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HomeMy WebLinkAboutExhibit 6EXHIBIT 6 DEIR Response to Comments (Nov. 2007) \63 Final Environmental Impact Report SCH No. 2006101105 RESPONSE TO PUBLIC COMMENTS HOAG HEALTH CENTER USE PERMIT AMENDMENT City of Newport Beach Planning Department 3300 Newport Boulevard Newport Beach, CA 92658 -8915 Prepared by: Keeton Kreitzer Consulting 97291 Irvine Boulevard, Suite 305 Tustin, CA 92780 November 2007 10S. RESPONSE TO PUBLIC COMMENTS HOAG HEALTH CENTER DRAFT ENVIRONMENTAL IMPACT REPORT NEWPORT BEACH, CA INTRODUCTION The 45 -day public review period for the Draft Environmental Impact Report (EIR) prepared for the Hoag Health Center Project extended from September 11, 2007 through October 25, 2007. The City of Newport Beach received ten (10) comment letters on the Draft EIR during the formal public review and comment period. Responses to the comments in the letters received by the City of Newport Beach have been prepared and are included with the Final EIR. The comment letters were received from: 1. Southern California Gas Company (September 12, 2007) 2. California Native American Heritage Commission (September 13, 2007) 3. Southern California Association of Governments (September 20, 2007) 4. California Department of Toxic Substances Control (October 3, 2007) 5. Newport Beach Environmental Quality Affairs Committee (October 16, 2007) 6. Orange County Resources & Development Management Department (October 19, 2007) 7. California Department of Transportation (October 22, 2007) 8. City of Costa Mesa (October 25, 2007) 9. South Coast Air Quality Management District (October 26, 2007)' 10. Don Krotee /Newport Heights Improvement Association (September 20, 2007)2 Responses to these comments have been prepared according to Section 15088 of the State CEQA Guidelines. The letters received during the public review period have been reproduced in the section that follows. The letters have been reviewed and substantive comments have been identified. Responses have been prepared and follow the letters from the agencies in this 'Response to Public Comments" Appendix to the Final EIR. Each comment in each letter for which a response is required has been numbered for easy reference. ' The South Coast AQMD requested and received a one -day extension of the comment period. 2 Comment received via email. Although reference to the traffic, noise and air quality mitigation measures associated with the Draft EIR appears in the email from Mr. Krotee, no specific comments on the adequacy of the information presented In the Draft EIR are provided by Mr. Krotee. Hoag Health Center Responses to Public Comments November 2007 Page f Southern California Gas Company A Sempra Energy utility" 1 September 12, 2007 City of Newport Beach 3300 Newport Beach Blvd P.O. Box 1768 Newport Beach, CA 92658 -8915 Attention: Jaime Murillo Letter No. 1 1919 S. State College SW& Anaheim. CA 928066114 PlgN� °)Ep, By ViMS,Vir SEP 17 2007 CITYOFNEVORTBFAcH Subject: EIR for the Hoag Health Center located at 500 -540 Superior Ave in Newport Beach. Thank you for providing the opportunity to respond to this E.I.R. (Coastal Land Impact Report) Document. We are pleased to inform you that Southern California Gas Company has facilities in the area where the aforementioned project is proposed. Gas service to the project can be provided from an existing gas main located in various locations. The service will be in accordance with the Company's policies and extension rules on file with the California Public Utilities Commission when the contractual arrangements are made. This letter is not a contractual commitment to serve the proposed project but is only provided as an informational service. The availability of natural gas service is based upon conditions of gas supply and regulatory agencies. As a public utility, Southern California Gas Company is under the jurisdiction of the California Public Utilities Commission. Our ability to serve can also be affected by actions of federal regulatory agencies. Should these agencies take any action, which affect gas supply or the conditions under which service is available, gas service will be provided in accordance with the revised conditions. .This letter is also provided without considering any conditions or non - utility laws and regulations (such as environmental regulations), which could affect construction of a main and/or service line extension (i.e., if hazardous wastes were encountered in the process of installing the line). The regulations can only be determined around the time contractual arrangements are made and constructbn has begun. Estimates of gas usage for residential and non - residential projects are developed on an individual basis and are obtained from the Commercial- industrial /Residential Market Services Staff by calling (800) 427 -2000 2 (Commercial /Industrial Customers) (800) 427 -2200 (Residential Customers). We have developed several programs, which are available upon request to provide assistance in selecting the most energy efficient appliances or systems for a particular project. If you desire further information on any of our energy conservation programs, please contact this office for assistance. Sincere ichael . H= Technical Services Supervisor Pacific Coast Region - Anaheim hCUVinr eir02Aw p Southern California Gas Company (September 12, 2007) Response to Comment No. t This comment, which indicates that gas service can be provided from an existing gas main(s) located in the project vicinity and, further, that gas service would be provided to the project based on gas supply in accordance with regulatory requirements, is acknowledged. Furthermore, it should be noted that gas service is already provided to the subject property through existing gas lines already constructed. No further response is necessary. Response to Com vent No. 2 As suggested in this comment, the project applicant will contact Southern California Gas Company for information on conservation programs that may be appropriate for implementation. This comment does not raise any environmental issues; no further response is necessary. Hoag Health Center Responses to Public Comments November2007 Page 2 Np< s7arE eP rar rr:G9uu Letter NO.2 e .ua NATIVE AMERICAN HERITAGE COMMISSION 916 CAPITOL MALL, ROOM 760 SACRAMENTO, GA 96611 (916)0534W FOX (918) 667.8790 web SRO w• %nWM.cs= e-mell: 4_nahc0peabell.net September 13, 2007 Mr. Jaime Mudlio, Associate Planner CITY OF NEWPORT REACH 3300 Newport Boulevard Newport Beach, CA 92658 -8915 RECENED BY 0 PLANNING DEPARTMENT 5EP 18 2007 CIP( OF NEWPORT BEACH - .;f 11. r � w, .�,: .1.- .� u- u.. -..1 a •: - -u Dear Mr. Murillo: The Native American Heritage Commission is the state's Trustee Agency for Native American Cultural Resources. The California Environmental Quality Act (CEQA) requires that any project that causes a substantial adverse change in the significance of an historical resource, that includes archaeological resources, is a'significant effect requiring the preparation of an Environmental Impact Report (EIR) per CEQA guidelines § 15064.5(b)(c). In order to comply with this provision, the lead agency is required to assess whether the project will have an adverse impact on these resources within the'area of potential effect (APE)', and if se, to mtiigate that effect, To adequately assess the project-related impacts on historical resources, the Commission recommends the following action: J Contact the appropriate California Historic Resources Information Center (CHRIS). Contact information for the Information Center nearest you is available from the State Office of Historic Preservation (918!853- 7278)/ httPh%iA;vw oho Darks ca oov/1068181es/1C% ORosker odf The record search will determine: • If a part or the entire APE has bean previously surveyed for cultural resources. • If any known cultural resources have already been recorded in or adjacent to the APE. • If the probability is low, moderate, or high that cultural resources are located in the APE. • If a survey is required to determine whether previously unrecorded cultural resources are present J If an archaeological inventory survey is required, the final stage is the preparation of a professional report detailing the findings and recommendations of the records search and field survey. • The final report containing site forms, site significance, and mitigation measurers should be submitted immediately to the planning department All information regarding site locations, Native American human remains, and associated funerary objects should be in a separate confidential addendum, and not be made available for pubic disclosure. • The final written report should be submitted within 3 months after work has been completed to the appropriate regional archaeological Informetion Carder. J Contact the Native American Heritage Commission (NAHC) for. A Sacred Lands File (SLF) search of the project area and information on tribal contacts in the project vicinity that may have additional cultural resource information. Please provide this office with the following citation format to assist with the Sacred Lands File search request USGS 7.5-minute Guadranais citation wlth name townehiD ranee )end section• . • The NAHC advises the use of Native American Monitors to ensure proper identification and care given cultural resources that may be discovered. The NAHC recommends that contact be made with Native American Contacts on the attached list to get their input on potential project impact (APE). In some cases, the existence of a Native American cultural resources may be known only to a local tribe(s). J Lack of surface evidence of archeological resources does not preclude their subsurface existence. • Lead agencies should include in their mitigation plan provisions for the identification and evaluation of accidentally discovered archeological resources, per California Environmental Quality Act (CEQA) §15064.5 (f). In areas of identified archaeological sensitivity, a certified archaeologist and a culturally affiliated Native American, with knowledge in cultural resources, should monitor all ground - disturbing activities. • Lead agencies should include in their mitigation plan provisions for the disposition of recovered artifacts, in consultation with culturally affiliated Native Americans. J Lead agencies should include provisions for discovery of Native American human remains or unmarked cemeteries In their mitigation plans. CEQA Guidelines, Section 15064.5(d) requires the lead agency to work with the Native Americans identified by this Commission if the initial Study Identifies the presence or likely presence of Native American human remains within the APE. CEQA Guidelines provide for agreements with Native American, identified by the NAHC, to assure the appropriate and dignified treatment of Native American human remains and any associated grave liens. J Health and Safety Code §7050.5, Public Resources Code §5097.96 and Sec. §15084.5 (d) of the CEQA Guidelines mandate Procedures to be foilowed in the event of an accidental discovery of any human remains In a location other than a dedicated cemetery. contact me at (918) 853-8251 if you have any questions. Attachment: List of Native American Contacts �1b Native American Contacts Orange County September 13, 2007 Juaneno Band of Mission Indians Acjachemen Nation Juaneno Band of Mission Indians David Belardes, Chairperson Adolph "Bud" Sepulveda, Chairperson 31742 As Belardes Juaneno P.O. Box 25828 Juaneno San Juan CapeVano , CA 92675 Santa Ana , CA 92799 (949) 493 -0959 bssepuliPyahoo.net (949) 493 -1601 Fax 714 -838 -3270 714 - 914 -1812 - CELL bsepuigyahoo.net Juaneno Band of Mission Indians Acjachemen Nation Sonia Johnston, Tribal Vice Chairperson Anthony Rivera, Chairman Juaneno Band of Mission Indians 31411 -A La Matanza Street Juaneno P.O. Box 25628 Juaneno San Juan Capistrano , CA 92676 -2674 Santa Ana , CA 92799 ariveragivaneno.com (714) 323 -8312 949 - 488 -3484 sonia. ohnston @sb lobal.net 949 - 488294 Fax 1 � Juaneno Band of Mission Indians Acjachemen Nation Joyce Perry, Tribal Manager & Cultural Resources 31742 Via Belardes Juaneno s"',bAncepi , CA 92675 (949) 493 -0959 (949) 293 -8522 Cell (949) 493 -1601 Fax Juaneno Band of Mission Indians Alfred Cruz, Culural Resources Coordinator P.O. Box 25628 Juaneno Santa Ana , CA 92799 714 988-u0z7Bsbcglobal.net sifredgcruz@sbcglobal.net ThIS I1st Is current only an of the date of this dooumerd. Dlstrlbullon ct thlo Not does not relieve any person of Statutory responsibility as defined In Section 7050.5 of the Hem and Safety Code. Section 5087.04 of the Public Resources Code and Section 5p97.98 of the Public Resourceb Code. This Ilan Is only applicable for contacting local Native American with regard b cultural resources for the proposed $CN/?D05101105; CEGA Notice of Completion; draft Environmerdal Impact Report(DENQ for HOAG Health Center, Use Permit AnrerKbrwnt; City of Newport Reach; orange CWmty, California. 2. California Native American Heritage Commission (October 13, 200 Response to Comment No. 1 As indicated on pages 13 through 15 in the initial study (Appendix A) in the Draft EIR, the project site has been significantly altered as a result of past development activities. It is likely that any cultural and/or scientific resources that may have existed on the subject property have been affected by prior grading and excavation that were necessary to prepare the site for development. Further, the vast majority of work to be undertaken to implement the proposed project will occur as interior remodeling without any associated excavation and/or grading that would disturb the underlying soils. Only limited excavation would be required Li orc.er to construction the new 20,586- square foot structure that is also proposed. Nonetheless, the initial study prepared for the proposed project included several mitigation measures (refer to pages 14 and 15 in Appendix A), including MM -3, which requires that a qualified archaeologist be retained to observe grading activities and conduct a pre - grading conference and related activities in order to address the need for further action in the event that cultural materials were encountered during the anticipated minor grading activities. That measure also requires that in the unlikely event that cultural materials are encountered, that all activities in the immediate area be halted until appropriate measures to address the resources are identified for implementation. MM -4 prescribes similar requirements for on -site monitoring for paleontological resources. Finally, MM -5 also prescribes the actions that shall be taken in the event that human remains are encountered. Specifically, the applicant must comply with the State Health and Safety Code and other requirements that apply, including notification of the County Coroner and, if the remains are determined to be Native American, appropriate representatives of that Native American community would also be notified. The initial study concluded that potentially significant impacts to cultural and scientific resources would be less than significant with the implementation of the prescribed mitigation measures (refer to pages 14 and 15 in Appendix A). Those mitigation measures will be included in the Mitigation Monitoring and Reporting Program that will be adopted for the proposed project to ensure that each will be implemented. 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NgoryaA uta Letter No. 3 RECOWD BY Pl.pdxlNING DEPARTMEN11.1' SEp 24 2007 September 20, 2007 �` Mr. Jaime Murillo CIV oJ N RP®RT Associate Planner Newport Beach Planning Department 3300 Newport Boulevard Newport Beach, CA 92658 -8915 RE: SCAG Clearinghouse No. 120070567 Hoag Health Center Use Permit Amendment Dear Mr. Murillo: Thank you for submitting the Hoag Health Center Use Permit Amendment for review and comment. As areawide clearinghouse for regionally significant projects, SCAG reviews the consistency of local plans, projects and programs with regional plans. This activity is based on SCAG's responsibilities as a regional planning organization pursuant to state and federal laws and regulations. Guidance provided by these reviews is intended to assist local agencies and project sponsors to take actions that contribute to the attainment of regional goals and policies. We have reviewed the Hoag Health Center Use Permit Amendment, and have determined that the proposed Project is not regionally significant per SCAG Intergovernmental Review (IGR) Criteria and California Environmental Quality Act (CEQA) Guidelines (Section 15206). Therefore, the proposed Project does not warrant comments at this time. Should there be a change in the scope of the proposed Project, we would appreciate the opportunity to review and comment at that time. A description of the proposed Project was published in SCAG's September 1 -15, 2007 intergovernmental Review Clearinghouse Report for public review and comment. The project title and SCAG Clearinghouse number should be used in all correspondence with SCAG concerning this Project. Correspondence should be sent to the attention of the Clearinghouse Coordinator. If you have any questions, please contact me at (213) 236 -1856. Thank you. . Sincerely, SHERYLL DEL ROSARIO Associate Planner Intergovernmental Review Doe #140052 11'J 3. Southern California Association of Governments (September 20, 2007) Response to Comment No. 1 This comment indicates that SCAG has reviewed the project and has determined that it is not regionally significant and, therefore, does not warrant comments from that agency. Because no environmental issues are raised in this letter related the adequacy of the EIR, no response is necessary. Hoag HeaRh Center Responses to Public Comments November2007 Page 4 kkA -\ ..�., Letter No. 4 Department of Toxic Substances Control Maureen F. Gorsen, director By PLANNING DEPARTMENT Linda et Adams 5796 Cor orate Avenue Secretary For p Arnold Schwarzenegger Environmental Protection Cypress, California 90630 OCT 0 9 2007 Governor October 3, 2007 CITY OF NEWPORT BEACH Mr. Jamie Murillo City of Newport Beach, Planning Department 3300 Newport Boulevard Newport Beach, California 92663 DRAFT ENVIRONMENTAL IMPACT REPORT (EIR) FOR HOAG HEALTH CENTER PROJECT (SCH# 2006101105) Dear Mr. Murillo: The Department of Toxic Substances Control (DTSC) has received your submitted Notice of Preparation of a Supplemental EIR for the above - mentioned project. The following project description is stated in your document: "Newport Beach Healthcare Center, LLC, is requesting the approval of an amendment to Use Permit No. 2006 -010 to allow (1) the conversion of the remaining 232,414 square feet of general office /R &D floor area, of the total 329,414 square feet of floor area currently permitted on -site, to medical office use within the M -1 -A zoning district; and (2) the construction of an additional 20,586 square feet of medical office and ancillary medical uses on -site, for a total of 350,000 gross square feet of medical office floor area. The total new medical office floor area requested in the proposed Use Permit amendment is 253,000 square feet. The request is consistent with the City's General Plan that designates the 13.7 acre site for Medical Commercial Office land uses and establishes a precise development limitation of 350,000 square feet of floor area. This land use designation is intended to provide primarily medical - related uses. Additionally, approval of a traffic study is being requested pursuant to the City of Newport Beach Traffic Phasing Ordinance. A total of 1,985 parking spaces previously approved in Use Permit 2006 -010 are provided to accommodate the development, including 427 surface parking spaces and 1,558 spaces in two parking structures. Total parking exceeds the minimum on -site parking requirements of 1,750 spaces prescribed by the City's parking code." Based on the review of the submitted document DTSC has the following comments: 1) The project construction may require soil excavation or filling in certain areas. Sampling may be required. If soil is contaminated, it must be properly disposed and not simply placed in another location onsite. Land Disposal Restrictions (LDRs) may be applicable to such soils. Also, if the project proposes to import Printed on Recycled Paper 11 y Mr. Jamie Murillo October 3, 2007 Page 2 soil to backfill the areas excavated, sampling should be conducted to ensure that the imported soil is free of contamination. Z 12) If during construction /demolition of the project, the soil and /or groundwater contamination is suspected, construction /demolition in the area would cease and appropriate health and safety procedures should be implemented. 13) If the site was used for agricultural or related activities, onsite soils and groundwater might contain pesticides, agricultural chemical, organic waste or 3 other related residue. Proper investigation, and remedial actions, if necessary, should be conducted under the oversight of and approved by a government agency at the site prior to construction of the project. 4) Envirostor (formerly CalSites) is a database primarily used by the California Department of Toxic Substances Control, and is accessible through DTSC's website. DTSC can provide guidance for cleanup oversight through an 4 Environmental Oversight Agreement (EOA) for government agencies, or a Voluntary Cleanup Agreement (VCA) for private parties. For additional information on the EOA please see www. dtsc. ca.aov /SiteCleanuo /Brownfields, or contact Maryam Tasnif - Abbasi, DTSC's Voluntary Cleanup Coordinator, at (714) 484 -5489 for the VGA. If you have any questions regarding this letter, please contact Ms. Eileen Khachatourians, Project Manager, at (714) 484 -5349 or email at EKhachat@dtsc.ca.gov. Sincerely, Greg Holmes Unit Chief Southern California Cleanup Operations Branch - Cypress Office cc: See next page )J(P Mr. Jamie Murillo October 3, 2007 Page 3 cc: Governor's Office of Planning and Research State Clearinghouse P.O. Box 3044 Sacramento, California 95812 -3044 CEQA Tracking Center Department of Toxic Substances Control Office of Environmental Planning and Analysis 1001 1 Street, 22nd Floor, M.S. 22 -2 Sacramento, California 95814 CEQA#1854 Ali 4. California Department of Toxic Substances Control (October 3, 2007) Response to Comment No. 1 As suggested in this comment, some soil excavation may be required in the future in order to construct the proposed 20,586 square foot structure. Two standard conditions have been prescribed (refer to Section 4.6.3 of the Draft EIR), that address public health and safety issues, including potential contaminated soils. Specifically, SC 4.6 -1 requires that the applicant shall comply with all applicable federal, state and local requirements pertaining to hazardous waste, including issues related to the identification and disposal of contaminated soil. In addition, SC 4.6 -2, which prescribes procedures to address the management and disposal of hazardous waste, will also be implemented as letermined necessary in the event that contaminated soils are encountered Response to Comment No. 2 As recommended in this comment and consistent with SC 4.6 -1, construction occurring in an area where soil and /or groundwater contamination is suspected would cease and appropriate health and safety procedures would be implemented in accordance with all applicable laws and regulations. In addition, both construction and operation - related measures have also been identified to ensure that other contamination that may occur on the site are properly addressed pursuant to regulatory requirements (see Section 4.6.3 of the DEIR). Response to Comment No. 3 As discussed in Section 4.6.1 of the Draft EIR (refer to page 4.6 -1), although the site was used for agricultural production prior to its development (more than 50 years ago), soil testing on the subject property did not reveal the existence of pesticides, agricultural chemicals, or organic waste. Nonetheless, as indicated in this comment, appropriate remedial actions will be conducted in the event concentrations of such contamination is identified in monitoring that is ongoing and recommended for other contaminants identified in prior studies (see SC 4.6 -1 in Section 4.6 -3 of the DEIR). Response to Comment No. 4 Should additional guidance from DTSC be necessary or desired, the applicant will coordinate cleanup efforts with all responsible agencies, including DTSC and the Envirostar database. This comment is acknowledged. Hoag Health Center Responses to Public Comments November2007 Page 5 Letter No. 5 To: Jaime Murillo 16 October 2007 Associate Planner City of Newport Beach From: Environmental Quality Affairs Committee (EQAC) Subject: DEIR, Hoag Health Center Use Permit Amendment, September 2007. EQAC hereby submits our review comments regarding the Subject DEIR. We trust that these will assist you in optimizing the Hoag Health Center project for the benefit of the City of Newport Beach. Although all parts of the DEIR were reviewed, we include comments only on those sections where clarification is needed. 4.2 Traffic and Parking 4.2.4 Potential Impacts (• Project generates a "net' increase in project related daily trip generation I [estimated] to be 12,743 based on NBTAM. • Table 4.2.3 sub note 2 "existing Trip Generation does not reflect UP 06 -010 2 approved by the City of NPB in 12/07 in order to provide a "worse case" analysis of traffic impacts. Include this UP 06-090 approved project in the traffic analysis. $ 1 • Table 4.2 -5, correct footnote 2 (refer to Appendix ??) I • 2025 Traffic Conditions — City of NBP includes the Improvement of the 19th 4 Street bridge, the Costa Mesa does not. How does this affect all of the previous traffic analysis? 5 I • Typo Page 4.2 -21 paragraph 3 indicates "9th Street bridge — reviewer assumed 19m Street bridge. 19 • Traffic Signal warrant analysis: DEIR states that a traffic signal to be 6 installed at Superior Ave./Project Driveway intersection. Does NB have authority to do this or are other approvals required? • Page 4.2 -23: Mitigation Measure 4.2 -2 is confusing because the end of the second paragraph on Page 4.2 -19 states that mitigation is infeasible until such 7 time as the City of Costa Mesa has a mechanism to accept fair share fees to complete that intersection. The paragraph on Page 4.2 -24 should clarify whether Mitigation Measure 4.2 -2 is in or out. As an alternative, inquire with the City of Costa Mesa on how they may accept fair share fees. 4.3 Air Quality The last paragraph on Page 4.3 -15 states that the proposed project would result in 8 potentially significant air quality impacts from long -term operational emissions of four criteria pollutants. The last paragraph on Page 4.3 -16 states that because air quality is improving in the air basin, violation of air quality standards will not likely worsen ) �0� regional air quality, lead to a violation or contribute to a violation. Please cite the research that demonstrates air quality in the air basin will improve in the future. The conclusion on Page 4.3 -16 appears to imply that if regional air quality is forecast to improve, individual projects may exceed long -term operational emission standards. Is this correct? The first sentence on Page 4.3 -21 states that lower vehicular emissions from advanced technology and lower future ambient CO levels will offset the growth in CO concentrations from future traffic increases. Cite the data source that demonstrates the 9 certainty that advanced technology will reduce future vehicular emissions and lower future ambient CO levels. If such information is not available, revise the air quality forecast model to eliminate factors that reduce predictions of future CO levels from vehicular traffic. Truck idling is a potential source of air pollution, increasing the significance of impact in 10 this area. Please provide mitigation to minimize air quality impacts, to include controls on truck idling. 11 12 4.4 Noise As a general comment throughout Section 4.4 of the EIR and in Appendix E concerning Short - and long -term impacts on residents on Superior Avenue and Dana Road: Human hearing and the damaging effects of noise are not linear with respect to any physical measures of sound intensity or frequency. Some frequencies have more damaging effects in the long and short term. Current research suggests that the A- weighted decibels (dBA) scale that LSA Associates uses is outdated, and a more appropriate assessment would use C- weighted measures, which more appropriately captures the effects of low- frequency noise of the kind that will be at issue for the HHC project. For example, using A- weighting, a low frequency noise of 50 Hz, which vibrates homes and is felt in the body, is under measured by 30 dB as compared to 1.3 dB in measurements taken with C- weighting. Overall measurements are under measured by 7 -8 dB with A- weighting as compared to C-weighting. The CNEL measures presented by LSA Associates do not address this criticism. Various industrial sources emit continuous low- frequency noise (compressors, pumps, diesel engines, fans, public works). Heavy -duty vehicles and air traffic produce intermittent low - frequency noise. Low - frequency noise may also produce vibrations and rattles as secondary effects. Health effects due to low- frequency components in noise are estimated to be more severe than for community noises in general (Berglund et al. 1996). Since A- weighting underestimates the sound pressure level of noise with low- frequency components, a better assessment of the impacts to adjacent residents and their health would be to use C- weighting. The World Health Organization's safety recommendations use dBC measures. Although the HHC EIR may be required to conform to The City of Newport Beach dBA criteria, it should be noted that the choice of such criteria are not written in stone and future studies should be asked to present more meaningful measures (e.g., dBC and spectral harmonic analyses) of noise impacts so that an informed evaluation can be done. 2 aO P.4.4 -17, subsection 4.4.5: It is very difficult to evaluate the DEIR assessment of the long -term impact expected from the project's additional vehicular traffic. Is it possible 13 to give an impression of how much additional vehicular traffic is expected during peak work hours, over the projected amounts that are seen due to seasonal (summer) traffic increases and general yearly expected increases? Appendix E prepared by LSA Associates, Inc. roise)? P. 3, para. 1: RE: Two shuttle trips per day. Will loading/unloading occur on Dana 1,4 oad? Will there be through access (to eliminate potential vehicle backup alarm • P. 3, para. 1: Interim 1 -year shuttle service to Hoag Hospital: Need better estimate of noise impacts/durations /mitigations for that year. If it is serving all of Hoag it seems 15 that it could be a significant impact. Is it possible to require that all shuttle pickups /deliveries take place in the area between buildings and parking structures? • P.7, para 1 -2: Measurement of sound using dBA scales. See general comment above about the uninformative value of dBA measures. 16 See, also Berglund B., Lindvall T., Schwela D.H. (eds.) (1999). Guidelines for Community Noise. London:World Health Organization. 17 I • P.16, item N2.3: RE: truck deliveries. Does design component involve drive -thru access to eliminate back up alerts impacting residents throughout the day? • P. 17, "construction noise" item: During construction, noise may range up to 84 — 91 dBA. This is considerable. Is there any way to get a dBC measure (broken out 18 by spectral frequency) of this since it exceeds the ordinance? Also, a project map illustrating the expected daily durations, including the hourly timeframes, at these extreme levels, would be helpful. • P. 24: RE: long -term stationary noise impacts. Not enough is said about how rooftop mechanical units, truck delivery and other activities in the parking lot would generate 19 long -term impacts and if they need mitigation. Also, please analyze the impacts of truck idling on noise, providing estimated duration and decibel levels. If significant impacts are found, provide appropriate mitigation. • P. 25, the top paragraph RE: delivery entrance: "it is assumed that the medical office use loading area (near the front entrance of the building) is at least ... 250 ft from ZQ the residences to the west." Recommend that the option be examined to position receiving between the buildings and the parking structures. It seems that more mitigation is needed for this item. 21 • P. 27: "...no significant noise impacts would occur from the rooftop mechanical units .." Are the HVAC units the only units of concern on the rooftop? Where are the �a� trash compactors and such? Will elevator motors, used nightly by cleaning crews, be positioned on the roof and operating within acceptable noise levels? It is unclear if the design components of the project place these large /noisy devices as far as possible from neighboring residences in an effort to minimize their impact. 5.10 Aesthetics No significant aesthetic impacts are seen to be caused by the proposed construction of the parking structure as well as the other changes to the property related to and included in the amendment. Assuming the continued attention to the goal of minimal aesthetic 22 change, during and after the construction, this will be validated once the construction project is completed. The maintenance of similar sight lines and elevation is very important to this validation of continued aesthetics. Notwithstanding close control of the building and architectural details, aesthetics of the 23 project can be greatly enhanced with proper emphasis on landscaping and judicious use of foliage. Is there a detailed landscape plan that will make the project compatible with planned Superior Avenue beautification? 5.14 Hazards and Hazardous Materials • The DEIR appendices are not numbered in any sequential fashion nor are some of the 24 pages numbered at all. This results in the document being very difficult, cumbersome and time consuming to read. • The DEIR does not include responses to a letter from the Department of Toxic Substances Control item #4 asking the following: "All environmental investigations, 25 sampling and/or remediation for the site should be conducted under a work plan approved and overseen by a regulatory agency.... The findings on any investigations, including Phase I & II investigations, should be summarized in the document." Where are the answer and summary? • A letter from the Department of Toxic Substances Control item #6 asks: Where are 26 the work plans and studies as requested for the above? i.e. — asbestos and lead. 2716 What are the total tonnages to be removed and how will the truck staging take place? What are the traffic, noise and air quality impacts of this truck staging? • Hazardous Materials Checklist, Appendix A, page 19, states that they will comply with all State Agencies with regard to the removal of asbestos (they know that it is there) and lead. The checklist item also indicates, "The LBP and ACM that may 28 exist in the buildings that will remain will be removed prior to the remodeling that will be undertaken to implement the proposed project and demolition of the existing office building. Therefore neither demolition of that structure nor remodeling necessary to convert the existing floor area to medical office floor area would NOT 4 �A�- result in the emission and dispersal of any hazardous materials and/or contaminants within the project area. What does this mean? • Checklist, page 21 states mitigation measures, MM-6, MM -7, and MM -8... Should 29 the prior studies or documents be available to the public in this report to demonstrate how they accomplished these in the past? 9.0 Cumulative Impacts of the Proposed Project. The DEIR states that Cumulative Effects due to 14 projects (' 0 in Newport Beach and 4 in Costa Mesa) were analyzed to show that no additional significant impacts in any environmental area resulted from consideration of these 14 projects. The existing significant/unavoidable impacts on air quality and Newport Blvd. traffic congestion were not worsened despite the impact of these 14 projects. However, many of these projects are far away from this site (e.g. Newport Coast and Newport Ridge) and it is not surprising that they would have minimal affect. Shouldn't development of Westside Costa Mesa mixed use development projects be included in the study? What does future Superior Ave. beautification do to long -term traffic flow in the vicinity of the project? It seems that these projects could be considered in the same context as other "proposed but not approved" projects among the 14 which were considered. These could have significant impacts on traffic on Superior, Placentia and PCH. Thank you for the opportunity to provide these comments on the Subject DEIR for the Hoag Hospital Health Center Project. IaD 5. Newport Beach Environmental Quality Affairs Committee (October 15, 2007) Response to Comment No. t This comment acknowledges the `net" increase in project - related daily traffic generated by the proposed project. No response is necessary. Response to Comment No. 2 The property is a fully developed office and research & development center. It currently consists of 4 buildings totaling 415,493 square feet with a four -level above grape parking garage. Current approvals allow for 57% research & development, research & development/industrial uses (236,832 square feet) and 43% office uses (178,661 square feet). On December 7, 2006 the Newport Beach Planning Commission adopted Mitigated Negative Declaration SCH. No. 2006101105 and approved Use Permit No. 2006 -010 and Traffic Study No. 2006 -001 to allow for 97,000 square feet of medical office uses on the site. The approval also allowed for the demolition of an existing 86,079 square foot building to be replaced with a four -level parking garage. The site was proposed to consist of 97,000 square feet of medical office, 136,000 square feet of general office, and 96,414 square feet of research & development. The approval of the 97,000 square feet of medical office is not taken into account in this study because the proposed project is within two years of the most current approval. Therefore, the trips credited for the most recent approval are not taken into account pursuant to the Traffic Phasing Ordinance (TPO) to avoid double counting trips. The DEIR traffic analysis is sufficient without UP 2006 -010 elements, as it presents the worst cast scenario for traffic. The remainder of the comment, on NBTAM rates, restates DEIR information and does not merit further response. Response to Comment No. 3 As suggested in this comment, Footnote 2 in Table 4.2 -5 shall be corrected to reflect Appendix C (Traffic Impact Analysis). The revised footnote will read as follows: ..2 Approved projects in the City of Newport Beach identified in Table 5 of the Traffic Impact Analysis (refer to Appendix C)." Response to Comment No. 4 As indicated on page 65 of the traffic analysis, inclusion of the 19th Street bridge over the Santa Ana River is consistent with the Orange County Master Plan of Arterial Highways (MPAH). Although the City of Costa Mesa has identified its desire to delete this facility from the MPAH, the bridge has not yet been officially deleted. As a result, the traffic analysis, in order to be consistent with the long -range circulation plan (i.e., MPAH), assumes the extension of 19th Street over the Santa Ana River as reflected on the MPAH. As noted in Section 8 of the traffic study, the proposed project is consistent with the City of Newport Beach General Plan; therefore, no additional long -range analysis is needed. The traffic study reflected the near- term -oadway network (currently, the 19th Street bridge over the Santa Ana River does not exist). The information in Section 8 of the traffic study simply discusses the differences in the City's circulation system. Response to Comment No. 5 This comment is correct in pointing out a typographic error. The reference to the "91h Street bridge" in the first sentence in the third paragraph on page 4.2 -21 will be revised to ,19th Street bridge." The revised language will read as follows: Hoag Health Center Responses to Pubtlo Comments November2007 Page 6 "Based on the City of Costa Mesa General Plan (adopted January 22, 2002), the Costa Mesa City Council policy direction is to delete the 19th Street Bridge over the Santa Ana River from the MPAH." Response to Comment No. 6 The location of the proposed traffic signal is in the City of Newport Beach. As such, approval of this facility rests entirely within the jurisdiction of the City of Newport Beach. Response to Comment No. 7 The Newport Boulevard /181h Street - Rochester Avenue intersection is located within the jurisdiction of the City of Costa Mesa. As indicated in the discussion in Section 4.2.6 of the Draft EIR (refer to page 4.2 -24), the City of Costa Mesa does not have a mechanism for accepting the fair share fee contribution from the applicant intended to pay for the Newport Boulevard /18" Street - Rochester Street improvements identified in MM 4.2 -2. Without such a mechanism, the measure cannot be implemented and is, therefore, infeasible. Further, neither the City of Costa Mesa nor the City of Newport Beach could, by law, force upon an applicant a mitigation measure for a cumulative impact that would have the applicant financing the entirety of an improvement, when only a portion of the impact would be attributable to the impacts of the proposed project. (See e.g., 14 Cal. Code Regs. § 15126.4(a)(4))B); 14 Cal. Code Regs. § 13130(a)(3); Napa Citizens for Hones Govt v. Napa County Bd. of Supervisors 91 Cal. App. 41h 342, 364 (2001); and Costa Mesa Mun. Code § 13 -275.) Because there is no current assurance that MM 4.2 -2 is legally feasible, the mitigation measure was not relied upon to mitigate cumulative impacts, and the DEIR properly concluded that the anticipated project - related cumulative impact at the Newport Boulevard /18" Street - Rochester would remain significant and unavoidable, necessitating the adoption of a Statement of Overriding Considerations in order to approve the proposed project. Response to Comment No. 8 The South Coast Air Quality Management District (SCAQMD) 2007 Air Quality Management Plan (2007 AQMP) has incorporated the projections of future criteria air pollutant concentrations in the South Coast Air Basin (SCAB) that includes Orange County and shows that air quality in the SCAB will improve in the coming years. The projections have factored in the anticipated improved vehicle exhaust due to fleet change (older cars replaced by newer cars with much lower emission levels) and other improvements (reduction of emissions from stationary sources due to new laws restricting emissions to lower levels). With the overall improvement trend in the SCAB region, emissions associated with an individual project, even if the emissions would exceed the emission thresholds recommended by the SCAQMD, are not expected to affect the target attainment date identified in the 2007 AQMP by the SCAQMD. Therefore, a project can exceed the SCAQMD emission thresholds, as long as it also implements all feasible mitigation measures, as proposed in the Draft EIR, and clearly discloses the potential impacts, and not after the projections identified in the AQMP. As indicated in page 4.3 -22 of the Draft EIR, direct increases in population growth are not anticipated. Because the project is consistent with the long -range adopted land use plan, any indirect growth associated with the proposed project would be within the City's General Plan projection and, therefore, consistent with the AQMP. Response to Comment No. 9 The California Air Resources Board issued the latest emission prediction model, EMFAC2007, which incorporates the current and projected fleet mix from vehicles in many areas of California. A discussion of the methodology utilized to quantify the project - related air pollutant emissions, is presented on page 20 of Appendix D (Air Quality Analysis) in the Draft EIR. As indicated in that discussion, the URBEDMIS 2007 model was used to estimate project - related mobile and station sources emissions because air quality models identified in the CEQA Air Quafrty Handbook (April 1993), which provides guidance and prescribes Hoag Health Center Responses to Public Comments November2007 Page 7 the requirements to conduct air quality analysis, are outdated. The EMFAC2007 model provides emission factors for several criteria pollutants, including carbon monoxide (CO), for current and future years. The CO emission factor for future years are projected to decrease gradually from its current year level. In addition, CO concentrations monitored at all Orange County monitoring stations show a consistent decreasing trend over the years. The 2007 AQMP also includes the assumption that CO concentrations for future years will be lower than their current levels (refer to Response to Comment No. 8). Both ARB's EMFAC2007 and SCAQMD's 2007 AQMP help confirm the statement that lower vehicular emissions from advanced technology and lower future ambient CO levels will offset the growth in the CO concentrations from future project - related traffic increase. Response to Comment No. 10 The Air Resources Board (ARB) has established a rule (refer to Section 3585 within Chapter 10 — Mobile Source Operational Controls, Article - Motor Vehicles, Division 3, Air Resources Board, Title 13, California Code of Regulations) to prohibit trucks from idling more than 5 minutes while loading or unloading. This rule will be included by the City of Newport Beach as a standard condition to minimize air emissions associated with idling trucks. In addition, MM 4.3 -1d requires that the work crews will shut off equipment when not in use to further reduce pollutant emissions. Response to Comment No. 1 f The Noise Element of the Newport Beach General Plan identifies nose sensitive land uses and noise sources, and defines areas of noise impact for the purpose of developing policies to ensure that residents in the City will be protected from excessive noise intrusion. The information contained in the document provides the framework to achieve compatible land uses and provide baseline levels and noise source identification for local noise ordinance enforcement. The Noise Element policies and thresholds of significance utilize the A- weighted decibels (dBAs) as the standard unit of measurement. Additional, the City's Community Noise control Ordinance (Chapter 10.26 of the Municipal Code) utilizes A- weighted decibels as the standard unit of measurement for establishing maximum interior and exterior noise standards. The A- weighted decibel level has been used in all federal, State, and local noise criteria because it has been proven that it can best reflect human hearing, including the potential harmful effects such as hearing damage or temporary/permanent hearing threshold shift. For example, the Occupational Safety and Health Administration (OSHA) has established a criterion that if a workplace that would expose workers to noise levels exceeding 90 dBA continuously for more than 8 hours, then a hearing protection program, such as workers wearing hearing protection gear or reduce the work hours to less than 8 hours, would need to be implemented. Therefore, unless the noise levels exceed 90 dBA, no immediate or long -term hearing damage would occur. Guidelines for Community Noise by WHO (edited by Birgitta Bertlund, Thomas Lindvall, and Dietrich H. Schwela) cited by the commenter uses the A- weighted dB levels in its Guidelines Values for Community Noise in Specific environments (Table 41 on page 65 of that document). In addition, in subsection 2.3.3 on page 28 of the WHO document (Frequency Content and Loudness) states that "A- weighted measures have been particularly criticized as not being accurate indicators of disturbing effects of noises with strong low frequency components. However, these differences in prediction accuracy are usually smaller than the variability of responses among groups of people. Thus, in practical situations the limitations of A- weighted measures may not be so important." Therefore, the use of C- weighted noise level is neither warranted nor required. Hoag Health Center Responses to Public Comments November2007 Page 8 Iaki> Response to Comment No. 12 Noise associated with the proposed project is not expected to have substantially high volume of low frequency noise referred to by the commenter that could potentially cause harmful health effects at adjacent uses. As indicated in Response to Comment No. 11, the limitations of utilizing the A- weighted measure is not inappropriate for evaluating community noise levels "in practical situations." Further, because the City, which recently (2006) updated the General Plan, including the Noise Element, continues to rely on utilizing the A- weighted noise measurement scale in evaluating noise impacts in the City, which is consistent with the State of California Noise guidelines. For that reason, the noise analysis that evaluated the potential project - related impacts followed the current methodology utilized by the City of Newport Beach. The suggestion in this comment that the City determine in the future that the 0-weighted noise measurement standard is more appropriate in evaluating future projects is acknowledged; however, that suggestion, which may result in a change in City policy, is more appropriately directed to the City Council for consideration outside the context of the proposed project. Response to Comment No. 13 The traffic generated by the project is determined by multiplying an appropriate trip generation rate by the quantity of land use. Trip generation rates are predicated on the assumption that energy costs, the availability of vehicles to drive, and our fife styles remain similar to what we know today. A major change in these variables may affect trip generation rates. Trip generation rates were determined for daily traffic, morning peak hour inbound and outbound traffic, and evening peak hour inbound and outbound traffic for the proposed land uses. By multiplying the traffic generation rates by the land use quantities, the project- generated traffic volumes are determined. Table 2 of the traffic study exhibits the traffic generation rates. The City of Newport Beach trip generation rates are derived from the Newport Beach Traffic Analysis Model (NBTAM). The traffic analysis analyzes average weekday conditions. Based upon City of Newport Beach (NBTAM) rates (see Table 3 of the traffic study), the proposed project is projected to generate a total of approximately 17,500 daily vehicle trips, 1,050 (840 inbound /210 outbound) of which would occur during the morning peak hour and 1,750 (525 inbound /1,225 outbound) of which would occur during the evening peak hour. The trip generation rates are for average weekday conditions and the project trip generation is based upon 350,000 square feet of medical office (see Table 3 of the traffic study). Response to Comment No. 14 This comment mistakenly indicates that two shuttle trips per day will occur. The proposed shuttle service will operate four round trips per hour between 7:00 a.m. and 7:00 p.m. between the site and Hoag Hospital each day. (The number of shuttle trips was increased from two trips per hour, as reported in the Draft EIR, to four trips per hour; refer to the Hoag Health Center Draft EIR Errata). All loading and unloading will take place within the limits of the Hoag Health Center property and not along the roadways that serve the existing residential development on Dana Road and Flagship Road. The shuttle will enter the site from the southern entrance on Superior Avenue and exit the site from the northern access on Superior Avenue. Shuttle riders will be picked up and/or dropped off in the interior portion of the site; no loading/unloading will take place along Dana Road and the shuttle will note be allowed to travel on Dana Road or Flagship Road as indicated on page 4.2 -22 of the DEIR. Because the shuttle service within the boundaries of Hoag Health Center will be directed in a one -way pattern, it is anticipated that there will be no need for the shuttle to back up and, consequently, no expectative that there will be any back -up alarms from the shuttles. In the future, at ultimate buildout of the project, the pick -up and drop -off will occur between the existing medical office buildings and the parking structures. Hoag HeaRh Center Responses to Public Comments November 2007 Page 9 �a� Response to Comment No. 15 It should be noted that the shuttle proposed for the project is not "interim" as suggested in this comment. Rather, the shuttle will operate permanently between the Hoag Health Center and the Hoag Hospital Main Campus to facilitate movement of patients and medical staff between the two locations. The traffic and noise impact analyses included the shuttle bus trips along the access roads from Hoag Health Center. In addition, the loading /unloading and parking lot activity poise analysis included potential shuttle bus loading and unloading activities anticipated to occur within the project site (no loading /unloading will occur on Dana Road). Based on the findings of these analyses, no significant noise impacts would occur. As indicated in Response to Comment No. 14, in the short-term (i.e., prior to "buildout" with the remaining 20,586 square feet of medical office floor are 3) shuttle pickups and deliveries would occur at the designated locations within the limits of the subject property analyzed in the traffic access study. It is anticipated, however, that pick -up and drop -off would occur between the buildings and the parking structures upon buildout of the site as proposed. Further, shuttle and truck circulation through the site would occur via a continuous 'loop" to avoid the need to back -up. As a result, back -up alarms from the shuttle are not anticipated. Response to Comment No. 16 Please refer to the response to the general comment on dBA vs. dBC in Response to Comment No. 11. As suggested in that response the C- weighted noise measurement is not warranted unless long -term noise levels exceed 90 dB. The long -term analysis presented in the Draft EIR (refer to Section 4.4.2 on page 4.4 -9) concludes that long -term noise levels would not exceed 90 dBA. Response to Comment No. 17 Similar to shuttle passenger loading and unloading on the site, trucks will enter and exit the Hoag Health Center property at the same access locations, which will facilitate the on -site truck circulation. Trucks will access the site from either the southern or main drive access and will access the building from the peripheral drives, exiting the site from the main or northern access. It is not anticipated that 'backup° alerts would be used on a regular basis during the day because the truck traffic through the site will be directed in a one -way direct through the site with little expectation of any back -up alarms. Response to Comment No. 18 Construction noise in the City is regulated by Section 10.28.040 (Construction Activity — Noise Regulations) of the Municipal Code, which does not establish maximum noise levels, but rather limits the hours of noise - generating construction activities to between the hours of 7:00 a.m. and 6:30 p.m., Monday through Friday and 8:00 a.m. and 6:00 p.m. on Saturday. No violation of the noise ordinance would occur. Although construction equipment could result in short-term, intermittent, maximum noise levels reaching 84 to 91 dBA Lmax, this range of maximum noise levels is comparable to the noise levels generated by vehicle passby along arterials. As construction equipment moves around the project site, this maximum noise would occur only intermittently at specific locations adjacent to the project site and mapping of the maximum noise level by construction equipment is not feasible or warranted. Please also refer to the responses to the general comment on dBA vs. dBC in Response to Comment No. 11. Response to Comment No. 19 Noise associated with rooftop mechanical units, truck delivery /loading/unloading and activities in the parking lot, including truck idling while loading /unloading, has been evaluated in detail (refer to page 4.4- 14 through 4.4 -16 of the Draft EIR). Based on the analysis conducted for the project by LSA and included in the Draft EIR, no significant noise impacts were found from these activities (refer to page 4.4 -17. Hoag Health Center Responses to Public Comments November2007 Page 10 / 1 l iU! Response to Comment No. 20 Noise associated with loading /unloading associated with the medical offices has been evaluated and no significant impacts were found (refer to page 4.4 -14 in the Draft EIR). The option to position receiving between the buildings and the parking structures is a site design issue and would not be required for noise mitigation purposes. Response to Comment No. 21 The location of trash compactors and related features is a design issue that will be subject to review by the City of Newport Beach during the elan c'ieck process. Nonetheless, trash compactors and elevator motors would be designed and operated to meet the noise ordinance requirement. As currently proposed, mechanical units will be enclosed. As a result, the enclosed rooftop HVAC units would not have any significant noise impacts because the enclosure would provide sufficient noise attenuation. Response to Comment No. 22 This comment acknowledges the conclusion of 'less than significant' aesthetic impacts presented in the initial study prepared for the proposed project. No response is necessary. Response to Comment No. 23 Although some modifications associated with the new 20,586 square foot structure proposed within the site are anticipated that would require landscape modifications in the area where that development would take place, project implementation will not result in any physical changes along Superior Avenue and, therefore, will not result in changes to the landscape character along that roadway. As a result, both the architectural and landscape character of the existing and future site development will not affect the Superior Avenue beautification improvements that will be implemented by the City, as the site characteristics along Superior Avenue will not change. Response to Comment No. 24 Although the technical studies (i.e., traffic, noise, and air quality) reflect page numbers, the appendices of those studies (e.g., computer output sheets, letters, etc.) were not numbered. This comment, which suggests that the lack of page numbering of those materials is acknowledged and the appendices will be numbered with the preparation of the Final EIR. Response to Comment No. 25 The preface to Section 4.6 (refer to page 4.6 -1) indicates that the analysis of public health and safety is based on the Phase I Environmental Site Assessment (ESA) and related studies (refer to page 12 -1 of the Draft EIR) conducted on the subject site to evaluate the potential health and safety impacts resulting from project implementation. As indicated in the preface (and requested in this comment), the findings and recommendations of those reports are summarized in Section 4.6 of the Draft EIR. All of the applicable studies are available for public review at the City of Newport Beach in the Planning Department. Response to Comment No. 26 The NOP comment referenced here by the EQAC relates to the preliminary analysis presented in the Initial study conducted for the proposed project. Since the preparation of the initial study, subsequent analysis was conducted that determined that all of the ACM and LBP has been removedlabated from the existing structures. The surveys documenting the removal /abatement of the asbestos containing materials (ACM) and lead -based paint (LBP) in the existing structures are also available at the City of Newport Beach. Hoag Health Center Responses to Public Comments November2007 Page f t r� Response to Comment No. 27 As indicated in the response to Comment No. 26, project implementation does not require the removal/abatement of ACM and/or LBP from the structures. Further, demolition of existing structures is not proposed; therefore, no hazardous materials will be removed from the site that would generate heavy truck traffic and, consequently, additional noise and air quality impacts. Response to Comment No. 28 The discussion cited in this comment from the initial study makes reference to the demolition of the existing structure that will be replaced by the parking structure that was approved as part of UP 2006 -010 in December 2006. The potential impacts associated with the prior Use Permit have been evaluated and addressed through mitigation measures prescribed as part of the environmental analysis conducted for that project. As indicated in the response to Comment No. 26 check out, all of the ACM and LBP has been removed /abated. Therefore, project implementation would not result in any emissions (i.e., dispersal) of hazardous materials and /or contaminants (e.g., ACM and LBP) from the project site. Response to Comment No. 29 All prior studies related to the site's environmental characteristics are available at the City of Newport Beach (Planning Department) for review. Provision of the studies with the Draft EIR is not needed because issues discussed in the prior studies related to prior approvals and not to the proposed project. Response to Comment No. 30 During the environmental review process, the City of Costa Mesa was contacted and the list of "related" (i.e., cumulative) projects in the City at the time the Notice of Preparation (NOP) was distributed was provided by the City. The Westside Costa Mesa mixed use development projects were not identified by the City and, therefore, were not included in the analysis of cumulative project. Further, the Superior Avenue beautification project, which has been proposed by the City of Newport Beach, includes the integration of landscape medians along portions of Superior Avenue; however, the improvements do not extend north of Dana Road in the vicinity of the project site and, more importantly as it relates to traffic flow and vehicle capacity, no changes to the existing number of travel lanes along Superior Avenue are proposed by the City's beautification project that would adversely affect the capacity of that roadway. Therefore, implementation of the Superior Avenue beautification project improvements will not result in any long -term cumulative impacts to traffic in conjunction with the implementation of the proposed project. Hoag Health Center Responses to Publho Comments November 2007 Page 12 October 19, 2007 Jaime Murillo, Associate Planner City of Newport Beach Planning Department 3300 Newport Boulevard Newport Beach, CA 92658 -8915 12i CVP," �4t OCT 22 2;i C9jy OF NEkA�°D Iq? BEACH SUBJECT: DEIR —Hoag Health Center Use Permit Amendment Dear Mr. Murillo: NCL 07 -032 The above mentioned item is a DEIR for Hoag Health Center Use Permit Amendment located in the City of Newport Beach. The County of Orange has reviewed the DEIR and offers the following comments regarding Water Quality concerns: WATER QUALITY 1. The DEIR states that the water quality impacts from the project will be less than significant since the project site is currently developed and almost completely impervious. The proposed project is considered a priority project under the 2003 Countywide Drainage Area Management Plan (DAMP). Additionally, the project location is within the sensitive Newport Bay watershed, which has multiple 303(d) listings and Total Maximum Daily Loads assigned. Redevelopment of the scope of proposed project has the potential to cause significant water quality impacts during both the construction and post- construction phase. The EIR should evaluate these potential impacts as follows: The water quality impacts of the project should be evaluated in accordance with the provisions outlined in Exhibit 7 -1 of the 2003 Countywide Drainage Area Management Plan (DAMP). At a minimum, the following information should be provided: a. A description of project characteristics with respect to water quality issues, such a§ project site location in a given watershed, site acreage, change in percent impervious surface area, and BMPs to be incorporated into the project design. t�` Letter No. 6 - COUNTY OF ORANGE Bryan spn gte, Director Flow� Street 300 N. Santa Ana, CA U M P.O. Box 4048 O � RESOURCES& DEvELoPMENTATANAGEMENTDEPARTMENT Santa Ana, CA 92702 -4048 �LIFOR Telephone: (714) 834 -2300 Fax: (714) 834 -5188 October 19, 2007 Jaime Murillo, Associate Planner City of Newport Beach Planning Department 3300 Newport Boulevard Newport Beach, CA 92658 -8915 12i CVP," �4t OCT 22 2;i C9jy OF NEkA�°D Iq? BEACH SUBJECT: DEIR —Hoag Health Center Use Permit Amendment Dear Mr. Murillo: NCL 07 -032 The above mentioned item is a DEIR for Hoag Health Center Use Permit Amendment located in the City of Newport Beach. The County of Orange has reviewed the DEIR and offers the following comments regarding Water Quality concerns: WATER QUALITY 1. The DEIR states that the water quality impacts from the project will be less than significant since the project site is currently developed and almost completely impervious. The proposed project is considered a priority project under the 2003 Countywide Drainage Area Management Plan (DAMP). Additionally, the project location is within the sensitive Newport Bay watershed, which has multiple 303(d) listings and Total Maximum Daily Loads assigned. Redevelopment of the scope of proposed project has the potential to cause significant water quality impacts during both the construction and post- construction phase. The EIR should evaluate these potential impacts as follows: The water quality impacts of the project should be evaluated in accordance with the provisions outlined in Exhibit 7 -1 of the 2003 Countywide Drainage Area Management Plan (DAMP). At a minimum, the following information should be provided: a. A description of project characteristics with respect to water quality issues, such a§ project site location in a given watershed, site acreage, change in percent impervious surface area, and BMPs to be incorporated into the project design. t�` 2 Jaime Murillo NCL 07 -032 Page 2 b. A review of DAMP Exhibit 7.1 Table 7 -1.1, Priority Projects Categories. This project is considered a Priority Project and will require the development of a Water Quality Management Plan. c. Identification of receiving waters. The EIR should identify all receiving waters that may receive runoff from the project site. d. A description of the sensitivity of the receiving waters. In particular the DEIR should identify Areas of Special Biological Significance, water bodies with Total Maximum Daily Loads (TMDLs), 303(d) listed impaired water bodies. e. A characterization of the potential water quality impacts from the proposed Project and identification of the anticipated pollutants to be generated by the project. f. An identification of hydrologic conditions of concern, such as runoff volume and velocity; reduced infiltration, and increased flow, frequency, duration, and peak of storm runoff. g. An assessment of project impact significance to water quality. h. An evaluation of thresholds of significance. I. if a proposed project has the potential to create a major new sormwater discharge (major land development project that has the potential to convert large amounts of pervious land surface to impervious surface area) to a water body with an established TMDL, the EIR should consider quantitative analysis of the anticipated pollutant loads in the sormwater discharges to the receiving waters. J. A reasonable analysis of the cumulative impacts of the proposed project together with past, present and reasonably anticipated future projects (related projects) that could produce cumulative impacts with the proposed project. 2. The EIR should describe implementation of post - construction Best Management Practices (BMPs) consistent with the Water Quality Management Plan (WQMP) program in Section 7 and Exhibit 7 -11 of the 2003 Countywide DAMP. This includes describing commitments to installation and maintenance of site design, source control and treatment control BMPs consistent with the DAMP New Development and Significant Redevelopment Program. Under the new Municipal Stormwater NPDES permit and the 2003 DAMP, this project will be considered a priority project and will require appropriately sized treatment control BMPs to be included in the WQMP which should be targeted to address the pollutants of concern and to achieve the highest level of treatment either singly or in combination (see Table 7.2 -6). �3 Jaime Murillo NCL 07 -032 Page 3 13. Mitigation for the construction phase of the project should include compliance with 3 the State General Construction Permit and the inclusion of the following as general or specific notes on project plan sheets: a. Sediment from areas disturbed by construction shall be retained on site using structural controls to the maximum extent practicable. b. Stockpiles of soil shall be properly contained to eliminate or reduce sediment transport from the site to the streets, drainage of facilities or adjacent properties via runoff, vehicle tracking, or wind. c. Appropriate BMPs for construction- related materials, wastes, spills or residues shall be implemented to minimize transport from the site to streets, drainage facilities, or adjoining properties by wind or runoff. d. Runoff from equipment and vehicle washing shall be contained at construction sites unless treated to reduce or remove sediment and other pollutants. e. All construction contractor and subcontractor personnel are to be made aware of the required best management practices and good housekeeping measures for the project site and any associated construction staging areas. f. At the end of each day of construction activity all construction debris and waste materials shall be collected and properly disposed in trash or recycle bins. g. Construction sites shall be maintained in such a condition that a storm does not carry wastes or pollutants off the site. Dischargers other than stormwater (non - stormwater discharges) are authorized under California's General Permit for Storm Water Discharges Associated with Construction Activity only where they do not cause or contribute to a violation of any water quality standard and are controlled through implementation of appropriate BMPs for elimination or reduction of pollutants. Non- stormwater discharges must be eliminated or reduced to the extent feasible. Potential pollutants include but are not limited to: solid or liquid chemical spills; wastes from paints, stains, sealants, solvents, detergents, glues, lime, pesticides, herbicides, fertilizers, wood preservatives, and asbestos fibers, paint flakes or stucco fragments; fuels, oils, lubricants and hydraulic, radiator or battery fluids; concrete and related cutting or curing residues; floatable wastes, wastes from any engine /equipment steam cleaning or chemical degreasing; wastes from street cleaning; and superchlorinated potable water line flushing and testing. 0 Jaime Murillo NCL 07 -032 Page 4 During construction, disposal of such materials should occur in a specified and controlled temporary area on -site physically separated from potential stormwater runoff, with ultimate disposal in accordance with local, state and federal requirements. Discharging contaminated groundwater produced by dewatering groundwater that has infilt ated into construction site is prohibited. Discharging of contaminated soils via surface erosion is also prohibited. Discharging of non- contaminated groundwater produced by dewatering activities requires a National Pollutant Discharge Elimination System (NPDES) permit from the Santa Ana Regional Water Quality Control Board. If you have any questions, please contact Sally Hohnbaum at (714) 834 -5907. Ronald L. Tippetpl Chief Current and Environmental Planning 04 6. Orange County Resources Development & Management Department (October 19, 200') Response to Comment No. 1 As stated both in the Initial Study (page 22 of Appendix A of the DEIR) and in the project description (section 3.4 of the DEIR), the proposed project will not involve construction of a substantial amount of new structures. The proposed improvements will occur as modifications to the interiors of the existing structures to accommodate the conversion of the structures to medical office floor area from the existing R &D and general office uses. With the exception of the 20,586 square foot structure proposed to be constructed in the future, no other new development requiring site modification is proposed. It would appear that the commenter may be basing its comments on a misunderstanding regarding the proposed project, assuming that much more new construction /redevelopment exposed to the elements is proposed than is actually involved in the proposed project. The existing, mostly- impervious condition of the site will be largely unchanged with the implementation of the proposed project, with the only addition of any impervious areas being the new 20,586- square -foot building. As per the requirements of the City's Local Implementation Plan (LIP), implementing the County -wide Drainage Area Management Plan (DAMP), the proposed project was evaluated against the thresholds of significance found in both the DAMP and LIP. Per that analysis, found in the Initial Study on pages 22 -27 of Appendix A of the DEIR, the City found that the proposed project would have either no impact or a less than significant impact regarding water quality and hydrology for both the construction and long -term operational phases. In accordance with CEQA regulations, given the conclusions of less than significant water quality and hydrology impacts, no additional analysis of water resource issues of the type suggested by the commenter is required beyond the analysis presented in the Initial Study and summarized in section 5.5 of the DEIR. (14 Cal. Code Regs. §15128.) Response to Comment No. 2 Section A -7 (New Development/Significant Redevelopment) of the City's LIP prescribes several conditions of approval for projects such as the proposed project. As such, the following conditions will be applied by the City to the future development of the proposed 20,586 square foot structure incorporated into the proposed project: Prior to the issuance of any grading or building permits, the applicant shall submit to the City for review and approval a Project Water Quality Management Plan (WQMP) that: Discusses regional or watershed programs (if applicable); Addresses Site Design Best Management Practices (BMPs) (as applicable) such as minimizing impervious areas, maximizing permeability, minimizing directly connected impervious areas, creating reduced or "zero discharge" areas, and conserving natural areas; - Incorporates the applicable Routine Source Control BMPs as defined in the DAMP; - Incorporates Treatment Control BMPs as defined in the DAMP; - Generally describes the long -term operation and maintenance requirements for the Treatment Control BMPs; - Identifies the entity that will be responsible for long -term operation and maintenance of the treatment Control BMPs; and - Describes the mechanism for funding the long -term operation and maintenance of the Treatment Control BMPs. Hoag Health Center Responses to Public Comments November2007 Page 73 10 Prior to grading or building permit closeout and/or the issuance of a certificate of use or a certificate of occupancy, the applicant shall: Demonstrate that all structural BMPs described in the Project WQMP have been constructed and installed in conformance with approved plans and specifications; Demonstrate that the applicant is prepared to implement all non - structural BMPs described in the Project WQMP; Demonstrate that an adequate number of copies of the approved Project WQMP are available for the future occupiers; Submit for review and approval by the City an Operations and Maintenance (O &M) Plan for all structural BMPs. As discussed on page 25 of the Initial Study (Appendix A of the DEIR), a Water Quality Management Plan (WQMP) has been prepared for the existing development approved for the Hoag Health Center project site. The WQMP prepared for the subject property will be updated to comply with current and future requirements prescribed by the City's LIP, including the incorporation of elements required by the LIP and as stated in the conditions of approval quoted above and including incorporation of site design, source control and treatment control Best Management Practices (BMPs) as required by the LIP. The only aspect of the proposed project that will trigger the need to revise the WQMP will be the construction of the new 20,586 square foot building, as all other project aspects will involve remodeling of building interiors. The new building proposed by the proposed project would qualify as a "Priority Project," per the City's LIP, and the future modification of the subject property's WQMP would be revised consistent with the requirements for Priority Projects with respect to the new building. To this end, the revisions to the WQMP will incorporate specific BMPs to address the specific hydrologic and water quality characteristics of the proposed new building ensuring that all BMPs proposed will act in concert to address any potential pollutants of concern or hydrologic conditions of concern identified as part of the WQMP revisions. As required by the City's LIP, the revisions to the WQMP necessitated by the proposed will also account for any downstream sensitive water resources, including any identified impairments and will ensure that selected treatment BMPs for the new building address downstream impairments as required by the LIP. Because the subject property is presently developed, and because implementation of the WQMP revisions required per the City's LIP will involve the implementation of the BMPs (including treatment controls) not presently incorporated into the existing development at the project site, it is expected that surface water quality runoff from the proposed project could improved over the existing conditions. Response to Comment No. 3 Section A -7 (New Development/Significant Redevelopment) of the City's LIP prescribe a condition of approval that will apply to the future development of the proposed 20,586 square foot structure incorporated into the proposed project; the relevant condition of approval that will be imposed by the City follows: Prior to the issuance of any grading or building permits for projects that will result in soil disturbance of one or more acres of land, the applicant shall demonstrate that coverage has been obtained under California's General Permit for Stormwater Discharges Associated with Construction Activity by providing a copy of the Notice of Intent (NOI) submitted to the State Water Resources control Board and a copy of the subsequent notification of the issuance of a Waste Discharge Identification (WDID) Number. Projects subject to this requirement shall prepare and implement a Stormwater Pollution Prevention Plan ( SWPPP). A copy of the current SWPPP shall be kept at the project site and be available for City review on requires. As prescribed in Section A -7.5.5 (Plan Check: Issuance of Grading or Building Permit) of the City's LIP, construction activities for the new 20,586 square foot building will comply with the Statewide General Permit for Stormwater Discharges Associated with Construction Activity. Compliance with this General Hoag Health Center Responses to Public Comments November2007 Page 14 1 3(° Permit will require implementation and maintenance of BMPs during the construction phase that meet the technology -based standards of the General Permit and that ensure runoff from the future construction site does not cause or contribute to exceedances of water quality standards in downstream waterways. Additionally, compliance with the City's LIP will require inclusion in the plan notes, requirements suggested by the commenter (plan note requirements included in the City's LIP are nearly identical those plan notes suggested by the commenter, with only minor non - substantive differences). Through inclusion of the plan notes and adherence to the requirements of the General Permit and conditions of approval discussed above, runoff during the construction phase will not significantly impact water quality (see page 25 of the Initial Study included as Appendix A of the DEIR). Hoag Health Center Responses to Public Comments November2007 Page 15 y %� 1 ✓1 DEPARTMENT.OF TtANSPORTATION District 12 3337 Wd ICNQn DI1VU, SLULe 380 Irvinc, CA 92612.8894 Tel: (949) 724-2241 Fu; (949) 724 -2592 FAX & MAIL October 22, 2,007 i Jaime Murilld File: IGR/C] City ofNewport Beach SCR #: 2006 3300 Newport Bou.l6vard Log #: 1790, Newport Beach, California 92685 PCH, SR -55 Subject: Hoag Health Center Dear Mr. Murillo, Thank you for the ppportunity to review and comment on the Draft Environs Report (DEIR) slid Traffic Impact Analysis for the Hoag Health Centel applicant Newport teach Healthcare Center, is requesting the approval of an am existing use petxnit;to allow the conversion of the rernaining 232,414 square fe< medical offices, an.ii construction of an additional 20,586 square feet of rnedi ancillary uses on -siic. Then project site is located on 500 -540 Superior ,Avenue Newport Beach. Th6 nearest State routes to the project site are PCH and SR -55. Caltrans District i2 is a responsible agency on this project and we have comments: , 1 12. 2 13. 3 As shown in Table 10 of the Traffic Impact Analysis (pg. 64), the following v or will be.experlencing LOS' of 6 or worse. Volume capacity ratio increase t those intersections will be 1% or above (Table 9, pg. 55). Please iden measures for the following intersections: ■ Nev. Sort Boulevard at 196 Street — LOS P, V/C ratio increase 1.2% • Newport Boulevard at 18' Street — LOS F, V/C ratio increase 0.9■% " Newtort Boulevard at 17th Street —LOS F, V/C ratio increase 2,5% ■ West,, Coast Highway at Superior Avenue -- LOS very close B, V/C: This project is M icipated to adversely impact intersection turning pockets, noted that demlurds at turning pockets are at or reaching capacities. Plea storage Length autalysls for left mid right turn pockets at the intorsoction Boulevard and PICH within the study area. Letter No. 7 Flux yoHrgower.' Be aneryy GFdMil 1105 ,utai Impact project. The tdtnent to the office use to d office and i the City of following ,rsectrons are the project at mitigation 3.5% It should be provide the on Newport On Page 67, the report states tttat a Synehro Analysis has been conducted long Superior .Avenue. NmAt Boulevard may also be impacted by the project. Theref re, a Synchro Analysis should! also be conducted for intersections along Newport Boulevard. Please submit additional. Synaro ;files accordingly. Pas+t. -R" Fax Note 7671 rn J�iel^� MUr "a, O irem 1 ,eV't J"1 R r� co.lOopt. Cn{ fik„L or�i3arla'- C��kran Oesslru4t'1. pha,au `I`i`i 6`1y 32a�t Phwew "tK5 'Yiy 12. +11 Fax M , �,) e,( y-LZ Rix N 17 U Please continue to neap us in-formed of this project and any future developments which could potentially impact t�e State Transportation Facilities. If you have any questions or need to contact us, please do, not hesitate to call Marlon Regisfoad at (949) 724 -2241. i a Sincerel ' ZR . Ch , $rancLoal Develt%itergovemmental Review C: Terry Roberts, Office of Planning and Research "Wirana fmprom mobility across Calj/Lwnla" } f 1 �R California Department of Transportation (October 22, 2007) Response to Comment No. f Table 10 of the traffic study (Appendix C of the DEIR) shows the Delay increase (in seconds) at the study area intersections required by the California Department of Transportation based upon the Notice of Preparation comments for the Hoag Health Center project. Section 6 of the traffic study states that the project will result in a significant impact at a study area intersection if the project generates an increase of one - percent or more at a study area intersection operating at worse than Level of Service D during the morning /evening peak hours. Based upon the City of Newport Beach traffic study guidelines, a significant impact is based upon the Intersection Capacity Utilization methodology. Based upon the Intersection Capacity Utilization (volume to capacity ratios) shown in Table 9 of the traffic study, the following Levels of Service are projected at the study area intersections: • Newport Boulevard at 19th Street Not worse than Level of Service D. • Newport Boulevard at 18th Street — ICU increase greater than 1 %. The project will contribute its fair share toward improvements or alternative mitigation measures determined to be appropriate (providing equal or better effectiveness) by the City of Costa Mesa. • Newport Boulevard at 17th Street — Not worse than Level of Service D. West Coast Highway at Superior Avenue — Not worse than Level of Service D. Response to Comment No. 2 The study area intersections where the project is projected to utilize the left and right turn lanes on a California Department of Transportation (Caltrans) facility are analyzed below. The projected average queue has been obtained from the Delay worksheets in Appendix G of the traffic study (Appendix C of the DEIR). Existin + Approved Pro'ects + Cumulative Projects + Project Traffic Conditions Queue (Number of Queue Intersection Turning Movement vehicles per lane Length Satisfied? Morning Evening Newport Boulevard (NS) at: Northbound Harbor Boulevard (EW) Left 4 12 Yes Newport Boulevard (NS) at: Southbound 17th Street (EW) Right N/A N/A N/A Newport Boulevard (NS) at: Southbound Industrial War (EW) Right N/A N/A N/A Newport Boulevard (NS) at: Northbound Hospital Way EW ) Left 8 11 No Newport Boulevard (NS) at: Southbound West Coast Highway EW ) Left 8 10 Yes Superior Avenue (NS) at: Eastbound West Coast Highway EW Left 13 10 Yes N/A = Not Applicable, right turn lane shared with through lane. Hoag Health Center Responses to Public Comments November2007 Page 16 ,ill With regard to the Newport Boulevard/Hospital Road intersection, the DEIR identified project impacts to this intersection (refer to page.4.2 -16). The preceding table shows an increase to the impacts for which mitigation would be required. The mitigation measure to be added to the DEIR (see Errata to the DEIR) that addresses queuing is as follows: MM 4.2 -3 Prior to the issuance of any medical office tenant improvement permits causing the site to exceed 97,000 square feet of medical office floor area, the applicant shall post a 10 -year bond to lengthen the northbound left turn lane at the intersection of Newport Boulevard /Hospital Way to provide sufficient storage length. The City will be responsible for completing the roadway improvements and the applicant shall reimburse the City for all costs associated with the improvements. With the addition of this MM 4.2 -3 and in light of the analysis presented above, traffic impacts related to queuing at Caltrans facilities, inclusive of the intersection at Newport Boulevard /Hospital Road, will be less than significant. Response to Comment No. 3 As noted in Section 9 of the traffic study (Appendix C of the DEIR), a traffic signal is projected to be warranted at the following study area intersection for existing (Year 2009) + approved projects + project traffic conditions: Superior Avenue (NS) at: Project Central Driveway (EW) This traffic signal is a project design feature A Synchro operational analysis has been conducted on the study area intersections along Superior Avenue to address operation of the new traffic signal at the project central driveway (see Appendix I of the traffic study). Based upon the Synchro operational analysis, the study area intersections along Superior Avenue are projected to operate within acceptable Levels of Service during the peak hours for existing (Year 2009) + approved projects + cumulative projects + project traffic conditions. As shown in Table 9 of the traffic study, the project - generated traffic resulted in a significant impact at the intersection of Newport Boulevard at 18th Street/Rochester Street (increase of one - percent or more at a study area intersection operating at worse than Level of Service D during the morning /evening peak hours). As mitigation for the significant cumulative impacts, mitigation measure 4.2 -2 (refer to page 4.2 -23 of the DEIR) states that the project would contribute its fair share toward the following improvements at the Newport Boulevard (NS) /181h Street - Rochester Street (EW) intersection: provide a southbound through /right turn lane. The southbound improvement would require street widening. With the improvements discussed in MM 4.2 -2, the project is projected to not have a significant impact at the study area intersections along Newport Boulevard. It should be noted that with the mitigation measure above, the intersection of Newport Boulevard at 18th Street/Rochester Street is projected to operate within acceptable Level of Service during the peak hours and the Newport Boulevard intersections will not be impacted by the project. Therefore, a Synchro analysis along Newport Boulevard is not required. Hoag Health Center Responses to Pu&ic Comments November 2007 Page 17 0\ October 25, 2007 CITY OF COSTA MESA P.O, SOX 1900 • 71 FAIR DRIVE • CALIFORNIA 0202E -1200 DEVELOPMENT SERVICES DEPARTMENT Letter No. 8 Mr. Jaime Mudllo, Associate Planner City of Newport Beach Planning Department 3300 Newport Boulevard Newport Beach, CA 92658 -8915 Dear Mr. Murillo: The City of Costa Mesa appreciates the positive working relationship with the City of Newport Beach in collectively analyzing development projects that may have intelurisdlcdonal land use impacts. The City is submitting our comments on the Draft Environmental Impact report (EIR) for the Hoag Health Center. The proposed project involves the development of medical offices in the Newport Technology Canter site located at 500 -540 Superior Avenue. Please address the following comments in the Final EIR. 1) Existing Traffic V044mes. The analysis of Newport Boulevard Intersections in the City of Costa Mesa were conducted using 2004 traffic counts. A growth factor of 1 percent per year was applied to develop 2007 traffic volumes. Recently, the City conduced traffic volume counts at several study intersections along Newport Boulevard. The recent volumes on Newport Boulevard, especially during evening peak period, are higher by 10 to 15 percent compared to 2004 volumes. The new volumes are attached and should be incorporated in the study. It is likely that with the new volumes, the intersection of Newport Boulevard— Harbor Boulevard as well as other intersections may also be impacted due to the Project, resulting In the need for identification of further mitigations. 2) Protect Traffic. While the traffic analysis does not Identify any mitigation measures at Newport Bouevard -17th Street Intersection. the City is concerned with the number of 2 vehicles added to this intersection due to the Project, A total of 333 vehicles are added to the eastbound movements in the evening peak period per Figure 11 of the traffic study. The left -turn storage is limited and is already being exceeded, Other measures to divert this traffic to other parallel streets should be considered. 3) Prolect Traffic Impacts, Per Table 9, even with the proposed mitigation, the intersection 3 of Superior Avenue /17th Street is projected to operate at Level of Service E during both peak periods. This is of significant concern as options for additional Improvements are limited due to right -of -way constraints. 14) Recommended Improvements The City is concerned about the recommendation for an 4 additional southbound through lane at the Newport Bouelvard -18th Street intersection. In addition, with the new traffic volumes, there may be a need for similar improvement at Building Dirvrelon (714) 7845270 - Code EMaroemenl (714) 7545020 • Planning OMSIM (714) 754.E2A0 FAX (7141164<52545 • TOO 914) 704.0244. »xw al.aa4g4�pae.ce.u6 Mr.Murillo October 26, 2007 Page 2 the Newport Boulevard- Harbor Boulevard Intersection. The City requires that the applicant Initiate the process for this Imprc"Ment with involved agencies (State of California Department of Transportation and Costa Mesa). 5) Improvements alono 17th Strew, The City Is also concerned about 17th Street between Superior Avenue and Newport Boulevard. The recommended Improvement does not address the lack of storage in the eastbound direction for the significant addition In trips due to the Project. In order to address this high demand for access to Newport 5 Boulevard from northbound Superior Avenue, the City requires that the applicant consider Improvements to Industrial Way to the north of the site. These include full Improvements to the street between Superior Avenue and Newport Boulevard, and addition of signage along Superior Avenue directing traffic to use industrial Way to reach Newport Boulevard. B) Feasib1RY of NewD i th % I►gffioado� n Measure, The EIR indicates that suggested mitigation at Newport Blvd. and 18 Street is not feasible because the City "does not have a mechanism for accepting the fair share fee program" (page 4.2 -24 of EIR]. The City believes that this not adequate justification to render a mitigation measure Infeasible. In fact, if the applicant provides for 100% the cost of the improvement and adequate right -of -way is acquired, the NewporVIS' Street mitigation measure could be implemented. The EIR would need to evaluate the following: • Identification of the project's share toward the circulation improvement; o Assessment of the required right- of-way to Implement the improvement; • Discussion of any necessary coordination with the City and Coltrane regarding Implementation of the improvement; • Imposition of a conditon of approval requiring the developer to provide for 100% of the cast of the improvement. The proposed expansion of the Hoag Health Center needs to include traffic mitigation measures which are correctly identified and implemented. Consideration of these comments would help minimize the project's traffic impacts in both the Cities of Costa Mesa and Newport Beach. Thank you for addressing these comments. If you have any questions /comments regarding this letter, please contact Claire Flynn, Principal Planner, at (714) 754 -5278, rice "'JJV'�4� DON 4. Deputy City Mgr., Development Svs. Director cc: Peter Naghavi, Transportation Manager Raja Sothuraman, Associate Engineer Claire Flynn, Principal Planner 2007 TMC VOLUMES SBL SST SBR WBL WBT WBR NBL NBi i h & 19th NBR BBL On WAK 1 1 2.5 1.6 1 5 1,6 1 1 24 1.5 1 MS 21 16 68 9 179 14 ' 1 42 316 149 54 2687 7 803 32 24 Na on a 17th 2 1 3 0 2 1 1 1 3 2 US 1 1772 39 392 49 1754 44 339 3 700 1 2288 340 271 475 7 62 IT04 186 093 365 22 26 New lRoIader 3 1 1 1 1 3 2 7 1 83 1 2989 162 1 7 67 29 1 63 2796 7 B 7 2 129 a 141 78 22 108 15 248 4 47 26 ort Braa 9 3 7 1 1 0 0 1 1 9 2349 46 7 37 U---70T— 4 2 8 3 1 - 1 81 15 T 2492 18 23 27 New ort B Harbor 3 1 0 0 2 a 0 t 0 0 2 9 48 0 0 0 311 2601 0 25 0 476 3098 48 p 0 0 712 2435 121 p 8. City of Costa Mesa (October 25, 2007) Response to Comment No. 1 Appendix B of the traffic study (Appendix C of the DEIR) includes the traffic count worksheets of Newport Boulevard intersections in the City of Costa Mesa. Traffic counts for the Newport Boulevard intersections were not taken from 2004, as stated by the commenter; rather, Newport Boulevard intersection traffic counts in the City of Costa Mesa were conducted in March 2007: Newport Boulevard (NS) at: 19th Street (EW) — 3/14/2007 Broadway (EW) — 3/14/2007 Harbor Boulevard (EW)- 3/14/2007 18th Street/Rochester Street (EW) — 3/14/2007 17th Street (EW) — 3114/2007 16th Street (EW) — 3/14/2007 Industrial Way (EW) — 3/14/2007 Traffic counts suggested for use by the commenter appear on an undated table without attribution or other information regarding the authenticity of the figures. Traffic counts utilized as a basis for analysis in the DEIR were taken from the most recent available data (March 14, 2007) at the time of the Notice of Preparation (March 26, 2007). Use of the March 2007 data is consistent with CEQA Guidelines section 15125(a) which discusses establishing the existing conditions for use in the EIR as of the date of the Notice of Preparation. Given the consistency of the traffic analysis with CEQA regulations and the lack of detailed information regarding the figures discussed by the commenter, use of the March 2007 traffic counts was justified in the DEIR traffic analysis and no additional analysis is required. Response to Comment No. 2 As shown on Exhibit 4.2 -5 of the DEIR, the traffic analysis assigned 35% of the project traffic on Superior Avenue to 17th Street based upon a City of Costa Mesa comment on an earlier draft of the traffic study. (A prior draft (dated July 31, 2007) of the traffic study had assigned 15 % of the project traffic on Superior Avenue to 17th Street.) Assignment of 350% of project traffic to 17th Street resulted in a total of 333 vehicles added to the eastbound movements in the evening peak hour. Considering all traffic at the Newport Boulevard/17th Street intersection (project- related and non - project related traffic), and considering the assignment of 35% of project traffic to 17th Street, the Levels of Service during the peak hours at the Newport Boulevard/17th Street intersection was projected to be acceptable and the traffic impacts at the Newport Boulevard/17th Street intersection were concluded to be less than significant with implementation of the proposed project (inclusive of mitigation). (DEIR pages 4.2- 16 -17.) Although the traffic analysis in the DEIR has concluded that there would be no significant impacts at the Newport Boulevard /17th Street intersection, and thus no mitigation for that intersection is required, there is an opportunity to encourage traffic away from the Newport Boulevard/17th Street intersection and onto Industrial Way, where traffic volumes are much lower than at the Newport Boulevard /17th Street intersection. The following project design feature is to be made part of the proposed project, with the consent of the City of Costa Mesa: An existing sign on northbound Superior Avenue (south of Industrial Way) currently routes traffic to the 1- 405/SR -55 Freeways via northbound Superior Avenue to 17th Street. This sign will be replaced with a sign that routes traffic to the 1- 405/SR -55 Freeways via either northbound Superior Avenue to 17th Street or eastbound Industrial Way to Newport Boulevard. Hoag Health Center Responses to Pubfic Comments Novernber2007 Page 18 1A5 Implementation of the signage alerting drivers to the Industrial Way alternative of reaching the 1- 405 /SR- 55 Freeways will not create any significant impacts. An earlier version of the traffic study (July 31, 2007) assigned 15% of the project traffic on Superior Avenue to 17th Street. This resulted in a total of only 143 vehicles added to the eastbound movements in the evening peak hour (reduction of 190 vehicles). The remaining 20% was assigned to Industrial Way between Superior Avenue and Newport Boulevard. Assuming the traffic reductions along 17th Street and commensurate increases in traffic on other parallel streets (in comparison to the final traffic study analysis included with the DEIR), additional traffic from the proposed project as well as other approved projects and cumulative projects (and considering existing conditions on other streets), would have a less than significant impact as other intersections were predicted to operate within acceptable levels of service during the peak hours. These other intersections would include Superior Avenue (NS) at 16th Street/industrial Way (EW) and Newport Boulevard (NS) at Industrial Way (EW). Thus, including the additional signage encouraging traffic to utilize Industrial Way would not have any significant adverse impacts. Response to Comment No. 3 As shown in Table 9 of the traffic study (see also page 4.2 -19 of the DEIR, the intersection of Superior Avenue /17th Street is projected to operate at the following Levels of Service during the peak hours without and with the project: As shown in Section 6 of the traffic study and on pages 4.2 -15 -19 of the DEIR, the project - generated traffic resulted in a significant impact at the intersection of Superior Avenue /17th Street (increase of one - percent or more at a study area intersection operating at worse than Level of Service D during the morning /evening peak hours); therefore, the mitigation for project impacts at Superior Avenue /17th Street was included In the DEIR. Mitigation measure 4.2 -1 (on page 4.2 -23 of the DEIR) states: Prior to issuance of the certificate of occupancy, the project applicant shall be required to restripe to provide a westbound left turn lane, shared left/through lane, through lane, and right turn lane. This improvement would require modification to the traffic signal phasing and interconnect with the Newport Boulevard /17th Street intersection. As stated on page 4.2 -19, with the proposed mitigation, the LOS at the Superior Avenue /17th Street intersection would be less with the proposed project (with mitigation) than without the proposed project, and project impacts with mitigation are considered less than significant. By improving the LOS at the Superior Avenue /17th Street intersection, the proposed project is providing a benefit to the City of Costa Mesa, although the proposed project's mitigation will not alleviate all of the congestion at this intersection. Response to Comment No. 4 As concluded in the DEIR, proposed project traffic impacts at Newport Boulevard/Harbor Boulevard are less than significant and levels of service will remain at acceptable levels (see DEIR pages 4.2 -15 and 4.2 -16). The mitigation proposed (MM 4.2 -2) for Newport Boulevard/18t' Street - Rochester Street was deemed legally Infeasible due to the lack of an established program to accept fair share fees for the proposed improvements at that intersection (refer to page 4.2 -24 of the DEIR). Thus, there is no assumption in the DEIR that MM 4.2 -2 would be implemented. Therefore, there was no need to assess in Hoag Health Center Responses to Public Comments November 2007 Page 19 ti` 4 Morning Evening Peak Peak Descri for Hour Hour Existing + Approved Projects + Cumulative Pro ects F E Existing + Approved Projects + Cumulative Projects + Pro'ect F E As shown in Section 6 of the traffic study and on pages 4.2 -15 -19 of the DEIR, the project - generated traffic resulted in a significant impact at the intersection of Superior Avenue /17th Street (increase of one - percent or more at a study area intersection operating at worse than Level of Service D during the morning /evening peak hours); therefore, the mitigation for project impacts at Superior Avenue /17th Street was included In the DEIR. Mitigation measure 4.2 -1 (on page 4.2 -23 of the DEIR) states: Prior to issuance of the certificate of occupancy, the project applicant shall be required to restripe to provide a westbound left turn lane, shared left/through lane, through lane, and right turn lane. This improvement would require modification to the traffic signal phasing and interconnect with the Newport Boulevard /17th Street intersection. As stated on page 4.2 -19, with the proposed mitigation, the LOS at the Superior Avenue /17th Street intersection would be less with the proposed project (with mitigation) than without the proposed project, and project impacts with mitigation are considered less than significant. By improving the LOS at the Superior Avenue /17th Street intersection, the proposed project is providing a benefit to the City of Costa Mesa, although the proposed project's mitigation will not alleviate all of the congestion at this intersection. Response to Comment No. 4 As concluded in the DEIR, proposed project traffic impacts at Newport Boulevard/Harbor Boulevard are less than significant and levels of service will remain at acceptable levels (see DEIR pages 4.2 -15 and 4.2 -16). The mitigation proposed (MM 4.2 -2) for Newport Boulevard/18t' Street - Rochester Street was deemed legally Infeasible due to the lack of an established program to accept fair share fees for the proposed improvements at that intersection (refer to page 4.2 -24 of the DEIR). Thus, there is no assumption in the DEIR that MM 4.2 -2 would be implemented. Therefore, there was no need to assess in Hoag Health Center Responses to Public Comments November 2007 Page 19 ti` 4 the DEIR any impacts of implementation of MM 4.2 -2 on the Newport Boulevard /Harbor Boulevard intersection as suggested by the commenter. Response to Comment No. 5 This comment is acknowledged. Please refer to City of Costa Mesa Response to Comment 2. Response to Comment No. 6 The City of Costa Mesa has requested that the City of Newport Beach include a mitigation measure requiring the project applicant to pay 100% of the cost the impro;remerts and right -of -way acquisition to implement mitigation at Newport Blvd. and 181h Street - Rochester Street (i.e. adding a southbound through/right turn lane) rather than the proposed mitigation (MM 4.2 -2 on DEIR page 4.2 -23). Because the project has a cumulative impact on the intersection, the City of Newport Beach could require the project applicant to pay a proportionate share of the improvement costs tied to the mitigation of the identified impact. However, a mitigation measure that would require the project applicant to construct the improvement or pay 100% of the cost to construct the improvement and acquire the right -of -way is not supported by applicable regulation, case law or Costa Mesa's own establish fair share traffic fee mitigation program. (See, Costa Mesa Municipal Code §13 -275; and Napa Citizens for Honest GovY v. Napa County Bd. of Supervisors 91 Cal. App. 4"' 342, 364 (2001).) Here, the City of Costa Mesa's fair share fee program only allows for the collection of fair share fees if a project has been identified as being part of its fair share fee program. The improvements and right -of -way acquisition proposed as a mitigation measure for this project have not been identified as part of the City of Costa Mesa's fair share fee program. Therefore, it Is infeasible to require the payment of the proportionate share of mitigation fees to the City of Costa Mesa because Costa Mesa does not have an enforceable mitigation program that is tied to mitigation of the identified impact. Given that the only appropriate mitigation for the subject intersection is payment of a fair share fee —not the construction or financing of the entire improvement —the acquisition of right of way for the suggested intersection improvement would be accomplished by the City of Costa Mesa or other government agency (e.g., Caltrans) constructing the improvement —not by the project applicant. Furthermore, any coordination between government agencies related to the suggested intersection improvement is outside the purview of private entities such as the project applicant. Additionally, the determination of the amount of proposed project's fair share obligation toward the circulation improvement can only be accomplished by the City of Costa Mesa, pursuant to the program it has established for determining fair share fees. In light of the above discussions, the justification provided on page 4.2 -24 of the DEIR as to why the proposed fair share fee mitigation proposed for the Newport Boulevard /18�h Street - Rochester Street intersection is not legally feasible, is adequate. The additional analyses requested by the commenter are not warranted and would not yield legally defensible mitigation for the proposed project's cumulative impacts at the subject intersection. Hoag Health Center Responses to Public Comments November2007 Page 20 ya1 Letter No. 9 ',. South Coast Air Quality Management District 21865 Copley Drive, Diamond Bar, CA 91765-4178 s is 19091 396 -2000 • www.agmd.gov LAM: OCTOBER 26, 2007 October 26, 2007 Mr. Jaime Murillo City of Newport Beach Planning Department 3300 Newport Boulevard Newport Beach, CA 92658 -8915 Dear Mr. Murillo: Draft Environmental Impact Report (DEIR) for the Hoag Health Center Use Permit Amendment (September 2007) The South Coast Air Quality Management District ( SCAQMD) appreciates the opportunity to comment on the above - mentioned document, and thanks the lead agency for allowing additional time for submitting comments. The following comments are meant as guidance for the lead agency and should be incorporated in the Final Environmental Impact Report. Pursuant to Public Resources Code Section 21092.5, please provide the SCAQMD with written responses to all comments contained herein prior to the certification of the. Final Environmental Impact Report. The SCAQMD would be available to work with the Lead Agency to address these issues and any other questions that may arise. Please contact Charles Blankson, Ph.D., Air Quality Specialist — CEQA Section, at (909) 396 -3304 if you have any questions regarding these comments. Sincerely Steve Smith, Ph.D. Program Supervisor, CEQA Section Planning, Rule Development & Area Sources Attachment SS: CB ORC070911 -01 Control Number 1�� 1! 2 Mr. Jaime Murillo 4- October 26, 2007 Draft Environmental Impact Report (DEIR) for the Hoag health Center Use Permit Amendment 1, O erational Emissions: The lead agency states on pages 4.3 -15 and 4.3 -16 of the DPM that although operational emissions would be significant for carbon monoxide (CO), volatile organic compounds (VOC), nitrogen oxides (NOx) and particulate matter (PIA10), the proposed project is not expected or likely to "significantly deteriorate regional air quality or contribute to significant health risk, ... or lead to a violation or to contribute substantially to a violation of federal or state air quality standards to result in a cumulatively considerable net increase..." Not only does the SCAQMD disagree with this type of post hoc rationalization, it is internally inconsistent with the discussion of cumulative air quality impacts in Section 9.3.5 of the Draft EIR. In Section 9.3.5 the lead agency states that because the incremental operational emissions exceed the significance thresholds they will be significant on a cumulative basis. The SCAQMD, therefore, recommends that the inconsistent statement on page 4.3 -16 be deleted. 2. Mitigating Operational Emissions: The lead agency states on page 4.3-23 of the DEIR that there are no feasible measures that would reduce the significant operational emissions impacts to a less than significant level. Because of the magnitude of the significant adverse emissions from the proposed project's operations, the lead agency should consider the following measures, in addition to those listed on page 34 of Appendix D: • The health center should iddate a program to convert its fleet of vehicles, either for patient delivery or deliveries of supplies and materials, to alternative- fueled vehicles or lowest emitting vehicles in that vehicle class. • Install light - colored roofing materials to deflect heat and conserve energy. • Install solar panels on roofs to supply electricity for air- conditioning. Install high energy - efficient appliances such as refrigerators, furnaces and boiler units. a Install automatic lighting occupant sensors on/off controls. For additional mitigation measures for the lead agency's consideration, refer to the foUowingURL:http://www.agmd.&osLc,qga/h—mdbookiiiii.-Ofio-WMM intro html. 3 Mr. Jaime Murillo -2- October 26, 2007 3. Health Risk Assessment The HRA for the diesel emergency backup generator is based on Rule 1470 requirements, using an emission factor of 0.01 gm/hp -hr and 12 hours of testing per year. These parameters are applicable if there is a school within 500 feet of the engine. If there are no schools within 500 feet, Rule 1470 allows the use of emergency backup generators with an emission rate of 0 -15 gm/hp -hr and allows 50 hours of testing per year. If there are no schools within 500 feet of the engine, use of the more stringent parameters, i-6 health protective and should be required by the lead agency when submitting permit applications for the emergency backup engines to the SCAQMD, since these parameters are included as part of the project description. The engine parameters presented in the Air Quality Analysis include a stack diameter of 0.82 meter and a stack exit velocity of 45.4 meters per second. These stack parameters are not typical for the size of engine analyzed (800 bhp). For an 800 bhp engine the stack diameter is expected to be about 03 meter and the stack velocity is expected to be eight meters per second. The stack parameters used by the lead agency result in an overly optimistic health risk result. The SCAQMD requests that the I4RA be revised to include the more typical stack width and exhaust velocity parameters or provide the manufactures engine specification sheet verifying the engine parameters used in the HRA in the Draft EIR. A site map identifying the sensitive receptor was not included in the Draft EIR. Please include a site map identifying sensitive receptors in the Final EIR. 9. South Coast Air Quality Management District (October 26, 2007) Response to Comment No. f The statements made on pages 4.3 -15 and 4.3 -16 are intended to describe, in a qualitative manner, the 'fact that even though emissions from a project may exceed the air district thresholds for the entire region, the effect of those emissions on the health of individuals living near the project is likely to be less than significant, due to the dispersed nature of the emission sources and other factors that affect the distribution of pollutants in air. However, because the statements of concern to the commenter do not affect the overall air quality conclusions reached in the DES, the statement of concern to the commenter has been deleted, to wit, the paragraph below Table 4:3 -6 on page 4.3 -16 will be deleted in its entirety. Response to Comment No. 2 The operational emissions are more than 98% mobile source emissions, which are principally privately owned motor vehicles. The project is expected to generate 17,500 daily vehicle trips. Implementation of the additional measures suggested by the commenter would not reduce the proposed project's air quality impacts to below a level of significance. Thus, proposed project impacts would remain significant and unavoidable as concluded on page 4.3 -23 of the DEIR. Only one of the measures suggested by the commenter relates to mobile sources —the recommendation for the project applicant to convert its fleet vehicles to alternative -fuels or low emission vehicles. The project applicant does not own or operate a fleet of vehicles servicing the proposed project and thus has no fleet to which the commenter's suggestion would apply. The shuttle vehicles to be used at the proposed project are not controlled by the project applicant. and thus, the project applicant has no ability to mandate the fuel type or emissions efficiency of those vehicles. With.regard to the commenters other suggested measures related to non - mobile sources and site design /energy efficiency: • The buildings at the project site are already constructed and have light colored roofing. These existing buildings are not proposed to be modified on the exterior as part of the proposed project. The additional building to be constructed as part of the proposed project would have roofing similar to the existing buildings in keeping with the common design elements of the site. • Because the buildings at the project site are already built with electrical infrastructure already in place, removal of the existing electrical systems and replacement with alternative solar systems suggested by the commenter are not feasible economically or reasonable technically. • The automatic lighting suggested by the commenter is already incorporated into the existing buildings and would be included in the interior remodeling and new construction involved in implementation of the proposed project. • Energy efficient appliances are already incorporated Into the existing buildings and would continue to be utilized as the remodeling and new construction of the proposed project takes place. Response to Comment No. 3 There are no schools located within 500 feet of the proposed project. The nearest sensitive receptors are located across Dana Road no closer than 100 feet from the nearest possible location of the generator on site. Consistent with the recommendations of the commenter, the Health Risk Assessment (HRA) has been revised to use the 0.15 gm /hp -hr emission factor and 50 hours per year for testing. Additionally, the engine parameters requested by SCAQMD have also been implemented. The resulting values are a Hoag Health Center Responses to Public Comments November2007 Page 21 1I)k carcinogenic risk of 2.3 in 1 million and a chronic hazard index of 0.0015, both less than their respective thresholds of 10 in 1 million and 1.0. Therefore, the impact would remain less than significant. The Revised Screening Level Health Risk Assessment has been attached with these responses. To reflect the new health risk analysis included as part of this response, Table 4.3 -8 on page 4.3 -19 of the DEIR is revised as reflected below. Table 4.3 -8 Screening Level Health Risk Assessment for Generator Exhaust Hoag Health Center Use Permit Amendment Additionally, a map showing the sensitive receptors near the project site (as requested by the commenter) will be included in the DEIR Errata. Hoeg Health Center Responses to Public Comments November2007 Page 22 15� Cancer Risk No. In 1,000,000 Chronic Risk HI Nearest Residence 2.3 0.0015 Threshold 10 _ 1 Significant Impact? No No SOURCE: LSA Associates, Inc. November 2007 Additionally, a map showing the sensitive receptors near the project site (as requested by the commenter) will be included in the DEIR Errata. Hoeg Health Center Responses to Public Comments November2007 Page 22 15� Letter No. 10 Murillo, Jaime From: Don Krotee [dkrotee @krotee.com] Sent: Thursday, September 20, 2007 10:58 AM To: Wood, Sharon; Murillo, Jaime Subject: Hoag in Tech Center- CEQA comment Jaime: Our HOA has some questions and concerns about the traffic produced by an R & D property being purchased and used by a considerably more intense use, Med Office. We know that Hoag has put efforts into the delicate balance of the old R &D parking (and assuredly the increased ADT for the R &D vs. the new and more intense Med. Center) but, we would like to agree that it's enough. To do this we understand that the user struck at least a portion of this balance by the tearing down of a building as I recall. I'd like to see a PDF of the latest site plan, the most recent parking tabulation and the traffic report(s) manifesting this balance. If they are inseparable from the Environmental document please direct me to where they are available on line. I am very appreciative. In this same regard, if I have addressed this to the wrong staff planner, please forward. The City should accept this as both a general and specific comment in regard the the traffic, noise and air quality mitigations associated with the CEQA document and include this with other such comments. Further, where there is noticed public hearings, please contact our organization as a concerned and affected community. Don Krotee Newport Heights Improvement Association www.newportheicihts.org don newportheights.org 153 1 1/09/2007 10. Don Krotee /Newport Heights Improvement Association (September 20, 2007) Response to Comment No. 1 Although this comment makes reference to "... the traffic, noise, and air quality mitigations associated with the CEQA document ... ", no specific comments are provided. City staff responded to the commenter on September 20, 2007. That response provided information on the project requested by the commenter and advised the commenter that the Draft EIR was available for public review at the City's libraries and in the Planning Department. The City's response to Mr. Krotee's inquiry is attached. No further response is necessary. Hoag Health Center Responses to Public Comments November 2007 Page 23 l5� Page 1 of 2 Murillo, Jaime From: Murillo, Jaime Sent: Thursday, September 20, 2007 12:02 PM To: 'Don Krotee' Cc: Wood, Sharon; 'Keeton Kreitzer' Subject: RE: Hoag in Tech Center- CEQA comment Don, Thank you for your comments in regards to the Hoag Health Center project and Draft EIR. Your community association will be added to the public hearing mailing list for the project. You are correct, Use Permit No. 2006 -010 approved in Dec. 06 authorized the demolition of an 86,079 square - foot office /R &D building on the northeasterly portion of the site and construction of a new parking structure in its place. Additionally, that Use Permit authorized 97,000 square feet of medical office use on -site. Staff is currently processing Hoag's request to amend Use Permit No. 2006 -010 authorizing the conversion of the remaining 232,414 sq. ft. of general office and R& D floor area, of the existing 329,414 sq. ft. of existing floor area (after demolition), to medical office use. Additionally, construction of an additional 20,586 sq. ft. of medical office space on -site is proposed, for a total of 350,000 sq. ft. of medical gross floor area on -site, consistent with the General Plan precise development limitation for the site. The Draft EIR has been prepared for the project and is available for public review at the City's libraries or here at City Hall within the Planning Department. Additionally, a copy of the document has been posted on the City's website at the following link: hftp: / /www6 city newport-beach.ca us/GISDownloads- 1100104/Downloads/Planning/Hoag Please refer to page 3 -14 of the document for the latest site plan for the project. Please refer to page 42 -1 of the document for a detailed analysis of Traffic and Circulation, and Appendix C of the document to review the Traffic Impact Analysis prepared for the project. Please refer to page 4.2 -22 of the document for a discussion on parking. A total of 1,985 parking spaces are proposed as follows: Surface Spaces 427 Existing Structure Spaces 861 Proposed Structure Spaces 697 Total 1,985 parking spaces Please send any further comments on the Draft EIR to my attention at: Planning Department, 3300 Newport Blvd.,Newport Beach, CA 92658. Comments will be accepted until October 25, 2007. A Planning Commission hearing is anticipated on Nov. 8, 2007. Thanks, Jaime Jaime Murillo Associate Planner City of Newport Beach (949) 644 -3209 (949) 644 -3229 Fax jmurilla ®city.newport- beach.ca.us 05 11/09/2007 E