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HomeMy WebLinkAboutHoag Healthcare Center - 500-540 Superior Ave - PA2006-113CITY,OF NEWPORT BEACH PLANNING COMMISSION STAFF REPORT Agenda Item: 6 December 7, 2006 TO: Planning Commission FROM: Planning Department Jaime Murillo, Associate Planner, (949) 644 -3209 imurillo &- citv.newport- beach.ca.us SUBJECT: Hoag Healthcare Center Use Permit No. 2006 -010 Traffic Study No. 2006 -001 Mitigated Negative Declaration (SCH No. 2006 - 101105) 500 -540 Superior Avenue (PA2006 -113) APPLICANT: Newport Beach Healthcare Center, LLC RECOMMENDATION Staff recommends that the Planning Commission adopt the Mitigated Negative Declaration and approve Use Permit No. 2006 -010 and Traffic Study No. 2006 -001 by adopting the attached draft resolution. Environmental Review As stated in the November 16, 2006 Planning Commission staff report, a Mitigated Negative Declaration (MND) has been prepared by Keeton Kreitzer Consulting for the proposed project in accordance with the implementing guidelines of the California Environmental Quality Act (CEQA). The MND is attached was Exhibit 3 to the prior staff report package. The MND was circulated for public review between October 16 and November 14, 2006. Comments were received from the California State Department of Transportation, Rosamond U. Hall, the City of Costa Mesa, Leibold, McClendon & Mann, P.C., Department of Toxic Substances Control, Richard Smith and the Southern California Association of Governments. Responses to these comments have been prepared for consideration (Exhibit 2). Adoption of the MND by the Planning Commission after public hearing is required prior to approval of the Use Permit and Traffic Study. Hoag Healthcare Center (PA 2006 -113) December 7, 2006 Page 2 of 3 Revised Resolution Based on comments received on the draft resolution, staff has revised the resolution to include a number of corrections and clarifications. The following changes were made to the resolution: 1. Title of resolution now clarifies that the Planning Commision is adopting a MND. 2. The 4th WHERAS was added clarifying that the project is consistent with the prior Land Use Element designation of General Industry (GI) and variable floor area limitation. 3. The 7th WHEREAS now identifies from whom comments were received regarding the MND. 4. The 8k' WHEREAS identifies the Mitigation and Monitoring Reporting Plan (MMRP). 5. The 9th WHEREAS was added to clarify that the applicant is responsible for bearing the expense of any judicial challenge of the CEQA determination. 6. The 11th WHEREAS, 1st point, corrected a reference to the current General Plan Land Use Designation of the site as CO -M (old GP designation of General Industry was accidentally cited). 7. The previous draft resolution included the standard conditions and mitigation measures of the MMRP as part of the conditions of approval. However, for clarification and to formally adopt the MMRP as a separate document, the complete MMRP has now been incorporated into the draft resolution as Exhibit "A" and the project conditions of approval are now attached as Exhibit'B ". In addition to the above changes to the text of the draft resolution, the following conditions were added to the project per the recommendation of the City Attorney's Office and as stated in the response to comments: 21. To the fullest extent permitted by law, applicant shall indemnify, defend and hold harmless City, its City Council, its boards and commissions, officials, officers, employees, and agents from and against any and all claims, demands, obligations, damages, actions, causes of action, suits, losses, judgments, fines, penalties, liabilities, costs and expenses (including without limitation, attorney's fees, disbursements and court costs) of every kind and nature whatsoever which may arise from or in any manner relate (directly or indirectly) to City's approval of the Hoag Healthcare Center Project including, but not limited to, the approval of Use Permit No. 2006 -010 and Traffic Study No. 2006 -001; and /or the City's Hoag Healthcare Center (PA 2006 -113) December 7, 2006 Page 3 of 3 related California Environmental Quality Act determinations, the certification of the Mitigated Negative Declaration and /or the adoption of a Mitigation Monitoring Program for the Hoag Healthcare Center Expansion Project. This indemnification shall include, but not be limited to, damages awarded against the City, if any, costs of suit, attorneys' fees, and other expenses incurred in connection with such claim, action, causes of action, suit or proceeding whether incurred by applicant, City, and /or the parties initiating or bringing such proceeding. The applicant shall indemnify the City for all of City's costs, attorneys' fees, and damages which City incurs in enforcing the indemnification provisions set forth in this condition. The applicant shall pay to the City upon demand any amount owed to the City pursuant to the indemnification requirements prescribed in this condition. 22. Prior to the issuance of the demolition permit, the applicant shall undertake and complete an asbestos survey and lead -based paint survey to determine the presence of asbestos and lead -based paint. If it is determined that ACM and /or LBP exists in the structures to be demolished, abatement of the ACM and LBP shall occur prior to demolition of the existing structure. All work undertaken by, the contractor shall comply with SCAQMD Rule 1402 related to the .disturbance of ACM, as well as the storage and disposal of ACM. The contractor's responsibilities shall include proper notification, removal techniques for ACM, clean -up procedures, and waste storage and disposal. 23. If it is determined that hazardous wastes are, or will be, generated by the proposed operations, the wastes must be managed in accordance with the California Hazardous Waste Control Law (California Health and Safety Code, Division 20, Chapter 6.5) and Hazardous Waste Control Regulations (California Code of Regulations, Title 22, Division 4.5). 24. If contaminated soils are encountered during demolition, site preparation, and /or construction activities associated with project implementation, such activities shall cease and appropriate health and safety procedures shall be prescribed and implemented. No further work shall be undertaken until such time as it can be shown to the responsible regulatory agency that the public would not be exposed to a potential health hazard. Prepared by: Jirime Murillo, Associate Planner Exhibits 1. Revised Draft Resolution of Approval 2. Response to Public Comments Submitted by: a. via L , Planning Dir r EXHIBIT 1 Revised Draft Resolution of Approval q RESOLUTION NO. _ A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF NEWPORT BEACH ° . STUDY NO. 2006 -001 FOR PROPERTY LOCATED AT 500 -040 SUPERIOR AVENUE (PA2006 -113). WHEREAS, an application was filed by Newport Beach Healthcare Center, LLC requesting approval of Use Permit No. 2006 -010 and Traffic Study No. 2006 -001, with respect to properties located at 500 -540 Superior Avenue, more specifically located west of Newport Boulevard, east of Superior Avenue, and north of Dana Road, to allow the conversion of 97,000 square feet of research and development (R &D) /general office use to medical office use. The, request also includes the demolition of am existing building and the construction of an additional parking structure that exceeds the: maximum building bulk limitation for the site. Additionally, the applicant requests approval of a traffic study pursuant to the City of Newport Beach Traffic Phasing Ordinance (TPO); and WHEREAS, a public hearing was held on December 7, 2006 in the City Hall Council Chambers, 3300 Newport Boulevard, Newport Beach, California. A notice of time, place and purpose of the meting was given in accordance with the Municipal Cade. Evidence, both written and oral, was presented to and considered by the Planning Commission at this meeting; and WHEREAS, the proposed medical office use, pursuant to the conditions which it will be operated and maintained, is consistent with the Medical Commercial Office (CO- M) land use designation of the 2006 Updated General Plan Land Use Element, which provides primarily for medical- related offices, other professional offices, retail, short- term convalescent and long -term care facilities, research labs, and similar uses. The project site, in particular, is allocated a precise development limitation of 350,000 square feet of floor area. The proposed intensity of development with the demolition of an existing 89,079 square foot building and the proposed medical office use is consistent with this designation; and 5 Planning Commission Resolution No. _ Page 2 of 17 WHEREAS, the subject property is located within the M -1 -A (Controlled Manufacturing) zoning district which provides for a wide range of moderate to low intensity industrial uses and limited accessory and ancillary commercial and office uses. Business and Professional Office uses are permitted within the M-1 -A zone, with the exception that medical offices require the approval of a use permit. The proposed project is consistent with this designation and complies with all development standards with the exception of building bulk. With the implementation of the new CO -M land use designation, the zoning of the site will change to one that will facilitate medical office use and the project should not conflict with future zoning implementation; and WHEREAS, a traffic study for the proposed project has been prepared and approved in compliance with Chapter 15.40 (Traffic Phasing Ordinance) of the Newport Beach Municipal Code for the following reasons: 1. A traffic study, entitled, "City of Newport Beach, Hoag Healthcare Center Traffic Impact Analysis dated September 27, 2006" was prepared by Kunzman Associates for the project in compliance with Chapter 15.40 of the Municipal Code (Traffic Phasing Ordinance). 2. Trip generation rates were developed from two sources. The City of Newport Beach trip generation rates are derived from the Newport Beach Traffic Analysis Model ( "NBTAM ") and were used for analysis of Newport Beach intersections. The City of Costa Mesa trip generation rates are derived from the Institute of Transportation Engineers, Trip Generation, r Edition (2003) and were used for evaluation of Costa Mesa intersections. The Traffic Phasing Ordinance ( "TPO ") analysis was required only for primary intersections in the City of Newport Beach. For the purposes of studying the cumulative impacts, the traffic study analyzed intersections in the City of Costa Mesa, utilizing the ITE trip generation rates. 3. The traffic study indicates that the project will increase traffic on eight of nine studied primary intersections in the City of Newport Beach by one percent (1 %) or more during peak hour periods one year after the completion of the project. 4. Utilizing the Intersection Capacity Utilization (ICU) analysis specified by the Traffic Phasing Ordinance, the traffic study determined that the eight primary intersections identified will continue to operate at satisfactory levels of service as defined by the Traffic Phasing Ordinance, and no mitigation is required. 5. The traffic study also performed a cumulative traffic analysis, including an analysis of seven intersections in the City of Costa Mesa. Reasonably foreseeable projects and approved projects that are not included in the committed project list were Planning Commission Resolution No. _ Page 3 of 17 added to project related traffic and evaluated. The conclusion of this analysis also indicates that there will be a less than significant impact to traffic circulation and that no mitigation is required. 6. Based on the weight of the evidence in the administrative record,. including the traffic study, the implementation of the proposed mix of uses will neither cause nor make worse an unsatisfactory level of traffic service at any impacted primary intersection. 7. Construction of the project will be completed within sixty (60) months of this approval, or the approval of a new traffic study will be required. WHEREAS, an Initial Study and Mitigated Negative Declaration (MND) have been prepared in compliance with the Environmental Quality Act (CEQA), the State CEQA Guidelines; and, City Council Policy K -3. The Draft MND was circulated for public comment between October 16 and November 14. 2006. RIP n M The contents of the environmental document, including comments on the document, have been considered in the various decisions on this project; and WHEREAS, on the basis of the entire environmental review record, the proposed project, will have a less than significant impact upon the environment and there are no known substantial adverse affects on human beings that would be caused. Additionally, there are no long -term environmental goals that would be compromised by the project, nor cumulative impacts anticipated in connection with the project The mitigation measures identified �_ `,� P "` c` are feasible and reduce potential environmental impacts to a less than significant level; and WHEREAS, the maximum building bulk limitation for the sit is the base floor area limit (0.5) plus 0.25 for a maximum of 0.75, or 447,295 square feet. The proposed project consists of a total of three buildings and two 4 -level parking structures, resulting in a total bulk area of 747,202 square feet. A use permit for the increased building bulk has been prepared and approved in accordance with Section 20.63.060 (Floor Area 1 Planning Commission Resolution No. _ Page 4 of 17 Ratios and Building Bulk) of the Newport Beach Municipal Code, for the following reasons: The increased development will not create abrupt changes in scale with development in the surrounding area because the proposed parking structure will not exceed the height of the existing building it replaces and should therefore not be considered an intrusive element within the area. The location of the new parking structure backs up to the existing City Yard and is proposed to be screened from Newport Boulevard with trees and landscaping. The proposed parking structure is located farthest from the existing residential development to the south and is separated by abutting streets, existing multi -story buildings, parking areas and landscaping within the overall campus. The parking structure has been designed to be open with natural ventilation and one floor located below, grade. The use of glass and perforated metal panels on the parking structure will provide a "transparency" that will help break up the visual massing of the building. 2. The proposed parking structure will be compatible with the surrounding. area since it is located adjacent to the city corporate yard and separated from nearby residential uses by abutting streets, parking areas and open space. The project will substitute a new parking structure in place of the demolished office building and will not significantly change the existing visual character or quality of the site or its surroundings. Additionally, the proposed parking structure will support the increased parking needs of the existing R &D /general offices uses and proposed medical office use by providing additional parking opportunities. 3. The increased development will not result in significant impairment of public views as public views do not exist through the site. 4. The site is physically suitable for the proposed development as it is located in a fully developed and urbanized area, and does not contain any sensitive habitat or natural resources. The site itself is developed with 4 R &D /office buildings, a large parking structure, and surface parking. Although the property is devoid of slopes, the site is bounded by a 25- to 30 -foot descending slope along the eastern property boundary. However, the proposed parking structure is located approximately 60 feet from the top of the slope at its nearest point. Therefore, the potential for gross instability of the slope affecting the parking structure is low, especially since the existing building is located in the same position and has not experienced an subsidence issues to date. An initial study has been prepared which considered all physical aspects of the project including setbacks, site access, landscaping, open space, building height, available parking, and available utilities, and determined that no significant environmental impacts should occur as a result of project implementation. I Planning Commission Resolution No. Page 5 of 17 WHEREAS, the proposed project, pursuant to the conditions under which it will be operated and maintained, will not be detrimental to the public health, safety, peace, morals, comfort, or welfare of persons residing or working in or adjacent to the neighborhood of such use; and will not be detrimental to the properties or improvements in the vicinity or to the general welfare of the City for the following reasons: Medical office use is permitted within the General Plan land use designation, as well as the Controlled Manufacturing (M- 1-A) Zoning District, with the approval of a use permit. 2. The parking structure is located adjacent to the City's Corporate Yard and is separated from residential uses by abutting streets, parking areas, and open space within the overall campus. 3. The proposed parking structure has been designed to be consistent and compatible with the existing development through building height, massing, and architectural character, and as a result, will remain much the same as the existing development and will not be perceived as additional bulk on site. 4. The project is proposed to provide a total of 1,985 parking spaces on -site, exceeding the minimum code requirement by 763 spaces, thereby providing sufficient parking to accommodate the proposed uses. 5. The Traffic Engineering Department has reviewed the proposed shuttle operation and has approved a safe route and operation that will avoid travel adjacent to residences and convalescent homes. 6. The traffic study has determined that the increased traffic generated as a result of project implementation will not result in significant impacts to intersections or traffic circulation in the City of Newport Beach, nor affect intersections in the City of Costa Mesa. 7. An environment review and analysis was performed for the project and was determined that no environmental impacts would occur as a result of project implementation. NOW THEREFORE, THE PLANNING COMMISSION HEREBY RESOLVES AS FOLLOWS: Section 1. The Planning Commission of the City of Newport Beach does hereby find, on the basis of the whole record, that there is no substantial evidence that the project will have a significant effect on the environment and that the Mitigated Negative Declaration reflects the Planning Commission's independent judgment and analysis. The Planning Commission hereby adopts Mitigated N ative Declaration SCH No. 2006- 101105, 16 t +# 'j _ MIN W Il Planning Commission Resolution No. _ Page 6 of 17 The document and all material, which constitute the record upon which this decision was based, are on file with the Planning Department, City Hall, 3300 Newport Boulevard, Newport Beach, California. Section 2. Based on the aforementioned findings, the Planning Commission hereby recommends approval of Use Permit No. 2006 -010 and Traffic Study No. 2006- 001, all subject to the Conditions of Approval in Of attached hereto and made hereof. PASSED, APPROVED AND ADOPTED THIS 7h DAY OF DECEMBER, 2006. BY: Jeffery Cole, Chairman M Robert Hawkins, Secretary AYES: NOES: ABSENT: )a Planning Commission Resolution No. Page 7 of 17 Mitigation Monitoring and Reporting Program Hoag Health Center Project Newport Beach, CA 2 .... ... ... n: Aesthetics The site shall not be excessively illuminated based on the luminance recommendations of the Illuminating Engineering Society of North America, or, if in the opinion of the Planning MM-1 Director, the Illumination creates an unacceptable On-Going Project Operations Planning negative impact on surrounding land uses or Monitoring Department environmental resources. The Planning Director may order the dimming of light sources or other remediation upon finding that the site is excessively illuminated. Prior to the issuance of building permits, the MM -2 applicant shall prepare a photometric stud) n Plan Check Prior to Issuance of the Planning conjunction with a final lighting plan for approval Building Permit Department by the Planning Department. Air Quality The applicant shall employ the following best available control measures ('BACMs) to reduce construction- related air quality impacts: Dust Control • Water all active construction areas at least twice daily- • Cover all haul trucks or maintain at least two feet of freeboard. • Pave or apply water four times daily to all unpaved parking or staging areas. • Sweep or wash any site access points within two hours of any visible dirt deposition on any public roadway. On-Going • Cover or water twice daily any on -Site Monitoring Building SCA stockpiles of debris, dirt or other dusty Contractor to During Grading and Department material. Certify Emission Construction Contractor • Suspend all operations on any unpaved and Off-Site Impacts surface I winds exceed 25 mph. Emissions • Require 90-day low-NOx tune-ups for off road equipment. • Limit allowable idling to 30 minutes for trucks and heavy equipment Off-Site impacts • Encourage car pooling for construction workers. • Limit lane closures to off -peak travel periods. - Park construction vehicles off traveled Planning Commission Resolution No. Page 8 of 17 Id. No kAidgattatrAAeasiire AA.ethodaf `' -A roadways. • Wet down or cover dirt hauled off-site. • Sweep access points daily. • Encourage receipt of materials during non- Peak traffic hours. • Sandbag construction sites for erosion control. Fill Placement • The number and type of equipment for dirt pushing will be limited on any day to ensure that SCAQMD significance thresholds are not exceeded. • Maintain and utilize a continuous water application system during earth placement and compaction to achieve a 10 percent soil moisture content in the top six-inch surface layer. Subject to review/discretion of the geotechnical engineer- Cultural Resources Prior to issuance of a grading permit, the applicant shall provide written evidence to the Planning Director that a qualified archaeologist has been retained to observe grading activities and conduct a Pre-grading conference, shall establish procedures for archaeological resource surveillance, and shall establish, in cooperation with the applicant, procedures for temporarily halting or redirecting work to permit the sampling, identification and evaluation Of the artifacts as MM-3 appropriate. If additional or unexpected Report Prior to Issuance of the Planning archaeological features are discovered, the Grading Permit Department archaeologist shall report such findings to the applicant and to the Planning Department, If the archaeological resources are found to be significant, the archaeological observer shall determine appropriate actions, in cooperation with the applicant, for exploration and/or salvage. These actions, as well as final mitigation and disposition of the resources, shall be subject to the a roval of the Planning Director. Prior to issuance of a grading permit, the applicant shall provide written evidence to the Planning Director that a qualified paleontologist has been retained to observe grading activities and -salvage fossils as necessary. The paleontologist shall be present at the pre-grading conference, shall establish Procedures for temporarily halting or redirecting work to permit MM4 the sampling, identification and evaluation of the Report Prior to Issuance of the Planning fossils as appropriate. If major paleontological Grading Permit Department resources are discovered that require long-term baiting or redirecting of grading, the paleontologist shall report such findings to the applicant and the Planning Department The paleontologist shall determine appropriate actions, in cooperation with the applicant, which mitigation and disposition of the resources shall be Subject to the approval of the Planning Director. Id. Planning Commission Resolution No. Page 9 of 17 No; Mtttgadan Measure Method of .. .... .... M . ...... ow In accordance with the Public Resources Code 5097 94, if human remains are found, the Orange County Coroner must be notified within 24 hours of the discovery. If the coroner determines that the remains are not recent, the coroner shall Contractor MM -5 notify the Native American Heritage Commission Notification During Grading and (NAHC) in Sacramento to determine the most Construction Building likely descendent for the area. The designated Department Native American representative shall then determine, in consultation with the property owner, the disposition of the human remains. Hazards and Hazardous Materials Prior to the issuance of the demolition permit, the applicant shall undertake and complete an asbestos survey and lead-based paint survey to determine the presence of asbestos and lead- based paint- If it is determined that ACM and /or LBP exists in the structures to be demolished, abatement of the ACM and LBP shall occur prior SC-10 to demolition of the. existing structure. All work Survey Prior to Issuance of the Building undertaken by the contractor shall ,comply with , Demolition Permit Department SCAQMD Rule 1402 related to the disturbance of ACM, as well as the storage and disposal of ACM. The contractors responsibilities shall include proper notification, removal techniques for ACM, clean-up procedures, and waste storage and disposal. The applicant shall prepare a plan that prescribes appropriate building management measures to control vapor intrusion into the buildings at the MM-6 site. The Building Management Plan shall be Plan Check Prior to Issuance of the Fire [)apartment submitted to either the RWQCB, the Orange Building Permit County Health Care Agency, and/or DTSC for approval prior to the issuance of the building permit for the Project. The applicant shall prepare a soil profile plan that characterizes the excavated soils that would be MM-7 reused or removed from the site. This plan shall Plan Check Prior to Issuance of the Fire Department be submitted to either the RWOCB, the Orange Building Permit OCHCA, and/or DTSC for approval prior to the issuance of the building permit for the Project. In the event that hazardous waste is discovered during site preparation or construction, the applicant shall ensure that the identified hazardous waste and/or hazardous materials are handled and disposed of in the manner specified MM-8 by the State of California Hazardous Substances On-Site During Grading and Fire Department Control Law (Health and Safety Code Division 20, Monitoring Construction Chapter 6.5), standards established by the California Department of Health Services and office of Statewide Planning and Development, and according to the requirements of the California Administrative Code, Title 30. Hydrolol and Water Quality Storm Water Pollution Prevention Plan (SWPPP) and Notice of Intent (NOI) to comply with the General Permit for Construction Activities SC-2 will be prepared, submitted to the State Water Plan Check Prior to Issuance of the Building Quality Control Board for approval and made part Grading Permit Department of the construction program. The project applicant will provide the City with a copy of the 13 Planning Commission Resolution No. Page 10 of 17 1q N M, J ............. Mp Dk;z NOI and their application check as proof of filing with the State Water Quality Control Board. This plan will detail measures and practices that will be in effect during construction to minimize the prolecfs impact on water quality. A list of 'good house-keeping" practices wig be incorporated into the long-term post-construction operation of the site to minimize the likelihood that pollutants will be used, stored or spilled on the site that could impair water quality. These may include frequent parking area vacuum truck sweeping, removal of wastes or spills, limited use SC-3 of harmful fertilizers or pesticides, and the Plan Check Prior to Issuance of the Building diversion of storm water away from potential Grading Permit Department sources of pollution (e.g., trash receptacles and parking structures). The Stage 2 WOMP shall list and describe all structural and non-structural BMPs. In addition, the WOMP must also identify the entity responsible for the long-term inspection, maintenance, and funding for all structural (and if applicable Treatment Control) BMPs. Noise Construction activities shall comply with Section 10.28.040 of the Newport Beach Municipal Code, which restricts hours of noise-generating SC-4 construction activities that produce noise to On -Site During Grading and Building between the hours of 7:00 a.m. and 6:30 p.m., Monitoring Construction Department Monday through Friday and 8:00 a.m. and 6:00 p.m. on Saturday. Noise-generating construction activities are not allowed on Sundays or Holidays. Prior to the issuance of the demolition permit, the project applicant shall prepare a construction staging plan that reflect the locations of the construction and staging areas on the subject Prior to Issuance of the PublicWorks MM -9 property, which shall be located as far away from Plan Check Demolition Permit Department the nearby residential development as possible to reduce temporary noise impacts. Public Services and Facilities Any elevators shall be gurney accessible in Prior to Issuance of the SC-5 accordance with Chapter 30 of the 2001 California Plan Check Building Permit Fire. Department Ruddina rmda The Fire Chief may require the submittal for approval of geological studies, evaluations, reports, remedial recommendations and/or similar documentation from a state- licensed and department approved individual or firm, on any parcel of land to be developed which: SC-6 Has, or is adjacent to, or within 1,000 feet Plan Check Prior to Issuance of the Grading Permit Fire Department (304.8 m) of a parcel of land that has an active, inactive, or abandoned oil or gas well operation, petroleum or chemical refining facility, petroleum or chemical storage; or May contain or give off toxic, combustible or flammable liquids, gases, or vapors. SC-7 Automatic fire sprinklers and Class I standpipe Plan Check Prior to Issuance of the Fire Deparbrient required. Building Permit r­SC-8 I Fires rinkler system shall be monitored. Plan Check Prior to Issuance of the Fire Department 1q Planning Commission Resolution No- _ Page 11 of 17 Utilities sanitary sewer system demand study on the existing facilities that will serve the portion of the site impacted by the proposed development. prior to Issuance of the Public Works SC -9 These studies shall 6e submitted to the City of Plan Check Building Pernik Department Newport Beach prior to issuance of the demolition permit. The owner shall bear the costs of all water and/or sanitary sewer systems 0 Planning Commission Resolution No. _ Page 12 of 17 Conditions of Approval Use Permit No. 2006 -010 & Traffic Study No. 2006 -001 Planning Department The development shall be in substantial conformance with the plans dated November 6, 2006, except as modified by other conditions. 2. The project is subject to all applicable City ordinances, policies, and standards, unless specifically waived or modified by the conditions of approval. 3. The applicant shall comply with all federal, state, and local laws. Material violation of any of those laws in connection with the use may be cause for revocation of this Use Permit. 4. Project approvals shall expire unless exercised within 24 months from the effective date of approval as specked in Section 20.91.050A of the Newport Beach.Municipal Code. Reasonable extensions may be granted by the Planning Director in accordance with applicable regulations. 5. This Use Permit may be modified or revoked by the City Council or Planning Commission should they determine that the use or one or more of the conditions set forth herein is not being complied with, or the manner in which the project is being operated or maintained is detrimental to the public health, welfare or materially injurious to property or improvements in the vicinity or if the property is operated or maintained so as to constitute a public nuisance. 6. The project site may be occupied by no more than 97,000 square feet of medical office use and 136,000 square feet of general office use. The remaining floor area (96,414 square feet minimum) shall be occupied by research and development uses. The Planning Director shall review all building plans, future tenant improvement plans and/or business plans for all prospective tenants proposed to be classified as research and development .uses to make a finding that the tenant occupancy is a use that is consistent with Section 20.20.020 of the Newport Beach Municipal Code, and further as defined in Section 20.05.060 (B), (D), and (F). 7. The applicant may proceed to lease medical office space during the construction of the parking structure; however, the project site shall maintain the minimum number of parking spaces required by the Zoning Code for the operating mix of uses during such time. 8. The final design of the parking structure shall provide all architectural treatments as proposed and approved. f� Planning Commission Resolution No. Page 13 of 17 9. No ancillary parking shall be permitted to occur at the project site for the use of Hoag Hospital, except during a one -year interim period to facilitate the completion of Hoag Hospital's construction of the Lower Campus (so long as that the minimum parking to facilitate the operation of the mix of on -site uses is provided). 10. Prior to issuance of building permits for any new construction, the applicant shall submit a landscape and irrigation plan prepared by a licensed landscape architect or licensed architect for on -site and any adjacent off -site planting areas. These plans shall incorporate drought tolerant plantings and water efficient irrigation practices. Except for that portion of the landscape plan that is subject to the approval of the Planning Commission, the landscape plans shall be approved by the Planning Director prior to the issuance of a building permit. All planting areas shall be provided with a permanent underground automatic sprinkler irrigation system of a design suitable for the type and arrangement of the plant materials selected. The irrigation system shall be adjustable based upon either a signal from a satellite or an on -site moisture - sensor, Planting areas adjacent to vehicular activity shall be protected by a continuous concrete curb or similar permanent barrier. Landscaping shall be located so as not to impede vehicular sight distance to the satisfaction of the Traffic Engineer. 11. All landscape materials and landscaped areas shall be maintained in accordance with the approved landscape plan. All landscaped areas shall be maintained in a healthy and growing condition and shall receive regular pruning, fertilizing, mowing and trimming. All landscaped areas shall be kept free of weeds and debris. All irrigation systems shall be kept operable, including adjustments, replacements, repairs, and cleaning as part of regular maintenance. 12.AII mechanical equipment shall be screened from view of adjacent properties and adjacent public streets, and shall be sound attenuated in accordance with Chapter 10.26 of the Newport Beach Municipal Code, Community Noise Control. 13.Prior to issuance of the certificate of occupancy or final of building permits, the applicant shall schedule an evening inspection by the Code and Water Quality Enforcement Division to confirm control of light and glare specified in Condition Nos. 48 & 49. 14. notification of costs, the applicant shall be responsible for the payment of all administrative costs identified by the Planning Department. 15. New landscaping shall incorporate drought- tolerant plant materials and drip irrigation systems where possible. 11 Planning Commission Resolution No. _ Page 14 of 17 16. Water leaving the project site due to over - irrigation of landscape shall be minimized. If an incident such as this is reported, a representative from the Code and Water Quality Enforcement Division of the City Manager's Office shall visit the location, investigate, inform the tenant if possible, leave a note, and in some cases shut off the water. 17. Watering shall be done during the early morning or evening hours (between 4:00 P.M. and 9:00 A.M.) to minimize evaporation the following morning. 18. All leaks shall be investigated by a representative from the Code and Water Quality Enforcement Division of the City Manager's Office and the Applicant shall complete all required repairs. 19. Water should not be used to clean paved surfaces such as sidewalks, driveways, parking areas, etc. except to alleviate immediate safety or sanitation hazards. 20. Reclaimed water shall be used whenever available, assuming it is economically feasible. �b Planning Commission Resolution No. _ Page 15 of 17 Building Department 25.The applicant shall be responsible for the payment of all applicable City plan check and inspection fees. 26.The applicant is required to obtain all applicable permits from the City Building and Fire Departments. The construction plans must comply with the most recent, City- adopted version of the California Building Code. 27.The size, layout, path of travel and dispersion of the disabled parking stalls shall be reviewed and approved by the Building Department prior to the issuance of permits and shall comply with code requirements. 28.The proposed open parking garage occupancy (S-4) and basement occupancy separation shall comply with Sections 311.2.2.2 of the California Building Code (CBC 2001). 29. Compliance with ADA code requirements shall be verified for the existing parking structure on -site and updated as required by the Building Department. 30. Canopies shall be provided above the disabled parking stalls at the other buildings within the project site per Section 1109B.2 of the California Building Code, unless otherwise approved by the Building Department. 19 Planning Commission Resolution No. _ Page 16 of 17 Public Works Department 31. ADA compliant paths shall be provided within the areas identified and affected by the project's scope of work. Prior to commencement of demolition and grading of the project, the applicant shall submit a construction management and delivery plan to be reviewed and approved by the Public Works Department. The plan shall include discussion of project phasing; parking arrangements for both sites during construction; anticipated haul routes and construction mitigation. Upon approval of the plan, the applicant shall be responsible for implementing and complying with the stipulations set forth in the approved plan. 33.Traffic control and truck route plans shall be reviewed and approved by the Public Works Department before their implementation. Large construction vehicles shall not be permitted to travel narrow streets as determined by the Public Works Department. Disruption caused by construction work along roadways and by movement of construction vehicles shall be minimized by proper use of traffic control equipment and flagman. 34. Vehicular traffic on Dana Road and Flagship Road shall not be impacted by private construction work. 35.A haul route permit shall be required for any large construction related vehicle (i.e. dirt hauling vehicle). 36. No construction material shall be staged or stored within the public right -of -way. 37. Prior to issuance of building permits for new construction, the on -site parking (surface and structure), vehicle circulation and pedestrian circulation systems shall be subject to further review and approval by the Traffic Engineer. 38. The intersection of the driveways and streets shall be designed to provide adequate sight distance per City Standard STD - 110 -L. Slopes, landscape, walls and other obstruction shall be considered in the sight distance requirements. Landscaping within the sight line shall not exceed twenty -four inches in height. The sight distance requirement may be modified at non - critical locations, subject to approval of the Traffic Engineer. 39. The southerly driveway (adjacent to Dana Road) shall be restricted to right -turn in and right -turn out. The method to reinforce (i.e. signage, median, etc.) the right -turn in and right -turn out driveway shall be reviewed and approved by the Public Works Department. ab Planning Commission Resolution No. Page 17 of 17 40.The van shuttle between Hoag Hospital and the project site shall not use local streets (i.e. Dana Road and Flagship Road) and residential areas. The shuttle route shall be restricted to the City's arterial system (i.e. Newport Boulevard, Superior Avenue, Placentia Avenue, Hospital Road). 41. Prior to the issuance of any medical office tenant improvement permits, the applicant shall post a 10 -year bond for the traffic signal installation at the main project driveway (center driveway) and roadway improvements (medians, striping, planting). Upon acquisition of the required right -of -way needed to accommodate the improvements, the City will be responsible for completing the traffic signal installation and street improvements, and the applicant shall reimburse the City for all costs associated with the improvements. 42. Prior to issuance of grading permits, the applicant shall prepare and submit a Water Quality Management Plan (WQMP) for the proposed project, subject to the approval of the Building Department and Code and Water Quality Enforcement Division. The WQMP shall provide appropriate Best Management Practices (BMPs) to ensure that no violations of water quality standards or waste discharge requirements occur. 43. Prior to the issuance of grading permits, the applicant shall prepare a water system and a sanitary sewer system demand study on the existing facilities that will serve the portion of the. site impacted by the proposed development. These studies shall be submitted to the City of Newport Beach prior to issuance of the demolition permit. The owner shall bear the costs of all water and /or sanitary sewer systems improvements required by the development. ,�I EXHIBIT 2 Responses to Public Comments zA RESPONSE TO PUBLIC COMMENTS HOAG HEALTH CENTER MITIGATED NEGATIVE DECLARATION NEWPORT BEACH, CA INTRODUCTION The 30 -day public review period for the Draft Mitigated Negative Declaration (MND) prepared for the Hoag Health Center Project extended from October 16 through November 14, 2006. The City of Newport Beach received seven (7) comment letters on the Draft MND during the formal public review and comment period. Responses to the comments in the letters received by the City have been prepared and are included with the Final MND. The comment letters were received from: 1. California Department of Transportation (November 13, 2006) 2. Rosamond U. Hall (November 7, 2006) 3. City of Costa Mesa (November 14, 2006) 4. Leibold McClendon & Mann (November 14, 2006) 5. Department of Toxic Substances Control (November 13, 2006) 6. Richard Smith (November 13, 2006) 7. Southern California Association of Governments (November 14, 2006) 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 letter has 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 MND. Each comment in each letter for which a response is required has been numbered for easy reference. Hoag Health Center Responses to Public Comments December 2008 �3 .,..v ucrANIMENT 6 2006 DEPARTMENT OF TRANSPORTATION NOV District A CITY OF NEWPORTAACk1 3337 Michelson Drive, Suite 380 " Irvine, CA.92612 -8894 ` Tel: (949) 724 -2267 F%x ymtr r7 Fax: (949) 724 -2592 Be energy effletend FAX & MAIL Novemlier•13; 200¢ , Jamie Murillo City of Newport Beach 3300 Newport Boulevard Newport Beach, California 92685 Subject: Hoag Heath Center Use Permit Dear Mr. Murillo, File: IGR/CEQA SCH #: 2006101105 Log #: 1790 PCH, SR -55 Thank you for the opportunity to review and comment on the Initial Study and Mitigated Negative Declaration for the Hoag Health Center project. The applicant Newport Beach Healthcare Center, is requesting the approval of an amendment to the existing use permit to allow the conversion of a 97,000 square feet office use to medical offices, demolition of one existing building, construction of a second parking structure, and the project site to exceed the maximum building bulk limitation. The project site is located on 500 -540 Superior Avenue in the City of Newport Beach. The nearest State routes to the project site are PCH and SR -55. Caitraus District comment: 12 status is a responsible agency on this project and has the following Caltrans Traffic Operations requests all applicants to use the Highway Capacity Manual (HCM) method outlined in the latest version when analyzing traffic impacts on State Transportation Facilities. The use of HCM is preferred by Caltrans because it is an operational analysis as opposed to the Intersection Capacity Utilization (ICU) method, which is a planning analysis. In the case of projects that have direct impacts on the state's facilities Caltrans recommends that the traffic impact analysis be based on HCM method. Should the project require an encroachment permit, traffic operations may find the Traffic Impact Study based on ICU methodology inadequate resulting in possible delay or denial of a permit by Caltrans. All input sheets, assumptions and volumes on State Facilities including tamps and intersection analysis should be submitted to Caltrans for review and approval. Please continue to keep us informed of this project and any future developments, which could potentially impact the State Transportation Facilities. If you have any questions or need to contact us, please do not hesitate to call Maryam Molavi at (949) 724 -2267. Sin Ryan hamberlain, Branch Chief Local Development/Intergovernmental Review C: Terry Roberts, Office of Planning and Research "Caltrans improves mobihry across CaWorma" f' California Department of Transportation (November 14, 2006) Response to Comment No. 1 The traffic study was prepared in accordance with the City of Newport Beach Traffic Phasing Ordinance (TPO) requirements and City of Costa Mesa Traffic Study guidelines. If a discretionary permit is required by Caltrans in the future, the applicant would be conditioned to prepare a traffic study in accordance with Caltrans requirements at that time. Hoag Health Center Responses to Public Comments December 2000 g5 ROSAMOND U. HALL R. E. Hall Family Limited Partnership P.O. BOX 2450 NEWPORT BEACH, CA 92658 -8972 November 7, 2006 RECEIVED By PLANNING DEPARTMENT Nov 0 g 2006 Attn: Planning Commission �� �F �E r►rVRM City of Newport Beach Planning Department I BEACH P.O. Box 1768 Newport Beach, CA 92658 -8915 RE: Application No.: PA2006-113 Applicant Name: Hoag Healthcare Center Traffic Study No.: 2006 -001 Use Permit No.: 2006 -010 Property Location: 500 -540 Superior Avenue, Newport Beach, CA Dear Planning Commission members, As I stated in my letter dated May 17, 2004 regarding: Application No.: PA2003 -122 Applicant Name: New Superior Group, LLC Traffic Study No.: 2003 -001 Amendment to: Use Permit No. 3679 Property Location: 500 -540 Superior Avenue, Newport Beach, CA We would be impacted by the above Use Permit Changes. I would like to inform you that: We did not support the change in designation from research and development uses to general office uses and now we definitely do not support the change to medical offices. There is already considerable traffic on Superior Avenue that causes congestion, even to the point of turning onto Superior from as far away as Hospital Road intersection. With the designation medical offices will come a significantly increased amount of employees, visitors and clients to and from these offices. There have already been numerous accidents at this intersection with pedestrians and vehicles without any solutions to existing problems. We should not be adding traffic as they have not been addressed. Sincerely, Rosamond U. Hall M- ROSAMOND U. HALL P.O. BOX 2450 NEWPORT BEACH, CA 92658 -8972 May 17, 2004 Attn: Jim Campbell City of Newport Beach Planning Department P.O. Box 1768 Newport Beach, CA 92658 -8915 RE: Application No.: Applicant Name: Traffic Study No.: Amendment to: Property Location: Dear Mr. Campbell, PA2003 -122 New Superior Group, LLC 2003 -001 Use Permit No. 3679 500 -540 Superior Avenue Newport Beach, CA RECEIVED BY PLANNING DEPARTMENT NOV 0 9 2006 CITY OF NEWPORT BEACH I have received the Notice of Public Hearing to be held 7 :00 PM, May 25, 2004 in the Council Chambers of the Newport Beach City Hall. As we would be impacted by the above Use Permit Changes I would like to inform you that: We do not support the change in designation from research and development uses to general office uses. There is already considerable traffic on Superior Avenue that causes congestion, even to the point of turning onto Superior from as far away as Hospital Road intersection. With the designation general office will come a significantly increased amount of employees, visitors and clients to and from these offices. Sincerely, Rosamond U. Hall �1 2. Rosamond U. Hall (November 7, 2006) Response to Comment No. 1 This comment (and letter to City staff dated May 17, 2004) expresses general opposition to the proposed project. The comment does not raise any issues about the project's environmental impacts or the adequacy of the initial study prepared pursuant to CEQA. This comment is acknowledged and will be forwarded to the Newport Beach Planning Commission for consideration prior to taking action on the proposed project. Hoag Health Center Responses to Public Comments December 2006 I November 14, 2006 CITY OF COSTA MESA P.O. BOX 1200 - 77 FAIR DRIVE • CALIFORNIA 92626.1200 DEVELOPMENT SERVICES DEPARTMENT Mr. Jamie Murillo, Associate Planner Planning Department City of Newport Beach 3300 Newport Boulevard P.O. Box 1768 Newport Beach, CA 92658 -8915 RECEIVED BY PLANNING DEPARTMENT NOV 16 2006 CITY OF NEWPORT BEACH SUBJECT: NOTICE OF INTENT TO ADOPT A NEGATIVE DECLARATION FOR HOAG HEALTH CENTER AT 500 -540 SUPERIOR AVENUE Dear Mr. Murillo: The City of Costa Mesa has reviewed the Notice of Intent to adopt a Negative Declaration for Hoag Health Center at 500 -540 Superior Avenue. The proposed project consists of: (1) the conversion of general office use to medical office use; (2) the completion of a remodel of the Project site including demolition of one of the existing buildings; (3) the construction of a second parking structure; and (4) the Project site to exceed the maximum building bulk limitation for the site. Following are the City's comments on the proposed project. • TRANSPORTATIONICIRCULATION The City encourages that the Negative Declaration analysis be conducted under the following assumptions: (a) It is the City's understanding that the site is not fully occupied. Therefore, any future analysis should take into account full 1 occupancy of the site as a background condition. (Ref: Page 23 of the traffic study states that "...the property is fully developed office..." (b) Table 7 of the Negative Declaration (Page 44) and Table 4 - Cumulative Project List of Appendix B (Page 34), should include 1901 Newport Boulevard, a 145 -unit residential development, and 2 1640 Newport Boulevard, a 4 -story, 76,650 sq. ft. medical office building in the vicinity of Newport Boulevard /19" Street. _ The City recommends that all analyses include these assumptions. Building Division (714) 7545273 • Code Enforcement (714) 7545623 • Planning Division (714) 7545245 FAX (714) 754 -4856 • TDO (714) 7545244 • mmv.ci.costaanesa.ca.us Mr. Murillo November 14, 2006 Page 2 The City would also appreciate clarification as to what project is specifically being referenced in Table 8 (Page 46) of the Negative Declaration under CEQA Impact Analysis. Thank you for the opportunity to comment on this Negative Declaration. The City requests that the above comments be addressed and submitted for review to Peter Naghavi, Transportation Services Manager for the City of Costa Mesa, prior to further action by elected officials. We hope to continue to have close communication on this project and an opportunity to fully understand any significant impacts. If you have any questions or need. additional information, please contact me at (714) 754 -5609. Sincerely, FMIaAEL ROBINSON, AICP stant Dev. Svs. Director cc: City Council Allan Roeder, City Manager Donald D. Lamm, Deputy City Mgr., Dev. Svs. Director Kimberly Hall - Barlow, City Attorney Kimberly Brandt, Principal Planner Peter Naghavi, Transportation Mgr. Raja Sethuraman, Assoc. Engineer Rebecca Robbins, Assistant Planner 3. City of Costa Mesa (November 14, 2006) Response to Comment No. f The traffic study takes into account the previous approvals (Newport Technology Center) for the proposed site as background traffic (refer to Table 4 in the traffic study). Response to Comment No. 2 Based on previous meeting and correspondence with City of Costa Mesa staff, only the Pacific Medical Plaza (76,650 Sq. ft.), located at 1626 and 1640 Newport Boulevard, was taken into account as part of the Hoag Healthcare Center Traffic Study (refer to page 43 and Appendix E of the Traffic Study). The 145 - unit residential development located at 1901 Newport Boulevard was never mentioned in previous discussion with City of Costa Mesa staff and was not included in the future projects identified by the City. Hoag Health Center Responses to Public Comments December 2M 31 LB Bom MCCLENDON & MANN A PitonwONAL CoRPORArRm JOHN G. MCCLWNDON j+rhnWeQti.com 23422 NhL Cxesa DRIVE, SUM 105 LACUNA Haas, CALtromm 92653 (149) 457-6300 FAX: (949) 4574M November 14, 2006 Me-MAIL TO: Jmurillo a(t> ity.newport- 6each.ca.us Honorable Chairperson and Members of the City of Newport Beach Planning Commission 3300 Newport Boulevard Newport Beach, California 92658 -8915 Re: Hone Healthcare Center [gMgiicant: Neweort Beach Healthcare Center . LLCI Mitigated Negative Declaration for Use Permit No. 2006 -010 and Traffic Study No. 2006- 001(PA2006 -113) – Request to Prepare Draft EIR for Project Dear Chairperson and Planning Commission Members: This firm represents a group of citizens who are concerned about the potentially significant environmental impacts that will likely result from the above - referenced project (the "Project "). On behalf of these concerned citizens, we submit this letter urging that you not approve the Project entitlements unless and until a legally adequate environmental impact report ( "EIR ") is prepared thatadequatelyanalyzes numerous environmental issues that have been either ignored completely, or perfunctorily dismissed as insignificant, in the mitigated negative declaration ( "MND') that Keeton Kreitzer Consulting prepared for the Project. Traffic/Parldng and "Piecemealing" of the Project Section 15378 of the CEQA Guidelines defines a "project" under CEQA to mean "the whole of an action which has a potential for resulting in a physical change in the environment, directly or ultimately... " (Emphasis added.) In deference to this definition of a "project," courts have consistently found that "piecemealing" a project through the CEQA review process, i.e., breaking a project up into parts, and then incrementally approving each of those parts without an EIR, violates both the letter and the spirit of CEQA, and Sections 15004, 15051, and 15378 of the CEQA Guidelines. As the court noted in Rio Vista Farm Bureau v. County of Solano (1992) 5 Cal.AppAth 351, 370: "The requirements of CEQA cannot be avoided by piecemeal review which results from `chopping a large project into many little ones — each with a minimal potential impact on the environment — which cumulatively may have disastrous consequences.' (Bozung v. Local Agency Formation Com. (1975) 13 Ca1.3d 263, 283 -284 [118 Cal.Rptr. 249, 529 P.2d 3a City of Newport $each Planning Commission. Hoag Healthcare Center Project November 14, 2006 Page 2 10171; City of Antioch v. City Council (1986) 187 Cal.App.3d 1325,1333 [232 Cal.Rptr. 507].)" (See also, Citizens Assn. for Sensible Development of Bishop Area v. County oflnyo (1985) 172 Cal.App.3d 151.) Although the MND is rather obtuse on the point, it nevertheless reveals that the conversion of 97,000 square feet of existing floor area to medical office use is simply the first "part" of the applicant's plan to ultimatelyutilize the entire 329,414 square feet for medical office use. For example, on page 32 of the MND Checklist Form, the consultant acknowledges that the replacement of an existing office building with a new parking structure is being proposed in order "to accommodate existing gncj future use of the site" (Emphasis added.) Then, on page 49, the MND acknowledges that the site currently has more than enough parking to accommodate the proposed 97,000 square feet of medical office uses, 136,000 square feet of general office uses, and 96,414 square feet of research and development uses. Nevertheless, the applicant proposes to construct additional parking such that the site will have a total of 1,985 parking spaces — "approximately six parking spaces for each 1,000 square feet of floor area" (City code requires only 3.8 parking spaces for each 1,000 square feet for floor area). Thus, "[t]he proposed onsite parking, which exceeds the required r2el 1 dng by 62 percent will be adequate to serve the Project." (Emphasis added.) Experience and common sense tell us that developers do not develop 62 percent more parking spaces than their projects need for no reason — especially in an excavated parking structure where the construction cost can easily exceed $20,000 per space! Here, the huge surplus of parking spaces removes a barrier to the future conversion of the 136,000 square feet of general office uses (per Code, parked at one space per 250 sq. ft.) and 96,414 square feet of research and development uses (per Code, parked at one space per 500 sq. ft.) to medical office uses (per Code, parked at one space per 200 sq. ft.). This foreseeable expansion of use can only be properly addressed in an EIR As the court noted in City of Antioch v. City Council (1986) 187 Cal.App.3d 1325,1337-1338: "[S]ection 15064, subdivision (e), of the [CEQA] Guidelines and Appendix G thereto, [] indicate that extension of a sewer deemed to have a significant effect on the environment. [fn. omitted] appellant also claims that construction of the utilities requires an EIR... . In sum, our decision in this case arises out of the realization that the sole reason to construct the road and sewer project is to provide a catalYsf% further develonment in the immediate area 35 City of Newport Beach Planning Commission. Hoag Healthcare Center Project November 14, 2006 Page 3 ... the fact that a particular development which now appears reasonably foreseeable may, in fact, never occur does not release it from the EIR process. [ ] Similarly, the fact that future development may take several forms does not excuse environmental review.... [ MhilePittsbum need notnredict the nrecisgLorin low ati amQu I of commercial and residential develotmtent resulting from oonstwetion ofthe roadwav and utilities, it cannot gmt4md none will occur: it sin4ly must assume the general form, location and amount of such development that now seems reasonable to anticipate, as the developer has doubtless already dope, and evaluate that development by means of the EIR ow —ess." (Emphasis added.) Similarly, the construction ofparking spaces that exceed Parking Code requirements by 62 percent provides a "catalyst" for the Project applicant's future conversion of the entire site to medical office uses. Moreover, the fact that this additional parking is a centerpiece of the Project indicates that the developer here — a hospital— has "doubtless already" anticipated such a conversion. The consultant's failure to base the Project's traffic analysis on this entirely foreseeable ultimate use ofthe site results in the MND significantly underestimating the Project's traffic and circulation impacts. C ; r 1..: 477577, The MND completely fails to provide any analysis of the Project's potential impacts on climate change. By doing so, it commits the same error that caused the California Attorney General to threaten legal action against the Orange County Transportation Authority for its 2006 Long -Range Transportation Plan Draft Program EIR. (See E hi 't 1.) Last summer, the Attorney and OCTA settled the dispute, with OCTA agreeing to include a discussion of global warming impacts in its EIR. (ibid.) The serious consequences of the global warming issue as it pertains to California were identified this year in the summary report from the California Climate Change Center titled Our Changing Climate: Assessing the Risks to Cagornia. Ex 'bit .) As noted in the Pall, 2006 edition of Environmental Assessor Qxhffbi pages 11 -12), the global warming issue is now front- and - center as a concern in the CEQA review process: "While the state develops its plans and programs, growing public interest in what can be done locally to address this global concern is also on the rise... . �A J� City of Newport Beach Planning Commission. Hoag Healthcare Center Project November 14, 2005 Page 4 . CEQA comment letters will draw attention to global warning attributes of proposed development projects... It would seem that the CEQA process is about to become a little more complex as interested patties grapple with the global warming contributions of land use development projects." The South Coast AirQuality Management Districthas set signifcancethresholds for specific air pollutants, including Volatile Organic Compounds, or "VOC." (Exhibit 4.) Similarly, the Califomia Air Resources Board uses the term Reactive Organic Gases, or "ROG" for these types ofpollutants. Qhibit 5.) Notably, excepted from ROG is (among other things) carbon dioxide — a contributor to global warming. Consequently, since the MND's air quality analysis addresses only ROG, CO, NOx, SO,,, and PM,a, it fails to address carbon dioxide as a potential Project impact 'and contributor to global warming, i., , I V J! !1 e In what can only be viewed as sleight -of -hand, the MND's discussion of NO, emissions arbitrarily bifurcates the daily construction- related NO, emissions into (1) impacts related to the parking structure, and (2) impacts related to soil hauling. By parsing the two and considering them separately, the MND (p. 11) concludes that daily NO,, emissions will not exceed the SCAQMD's significance threshold of 100 pounds per day. That the MND does this is surprising, given that it elsewhere acknowledges (A) that excavation and soil export will be necessary in constructing the parking structure and (B) that further excavation of an unknown degree will be necessary in order to remediate the site's known soil contamination. However, the MND's attempt to avoid triggering a threshold that would require the preparation ofen EIRdoesn'twash. When 86.4dailypoundso#NO „ emissionsfromparking structure construction are added to the 53 daily pounds of NO, emissions from soil hauling, the total is 139.4 pounds per day —which exceeds the SCAQMD's significance threshold by nearly 40 %. aek of Analysis of_he Site's Known Toxic I 2 3 According to page 5 of the February 1, 2006 Phase I Environmental Site Assessment ("Phase I') prepared for the site by his Environmental, historical aerial photographs show that Buildings A through D were developed on the site by 1968, and that Buildings A and B 4 were demolished and replacement building constructed in the same locations by 2002. Consequently, this means the existing Building C and D were constructed prior to the EPA banning asbestos- containing building materials ( "ACBMs ") in 1973 -197$. E 'bit .) 35 City of Newport Beach Planning Commission. Hoag Healthcare Center Project November 14, 2006 Page 5 Iris Environmental claims that its Phase I was conducted in accordance with American Society for Testing and Materials (ASTM) standards, However, "If you tell your consultant you want a Phase I (environmental site assessment] performed by the ASTM standards, they will not identify potentially asbestos- containing material." Mahihit 7, Part H, A., #17.) Perhaps this explains why the Iris Environmental's Phase I (p. 11) passes over the asbestos issue in such a cursory fashion. After acknowledging that a 1999 asbestos survey "identified asbestos- containing materials (ACMs) in all five former buildings," Iris discounts this by claiming— in a statement that contradicts its earlier dating ofbuilding construction —that "all of the current buildings at the Site were either constructed or renovated between 2001 and 2002, and that Iris "did not observe any evidence of asbestos at the Site during the Site visit." The-IdWacknowledges (and then dismisses as a non - issue) that sensitive, romptors'am located immediately adjacent to the Project site. In Chapter 4 of its CEQA Air. Quality Handbook, the SCAQMD notes that certain uses, such as the aerospace use previously associated with the Project site, carry with them the prospect of toxic emissions. (xbibit g.) y Moreover, the SCAQMD also instructs public agencies to carefully consider "land use compatibility issues, particularly in reference to sensitive receptors." (Ibid.) It is important to note that the EPA is on record as stating that it "work[s] under the assumption that there is no safe level of asbestos exposure. Asbestos is like a time bomb. Once you've been exposed, you don't know how your body will respond over time." Et xhibit 9.) Given the site's previous use, it is reasonably foreseeable that the proposed demolition of "Building 4" and excavation for the new construction will result in the release of asbestos and/or toxic emissions into the air in close proximity to sensitive receptors. Therefore, this issue must be addressed. In sum, the MND fails to perform its CEQA function of informing the public and decision- makers of the Project's true potential impacts. The Project requires the preparation of an EIR that considers a reasonable range of alternatives to the Project — including, perhaps, an alternative location for the proposed Project that might also be environmentally superior. Respectfully submitted, LEtsOLD McCLENDON & MANN, P.C. Plohn Cle ndon 30 4. Leibold McClendon & Mann (November 14, 2006) Response to Comment No. 1 The comment suggests that the conversion of the 97,000 square feet to medical office use is simply the first "part" of a plan to ultimately utilize the entire square footage on the property for medical office and, as such, this is piecemealing in violation of CEQA. The primary basis for this conclusion that this is part of a bigger plan is that the parking structure to be built will allow substantially more parking spaces than the City parking code requires for the property. The comment references the MND as supporting this when it states that the new parking structure is being proposed in order "to accommodate existing and future use of the site." As defined by CEQA, a project means the whole of the action whether it is one action or a series of related actions. See CEQA section 15378. However, related actions have to be included in the same CEQA document only when they are reasonably foreseeable, not when they are remote and speculative. See Laurel Heights Improvement Association v. Regents of the University of California (1988) 47 Cal. 3D 376. Further, the whole of the action is determined by the facts and circumstances of each case and not by making conclusions from cases that may not have the same facts as the one at hand. As detailed below, the facts and circumstances regarding the operation of the hospital support the City's conclusion that the conversion of the 97,000 square feet to medical uses is the project as a whole and not the catalyst for a future action. The commenter concludes that the conversion of the 97,000 square feet of existing floor area to medical uses is simply the first part of the application's ultimate plan to utilize the entire 329,414 square feet of medical use. He supports his conclusion based on a statement in the MND and speculation about common sense and experience. First, he cites page 32 of the MND Checklist Form, which indicates that a new parking structure is being proposed "to accommodate existing and future uses of the site ". He then speculates that providing more parking spaces than is required under City regulations means that a future expansion is in the works. The statement from the MND was misinterpreted by the commenter and his speculation is not appropriate as support for additional CEQA review. The word "future uses" as used in the environmental analysis presented in the initial study refers to the proposed project and not a subsequent phase to ultimately convert the entire 329,214 square feet for medical use. The terms "future use" or "future users" are used throughout the MND to refer to the "proposed project" as described in the Project Description (i.e., the proposed conversion of 97,000 square feet of existing floor area to medical office uses). The commenter further states that "experience and common sense tell us that developers do not develop 62 percent more parking spaces than their projects need for no reason," which is unreasonably speculative for the reasons that follow. First, it is important to understand that Hoag is not a developer; rather Hoag is a non - profit organization whose primary purpose is to provide higher quality service to its patients. Additionally, based on its "experience and common sense" in operating a medical facility, Hoag believes that the City's parking code requirements established for medical office uses and/or the existing number of parking spaces on site may not adequately meet its goals. This is evidenced by the fact that Hoag's main hospital campus currently provides more parking spaces than required. Hoag parking exceeds City regulations by 10 percent. Providing more parking spaces is required is not an uncommon practice. There are numerous service- oriented businesses that have found it in their best interests to exceed City parking requirements to provide better service to their constituents based on facts and circumstances related to the operation of their facilities. The commenter cites the City of Antioch case as supportive of his conclusions. In that case, the court held that the construction of a road and installation of a sewer line would provide a catalyst for further development. The analogy to the provision of additional parking spaces is misplaced. The construction of the road and sewer line was done to eventually serve a developer's property that abutted the street. In Hoag Health Center Responses to Public Comments December 2006 31 that case the city did not disagree that future development could actually be served by the street and sewer line. In this case, the proposed parking spaces are not being constructed to serve an, as yet, undefined "future project," but rather to provide better service to its patients, including the proposed project as described in the initial study. The reality and primary reason the applicant requested the conversion of 97,000 square feet of medical office use, was to remain consistent with the amended 1988 Land Use Element of the City's General Plan (previously in effect until November 8, 2006). The 1988 Land Use Element limited development of the site to a variable Floor Area Ratio (FAR) of 0.5 /0.75. The first number before the slash is the base FAR and the second number is the Maximum FAR. When variable designations for a site are identified, the permitted gross floor area of the site is prorated according to type of use. Chapter 20.63 (Floor Area Ratios and Building Bulk) of the Municipal Code establishes the procedures to implement a variable floor area ratio and categorizes land uses as Reduced, Base, or Maximum FAR uses. The Chapter also identifies weighting factors for each type of use and indicates that the base development allocation (0.5 FAR) shall not be exceeded. The R &D uses are included under the category of "Industry, Research and Development" and are classified as Maximum FAR uses. As such, they are applied a weighting factor of 0.50. Both general office and medical office uses are included under the category of "Office, Business and Professional" uses and are classed as a Base FAR use with an applied weighting factor of 1.0. Since the site is 596,393 square feet in area, the base 0.50 FAR resulted in a limitation of 298,196.5 square feet. The resulting total weighted FAR of the proposed project is 0.47, consistent with the Base 0.50 FAR limitation, and is calculated as follows: Use Use 1&2 Gross Floor Areas . ft. Weighting Factor . Weighted Area ' s . ft. Welghtel FAR R &D Maximum FAR 96,414 0.5 48,207 08 General Office Base FAR 136,000 1.0 136,000 .23 Medical Office Base FAR 97,000 1.0 97,000 .16 Totals 329,414 281,207 0.47 However, should the applicant have requested full build out of the site as medical office, the project would have resulted in 329,414 square feet of a Base FAR type use (or a total weighted FAR of 0.55), which is inconsistent with the Base 0.50 FAR limitation of the 1988 amended Land Use Element. To obtain project approval under the old Land Use Element, a use permit request to exceed the Base FAR limitation of the site would have been necessary and most likely denied due to the inability to make specific findings required for such a request. Alternatively, the applicant would have been required to pursue an amendment to the General Plan to increase the Base FAR limitation from 0.5 to 0.55 to accommodate the increased intensification. Under Charter Section 423 (Greenlight 1), a general plan amendment of this type would have required a city wide vote which is very costly, time consuming and, based on recent history, likely to be turned down. Given that option, Hoag decided to pursue the project as proposed, that would address its current needs and stood a reasonable chance of approval. As a result, any plans for future development of the property could not be proposed until such time as more was known about the future needs of the hospital, the outcomes of proposed initiatives [i.e. Measure V (General, Plan Update) and Measure Xj, and management decisions by the hospital. In the event the applicant submits such a comprehensive, long - range plan in the future for possible additional medical use, it would be subject to further environmental review by the City of Newport Beach, which may include the preparation of a project specific EIR, to address a variety of issues, including traffic and other issues identified in an initial study that would be undertaken as part of the development review process. It is also worth noting that the City has already prepared and certified a Program Environmental Impact Report (the "PEIR ") for the recently adopted general plan update (the "General Plan Update "). The PEIR analyzed all land use changes proposed under the General Plan Update. The General Plan Update changed the land use designation for the Hoag property at issue here to one that permits the entire site to Hoag Health Center Responses to Public Comments December 2006 3� be used for medical offices. Thus, even if the provision of extra parking spaces could be construed as a catalyst for future development, such future development has already been analyzed under the PEIR and determined to be consistent with City policy. Any such future use would be subject to the terms and mitigation measures contained in the PEIR and would likely require a project specific EIR that tiers off the PEIR. Finally, it is important to note that the applicant had originally proposed a total of 138,000 square feet of medical office uses (i.e., maximum conversion area permissible under the 1988 Land Use Element). However, the cursory air quality assessment conducted for the proposed floor area indicated that a significant, unavoidable adverse air quality impact would occur. As a result, the project was revised to include only 97,000 square feet of medical office uses in order to mitigate the potentially significant air quality impacts identified with the original project application. The reduction in medical office floor area effectively reduced the potentially significant air quality impacts to a less than significant level. However, should the applicant propose a project in the future that would result in the conversion of the remaining non - medical office floor area to medical office uses, as suggested in this comment, the project would be subject to additional environmental analysis in the form of an environmental impact report Given all of the above, the City believes that the MND prepared for the Hoag Health Center project adequately addressed the potential environmental impacts of the "entirety of the proposed action" and that the applicant has not engaged in any improper piecemealing or segmentation as suggested in this comment. Response to Comment No. 2 The comment suggests that the MND is deficient because it did not address the possible global warming or climate impacts of the project. The South Coast AQMD, as the Responsible Agency for air quality under CEQA in this region, establishes air quality significance thresholds for CEQA projects. Currently, there are thresholds for both construction activities (short -term emissions) and operational emissions (on- going). The thresholds established are for criteria pollutant emissions including: NOx, SOx, PM, CO and VOCs /ROGs. The terms volatile organic compounds (VOCs) and reactive organic gases (ROGs) are generally used interchangeably, As the comment correctly points out, there are currently no CEQA standards for greenhouse gas emissions. Greenhouse gases include, among others, carbon dioxide (CO2) and methane. SCAQMD specifically excludes CO2 and methane from the definition of VOCs (SCAQMD Rule 102 — Definition of Terms). When and if, the release of CO2 from development projects is determined to be a potential environmental impact by those with appropriate expertise and methods are developed to determine appropriate thresholds of significance than failure to address the issue may become a valid comment. However, given the current state of knowledge in this area and the lack of any scientifically based standards the commenter is asking the City to engage in speculation which is. prohibited under CEQA. Response to Comment No. 3 The comment suggests that the MND's discussion of NOx emissions incorrectly bifurcated the daily emissions into impacts related to construction of the parking structure and emissions related to soil hauling. The basis of this argument is the assumption that these two activities would go on simultaneously and thus, their air quality impacts should be added together. The problem with this comment is that the basic assumption is wrong. With respect to construction emissions, all pollutants, including NOx were analyzed for the worst -case scenario (i. e., total number of construction equipment devices on -site at any one time). The project description for this project calls for two distinct construction phases: dirt hauling which will occur after building demolition and then parking structure construction. Since these two phases will occur one following the other the impacts were analyzed separately as per CEQA requirements. SCAQMD's CEQA handbook requires applicants to, "... analyze the impact of emissions during each identified phase (emphasis added) of project development Hoag Health Center Responses to Public Comments necember 2006 3"t, and build out year. As part of the impact analysis, emissions need to be compared to the thresholds of significance." (SCAQMD CEQA Air Quality Handbook, 1993, page 7 -2). Response to Comment No. 4 The comment suggests that it is reasonably foreseeable that the proposed demolition of "Building 4" and excavation for the new construction will result in the release of asbestos and /or toxic emissions into the air in close proximity to sensitive receptors and that this issue was not properly addressed in the MND. This issue was clearly addressed in the MND. Page 21 of the Initial Study acknowledges the existence of asbestos - containing materials (ACM) and lead -based paint (LBP) in the existing structures. Further, the discussion of those materials in that analysis also identifies the requirement of the applicant to conduct ACM and LBP abatement in accordance with current regulatory requirements prescribed by the Orange County Health Care Agency (OCHCA) and /or South Coast Air Quality Management District (SCAQMD). As indicated in that discussion, the abatement of these materials would occur prior to demolition of the existing structure in question and would, therefore, avoid any significant emissions associated with either substance. The requirement to abate the AGM and LBP will be included as a condition of approval and will be included in the Mitigation Monitoring and Reporting Program (MMRP) to ensure that the abatement procedures have been completed prior to issuance of the demolition permit. As a result, potential impacts associated with project implementation are determined to be less than significant because the abatement of the ACM and LBP prior to demolition will effectively eliminate any significant exposure to nearby sensitive receptors. Hoag Health Center Responses to Pubfic Comments December 2006 qb .a Linda S. Adams Secretary for Environmental Protection Department of Toxic Substances Control November 13, 2006 Mr. Jaime Murillo Maureen F. Gorsen, Director 5796 Corporate Avenue Cypress, California 90630 Associate Planner Planning Department City of Newport Beach 3300 Newport Avenue Newport Beach, California 92658 RECEIVED BY Arnold Schwarzenegger PLANNING DEPARTMENT Governor NOV 16 2006 CITY OF NEWPORT BEACH NOTICE OF INTENT TO ADOPT A MITIGATED NEGATIVE DECLARATION FOR THE HOAG HEALTH CENTER USE PERMIT (SCH# 2006101105) Dear Mr. Murillo: The Department of Toxic Substances Control (DTSC) has received your submitted Notice of Intent to adopt a Mitigated Negative Declaration (ND) for the above- mentioned project. Your document states the Project Description as: "Newport Beach Healthcare Center, LLC is requesting the approval of an amendment to the existing use permit to allow: 1) the conversion of 97,000 square feet of research and development (R &D) /general office use to medical office use within the M-1 -A zoning district; 2) the completion of a remodel of the Project site that includes the demolition of one of the existing buildings; 3) the construction of a second parking structure; and 4) the Project site to exceed the maximum building bulk limitation for the site. Project implementation will result in a reduction in the overall building area with the demolition of one of the existing buildings located at 530 Superior Avenue. Demolition of this 86,079 square foot building would leave a total gross floor area of 329,414 square feet on the Project site, including the proposed 97,000 square feet of medical office use. The remaining floor area would be divided into general office totaling 146,000 square feet and research and development totaling 96,414 square feet. The Project will comply with the maximum permitted floor area ratio applicable to the General industrial land use designation and the M-1 -A zoning district." Based on the review of the submitted document DTSC has comments as follows: 1) The ND should identify the current or historic uses at the project site that may have resulted in a release of hazardous wastes /substances. 9 Printed on Recycled Paper 41 Mr. Jaime Murillo November 13, 2006 Page 2 2) The ND should identify the known or potentially contaminated sites within the proposed Project area. For all identified sites, the ND should evaluate whether conditions at the site may pose a threat to human health or the environment. Following are the databases of some of the regulatory agencies: • National Priorities List (NPL): A list maintained by the United States Environmental Protection Agency (U.S.EPA). • Envirostor (formerly CalSites): A Database primarily used by the California Department of Toxic Substances Control, accessible through DTSC's website (see below). • Resource Conservation and Recovery Information System (RCRIS): A database of RCRA facilities that is maintained by U.S. EPA. I 2 • Comprehensive Environmental Response Compensation and Liability Information System (CERCLIS): A database of CERCLA sites that is maintained by U.S.EPA. • Solid Waste Information System (SWIS): A database provided by the California Integrated Waste Management Board which consists of both open as well as closed and inactive solid waste disposal facilities and transfer stations. • Leaking Underground Storage Tanks (LUST) / Spills, Leaks, Investigations and Cleanups (SLIC): A list that is maintained by Regional Water Quality Control Boards. • Local Counties and Cities maintain lists for hazardous substances cleanup sites and leaking underground storage tanks. . • The United States Army Corps of Engineers, 911 Wilshire Boulevard, Los Angeles, California, 90017, (213) 452 -3908, maintains a list of Formerly Used Defense.Sites (FUDS). 3) The ND should identify the mechanism to initiate any required investigation and /or remediation for any site that may be contaminated, and the government agency to provide appropriate regulatory oversight. DTSC could require an 3 oversight agreement in order to review such documents. Please see comment No. 17 below for more information. Mr. Jaime Murillo November 13, 2006 Page 3 4) Your document states: "A subsequent Phase Environmental Site Assessment (ESA) for the Newport Technology Center was conducted by Iris Environmental (February 1, 2006). Based on the findings presented in that ESA, soil and groundwater contamination at the site has resulted from operations conducted by 4 former site occupants. The RWQCB continues to provide active oversight for site investigation and remediation activities. As indicated above and confirmed in the most recent ESA, the primary contaminants at the site are VOCs." DTSC understands that the RWQCB will be overseeing remediation of the groundwater. Please ensure that any contaminated soils are also remediated to appropriate health -based standards. 5) Proper investigation, sampling and remedial actions overseen by a regulatory agency, if necessary, should be conducted at the site prior to the new development or any construction. All closure, certification or remediation approval reports by these agencies should be included in the ND. 6) If any property adjacent to the project site is contaminated with hazardous chemicals, and if the proposed project is within 2,000 feet from a contaminated site, then the proposed development may fall within the "Border Zone of a b Contaminated Property." Appropriate precautions should be taken prior to construction if the proposed project is within a Border Zone Property. 7) Your document states that: "Asbestos- containing materials (ACM) and lead - based paint (LBP) will be removed prior to demolition of the existing office building." Since buildings or other structures, asphalt or concrete -paved surface areas are being planned to be demolished, an investigation should be conducted for the presence of other related hazardous chemicals, lead -based paints or products, mercury, and asbestos containing materials (AGMs). If other hazardous chemicals, lead -based paints or products, mercury or ACMs are identified, proper precautions should be taken during demolition activities. Additionally, any contaminants should be remediated in compliance with California environmental regulations and policies. 8) The project construction may require soil excavation and soil filling in certain areas. Appropriate sampling is required prior to disposal of the excavated soil. If the soil is contaminated, properly dispose of it rather than placing it in another location. Land Disposal Restrictions may be applicable to these soils. Also, if the project proposes to import soil to backfill the areas excavated, proper sampling should be conducted to make sure that the imported soil is free of contamination. 4' Mr. Jaime Murillo November 13, 2006 Page 4 9) Your document states: "The assessment and management of indoor air quality is currently under the oversite of the RWQCB." Human health and the environment of sensitive receptors should also be protected during the construction and demolition activities. 10) If it is determined that hazardous wastes are, or will be, generated by the proposed operations, the wastes must be managed in accordance with the 10 California Hazardous Waste Control Law (California Health and Safety Code, Division 20, chapter 6.5) and the Hazardous Waste Control Regulations (California Code of Regulations, Title 22, Division 4.5). 11) If it is determined that hazardous wastes are or will be generated and the wastes are (a) stored in tanks or containers for more than ninety days, (b) treated onsite, or (c) disposed of onsite, then a permit from DTSC may be required. If so, the facility should contact DTSC at (714) 484 -5423 to initiate pre application discussions and determine the permitting process applicable to the facility. 12) If it is determined that hazardous wastes will be generated, the facility should t 2 obtain a United States Environmental Protection Agency Identification Number by contacting (800) 618 -6942. 13) Certain hazardous waste treatment processes may require authorization from the local Certified Unified Program Agency (CUPA). Information about the 3 requirement for authorization can be obtained by contacting your local CUPA. 14) If the project plans include discharging wastewater to a storm drain, you may be required to obtain a NPDES permit from the overseeing Regional Water Quality y Control Board (RWQCB). 15) If during construction /demolition of the project, the soil and /or groundwater it contamination is suspected, construction /demolition in the area should cease and appropriate health and safety procedures should be implemented. 16) DTSC can provide guidance for cleanup oversight through an Environmental Oversight Agreement (EOA) for government agencies, or a Voluntary Cleanup Agreement (VCA) for private parties. For additional information on the EOA 16 please see www.dtsc. ca.gov /SiteCleanur)/Brownfields, or contact Maryam Tasnif- Abbasi, DTSC's Voluntary Cleanup Coordinator, at (714) 484- 5489.or the VCP, 41 Mr. Jaime Murillo November 13, 2006 Page 5 If you have any questions regarding this letter, please contact Ms.Teresa Hom, Project Manager, at (714) 484 -5477 or email at thom @dtsc.ca.gov. Sincerely, FAINAV Greg Holmes Unit Chief Southern California Cleanup Operations Branch - Cypress Office cc: Govemor's Office of Planning and Research State Clearinghouse P.O. Box 3044 Sacramento, California 95812 -3044 Mr. Guenther W. Moskat, Chief Planning and Environmental Analysis Section CEQA Tracking Center Department of Toxic Substances Control P.O. Box 806 Sacramento, California 95812 -0806 CEQA# 1575 �( 5 5. Department of Toxic Substances Control (November 13, 2006) Response to Comment No. 1 As indicated on page 23 of the Initial Study, a Phase I Environmental Site Assessment (ESA) for the Newport Technology Center (i.e., current use) was conducted by Iris Environmental. The results of this ESA are summarized in the initial study and the document is included in the source list on page 55 of the Initial Study. The ESA prepared by Iris Environmental, dated February 1, 2006, was prepared in conjunction with the acquisition of the subject property (Phase 1) and provides a listing of historical uses of the property and discussions of past chemical releases at the site. The Phase I ESA is on file with the Newport Beach Planning Department. Response to Comment No. 2 As part of the Phase I ESA process, surrounding sites and their potential to degrade environmental conditions on the subject property were evaluated and discussed in the Phase I report, which was made available to the City of Newport Beach and to the environmental regulatory agency overseeing the environmental remedial efforts underway at the site. The Santa Ana Regional Water Quality Control Board (SARWQCB) is overseeing all environmental investigation and remediation efforts at the site. Raytheon Company is the responsible party conducting site investigation and remediation activities, which are being overseen by the SARWQCB. Response to Comment No. 3 At the present time, the only subsequent investigation that must be conducted is that prescribed by the City of Newport Beach. As indicated on page 21 of the initial study, the applicant will be required to undertake a ACM /LBP survey to confirm the presence or absence of those materials in the structure proposed for demolition. The City has included the following condition, which will be included in the Mitigation Monitoring and Report Program (MMRP) for implementation. SC -10 Prior to the issuance of the demolition permit, the applicant shall undertake and complete an asbestos survey and lead -based paint survey to determine the presence of asbestos and lead -based paint. If it is determined that ACM and/or LBP exists in the structures to be demolished, abatement of the ACM and LBP shall occur prior to demolition of the existing structure. All work undertaken by the contractor shall comply with SCAQMD Rule 1402 related to the disturbance of ACM, as well as the storage and disposal of ACM. The contractor's responsibilities shall include proper notification, removal techniques for ACM, clean -up procedures, and waste storage and disposal. Mitigation Measures 6, 7, and 8 on page 23 of the initial study identify the requirements imposed on the application to ensure that the existing site contamination will be addressed in accordance with applicable regulatory agency requirements. Although this comment makes reference to "Comment No. 17," no such comment is included in the letter from DTSC. Response to Comment No. 4 As suggested in this comment by DTSC, all contamination soils and other hazardous conditions (e.g., ACM and LBP, etc.) will be abated and/or mitigated in accordance with all required health -based standards prescribed by the responsible regulatory agency. Hoag Health Center Responses to Public Comments December 2006 ql� Response to Comment No, 5 Refer to Response to Comment No. 3. The remediation program is actively underway at the site and the SARWQCB continues to provide ongoing oversight for the entire investigation and remediation program currently being implemented. Response to Comment No. B The subject property is not located within 2,000 feet of a "Border Zone of a contaminated Property." Further, the environmental assessments conducted for the subject property have identified the nature and extent of contamination on the site and in the project environs. That information has been summarized in the initial study and appropriate mitigation measures have been prescribed to ensure that future development and /or sensitive receptors are not exposed to hazardous conditions. Response to Comment No. 7 Refer to Response to Comment No. 3, which reflects the "standard condition" imposed on the project applicant. As indicated in the City's condition, the applicant will be required to abate any ACM/LBP that may be found in the existing structure prior to demolition of that structure. In addition, any other hazardous materials that may be encountered during that survey will also be identified and appropriate precautions, including remediation of the hazardous condition(s) consistent with current regulatory requirements will be taken prior to or during demolition activities as determined necessary by the responsible regulatory agency. Response to Comment No. 8 This comment is acknowledged. Any soil that is excavated and either removed from the site or used as fill will be tested to ensure that it is not contaminated (refer to MM -7 on page 23 of the initial study). If found to be contaminated, the soil will be removed and disposed at a landfill certified to accept the contaminated soil. Although it is not anticipated that additional soil would be imported for use on the site, such imported materials, if required, would also be tested to ensure that they are free of contamination, as suggested in this comment. Response to Comment No. 9 This comment is acknowledged. MM-6 on page 23 of the initial study outlines the program for vapor intrusion into the proposed buildings that will accommodate the proposed medical office uses. As previously indicated, all activities associated with project implementation, including demolition, site preparation, construction and operation, will ensure that the health and safety of the nearby sensitive receptors will be protected. Several mitigation measures and standard conditions have been prescribed and will be overseen by the Orange County Health Care Agency, Regional Water Quality Control Board and /or the Department of Toxic Substances Control to ensure such protection is achieved. Response to Comment No. 10 This comment is acknowledged. A condition will be included if the project is approved that requires the applicant to comply with the applicable section of the California Hazardous Waste Control Law, as recommended in this comment. Response to Comment No. 11 This comment is acknowledged. If a permit from DTSC is required, the applicant will comply with the application requirements outlined by the agency. Hoag Health Center Responses to Public Comments December 2006 11 Response to Comment No. 12 This comment is acknowledged. If hazardous wastes will be generated by the proposed project, the applicant will comply with the requirement to obtain a permit number from the U.S. Environmental Protection Agency. Response to Comment No. 13 This comment is acknowledged. The applicant will contact the Certified Unified Program Agency (CUPA) if necessary to ensure compliance with current applicable regulatory requirements. Response to Comment No. 14 As indicated on page 20, the proposed project will be subject to a NPDES permit from the Regional Water Quality Control Board. As required by the City and the NPDES permit, the applicant will be required to prepare a Stormwater Pollution Prevention Plant (SWPPP) that includes appropriate Best Management Practices (BMPs). In addition, the applicant will also prepare a Water Quality Management Plan (WQMP), which also prescribes BMPs to ensure that water quality is not adversely affected by stormwater discharges resulting from project implementation. Response to Comment No. 15 As recommended in this comment, the following condition will be included to ensure that potential health hazards are adequate addressed: "If contaminated soils are encountered during demolition, site preparation, and/or construction activities associated with project implementation, such activities shall cease and appropriate health and safety procedures shall be prescribed and implemented. No further work shall be undertaken until such time as it can be shown to the responsible regulatory agency that the public would not be exposed to a potential health hazard." Response to Comment No. 16 This comment is acknowledged. The applicant will contact DTSC, as recommended in this comment, if it is determined that the applicant requires guidance for cleanup activities conducted on the subject property. Hoag Health Center Responses to Public Comments December 2006 q Rlohe l Smith 450 earero way Newport Bewh, CA 9288:1 November 13,2W6 City of Newport Beach Attention: Planning Commission Regarding: Hoag Healthcare Center PA2006 -113 Punic Hearing 3300 Newport Boulevard Newport Beach, CA 92658 -8915 Dear Planning Commission of the City of Newport Beady. RECEIVED BY PLANNING DEPARTMENT NOV 16 2006 CITY OF NEWPORT BEACH FILE COPY Beyond the altruism of expanding the healthcare services in the vicinity of Hoag Hospital, everybody knows why Newport Beach Center, LLC at 500 Superior Avenue has applied to convert R&Meneral Use zoned property to Medical Office use and has also applied to expand the bulk building limitation for the site. Newport Beach LLC will realize significantly more revenue by approval of their proposal. Without the City of Newport Beach acting on behalf of residents and the environment to ask Newport Beach Center, LLC to fulfil certain requirements in exchange, the increased revenue of the property owner will be at the cost of the surrounding residents and at the cost of the surrounding environment. As a dose neighbor residing in the structure next to the project site, at the 450 address along Superior Avenue, I observe that Newport Beach Carter, LLC is not currently a good neighbor of Newport Beach residents, and therefore I strongly urge the City to be firm- handed in dealing with the bad neighbor requesting the community s goodwill towards its efforts to earn further financial gain. Increasintg the capacity and approving a change of use of the 500 Superior Avenue commercial property will give a bad neighbor license to further deteriorate the quality of fife in the residential Community where the Property resides. This contradicts the goals of the Update to the City of Newport Beach General Plan which was just approved. Namely, the Update to the General Plan recognizes the importance of Newport Beach's residential neighborhoods and seeks to enhance these residential neighborhoods. If the City of Newport Beach approves re- zoning the site for change of use as well as exceeding the Capacity of the site, the City should expect the site to give some things in return in order to better the surrounding neighborhoods. First, I recommend a small park be donated to the city from the site's land in exchange for approving the site's requests, preferably for a skate park, as unfortunately teenagers on skateboards are not welcome at this site or other nearby business complexes and there is no park in the neighborhood for such use. There are a lot of teenagers who like to ride skateboards who I think the city should value more highly as neighbors in this area than Newport Beach Carrier, LLC at 500 SuperiorAvenue. Youth are, after ag, our future. Second, require the site to give up enough land along Dana Road to add a right turn lane going onto Superior. The additional traffic in the area wig warrant this road improvement A traffic signal at Dana Road and Superior Avenue will also probably be necessary. Third, require the site to provide pubic parking hours for its parking structure or structures, during evenings and on holidays. There is nothing worse than living next door to a parking structure to which one has no access, especially on Fourth of July when one has to park one mile away from one's home in order to find a parking space. The fact is, people use parting places along Dana Road and along Superior who should be using the current parking structure on the site, people who prefer these spots rather than walking to the Parting structure Lure on site or at Hoag Hospital. Fourth, eliminate the use of the Newport Beach Carter, LLC as an off-site parking area for Hoag Hospital staff. The parting shuttles constantly drdirg the block, corning from Hospital Road onto Superior and then onto the site, are a constant nuisance and impact on the traffic. They worsen traffic 0 0 Page 2 November 13, 2008 flow of cars turning left onto Superior Avenue from Dana Road. I believe the site plans to continue its use as ofishie parking for Hoag Hospital, and I do not think another paridrig structure would be needed If the site were not used as off -site parking for hospital employees. Fifth, perhaps a site of this scope needs an aitemafive entry and exit point rather than from Superior Avenue. If the site wishes to use 500 Superior Avenue as off -site parking with shuttle service to Hoag Hospital, perhaps parking shuttles should not route along a residential neighborhood, alai Hospital Road and onto Superior Avenue. Maybe the site needs to have an entry and exit directly from Newport Boulevard. Another concern of the site increasing traffic on Superior Avenue is additional traffic at Newport Boulevard /Superior /17" Street. If the site expands as it wishes, it will further burden the intersection at Newport Boulevard and 17"' Street, already recognized as the worst in the City for traffic congestion. Please do not squander the resources of the City of Newport Beach so that Newport Beach Center LLC can increase Its revenue. Please consider asking for the above concessions by the 500 Superior Avenue site if it expects the City to make the concessions of approving increasing the site capadty as well as approving the change of use for the site. — Sincerely, Richard Smith Resident of Newport Beach 50 6. Richard Smith (November 13, 2006) Response to Comment No. 1 This comment expresses general opposition to the proposed project. The comment does not raise any issues about the project's environmental impacts or the adequacy of the initial study prepared pursuant to CEQA. This comment is acknowledged and will be forwarded to the Newport Beach Planning Commission for consideration prior to taking action on the proposed project. Hoag Health Center Responses to Public Comments December 2006 5( SOUTHERN CALIFORNIA ASSOCIATION of GOVERNMENTS Main Office 818 West Seventh Street 12th Floor Los Angeles, California 90017 -3435 t (213) 2361800 1(213)2.36 -1825 www.scag.ca.gov OHleers: Preside m: Vromw B. Broke, Lm Angeles (Maly • First Are Resident: Gary Mitt, San Bemdrdhl0 County- Second Vice Pmident Richard and, lake ruess , loo t<Nak past Resident: Toni young, Pon Hueneme Imperial County: Victor Carrillo, Imperial County• don Edney, Bl Centre Lus hngeks County: Warne B. Burke, Los Angeles County • 2ev hro ly.ky, Las Angeles County -Am Aldingec Manhattan Beach • Harty Baldwjn, San Gabbed. Pool BowNr, Cermw, - TOM Compbek, Burbank • Tony Cardenas, Los Angeles - Stan Carroll, is Habra Heights Margaret CMrk, Rosemead • Gene Dmdehs Paramount Afire Dispema, Pabndale •Judy Dunlap, Inglewood• Rae 6abeyrch, Long Beach David Gain, Downey• Eric Uncut LOS Angeles Wyndy Geuel, Los Angeles • Frank Gssmle, Cvdakry Janke HaYm,lm audit- hadaeHZN, Company • Keith W. Hanks, Musa • Jose Hutac Los Angeles - Gran LaBUAge,, Las Angeles• Puma Leon, Pomona • piuiPowaks, lonance • your PCwnoc Santa Monica • Alex Padilla, Los Angeles• Removal Parks, LOS Angeles ban Peny, Las Angeles • Ed Reyes, Los Angeles • Sm Rusendahl, Los Angeles ' Goig Smith, Los Angeles - Tom Sykes, Walnut • Paul Talbot A burns • Mike Ten, South Pasadena • Tama Reyes traitor, Long Beach . Antonio y1waigosa, Los Angeles - Dennis Washburn, GnIals u •Jack Webs. Los Angeles • Herd 1. Wesson, D. Los Angeles - Dennis Zinc, Los MPH, Orange County; Chile Rome, Orange courty- (hrisline Barre; La Palma - John Beauman, Bras • Lou Bone, Tustin • Art Brown, Boom Pan Richard Chavez, Anaheon • Debbie Cook, Huntington Beach Leslie.Daigle, Newport Beach • Rithard Damn, Lake Erml -Paul Glatt, Laguna Niguel- Marilynn Bra. Los AMmims Riverside County. kh Stone, Riverside County • Thomas Buckley, Lake Elumre - Bonnie LlicAmges, Mauro Valley • Ran Lovesldge. Riverside - Greg Penis Cathedral City • Ran Roberts, lemecula San Bernardino County: Gary Ovin,, San Bernardino County • Lawrence Dale, Barstow Paul Eaton, Mann • Ere, Ann Garcia, Grand Tenaee • Tm laspn, Town of Apple VA" - Lany Mc(alm, Highland- Deborah Robertson, Rand Alto Wapnm, Ontario Ventura(aunn:luoy MIkNS Ventura County Glen Becena, Simi yalleY • Curl Morelmme, San Buenaventura • Goal Young, Pon Hueneme Orange County Tramporratlan Authority: LOU(on o, tpuncy m Orange Renewed. Camty Transportation (omminioo: Robin Law, Hemet Ventura County Tranryortation (oamnkMOw: Ranh Muddies Moor park a.wm November 14, 2006 Mr. Jaime Murillo RECEIVED BY PANNING DEPARTMENT NOV 16 2006 Associate Planner CITY OF NEWPORT BEACH City of Newport Beach P. O. Box 1768 Newport Beach, CA 92658 RE: SCAG Clearinghouse No. 120060703 Hoag Health Center Dear Mr. Murillo: Thank you for submitting the Hoag Health Center 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, 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 will be published in SCAG's October 131, 2006 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 Laverne Jones at (213) 236 -1857. Thank you. Sincerely, SY IA PATSAOURAS Manager, Environmental Division Doc #128638 5,?- Southern California Association of Governments (November 14, 2006) Response to Comment No. 1 This comment, which indicates that SCAG has reviewed the proposed project and determined that it is not regionally significant, is acknowledged. No response is necessary; however, as requested, the City of Newport Beach will notify SCAG if there is a change in the scope of the project. Hoag Health Center Responses to Public Comments December 2006 53