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HomeMy WebLinkAboutPACIFIC CITY PROJECT (5 OF 6) - Final Environmental Impact R VOLUME III FEBRUARY 2004 / I. ' jj .� �w r i ,if , ♦ w yr. ,. t 1 1 0111111111P II • `icy'• �� d'�'*, tX it ,, ., ,,: ete 'N. 'Oki ."` ! - 4 p�.�� a- 4. a N, I / 3,, ti I `a FINAL ENVIRONMENTAL I M PACT REPORT PACIFIC CITY JJ SCH No. 20030I I024 EIR 02-0 I •� V City of Huntington Beach 2000 Main Street, P.O. Box 190 Huntington Beach, Ca 92648 714.536.5271 Prepared by EII' A S S (S ( IA 'I I S www.eipassociates.com 1 2301 Wilshire Boulevard, Suite 430 Los Angeles, Ca 90025 310.268.8132 Feb 10 03 02: 24p HPI J// (909) 981 -9396 p. 1 /1441.")."-- 4gdfleff 0*°41-A4-7 8 Via De La Mesa Rancho Santa Margarita,CA 92688 Urban Planning (949)233-1814 Fax:(949)459-1620 Consulting Group Fax � C o ' To: City Clerk,City of Huntington Beach From: UPCG � Fax: (714)374-1557 Pages: 7(including cover) c-' Phone: Date: 02/10/03 Re: Pacific City Project CC: ❑Urgent x For Review ❑ Please Comment 0 Please Reply 0 Please Recycle • Comments: I he following information is provided pursuant to the public notice for the Pacific City Project: Thanks. Feb 10 03 02: 24p HPI (909) 981 -939G p. 2 v 8 Via De La Mesa Rancho Santa Margarita, CA 92688 C (949) 233-1814 (949) 459-1620 February 10, 2003 Honorable Mayor, the City Council and Members of the Planning Commissioner City of Huntington Beach 2000 Main Street Huntington Beach CA 92648 RE: Notice of Preparation of Environmental Impact Report and Environmental Assessment No. 02-05 for the Pacific City Project Dear City Decision Makers: The Urban Planning Consulting Group, Inc., is a land use and environmental consulting firm providing land use and environmental planning services to clients. The firm is located in the City of Rancho Santa Margarita, Orange County California. On behalf of the Pacific City Action Coalition Group, Urban Planning Consulting Group offers the following comments on the notice of preparation of a Draft Environmental Impact Report and Environmental Assessment No. 02-05 for the Pacific City Project, The Pacific Action Coalition Group is a coalition of residents within the project site. The Pacific Action Coalition Group would like the City of Huntington Beach, as Lead Agency in preparation of the environmental documents for this project, to consider the following recommendations: Hazards and Hazardous Materials: The Initial Study indicates that the property north of the Huntington Shores Motel was formerly occupied by a (natural) gas plant. This resulted in the presence of Benzene and Toluene leaking into the soil from the condensate due to processing of the gas. No recent tests have been conducted in this or adjacent areas of the site. The last tests occurred in 1996 and are not current enough (See Phase II Investigation Report/Remediation Plan Atlanta Areas - December 1996). Additional soil gas testing for volatile organic compounds was only conducted in certain portions of the site. With 20 oil wells scattered throughout the property, the likelihood that contamination was limited only to the region tested is remote at best (See Remediation Plan, Rev. 3 Atlanta Site - May 2002). State Division of Oil and Gas records show that the re-abandonment of the oil wells in the late 1990's was necessary to stop leaking gas. They had been previously abandoned in the late 1980's. The wells have not been tested by Oil and Gas since the Feb 10 03 02: 24p HPI (909) 981-9396 p. 3 NOP Draft EIR for Pacific City Project Environmental Assessment No.02-05 February 10, 2003, Page 2 re-abandonment and the agency states that their tests are only good for a one-year period. Thus the wells must be re-tested to ensure there are no leaks presently. And there remains the -question of the extent of any groundwater contamination (See Remediation Plan). Because of a lack of recent extensive soil gas and oil well testing, there is a likelihood that contaminants exist which have not yet been identified exist. Therefore, any additional excavation or movement of the soil would be premature until the site's true soil condition regarding hazardous materials is known. Transportation/Traffic; Residents believe keeping Huntington Street in its present width and alignment except for some curb and sidewalk improvements on Pacific City side will not work. Residents would also like to see some improvements in the entrance and exit of Pacific Mobile Home Park, along with curb improvements or installation of sidewalks, removal of overhead utility poles, and a retaining/sound (and for esthetics) wall on mobile home park side of Huntington Street at developers expense (without removing any homes). • Consideration should be given to relocating the entrance/exit of Pacific Mobile Home Park to present dead-end configuration of Delaware Street, and officially abandoning the Delaware Street extension south of Atlantic Avenue to connect with Huntington Street at Pacific View Avenue. • The City should consider abandoning the extension of Delaware Street, which is currently on the Orange County Master Plan of Arterial Highways (MPAH) and Huntington Beach Precise Plan of Street Alignments (PPSA) as this new extended configuration. • The developer should be required to pay for all related traffic improvements, removing of Pacific Mobile Home Park entrance from Huntington Street to Delaware Street, and the installation of curbs, sidewalks, infrastructure improvements, underground utility poles, retaining walls, etc., all around the mobile home park. No mobile homes should be affected along Huntington Street. Developer should be required to relocate those affected with new Delaware Street entrance back into the park. • Sound walls should be constructed around and on park side because of noise from increased traffic due to Pacific City development. • Consideration should be given to Pacific View Avenue (Walnut Avenue) extension from 1st Street to 6th Street, and Pacific View Avenue (Walnut Avenue extension from Beach Blvd. to connect with Hamilton / Victoria (Costa Mesa) and the 55 freeway. Cite of Huntington Beach-Pacific City 2 The Urban Planning Consulting Group Feb 10 03 02: 25p HPI (909) 981 -9336 p. 4 NOP Draft EIR for Pacific City Project Environmental Assessment No.02-05 February 10, 2003, Page 3 • The City should consider the possible extension of Delaware Avenue south of Atlantic Avenue. • Residents believe that the parking projections for the Hyatt/Hilton Waterfront Projects may be incorrect because it is based solely on total valet parking. Lessons learned from this development should be applied to the proposed project to avoid the same problems. • The parking garages should be designed to fit hotel tour buses, delivery vans, as well as moving vans and. trucks. Moving vans and trucks and delivery vans currently park on Pacific View Avenue because they will not fit into parking garage. • In preparation of the EIR, the City should revisit all previous reports and findings (EIR) for the Waterfront Resort and/or expansion projects in regards to Pacific City. Information need to be updated to current standards and conditions, as it appears Pacific City is now exceeding all original projections. • Residential and retail development will likely increase traffic significantly during peak commuter hours, weekends and during the summer. The EIR should consider impacts on traffic flow/congestion in the immediate vicinity of the property and regionally (e.g., Beach Blvd, Goldenwest St., PCH and freeways). • Impacts from traffic/parking needs for site workers, materials/waste delivery to/from site need to be addressed in the EIR to minimize impacts on the neighborhood and ensure access to adjacent resident sites is not impeded. • Specifics regarding proposed pedestrian access for the public should be stated in the EIR. For example, hours that public access will be available must be stated. Also, since the pedestrian access ways are proposed to be gated, availability of the access to the public should be considered such that public access will not be further restricted than initially proposed. • Bicycle lanes should be maintained on all streets surrounding the site. No non- pedestrian access (e.g., bicycles, skates, etc.) is proposed through the facility. Therefore lanes for safe travel for bicyclists and skaters must be provided on streets surrounding the site. • Since zoning allows higher buildings on the east (Huntington Street) side than on the north (Atlanta St.) and west (First St.) sides, and since the site is surrounded on the east, west and north by residential homes, the City should consider the same height restriction on the west side as for other adjacent residential areas. This would ensure that ordinances for aesthetics (e.g., view, glare, noise, etc.) are appropriately maintained for residents adjacent to the west of the site. City of Huntington Beach—Pacific City 3 The Urban Planning Consulting Group Feb 10 03 02: 25p HPI (909) 981-9396 p. 5 NOP Draft EIR for Pacific City Project Environmental Assessment No.02-05 - February 10,2003, Page 4 • Any future traffic studies must take into account peak periods for the region. This is particularly relevant to this project as the new Hyatt Hotel just south of the site hosts an 110,000 square foot convention center, which will bring thousands of business travelers to the area. The Linscott study doesn't appear to address this. • The impact of the increased density of the project on access and service to existing neighborhoods such as the adjacent Pacific Mobile Home Park, homes along Atlanta and Huntington streets as well as patrons of the commercial and residential parts of the development should be carefully studied. The Linscott study did not seem to address this issue. • Any proposed parking analysis should account for (1) project usage, (2) Hyatt's new convention facility and (3) regional parking during the height of the summer tourist season. • The anticipated increase in residential and retail population as a result of the project will impact already overcrowded parking conditions downtown. The specific number of parking spaces to be provided for residents, guests and commercial vehicles must be provided in the proposal so that the sufficiency of parking proposed can be evaluated based on the estimated demand for resident, guest and commercial visitor parking. The proposal also notes that on-street parking on adjacent streets will be: allowed. Currently there is no on-street parking allowed on Atlanta. and Huntington since these are single lane roads. Again, this proposal taxes the existing single lane roadways and the proposal does not state that dedicated right of way will be used for additional vehicle and bike lanes, or space for on street parking. The proposal only notes that sidewalk and curb and gutter improvements will be made. • How will buses be accommodated along adjacent streets with the increased traffic? • The project is anticipated to increase traffic on Huntington Street and surrounding streets. Huntington Street is proposed to be widened to a 90-foot right-of-way. Where would the additional ROW be taken from? From the developer property or public and/or residential property? Public Services • In light of the $7 million City of Huntington Beach deficit due to the current State budget crisis, the EIR should identify project impacts on current public services such as Fire, Police and Lifeguard services. • The EIR should clarify whether the proposed roadways within the residential development would be private or public. Impacts for access for Police and Fire departments in emergency conditions should be analyzed. City of Huntington Beach-Pacific City . 4 The Urban Planning Consulting Group Feb 10 03 02: 25p HPI (909) 981 -9399 p. 0 NOP Draft EIR for Pacific City Project Environmental Assessment No.02-05 February 10,2003, Page 5 Public Beach Access • While not specifically addressed in the Initial Study, the issue of public beach access is critical for any coastal development. The EIR should identify the project's impacts on beach parking during peak summer months. The Linscott study does not seem to address this critical peak period. Aesthetics • The EIR should address impacts on the elimination of existing ocean views of residents in adjacent neighborhoods along Huntington, Atlanta and First streets, and propose measures to preserve the vistas the residents have had for years. • Impacts from shade and shadows, light from both the commercial and residential parts of the project, and glare should be adequately addressed, as they will severely impact surrounding neighborhoods. Recreation • With city park ratios of five acres per 1,000 persons, how is .90 acre for the project's park space allowed? Is one fifth or less of the required space acceptable? There must be both an increase in park space and reduced density to accommodate this guideline. Noise • The EIR must specifically propose mitigation measures to address the issue of excessive noise during the construction phase on neighboring development. In addition, the city should inform the public how compliance with noise regulations will be enforced. • Noise during site operations during/following completion of the construction phase also needs to be addressed. Hotel, bars, restaurants, and other commercial facilities proposed to operate at the site will create noise that may be a nuisance to neighboring residents. Schedule for Construction and Operations • The construction schedule proposed is basically without restrictions and does not consider the adjacent land use and quality of life of the neighbors. The proposed operating schedule is 7 a.m. to 8 p.m. Mon-Sat. This schedule should be restricted to Mon - Fri only, with working hours restricted to allow neighbors morning and evening hours undisturbed by noise. Recommend 9 a.m. to 6 p.m. operating schedule Mon - Fri. The approved schedule should remain in effect for the life of the project or until adjacent site uses change. In addition, set-up for City of Huntington Beach-Pacific City 5 The Urban Planning Consulting Group Feb 10 03 02: 25p HPI (909) 981 -939G p. 7 NOP Draft EIR for Pacific City Project Environmental Assessment No.02-05 February 10,2003, Page 6 site work should be monitored by the city so that residents are not exposed to excessive noise and emissions from idling trucks, and loading/unloading operations at times outside the construction schedule. • The timetable for construction should be specific with regard to when public access ways and other facilities (public park space, etc.) are to be constructed. Provisions should be included that require completion of the promised public facilities to be provided (parks,. street improvements, etc.) on a specified schedule. Project Alternatives The City should consider reducing the scope of the project by reducing the number of condominium units and retail space, as this would reduce the project's impacts on the residents, surrounding land uses, and the environment. Conclusion In summary, environmental documents are informational documents required to provide detailed information on proposed developments and recommend adequate mitigation measures along with such disclosure. Based on the concerns expressed by nearby residents, the EIR should adequately address these significant concerns. We hope that bringing these issues to your attention at this point would serve as a guide to the preparation of the EIR. We anticipate the preparation and review of the draft EIR upon completion, and we thank you for your consideration. Sincerely, THE URBAN PLANNING CONSULTING GROUP Gabriel Elliott Principal City of Huntington Beach-Pacific City 6 The Urban Planning Consulting Group _ PACIFIC CITY Volume III—Text Changes and Responses to Comments Final Environmental Impact Report EIR No. 02-01 SCH No. 2003011024 Prepared for City of Huntington Beach 2000 Main Street Post Office Box 190 Huntington Beach, California 92648 Prepared by EIP Associates 12301 Wilshire Boulevard, Suite 430 Los Angeles, California 90025 February 2004FEw , ,FEB 20 Z004 CONTENTS VOLUME I—DRAFT ENVIRONMENTAL IMPACT REPORT Executive Summary xv Introduction xv Structure of the EIR xv Summary of Proposed Project xvi Summary of Project Objectives xix Public Involvement xx Classification of Environmental Impacts and Discussion of Mitigation Measures xxi Significant and Unavoidable Impacts xxii Synopsis of Alternatives xxii Summary of Environmental Impacts and Mitigation Measures xxiii Chapter 1 Introduction 1-1 1.1 Overview of the Proposed Project 1-1 1.2 Relationship of Proposed Project to Previous Environmental Documentation 1-1 1.3 Purpose of the EIR 1-2 1.4 Environmental Review Process 1-3 1.5 Intended Use of the EIR 1-5 1.6 Scope of the EIR 1-6 1.7 Project Sponsors and Contact Persons 1-7 1.8 Document Organization 1-7 1.9 Areas of Controversy and Issues to Be Resolved 1-8 Chapter 2 Project Description 2-1 2.1 Project Location 2-1 2.2 Existing Site Characteristics 2-1 2.2.1 Existing On-Site Land Use 2-4 2.2.2 Surrounding Land Uses 2-4 2.2.3 Existing General Plan/Zoning Designations 2-5 2.2.4 Former Uses of the Site 2-7 2.3 Proposed Project Development 2-8 2.3.1 Visitor-Serving Commercial Center 9-13 2.3.2 Residential Village 2-16 2.3.3 Vehicular and Pedestrian Circulation Improvements 7-17 2.4 Construction Scenario 2-26 2.5 Project Goals and Objectives 2-26 2.6 Intended Uses of the EIR 2-30 Pacific City EIR 1ii Contents 2.6.1 City of Huntington Beach 2-30 2.6.2 State and Local Agencies 2-31 2.7 Cumulative Projects 2-32 Chapter 3 Environmental Impact Analysis 3-1 3.1 Aesthetics 3.1-1 3.1.1 Existing Conditions 3.1-1 3.1.2 Regulatory Framework 3.1-23 3.1.3 Thresholds of Significance 3.1-29 3.1.4 Project Impacts 3.1-29 3.1.5 Cumulative Impacts 3.1-45 3.1.6 Mitigation Measures and Residual Impacts 3.1-46 3.2 Air Quality 3.2-1 3.2.1 Existing Conditions 3.2-1 3.2.2 Regulatory Framework 3.2-5 3.2.3 Thresholds of Significance 3.2-11 3.2.4 Project Impacts 3.2-12 3.2.5 Cumulative Impacts 3.2-18 3.2.6 Mitigation Measures and Residual Impacts 3.2-19 3.3 Biological Resources 3.3-1 3.3.1 Existing Conditions 3.3-1 3.3.2 Regulatory Framework 3.3-11 3.3.3 Thresholds of Significance 3.3-18 3.3.4 Project Impacts 3.3-18 3.3.5 Cumulative Impacts 3.3-23 3.3.6 Mitigation Measures and Residual Impacts 3.3-24 3.4 Cultural Resources 3.4-1 3.4.1 Existing Conditions 3.4-1 3.4.2 Regulatory Framework 3.4-11 3.4.3 Thresholds of Significance 3.4-16 3.4.4 Project Impacts 3.4-16 3.4.5 Cumulative Impacts 3.4-18 3.4.6 Mitigation Measures and Residual Impacts 3.4-18 3.5 Energy and Mineral Resources 3.5-1 3.5.1 Existing Conditions 3.5-1 3.5.2 Regulatory Framework 3.5-6 3.5.3 Thresholds of Significance 3.5-8 3.5.4 Project Impacts 3.5-9 3.5.5 Cumulative Impacts 3.5-11 3.5.6 Mitigation Measures and Residual Impacts 3.5-12 3.6 Geology and Soils 3.6-1 3.6.1 Existing Conditions 3.6-1 3.6.2 Regulatory Framework 3.6-11 3.6.3 Thresholds of Significance 3.6-16 3.6.4 Project Impacts 3.6-16 3.6.5 Cumulative Impacts 3.6-19 iv City of Huntington Beach Contents 3.6.6 Mitigation Measures and Residual Impacts 3.6-20 3.7 Hazardous Materials 3.7-1 3.7.1 Existing Conditions 3.7-2 3.7.2 Regulatory Framework 3.7-12 3.7.3 Thresholds of Significance 3.7-15 3.7.4 Project Impacts 3.7-15 3.7.5 Cumulative Impacts 3.7-19 3.7.6 Mitigation Measures and Residual Impacts 3.7-19 3.8 Hydrology and Water Quality 3.8-1 3.8.1 Existing Conditions 3.8-1 3.8.2 Regulatory Framework 3.8-9 3.8.3 Thresholds of Significance 3.8-16 3.8.4 Project Impacts 3.8-17 3.8.5 Cumulative Impacts 3.8-24 3.8.6 Mitigation Measures and Residual Impacts 3.8-26 3.9 Land Use and Planning 3.9-1 3.9.1 Existing Conditions 3.9-1 3.9.2 Regulatory Framework 3.9-3 3.9.3 Thresholds of Significance 3.9-18 3.9.4 Project Impacts 3.9-19 3.9.5 Cumulative Impacts 3.9-22 3.9.6 Mitigation Measures and Residual Impacts 3.9-23 3.10 Noise 3.10-1 3.10.1 Existing Conditions 3.10-1 3.10.2 Regulatory Framework 3.10-8 3.10.3 Thresholds of Significance 3.10-14 3.10.4 Project Impacts 3.10-14 3.10.5 Cumulative Impacts 3.10-20 3.10.6 Mitigation Measures and Residual Impacts 3.10-22 3.11 Population and Housing 3.11-1 3.11.1 Existing Conditions 3.11-1 3.11.2 Regulatory Framework 3.11-10 3.11.3 Thresholds of Significance 3.11-13 3.11.4 Project Impacts 3.11-13 3.11.5 Cumulative Impacts 3.11-17 3.11.6 Mitigation Measures and Residual Impacts 3.11-18 3.12 Public Services 3.12-1 3.12.1 Existing Conditions 3.12-1 3.12.2 Regulatory Framework 3.12-5 3.12.3 Thresholds of Significance 3.12-9 3.12.4 Project Impacts 3.12-9 3.12.5 Cumulative Impacts 3.12-13 3.12.6 Mitigation Measures and Residual Impacts 3.12-14 3.13 Recreation 3.13-1 3.13.1 Existing Conditions 3.13-1 Pacific City EIR v Contents 3.13.2 Regulatory Framework 3.13-4 3.13.3 Thresholds of Significance 3.13-9 3.13.4 Project Impacts 3.13-9 3.13.5 Cumulative Impacts 3.13-12 3.13.6 Mitigation Measures and Residual Impacts 3.13-13 3.14 Transportation/Traffic 3.14-1 3.14.1 Existing Conditions 3.14-1 3.14.2 Regulatory Framework 3.14-23 3.14.3 Thresholds of Significance 3.14-27 3.14.4 Project Impacts 3.14-28 3.14.5 Cumulative Impacts 3.14-77 3.14.6 Mitigation Measures and Residual Impacts 3.14-77 3.15 Utilities and Service Systems 3.15-1 3.15.1 Existing Conditions 3.15-1 3.15.2 Regulatory Framework 3.15-5 3.15.3 Thresholds of Significance 3.15-12 3.15.4 Project Impacts 3.15-13 3.15.5 Cumulative Impacts 31.15-19 3.15.6 Mitigation Measures and Residual Impacts ' 3.15-21 Chapter 4 Alternatives to the Proposed Project 4-1 4.1 Introduction 4-1 4.1.1 Rationale for Selecting Potentially Feasible Alternatives 4-1 4.1.2 City of Huntington Beach Objectives 4-2 4.1.3 Applicant Objectives 4-2 4.2 Alternatives Analysis 4-3 4.2.1 No Project/No Development Alternative 4-4 4.2.2 Reasonably Foreseeable Development 4-5 4.2.3 Reduced Project Alternative 4-13 4.3 Other Alternatives Considered 4-24 4.3.1 Alternative Site 4-24 4.3.2 Limited Development Alternative 4-25 4.3.3 Reduced Residential Density Alternative 4-26 4.4 Environmentally Superior Alternative 4-26 Chapter 5 Long-Term Implications 5-1 5.1 Growth-Inducing Impacts 5-1 5.1.1 Extension of Public Facilities 5-1 5.1.2 Employment Generation 5-2 5.1.3 Additional Housing Supply 5-3 5.2 Significant, Irreversible, Environmental Changes 5-3 5.3 Significant, Unavoidable Impacts 5-4 vi City of Huntington Beach Contents Chapter 6 List of Preparers 6-1 Chapter 7 References 7-1 7.1 Written References 7-1 7.2 List of Persons and Agencies Contacted - 7-6 Figures Figure 2-1 Project Vicinity& Regional Location Map 2-2 Figure 2-2 Existing Site Overlays and Surrounding Uses 2-3 Figure 2-3a Proposed Site Plan—Floor Plan Street/Podium Level 2-9 Figure 2-3b Proposed Site Plan—Floor Plan Level Two 2-10 Figure 2-3c Proposed Site Plan—Floor Plan Level Three 2-11 Figure 2-3d Proposed Site Plan—Floor Plan Level Four 2-12 Figure 2-4 Proposed Building Heights 2-15 Figure 2-5a Common Open Space Diagram 2-18 Figure 2-5b Private Open Space Diagram 2-19 Figure 2-6 Vehicular Access and Circulation 2-24 Figure 2-7 Pedestrian Access and Circulation 2-25 Figure 2-8a Construction Schedule 2-27 Figure 2-8b Construction Phasing 2-28 Figure 2-9 Cumulative Projects 2-34 Figure 3.1-1 Photo Location Map 3.1-4 Figure 3.1-2 Viewpoint 1: View Southwest from Huntington Street 3.1-5 Figure 3.1-3 Viewpoint 2: View Southwest from Intersection of Huntington Street and Atlanta Avenue 3.1-6 Figure 3.1-4 Viewpoint 3: View South from Atlanta Avenue 3.1-7 Figure 3.1-5 Viewpoint 4: View Southeast from Orange Avenue 3.1-8 Figure 3.1-6 Viewpoint 5: View Southeast from First Street 3.1-9 Figure 3.1-7 Viewpoint 6: View East from PCH, West of First Street 3.1-10 Figure 3.1-8 Viewpoint 7: View Northeast from the Huntington Beach Pier 3.1-11 Figure 3.1-9 Viewpoint 8a: View Northeast from PCH, between First and Huntington Streets 3.1-12 Figure 3.1-10 Viewpoint 8b: View Northeast from Beach Parking Lot, between First and Huntington Streets 3.1-13 Figure 3.1-11 Viewpoint 9: View North from PCH at Huntington Street 3.1-14 Figure 3.1-12 Viewpoint 10: View West from Pacific View Avenue, East of Huntington Street 3.1-15 Figure 3.1-13 Viewpoint 11: View Southwest from Manning Park 3.1-16 Figure 3.1-14 Viewpoint 12: View East from PCH at the Huntington Beach Pier 3.1-17 Figure 3.1-15 Areas Across from Proposed Garage A 3.1-20 Figure 3.1-16 Areas Across for Proposed Garage B 3.1-21 Figure 3.1-17, Areas Across From Proposed Garage C 3.1-22 Figure 3.1 18 Typical Shadows Cast by Proposed Development 3.1-35 Figure 3.1-19 Worse Case Shadows—Winter Solstice 3:00 P.M. 3.1-36 Figure 3.1 20 Proposed Garage and Intersection Locations 3.1-39 Pacific City EIR vii Contents Figure 3.1-21 Conceptual Headlight Effects 3.1-42 Figure 3.3 1 On-Site Vegetation Types 3.3-8 Figure 3.5-1 Oil Overlay Districts 3.5-5 Figure 3.6-1 Major Regional Faults 3.6-6 Figure 3.6-2 Local Faults 3.6-7 Figure 3.6-3 On-Site Soil Regions 3.6-9 Figure 3.7-1 Site Investigation/Remediation Status 3.7-8 Figure 3.8-1 Drainage Channels and Pumping Stations 3.8-3 Figure 3.8-2 Vicinity Map & Drainage Areas 3.8-5 Figure 3.8-3 Existing Hydrology 3.8-7 Figure 3.8-4 Moderate Tsunami Run-Up Area 3.8-10 Figure 3.8-5 Proposed Drainage 3.8-22 Figure 3.9-1 General Plan Land Use Map 3.9-6 Figure 3.9-2 Downtown Specific Plan Districts 3.9-15 Figure 3.10-1 Representative Environmental Noise Levels 3.10-2 Figure 3.10-2 Noise Measurement Locations 3.10-6 Figure 3.14-1 Existing Roadway Conditions and Intersection Controls 3.14-5 Figure 3.14-2 Existing A.M. Peak Hour Traffic Volumes 3.14-9 Figure 3.14-3 Existing P.M. Peak Hour Traffic Volumes 3.14-11 Figure 3.14-4 Existing Average Daily Traffic Volumes 3.14-13 Figure 3.14-5 Existing Off-Site Parking Plan 3.14-22 Figure 3.14-6 A.M. Peak Hour Project Traffic Volumes 3.14-31 Figure 3.14-7 P.M. Peak Hour Project Traffic Volumes 3.14-33 Figure 3.14-8 Average Daily Project Traffic Volumes 3.14-35 Figure 3.14-9 2008 A.M. Peak Hour Volumes with Project Traffic 3.14-43 Figure 3.14-10 2008 P.M. Peak Hour Volumes with Project Traffic 3.14-45 Figure 3.14-11 2008 Average Daily Volumes with Project Traffic 3.14-47 Figure 3.14-12 2020 General Plan Buildout A.M. Peak Hour Volumes with Project Traffic 3.14-59 Figure 3.14-13 2020 General Plan Buildout P.M. Peak Hour Volumes with Project Traffic 3.14-61 Figure 3.14-14 2020 General Plan Buildout Average Daily Traffic Volumes with Project Traffic 3.14-63 Figure 3.14-15 Proposed Street Parking 3.14-70 Figure 4.14-16 Proposed Site Plan 3.14-73 Tables Table ES-1 Proposed Visitor-Serving Commercial Uses xvii Table ES-2 Residential Units xvii Table ES-3 Summary of Proposed Roadway Improvements xviii Table ES-4 Summary Impact Table xxiv Table 2-1 Summary of Existing Site Characteristics 2-1 Table 2-2 Summary of Applicable Design and Development Provisions 2-6 Table 2-3 Proposed Project Uses 2-8 viii City of Huntington Beach Contents Table 2-4 Summary of Project and Site Characteristics: Visitor Serving Commercial Center 2-13 Table 2-5 Proposed Commercial Uses 2-13 Table 2-6 Summary of Project and Site Characteristics: Residential Village 2-16 Table 2-7 Residential Units 2-16 Table 2-8 Summary of Proposed Roadway Improvements 2-20 Table 2-9 Cumulative Projects 2-33 Table 3.1-1 General Plan Urban Design Element-Policies Applicable to Aesthetics 3.1-24 Table 3.1-2 General Plan Environmental Resources/Conservation Element-Policies Applicable to Aesthetics 3.1-25 Table 3.1-3 General Plan Coastal Element-Policies Applicable to Aesthetics 3.1-27 Table 3.1-4 Garage Exit and Potentially Affected Residential Use Elevations 3.1-43 Table 3.2-1 Summary of Ambient Air Quality in the Project Vicinity 3.2-4 Table 3.2-2 Existing Localized Carbon Monoxide Concentrations 3.2-6 Table 3.2-3 SCAG Regional Comprehensive Plan and Guide-Actions Applicable to Air Quality 3.2-8 Table 3.2-4 General Plan Air Quality Element-Policies Applicable to Air Quality 3.2-9 Table 3.2-5 Estimated Peak Daily Construction Emissions 3.2-13 Table 3.2-6 Project Daily Operational Emissions 3.2-15 Table 3.2-7 Future (2010) With Project Localized Carbon Monoxide Concentrations 3.2-16 Table 3.2-8 Daily Reduced Operational Emissions 3.2-19 Table 3.3-1 Plants Observed on the Project Site 3.3-3 Table 3.3-2 Wildlife Observed on the Project Site 3.3-5 Table 3.3-3 SCAG Regional Comprehensive Plan and Guide-Policies Applicable to Biological Resources 3.3-15 Table 3.3-4 General Plan Land Use Element-Policies Applicable to Biological Resources 3.3-15 Table 3.3-5 General Plan Environmental Resource/Conservation Element-Policies Applicable to Biological Resources 3.3-16 Table 3.3-6 General Plan Coastal Element-Policies Applicable to Biological Resources 3.3-18 Table 3.4-1 SCAG Regional Comprehensive Plan and Guide-Policies Applicable to Cultural Resources 3.4-12 Table 3.4-2 General Plan Historic and Cultural Resources Element-Policies Applicable to Cultural Resources 3.4-13 Table 3.4-3 General Plan Coastal Element-Policies Applicable to Cultural Resources 3.4-14 Table 3.5-1 General Plan Utilities Element-Policies Applicable to Energy and Mineral Resources 3.5-6 Table 3.5-2 General Plan Environmental Resources/Conservation Element-Policies Applicable to Energy and Mineral Resources 3.5-7 Table 3.5-3 General Plan Coastal Element-Policies Applicable to Energy and Mineral Resources 3.5-7 Table 3.5-4 Proposed Electricity Demand 3.5-9 Table 3.5-5 Proposed Natural Gas Demand 3.5-10 Pacific City EIR ix Contents Table 3.6-1 Relationship between Greatest Measure Intensity and Magnitude 3.6-4 Table 3.6-2 Nearest Regional Faults Affecting the Proposed Pacific City Site in Huntington Beach 3.6-5 Table 3.6-3 SCAG Regional Comprehensive Plan and Guide-Policies Applicable to Geology and Soils 3.6-13 Table 3.6-4 General Plan Environmental Hazards Element-Policies Applicable to Geology and Soils 3.6-14 -- Table 3.6-5 General Plan Coastal Element-Policies Applicable to Geology and Soils 3.6-15 Table 3.7-1 Historical On-Site Uses 3.7-2 Table 3.7-2 Historical Adjacent Uses 3.7-3 Table 3.7-3 Regulatory Database Search Results for Sites within One Mile 3.7-4 Table 3.7-4 General Plan Coastal Element-Policies Applicable to Hazardous Materials 3.7-14 Table 3.8-1 Pre-Development Drainage Conditions (Post-1986 Values) 3.8-6 Table 3.8-2 General Plan Utilities Element-Policies Applicable to Hydrology and - Water Quality 3.8-12 Table 3.8-3 General Plan Environmental Hazards Element-Policies Applicable to Hydrology and Water Quality 3.8-14 Table 3.8-4 General Plan Coastal Element-Policies Applicable to Hydrology and Water Quality 3.8-15 Table 3.8-5 General Plan Growth Management Element-Policies Applicable to Hydrology and Water Quality 3.8-16 Table 3.8-6 Summary of First Flush Discharges 3.8-20 Table 3.8-7 Projected Drainage Conditions (in cfs) 3.8-21 Table 3.9-1 SCAG Regional Comprehensive Plan and Guide-Policies Applicable to Land Use 3.9-4 Table 3.9-2 General Plan Land Use Element-Policies Applicable to Land Use 3.9-7 Table 3.9-3 General Plan Coastal Element-Policies Applicable to Land Use 3.9-13 Table 3.10-1 Representative Environmental Noise Levels 3.10-3 Table 3.10-2 Human Response to Different Levels of Groundborne Vibration 3.10-5 Table 3.10-3 Existing Daytime Noise Levels at Selected On- and Off-Site Locations 3.10-5 Table 3.10-4 Existing Roadway Noise Levels On Site 3.10-7 Table 3.10-5 Existing Roadway Noise Levels Off Site 3.10-8 Table 3.10-6 General Plan Noise Element-Policies Applicable to Noise 3.10-9 Table 3.10-7 City of Huntington Beach Noise Ordinance Exterior Noise Standards 3.10-13 Table 3.10-8 City of Huntington Beach Noise Ordinance Interior Noise Standards 3.10-13 Table 3.10-9 Noise Ranges of Typical Construction Equipment 3.10-15 Table 3.10-10 Typical Outdoor Construction Noise Levels 3.10-15 Table 3.10-11 Vibration Source Levels for Construction Equipment 3.10-16 -- Table 3.10-12 Predicted Future Roadway Noise Levels On Site 3.10-18 Table 3.10-13 Project Traffic Noise Impacts 3.10-20 Table 3.10-14 Cumulative Project Roadway Traffic Noise Impacts 3.10-21 Table 3.11-1 Population Growth: City of Huntington Beach(1980-2000) 3.11-2 Table 3.11-2 Households in Huntington Beach and Orange County (1990-2000) 3.11-3 Table 3.11-3 City of Huntington Beach Age Distribution in 2000 3.11-4 x City of Huntington Beach Contents Table 3.11-4 Housing Stock in the City of Huntington Beach 3.11-4 Table 3.11-5 Total Housing Units: City of Huntington Beach (1990-2000) Defined by Units per Structure 3.11-4 Table 3.11-6 Occupancy Status of Housing Stock in Huntington Beach in 2000 3.11-6 Table 3.11-7 RHNA Needs by Income Category for Huntington Beach (June 1, 1998, through June 30, 2005) 3.11-7 Table 3.11-8 SCAG Population, Households, and Employment Forecast 3.11-7 Table 3.11-9 Residential Sites Inventory 3.11-8 Table 3.11-10 Housing Growth Need and Development Potential by Income Group 3.11-9 Table 3.11-11 SCAG Regional Comprehensive Plan and Guide-Policies Applicable to Population and Housing 3.11-11 Table 3.11-12 General Plan Housing Element-Policies Applicable to Population and Housing 3.11-12 Table 3.11-13 Project Contribution to Population Increases 3.11-14 Table 3.11-14 Projected Project Employment 3.11-15 Table 3.12-1 Current School Enrollment of the Huntington Beach City School District....3.12-4 Table 3.12-2 Estimated Beach Attendance in Area 1 3.12-5 Table 3.12-3 SCAG Regional Comprehensive Plan and Guide-Policies Applicable to Public Services 3.12-6 Table 3.12-4 General Plan Public Facilities and Services Element-Policies Applicable to Public Services 3.12-7 Table 3.12-5 General Plan Growth Management Element-Policies Applicable to Public Services 3.12-8 Table 3.12-6 Additional Students Generated by Proposed Project 3.12-12 Table 3.13-1 Huntington Beach Recreational Facilities 3.13-3 Table 3.13-2 General Plan Recreation and Community Services Element-Policies Applicable to Recreation 3.13-5 Table 3.13-3 General Plan Coastal Element-Policies Applicable to Recreation 3.13-8 Table 3.13-4 General Plan Growth Management Element-Policies Applicable to Recreation 3.13-9 Table 3.14-1 Level of Service Definitions for Signalized Intersections (ICU Method) 3.14-16 Table 3.14-2 Level of Service Criteria for Signalized Intersections (HCM Method) 3.14-17 Table 3.14-3 Level of Service Criteria for Unsignalized Intersections (HCM Method) 3.14-17 Table 3.14-4 Existing Year 2001/02 Peak Hour Levels of Service 3.14-17 Table 3.14-5 Roadway Segment Capacities 3.14-20 Table 3.14-6 Year 2001 Existing Roadway Link Capacity Analysis Summary 3.14-20 Table 3.14-7 SCAG Regional Comprehensive Plan and Guide-Policies Applicable to Transportation/Traffic 3.14-23 Table 3.14-8 General Plan Circulation Element-Policies Applicable to Transportation/Traffic 3.14-24 Table 3.14-9 General Plan Growth Management Element-Policies Applicable to Transportation/Traffic 3.14-27 Table 3.14-10 Project Traffic Generation Forecast 3.14-29 Table 3.14-11 Related Projects Traffic Generation Forecast 3.14-39 Table 3.14-12 Year 2008 Peak Hour Intersection Levels of Service Summary 3.14-40 Pacific City EIR xi Contents i Table 3.14-13 Peak Hour Intersection Levels of Service Summary—Caltrans (HCM) 3.14-42 Table 3.14-14 Year 2008 Roadway Link Capacity Analysis Summary 3.14-49 Table 3.14-15 Year 2020 General Plan Buildout Peak Hour Intersection Levels of Service Summary—w/Hamilton Ext. w/Walnut Alignment w/SARC 3.14-53 Table 3.14-16 Year 2020 General Plan Buildout Roadway Link Capacity Analysis Summary w/Hamilton Ext. w/Walnut Alignment w/Santa Ana River Crossing 3.14-56 Table 3.14-17 Long-Term Parking Plan for Existing Off-Site Parking Spaces 3.14-69 Table 3.14-18 Project Access Driveways 3.14-75 Table 3.15-1 City of Huntington Beach Water Supply and Demand (in acre-feet) 3.15-3 Table 3.15-2 SCAG Regional Comprehensive Plan and Guide—Policies Applicable to Utilities and Service Systems 3.15-7 Table 3.15-3 General Plan Utilities Element—Policies Applicable to Utilities and Service Systems 3.15-7 Table 3.15-4 General Plan Coastal Element—Policies Applicable to Utilities and Service Systems 3.15-10 Table 3.15-5 General Plan Growth Management Element—Policies Applicable to Utilities and Service Systems 3.15-11 Table 3.15-6 Projected Water Demands for the Proposed Project 3.15-13 Table 3.15-7 Estimated Water Demand Types for the Proposed Project 3.15-14 Table 3.15-8 Projected Sewer Flows 3.15-17 Table 3.15-9 Proposed Solid Waste Demand 3.15-18 Table 4-1 Reduced Project Commercial Uses 4-14 Table 4-2 Reduced Project Alternative Daily Operational Emissions 4-17 Table 4-3 Comparison of Alternatives to the Proposed Project 4-27 VOLUME II-APPENDICES TO THE DRAFT ENVIRONMENTAL IMPACT REPORT Appendices Appendix A Initial Study/Notice of Preparation and Scoping Comments Appendix B Air Quality Data Appendix C Noise Data Appendix D Water and Sewer Materials Appendix E Hazardous Materials Appendix F Specific Plan Conformity Appendix G Drainage Study Appendix H Traffic Appendix I Biological Resources Information Appendix J Geotechnical Investigation Appendix K Shade and Shadow Diagrams Appendix L Cultural Resources xii City of Huntington Beach Contents VOLUME III-TEXT CHANGES AND RESPONSES TO COMMENTS Chapter 1 Introduction 1-1 1.1 CEQA Requirements 1-1 1.2 Public Review Process 1-1 1.3 Contents and Organization of the Final EIR 1-1 1.4 Use of the Final EIR 1-2 Chapter 2 Text Changes 2-1 - 2.1 Format of Text Changes 2-1 2.2 Text Changes 2-1 2.3 Figure Changes 2-174 2.4 Appendix Changes 2-181 Chapter 3 Responses to Comments 3-1 3.1 Organization of the Responses to Comments 3-1 3.2 Comments and Responses to Comments 3-2 3.3 Comments on the Draft EIR 3-3 3.4 Topical Responses 3-173 Topical Response on Water Quality 3-173 Topical Response on Traffic Generation 3-176 Topical Response on Shared Parking 3-180 Response to Comment Letter DOC (Department of Conservation, State of California, December 1, 2003) 3-183 Response to Comment Letter DOT(California Department of Transportation, December 3, 2003) 3-185 Response to Comment Letter DTSC (Department of Toxic Substances Control, November 4, 2003) 3-190 Response to Comment Letter CNB (Steven Bromberg, Mayor of the City of Newport Beach, December 3, 2003) 3-194 Response to Comment Letter HBUHSD (Huntington Beach Union High School District, October 27, 2003) 3-198 Response to Comment Letter OCPD (County of Orange Planning&Development Services Department, December 3, 2003) 3-199 Response to Comment Letter OCTA (Orange County Transportation Authority, December 3, 2003) 3-203 Response to Comment Letter SCAG (Southern California Association of Governments, November 25, 2003) 3-204 Response to Comment Letter HBEB (City of Huntington Beach Environmental Board, November 24, 2003) 3-205 Response to Comment Letter HBT (Huntington Beach Tomorrow, December 3, 2003) 3-210 Response to Comment Letter OCC (Orange County Coastkeeper, December 1, 2003) 3-212 Response to Comment Letter LBBS (Lewis Brisbois Bisgaard& Smith LLP, December 3, 2003) 3-216 Pacific City EIR xiii Contents Response to Comment Letter OEG (A) (Orosz Engineering Group, Inc., December 3, 2003) 3-224 Response to Comment Letter OEG (B) (Orosz Engineering Group, Inc., December 4, 2003) 3-226 Response to Comment Letter PCAC (Pacific City Action Coalition, December 3, 2003) 3-228 Response to Comment Letter PCAC (A) (Pacific City Action Coalition, Attachment A, December 3, 2003) 3-247 Response to Comment Letter PCAC (B) (Pacific City Action Coalition, Attachment B, December 3, 2003) 3-253 Response to Comment Letter PCAC (C) (Pacific City Action Coalition, Attachment C, December 3, 2003) 3-259 Response to Comment Letter RMC (Robert Mayer Corporation, December 3, 2003) 3-263 Response to Comment Letter RMC (A) (Kimley-Horn and Associates, Inc. (Attachment A to Robert Mayer Corporation Letter), December 2, 2003) 3-291 Response to Comment Letter RMC (B) (Richard Watson&Associates, Inc. (Attachment B to Robert Mayer Corporation Letter), December 2, 2003) 3-300 Response to Comment Letter Bixby(Mr. Mark D. Bixby, December 2, 2003) 3-306 Response to Comment Letter Cross (Mr. Paul Cross, November 14, 2003) 3-313 Response to Verbal Comments (Pacific City Draft EIR Public Meeting, November 13, 2003) 3-320 Response to Comment Churchin (Attachment to Verbal Comments) (Mr. Mike Churchin) 3-327 Response to Comment Card Bixby(A)Mr. Mark D. Bixby(November 13, 2003) 3-330 Response to Comment Card Brucculeri Mr. Frank C. Brucculeri(November 14, 2003) 3-331 Response to Comment Card Calonico Mr. Al Calonico (November 13, 2003) 3-332 Response to Comment Card Churchin(A) Mr. Mike Churchin (November 13, 2003) 3-333 Response to Comment Card Cross (A) Mr. Paul Cross (November 13, 2003) 3-334 Response to Comment Card Knox Ms. Laura Knox(November 13, 2003) 3-335 Response to Comment Card Mathis Ms. Faye S. Mathis (November 13, 2003) 3-336 Response to Comment Card Sisker Mr.John Sisker (November 13, 2003) 3-337 Figures Figure 2-5a (old) Common Open Space Diagram 2-175 Figure 2-5a (revised) Common Open Space Diagram 2-176 Figure 2-7 (old) Pedestrian Access and Circulation 2-177 Figure 2-7 (revised) Pedestrian Access and Circulation 2-178 —, Figure 3.9-1 (old) General Plan Land Use Map 2-179 Figure 3.9-1 (revised) General Plan Land Use Map 2-180 Tables Table 3-1 Comment Letters Received During the Draft EIR Comment Period 3-1 xiv City of Huntington Beach Chapter 1 INTRODUCTION 1.1 CEQA REQUIREMENTS Before approving a project, the California Environmental Quality Act (CEQA)requires the Lead Agency to prepare and certify a Final Environmental Impact Report (Final EIR). The contents of a Final EIR are f specified in Section 15132 of the CEQA Guidelines, which states that: The Final EIR shall consist of (a) The Draft EIR or a revision of the Draft (b) Comments and recommendations received on the Draft EIR either verbatim or in summary (c) A list of persons,organizations, and public agencies commenting on the Draft EIR (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process (e) Any other information added by the Lead Agency The Lead Agency (the City of Huntington Beach) must also provide each public agency that commented on the Draft EIR with a copy of the City's response to those comments at least 10 days before certifying the Final EIR. In addition, the City may also provide an opportunity for members of the public to review the Final EIR prior to certification, though this is not a requirement of CEQA. 1.2 PUBLIC REVIEW PROCESS The Draft EIR for the Proposed Pacific City project was circulated for review and comment by the public, agencies, and organizations for a 45-day public review period that began on October 17, 2003 and concluded on December 3, 2003. A Public Information Meeting was held on November 13, 2003 to receive comments on the adequacy of the Draft EIR, in which 40 verbal comments were received. In addition, 18 individual written comment letters were received during the review period. 1.3 CONTENTS AND ORGANIZATION OF THE FINAL EIR This Final EIR is composed of three volumes. They are as follows: Volume 1 Draft EIR—This Volume describes the existing environmental conditions on the project site, and in the vicinity of the project site; analyzes potential impacts on those conditions due to the proposed project; identifies mitigation measures that could avoid or reduce the magnitude of significant impacts; evaluates cumulative impacts that would Pacific City EIR 1-1 Chapter 1 Introduction be caused by the project in combination with other future projects or growth that could occur in the region; analyzes growth-inducing impacts; and provides a full evaluation of the alternatives to the proposed project that could eliminate, reduce, or avoid project- related impacts. Volume 2 Technical Appendices—This Volume includes supporting technical data used in the preparation of the Draft EIR. Refer to the Table of Contents provided in Volume 1 of this Final EIR for a complete list of Appendix titles. Volume 3 Text Changes and Response to Comments—This part contains an explanation of the format and content of the Final EIR; all text changes to the Draft EIR; a complete list of all persons, organizations, and public agencies that commented on the Draft EIR; copies of the comment letters received by the City of Huntington Beach on the proposed project; and the Lead Agency's responses to those comments. — 1.4 USE OF THE FINAL EIR The Final EIR allows the public and the City of Huntington Beach an opportunity to review the response to comments, revisions to the Draft EIR, and other components of the EIR, such as the MMP, prior to the City's decision on the project. The Final EIR serves as the environmental document to support approval of the proposed project, either in whole or in part. After completing the Final EIR, and before approving the project, the Lead Agency must make the following three certifications as required by Section 15090 of the CEQA Guidelines: • That the Final EIR has been completed in compliance with CEQA • That the Final EIR was presented to the decision-making body of the Lead Agency, and that the decision-making body reviewed and considered the information in the Final EIR prior to approving the project • That the Final EIR reflects the Lead Agency's independent judgment and analysis Additionally, pursuant to Section 15093(b) of the CEQA Guidelines, when a Lead Agency approves a project that would result in significant, unavoidable impacts that are disclosed in the Final EIR, the agency must state in writing its reasons for supporting the approved action. This Statement of Overriding Considerations is supported by substantial information in the record, which includes this Final EIR. Since the proposed project could result in significant, unavoidable impacts, the City of Huntington Beach would be required to adopt a Statement of Overriding Considerations if it approves the proposed project. These certifications, the Findings of Fact, and the Statement of Overriding Considerations are included in a separate Findings document. The Final EIR will be considered, and , in conjunction with making Findings, the City of Huntington Beach may decide whether or how to approve the proposed project. 1-2 City of Huntington Beach Chapter 2 TEXT CHANGES 2.1 FORMAT OF TEXT CHANGES Text changes are intended to clarify or correct information in the Draft EIR in response to comments received on the document, or as initiated by Lead Agency staff. Revisions are shown in Section 2.2 below as excerpts from the Draft EIR text, with a deleted text and an underline beneath inserted text. In order to indicate the location in the Draft EIR where text has changed, the reader is referred to the page number of the Draft EIR. 2.2 TEXT CHANGES This section includes revisions to text, by Draft EIR Section, that were initiated either by Lead Agency staff, or in response to public comments. The changes appear in order of their location in the Draft EIR. Pacific City EIR 2-1 Chapter 2 Text Changes "'' *S'o'r " $ *'"sy rf `.xK""` ^, y" • k„' • t r0 5 '+' :Y•.t• h- ;• - ; Paget, xecuktumma�ry Tabled •Surnm •Ptxposc�Roarl�tprn,� n ' � Table ES-3 Summary of Proposed Roadway Improvements Roadway Proposed Project Improvements Pacific Coast Dedicate ROW north of centerline Highway Widen PCH on north side for provision of a third westbound through lane and future bike lane Remove parallel parking on north side of roadway and replace on-site Close existing median opening and install median landscaping along a portion of PCH,between First and Huntington Streets Pedestrian site access to commercial component Additional North-South crosswalk at the northeast corner of PCH and First Street Grade-separated pedestrian overcrossing over PCH to beach area could be constructed in the future Provide an Orange County Transportation Authority bus turnout on the north side of PCH,west of Huntington Street Atlanta Avenue Dedicate ROW between First Street and Huntington Street,south of centerline Additional eastbound travel lane Sidewalk,curb and gutter,paving,and a landscaped median between First and Huntington Streets Pedestrian access to residential component Huntington Street Dedicate ROW between Pacific View Avenue and Pacific Coast Highway,west of centerline Additional southbound travel lane between PCH and Pacific View Southbound right turn lane at PCH Provide traffic signal at intersection with Atlanta Avenue Landscaped median between Pacific View Avenue and PCH Sidewalk,curb,gutter,and paving between Pacific View Avenue and Atlanta Avenue Vehicular service access to commercial component Vehicular resident-only access to residential component Pedestrian access to residential component First Street Dedicate ROW east of centerline between Atlanta and Pacific View Avenue for an ultimate configuration with a 100-foot- wide right-of-way Additional southbound and northbound travel lane between PCH and Atlanta Additional southbound left-turn lane onto PCH Sidewalk,curb and gutter,paving,and landscaped medians Vehicular service access to commercial component Vehicular resident-only access to residential component Pedestrian access to residential component Pacific View Extension of roadway,which currently exists only from Huntington Street to approximately 500 feet east along the existing Avenue Waterfront Hilton project,through site in a 90-foot rightef-wayROW,in compliance with the Precise Plan of Street Alignment. Ultimate Condition: Primary Arterial Street Four-lane divided cross section within the 90 foot ROW. No angled parking Some on-street parallel parking Interim Condition: Parallel parking on north side of street for the proposed public park One lane of traffic in each direction with a center turning lane,ell-street bike-lanes and pedestrian crosswalks Angled parking on south side of roadway Sidewalk,curb and gutter,paving,and raised landscaped medians Three vehicular accesses to commercial component(two public and one service) Two vehicular accesses to residential component(residents and guests) Pedestrian access to residential and commercial components SOURCE. Makallon Atlanta Huntington Beach,LLC,July 7,2003b 2-2 City of Huntington Beach Chapter 2 Text Changes fin:... n x x �: x �a a ya.., „ Ira e xi.° able E5-4 umrna {Im act Cabje�„ select agest<e • ; Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact Aesthetics Impact AES-1: Implementation of the proposed project would not None required. Less than substantially degrade scenic resources within Pacific Coast Highway, significant a State Scenic Highway. Impact AES-2: Implementation of the proposed project would not None required. Less than have a substantial effect on the scenic vista. significant Impact AES-3: Implementation of the proposed project would not None required. Less than substantially degrade the existing visual character or quality of the significant project site and its surroundings. Impact AES-4: The proposed project would cast shadows on None required. Less than surrounding residential uses. significant Impact AES•5:Structural development would introduce new sources MM AES•1.To the extent feasible,the Applicant shall use nonreflective facade treatments,such as matte paint or Less than of light and glare into the project vicinity. glass coatings. Building materials shall be consistent with the City Urban Design Guidelines,and reflective glass significant shall not constitute a primary exterior material. Prior to issuance of building permits for the proposed project,the Applicant shall indicate provision of these materials on the building plans. Impact AES-6:Structural development would not result in significant The following measure is recommended to further reduce less-than-significant impacts: Less than nighttime lighting in the proiect vicinity. MM AES-2:The lighting plan shall include provisional measures to limit nighttime illumination during periods of fog. si ng ificant Measures may include but would not be limited to reduced foot-candle illumination levels or reduced number of lighting fixtures in use. Impact AES-67• Implementation of the proposed project would None required. Less than introduce new sources of vehicle headlight,although they would not significant significantly affect adjacent sensitive uses. The following standard City requirements(CR)would apply to the project. CR AES-A All exterior mechanical equipment shall be screened from view on all sides.Rooftop mechanical equipment shall be setback 15 feet from the exterior edges of the building.Equipment to be screened includes,but is not limited to,heating,air conditioning,refrigeration equipment,plumbing lines,ductwork and transformers.Said screening shall be architecturally compatible with the building in terms of materials and colors.If screening is not designed specifically into the building,a rooftop mechanical equipment plan showing screening must be submitted for review and approval with the application for building permit(s). CR AES-B If outdoor lighting is included,energy saving lamps shall be used.All outside lighting shall be directed to prevent"spillage"onto adjacent properties and shall be shown on the site plan and elevations. CR AES-C All landscape irrigation and planting installation shall be certified to be in conformance to the City approved landscape plans by the Landscape Architect of record in written form to the City Landscape Architect prior to the final landscape inspection and approval. CR AES-D Prior to occupancy,all new and existing overhead utilities shall be installed underground in accordance with the City's Underground Utility Ordinance.In addition,all electrical transformers shall be installed underground. Air Quality Impact AQ-1.Peak construction activities associated with the MM AQ-1:The project developer(s)shall require by contract specifications that construction equipment engines will Significant proposed project could generate emissions that exceed SCAQMD be maintained in good condition and in proper tune per manufacturer's specification for the duration of construction. and thresholds. Contract specification language shall be reviewed by the City prior to issuance of a grading permit. unavoidable Pacific City EIR 2-3 Chapter 2 Text Changes • is• 2H"• r i n e a r; a x e xxvinTable Summary imsac•Table selecteri pages ` -. :. A �s....�.:,.r.>,� .trms�t�s::.�,rc�i���.pa;;�:k'r�a� �r...t�� a!: �t;sa...���rr�.-.d.:€.,.::..�.w.... <... . .�� •sa:.: .. .. .:�. a.. ,:a::�>- .� .. .., Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact Impact AQ-2: Daily operation of the project would generate MM AQ-6:The project developer shall include in construction and sales contracts the following requirements Significant emissions that exceed SCAQMD thresholds. or measures shown to be equally effective to reduce project-related stationary and area source emissions: and • Use solar or low-emission water heaters in the residential,office,and visitor-serving commercial buildings unavoidable • Provide energy-efficient heating with automated controls in the residential, office, and visitor-serving commercial buildings • Use energy-efficient cooking appliances in the in the residential and visitor-serving commercial buildings • If fire places are provided in new residential units, install the lowest-emitting fireplaces commercially available at the time of development • Require that contract landscapers providing services at the project site use electric or battery-powered equipment,or internal combustion equipment that is either certified by the California Air Resources Board or is three years old or less at the time of use. Contract specification language shall be reviewed by the City prior to issuance of a grading-building permit. MM AQ-7: The project developer shall include in construction and sales contracts for the commercial and offices uses on site that preferential parking spaces be provided for carpools and vanpools. Contract specification language shall be reviewed by the City prior to issuance of a grading-building permit.A minimum of 7'2"of vertical clearance shall be provided in the parking structure for vanpool access. Inclusion of the vertical clearance shall be verified on building plans prior to issuance of a building permit. Impact AQ-3: The proposed project would generate increased None required. Less than local traffic volumes, but would not cause localized CO - significant concentrations at nearby intersections to exceed national or State standards. Impact AQ-4:The proposed project would provide new sources None required. Less than of regional air emissions, but would not impair implementation of significant the Air Quality Management Plan. Impact AQ-5: Implementation of the proposed project could None required. Less than release toxic air contaminants,but not in significant amounts. significant 2-4 City of Huntington Beach Chapter 2 Text Changes x <:: ..gy .k ,..:> ; ;., - : ;"'. rrr "'f .,ate • XXYII Viable S-4::Summa :=1t7ti} � r'''�E,:: Str G.. I«j S LS ;: � s � .. R'�:d:..�•5:....> "�,���v� �:�v,a���3sA�Y �«3','3°3;, r� .v. �: .: 'w«m:...m� "' �. ; ��> ::S�;S.?�:,:t�iF��ux�". � • .,.�.3�`3. s«.c:..,h�..:e.::...,. :zai�.:.r: :s�a ....,,' .,a�,�.'fw.....�....::, , .....�.. ..... �: F.: Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact The following standard City requirements(CR)would apply to the project.CR AQ-A through CR AQ-C shall be completed prior to issuance of a grading permit. CR AQ-A The name and phone number of an on-site field supervisor hired by the developer shall be submitted to the Departments of Planning and Public Works prior to issuance of grading permits.In addition,clearly visible signs shall be posted on the perimeter of the site every 250 feet indicating who shall be contacted for information regarding this development and any construction/grading-related concerns.This contact person shall be available immediately to address any concerns or issues raised by adjacent property owners during the construction activity.He/She will be responsible for ensuring compliance with the conditions herein,specifically,grading activities,truck routes,construction hours,noise,etc.Signs shall include the Applicant's contact number regarding grading and construction activities,and"1-800-CUTSMOG"in the event there are concerns regarding fugitive dust and compliance with AQMD Rule No.403. CR AQ-B The Applicant shall notify all property owners and tenants within 500398 feet of the perimeter of the property of a tentative grading schedule at least 30 days prior to such grading. CR AQ-C The Applicant shall demonstrate that the gradinglerosion control plan will abide by the provisions of AQMD's Rule 403 as related to fugitive dust control,prior to issuance of grading permits. CR AQ-D through CR AQ-F shall be implemented during grading and construction operations: CR AQ-D The construction disturbance area shall be kept as small as possible. CR AQ E Wind barriers shall be installed along the perimeter of the site and/or around areas being graded:.- CR AQ-F Remediation operations,if required,shall be performed in stages concentrating in single areas at a time to minimize the impact of fugitive dust and noise on the surrounding areas. Biological Resources Impact BI0-1:Proposed project implementation may result in MM BI0.1:If before the start of construction,substantial growth of native vegetation or sensitive habitats has occurred Less than impacts on special status plant species,if present on the on the project site as determined by a qualified biologist,then special status plant or habitat surveys shall be significant proposed project site. conducted during the appropriate time of the year prior to construction of the proposed project,to determine the presence or absence of special status plant species or habitats.These surveys shall be conducted during the appropriate blooming period as determined by a qualified biologist.If any of these species are found to be present on the proposed project site,then measures would be developed in consultation with the appropriate resource agencies,if the status of the species and the size of the population warrant a finding of significance.Appropriate measures may include avoidance of the populations,relocation,or purchase of offsite populations for inclusion to nearby open space areas.A City-qualified biologist shall present recommendations to the city for review and approval.Any subsequent avoidance,relocation,or other mitigation strategies required to reduce impacts to a less-than-significant level shall be implemented prior to issuance of a grading permit. Impact BI0.2:Proposed project implementation would not None required. Less than significantly impact special status wildlife species. significant Impact BI0-3:Proposed project implementation would be None required. Less than consistent with local policies or ordinances protecting biological significant resources. Impact BI0-4:The project would not have an adverse effect on None required. No impact federally protected wetlands as defined by Section 404 of the Clean Water Act. Pacific City EIR 2-5 Chapter 2 Text Changes rrs� e�xxuiiil ebieE 4"" umma�rl ait F1 " .electedfpsges .. Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact Impact BIOS:Implementation of the project would not significantly None required. Less than impact sensitive habitat types,including wetlands as defined by the significant CDFG. Impact BI0-6:Construction activities at the project site would not The following mitigation measure is recommended to further reduce less-than-significant impacts: Less than significantly disturb wildlife in the project site vicinity MM BIO 2:Grading shall begin at the perimeter,near existing residences,and proceed toward the center of the site. significant Impact BIO.7:An increase in night lighting from the proposed project None required. Less than would not significantly affect behavioral patterns of wildlife at the significant project site. Cultural Resources Impact CR-1:Paleontological resources that could be located on-site MM CR-1:Monitor grading and excavation for archaeological and paleontological resources: Less than would be adversely affected by earth-moving activities that could (a)The Applicant shall arrange for a-qualified(as defined by the Oranqe County Archaeoloqical/Paleontological significant damage these materials. Curation Project)professional archaeological and paleontological monitor to be present during demolition,grading, trenching,and other excavation on the project site.The Applicant shall also contact the appropriate Gabrielino and Juaneno tribal representatives to determine whether either group desires Native American monitoring of grading activities.If Native American monitors are requested,the Applicant shall arrange for the-monitoring with tribal representatives.Additionally,prior to project construction,construction personnel will be informed of the potential for encountering significant archaeological and paleontological resources,and instructed in the identification of fossils and other potential resources.All construction personnel will be informed of the need to stop work on the project site until a qualified archaeologist or paleontologist has been provided the opportunity to assess the significance of the find and implement appropriate measures to protect or scientifically remove the find.Construction personnel will also be informed of the requirement that unauthorized collection of cultural resources is prohibited. (b)If archaeological or paleontological resources are discovered during earth moving activities,all construction activities within 50 feet of the find shall cease until the archaeologist/paleontologist evaluates the significance of the resource.In the absence of a determination,all archaeological and paleontological resources shall be considered significant.If the resource is determined to be significant,the archaeologist or paleontologist,as appropriate,shall prepare a research design for recovery of the resources in consultation with the State Office of Historic Preservation that satisfies the requirements of Section 21083.2 of CEQA,as well as Chapter 3 and Appendices E,F,and G of the Curation Project.The archaeologist or paleontologist shall complete a report of the excavations and findings, and shall submit the report for peer review by three County-certified archaeologists or paleontologists,as appropriate.Upon approval of the report,the Applicant shall submit the report to the South Central Coastal Information Center at California State University,Fullerton,the California Coastal Commission,and-the City of Huntington Beach,the Oranqe County Archaeo/Paleo Resource Management Facility(APRMF),and the Orange County Historic Programs Office. (c)Monitored grading at the location of CA-ORA-1582H shall involve the removal of refuse deposit in 15 to 20 cm layers using a skip loader.All materials shall be deposited in small to medium piles for scanning by archaeologists for diagnostic materials.If the resource encountered consists of complete or nearly complete artifacts from CA- ORA-1582H,then artifacts shall be cleaned and cataloged,in accordance with the requirements of the Curation Project,for curation at a facility within Oranqe County that is acceptable to the City of Huntington Beach.The applicant shall be responsible for payment of all applicable curation fees,and the curation contract shall specify that materials shall be available for loans to educational institutions_,and-ne No further study would be required. 2-6 City of Huntington Beach Chapter 2 Text Changes ma's '' s f'R'"w r �. "` , rx a, f a a bi Sum tar+1�m aGt�Tab(e eEe e�. +� a .<... .. �� � : Table ES=4 Summary Impact Table Residual Impact Mitigation Measure Impact (d) In the event of the discovery on the project site of a burial,human bone,or suspected human bone,all excavation or grading in the vicinity of the find will halt immediately and the area of the find will be protected.If a qualified archaeologist is present,he/she will determine whether the bone is human.If the archaeologist determines that the bone is human,or in the absence of an archaeologist,the Applicant immediately will notify the City Planning Department and the Orange County Coroner of the find and comply with the provisions of P.R.C.Section 5097 with respect to Native American involvement,burial treatment,and reburial. Impact CR-2:Construction of the proposed project would cause a MM CR-2:Scientific recovery of archaeological resources associated with CA ORA 149:The Applicant shall retain a Less than substantial adverse change in the significance of CA-ORA-149,a qualified archaeologist('ti.,listed o..the Registry f Professional rchao logistsas defined by the Orange County significant prehistoric archaeological site. Archaeological/Paleontological Curation Proiect)to develop and implement,in consultation with the State Office of Historic Preservation,a research design and recovery plan for remaining elements of CA ORA 149.The recovery plan shall emphasize data collection in Locus A,between Test Units 1 and 2,as well as on a core area of Locus B, centered around Test Unit 4,and shall be designed to satisfy the requirements of Section 21083.2 of CEQA,as well as Chapter 3 and Appendices E,F,and G of the Curation Project. Impact CR-3:Construction of the proposed project could cause a MM CR-1 as indicated above. Less than substantial adverse change in the significance of previously unknown significant archaeological resources,including human burials,that could be present on the project site. Impact CR-4:Construction of the proposed project would not cause None required. Less than a substantial adverse change in the significance of CA-ORA- significant 1582H—a historical archaeological dump site. Energy and Mineral Resources Impact EM-1: Implementation of the proposed project would not The following mitigation measure is recommended to further reduce less-than-significant impacts: Less than substantially increase electricity demands beyond available supply or MM EM-1:The proposed project shall implement an energy conservation plan that could include,but would not be significant result in attracting additional or higher density development to the limited to,measures such as energy efficient lighting,and heating,ventilation,and air conditioning systems(HVAC) project area. controls to reduce the demand of electricity and natural gas. The energy conservation plan shall be subject to review and approval by the City Building and Safety and Planning Departments prior to the issuance of building permits. Impact EM-2: Implementation of the proposed project would not The following mitigation measure is recommended to further reduce less-than-significant impacts: Less than substantiallyincrease naturalgas demands beyond available supply significant y pp y MM EM-1 as indicated above. or result in attracting additional or higher density development to the project area. Impact EM-3: Implementation of the proposed project would not None required. Less than result in the loss of availability of a known mineral resource or the significant loss of availability of a locally important mineral resource recovery site. Pacific City EIR 2-7 Chapter 2 Text Changes Pabte Sumary'ima'�ctble selcdg � :, . f .: .53° . Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact Geology and Soils Impact GEO-1: Project implementation could expose people or MM GE0.1•The grading plan prepared for the proposed project shall contain the recommendations of the final soils Less than structures on-site to strong seismic ground shaking and seismic- and geotechnical analysis prepared pursuant to CR GEO-A,as approved by the City.These recommendations shall significant related ground failure associated with liquefaction. be implemented in the design of the project,including but not limited to measures associated with site preparation, fill placement and compaction,seismic design features,excavation stability and shoring requirements,dewatering, establishment of deep foundations,concrete slabs and pavements,cement type and corrosion measures,surface drainage, erosion control, ground improvements, tsunami protection, and plan review. All geotechnical recommendations provided in the soils and geotechnical analysis shall be implemented during site preparation and construction activities. Impact GE0.2: Project implementation would locate structures on MM GEO-1 as indicated above. Less than soils that are considered potentially expansive, unstable, prone to significant settlement,and corrosive. Impact GEO.3: Construction activities would temporarily increase None required. Less than soil exposure to wind and water erosion. significant The following standard City requirements(CR)would apply to the project. CR GEO-A Prior to recordation of the final map,a qualified,Licensed Engineer shall prepare a detailed soils and geotechnical analysis.This analysis shall include Phase II Environmental on-site soil sampling and laboratory testing of materials to provide detailed recommendations for grading,chemical and fill properties,liquefaction,foundations,landscaping,dewatering,ground water, retaining walls,pavement sections and utilities. Hazardous Materials Impact HAZ-1: Grading and excavation of the site could expose MM HAZ•1• Prior to the issuance of a grading permit, a Registered Environmental Assessor shall perform a site Less than construction personnel and the public to contamination present in the inspection to identify the potential for presence of PCBs on the site. If the potential for PCBs exists, then the significant soil associated with former on-site uses. Applicant shall, in consultation with the City of Huntington Beach, sample soil surrounding the affected areas to identify the extent of contamination.Contamination shall be remediated in accordance with MM HAZ-3 and HAZ-4. MM HAZ-2: Prior to the issuance of a grading permit,sampling shall be performed in the area identified in Figure 3.7-1 as"Area D."The extent of sampling shall be determined by the Huntington Beach Fire Department as that which is appropriate to characterize the extent of any potential contamination in Area D. Contamination shall be remediated in accordance with MM HAZ-3 and HAZ-4. MM HAZ-3: Prior to issuance of a grading permit,the Applicant shall,in consultation with the City of Huntington Beach and other agencies,as required,formulate a remediation plan for further soil contamination that exists on the project site.The plan shall include procedures for remediation of the project site to the City of Huntington Beach standards.Plans shall be submitted to the Planning,Public Works,and-Fire Departments for review and approval k the Planning,Public Works,and Fire Departments in accordance with City Specification No.431-92.The plan shall include methods to minimize remediation-related impacts on the surrounding properties, including processes by which all drainage associated with the remediation effort shall be retained on site and no wastes or pollutants shall escape the site and requirements to provide wind barriers around remediation equipment. Qualified and licensed professionals shall perform the remediation activities and all work shall be performed under the supervision of the City of Huntington Beach. 2-8 City of Huntington Beach - Chapter 2 Text Changes �; a xfe sele ked1 e . „, � ,�s�u�'.Q:s�..x.«..�..vus.� -^- :.�.C :wxe..�mow. 3..:�. .:r_ ...;A�. �... .�v ,.a..���a:�. ..r._:..,:, � �..:n ; Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact MM HAZ-4:Closure reports or other reports acceptable to the City Fire Department that document the successful completion of required remediation activities for contaminated soils, in accordance with City Specification 431-92, shall be submitted and approved by the City Fire Department prior to issuance of grading permits for site development.No construction shall occur on-site until reports have been accepted by the City.Closure reports will not be required in the area identified in Figure_3.7-1 as"Area C"until remediation of this area has occurred as part of project construction;these reports will be required pursuant to MM HAZ-6.If remediation is necessary pursuant to MM HAZ-3,then grading-soil remediation permits for this remediation shall be issued. MM HAZ-5:In the event that previously unknown soil contamination that could present a threat to human health or the environment is encountered during construction, construction activities in the immediate vicinity of the contamination shall cease immediately. A risk management plan shall be prepared and implemented that (1) identifies the contaminants of concern and the potential risk each contaminant would pose to human health and the environment during construction and post-development and(2)describes measures to be taken to protect workers and the public from exposure to potential site hazards.Such measures could include a range of options,including, but not limited to, physical site controls during construction, remediation, long-term monitoring, post-development maintenance or access limitations,or some combination thereof.Depending on the nature of contamination,if any, appropriate agencies shall be notified (e.g., City of Huntington Beach Fire Department).A site health and safety plan that meets OSHA requirements shall be prepared and in place prior to the commencement of work in any contaminated area.The developer shall ensure proper implementation of the health and safety plan. MM HAZ-6:Closure reports documenting the successful completion of required remediation activities for(1)areas adjacent to the existing water main on site and (2) areas of archaeological sensitivity shall be submitted and approved by the City Fire Department prior to issuance of building permits in these areas. Impact HAZ-2: Grading and excavation of the site could result in MM HAZ-7•Where construction is proposed over abandoned oil wells,the developer shall consult with DOGGR to Less than damage to existing abandoned oil wells. determine if plug or replug of wells is necessary.Prior to the issuance of grading permits,the Applicant shall submit significant evidence of consultation with DOGGR indicating wells have been plugged or abandoned to current DOGGR standards. MM HAZ-8: In the event that abandoned oil wells are damaged during construction, construction activities shall cease in the immediate vicinity immediately Remedial plugging operations would be required to re-plug the affected wells to current Department of Conservation specifications. Depending on the nature of soil contamination, if any, appropriate agencies shall be notified(e.g.,City of Huntington Beach Fire Department).The developer shall ensure proper implementation of the reabandonment operation in compliance with all applicable laws and regulations. Impact HAZ-3: No residual contamination is anticipated that would None required. Less than affect visitors and residents of the proposed project. significant Pacific City EIR 2-9 Chapter 2 Text Changes z M hT_a hT ac a s 'ect r gam : �.: Pag xxjc rY Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact The following standard City requirements(CR)would apply to the project. CR N-A Construction shall be limited to Monday—Saturday 7:00 AM to 8:00 PM.Construction shall be prohibited Sundays and Federal holidays. CR N-B The Applicant shall notify all property owners and tenants within 300500 feet of the perimeter of the property of a tentative grading schedule at least 30 days prior to such grading. CR N-C The developer shall coordinate the development of a truck haul route with the Department of Public Works if the import or export of material is required. This plan shall include the approximate number of truck trips and the proposed truck haul routes.It shall specify the hours in which transport activities can occur and methods to mitigate construction-related impacts to adjacent residents.These plans must be submitted for approval to the Department of Public Works prior to issuance of a precise grading permit. CR N-D All haul trucks shall arrive at the site no earlier than 8:00 a.m.or leave the site no later than 5:00 p.m.,and shall be limited to Monday through Friday only. CR N-E Neighbors within 200500 feet of major construction areas shall be notified of the construction schedule in writing prior to construction;the project sponsor shall designate a"disturbance coordinator"who shall be responsible for responding to any local complaints regarding construction noise;the coordinator(who may be an employee of the developer or general contractor) shall determine the cause of the complaint and shall require that reasonable measures warranted to correct the problem be implemented;and a telephone number for the noise disturbance coordinator shall be posted conspicuously at the construction site fence and included on the notification sent to neighbors adjacent to the site. Population and Housing Impact P-1• Implementation of the proposed project would not None required. Less than directly or indirectly induce substantial population growth beyond significant current growth projections established by the City. Impact P-2:Proposed housing would not directly or indirectly induce MM P•1: The Applicant shall prepare an Affordable Housing Program to the satisfaction of the City Planning & Less than substantial population growth beyond current growth projections Economic Development Departments. The Program shall detail the provisions for either on-or off-site affordable significant established by the City, although the required number of affordable housing, or a combination of the two that meet the requirements of Community Redevelopment Law and City housing units may not be provided on-site by the project. requirements. The Affordable Housing Program shall be submitted to the Planning Department for review and approval prior to submittal of the final map. The agreement shall be executed prior to the issuance of the first building permit for the residential project.The Applicant shall adhere to all provisions of the Program. Public Services Impact PS•1:The current staff and equipment of the HBFD would be MM PS•1:Provide enclosed,fire-rated stairs to each subterranean level from the exterior every 300'lineal feet of Less than sufficient to meet the demands of the proposed project, although the building perimeter significant project design may not provide adequate pedestrian emergency MM PS-2:Project design shall include ventilation of smoke and products of combustion.Zoned,mechanical smoke access. removal system,with manual controls for firefighters shall be located in the fire control room.An emergency power source is necessary and the system shall also comply with Building Code requirements to exhaust CO and other hazardous gases. MM PS-3: Dedicated rooms for Fire Department exclusive use to observe, monitor and as necessary control all emergency systems operation shall be provided.A total of three rooms shall be provided as follows:(1)commercial area and the related subterranean parking garage; (2)high-rise hotel; and (3) residential garages and dwellings. Rooms shall be located in an exterior location at grade level and have unrestricted access clear-to-the sky. 2-10 City of Huntington Beach Chapter 2 Text Changes age a writhe tA*Mril r I�mpa tx, a to"s�lecte pages.. 1 w s r Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact Impact PS-2:The proposed project would add residential and visitor- The following mitigation measure is recommended to further reduce less-than-significant impacts: Less than serving uses to the area, and would increase demands on police MM PS-4: Prior to issuance of a building permit, the Applicant shall consult the Huntington Beach Police significant protection. Department regarding the provision of adequate Crime Prevention Design measures, and shall incorporate the Department's recommendations into the plan. Impact PS-3:Development of additional residential units would result MM PS-5: The developer for the proposed project shall negotiate with the City school districts regarding school Less than in an increase in the number of students within the school districts impact fees to address the adverse impacts of the development,thus,ensuring that the new development would significant serving the site,and increase demands on school facilities. bear its fair share of the cost of housing additional students generated.The Planning Department shall be provided with a copy of the agreement prior to recordation of the final map. Impact PS-4:Existing lifeguard services would be adequate to serve The following mitigation measure is recommended to further reduce less-than-significant impacts: Less than increased use of the beach area resulting from additional residential MM PS-6: The Applicant shall develop and institute a Beach Safety and Maintenance Awareness Program to be significant and visitor-serving uses. reviewed and approved by the Community Services Department. The Program shall include (1) informational disclosures(i.e.,handouts)to all residents and hotel guests and(2)posting of signs on site.Program materials shall include but would not be limited to the following items: ■ Beach safety guidelines related to swimming,tides,sun exposure,and other potential risks from beach use • City Regulations on the use of beach property,including permissible uses of the beach and appropriate trash disposal • Identification of penalties imposed for violation of City Regulations The City shall ensure strict enforcement of regulations related to beach use and maintenance. The following standard City requirements(CR)would apply to the project. CR PS-A Automatic sprinkler systems shall be installed throughout.Shop drawings shall be submitted and approved by the Fire Department prior to system installation.(FD) CR PS-B Fire hydrants must be installed before combustible construction begins. Prior to installation, shop drawings shall be submitted to the Public Works Department for review and approved approval by the Public Works and Fire Departments.(Fire Dept.City Specification 407).(FD) CR PS-C Prior to issuance of building permits,fire access roads shall be provided in compliance with Fire Dept.City Specification 401.Include the Circulation Plan and dimensions of all access roads. Fire lanes will be designated and posted to comply with Fire Dept.City Specification No.415.(FD) CR PS-D The development shall comply with all applicable provisions of the Municipal Code, Building Department,and Fire Department as well as applicable local, State,and Federal Fire Codes, Ordinances,and standards. Note:This requirement also applies to other resources such as geology and hazards. Recreation Impact REC-1: Project implementation would not provide adequate MM REC-1: The Applicant shall demonstrate compliance with City parkland requirements identified in Chapter Less than recreational facilities to meet increased demands from the project. 254.08 of the City of Huntington Beach Municipal Code.Any on-site park provided in compliance with this section significant shall be improved prior to final inspection(occupancy)of the first residential unit(other than the model homes). Impact REC-2: Construction effects associated with on-site None required. Less than recreational facilities would not significantly affect the environment significant over the short term. Pacific City EIR 2-11 Chapter 2 Text Changes )' ., ry impact Table,"se ette < a esx iPa'e°x�au�l able i umma,�. E g' . Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact Transportation/Traffic Impact TR-1. Under Year 2008 conditions, implementation of the MM TR-1 The Applicant shall contribute a fair share contribution of 22 percent'to the installation of a third northbound Significant and proposed project would significantly affect the operating conditions of the through lane on PCH consistent with the Orange County MPAH and Caltrans Route Concept Study for PCH.The County of unavoidable intersection of PCH at Warner Avenue by increasing traffic volume. Orange and Caltrans would complete this improvement. The Applicant's fair share contribution shall be paid prior to issuance of athe first certificate of occupancy. Impact TR-2: Under Year 2008 conditions, implementation of the MM TR-2:A second westbound right turn lane shall be added on Seapoint Avenue.The City shall ensure completion of this Less than proposed project would significantly affect the operating conditions of the improvement, and the Applicant shall contribute a fair share contribution of 26 percentz to this improvement. The significant intersection of PCH at Seapoint Avenue by increasing traffic volume Applicant's fair share contribution shall be paid prior to issuance of athe first certificate of occupancy. under Caltrans Methodology. Impact TR-3: Under Year 2008 conditions, implementation of the None required. Less than proposed project would not significantly adversely affect the operating significant conditions of roadway segments by increasing traffic volume. Impact TR-4:Under the Year 2020 conditions with scenario No.1 (with MM TR-2 as indicated above. Less than the Hamilton Avenue Extension, Walnut Avenue Alignment, and Santa significant Ana River Crossings), the proposed project would adversely affect the operating conditions of the intersection of PCH at Seapoint Avenue by increasing traffic volume. Impact TR-5: Under the Year 2020 conditions with scenario No. 1 (with None required. Less than the Hamilton Avenue Extension, Walnut Avenue Alignment, and Santa significant Ana River Crossings),the proposed project would not adversely affect the operating conditions of roadway segments by increasing traffic volume. Impact TR-6:Project-generated traffic would require the addition of traffic MM TR-3:Install a traffic signal at First Street and Atlanta Avenue prior to issuance of occupancy permits.The City shall Less than signals. provide reimbursement for the balance of the funding of improvements through the Fair Share Traffic Impact Fee account significant or shall designate credits against the protect fees to that account.The City shall ensure completion of this improvement, and the Applicant shall contribute a fair share contribution of 57 percent3 to the improvement. Impact TR-7• Implementation of the proposed project would not None required. Less than adversely affect the operating conditions of nearby facilities or streets that significant are part of the Congestion Management Program Highway System (CMPHS). Impact TR-8:The proposed project would provide adequate parking. None required. Less than significant r Fair share calculation is provided in Appendix H,Traffic Impact Analysis Report. 2 Ibid. 3 Ibid. 2-12 City of Huntington Beach - Chapter 2 Text Changes • ,ra - I'm £ %.s �, .v, :. S" 4 F''s ,k .c ".rp:.• s SIC'•,.' w ...„.. �r.,".":,'fir :. .a .. [�age`xxxvll Table ES-45um�nry�Imact Table s [ecteo pSg ..x3,k:_..�"'fur:.>. '.-��..,..a...�ak&a `s "'xu� .......aF,ix.� tx &..�....eAa ���-.�r�� _,,.M.. .��C�07 ,m. .. Table ES-4 Summary Impact Table Residual Impact Mitigation Measure Impact Impact TR-9: The proposed project would provide adequate None required. Less than vehicular access driveways and would not result in inadequate significant emergency access. Impact TR-10: The project would not substantially increase None required. Less than roadway hazards. significant Impact TR-11• The project would not conflict with adopted None required. Less than policies supporting alternative transportation (e.g., bus turnouts, significant bicycle racks). The following standard City requirements(CR)would apply to the project. CR TR-A During grading and construction,on-site parking shall be provided for all construction workers and equipment unless approved otherwise by the Public Works Department. CR TR-B During grading and construction, the property owner is responsible for all required clean up of off-site dirt, pavement damage and/or restriping of the public rights-of-way as determined by the Public Works Department. CR TR-C A Transportation Demand Management Plan shall be submitted for review and approval prior to issuance of Certificate of Occupancy. CR TR-D A traffic control plan for all work within the City right-of-way and Caltrans right-of-way shall be submitted to the Public Works department for review and approval prior to issuance of a grading permit. The City's plans shall be prepared according to the Traffic Control Plan Preparation Guidelines. Plans for Pacific Coast Highway shall be per Caltrans requirements and subject to their review and approval. CR TR-E The developer shall coordinate the development of a truck haul route with the Department of Public Works if the import or export of material is required.This plan shall include the approximate number of truck trips and the proposed truck haul routes. It shall specify the hours in which transport activities can occur and methods to mitigate construction-related impacts to adjacent residents.These plans must be submitted for approval to the Department of Public Works prior to issuance of a grading permit. CR TR-F Traffic impact fees shall be paid at the rate calculated at the time of payment.The fee shall be based on the trip generation for the actual building square footage,units or rooms as applicable using methodology approved as part of the project traffic impact study. Utilities and Service Systems Impact U-1. Sufficient water supplies would be available from None required. Less than existing entitlements and resources to serve the proposed significant project. Impact U-2: The proposed project would be served with None required. Less than adequate water and fire flows. significant Impact U-3: The proposed project would be adequately served None required. Less than by the wastewater treatment provider, and would not exceed significant wastewater treatment requirements or require the expansion or construction of new wastewater treatment facilities. Pacific City EIR 2-13 Chapter 2 Text Changes t_, ' ........_... CHAPTER 1 INTRODUCTION 1.1 OVERVIEW OF THE PROPOSED PROJECT The project proposes development of 31.5 gross acres of currently vacant land bound by First Street on the west, Huntington Street on the east, Atlanta Avenue on the north, and Pacific Coast Highway (PCH) on the south, in the Downtown area of the City of Huntington Beach. The proposed Pacific City project consists of a visitor-serving/neighborhood commercial-retail center, a residential village, and vehicular and pedestrian circulation improvements. Approximately 10.6 net acres of the project site adjacent to PCH would be developed with up to 400 rooms of hospitality (i.e., hotel) and up to 240,000 square feet (sf) of visitor-serving commercial uses that are proposed to include retail, office, restaurant, cultural, and entertainment facilities, with approximately 1,543 parking spaces in a subterranean garage. The approximately 17.2-net-acre northeastern portion of the project site would be developed with 516 condominium homes at an average of 30 dwelling units per net acre, in accordance with density levels set forth in the City of Huntington Beach General Plan and Downtown Specific Plan. A total of 1,341 parking spaces in a subterranean garage and approximately 19 on-site surface parking spaces would be provided to serve this residential component. In addition, pedestrian corridors would be provided through the site to improve pedestrian access between the surrounding residential communities and the proposed residential and commercial components. Several accessways to the beach area south of the , project site are also proposed. The proposed project has been designed to conform to the existing land use and zoning designations in the City of Huntington Beach General Plan and Downtown Specific Plan. For a detailed description of the proposed project, refer to Chapter 2 (Project Description) of this document. 1.2 RELATIONSHIP OF PROPOSED PROJECT TO PREVIOUS ENVIRONMENTAL DOCUMENTATION This EIR serves as a project EIR, since it analyzes impacts of a specific development project. This EIR also serves as a Subsequent EIR, since development on the project site has been addressed on a programmatic level as part of the analysis included in several Program EIRs prepared by the City of Huntington Beach. These documents include (1) The Huntington Beach Downtown Specific Plan EIR 82-2 (SCH No. 82012914) and Addendum to SEIR 82-2; (2) The Huntington Beach General Plan Update EIR 94-1 (SCH No. 940991018); and (3) The Huntington Beach Redevelopment Project EIR 96-2 (SCH No. 96041075). Each of these documents includes analysis that accounts for development at the project site. The General Plan Update EIR analyzes the theoretical buildout of the entire City, while 2-14 City of Huntington Beach Chapter 2 Text Changes ...,. • f r F ,•x e ats.„ u :. • ••*, M. � . below, for a complete discussion of pedestrian access and circulation. Recreational facilities would include five recreational areas, the largest of which is identified as the"Village Green"in the center of the proposed residential area adjacent to the loop road. This 2.03-acre 2.5 aere area would be accessible to the public. The four other individual recreational areas would be located throughout the residential component and would primarily serve residents of the proposed project, although Area 1, at the corner of First Street and Atlanta Avenue, would be publicly accessible. Additional common open space areas would be situated around all the residential buildings, as shown in Figure 2-5a. Private open space would be provided through patios, balconies, and stoops, as shown in Figure 2-5b. Parking would be provided in subterranean garages and in surface parking areas along the interior collector street. A total of 1,360 spaces would be provided for residential uses. A minimum of two parking spaces in the subterranean garage would be provided for each unit. In addition, subterranean and surface parking would be provided to serve guests of the community, as required by the Zoning Code. Residential village architecture would comply with the City's Urban Design Guidelines. The landscape concept for the residential village district set forth in the Conceptual Master Plan would also be consistent with the Urban Design Guidelines, which strives to achieve compatibility with the existing surroundings. Proposed landscaping would feature prominent evergreen trees such as Jacaranda and Magnolia, as well as several varieties of palms. In addition, various flowering and evergreen shrubs would be planted, including Bougainvillea, agave, and star jasmine, as well as other vines and groundcovers. Affordable Housing is proposed to be provided by a combination of on- and off-site units in compliance with the City's Housing Element and Redevelopment Agency requirements. Fifteen. percent, or 78 affordable units, have been identified as the Agency obligation based on the Applicant's proposed 516 units in the submitted site plan and related applications. A total of 39 moderate-income units are proposed on site, with the balance of units proposed off site. Section 3.11 (Population and Housing) provides detail on the project obligations for affordable housing. 2.3.3 Vehicular and Pedestrian Circulation Improvements Vehicular and pedestrian access to the project site would be provided by a combination of existing and proposed roadways, as described in this section. A summary of proposed roadway improvements and project accesses is provided in Table 2-8. Roadway widening proposed by the project would be accomplished by widening onto the project site. Encroachment into property surrounding the site is not proposed as part of the project. Pacific City EIR 2-15 Chapter 2 Text Changes Oege72* 04tebje 2• 8°5umym ii 4f P rpns li a{dw y 161Prorencints" y,. . Table 2-8 Summary of Proposed Roadway Improvements Roadway Proposed Project Improvements Pacific Coast Dedicate ROW north of centerline Highway Widen PCH on north side for provision of a third westbound through lane and future bike lane Remove parallel parking on north side of roadway and replace on-site Close existing median opening and install median landscaping along a portion of PCH,between First and Huntington Streets Pedestrian site access to commercial component Two at grade crosswalks at intersections of First and Huntington Streets Additional North-South crosswalk at the northeast corner of PCH and First Street Grade-separated pedestrian overcrossing over PCH to beach area could be constructed in the future Provide an Orange County Transportation Authority bus turnout on the north side of PCH,west of Huntington Street Atlanta Avenue Dedicate ROW between First Street and Huntington Street,south of centerline Additional eastbound travel lane Sidewalk,curb and gutter,paving,and a landscaped median between First and Huntington Streets Pedestrian access to residential component Huntington Street Dedicate ROW between Pacific View Avenue and Pacific Coast Highway,west of centerline Additional southbound travel lane between PCH and Pacific View Southbound right turn lane at PCH Provide traffic signal at intersection with Atlanta Avenue Landscaped median between Pacific View Avenue and PCH ' Sidewalk,curb,clutter,and paving between Pacific View Avenue and Atlanta Avenue Vehicular service access to commercial component Vehicular resident-only access to residential component Pedestrian access to residential component First Street Dedicate ROW east of centerline between Atlanta and Pacific View Avenue for an ultimate configuration with a 100-foot-wide right-of- way Additional southbound and northbound travel lane between PCH and Atlanta Additional southbound left-turn lane onto PCH Sidewalk,curb and gutter,paving,and landscaped medians Vehicular service access to commercial component Vehicular resident-only access to residential component Pedestrian access to residential component Pacific View Extension of roadway,which currently exists only from Huntington Street to approximately 500 feet east along the existing Waterfront Avenue Hilton project,through site in a 90-foot ROW,in compliance with the Precise Plan of Street Alignment Ultimate Condition: Primary Arterial Street Four-lane divided cross section within the 90 foot ROW. No angled parking Some on-street parallel parking Interim Condition: Parallel parking on north side of street for the proposed public park One lane of traffic in each direction with a center turning lane,on-street bike lanes and pedestrian crosswalks Angled parking on south side of roadway Sidewalk,curb and gutter,paving,and raised landscaped medians Three vehicular accesses to commercial component(two public and one service) — Two vehicular accesses to residential component(residents and guests) Pedestrian access to residential and commercial components SOURCE: Makallon Atlanta Huntington Beach,LLC,July 7,2003b 2-16 City of Huntington Beach Chapter 2 Text Changes y A k x , . / t K zrya i . ` .. .:�.: • .,. � :.,..._� aTAMS_nr'• Off-Site Vehicular Circulation and Parking Pacific Coast Highway. PCH is showndcsignatcd in the Circulation Element of the General Plan as a Major Arterial Highway, and the Caltrans Route Concept Report and the County of Orange Master Plan of Arterial Highways (MPAH) set the standards for this roadway. It has an existing 84-foot pavement width, including a 12-foot median and an 8-foot sidewalk on the inland side. There are two lanes of travel in each direction at the eastern end of the project site, and three lanes of travel in each direction at the western end of the project site. In addition, a median break with an eastbound left-turn pocket is located approximately 800 feet from the eastern project boundary (Huntington Street and PCH). Presently, metered parallel parking is provided on both sides of the street, with 27 metered parking spaces located along the north side of PCH fronting the Pacific City project site. As required by Caltrans, PCH will include three travel lanes and an on-street bike lane along the project frontage. These improvements would be implemented by the proposed project and result in the removal of the 27 metered parking spaces along the project frontage. Project design includes parking spaces to replace the loss of these parking spaces in the commercial parking structure. An Orange County Transportation Authority (OCTA) bus turnout will be provided on the north side of PCH, west of Huntington Street. No vehicular access from this roadway would be provided. Atlanta Avenue. This street is currently designated as a Primary Arterial Street in the Circulation Element. Atlanta Avenue has an existing 45-foot pavement width and 63-foot ROW east of Huntington Street and 45-foot pavement width and 58-foot ROW west of Huntington Street. Additional right-of-way would be dedicated and constructed between First Street and Huntington Street, south of the centerline (within the project site) to allow for street improvements as part of the proposed project, including an additional eastbound travel lane. Widening of this street would occur; however, no vehicular access to the site from this roadway would be provided to the project site. The exact dedication would vary depending on the location due to the centerline location and the curve in the roadway. As discussed under Huntington Street below, a traffic signal would be installed at the intersection of Huntington Street and Atlanta Avenue. Huntington Street. Huntington Street, between Atlanta Avenue and Pacific View Avenue, is currently configured as a collector street with a 40-foot pavement width and 10-foot ROW on both sides of the street for sidewalk and parkway improvements. An existing sidewalk is located on the west side of the street. Huntington Street, between Pacific View Avenue and PCH is designated as a three-lane +—lane secondary arterial but has a current configuration that includes 32 feet of pavement width-to-curb and 8-foot sidewalk east of the centerline and 20 feet of pavement width- to-curb and 10-foot sidewalk west of the centerline. Ten feet of ROW would be dedicated between Pacific View Avenue and PCH, west of the centerline to allow for the full secondary arterial ROW with sidewalks as well as curb and gutter improvements. An additional southbound travel lane between PCH and Pacific View would be provided, as would a southbound right Pacific City EIR 2-17 Chapter 2 Text Changes turn lane at PCH. Project accesses from Huntington Street would include a service entrance to the commercial component and two resident-only entrances to the residential component. A traffic signal would be installed at the intersection of Huntington Street and Atlanta Avenue. The need for this signal was established by previous environmental documentation for the Waterfront Development Project, SEIR 82-2. First Street. First Street is designated as a Primary Arterial Street, but has a current configuration that varies with a 75-foot ROW near PCH, which includes 62 feet of pavement curb-to-curb and 6.5 feet of sidewalk and parkway on each side. Near the intersection with Olive, First Street has a 95-foot ROW with 75 feet of pavement curb-to-curb and 10 feet of parkway and sidewalk on each side. Widening would occur on this street, and 16 on-street parking spaces would remain on the east side of the street. The ultimate configuration of First Street would include a 100-foot ROW, with 42 feet of pavement and 8 feet of parkway and sidewalk on each side of the existing centerline of the street. An additional southbound left-turn lane onto PCH would be provided. Project accesses from First Street would include a service entrance to the commercial component and one resident-only entrance to the residential component. Pacific View Avenue. Pacific View Avenue is designated as a Primary Arterial Street, although the street presentlyterminates at the southeastern project boundary. Pacific View Avenue would be extended through the site as part of the proposed project, consistent with the Precise Plan of Street Alignment(PPSA No. 88-1). The alignment would provide for a slight curvilinear design with a 90- foot ROW. In the near term, one lane of traffic would be provided in each direction with a turiting-lattelandscaped median, and pedestrian crosswalks. Angled parking would be provided on the south side of roadway in the short term. The ultimate configuration of this roadway would include a 4 lane divided cross section within the 90-foot ROW. It is anticipated that some on-street parking may be retained with the reconfiguration, though angled parking would not be allowed. Project access from Pacific View Avenue would include three accesses to the commercial component(two public and one service) and two accesses to the residential component via the loop road. Parking. Off-site parking would only be provided on Atlanta Avenue and First Street. In the short- term, 22 spaces would be provided on Atlanta Avenue and 16 spaces would be provided on First Street. However, the parking spaces on the south side of Atlanta Avenue would eventually be removed when Atlanta Avenue is fully improved between Huntington Street and Beach Boulevard. Thus, the only long-term, off-site parking would be on First Street, where 16 parking spaces would remain. Approximately 53 existing off-site parking spaces that currently abut the site would be removed as a result of the proposed project, and would be relocated as on-site parking within the parking structure. Refer to Section 3.14 for details on project impacts to off-site parking. 2-18 City Huntington on Beach t� Chapter 2 Text Changes ��-'T "' ^, �� ;k� ��e'� �'' ate"'• r y " �a � �. �8ge 2 ,� �i ah c On-Site Vehicular Access, Circulation, and Parking Vehicular access to the visitor-serving uses would be from First Street (service only), the extension of Pacific View Avenue (two visitor and one service access), and Huntington Street (service and employee only). Service entries would be designed to accommodate delivery vehicles and moving vans and trucks. From the westerly access from Pacific View Avenue, motorists would enter the commercial component and directly access the subterranean parking structure from the on-site drive. From the easterly access from Pacific View Avenue, motorists would access the site via an on-site drive and drop off guests at the hotel facility, drop off their vehicles to be valet parked, or access the subterranean parking garage. Proposed vehicular access to the site is depicted on Figure 2-6. Service vehicles would be provided with three accesses (First Street, Huntington Street, and Pacific View Avenue) and loading areas that would be separate from visitor access points. All loading and unloading would occur off-street, within designated areas of the project site. No vehicular access is proposed from PCH. Vehicular access to the residential uses would be provided from Pacific View Avenue (two access points), First Street, and Huntington Street (two access points). The residential village includes a private community collector street(loop road) off of Pacific View Avenue that would be gated, and would provide access to residents and guests. The street would be publicly accessible to pedestrians. The First Street and Huntington Street access points would be available for residents only, include security gates, and lead directly to the subterranean parking spaces. Internal to the site, along the loop road, both residents and guests would have access to the subterranean parking garages. Subterranean parking spaces would be provided,for each condominium unit with adequate subterranean and surface parking (along the interior loop road) to serve guests of the community, as required by the Downtown Specific Plan. Pedestrian Access Pedestrian access improvements include pedestrian corridors throughout the project site (Figure 2- 7). Pedestrian pathways would link the surrounding residential communities and the proposed residential component, and would be publicly accessible at all times. These pedestrian access ways would then connect to the commercial component and PCH and, ultimately, to the beach parking lot. Pursuant to the Downtown Specific Plan, development in Districts 7 and 8A requires the dedication, or a waiver thereof, of a 20-foot-wide corridor between Atlanta Avenue and PCH for public access between the southern end of the Pacific Electric ROW and PCH. This public access corridor commences on Atlanta Avenue and aligns with Alabama Street (oriented perpendicular to Atlanta Avenue)to facilitate pedestrian Pacific City EIR 2-19 Chapter 2 Text Changes movement to the Downtown area. Public access is provided via the loop road through District No. 8A to Pacific View Avenue, extending through Pacific City District No. 7 to PCH. Pedestrian movement across Pacific View Avenue would be provided at four locations between First Street and Huntington Street. At-grade pedestrian crosswalks would be provided at the intersection of First Street at Pacific View Avenue, the intersection of Huntington Street at Pacific View Avenue, and at two locations on Pacific View Avenue between Huntington Street and First Street where the loop road intersects with Pacific View Avenue. Pedestrian pathways would connect to the commercial component by intersections and clearly delineated entrances to the visitor-serving commercial and hotel amenities. At-grade crossings are proposed at the existing signalized intersections of PCH and Huntington and First Streets to the beach. In addition, a pedestrian bridge over PCH is proposed as part of the Pacific City Master Plan. This feature is not part of the Tentative Tract Map, and as such, is not proposed to be constructed at this time. However, this element is analyzed in this EIR, since it could be built in the future as part of the project. 2.3.4 Drainage Improvements Proposed project design would include improvements to the existing drainage system serving the site. On-site drainage areas would have the first flush (85-percentile 24-hour storm event or the maximum flow rate of runoff produced from a rainfall intensity of 0.2 inch per hour) and dry- weather flows treated by filtration systems included as part of project design. Discharges from the entire site would be detained on-site to allow for treatment of runoff through filtration systems prior to entering the storm drain system. The detention basin would be below ground, and is planned to be located immediately north of Pacific View Avenue, east of First Street, although the complete design of this facility has not been submitted to the City. The entire site currently drains to the Atlanta Stormwater Pump Station (ASWPS). The proposed project would be divided into two separate drainage areas. A 7.7-acre area that would include primarily the site perimeter would drain to the ASWPS, and the balance of the site would drain stormwater flows to First Street. The project proposes to construct a storm drain line in First Street that would exclusively serve stormwater flows from the project site. This line would run parallel to the existing City 36-inch line in First Street. The project-specific storm drain line would then connect to the City's 36-inch South Beach Storm Drain south of PCH. As required by the City Public Works Department, the project would be limited to flows of 20 cubic feet per second from this area, based on overall planned pipe capacity of the City system in this location. In addition, the dry weather flow from this area can be routed to the ASWPS, in order that, at the City's discretion, these flows may be routed for treatment by OCSD. 2.4 CONSTRUCTION SCENARIO It is anticipated that the proposed project would be constructed in several major phases over a six- year period beginning in 2004. The site would be mass graded. Grading would involve the cut and fill of approximately 274,600 cubic yards of soil that would be balanced on site. Residential units would be constructed in three phases, during which time the visitor-serving commercial uses, followed by hotel construction, would occur. Construction of the 2.03-acre 2.5 acre recreational area in the center of the residential component would be constructed as part of the first phase of 2-20 City of Huntington Beach Chapter 2 Text Changes residential construction. Proposed construction phasing is illustrated in Figures 2-8a and 2-8b. Construction would be fully completed by 2010. 2.5 PROJECT GOALS AND OBJECTIVES Project objectives have been identified by both the City and the Applicant. The City's project objectives are as follows: • Assist in the implementation of the City's General Plan, Downtown Specific Plan, and Redevelopment Plan • Enhance the Downtown as a destination for visitors by expanding hotel, retail, and entertainment opportunities Pacific City EIR 2-21 Chapter 2 Text Changes rm�,.� m'�,�a'�'ar"`�✓ �y^�, ° Y - ,e S3i-i �'- YY - �k F � • • .::>,., ..fix. ✓.aa>,xt .�,. .. ......... z.:Ex,..M r„�.",FX,.sac .• , y, „�, .::'x s i..3sE... +�'.`�:', after noon. As indicated previously, significant impacts would occur due to the casting of shadows on adjacent residential properties or light-sensitive uses for more than three hours between the hours of 9:00 A.M. and 3:00 P.M. As no shadows on the mobile homes are present in the 12:00 noon diagram, the shadows cast by the proposed project would have a duration of less than three hours during this period. In addition, with a sunset of about 4:15 during the Winter Solstice, shadows would not remain at this length for a substantial duration of time. Additional shade would result on a select number of residences during the shortest days of the year. However, shadows cast by proposed development would not result in a significant impact from shading of these residences. Impact AES-5 Structural development would introduce new sources of light and glare into the project vicinity. For the purposes of this analysis, light or glare effects evaluate the change in illumination level as a result of project sources and the extent to which project lighting would spill off the project site and affect adjacent light-sensitive areas. Structures would range from two to eight stories in height. Buildings generally three or more stories in height have the potential to include large building faces that could introduce reflective surfaces (e.g., brightly colored building facades, reflective glass) that could increase existing levels of daytime glare. The westward orientation of the primary facade would be subject to and could reflect direct afternoon sunlight. The project could serve as a new source of substantial glare in the area, and impacts would be potentially significant. Impact AES-6 Structural development would not result in significant nighttime lighting in the project vicinity. Project implementation would increase overall nighttime lighting in the project area with the introduction of additional street lighting, building exterior lighting, and vehicle headlights. As described in Section 2.2.2 (Surrounding Land Uses), uses across Huntington Street south of Pacific View Avenue and across First Street south of Walnut Avenue are hotel and commercial uses, respectively, which are not considered sensitive receptors and would not be adversely affected by increased light in the area. However, some residential uses lie along First Street north of Walnut Avenue, and the Pacific Mobile Home Park is located across Huntington Street, north of the proposed alignment of Pacific View Avenue. These uses would be considered sensitive with respect to increases in nighttime lighting. As described above in Section 3.1.1 (Existing Conditions), several sources of nighttime lighting exist in the project vicinity, and the quality of the night sky has already been diminished. Streetlights provide the majority of light along the streets that surround the project site, particularly PCH. Surrounding uses, particularly the Hilton Waterfront Resort, also provide exterior lighting. The proposed project would introduce nighttime lighting directly onto the project site, as well as into the project vicinity. Consequently, the surrounding residential uses could be exposed to exterior lighting associated with the proposed buildings, particularly the condominium buildings proposed in the northern portion of the project site. However, as a standard condition of approval, the City requires that all outdoor lighting be directed to prevent light spillage onto adjacent properties, with indication of such provision on the final site plans. Additionally, some of this light would be masked by existing street lighting and nighttime vehicular traffic. This impact would be less than significant. 2-22 City of Huntington Beach Chapter 2 Text Changes reflect direct afternoon sunlight. The project could serve as a new source of substantial glare in the Impact AES-67 Implementation of the proposed project would introduce new sources of vehicle headlight, although they would not significantly affect adjacent sensitive uses. Proposed ingress and egress points for the parking garage would be located along the perimeter of the property and internal to the site. Some of these access points would be situated across from residences, and headlights of vehicles could be directed onto residential properties along these streets as vehicles exit the parking garage. In addition, the proposed extension of Pacific View Avenue would create two new roadway intersections at First Street and at Huntington Street. Vehicle headlights at these intersections could affect adjacent residential properties. In total, there are 11 project accesses proposed,in addition to 4 new intersections, as shown in Figure 3.1-20. Vehicular headlight, like all light, travels indefinitely until impeded by an intervening object. This analysis assumes all vehicle headlamp centers for service vehicles would be within the federal and State standard maximum of 54 inches (4.5 feet) in height and residential vehicles would have a headlamp center a maximum of 41 inches (3.4 feet) in height, due to garage clearance. However, typically vehicular headlights would be between two and three feet above ground level for sedans and mid-size truck/sport utility vehicles, respectively. The analysis also assumes that residential vehicles exiting the proposed garages would not be using "high beams" but rather "low beams," which diffuse light in a manner that primarily limits beam light up to 6 inches above the headlamp center. That is, for vehicles with a headlight center of 3 feet above ground, light would not be spread more than 3.5 feet above ground level, at distances of 40 feet or more. Garage A Garage A would be located on First Street and serve the residential portion of the proposed project. Headlights of residential vehicles exiting Garage A would be directed primarily onto First Street and the opposite vacant lot owned by the Applicant, shown in Figure 3.1-15. The vacant lot is somewhat shielded from view by a mesh-covered chain-link fence. Since the lot is vacant,it is not considered a light-sensitive use, and the project would not affect the existing conditions. The site could be developed in the future for residential uses, and vehicles exiting the parking garage would have the potential to cast light onto Pacific City EIR 2-23 Chapter 2 Text Changes CR AES-D Prior to occupancy, all new and existing overhead utilities shall be installed underground in accordance with the City's Underground Utility Ordinance. In addition, all electrical transformers shall be installed underground. In addition to the standard City requirements listed above, the following mitigation measure (MM) would be required to address significant effects of Impact AES-5. MM AES-1 To the extent feasible, the Applicant shall use nonrfective facade treatments, such as matte paint or glass coatings. Building materials shall be consistent with the Downtown Design Guidelines, and reflective glass shall not constitute a primary exterior material. Prior to issuance of building permits for the proposed project, the Applicant shall indicate provision of these materials on the building plans. The following mitigation measure (MM) would be recommended to address less than significant effects of Impact AES-6. MM AES-2 The lighting plan shall include provisional measures to limit nighttime illumination during periods offog. Measures may include but would not be limited to reduced foot- candle illumination levels or reduced number of lighting fixtures in use. Impacts AES-1 through AES-4,attel-AES-6, and AES-7 would be less than significant, as described above. Incorporation of MM AES-1 would ensure that impacts from light and glare would be reduced to less-than-significant levels. The provision of nonreflective façade treatments for structures proposed under the project would ensure that impacts described under Impact AES-5 related to daytime glare would be reduced to a less-than-significant level by reducing the reflective properties of the building materials employed, such as glass,metal, or finished concrete. Limitation of nighttime illumination during periods of fog would further reduce less than significant impacts of night lighting, as described under Impact AES- 6. 2-24 City of Huntington Beach Chapter 2 Text Changes „ s^x'- 4 �#f r7 Fagg ' ►:4 . &"� x CR AQ,B The Applicant shall notify all property owners and tenants within 500300 feet of the perimeter of the property of a tentative grading schedule at least 30 days prior to such grading. CRAQ,C The Applicant shall demonstrate that the grading/erosion control plan will abide by the provisions of AQMD's Rule 403 as related to fugitive dust control, prior to issuance of grading permits. CR AQ-D through CR AQ-F shall be implemented during grading and construction operations: CR AQD The construction disturbance area shall be kept as small as possible. CR AQE Wind barriers shall be installed along the perimeter of the site and/or around areas being graded. CR AQF Remediation operations, if required, shall be performed in stages concentrating in single areas at a time to minimize the impact of fugitive dust and noise on the surrounding areas. In addition to the standard City requirements listed above, mitigation measures (MM) would be required to address project impacts. The following mitigation measures would be required to address potentially significant air quality impacts associated with construction activities, as described under Impact AQ-1. MMAQ,1 The project developer(s) shall require by contract specifications that construction equipment engines will be maintained in good condition and in proper tune per manufacturer's specification for the duration of construction. Contract specification language shall be reviewed by the City prior to issuance of a grading permit. MM AQ-2 The project developer(s) shall require by contract specifications that construction- related equipment, including heavy-duty equipment, motor vehicles, and portable equipment, shall be turned off when not in use for more than five minutes. Contract specification language shall be reviewed by the City prior to issuance of a grading permit. MM AQ,3 The project developer(s) shall encourage contractors to utilize alternative fuel construction equipment (i.e., compressed natural gas, liquid petroleum gas, and unleaded gasoline) and low-emission diesel construction equipment to the extent that the equipment is readily available and cost eective. Contract specification language shall be reviewed by the City prior to issuance of a grading permit. MM AQ4 The project developer(s) shall require by contract specifications that construction operations rely on the electricity infrastructure surrounding the construction sites rather than electrical generators powered by internal combustion engines to the extent Pacific City EIR 2-25 Chapter 2 Text Changes MM AQ-6 The project developer shall include in construction and sales contracts the following requirements or measures shown to be equally effective to reduce project-related stationary and area source emissions: • Use solar or low-emission water heaters in the residential, ofce, and visitor- serving commercial buildings ■ Provide energy-Efficient heating with automated controls in the residential, ofce, and visitor-serving commercial buildings ■ Use energy-Efficient cooking appliances in the in the residential and visitor- serving commercial buildings • If fire places are provided in new residential units, install the lowest-emitting fireplaces commercially available at the time of development • Require that contract landscapers providing services at the project site use electric or battery-powered equipment, or internal combustion equipment that is either certified by the California Air Resources Board or is three years old or less at the time of use. Contract specification language shall be reviewed by the City prior to issuance of a grading building permit. MMAQ-7 The project developer shall include in construction and sales contracts for the commercial and offices uses on site that preferential parking spaces be provided for carpools and van pools. Contract specification language shall be reviewed by the City prior to issuance of a gradingbuilding permit. A minimum of 7'2" of vertical clearance shall be provided in the parking structure for vanpool access. Inclusion of the vertical clearance shall be verified on building plans prior to issuance of a building permit. These measures would ensure that construction emissions are not greater than predicted in this analysis. They would also reduce the operational emissions of the proposed project by approximately 0.01 pound per day of VOC and 0.17 pound per day of NO.. The daily emissions associated with construction and operational activities, as described under Impact AQ-1 and Impact AQ-2, would remain significant and unavoidable. Impact AQ-3 through Impact AQ-5 would be less than significant, as described above. 2-26 City of Huntington Beach Chapter 2 Text Changes ors > 'J '` Page:33- , £, R Table 3.3-1 Plants Observed on the Project Site Name Wetland Indicator Status ANGIOSPERMAE—FLOWERING PLANTS DICOTYLEDONES AIZOACEAE—FIG-MARIGOLD FAMILY Mesembponthetim Mesembryanfhemum crystallinum1 NIA Crystalline iceplant ANACARDIACEAE—SUMAC FAMILY Rhus integrifolia1 NIA Lemonade berry APIACEAE(UMBELLIFERAE)—CARROT FAMILY Foeniculum vulgare1 FACU Sweet fennel ARALIACEAE—GINSENG FAMILY Hedera helix1 N/A English ivy ASTERACEAE(COMPOSITAE)—SUNFLOWER FAMILY Heterotheca grandiflora1 N/A Telegraph weed Isocoma menziesii1 FACW Coastal goldenbush BRASSICACEAE(CRUCIFERAE)—MUSTARD FAMILY Brassica nigra1 N/A Black mustard CARYOPHYLLACEAE—PINK FAMILY Spergularia marina1 OBL Salt-marsh sand spurry CHENOPODIACEAE—GOOSEFOOT FAMILY Atriplex semibaccata& FAC Australian saltbush Atriplex lentiformis ssp.lentiformis2 FAC Brewer's saltbrush Bassia hyssopifolia2 FAC Five-horn bassia Suaeda taxifolia2 N/A Woolly sea-blite Chenopodium califomicum2 N/A California goosefoot Salsola fragus1 N/A Russian thistle CYPERACEAE—SEDGE FAMILY Cyperus eragrostis2 FACW Tall flatsedge FABACEAE(LEGUMINOSAE)—LEGUMEIPEA FAMILY Acacia sp.1 N/A Acacia Pacific City EIR 2-27 Chapter 2 Text Changes Table 3.3-1 Plants Observed on the Project Site Name Wetland Indicator Status FAGACEAE—OAKIBEECH FAMILY Quercus sp.t N/A Ornamental oak JUNCAGINACEAE—Arrowgrass family Triglochin concinna2 OBL Arrowgrass MALVACEAE—MALLOW FAMILY Malva parviflorat N/A Cheeseweed MYRTACEAE—MYRTLE FAMILY Eucalyptus globulest N/A Tasmanian blue gum OXALIDACEAE—WOOD-SORREL FAMILY Oxalis pes-caprae1 N/A Bermuda buttercup/sour grass POLYGONACEAE—BUCKWHEAT FAMILY Rumex crispust FACW- Curly dock POACEAE—GRASS FAMILY Cynodon dactylont FAC Bermuda grass Polypogon monspeliensis2 FACW+ Rabbitsfoot grass Parapholis incuwa incurva 2 OBL Sicklegrgass Spartina-sp.Distichlis spicata 2 FACW Saltgrass 1. Species observed during the December 19,2001,site visit. 2. Additional species observed by EIP Biologist on September 24,2003 Indicator categories Code Wetland Type Comment OBL Obligate Wetland Occurs almost always(estimated probability 99%)under natural conditions in wetlands. _ FACW Facultative Wetland Usually occurs in wetlands(estimated probability 67%-99%),but occasionally found in non-wetlands. FAC Facultative Equally likely to occur in wetlands or non-wetlands(estimated probability 34%-66%). FACU Facultative Upland Usually occurs in non-wetlands(estimated probability 67%-99%),but occasionally found on wetlands(estimated probability 1%- 33%). UPL Obligate Upland Occurs in wetlands in another region,but occurs almost always(estimated probability 99%)under natural conditions in non-wetlands in the regions specified.If a species does not occur in wetlands in any region,it is not on the National List. NIA Not listed as an indicator species. SOURCE: Appendix I 2-28 City of Huntington Beach Chapter 2 Text Changes •ru,w �' " • > -' .z......¢.,..1 imFFmr��;:,r .5 & ex`a .e.,� r' .A:�:.. . , Y Table 3.4-3 General Plan Coastal Element—Policies Applicable to Cultural Resources Goal,Objective,or Policy Project Consistency Policy C 5.1.4.A completed archeological As described above Section 3.4.1 (Existing Conditions),an archaeological resources technical report research design shall be submitted along was prepared for the proposed project site by PAS and submitted to the City and would be subject to with any application for a coastal peer review,at the City's discretion.The report included a discussion of research topics and the development permit for development within theoretical framework that could be addressed by data from the archaeological sites and evaluated any area containing archeological or the significance of the sites and recovered cultural material using the applicable criteria from the paleontological resources.The research California Register of Historical Resources,which are also included in Section 15064.5(a)of the design shall determine the significance of CEQA Guidelines.The principal investigators for the report also consulted with the Native American any artifacts uncovered and make Heritage Commission and with representatives of appropriate Native American groups. recommendations for preservation. The conclusions and recommendations of the report will be made available to the Office of Historic Significance will be based on the Preservation as a part of the Draft EIR,and the recommendations of the report,in addition to other requirements of the California Register of mitigation provided in this EIR,will be included in the Mitigation Monitoring and Ftieg-Program for Historical Resources criteria,and prepared the project,pursuant to Section 15097 of the CEQA Guidelines,and will be fully enforceable.The based on the following criteria: proposed project would,therefore,be consistent with this policy. a. Contain a discussion of important research topics that can be addressed; and b. Be reviewed by at least three(3) County-certified archeologists(peer review committee). c. The State Office of Historic Preservation and the Native American Heritage Commission shall review the research design. d. The research design shall be developed in conjunction with affected Native American groups. e. The permittee shall comply with the requirements of the peer review committee to assure compliance with the mitigation measures required by the archeological research design. Policy C 5.1.5.A County-certified Mitigation measures proposed for the project include provisions for monitoring of earth-disturbing paleontologist/archeologist,shall monitor activities by archaeologists,paleontologists,and a Native American representative,as well as all grading operations where there is a provisions for cessation of earth-disturbing activities as the significance of any recovered materials is potential to affect cultural or assessed and subsequent appropriate actions are taken.The project would,therefore,be consistent paleontological resources based on the with this policy. required research design.A Native American monitor shall also monitor grading operations.If grading operations uncover paleontological/archeological resources,the paleontologist/archeologist or Native American monitor shall suspend all development activity to avoid destruction of resources until a determination can be made as to the significance of the paleontological/archeological resources.If found to be significant,the site(s)shall be tested and preserved until a recovery plan is completed to assure the protection of the paleontological/archeological resources. Pacific City EIR 2-29 Chapter 2 Text Changes 3.4.5 Cumulative Impacts This cumulative impact analysis considers development of the proposed project, in conjunction with other development within the vicinity of the project in the City of Huntington Beach. Cumulative development would require grading and excavation that could potentially affect archaeological or paleontological resources, similar to the proposed project. The cumulative effect of these projects is the continued loss of these resources. The potential loss of paleontological and archaeological resources under the project would contribute to the degradation of the historic fabric of the City of Huntington Beach. However, project specific mitigation would be implemented as appropriate to reduce the effect of this development by ensuring the evaluation and—where appropriate—scientific recovery and study of any resources encountered, which would ensure that important scientific information that isprovided bythese resources regarding P g g history and prehistory would not be lost. Similar conditions would be required where cumulative development has the potential to affect these resources. The contribution of the proposed project to the degradation of the historic fabric of the City of Huntington Beach would, therefore, not be cumulatively considerable. Cumulative impacts would be less than significant. 3.4.6 Mitigation Measures and Residual Impacts The following mitigation measure (MM) would be required to address impacts to archaeological and paleontological resources, as described above under Impacts CR-1 and CR-3. MM CR-1 Monitor grading and excavation for archaeological and paleontological resources: (a) The Applicant shall arrange for U-qualifi'ed (as defined by the Orange County Archaeological/Paleontological Curation Project) professional archaeological and paleontological monitors to be present during demolition, grading, trenching, and other excavation on the project site. The Applicant shall also contact the appropriate Gabrielino and Juaneno tribal representatives to determine whether either group desires Native American monitoring of grading activities. If Native American monitors are requested, the Applicant shall arrange for the monitoring with tribal representatives. Additionally, prior to project construction, construction personnel will be informed of the potential for encountering significant archaeological and paleontological resources, and instructed in the identification of fossils and other potential resources. All construction personnel will be informed of the need to stop work on the project site until a qualified archaeologist or paleontologist has been provided the opportunity to assess the significance of the find and implement appropriate measures to protect or scientifically remove the find. Construction personnel will also be informed of the requirement that unauthorized collection of cultural resources is prohibited. (b) If archaeological or paleontological resources are discovered during earth moving activities, all construction activities within 50 feet of the find shall cease until the archaeologist/paleontologist evaluates the significance of the resource. In the absence of a determination, all archaeological and paleontological resources shall be considered significant. If the resource is determined to be significant, the archaeologist or paleontologist, as appropriate, shall prepare a research design for recovery of the resources in consultation with the State .Office of Historic 2-30 City of Huntington Beach Chapter 2 Text Changes Preservation that satisfies the requirements of Section 21083.2 of CEQA, as well as Chapter 3 and Appendices E, F, and G of the Curation Project. The archaeologist or paleontologist shall complete a report of the excavations and findings, and shall submit the report for peer review by three County-certified archaeologists or paleontologists, as appropriate. Upon approval of the report, the Applicant shall submit the report to the South Central Coastal Information Center at California State University, Fullerton, the California Coastal Commission, errd the City of Huntington Beach, the Orange County Archaeo/Paleo Resource Management Facility(APRMF), and the Orange County Historic Programs Office. (c) Monitored grading at the location of CA-ORA-1582H shall involve the removal of refuse deposit in 15 to 20 cm layers using a skip loader. All materials shall be deposited in small to medium piles for scanning by archaeologists for diagnostic materials. If the resource encountered consists of complete or nearly complete artifacts from CA-ORA-1582H, then artifacts shall be cleaned and cataloged accordance with the requirements of the Curation Project, for curation at a facility within Orange County that is acceptable to the City of Huntington Beach_ The applicant shall be responsible for payment of all applicable curation fees, and the curation contract shall spec fv that materials shall be available for loans to educational institutions.;- el me-No further study would be required. (d) In the event of the discovery on the project site of a burial, human bone, or suspected human bone, all excavation or grading in the vicinity of the find will halt immediately and the area of the find will be protected. If a qualified archaeologist is present, he/she will determine whether the bone is human. If the archaeologist determines that the bone is human, or in the absence of an archaeologist, the Applicant immediately will notify the City Planning Department and the Orange County Coroner of the find and comply with the provisions of P.R.C. Section 5097 with respect to Native American involvement, burial treatment, and reburial. Implementation of MM CR-1 would reduce Impacts CR-1 and CR-3 to less-than-significant levels by ensuring that paleontological resources and unanticipated archaeological resources, including human burials, would be subject to scientific recovery and evaluation, pursuant to CEQA, which would ensure that important scientific information that could be provided by these resources regarding history or prehistory is not lost. The following mitigation measure would be required to address impacts to archaeological resources, as described above under Impact CR-2. Pacific City EIR 2-31 Chapter 2 Text Changes Page 32a �s � a MM CR-2 Scientific recovery of archaeological resources associated with CA ORA 149: The Applicant shall retain a qualified archaeologist (i.e., listed on the Registry of Professional Archacologistsas defined by the Orange County Archaeological/Paleontological Curation Project) to develop and implement, in consultation with the State Office of Historic Preservation, a research design and recovery plan for remaining elements of CA ORA 149. The recovery plan shall emphasize data collection in Locus A, between Test Units 1 and 2, as well as on a core area of Locus B, centered around Test Unit 4, and shall be designed to satisfy the requirements of Section 21083.2 of CEQA, as well as Chapter 3 and Appendices E, F, and G of the Curation Project. Implementation of MM CR-2 would reduce Impact CR-2 to a less-than-significant level by ensuring that significant elements of CA ORA 149, a prehistoric archaeological site, would be subject to scientific recovery and evaluation,pursuant to CEQA, which would ensure that important scientific information that could be provided by these resources regarding history or prehistory is not lost. Impacts to CA-ORA-1582H, as described above under Impact CR-4 would be less than significant. 2-32 City of Huntington Beach Chapter 2 Text Changes a k z z k Impact EM-2 Implementation of the proposed project would not substantially increase natural gas demands beyond available supply or result in attracting additional or higher density development to the project area. The natural gas demand rates in cubic feet for the proposed project are shown in Table 3.5-5. Table 3.5-5 Proposed Natural Gas Demand Type of Use Generation Rate Square Feet* Units Cubic Feet Generated per Year Hotel 4.8 cubic feet/square feet/month 370,000 N/A 21,312,000 Retail 2.9 cubic feet/square feeUmonth 240,000 N/A 8,352,000 Residential 4,011.5 cubic feet/unit/month N/A 516 24,839,208 Total 610,000 516 54,503,208 * Values represent the maximum amount of square footage that could be used for the proposed project. SOURCE: SCAQMD 1993 Based upon the rate information, the total project demand for natural gas would be approximately 53,195,208 54,503,208 cubic feet,per year. According to SCGC, the proposed project would likely be served by new natural gas lines that connect to either the gas mains located on Atlanta Avenue or Huntington Street (Kevin Stonesifer, February 2003). SCGC has indicated that an adequate supply of natural gas is currently available to serve the proposed project, and that the natural gas level of service provided to the surrounding area would not be impaired by the proposed project. Depending on the amount of natural gas required by the proposed project, proper-sized natural gas lines would be constructed to provide the necessary loads to the site (James Bevans, February 2003). The service would be in accordance with the company's policies and extension rules on file with the California Public Utilities Commission at the time contractual agreements are made. Since new gas lines would be constructed to serve only the proposed project, this upgrade would not attract more or higher density development to the area. Therefore, natural gas demand associated with the proposed project would be less than significant. Impact EM-3 Implementation of the proposed project would not result in the loss of availability of a known mineral resource or the loss of availability of a locally important mineral resource recovery site. As discussed in Section 3.5.1 (Existing Conditions), the portion of the project site underlain by mineral resources is identified as an Oil Overlay"C" District by the Downtown Specific Plan. The overlay allows for existing and/or expanded oil production on the property if proposed, although the project does not propose this use. Pacific City EIR 2-33 Chapter 2 Text Changes active "blind thrust faults" (i.e., faults which lack surface expression, commonly associated with fold belts and compressional deformation) or other potentially active sources (currently not zoned) may be capable of generating earthquakes. Blind thrust faults were responsible for both the 1987 Whittier Narrows (5.9Mw)and the 1994 Northridge (6.7Mw) earthquakes. Past Seismic Activity The project region has experienced moderate seismic activity from various regional faults over the past 201 years. Based on analysis of historical seismic events, the maximum-recorded magnitude in the project region was 7.0Mw, which occurred on December 16, 1858, and was caused by the San Andreas Fault. The maximum historic site acceleration in the project region was estimated to be 0.4 g on March 11, 1933, caused by an earthquake of 6.3Mw on the Newport Inglewood Fault. Seismic Hazards Groundshaking The major cause of structural damage from earthquakes is groundshaking. The intensity of ground motion expected at a particular site depends upon the magnitude of the earthquake, the distance to the epicenter, and the geology of the area between the epicenter and the property. Greater movement can be expected at sites located on poorly consolidated material, such as alluvium, within close proximity to the causative fault, or in response to an event of great magnitude. Table 3.6-1 above describes the relationship between the Richter Scale Magnitude and the effects of groundshaking. Liquefaction Liquefaction is a seismic phenomenon in which loose, saturated, fine-grained granular soils lose internal shear strength and behave similarly to fluid when subjected to high-intensity ground shaking. Liquefaction occurs when three general conditions exist: (1) shallow groundwater; (2) low-density, fine, clean, sandy soils; and (3) high-intensity ground motion. From a liquefaction hazard standpoint, the site may be divided into two types of regions: those underlain by competent natural soils (terrace deposits) and those underlain by recent alluvium. Generally, the majority of the site is underlain by terrace and engineered fill, which are, in turn, underlain by terrace deposits. Figure 3.6-3 shows the soil regions on the project site. Based on the dense nature of the terrace and fill materials, and from analysis in the Preliminary Geotechnical Investigation report, the potential for liquefaction is considered to be low in these areas. The southeastern corner of the project site, however, is underlain by loose to medium dense alluvial deposits. The potential for liquefaction within this portion of the site the 2-34 City of Huntington Beach Chapter 2 Text Changes alluvial arca, according to the preliminary Geotechnical Investigation, varies from high to medium modcratc to high to very high, with most of the area designated very high potential potential, as shown in Figure 3.6-3. In addition, these alluvial soils in the southeastern portion of the project site are located within a State of California Seismic Hazard Zone Map for Liquefaction. Ground Lurching, Cracking, or Seismically Induced Spreading The geologic units that underlay the project site are dense to over-consolidated terrace alluvium, and medium dense alluvium. The potential for ground lurching, cracking, or seismically induced spreading or compaction effects within these areas are considered low, especially considering the engineering controls and corrective grading anticipated to be performed for the proposed project. Soil Settlement Soil settlement is the condition where soils deform in a vertical direction when a vertical load is placed on top of it. The compression of the soil bed by the vertical load results from the characteristics of the soil particles that are contained in the soil bed, as the spaces that are filled with either air or water between the soil particles are squeezed out. The southeastern portion of the site is underlain by approximately 15 to 20 feet of settlement-prone alluvial/lagoonal deposits, identified as "Afu/QaP' and "Qal" on Figure 3.6-3. Under currently proposed fill loads for the project site, settlement of these soils could be on the order of 1/2-inch for each foot of fill placed over a period of several months. The Preliminary Geotechnical Investigation indicates that the settlement potential of each building should be determined on a case-by-case basis to ensure that final project design incorporates all necessary and appropriate engineering features to reduce' settlement-related impacts. Subsidence Land subsidence is the condition where the elevation of a land surface decreases due to the withdrawal of fluid. The location of major oil drilling areas and state-designated oil fields are areas with subsidence potential in the City of Huntington Beach. According to the Huntington Beach General Plan, the site is not within an area that has been impacted by long-term subsidence due to local oil extraction. Oil Wells and Methane The project site is located within the Huntington Beach Oil Field operated by Chevron and several abandoned oil wells exist within the site. Although operation of the oil field has been shut down for many years, the former oil drilling activities at the site have resulted in alterations to the previous landform. Pacific City EIR 2-35 Chapter 2 Text Changes Y _ : gym _._ � ' through 4, with Zone 1 having the least seismic potential and Zone 4 having the highest seismic potential. The project site is located in Seismic Zone 4; accordingly, any future development would be required to comply with all design standards applicable to Seismic Zone 4. State California Building Code The State of California provides a minimum standard for building design through the California Building Code (CBC). The CBC is based on the UBC, with amendments for California conditions. Chapter 23 of the CBC contains specific requirements for seismic safety. Chapter 29 of the CBC regulates excavation, foundations, and retaining walls. Chapter 33 of the CBC contains specific requirements pertaining to site demolition, excavation, and construction to protect people and property from hazards associated with excavation cave-ins and falling debris or construction materials. ChaptcrSection 70 in the Appendix toof the CBC regulates grading activities, including drainage and erosion control, although the City relies on County Guidelines and their Municipal Code for regulation of this activity. Construction activities are subject to occupational safety standards for excavation, shoring, and trenching as specified in Cal-OSHA regulations (Title 8 of the California Code of Regulations [CCR], as discussed below) and in Section A33 of the CBC. Seismic Hazards Mapping Act CDMG also provides guidance with regard to seismic hazards. Under the Seismic Hazards Mapping Act, seismic hazard zones are to be identified and mapped to assist local governments in land use planning. The intent of this publication is to protect the public from the effects of strong ground shaking, liquefaction, landslides, ground failure, or other hazards caused by earthquakes. In addition, CDMG's Special Publications 117, "Guidelines for Evaluating and Mitigating Seismic Hazards in California," provides guidance for the evaluation and mitigation of earthquake-related hazards for projects within designated zones of required investigations. Local Regulations Southern California Association of Governments SCAG's Regional Comprehensive Plan and Guide (RCPG) and RHNA are tools for coordinating regional planning and development strategies in southern California. Policies contained in the RCPG identified by SCAG as relevant to the proposed project are identified in Table 3.6-3, and this table also includes an assessment of the proposed project's consistency with these policies. 2-36 City of Huntington Beach Chapter 2 Text Changes the largest magnitude earthquake at the project site would likely be generated by the Newport- Inglewood fault, with a 6.9 moment magnitude. Damage from an earthquake of this range in intensity could include general damage to foundations, shifting of frame structures if not bolted, and breaking of underground pipes. Since the proposed project site is located in Seismic Zone 4 of the 1997 LIBC, structures would be designed in accordance with parameters given within Chapter 16 of the current UBC. In addition, as required by CBC Chapter 33 for the construction of new buildings and/or structures, specific engineering design and construction measures would be implemented to anticipate and avoid the potential for adverse impacts to human life and property caused by seismically induced groundshaking. However, active and potentially active faults within Southern California are capable of producing seismic shaking at the project site, and it is anticipated that the project site would periodically experience ground acceleration as a result of exposure to small and moderate magnitude earthquakes occurring on active distant and blind thrust faults. Therefore, impacts related to seismically induced groundshaking would be potentially significant. As discussed in Section 3.6.1 (Existing Conditions), the potential for liquefaction of the subsurface soils on the majority of the project site, which is underlain by terrace and engineered fill, is considered low. However, the potential for liquefaction is very high inodcratc to high in the southeastern corner of the project site, which is underlain by loose to medium dense alluvial deposits (refer to Figure 3.6-3). In addition, the alluvial soils in the southeastern portion of the project site are located within a State of California Seismic Hazard Zone Map for Liquefaction. As such, the potential for liquefaction is present in this portion of the site. The 400-room hotel, which is proposed to be developed in this area, could thus experience substantial damages in the event of an earthquake. Moreover, the largest concentration of persons would be in this area of the site, and could potentially be exposed to these risks. As such, this impact is considered to be potentially significant. Impact GEO-2 Project implementation would locate structures on soils that are considered potentially expansive, unstable, prone to settlement, and corrosive. As discussed in Section 3.6.1 (Existing Conditions), the geologic units that underlay the project site consist of dense to over-consolidated terrace alluvium, and medium-dense alluvium. According to the Preliminary Geotechnical Investigation prepared for the project site, the majority of the on-site, near-surface soils exhibit a medium to high potential for expansion. With the consideration that engineering controls and corrective grading would be performed for the proposed project, the potential for ground lurching, cracking, or seismically induced spreading or compaction effects within the project site is considered low. In addition, according to the City of Huntington Beach General Plan, the project site is not located within an Pacific City EIR 2-37 Chapter 2 Text Changes 17,457,71M, A' Maw_, .' �.? a '�_ g� ? a2.fe k.' LU __ 274,660 cubic yards of soil balanced on site. As the site is undeveloped, it is currently exposed to the potential for erosion. The addition of paved and landscaped areas would, over the long term, decrease the potential for erosion because fewer exposed soils would exist on site. Since the project site does not contain steep slopes, the potential for erosion by water through surface drainage at the project site during construction would be reduced. Earth-disturbing activities associated with demolition and construction would be temporary and would not result in a permanent or significant alteration of significant natural topographic features that could increase or exacerbate erosion. Specific erosion impacts would depend largely on the areas affected and the length of time soils are subject to conditions that would be affected by erosion processes. Although the potential for erosion on the project site would be limited, exposure of soil to wind and water during construction would still occur. The proposed site is greater than 5 acrcsl acre in size, and is subject to the provisions of the General Construction Activity Stormwater Permit adopted by the State Water Resources Control Board (SWRCB). The developer for the proposed project must submit a Notice of Intent (NOI) to the SWRCB for coverage under the Statewide General Construction Activity Stormwater Permit and must comply with all applicable requirements, including the preparation of a Stormwater Pollution Prevention Plan (SWPPP), applicable NDPES Regulations, and best management practices (BMP). The SWPPP must describe the site, the facility, erosion and sediment controls, runoff water quality monitoring, means of waste disposal, implementation of approved local plans, control of post-construction sediment and erosion control measures, maintenance responsibilities, and nonstormwater management controls. Inspection of construction sites before and after storms is required to identify stormwater discharge from the construction activity and to identify and implement controls where necessary. In addition, all construction activities would comply with Chapter 29 of the CBC, which regulates i excavation activities and the construction of foundations and retaining walls, and Chaptcr 70 of €43E Chapter 17.05 of the City's Municipal Code, which regulates grading activities, including drainage and erosion control. Compliance with this permit process and the CBC requirements would minimize effects from erosion. Therefore, compliance with the Statewide General Construction Activity Stormwater Permit requirements and the CBC requirements would ensure that erosional impacts resulting from project construction would be less than significant. 3.6.5 Cumulative Impacts This cumulative impact analysis considers development of the proposed project, in conjunction with other development within the vicinity of the project in the City of Huntington Beach. Risks associated with --I 2-38 City of Huntington Beach Chapter 2 Text Changes � • r� "'�+'' . `.Fw:.' . i ° ygq,.//✓' '� -i Y".Lt f/X.D -: '.. ,` W. Table 3.7-3 Regulatory Database Search Results for Sites within One Mile Proximity to Facility Name Project Site(Miles) Location Database Wind&Sea Surfboards 0.25 520 Pacific Coast Highway LUST Wind and Sea Surfboard Shop 0.25 520 Pacific Coast Highway LUST Java Jungle 0.25 602 Pacific Coast Highway LUST Not reported 0.50 414 11th Street CHMIRS Old Lake Fire Station 0.50 704 Lake Street CORTESE Arco(Abandon) 0.50 21302 Pacific Coast Highway CORTESE Action Boats 0.50 21622 Coast Highway CORTESE Database acronyms: RCRIS—The Resource Conservation and Recovery Act database includes selected information on sites that generate,store,treat,or dispose of hazardous waste as defined by the act.The source of this database is the U.S.EPA. CHMIRS—The California Hazardous Material Incident Report System contains information on reported hazardous material incidents,i.e.,accidental releases or spills.The source is the California Office of Emergency Services. CORTESE—This database identifies public drinking water wells with detectable levels of contamination, hazardous substance sites selected for remedial action,sites with known toxic material identified through the abandoned site assessment program,sites with USTs having a reportable release and all solid waste disposal facilities from which there is known migration.The source is the California Environmental Protection Agency/Office of Emergency Information. LUST—The Leaking Underground Storage Tank Incident Reports contain an inventory of reported leaking underground storage tank incidents.The data come from the State Water Resources Control Board Leaking Underground Storage Tank Information System: UST—The Underground Storage Tank database contains registered USTs.USTs are regulated under Subtitle I of the Resource Conservation and Recovery Act(RCRA).The data come from the State Water Resources Control Board's Hazardous Substance Storage Container Database. CA FID—The Facility Inventory Database contains active and inactive underground storage tank locations.The source is the State Water Resource Control Board. HIST UST—Historical UST Registered Database. HAZNET—The data are extracted from the copies of hazardous waste manifests received each year by the DTSC. Data are from the manifests submitted without correction,and therefore many contain some invalid values for data elements such as generator ID,TSD ID,waste category,and disposal method.The source is the Department of Toxic Substance Control. SOURCE: Environmental Data Resources,Inc.,2003 As shown in Table 3.7-3, 10 LUST cases are within one mile of the project site. Of these 10 cases, all but one (Java Jungle) has been closed (i.e., the tank has been either replaced or removed, and contamination has been remediated). A preliminary site assessment is currently underway at the one remaining facility. Other Contaminants on Adjacent Propert.e_Former Uses on the Project Site According to the 1995 environmental site assessment prepared for the Huntington Shores Motel (HLA 1995), the The property north of the project site, located at First Street and Atlanta and currently occupied by residential uses, was reportedly occupied by a former gas plant, as identified by an individual interviewed as part of the 1995 site investigation process_ for the Huntington Shares—Mettet- ewe Federal Supply Company in 1922 and Richfield Oil Company in 1939 (dc Barros and Crull 2002). Subsequent consultation with the individual previously interviewed 'revealed that this facility was a gas compressor plant, which did not process gas or petroleum product. Rather, it served as a compressor system that conveyed gas from the oil field beneath the project site, and delivered it to a gas plant located at the intersection of Palm Avenue and Goldenwest Street. Gas was drawn from the former oil field through a pipeline connected to the compressor plant, and then transferred to Pacific City EIR 2-39 Chapter 2 Text Changes the gas plant at Palm Avenue and Goldenwest Street (personal communication, Rick Sailor 2003). Natural gas remained fully enclosed within the intake pipe and the plant itself. In addition, this facility was not located on the adjacent property as reported in previous documents, but instead was present on the project site. The facility's location was confirmed by information contained in the Supplemental Soil Investigation Work Plan submitted by Blasland, Bouck & Lee, Inc. (BBL) to the City of Huntington Beach Fire Department. oil uses on the property, but no documentation exists to support thc existence of a gas plant. If a gas plant did exist on property adjacent to thc project sitc, toxic contaminants associated with gas l wcvcr, `z �esc-eui t-aittihairtstcorrlll-1., to thc project sitc. The Phase I ESA for the project site did not identify any potential concerns these contaminants arc not expected to exist on the northwestern portion of thc sitc or otherwise affcct soils on thc project siteThis facility was demolished and all identified stained and odorous soil were excavated and removed from the project site in the late 1960s to early 1970s (BBL 2003). The sampling effort that would occur on the eastern portion of the site would ensure that contamination related to former oil field activities is identified. Contamination at the Project Site Environmental concerns at the project site are typical of that of former oil field properties and include residual total petroleum hydrocarbon (oil) contamination in the soil, possible methane (natural gas) emissions, unclosed oil wells, and small quantities of chemical and/or heavy metal- impacted soil. The Phase II Investigation Report prepared in 1996 for the project site identified 10 AST settings, former locations of pipelines and pipeline headers (only one pipeline header was actually found during this field investigation), 20 abandoned oil wells, and one abandoned water well at the project site. In addition, no use, storage, or disposal of hazardous substances or materials was present on the project site at the time the Phase II Investigation Report was prepared. According to the subsequent Phase I analysis prepared in 1998, a site reconnaissance indicated that no USTs and ASTs remained on the project site. (--- Overview of Site Remediation Process As the project site is undergoing remediation, and the site remediation process involves several steps to document contamination, remediation, and site cleanup, this section provides an overview of this process to facilitate an understanding of the previous and current investigations. As a first step, a Phase I Environmental Site Assessment(ESA) is used for information purposes by identifying potential environmental impacts related to hazardous materials through historical record searches, visual inspection, aerial photograph review, etc. This assessment is conducted in general accordance with E1527-00 — American Society for Testing and Materials (ASTM) "Standard Practice for Environmental Site Assessments: Phase I Initial Site Assessment Process."The Phase I ESA must be conducted by a qualified environmental professional (e.g., Registered Environmental Assessor, Registered Geologist, Professional Engineer, etc.). The necessity of further investigation (i.e., a Phase II ESA) is based on the findings of the Phase I ESA. A Phase II ESA consists of analytical testing of potentially contaminated soil, groundwater, or other materials. If contamination is identified, then a project sponsor or property owner would enter into a corrective action agreement with the local oversight agency after confirmation of any identified environmental concerns from the Phase II ESA. The local oversight agency is the City of Huntington Beach Fire 2-40 City of Huntington Beach Chapter 2 Text Changes Department for this project. Concurrence of appropriate remedial action with the oversight agency must be obtained when impacts to soil, groundwater, or other materials have been identified above acceptable local, State, or federal contaminant levels or preliminary remedial goals. The target cleanup levels for the proposed project site are 1,000 milligrams per kilogram (mg/kg) total recoverable petroleum hydrocarbons (TRPH) for residential uses and 2,000 mg/kg.TRPH for commercial uses. These remediation goals are in II Pacific City EIR 2-41 Chapter 2 Text Changes ._,.w„,_v......3„.,w„, �„ a ;r-�'^�z»s- °� - ..8�,�,y,g �,� - "•�.- *x,y�,,�,'V"Y'.,.� -,�._.� - i�: s � W � � located within the site. Remediation of these areas is proposed to occur concurrent with project construction since remediation of the areas would entail grading of the site. The location of the archaeologically sensitive areas is not disclosed in this EIR in order to protect the integrity of the resource. As such, the precise location of this portion of Area C is not identified. The area where further investigation is necessary is Area D, in the southwestern portion of the site, where the former Grinder Restaurant and Huntington Shores motel were located. These areas do not include identified former oil wells or storage tanks. Sampling completed as part of the 1996 Phase II Investigation delineated the areas where remediation was necessary. Test results from that sampling effort did not detect that the contamination on the northern and eastern portions of the site had migrated to this area on the western portion of the site. BBL intends to perform sampling in Area D to ensure that all potential contamination has been identified. According to the 2002 Remediation Plan, further soil investigations were conducted on the project site to evaluate the depth of petroleum hydrocarbon-impacted soils near groundwater. The detailed report (i.e., boring logs, etc.) on this soil investigation has not been completed. Three samples were extended 4 to 5 feet past groundwater in three of the areas previously identified as containing elevated concentrations of petroleum hydrocarbons. In cases where petroleum hydrocarbons in the soil have extended to groundwater, the extent of soil impacted with petroleum hydrocarbons is generally limited to within one to two feet of first encountered groundwater and the petroleum hydrocarbon impacted soil appears to have minimal impact on groundwater (Harding ESE 2002b). As discussed in Section 3.8 (Hydrology and Water Quality), groundwater beneath the project site is also brackish due to saltwater intrusion, and, as such, is not used as potable water by the City. Lead-Impacted Soils Aside from oil-impacted soils, the 1996 Phase II Investigation also indicated the detection of lead- impacted soil in the south-central portion of the project site. In May 1997, approximately 10 cubic yards of lead-impacted soil were excavated to a depth of approximately 4 feet from a 12-foot by 7- foot area at the project site. All soil samples collected from the excavation, following the removal of the impacted soil, contained soluble lead at concentrations below 5 parts per million (ppm) in accordance with the City of Huntington Beach Soil Clean-Up Standard Specification 431-92 (City Specification 431-92). 41,e-Qalifurnia Codc of Rcgulations (CCP)Titic 22 action lcvcl of 5 parts per titilliett-qtypi ). The excavation area was backfilled with clean native soil located on the project site. In June 1997, the excavated lead impacted soil was transported under a non-Resource Conservation and Recovery Act(RCRA) hazardous waste manifest to the Laidlaw Class I Landfill in Buttonwillow, California. Completion of removal of lead-impacted soil has also been documented (BBL 1997). 2-42 City of Huntington Beach Chapter 2 Text Changes Page 18 jr.1 addition, exposure to contaminants could occur if these contaminants migrated from the contaminated zone to surrounding areas either before or after the surrounding areas were developed, or if contaminated zones were disturbed by future development at the contaminated location. Although it is not anticipated, due to the extensive testing, characterization and remediation already completed to date, the potential exposure of construction personnel or the public to remnant hazardous substances from former on-site uses and facilities at the project site exists, and this would be a potentially significant impact. Impact HAZ-2 Grading and excavation of the site could result in damage to existing abandoned oil wells. As discussed in Section 3.7.1 (Existing Conditions), 20 abandoned oil wells are located throughout the project site. Wells were re-abandoned in accordance with DOGGR standards between 1997 and 1999. Because development would occur over a majority of these wells with the proposed project, the potential exists for grading and excavation activities to damage these abandoned oil wells during construction of the project. In addition, the proposed underground parking structures serving the project would extend down to approximately 22 feet below ground level. There is the possibility that some abandoned oil wells at the site may be located above the proposed floor grade of these structures. In this case, these abandoned oil wells would need to be cut and reabandoned. Procedures would comply with City Specifications 422 and 429, which address well abandonment requirements and methane mitigation. If the existing oil wells are damaged, health and safety risks could be posed to construction workers and the public through exposure to well contents (by direct dermal contact and/or ingestion) or vapors, as well as contamination of the soil at the project site. In addition, soil contamination resulting from damage to existing abandoned oil wells could also spread from the contaminated zone to surrounding areas either before or after the surrounding areas are developed. As such, impacts associated with risks from existing abandoned oil wells on the project site are considered to be potentially significant. Impact HAZ-3 No residual contamination is anticipated that would affect visitors and residents of the proposed project. Although remediation of oil-impacted soils at the project site resulting from former oil production activities have mostly been completed, there remains a possibility that some contaminated soil could remain that may not have been detected. Remediation remains underway, and some remediation would occur during project construction in conjunction with monitoring of the areas of archaeological sensitivity and relocations of the existing water pipeline. Due to the migratory nature of oil in the soil, the risk remains for oil contamination to exist in soil areas that have not been previously trenched for sampling and investigation. Impact HAZ-1 identifies risks to construction workers and the public due to potential on-site contaminants. Mitigation measures detailed below would ensure that any remaining contamination risks are addressed during grading and excavation activities. As such, any residual oil contamination remaining in the soil would be detected Pacific City EIR 2-43 l i Chapter 2 Text Changes CR HAZ-A Prior to issuance of grading permits, the project shall comply with all provisions of the Huntington Beach Fire Code and Fire Dept. City Specifications 422 and 431 for the abandonment of oil wells and site restoration. CR HAZ-B Prior to the issuance of grading permits and during construction, the project shall comply with all provisions of the HBMC Section 17.04.085 and Fire Dept. City Specification 429, Methane District Building Permit Requirements. CR HAZ-C The development shall comply with all applicable provisions of the Municipal Code, Building Division, and Fire Department as well as applicable local, State and Federal Fire Codes, Ordinances, and standards. In addition to the standard City requirements listed above, mitigation measures (MM) would be required to address project impacts. The following mitigation measures would be required to address potentially significant impacts associated with exposure of construction personnel and the public to contaminated soil, as described under Impact HAZ-1. The overall intent of these mitigation measures is to ensure remediation of contaminated soils prior to proposed development. MM HAZ-1 Prior to the issuance of a grading permit, a Registered Environmental Assessor shall perform a site inspection to ident f, the potential for presence of PCBs on the site. If the potential for PCBs exists, then the Applicant shall, in consultation with the City of Huntington Beach, sample soil surrounding the affected areas to identify the extent of contamination. Contamination shall be remediated in accordance with MM HAZ-3 and MM HAZ-4. MM HAZ-2 Prior to the issuance of a grading permit, sampling shall be performed in the area identified in Figure 3.7-1 as"Area D."The extent of sampling shall be determined by the Huntington Beach Fire Department as that which is appropriate to characterize the extent of any potential contamination in Area D. Contamination shall be remediated in accordance with MM HAZ-3 and MM HAZ-4. MM HAZ-3 Prior to issuance of a grading permit, the Applicant shall, in consultation with the City of Huntington Beach and other agencies, as required,formulate a remediation plan for further soil contamination that exists on the project site. The plan shall include procedures for remediation of the project site to the City of Huntington Beach standards. Plans shall be submitted to the Planning, Public Works, and F; . Departments for review and approval by the Planning, Public Works, and Fire Departments in accordance with City Specification No. 431-92. The plan shall include methods to minimize remediation-related impacts on the surrounding properties, including processes by which all drainage associated with the remediation effort shall be retained on site and no wastes or pollutants shall escape the site and requirements to provide wind barriers around remediation equipment. Qualified and licensed professionals shall perform the remediation activities and all work shall be performed under the supervision of the City of Huntington Beach. MM HAZ-4 Closure reports or other reports acceptable to the City Fire Department that document the successful completion of required remediation activities for contaminated soils, in accordance with City Specification 431-92, shall be submitted and approved by the City Fire Department prior to issuance of grading permits for site development. No construction shall occur on-site until reports have been accepted by the City. Closure 2-44 City of Huntington Beach Chapter 2 Text Changes reports will not be required in the area identified in Figure 3.7-1 as "Area C"until remediation of this area has occurred as part of project construction; these reports will be required pursuant to MM HAZ-6. If remediation is necessary pursuant to MM HAZ-3, then gradingsoil remediation permits for this rcmediation shall be issued. MM HAZ-5 In the event that previously unknown soil contamination that could present a threat to human health or the environment is encountered during construction, construction activities in the immediate vicinity of the contamination shall cease immediately. A risk management plan shall be prepared and implemented that (1) identifies the contaminants of concern and the potential risk each contaminant would pose to human health and the environment during construction and post-development and(2) describes measures to be taken to protect workers and the public from exposure to potential site hazards. Such measures could include a range of options, including, but not limited to, physical site controls during construction, remediation, long-term monitoring, post-development maintenance or access limitations, or some combination thereof. Depending on the nature of contamination, if any, appropriate agencies shall be notified (e.g., City of Huntington Beach Fire Department). A site health and safety plan that meets OSHA requirements shall be prepared and in place prior to the commencement of work in any contaminated area. The developer shall ensure proper implementation of the health and safety plan. MM HAZ-6 Closure reports documenting the successful completion of required remediation activities for (1) areas adjacent to the existing water main on site and (2) areas of archaeological sensitivity shall be submitted and approved by the City Fire Department prior to'issuance of building permits in these areas. The following mitigation measures would be required to address potentially significant impacts associated with damage to existing abandoned oil wells at the project site, as described under Impact HAZ-2. MM HAZ 7 Where construction is proposed over abandoned oil wells, the developer shall consult with DOGGR to determine if plug or replug of wells is necessary. Prior to the issuance of grading permits, the Applicant shall submit evidence of consultation with DOGGR indicating wells have been plugged or abandoned to current DOGGR standards. Pacific City EIR 2-45 Chapter 2 Text Changes On-Site Drainage Patterns The on-site drainage area boundary is approximately 34.6 acres and includes the project site as well as approximately3.1 acres along Huntington Avenue and PCH. All on-site flows are currently directed via sheet flow and a graded ditch to an inlet located at the southeastern end of the site (refer to Figure 3.8-3). Table 3.8-1 Pre-Development Drainage Conditions (Post-1986 Values) Storm Event(Year) On-Site Area(cfs) 25 48.6 100 67.0 SOURCE: Drainage Study and Hydrology Analysis by Hunsaker&Associates Irvine,Inc.,dated April 14,2003 Water Quality Stormwater pollutants include a wide array of environmental, chemical, and biological compounds from both point and nonpoint sources. In the urban environment, stormwater characteristics depend on site conditions (e.g., land use, perviousness, pollution prevention),rain events (duration or intensity), soil type and particle size, multiple chemical conditions, the amount of vehicular traffic, and atmospheric deposition. The EPA estimates that short-term runoff from construction sites, without adequate erosion and runoff control measures, can contribute more sediment to receiving waters than that deposited by natural processes over a period of several decades. Stormwater quality in the City of Huntington Beach is typical of most urban areas in that it includes a variety of common contaminants. These pollutants consist primarily of suspended sediments, fertilizers and pesticides, animal waste, and contaminants that are commonly associated with automobiles (e.g., petroleum compounds such as oil, grease, and hydrocarbons). In addition, urban stormwater often contains high levels of soluble and particulate heavy metals generated from traffic, industrial facilities, and occasionally, residential sources. These metals are frequently found in concentrations that are harmful to aquatic life and other biota dependent on aquatic life as a food source. Two of the most common metals found in both the water column and sediments are zinc and copper. Zinc tends to exhibit toxicity effects in the fresh water environment; copper exhibits toxicity characteristics in the marine environment. II 2-46 City of Huntington Beach Chapter 2 Text Changes The ASWPS provides water quality protection for urban runoff. During dry weather and low-flow drainage' events, the water from the ASWPS is discharged into the Orange County Sanitation District (OCSD) sewer lines. This allows for treatment of nuisance runoff. OCSD and the City have acknowledged that certain types 'of dry-weather urban runoff create public health and/or environmental problems. As the OCSD has limited available capacity in its system to allow some dry-weather runoff to be accepted, dry weather flows in portions of the City are discharged to the OCSD, although not all runoff in the City is treated. A permit issued by the OCSD authorizes the ASWPS diversion. This permit has numerous requirements, including water quality limits. Should any of these requirements be violated, the permit can be revoked and this option would no longer be feasible for the City. The majority of pollutants are transferred from impervious surfaces to receiving waters during nuisance flow conditions. Treatment of dry-weather flows is not required by the RWQCB; rather, it allows for additional water quality protection. Treatment of flows by OCSD also allows for reductions in bacterial contaminants present in stormwater flows, although no water quality standards have been adopted to address bacterial levels in runoff. Tsunami Tsunamis are seismically generated sea waves caused by sea-floor displacements (faulting or landslides), or similar large-scale, short-duration phenomena, such as volcanic eruptions. The tsunami warning system in the United States is a function of the National Oceanic and Atmospheric Administration's (NOAA) National Weather Service. When a large earthquake occurs near the coast in the North Pacific, the regional warning system in Alaska, known as the Alaska Tsunami Warning Center (ATWC), determines the location (epicenter) and magnitude of the event. If an earthquake is considered to be great enough to generate a tsunami, the ATWC will issue an immediate"Tsunami Warning"for the area near the epicenter. This warning is issued through state emergency services offices, Coast Guard, military, FAA, National Weather Service, and other agencies. The elevation of the tsunami run-up beyond the initial tidal elevation can be generally estimated from "maximum" past occurrence in California (estimated at 4 or 19 feet) from distant (South Pacific-South America-Alaska) or local (Santa Barbara Channel) earthquakes. The City of Huntington Beach Emergency Management Plan predicts the following wave heights, exclusive of tide and storm-generated wave heights, for a 100-year and 500-year tsunami occurrence: 100-year Occurrence 500-year Occurrence 4.0 feet minimum 6.8 feet minimum 6.6 feet average 114 feet average 9.2 feet maximum 16.0 feet maximum No known tsunami has ever reached the Orange County coast, but in 1964, following the Alaska 8.2 earthquake, tidal surges of approximately four to five feet hit the Huntington Harbor area, causing moderate damage. The tsunami threat to the City of Huntington Beach is considered low to moderate. Because tsunamis result from large offshore earthquakes and ocean landslides, local earthquakes would not generate a tsunami in the City. Because the City of Huntington Beach has southwestern-facing beaches, the City is vulnerable to tsunamis or tidal surges from the south and from the west. According to the City of Huntington Beach General Plan, the eastern portion of the project site is Pacific City EIR 2-47 Chapter 2 Text Changes located in a moderate tsunami run-up area (Figure 3.8-4). Of the six Huntington Beach Primary Danger Areas for tsunamis, which are listed in order of priority, the project site is located in "Primary Danger Area 4" under the City of Huntington Beach Emergency Management Plan. The suggested evacuation site for a tsunami incident in "Primary Danger Area 4" is Westminster High School, located at 14325 Golden West Street in Westminster. 3.8.2 Regulatory Framework The following subsection is brief summary of the regulatory context under which surface and groundwater resources are managed at the federal, State, and local level. Clean Water Act The 1972 amendments to the Clean Water Act (CWA) prohibit the discharge of pollutants to navigable waters from a point source (a discharge from a single conveyance such as a pipe) unless the discharge is authorized by a National Pollutant Discharge Elimination System (NPDES) permit. In 1987, in recognition that diffuse, or nonpoint, sources were significantly impairing surface water quality, Congress amended the CWA to address nonpoint source stormwater runoff pollution in a phased program requiring NPDES permits for operators of municipal separate storm sewer systems (MS4s), construction projects, and industrial facilities. The purpose of the NPDES program is to establish a comprehensive stormwater quality program to manage urban stormwater and minimize pollution of the environment to the maximum extent practicable (MEP). The NPDES program consists of (1) characterizing receiving water quality, (2) identifying harmful constituents, (3) targeting potential sources of pollutants, and (4) implementing a Comprehensive Stormwater Management Program (CSWMP). The State Water Resources Control Board(SWRCB) has adopted a statewide General Permit(WQ Order 99-08-DWQ) for stormwater discharges associated with construction activity. These regulations require that all construction activity subject to this permit including clearing, grading, and disturbances to the ground such as stockpiling or excavation prohibit the discharge of stormwater from construction projects that include 1 acre 5 acres or more of soil disturbance, unless the discharge is in compliance with the NPDES Phase 1 General Permit. Construction activities subject to this permit include clearing, grading, and other disturbance to the ground, such as stockpiling, or excavation that results in soil disturbance of at least 1 acre 5 acres of total land area. In addition, as required by NPDES,because construction on the project site would occur over an area greater than 1 acre, the developer would be required to submit a Notice of Intent (NOI) to the SWRCB for coverage under the permit and would be required to comply with all its requirements. 2-48 City of Huntington Beach - Chapter 2 Text Changes The NPDES General Permit requires all dischargers to (1) develop and implement a Stormwater Pollution Prevention Plan (SWPPP), which specifies Best Management Practices (BMPs); (2) eliminate or reduce nonstormwater discharge to storm sewer systems; and (3) develop and implement a monitoring program of all BMPs specified. The two major objectives of the SWPPP are to (1) help identify the sources of sediment and other pollutants that affect the water quality of stormwater discharges and (2) to describe and insure the implementation of BMPs to reduce or eliminate sediment and other pollutants in stormwater as well as nonstormwater discharges. Basin Plan Existing water quality issues have been identified in the watershed planning process and are incorporated in the Water Quality Control Plan (WCQPWQCP) for the Santa Ana River Basin (Basin Plan). The Basin Plan designates beneficial uses of the waters of the region and specifies water quality objectives intended to protect those uses. The Basin Plan also specifies an implementation plan describing actions that are necessary to achieve and maintain water quality standards, and regulates waste discharges to minimize and control their effects. No water quality standards have been set for bacteria levels. Dischargers must comply with the water quality standards contained in the Basin Plan, and the proposed project would, therefore,be required to be consistent with this plan. Orange County Drainage Area Management Plan In order to ensure that construction sites implement the appropriate pollution control measures, the 2003 Orange County Drainage Area Management Plan (DAMP) details recommended BMPs to be applied to new development and significant redevelopment in Orange County. Projects are identified as either priority projects or non-priority projects. Priority projects include, but are not limited to, residential development of 10 units or more, commercial and industrial development greater than 100,000 square feet, including parking area, impervious surface of 2,500 square feet or more located within, directly adjacent to (within 200 feet), or discharging directly to receiving waters within Environmentally Sensitive Areas, and parking lots 5,000 square feet or more, with 15 parking spaces or more, and potentially exposed to urban stormwater runoff. The proposed project would be considered a priority project under the 2003 DAMP Model Water Quality Management Plan (WQMP). These regulatory requirements regulations require that the project incorporate and implement all source control BMPs (routine structural and routine non-structural), unless not applicable to the project due to project characteristics, and document clearly why any applicable source control BMP was not included; incorporate and implement site design BMPs, as appropriate, and document the site design BMPs that are included; and either incorporate and implement treatment control BMPs, by including a selection of such BMPs into the project design;. or participate in or contribute to an acceptable regional or watershed-based program. Projects participating in a regional or watershed program will also implement source control BMPs and site design BMPs consistent with the requirements of the approved regional or watershed-based plan. The combination of source control, site design, and treatment control BMPs or regional or watershed-based programs must adequately address all identified pollutants and hydrologic conditions of concern. These regulations are designed to ensure that stormwater quality management is considered during a project's planning phase, implemented during construction, and maintained for the life of the project. Routine structural BMPs may function either to minimize Pacific City EIR 2-49 Chapter 2 Text Changes the introduction of pollutants into the drainage system or to remove pollutants from the drainage system. Applicable structural and nonstructural BMPs implemented on the site for source control and pollution prevention to minimize the introduction of pollutants into the drainage system would depend on the ultimate configuration of the proposed land use. Appropriate residential and retail/office center nonstructural BMPs listed in the DAMP that may be used on site to control typical runoff pollutants include homeowner/tenant education, activity restrictions, common area landscape management, BMP maintenance, common area litter and animal waste control, catch basin inspection, employee training, and private street/lot sweeping. BMPs can serve to address bacterial contaminants in addition to other contaminants, although there are no water quality standards set for bacteria levels. The proposed project would include these BMPs and would therefore be consistent with this plan. 2-50 City of Huntington Beach - Chapter 2 Text Changes 3.8.4 Project Impacts Impact HYD-1 The proposed project would not violate water quality standards, waste discharge requirements, result in substantial sources of polluted runoff,or otherwise substantially degrade water quality. For the purposes of this analysis, effects from violation of water quality standards, waste discharge requirements, or degradation of water quality would be considered significant if discharges associated with the project would (1) create pollution, contamination, or nuisance as defined in Section 13050(k) through (m) of the California Water Code or (2) cause regulatory standards, as defined in the applicable NPDES stormwater permit number CAS618030, Water Quality Control Plan or the City's Stormwater and Urban Runoff Management Ordinance for the receiving water body, to be violated. Alterations to the existing drainage pattern of the site or area that would result in substantial additional polluted runoff as, defined by Water Code Section 13050(k) through (m), would be considered significant if the project affects the rate or change in the direction of movement of existing contaminants or expands the area affected by contaminants. Construction Discharges As noted above in Regulatory Framework, the proposed site is greater than 5 acres 1 acre in size, and is subject to the provisions of the General Construction Activity Stormwater Permit adopted by the SWRCB. One of the purposes of this permit is to ensure minimal water quality effects from stormwater runoff. The developer for the proposed project must submit a Notice of Intent (NOI) to the SWRCB for coverage under the Statewide General Construction Activity Stormwater Permit and must comply with all applicable requirements, including the preparation of a Stormwater Pollution Prevention Plan (SWPPP), applicable NDPES regulations, and BMPs. Pacific City EIR 2-51 Chapter 2 Text Changes A Preliminary Water Quality Management Plan (PWQMP) has been developed for the project and outlines the comprehensive approach that would be used in the attainment of water quality goals required for the proposed project (Appendix G). This plan conforms to the NPDES Permit and current DAMP, and supports the City's commitment to the protection and enhancement of coastal water quality. The plan also complements the goals and mission statement of the City of Huntington Beach Citywide Water Quality Management Plan Task Force. The PWQMP serves as the foundation of the final WQMP and explains the methodology used to determine the types of management practices that are best suited for the proposed project, to achieve the required water quality levels as detailed by the DAMP and local requirements. The PWQMP includes filtration (treatment of runoff from the site) as a key component of the overall system. Pollutant loads for existing and developed conditions were calculated to determine recommendations and requirements for filtration. These requirements would be achieved on the project site through the use of a series of state-of-the-art pollutant filters incorporated into the storm drain system. These filters are described in technical detail in the drainage report prepared by Hunsaker & Associates (Appendix G). In conjunction with these filters, a screening unit is proposed, which would provide additional screening of stormwater and is primarily focused on the treatment of trash, debris, and larger solids. On-site drainage areas would have first-flush and dry weather flows treated by these systems. After treatment, the 85-percentile 24-hour storm event or the maximum flow rate of runoff produced from a rainfall intensity of 0.2 inch per hour first-flush and dry weather flows would be discharged into the storm drain system in Pacific View Avenue, as well as into the drainage system in First Street that is proposed as part of the project, and further discussed in impact HYD-2. If additional treatment of petroleum hydrocarbons is required, specialized filtration inserts can be installed to reduce these pollutants. In addition, as part of the comprehensive stormwater treatment plan, the proposed project would incorporate the requirements of DAMP-Section 7, including all feasible recommended BMPs. Other BMPs may include programs to educate the public on the proper disposal of hazardous/toxic wastes, pickup and disposal of animal feces, regulatory approaches, and detection and elimination of illicit and illegal dumping. Plans for grading, drainage, and erosion control would be reviewed by the City Engineer prior to issuance of grading permits. With implementation of these BMPs and the WQMP, all impacts related to water quality would be reduced to the maximum extent practicable, as required by the DAMP and City regulations_;In addition to ensuring that the project meets current water quality standards—including those for non-point sources of contamination— these BMPs would also reduce the potential for bacterial contaminants in runoff,, and would be considered less than significant. The proposed project does not currently anticipate the need for dewatering for the development. Should site conditions or future project revisions require a dewatering program, the program would be developed in accordance with the California Regional Water Quality Control Board, Santa Ana Region, Order No. 93-49, NPDES Permit No. CAS618030, and Template Monitoring and Reporting Program No. 98-67. 2-52 City of Huntington Beach Chapter 2 Text Changes 'Pa 1 .; '. ,"ate#tr^.54F P_ - x ��.°" • -• Table 3.8-7 Projected Drainage Conditions(in cfs) Drainage Area"B"—prior to Drainage Area"B"— Storm Event(Year) Drainage Area"A" detention post-detention 25 16.7 66.1 20.0 100 21.8 85.2 20.0 SOURCE: Drainage Study Including Preliminary Hydrology Analysis and Water Quality Analysis,Hunsaker&Associates,April 14,2003a. Drainage Impacts—Area "A" Area"A"would be serviced by a proposed system of inlets and underground pipe conduits joining the existing 42-inch storm drainpipe at the intersection of Pacific View Avenue and Huntington AventteStreet. With implementation of the proposed project, a maximum of 21.8 cfs would be permitted to be discharged into the existing 42-inch pipe in Pacific View Avenue. Drainage Area "A"has been sized appropriately to this discharge limit for estimates of a discharge of 21.8 cfs in a 100-year event. The expected discharge to the ASWPS is well below both the designed allowable discharge of 34.4 cfs and the current condition of 67.0 cfs discharged during a 100-year event(refer to Appendix G, Section 1, page 4). Drainage Impacts—Area "B" The storm flows from Drainage Area"B" would flow west to First Street. The project proposes to construct a storm drain line in First Street that would exclusively serve the project site. This line would run parallel to the existing City 36-inch line in First Street. The project-specific storm drain line would then connect to the City's 36-inch South Beach Storm Drain south of PCH. As required by the City Public Works Department, the project would be limited to flows of 20 cfs from Drainage Area"B,"based on overall planned pipe capacity of the City system. As shown in Table 3.8-7, post-project hydrology of Area"B"would result in runoff of 66.1 cfs in a 25-year storm event. As a result, a reduction in discharge of about 46 cfs would be required in order to limit the discharge to 20 cfs. An on-site underground detention basin is proposed to accomplish this reduction. A volume of about 0.82 acre-feet is required for the required reduction in discharge. Flows exceeding attenuation limits would be allowed to run off via surface streets, and the drainage study has indicated that the volume of this runoff would not impact drainage systems or flood traffic lanes. According to the Orange County Local Drainage Manual, habitable structures require protection for a 100-year event. The proposed City drainage system along First Street and the proposed project Area "B" drainage system are designed to convey flows from a 25-year event. For storms above the 25-year event and up to the 100-year event, site discharges would be conveyed via surface street flow along First Street, thus meeting flood protection goals. The site is above the 100-year flood elevation defined by FEMA. Pacific City EIR 2-53 Chapter 2 Text Changes While the proposed project would alter the direction of runoff stormwater flows, the drainage alterations to the site and adherence to the requirements of the NPDES permit and the WQMP would not result in exacerbation of localized flooding; in fact, the changes in the drainage patterns, as well as the proposed detention basin, would divert a significant portion of the site's aurfaee stormwater runoff from the over-capacity ASWPS to a new storm drain system, which would be designed to ensure adequate capacity to accommodate stormwater flows from the project site. As discussed above, Drainage Area"A"would continue to flow to the ASWPS for all dry-weather and stormwater flows. In addition, only the dry weather flow for Drainage Area"B" can be routed into Area"A" and to the ASWPS, in order that, at the City's discretion, these flows may be routed for treatment by OCSD. As identified above, the stormwater flows for Drainage Area "B" would be routed to the storm drain in First Street that the applicant would construct. All flows, both dry weather and storm flow, would be treated in accordance with the City's MS4 Permit and other applicable City requirements and standards. The overall reduction of stormwater flows would be less than 5 percent. In order to ensure adequate drainage improvements, all features of the proposed system would be designed and constructed in accordance with the standards set by the City of Huntington Beach and the Orange County Flood Control District. Plans for grading, drainage, and erosion control would be reviewed by the City Engineer prior to issuance of grading permits. Therefore, with inclusion of the project features designed to minimize drainage, this impact would be less than significant. Impact HYD-3 The proposed project would contribute to a reduction of flows to the over-capacity Atlanta Stormwater Pumping Station. The ASWPS has a current capacity of 551 cfs, as noted above. The tributary area it services discharges approximately 1,125 cfs in a 100-year event. This indicates a capacity deficiency of about 574 cfs. Currently, approximately 177 cfs is discharged to the ASWPS from the Alabama Street Discharge Area, including the proposed project site. With the proposed City storm drain system along First Street and the proposed project's Area`B" drainage system, approximately 155.2 cfs in a 100-year event would be diverted away from the ASWPS. With implementation of the proposed project, the northerly, easterly, and southerly perimeter area shown as Drainage Area "A" on Figure 3.8-5, or 21.8 cfs, would discharge to the existing 42-inch pipe, located in Pacific View Avenue, that discharges to the ASWPS. This would be a net reduction of about 85 percent. Design flows to the ASWPS can therefore be reduced from 1,125 cfs to 968.8 cfs as a result of the diversion of flows and the capacity deficiency reduced from 574 to 396 cfs. Thus, a beneficial impact would result from implementation of the proposed project, in that stormwater flows to the ASWPS would be substantially reduced and fall below the design capacity of the ASWPS. Impact HYD-4 The proposed project would result in the placement of additional structures in an area of low to moderate tsunami risk. Inundation by tsunami would be considered significant if the project would substantially intensify tsunami hazards and as a result, substantial damage to structures or infrastructure, or exposure of people to this risk would result. Due to its location on the coast, the City of Huntington Beach is subject to potential run-up and tsunami damage from both distant and locally generated tsunamis. The eastern portion of the project 2-54 City of Huntington Beach F Chapter 2 Text Changes As the City of Huntington Beach is within a developed urban setting, it is not expected that full implementation of the City of Huntington Beach General Plan would result in the conversion of large amounts of open space to urban uses, and it is therefore not expected that there would be a significant increase in runoff in the City as a whole. Most of the drainage system in the watershed consists of engineered storm channels and, therefore, is expected to experience little change. Additionally, the proposed project was considered under the City of Huntington Beach's Master Plan of Drainage and, with the planned improvements to the City's storm drain system and project infrastructure, adequate drainage infrastructure would be available. Additionally, future development would be required to comply with stormwater discharge laws and to obtain the proper permits. Consequently, cumulative impacts would be less than significant with regard to this potential impact. The contribution of the proposed project to cumulative impacts on hydrology and water quality is less than significant, because stormwater flows are not expected to increase significantly, which could increase pollutant loads. overall, and because the project would result in a decrease in Project design and reduction of flows to the Atlanta Stormwater Pumping Station; which would be a beneficial effect impact of the project. Cumulative development would not substantially alter the existing drainage pattern of the area, including the alteration of the course of a stream or river, in such a manner that would result in substantial erosion or siltation, flooding, or the exceedance of existing or planned stormwater drainage systems. Implementation of NPDES Phase I and II requirements are designed to ensure that cumulative development does not result in higher-than-allowed concentrations of pollutants in stormwater discharges, and appropriate stormwater treatment would ensure that discharges into the ocean would not violate water quality standards. Extensive development is not anticipated in the remaining open spaces in the Talbert Watershed, and it is unlikely that substantial alteration of drainage systems and watercourses in those areas would occur. This indicates that the amount of runoff would not substantially increase, thereby avoiding substantial increases in erosion, siltation, flooding, and preventing the exceedance of capacity of the stormwater drainage system. As a consequence, it is not expected that impacts would be cumulatively considerable, and the project would have a less-than-significant contribution to this effect. Cumulative development is not expected to otherwise substantially degrade water quality. Substantial increases in runoff are not expected to occur, and compliance with NPDES requirements and CEQA mitigation would ensure that water quality in the watershed is not degraded by future development. Additionally, project compliance with NPDES requirements and the small amount of runoff would ensure that the project contribution to cumulative impacts is also less than significant. Cumulative impacts would, therefore, be less than significant. Pacific City EIR 2-55 Chapter 2 Text Changes As shown, cumulative development would result in noise level increases of 0.0 to 3.0 dBA Ldn along the studied roadways, with the maximum increase occurring along Beach Boulevard from PCH to Atlanta Avenue. The future noise levels along two roadway segments would actually be reduced as a result of changes in local circulation patterns that occur under the Hunting Beach General Plan. The contribution of the proposed project would range from 0.1 dBA to 2.2 dBA. Of the 3.0 dBA increase along Beach Boulevard, the contribution of the proposed project would be 0.5 dBA. The 0.1 dBA to 2.2 dBA contribution of the proposed project to future roadway noise levels would not exceed the identified thresholds of significance and, therefore, would not be cumulatively considerable. 3.10.6 Mitigation Measures and Residual Impacts The following standard City requirements (CR) would apply to the project. CR N-A Construction shall be limited to Monday—Saturday 7:00 A.M.-8:00 P.M. Construction shall be prohibited Sundays and Federal holidays. CR N-B The Applicant shall notify all property owners and tenants within 399500 feet of the perimeter of the property of a tentative grading schedule at least 30 days prior to such grading. CR N-C The developer shall coordinate the development of a truck haul route with the Department of Public Works if the import or export of material is required. This plan shall include the approximate number of truck trips and the proposed truck haul routes. It shall spec fy the hours in which transport activities can occur and methods to mitigate construction-related impacts to adjacent residents. These plans must be submitted for approval to the Department of Public Works prior to issuance of a precise grading permit. CR N-D All haul trucks shall arrive at the site no earlier than 8:00 A.M. or leave the site no later than 5:00 P.M., and shall be limited to Monday through Friday only. CR N-E Neighbors within 409500 feet of major construction areas shall be notified of the construction schedule in writing prior to construction; the project sponsor shall designate a "disturbance coordinator"who shall be responsible for responding to any local complaints regarding construction noise; the coordinator (who may be an employee of the developer or general contractor) shall determine the cause of the complaint and shall require that reasonable measures warranted to correct the problem be implemented; and a telephone number for the noise disturbance coordinator shall be posted conspicuously at the construction site fence and included on the notification sent to neighbors adjacent to the site. 2-56 City of Huntington Beach Chapter 2 Text Changes IA � �� ,: �� z- ref ��.. x � „Es n 414 - �� �,�. .,.;�• y.,�,. ,� currently 1.8 officers per 1,000 residents (Pelletier 2003). Currently the average emergency response time within the City is approximately 7.4 minutes, while the average nonemergency response time is approximately 15.3 minutes. The HBPD indicates that the department now provides a minimum level of service to the City. HBPD utilizes the "beat cop" system, which is a new and innovative approach initiated by die City in 2000. The City is divided into twelve beat areas, and each beat is assigned an officer to provide the beat area with 24 hours per day, 7 days per week coverage. Under the Beat Command System, each beat officer is assigned the responsibility of Community Oriented Policing, which is a philosophy of working and communicating with the community to identify services needed, and problem solving in their respective beat areas. Each beat is also assigned a sergeant to supervise and assist in the Community Oriented Policing activities within the beat. The proposed project site is located in Area 4 of the City's Beat Command System. Depending on time of day and year, this beat system allows for quick response time and specific beat coverage unless officers are called upon by nearby beat officers for backup. Law enforcement services require certain equipment, in addition to staff, in order to maintain an acceptable level of service. HBPD equipment includes vehicles, radios, and mobile data terminals, which HBPD has indicated are currently adequate but are at minimum levels. Currently the HBPD has no plans for expansion. In addition to the above-listed equipment, the department also operates the HBPD Aero Unit, which manages helicopter patrols in the City. Currently, the Aero Unit operates three MD 520N series turbine powered helicopters out of the hangar facility, which is owned and operated by the City expressly for police and fire operations. The Aero Unit is made up of six police officer/pilots, one police sergeant/pilot, two mechanics, one part-time secretary, and one part-time student worker. Helicopters are equipped with communication equipment, spotlights, and infrared equipment. With the helicopter's special equipment and flight crews, the air unit increases response times to emergencies. On the scene, helicopter units can determine whether ground units are needed in order to clear officers to handle other calls, further increasing the effectiveness of the HBPD. The City is riot identified as a particularly high crime area. The California Crime Index (CCI) includes the number of major crimes in the City for a given year, including violent crimes, and offenses such as burglary and motor vehicle theft. The total CCI in 2001 for Orange County was 32,438. For individual cities, the CCI ranges from about 200 for small cities not near major urban centers such as Laguna Hills, to about 5,000 for large cities with high crime rates, such as Santa Ana. The City of Huntington Beach had a total CCI of 1,892 in the year 2001. This is comparable to the CCI in Irvine, Orange, Buena Park, and other comparably sized cities in Orange County (Department of Justice, 2001), and in keeping with the crime rate expected for a city of its size. Schools The City of Huntington Beach is served by one high school district and four elementary/junior high school districts. The Huntington Beach Union High School District (HBUHSD) operates four high schools serving students in grades 9 through 12 for the entire City of Huntington Beach as well as substantial portions of the cities of Westminster and Fountain Valley. , which includes the cntirc Pacific City EIR 2-57 \ Chapter 2 Text Changes - high schools scrving Huntington Bcach studcnts in gradcs 9 through 12. 2-58 City of Huntington Beach Chapter 2 Text Changes Page a: rt".. � u Municipal Code—Fire Code The California Fire Code, discussed above under State regulations, is adopted by the City as Chapter 17.56, Huntington Beach Fire Code, of the Municipal Code. The Fire Code include regulations concerning building standards, fire truck and apparatus access to structures, fire protection devices such as extinguishers and smoke alarms, and fire suppression training. 3.12.3 Thresholds of Significance In general, project impacts upon public services would be considered significant if existing or planned public service facilities would not be able to provide adequate service to the community as a result of project-induced population growth or concentration of population. Project impacts would be considered significant if any of the following would occur: Fire/Police/Lifeguard • Require additional emergency response personnel and/or equipment to maintain acceptable levels of service, or if project-related development results in increased response times of service providers to a degree that would adversely impact public health and safety • Require additional staff or equipment to maintain an acceptable level of service (i.e., response time, equipment suitability) • Interfere with emergency response or evacuation plans Schools • Increase the number of students at nearby schools in excess of school capacity 3.12.4 Project Impacts Impact PS-1 The current staff and equipment of the HBFD would be sufficient to meet the demands of the proposed project, although project design may not provide adequate pedestrian emergency access. The HBFD has indicated that it has sufficient facilities and staff to accommodate the needs of the proposed project and can serve the project without causing service levels to drop below current , levels (Division Chief Fire Marshall Chuck Burney, February 2003). Presently, the HBFD employs 10 personnel at Fire Station #5, which is located less than 0.5 mile from the project site and provides first-response service to the project area. Fire Station #4 employs 4 personnel and is located approximately 1 mile from the project site. Both stations have an average emergency response time to the project area of less than five minutes, which is within the established objective of the City's Growth Management Element. Considering the current station Pacific City EIR 2-59 Chapter 2 Text Changes .'3z.:S::u. ;:qi14..,.4 :Gv. >`M :YAc m.? .. ."4a�' .£: .x;x a ' �i.r A�.:«w�'m' ;:r .,,...,. locations,the population density, and call volmne, the Fire Department considers this an acceptable level of staffing and response time. As such, HBFD staff and equipment would be sufficient to ; respond to the needs of the proposed project. Due to the quantity of development proposed, the project would result in the congregation of large numbers of people on site. In aggregate, the commercial, hotel, and residential uses could result in several thousand persons on the site simultaneously. The site design includes a complex of buildings with subterranean structures, multiple access points, and multiple buildings over the 31-acre property. These project characteristics result in a need for the fire department to observe, monitor and, as necessary, control the on-site emergency systems in order to respond effectively to an emergency, should one arise, on-site. Enhanced communication systems are proposed for the subterranean parking structure that would allow radio communication in the garage. Adequate vehicular emergency access would be provided, as discussed under Impact TR-9. Vehicular access points would be designed to ensure adequate emergency access per code requirements. However, the HBFD has expressed concerns regarding emergency pedestrian access to the subterranean garage, due to the size of the garage and the need to access both levels on foot, and not solely from emergency vehicles. The subterranean garage in particular could be a constrained access point in an emergency situation whcrc vehicles arc attempting to exit the facility and emergency response personnel necda to gain entry. Without enhanced fire protection features related to emergency pedestrian access for the site, impacts on fire protection would be potentially significant. Impact PS-2 The proposed project would add residential and visitor-serving uses to the area,and would increase demands on police protection. As discussed in Section 3.12.1 (Existing Conditions), the existing service ratio of 1.1 officers per 1,000 residents is considered adequate by the HBPD. In addition, equipment required to maintain an acceptable level of service is currently adequate but at minimum levels. Implementation of the proposed project would alter the personnel-to-population ratio. The proposed project would result in a direct population increase of 1,419 persons, and would result in a slight decrease in the service ratio to 1.09 officers per 1,000 residents. Additionally, no plans for expansion of HBPD personnel levels or facilities currently exist. The permanent increase in the City's residential population resulting from the proposed project, in addition to the addition of hotel and restaurant uses that would include nightlife activities could increase the service calls to the HBPD. Future entertainment uses would require a separate entertainment permit to be approved by the Police c Department. Security concerns related to these uses would be addressed through the permit process, at which time the Police Department would have the opportunity to review the proposed uses and provide input on necessary security measures. The proposed project does not include any features that would make it particularly susceptible to criminal activity. Residential buildings would be individually secured with gates at courtyard entrances and all entrances into individual buildings. Access to garages on First Street and Huntington Street and to stairs leading into the subterranean parking garages would be gated. Vehicular privacy gates are also proposed at 2-60 City of Huntington Beach Chapter 2 Text Changes c �, r70 ter , fit.. ,�M�=.:.�..s.. •, • CR PS-A Automatic sprinkler systems shall be installed throughout. Shop drawings shall be submitted and approved by the Fire Department prior to system installation. (FD) CR PS-B Fire hydrants must be installed before combustible construction begins. Prior to installation, shop drawings shall be submitted to the Public Works Department review and .ppnitedapproval by the Public Works and Fire Departments. (Fire Dept. City Specification 407). (FD) CR PS-C Prior to issuance of combustible construction,fire access roads shall be provided in compliance with Fire Dept. City Specification 101426. Include the Circulation Plan and dimensions of all access roads. Fire lanes will be designated and posted to comply with Fire Dept. City Specification No. 415. (FD) CR PS-D The development shall comply with all applicable provisions of the Municipal Code, Building Department, and Fire Department as well as applicable local, State, and Federal Fire Codes, Ordinances, and standards. Note: This condition of approval also applies to other resources such as geology and hazards. In addition to the standard City requirements listed above, mitigation measures (MM) would be required to address project impacts. Implementation of the following mitigation measures would be required to address impacts on fire protection, as described under Impact PS-1: MM PS-I Provide enclosed,fire-rated stairs to each subterranean level from the exterior every 300'lineal feet of the building perimeter MM PS-2 Project design shall include ventilation of smoke and products of combustion. Zoned, mechanical smoke removal system, with manual controls for firefighters shall be located in the fire control room. An emergency power source is necessary and the system shall also comply with Building Code requirements to exhaust CO and other hazardous gases. MM PS-3 Dedicated rooms for Fire Department exclusive use to observe, monitor and as necessary control all emergency systems operation shall be provided. A total of three rooms shall be provided as follows: (1) commercial area and the related subterranean parking garage; (2)high-rise hotel; and(3)residential garages and dwellings. Rooms shall be located in an exterior location at grade level and have unrestricted access clear-to-the sky. Implementation of the following mitigation measure is recommended to further reduce less-than- significant impacts on police services, as described above under Impact PS-2: iI Pacific City EIR 2-61 Chapter 2 Text Changes from vehicular traffic along Pacific Coast Highway (PCH). The beaches, particularly Huntington City Beach near the Municipal Pier, have been the sites of many national and international sporting events, including surfing, volleyball, and skateboarding competitions. Huntington Beach is known as one of the best surfing areas on the west coast, and has earned the nickname"Surf City, USA."Its renowned surf is a result of the shoreline's long, gradually sloped beach gradient and location in relation to ocean swells. Parks and Recreational Facilities Huntington Beach contains 69 6r recreational parks, located throughout the City. Many of the parks have grass fields and landscaping devoted to sports, picnicking, and general enjoyment of the outdoor environment. The City classifies these parks into four categories, based primarily on their size, as follows: • Mini Park—Consists of less than one acre and intended to serve the immediate neighborhood in which they are located; provides passive open space and buffering from adjacent developments, with walking paths and benches; e.g., Booster Park, French Park, and Tarbox Park. • Neighborhood Park—Usually 2.5 to 5 acres in size and are intended to serve a 0.25 to 0.5 mile radius; planned for the activities of children from age 5 to 15; centrally located in a neighborhood and often adjacent to a school; e.g., Arevalos Park, Conrad Park, Lambert Park, Hawes Park,Burke Park, and Wieder Park. • Community Park—Designed to serve several neighborhoods within a 1- to 1.5-mile radius and ranging from approximately 10 to 40 acres in size; planned for youths and adults and hosts a wider range of activities than smaller parks; e.g., Chris Carr Park, Gisler Park, Langenbeck Park, and Marina Park. • Regional Park—Larger than 40 acres and serves a large regional area up to a 30- or 40-mile radius; provides special recreational opportunities such as camping, equestrian centers, nature preserves,trails, and lakes; e.g., Huntington Central Park and Blufftop Park. Based on the City's Park Strategy Fee and Nexus Study (Park Stratcgy fee study Preport) completed in December 2001 (City of Huntington Beach 2001b), the City's 69 park assets and 42 ; special-use recreation assets comprise a total of 906.7 acres. Parks alone occupy 803.6 acres, while nonpark buildings occupy 4.6 acres and nonpark special_use assets, which primarily consist of Meadow Lark Golf Courses occupy 98.5 acres. The General Plan has established a "parkland to population" ratio of five acres per 1,000 persons. The City currently has 4.75 acres of parkland per 1,000 persons, including the City-leased beach and Meadowlark Golf Course. Based on the estimated population in the Park Strategy Report of approximately 190,746 residents, and the City's parkland ratio standard of five acres per 1,000 persons, the present parkland requirement is 955.0 acres. The City's total of 906.7 park acres falls short of the identified ratio requirement by 48.3_acres, although this total does not include the 380 acres of beaches that contribute to recreational opportunities in the City. 2-62 City of Huntington Beach Chapter 2 Text Changes r' .,a'airit, ' ;:: r ir . a.. . irit, The proposed project would be required to satisfy Chapter 254.08 of the City's Municipal Code, which implements the provisions of the Quimby Act. Specifically, this chapter requires that five acres of property for each 1,000 residents be devoted to local park and-recreational purposes. In accordance with the parkland dedication requirements provided in the Huntington Beach Municipal Code, the proposed project would be required to provide 6.9 acres of parkland. This could be met through a combination of park fees and land dedication. As proposed, a total of 11.06 net acres of open space would be provided on the project site. This open space would include 1.78 acres of private open space and 9.28 net acres of common open space. The common open space would include five keyrecreational areas and common areas such P P P as public paseos and open space throughout the site, as shown on Figure 2-5a. The five recreational areas would be situated throughout the residential portion of the proposed project for a total of 2.50 acres, the largest of which would total 2.03 2.01 acres in the center of the residential development. This area, identified as the "Village Green," would be owned and maintained by the Pacific City Residential Homeowners Association, but open to the public through four pedestrian paseos. As currently proposed, the The "Village Green" would not be dedicated to the City as parkland. However, regardless of whether or not this area is dedicated to the City, the proposed project would fall short of the 6.9 acres of parkland required by the Quimby Act, as implemented by the City, and Thcrcforc, thc proposed projcct would not satisfy the parkland to population ratio requirements of thc City. The four additional recreational areas would primarily serve residents of the proposed project, as the residential units would be clustered around the recreational areas. However, Area 1 at the corner of First Street and Atlanta Avenue would be publicly accessible. The additional common open space would be positioned throughout the project site. Residents and employees of the proposed project may also use existing neighborhood and regional parks, as well as the beach. Residents of the site would most likely use these facilities after typical business hours and on the weekends, while employees at the site would use recreational facilities during lunch breaks, which would typically occur during the day. As such, the recreational facility demand generated by residents and employees would generally be concentrated during different times of the day. The increase in population as a result of the project is consistent with the City's General Plan and Zoning Ordinance, indicating that this population increase was previously assumed to occur in the City's planning activities. Pedestrian corridors would also be provided throughout the project site, as shown in Figure 2-7. Pedestrian pathways would link the surrounding residential communities and pathways, including the public access corridor that commences on Atlanta Avenue and aligns with Alabama Street (oriented perpendicular to Atlanta Avenue). In addition, as mentioned previously, four pedestrian paseos would provide access to the proposed "Village Green." These would include (1) pedestrian access from First Street aligned directly Pacific City EIR 2-63 Chapter 2 Text Changes xv" ,rx a 4i. t/�, s azy yix • 7 .4't • ,4:4 1 across from Walnut Avenue; (2) pedestrian access from Atlanta Avenue directly across from Alabama Street; (3)pedestrian access from Huntington Street across from the entrance to the Pacific Mobile Home Park; and (4) a 55-foot wide pedestrian access paseo from Pacific View Avenue. Pedestrian access ways would connect the residential and commercial components and PCH and, ultimately, the beach. Although not proposed in the current tentative tract map, a grade- separated pedestrian overcrossing is part of the Master Plan, which could be constructed in the future. This pedestrian bridge would span midway between Huntington Street and First Street over PCH, providing access to and from the Pacific Ocean to the project site. Pedestrian pathways throughout the site would be publicly accessible at all times. Residents of the proposed project may use neighborhood, community, and regional parks. The increase in population as a result of the project is consistent with the City's General Plan and zoning densities for the site. Therefore, the project would not result in increased demand not already anticipated in the City's planning activities. However, although the proposed project includes common open space areas and recreational opportunities that would be accessible to the general public within the proposed project site, the project does not specifically dedicate the 2.03 2.01 acre recreational area as parkland to the City. Since no parkland dedication is proposed, in-lieu fees could substitute for the 6.9 acres of required parkland dedication. Without adequate provision of parkland and/or payment of fees, impacts would be potentially significant. Impact REC-2 Construction effects associated with on-site recreational facilities would not significantly affect the environment over the short term. The proposed project would result in an overall increase in population in the City of Huntington Beach. Development of the proposed project would result in the addition of 516 dwelling units and a mixed-use visitor-serving commercial center on a currently vacant parcel of land in Downtown Huntington Beach. As described throughout Chapter 3 (Environmental Impact Analysis) of this DEIR, construction and operational activities on the project site would have an adverse impact on various resources. Specifically, construction activities associated with implementation of passive open space features, such as parkland, public access corridors and common recreational facilities would affect environmental resources. As indicated in Impact AQ-1 in Section 3.2 (Air Quality), daily construction activities could generate emissions that exceed SCAQMD thresholds, which would result in a potentially significant impact. In addition, Impact BIO-4 in Section 3.3 (Biological Resources) indicates that construction activities at the project site would increase noise levels above present levels but have a less-than-significant impact on any wildlife that may be in the project site vicinity. Construction of the proposed project would also result in potentially significant impacts to Cultural Resources (Section 3.4) as described in Impacts CR-1 through CR-3. Additionally, construction activities would temporarily increase soil exposure to wind and water 2-64 City of Huntington Beach Chapter 2 Text Changes e Diego Freeway (I-405) and PCH (SR-1), which run in a northwest to southeast orientation in the vicinity of the project, and Beach Boulevard (SR-39), which runs in a north to south orientation to the east of the project site. The San Diego Freeway, which is located approximately five miles north of the project site, provides north/south access through the City of Los Angeles and connects the Westside with the San Fernando Valley to the north and the South Bay area to the south. The primary access to the project site from the 1-405 is via an interchange at Beach Boulevard. PCH borders the site on the southwest, and is a major highway that extends through Orange County and links Huntington Beach with the neighboring communities of Seal Beach, Long Beach, Costa Mesa, and Newport Beach. Local Access Principal Significant local arterials, which are streets that carry the majority of traffic traveling through the city and are generally developed as commercial corridors, that serve the project site include Beach Boulevard, Main Street, First Street, Huntington Street, Atlanta Avenue, Pacific View Avenue, Delaware Street, and a portion of Huntington Street. Pacific Coast Highway (PCH), also known as State Route 1, is dcsignatcd shown as a Major Arterial Highway in the City's General Plan Circulation Element southeast of Goldenwest Street, and the Caltrans Route Concept Report and the County of Orange Master Plan of Arterial Highways (MPAH) sets the standards for this roadway. PCH provides both regional and local access to the project site. PCH is currently configured as a six-lane arterial south of Beach Boulevard, and is striped for six lanes from midway between Huntington Street and First Street to 6th Street, which includes the northwesterly half of the project frontage. Northwest of 6th Street, PCH is configured as a four-lane arterial. Metered parking is currently provided on both sides of PCH except along the southwesterly half of the project frontage and along the southwest side of PCH, which is improved with a transit turnout for bus layovers and boardings. The speed limit along PCH varies from 35 miles per hour (MPH) to 50 MPH in the project vicinity. PCH currently peI forms as a four-lane Expressway between Warner Avenue and Seapoint Avenue. Beach Boulevard, also known as State Route 39, is designated as a Superstreet/Smartstreet on the Caltrans Route Concept Report and the County of Orange MPAH. Beach Boulevard provides both regional and local access to the project site and currently consists of six lanes between PCH and Ellis Avenue/Main Street and eight lanes north of Ellis Avenue/Main Street. Beach Boulevard begins at PCH in Huntington Beach and continues northward through the study area and cities of Westminster, Garden Grove, Anaheim, Buena Park, and La Mirada before terminating at Whittier Boulevard in La Habra. Pacific City EIR 2-65 Chapter 2 Text Changes Atlanta Avenue is designated as a four-lane Primary Arterial Highway in the City's General Plan Circulation Element and Orange County MPAH. The City's General Plan also designates this street as a Landscape Corridor. Atlanta Avenue originates at First Street and continues easterly to its terminus at the Santa Ana River. Atlanta Avenue is currently a two-lane roadway along the project frontage and becomes four lanes from Delaware Street to the Santa Ana River. Parking is permitted on the side of Atlanta Avenue adjaccnt to opposite die existing single-family residences and is rcstrictcd along the project frontage. Main Street is designated as a four-lane Primary Arterial Highway in the City's General Plan Circulation Element and Orange County MPAH north of 17th Street, and extends from PCH to Beach Boulevard. Main Street is local street south of 17`1' Street. Main Street is currently a two-lane roadway between PCH and Adams, a four-lane roadway between Adams Avenue and Yorktown Avenue, and a six-lane roadway between Yorktown Avenue and Beach Boulevard. Within the Main Street segment between PCH and Adams, angle parking is located in the Downtown area between PCH and 6th Street. First Street is designated as a four-lane Primary Arterial Highway in the City's General Plan Circulation Element and Orange County MPAH, and extends from PCH to Atlanta Avenue/Orange Avenue. First Street is currently a two-lane roadway and parking is permitted along both sides. The City's General Plan also designates this street as a Landscape Corridor. Huntington Street is designated as a three fet±Y-lane Secondary roadway from PCH to Pacific View Avenue and a local street north of Pacific View in the City's General Plan Circulation Element and Orange County MPAH. Huntington Street originates at PCH and continues northerly to its terminus at Garfield Avenue. Huntington Street is currently a two-lane roadway with a middle lane allowing for turns, with primarily residential frontage north of Atlanta Avenue. Parking is not permitted along either side of Huntington Street adjacent to the project frontage. Delaware Street is designated as a four-lane Secondary roadway in the City's General Plan Circulation Element and Orange County MPAH, and currently extends from just south of Atlanta Avenue to Taylor Drive north of Ellis Avenue. Delaware Street currently varies between a two- lane roadway and four-lane roadway with primarily residential frontage. Parking is permitted along both sides of Delaware Street. An extension of Delaware Street south of Atlanta Avenue to PCH is identified in the City's MPAH, Circulation Element (Figure CE-13), and Precise Plan of Street Alignment 70-3. However, implementation of this improvement is currently not programmed. Pacific View Avenue is designated as a four-lane Primary Arterial Highway in the City's General Plan Circulation Element and Orange County MPAH. The City's General Plan also designates this street as a Landscape Corridor. Pacific View Avenue existed only from Huntington Street to approximately 500 feet east along the existing Waterfront Hilton project when the counts were conducted for the proposed project's Traffic Impact Analysis. Pacific View Avenue has been extended easterly to Beach Boulevard in conjunction with current development of the Hyatt Regency Resort, and will be extended westerly to First 2-66 City of Huntington Beach Chapter 2 Text Changes Pa e 844 r Street in conjunction with the proposed project. Parking is currently prohibited along the entire length of Pacific View Avenue. Figure 3.14-1 illustrates the existing roadway conditions and intersection controls in the project area, as described above. Study Area Intersections An inventory of key area roadways and intersections for the proposed project vicinity was performed during the preparation of the Traffic Impact Analysis Report. The traffic report analyzed existing and future peak hour traffic conditions upon completion of the proposed project in Year 2008 at the following thirty-t-wethree key intersections (thirty-one of which currently exist) and twenty-five roadway segments(twenty-four of which currently exist): Year 2008 Study Intersections • Goldenwest Street at PCH • 17th Street at PCH • 9th Street at PCH • 6th Street at PCH • Main Street at 6th Street • Main Street at PCH • First Street at Atlanta Avenue • First Street at PCH • Huntington Street at Atlanta Avenue • Delaware Street at Atlanta Avenue • Huntington Street at PCH • Huntington Street at Pacific View Avenue • Beach Boulevard at Adams Avenue (Congestion Management Plan Intersection) • Beach Boulevard at Indianapolis Avenue • Beach Boulevard at Atlanta Avenue • Beach Boulevard at PCH (Congestion Management Plan Intersection) • Newland Street at Atlanta Avenue Pacific City EIR 2-67 Chapter 2 Text Changes Rage 31M7 .. _. `, ,. , e....s.,....._....�._....,._ ..�. ...w .,E.. SI_...x._...._....,x.. • Newland Street at PCH • Magnolia Street at PCH • Magnolia Street at Atlanta Avenue • PCH at Seapoint Avenue • PCH at Warner Avenue (Congestion Management Plan Intersection) • PCH at Brookhurst Avenue • Main Street at Adams Avenue • Main Street at Utica Avenue • Lake Street at Adams Avenue • Lake Street at Yorktown Avenue • Beach Boulevard at Yorktown Avenue • Beach Boulevard at Garfield Avenue • Newland Street at Ellis Avenue/Main Street • Superior Avenue/Balboa Blvd. at PCH (Congestion Management Plan Intersection) • First Street at Pacific View Avenue (Future) • Beach Boulevard at Pacific View Avenue (Future) Year 2008 Study Roadway Segments (Links) • PCH, from Warner Avenue to Seapoint Avenue • PCH, from Seapoint Avenue to Goldenwest Street • PCH,from Goldenwest Street to 6th Street • PCH, from 6th Street to First Street • PCH, from First Street to Huntington Street • PCH, from Huntington Street to Beach Boulevard • PCH, from Beach Boulevard to Newland Street • PCH, from Magnolia Street to Brookhurst Street • Beach Boulevard, from PCH to Atlanta Avenue • Beach Boulevard, from Atlanta Avenue to Indianapolis Avenue • Beach Boulevard, from Indianapolis Avenue to Adams Avenue • Beach Boulevard,from Adams Avenue to Yorktown Avenue 2-68 City of Huntington Beach Chapter 2 Text Changes • Beach Boulevard, from Garfield Avenue to Main Street • Atlanta Avenue, from Beach Boulevard to Delaware Street • Atlanta Avenue, from First Street to Huntington Street • Atlanta Avenue, from Huntington Street to Delaware Street • First Street,from Orange Avenue to PCH • Huntington Street, from Atlanta Avenue to Pacific View Avenue • Main Street, from Palm Avenue to Adams Avenue • Lake Street,from Indianapolis Avenue to Adams Avenue • Lake Street, from Adams Avenue to Yorktown Avenue • Adams Avenue, from Beach Boulevard to Newland Street • Indianapolis Avenue, from Beach Boulevard to Newland Street • Atlanta Avenue,from Beach Boulevard to Newland Street • Pacific View(future with project), from First Street to Huntington Street Existing Traffic Volumes and Level of Service Existing Area Traffic Volumes The existing A.M. and P.M. peak hour intersection traffic volumes for the existing 3031 study intersections were obtained from manual morning and evening peak period turning movement counts conducted in late August 2001 and May 2002. These intersections were designated for evaluation based on a "select-zone" analysis of the City's Santa Ana River Crossing Cooperative Study (SARCCS) transportation model. These existing A.M. and P.M. peak hour turning movement volumes are illustrated in Figure 3.14-2 and Figure 3.14 3, respectively. The 2001/02 detailed weekday manual peak period traffic count data for the existing t-kirty31 of the 33 key study intersections, and the daily traffic counts for seven of the 24 key area roadway segments are provided in Appendix A of the Traffic Impact Analysis Report. The existing average daily traffic (ADT) volumes on the key study roadway segments in the vicinity of the project site were obtained from recent (August 2001) traffic counts and the City's Traffic Flow Map. These existing ADT volumes represent Existing 2001 conditions and are illustrated in Figure 3.14-4. Pacific City EIR 2-69 Chapter 2 Text Changes ptgke �� .,.k�'' � " �,. :Yx�..'.x, ax... nar'.IIa'a t % h .,;z'�a.'ufr'...�'. ... A majority of the study intersections were counted in August 2001 during the peak summer season. At this time, average daily traffic counts along the four project frontage roadways as well as Atlanta Avenue east of the project site and PCH northwest of 9th Street were also taken. It should be.noted that the summer weekday condition is typically higher than during the winter months and, consequently was used in this analysis to present a conservative scenario. Summer weekend traffic represents a "peak" period due to the beach resort character of the Downtown. Consequently, higher levels of traffic are experienced in the vicinity of the proposed project during the summer weekends than during aieal weekdays. Common traffic engineering practice is to mitigate traffic and parking impacts to a typical weekday period, rather than a peak day (such as a holiday weekend, or summer weekendperiod). As a result, the summer Weekday weekend condition is included in Appendix H to provide a comparison between typical periods and summer weekends perieds. Direct traffic and parking project impacts and mitigation measures have been developed based on t pieal summer weekday traffic counts. Existing Intersection Conditions To quantify the existing baseline traffic conditions, the 30 existing study area intersections were analyzed to determine their operating conditions during the morning and evening peak periods. Twenty six (26) of the study intersections are controlled by traffic signals. In conformance with City of Huntington Beach (City) criteria, the Intersection Capacity Utilization (ICU) Methodology was employed to investigate the existing A.M. and P.M. peak hour operating conditions for these key intersections. The ICU technique is used for signalized intersections and estimates the volume to capacity (V/C)relationship for an intersection based on individual V/C ratios for key conflicting movements. The ICU numerical value represents the percent of the capacity required by existing or future traffic. The ICU value translates to a Level of Service (LOS) condition, which is a relative measure of the performance of the intersection. There are six Levels of Service that range from LOS A (free flow with an ICU of 0.60 or less) to LOS F (forced flow with an ICU in excess of 1.00). LOS D (ICU of 0.81 to 0.90)is traditionally considered the maximum acceptable LOS for urban and suburban peak hour conditions. The City of Huntington Beach considers LOS D to be the maximum acceptable LOS for signalized intersections. LOS definitions are provided in Table 3.14-1. In conformance with the current State of California Department of Transportation (Caltrans) requirements, existing A.M. and P.M. peak hour operating conditions for the 19 Caltrans-operated signalized intersections within the project study area (SR-39 [Beach Boulevard] and SR-1 [PCH]) were evaluated using the 2000 Highway Capacity Manual (HCM) signalized methodology. Based on the HCM method of analysis, LOS for signalized intersections is defined in terms of control delay, which is a measure of driver discomfort, frustration, fuel consumption, and lost travel time. 2-70 City of Huntington Beach Chapter 2 Text Changes Table 3.14-1 Level of Service Definitions for Signalized Intersections (ICU Method) Level of Service Intersection Capacity (LOS) Utilization Value(V/C) Level of Service Description A 0.00 to 0.60 Free flow;Very low delay,less than 10.0 seconds per vehicle. B 0.61 to 0.70 Rural Design;Delay in the range of 10.1 to 20 seconds per vehicle. C 0.71 to 0.80 Urban Design;Delay in the range of 20.1 to 35 seconds per vehicle. D 0.81 to 0.90 Maximum Urban Design;Delay ranges from 35.1 to 55 seconds per vehicle. E 0.91 to 1.00 Capacity;Delay ranges from 55.1 to 80 seconds per vehicle. F >1.01 Forced Flow,Delay in excess of 80 seconds per vehicles SOURCE: Linscott Law&Greenspan Engineers,Traffic Impact Analysis Report,April 2003a The delay experienced by a motorist is made up of a number of factors that relate to control, geometries, traffic, and incidents. Whereas total delay is the difference between the travel time actually experienced and the reference travel time that would result during ideal conditions (in the absence of traffic control, geometric delay, roadway incidents, and other vehicles on the road), control delay represents the portion of the total delay that is attributed to the control facility. As such, control delay includes initial deceleration delay, queue move-up time, stopped delay, and final acceleration delay. Under the HCM methodology, LOS criteria for traffic signals are stated in terms of the average control delay per vehicle, which is measured in seconds/vehicle. The six qualitative categories of LOS that have been defined along with the corresponding HCM control delay value range for signalized intersections are shown in Table 3.14-2. In addition, out of the 37133 study intersections for the proposed project, four intersections (First Street/Atlanta Avenue; Huntington Street/Atlanta Avenue; Delaware Street/Atlanta Avenue; and Huntington Street/Pacific View Avenue) are currently unsignalized. In conformance with the City of Huntington Beach requirements, the existing A.M. and P.M. peak hour operating conditions for these four unsignalized intersections were also evaluated using the HCM methodology, which estimates the average total delay for each of the subject movements and determines the LOS for each movement. Table 3.14-3 defines the six qualitative categories of LOS for unsignalized intersections under the HCM method of analysis. Based on City criteria for unsignalized intersections, LOS D is the minimum acceptable intersection LOS. Table 3.14-4 summarizes the existing service level calculations for the ty31 existing study intersections (two of the 3-2 total study intersections are future intersections with no existing traffic)based on existing traffic volumes and current street geometry. As shown, all ty31 study intersections currently operate at LOS D or better, except the intersection of PCH at Warner Avenue, which currently operates at LOS E during the P.M. peak hour. Pacific City EIR 2-71 Chapter 2 Text Changes � v `�a�[ y� - 7Y;; ... s " 3• r^, Y _y Pa P� e'^ ' se> war:.S t- � st r 4 , ..�.... ��� .:,.` ....�....,�.oe.��S ,A.ao_'^'�.�......_.::�t.� "�.._.� vim ... x./.�.Table 3.14-4 Existing Year 2001/02 Peak Hour Levels of Service Key Intersection Time Period Control Type ICU/HCM LOS 26 Lake Street at A.M. 5(I)Traffic Signal 0.512 A Adams Avenue P.M. 0.588 A 27 Lake Street at A.M. 24 Traffic Signal 0.328 A Yorktown Avenue P.M. 0.451 A 28 Beach Boulevard at A.M. 84 Traffic Signal 0.632 B Yorktown Avenue P.M. 0.690 B 29 Beach Boulevard at A.M. 84 Traffic Signal 0.624 B Garfield Avenue P.M. 0.749 C 30 Beach Boulevard at A.M. 64 Traffic Signal 0.557 A Ellis Avenue/Main Street P.M. 0.669 B 31 Superior Ave./Balboa Blvd. A.M 64)Traffic Signal 0.678 at Pacific Coast Highway. P.M.. 0.603 B 3432 First Street at A.M. N/A N/A N/A Pacific View Avenue(future) P.M. N/A N/A N/A 3233 Beach Boulevard at A.M. N/A N/A N/A Pacific View Avenue(future) P.M. N/A N/A N/A s/v=seconds per vehicle(delay) Bold V/C and LOS values indicate adverse service levels based on City LOS Standards SOURCE: Linscott,Law&Greenspan 2003a Existing Roadway Segments (Links) In conformance with the City's criteria, existing daily operating conditions for the 24 existing roadway links have been investigated according to the volume-to-capacity (V/C) of each link. The V/C relationship is used to estimate the LOS of the roadway segment with the volume based on 24-hour traffic count data and the capacity based in the City's classification of each roadway. Based on the City's General Plan, Orange County's MPAH, Caltrans Route Concept Report, and consultation with City staff, the roadway segment capacities of each street classification are shown in Table 3.14-5. The results of the analysis of existing service levels for the 24 existing study roadway segments, based on existing 24-hour traffic volumes and current roadway geometry, are summarized in Table 3.14-6. As shown, only two of the study segments currently operate below the City's maximum V/C criteria of 0.81. Based on the V/C method of analysis, the roadway segments of PCH between Goldenwest Street/Sixth Street and Huntington Street /Beach Boulevard currently operate at LOS E on a daily basis. The remaining 22 roadway segments in the study area currently operate at LOS C or better. 2-72 City of Huntington Beach Chapter 2 Text Changes Pa" 314= 5 ,�� Table 3.14-8 General Plan Circulation Element—Policies Applicable to Transportation/Traffic Goal,Objective,or Policy Project Consistency Policy CE 2.3.2.Limit driveway Driveway access points would be provided sufficient to serve the project.Impact TR-8 access points and require adequate demonstrates that driveways would ensure a smooth and efficient flow of traffic. driveway widths onto arterial roadways and require driveways be located to ensure the smooth and efficient flow of vehicles,bicycles and pedestrians. Policy CE 2.3.3.Require,where Mutual access and shared driveways to proposed commercial uses and hotel uses appropriate,an irrevocable offer of would be provided on site. mutual access across adjacent nonresidential properties fronting arterial roadways and require use of shared driveway access. Policy CE 2.3.4.Require that new The project proposes roadway improvements to mitigate traffic impacts to the maximum development mitigate its impact on extent feasible. City streets,including but not limited to,pedestrian,bicycle,and vehicular conflicts,to maintain adequate levels of service. Goal CE 4.Encourage and develop a Conformance with implementing policies,as discussed below,results in conformance transportation demand management with this goal. (TDM)system to assist in mitigation} mitigating traffic impacts and in maintaining a desired level of service on the circulation system. Policy CE 5.1.1.Maintain an Adequate parking to serve project demand would be provided on site,as discussed adequate supply of parking that under impact TR-7.The project would also retain public parking on-site and on First supports the present level of demand Street to serve existing public parking demand within the project area. and allow for the expected increase in private transportation use. Policy CE 5.1.2.Provide safe and Parking would be provided on-site and would be in subterranean structures to minimize convenient parking that has minimal impacts.On-street public parking will also be maintained. impacts on the natural environment, To address the potential impacts on pedestrians and bicyclists within the project site the community image,or quality of associated with the provision of diagonal parking,the proposed project would comply life. with Municipal Code sections 10.40.200-210 by obtaining a resolution to establish a diagonal parking zone and an exception to allow for diagonal parking on Pacific View Avenue,which is a master plan arterial street.Angled parking would be provided on the south side of the roadway in the short term.The ultimate configuration of this roadway would include a 4 lane divided cross section within the 90-foot ROW.It is anticipated that some on-street parking may be retained with the reconfiguration,though angled parking would not be allowed. Pacific City EIR 2-73 Chapter 2 Text Changes Table 3.14-8 General Plan Circulation Element—Policies Applicable to Transportation/Traffic Goal,Objective,or Policy Project Consistency Goal CE 6.Provide a city-wide Conformance with implementing policies,as discussed below,results in conformance system of efficient and attractive with this goal. pedestrian,equestrian,and waterway facilities for commuter,school and recreational use. Objective CE 6.1.Promote the Conformance with implementing policies,as discussed below,results in conformance safety of bicyclists and pedestrians with this objective. by adhering to Caltrans and City-wide standards. Policy CE 6.1.2.Link bicycle routes Pedestrian circulation on-site would connect to the existing Class II bike path on First as shown in Figure CE-9 with Street. pedestrian trails and bus routes to promote an interconnected system. Policy CE 6.1.6.Maintain existing The project would provide a network of pedestrian walkways that would link to citywide pedestrian facilities and require new routes and would allow movement between developments,schools,and public development to provide pedestrian facilities.Specifically,at-grade pedestrian crossings are proposed at the existing walkways and bicycle routes between signalized intersections of PCH at Huntington Street and PCH at First Street to the developments,schools,and public beach. In addition,although not part of the proposed project,a grade-separated facilities. pedestrian bridge would be located midway between Huntington Street and First Street to connect the project site to the beach. yen.o which a maser plan arterial street Policy CE 6.1.7.Require new Facilities accessible to the elderly and disabled would be provided,consistent with code development to provide accessible requirements. facilities for the elderly and disabled. Goal CE 7 Maintain and enhance Conformance with implementing policies,as discussed below,results in conformance the visual quality and scenic views with this goal. along designated corridors. Objective CE 7.1.Enhance existing Conformance with implementing policies,as discussed below,results in conformance view corridors along scenic corridors with this objective. and identify opportunities for the designation of new view corridors. Policy CE 7.1.1.Require the As discussed under Impact AES-1 impacts to the view corridor along Pacific Coast roadways,as shown in Figure CE-12, Highway would be less than significant.The project would maintain local highways by to be improved and maintained as providing landscaping along PCH,and-at key entry points,and minor entry treatments local scenic highways,major urban for the intersections of PCH and First Street. scenic highways,minor urban scenic highways,and landscape corridors with key entry points. Policy CE 7.1.5.Require any As discussed under Impact AES-2 impacts to the visual character would be less than bridges,culverts,drainage ditches, significant.The retaining walls,and pedestrian bridge that could be constructed in the retaining walls and other ancillary future and other project features would be architecturally consistent with surrounding roadway elements to be compatible development. and architecturally consistent with surrounding development and any other design guidelines. 2-74 City of Huntington Beach Chapter 2 Text Changes i�a G4j37� �� kcYr .Ai 5.... w.. �� .S.J.� ri.Xc'�.C,:SA • Pacific Coast Highway—The north side of PCH would be widened approximately 8 feet along the project frontage between First Street and Huntington Street. The widening would also include a 10-foot property line dedication and installation of an OCTA bus turnout along the north side of PCH west of Huntington Street. The widening would allow for a third westbound through lane to be established on PCH west of Huntington Street, and would provide the ability for the incorporation of a bicycle lane through this section. • Huntington Street—The west side of Huntington Street would be widened approximately 10 feet along the project frontage between PCH and Pacific View Avenue. This would allow for an additional southbound travel lane as well as an exclusive southbound right turn lane at PCH. The widening would also include a 10-foot property line dedication (40-foot half- width). • Pacific View Avenue—Pacific View Avenue would be developed as part of the Pacific City project through the project site from Huntington Street to First Street consistent with the Precise Plan of Street Alignment. However, based on the Year 2008 total daily traffic volume as presented in Exhibit 27 and Exhibit 28 (8,848 VPD), it is recommended that Pacific View Avenue be constructed to a width of 70 feet curb-to-curb. This would allow for one 20-foot westbound through lane, a 14-foot raised landscaped median island, and a 14- foot eastbound through lane and angle parking at 45° (22 feet). The roadway would be dedicated to a width of 90 feet, which would allow for an 18-foot parkway on the north side and a 2-foot parkway on the south side. The ultimate configuration of this roadway would include a 4 lane divided cross section within the 90=foot right-of-way. It is anticipated that some on-street parking may be retained with the reconfiguration, though angled parking will not be allowed under this configuration. Appendix K of the traffic report presents a diagram of the proposed layout of Pacific View Avenue. • Pedestrian Pathway—In addition to the widening along Atlanta Avenue, a twenty four-foot wide pedestrian access easement would be dedicated through the project site extending from the south side of Atlanta Avenue, at Alabama Street, to Pacific View Avenue at the easterly residential access driveway where pedestrians can cross at the all-way stop. Linkages are also proposed from the residential village through the visitor-serving commercial component of the project site. From the visitor-serving commercial area, access is provided to PCH and the beach via at-grade intersections at PCH at First Street and PCH at Huntington Street. Furthermore, as part of the overall Master Plan, a grade-separated pedestrian bridge would also be located midway between Huntington Street and First Street to provide a connection from the beach to the public areas near the hospitality uses located within the visitor-serving commercial area. Future Year 2008 Conditions The proposed project has an assumed completion date of Year 2008. In order to properly evaluate the potential impact of the proposed project on the local streets,it is necessary to develop estimates of the near-term (Year 2008) traffic conditions at the33 key intersections, which include two future intersections along Pacific View Avenue, and 25 key roadway segments, with and without project-related traffic. Pacific City EIR 2-75 Chapter 2 Text Changes l ,age 4Z & .. E S � a . .. 4�<, F .: o ;z,t. •Yc ztk'n ':.., i�F �::u N''. '.:..� .x:,,zb����� £� l�}i.1�.a.:� ..t�. x.y..... - Year 2008 Background Traffic Conditions Ambient Traffic The background traffic growth estimates for Year 2008 were calculated using ambient growth factors, which are intended to include unknown and future cumulative projects in the study area, as well as account for regular growth in traffic volumes due to development of projects outside the study area. Based on buildout traffic volumes and prior studies conducted in the Downtown area, future growth in the traffic volumes at the key study intersections were calculated at 1 percent per year. Upon the application of this growth rate to existing 2001 traffic volumes, it was determined that a 7 percent growth in existing volumes at the-3-233 key study intersections and 24 key roadway segments would occur by horizon year 2008. Cumulative Projects Traffic Characteristics Based on information provided by the City of Huntington Beach Planning staff, there are fourteen potential planned and/or approved projects, which may generate traffic in the project study area by the Year 2008. Of the fourteen potential cumulative projects, four have been identified as having significant traffic generation potential. These four projects are • The Strand at 5th Street and PCH • The Waterfront Residential development and Hyatt Regency Resort • The Beachside project at Atlanta Avenue and Beach Boulevard • The Boardwalk project at Goldenwest Street and Palm Avenue The corresponding forecast peak hour and daily traffic volumes for each of the four cumulative projects in the City of Huntington Beach are shown in Table 3.14-11. As shown, the total forecast related traffic generation is estimated at 19,882 two-way daily trips with 1,303 A.M. peak hour trips (545 inbound, 758 outbound) and 1,781 P.M. peak hour trips (1,037 inbound, 744 outbound). Based on information provided by City of Newport Beach Planning staff, there are twelve approved projects as well as eight uncommitted potential projects, which may generate traffic in the project study area by the Year 2008. AM and PM peak hour traffic from these 20 projects in addition to the four projects identified above have been distributed at the intersection of Superior/Balboa and PCH. Appendix L of the Traffic Study contains the City of Newport Beach related project traffic information provided by the City of Newport Beach. The related project information that is included for the analysis of the Superior/Balboa and PCH intersection is not included in other intersections analyzed, as the ambient growth captures these trips for critical movements analyzed. 2-76 City of Huntington Beach Chapter 2 Text Changes Table 3.14-11 Related Projects Traffic Generation Forecast Daily A.M.Peak Hour P.M.Peak Hour Related Project Description 2-Way In Out Total In Out Total Trip Generation Forecast The Strand Retail/Restaurant/Office/Hotel(121,000 SF&149 Rooms) 7,106 220 163 383 324 293 617 1 Waterfront Ocean Grand Resort Low Density Residential(184 DU) 2,208 40 118 158 129 77 206 Resort Hotel(519 Rooms) 4,515 208 140 348 213 182 395 Subtotal 6,723 248 258 506 342 259 601 The Beachside Single-Family Residential(86 DU) 823 16 48 64 56 31 87 The Boardwalk(Area 4B&PLC) Residential(500 DU) 5,230 61 289 350 315 161 476 Total Related Project Trip Generation 19,882 545 758 1,303 1,037 744 1,781 SOURCE: City of Huntington Beach Planning Department 2003;LSA Associates 1998,1999,2002 Intersection Analysis—City Criteria Future Year 2008 Without Proposed Project Based on the traffic generation forecast for the Year 2008 background traffic conditions, the peak hour ICU/HCM Level of Service results at the33 study intersections were determined. The results are shown in Table 3.14-12, column(1). An analysis of near-term (Year 2008) traffic conditions in Table 3.14-12 indicates that the forecast increase in background traffic would continue to cause one of the 33 study intersections to operate at adverse service levels. The intersection of PCH at Warner Avenue, which currently operates at LOS E during the P.M. peak hour, is expected to operate at LOS F (P.M.) with the addition of background traffic in Year 2008. The remaining 34-32 key intersections are expected to continue to operate at LOS D or better in both peak hours. Future Year 2008 With Proposed Project As shown in Table 3.14-12, column (2), the intersection of PCH at Warner Avenue would experience an increase in ICU as a result of the proposed project traffic combined with background traffic (ambient plus cumulative projects), but the intersection would continue to operate at the same adverse service levels (LOS E or F) during the A.M. and P.M. peak hours. The remaining 32 key study intersections have been forecasted to continue to operate at acceptable service levels with the addition of the proposed project traffic during both the weekday A.M. and P.M. peak commute hours. These projected A.M. and P.M. peak hour traffic volumes for the Year 2008 are illustrated in Figures 3.14-9 and 3.14-10,respectively. Pacific City EIR 2-77 Chapter 2 Text Changes «rt`r..«5.--7-.4:5iS5 .4 E14�. E*r eS .. k�.... ,,, .;r. p ]'C "C % , , `lea 0�3 , Table 3.14-12 Year 2008 Peak Hour Intersection Levels of Service Summary (1) (2) (3) (4) Year 2008 Background Year 2008 Background Project Impact/ Year 2008 With Time Conditions Plus Project Significance Mitigation Key Intersections Period ICU LOS ICU LOS ICU Inc. Y/N ICU LOS 23. Pacific Coast Highway at A.M. 0.743 C 0.757 C 0.014 N - - Brookhurst Street P.M. 0.809 D 0.845 D 0.036 N - - 24 Main Street at A.M. 0.500 A 0.509 A 0.009 N - - Adams Avenue P.M. 0.703 B _ 0.729 C 0.026 N - - 25 Main Street at A.M. 0.227 A 0.231 A 0.004 N - - Utica Avenue P.M. 0.336 A 0.346 A 0.010 N - - 26. Lake Street at A.M. 0.553 A 0.556 A 0.003 N - - Adams Avenue P.M. 0.644 B 0.656 B 0.012 N - - - 27 Lake Street at A.M. 0.366 A 0.373 A 0.007 N - - Yorktown Avenue P.M. 0.494 A 0.509 A 0.015 N - - 28 Beach Boulevard at A.M. 0.705 C 0.721 C 0.016 N - - - Yorktown Avenue P.M. 0.773 C 0.800 C 0.027 N - - 29 Beach Boulevard at A.M. 0.685 B 0.707 C 0.022 N - - Garfield Avenue P.M. 0.830 D 0.858 D 0.028 N - - 30. Beach Boulevard at A.M. 0.610 B 0.621 B 0.011 N - - Ellis Avenue/Main Street P.M. 0.736 C 0.752 C 0.016 N - - 31 Superior/Balboa at A.M 0.768 C 0.779 C 0.011 N = _ Pacific Coast Highway P.M 0.708 C 0.728 C 0.020 N = _ First Street at 34 A.M. N/A N/A 2.62 A N/A N - - 32. Pacific Views Avenue P.M. N/A N/A 4.34 A N/A N - - (future) 32 Beach Boulevard at A.M. 0.215 A 0.250 A 0.035 N - - 33. Pacific View Ave(future) P.M. 0.252 A 0.284 A 0.032 N - - 1. LOS indicated as intersection delay in seconds/vehicle(slv) Bold VIC and LOS values indicate adverse service levels based on City LOS Standards SOURCE: Linscott,Law&Greenspan 2003a In addition, the projected ADT volumes, which represent the Year 2008 conditions with the proposed project, are illustrated in Figure 3.14-11. Intersection Analysis-State of California (Caltrans) Methodology As required by the State of California Department of Transportation (Caltrans), the 4-920 state route intersections within the project study area [SR-39 (Beach Boulevard) and SR-1 (PCH)] were analyzed on an A.M. and P.M. peak hour basis, for existing and Year 2008 traffic conditions, consistent with the recently published Caltrans Guide for the Preparation of Traffic Impact Studies, [June, 2001]. The peak hour HCM (HCS-2000 for signalized intersections) Level of Service results at the 4-920 State-controlled study intersections within the study area are shown in Table 3.14-13. 2-78 City of Huntington Beach Chapter 2 Text Changes V; '`i` �{ ems ds � . 1 -74 2 ✓ Y a J ��n � 1t L 3: k F l t " .. ..a7�i !S�O.R ..' �.:..... viu.i, . .'.�>a.......�.. fi .. :w:'..� Gs.......:: �.... ..0 ..:.,. .« .i:��� � xc. Table 3.14-13 Peak Hour Intersection Levels of Service Summary-Caltrans(HCM) (2) (3) (4) (1) Year 2008 Year 2008 Project (5) Year 2001 Existing Background Background Plus Impact/ Year 2008 With Time Conditions Conditions Project Significance Mitigation Key Intersections Period HCM LOS HCM LOS HCM LOS Yes/No HCM LOS 1. Goldenwest Street at A.M. 38.0 D 51.5 D 54.9 D No _ _ Pacific Coast Highway P.M. 35.0 C 45.9 D 51.4 D No 2 17th Street at A.M. 19.5 B 21.9 C 22.7 C No _ _ Pacific Coast Highway P.M. 18.7 B 24.0 C 30.2 C No 3. 9th Street at A.M. 18.5 B 21.6 C 22.8 C No _ _ Pacific Coast Highway P.M. 15.6 B 22.0 C 32.1 C No 4. 6th Street at A.M. 21.5 C 23.5 C 23.8 C No - - Pacific Coast Highway P.M. 18.3 B 21.6 C 21.9 C No 5. Main Street at A.M. 21.3 C 22.1 C 22.6 C No _ _ Pacific Coast Highway P.M. 22.0 C 23.8 C 24.5 C No 6 First Street at A.M. 33.5 C 40.1 D 47.8 D No - - Pacific Coast Highway P.M. 35.4 D 43.6 D 51.1 D No 7 Huntington Street at A.M. 21.4 C 28.9 C 47.7 D No _ Pacific Coast Highway P.M. 18.8 B 23.1 C 41.4 D No 8 Beach Boulevard at A.M. 39.1 D 40.9 D 41.4 D No - - Adams Avenue P.M. 41.5 D 45.4 D 48.5 D No 9. Beach Boulevard at A.M. 26.4 C 26.8 C 27.1 C No _ _ Indianapolis Avenue P.M. 27.1 C 27.9 C 28.6 C No 10. Beach Boulevard at A.M. 29.3 C 29.6 C 29.6 C No - _ Atlanta Avenue P.M. 32.5 C 33.4 C 34.7 C No 11 Beach Boulevard at A.M. 35.0 C 39.7 D 42.3 D No - Pacific Coast Highway P.M. 25.5 C 33.7 C 46.1 D No 12 Newland Street at A.M. 23.7 C 26.3 C 27 7 C No - - Pacific Coast Highway P.M. 23.1 C 25.9 C 28.1 C No - 13. Magnolia Street at A.M. 23.9 C 27.0 C 29.1 C No - Pacific Coast Highway P.M. 25.2 C 29.0 C 32.5 C No 14 Pacific Coast Highway at A.M. 24.9 C 29.3 C 31.5 C No 29.0 C Seapoint Avenue P.M. 34.6 C 62.8 E 79.4 E Yes 51.5 D 15, Pacific Coast Highway at A.M. 60.7 E 105.2 F 117.3 F Yes 44.9 D Warner Avenue P.M. 204.9 F 293.0 F 319.8 F Yes 42.6 D 16 Pacific Coast Highway at A.M. 32.9 C 37.9 D 40.6 D No - - Brookhurst Street P.M. 26.5 C 33.6 C 45.4 D No 17. Beach Boulevard at A.M. 39.8 D 44.0 D 45.9 D No _ _ Yorktown Avenue P.M. 39.0 D 46.1 D 52.2 D No 18. Beach Boulevard at A.M. 38.8 D 41.4 D 43.1 D No _ _ Garfield Avenue P.M. 42.4 D 49.4 D 54.6 D No 19 Beach Boulevard at A.M. 36.6 D 38.5 D 39.4 D No _ _ Ellis Ave/Main Street P.M. 42.5 D 49.0 D 54.0 D No 20 Superior/Balboa at A.M. 38.3 D 44.6 D 46.2 D No Pacific Coast Highway P.M. 42.2 D 49.0 D 52.0 D No Bold VIC and LOS values indicate adverse service levels based on City LOS Standards SOURCE: Linscott,Law&Greenspan 2003a Pacific City EIR 2-79 Chapter 2 Text Changes l� ge 81449 *" ..„rr �xaik �. .. ...���.. ., `���.e.., .. ..�: :�� M..;4, ..�.;: .,. �'.�..' ��-..' �.. _,.�,�.� �� �.::1.��.. „�, Future Year 2008 Without Proposed Project As shown in Table 3.14 13, the forecast increase in background traffic is expected to result in or continue to operate at adverse service levels at two of the 4-920 State-controlled study intersections. The intersection of PCH at Warner Avenue, which currently operates at LOS E during the A.M. peak hour and LOS F during the P.M. peak hour, is expected to operate at LOS F during both A.M. and P.M. peak hours in Year 2008, with the addition of background traffic. The intersection of PCH at Seapoint Avenue, which currently operates at LOS C during both A.M. and P.M. peak hours, is expected to operate at LOS E during the P.M. peak hour in Year 2008, with the addition of background traffic. The remaining 4-718 State study intersections are expected to continue to operate at LOS D or better in both peak hours. Future Year 2008 With Proposed Project When the proposed project-related traffic is combined with the background traffic (ambient plus cumulative projects), the same two key study intersections (PCH at Warner and Seapoint Avenues) would experience an increase in HCM intersection delay, but are expected to continue to operate at the same adverse service levels. The intersection of PCH at Warner Avenue would still operate at LOS F during both A.M. and P.M. peak hours, while the intersection of PCH at Seapoint Avenue would operate at LOS E during the P.M. peak hour. The remaining 4-718 intersections are expected to either operate at LOS D or better during the A.M. and P.M. peak hours, with the addition of project traffic. Roadway Segment Analysis The daily roadway segment Level of Service at the 25 study roadway segments are summarized in Table 3.14-14. Table 3.14-14 Year 2008 Roadway Link Capacity Analysis Summary (1) (2) (3) (4) Year 2008 Background Year 2008 with Project (5) LOS E Arterial Capacity Lanes Daily Volume V/C Ratio LOS Daily Volume V/C Ratio LOS V/C Increase Pacific Coast Highway 60,800 4 46,456 0.764 C 48,241 0.793 C 0.029 Wamer Ave to Seapoint Ave Pacific Coast Highway 60,800 4 39,794 0.655 B 41,579 0.684 B 0.029 Seapoint Ave to Goldenwest St Pacific Coast Highway 37,500 4 42,711 1.139 F 44,881 1.197 F 0.058 Goldenwest Street to 6th Street Pacific Coast Highway 56,300 6 43,067 0.765 C 45,237 0.803 C 0.038 6th Street to First Street Pacific Coast Highway 56,300 6 43,810 0.778 C 43,810 0.778 C 0.000 First Street to Huntington Street 2-80 City of Huntington Beach Chapter 2 Text Changes levels of service with the addition of project traffic. The remaining 18 roadway segments are expected to operate at LOS C or better on a daily basis,with the addition of project traffic. Future Year 2020 General Plan Buildout Conditions The Year 2020 General Plan Build-out condition without and with the proposed project traffic was analyzed at 4931 key study intersections and 27 key roadway segments as part of the traffic study. These intersections and roadway segments were based on traffic forecasts using the Santa Ana River Crossings Cooperative Study (SARCCS) traffic analysis model. Due to limitations in the SARCCS traffic analysis model, only 30 of the 32 study intersections were analyzed. The intersections of First Street/Pacific View Avenue and Magnolia Street/Atlanta Avenue were excluded. In order to determine the Year 2020 General Plan Buildout traffic volumes in the project vicinity based on several different potential build-out roadway network scenarios, model runs of the Year 2020 General Plan Buildout SARCCS were conducted without and with proposed project traffic for four roadway network scenarios, listed as follows: 1. With Hamilton Avenue Extension, Walnut Avenue Alignment, and the Santa Ana River Crossings (Current General Plan Circulation Element Network) 2. Without'Hamilton Avenue Extension, but with Walnut Avenue Alignment and the Santa Ana River Crossings 3. Without Hamilton Avenue Extension and Walnut Avenue Alignment, but with the Santa Ana River Crossings 4. Without Hamilton Avenue Extension, Walnut Avenue Alignment, and the Santa Ana River Crossings The Hamilton Avenue Extension refers to the potential future connection of Hamilton Avenue between Newland Street and Beach Boulevard through the existing wetland consistent with the General Plan Circulation Element. The Walnut Avenue Alignment refers to the extension of Walnut Avenue between Second Street and First Street to align with future Pacific View Avenue through the proposed project. The Santa Ana River Crossings refer to future bridge crossings of the Santa Ana River channel at Garfield Avenue/Gisler Avenue and Banning Avenue/19th Street to connect Costa Mesa and Huntington Beach. Intersection capacity analyses and roadway segment capacity analyses have been conducted for General Plan Build-out roadway network scenario No. 1 only, which is consistent with the City's current General Plan Circulation Element network. The remaining three General Plan Buildout roadway network scenarios were used to analyze their effect on Pacific View Avenue through the project site between 1st and Huntington Streets. Pacific City EIR 2-81 Chapter 2 Text Changes Rage 3. ._ _.. _ 7 _F7ff. r# vs' W Intersection Analysis under Scenario No. 1 The peak hour LOS results at the 4031 key study intersections for the Year 2020 General Plan Buildout condition under scenario No. 1, without and with the proposed project-related traffic, are summarized in Table 3.14-15. Table 3.14-15 Year 2020 General Plan Buildout Peak Hour Intersection Levels of Service Summary-w/Hamilton Ext. w/Walnut Alignment w/SARC (1) (2) (3) (4) Year 2020 Without Year 2020 With Project Project Impact/ Year 2020 With Time Project Traffic Traffic Significance Mitigation Key Intersections Period ICU LOS ICU LOS ICU Inc. Y/N ICU LOS 1 Goldenwest Street at A.M. 0.588 A 0.600 A 0.012 N - - Pacific Coast Highway P.M. 0.728 C 0.746 C 0.018 N - - 2 17th Street at A.M. 0.624 B 0.638 B 0.014 N - - Pacific Coast Highway P.M. 0.677 B 0.699 B 0.022 N - - 3 9th Street at A.M. 0.607 B 0.621 B 0.014 N - - Pacific Coast Highway P.M. 0.596 A 0.618 A 0.022 N - - 4. 6th Street at A.M. 0.641 B 0.654 B 0.013 N - - Pacific Coast Highway P.M. 0.724 C 0.744 C 0.020 N - - 5. Main Street at A.M. 0.249 A 0.261 A 0.012 N - - 6th Street P.M. 0.424 A 0.451 A 0.027 N - - 6 Main Street at A.M. 0.778 C 0.790 C 0.012 N - - Pacific Coast Highway P.M. 0.869 D 0.888 D 0.019 N - - 7 First Street at A.M. 0.210 A 0.226 A 0.016 N - - Atlanta Avenue P.M. 0.267 A 0.318 A 0.051 N - - 8 First Street at A.M. 0.648 . B 0.648 B 0.000 N - - Pacific Coast Highway P.M. 0.636 B 0.691 B 0.055 N - - 9 Huntington Street at A.M. 0.242 A 0.266 A 0.024 N - - Atlanta Avenue P.M. 0.338 A 0.353 A 0.015 N - - 10. Delaware Street at A.M. 0.212 A 0.248 A 0.036 N - - Atlanta Avenue P.M. 0.271 A 0.391 A 0.120 N - - 11 Huntington Street at A.M. 0.634 B 0.685 B 0.051 N - - Pacific Coast Highway P.M. 0.606 B 0.732 B 0.126 N - - 12 Huntington Street at A.M. 0.125 A 0.278 A 0.153 N - Pacific View Avenue P.M. 0.192 A 0.367 A 0.175 N - - 13. Beach Boulevard at A.M. 0.651 B 0.678 B 0.027 N - - Adams Avenue P.M. 0.820 D 0.849 D 0.029 N - - 14. Beach Boulevard at A.M. 0.413 A 0.439 A 0.026 N - - Indianapolis Avenue P.M. 0.557 A 0.593 A 0.036 N - - 15. Beach Boulevard at A.M. 0.408 A 0.452 A 0.044 N - - Atlanta Avenue P.M. 0.722 C 0.783 C 0.061 N - - 16 Beach Boulevard at A.M. 0.693 B 0 712 C 0.019 N - - Pacific Coast Highway P.M. 0.762 C 0 795 C 0.033 N - - 17. Newland Street at A.M. 0.329 A 0.333 A 0.004 N - - Atlanta Avenue P.M. 0.512 A 0.523 A 0.011 N - - 18 Newland Street at A.M. 0.745 C 0.763 C 0.018 N - - Pacific Coast Highway P.M. 0.665 B 0.699 B 0.034 N - - 2-82 City of Huntington Beach Chapter 2 Text Changes Table 3.14-15 Year 2020 General Plan Buildout Peak Hour Intersection Levels of Service Summary-w/Hamilton Ext. w/Walnut Alignment w/SARC (/) (2) (3) (4) Year 2020 Without Year 2020 With Project Project Impact/ Year 2020 With Time Project Traffic Traffic Significance Mitigation Key Intersections Period ICU LOS ICU LOS ICU Inc. Y/N ICU LOS 19 Magnolia Street at A.M. 0.759 C 0.777 C 0.018 N - - Pacific Coast Highway P.M. 0.782 C 0.809 D 0.027 N - - 20 Pacific Coast Highway at A.M. 0.882 D 0.896 D 0.014 N 0.784 C Seapoint Avenue P.M. 0.952 E 0.974 E 0.022 Y 0.929 E 21. Pacific Coast Highway at A.M. 0.796 C 0.806 D 0.010 N - - Warner Avenue P.M. 0.882 D 0.897 D 0.015 N - - 22. Pacific Coast Highway at A.M. 0.887 D 0.900 D 0.013 N - - Brookhurst Street P.M. 0.705 C 0.742 C 0.037 N - - 23. Main Street at A.M. 0.634 B 0.646 B 0.000 N - - Adams Avenue P.M. 0.718 C 0.740 C 0.012 N - - 24. Main Street at A.M. 0.626 B 0.632 B 0.006 N - - Utica Avenue P.M. 0.495 A 0.506 A 0.011 N - - 25. Lake Street at A.M. 0.652 B 0.658 B 0.006 N - - Adams Avenue P.M. 0.668 B 0.677 B 0.009 N - - 26. Lake Street at A.M. 0.563 A 0.570 A 0.007 N - - Yorktown Avenue P.M. 0.510 A 0.525 A 0.015 N - - 27 Beach Boulevard at A.M. 0.724 C 0.748 C 0.024 N - - Yorktown Avenue P.M. 0.871 D 0.893 D 0.022 N - - 28. Beach Boulevard at A.M. 0.766 C 0.784 C 0.018 N - - Garfield Avenue P.M. 0.878 D 0.900 D 0.022 N - - Beach Boulevard at A.M. 0.691 B 0.701 B 0.010 N - - 29. Ellis Avenue/Main P.M. 0.798 C 0.814 D 0.016 N - - Street 30. Superior/Balboa at A.M.. 0.794 C 0.806 D 0.012 N Pacific Coast Highway P.M.. 0.633 B 0.652 B 0.019 N 31. Beach Boulevard at A.M. 0.468 A 0.506 A 0.038 N - - 3Q Pacific View Avenue P.M. 0.669 B 0.696 B 0.027 N - - Bold VIC and LOS values indicate adverse service levels based on City LOS Standards , SOURCE: Linscott,Law&Greenspan 2003a Future Year 2020 Without Proposed Project As shown in Table 3.14-15, without the proposed project-related traffic, one of the thirty-one key study intersections (Seapoint Avenue and PCH) would operate at adverse LOS E (V/C = 0.952) during the P.M. peak hour based on the SARCCS traffic model data. The remaining intersections are forecast to operate at LOS D or better during the A.M. and P.M. peak hours. Future Year 2020 With Proposed Project When the proposed project-related traffic is added to the future Year 2020 General Plan Buildout condition, the same intersection (Seapoint Avenue at PCH) would continue to operate at adverse LOS E during the P.M. peak hour. Although the addition of the proposed project traffic would increase the ICU at Pacific City EIR 2-83 Chapter 2 Text Changes y. ;Page,!tz4 t Y am`r- .,.W ' d - F : .:- ; ..m.s._.........._�,,,.r,�_.. '� a.....:b.. ��....:�..,,.a»" this intersection by 0.022, the ultimate level of service would remain the same as the Year 2020 background conditions. The remaining 2130 intersections were forecasted to operate at LOS D or better during the A.M. and P.M. peak hours. These projected A.M. and P.M. peak hour traffic volumes for the Year 2020 are illustrated in Figures 3.14-12 and 3.14-13,respectively. In addition, the projected ADT volumes, which represent the Year 2020 conditions with the proposed project, are illustrated in Figure 3.14-14. Roadway Segment Analysis under Scenario No. 1 The Daily Level of Service results at the 27 key roadway segments analyzed for the Year 2020 General Plan Buildout condition under Scenario No. 1, without and with the proposed project- related traffic, are summarized in Table 3.14-16. Future Year 2020 Without Proposed Project As shown, without project traffic for the Year 2020 General Plan Buildout condition, six of the 27 roadway segments are expected to operate at adverse LOS D or worse. These 6 roadway segments with adverse service levels without project traffic include • PCH: Goldenwest Street to 6th Street(LOS D, V/C = 0.881) • PCH: 6th Street to First Street(LOS D, V/C = 0.881) • PCH: First Street to Huntington Street(LOS D, V/C = 0.867) • PCH: Newland Street to Magnolia Street(LOS F, V/C = 1.025) • PCH: Magnolia Street to Brookhurst Street(LOS F, V/C = 1.005) • Beach Boulevard: Garfield Avenue to Ellis/Main Avenue (LOS D, V/C= 0.828) The remaining 21 roadway segments are expected to operate at LOS C or better on a daily basis, without the proposed project traffic. Future Year 2020 With Proposed Project As shown in Table 3.14-16, when the proposed project traffic is added to the Year 2020 General Plan Buildout condition under Scenario No. 1, the same 6 study roadway segments would continue to operate at the same unsatisfactory LOS. In addition, 3 of the 6 roadway segments would also experience a V/C increase greater than 0.030, while 1 roadway segment (PCH: First Street to Huntington Street) would experience a decrease in V/C upon addition of the proposed project traffic. However, based on the City's impact criteria for roadway links, none of the study roadway link has an adjacent study intersection with 2-84 City of Huntington Beach Chapter 2 Text Changes 'agG14i5 1 s' 7 • Caltrans Methodology Under the State of California (Caltrans) Methodology, the Year 2008 peak hour intersection capacity analysis, as summarized in Table 3.14-13, shows that the intersection of PCH at Warner Avenue would operate at LOS F during both A.M. and P.M. peak hours, which is an unsatisfactory LOS. Table 3.14-13 shows that this intersection would still operate at the same LOS during the A.M. and P.M. peak hours without addition of proposed project traffic. The Year 2008 background conditions indicate that the forecast increase in background traffic alone would result in the same unsatisfactory LOS at the intersection of PCH and Warner Avenue. The addition of the proposed project traffic would increase the HCM intersection delay at this intersection and further worsen intersection operations. Therefore, under Caltrans methodology, impacts at this intersection would be potentially significant. Impact TR-2 Under Year 2008 conditions, implementation of the proposed project would significantly affect the operating conditions of the intersection of PCH at Seapoint Avenue by increasing traffic volume under Caltrans Methodology. Under the State of California (Caltrans) Methodology, the Year 2008 peak hour intersection capacity analysis, as summarized in Table 3.14-13, shows that the intersection of PCH at Seapoint Avenue would operate at LOS E during P.M. peak hour with the proposed project traffic, which is an unsatisfactory LOS. Table 3.14-13 shows that this intersection would still operate at the same LOS during the A.M. and P.M. peak hours without addition of proposed project traffic. The Year 2008 background conditions indicate that the forecast increase in background traffic alone would result in the same unsatisfactory LOS at the intersection of PCH and Seapoint Avenue. The addition of the proposed project traffic would increase the HCM intersection delay at this intersection and further worsen intersection operations. Therefore, under Caltrans methodology, impacts at this intersection would be potentially significant. Impact TR-3 Under Year 2008 conditions,implementation of the proposed project would not significantly adversely affect the operating conditions of roadway segments by increasing traffic volume. Analysis of the Year 2008 roadway segment capacities at the 25 study roadway segments, which is summarized in Table 3.14-14, shows that unsatisfactory LOS would be expected to occur at the following seven roadway segments due,to background traffic conditions: • PCH: Goldenwest Street to 6th Street(v/c = 1.139, LOS F) • PCH: Huntington Street to Beach Boulevard(v/c = 1.160, LOS F) • PCH: Beach Boulevard to Newland Street(v/c = 0.828, LOS D) Pacific City EIR 2-85 Chapter 2 Text Changes r'age‘g-a: U ��.,,x.� ..- .,. '�,::�A���.,.•.a a:: ,:.'�� � ^fie�� ...:� �>. S�..M .:'- ���"�.��.: � 1s7,e4 nk • PCH: Magnolia Street to Brookhurst Street(v/c = 0.826, LOS D) • Beach Boulevard: Adams Avenue to Yorktown Avenue (v/c = 0.821, LOS D) • Beach Boulevard: Garfield Avenue to Main Street(v/c = 0.905, LOS E) • Atlanta Avenue: First Street to Huntington Street(v/c = 0.825, LOS D) As shown in Table 3.14-14, aside from the Atlanta Avenue segment between First Street and Huntington Street,the other 6 study roadway segments identified above would continue to operate at the same adverse LOS with the addition of the proposed project traffic when compared to the City criteria, and each of these 6 study segments would also experience a V/C increase greater than 0.030. None of the study roadway segments, however, has an adjacent study intersection(s) with adverse LOS with the addition of project traffic. Therefore, impacts on these roadway segments would be less than significant. Impact TR-4 Under the Year 2020 conditions with scenario No. 1 (with the Hamilton Avenue Extension, Walnut Avenue Alignment, and Santa Ana River Crossings), the proposed project would adversely affect the operating conditions of the intersection of PCH at Seapoint Avenue by increasing traffic volume. The Year 2020 General Plan Buildout Peak Hour Intersection Capacity Analysis under scenario No. 1 (with the Hamilton Avenue Extension, Walnut Avenue Alignment, and Santa Ana River Crossings) at the 3831 key intersections without and with the proposed project traffic is summarized in Table 3.14-15. As shown, the following key study intersection would operate at LOS E under 2020 General Plan Buildout Conditions, while the remaining 4930 key study intersections are forecast to operate at LOS D or better during the A.M. and P.M. peak hours: • Seapoint Avenue at PCH (LOS E during P.M. peak hour) The addition of the proposed project traffic would increase the ICU at this intersection by 0.022, and further worsen intersection operations. Therefore, impacts at this intersection would be potentially significant. Impact TR-5 Under the Year 2020 conditions with scenario No. 1 (with the Hamilton Avenue Extension, Walnut Avenue Alignment, and Santa Ana River Crossings), the proposed project would not adversely affect the operating conditions of roadway segments by increasing traffic volume. The Year 2020 General Plan Buildout Daily Roadway Link Capacity Analysis under Scenario No. 1 at the 27 study roadway segments without and with the proposed project traffic are summarized in Table 3.14-16. As 2-86 City of Huntington Beach Chapter 2 Text Changes Rage 4 $ ty,no r were conducted using the peak hour volume warrant and planning warrant (Caltrans Figure 9.4) at the 3 unsignalized intersections. Based on an analysis of the applicable warrants, Year 2008 conditions without and with proposed project traffic indicated that none of the 3 key unsignalized study intersections satisfy the peak hour traffic signal warrant. In addition, using the planning warrant and Year 2008 and Year 2020 daily traffic at the Huntington Street/Pacific View Avenue intersection, the signal warrant was not satisfied. However, using the planning warrant, the intersection of First Street and Atlanta Avenue satisfied the traffic signal warrant. This intersection would require a traffic signal due to existing traffic with the addition of ambient growth. The proposed project would add to the need for a traffic signal at this location. In the absence of a traffic signal at this location, impacts would be potentially significant. Impact TR-7 Implementation of the proposed project would not adversely affect the operating conditions of nearby facilities or streets that are part of the Congestion Management Program Highway System (CMPHS). As shown in Table 3.14-10, the proposed project is projected to generate approximately 12,002 daily trip-ends, which meets the criteria requiring a CMP traffic impact analysis. The CMP highway system arterial facilities and CMP arterials closest to the proposed project site consist of Beach Boulevard, PCH, and Warner Avenue. The CMP arterial monitoring locations/intersections nearest to the project site include Warner Avenue at PCH, Beach Boulevard at PCH, and-Beach Boulevard at Adams Avenue. Based on project trip generation estimates and trip distribution patterns, the amount of project traffic using these CMP facilities indicates that only 1 of the 3 all three CMP intersections have a roadway link adjacent to the intersection thatd exceeds the 3 percent threshold established by the CMP and all three CMP intersections have been analyzed. In addition, the roadway link on PCH north of the intersection of Superior Avenue/Balboa Boulevard at PCH exceeds the 3 percent threshold and the roadway link south of the intersection of Superior Avenue/Balboa Boulevard and PCH falls below the 3 percent threshold. Therefore, the intersection of Superior/Balboa and PCH has been analyzed according to the CMP criteria. The intersection of Beach Boulevard at PCH is Projected intersection operations at this CMP intersections would be within acceptable LOS. <LOS A in the A.M. peak hour and LOS D in the Therefore, impacts to the CMPHS would be less than significant. Impact TR-8 The proposed project would provide adequate parking. The parking conditions associated with the proposed project consist of off-site parking supply and demand adjacent to the project site, and on-site parking supply and demand provided within subterranean parking structures below both the retail/restaurant/office/hotel and residential developments. Off-Site Parking As presented in Figure 3.14-5, there are currently 102 parking spaces (98 metered spaces and 100 feet of unrestricted parking, or approximately 4 spaces) on both sides of First Street, Atlanta Avenue, and PCH Pacific City EIR 2-87 Chapter 2 Text Changes C7... $ 4.7,73:4 r 3 a I ; ,:, . ems - °e,-FcY'3 [ .._.. �..,.....,_.�wx..� ._nm ��k:.... , P along the north side of PCH. The existing parking spaces currently abutting the site, as shown in Figure 3.14-5, that are removed as a result of the proposed project would be replaced with on-site parking within the parking structure. On-site street parking would include approximately 55 parking spaces on Pacific View Avenue (16 spaces on the north side and 39 spaces on the south side) and 19 parking spaces on the internal loop road. This is in addition to all required on-site parking that would be provided in the subterranean garages. However, the 39 angled spaces depicted on the south side of Pacific View Avenue would occur in the short term only. This parking would be removed in the long term, resulting in an ultimate configuration of approximately 16 spaces on the north side of Pacific View Avenue. Shared Parking Analysis The parking demand for the proposed project was calculated by using the shared parking criteria established by the Urban Land Institute (ULI) (Linscott Law & Greenspan Engineers 2003b). The basis for using this shared parking criteria stems from accumulated experience in parking demand characteristics, which indicates that a mixing of land uses (as proposed under the proposed project) results in an overall parking need that is less than the sum of the individual peak requirements for each land use. Shared Parking calculations recognize that different uses often experience individual peak parking demands at different times of day, or days of the week. When uses share a common parking footprint, the total number of spaces needed to support the collective whole is determined by adding parking profiles (by time of day or day of week), rather than individual peak ratios as represented in the City of Huntington Beach Zoning and Subdivision Ordinance (Chapter 231— Off-Street Parking and Loading Provisions). The shared parking methodology is applicable to the proposed project because the individual land uses (i.e., retail, restaurant, hotel and office uses) experience peak demands at different times of the day. To account for parking demand interaction with the beach, adjacent resort hotels, surrounding residential neighborhoods, and Downtown parking supply, consistent with the traffic study for the proposed project and information provided in ULI's Shared Parking, which indicates non-auto use ranging from 10 percent to as much as 57 percent, a parking demand reduction was applied to the traffic generation forecast. The following assumptions were utilized in calculating shared parking projections: ■ 20 percent City parking code reduction for restaurants to account for parking demand interaction with the beach, adjacent resort hotels, surrounding residential neighborhoods, and Downtown parking supply • 15 percent City parking code reduction for retail to account for parking demand interaction with the beach, adjacent resort hotels, surrounding residential neighborhoods, and Downtown parking supply • 5 percent City parking code reduction for office to account for parking demand interaction with the surrounding residential neighborhoods, and Downtown parking supply 2-88 City of Huntington Beach Chapter 2 Text Changes determined. This ensures that adequate storage capacities would be provided to ensure adequate levels of service of operating characteristics in and around the facility. Each of the five residential access driveways and two retail/restaurant/office/hotel access driveways would have a maximum expected queue of two vehicles, with a storage reservoir length of 44- feet between the gate and back of sidewalk. However, the visitor access driveway on Driveway #6 would require a storage reservoir length of 66 feet between the manned guard house and the back of the sidewalk. Driveway #6 would accommodate both residents and visitors with separate drive aisles for each, and could accommodate three vehicles between the manned guardhouse and the back of the sidewalk. A separate drive aisle would be provided for residents to by-pass visitors queuing at the manned guardhouse. Based on the results of this analysis, adequate driveway and queuing access for the proposed project would be provided, and vehicles would be able to safely and efficiently maneuver into and out of the site. In addition, project accesses would be designed in accordance with Fire Department requirements for accessibility. As such, a—impacts associated with emergency vehicular access to the project site would be less than significant. For a discussion of Fire Department service at the site,refer to Impact PS-1 in Section 3.12 (Public Services) of the EIR. Table 3.14-18 Project Access Driveways Driveway No. Access Design Features 1 Service access for Retail/Restaurant Right-turn in/right-turn out only with one inbound and one outbound lane uses 2 Customer access for Full-movement with all-way stop control with one inbound and two Retail/Restaurant/Office uses outbound lanes(left turn and right turn);westbound left turn pocket recommended minimum length of 100 feet on Pacific View Avenue 3 Customer access for Full-movement with all-way stop control;one inbound and two outbound Retail/Restaurant/Office and Hotel lanes(left turn and right turn);westbound left turn pocket recommended uses minimum length of 200 feet on Pacific View Avenue. 4 Service and secondary employee Right-turn in/right-turn out only;one inbound and one outbound lane. access for Hotel use 5 Resident-only access for Residential Full-movement with all-way stop control;one inbound and one outbound use lane;eastbound left turn pocket recommended length of 100 feet on Pacific View Avenue. 6 Resident and visitor access for Full-movement with all-way stop control;two inbound and two outbound Residential use lanes(left turn and right turn);eastbound left turn pocket recommended minimum length of 100 feet on Pacific View Avenue. 7 Resident-only access for Residential Full-movement with outbound stop control;one inbound and one use outbound lane with 44-foot storage reservoir at gate;northbound left turn pocket recommended minimum length of 100 feet on Huntington Street. 8 Resident-only access for Residential Full-movement with outbound stop control;one inbound and one use outbound lane with 44-foot storage reservoir at gate;northbound left turn pocket recommended minimum length of 100 feet on Huntington Street. 9 Resident-only access for Residential Right-turn in/right-turn out with outbound stop control;one inbound and use one outbound lane with 44-foot storage reservoir at gate. 10 Service access for Retail/Restaurant Right-turn in/right-turn out only with one inbound and one outbound lane. uses Impact TR-10 The project would not substantially increase roadway hazards. For the purposes of this analysis, roadway hazards are defined as changes to circulation patterns that could result in unsafe driving conditions. Examples include inadequate vision or stopping distance at Pacific City EIR ! 2-89 Chapter 2 Text Changes CR TR-C A Transportation Demand Management Plan shall be submitted for review and approval prior to issuance of Certficate of Occupancy. CR TR-D A traffic control plan for all work within the City right-of-way and Caltrans right-of- way shall be submitted to the Public Works department for review and approval prior to issuance of a grading permit. The City's plans shall be prepared according to the Traffic Control Plan Preparation Guidelines. Plans for Pacific Coast Highway shall be per Caltrans requirements and subject to their review and approval. CR TR-E The developer shall coordinate the development of a truck haul route with the Department of Public Works if the import or export of material is required. This plan shall include the approximate number of truck trips and the proposed truck haul routes. It shall specify the hours in which transport activities can occur and methods to mitigate construction-related impacts to adjacent residents. These plans must be submitted for approval to the Department of Public Works prior to issuance of a grading permit. CR TR-F Traffic impact fees shall be paid at the rate calculated at the time of payment. The fee shall be based on the trip generation for the actual building square footage, units or rooms as applicable using methodology approved as part of the project traffic impact study. In addition to the standard City requirements listed above, mitigation measures (MM) would be required to address project impacts. The following mitigation measures would be required to address impacts to intersection operations, as described above under Impact TR-1, Impact TR-2, and Impact TR-4. MM TR-1 The Applicant shall contribute a fair share contribution of 22 percent to the installation of a third northbound through lane on PCH consistent with the Orange County MPAH and Caltrans Route Concept Study for PCH. The County of Orange and Caltrans would complete this improvement. The Applicant's fair share contribution shall be paid prior to issuance of ethe first certificate of occupancy. MM TR-2 A second westbound right turn lane shall be added on Seapoint Avenue. The City shall ensure completion of this improvement, and the Applicant shall contribute a fair share contribution of 26 percent to this improvement. The Applicant's fair share contribution shall be paid prior to issuance of ethe first certificate of occupancy. Implementation of MM TR-1 would improve the Year 2008 level of service at the PCH and Warner Avenue intersection, under the City criteria, from LOS E and LOS F during the A.M. and P.M. peak hours, 2-90 City of Huntington Beach Chapter 2 Text Changes respectively, to LOS C and LOS D. Under the State of California Methodology, this mitigation measure would improve the Year 2008 level of service at the PCH and Warner intersection from LOS F during both the A.M. and P.M. peak hours to LOS D. This intersection improvement is currently under study by the County of Orange. Feasibility of implementing this improvement has not been determined at this time. In addition, the ultimate implementation of this measure is not under the discretion of the City of Huntington Beach. Under the State of California Methodology, MM TR 2 would improve the Year 2008 level of service at the PCH and Seapoint Avenue intersection from LOS E during the P.M. peak hour to LOS D, while the recommended intersection improvement under MM TR 2 would also serve to offset the impact of the proposed project traffic during Year 2020 at the intersection of PCH and Seapoint Avenue during the P.M. peak hour. Although implementation of MM TR 2 would improve the Year 2008 level of service,at this intersection to an acceptable level, it would only reduce the ICU at this intersection by 0.045 during Year 2020. As such, this intersection would still remain at LOS E in Year 2020 upon implementation of MM TR 2. However, the resulting ICU after implementation of MM TR 2 would be reduced below that of the Year 2020 baseline conditions, and intersection operations would be within City thresholds. Therefore, the impact at this intersection from operation of the proposed project in Year 2020 would be reduced to a less- than-significant level. The Applicant would contribute its fair share of 26 percent to this improvement, and the City would be obligated to implement this intersection improvement. The Downtown Specific Plan EIR identified significant impacts to circulation. The impacts to specific intersections were not identified, and these impacts are defined and clarified in this EIR. However, the significant effect on traffic as previously identified in EIR 82-2, in addition to the Statement of Overriding Considerations prepared on that EIR (City Resolution No. 5284)is noted. The impact identified under Impact TR-1 would be significant and unavoidable because implementation of MM TR 1 may not be feasible and implementation of this measure is not under the discretion of the City of Huntington Beach. The impact on the intersection of PCH and Seapoint in Years 2008 and 2020, as discussed under Impact TR-2 and Impact TR-4, respectively, resulting from the proposed project would be less than significant upon implementation of MM TR-2. The following mitigation measure would be required to address impacts associated with the need for a new traffic signal, as described above under Impact TR-6. MM TR 3 Install a traffic signal at First Street and Atlanta Avenue prior to issuance of occupancy permits. The City shall provide reimbursement for the balance of the funding of improvements through the Fair Share Traffic Impact Fee account or shall designate credits against the project fees to that account. The City shall ensure completion of this improvement, and the Applicant shall contribute a fair share contribution of 57 percent to the improvement. Implementation of MM TR 3 would ensure efficient traffic flow at the intersection of First Street and Atlanta Avenue. Impact TR-6 would be reduced to less than significant. All other impacts to transportation, as described under Impacts TR-3, TR-5, and TR-7 through TR-11 would be less than significant, as discussed under project impacts. Pacific City EIR 2-91 Chapter 2 Text Changes Page 315- . , "x *� '' " � ¢ � � � 3.15 UTILITIES AND SERVICE SYSTEMS This EIR section analyzes the potential for adverse impacts on utilities and service systems resulting from implementation of the proposed project. The Initial Study (Appendix A) identified the potential for impacts associated with water supply, sewer/wastewater service, and solid waste. Data used to prepare this section were taken from the City's General Plan Utilities Element, the Water Supply Assessment (Appendix D), Domestic Water System and Sanitary Sewer System CEQA Support Information report, and information from the service providers regarding available service levels and current or anticipated constraints. Full bibliographic entries for all reference materials are provided in Chapter 7 (References) of this document. It should be noted that telephone and cable television services are "on demand"services and are, therefore, not considered in this analysis; electrical and natural gas services are specifically addressed in Section 3.5 (Energy and Mineral Resources); and storm drainage facilities are specifically addressed in Section 3.8 (Hydrology and Water Quality). 3.15.1 Existing Conditions Water Supply The City of Huntington Beach provides potable water to the project site. Currently, the City's domestic water system that serves the project site includes 12- to 20-inch pipelines located in the streets that border the project site and an 18-inch pipeline running through the site. Specifically, the off-site domestic water system that serves the project site includes the following: • Water availability from the north through a 20-inch pipeline in Lake Street, with a connection to serve the project site through an existing 18-inch pipeline on the project site. The 18-inch water main is part of the water supply for the Hilton Hotel and the Waterfront development, east of the proposed project. • Additional supply from the north through a 12-inch pipeline in Atlanta Avenue • Water supply from the west via a 12-inch pipeline continued in First Street to Pacific Coast Highway (PCH) • Water supply from the south and east through a 12-inch water main in PCH The City of Huntington Beach is currcntly constructing recently completed construction of an extension of the existing on-site 18-inch pipeline to connect to a new 12-inch main in Beach Boulevard. The existing project area water system has sufficient capacity for existing development and the approved commercial expansion projects east of the project site. 2-92 City of Huntington Beach Chapter 2 Text Changes rA 1; ,,:'v..Ji✓Lt . .,....s .�'<.sair a/ i.X '� . The City has a sccurc and reliable, drought resistant an adequate water supply, with water available to the City through two water supply sources: groundwater and imported surface water. The primary water source for the City of Huntington Beach's municipal water supply is groundwater produced from the City's wells in the Santa Ana Groundwater Basin. The City produces groundwater via seven existing domestic water wells that meet or exceed all water quality standards. The remaining water supply is purchased from the Municipal Water District of Orange County, a member agency of the Metropolitan Water District of Southern California. This imported water is supplied to the City via three service connections. In addition, the City has emergency mutual-aid water connections with the Cities of Fountain Valley, Seal Beach, and Westminster. Water supply is provided to the City and managed pursuant to a system of institutional arrangements, agreements, permits, licenses, judgments, and statutes. The quality of the water available to the City is regulated by the California Regional Water Quality Control Board, Santa Ana Region, and is managed, in part,by the Orange County Water District(OCWD). The quantity and sources of the native surface supply to the Santa Ana River, which naturally replenishes the Orange County Groundwater Basin, is governed by the terms of judgments entered pursuant to settlement agreements among upper and lower Santa Ana River Basin water users. These and other contractual arrangements have been refined since the formation of the Orange County Water District in 1933, the formation of the Metropolitan Water District of Southern California in 1928, and the organization of the Municipal Water District of Orange County in 1951. As stated in the Water Supply Assessment (WSA) dated June 6, 2003, prepared for the proposed project and supported in the City's 2000 Urban Water Management Plan, the combined ability of these water importers and regional suppliers can meet the needs of their member agencies, including the City of Huntington Beach. The WSA concludes that the total water supply available to the City during normal, single dry and multiple dry years within a 20-year projection will meet the projected water demand of the proposed project, as well as the demand of existing and other planned future uses, including agricultural uses. Projected water supply and demand for the City of Huntington Beach is provided in Table 3.15-1. The Urban Water Management Plan projects City water demands in five-year increments up to the year 2020. The Plan is based upon the ultimate land use areas from the City's General Plan. Available water supply for the City of Huntington Beach is projected to exceed the water demand of the City, including the proposed project and other planned future developments, over the next 20 years. In addition to the 2000 Urban Water Management Plan, the City of Huntington Beach also adopted a Water Master Plan in December 2000 to evaluate and plan for adequate water supply at build-out of the General Plan, as amended, and adopted specific plans, including the Downtown Specific Plan, as amended. This Plan I ' Pacific City EIR 2-93 � I Chapter 2 Text Changes Pag a 3 .5- ... confirms the Urban Water Management Plan's conclusion that water can be provided at full system build-out by Year 2020. Furthermore, according to the City (Rulla 2002), a February 11, 2002 report by the Metropolitan Water District concluded that if all imported water supply programs and local projects proceed as planned, with no change in demand projections, reliability could be assured beyond 20 years. Table 3.15-1 City of Huntington Beach Water Supply and Demand (in acre-feet) Year 2000 2005 2010 2015 2020 2022 Supply 37,460 38,200 40,075 40,100 40,100 40,100 Demand 34,600 35,526 37,270 37,330 37,330 37,330 Difference 2;860 2,674 2,805 2,770 2,770 2,770 SOURCE: City of Huntington Beach,2000 Urban Water Management Plan(December 2000),as cited in the Water Supply Assessment for Pacific City Development(Appendix D) Wastewater Service The Orange County Sanitation District (OCSD) provides regional wastewater collection, treatment, and disposal services for the City of Huntington Beach. OCSD operates two wastewater treatment plants, Plant 1 and Plant 2, and both perform primary and secondary treatment procedures. Plant 1 is located in Fountain Valley, and Plant 2 is located in Huntington Beach. The two plants receive a total of 234 million gallons per day (mgd), with Plant 1 receiving approximately 83 mgd and.Plant 2 receiving the remaining 151 mgd (OCSD 2002). Plant 2 treats most of the City's sewage. No existing capacity issues have been identified, and OCSD has developed engineering plans for plant improvements anticipated to meet area demands to the year 2050. The OCSD discharges treated wastewater offshore approximately 5 miles from the coast, at a depth of 200 feet underwater, southwest of the mouth of just north of the Santa Ana River in Huntington Beach (Personal communication, Tom Walker, December 30, 2003). The OCSD is permitted to discharge this treated wastewater through a permit jointly issued by the Environmental Protection Agency (EPA) and the Regional Water Quality Control Board (RWQCB). OCSD treats wastewater through preliminary, advanced primary, and secondary treatment in order to ensure that discharged treated wastewater does not include harmful concentrations of contaminants. The OCSD tracks and evaluates water quality, sediment quality, and sea life from Seal Beach to Corona del Mar to ensure that applicable beach and water quality standards are being met. During February 2002, routine ocean monitoring detected bacteria often associated with wastewater at shallower depths than previously seen. The amount of bacteria detected did not exceed any applicable water quality standards. However, in order to eliminate the possibility that treated wastewater is adversely affecting the surf zone or recreational water quality standards, OCSD board of directors directed that all wastewater be disinfected prior to discharge. The short-term disinfection method, which began in August 2002, is a chlorination-dechlorination process. While this method is currently being employed, the OCSD is researching a long-term disinfection method. 2-94 City of Huntington Beach Chapter 2 Text Changes -fig s` ' � , Plan, an adequate water supply exists to serve the proposed project. The 2000 Urban Water Management Plan, which projected water demands for the City based on the ultimate land uses allowed under the City's General Plan, concluded that available water supply for the City of Huntington Beach would exceed the water demands of the City, including the proposed project and other planned future developments, over the next 20 years. The plan projected that a water demand of 37,330 acre-feet would occur in the City of Huntington Beach by year 2022, and that a water supply of 40,100 acre-feet would be available to serve that demand. Provision of this reliable, drought resistant water supply to the City is done through coordination with other local, regional, and state agencies. The two water supply sources available to the City, groundwater from the Santa Ana Groundwater Basin and imported surface water from the Metropolitan Water District of Southern California, are managed pursuant to a system of institutional arrangements, agreements, permits, licenses, judgments, and statues. The water supply provided to the City from water importers and regional suppliers, which are governed by contractual agreements, would provide the City with a sccurc and rcliablc an adequate water supply over the next 20 years. Therefore,impacts to water supply would be less than significant. Impact U-2 The proposed project would be served with adequate water and fire flows. Based on the design criteria for the City of Huntington Beach and the current proposed development concept, the estimated water demand types for the proposed project are shown in Table 3.15-7. Table 3.15-7 Estimated Water Demand Types for the Proposed Project Water Demand Million Gallons per Day Gallons per Minute Average Day Demand 0.42 292 Maximum Day Demand 0.67 467 Peak Hour 1.05 730 Maximum Fire Flow 5.755 4,000 SOURCE: Hunsaker&Associates 2003b In addition, the following water pressure requirements have been determined for the proposed project and within the immediate project area: • Average-Day Simulations—Pressures in the immediate area of the proposed project must not drop by more than 2 psi. Pressures in the area including the proposed project must not drop below 50 psi • Peak-Hour Simulations—Pressures in the immediate area of the proposed project must not drop by more than 4 psi. Pressures in the area including the proposed project must not drop below 40 psi Pacific City EIR 2-95 Chapter 2 Text Changes jri . z'E <.aar....,:1. ` n.,.... '__.az�....._a.....'�` °'.�. -`.� �. � 4.�....� ' .�` .. .»..'�w"'„ ,z.:�,. The City of Huntington Beach Fire Department (HBFD) requires a 4,000-gpm fire-flow rate at the project site using three consecutive hydrants while maintaining a minimum residual pressure of 20 psi at each of the three hydrants. Due to the possibility of a fire occurring on any given day, the required fire flow at the project site must operate with maximum-day demands occurring elsewhere throughout the water system. In order to accommodate the water demands of the proposed project, including required water and fire flow rates, the project Applicant has agreed to fund the construction of new water lines on- and off-site to improve the City's distribution system beyond its present capabilities. Specifically, water pipelines improvements to be constructed, per City of Huntington Beach standards, as part of the proposed project include_ • A new 18-inch water main on Pacific View Avenue between First Street and Huntington Street • A new 12-inch water main in Huntington Street that would connect to an existing 12-inch water main in Atlanta Avenue, an existing water main in Huntington Street, and a new 18- inch water main in Pacific View Avenue • A new 12-inch water main in First Street (in the public right-of-way) that would connect to the existing 12-inch water main in Atlanta Avenue and with the new 18-inch water main in Pacific View Avenue • A new 12-inch water main in First Street that would connect to a new 12-inch water main in PCH and with the new 18-inch water main in Pacific View Avenue • A new 12-inch water main in Pacific Coast Highway that would connect with the new 12- inch water main in First Street and with an existing 12-inch water main in Huntington Street The proposed 12-inch water main in Huntington Street would be constructed and put into service prior to taking the 18-inch water main out of service. These improvements to the water pipeline system in the project area would provide the necessary pressure requirements to meet the average-day demand, peak-hour demand, and fire flow plus maximum-day demand of the proposed project as determined by the City and HBFD. Thus, upon completion of the proposed pipeline realignments and supplemental inter-ties to the adjacent domestic water system infrastructure,the City's domestic water system would be enhanced beyond its current capabilities to provide adequate water supply and fire flows for the proposed project. Impacts related to water and fire flows for the proposed project would be less than significant. Impact LI-3 The proposed project would be adequately served by the wastewater treatment provider, and would not exceed wastewater treatment requirements or require the expansion or construction of new wastewater treatment facilities. Regional sewer service to the City of Huntington Beach for the proposed project would be provided through construction of a new sewer connection from the project site to the OCSD's 54- inch diameter Coast Trunk Sewer, which is located at the intersection of Walnut Avenue and First Street. Relocation or modification of the other existing trunk sewers located within the public right-of-way and in the vicinity of 2-96 City of Huntington Beach Chapter 2 Text Changes fig - W. '" _ ' <...:` .«.nkif \ � .i..!......;.,. a .m �a E the absence of a recycling plan, the generation of solid waste by the proposed project would conflict with the State statute. Impacts associated with solid waste generation would be potentially significant. 3.15.5 Cumulative Impacts This cumulative impact analysis considers development of the proposed project, in conjunction with other development within the vicinity of the project in the City of Huntington Beach. Infrastructure capacity for utility services is a regional problem due to recent and projected population increases in the Southern California area. This population increase creates additional demand for utility services, which may already be at or near capacity. Water Supply A Water Supply Assessment prepared in May 30, 2003 by Hunsaker & Associates Irvine, Inc. demonstrated that an adequate supply of water in the City would be available to serve the proposed project. The 2003 Water Supply Assessment factored in the water demands of the proposed project, based on the proposed land uses, and the water demands from existing and other planned future developments in the City. This assessment, supported by the City's Urban Water Management Plan and Water Master Plan, concluded that the total water supply available to the City during normal, single dry and multiple years within a 20-year projection would meet the projected water demand of the proposed project, as well as the demand of existing and other planned future uses, including agricultural uses. Therefore, the Water Supply Assessment addresses cumulative water demands and concludes that an adequate water supply would be available to meet those demands. The existing project area water distribution system has sufficient capacity to meet the demands of the existing development and the commercial expansion projects east of the proposed project. Implementation of the proposed construction of five new water mains in the project area would need to be implemented in order to accommodate the water demands of the proposed development. Analysis of water demand using the City's H2Onet hydraulic model of the water distribution system revealed that pressure requirements for average-day demand, peak-hour demand, and fire flow plus maximum-day demand for the proposed project would be met with these piping improvements without affecting the provision of maximum-day demands elsewhere throughout the water system. Therefore, after the construction of the proposed water pipeline improvements, increased water supply demand by the City in the future would not result in water supply or water pressure deficiencies and impacts on water would not be cumulatively considerable. Pacific City EIR 2-97 Chapter 2 Text Changes '`%: "y"» t z lA 'fit. kk .. fd,'Z f Utilities and Service Systems Under this alternative, the increase in visitor-serving commercial development would increase the demands on water and wastewater services, and the amount of solid waste generated at the project site. Similar to the proposed project, construction of the necessary water and wastewater lines on- and off-site would be performed to accommodate the demands of the project. In terms of the increased demand on water services, the City's 2000 Water Master Plan, which evaluates and plans for adequate water supply at build-out of the General Plan, as amended, and adopted specific plans, including the Downtown Specific Plan, as amended, concluded that water can be provided at full system build-out by Year 2020. This alternative would be within the allowable intensities for development, and therefore, has been accounted for in the 2000 Water Master Plan. As such, with construction of all water improvements recommended in the project's approved Water Supply Assessment prepared for the proposed project, maximum build-out of the project site would not result in significant impacts on water supply. In terms of wastewater service, the Orange County Sanitation District (OCSD) estimates that there would be more than 30 mgd of unused peak flow capacity for the Coast Trunk Sewer through the year 2020, which is more than sufficient to handle the peak sewage flows resulting from the project under this alternative. Therefore, the impact of development under this alternative on the Coast Trunk Sewer capacity would be less than significant. In terms of solid waste, the City is responsible for meeting the requirements of AB939, which includes a 50 percent disposal reduction by the start of 2000 and preparation of a solid waste reduction plan to help reduce the amount of solid waste disposed at landfills. Incorporation of the identified mitigation measures would help minimize this impact, although solid waste impacts would be greater under this alternative. Overall, impacts associated with utilities and service systems would be greater under this alternative than the proposed project, although impacts would be mitigated to less-than-significant levels. 4.2.3 Reduced Project Alternative Description Implementation of the Reduced Project Alternative would result in less visitor-serving commercial uses, while maintaining the same amount of resort and residential uses as under the proposed project. Specifically, this alternative would provide a total of 561,100 sf of visitor-serving commercial uses, which include 112,200 sf of retail uses, 48,900 sf of restaurant/clubs, and 30,000 sf of office space, as shown in Table 4-1, below. These uses under the Reduced Project Alternative would represent a reduction of 28,900 sf of retail uses and a 30,000 sf decrease in office uses, while increasing restaurant/club uses by 10,000 sf. Commercial 2-98 City of Huntington Beach Chapter 2 Text Changes would not be as great as that allowed under the proposed project, the Applicant's objective of generating economic growth opportunities for the community that is consistent with the City's General Plan goals and creating additional employment opportunities for local and area residents would be achieved to a lesser degree. Impacts Aesthetics A reduction in retail and office uses under this alternative would reduce the development intensity on the site. Impacts to scenic resources within PCH, as described under Impact AES-1, would be the same under this alternative. The primary scenic resources visible from PCH near the project site include the beach and Pacific Ocean and Huntington Beach Pier, all located south and west of PCH. The project would develop land east and north of PCH, such that the project would not affect views of these scenic resources. A pedestrian overcrossing could be constructed in the future, and similar to the proposed project, impacts on scenic resources as a result of this project feature would be less than significant. Impacts to scenic vistas, as described under Impact AES-2 for the proposed project, would also be less than significant under this alternative. This alternative would include no 3-story commercial structures, although the overall building footprint would remain the same. Thus, views of the beach area from locations north of PCH would be similarly affected under this alternative, and impacts would be less than significant. Changes to visual character as described under Impact AES-3 for the proposed project would be similar under this alternative. The project would implement a high-quality mixed-use development on an underutilized site with no scenic resources. The project would implement the objectives of the Downtown Specific Plan on the site, and would be compatible in massing and character with adjacent development. The reduction in massing and building height associated with the less intense uses under this alternative reduces the contribution of the project to the overall density of development in the Downtown area. However, this alternative would not change the project effects to the visual character, and impacts under this alternative would remain less than significant. Impacts on shade/shadow and light and glare under this alternative would be similar to the proposed project. The primary contributor to shadows would be the eight-story hotel tower, which would remain a part of this alternative. This project feature would cast shadows onto adjacent residential areas during the Winter Solstice for fewer than three hours. Impacts would be similar to the proposed project, and would be less than significant, as described under Impact AES-4. As discussed under Impact AES-5, the project would result in additional sources of ate glare. However, although there would be a decrease in the amount of visitor-serving commercial development, the project under this alternative may also introduce additional reflective surfaces (e.g., brightly colored building facades, reflective glass) that could increase existing levels of daytime glare, which would potentially constitute a significant impact. Incorporation of MM AES-1 would reduce this impact associated with daytime glare to a less-than- significant level. As discussed under Impact AES-6, the project would result in additional sources of nighttime lighting. The lighting provisions of the Huntington Beach standard conditions of approval Pacific City EIR 2-99 Chapter 2 Text Changes require that all outdoor lighting be directed to prevent light spillage onto adjacent properties. Recommended MM AES-2 includes provisional measures to reduce lighting during periods of fog to reduce the effects of nighttime lighting during these instances. The impact of nighttime lighting on the project site and the project vicinity would be less than significant under this alternative. Since the location of project access under this alternative would not change, the impacts related to vehicular headlights on neighboring residences would remain a less-than-significant impact, as described under Impact AES-6. Impacts under the Reduced Project Alternative would generally be less severe than the proposed project. Air Quality The reduced project alternative would reduce total site development by 48,900 sf, which would result in a corresponding decrease in vehicular trips, and, therefore, air quality emissions. Air Quality impacts associated with site preparation activities that include excavation and grading, as well as construction of proposed structures, as identified in Impact AQ-1, would be the similar to those under the proposed project. MM AQ-1 through MM AQ-5 would be required to reduce construction emissions. Despite the reduction in the project site, the size of the site, coupled with the concurrent residential and commercial/hotel construction would result in significant and unavoidable construction air quality impacts. Under project operations, fewer operational trips by consumers and/or delivery trucks would occur, and air quality impacts associated with exceeding SCAQMD thresholds as identified in Impact AQ-2 would be less severe under this alternative than those anticipated under the proposed project. The estimated daily operational emissions associated with the reduced project alternative are presented in Table 4-2 and take into consideration the internal trip reduction and mode-shift reduction characteristics of the mixed-use interaction of the proposed project and the surrounding land uses, and the design features of the proposed project. As shown, the reduced project alternative would generate daily emissions of VOC that exceed the thresholds of significance recommended by the SCAQMD. MM AQ-6 and MM AQ-7 would reduce effects, although operational impacts as described under Impact AQ-2 would remain significant and unavoidable. 2-100 City of Huntington Beach Chapter 2 Text Changes Rage" •424 ttir ghTiff , � � .rE. Utilities and Service Systems Under this alternative, the decrease in office and retail development would result in fewer demands on water and wastewater services, and the amount of solid waste generated at the project site than as described under Impact U-lthrough Impact U-4. Overall, utilities and service systems impacts would be less severe under this alternative than the proposed project since less development would occur. The City's 2000 Urban Water Management Plan and Water Master Plan indicated that adequate water supply exists to serve the proposed project. This alternative would result in fewer additional demands on water. Therefore,impacts associated with sufficient water supply under this alternative would also be less than significant. This alternative is anticipated to result in demands of approximately 406,950 gpd, which is 1,950 gpd less than the proposed project. Additionally, since the project Applicant has agreed to fund the design and construction of new water lines on- and off- site to improve the City's distribution system beyond its present capabilities, sufficient fire flows would also exist. Adequate capacity exists in the Coast Trunk Sewer and OCSD's existing wastewater treatment facilities to serve the proposed project. This alternative would result in approximately 228,280 gpd of wastewater, which is 7,7002,700 gpd less generation of wastewater compared to the proposed project. Because the existing facilities would adequately serve the project, this alternative, which has a lower wastewater generation, would also be adequately served and this impact would also be less than significant. The reduction in visitor-serving commercial development under this alternative would result in annual solid waste generation at the project site of 1,666 tons, which is approximately 215 tons less than the proposed project. Incorporation of MM U-1 identified for the proposed project would further reduce solid waste impacts under this alternative to a less-than-significant level. 4.3 OTHER ALTERNATIVES CONSIDERED This section discusses alternatives that were considered but not carried forward for detailed analysis. These alternatives were part of the initial screening process, which identified a range of potential alternatives. Alternatives were not evaluated in detail because they either did not meet project objectives, and/or did not reduce significant project impacts. 4.3.1 Alternative Site Use of an An-alternative site was reviewed as a potential alternative to the project site. Significant and unavoidable impacts from the proposed project are related to air quality and transportation. Impacts on these resources would occur even if the project were to be developed at a different location, as these impacts are related to specific project characteristics, not project location. Location of the project at another site could reduce impacts to the Warner Avenue/PCH and Seapoint Avenue/PCH intersections. However, the total trip generation would be the same, and relocating the project to lessen impacts to these intersections would not necessarily eliminate traffic impacts of the project, as it is likely that any other location in the City would have impacts to intersection operations. Further, the construction activities would result in the same daily emissions, irrespective of project location, and mobile air emissions would be the same, since trip it Pacific City EIR 2-101 Chapter 2 Text Changes generation would be the same. Therefore, significant and unavoidable impacts would likely occur, even at an alternative location. Despite the inability of significant and unavoidable impacts to be reduced by an alternative location, the City considered whether an alternative location would be feasible in its efforts to adequately consider a range of alternatives. Due to the developed nature of the City, there are a limited - number of sites that are at least 31 acres in size and could accommodate the proposed project components. A site known as the Nesi Ascon Site, located southeast of the project site on the southwest corner of Magnolia Street and Hamilton Avenue within the City, was considered, as it is large enough to accommodate the proposed uses. However, this site is a former landfill that accepted hazardous waste, and usage of this site would require extensive remediation efforts prior to project implementation. In addition, this site is general planned and zoned solely for residential uses, which would not meet the Applicant or City objectives related to generation of employment and strengthening the City as a visitor-serving destination. This site would therefore not meet project objectives, would not reduce significant and unavoidable impacts, and could result in additional impacts related to remediation and land use due to General Plan/Zoning changes. Thus, this site was not analyzed in detail because it would not mcct projcct objectives and would require extensive rcmcdiation: The Cenco property is located immediately northwest of Nesi Ascon and would also be large enough to accommodate the proposed project. This site is zoned for Limited Industrial uses. It would allow limited residential and commercial uses, primarily oriented to employees of the surrounding industrial development, which would not meet the Applicant or City objectives related to generation of employment and strengthening the City as a visitor-serving destination. In addition, this property is adjacent to wetlands and could indirectly affect this sensitive habitat. This site would therefore not meet project objectives, would not substantially reduce significant and unavoidable impacts, and could result in additional impacts related to biological resources and land use due to General Plan/Zoning changes. A third property that would be large enough to accommodate the proposed project is a parcel at PCH and Goldenwest. This site is specific planned for commercial and open space and currently contains active oil production facilities. There is no indication that this present use would change. Use of this site would require abandonment of existing uses, site remediation, and a General Plan and Zoning designation change to permit the proposed uses. Significant and unavoidable impacts would remain, and, in fact, could be compounded, since significant traffic impacts are currently identified at the PCH/Seapoint intersection. Additional impacts would result due to the secondary effects from remediation and General Plan and Zoning designation changes. Therefore, none of the alternative locations would reduce significant impacts that could not otherwise be mitigated, would result in additional adverse impacts, and, in the instances of the Nesi Ascon site and the Cenco site, would not meet basic project objectives. 4.3.2 Limited Development Alternative An alternative that would result in limited commercial development beyond the Reduced Project Alternative was considered. As previously discussed, the intent of the alternatives analysis is to provide alternatives to the project that would reduce significant project impacts while meeting most of the objectives of the project. Significant and unavoidable impacts would result from 2-102 City of Huntington Beach Chapter 2 Text Changes operational air emissions. In addition, one of the significant project impacts is traffic impacts to the intersection of PCH and Seapoint Avenue under 2008 ,and 2020 conditions. Significant and unavoidable impacts would occur at the intersection of PCH and Warner, although these would occur in the near-term conditions only. The key contributor of roadway trips that result in the significant air quality and traffic impacts is a result of the retail and office components of the project. As shown in Table 3.14-10, a total of 12,002 daily trips would be generated by the project. Of this total, commercial uses would generate 7,033 trips, hotel uses would generate 2,249 trips, and office uses would generate 672 trips. In order to reduce project contribution to operational air quality emissions and impacts to die PCH/Seapoint intersection to less-than-significant levels without mitigation, the project would need to be reduced to 96,600 sf of retail uses, with no office or hotel uses contained in the project at all. This reduction would be less than half the commercial development currently proposed and would result in less-than-significant operational air quality impacts and traffic effects. This alternative would fail to satisfy the basic objectives of the project and would likely render the project infeasible. A key City objective is the implementation of the Downtown Specific Plan, which identifies strengthening the visitor-service services of the area, such as hotel and retail uses. The need for hotels in the Downtown is a key element of the Specific Plan that would bring a critical mass of activity to the waterfront area to support expansion of other services. In addition, the City objectives include enhancement of the Downtown as a destination for visitors by expanding hotel, retail, and entertainment opportunities. None of these project objectives would be met under this alternative. In addition, the Applicant has indicated that without a critical mass of commercial and hotel uses, the project is not feasible to implement from an economic perspective and would not be implemented. Therefore, this alternative is not analyzed in detail. Pacific City EIR 2-103 Chapter 2 Text Changes .. _ ..« ...«.. :.V �....a.:.�`.... -`...A.. ....n.:.Y..F:s, ..Aa..: aC..,r...,c.... -Q .. 4,1 4.3.3 Reduced Residential Density Alternative A reduced residential density alternative was also considered. This alternative would focus on a decrease in the number of condominiums proposed as part of the project. A reduction in the density of residential units would reduce the severity of impacts, but would not lessen any significant impacts to less-than-significant levels. Significant and unavoidable impacts to air quality would result during project construction and operation. Daily construction activities would be the same even with a reduction in density, so this impact would remain. Significant impacts related to operational air emissions are largely a result of vehicular traffic, of which commercial development is the primary contributor. As shown in Table 3.14-10, a total of 12,002 daily trips would be generated by the project. Of this total, residential uses would generate 2,048 trips, or slightly less than 20 percent of total project trips. As shown in Table 3.2-6, VOC emissions from the project would total 70.94 pounds per day (lbs/day), exceeding the threshold of 55 lbs/day, thus exceeding thresholds by approximately 30 percent. As a conservative estimate, if the number of vehicular trip from residential development were to be reduced by half, a reduction in the number of trips would not be substantial in comparison to the more than 10,000 daily trips generated as a whole, and would not be large enough to reduce air impacts to less-than-significant levels. A rcduction in dcnsity of rcsidcntial uscs Thus, this potential alternative would not reduce operational air emissions or traffic impacts below levels of significance. A reduction in density would reduce the changes in the character of the area, as discussed under the aesthetic and land use analyses. Visual changes were determined not to adversely impact the visual quality of the area or the public availability of scenic views, as discussed in Section 3.1. The project would also be compatible with the density of surrounding areas, and with the allowable zoning for the site, such that land use impacts would be less than significant under the proposed project, as discussed in Section 3.9. Therefore, the reduction in density would not address any significant visual or land use impact, since none would result from the proposed project. All other project impacts would be mitigable to less-than-significant levels. A reduced residential density alternative would not reduce significant impacts that could not otherwise be reduced by mitigation measures identified for the proposed project. As such, an analysis of this alternative is not provided in detail. 4.4 ENVIRONMENTALLY SUPERIOR ALTERNATIVE A comparison of the proposed project with the alternatives analyzed in this section provides the P P P y basis for determination of the environmentally superior alternative. Impacts of each of the alternatives are compared to the proposed project in Table 4-3. Impacts to a particular resource that would be greater than the proposed project are indicated with a plus (+) sign, and impacts to a particular resource that would be less than the proposed project are indicated with a minus (—) sign. Impacts to resources that would be roughly equivalent to the proposed project are indicated with an equals (_) sign in the table below. The No Project/No Development Alternative would be environmentally superior to the proposed project on the basis of the minimization or avoidance of physical environmental impacts. However, the CEQA Guidelines require that if the environmentally superior alternative is the No Project Alternative, "the EIR shall also identify an environmentally superior alternative among the other alternatives." 2-104 City of Huntington Beach Chapter 2 Text Changes ., 5 CHAPTER 7 REFERENCES 7.1 WRITTEN REFER ENCES Abrams, L. 1923. Illustrated Flora of the Pacific States, Volumes I, II, and III. Stanford, CA: Stanford University Press. 1960. Illustrated Flora of the Pacific States, Volume IV. Stanford, CA: Stanford University Press. American Ornithologists' Union (AOU). 1998. Check-list of North American Birds, 7th ed. American Ornithologists' Union, Washington, DC. Anaheim, City of. 1999. Initial Study and Mitigated Negative Declaration, Pointe Anaheim. Prepared by BonTerra Consulting, 19 January. Aqua Science Engineers, Inc. 1998. Phase I Environmental Site Assessment, Atlanta Avenue Property, Huntington Beach, California 92648, March 26. Beatty, D. , J. Coomes, Jr., T. Hawkins, E. Quinn, Jr., and I. Yang. 1995. Redevelopment in California 1995 2nd (Second) ed. Solano Press Books. BonTerra Consulting. 2002. Revised Pacific City Biological Technical Report with cover letter, 6 February. Blasland, Bouck& Lee, Inc. 1997. Letter Report—Soil Excavation, Sampling, and Disposal of Lead Impacted Soil, Atlanta Lease, Huntington Beach Ca. Project No. 07942.01, 11 July. Bryan A. Stirrat & Associates (BAS). 2000a. Asbestos Bulk Survey: Former Grinder Restaurant, 21001 Pacific Coast Highway, Huntington Beach, California, October 17. . 2000b. Air Monitoring and Abatement Oversight: Former Grinder Restaurant, 21002 Pacific Coast Highway, Huntington Beach, California, December 14. California Department of Fish and Game (CDFG). 2001a. List of Special Plants. Natural Heritage Division, Sacramento, CA,January. 200lb. California Natural Diversity (RareFind) a• Database.se. Natural Heritage Division, Sacramento, CA, October. . 2001c. Special Animals List. Natural Heritage Division, Sacramento, CA,July. California Department of Justice, Office of the Attorney General. 2001. California and FBI Crime Index. http://justice.doj.ca.gov/cjsc_stats/prof01/30/11.pdf. Accessed on August 1, 2003. California Department of Motor Vehicles. 2003. California Vehicle Code Division 12—Equipment of Vehicles, Chapter 2. Lighting Equipment, Article 2. Headlamps and Auxiliary Lamps, August. http://www.dmv.ca.gov. Pacific City MR 2-105 II Chapter 2 Text Changes a G W Ti qgW �;;- 4� 1- �C ' : A ;P6 California Energy Commission Web site (www.energy.ca.gov/). California Integrated Waste Management Board. 2003. http://www.ciwmb.ca.gov/wastechar/ WasteGenRates/WGResid.htm. Accessed on March 24, 2003. California Native Plant Society (CNPS). 2001. Electronic Inventory of Rare and Endangered Vascular Plants in California. California Native Plant Society, Sacramento, CA. California Public Utilities Commission Web site (www.cpuc.ca.gov/). California, State of. Department of Conservation. Office of Land Conservation. 1999. 1998 Orange County Important Farmland Map. California, State of. Water Code. Section 13050(k)(1) Christopher A Joseph & Associates. 2002. City of Santa Monica Draft Master Environmental Assessment, January. de Barros, P. and S. Crull. 2002. Evaluation of Prehistoric Archaeological Site CA-ORA-149 and Historical Archaeological Site CA-ORA-1582H,January. . 2001. Paleontologic Resource Impact Mitigation Program Final Report,July. DOGGR (Department of Conservation Division of Oil, Gas, and Geothermal Resources). 1998 and 1999. Reports of Well Plugging and Abandonment, API Nos.: 059-03308, 059-03309, 059-03310, 059-03312, 059-03313, 059-03314, 059-03315, 059-00122, 059-03316, 059- 03317, 059-03318, 059-03319, 059-00123, 059-00124, 059-03311, 059-00125, 059-01938, 059-01905, 059-04162, 059-04164, 059-20894. Environmental Data Resources, Inc. 2003. The EDR Radius Map with GeoCheck. Prepared for the Pacific City Project, 21 February. Environmental Protection Agency. 2003. Bacterial Water Quality Standards for Recreational Waters (Freshwater and Marine Waters). Washington, DC: Office of Water, June 2003 Federal Emergency Management Agency. [1997] 2002. Flood Insurance Rate Maps. Orange County, CA (http://inapl.msc.fema.gov/idms/IntraView.cgi?KEY=34534903&IFIT=1), as updated by Letter of Map Revision, 13 February. Flex Your Power Web site (www.flexyourpower.ca.gov/state/fyp/fyp_homepage.jsp). Gray, J., and D. E. Bramlet. 1992. Habitat Classification System Natural Resources Geographic Information System (GIS) Project. Prepared for the County of Orange Environmental Management Agency, Santa Ana, CA. G & G Engineering, Inc. 2002. Preliminary Sewer Study for the Strand, Downtown Huntington Beach, January. Harding ESE. 2001. Revised Remediation Plan,June 15. . 2002a. Additional Information for Atlanta Site, Commercial Property Bounded by PCH, Huntington Street,Atlanta Avenue, and First Street, Huntington Beach, California, January 3. 2-106 City of Huntington Beach Chapter 2 Text Changes �....:T4W MAN F MTSAtfi RI* Ham: . 1998. Waterfront Ocean Grand Resort Supplemental Environmental Impact Report. Prepared by EIP Associates. . 1999. Mitigated Negative Declaration for the 31 Acre Site Soil Export. Environmental Assessment No. 99-1. . 2000a. City of Huntington Beach General Plan, Community Development Chapter, 2000-2005 Housing Element. . 2000b. City of Huntington Beach Water Master Plan, December. . 2000c. City of Huntington Beach Urban Design Guidelines, 5 September. Adopted by Resolution No. 2000-87. . 2000d. City of Huntington Beach Emergency Management Plan. Emergency Services Office. Updated 1 December. . 2001a. City of Huntington Beach General Plan, Natural Resources Chapter, Coastal Element. . 200lb. City of Huntington Beach Park Strategy and Fee Nexus Study, Final Report. December. . Planning Department. 2001. Notice of Exemption for Coastal Development Permit No. 00-09/Conditional Use Permit No. 00-36 (Filed on March 12, 2001), 14 February. . 2002a. Huntington Beach Downtown Specific Plan "Village Concept." Ordinance No. 3532. Revised 6 February. . 2002b. Block 104/105 Final Environmental Impact Report. Prepared by EIP Associates. . City of Huntington Beach Web site (www.ci.huntington-beach.ca.us/). ITE. Trip Generation, Sixth Edition. 1997 Kostka, Stephen L. and Michael H. Zischke. 2003. Practice Under the California Environmental Quality Act. Oakland, California: Continuing Education of the Bar, 1993. Updated December 2003. Lander, E. B. 1998. Paleontologic Resource Inventory/Impact Assessment, Huntington Beach Urban Center, Huntington Beach, Orange County, California. Paleo Environmental Associates, Inc. Prepared for Professional Archaeological Services. Laudenslayer, W. F., Jr., W. E. Grenfell, Jr., and D. C. Zeiner. 1991. A check-list of the amphibians, reptiles, birds, and mammals of California. Calif. Fish and Game 77:109-141 Linscott, Law & Greenspan. 2003a. Traffic Impact Analysis Report, Pacific City, 21 April. . 2003b. Parking Demand Analysis, Pacific City, 16 October. Makallon Atlanta Huntington Beach, LLC. n.d. Environmental Assessment No. 02-05. . 2002. Pacific City Project Description, 18 December. . 2003a. Pacific City Project Plans and CUP Application, 3 July. Pacific City EIR 2-107 Chapter 2 Text Changes . 2003b. Pacific City Master Plan, 7 July. MARCOR Remediation, Inc. 2000. Completed Project Document Package: Asbestos Abatement, Huntington Shore [sic] Motel Buildings 1, 2, 3, & 4, 21002 Pacific Coast Highway, Huntington Beach, California 92648, 1 March. Meltebarger, Monte J. 2002. Cover letter dated January 28, 2002, and package of will-serve letters for dry utilities, 28 January. Munz, P. A. 1974.A Flora of Southern California. Berkeley, CA: University of California Press. O'Shea, M.L., and R. Field. 1991. Detection and Disinfection of Pathogens in Storm-Generated Flow. Cincinnati, Ohio: Environmental Protection Agency, Risk Reduction Lab, 1991. Orange, County of. 2002. Airport Environs Land Use Plan for Joint Forces Training Base Los Alamitos, 17 October. Orange County Sanitation District (OCSD). 2002. Factsheets: Orange County Sanitation District Facts and Key Statistics;301(h)Provision of the Clean Water Act;and Disinfecting Wastewater. Pacific Coast Homes. 1993. Phase 1 Site Assessment:Atlanta Avenue Property. July. Patricia R. Koch. 2003. Letter from Assistant Superintendent, Business Services of the Huntington Beach Union High School District. February 6. Purkiss Rose-RSI Landscape Architecture Recreation and Park Planning. 2001. South Beach Phase II. Preliminary Site Plan from First Street to Huntington Dr., Huntington Beach, CA, _! December 17. Reed, Porter B. Jr. 1988. National List of Plant Species That Occur in Wetlands: National Summary. For National Wetlands Inventory, U.S. Department of the Interior. Rulla, Tom. 2002. Memorandom regarding water supply for the Strand Project. May 14. Santa Ana Regional Water Quality Control Board. 1995. Water Quality Control Plan, Santa Ana Basin. Bryan A. Stirrat & Associates. 2000a. Asbestos Bulk Survey (Former Grinder Restaurant), 17 October. . 2000b. Air Monitoring and Abatement Oversight (Former Grinder Restaurant), 14 December. Thomas Bros. Maps. 2003. Los Angeles and Orange Counties. United States Bureau of the Census. 2000. Web site (http://factfinder.census.gov). United States Department of Agriculture. 1974. Soil Survey of Orange County and the Western Part of Riverside County, CA. United States Department of Transportation, Federal Railroad Administration, 1998. High-Speed Ground Transportation Noise and Vibration Impact Assessment. Wetland Training Institute, Inc. 1995. Field Guide for Wetland Delineation. 1987 Corps of Engineers Manual. Glenwood, NM: WTI 01-1, 143pp. 2-108 City of Huntington Beach Chapter 2 Text Changes vgg,:aRifeW7:4W*::rgZSV4W* IA,*lair TO'S Chevron Environmental Management Company. 2003. Work Plan Supplemental Soil Investigation Atlanta Site Huntington Beach, California. November 11. Zeiser Kling Consultants, Inc. 2001a. Addendum Report and Response to City Comments on Item No. 10, 14 March. . 200lb. Preliminary Geotechnical Investigation, 19 November. 7.2 LIST OF PERSONS AND AGENCIES CONTACTED James Bevans. Southern California Gas Company. February 2003. Frank Blonska. Huntington Beach City School District. January 2003. Chuck Burney. Huntington Beach Fire Department. February 2003. Lee Dickerhoof. Southern California Edison Company. March 2003. Dave Dominguez. Huntington Beach Community Services Department. February 2003. Shawna Krone. City of Huntington Beach Police Department. March 2003. Kyle Lindo. Huntington Beach Marine Safety Division.January and February 2003. Gary Mesa. Huntington Beach Police Department.January 2003. Jerry Moffat. Rainbow Disposal Company. May 2003. Jacques Pelletier. Huntington Beach Fire Department. February 2003. David Perry. Huntington Beach City School District. July 2003. Gary Reynolds. Orange County Vector Control. September 2003. George Rice. Southern California Gas Company. March 2003. Rick Sailor, Former Chevron Employee. December 2003. Kevin Stonesifer. Southern California Gas Company. February 2003. Tom Walker. Orange County Sanitation District. December 2003. Mel Wright. City of Huntington Beach Petro-consultant. March 2003. Pacific City EIR 2-173 Chapter 2 Text Changes 2.3 FIGURE CHANGES Figures changed in the EIR, as shown on the following pages, include the following: • Figure 2-5a Common Open Space Diagram • Figure 2-7 Pedestrian Access and Circulation • Figure 3.9-1 Land Use Map Additional information relevant to the following figures appears in Volume III, Section 2.4, Appendix Changes. • Figure 3.14-1 Existing Roadway Characteristics > See Exhibit 3A in Section 2.4 for additional information • Figure 3.14-2 Existing A.M. Peak Hour Traffic Volumes > See Exhibit 4A in Section 2.4 for additional information • Figure 3.14-3 Existing P.M. Peak Hour Traffic Volumes > See Exhibit 5A in Section 2.4 for additional information • Figure 3.14-6 A.M. Peak Hour Project Traffic Volumes > See Exhibit 8A in Section 2.4 for additional information • Figure 3.14-7 P.M. Peak Hour Project Traffic Volumes > See Exhibit 9A in Section 2.4 for additional information • Figure 3.14-8 Average Daily Project Traffic Volumes > See Exhibit 10A in Section 2.4 for additional information • Figure 3.14-9 2008 A.M. Peak Hour Volumes with Project Traffic > See Exhibit 14A in Section 2.4 for additional information • Figure 3.14-10 2008 P.M. Peak Hour Volumes with Project Traffic > See Exhibit 15A in Section 2.4 for additional information • Figure 3.14-12 2020 General Plan Buildout A.M. Peak Hour Volumes with Project Traffic > See Exhibit 22A in Section 2.4 for additional information • Figure 3.14-13 2020 General Plan Buildout P.M. Peak Hour Volumes with Project Traffic > See Exhibit 23A in Section 2.4 for additional information 2-174 City of Huntington Beach I , . --- „„. •••,...,,. , ,,, , , ., ,. .••,,,,p -.• ''‘,' .;#"•-4 .-.\ ..--'• •=, ., ' •, "=.., ''''•• , „ ' • .,• .. ,,.. j.., /,',/ . . •e;4, ,, , , ,.. -; ,‘. r , COMMON OPEN SPACE AREA ' • "'' - ..,- s 1 s „40. je `.0' RECREATION AREA " • .•./40 ,, .4, *\\\\ , "••• , •.., , , •, 3 ,.>44-''' "'-'• „ . . 40' "A", < '‘'(. " '• '' , ,/t• •#.4{,",;, •, .t ,I i'. ' -•ii;',,, ,. . „-V1, 0 , • ‘ ,',.;t''• ,''• *,;,,,` \ • ' . REQUIRED PROVIDED / . ' ' /'•\... - 4.4 " ,;,•'' .• , s'- ?' ° .1' .' , . ' ' ' '''' \'' '' \ <- #0, " '4::;6 , ,1'211* 'ct t'''4, , \‘' ' '.' ',. 3 , PARCEL-1 2094,48918ASc.rer 4044.12887ASc.re :4.4.3sh. '' ,' ,,,,'/,,,4VA'4,,,k''• //, - •',/ 41,,,,,4.:• .<":2.eez,;4.1.,"v.1#9•.....0. ... ,,,, • 4, .0.,, 20'Setback Total; • '"•• .•• •-'',.'.,1'.•,•: •• 10,;"•'°'''.),,X:0, 141,/,', lite' 1 '''' A , , -.,. ,,,. ., , , -... ,.„•,...,.., ,,,,,,,,,,,, ,,,,,,,.. . _,,.. . ...,,,,,, , , _ ... , \ ,,,,,,,,,,,.: , ,.,," 'A !.',"'• .:,„. *•, -1/4.4t,it • ': '' ', . Recreation Area Total: •••' •••' •t ''''z #,••3"•J:':, ' 3 ' ,,,, .,:t} ,, 6,035 S.F=0.14 Acre • 4.' ,..";•"•. "-Y; # , ..;,?„'' ., ,*\*k\-. „...' 2) ,4.040 S.F.=0.09 Acre • ' \ i ft>{,'''L , ,. '.";54',"•' 052i lien0 • • -•,• "lel '..- -' - .„• -3) '''7,562 S.F.=0.17 Acre , ••, :.•-•Ityi, t- dit• . '...7i,"i:..s. • t: 4) 0,26o S.F. 2.04 Acre e1/1.0 ;''", "'" - ? -ea-,,-aa-, ;„ * .''' 4 ..-' *, - • ; ,i V__-,,;',R,:: ,,, • '', ',„.::'• ',.. ' - :'' ,• ,„t ••'=,,, • ;L:i47 4425 ssiFF:(12i:Aacc: --4>.....4k ;•107 '*,„-.,,w, • ,x ,,,,, , ,,, , , 1 ..-p. .4:vs.0400#.4.8. ‘. ,.*„..,..,;,,. 4 - 'r ,-/-."- • 4,1*****%•*>40.\ N ,?,,,,x.eA,:, A., 0 • • ' -- - . ,,L ms ,.1': L,N .21 ....?6•1,:ls• :••'4,0,04•41%,,t**'''`4.'• \ '. . ' 147)' • \ • _..., 4>48,ke. \ . •;X••fr .:„.. '••4;;451,1,°;,1;Vy:A•444"'•21217/4-111:,04014$4. 1:',. ,,,...,, •,1,?;;;'''',,e, 'Oils `' • ,h • 1 ,r -. -IA-- .- -1,-., elv 40-94,w4p4.4,4r*.~ . .„ .,, /,),,,,,,,,,,„, `”-›* \ .; a 'll ',',‘ '%; 's''',,' P4, 4%,"*W404.,,,,•***tr,,' V,..:'7,r,% ,.'0 4•••, '''•. .1/,%,,\* il ,,v, AES 1,,......4.4,t•th.,•.4)..4.a/04 t.'....,,<,4*, -,e' .,..4.,,,,,-,,,e,•;•,„,k,.,r,,,,,,,toAvo.,,,,, .-„,'.,• : ' '-1 ,d'•/ 1,- ••••- •‘•'-.k-o-tir,o,o,••.4041..-,,---,t', /'' i-, - -,e'v vq,* \ , ) ,qa ;,,,,,- . " "0 s w 4-t,•0*#,,,.•':'4,'''";•• =,'v,;• ;,%$\41='<' /I , ;• 1 ' ' 'ro i'.-41. el i 1 '''..,,„.,...„Ite„-***44 .•'1'..'''I. '''-•;'0.1` ,,,,,t4,-/t—t. A. -,; * \ .,. ., ,. , ..,. 0 ; 0, . .01 .. 1,:.,,, ‘.7.4,-.•,,ft/p.*4„;'t .. : -.,, Z;', _..,,,.4/.•.'elk ' ;4':g-i., -- •,,,,,N „ • 4 .„. ,• , ..I;-,'3,6. ,j/j;, 0,0,,,,,,,,;6,4.44 k....,,,t•n, ‘f.'",, ‘...,> ,,5A ;,;•;'', ,,,,A.,,,,O.„,-.1,;.•\ \',e ca. i :•'1! ,, , 0 „•;V,,,,y/F.!7;,.„,:, •tk,k,'*IkV''?,--',•;,,, 4', ',,, ...1 %4A 4:;,21,:re,' N------r•tr7-, -'‘''''''',/"'""/;.':, •,.'2;'''''''' '''''';,, ,,,, '\*****',', ••'''',-..„,".% 1'; _ -. . .. . ., . 1 '';':'„ 0, ,';',1 C'''°' ,- *•44.411k':••••'•'+'-'•••''''-e-:' ';',',:t i';' ,. iist.;,P,1 '%'- '' ._______,\s, ,.,,.. .,, ,,:,, ,'• t,.1%,'%:•'",.,':,..,..''.**;'' -''''' • " •' • i 4.,..'s, '..4.. I '''''..*A .;-4':.:,:'S•',. - ....-- _ ____----- - 1 111:,' ". .1, 0'4:0„-Z•;':'- ',';',-;-:-''''t.\ ''"• ,' - ,.....•• • ,, a _,.,, -------- 10400116ril,i_,,illition •'•., \'-i , =:= . :_ -";___,_,,,,_‘____•--, __ ,..7.,,,, , „,,,,,,,--r-rw• _,- , tz,, 0)1‘...irkvi4'' flip rt.% ,\( ''.-, „ „ ,, i.", A,:, .7,,,- .•..7', -•'•V-I,,, -;="•-.?•A -- ------ fra =-- -- ---:•:,..----Y A 3, , , ti w v,11,44 .. --.„ %, ..'-q!s - - „.,.... C I F I C .... ..,.„,..--.' -S111111, " '1,17,1t ,,, .. - _ gm ..„...ti 10.- 11-:-..5'; •• ' "•., ., A „14,,i':.;.' • " Q, =. 0 .-K IZI-760: r/11- = Tiggy iiipt-:,.,.... •,- Nt:?.. •:. :••• ,'i.,:.,,..kii,•,...., \ .11/4 ,.., „,...,,..,;,,,...,:,...",..,.,•;.-',-,b.-.' ,.! ,4 illibr __--. / \.,,,-. •'5 - ` toil 0.1144•:'1:41, ., . • '' ' P --'''.'' / .4 Vies -\-- 1111Lit'' :...' . • i; ,s ,; , .4V---r". -. '--- -------- -0 • - - .;' '. ''-.. \ ' r .4' 0 ill CI „.„,,,=-=='' "tr:,,•, ',I'..Os_ I,- ,,,ton. - ...- __-----•-___-=-41:-', -2-3'-'.--- . ' . „ ,". • r. rill ..111111111111111 40 0 ,_ ,„, tr.:: +...-.:.::;„.„ _2--------7:4-14::,*-7,?.. •i , . ; ,• .:,--. % rwirer 0 ,.., _____ „ *--.,-,,,..„.,!;-?-,T,:,...1-- _.., , . . ,-- ..„..- OAP _• ..,,, ......--, .,. ?.. 1 '`,,,I-e',. ' W • tA0 ,>/----- , -cr --- ..,_ •-----..-:--- :,--, , - i , :- -,...: 1 .014 • _____/7 -.;=---- - . _- _ ;ry-•• • ' itt,',,•,-;-'- - .„ bi i a awAY ,_ „ .=:'". - - ',...F?C••• •••'- ,_ , • , __„ Goal. - pctr A -ic „ •,=;. .v., .„. , , -•., .. • , ,•=. ;•,"; , , : -. , , .., • . „.. . .,....- . . ... . .. . . . • • . •- • . I. - - FIGURE 2-5a Not to Scale ...- , J ,. ' „.... Common Open Space Diagram .... . .: „._. , ‘ .. ........ City of Huntington Beach•Pacific City EIR SOURCE:Makallon Atlanta Huntington Beach,LLC.2003a 10261-00 , --i*.,-• \ 7--• ,-..\''..".`ti,-'-'/..,, ).•"„ ,.„. i,....•, \; `',..„. -,," /\• '. V.X. :/74,,,„,6.,„ \\ .;,„ '',..'',-- .1 -r--:--,,,,:Z,.. ; :-..i''''.:.,,,'e.Y ,2 -t ' . ';-..; . ` ..." •• . ---i".•':• . ^ \---• \i./,r''' 7.„.• i'104.(P X •:•,7.--it'i ; ,-,'''"t.',. :-,,' ' ' i---t ,.`,‘ ''''' , (...:\,/,'1;"'s=" ‘‘`. ' ' ,.' ' „, dr t,' %,11 , .,,,%.:..r.--,'v.,\.... ,....7 ,\ : ..., 1r ,,,,I. ,,,,, • , COMMON OPEN SPACE AREA 1" "\ ' ''' cii- ';‘"" ..iii.\ \ \....2 .4. '' e',/e" \..? ''''', . ' ‘: > ,k,...,\ . ..)....., .. • \ ....,,.... • ;,,,.. 1A .., , „. • • , . ..../:',.." / -..• ,.. ,.. ., .,,,•, .,' ,..\ (,,,,-$ /, 1.' '< /` ' %.* \-4 \7 '-\ '• --N,' 4.- ,/,- ' • ,,A \ , --,,, .,-, - ,... --,..-- s . - ::,..a;4, RECREATION AREA •,.--- , ,, -/\..-- ..• -. ----, •/• ".. o- 7 ,,,,, Ovi,,„ .., c.i: 'i.. 2-•ii%..,,i-- - -i•.'s••-"-'" , x ,XV..?•"\.. , ,/, - Ng ;' 4". z• OA.4.#' '...: ._ 2.' ,,, • ,' \ .• is / , > ../ ' ‘//// ', A•\,, ,•;.,' .:,f '7/ /••, \/' •.4 " , -. fr/'' ''' \ • • / ' e. ', °)21', ./// 'r ' \ \ ' PARCEL-1 209,498 S.F 404,187 S.F .-..--..• •.‘ , ,,i.,Z ,if,...">,‘•/, ''. ( ,,'4 \ /'e ,,, , • //4N X ,. - .., i.,. // // .ilZ-4-1 .':4(4/ '4 0 4.81 Acre 9.28 Acre --,,,) • ;•-tii 41 ''' 74ettoe,, /, *V '<'-. '-i 7 ' ' ''--t--,'i. s'::.'•- \/ ,. --/ /'' ';# • .4eeit;•e," ?•/#44 V, ..., •-, ,,,,, '.• ---...., ---.... ••••)- • .-- ...• /'' A',4ici•r0 iet•41),, .,/ ti, . X ,,,, 20'Setback Total: •. '-i•`.7;ii N -,„ • `‘•s.,/ • , .- ,,,./.04.• .,/d),.-7",:---,-,‘"- .p.-"; , \-„,.. 4, .... ..,. -. ..:85, --i. --•., -'... ..i•ii i ,fil „, /../.,..,f, ,..4 ... , _.. • •, ----,..,,, ,•,',,,, p. - _ A . e/,.. ,•/ e„...„. ,.. „,„,.:.._. .. ,_: Recreation Area Total: ' / \ ,,,,,,,, ,„,:„..„,/,, 1) 6,035 S.F= 0.14 Acre 2) 4,040 S.F= 0.09 Acre 0 0‘ # 1. A./'/Az 1A? / % \'‘, ••••,..',._.,',,..,,. '•$:if/IkAl A/;,‘,"•••,, #. 4) 88,593 S.F=-24:14-Aere 2.03 Acre ' 1''V • 5) 2,745 S.F= 0.06 ACie /„... 70, ‘,...,,, . p, .• ,040,14, ., _ •\ , i.:, Total 108,975 S.F= 250 Acre :, 2,0,,e/ ,ds • ?/A„,...- .....,.• „ /- • ''-4V7 , , • 'il -4-•:4.11,(,-,. ..,F*-A . '//A ••••••••-•/..: . ' •11‘. 40,-,-P.• * \ -::•: •-• 1., A • •-• • •-":•6;••••/07•It>wt., , // • •:- ,, , 1 ,i •-•''' r ' , i FA. rr ., 4Avtgweitife*\ st. ,,, ,se 4.v>1., N .... .:,"- tic-) 00. 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II 10 1•1111 A 0 • . ..10•1.16 i 1 --4- • ..... .• 1 i • -.. ... 10.1" v -.., ...”-- ''-',;i§07:.• ••• • ,.:0.,. ..-- , - .- 4,0..0.0••—-- T HIGHW''" ..i.-_d-s.,11, • nuis,000,71.• • Fic cO AS ---,"A.M.." - ,PACt .f • 17 •• .„ - '-', „.„.. ,, ,,, ' , '''...I:. ..1 i I I , m ,,..-.----.7.--i'-• - -......-..., I I I I I I .......- • - ...•. •... ••• ................. .0. : AI( EIP FIGURE 2-7 Not to Scale Pedestrian Access and Circulation . SOURCE:Makallon Atlanta Huntington Beach,LLC.2003a 10261-00 City of Huntington Beach•Pacific City EIR :. ,. '' .: ... . . . LEGEND ,t,. e —,V' ..•••• - „ IA . • .3 3 s., •1'' 3 4, • ' 9 ' 'c. ' '' ,.: ' I in u I mu I 20'WIDE PUBLIC ACCESS 01, ,•' # •• • .i..,., . ...,<1.) , ' 1 V., • ' - - ,. • < .., • , CORRIDOR 0' .* - 2\) • , ., 2 ...:, 0 i I.',„ ' -.1k' • .: . ' FRONT DOOR TO BUILDING t. # , ' .'" , . • .0'. • . ',i 4 , •, .: : .. ... •C\ ..., ..,:, • SECURED ACCESS' • ,. ,. 3-3 , „ , ..,,• -#, V- # . . *••• ' , ——- PERIMETER PARKWAY S. 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E I P FIGURE 2-7 Not to Scale Pedestrian Access and Circulation SOURCE:Makallon Atlanta Huntington Beach,LLC.2003a 10261-00 0 i.I I'V i City of Huntington Beach•Pacific City EIR •- - -- • LEGEND LEGEND LEGEND LEGEND PROJECT SITE BOUNDARY OPEN SPACE COMMERCIAL,INDUSTRIAL,MIXED-BBE DENSITY SCHEDULE 15 Max.15 UnitslNet Acre RESIDENTIAL OS-P. .PARK'. Max,25 Units/Net Acre RL RESIDENTIAL LOW 1 OS S I. SNORE DENSITY PERMITTED DENSITY DENSITY l CODE (FLOOR AREA RATIO) 0i SS Units or Greater/Net Acre PUBLIC RESIDENTIAL MEDIUM F1 0.35 RM DENSITY P. I PUBLIC F6 2.0 •• RESIDENTIAL MEDIUMSCHOOL,HOSPITAL 1. RMH p(} CHURCH(UNDERLYING DESIGNATION) f HIGH DENSITY F7 3.0 / RESIDENTIAL HIGH 2 F8 1.5(MU)-0.35(C)/25 DU/AC fry', RH ovErtiY DENSITY COMMERCIAL I -a AUTO'DISTRICT OVERLAY .- F11 2.0(MU)-2.0(C)/25 DU/AC CN COMMERCIAL -d DESIGN OVERLAY F12 3.0(MU)-3.0(C)/35 DU/AC• �'G NEIGHBORHOOD''` �j -h HISTORICAL,OVERLAY /I *ONLY INCLUDES DESIGNATIONS ♦ ),"N! . , ..I J !`,. RMH-25 i CG I COMMERCIAL >x RELEVANT TO PORTION OF THE MAP L�,/ \ + ,� GENERAL -Sp SPECIFIC PLAN OVERLAY SHOWN HERE. y ���� v `r� 010 CV J COMMERCIAL VISITOR -pd PEDESTRIAN OVERLAY l ;� - , � -F1 MIXED USE >,K4OsP °V. "\..' / ` -' / \ p MIXED USE VERTICAL y ; i��1 �r /~ ,\:(\C:111: MV \ • ` `r/I �/ ➢RMH-25-d`:i , `� N. �\ . .::::^ l'."-3 A AC1...H VENUE •-� ` y(,. L LIS y i �.. q _ l: ' \. ;- `' •' '' / RM-15 ` P Effi.R1 t: ILI : 1:.....1 i L .N.flVEN UE __.<{..-....I,.` • -, � ` •j%. ` , "\\<\,:s„..,. / ...../ ,,...;‘,... ,, 1 4.,„ 4 tm.7,-,_ ,4, .... ,, \\\< :,.....1: 1 _ U!4 N-F�1 ti1Ht 3 _1,.-"N r ,. 1 ...- •,... v-7: ' S1Mi...,,:- .43E AVENUE t ;. -: RH 30 4" , RH-30-sp - Ntr:•••• . P(RL-22i I_ 'j P ,_ W W :-:- a :�b:,_ F I: r0I. EAVENtlE Fl......, rrjr, w�. ..W: 0..= N F.\\\� •1 * �� �.i„' . -. , W s W �._ 7 W W It N "" y` .4f ' a is . ....., _ . . : :::::: CVF7 ,_ _. 11 E rT� 1 :: ......._..._-.,. W. S , ('T'�";•;�t ,. '�. . .! 1' ::::e --i=:',� ETA •jT ! �,s..,�-�- ,,,, -- • .,, ;: fn-Tl . :, . ail �rc,r.�= __ lid, r LI r'''': ll.t xL:t MV-F8-d PACIFIC COAST HIGHWAY ^- L ,A`_9!- ''.•��'-'�-� PACIFIC` :O:CEA'.N : . FIGURE 3.9- 1 Not toScaleEIP General Plan Land Use Map SOURCE:City of Huntington Beach 1996b. 10261-00 • ` ' City of Huntington Beach•Pacific City EIR LEGEND LEGEND LEGEND LEGEND PROJECT SITE BOUNDARY OPEN SPACE COMMERCIAL,INDUSTRIAL,MIXED USE 15 Max.16 Units/Net Acre RESIDENTIAL OS-P PARK DENSITY SCHEDULE 25 Max.26 Units/Net Acre RL RESIDENTIAL LOW OS-S SHORE DENSITY PERMITTED DENSITY DENSITY CODE (FLOOR AREA RATIO) 30 30 Units or Greater/Net Acre RESIDENTIAL MEDIUM PUBLIC F1 0.35 RM DENSITY P PUBLIC F6 2.0 r RMH RESIDENTIAL MEDIUM P SCHOOL,HOSPITAL CHURCH ryfmrRinNo oryoNpnom Y HIGH DENSITY ,� F7 3.0 // \\ <its< � RH RESIDENTIAL HIGH +� OVERLAY ✓ Ffi 1.5(MU)-0.35(C)125 DU/AC / \ - t DENSITY n C \ 1 -a AUTO DISTRICT OVERLAY / F11 2.0(MU)-2.0(C)/25 DU/AC ,,',°,,,- •3• - COMMERCIAL �' \...,rCOMMERCIAL -d DESIGN OVERLAYF12 3.0(MU)3.0(C)/35 DU/ACC# /� t\\\*: - J I CN NEIGHBORHOOD � ''r � COMMERCIAL 'h HISTORICAL OVERLAY • *ONLONLY INCLUDES O ORTIDESIGNATIONS MAP �*�;3\ , *�I ` RMH-25 CG GENERAL -Sp SPECIFIC PLAN OVERLAY '* 4 SHOWN HERE. i., + , 00 CV COMMERCIAL VISITOR -pd PEDESTRIAN OVERLAY � } ,,• ��- \•CG-F1 Ian • ��` 1�> N . t MIXED'USE > ��•�' \%OS-P /j6 %e :�_ r� #�' /,-- % ^� MV MIXED USE VERTICAL S v �,; 4 ray' s. RMH-25-d "�'�` riK \\,,;"' - :;>/:: • ...._ ..... ACACIA-ilAVENUE _ ` \ . V �:; % ... ',// '\ t, RMH 25-d 1 \ S4.j \ °f } r /=` \ N. • 9Y'.) ., , :60,,- .....,„ \ (9 4,,, RM-15 1 /... p•ECAN AVENUE • \ \ 994 V" `� /• " / I••-•fir'— cis. t' '� - - q \\\ SJ� #'�'O .,. f -, \*\., < II._31 ti7. {... w .le J• gym•\\ ,�? • ,.f . :,:;.:__.1 - — P(CN-F1) ;7 .., Li Li ORANGE AVENUE "' �"~~ V \ ram'_ 77 E— } ....i in r.2.4.::_i 1 JAL - ._ : r -• RH-30-sp ll - :=-: -.,, \ H ? MV-F T < ,i it-J F F - Ft'1- 'St t r `y4�•7C�.:..I L_....:1...._. w F W Orn rc i \. y .T ENU _ O w..-._ t[�.��'����'� �. N w , OLIVE A V �( - w y ---W.w.-,' r....-zz7j. 4-- _ O_. cm \ \' \ w w w t _ .91 wk. • `� _: CV-F7-sp. TWA N '~ _ ._-✓^ yam.. :atisJ«... bi Lind L � ''Tta I . t Itltl t!i . _ .. O$ $ --..— .........:117:7--.........: �I MV-F8-d-sp L°s�; ppCIFIC COAST HIGHWAY ry _you--'ed. '`•'^ PACIFIC OCEAN FIGURE 3.9-1 Not to Scale 40 E I P ..General Plan Land Use Map SOURCE:City of Huntington Beach 1996b. I0261-00 '' City of Huntington Beach•Pacific City EIR Chapter 2 Text,Changes 2.4 APPENDIX CHANGES Appendix H Traffic has been modified to include the information presented on the following pages. Pacific City EIR 2-181 PACIFIC CITY EIR TRAFFIC IMPACT ANALYSIS ADDENDUM Huntington Beach, California Prepared for: MAKAR PROPERTIES,LLC. 4100 MacArthur Boulevard, Suite 150 Newport Beach,California 92658 Prepared By: LINSCOTT,LAW & GREENSPAN,ENGINEERS 1580 Corporate Drive, Suite#122 Costa Mesa,California 92626 Phone#: (714)641-1587 FAX#: (714)641-0139 February 18, 2004 LLG Project No. 2-002133-1 Prepared by: Keil D.Mabeny,P.E. Associate Principal INTRODUCTION Linscott, Law, & Greenspan, Engineers (LLG) is pleased to submit the following addendum to the Pacific City Draft Environmental Impact Report (DEIR)Traffic Impact Analysis (TIA), dated April 21, 2003. As a result of comments provided on the DEIR, we have conducted additional analyses based on our evaluation of Pacific City's potential traffic impact in the City of Newport Beach. This memorandum details the additional traffic impact analyses consistent with the City of Newport Beach and California Department of Transportation (Caltrans) traffic impact criteria. For purposes of consistency with the DEIR TIA, the tables and exhibits contained in this addendum have an "A" (except Exhibit 7)placed after the matching table and exhibit number from the DEIR TIA. This Traffic Impact Study Addendum addresses the potential traffic impacts on the City of Newport Beach associated with the proposed Pacific City mixed-use project located in the City of Huntington Beach. The project site is bound by Pacific Coast Highway on the south, 1st Street on the west, Atlanta Avenue on the north, and Huntington Street on the east, with the proposed extension of Pacific View Avenue bisecting the site, from Huntington Street to 1st Street. The project includes the development/construction of approximately 240,000 SF of office/retail/restaurant use, a 400- room resort hotel,and 516 residential condominiums. The thirty-two key area study intersections contained in the DEIR TIA were selected for evaluation based on a "select-zone" analysis of the Santa Ana River Crossings Cooperative Study (SARCCS) traffic model, which was used to develop the Maximum Possible ICU Impact table (Table 1 in the DEIR TIA). Table 1A presents the study area boundary evaluation of project traffic directed toward the City of Newport Beach. Intersections with a maximum possible ICU increase of greater than 1% were analyzed and intersections with a maximum possible ICU increase of less than 1% were not analyzed. As presented in Table 1A, the intersection of Superior Avenue/Balboa Boulevard and Pacific Coast Highway (PCH) has a maximum possible ICU impact of 2.0% and therefore is included in the Pacific City traffic impact analysis study area and has been analyzed in this addendum. TABLE 1A STUDY AREA BOUNDARY Pacific City Addendum,Huntington Beach Maximum Possible Possibly Intersection ICU Impact Impacted? Pacific Coast Highway at 2.0% YES Superior Ave/Balboa Blvd Pacific Coast Highway at 0.8% NO Hoag Dr/Balboa Cove Pacific City Addendum Huntington Beach, California Page 1 EXISTING TRAFFIC CONDITIONS Exhibit 3A presents the existing roadway conditions for the key study intersection of Superior Avenue/Balboa Boulevard and Pacific Coast Highway. This exhibit identifies the number of travel lanes,intersection configurations and traffic control/signal phases. EXISTING AREA TRAFFIC VOLUMES Existing (Year 2003) AM and PM peak hour intersection traffic volumes for the intersection of Superior/Balboa and PCH were obtained from the City of Newport Beach. Exhibits 4A and 5A summarize the existing AM peak hour and PM peak hour turning movement volumes for the study intersection of Superior/Balboa and PCH,respectively. Appendix AA contains the City of Newport Beach 2003 detailed weekday ICU calculation sheet, which presents the peak hour traffic count data for the intersection of Superior/Balboa and PCH. EXISTING INTERSECTION CONDITIONS Existing Intersection Level of Service Results Table 7A summarizes the existing service level calculations for the intersection of Superior/Balboa and PCH based on existing traffic volumes and current street geometry. As shown, the intersection of Superior/Balboa and PCH intersections currently operates at LOS B during both the AM and PM peak hours.Appendix DD presents the Existing ICU/LOS calculation sheets. TABLE 7A EXISTING PEAK HOUR LEVELS OF SERVICE Pacific City Addendum,Huntington Beach TIME CONTROL: 'KEY INTERSECTION PERIOD TYPE ICU/HCM LOS 33. Pacific Coast Highway at AM 60 Traffic 0.678 B Superior Ave/Balboa Blvd PM Signal 0.603 B PROJECT TRAFFIC CHARACTERISTICS Traffic generation is expressed in vehicle trip ends, defined as one-way vehicular movements, either entering or exiting the generating land use. Generation factors and equations used in the traffic forecasting procedure are found in the Sixth Edition of Trip Generation, published by the Institute of Transportation Engineers (1'1'E) [Washington D.C., 1997]. . Pacific City Addendum - Huntington Beach, California Page 2 - - - , 1 1 1 1, N\ TO SR-55 g FWY 5 Q en Q TO JR- PROJECT ,��' 2 SITE •; y e HUNTINGTON BEACH NEWPORT BEACH P . , la. 4 O" 1 I I 0 02 2 cr - n O PACIFIC OCEAN / •• HoA i - / ih- i \ --°' 1-tt i \ - ) 6 PHASE "' - SIGNAL o N G 0 N J 41 1111"I'''` EXHIBIT 3A ©NO SCALE LINSCOTT EXISTING ROADWAY CONDITIONS LAW & AND INTERSECTION CONTROLS GREENSPAN ENGINEERS PACIFIC CITY, HUNTINGTON BEACH r TO re SR-55 FWY 3: 0, e z e TO JQ� e PROJECT Ai' z SITE ; t" 6 HUNTINGTON BEACH NEWPORT BEACH $ 0 2- J42- Q4- o c fp f 0 PACIFIC OCEAN / . HOA a 9 / I. 4 N / �Nm �193� ,--78 1 i t 993—i i \ 1979—\298Th ��r � _ a N O O N 4111iN EXHIBIT 4A ©NO SCALE LINSCOTT LAW & GREENSPAN ' EXISTING AM PEAK HOUR TRAFFIC VOLUMES ` ENGINEERS PACIFIC CITY, HUNTINGTON BEACH . TO SR-55 + FWY ik- z c2 ‘a- TO J� -r PROJECT -2' z SITE .; h e' HUNTINGTON BEACH NEWPORT BEACH N. 3 4 O amR IOg. S � Q c h ? �� a PACIFIC OCEAN / H=•� 9 r a'`"_' L-120\ �� �1628 a r-182 I \ N a 984 1 } r 277-1 W o/� rn N / N 0 0 N J (,--- ll111I''' EXHIBIT 5A , ©NO SCALE LINSCOTT LAW & GREENSPAN EXISTING PM PEAK HOUR TRAFFIC VOLUMES RE ENGINEERS PACIFIC CITY, HUNTINGTON BEACH _ - _ J , 1 Pacific City Project Traffic Generation As presented in Table 10 of the DEIR TIA, the proposed Pacific City project has a trip generation potential of 12,002 daily trips, of which 628 trips (345 inbound, 283 outbound) are produced in the AM peak hour and 1,051 trips (505 inbound, 546 outbound) are generated in the PM peak hour. Project Traffic Distribution and Assignment Exhibit 7AA identifies the anticipated traffic distribution and assignment pattern consistent with the DEIR TIA, at the intersection of Superior/Balboa and PCH, for the Retail/Restaurant/Office portion - of the Pacific City project. A majority percentage (7%) of the Retail/Restaurant/Office project-related traffic attracted to this intersection is expected to travel through the intersection on Pacific Coast Highway, and 4% is expected to travel on Superior Avenue and Balboa Boulevard each to account for traffic directed toward the SR-55, SR-73 and I-405 freeways and residential attraction in Newport Beach,respectively. Exhibit 7BB identifies the anticipated traffic distribution and assignment pattern consistent with the DEIR TIA, at the intersection of Superior/Balboa and PCH,for the Residential portion of the Pacific City project. A majority percentage (15%) of the Residential project-related traffic attracted to this intersection is expected to travel through the intersection on Pacific Coast Highway, and 8% is expected to travel on Superior Avenue to account for traffic directed toward the SR-55, SR-73 and I-405 freeways while only 2% is directed toward the residential and beach area of Newport Beach via Balboa Boulevard. Exhibit 7CC identifies the anticipated traffic distribution and assignment pattern consistent with the DEIR TIA, at the intersection of Superior/Balboa and PCH, for the Hotel portion of the Pacific City project. A majority percentage(18%)of the Hotel project-related traffic attracted to this intersection is expected to travel through the intersection on Pacific Coast Highway, with 7% expected to travel on Superior Avenue to account for traffic directed toward the SR-55, SR-73 and I-405 freeways and 5%percent on Balboa Boulevard directed toward the beach attractions in Newport Beach. The anticipated weekday AM and PM peak hour project traffic volumes at the intersection of Superior/Balboa and PCH associated with Pacific City are presented in Exhibits 8A and 9A, respectively. The peak hour traffic volumes generated by the proposed project reflect the traffic distribution characteristics shown in Exhibits 7AA, 7BB, and 7CC and the peak hour traffic generation forecast presented in Table 10 of the DEIR TIA. Exhibit 10A presents the added daily project traffic assignments on PCH roadway links north and south of Superior/Balboa and PCH. Pacific City Addendum Huntington Beach,California Page 6 r TO SR-55 FWY A. el Q • i• 2 Q TO � Q PROJECT - ' 2 - SITE :- o • Al 6 HUNTINGTON . BEACH • NEWPORT BEACH NIL i. � 4- , I 9 �� yQ a N /9 ft PACIFIC OCEAN HOq /l / ��/ 9 / '.41r I / o ''y o Fi / K \ y iri e g 1 ` 4%� Naa ° M� � / F,\� / 0 j 0 0 N 411111N EXHIBIT 7AA ©NO SCALE LINSCOTT PROJECT TRIP DISTRIBUTION PATTERN LAW &GREENSPAN RETAIL/RESTAURANT/OFFICE ENGINEERS PACIFIC CITY, HUNTINGTON BEACH TO SR-55 FWY ti Q i. Z / ' TO ck J� Q PROJECT 'Is' z SITE ; h 1 - HUNTINGTON BEACH • NEWPORT BEACH iv o 4 \4\ a o� S (t0� N cJ m o PACIFIC OCEAN ` HOA �1 / �1r/ 9 / -.go li / 9 J 7AA / � -f 5 \ � I : a--157 I 8%J \ N `\12%� N / r"3 / N N O 0 N C 411►i���°- EXHIBIT 7BB vN0 SCALE LINSCOTT PROJECT TRIP DISTRIBUTION PATTERN LAW &GREENSPA RESIDENTIAL ENGINEERS N PACIFIC CITY, HUNTINGTON BEACH J TO SR-55 it .W FWY ,` 4 Q / & z (1 Q TO J� ti v�PROJECT , ' z SITE . • Q I ,! vi •A HUNTINGTON BEACH 4 ,k).. NEWPORT BEACH P n o,k 0 . .>, . Csl Q(V a s °J C I /^ S PACIFIC OCEAN HOA /. / �a 9 �� I 6. L 0 9 a 6 o I a--18% ' i ` 7%� \ 4 18%---► s 0 0 O N C / AlIllIIlli,. ©NO SCALE EXHIBIT 7CC LINSCOTT PROJECT TRIP DISTRIBUTION PATTERN LAW & HOTEL GREENSPAN ENGINEERS PACIFIC CITY, HUNTINGTON BEACH 1 TO SR-55 FWY 42 Q h Z Q TO Q- a PROJECT :�'2' �2 SITE :" N e HUNTNGTON BEACH NEWPORT BEACH ' h 0 ,0 8 6- 1 -J N N in 0 PACIFIC OCEAN / . H �l 9 - 0 1....:=1 .s-i , —39 , i 18-1 3 \ 39-- 1 / \ 10� / o 0 0 0 N i n 1111IIh, EXHIBIT SA vNO SCALE LINSCOTT LAW & AM PEAK HOUR PROJECT TRAFFIC VOLUMES N PACIFIC CITY, HUNTINGTON BEACH ENGINEERS f., • -- -- 1 TO ki SR-55 FWY 62 Q z Q TO co Q PROJECT Ai' 2 SITE :- y / e HUNTINGTON• BEACH NEWPORT BEACH P • h 4 . ?,, o I 2 co N 0 PACIFIC OCEAN Noq �1 / �1i/ 9 // . I /7 <9 co. / i J --53 zsJ \ 7 \\ 22� al / / / N O 0 N • / 41IIIIN EXHIBIT 9A vN0 SCALE LINSCOTT LAW & GREENSPAN - PM PEAK HOUR PROJECT TRAFFIC VOLUMES RE ENGINEERS PACIFIC CITY, HUNTINGTON BEACH i TO SR-55 g FWY 1 h Q Q _ TO J� : • PROJECT 'IS 2 SITE :' rn • e' HUNTINGTON BEACH NEWPORT BEACH P .>, • 1 4 a A O I ¢s9 I iv 2 a Q PACIFIC OCEAN �5�, 110issA 9 I a ". N 9 r4 o N \ a I • ON O N Ci 1 (r- Aii4i11 EXHIBIT 10A ©NO SCALE LIN SCOTT LAW & DAILY PROJECT TRAFFIC VOLUMES GREENSPAN PACIFIC CITY, HUNTINGTON BEACH ENGINEERS 2008 TRAFFIC CONDITIONS 2008 Background Traffic Conditions Ambient Traffic Horizon year background traffic growth estimates have been calculated using ambient growth factors. The ambient traffic growth factor is intended to include unknown and future related projects in the study area, as well as account for regular growth in traffic volumes due to development of projects outside the study area. Consistent with the DEIR TIA, future growth in the AM and PM peak hour traffic volumes at the intersection of Superior/Balboa and PCH has been calculated at one percent (1.0%) per year. Applying this growth factor to existing 2003 traffic volumes results in a five percent(5%) growth in existing volumes to horizon year 2008. Related Projects Traffic Characteristics Based on information provided by City of Newport Beach Planning staff,there are twelve approved projects as well as eight uncommitted potential projects, which may generate traffic in the project study area by the Year 2008. AM and PM peak hour traffic from these 20 projects in addition to the four projects used in the DEIR TIA have been distributed at the intersection of Superior/Balboa and PCH. Appendix L contains the City of Newport Beach related project traffic information provided by the City of Newport Beach. The related project information that is included for the analysis of the Superior/Balboa and PCH intersection is not included in other intersections analyzed in the traffic study. The traffic impact _ analysis prepared in April 2003 included ambient growth,in addition to specific cumulative projects identified in that report. At the remaining 31 intersections, for the critical movements that are analyzed, the traffic volumes resulting from ambient growth are greater than the traffic volumes from related projects in the City of Newport Beach. Thus, inclusion of the additional traffic from City of Newport Beach related projects is not warranted. Exhibits 11A and 12A present the AM and PM peak hour background traffic volumes (existing traffic plus ambient growth traffic plus related project traffic) at the intersection of Superior/Balboa and PCH for project buildout Year 2008,respectively. 2008 Background Plus Pacific City Project Traffic Exhibits 14A and 15A illustrate Year 2008 forecast AM and PM peak hour traffic volumes with the inclusion of the trips generated by Pacific City project at the intersection of Superior/Balboa and PCH. Pacific City Addendum Huntington Beach,California Page 13 --N TO SR-55 k FWY o; C Q ,A 2 Q TO J2h .:- PROJECT 2 Z SITE / HUNTINGTON BEACH NEWPORT BEACH • P o 1 0 k. Psi �JQ = o N Q I,0 PACIFIC OCEAN / H /� (- 9 / 1 i EiN —283\ '. g 946 \ , J � Z. r-83 I 0 I N 1061-I ,2276 r 329Th P J N / N O O N J 1 ©,ilIIlIlIN. EXHIBIT 11A NO SCALE LINSCOTT LAW & • GREENSPAN 2008 AM PEAK HOUR BACKGROUND TRAFFIC VOLUMES ENGINEERS PACIFIC CITY, HUNTINGTON BEACH`� J i i • • TO it SR-55 ki FWY c2 Q & 2 TO J�� sr PROJECT _Li• 2 SITE :- y• e HUNTINGTON BEACH • NEWPORT BEACH P �� b 4q. ti :g q. 7 I ` c n_ of 0 PACIFIC OCEAN / • HOA meat,.i S / r t7/\ , �� -184 , 9Fi jILr-191 1954 b 343-1 \ 7 \ 1295-- 1, r 306Th`� / \ N / N O O N I 'llII►ill''', EXHIBIT 12A ©NO SCALE LINSCOTT LAW &GREENSPAN 2008 PM PEAK HOUR BACKGROUND TRAFFIC VOLUMES ENGINEERS PACIFIC CITY, HUNTINGTON BEACH • TO k SR-55 FWY h e . A 2 e TO - e PROJECT Z' 2 SITE :•- y i e HUNTINGTON BEACH NEWPORT BEACH P .;, 13 4 0 o� Pi JQ��• � cr 2 0 02- o w PACIFlC OCEAN HOq 1 Z esesso at ‘h. / $ i / ry cNi, 283\ '` i J --985 \ 0 b r--83 \ I O N 0 O N C 411iN EXHIBIT 14A ©NO SCALE LINSCOTT LAW & GREENSPAN 2008 AM PEAK HOUR VOLUMES WITH PROJECT TRAFFIC ENGINEERS PACIFIC CITY, HUNTINGTON BEACH J 1 r TO 0: SR-55` FWY co Q & 2 h srTO Q' PROJECT �J Z SITE :•- to 1 6 HUNTINGTON BEACH NEWPORT BEACH P t . 1 a x. /Z /gam � . N JQ� 2 0 h W N alPACIFlC OCEAN / H l 9 ',4tr a al a o ;rn �184� 9 3+ r191 2007 I a N I 389� '. \ s 1345— , a N. / N a N C '''llIIII ''` EXHIBIT 15A ©NO SCALE LINSCOTT LAW ScGREENSPAN 2008 PM PEAK HOUR VOLUMES WITH PROJECT TRAFFIC RE ENGINEERS PACIFIC CITY, HUNTINGTON BEACH II TRAFFIC IMPACT ANALYSIS METHODOLOGY Impact Criteria and Thresholds (City of Newport Beach) The relative impact of added project traffic volumes generated by the Pacific City Project during the AM and PM peak hours and daily basis were evaluated based on the analysis of existing and future operating conditions at the intersection of Superior/Balboa and PCH, without, then with, the proposed Pacific City project. The previously discussed capacity analysis procedures were utilized to investigate the future volume-capacity relationships and service level calculations at the study intersection. "Significant Traffic Impact"for City intersections: A "Significant" traffic impact for intersections is defined as a project-related V/C ratio value greater than or equal to LOS E (0.905), which requires mitigation by reducing the V/C ratio to LOS D (0.904) or baseline, if the baseline is LOS E or F (greater than or equal to 0.905). Baseline is defined as the pre-project condition (Year 2008 Background). Impact Criteria and Thresholds (State of California) The relative impact of added project traffic volumes generated by the Pacific City Project during the AM and PM peak hours basis were evaluated based on the analysis of existing and future operating conditions at the intersection of Superior/Balboa and PCH, without, then with, the proposed Pacific City project. The LOS standards and impact criteria specified by the State of California Department of Transportation (Caltrans) for State-controlled intersections have been applied to the twenty Caltrans intersections within the study area. The following definition describes the Caltrans impact criteria used in this study. "Significant Traffic Impact" for State intersections: A "Significant" traffic impact for Caltrans intersections is defined as a project-related V/C ratio value greater than or equal to LOS E (55.1 sec/veh), which requires mitigation by reducing the intersection delay to LOS D (55.0 sec/veh)or baseline,if the baseline is LOS E or F(greater than or equal to 55.1 sec/veh). Baseline is defined as the pre-project condition (Year 2008 Background). Pacific City Addendum Huntington Beach, California Page 18 Traffic Impact Analysis Scenarios Per City Staff,the following scenarios are those for which LOS calculations have been performed: Year 2008 Horizon 1) 2008:Future Background(Existing plus Ambient traffic plus Related Project traffic) 2) 2008:Future Background with Pacific City Project Traffic 3) Project Impact(ICU/HCM increase)/Significance 4) Scenario(2)with Improvement Measures,if necessary Year 2020 Buildout 1) 2020: Future General Plan Buildout Conditions Without Pacific City Project Traffic 2) 2020: Future General Plan Buildout Conditions With Pacific City Project Traffic 3) Scenario(2)with Improvement Measures,if necessary II YEAR 2008 PEAK HOUR INTERSECTION CAPACITY ANALYSIS Table 12A summarizes the peak hour ICU/HCM Level of Service results at the intersection of Superior/Balboa and PCH. The first column of values in Table 12A presents a summary of Year 2008 background traffic conditions based on existing intersection geometry,but without any Pacific City project traffic. The second column presents future forecast traffic conditions with the addition of Pacific City project traffic. The third column shows the increase in ICU value due to the added peak hour project trips and indicates whether the traffic associated with the Pacific City project will have a significant impact based on the significance criteria identified earlier. 2008 Future Background Traffic Conditions An analysis of future (Year 2008) traffic conditions indicates that the forecast increase in background traffic will not cause the intersection of Superior/Balboa and PCH to operate at adverse service levels. The intersection of Superior/Balboa and PCH, which currently operates at LOS B during the AM and PM peak hours, is expected to operate at LOS C, during both the AM and PM peak hours,with the addition of ambient traffic and related project traffic. 2008 Near-Term Conditions with Pacific City Project Traffic Review of Columns 2 and 3 of Table 12A shows that, in the near-term horizon Year 2008, the intersection of Superior/Balboa and PCH is expected to continue to operate at acceptable service levels and will not be impacted as a result of Pacific City project traffic combined with background traffic (ambient plus related projects). The intersection of Superior/Balboa and PCH, is expected to continue to operate at LOS C, during both the AM and PM peak hours, with the addition of Pacific City project traffic to background traffic. Appendix DD presents the Year 2008 ICU/LOS calcula- tions at the intersection of Superior/Balboa and PCH for the AM and PM peak hours. Pacific City Addendum Huntington Beach, California Page 19 TABLE 12A YEAR 2008 PEAK HOUR INTERSECTION LEVELS OF SERVICE SUMMARY Pacific City Addendum,Huntington Beach (1) '(2) Year 2008 Year 2008 Background Background Project"Impact/. Time Conditions Plus Project . Significance Key Intersections '.Period ICU ' LOS. ICU ' LOS. ICU Inc.. -Y/N 33. Pacific Coast Highway at ' AM 0.768 C 0.779 C 0.011 N Superior Ave/Balboa Blvd PM 0.708 C 0.728 C 0.020 N State of California(Caltrans)Methodology Table 13A summarizes the peak hour HCM (HCS-2000 for signalized intersections) Level of Service results at the intersection of Superior/Balboa and PCH. The first column of HCM/LOS - values in Table 13A presents a summary of Year 2003 existing traffic conditions. The second column presents Year 2008 background traffic conditions based on existing intersection geometry, but without any Pacific City project traffic. The third column presents future forecast traffic conditions with the addition of Pacific City project traffic. The fourth column indicates whether the _ intersection will operate at adverse service levels, which is LOS E or worse (55.1 seconds/vehicle and greater),with the addition of Pacific City project traffic. 2008 Future Background Traffic Conditions An analysis of future (Year 2008) traffic conditions indicates that the forecast increase in background traffic will not cause the intersection of Superior/Balboa and PCH to operate at adverse service levels. The intersection of Superior/Balboa and PCH is expected to operate at LOS D, during both the AM and PM peak hours, with the addition of ambient traffic and related project traffic. 2008 Near-Term Conditions with Pacific City Project Traffic Review of Columns 2 and 3 of Table 13A shows that, in the near-term horizon Year 2008, the intersection of Superior/Balboa and PCH is expected to continue to operate at acceptable service levels and will not be impacted as a result of Pacific City project traffic combined with background traffic (ambient plus related projects). The intersection of Superior/Balboa and PCH, is expected to continue to operate at LOS D, during both the AM and PM peak hours, with the addition of Pacific City project traffic to background traffic. Pacific City Addendum Huntington Beach, California Page 20 Appendix EE presents the Year 2008 HCM/LOS calculations at the intersection of Superior/Balboa and PCH for the AM and PM peak hours. TABLE 13A YEAR 2008 PEAK HOUR INTERSECTION LEVELS OF SERVICE SUMMARY CALTRANS (HCM) Pacific City Addendum,Huntington Beach (1) , (2)- ' (3) (4) Year 2003 Year 2008 - 'Year 2008 Project. Existing Background Background Impact/ Time Conditions, Conditions Plus Project Significance Key Intersections Period HCM .LOS . IICM . LOS . : HCM LOS Yes/No 33. Pacific Coast Highway at AM 38.3 D 44.6 D 46.2 D No Superior Ave/Balboa Blvd PM 42.2 D 49.0 D 52.0 D No YEAR 2008 ROADWAY LINK CAPACITY ANALYSIS Based on the City's impact criteria for roadway links, which states "A significant traffic impact for roadway links is defined as a project-related V/C ratio value greater than or equal to LOS D (0.805), a project-related increase of 0.030, and an adverse intersection service level (LOS E or F) at either of the two adjacent intersections", the roadway link on PCH between Brookhurst Avenue and Superior Avenue/Balboa Boulevard will not be significantly impacted by Pacific City project traffic because neither adjacent intersection (Brookhurst/PCH & Superior-Balboa/PCH) operates at adverse levels of service with the addition of project traffic in Year 2008. Pacific City Addendum Huntington Beach, California Page 21 YEAR 2020 GENERAL PLAN BUILDOUT TRAFFIC CONDITIONS Year 2020 General Plan Buildout traffic volumes, which includes the buildout of both Huntington Beach and Newport Beach as well as Costa Mesa and Fountain Valley, have been developed using the City of Huntington Beach Santa Ana River Crossings Cooperative Study (SARCCS) traffic analysis model as executed by Urban Crossroads consistent with the DIER TIA. In order to determine the Year 2020 General Plan Buildout traffic volumes at the intersection of Superior/Balboa and PCH, we conducted Year 2020 General Plan Buildout SARCCS model runs without and with Pacific City project traffic for the current General Plan Circulation Element network (With Hamilton Avenue Extension With Walnut Avenue Alignment and With the Santa Ana River Crossings)and Orange County's Master Plan of Arterial Highways (MPAH)network. Year 2020 General Plan Buildout Traffic Conditions Without Pacific City Project Traffic Exhibits 19A and 20A present Year 2020 Buildout AM and PM peak hour traffic volumes, respectively, at the intersection of Superior/Balboa and PCH without the proposed Pacific City Project for the Current General Plan Circulation Element and MPAH roadway network. Appendix HH presents the Year 2020 General Plan Buildout traffic model data without and with project traffic for the current General Plan Circulation Element network (With Hamilton Avenue Extension With Walnut Avenue Alignment and With the Santa Ana River Crossings) and Orange County's Master Plan of Arterial Highways (MPAH)network. Year 2020 General Plan Buildout Traffic Conditions With Pacific City Project Traffic Exhibits 22A and 23A present Year 2020 Buildout AM and PM peak hour traffic volumes, respectively, at the intersection of Superior/Balboa and PCH with the proposed Pacific City Project for the current General Plan Circulation Element and MPAH roadway network. Pacific City Addendum Huntington Beach,California Page 22 --' TO SR-55 g FWY ti ee (1 Q Q TO JQ- Q PROJECT �•2' z SITE .; y .. Al e. HUNTINGTON BEACH NEWPORT BEACH - -; o 4 2 0 h r Jq N h o � PACIFIC OCEAN / , "Ho '1 9 4 / fgEIN J i —60 r-1E0\\I 0 i i 1041J 1 } r \ 0. \\316Th-`NS / 4 N 1 0 O O N C I 4111lll''' EXHIBIT 19A ©NO SCALE LINSCOTT 2020 GENERAL PLAN BUILDOUT AM PEAK HOUR VOLUMES LAW &GREENSPAN WITHOUT PROJECT TRAFFIC ENGINEERS PACIFIC CITY, HUNTINGTON BEACH • TO k SR-55 FWY EZ Z ' 0 Q TO e- c • PROJECT 8 2 SITE •:' / - e HUNTINGTON BEACH NEWPORT BEACH P o 0 i. At- �JQ 2 0 • I � PACIFIC OCEAN HOA / Ira1 9 // - \ c cri� � T�122\ , v r 2592 ` 1 0 244J , r \ . \ 1041-- c., / 304-1`w / pi I 411iNEXHIBIT 20A ©NO SCALE LINSCOTT LAW & 2020 GENERAL PLAN BUILDOUT PM PEAK HOUR VOLUMES GREENSPAN WITHOUT PROJECT TRAFFIC ENGINEERS PACIFIC CITY, HUNTINGTON BEACH • TO SR-55 g FWY & a Z 62 Q TO J� ti PROJECT •2' SITE J�� h e HUNTINGTON BEACH NEWPORT BEACH P o 0 et JQ�� , , co 2 in O } PACIFIC OCEAN / 2.1.61 9 -.r / i / 0 a / NwN �214\, K. -,8V I 63p9 0 J i N 1059J � I 2407-- NN \326T ��8 / i N. / N O O N / \ 411i'I'''. EXHIBIT 22A vN0 SCALE LINSCOTT 2020 GENERAL PLAN BUILDOUT AM PEAK HOUR VOLUMES LAW &GREENSPAN WITH PROJECT TRAFFIC ENGINEERS PACIFIC CITY, HUNTINGTON BEACH `` —J TO SR-55 FWY it 63 Q 2 TO j� Q h. PROJECT 'Z 2 SITE :_ Al e HUNTINGTON BEACH NEWPORT BEACH �� 4 o� Q4zi =� N 4' H N a ` PACIFIC OCEAN NOA, __ l / I ±....\ / 5` § TL1755 J + ` c259 1 7 1 270- 1 a \ 1091-- sir / 326-1\••Ic.n N O o N ,,,II11►IIII,,. EXHIBIT 23A ©NO SCALE LINSCOTT 2020 GENERAL PLAN BUILDOUT PM PEAK HOUR VOLUMES LAW & WITH PROJECT TRAFFIC GREENSPAN PACIFIC CITY, HUNTINGTON BEACH ENGINEERS I YEAR 2020 GENERAL PLAN BUILDOUT TRAFFIC IMPACT ANALYSIS Impact Criteria and Thresholds The relative impact of the added project traffic volumes generated by Pacific City General Plan Buildout Analysis on the current General Plan Buildout Circulation Element and MPAH network, during the AM peak hour and PM peak hour was evaluated based on analysis of future operating conditions at the intersection of Superior/Balboa and PCH, without, then with the proposed Pacific City project. The previously discussed capacity analysis procedures were utilized to investigate the future volume-to-capacity relationships and service level characteristics at each study intersection. The significance of the potential impacts of the project at each key study intersection was then evaluated using the City of Newport Beach traffic impact criteria described previously. 2020 General Plan Buildout Peak Hour Intersection Capacity Analysis - With Hamilton Avenue Extension With Walnut Avenue Alignment and With the Santa Ana River Crossings (Current General Plan Circulation Element and MPAH Roadway Network) Table 15A summarizes the peak hour Level of Service results at the intersection of Superior/Balboa and PCH for the Year 2020 General Plan Buildout condition for the current General Plan Circulation Element and MPAH roadway network. The first column (1) of ICU/LOS values in Table 15A presents a summary of Year 2020 peak hour traffic conditions without project traffic. The second column (2) lists Year 2020 conditions with project traffic based on existing intersection geometry. The third column (3) indicates whether the traffic associated with Pacific City Project will have a significant impact based on the City of Newport Beach traffic impact criteria, which is the same as Huntington Beach's traffic impact criteria. TABLE 15A YEAR 2020 GENERAL PLAN BUILDOUT PEAK HOUR INTERSECTION LEVELS OF SERVICE SUMMARY W/HANIILTON EXT.W/WALNUT ALIGNMENT W/SARC Pacific City Addendum,Huntington Beach (1) .(2).., (3) , Year 2020 ' ' Year 2020 . Without With Project Impact/ Time Project;Trafic Project Traffic Significance Key.Intersections " . .Period— ICU" LOS ICU , ...:LOS ICU Inc. Y/N 33. Pacific Coast Highway at AM 0.794 C 0.806 D 0.012 NO Superior Ave/Balboa Blvd PM 0.633 B 0.652 B 0.019 NO Pacific City Addendum Huntington Beach,California Page 27 Year 2020 General Plan Buildout Without Pacific City Project Traffic Condition An analysis of future (Year 2020) General Plan Buildout Without Pacific City Project traffic conditions indicates the intersection of Superior/Balboa and PCH will operate at acceptable LOS C and LOS B during the AM and PM peak hours, respectively, based on the SARCCS traffic model data and existing lane geometry. Year 2020 General Plan Buildout With Pacific City Project Traffic Condition Review of Columns 2 and 3 indicates that the intersection of Superior/Balboa and PCH will operate at acceptable LOS D and LOS B during the AM and PM peak hours,respectively, with the addition of Pacific City Project traffic in the future Year 2020 General Plan Buildout condition. Appendix II contains the Year 2020 General Plan Buildout Intersection Capacity Utilization (ICU) calculation worksheets for the intersection of Superior/Balboa and PCH. CONGESTION MANAGEMENT PROGRAM(CMP)ANALYSIS This section presents the Congestion Management Program (CMP) traffic analysis. The analysis is consistent with the requirements and procedures outlined in the current Orange County Congestion Management Program (CMP). The CMP requires that a traffic impact analysis be conducted for any project generating 2,400 or more daily trips, or 1,600 or more daily trips for projects that directly access the CMP Highway System (HS). Per the CMP guidelines, this number is based on the desire to analyze any impacts that will be 3% or more of the existing CMP highway system facilities' capacity. As noted in the Pacific City traffic study, the proposed project is projected to generate approximately 12,002 daily trip-ends,and thus meets the criteria requiring a CMP TIA. The CMP highway system arterial facilities and CMP arterials closest to the project site consists of the Beach Boulevard, Pacific Coast Highway (PCH), and Warner Avenue. The CMP arterial monitoring locations/intersections nearest to the Pacific City site include Warner Avenue at PCH, Beach Boulevard at PCH,and Beach Boulevard at Adams Avenue. Based on project trip generation estimates and trip distribution pattern presented earlier, the amount •of project traffic using these CMP facilities indicates that, for all three CMP intersections listed • above, a roadway link adjacent to the intersection exceeds the 3% threshold (1,689 daily trips) established by the CMP and all three CMP intersections have been analyzed in this report. In .addition, the roadway link on PCH north of the intersection of Superior Avenue/Balboa Boulevard and Pacific Coast Highway exceeds the 3% threshold and the roadway link south of the intersection of Superior Avenue/Balboa Boulevard and PCH falls below the 3% threshold. Therefore, the intersection of Superior/Balboa and PCH has been analyzed according to the CMP criteria. As a result, based on the traffic impact analyses conducted within the DEW TIA and this addendum using the Orange County CMP criteria,it is concluded that the Pacific City project will not have any significant traffic impact on the Congestion Management Program Highway System. This is consistent with the DEER TIA. Pacific City Addendum Huntington Beach,California Page 28 CONCLUSIONS • The operating conditions at the intersection of Superior Avenue/Balboa Boulevard and Pacific Coast Highway were evaluated using the City of Newport Beach (ICU) methodology and California Department of Transportation (Caltrans) methodology (HCM) for signalized intersections. The analysis investigated the relative traffic impacts of the proposed Pacific City project on a near-term(Year 2008)and General Plan Buildout(Year 2020)basis. • As presented in Table 12A, in the near-term horizon Year 2008 and according to City of Newport Beach methodology, the intersection of Superior/Balboa and PCH is expected to operate at acceptable service levels and will not be impacted as a result of Pacific City project traffic combined with background traffic (ambient plus related projects) based on City of Newport Beach traffic impact criteria.The intersection of Superior/Balboa and PCH,is expected to continue to operate at LOS C, during both the AM and PM peak hours, with the addition of Pacific City project traffic to background traffic • As presented in Table 13A, in the near-term horizon Year 2008 and according to Caltrans methodology, the intersection of Superior/Balboa and PCH is expected to continue to operate at acceptable service levels and will not be impacted as a result of Pacific City project traffic combined with background traffic (ambient plus related projects) based on Caltrans traffic impact criteria.The intersection of Superior/Balboa and PCH,is expected to continue to operate at LOS D, during both the AM and PM peak hours, with the addition of Pacific City project traffic to background traffic. • As presented in Table 15A, the intersection of Superior/Balboa and PCH will operate at acceptable LOS D and LOS B during the AM and PM peak hours, respectively, with the addition of Pacific City Project traffic in the future Year 2020 Newport Beach and Huntington Beach General Plan Buildout condition based on SARCCS traffic model data and existing lane geometry. • The conclusions of this analysis are consistent with the conclusions of the Draft EIR/Draft TEA. The analysis concludes that no new significant impact would result, and no increase in the severity of an impact will occur. • Based on our evaluation of the Orange County Congestion Management Program (CMP) requirements, it is concluded that the Pacific City project will not have any significant traffic impact on the Congestion Management Program Highway System. Attachments N:12100\2002133keport\Pacific City TIA AddendumDOC Pacific City Addendum Huntington Beach,California Page 29 Chapter 3 RESPONSES TO COMMENTS 3.1 ORGANIZATION OF THE RESPONSES TO COMMENTS In total, 18 comment letters regarding the Draft EIR were received from three State departments, five regional and/or local agencies, three organizations, five private entities, and two individuals. In addition, verbal comments and associated speaker cards were received at the Pacific City Draft EIR Public Information Meeting that was held on November 13, 2003. Table 3-1 provides a comprehensive list of commenters in the order that they are presented in this section. Table 3-1 Comment Letters Received During the Draft EIR Comment Period No. Commentor/Organization Page State Departments 1. Department of Conservation,State of California,December 1,2003 3-3 2. California Department of Transportation,December 3,2003 3-5 3. Department of Toxic Substances Control,November 4,2003 3-10 Regional/Local Agencies 4. Steven Bromberg,Mayor of the City of Newport Beach,December 3,2003 3-13 5. Huntington Beach Union High School District,October 27,2003 3-16 6. County of Orange Planning&Development Services Department,December 3,2003 3-17 7. Orange County Transportation Authority,December 3,2003 3-21 8. Southem California Association of Governments,November 25,2003 3-23 Organizations 9. City of Huntington Beach Environmental Board,November 24,2003 3-25 10. Huntington Beach Tomorrow,December 3,2003 3-28 11. Orange County Coastkeeper,December 1,2003 3-30 Private Entities 12. Lewis Brisbois Bisgaard&Smith LLP,December 3,2003 3-35 13. Orosz Engineering Group,Inc.,December 3,2003 3-43 14. Orosz Engineering Group, Inc.,December 4,2003 3-45 15. Pacific City Action Coalition,December 3,2003 3-48 Pacific City Action Coalition,Attachment A,December 3,2003 3-64 Pacific City Action Coalition,Attachment B,December 3,2003 3-71 Pacific City Action Coalition,Attachment C,December 3,2003 3-75 16. Robert Mayer Corporation,December 3,2003 3-78 Kimley-Hom and Associates,Inc.,Attachment A to Robert Mayer Corporation Letter,December 2,2003 3-92 Richard Watson&Associates, Inc.,Attachment B to Robert Mayer Corporation Letter,December 2,2003 3-104 Individuals Written Letters 17. Mr.Mark D.Bixby,December 2,2003 3-133 18. Mr Paul Cross,November 14,2003 3-152 Pacific City EIR 3-1 Chapter 3 Responses to Comments Table 3-1 Comment Letters Received During the Draft EIR Comment Period Verbal Comments Pacific City Draft EIR Public Meeting,Verbal Comments,November 13,2003 3-157 Mr.Mike Churchin,Attachment to Verbal Comments,November 13,2003 3-161 Speaker Cards Mr.Mark D.Bixby,November 13,2003 3-163 Mr.Frank C.Brucculeri,November 13,2003 3-164 Mr.Al Calonico,November 13,2003 3-165 Mr.Mike Churchin,November 13,2003 3-166 Mr.Paul Cross,November 13,2003 3-167 Ms.Laura Knox,November 13,2003 3-168 Ms.Fay Mathis,November 13,2003 3-169 Mr.John Sisker,November 13,2003 3-170 Mr.John Sisker,second submittal,November 13,2003 3-171 3.2 COMMENTS AND RESPONSES TO COMMENTS This chapter of the Final EIR contains all comments received on the Draft EIR during the public review period, as well as the Lead Agency's responses to these comments. Reasoned, factual responses have been provided to all comments received, with a particular emphasis on significant environmental issues. Detailed responses have been provided where a comment raises a specific issue; however, a general response has been provided where the comment is relatively general. Although some letters may raise legal or planning issues, these issues do not always constitute significant environmental issues. Therefore, the comment has been noted, but no response has been provided. Generally, the responses to comments provide explanation or amplification of information contained in the Draft EIR. The following Section contains the original comment letters, which have been bracketed to isolate the individual comments, followed by a section with the responses to the comments within the letter. As noted above, and stated in Sections 15088(a) and 15088(b) of the CEQA Guidelines, comments that raise significant environmental issues are provided with responses. Comments that are outside of the scope of CEQA review will be forwarded for consideration to the decision makers as part of the project approval process. In some cases, a response may refer the reader to a previous response, if that previous response substantively addressed the same issues. 3-2 City of Huntington Beach STATE DEPARTMENTS • DEPARTMENT OF CONSERVATION STATE OF CALIFORNIA November 26, 2003 CPLIFD.RNIA , R�i} illi�« CONSERVATION Mary Beth Broeren, Principal Planner DIVISION OF OIL, City of Huntington Beach GAS, 8 GEOTHERMAL Department of Planning RESOURCES 2000 Main Street Huntington Beach, CA 92648 5815 CORPORATE AVE SUITE 200 Subject: Draft Environmental Impact Report, Project Title: Pacific City CYPRESS EIR 02-01, SCH No. 2003011024 CALIFORNIA 90630-4731 Dear Ms. Broeren: PHONE 7 1 4/8 1 6-6 8 4 7 The Department of Conservation's Division of Oil, Gas, and Geothermal FAX Resources(Division) has reviewed the above referenced Draft 7 1 4/6 1 6-f 0 5 3 Environmental Impact Report for the Pacific City Project in Huntington Beach. The Division supervises the drilling, maintenance, and plugging DOC 1 I N T E R N E T and abandonment of oil, gas, and geothermal wells in California. The consrv.ca.gov scope and content of information that is germane to the Division's responsibility are contained in Section 3000 et seq. of the Public ARNOLD Resources Code (PRC), and administrative regulations under Title 14, S C H W A R Z E N E G G E R Division 2, Chapter 4 of the California Code of Regulations. We offer the G O V E N O R following comments for your consideration_ The proposed project is located within the administrative boundaries of the Huntington Beach oil field. There are numerous plugged and abandoned wells within the project boundaries-These wells are identified DOC-2 on Division map 135 and records. The Division recommends that all wells within or in close proximity to project boundaries be accurately plotted on - future project maps. Furthermore, if any additional abandoned or unrecorded wells are damaged or uncovered during excavation or grading, remedial plugging DOC-3 operations may be required. If such damage or discovery occurs, the Division's district office must be contacted to obtain information on the requirements for and approval to perform remedial operations. To ensure proper review of building projects, the Division has published an informational packet entitled, "Construction Project Site Review and Well Abandonment Procedure"that outlines the information a project DOC-4 developer must submit to the Division for review. Developers should contact the Division's Cypress district office for a copy of the site-review packet. The local planning department should verify that final building plans have undergone Division review prior to the start of construction. 3-3 Ms. Mary Beth Broeren— Principal Planner- City of Huntington Beach - - November 26, 2003 Page 2 Determination of the adequacy of any proposed methane mitigation measures for the project is beyond the Division's authority. However, the Division recommends that any DOC-5 plugged and abandoned well be vented if a structure is to be built over or in proximity to a well. If any structure is to be located over or in the proximity of a previously plugged and abandoned well, the well may need to be plugged to current Division specifications. Section 3208.1 of the PRC authorizes the State Oil and Gas Supervisor(Supervisor)to DOC-6 order the reabandonment of any previously plugged and abandoned well when construction of any structure over or in the•proximity of the well could result in a hazard. The cost of reabandonment operations is the responsibility of the owner of the property upon which the structure will be located. Thank you for the opportunity to comment on the Draft Environmental Impact Report for the Pacific City Project. If you have questions on our comments, or require technical DOC-7 assistance or information, please call me at the Cypress district office: 5816 Corporate Avenue, Suite 200, Cypress, CA 90630-4731; phone (714) 816-6847. Sincerely, Paul L. Frost Associate Oil & Gas Engineer cc: Linda Campion, Division of Oil, Gas, and Geothermal Resources, Sacramento • 3-4 9'ADONAND HOUSING AGENCY ARNOLDSCIiWARI�lmot SfATE0FCA1.lFORNiA BUSIN�SS.TRAIJ91'OA_ DEPARTMENT OF TRANSPORTATION District 12 .,:1'1 3337 Michelson-,Drive,Suite 380 �x- Irvine,CA 92612-8894 Tel:(949)2724-2267 Flex your power! Fax:(949)724-2592 Be energy efficient! FAX&MAIL • December 3, 2003 t,; 1 Mary Beth.Broeren File: IGR/CEQA City of Huntington Beach SCH#:2003011024 2000 main Street Log#: 1193B Huntington Beach, CA 92648 SR PCH Subject:Pacific City Dear Ms. Broeren, Thank you for the opportunity to review and comment on the Draft Environmental Impact Report(DEIR)for the Pacific City Project. The project proposes to develop a 31.5-acre vacant site bounded by Pacific Coast Highway (PCH), 1st Street, Huntington Ave, Atlanta Ave into a DOT-1 mixed-use commercial and residential center including a 400-room hospitality/hotel, 240,000 square feet of retail, office, restaurant, cultural, and entertainment facilities, 516 condominiums, and improvements to vehicular and pedestrian circulation. The nearest State Routes to the project site are PCH and SR 39. Caltrans District 12 status is a responsible agency on this project and has the following comments: 1. Page 2-21 of Chapter 2: State facility improvements mentioned in the Caltrans Transportation DOT-2 Concept Report(previously known as Route Concept Report)are not programmed or funded, therefore should not be treated as committed improvements. Please clarify the network assumption(lane numbers)for Pacific Coast Highway(PCH)in years 2008 and 2020 analysis. 2. Table 3.14-10, Section 3.14,Chapter 3—Project Traffic Generation Forecast: a. The 5,000 square feet(sf) reserved for the surfing museum should be included in the total DOT-3 square footage for Retail/Restaurant By removing 5,000 sf from the 180,000 s1 the forecasted trips reduce from 9,947 to 9,769,thus giving incorrect traffic counts. b. The internal capture rates used for the trip reduction are too high. Caltrans TIS guideline recommends 5% for internal capture rate. Please provide detailed justification for these DOT-4 high reduction rates (both internal and mode shift). Please refer to the TIS Guidelines provided to you as an attachment to Caltrans letter dated February 5, 2003. c. Appendix C, which is referred to as Trip Reduction Flow Diagram, is not included in7 DOT-5 • Appendix H—Traffic of the DEIR. Please provide a copy of Appendix C. 3: Page 3,14-30, Chapter 3: The summary of the percentage of Residential project-related traffic DOT-6 surpasses 100%. Please verify. "Colima improves mobility across California" 3-5 Mary Beth Broeren December 3, 2003 Page:2 • 4. Page 3.14-51, Section 3.14, Chapter 3 - Future Year 2008 with Proposed Project: Transportation Planning questions the use of City of Huntington Beach thresholds for roadway link impact analysis. By applying the city guidelines as identified on Page 49 of Appendix H and Page 3.14-28 of Chapter 3, none of the impacted segments on the state facilities(PCH and DOT-7 Beach Blvd.) would be mitigated Same comment applies to Year 2020 with Proposed Projects on page 3.14-55. Please explain how the adjacent intersections operate at the acceptable LOS while the segment fails? — 1 5. For future reference, we recommend that the roadway segment level of service (LOS) should be based on the Peak Hour/Peak Period rather than the ADT(Table 3.14-5&6, Page 3.14-20, DOT-8 Section 3), since it is a better indicator of the roadway performance. 6. Page 63 -Pedestrian Pathway: The project is anticipated to generate substantial amount of pedestrian traffic that will impact the level of service at the crosswalks and intersections in the vicinity of the project area. Particularly, the crosswalk on PCH at Pt Street,Huntington Street DOT-c) and Main Street. In order to adequately address the impacts on these locations the following is requested: a. It is not clear whether there is a pedestrian bridge to be constructed as part of this project. j DOT-10 Please clarify. The Department's concern is pedestrian circulation impact to PCIL b. The pedestrian circulation pattern will be different before and after the bridge construction. Please address this timing issue and submit engineering plans and schedule of the pedestrian DOT-11 bridge construction to Caltrans(Traffic Operations North)for review and comment. c_ Submit estimated project pedestrian volumes at the above intersections. DOT-12 d. Submit the intersection capacity analysis including the pedestrian volumes with and with DOT-13 out the pedestrian bridge. 7. Currently PCH at 1`` Street is not provided with a crosswalk at the south leg .If a sidewalk is DOT-14 warranted to accommodate the project pedestrian traffic, the project proponent is responsible for the crosswalk installation and the signal modification. 8. Section 3.8, Hydrology and Water Quality, dirisces drainage facilities on and around the project site, and mentions some proposed changes to these facilities. Please note, the Caltrans DOT-15 NPDES Unit must approve any changes to State drainage facilities. — 9. If any project work (e.g. storage of materials, street widening, emergency access improvements, sewer connections, sound walls, storm drain construction, street connections, 'etc.) occurs in the vicinity of the Caltrans Right-of-Way, an encroachment permit would be required and environmental concerns must be adequately addressed. If the environmental DOT-16 documentation for the project does not meet Caltrans requirements, additional documentation (e.g. Native American Heritage Commission consultation for cultural resources) would be required before approval of the encroachment permit. Please coordinate with Caltrans to meet requirements for any work within or near Caltrans Right-of-Way. (See Attachment: Environmental Review Requirements for Encroachment Permits) — "Caltrans(improves mablllryacrossCalifornia" 3-6 Mary Beth Broeren December 3, 2003 Page:3 10_All work within the State Right of Way must conform to Caltrans Standard Plans and Standard Specifications for Water Pollution Control, including production of a Water Pollution Control Program (WPCP)or Storm Water Pollution Prevention Plan(SWPPP) as required. Any runoff draining into Caltrans Right of Way from construction operations, or from the resulting DOT-17 project, must fully conform to the current discharge requirements of the Regional Water Quality Control Board to avoid impacting water quality. Measures must be incorporated to contain all vehicle loads and avoid any tracking of materials, which may fall or blow onto Caltrans roadways or facilities.(See Attachment Water Pollution Control Provisions) Please continue to keep us informed of any future developments, which could potentially impact the transportation facilities. If you have any questions or need to contact us,please do not hesitate DOT-18 to call Maryam Molavi at(949)724-2267. Sincerely, Robert F. o eP Chi IGR/Community Planning Branch c: Terry Roberts, Office of Planning and Research Terri Pencovic,Caltrans HQ IGR/Community Planning Gail Farber,District 12 Deputy Director of Planning Saied Hashemi, Traffic Operations North Leslie Mandersheid,Environmental Planning B Charlie Larwood, Transportation Planning Cotmans improver mobility across Cahfornma" 3-7 ENVIRONMENTAL REVIEW REQUIREMENTS FOR ENCROACHMENT PERMITS Any Party,outside of Caltrans,that does work an a State Highway or interstate Highway in California needs to apply for an encroachment permit. To acquire any encroachment permit,environmental concerns must be addressed. Environmental review of encroachment permit applications may take 3 weeks if the application is complete or longer if the application is incomplete. For soil disturbing activities(e.g.geotechnical borings,grading,usage of unpaved roads from which dirt and other materials may be tracked onto the State/Interstate highways,etc),compliance with Water Quality and Cultural Resources Provisions are emphasized. Surveys may/may not be soil-disturbing activities,depending on the site and survey method. A complete application for environmental review includes the following: 1. If an environmental document(CE,EIR/EiS,ND,etc.)has been completed for the project,copy of the final,approved document must be submitted with the application. 2. Water Quality Provision: All work within the State Right of Way must conform to Caltrans Standard Plans and.Standard Specifications for Water Pollution Control including production of a Water Pollution Control Program or Storm Water Pollution Prevention Plan as required.The applicant must provide Encroachments with a copy of the Storm Water Pollution Prevention Plan(SWPPP,including Best Management Practices(BMPs)to be imptemented for construction activities impacting Caltrans Right of Way,prepared for this as required by the NPDES Statewide Storm Water Permit for General Construction Activities. If no SW PPP has been prepared for this project,then the applicant must follow the requirements described in the attached Water Pollution Control Provisions(please see attachment). 3. Cultural Resources Provisions: If not included in the environmental document,before permit approval and project construction,the encroachment permit applicant must complete a Cultural Resource Assessment pursuant to Caltrans Environmental Handbook,Volume 2,Appendix B-1,and Exhibit 1.as amended. The Cultural Resources Assessment ascertains the presence or absence of cultural resources within a one-mile radius of the project area and evaluates the impact to any historical/cultural resource. Cultural Resources include"those resources significant in American history, architecture,archaeology,and culture,including Native American Resourhees"(Caltrans Environmental Handbook,Volume 2,Chapter?,as amended)].The Cultural Resource Assessment must include: a) a clear project description and map indicating project work,staging areas,site access,etc.; b) a Record Search conducted at the South Central Coastal Information Center(SCCIC)located at California State University,Fullerton. For information call(714)278-5395; c) proof of Native American consultation_ Consultation involves contacting the Native American Heritage Commission(NAHC),requesting a search of their Sacred Lands File,and following the recommendations provided by the NAHC. For information call(915)653-4082: d) documentation of any historic properties(e.g.prehistoric and historic sites,buildings,structures,objects,or districts listed on,eligible for,or potentially eligible for listing on the National Register of Historic Places) within a one mile radius of the project area; e) and a survey by qualified archaeologist for all areas that have not been previously researched. The SCCIC and NAHC have an approximate turn around time of 2 weeks. 4. Biological Resources Provisions: Work conducted within Caltrans Right of Way should have the appropriate plant and wildlife surveys completed by a qualified biologist if the information is not included in the environmental document, Environmental Planning requests that the applicant submit a copy of the biological study,survey,or technical report by a qualified biologist that provides details on the existing vegetation and wildlife at the project site and any vegetation that is to be removed during project activities.Official lists and databases should also be consulted for sensitive species such as the California Natural Diversity Database and lists provided by the U.S.Fish and Wildlife Service and the California Department of Fish and Game.Any impacts that affect waterways and drainages and/or open space during construction,or that occur indirectly as a result of the project must be coordinated with the appropriate resource agencies.As guidance,we ask that the applicant include: a)dear description of project activities and the project site b)completed environmental significance checklist(not just yes and no answers,but a description should be given as to the reason for the response), c)staging/storage areas noted on project plans, d)proposed time of year for work and duration of activities(with information available), e)any proposed mitigation(if applicable to the project), f)and a record of any prior resource agency correspondence(if applicable to the project). 3-8 ATTACHMENT CALTRANS DISTRICT 12 WATER POLLUTION CONTROL PROVISIONS Any runoff draining into Caltrans Right of Way must fully conform to the current discharge requirements of the Regional Water Quality Control Board (RWQCB) to avoid impacting water quality. Permittee shall fully conform to the requirements of the Caltrans Statewide National Pollutant Discharge Elimination System (NPDES) Storm Water Permit, Order No. 99-06-DWQ, NPDES No. CAS000003,adopted b y the State Water Resources C ontrol B oard (SWRCB) on July 15, 1999, in addition to the BMPs specified in the Caltrans Storm Water Management Plan (SWMP). When applicable, the Permittee will also conform to the requirements of the General NPDES Permit for Construction Activities, Order No. 99-08-DWQ, NPDES No. CAS000002, and any subsequent General Permit in effect at the time of issuance of this Encroachment Permit. These permits regulate storm water and non-storm water discharges associated with year-round construction activities. Please note that project activities should pay extra attention to storm water pollution control during the "Rainy Season" (October IS`—May 1s`) and follow the Water Pollution Control BMPs to minimize impact to receiving waters. Measures must be incorporated to contain all vehicle loads and avoid any tracking of materials,which may fall or blow onto Caltrans Right of Way. For all projects resulting in 0.4 hectares(1 acre)or more of soil disturbance or otherwise subject to the NPDES program, the Contractor will develop, implement, and maintain a Storm Water Pollution Prevention Plan (SWPPP) conforming to the requirements of the Caltrans Specification Section 7- 1.01 G "Water Pollution C ontrol",the D eparhment's Statewide NPDES Permit,the General N PDES Permit for Construction Activities, and the Storm Water Quality Handbooks "Storm Water Pollution Prevention Plan (SWPPP) and Water Pollution Control Program (WPCP) Preparation Manual", and "Construction Site Best Management Practices (BMPs) Manual" effective November 2000, and subsequent revisions. In addition, the SWPPP must conform to the requirements of the SWRCB Resolution No.2001-046,the Sampling and Analytical Procedures(SAP)Plan. For all projects resulting in less than 0.4 hectares (1 acre) of soil disturbance or not otherwise subject to the requirements of the NPDES program,the Contractor shall develop, implement, and maintain a Water Pollution Control Program (WPCP) conforming to the requirements of the Department's Specifications Section 7-1-.O1G (Water Pollution Control), and the Storm Water Quality Handbooks: "Storm Water Pollution Prevention Plan (SWPPP) and Water Pollution Control Program (WPCP) Preparation Manual" and"Construction Site Best Management Practices (BMPs)M anual"effective March 2003,and subsequent revisions. Copies of the Permits and the Construction Contractor's Guide and Specifications of the Caltrans Storm Water Quality Handbook may be obtained from the Department of Transportation, Material Operations Branch, Publication Distribution Unit, 1900 Royal Oaks Drive, Sacramento, California 95815,Telephone: (916)445-35207 Copies of the Permits and Handbook are also available for review at Caltrans District 12, 3347 Michelson Drive, Suite 100, Irvine, California 92612, Telephone: (949) 724-2260. Electronic copies can be found at http://www.dot.ca.gov/hq/construe/stormwater.html Revised 10/23/01 3-9 Department of Toxic Substances Control ems: - Edwin F. Lowry, Director 5796 Corporate Avenue ,Kinston H. Hickox Cypress, California 90630 Agency Secretary tiy<,�, Gray Davis 9 Y rY Governor California Environmental NO-ti' 7 2; ,/4. Protection Agency - November 4, 2003 Ms. Mary Beth Broeren Principal Planner Department of Planning City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 - NOTICE OF COMPLETION OF DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE PACIFIC CITY PROJECT (SCH #2003011024) Dear Ms. Broeren: The Department of Toxic Substances Control (DTSC) has received your Notice of Completion (NOC) of a draft Environmental Impact Report (EIR) for the above- mentioned Project. DISC-1 Based on the review of the document, DTSC's comments are as follows: _J 1) The draft EIR needs to identify and determine whether current or historic uses at the Project site have resulted in any release of hazardous wastes/substances at DISC-2 the Project area. 2) The draft EIR needs to identify any known or potentially contaminated sites within the proposed Project area. For all identified sites, the draft EIR should DTSC-3 evaluate whether conditions at the site pose a threat to human health or the environment. 3) The draft EIR should identify the mechanism to initiate any required investigation 'and/or remediation for any site that may be contaminated, and the government DTSC-4 agency to provide appropriate regulatory oversight. If hazardous materials/wastes were stored at the site, an environmental assessment should be conducted to determine if a release has occurred. If so, further studies DTSC-6 should be carried out to delineate the nature and extent of the contamination. Also, it is necessary to estimate the potential threat to public health and/or the —1 environment posed by the site. It may be necessary to determine if an expeditedJDTSC-6 The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 3-10 For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at www.dtsc.ca.gov. ® Printed on Recycled Paper Ms. Mary Beth Broeren November 4, 2003 Page 2 of 3 response action is required to reduce existing or potential threats to public healthA or the environment. If no immediate threat exists, the final remedy should be DTSC-6 implemented in compliance with state regulations and policies. 4) All environmental investigation and/or remediation should be conducted under a Workplan which is approved by a regulatory agency that has jurisdiction to oversee hazardous waste cleanups. The draft EIR states that upon completion DTSC-7 of the remediation program,_approval of a Site'Closure Report by the oversight agency is required prior to redevelopment of any site with identified environmental concern. Except for petroleum hydrocarbon, the City of Huntington Beach, the identified oversight agency, may not.have the jurisdiction to oversee hazardous waste cleanups. 5) 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 DTSC-8 Contaminated Property." Appropriate precautions should be taken prior to construction if the proposed project is within a "Border Zone Property." 6) According to the draft EIR, volatile organic compounds (VOCs) detected at the ; site were compared with the U.S. Environmental Protection Agency's preliminary remediation goals (PRGs) and recommended no further action. DTSC DTSC-9 recommends that a site-specific health risk assessment, using a residential scenario, be conducted and reviewed by a regulatory agency that has jurisdiction to oversee hazardous substance cleanups. PRGs are screening criteria and are not intended as cleanup standards. 7) The draft EIR states that all soil samples collected from the excavation, following the removal of the impacted soil, contained soluble lead at concentrations below the California Code of Regulations Title 22 action level of five (5) parts per million (ppm). Appendix E, Summary of Hazardous Materials Investigations on the DTSC-10 Project Site, also states that lead concentration in soil were compared with the Soluble Threshold Limit Concentrations (STLCs) and Total Threshold Limit Concentrations (TTLCs). TTLCs and STLCs are not cleanup standards. They are used for classification of hazardous wastes. Therefore, DTSC recommends that a site specific risk assessment using a residential scenario be conducted and reviewed by a regulatory agency. 8) Appropriate investigation should be conducted to determine whether.the project site is contaminated with polychlorinated biphenyls (PCBs). Disc 11 3-11 Ms. Mary Beth Broeren November 4, 2003 Page 3 of 3 9) If during construction/demolition of the project, soil and/or groundwater contamination is suspected, construction/demolition in the area should cease and appropriate health and safety procedures should be implemented. If it is DTSC-12 determined that contaminated soil and/or groundwater exist, the draft EIR should identify how any required investigation and/or remediation will be conducted, and the government agency to provide appropriate regulatory oversight. DTSC provides guidance for preparation of a Preliminary Endangerment Assessment (PEA), and cleanup oversight through, the Voluntary Cleanup Program (VCP). For additional information on the VCP, please visit DTSC's web site at www.dtsc.ca.gov. DTSC-13 If you have any questions regarding this letter, please contact Mr. Johnson P. Abraham, Project Manager, at (714)484-5476. Sincerely, Greg Holmes Unit Chief Southern California Cleanup Operations Branch Cypress Office cc: Governor'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 3-12 REGIONAL/LOCAL AGENCIES DEC v - ' F CITY OF NEWPORT BEACH �a fir OFFICE OF THE MAYOR :-;1-/PORN. `. Mayor Steven Bromberg November 26, 2003 Mayor Pro Tem Tod W.Ridgeway Council Members Garold B.Adams Ms. Mary Beth Broeren John Heffernan Planning Department Richard A.Nichols 2000 Main Street Gary L.Proctor Huntington Beach, CA 926648 Don Webb Dear Ms. Broeren: - Pacific City Project Draft Environmental Impact Report Thank you for the opportunity to comment on the Pacific City Project Draft-Environmental Impact Report (Draft EIR). The City of Newport Beach has an Environmental -Quality' Affairs Citizens Advisory Committee (EQAC), which reviews NOPs and Draft EIRs prepared for Newport Beach projects, as well as projects in adjacent communities that may impact Newport Beach. EQAC reviewed this Draft EIR and CNB-1 prepared the following comments-on the document, along with the City's Public Works staff. EQAC's comments were approved by the Committee on November 17, and by the City Council on November 25. Please note that the City did not receive or provide comments on the IS/NOP, but EQAC did review the summary of comments provided as an appendix to the Draft EIR as part of its review Of this document. Air Quality Section 3.2.2 — Regulatory Framework. The existing localized carbon monoxide concentrations shown on Table 3.2-5 exceed the future (2010) with project localized carbon monoxide concentrations shown CNB-2 on Table 3.2-7. This outcome is counterintuitive. An explanation of why air quality improves in the future with the project should be provided. - Section 3.2.4 — Project Impacts, indicates the current and projected population and employment for Orange 'County. These figures are CNB-3 incorrect and should be updated: Section 3.2.6 — Mitigation Measureseand Residual impacts. The CNB-4 mitigation measures as currently writterf;are too vague and uncertain, v City Hall • 3300 Newport Boulevard • Post Office Box 1768 Newport Beach, California 92658-8915 • www.city.newport-beach.ca.us (949)644-3004 3-13 Page 2 Pacific City Project Draft Environmental impact Report November 26, 2003 and will not necessarily result in reductions in air quality impact. J CNB-4 Comments on specific mitigation measures are presented below: IJ CNB-5 CR AQ-E — An explanation of the type of wind barrier that will be 1 CNB-6 implemented should be provided. CR AQ- F- An explanation of what is meant by a remedial operation and how it will reduce fugitive dust should be provided. CNB-7 MM AQ —1 through AQ-6 rely on contract specifications as an implementation method. CNB-8 The developer and the contractor have a financial incentive not to comply with these mitigation measures. A-description of the City's CNB-9 inspection program and how it will function to ensure mitigation measures are carried through should be provided. _ MM AQ-4 — The contractor should be required to rely on electric utilities, and not be given the option of using electric utilities to the CNB-10 extent feasible. MM AQ-6— It is suggested that performance standards be required tol ensure that energy efficient appliances are installed. CNB 11 Hydrology and Water Quality — Table 3.8-4, Policies Applicable to Hydrology and Water Quality. Policy 6.1.25 states that new development will minimize the creation of CNB-12 impervious areas. We suggest that the developer strongly consider using porous pavement and swales wherever possible, especially in the street and parking areas, to help divert run-off water back into the earth. Transportation and Traffic — The City of Newport Beach is concerned about the size of the project relative to the area covered by the traffic study. The draft ERR traffic study includes Pacific Coast Highway only as far as the Brookhurst intersection within the City of Huntington Beach. The scope of the study should be extended along Pacific Coast Highway up to the CNB-13 intersection with Dover Drive. This will cover several major arterial intersections, such as PCH/Superior and PCH/Newport Boulevard that would potentially be impacted by a project of this size. The Project Trip Distribution diagrams indicate that almost 25% of the project traffic is anticipated to use Pacific Coast Highway in Newport Beach. The impacts of this additional traffic, some 3000 daily trips, must be analyzed in detail. 3-14 • Page 3 Pacific City Project Draft Environmental Impact Report November 26, 2003 In addition to extending the geographical scope of the traffic study, the key intersection analysis, as described on page 3.14-52, should include scenario 4 (without the 19th Street Bridge over the Santa Ana CNB-14 River). The completion of this link is not a certainty, and our understanding is that the City of Huntington Beach has agreed to analyze projects with and without the 19th Street Bridge. The Congestion Management Program (CMP) analysis is incomplete and further substantiates the need to extend the boundary of the study. The CMP, as adopted in Orange County, requires the analysis to extend.to the point that project traffic falls below 3% of the CNB 15 roadway's LOS E capacity. In the case of West Coast Highway in Newport Beach, this threshold is 1689 daily-trips and the traffic study indicates the project volume is around 3000 daily trips, well in excess of the threshold. — The City appreciates the opportunity to comment on this DEIR, and we look forward to reviewing responses to our comments. If Newport Beach staff can assist in the preparation of responses, please call CNB-16 Assistant City Manager Sharon Wood at 644-3222 or Traffic and Development Services Manager Rich Edmonston at 644-3345. Sincerely, teve Bromberg • 0. Mayor Cc: Environmental Quality ualit Affairs Committee Rich Edmonston, Transportation and Development Services Manager 3-15 }! Board of Trustees: 1cM a HUNTI NGTON BEACH UNION Bonnie Castrey a° Fy Brian Garland- HIGH SCHOOL DISTRICT Matthew Harper Susan Henry Y I 10251 Yorktown Avenue ' Huntington Beach, California 92646-2999 Michael Simons • - c& 1714)9E44339 FAX(714)963-7694 Van W.Riley,Ph.D.,Superintendent of Schools Dh 9C'4O FAX TRANSMITTAL e: October Date: 27, 2003 TO: Mary Beth Broeren FAX No.; 714-374-1540 From: Patricia Koch FAX No.: 714-963-7684 - • Number of Pages (excluding cover page) Response requested Comments: We have downloaded Pages 3,12-3 and 3.12-4 from the Pacific City Project Draft EIR. We request that you correct the section on Schools to indicate that the High HBUHSD-1 School District "also serves substantial portions of the City of Westminster and City of Fountain Valley" . Misc/Ciries/Draf EIR _ Our mission is to educate all students,responding to their diverse needs, using a challenging curriculum with multiple i avenues of learning, to develop creative,responsible and productive members of our community. 3-16 1 o " 116 County of Orange ,Ile:1 I',K •r''/ * Planning & Development Services Department .�r�N i'n WON.r,.uwr�l nNA,1'nl.'1f,R NIA rFoti MAIi.INt;,1111141:3i I'CY I0.S 411a1; I'N IA,'NA.1'.\ 9270i.J6VM NCL 03.1 1 I December 3,2003 Mary Beth Broeren, Principal Planner City of Huntington Beach Planning Department 2000 Main Street Huntington Beach, CA 92648 SUBJECT. 1)1;1R for the Pacific City Project Dear Ms. Broeren: The above referenced project is a Draft Environmental Impact Report(DEIR) for the City of Huntington Beach. The project will provide a mixed-use visitor-serving commercial center with a residential village located on a 31.5-acre vacant downtown parcel on the inland side of Pacific OCPD-1 Coast Highway. The County of Orange has reviewed the DEIR and offers the following comments: WATER QUALITY I Fite water quality impacts of the project should be reviewed in accordance with the OCPD-2 provisions outlined in Exhibit 7-1 of the 2003 Countywide Drainage Area Management Plan (DAMP). AL a minimum, the following information should be provided a. A review of DAMP Exhibit 7.1 Table 7-1.1, Priority Projects Categories. Projects that fall into one of these categories should be carefully reviewed fur potential OCPD-3 stormwater/urban runoff impacts. b. Identification of receiving waters. The EIR should identify all receiving waters OCPD-4 that may receive runoff from the project site. c. A description of the sensitivity of the receiving waters. In particular the EIR should identify Areas of Special Biological Significance, water bodies with Total Maximum Daily Loads (TMDLs), and 303(d) listed impaired water bodies that OCPD 5 may be impacted by the proposed project. For example, Huntington Beach State 1 � I 3-17 Park is listed on the 2002-303(d) list as impaired for enterococci, with an estimated impacted area of 5.8 miles. The project is locu•ed wr.hiri i5 rrites o.' OCPD-5 the site of impairment. — d, An identification of hydrologic conditions of concern, such as runoff volume and velocity; reduction of infiltration, and any increase of flow, frec;uercy, durati :n, OCPD-6 and peak of storm runoff. — 2. Implementation of post-construction Best Management Practices(B.lvMPs)consistent witn — the Water Quality Management Plan(WQMP)program in Section 7 and Exhibit 7-ll of the 2003. Countywide DAMP. This includes describing commitments to installation and maintenance of site design,source control and treatment control BMPs consistent with OCPD-7 the DAMP New Development and Significant Redevelopment Program. Under the new Municipal Stormwater NPDES permit and the 2003 DAMP, this project will he considered a priority project and will require appropriately sized treatment control BMPs to be included in the WQMP. 3. Mitigation for the construction phase of the project should include compliance with the State General Construction Permit and the inclusion of the following as general or specific notes on project plan sheets. a. Sediment from areas disturbed by construction shall be retained on site using structural controls to the maximum extent practicable. b. Stockpiles of soil shall be properly contained to eliminate or reduce seduncnt transport from the site to the streets, drainage of facilities or adjacent properties via runoff,vehicle tracking, or wind. c. Appropriate BMPs for construction-related materials,wastes, spills or residues OCPD-8 shall he implemented to minimize transport from the site to streets, drainage I facilities,or adjoining properties by wind or runoff. d Runoff from equipment and vehicle washing shall be contained at construction sites unless treated to reduce or remove sediment and other pollutants e. All construction contractor and subcontractor personnel are to he made aware of the required best management practices and good housekeeping measures for the project site and any associated construction staging areas. f. At the end of each day of construction activity all construction debris and waste materials shall be collected and properly disposed in trash or recycle bins. g. Construction sites shall be maintained in such a condition that a storm does not carry wastes or pollutants off the site. Dischargers other than stormwater(non- stormwater discharges)arc authorized under California's General Permit for Storm Water Discharges Associated with Construction Activity only where they do not cause or contribute to a violation of any water quality standard and arc controlled through implementation of'appropriate l3MPs for elimination or V 2 3-18 • • • • - t ntiwater dischar es must be ettnirated or reduction of pollutants, Non s o g reduced to the extent feasible. Potential pollutants include but are nut limited to• solid or liquid chemical spills, wastes from paints, stains, sealants, solvents,detergents, glues, time,pesticides, herbicides, fertilizers,wood,preservatives,and asbestos fibers,paiul :lakes er stucco fragments; fuels, oils, lubricants and hydraulic, radiator or hmitter" fluids concrete and related cutting or curing residues; floatable wastes, wastes from any ' engine/equipment steam cleaning or chemical degreasing; wastes from street OCPD-8 cleaning; and super chlorinated potable water line flushing and testing. During construction,disposal of such materials should occur in a specified and controlled temporary area on-site physically separated from potential storm water runoff, with ultimate disposal in accordance with local, state and federal requirements. h. Discharging contaminated groundwater produced by dewatering groundwater that has infiltrated into construction site is prohibited. Discharging of contaminated soils via surface erosion is also prohibited. Discharging of non-contaminated groundwater produced by dewatering activities requires a National Pollutant Discharge Elimination System(NPDliS) permit from the San Diego Regional Water Quality Control Board. _J 4. The EIR should discuss the potential impacts of the proposed new storm drain line at First Street to the water quality issues identified for the Pacific Ocean at Huntington Beach State Park, Due to the project's proximity to lluntington Beach Slate Park, a OCPD-9 project design goal should be to eliminate all dry weather and low-flow discharges from the site using site design and source control I3MPs as described in the 2003 DAMP Section 7 and its exhibits. The 2003 DAMP can he found at. http.11www.ocwatersheds.com/StonnWateridocuments_damp.asp. Section 3.8.2 Regulatory Framework 5 The State Construction General Permit now requires the submittal of a NOI Package and preparation of a SWPPP in the following situations •'Dischargers whose projects disturb 1 or more acres of soil or whose projects disturb less than I acre but arc part of a larger common plan of development OCPD-10 that in total disturbs 1 or more acres,are required to obtain coverage under the General Permit for Discharges of Storm Water Associated with Construction Activity(Construction General Permit. 0)-08-DW(2) Construction activity subject to this permit includes clearing, grading and disturbances to the ground such as stockpiling,or excavation,but does not include regular maintenance activities performed to restore the original line, __ grade, or capacity of the facility." v 3 3-19 A This section should be rewritten to reflect that this requirement is applied to projects that OCPD-10 are one(1) or more acres in size, not live(5) _ b. The section should also include the requirement to prepare a WQiv1P that describes all OCPD-11 post-structural BMPs. CU[.TURAI../HTSTOR'CAL 7. The mitigation language in the E1R should he updated to use current standard conditions for cultural resources management so that any recovered artifacts and fossils are prepared properly and their disposition is addressed as needed. The County of Orange Cuuration OCPD-12 Project, funded by a TEA grant,has produced a set of guidelines and procedures as a model for cultural resource professionals to use in the field and in preparing the collections, including a recommended database. This information may be accessed on the California State University Fullerton Anthropology Department website. hun:fianthro_fullerton.edu/orangec.ocuration. S. MM CR-lc states that in case of unique archaeological resources being lound, they"shall be cleaned and catalogued for curation at a facility acceptable to the City of Huntington Beach." We encourage the City of Huntington Beach to follow the Orange County Board of Supervisors' intent to keep resources within the county.Thus., the E112 language should OCPD-13 be changed to require that resources collected from the site during grading/or and construction should be donated to a suitable repository"within Orange County " Prior to donation, the certified paleontologist should prepare the fossil collection "to the point of identification." 9. The project proponent should be prepared to pay'`potential curation fees" to the County or other suitable repository for the long-term curation and maintenance of donated OCPD 14 collections. Thank you for the opportunity to respond to the DER. If you have any questions, please contact OCPD-15 Charlotte Harryman at (7 1 4) 834-2522_ Sincerely, •••• /626 fil Timothy Neely, Mali r Environmental Plat I ig Services Division _I 4 3-20 Fil _ OCTA soAwD oi•DrnEcroRs December 3,2003 Pfeevee Maumee Ginter T.liinterbam ei Ms. Mary Beth Broeren, Principal Planner y'm'''"ai'"'a° City of Huntington Beach Planning Department Anm,c drum, 2000 Main Street °Nectar Huntington Beach,CA 92648 Biu Cam a&1 arretror Subject: Huntington Beach Pacific City DEIR l:amrn'n 0uyoung Direclei sd,evMCCrax6w, Dear Ms. Broeren: 1$ueCfer r,:nnsermmy The Orange County Transportation Authority (OCTA) has reviewed the above OCTA-1 ajecrur referenced document and has the following comments: *gee A.Paddy C'r"`'M Master Plan of Arterial Highways(MPArrli lam. w.:raa men., The proposed project would construct Pacific View Avenue as a two lane "S""'' divided street, although the DEIR states a ninetyfoot right-of-way would be Devour u9 9 Y dedicated to allow for future ultimate widening to four lanes. Both the Orange 1 4 `i'tl7wJr1 0,10701 County Master Plan of Arterial Highways (MPAH) and the City of Huntington OCTA-2 ,,,,,�R edrxrar. Beach General Plan classify Pacific View Avenue as a primary (four lane awedteOMINUK divided)arterial. While this is correctly stated in the DEIR, OCTA wishes to re- , s® a,.r, affirm the necessity of preserving the ability in the future to complete the street Allemate I to its ultimate four lane width. As such,the 55 on-street parking spaces located Thomases.Mon on Pacific View Avenue must be considered temporary, since they will occupy nN'yn'k O,reaor right-of-way needed for the ultimate widening of the street. Canty Qurm Govemar s r-r.afino+vcnmu Bus Facilities G►nEF Math*OFFICE OCTA currently operates bus service to the area via Routes 1. 25, 29, 172, and 173.'OCTA currently has a bus stop at northbound PCH/farside Huntington St OCTA-3 Anew T.L Cnw.1 Executive ONa:er and eastbound Atlanta Ave/farside 1st St. It is recommended that a "farside" type turnout be placed at these locations in conjunction with this development. In order to access this facility, many of the OCTA buses operate on Huntington, Atlanta. 1st and PCH. It is imperative for OCTA bus operations that this facility OCTA-4 and adequate access to this facility be maintained. Furthermore. OCTA would recommend that any improvements in the area consider the impact on OCTA bus operations. Ot nlj&County Trani{,ortaliran Aulhvrity 550 South Mum Street i P O.8ox 14 tile!Orange I Clekunia 02116.1-7534/(714)560 OCTA(6282) 3-21 Ms. Mary Beth Broeren December 3, 2003 , Page 2 OCTA appreciates the opportunity to review and comment on this project. Please contact me with any questions or concerns at 714560-5749 or OCTA-5 cwright atocta.net. Sincerely, At-Vie' Christopher Wright - - Associate Transportation Analyst TOTAL P.03 3-22 SOUTHERN CALIFORNIA November25,2003 _ Ms.Mary Beth Broeren Principal Planner j4O"r '-i`` P :=srfr4 City of Huntington Beach >• Department of Planning 2000 Main Street ••-"-p Huntington Beach,CA 92648 ASSOCIATION of RE: Comments on the Draft Environmental Impact Report for the Pacific City GOVERNMENTS Project—SCAG No.120030596 Main Office Dear Ms.Broeren: 818 West Seventh Street izth Floor Ti'lattk you for Submitting the Draft-Environiner tei Impact Report for the Pacific City Los Angeles,California Project to SCAG for review and comment. As areawide clearinghouse for regionally significant projects, SCAG reviews the consistency of local plans, projects, and SCAG-1 90037-3435 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. I(213)2364800 Guidance provided by these reviews is intended to assist local agencies and project f(213)236-1825 sponsors to take actions that contribute to the attainment of regional goals and policies. It is recognized that the proposed Project considers the development of-a mixed-use, wmv.scaS•Ca.gov visitor-serving commercial center with a residential village. Major components include a WDces:President:Maya Bea Pony,Brea•first 400-room hotel, 240,000 square feet of commercial and office uses and up to 516 SCAG-2 Vise President:Cwrcilmember Ron Roberts. Temecula•Second Vice President: supervisor condominium units. The 31.5-acre site is located at the southeast intersection of Hank Wiper. Impr•rltl • Pi11 President:Councimember Ronald Bates,lux Alamitos Atlanta Avenue and Huntington Street,in the City of Huntington Beach. loge rat County:(lark Kuipe.Imperial County InShtekds,Braale' SCAG staff has evaluated the Draft Environmental Impact Report for consistency with Los Aag•las Canty.blame Brathwaice Backe. Los Angeles CuVnle rParoslausky.los Angeles the Regional Comprehensive Plan and Guide and Regional Transportation Plan. The County•Melanie.Aldrevts CComptonHarry Draft EIR includes a discussion on the proposed Projects'consistency with SCAG policies SCAG-3 Baldwin,San tsar -Paull Braden.Cerritos- Tony(Ades.Los Angeles-Margaret Clark• and applicable regional plans, which were outlined in our February 4, 2003 letter on the Rosemead•Gene Daniels.Paramount•Mike Dispee a,Palmdale-lady Dunlap,inRIewoon• Notice of Preparation(NOP)for this Draft EIR. — Eric tialcetll los Aisles•Wendy Greuel Los Angeles•frank Geode.Cudahy•fames Hahn. los Angeles•lake+I.ahir.t,Angeles•Sandra The Draft EIR, in Sections 3.2-Air Quality, 3.3-Biological Resources, 3.4-Cultural lambs.El Scgundd•Tom LaBonRe.lusArgedes- Bonnie lwemhal,limy Beach•Marto Ludlow. Resources, 3.6-Geology and Soils, 3.9-Land Use and Planning, 3.11-Population and los Angeles•Keith MrCadhy.Downey-Llewellyn Miller.Claremont • Cindy Miscilowski• Los Housing, 3.12-Public Services, 3.14-Transportation/Traffic, and 3.15-Utilities and Service Angeles - Paul ta a. lee Pa • Pam Systems cited SCAG policies and addressed the manner in which the proposed Project is !)'Connor.Santa Mlnica•Ales Padilla.1us nngeles•Bernard Parks,los inigetes•Ian Perry, SCAG-4 los Angeles•fleabite P,vu,real Rivera-Ed consistent with applicable core policies and supportiveancillary of applicable policies. The Reyes,los Angeles•Greig Smith.Los Angeies• Draft EIR incorporated a side-by-side comparison of SCAG policies with a discussion of Dick Stanford.Musa•Tom SVkeS,Walled•Paul rP Y Pa Talbot.Alhambra-It Wet,Tyler.It.Pasadena• the consistency or support of the applicable policies with the proposed Project. This Trans Reyes Ilf angr,lung Beach •Antonio valar;gosa,t„•AnfedK•nunnls Washburn. approach to discussing consistency or support of SCAG policies is commendable and we Calabasas-lack Weiss.Los Angeles•Bob Tousefial.Glendale•Dennis P.line,Los Arteries appreciate your efforts. Based on the information provided in the Draft EIR,we have no oraste Colnn,Chti•Wry,Orange Candy.IAtn further comments. A description of the proposed Project was published in the October 16- Bonn.Tate.Rjtds•Art Burn. vez,AnBuena m•Debie 31,2003 Intergovernmental Review Clearinghouse Report for public review and comment. Boni.Tustin•Airhar 1 Chavez,Anaheim•Debbie Cook.Nonlitrgton Veach-Cathryn Dudomg, , Laguna Niguel•Richard Dixon.Lake fared•Alla — Duke•la Palma-Bee Terry,fined-Tod Ridgway, If you have any questions,please contact me at(213)236-1867. Thank you. -- Newport Beach Wrinkle County: Marion Ashley.Riverside County-Rail trMridgr.Riverside•WI Muir. ncerel�/, Corona•Greg Pettis,Cathedral City-Kan Roberts. \ Temecula•Charles White.Moreno Valley . San Renardino County: Paul Blanc. San Bernardino County- Bill Alexander.Rancho 1 / Cucamonga•Edwa1l Summon,Town ul Aople Valley•laarence Date.IkvHnw-LeeAnnGania. M.S H,AICP Grand hermce•sulan Lorgrilte.San Bernardino• 'i Gary Milt,Ontario••Deborah Robertson.Rialto Senior Regional Planner Vedora ratntr"ray Mainly,ve..l"'"r°"""- Intergovernmental Review Glen Berens.Simi Valley•Cad Morehouse.Sad Ruenxmntula•luni Soong.Pon Hueneme Riverside Canty Transportation Canmissiom Robin time.Hemet Verdun County Transportation Comalissidn:Bill Davis.Simi Valley smntdone..ple!Pan, YRC9l9Rr,1 , ® 3-23 ORGANIZATIONS tp s nv'sronmental Board C1 T`i 'OF HUNT INGTON BEACH 4i-�ft,GFn;?:Saco Post Office Bo'; 1 90 Hu ltinc:tol F':r. ! November 24,2003 Ms.Mary Beth Broeren City of Huntington Beach Planning Department 2000 Main Street,3rd Floor Huntington Beach, CA 92648 Subject: Draft Environmental Impact Report(Pacific City) Dear Ms. Broeren: The Environmental Board of the City of Huntington Beach is pleased to submit comments and HBEB-1 recommendations regarding the subject Draft Environmental Impact Report("DEIR"). We believe that the DEIR overall is thorough and well prepared. We concur that the following are significant, unavoidable adverse impacts that would result from project implementation. • Air Quality: 1. Peak construction activities associated with the proposed project could generate emissions that exceed SCAQMD thresholds. HBEB-2 2. Daily operation of the project would generate emissions that exceed SCAQMD thresholds. • Transportation: 1. Under Year 2008 conditions,implementation of the proposed project would significantly affect the operating conditions of the intersection of Pacific Coast Highway and Warner Avenue. After reviewing the DEIR and discussing it at our November 6,2003 meeting,the Environmental Board1 HBEB-3 voted to submit comments and recommendations reflecting the issues discussed below. 1. Typically we would request efforts to maximize percolation of storm water into the groundwater aquifer. However,in this case,the groundwater aquifer has no beneficial use due to the level of HBEB-4 Total Dissolved Solids. — 2. In the event that the project scope changes,we recommend that the twenty-feet wide public access corridor through District 8A be retained,as well as public access through District 7. It has been our experience that public access included in some projects has not been adequately HBEB-5 marked so that the public realizes these areas are for their use. Therefore,we recommend that the public access corridor be prominently marked identifying it as public access.The proposed 3-25 Ms.Mary Beth Broeren November 24,2003 Page 2 method of identification should be included in the Signage Plan submitted to the City EngineerHBEB 5 for approval. 3. The proposed project includes installation of Storm Drainage Filters to remove contaminants from storm water that is directed from the site,however,no information is included that explains how this equipment will be maintained to insure that it will properly function throughout the life HBEB-6 of the project. Please include a description of who will be responsible for maintaining the equipment as well as information as to how performance will be insured. This information should be included in a plan submitted to the City for approval. 4. With the projected addition of approximately 1400 residents, we believe that an analysis should be included that evaluates the impact of pedestrians crossing Pacific Coast Highway. During weekend periods,we believe that there could be a significant increase in pedestrian traffic across HBEB-7 Pacific Coast Highway due to residents seeking use of the beach as well as visitors parking at the beach and walking to the commercial facilities proposed by the project. We are concerned that this additional pedestrian traffic may adversely impact vehicular traffic and safety of the pedestrians thereby making the pedestrian overpass a necessity, Also,sufficient space must be allocated on either side of PCH to allow for required access by handicap individuals to the J HBEB-8 elevated pedestrian overpass,including elevators or ramps. S. On page 3.1-47,mitigation CR AES-D states,"Prior to occupancy, all new and existing overhead utilities shall be installed underground in accordance with the City's Underground Utility Ordinance". However,elsewhere in the document,it suggests that the 16 KV electrical lines will HBEB-9 not be relocated. Would you please clarify these apparent discrepancies? Also,if the 16 KV lines are not to be relocated underground,please include a discussion of reasons. —. 6. We appreciate the detailed study of the impacts of vehicular Lights on adjacent residential areas when exiting the garage areas of the project,however,we believe that vertical movement of vehicles due to roadway imperfections and gutters will cause headlights to shine above the limits shown in the DEIR causing a nuisance to residential neighbors. We recommend an addition HBEB-10 - evaluation to determine the feasibility of orienting the garage egress at an angle such that the headlights are directed in a path that is more toward the street and less toward the residences. Alternately, landscaping could be installed across the street from the development at each egress point to block light from vehicles. 7. An explanation of the timing of traffic improvements particularly at the intersection of PCH and Warner and on Atlanta Ave. east of the project site should be provided. The discussion should HBEB-11 contain an explanation of the approval and review process as well as likelihood and timing of completion of these improvements. _ 8. Because of the project's traffic and air quality impacts,greater consideration should be given to the promotion of other modes of transportation besides personal vehicles that could offset these HBEB-12 impacts. 7 3-26 • Ms.Mary Beth Broeren November 24,2003 Page 3 9. The air quality analysis notes that the'project is anticipated to result in some trip reduction thereby providing beneficial air quality impacts. Additional explanation should be included as to HBEB-13 the basis for these conclusions. 10.The village green should remain public to address significant impacts to open space. HBEB-14 11.Bacterial removal from dry weather flows to address water quality issues should be given consideration. _j HBEB-15 12. A discussion should be includedas to how construction related water contamination is addressed. HBEB-16 13.A discussion should be included as to how hazardous materials will be handled during site ' HBEB-17 excavation and preparation. 14. Mitigation Measure CR AQ-B should be modified to require the applicant to notify property T HBEB 18 owners within at least 500 feet of the perimeter instead of 300 feet. 15. Mitigation Measure AQ-5 should be modified as follows: Bullet No. 7—Revise to read,"Sweep streets throughout the day" HBEB-19 Bullet No. 9—Revise to read,"Apply water at least three times daily or more as needed..." Bullet No. 10—Revise to read"...10 MPH..."instead of"...15 MPH..." 16.Mitigation Measure AQ-6 should be modified as follows: Bullet No. 1 —Revise to read,"Use solar or low-emission/high efficiency water heaters..." HBEB-20 Bullet No. 2—Revise to read,"Provide high efficiency heating..," 17.Lastly,we recommend that a procedure for auditing the construction activities be included. Although the developer has described how contracts with builders will include requirements for implementing mitigations to reduce detrimental air and water releases from the site,experience suggests that construction contractors frequently fail to monitor these mitigations. Developers HBEB-21 may not feel responsible for how well the construction contractor manages environmental controls. However,we believe that the developer is ultimately responsible for insuring implementation of the mitigation measures. We recommend that the developer should produce a plan to audit performance of the construction contractor,for approval by the City. Yours truly, , /4 den r hart ENVIRONMENTAL BOARD 3 3-27 HUNTINGTON BEACH TOMORROW w P. O.BOX 865,HUNTINGTON BEACH, CA 92648 "Making a difference today for Huntington Beach tomorrow" Phone: (714) 840-4015 E-Mail: info@hbtomorrow.org December 3, 2003 Mary Beth Broeren Planning Department City of Huntington Beach Huntington Beach Ca 92648 Subject: Comments on Draft EIR for the Pacific City Project Section 3.2 - Air Quality CR AQ-B Require applicant to notify property owners within at least 500 feetHBT-1 of the perimeter, not 300 feet. MMAQ-5 Bullet#7: Change to read "Sweep streets throughout the day" -- instead of ..."end of day" Bullet #9: Change to read "Apply water at least three times daily or HBT-2 more as needed. . " Bullet#10: Change to read ""...10 MPH..." instead of "...15 MPH" MMAQ-6 Bullet#1: Change to read: Use solar or low-emmision/high efficiency water heaters ... HBT-3 Bullet#2: Change to read "provide high efficiency heating..." Section 3.10 - Noise Trash collection noise is not discussed. Add trash collection services for HBT-4 hotel, commercial and residential shall be performed between the hours of 8 AM and 5 PM. Section 3.12 - Public Services The section on existing Police services does not discuss the use of HBT-5 helicopter patrols that has effectively acted as a force multiplier for officers on duty. 3-28 4.7 Section 3.14 - Transportation/Traffic MM TR-1&2 Place a requirement on the developer that ties the project phasing HBT-6 to the actual construction of improvements at PCH & Warner and PCH and Seapoint. MM TR-3 Require the developer to include the pedestrian bridge in all plans now and that provisions for a Measure C vote and dedication of required HBT-7 land be stipulated. MM TR-3 The DEIR does not address the traffic bottleneck on Atlanta Ave. east of the project. The obvious solution is to widen Atlanta between HBT-8 Huntington and Delaware. This will be controversial and costly but necessary to mitigate the problem. MM TR-3 Additional bus stop locations and foot traffic paths must be HBT9 clearly defined to accommodate the amount of anticipated use. MM TR-3 It should be clearly noted in the DEIR that the Hamilton Ave. extension and the Santa Ana River Crossing at Banning/19`h Street are projects HBT-10 that are unbudgeted, unwanted by the residents and whose futures are very much in doubt. Section 3.15 - Utilities and Service Systems The Orange County Sanitation District discharges waste southwest (of the HBT-11 mouth) of the Santa Ana River, not north as stated in Wastewater Services. Edward Kerins President Huntington Beach Tomorrow 3-29 fitORANGE COUNTY COASTKRRPER 441 Old Newport Blvd. Suite 103 Newport Beach, California 92663 Office: (949)723-5424 Fax:(949)675=7091 Email:coastkeeperl@earthlink.net http://www.coastkeeper.org .a?`' ?Eta DEC 0 2 2003 December 1, 2003 Nary Beth Broeren Planning Department City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 RE: Comments on the EIR for the Pacific City development Dear Ms. Broeren The Orange County Coastkeeper is a non-profit organization with a mission to protect and preserve the marine habitats and watersheds of Orange County through education, restoration, policy advocacy, and enforcement. Our interest in this project Is to ensure that a state-of-the-art-water quality management plan is designed and implemented. Additionally, we want to see a plan implemented whereby no net increase of pollutants will be discharged from the site to the beach across Pacific Coast Highway. We have been meeting with representatives of the applicant and in , these initial stages of entitlement; they have been both cooperative and committed to develop such a plan. _ Orange County Coastkeeper has identified issues we feel are important to the - development of an appropriate water quality management plan. In reviewing the most recent EIR, we see significant changes in the storm water.discharge points of the project. The current water quality plan shows-the majority of area (26.9 of the 34.6 acres)draining from the project to First Street, under PCH, and discharging OCC-2 onto the beach. We are concerned the applicant has chosen to discharge the majority of runoff directly onto the beach rather than discharging along Atlanta Avenue, upgrading the pump station, and ultimately the Talbert Marsh. In light of 4 this major alteration in the water quality plan, it is essential that the applicant 1 adhere to a higher standard of treatment rather than the ordinary employment of "Best Management Practices"(SMP's)stipulated in the Drainage Area Management Plan (DAMP)and the City's regulations. We feel there are issues that must be addressed and components that must be included in an appropriate and sophisticated water quality management plan: 0CC-3 3-30 I) Talbert Marsh: The plans call for runoff to be discharged to the Talbert Marsh, an analysis of the treatment capacity of the Talbert Marsh should be completed. It is essential there be assurances that appropriate deansing occ-a capacity exist.The residence time, area, flora, and water volumes must be calculated and proven effective in order to ensure true natural treatment as a Best Management Practice. —i 2) The project indudes storm water storage facility, which is necessary to meet as a minimum standard.the 85th percentile requirement of the storm water permit, and the City's 20 c.f.s. discharge limitations onto the beach. occ-5 Coastkeeper urges the City to make certain the sizing of the water storage facility (0.82 acre-feet) is adequate to attenuate flows that exceed 20 c.f.s. 3) Coastkeeper believes the City is missing an opportunity to enhance water quality of urban runoff by not entering into an agreement with applicant to collect and treat runoff from the surrounding developed downtown area adjacent to the project. Now is the opportunity for the City to be innovative. occ-6 A plan could be negotiated with the applicant that would drain a section of downtown area flows through the applicant's filtration facility to improve the water quality before discharging it onto the beach. _. 4)The City should carefully consider the potential utilization of the small vacant City-owned lot at First Street and Atlanta Avenue for underground storm water storage before treatment. A metered -parking lot could easily be Constructed at grade. With this facility, the City and the applicant, by mutual agreement, could collect storm flows from the downtown area then slowly OCC-7 release the water through the applicant's filtration facility before it is discharged onto the beach. By over-sizing the facilities that discharge to First Street, the City and the applicant both have the potential to develop an arrangement whereby all parties benefit. 5) For low flow discharges from drainage area"A"that are to be diverted to the Orange County Sanitation District, there should be a long-term agreement occ-8 between OCSD and the applicant and/or City for such a diversion. 6) It is our strong conviction that water discharged via First Street storm drain for discharge onto the beach MUST be treated to higher levels than those specified in the stormwater permit. AIL water discharged onto the beach across from First Street should be treated so that common pollutants found in occ-9 urban runoff such as metals, nitrates, oils and grease, including bacteria, are removed. We support the use of Stormwater Management media filters for removal of metals and hydrocarbons, however, ozone or ultraviolet treatment devices are needed to accomplish bacteria removal. Water storage facilities are necessary to collect water from high intensity occ io 3-31 • • peak storm flows so water can be released through these filtering devices at A a slower rate of 20 c.f.s. ocC 10 7) The beach is the City's major economic engine. Coastkeeper believes ANY discharge onto a beach that accommodates heavy recreational uses should occ-11 meet the numeric standards of the California Toxics Rule (CTR) and additionally treat to remove bacteria. _ 8) We suggest a monitoring program for both construction and post construction phases of the project. The applicant should develop an aggressive Storm Water Pollution Prevention Plans(SWPPP)and the City should both monitor and enforce the SWPPP. There should be post oCC-12 construction monitoring for a period of at least three years, preferably five years, to ensure the overall water quality management plan is effectively working and meeting the CTR standards. 9) Currently, only 7.7 acres of the 34.6 acre project is planned to discharge through the Atlanta Storm Water Pumping Station and diverted to the Orange County Sanitation District during non-storm low flow periods. The larger 26.9 acre drainage"B"will receive no diversion. This is more reason to highly OCC-13 treat the more polluted low flows at the First Street discharge. In summer months with high recreational use on the beach, the bacteria as well as all other typical urban pollutants must be removed before any discharge to the beach occurs. —1 10)The ER (3.8-21)states,"Flows exceeding attenuation limits would be allowed to run off via surface streets, and the drainage study has indicated that the volume of this run off would not impact drainage systems or flood traffic lanes." This statement is saying that the difference between a 25-year OCC-14 storm event and a 100-year event will be discharged onto the surface streets along First Street and will not cause an impact to either the drainage systems or traffic lanes. Coastkeeper finds it difficult to agree with this statement and would like to see the study proving there would be no impact from discharging large flows onto First Street and into PCH. Coastkeeper realizes some of the components we are suggesting are difficult to implement and go beyond what current regulations dictate. If the City is truly committed to water quality and innovation, it will give serious consideration to • what is best for Huntington Beach and the milliOns who recreate on the beaches, oCC-15 rather than what is the"maximum extent practicable"(MEP). We interpret MEP as"the least for the cheapest". This project is virtually on the beach, not miles inland,therefore, the standards you apply must take into account that these are direct discharges into the ocean. } 3-32 tr • Our conversations with the applicant have certainly given us the impression that they stand willing to develop such a water quality plan, with the only condition being that the final plan is fair. We challenge the City to creatively design a water quality management plan that goes the extra mile to ensure coastal water occ 1 s protection. The water quality plan described in this EIR is, in our opinion, very inadequate given its proximity to Huntington Beach's fragile economic engine and delicate coastal resource. Thank you for your consideration. Sincere! , 10P(/ 7-6-id),WYN - any : . Execu�. - ''irector 3-33 ■ PRIVATE ENTITIES • LEWIS BRISBOIS BISGAARD & SMITH LLP '�=° : LOU.) ATTORNEYS AT LAW 650 TOWN CENTER DRIVE, SUITE 1400, COSTA MESA, CA 92626 PHONE: 714.545.9200 I FAX: 714.850.1030 I WEBSITE: www.lbbslaw.com FRANK BRUCCULERI December.3, 2003 DIRECT DIAL:714.668.5512 E-MAIL:brucculeri@lbbslaw.com it VIA MESSENGER _ _ City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 Attn: Mary Beth Broeren Re: Public Comments Re Pacific City DRAFT Environment Impact Report Dear Ms. Broeren: We have been retained by South Coast Angus, LLC ("South Coast")to lodge formal public comment with the City of Huntington Beach("the City") in response to the City's invitation to provide public comments regarding the Pacific City Draft Environmental Impact Report("EIR"). You may recall that we attended the November 13, 2003 public meeting, scheduled by the Planning Commission for the City of Huntington Beach, and we placed, on the audio-taped record, public comments regarding the draft EIR, specifically referencing LBBS-1 deficiencies in section 3.5 [Energy and Mineral Resources] of the draft EIR and the incorporated appendices referenced therein. This serves to further memorialize and delineate the comments we made at the November 13 meeting, and now does so formally on behalf of South Coast. A. FUNDAMENTAL DEFICIENCIES IN THE DRAFT EIR 1. Summary of Inadequacies of Section 3.5 of the EIR [Energy and Mineral Resources] LBBS-2 In direct contradiction of the City's Municipal Code and zoning laws, the EIR proposes to eliminate direct access to Oil Overlay C at the proposed Pacific City development site. The zoning laws of the City and the City's Municipal Code established the mineral rights of the City and private mineral owners to the minerals found at the region in the City, designated as Oil v Los ANGELEs SAN FRANCISCO SAN Dim) COSTA MESA SAN BERNARDINO SACRAMENTO NEW YORK LAS VEGAS 213 250.1800 415.362.2580 619.233.1006 714.545.9200 909.387.1130 916.564.5400 212.232.1300 702.366.9212 4829-3008-1536.1 3-35 LEWIS BRISBOIS BISGAARD&SMITH LLP December 3, 2003 Page 2 Overlay C. The proposed Pacific City development, through the draft EIR, seeks to repeal the n agreements reached between the City,the State of California and the California Coastal Commission and the statutory mandate of section 4.14.03 of the Downtown Specific Plan and Chapter 15.50 of the City's Municipal Code, specifically the consolidation of the City's oil fields and authorized direct access points in the City to the Huntington Beach oil field. The proposed alternative to direct oil production access at Oil Overlay C, by the EIR, is slant drilling at LBBS-2 another region not identified in the EIR-- in the City. The slant drilling, as proposed by the EIR, effectively and absolutely bars direct access to Oil Overlay C, as intended by the City's Municipal Code and zoning laws. Indeed, glaringly absent from the EIR is any discussion of how the proposed slant drilling preserves the legislative intent of, and complies with section 4.14.03 of the Downtown Specific Plan and Chapter 15.50 of the City's Municipal Code, and how the proposed slant drilling is a safe, effective and feasible alternative to the existing laws of the City by providing direct access to Oil Overlay C. _ Without any detailed, or authoritative analysis,the EIR proposes slant drilling at an unidentified location in the City in an apparent effort to satisfy the statutory requirements of section 4.14.03 of the Downtown Specific Plan and Chapter 15.50 of the City's Municipal Code, and in an apparent attempt to mitigate the potential specter of claims that slant drilling constitutes LBBS-3 an unlawful taking of the mineral rights of private mineral owners. More disturbing is that the proposed slant drilling belies established black letter law, that the mineral estate owner is the dominant estate or tenement, and the surface estate owner is the subservient estate or tenement._j The EIR refers to an alleged"consultation" between the City's fire department the City's petro-consultant, Mel Wright, concerning the feasibility of slant drilling"near"the project site, however, no discussion of the factors and concerns allegedly considered by Mr. Wright,to support his purported opinion that slant drilling was a feasible alternative to extracting mineral LBBS-4 resources directly on top of Oil Overlay C, is found in section 3.5 of the EIR or any of the appendices to the EIR. Surprisingly,the opinions and conclusions of the City's petro- consultant, Mel Wright, were not memorialized so as to provide credible support for the proposed alternative of slant drilling. 2. General Comments At the November 13 meeting, the agents for EIP presented the public with three questions, as follows: • LBBS-5 1. Did the EIR capture the impact(s) of the Pacific City project on the City? 2. Did the EIR address those impact(s) V 3-36 4829-3008-1536.1 LEWIS BRISBOIS BISGAARD&SMITH LLP December 3, 2003 Page 3 3. Did the EIR provide adequate mitigating alternatives to address the impact(s) of the Pacific City project on the City? LBBS 5 First, the scope of the public inquiry presented by the agents for EIP did not adequately address all phases of the impact on the mineral and energy rights of Huntington Beach mineral owners as the public inquiry EIP was limited to two phases of the project, (1) during construction, and(2) post construction. As such, the scope of EIP's public inquiry did not take into account the impact(s) on the City, its residents, and its resident business owners before LBBS-6 construction commences, and the impact(s) on Oil Overlay C. As designed and currently proposed to the City, the Pacific City project completely covers Oil Overlay C, and does not provide direct access for oil production from Oil Overlay C. The EIR suggest that oil production may be accessed by slant drilling, but fails to provide any meaningful analysis in support thereof. _ Second, the EIR does not sufficiently state, in any detail, an analysis outlining the proposed mitigating alternatives to the impact(s) of the Pacific City project on the energy and mineral resources available to resident mineral owners and the City, including but not limited to, LBBS-7 the potential wrongful taking of the Oil Overlay rights established by Chapter 15.50 of the City's Municipal Code, and why the proposed mitigating alternatives do not violate the City's zoning laws. In sum, while EIR recognized the purpose, and public policy of the City supporting the establishment of Oil Overlay C at page 3-15-4 of the EIR, it is resoundingly silent as to how the LBBS-8 rights of resident mineral owners will be preserved, as currently proposed. _._s 2. Conformity With The Chapter 15.50 Of The City's Municipal Code And Downtown Specific Plan, Section 4.14.03 It is unclear from the EIR that the City and/or the developer of the Pacific City project intend to comply with Chapter 15.50 of the City's Municipal Code, specifically §15.50.010. Section 15.50.010 established the intent of the City, along with the intent and agreement of the State of California and the California Coastal Commission, to consolidate the oil operations in LBBS-9 and around the City and off the shores of the City. The EIR does not provide any analysis as to how the City and/or the developer intend to comply with § 15.50.010 of the Municipal Code, or if it does not comply, how the violation should be mitigated. a. Was it the intent of the City, through the passage of Chapter 15.50, to consolidate the oil production/operations throughout the city by reducing access to the Huntington Beach oil field by establishing three (3) primary access points at Oil Overlay A, Oil Overlay B and Oil Overlay C? _ 3-37 4829-3008-1536.1 LEWIS BRISBOIS BISGAARD&SMITH LLP December 3, 2003 Page 4 The EIR fails to explain, in any detail, how the proposed mitigating alternative of"slant drilling" at site separate and apart from the location of Oil Overlay C conforms with section 4.14.03 of the Downtown Specific Plan, and Chapter 15.50 of the City's Municipal Code. b. Does the City intend to enforce section 4.14.03 of the Downtown Specific Plan, and Chapter 15.50 of the City's Municipal Code, and thereby preserve the rightful access of resident mineral owners to Oil Overlay C? LBBS-10 c. If so, then does the City intend to require the developer of Pacific City to set aside at least 2 acres at the Pacific City site pursuant to the requirements of section 4.14.03 of the Downtown Specific Plan? Impact EM-3 of the EIR, at page 3.5-10, shows that as currently proposed, the Pacific City plan does not propose or allow for existing and/or expanded oil production on the property as required by section 4.14.03. Section 4.14.03 specifically requires, "[t]he [conceptual site] plan shall include at least one(1) oil island of not less than two (2) acres in size for new oil well drilling and oil production. Such LBBS-11 island(s) shall be incorporated into the overall development plan so that noise, odor and visual impacts on the residences are minimized, and safe access to the oil site(s) is provided. Findings that at least one such island so designed is incorporated into the plans shall be made by the Planning Commission before approving any development project." The EIR does not address how the proposed Pacific City project provides for a two (2) acre oil island over Oil Overlay C, and as statutorily mandated by section 4.14.03. d. Was it the intent of the City, through the passage of section 4.14.03 of the LBBS-12 Downtown Specific Plan, to preserve subterranean direct access to the minerals in the Huntington Beach oil field by designating Oil Overlay C? • e. Prior to, or at the time of the City's decision to approve the location of Oil Overlay C, did the City consider the geological and engineering impact(s) on the residents of the City and the City by establishing a region of the LBBS-13 Huntington Beach oil field, such as Oil Overlay C? If so, what were the potential impact(s) considered by the City? _ Appendix A of the EIR, at page 22, recognizes the potential significant impact(s) and value of the mineral resources that are located in the region of the City designated as Oil Overlay 3-38 4829-3008-1536.1 LEWIS BRISBOIS BISGAARD &SMITH LLP December 3, 2003 Page 5 C. The text of section 3.5 of the EIR, however, obliquely references Appendix A, but then fails h connect its application to the discussion set forth in the EIR. LBBS.14 f. Was public safety a factor in the City decision-making analysis when it considered creating direct access to the Huntington Beach oil field at the LBBS-15 regional location designated as Oil Overlay C? — g. If the City approves the Pacific City plan as currently proposed, is it the intent of the City to preserve the designated Oil Overlay regions, specifically Oil Overlay C, as established by section 4.14.03 of the Downtown Specific LBBS-16 Plan and Chapter 15.50 of the City's Municipal Code? And,how will it comply with section 4.14.03 of the Downtown Specific Plan and Chapter 15.50 of the City's Municipal Code? — h. If the City intends to approve the Pacific City plan,including EIP's proposal of slant drilling at an unknown site in the City, then how does the LBBS-17 City intend to comply with section 4.14.03 of the Downtown Specific PIan and Chapter 15.50 of the City's Municipal Code? As currently proposed in the EIR,there is no detailed analysis as to how the Pacific City project intends to preserve the legislative intent of section 4.14.03 of the Downtown Specific Plan and Chapter 15.50 of the City's Municipal Code City insofar as it relates to the preservation of the Oil Overlay C, or how it intends to preserve the historical agreements between the City, LBBS-18 the State of California, and the California Coastal Commission relating to Oil Overlay C, as embodied by section 4.14.03 of the Downtown Specific Plan and Chapter 15.50 of the City's Municipal Code. B. MISLEADING AND FALSE REPRESENTATIONS IN THE EIR 1. Misrepresentations of Purported Statements by Mel Wright That Other Sites Are Available The EIR indicates Mel Wright, referred to in the EIR as the City's Consultant, that there LBBS-19 are off site locations that one can drill from to reach the minerals under the Pacific City property, so that, in Pacific City's opinion, thought wrongly implying it is Mr. Wright's opinion, it is no longer necessary to reserve such natural resource production site as called for in Natural Resource Overlay C and previously approved by the State Land Commission, Coastal Commission, and the.City. — 3-39 4829-3008-1536.1 LEWIS BRISBOIS BISGAARD &SMITH LLP December 3, 2003 Page 6 a. However,in our discussions with Mr.Wright,he indicated that he never spoke to the Pacific City representatives, and the last work he remembers performing as a consultant for the City of Huntington Beach, in the early 1990s, was surveying for possible drilling locations in the LBBS-20 Huntington Beach Onshore Area, without regard to any"01" zoning (oil production and new drilling, such as the approved overlays here). Mr. Wright never indicated there were any other"01" zoning, and instead has informed us that there are no other possible"01" locations in the area. b. Even moving across the zoning street to an existing"0" only site (existing production),would require obtaining approval from various state LBBS-21 agencies, to approve any further drilling from the existing site, plus the unit operator of the majority of units mineral rights. c. The nearest other alternative site is more than a mile and half away, many thousands of feet away, while the minerals in the area are as shallow as 500 feet. This would require not just directional drilling,but almost pure LBBS-22 lateral drilling. The costs of drilling such a well are not economically reasonable or feasible. _j d. Since the 1920s, there have been regulations on where and when to drill, ending with residual locations, agreed to by all responsible agencies in the State of California and the City,including the"01" zoned Resource LBBS-23 Overlay here in question. Thus, contrary to the "opinion" of Pacific Cities, as stated in the EIR, the Resource Overlay in question here is the ONLY economically feasible drilling site in the area that is LBBS-24 currently so approved by the responsible state agencies. 2. Misrepresentations that Build-Up of Underground Natural Gas in the Area Is Purportedly Insignificant The EIR wrongly suggests there are no significant amounts of methane in the area to be remediated. This is incorrect. LBBS-25 a. The closest existing active oil well has reported build up pressure caused by natural gas, on the casing side of the well, that exceeds 1000 lbs per square inch, within several hours of the well being shut in,indicating very significant natural gas pressures remain in the reservoir. 3-40 4829-3008-1536.1 LEWIS BRISBOIS BISGAARD&SMITH LLP December 3, 2003 Page 7 b. The decades of oil production has created pressure voids, and in those pressure voids,natural gas escapes solution and fills those pressure voids, building up significant pressures as more and more gas escapes from its natural solutions in liquids such as water, due to the low pressure. Local LBBS-26 conditions then allow these pockets of natural gas to easily migrate to the surface, and once there, they become potentially explosive—such as the occasional explosions and fires in the Los Angeles Fanners Market area. d. This potentially dangerous problem is remediated by injecting liquids such as water into the gas pockets voids. The more dense liquid forces the LBBS 27 natural gas in the pockets back into suspension within the liquid, as the liquid fills those pockets. — This injection remediation requires an active drill site, such as the"01" zoned site in question here. The loss of the site will mean the loss of any feasible, meaningful opportunity to LBBS-28 remediate this potentially significant problem for the residents of the City. 3. Implicit Misrepresentation that Existing Mineral Owners Will Not Be Denied Access to Very Substantial, Multi-Million Dollar Mineral Reserves The EIR implicitly represents to the existing mineral owners that they will be able to capture their very valuable (multi-million dollar) mineral rights. Those mineral owners include not only voting tax payers within the City but even the City itself (which could, e.g., help fund schools as done in Beverly Hills). a. As discussed above, there are no other zoned, approved, feasible, economical drill sites in the area,zoned as "01". I LBBS-29 b. The regulation of oil and gas production and the Natural Resources Overlay concept was designed as a compromise between mineral owner's and the surface owners. Mineral owners normally own the "dominant tenement", which would otherwise control over the rights of all the surface owners. Thus the creation of the Overlays was intended as a compromise, to allow substantial surface development, while reserving sufficient surface area for use by the dominant tenement mineral owner's to drill for and produce the minerals. Thus, loss of this sole remaining site is would mean City will have denied the existing mineral owners their constitutional right to property, without providing just compensation. 3-41 4829-3008-1536.1 LEWIS BRISBOIS BISGAARD&SMITH LLP - December 3, 2003 Page 8 In conclusion, we are happy to meet with the City or anyone else concerned to discuss in EBBS 30 more detail these and other relevant points related to this development. V ruly yours, C. rank Brucculen of LEWIS BRISBOIS BISGAARD & SMITH LLP LMK 3-42 4829-3008-1536.1 OEG GE Orosz Engineering Group,inc. 1627 Calzada Avenue Santa Yner,California 93460 Phone/FAX B05-608-7814 email oeg@quixnet.net OEG Reference 120203 December 3, 2003 Honorable Members of the Planning Commission Via FAX 714-374-1540 c/o Ms. Mary Beth Boreren City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 _ _ Subject: Pacific City EIR Dear Planning Commission Members: On behalf of the Pacific City Action Coalition, Orosz Engineering Group, Inc (OEG) has conducted a preliminary review of the subject project traffic analysis contained in section 3.14 of the EIR, and Appendix H of the EIR. OEG(A)-1 Our review noted two areas of interest: Trip Generation Reductions and Shared Parking II Analysis. The following comments are made with respect to these two issue areas. Trio Reduction Methodology No supporting information was provided to document how the hotel, office, retail/restaurant, and residential uses could result in the trip reductions listed in Table 3.14-10. The missing technical data was noted to be available at the City, but the City Clerk provided the same information (a note stating that the information was available at the City)that was available on- line.The note also indicated that the parking analysis was updated in October 2003. Whether OEG(A)-2 the most recent data was used in the EIR analysis is unclear. Without reasonable documentation for this information, the reductions should not be taken. The analysis may underestimate the potential impacts of the proposed project. Additional information on the trip reductions is necessary and should be available for public review. Shared Parking Analysis Based on the limited data available, there are adjustments that impact the shared parking analysis due to the seasonal variation in parking demands that are not addressed. It is not OEG(A)-3 clear from the EIR analysis if the peak parking demand noted is for a summer weekday or summer weekend day. This should be clarified. Further, a net surplus of 8 parking spaces in a total of 1543 spaces or 0.5% is not reasonable. Parking studies have shown that a parking facility appears full to a driver at 85-90% occupied. OEG(A)4 With this in mind and the uncertainty of the reductions for interaction with off-site uses,the parking proposed is approximately 150 spaces short at peak times. In a beachfront U 3-43 • Honorable Members of the Planning Commission c/o Ms. Mary Beth Boreren December 3, 2003 Page 2 A environment, parking shortages are problematic and could lead to residential neighborhood parking intrusion. This issue should be clarified or addressed in the final environmental analysis OEG(A)-4 or if not remedied, a significant environmental impact should be identified. Clarification of these two issues is requested to be available for public review. When the data is— available, another public review period should be noticed. OEG(A)-5 Should you have any questions regarding this information, please contact us. Sincerely, I() - Stephen A. Orosz, PE, OE _I Orosz Engineering Group, Inc • • • • • 3-44 0 Its Grosz Eegineer:rrg&r00.0,ln(- 1627 Caltada Avenue Santo Vncz.California 93460 Phone/FAX 805-688-78'4 retail e:gh.quiznet.net OEG Reference 120203 December 4, 2003 Honorable Members of the Planning Commission Via FAX 714-374-1540 c/o Ms. Mary Beth Boreren City of Huntington Beach 2000 Main Street Huntington Beach,CA 92646 Subject: Pacific City EIR Dear Planning Commission Members; On behalf of the Pacific City Action Coalition,Orosz Engineering Group, Inc(OEG) has conducted a preliminary review of the subject project traffic analysis contained in section 3 14 of the EIR,and Appendix H of the EIR,and detailed information not made available to the general public but provided by the document preparer. This letter is an update to that submitted on December 3, 2003, with additional issues generated by the review of the technical OEG(B)-1 information in Appendix C of the Traffic Study and pages 69,70&71 of the traffic study. This information was not readily available and had to be obtained from the document preparer, Linscott, Law&Greenspan. The data became available to us on December 3, 2003 at 4:52 PM. Our review noted two areas of interest:Trip Generation Reductions and Shared Parking Analysis. The following comments are made with respect to these two issue areas. Trip Reduction Methodology — No supporting information was provided to document how the hotel, office, retail/restaurant, and residential uses could result in the trip reductions listed in Table 3.14-10. The missing technical data was noted to be available at the City,but the City Clerk provided the same information(a note stating that the Information was available at the City)that was available on- OEG(B)2 line.The note also indicated that the parking analysis was updated in October 2003. After additional research,the missing technical data was provided by the Engineering firm of Linscolt, Law&Greenspan. Whether the most recent data was used in the EIR analysis is unclear. Without reasonable documentation for this information,the reductions should not be taken. The analysis may underestimate the potential impacts of the proposed project. Additional information on the trip reductions is necessary and should be available for public review. receipt of the tripreduction flow mapfrom the traffic engineer,we have reviewed the After 9 assumptions used in the analysis. The trip reduction flow map has two components—Internal OEG(B)-3 Capture and Mode Shift. The Internal Capture trip reduction percentages seem reasonable given the size of the project. However,the mode shift or draw from existing traffic sources \./ 3-45 • Honorable Members of the Planning Commission c/o Ms.Mary Beth Boreren December 4, 2003 Page 2 adjacent to the site seems too high. What the percentages used in the analysis assume the /\ following: Hotel Traffic—Every day 80 of the 400 rooms are filled from people already in the vicinity. This traffic would include employees and guests. This seems to be extremely aggressive. Retail/Restaurant—Every day 35,000 square feet of space is used by people already in the vicinity This is the equivalent of seven fast food establishments or two sit-down type restaurants. This seems to be overly aggressive. Residential—Every day the tenants in 52 of the 516 housing units would work within OEG(B)-3 walking distance of off-site destinations. Conservatively speaking this would mean that about 100 people would walk to work from the site to of site establishments. This does not make sense. - 1 Office—Every day 6,000 square feet of office space is utilized by people living in the i immediate vicinity and walking to work on-site. While some synergy may occur with unmet existing travel demands from existing off-site uses, the percentages used in the traffic analysis seem overly aggressive and underestimate the potential traffic impacts to the adjacent road system. Unless the assumptions are backed-up with some reasonable supporting data,the trip reductions for the mode shift should be removed from the analysis and the intersection impacts reassessed. Additional mitigation measures may be required to mitigate the additional traffic trips. Shared Parkin Analysis — Based on the limited data available, there are adjustments that impact the shared parking analysis due to the seasonal variation in parking demands that are not addressed. It is not OEG(B)-4 clear from the EIR analysis if the peak parking demand noted is for a summer weekday or summer weekend day. This should be clarified. _ The initial reduction of the City parking codes for the Retail, Restaurants, and Hotel operations are reasonable. It is logical for the customer driven uses to have some interaction with other similar uses in the vicinity,however, the reduction in parking demand for office uses does not OEG(B)-5 make sense. A more reasonable analysis would not include a reduction for office parking demands, unless documentation is provided to support the reduction. _ The shared parking detailed analysis provided by the traffic consultant was reviewed and OEG(B)-6 appears to be consistent with accepted practices for shared parking analysis. However,a net surplus of 8 parking spaces in a peak demand total of 1543 spaces or 0.5% is not reasonable. Parking studies have shown that a parking facility appears full to a driver at 85-95%occupied. The effective parking supply is the peak parking demand plus 5-10%of the OEG(B)-7 total. This factor reduces the need to search the entire system for the last available spaces. It also allows for operating fluctuations,vehicle maneuvers and vacancies created by reserving V 3-46 ti Honorable Members of the Planning Commission c/o Ms.Mary Beth Boreren December 4,2003 Page 2 spaces for certain users,and make s up for losses attributable to mis-parked vehicles, etcl. /\ With this in mind and the uncertainty of the reductions for interaction with off-site uses, the parking proposed is approximately 75-225 spaces short at peak times. In a beachfront OEG(B)-7 environment, parking shortages are problematic and could lead to residential neighborhood parking intrusion. This issue should be clarified or addressed in the final environmental analysis or if not remedied,a significant environmental impact should be identified. _ Clarification of these issues is requested and should be made available for general public review. After the general public has had adequate time to review the data available,another public review period should be noticed. OEG(B)-8 Should you have any questions regarding this information, please contact us. Sincerely, Stephen A. Orosz, PE, PTOE Orosz Engineering Group, Inc ' The Dimensions of Parking,Fourth Edition,Page 29,Urban Land Institute,2000 3-47 ♦ L Oa 1.i Pacific City Action Coalition 16787 Beach Blvd.,#316 Huntington Beach, Ca 92647 December 3,2003 Ms. Mary Beth Broeren City of Huntington Beach Planning Department 2000 Main St. Huntington Beach, CA 92648 Re:Pacific City Environmental Impact Report No. 02-01 Response Dear Ms.Broeren: Enclosed is the Pacific City Action Coalition's response to the Pacific City Draft Environmental Impact Report.Included in the response are consultant comments from the Urban Planning and Consulting Group and Dr. Matthew Macleod,which are included in the body of the response and Attachment A.Additional comments from Coalition members are contained in Attachments B and C. PCAC-1 If you have any questions,please call(714)430-8596.Thank you for the opportunity to comment on this matter. This letter is being sent via fax,email and hand delivery this date. Sincerely, •e 4-12,6 acific City Action Coalition 3-48 8 Via De La Mesa Rancho Santa Margarita, CA 92688 (949) 233-1814 n (949) 459-1620 November 26, 2003 Pacific City Action Coalition 16787 Beach Blvd., #316 Huntington Beach, CA 92647 RE: Response to the Pacific City Draft Environmental Impact Report No.02-01 We have reviewed the Draft Environnierital Impact Report for the Pacific City project and present the following comments and observations. Project Description The project is a mixed-use visitor-serving commercial center together with a residential village located on a 31.5-acre vacant parcel in the City downtown on the inland side of Pacific Coast Highway. Major project components include: Visitor-serving Commercial Center This component would occupy approximately 10.6 acres of the site adjacent to PCH and provide hospitality and commercial facilities. Upscale-oriented hospitality facilities (hotels) would include up to 400 guest rooms and associated amenities, and up to 240,000 square feet of commercial uses that could include retail, office, restaurant, cultural and entertainment facilities. Approximately 2 to 8 story buildings are proposed on this site, consisting of 8-story hotel and 2 to 3 stories of retail and office uses. PCAC-2 • Residential.Village The residential component would occupy the approximately 17.2-acre northeastern portion of the project site. A total of 516 condominiums would be developed at an average of 30 dwelling units per acre. Development would include 2- to 4-story structures with a variety of architecture, dwelling unit types and sizes, clustered.around recreational amenities to serve the residents of the village. Parking would be provided in a subterranean garage and in surface parking areas along the interior collector street. Vehicular and Pedestrian Circulation Improvements Vehicular and pedestrian access to the project site would be provided by a combination of existing and proposed roadways. Pacific View Drive would be extended through the site in a 90-foot right of way. On Huntington Street, between Pacific View Drive and Pacific Coast Highway, additional right of way would be dedicated west of the centerline to allow for the full secondary arterial right of way with sidewalks and curb and gutter V 3-49 • EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26,2003, Page 2 improvements. On Atlanta Avenue, between 1st Street and Huntington Street, additional right of way would be dedicated south of the centerline to allow for arterial improvements. Setting Project Area is bounded by 1st Street on the west, Huntington Street on the east, Atlanta Avenue on the north, and Pacific Coast Highway to the south. The project site is also located within the California Coastal Zone and the Main-Pier Redevelopment Project Area. The project would be constructed in major phases over a two- to ten- year period, beginning in 2004. _The project site is currently vacant, although construction activities and various land uses on the project site have occurred since the late 1800s. Southern California Edison currently maintains aerial transmission lines along the 1st Street property boundary and regional 66KV transmission facilities along the Atlanta Avenue site boundary. On-site oil facilities have been abandoned and soil remediation is underway, with completion expected in 2003. A portion of the southwesterly corner of the site was recently used as a staging/storage facility for beach cleaning equipment for the City of Huntington Beach. The site is no longer used for this purpose, although a storage bin remains on the property. PCAC-2 As of 1999, a portion of the site was listed as an archeological resource (ORO-149). resources. Portions of the site may contain paleontological esou ces. Remediation In 1996, prior to the acquisition of the site by Atlanta Huntington Beach, LLC, Shea Vickers development, LLC, the prior owner, initiated an extensive site investigation and subsequent oil remediation program. Remediation of the site was performed pursuant to a Remediation Work Plan approved by the Huntington Beach Fire Department and included excavation and stockpiling of oily soil and the abandonment of several oil wells. In March 1998, an application was filed by Shea Vickers Development, LLC for a Coastal Development Permit to allow remedial grading of the property to remove oily soils and to import approximately 23,630 cubic yards of soil. This request was tabled and was not acted upon by the Zoning Administrator. CEOA In January 2003, the City of Huntington Beach issued a Notice to Prepare an Environmental Impact Report. Citing CEQA Section 15183(a), an EIR has been prepared for the project. The EIR addresses impacts related to aesthetics, air quality, biological resources, cultural resources, energy and mineral resources, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services and utilities, recreation, transportation and traffic, and utilities and service systems. V 3-50 City of Huntington Beach-Pacific City 2 The Urban Planning Consulting Group • EIR for Pacific City Project EIR'No.02-01 SCH No.2003011024 November 26,2003, Page 3 Protect Objectives Several objectives were identified for the project; they include: 1. Assist in the implementation of the City's General Plan, downtown specific plan, and redevelopment.plan. 2. Enhance the downtown area as a destination for visitors by expanding hotel, retail, and entertainment opportunities. 3. Expand residential opportunities in the downtown to provide for a greater number and variety of housing options and a stronger base for the commercial sector of the downtown. 4. Enhance the community image of Huntington Beach through design and construction of high quality development consistent with the urban design element of the General Plan. 5. Ensure adequate utility infrastructure and public services for new development. 6. Mitigate environmental impacts to the greatest extent possible. PCAC-2 Analysis The following project related impacts were considered significant and unavoidable in the EIR: 1. Air Quality 2. Transportation — under the Year 2008 conditions, project would significantly affect the operating conditions of the intersection of PCH &Warner Avenue and PCH at Seapoint by increasing traffic volumes. Project Alternatives Three project alternatives were considered; they are: 1. No Project Alternative/No Development 2. Reasonably Foreseeable Development 3. Reduced Project Alternative, which would reduce the commercial component of the proposed project and is considered by the EIR as environmentally superior alternative to the project. J Project Impacts PCAC-3 V 3-51 1 __ City of Huntington Beach—Pacific City 3 The Urban Planning Consulting Group ' , EIR for Pacific City Project - EIR No.02-01 SCH No.2003011024 i November 26,2003, Page 4 The analysis provided in the EIR for the following topics are considered weak: 1'PCAC-3 '_ Air Quality, This section omits an important threshold of significance required by CEQA, which is the creation of objectionable odors affecting a substantial number of people. If this threshold of significance were PCAC 4 analyzed, the impacts could be considerable significant and would change the complexity of the conclusions derived from the project. _ This section also fails to analyze the environmental impacts of paint and other solvents that may be 1 i used during post construction of the site. Most air quality analyses have standard conditions dealing with this issue, including type of paint to be used on buildings and the quantity that can be painted PCAC-5 on a daily basis. Most importantly, the proposed mitigation measures are weak and inadequate for a project of this magnitude. A more thorough air quality analysis needs to be prepared, including the environmental PCAC-6 effects of this project's pre-, during-, and post-construction impacts on surrounding land uses (the mobile home park) and other sensitive receptors. — For additional comments,see Attachment A PCAC-7, Cultural Resources, 1 Because of the paleontological discoveries on the site, and potential for archaeological discoveries) I the site contains a California prehistoric archaeological site CA-ORA-149), adequate mitigation pCAC-8 measures need to be in place to prevent annihilation of any precious paleontological or archaeological artifacts. These mitigation measures should include standard, acceptable measures widely used in the industry. • Energy and Mineral Resources. The project site is located within the Huntington Beach Oil Field and is designated as District No. BA by the Downtown Specific Plan. The site is also identified as an oil overly "C" district to allow for existing and/or expanded oil production on the property. A Phase II environmental analysis and aerial maps of the site identified 10 aboveground storage PCAC-9 tank, pipelines, 20 abandoned oil wells, and abandoned water well. The proposed project would , result in the development of residential uses on a portion of the site underlain by mineral resources. However, the only mitigation measure proposed under this section pertains to an energy conservation plan. No mitigation measures are proposed for handling the oil and water walls identified on the site. At a minimum, this EIR should identify a contingency plan for dealing with the potential discovery of oil wells and water wells. 3-52 City of Huntington Beach-Pacific City 4 The Urban Planning Consulting Group EIR for Pacific City Project - ' EIR'No.02-01 SCH No.2003011024 November 26,2003, Page 5 Geology and Soils. Groundwater was encountered at depths ranging from 5 to 24 feet below ground surface on this PCAC-10 site. The site is also located within a methane overly district in the City's General Plan. A soils testing plan is therefore required as part of project implementation. There is a high potential for ocean-related corrosion to building materials due to the site's proximity to the Pacific Ocean (500 feet). Additionally, project implementation would locate structures on soils that are considered potentially expansive, unstable, prone to settlement, and corrosive. 15-20 feet of loose-to-medium dense alluvial deposits found in the southeastern portion of the site where the hotel and portions of the commercial development are proposed, are settlement prone. However, only one mitigation measure was proposed. This mitigation measure requires the grading PCAC 11 plan to include recommendations of a proposed soils and geotechnical analysis. This is not acceptable. The results of the soils and geotechnical analysis should be the driving factor in the location of buildings on the site. Mitigation measures need to be identified to deal with the issues related to expansive, unstable and corrosive soils. These measures need to be identified in the EIR and not in a separate document to be prepared in the future. For additional comments,see Attachment A J PCAC-12 Hazardous Materials. The project site was identified in the State of California Hazardous Materials Database. There is a potential for residual oil contamination in the soil and possible methane emissions. There are also unclosed oil wells and a site investigation has revealed the presence of oil-impacted soils with total recoverable petroleum hydrocarbon levels above allowable limits. There also is the presence of lead-impacted soil and methane gas accumulation on the site. The MM HAZ-1: This mitigation measure delays the findings of a potentially significant impact PCAC-13 to prior to issuance of a grading permit. The concern with this approach is that if PCB were detected, members of the public and other who have commented in this EIR would not be privileged to such information and the accepted method of remediation. Also, if the remediation delays the project or - causes a significant change in the project, the EIR would not have analyzed it and there is no avenue for the public to request preparation of adequate environmental documents to address the issue. — MM HAZ-2: Same comments as in MM HAZ-1, above. PCAC-14 MM HAZ-3: The public is entitled to the contents of the remediation plan proposed under this mitigation measure. This is delaying an impact to a future time convenient to the developer rather than the public. All related impacts of this project should be PCAC-15 disclosed now and adequate remediation recommended. The remediation plan V City of Huntington Beach-Pacc City 5 The Urban Planning Consulting Group 3-53 • ' , EIR for Pacific City Project -- EIR No.02-01 SCH No.2003011024 November 26,2003, Page 6 should be outlined in the EIR so that monitoring of the impact can be carried out is PCAC-15 conformance with CEQA. — For additional comments, see Attachment A j PCAC-16 Hydrology and Water. The project site has the potential to affect drainage facilities at the Atlanta Stormwater Pump Station and the First Street Storm Drain System. Potential water table contamination has not been adequately addressed. The EIR's position is that since the ground water in the vicinity of the project PCAC 17 site is not potable (due to possible salt contamination from the Pacific Ocean), this impact is not significant. Our contention is that water table contamination is an environmental concern regardless of the quality of the water. There are no mitigation measures proposed to address possible_ groundwater contamination. In addition, the EIR mentions an oily soil remediation process currently underway on portions of the project site pursuant to CUP 00-36 and Coastal Development Permit 00-09. However, the EIR fails to incorporate the recommendations or conditions of approval PCAC 18 of these discretionary actions into the EIR as possible mitigation measures. This is crucial since portions of the site in questions are critical to overall development of the project. The EIR should provide the link between these actions. For additional comments, see Attachments A and C I PCAC-19 Land Use and Planning. There are relatively few structures more than four-stories high along the waterfront I ! area. The proposed hotel would add an 8-story tower to the waterfront area. The proposed development would generate approximately 601 employees and 1,419 residents. The project includes land uses more intense than those surrounding the site and would increase development density of the area. The northerly portion of the site would be developed with high-density residential uses. The mobile home park located PCAC-20 to the east of the project site is developed at Medium Density with up to 15 units per acre, half of the density of the proposed development. The area is identified with one-story high building; the project proposes two-to-three story buildings in some areas and four-story buildings in others. The proposed 90-foot separation between the hotel and commercial areas and the residential area is inadequate based on the level of activity proposed within these uses. PCAC-21 This section of the EIR fails to address land use compatibility issues between existing i PCAC-22 developments within the project vicinity and the proposed project. Also, this development requires special permits to allow structures within. 50-foot front yard setback from PCH. Special permits are also required for front yard setback i PCAC 23 encroachment from Pacific View Avenue and for the parking garage ramps to exceed the City standard of 10%. The EIR did not disclose why these special permits are V 3-54 City of Huntington Beach—Pack City 6 The Urban Planning Consult*Group i • EIR for Pacific City Project - EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 7 necessary or recommend alternative designs to eliminate the need for the special PCAC-23 permits. Also, the EIR did not disclose what the proposed parking garage ramp PCAC 24 standard would be. Additional discussion is required in this area. The proposed project, density of 30 d.u. to the acre exceeds that of any existing development within vicinity i of the project. This impact is not thoroughly analyzed in the EIR and the conclusion : PCAC-25 that the proposed project would not substantially conflict with existing permitted uses' can be challenged. For additional comments, see Attachment B J PCAC-26 Noise. _ PCAC-27 It does not appear that the mitigation measure proposed in MM N-2 is adequate to address the noise impacts identified in the EIR. _I For additional comments, see Attachment C J PCAC-28 Population/Housing. The proposed project may not meet the City's affordable housing requirements. PCAC-29 Public Services. The proposed project would add residential and visitor-serving uses to the area, and would increase demands on police protection. Mitigation Measure MM PS-4 requires that prior to building permit issuance, the applicant consult with the Huntington Beach Police Department regarding the provision of adequate crime prevention design PCAC 30 measures. The stage prior to issuance of building permits is too late to implement any crime prevention design elements. This needs to the done at the planning stages or the design review stage to ensure that the recommendations of the Police Department are incorporated into project design. Recreation. - The City's total of 906.7 park acres fall short by 48.3 acres the identified ratio of five acres of park land per 1,000 persons. Project implementation would not provide adequate recreational facilities to meet increased demand from the project. PCAC.31 Mitigation Measure MM REC-1 does not include language that is clear as to what the obligations of the project proponent is in regards to parkland mitigation. Transportation/Traffic Based on the current parking problems within the project area, the use of an internal PCAC-32 capture/mode shift is unnecessary and undermines the understanding of the true impacts of this project on transportation, traffic and parking. City of Huntington Beach—Pacific City 7 The Urban Planning Consulting Group 3-55 , EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 1 November 26,2003, Page S Also, the use of a 1% growth factor in the volume of traffic at key intersections is too low to provide a true picture of conditions. A 2% or 21/2% factor would provide the PCAC-33 type of responses needed to truly analyze impacts. It is also not clear why the Future Year 2008 conditions with the proposed project are not different from the Future 2008 conditions without the project considering the PCAC-34 project contributes an underestimated 12,002 daily trips. No analysis was presented in the EIR to support the conclusion in Impact TR-8. The parking reductions proposed in.the EIR and the liberal use of off-site parking spaces for PCAC 35 the project masks the actual parking impacts of this development and does not aid in resolving the parking situation within the project vicinity. The use of parking demand reduction is not appropriate in this case because of the existing parking conditions within the area. There is a 20% City parking code reduction, a 15% retail parking reduction, and a 5% residential parking reduction for a PCAC-36 total proposed parking requirement of 1,482 spaces for all proposed uses. This is insufficient. For additional comments, see Attachments B and C 1 PCAC-37 Alternatives — _ The EIR identified three project alternatives - a no project alternative, a reasonably foreseeable alternative and the reduced project alternative. PCAC-38 The impacts related to the Reasonable foreseeable alternative were found to be more severe than the proposed project. The impacts of the reduced project alternative were found to be environmentally superior to the proposed project. The reduced project was also found to meet the proposed project goals and objectives and implementation would result in a project with significantly less impacts on the ' environment. This alternative will provide less visitor-serving commercial uses but PCAC-39 maintain the same level of residential development. This alternative is highly recommended. / 3-56 City of Huntington Beach—Pacific City 8 The Urban Planning Consulting Group , EIR for Pacific City Project - EIR No.02-01 SCH No.2003011024 November 26, 2003, Page 9 Conclusion In summary, environmental documents are informational documents required to provide detailed information on proposed developments and recommend adequate mitigation measures along with such disclosure. This EIR has not done a good job with recommending adequate mitigation measures to the project's identified impacts. PCAC-40 Sincerely, THE URBAN PLANNING CONSULTING GROUP For comparison, the following information was presented to the City as part of public comments on the notice of preparation of the EIR earlier this year. It is PCAC-41 clear that the recommendations in the comments have not been followed. Remediation, In 1996, prior to the acquisition of the site by Atlanta Huntington Beach, LLC, Shea Vickers development, LLC, the prior owner, initiated an extensive site investigation and subsequent oil remediation program. Remediation of the site was performed pursuant to a Remediation Work Plan approved by the Huntington Beach Fire Department and PCAC-42 included excavation and stockpiling of oily soil and the abandonment of several oil wells. In March 1998, an application was filed by Shea Vickers Development, LLC for a Coastal Development Permit to allow remedial grading of the property to remove oily soils and to import approximately 23,630 cubic yards of soil. This request was tabled and was not acted upon by the Zoning Administrator. CEOA In January 2003, the City of Huntington Beach issued a Notice to Prepare an Environmental Impact Report. Citing CEQA Section 15183(a), the EIR being prepared for the project is considered subsequent to EIR 82-2, which is a Program EIR for the Huntington Beach Downtown Specific Plan. According to Environmental Assessment PCAC-43 02-05, prepared by the City of Huntington Beach, the project site has been addressed on a programmatic level of part of the analysis included in several Program EIRs prepared by the City. These documents, in addition to EIR 82-2, include: The Huntington Beach General Plan Update EIR 94-9, and the Huntington Beach Redevelopment Project EIR 96-2. Existing Analyses Traffic PCAC-44 Linscott, Law &Greenspan, engineers, prepared a traffic impact analysis report for the Pacific City project in April 2002. The report concluded that the Pacific City project is expected to generate, ' V City of Huntington Beach—Pacific City 9 The Urban Planning Consulting Group 3-57 EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26,2003, Page 10 Phase I and II combined, 12,076 daily vehicle trips (one half arriving, one half departing), with A approximately 752 vehicle trips anticipated during AM peak hour (416 inbound, 336 outbound) and 1,122 vehicle trips (579 inbound, 543 outbound) forecast during the PM peak hour. According to the 2002 report, there are four related projects, identified from a list of 14 potential related projects provided by the City, which are included in the General Plan Update Analysis (The PCAC-44 Strand, The Waterfront Ocean Grand Resort, The Beachside Project, and The Boardwalk Project) in the City of Huntington Beach that could impact the key study intersections and roadways. The total forecast traffic generation for the related projects in the City of Huntington Beach is estimated at 25,750 two-way vehicle trips per day with 1,752 AM peak hour trips (802 inbound, 950 outbound) and 2,297 PM peak hour trips (1,320 inbound, 977 outbound). Proposed Improvements In conjunction with development of Pacific City, the project frontages of Atlanta Avenue, lst Street, and Pacific Coast Highway will be widened to accommodate anticipated traffic. Pacific View Avenue will be extended through the project from Huntington Street to 1st Street as a 52-foot roadway PCAC 45 within a 90-foot right-of-way. A traffic signal will be installed at the project access driveway on Pacific Coast Highway, at the existing median break, and two pedestrian bridges are proposed across PCH for improved access to the beach. Water Supply Assessment Hunsaker & Associates prepared a Water Supply Assessment for the Pacific City Development in November 2002. The City's public works department contracted with Tetra Tech, Inc, to perform a computer model hydraulic analysis of water services for the Pacific City project site and the surrounding area based on City Planning data, and data provided by the applicant. The analysis noted various water distribution system deficiencies resulting from the proposed project that will PCAC-46 require mitigation (in the form of infrastructure improvements), to meet the demands of, and for the benefit of the proposed project and the surrounding area. The report concludes that, upon completion of the improvements identified in the report, the City of Huntington Beach can provide adequate water supply for the proposed development, in accordance with the adopted Water Master] Plan. Analysis -' The City of Huntington Beach has prepared Environmental Assessment 02-05 that identified potentially significant environmental factors as a result of the proposed project. These factors are: Land Use, Population and Housing, Geology and Soils, Hydrology and Water, Air Quality, PCAC-47 Transportation and Traffic, Biological resources, Mineral Resources, Hazards and Hazardous materials, Noise, Public Services, Utilities/Service Systems, Aesthetics, Cultural Resources, Recreation, and Mandatory Findings of Significance. On the basis of this initial evaluation, the City of Huntington Beach has determined that an Environmental Impact Report is required. 3-58 City of Huntington Beach—Pacfc City 10 The Urban Planning Consulting Group • . EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26,2003, Page 11 • The Pacific Action Coalition Group would like the City of Huntington Beach, as Lead Agency in preparation of the environmental documents for this project, to consider the PCAC-48 following recommendations: _ Hazards'and Hazardous Materials: The Initial Study indicates that the property north of the Huntington Shores Motel was formerly occupied by a (natural) gas plant. This resulted in the presence of Benzene PCAC 4s and Toluene leaking into the soil from the condensate due to processing of the gas. No recent tests have been conducted in this or adjacent areas of the site. The last tests occurred in 1996 and are not current enough (See Phase II Investigation Report/Remediation Plan Atlanta Areas - December 1996). _ Additional soil gas testing for volatile organic compounds was only conducted in certain portions of the site. With 20 oil wells scattered throughout the property, the likelihood PCAC-50 that contamination was limited only to the region tested is remote at best (See Remediation Plan, Rev. 3 Atlanta Site - May 2002). — State Division of Oil and Gas records show that the re-abandonment of the oil wells in the late 1990's was necessary to stop leaking gas. They had been previously abandoned in the late 1980's. The wells have not been tested by Oil and Gas since the re-abandonment and the agency states that their tests are only good for a one-year PCAC-51 period. Thus the wells must be re-tested to ensure there are no leaks presently. And there remains the question of the extent of any groundwater contamination (See Remediation Plan). -� Because of a lack of recent extensive soil gas and oil well testing, there is a likelihood that contaminants exist which have not yet been identified exist. Therefore, any PCAC-52 additional excavation or movement of the soil would be premature until the site's true soil condition regarding hazardous materials is known. —, Transportation/Traffic: — Residents believe keeping Huntington Street in its present width and alignment, except for some curb and sidewalk improvements (on Pacific City side) will not work. Residents would also like to see some improvements into the entrance / exit of Pacific PCAC-53 Mobile Home Park, along with curb improvements or installation of sidewalks, removal of overhead utility poles, and a retaining/sound (and for esthetics) wall on mobile home park side of Huntington Street at developers expense (without removing any homes). _ • Consideration should be given to relocating the entrance/exit of Pacific Mobile Home Park to present dead-end configuration of Delaware Street, and officially PCAC 54 abandoning the Delaware Street extension south of Atlantic Avenue to connect with Huntington Street at Pacific View Avenue. _ City of Huntington Beach-Pacific City 11 The Urban Planning Consulting Group 3-59 • EIR for Pacific City Project ' EIR No.02-01 SCH No.2003011024 November 26, 2003, Page 12 • The City should consider abandoning the extension of Delaware Street, which is currently on the Orange County Master Plan of Arterial Highways (MPAH) and ' PCAC-55 Huntington Beach Precise Plan of Street Alignments (PPSA) as this new extended configuration. • The developer should be required to pay for all related traffic improvements, removing of Pacific Mobile Home Park entrance from Huntington Street to Delaware Street, and the installation of curbs, sidewalks, infrastructure improvements, underground utility poles, retaining walls, etc., all around the PCAC-56 mobile home park. No mobile homes should be affected along Huntington Street. Developer should be required to relocate those affected with new Delaware Street entrance back into the park. • Sound walls should be constructed around and on park side because of noise PCAC-57 from increased traffic due to Pacific City development. -- • Consideration should be given to Pacific View Avenue (Walnut Avenue) extension from 1St Street to 6th Street, and Pacific View Avenue (Walnut Avenue extension PCAC-58 - from Beach Blvd. to connect with Hamilton / Victoria (Costa Mesa) and the 55 freeway. — • The City should consider the possible extension of Delaware Avenue south of PCAC-59 Atlantic Avenue. • Residents believe that the parking projections for the Hyatt/Hilton Waterfront Projects may be incorrect because it is based solely on total valet parking. PCAC-60 Lessons learned from this development should be applied to the proposed project to avoid the same problems. _ • The parking garages should be designed to fit hotel tour buses and moving vans and trucks. Moving vans and trucks currently park on Pacific View Avenue PCAC-61 because they will not fit into parking garage. • In preparation of the EIR, the City should revisit all previous reports and findings (EIR) for the Waterfront Resort and/or expansion projects in regards to Pacific PCAC-62 City. Information need to be updated to current standards and conditions, as it' appears Pacific City is now exceeding all original projections. • Residential and retail development will likely increase traffic significantly during peak commuter hours, weekends and during the summer. The EIR should PCAC 63 consider impacts on traffic flow/congestion in the immediate vicinity of the property and regionally (e.g., Beach Blvd, Goldenwest St., PCH and freeways). • Impacts from traffic/parking needs for site workers, materials/waste delivery to/from site need to be addressed in the EIR to minimize impacts on the PCAC-64 -- neighborhood and ensure access to adjacent resident sites is not impeded. 3-60 City of Huntington Beach—Pacffic City 12 The Urban Planning ConsultingGroup • EIR for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26,2003, Page 13 • Specifics regarding proposed pedestrian access for the public should be stated in the EIR. For example, hours that public access will be available must be stated. Also, since the pedestrian access ways are proposed to be gated, availability of PCAC-65 the access to the public should be considered such that public access will not be further restricted than initially proposed. • Bicycle lanes should be maintained on all streets surrounding the site. No non- edestrian access (e.g., bicycles, skates, etc.) is proposed through the facility. p Y � P P PCAC-66 Therefore lanes for safe travel for bicyclists and skaters must be provided on streets surrounding the site — • Since zoning allows higher buildings on the east (Huntington Street) side than on the north (Atlanta St.) and west (First St.) sides, and since the site is surrounded on the east, west and north by residential homes, the City should consider the PCAC 67 same height restriction on the west side as for other adjacent residential areas. This would ensure that ordinances for aesthetics (e.g., view, glare, noise, etc.) - are appropriately maintained for residents adjacent to the west of the site. • Any future traffic studies must take into account peak periods for the region. This is particularly relevant to this project as the new Hyatt Hotel just south of the site hosts an 110,000 square foot convention center, which will bring thousands PCAC 68 of business travelers to the area. The Linscott study doesn't appear to address this. • The impact of the increased density of the project on access and service to existing neighborhoods such as the adjacent Pacific Mobile Home Park, homes along Atlanta and Huntington streets as well as patrons of the commercial and PCAC 69 residential parts of the development should be carefully studied. The Linscott study did not seem to address this issue. • Any proposed parking analysis should account for (1) project usage, (2) Hyatt's new convention facility and (3) regional parking during the height of the summer PCAC-70 tourist season. • The anticipated increase in residential and retail population as a result of the project will impact already overcrowded parking conditions downtown. The specific number of parking spaces to be provided for residents, guests and commercial vehicles must be provided in the proposal so that the sufficiency of parking proposed can be evaluated based on the estimated demand for resident, PCAC-71 guest and commercial visitor parking. The proposal also notes that on-street parking on adjacent streets will be allowed. Currently there is no on-street parking allowed on Atlanta and Huntington since these are single lane roads. Again, this proposal taxes the existing single lane roadways and the proposal does not state that dedicated right of way will be used for additional vehicle and V City of Huntington Beach —Pacific City 13 The Urban Planning Consulting Group &61 EIR,tor Pacific City Project -- EIR No.02-01 SCH No.2003011024 November 26, 2003, Page 14 bike lanes, or space for on street parking. The proposal only notes that sidewalk Pcacai and curb and gutter improvements will be made. • How will buses be accommodated along adjacent streets with the increased PCAC-72 traffic? • The project is anticipated to increase traffic on Huntington Street and � l surrounding streets. Huntington Street is proposed to be widened to a 90-foot PCAC 73 right-of-way. Where would the additional ROW be taken from? From the developer property or public and/or residential property? — Public Services• In light of the $7 million City of Huntington Beach deficit due to the current State PCAC-74 budget crisis, the EIR should identify project impacts on current public services such as Fire, Police and Lifeguard services. • The EIR should clarify whether the proposed roadways within the residential development would be private or pubic. If the roadways are public, impacts for PCAC-75 access for Police and Fire departments in emergency conditions should be analyzed. _ Public Beach Access • While not specifically addressed in the Initial Study, the issue of public beach PCAC 76 access is critical for any coastal development. The EIR should identify the project's impacts on beach parking during peak summer months. The Linscott study does not seem to address this critical peak period. Aesthetics • The EIR should address impacts on the elimination of existing ocean views of PCAC-77 residents in adjacent neighborhoods along Huntington, Atlanta and First streets, and propose measures to preserve the vistas the residents have had for years. • Impacts from shade and shadows, light from both the commercial and residential parts of the project, and glare should be adequately addressed, as they will PCAC-78 severely impact surrounding neighborhoods. Recreation — • With city park ratios of five acres per 1,000 persons, how is .90 acre for the project's park space allowed? Is one fifth or less of the required space PCAC-79 ' acceptable? There must be both an increase in park space and reduced density to accommodate this guideline. 3-62 City of Huntington Beach —Pacific City 14 The Urban Planning Consulting Group ' EIR for Pacific City Project EIR No. 02-01 SCH No.2003011024 November 26,2003, Page 15 Noise — • The EIR must specifically propose mitigation measures to address the issue of excessive noise during the construction phase on neighboring development. In PCAc-80 addition, the city should inform the public how compliance with noise regulations will be enforced. • Noise during site operations during/following completion of the construction phase also needs to be. addressed. Hotel, bars, restaurants, and other PCAC-81 commercial facilities proposed to operate at the site will create noise that may be a nuisance to neighboring residents. _ Schedule for Construction and Operations -, • The construction schedule proposed is basically without restrictions and does not consider the adjacent land use and quality of life of the neighbors. The proposed operating schedule is 7 a.m. to 8 p.m. Mon-Sat. This schedule should be restricted to Mon - Fri only, with working hours restricted to allow neighbors PCAC-82 morning and evening hours undisturbed by noise. Recommend 9 a.m. to 6 p.m. operating schedule Mon - Fri. The approved schedule should remain in effect for the life of the project or until adjacent site uses change. In addition, set-up for site work should be monitored by the city so that residents are not exposed to excessive noise and emissions from idling trucks, and loading/unloading operations at times outside the construction schedule. — • The timetable for construction should be specific with regard to when public access ways and other facilities (public park space, etc.) are to be constructed. Provisions should be included that require completion of the promised public PCAC 83 facilities to be provided (parks, street improvements; etc.) on a specified schedule. — • &63 City of Huntington Beach—Pacific City 15 The Urban Planning Consulting Group . EIR for Pacific City Project EIR No. 02-01 SCH No. 2003011024 November 26,2003, Page 16 ATTACHMENT A PACIFIC CITY DRAFT EIR RESPONSE HAZARDOUS MATERIALS The Pacific Action Coalition has researched records and interviewed Huntington Beach residents and city officials about the presence of hazardous materials on the site of the proposed Pacific City development. An environmental chemist consulting for the Pacific City Action Coalition reviewed the Hazardous Materials section of the Pacific City Draft Environmental Impact Report and other reports describing remediation and characterization PCAC(A)-1 activities on the site. This document presents the Coalition's concerns related to hazardous materials on the site that are not satisfactorily addressed in the Draft Environmental Impact Report. We conclude with a recommended course of action that will ensure adequate assessment and mitigation of environmental and human health risks associated with development on the Atlanta Avenue site. THE EIR CLAIMS AREA D NEEDS INVESTIGATION,BUT THE PRIOR TESTING THERE HAS BEEN KEPT SECRET. (1)The ER, in Section 3.7-10 states, "The area where further investigation is necessary is Area D, in the southwestern portion of the site...These areas do not include former oil wells or storage tanks. Sampling completed as part of the 1996 Phase II Investigation delineated the areas where remediation PCAC(A)-2 was necessary. Test results from that sampling effort did not detect that the contamination on the northern and eastern portions of the site had migrated to this area on the western portion of the site." The ER implies that no remediation is necessary in the western part of the site while at the same time saying that further investigation is necessary. What the ER fails to address is the testing which had been conducted in Area D by developer Makar Properties, Chevron and their consultant,Harding ESE in late 2001 or early 2002, identifying PCAC(A)-3 potential groundwater contamination by hydrocarbons. According to a sworn affidavit by Kamron Saremi of the California Regional Water Quality Board, Chevron's consultant,Harding ESE, approached him in 2002 with a proposal to leave contaminated soils in place which were near groundwater in the west central portion of the site. PCAC(A)-4 Saremi visited the site with Chevron and their consultant. He stated that Harding ESE presented groundwater testing samples to him taken from sample bores in the impacted area,the sampling area being approximately one acre. Saremi said the vertical extent of impacted soil was approximately five to ten feet below the ground surface.He stated that Chevron knew that a City of Huntington Beach requirement mandated the soil involved would have to be excavated. V 3-64 City of Huntington Beach—Pacific City 16 The Urban Planning Consulting Group EIR.for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26, 2003, Page 17 Saremi told the consultant that the groundwater test results necessitated them conducting more extensive testing in a larger area and suggested they submit a work plan for this purpose. Chevron said they would talk to their consultant and prepare a work plan for submittal. Chevron then PCAC(A)-4 contacted Saremi two weeks later and said they had decided to work with the City of Huntington Beach to implement the required soil excavation. These test records have been requested from the City and developer Makar for months and have not— PCAC(A) 5 been disclosed to the public. _ A document dated January 3, 2002 was-then submitted to Saremi and cc'd to the City's Fire Department, Chevron and developer Makar referencing the above discussion. The report includes a PCAC(A)-6 groundwater testing plan,but references the southeastern part of the site, an area totally separate from the section visited and discussed by Saremi. — (2)The EIR, in Section 3.7-17 states,"While not anticipated once closure reports have been submitted,the possibility remains for unidentified soil contamination...or for unidentified underground storage tanks to be encountered during grading or excavation activities...It is possible that underground tanks may have been in use at the project site prior to permitting and record keeping requirements." A sworn affidavit by resident John Sisker, identified six to eight narrow,cylindrical tanks with pipes PCAC(A)-7 extending into the ground, located near First Street, approximately halfway between Atlanta Avenue and Pacific Coast Highway,the same area as the potential groundwater contamination noted above. These tanks and pipes are believed to be the type used in distilling or separating operations that separated and distributed crude oil into gasoline and diesel fuels. It is likely that the tanks referred to are located in the west central part of the site, Area D,and were repositories for the gasoline products referenced above. There is therefore evidence that the southwestern portion of the site(Area D) is contaminated with petroleum hydrocarbons,but the extent and composition of this contamination has not been characterized in the EIR and no plan for remediation of this area has been submitted. The potential PCAC(A)-8 impacts of contamination in Area D on workers and residents near the development are unknown,but must be analyzed in the EIR rather than deferred until after development has already proceeded. (3)In 19.90, a warning sign identifying the presence of carcinogens and chemicals which may cause birth defects was present on the site,but has since been removed. This warning was precipitated by the Proposition 65 guideline regarding potential groundwater contamination. Where are the test PCAC(A)-9 results or reports which generated this warning? It is believed that Chevron, who owned the property at the time,was aware of prior groundwater contamination and has reports indicating such. • 3-65 City of Huntington Beach—Pacific City 17 The Urban Planning Consulting Group • . EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26,2003, Page 18 • (4)The EIR states, in Section 3.7-10,that"groundwater beneath the project is also brackish due to saltwater intrusion, and as such, is not used as potable water by the City"as a justification for why groundwater contamination should not be a concern. PCAC(A)-10 This statement ignores the scientific fact that petroleum contamination on the Pacific City site could potentially pose health risks to residents of the adjacent community,particularly if there are low molecular weight carcinogenic hydrocarbons such as benzene,toluene, ethyl benzene and xylene (BTEX) at the site. If present at sufficient levels,BTEX could form a non-aqueous phase that would leach through the soil to the soil-groundwater interface and spread out along the top of the groundwater. This could PCAC(A)-11 lead to exposure of residents in nearby houses by infiltration of vapors and subsequent inhalation. A study released last year in the American Journal of Industrial Medicine found an increased risk of 1 gliomas (a type of tumor)in Swedish men and women over two decades when occupationally exposed to petroleum products and other chemicals such as arsenic and mercury. PCAC(A)-12 The study is indicative of current research interest in this area, and is particularly relevant given the recent cases of brain stem glioma among Huntington Beach residents who lived along Yorktown Avenue and were potentially exposed to oil field contamination. The ER does not address the possible impacts of hydrocarbon contamination of groundwater on residents living adjacent to the site, and the extent of this groundwater contamination remains PCAC(A)-13 unknown. THE EIR IDENTIFIES AREA A AS HAVING COMPLETED REMEDIATION. (1)The ERR states in Section 3.7-7 that the soil involved in the 1999 export to the Hyatt (approximately 215,000 cubic yards)exceeded city specifications for hydrocarbon contamination and Pcac(A) 14 was either excavated or remediated on site. The ER also states in section 3.7-17, "Residual oil could be present in the areas remediated,and this cannot be confirmed until closure reports have been submitted and accepted by the City Fire Department that verify the site has been satisfactorily remediated." _ • The"Final Environmental Closure Report"for the Hyatt submitted to the city by Hyatt developer —1 Robert Mayer Corporation claimed there was no evidence of contaminated soil in any of the samples PCAC(A)-15 tested and thus contained no documentation of either excavated or remediated soil. The Mayer Corporation conducted limited sampling in Area A during the period of August through— September 1999,even though soil continued to be excavated and transported through November of PCAC(A)-16 that year. 3-66 City of Huntington Beach—Pacific City 18 The Urban Planning Consulting Group EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26,2003, Page 19 A Residents John Sisker and Ron Satterfield completed sworn affidavits attesting to soil being vented for a period of six months to one year after being stockpiled at the Hyatt location. It is believed that the venting was carried out to purge the soil of low molecular weight hydrocarbons (BTEX chemicals). PCAC(A)-16 Photos of the site taken during the 1999 soil transport reveal the soil to be very dark and in some instances,nearly black. Considering the site's history of oil production,it is likely that the soil samples taken did not accurately reflect the nature and extent of the area's contamination. Furthermore,mixing of soils as a type of "remediation"does not remove contaminants from the site, PCAC(A)-17 leaving the possibility that high concentrations of contaminated soil could still exist. (2)Mayer Corporation has a history of non-compliance with state and local requirements spanning ' the last decade,including: A 1990 class action lawsuit filed by Pacific Mobile Home Park residents against the Mayer Corporation for violating AQMD dust control guidelines while constructing the Hilton hotel. Ironically,the dust which covered homes in the park came from stockpiles of soil at the Pacific City site,which at the time had signs posted warning of soil contamination. The suit was settled for $100,000. A 1991 AQMD lawsuit filed against the Mayer Corporation for dust control violations during the construction of the Hilton hotel which was settled for$15,000. PCAC(A)-18 Several neighborhood complaints were lodged with both the AQMD and the City during the 1999 soil transport. Although the Mayer Corporation had a dust control plan in place,measures to control the dust were not implemented until the surrounding homes had been covered with dust. • A$55,000 fine assessed by the Regional Water Quality Control Board for stormwater runoff violations occurring in December,2002. Among the violations were the dumping of sediment laden storm water directly into the storm drain. According to Seaside Village residents, who face the new residential development behind the Hyatt hotel,the Mayer Corporation continues to violate Water Board guidelines by allowing runoff from the project to impact their homes. The above facts raise several questions—(1)Did the City's Fire Department know that there was contaminated soil which was found and not included in Mayer's report?If so,why did they sign off on the project? (2)Was the Fire Department unaware of any such findings?(3)Where are the records to support the EIR's claim that the soil was contaminated, excavated and remediated,despite months PCAC(A)-19 of requests from both the city and developer Makar for more details on Mayer's report,(4)Was the contaminated soil actually excavated and remediated on site or just transported as eyewitness accounts verify, (5)Why is the soil contamination being disclosed now despite the public being told V City of Huntington Beach —Pacific City 19 The Urban Planning Consulting Group 3-67 EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26, 2003, Page 20 for years that the soil involved was clean? (6)Does this mean that the"Final Environmental Closure _ Report"for the Hyatt was inaccurate? (7)If so, why doesn't the EIR address this issue? PCAC(A)-19 (3)Moreover, the 1996 Phase II Study shows four areas that were"surgically excavated"to remove hydrocarbon contaminated soil for remediation by mixing. Three of these four areas are marked in the EIR map, Figure 3.7-1, as part of Area A where remediation has been deemed complete. However, one of the four areas, Surgical Excavation Number 1 on the 1996 map, is part of Area B in PCAC(A)-20 the EIR map, where remediation is "currently underway." Thus, as Surgical Excavation Number 1 in 1996 was not effective at cleaning up the site, why would the other three excavations in Area A be considered effective? (4) In Section 3.7-5, the EIR references reports of a former gas plant, identified by a Chevron employee interviewed for the 1995 Phase I Study. The plant reportedly operated at the corner of First Street and Atlanta Avenue,north of the site. The EIR then makes two statements, (1)"...no documentation exists to support the existence of a gas plant"and,(2) "If a gas plant did exist on property adjacent to the project site,toxic contaminants associated with gas condensate from a gas plant could remain in the soil." PCAC(A)-21 - The EIR should not use a lack of documentation from half a century ago as justification for questioning the plant's existence At the same time,the EIR acknowledges that the former Chevron employee who identified the gas plant was also correct in stating that toxic contaminants could remain in the soil. Once again, several questions are raised, (1)Where are the test results, documents or statements to support the above statement?, (2)Is the EIR relying on the Chevron employee's statement for this information?, (3)Wouldn't the Chevron employee's statement regarding the gas plant's existence then be reliable? The EIR again contradicts itself. Section 3.7-5 states, "These contaminants would be localized on the site and would not be expected to have migrated across First Street through the soil to the project site...As such, these contaminants are not expected to exist on the northwestern portion of the site or otherwise affect soils on the property site."While Section 3.7-18 states,"Due to the migratory nature of oil in.the soil,the risk remains for oil contamination to exist in soil areas that have not been previously trenched for sampling and investigation." PCAC(A)-22 Which of these statements is accurate? If the first statement is true, are there test results to substantiate it?Is there new testing of the northwest part of the site which has not been disclosed? 3-68 City of Huntington Beach—Pacific City 20 The Urban Planning Consulting Group EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26,2003, Page 21 A Or is the EIR relying on the 1996 Phase II testing of the northwest portion and/or the 1999 testing by PCAC(A)-22 Mayer, both of which have been contradicted in the EIR itself. _. THE TEST RESULTS ARE CONTRADICTORY AND UNRELIABLE (1) The EIR states in Section 3.7-9 that 1999 hydrocarbon testing in the southeastern part of the site revealed levels of up to 130,000 mg/kg for shallow soil and 68,000 mg/kg for deep soil. These levels are 15 to 100 times higher than the prior testing conducted in the 1996 Phase II Study by Chevron's PCAC(A)-P3 consultant,Harding Lawson. As some of the areas tested in 1999 and 1996 overlap, this seems to indicate that the site became more contaminated over time. How is this possible? Or does this mean that the 1996 Phase II Study was inaccurate? — Where are the test results and sampling maps to accompany the 1999 testing? These documents have been requested from the city and developer Makar for months and have not PCAC(A)-24 been disclosed to the public. — (2)Developer Makar, along with Chevron and their consultant Harding Lawson made an exemption request to leave approximately 800 cubic yards of contaminated soil surrounding a water main in Area C. They wanted to rely on BTEX testing from the 1996 Phase II Study,even though no testing in the impacted area was conducted during that period. PCAC(A)-25 The original exemption request was recommended for approval by the city's consultant,Geosciences Analytical, whose principal,Fleet Rust was convicted in 2002 of falsifying methane monitoring data to the City. The developer and Chevron withdrew their exemption request shortly after the Pacific City Action Coalition disclosed the above details to the public. 3-69 City of Huntington Beach—Pacific City 21 The Urban Planning Consulting Group EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26, 2003, Page 22 CONCLUSIONS — The Pacific City Draft Environmental Impact Report's Hazardous Materials section relies heavily on prior studies conducted by developer Makar Properties, Chevron and their consultant(s)Harding Lawson and Harding ESE, and the Robert Mayer Corporation. These studies were sanctioned and approved by the City of Huntington Beach and their consultants. PCAC(A)-26 As previously illustrated,the studies have been shown to be misleading,incomplete and contradictory and thus unreliable. One of the consultants involved in assessing the site was even convicted of submitting fraudulent test results for another site. The City of Huntington Beach has improperly sanctioned and distributed much of the misleading data and been negligent in it's role of ensuring,compliance with established laws and regulations. The only fair conclusion is that the parties involved—developer Makar Properties, Chevron and their consultants along with the City of Huntington Beach,cannot be relied upon to provide an objective, accurate characterization of the environmental conditions at the Pacific City site. PCAC(A)-27 Given the potential community health risks involved as a result of not properly assessing conditions at the site,the only viable alternative is to have testing done by an independent firm,mutually selected by the developer,Chevron, the city and the Pacific City Action Coalition, paid for by the developer and Chevron,who is responsible for the site clean-up. 1 3-70 City of Huntington Beach—Pacific City 22 The Urban Planning Consulting Group • , EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26,2003, Page 23 ATTACHMENT B ISSUES INVOLVING PACIFIC MOBILE HOME PARK SURROUNDING STREETS AND POTENTIAL WETLANDS PCAC(B)-1 These comments address the Pacific City project impacts to Pacific Mobile Home Park and the Draft EIR's failure to analyze the ultimate outcome during and after build-out of Pacific City to Pacific Mobile Home Park This would include the Delaware Street extension, which the EIR seems to indicate would eliminate the mobile home park and the widening of Atlanta Avenue between Huntington Street and Delaware Street. —. According to Mayor Connie Boardman, the City has been meeting with the owners of Pacific Mobile Home Park, Mark Hodgson and brothers as to the impact Pacific City will have on PCAC(B)-2 the park and the residents. Any and all known future impacts to this mobile home park and the residents must be disclosed. The residents have been told, both directly and indirectly, that the present owners of this park intend to keep said property as a mobile home park well into the future. PCAC(B)-3 Residents, acting upon this information, are putting in new homes as well as fixing up existing ones. The Environmental Impact Report fails to address the project's impact on the park THE FOLLOWING CONCERNS HAVE NOT BEEN ADDRESSED BY THE EIR: PCAC(B)-4 TOTAL AND ULTIMATE IMPACTS)TO PACIFIC MOBILE HOME PARK: Regarding Huntington Street,Atlanta Avenue,Delaware Street(extension), and Pacific View PCAC(B) 5 Avenue • Precise alignments and/or improvements • Mobile home park entrance/exit _ • Total number and identification of mobile homes to be displaced ] PCAC(B)-6 • Ingress/egress from Huntington Street and Atlanta Avenue PCAC(B)-7 into Pacific City and/or Pacific Mobile Home Park • Number of inlets and outlets J PCAC(B)-8 ▪ Set back requirements on street,restricted flow of traffic ] PCAC(B)-9 • Intended land use if not a mobile home park ] PCAC(B)-101 • Time frame PCAC(B-)-11 • Known factors by park owners/management company ] PCAC(B)-12 City of Huntington Beach—Pack City 23 The Urban Planning Consulting Group 3-71 EIR far Pacific City Project - EIR No.02-01 SCH No.2003011024 . November 26,2003, Page 24 ULTIMATE EXTENSION OF DELAWARE STREET: Regarding the Master Plan of Arterial Highways and City Circulation Element PCAC(B)-13 from Atlanta Avenue to Pacific View/Huntington Street • Will eliminate Pacific Mobile Home Park. • Time frame THE TAKING(POSSIBLE EMINENT DOMAIN) OF ANY OR ALL OF PACIFIC MOBILE HOME PARK: • Compensation to residents/landowner PCAC(B) 14 • Market value • Time frame THIRTEEN,TEN AND/OR SIX FOOT EASEMENT(S)INTO PACIFIC MOBILE HOME PARK: • Parallels Huntington Street PCAC(B)15 • City and/or Edison easement • Effects on mobile home park • Time frame PACIFIC VIEW/HUNTINGTON STREET: • Designated for signalized intersection • When and what configuration PCAC(B)-1 s • Eliminate connect to pacific view/dead end • Time frame THE PRECISE WIDENING/REALIGNMENT OF HUNTINGTON STREET,ATLANTA AVENUE, AND 1ST STREET AND RELATED INTERSECTIONS: • All projected/future circulation elements and traffic flow patterns • Configuration for all curbs, gutters, sidewalks,pedestrian paths,bikeways, on-street PCAC(B)-17 parking,underground utilities and other infrastructure needs; curb cuts,bus routes, ingress /egress into development and/or surrounding communities V • Needs to be determined for both sides of each street • Time frame THE EIR FAILS TO ADDRESS HOW THE PACIFIC CITY SITE AND/OR OTHER _ ADJACENT PROPERTIES WILL BE USED FOR ANY FUTURE PARKING ISSUES: • The Waterfront Hilton/Hyatt not providing adequate parking for guests and/or employees PCAC(B)18 • Has no parking areas for tour buses and/or moving vans for convention equipment V 3-72 City of Huntington Beach—Pacific City 24 The Urban Planning Consulting Group EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26,2003, Page 25 • Hotel employees still required to park off-site at peak times, and have been since the early A 1990's,on the Pacific City site itself • Impact to surrounding neighborhoods when Pacific City site is no longer available for overflow Waterfront parking • It is believed Waterfront hotel employees are being charged if they do park within the PCAC(B)-18 parking areas that were supposed to be part on the approved on-site employees parking management plan • Some employees parking within the beach public parking lot instead,and before hours to avoid being charged TAKING OF HOUSES/PROPERTY ALONG DEVELOPED SIDE OF ATLANTIC AVENUE: • Possibly through future eminent domain PCAC(B)-19 • Any improvements to existing road circulation • Time frame IMPACT ON THE CITY OF NEWPORT BEACH: • With the addition of 3,000 cars per day to the Pacific City site alone, the City of Newport Beach anticipates that at least half these cars will end up in their city PCAC(B)-20 • This will cause increased traffic on already congested Pacific Coast Highway and other roads within their city • Concerns about the proposed 19th Street bridge across the Santa Ana River—what if the bridge isn't built?How will traffic be handled in this case? POSSIBLE SIGNIFICANT WETLANDS VEGETATION AND/OR PONDING ON SITE: • Potential wetlands vegetation and ponding identified by Mark Bixby was not adequately PCAC(B)-21 addressed in the EIR • Developer Makar Properties was stopped twice in September of 2003 for grading without a permit immediately after Bixby's presentation to the City Planning Commission J City of Huntington Beach—Pacific City 25 The Urban Planning Consulting Group 3-73 • EIR.for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26,2003, Page 26 PROPOSED MITIGATIONS • The widening of Huntington Street, from Pacific View Drive to Atlanta Avenue, for proper traffic flow for north/south circulation(including right-and left-hand turn PCAC(B)-22 pockets, center landscaping,bicycle lanes)using the Pacific City developers property. We oppose any encroachments into surrounding neighborhoods including that of Pacific Mobile Home Park. • The widening of Atlanta Avenue from Huntington Street to Delaware Street to be configured so that no existing mobile homes will be effected within Pacific Mobile Home PCAC(B)-23 Park. - • Elimination of the decades-old realigned plans and proposed Delaware Street extension, as currently projected on both the City and County master traffic plans. The extension is PCAC(B)-24 intended to connect Delaware Street with Huntington Street at Pacific View Drive,thus eliminating Pacific Mobile Home Park according to the Pacific City Environmental Impact Report(EIR). • Full and complete disclosure from the owners and property management company ' PCAC(B)-25 regarding impacts to Pacific Mobile Home Park. J • Reducing the proposed density of 516 residential units,as this will cause major traffic and PCAC(B)26 parking impacts in the region,particularly during the summer months. _ • Maintaining as many existing view corridors for all residents in the surrounding PCAC(B)-27 neighborhoods. • • Perform a totally new and updated traffic study using today's actual traffic flow, street PCAC(B)-28 - congestion,parking issues, etc.,which would then be the basis for any future traffic J projections because of Pacific City. • Pacific Mobile Home Park, and/or other adjacent properties, not to be used as a solution i for future parking and/or other related issues,by Makar Properties,the Robert Mayers PCAC(B)-29 Corporation, and/or the City. • 3-74 City of Huntington Beach—Pacfic City 26 The Urban Planning Consulting Group , EIS for Pacific City Project EIR No.02-01 SCH No. 2003011024 November 26, 2003, Page 27 ATTACHMENT C PACIFIC CITY ACTION COALITION DRAFT EIR COMMENTS • The EIR does not adequately address amplified noise from the commercial portion of the PCAC(C)-1 development. Significant impact has been experienced in the neighborhoods surrounding the Hyatt as they frequently have outdoor amplified concerts/events that intrude on the generally low] level noise of a residential area. • The EIR does not adequately outline"public access"to the bridge over PCH that is proposed. If the measure of"public access"experienced at the Hyatt project is an indicator,this would be pCAC(C) 2 deemed unacceptable. Public access and utility should include consideration of useful route, maximum width, clear signage or views indicating access,no limits/obstructions on public access • i.e. events/restrictions on common beach access modalities such as bikes/roller blades/wagons. Access should be clear and functional for all these modes. • The EIR does not adequately address light contamination that results from significant use of"up" lighting as demonstrated by the Hyatt. Impact on surrounding neighborhoods is significant at PCAC(C)-3 night and intolerable during the frequent foggy weather we experience near the beach. • Erosion control was poorly managed at the Hyatt development and the residential project to the North of it despite fines and significant community/public works/water quality board involvement. There needs to be clearly outlined process with active city involvement,oversight ! PCAC(C)-4 and significant negative impacts to the developer should erosion control fall out of substantial compliance. The city public works department was unable to change the gross inconsideration and impact of silted storm drainage into neighboring communities and our wetlands/ocean. _ • The timeline proposed is unacceptable. If the developer is hindered by fmance concerns (as experienced by the Hyatt project)perhaps a more stable,more aptly funded developer should be considered. IF such a timeline is unavoidable,the impacted residents should be afforded ! PCAC(C)5 EXTRAORDINARY accommodation in minimizing intrusion and impacts (noise blankets, temporary relocation,monitoring of air/noise/storm drain quality). —� • Alternatives to the proposed density were not adequately explored in the EIR. Current development at the Waterfront residential project is not as dense,yet the EIR states that lower ! PCAC(C)-6 densities would not meet current planning goals. • Pedestrian access in and around the project is not adequately address in the EIR. If this project were to be an asset to the community and not just to the developers that sell it,pedestrian issues would be a primary consideration. Sidewalks on all borders and throughways to the property, POAC(c)-7 clear rights of way for pedestrian and bicycle/roller blade traffic would create a project open to area residents and facilitating access to commercial,pier,beach and downtown venues by paths other than PCH. The"commercial"aspects of the Hyatt project were oversold to the community`1 City of Huntington Beach—Pacc City 27 The Urban Planning Consulting Group 3-75 EIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26,2003, Page 28 and remain primarily hotel oriented. Sidewalks on one side of the street and not the other create n an uninviting environment for local pedestrian traffic... a major source of revenue in the off-peak PCAC(C)7 seasons. • The balance of commercial to residential space is too far toward residential. If this project and the city are to seek destination status,there needs to be a greater draw than very dense resident PCAC(C)8 traffic/consumption. This city could use a few more active cash registers in the primary tourism areas adjacent to the coast. High quality dining absent the pricing and limitations of a hotel venue are the first opportunities that come to mind. _f • Parking,while it maybe in compliance with code, is inadequate for a pq "destination"project,and does not consider the downtown area as having been built prior to generation of current parking codes. Parking for residential and commercial uses is inconvenient and inadequate. Multi level parkingmayput moneyin thepockets of some and"adequately"mane a focused PCAc(c)-s garage g concerns,but ample street and single level parking creates the feeling of open space and quality of life that the pier/downtown area is worthy of. It is of interest to note that the Hyatt directs its employees to park in the adjacent communities when holding large events ... presumably because the parking designed is inadequate to accommodate both employees and guests. The downtown area can ill afford this impact. —� • Increased traffic in the area is inevitable. While traffic studies in the EIR don't suggest a traffic light at the intersection of Atlanta and Huntington,common sense does. As frequent travelers to Pcac(c)-10 this intersection confidently state, summer traffic is already a concern,without the proposed development. Without a timed break in traffic,access to downtown areas becomes tenuous and crossing Atlanta via the crosswalk at Delaware to access the local park quite hazardous due to the incline, lines of sight and speed along the wide Atlanta corridor. J • Significant unavoidable impact on traffic at PCH and Warner creates a question of air quality impact on the Bolsa Chica. Idling traffic can already be a problem as commuter traffic backs up pcAc(c)-11 from Warner south along PCH. There is no consideration of air quality impact due to idled traffic for this avian sanctuary or for the wetland areas south of the development that will experience increasing traffic loads and idle time. • Significant conflicting messages exist regarding traffic concerns as they relate to the county plan. Most proximate is the extension of Delaware to the south. Is this being proposed and used in traffic projections? Are the traffic projections considering the 19th street bridge over the Santa PCAC(C)-12 Ana River? These two issues are contentious and are not reliably prone to inclusion or exclusion when projecting traffic impact. • Impact on local schools should be considered WITH projected impacts of current and planned PCAC(C)-13 future development in the downtown area. 3-76 City of Huntington Beach —Pacific City 28 The Urban Planning Consulting Group . • FIR for Pacific City Project EIR No.02-01 SCH No.2003011024 November 26, 2003, Page 29 • Height or number of stories above curb height should be portrayed. The 4 story limitation presented for the Hyatt was misleading to the public as the project resulted in a final height far pCAC(C)-14 above that presented publicly when soil compaction and parking garage additions to height were added. • Traffic impacts to the south including nearest freeway access to the 55 are not addressed in the PCAC(C)-15 MR draft. 3"77 City of Huntington Beach—Pacific City 29 The Urban Planning Consulting Group • THE ROBERT MAYER r °Y CORPORATION ! , December 3,2003 Ms. Mary Beth Broeren - City of Huntington Beach _ - Planning Department 2000 Main Street Huntington Beach, California 92648 Re: Draft Environmental Impact Report No. 02-01 for the Pacific City Project Dear Ms. Broeren: The Robert Mayer Corporation submits the following comments with regard to the Draft RMC-1 Environmental Impact Report No. 02-01 ("DEIR")for the Pacific City Project("Project"): _ 1. The City's "Notice of Availability of the Draft Environmental Impact Report No. 02-01 for the Pacific City Project" is misleading in that it erroneously states that the Project's Transportation/Traffic impacts would be mitigated to a "less-than-significant level." As is described in the DEIR, there are transportation impacts that are significant and unavoidable (see RMC-2 page xxii and 3.14-65). Therefore, the availability of the DEIR should be re-noticed to obviate the misleading effect of the original notice, in that some members of the public who may be interested in reviewing and commenting on projects primarily when they exacerbate traffic conditions might well have chosen not to participate in the DEIR process here, believing that the traffic impacts of the Project would be fully mitigated to a level of insignificance, when in fact they would not be. —� 2. As described in detail in the attached report prepared by Kimley-Horn Associates (see Exhibit "A" to this letter,which is incorporated by this reference as if fully set forth herein), RMC 3 the traffic and parking analyses in the DEIR are deficient for several reasons. First, the traffic study erred in its analysis of the required signalization at the intersection of Atlanta Avenue and Huntington Street. Such signal should in fact be the responsibility of the Project. _ 3. The traffic analysis also made various assumptions regarding internal captureT rates that resulted in a substantial theoretical reduction in the traffic generated by the Project. However, not only were the assumptions used different that the accepted ITE methodology, but RMC-4 no support for the method used was provided. An important issue to consider is whether any0 660 Newport Center Drive . Suite 1050 . Newport Beach, CA 92660 - 3-78 P.O. Box 8680. Newport Beach,CA 92658-8680 tel 949.759.8091 . fax 949.720.1017 • • • • Ms. Mary Beth Broeren December 3,2003 Page 2 significant reduction in traffic generation is warranted, no matter what methodology is used, RMC 4 given the significant reduction that can result from such assumptions. 4. In addition to the internal capture assumptions, the traffic study then applied unsupportable mode-shift reductions to the traffic generation of the Project. These assumptions, discussed in greater detail in the attached Kimley-Horn report, assume a significant portion of visitors to the Project are beach and downtown visitors who came for other purposes, and then also decided to patronize the Project by walking '/a to mile to the Project and back again. Such RMC-5 an assumption is unlikely at best. Moreover, when one computes the actual effect of the percentage reductions used to the trip count estimated for the Project,the calculation reveals the assumption that on an average weekday (not peak weekend) some 3,000 people each day and 330 people in the evening peak hour, will walk to the Project from the beach or downtown area. On a typical non-summer weekday this would appear to be an extremely optimistic assumption, which if true, would likely render the downtown area virtually vacant of visitors. 5. Although the Downtown Specific Plan provides that the Project site "is not intended to compete with the downtown commercial core,"the DER inconsistently assumes that RMC-6 the site will compete with the downtown commercial core by estimating and planning that an unrealistically large percentage of trips to the Project site will come from the downtown area. 6. We also believe that the traffic study improperly assumes that a significant percentage of trips to the Project's restaurants are from existing beach visitors, who typically are not dressed for, or otherwise prepared to patronize, quality sit-down dining establishments. This : RMC-7 drop-in dining situation has not been significantly experienced at the Hilton or Hyatt hotels at The Waterfront for these reasons. 7. The use of both internal capture rates and questionable mode-shift assumptions is an overly optimistic approach to estimating traffic generation without reliable factual support for the use of either assumption individually, let alone in combination. The traffic study's impact RMC-8 calculations should be run assuming there is no internal capture or mode-shift effect occurring, so that the full impact of such an important assumption is understood and disclosed. 8. The traffic study also failed to consider the fact that Mayer Financial Ltd. ("Mayer") entered into a Development Agreement and a Disposition and Development Agreement ("Agreements") in September 1998, entitling Mayer to develop a third 300-room hotel on the site immediately south of the existing Hilton Hotel within The Waterfront RMC-9 development site. As the successful developer of both the Hilton and Hyatt Hotel projects, Mayer fully intends to proceed with the third hotel project as contemplated in the Agreements. The DEIR's 2008 near term traffic analysis,however, failed to consider the traffic from this third I hotel at The Waterfront, thus undermining the validity of all traffic calculations in the traffic] study. —1 3-79 Ms.Mary Beth Broeren December 3, 2003 Page 3 9. The shared parking analysis is similarly flawed. First, as explained more fully in the Kimley-Hom report, the shared parking analysis incorrectly underestimates the amount of parking required under the City codes by not calculating the demand of the hotel meeting space or spa, which it later does consider in subsequent calculations. It similarly errs when making a j RMC-10 comparison to requirements under the Downtown Parking Master Plan. Therefore, shared parking study greatly understates the proposed reduction in parking from code requirements. Code requirements are approximately 2,155 to 2,488 spaces (depending on the actual amount of meeting space in the hotel), and the proposed Project parking is 1,535 spaces, a reduction of up to 953 spaces or 38%. _ 10. The shared parking study also relies upon all of the unsupportable trip generation reductions from internal capture and mode-shift assumptions in the traffic study, and applies the percentage reduction in trip generation to the initial parking demand before considering shared i RMC-11 use. Therefore, the shared use calculations already were pre-discounted for internal capture and mode-shift effects (which are analogous to shared parking concepts). As a result, there is a double discounting occurring;which well understates the parking needs of the Project. 11. As the Kimley-Horn report discusses in greater detail, the shared parking analysis also makes incorrect computational reductions for use of facilities by hotel guests, and further dubious assumptions walk-in traffic from the breach and downtown areas. As the report notes, it is unusual for a development to assume that 15 to 20%of its parking demand will be satisfied by RMC-12 off-site parking supplies that are located up to 1/2 mile away, especially in an area where existing parking demand can be substantial. If the assumptions in the shared parking study for walk-in traffic prove incorrect, the Project's parking demand could spill over-into the downtown and beach parking lots,further impacting these parking areas. The DEIR failed to adequately discuss this potential impact. 12. The DEIR also includes the phrase "parking demand interaction with . . . the downtown parking supply" and the shared parking study assumes such interaction in its calculations. However, as discussed in the Kimley-Horn report,the distance from the downtown parking supply to the Project site is too great to reliably be considered as a factor. In fact, the RMC-13 — Project is outside of the Downtown Master Parking Plan zone. Nonetheless,the parking analysis assumes that the Project is within that zone and assumes that there is a significant interaction with the downtown parking supply. As a result of such assumption, the shared parking study is fatally-flawed. J 13. The Project also improperly relies on beach parking to satisfy the Project's parking needs, as the DEIR often uses the phrase "parking demand interaction with the beach" RMC-14 and the shared parking analysis uses this interaction as a basis to reduce parking. However, City codes and Coastal Act policy preclude a project from relying on beach parking. Thus, the \l/ 3-80 Ms. Mary Beth Broeren December 3, 2003 Page 4 component of"parking demand interaction with the beach" should be separately identified and"RMC-14 eliminated from the analysis. 14. The shared parking analysis also improperly assumes artificially low percentages—I for non-guest use of meeting rooms on weekdays (85%) and weekends (75%). These assumptions are based on one sample of information at a distant property. Our company's experience in this coastal location with its Hilton and Hyatt Hotel operations, particularly in the summer months, shows that there is nearly 100% non-guest use of the meeting rooms on some RMC-15 weekends (for weddings and other large social/charitable events held while the hotel is fully occupied with vacation-oriented guests). Further, the DEIR inappropriately uses average situations, rather than peak demand, and thus the figures are misleading and serve to underestimate the true parking demand. 15. Additionally, the hotel occupancy rates used for Tables 5 and 6 in calculating the shared use numbers indicate a lower occupancy on weekends than on weekdays. This is supported by neither common sense nor our company's experience in the operation of the hotels at The Waterfront in this suburban resort location. Occupancy rates and room rates actually rise on the weekends at the Hilton and Hyatt Hotels. Further, the assumption of only a 60% occupancy rate on Saturday at 1:00 p.m. is absurdly low. A great majority of weekend guests RMC-16 check in Friday night for a 2-night stay, and the Hilton runs at virtually 100% occupancy on most Saturdays. At 1:00 in the afternoon, on summer weekends, most all guests are either in their room, at the pool, or on the beach, and their cars are in the parking garage. Thus, the parking assumptions provide an unrealistically low average demand, rather than predicting peak usage in a shared use environment. Thus, it improperly understates the parking impacts of the Project. i 16. For purposes of determining demand, the parking study also erroneously uses a figure of 9,300 square feet for the meeting space in the proposed hotel, while it actually is proposed to be 16,000 square feet. (Table ES-1 on Page xvii.) Thus, the parking demand is RMC-17 further understated. On the other hand, if in fact the project will only provide 9,300 square feet of meeting space, the entitlement application and project description should be amended to reflect this figure. — 17. The shared parking study also assumes an unrealistically low use of meeting space at 30 square feet per person. Large banquet events often seat people at 12 square feet per person. The assumption of 2.5 persons per car is also unsubstantiated by any empirical evidence. RMC-18 Rather than the resulting low figure of 124 spaces being required for this meeting space, as the attached Kimley-Horn report suggests, 266 to 457 spaces may be required for the meeting space at the Project's hotel, depending on the actual total size of the meeting space.18. The shared parking study also fails'to take into account valet use. The Hyatt Hotel uses 100% valet parking, while the Hilton Hotel currently uses a mix of valet and self- RMC-19 3-81 Ms.Mary Beth Broeren i December 3, 2003 Page 5 . parking and will probably convert to 100% valet in the near future. The Project parking study fails to consider that valet operations require parking spaces that are segregated from general public parking, so that valet staff can have readily available numbered spaces for quick RMC-19 placement and retrieval. This component of parking demand, which may be all of the proposed Project's hotel use, should be excluded from consideration of shared use, since it cannot be shared with other users. — • 19. The DEIR's Project Description states that while the "interim condition" of Pacific View Avenue will contain angled parking on the south side of the roadway,the"ultimate condition" will have no angled parking. (Page 2-20.) Elsewhere, however, the DEIR states that angled parking will be provided in the long term. (Pages 3.14-26; 3.14-70.) Not only is this RMC-20 misleading, but if in fact angled parking is allowed on Pacific View Avenue in the immediate proximity to the main entry and the four-way intersection at the center of the Project, conflicting traffic patterns and delays will result. The impacts of this design are improperly deferred, 1 • especially in light of the fact that Pacific View Avenue is a 10,000+ADT street with peak uses occurring in hotel, restaurant, and retail uses. In Mayer's developed hotel projects to the east,- -� on-street parking is prohibited on Pacific View Avenue between Huntington Street and Beach ;. Boulevard in order to ensure adequate emergency vehicle access to the hotels. This same : RMC-21 standard should apply to the Project because of public safety concerns and because it is acknowledged in the DEIR that the Project design does not provide adequate emergency access._ (Pages xxxiv, 3.12-10.) Nothing is provided in the Project conditions to mitigate the acknowledged inadequate emergency access. (See, e.g., pages 3.14-72 through 3.14-77 [dealing RMC-22 only with non-emergency access to the Project].) _ 20. If in fact there will be an interim design condition, followed by an ultimate configuration, there is no explanation in the DEIR of what criteria triggers the requirement that the configuration be changed to the ultimate design. If such a change is anticipated as mitigation RMC-23 measure against future impacts, the DEIR is also unclear as to whether this is a Project requirement,and/or what the funding source for such change is. _ 21. Exacerbating the problems caused by the angled parking on Pacific View Avenue is the fact that the Project design proposes primary and secondary intersections that serve as entries to both the residential and commercial portions of the Project. The primary entry indicates a circular drive for entry into both the hotel and retail portions. It is likely that severe 1 congestion will occur at this main intersection during peak periods, where inbound hotel or I banquet guests may queue up to the hotel porte-cochere and completely block access in the RMC-24 intersection and into the garage and retail portion. This will cause additional emergency access ! - problems. (Page 3.12-10 [the garage "could be a constrained access point in an emergency ': situation where vehicles are attempting to exit the facility and emergency response personnel need to gain entry"].) At The Waterfront site to the east,the hotel entries are not combined with j other uses or intersections, and a separate entry to the residential component away from the hotel jRMC-25 3-82 • • Ms. Mary Beth Broeren December 3, 2003 Page 6 entries avoids such conflicts. The Kimley-Hom report also suggests that these angles parking�RMC-25 spaces will disrupt eastbound traffic flow on Pacific View Avenue. 22. Left-turn lane lengths on Pacific View Avenue may be insufficient to handle peak I RMC-26 period volumes for turns into the main entry and need to be further studied and modified. 23. As noted in the Kimley-Horn report, the traffic study may also underestimate the volume of traffic on Pacific View Avenue when considering the Project's total generation, the generation of the adjacent hotel and residential uses at The Waterfront, and the assumption that a percentage of trips on Pacific Coast Highway will divert to Pacific View Avenue through the RMC-27 Project. As a result, the difficulties with the one-lane street design, inadequate left-turn lanes, on-street parking and combined-use entry intersections may be exacerbated and not adequately disclosed in the DEIR. 24. Lastly, with respect to the traffic and parking analyses, is the fact that the list on preparers in Chapter 6 of the DEIR indicates that LSA Associates, Inc. ("LSA") prepared the transportation/circulation portion of the DEIR. You have explained that Linscott Law and Greenspan("LLG")prepared these reports for the Project applicant, and the City retained LSA to review these reports. Upon my request you did locate and provide a copy of the LSA report. However, CEQA requires that the City make all reports referred to in the DEIR readily available RMC 28 for inspection by the public. The LSA report was not posted on the City's website as was the rest of the DEIR, nor included with the documents made available for public review at the City Planning Department counter or the public library. It is only by the most detailed scrutiny that a reader might find the reference to the LSA report, since it appeared on the 489th of the 495 pages of the DEIR. It appears that I may be the only person who noted the existence of the LSA report and requested a copy. This matter is important because the LSA report did question several issues in the LLG analyses. Some of the requested corrections and clarifications were made in the subsequent draft by LLG that was included with the DEIR. However, not all the important issues were addressed or clarified. In particular,we note that LSA stated the following: RMC-29 Table 10: Provide an explanation for Internal Capture and Mode Shift percentages that are used for each land use. There are no empirical data provided in the analysis or in any citation of a professional source to support the assumptions that are included in the picture in Appendix C. In order to provide some level of assurance and reasonability, more data and analysis should be included to justify the Trip Reduction Flow Diagram and the resulting adjustments to the gross trip generation. (emphasis added) V 3-83 Ms. Mary Beth Broeren December 3, 2003 Page 7 It appears that no empirical data or professional source was provided to support the,\ internal capture and mode-shift assumptions to justify the reductions in gross trip generation (which were also then incorporated into the shared parking analysis.) Based on the above comment in the LSA report,and the fact that no additional supporting information was provided, RMC-29 the reductions in trip generation must be concluded to be unreasonable. The matter has also been more fully discussed previously in paragraphs 3 and 4 of this letter and in the Kimley-Hom report. i We believe that the City's failure to include the LSA report in the published DEIR7 documentation, particularly in light of the fact that it contained information that questioned critical assumptions made in the traffic and shared parking analyses, did not serve the purpose of providing a full and complete disclosure of the potential circulation impacts associated with the Project. Therefore, the availability of the DEIR should be re-noticed and the LSA report should RMC 30 be included in the published DEIR documentation with clarification as to what portions of the LSA report were and were not revised in the LLG analyses, so that members of the public who may be interested in reviewing and commenting on the DEIR might have the opportunity to more fully understand the information regarding potential circulation impacts which is in the City's possession. 25. The DEIR's alternatives analysis is also deficient. CEQA requires that an EIR describe a reasonable range of alternatives to the proposed project, or to its location, that would feasibly attain most of the project's basic objectives while reducing or avoiding any of its significant effects. The DEIR ignores potentially viable offsite and onsite alternatives. Only one alternative site was considered(the Nesi Ascon site), and it was summarily rejected because it (i) is zoned solely for residential use and thus would not meet Project objectives of generating employment and strengthening the City as a visitor-serving destination, and (ii) would require extensive remediation since it is a former dump site. (Pages 4-24 to 4-25.) Other alternative RMC-31 sites are apparently available,but have not been evaluated. Although the DEIR states that "there are a limited number of sites" that could accommodate the size of the Project (page 4-24), that suggests that the Nesi Ascon site is not the only alternative site available. Moreover, the current zoning of the property is irrelevant in that a project application could easily include a general plan amendment/zone change to accommodate the commercial aspects of the Project and thus - meet Project objectives. Nor is there any indication that the'remediation necessary for the Nesi Ascon'site makes the site economically infeasible. After all, the proposed Project site also requires extensive remediation because of the presence of hazardous materials. (Chapter 3.7.) More alternative sites should thus be evaluated. ' 26. A second "alternative" that was summarilyrejected bythe DEIR was the "Limited Development Alternative." This alternative eliminated all office and hotel uses and included only 96,000 square feet of commercial use, which represents an approximately 85- RMC-32 percent reduction in the non-residential portion of the Project. Predictably, this extreme v 3-84 Ms. Mary Beth Broeren December 3,2003 Page 8 alternative was rejected because (i) it failed to meet the Project's objectives of strengthening /\ visitor-services of the area and the need for hotels in the downtown area to support the expansion of other services, and (ii) according to the Applicant,the reduction in the commercial/resort uses would "likely" render the Project infeasible. (Page 4-25.) No actual evidence, however, is presented to show infeasibility on economic grounds. Moreover, this "alternative" should not ' RMC-32 have even been considered for it was known to be untenable from the outset. It is obvious that such an extreme reduction of the commercial aspect of the Project, along with the complete elimination of hotel and office uses, would disable the alternative from meeting the project's defined objectives. The summary rejection of patently untenable alternatives does not satisfy an agency's obligation to consider a reasonable range of alternatives. 27. A third "alternative" that was summarily rejected by the DEIR was the "Reduced Residential Density Alternative," which focused on an unspecified decrease in the number of condominiums proposed as part of the Project. This alternative was rejected purportedly because it would not lessen the air quality and traffic impacts to less than significant levels. Again, there is insufficient evidence in the record, such as a discussion of the ADT involved as compared to the Project, to support that conclusion. Moreover, this approach erroneously assumes that an RMC-33 alternative must completely avoid a significant impact in order to be considered worthy of detailed analysis. Nothing suggests that reducing the residential portion of the Project would not substantially lessen the identified significant impacts, which is all that is necessary under CEQA to require analysis. Further, it should be noted that although the residential portion of The Waterfront site just east of the Pacific City site was originally zoned (and entitled through its original development agreement) for approximately 875 residential units, the density was later reduced to 184 units. Such reduction was found to be economically feasible, and substantially reduced the potential environmental impacts of that project. It is therefore logical to study in detail a substantial reduction in residential density as one of the project alternatives at the Pacific City project. 28. The DEIR misleadingly states that, aside from the alternatives summarily rejected, three alternatives were selected for detailed analysis: (i) The "No Project/No Development Alternative," (ii)the "Reasonably Foreseeable Development Alternative," and (iii) the "Reduced Project Alternative." This is misleading in that the first two purported alternatives are really just two aspects of the same "No Project" alternative which, under CEQA, must be evaluated in an EIR. (CEQA Guidelines § 15126.6(e) [the "No Project" alternative evaluation RMC-34 proceeds (i) along the "no build" line when the existing environment will be maintained if the project is disapproved or (ii) along the"foreseeable development" line when it is predictable that other development will be proposed if the project is disapproved].) Here, the "No Development Alternative"is irrelevant in that nothing indicates that disapproval of the Project would foreclose any development on the site. Moreover, this evaluation is redundant in that the DEIR already analyzes the Project's impacts against the baseline condition, which is the existing conditions on the site (the "no build" scenario). The only appropriate "No Project" evaluation in this case is v Ms. Mary Beth Broeren December 3, 2003 Page 9 the "Reasonably Foreseeable Development Alternative," which assumes maximum build-out r under the currently allowed land uses as designated,in the Downtown Specific Plan. RMC-34 29. Because the"No Development Alternative" is irrelevant under the circumstances, and because a "No Project" alternative is required to be analyzed in an EIR under CEQA, the DEIR actually analyzes only one true alternative to the Project, that being the Reduced Project Alternative. This limited review of alternatives is unreasonable. At the very least, the DEIR • should also include an analysis of a_"Reduced Hotel Alternative" for the Project, especially in light of the fact that, as the DEIR itself points out, the Downtown Specific Plan anticipates that visitor-serving commercial uses can be accommodated onsite with a 200-room hotel. (Page 3.9- 16.) And, because the commercial portion of the Project consists only of one- to three-story RMC 35 structures, it would certainly be reasonable, if only for aesthetic reasons, to at least explore a hotel of similar dimensions. Why would a three- or four-story hotel (100 to 200 rooms) not be considered when it obviously would have less severe impacts in terms of mass, bulk, and density of viewshed than the eight-story hotel proposed by the Project, and probably less severe impacts on all resources, including air quality and transportation (in that it would constitute a 35-50% reduction in commercial/resort uses)? Indeed, considering a Reduced Hotel Alternative would appear to be eminently more reasonable than considering, and then summarily rejecting, an alternative that includes an 85% reduction of non-residential uses (the Limited Development Alternative), or considering in detail an alternative that includes only a nominal 8% reduction of commercial uses (the Reduced Project Alternative). Because the DEIR considered a reduced residential alternative and a reduced commercial alternative,but not a reduced hotel alternative, it apparently assumed that a 400-room hotel is the minimum size necessary to achieve Project objectives. As stated, the Downtown Specific Plan -- directly contradicts this assumption. Moreover, the DEIR completely fails to analyze the stated objective of increasing visitor-serving facilities in relation to the fact that the Downtown Specific Plan also stated in Section 3.2.2 that District Nine, the site of The Waterfront development immediately to the east of the Project,was anticipated to have a total of 300 to 400 hotel rooms - developed at that location. Yet the Hilton and Hyatt hotels already have been constructed at The RMC-36 Waterfront site (for a total of 800+ rooms) and a third hotel site for up to 300 rooms has been approved at The Waterfront site as well. In light of these prior approvals that greatly exceed the objective for the number of hotel rooms 'expressed in the Downtown Specific Plan for District Seven'and Nine combined, is there even a need for a hotel on the proposed site? If so, what capacity is needed to meet the City's expressed objective? To what extent would a 100- or 200- room hotel, which would reduce the environmental impacts of the Project and still be consistent _ with the Specific Plan for the area, still meet the objective? The DEIR addresses none of these conspicuous issues. J 30. The failure of the DEIR to take into account the approved third hotel site for The d RMC-37 Waterfront site also vitiates the adequacy of the DEIR's cumulative impact analysis. For 3-86 • Ms. Mary Beth Broeren December 3,2003 Page 10 example, The Waterfront site's third hotel is not included in the cumulative impact section. n (Pages 2-32 and 2-33.) Nor was the third hotel site mentioned in the discussion of surrounding uses. (Page 2-5.) Thus, the cumulative impact conclusions throughout the document are j RMC-37 understated. For example, projected traffic from the third hotel's development is missing from the 2008 near term traffic analysis. These failures render the entire DEIR deficient. 31. The DEIR also fails to evaluate an alternative with both reduced commercial and-1 reduced residential portions. There is no explanation as to why the alternatives are limited to an RMC-38 "either/or" context (either reduced commercial or reduced residential, but not a combination thereof). — 32. Nor does the DEIR explain why a reconfigured Project was not evaluated. This ; would seem to be reasonable in light of the fact that the hotel, which would have the highest RMC-39 concentration of people, is proposed for the southeast portion of the site, which has the highest liquefaction potential,the highest settlement potential, and the most corrosive soils. 33. The DEIR also fails to adequately evaluate the impacts of the Project on the wetlands onsite. It concedes that the site "in its current state, could be considered a wetland due to the presence of hyrophitic vegetation within the remediation pits." (Page 3.3-22.) It then states that under the law, the Applicant will have to review the conditions that exist at the site RMC-40 after the soil remediation pits are refilled, and if potential wetlands are identified at that time the Applicant would be required to obtain permits from the City and the California Department of Fish and Game. The DEIR then simply concludes that compliance with existing laws, including the State's "no net loss" policy, would ensure that the impacts are less than significant because any loss of wetlands could be mitigated by restoring or otherwise providing for additional_, wetlands offsite. This analysis is deficient for several reasons: First, the analysis assumes that the Applicant will automatically be permitted to refill the RMC-41 remediation pits. Under the California Coastal Act, the Applicant may not be allowed to destroy those wetlands by refilling the pits. Second, even were refilling allowed, the analysis erroneously assumes that a "no net loss" policy would apply to any wetland condition that still existed, allowing the Project to proceed as long as there were offsite mitigation. Because the site is within the coastal zone, the 1 applicable policy would not permit the Applicant to destroy wetlands and mitigate that loss I offsite. (Bolsa Chica Land Trust v. Superior Court (1999) 71 Cal.App.4th 493.) Development of wetlands with any of the proposed Project uses would not be allowed under Public Resources +� RMC-42 Code section 30233(a). Indeed, as the experience at The Waterfront project showed, even with offsite mitigation approvals pre-dating the Bolsa Chica case, and the specific, affirmative vote of the Coastal Commission to allow offsite mitigation, the Commission's staff intervened to derail`i' 3-87 Ms. Mary Beth Broeren December 3, 2003 Page 11 the offsite mitigation. Therefore, the assumption that offsite mitigation could occur is� unreasonable. RMC 42 It should be determined now whether the Applicant will be allowed to destroy those portions of the site that constitute wetlands as part of the remediation of the site. If not, the extent of the wetland parameters should be determined and mitigation measures developed (e.g., RMC-43 relocating structures away from the wetlands) to avoid any impact thereon. It is improper to defer such determinations to sometime in the future, especially in light of the fact that the DEIR erroneously assumes that the property owner will automatically be allowed to refill the i remediation pits and that any impact on wetlands can be addressed by offsite mitigation. 34. The DEIR also fails to adequately evaluate various impacts, unlawfully defers analyses and mitigation, and fails to impose concrete, effective, and enforceable mitigation measures. For example, many of the mitigation measures discussed in the DEIR are couched in I • vague and unenforceable terms. Thus, the Project is required to use non-reflective facade treatments and to not use electrical generators powered by internal combustion engines during construction, but only "to the extent feasible." (DEIR, pp. xxiv, xxv.) Further, contract RMC-44 specification language to mitigate air quality impacts need only be reviewed (but not approved) by the City. (Id., pp. xxiv to xxvi; compare with xxix, xxxii, and xxxiii where other plans and permits are required to be reviewed and approved.) No performance standards are imposed to ensure that mitigation will actually effectively occur. Agencies cannot rely on vague, incomplete, or untested mitigation measures, and an EIR is inadequate if suggested measures are j so undefined that it is impossible to evaluate their effectiveness. (San Franciscans for Reasonable Growth v. City and County of San Francisco(1984) 151 Cal. App. 3d 61,79.) 35. In other portions of the DEIR, certain impacts are identified as potentially significant, but are not mitigated as required by CEQA. For example, the DEIR finds that construction effects associated with on-site recreational facilities would significantly affect the --' environment over the short term. Although no mitigation measures are imposed to deal with RMC-45 these impacts, the DEIR simply concludes that the impacts are less than significant. (Page xxxv.) The conclusion does not jibe with the analysis or the requirements of CEQA. 36. Other analyses conclude that no mitigation measures are necessary because the impacts involved are less than significant. The reasons cited, however, do not support the conclusions. For example, the DEIR states that police services are currently provided at a ratio of 1.1 officers for every 1,000 residents, which is considered merely "adequate," and that police equipment is at"minimum levels." (Pages 3.12-10, 3.12-11.) Although the DEIR acknowledges RMC 46 that the project will reduce the existing service ratio to 1.09 officers per 1,000 residents and will put an increased burden on police equipment, it simply concludes that this impact is less than , significant because "the City is not considered a high crime area." (Page 3.12-11.) This misses the point. Presumably, the perceived adequacy of the current service ratio and equipment levels \J 3-88 Ms. Mary Beth Broeren December 3, 2003 Page 12 already takes into account the crime rate in the City. And, if police services are at minimum levels now, logically the development of a significant new project with new demands, but with no increase in public safety resources, would mean that the police department would be RMC-46 functioning below minimum levels once that project is developed, whether or not the City is a high crime area. Thus,this impact is significant and must be mitigated. 37. Similarly, the DEIR_states that the proposed project could release toxic air contaminants, but not in significant amounts. (Pages xxvi, 3.2-18.) The basis of this finding is not disclosed, and the document simply concludes, without any quantification, that any impacts would be less than significant. The DEIR should evaluate the Project's potential cancer risks from diesel sources under the SCAQMD's guidance document on this topic, "Health Risk RMC-47 Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis," which is available online. The lack of any quantification or information as to the basis of DEIR's conclusion does not comport with the substantial evidence standard required for an EIR. 38. As for the DEIR's air quality analysis in general, the SCAQMD CEQA Air-1 Quality Handbook requires that the most current EMFAC emissions factors and projected future CO concentrations (both provided online) be used in determining on-road mobile source vehicle RMC 48 emissions and CO Hotspots Analysis. It is not clear from Air Quality Data (Appendix B of the DEIR)whether the DEIR complied with these requirements. — 39. Another example of an area where mitigation measures were improperly deemed unnecessary is emergency access. The DEIR acknowledges that the Project "could result in several thousand persons on the site simultaneously,"and that the subteiranean garage "could be a constrained access point in an emergency situation where vehicles are attempting to exit the facility and emergency response personnel need to gain entry." (Page 3.12-10.) This is also acknowledged in the Executive Summary where it states that "project design may not provide RMC-49 adequate emergency access." (Page xxxiv.) The mitigation measures dealing with public service impacts, however, simply provide for fire-rated stairs, a mechanical smoke removal ' system, and dedicated rooms for the fire department to observe, monitor, and control emergency systems. Nothing is provided to mitigate the acknowledged inadequate emergency access. (Page-3.12-15.)Despite the acknowledgement that project design does not provide adequate emergency access and the dearth of mitigation measures to deal with that inadequate design, the DEIR concludes that the project would not result in inadequate emergency access, and concludes that public service impacts are less than significant. (Pages xxxiv, 3.14-72, 'cavil [project "would RMC 50 not result in inadequate emergency access"].) No evidence supports this fording. (Pages 3.14-72 to 3.14-77 [only non-emergency customer/service access driveways are addressed].) In fact, the finding is directly contradicted by the referenced portions of the DEIR. 3-89 Ms. Mary Beth Broeren December 3,2003 Page 13 40. The DEIR finds that the southeastern corner of the Project site (where the hotel is to be located) is "underlain by loose to medium dense alluvial deposits," and that the "potential for liquefaction within the alluvial area . . . varies from moderate to high to very high, with most of the area designated high to medium potential . . . ." (Pages 3.6-8 to 3.6-10.) On the contrary, Figure 3.6-3 shows that most of the area is designated as very high potential. (Page 3.6-9.) RMC-51 Thus, the DE1R's liquefaction analysis is based upon a faulty premise and understates potential impacts. Moreover, the fact that the southeast portion of the site has the highest liquefaction potential, the highest settlement potential, and the most corrosive soils also establishes that the DEIR should evaluate an alternative that re-locates the hotel, which would have the highest concentration of people,to a different portion of the site. 41. The DEIR also fails to evaluate certain impacts altogether. For example, although the Project provides for 516 units of housing, it generates more new jobs (601) than housing. (Pages 3.11-13, 3.11-17.) Because of the current housing shortage in Orange County, the DEIR RMC-52 should evaluate whether the Project will exacerbate the County's jobs/housing imbalance and, if so,the environmental impacts that could result from that. It has failed to address this issue. 42. Another example of the failure to adequately evaluate impacts is in the area of S hydrology/storm drainage. As set forth in the attached report of Richard Watson &Associates, Inc., an expert in storm water issues (see Exhibit "B" to this letter, which is incorporated by this reference as if fully set forth herein), the DEIR fails to evaluate the fact that the proposed storm water filtration system does nothing for bacterial levels,yet discharges directly to the beach. The current site drainage goes to the Atlanta pump station, and during the dry weather months, that discharge is diverted to the Orange County Sanitation District. Because of this diversion ; RMC-53 program in large parts of the City,bacterial levels at the,beach have fallen. The proposed change in the drainage pattern, notwithstanding the proposed filtration systems by Stormwater Management, Inc.,will have an adverse effect on bacterial levels at the beach. As a result, as the attached report states, "There is a high probability that the project will violate water quality standards for pathogens unless additional treatment control BMPs are added to the project to remove bacteria and viruses from dry-season and first-flush flows before they are discharged to South Beach." Further, as the report describes in greater detail, the DEIR is deficient and in error by reporting that no significant environmental impact will result. —+ - 43. The DEIR also failed to adequately consider the option of upgrading the Atlanta Stormwater Pumping Station to accept the Project's storm water flows. Rather, the DEIR concludes, "the project would result in decreased flows to the Atlanta Stormwater Pumping Station, which would be a beneficial effect". However, improving the capacity of the Atlanta Stormwater Pumping Station would have the more beneficial effect of allowing dry-season flows RMC-54 to be diverted to the Orange County Sanitation District, and further, to increase public safety by reducing the generalized risk of flooding associated with the apparent existing under-capacity of the Atlanta Stormwater Pumping Station. 3-90 Ms. Mary Beth Broeren December 3, 2003 Page 14 44. Lastly, the DEIR failed to consider the fact that the existing First Street storm water outfall at the beach currently discharges waters containing bacteria and other pollutants from other existing portions of the City directly onto the City's busiest beach and into the ocean. Low flows and nuisance discharges currently pond at the outfall discharge point, at least allowing the potential for some elimination of pathogens from prolonged UV exposure and i drying, but significant public exposure and health risk still does exist in this condition. See the RMC-55 photographs attached as Exhibit "C"to this letter illustrating this point. A warning sign is posted at the outfall that states, "WARNING! RUNOFF/STORM DRAIN WATER MAY CAUSE ILLNESS -- AVOID CONTACT WITH PONDED OR FLOWING RUNOFF AND THE AREA WHERE RUNOFF ENTERS THE OCEAN" Even if the additional storm water flow from the Project were fully sterilized, the additional quantity of water discharging at the outfall created by the new 26.9 acres of tributary area from the Project would potentially cause the existing polluted and ponded water to flow into the ocean when previously it would not have; thereby transporting pathogens to the ocean and increasing the risk of unsafe bacteria levels within the ocean waters. It hardly need be RMC 56 mentioned, but even the remote possibility that bacteria levels in the ocean might be increased, creating the specter of renewed beach closures and adverse publicity for the City, is a significant environmental and economic risk that should have been disclosed in the DEIR and should be unquestionably avoided. Thank you for the opportunity to review and comment on the proposed Project. Because the DEIR has failed to comply with CEQA in the manner described'above, it is respectfully RMC-57 requested that the City reevaluate the many environmental impacts of the Project, revise the environmental documents,and re-circulate the revised documents for additional public comment. THE ROBERT MAYER CORPORATION Shawn K. Millbem Senior Vice President,Development Attachments: Exhibit "A": Kimley-Horn Associates report Exhibit"B": Richard Watson&Associates, Inc. report Exhibit"C": Photographs of First Street Storm Drain Outfall 3-91 conKimleyHorn and Associates, Inc. Suite 140 2100 W.Orangewood Avenue December 2,2003 Orange,California 92868 Mr. Shawn Milbern The Robert Mayer Corporation 660 Newport Center Drive,Suite 1050 Newport Beach,CA 92658 Subject: Pacific City Traffic Study Review Dear Mr.Milbem: We have reviewed the Traffic Impact Analysis (LLG, April 21, 2003) and Parking Study (LLG, October 15, 2003) for the Pacific City development in the City of Huntington Beach. Our review comments are attached. RMC(A)-1 Our review focused on the underlying trip generation and parking assumptions for the development, and the project's traffic and parking impacts on the area immediately surrounding the project site. Please contact me if you have any questions, or if you need additional information. Sincerely, KIMLEY-HORN AND ASSOCIATES,INC. Serine Ciandella,AICP Associate TEL 714 939 1030 - - 3-93 FAX 714 938 9488 Kei M9einij t ern) Pacific City Traffic Study Review Atlanta Avenue at Huntington Street Signal Item 7.on page ii of the Executive Summary of the Traffic Study states: , "As indicated in the 1998 Updated Waterfront Ocean Grand Resort Transportation RMC(A)2 and Circulation Analysis, the intersections of Beach Boulevard at Pacific View • Avenue and Atlanta Avenue at Huntington Street were assumed to be signalized intersections and analyzed as such." This statement is repeated on page 50 of the Traffic Study,and is referenced again on page 62. With regard to the intersection of Atlanta at Huntington, this statement is in error. The Waterfront study did not analyze the intersection of Atlanta Avenue at Huntington Street. The RMC(A)-3 intersection is still unsignalized, and the Waterfront Ocean Grand project is not conditioned to signalize the intersection. , In the Pacific City Traffic Study, although the statement was made several times that the intersection was assumed to be signalized, the Year 2008 intersection analysis summary presented on Table 12 (page 52) indicates that the intersection of Atlanta / Huntington was assumed to be unsignalized in the "Without Project" condition, and signalized in the "With RMC(A)-4 Project" condition. Furthermore, based on the intersection analysis worksheet in Appendix D, if left unsignalized, the project traffic will cause the intersection to worsen from LOS "D" to LOS "E"(45.78 average seconds delay per vehicle). The Pacific City project should be responsible for installation of a traffic signal at the intersection of Atlanta Avenue at Huntington Street,for the following reasons: • The intersection is located at the northeast corner of the project site, and the project will widen the street along the project frontage to provide additional travel lane width. RMC(A)-5 • The project trip distribution assumptions,presented on Figures 7A-7C (pages 34-36), assume over 20%of the project traffic will travel through the intersection. - .• The intersection will operate at LOS "D" (28.0 average seconds delay per vehicle) in the evening peak hour without the project. • If left unsignalized, the project traffic will cause the intersection to worsen from LOS "D"to LOS"E"(45.78 average seconds delay per vehicle). Project Trip Generation — The project trip generation discussion for the Pacific City project, which starts on page 30, RMC(A) 6 indicates that reductions in project traffic were taken into account for "internal capture" and "mode-shift". 3-94 - 1 - Internal Capture The internal capture reduction was applied to account for the trip interactions between the proposed uses within the project. Internal capture is a legitimate reduction of external trips for mixed-use developments such as Pacific City, and the methodology for calculating internal RMC(A)-7 capture is well documented in the Institute of Transportation Engineers Trip Generation publication(6th Edition). The ITE methodology for calculating internal capture applies percentages for interactions between pairs of land uses to both the trips originating from each land use, as well as the trips destined for each land use; compares the resulting trips between each pair; then selects the lesser ; RMC(A)-8 of the two. The ITE methodology applies to midday, PM peak, and daily. ITE does not provide any internal capture assumptions for the AM peak hour. Using the specific mix of uses proposed in the Pacific City project, the ITE reduction for internal capture would be as follows: Daily: 2,214 trips(13.4%reduction) AM peak: no reduction RMC(A)-9 PM peak: 234 trips(14.6%reduction) A copy of Internal Capture worksheets using the ITE methodology is attached. The internal capture assumptions used in the Pacific City traffic study do not reflect the ITE methodology. The internal capture assumptions are presented in a hand-drawn diagram in Appendix C of the study. In some cases, the Pacific City reduction percentages are less than the RMC(A) 10 ITE methodology. In other cases, the morning peak hour in particular, the Pacific City assumptions exceed ITE, since ITE does not provide for any AM peak internal capture reduction. In either case,no explanation for the percentages assumed in the Pacific City study is provided. For comparison purposes, the internal capture reductions assumed in the Pacific City traffic study are as.follows: Daily: 1,552 trips(9%reduction) RMC(A)-11 AM peak: 64 trips(10%reduction) PM peak: 155 trips(10.2%reduction) The study should use the ITE internal capture assumptions (which will actually produce slightly greater reductions for the daily and PM peak hour conditions), or provide a source for the RMC(A)-12 - assumptions used. Mode-Shift The Pacific City Traffic Study indicates that, in addition to the internal capture reduction, a mode-shift reduction was applied to the traffic generation forecast to account for the trip RMC(A)-13 interaction between the Pacific City project uses and the beach and downtown areas. No other explanation is given,and no source for the percentage reductions is provided. "Mode shift" typically refers to a change in an individual's travel mode from automobile tc;—.1 another mode, such as transit, rail, carpooling or vanpooling, bicycling, or walking. It does not ; RMC(A)-14 3-95 -2- -s typically refer to people who drive to one location,such as the beach or downtown area,and then opt to also patronize the Pacific City development by walking'/4 to %s mile to and from the site. RMC(A)-14 In effect, as used in the Pacific City report,the mode-shift reduction is really an expansion of the internal capture process to include the broader beach and downtown area by assuming that these popular areas provide a ready-made pool of customers. Just as people who are already on site at the Pacific City development will interact with other uses,the assumption is that people who are RMC(A)-15 already in the downtown and beach area will also patronize the Pacific City uses. This assumes that people will a.)come to the downtown and beach area for a separate purpose or purposes,b.)decide to also patronize the Pacific City development,and c.) walk the '%to'A mile to the Pacific City development and back again. The hand-drawn diagram in Appendix C indicates that, over and above the internal capture reduction, 20% of the total daily retail and hotel traffic and 10%of the total daily residential and office traffic would be comprised of the people described in the preceding paragraph. These percentages equate to almost 3,000 trips per day(1,500 in and 1,500 out). In the PM peak hour, RMC(A)-16 the percentages increase to 25%for hotel and retail, and 15%for residential,for a total reduction of 330 trips in the PM peak hour. Assuming an average of 2 people per car, the assumption is that 3,000 people each day and 330 people in the evening peak hour on a typical weekday will walk to Pacific City from the beach or downtown area. • • Again, these reductions are over and above the internal capture reductions. No justification for these percentages is provided. RMC(A)-17 Even if one accepts the assumption that some people will leave their original downtown or beach destination and walk to Pacific City and therefore trip-making to the site is reduced, the quantity of the reduction is in question. The traffic study provided a detailed discussion on pages 2 and 3 and in Appendix J regarding typical weekday peak traffic vs. peak summer traffic, to justify RMC(A)-18 conducting only "typical weekday" traffic analysis. And the trip generation discussion on page 30 states that,"Table 10 presents the daily,AM and PM peak hour traffic volumes on a"typical" weekday for the proposed project." _ A drive along PCH and Main Street in downtown Huntington Beach on a typical weekday during the months of October through May would suggest that the assumption that 3,000 people per day, and over 300 people in a single evening peak hour will leave their original.downtown or beach i RMC(A)-19 area destination to walk to Pacific City and back again is an overly optimistic assumption. It seems more likely that patrons of the new Pacific City development will make Pacific City their primary destination, and perhaps walk across to the beach or to downtown as a secondary destination. The study should provide a source and justification for the mode-shift reductions,or the reduction in project traffic should not be taken. Further discussion of the issue of"capturing" customers I RMC(A)-20 from the ambient downtown and beach crowds is provided in the discussion of parking. Related Projects(Year 2008)Analysis The Related Projects discussion in the Pacific City traffic study,which starts on page 40,presents a list of 14 planned and/or approved projects. Of the 14,the study indicates that one project and a ; RMC(A)-21 portion of another project are to be completed after Pacific City, and therefore were not included in the traffic analysis. Nit 3-96 -3- Of the two projects listed as scheduled for completion after Pacific City, one was the Hotel component of the Waterfront project, which is located immediately adjacent to the Pacific City project site. The study identifies the Waterfront project as follows: "Waterfront Residential Development (184-unit residential development located at RMC(A)-21 Beach Boulevard and PCH,adjacent to the Ocean Grand Resort project and a 300-room hotel to be constructed after 2008)Residential component included in traffic impact analysis." Typically, any identified approved or pending project is included in the Related Projects analysis, even if there is a possibility that the project may not be completed by the analysis year. In the case of the Waterfront 300-room hotel, there is no restriction in place that would preclude the RMC(A)-22 hotel from being constructed prior to 2008. Given the proximity of the future hotel site to the Pacific City project site, and the fact that the Waterfront Hotel could be developed prior to 2008, the Year 2008 analysis should be re-done to include the Waterfront Hotel. _ Parking Proiect Summary • Comparing Table 2 of the Traffic Study(page 10)with Table 1A of the Parking Study (the first page following page 13), there are substantial differences in the retail and restaurant square RMC(A)-23 footages, and a slight reduction in ballroom square footage. Which is the correct project summary? If the Traffic Study land use summary is correct(with the higher amount of restaurant square footage), the parking study has analyzed an incorrect land use mix, and assumes a lesser parking requirement. _ Total City Code Parking Requirement RMC(A)-24 The parking analysis understates the raw (unadjusted) project parking requirements per the City of Huntington Beach code requirements. On page 3 of the Parking Study;last paragraph,the city code requirement for Hotel is stated to be: a "1.1 spaces per room of hotel use plus one space per passenger transport vehicle f RMC(A)-25 (minimum S of two) and any additional uses within the hotel (i.e. banquet/meeting/ballroom,restaurant,and spa)." J Table 2A indicates that the City Code parking requirement for the entire project would be 1,888 spaces,plus the 53 replacement spaces. But the hotel uses listed in the table include only the 400 ' RMC(A)-26 hotel rooms and the 5,000-square-foot signature restaurant. The 16,000-square-foot Ballroom and the 15,000-square-foot Hotel Spa are not listed. Based on Shared Parking Table 5A of the Parking Study,the additional raw parking requirement, for the ballroom would be 124 spaces (assuming only 9,300 square feet of assembly area, 30 square feet per person, and 2.5 persons per vehicle), and 90 spaces would be needed for the spa, for a total of another 214 parking spaces. Accepting the lenient calculations for the Ballroom RMC(A)-27 (discussed in the next section), the total City Code parking requirement for the Pacific City project, including the 53 replacement spaces,would be 2,155 spaces. Assuming the City's actual parking requirement for Ballroom, as discussed in the next section, the parking requirement for the Ballroom would be 266 spaces (assuming 9,300 SF of assembly area) or 457 spaces W 3-97 -4- r (assuming 16,000 SF of assembly area),bringing the total City Code parking requirement for the Pacific City project to 2,297 to 2,488 spaces (depending on the actual size of the Ballroom RMC(A)-27 assembly area—see next discussion). _ Ballroom Parking Requirement No discussion is provided to explain the parking assumptions associated with the Ballroom. RMC(A)-28 Table 2A and Table 4A of the Parking Study summarize the project's parking requirements, but make no mention of the Ballroom. The Shared Parking analysis does include the Ballroom. — The Traffic Study lists the Ballroom as 16,000 square feet(Table 2,page 10). The Parking Study lists the Ballroom as 15,000 square feet (Table 1A). The shared parking analysis (Tables 5A— 6B) apply parking requirements to only 9,300 square feet of area. Presumably,the 9,300 square RMC(A)-29 feet is the actual assembly area, exclusive of pre-function, kitchen, hallways, bathrooms, and storage areas. This should be confirmed,and if so,it should be clearly stated as such. — The Shared Parking tables indicate that the parking requirement for the Ballroom (listed in column 3, with the heading of Hotel Conference/Meeting Rooms) is derived by dividing the 9,300 square feet by 30 square feet per person, and then assuming that people will arrive 2.5 people to a vehicle,for a parking requirement of 1 space per 75 square feet. What is the basis for RMC(A)-30 -- these assumptions? The City of Huntington Beach City code calls for 1 parking.space per 35 square feet of assembly area, or 1 space per 3 fixed seats. Assuming 9,300 square feet of assembly area, the Ballroom parking requirement would be 266 spaces. If the actual Ballroom (assembly area) is 16,000 square feet, the parking requirement would be 457 spaces. The Ballroom parking requirement needs to be clarified and included in the parking analysis. Parking Reductions In addition to not including the parking requirement for the Ballroom and the Hotel Spa, the RMC(A)-31 parking study then proceeds to take further compounded parking reductions for 1.)shared parking relationships among mixed uses, 2.) guest use of hotel facilities, and 3.) walk-in traffic from the downtown and beach areas. Shared Parking In general, the shared parking analysis was conducted in accordance with thee Urban Land Institute Shared Parking methodology. While some of the time-of-day usage factors included in RMC(A)-32 the ULI Shared Parking report may not be directly applicable to a beach resort development such as Pacific City, in general, a shared parking approach is an appropriate application for a mixed- use development such as Pacific City. — It should be noted,however,that the valet parking operation proposed for the hotel component of the project could have an adverse impact on the success of a shared parking program. How many parking spaces will be designated for valet use only? Shared parking is based on the premise that any parking space can be occupied by any use on the site, and that parking that is not needed by one use at a particular hour of the day will be available to all other uses, if needed. Spaces that RMC(A)-33 are set aside for valet parking will not be available to visitors of the restaurant and retail components of the project. The ULI shared parking analysis indicates that the hotel will be operating at 60% of its peak during the midday, when retail is at 95% and restaurants are at 100%. Will the 177 un-used hotel spaces be available for use by other visitors to the site, or will they be marked valet only? • 3-98 -5- • 9 •I •• Guest Discount for Hotel Uses While a shared parking approach is an appropriate application for a mixed-use development such as Pacific City, to apply a discount to account for guest use of the hotel facilities on top of the ULI discount is not. The City requires that the parking code be applied to individual on-site hotel amenities, such as the spa, restaurant, and ballroom, to account for the fact that providing these RMC(A)-34 facilities on site not only attracts outside customers,but also results in hotel guests staying in the hotel,rather than leaving to go to off-site businesses. Whether the customer of the restaurant or spa or ballroom is a guest or a non-guest,a parking demand is generated. To discount the parking requirement to account only for non-guest use of the facilities, and then to further discount that parking demand by the ULI time-of-day usage factors results in a double parking discount. For example, at 7:00 PM, the'ULI weekday chart on Table 5A shows that the hotel parking demand would be at 75%, which would mean that at that time, 110 of the 442 hotel parking spaces would be available for use by customers of other Pacific City uses. Presumably, 25% of the hotel guests have left the hotel for some purpose, such as dinner. At the same time, the signature restaurant is shown to be at 100%. But the adjustment at the top of the table assumes RMC(A)35 that only 25% of the demand at the restaurant is non-guests, and that the parking demand for the j restaurant would only be 13 spaces,which would mean that 37 of the 50 restaurant spaces would also be available to be shared by other uses. This suggests that between the hotel and the signature restaurant, a total of 147 spaces are available to be shared by customers of other uses within the Pacific City development. But the assumption that only 25%of the restaurant demand is non-guests means that 75% of the restaurant demand would be hotel guests. 75% of the 50 parking spaces for the signature restaurant (37 spaces), would be needed by the hotel guests, because they didn't leave the hotel for dinner. So, between the hotel and the restaurant, the number of spaces available to be shared would be 110 spaces, not 147. The same argument applies to the discounts taken for non-guest patrons of the Ballroom and the spa. The double discount is inappropriate,and should be corrected. Walk-In Discount T • The earlier discussion regarding "mode-shift" trip reduction comes up again with regard to the parking analysis. The Parking Study assumes a discount in parking requirement to account for patrons who will walk in from the surrounding downtown and beach areas. What is the basis for RMC(A)-36 assuming a 20%reduction in parking for the restaurants and 15%for retail? It seems more likely that people wishing to patronize the new Pacific City retail and restaurant uses will want to drive directly to Pacific City, and park close to their destination, rather than walk 'A to V2 mile from downtown and beach areas. _J In.addition to the issue of walking distance,it is assumed that the parking for Pacific City will be paid parking, and that the Pacific City shops and restaurants will validate parking in their own parking facilities. It is further assumed that Pacific City shops and restaurants will not validate parking tickets for people who park in City structures or in beach parking lots. It does not seem RMC(A)-37 likely that Pacific City customers will leave their car in beach or downtown parking areas, where the cost to park will be their own expense, and walk to Pacific City and back again. It is more likely that people will prefer to park in the Pacific City parking areas within a comfortable walking distance of their intended destinations, and where they know their parking will bJ validated. 3-99 -6- • I r It is also important to note that during the peak downtown and beach seasons,which are the times that would have the most potential for providing an ambient customer base for Pacific City, the RMC(A)-38 downtown parking and beach parking are frequently impacted,and finding a parking spot can be difficult. It is unusual for a development to assume that 15 to 20%of a project's parking demand will be satisfied by off-site parking supplies that are located up to V2 mile away, especially in an area where existing parking demand is substantial. It is Pacific City's obligation to provide adequate RMC(A)-39 on-site parking to satisfy its own parking demand, and to not expect the existing downtown and beach parking supply to satisfy 15 to 20% of its parking needs. If inadequate on-site parking is provided, then Pacific City parking demand could spill over into the downtown and beach parking lots,further impacting these parking areas. Parking Rates per Downtown Parking Master Plan Although the Pacific City development is not located in,Downtown Specific Plan area, the RMC(A)-40 Parking Study does provide a parking summary (on Table 4A) using the Downtown Parking Master Plan codes for comparison purposes _J The Downtown Parking Master Plan has developed separate parking rates for downtown uses, specifically to account for the close interactions between the food, retail, and office uses in the ' RMC(A)-41 downtown area. Downtown parking rates have been.reduced by 40%for retail uses, and by 50% for office uses,when compared to City code. The restaurant rate is the same as the City code. Although the Pacific City development is not located within the Downtown Specific Plan area, due to its proximity to the area,it has been assumed that it will experience substantial interaction with downtown area. Accordingly, it would appear to have been appropriate for the parking for RMC(A)-42 Pacific City to be based on the Downtown Master Plan parking rates (as shown on Table 4A in the Appendix G to the Traffic Study, and as clarified below), and forego the unsubstantiated discount for downtown and beach interaction. It should be noted that the parking rates shown on Table 4A of the Parking Study(in Appendix G to the Traffic Study) do not reflect the current Downtown Parking Master Plan parking rates shown in the Downtown Specific Plan(Revised 2/06/02). The parking rates shown on Figure 4.2 RMC(A)-43 of the Downtown Specific Plan are 1 space per 333 SF of Retail (as opposed to 1 per 250 SF on I Table 4A)and 1 space per 500 SF of Office(as opposed to 1 per 1,000 SF on Table 4A). . _j Applying the Downtown Parking Master Plan rates to the project, and including parkingT requirements for the Spa (90 spaces) and Ballroom (266 to 457 spaces — see prior discussion), RMC(A)-44 would produce a project parking requirement of 1,841 to 2,032 spaces. Conclusion When evaluating the adequacy of the proposed parking supply of 1,543 spaces, consideration should be given to the "raw" parking requirement of 2,488 spaces, based on City parking code. RMC(A)-45 The proposed parking supply represents a reduction of 945 spaces when compared to the City code,based on shared parking, walk-in business,and reductions for guest use of hotel amenities. This parking reduction represents 38%of the unadjusted parking requirement. The summary on page 11 of the Parking Study in Appendix G of the Appendix to the traffic study states, RMC(A)-46 3-100 -7- • " . . . with the addition of the 53 spaces to be relocated on-site,the total parking demand for the Visitor-Serving commercial project.is 1,535 parking spaces. RMC(A)-46 With a proposed on-site parking supply of 1,543 parking spaces, a parking surplus of 8 spaces is forecast." With a parking reduction of 945 spaces, which depends on a number of concurrent reduction factors to be in effect at the same time (shared parking, walk-in business, and guest use of RMC(A)-47 facilities),a parking surplus of 8 spaces seems to leave little room for error. Using the Downtown Parking Master Plan rates, which already take into account interactions and shared parking relationships between downtown uses, would result in a parking requirement of RMC(A)-48 1,841 to 2,032 spaces,which is more in keeping with the parking requirements for the downtown area. Pacific View Avenue Roadway Configuration T Page 86 of the Traffic Study states that Pacific View Avenue would operate at LOS B or better as a two-lane divided roadway between 15t and Huntington Streets under any of the four scenarios analyzed. This is based on a forecast of 8,000 to 11,000 ADT and a daily capacity of 18,000 RMC(A)-49 ADT. What is the basis for assuming only 5% of the traffic on PCH will divert to Pacific View Avenue (in Scenario 1)? With the combination of traffic from the Waterfront development and the attractiveness of Pacific View as a parallel route between Beach Boulevard and 1st Street, and given the volume of traffic on PCH,it seems the daily volume on Pacific View Avenue could be substantially higher. • The daily LOS notwithstanding, it seems the proposed diagonal parking along the south side of Pacific View Avenue between the project entrances has the potential to create conflicts with 1 through and turning traffic. Drivers backing out of these spots, and other drivers waiting to take 1 RMC(A)-50 these spots will hinder the eastbound movement of other vehicles along Pacific View Avenue. I This will be most noticeable on weekends and evenings, when traffic demands to and from the Pacific City development will be at its greatest. On a related note, Exhibit 18 of the Traffic Study (page 68) shows 30 angled parking spaces proposed,while the exhibit in Appendix K of the Traffic Study shows 39. Which is correct? J RMC(A)-51 II 3-101 • -8- co O N MULTI-USE DEVELOPMENT--INTERNAL CAPTURE WORKSHEET PROJECT NAME: PACIFIC CITY LAND USE A: RETAIL+HOTEL PROJECT NO.: ITE LU Code Size TIME PERIOD: DAILY Total Internal External Enter 6,491 598 5,893 Exit 6,491 500 5,990 Total 12,981 1.098 11,883 % 100% 8% 92% RETAIL+HOTEL -ETAIL+HOTEL RETAIL+HOTEL RETAIL+HOTEL Land Use A Land Use A Land Use A Land Use A Exit Demand Enter Demand Exit Demand V Enter Demand 3% i j 4% 260 11% 714 9%! 5841 Balanced 1 67I 99 Balanced Balanced 433 499 Balanced • 15% 67 • 22% 99 ( 33%! 43 I 38%1 499 I OFFICE OFFICE RESIDENTIAL RESIDENTIAL Land Use B Land Use B Land Use C Land Use C Enter Demand Exit Demand Enter Demand Exit Demand LAND USE B: OFFICE LAND USE C: RESIDENTIAL OFFICE RESIDENTIAL ITE LU Code Land Use B Land Use C ITE LU Code Size Enter Demand Balanced Exit Demand Size Total Internal External 0% - I - , 0% - Total Internal External Enter 448 67 381 ► Enter 1,313 442 871 Exit 448 108 340 2% 91 91 3% 39 Exit 1,313 499 814 Total 896 175 721 OFFICE Balanced RESIDENTIAL Total 2,626 941 1,685 100% 20% 81% Land Use B ••• Land Use C • % 100% 36% 64% Exit Demand Enter Demand NET EXTERNAL TRIPS Land Use>>»» A B C Total Enter 5,893 381 871 7,145 Exit 5,990 340 814 7,145 Total 11,883 721 1,685 14,289 Internal Capture Single Use Trip Generation 12,981 896 2,626 16,503 0.134151 I INTERCAP/DAILY 12/2/2003/5:02 PM MULTI-USE DEVELOPMENT -INTERNAL CAPTURE WORKSHEET PROJECT NAME: PACIFIC CITY LAND USE A: RETAIL+HOTEL PROJECT NO.: 0 ITE LU Code Size TIME PERIOD: PM PEAK Total Internal External Enter 564 52 512 Exit 589 57 532 Total 1,153 109 1,044 % 100% 9% 91% RETAIL+HOTEL - TAIL+HOTEL RETAIL+HOTEL RETAIL+HOTEL Land Use A Land Use A Land Use A Land Use A ' Exit Demand Enter Demand Exit Demand Enter Demand 3% 18, 2% 11 12% 711 9% 51 Balanced 8 11 Balanced Balanced 50 41 Balanced I 31%1 81 MEM - 28 31%11.110 53% 41 OFFICE OFFICE RESIDENTIAL RESIDENTIAL Land Use B Land Use B Land Use C Land Use C Enter Demand Exit Demand Enter Demand Exit Demand LAND USE B: OFFICE LAND USE C: RESIDENTIAL OFFICE RESIDENTIAL ITE LU Code Land Use B Land Use C ITE LU Code Size Enter Demand Balanced Exit Demand Size Total Internal External < < < 0% - I - I 0% - < < < < < < Total Internal External Enter 25 8 17 4 10 Enter 160 52 108 Exit 122 14 108 > > > 2% 2 I 2 I 2% 3 > > > > > > Exit 77 41 36 Total 147 21 126 OFFICE Balanced RESIDENTIAL Total 237 93 144 % 100% 15% 85% Land Use B Land Use C % 100% 39% 61% Exit Demand Enter Demand NET EXTERNAL TRIPS Land Use>>>>>> A B C Total Enter 512 17 108 637 Exit 532 108 36 676 Total 1,044 126 144 1,313 Internal Capture Single Use Trip Generation 1,153 147 237 1,537 0.14558 CP Ca INTERCAP/PM PEAK - 12/2/2003/5:02 PM EXHIBIT "B" TO COMMENT LETTER RICHARD WATSON & ASSOC., INC. REPORT 3-104 a L is may' RICHARD WATSON & ASSOCIATES, INC. Urban &Regional Planning 2 December 2003 Shawn K. Millbern Senior Vice President The Robert Mayer Corporation 660 Newport Center Drive, Suite 1050 Newport Beach, CA 92660 Dear Mr. Millbern: - - Per your request, I have reviewed sections of the Draft Environmental Impact Report prepared by EIP Associates for the Pacific City Project in Huntington Beach. The sections that I have reviewed include the Executive Summary, Chapter 1 (Introduction), Chapter 2 (Project Description), Section 3.8 (Hydrology and Water Quality)of Chapter 3 RMC(B)-1 (Environmental Impact Analysis),Appendix A(Initial Study/Notice of Preparation and Scoping Comments), and Appendix G(Drainage Study). My qualifications for conducting such a review are noted in the attached Statement of Qualifications. The focus of my review has been the potential water quality impacts and the post- construction best management practices (BMPs) incorporated into the project to address these impacts. I have identified several potential deficiencies in the Draft EIR and one RMC(B)-2 potential impact that was not disclosed in the materials that I reviewed. All of the potential deficiencies discussed below are, at least in part, related to a water quality impact that was overlooked and thus not disclosed. Potential Adverse Impact of Changing Drainage Pattern Not Disclosed A major water quality impact that is not adequately addressed in the Draft EIR is the RMC(B)-3 impact of diverting surface runoff from 26.9 acres of the site from the Atlanta Stormwater Pump Station(ASWPS)to the First Street Storm Drain System(FSSDS). Section 3.8 of the Draft EIR indicates that the "predevelopment drainage area of 34.6 acres, currently tributary to the ASWPS, would be reduced to a 7.7-acre area." The analysis in the Draft EIR of the impacts to the beach and ocean water quality of diverting surface runoff from the Atlanta Stormwater Pumping Station to the First Street Storm Drain fails to address the potential impacts of reducing future dry weather urban RMC(B)-4 runoff diversions to the Orange County Sanitation District(OCSD). Rather,the discussion of this diversion in the Draft EIR based on the Drainage Study prepared by Hunsaker&Associates focuses on first flush discharges as well as the 25 and 100 year storm events. DEVELOPMENT SERVICES • STORM WATER QUALITY • STRATEGIC PLANNING 21922 Viso Lane • Mission Viejo, CA 92691-1318 USA • 949.855.6272 • Fax 949.855.0403 3-105 www.rwaplanning.com • rwatson@rwaplanning.com •1 t Mr. Shawn K. Millbern 2 December 2003 Page 2 of 6 The OCSD web site indicates that since initiation of the District's urban runoff program in 1999,there has been a decrease in bacterial water quality standard exceedances in Huntington State and City Beaches. The web site also includes the Atlanta Stormwater RMC(B)-5 Pumping Station as one of the urban runoff diversion systems that had a combined average daily discharge of.893 MGD to the treatment plant. The diversion of urban runoff from 26.9 acres of Pacific City to the First Street Drain will mean that the majority of increased dry weather urban runoff from the property will not go to the OCSD for treatment. The Preliminary Water Quality Management Plan for the project proposes that instead of treatment through the OCSD system,onsite drainage areas would have first-flush and dry weather flows treated by filtration or by filtration and screening. The specific treatment devices proposed for use are the StormFilter and RMC(B)-6 StormScreen treatment systems manufactured by Stormwater Management, Inc.These are well-recognized treatment systems for removing a number of important pollutants, including trash and debris, sediments,oil and grease, soluble heavy metals, organics and soluble nutrients. However, filtering and screening are not effective treatment methods for removing bacteria from stormwater or non-stormwater discharges. A StormFilter unit may reduce a limited amount of bacteria attached to nutrients in the discharges,but it will not disinfect the discharges. Stormwater Management and other companies are searching for methods to filter out human pathogens and other bacteria from discharges, but thus far I have been unable to do so. The only way to significantly reduce bacteria in the stormwater and dry weather discharges from the Pacific City project to the beach would be to follow the StormFilter unit with a treatment BMP specifically designed to remove pathogens. Today,pathogen removal generally involves either ultra-violet treatment or ozone treatment. These treatment alternatives were not addressed in the Draft EIR because the bacteria problem was largely ignored in the document. _. Probable Significant Impacts on Water Quality 1 The Draft EIR, in Section 3.8.3,points out that the proposed project would result in significant impacts on hydrology or water quality if it: I RMC(B)-7 • Violates any water quality standards or waste discharge requirements,or • Otherwise substantially degrades water quality. There is a high probability that the project will violate water quality standards for J1 pathogens unless additional treatment control BMPs are added to the project to remove bacteria and viruses from dry-season and first flush flows before they are discharged to RMC(B)-8 South Beach. 3-106 Mr. Shawn K. Millbern • 2 December 2003 Page 3 of 6 Deficiencies in Draft EIR Project Fails to Meet City's Project Objectives The Pacific City project, as described in the Draft Environmental Impact Report prepared by EIP Associates, fails to meet two of the City of Huntington Beach's project objectives. RMC(B)-9 It fails to: • Ensure adequate utility infrastructure and public services for the new development; and • Mitigate environmental impacts to the greatest extent possible. —� The Pacific City plan does not include appropriate stormwater quality infrastructure to mitigate to the greatest extent possible the adverse environmental impacts of diverting RMC(B)-10 urban runoff from 26.9 acres of Pacific City from the Atlanta Stormwater Pump Station to the First Street Storm Drain that discharges across South Beach to the ocean. — Currently, dry weather flows to the Atlanta Stormwater Pump Station are diverted to the i Orange County Sanitation District for treatment of bacterial contaminants before the RMC(B) 11 flows are discharged to South Beach. Similar treatment is currently being carried out in the City of Encinitas and is planned for the City of Malibu. J Alternative types of treatment infrastructures are available to mitigate the adverse impacts of diverting drainage from the Atlanta Stormwater Pump Station. These technologies should be discussed in the EIR and one of these should be used to treat the RMC(B)-12 dry weather flows and first flush stormwater flows before they are discharged onto South Beach. Errors in Summary Impact Table (Table ES-4) There are four errors in the Hydrology and Water Quality section of the Summary Impact table. These errors relate to Impact HYD-1 and Impact HYD-2, which are described in the Draft EIR as follows: RMC(B)-13 Impact HYD-1: The proposed project would not violate quality standards, waste discharge requirements,result in substantial sources of polluted ' runoff, or otherwise substantially degrade water quality. Impact HYD-2: The proposed project would alter the drainage patterns of the site,but not in a manner that would create substantial flooding, erosion, or siltation on or off site, or result in substantial additional polluted runoff. V 3-107 Mr. Shawn K. Millbern 2 December 2003 Page 4 of 6 Table ES-4 erroneously states that no mitigation measure is required for either Impact RMC(B)-13 and that the residual impact of each is "Less than significant." On page xxi the classification of"Less than significant"and"significant"for environmental impacts are defined as follows: Less than significant(LS)—Results in no substantial adverse change RMC(B)-14 to existing environmental conditions Significant(s)—Constitutes a substantial adverse change to existing environmental conditions that can be mitigated to less-than-significant levels by implementation of feasible mitigation measures or by the selection of an environmentally superior project alternative. It appears that the reason for the erroneous determinations is that the probable adverse impacts of shifting the runoff from 26.9 acres of the project to the First Street Storm Drain and South Beach were not considered.Neither the Drainage Study nor the Draft RMC(B)-15 EIR presents a plan for removing bacteria from the dry-season flows that would otherwise be sent to the Orange County Sanitation District for treatment. There is no support in the EIR for the determination that no mitigation is required for Impact HYD-1 or for Impact HYD-2. Furthermore, given the problem with high bacteria counts in the — surf zone along the beaches of Huntington Beach, it is necessary to treat the future dry weather urban runoff using either ultra-violet or ozone treatment before the residual RMC(B)-16 impact of either Impact HYD-1 or Impact HYD-2 could legitimately be determined to be f "less than significant,"unless the runoff is sent to OCSD for treatment. Inconsistencies with General Plan Elements Because the proposed project does not adequately mitigate the potential adverse water RMC(B)-17 quality impacts of shifting future urban runoff from the Atlanta Stormwater Pump Station to the First Street Storm Drain, it is inconsistent with at least two objectives and two policies of the General Plan Utilities Element presented in Table 3.8-2 of the Draft EIR and one policy of the General Plan Coastal Element presented in Table 3.8-4. _ Objective U1.2: The proposed project is inconsistent with this objective because it does not ensure that the new development does not degrade the City's surface waters. RMC(B)-18 Objective U3.3: It is inconsistent with this objective because it does not evaluate a significant potential degradation from a planned storm drain to a sensitive environment, RMC(B)-19 namely South Beach and the surf zone. Policy U3.1.3: It is inconsistent with this policy in that it does not fully mitigate impacts of improvements to the drainage system. RMC(B)20 3-108 Mr. Shawn K. Millbern 2 December 2003 Page 5 of 6 Policy U3.3.3: The proposed project is inconsistent with this policy because it fails to implement the most efficient technology (ultra-violet and ozone)to control potential RMC(B)-21 bacterial discharges through the First Street Storm Drain to South Beach. Policy C6.1.1 of the Coastal Element: The project is inconsistent with this policy in that it does not include mitigation measures to prevent the bacterial degradation of water RMC(B)-22 discharge to the surface of South Beach, especially dry weather discharges that will no longer be diverted to OCSD for treatment. Cumulative Impacts In the cumulative impacts discussion(Sub-section 3.8.5), the Draft EIR asserts that: RMC(B)-23 "As all development is required to comply with applicable federal, State, and local regulations, cumulative development should not violate water quality standards or waste discharge requirements, and thereby would not result in a significant cumulative impact." The Draft EIR concludes that"the contribution of the proposed project to cumulative impacts on hydrology and water quality is less than significant" in part because "the project would result in decreased flows to the Atlanta Stormwater Pumping Station, ! RMC(B)24 which would be a beneficial effect."In order to accurately conclude that the impacts on water quality are less than significant,the Drainage Study and the Draft EIR should be revised to address the bacteria water quality standards exceedances that could result from diverting future urban runoff from the Atlanta Stormwater Pumping Station to the First Street Storm Drain. J Conclusion A mixed use project of the magnitude and nature of Pacific City, that discharges stormwater and non-storm water flows primarily through a storm drain that outlets on the RMC(B)-25 beach, has the potential to.adversely impact water quality. As the Santa Ana Regional Water Quality Control Board commented in its letter of January 28, 2003, "There is widespread experience that urban development activity impacts water quality."The jproject's close proximity to the beach magnifies the importance of the discharges. I i Section 1.3 of the Draft EIR states that the document"has been prepared to identify any potentially significant impacts associated with the planning, construction, or operation of the project, as well as appropriate and feasible mitigation measures or project alternatives that would minimize or eliminate these impacts."Unfortunately,the potential adverse RMC(B)-26 impacts on water quality of shifting most of the post-construction drainage to the First Street Storm Drain, as well as two appropriate and feasible mitigation measures to minimize or eliminate the impact,have been overlooked. 3-109 Mr. Shawn K. Millbern 2 December 2003 Page 6 of 6 Discussion of this potential impact and the mitigation measures that could reduce or eliminate it must be added to the EIR for the document to adequately inform decision- makers and the general public of the significant environmental effects of the project and RMC(B)-27 to identify possible ways to minimize these impacts as outlined in Section 15121(a) of the CEQA guidelines. Sincerely, .RICHARD WATSON&ASSOCIATES, INC. aleGtelAl Richard A. Watson President RW/jm Attachment 3-110 9�:,, ::4i- '. 111011.111[/�/ RICHARD WATSON & ASSOCIATES, INC. Urban & Regional Planning Statement of Qualifications August 2003 • DEVELOPMENT SERVICES • STORM WATER QUALITY • STRATEGIC PLANNING 21922 Viso Lane • Mission Viejo, CA 92691-1318 USA • 949.855.6272 • Fax 949.855.0403 3-111 www.rwaplanning.com • rwatson@rwaplanning.com RWA Statement of Qualifications, August 2003 Page 2 of 17 Introduction to RWA Richard Watson & Associates, Inc. (RWA) is a planning and development services firm based in Mission Viejo, California. RWA works independently and in collaboration with other firms and consulting associates to provide'planning and problem-solving services for - private and public sector clients. RWA excels in assembling experts from complementary disciplines to form unparalleled project teams. RWA stresses a practical approach to each assignment. This approach is based on firm President Richard Watson's broad range of hands-on experience in assessing situations and developing innovative methods to prevent or solve problems. Mr. Watson's development experience ranges in scale from individual parcels to planned communities to cities and counties to a multi-state economic development region. His extensive stormwater work includes contributing to the development of public policy regarding water quality, speaking at numerous conferences and workshops dealing with implementation of the stormwater program, and supporting private and public sector clients with stormwater quality management issues. Richard Watson & Associates provides planning services in three (3) key areas: • Development Services • Stormwater Quality Services • Strategic Planning These areas encompass a variety of planning services and can be applied to a diverse array of projects. They are equally applicable to new development, redevelopment, or reuse. To enhance these services, RWA also offers clients on-site and on-line training as well as state of the art multimedia services. 3-112 ' RWA Statement of Qualifications, August 2003 Page 3 of 17 Development Services Richard Watson is a geographer/planner with over 25 years of experience in property assessment, advance planning, and project implementation. Mr. Watson is skilled at evaluating development potential and estimating short- and long-term development opportunities. He has assessed the feasibility of numerous development opportunities relative to local and regional infrastructure, economic and demographic projections, and market conditions. During his 15-year employment with the Mission Viejo Company in Mission Viejo, California, Richard Watson developed a program that served as the framework for the land acquisition, property management, and development phases of the Company's inventory replacement program. He worked on planning and research to ensure the successful implementation of the Aliso Viejo and Mission Viejo Planned Communities in Southern California, and provided strategic support in solving environmental and infrastructure- financing problems related to the Highlands Ranch New Town in Colorado. He supervised the Company's wetlands program, which included developing major wetlands mitigation. Mr. Watson also supervised park planning, served as liaison with coastal planning agencies, and assisted with the planning and design of school sites for the Aliso Viejo Planned Community. Through RWA, Mr. Watson prepares varied development plans for both private and public-sector clients, outlining the steps necessary to take a property from its present status to full planning and zoning entitlement. He is experienced in developing processes for meeting regulatory requirements, securing timely approval of plans and facilitating their successful implementation. He helps clients position themselves to act on investment opportunities by assessing economic factors, infrastructure, and other critical forces that shape market conditions. Mr. Watson's expertise in the field has brought him to the attention of the international planning community. He served as the Team Leader of a development planning and engineering team for the MiraNila New Town project in Cebu, the Philippines. He provided planning support to Kaichuan Engineering and Development Company for an ecological hillside development project in Taipei, Taiwan and was an invited keynote speaker at a sustainable development conference in Taipei. In addition, Mr. Watson has been an invited speaker/panelist at International Urban Development Association(formerly International New Town Association) conferences in Europe. He has also served as a consultant on regulatory issues to the Building Industry Association of Southern California. Richard Watson's professional affiliations include the American Institute of Certified Planners, the American Planning Association,the American Public Works Association,the 3-113 RWA Statement of Qualifications, August 2003 Page 4 of 17 Building Industry Association of Southern California, the California Building Association, the California Planning Roundtable, the California Water Environment Association, the International Erosion Control Association, the Pacific Rim Council on Urban Development,the Urban Land Institute, and the Water Environment Federation RWA Development Services include: • Analyzing properties for development potential and feasibility; • Assessing properties for regulatory constraints and opportunities, as well as potentially competing goals; • Planning support for economic development, emphasizing balanced spatial organization and the creation of marketable land use; • Initiating planning programs to secure planning and zoning entitlements for future development; • Developing processes for securing timely approval of plans and facilitating their successful implementation; • Providing expert witness testimony; • Providing guidance in meeting regulatory requirements and complying with processing procedures; and • Providing a variety of environmental analyses, with special attention given to topography, geology, soils, hydrology, biological resources, and stormwater quality. RWA provides advice and assistance in carrying concepts to reality. We draw on a background of extensive practical experience to craft innovative planning solutions. 3-114 RWA Statement of Qualifications. August 2003 Page 5 of 17 Stormwater Quality Services /NPDES Richard Watson & Associates, Inc. (RWA)`is uniquely qualified to help clients comply with the National Pollutant Discharge Elimination System (NPDES) and other stormwater quality regulations. Richard Watson has 12 years of experience in stormwater quality management, making him a valuable asset in navigating this complex regulatory environment. An active participant in the California Stormwater Quality Association (formerly Stormwater Quality Task Force) since 1991, Mr. Watson is extremely knowledgeable about policies and concerns regarding stormwater. He has working relationships with State and Regional Board staff members,.municipal NPDES program staff members, and water quality engineers and researchers throughout California. He is currently a member of the Executive Program Committee of the Association and Chair of its Watershed Management /TMDL/Impaired Waters Work Group. Since 1997, RWA has served on a multi-disciplinary team assisting the California Department of Transportation (Caltrans) with stormwater quality issues. Richard Watson worked on the BMP Retrofit Pilot Program, for which he assisted with the siting of pilot retrofit best management practices (BMPs) at 33 locations in Caltrans District 7 (Los Angeles County) and District 11 (San Diego County). This pilot project was initiated to determine the cost-effectiveness and water quality benefits of structural BMPs when retrofitted into existing facilities. Mr. Watson chaired the advisory team that developed a Long-Term Stormwater Compliance Strategy Program for Caltrans. This team, comprised of Caltrans personnel, consultants, and university researchers, directed several studies designed to increase understanding of the nature of stormwater quality problems, address potential solutions, and determine related costs. He also managed the Caltrans San Diego Water Quality Control Study (SDWQCS), a two-year study to determine the extent to which Caltrans should expand current practices to prevent stormwater pollution, control source, and/or treat discharges from its storm drain systems. The study addressed this obJective through a watershed-based approach. The program consisted of five components: Outfall Inventory, Outreach and Partnering, Water Quality Assessment, Technology Assessment, and Scenario Development and Assessment. The SDWQCS was the first of many watershed programs to be developed in Caltrans Districts to establish priorities for stormwater controls. Richard Watson has been one of the principal private sector contributors in the development of a workable General Permit for Stormwater Discharges Associated with Construction Activity in California. In addition, he served on the Technical Advisory Panel 3-115 RWA Statement of Qualifications, August 2003 Page 6 of 17 for the development of the original Construction, Municipal, and Commercial / Industrial BMP handbooks for California. He also served on the Urban Development Technical Advisory Committee for review of the State's Nonpoint Source Pollution Management Program, which involved working with staff members of the State Water Resources Control Board, the California Coastal Commission, various Regional Water Quality Control Boards, and others to review the adequacy of nonpoint source pollution in California. While employed by Mission Viejo Company, Mr. Watson handled numerous technical and policy issues in the development_ of both the Mission Viejo and Aliso Viejo planned communities in Orange County, including compliance with NPDES requirements. He developed the overall Mission Viejo Company NPDES program and supervised the development of comprehensive stormwater pollution prevention plans (SWPPPs) for Aliso Viejo and Mission Viejo. RWA helped prepare a Post-Construction Stormwater Quality Program and Evaluation Monitoring Program for the Eastern Transportation Corridor in Orange County, California. (With RBF Consulting and G. Fred Lee & Associates for Silverado Constructors.) Project work included development of structural and non-structural post-construction BMPs for a 26-mile toll road and design of a monitoring program to evaluate impacts to beneficial uses of receiving waters for the stormwater runoff from the Corridor. Mr. Watson assisted the County of Orange (California) with development of a Drainage Area Management Plan. In particular, he helped develop appendices dealing with construction and new development. RWA, in association with David Taussig & Associates (DTA), prepared a Long-Term Financing Study for the Orange County Stormwater Program, Orange County, California. The study included a review of financing mechanisms used by municipal permittees, an evaluation of alternative financing mechanisms, the development of case studies, and the presentation of recommendations for implementing a preferred financing plan. RWA and DTA recently updated this study. RWA also recently served on the RBF Consulting/Larry Walker & Associates project team to provide Stormwater Quality Management and NPDES Compliance Support for the County of Orange (California). For this project, Richard Watson developed a template for an extensive stormwater quality training program and coordinated the efforts of other consultant contributors. 3-116 RWA Statement of Qualifications. August 2003 Page 7 of 17 In 1997, the National Water Research Institute (NWRI) invited Mr. Watson to participate in a Nominal Group Technique workshop to address potential stormwater harvesting; specifically,to identify significant barriers to harvesting stormwater as a viable component of the water supply. The resulting report serves as an action guide for NWRI and its co- sponsoring agencies. Richard Watson actively participated in the work of the San Diego Bay Watershed Task Force, a stakeholder collaborative effort addressing stormwater pollution and other nonpoint source pollution that affects San Diego Bay. He was a member of the sub- committee addressing water quality issues in the Pueblo San Diego sub-watershed. Richard Watson serves on the Southern California Water Resources Committee of the American Public Works Association and is a member of the California Building Industry Association Water Resources Task Force. He has contributed to the development of public policy related to planning, development, environmental management, and water quality, and is a frequent speaker at conferences and workshops dealing with implementation of the stormwater program. Current projects include: • Coalition for Practical Regulation Technical Stormwater Quality Consultant for a group of more than 40 small and medium-sized cities in Los Angeles County • County of San Diego, Department of General Services Stormwater Quality Management/NPDES Compliance Support • Hines Nurseries Stormwater Quality Management/NPDES Compliance Support • Talega, LLC Stormwater Quality Management/NPDES Compliance Support Refinement and implementation of SWPPP for Talega Planned Community RWA's stormwater client list (past and present) also includes: Valley Crest; New Urban West, Inc.; AGK Group; Melville Realty Co., Inc.; New Center Company; Toys "R" Us; Musil, Perkowitz, Ruth, Inc.; and El Paseo Partners, Ltd. 3-117 • RWA Statement of Qualifications. August 2003 Page 8 of 17 Detailed Resume of Training Experience Richard Watson has developed and taught university courses in Urban and Regional Planning, Physical Geography, and Transportation Planning. His training experience includes developing and conducting programs dealing with permit compliance for numerous public and private sector clients, including: City of San Juan Capistrano, California Staff Training Training included general awareness training for City staff and specific construction and corporation yard inspection training. The construction inspection training included both classroom and field training. California Department of Transportation (Caltrans) Staff Training This training session, prepared and conducted with Scott Taylor of RBF Consulting, dealt with General Permit compliance for the California Department of Transportation (Caltrans). County of Orange (California) NPDES Permit Compliance Assistance—Training Component RWA served as a member of the RBF Consulting/Larry Walker and Associates team providing NPDES permit compliance assistance to the County of Orange. Work on this project included developing training modules and conducting training sessions related to Plan Development, Existing Development, and Illegal Discharges/Illicit Connections. In addition, Richard Watson has worked with the County and the County's Public Education consultant to develop a template for consistent appearance and elements to be used in the various training modules being developed to meet new permit requirements. County of San Diego,Department of General Services Staff and Contactor Training— Four Specialized Training Modules This training focused on permit compliance for the Facilities Services, Fleet Management, and Facility Support Contracts Management Divisions of the Department of General Services, and tenant departments at County facilities. The concept of this program was to 3-118 , RWA Statement of Qualifications, August 2003 Page 9 of 17 integrate permit compliance as much aspossible into existingprograms in order to reduce �' p p g the need for extra staff and to reduce long-term costs while increasing compliance. DPR Construction,Inc. Staff Training This field staff training program was prepared and presented in collaboration with Scott - Taylor of RBF Consulting. The three training sessions held -- two for DPR's San Diego Office and one for its Newport Beach, California office — focused on compliance with California's General Construction Permit. Talega Associates,LLC Staff Training In addition to revising and updating the Stormwater Pollution Prevention Plan (SWPPP) and conducting field reviews with US EPA Region IX, San Diego Regional Water Quality Control Board and Talega staff members, Richard Watson & Associates, Inc. prepared and presented a series of training seminars for Talega staff, contractors, and merchant builders. This training has focused on the needs of each group and has included participation by a city inspector. Annual refresher courses are presented each fall. Valley Crest Staff Training RWA prepared and presented this training session for field staff in the San Fernando, California office of Valley Crest Landscape Development. The program focused on training field staff to effectively handle stormwater quality issues for a downtown street renovation project Valley Crest was working on for the City of Santa Monica, California. 3-119 RWA Statement of Qualifications. August 2003 Page 10 of 17 Strategic Planning Richard Watson & Associates, Inc. (RWA) combines analysis, experience, and insight in a practical and effective approach to strategic planning developed through 15 years of experience with the Mission Viejo Company. By monitoring local conditions, market fluctuations, economic trends and regulatory practices, we develop strategic plans to create competitive advantage and position. The central goal of a strategic planning program is to create and maintain value. The way to accomplish this is to creatively assess the future and act accordingly. A Practical Approach to Strategic Planning Strategic planning is an integrated decision-making process in which goals and the requirements for meeting them are clearly defined, helping to ensure coordination among decisions and to effectively direct efforts. RWA uses a semi-formal strategic planning approach, which is designed to promote strategic thinking without the expense or complication of establishing formal statistical analysis and modeling systems. RWA emphasizes limited strategic analysis and the formation of strategies around which a development program could be structured. RWA's method is a comprehensive reasoning process that focuses on problem solving and future implications of current decisions. It promotes anticipation and timely response to the environment of constant change in which developers and municipalities operate. A Strategic Plan developed by RWA involves a number of component plans that work together to help ensure successful completion of the project. We prepare a "Plan for a Plan" to outline the steps necessary to take a property from its present status to full planning and zoning entitlement. An Opportunity Plan positions the property owner to be ready to respond to changing market and regulatory conditions and:to take advantage of future development and sales opportunities. Among the other plans that may developed are: ■ Acquisition Strategy • Political Strategy • Government Relations Strategy • Public Relations Strategy ■ Community Relations Strategy • Defensive Strategy ■ Exit Strategy 3-120 RWA Statement of Qualifications, August 2003 Page I l of 17 RWA Multimedia Services RWA provides a range of powerful multimedia tools to.support and enhance our core planning services. We offer a unique combination of planning expertise and state-of-the art digital and multimedia technology to aid in training, documentation, litigation, and project proposals. Our ability to create and implement multimedia tools in-house assures the accuracy and confidentiality of the product, and gives clients the added convenience of an integrated planning and multimedia team. On-site and Online Training Insight and flexibility are key elements of RWA's training philosophy. Through our on- site training programs,we provide clients with comprehensive information tailored to their specific projects. Training by RWA integrates hands-on planning experience with compelling multimedia presentations that can include a range of photographic, video, and animation elements. Clients who incorporate training into their projects can utilize RWA's catalog of multimedia exhibits to help team members understand and navigate today's complex regulatory environment and realize maximum value. To complete the training package, RWA offers online training as part of a scalable eLearning system. This system is capable of providing 24 hour-a-day access to training and testing for target audiences. With the ability to utilize PowerPoint slides, graphics, video, audio, and animation, this approach presents a highly flexible and effective instructional tool. In addition, this system can play a key role in verification of training/educational efforts to fulfill reporting requirements. Proof of user participation, as well as test results, can be delivered to supervisors in standard database formats. This application can be enabled via RWA's website, or the client's LAN/WAN or internet site, as required. Project Documentation Capitalizing on our expertise in project analysis and multimedia production, RWA is able to offer clients a tangible record of their project from inception to completion. This service can include written, photographic, video, 3-D animation, and time-lapse documentation. Clients can then utilize these records not only as proof of performance, but as a powerful marketing tool for future projects. Contract Proposals and Interviews RWA is experienced in creating successful proposals and interview presentations. In addition to serving as a team member on presentations, RWA can provide clients with presentation techniques and supporting media elements based on our thorough 3-121 RWA Statement of Qualifications. August 2003 Page 12 of 17 understanding of the selection process for major contracts. Through these services, RWA can relieve many of the technical strains involved in the proposal/interview preparation process, allowing clients to focus on message. - Litigation Support In addition to expert witness testimony, RWA can also provide clients with critical litigation support. These services can incorporate subject research and litigation-related multimedia services including videotaping, digital video editing, and 3-D animation. Clients can utilize these elements to dramatically enhance their ability to communicate complex concepts and arguments to key individuals in the litigation process. 3-122 ,• RWA Statement of Qualifications, August 2003 Page 13 of 17 Richard A. Watson,President Richard Watson & Associates,Inc. PROFESSIONAL EXPERIENCE: - 1993 —present Richard Watson&Associates, Inc. President 1993-1993 Culbertson, Adams &Associates, Inc. Vice President 1982-1993 Mission Viejo Company Associate Director and Director, Planning Research 1978-1982 Jack G. Raub Company (Became a division of Mission Viejo Company) Director of Advance Planning 1974-1978 Ozarks Regional Commission Regional Planner 1971-1974 Oklahoma State University Instructor,Department of Geography; Coordinator of Geography Extension 1970-1971 University of Alberta Sessional Lecturer,Department of Geography PROFESSIONAL AFFILIATIONS: American Institute of Certified Planners American Planning Association American Public Works Association Building Industry Association of Southern California California Building Association California Planning Roundtable 3-123 1. RVVA Statement of Qualifications, August 2003 Page 14 of 17 Richard A. Watson,President Richard Watson & Associates,Inc. - PROFESSIONAL AFFILIATIONS (continued): California Stormwater Quality Association(formerly California Stormwater Quality Task Force) California Water Environment Association International Erosion Control Association National Association of Home Builders Pacific Rim Council on Urban Development Urban Land_Institute Water Environment Federation EDUCATION: Stanford University History Major, 1960-1962 University of California, Los Angeles B.A. Geography, 1964 M.A. Geography, 1969 University of Alberta, Canada All requirements for Ph.D. except dissertation Geography,with planning emphasis, 1967-1971 EXPERTISE: Stormwater management and compliance Development feasibility and due diligence Planned communities; large scale development Environmental analysis and planning Economic development Open space,park, and recreation planning Resource management and mitigation Strategic planning Government and community relations Project implementation References Available Upon Request 3-124 RWA Statement of Qualifications. August 2003 Page 15 of 17 PROJECT ASSIGNMENTS Richard Watson & Associates, Inc. (RWA): Major Project Assignments • Stormwater quality management support for County of San Diego, Department of General Services • Task leader / consultant team member supporting the County of Orange with Stormwater Quality Management / NPDES Compliance (member of RBF Consultingl/Larry Walker&Associates project team) • Stormwater quality consultant to Coalition for Practical Regulation (a group of more than 40 small and medium-sized cities in Los Angeles County) ■ Stormwater quality consultant for California Department of Transportation (with RBF Consulting) ■ Stormwater quality consultant to City of Mission Viejo • Leader of master planning team for MiraNila New Town project, Cebu, The Philippines • Eastern Transportation Corridor Runoff Management Plan Evaluation Monitoring Program (with RBF Consulting and G. Fred Lee &Associates) ■ Consultant to Kaichuan Engineering and Development Company, Taiwan, on planning for ecological hillside community ■ Land development workshop for the Department of Land Development, Taiwan Provincial Government,ROC • Consultant and expert witness testimony for several property owners in major California eminent domain property condemnation cases • Consultant on regulatory issues to Building Industry Association of Southern California • Consultant to CDS Technologies, Inc. on introduction of continuous deflective separation stormwater treatment to Southern California 1 ' • Preparation of Stormwater Pollution Prevention Plans for construction and new development Culbertson, Adams & Associates: Major Project Assignment I Formerly Robert Bein,William Frost&Associates 3-125 RWA Statement of Qualifications. August 2003 Page 16 of 17 ■ Consultant to Mission Viejo Company on implementation of Aliso Viejo and Mission Viejo Planned Communities Mission Viejo Company: Major Project Assignments • Directed planning and research to ensure the successful implementation of the Aliso Viejo and Mission Viejo Planned Communities • Supervised Company Stormwater Quality Program ■ Developed an Inventory Replacement Program to serve as a framework for property acquisition,property management, and planning for future development • Provided governmental coordination with City and County officials in Kern, Orange, Riverside, San Bernardino, and San Diego Counties • Developed property management programs for Mission Viejo Company properties • Supervised park planning for the Aliso Viejo Planned Community • Assisted with planning and design of school sites • Worked with numerous engineering, design and construction disciplines as well as coordination with many public and private organizations • Supervised Mission Viejo Company's wetlands program, securing appropriate permits and agreements as well as the development of major wetlands mitigation • Made presentations to international media and development groups as well as to domestic financial groups • Served as Conference Director when Mission Viejo Company hosted the International Urban Development Association (formerly the International New Town Association)Annual Conference in Mission Viejo and San Francisco • Provided private sector perspective and contributed to revising the Land Use Element, the Noise Element, the Recreation Element, the Open Space Element, and the Safety Element to the Orange County General Plan Jack G. Raub Company: Major Project Assignments • Directed five sections of Advance Planning, including Economic Planning, Environmental Analysis, Housing and Community Development, Policy Planning, and Resource Planning ' - ■ Supervised preparation of the Aliso Viejo Greenbelt Management Program 3-126 RWA Statement of Qualifications, August 2003 Page 17 of 17 ■ Supervised preparation of the Local Coastal Program for the Aliso Viejo Planned Community ■ Participated in preparation of the Aliso Viejo Planned Community Development Plan • Conducted numerous negotiations with the County of Orange, the California Coastal Conservancy, and the California Coastal Commission • Made frequent presentations to public agencies and citizen groups Ozarks Regional Commission: Major Project Assignments • Developed a new Economic Development Action Plan for the five-state region • Supervised the Commission's annual State Investment Planning process • Reviewed individual infrastructure investment projects • Developed the Commission's energy program • Assisted in the development of a regional air service program • Worked closely with five governors' offices and numerous federal, state and local agencies • Coordinated public and private sector advisory groups 3-127 EXHIBIT "C" TO COMMENT LETTER PHOTOGRAPHS OF FIRST STREET STORM DRAIN OUTFALL 3-128 i , .4 _ r'N !tt' yr•S Y2^, � : a'S •d.7: •' � AI.°.'i'.r. 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FFFNl EA AREA .:14/2 € 1 er, FR rHEOG N • ,; / "' EA _ , .fit f'`r ..r J r4 t ra*1.11 „.fif ' 4, r!{� c.), `'�JT.4./ !:: yea!e ^b r..�p�Jr.:�raS°S�t'�"��8 v . ec: "� A ...: .% ,M1. p E YZRr�"��.1Y'liti / ri 1, w. , NTEOEAGUA/AG Utin VI U 6 5 � r ADEL DRENAJEDE � � k Ti TAPUEDECAUSARENRRMEDA F ,. � DES rfta �,, r• ;' EVITECONTACTO CON AGUADEDESAG OUE ESTEESTANCADAOCORRIENDOYElAREA ,, ` ' o DONDEDESEMBOCAAL OCEANO t 'J'* o ' ORANGECOUNTYENVIRONMENTAL HEALTHOIVIS/0N •9 04 ';^ t".10i FOR FURTHER/NFIr •nos,,CALL 14 6574751 :601, ,• - A »ot WWW.00.CA.GOV/H LATORY/OCEANISEACH.HTH~ P „'0 ♦.. ..is-.-".: ,..�.s{S.�A .: t ''k�fSry/jk > e' �ri �v 1 xi •4 :c.i.,04f. l'''..,,.1 4944;`,": War ;.' �,ng sign at v vtfal1, 3131 INDIVIDUALS WRITTEN LETTERS December 2,2003 Mary Beth Broeren,Principal Planner City of Huntington Beach Department of Planning �. ' 2000 Main Street Cf =' Huntington Beach,CA 92648 RE: Pacific City DEIR No.02-01 Dear Ms.Broeren, I am writing this comment letter because 1)I am concerned that the Pacific City DEIR does not accurately represent the wetland indicator vegetation that can be found on the site and 2) the Bixby-1 applicant has been acting in an egregiously bad-faith manner regarding vegetation removal from the site. Chronology 1 Bixby-2 The chronology of my involvement with the Pacific City project is as follows: September 2,2003—My 1st site visit;no pictures taken. Half a dozen wetland indicator species found growing up against the property fence along the southern portion of Huntington St. Bixby-3 Ponding observed in several locations with lush vegetation. _ September 7,2003—My 2"d site visit; 35 pictures taken. Wetland indicator species photographed:Parapholis incurva(Sicklegrass,OBL),Heliotropium curassavicum(Seaside Bixby-4 heliotrope,OBL),Polypogon monspeliensis(Rabbitsfoot grass,FACW+),Malvella leprosa (Alkali mallow,FAC),Bassia hyssopifolia(Five-horn bassia,FAC). _ September 9,2003—1d Planning Commission study session for Pacific City. I spoke during Bixby 5 Public Comments and mentioned that wetland indicator vegetation had been found on the site. September 11,2003--Area residents report grading&vegetation removal activity on the site. The large ponding area at PCH&Huntington has been filled in. The smaller ponding area opposite the Pacific Mobile Home Park entrance has been partially filled in. Area residents Bixby-6 complained to the city about dust blowing off of the site and the city issued a cease&desist order to stop the activity. September 14,2003—My 3`d site visit;28 pictures taken. Wetland indicator species photographed:Parapholis incurva(Sicidegrass,OBL),Heliotropium curassavicum(Seaside Bixby 7 heliotrope,OBL),Malvella leprosa(Alkali mallow,FAC),Cynodon dactylon(Bermuda grass, FAC). J September 17,2003—Area residents report more grading&vegetation removal; 29 pictures !` taken. Small ponding opposite the mobile home park has now been completely filled in. A Bixby-8 3-133 water truck was used in an attempt to reduce dust emissions,but area residents still noted blowing dust. Bixby-8 September 18,2003—My 4th site visit; 5 pictures taken. Large piles of dead vegetation noted in several locations. I filed a written complaint.with the California Coastal Commission Bixby-9 Enforcement Division resulting in an investigation being opened. September 21,2003—My 5th site visit; 35 pictures taken to document changes since my Bixby-10 September 14, 2003 site visit. September 23,2003—2°"Planning Commission study session for Pacific City. I spoke during the study session and gave a brief summary of the recent grading&vegetation removal, During Bixby-11 the 7PM portion of the meeting,I also gave a PowerPoint presentation which showed several sets of"before"and"after"pictures documenting changes on the site. October 6,2003—Igave a PowerPointpresentation(attached)during7PM CityCouncil Public Bixby-12 Comments to bring the council up to date regarding recent events at the Pacific City site. October 9,2003—Area residents report more vegetation removal. IBixby-13 November 16,2003—My 6th site visit;20 pictures taken,vegetation mapped. Wetland indicator~ species photographed:Heliotropium curassavicum(Seaside heliotrope, OBL),Polypogon !Bixby-14 monspeliensis(Rabbitsfoot grass,FACW+),Malvella leprosa(Alkali mallow,FAC), Spergularia marina(Salt-marsh sand spumy,OBL),Distichlis spicata(Saltgrass,FACW). November 24,2003—Area residents report vegetation removal along Huntington St. Bixby-15 November 28,2003—My 7th site visit;vegetation map refined. Additional areas of rabbitsfoot grass noted from last season. Alkali mallow has increased in number since my November 16, Bixby-16 2003 visit,both in terms of scattered individuals and the size of two large aggregations. _ DEIR Errors, Omissions, and Inconsistencies Bixby-17 DEIR Volume I,Section 3.3 (Biological Resources)contains various errors,omissions,and inconsistencies: — 1. Minor typos and/or taxonomic inconsistencies—some species names in Table 3.3-1 (Plants Observed on the Project Site)differ from the USDA NRCS PLANTS database at http://plants.usda.gov/: Bixby-18 o The DEIR lists the species name for"Crystalline iceplant"as"Mesembryantheum crystallinum",but PLANTS lists it as Mesembryanthemwn crystallinum. V 3-134 o The DEIR lists the species name for"Airowgrass"as"Triglochin concinna",but PLANTS lists it as Triglochin concinnum. Bixby-18 o The DEIR lists the species name for"Sicklegrass".as"Parapholis incurve",but PLANTS lists it as Parapholis incurva. 2. Species misidentification—Table 3.3-1 incorrectly lists the species for"Saltgrass"as "Spartina". The correct species name for the saltgrass that I have observed on the project Bixby-19 site is Distichlis spicata. "Spartina"is actually the species name for cordgrass. Cordgrass requires full tidal flow which is obviously not present on the project site. 3. Species omissions—Table 3.3-1 fails to list the following two wetland indicator • vegetation species that are readily visible from the Huntington St.side of the project site fence: _ I o Heliotropium curassavicum(Seaside heliotrope,OBL)—multiple plants of this species were observed alongside Huntington St.during every site visit. o Malvella leprosa(Alkali mallow,FAC)—this species differs from cheeseweed mallow in that the leaves are a lighter shade of green,with asymmetrical edges ; Bixby-20 and crinkling,and the bloom is a lovely pale yellow flower about an inch in diameter. Many scattered alkali mallow plants can be found alongside Huntington St.from opposite of the mobile home park entrance down to Pacific Coast Highway. There are two large aggregations on the property—one of perhaps 25-30 square feet opposite of the mobile home park entrance,and another one of perhaps 50-100 square feet opposite of the Hilton hotel. The numbers of alkali mallow plants all along Huntington St.had definitely increased between my November 16 and November 28s'site visits. j 4. Several passages in Section 3.3 assert or imply that all wetland indicator vegetation species were found down inside the soil remediation pits. This is simply not true. While the pits did support some lush wetland vegetation prior to the September 11"grading& vegetation removal,all of the species that I am able to observe from Huntington St. in Bixby-21 November 2003 are located at or above the same grade as the adjacent street(see the annotated aerial map attached below for a list of these species). I_ 5. Table 3.3-1 neglects to include and explain the wetland indicator status codes associated with each wetland vegetation species. Because I believe this information will be useful to the Huntington Beach Planning Commission and City Council,I have attached a revised copy of Table 3.3-1 below along with the USDA explanation of the status codes. Bixby-22 For example,Heliotropium curassavicum,Spergularia marina, Triglochin concinnum, and Parapholis incurva have all been found on the project site and are rated OBL (Obligate)which mean that these species are found in wetlands 99%of the time. • 3-135 • 1 6. Page 3.3-9 under"Special Status Plants"says: "Special status plant species known to occur in the proposed project region are summarized in identified in Table 1 of Appendix I. No special status plant species have been identified or are expected to occur on the Bixby-23 project site." Table 1 of Appendix I lists Suaeda taxifolia(Woolly sea blite)as a special status plant species,and Table 3.3-1 declares this species as being present during the September 24, 2003 El?site survey. This directly contradicts the"no special status plants"assertion of page 33-9. 7. Mitigation Measure BIO-1 on page 3.3-24 says: 7 "If before the start of construction,substantial growth of native vegetation or sensitive habitats has occurred on the project site as determined by a qualified biologist,then special status plant or habitat surveys shall be conducted during the appropriate time of the year prior to construction of the proposed project,to determine the presence or absence of special status plant species or habitats.These surveys shall be conducted during the appropriate blooming period as determined by a qualified biologist." The DEIR calls for future plant surveys to be performed during the"appropriate Bixby-24 blooming period",and yet the only plant surveys done to date have been in December 2001 (the dead of winter)and September 2003 (near the end of the dry season). Given that maximal Huntington Beach Coastal Zone vegetation diversity occurs in the period February through May,the current plant surveys in the DEIR should be considered inadequate assessments of the vegetation species that will be impacted if this project is developed. Mitigation Measure BIO-1 is ultimately rendered moot by the excessive disking and other forms of vegetation removal that have been occurring with great frequency on the project site—even during the dry season when plant growth activity is largely quiescent. If the applicant is truly serious about mitigating for any special status or wetland vegetation on the project site,then the frequent vegetation removal needs to stop so that the vegetation can be accurately surveyed prior to project approval Water Quality Comments Page 3 of the Preliminary Water Quality Management Plan(PWQMP)in DEIR Volume II Appendix G boasts: Bbthy-25 "The StormFilter is unique in its ability to meet current and future pollution • challenges. No other system offers this degree of excellence and versatility." V 3-136 This sounds like it was cut/pasted directly from the vendor's marketing brochure,and therefore it IN needs to be viewed with skepticism. No system can accurately boast about meeting future challenges if the applicable regulatory measurements(TMDLs,etc)have yet to be established. Bixby-25 Regardless of whether or not StormFilter(and StormScreen)live up to the vendor's hype, reliance on these systems as the sole structural BMPs shows a lack of progressive thinking. Why Bixby-26 weren't natural treatment systems considered as a part of the treatment train for this project? f As an example,consider the mini-wetlands treatment system installed at the Wild Oats shopping center located at 6550 E.Pacific Coast Highway in Long Beach: cyA ', ,. -tY„v' .. - •ti-=T--.4.4 c.-''.«,:.y .v t.:.s Jr. t" i= -z'43: -t33x, - ^a a+.•+„�c:.`'-u�f::A, �s -f�'�,«: -4 y`rt� �ai .. -�ti:J W' �,-: n' ti";' :'i - �,�,. 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'-,---'`-t`E.7..'t.T.T ."-*'-,.e.,:r- i ---.k.,'1444 LR!_ y1`- .› y a.,., sce,t R •- 4 5-4 'e!±` 'i l:•:_.ri m u,;. 1 1 y - - T.T , F T J«`3 «q 1!IJ. --11- i,, _ii �' I Y k 1.fit. tt•,'7" 3,'C +E5 , kk_,i bc4 n,,ewe 4..,, § ��r�Lw_e, 4"` y``6:j i" z C a 4 At' " , ''Q3" �` - a. *0' J-AE,`:` '€� �` �' t IIbATER ti WORLD p} + �i p `P4w�. ,,, � . s14,„{:t sly ,:. Td !� r T t-'` 5`.,,i`,"-141,�. z c..�. u' {"e,,k ?=t r,1„.....,, , 1,�.1 i Bixby-27 • C "i L 5 Yr= I. -i4[t� ra-t M«1'`-Y_-.... -,-`x.'#7"8 : `''-'z' • "t"t ,1- ji . 42- �kh •Ch • -, 1, �'' I i tmn�IJJanuJn I M� )t I I R . •Q_.,§ ;sk �w 1t -,..44- �"9' & �a ' ,ii t, R -.i '.=,-t. -s a ,,� - {�•I ii7 ._ _ .t-...t 1-•., t 1 ! - .i, o ea.91i Sl ii sn �Igi r I: • C•1 3 �.t0. GSl f" '`'' $ �)� ^ .I•v!. I'.,�.-. �r c _52 l 1„ • Q II -a-`d I ' � t ',M>a�'- • t'.I! �' r J. A eft[.. •- . 3 - t I' I I I I 1 ipl�'Itm , rr l ' f,afa..'it a�:,,; IJQa J ' -tY I "I j,�•Ics6o �t 'd r J eeT ,,k,. 1 S I ^'a `1 • ) J This small constructed wetland filters the runoff from the parking lot(left of frame)before it enters the storm drain system. Besides improving water quality,such natural treatment systems f also provide habitat value and improved aesthetics. i 3-137 .. Conclusions Wetland Vegetation The site visit by BonTerra Consulting in December 2001 only found 6 species of wetland indicator vegetation. My access to the project site is limited to what I can see by naked eye,camera,and binoculars while standing on the public side of the perimeter fence. Despite this,my September 2003 site visits turned up an additional 6 species of wetland indicator vegetation that were somehow missed by BonTerra who presumably had full access to the project site. Bixby-28 At the September 9,2003 Planning Commission study session,I mentioned that I had seen wetland vegetation on the project site.This apparently prompted EIP to do a supplemental vegetation survey on September 24,2003 which turned up an additional 3 species of wetland indicator vegetation that had not been seen by either BonTerra or me. What started out as only 6 species of wetland indicator vegetation has suddenly now become 15 species,which is pretty amazing considering 1)that all vegetation surveys to date have occurred in either the dead of winter or the end of the dry season,and 2)the recurrent and overzealous disking and vegetation removal. It really makes a person wonder what would be seen on the project site during the peak +. February May growing season. The DEIR's lack of data in this area demonstrates a clear lack of Bixby-29 due diligence(at best). While I give Ell'credit for doing another vegetation survey on September 24,2003,I believe —1 that continued monitoring of vegetation is warranted between now and the eventual Planning 1Bixby-30 Commission and City Council public hearings on this project. Bad-Faith Actions by the Applicant `1 The intent of the CEQA process is to fully disclose the environmental impacts caused by a project. Current project site biological resources must be accurately surveyed before biological Bixby-31 impacts can be determined. The applicant has deliberately avoided conducting any vegetation surveys during the February-May time period when the greatest number of vegetation species would normally be present. Therefore the DE1R would seem to be inadequate regarding the impacts upon vegetation resources. TheDEIR acknowledges that the California Coastal Commission uses a one parameter method for determining the presence of wetlands. Yet the applicant routinely removes all wetland vegetation(the one parameter most likely to apply at this project site)without any legitimate Bixby-32 reasons to do so. This may be a gross violation of the California Coastal Act which prohibits the destruction of wetlands in the Coastal Zone. 3-138 Further adding insult to injury,the applicant's frequent vegetation removal operations cause clouds of dust to blow off of the project site. The applicant is well aware of the concerns of neighboring residents regarding toxic soil contamination. But by allowing potentially toxic dust Bixby-33 to blow into neighboring homes,the applicant demonstrates a callous disregard for the health of Huntington Beach residents. It is well within the applicant's power to make all of these issues disappear by simply allowing the vegetation to grow on the project site. If the vegetation were allowed to grow: • An accurate vegetation survey could be performed that would comply with the spirit and the letter of CEQA; Bixby-34 • The Coastal Commission would be able to make an accurate determination about whether or not a one-parameter wetland exists at this site; • Dense vegetation would help to prevent dust from blowing off of the project site_ A Lack of Vision The applicant takes a technical approach in designing structural BMPs to help ensure good urban runoff water quality,but ultimately demonstrates a lack of vision by ignoring the aesthetic benefits and habitat values that a mini-wetland natural treatment system could provide as part of Bixby-35 the treatment train. Altering the project to incorporate one or two mini-wetlands would be a nice touch that would recognize the apparent wetland heritage of a place where 15 wetland vegetation species(and counting)still survive today. _ J Yours truly, Mark D.Bixby 17451 Hillgate Ln Huntington Beach,CA 92649-4707 714-625-0876 e-mail:mark@bixby.org Attachments: (A) DEIR Table 3.3-1 Plants Observed on the Project Site(Revised) (a)Wetland Status Codes Defined (c)Annotated aerial photograph showing wetland vegetation seen during November 2003 (p)City Council Public Comments PowerPoint presented on October 6,2003 3-139 • Table 3.3-1 Plants Observed on the Project Site (Revised) - This revised version of DEIR Table 3.3-1 includes corrections for all of the errors and omissions mentioned above. Modifications have been Wetland Scientific Name Common Name Statos Cade AIZOACEAE—FIG-MARIGOLD FAMILY Mesembryanthemum crystallinuml Crystalline iceplant ANACARDIACEAE—SUMAC FAMILY Rhus integrifolial Lemonade berry APIACEAE(UPABELLIFERAE)—CA*RROT FAMILY Foeniculum vulgate' Sweet fennel _ FACIl ARALIACEAE—GINSENG FAMILY Hedera helix' English ivy ASTERACEAE(COMPOSITAE)—SUNFLOWER FAMILY Heterotheca grandiflora' Telegraph weed Isocoma menziese Coastal goldenbush FACW 000:010AC04.74000g*.:1041.0( $iti414..!#-Oltotrope OBL BRASSICACEAE(CRUCIFERAE)—MUSTARD FAMILY Brassica nigral Black mustard CARYOPHYLLACEAE—PINK FAMILY Spergularia marina' Salt-marsh sand spurry OBL CHENOPODIACEAE—GOOSEFOOT FAMILY H Atriplex semibaccatal Australian saitbush FAC Atriplex lentiformis ssp. lentiformis2 Brewer's saltbrush FAC Bassia hyssopifolia2 Five-horn bassia 'FAO Suaeda taxifolia2 Woolly sea-blite Chenopodium califomicum2 California goosefoot Salsola tragus' Russian thistle CYPERACEAE—SEDGE FAMILY Cyperus eragrostis2 Tall flatsedge FACW • 3-140 Ai-6(hr\nell+- A 1 /2_ • • Scientific Name Common Name Wetiand Sfatus'Gode FABACEAE(LEGUMINOSAE)--LEGUMEIPEA FAMILY Acacia sp.' Acacia FAGACEAE—OAKIBEECH FAMILY Quercus sp.' Ornamental oak JUNCAGINACEAE—ARROWGRASS FAMILY Triglochin concinnurri2 Arrowgrass OBL MALVACEAE—MALLOW FAMILY Melva parviilora' Cheeseweed Malvella 10ros43 {c1 :taltow FAC MYRTACEAE—MYRTLE FAMILY - Eucalyptus globules' Tasmanian blue gum OXAUDACEAE—WOOD-SORREL FAMILY Oxalis pes-caprae' Bermuda buttercup/sour grass POLYGONACEAE—BUCKWHEAT FAMILY Rumex crispus' Curly dock FACW- POACEAE—GRASS FAMILY Cynodon dactylon' Bermuda grass FAC DistichlisspicataZ Saltgrass FACW Polypogon monspeliensis2 Rabbitsfcot grass • FACW.+ Parapholis incurva2 Sicklegrass OBL I. Site visit by BonTerra Consulting on December 19,2001 2. Site visit by EIP on September 24,2003 3. Additional species noted by Mark Bixby on multiple site visits 3-141 A cI vrv1evi-A 212. tl -, Wetland Status Codes Defined From http:/fplants.usda.govfwetinfo.html: Code Wetland Type Comment OBL Obligate Wetland Occurs almost always(estimated probability 99%)under natural conditions in wetlands. FACW Facultative Wetland Usually occurs in wetlands(estimated probability 67%- 99%),but occasionally found in non-wetlands. FAC Facultative Equally likely to occur In wetlands or non-wetlands (estimated probability 34%-66%). Usually occurs in non-wetlands (estimated probability 67%- FACU Facultative Upland 99%),but occasionally found on wetlands(estimated probability 1%-33%). Occurs in wetlands in another region, but occurs almost _ always(estimated probability 99%)under natural UPL Obligate Upland conditions in non-wetlands in the regions specified. If a species does not occur in wetlands in any region, it is not on the National List. Wetland status codes"reflect the range of estimated probabilities(expressed as a frequency of occurrence)of a species occurring in wetlands versus non-wetland across the entire distribution of the species.A frequency,for example,of 67%-99%(Facultative Wetland)means that 67%- 99%of sample plots containing the species randomly selected across the range of the species would be wetland.When two indicators are given,they reflect the range from the lowest to the ' highest frequency of occurrence in wetlands across the regions in which the species is found.A positive(+)or negative(-)sign was used with the Facultative Indicator categories to more specifically define the regional frequency of occurrence in wetlands.The positive sign indicates a frequency toward the higher end of the category(more frequently found in wetlands),and a negative sign indicates a frequency toward the lower end of the category(less frequently found in wetlands)." 3-142 AH-Uchrieri+- i / Wetland Vegetation Seen during November 2003 Site Visits - y a r tw • • • ,a _ a s ti n h 1, e Fir , s. _ B s fi' �t M ,`� m 1 _ `t2 „ • ." • .0 _.L 1 .ti kCf B=Bassia hyssoprfolia(Five-horn bassia,FAC) NOTE:nearly all plants listed C=Cynodon dactylon(Bermuda grass,FAC) on this map are found at or D=Distichlis spicata(Saltgrass,FACW) above street grade level. H=Heliotropium curassavicum(Seaside heliotrope,OBL) Each map letter indicates one M=Malvella leprosa(Alkali mallow,FAC) or substantially more plants. P=Parapholis incurva(Sicidegrass,OBL) R=Polypogon monspeliensis(Rabbitsfoot grass,FACW+) S=Spergularia marina(Salt-marsh sand spurry,OBL) - 3-143 A*66 h rnevi1- C ! /1 HB C:ity Council Public Comments October 6,2003_ • Pacific City A Case Study in Bad-Faith Grading Mark Bixby mark@bixby.org Timeline • 09/09/03 —wetland characteristics mentioned by me at PC study session • 09/11/03 — pond filling & vegetation removal; stop work order issued by city • 09/17/03 — stop work order ignored; more pond filling & vegetation removal • 09/18/03 — complaint filed w/Coastal Commission Enforcement Division 1 3-144 (A('VI Li I/Z , • 2003- LIB City Council Public Comments October 6, Pacific ' Mobile Home Park Looking west -.... : • ‘,•,-..!t....,....,;:-, :,-i."'-,:-- •.'" ..••- „.,,,,..:..-''':'•''.•.:::, .•--'iE-•.-. 2.`' e:. ,,,:!_;,..;...,,:',,,,..,:'.. •_‘...,_-_,.-2'1.-..- --- ---;-'.,, '7-2?I''' ' ‘..--,,-.7,."`-'';..,'!--..:-:-...2.::. _''''',.."'. :. '..' 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'L.'•:•i-.'f,-A.l'i•- •--. '' ,•.;7':` .c'' ,..,,,,....,,\,,-,,r,!..,....*,:-.- '.:*•-',".:. 4--- .:...-'..,',1.-... ---._',.--'':.,,-.: _'4-•-..,"...;:.--,--.7.7..-=4,-- pi,4,,.,``.43=-4\'',-?'r'..I''''rc.•'f':T.;,.4''',.''tq:=;.:1',.-.,.%,-.4'..,.. ......----.:,._<.-.,:i,z,-::....,,.._.,_•;,._, ..., rEA'''',.."7:a-:;•!.*.,-4- 1,...-,'7,frp;63:.4'"(ILL''.. .,,.;"'‘42.2,..s.1:-:'..:,.:.Z.LC-....,---.-- ' yr75,-..W,',,.::,c---. .4,-,.1,1:5,1;',. :2_..,i.,-..,--,-:;z71;4:t? :".---,' • • .',-'1.''..!•'<1.--'-,'''',-'2.,;,,ii::.!,,Tifkce.,•: -...,-. September 7, 2003 ,....,,,...,......_ 2 • 3-145 + r), r) / AA46 r Iii vvIetil HB City Council Public Comments October 6,2(}03 • - , • Y • :>>• September 14, 2003 • • • • • • September 17, 2003 3 3-146 A /A/ to PL'1+ F) BB City Council Public Comments October 6,2003 i L'^i: -9''_,�� 0 • • _S .. -ice r ---..• - •.. _ - _, r 4� r,f xl ' , • } • " ci'�. {v r ' i � syif i: Ze } c.l i -te ^ ti1 . � r :] > ' c � vy�'. Y < 4 t r ti a, _, r September 21 , 2003 • PCH & Huntington St. Looking west 4 3-147 October 6,2003 HB City Council Public Comments a .1.. September 7, 2003 ,.....;'...a.....:.,-,:�"hY.R i� a,;. .T .':•tt�,.yam 1O_ ll. -cue 1' •^ 4 k 34`5, -.' �F , � . -,. d a...- ;r"aIplIII , i gq • • f ll 3 September 14, 2003 5 3-148 HB City Council Public •Comments October 6,2003_ �:5�.'.li rji '`=w 7} . n .� _ _ r..-cam:.i�i�., _,:•.,,1;,4 -.:;_4 _ ;'.�+'.. - �i.-.`• t"�fir ± ais�i+.=:-4.-e r kS ry. September 17, 2003 • 4 yM r l ,-1 l . 1 `F�'�>S.JrY ^1 ( i .ii a y x '( _laci',+, September 21 , 2003 6 3-149 • [as-1-7.r ',�,nn,flrfE ! .� 1r if • . • r • , HB City Council Public Comments October 6,2003_ Conclusions n • Egregious bad-faith actions by Makar • Makes a mockery of the planning process • Deja vu (Shea Parkside grading abuses) • Time for fines instead of wrist-slaps! But wetland vegetation still exists! Hopefully the DEIR will contain the whole P Y truth and nothing but the truth Continued monitoring is warranted... 7 3-150 A-4-77r (n in/1P(/1-{- I J 7/k w 1 . HB City Council Public Comments October 6,2003- _ Your Monitoring Help is Needed! Contact me for FREE training on how to recognize wetland vegetation species anywhere in Huntington Beach Mark Bixby mark@bixby.org 8 3-151 ri , '/Q • ;6 I 4 Comments Of Paul Cross On Draft Environmental Impact Report No. 02-01 For The Pacific City Project 1. The project will destroy existing public sight-lines to the ocean enjoyed by users and residents of Huntington Street and Alabama Avenue. Statements in the EIR that there are no existing views of the ocean which are worth preserving at any point north of Atlanta Avenue are false and must be corrected. Pacific City will extend two and one-half city blocks,with a maze of buildings reaching 90 feet above sea level. For an unbroken quarter of a mile,no view of the ocean will remain for anyone Cross-1 north of Atlanta Avenue.There is no sense of city planning. Instead,the interest of the developer is placed ahead of the interest of the neighborhood north of Atlanta Avenue. Hundreds of pedestrians and vehicles travel south on Huntington and Alabama Streets and can view the ocean from vantage points north of Atlanta Avenue.These sight-lines should be maintained in keeping with virtually all other north-south,ocean-close streets of Huntington Beach. 2. The project will overload vehicular traffic on Huntington Street.This overload is not properly remedied by an existing proposal to extend Delaware Avenue through the middle of adjacent Pacific Cross-2 View Mobile Home Park. Two additional Huntington Street traffic lanes are required,both to be taken from the Pacific City project,not the adjacent mobile home park. — 3. The extreme height of the buildings proposed for the Pacific City residential units(90 feet above sea level versus 10 feet for other homes along Huntington Street)will cast shadows over the first tier of mobile homes,and in some cases as far as the second and third tiers of the mobile home park. Therefore,for this additional reason,Huntington Street must be widened by two lanes into the Pacific Cross-3 City project.As well,a landscaped median strip along Huntington Street is necessary to filter the view downward from the condos to the mobile homes and upward from the mobile homes to the condos.. 4. The public walkwaythrough the project from Alabama Avenue to Pacific Coast Highway will not — g g Y provide a view of the ocean except at the extreme south end of the walkway. This walkway is mandated by order of the California Coastal Commission and by an order of the City of Huntington Beach;and is the right-of-way of a former passenger railroad. Destruction of the ocean sight-line Cross-4 along the old railway right-of-way is contrary to the clear intent of City and Coastal Commission orders entered in 1995.Nothing is offered as recompense for this loss. Instead,the City appears eager to reward the developer at the expense of residents who would use the old railway trail. - 5. The Pacific City project is to be constructed on a podium or platform rising 30 to 32 feet above sea level, and will not follow the natural downward slope of the land. For example,Huntington Street at its intersection with Pacific View Avenue is only 5 feet above sea level,yet except for a single tier of four story condos immediately adjacent to Huntington Street,all of the residential buildings will be placed on top of the 30-foot platform,and all except the tier directly along Huntington Street will be up to 60 feet higher than the podium level. Of the proposed 516 residential units, about.95 percent will be encased in a four story configuration.More specifically,only 10 of the units will present a two- story face and only about 15 more(those directly facing Atlanta Avenue)will rise three stories. Thus, Cross-5 the ambient height of the residential project will be 90 feet above sea level and not in keeping with the 'downward slope of the terrain. Although,there is a nominal 50-foot height limitation for four story residential units,that limitation permits a 3 or 4 foot addition at the base of a building and another 5 to 10 foot addition at the roof. Couple those extensions with a 30 to 32 foot high podium and there are buildings of up to 6 stories tall,much higher than anticipated by the California Coastal Commission. - In this regard,the mounding of dirt to encompass a two story garage,with four floors of condos above, is still a six story building.By an order entered in 1995,the Coastal Commission contemplated that there would be an extension of Walnut Street which would follow the natural downward slope of the land from I'`Street to Huntington Street. Instead,the developer proposes to mound the land along virtually the entire length of a different street,Pacific View Avenue,thereby raising the level of the new east-west roadway to 29 to 30 feet above sea level for most of its length through the project.Only at the extreme east-end does Pacific View Avenue finally dip sharply down to meet Huntington Street, 3-152 which as noted is about 5 feet above sea level at that point.Thus,by eliminating the anticipated extension of Walnut Street and by building up the sloping land,the builder seeks to obtain six story building heights not authorized by the Coastal Commission. Reasonably,the developer must be compelled to reduce the elevation of the buildings which otherwise would be sited up 25 feet below the podium level.That is,should the builder wish to adhere to a concept of placing buildings on a tall Cross-5 artificial platform, sight-lines and air movements must not be thereby impaired. In this regard it is important to remember that the Coastal Commission rejected pre-1995 proposals to erect tall structures on the residential portion of Pacific City.The explicit four story height limitation of the Coastal Commission must be respected, and not corrupted by artifice. Clearly,over much of the site,the the proposed podium is a third floor cover for six story buildings. 6. Bus pullouts must be provided along Pacific View Avenue,together with bus shelters,benches,and kiosks for the posting of bus schedules. Over 150 busses traverse the perimeter of Pacific City each day. The failure to adequately accommodate public transit at the site is shocking.The routing of busses along Pacific View Avenue will shorten the route of one-half of the daily busses by about one- Cross-6 half mile,and will save fuel and reduce pollution. As well,access to the site by handicapped individuals will be enhanced. Also, some automobile traffic will be eliminated and parking needs will be reduced. Indeed,merchants located at the commercial center of Pacific City could participate in a bus pass system for their bus using customers in addition to validation of parking for automobile using customers. — 7. First Street is designed to be up to 100 feet wide,and at its endpoint with Atlanta presently has a cross-walk of 130 feet. This is far too wide and is unacceptable. Apart from being dangerous,the wide girth of the street transforms Pacific City into an island separate from downtown Huntington Beach. A median strip and traffic Iight will help but more needs to be done to make crossing 1st Street pedestrian friendly.The needed elimination of two lanes of 1st Street would only cause the loss of 16 parking spaces on the east side of Is'Street and 13 more on the west side of 1st Street.There still would Cross-7 be four traffic lanes,plus a median strip. The City owned sliver of land located at the corner of 1 stStreet,at its intersection with Atlanta-Orange,would provide supplemental parking to replace the loss of 29 parking spaces on Id Street,if such should prove to be necessary.The two eliminated lanes of roadway could easily be ceded back to the developer. In return,some of the mitigating measures enumerated herein could be imposed as a tradeoff for the benefit of the City and its residents. • 8. The proposed 516 residential units require 6.9 acres of additional city parkland. The developer seeks to� meet that obligation by the payment to the city of"in lieu of fees"which may reach as high as$12,000,000. The money would be spent at some indefinite point in the future for parkland located somewhere in Huntington Beach,but unfortunately not in the vicinity of the area impacted by Pacific City. There simply is no land available anywhere near Pacific City which can be converted to the required amount of public _ parkland. The ocean is not a proper substitute. Accordingly,the necessary parkland should come out of the Pacific City project itself. The outlines of an acceptable Pacific City parkland dedication is contained in a City of Huntington Beach Planning Department, Subdivision Committee publication dated October Cross-8 21,2003. Therein,as Item 3 a of Pacific City Subdivision, Suggested Conditions Of Approval—Tentative Tract Map No. 16338,the center of the residential complex would be fully opened to the public and would become part of downtown Huntington Beach,not an isolated island as presently planned by the builder. Inasmuch as the proper treatment of Huntington Street(wider by two lanes and a median strip)and a proper respect for the downward sloping nature of the terrain(true four and two story buildings,in place of six story buildings over much of the project),would cause the loss of some residential units,imposition of suggested condition of approval(Item 3 a)need not entail the loss of any additional residential units. Of course,if Huntington Street is not widened and if buildings five or six stories high measured from the natural slope of the land are allowed,then Item 3 a would require the loss of 60 units as specified therein, so as not to violate public parkland requirements. 3-153 9. Residential areas to the north of Pacific City may contain up to 25 units per acre,and can not exceed three stories.Except for Pacific City,no surrounding land is zoned for multiple family high density. There is a tract of land located behind the new Hyatt Hotel on Pacific View Avenue which was similarly zoned,but that land is being developed as medium density residential,two steps down from the plans of the developer for Pacific City, Circumstances have changed greatly after the 1995 action imposing a 30-unit limitation on Pacific City. For one thing,the developer has waited, and waited and waited to submit a reasonable plan for Pacific City.Upon information and belief,the site was purchased for$20,000,000 and has a tax base well below the current market value of over $100,000,000 for 31 acres of undeveloped Orange County ocean-front property. Here,keep in mind that any clean-up costs associated with the site must be borne by Chevron Corporation.With the huge and continuing escalation of property values along. coastal California,the developer appears to have expended a tremendous amount of energy upon public Cross-9 relations and hardly any on actual development.The sound business judgement of the developer to await steep land value increases cannot be gainsaid.However,in the face of such delay,the City cannot be bound to an imagined promise that 30 units per acre can be erected no matter how many years have passed and no matter how circumstance have changed The city is a place of one,two and three story homes. At the ocean,the sole residential high rise is Pier Colony,an abode of many weekend-summer time only residents.There is no need to build four more Pier Colonies at Pacific_City, catering primarily to part-time residents.Merchants benefit from a steady stream of year-round inhabitants.Furthermore, utility and sales tax receipts of the city are significantly augmented by year-round"townies"as opposed to"weekenders". Zoning should comport with actual neighborhood circumstances. Thus,the project must step down from its multiple-family,high-density designation to one of moderate high density of not more than 25 units per acre with a 35 foot height limitation. 1 10. The downtown specific plan,among other things,provides incentives for affordable housing. A modest number of homes will be provided by Pacific City on and offsite for lower income residents. However,the vast majority of the proposed 516 residential units will sell at an average projected price of$450 per square foot. Compare those prices,for example,with the ground rents of residents of the I 1 250 pads at Pacific View Mobile Home Park of$600 a month,and it becomes plain that Pacific City provides few incentives for affordable housing and more likely a disincentive should the future of the Cross-10 mobile home park be undercut by a need to construct roadways(Delaware Avenue or Huntington Street)into and over mobile home pads. Already,it appears that Atlanta Street will expanded into the mobile home park,causing the loss of homes. As well,the City of Huntington Beach continues to plan for the routing of Delaware Avenue directly through the mobile home park so as to handle vehicular traffic upon the full build-out of Pacific City.What a mockery,250 low cost housing units are lost,in return for modicum of additional abodes generated by Pacific City. 11. During 1995,by Resolution No.6685,The City of Huntington Beach, in accordance with the California Coastal Commission,adopted a coastal plan encompassing the area where Pacific City is to constructed. That plan requires view,light and air corridors to the ocean with a mix of two to four story structures.Unfortunately,the proposed plan is one for a mass of tall buildings with an ambient Cross 11 'height of 90-92 feet above sea level and as much as 85 feet above the street level of Huntington Street. Remember here that virtually all of the buildings will be affixed to an elevated platform of up to 25 or 27 feet above the surface level of portions Huntington Street,and that,as we11,10 additional feet can added to reach the apex of the roof. Thus,buildings with a 50-foot-four story limit,actually are six stories in height,and should not be permitted. 12. The 66—K V power line along Atlanta should be placed underground. Why the power line should Cross 12 continue as an eyesore and potential hazard is not explained or justified. 3-154 - • 13.. Access to the proposed public walkway commencing at Alabama Street and extending through the project to Pacific Coast Highway must be improved beyond the present concept. Although there is a sidewalk on the north side of Atlanta Avenue west of Alabama,the sidewalk does not continue eastward in the direction of Huntington Street.This oversight should be corrected.Again it bears repeating that Pacific City must not be an island separate from downtown Huntington Beach.In short,the public's access to the Cross-13 pedestrian pathway should be safe and inviting,with full sidewalks on both sides of Atlanta Avenue extending from Street to Huntington Street. There also must be a designated pedestrian crossover at Alabama,and a pedestrian controlled traffic signal at that location. In this regard,the proposed traffic light at Street and Atlanta-Orange is not sufficient for the needs of pedestrians crossing Atlanta at the Alabama intersection. Residents on the perimeter of the project are expected to endure six years of construction with endless the clanging of pile drivers.After all of that,will we be confronted with just another inaccessible habitat for weekenders,with little connection to Huntington Beach? 14. The six to ten-year time frame for completing the project is excessive. The developer should be isfinishedwithin two Cross-14 compelled to post a bond of in an amount sufficient to insure that construction i years. 15. Testing of the site for soil contaminants should be performed by an independent entity not selected Cross-15 solely by the developer or by Chevron. Submitted by Paul Cross, a resident of Huntington Beach at 109 Huntington Street, on November 14, 2003. 3-155 � I VERBAL COMMENTS Verbal Comments Pacific City DEIR Public Meeting-November 13,2003 1. John Sisker(Pacific City Action Coalition&Mobile Home resident) • The ER did not address the extension of Delaware Avenue through Huntington Street to Mobile Verbal-1 Home Park,but it is included in the traffic analysis • When will this occur(2008-2020)? • How will the extension affect traffic and overall circulation? ] Verbal-2 2. Paul Cross (Mobil Home resident) • Submitted previous comments on Nov. 6th Verbal-3 • His scoping comments were not commented upon in the EIR — ■ Why has the planning for this project taken so long? ,Verbal-4 • The construction period is too long for the project Verbal-5 • The construction period should be shortened to no more than 2 to 3 years • Need an independent study to characterize soil remediation conditions for closure report to ensure Verbal-6 safety ■ Maintain the existing sight line to the ocean along the east side of Huntington Street by moving the Verbal-7 proposed hotel westward by approximately 30 feet to preserve the view corridor • Street mouth at ls`Street and Atlanta Avenue is too wide,making it dangerous to cross • Keep 1S`Street narrower and consider giving up a portion of the street for additional parking Verbal-8 3. Mark Bixby • The vegetation survey performed in September for the DEIR was much better; however, the survey missed two species • The scientific name for Salt Grass used in the ERincorrect Verbal-9 • He will be submitting a written report,and will identify the correct species names within it • Vegetation table should be modified to include wetland indicator status of each species 4. Faye Mathis(resident on Alabama,facing Atlanta Ave.) • Concerned about the height(50 feet)of the development Verbal-10 • The height would obstruct views — 5. Al Calonico • Concerned about the traffic on surrounding streets Verbal-11 • All streets,except PCH,are one lane in each direction ■ What is being done to improve/widen the circulation on the surrounding streets? 3-157 — 6. Mike Churchin • Read written statement,provided as an Attachment to the Verbal Comments. Verbal-12 — 7. Paul Cross • Huntington Street should be widened by two lanes Verbal-13 • Mobil Home Park is put at great risk due to traffic conditions resulting from the project — ■ EIR does not adequately characterize the shadows that will be cast onto the Mobil Home Park from the new development; it will be cast three tiers back, and it should not matter if it is for a Verbal-14 period of fewer than three hours • The proposed condos will be too tall and will look down upon the mobil homes; a median strip on Verbal-15 Huntington Street with associated landscaping would help filter the views ] 1 • Traffic conditions, loss of views, and extension of Delaware are all problems characterized as a death threat to the Mobil Home park Verbal-16 • Some accommodation has to be made now for the Mobile Home Park • The City does not consider that the Mobil Home park even exists _ ■ Height of the proposed buildings is not consistent with Coastal Commission adopted policies of a 4-story height limit. The project includes 4 stories of building plus the 2 stories of subterranean Verbal-17 garage. The ground floor elevation would be above the existing ground level and taller than the development approved by the Coastal Commission; the configuration is too tall — • Sightline of the ocean should be provided by a pathway through the project; connection od'Verbal-18 surrounding area to the ocean must be maintained — ■ In favor of the commercial portion of the project, but not the residential because it is too]I Verbal-19 high/dense • He does not want the project to become another Pier Colony, which only appeals to weekend Verbal-20 visitors so do not pay any sales or utility taxes 8. John Sisker — ■ Traffic bottleneck on Atlanta Avenue, Huntington Street, and Delaware Street would have to be alleviated Verbal-21 • Huntington Street needs to be widened by two lanes, but must not encroach into the Mobil Home Park — ■ Mobil Home Park owner is committed to upgrading the park, but plans show that the City does Verbal-22 plan on the park being around in the future 9. Faye Mathis Verbal-23 • Plan for sidewalks on both sides of Atlanta 3-158 2 10. Paul Cross ■ Sidewalks are necessary to adequately connect pedestrians to the surrounding environment; need Verbal-24 adequate public access on project site _ 11. Mike Churchin • Favor an alternative with decreased density for the project Verbal-25 • Why did the lower density project behind the Hyatt meet density requirements for the City, but this project needs increased density? _ • Appropriate public access is needed for the project with wide walkways and views, not requiring the public to walk through a hotel wedding Verbal-26 • Amplified noise is unacceptable to nearby residents and needs to be analyzed Verbal 27 • Will there be outdoor concert venues? I • Concerned about the impacts of downtown development and commercial uses 1 Verbal-28 12. Paul Cross • No land is available in the nearby vicinity for a public park; with the development of 516 units,the developer will opt to pay in-lieu fees so that the City can buy parkland Verbal-29 • The two acre site should be a public park with two easements along First and Huntington Streets, which would become walkways _ • Integrate project with the rest of downtown Verbal-30 • City should open up project as a way of providing needed parkland Verbal-31 13. Laura Knox — ■ Read written statement, provided as Comment Letter LBBS in the Response to Comments Verbal-32 document 14. Mike Churchin • Problems associated with pedestrian access through the project site and connection to the Verbal-33 downtown area _ • Significant up-lighting on hotels floods onto adjacent properties and creates a glare effect in the l Verbal-34 fog;lighting needs to be directed downward • Existing requirements are not adequate to address erosion control problems • Need strict enforcement and compliance to control the amount of silt that gets transported onto the Verbal-35 beach from the project — 15. Paul Cross • Approximately 150 buses traverse the perimeter of the project area JVerbaI36 3-159 • • Approximately half of these buses turn on to Huntington Street towards Atlanta Avenue, and then A turn on First Street towards PCH;buses could be re-routed to Pacific View Avenue Verbal-36 • Public transit through the project site should be provided(bus turnouts,kiosks, shelters,etc.) _ • Why will the 66-kV powerline going to remain on the project site along Atlanta Avenue?; get rid Verbal-37 of it or put it underground Additional Discussion Items(dialogue among public) • Parking remains a concern Verbal-38 • Hotel/commercial/residential uses from the proposed project must provide adequate parking • When hotels (e.g., Hyatt) have large events, they ask employees to park on public streets; thus, although parking may meet code,its inadequate • Clarify if Delaware extension is part of the project because the traffic analysis is based on that Verbal-39 • Traffic increase would imminently result from the project and Huntington Street and Atlanta Avenue would need more than a stop sign;there needs to be a traffic signal installed Verbal-40 3-160 4 ` ATTACHMENT . (Written Input Provided by Mike Churchin at the Public Information Meeting) EIR Questions 1. The FIR does not address(1)the potential groundwater contamination and testing which had been done by Makar and Chevron in the west central part of the site as documented by Water Board engineer Kamron Saremi and(2)the misleading documents submitted to the city by Harding ESE,Makar and Chevron's consultant, identifying the southeastern part of the site as the area in question. Where are the test results documented by Saremi and why haven't they been Churchin-1 addressed by the OR and released to the public despite weeks of requests for their disclosure? Is this information so damaging that the city,Makar and Chevron are forced to hide it? 2. The FIR states in Section 3.7-7 that the soil involved in the 1999 export to the Hyatt exceeded city specifications for hydrocarbon contamination and was either excavated or remediated on site. As the"Final Environmental Closure Report"for the Hyatt submitted to the city by Hyatt developer Robert Mayer Corporation finds no evidence of contaminated soil, does this mean that the Final report was inaccurate? • Which report is correct? I Churchin-2 If the soil was indeed contaminated as the EIR suggests,where are the test results to support this statement? Where are the records of how much soil was excavated and where it was taken? The public has not seen these reports despite several requests from both the city and Makar for more details on Mayer's report And why is the soil contamination being disclosed now despite the public being told for years that the soil involved was clean? Once again,was this information so damaging that the city,Makar and Chevron are forced to hide it? 3. The ELK states in Section 3.7-9 that 1999 hydrocarbon testing in the southeastern part Of the site revealed levels of up to 130,000 mg/kg.This is approximately 15 to 100 • times higher than the prior testing conducted in the 1996 Phase II Study. As some of the areas tested in 1999 and 1996 overlap,does this mean that the site Churchin-3 became more contaminated over time? Or does this mean that the 1996 Phase II Study was inaccurate? U 3-161 w . Where are the test results and sampling maps to accompany the 1999 testing? I Once again,these documents have been requested from the city and Makar for months and have not been disclosed. Churchin-3 Is this yet another example of the city,Makar and Chevron hiding damming information? 4. In Section 3.7-5,the FIR references reports of a former gas plant,identified by a Chevron employee interviewed for the 1995 Phase I Study. The plant reportedly operated at the corner of First and Atlanta,north of the site. The EIR then makes two contradictory statements. It states,"...no documentation exists to support the existence of a gas plant"and then states;"If a gas plant did exist Churchin-4 on property adjacent to the project site,toxic contaminants associated with gas condensate from a gas plant could remain in the soil." What type of documentation would exist for an operation from a half century ago? Isn't a Chevron employee's statement verifying a gas plant sufficient? The E]R also asserts that any toxic contaminants associated with gas condensate fronT1 a gas plant could remain in the soil. How do you know that?Are there test results,documents or statements to support ', this? • Churchin-5 Or are you relying on the Chevron employee's statement for this information? If so,then wouldn't their statement regarding the existence of a gas plant also be reliable? The EIR also states,"These contaminants would be localized on the site and would not be expected to have migrated across First Street through the soil to the project site.As such,these contaminants are not expected to exist on the northwestern portion of the site or otherwise affect soils on the property site."• Where is the data to support this?Is there new testing of the northwest part of the site I Churchin-6 which we don't know about? Are you relying on the Phase II testing of the northwest portion and/or the 1999 testing by Mayer?Both of these reports have been contradicted in the FIR itself - I Is this still another example of the city,Makar and Chevron hiding damaging information? — 3-162 SPEAKER CARDS SPEAKER/COMMENT CARD Welcome to the PACIFIC CITY EIR INFORMATION MEETING Please complete this form if you wish to make public comments at this meeting. Please print. YOUR NAME: ` t'r3r r B)`-r1,6 ADDRESS: l 7 2/6l 6i[`s i' Street /Yl ZipCode?C'? GROUP AFFILIATION (if any): TELEPHONE: 71 Y—A -643.725 DATE: 1 b /1-7/03 DO YOU WISH TO SPEAK TONIGHT?: COMMENTS: -ra Lk- 3d3 _/ c tt lZ -,o 6eTe. 3 -3 -`/ y:r ce rre c-P/y —ate 5fee rt 1 tn� G5 `ri 3/ eaie5 tad ore -Co r �ar/ Sra.55 + Bixby(A)-1 t lat a Corr c D 4p eC ite.5 s1 Gz'i e. 1'$ b f 671 c 4 1 i'5 tff� ;c� i kaae r5o41d1r Serve rCp City of Huntington Beach 2000 Main Street, Huntington Beach,CA 92648 Attn: Mary Beth Broeren (Additional space on back) Give this form to Staff. Speakers will be called on starting.Jt approximately 6:30 p.m. • 3-163 SPEAKER/COMMENT CARD Welcome to the PACIFIC CITY EIR INFORMATION MEETING Please complete this form if you wish to make public comments at this meeting. Please print. YOUR NAME: F7OX C . R (LA C�.� �f . ADDRESS: 11-7 S i1cil &I (? !cam 7 Street �t11 Zip Code GROUP AFFILIATION (iif any): TELEPHONE: DATE: 11 ! ''G S DO YOU WISH TO SPEAK TONIGHT?: YL‹ COMMENTS: Tine. ET& does r 6\- pcogerll ciacier.cx 11Ne. enel1e5y e1;wa 1 re ce_ SS.te CUr,Si sIPA4- w% % }k,c.. <et . n1 s dS 7�c, ,;51 c P cin(a p el 5 nc. Ph 1 ap _ O ' Se, I t{ 4N GAL' .,Prod O*cr\av f Sec�nc>r, It. 14.i3 O 11v1:7 C —� SreACA11I, 141t. EER Co ve y f a�I t 143 "WAWA s e,Cori ery CGSC vw}w► o f ati->eas AIRS on riksta-far City of Huntington Beach 2000 Main Street,Huntington Beach,CA 92648 Oil t 31.‘ tetnhry tier c )uff4\14 rt e€ ---°*) Attn: Mary Beth Broeren (Additional space on back) Give this form to Staff. Speakers will be called on starting at approximately 6:30 p.m. II Brucculeri 1 IL al U N\ Ce t 1 s`suc., ETA IN, c.?- r1.3 4‘1004.4 4 _ 4 s 1 L` a 166444P t nl kc ar C. )c e. t/LW m:s)c.c.hos 5.Wer•VAC a1‘,1+(e ca ‘1 a 364 deM ie5 ch,ncic.1 Cesa c es Iaca‘eJ .1ow \hc. emeaseti e4)- 5v\e.. mcrvxki ,r; 41c,. t\ Valid 4.6 HGckdrevs 1•41►c need foeC 0.Were., be, cUer�' S• 'c 4re..n c.1�1 h oil + na rC.co1441. Ca,,►d be aCCIANO Wihe4.1 w10 fc&Q.T.J o c7irx .6. /oca l hi woo( 3-164 SPEAKER/COMMENT CARD Welcome to the PACIFIC CITY EIR INFORMATION MEETING Please complete this form if you wish to make public comments at this meeting. Please print. 7 YOUR NAME: Al CA 2 oil) /c: ADDRESS: 47.5 / IL/4)<c I ti Z 7.76 Street City Zip Code GROUP AFFILIATION (if any): TELEPHONE: 7/,— 7 ?- S 226 DATE: , DO YOU WISH TO SPEAK TONIGHT?: COMMENTS: CJ c "go -•- ,n f/ G f/ 721,e/v:s 6,0 T- e A g7—GJ 6 i`— a r STie 6 r1' g 23veit.�L Calonico-1 TAI f ic,v,c C, Ty 57,6�GTG�. l- City of Huntington Beach 2000 Main Street, Huntington Beach,CA 92648 Attn: Mary Beth Broeren (Additional space on back) Give this form to Staff. Speakers will be called on starting at approximately 6:30 p.m. 3-165 • SPEAKER/COMMENT CARD Welcome to the PACIFIC_CITY FIR INFORMATION MEETING Please complete this form if you wish to make public comments at this meeting. Please print YOUR NAME: 41` ► IL E C. f Lk. r c Gi (\. • ADDRESS: 5. 2l ! y. l.-15 prrL.. City Zp CodeGROUP AFFILIATION (if any): TELEPHONE: / DATE: 1 l! 13 1 0 2) DO YOU WISH TO SPEAK TONIGHT?: ‘/ COMMENTS: - Avu.iol i tti�li�/� ( L' A4A ) f� - r • � In l.AI Jv ( 'l.. g 1. • .1.0 5 • City of Huntington Beach _ 2000 Main Street,Huntington Beach,CA 92648 T idx- p. Attn: Mary Beth Broeren (Additional space on back) Give this form to Staff. Speakers will be called on starting at approximately 6:30 p.m. Churchin(A)-1 • 3-166 SPEAKER/COMMENT CARD Welcome to the PACIFIC CITY EIR INFORMATION MEETING Please complete this form if you wish to make public comments at this meeting. Please print. YOUR NAME:rif ' CA) ADDRESS: /3/ 1/`�4//..4" 11/ 5;] J// Street , City Zip Cade Cross(A)-1 GROUP AFFILIATION (if anypipdA,/d'�/,C }' TELEPHONE: L —/ ✓; n DATE: ��lJ � V '; DO YOU WISH TO SPEAK TONIGHT?: 7/1..•:,5 COMMENTS: —' City of Huntington Beach 2000 Main Street, Huntington Beach,CA 92648 Attn: Mary Beth Broeren (Additional space on back) Give this form to Staff. Speakers will be called on starting at approximately 6:30 p.m. 3-167 SPEAKER/COMMENT CARD Welcome to the PACIFIC CITY EIR INFORMATION MEETING Please complete this form if you wish to make public comments at this meeting. Please print. YOUR NAME: cu i/ ADDRESS: �5o C` 6-w-ri de,A1ZA i data, 6(egQ 94Q, -) ( Street City Knox-1 ��J p Code GROUP AFFILIATION (if any): TELEPHONE114-S 123 �o 7) DATE: it / 13 70 3 DO YOU WISH TO SPEAK TONIGHT?: l `t-S COMMENTS: City of Huntington Beach 2000 Main Street, Huntington Beach, CA 92648 Attn: Mary Beth Broeren (Additional space on back) Give this form to Staff. Speakers will be called on startingat approximately 6:30 p.m. P PP Y 3-168 SPEAKER/COMMENT CARD • Welcome to the PACIFIC CITY EIR INFORMATION MEETING Please complete this form if you wish to make public comments at this meeting. Please print. YOUR NAME: 2/ 51 - " f A J ADDRESS: • /-X:.Z) ,I /^ / 7,/,)94A1 - v _ Street City GROUP AFFILIATION (if any): TELEPHONE: 7,/- ziP4-151)eicl,e1,-,5±27-t:4.- „, z.DATE: /0) 21- 7‘71- DO YOU WISt / IH TO SPEAVONIGHT?: 9;6) / 7 CO1ENTS: P2-tv- Z-e(--ie 114: 1"4"7//"7`te - Mathis-1 7• ,.z4-'e7 • - iv s7YE • ‘,5 City of Huntington Beach 2000 Main Street, Huntington Beach,CA 92648 Attn: Mary Beth Broeren (Additional space on back) Give this form to Staff. Speakers will be called on starting at approximately 6:30 p.m. 3-169 SPEAKER/COMMENT CARD Welcome to the PACIFIC CITY EIR INFORMATION MEETING Please complete this form if you wish to make public comments at this meeting. Please print. YOUR NAME: t 5/9/J' ' 1i' �- _ ADDRESS: fez✓ i,f% ILE c�w%~ 7/./}7 . • frgee', '1 /✓?:r ?�'t', City Code GROUP AFFILIATION (if any): ` &� 3% s./ a4J TELEPHONE: �i(% % ‘_38S 5 DATE: . %1,03 DO YOU WISH TO SPEAK TONIGHT?: COMMENTS: �i'�i, Gfc-�G }-~ / ., -� . -& ,71 fy%�"� Sisker-1 City of Huntington Beach 2000 Main Street, Huntington Beach, CA 92648 Attn: Mary Beth Broeren (Additional space on back) Give this form to Staff. Speakers will be called on starting at approximately 6:30 p.m. 3-170 SPEAKER/COMMENT CARD • Welcome to the PACIFIC CITY EIR INFORMATION MEETING Please complete this form if you wish to make public comments at this meeting. Please print. YOUR NAME: —)O,4 %/S . ADDRESS: 80 A-e1%1,e �lei �if� /�'u 47-7 66 Pig" �i J �IZOraf1 TELEPHONE: iSZ P�v P�"'V GROUP AFFILIATION (if any): DATE: /7110 DO YOU WISH TO SPEAK TONIGHT?: COMMENTS: /0irl6UJLLE� ��"y�� DG�� s'cfJ,�,,t��% ,� ��F , Sisker-2 /56L9 ,e-ertO&r alhi 7J'0'Ge- L' 3/C �63 7O d/i/ex/' 6', 4 /- 0e7/7/,,2 4YA/7 - ty-- ,/'el / Sisker-3 City of Huntington Beach K: C � 2000 Main Street, Huntington Beach, CA 92648 Attn: Mary Beth.Broeren (Additional space on back) Give this form to Staff. Speakers will be called on starting at approximately 6:30 p.m. S' G , j/ /o �4 fC'.4i"-YiZ'ca 7! �? G 1j�J 1�J' ,7 G'6197 /}Bdd7 71y6 - G9/.75% .~ �.�T�.044. v,� "f/5 OfJ���/i j�QJLG/ � Sisker-4 - Ara5:-,117 6toi,„4,4990,16ei? 1.10&Z.41 /b&-3.4,0 5;5"/C' tJ 7, ce. �/JS/7 Aeox,'27 �� /� , ,t �Q/ �T /Jl/,l,7,/7�GK! J,77� Sisker 5 .„4c,e32--czisfzej /3 7 /€� ", „ : 1 C7- 3-171 Intentionally Left Blank Chapter 3 Responses to Comments 3.4 TOPICAL RESPONSES There were three issues raised in a number of the comment letters: (1) Water Quality, (2) Traffic Generation, and (3) Shared Parking. Therefore, topical responses have been prepared that consider the key points of the comments on each of these issue areas and present one consolidated response on each issue. Topical Response on Water Quality This Topical Response addresses concerns related to drainage issues and bacterial contaminants in runoff from the project site. Information presented in this response has been reviewed and affirmed by City staff with expertise in water quality issues. As discussed on pages 3.8-20 of the Draft EIR, the proposed project would be divided into two separate drainage areas with separate storm drain systems, as illustrated by Figure 3.8-5. The intent of this configuration would be to reduce stormwater runoff directed to the ASWPS. The predevelopment drainage area of 34.6 gross acres, currently tributary to the ASWPS, would be reduced to a 7.7-acre area designated Drainage Area"A."The balance of the site would be designated Drainage Area"B," and stormwater flows would be directed to the proposed project-specific drainage system in First Street, discussed below. All dry weather flows for the proposed project would be directed to ASWPS for treatment by OCSD. The reduction in stormwater flows directed to the ASWPS from the reconfiguration of the drainage areas on-site would result in a reduction in 100-year storm flow from 67.0 cfs to 21.8 cfs to the ASWPS. All proposed drainage improvements would be designed and constructed in accordance with the standards set by the City of Huntington Beach and the Orange County Flood Control District. Runoff from the site is governed by the Santa Ana Regional Water Quality Control Board (SARWQCB) through the programs that implement water quality standards adopted by the SARWQCB. With, and through the authority of, the State Water Resources Board, the SARWQCB acts as the water pollution control agency for all purposes stated in the Clean Water Act in the Santa Ana Region. Section 3.8.2 of the Draft EIR discusses the Regulatory Framework applicable to the proposed project. As discussed under this section, the Clean Water Act, which is enforced through NPDES requirements, the applicable Basin Plan, and the Orange County Drainage Area Management Plan would apply to the site, and the project would meet all standards identified in these programs. The Drainage Study Including Preliminary Hydrology Analysis and Water Quality Analysis for Pacific City (Hunsaker & Associates 2003a) demonstrates the project would be in compliance with these standards once the final documents are submitted and approved. This report was reviewed independently by the City and the City's consultants in order to ensure its technical accuracy. Thus, the proposed project would conform to all water quality requirements adopted by Pacific City EIR 3-173 Chapter 3 Responses to Comments the SARWQCB. As discussed under Impact HYD-1 of the Draft EIR, the proposed project would not violate water quality standards or waste discharge requirements; result in substantial sources of polluted runoff; or otherwise substantially degrade water quality. Although bacterial contamination has been a subject of discussion in recent years, the SARWQCB has not adopted water quality standards for bacteria and pathogens in urban runoff. Further, according to the U.S. Environmental Protection Agency (U.S. EPA 1991): Stormwater runoff is often rich in bacteria originating from ... non-human (and largely non-disease producing) sources and can contain high densities of indicator bacteria. Consequently, for receiving waters containing discharges which originate primarily from separate storm drainage systems (and do not contain sanitary wastewater),these indicators are ill-suited to accurately assess the water's disease-producing capabilities. Dry-weather flows in the portions of the City that drain to the ASWPS are currently treated for bacterial contamination by the Orange County Sanitation District (OCSD). The basis for current treatment of dry- weather flows is set forth in Resolution No. OCSD 01-07, which acknowledges that certain types of dry- weather urban runoff create public health and/or environmental problems, and that this runoff is infeasible to economically or practically control. As the OCSD has limited capacity available in its system to allow dry- weather runoff to be accepted, only a portion of the dry-weather flows in portions of the City are discharged to the OCSD, and the treatment of dry-weather flows is not required by the SARWQCB. As discussed above, no standards have been adopted to address bacterial levels in runoff. However, methods to disinfect runoff, thus treating the runoff for bacterial contamination exist and include ultra-violet treatment, ozone treatment, and chlorination/de-chlorination. The OCSD has identified that the RWQCB recognizes that the chlorination/de-chlorination process is the only feasible option to implement disinfection technology as quickly as possible, and this is the method currently used by OCSD to disinfect flows (OCSD 2002). Implementation of this method requires careful monitoring and management of hazardous materials required to complete the chlorination/de-chlorination process, which would result in secondary impacts if employed at the project site. Ultra-violet and ozone treatment require further investigation and study, and implementation of these treatment methods would involve detailed resource- intensive improvements, beyond typical Best Management Practices (BMPs). These improvements are currently under investigation by OCSD, the wastewater treatment provider for a 470-square-mile area. However, given the extent of efforts necessary to treat bacterial contamination in a manner that does not result in secondary impacts and the lack of adopted regulations addressing this issue, any of these undertakings would not be considered practical and are not statutorily required to address runoff from the 26.9-acre project site area. Nevertheless, the proposed project would include various measures to reduce the potential for bacterial contamination of runoff. On-site drainage areas would have the first flush (85-percentile 24-hour storm 3-174 City of Huntington Beach Chapter 3'Responses to Comments event or the maximum flow rate of runoff produced from a rainfall intensity of 0.2 inch per hour) and dry- weather flows treated by filtration systems included as part of project design. Also, as described on pages 3.8-18 to 3.8-19 of the Draft EIR, the Applicant would be required by the City to develop and implement a Water Quality Management Plan (WQMP) for the proposed project to maintain compliance with NPDES standards. The WQMP would include site design, source control, and treatment control BMPs to address the specific pollutants anticipated from the project and project site, and would detail the specific operation and maintenance of each BMP. These BMPs would range from general,relatively simple procedures, such as street-sweeping, to educational programs regarding a range of issues, such as disposal of hazardous/toxic wastes, pickup and disposal of animal feces, and detection and elimination of illicit dumping. In addition to ensuring that the project meets current water quality standards—including non-point sources of contamination—these BMPs would also reduce the potential for bacterial contamination of the water supply. In addition, the project would comply with the conditions of the City's NPDES Stormwater MS4 permit (NPDES No. CAS618030) and the Drainage Area Management Plan (DAMP) adopted under the terms of the permit. The goal of the permit is to protect beneficial uses of receiving waters by reducing pollutant loading to surface waters from urban runoff to the maximum extent practicable (MEP). MEP as defined in the permit, is the maximum extent feasible, taking into account considerations of synergistic, additive, and competing factors, including but not limited to gravity of the problem, technical feasibility, fiscal feasibility, public health risks, societal concerns, and social benefits. The Applicant would be bound by the City's Water Quality Ordinance, adopted to ensure compliance with the NPDES Stormwater Permit, applicable provisions of the DAMP, and the Statewide General Permit for Stormwater Discharge Associated with Construction Activity. With respect to dry weather flows, Drainage Area"A" would continue to go to the ASWPS for all dry-weather and stormwater flows. In addition, the dry weather flow for Drainage Area "B" can be routed into Area "A" and to the ASWPS, in order that, at the City's discretion, these flows may be routed for treatment by OCSD. Section 3.8 of the Draft EIR has been revised to include additional information related to bacterial contamination in water quality. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. Pacific City EIR 3-175 Chapter 3 Responses to Comments Topical Response on Traffic Generation This Topical Response addresses comments stating that trip generation is too low. Trip generation presented in the analysis is based on standard industry data and location-specific characteristics of the area that the City has developed based on previous experience. The analysis considers a reasonable, conservative scenario for trips resulting from the proposed project. Several commenters questioned the methodology for determining trip reductions. The reductions to base trip volume taken included reductions for internal capture and mode shift, as shown in Table 3.14-10 on page 3.14-29 in the EIR. The reductions vary based on trip generation time period [A.M. or P.M. peak hours, or Average Daily Trips (ADTs)]. Internal capture refers to reductions taken due to the interaction of uses on-site. That is, vehicular trips would be related to more than one of the uses on site. Internal capture ranges from 8 to 15 percent, based on the type of use and the time period. Reductions to the base trip volume can be applied through use of either a mode shift or pass-by traffic. Either of these methodologies support the concept that a portion of the trips resulting from the proposed project would be related to vehicular trips already on the roadway. A mode shift reduction was considered the more appropriate type of reduction to take due to the site proximity to the Downtown core district and recreation attraction; the project site is approximately 0.25 mile south of the core of the City's Downtown. It is reasonable to assume that customers would walk 1/4 mile, which takes approximately 9 to 10 minutes. As such, it is appropriate to expect that a portion of the persons in the Downtown area would access the project site. The outcome of either the mode shift or pass-by methodology would result in a similar total number of trips generated from the site, and the conclusions of the analysis would be the same. The mode shift for the proposed project ranged from 10 to 25 percent, based on type of use and time period. Consequently, overall trip reductions ranged from 18 to 32 percent for the proposed project. To ensure that the analysis reflects industry standards for estimating trip generation potential, several factors were considered, including the following: • Nationally accepted base trip generation statistics from the Institute of Transportation Engineers • Typical character of sites used in compiling the ITE trip generation statistics (location, transit use potential, pedestrian accessibility, etc.) • Assessment of potential interaction between individual uses within the development (mixed use/internal trip capture) > Potential interaction as indicated in the shared parking analysis > Multi-use development procedures and statistics identified in the ITE Trip Generation Handbook 3-176 City of Huntington Beach - Chapter 3 Responses to Comments > Consideration of relevant traffic studies with internal trip capture (identified below) > Exercise of professional discretion for appropriate internal trip capture • Assessment of potential interaction between project land uses and external attractions/uses > Consideration of proximity to Downtown core as an example of interaction > Consideration of relevant traffic studies with mode shift(identified below) > Primary intent of development to capitalize on area activity such as beach, Downtown business core, transit use, pass-by trip potential and other area hotels > Project's inherent support of destination resort concept for coastal visitors ITE Trip Rates are considered "base trip rates" and reflect the number of trips that would occur from each use as a stand-alone development, with no reductions for transit, pedestrian uses, or individuals parking once and accessing more than one use. As such, it is appropriate to apply reductions to these base trip rates to reflect the local environment of the development, which influences the number of trips the project generates. This concept is specifically cited in the ITE Trip Generation Users Guide (ITE 1997) which states the following: Data were primarily collected at suburban locations with little or no transit service, near-by pedestrian amenities, or transportation demand management (TDM) programs. At specific sites, the user may wish to modify trip generation rates presented in this document to reflect the presence of public transportation service, ridesharing or other TDM measures, enhanced pedestrian and bicycle trip-making opportunities, or other special characteristics of the site or surrounding area. Thus, as suggested by the ITE, trip rates were modified for the traffic study for the proposed project. The October 1998 ITE Trip Generation Handbook gives further guidance by presenting a review of the procedures and concepts that are applicable to mixed-use developments. While there is an entire chapter dedicated to this topic (Chapter 7), it specifically states: "the analyst is encouraged to make logical assumptions in his/her use of this procedure. In summary, use good professional judgment." Therefore, it is standard industry practice to apply trip reductions based on the professional discretion of the analyst. CEQA practice permits disagreement among experts in the analysis. This is identified in CEQA Guideline Section 15151, which states that disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. Practice Under the California Environmental Quality Act (Stephen L. Kostka and Michael H. Zische), Section 13.26 expands on this concept by citing case law that the lead agency may rely on the conclusions presented in the EIR, even if other experts disagree with the data, analysis, or conclusions presented, Laurel Heights Improvements Association v Regents of the University of California (1988)). Disagreement was presented during the public Draft EIR review period, as presented in the comment letters. This Topical Response provides the supporting data to explain Pacific City EIR 3-177 Chapter 3 Responses to Comments why the methodology used in the analysis is appropriate, even though public commentors have identified disagreement with the conclusions. The project itself represents a unique development in the area, and as a result, no one prior traffic study can be relied on as containing the data that would be appropriate to use in this analysis. The unique characteristics of the project include its size, mix of uses, and location. The project site, at 31.5 acres, represents a singularly large scale mixed use development in the Downtown- area. The site would result in internal capture rates unlike those experienced in smaller scale mixed use developments in the area, because the project site would include a greater number of uses that would share patrons as compared to smaller developments. With respect to the mix of uses, the project site would include four non-residential uses that would generate trips: hotel, retail, restaurant, and office. Mixed-use developments typically include only two or three different types of uses. The total of four types of uses increases the complexity of interaction among uses. With respect to the location, the project is sited immediately adjacent to not only the beach but also the Downtown core, in a location intended to maximize the project's interaction with these uses. Notwithstanding the unique aspects of the project, several recent documents support the range of the internal capture and mode shift percentages used in the EIR. The Downtown Parking Master Plan (DPMP) is contained in Section 4.2.14 of the Downtown Specific Plan. The DPMP identifies reductions that average — 38 percent of code requirement, based on the particular land use. While this Plan focused on parking use, it also demonstrates the synergy of the mix of retail and restaurant uses within proximity to beach amenities. This study supports the conclusion that a 30 to 40 percent reduction in overall trip generation has been experienced in the Downtown area compared with the individual base trip generation that would be estimated for stand-alone uses. The recently approved and certified "The Strand" EIR (SCH No. 2000051109), located at PCH and 5th Street also applied mode shift and internal capture reductions. This development includes approximately 100,000 square feet of commercial retail and a 152-room hotel. The trip reductions applied in that analysis included 30 percent reduction for mode shift and an internal capture rate of 10 percent. The Pointe Anaheim project in the City of Anaheim also exhibits characteristics similar to the proposed project. While this project is not in a beach community, the project site is situated adjacent to another regional attraction—Disneyland. That project includes hotel, theater, retail, restaurant, and entertainment uses totaling approximately 1.5 million square feet in all. The traffic analysis presented in the Mitigated Negative Declaration (City of Anaheim, 1999) used internal capture rates ranging from 20 to 30 percent and mode shift ranging from 45 to 55 percent. Therefore, as seen in these examples, the base trip generation reductions taken for the project, including mode shifts ranging from 10 to 25 percent and internal capture ranging from 8 to 15 percent, resulting in overall reductions ranging from 18 to 32 3-178 City of Huntington Beach Chapter 3 Responses to Comments percent, are comparable to, and often less than, reductions taken for other developments that exhibit some similarity to the proposed project. The project traffic generation contained within the Pacific City traffic impact analysis report, after application of the internal capture and mode shift reductions, is consistent with the appropriate vehicle traffic generation forecast for Pacific City based on the specific land use characteristics of the development, size, and location. Pacific City EIR 3-179 Chapter 3 Responses to Comments Topical Response on Shared Parking This Topical Response addresses comments stating that the shared parking analysis is not appropriate. The shared parking analysis is based on industry data prepared by the Urban Land Institute (ULI), Institute of Transportation Engineers (ITE), and the City's accumulated experience in parking demand characteristics. The analysis considers a reasonable scenario for parking demand resulting from the varying mix of proposed visitor-serving commercial uses (hotel, retail, office, restaurant, cultural, and entertainment); it does not include the residential portion of the proposed project. The Topical Response on Traffic Generation demonstrates the appropriateness of the use of the mode shift for the project. This concept was also applied to the shared parking analysis. Therefore,refer to that Topical Response for an explanation of the basis for mode shift reductions, which are reflected in the shared parking analysis. Shared parking accounts for the opportunity for a mix of land uses within one area to share the same parking supply without having to provide additional parking for each individual land use. This is due to variations in the peak hour of parking, and the multiple trip purposes that can be satisfied at a mixed-use project site.When uses share a common parking footprint, the total number of spaces needed to support the collective whole is determined by adding parking profiles (i.e., the percentage of spaces occupied at a given time), rather than individualpeak ratios as represented in the Cityof Huntington Beach Zoning and Subdivision p � g Ordinance (ZSO, Chapter 231—Off-Street Parking and Loading Provisions). The shared parking methodology is applicable to the commercial portion of the proposed project because the individual land uses (i.e., retail, restaurant, hotel, and office uses) experience peak demands at different times of the day. The base parking demand ratios are consistent with City code and are all design ratio demands without any reductions for seasonal variations. For analysis purposes, some ULI recommendations have been increased during particular times of day to provide a conservative approach. For example, ULI recommends occupancy of 30 percent of peak parking demand for hotel use during the noon hour, but this has been increased to 75 percent in the analysis. A key factor in the shared parking analysis is the understanding that the peak demand for commercial parking spaces occurs during the midday hours of 12:00 PM and 1:00 PM, when the mode shift reduction factors discussed under the Topical Response on Traffic Generation are appropriately applied. The shared parking analysis for the proposed project considers parking demand during the weekday (Table 5A), and on the weekend (Table 5B). Parking demand in the visitor-serving commercial portion of the project site 3-180 City of Huntington Beach Chapter 3 Responses to Comments would be higher during the week, primarily due to parking demand related to office space that would not occur on the weekend. The Downtown Parking Master Plan (DPMP) contained in Section 4.2.14 of the Downtown Specific Plan validates and uses the concept of shared parking. Although the DPMP parking rates do not apply to the proposed project because the proposed project is not within the DPMP boundaries (which extends approximately one block east and west of Main Street, from PCH to Acacia Avenue). The project site is within the Downtown Specific Plan area, and therefore would interact with the Downtown, as patrons of the project site would include patrons of the Downtown area. Due to the uniqueness of the project, as discussed in the Topical Response on Traffic Generation, site-specific data were used to determine parking rates. In order to provide a comparison for these rates, the parking rates from the DPMP were applied to the project. Parking requirements under the DPMP, if they were applicable to the proposed project, would be 1,566 spaces, as shown in Table 4A, which is only slightly more spaces (31) than the 1,535 spaces required based on the project-specific shared parking analysis. The project site is approximately 0.25 mile south of the core of the City's Downtown. It is reasonable to assume that customers would walk 1/2 mile, which takes approximately 9 to 10 minutes. As such, it is reasonable to expect that a portion of the persons in the Downtown area would access the project site. The analysis does not rely on the use of off-site parking facilities to meet project needs. Rather, through the application of the mode shift, it assumes that some vehicles will already be parked in the area, within walking distance of the site, and therefore, these vehicles would not be moved to park on the site. A number of comments request detail on how the ballroom/meeting facilities and spa were included in the shared parking analysis. As identified in Table 2-5 on page 2-13 of the Draft EIR, 16,000 square feet are allocated to balh-oom uses. Of this area, there would be 9,300 sf of useable space allocated to the ballroom. This space can be allocated as ballroom space/banquet facilities and conference space/meeting rooms. The space would generally be used for conferences and meetings during the week and banquet activities on the weekend. Thus, the terminology varies depending on the day of the week that is referred to, but, under any scenario, would include a maximum of 9,300 sf of useable space. This space is referred to as "ballroom" under this Topical Response. The usable space of the ballroom is a relatively small area. It represents less than 3 percent of the hotel square footage, and is far less than the adjacent Hyatt which includes approximately 52,000 square feet of meeting space, including a 20,000 square foot ballroom, or the adjacent Hilton, which includes approximately 19,000 square feet of ballroom space. City code requires 1.1 parking spaces per hotel room, which factors in parking demand associated with the ballroom and spa; parking demand for these uses are typically not counted separately. Consequently, Table 2A, which presents City Code parking requirements, does not include a separate line item for the ballroom or spa. As a Pacific City EIR 3-181 Chapter 3 Responses to Comments conservative measure, however, parking demand from these uses was included in the shared parking analysis, so that the total hotel parking demand exceeds City requirements. Columns 3 and 4 in Tables 5A and 5B identify parking demand from these uses. As a validation for the total recommended parking demand in the shared parking analysis, the aggregate parking rate for full buildout of the retail portion (retail/commercial and restaurant uses) and hotel portion (including the signature restaurant, meeting space and spa service) was calculated and compared to industry standards. That is, at the 1:00 PM peak parking period, the number of spaces required based on the parking profile (i.e., the percentage of spaces occupied at a given time) was computed for all the uses associated with the retail portion of the project and all the uses associated with the hotel portion of the project. This data was then compared to industry standard parking requirements for each of these uses. For the retail portion of the project, the aggregate parking rate required for the 1:00 PM peak parking period is 4.56 spaces per 1,000 SF of gross leasable area (GLA). This requirement exceeds the rate of 4.35 spaces per 1,000 SF of GLA recommended for shopping centers less than 400,000 SF of GLA in size based on information provided in Chapter 2 of the Parking Requirements for Shopping Centers: Summary Recommendations and Research Study Report, 2nd Edition, Published by the ULI. For the hotel portion of the project (including the signature restaurant, meeting space and spa service), the aggregate parking rate for the 1:00 PM weekday peak parking period is 1.13 spaces per room, which is consistent with the design ratio for hotels of 1.1 spaces per room, and for the hotel weekday peak parking period, the aggregate parking rate is 1.35 spaces per room. As a result, consistent with the traffic generation forecast, the resultant peak parking demand is consistent with industry standards relative to the specific land use characteristics proposed within the Pacific City development. 3-182 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter DOC (Department of Conservation, State of California, December 1, 2003) DOC-1 Comment noted. Please refer to responses to specific concerns identified below. DOC-2 Figure 3.7-1 on page 3.7-8 of the Draft EIR illustrates the location of oil wells located within the project site. The City will consider inclusion of the location of oil wells on future maps. DOC-3 MM HAZ-7 on page 3.7-21 of the Draft EIR requires consultation with DOGGR when construction is proposed over abandoned oil wells to determine if the plugging or re- plugging of the wells is necessary. MM HAZ-8 on page 3.7-22 of the Draft EIR requires the re-plugging of abandoned oil wells to current DOC specifications if they are damaged during construction. The developer would ensure proper implementation of the reabandonment operation in compliance with all applicable laws and regulations. DOC-4 MM HAZ-7 on page 3.7-21 of the Draft EIR also requires the Applicant to submit evidence of consultation with DOGGR indicating wells have been plugged or abandoned to current DOGGR standards prior to issuance of grading permits. DOC-5 Page 3.7-16 of the Draft EIR identifies that the project would be required to adhere to City Specification 429, which specifies requirements for permits for construction within methane districts (i.e., in the vicinity of abandoned oil wells), including the provision of methane barriers and a gas collection system for structures. This requirement appears as CR HAZ-B on page 3.7-20 of the Draft EIR. Compliance with this specification would mitigate the potential presence of methane gas on the project site. DOC-6 As stated on page 2-8 of the Draft EIR, oil well reabandonment was completed from 1997 through 1999. As such, all abandoned wells are anticipated to be in conformance with DOGGR standards. As stated on page 3.7-16 of the Draft EIR, the project would be required to comply with City Specification 422, which would ensure all wells are appropriately abandoned prior to construction. This requirement appears as CR HAZ-A on page 3.7-20 of the Draft EIR. Pacific City EIR 3-183 Chapter 3 Responses to Comments Impact HAZ-2 on page 3.7-18 of the Draft EIR addresses development over previously plugged and abandoned wells. MM HAZ-7 on page 3.7-21 of the Draft EIR requires consultation with DOGGR when construction is proposed over abandoned oil wells to determine if the plugging or re-plugging of the wells is necessary. DOC-7 Comment noted. 3-184 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter DOT (California Department of Transportation, December 3, 2003) DOT-1 Comment noted. DOT-2 As identified on page 2-21 of the Draft EIR, "PCH will include completion of a third travel lane and an on-street bike lane along the project frontage. These improvements would be implemented by the proposed project ..." In Year 2008, the lane geometry is existing plus a third northbound through lane. In Year 2020, the lane geometry is existing plus a third northbound and southbound through lane, consistent with County of Orange Master Plan of Arterial Highways. It is acknowledged that the improvements in the Caltrans Route Concept Report are not funded or programmed. However, since the third southbound lane on PCH is identified in both the Route Concept Report and the MPAH, it is reasonably foreseeable to consider that this improvement would be implemented by 2020 (17 years from when the traffic analysis was completed). DOT-3 The Surf Museum is currently located at 411 Olive Avenue, three blocks west of the project site, and may be relocated to the project site. The Surf Museum is expected to generate nominal destination traffic. Museums typically generate very little weekday peak hour and daily traffic. In addition, if the museum is not constructed, the square- footage of this use would be eliminated from the project. Therefore, it is not appropriate to assume the museum area as a restaurant or retail use. DOT-4 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of mode shift and internal trip capture. The project does not use the TIS internal capture rates, although all other TIS Guidelines are used in the traffic analysis. The internal capture rates are generally based on Tables 7.1 and 7.2 in the ITE Trip Generation Handbook (October 1998) and have been adjusted based on the project characteristics and the professional judgment of the project traffic engineer in consultation with the City based on experience in the area. In addition, the project internal capture rates are actually less than the ITE internal capture calculation worksheet methodology rates. The mode shift percentages conform to ITE recommendations and reflect traffic engineer and City experience of traffic in the area based on the unique combination of the proposed project's mixed-use land characteristics and proximity to the beach, as experienced in Main Street/Downtown Pacific City EIR 3-185 Chapter 3 Responses to Comments and adjacent hotel land uses. Clearly, guidelines do not address all conditions; the use of engineering judgment is appropriate for the proposed project analysis. DOT-5 Although not provided in the Appendices to the Draft EIR, the Trip Reduction Flow Diagram, or Appendix C of the Traffic Analysis Impact Report for the proposed project, was available for review at the City as well as the City of Huntington Beach Central and Main libraries. However, as requested by the commenter, a copy of Appendix C was faxed to Caltrans on December 15, 2003. DOT-6 Residential traffic would be distributed onto the surrounding street network. The discussion on page 3.14-30 of the Draft EIR identifies the portion of project traffic that would occur on Beach Boulevard, PCH, Atlanta Avenue, and Main Street. A portion of the traffic distributed onto Atlanta Avenue would also use Beach Boulevard, resulting in an overlap of the project distribution percentages. Consequently, the traffic percentages identified in this discussion add to over 100 percent. DOT-7 The information presented on page 3.14-51 of the Draft EIR provides the future LOS without the proposed project, and the information of page 3.14-55 of the Draft EIR provides the LOS with the project. As shown on these pages, where the LOS exceeds significance criteria, it is due primarily to regional and background traffic. The proposed project would not result in additional traffic that would exceed significance criteria, and, consequently, no mitigation is necessary. With respect to the differences between LOS at intersections compared to roadway links, many of the study locations along PCH have additional lanes at the intersection compared to the roadway link, such as left turn lanes and right turn lanes, which provide for additional capacity and, therefore, improved LOS. In addition, analysis is presented for both ICU (City methodology) and HCM (Caltrans methodology). ADT segment analysis is a general analysis tool that is based on several assumptions that derive an ADT capacity from a peak hour lane capacity. For basic transportation planning, this can be an effective though elementary tool. The traffic engineering profession has long acknowledged that peak hour analysis is a better indicator of system performance and that intersections almost always represent the most restrictive element of the system. Therefore, the analysis focuses on the peak hour intersection analysis as a predictor of system performance. 3-186 City of Huntington Beach Chapter 3 Responses to Comments DOT-8 Comment noted. The City of Huntington Beach has determined that ADT level of service is appropriate for use in roadway segment level of service calculations, consistent with the policies contained in the City's General Plan Circulation Element rather than the peak hour period for roadway segments. Peak hour trips are used for the intersection analysis, which is typically the controlling element of the circulation system and results in the roadway improvements identified for the proposed project. Please refer to Response to Comment DOT-7 on page 3-186 for additional detail. DOT-9 Figure 2-7 has been revised in the Final EIR to identify that crosswalks currently exist at the intersection of Huntington Street and PCH, and crosswalks that exist at the intersection of First Street and PCH, with the exception of the southern leg of this intersection, which is proposed as part of the project. Pedestrian access to the proposed project across PCH would be provided from these existing and proposed crosswalks. At these intersections, the maximum anticipated traffic signal cycle length would be 120 seconds, allowing 30 cycles each hour for pedestrians to cross PCH. Approximately 20 pedestrians can comfortably cross PCH within each crosswalk per cycle. Consequently, a total of 600 pedestrians could be accommodated within each crosswalk per hour, resulting in a total pedestrian capacity of 1,200 pedestrians per hour across PCH within crosswalks at both PCH/First Street and PCH/Huntington Street. The Pacific City project would generate a maximum of approximately 500 pedestrians crossing within both crosswalks during the PM peak hour, due to the mode shift anticipated as a result of this project. This information is calculated through use of the data presented in Table 3.14-10 in the Draft EIR, which shows traffic generation for the proposed project. Tallying the mode shift vehicles during the PM peak hour, shown in the far right column, yields a total of 331 vehicles associated with the mode shift. Assuming 2 persons per vehicle, 662 pedestrians would be associated with the mode shift. The analysis conservatively assumes that 75 percent of these pedestrians parked at the beach and visited the project, which yields the conclusion of approximately 500 pedestrians (0.75 x 662)using the crosswalks during the PM peak hour. This pedestrian volume is below the maximum capacity of 1,200 pedestrians that could be accommodated in one hour at existing and proposed crosswalks. In addition, the level of service calculation for traffic at each intersection assumed adequate pedestrian crossing time for each cycle. Pacific City EIR 3-187 Chapter 3 Responses to Comments DOT-10 As noted on page 2-26 of the Draft EIR, the pedestrian bridge over PCH is proposed as part of the Pacific City Commercial Master Plan, but is not proposed to be constructed at this time. However, this element is analyzed in the Draft EIR, since it could be built in the future as part of the project. The Department's comment regarding pedestrian impacts to PCH is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. DOT-11 As required by the City and requested by the commenter, if proposed to be constructed in the future, construction of the pedestrian bridge would require additional review by the City and Caltrans. DOT-12 Please see Response to Comment DOT-9 on page 3-187 for estimated pedestrian volumes. DOT-13 Please refer to Response to Comment DOT-9 on page 3-187 for a discussion of pedestrian circulation. If in the future, a pedestrian bridge were to be constructed, additional pedestrian traffic could be accommodated that would positively impact the level of service at crosswalks and intersections by reducing the number of pedestrians at grade. DOT-14 As shown on Figure 2-7 on page 2-25 of the Draft EIR, a crosswalk is proposed on PCH at First Street at the south leg. This figure has been revised in the Final EIR to identify existing crosswalks at all other portions of this intersection. The existing traffic signal would be modified in conjunction with the widening of lst Street along the project frontage and the crosswalk improvements. DOT-15 No changes to state drainage facilities are proposed. DOT-16 Section 2.6.2 on page 2-31 of the Draft EIR identifies the need for encroachment permits, consistent with this comment. DOT-17 As discussed under Impact HYD-lon pages 3.8-17 through 3.8-19 of the Draft EIR, the project includes measures to minimize water quality impacts during construction and operation. The project would comply with applicable requirements of the Statewide General Construction Activity Stormwater Permit, including SWPPP preparation. Because a SWPPP would be prepared, the project would conform to the Water 3-188 City of Huntington Beach Chapter 3 Responses to Comments Pollution Control Provisions identified by Caltrans. The project would implement BMPs as appropriate, including containment of all vehicle loads and avoidance of tracking of materials, which may fall or blow into Caltrans roadways of facilities. Runoff water quality from project operation would be addressed through a Water Quality Management Plan, which would serve as the manual to maintain water quality in conformance with the NPDES Permit and the County of Orange DAMP. Conformance with these water quality standards would, in turn, meet the current discharge requirements of the Santa Ana Regional Water Quality Control Board. DOT-18 Comment noted. Pacific City EIR 3-189 Chapter 3 Responses to Comments Response to Comment Letter DISC (Department of Toxic Substances Control, November 4, 2003) DTSC-1 Comment noted. Please refer to responses to specific concerns identified below. DTSC-2 Table 3.7-1 on page 3.7-2 of the Draft EIR provides the past uses of the project site based on site reconnaissance and review of files, aerial photographs, and previous - environmental documentation. Pages 3.7-6 through 3.7-12 of the Draft EIR identified hazardous substances identified on site that have resulted from historic uses, which - includes residual total petroleum hydrocarbons, lead, asbestos, and VOCs (2-butanone, acetone, and styrene). The extent of contamination and remediation strategies for these hazardous substances is also addressed throughout this section, including the need to delineate the nature and extent of contamination in some areas. DTSC-3 Figure 3.7-1 on page 3.7-8 of the Draft EIR illustrates the project site and classifies areas on the site as one of the following: (a) remediation complete; (b) remediation underway; (c) remediation to be completed during project construction; or (d) further investigation necessary. Impact HAZ-1 on page 3.7-15 of the Draft EIR addresses potential threats to human health or the environment in these areas. DTSC-4 MM HAZ-1 and MM HAZ-2 on page 3.7-20 of the Draft EIR require that site inspection and soil sampling be performed to identify the extent of contamination and potential remediation that may be required prior to the issuance of grading permits. MM HAZ-3 on page 3.7-20 of the Draft EIR requires the Applicant to consult with the - City and other agencies to formulate a remediation plan for further soil contamination that exists on the site prior to the issuance of a grading permit. As identified on - page 3.7-6 of the Draft EIR, the City Fire Department is the local oversight agency for this project. -- DTSC-5 Please refer to Response to Comment DTSC-2 above for a discussion of hazardous substances identified on the project site. DTSC-6 Please refer to Response to Comment DTSC-2 above for a discussion of hazardous substances identified on the project site. The site is currently fenced and is not - accessible to the public. As such, no immediate threat from the site exists in its current condition. All remediation would be completed in conformance with applicable 3-190 City of Huntington Beach Chapter 3 Responses to Comments polices. In addition, the Site Closure Report that will be prepared after completion of remediation at the project site must be reviewed and approved by the City of Huntington Beach Fire Department, which is the local oversight agency for cleanup of the site. DTSC-7 The City of Huntington Beach Fire Department (HBFD) is the regulatory agency with local oversight for cleanup of the project site, as stated on page 3.7-6 of the Draft EIR. The primary contaminant of concern on-site is petroleum hydrocarbons. The HBFD is required to review and approve the Site Closure Report prepared following completion of remediation. If other agency oversight is required, it will be initiated by the City. DTSC-8 As discussed on pages 3.7-3 through 3.7-5 of the Draft EIR, a search of federal, State, and local regulatory databases was completed to determine if any known contaminated sites were located on the property, or within one mile of the site. Since a border zone property refers to any contaminated property within 2,000 feet of the project site, this one-mile radius search revealed all known contaminated sites within this potential border zone. Since no known contaminated sites exist within 2,000 feet of the project site (according to the EDR radius map search performed for the Pacific City property and included in Appendix E of the Draft EIR), the proposed project is not considered within the border zone of a contaminated property. However, in the event that previously unknown soil contamination that could present a threat to human health or the environment is encountered during construction, construction activities in the immediate vicinity of the contamination would cease immediately, and a risk management plan would be prepared, according to MM HAZ-5 on page 3.7-21 of the Draft EIR. DTSC-9 As discussed on page 3.7-6 of the Draft EIR, the HBFD is the local oversight agency for the project and will determine the appropriate remedial action that would be necessary prior to project construction. Remedial action is required when impacts to soil, groundwater, or other materials have been identified above acceptable local, State, or federal contaminant levels or preliminary remedial goals. In addition, as described in MM HAZ-3 and HAZ-4 on pages 3.7-20 through 3.7-21 of the Draft EIR, all remedial plans for the project site would be reviewed and approved by HBFD in accordance with City Specification No. 431-92. Pacific City EIR 3-191 Chapter 3 Responses to Comments DTSC-10 The text on page 3.7-10 of the Draft EIR has been revised to accurately reflect the soil contamination standards of the City Specification 431-92 rather than the Title 22 action standards, which addresses drinking water quality. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. The response below reflects the revised language of this section. As stated on page 3.7-10 of the Draft EIR, "...All soil samples collected from the excavation, following the removal of the impacted soil, contained soluble lead at concentrations below 5 parts per million (ppm) in accordance with the City of Huntington Beach Soil Clean-Up Standard Specification 431-92 (City Specification 431- 92)." According to City Specification 431-92, the action level for lead in soils (i.e., the level that would trigger remediation) is when the total threshold limit concentration (TTLC) is greater than ten times the maximum concentration soluble threshold limit concentration (STLC); 50 ppm for TTLC or 5 ppm for STLC. While these measurements are used as a general hazardous waste classification, they are, nonetheless, the clean-up standards used for the project site as specified in City Specification 431-92. As discussed on page 3.7-15 of the Draft EIR, "The City of Huntington Beach Specification 431-92, Soil Clean-Up Standard (City Specification 431-92), dated July 30, 1992 governs investigation and remedial efforts of contaminated soils. Soil cleanup standards for TRPH-impacted soils are set at less than 500 mg/kg and 1,000 mg/kg for residential and commercial sites, respectively. However, at sites where the acceptable thresholds for the EPA Test Methods 8015M, 8020 and 8270 are met, as expected at the project site, the soil cleanup standard is less than 1,000 mg/kg for residential sites and 2,000 mg/kg for commercial sites" (emphasis added). Thus, as required by MM HAZ-3 on page 3.7-20 of the Draft EIR, the Applicant shall, in consultation with the City of Huntington Beach and other agencies, as required, formulate a remediation plan for review and approval in accordance with City Specification No. 431-92. DTSC-11 MM HAZ-1 on page 3.7-20 of the Draft EIR requires a site inspection to identify the potential for PCB contamination on the site prior to the issuance of a grading permit. If the potential for PCB contamination exists, then the Applicant must consult with the City, sample the soil to identify the extent of contamination, and implement an appropriate remediation plan. -- 3-192 City of Huntington Beach Chapter 3 Responses to Comments DTSC-12 MM HAZ-5 on page 3.70-21 of the Draft EIR mitigates the potential for previously unknown soil contamination during construction by requiring the immediate cessation of construction activities and the preparation and implementation of a risk management plan if contamination is in fact encountered. Please refer to Response to Comment DTSC-4 on page 3-190 for information on how investigation and remediation would be conducted. DTSC-13 Comment noted. Pacific City EIR 3-193 Chapter 3 Responses to Comments Response to Comment Letter CNB (Steven Bromberg, Mayor of the City of Newport Beach, December 3, 2003) CNB-1 Comment noted. CNB-2 The condition in which future localized carbon monoxide (CO) concentrations would be lower than existing levels is due to anticipated improvements in vehicle emission rates projected for the future by the California Air Resources Board (ARB). These projections have two effects. First, the emission factors model published by the ARB and programmed into the simplified CALINE4 screening model that was used to predict localized CO concentrations in the Draft EIR identify reduced emissions per vehicle on an annual basis. Second, cleaner vehicles will reduce the ambient CO concentrations throughout the South Coast Air Basin and Source Receptor Area (SRA) 18 in which the City of Huntington Beach is located. The South Coast Air Quality Management District (SCAQMD) predicts that 1-hour ambient concentration of CO in SRA 18 will be reduced from 8.0 parts per million (ppm) in 2003 to 5.8 ppm in 2010. The 8-hour ambient concentration of CO in SRA 18 will slightly increase from 4.6 ppm in 2002 to 4.7 ppm in 2010. These conditions are reflected in the analysis presented in the Air Quality section of the Draft EIR. CNB-3 As discussed on page 3.2-19 of the Draft EIR, the Growth Management Chapter of the Regional Comprehensive Plan and Guide (RCPG) forms the basis of the land use and transportation control portions of the 1997 Air Quality Management Plan (AQMP). Therefore, the analysis of the proposed project's consistency with the AQMP is based on the population and employment projections from the Growth Management Chapter of the RCPG. Although updated numbers for Orange County may be available, they are not applicable to this analysis. CNB-4 This comment is acknowledged, and the opinion of the commenter will be provided to g the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. CNB-5 Comment noted. Please refer to responses to specific concerns identified below. CNB-6 CR AQ-E on page 3.2-20 of the Draft EIR is a standard City requirement and thus, the type of wind barrier used for the project would be in accordance with City guidelines. 3-194 City of Huntington Beach Chapter 3 Responses to Comments CNB-7 Remedial operations refer to soil remediation that may occur concurrently with project construction. The intent of the requirement is that the remediation work area be contained as much as possible and be staged such that fugitive dust associated with the remediation is minimized. It does not mean, as stated in the comment that remediation would reduce fugitive dust. Rather, when soil remediation is contained in single areas, better protective measures can be taken to control dust. CNB-8 The Mitigation Monitoring and Reporting Program provides methods to ensure implementation of mitigation measures. The City would review and approve grading and building plans as appropriate for inclusion of the mitigation requirements at plan check, prior to issuance of permits. In addition, project conditions of approval would require a full-time monitor during construction activities in order to ensure that all mitigation and City conditions are appropriately implemented. Implementation would also be ensured by periodic, direct inspection by City staff. CNB-9 Please refer to Response to Comment CNB-8 above for a discussion of the implementation of mitigation measures. CNB-10 Because electrical supplies are readily available in the vicinity of the proposed project site, building contractors are expected to rely mostly on electricity from power poles during the construction phases of development. There may be some instances in which portable generators may need to be used for individual or short-term operations where wired electricity is not available. The City of Huntington Beach would not preclude the use of such equipment. CNB-11 As part of the mitigation monitoring effort for the proposed project, project developers would be required to provide manufacturer's information indicating that developer- installed appliances are considered to be energy efficient. An example of energy efficient appliances are those identified with the "energy star" label. These types of appliances meet the intent of the recommended mitigation measure. CNB-12 Use of porous pavement and swales is not required, as the project would have a less- than-significant impact on runoff and groundwater recharge. The project would predominantly include subterranean parking; therefore, porous pavement is not feasible. This comment is acknowledged, and the opinion of the commenter will be Pacific City EIR 3-195 Chapter 3 Responses to Comments provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. CNB-13 Based on the City of Huntington Beach 1 percent maximum ICU increase study area criteria, the intersection of PCH at Superior/Balboa in the City of Newport Beach, has a maximum possible ICU percent impact greater than 1 percent (2.1 percent in the PM peak hour). The intersection of PCH at Hoag Drive/Balboa Cove in the City of Newport Beach has a maximum possible ICU percent impact less than 1 percent (0.8 - percent in the AM and PM peak hour). Therefore the intersection of PCH at Superior/Balboa defines the limit of the study area. An analysis of this intersection has been included in the Final EIR. This intersection is analyzed according to the City of Newport Beach methodology on a near-term Year 2008 and General Plan Buildout basis as well as according to the Caltrans methodology. Impacts at this intersection would be less than significant, and this analysis does not constitute "significant new information," as discussed in CEQA Guidelines Section 15088.5. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. CNB-14 As described on page 72 of Appendix H of the Draft EIR, model runs were completed g P p with and without these two roadway improvements. The Year 2020 scenario reflects implementation of roadway improvements identified in the General Plan, including the bridge improvements, in the analysis. The analysis conforms to the adopted long-range plans for the transportation network in the City. The City of Huntington Beach does not require that elimination of the Banning/19th Street Bridge be analyzed because the bridge is currently contained in the City of Huntington Beach General Plan and Master Plan of Arterial Highways (MPAH), and the City has not taken a formal position to evaluate all projects with and without the crossing. Nevertheless, traffic volumes would not substantially change in the absence of the Banning/19th Street Bridge improvement. Further, impacts from removal of the bridge improvements are required to be analyzed in environmental documentation by OCTA, as the lead agency for that effort. CNB-15 Based on the Orange County Congestion Management Program (CMP) study area "Radius of Development Influence" section of the CMP Traffic Impact Analysis (TIA), the study area is recommended to be defined by the CMP links which have a project impact of 3 percent or more of their daily LOS"E"capacity. On Pacific Coast Highway, the intersections between Goldenwest Street and Beach Boulevard in the City of Huntington Beach, which have been analyzed in the Traffic Impact Analysis Report 3-196 City of Huntington Beach Chapter 3 Responses to Comments (Appendix H to the Draft EIR) for the proposed project, satisfy the CMP study area criteria. In response to this comment, the intersection of PCH at Superior/Balboa has also been analyzed for CMP impacts, as discussed below. The project's impact on the PCH roadway link south/east of Superior/Balboa falls below the 1,689 vehicles per day (3 percent) threshold, and, as such, does not require CMP analysis. The intersection of PCH at Superior/Balboa has been analyzed consistent with Orange County CMP TIA criteria using 2003 existing peak hour traffic volumes provided by the City of Newport Beach Engineering Staff. Please refer to Chapter 2, Volume III of the Final,EIR for the full data and analysis of this intersection. The analysis concludes that the intersection of PCH at Superior/Balboa is anticipated to operate at acceptable LOS C during the AM and PM peak hours in Year 2008 with the addition of proposed project traffic. Therefore, based on CMP impact criteria, the intersection of PCH at Superior/Balboa would not be significantly impacted by the proposed project traffic. This analysis does not constitute "significant new information", as discussed in CEQA Guidelines Section 15088.5. CNB-16 Comment noted. Pacific City EIR 3-197 Chapter 3 Responses to Comments Response to Comment Letter HBUHSD (Huntington Beach Union High School District, October 27, 2003) HBUHSD-1 The text on page 3.12-3 of the Draft EIR has been revised to clarify which areas are served by the four HBUHSD high schools. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. 3-198 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter OCPD (County of Orange Planning & Development Services Department, December 3, 2003) OCPD-1 Comment noted. OCPD-2 Impact HYD-1 on page 3.8-17 of the Draft EIR provides a comprehensive discussion and analysis of the potential impacts of the proposed project on water quality. The proposed project is recognized as a priority project pursuant to the Model Water Quality Management Plan. As noted on page 3.8-19 of the Draft EIR, a Preliminary Water Quality Management Plan (PWQMP) has been developed for the project and outlines the comprehensive approach that would be used in the attainment of water quality goals required for the proposed project. The PWQMP is included as Appendix G to the Draft EIR. The plan conforms to the NPDES Permit and the 2003 DAMP, and supports the City's commitment to the protection and enhancement of coastal water quality. The plan also complements the goals and mission statement of the City of Huntington Beach Citywide Water Quality Management Plan Task Force. The PWQMP would serve as the foundation for the final WQMP and explains the methodology used to determine the types of management practices that are best suited for the proposed project in order to achieve the required water quality levels as detailed by the DAMP and local requirements. Filtration and screening of pollutant loads, including specialized filtration inserts for additional treatment of petroleum hydrocarbons, if necessary, would be included as part of the proposed project. All feasible recommended BMPs as incorporated into the 2003 DAMP Section 7 are included as an integral part of the proposed project. With implementation of these BMPs and the WQMP, all impacts related to water quality would be reduced to the maximum extent practicable, as required by the 2003 DAMP and City regulations. OCPD-3 Please refer to Response to Comment OCPD-2 above. The proposed project has been identified as a priority project under the 2003 DAMP and potential stormwater and pollutant runoff impacts will be carefully considered as required. OCPD-4 Section 3.8.1 (Existing Conditions, Regional Hydrology) on page 3.8-1 of the Draft EIR identifies the two main tributaries that drain into the Talbert Watershed: on the western side, the Talbert and Huntington Beach Channels drain through the Talbert Marsh before emptying into the Pacific Ocean. On the eastern side, the Greenville- Pacific City EIR 3-199 Chapter 3 Responses to Comments Banning Channel empties into the Santa Ana River. Downtown area site drainage has been identified in the Draft EIR as conveying runoff across Pacific Coast Highway to the Pacific Ocean, where the runoff discharges at South Beach via an open ditch. Discharge from the project site is conveyed to the existing 42-inch reinforced concrete pipe in Pacific View Avenue, through the Atlanta Stormwater Pumping Station (ASWPS), and eventually to the Huntington Beach Channel. All receiving waters that may receive runoff from the project site have thus been identified in the Draft EIR. OCPD-5 TMDLs for receiving waters were not calculated as part of the hydrology study performed for the proposed project. With the inclusion of state-of-the-art filtration devices and other screening for pollutant loads, as noted in the discussion under Impact HYD-1 on pages 3.8-17 through 3.8-19 of the Draft EIR, impacts of the proposed project with regard to increased pollutant concentrations are reduced to a less-than- significant level. Please refer to the Topical Response on Water Quality on page 3-173 for discussion of bacteria with respect to water quality. It is recognized that Huntington Beach State Park is listed on the 2002-303(d) list as impaired for Enterococci, with an impacted area of approximately 5.8 miles. Additionally, the proposed project must meet all requirements related to water quality discharges. Therefore, no further analysis is necessary. OCPD-6 The discussion under Impact HYD-2, on pages 3.8-20 through 3.8-23 of the Draft EIR, considers impacts of the proposed project on changes in drainage patterns and determined that discharge volumes from Area A would be reduced compared to existing conditions. The reduction in stormwater flows directed to the ASWPS from the reconfiguration of the drainage areas on site would result in a reduction in 100-year storm flow from 67.0 cfs to 21.8 cfs to the ASWPS. First-flush discharges and projected drainage conditions are summarized in Tables 3.8-6 on page 3.8-20 and Table 3.8-7 on page 3.8-21, respectively, of the Draft EIR. The discussion under Impact HYD-2 further notes that an on-site underground detention basin is proposed to accomplish a reduction in flow discharges from Area B. Stormwater flows exceeding attenuation limits would be allowed to run off via surface streets, and the drainage study has indicated that the volume of this runoff would not impact drainage systems or flood traffic lanes. As identified on page 3.8-1, a discussion of groundwater recharge was scoped out from detailed analysis in the Draft EIR, as the City's groundwater wells are located a 3-200 City of Huntington Beach Chapter 3 Responses to Comments minimum of two miles inland from the project site and the City does not rely on groundwater that close to,the ocean due to saltwater intrusion. For a discussion of proposed filtration devices included in the project, see Response to Comment OCPD-2 on page 3-199. OCPD-7 Please refer to Response to Comment OCPD-2 on page 3-199 for a discussion of the WQMP for the proposed project. The WQMP for the proposed project would include implementation of all post construction BMPs in accordance with Section 7 of the 2003 DAMP. As noted above, the project has been identified as a priority project under the Model WQMP of the DAMP. OCPD-8 The project would comply with the State General Construction Permit. CR HYD-A, on page 3.8-26 in the Draft EIR, would require the project to incorporate all necessary BMPs to eliminate polluted runoff during construction. The specific notes identified in the comment would be incorporated on the plans per the applicable 2003 DAMP requirements. OCPD-9 It is recognized that Huntington Beach State Park is listed on the 2002-303(d) list as impaired for Enterococci, with an impacted area of approximately 5.8 miles. Please refer to the Topical Response on Water Quality on page 3-173 for a discussion of treatment of dry-weather flows. The project WQMP would be required to incorporate site design, source control, and treatment control per the City's Water Quality Ordinance and applicable 2003 DAMP requirements. OCPD-10 Page 3.8-9 to 3.8-12 of the Draft EIR identifies the requirement for submittal of an NOI package and preparation of an SWPPP. Text has been amended, as shown in - Chapter 2, Volume III of the Final EIR, to reflect that the proposed project is greater than 1 acre in size and is subject to the requirements of the Construction General Permit 99-08-DWQ. OCPD-11 Please refer to Response to Comment OCPD-2 on page 3-199. In addition, text has been modified, as shown in Chapter 2, Volume III of the Final EIR, to incorporate specific language from the DAMP with respect to implementation of pre and post structural BMPs. Pacific City EIR 3-201 Chapter 3 Responses to Comments OCPD-12 MM CR-1 and MM CR-2 on pages 3.4-18 to 3.4-20 of the Draft EIR already reflect the intent and relevant practices described in the Orange County Archaeological/Paleontological Curation Project Final Report ("Curation Project"), and exceed the recommendations of the Curation Project with respect to Native American consultation and involvement in monitoring and resource recovery. Further, as described on,pages 3.4-1 to 3.4-11 of the Draft EIR, extensive pre-construction evaluation and investigation of the site have already occurred: the extent, nature, and significance of the archaeological deposits on the project site are, therefore, well understood, and treatment measures specific to the resources on the site have been developed. Consequently, the pre-construction mitigation measures described in Chapter 3 of the Curation Project have generally been satisfied for paleontological and archaeological resources, and the reports are on file at the City of Huntington Beach Planning Department. However, MM CR-1 and MM CR-2 on pages 3.4-18 to 3.4-20 of the Draft EIR have been revised to provide some clarification and greater consistency with the language of the Curation Project. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. OCPD-13 MM CR-1 on pages 3.4-18 through 3.4-19 of the Draft EIR has been modified to identify that resources shall be retained within the County, at a facility acceptable to the City. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. Additionally, because analysis of any recovered paleontological materials must occur, the fossils must be prepared to the point of identification prior to curation, consistent with accepted professional practice. OCPD-14 The project applicant would be required to recover resources associated with CA- ORA-149 and monitor construction for discovery of archaeological and paleontological resources. The applicant would be required to ensure that resources are curated at an appropriate facility, and would be responsible for applicable curation fees. Once curated, the applicant would not retain ownership or responsibility for the materials. Therefore, the costs due to long-term curation and maintenance of donated collections would not be the responsibility of the project applicant. OCPD-15 Comment noted. 3-202 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter OCTA (Orange County Transportation Authority, December 3, 2003) OCTA-1 Comment noted. Please refer to responses to specific concerns identified below. OCTA-2 As described on page 3.14-37 of the Draft EIR, Pacific View Avenue would be dedicated to a width of 90 feet and the ultimate configuration for this roadway would include a four lane divided cross section within the 90-foot right-of-way. In addition, although the near-term on-street parking spaces on this roadway would be temporary, it is anticipated that some on-street parallel parking would be retained with reconfiguration. These parking spaces were not included in the calculations used to determine if the project provides adequate (i.e., replacement of existing parking spaces that would be removed) on-street parking. OCTA-3 OCTA currently has a bus stop at northbound PCH/farside Huntington St. and eastbound Atlanta Ave/farside 1st. As discussed on page 3.14-76 of the Draft EIR, the project proposes an OCTA bus turnout on the north side of PCH, west of Huntington Street; this bus stop would be a farside turnout stop. In addition, the farside stop at Atlanta can be retained; however, a requirement for a turnout at this stop has not been included as part of the proposed development and is not anticipated to result in any environmental constraints. OCTA-4 As discussed on page 3.14-76 of the Draft EIR, the project proposes an OCTA bus turnout on the north side of PCH, west of Huntington Street. In addition, as discussed on page 3.14-77 of the Draft EIR, the Goldenwest College/Huntington Center Area is developed with a transportation center along Gothard Street and provides bus layovers and transfers for the OCTA as well as other transportation center facilities. The PCH and First Street area also has a 560-foot bus turnout along the south side of PCH between First Street and Huntington Street that provides bus layovers and boarding for OCTA. Project implementation is anticipated to be consistent with local policies related to transportation, including the SCAG Regional Comprehensive Plan and Guide and the City's General Plan Land Use and Transportation Elements. OCTA-5 Comment noted. Pacific City EIR 3-203 Chapter 3 Responses to Comments A Response to Comment Letter SC G (Southern California Association of Governments, November 25, 2003) SCAG-1 Comment noted. SCAG-2 Comment noted. SCAG-3 Comment noted. SCAG-4 This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. 3-204 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter HBEB (City of Huntington Beach Environmental Board, November 24, 2003) HBEB-1 Comment noted. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. HBEB-2 The commenter correctly restates the significant, unavoidable impacts to Air Quality and Transportation identified in the Draft EIR. No further response is required. HBEB-3 Comment noted.edresponses to specific Please refer to concerns identified below. HBEB-4 Comment noted. As identified in this comment, the Draft EIR states that groundwater beneath the site has no beneficial use. HBEB-5 As required by the Downtown Specific Plan (DTSP) and as discussed on page 2-23 of the Draft EIR, development in Districts 7 and 8A requires the dedication of a 20-foot- wide public access corridor to facilitate pedestrian movement to the Downtown area; thus, the corridor shall remain an integral part of the proposed project. As stated on pages 2-25 and 2-26 of the Draft EIR, this public access corridor commences on Atlanta Avenue and aligns with Alabama Street (oriented perpendicular to Atlanta Avenue) to facilitate pedestrian movement to the Downtown area, where public access is provided via the loop road through District No. 8A to Pacific View Avenue, extending through Pacific City District No. 7 to PCH. In addition, as discussed on page 2-14 of the Draft EIR, a sign program, which would meet the objectives of the DTSP and Design Guidelines, would be planned and implemented at a later date through adoption of a Pacific City Sign Program, which would be subject to review and approval by the City Design Review Board. Therefore, review and approval of the sign program would ensure that the public access corridor is adequately marked as such. HBEB-6 Project conditions of approval would include requirements for the homeowners association to periodically clean filter systems in order to ensure their proper maintenance. Logs would be submitted to the City in order to demonstrate ongoing maintenance. These conditions would ensure that filers would properly function throughout the life of the project. In addition, the Water Quality Management Plan (WQMP) required for the project would include a detailed long-term operation and Pacific City EIR 3-205 Chapter 3 Responses to Comments maintenance plan for all structural BMPs. The City would require, at a minimum, an inspection and cleaning (if required) of all structural BMPs to be conducted annually in the late summer/early fall (prior to the rainy season). HBEB-7 Please refer to Response to Comment DOT-9 on page 3-187 for an analysis of the pedestrian crossings. The project would have two pedestrian connections to the beach area at 1st Street and Huntington Street via the existing traffic signal, which would adequately accommodate pedestrian traffic from the project site. Therefore, the pedestrian bridge is not required to address project impacts; rather, it is a potential amenity that could be constructed in the future. HBEB-8 At the time that the pedestrian bridge is proposed for entitlement and construction, the access in conformance with ADA accessibility requirements would be included as part of the design. HBEB-9 The City's Municipal Code Section 17.64.130(c) states, "Poles, overhead wires and associated overhead structures used for the transmission of electric energy at nominal voltages in excess of 34,500 volts." Therefore, the 66-kV electrical line along Atlanta Avenue is exempt from Code requirements for undergrounding. HBEB-10 As stated in Impact AES-6 on pages 3.1-39 through 3.1-45 of the Draft EIR, headlight impacts on surrounding uses from vehicles exiting and turning from the proposed garage egresses would be less than significant. Existing fencing and vegetation would shield headlights from shining into adjacent property. Roadway imperfections and gutters would cause headlight spread to vary by several inches only and would not _- change the conclusions of the analysis. In addition, landscaping as well as a fence currently exists along the eastern edge of Huntington Street, between the existing mobile homes and the proposed egress points for Garages B and C. Also, a landscaped median is proposed for First Street, between the existing residential uses and the proposed egress point for Garage A. Residences adjacent to the project site would, therefore, be adequately screened from headlights, and no further mitigation is required. HBEB-11 The timing of intersection improvements at the intersection of PCH and Warner Avenue has not been determined. Please refer to Response to Comment HBT-6 on page 3-210 for additional information on the timing of traffic improvements. 3-206 City of Huntington Beach Chapter 3 Responses to Comments The proposed project is not responsible for the widening of Atlanta Avenue east of Huntington Street as a, result of traffic impacts. As shown in Table 3.14-14 on page 3.14-50 and Table 3.14-16 on page 3.14-56 of the Draft EIR, the roadway link of Atlanta Avenue from Huntington Street to Delaware Street would continue to operate at LOS A in both Year 2008 and Year 2020 scenarios. Therefore, no improvements to this roadway segment would be required as a result of the proposed project. HBEB-12 As discussed on page 3.14-76 of the Draft EIR, a bus turnout is proposed on the north side of PCH and a bike lane would also be provided on PCH as part of the proposed project. Additionally, the existing bus turnout along the south side of PCH could also be upgraded to accommodate additional transportation facilities. The City has been awarded a grant from OCTA to enhance this transit site. Further, the project would be required to comply with the Transportation Demand Management (TDM) Ordinance, including the provision of car pool parking spaces. HBEB-13 The Draft EIR does not state that the project would provide beneficial air quality impacts. Pages 3.2-15 through 3.2-17 of the Draft EIR simply identify the characteristics of the proposed project and surrounding environment that would help to encourage non-motor vehicle transportation by future residents, customers, and employees of the proposed project. These characteristics would help to reduce the operational emissions that would otherwise be generated by the individual proposed land uses. For example,residents of the proposed project could walk to the commercial area instead of driving. Likewise, employees of the project would have substantial opportunity to shop and eat at the site before, during, and/or after their work shifts, thereby reducing potential motor vehicle trips and associated emissions. HBEB-14 As discussed on page 3.13-13 of the Draft EIR, MM REC-1 requires the Applicant to demonstrate compliance with the City parkland requirements identified in Chapter 254.08 of the City's Municipal Code. Thus, either the dedication of parkland and/or the payment of in-lieu fees would address the impacts to open space. HBEB-15 Please refer to the Topical Response on Water Quality on page 3-173, which discusses the issue of bacterial removal from dry-weather flows. Drainage Area "A" would continue to go to the ASWPS for all dry-weather and stormwater flows. In addition, dry weather flow for Drainage Area"B" can be routed into Area"A"and to the ASWPS, Pacific City EIR 3-207 Chapter 3 Responses to Comments in order that, at the City's discretion, these flows may be routed for treatment by OCSD. HBEB-16 As discussed on pages 3.8-17 and 3.8-18 of the Draft EIR, the project site is subject to the provisions of the General Construction Activity Stormwater Permit adopted by the SWRCB. As outlined in the permit, the project would also be required to implement a SWPPP, which provides guidelines to identify impacts on and mitigation of stormwater discharges and water quality during construction. Furthermore, all construction discharges would comply with Orange County guidelines for excavation and grading, the City's Grading Manual, and the Huntington Beach Municipal Code. Compliance by the project with these requirements would reduce impacts related to construction discharge to a less-than-significant level. HBEB-17 Impact HAZ-l on pages 3.7-15 through 3.17-18 of the Draft EIR discusses effects from site contamination during construction. All contamination would be remediated prior to construction, with the exception of areas of archaeological sensitivity and the area around the existing water line. These two areas would be remediated during construction in accordance with OSHA requirements. MM HAZ-5 on page 3.7-21 of the Draft EIR includes provisional measures if hazardous materials are encountered during construction. This measure requires that a risk management plan is implemented which could include, but not limited to, physical site controls during construction, remediation, long-term monitoring, post-development maintenance or access limitations, or some combination thereof. A site health and safety plan that meets OSHA requirements would be prepared and in place prior to the commencement of work in any contaminated area. HBEB-18 CR AQ-B on page 3.2-20 of the Draft EIR is a standard City condition of approval. The City has determined that notice within 300 feet to property owners provides appropriate notification of project construction. However, in response to the concerns raised, the City will increase the notification requirement to 500 feet for this project. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. HBEB-19 These measures are part of Rule 403 established by SCAQMD. Compliance with more - stringent measures has not been deemed necessary to ensure effective dust suppression. 3-208 City of Huntington Beach Chapter 3 Responses to Comments HBEB-20 As part of the mitigation monitoring effort for the proposed project, project developers would be required to provide manufacturer's information indicating that developer- installed appliances are considered to be energy efficient. An example of energy efficient appliances are those identified with the "energy star" label. These types of appliances meet the intent of the recommended mitigation measure. HBEB-21 The MMRP provides specific mitigation monitoring requirements, including implementation documentation, monitoring activity, timing, and responsible monitoring party. Verification of compliance with each measure is required, thus ensuring implementation of mitigation measures. In order to ensure that mitigation would effectively occur, project conditions of approval would require the Applicant to retain a full-time monitor during the grading and site preparation phase of construction. In addition, it is the responsibility of City inspectors to ensure that project conditions are being implemented and followed. City inspectors would exercise due diligence and care in order to ensure that specifications on grading and building plans are implemented. Suggestions identified in this comment will be forwarded to decision makers for consideration during their deliberation of whether or not to approve the proposed project. Pacific City EIR 3-209 Chapter 3 Responses to Comments Response to Comment Letter HBT (Huntington Beach Tomorrow, December 3, 2003) HBT-1 CR AQ-B on page 3.2-20 of the Draft EIR is a standard City condition of approval. The City has determined that notice within 300 feet to property owners provides appropriate notification of project construction. However, in response to the concerns raised, the City will increase the notification requirement to 500 feet for this project. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. HBT-2 These measures are part of Rule 403 established by SCAQMD. Compliance with more stringent measures has not been deemed necessary to ensure effective dust suppression. HBT-3 As part of the mitigation monitoring effort for the proposed project, project developers would be required to provide manufacturer's information indicating that developer- installed appliances are considered to be energy efficient. An example of energy efficient appliances are those identified with the "energy star" label. These types of appliances meet the intent of the recommended mitigation measure. HBT-4 Trash collection services for the proposed project would occur during the same hours as occurs elsewhere throughout the City of Huntington Beach. In general, these services occur between 7:00 A.M. and 4:00 P.M. when solid waste can be collected and disposed of during the same day. Noise associated with trash collection would not violate City noise ordinances or exceed noise thresholds. HBT-5 Page 3.12-3 of the Draft EIR has been revised to update the existing conditions information on helicopter patrols in the City; however, this information does not change the conclusions of the analysis. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. HBT-6 As discussed under MM TR-2 on page 3.14-78 of the Draft EIR, the Applicant's fair share contribution to improvements to PCH and Seapoint are required to be paid prior to issuance of a certificate of occupancy. The mitigation measure requires the City to ensure completion of this improvement, and the MMRP of this Draft EIR requires the improvement to be completed prior to a certificate of occupancy. As discussed under MM TR-lon page 3.14-58 of the Draft EIR, the Applicant is required only to contribute its fair-share toward the improvements at PCH and Warner 3-210 City of Huntington Beach Chapter 3 Responses to Comments Avenue and is not required to construct this improvement. The County of Orange and Caltrans would be responsible for completion of this improvement. As discussed on page 3.14-79 of the Draft EIR, feasibility of implementing this improvement has not been determined. In addition, ultimate implementation of this measure is not under the discretion of the City of Huntington Beach. As such, the impact during Year 2008 to this intersection was determined to be significant and unavoidable. HBT-7 The pedestrian bridge is a potential future project and community amenity. It is not a mitigation measure required to address significant impacts and, as such, it is not required as part of the proposed project. When the pedestrian bridge is submitted for approval by the City, it would be required to obtain the approvals required pursuant to City regulations at the time of submittal. HBT-8 As shown in Table 3.14-14 on page 3.14-50 and Table 3.14-16 on page 3.14-56 of the Draft EIR, the roadway link of Atlanta Avenue from Huntington Street to Delaware Street would continue to operate at LOS A in both Year 2008 and Year 2020 scenarios. Therefore, no improvements to this roadway segment would be required as a result of the proposed project. HBT-9 A bus turnout would be constructed along the PCH project frontage west of Huntington Street in conjunction with the proposed project. Please refer to Response to Comment HBEB-5 on page 3-205 for a discussion of identification of pedestrian pathways. HBT-10 The comment provides information and opinion about the Hamilton Avenue extension and the Banning/19th Street Santa Ana River crossing. Please refer to Response to Comment CNB-14 on page 3-196 for a discussion of analyses with and without these improvements. HBT-11 After consultation with the OCSD (Personal communication, Tom Walker, December 30, 2003), the text on page 3.15-3 of the Draft EIR has been revised to clarify that the Orange County Sanitation District discharges waste approximately five miles southwest of the mouth of the Santa Ana River. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. Pacific City EIR 3-211 Chapter 3 Responses to Comments Response to Comment Letter OCC (Orange County Coastkeeper, December 1, 2003) OCC-1 As discussed on page 3.8-19 of the Draft EIR, a Preliminary Water Quality Management Plan (WQMP) has been developed for the project that outlines the comprehensive approach that would be used in the attainment of water quality standards and goals promulgated by the SARWQCB and the City of Huntington Beach (refer to Appendix G of the Draft EIR.) Runoff water quality would meet the standards of regulations governing the site, including NPDES and the 2003 DAMP. Current regulations governing site discharge do not require "no net increase"in pollutants; thus, this performance standard is not applicable to the project. OCC-2 Please refer to Response to Comment RMC-54 on page 3-289 for a discussion of the feasibility of upgrades to the ASWPS. The adopted water quality standards governing the site are those employed by the RWCQB and 2003 DAMP, even if the project site is located adjacent to the beach. Further, there is no nexus that requires the applicant to adhere to a different standard of treatment other than established laws or regulations. Please refer to the Topical Response on Water Quality on page 3-173 for an additional discussion of water discharges. OCC-3 Please refer to responses to specific concerns below. OCC-4 The project provides appropriate water quality control devices on-site, which would be implemented through a WQMP for the project. The Talbert Marsh is not identified as a management tool to address runoff from the project site. Runoff from the ASWPS, other than dry-weather flows, is currently discharged to the Talbert Marsh. The ASWPS has an existing pump capacity of 551 cfs. The project would discharge 16.7 cfs and 21.8 cfs to the ASWPS during 25- and 100-year storm events, respectively, which represents a net decrease from the total area of the site discharging to the ASWPS, compared to the existing condition. The project represents a small portion of the total pump capacity of the ASWPS. An analysis of the ability of the Talbert Marsh to serve as a management tool for water quality discharging from the ASWPS is beyond the scope of this EIR, because the marsh is not part of the WQMP for the proposed project. OCC-5 As discussed on page 3.8-21 of the Draft EIR, an on-site underground detention basin with a volume of about 0.82 acre-feet would be required to reduce the stormwater 3-212 City of Huntington Beach Chapter 3 Responses to Comments discharge from Drainage Area "B"—that portion of the site that would drain to First Street—to 20 cfs. City Public Works and the City's consultants have reviewed the design feature to ensure that it has been appropriately sized. The City would review and approve final civil engineering drawings and calculations for the detention basin. OCC-6 The subject of the Draft EIR is the proposed Pacific City development, and the Hydrology analysis presented in the Draft EIR considers project impacts on hydrology and water quality that could result from the proposed development. Consideration of the project's ability to treat runoff from adjacent areas is not part of the scope of the Draft EIR. This comment does not address the adequacy of the Draft EIR, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. OCC-7 The project is not required to address storm drain and runoff issues in areas beyond the project site, particularly when off-site areas are not affected by development of the project site. Storm drain facilities servicing the project site would be sized to adequately handle runoff following project implementation. This comment does not address the adequacy of the Draft EIR, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. OCC-8 Resolution OCSD 01-07 provides the agreement between the City and OCSD that enables treatment of some of the City's dry-weather flows by OCSD, and the City holds a long-term permit from the OCSD for the ASWPS that authorizes and regulates' discharges. The analysis of water quality impacts does not rely on OCSD treatment of dry-weather flows to ensure that impacts would be less than significant. Therefore, no long-term agreement between the City and OCSD is required to address project impacts. OCC-9 Please refer to the Topical Response on Water Quality on page 3-173 which addresses the issue of bacterial contaminants and treatment. The WQMP would address other pollutants, including metals, nitrates, and oils and grease, as identified in Appendix G (Drainage Study Including Preliminary Hydrology Analysis and Water Quality Analysis for Pacific City) of the Draft EIR. As stated on pages 1 and 3 of Appendix G of the Draft EIR, Section 6 (Recommended Water Quality Mitigation Post Construction Best Pacific City EIR 3-213 Chapter 3 Responses to Comments Management Practices for Pacific City Project), the WQMP would outline the type of BMP that would be used and what mitigation is expected. For example, the type of structural BMP that is planned for installation (i.e., StormFilter) can contain a variety of filter material, and each material has specific pollutant restricting capabilities. These site-specific media options give the StormFilter the ability to remove high levels of stormwater pollutants, such as sediments, oil and grease, soluble heavy metals, organics, and soluble nutrients. Upon completion of the project and after a short period of time, the filter material is removed and tested for actual pollutant discharge for further filter recommendations, thus minimizing pollutants loads contained in site discharges. OCC-10 Comment noted. The proposed project includes a detention basin that would limit discharges to the project's First Street drainage system at a rate of 20 cfs. OCC-11 The California Toxics Rule is a rule that indicates specific chemicals for which sewage plant operators must test for, and in some cases, either must substantially reduce or completely remove from wastewater before discharging it into rivers, tributaries, and other surface waters. Thus, this rule is not applicable to the proposed project. Please --- refer to the Topical Response on Water Quality on page 3-173 for a discussion of the treatment of runoff for bacterial contamination. OCC-12 As discussed under Impact HYD-1 on page 3.8-17 of the Draft EIR, the proposed project would prepare a SWPPP. SWPPP preparation would be required and enforced through CR HYD-A, as indicated on pages 3.8-26 of the Draft EIR. Please refer to Response to Comment HBEB-6 on page 3-205 for information on long- term monitoring of water quality management issues. As discussed above, the California Toxics Rule does not apply to the project site. OCC-13 Please refer to the Topical Response on Water Quality on page 3-173 which addresses the issue of treatment of runoff for bacterial contamination. OCC-14 The City of Huntington Beach and the County of Orange have standards that identify the amount of runoff allowable on surface streets. The 100-year flows must be contained within the street right-of-way, and one 12-foot lane must be clear of water on arterial highways, as specified in the City of Huntington Beach Standard Plan 300 and Orange County Local Drainage Manual. Appendix G (Drainage Study Including 3-214 City of Huntington Beach Chapter 3 Responses to Comments Preliminary Hydrology Analysis and Water Quality Analysis for Pacific City) of the Draft EIR, prepared by Hunsaker & Associates Irvine, Inc. provides preliminary calculations that indicate that stormwater flows from a 25-year event or 100-year event would allow more than one lane in each direction to remain clear of water on PCH and First Street. Please refer to Section 1, pages 3 through 6 of Appendix G in the Draft EIR for a complete discussion of runoff water. OCC-15 Comment noted. Please refer to the Topical Response on Water Quality on page 3-173 for a discussion of reducing pollutants to the Maximum Extent Practicable. These comments do not address the adequacy of the Draft EIR, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. OCC-16 Comment noted. As discussed under the specific responses provided above, the WQMP and project design features would ensure that site discharges would meet applicable water quality standards. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Pacific City EIR 3-215 Chapter 3 Responses to Comments Response to Comment Letter LBBS (Lewis Brisbois Bisgaard & Smith LLP, December 3, 2003) LBBS-1 Comment noted. LBBS-2 Neither Chapter 15.50 (Consolidation Projects) of the City's Municipal Code nor City zoning laws, through Downtown Specific Plan (DTSP) Section 4.14.03, create any right of direct access to Oil Overlay "C" at the project site. Oil Overlay "C" in the DTSP"facilitates" or allows for existing and/or expanded oil production on the project site, if the owner of the site's real property surface rights proposes to continue or expand such production. This Oil Overlay does not create rights of surface entry where none exist; the Oil Overlay was intended to provide an enabling mechanism for property owners to expand or consolidate dispersed, existing operations. The Oil Overlay consolidation project was implemented in order to address the environmental effects of dispersed oil recovery operations. The Oil Overlay has eight objectives, as listed in 15.50.010 of the Huntington Beach Municipal Code and summarized here: (1) to consolidate oil operations onto specified locations; (2) to obtain the abandonment and replacement of outdated and hazardous wells and tanks; (3) to eliminate or substantially lessen environmental effects with mitigation; (4) to offset unavoidable impacts with overriding improvements in other areas; (5) to minimize visual impacts; (6) to protect the public from damage and nuisance associated with operation of oil recovery facilities; (7) to maintain consistency with the General Plan; and 8) to provide a higher level of safety for the public. The intent of Section 4.14.03 (Oil Overlay "C") of the DTSP is to permit, but not require, oil-drilling operations on areas within the City that are designated as Oil Overlay "C." Because the DTSP, of which Oil Overlay "C" is a part, overlies still- productive oil reserves, oil production will continue to be permitted in parts of this area. The City has designated oil "suffix" zoning districts which permit the oil facilities allowed by suffix (see Municipal Code §220.02) and the underlying base zone use, such as commercial or residential development for relevant parcels in the DTSP area. The base zoning for this overlay area is high density residential; a 30 unit per acre residential project is proposed without any oil production. Existing and/or expanded oil production may continue in these areas provided that the additional conditions outlined in the DTSP §4.14.03 are met. In particular, preparation of a conceptual site plan that 3-216 City of Huntington Beach Chapter 3 Responses to Comments includes at least one oil island of not,less than two acres in size would need to be provided for new oil well drilling and oil production is applicable only when a project proposes oil drilling or other oil production activities. The oil island requirement for proposed drilling or production is intended to mitigate the environmental effects of such activities. The former oil production activities on the project site have been terminated for a period of time and the site is currently vacant. As discussed on page 3.5-4 of the Draft EIR, oil well abandonment at the project site occurred over a number of years, beginning in 1976 and occurring through 1999. The majority of on-site wells were initially abandoned in 1988 and subsequently re-abandoned in 1998; additionally, all of the abandoned oil well sites have also been remediated, thus, those wells are no longer operational. This project proposes residential and commercial uses for the site, in keeping with the DTSP-zoned base use for the project site, and with General Plan Coastal Element Policy C 8.4.3 to encourage comprehensive planning for new uses on large oil parcels. Further, according to the deed for the parcel[s] that constitute the project site, the owner of the mineral rights has no rights to access those resources through surface means: the "Grantor, its successors and assigns, shall not use the surface of said land [Parcel B] in the exercise of any said rights [all petroleum and other hydrocarbon substances and products] and shall not disturb the surface of said land or any improvements thereon or remove or impair the lateral and subjacent support of said land or any improvements thereon, and shall conduct no operations within 500 feet of the surface of said land" (deed recorded September 13, 1960, Book 5413, Page 449). The deed notes the Grantor holds the "sole and exclusive right to drill slanted wells from location on other lands into and through, and to construct or develop mines, tunnels, shafts, or other works in and through the subsurface of said land for the purposes of recovering said reserved substances from said land or recovering like substances from other lands; provided, however, that the surface of said land shall not be used for the exploration, development, extraction, or removal of said minerals or substances from said land or other lands, as reserved in the deed from City of Huntington Beach, recorded January 13, 1960 in Book 5051, Page 383 of official records." Pacific City EIR 3-217 Chapter 3 Responses to Comments - In light of the deed restrictions on the project site parcel, the mineral estate owner is not accorded dominant tenement; that right is reserved explicitly in the deed for the surface estate owner. As the deed was recorded well in advance of the development of the Oil Overlay zones, Overlay "C" does not supersede the deed nor afford direct surface access to the mineral estate holder. Thus, the option of slant drilling is discussed in the Draft EIR to record that the proposed project would not result in the loss of direct access to mineral resources via the means available to the mineral estate holder for the project site parcel[s]. Note additionally, the project does not propose slant drilling, and as such, no analysis of this activity is provided. As indicated on page 3.5-11 of the Draft EIR, slant drilling is present as a feasible future action that would allow for future access to mineral resources, demonstrating that the project does not result in loss of available mineral resources. If slant drilling were proposed in the future, environmental analysis would be completed at that time to evaluate the effects of this activity. LBBS-3 Upon consultation with the HBFD and the City's petroleum-consultant, slant drilling was identified as a feasible means of accessing mineral resources beneath the site. As stated on page 3.5-11 of the Draft EIR, the City's petroleum consultant, Mel Wright, communicated to the City in March 2003 that "Resources beneath the project site are located at a depth that it is possible for slant drilling to occur at available off-site locations in order to extract mineral resources from the site." The deed for the property clearly states that the mineral estate holder would not have surface access to those rights, and the deed specifically calls out slant drilling as a method to realize those resources. Please refer to Response to Comment LBBS-2 on page 3-216 for additional detail on the deed agreement regarding the legal relationship between the surface estate owner and the mineral estate owner for the project site parcel[s]. LBBS-4 Mel Wright was contacted by EIP Associates on March 24, 2003 via telephone regarding the feasibility of slant drilling for the project site. The consultation was part of the data gathering process for the Draft EIR. The information provided by Mel Wright is part of EIP Associates' internal data records for the project. Please refer to Response to Comment LBBS-2 on page 3-216 for additional detail. Mel Wright was subsequently contacted on December 22, 2003 to clarify his prior conversation with EIP Associates and confirm feasibility of slant drilling. 3-218 City of Huntington Beach Chapter 3 Responses to Comments LBBS-5 This comment accurately reflects the information presented at the public information meeting. No further response is required. LBBS-6 The EIR considers all phases of the proposed project, including the construction and operation of the project as sources of impacts, in an effort to include mitigation as part of planning where relevant,. The project evaluated in the EIR is the construction and operation of the Pacific City project. Any activities conducted prior to commencement of construction on-site are not considered a part of the proposed project. The project does not propose oil drilling, so preparation of a conceptual site plan that includes an oil island is not required or appropriate for the project. Please refer to Response to Comment LBBS-2 on page 3-216 for further discussion. As stated on page 2-7 of the Draft EIR, a portion of the DTSP District No 8A has a "Resource Production Overlay" which provides development standards in order to govern oil production activities on site, if proposed. However, no such production is proposed at any phase of the proposed project. LBBS-7 It is the intention of Section 4.14.03 of the DTSP to permit, but not require, oil- drilling operations on areas designated as Oil Overlay"C." Further, the recorded deed does not accord surface access to the mineral estate owner, and therefore, no wrongful taking would be committed. Thus, there is no impact, and mitigation or analyses of alternatives are not required. Please refer to Response to Comment LBBS-2 on page 3- 216 for further discussion of mineral rights on the project site. LBBS-8 As discussed in Response to Comment LBBS-2 on page 3-216, the deed agreement for this parcel clearly demonstrates that the holder of the mineral estate cedes surface access to those resources. Further, as project development would be in compliance with Section 4.14.03 of the DTSP, no violation of the rights of resident mineral owners would be committed. LBBS-9 The original intent of the City regarding the relationship between Chapter 15.50 and Oil Overlay designations is not within the scope of the proposed project. Nevertheless, any actions associated with the consolidation of the on-site oil operations as defined under Chapter 15.50 were considered prior to the termination of these oil production activities on the project site. The project would not result in termination of any oil production on site, and, as such, Chapter 15.50 is largely inapplicable to the project Pacific City EIR 3-219 Chapter 3 Responses to Comments and implementation of the proposed project would not violate Chapter 15.50 of the City's Municipal Code. Please refer to Response to Comment LBBS-2 on page 3-216 for additional discussion regarding the intent of Chapter 15.50. LBBS-10 Implementation of the proposed project would not violate Section 4.14.03 of the DTSP, as Section 4.14.03 is intended to permit, but not require, oil-drilling operations on the area designated as Oil Overlay "C" and permits commercial and residential uses on the project site. As the project site is no longer occupied by oil operations, Chapter 15.50 of the City's Municipal Code, regarding the consolidation of oil operations, is not applicable. Therefore, the proposed project would be in conformance with these two sections of City code. Please refer to Response to Comment LBBS-2 on page 3-216 for additional discussion regarding the intent of Chapter 15.50 and mineral rights on the project site. LBBS-11 The quoted paragraph from the regulations sections is correct, however the first clause of the regulations section states that "well drilling and redrilling shall be permitted in accordance with Title 15 of the Huntington Beach Municipal Code..." which premises the regulatory prescription for the provision of a two-acre oil drilling island. Such a set- aside is not required for the project, since it does not propose oil-drilling activities. LBBS-12 The proposed project is not required, or statutorily mandated, by Section 4.14.03 to provide for a two-acre oil island on the site. Please refer to Responses to Comments -- LBBS-2 on page 3-216 and LBBS-11 above for further discussion of the requirement to provide an oil island on the project site. LBBS-13 This issue is not a comment on the adequacy of the Draft EIR. As such, no further response is necessary. LBBS-14 Appendix A of the Draft EIR includes the Initial Study—a guiding document for preparation of the Draft EIR analysis. The Initial Study is intended to inform the Draft EIR as to impacts to consider for analysis of environmental effects, but it is not an ultimate conclusion. Conclusion of significance as to an impact is made in the body of the Draft EIR for each impact statement considered. LBBS-15 This issue is not a comment on the adequacy of the Draft EIR. As such, no further response is necessary. 3-220 City of Huntington Beach Chapter 3 Responses to Comments LBBS-16 Please refer to Responses to Comments LBBS-2 on page 3-216 and LBBS-11 on page 3- 220 for a discussion regarding why implementation of the proposed project would neither violate Section 4.14.03 of the DTSP or Chapter 15.50 of the City's Municipal Code. LBBS-17 Neither the Pacific City project nor the Draft EIR proposes slant drilling. Rather, as indicated on page 3.5-11 of the Draft EIR, slant drilling—the method of access specified in the deed for the parcel—is identified as a feasible method of mineral resource recovery, should recovery be desired in the future. LBBS-18 Please refer to Response to Comments LBBS-2 on page 3-216 and LBBS-11 on page 3- 220 for a discussion regarding why the proposed project would not violate Section 4.14.03 of the DTSP or Chapter 15.50 of the City's Municipal Code. LBBS-19 The consultation with Mel Wright was strictly to assess the feasibility of slant drilling onto the project site. EIP Associates contacted Mel Wright on March 24, 2003 via telephone to inquire about the feasibility of slant drilling for the project site, not to identify if other nearby areas were zoned for slant drilling. Please refer to Response to Comment LBBS-4 on page 3-218 for further discussion regarding the status of resource extraction on the project site and the possibility of future resource extraction from the project site. In addition, please refer to Response to Comments LBBS-2 on page 3-216 and LBBS-11 on page 3-220 for discussion regarding why the proposed project would not violate Section 4.14.03 of the DTSP or Chapter 15.50 of the City's Municipal Code. LBBS-20 EIP reaffirmed their previous consultation with Mel Wright on December 22, 2003. Please refer to Responses to Comments LBBS-3 and LBBS-4 on page 3-218 , and LBBS- 19 above for additional detail regarding discussions with Mel Wright on slant drilling. LBBS-21 The deed for the property clearly states that the mineral estate holder would not have surface access to those rights, and the deed specifically calls out slant drilling as a method to realize those resources. Therefore, the Draft EIR discussed slant drilling in keeping with deed restrictions as an option to preserve access to these mineral resources. Please refer also to Responses to Comments LBBS-2 on page 3-216 and LBBS-3 on page 3-218 for discussion regarding why slant drilling was discussed in the Draft EIR. Pacific City EIR 3-221 Chapter 3 Responses to Comments LBBS-22 Please refer to Responses to Comment LBBS-21 on page 3-221 for discussion regarding why slant drilling was discussed in the Draft EIR. LBBS-23 Please refer to Responses to Comment LBBS-21 on page 3-221 for discussion regarding g why slant drilling was discussed in the Draft EIR. LBBS-24 Please refer to Responses to Comment LBBS-21 on page 3-221 for discussion regarding why slant drilling was discussed in the Draft EIR. LBBS-25 As stated on page 3.7-12 of the Draft EIR, the site is located entirely within a methane gas overlay district designated by the City, and as such, methane gas may underlay the site. Impacts HAZ-1 and HAZ-2, on pages 3.7-16 to 3.7-18 of the Draft EIR, discuss potential hazards that could result from the presence of methane on the project site. The project would comply with City specifications necessary to maintain standards of -- construction required within the Methane Overlay District. As discussed on page 3.7- 16 of the Draft EIR, City Specification 429 specifies requirements for permits for construction within methane districts (i.e., in the vicinity of abandoned oil wells), including the provision of methane barriers for structures. Furthermore, City Requirement (CR) HAZ-B would be applied to the project, which requires the project to comply with all provisions of the HBMC Section 17.04.085 and Fire Dept. City Specification 429 prior to the issuance of grading permits. Finally, any risks associated with former oil wells (including methane gas) have been taken into consideration in the geotechnical report and site characterization studies performed for the project, the former oil wells on the site have been abandoned to DOGGR standards, and the regulatory framework that covers this issue has been followed for the proposed project. LBBS-26 Please refer to Response to Comment LBBS-25 above for a discussion in the Draft EIR regarding analysis of impacts related to the presence of methane gas. LBBS-27 Please refer to Response to Comment LBBS-25 above for a discussion in the Draft EIR regarding analysis of impacts related to the presence of methane gas. LBBS-28 Please refer to Response to Comment LBBS-25 above for a discussion in the Draft EIR regarding analysis of impacts related to the presence of methane gas. 3-222 City of Huntington Beach Chapter 3 Responses to Comments LBBS-29 Please refer to Response to Comment LBBS-2 on page 3-216 for discussion regarding the intended use of Oil Overlay C and the rights of mineral estate owner to access resources beneath the site. LBBS-30 Comment noted. Pacific City EIR 3-223 Chapter 3 Responses to Comments Response to Comment Letter OEG (A) (Orosz Engineering Group, Inc., December 3, 2003) OEG(A)-1 Comment noted. Please refer to responses to specific concerns identified below. OEG(A)-2 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of the appropriateness of the internal capture rates and trip reductions. The internal capture rates are consistent with and actually less than ITE methodology and the mode shift percentages conform to ITE recommendations and reflect the experience of City staff and the unique combination of the proposed project's mixed- use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. As indicated in the NOA, all documentation was available at the City's Planning Department, the Main Street Library, and the Central Library, and the requested data were provided to the commenter. OEG(A)-3 The text of the Draft EIR page 3.14-15 has been revised to clarify that the summer weekday condition is typically higher than during the winter months and, consequently was used in this analysis to present a conservative scenario. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. As also identified on page 3.14-15 of the Draft EIR, summer weekend traffic represents a "peak" period due to the beach resort character of the Downtown area. Common traffic engineering practice is to mitigate traffic and parking impacts to a typical weekday period, rather than a peak day (such as a holiday weekend, or summer weekend). The base parking demand ratios are consistent with City code, and use design ratio demands without any reductions for seasonal variations. OEG(A)-4 The City does not require an additional safety factor in parking facilities, which would result in a larger number of excess spaces. Instead, a safety factor is included into the base parking rates that the City uses. Consequently, provision of the number of required parking spaces allows for a buffer in the number of available parking spaces. A parking management plan would be utilized to oversee commercial parking operations and would direct vehicles to available spaces. OEG(A)-5 The Responses to Comments will become part of the Final EIR and will be provided to the decision-makers for review and consideration during their deliberations of whether 3-224 City of Huntington Beach Chapter 3 Responses to Comments or not to approve the proposed project. The responses will be distributed in accordance with CEQA Section 21092.5, and will be provided to all commenting agencies on the proposed project. As identified in the subsequent comment letter provided by the same commenter, OEG(B), the requested data was provided. Recirculation of a Draft EIR is required when "significant new information" is made available, as discussed in CEQA Guidelines Section 15088.5. Examples of significant new information identified in the CEQA Guidelines include: (1) a new significant impact; (2) a substantial increase in the severity of an environmental impact; (3) a new alternative or mitigation measure that is considerably different than others previously analyzed, which the project proponents decline to adopt; or (4) fundamental and basic inadequacies and conclusory information in the Draft EIR such that meaningful public review was precluded. The lack of furnishing background data immediately upon request, which does not alter the conclusions presented in the Draft EIR, does not satisfy the criteria set forth in the Public Resources Code or CEQA Guidelines for recirculation. Pacific City EIR 3-225 Chapter 3 Responses to Comments Response to Comment Letter OEG (B) (Orosz Engineering Group, Inc., December 4, 2003) OEG(B)-1 Please refer to responses below for detail. Regarding the comment that information was not readily available, the City regrets that the commenter had difficulty obtaining the information; however, as identified in the Notice of Availability, information was available at the City's Planning Department, Main Street Library, and Central Library. OEG(B)-2 The City confirms that the most recent data were used in the Draft EIR analysis. Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of the appropriateness of the internal capture rates and mode shift used in the analysis. OEG(B)-3 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of the appropriateness of the mode shift used in the analysis. The mode shift percentages conform to ITE recommendations and reflect traffic engineer and City experience with the unique combination of the proposed project's mixed-use land P q P P characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. This comment oversimplifies the interaction of uses on the project site and quantifies the mode shift in terms of percentages and uses that are not reflective of the proposed project. The reduction for hotel traffic is intended to reflect the average reduction for each guest. For example, a guest at a typical hotel may drive to a recreation area for an afternoon, while a guest at the proposed project hotel will more likely walk to the beach, pier area, or nearby cultural facilities. With respect to retail/restaurant and office uses, the mode shift does not equate to a proportion of the use with a specified number of restaurants or square footage of the site. Rather, one out of every five vehicular trips is assumed to already be in the area when ADT are considered for these uses. The mode shift for the residential uses is not absolute, but rather an aggregate assumption based on the varying affect of each unit. OEG(B)-4 Please refer to Response to Comment OEG(A)-3 on page 3-224, which provides an identical comment, for discussion of shared parking and peak demand. 3-226 City of Huntington Beach - Chapter 3 Responses to Comments OEG(B)-5 Please refer to the Topical Response on Shared Parking on page 3-180 for a discussion of why the reductions are appropriate. The office reduction percentage of 5 percent of parking demand is characteristic of the area, based on the City's experience. - OEG(B)-6 Comment noted. OEG(B)-7 Please refer to Response to Comment OEG(A)-3 on page 3-224 which addresses the adequacy of the total number of parking spaces. OEG(B)-8 Please refer to Response to Comment OEG(A)-5 on page 3-224 which provides the same comment. Pacific City EIR 3-227 Chapter 3 Responses to Comments Response to Comment Letter PCAC (Pacific City Action Coalition, December 3, 2003) PCAC-1 Comment noted. PCAC-2 This comment provides an overview of the project and generally restates the information given in Chapter 2 (Project Description) of the Draft EIR. This comment does not raise any environmental issues, and no further response is required. PCAC-3 This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Please refer to responses below that provide responses to specific issues raised in this comment letter. PCAC-4 As stated on page 18 of the Initial Study prepared for the proposed project, which is included as Appendix A to the Draft EIR, the potential creation of objectionable odors affecting a substantial number of people would be less than significant. Because the Initial Study concludes that odors associated with the proposed project would be less than significant, no further analysis is required, and, as such, no additional information is provided in the EIR. PCAC-5 Once the proposed project is completed and operational, paints and solvents would be used on an occasional basis to refresh the architectural surfaces of the residential and commercial buildings. The content of all such paints and solvents are regulated by the SCAQMD, and these products are readily available at thousands of stores throughout the South Coast Air Basin. Because these products are used infrequently and are readily available, the City would not restrict their use for this project when all other projects in the City are not subject to any such regulation. PCAC-6 This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. The potential air quality impacts of the proposed project are discussed on pages 3.2-13 through 3.2-27 of the Draft EIR. The effectiveness of the internal trip reduction and mode-shift reduction characteristics of the mixed-use interaction of the proposed project and the surrounding land uses is discussed on pages 3.2-21 and 3.2-22 of the Draft EIR. As shown, the reduction of each 3-228 City of Huntington Beach Chapter 3 Responses to Comments pollutant type ranges from 27.1 to 38.2 percent. In addition, page 3.2-27 of the Draft EIR states that the recommended mitigation measures would ensure that construction emissions are not greater than predicted in this analysis. They would also reduce the operational emissions of the proposed project by approximately 0.01 pound per day of VOC and 0.17 pound per day of NON. Impact AQ-3, discussed on pages 3.2-15 and 3.2-16 of the Draft EIR addresses exposure of sensitive receptors to substantial pollutant concentrations of carbon monoxide (CO). The analysis evaluates CO concentrations at study area intersections based on national and State standards, the generally accepted approach for evaluation of this impact. CO concentrations drop off substantially with increased distance from an intersection, and, as a result, impacts at the mobile home park would be even less than at affected intersections. As shown in Table 3.2-7, CO concentrations would remain well below thresholds, and no further analysis of this issue is warranted. PCAC-7 This comment references the enclosed PCAC(A). Please refer to Responses to Comments PCAC(A)-1 through PCAC(A)-27 on pages 3-247 through 3-252 for a detailed discussion of each comment. PCAC-8 MM CR-1 and MM CR-2 on pages 3.4-18 through 3.4-20 of the Draft EIR have been revised as reflected in Response to Comment OCPD-12 on page 3-202. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. The mitigation measures would ensure that appropriate measures are taken with regard to paleontological resources and unanticipated archaeological resources. These measures require monitoring of grading and excavation activities for archaeological and paleontological resources and include standard practices widely used in the industry. PCAC-9 Oil and water wells on the site are former uses. As stated on page 2-8 of the Draft EIR, the majority of the oil production uses previously located on site was initially abandoned in 1988. Therefore, mineral resource extraction has not occurred on site for over a decade. Impact HAZ-2 on page 3.7-18 of the Draft EIR identifies the potential for damage to existing wells, and MM HAZ-7 and MM HAZ-8 on pages 3.7-21 and 3.7-22 of the Draft EIR identify measures necessary where construction is proposed over abandoned wells and if wells are damaged during construction. MM HAZ-5 on page 3.7-21 of the Pacific City EIR 3-229 Chapter 3 Responses to Comments Draft EIR addresses issues associated with unanticipated discovery of contamination on site during construction. The procedures identified in this Mitigation Measure would also apply in the unlikely event that former wells are discovered, as former wells would have associated contamination, thus triggering implementation of MM HAZ-5 if unidentified wells are discovered. PCAC-10 A soils and geotechnical analysis would be required as identified by CR GEO-A on page 3.6-20 of the Draft EIR, and project design would be required to comply with the recommendations in the final soils and geotechnical analysis, as identified by MM GEO-1 on page 3.6-21 of the Draft EIR. Measures would include but would not be limited to dewatering, surface drainage, and other measures that would address groundwater at the site. Further, the project would comply with City specifications necessary to maintain standards of construction required within the Methane Overlay District. As discussed on page 3.7-16 of the Draft EIR, City Specification 429 specifies requirements for permits for construction within methane districts (i.e., in the vicinity of abandoned oil wells), including the provision of methane barriers for structures. Furthermore, CR HAZ-B would be applied to the project, which requires the project to comply with all provisions of the HBMC Section 17.04.085 and Fire Dept. City Specification 429 prior to the issuance of grading permits. Finally, any risks associated with former oil wells (including methane gas) have been taken into consideration in the geotechnical report and site characterization studies performed for the project, the former oil wells on the site have been abandoned to DOGGR standards, and the regulatory framework that covers this issue has been followed for the proposed project. PCAC-11 This comment correctly notes the potential for ocean-related corrosion and other site- specific soil constraints. Site specific soils constraints would pose an issue related to building location if they could not be addressed through standard design and construction techniques. As a standard City requirement, a qualified, Licensed Engineer must prepare a detailed soils and geotechnical analysis for the project site to identify project design features that must be incorporated in order to address the issues related to expansive, unstable, and corrosive soils. MM GEO-1 on page 3.6-21 of the Draft EIR ensures that the grading plan prepared for the project site would incorporate these recommendations. As such, the grading plan for the project site would include measures to address seismic hazards and foundation design for the project. 3-230 City of Huntington Beach Chapter 3 Responses to Comments The Geotechnical Investigation (included as Appendix J of the Draft EIR) identifies measures to address issues related to unstable, expansive, settlement-prone, and corrosive soils. These measures would be refined upon completion of final building design. Thus, measures to address these issues have not been deferred to a document in the future. PCAC-12 This comment references the enclosed PCAC(A). Please refer to Responses to Comments PCAC(A)-1 through PCAC(A)-27 on pages 3-247 through 3-252 for a detailed discussion of each comment. PCAC-13 An EIR is prepared for a proposed project to serve as an informational document that discloses to the public the current conditions of a project site and identifies any potentially significant environmental impacts associated with the planning, construction, or operation of the project, as well as feasible mitigation measures to minimize or eliminate these impacts. Currently, the possibility for PCB contamination at the site exists, which is disclosed under Impact HAZ-1 on page 3.7-11 of the Draft EIR, and this impact is considered potentially significant. Thus, the intent of MM HAZ-1 on page 3.7-15 of the Draft EIR is to ensure that any potential contamination from PCBs at the project site would be addressed prior to project development. As discussed in CEQA Guidelines Section 15126.4(B), measures may specify performance standards which would mitigate the significant effect of the project and which may be accomplished in more than one specified way. In the instance of MM HAZ-1, the performance standard is completion of remediation in accordance with MM HAZ-3 and HAZ-4. MM HAZ-3 and HAZ-4, as discussed on pages 3.7-20 and 3.7-21 of the Draft EIR, outline the process for remediation and require submittal of closure reports or other reports acceptable to the City Fire Department that document the successful completion of required remediation. Thus, the standard that must be met is the acceptance of closure reports or other acceptable documentation by the City Fire Department. The mitigation program outlined in the EIR would ensure clean up of PCBs, if identified on-site. PCAC-14 Please refer to Response to Comment PCAC-13 above for a discussion of use of performance standards in Mitigation Measures. The performance standards for MM HAZ-2 are the same as those identified for MM HAZ-1, as discussed on page 3.7-20 of the Draft EIR. Pacific City EIR 3-231 Chapter 3 Responses to Comments PCAC-15 As discussed on page 2-4 of the Draft EIR, the current remediation effort is occurring as an action independent of the proposed project entitlement effort, and would occur irrespective of whether or not the project proceeds towards construction of approved land uses. MM HAZ-3, as discussed on page 3.7-20 of the Draft EIR, would address remediation of remaining contamination in the areas of the existing water main, archaeological sensitivity, and any other locations identified as part of the efforts required under MM HAZ-1 and MM HAZ-2, which are also discussed on page 3.7-20 of the Draft EIR. Remediation of the water main and areas of archaeological sensitivity are occurring in conjunction with project construction only as a result of the efficiencies of completing this remediation concurrently with project construction; however, it is an action separate from the proposed project, as such, implementation and monitoring of remediation activities are also separate from the proposed project, except in the instance where grading associated with the proposed project reveals the necessity for additional remediation. As stated in MM HAZ-3, remediation activities shall be approved by the City and performed under the supervision of the City of Huntington Beach. Therefore, monitoring by the City is incorporated in the measure and no additional monitoring is required. PCAC-16 This comment references the enclosed PCAC(A). Please refer to Responses to Comments PCAC(A)-1 through PCAC(A)-27 on pages 3-247 through 3-252 for a detailed discussion of each comment. PCAC-17 Any groundwater contamination that may have occurred as a result of previous activities on-site is not an effect of the proposed project. As discussed on page 3.7-10 of the Draft EIR, petroleum hydrocarbon impacted soil appears to have minimal impact on groundwater. Further, since groundwater beneath the project site is brackish due to saltwater intrusion, it is not used as potable water by the City. Therefore, there is no nexus between existing groundwater quality and impacts of the proposed project. As such, no mitigation for the remediation of groundwater is required. CR GEO-A requires that recommendations for addressing groundwater are included in the final geotechnical and soils analysis. PCAC-18 As discussed on page 2-4 of the Draft EIR, the current remediation effort is occurring as an action independent of the proposed project, and would occur irrespective of whether or not the proposed project proceeds. The recommendations and Conditions of Approval associated with CUP 00-36 and CDP 00-09 address impacts from 3-232 City of Huntington Beach Chapter 3 Responses to Comments remediation activities; it would not be appropriate to add them as mitigation measures to this EIR because the CDP and the CUP have already been issued and operate independently of any discretionary action by the City on the EIR. The EIR addresses impacts due to construction and operation of residential and visitor-serving commercial uses. Therefore, the recommendations for remediation activities do not address project impacts. Notwithstanding the current remediation effort, as discussed on page 3.7-20 of the Draft EIR, MM HAZ-3 requires remediation of any additional contamination identified pursuant to MM HAZ-1 and MM HAZ-2. MM HAZ-3 requires this remediation plan—if necessary—to include methods to minimize remediation-related impacts on the surrounding properties. The remediation plan would require review and approval by the HBFD. PCAC-19 This comment references the enclosed Attachments PCAC(A) and PCAC(C). Please refer to Responses to Comments PCAC(A)-1 through PCAC(A)-27 on pages 3-247 through 3-252, and PCAC(C)-1 through PCAC(C)-15 on pages 3-259 through 3-262 for a detailed discussion of each comment. PCAC-20 The commenter correctly identifies and reiterates information presented in the land use analysis of the Draft EIR. No comments on the adequacy of the analysis are provided, and no further response is necessary. PCAC-21 The proposed layout of the residential area in comparison to the hotel and commercial area is based upon the specified zoning and land use designations within each Specific Plan District. Setbacks from the street and separation of these uses by the extension of Pacific View Avenue conform to the Specific Plan requirements identified for this site and deemed appropriate by the City during the Specific Plan process. Thus, further setbacks are not required. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. PCAC-22 Impact LU-2 on page 3.9-20 of the Draft EIR fully addresses and analyzes land use compatibility issues with surrounding areas. The proposed project would be developed in conformance with the Downtown Specific Plan (DTSP). As stated on page 3.9-20 of the Draft EIR, these land use designations and their relationship to existing uses have Pacific City EIR 3-233 Chapter 3 Responses to Comments been evaluated in prior environmental documentation, including the Huntington Beach DTSP EIR, the Huntington Beach General Plan Update, and the Huntington Beach Redevelopment Project EIR. Each of these documents includes analysis that accounts for development, including the issue of density, at the project site. Impact LU-2 compares proposed development to existing development in terms of types and intensity of uses, in order to address land use compatibility. The analysis concludes that while project development would be more intense than uses surrounding the site, it would result is uses that would be compatible with similar, surrounding land uses, and impacts would be less than significant. PCAC-23 In order to obtain the Special Permits for building encroachments into the setbacks as well as to allow for 15 percent parking garage ramps in three areas, the Applicant would be required to demonstrate that deviation under these Special Permits would provide a greater benefit than the project would have if requirements of the Specific Plan were met. Portions of the building structures in the commercial component of the project, are proposed to project into the front setback along the PCH frontage. The purpose of proposing the building pads within the 50 foot setback is due to the configuration of the property boundary lines compared to the sidewalk on PCH. The encroachment into the setback would enhance building articulation on PCH rather than resulting in a single mass of development. In addition, there are areas along Pacific View Avenue where portions of the neighborhood serving retail buildings encroach into the 20 foot front yard setback. The purpose of proposing minor encroachments into the front yard setback is to allow for the commercial buildings to provide a more storefront pedestrian experience. The Special Permits allow for the placement and design of structures that facilitate and encourage pedestrian activity and convey a visual link to these two streets. The reduced setbacks also allow for clustering of buildings to create plaza areas throughout the project. In addition, as discussed on page 3.14-76 of the Draft EIR, a special permit would be required to allow for parking garage ramps of 15 percent in three locations within District 8A. The Special Permit for increased ramp slope of 15 percent for the residential portion of the project allows for more efficient use of land because these ramps require less ground surface area, and therefore, they allow more useable common open space area. 3-234 City of Huntington Beach Chapter 3 Responses to Comments These Special Permits are consistent with the objectives of the DTSP and the Coastal Element and are compatible with the surrounding environment. The arrangement of structures, parking, circulation areas, and open space areas relate to the surrounding built environment in pattern, function, scale, and character. The commercial portion of the project includes a mix of setbacks consistent with existing building setbacks north of the site along PCH and the existing hotels south of the site along PCH. PCAC-24 As discussed in Impact TR-10 on page 3.14-76 of the Draft EIR, the proposed parking garage ramps would consist of both 10 percent and 15 percent grades. Where applicable, a 15 percent grade would allow for more open space in the common areas of the residential village. PCAC-25 Please refer to Response to Comment PCAC-22 on page 3-233 for a discussion of the land use compatibility analysis in the Draft EIR. The residential development conforms to the allowed density of 30 units per acre for the site. PCAC-26 This comment references the enclosed PCAC(B). Please refer to Responses to Comments PCAC(B)-1 through PCAC(B)-29 on pages 3-253 through 3-258 for a detailed discussion of each comment. PCAC-27 MM N-2 on page 3.10-23 of the Draft EIR is considered feasible to ensure that noise levels at the proposed residential uses do not exceed City standards. PCAC-28 This comment references the enclosed PCAC(C). Please refer to Responses to Comments PCAC(C)-1 through PCAC(C)-15 on pages 3-259 through 3-262 for a detailed discussion of each comment. PCAC-29 Impact P-2 on page 3.11-16 of the Draft EIR acknowledges that because the details related to the provision of affordable housing units have not been finalized, this impact would be potentially significant. Mitigation Measure P-1 on page 3.11-18 of the Draft EIR ensures that affordable housing requirements of the Community Redevelopment Law would be met, and the residual impacts would be reduced to a less than significant level. PCAC-30 Crime prevention design measures are anticipated to include features such as security enhancement lighting, and other features of project design that would not significantly modify the overall building plans. In addition, consultation prior to issuance of building Pacific City EIR 3-235 Chapter 3 Responses to Comments permits would ensure that any modifications could be incorporated into building plans before they are finalized. PCAC-31 The comment correctly identifies the issues raised with Impact REC-1 on page 3.13-9 of the Draft EIR. To address these issues, Mitigation Measure REC-1 on page 3.13-13 of the Draft EIR requires compliance with City parkland requirements, Chapter 254.08 of the City's Municipal Code. In order to comply with the requirements, the adequate provision of parkland (i.e., dedication of 2.4 acres of recreational area as parkland) or the payment of in-lieu fees to substitute for parkland dedication would be required. Fulfillment of this requirement could occur through any combination of on- or off-site parkland dedication and in-lieu fee payment. The City has contemplated and may, at its discretion, require the dedication of parkland on-site as a condition of approval of the project. PCAC-32 Please refer to the Topical Responses on Traffic Generation on page 3-176 and Shared Parking on page 3-180 for a discussion of why the internal capture and mode shift are appropriate to use. The internal capture reduction is used for trip generation only. The internal capture reduction and the mode shift percentages conform to ITE — recommendations and reflect traffic engineer and City experience with the unique combination of the proposed project's mixed-use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. PCAC-33 As described on page 40 of Appendix H (Traffic Impact Analysis Report) of the Draft FIR, a one percent growth rate is appropriate based on buildout traffic volumes and is consistent with recent studies conducted in the Downtown area. The use of one percent as a growth rate is also an accepted industry standard and has repeatedly been used in forecasting traffic volumes throughout the region. There are several related projects identified where specific traffic counts have been incorporated into the analysis, and these projects are shown in Table 3.14-11 on page 3.14-39 of the Draft EIR. The use of the one percent growth rate does not replace those individual projects, as detailed on pages 40-41 of Appendix H of the Draft EIR. P CAC-34 Tables 3.14-12 and 3.14-14 on pages 3.14-40 through 3.14-41 and 3.14-49 of the Draft EIR, respectively, provide Year 2008 Conditions with and without the proposed project. Additional trips have been assigned to the roadways, as is reflected in the change's in ICU and v/c ratios. However, the LOS does not always change with the 3-236 City of Huntington Beach Chapter 3 Responses to Comments addition of project traffic because the LOS reflects a range of delay that could occur, and the project-added traffic is not substantial enough to increase the delay from one LOS level to another. PCAC-35 Please refer to the Topical Response on Shared Parking on page 3-180. Supporting data for the shared parking analysis were available for review at the City during the Draft EIR comment period. The parking reductions reflect the mode shift percentages appropriate for the site based on ULI data and City experience with the unique combination of the proposed project's mixed-use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. Any existing parking issues in the project vicinity are not the responsibility of the proposed project. The comment refers to the "liberal use of off-site parking." Off site parking spaces are not assumed in the analysis of the shared parking. Rather, the analysis considers a mode shift, which involves the concept that some of the vehicles resulting from the proposed project would be attributable to vehicles that would access the area even if the project were not to occur. This mode shift reduces the total number of vehicles generated by the project that would require parking on-site. PCAC-36 Please refer to the Topical Responses on Traffic Generation on page 3-176 and Shared Parking on page 3-180, which discuss the basis for development of the mode shift data. The parking reductions reflect the mode shift percentages appropriate for the site based on ULI data and City experience with the unique combination of the proposed project's mixed-use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. PCAC-37 This comment references the enclosed PCAC(B) and PCAC(C). Please refer to Responses to Comments PCAC(B)-1 through PCAC(B)-29 on pages 3-253 through 3- 258 and PCAC(C)-1 through PCAC(C)-15 on pages 3-259 through 3-262 for a detailed discussion of each comment. PCAC-38 Comment noted. Pacific City EIR 3-237 Chapter 3 Responses to Comments PCAC-39 Comment noted. As discussed on page 4-27 of the Draft EIR, the Reduced Project Alternative is considered the environmentally superior alternative to the proposed project. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. PCAC-40 Please refer to responses to PCAC-1 though PCAC-39 for a discussion on the adequacy and appropriateness of mitigation measures used in the Draft EIR. This comment is acknowledged, and the opinion of the commenter will be provided to the decision- makers for review and consideration during their deliberations of whether or not to approve the proposed project. PCAC-41 Please refer to individual responses below for a discussion of how each of the items identified in the scoping letter was considered during preparation of the Draft EIR. PCAC-42 Section 3.7 (Hazardous Materials) of the Draft.EIR addresses the current status of soils on-site and summarizes remediation that has occurred to date, in addition to identifying a mitigation program to ensure that soils on-site are appropriately remediated. PCAC-43 Comment noted. PCAC-44 This information was generated in a prior traffic analysis for the site, which has been updated based on a refined project description and City comments and, therefore, is no longer applicable. PCAC-45 This information is not entirely consistent with the current development application and is not applicable to the analysis. The proposed project is described in Chapter 2.0 of the Draft EIR, including street widening and pedestrian improvements. PCAC-46 The commenter correctly notes that the City can provide an adequate water supply for the proposed project, in accordance with the adopted Water Master Plan, as discussed in Impact LI-1 on pages 3.15-13 and 3.15-14 of the Draft EIR. No mitigation is required. Improvements identified in the Water Supply Assessment for the proposed project are included as part of the project design. PCAC-47 Comment noted. The Draft EIR analyzed issues pertaining to Land Use, Population and Housing, Geology and Soils, Hydrology and Water, Air Quality, Transportation and 3-238 City of Huntington Beach - Chapter 3 Responses to Comments Traffic, Biological Resources, Mineral Resources, Hazards and Hazardous Materials, Noise, Public Services, Utilities/Service Systems, Aesthetics, Cultural Resources, and Recreation as a result of implementation of the proposed project. PCAC-48 Comment noted. The City considered this input, along with all scoping comments provided, during the preparation of the Draft EIR. A summary of how each of these issues was addressed is provided in the responses below. PCAC-49 The potential for a gas plant is discussed on page 3.7-5 of the Draft EIR. Please refer to Response to Comment Churchin-4 on page 3-328 for a discussion of the former facility. Page 3.7-5 of the Draft EIR has been updated to clarify that no gas plant was located adjacent to the site. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. PCAC-50 Section 3.7 of the Draft EIR addresses the current status of soils on-site and summarizes remediation that has occurred to date, in addition to identifying a mitigation program to ensure that soils on-site are appropriately remediated. PCAC-51 MM HAZ-7 on page 3.7-21 of the Draft EIR requires the developer to consult with DOGGR during construction over abandoned oil wells to determine if plug or replug of wells is necessary. In addition, MM HAZ-8 on page 3.7-22 of the Draft EIR would require the immediate ceasing of construction activities in the event abandoned oil wells are damaged during construction and for remedial plugging operations to be required. PCAC-52 MM HAZ-5 on page 3.7-21 of the Draft EIR requires that a risk management plan be prepared and implemented in the event that previously unknown soil contamination is encountered during construction. In addition, a site health and safety plan that meets OSHA requirements would also be prepared and implemented prior to the commencement of work in any contaminated area. PCAC-53 As indicated on page 3.1-31 of the Draft EIR, undergrounding of utility lines would occur as part of the proposed project along Huntington Street. No significant impacts would occur off-site with respect to the infrastructure referenced in the comment based on existing and future traffic volumes or conditions caused by project traffic. The Year 2008 total daily traffic volume on Huntington Street is anticipated to be 4,055 vehicles per day (VPD), which is well within the acceptable daily traffic volume for a Pacific City EIR 3-239 Chapter 3 Responses to Comments two-lane roadway. Thus, other improvements (i.e., widening of Huntington Street, implementation of access improvements to the Mobile Home Park, installation of sidewalks, or installation of retaining/sound walls) cannot be justified with the proposed project. PCAC-54 With respect to improvements, extension of Delaware Street and/or the mobile home park entrance/exit, no improvements to or removal of the Delaware Street or the mobile home park entrance/exit are necessitated by the proposed project, and none are planned in conjunction with the project. The proposed project would not result in a significant impact to the mobile home park ingress/egress, as the Huntington Street roadway segment between Atlanta Avenue and Pacific View Avenue would operate at LOS A during Year 2008 and 2020 conditions, as shown in Tables 3.14-14 and 3.14-16 on pages 3.14-49 and 3.14-56, respectively, in the Draft EIR. Therefore, no nexus exists between project impacts and this requested improvement. An extension of Delaware Street south of Atlanta Avenue to PCH is identified in the -- City's MPAH, Circulation Element (Figure CE-13), and Precise Plan of Street Alignment 70-3, which was approved by Huntington Beach City Council through Ordinance No. 1581. Implementation of this improvement is currently not programmed. However, as the Delaware Street extension is identified as a long-range improvement in the City, it is appropriate to include this improvement in the General Plan buildout scenario for traffic. Approval of the proposed project would not affect positively or negatively the potential for the Delaware extension to be implemented. Further, consideration of abandoning the Delaware Street extension is not part of the scope of this EIR. PCAC-55 The planned traffic improvements for the project, which are discussed on page 3.14-30 of the Draft EIR, do not include the extension of Delaware Street. Although this extension may eventually occur, it would occur independent of this project and would require additional studies/review'at that time. Please refer to Response to Comment PCAC-54 above for further information on the Delaware Street extension. PCAC-56 There is no nexus between this request and the project's traffic impact. In addition, the Pacific Mobile Home Park is not included as part of the proposed project. Therefore, issues pertaining to the possible relocation of the mobile home park entrance/exit were not addressed in the Draft EIR. 3-240 City of Huntington Beach Chapter 3 Responses to Comments PCAC-57 No significant impacts would occur off-site with respect to noise due to conditions caused by the proposed project. Thus, the construction of sound walls would not be necessary as part of the proposed project. Off-site noise impacts are discussed in Section 3.10.4 of the Draft EIR. PCAC-58 The extension of Walnut Street between 1st and 6th Streets as well as Pacific View Avenue between Beach Boulevard and the 55 freeway is not included as part of, nor required for the proposed project. Therefore, issues pertaining to these possible extensions were not addressed in the Draft EIR. However, these issues are addressed in the City's General Plan Circulation Element and are included in the assumptions in the 2020 analysis. PCAC-59 Please refer to Response to Comments PCAC-54 and PCAC-55 on page 3-240 for a discussion of the Delaware Street extension. PCAC-60 Comment noted. The traffic analysis included within the Draft EIR was not based solely on valet parking. PCAC-61 The proposed hotel and commercial components are designed with a loading area sufficient in size to accommodate buses, vans, and trucks per City code requirements. As stated on page 3.14-74 of the Draft EIR, proposed Driveways #1, #4, and #10 would provide service access for the commercial component of the proposed project, while proposed Driveways #2 and #3 would provide customer access to the commercial component. Thus, vehicles accessing the commercial component of the project site would not experience traffic congestion due to loading activities at the loading docks for the commercial uses at the project site. Since larger vehicles such as tour buses and moving vans would arrive on rare occasions, and generally not during the peak time of day, this was not considered part of the typical weekday analysis. PCAC-62 The Draft EIR analyzes impacts of the proposed project compared to baseline existing conditions from time of issuance of the Initial Study/Notice of Preparation. Thus, the Draft EIR does not rely on conclusions of previous environmental documentation. As stated on page 1-2 of the Draft EIR, this EIR serves as a project EIR, since it analyzes impacts of a specific development project; however, this EIR also serves as a Subsequent EIR, since development on the project site has been addressed on a programmatic level as part of the analysis included in several Program EIRs prepared by Pacific City EIR 3-241 Chapter 3 Responses to Comments the City of Huntington Beach. Section 21166 of the CEQA Guidelines requires re aration of a subsequent EIR due to changes in the existing P q g conditions discussed in the DTSP Area and the proposed project description. Implementation of the proposed project would be consistent with the Zoning and General Plan land use designations for the project site; however, changes with respect to the circumstances under which the project is being undertaken (i.e., changes to existing conditions) and new information, in the form of project details, has become available since the completion of DTSP EIR 82-2. Therefore, impacts particular to the project site required analysis that was not provided in previous documentation. The project proposed by the Applicant is consistent with the intensities identified in the General Plan and DTSP for the site. PCAC-63 The traffic impact analysis for the proposed project addressed local and regional traffic impacts consistent with City, County, and State guidelines. The text on page 3.14-15 of the Draft EIR has been revised to clarify that the summer weekday condition is typically higher than during the winter months and, consequently was used in this analysis to present a conservative scenario. PCAC-64 Employee traffic and employee parking, as well as waste management services, are accounted for in the traffic (i.e., trip generation) and parking analyses for the proposed project. PCAC-65 As stated on page 3.13-11 of the Draft EIR, "Pedestrian pathways throughout the site would be publicly accessible at all times." However, page 2-23 of the Draft EIR has been revised to clarify the availability of pedestrian access. PCAC-66 As stated on page 3.14-26 of the Draft EIR (Consistency Analysis with General Plan Circulation Element Policy 6.1.2), pedestrian circulation on-site would connect to the existing Class II bike path on First Street. In addition, as stated on page 3.13-4 of the Draft EIR, a Class I trail (Bike Path) runs the entire length of the beach, parallel to PCH, and is linked to the regional Santa Ana Bikeway. These trails are also part of the Orange County Master Plan of Regional Riding and Hiking. Several east/west Class II bikeways (Bike Lanes) run throughout the City as well, connecting to both of the Class I bike paths. In addition, as stated on page 2-20 (Table 2-8: Summary of Proposed Roadway Improvements) of the Draft EIR, PCH would be widened on the north side 3-242 Cityof Huntington B each Chapter 3 Responses to Comments for provision of a third westbound through lane and future bike lane. Thus, bicycle facilities would be provided within and adjacent to the project site consistent with City of Huntington Beach requirements. With respect to skaters (i.e., roller skaters and rollerbladers), the City does not differentiate between pedestrians and skaters, with the exception of prohibiting this use in business districts. Skaters could access pedestrian pathways through the residential portion of the site, and utilize the on-street bike path on First Street to access the beach. PCAC-67 As discussed on page 2-6 of the Draft EIR, the DTSP includes specific development regulations and zoning standards that are intended to supplement and/or supercede the Zoning Ordinance to promote the unique character of the particular subarea. Structures within District No. 7 permit building heights of eight stories. Structures within District No. 8A, "High Density Residential," are permitted up to a maximum height of 50 feet. These height limits were considered in the Specific Plan EIR (EIR 82- 2) and determined to be appropriate for the site. Building heights are in compliance with the DTSP. In addition, buildings would be stepped down along Huntington Street, consistent with Section 230.70 C of the Huntington Beach Zoning and Subdivision Ordinance, and would provide a transition to adjacent single-story structures. As discussed throughout Chapter 3 of the Draft EIR, issues such as view, glare, and noise are addressed with respect to the project's consistency with existing City Ordinances. PCAC-68 The text of the Draft EIR page 3.14-15 has been revised to clarify that the summer weekday condition is typically higher than during the winter months and, consequently was used in this analysis to present a conservative scenario. Table 3.14-11 includes trip generation from related projects that is included in the analysis. The Waterfront Ocean Grand Resort is the Hyatt project, and is therefore included in the analysis. The roadwaysegment and intersection LOSprovide an analysis of access and service to PCAC-69 grn y existing neighborhoods, including the Pacific Mobile Home Park, homes along Atlanta and Huntington streets, and others. Therefore, this issue has been considered. PCAC-70 The Pacific City shared parking analysis addresses (1) project usage consistent with City of Huntington Beach requirements and (3) regional parking during the summer months Pacific City EIR 3-243 Chapter 3 Responses to Comments - by assuming peak parking demand for each of the land uses within the project. The proposed project is not responsible for analyzing (2) the Hyatt's new convention facility parking demand, as this is not an impact of the proposed project. The project parking does not rely on off-site parking. Existing on-street parking that is removed by the project would be replaced with on-site parking within the parking structure and as on- street parking. PCAC-71 Section 3.14 of the Draft EIR discusses the number of parking spaces to be provided for residents, guests, and commercial vehicles. This section also discusses changes to on- street parking as a result of the proposed project. The comment provides no factual evidence that the project would impact "already overcrowded parking conditions downtown." The project would remove 53 existing on-street parking spaces, and would replace those spaces with spaces in the proposed parking structure. As shown in Table 2-8 on page 2-20 of the Draft EIR, roadway widening would result in an additional eastbound travel lane on Atlanta Avenue, and an additional southbound travel lane between PCH and Pacific View Avenue. PCAC-72 Project improvements would not change the wayin which buses are accommodated p g along adjacent streets with increased traffic; facility improvements are included in the Draft EIR. As discussed on page 3.14-76 of the Draft EIR, a bus turnout would be constructed on the north side of PCH, west of Huntington Street, in conjunction with the proposed project. In addition, the bus turnout on the south side of PCH, between Huntington and First Streets, and the bus stop on the south side of Atlanta Avenue, east of First Street, would be maintained. PCAC-73 As stated on page 3.14-37 of the Draft EIR, the west side of Huntington Street would be widened and dedicated 10 feet along the project frontage south only between Pacific View Avenue and PCH to accommodate a 80-foot ROW. All street widening would occur onto the proposed project site, and no encroachment into surrounding properties would occur. No widening is proposed on Huntington Street north of Pacific View Avenue adjacent to the residential portion of the project. PCAC-74 Project impacts on existing public services, including Fire, Police, and Lifeguard services, are discussed in Section 3.12.4 of the Draft EIR. 3-244 City of Huntington Beach Chapter 3 Responses to Comments PCAC-75 The extension of Pacific View Avenue would be a public roadway, and the internal loop road on the residential portion of the project would be a private roadway. Impacts associated with emergency access at the project site are addressed under Impact TR-9 and PS-1 on pages 3.14-72 and 3.12-9 of the Draft EIR,respectively. - PCAC-76 Impact TR-8 on page 3.14-68 of the Draft EIR addresses parking impacts of the proposed project. Because adequate parking would be provided on-site, beach parking would not be adversely impacted. PCAC-77 Impact AES-2 discusses impacts on scenic vistas. As discussed on page 3.1-30 of the Draft EIR, views from adjacent residences are from private residential locations; affects to these views would not be considered significant. Pedestrians accessing the project site would have views of the ocean, which would be far more expansive than those currently available from public vantage points surrounding the site. PCAC-78 Impact AES-4 on page 3.1-34 of the Draft EIR analyzes impacts from shade and shadows, and Impact AES-5 on page 3.1-37 of the Draft EIR analyzes impacts on light and glare. Impacts have been determined to be reduced to less-than-significant levels. PCAC-79 Impact REC-1 on page 3.13-9 of the Draft EIR discusses project impacts on parkland. Mitigation Measure REC-1 on page 3.13-13 of the Draft EIR requires the project to meet City parkland requirements through the dedication of parkland or the payment of in-lieu fees. PCAC-80 As discussed under Impact N-1 on page 3.10-14 of the Draft EIR, construction noise levels would not exceed the standards established in the Huntington Beach Municipal Code. Nevertheless, due to the nature of noise associated with pile driving activities, Mitigation Measure N-1 on page 3.10-23 of the Draft EIR is recommended to limit pile driving activities to the hours of 8:00 A.M. to 6:00 A.M., Monday through Friday. The Mitigation Monitoring and Reporting Program (MMRP) provides methods to ensure implementation of mitigation measures. In addition, as described in CR N-E on page 3.10-22 of the Draft EIR, the project would include a "disturbance coordinator" who shall be responsible for responding to complaints regarding construction noise. PCAC-81 Specific commercial uses have not been identified for the project site, although amplified music could occur associated with the restaurants, nightclubs, and promenade and plaza areas. The potential for specific commercial operations to generate nuisance Pacific City EIR 3-245 Chapter 3 Responses to Comments noise would be evaluated as part of the Conditional Use Permit(CUP) process for each commercial use that locates within the project site. Mandatory compliance with the City's Noise Ordinance would ensure that potential noise impacts would be reduced to less-than-significant levels. Based on the proposed site plan, however, the commercial uses would front Pacific Coast Highway. Noise from music and other activities are expected to be directed toward the coast and away from the new and existing homes in the area. In addition, commercial buildings would act as noise barriers between the front of the restaurants, bars, etc. and the nearby homes. PCAC-82 The proposed construction schedule and associated noise levels are consistent with the City Municipal Code. Please refer to Response to Comment PCAC-80 on page 3-245 for a discussion of hours of construction and noise monitoring. This comment is acknowledged, and the opinion of the commenter will be provided to the decision- makers for review and consideration during their deliberations of whether or not to approve the proposed project. PCAC-83 The proposed construction schedule is provided in Figures 2-8a and 2-8b on pages 2-27 and 2-28, respectively, of the Draft EIR. The text on page 2-26 of the Draft EIR indicates that construction of the recreational area in the center of the residential component would be constructed as part of the first phase of residential construction. The remainder of this comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. 3-246 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter PCAC (A) (Pacific City Action Coalition, Attachment A, December 3, 2003) PCAC(A)-1 Comment noted. Please refer to specific responses below. PCAC(A)-2 As indicated on page 3.7-10 of the Draft EIR, BBL intends to perform sampling in Area D to ensure that all potential contamination has been identified. Sampling performed as part of the 1996 Phase II Investigation targeted areas where former ASTs, pipelines and pipeline headers, and abandoned wells were located. However, an extensive survey of the project site was not performed. The initial sampling performed indicates that contamination did not migrate onto the western portion of the site. However, detailed sampling of soils in Area D would provide conclusive evidence; consequently, sampling of this area is required as part of MM HAZ-2 on page 3.7-20 of the Draft EIR. PCAC(A)-3 The testing conducted by Harding ESE in late 2001 or early 2002 is discussed on page 3.7-10 of the Draft EIR. As discussed, the detailed report on the soil investigation has not been completed. However, three samples were extended four to five feet past groundwater in three of the areas previously identified as containing elevated • concentrations of petroleum hydrocarbons. In cases where petroleum hydrocarbons in the soil have extended to groundwater, the extent of soil impacted with petroleum hydrocarbons is generally limited to within one to two feet of first encountered groundwater and the petroleum hydrocarbon impacted soil appears to have minimal impact on groundwater. PCAC(A)-4 This comment provides information about previous activities that may have occurred on-site. This comment does not address the adequacy of the Draft EIR. Nevertheless, as described on page 3.7-20 of the Draft EIR, MM HAZ-2 requires sampling in the western portion (Area D) of the project site, as discussed on page 3.7-10 of the Draft EIR, to ensure that all potential contamination has been identified In addition, the Huntington Beach Fire Department, which is the local oversight agency for cleanup of the project site, will not approve the Site Closure Report without concurrence from the Santa Ana Regional Water Quality Control Board. . PCAC(A)-5 This comment provides information about previous activities that may have occurred on-site. This comment does not address the adequacy of the Draft EIR. As a point of clarification, the City has not requested the records identified in this comment. Testing Pacific City EIR 3- 247 Chapter 3 Responses to Comments records are normally submitted at the City's request for closure, which has not yet occurred on site. PCAC(A)-6 This comment provides information about previous activities that may have occurred on-site. This comment does not address the adequacy of the Draft EIR, and no further response is required. This comment does, however, correctly identify that a groundwater testing plan was submitted to the City for the southeastern portion of the site. This document was superceded by Remediation Plan, Revision 3, prepared by Harding ESE. . PCAC(A)-7 In order to provide detailed characterization of soils and any potential contamination in Area D, MM HAZ-2 on page 3.7-20 of the Draft EIR would be implemented and would require sampling in this area. If contamination is identified, it would be remediated in accordance with MM HAZ-3 and HAZ-4, as discussed on pages 3.7-20 and 3.7-21 of the Draft EIR. Further, MM HAZ-5, as discussed on page 3.7-21 of the • Draft EIR, would require construction activities to cease in the event that previously unknown soil contamination is encountered that could present a threat to human health or the environment. As such, the mitigation program presented in the Draft EIR would ensure characterization of any contamination in Area D and remediation, if necessary. PCAC(A)-8 Please refer to Response to Comment PCAC(A)-7 above, which discusses characterization of Area D. Please refer to Response to Comment PCAC-13 on page 3- 231, which discusses the use of performance standards in mitigation in order to ensure effective implementation and avoid mitigation deferral. Impact HAZ-1 on page 3.7-15 of the Draft EIR discusses impacts of potential contamination on-site, and the effects on workers and residents in the area. PCAC(A)-9 This comment discusses the prior presence of a warning sign on the project site and does not provide comments on the adequacy of the Draft EIR analysis; thus, no further • response is necessary. However, worth noting, as discussed on pages 3.7-20 through 3.7-21 of the Draft EIR, MM HAZ-1 through HAZ-6 require remediation in accordance with existing City specifications. PCAC(A)-10 Any groundwater contamination that may have occurred as a result of previous activities on-site is not an effect of the proposed project. As discussed on page 3.7-10 of the Draft EIR, petroleum hydrocarbon impacted soil appears to have minimal impact 3-248 City of Huntington Beach Chapter 3 Responses to Comments on groundwater. Further, since groundwater beneath the project site is brackish due to saltwater intrusion, the City does not use it as potable water. Therefore, there is no nexus between existing groundwater quality and impacts of the proposed project. Petroleum hydrocarbon impacted soil appears to have a minimal impact on groundwater. As discussed on page 3.7-10 of the Draft EIR, in cases where petroleum hydrocarbons in the soil have extended to groundwater, the extent of soil impacted with petroleum hydrocarbons is generally limited to within one to two feet of first encountered groundwater. In addition, as discussed in the Revised Remediation Plan of June 2001, Harding ESE determined that contaminated soil at the property is limited to TRPH and is not related to any other volatile or semi-volatile compounds, including BTEX, or other petroleum hydrocarbons (i.e., diesel or gasoline). Thus, levels of BTEX discovered at the project site were below action levels, as mandated by the HBFD. PCAC(A)-11 Please refer to Response to Comment PCAC(A)-10 on page 3-248 for a discussion of potential groundwater contamination related to BTEX at the project site. PCAC(A)-12 This comment provides information about current research, and incidences of cancer within the City of Huntington Beach. This comment does not address the adequacy of the Draft EIR, and no further response is required. PCAC(A)-13 Please refer to Response to Comment PCAC(A)-10 on page 3-248 for a discussion of issues related to groundwater contamination. In addition, the SARWQCB will require sampling of groundwater to confirm that contamination is below acceptable levels prior to their approval of the site. PCAC(A)-14 This comment correctly states information provided in the Draft EIR. According to the 2002 Remediation Plan (Revision 3), soil involved in the 1999 export to the Hyatt was excavated and remediated to meet the City Specification 431-92 criteria, as detailed in the closure report for the soil that was exported to the Hyatt site. Soil samples taken from the bottom and sidewalls of each excavation at the project site were taken to ensure that TRPH concentrations in the remaining soil were below City Specification 431-92 criteria. However, a closure report for these soils remaining on-site has not been submitted to the local oversight agency yet because, as detailed in Section 3.7 of the Draft EIR, other portions of the project site contain contamination that requires Pacific City EIR 3-249 Chapter 3 Responses to Comments remediation. Since a closure report is typically prepared once remediation has been completed on the entire site, it would not, therefore, be appropriate to submit a closure report until all contamination has been remediated. As such, the excavated soil was remediated at the project site, and once it was determined to be clean, it was exported to the Hyatt site. It was then tested a second time at the Hyatt site to confirm it was fully remediated. It is anticipated that contamination of remaining soil in the area where soil was exported to the Hyatt at the project site (referred to as "Area A" in the Draft EIR) has been remediated. However, until a closure report is submitted and approved, this cannot be confirmed. PCAC(A)-15 The closure report for the soil exported to the Hyatt site details that the exported soil was remediated. As such, no evidence of contaminated soil was found in any of the samples tested. However, this report for the Hyatt does not address soil remaining in the export area (Area A) on the project site. Documentation of the successful remediation of this area will be presented as part of the closure report to the City. Please refer to Response to Comment PCAC(A)-14 on page 3-249 for additional detail. PCAC(A)-16 As discussed on pages 3.7-7 through 3.7-8 of the Draft EIR, during the soil exporting activities for the Hyatt, Area A was sampled to identify whether oily soil was present. All affected soil exhibiting concentration above City Specification 431-92 criteria were either excavated from the site or mechanically treated to meet the criteria. PCAC(A)-17 Mixing of the soils is an accepted method of soil remediation by the City of Huntington Beach, the local oversight agency for this project. Soil mixing has been implemented as a successful method of remediation since the 1950s in the United States and has been technically proven to adequately remediate soils. The process of mixing includes blending contaminated soils on site with clean soils, in order to reduce the concentrations of the contamination in the soil. Soils are tested until it is demonstrated that contaminant concentrations fall below accepted levels. In order to ensure that all soils have been remediated, samples generally include soils taken from all depths and from several locations where remediation is occurring. PCAC(A)-18 These comments address potential non-compliance issues associated with the Robert Mayer Corporation and the Hilton and Hyatt developments, both located adjacent to the project site. The Robert Mayer Corporation is not affiliated with the proposed project. In addition, there is no relationship between proposed development that 3-250 City of Huntington Beach Chapter 3 Responses to Comments would occur in the future at the project site and suspected non-compliance issues at the adjacent Hilton and Hyatt sites. Please refer to Response to Comment HBEB-21 on page 3-209 for a discussion of monitoring during the construction phase of the proposed project. PCAC(A)-19 Please refer to Response to Comment Churchin-2 on page 3-327, which clarifies issues related to remediation of soils exported to the Hyatt site. Please refer to Response to Comment PCAC(A)-14 on page 3-249 for a discussion of documentation for remediated soils as part of the export of soils to the Hyatt site. The Fire Department was aware that contamination was identified in soils to be exported to the Hyatt site, and, as a result, remediation of these soils was required prior to their export to the Hyatt site. PCAC(A)-20 The source for Figure 3.7-1 on page 3.7-8 of the Draft EIR is the Remediation Plan Revision 3, not the 1996 Phase II Study. Conclusions identified in the 1996 Phase II Study have been superceded by information in Remediation Plan Revision 3, prepared by Harding ESE. PCAC(A)-21 Please refer to Responses to Comments Churchin-4 on page 3-328 and Churchin-5 on page 3-329 for a discussion of contamination resulting from the former gas plant. Page 3.7-5 of the Draft EIR has been updated to clarify that no gas plant was located adjacent to the site. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. PCAC(A)-22 The statement on page 3.7-5 of the Draft EIR discusses potential contaminants from the former gas plant. However, as discussed in Responses to Comments for Churchin-4 on page 3-328 and Churchin-5 on page 3-329, no gas plant was formerly located adjacent to the site, and page 3.7-5 of the Draft EIR has been revised to reflect this updated information. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. The contaminants referred to on page 3.7-18 of the Draft EIR are related to petroleum hydrocarbons. Therefore, these statements refer to two separate issues and do not contradict each other. The analysis presented in the Draft EIR relies on the most current studies completed for the site. Mitigation Measure HAZ-4 on page 3.7-21 of the Draft EIR requires that, before construction can commence in these areas, a closure report or other document as deemed acceptable by the City Fire Department be submitted to demonstrate that soils on site in all areas have been effectively remediated. Pacific City EIR 3-251 Chapter 3 Responses to Comments PCAC(A)-23 Please refer to Response to Comment Churchin-3 on page 3-327 for a discussion of the results of the 1996 investigation compared to the 1999 investigation. The site did not become more contaminated over time. PCAC(A)-24 A detailed report on the 1999 sampling effort has not been submitted to the City. The results of this sampling effort are identified on the Plates 2 and 3 of Remediation Plan, Revision 3 prepared by Harding ESE, identified as Harding ESE 2002b in the references section of the Draft EIR. Plates 2 and 3 also identify the locations where soil samples were taken. PCAC(A)-25 Mitigation Measure HAZ-4 on page 3.7-21 of the Draft EIR requires that the area surrounding the water main be remediated in accordance with City specifications and that a closure report or other reports as deemed acceptable by the City Fire Department document successful completion of required remediation are approved prior to the issuance of grading permits. PCAC(A)-26 Data used to prepare Section 3.7 (Hazardous Materials) of the Draft EIR were taken from several previously completed and City-approved studies for the site. Perception of misleading, incomplete, or contradictory data in these reports are clarified by the responses to comments presented throughout this document. None of the reports relied upon for making conclusive determinations as to the level of on-site contamination were authored by individuals convicted of submitting fraudulent test results. PCAC(A)-27 MM HAZ-1 through HAZ-6 on pages 3.7-20 through 3.7-21 of the Draft EIR require that, prior to the issuance of a grading permit, all impacts associated with soil contamination at the project site be mitigated to an level acceptable to the City Fire Department, the local oversight agency for the project. MM HAZ-7 and HAZ-8 on pages 3.7-21 through 3.7-22 of the Draft EIR ensures that DOGGR would be involved in addressing potentially significant impacts associated with damage to existing abandoned oil wells at the project site. These mitigation measures ensure that the proposed project would not be adversely impacted by any existing soil contamination at the project site. No subsequent study or documentation is necessary. 3-252 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter PCAC (B) (Pacific City Action Coalition, Attachment B, December 3, 2003) PCAC(B)-1 The traffic study, included as Appendix H to the Draft EIR, was prepared to analyze future traffic conditions resulting from implementation of the proposed project on the nearby street network. As such, the geographical scope of the traffic study included Delaware Street, which is located in proximity to the project site to the east. However, the planned traffic improvements for the project, as discussed on pages 3.14-30 and 3.14-37 of the Draft EIR, do not include the extension of Delaware Street. Although this extension may eventually occur, it would occur independently of this project and would require additional studies/review at that time. Please refer to Response to Comment PCAC-54 on page 3-240 for further information on the Delaware Street extension. PCAC(B)-2 Comment noted. PCAC(B)-3 The Draft EIR is a public information document intended to disclose potentially significant environmental impacts associated with the planning, construction, and operation of the proposed project. No mobile homes would be displaced and/or taken as a result of the proposed project. PCAC(B)-4 Comment noted. Please refer to responses to specific concerns identified below. PCAC(B)-5 Improvements to Huntington Street, Atlanta Avenue and Pacific View Avenue are described on Table 2-8, pages 2-20 through 2-22, page 3.14-30 and 3.14-37 of the Draft EIR and on page 62 of Appendix H (the traffic study). With respect to improvements or extension(s) of Delaware Street and the mobile home park entrance/exit, no improvements to Delaware Street or the mobile home park entrance/exit are necessitated by the proposed project, and none are planned in conjunction with the project. An extension of Delaware Street south of Atlanta Avenue to PCH is identified in the City's MPAH, Circulation Element (Figure CE-13), and Precise Plan of Street Alignment 70-3, which was approved by Huntington Beach City Council through Ordinance No. 1581. Implementation of this improvement is currently not programmed. However, as the Delaware Street extension is identified as a long-range Pacific City EIR 3-253 Chapter 3 Responses to Comments improvement in the City and is considered part of the buildout street system, it is appropriate to include this improvement in the General Plan buildout scenario for traffic. Approval of the proposed project would not affect the potential for the Delaware extension to be implemented. PCAC(B)-6 No mobile homes would be displaced and/or taken as a result of the proposed project. PCAC(B)-7 Project access is addressed on pages 2-20 through 2-26, Impact TR-9 on pages 3.14-72 through 3.14-75 of the Draft EIR text, and pages 7 and 8 of Appendix H (Traffic Study). As discussed under Impact TR-9, adequate driveway and queuing access for the proposed project would be provided, and impacts associated with vehicular access to the project site would be less than significant. PCAC(B)-8 Please refer to Response to Comment PCAC(B)-7 above for a discussion of project access. PCAC(B)-9 Figures 2-3a through 2-3d on pages 2-9 through 2-12 of the Draft EIR illustrate how buildings would be setback from the street. Appendix F, Specific Plan Conformity, addresses project conformity with the Specific Plan, including building setbacks. The proposed project would not result in development within the roadway that would restrict the flow of traffic. PCAC(B)-10 The mobile home park land use designation is intended to remain as such and would not change as a result of the proposed project. PCAC(B)-11 The project timefi ame is addressed on pages 2-26 through 2-27 of the Draft EIR. PCAC(B)-12 The Draft EIR is a public information document intended to disclose potentially significant environmental impacts associated with the planning, construction, and operation of the proposed project. This comment does not contain input on the adequacy of the Draft EIR, and, as such, no further response is required. PCAC(B)-13 The extension of Delaware Street is not part of the proposed project. This change in the City network is currently identified in City planning documents and was addressed at a program level in City's General Plan EIR but would not be implemented by the proposed project. Please refer to Response to Comment PCAC-54 on page 3-240 for further information on the Delaware Street extension. 3-254 City of Huntington Beach Chapter 3 Responses to Comments PCAC(B)-14 No mobile homes would be displaced and/or taken as a result of the proposed project. PCAC(B)-15 Please refer to Response to Comment PCAC-73 on page 3-244 for a discussion of street widening. No easements are proposed or required within the adjacent mobile home park as a result of the proposed project. PCAC(B)-16 A traffic signal is not warranted at Huntington Street and Pacific View Avenue as discussed under Impact TR-6 on pages 3.14-67 through 3.14-68 of the Draft EIR. With respect to the configuration of Pacific View and Huntington Street, the roadway improvements related to the proposed project are identified on pages 2-20 through 2- 22, 3.14-30, and 3.14-37 of the Draft EIR. PCAC(B)-17 Street improvements that would occur as part of the proposed project are discussed on pages 2-20 through 2-22, 3.14-30, and 3.14-37 of the Draft EIR. Construction-level plans are not available at this stage of the project. PCAC(B)-18 The proposed project is not responsible for analyzing any potential parking issues identified for adjacent projects, including the Waterfront Hilton. Issues related to the Waterfront Hilton identified in this comment are a City enforcement issue and not related to the proposed project. As discussed in Section 2.2.1 on page 2-4 of the Draft EIR, the southwest corner of the site was recently used as a temporary staging/storage facility for beach cleaning equipment and employee vehicles for the City of Huntington Beach. The proposed hotel is designed with loadingareas consistent with Citycode P P z�' requirements, which would accommodate moving vans for convention equipment. Adequate loading areas would be provided on-site for tour buses in the hotel drop-off area. Since tour buses would arrive on rare occasions and generally not during the peak time of day, this was not considered within the typical weekday analysis. PCAC(B)-19 No homes would be displaced and/or taken as a result of the proposed project. PCAC(B)-20 Increased traffic on PCH is addressed in the Draft EIR as part of the circulation/traffic analysis, as described under Impacts TR-1 through TR-5 on pages 3.14-58 through 3.14-67 of the Draft EIR. Pacific City EIR 3-255 Chapter 3 Responses to Comments Please refer to Response to Comment CNB-13 on page 3-196 for a discussion of impacts to intersections in the City of Newport Beach. Please refer to Response to Comment CNB-14 on page 3-196 for a discussion of issues related to the Banning/19`h Street Bridge. PCAC(B)-21 Consistent with Section 15126 of the CEQA Guidelines, the Draft EIR examines the project-specific impacts of implementing the proposed project. With respect to biological resources, the analysis was based, per CEQA Guidelines Section 15126.2, on the physical conditions in the affected area, as they exist at the time of the publication of the notice of preparation. The site was in mid-remediation phase at that time. Impacts were based on biological surveys that documented the biota that occurs within the site during both December 2001 and September 2003. As a result of the remediation process, which includes earth moving activities, conditions at the site are somewhat dynamic. However, the conditions present during these surveys represent the range of conditions at the time the notice of preparation was published. The analysis of wetlands was adequately addressed in the EIR in compliance with CEQA Guidelines. As stated in CEQA Guidelines Section 15204(a), the adequacy of an EIR is determined in terms of what is reasonably feasible in light of factors such as the geographic scope of the project, the magnitude of the project, and the severity of the likely environmental impacts. As further expressed in Section 15151 of the CEQA Guidelines, "the courts have looked not for perfection but for adequacy, completeness, and a good faith effort at full disclosure." In this case, to assess the potential biological impacts of the proposed project, an initial biological survey was performed during the initial phases of project development. An additional survey was then performed in 2003 when wetland vegetation was found in the area of the remediation pits. Two surveys of the site were performed, in a manner sufficient to allow for the quantification of impacts to biota. Therefore, this effort represents a good faith effort at full disclosure of -- potential biological impacts of the proposed project. Furthermore, the California Department of Fish and Game (CDFG), U.S. Fish and Wildlife Service (USFWS), and California Native Plant Society (CNPS) do not require that the surveys are conducted during blooming season, just that they are "Conducted in the field at the proper times of year when special status and locally significant plants' are both evident and identifiable." 3-256 City of Huntington Beach Chapter 3 Responses to Comments The commenter also provides information stating that the Applicant was stopped from grading the property in September 2003. This comment does not address the adequacy of the Draft EIR and no further response is required. PCAC(B)-22 Please refer to Response to Comment Cross-2 on page 3-313 for a explanation as to why widening Huntington Street beyond project specifications is not warranted. The proposed project would not encroach onto the adjacent Mobile Home Park. PCAC(B)-23 Please refer to Response to Comment HBT-8 on page 3-211 for an explanation as to why widening Atlanta Avenue beyond project specifications is not warranted. The proposed project would not encroach onto the adjacent Mobile Home Park. PCAC(B)-24 Please refer to Response to Comment PCAC-54 on page 3-240 for a discussion of the relationship of the Delaware Street extension to the proposed project and the traffic analysis. The commenter provides additional opinion about this future improvement. This comment, however, does not address the adequacy of the Draft EIR and no further response is required. PCAC(B)-25 The Draft EIR is a public information document intended to disclose all potential environmental impacts associated with the planning, construction, and operation of the proposed project. As such, information on impacts to the adjacent mobile home park is given throughout the Draft EIR. PCAC(B)-26 The project is in compliance with the permitted residential densities of Downtown Specific Plan (DTSP) District 84. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration when deciding whether to approve or deny the proposed project. PCAC(B)-27 As stated in Impact AES-2 on page 3.1-30 of the Draft EIR, views from surrounding residences are from private locations; affects to these views would not be considered significant. Therefore, no further mitigation is required. The project site is zoned as DTSP Districts 7 and 8A, which indicates that the City has intended the property for downtown, coastal development. Also, as stated on page 3.1-26 of the Draft EIR in project consistency for Policy ERC-4.1.5 (Table 3.1-2), there are no public view corridors from or through the project site. View corridors near the project site include First Street and Huntington Street; however, neither of these streets would be narrowed as a result of the proposed project. In addition, pedestrians accessing the Pacific City EIR 3-257 Chapter 3 Responses to Comments project site would have views of the ocean, which would be far more expansive than those currently available. Please refer to Responses to Comments Cross-1 on page 3- 313 and Cross-5 on page 3-315 for additional detail. PCAC(B)-28 The commenter does not provide any basis or evidence for the need for a new traffic study. The study prepared is consistent with CEQA requirements and City guidelines with respect to traffic impact analysis. The study has been independently reviewed and affirmed through peer review. Therefore, a new traffic study is not warranted. PCAC(B)-29 The project does not propose to use the mobile home park and/or other adjacent properties for a solution for parking or related issues. The mobile home park is not identified in the Draft EIR as a source of parking for the proposed project. 3-258 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter PCAC (C) (Pacific City Action Coalition, Attachment C, December 3, 2003) PCAC(C)-1 Please refer to Response to Comment PCAC-81 on page 3-245 for a discussion of amplified noise. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration when deciding whether to approve or deny the proposed project. PCAC(C)-2 The project would dedicate a 20-foot-wide public access corridor through the entire project site. Please refer to Response to Comment HBEB-5 on page 3-205 for further discussion regarding public access. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration when deciding whether to approve or deny the proposed project. PCAC(C)-3 Additional discussion has been added to the Draft EIR to identify the potential for lighting directed upwards onto building facades in a manner that would result in nighttime illumination effects. An additional mitigation measure has been recommended in the Final EIR to including lower lighting levels during periods of fog, in order to reduce nighttime illumination from the project site. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. PCAC(C)-4 These comments address potential non-compliance issues associated with the Robert Mayer Corporation and the Hilton and Hyatt developments, located adjacent to the project site. The Robert Mayer Corporation is not affiliated with the proposed project. In addition, there is no relationship between proposed development that would occur in the future at the project site and alleged non-compliance issues at the adjacent Hilton and Hyatt sites. Please refer to Response to Comment HBEB-21 on page 3-209 for a discussion of monitoring during the construction phase of the proposed project. PCAC(C)-5 Please refer to Response to Comment Cross-14 on page 3-319 for a discussion of the project schedule. Impacts to noise and water quality would be reduced to less-than- significant levels during construction activities. Mitigation measures have been identified in the Draft EIR to reduce air quality impacts to the extent feasible. PCAC(C)-6 As stated on page 4-26 of the Draft EIR, a reduction in the density of residential units would reduce the severity of impacts, but would not lessen any significant impacts to Pacific City EIR 3-259 Chapter 3 Responses to Comments less-than-significant levels. Please refer to Response to Comment RMC-33 on page 3- 276 for further detail. PCAC(C)-7 Pedestrian access improvements are described on pages 2-23 and 2-26 of the Draft EIR. In addition, Figure 2-7 on page 2-25 of the Draft EIR illustrates that sidewalks are proposed along all street frontages. As discussed on page 3.14-37 of the Draft EIR, during project implementation, a 20-foot-wide pedestrian access easement would be dedicated through the project site that extends from the south side of Atlanta Avenue, at Alabama, to Pacific View Avenue at the easterly residential access driveway. Linkages are also proposed from the residential village through the visitor-serving commercial component of the project site. In addition, please refer to Response to Comments Verbal-23 on page 3-323, and PCAC-65 and PCAC-66 on page 3-242 for additional discussion of sidewalks on Atlanta Avenue, pedestrian access availability, and bicycle lanes, respectively. PCAC(C)-8 The proposed residential portion of the project site complies with the balance of uses permitted in the Downtown Specific Plan (DTSP), and is intended to establish a population base to help support the commercial uses of the project. This comment is acknowledged, and the opinion of the commenter will be provided to the decision- makers for review and consideration when deciding whether to approve or deny the proposed project. PCAC(C)-9 Please refer to the Topical Response on Shared Parking on page 3-180 for an explanation of why the methodology used for the parking analysis is appropriate. Inconveniences and/or inadequacies identified in this comment related to existing commercial and residential uses, including parking issues related to the Hyatt, are not an impact of the proposed project, and thus an analysis and mitigation of this issue is not required. This comment expresses several opinions about the adequacy of the parking and the relationship of street and single level parking to a feeling of open space and quality of life. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. PCAC(C)-10 The project as proposed includes signalization at the intersection of Atlanta Avenue and Huntington Street, as identified in Table 2-8 and page 2-21 of the Draft EIR. The Traffic Impact Analysis Report, included as Appendix H of the Draft EIR, indicates that 3-260 City of Huntington Beach Chapter 3 Responses to Comments the proposed project's fair share contribution to this signal would be 59 percent based on traffic volume. In addition, MM TR-3 on page 3.14-80 of the Draft EIR, requires the installation of a traffic signal at the intersection at First Street and Atlanta Avenue prior to the issuance of occupancy permits. The City would ensure completion of this improvement, and the Applicant would be required to contribute a fair share contribution of 57 percent to the improvement. PCAC(C)-11 Impact AQ-3 on pages 3.2-13 through 3.2-15 of the Draft EIR discusses the issue of carbon monoxide (CO) hotspots resulting from decreased levels of service at intersections in the future. Emissions from the PCH and Warner Avenue intersection were included in this analysis. CO hotspots would not exceed National or State standards at 25, 50, or 100 feet. CO concentrations would be further dispersed at locations beyond 100 feet, including the Bolsa Chica area. PCAC(C)-12 The Year 2020 traffic analysis does include the extension of Delaware Street and installation of the Banning/19`h Street Bridge because they are both currently contained in the City of Huntington Beach General Plan and Orange County MPAH. The traffic study also included a scenario without the Banning/19`h Street Bridge. Please refer to Response to Comment HBT-10 on page 3-211 for additional discussion of this issue. Please see Response to Comment PCAC-54 on page 3-240 for further information on the Delaware Street extension. PCAC(C)-13 Impact PS-3 on pages 3.12-11 through 3.12-12 of the Draft EIR describes that development of additional residential units would result in an increase in the number of students within the school districts serving the site and increase demands on school facilities. Cumulative impacts to schools, as discussed on page 3.12-14 of the Draft EIR, describe the projected impacts of the project in combination with planned future development in the area. Therefore, this issue has been adequately addressed in the EIR. PCAC(C)-14 As illustrated in the Draft EIR, the project consists of two levels of subterranean garages (in order to alleviate impacts to surface parking) and consists of structures that range from two to four stories in height, excepting the height of the eight-story hotel. Refer to Response to Comment Cross-5 on page 3-315 for detail. I Pacific City EIR 3-261 Chapter 3 Responses to Comments PCAC(C)-15 The nearest freeway access to the SR-55 is significantly outside the study area, located approximately 6 miles from the project site, and is not required to be analyzed based on the size and location of the proposed development. This is consistent with the City of Huntington Beach guidelines and standard traffic impact analysis methodology. 3-262 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter RMC (Robert Mayer Corporation, December 3, 2003) RMC-1 Comment noted. RMC-2 As discussed on page 2 of the Notice of Availability (NOA), the Draft EIR determined that implementation of the proposed project would result in "Significant, unavoidable impacts" in the following issue areas: • Air Quality • Transportation/Traffic The NOA does also state that other potentially significant impacts in the issue area of Transportation/Traffic could be mitigated to a less-than-significant level. It should be noted that in the issue area of Transportation/Traffic, there are several individual impacts associated with this resource area. Each impact is classified with respect to its level of significance, and it is possible, and common with most projects, for different impacts under the same resource to be identified with different levels of significance. RMC-3 The traffic impact analysis for the Waterfront Ocean Grand Resort (i.e., the Hyatt Hotel), dated July 2, 1998, indicates that a traffic signal is anticipated as a future condition at the intersection of Atlanta Avenue and Huntington Street. The project as proposed includes signalization at the intersection of Atlanta Avenue and Huntington Street, as identified in Table 2-8 and page 2-21 of the Draft EIR. The Traffic Impact Analysis Report, included as Appendix H of the Draft EIR, indicates that the proposed project's fair share contribution to this signal would be 59 percent based on traffic volume. In addition, MM TR-3 on page 3.14-80 of the Draft EIR, requires the installation of a traffic signal at the intersection at First Street and Atlanta Avenue prior to the issuance of occupancy permits. The City would ensure completion of this improvement, and the Applicant would be required to contribute a fair share contribution of 57 percent to the improvement. RMC-4 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of the trip generation. The internal capture rates are generally based on Tables 7.1 and 7.2 in the ITE Trip Generation Handbook (October 1998) and have been adjusted based on the specific project characteristics. These internal capture reduction Pacific City EIR 3-263 Chapter 3 Responses to Comments values based on the ITE methodology are considered guidelines for determining appropriate reductions and can be adjusted to reflect unique project characteristics. RMC-5 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of why the mode shift is appropriate to use. The mode shift percentages conform to ITE recommendations and reflect traffic engineer and City experience with the unique combination of the proposed project's mixed-use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. Mode shift can refer to walking, as noted in the comment, which is the primary visitation mode besides the automobile. City experience indicates that it is typical for some individuals to drive to the general area, park once, then access a number of uses in the Downtown area, rather than driving between each of these locations situated within close proximity (i.e., less than 1 mile) of each other. It is reasonable to assume that customers would walk 1/2 mile, which takes approximately 9 to 10 minutes. Several parking facilities within the Downtown area are well within walking range of the proposed project(1/4 to 1/2 mile). This comment correctly defines walk-in traffic on a daily and hourly basis. However, over a ten hour (i.e., daily) period and one hour PM peak period, the walk-in traffic equates to approximately five people per minute and six people per minute, respectively, dispersed throughout the total 240,000 square feet of development. RMC-6 The commenter correctly notes, as stated on page 35 of the Downtown Specific Pla n (DTSP), that "Development in this District is not intended to compete with the Downtown commercial core...," and rather, "The commercial uses in this District would be of a more seasonal variety with the District serving as a connecting link between the Downtown area and District Nine," which is the area east of Huntington Street where the Hilton Waterfront Beach Resort is located. Thus, as stated in the Draft EIR, the proposed project is not intended or anticipated to compete with the Downtown commercial uses, and instead, is designed to complement the existing uses in the Downtown area. Many downtown patrons walk from the Pier/Pier Plaza to the 4th or 5th block of Main Street and can be reasonably expected to walk from Main Street or the Pier Area 4 or 5 blocks to Pacific City. Consequently, since the project serves as the "connecting link" to the Downtown area, some shared patronage could reasonably be assumed and is factored into the traffic analysis for the proposed project. 3-264 City of Huntington Beach I Chapter 3 Responses to Comments RMC-7 The Downtown area experiences a significant amount of restaurant patronage from beach goers, and the proposed project is envisioned to include restaurants and other commercial uses that accommodate beach goers. The restaurants included as part of the visitor-serving commercial uses at Pacific City would be different from the restaurants contained in the proposed hotel and the existing Hyatt hotel. For restaurants located outside of hotels and adjacent to the beach, typically more beach users would be anticipated to access these restaurants than those located inside of hotels. In addition, beach goers represent a portion of the total restaurant patrons. RMC-8 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of the trip generation. Elimination of the internal capture and mode shift would be inconsistent with prudent traffic engineering practice, would significantly overstate the project traffic generation forecast, and, therefore, would result in unrealistic impacts. RMC-9 Although the Development Agreement allows for a third hotel, the hotel is subject to the approval of a Conditional Use Permit (CUP) and Coastal Development Permit (CDP) as well as required environmental documentation. No proposal, application, or other project submittal related to project entitlement on the Waterfront's third hotel site has been provided to the City, and until such time, that hotel could be modified in scope or character by the developer consistent with the procedures set forth in the amended Development Agreement. Because no information indicating that this project would be developed in the reasonably foreseeable near future was available, this project was not included in the Year 2008 analysis. However, the hotel development is included in the General Plan Buildout analysis included in the Draft EIR, and no new impacts, beyond those identified in the Draft EIR, are indicated as a result of its inclusion. RMC-10 Please refer to the Topical Response on Shared Parking on page 3-180 for a discussion of demand and shared-use calculations. The shared parking analysis does separately include the ballroom area and spa services, as identified in columns 3 and 4 of Tables 5A and 5B in the Shared Parking Analysis. The weekday and weekend parking demand profile (i.e., the percentage of spaced occupied at a given time) for the hotel guest room was increased from LILI's recommended use of 30 percent of the peak parking demand to 75 percent of the peak parking demand for the 1:00 pm hour to account for guest use of the meeting space area. Pacific City EIR 3-265 Chapter 3 Responses to Comments The DPMP requirements do not apply to the project site because the site is outside of the DPMP boundaries (see Section 4.2.14 of the DTSP). The information contained within the specified table of the traffic study was included for comparative purposes. However, based on the mix of uses proposed (e.g., hotel), the project is not identical to retail or restaurant uses within the DPMP area, and thus, parking for the project can not be based on the DPMP parking rates.- RMC-11 Please refer to the Topical Response on Shared Parking on page 3-180. The empirical data used in the shared parking analysis are from the Ritz Carlton, Laguna Niguel, and Marriott Laguna Cliff, which, like the proposed Pacific City hotel, are located in proximity to the beach. The parking analysis does not include any internal capture reduction, and the mode shift percentages reflect the unique combination of the proposed project's mixed-use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. There is no double discount in the parking analysis. The parking demand requirements were adjusted for guest and non-guest usage for the hotel restaurant, conference rooms, and spa based on experience with prior resort hotel shared parking studies. The weekday and weekend parking demand profile for hotel guest rooms was increased from LILI's recommended use of 30 percent of the peak parking demand to 75 percent of the peak parking demand for the 1:00 PM hour to account for guest use of the meeting space area. This adjustment provides approximately 200 additional spaces in the peak parking demand hour, beyond LILI's recommended 1:00 pm peak demand, for guest use of other amenities. The mode shift considers persons in the area that have parked elsewhere (the beach or Downtown core) and accessed the site. Conversely, the shared parking analysis considers the fact that different uses on-site have variations in the peak hour of parking, and can share parking spaces. As such, no double discount has occurred, since these are separate accepted methods for determining adequate project parking demand. RMC-12 Please refer to the Topical Responses on Traffic Generation on page 3-176 and Shared Parking on page 3-180 for a discussion on parking demand from hotel amenities due to non-guest use and the mode shift application to the proposed project. RMC-13 Several parking facilities within the Downtown area are well within walking range of the proposed project ('/4 to 1/2 mile), which can reliably be considered as a factor in the parking study calculations. It is reasonable to assume that customers would walk '/z 3-266 City of Huntington Beach Chapter 3 Responses to Comments mile, which takes approximately 9 to 10 minutes. The parking analysis does not assume that the project is located within the Downtown Master Parking Plan boundaries,but in proximity to the Downtown core, which would result in interaction with this area. Thus, a mode shift is applied to account for use of the site by persons already in the Downtown area. Please see the Topical Response on Traffic Generation on page 3-176 for a discussion of mode shift. RMC-14 Please refer to the Topical Response on Shared Parking on page 3-180. The parking analysis recognizes the fact that interaction with the beach is obvious during certain periods of the day, because some visitors to the beach would also access the proposed project, and this is captured in the mode shift assumptions. Beach parking is not relied on to satisfy parking demands of the proposed project. Rather, the analysis acknowledges the expectation that patrons with a primary purpose of visiting the beach would also patronize the proposed project. RMC-15 The empirical data used in the shared parking analysis are from the Ritz Carlton, Laguna Niguel, and Marriott Laguna Cliff, which, like the proposed Pacific City hotel, are located in proximity to the beach. Based on the characteristics of the proposed hotel and these two other hotels in Orange County, use of this data is appropriate and reliable. The proposed meeting space area is not significant in size and would not accommodate large conferences or weddings equivalent to those typically provided at the Hyatt or Hilton hotels. The traffic study lists the ballroom area as 16,000 sf, the net usable meeting/banquet/ballroom area is only approximately 9,300 sf. The actual square footage is a small portion of the 370,000 sf of the hotel, and substantially less than the 52,000 square feet of ballroom area provided at the Hyatt and 19,000 square feet of ballroom area provided at the Hilton. Furthermore, weddings and other large social/charitable events most frequently occur on the weekend, which is not the peak parking demand period, and therefore, even if the proposed hotel had a large enough meeting space area, such uses would not exceed the peak parking demand period that has been analyzed. Nevertheless if the weekend parking analysis resulted in ballroom use of 15 sf per person, then the total parking demand would be 1,440 spaces and would remain less than the weekday maximum requirement. Finally, the Draft EIR traffic and parking analyses did not use average situations for the parking analysis. As indicated on page 3.14-17 of the Draft EIR, the shared parking calculations recognize that different uses often experience individual peak parking demands at different times Pacific City EIR 3-267 Chapter 3 Responses to Comments of day, or days of the week. When uses share a common parking footprint, the total number of spaces needed to support the collective whole is determined by adding parking profiles (by the time of day or day of week), rather than individual peak ratios as represented in the City of Huntington Beach Zoning and Subdivision Ordinance (ZSO, Chapter 231—Off-Street Parking and Loading Provisions). The shared parking methodology is applicable to the proposed project because the individual land uses (i.e., retail, restaurant, hotel, and office uses) experience peak demands at different times of the day. The base parking demand ratios are consistent with City code and are all design ratio demands without any reductions for seasonal variations. RMC-16 The parking profile percentages in Tables 5A and 5B are not occupancy rates but rather parking demand profiles as a percentage of peak demand by time of day, based on ULI Shared Parking data. In fact, ULI recommends a 30 percent parking demand for 1:00 PM on both a weekday and weekend, but the parking study has adjusted the percentages to 75 percent and 60 percent use of peak demand of spaces at 1:00 PM (also at 11:00 AM, 12:00 PM, and 2:00 PM) on the weekday and weekend, respectively, to remain conservative and to account for hotel guests attending meetings/events in the hotel. The weekend period is not the peak period for parking, primarily because office uses would not generate substantial parking demand on the weekends. RMC-17 While the traffic study and Project Description in the EIR list the ballroom area as 16,000 sf, the net usable meeting/banquet/ballroom area is approximately 9,300 sf. The remaining area is pre-function, banquet office, and kitchen area. Therefore, the Project Description is correct and no text change is warranted. RMC-18 The proposed banquet area, at 16,000 sf, represents a small portion of the total 370,000 sf of the hotel. The trip generation of 30 sf per person reflects a typical weekday event, which is the peak parking demand period for the project (1:00 PM). The 2.5 persons per car ratio is based on the empirical data collected at the Marriott Laguna Cliff hotel. The parking code does not require the banquet and spa uses to be included as separate components for parking because the code requirement for a typical hotel rate already includes ancillary uses. However, the shared parking analysis does calculate these uses separately as a prudent and conservative measure. As discussed under Response to Comment RMC-15 on page 3-267, if ballroom use of 15 sf per person is applied, then total parking demand would be 1,440 spaces and would remain 3-268 City of Huntington Beach Chapter 3 Responses to Comments less than the weekday maximum requirement. This information does not affect the conclusions of the EIR. RMC-19 The hotel component would not consist entirely of valet parking. Only a portion of the patrons would be anticipated to use valet services, so not all spaces needed for the hotel valet would need to be reserved. In addition, the parking management plan would ensure that garage capacity is monitored, so that if additional spaces reserved for valet are needed for self-park, these could be made available. Therefore, valet parking would not affect the shared parking supply. RMC-20 Page 2-20 (Table 2-8) of the Draft EIR states that the "ultimate condition" of the proposed project would not have angled parking. However, page 3.14-26 of the Draft EIR provides a summary table (Table 3.14-8) of the applicable transportation/traffic policies in the General Plan Circulation Element. Table 3.14-8 indicates that the project would be consistent with Policy CE 6.1.6 by obtaining an exception to allow for diagonal parking on Pacific View Avenue. The text has been revised to eliminate the discussion of angled parking to clarify this issue. In addition, page 3.14-70 of the Draft EIR provides a figure (Figure 3.14-15) of proposed street parking. Figure 3.14-15 depicts 39 angled spaces along the south side of Pacific View Avenue. The text on page 3.14-71 of the Draft EIR has been revised to indicate parking would occur in the short term only. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. This parking would be removed in the long term, and the impacts of the design presented in the Draft EIR are appropriately analyzed. RMC-21 The roadways adjacent to the proposed project, which include Pacific View Avenue, have been designed with standard lane widths (minimum of 12-foot through lanes and 18-foot curb lanes) that can accommodate emergency vehicles. The Final EIR has been revised to clarify that the potential constraints to emergency access are related to pedestrian, not vehicular, access. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. RMC-22 As standard practice, the City Fire Department reviews all building plans to ensure conformance with City standards, including site accessibility. CR PS-C identified on page 3.12-15 of the Draft EIR requires compliance with Fire Department Specifications for fire access roads. The intent of the discussion under Impact TR-9 on pages 3.14-72 through 3.14-75 of the Draft EIR is that the design features of the 10 project access Pacific City EIR 3-269 Chapter 3 Responses to Comments driveways (shown in Table 3.14-18) would ensure adequate driveway and queuing access during project operation. The discussion under Impact TR-9 has been modified - to include a discussion of project impacts to emergency access roads. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. The conclusions of the analysis, however, would not significantly change as a result of this addition. Impact PS- 1 discusses emergency access issues related to pedestrian Fire Department access to the site. Mitigation Measures PS-1 through PS-3 would be required to address these issues, and include provision of fire-rated stairs, ventilation systems, and monitoring systems on-site. I RMC-23 The reconfiguration of Pacific View Avenue to a 4-lane secondaryarterial would be � subject to a project condition requiring posting of a performance bond or other security by the Applicant to ensure future funding. Reconfiguration schedules would be based on the identified need for such modifications to occur. Reconfiguration would be triggered by other area development traffic analyses and observed incremental growth that reflect this need. RMC-24 Impact TR-9 on pages 3.14-72 through 3.14-75 of the Draft EIR analyzes the functionality of vehicular access driveways. The project intersections, roadways, and emergency routes have been properly designed by taking the project traffic and queuing calculations into consideration. Those vehicles accessing the retail/restaurant parking would enter the parking area on the west side of the main entrance, whereas hotel patrons would access the east side of the main entrance. The circular drive would be large enough to accommodate the minimal drop-off/pick-up traffic, as well as hotel traffic, without adversely affecting access. Also, please refer to Response to Comment RMC-21 on page 3-269 for a discussion of project impacts to emergency access. RMC-25 The design and operation of Pacific View Avenue includes a 17-foot eastbound and 18- foot westbound, through lane that would allow vehicles to back out of their parking space without significantly impacting through traffic. In addition, the diagonal parking is an interim condition, and the roadway would ultimately include two lanes of travel in each direction. RMC-26 The left turn pockets were designed to accommodate the peak hour left-turn volume consistent with the standard traffic engineering assumption of one foot of left turn pocket length for each peak hour left turn volume. Impact TR-9 on pages 3.14-72 3-270 City of Huntington Beach Chapter 3 Responses to Comments through 3.14-75 of the Draft EIR also addresses the functionality of vehicular access driveways. Please refer to Response to Comment RMC(A)-50 on page 3-298 for a discussion of angled parking on Pacific View Avenue. RMC-27 The General Plan buildout traffic volume forecast for Pacific View Avenue is based on the City's traffic model, which indicates that a minimal volume of Pacific Coast Highway (PCH) traffic would divert to Pacific View Avenue through the Pacific City site. In addition to the traffic diversion included in the traffic model, the analysis assumed that an additional 5 percent of traffic would divert onto Pacific View Avenue, in order to provide a conservative analysis. The roadway width, lane configurations, roadway connectivity, and traffic control on Pacific View Avenue would not encourage substantial diversion of trips from PCH to this roadway. RMC-28 LSA was retained by the City to conduct an independent review of the traffic study prepared by Linscott, Law and Greenspan. This review is part of an internal review and comment process for the preparation of the Draft EIR. LSA commented on a working draft of the traffic study, and their input was used to refine and revise the analysis. Similar to preliminary draft documents, this information is not typically part of the reference material for an EIR. RMC-29 Please refer to the Topical Response on Traffic Generation on page 3-176. As detailed in the Topical Response, the mode shift percentages conform to ITE recommendations and reflect the unique combination of the proposed project's mixed-use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. The City determined that the appropriate level of assurance and reasonability are reflected in the modeling; as described in the Topical Response, therefore, no further changes were made in response to the LSA report. RMC-30 Please refer to Response to Comment RMC-28 above for discussion regarding the inclusion of LSA's peer review of a working draft of the traffic report prepared for the project. As stated in the comments provided by LSA: "The traffic impact analysis represents a fair evaluation of the potential circulation impacts attributed to the proposed project as described.... The comments and the requested revisions do not materially alter the results of the impact analysis or the identification of appropriate project-related mitigation measures." Pacific City EIR 3-271 if Chapter 3 Responses to Comments Recirculation of a Draft EIR is required when "significant new information" is made available, as discussed in CEQA Guidelines Section 15088.5. Examples of significant new information identified in the CEQA Guidelines include (1) a new significant impact; (2) a substantial increase in the severity of an environmental impact; (3) a new alternative or mitigation measure that is considerably different than others previously analyzed, which the project proponents decline to adopt; or (4) fundamental and basic inadequacies and conclusory information in the Draft EIR such that meaningful public review was precluded. The lack of inclusion of the LSA report, which does not alter the conclusions presented in the Draft EIR, does not satisfy the criteria set forth in the Public Resources Code or CEQA Guidelines for recirculation; therefore, recirculation of the Draft EIR is not required. RMC-31 As noted in this comment, CEQA Guidelines Section 15126.6(a) states that an EIR must consider "a range of reasonable alternatives...which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project..." In identification of project alternatives, consideration is given to whether development of the project in a different location would reduce significant impacts. Since nearly all significant impacts can be reduced to less-than-significant levels through mitigation measures, the focus of the alternatives analysis is on significant and unavoidable impacts. Significant and unavoidable impacts from the proposed project are related to air quality and transportation. Impacts on these resources would occur even if the project were to be developed at a different location, as these impacts are related to specific project characteristics, not project location. Location of the project at another site could reduce impacts to the Warner Avenue/PCH and Seapoint Avenue/PCH intersection. However the total trip generation would be the same, and relocating the project to lessen impacts to these intersections would not necessarily eliminate traffic impacts of the project, as it is likely that any other location in the City would have impacts to intersection operations. Further, the construction activities would result in the same emissions, irrespective of project location, and mobile air emissions would be the same, since trip generation would be the same. Therefore, significant and unavoidable impacts would occur, even at an alternative location. The Draft EIR has been revised to include this additional discussion. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. 3-272 City of Huntington Beach Chapter 3 Responses to Comments Despite the inability of significant and unavoidable impacts to be reduced by an alternative location, the City considered whether an alternative location would be feasible in its efforts to adequately consider the range of alternatives. Key criteria used to identify alternative sites include its location and size. City project objectives reflect the goal of providing a mixed-use project in the City's Downtown area. Three of the six objectives identified by the City in Section 2.5 on pages 2-26 through 2.27 of the Draft EIR, relate to development in the Downtown area. In addition to project location, the size of the site and the proposed development limit the number of alternative sites that would be available. While a project of a reduced scale could be constructed on a smaller parcel, in order to achieve the residential and commercial goals of the project, it would need to be large enough to accommodate both of these project components. In addition to location and size, both residential and commercial uses must be permitted at an alternative site in order to meet basic project objectives related to commercial and residential development. This comment notes that it is possible for a general plan amendment/zone change to occur at an alternative location. The City General Plan and Zoning Code are the "blueprint" for development within the City and guide land use decisions made within the City. A general plan amendment and zone change would modify this blueprint, and while this is permitted, it would result in land use implications beyond the site itself and potentially intensify impacts. Changes to the General Plan and Zoning Code could affect specific development locations, intensity, and balance of land uses within the area. Three parcels are located near the Downtown area that are large enough to accommodate uses proposed by the project. These include (1) the Nesi Ascon site, which is discussed in Section 4.3.1 on pages 4-24 through 4-25 of the Draft EIR; (2) the Cenco property located immediately northwest of the Nesi Ascon site; and (3) the AERA property at PCH and Goldenwest. The Nesi Ascon site is discussed on pages 4-24 through 4-25 of the Draft EIR. This site would not meet basic project objectives because it is located outside of the Downtown area. With respect to remediation of the Nesi Ascon site, there are major differences between the hazardous materials on the project site and the Nesi Ascon site. Remediation at the Nesi Ascon site would be more extensive, due to the type of contamination at this site from its former use as a landfill that accepted hazardous Pacific City EIR 3-273 Chapter 3 Responses to Comments waste. In addition, remediation is well underway at the project site, and it has not yet been initiated at the Nesi Ascon site, which would extend the timeframe under which development could occur. Economic effects are not considered a determining factor in consideration of this alternative. Rather, the lack of allowed commercial uses would preclude these types of uses from occurring on the project site, and eliminate achieving project objectives related to expanding hotel, retail, and entertainment opportunities and providing economic growth and employment opportunities in the City. Given that the project site has been designated for the same type and intensity of use in the City General Plan and DTSP, and remediation is underway, it is appropriate for development to be considered on the project site without further consideration of the Nesi Ascon site as an alternative location for the project. A discussion of the Cenco property located immediately northwest of the Nesi Ascon site and the parcel at PCH and Goldenwest, both of which would be large enough to accommodate the proposed project but were otherwise deemed infeasible, has been added to the Final EIR. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. The Cenco property is adjacent to wetlands, zoned for Limited Industrial uses, and would permit limited residential and commercial uses primarily oriented to employees of the surrounding industrial development. The property at PCH and Goldenwest currently contains active oil production facilities, and there is no indication that this present use would change. Moreover, the Specific Plan for this site does not allow for residential development. Therefore, neither of these locations would meet the objectives identified for project alternatives. Alternatives to the general land uses proposed at the project site were also evaluated on a programmatic level in prior environmental documentation, and the following discussion provides a review of these previous alternatives considered for the site within a larger planning context. As discussed on page 1-1 of the Draft EIR, development on the project site is addressed on a programmatic level as part of the analysis included in several previous Program EIRs prepared by the City of Huntington Beach. These documents, which are incorporated by reference in the Draft EIR on page 1-1 in accordance with CEQA Guidelines section 15150, include (1) The Huntington Beach DTSP EIR 82-2 and Addendum to SEIR 82-2; (2) The Huntington Beach General Plan Update EIR 94-9; and (3) The Huntington Beach Redevelopment Project EIR 96-2. A range of alternatives for the area analyzed in each EIR, which included the project site, 3-274 City of Huntington Beach Chapter 3 Responses to Comments were considered in each of these documents, including a No Project Alternative in all three EIRs. Each of the relevant plans that included the project site was adopted, and the No Project Alternative assessed in each EIR was determined not to be the appropriate alternative. The Huntington Beach General Plan Update EIR, which addressed development Citywide, also contained the following relevant alternative: • Reduced Buildout Alternative—Reduce developmentCityby in the 25 percent. The Huntington Beach Redevelopment Project EIR, which was prepared for the redevelopment project area that includes the project site, contained the following relevant alternatives: • Alternate Project Location Alternative—No suitable location could be identified. • Increased Development Alternative—Maximize development up to capacities greater than development intensity allowed under the City General Plan. • Reduced Development Alternative—Reduce programs to fund capital improvement projects within the Redevelopment Area. The Final DTSP EIR, which was prepared for the DTSP area and includes the project site,reviewed the following relevant alternatives: • Lower Intensity Alternative—Reduce the allowable densities and decrease the building envelope in the DTSP area. • Higher Intensity Alternative—Intensify development in the DTSP area. As discussed on page 3.9-20 of the Draft EIR, the City determined that the uses identified in each of the three planning documents, which included the project site, were appropriate and fulfilled the City's objectives for the larger planning area. The alternatives identified above did not substantially reduce significant impacts and/or did not meet objectives for the area. Thus, the allowable uses and alternatives to these uses were considered on a macro-level within the Program EIRs identified above. The Pacific City EIR 3-275 Chapter 3 Responses to Comments analysis provided in the EIR considered the specifics of development on the site, and analyzed a range of alternatives for the site, as discussed in detail in Chapter 4 of the Draft EIR. RMC-32 The Limited Development Alternative was considered in the initial screening process. This alternative is discussed under the "Other Alternatives Considered." As discussed on page 4-24 of the Draft EIR, these alternatives were not carried forward for detailed analysis because they either did not meet project objectives, and/or did not reduce significant project impacts. Please refer to Response to Comment RMC-31 on page:� P P Pg 3- 272 for a discussion of significant and unavoidable impacts on air quality and traffic. Thus, the focus of the alternatives analysis was on the reduction of impacts to these resources. As stated on page 4-25 of the Draft EIR, the key contributor of roadway trips that result in the significant air quality and traffic impacts is a result of the retail and office components of the proposed project. Section 4.3.2, the Limited Development Alternative, on page 4-25 of the Draft EIR considered the level of development needed to reduce air quality and traffic impacts to less-than-significant levels. This alternative would fail to satisfy the basic objectives of the project, and thus it would not meet the intent of the alternatives analysis under CEQA. In addition to the project inability to meet objectives, it was also identified as infeasible. As identified under CEQA, economic viability is one of the factors that may be used to determine feasibility of the alternative; nonetheless, even if this alternative were economically viable, it was not considered in detail due to its inability to meet basic project objectives. RMC-33 Section 4.3.3, the Reduced Residential Density Alternative, on page 4-26 of the Draft EIR is not eliminated from detailed consideration because it is not economically viable. Rather, as stated on page 4-26 of the Draft EIR, a reduction in the density of residential units would reduce the severity of impacts, but would not lessen any significant and unavoidable impacts to less-than-significant levels. Please refer to Response to Comment RMC-31 on page 3-272 for a discussion of the intent of the alternatives analysis. Additional information has been added to the Final EIR discussion of the Reduced Residential Density Alternative to provide evidence as to why this alternative was not considered in detail. The Draft EIR has been revised to include this additional discussion. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. 3-276 City of Huntington Beach Chapter 3 Responses to Comments As shown in Table 3.14-10 on page 3.14-29 of the Draft EIR, a total of 12,002 trips would be generated by the proposed project. Of this total, residential uses would generate 2,048 trips, or slightly less than 20 percent of total project trips. As shown in Table 3.2-6 on page 3.2-15 of the Draft EIR, VOC emissions from the project would total 70.94 pounds per day (lbs/day), exceeding the threshold of 55 lbs/day, thus, exceeding thresholds by approximately 30 percent. Even if the number of residences were to be reduced by half, a reduction of 1,024 trips would not be substantial in comparison to the trips generated as a whole, and would neither substantially reduce impacts to traffic or air quality, nor reduce impacts to less-than-significant levels. Further, the site is zoned for a density of 30 units per acre, and it is appropriate to develop the site in this range, as development of this density has been envisioned on the site in the City General Plan and DTSP. Thus, the City has already made fundamental policy decisions about the appropriate residential density for the site. In keeping with the legislative goal of long-term comprehensive planning, the City does not need to reconsider their past policy decisions about.the density on the site (Citizens of Goleta Valley v. Board of Supervisors, (1990) 52 Cal.3d 553). CEQA policy and Guidelines limit the environmental analysis required on a project that is consistent with the general plan and zoning and/or a redevelopment plan (refer to CEQA Sections 21083.3 and 21093 and CEQA Guidelines Sections 15180 and 15183). RMC-34 Please refer to Response to Comment RMC-32 on page 3-276. As discussed, several alternatives were considered but not carried forward for detailed analysis. These alternatives were part of the initial screening process and were not "summarily rejected." As identified in Practice Under the California Environmental Quality Act (Stephen L. Kostka and Michael H. Zische), Section 15.5, "There are two stages of analysis in selecting alternatives to be included in an EIR. At the first stage, the lead agency identifies potential alternatives that meet the threshold tests defining suitable alternatives, and excludes those that do not. At the second stage of analysis, the lead agency must consider the suitable alternatives that remain and identify a reasonable range for review in the EIR."The"threshold tests"refer to several criteria to determine whether an alternative should be considered in detail. These include whether or not the project could (1) reduce significant impacts; (2) meet project objectives; (3) are feasible; or (4) are plainly unreasonable. Section 4.3 of the EIR identifies for the record those alternatives that were part of the first stage of the alternatives analysis, and, thus, Pacific City EIR 3-277 Chapter 3 Responses to Comments includes those alternatives considered, but that did not meet the threshold tests for alternatives that should be analyzed in detail in the EIR. The first two alternatives would result in different outcomes at the project site. The No Project/No Development alternative was prepared to disclose the effects of no development on the site. The No Project/Reasonably Foreseeable Development was prepared to present the effects if the proposed project were not approved, and another development proposal were submitted. Thus, one alternative addresses no development on site, and the other addresses future development on site. As such, these are two different future scenarios, and the statement that three alternatives were selected for detailed analysis is an accurate statement and is not"misleading." RMC-35 Contrary to the information presented in this comment, three alternatives are analyzed in detail in Sections 4.2.1 through 4.2.3 on pages 4-4 through 4-24 of the Draft EIR: (1) No Project/No Development; (2) No Project/Reasonably Foreseeable Development; and (3) Reduced Project. The CEQA Guidelines Section 15126.6(a) state that"there is no iron clad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason." The rule of reason requires that only those alternatives needed to permit a reasoned choice need to be analyzed in detail, and the alternatives should be limited to those that would avoid or reduce significant impacts, and only those that would feasibly meet most of the project objectives require detailed study (CEQA Guidelines Section 15126.6(f). Thus, as discussed in Response to Comment RMC-31 on page 3-272, the focus of the alternatives was on those reducing significant air quality and traffic impacts. The conclusions of the EIR and the land use designations of the site—permitting residential uses in certain areas and commercial uses in others—thereby limited the feasible range of alternatives that warranted detailed analysis. A Reduced Hotel Alternative would not satisfy the intent of the alternatives analysis. A reduction in hotel uses would not be sufficient enough to reduce trip generation to a level that would substantially lessen operational air emissions and trip generation. Additional information has been added to the Final EIR discussion of the Reduced Residential Density Alternative to provide evidence as to why this alternative was not considered in detail. The Draft EIR has been revised to include this additional discussion. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. 3-278 City of Huntington Beach Chapter 3 Responses to Comments As shown in Table 3.14-10 on page 3.14-29 of the Draft EIR, a total of 12,002 trips would be generated by the proposed project. Of this total, the hotel would generate 2,249 trips, or slightly less than 20 percent of total project trips. As shown in Table 3.2-6 on page 3.2-15 of the Draft EIR, VOC emissions from the project would total 70.94 pounds per day (lbs/day), exceeding the threshold of 55 lbs/day, thus exceeding thresholds by approximately 30 percent. A 50 percent reduction in the number of hotel rooms would result in fewer trips. However, the number of trips would be reduced by less than half(1,125 trips). The reduction in hotel trips would not be substantial in comparison to the trips generated as a whole, and would neither substantially reduce impacts to traffic or air quality, nor reduce impacts to less-than- significant levels. As discussed under Section 3.1, Impacts AES-2 and AES-3 on pages 3.1-30 through 3.1-34 of the Draft EIR, visual changes were determined not to adversely impact the visual quality of the area or the public availability of scenic views. A three- or four- story hotel would have less severe impacts in terms of mass, bulk, and density, as indicated in this comment. However, since no significant aesthetic impacts are identified, it would not be appropriate to analyze a reduced hotel on the basis of reduced aesthetic impacts. The original DTSP, adopted in 1983, contained sections that presented 1) an overview of the DTSP purpose and concept and 2) development standards. In 1995, the development standards of the DTSP were amended as part of the revisions commonly referred to as the "Village Concept." However, the overview section of the DTSP was not included in the amended DTSP and is therefore out of date with the 1995 amendment (and its subsequent amendments through February 2002). From an implementation perspective, the development standards, not the overview, govern development of the DTSP area and are the binding document for development. As noted in the table of contents for the DTSP, dated February 2002, the Specific Plan concept is pending review and will be updated. Notwithstanding the above, the 1983 overview provides useful information and guiding principles as to the City's intent for the DTSP area. At the time, the vision was a total of 1,600 hotel rooms distributed among three districts, up to 3,700 residential units, and over 600,000 square feet of commercial space. As the commentor indicates they have thus far received entitlements to construct over 800 rooms in District 9; however, Pacific City EIR 3-279 Chapter 3 Responses to Comments the 1983 concept only envisioned a maximum of 400 rooms in this District. It can reasonably be concluded by the commentor's own observation that the concept plan was only intended to provide a broad brush outline of the City's goals for the area at that time; otherwise no additional hotels could reasonably be expected to be approved in District 9 using the 1983 concept as a frame of reference. Further analysis of the 1983 concept shows that the total number of hotel rooms that the City expects to be constructed in the entire DTSP area at this time is very close to the maximum expected in 1983. When one combines constructed (817), approved (148), proposed (400) and possible future (300) hotel rooms, a total of 1,665 is achieved. This total is not notably different than the total of 1,600 rooms expected in 1983. The primary difference is the location of the rooms. In the 1983 concept it was expected that District 3 would have 400-800 hotel rooms and District 9 would have 300-400 rooms. Based on the constructed and approved projects, District 3 will only have 148 rooms and District 9 has 817 rooms. District 7, the location of the Pacific City site, was originally envisioned for 200-400 rooms, and the project proposal of 400 rooms is consistent with the 1983 concept as well as the current DTSP. Finally, the 1983 concept states that the "proposed land use designations and district configurations are intended to anticipate development demands and achieve the optimum potential..." In other words, the City's objective in developing the 1983 concept was to maximize development to meet expected demand. Again, the Pacific City proposal for 400 hotel rooms is consistent with this stated objective. As discussed under Section 4.3.2 on page 4-25 of the Draft EIR, the Limited Development Alternative was developed in order to identify the amount of development needed to reduce air and traffic impacts to less-than-significant levels. The Reduced Project Alternative includes a reduction of 48,900 square feet of commercial uses, which would be approximately 20 percent less commercial development than the proposed project. This would substantially reduce air emissions and vehicular trips. NOa emissions would be reduced to less-than-significant levels, although VOC emissions would remain significant. Traffic impacts to the PCH/Seapoint intersection would remain significant, but would be mitigable, similar to the proposed project, and impacts to the PCH/Warner intersection would not be substantially reduced and would remain significant and unavoidable in the 2008 scenario. 3-280 City of Huntington Beach Chapter 3 Responses to Comments RMC-36 A 400-room hotel would not be the minimum size necessary to achieve project objectives, and this information is neither stated nor implied in the Draft EIR. Please refer to Response to Comment RMC-35 on page 3-278 for a discussion of why a reduced hotel alternative was not considered; this alternative would not avoid or substantially reduce significant effects that could otherwise be addressed through project mitigation. The relative need for a hotel is driven by an array of socio-economic factors: the DTSP was initially adopted in 1983 and updated with the"Village Concept" in 1996, and the number of hotel rooms identified as needed in the area evolved as market indicators have changed. Further, the DTSP permits for hotel uses in District 7. RMC-37 The cumulative project list includes a list of past, present, and reasonably foreseeable projects for the cumulative impact analysis. The timing for the 300-room hotel (which is anticipated to be open after Year 2008) was directed by the City based on expected time periods for final designation of an operator, preparation of construction drawings based on operator programs and overall commercial hospitality phasing, and therefore, it was excluded from the near-term analysis. However, the hotel development is included in the General Plan Buildout analysis included in the EIR text and the Traffic Study, which is included as Appendix H to the Draft EIR, and no new impacts, beyond those identified in the Draft EIR, are indicated as a result of its inclusion. Also, please refer to Response to Comment RMC-9 on page 3-265 for a discussion of the inclusion of the proposed 300-room Waterfront hotel in the cumulative analysis for the proposed project. RMC-38 A combination of a reduced commercial and residential project would, similar to the limited development alternative, need to be reduced to such a limited amount of development in order to substantially reduce significant impacts that could not otherwise be mitigated, that the project would not be feasible. As the commercial component is the largest generator of vehicular trips, this component of the project would need to be reduced to similar levels presented in the Limited Development Alternative, which, as indicated under Section 4.3.2 on page 4-25 of the Draft EIR, would not be feasible. CEQA Guidelines Section 15126.6(a) also indicates that "an EIR need not consider every conceivable alternative..." The project considers a reduced retail project, limited residential development, and limited commercial and hotel development. This Pacific City EIR 3-281 Chapter 3 Responses to Comments combination of alternatives initially considered represents a reasonable range of alternatives that allow for meaningful comparison by the City. RMC-39 A reconfigured project would not reduce significant impacts that could not be feasibly mitigated to less-than-significant levels. Please refer to Response to Comment RMC-31 on page 3-272 for a discussion of significant impacts resulting from the type of development rather than location. Therefore, a reconfigured alternative would not address these impacts. Geologic impacts including liquefaction, settlement, and soil corrosion would be reduced to less-than-significant levels through the implementation of Mitigation Measure GEO-1, as discussed on page 3.6-21 of the Draft EIR. RMC-40 Comment noted. Please refer to Responses to Comments RMC-41 and RMC-42 below, for a discussion of remediation pits and wetlands. RMC-41 The commenter asserts that the remediation pits would not "automatically be permitted to be filled" under the Coastal Act. As stated in Impact BIO-5 on pages 3.3- 21 through 3.3-22 of the Draft EIR, the City has approved the remediation plan under Coastal Development Permit (CDP) 00-09 and Conditional Use Permit 00-36. Part of the approved remediation plan includes filling of the pits. The pits would not, therefore, be filled only for the purpose of developing the proposed project. RMC-42 In the Bolsa Chica case, a developer sought to develop a deteriorating Environmentally Sensitive Habitat Area (ESHA) and mitigate the loss by re-creating a similar area at another site. The court held that the Coastal Act"does not permit destruction of an (ESHA] simply because the destruction is mitigated offsite. There must be a showing that the destruction is needed to serve some other recognized environmental or economic interest." Although the commenter correctly described and cited this case, the commenter erroneously applied it to the proposed project, as the case only addressed currently designated ESHA's, which the property is not. Further, as described in Response to Comment RMC-41 above, the filling of the pits would serve another recognized environmental interest (i.e., remediation of contaminated soils). Consequently, the analysis may reasonably assume that off-site mitigation could occur in the event that wetlands are identified. With respect to development allowed under PRC 30233(a), Impact BIO-5 on pages 3.3-21 through 3.3-22 of the Draft EIR states that if, after filling the remediation pits, wetland vegetation still exists, "the Applicant would be required to obtain all necessary permits 3-282 City of Huntington Beach Chapter 3 Responses to Comments required by the City(as trustee for the CCC) and the CDFG in order to be in compliance with the Fish and Game Code of California and the California Coastal Act." The CDFG has the discretion to determine the "normal circumstances"that exist on the site, and to decide whether the area meets the definition of a wetland after the remediation is complete. The applicability of PRC 30233(a) to the project would be assessed when and if the CDFG found the area to be a wetland. RMC-43 As stated in Impact BIO-5 on pages 3.3-21 through 3.3-22 of the Draft EIR, the permitted remediation is not yet complete, and until it is complete a determination of the presence or absence of wetlands under normal conditions (as defined by the CDFG) would not be possible, as the site is currently in an altered state due to the remediation process. The majority of the wetland vegetation present is within the remediation footprint and supported by groundwater seepage that is approximately 15 feet below normal grade, and the approved remediation plan includes filling of these pits. To date, the Coastal Commission has not offered a conflicting statement indicating that filling of the pits would not be allowed, and thus the applicant shall assess wetland vegetation after the remediation is complete, when the pits are re-filled and the project site is returned to its normal state. Also, please refer to Responses to Comments RMC-41 and RMC-42 on page 3-282 for further discussion of permitted re-filling of the pits, and the potential for off-site mitigation of any potential impacts to wetlands. RMC-44 Please refer to Responses to Comments RMC-41 and RMC-42 on page 3-282 for discussion regarding deferral of analysis and mitigation. As required by Section 15126.4(a)(1) of the CEQA Guidelines, the Draft EIR describes feasible measures that could minimize significant adverse impacts. As required by Section 15126.4(a)(2) of the CEQA Guidelines, these measures are fully enforceable through permit conditions, agreements, or other legally binding instruments. Pursuant to Section 15097 of the CEQA Guidelines, a Mitigation Monitoring and Reporting Program (MMRP) has been prepared for the proposed project. The MMRP provides specific mitigation monitoring requirements, including implementation documentation, monitoring activity, timing, and responsible monitoring party. Verification of compliance with each measure is required, thus ensuring implementation of mitigation measures. Pacific City EIR 3-283' Chapter 3 Responses to Comments Regarding Mitigation Measure AES-1 on page 3.1-47 of the Draft EIR, this measure has been included in its current form in several environmental documents prepared for and certified by the City and has been determined by the City to be an effective and enforceable means of mitigating daytime glare impacts from structures. The use of the - term "to the extent feasible"is intended to indicate that some reflective surfaces cannot be avoided, but shall be minimized to the satisfaction of the City. However, to provide an additional measure of protection, MM AES-1 on page 3.1-47 of the Draft EIR has been revised to include additional standards that have historically been incorporated into d d Stan ar conditions of approval for some projects. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. The project would also be -- reviewed by the City's Design Review Board to ensure its visual elements conform to City requirements. Further, it should be noted that Public Works would ensure that mitigation measures are addressed during the plan check phase. The Public Works inspectors would ensure that the conditions and mitigation measures identified are implemented and followed. The limitation imposed by Mitigation Measure AQ-4 on pages 3.2-20 through 3.2-21 of the Draft EIR regarding the use of electrical generators powered by internal combustion engines during construction would be enforced through specifications on grading and building plans, which must be approved by the City, contrary to the assertion in the comment that language need only be reviewed. Further, the MMRP for the project indicates, on page 1 and subsequent pages, that, where applicable, grading and building plans would be reviewed and approved in order to ensure inclusion. In addition, even with implementation of this measure (identified as MM AQ-4 in the Draft EIR), the analysis recognizes that the measures proposed in the Draft EIR for the reduction of construction-related emissions cannot be assumed to reduce such emissions to less-than-significant levels, and impacts to air quality would remain significant. Further, these measures are not, as the comment incorrectly asserts, untested: they represent standard measures recommended by the SCAQMD and incorporated into environmental documentation on a regular basis. Project conditions of approval would require the Applicant to retain a full-time monitor for the project site during site preparation and construction, and designate a representative to coordinate and ensure implementation and compliance of all mitigation measures in the MMRP. In addition, it is the responsibility of City inspectors 3-284 City of Huntington Beach Chapter 3 Responses to Comments to ensure that project conditions are being implemented and followed. City inspectors would exercise due diligence and care in order to ensure that specifications on grading and building plans are implemented. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. RMC-45 The impact statement for Impact REC-2 on pages 3.13-11 through 3.13-12 of the Draft EIR has been revised to clarify that construction of recreational facilities associated with the proposed project would not significantly affect the environment over the short term. As described within the impact text, mitigation measures associated with the referenced sections associated with construction impacts would reduce impacts to a less-than-significant level, with the exception of construction impacts of air quality. Construction would occur as part of the development of the overall site, and that effect on air quality would be significant and unavoidable, as discussed under Impact AQ-1 on pages 3.2-10 through 3.2-11 of the Draft EIR. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. RMC-46 As discussed on page 3.12-10 of the Draft EIR, implementation of the proposed project would only result in a slight decrease in the service ratio from 1.1 officers per 1,000 residents to 1.09 officers per 1,000 residents, In addition, the proposed project would contribute funding to the City's general fund in the form of tax revenue, fees, and other ancillary payments, which can be used by the City to fund additional police officers. Furthermore, the measures included in MM PS-4 on page 3.12-16 of the Draft EIR are recommended to further reduce impacts on police services. RMC-47 The SCAQMD's Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Emissions were prepared to analyze potential cancer risks associated with diesel particulate matter generated from facilities that have substantial numbers of diesel sources such as truck stops, warehouse distribution centers, transit centers, water ports, and rail yards. General commercial centers—such as the proposed project—are not considered to be sources of significant localized health risks. The California Air Resources Board's (CARB's) Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles identifies ranges of potential cancer risks associated with seven common sources. One of these is a warehouse distribution center with a refueling station and shipping/receiving areas. Pacific City EIR 3-285 Chapter 3 Responses to Comments Using year 2000 emission inventories and assuming that 200 heavy-heavy-duty diesel trucks would pick up and receive goods each day, and that 100 of these vehicles would refuel at the facility each day, the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles identifies a risk potential of approximately 10 chances per million based on 24 hours per day, 365 days per year for 70 years of constant exposure to the diesel fumes at a distance of 20 meters from the fence line of the facility. Ten in one million is the level at which the SCAQMD considers the impacts from an individual project to be significant. Using this information, the potential risks associated with the proposed project site can be estimated to identify a potential worst-case scenario, even though there would be no refueling of diesel trucks at the project site. As shown in Appendix C of the Draft EIR, the proposed project would generate approximately 219 truck trips per day. Of these, only about 6.5 percent or 14 trucks would be heavy-heavy-duty. The potential worst-case risks to nearby residents can be calculated as follows: • Potential Cancer Risk = 10 cases per million (200 HHD Trucks) x 0.065 (Project HHD Trucks) = 0.65 cases per million The actual risks would be lower than the potential risks since there would be no fueling of diesel trucks at the project site. Based on this information, the potential cancer risks to nearby residents surrounding the project site would be substantially less than the SCAQMD's ten in one million standard using year 2000 data. No buffers or setback distances would be needed to protect the residents near the project site from diesel exhaust emissions. The Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles identifies programs that would reduce the potential risks associated with diesel vehicle exhaust in California by up to 75 percent by 2020. Therefore, the potential risks to everyone in the state would be substantially reduced from 2000 levels. No further evaluation is required. RMC-48 The SCAQMD CEQA Air Quality Handbook does not require the use of the most current EMFAC emission factors when preparing air quality impact analyses. In the first place, the CEQA Air Quality Handbook is a guidance document that explains methodologies and thresholds of significance that the SCAQMD uses when preparing 3-286 City of Huntington Beach Chapter 3 Responses to Comments air quality impact analyses and that provide recommendations for other lead agencies in the South Coast Air basin. Nothing in the CEQA Air Quality Handbook is required for any lead agency with the exception of the SCAQMD. It certainly makes sense, however, to use the most current emission factors available in most instances. The current emission factors available for motor vehicles in California are listed in the EMFAC 2002 mobile source emissions inventory. The operational emissions associated with the proposed project were calculated using the URBEMIS 2002 transportation and land use program model, which was developed with EMFAC 2002 emission factors. The simplified CALINE4 screening procedure that was used to calculate localized CO concentrations is currently programmed with an older version of the State's mobile source emissions inventory (EMFAC7G). These emission factors for CO, however, are greater than those identified in EMFAC 2002. For example, the composite emission factor for vehicles traveling 15 miles per hour in 2003 is 11.37 grams per mile under EMFAC7G and 9.92 under EMFAC 2002. Therefore, the localized CO concentrations identified in the Draft EIR are higher than what would otherwise be identified when using the most current emission factors and were used to provide a potential worst-case analysis. The procedure also used the projected ambient CO concentrations for SRA 18 published by the SCAQMD as the baseline to which the localized vehicle emission were added. RMC-49 With regard to emergency access on the project site and specifically, the subterranean garage, Section 3.12 (Public Services) of the Draft EIR focuses on pedestrian movement in and out of this area while Section 3.14 (Traffic) of the Draft EIR focuses on vehicle movement in the area. EIP consulted with the HBFD concerning the potential impact related to pedestrian emergency access for the proposed project. MM PS-1 on page 3.12-15 of the Draft EIR was provided by the HBFD in order to reduce this impact to a less-than-significant level. Impact PS-1 on pages 3.12-9 to 3.12-10 of the Draft EIR has been revised to clarify the discussion of emergency access. In addition, Impact TR-9 on page 3.14-75 of the Draft EIR has been similarly revised. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. RMC-50 Refer to Response to Comment RMC-49 above for a discussion of clarifications to the emergency access impact analysis in the Draft EIR. Pacific City EIR 3-287 Chapter 3 Responses to Comments RMC-51 Figure 3.6-3 on page 3.6-9 of the Draft EIR illustrates the appropriate liquefaction potential for the project site. Pages 3.6-8 and 3.6-17 of the Draft EIR have been revised to reflect the accurate liquefaction potential for the southeastern corner of the project site. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. Although the Draft EIR language has been updated to reflect the accurate liquefaction potential as very high on the southeastern portion of the project site, the overall conclusion of this impact would not change. The impact would remain potentially significant, as the incorporation of MM GEO-1 on page 3.6-21 of the Draft EIR would still reduce the impact to a less-than-significant level, based on the findings of the geotechnical investigation prepared for the proposed project (Appendix J to the Draft EIR). RMC-52 As discussed in Impact P-1 on pages 3.11-13 through 3.11-16, the project-related increase would be well within and consistent with SCAG projections for employment in the City and County. The proposed project would be consistent with the City General Plan and Specific Plan land use designations for the project site. The project would implement the previously planned residential and commercial uses for the site, and the associated jobs housing implications were considered during these area-wide planning processes. Thus, the project would not shift the jobs-housing scenario that was already considered to occur in the project area and incorporated into long term County projections. Moreover, a one-to-one correlation with respect to housing units and jobs generated cannot reasonably be assumed for the proposed project. As stated on pages 3.11-2 and 3.11-14 of the Draft EIR, the average number of persons per household in the City is conservatively assumed to be 2.75, indicating that one or two persons per household could hold jobs. In addition, unemployment rates generally fluctuate between 2 and 8 percent, depending on economic conditions. Thus, jobs generated by the project not only provide jobs for new population in the City or area, from the proposed project or other population growth, but would also meet demands resulting from unemployment. Further, not all jobs provided by the project would employ full-time, adult workers; many available positions, particularly those of the proposed commercial uses, would also employ part-time adult and teenage workers, who would likely be drawn from the local area. Although the housing component of the project would not necessarily provide housing for the employees of the project, the provision of housing would help to ensure that employment opportunities provided by 3-288 City of Huntington Beach - ' Chapter 3 Responses to Comments the project would not result in an unanticipated demand for housing that could not be accommodated in the City or County. RMC-53 Please refer to the Topical Response on Water Quality on page 3-173, which addresses the issue of bacterial levels in runoff. Drainage Area "A" would continue to flow to the ASWPS for all dry-weather and stormwater flows. In addition, the dry weather flow for Drainage Area"B" can be routed into Area"A" and to the ASWPS, in order that, at the City's discretion, these flows may be routed for treatment by OCSD. The project conforms to all water quality standards adopted in order to protect water resources. No water quality standards for pathogens have been adopted by the SARWQCB. Please refer to Responses to Comments identified as RMC(B) on pages 3-300 through 3-305 that demonstrate the adequacy of Draft EIR conclusions with respect to water quality. RMC-54 The ASWPS has a tributary area of approximately 1,125 cfs in the 100-year event. If the entire project site drained toward the ASWPS, it would contribute approximately 107 cfs, which is approximately 10 percent of the tributary area. The City has no plans to increase the capacity of the ASWPS in the near future, and any projection that this could occur in the future would be speculative; therefore, any fairshare contribution from the proposed project towards upgrades to the pump station is infeasible. Upgrades to the ASWPS are not feasible and would result in secondary environmental impacts. In,order to upgrade the ASWPS to allow stormwater flows from the project site to be handled by this facility, the pump station would need to be reconstructed, and drainage facilities connecting to the pump station would need to be resized. Existing drainage facilities are located beneath the mobile home park adjacent to the site, as well as beneath other existing residential and commercial uses. These uses would be temporarily and/or permanently disrupted and damaged by the construction necessary for the pump station upgrade. Therefore, the benefit of treating additional stormwater flows by upgrading the ASWPS would not override the secondary environmental impacts, which could include, but would not be limited to displacement of housing, construction-related air quality, noise, and traffic impacts. RMC-55 Existing discharges to the beach from the existing First Street stormwater outfall, as well as ponding of this runoff and any existing hazards associated with this current condition, are an existing condition and would not be an impact of the proposed project. The EIR does not need to consider this further because it has not been Pacific City EIR 3-289 Chapter 3 Responses to Comments determined if runoff from the ponded area at the outfall site on the beach would reach the ocean. The proposed project would contribute 26.9 acres to the total drainage area of 53 acres that would be served by the planned future Alabama Street storm drain system. Based on a 25-year storm event, the Alabama Street storm drain will be designed to handle a combined 67.5 cfs (from areas other than the project site) and 20 cfs (from the Pacific City project site), with an approximate total flow of 90 cfs. The project would increase the discharge at the beach in this area, but, based on the project size in comparison to the larger drainage area, the proposed project would only contribute to a portion of this effect, and, furthermore, project-related discharges would comply with all prevailing laws and regulations that apply to water quality management. The Alabama Street storm drain project is expected to be brought before the Zoning Administrator in April 2004. RMC-56 Existing flows and flows that would occur due to the improvements to the future Alabama Street storm drain system have the potential to discharge runoff to the Pacific Ocean via the existing outfall. The proposed project would increase flows by 20 cfs and, as such, would increase the discharge of water into the ocean. The outfall exists for the sole purpose of transporting flows to the ocean, and ponded flows on the beach are eventually transported to the ocean by existing flows under existing conditions. Consequently, the transport of pathogens or bacteria that may be present in existing flows (and for which no standards have been adopted by the SARWQCB) occurs under existing conditions. Worth noting, an increase in the volume of water could also potentially dilute existing or future bacterial levels. RMC-57 This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration when deciding whether to approve or deny the proposed project. 3-290 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter RMC (A) (Kimley-Horn and Associates, Inc. (Attachment A to Robert Mayer Corporation Letter), December 2, 2003) RMC(A)-1 Comment noted. Please refer to responses to specific concerns identified below. RMC(A)-2 This comment correctly notes that the intersection of Atlanta Avenue and Huntington Street would be signalized. The project as proposed includes signalization at the intersection of Atlanta Avenue and Huntington Street, as identified in Table 2-8 and page 2-21 of the Draft EIR. Please refer to Response to Comment RMC-3 on page 3- 263 for details of the specific mitigation identified. RMC(A)-3 Please refer to Response to Comment RMC-3 on page 3-263 for a discussion of the signal warrant at Huntington Street and Atlanta Avenue. The project as proposed includes signalization at the intersection of Atlanta Avenue and Huntington Street, as identified in Table 2-8 and page 2-21 of the Draft EIR. The Traffic Impact Analysis Report, included as Appendix H of the Draft EIR, indicates that the proposed project's fair share contribution to this signal would be 59 percent based on traffic volume. The traffic impact analysis for the Waterfront Ocean Grand Resort, dated July 2, 1998, also indicates that a traffic signal is anticipated as a future condition at the intersection of Atlanta Avenue and Huntington Street. RMC(A)-4 Please refer to Response to Comment RMC-3 on page 3-263 for a discussion of signalization of Huntington Street and Atlanta Avenue intersection following implementation of the project. Page A)-5 Pa e 64 of the Traffic Impact Analysis Report (Appendix H to the Draft EIR) identifies the project's fair share contribution to a signal at Huntington Street and Atlanta Avenue would be 59 percent based on traffic volume. This comment is acknowledged, and the opinion of the commenter will be provided to decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. RMC(A)-6 Comment noted. RMC(A)-7 Comment noted. Pacific City EIR 3-291 Chapter 3 Responses to Comments RMC(A)-8 The mixed-use project characteristics, the proximity of the existing and proposed residential uses, and the location of the office above the retail/commercial and restaurant uses support an AM internal capture reduction. The rationale used for the proposed project AM internal capture reduction is the same as that developed by ITE (i.e., it is based on percentages for interactions between pairs of land uses). RMC(A)-9 Please refer to the Topical Response on Traffic Generation on page 3-176. These internal capture reduction values based on the ITE methodology are considered guidelines for determining appropriate reductions and can be adjusted to reflect unique project characteristics. RMC(A)-10 Please refer to the Topical Response on Traffic Generation on page 3-176. The internal capture rates are generally based on Tables 7.1 and 7.2 in the ITE Trip Generation Handbook (October 1998) and have been adjusted based on the specific project characteristics. These internal capture reduction values, based on the ITE methodology, are considered guidelines for determining appropriate reductions and can be adjusted to reflect unique project characteristics. RMC(A)-11 Comment noted. RMC(A)-12 Internal capture reduction values based on the ITE methodology are considered guidelines for determining appropriate reductions and can be adjusted to reflect unique project characteristics. Please refer to Response to Comment DOT-4 on page 3-185 for a source for the assumptions used. RMC(A)-13 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of why the mode shift is appropriate to use. The mode shift percentages conform to ITE recommendations and reflect traffic engineer and City experience with the unique combination of the proposed project's mixed-use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. RMC(A)-14 Please refer to the Topical Response on Traffic Generation on page 3-176 and Response to Comment RMC-5 on page 3-264 for a discussion of why the mode shift is appropriate to use. 3-292 City of Huntington Beach Chapter 3 Responses to Comments RMC(A)-15 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of why the mode shift is appropriate to use. The methodology used in the Pacific City traffic study is consistent with sound traffic engineering practice. Reductions to the base trip volume can be applied through use of either a mode shift or pass-by traffic. A mode shift reduction was considered the more appropriate type of reduction to take based on the project's characteristics and setting. The outcome of either methodology would result in a similar total number of trips generated from the site, and the conclusions of the analysis would be the same. RMC(A)-16 This comment correctly defines walk-in traffic on an hourly basis. However, over a ten hour (i.e., daily) period and one hour PM peak period, the walk-in traffic equates to approximately five people per minute and six people per minute, respectively, dispersed throughout the total 240,000 square feet of development. Please refer to the Topical Response on Traffic Generation on page 3-176 for additional discussion on trip generation. RMC(A)-17 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of why the mode shift is appropriate to use. The mode shift percentages conform to ITE recommendations and reflect traffic engineer and City experience with the unique combination of the proposed project's mixed-use land characteristics and proximity to the beach, as experienced in Main Street/Downtown and adjacent hotel land uses. RMC(A)-18 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of why the percentages used in the mode shift are appropriate. The traffic impact analysis for the proposed project addressed local and regional traffic impacts consistent with City, County, and State guidelines. The text of the Draft EIR page 3.14-15 has been revised to clarify that the summer weekday condition is typically higher than during'the winter months and, consequently was used in this analysis to present a conservative scenario. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. RMC(A)-19 Please refer to the Topical Response on Traffic Generation on page 3-176 and Response to Comment RMC(A)-16 above for a discussion of why the mode shift is appropriate to use. Pacific City EIR 3-293 Chapter 3 Responses to Comments RMC(A)-20 Please refer to the Topical Response on Traffic Generation on page 3-176 for a discussion of why the mode shift is appropriate to use. RMC(A)-21 Although the Development Agreement allows for a third hotel, the hotel is subject to the approval of a CUP and CDP as well as required environmental documentation. No proposal, application, or other project submittal related to project entitlement on the Waterfront's third hotel site has been provided to the City, and until such time, that hotel could be modified in scope or character by the developer consistent with the procedures set forth in the amended Development Agreement. Because no information indicating that this project would be developed in the reasonably foreseeable near future was available, this project was not included in the Year 2008 analysis. However, the hotel development is included in the General Plan Buildout analysis included in the Draft EIR; no new impacts, beyond those identified in the Draft EIR, are indicated as a result of its inclusion. RMC(A)-22 Please refer to Response to Comment RMC(A)-21 above for a discussion on why the -- Waterfront's third hotel site was not included in the Year 2008 analysis. RMC(A)-23 The correct information on the proposed project is presented in Chapter 2 of the Draft EIR. Proposed square footage of commercial development is included in Table 2-5 on page 2-13. The information in Table lA of the parking study identifies that within the 180,000 sf shopping center use, there would be 38,900 sf of restaurants, and 141,100 sf of retail uses. This distinction affects the parking demand, but not the traffic analysis. This table also includes the outdoor dining area, which is not part of the traffic generation forecast. Thus, the parking study uses a more detailed breakdown of uses because those uses would affect the shared parking need, whereas, standard practice for determining traffic generation is based on general square footage of development. The methodology of all aspects of the traffic study is consistent with the approach applied to the Hyatt Hotel and"The Strand"project in the Downtown area. RMC(A)-24 Comment noted. Please refer to Topical Response on Shared Parking on page 3-180 for an explanation of why the parking demand information presented is appropriate. RMC(A)-25 This comment accurately restates the City parking code requirement as repeated on page 3 of the Parking Study. Comment noted. 3-294 City of Huntington Beach Chapter 3 Responses to Comments RMC(A)-26 Please refer to the Topical Response on Shared Parking on page 3-180. The hotel parking demand per City Code factors in demand for the ballroom and spa, and, as such, parking demand for these uses are typically not counted separately. However, as a conservative measure, separate parking demand from these uses was included in the shared parking analysis. RMC(A)-27 Please refer to the Topical Response on Shared Parking on page 3-180 for a discussion on the shared parking analysis and City code parking requirements. The ballroom and spa, which include 9,300 sf of usable space, are not counted separately in the City code requirements for parking. RMC(A)-28 Please refer to Response to Comment RMC(A)-26 above for discussion on parking assumptions associated with the ballroom. RMC(A)-29 While the traffic study and EIR Project Description list the ballroom area as 16,000 sf, the net usable meeting/banquet/ballroom area is approximately 9,300 sf. The remaining area is pre-function, banquet office, and kitchen area. Therefore, the Project Description is correct and no text change is warranted. RMC(A)-30 Please refer to Responses to Comments RMC-15 on page 3-267 and RMC-18 on page 3-268 for discussion of parking demand associated with the ballroom. In addition, the weekday and weekend parking demand profile (i.e., the percentage of spaces occupied at a given time) was increased from LILI's recommended use of 30 percent of the peak parking demand to 75 percent of the peak parking demand for the 1:00 pm hour to account for guest use of the meeting space area. As such, the parking analysis considers parking demand of the ballroom area from both persons driving to the site, and hotel guests. RMC(A)-31 The parking study does include the ballroom area and spa services, as identified in columns 3 and 4 of Tables 5A and 5B in the Shared Parking Analysis. Please refer to the Topical Response on Shared Parking on page 3-180 for a discussion of the appropriate reductions based on the characteristics of the proposed project. Please refer to responses to comments below that address specific comments on shared parking [RMC(A)-32 and RMC(A)-33], guest use of the hotel [RMC(A)-34 and RMC(A)-35], and walk-in traffic [RMC(A)-36 through RMC(A)-39] on pages 3-295 through 3-297. RMC(A)-32 Comment noted. Pacific City EIR 3-295 i I Chapter 3 Responses to Comments RMC(A)-33 The hotel component would not consist entirely of valet parking. Only a portion of the patrons would be anticipated to use valet services, so not all spaces needed for the hotel valet would need to be reserved. In addition, the parking management plan would ensure that garage capacity is monitored, so that if additional spaces reserved for valet are needed for self-park, these could be made available. Therefore, valet parking would not affect the shared parking supply. RMC(A)-34 Please refer to the Topical Response on Shared Parking on page 3-180 for a discussion on the shared parking analysis. The parking analysis considers parking demand of the ballroom area from both persons driving to the site, and hotel guests. As shown in Tables 5A and 5B of the shared parking analysis, no adjustments were made in column 1, Hotel, to the code-required parking rate of 1.1 spaces per room. The City Code does not require counting of on-site hotel amenities separately from the project, although the shared parking analysis does this as a conservative measure. In columns 3 and 4, the ballroom and spa facilities are counted. The reductions account for a portion of the hotel guests using these facilities. The weekday and weekend parking demand profile was increased from LILI's recommended use of 30 percent of the peak parking demand to 75 percent of the peak parking demand for the 1:00 P.M. hour to account for guest use of the meeting space area. Therefore, no double-discounting occurred. RMC(A)-35 Please refer to the Topical Response on Shared Parking on page 3-180 and Response to Comment RMC(A)-34 above for a discussion on the shared parking analysis. There is no double discount in the parking analysis. The weekday and weekend parking demand profile was increased from LILI's recommended use of 30 percent of the peak parking demand to 75 percent of the peak parking demand for the 1:00 P.M. hour to account for guest use of the meeting space area. This adjustment provides approximately 200 additional spaces in the peak demand hour, beyond LILI's recommended 1:00 P.M. peak demand, for guest use of other amenities. In addition, peak parking demand would occur at 1:00 P.M., not 7:00 P.M., the scenario presented in this comment. RMC(A)-36 Please refer to the Topical Responses on Traffic Generation on page 3-176 and Shared Parking on page 3-180 for a discussion on the mode shift application to the proposed project. RMC(A)-37 Downtown parking facilities offer parking validation. Consequently, there would be no incentive for persons to park at the project site instead of the Downtown area. 3-296 City of Huntington Beach Chapter 3 Responses to Comments RMC(A)-38 The mode-shift customer is accounted for within the beach visitors' category for those customers who park at the beach and is not based on new visitors attracted to the proposed project but, rather, those attracted to beach parking. It is acknowledged that at certain times, under existing conditions, it can be difficult to park in the project vicinity. The text of the Draft EIR page 3.14-15 has been revised to clarify that the summer weekday condition is typically higher than during the winter months and, consequently was used in this analysis to present a conservative scenario. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. RMC(A)-39 Please refer to the Topical Responses on Trip Generation on page 3-176 and Shared Parking on page 3-180 for a discussion of mode shift application to the proposed project. Because adequate parking would be provided on-site, proposed project parking demand would not impact the Downtown core and beach parking lots. RMC(A)-40 Comment noted. RMC(A)-41 Comment noted. RMC(A)-42 Please refer to the Topical Response on Shared Parking on page 3-180 for a discussion of the appropriateness of the use of the shared parking analysis compared to the Downtown Parking Master Plan parking requirements. The proposed project is located within the Downtown Specific Plan (DTSP) area, but is not within the Downtown Parking Master Plan area. The project would interact with the Downtown area, as identified by this comment. However, based on the mix of uses proposed (e.g., hotel), the project is not identical to the Downtown core, and thus, parking demand was not based on the Downtown Master Plan parking rates. RMC(A)-43 The data shown in Table 4A of the shared parking analysis are consistent with the Downtown Parking Master Plan requirements shown in Figure 4.2 of the DTSP. Table 4A uses information for Area 1, which includes the southerly portion of the Downtown area, immediately across from PCH. As the proposed project would be located immediately across from PCH, outside of the Downtown core, parking requirements from Area 1 were used for comparative purposes. Figure 4.2 does not require 1 space per 333 sf of retail as identified in this comment, and parking requirements of 1 space per 500 sf of office are for the North area. Nevertheless, as noted in Response to Pacific City EIR 3-297 Chapter 3 Responses to Comments Comment RMC(A)-42 on page 3-297, the information in Table 4A is for informational purposes only, and is not used for the ultimate analysis of parking adequacy. RMC(A)-44 Please refer to Response to Comments RMC(A)-34 on page 3-296 and RMC(A)-42 on page 3-297 for a discussion of City-approved parking methodology. RMC(A)-45 Please refer to the Topical Response on Shared Parking on page 3-180 for a discussion of the appropriateness of the use of the shared parking analysis. Application of separate City Code requirements is not appropriate for the project site, as the site includes unique features that promote the use of shared parking on-site. RMC(A)-46 The comment correctly repeats text from an appendix to the traffic study (Appendix H of the Draft EIR). Comment noted. RMC(A)-47 The City does not require an additional safety factor in parking facilities, which would result in a larger number of excess spaces. Instead, a safety factor is included into the base parking rates that the City uses. Consequently, provision of the number of required parking spaces allows for a buffer in the number of available parking spaces. A parking management plan would be utilized to oversee commercial parking operations and would direct vehicles to available spaces. RMC(A)-48 Please refer to the Topical Response on Shared Parking on page 3-180 for a discussion of the appropriateness of the use of the shared parking analysis and reasons why the Downtown Parking Master Plan rates are not the requirements for the project site. RMC(A)-49 The General Plan buildout traffic volume forecast for Pacific View Avenue is based on the City's traffic model, which indicates that a minimal volume of Pacific Coast Highway (PCH) traffic would divert to Pacific View Avenue through the Pacific City site. In addition to the traffic diversion included in the traffic model, the analysis assumed that an additional 5 percent of traffic would divert onto Pacific View Avenue, in order to provide a conservative analysis. The roadway width, lane configurations, roadway connectivity, and traffic control on Pacific View Avenue would not encourage substantial diversion of trips from PCH to this roadway. RMC(A)-50 The design and operation of Pacific View Avenue includes a 17-foot through lane that would allow vehicles to back out of their parking space, reducing affects on through 3-298 City of Huntington Beach Chapter 3 Responses to Comments traffic. In addition, the diagonal parking is proposed as an interim condition, and the roadway would ultimately include two lanes of travel in each direction. RMC(A)-51 Appendix K of the Traffic Study, included as Appendix H to the Draft EIR, shows the correct number of angled parking spaces as 39 spaces. This information is also correctly presented in Figure 3.14-15 on page 3.14-53 of the Draft EIR. The depiction of 30 angled parking spaces in Exhibit 18 represents a previous design of the project, and does not change any of the conclusions in the Draft EIR. Pacific City EIR 3-299 Chapter 3 Responses to Comments Response to Comment Letter RMC (B) (Richard Watson & Associates, Inc. (Attachment B to Robert Mayer Corporation Letter), December 2, 2003) RMC(B)-1 Comment noted. RMC(B)-2 Please refer to specific responses below and to the Topical Response on Water Quality on page 3-173 for further discussion of water quality issues, including an analysis regarding bacterial contamination of runoff. As demonstrated by the responses provided below, the water quality analysis in the Draft EIR fully complies with the requirements of CEQA. RMC(B)-3 Impact HYD-2 presented on pages 3.8-20 though 3.8-23 of the Draft EIR discusses the changes to drainage patterns that would occur as a result of the proposed project. RMC(B)-4 Please refer to the Topical Response on Water Quality on page 3-173, which discusses why dry-weather runoff is not required to be treated by OCSD. Nevertheless, the dry weather flow for Drainage Area"B" can be routed into to the ASWPS, in order that, at the City's discretion, these flows may be routed for treatment by OCSD. The Draft EIR has been revised to discuss dry-weather flows and treatment by OCSD. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. However, no new significant water quality impacts would result. Water quality impacts from operational discharges are discussed under Impact HYD-1 (pages 3.8-18 and 3.8-19 of the Draft EIR). Operational discharges would be addressed through a Water Quality Management Plan (WQMP), and the Preliminary WQMP is in compliance with NPDES requirements and the DAMP. Further, as discussed in Section 3.8 (Hydrology and Water Quality) of the Draft EIR, the first-flush (85-percentile 24-hour storm event or the maximum flow rate of runoff produced from a rainfall intensity of 0.2 inch per hour) and dry-weather flows would be treated by proposed filtration systems proposed as part of the project. BMPs would also be implemented that would address water quality from potential point- and non-point-source contamination. BMPs such as street sweeping and educational programs would address first flush discharges and stormwater flows from 25- and 100-year storm events. RMC(B)-5 Comment noted. The information regarding the improvements to water quality as a result of treatment by the OCSD is acknowledged and supported by information 3-300 City of Huntington Beach Chapter 3 Responses to Comments published in OCSD's website (http://www.ocsd.com/info/runoff/default.asp, January 22, 2004). However, while the program has been successful, there are no funded or proposed plans to expand treatment of all stormwater flows generated throughout the City of Huntington Beach. Therefore, the analysis contained in the Draft EIR does not assume the treatment of project-related flows that are not diverted to the ASWPS, while recognizing that treatment is not currently required by federal, State, or local laws or regulations. RMC(B)-6 This comment notes that dry-weather flows from the majority of the site (26.9 acres) would not be treated by OCSD. The EIR has been revised to discuss that Drainage Area "B" can be routed to the ASWPS, in order that, at the City's discretion, these flows may be routed for treatment by OCSD. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. Nevertheless, please refer to the Topical Response on Water Quality on page 3-173, which discusses why dry-weather runoff would not be required to be treated by OCSD. Filtering and screening are not intended to disinfect stormwater or non-stormwater discharges. Disinfection in order to address bacterial contamination is not required by the SARWQCB, and treatment on-site of flows for bacteria is neither required nor feasible for the proposed project, as further discussed in the Topical Response on Water Quality. RMC(B)-7 Comment noted. This comment correctly summarizes the standards used in the analysis under Impact HYD-1 on pages 3.8-17 through 3.8-19 of the Draft EIR. RMC(B)-8 As stated in the Topical Response on Water Quality on page 3-173, no water quality standards for pathogens have been adopted by agencies with jurisdiction over the project. RMC(B)-9 Please refer to Responses to Comments RMC(B)-10 below and RMC(B)-11 on page 3- 302 that address how the proposed project meets the objectives of ensuring adequate utility infrastructure and public services for the new development and mitigating environmental impacts to the greatest extent possible. RMC(B)-10 As discussed under Impact HYD-2 on page 3.8-21 of the Draft EIR, the project proposes to construct a storm drain line in First Street that would exclusively serve the project site. This line would run parallel to the existing City 36-inch line in First Street. The project-specific storm drain line would then connect to the City's 36-inch South Pacific City EIR 3-301 Chapter 3 Responses to Comments Beach Storm Drain south of PCH. These improvements would ensure that adequate stormwater infrastructure is installed to handle project runoff. Please refer to Response to Comment RMC-54 on page 3-289 for a discussion of why upgrades to the ASWPS are not feasible. As discussed under that response, upgrades to the ASWPS would result in more construction-related impacts than the addition of a storm drain line in First Street that would exclusively serve the project. Please refer to the Topical Response on Water Quality on page 3-173, which discusses why bacterial contamination is not considered a significant impact. RMC(B)-11 Comment noted. This comment correctly states that dry-weather flows to the ASWPS are treated by OCSD. RMC(B)-12 Please refer to the Topical Response on Water Quality on page 3-173, which discusses treatment options for bacteria and pathogens. As discussed in that response, these treatment options would neither be required nor feasible to implement for the proposed project. Contrary to the comment, and as discussed in the Topical Response on Water Quality, there is no adverse impact(of diverting drainage) to be mitigated. RMC(B)-13 The information presented in Table ES-4, the Summary Impact Table on pages xxiv through xxxvii of the Draft EIR, accurately reflects the analysis presented in Section 3.8 (Hydrology and Water Quality) of the Draft EIR. The analysis under Impacts HYD-1 and HYD-2 on pages 3.8-17 through 3.8-23 demonstrates that the project would meet all applicable water quality standards and would not otherwise substantially degrade water quality. Therefore, no mitigation is required. Please refer to the Topical Response on Water Quality on page 3-173, which discusses issues related to bacterial contamination. RMC(B)-14 Please refer to Response to Comment RMC(B)-13 above for a discussion of information presented in the Table ES-4, the Summary Impact Table. RMC(B)-15 Please refer to the Topical Response on Water Quality on page 3-173, for a discussion of why bacterial contamination is not considered a significant impact. Drainage Area "B" can be routed to the ASWPS, in order that, at the City's discretion, these flows may be routed for treatment by OCSD. Additional information on bacterial contamination has been added to Impact HYD-1. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. 3-302 City of Huntington Beach Chapter 3 Responses to Comments RMC(B)-16 Please refer to the Topical Response on Water Quality on page 3-173, which addresses why treatment of runoff for bacteria is not required and why it would not be required nor feasible for the proposed project to treat dry-weather flows for contamination. The basis for determination of Impacts HYD-1 and HYD-2 on pages 3.8-17 through 3.8-23 of the Draft EIR as less than significant includes reliance on adopted water quality standards, which the City has identified as a standard to determine whether impacts to water quality would be significant. Furthermore, neither the City, the OCSD, nor the SARWQCB has funded or planned for the treatment of all runoff by the OCSD. Nevertheless, Drainage Area "B" can be routed to the ASWPS, in order that, at the City's discretion, these flows may be routed for treatment by OCSD. RMC(B)-17 Please refer to Response to Comment RMC(B)-13 on page 302 for a discussion of the determination of less than significant impacts on water quality. The project is consistent with City General Plan objectives and policies, as discussed in Responses to Comments RMC(B)-18 through RMC(B)-22 below. RMC(B)-18 As discussed in the Topical Response on Water Quality on page 3-173, the proposed project would not substantially degrade surface water quality, which is the standard of significance identified on page 3.8-16 of the Draft EIR. Please refer to Response to Comment RMC(B)-4 on page 3-300 for a discussion of why operational discharges would be less than significant. RMC(B)-19 The proposed project would tie into the existing drainage pipe that empties onto South Beach. The project would attenuate stormwater flows to 20 cfs and would contribute only a portion of the discharges in this area. Please refer to Response to Comment RMC(B)-4 on page 3-300 for a discussion of why operational discharges would be less than significant. RMC(B)-20 Please refer to Response to Comment RMC(B)-4 on page 3-300 for a discussion of why operational discharges would be less than significant. RMC(B)-21 Please refer to the Topical Response on Water Quality on page 3-173. Contrary to the comment, ultra-violet and ozone are not the most efficient technology. In fact, those two technologies would be infeasible for the site as addressed in the Topical Response on Water Quality. RMC(B)-22 Policy C 6.1.1, as shown on page 3.8-15 of the Draft EIR states: Pacific City EIR 3-303 Chapter 3 Responses to Comments Require that new development include mitigation measures to enhance water quality, if feasible; and, at a minimum, prevent the degradation of water quality of groundwater basins,wetlands, and surface water. This policy is not aimed at prevention of bacterial degradation of receiving waters. In fact, as discussed under the Topical Response on Water Quality on page 3-173, no standards addressing bacterial contamination have been adopted. Consistency with this policy is demonstrated in Table 3.8-4 on page 3.8-15 of the Draft EIR by indicating that: The proposed project includes as part of its Water Quality Management Plan installation of filtration and screening devices to promote maximum water quality in stormwater runoff. With implementation of this plan and BMPs, the proposed project would be consistent with this policy. With respect to dry weather flows, Drainage Area"B" can be routed to the ASWPS, in order that, at the City's discretion, these flows may be routed for treatment by OCSD. Please refer to the Topical Response on Water Quality for a discussion of this issue. RMC(B)-23 Comment noted. This comment correctly quotes a portion of the cumulative impact analysis on water quality. RMC(B)-24 Please refer to the Topical Response on Water,Quality on page 3-173, which addresses why bacterial contamination is not considered a significant impact. RMC(B)-25 This comment correctly notes that the proposed project has the potential to adversely impact water quality due to its size, proposed uses, and proximity to the beach. This comment also correctly notes that the SARWQCB stated that there is widespread experience that urban development activity impacts water quality. Due to water quality concerns associated with the proposed project, project design features would be incorporated into the proposed project to address runoff concerns. These project design features include site design BMPs, source control BMPs, treatment control BMPs, on-site detention, filtration devices, and WQMP preparation to ensure that operational discharges conform to applicable water quality requirements and that impacts would be less than significant. RMC(B)-26 Please refer to the Topical Response on Water Quality on page 3-173 and Response to Comment RMC(B)-4 on page 3-300, for a discussion of the validity of the methodology used in the hydrology analysis. 3-304 City of Huntington Beach Chapter 3 Responses to Comments RMC(B)-27 As indicated under the Topical Response on Water Quality on page 3-173, a discussion of issues and/or impacts related to bacterial contamination has been added to the Final EIR. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. This discussion clarifies the current regulatory agency policy on the issue of bacterial contamination. The conclusion that impacts would be less than significant under Impact HYD-1 on pages 3.8-17 through 3.8-19 of the Draft EIR remains valid. The Draft EIR fully complies with the requirements of CEQA Guidelines Section 15121, which identifies the purpose of an EIR as an informational document. Pacific City EIR 3-305 Chapter 3 Responses to Comments Response to Comment Letter Bixby (Mr. Mark D. Bixby, December 2, 2003) Bixby-1 Comment noted. The City of Huntington Beach respectfully disagrees with the commenter regarding the wetland indicator vegetation, as will be detailed below in Responses to Comments Bixby-20 through Bixby-28 on pages 3-308 through 3-311, and believes that the Draft EIR is in full compliance with CEQA and the CEQA Guidelines. Regarding vegetation removal, all vegetation removal on-site has been conducted in accordance with the City of Huntington Beach requirements. Vegetation removal on site is part of ongoing site maintenance required so that vegetation on site does not become overgrown. Bixby-2 Comment noted. This comment is an introduction to the commenter's chronological involvement with the proposed project. It does not raise any environmental issues, therefore, no further response is required. Bixby-3 The commenter presents the results of a series of site visits that the commenter made. These visits noted the current state of the site, which included a description of the remediation pits and five species of wetland vegetation that the commenter observed within the project area. The comment does not raise any specific environmental issue; therefore, no further response is required. Bixby-4 Please refer to the Response to Comment Bixby-3 above for a discussion of the commenter's site visit. The comment does not provide any comment on the environmental analysis, so no further response can be provided. Bixby-5 This comment indicates that the information discussed in Bixby-3 above was presented to the Planning Commission on September 9, 2003. The comment does not provide any comment on the environmental analysis, so no further response can be provided. Bixby-6 This comment correctly summarizes grading and vegetation removal, complaints by City residents, and issuance of a cease and desist order by the City on September 11, 2003. While complaints were received, cessation of work was requested through verbal communication from City inspectors, not through issuance of a cease and desist order. As discussed on page 3.3-1 of the Draft EIR, the project site has been disced regularly to maintain the site and prevent the growth of unwanted vegetation. The 3-306 City of Huntington Beach Chapter 3 Responses to Comments comment does not provide any comment on the environmental analysis, so no further response is necessary. Bixby-7 The commenter presents the results of an additional site visit that the commenter made on September 14, 2003. This visit noted four species of wetland vegetation that the commenter observed within the project area. The comment does not raise any specific environmental issue; therefore, no further response is required. Bixby-8 The commenter presents the results of an additional site visit that the commenter made on September 17, 2003 and indicated that remediation process has in-filled certain areas of the site that had ponded water. The comment does not raise any specific environmental issue; therefore, no further response is required. Bixby-9 The commenter presents the results of an additional site visit that the commenter made on September 18, 2003. The commenter photographed dead vegetation and stated that the commenter filed a written complaint with the CCC. The comment does not provide any comment on the environmental analysis, so no further response can be provided. Bixby-10 The commenter presents the results of an additional site visit that the commenter made on September 21, 2003. The comment does not provide any comment on the environmental analysis, so no further response can be provided. Bixby-11 This comment indicates that the information discussed in Response to Comments Bixby-3 through Bixby-10 above was presented to the Planning Commission on September 23, 2003. The comment does not provide any comment on the environmental analysis, so no further response can be provided. Bixby-12 This comment indicates that the information discussed in Bixby-3 through Bixby-10 above was presented in PowerPoint format during City Council Public Comments on October 6, 2003. The comment does not provide any comment on the environmental analysis, so no further response can be provided. Bixby-13 Comment states that more vegetation removal was reported by the residents surrounding the project site. The comment does not provide any comment on the environmental analysis, so no further response can be provided. Pacific City EIR 3-307 Chapter 3 Responses to Comments Bixby-14 The commenter presents the results of an additional site visit that the commenter made on November 16, 2003. This visit noted five species of wetland vegetation that the commenter observed within the project area. The comment does not raise any specific environmental issue; therefore, no further response is required. Bixby-15 Comment states that more vegetation removal was reported by the residents surrounding the project site. The comment does not provide any comment on the environmental analysis, so no further response can be provided. Bixby-16 The commenter presents the results of an additional site visit that the commenter made on November 28, 2003. This visit noted species of wetland vegetation that the commenter observed within the project area. The comment does not raise any specific environmental issue; therefore, no further response is required. Bixby-17 The commenter provides an introductory statement that points out inconsistencies within the Draft EIR. Specific responses to these assertions are detailed in Responses to Comments Bixby-18 through Bixby-24 below. Bixby-18 In response to the comment provided, Table 3.3-1 on page 3.3-4 of the Draft EIR has been revised to reflect the accurate species name for "Crystalline ice plant" and "Sicklegrass." With respect to arrowgrass, the California Native Plant Society notes common arrowgrass as Triglochin concinna, as cited in the Draft EIR. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. PP Bixby-19 The commenter is correct in noting that the common name and species name for saltgrass is inconsistent. The species name have been be revised in Table 3.3-1 of the Final EIR. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. Bixby-20 Neither Heliotropium curassavicum nor Malvella leprosa, which are non-special status wetland indicator species, were observed on the site by either of the consultants who evaluated the site biology (EIP September 24, 2003, and BonTerra December 19, 2001). Nevertheless, failure to detect any species that are not protected under local, State, or federal laws or regulations would not be sufficient grounds to find the Draft EIR inadequate or represent "significant" new information that would trigger a recirculation of the Draft EIR. 3-308 City of Huntington Beach Chapter 3 Responses to Comments Bixby-21 Although the Draft EIR does focus on the remediation areas as the primary portions of the site that contain wetland vegetation, page 3.3-7 of the Draft EIR states that: "Approximately 27.2 acres of disturbed vegetation type is found throughout the proposed project site. This vegetation type is comprised of primarily disced bare ground with ruderal species. These species included black mustard (Brassica nigra), Bermuda grass (Cynodon dactylon)..." Bermuda grass is a wetland indicator species and it is clearly stated that it occurs throughout the site. Bixby-22 The commenter has included a revised table that lists the wetland indicator status of each plant species found onsite. The indicator status is taken from USDA's PLANTS database, which in turn are abstracted from the USFWS 1988 national list of vascular plant species that occur in wetlands. The commenter would like this information added to the Draft EIR. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. • This same list is noted on page 3.3-12 of the Draft EIR where it discusses wetland species. Specifically, the Draft EIR states that, "More than 50 percent of the dominant plant species at the site must be typical of wetlands (i.e., rated as facultative or wetter in the National List of Vascular Plant Species that Occur in Wetlands (NLPSOW)." As the NLPSOW hydric designation does not individually afford any species special status a full discussion of hydric plant characteristics, inclusion of such designations are not required under CEQA. However, Table 3.3-1 of the Draft EIR has been revised to include the wetland indicator status of each plant species noted in the Draft EIR, and include a notation of what each indicator means. Please refer to Chapter 2, Volume III, ,of the Final EIR for specific text changes. Bixby-23 The plant mentioned is the Woolly sea-blight (Suaeda taxifolia). This species is listed on the California Native Plant Society (CNPS) list as a 4 (limited distribution species). It is not afforded any special status or listed as rare by any State, federal, or local agencies. Nor would this species meet the definition of rare contained in Section 15380 of the CEQA Guidelines (generally a CNPS ranking of 2 or lower). As such, the analysis in the Draft EIR is adequate and correctly states that there are no special status species onsite. Bixby-24 Consistent with Section 15126 of the CEQA Guidelines, this EIR examines the project- specific impacts of implementing the proposed project. With respect to biological Pacific City EIR 3-309 Chapter 3 Responses to Comments I - resources, the analysis was based, per CEQA Guidelines (15126.2), on the physical conditions in the affected area, as they exist at the time of the publication of the Notice of Preparation (NOP). At this time, the site was in mid-remediation phase, and impacts were based on multiple surveys that documented the biota that occurs within the site. In reference to the adequacy of the Draft EIR, as stated in Section 15204(a) of the CEQA Guidelines, the adequacy of an EIR is determined in terms of what is reasonably feasible in light of factors such as the geographic scope of the project, the magnitude of -the project, and the severity of the likely environmental impacts. As further expressed in Section 15151 of the CEQA Guidelines, "An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible."In this case, multiple surveys of the site were performed, and although they did not cover the blooming periods of every plant in the survey, per CEQA Section 15151, potential habitat to support annual upland plant species can be identified year-round and wetland indicator species can be identified any time of the year. Thus, the surveys would be sufficient to allow for the quantification of impacts to biota. Furthermore, the CDFG, USFWS, and CNPS do not require that the surveys are conducted during blooming season, just that they are "Conducted in the field at the proper times of year when special status and locally significant plants are both evident and identifiable." As such, the surveys and assessment within the Draft EIR are adequate under current CEQA guidelines. The commenter also questions the applicability of MM BIO-1 on page 3.3-24 of the Draft EIR, given the current level of disturbance at the site. As stated within Impact Bio-5 on page 3.3-21 of the Draft EIR, the implementation of a permitted remediation plan currently inhibits the assessment of the normal conditions of the site. To ensure that the potential impacts to CDFG wetlands are less than significant after the remediation is complete, MM BIO-1 was identified. This mitigation is designed to assess normal conditions of the site (i.e., those at grade) and require that all applicable State and federal permits be obtained. This mitigation is consistent with Sections 15126.4(a)(1)(A), 15126.4(a)(1)(B), 15126.4(a)(2), and 15126.4(a)(4)(B) of CEQA. The mitigation provided for impacts to biological resources is designed to meet or exceed agency standards via the agency oversight of the final permit approval process. In those cases where the mitigation meets agency standards or requirements, those standards and requirements have been developed, in part, for the purpose of 3-310 City of Huntington Beach Chapter 3 Responses to Comments providing guidance as to proportionality between an impact and proposed mitigation, either on a general basis (i.e., "no net loss" of wetlands) or on a project-specific basis (i.e., pre-construction surveys for wetland species). Bixby-25 Because the commenter does not raise any specific environmental issue, no further response can be provided. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Bixby-26 The use of natural treatment systems such as wetlands is not part of the project description or alternatives, and, thus, is not analyzed under CEQA. The use of the StormFilter filtration devices are proven technology that would achieve the water quality standards applicable to the site. The homeowners association on-site would be required to maintain filtration devices to ensure their effectiveness over the long term. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Bixby-27 Because the commenter does not raise any specific environmental issue, no further response can be provided. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Bixby-28 The commenter is correct in stating that BonTerra found six wetland indicator species in December 2001 and EIP Associates found seven more in September of 2003. Project biologists have not observed the two species that the commenter has reported as being present. Please refer to Responses to Comments Bixby-20 and Bixby-24 on pages 3- 308 through 3-309 for a discussion of the biological surveys completed to date. Bixby-29 Please refer to Response to Comment Bixby-24 on page 3-309 for a discussion of the biological surveys completed to date and the requirement for additional surveys pursuant to Mitigation Measure BIO-1 on page 3.3-24 of the Draft EIR. Bixby-30 As stated in CEQA Guidelines (15126.2), the lead agency should normally limit its examinations to changes in the existing physical conditions in the affected area as they exist at the time of the publication of the Notice of Preparation (NOP). Continued surveys would not be required. Please refer to Response to Comment Bixby-24 on Y q P Y Pacific City EIR 3-311 Chapter 3 Responses to Comments page 3-309 for a discussion of the biological surveys completed to date and the requirement for additional surveys pursuant to Mitigation Measure BIO-1 on page 3.3- 24 of the Draft EIR. Bixby-31 Please refer to Response to Comment Bixby-24 on page 3-309 for a discussion of the biological surveys completed to date and the adequacy of the surveys under CEQA. Bixby-32 As stated in Impact BIO-5 on page 3.3-21 of the Draft EIR, the City has approved Coastal Development Permit (CDP) 00-09 and Conditional Use Permit (CUP) 00-36. Part of the approved remediation plan would cover the filling of the pits. Bixby-33 Because the commenter does not raise any specific environmental issue, no further response can be provided. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Bixby-34 The commenter would like that the vegetation be allowed to grow on site. As stated in Impact BIO-5 on page 3.3-21 of the Draft EIR, the City has approved Coastal Development Permit (CDP) 00-09 and Conditional Use Permit (CUP) 00-36, which allows for remediation of the site. The Applicant is also responsible for preventing overgrown vegetation on the site, as site maintenance has been occurring on-site since 1998 and is not part of the activities associate with soil remediation. This comment is acknowledged, and the opinion of the commenter will be provided to the decision- makers for review and consideration during their deliberations of whether or not to approve the proposed project. Bixby-35 The commenter would like the proposed project to be altered to include mini-wetlands to increase the aesthetic and habitat values of the site. The use of natural treatment systems such as wetlands is not part of the project description or alternatives, and thus is not analyzed under CEQA. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. 3-312 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Letter Cross (Mr. Paul Cross, November 14, 2003) Cross-1 From certain locations north of the project site, limited views of the ocean are visible. However, due to local topography in the area as well as existing development, no extensive public views of the ocean are available from north of Atlanta Avenue. Thus, these intermittent views do not constitute scenic vistas. A representative public view of the coast from north of the project site is provided in Figure 3.1-13 on page 3.1-16 of the Draft EIR (view south from Manning Park), and, as illustrated in this figure, impacts on the viewshed would be minimal. As stated in Impact AES-2 on page 3.1-30 of the Draft EIR, views from north of Alabama Avenue are from private locations, and effects to these views are not, therefore, considered by the City to be significant. Further, the project site is zoned as Downtown Specific Plan (DTSP) Districts 7 and 8A, which indicates that the City has intended the property for Downtown, coastal development. As stated on page 3.1-26 of the Draft EIR in project consistency for Policy ERC-4.1.5 (Table 3.1-2), there are no public view corridors from or through the project site. View corridors along First Street would be maintained, consistent with other north-south streets in the City that provide sight-lines to the coast. Intermittent views of the ocean are available along Huntington Street between Pacific View and Atlanta Avenue. As discussed under Impact AES-2 on page 3.1-30 of the Draft EIR, due to intervening topography, these views are not considered scenic vistas. Some existing views of the ocean from portions of Huntington Street would be blocked by proposed development. However, pedestrians accessing the project site would have views from the project site of the ocean, which would be far more expansive than those currently available from either Huntington Street south of Atlanta Avenue or areas north of Atlanta Avenue. Cross-2 As discussed on page 3.14-37 of the Draft EIR, street improvements as part of the proposed project include the widening of the west side of Huntington Street by approximately 10 feet. As shown in Table 3.14-14 on page 3.14-50 and Table 3.14-16 on page 3.14-56 of the Draft EIR, the roadway link of Huntington Street from Atlanta Avenue to Pacific View Avenue would continue to operate at LOS A in both Year 2008 and Year 2020 scenarios. Therefore, no significant impact to Huntington Street would occur, and no additional improvements to the street would be required. Pacific City EIR 3-313 Chapter 3 Responses to Comments Cross-3 Based on the shadow renderings provided in Appendix K to the Draft EIR, shadows on the mobile home park would be present at one of the four times during the year for which diagrams were made, the Winter Solstice. As described on page 3.1-34 of the Draft EIR, the threshold of significance for shadow impacts is three hours of shadow on adjacent residential or other light-sensitive uses, a threshold that is consistent with previous environmental studies prepared by the City and is an accepted industry standard. Impact AES-4 on pages 3.1-34 through 3.1-37 of the Draft EIR concluded that shadows cast by proposed project would not result in a significant impact from shading of the mobile home residences. These shadows would have a duration of less than three hours between the hours of 9:00 A.M. and 3:00 P.M., and would not, therefore, exceed the threshold of significance for the impact. Consequently, no further mitigation would be required. With regard to the request for a landscaped median strip along Huntington Street, the Draft EIR concluded, as described on pages 3.1-32 to 3.1-34, that the proposed project would not substantially degrade the existing visual quality of the project site or its surroundings. A discussion specific to the views of the project from the Pacific Mobile Home Park (Viewpoint 1) is provided on page 3.1-32 of the Draft EIR and concludes that the proposed landscaping (which would include a mix of trees and shrubs) would, in combination with the proposed setbacks and variations in building height and rooflines, sufficiently soften the appearance of the proposed development, and no significant impact would occur. Further, the land use impact analysis concluded, on - -, page 3.9-21 of the Draft EIR, that, "While the intensity of development would increase, in terms of the number of units per acre and the total mass of development, the increased intensity in land use would not result in inherent conflicts with similar adjacent [i.e., residential] uses," and also that "existing residential uses would be separated from nonresidential uses on the west, east, and north by roadways a minimum of 80 feet in pavement width, landscaping, and screening vegetation," and no significant land use compatibility impact was determined to occur. Consequently, no additional mitigation, such as a landscaped median strip, would be required to reduce this impact with respect to the Pacific Mobile Home Park. Cross-4 As described on pages 2-23 to 2-26 of the Draft EIR, pedestrian access improvements provided with the proposed project include a series of pedestrian pathways that would connect the residential component of the project to the commercial component and to 3-314 City of Huntington Beach Chapter 3 Responses to Comments the beach parking lot. As required by the DTSP, these pathways include "the dedication, or a waiver thereof, of a 20-foot-wide corridor between Atlanta Avenue and PCH for public access between the southern end of the Pacific Electric ROW and PCH" (emphasis added). The purpose of the ROW is the provision of public access to the coast through the project site. As discussed on page 3.14-37 of the Draft EIR, a 20- foot-wide pedestrian access easement would be dedicated through the project site that extends from the south side of Atlanta Avenue, at Alabama, to Pacific View Avenue at the easterly residential access driveway. This would allow pedestrians to cross at the all-way stop sign to access the project site. As discussed in Table 3.1-2 on page 3.1-26 of the Draft EIR, no public view corridors currently exist from the project site, and as discussed on page 3.1-31 of the Draft EIR, "access to the Pacific Ocean as a scenic resource from the project site is currently unavailable, and the project would provide access to these viewing opportunities." No loss of coastal access from or through the project site would occur as a result of the proposed project, and the City has determined that the proposed project would be consistent with the intent and requirements of the CCC and the City regarding the provision of a public access corridor. Consequently, no significant impact would occur with respect to access, and no mitigation would be required. Cross-5 The proposed project would raise the existing ground surface level for portions of the site to accommodate development, including building pads and subterranean garages. However, the datum for the height of the proposed structures is set at the highest adjacent street level along the front property line (i.e., at the curb of First Street for the residential portion of the project), as required by Section 4.0.04, "Height" and "Street Level" definitions of the DTSP. The height limits imposed by the DTSP for Districts 7 and 8A are, therefore, measured from this point and were understood by the CCC to be measured from these points when the CCC approved the DTSP, thereby authorizing the height limits set forth. When measured from these points, the heights of the buildings of the proposed residential village would not, as discussed on page 2-16 of the Draft EIR, exceed the height limit of 50 feet and would, therefore, be consistent with the DTSP and with the intent of the CCC. The Applicant neither proposes nor seeks approval for six-story building heights in the residential village portion of the project (DTSP District 8A). Pacific City EIR 3-315 Chapter 3 Responses to Comments As discussed in Impact AES-3 on pages 3.1-31 through 3.1-32 of the Draft EIR, the proposed eight-story hotel towers would also be within the height limits specified in the DTSP and would be constructed proximate to the adjacent hotel, providing a transition to the lower-scale, three-story commercial development on the western portion of District No. 7, which is similar in size and massing to the commercial development near the Downtown core. As discussed on page 2-30 of the Draft EIR, the project requires a Coastal Development Permit, Conditional Use Permit, and Design Review Board approval, each of which addresses the building heights of development on the project site. The comment asserts that the proposed Pacific View Avenue is "an entirely different street" from the Walnut Avenue extension described in the DTSP. The proposed Pacific View Avenue in fact serves as the Walnut Avenue extension, as depicted by the contours of Districts 7 and 8A on pages 50 and 53, respectively, of the DTSP, and for which setback and ROW dedication requirements are described in Sections 4.09.08 and 4.10.06 of the DTSP for Districts 7 and 8A, respectively. Further, as described on page 2-22 of the Draft EIR, the proposed alignment of Pacific View Avenue would comply with Precise Plan of Street Alignment(PPSA) 88-1 that was previously adopted by the City for the roadway. Although the proposed street does not precisely follow the natural contour of the site, the contour along the proposed street alignment has been extensively modified by erosion and previous excavation. However, notwithstanding this, the proposed Pacific View Avenue would generally follow the existing downhill slope of the site from First Street to Huntington Street, though with a slightly steeper initial grade at Huntington Street. Please also refer to the Responses to Comments Cross-1 on page 3-313 and Cross-4 on page 3-314 for discussion of public views and view corridors from and through the project site, and the effects of the proposed project on scenic views. Cross-6 The proposed project would satisfy all requirements provided by OCTA regarding bus facility improvements. A bus turnout would be provided along PCH, north of Huntington Street, which would adequately serve the proposed project. Cross-7 As discussed under Impact TR-10 on pages 3.14-75 and 3.14-76 of the Draft EIR, the proposed project would not substantially increase roadway hazards, including 3-316 City of Huntington Beach Chapter 3 Responses to Comments vehicular/pedestrian traffic conflicts. Consequently, no mitigation would be required. Further, the proposed widening of some road segments surrounding the project site is proposed to accommodate the anticipated traffic generated as a result of the proposed project. First Street and Atlanta Avenue would not, therefore, be considered "too wide" or "unacceptable," and no modification of the proposed ROW would be required. Cross-8 As discussed in Impact REC-1 on pages 3.13-11 and 3.13-12 of the Draft EIR,'the proposed project does not include the provision of the 6.9 acres of parkland required under Section 254.08 of the City ZSO. However, implementation of MM REC-1 on page 3.13-13 of the Draft EIR requires that the project demonstrate compliance with the provisions of the ZSO prior to occupation of the first residential unit. Fulfillment of this measure could occur through any combination of on- or off-site parkland dedication and in-lieu fee payment. As noted in the comment, the City has contemplated and may, at its discretion, require the dedication of parkland on-site as a condition of approval of the project. With implementation of MM REC-1, the proposed project would not violate the parkland requirements of the City. Please refer to Response to Comment Cross-5 on page 3-315 for a discussion of the heights of the proposed grade and structures on the project site, and compliance of these heights with the DTSP and ZSO. Please refer to Response to Comment Cross-7 on page 3-316 for further discussion regarding the necessity of narrowing the proposed First Street ROW. Cross-9 The residential portion of the project site is zoned as DTSP District 8A and is governed by the density requirements contained in the relevant sections of the DTSP. As described on page 3.9-20 of the Draft EIR, the land use designations for the project site have been evaluated on a programmatic basis in previous environmental documents and, as described in Response to Comment Cross-5 on page 3-315, have been approved by both the City and the Coastal Commission. Further, the development standards associated with these designations have also been previously evaluated from a planning perspective by the City, as the City continuously reviews the DTSP Village Concept, which contains the development standards. The current Village Concept is dated February 6, 2002. Also, as discussed on page 2-30 of the Draft EIR, the project requires a Coastal Development Permit, Conditional Use Permit, and Design Review Pacific City EIR 3-317 Chapter 3 Responses to Comments Board approval, each of which addresses the building heights of development on the project site. Also, please refer to Response to Comment Verbal-25 on page 3-324 for further discussion of the design of the proposed project with respect to the intent of the site designations and the General Plan subareas. Cross-10 Pages 3.11-9 and 3.11-10 of the Draft EIR discuss current and future needs for affordable housing in the City. Impact P-2 on page 3.11-16 of the Draft EIR discusses preliminary proposals for new affordable housing units both on- and off-site. While the Draft EIR acknowledges that impacts would be potentially significant in the absence of a final, City-approved plan for project-related affordable housing, implementation of MM P-1, as discussed on page 3.11-18 of the Draft EIR, would ensure that affordable housing requirements of the Community Redevelopment Law would be met, and the associated impacts would be reduced to a less-than-significant level. Further, the project would not result in the loss of any mobile home units, and does not propose to widen Atlanta Avenue onto the Mobile Home Park. Cross-11 Please refer to Response to Comment Cross-5 on page 3-315 for a discussion of project grade and building height levels, as well as the measurement of these levels under the City ZSO and consistency of these levels with the applicable provisions of the DTSP, which was adopted by the City and approved by the CCC. Also, please refer to the Responses to Comments Cross-1 on page 3-313 and Cross-4 on page 3-314 for a discussion of public views from and through the project site, and the effects of the project on scenic views. Cross-12 The 66-kV electrical line along Atlanta Avenue would not be placed underground because, due to cost and logistical considerations, the City's Underground Utility Ordinance does not require undergrounding electrical lines that carry 66-kV or more. Further, the presence of the existing 66-kV lines is an existing condition and not an effect of the proposed project. Cross-13 Pedestrian linkages would be provided to allow access from the residential village through the visitor-serving commercial component of the project site to PCH and the beach. Installation of a sidewalk on the north side of Atlanta Avenue constrains existing residences and results in alignment issues through Huntington Street. The installation 3-318 City of Huntington Beach Chapter 3 Responses to Comments of a pedestrian signal at Alabama and Atlanta is not warranted with the development of the proposed project. As shown on the project plans, the project is proposing all street improvements to accommodate the project traffic and pedestrian volumes. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Cross-14 Construction timing is based upon market conditions and is necessary to establish a population base to help support the commercial uses of the project. Further, a contraction of the construction schedule in order to complete work within 2 years could increase construction traffic, air, and noise impacts as construction traffic and activity at the project site could substantially increase daily activity. This comment is acknowledged, and the opinion of the commenter will be provided to the decision- makers for review and consideration during their deliberations of whether or not to approve the proposed project. Cross-15 The City Fire Department is the local oversight agency for the project. As discussed in MM HAZ-4 and MM HAZ-6 on page 3.7-21 of the Draft EIR, closure reports or other reports documenting the successful completion of required remediation activities for contaminated soils, in accordance with City Specification 431-92, must be submitted to and approved by the City Fire Department prior to issuance of grading permits for site development. All soil testing and conclusions reached based upon this testing, regardless of the entities performing the work, must be approved by the City Fire Department. Pacific City EIR 3-319 Chapter 3 Responses to Comments Response to Verbal Comments (Pacific City Draft EIR Public Meeting, November 13, 2003) Verbal-1 The traffic study was prepared to analyze future traffic conditions resulting from implementation of the proposed project on the nearby street network. As such, the future roadway configurations anticipated in Year 2020 were used to determine trip distribution. Planned traffic improvements proposed as part of the project are discussed on page 3.14-30 of the Draft EIR, and do not include the extension of Delaware Street. Although this extension may eventually occur, it would occur independently of the proposed project. Please refer to Response to Comment PCAC-54 on page 3-240 for -- further information on the Delaware Street extension. Verbal-2 Impacts from the extension of Delaware Street would not occur as a part of the proposed project. At the time that this improvement is undertaken, analysis would be performed identifying the City-wide changes to circulation patterns. Please refer to Response to Comment PCAC-54 on page 3-240 for further information on the Delaware Street extension. Verbal-3 All comments received during the scoping period were reviewed and considered during the preparation of the Draft EIR. However, as required under CEQA, individual comments are not directly responded to until after the public review period of the Draft EIR, which are then compiled in the Final EIR. Verbal-4 The planning for this project completed by the City and Applicant is separate from that of CEQA compliance and completing CEQA required environmental documentation. Thus, no further comment is required on the timeframe of the City's planning process. However, it should be noted that completion of the Draft EIR has followed a typical schedule for CEQA review of projects of the scope and complexity presented under the proposed project. Verbal-5 Construction timing is based upon market conditions and is necessary to establish a population base to help support the commercial uses of the project. This comment is acknowledged, and the opinion of the commenter will be provided to the decision- makers for review and consideration during their deliberations of whether or not to approve the proposed project. 3-320 City of Huntington Beach Chapter 3 Responses to Comments Verbal-6 Please refer to Response to Comment Cross-15 on page 3-319, which addresses why no independent study to characterize soil remediation conditions is necessary. Verbal-7 Please refer to Response to Comment Cross-1 on page 3-313 for a discussion of existing intermittent views available from Huntington Street and the effects of the proposed project on these views. Verbal-8 Please refer to Response to Comment Cross-7 on page 3-316 for a discussion of impacts regarding pedestrian hazards and the necessity of reducing the proposed width of First Street. Verbal-9 Please refer to Responses to Comments Bixby-19 and Bixby-20 on page 3-308 and Bixby-22 on page 3-309, which address issues related to biological resources. Verbal-10 Please refer to Responses to Comments Cross-1 on page 3-313, Cross-4 on page 3- 314, and Cross-5 on page 3-315 for discussions of the heights of the proposed structures and effects on existing views through and from the project site. Verbal-11 The planned traffic improvements included as part of the proposed project are included on pages 3.14-30 and 3.14-37 of the Draft EIR. Impacts to all intersections and roadway segments would be less than significant, with the exception of the intersection of PCH and Warner Avenue under the Year 2008 scenario and the intersection of PCH and Seapoint Avenue in Years 2008 and 2020. Implementation of MM TR-1 on page 3.14-78 of the Draft EIR would improve the Year 2008 LOS at the PCH and Warner Avenue intersection, under the City criteria, from LOS E and LOS F during the AM and PM peak hours, respectively, to LOS C and LOS D. However, since this improvement is not under the jurisdiction of the City, it is possible that it may not be implemented. MM TR-2 on page 3.14-78 of the Draft EIR would reduce the impact on the intersection of PCH and Seapoint Avenue in Years 2008 and 2020 to a less-than- significant level. Verbal-12 Please refer to Responses to Comments Churchin-1 through Churchin-6 on pages 3- 327 through 3-329, following the Responses to Verbal Comments. Verbal-13 Please refer to Response to Comment Cross-2 on page 3-313, which addresses why widening of Huntington Street beyond that proposed by the proposed project is not warranted. Pacific City EIR 3-321 Chapter 3 Responses to Comments Verbal-14 Please refer to Response to Comment Cross-3 on page 3-314, which discusses the issues of shadows resulting from the proposed project. Verbal-15 Potential views of development onto neighboring properties is not a physical environmental effect, and does not require analysis under CEQA. However, a basic assessment of visual privacy for the proposed project yielded the following conclusions. Some intermittent views into the mobile home park would be available from Pacific City residences. These views would be limited to mobile homes along the Huntington Street frontage, a maximum of 22 homes. However, as shown in Figures 3.1-16 and 3.1-17 in the Draft EIR, intervening structures would obscure these views, including sunshades and carports, the existing 6 foot-tall wooden fence along the Huntington Street frontage, vegetation on the fence, and sporadic vegetation between the fence and residences, including mature trees. These views would also be obscured by the vegetation proposed with the project, including trees that would be planted both along the street and within the property line. Further, as described on page 3.1-41 of the Draft EIR and shown in Figure 3.1-16, no residential windows are visible along the lower levels of some portions of Huntington Street. Finally, views would also be attenuated by distance. As shown in project site plans (c.f. Figure 2-3a in the Draft EIR), the proposed residential structures would be separated from the nearest mobile homes by over 70 feet, further degrading visibility. Therefore, no substantial degradation of residential privacy would occur as a result of the proposed project. Verbal-16 This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Verbal-17 Please refer to Response to Comment Cross-5 on page 3-315, which discusses project mounding issues. Verbal-18 Please refer to Response to Comment Cross-4 on page 3-314, which discusses public views from the project site. Verbal-19 The comment in favor of the commercial portion of the project is acknowledged. Regarding the comment on the density of the residential sections, as stated on page 3.9-20 of the Draft EIR, these land use designations were evaluated programmatically in prior environmental documentation and have, thus, been 3-322 City of Huntington Beach Chapter 3 Responses to Comments approved. The project site is zoned as Downtown Specific Plan (DTSP) Districts 7 and 8A, which indicates that the City has intended the property for Downtown, coastal development; thus, the project site is zoned for density levels accordingly. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Verbal-20 Please refer to Response to Comment Verbal-19 on page 3-322. Pier Colony is an attached-unit condominium project that differs from the proposed development and includes a number of separate structures and separate entries to individual units. Verbal-21 As discussed on pages 3.14-30 and 3.14-37 of the Draft EIR, street improvements to both Atlanta Avenue and Huntington Street would occur as part of the proposed project. The widening of Huntington Street by 10 feet would occur along the project frontage between PCH and Pacific View Avenue. As shown in Table 3.14-12 on page 3.14-41 of the Draft EIR, the intersections of Huntington Street at Atlanta Avenue, as well as Delaware Street at Atlanta Avenue would operate at acceptable levels of service during both Year 2008 and 2020 conditions with the proposed project. Therefore, no improvements to these streets beyond those identified in the Draft EIR would be required. Verbal-22 No mobile homes would be lost as a result of the proposed project. Since this comment does not address an environmental issue associated with the proposed project, no further response is required. Verbal-23 There is no nexus between this request and project impacts, as the proposed project would not significantly impact pedestrian circulation. The project would provide a sidewalk on the south side of the Atlanta Avenue project frontage. Installation of a sidewalk on the north side of Atlanta Avenue would result in effects on the adjacent existing residences and create an alignment constraint between the east and west sides of Huntington Street. Verbal-24 Please refer to Response to Comment PCAC(C)-7 on page 2-260, which addresses pedestrian access through the project site. In addition, please refer to Response to Comment Verbal-23 above, which addresses sidewalks on Atlanta Avenue. Pacific City EIR 3-323 Chapter 3 Responses to Comments Verbal-25 As discussed in Section 3.9 (Land Use and Planning) of the Draft EIR, the project complies with the commercial visitor and residential high-density designations and fulfills the intent of the General Plan Subareas 4C and 4I. In addition, the project complies with the requirements of District No. 7, "Visitor-Serving Commercial" and District No. 8A, "High Density Residential," which allows a maximum of 30 units per net acre. The City General Plan provides the "blueprint" for development throughout the City and assigns density to individual parcels based on a complex of factors including site-specific constraints, surrounding uses, total housing needs projected in the City, among others. Density of the development behind the Hyatt site was based on the site-specific needs determined for that site and is not related to the density requirements identified for the proposed project. Verbal-26 As discussed on pages 2-23 through 2-26 of the Draft EIR, the project would provide pedestrian corridors throughout the project site in order to link the surrounding residential communities and the proposed residential component. These accessways, as detailed in Table 2-8 on page 2-20 of the Draft EIR are consistent with Specific Plan objectives and generally would provide access from inland areas to the proposed visitor-serving commercial uses as well as to the beach. Improvements would connect the commercial component and PCH, the residential component and Atlanta Avenue, the residential component and Huntington Street, the residential component and First Street, and the commercial component and Pacific View Avenue. This comment is acknowledged, and the opinion of the commenter will be provided to the decision- makers for review and consideration during their deliberations of whether or not to approve the proposed project. Verbal-27 Specific commercial uses have not been identified for the project site, although amplified music could occur associated with the restaurants, nightclubs, and promenade and plaza areas. The potential for specific commercial operations to generate nuisance noise would be evaluated as part of the approval process for each commercial use that locates within the project site. Mandatory compliance with the City's Noise Ordinance would reduce potential impacts to less-than-significant levels. Based on the proposed site plan, however, the commercial uses would front Pacific Coast Highway. Noise from music and other activities are expected to be directed toward the coast and away from the new and existing homes in the area. In addition, commercial buildings would 3-324 City Huntington on Beach gt Chapter 3 Responses to Comments act as noise barriers between the front of the restaurants, bars, etc. and the nearby homes. Verbal-28 The project would provide economic growth opportunities for the community through the development of the project's dining/retail/entertainment center, consistent with the General Plan goals as well as employment opportunities for local and area residents. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Verbal-29 Implementation of MM REC-1 on page 3.13-13 of the Draft EIR would bring the project into compliance with the City parkland requirements. Therefore, either parkland dedication (i.e., the dedication of the Village Green as parkland) or payment of in-lieu fees as parkland substitution would be required. This comment is acknowledged, and the opinion of the commenter will be provided to the decision- makers for review and consideration during their deliberations of whether or not to approve the proposed project. Verbal-30 The project would be developed in accordance with the General Plan and DTSP to reinforce the identity of the Downtown area and provide coordinated design elements throughout the area. This comment is acknowledged, and the opinion of the commenter will be provided to the decision-makers for review and consideration during their deliberations of whether or not to approve the proposed project. Verbal-31 Please refer to Response to Comment Verbal-29 above for a discussion on parkland requirements. Verbal-32 Please refer to Responses to Comments LBBS-1 through LBBS-30 on pages 3-216 through 3-223, which address the comments raised by this commenter. Verbal-33 Please refer to Response to Comment Verbal-26 on page 3-324 for a discussion of public access to the site. Verbal-34 Additional discussion has been added to the Final EIR to identify the potential for lighting directed upwards onto building facades in a manner that would result in nighttime illumination effects. An additional mitigation measure has been Pacific City EIR 3-325 Chapter 3 Responses to Comments -- recommended in the Final EIR to including lower lighting levels during periods of fog, in order to reduce nighttime illumination from the project site. Verbal-35 Please refer to Response to Comment HBEB-21 on page 3-209, which discusses monitoring that would occur during project construction. Verbal-36 Please refer to Response to Comment Cross-6 on page 3-316 for a discussion of how transit would be accommodated within the proposed project. Verbal-37 The 66-kV electrical line along Atlanta Avenue would not be placed underground, as undergrounding of electrical lines 66-kV and over is not required by the City's - Underground Utility Ordinance due to cost and logistical considerations. Verbal-38 As discussed under Impact TR-8 on page 3.14-68 of the Draft EIR, the proposed project would provide adequate parking. The existing amount of off-site parking spaces on the surrounding streets to the project site would be replaced under the proposed project. In addition, with a proposed on-site parking supply of 1,543 parking spaces, a theoretical parking surplus of eight spaces is forecasted at peak demand times. Verbal-39 Please refer to Response to Comment PCAC-54 on page 3-240, which addresses the Delaware Street extension. Verbal-40 As discussed under Impact TR-6 on page 3.14-67 of the Draft EIR, a traffic signal is proposed at Huntington Street and Atlanta Avenue. 3-326 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Churchin (Attachment to Verbal Comments) (Mr. Mike Churchin) Churchin-1 As discussed on page 3.7-10 of the Draft EIR, the 2002 Remediation Plan indicated that further soil investigations were conducted on the project site to evaluate the depth of petroleum hydrocarbon-impacted soils near groundwater. The results of these soil investigations have not yet been completed at this time. However, the groundwater beneath the project site is brackish due to saltwater intrusion and is not used as potable water by the City. As a State agency with jurisdiction over water quality, the SARWQCB has the authority to issue a Cleanup and Abatement Order for violation of surface water and groundwater quality standards. There are no records to indicate that such an order has been issued for the project site. Churchin-2 As discussed on pages 3.7-7 through 3.7-8 of the Draft EIR, approximately 200,000 cubic yards of soil material was exported in 1999 from the northern portion of the project site for the development of the Hyatt Regency Resort. The initial testing of these soils, prior to export, revealed evidence of contamination. Subsequently, prior to export of the soil, it was remediated to meet City Specification 431-92 criteria. The "Final Environmental Closure Report" for the Hyatt site provided documentation to indicate that this exported soil, which was initially contaminated, has been remediated. There has been no change in the information that the City has put forth on the status of soils exported to the Hyatt site; these soils were originally identified as contaminated, then, following remediation of the soils, they were identified as "clean" in accordance with City Specification 431-92 criteria. Thus, there is no conflict between the information provided in the Draft EIR and the "Final Environmental Closure Report" for the Hyatt. Churchin-3 According to the 1996 Phase II Investigation, testing for potentially contaminated soil, groundwater, or other materials were performed at the locations where former Above Ground Storage Tanks (AST), pipelines, and oil wells existed. As such, an extensive survey of the project site was not performed, and all contamination was not identified. As discussed on page 3.7-9 of the Draft EIR, additional soil investigation was performed on behalf of Chevron from July to September 1999 at the project site to evaluate if further soil remediation efforts were required. During q these soil Pacific City EIR 3-327 Chapter 3 Responses to Comments investigations, trenches were cut in an extensive fashion and soil samples were !_, collected at both shallow and deep locations within the trenches. Thus, the higher concentration of hydrocarbons is a result of more extensive soil sampling at the project site. A detailed report documenting this contamination has not been submitted to the City. The test results and maps identifying the location of the 1999 testing are contained on Plates 2 and 3 in the Remediation Plan, Revision 3, identified as Harding ESE 2002b in the EIR. Churchin-4 The statement that"no documentation exists to support the existence of a gas plant" is correct. However, the Draft EIR takes a conservative approach and addresses the reasonable worst-case scenario. As such, the potential contamination if a gas plant did exist, is disclosed. Documentation or other evidence of a former gas plant could include information from aerial photos, Sanborn maps, City records, and anecdotal information. On December 18, 2003, the former Chevron employee (Mr. Rick Sailor) was contacted by EIP Associates to clarify the information he provided in the Phase I concerning the identification of a former gas plant north of the project site, at the corner of First Street and Atlanta Avenue. Mr. Sailor indicated that he was misquoted by the Phase I study, and that the facility was a former gas booster plant. In addition, Mr. Sailor indicated that the gas booster plant was located in the northern portion of the project site, and not on the adjacent property. This information is confirmed by a 2003 work plan submitted to the Huntington Beach Fire Department for the supplemental soil investigation at the project site. The gas booster plant did not process gas or petroleum product. Rather, it served as a compressor system that transferred gas from the oil field beneath the project site and delivered it to a gas plant located at the intersection of Palm Avenue and Goldenwest Street. Gas was drawn from the former oil field through a pipeline connected to the booster plant, and then transferred to the gas plant at Palm Avenue and Goldenwest Street. Natural gas was, therefore, fully enclosed within the intake pipe at the booster plant and the plant itself. According to the Supplemental Soil Investigation Work Plan submitted by Blasland, Bouck & Lee, Inc. (BBL) to the Huntington Beach Fire Department, this facility was demolished and all identified stained and odorous soil were excavated and removed from the property in the late 1960s to early 1970s (BBL 2003). Soil samples confirming complete clean-up from previous uses on-site, including this facility, will be provided in the site closure report. 3-328 City of Huntington Beach Chapter 3 Responses to Comments Page 3.7-5 of the Draft EIR has been revised to reflect this updated information. Please refer to Chapter 2, Volume III of the Final EIR for specific text changes. Churchin-5 The potential for toxic contaminants to remain in the soil was identified in the Phase I report, which identified the possibility of a former gas plant on the site. Misinformation regarding the former gas plant has been clarified, as discussed in Response to Comment Churchin-4 on page 3-328. Page 3.7-5 of the Draft EIR has been revised to reflect this change, as no contamination from the gas booster plant is anticipated. Please refer to Chapter 2, Volume III, of the Final EIR for specific text changes. Any contamination resulting from natural gas and the associated booster plant on the project site would be identified through the sampling effort on-site. As discussed in Section 3.7 (Hazardous Materials) of the Draft EIR and shown in Figure 3.7-1 on page 3.7-8 of the Draft EIR, contamination on the majority of the site has been characterized. Areas on the site are classified as one of the following: (a)remediation complete; (b)remediation underway; (c)remediation to be completed during project construction; or (d)further investigation necessary. BBL intends to perform sampling in "Area D" to ensure that all potential contamination has been identified. In addition, the Supplemental Site Investigation Work Plan submitted by BBL to the City Fire Department in November 2003 indicated that sampling is also proposed in the northern portion of the site (referred to as "Area A" in the Draft EIR and where the former gas booster plant was located), where remediation has been completed, as due diligence to ensure that all contamination has been addressed in this area. These sampling efforts would ensure that contamination associated with petroleum extraction, including associated natural gas, on-site has been fully characterized. Churchin-6 Please refer to Response to Comment Churchin-5 above for information on site characterization. All available information on site characterization has been made accessible to the public. Pacific City EIR 3-329 Chapter 3 Responses to Comments Response to Comment Card Bixby (A) Mr. Mark D. Bixby (November 13, 2003) Bixby(A)-1 Please refer to Responses to Comments Bixby-1 through Bixby-35 on pages 3-306 through 3-312 for a discussion of biological resources. II 3-330 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Card Brucculeri Mr. Frank C. Brucculeri (November 14, 2003) Brucculeri-1 Please refer to Response to Comment LBBS-2 on page 3-216 for a discussion of the Oil Overlay "C" as described in Section 4.14.03 and Response to Comment LBBS-17 on page 3-221 for a discussion of on-site slant drilling. Pacific City EIR 3-331 Chapter 3 Responses to Comments Response to Comment Card Calonico Mr. Al Calonico (November 13, 2003) Calonico-1 Please refer to Response to Comment Verbal-11 on page 3-321 for a discussion of traffic patterns surrounding the project site. 3-332 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Card Churchin (A) Mr. Mike Churchin (November 13, 2003) Churchin(A)-1 This commenter calls out several general areas of environmental concern, including density issues, pedestrian and public access, excessive noise, parking adequacy, contamination, and lighting issues. For a discussion of each issue, please refer to Responses to Comments Verbal-25 on page 3-324, Verbal-26 on page 3-324, Verbal- 27 on page3-324, Verbal-38 on page 3-326, DTSC-1 through DTSC-12 on pages 3-190 through 3-193, and Verbal-34 on page 3-325, respectively. Pacific City EIR 3-333 Chapter 3 Responses to Comments Response to Comment Card Cross (A) Mr. Paul Cross (November 13, 2003) Cross(A)-1 As no specific comment is stated on the card, no response is required. However, this commenter verbally addressed issues in several areas. Please refer to Response to Comments Verbal-3 through Verbal-8 on pages 3-320 through 3-321, Verbal-13 through Verbal-20 on pages 3-321 through 3-323, Verbal-24 on page 3-323, Verbal-29 through Verbal-31 on page 3-325, and Verbal-36 and Verbal-37 on page 3-326 for a discussion of issues raised verbally by this commenter. 3-334 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Card Knox Ms. Laura Knox (November 13, 2003) Knox-1 As no specific comment is stated on the comment card, no response is required. However, the commenter verbally addressed several general issues within the area of energy and mineral resources. These comments correspond to those issues addressed in comment letter LBBS. Please refer to Response to Comments LBBS-1 through LBBS- 30 on pages 3-216 through 3-223. Pacific City EIR 3-335 Chapter 3 Responses to Comments Response to Comment Card Mathis Ms. Faye S. Mathis (November 13, 2003) Mathis-1 Please refer to Responses to Comments DTSC-9 and PCAC(A)-2 for discussions of the reports required following remediation activities. Please also refer to Response to Comment Verbal-25 on page 3-324 for a discussion of density issues and Response to Comment Verbal-11 on page 3-321, which addresses concerns related to traffic congestion. 3-336 City of Huntington Beach Chapter 3 Responses to Comments Response to Comment Card Sisker Mr. John Sisker (November 13, 2003) Sisker-1 Please refer to Response to Comment Verbal-11 on page 3-321 for a discussion of traffic impacts. Impacts related specifically to Delaware and Huntington Avenues are addressed in responses to comments Verbal-1, Verbal-2, and Verbal-21, on pages 320 and 323,respectively. Sisker-2 Section 3.11 of the Draft EIR discusses current and future needs for affordable housing. The section also outlines the developer's preliminary proposals for new affordable housing units both on and off site. Please refer to Response to Comment PCAC-29 on page 3-235 for further discussion of this issue. Sisker-3 The comment regarding the role and knowledge that the owners of Pacific Mobile Home Park play in the life of the park itself does not address an environmental issue or adequacy of the Draft EIR, and thus, no response is required. Sisker-4 Please refer to Response to Comment Verbal-22 on page3-323 for a discussion of impacts on the mobile home park. Additionally, the public review period of the Pacific City Draft EIR is intended to disclose all potential environmental impacts regarding the project to interested parties, including residents of the mobile home park. The comment regarding the creation of an official Mobile Home Park non-profit is noted, but is not a comment on the adequacy of the Draft EIR. Therefore, no further response is required. Sisker-5 Please refer to Response to Comment Sisker-1 above for a discussion of traffic impacts. Pacific City EIR 3-337