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HomeMy WebLinkAboutRCC AGENDA PK 1991/07/22RESOURCE CONSERVATION COMMISSION Agenda Items for July 22, 1991 Review of Local Coastal Program Alternative 8 A. BACKGROUND Chula Vista Investors is the major landowner of property located in the Chula Vista Bayfront north of "F" Street. Since purchasing the property in August of 1988, Chula Vista Investors has been working on a complete revision of the City's certified Local Coastal Program (LCP) referred to as an LCP Resubmittal. Pursuant to a request from the applicant, Alternative 8 (a reduced density alternative concept plan proposed by the applicant) is being considered by the Planning Commission, rather than the original proposed project, which included the text and graphics constituting a Local Coastal Program Resubmittal, as well as a proposed concept plan. A letter from the applicant's attorney making the request for consideration of Alternative 8 is attached as Exhibit A. The Alternative 8 concept plan for the Midbayfront proposes a mixed use project totalling approximately 3.9 million square feet of building area. The concept plan proposes 1,400 residential units; 1,800 hotel units; 150,000 square feet of commercial retail use; 640,000 square feet of professional office use (approximately 560,000 square feet of the office space is within the Rohr campus); and approximately 246,000 square feet, which includes athletic facilities and a conference center. Should the City Council choose to approve Alternative 8, the applicant would be required to prepare a revised LCP Resubmittal document, which would reflect the reduced density plan proposed by Alternative 8. The revised LCP Resubmittal and associated General Plan Amendment would require a Planning Commission recommendation and City Council approval prior to being forwarded to the California Coastal Commission for certification. Thus, this staff analysis focuses on the major issues raised by the Alternative 8 concept plan. An EIR was prepared to address the potential environmental impacts associated with the applicant's LCP Resubmittal and six reduced density alternatives (Alternative 8 was one of those alternatives). Any changes to the LCP would require corresponding changes to the General Plan, Zoning Code, and Bayfront Redevelopment Plan. Thus, the EIR also addressed changes to those plans. FEIR-89-08 is included in the members' packets and is available for public review at the Community Development Department. 1 B. RECOMMENDATION It is recommended that the Resource Conservation Committee adopt a motion recommending that the Planning Commission make the following recommendation to the City Council: 1. Adopt a resolution: a. Certifying that FEIR-89-08 has been prepared in accordance with CEQA and the Environmental Review Procedures of the City of Chula Vista and that the Planning Commission has reviewed these documents; and b. Continue this item and direct staff to work with the applicant and the Bayfront Planning Subcommittee to resolve the key issues raised by the proposed project. Resolution of those key issues would entail: -Determination of appropriate land use intensity -Location of buildings exceeding two stories away from the perimeter of the site where they conflict with public open space uses and uses of the adjacent National Wildlife Refuge -Preservation of public views to the bay from "E" and "F" Streets and removal of buildings west of Marina Parkway to ensure public views to the bay and wetlands from Marina Parkway -Evaluation of the potential for inclusion of a cultural arts facility in the plan -Exploration of alternative phasing and financing programs to increase the financial feasibility of the plan -Resolution of unmitigated impacts in the areas of traffic, land use, visual quality, parks/recreation/open space and schools C. DISCUSSION Alternative 8 includes parks and part of a man-made lagoon at the northern and western perimeter of the Midbayfront Planning Area. The lagoon, which is a positive feature of the proposal, would be salt water, and would extend east from the Bay into central portion of the Midbayfront (Exhibit B). The parks and the lagoon would be available for public use, as well as for resident and visitor use. 2 The attractive visitor serving land uses proposed by Alternative 8, including hotels, retail shops, restaurants, a conference center, and athletic facilities (a tennis complex, swimming facility and an ice rink) are consistent with the visitor serving focus outlined in the goals and objectives for Bayfront development adopted by the Redevelopment Agency in 1988. Further, the proposal to incorporate underground parking included in Alternative 8 would improve the aesthetics of the project because it would allow more productive uses of the limited bayfront acreage, more flexibility in site planning (building placement), and avoid an unappealing expanse of asphalt and parked cars. Although the number of potential employers resulting from implementation of Alternative 8 is not yet known, it is anticipated that the proposed project will result in substantial employment opportunities. Those employment opportunities would result in beneficial impacts to the City and the regional economy. In addition, the residential component of the project would add to the Citywide and regional supply of housing. While Alternative 8 includes the appealing visitor serving land uses and community benefits detailed above, the proposal raises several key issues. Those issues include consistency with the 1988 goals and objectives for Midbayfront development approved by the Redevelopment Agency; overall intensity; economic feasibility; and unmitigated environmental impacts. Consistency with 1988 Redevelopment Aaencv Approved Goals and Objectives An analysis was conducted to determine the extent to which the proposed Alternative 8 is consistent with or implements the goals and objectives for Midbayfront development approved by the Redevelopment Agency in 1988. The highlights of that consistency analysis follows. (Summarized objectives/criteria are underlined; analysis/comments are presented without the underline.) The Midbayfront should include uses which balance the existing development in other areas of the Bayfront. These could include compatible office or residential; uses which do not detract from the destination resort focus. Alternative 8 generally does include uses which complement and balance uses in other areas of the Bayfront and the benefits of a mixed use development could be realized. However, it also has a substantial high density residential component (approximately 1.4 million square feet) and a 640,000 square office component (560,000 square feet is for the Rohr campus). When combined, the office and residential elements exceed the Visitor Commercial component, potentially detracting from the "destination resort" focus specified in the goals and objectives. 3 buffering conflicting uses. Alternative 8 has incorporated a significant buffer adjacent to the wildlife refuge. However, the nature and scale of the project may create conflicts regardless of buffer size or setbacks. The location of intense land uses adjacent to the National Wildlife Refuge boundary will result in significant impacts on the biological resources within the Refuge. natural resources of the bay. Alternative 8 provides public park and open spaces along the perimeter of the Midbayfront, adjacent to the National Wildlife Refuge and bay. Pedestrian and bicycle trails are proposed for this area, with connections to off-site destinations. Alternative 8 integrates a luxury hotel within the public open space west of Marina Parkway. This luxury hotel would obstruct views to the Bay and wetlands from Marina Parkway. In addition, the location of public open space immediately adjacent to high density residential uses in the northern portion of the Midbayfront also raises the concern that the public open space would tend to function as a private amenity. Alternative 8 would also result in significant visual access impacts including: (1) obstruction of existing scenic bay views from public use areas; and (2) creation of a visually dominant landscape from the Nature Interpretive Center, where aesthetic enjoyment of the natural environment is a significant part of the visitor experience. Overall Intensity The total proposed development for Alternative 8 includes approximately 3.9 million square feet (s.f.) of building space in the Midbayfront subarea. In comparison, the certified LCP allows 1.9 to 2.5 million s.f. of building space in the Midbayfront subarea (Exhibit C). Thus, the proposed Alternative 8 building space is approximately 1.4 million square feet greater than the maximum allowable density in the Midbayfront under the certified LCP. Exhibit D provides a land use comparison between Alternative 8, the certified LCP, and other alternatives addressed in the EIR for the Midbayfront subarea. Increased intensity is not necessarily negative. The acceptability of increased intensity depends on factors such as translation into building bulk and scale, the resultant environmental impacts, economic viability, and character and overall relationship with the rest of Chula Vista. 4 Building Heights The height of many of the buildings exceed the maximum height limitations allowed by the certified LCP. In general, the prevalent building height within the Midbayfront subarea in the certified LCP is 4 stories (or 44 feet). A small 5 story (55 feet) area, and a single 70-foot focal point are, however, provided for under the certified LCP. In addition, the General Plan defines the categories of development in Chula Vista with respect to height as follows: Lowrise 0-3 stories Midrise 4-7 stories Highrise 8-15 stories Using a general guideline of 14 feet per story, those ranges would translate to the following building heights. Lowrise 0-42 feet Midrise 43-98 feet Highrise 99-210 feet In comparison to these existing standards, Alternative 8 proposes: one 229 foot-high hotel which exceeds the parameters established for highrise development in the General Plan; two hotels and three apartment buildings in the highrise category; and one hotel, approximately fifteen apartment buildings, eight specialty retail buildings, two commercial buildings, one office building, one conference / theater facility, one ice rink, and one light industrial building in the midrise range. The balance of the structures proposed under Alternative 8 are below 43 feet in height ( within the lowrise category). Acceptable building heights will vary with specific uses, specific locations on the site, and the overall character of a plan. Generally, taller buildings would be acceptable with decreased bulk, increased open space, or other public or aesthetic benefits. They should be located in the interior of the site providing a low profile adjacent to open space and existing low-rise development on the perimeter of the site. Preservation of views, including on and off site view corridors, views on "arrival", views to public areas, and views to the bay, should be considered in the placement of buildings. Although the Alternative 8 plan includes taller buildings, the proposal would not result in decreased building bulk on the site. Regarding the issue of increased open space, Alternative 8 would actually provide slightly less ( approximately three acres) of public parks than the certified LCP. Alternative 8 also proposes to locate several tall buildings at the perimeter of the site adjacent to the open space and the National Wildlife Refuge, particularly in the northern portion of the Midbayfront where three highrise residential buildings are proposed to be located adjacent to the public open space, proximate to the National Wildlife Refuge. Residential Intensity The certified Local Coastal Program allows 15 to 30 dwelling units per acre in the residentially designated areas of the Midbayfront. The General Plan outlines the Residential High category as allowing 18 to 27+ dwelling units per gross acre and specifies that any new project under this category must contain substantial landscaped open space for use by residents of the project. There is no maximum density for this category. The density shown as maximum indicates only that projects in the City have traditionally been constructed below this density. Section 6.2 of the General Plan provides guidelines for establishing residential densities within the range. It provides the criteria used in determining the appropriate gross density for project implementation within any given range. In the City's evaluation to determine the appropriate density for a project, the assumed density, in any residential range begins at the "baseline density" (or lower end of the range) and may move toward the upper end of the range. Alternative 8 proposes residential densities in the northern area of 63.1 dwelling units per acre. This density substantially exceeds the low end of the Residential High category. The analysis of General Plan criteria for determining the appropriate density within the range does not support the density proposed for the following reasons. 1. The intensity of the proposed project is not compatible with the intensity of existing and proposed surrounding land use patterns. The intensity of the proposed residential and hotel development is out of scale with the surrounding area, particularly, the National Wildlife Refuge and Chula Vista Greenbelt which are located immediately west of the proposed project. For residential development, the existing densities in the .5 mile surrounding area range from an average of 15 dwelling units per acre to a high of approximately 35 to 40 dwelling units per acre in the older areas. The newer residential developments have maximum densities of 22 to 28 dwelling units per acre. 2. The proposed project does not appear to be sensitive to the physical characteristics of the site because: 6 - The proposed building placement would result in shadow / shading impacts to park areas. Those impacts were quantitatively determined in studies undertaken for the EIR. - Buildings are located in areas where they adversely impact public views of the Bay and wetlands. Economic Feasibility Summary of Economic Analysis Williams-Kuebelbeck & Associates, Inc. (WK&A) was retained by the Redevelopment Agency to evaluate the financial feasibility of the developer's original proposal and two reduced density alternatives, and the fiscal impacts of each. (This summary does not include the fiscal impact analysis.) It is important to note that Alternative 8, the developer's current proposal, is slightly less dense than the developer's original proposal, and slightly more dense than the first reduced density alternative included in the economic feasibility analysis. The economic study conducted by WK&A analyzed the Developer's proposal, Alternative 3 and Alternative 5 as described in Exhibit D. Two financial performance measures were used to evaluate the financial feasibility of the proposed project to the developer: internal rate of return (IRR) and net present value (NPV). The proposed project and both the reduced density alternatives are financially infeasible according to both measures used. According to WK&A there are several potential modifications to the proposed project that would improve its financial performance. First, it may be appropriate to reevaluate the heavy up-front costs of the project. Items such as public improvements, subterranean parking, and sports facilities were identified as resulting in heavy up-front costs. It is important to determine which nonrevenue producing amenities the project should provide so that non-essential elements with high costs can be eliminated to reduce those heavy up-front costs. Second, the project phasing could be adjusted to include some of the heavy up-front costs in later phases to improve the project's economic feasibility. In addition, it should be noted that alternative financing options were not analyzed. Such options could also positively impact the financial feasibility of the project for the developer. Unmitigated Environmental Impacts Under Alternative 8, significant unmitigated impacts in the areas of geology/soils/groundwater and hydrology/water quality would 7 remain due to lack of specific mitigation measures at the plan level. Impacts in the areas of visual aesthetics/community character, land use/general plan elements/zoning, and parks/recreation/open space would be significant and unmitigable under Alternative 8. Specific visual concerns include the obstruction of existing public views to the Bay from "E" and "F" Streets, and the blockage of future views of the bay and wetlands from Marina Parkway because of the location of a hotel west of Marina Parkway. Seven impacts to biological resources would remain significant and not mitigated at the plan level under Alternative 8. The incremental loss of raptor foraging areas would also be significant and unmitigable under Alternative 8. Any development of the site would result in the loss of raptor foraging habitat. Traffic impacts were assessed as significant and unmitigable at the plan level under Alternative 8 because of uncertainty regarding the feasibility of mitigation measures. Finally, the issues of school transportation costs and school sites would remain unresolved, and therefore, significant under Alternative 8. Conclusion In summary, this report provides an analysis of the key issues raised by Alternative 8 including: consistency with 1988 goals and objectives for Midbayfront development approved by the Redevelopment Agency; overall intensity; economic feasibility; and unmitigated environmental impacts. A short synopsis of the conclusion of each of those analyses follows. -In general, Alternative 8 is consistent with the goals and objectives calling for a visitor serving focus and a mixed use development, although the proposed development does include substantial residential and office elements which could interfere with the visitor serving focus. -The overall intensity of the proposed project exceeds the intensity parameters established in the certified LCP and the General Plan. Several other factors that should be considered in determining the acceptability of increased intensity were also explored including whether Alternative 8 would result in: decreased bulk, increased open space, preservation of views, and consolidation of tall buildings away from the perimeter of the site. Alternative 8, as proposed does not incorporate any of these factors that would help to make increased intensity more attractive. -Based on the two measures of financial feasibility tested by the City's economic consultant, neither the proposed 8 project nor either of the reduced density alternatives tested were financially feasible. The economic consultant did identify several ways to increase the financial feasibility of the project including re-evaluation of heavy up-front costs such as public improvements, subterranean parking, and sports facilities. Adjusting project phasing to include some of the high cost items in later phases of the project was also identified as a way to make the project more financially feasible. No alternative financing options were evaluated in the financial feasibility analysis. Such options could increase the financial feasibility of the proposal. -Alternative 8 would result in numerous unmitigated environmental impacts. Impacts in the areas of land use and visual aesthetics can only be mitigated by project redesign. Traffic, schools, geology/soils/groundwater, hydrology/water quality and several biological impacts will require resolution at the project level of CEQA compliance. The significant unmitigable biological impact, loss of raptor foraging habitat, would occur with any development of the site. The Bayfront Planning Subcommittee was established by the City Council in May 1991, in an effort by the Council to increase public participation in the Bayfront Planning process. In addition to a nine member appointed Subcommittee, Mayor Nader and Councilwoman Grasser Horton serve on the Subcommittee. The following list includes the name and the appointing commission/councilmember for each member of the Bayfront Planning Subcommittee. The two current vacancies resulted from the recent appointment of Ms. Grasser Horton to the City Council. Subcommittee Member Pat Ables John Ray William Tuchscher (to be appointed) Larry Dumlao Russ Bullen John Moot William Virchis (to be appointed) Apnointina Commission/Councilmember Cultural Arts Commission Resource Conservation Commission Economic Development Commission Planning Commission Mayor Nader Councilman Moore Councilman Malcolm Councilman Rindone Councilwoman Grasser Horton To date the Bayfront Planning Subcommittee has considered items such as the history of the Bayfront, the Subcommittee's vision for development of the Bayfront, the Environmental Impact Report prepared for the applicant's proposal, and the potential for inclusion of a cultural arts facility within the Bayfront development. Thus, it would be appropriate to include the Bayfront Planning Subcommittee in future planning efforts for the Bayfront to ensure an expanded opportunity for community input into the process. 9 F ) of y ,Si~~~ !!! R :'l r3 P~; ~f~? jt ~ ~1 Lk PETERSON f3 PRICE RAUL A. REiERSOrv A A PROFESSIONAL CORPORATION JUN 2 4 GREGORY G M. GAR RATT L1~WYF RS EDWARD E WHITTLER . LYNNE L REIDEL SHO E STREET, SUITE 2300 REeECCA MicnAEL SAID DIEGO, CALIFORNIA 921074454 ~ M AftSNAL A-SCARR " - MATTHEW A. PETERSON LARRY N- MURNANE June 21, 1991 Mr. Chris Salomone Community Development Director City of Chula Vista 276 4th Avenue (Public Services Building) Chula Vista, CA 92010 TELEPHONE AREA CO DC 619 234-0361 Fnx (619)234-4786 FILE NO. 3848.002 Re: Chula Vista Bayfront Local Coastal Program Resubmittal Dear Chris: As a follow up to your letter dated June 14, 1991, please be advised that we would like the Planning Commission and City Council to consider Alternative 8 rather than the proposed LCP Resubmittal dated June 28, 1990. It is our understanding that Alternative 8 has already been analyzed in terms of environmental impacts and has also been analyzed by your staff in terms of density, traffic and other considerations. We recognize that should the Planning Commission and City Council approve Alternative 8, we would reed to prepare a revised LCP Resubmittal document which would reflect the reduced density project proposed by Alternative 8. We believe that we could process such revisions in a very short time period and would assume that the City could also docket the Planning Commission and City Council hearings within a very short time frame. We are assuming that should the Planning Commission and Ci-ty Council approve Alternative 8, that staff would not need to, once again, independently, analyze or do any further work, with the exception of verifying that the modifications Mr. Chris Salomone June 21, 1991 Page 2 proposed in the LCP Resubmittal are consistent with the project as contemplated in Alternative 8. If this is not the case, please contact us at your earliest convenience so that we can clarify the appropriate procedure. Thank you for your courtesy. Very truly yours, PETERSON & PRICE A Professional Corporation ~1 ~~~~ ~-~/,~ Matthew A. Peterson cc: Chula Vista Investors ~~ -~ C P R E S U M T T A L 8 F Illp~lf!III E III 1111111E T IIIfIII I I II IIII I IIII I~ _ O 500 '1000 I'I,~, ~, 'I ~h • /eo` c° ~o \/ ~~~ „~ .~ ~ ~~ J , y ` -~ ~_ - ~ = ~m~m GREENBELT S7re ~i ~~J 'Since prcpantion of these graphics, Rehr has cubmittcd a profxxnl diftcrcnt from the one sumbittcd by CVI for this location. TL< reader is referred to Lcttcr U in the Comm<nss Votumc for the new Rohr Plan. .,... t __,~~ ~,~,~, AL'PERI\IA'1'IVE 2 ~II~~~,~,~~~~~IIIIII,I~~'°~''~I~"'II~~~~~~~~~II~~~;"~~II"il~~~~~~~~~y,~~~I~~~,~~~,~~~,I~~~~~iu"..IIINIII°'llllllli";ilmu,lmnw ~ 7 y 7 p n n 3 ~ ~ cao w ~ m y .. y y ny < ~ ~ w o ~ A T` N w v .- n ~ ~ v~ m v0, Q. A y c " ~ ~ ~ O ~+ m by O ~ D .. ~ ny !~`-Dff ~ C a y o• w () ~ y w` ~' o 8~a ~ ~ o y ~ d p O o a ~ ryO ~_ N R W ~ w O -~ - ~ y O ~ O O -„ b w_ m N~ 7 ~ (~ ^. 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P ~ O O O O ~ p w ~ o w ~ ., ~+ ° p o o " o ~ p ~ p p p p O < O C O , O O O O A O (D y (D y y ~ N w w N A I ~^~, ^ w oo a~, tl bb ~ O ~ J ~ ~ N A .. oo m C ~ C O .~ i . w °` . ~ w w ~i O w ^ oo in in o t 0 ~~ O^ O ~- O^ (D P. C o O O ON O U U bb N w ~ ~ ~ to cn . i O ~ ~ ~ N ~ b b w N w _ ~~.~ ~ w N N .- N w N . ~ O A ~D A N ~ o0 a N O\ ^ ~y n o0 00 ~] Ol ~D LL O W <~ ' ~ r a A ^1 7 A A T n C° n ^: 3 S ~ 1 '~ n w ~ 3 A v ~ a ~, ve yy 1 O p: ~ G• ~ ~~y m ~i' C ~ ~ ^y~.c ~,p~'n' `.-' ~ Pi 7 ~• a ro 1 b n ffi C" n b C O' ao ~ ' ~a A a3 ~ ~ G~ ~ 0 w O ,~ a y n 0 3 b n 7 O 7 RESOURCE CONSERVATION COMMISSION AGENDA ITEMS for MEETING of JULY 22, 1991 REVIEW OF FINAL EIR-89-08 MIDBAYFRONT LCP RESUBMITTAL NO. 8 AMENDMENT A. BACKGROUND The original Draft EIR prepared on this proposal addressed the potential environmental effects of a proposed Local Coastal Program Resubmittal including both text and graphics. At the end of the public review period (Planning Commission hearing on September 26, 1990) Chula Vista Investors (the applicant) introduced a new revised concept plan. This new proposed project is termed Alternative 8. Should the City Council choose to approve the Alternative 8 concept plan, then the applicant would be required to prepare a revised LCP Resubmittal document to reflect the reduced density plan proposed by Alternative 8. Two major changes to the certified LCP would occur if Alternative 8 were approved. The first would involve the redesignation to "open space" on all City plans of the "D" Street Fill and Gunpowder Point, consistent with the establishment of the Sweetwater Marsh National Wildlife Refuge which includes those areas. The second major change would be to modify the arrangement of land uses, building height controls, and development intensity in the Midbayfront planning subarea. The Alternative 8 concept plan for the Midbayfront proposes a mixed use project totalling approximately 3.9 million square feet of building area. The concept plan proposes 1,400 residential units, 1,800 hotel units, 150,000 square feet of commercial retail, 640,000 square feet of professional office, and approximately 246,000 square feet which includes athletic facilities and a conference center. Alternative 8 includes parks and part of a man-made lagoon at the northern and western perimeter of the Midbayfront planning area. The lagoon is a salt water feature that would extend east from the Bay to the central portion of the Midbayfront. The parks and lagoon would be available for public use as well as for resident and visitor use. Alternative 8 proposes: • One 229 foot-high hotel which exceeds the parameters established for highrise development in the Chula Vista General Plan; • Two hotels and three apartment buildings in the highrise category (99-210 feet); • One hotel, approximately fifteen apartment buildings, eight specialty retail buildings, two commercial buildings, one office building, one conference/theater facility, one ice rink, and one light industrial building in the midrise range (43-98 feet); and -1- • The remainder of the structures are below 43 feet in height (within the lowrise category). Wetland setbacks are proposed along the perimeter of the Midbayfront which is adjacent to both San Diego Bay and Sweetwater Marsh National Wildlife Refuge. The environmental analysis included in the Final EIR addresses the following issues: geology/ soils/groundwater, hydrology/water quality, visual aesthetics/community character, conversion of agricultural lands, air quality, noise, biology, archaeology/history/paleontology, and land use/general plan elements/zoning, community social factors, community tax structure, parks/recreation/and open space, utility service, and transportation/access. The Final EIR also examines alternatives to the project, growth inducing impacts, cumulative impacts, and other environmental summaries required by CEQA. The environmental consultant that prepared this Final EIR is Keller Environmental Associates, Inc. of San Diego, California. B. RECOMMENDATION Certify that Final EIR-89-08 has been prepared in compliance with the State CEQA Guidelines and the Environmental Review Procedures for the City of Chula Vista, and further that the Resource Conservation Commission has reviewed and considered the information in the Final EIR as it reviews the Alternative 8 concept plan. C. ANALYSIS In addition, the Final EIR includes expanded and refined impact definitions to clearly distinguish between those significant impacts that may be mitigable at a later stage of planning and California Environmental Quality Act (CEQA) compliance and those impacts that may only be mitigated through a major redesign of the project or selection of another alternative. In preparing the August 1990 Draft E[R, the category "Significant and Not Mitigable" was used to categorize a broad range of impacts -- including those that were not considered to be mitigable except through project redesign, as well as those considered to be significant and not mitigated at the present time, based upon the information provided by the applicant at the plan-level of CEQA compliance. In various instances, impacts classified in the DEIR as "Significant, Unmitigable" at the plan level, maybe mitigable once more detailed studies and planning are completed by the applicant and the City. Consequently, in order to clearly distinguish between these two major impact categories, the project team refined the impact definitions and re-evaluated all environmental impacts of the proposed project and alternatives based upon the following criteria and definitions: • "Significant and Not Mitigable" -This category pertains only to those significant impacts that would not be mitigated below a level of significance at any stage of project planning and environmental compliance. Consequently, this impact category pertains to those effects that can only be avoided through project redesign or selection of another alternative. -2- • "Significant and Not Mitigated at the Plan-Level of CEQA Compliance" -This category of impacts applies to those environmental effects that are not presently mitigated by identifiable measures or the applicant's commitments. These impacts may or may not be mitigated at later stages of planning and environmental compliance. In most instances, additional baseline studies or project details are needed prior to determining whether mitigation would be feasible or not. • "Significant, Mitigable" -Impacts that exceeded the threshold of significance are categorized as "Significant, Mitigable" in those instances where mitigation measures are readily available or where the applicant has already provided sufficient information and mitigation commitments. In this instance, additional studies and/or design information are not necessary to establish appropriate measures and their effectiveness in reducing impacts below the significant threshold. • "Adverse, Not Significant" -Impacts considered to be adverse, but below a level of significance are listed under this impact level. • "No or Limited Impact" -Impacts that are considered to be very minor or undiscernible are classified in this category. • "Beneficial Impacts" -Impacts that will have a beneficial effect on the City of Chula Vista, its residents, and/or its environmental resources are so noted under this category. An analysis of the significant adverse environmental impacts which would result from implementation of Alternative 8 follows. 1. Geology/Soils/Groundwater Development of the proposed project and alternatives would result in the following four potentially significant impacts. The impacts are described in the right column and level of each impact is identified in the left column. Impact Level Impact Description Significant Mitigable 1. Ground settlement due to consolidation of the compressible estuarine/fluvial (bay) deposits and the artificial fill soils on site; Significant Mitigable 2. Grading impacts for onsite and offsite water and sewer pipelines; Significant, not mitigated at 3. Seismic hazards, including ground shaking, surface plan level displacement, liquefaction, tsunamis, and earthquake-induced flooding; and -3- Significant, not mitigated at 4. Potential foundation design and construction plan level difficulties associated with the construction of foundations and subterranean parking structures at or near the groundwater table. 2. Hvdrology/Water Ouality Five potentially significant hydrology/water quality impacts were cited as a result of development of the project and the alternatives. These include: Impact Level Impact Description a. and b. Significant , 1. Flooding of: (a) low-lying areas from tidal highs, Mitigable compounded by run-up from wind-driven waves (coastal flood hazards); (b) flooding from the c. Significant , not Sweetwater River; (c) flooding associated with mitigated at plan level exceeding the capacity of proposed storm drain facilities on site; Significant, not mitigated at 2. Erosion from inland or coastal flooding; plan level Significant, not mitigated at 3. Siltation and chemical contamination/degradation of plan level water quality from surface runoff-pesticides, fertilizers, oil, grease, etc.; Significant, mitigable 4. Inconsistency with City of Chula Vista standards, specifically related to the design storm flow, and gravity pipe requirements; and Significant, mitigable 5. Issues regarding quantity and quality of water for both the 10-acre public lagoon and the semi-public residential lagoon in the northern portion of the site. 3. Visual Aesthetics/Community Character Significant visual and aesthetic impacts would occur from development of Alternative 8 and three reduced density alternatives (Alternatives 3, 4 and 5). No significant aesthetic/visual impacts would occur from development allowed under the existing LCP. The significant impacts and the level of significance of each impact are summarized below. -4- Impact Level Impact Description Significant, not mitigable 1. Creation of a visually dominant urban landscape from the Nature Interpretive Center, where aesthetic enjoyment of the natural environment is a significant part of the visitor experience, would be permanently lost. Significant, not mitigable 2. Obstruction of existing scenic bay views from public use areas and establishments along Bay Boulevard. Significant, not mitigable 3. Creation of a visually dominant urban landscape from areas within the City of Chula Vista and from I-5, that would be incompatible with the waterfront image community identity of Chula Vista. 4. Conversion of Agricultural Lands 5. The loss of approximately 45 to 65 acres of potential agricultural land to urban uses is not considered significant at the plan level. The loss of any potential agricultural land represents an incremental contribution to a regionally significant loss of agricultural land to development. Air Ouality Potentially significant air quality impacts would occur from development of the proposed co-generation plant. An incremental contribution to regional air quality problems would also occur from vehicular sources. In addition, cumulative impacts would occur from vehicular emissions added to the co-generation plant emissions. Mitigation measures must be implemented to reduce these impacts to a level below significant, including compliance with the Air Pollution Control District's requirements for co-generation emissions, dust control (during construction), construction traffic monitoring, and implementation of Transportation Control Measures coordinated through a transportation management agency. Further, once the proposed parking garages have been designed, an additional air quality analysis must be conducted to assess potential air quality impacts to the garage users. 6. Noise Potentially significant noise impacts could occur from construction activities, and land use incompatibility. Specifically the location of the child care center close to the noise from I-5 and the co-generation facility raise noise concerns. These impacts can be mitigated to a level below significant by limiting construction activities to certain times, limiting construction access routes, establishing a noise performance standard 5- for the co-generation facility, and by requiring a noise barrier along the eastern end of the child care facility. 7. Bioloev Numerous impacts are cited to biological resources including wildlife resources, threatened and endangered species, and marine resources. Twenty-six mitigation measures are detailed for biological impacts in the FEIR. These mitigation measures would help to minimize the impacts of the project on biological resources, but one significant unmitigable impact would remain. There are not foreseeable mitigation measures available to compensate for the loss of raptor foraging habitat associated with the alteration of land uses in the Midbayfront. Thus, this impact is considered significant and unmitigable. The project description, environmental safeguards, and the mitigation measures detailed in the Final EIR provide adequate assurance that impacts associated with degradation of water quality alterations of predator/competition/prey regimes, human and pet presence, endangered species concerns, and vector control issue can be mitigated at the project level by the development and implementation of precise plans which address these concerns. Currently, there is not enough project-level detail available to adequately evaluate significance on these issues. A biological resources management plan will be developed in a completed form during the project level environmental review process. So, the impacts identified above remain significant and not mitigated at the plan level. 8. Archaeology/History The impacts to archaeological and historical resources were found to be significant but mitigable by subjecting off-site improvements (e.g., for utility extension) to archaeological review. 9. Paleontoloev Significant impacts to paleontological resources could occur during project grading. The standard on-site monitoring requirements are included in the Final EIR as mitigation for these impacts. 10. Land Use/General Plan Elements/Zoning The significant land use impacts associated with the proposed project and the level of significance of each impact are summarized below. Impact Level Impact Description Significant, not mitigable 1. Incompatibility of the intense nature of the development with the land uses of the surrounding Chula Vista area; -6- Significant, not mitigabee 2. Incompatibility ofthe intense nature of development with the adjacent unique open space uses of the Sweetwater Marsh National Wildlife Refuge and Nature Interpretive Center; Significant, mitigable 3. The potential incompatibility of the residences located above and nearby the commercial retail and commercial visitor uses in the central core area. Such potential impacts include noise from traffic and people, traffic congestion, night-lighting and competition for parking spaces, all of these largely occurring on weekends and evenings when most people are home; and Significant, not mitigated at 4. Inconsistency with the certified LCP, General Plan the plan level (2010), and Bayfront Redevelopment Plan. The only mitigation measure possible to reduce the impacts from land use intensity incompatibility (number 1 above) and incompatibility with the adjacent NWR (number 2 above) to below a level of significance would be to redesign the proposed project. Otherwise, these impacts would remain significant. Mitigation for impact number 3 above would involve building design techniques such as maximum insulation in exterior and interior walls, floor separation design, and window treatment. Mitigation for number 4 above would also necessitate either project redesign, or approval of an LCP Resubmittal, a General Plan Amendment, and a Redevelopment Plan Amendment; otherwise, this land use impact would also remain significant. 11. Community Social Factors A significant increase in housing and a resulting population increase would occur on the project site over what was planned for the site, and a substantial increase in employment opportunities would occur. Both the increase in housing and employment opportunities are considered beneficial impacts. 12. Community Tax Structure No significant adverse impacts would occur in the area of community tax structure. A positive impact to the City's Redevelopment Agency would occur under all of the alternatives. 13. Parks. Recreation. and Open Space The EIR cites the following inadequacies in the proposed project in the area of parks, recreation, and open space. -7- • Park development according to the proposed phasing plan would not provide adequate park area or parking for parks within Phase 1 to accommodate the anticipated high public usage; • Potentially insufficient amount of parking for park users; • Inadequate information regarding public access from on-site parking areas to parks, and from areas across I-5 to the east to the parks.; • Shade impacts to parks and public open space areas. Mitigation is possible to reduce the first three impacts to below a level of significance. These measures are: • Revise the Phasing Plan to include the parks and adequate public park parking (as approved by the City) within Phase I. • Creation of additional public parking spaces per City requirements to be determined at the project level. • Provision of access plan, showing designated public parking areas, access routes to public areas, and access routes and signage from the east side of I-5 across the "E" Street bridge. The access plan must be approved by City Planning and Community Development Departments. The fourth impact can only be reduced by project redesign, thus, it remains significant and unmitigable. 14. Utility Service In the area of schools, the creation of new Mello-Roos districts would provide for the collection of funds to finance items such as buses, relocatable classrooms, permanent classrooms, and property on which those facilities could be located. Annual costs for student transportation including bus maintenance and drivers' salaries are not, however, eligible for Mello-Roos funding. These costs need to be funded by either a cash contribution from the applicant or a long-term binding agreement with the applicant to finance annual school transportation costs. The issue of new school sites or additional property adjacent to existing schools for the construction of capital improvements must be resolved during the project level of CEQA compliance and the impact remains significant at the plan level. 15. Transportation/Access Development of the proposed project would result in significant impacts to street and intersection capacities at streets in the project vicinity. The Year 2000 condition was analyzed with the traffic generated by the Proposed Project added to the No-Project condition. This analysis revealed that under this -8- condition, like the No-Project condition, all study area intersections will operate at LOS C or better during the a.m. peak hour. During the p.m. peak hour, with the proposed project generated traffic added to the network, the following intersections will operate at unacceptable levels of service (LOS D or worse -Arterial Intersections, LOS E or worse -Freeway Ramp Intersections). • I-5 Southbound Ramp/"E" Street (LOS F, ICU 1.05) • I-5 Northbound Ramp/"E" Street (LOS F, ICU 1.30) • Broadway/"E" Street (LOS F, ICU 1.04) • Broadway/"F" Street (LOS D, ICU 0.84) • Broadway/"H" Street (LOS E, ICU 0.95) Measures have been suggested and analyzed that would result in the following levels of service. • I-5 Southbound Ramp/"E" Street (LOS D, ICU 0.87) • I-5 Northbound Ramp/"E" Street (LOS C, ICU 0.74) • Broadway/"E" Street (LOS C, ICU 0.76) • Broadway/"F" Street (LOS C, ICU 0.79) • Broadway/"H" Street (LOS C, ICU 0.75) The feasibility of several of the measures including restriping of the "E" Street overcrossing, and widening Bay Boulevard to provide three northbound lanes has not as yet, been demonstrated. The feasibility of these measures must, however, be confirmed by the City Traffic Engineer and CalTrans prior to accepting the measures as appropriate mitigation at the project level. Thus, many of the traffic impacts associated with the proposed project remain significant and not mitigated at the plan level. In addition, at the project level, a determination of the applicant's fair share of the improvements required at the off-site intersections will be analyzed. D. ALTERNATIVES CEQA requires description of a range of "reasonable alternatives to the project, or to the location of the project, which could feasibly attain the basic objectives of the project," and to evaluate the comparative merits of the alternatives. The discussion of alternatives "shall focus on alternatives capable of eliminating any significant adverse environmental effects or reducing them to a level of insignificance, even if these alternatives would impede to some degree the attainment of project alternatives, or would be more costly." The alternatives analysis in the Recirculated DEIR includes nine alternatives, five of which were development plans which were analyzed at the same level of detail as the proposed project. The alternatives are listed below; numbers 2 through 5, and 8, are those that are analyzed in the same level of detail as the proposed project. (I) No Project (2) Development Under Existing Certified LCP (3) Reduced Density 1 (26 percent intensity decrease from developer's proposal) -9- (4) Reduced Density lA (26 percent intensity decrease from developer's proposal) (5) Reduced Density 2 (47 percent intensity decrease from developer's proposal) (6) Possible Locational Alternatives (7) Reduced Density/Modified Design Alternative (47 percent intensity decrease from developer's proposal) (8) Applicant's Revised Development Plan (9) Alternative Developed in Response to Public Comments Locational Alternatives Eight locational alternatives were analyzed in the DEIR. The alternative site locations are included in response to the recent Goleta case, in which the Court ruled that EIRs must evaluate alternative locations for a project, in addition to project alternatives on the same site. Alternative sites aze examined in the EIR not as a viable option to the proposed project, but rather to assess whether environmental impacts from the same or a similar project might be reduced or eliminated at a different site than the proposed location. The Midbayfront development plan would create reduced impacts in a different location, possibly in such areas as shown by possible locational alternatives 2 and 6. It was also concluded that the elements of the development plan that resulted in the significant, unmitigable impacts were the high density, building bulk, and building heights. Thus, Alternatives 7 and 9, additional on-site alternatives, were designed by the City's environmental and planning consultants in an effort to reduce project impacts and to respond to public comments regarding the project density, bulk, and height. The impacts associated with Alternatives 7 and 9 are summarized below. Alternative 7 Alternative 7 was developed by reviewing the potentially significant impacts of the proposed project, and designing a development which maintained the land uses proposed by the project while avoiding or significantly reducing the cited impacts. The design reduced the overall intensity to a level allowed by the existing LCP (this alternative assumes a maximum of approximately 2.5 million square feet of building). The design also reduced the heights of buildings throughout the project area. Under Alternative 7, the significant unmitigated impacts in the areas of geology/soils/ groundwater and hydrology/water quality would remain due to lack of specific mitigation measures at the plan level. It is, however, likely that these impacts could be mitigated to below significant at the project level. With the mitigation measures outlined in the Final EIR, impacts in the areas of visual aesthetics/community character, land use/general plan elements/zoning, and parks/recreation/and open space could be mitigated to a less than significant level. Five impacts to biological resources would remain significant and not mitigated at the plan level under Alternative 7. The incremental loss of raptor foraging areas -10- would be significant and unmitigable under Alternative 7. In addition, traffic impacts were also assessed as significant and not mitigated at the plan level because of the uncertainty regarding the feasibility of the mitigation measures. Finally, the issues of school transportation costs and school sites would remain unresolved, and therefore, significant under Alternative 7. In summary, although significant unmitigable impacts would result from implementation of Alternative 7, the number of unmitigable impacts would be substantially reduced from the number identified for the proposed project. Alternatives 7 and 9 have fewer significant adverse environmental impacts than any of the other alternatives analyzed except the No Project alternative. Alternative 9 Alternative 9 was developed in response to comments received on the original Draft EIR. The impacts associated with Alternative 9 would be very similar to the impacts identified for Alternative 7. (C:\ W P51\6AYFRONI'\89-8-EIRT'XTJ 11-