HomeMy WebLinkAbout2006-06-05_EQAC_Agenda� J
CITY OF NEWPORT BEACH
ENVIRONMENTAL QUALITY AFFAIRS
COMMITTEE
DATE /TIME: Monday, June 5, 2006 - 7:00 p.m.
LOCATION: Police Department Auditorium
870 Santa Barbara Drive
Roll Call
1. Minutes of May 22, 2006 (draft minutes attached)
2. Discussion of subcommittee comments on Draft Environmental Impact Report on General
Plan 2006 Update (attachment)
3. Public Comments
4. Future Agenda Items
5. Adjournment
NEXT MEETING DATE: July 17, 2006
'Attachments can be found on the City's website hftp:/Iwww.city.newDort-beach.ca.us. Once there, click on City
Council then scroll to and click on Agendas and Minutes then scroll to and click on Environmental Quality
Affairs. If attachment is not on the web page, it is also available in the City of Newport Beach Planning Department,
3300 Newport Boulevard, Building C, 2 n Floor.
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CITY OF NEWPORT BEACH
ENVIRONMENTAL QUALITY AFFAIRS COMMITTEE
DRAFT MINUTES 05 -22 -06
Draft minutes of the Environmental Quality Affairs Committee held at the City of Newport
Beach Police Department Auditorium, 870 Santa Barbara Drive, on Monday, May 22, 2006.
Members Present:
X
Keith Curry, Council Member
Sandra Haskell - excused
X
Richard Nichols, Council Member
X
Barry Allen
X
Cris Trapp, Chairperson
Kristine Adams
X
Dolores Ottin , Vice Chair
Marianne Zip pi
X
Lloyd Ikerd
Tom Hyans — Sick Leave
X
Matt Wiley
X
Jack Wu
X
I Christopher Welsh
X
Jennifer Winn
X
Mike Browning
X
Ray Halowski
X
Brent Cooper
X
Barbara Thibault
X
Laura Dietz
X
Merritt Van Sant
X
Kenneth Drellishak
Laura Curran
X
Walter Lazicki
Staff Representatives: Guests Present:
Chairperson Cris Trapp called the meeting to order at approximately 7:05 p.m.
1. Minutes of March 20,2006
Motion: Kenneth Drellishak moved to approve the minutes as written.
Ray Halowski seconded the motion.
Motion passed unanimously
2. Discussion of subcommittee comments on Draft Environmental Impact Report on
General Plan 2006 Update—
The Committee discussed draft comments and changes to the comments. This item
was continued to the June 5t" meeting.
3. Report from EQAC Representative to GPUC —
No report.
4. Report from EQAC Members on GPAC —
No report.
5. Economic Development Committee (EDC) Representative's Report —
Cris Trapp reported on a report given to the EDC from OC Cruiser.
6. Report from Staff on Current Projects —
Sharon Wood advised that the South Coast Shipyard DEIR and Our Lady Queen of
Angels Mitigated Negative Declaration will be out for public review soon. Cris Trapp
asked for volunteers for the South Coast Shipyard subcommittee. The following
volunteered for the subcommittee:
• Christopher Welsh
• Dolores Otting
• Barry Allen
• Kenneth Drellishak
• Brent Cooper
• Jack Wu
7. Public Comments —
None
8. Future Agenda Items —
None discussed
9. Adjournment —
The meeting was adjourned at 10:12 p.m.
MEMORANDUM DRAFT
To: Gregg Ramirez, Senior Planner, City of Newport Beach
From: Environmental Quality Affairs Citizens Advisory Committee
City of Newport Beach
Subject: Draft Environmental Impact Report for the City of Newport Beach
General Plan Update (the "Project ")
Date: #I&y-22June 5, 2006
Thank you for the opportunity to comment on the Draft Environmental Impact
Report ( "DEIR ") for the captioned Project. We offer the following comments in the
hopes of improving the final Environmental Impact Report and this important Project for
the City of Newport Beach ( "City ").
A. Project Description:
The Statement of Objectives defines an objective to "provide effective means to
ensure compliance with Section 423 of the Charter" The Project descrintion in the final
EIR should define Section 42' ) of the Charter so that reviewers can determine whether
that objective is being met. (Page 3 -9)
The Undated General Plan Land Use Changes describes the existing land use
categories and summarizes proposed land uses under the General Plan Undate on Table
3 -3. These changes were reportedly made in response to the Objectives referred to above
which resulted from the extensive public outreach process and in accordance with CEOA
requirements. However, another guiding document for General Planning has been
published by California Air Resources Board and should be consulted as part of this FIR
"Air Quality and Land Use Handbook: A Community Health Perspective " Published in
2005, contains valuable guidelines for making land use decisions which minimize the
effects of air pollution on the affected community. (Page 3 =10)
Table 3 -3 shows a planned increase of 1.188 dwelling units and 430 hotel rooms
on the Balboa Peninsula without any significant traffic impacts (Also see Table 3 -4)
This seems wrong based on the experience of those who travel regularly on the peninsula
The final EIR should clearly discuss whether a formal traffic stud), prepared for this area
reflecting the residential /hotel room growth as well as the theaters nautical museum and
other growth at Balboa Village. The final EIR should fully discuss the findings of such a
study. (Page 3 -13
EQAC - DRAFT
City of Newport Beach
Page 2
May 22, 2006
B. Environmental Checklist and Discussion:
I. Aesthetics and Visual Ouality
Section 4.1 analyzes the impacts of the proposed General Plan Update on the
aesthetic character of the City. The first threshold question to be addressed is whether the
proposed Project would have a substantial adverse effect on a scenic vista. As the DEIR
points out, there are numerous scenic vistas in the City due to the topography within the
City and the natural features in and around the City, including the ocean and the bay, as
well as nearby and distant mountain ranges.
The DEIR goes on to say that the proposed General Plan Update would protect
the scenic vistas in the City; however, it states that there are no "officially designated
scenic vistas in the City." The final EIR should define "official designation" with respect
to scenic vistas in the City and discuss what, if anything, an official designation would
add to the protection of the scenic vistas beyond the policies included in the proposed
General Plan Update. The final nm „>,e la ,,,..e add_,.,.. the City's reasons for no
adopting sueh an offleial designation.
The second threshold question that is addressed in the Aesthetics and Visual
Quality Section is whether the proposed Project would substantially damage scenic
resources, including trees, rock outcroppings and historic buildings within a State scenic
highway. The DEIR states that "there are currently no officially designated scenic
highways within the City of Newport Beach," and the reason for that is because the City
has not applied to Caltrans for scenic highway approval.
The final EIR should explain the implications of a highway being designated as a
scenic corridor, including the effects such a designation would have on future
development within the City of Newport Beach.
Another threshold question is whether the proposed Project would create a new
source of substantial light and glare that would adversely affect day or nighttime views.
The DEIR states that if Banning Ranch is not acquired for open space and development
occurs in that area, there will be significant and unavoidable light and glare impacts due
to nighttime lighting. The final EIR should discuss why, even with sensitive siting of
uses and structures, these impacts would not or could not be mitigated to a level less than
significant.
As a point of correction, Figure 4.1 -3 should be revised to include MacArthur
Boulevard from San Joaquin Hills Road to seuth of San Miguel as ., Coastal View
a
R$adCoast Highway.
EQAC
City of Newport Beach
Page 3
May 22, 2006
II. Air Quality
DRAFT
Table 4.2 -1 (Page 4.2 -6) provides a summary of ambient air quality as measured
at the South Coast Air Quality Management District ( "SCAQMD ") monitoring station in
Costa Mesa from 2001 -2003 and lists the relevant Air Quality Standards for Ozone, CO,
NO2 and S02. _However, the text describing Table 4.2 -1 notes that "the largest contributor
to inhalation cancer risk is small diameter particulate matter produced by diesel engines."
The DEIR also describes atmospheric lead (Pb) particulates as a health concern.
Both of these health hazards (i.e. lead -(P-b) and respirable particulate matter
(PM2.5 /PM10)) should be included in SCAQMD monitoring station results in the final
EIR. Since these are airborne contaminants, which are sure to increase in our elevated
traffic and construction intensive areas (due to heavy use of diesel equipment), the final
EIR should explain how the City can be assured that we are properly accounting for the
health hazards associated with them.
Volume II of the DEIR contains Appendix B, related to Air Quality, which
requires attention. Near the end of Appendix A. there is a letter from Steve Smith, Ph.D.
of SCAQMD. Among other comments, Dr. Smith recommends that when signi fic "*
traffic inereases are planned, lead ageneies (the City of Newport Beach in this ease)
should perform a loealized signifieanee analysis using localized signifieanee 4gesholds
(LST's) developed by SCAQMD. It is not elear whe4her this reeemmendation has bee
followed in this DEIR. The fi" PIR should eleafly state that a leealived signifleaflee
a
Dr. S�ish a1s ,. &eeg .". °.,a° that "projects generating or attracting vehicular trips,
especially heavy -duty diesel vehicles, perform a mobile source health risk assessment" in
accordance with California Environmental Quality Act ( "CEQA ") Guidelines published
on the CEQA website. The final EIR should include a mobile source health risk
assessment and provide the results of the analysis.
Appendix B contains Air Quality Data based on computer analysis from a
modeling program titled " URBEMIS 2002 for Windows 8.7.0." Although Pb and PM2.5
have been previously noted as potential health hazards, they are not included in the
modeling. The final EIR should identify how the proposed Project would deal with these
hazards, and identify other possible analysis tools that could be utilized.
In this same Appendix B, the URBEMIS modeling results are potentially
confusing and contradictory. Compare the results from Appendix B, sheet #1 (marked
page: 1, 3/8/2006, 2:36 pm) and sheet #5 (also marked page: 1, 3/2/2006, 2:37 pm). The
titles on these pages are identical regarding on -road motor vehicle emissions summarized
in pounds /day for summer. The final EIR should explain the difference, for example, in
ROG from 2937.541bs /day to 359.52 lbs /day, and state how the City can assure that the
correct numbers are used in subsequent analyses. Also, ROG is not defined. Is this
1
EQAC - DRAFT
City of Newport Beach
Page 4
May 22, 2006
related to the volatile organic compounds ( "VOC -s ") defined on page 4.2 -2 of the DEIR?
If so, the final EIR should fully explain. If not, the analysis of VOC's should be included
in the final EIR.?
Under Construction Emission Thresholds (Page 4.2 -10), the DEIR identifies a
threshold of 150 lbs /day of PMIo, but says nothing about PM2.5 (another potentially
dangerous respirable particulate pollutant). The final EIR should iaaenti y- ifclarifv
whether this is a potential problem in pollution enforcement and identify the thresholds
for this component.
■�+rn ees!rass••r .
e
■
Quality �
hernative full ipfrastniettife ... "shetild be made stronger by imposing
—1-i—ments. 11, this is not done now by the City loek4ng fafward fef the next 20 years,
hOW else Will it get d0fle? Table 2-2, identifies five Air Quality Impacts and states
• qu.4 '• _
However. discussion of Impact 4.2 -1 on pa<ye 4.2 -12 states that this Droiect would
"obstruct implementation of the Air Quality Management Plan because the Updated
General Plan leads to a total Newport Beach population of 103,753 persons which is
approximately 10% over the SCAG - projected population for this area.” Since the City
has the option to plan for any population level it seems reasonable to plan for the SCAG-
projected population in an effort to comply with thresholds implicit in Impact 4.2-1.
•
■ r
Wll
• „■ ..
■�+rn ees!rass••r .
e
■
Quality �
hernative full ipfrastniettife ... "shetild be made stronger by imposing
—1-i—ments. 11, this is not done now by the City loek4ng fafward fef the next 20 years,
hOW else Will it get d0fle? Table 2-2, identifies five Air Quality Impacts and states
• qu.4 '• _
However. discussion of Impact 4.2 -1 on pa<ye 4.2 -12 states that this Droiect would
"obstruct implementation of the Air Quality Management Plan because the Updated
General Plan leads to a total Newport Beach population of 103,753 persons which is
approximately 10% over the SCAG - projected population for this area.” Since the City
has the option to plan for any population level it seems reasonable to plan for the SCAG-
projected population in an effort to comply with thresholds implicit in Impact 4.2-1.
EQAC
City of Newport Beach
Page 5
May 22, 2006
DRAFT
The discussion of Impact 4.2 -2 regarding construction emissions states that,
despite implementation of policies NR 8.1 through NR 8.5, we expect that construction
emissions resulting from this project will lead to significant and unavoidable
consequences. The final FIR should analyze whether the City's policies related to
construction emission should be strengthened to make them more effective. (Paces. 4.2-
13, 14, 15)
The discussion of Impact 4.2 -3 regarding cumulative increases in non - attainment
air_ pollutants is very encouraging and shows that the proposed policies should be
effective in achieving 2003 AQMP performance standards and emission reduction
targets. It appears reasonable to for the final EIR to state that rigorous enforcement of
these policies will lead to a less than significant impact. Pages 4.2 -14, 15)
The DEIR is basically silent on the issue of air pollution control of emissions
from the large number of watercraft that navigate Newport Bay. The final EIR should
fully address this issue. For example, anitem on "reduced levels of air pollution" could
be added to Policy HB 4.3 on page 4.1 -39.
Also. in the spirit of trying to be as responsive as possible, the final EIR should
change Policy N 7.4, Use of Blowers (Page 4.2 -20), to read that the Citv will eliminate
the use of blowers by the City by 2010 (for example) and require the same on private
property.
III. Biological Resources:
The second sentence under "Watersheds" appears to conflict with the final
sentence and should therefore be deleted. The watersheds are not discussed in detail in
this chapter. (Page 4.3 -3)
The location of giant kelp beds in Figure 4.3 -1 is almost impossible to read.
Surely it is not in the State highways shown in red. It is suggested that an arrow and label
be added to the diagram. Additionally, the legend shows "county boundary in green," but
the green area is simply everything outside of Newport Beach. In order to fulfill the
informational function of CEQA, this diagram needs to be clarified.
Under Impact 4.3 -2, the fourth sentence does not logically follow its predecessors.
The first part of the discussion states that the proposed Project would allow infill
development and would concentrate new development in certain specified subareas. It
goes on to state that the proposed Project priority for Banning Ranch is open space, "the
Plan also considers the possible development of a mixed - density residential village with a
small component of resident- and visitor - serving commercial ..." Then it states that
"(t)his would preclude most sites containing riparian habitats from being developed under
the proposed General Plan Update." What would preclude development of riparian sites?
F
EQAC -? DRAFT
City of Newport Beach
Page 6
May 22, 2006
This may belong at the end of the paragraph discussing regulation. The discussion
should be clarified or the sentence should be removed. (Page 4.3 -24)
There is a typographical error in the paragraph entitled Proposed General Plan
Update Policies. The second and third sentences are duplicates. (Page 4.3 -30)
�ers����inti�rasens 'ss�erseTS�rru!�a�ars�ue*e�eas .
The use of the word "important" in Policy NR10.10 provides a loophole for a
potential developer of the Banning Ranch to avoid habitat replacement if it is not
"important." In order to support the conclusion of less than significant impact on
biological resources, the word "important" should be deleted and replacement of any
habitat should be required. (Page 4.3 -32)
it is suggestedThe DEIR suggests that the official source of the Southern
California Eelgrass Mitigation Policy be stated. We were unable to 'a' 'is detail his
detail does not appear to be in the text. In order to fulfill the informational purpose of
CEQA the origin of this policy should be noted. (Page 4.3 -32)
IV. Cultural Resources
The DEIR states that "(t)he City's Historic Resource Inventory includes 61
properties which while not officially adopted, serves as a useful ugi 'de to potentially
historic properties...." The final EIR should clarify the City's criteria for selecting
potentially historic properties. ( Page 4.4 -14)
V. Geology, Soils and Mineral Resources
The section of the document is difficult to measure. It relies heavily on citing
documents that are not included; i.e., "all activities within the City would be required to
comply with standards, which will ensure implementation of appropriate ...etc." ASK
Sandie FOR CITE Short of finding all of those documents and reviewing them, one
must assume that future building will comply with all safety and earthquake standards,
and that the soil beneath them, subject to geological studies, will also be in compliance.
LOOK ON P. 4.5 -10
In describing the coastal platform occupied by Corona del Mar, and the area of
Newport Coast, no mention is made of the sediment flows or major drainage courses
found in these areas. These areas should be identified in these opening descriptions in the
final EIR, since they are referred to in later sections. (Page 4.5 -1)
EQAC
City of Newport Beach
Page 7
May 22, 2006
DRAFT
The subsection on regulatory framework sites Uniform Building Code, California
Building Code, Seismic Hazards Mapping Act, National Pollution Discharge Elimination
System ( "NPDES ") (general construction activity stormwater permit). However, there
is no discussion of the Clean Water Act that would limit the AMOUNT of runoff or limit
the percentage if increase a project generates on the AMOUNT of runoff. Construction
here and in surrounding cities increases the effects runoff has on all the concerns
addressed in this section of geology and soils and other sections. The final EIR should
address this issue.
The discussion of the Thresholds of Significance states that the "(i)mplementation
of the proposed General Plan Update could result in substantial soil erosion and the loss
of topsoil." The final EIR should identify the standards that would be used to determine
if a project results in significant impacts with respect to soil erosion and the loss of
topsoil. (Page 4.5 -15)
VI. Hazards and Hazardous Materials
With each and every item in the Hazards and Hazardous Materials section, the
DEIR refers to regulations and the proposed policies as the factors that render each and
every item LESS THAN SIGNIFICANT.
EXAMPLE: Future development could "uncover previously undiscovered soil
contamination as well as result in the release of potential contaminants that may be
present in building materials (e.g. mold, lead, etc.). This could result in a significant
WON
-111 W W POOR
VI. Hazards and Hazardous Materials
With each and every item in the Hazards and Hazardous Materials section, the
DEIR refers to regulations and the proposed policies as the factors that render each and
every item LESS THAN SIGNIFICANT.
EXAMPLE: Future development could "uncover previously undiscovered soil
contamination as well as result in the release of potential contaminants that may be
present in building materials (e.g. mold, lead, etc.). This could result in a significant
EQAC -� DRAFT
City of Newport Beach
Page 8
May 22, 2006
impact." See -13 Paae 4.6 -19)- The DEIR cites "compliance with existing regulations"
and with proposed GPU U General Plan Update policies as factors that would "reduce
impacts to less than significant."
The DEIR states it has been prepared as a "Program EIR" pursuant to CEQA
guidelines and lists one advantage as allowing "the Lead Agency to consider broad policy
alternatives and program wide mitigation measures at an early time when the agency has
greater flexibility to deal with basic problems or cumulative impacts."
Accordingly, and in light of the DEIR's reliance on regulations and proposed
policies as the factors that reduce any and all potential impacts to "less than significant,"
it appears necessary to include in the final EIR (1) a further discussion of the means of
enforcement and the agencies /departments of enforcement of the City's proposed
policies, (2) the timelines and response times for enforcement of each regulation and
policy, and (3) the implementation of a General Plan Update -wide policy that sets forth a
checklist to be used in each and every Spee specific PFejeet- rp oject EIR, for routinized
tracking and application of the regulatory obligations and enforcement
timelines /response -times (both for the applicants and the enforcement agencies) as they
relate to all projects implicating hazards and hazardous waste impacts /risks. Kest
4"ertamly -all inVaets whether-petei4ial or definite should be a ,,,..,,,a in light e
the response, elean up, and remediation times a#endant to the regiuleAieiis/policies and
enforcement eited by the City as the faeters that render all impac4s less than signifiearn.
■_ . _ .
0=1
IN
Mar fflpq"Vm�.
loll
Impact 4.6 -1 states that implementation of the proposed General Plan Update
could result in an increase in commercial development that could increase the overall
routine transport, use, storage, and disposal of hazardous materials within the City. NO
MITIGATION IS REQUIRED. LESS THAN SIGNIFICANT.
111M.-M! 01 WINNOW
0=1
IN
111M.-M! 01 WINNOW
EQAC
City of Newport Beach
Page 9
May 22, 2006
DRAFT
Impact 4.6 -2 states that construction activities associated with implementation of
the proposed General Plan Update could result in the release of hazardous materials to the
environment through reasonably foreseeable upset and accident conditions. NO
MITIGATION IS REQUIRED. LESS THAN SIGNIFICANT.
Impact 4.6 -3 states that operation of future land uses that could be developed
under the proposed Project could create a significant hazard to the public or the
environment through reasonably foreseeable upset and accident conditions involving the
release of hazardous materials into the environment. NO MITIGATION IS
REQUIRED. LESS THAN SIGNIFICANT.
_ _
NORMIS
Impact 4.6 -3 states that operation of future land uses that could be developed
under the proposed Project could create a significant hazard to the public or the
environment through reasonably foreseeable upset and accident conditions involving the
release of hazardous materials into the environment. NO MITIGATION IS
REQUIRED. LESS THAN SIGNIFICANT.
_ _
Impact 4.6 -3 states that operation of future land uses that could be developed
under the proposed Project could create a significant hazard to the public or the
environment through reasonably foreseeable upset and accident conditions involving the
release of hazardous materials into the environment. NO MITIGATION IS
REQUIRED. LESS THAN SIGNIFICANT.
i
EQAC DRAFT
City of Newport Beach
Page 10
May 22, 2006
Impact 4.6 -4 states that implementation of the Proposed General Plan Update
could result in a safety hazard as a result of existing oil wells or methane gas areas within
the City. NO MITIGATION IS REQUIRED. LESS THAN SIGNIFICANT.
n
r
r
Impact 4.6 -4 states that implementation of the Proposed General Plan Update
could result in a safety hazard as a result of existing oil wells or methane gas areas within
the City. NO MITIGATION IS REQUIRED. LESS THAN SIGNIFICANT.
n
Impact 4.6 -5 states that implementation of the proposed General Plan Update
could emit hazardous emissions or handle acutely hazardous materials, substances, or
waste within one - quarter mile of an existing or proposed school. NO MITIGATION IS
REQUIRED. LESS THAN SIGNIFICANT.
NOW
0.0
NOW
r
Impact 4.6 -5 states that implementation of the proposed General Plan Update
could emit hazardous emissions or handle acutely hazardous materials, substances, or
waste within one - quarter mile of an existing or proposed school. NO MITIGATION IS
REQUIRED. LESS THAN SIGNIFICANT.
EQAC '....' DRAFT
City of Newport Beach
Page 11
May 22, 2006
4he eiifflulative risks of the emissions and handling of baixardous material neaf seheels as
every projeet is implemented under this General Plan Update, Whiek should in tufn serve
.�7��esr ..ese�s�s�s, ri_eeESeellf.vY
ROM
OPINION
Impact 4.6 -6 states that the proposed General Plan Update includes sites, which
are included on a list of hazardous materials sites compiled pursuant to Government Code
Section 65962.5 and, as a result, could create a significant hazard to the public or the
environment. - NO MITIGATION IS REQUIRED. LESS THAN SIGNIFICANT.
Impact 4.6 -7 states that implementation of the proposed General Plan Update
could result in a safety hazard for people residing or working in the Planning Area as a
result of the proximity of a public airport. NO MITIGATION IS REQUIRED. LESS
THAN SIGNIFICANT.
OPINION
WIMINNIRM
r
Impact 4.6 -7 states that implementation of the proposed General Plan Update
could result in a safety hazard for people residing or working in the Planning Area as a
result of the proximity of a public airport. NO MITIGATION IS REQUIRED. LESS
THAN SIGNIFICANT.
EQAC
City of Newport Beach
Page 12
May 22, 2006
DRAFT
Impact 4.6 -8 states that implementation of the proposed General Plan Update
could result in interference with an adopted emergency response plan or emergency
evacuation plan. NO MITIGATION IS REQUIRED. LESS THAN SIGNIFICANT.
IN
. . . . .
.._
. . . . .
IV, UUMM99M.M.Wnra
Impact 4.6 -8 states that implementation of the proposed General Plan Update
could result in interference with an adopted emergency response plan or emergency
evacuation plan. NO MITIGATION IS REQUIRED. LESS THAN SIGNIFICANT.
Impact 4.6 -9 states that implementation of the proposed General Plan Update
could result in development in urbanized areas adjacent to or intermixed with wildlands.
NO MITIGATION IS REQUIRED. LESS THAN SIGNIFICANT.
Th These potential impacts is -are remote and undefined. Each and every project
under the proposed General Plan Update that leads to increased residential and
commercial development; whieh in he threat ef fire " ds clue"
lee ation of level Amer' and livif b. should be specifically evaluated as it becomes more
defined, rather than allowing this DEIR and related conclusions to function and serve as
the conclusive evaluation of environmental impacts. `r" ieh is to say, an), evaluation ,.r
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IN
. . . . .
.._
. . . . .
Impact 4.6 -9 states that implementation of the proposed General Plan Update
could result in development in urbanized areas adjacent to or intermixed with wildlands.
NO MITIGATION IS REQUIRED. LESS THAN SIGNIFICANT.
Th These potential impacts is -are remote and undefined. Each and every project
under the proposed General Plan Update that leads to increased residential and
commercial development; whieh in he threat ef fire " ds clue"
lee ation of level Amer' and livif b. should be specifically evaluated as it becomes more
defined, rather than allowing this DEIR and related conclusions to function and serve as
the conclusive evaluation of environmental impacts. `r" ieh is to say, an), evaluation ,.r
0
EQAC
City of Newport Beach
Page 13
May 22, 2006
DRAFT
Most importantly, every projee4 ,..,.7,.r the p sed General Plan Update that
implicates increased fire hazards in the �Aildlands sbould be evaI44ated- i4l 00H.Junetion with
11 other prc�ee4s under the proposed — ". I te that implieat the saffie
b
there should be a system with which to track the cumulative risks - impacts as each project
is implemented under the proposed General Plan Update, which should in turn serve as
the threshold data for all specific- project EIR analyses.
Note: The DEIR identifies only the following concerns relating to hazards and
hazardous materials that were expressed in EQAC's comments to the NOP:
"The Environmental Quality Affairs Citizens Advisory Committee for the City of
Newport Beach requested that the DEIR address potential impacts caused by the siting of
school facilities or residential developments on hazardous materials sites. as well as the
possible mitigation of these impacts."
VII. Hydrology and Water Quality
"`eetionSection 4.7 analyzes the impacts of the proposed Project on
hydrology and water quality within the City of Newport Beach.
Three types of upgrades are proposed for the City's storm drain system at a total
estimated cost of $18.5 million. The final EIR should detail the mechanisms that will be
put into place to ensure that these upgrades will be carried out despite potential budget
issues and any changes in City personnel.
All cumulative impacts for Water Quality, Groundwater, Storm Drainage and
Flood Hazards are rated as "less than significant" because each project within each area
will meet City, County and State Regulations and Codes. Again, upgrades to existing
facilities or the construction of new facilities would be required to meet the "less than
significant" standard. The final EIR should detail the mechanisms that will be put into
place to ensure that these upgrades will be carried out despite potential budget issues
VIII. Land Use and Planning
The proposed General Plan Update will be the blueprint for future development
within the City of Newport Beach for the next twenty years, and Section 4.8 analyzes the
impacts of the proposed General Plan Update on the future land use and planning within
the City that will guide that development.
The first threshold question asks whether the proposed development within any
Planning Area would create incompatibilities with adjacent land uses. The DEIR states
that the potential for conflict exists most where mixed use development occurs. The
proposed General Plan Update would add mixed use in some planning areas, such as
EQAC j DRAFT
City of Newport Beach
Page 14
May 22, 2006
Mariners' Mile, West Newport Mesa, Balboa Peninsula, Banning Ranch (if it is not
acquired for open space) and Newport Center, and would introduce mixed use in other
areas, including the Airport Area. Proposed Land Use Policies are cited as reasons why
intensification of land use will not result in an incompatibility.
Overall, the policies encourage but do not mandate property owners to comply
with the policies. In the absence of any incentive programs or mandatory requirements,
the EIR may not actually mitigate land use incompatibilities to a less than significant
level.
The DEIR Policy LU 5.2.2 "Buffering Residential Areas" suggests the use of
landscape screening to accomplish buffers to residential areas. No mention is made of
the potential to use specialized Mixed Use structures to transition from commercial to
residential. Examples of this would be single family type structures with a commercial
use such as a bookkeeper or architect on the commercial side, and the proprietor's
residence being located on the residential side.
The DEIR lists Policy LU 5.3.1 of the General Plan Update, which "provides
guidance that would minimize conflicts among uses in mixed use facilities," and lists
such items as design, building materials, building elevations, design of parking areas, and
landscape to minimize conflicts. These items are physical measures to minimize
conflicts. The policy does not include operational measures or discretionary review
procedures to provide the means to fully evaluate the range of mixed uses that would
occupy the same site. -The final EIR should discuss additional methods to reduce
conflicts so that incompatible mixed uses proposed on the same site are modified or
prohibited.
In the West Newport Mesa Area, Policy LU 6.6.5 is intended to increase
compatibility between residential and industrial uses through master plans for the new
residential areas. However, this policy does not address problems generated by industrial
uses that do not respect master plan boundaries, such as diminished air quality, odors,
noises and the attractive nuisance that industrial sites become when resident children are
introduced into the area.
EQAC DRAFT
City of Newport Beach
Page 15
May 22, 2006
Section 4.8.2 E.Eis4ing Gendifiens/Re.iden ial r. r..:,.i.i.,..i,,.eAs The commentary
on the existing land use at Lido Peninsula within Section 4.8.2 (Existing
Conditions/Residential Neighborhoods) incorrectly identifies the land use as single
family attached (it is manufactured housing) and fails to identify Lido Peninsula as
manufactured housing in the list of manufactured and/or mobile home uses within the
City.
In Section 4.8.2 jOther Land Use Changes),. T4ie-GAUthe DEIR identifies two
parcels to be rezoned to multi - family residential; in both cases, the reason given is
consistency with adjacent uses. _Since the existing uses (childcare, church &-and senior
housing) do not appear to be in conflict with a residential area, the change seems to
eliminate needed ancillary uses without reason. This is counter also to Policy LU 6.2.5,
which seeks to allow for complementary uses.
IX. Noise
Figures 4.9 2, 4, 5, and 7 show the airport as being gray on the Legend, yet that
area is not included on these figures. It ,.- uld be help£ ul if it could be fern°° The
figures should be revised in the final EIRto delete that reference.
There is an endorsement of the current level of charter boat activity on the Bay.
This effectively approves this level of service without a CEQA review. PAGE 4.1 -39:
Paragraph 4.9 -4 contains a statement that construction noise would be considered
"less than significant" even though exempt from City Code._ Construction noise should
be finther analyzed in the final EIR, with it ° °' w,._ supporting dimseiis�ata
based on numerical noise levels
Pages 4.9 -36 and 37 refer to Tables N2, N3; however, these tables do not appear
to be in the document.
X. Population and Housing
'k
EQAC �'' DRAFT
City of Newport Beach
Page 16
May 22, 2006
The housing/population section of the DEIR reflects EQAC's request for an
analysis of the buildouts proposed as measured by both the number of dwelling units
proposed and related population increases. Using the figure of 2.1.9 persons per unit
(2005) for projection purposes, the DEIR numbers are condensed as follows:
Dwelling Population
GP Existing 9549 20,912
GP Proposed 14,215 31,131
The population numbers on page 4.10.2 however. do not provide a breakdown
under either scenario as to the demogrrUhics (ages) of the population. The final EIR
should provide this information, which would provide the City with an additional
planning tool with respect to where growth is more likely to occur. Different aye groups
need different housing options. For example, high rises for seniors that also meet
affordable housing quotas are more likely over time to reduce the 2.19 figure per unit.
The paragraph entitled "Vacancy Rates" indicates that the City currently has a
vacancy rate of 10.9 %. substantially igher than that of the county at 3.7 %. This
intuitively seems incorrect and the use of 10.9% is likely under- representing the actual
population levels. (Page 4.10 -3)
In the third paragraph on page 4.10 -5, this percentage is used to indicate that all
allowed units would likely be filled to the level of 89.1 %, thereby justifying a higher
number of units.
This vacancy rate should be verified in the final EIR. It is likely being under-
represented because of the protocol by which vacancy is being measured.
XI. Public Services
(a) Fire Protection
The DEIR states that the proposed Project is not found to have significant impacts
on fire protection. However, this statement appears to contradict the remainder of the
text in this subsection. Throughout the subsection, the need for new services is directly
related to population growth, yet the DEIR states that the ""....Nl3FD does not use
population projections to determine projected future needs." (Page 4.11:_7)
The DEIR further states that: "tli?n the Airport Area, an increase in density by
both infill and conversion of low rise properties to mid and high rise will necessitate the
addition of a ladder truck company to the Santa Ana Heights Fire station." and =The
DEIR also states that "CUu)nder build out of the proposed General Plan Update, 4300
multi - family units would be constructed in this area. As a result of this development,
demand for 24 hour residential medical service could increase." (Page 4.11-4 and 9)
s
EQAC - `" DRAFT
City of Newport Beach
Page 17
May 22, 2006
"Thus, fire staffing and facilities would be expanded commensurately to serve the
needs of new development to maintain the current response time." (Page 4.11. -10)
The DEIR goes on to state that the "demand created by residents at the Irvine
Business Complex would adversely affect fire demand in the Planning Area such that
new facilities would be required, and thus the cumulative impact would less than
significant."
In addition, the DEIR states that the City of Costa Mesa is anticipating an
increased need for their services as a result of build out. "Given the large number of
firefighters that are required to respond to high risk, high consequence fire, fire
departments increasingly rely on automatic and mutual aid agreements to address the
fire suppression needs of the DEIR community." (Page 4.11 -7)
The final EIR should fully analyze the impacts noted above, as well as the
potential addition of 31,131 residents as projected in the proposed Project. In addition,
the final EIR should indicate where additional fire stations would be located and list the
criteria that would be used to site additional stations.
By adding 31,000 people at build out, our ability to respond inside the City will
be stretched, which will necessitate reducing our ability to respond outside the City. The
final EIR should analyze the impact that this will have on the City's Mutual Aid
Agreements with the surrounding cities.
The DEIR states that "(t)he Insurance Service Office recommends that a second
company be put in service in a fire station if that station receives more than 2,500
(medical emergency) calls per year." At the current rate of 2,011 calls per ambulance,
the City is perilously close to that level already. As the population increases, the City
will quickly reach the level where another station is needed, since most of the City's
stations cannot accommodate another company. This will have extensive environmental
effects. The final EIR should fully analyze this situation and propose any necessary
mitigation measures. (Page 4.11.5)
Further, the DEIR goes on to state that "(i)f an engine company provides support
to the paramedic ambulance by responding to medical aid calls and this impacts the
station's response to structure fire calls, it ... can result in a company being unavailable to
respond to a structure fire ... it can result in a larger fire before assistance arrives." This
Fcm
OMM.M=
By adding 31,000 people at build out, our ability to respond inside the City will
be stretched, which will necessitate reducing our ability to respond outside the City. The
final EIR should analyze the impact that this will have on the City's Mutual Aid
Agreements with the surrounding cities.
The DEIR states that "(t)he Insurance Service Office recommends that a second
company be put in service in a fire station if that station receives more than 2,500
(medical emergency) calls per year." At the current rate of 2,011 calls per ambulance,
the City is perilously close to that level already. As the population increases, the City
will quickly reach the level where another station is needed, since most of the City's
stations cannot accommodate another company. This will have extensive environmental
effects. The final EIR should fully analyze this situation and propose any necessary
mitigation measures. (Page 4.11.5)
Further, the DEIR goes on to state that "(i)f an engine company provides support
to the paramedic ambulance by responding to medical aid calls and this impacts the
station's response to structure fire calls, it ... can result in a company being unavailable to
respond to a structure fire ... it can result in a larger fire before assistance arrives." This
�s
EQAC
City of Newport Beach
Page 18
May 22, 2006
DRAFT
would be especially applicable to fires within the Newport Coast area, which is built over
a large area and surrounded by natural vegetation that has already proved to be a fire
hazard. The final EIR should fully analyze this situation and propose any necessary
mitigation measures.
The DEIR discusses the problems associated with structural fires in the older
portions of the City, which are especially susceptible to this hazard; a.—Areas such as
Balboa Peninsula, Balboa Island and Corona del Mar. The density of construction and
the narrow streets in these areas can affect emergency access. Although the DEIR
recognizes these problems, it offers nothing in the way of providing additional fire
protection for the thousands of new residents projected for these areas. The final EIR
should fully analyze this situation and propose any necessary mitigation measures.
There is a likely typographical error on page 4.11. 1, last paragraph, third line.
The sentence now reads: "Most of the Banning Ranch is not served....." and it should
read "Most of the Banning Ranch is now served....."
(b) Police Protection
There appears to be an error in the number of calls that are received by the
Dispatch Center. In one instance the DEIR states that there is an average of 24,000 calls
received by the Police Dispatch Center and in the next paragraph, the DEIR states that the
Dispatch Center receives 200,000 calls a year. This information should be corrected in
the final EIR because it will determine the accurate impact of the proposed Project on the
police protection services.
The following environmentally related issues are not addressed in the DEIR:
preparation for environmentally oriented acts of terrorism, such as hazardous waste,
water contamination, air pollution; catastrophic events arising from accident or terrorism
attacks at John Wayne Airport and a subsequent air crash in areas under the flight path;
tsunamis; the lack of an easily accessible and area wide alert system for residents. These
issues should be fully discussed in the proposed General Plan Update and should be
analyzed in the final EIR.
(c) Schools
The DEIR states that with the total increase of approximately 6,230 students
within the City (after buildout of the General Plan), it is assumed that approximately
4,347 students could attend schools within the Newport Mesa Unified School District
( "NMUSD "), which could potentially exceed the capacity of the District." However, the
DEIR goes on to state that "adherence to the policies contained in the proposed General
Plan Update, would ensure that impacts related to the provision of new educational
facilities is less than significant." (Page. 4.11 -24)
EQAC '� DRAFT
City of Newport Beach
Page 19
May 22, 2006
These two statements appear to be contradictory. The final EIR should clarify
this inconsistency. fully analyze the impacts to the schools at full buildout of the
proposed General Plan Update and recommend any necessary mitigation measures.
XII. Recreation and Open Space
Policy R9.5 (regarding private communities) is unclear. Is-tkeThe final EIR
should clarify whether the policy is suggesting-recommending that coastal access be
protected for the residents of these communities, or does the pahey in4en' that private
developments not be allowed to inhibit coastal access for non - residents? The pelie5
should be elan fied ;,, +t,,, final nrn. (Page 4.12 -24)
XIII. Transportation/Traffic
The discussions of traffic in Corona Del Mar do not show what happened to all the
traffic on Coast Highway between Marguerite and Poppy in both A.M. &and P.M. The
numbers do not add up when the cars on Marguerite, Poppy and Coast Highway are
calculated to get to the ICU of 0.99, 0.69, 0.83, 0.82, and 0.61 and 0.65. There is a
discrepancy with Marguerite at .83 and .82 and Poppy at .61 and .65 for A.M. &and P.M.
(Page 4.13 -11)
The DEIR discusses some "suggested" ideas for parking. In addition, it discusses
some programs but does not identify any "problems" that may be made worse than they
already are if the additional square footage is allowed for development of homes and
businesses. The final EIR should discuss specific proposals for parking. (Page 4.13 -17)
The Congestion Management Plan (`_CMP ") does not explain what the information
gathered is used for, nor does it identify any projects that meet the requirement for a Traffic
Impact Analyzes (_TIA" ). hThe CMP just-si lly lists four streets that are subject to the
CMP, but it doesn't indicate how this is utilized in or for thei proposeds General Plan
Update. The final EIR should make it clear that the CMP is included for background and is
not being considered by the City to become part of the General Plan Update.
Here at+d en page 4.13 -2-2 it also indioates L4at tl4s study "guidelines" is tO 411 AiWRi4l RB I OS
of "E". The decision makers sheuld bemade awafe of this as R seems to eenfliet with LOS
"l)" iA Rther areas, of this study. (Page 4.13 19)
■_
r
EQAC
City of Newport Beach
Page 20
May 22, 2006
DRAFT
The Thresholds of Significance outlines some CEQA guidelines on "adverse
impacts." Because of the Newport Beach Traffic Phasing Ordinance ( "TPO' ), the final EIR
should analyze the "adverse impacts" from traffic not only as CEQA requires, but also as the
TPO requires. (Page 4.13 -21)
The DEIR states that "LOS (le��e?r sew) D is the threshold for intersection
performance" in the City of Newport Beach. Considering the adverse effects of LOS "D,"
the policy makers and decision - makers may want to know what would be required to bring
this "threshold" to some better or more comfortable driving LOS, for example LOS "C."
The final EIR should include such an analysis. (Page 4.13 -21 and 22)
It is unclear whether items are or are not considered that have not been built and may
never be built are included in the statistics developed by the model. It is also unclear
whether actual existing traffic is considered in the model. It appears as if certain traffic that
exists is not considered. (SHOULDER SYSTEM - We don't consider and omit heavy
traffic use in summer and instead use spring and fall traffic counts discussed in multiple
locations, but by example see General Plan Public Draft - Chapter 7 - Circulation Element -
page 7 -3 continued on page 7 -4 and Appendix D to DEIR - paragraph 2.7 at page 2 -25 an d
DEIR - Chapter 4 - Daily Traffic Volumes - pie 4.13 -24.) This should be made much
clearer in the final EIR so the decision - makers are not confused as to what is and what is not
included so that they can make decisions on the value or lack thereof of this model's
estimates or predictions. (Page 4.13 -23)
Project Impacts, image 4.13 -25, states under Impact 4.13 -1 i Tthat
"implementation of the proposed General Plan Update could result in a substantial increase
in the number of vehicle trips, volume to capacity ratio on roads, or congestion at
intersections compared to existing conditions." Following this statement, the DEIR states
that the alternatives analyzed using the roadway system incorporate the "constrained
roadway network" explained in Section 4.13.5. However, here it indicates that under
the highest daily traffic volume counted in 2002 occurred on certain roadways. "'fie
the proposed General plan Update, traffic on these Foadvvays Nvould increase in enEeess e
The roads mentioned where this would occur are Campus Drive, Irvine Avenue,
Coast Highway, Jamboree Road, MacArthur Boulevard, Newport Boulevard, and Newport
Coast Drive. The DEIR further indicates that "this proposed General Plan Update itself
would generate approximately 44 percent of the total increase in traffic_ —"
While some additional information in the final EIR might make the analysis even
more cumbersome than this DEIR, it does seem that the decision - makers might want
available to them, in a format that they can easily utilize, a very clear statement of the name
of a roadway, the segment of that roadway involved, and the actual traffic as it exists today
in that segment, the estimated traffic for that segment that would be generated without any
change in the current General Plan, and the anticipated amount of traffic on that segment of
the road if this proposed General Plan Update is approved.
EQAC
City of Newport Beach
Page 21
May 22, 2006
DRAFT
It would seem that with this relatively simple to prepare document, the decision -
makers would have clear examples in front of them of the current traffic and increased
traffic that might result from changes currently in effect or changes that might go into effect
with the proposed General Plan Update. That information may be of assistance to them in
making decisions on whether the proposed General Plan Update or even the current General
Plan should or might be modified. (Page 4.13 -25)
Pages 4.13 -25 and 28 list certain roadway segments that are currently operating at
volume/capacity "V /C") ratios greater than 0.90. It is unclear whether this list was
prepared from actual traffic counts or based on calculations using a traffic model. This
should be clarified in the final EIR.
Throughout the segment of this chapter dealing with daily traffic, the issue of traffic
generated within the City that obviously utilizes City streets and discussions of traffic that
commences outside of the City and then comes into the City and utilizes City roads are-is
discussed in great detail. It would be beneficial to provide the information in the final EIR
on the sources for that information as it is utilized in this DEIR.
The DEIR states "the proposed General Plan Update, without growth in the region,
would increase traffic volume 13 percent over 2002 traffic counts, and would increase the
number of roadway segments exceeding a V/C ratio of 0.90 from 17 to 30." The DEIR goes
on to state that "because intersection operations are considered to be the most meaningful
measure of the performance of the roadway system, this impact related to the proposed
General Plan Update would be less than significant."
It is unclear whether these statements contrast with the statement earlier in this
Section wherein the DEIR indicated "the proposed General Plan Update itself would
generate approximately 44 percent of the total increase in traffic." This inconsistency
should be corrected in the final EIR: how an increase in traffic volume of 13 percent from
the proposed General Plan Update contrasts with the statement that the "General Plan
Update itself would generate approximately 44 percent of the total increase in traffic." (Page
4.13 -32)
�.
EQAC
City of Newport Beach
Page 22
May 22, 2006
J
DRAFT
The DEIR asks the threshold question: "Would the proposed project (General Plan
Update) result in inadequate emergency access ?" The finding stated is that any potential
impacts would be "less than significant." The final EIR should include a much more
detailed analysis of emergency evacuation from the area. It appears that if you have a
number of roadways, the main thoroughfares in the City, operating at LOS E during periods
of time of heavy traffic, and it is anticipated that there would be very heavy traffic in any
attempt to evacuate the area in the event of an emergency, that the statement that approval of
this proposed General Plan Update would result in "a less than significant" impact on
emergency evacuation may be an unfair statement or an inaccurate statement for the
decision - makers to rely upon in reviewing this proposed General Plan Update. (Page 4.13-
44)
The DEIR also asks the following threshold question: "Would the proposed project
(the General Plan Update) result in inadequate parking capacity ?" The finding is that the
impact on parking by the proposed General Plan Update would be "less than significant,"
which was based on parking surveys /studies and recommendations. Relying on
"recommendations" which have not been implemented and upon surveys /studies in an
analysis, and then making the statement that there is no parking problem or that it is "less
than significant" is not an appropriate conclusion based upon the information provided.
The final EIR should include a much more detailed analysis of the parking issue
with proposals that shall be implemented and with studies indicating that those requirements
are practical and cost effective and can be implemented by the City. This analysis must be
completed before a finding of "less than significant" can be made. (Page 4.13 -45)
In the Cumulative Impacts discussion, the DEIR indicates that traffic volumes
anticipated by the proposed General Plan Update would increase 30.9 percent over 2002
counts and 23.9 percent over 2005 levels. The DEIR then goes on to indicate that with
proposed improvements, the number of intersections operating at LOS E or worse would
decrease. Again, the City's existing General Plan circulation element, and other documents
in the City state that LOS D is the "threshold" on which the City of Newport Beach acts.
The DEIR then concludes that the traffic volumes in the proposed General Plan
Update would be "less than significant." The DEIR goes on to state that the proposed
Project's contribution to this impact would be cumulatively considerable and "significant
and unavoidable." The final EIR should clearly state why they havethe DEIR has discussed
throughout the traffic analysis a seeming approval of LOS E when the City's existing
General Plan circulation element, and other documents in the City, identify LOS D or better
as being acceptable. The General Plan circulation element specifically indicates that LOS E
is considered unacceptable. (Page 4.13 -46)
1
EQAC
City of Newport Beach
Page 23
May 22, 2006
"..._ DRAFT
In several locations in the Transportation/Traffic Section, the DEIR places an
emphasis on completing the improvements set forth in Table 4.13 -10 in order to achieve or
continue to allow a reasonable level of traffic movement. After placing significant emphasis
on these modifications, the DEIR then indicates on page 4.13 -46 that "these are conceptual
improvements, and alternative improvements that would achieve acceptable operations
could be substituted."
The section entitled Roadway System indicates at Policy CE 2.1.2 of the Traffic
Phasing Ordinance "update the Traffic Phasing Ordinance to maintain consistency with the
General Plan Circulation Element level of service standards." Obviously, there is some plan
to update the TPO, but there is no suggestion as to how it should be updated or the language
that should be utilized. Considering the significance of the TPO and its effect upon the City
of Newport Beach, it seems reasonable that the final EIR should point out the changes
necessary in the TPO so that the people reviewing the final EIR and the decision - makers are
aware of the modifications or changes that are necessary in this very important ordinance to
ensure its compliance with this new General Plan Circulation Element. (Page 4.13 -49)
Under Policy CE 2.1.5 (Roadway Improvements), the DEIR states= that
" jP&rsuant to construction of intersection improvements shown in €Figure CE 3 are
alternate improvements that achieve an acceptable level of service." Throughout the
proposed General Plan Update and this DEIR, it is stated that the current City's circulation
element requires LOS "D" or better. The language in Policy CE 2. 1.1 agrees with this with
six exceptions. Policy CE 2.1.5 should also make it clear that the "acceptable level of
service" is LOS "D" so there is no confusion between the different policies set forth on these
two pages. (Page 4.13 -50)
Policy CE 2.2.2 (-'Up -to -Date Standards": 1 states that "(gMeriodically review and
update street standards to current capacity and safety practices." While "standards" are
important, considering the fact that this document outlines a number of "street standards"
and indicates in many circumstances the "current capacity" is arguably lower than what the
"street standards" should be. It is suggested that an example be set forth under this policy as
to what this particular policy means as a practical matter by giving a practical example that
would meet this particular policy so that the decision - makers would know on voting on this
particular policy what they were voting for. (Page 4.13 -50)
Policy CE 7.1.5 (Avon Street Municipal Parking Lot relocationj— states "C
" Eonsider relocation of the Avon Street Municipal Lot to better serve commercial uses in
Marina's- Mariner's Mile." The final EIR should include a discussion of some practical
OWN 06,01
WINNOW
"I
The section entitled Roadway System indicates at Policy CE 2.1.2 of the Traffic
Phasing Ordinance "update the Traffic Phasing Ordinance to maintain consistency with the
General Plan Circulation Element level of service standards." Obviously, there is some plan
to update the TPO, but there is no suggestion as to how it should be updated or the language
that should be utilized. Considering the significance of the TPO and its effect upon the City
of Newport Beach, it seems reasonable that the final EIR should point out the changes
necessary in the TPO so that the people reviewing the final EIR and the decision - makers are
aware of the modifications or changes that are necessary in this very important ordinance to
ensure its compliance with this new General Plan Circulation Element. (Page 4.13 -49)
Under Policy CE 2.1.5 (Roadway Improvements), the DEIR states= that
" jP&rsuant to construction of intersection improvements shown in €Figure CE 3 are
alternate improvements that achieve an acceptable level of service." Throughout the
proposed General Plan Update and this DEIR, it is stated that the current City's circulation
element requires LOS "D" or better. The language in Policy CE 2. 1.1 agrees with this with
six exceptions. Policy CE 2.1.5 should also make it clear that the "acceptable level of
service" is LOS "D" so there is no confusion between the different policies set forth on these
two pages. (Page 4.13 -50)
Policy CE 2.2.2 (-'Up -to -Date Standards": 1 states that "(gMeriodically review and
update street standards to current capacity and safety practices." While "standards" are
important, considering the fact that this document outlines a number of "street standards"
and indicates in many circumstances the "current capacity" is arguably lower than what the
"street standards" should be. It is suggested that an example be set forth under this policy as
to what this particular policy means as a practical matter by giving a practical example that
would meet this particular policy so that the decision - makers would know on voting on this
particular policy what they were voting for. (Page 4.13 -50)
Policy CE 7.1.5 (Avon Street Municipal Parking Lot relocationj— states "C
" Eonsider relocation of the Avon Street Municipal Lot to better serve commercial uses in
Marina's- Mariner's Mile." The final EIR should include a discussion of some practical
EQAC -i DRAFT
City of Newport Beach
Page 24
May 22, 2006
suggestions for where this municipal lot might be relocated. Also, the number of parking
spaces currently available in that lot and how that might be replaced with a lot or lots of
equal size should be detailed in the final EIR. (Page 4.13 -56)
Policy CE 7.1.9 (— Parking Requirements for Pedestrian - Oriented and Local -
Serving Uses states — "Consider revising parking requirements for small scale neighborhood
serving commercial uses in areas that derive most of their trade from walk -in business,
especially where on -street or other public parking is available." The final EIR should
include a discussion of the specific areas that are under consideration when this policy was
developed, as well as the proposed "revised parking requirements" for these specific areas.
(Page 4.13 -57)
Policy CE 7.1.10 (— Parking for Marine Recreational Users)— states "Provide
adequate parking as necessary in the vicinity of visitors serving marine uses, including
marinas, water transportation terminals, boat ramps, as well as parking suitable for service
vehicles in commercial marinas and berthing areas." The final EIR should indicate the
names and descriptions of these areas and proposals for how to provide this "adequate
parking." (Page 4.13 -57)
Policy CE 7.1.13 ( —Up -to -Date Parking Requirements)— states "Periodically review
and update off - street parking requirements to insure that new development provides off -
street parking sufficient to serve approved uses." If this is merely a recommendation to
review the requirements but not to impose them on existing businesses. then this would
seem to be appropriate. However, if any review and update, under this policy, would be
read by anyone as imposing upon existing buildings or developments "updated off -street
parking requirements" then this should be made very clear in the final EIR so that it could be
commented upon by the business community. (Page 4.13 -57)
Policy CE 7.2.3 (— Shared Valet Service states—"Explore the feasibility of shared
valet parking programs in areas with high parking demand and less conveniently located
parking facilities, such as Mariner's Mile and McFadden Square." The final EIR should
indicate where these shared parking facilities would be located. (Page 4.13 -57)
Policy LU 3.2 (Growth and Change...) This particular policy indieet «states that
there is a necessity to "accommodate Newport Beach's share of projected regional
population growth." .. -It is not clear that the DEIR indicates what the number of people
concerned is or the number of families or the number of units that would be the "share" of
Newport Beach. The final EIR should indicate the number of this "share" based on some
recognized standard or requirement. (Page 4.13 -60)
Policy LU 6.15.20 jConnected Streets), The policy proposes to connect new and
existing streets across MacArthur Boulevard, along with crosswalks; and pedestrian refuges
in the median. The final EIR should indicate where these connections across MacArthur
Boulevard are intended or contemplated to occur. The reason that this is significant is
because of the V/C figures for MacArthur Boulevard discussed in this transportation/traffic
EQAC
City of Newport Beach
Page 25
May 22, 2006
DRAFT
element. It would appear that additional street crossings or signals might create additional
delays on the roadway that might affect even more than currently the V/C ratio. (Page 4.13-
61)
XIV. Utilities and Service Systems
(a) Water System
The DEIR states that the City currently supplies water to 75,600 people and
various land uses. The sources are water that is imported from The City i .,pe fts wale
frerm-theMunicipal Water District of Orange County ( "MWDOC ") ; groundwater that is
pumped from the Orange County Groundwater Basin and reclaimed water. Also, there
are areas of the City that get water from Irvine Ranch Water District ( "IRWD ") and Mesa
Consolidated Water District ( "MCWD ").
The DEIR states that MWDOC can meet 100 percent of the City's imported water
needs until the year 2030. The DEIR further states that the implication of the proposed
General Plan Update could require or result in the construction of new /and or expanded
water treatment plants or water conveyance systems in the Planning Area. This impact
would be less than significant since the City LU2.8 directs the City to accommodate any
infrastructure or conveyance necessary to meet the water needs.
The DEIR states that currently the City only receives 25 percent of its water from
MWDOC and 75 percent from Orange County Groundwater Basin. However the Notice
of Preparation ( "NOP ") for the proposed Project, Volume II, page 44, states that the City
currently receives 64 percent from the Basin and 36 percent from MWDOC. The DEIR
gives no information or indication as to how often the percentages change and why and
what the current numbers are. The DEIR neglects to give any information regarding
what other cGities get their water from the Groundwater Basin, how much, and how the
cumulative growth of all the cGities will affect the availability of water from the
Groundwater Basin up and until the year 2030.
The DEIR neglects to give any numbers as to how MWDOC and the Orange
County Groundwater Basin would be affected by dry years and out and out drought.
The final EIR should provide this analysis and recommend any necessary mitigation.
The DEIR informs the reader with Table 4.14 -2 of the Water Supply Reliability.
which shows drought and dry years. It goes on to say that during short -term periods (of
drought and /or dry conditions) the City would implement its water shortage contingency
plan. The final EIR should provide a full discussion of the City of Newport Beach water
shortage contingency plan.
The DEIR states that "(a)ccording to the City of Newport Beach's 2005 Urban
Water Management Plan, water supplies can continue to meet the City's imported water
EQAC DRAFT
City of Newport Beach
Page 26
May 22, 2006
needs until the year 2030." The final EIR should inform the reader what happens after
the year 2030, particularly with 31,000 additional residents at the proposed General Plan
buildout.
The DEIR continues and states "(t)he Groundwater Replenishment System
( "GRS "), a joint venture by OCWD and the Orange County Sanitation District
( "OCSD "), will help to reduce Orange County and Newport Beach's reliance on
imported surface water by taking treated wastewater and injecting it into the groundwater
basin. GRS will be online by 2007, and will produce approximately 70,000 acre -feet of
water per year." The final EIR should inform the reader what percentage of the blended
water will be wastewater and what percentage will be basin water, and whether or not
there will be a time when it will be 100 percent treated wastewater.
The DEIR informs the reader with Table 4.14 -2 of the Water Supply Reliability,
which shows drought and dry years. It goes on to say that during short-term periods (of
drought and /or dry conditions) the City would implement its water shortage contingency
plan. The final EIR should provide a full discussion of the City of Newport Beach water
shortage contingency plan.
(eb) Solid Waste
Solid Waste Haulers footnote 125 denotes that no trash is taken out of the County;
however, some is going to the Burner /Incinerator in Long Beach. which is- an alternative
that may need to be added to the list of sites for trash since this is a 20 year plan
The Refuse division of the City of Newport C + Beach picks up residential trash
from single family homes with the exception of Newport Coast. Bonita Canyon and
Santa Ana Heights need to be added to make the statement factual.
The DEIR neglects to mention and inform the reader that like the landfills, the
California Integrated Waste Management Board ( "CIWMB "), Title 14, and LEA regulate
and permit Transfer Stations and the tonnages that each Transfer Station is allowed. The
DEIR neglects to mention what the current tonnages are, what cities use them, the total
daily tonnage available, and what tonnage might be necessary to meet future waste
tonnages. The final EIR should provide this information, analyze any potential impacts
and recommend any necessary mitigation.
k
EQAC
City of Newport Beach
Paoe 27
May 22, 2006
DRAFT
The DEIR also neglects to inform the reader as to whether or not the Transfer
Station owned and operated by the City of Newport Beach would need to have its
totmage increased and by how much. The final EIR should state whether the City of
Newport Beach needs a new permit to meet the increasing tonnages of more growth.
The Enal EIR should inform the reader whether these facilities also have to be
licensed and permitted, and whether or not they have limits as to how much material they
can take.
The final EIR should identify the impacts of the surrounding cities on the few
L,and -lack- landfills and ter- transfer stations that are available. Tonnages for places
like Rancho Mission Viejo; Rancho Santa Margarita and IBC in Irvine, among others,
should be included in the final EIR so the reader could have a thorough understanding of
total County Tennagestonnases.
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