 �
Total 0.0229 ' 0.1958 ' 0.0833 ' 1.2500e- ' 1 0.0158 ' 0.0158 ' 1 0.0158 ' 0.0158 249.9382 ' 249.9382 ' 4.7900e- 1 4.58DOe- 251.4593
003 003 OD3
6.0 Area Detail
6.1 Mitigation Measures Area
ROG I NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Mitigated 19.6390 0.3732 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 ! 458.9790 889.3066 ' 1,348.285 1.3761 0.0312 ' 1,386.840
6 0
E
Unmitigated •' 19.6390 0.3732 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 •458.9790 ' 889.3066 ' 1,348.285' 1.3761 0.0312 ' 1,386.840
6 0
�1
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 29 of 30 Date: 7/7/2016 12:26 PM
6.2 Area by SubCategory
Unmitigated
ROG NOx CO SO2 Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 To[al PM2.5 PM2.5 Total
SubCategory Ib/day Ib/day
Architectural •• 0.8014 0.0000 0.0000 0.0000 0.0000 ± 0.0000 0.0000
Coating +
n Y Y Y Y Y Y
Consumer •• 5.8711 0.0000 0.0000 • 0.0006 0.0000 0.0000 T ?•0.0000
Products i
------------------------, w w w w T Y ------------------------------
Hearth •• 12.8398 0.3258 24.6295 0.0392 3.7430 • 3.7430 • • 3.7424 • 3.7424 ±458.9790 • 882.0000 1,340.979• 1.3688 • 0.0312 ?1;379.380
+ a 2
------- -------------- --------------------------------------------------- _______ ______
iii w______
w t_______
Landscaping •• 0.1267 0.0474 4.0842 2.1000e- 0.0223 0.0223 0.0223 0.0223 ± 7.3066 7.3066 7.2900e- 7.4597
004 + 003
i
Total 19.6390 0.3731 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 458.9790 889.3066 ' 1,348.285, 1.3761 0.0312 , 1,386.840
6 0
CalEEMod Version: CaIEEMOd.2013.2.2 Page 30 of 30 Date: 7/7/2016 12:26 PM
6.2 Area by SubCategory
Mitigated
ROG NOx CO SO2 Fugitive I Exhaust PM10 I Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 To[al PM2.5 PM2.5 Total
SubCategory Ib/day Ib/day
Architectural •• 0.8014 0.0000 0.0000 0.0000 0.0000 ± 0.0000 0.0000
Coating +
Y Y Y lm Y Y ---------------
Consumer
t.Consumer 5.8711 0.0000 0.0000 • 0.0000 O.000o 0.0000 • • 0.0000
Products i
------------------------, w w w w T Y ------------------------------
Hearth •• 12.8398 0.3258 24.6295 0.0392 3.7430 • 3.7430 • • 3.7424 • 3.7424 +458.9790 • 882.0000 1,340.979• 1.3688 • 0.0312 ?1;379.380
+ a 2
i w i w w --------- -------- r i-----------------------------
Landscaping
ww tLandscaping •• 0.1267 0.0474 4.0842 2.1000e- 0.0223 0.0223 0.0223 0.0223 ± 7.3066 7.3066 7.2900e- 7.4597
004 + 003
i
Total 19.6390 0.3731 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 458.9790 889.3066 ' 1,348.285, 1.3761 0.0312 , 1,386.840
6 0
7.0 Water Detail
7.1 Mitigation Measures Water
8.0 Waste Detail
8.1 Mitigation Measures Waste
9.0 Operational Offroad
Equipment Type Number Hours/Day DaysNear Horse Power Load Factor Fuel Type
10.0 Vegetation
CaIEEMod Version: CalEEMod.2013.2.2 Page 1 of 30 Date: 7/7/2016 12:28 PM
Newport Center Villas
Orange County, Winter
1.0 Project Characteristics
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Enclosed Parking with Elevator 126.00 Space 1.13 133,260.00 i 0
Condo/Townhouse High Rise 49.00 Dwelling Unit 0.77 163,260.00 140
1.2 Other Project Characteristics
Urbanization Urban Wind Speed(m/s) 2.2 Precipitation Freq(Days) 30
Climate Zone 8 Operational Year 2018
Utility Company Southern California Edison
CO2 Intensity 630.89 CH4 Intensity 0.029 N20 Intensity 0.006
(Ib/MWhr) (Ib/MWhr) (Ib/MWhr)
1.3 User Entered Comments & Non-Default Data
57
CalEEMod Version: CalEEMod.2013.2.2 Page 2 of 30 Date: 7/7/2016 12:28 PM
Project Characteristics-
Land Use- Floor Surface Area:296,520 sf
Construction Phase - Construction Duration: 2 years
Trips and VMT- 940 tons of demolition required; CalEEMod assumes 20 tons per truck, which results in 47 loads of demolition to be hauled away. As such, the
Project will require 94 two-way haul trips during demolition; added import of cement
Demolition -
Grading - Grading
Architectural Coating -
Vehicle Trips -Source: Institute of Transportation Engineers (ITE)Trip Generation Handbook (9th Edition, 2012)
Area Coating -
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Off-road Equipment-Added 2 excavators
Table Name Column Name Default Value New Value
tblArchitecturalCoati ng ConstArea_Nonresidential_Exterior 66,630.00 25,200.00
.....................g.....-4............................. i.......................--.
tblArchitecturalCoatin ConstArea_Nonresidential_Interior 199,890.00 75,600.00
..................g.........4-----------------------------r------------------------------F.......................--.
tblAreaCoatin Area-Nonresidential-Interior 199890 1 75600
""'....................'Y.............................-------------------------------F....................------
tblConstructionPhase NumDays 10.00 1 40.00
.......
'......".............y-----------------------------r-----------------------------i....................------
tblConstructionPhase NumDays 200.00 1 400.00
"'......................Y-............................+------------------------------F......................----
tblConstructionPhase NumDays 20.00 40.00
""'...................................................r------------------------------F.....................-----
tblConstructionPhase NumDays 4.00 30.00
""'....................'Y.............................-------------------------------F....................------
tblConstructionPhase NumDays 10.00 20.00
"""......"
.............y-----------------------------r-----------------------------i....................------
tblConstructionPhase NumDays 2.00 4.00
.............................Y.............................------------------------------i.......................--.
tblGrading MaterialExported 0.00 51,600.00
.............................. ----------------------------- 5---------- ---------4----.... ------.
tblLandUse LandUseSquareFeet 50,400.00 133,260.00
CalEEMod Version: CalEEMod.2013.2.2 Page 3 of 30 Date: 7/7/2016 12:28 PM
tblLanclUse LandUseSquareFeet 49,000.00 163,260.00
------------ -----------._'--------4-------------'-•---------._.. ._....._.•._-------•------
tblOffRoad Equipment LoadFactor 0.38 0.38
-----'•---------------'-'--__4-_.._"------------'.......... -----------------------------f.............._
tblOffRoadEquipment Load Factor 0.38 0.38
-----------------------------4------------------------------ -----------------
tblOffRoadEquipment Load Factor 0.38 1 0.38
'--'-------------------- ........ "-------'-'---- ------------------------------f'•'-•--••.._.._
tblOffRoadEquipment Load Factor 0.38 0.38
•------•-----•---------- -------------------_.-•------4------------------------------ ._....-----------------•--
tblOffRoadEquipment Load Factor 0.38 0.38
---._'................'-'---- .. -----------------------------f......._......_
tblOffRoadEquipment Load Factor 0.38 0.38
-----------------------------4-----------------------------4------------------------------ --------------------------
tblOffRoadEquipment OffRoadEquipmentType i Excavators
---•-------- .._'. ............' ------------------------------i .._..-._____--------._.._.
tblOffRoadEquipment OffRoadEquipmentType i Excavators
._......_'---'----------'---' ------------------------'---- ------------------------------i-_...---•--------------•--
tblOffRoadEquipment OffRoadEquipmentType i Excavators
------------------------------i .....................
..'_'
tblOffRoadEquipment OffRoadEquipmentType i Excavators
-----------------------------4----------------------------- ------------------------------i--------------------------
tblOffRoadEquipment OffRoadEquipmentType i Excavators
.......... "-------• -------- ------------•-• ------------------------------i ----..___......__._.._....
tblOffRoadEquipment OffRoadEquipmentType i Excavators
------------------ -----------—---- ------------------------------f--------------------------
tblProjectCharacteristics OperationalYear 2014 2018
---._" -------------------------------
tblTripsAndVMT HaulingTripNumber 93.00 94.00
-----------------------------4----------------------------------------------------------- --------------------------
tblTripsAndVMT HaulingTripNumber 0.00 2,000.00
-------•............•._�...........---........__. ------------------------------f'••-..___.._.._
tblVehicleTrips ST TR 7.16 4.31
------------------------- ._.....__.__-------_'-._._._'------------------------------ ...........
tblVehicleTrips SU TR 6.07 3.43
tblVehicleTrips WD—TR 6.59 4.18
2.0 Emissions Summary
CaIEEMod Version: CalEEMOd.2013.2.2 Page 4 of 30 Date: 7/7/2016 12:28 PM
2.1 Overall Construction (Maximum Daily Emission)
Unmitigated Construction
ROG NOx CO I S02 I Fugitive I Exhaust I PM10 I Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PMiO Total PM2.5 PM2.5 Total
Year Ib/day Ib/day
2016 7.0197 91.2804 70.5817 0.1843 8.9994 2.4730 11.4724 3.6192 2.2749 5.8940 ± 0.0000 • 18,608.68 18,608.68• 0.9731 0.0000 • 18,629.12
+ 57 57 00
i _
2017 •• 4.3172 31.0705 29.7163 0.0537 • 1.3087 1.6822 • 2.9909 • 0.3504 • 1.6024 • 1.9528 q 0.0000 •4,997.029 4,997.029• 0.8120 • 0.0000 5,014.081
i 3 3 5
r r w T Y r r T t
2018 - 62.0733 62.0733 � 27.2765 � 28.5793 � 0.0537 � 1.6404 � 1.4200 • 3.0604 • 0.4319 • 1.3546 • 1.7665 ± 0.0000 •4,915.977�4,915.977� 0.7881 • 0.0000 •4,932.527
y 5 5 4
L
Total •• 73.4102 149.6273 ' 128.8774 0.2917 • 11.9485 5.5752 17.5236 4.4014 5.2318 9.6333 1 0.0000 •28,521.69 1 28,521.69• 2.5732 • 0.0000 •28,575.72
11 25 25 89
Mitigated Construction
ROG NOx CO SO2 Fugitive Exhaust PM10 1 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 I CH4 N20 CO2e
PM10 PM70 Total PM2.5 PM2.5 Total
Year Ib/day Ib/day
2016 •• 7.0197 91.2804 70.5817 0.1843 8.9994 2.4730 • 11.4724 3.6192 • 2.2749 • 5.8940 0.0000 • 18,608.68 18,608.68• 0.9731 . 0.0000 • 18,629.12
y 57 57 00
---------------T l T- l T T- l T Y r l
2017 •• 4.3172 � 31.0705 - 29.7163 � 0.0537 • 1.3087 - 1.6822 • 2.9909 . 0.3504 • 1.6024 . 1.9528 ± 0.0000 •4,997.029�4,997.029r 0.8120 r 0.0000 ?5,014.081
y 3 i 3 5
_______ _______r______ _______r______r______r______T_______-_______-______-_______r______ __
2018 •• 62.0733 � 27.2765 � 28.5793 � 0.0537 1.6404 � 1.4200 3.0604 • 0.4319 1.3546 1.7865 ± 0.0000 •4,915.977�4,915.977• 0.7881 T 0.0000 ?4,932.527
+ 5 5 4
i
Total •• 73.4102 ' 149.6273 ' 128.8774 ' 0.2917 ' 11.9485 5.5752 17.5236 • 4.4014 5.2318 9.6333 1 0.0000 •28,521.69' 28,521.69• 2.5732 • 0.0000 •28,575.72
25 25 89
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 5 of 30 Date: 7/7/2016 12:28 PM
ROG NOx CO 502 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Percent 0.00 0.00 1 0.00 1 0.00 0.00 0.00 0.00 1 0.00 1 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Reduction
CaIEEMod Version: CalEEMOd.2013.2.2 Page 6 of 30 Date: 7/7/2016 12:28 PM
2.2 Overall Operational
Unmitigated Operational
ROG NOx CO I S02 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Area •• 19.6390 0.3732 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 ± 458.9790 • 889.3066 1,348.285• 1.3761 0.0312 • 1,386.840
+ 6 0
____ ____ i__ ____ ______ _______ ______ ______ _
Y r T
Energy 0.0229 � 0.1958 � 0.0833 � 1.2500e- • � 0.0158 0.0158 • • 0.0158 0.0158 � 249.9382 � 249.9382 • 4.7900e-T4.5800e ?251.4593
003003 003
________ __ _______ _______ _______ ______ _______ ______ _______ ---------------i ______
•
n r r w
-----------------------------
Mobile •• 0.6427 1.5698 7.0529 0.0203 • 1.5248 0.0224 • 1.5473 • 0.4069 • 0.0207 • 0.4275 ± • 1,655.583 1,655.583 0,0631 --------
.0631 r ?1,656.908
y 5 5 0
L
Total •• 20.3046 2.1387 ' 35.8499 0.0610 • 1.5248 3.8035 5.3284 0.4069 3.8012 4.2081 1 458.9790 •2,794.828 1 3,253.807• 1.4439 • 0.0357 •3,295.207
11 4 4 2
Mitigated Operational
ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 I CH4 N20 CO2e
PM10 PM70 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Area •• 19.6390 0.3732 28.7136 0.0394 . 3.7653 • 3.7653 • 3.7647 • 3.7647 456.9790 889.3066 1,348.285• 1.3761 . 0.0312 • 1,386.840
y 6 0
Energy •• 0.0229 0.1958 0.0833 1.2500e- • 0.0158 . 0.0158 . . 0.0158 . 0.0158 ± 249.9382 249.9382 r4.7900e-r4.5800e ?251.4593
003 y 003 003
Mobile •• 0.6427 1.5698 7.0529 0.0203 1.5248 0.0224 1.5473 • 0.4069 0.0207 0.4275 ± •1,655.583 1,655.583• 0.0631 T ?1,656.908
+ 5 5 0
i
Total •• 20.3046 ' 2.1387 ' 35.8499 ' 0.0610 , 1.5248 ' 3.8035 ' 5.3284 , 0.4069 • 3.8012 • 4.2081 1 458.9790 •2,794.828' 3,253.807• 1.4439 • 0.0357 ,3,295.207
4 4 2
`i/_/
CaIEEMod Version: CalEEMOd.2013.2.2 Page 7 of 30 Date: 7/7/2016 12:28 PM
ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 Total CO2 CH4 I N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Percent 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1 0.00 0.00 1 0.00 1 0.00 1 0.00 0.00
Reduction
3.0 Construction Detail
Construction Phase
Phase Phase Name Phase Type Start Date End Date Num Days Num Days Phase Description
Number Week
1 I
Demolition :Demolition 6/1/2016 ;7/26/2016 5; 40�
2 •Site Preparation :Site Preparation -7/27/2016 ;8/1/2016 ; 5' 4:
3 •Grading :Grading 8/2/2016 :9/12/2016 5: 30:
4 •Building Construction :Building Construction 9/13/2016 :3/26/2018 5: 400;
5 :Paving :Paving 3/27/2018 ;4/23/2018 5: 20:
"""' _ ____________--------"
6 •Architectural Coating :Architectural Coating 4/24/2018 6/18/2018 5. 40•
Acres of Grading (Site Preparation Phase): 2
Acres of Grading (Grading Phase): 11.25
Acres of Paving: 0
Residential Indoor: 330,602; Residential Outdoor: 110,201; Non-Residential Indoor: 75,600; Non-Residential Outdoor: 25,200 (Architectural
Coating —sgft)
OffRoad E ui ment
520
CaIEEMod Version: CalEEMOd.2013.2.2 Page 8 of 30 Date: 7/7/2016 12:28 PM
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition •Concrete/Industrial Saws 1 i 8.00: 81: 0.73
____________________________p___________________________H----------------a-------------H_____________-____;--------------
Demolition :Rubber Tired Dozers 1i 8.00: 255' 0.40
-------------------------------------------------------------------------i------------ ----- ----- --------------
Demolition •Tractors/Loaders/Backhoes 31 8.00- 97: 0.37
--------------------------------------------------------H______________-1i__________B.00 F_____________-_174 ___________--
Site PreparationGraders0.41
-------------------------------------------------------- -------- -------
Site Preparation :Rubber Tired Dozers t 1 7.00: 255' 0.40
--------------------------------------------------------H________________i-------------H_____________-____ --------------
Site Preparation •Tractors/Loaders/Backhoes 11 8.00: 97:; 0.37
Grading "
------ -------------""'__Graders_____________________I-----------------�''________6.00~--- -174 --------------
0.41
Grading :Rubber Tired Dozers 1� 6.00 255' 0.40
--------------------------------------------------------I ----------------i H----- -----
Grading •Tractors/Loaders/Backhoes ti 7.00: 97: 0.37
--------------------------------------------------------H________________i-------------H_____________-____ ______________
Building Construction :Cranes 11 6.00: 226'; 0.29
-------------------------------------------------------------------------i H----- -----
Building Construction :Forklifts 11 6.00: 89: 0.20
-------------------------------------------------------------------------i------------ H---- ---- --------------
Building Construction :Generator Sets 1! 8.00: 84' 0.74
--------------------------------------------------------H----------------i H----- -----
Building Construction •Tractors/Loaders/Backhoes I ti 6.00: 97: 0.37
Building Construction
----------------------------
1-----s-------------------------------------3II-------------F46: --------------
0.45
--------------------------------------------------------H----------------i-------------H----- ----- --------------
Paving :Cement and Mortar Mixers 11 6.00: 9: 0.56
-------------------------------------------------------------------------i------------ H---- ---- --------------
Paving •Pavers 1i 6.00- 125' 0.42
--------------------------------------------------------I ----------------i-- H----- ---- --------------
-
Paving :Paving Equipment ti 8.00, 130' 0.36
Paving -----------------------Rollers --------------------- ---------------- 1-------------F----------------80 --------------
0.38
-------------------------------------------------------- -----------------i------------ H----- ----- --------------
Paving •Tractors/Loaders/Backhoes 11 8.00: 97: 0.37
-------------------------------------------------------------------------i------------ H---- ---- --------------
Architectural Coating :Air Compressors 11 6.00: 78' 0.48
Demolition ____________________•Excavators __________________H_______________2�__________B.OO162 ___________0.38
Site Preparation_________________1 Excavators---------------------------H_______________2I__________B.00- 162 --------------___________---
0.38
Grading ______________________•Excavators2--------------------------- ----------------
- 162 --------------___________---
0.38
-------------------------------------------------------- -----------------i------------ H---- ---- --------------
Building Construction :Excavators 21 8.00- 162: 0.38
_______________________• __________________H_______________ i__________B.OO
PavingExcavators2
F162 ___________0.38
Architectural Coating :Excavators 2 8.00: 162: 0.38
S�1
CaIEEMod Version: CalEEMOd.2013.2.2 Page 9 of 30 Date: 7/7/2016 12:28 PM
Trips and VMT
Phase Name Offroad Equipment Worker Trip Vendor Trip Hauling Trip Worker Trip Vendor Trip iHaulingTrip Worker Vehicle Vendor I Hauling
Count Number Number Number Length Length Length Class Vehicle Class Vehicle Class
Demolition 71 18.00• 0.00: 94.00• 14.70 6.90: 20.00-LD Mix -HDT_Mix jHHDT
Site Preparation 51 13.00• 0.00: 0.00• 14.701 6.90: 20.00:LD_Mix :HDT_Mix 1HHDT
________________• 1 _________t__________;__________}____________1----------4----------� _____________� 1
Grading 51 13.00• 0.00: 6,450.00• 14.701 6.90: 20.00-LD Mix -HDT_Mix 1HHDT
1
________________• 1 _________t__________;__________}____________1----------4----------� ____________� 1
Building Construction 91 91.00• 27.00: 2,000.00• 14.701 6.90: 20.00:LD_Mix HDT_Mix 1HHDT
Paving 71 18.00• 0.00: 0.00• 14.701 6.90; 20.00-LD Mix :HDT_Mix 1HHDT
Architectural Coati ng 3• 18.00• 0.00• 0.00• 14.70• 6.90- 20.00-LD Mix :HDT_Mix •HHDT
3.1 Mitigation Measures Construction
3.2 Demolition -2016
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust 0.5029 0.0000 0.5029 0.0761 0.0000 0.0761 A 0.0000 0.0000
_------.. 1 1 1 1 , 1 , ______i_______, _______J_______• i _______ _______ _______
M1 7 T- 1 • 1 • i i T ♦ 1
r T
Off-Road 3.6868 37.1639 28.3891 • 0.0351 2.1828 2.1828 2.0359 2.0359 i •3,592.464 3,592.464• 0.9622 3,612.671
y 9 9 2
Total 3.6868 37.1639 28.3891 0.0351 0.5029 2.1828 2.6856 0.0761 2.0359 2.1121 •3,592.464'3,592.464 1 0.9622 ' ' 3,612.671
9 9 2
C'J7
CaIEEMod Version: CalEEMOd.2013.2.2 Page 10 of 30 Date: 7/7/2016 12:28 PM
3.2 Demolition - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0459 0.6697 0.5394 1.7300e- 0.0409 9.7600e- 0.0507 0.0112 8.9800e- 0.0202 + 173.7996 173.7996 1.2500e- 173.8259
003 003 003 j 003
Vendor •• 0.0000 • 0.0000 0.0000 0.0000 • 0.0000 0.0000 • 0.0000 0.0000 • 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
Worker 0.0657 • 0.0887 • 0.9308 • 2.3100e- r 0.2012 1.4100e- r 0.2026 0.0534 r 1.3000e- 0.0547 193.4222 193.4222 r 9.6000e- 193.6239
003 003 003 003
Total 0.1117 0.7585 1.4702 4.0400e- • 0.2421 0.0112 • 0.2533 0.0646 0.0103 0.0748 367.2218 367.2218 • 0.0109 367.4498
003
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 0.5029 0.0000 r 0.5029 0.0761 0.0000 0.0761 0.0000 r 0.0000
+
Off-Road •• 3.6668 • 37.1639 r 28.3891 • 0.0351 2.1828 • 2.1828 2.0359 2.0359 0.0000 •3,592.464-3,592.464 r 0.9622 3.612.671
9 9 2
Total 3.6868 37.1639 28.3891 • 0.0351 ' 0.5029 1 2.1828 • 2.6856 0.0761 ' 2.0359 2.1121 0.0000 •3,592.464 1 3,592.464• 0.9622 ' 3,612.671
9 9 2
CaIEEMod Version: CalEEMOd.2013.2.2 Page 11 of 30 Date: 7/7/2016 12:28 PM
3.2 Demolition - 2016
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0459 0.6697 0.5394 1.7300e- 0.0409 9.7600e- 0.0507 0.0112 8.9800e- 0.0202 + 173.7996 173.7996 1.2500e- 173.8259
003 003 003 j 003
+ _
Vendor •• 0.0000 • 0.0000 0.0000 0.0000 • 0.0000 0.0000 • 0.0000 0.0000 • 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
Worker •• 0.0657 • 0.0887 • 0.9308 • 2.3100e- r 0.2012 1.4100e- r 0.2026 0.0534 r 1.3000e- 0.0547 193.4222 193.4222 r 9.6000e- 193.6239
003 003 003 003
Total 0.1117 0.7585 1.4702 4.0400e- • 0.2421 0.0112 0.2533 0.0646 ' 0.0103 0.0748 367.2218 367.2218 • 0.0109 367.4498
003
3.3 Site Preparation - 2016
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 5.7996 0.0000 r 5.7996 2.9537 0.0000 2.9537 0.0000 r 0.0000
+
Off-Road •• 3.2230 • 34.6778 r 23.4056 • 0.0278 1.8367 • 1.8367 1.6898 1.6898 2,886.422 2,886.422 r 0.8707 2,904.706
6 6 2
Total 3.2230 34.6776 ' 23.4056 • 0.0278 ' 5.7996 1 1.8367 • 7.6363 2.9537 ' 1.6896 1 4.6435 • •2,886.422 j 2,886.422• 0.8707 j '2,904.706
6 6 2
�n-T
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 12 of 30 Date: 7/7/2016 12:28 PM
3.3 Site Preparation - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.9000 0.0000 0.0000 0.0000 ; 0.0000 0.0000 - 0.0000 0.0000
r r r r i r i r i
i
n r r r r i r ii
n w w • w •� • T Y
• � t
Worker •• 0.0475 • 0.0641 • 0.6722 • 1.6700e- • 0.1453 1.0200e- 0.1463 0.0365 9.4000e- 0.0395 ± 139.6938 139.6938 - 6.9400e- 139.8395
003 003 004 003
Total 0.0475 0.0641 0.6722 1.6700e- ' 0.1453 1.0200e- , 0.1463 0.0385 9.4000e- 0.0395 139.6938 139.6938 16.9400e- 139.8395
003 003 004 003
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 5.7996 0.0000 5.7996 2.9537 0.0000 2.9537 0.0000 0.0000
Off-Road •• 3.2230 • 34.6778 r 23.4056 • 0.0278 1.8367 • 1.8367 1.6898 1.6898 0.0000 •2,886.422 2,886.422 r 0.8707 2,904.706
6 6 2
Total 3.2230 34.6778 ' 23.4056 ' 0.0278 ' 5.7996 1 1.8367 1 7.6363 2.9537 ' 1.6898 4.6435 0.0000 •2,886.422 2,886.422, 0.8707 '2,904.706
6 6 2
SgJr
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 13 of 30 Date: 7/7/2016 12:28 PM
3.3 Site Preparation - 2016
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 6.0000 0.0000 0.0000 0.0000 i 0.0000 0.0000 - 0.0000 0.0000
i
n w w • w •, • T Y • r
• � t
Worker •• 0.0475 • 0.0641 • 0.6722 • 1.6700e- r 0.1453 1.0200e- r 0.1463 0.0365 9.4000e- 0.0395 ± 139.6938 139.6938 r 6.9400e- 139.8395
003 003 004 003
Total 0.0475 0.0641 0.6722 1.6700e- 0.1453 1.0200e- 0.1463 0.0385 9.4000e- 0.0395 139.6938 139.6938 • 6.9400e- 139.8395
003 003 004 003
3.4 Grading - 2016
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 5.1088 0.0000 r 5.1088 2.5551 0.0000 2.5551 0.0000 r 0.0000
_______ ______ _______ ______ _______ _______ _______ ______ ______ 1 _ ___________ _______ _______ _______
Off-Road •• 2.7710 r 29.9421 r 20.5615 • 0.0247 1.5789 • 1.5789 1.4526 1.4526 2,568.182 2,568.182 r 0.7747 2,584.450
2 2 0
Total 2.7710 29.9421 ' 20.5615 • 0.0247 • 5.1088 1 1.5789 • 6.6877 2.5551 1.4526 4.0077 •2,568.182 2,568.182 0.7747 '2,584.450
2 2 0
SgC
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 14 of 30 Date: 7/7/2016 12:28 PM
3.4 Grading - 2016
Unmitigated Construction Off-Site
ROG NOx I CO I S02 I Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 4.2012 61.2742 49.3480 0.1579 3.7453 0.8931 4.6384 1.0256 0.8214 1.8469 • 15,900.80 15,900.80• 0.1148 15,903.22
96 96 01
J _
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 x0000 • 0.0009 0.0000 • 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
7
n --------------------• w •,-------• ---------------Y • r
• 4 t
Worker •• 0.0475 • 0.0641 • 0.6722 • 1.6700e- r 0.1453 - 1.0200e- r 0.1463 - 0.0365 r 9.4000e- 0.0395 ± 139.6938 - 139.6938 r 6.9400e- - 139.8395
003 003 004 003
Total 4.2487 61.3383 50.0202 0.1596 • 3.8906 0.8941 4.7847 1.0641 0.8223 1.8864 • 16,040.50 16,040.50• 0.1217 1 16,043.05
35 35 96
Mitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Fugitive Dust • 5.1088 0.0000 r 5.1088 2.5551 0.0000 2.5551 0.0000 r 0.0000
_______ ______ _______ ______ _______ _______ _______ ______ ______ 1 _ ___________ _______ _______ _______
Off-Road •• 2.7710 r 29.9421 r 20.5615 • 0.0247 1.5789 • 1.5789 1.4526 1.4526 0.0000 •2,568.182 2,568.182 r 0.7747 2,584.450
2 2 0
Total 2.7710 29.9421 • 20.5615 • 0.0247 • 5.1088 1 1.5789 • 6.6877 2.5551 1.4526 4.0077 • 0.0000 •2,568.182 2,568.182 r 0.7747 '2,584.450
2 2 0
sg7
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 15 of 30 Date: 7/7/2016 12:28 PM
3.4 Grading - 2016
Mitigated Construction Offsite
ROG NOx I CO I S02 I Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 4.2012 61.2742 49.3480 0.1579 3.7453 0.8931 4.6384 1.0256 0.8214 1.8469 • 15,900.80 15,900.80• 0.1148 15,903.22
96 96 01
•' __r______ _______r______-_______-_______-_______
J _
Vendor •• 0.0000 • 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 • o.00g9 � 0.0000 • 0.0000 � 0.0000 0.0000 � 0.0000 • 0.0000 � � 0.0000
7
n --------------------• w q • ---------------Y • r
• 4 t
Worker •• 0.0475 • 0.0641 • 0.6722 • 1.6700e- r 0.1453 - 1.0200e- r 0.1463 - 0.0365 r 9.4000e- 0.0395 ± 139.6938 - 139.6938 r 6.9400e- - 139.8395
003 003 004 003
Total 4.2487 61.3383 50.0202 0.1596 • 3.8906 0.8941 4.7847 1.0641 0.8223 1.8864 • 16,040.50 16,040.50• 0.1217 1 16,043.05
35 35 96
3.5 Building Construction -2016
Unmitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 4.0718 • 29.4518 • 21.5985 • 0.0326 • 1.8038 • 1.8038 1.7207 1.7207 •3,152.278 3,152.278 r 0.7833 3,168.728
6 6 2
J
Total 4.0718 29.4518 21.5985 0.0326 1.8038 1.8038 1.7207 1.7207 •3,152.278 3,152.277[77;37�7 3,168.728
6 6 2
Q
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 16 of 30 Date: 7/7/2016 12:28 PM
3.5 Building Construction - 2016
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Iblday
Hauling 0.0977 1.4250 1.1476 3.6700e- 0.3557 0.0208 0.3765 0.0898 0.0191 0.1089 + 369.7863 369.7863 2.6700e- 369.8423
003 j 003
Vendor •• 0.2617 • 2.3906 3.3166 5.8000e- • 0.1687 0.0374 • 0.2061 0.0481 • 0.0344 0.0824 • 580.5820 580.5820 • 4.2800e- 580.6719
003 i 003
n w w • w T Y • i r
• t
Worker •• 0.33 • 0.4486 • 4.7057 • 0.0117 r 1.0172 � 7.1100e- r 1.0243 � 0.2698 � 6.5500e- � 0.2763 � 977.8567 � 977.8567 r 0.0486 � � 978.8763
32
003 003 +
+
Total 0.6917 4.2641 9.1699 0.0212 • 1.5416 0.0653 1.6069 0.4076 0.0600 0.4676 • 1,928.224 1 1,928.224• 0.0555 1 1,929.390
11 9 9 6
Mitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 4.0718 • 29.4518 • 21.5985 • 0.0326 • 1.8038 • 1.8038 1.7207 1.7207 0.0000 •3,152.278 3,152.278 r 0.7833 3,168.728
+ 6 6 2
Total 4.0718 29.4518 21.5985 0.0326 1.8038 1.8038 1.7207 1.7207 0.0000 •3,152.278 3,152.27;-[-77;;7-r7 3,168.728
6 6 2
��9
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 17 of 30 Date: 7/7/2016 12:28 PM
3.5 Building Construction - 2016
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Iblday,
Hauling 0.0977 1.4250 1.1476 3.6700e- 0.3557 0.0208 0.3765 0.0898 0.0191 0.1089 + 369.7863 369.7863 2.6700e- 369.8423
003 j 003
Vendor •• 0.2617 • 2.3906 3.3166 5.8000e- • 0.1687 0.0374 • 0.2061 0.0481 • 0.0344 0.0824 • 580.5820 580.5820 • 4.2800e- 580.6719
003 i 003
n w w • w T Y • i r
• � t
Worker •• 0.3323 • 0.4486 • 4.7057 • 0.0117 r 1.0172 7.1100e- r 1.0243 0.2698 6.5500e- 0.2763 977.8567 977.8567 r 0.0486 978.8763
003 003 +
+
Total 0.6917 4.2641 9.1699 0.0212 • 1.5416 0.0653 1.6069 0.4076 0.0600 0.4676 • 1,928.224 1 1,928.224• 0.0555 1 1 1,929.390
11 9 9 6
3.5 Building Construction -2017
Unmitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 I CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 3.6826 • 27.1827 • 21.1873 • 0.0326 • 1.6229 • 1.6229 1.5478 1.5478 •3,122.222 3,122.222 r 0.7602 3,138.186
+ 2 2 0
Total 3.6826 27.1827 21.1873 0.0326 1.6229 1 1.6229 1.5478 1.5478 •3,122.222 3,122.222• 0.7602 3,138.186
2 2 0
s90
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 18 of 30 Date: 7/7/2016 12:28 PM
3.5 Building Construction - 2017
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0918 1.3068 1.1027 3.6700e- 0.1227 0.0190 0.1417 0.0326 0.0175 0.0501 + 363.6841 363.6841 2.6200e- 363.7391
003 j 003
.• ,
+ _
Vendor •• 0.2407 • 2.1737 3.1466 5.7900e- • 0.1688 0.0334 • 0.2022 0.0481 r 0.0307 0.0788 571.1200 571.1200 • 4.1500e- 571.2072
003 i 003
n 7- w • w -, • T Y • i r
• � t
Worker •• 0.3021 • 0.4073 • 4.2796 • 0.0117 r 1.0172 � 6.9500e- r 1.0241 � 0.2698 � 6.4200e- � 0.2762 � 940.0030 940.0030 r 0.0451 940.9492
003 003 +
+
Total 0.6346 3.8878 8.5290 0.0212 • 1.3087 0.0593 1.3680 0.3504 0.0546 0.4050 • 1,874.807 1,874.807• 0.0516 1 1,875.895
1 1 5
Mitigated Construction On-Site
ROG NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 3.6826 • 27.1827 • 21.1873 • 0.0326 • 1.6229 • 1.6229 1.5478 1.5478 0.0000 •3,122.222 3,122.222 r 0.7602 3,138.186
+ 2 2 0
Total 3.6826 27.1827 21.1873 0.0326 1.6229 1 1.6229 1.5478 1.5478 0.0000 •3,122.222 3,122.222• 0.7602 3,138.186
2 2 0
5�j1
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 19 of 30 Date: 7/7/2016 12:28 PM
3.5 Building Construction - 2017
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
_ 0_
Hauling 0.0918 1.3068 1.1027 3.6700e- 0.1227 0.0190 0.1417 0.0326 0.0175 0.0501 + 363.6841 363.6841 2.6200e- 363.7391
003 j 003
J _
.• ,
Vendor •• 0.2407 • 2.1737 3.1466 5.7900e- • 0.1688 0.0334 • 0.2022 0.0481 r 0.0307 0.0788 571.1200 571.1200 • 4.1500e- 571.2072
003 i 003
•_______w______-_______•_______ _______ _______T_______Ya
� •-----------------------------------
003
i_______•r
_______-_______t
___
003 003___Worker . 51 0_0 _ 4.2796 0.0117 1.0172 6.9500e- 1.0241 0.2698 6.4200e- 0.2762 940.0030 940.0030 0.0451 940.9_4_9_2
_
Total 0.6346 3.8878 8.5290 0.0212 • 1.3087 0.0593 1.3680 0.3504 0.0546 0.4050 • 1,874.807 1,874.807• 0.0516 1 1,875.895
1 1 5
3.5 Building Construction -2018
Unmitioated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 I CH4 N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 3.1785 • 23.6975 • 20.5864 • 0.0326 • 1.3627 • 1.3627 1.3019 1.3019 •3,092.219 3,092.219 r 0.7393 : 3,107.743
2 2 4
Total 3.1785 23.6975 20.5864 0.0326 1.3627 1.3627 1.3019 1.3019 •3,092.219 3,092.219• 0.7393 3,107.743
2 2 4
�9
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 20 of 30 Date: 7/7/2016 12:28 PM
3.5 Building Construction - 2018
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0886 1.2129 1.0750 3.6600e- 0.4545 0.0190 0.4735 0.1140 0.0175 0.1315 + 357.6005 357.6005 2.6600e. 357.6563
003 j 003
+ _
Vendor •• 0.2245 • 1.9944 3.0108 • 5.7800e- • 0.1688 0.0314 • 0.2002 0.0481 • 0.0289 0.0770 561.4126 561.4126 • 4.1400e- 561.4994
003 i 003
-- w w • w •, T Y • r
• t
Worker •• 0.2754 • 0.3716 • 3.9071 • 0.0117 r 1.0172 � 6.8700e- r 1.0240 � 0.2698 r 6.3600e- � 0.2761 ± 904.7453 � 904.7453 r 0.0421 � � 905.6283
003 003
Total 0.5884 3.5790 7.9929 0.0211 • 1.6404 0.0573 1.6977 0.4319 ' 0.0527 0.4846 • 1,823.758 1,823.758• 0.0489 1 1,824.784
4 4 0
Mitigated Construction On-Site
ROG NOx I CO S02 I Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 3.1785 • 23.6975 • 20.5864 • 0.0326 • 1.3627 • 1.3627 1.3019 1.3019 0.0000 •3,092.219 3,092.219 r 0.7393 : 3,107.743
+ 2 2 4
+
Total 3.1785 23.6975 20.5864 0.0326 1.3627 1.3627 1.3019 1.3019 0.0000 •3,092.219 3,092.219• 0.7393 3,107.743
2 2 4
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 21 of 30 Date: 7/7/2016 12:28 PM
3.5 Building Construction - 2018
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0886 1.2129 1.0750 3.6600e- 0.4545 0.0190 0.4735 0.1140 0.0175 0.1315 + 357.6005 357.6005 2.6600e. 357.6563
003 j 003
+ _
Vendor •• 0.2245 • 1.9944 3.0108 • 5.7800e- • 0.1688 0.0314 • 0.2002 0.0481 • 0.0289 0.0770 561.4126 561.4126 • 4.1400e- 561.4994
003 i 003
n w • w • T Y • •
------------
-777
905.6283
003 003Worker 754 7
0.0421
Total 0.5884 3.5790 7.9929 0.0211 • 1.6404 0.0573 1.6977 0.4319 ' 0.0527 0.4846 • 1,823.758 1,823.758• 0.0489 1,824.784
11 4 4 0
3.6 Paving - 2018
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road n 1.6011 • 16.6884 • 15.6205 • 0.0240 0.9121 r 0.9121 0.8400 0.8400 •2,397.381 2,397.381 r 0.7385 2,412.889
+ 4 4 4
Paving •• 0.0000 0.0000 r 0.0000 0.0000 0.0000 0.0000 0.0000
Total 1.6011 • 16.6884 ' 15.6205 • 0.0240 0.9121 • 0.9121 ' 0.8400 0.8400 •2,397.381 2,397.381 • 0.7385 '2,412.889
4 4 4
S�j4
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 22 of 30 Date: 7/7/2016 12:28 PM
3.6 Paving - 2018
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 OMOD 0.0000 0.0000 0.0000 t 0.0000 0.0000 - 0.0000 0.0000
i
n ww • w •, • T Y • •r
4 t
Worker •• 0.0545 • 0.0735 • 0.7728 • 2.3100e- r 0.2012 � 1.3600e- r 0.2026 � 0.0534 r 1.2600e- � 0.0546 ± 176.9606 � 178.9606 r 8.3200e- � � 179.1353
003 003 003 003
Total 0.0545 0.0735 0.7728 2.3100e- • 0.2012 1.3600e- 0.2026 0.0534 1.2600e. 0.0546 178.9606 178.9606 • 8.3200e- 179.1353
003 003 003 003
Mitigated Construction On-Site
ROG NOx I CO S02 I Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Off-Road 1.6011 • 16.6884 • 15.6205 • 0.0240 0.9121 r 0.9121 0.8400 0.8400 0.0000 •2,397.381 2,397.381 r 0.7385 2,412.889
4 4 4
_______ ______ _______ _______ _______ ______ _______ ______ ______ 1 _ ___________ _______ _______ ---------------
Paving
______ _ ____Paving •• 0.0000 0.0000 r 0.0000 0.0000 0.0000 0.0000 0.0000
Total 1.6011 • 16.6884 ' 15.6205 • 0.0240 0.9121 • 0.9121 ' 0.8400 0.8400 0.0000 •2,397.381 2,397.381 • 0.7385 '2,412.889
4 4 4
CaIEEMod Version: CalEEMOd.2013.2.2 Page 23 of 30 Date: 7/7/2016 12:28 PM
3.6 Paving - 2018
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 OMOD 0.0000 0.0000 0.0000 A 0.0000 0.0000 - 0.0000 0.0000
i
n ww • w •, • T Y • •r
4 t
Worker •• 0.0545 • 0.0735 • 0.7728 • 2.3100e- r 0.2012 � 1.3600e- r 0.2026 � 0.0534 r 1.2600e- � 0.0546 ± 176.9606 � 178.9606 r 8.3200e- � � 179.1353
003 003 003 003
Total 0.0545 0.0735 0.7728 2.3100e- • 0.2012 1.3600e- 0.2026 0.0534 1.2600e. 0.0546 178.9606 178.9606 • 8.3200e- 179.1353
003 003 003 003
3.7 Architectural Coating - 2018
Unmitigated Construction On-Site
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Archit.Coating n 61.1243 • 0.0000 r 0.0000 0.0000 0.0000 0.0000 r 0.0000
_______ ______ _______ _______ _______ _______ _______ --------------1 _ ___________ _______ _______ _______
Off-Road •• 0.8945 • 8.3860 r 8.6050 • 0.0136 0.4600 • 0.4600 • 0.4352 0.4352 • 1,352.254 1,352.254 r 0.3601 1,359.816
2 2 2
Total 62.0188 8.3860 ' 8.6050 • 0.0136 1 0.4600 • 0.4600 1 ' 0.4352 1 0.4352 • • 1,352.254 j 1,352.254• 0.3601 j ' 1,359.816
2 2 2
CaIEEMod Version: CalEEMOd.2013.2.2 Page 24 of 30 Date: 7/7/2016 12:28 PM
3.7 Architectural Coating - 2018
Unmitigated Construction Off-Site
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 7otaICO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 - 0.0000 0.0000
7
n ww • w •, • T Y ,
• 4 t
Worker •• 0.05 • 0.0735 • 0.7728 • 2.3100e- � 0.2012 � 1.3600e- � 0.2026 � 0.0534 � 1.2600e- � 0.0546 ± 176.9606 � 178.9606 � 8.3200e- � � 179.1353
003 003 003 003
45
Total 0.0545 0.0735 0.7728 2.3100e- ' 0.2012 1.3600e- ' 0.2026 0.0534 1.2600e. 0.0546 178.9606 178.9606 ' 8.3200e- 179.1353
003 003 003 003
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 I N20 I CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Arent.Coating n 61.1243 • 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road •• 0.8945 • 8.3860 r 8.6050 • 0.0136 0.4600 0.4600 0.4352 0.4352 0.0000 • 1,352,254 1,352.254 r 0.3601 1,359.816
2 2 2
Total 62.0188 8.3860 ' 8.6050 ' 0.0136 1 0.4600 , 0.4600 1 ' 0.4352 1 0.4352 • 0.0000 • 1,352.254 j 1,352.254, 0.3601 ' 1,359.816
2 2 2
�q�
CaIEEMod Version: CalEEMOd.2013.2.2 Page 25 of 30 Date: 7/7/2016 12:28 PM
3.7 Architectural Coating - 2018
Mitigated Construction Offsite
ROG NOx CO I SO2 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-0O2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 • 0.0000 0.0000
J
Vendor •• 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 - 0.0000 0.0000
7
• 4 t
Worker •• 0.05 • 0.0735 • 0.7728 • 2.3100e- � 0.2012 � 1.3600e- � 0.2026 � 0.0534 � 1.2600e- � 0.0546 ± 176.9606 � 178.9606 � 8.3200e- � � 179.1353
003 003 003 003
45
Total 0.0545 0.0735 0.7728 2.3100e- ' 0.2012 1.3600e- ' 0.2026 0.0534 1.2600e. 0.0546 178.9606 178.9606 ' 8.3200e- 179.1353
003 003 003 003
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
ROG NOx CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-0O2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Mitigated 0.6427 1.5698 7.0529 0.0203 1.5248 0.0224 1.5473 0.4069 0.0207 0.4275 ! • 1,655.583 1,655.583 0.0631 1,656.908
5 5 0
___________•'______T______T______T______T______T______T______T______T______
Unmitigated •• 0.6427 1.5698 7.0529 0.0203 1.5248 0.0224 1.5473 0.4069 0.0207 0.4275 • 1,655.583 1,655.583• 0.0631 1,656.908
5 5 0
CaIEEMod Version: CalEEMod.2O13.2.2 Page 26 of 30 Date: 7/7/2016 12:28 PM
4.2 Trip Summary Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use WeekdaySaturday ISunday Annual VMT Annual VMT
Condo/Townhouse High Rise 204.82 211.19 i 168.07 685,071 685,071
Enclosed Parkin with Elevator 0 00 0.00 i 0 00
Total 204.82 211.19 168.07 685,071 685,071
4.3 Trip Type Information
Miles Trip% Trip Purpose%
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Condo/Townhouse High Rise 14.70 5.90 8.70 40.20 19.20 i 40.60 86 11 3
....................... ..........r_________ __________ ________T_________�___________,- ----------------------------------------
Enclosed Parking with Elevator• 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
0.510011• 0.056836• 0.192178• 0.151564 0.041643 0.005905 0.015642• 0.015146 0.001440 0.002149• 0.004721• 0.000504 0.002262
�.g Pg[W Detail
Historical Energy Use: N
5.1 Mitigation Measures Energy
�qq
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 27 of 30 Date: 7/7/2016 12:28 PM
ROG NOx CO I S02 I Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 TotalCO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
NaturalGas 0.0229 0.1958 0.0833 1.2500e- 0.0158 0.0158 0.0158 - 0.0158 + 249.9382 249.9382 4.7900e- 4.5800e- 251.4593
Mitigated003 003 003
J _
..
NaturalGas •• 0.0229 0.1958 0.0833 1.2500e- 0.0158 0.0158 0.0158 0.0158 '249.9382T 249.9382Y 4.7900e-T 4.5800e-Y 251.4593
Unmitigated 003 003 003
5.2 Energy by Land Use - NaturalGas
Unmitigated
NaturalGa ROG NOx CO 502 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-0O2 Total CO2 CH4 1120 CO2e
s Use PM10 PM10 Total PM2.5 PM2.5 Total
Land use kBTU/yr Ib/day Ib/day
Enclosed Parking 0 b 0.0000 • 0.0000 0.0000 r x0000 0.0000 0.0000 0.0000 • 0.0000 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
with Elevator
_____ f. _______ _______ _______ _______ _______ _______ _______ ---------------i______________ _______ _______ _____ ______
CondolTownhous 2124.47 0.0229 0.1958 0.0833 1.2500e- 0.0158 0.0158 0.0158 0.0158 249.9382 249.9382 4.7900e- 4.5800e- 251.4593
e High Rise 003 + 003 003
Total 0.0229 0.1958 0.0833 1.2500e• ' 0.0158 0.0158 0.0158 0.0158 249.9382 ' 249.9382 ' 4.7900e. 4.5800e- 251.4593
003 003 003
000
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 28 of 30 Date: 7/7/2016 12:28 PM
5.2 Energy by Land Use - NaturalGas
Mitigated
NaturalGa ROG NOx I CO I S02 I Fugitive Exhaust PM10 I Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 I CH4 N20 CO2e
s Use PM10 PM10 Total PM2.5 PM2.5 Total
Land Use kBTU/yr Ib/day Ib/day
Enclosed Parking 0 &. 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
with Elevator
1, J ___ ______ _
Condo/Townhous- 2.12447 60.0229 0.1958 0.0833 1.2500e- 0.0158 0.0158 0.0158 0.0158 249.9382 249.9382 4.7900e-T4.5800e ?251.4593
e High Rise 003 003 003
b
Total 0.0229 ' 0.1958 ' 0.0833 ' 1.2500e- ' 1 0.0158 ' 0.0158 ' 1 0.0158 ' 0.0158 249.9382 ' 249.9382 ' 4.7900e- 1 4.5800e- 251.4593
003 003 003
6.0 Area Detail
6.1 Mitigation Measures Area
ROG I NOx I CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 Total PM2.5 PM2.5 Total
Category Ib/day Ib/day
Mitigated 19.6390 0.3732 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 ! 458.9790 889.3066 1,348.285 1.3761 0.0312 1,386.840
6 0
E
Unmitigated 19.6390 0.3732 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 •458.9790 889.3066 1,348.285 1.3761 0.0312 � 1,386.840
6 0
��2
CaIEEMod Version: CaIEEMOd.2013.2.2 Page 29 of 30 Date: 7/7/2016 12:28 PM
6.2 Area by SubCategory
Unmitigated
ROG NOx CO SO2 Fugitive I Exhaust PM10 Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 To[al PM2.5 PM2.5 Total
SubCategory Ib/day Ib/day
Architectural •• 0.8014 0.0000 0.0000 0.0000 0.0000 ± 0.0000 0.0000
Coating +
n Y Y Y Y Y Y
Consumer •• 5.8711 0.0000 0.0000 • 0.0006 0.0000 0.0000 T ?•0.0000
Products i
------------------------, w w w w T Y ------------------------------
Hearth •• 12.8398 0.3258 24.6295 0.0392 3.7430 • 3.7430 • • 3.7424 • 3.7424 ±458.9790 • 882.0000 1,340.979• 1.3688 • 0.0312 ?1;379.380
+ a 2
------- -------------- --------------------------------------------------- _______ ______
iii w______
w t_______
Landscaping •• 0.1267 0.0474 4.0842 2.1000e- 0.0223 0.0223 0.0223 0.0223 ± 7.3066 7.3066 7.2900e- 7.4597
004 + 003
i
Total 19.6390 0.3731 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 458.9790 889.3066 ' 1,348.285, 1.3761 0.0312 , 1,386.840
6 0
002
CalEEMod Version: CaIEEMOd.2013.2.2 Page 30 of 30 Date: 7/7/2016 12:28 PM
6.2 Area by SubCategory
Mitigated
ROG NOx CO SO2 Fugitive I Exhaust PM10 I Fugitive Exhaust PM2.5 Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
PM10 PM10 To[al PM2.5 PM2.5 Total
SubCategory Ib/day Ib/day
Architectural •• 0.8014 0.0000 0.0000 0.0000 0.0000 ± 0.0000 0.0000
Coating +
Y Y Y lm Y Y ---------------
Consumer
t.Consumer 5.8711 0.0000 0.0000 • 0.0000 O.000o 0.0000 • • 0.0000
Products i
------------------------, w w w w T Y ------------------------------
Hearth •• 12.8398 0.3258 24.6295 0.0392 3.7430 • 3.7430 • • 3.7424 • 3.7424 +458.9790 • 882.0000 1,340.979• 1.3688 • 0.0312 ?1;379.380
+ a 2
i w i w w --------- -------- r i-----------------------------
Landscaping
ww tLandscaping •• 0.1267 0.0474 4.0842 2.1000e- 0.0223 0.0223 0.0223 0.0223 ± 7.3066 7.3066 7.2900e- 7.4597
004 + 003
i
Total 19.6390 0.3731 28.7136 0.0394 3.7653 3.7653 3.7647 3.7647 458.9790 889.3066 ' 1,348.285, 1.3761 0.0312 , 1,386.840
6 0
7.0 Water Detail
7.1 Mitigation Measures Water
8.0 Waste Detail
8.1 Mitigation Measures Waste
9.0 Operational Offroad
Equipment Type Number Hours/Day DaysNear Horse Power Load Factor Fuel Type
10.0 Vegetation
CC.�,
V�
QP
�P
�o�