RES-10807 Denying Final Environmental Plan AmendmentRESOLUTION NO. 10807
A RESOLUTION OF THE CITY COUNCIL OF THE
CITY OF ORANGE DENYING APPEAL NO. 0533 -14
AND UPHOLDING THE DECISION OF THE
PLANNING COMMISSION OF THE CITY OF
ORANGE TO DENY THE FOLLOWING: (A) FINAL
ENVIRONMENTAL IMPACT REPORT 1818 -09; (B)
GENERAL PLAN AMENDMENT NO. 2009 -02; (C)
ZONE CHANGE NO. 1254 -09; (D) DEVELOPMENT
AGREEMENT NO. 5825; AND, (E) ALL RELATED
ENTITLEMENTS, INCLUDING SPECIFIC PLAN
NO. 001 -09, TENTATIVE TRACT MAP NO. 17344,
TENTATIVE PARCEL MAP NO. TPM 2012 -101,
MAJOR SITE PLAN REVIEW NO. 0595 -09 AND
DESIGN REVIEW COMMITTEE NO. 4413 -09, FOR
THE RIO SANTIAGO PROJECT, GENERALLY
LOCATED ON 110 ACRES AT THE NORTHEAST
CORNER OF CANNON STREET AND SANTIAGO
BOULEVARD.
APPELLANT: JMI PROPERTIES /SANTIAGO PARTNERS, LLC
WHEREAS, the applicant has submitted an application for a Project in accordance
with requirements of the Municipal Code of the City of Orange which consists of
Environmental Impact Report No. EIR 1818 -09, General Plan Amendment No. GPA 2009-
002 (Includes amendments to the East Orange and Orange Park Acres Plans), Zone Change
No. ZC 1254 -09, Development Agreement No. DA 5825, Specific Plan No. SP 001 -09,
Tentative Parcel Map No. TPM 2012 -101, Tentative Tract Map No. 17344 (City No. TTM
025 -09), Major Site Plan Review No. MJSP 0595 -09 and Design Review Committee No.
DRC 4413 -09, all of which are collectively referred to herein as the "Project"; and
WHEREAS, the Project was processed in the time and manner prescribed by state
and local law; and
WHEREAS, Pursuant to the authority and criteria contained in the California
Environmental Quality Act (CEQA), staff analyzed the Project and determined that it will
have a significant unavoidable adverse effect on the environment; and
WHEREAS, Draft Environmental Impact Report No. 1818 -09 was circulated for
public review and comment within a State mandated 45 -day public review period as required
by CEQA, with the comment period occurring between May 16, 2013, and July 1, 2013; and
WHEREAS, Pursuant to the provisions of the CEQA, local CEQA Guidelines, and
the State CEQA Guidelines, an Environmental Impact Report (EIR No. 1818 -09) was
prepared for the Project, including changes and revisions (Errata) to EIR No. 1818 -09, the
Response to Comments, technical appendices, and the Mitigation Monitoring Program to
address the Project's potential significant environmental impacts; and
WHEREAS, the Design Review Committee reviewed the Project design at their
regular August 7 and October 21, 2013 meetings and recommended approval of the Project
by the City Council with Specific Plan design criteria and development standard changes and
recommended conditions to facilitate Design Review Committee review and acceptance of
the Project's sub -level site, architectural and landscape plans prior to the issuance of building
permits; and
WHEREAS, the Planning Commission held a duly advertised public hearing on
January 13, 2014, which was continued to January 20, 2014, then to January 27, 2014, then
to February 19, 2014, then to March 3, 2014, then to March 17, 2014, at which time
interested persons had an opportunity to testify either in support of, or opposition to, the
proposal and for the purpose of considering the Project; and
WHEREAS, the Planning Commission reviewed Environmental Impact Report No.
1818 -09, including all public comments, responses, errata and technical appendices, and
found it insufficient and inadequate for use for this Project; and
WHEREAS, upon hearing and considering all testimony and arguments, if any, of all
persons desiring to be heard, the Planning Commission considered all factors relating to the
proposed Project, including potential environmental impacts addressed in the Environmental
Impact Report No. 1818 -09 and unanimously voted to deny the Project; and
WHEREAS, the Project Applicant filed Appeal No. 0533 -14, appealing the Planning
Commission decision to deny the Project to the City Council of the City of Orange; and
WHEREAS, the City Council of the City of Orange held a duly advertised public
hearing on May 13, 2014, which was continued to June 10, 2014, at which time interested
persons had an opportunity to testify either in support of, or opposition to, the proposal and
for the purpose of considering the Project upon property described in the attached legal
description (Exhibit A); and
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of
Orange hereby denies Appeal No. 0533 -14, and upholds the decision of the Planning
Commission of the City of Orange to deny Environmental Impact Report No. EIR 1818 -09,
General Plan Amendment No. GPA 2009 -002 (Includes amendments to the East Orange and
Orange Park Acres Plans), Zone Change No. ZC 1254 -09, Development Agreement No. DA
5825, Specific Plan No. SP 001 -09, Tentative Parcel Map No. TPM 2012 -101, Tentative
Tract Map No. 17344 (City No. TTM 025 -09), Major Site Plan Review No. MJSP 0595 -09
and Design Review Committee No. DRC 4413 -09 ( "Project ") based on the following
findings:
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SECTION I — ENVIRONMENTAL IMPACT REPORT FINDINGS
The City Council finds that Environmental Impact Report (EIR) 1818 -09 does not
reflect the independent judgment and analysis of the City of Orange and is insufficient and
inadequate for use for this project for the following reasons:
1. The City Council finds that the information contained in EIR 1818 -09, does not
provide an adequate assessment of the potentially significant environmental
impacts of the proposed Project and required discretionary permits; and
2. The City Council finds it is not possible to conclude that, even with the
implementation of all mitigation measures recommended in EIR 1818 -09, there
are substantial overriding benefits of the Project which outweigh the significant
and unavoidable environmental impacts of the Project, with the exception of the
project's internal design, that could override site -based significant and
unavoidable aesthetic impacts; and
3. The City Council finds that the EIR is lacking in clarity, information, accuracy,
disclosure and completeness and that document components are dismissive and or
misleading, specifically pertaining to the Threshold analysis and responses for the
Land Use analysis with regard to a lack of analysis of changing the existing
Orange Park Acres Plan, East Orange Plan, Santiago Creek Greenbelt Plan and
the proposed General Plan text amendment implications for the City's Open
Space, Park General Plan Land Use Element designation; Biology with regard to
lighting impacts on sensitive species; Hydrology and Water Quality with regard to
dam inundation; Geology with regards to creek erosion; and Traffic with regard to
the conclusion that no impacts would result even if all mitigation improvements
were implemented; and
4. The City Council finds that critical public comments on the EIR received through
comment letters, public comments, correspondence, the Planning Commission
meetings, and the public hearings support the City Council's finding of
inadequacy; and
5. The City Council finds that the EIR did not undergo sufficient peer review
because it was only reviewed in certain subject areas at the beginning of the
process and not at critical stages throughout or at the end of the process; and
6. The City Council finds that due to insufficient analysis in the areas of Water
Hydrology and in particular with regard to dam inundation, the EIR would not
further the City's goals to provide for the safety of residents or protect the liability
of the City; and
7. The City Council finds that the EIR does not include exploration of appropriate
project alternatives, as evidenced by the number of overriding considerations
being requested for significant and unavoidable impacts; and
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8. The City Council finds that the EIR includes deferred mitigation for multiple
impact areas, particularly in the area of Traffic, because the timing for traffic
related improvements are not included in the City's current Capital Improvement
Program (CIP), or reasonably foreseeable in future CIP's.
SECTION II — GENERAL PLAN AMENDMENT
The City Council hereby denies General Plan Amendment No. 2009 -002 (the denial
includes amendments to the East Orange and Orange Park Acres Plans). The City Council
further finds that a recommendation on the environmental document for this portion of the
project is exempt from further analysis pursuant to CEQA section 15270 (Projects Which are
Disapproved) because CEQA does not apply to projects which a public agency rejects or
disapproves.
The City Council finds that the East Orange and Orange Park Acres Plans,
incorporated into the City's General Plan, are well accepted, long established documents that
the community expects to guide the development for the project site and the City is under no
obligation to change the General Plan unless it feels the right project would warrant such
change. The City Council finds that the density is too high under the proposed general plan
amendment for the residential portion of the Project, and with regard to the non residential
portion, the allowable uses are too intense, given that the project site is located immediately
adjacent to a uniquely rural equestrian community and is surrounded by property designated
low density residential. The area of the property designated for a senior residential
community would require a medium density residential general plan designation. This
designation would permit the maximum residential density, such as apartments, allowable in
the City. The City Council finds that this is completely out of context and not an appropriate
fit for the area. The City Council also finds that the area proposed for low density residential
would still have a higher density than what exists in the surrounding neighborhoods. The
City Council finds that the area designated for a recreational amenity was more like a
commercial designation because it would not be operated by a public entity. Finally, while
the City Council was in favor of having 50 acres of the project designated for open space, the
area would not be sufficient to be considered a City park because it lacked park amenities
and did not have a public entity readily willing to accept the responsibility and maintenance
for the area. The City Council finds that the lack of certainty with regard to certain essential
aspects of the Project and the proposed Project inconsistencies do not warrant removing the
Project area from the East Orange Plan or Orange Park Acres Plan.
SECTION III — ZONE CHANGE
The City Council hereby denies Zone Change No. 1254 -09. The City Council further
finds that a recommendation on the environmental document for this portion of the project is
exempt from further analysis pursuant to CEQA section 15270 (Projects Which are
Disapproved) because CEQA does not apply to projects which a public agency rejects or
disapproves.
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The City Council generally agreed that the zone district designation for the portion of
the project identified as Area A should be Open Space for the project. The City Council does
not agree with the zone district designation for the portion of the project identified as Area B.
While the City Council supports land uses offering recreational amenities, the Applicant's
proposal for the use as a private facility, coupled with the uses necessary to support it, make
it more commercial in nature. The commercial use of the property was not appropriate at this
location. With regard to the portion of the project identified as Area C, the City Council
finds that the low- medium density residential zoning designation is completely out of
character with the existing surrounding neighborhoods because it is far too dense for the area.
Also, the proposed senior assisted living and independent living uses are not compatible with
the surrounding neighborhood. Such a use in this area is not convenient, accessible or close
to the support needs of its residents. The proposed use is too remote to public transportation,
medical uses, shopping centers and similar uses that support the residents. Finally, with
regard to the portion of the project identified as Area D, the City Council finds that the land
use designation of single family residential is appropriate, however, a zone district
designation of R -1 -6 is not appropriate as it allowed minimum lot sizes of 6000 square feet,
which is too small for the area. The City Council recognizes that neighboring development
in the area located to the north and south sides of the project are designated R -1 -8, which
requires a minimum lot size of 8000 square feet and would be more compatible for the
Project. The east and north eastern portion of the site are designated R1 -20, which requires a
minimum lot size of 20,000 square feet and R1 -40, which requires a minimum lot size of
40,000 square feet and would be compatible lot sizes for these portions of the Project.
SECTION IV — DEVELOPMENT AGREEMENT FINDINGS
The City Council hereby denies Development Agreement No. 5825. The City
Council further finds that a recommendation on the environmental document for this portion
of the project is exempt from further analysis pursuant to CEQA section 15270 (Projects
Which are Disapproved) because CEQA does not apply to projects which a public agency
rejects or disapproves.
The City Council finds that the proposed Agreement is significantly lacking in
additional public benefits. The 50 acres of public open space does not identify any agency or
other entity willing to accept or maintain the property, much of which is located in the
middle of the Santiago Creek watershed. The area identified to be donated to the YMCA or
similar organization lacks a written commitment from any organization willing to acquire or
operate a private recreation facility. A private operator of this type of amenity is essentially a
pay to play facility and not encouraged by the City Council. The City Council finds that the
financial contributions offered for trail connections are likely insufficient because the
Applicant fails to identify the actual costs of building the trail connections. The City Council
finds the relocation of the two water wells on site is required to develop the property and do
not constitute public benefits. Finally, the City Council finds that most of the items offered
by the Applicant lack timing as to if and when they would occur.
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Accordingly, the City Council hereby finds that:
1. Development Agreement No. 5825 is not consistent with the objectives, policies,
general land uses, and programs specified in the General Plan and any applicable
specific plan or redevelopment plan, because it is significantly lacking in
additional public benefits required to approve a development agreement and seeks
park credits for open space area that is insufficient to meet the City's threshold for
park needs pursuant to Chapter 16.60 of the Orange Municipal Code; and
2. Development Agreement No. 5825 is not compatible with the uses authorized in
the district or planning area in which the real property is located and would
require a general plan amendment, and zone change to make the project
compatible; and
3. Development Agreement No. 5825 is not in conformity with the public necessity,
public convenience, general welfare, and good land use practices because the
proposed project seeks a higher density and land use intensity than what is
currently allowed in the area. The projects lacks additional public benefits
required for the approval of a development agreement and would result in the
increase of residential users of City parks without the benefit of providing
additional park space or fees in lieu; and
4. Development Agreement No. 5825 would not be beneficial to the health, safety,
and general welfare consistent with the policy of the City with respect to
development agreements as provided in Section 17.44.200 because it is
significantly lacking in public benefits to the entire community. The City Council
finds that even the dedication of 1.3 miles of public trails is deficient in
identifying an owner and maintenance responsibilities for the trails, and fails to
identify timing for the trail improvements; and
5. Development Agreement No. 5825 would adversely affect the orderly
development of property or the preservation of property values in the City
because the project as proposed is too dense and intense in terms of allowable
development and land use in the area in which it is located. As such, it would
likely detract from the surrounding properties, negatively affecting property
values; and
6. Development Agreement No. 5825 would not promote and encourage the
development of the proposed project by providing a greater degree of requisite
certainty. The City Council finds that the development agreement proposes to
dedicate 50 acres of public open space but does not identify any group or agency
willing to accept the maintenance of the property or any commitment related to
the timing on when the property would be conveyed as public open space.
Furthermore, the development agreement identifies a 10 acre donation to the
YMCA or similar organization for a recreational amenity but there are no written
commitments from the YMCA or similar organization to accept the property or
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timing identified for the property dedication. And finally, the Applicant proposes
two separate $100,000 contributions for local trail connections but fails to identify
the actual costs to build each connection or when the money would be donated for
the connections.
SECTION V — SPECIFIC PLAN, MAJOR SITE PLAN REVIEW, TENTATIVE
TRACT MAP, TENTATIVE PARCEL MAP AND DESIGN REVIEW COMMITTEE
FINDINGS
The City Council hereby denies Specific Plan No. 001 -09, Tentative Parcel Map No.
2012 -101, Tentative Tract Map No. 17344, Major Site Plan Review No. 0595 -09 and Design
Review Committee No. 4413 -09. The City Council further finds that a recommendation on
the environmental document for this portion of the project is exempt from further analysis
pursuant to CEQA section 15270 (Projects Which are Disapproved) because CEQA does not
apply to projects which a public agency rejects or disapproves.
Specific Plan:
The whole of the findings for Specific Plan approval are not met by the Project.
Required Findings:
1. That the proposal conforms to the General Plan in regard to land use designation
and intensity;
This finding is not met. As corroborated by the findings given for the denial of
General Plan Amendment No. GPA 2009 -002 the City Council finds that the
Project:
a) Does not conform to the General Plan's existing land use designation
without authorization for a change in Land Use designation.
b) Does not adequately approximate density equivalent to or transition to
the surrounding community.
c) Is not considerate of the low intensity concept of area greenbelt plans that
include the property.
d) Does not provide analysis or consistency with the low intensity nature of
the East Orange Plan or Orange Park Acres Plan.
e) Does not facilitate required public park needs required by the City to
justify the Project intensity.
f) Has insufficient analysis to determine that there would not be park
intensification impacts by allowing privatization of parks via changes to
the Open Space — Park General Plan Land Use Designation definition.
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g) Would create land use intensity incompatible with the area due to the
number of land uses that could occur and the massing of buildings that
could block viewsheds.
h) Would result in use elements that would introduce a commercial use to
an area that does not have such uses, thereby causing inconsistent land
uses, change of community character and higher traffic intensity via
commercial support vehicle activity.
i) Would include a senior residential component land use that would not be
supported by close convenient services hence, causing a use not
compatible with the area.
j) Would utilize a three story building component that is out of context with
the intensity of any other buildings in the area.
k) Would not have sufficient assurances in place to prevent the future
conversion of planning Area C to unrestricted apartments which would
increase traffic intensity to the area.
1) Includes use intensity not appropriate in a dam inundation area in such
close proximity to dams.
m) Would intensify emergency response needs in the event of a localized or
regional emergency.
n) Is not consistent with the numerous objectives, goals, and policies of the
General Plan specifically with regard to:
Bullet objective number 2 from "A Vision For Orange: 2030"
under the "Where We Play" header on page I -18 of the General
Plan envisions Santiago Creek protection. The Project has not been
shown to be consistent with this objective in that development
occurs immediately adjacent to the existing creek flow line with
potential to affect creek biology, hydrology and future remediation.
Bullet objective number 3 from "A Vision For Orange: 2030"
under the "Where We Play" header on page I -18 of the General
Plan envisions the City to strive to build a comprehensive system of
parks, open space, equestrian areas, scenic resources, undeveloped
natural areas, as well as a full array of recreational, educational, and
cultural offerings such as libraries, sports, entertainment areas, and
play facilities." The Project has not been shown to be wholly
consistent with this objective in that no public parks are provided as
required by the Orange Municipal Code and the project partially
obscures view of scenic resources.
Bullet objective number 4 from "A Vision For Orange: 2030"
under the "Where We Play" header on page I -18 of the General
Plan and bullet objective number four from "Introduction and
Vision for the Future" on page NR -1 of the General Plan both
envision the City developing a "connected multi -modal network for
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traveling from one end of town to the other that provides the option
for residents from different neighborhoods to access parks, open
spaces, and scenic areas by vehicle, transit, foot, bicycle or, where
appropriate, horse." The Project has not been shown to be wholly
consistent with this objective in that Project trail linkages for the
Santiago Creek Trail and westerly terminus of the Santiago Canyon
Road adjacent trail are not secured. Furthermore, the Project does
not provide a creek trail crossing or widening of the Mabury
adjacent trail as is identified in the General Plan. The project also
does not propose all trails to meet City trail right -of -way
dimensional standards.
General Plan Land Use Element Policy 6.4 seeks to "create and
maintain open space resources that provide recreational
opportunities, protect hillside vistas and ridgelines, and conserve
natural resources." This policy is not met in that the Project does
not provide recreational opportunities in the form of public parks
and public use of the open space area proposed north of Santiago
Creek. The project massing and density also partially obscures
views of hillside vistas and ridgelines.
2. That the proposal contains at least ten gross acres;
The Project contains approximately 110 acres. This finding can be met.
3. That the proposal provides for a mix of uses (such as, residential, commercial,
office, public facilities, open space);
The Project provides a mix of uses. This finding can be met.
4. That by incorporating features such as, but not limited to those listed below, the
proposal constitutes an environment equal to or better than what might be
accomplished under traditional development practices:
a) Where usable open space is provided in excess of the amount required
under conventional zoning;
b) Where natural features are preserved that enhance the development and
will benefit the community such as trees, scenic points, view corridors,
ridgelines, historic buildings or landmarks, unique geological formations
and other community assets;
c) Where perimeter setbacks of the development exceed the minimum
dimension required;
d) Where distinctive design techniques are incorporated such as
architectural treatments, site planning, structural design, landscaping as
well as integration into the community;
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e) Where the Project makes use of non- depletable energy sources for water
heating or space heating;
Where usable recreational amenities are provided in excess of the amount
required;
g) Where special amenities are provided such as daycare, preschool,
community care, or other amenities;
h) Where multi -modal transportation opportunities are provided such as
linkages to pedestrian and recreational trails, and public transit facilities;
i) Where public institutional needs are met by providing for schools,
religious facilities, libraries, post offices, policeTiire facilities; and
j) Where special needs housing is provided.
This finding is not met in its entirety. In addressing each of these issues the
City Council finds as follows:
a) Greater open space would result under the existing Greenbelt plan
designations of the Orange Park Acres and East Orange Plans. The
Project does not wholly consider said plans. The Open Space provided
by the Project does not include open space required by the Orange
Municipal Code that would best serve the City in the form of traditional
public park facilities with recreational facilities and a public parking lot.
b) Site constraints in relation to the surroundings are not adequately
considered. Bulk and height of Project buildings could obstruct view to
nearby Open Space Ridgelines as identified in the General Plan and
incompatibility with the density and scale of the surrounding community
context would result.
c) Perimeter setbacks exceed the requirements of the code however,
setbacks for the bulk and height of the buildings proposed do not
alleviate community compatibility concerns with the Project.
d) The Specific Plan includes distinctive design techniques such as
architectural treatments, site planning, structural design and landscaping;
however, the Specific Plan contains many indefinite clauses that could
result in a liability to the City when administering and maintaining the
Specific Plan. While the Specific Plan provides illustrations and some
framework that would contribute to internal integration, it does not
provide for adequate integration of the Project into the community due to
the nature of uses, intensity, density and height proposed. The Specific
Plan includes inadequate trail timing that is reliant on unpredictable
factors that would need to first occur. The Specific Plan includes
unrealistic contingency provisions for maintenance of the Project's Area
A passive open space, Area D active open space and Project trails.
e) The Specific Plan contains a Sustainable Design section requiring
builders "to go above and beyond" Title 24 standards by a minimum of
five percent. However, the Sustainable Design section contains several
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non - mandatory phrases that could hamper the portrayed sustainable
design for the Project.
f) The Open Space provided by the Project does not include open space
required by the Orange Municipal Code that would best serve the City in
the form of traditional public park facilities with recreational facilities
and a public parking lot.
g) The Project allows for the inclusion of special amenities.
h) The Specific Plan offers on -site trails. The eastern end of the Santiago
Canyon Road adjacent trail would connect to an existing trail. A trail
crossing would be provided at Nicky Way. However, trail connections
for the Santiago Creek adjacent trail and the westerly terminus of the
Santiago Canyon Road adjacent trail are not assured by the Specific Plan.
Completion of a creek crossing trail or expansion of the Mabury Avenue
adjacent trail envisioned in the General Plan would not be accomplished,
and as such conflicts with the General Plan. Furthermore, no linkage to
public transit facilities exists or is proposed.
i) Traffic mitigation needs created by the Project may not be met in that the
necessary mitigation measures /traffic improvements for the Project are
not identified and fully funded Capital Improvement Projects by the City.
Emergency evacuation needs of the Project would likely further strain
emergency responder resources and no detailed plans have been
demonstrated to show that the eventual site operators would alleviate the
need. Park needs of the Project, as required by the Orange Municipal
Code would not be met with public park facilities and a strain on other
existing City park facilities could result from use by residents of the site.
Uncertainty of Planning Area A open space and the Project trails
ownership could result in a strain of City resources to maintain or
encourage maintenance by the master owners association for the Project.
The Specific Plan contains many indefinite clauses that could result in a
liability to the City when administering and maintaining the Specific
Plan.
j) Age - qualified (senior housing) is proposed. However, no special needs'
housing for lower income families is specifically included.
Major Site Plan:
The whole of the findings for Major Site Plan approval are not met by the Project.
Required Findings:
1. The Project design is compatible with surrounding development and
neighborhoods.
This finding is not met. The City Council finds that the Project:
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a) Does not adequately approximate density equivalent to or transition to
the surrounding community. Site constraints in relation to the
surroundings were not adequately considered. Bulk/massing and height
of Project buildings could obstruct view to nearby Open Space
Ridgelines as identified in the General Plan and incompatibility with the
density and scale of the surrounding community context would result.
b) Is not considerate of the low intensity concept of area greenbelt plans that
include the property.
c) Does not provide analysis or consistency with the low intensity nature of
the East Orange Plan or Orange Park Acres Plan.
d) Would create land use intensity incompatible with the area due to the
number of land uses that could occur.
e) Would result in use elements that would introduce a commercial nature
to an area that does not have such uses, thereby causing inconsistent land
uses, change of community character and higher traffic intensity via
commercial support vehicle activity.
f) Would include a senior residential component land use that would not be
supported by close convenient services hence, causing a use not
compatible with the area.
g) Would utilize a three story building component that is out of context with
the intensity of any other buildings in the area.
h) Would not have sufficient assurances in place to prevent the future
conversion of planning Area C to unrestricted apartments which would
increase traffic intensity to an unacceptable level in the area.
2. The Project conforms to City development standards and any applicable special
design guidelines or specific plan requirements.
This finding is not met. The City Council finds that the Project merits denial of
General Plan Amendment No. 2009 -002 and Zone Change No. 1254 -09.
Without the change of land use designation, the Project is incompatible with the
existing General Plan and Zoning Designations for the site because the proposed
uses are not allowed.
3. The Project provides for safe and adequate vehicular and pedestrian circulation,
both on- and off -site.
This finding is not met. The City Council finds that the traffic mitigation needs
created by the Project may not be met in that the necessary traffic improvements
for the Project are not identified and fully funded Capital Improvement Projects
by the City. Emergency evacuation needs of the Project have not been detailed
to demonstrate that site occupants would be able to be evacuated and would be
evacuated in a manner that would not cause disruption of, or intensification to,
existing evacuation routes.
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City services are available and adequate to serve the Project.
This finding is not met. The City Council finds that Traffic mitigation needs
created by the Project may not be met in that the necessary mitigation
measures /traffic improvements for the Project are not identified Capital
Improvement Programs by the City. Emergency evacuation needs of the Project
would likely further strain emergency responder resources and no detailed plans
have been demonstrated to show that the eventual site operators would alleviate
the need. Park needs of the Project, as required by the Orange Municipal Code
would not be met with public park facilities and a strain on other existing City
park facilities could result from use by residents of the site. Uncertainty of
planning Area A open space and the Project trails ownership could result in a
strain of City resources to maintain or encourage maintenance by the master
owners association for the Project. The Specific Plan contains many indefinite
clauses that could result in a liability to the City when administering and
maintaining the Specific Plan.
4. The Project has been designed to fully mitigate or substantially minimize adverse
environmental effects.
This finding is not met. As evidenced in the findings for denial of EIR No.
1818 -09, the Project does not fully mitigate nor substantially minimize adverse
environmental effects.
Tentative Tract Map
The whole of the findings for Tentative Tract Map approval are not met by the
Project. The data and analysis upon which these findings are based are set forth in the
record.
Required Finding:
A. The requirements for the filing of subdivision maps shall be governed by the
provisions of the Subdivision Map Act and the provisions of Title 16 of the
Orange Municipal Code (OMC). All maps shall comply with the provisions of the
Subdivision Map Act, the City Zoning Ordinance, Title 16 of the OMC, and any
other ordinance, statute or law pertaining to the use, sale, leasing or subdivision
of land.
1. The proposed subdivision map and the design and improvements are
consistent with City of Orange General Plan which includes the East
Orange Plan and Orange Park Acres Plan as part of the Land Use
Element.
This finding is not met. The City Council finds that the Project merits
denial of General Plan Amendment No. 2009 -002 and Zone Change No.
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1254 -09. Without the change of land use designation, the Project is
incompatible with the existing General Plan and Zoning Designations for the
site because the proposed uses are not allowed.
2. The site is physically suitable for the type of development and the
proposed density of development.
This finding is not met. The City Council finds that the age- restricted
senior) component of the Project is not located in an area where necessary
support services are conveniently located. The site is located in a dam
inundation zone in close proximity to two dams. Associated potential dam
inundation impacts to life and property have not been fully mitigated by the
Project, specifically in consideration of the request to have the City's highest
density land use designation established for the senior independent and
assisted living land uses in planning Area C. The density of planning Area C
and the massing of building in planning Area B for the Project is out of
character with the surrounding community because the massing and density is
substantially higher than the surrounding rural suburban community.
Furthermore, the three story building component in planning Area C is out of
context with any other buildings in the area. The Project does not adequately
approximate density equivalent with or transition to the surrounding
community. The Project is not considerate of the low intensity concept of
area greenbelt plans that include the property. The Project does not provide
analysis or consistency with the low intensity nature of the East Orange Plan
or Orange Park Acres Plan. The Project does not facilitate required public
park needs required by the City to justify the Project density. The Project
would create land use intensity incompatible with the area due to the number
of land uses that could occur and the massing of buildings that could block
viewsheds. Project uses would introduce a commercial nature to an area that
does not have such uses, thereby causing inconsistent land uses, change of
community character and higher traffic intensity via commercial support
vehicle activity. The road infrastructure of the area requires improvements
merited by the Project and such improvements are not identified in the City's
Capital Improvement Program. The Project would intensify emergency
response needs in the event of a localized or regional emergency.
3. The design of the subdivision or the proposed improvements are not likely to
cause substantial environmental damage or substantially and unavoidably
injure fish or wildlife or their habitat.
This finding is not met. Environmental Impact Report No. 1818 -09 discloses
the Significant and Unavoidable Impacts of the DEIR including:
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Grading and Construction Aesthetic Impacts
Long -Term Aesthetic Visual Impacts
Light and Glare Impacts
Air Quality Impacts
Hydrology and Water Quality Impacts (Dam Inundation)
Transportation /Traffic Impacts
Cumulative (Aesthetics, Air Quality, and Traffic) Impacts
In addition to the above impacts, the City Council finds that the
Environmental Impact Report No. 1818 -09 does not:
Wholly reflect the independent judgment and analysis of
the City of Orange.
Provide an adequate assessment of the potentially
significant environmental impacts of the proposed
Project.
Provide adequate clarity, information, accuracy,
disclosure and completeness.
Provide adequate peer review.
The City Council further finds that the Environmental Impact Report No.
1818 -09:
Includes deferral of mitigation for multiple impact areas.
Would not further the City's goals to provide for the
safety of residents or protect the liability of the City.
Includes dismissive and or misleading components,
specifically pertaining to Threshold analysis and
responses for: the Land Use analysis with regard to a lack
of analysis of changing the existing Orange Park Acres
Plan, East Orange Plan, Creek Greenbelt Plans and the
proposed General Plan text amendment implications for
the City's Open Space, Park General Plan Land Use
Element designation; Biology with regard to lighting
impacts on sensitive species; Hydrology and Water
Quality with regard to dam inundation; and, Traffic with
regard to the conclusion that no impacts would result
even if all mitigation improvements were implemented.
Therefore, the City Council finds that the Project may cause substantial
environmental damage or substantially and unavoidably injure fish or wildlife
or their habitat beyond that which is reported in Environmental Impact Report
No. 1818 -09.
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4. The design of the subdivision or type of improvements are not likely to
cause serious public health problems.
This finding is not met. The City Council finds Environmental Impact
Report No. 1818 -09 inadequate for the reasons stated above and in the denial
findings for Environmental Impact Report No. 1818 -09. The Project has at
least three potential serious impact areas related to public health as follows:
The Project is located adjacent to the Villa Park Landfill
and methane migration is a known potential issue for
Project land and buildings.
The Project has Volatile Organic Compounds (VOCs) on-
site requiring remediation.
Portions of the Project are located in and/or adjacent to a
Very High Fire Hazard Severity Zone and approval of use
of County land for fire fuel modification purposes is
necessary to secure the tract as proposed.
Given the deficiencies in Environmental Impact Report No. 1818 -09, the City
Council is unable to wholly rely on it to make this finding, especially in
consideration of responsible agency concerns regarding the Project.
S. The design of the subdivision or the type of improvements will not conflict
with easements, acquired by the public at large, for access through or use
of, property within the proposed subdivision.
This finding can be made in that there are no known easements for public use
of any portion of the Property.
6 The subdivision provides for, to the extent feasible, future passive or
natural heating or cooling opportunities.
This finding is not met. The Specific Plan contains a Sustainable Design
section requiring builders "to go above and beyond" Title 24 standards by a
minimum of five percent. However, the Sustainable Design section contains
several non - mandatory phrases that could hamper the portrayed sustainable
design for the Project. The Project Specific Plan does not contain
requirements that make passive or natural heating or cooling mandatory.
7. The proposed subdivision complies with the development standards
contained in the City's Zoning Ordinance.
This finding is not met. The City Council finds that the Project merits denial
of General Plan Amendment No. 2009 -002 and Zone Change No. 1254 -09.
Without the change of land use designation, the Project cannot comply with
the development standards of the Zoning Ordinance because the proposed
uses are not allowed.
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8. The proposed uses are compatible with existing uses located in the vicinity
of the subject site.
This finding is not met. The density of planning Area C and the massing of
building in planning Area B for the Project is out of character with the
surrounding community because the massing and density is substantially
higher than the surrounding rural suburban community. Furthermore, the
three story building component in planning Area C is out of context with any
other buildings in the area. The number of lots per acre in planning Area D is
not commensurate to the larger size lots to the east of the Project site,
specifically south of Santiago Creek. The Project does not adequately
approximate density equivalent with or transition to the surrounding
community. The Project is not considerate of the low intensity concept of
area greenbelt plans that include the property. The Project does not provide
analysis or consistency with the low intensity nature of the East Orange Plan
or Orange Park Acres Plan. The Project would create land use intensity
incompatible with the area due to the number of land uses that could occur
and the massing of buildings that could block viewsheds. Project uses would
introduce a commercial nature to an area that does not have such uses, thereby
causing inconsistent land uses, change of community character and higher
traffic intensity via commercial support vehicle activity. The road
infrastructure of the area requires improvements merited by the Project and
such improvements are not identified in the City's Capital Improvement
Program.
9. The Project is subject to conditions that will preserve the public welfare
and insure that the Project will not have an adverse impact on adjacent
land uses, and local transportation systems, including local and regional
trails.
This finding is not applicable. No conditions are merited because the tract
map is denied in part because the Project will have an adverse impact on
adjacent land uses for the reasons cited in this resolution.
10. City departments have reviewed the proposed Project and found that City
services are available and adequate to serve the needs of the proposed
use.
This finding is not met. The Traffic mitigation needs created by the Project
may not be met in that the necessary mitigation measures /traffic
improvements for the Project are not identified and fully funded Capital
Improvement Projects by the City. Emergency evacuation needs of the
Project would likely further strain emergency responder resources and no
detailed plans have been demonstrated to show that the eventual site operators
would alleviate the need. Park needs of the Project, as required by the Orange
Municipal Code would not be met with public park facilities and a strain on
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other existing City park facilities could result from use by residents of the site.
Uncertainty of planning Area A open space and the Project trails ownership
could result in a strain of City resources to maintain or encourage maintenance
by the master owners association for the Project. The Specific Plan contains
many indefinite clauses that could result in a liability to the City when
administering and maintaining the Specific Plan.
11. The proposed subdivision allows implementation of local and regional
recreational opportunities as stated in the City's General Plan.
This finding is not met. The Project does not facilitate required public park
needs required by the City. The Open Space provided by the Project does not
include open space required by the Orange Municipal Code that would best
serve the City in the form of traditional public park facilities with recreational
facilities and a public parking lot. A strain on other existing City park
facilities could result from use by residents of the site. Greater open space
would result under the existing Greenbelt plan designations of the Orange
Park Acres and East Orange Plans. The Project did not wholly consider said
plans. The Project has insufficient analysis to determine that there would not
be park intensification impacts by allowing privatization of parks via changes
to the Open Space — Park General Plan Land Use Designation definition. The
Specific Plan includes inadequate trail timing that is reliant on unpredictable
factors that would need to first occur. The Specific Plan includes unrealistic
contingency provisions for maintenance of the Project's Area A passive open
space, Area D active open space and Project trails. Trail connections for the
Santiago Creek adjacent trail and the westerly terminus of the Santiago
Canyon Road adjacent trail are not assured by the Project. Completion of a
creek crossing trail or expansion of the Mabury Avenue adjacent trail, per the
General Plan, would not be accomplished.
12. A sufficient water supply is available to the Project.
This finding is met.
Design Review Committee:
The whole of the findings for Design Review Committee approval are not met by the Project.
Required Findings:
1. In the Old Towne Historic District, the proposed work conforms to the
prescriptive standards and design criteria referenced and /or recommended by
the DRC or other reviewing body for the Project (OMC 17.10.070.F.1).
This finding is not applicable. The Project is not in the Old Towne Historic
District.
2. In any National Register Historic District, the proposed work complies with
the Secretary of the Interior's standards and guidelines (OMC 17.10.07.F.2).
This finding is not applicable. The Project is not in a National Register
Historic District.
3. The Project design upholds community aesthetics through the use of an
internally consistent, integrated design theme and is consistent with all
adopted specific plans, applicable design standards, and their required
findings (OMC 17.10.07.F.3).
This finding is not met. Although the Project is internally consistent with an
integrated design theme, the City Council finds that overall community
aesthetics of the Project:
a) Does not adequately approximate density equivalent to or transition to
the surrounding community. Site constraints in relation to the
surroundings were not adequately considered. Bulk/massing and height
of Project buildings could obstruct view to nearby Open Space
Ridgelines as identified in the General Plan and incompatibility with the
density and scale of the surrounding community context would result.
b) Is not considerate of the low intensity concept of area greenbelt plans that
include the property.
c) Does not provide analysis or consistency with the low intensity nature of
the East Orange Plan or Orange Park Acres Plan.
d) Would result in use elements that would introduce a commercial nature
to an area that does not have such uses, thereby causing buildings with a
mass and architecturally - related function that reflect a change of
community aesthetics.
e) Would utilize a three story building component that is out of context with
the intensity of any other buildings in the area.
4. For infill residential development, as specified in the City of Orange Infill
Residential Design Guidelines, the new structure(s) or addition are
compatible with the scale, massing, orientation, and articulation of the
surrounding development and will preserve or enhance existing neighborhood
character (OMC 17.10.07.F.4).
This finding is not applicable. The Project is not infill residential
development, as specified in the City of Orange Infill Residential Design
Guidelines.
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ADOPTED this 81h day of July, 2014
Pi`rtJ
eyes E. Smith, Mayor, ity of Orange
ATTEST:
Mary a hy, City Clerk, Cit _ _ nge
I, MARY E. MURPHY, City Clerk of the City of Orange, California, do hereby
certify that the foregoing Resolution was duly and regularly adoted by the City Council of
the City of Orange at a regular meeting thereof held on the 8 day of July, 2014 by the
following vote:
AYES: COUNCILMEMBERS: Alvarez, Smith, Murphy
NOES: COUNCILMEMBERS: Whitaker, Bilodeau
ABSENT: COUNCILMEMBERS: None
ABSTAIN: COUNCILMEMBERS: None
Mary E. rp City Cle range
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