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HomeMy WebLinkAboutMtl's rec'd after packet distributionLETTER A7- City of Irvine (3 pages) Subject: Draft Environmental impact Report for the Proposed Expansion of the Hyatt Regency Newport Beach Dear Mr. Lepo: The City of Irvine has had the opportunity to review the draft Environmental Impact Report and the Hyatt Newporter Parking Review prepared in support of the proposed expansion to the Hyatt Regency Newport Beach. We appreciate this opportunity to comment on projects in adjacent jurisdictions that have the potential to result In impacts to the City of Irvine. The City was offered this opportunity for review earlier this year. That review resulted in a letter dated March 4, 2008 indicating that the City had no comments on the project at that time. At this time, after further detailed review, the City has concluded that there are several substantive Issues that need to be addressed before taking any action on this request or making any recommendation on the environmental documentation. The City would suggest that without making changes to the draft Environmental Impact Report as outlined by the comments provided below, the analysis contained in that document is flawed. We respectfully request that these comments be forwarded to your Planning Commission to be considered as a part of their deliberations on this project, and be made a part of the formal public record. The following are the City of Irvine's Comments on Chapter 5.11, Transportation and Appendix L to the drat Environmental Impact Report. 1. The study area boundary consists of 10 intersections. At the intersection of Jamboree/San Joaquin Hits Road, which is at the boundary of the study area, the trip distribution stows that 40 percent of the project traffic extends north on Jamboree. At the intersection of MacArthudCoast Highway, the trip distribution A7 -1 shows that 10 percent of the project traffic extends to the north on MacArthur. This means that 50 percent of the project traffic comes from, or is headed north out of the study area boundary. The intersection of Jamboree/MacArthur is two and a hall October 22, 2005 ygy oruMVtd 4ax David Lepo, Planning Director City of Newport Beach 3300 Newport Boulevard - Newport Beach, CA 92563 Subject: Draft Environmental impact Report for the Proposed Expansion of the Hyatt Regency Newport Beach Dear Mr. Lepo: The City of Irvine has had the opportunity to review the draft Environmental Impact Report and the Hyatt Newporter Parking Review prepared in support of the proposed expansion to the Hyatt Regency Newport Beach. We appreciate this opportunity to comment on projects in adjacent jurisdictions that have the potential to result In impacts to the City of Irvine. The City was offered this opportunity for review earlier this year. That review resulted in a letter dated March 4, 2008 indicating that the City had no comments on the project at that time. At this time, after further detailed review, the City has concluded that there are several substantive Issues that need to be addressed before taking any action on this request or making any recommendation on the environmental documentation. The City would suggest that without making changes to the draft Environmental Impact Report as outlined by the comments provided below, the analysis contained in that document is flawed. We respectfully request that these comments be forwarded to your Planning Commission to be considered as a part of their deliberations on this project, and be made a part of the formal public record. The following are the City of Irvine's Comments on Chapter 5.11, Transportation and Appendix L to the drat Environmental Impact Report. 1. The study area boundary consists of 10 intersections. At the intersection of Jamboree/San Joaquin Hits Road, which is at the boundary of the study area, the trip distribution stows that 40 percent of the project traffic extends north on Jamboree. At the intersection of MacArthudCoast Highway, the trip distribution A7 -1 shows that 10 percent of the project traffic extends to the north on MacArthur. This means that 50 percent of the project traffic comes from, or is headed north out of the study area boundary. The intersection of Jamboree/MacArthur is two and a hall Mr. David Lepo October 22, . 2006 Page 2 miles from this intersection. This intersection has been forecast to operate at unacceptable levels of service in future horizon years in other studies. Newport Beach has identified physical improvements for the intersection of A7-1 Jamboree/MacArthur', however, they are not yet fully funded. The study area (confd.) boundary will need be expanded to include the intersection of JamboreslMacArthur. 2. Explain why was TRAFFIX used to provide the ICU's instead of NBTAM to forecast the I A7 -2 traffic volumes. 3. This traffic study was done with a methodology that compares the trip generation of the Wyatt from the previously approved 1992 Circulation Improvement and Open A7 -3 Space Agreement ( CIOSA) that included an expansion of 68 moms, with the trip generation of this project that is a net increase of 76 moms. Previous comments made by attorneys representing Newport Beach, to the City of Irvine, on numerous traffic studies and environmental documents, have taken issue with similar methodology, wherein the trip generation of a project's entitled uses was compared with the proposed intensity of the current project. Newport Beach needs to further: evaluate the project's full Impacts of the 76 net new units (88 new timeshare units minus the 12 existing villas that are being removed) and not provide a comparison between the "phantom trips" generated by some un -built future . intensity and the proposed project. 4. The City understands that the Hyatt has previously contributed its fair share to the CIOSA Improvements. Explain why an expansion to any of the 11 CIOSA projects would not be subject to a proportional increase in their fair share contributions to CIOSA. A7-4 5. Revise the traffic analysis to provide an existing plus project scenario evaluation for I A75 CEQA compliance purposes. 6. Revise the traffic analysis to provide a separate evaluation of the project's contribution without considering the cumulative projects (those approved and not yet constructed projects and the reasonably foreseeable unapproved projects) so that A7 -6 the project's impact to intersection ICU's can be isolated from these other developments. 7. Even though a small expansion at this hotel does not trigger the threshold for an impact, the cumulative projects do contribute to forecast deficiencies at several I A7 -7 intersections. Does the City of Newport Beach have a program for addressing these forecast deficiencies that are not attributed to any specific projects? 6. Page 1 of the Traffic Study, Table ESA: The year 2012 should be provided on the I °without project" and "with project" columns to. correspond to those shown in Table A7 -8 4.4, and to explain why the ICU's am higher than the existing year. Mr. David Lepo October 22,2W8 Page 3 In addition to these comments, If there was a Response to Comments document prepared as a component of the draft Environmental Impact Report for this project, we would appreciate receiving a copy of that document electronically. The City looks forward to a complete and comprehensive response to the comments contained in the letter. The City also expects that the drat Environmental Impact Report will be dutifully and responsibly updated and revised to address these issues in order to achieve some measure of compliance with CEQk We are happy to make ourselves available for further consultation on these matters should you require further clarification. Sincerely, elf TIM GEHRICH, AICP Manager of Development Services cc: City of Newport Beach Planning Commission Douglas Williford, Director of Community Development Manuel Gomez, Director of Public Works Kerwin Lau, Project Development Administrator Sun -Sun Murilio, Supervising Transportation Analyst Timor Rafiq, Rafiq and Associates Diane.lakubowski, Rafiq and Associates Steve Weiss, Principal Planner Michael Philbrick, Senior Planner A7. Response to Comments from the City of Irvine, Tim Gehrich, dated October, 2008. Although this letter, dated October 22, 2008, was received after the close of the public review period, the City of Newport has decided to respond to the comments. A7 -1 The City of Newport Beach has received approximately $ 2.8 million from Measure M and GMA 8 for the construction of improvements to the intersection of Jamboree at MacArthur. These planned, and fully funded, improvements will provide for an acceptable level of service at the intersection. If the assumed project trip distribution is carried out to the Jamboree /MacArthur intersection, it is anticipated that approximately 25% of project trips would approach the intersection via Jamboree Road and 5% of project trips would approach via MacArthur Boulevard. In the AM peak period, these percentages would result in a forecast of nine inbound trips and six outbound trips. In the PM peak period, these percentages would result in a forecast of nine inbound trips and eight outbound trips. This is a minimal number of trips that would not be anticipated to result in a significant impact at this intersection, given the implementation of the fully funded, planned improvements. A7 -2 TRAFFIX is a computer program used to calculate ICU values. It is not a traffic forecast model, and was not used as one in this study. NBTAM is the City of Newport Beach's traffic model used to forecast future traffic volumes. However, NBTAM was not used to determine the volumes because the project has a short term future horizon year (Year 2011) for completion. Consistent with City of Newport Beach standards, the traffic analysis was completed for one year after project completion, Year 2012. The use of an annual growth factor of 1% for traffic volumes was determined to be a reasonable methodology to forecast Year 2012 ambient traffic volumes. This methodology is permitted under the City of Newport Beach Traffic Phasing Ordinance Traffic Impact Analysis Guidelines. A7 -3 The traffic study does provide a comparison of the proposed project's trip generation with the trip generation of the previously approved 1992 CIOSA project. However, this comparison is only provided to show consistency between the currently proposed project and the proposed CIOSA project under the City of Newport Beach's Traffic Phasing Ordinance. The consistency analysis was completed to compare the previously approved CIOSA project (68 rooms) with the proposed project (76 rooms). While there is a difference in the total number of rooms, there is a similar number of trips between the two projects because there have been refinements and updates in the trip generation rates in NBTAM during the last 14 years. The traffic impact study analyzes the full impact of the proposed project using the full trip generation information presented in Table 5.1 (page 28) of the traffic study. A7-4 As noted in the previous response, the traffic impact study includes a comparison of the trip generation for the current proposed project with the project approved as part of CIOSA. Because the proposed project does not generate new additional trips, the Hyatt project is not conditioned for an increase in their fair share fee. If any of the 11 CIOSA projects were to propose an expansion, and if that project generated new trips beyond the previously approved amount, that project could be conditioned to pay the appropriate additional fair share fees. A7 -5 The traffic study analyzes existing conditions and future conditions with and without the project. Future conditions include both approved projects and reasonably foreseeable projects in the baseline. The analysis clearly quantifies the project - specific impact on each study intersection. As shown on Table ES -1 and ES -2 for AM and PM peak conditions, respectively, the increase in V/C due to project implementation is shown for each intersection. As shown, none of these increases result in changing the level of service of the subject intersection in the year 2012. Moreover, as explained in the traffic report (Section 4.0, page 15), the analysis assumed that the lane geometries for each of the 10 study intersections in Year 2012 will be the same as existing conditions. Therefore, analysis of the future year does not assume any improvements that are not in place under existing conditions. As shown in Table ES -1, none of the intersections fall to an unacceptable LOS in the AM peak hour in 2012. Four intersections, however, would decline to an unacceptable LOS during the peak hour due to cumulative traffic in 2012 (see Table ES -2). The following table shows the impact of project- related trips only (no cumulative growth) on the existing condition level of service for the subject intersections in the PM peak: No. Intersection Existir Increase In V/C Due to Project Existing + Project Conditions (r /C I LOS V/C Y/C LOS Impact 1 Coast Highway and Dover Drive 0.779 C 0.001 0.780 C No 3 Coast Highway and Jamboree Road 0.771 C 0.006 0.777 C No 6 Coast Hghway and MacArthur Boulevard 0.756 C 0.001 0.757 C No 7 Jamboree Road and San Joaquin Hills Road 0.828 D 0.002 0.830 r No As shown by the Existing plus Project results in the above table, the proposed project would not significantly impact any of the study intersections. A7 -6 The traffic impact study analyzes and quantifies the project's impact to intersection ICU's as shown in Table ES -1. Analyzing a future condition without the cumulative projects would not be consistent with the City of Newport Beach Traffic Phasing Ordinance Traffic Impact Analysis Guidelines and would not provide a realistic assessment of future traffic conditions. As noted in Response A7 -5, the analysis does isolate the specific increase in V/C due to the proposed project. Moreover, the analysis summarized in the table provided in Response No. 5 confirms that project- related traffic alone would not lower the level of service of any of the study intersections to an unacceptable LOS. A7 -7 The City of Newport Beach's Traffic Phasing Ordinance sets forth a methodology for projects to contribute their fair share to the construction of identified traffic mitigation measures. A7 -8 This change will be incorporated into Table ES -1.