Save Irvine Open Space Comments on the Notice of Preparation (NOP) for the Supplemental Environmental Impact Report (SEIR) – Planning Area 52 Project

Dear Mr. Martin:

On behalf of Save Irvine Open Space, we respectfully submit the following comments regarding the Notice of Preparation (NOP) for the Supplemental Environmental Impact Report (SEIR) for the Planning Area 52 Project.

We respectfully request that the following issues be thoroughly evaluated and addressed in the SEIR to ensure a complete and transparent analysis of the project's potential environmental impacts.

V.1 Aesthetics

The initial study suggests that there is no need for further analysis of the view impacts associated with the project but that is inaccurate. The views along Irvine Center Drive particularly View photos numbered 12, 13, 14 are likely to be impacted and should be further analyzed in the SEIR for the project. Building mass allowed under the proposed medium high density zoning category should be shown in this location depicting the visual impacts of the residential structures allowed under the proposed zoning.

V.3 Air Quality Impacts

Given the proposed location of the K-6 school and its adjacency to industrial uses there is the need for further evaluation of air quality impacts associated with uses in the industrial area. That analysis should include an assessment of existing industrial uses in the vicinity and air quality impacts stemming from operational practices utilizing toxic substances that could be released into the air through normal or accidental procedures. The recent experiences in Garden Grove and Los Angeles are examples of questionable land use decisions gone bad.

V. 4 Biological Resources

The existing biological resources found in the eco-system on the 176 gross acre property is subject to profound disruption caused by the proposed project notwithstanding the proposed trail system and “nature park” consisting of 61 acres nearly 1/3 the size of the land mass supporting the biological resources currently found on the property. The SEIR must assess the impacts to the biological resources caused by the sheer reduction in acreage devoted to preservation and conservation.

V. 11 Land Use and Planning

The existing preservation land use category is the result of voter approval of Initiative Resolution 88-1 and as such cannot be changed without the consent of the Irvine electorate. This significant inconsistency with 88-1 should be acknowledged in the SEIR and the City Council must defer to the residents of Irvine for the ultimate approval before this project is implemented.

V. 14 Population and Housing

Notwithstanding the adoption of the 2045 General Plan Update in August 2024 it should be noted that the City’s Housing Element included as part of that update was certified by the California Department of Housing Development without the redevelopment of the proposed project in preservation land use category. The City can meet its housing goals without changing the preservation land use category and land use alternatives that do not change the preservation land use category should be evaluated in the SEIR.

V. 15 Public Services

Given the considerable traffic congestion currently experienced on adjacent streets and those in the vicinity there is considerable worry about worsening the ability of emergency vehicles to serve clients in need of care and must be addressed in the SEIR.

V. 16 Recreation

The project proponent’s ability to use park credit to satisfy not only its open space dedication requirements but to also use such credits for its community and neighborhood park obligations raises concerns about the impacts on recreational sports facilities in the City. The obvious impact on recreational golf in the City is also noted. These impacts must be analyzed in the SEIR.

V. 17 Transportation

The initial study makes reference to the probable significant and unavoidable impacts from traffic utilizing Vehicle Miles Traveled (VMT) methodology for evaluating traffic impacts. The SEIR must also apply the Intersection Capacity Utilization (ICU) modeling to evaluate the Level of Service (LOS) impacts on street intersections in the vicinity of the project and beyond given the results of the traffic modeling. This level of analysis is critical to understanding the true nature of the traffic impacts. The project proponent has previously committed to such an analysis in community meetings and the expectation is that this will occur as part of the traffic study in the SEIR. Please confirm.

Respectfully submitted,

Christina Shea
President
Save Irvine Open Space

Irvine, California

Email: save@saveirvineopenspace.com

Website: www.saveirvineopenspace.com

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