CARLSBAD
CLOVIS
IRVINE
LOS ANGELES
PALM SPRINGS
POINT RICHMOND
RIVERSIDE
ROSEVILLE
SAN LUIS OBISPO
3210 El Camino Real Suite 100, Irvine, California 92602 949.553.0666 www.lsa.net
MEMORANDUM
DATE: December 13, 2023
TO: Hayden Beckman, Senior Planner
FROM: Ryan Bensley, AICP, Principal
SUBJECT: Modifications to the Bolsa Chica Senior Living Community Specific Plan No. 19 (based on December 11, 2023 submittal)
It is LSA’s understanding that Hines (Project Applicant) has modified the development plans for the Bolsa Chica Senior Living Community Project from its original design as analyzed in the Draft Environmental Impact Report (EIR) circulated in April 2023 (Original Project). These changes, as understood by LSA, are summarized in Table A: Project Design Comparison below and are based on the updated Conditional Use Permit (CUP) and Specific Plan (Revised Project) submitted by the Project Applicant on December 11, 2023.
Table A: Project Design Comparison
Project
Total
Living
Units
Memory
Care
Units
Assisted
Living
Units
Independent
Living Units
Building
Square
Footage
Number
of
Stories
Building
Height in
Feet
Subterranean
Parking
Spaces
Original Project1 213 28 62 123 260,000 5 65 203
Revised Project2 178 28 73 77 244,295 4 52 160
Net Change (35) 0 11 (46) (15,705) (1) (13) (43)
1 City of Huntington Beach. 2023. Bolsa Chica Senior Living Community Draft Environmental Impact Report (SCH No. 2022110040). April.
Huntington Beach, California: State Clearinghouse. Website: https://files.ceqanet.opr.ca.gov/282863-4/attachment/QJCTr5XZJ6P- sWUYrqeZtEPqXv8enk-Ixlrn- (accessed December 12, 2023)
2 Wimberly Allison Tong & Goo. 2023. Huntington Beach Senior Living Development Plan Resubmittal. December 11. Huntington Beac h, California (accessed December 12, 2023)
As shown in Table A, the Revised Project would result in a reduced scale of development in comparison to the Original Project by providing fewer units within a shorter building that would contain less square footage. As described in the EIR, many of the Original Project’s impacts would be associated with the emissions, noise, and vehicle miles traveled as a result of project-related vehicle trips. By reducing the proposed number of units, particularly the number of independent living units, which have a higher trip generation rate than memory care units or assisted living units, the Revised Project would generate less vehicle noise and emissions and fewer vehicle miles traveled than the Original Project.
Under the Revised Project, the maximum height of the proposed building would be approximately 13 feet shorter than the Original Project, which would also result in reduced impacts related to aesthetics, specifically shade and shadow impacts, by reducing the length of the building’s shadows on Bolsa Chica Street, Warner Avenue, and several immediately surrounding properties.
12/13/23 «P:\HBC2201.01\04.3 - Final EIR\Design Change Memo\Bolsa Chica Senior Living Design Change Memo.docx» 2 Further, the development of a smaller building would be expected to result in a shorter construction schedule and slightly less overall construction activity; however, the Revised Project’s daily peak emissions and noise due construction is expected to be similar to the Original Project.
Aside from the changes to the impact analysis described, the Revised Project would result in the same impacts as the Original Project as the general scope of development would remain the same, with the exception of the reduced in units and building height.
Under Section 15088.5 of the California Environmental Quality Act (CEQA) Guidelines, recirculation of an EIR is triggered when “significant new information” is added to the EIR following public circulation. New information is not considered significant unless it changes the EIR in a way that deprives the public of a meaningful opportunity to comment upon substantial adverse environmental effects of the proposed project. “Significant new information” can be defined as the following:
• A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented;
• A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance;
• A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project's proponents decline to adopt it; or • The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. (Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043).
Section 15088.5 also states that recirculation is not required when the information added results in insignificant modifications to an adequate EIR.
As discussed above, the Revised Project would reduce the scale of the proposed development, which would generally reduce the intensity of the anticipated environmental impacts in comparison to the Original Project. The Revised Project was developed in response to comments raised during the public comment period regarding the Original Project’s building height and size in comparison to surrounding land uses. Therefore, it can be reasonably assumed that the Revised Project’s design modifications would not result in any new or increased significant environmental impacts beyond those already evaluated and disclosed in the EIR. Consequently, no new feasible project alternatives or mitigation measures have been identified as none are necessary.
Based on the factors discussed above, the City’s consideration of the Revised Project rather than the Original Project would not substantially alter the conclusions reached in the EIR or the validity of the document as a whole. Recirculation of the EIR would not be required under CEQA Guidelines Section 15088.5 as the EIR would remain adequate as the appropriate CEQA document to analyze the potential environmental effects of the Revised Project.