HomeMy WebLinkAbout0.0d_Public CommentsCorrespondence
Item No. Oa
Public Comments
Brenda Wisneski, Zoning Administrator 04/04/12
City of Newport Beach
3300 Newport Blvd
Newport Beach CA 92663
RE: Coast Business Center Sign Program 2121 E Coast Hwy (PA2012 -010)
Dear Ms. Wisneski,
Thank you for the opportunity to comment on the application for Modification Permit No. MD2012 -004
and Comprehensive Sign Program No. CS2007 -002 (PA2012 -010). I am opposed to approval for the
following reasons:
1. According to code, the applicant is allowed one sign on E Coast Hwy and one sign on Avocado
Ave. The applicant has substantially exceeded limits already.
2. According to code, the applicant is allowed a 75 sq ft sign on the primary frontage and a 37.5 sq
ft sign on the secondary frontage. I have been told the applicant has, or will have, 320 sq ft of
signage on E Coast Hwy and 120 sq ft of signage on Avocado Ave. This is four times the
allowable signage specified by code.
3. Additional approvals would amount to an excessive oroliferation of signage and would devalue
the current tenant signs by adding clutter. Additional signs would devalue neighboring
commercial property owner signs by adding clutter.
4. Adding signs does not assist in way finding. There is only one large white office building at the
corner of E Coast Hwy and Avocado Ave. Visitors do not enter suites at the sign locations.
Visitors enter through common lobbies.
5. Adding signs does not preserve community appearance. The property is adjacent to residential
properties and any increase in intensity of advertising, especially lighted signs, may negatively
affect the wellbeing of residential neighbors and decrease their property values. The same is
true for nearby commercial properties where signage is kept under control, such as Corona del
Mar Plaza and Newport Center.
6. The property is located across the highway from some of the premier commercial properties in
Newport Beach, Orange County and the nation. There is no need to revitalize the area with
signage.
These are some of my initial concerns. I am looking forward to providing you with additional and more
specific comments at the hearing on Wednesday.
Sincerely,
Dan Purcell
Ocean Blvd
Corona del Mar
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Correspondence
Item No. Oc
Public Comments
0E1VED BY
COMMUNITY
April 5. 2012
APR 0 5 2012
Newport Beach Planning Commission
3300 Newport Boulevard n DEVELOPMENT �.'
Newport Beach, CA 92663 �P
(via e-mail) OF NEWPOV� 0
Re: March 22, 2012 Hearing Item 4 - Newport Banning Ranch - (PA2008 -114)
Honorable Commissioners,
I would like to add my voice to that of Suzanne Forster in her April 4, 2012 letter to the editor of
the Daily Pilot requesting the Planning Commission rescind its two late night decisions of March
22, 2012 regarding the Newport Banning Ranch (NBR) application (recommendations to
Council regarding re- circulation and certification of the Environmental Impact Report (EIR)) and
reschedule a properly noticed and conducted hearing on the NBR EIR. This seems particularly
important to me for a project of wide public interest in multiple communities and I request that
this letter be made part of the administrative record for EIR SCH No. 2009031061.
I agree with Ms. Forster that the Chair's instructions to the public, however well intentioned,
were extremely intimidating, both in substance and tone, and at least in my view improperly
discouraged from speaking those members of the public who did not feel they were qualified
environmental experts with significant new factual information to add to the record. I also agree
with Ms. Forster that the traffic section of the EIR most likely requires significant revision in view
of the Orange County Transit Authority (OCTA)'s recent decision to permanently remove the
19th Street bridge from the County's Master Plan of Arterial Highways without providing any
agreed to mitigation measures — a fact which staff declined to acknowledge even though the
City of Newport Beach (CNB) is either initiating or in the process of considering litigation to
modify the OCTA action.
In addition I feel compelled to raise the following procedural and substantive issues which in my
view improperly limited public participation and which I feel will permanently cloud the
Commission's recommendations:
1. Inadequate hearing notice
2. Inadequate time to evaluate Response to Comments
3. Inadequate /misleading agenda listing
4. Improper handling of overflow crowd
5. Misleading and incomplete staff report
6. Failure to provide context for hearing
7. Lack of credible basis for actions
8. Adoption of defective resolution
1. Inadequate hearing notice
Please see Attachments 1 and 2 to this letter for a transcription of the notice of the March 22,
2012 CNB Planning Commission hearing published in the Daily Pilot on March 10, 2012. The
NBR portion of the notice (Attachment 1) describes the project, identifies the components of the
project application and informs the public than environmental concerns have been dealt with by
means of an EIR prepared in compliance with California Environmental Quality Act (CEQA)
Jim Mosher to Planning Commission, April 5, 2012 — page 2 of 9
guidelines. The notice gives no hint regarding the purpose of the March 22 hearing, and could
be read to imply the EIR has been completed and certified.
Compare this to the notice of the subsequent item (Attachment 2) which clearly notifies the
public of the purpose of the hearing and the contemplated actions.
The similar but somewhat more extensive notice mailed to neighboring property owners (not
attached) does include a line before the CEQA notice saying "The Planning Commission will
provide recommendations to the City Council for final decisions on these applications.
Additional public notice will be provided as to the date, time, and place of City Council hearings."
But again, no hint is given that the NBR DEIR will be the subject of the March 22 hearing, or that
recommendations regarding it would be made at that time.
2. Inadequate time to evaluate Response to Comments
On March 16, 2012 just six days before the hearing scheduled for an unstated purpose, CNB
released 1030 pages of Responses to Comments, 1200 pages of appendices related to those
comments, and a 96 page Mitigation, Monitoring and Reporting Program related to the NBR
DEIR. Even for those who knew the March 22 meeting would focus on the DEIR this was a very
large volume of closely worded material to digest in a very short time, especially for those,
including the Commission, who are not environmental professionals with 40 hours a week (or
more) to devote to the matter.
Several members of the public testifying on March 22 said they found the responses to their
own comments non - responsive. Aside from a few perfunctory questions from Commission to
staff at the March 22 hearing it is unclear if anyone, including staff or consultants, made any
effort to determine if the public agencies submitting comments found the responses adequate or
if they continued to have reservations about the NBR DEIR.
3. Inadequate /misleading agenda listing
The agenda listing for the NBR portion of the Planning Commission's March 22, 2012, on the
basis of which the public is supposed to be able to determine if they want or need to attend, is
transcribed in Attachment 3 to this letter.
The agenda listing for the previous item (the Ocean Boulevard lot merger) clearly states in the
Summary the purpose of the hearing and under Action mentions not only that the Commission
will be conducting a hearing, but that it will be recommending approval or denial by means of
adopting one of two alternative resolutions referenced in the associated staff report.
By contrast, the NBR agenda listing gives no hint under Summary of what the purpose of the
hearing, and there is nothing under CEQA Compliance suggesting the EIR is tentative or has
not already been approved. Under Action the public is told the Commission will "Receive staff
report focused in Environmental Impact Report," conduct a hearing and continue the hearing to
April 5, 2012.
Jim Mosher to Planning Commission, April 5, 2012 — page 3 of 9
This is defective in two ways. First, based only on this agenda the public might reasonably
assume the EIR had already been certified and a staff report on the EIR was to be presented
simply as a way to set the context for opening a hearing on the development application, which
was be continued to a future date. Second, for those more familiar with the culture of CNB
Planning Commission agendas, the absence of any mention that a resolution was going to be
considered for adoption definitely means that no action would be taken until a subsequent
meeting.
I have personally examined all the Planning Commission agendas back through 2009, and a
number from prior years, and although the Commission may suggested modifications to the
actions recommended by staff, prior to the March 22 NBR matter I have been unable to find any
prior instance in which the Commission took an action when no action was noticed in the
agenda. In a number of instances the agenda announced under Action, as for the NBR listing,
that the Commission would "(1) Conduct public hearing; (2) Continue public hearing to ..." On
rare occasions the Commission modified the recommended date for the continuation of the
hearing, but in every case the Commission continued the hearing as promised without taking
any action beyond ones clearly noticed in the agenda.
Although the Assistant City Attorney assured the Commission that the March 22 votes were
properly agendized in compliance with the Brown Act, the California Attorney General in their
handbook on the very similarly worded Bagley -Keene Act (governing state, as opposed to
county and local, agencies) notes that if a body voluntarily chooses to distinguish action from
discussion items in their agendas, they should feel compelled to fit their actions to their notices
In summary, no one seeing the March 22, 2012 agenda would have expected the Planning
Commission to do anything other than open a hearing on the NBR and continue it to April 5t".
While the Chair, in his opening remarks to the NBR matter, may have implied actions on the EIR
might be taken that night, that is insufficient. A reasonable person relying on the agenda would
have assumed that before any such actions were taken they would have an additional
opportunity to provide input on April 5, and perhaps beyond.
4. Improper handling of overflow crowd
As the Commission may be only dimly aware, a very large crowd assembled at the CNB Council
Chambers at 6:30 pm on March 22, the noticed time of the hearing. The crowd filled the lobby
and overflowed into the courtyard, a problem compounded by staff having scheduled the
contentious Ocean Boulevard item (which itself may have filled the Chamber) on the same
night. Staff did not have an adequate supply of agendas or staff reports, nor did they provide
any means for the overflow crowd to hear or participate in the proceedings. For example, at the
beginning of the meeting the Chair offered to allow some of the overflow public to sit at the staff
conference table at the front of the hall, but even inadequate as that was, those being invited
could not hear the invitation.
Since no indication was given as to when the NBR matter would be heard, or if the entire
overflow audience would have a chance to be seated for it, many left in frustration, and
assuming they had seen a copy of the agenda would have done so assuming they would have
an opportunity to speak and participate on April 5, before any action was taken. No
announcement, audible or otherwise, was made to the contrary prior to the commencement of
the NBR hearing at 9:00 pm. At a minimum, it would seem to me the overflow crowd should
have been given a reasonable time to express their views through written comments before the
Jim Mosher to Planning Commission, April 5, 2012 — page 4 of 9
Commission considered any action, or have been clearly notified as to whether the hearing was
going to be continued (as promised) or not.
5. Misleading and incomplete staff report
The staff report compounds the confusion regarding whether any action was contemplated on
Agenda Item 4 (the NBR application) at the March 22, 2012 meeting by copying on handwritten
page 1 the inadequate language from the agenda as "Project Summary' and
"Recommendation." Again there is no hint the EIR has not been already approved and that a
vote or votes or a resolution or resolutions is contemplated at the March 22 meeting.
On the contrary, those who leaf through to handwritten page 7 will see that the timeline for the
"EIR Review Process" includes not only the March 22 hearing before the Planning Commission,
but also a second one on April 5, and possibly more.
Those who notice a draft resolution recommending certification is included in the staff report as
Attachment No. PC 1 will have had this impression reinforced by the "Whereas" on handwritten
page 20 which says that "public hearings were held on March 22 and , 2012," where it
can only be assumed the dates of subsequent hearings on the EIR were intended to be added
to the blank space.
The only thing contradicting this interpretation is the statements made under "Discussion" on
handwritten page 8, suggesting the March 22 meeting will be devoted to the EIR and the April 5
meeting to the development application — but we now know the staff was not in fact prepared to
conduct a hearing on the application on April 5 and asked for the NBR matter to be continued to
April 19.
The staff report is also inadequate in providing no clear menu of actions required to complete
consideration of the EIR by the Planning Commission.
6. Failure to provide context for hearing
As indicated in the draft minutes of the March 22 meeting, Agenda Item 4 began with an
explanation by the Chair of the EIR process. For those who had not previously attended a
meeting regarding the NBR application, this was woefully inadequate, especially since, as noted
above, the vast bulk of the audience were provided with neither agendas or staff reports. To the
best of my recollection neither the project nor the contents of the EIR were described, and the
Commission launched into a short laundry list of questions, apparently assuming everyone in
the audience had attended all the Study Sessions and had time to understand the structure and
content of the EIR (described only as "oh the documentation is exhaustive — I think it's three feet
tall) on their own.
Considering this was the first public hearing, and especially in view of the absence of agendas
and staff reports, I feel the public deserved having the context laid a bit better before being
asked to comment on something they may or may not have seen.
Jim Mosher to Planning Commission, April 5, 2012 — page 5 of 9
7. Lack of credible basis for actions
In moving to reject re- circulation of the NBR DEIR and in adopting the resolution recommending
its certification, the Planning Commission is presumably telling the CNB Council that it has
thoroughly reviewed the EIR and, in its independent judgment, agrees with all its conclusions.
To put this in context, Attachment No. PC 3 to the March 22, 2012 Staff Report is a table giving
a "Summary of Significant Impacts and Mitigation Program." Although it seems to list
"insignificant" and "less than significant" impacts as well, the table includes something like 90
numbered questions (an exact total is difficult because, for example, question Threshold 4.6 -5
contains three separate questions that are not separately numbered) that have to be answered
as to whether they have an environmental impact or not. The consultant appears to have
concluded that something like 23 of these will have "no impact," 47 will have (after mitigation)
"less than significant impact" and 8 will have a "significant unavoidable impact."
It is absolutely incredible to me that after diligently reviewing the project application, 1432 pages
of the DEIR (plus another 5817 pages of appendices), the 1030 pages of comments (plus
another 1200 pages of appendices), and the 96 page Mitigation, Monitoring and Reporting
Program, and listening to the public testimony at its study sessions and public hearing, that the
Planning Commission failed, in its independent judgment, to find a single instance in which they
might reach a different conclusion from the applicant and consultant as to the significance of a
particular impact, or think a different mitigation measure might be more effective.
I am particularly curious if the Planning Commissioners agree with the applicant and consultant
that a massive pedestrian bridge over West Pacific Coast Highway has no visual impact, or that
an alternative of annexation without development (that is continuing under the current
ownership, but with the City Charter forcing consolidation of oil operations) should not have
been considered (Alternative A, as I understand it, assumes no annexation, and therefore a
continuation of oil operations as they now exist).
8. Adoption of defective resolution
In addition to thinking the NBR DEIR should be re- circulated (due primarily to defective noticing
for which the consultant could offer no adequate response), had I known the draft resolution in
the March 22, 2012 staff report was going to be considered at that meeting (and not on April 5
or at some subsequent meeting, as the agenda and staff report implied) I would have spoken
against it, for it is highly defective, both on its own merits and in comparison to other resolutions
adopted by the Planning Commission recommending certification of EIR for other projects.
As a Newport Beach taxpayer I think I am most concerned about the final boilerplate "Whereas'
on handwritten page 20 of the staff report (page 2 of 23 of the draft resolution), which seems to
state the Planning Commission is recommending certification on the assumption that the costs
of any legal challenges will be borne by the project applicant — but offers no suggestion as to
how that assumption will be implemented or could be enforced by the City Council. For an EIR
that is almost certain to provoke a legal challenge this seems to me to be an extremely serious
shortcoming. At the same time, I am also concerned that such a guarantee, if feasible, could
lead to a "we can approve anything because we won't have to pay to defend it" attitude, which,
at least to me, serves neither the public nor the applicant well.
Jim Mosher to Planning Commission, April 5, 2012 — page 6 of 9
Beyond that, the 19 page "Exhibit B — Findings of Fact" is, in my opinion, highly defective both in
substance and in comparison to the attachments to other resolutions recommending certification
of EIRs approved by the Planning Commission in the past, and I am again startled that the
Commission voted to adopt this without recommending a single change.
First, I am unable to find any guidance given as to the Council as to the CEQA required
definition of what constitutes the Final EIR and the administrative record related to it.
Second, I am able to detect relatively clear findings supporting the conclusions of the EIR only
with regard to the 5 to 7 "Effects with No Impact" listed on handwritten page 39 of the staff
report (page 21 of the 23 page draft resolution). With respect to the list of the 8 to 13 (it's hard
to count precisely) "Significant Unavoidable Impacts" listed on pages 22 and 23 of the draft
resolution, the findings supporting the conclusion that these are significant frequently lack clarity
and the findings supporting the notion these effects cannot be mitigated are generally non-
existent. Moreover, the list of "no impact" effects appears to be an arbitrary subset of the effects
concluded to have "no impact" as listed in the following Attachment No. PC 3 to the Staff
Report. I am unable to understand why one particular subset of "no impact" effects deserves
support by "Findings of Fact" and the others do not.
Third, the Commission appears to be offering the Council no guidance at all as to proposed
findings regarding the 47 or so other effects the EIR concludes will have a "less than significant
impact" after mitigation — either as to why they are significant to start with or as to why the
proposed mitigation measures would be effective.
On that final note, it is unclear if the Commission, after reviewing it, is making a
recommendation with regard to the Mitigation, Monitoring and Reporting Program since it is
unclear from the resolution what the Commission is recommending be regarded as the Final
EIR for the NBR project.
Again, attention to proper process, a thorough independent analysis of impacts and mitigation
measures and a sincere effort to engage public involvement seem particularly important for a
high profile project involving communities outside Newport Beach. For the above reasons and
others stated in public comment, I feel the City's handling to date of the NBR environmental
review has been inadequate and urge the Commission to reconsider its March 22nd decisions
regarding re- circulation and certification of the EIR.
Thank you in advance for your consideration of my comments
Yours sincerely,
James M. Mosher, Ph.D.
2210 Private Road
Newport Beach, CA. 92660
iimmosher(a)yahoo.com
(949) 548 -6229
Jim Mosher to Planning Commission, April 5, 2012 — page 7 of 9
Attachment 1 : Content of Notice Published in Daily Pilot - March 10, 2012
3300 Newport Boulevard,
Newport Beach
PLANNING COMMISSION AGENDA
Regular Meeting March 22, 2012 at 6:30 p.m.
1. SUBJECT: Newport Banning Ranch - PA2008 -114
North of West Coast Highway, south of 19th Street, and east of the Santa Ana River. The
Project Site is adjacent to the City of Costa Mesa on the east, unincorporated County on the
north and west, and the existing developed areas of the City of Newport Beach on the south
and southeast. The Santa Ana River and the City of Huntington Beach are located west of
the Project Site.
SUMMARY: A proposed planned community on a 401.1 acre project site for development of
1,375 residential dwelling units, a 75 room resort inn and ancillary resort uses, 75,000
square feet of commercial uses, and approximately 51.4 acres of parklands. The application
consists of the following components: a Pre- annexation and Development Agreement
between the applicant and the City of Newport Beach describing development rights and
public benefits; General Plan Amendment to the Circulation Element of the General Plan to
delete the planned segment of 15th Street west of Bluff Road; Code Amendment to rezone
the project site from. Planned Community (PC -25) to Planned .Community (PC -57) and a
pre- annexation zone change is proposed for those portions of the project site located within
the City's Sphere of Influence from County zoning to PC -57; Planned Community
Development Plan would establish the allowable land uses, general development
regulations and implementation and administrative procedures; Master Development Plan
to establish detailed design criteria for each .land use component to guide the review of
subsequent development approvals; Tentative Tract Map to establish lots for public
dedication or conveyance, lots for residential development and conveyance to homebuyers,
and lots for financing and conveyance; Affordable Housing Implementation Plan specifying
how the project would meet the City's affordable housing requirements; and Traffic Study
Approval pursuant to Chapter 15.40 (Traffic Phasing Ordinance).
APPLICATION:ER2009 -002, DA2008 -003, NT2008 -003, GP2008 -008, PC2008 -002, and
CA2008 -004
CEQA COMPLIANCE: NOTICE IS HEREBY FURTHER GIVEN that pursuant to the
California Environmental Quality Act (CEQA) the City of Newport Beach has prepared
Environmental Impact Report (EIR) -SCH No. 2009031061 to evaluate the environmental
impacts resulting from the proposed project. The DEIR has been prepared in accordance
with the California Environmental Quality Act of 1970 (CEQA), as amended (Public
Resources Code Section 21000 et seq.), and the State CEQA Guidelines for
Implementation" of CEQA, (California Code of Regulations, Title 14, Section 15000 et seq.).
Jim Mosher to Planning Commission, April 5, 2012 — page 8 of 9
Attachment 2: Remainder of Notice Published in Daily Pilot - March 10, 2012
2. SUBJECT: 2808 and 2812 Ocean Boulevard Lot Merger - PA2011 -141
2808 and 2812 Ocean Boulevard
SUMMARY: At the direction of the City Council, the Planning Commission will reconsider Lot
Merger Application No. LM2011 -002 requesting approval to combine 2808 and 2812 Ocean
Boulevard. The Commission will review alternative development standards proposed by the
applicant to be applied to the development of the property. The Planning Commission will
make a recommendation of approval or denial to the City Council, which will hear the
application at a future meeting.
APPLICATION: LM2011 -002
CEQA COMPLIANCE: The project is categorically exempt under Section 15305 of the
California Environmental Quality Act (CEQA) Guidelines - Class 5 (Minor Alterations in Land
Use Limitations).
Published Newport Beach /Costa Mesa Daily Pilot March 10, 2012
Attachment 3 : Content of March 22, 2012 Agenda Listing
ITEM NO. 4 Newport Banning Ranch - (PA2008 -114)
5200 West Coast Highway
SUMMARY: A proposed planned community on a 401.1 acre project site for development of
1,375 residential dwelling units, a 75 -room resort inn and ancillary resort uses, 75,000 square
feet of commercial uses, approximately 51.4 acres of parklands, and approximately 252.3 acres
of permanent open space.
CEQA COMPLIANCE: An Environmental Impact Report (EIR) SCH No. 2009031061 to
evaluate the environmental impacts resulting from the proposed project. The EIR has been
prepared in accordance with the California Environmental Quality Act of 1970 (CEQA), as
amended (Public Resources Code Section 21000 et seq.), and the State CEQA Guidelines for
Implementation of CEQA (California Code of Regulations, Title 14, Section 15000 et seq.).
1) ACTION:
1) Receive staff report focused in Environmental Impact Report;
2) Conduct a public hearing; and
3) Continue public hearing to April 5, 2012.
Jim Mosher to Planning Commission, April 5, 2012 — page 9 of 9
Attachment 4: California Attorney General's View of Agenda Requirements
From the AG's Bagely -Keene Open Meeting Handbook:
"The agenda items should be drafted to provide interested lay persons with enough
information to allow them to decide whether to attend the meeting or to participate in that
particular agenda item. Bodies should not label topics as "discussion" or "action" items
unless they intend to be bound by such descriptions. Bodies should not schedule items
for consideration at particular times, unless they assure that the items will not be
considered prior to the appointed time. "
Source: http: / /ag.ca.gov /publications /bagleykeene2004 ada.pdf (under "Notice and
Agenda Requirements" on page 8)
Note: I have not found time to locate a similar statement by the Attorney General with
regard to the Brown Act, but the statutory sections being interpreted are essentially
identical in the two acts.
Additional References/ Web Links
Suzanne Forster letter to Daily Pilot:
http: / /www. dailypi lot.com /news /opi n ion /tn -d pt- 0403 -mail bag- 20120403, 0, 2060329.story
March 22, 2012 Planning Commission agenda and staff report:
http://www.newportbeachca.gov/index.aspx?paqe=l 328
Specifically:
http : / /www.newportbeachca.gov /PLN /PLANNING COMMISSION.asp ?path= /03 -22 -2012