3.5 - Land Use and Planning

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1 City of Irvine - William Lyon Homes: Vista Verde Land Use and Planning Land Use and Planning Introduction This section describes existing land uses, applicable land use plans, policies or regulations, and any potential conflicts that may arise through Project implementation. Descriptions and analysis in this section are derived from field observation, review of pertinent planning documents including the City s General Plan, and from project information contained in Appendix A, Notice of Preparation and Correspondence Environmental Setting University Park Planning Area (PA) 20 encompasses approximately 592 acres within the central portion of the City of Irvine. It is bound by the San Diego Freeway (Interstate 405) to the north, Culver Drive to the west, and University Drive to the south and east. The Village of University Park includes approximately 503 residential acres, 22 commercial acres, and 19 open space acres (recreation). The residential acres are further broken down by Low Residential (93 acres), Medium Residential (296 acres) and Medium-High Residential (114 acres). The Vista Verde residential project is located within the east portion of PA 20 along Michelson Drive, a two-lane divided roadway that runs east-west through the planning area. The 8.47-acre Vista Verde parcel (APN ) is located on Michelson Drive between Yale Avenue and Rosa Drew Lane. The site is bound by Michelson to the north, Rosa Drew Lane to the east and southeast, the Parkside Recreation Center and Dave Robins Park to the southwest, and homes along Cottonwood to the west. Onsite Land Uses The project site is the former Vista Verde Elementary School currently owned by Irvine Unified School District (IUSD). After the school use on site ceased in 2005, the Pacific Pointe Church began use of the school in The school is used by the Pacific Pointe Church for weekly Sunday services from 10:00-11:30am and occasionally on Wednesday evenings for church activities. Features of the site include a main school building, four portable classroom structures, playground areas, grass-covered areas, an athletic field, and associated parking areas. Surrounding Land Uses The site is located within a residential area adjacent to Dave Robins Park, a private neighborhood park. Surrounding land uses include: North - Michelson Drive, attached condominium residences across Michelson Drive, and Rancho San Joaquin Middle School South - Rosa Drew Lane, single-family residences across Tamarack Lane East - Rosa Drew Lane, Parkwood Apartments across Rosa Drew Lane Michael Brandman Associates 3.5-1

2 Land Use and Planning City of Irvine - William Lyon Homes: Vista Verde West - Single-family residences, Dave Robins Park, and recreation center Existing General Plan Designation The Project site s current General Plan land use designation is Institutional-Educational Facilities. This land use category includes public and private schools and support facilities from kindergarten through college/university levels and allows residential developments as noted in the General Plan text (pursuant to Land Use Element Figure A-3, note 3). The General Plan land use designations for the areas surrounding the site are Institutional-Educational Facilities to the north (Rancho Middle School), Medium Density Residential to the north, west, and southwest, and Medium High Density Residential to the east. The Medium Density areas permit an overall density of up to 12.5 dwelling units per acre, and include single-family homes in the Parkside Neighborhood to the west and to the southwest, and single-family attached homes to the north along Michelson Drive. The Medium High Density area permits an overall density of up to 31 dwelling units per acre and includes the Parkwood Apartments to the east along Rosa Drew Lane. Existing Zoning Designation The project site is designated as 6.1 Institutional in the City of Irvine Zoning Ordinance. This designation allows for a variety of permitted uses, including schools, parks, residential shelters, and wireless communications facilities, and conditionally permitted uses including churches, community facilities, childcare centers, conference facilities, government facilities, and hospitals. Zoning for areas surrounding the project site includes the 6.1 Institutional district (Rancho Middle School), 2.2B Low-Density Residential district (Parkside Neighborhood), and 2.4B Medium-High Density Residential district (Parkwood Apartments). Regional Comprehensive Plan and Guide Orange County and the City of Irvine are located at the western edge of a six-county metropolitan region composed of Orange, Los Angeles, Ventura, Riverside, San Bernardino, and Imperial Counties. The Southern California Association of Governments (SCAG) serves as the federally recognized Metropolitan Planning Organization for this Southern California Region. Orange County and its jurisdictions constitute the Orange County subregion within the SCAG region. The Orange County subregion is governed by the Orange County Council of Governments (OCCOG). SCAG has developed a Regional Comprehensive Plan (RCP), which is a major advisory plan that addresses important regional issues like housing, traffic/transportation, water, and air quality. The most recent version of the RCP (adopted in 2008) is an advisory plan only. This plan identifies voluntary best practices to approach growth and infrastructure challenges in an integrated and comprehensive manner and includes goals and outcomes to measure progress toward a more sustainable region. The RCP is an advisory document to local agencies in the Southern California region for their information and voluntary use for preparing local plans and handling local issues of regional importance. SCAG s RCP includes a package of policies related to growth and development that Michael Brandman Associates

3 City of Irvine - William Lyon Homes: Vista Verde Land Use and Planning seek to coordinate infrastructure with projected population and housing growth. In general, SCAG policies encourage job and housing opportunities to be balanced at the county or Regional Statistical Area (both much larger than the project level). SCAG policies also encourage job growth to be concentrated near transit services and transit nodes, and existing freeways, HOV lanes, and toll roads. Given the expansive scope of and general nature of the RCP, not all of these policies apply to every project. This project is not of region-wide significance per SCAG Intergovernmental Review (IGR) criteria and CEQA Guidelines (Section 15206). The project is not a residential development of more than 500 units, and therefore an analysis of project consistency with the RCP is not required Thresholds of Significance According to Appendix G of the CEQA Guidelines, a project would normally have a significant effect on the environment if it would: b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect. The Initial Study included in Appendix A provides substantial evidence that impacts associated with the following thresholds would have no impact: a) Physically divide an established community. c) Conflict with any applicable habitat conservation plan or natural community conservation plan. Therefore, these topics are not addressed in the following impact analysis Project Impacts Land Use Plan, Policy or Regulatory Conflict Impact LUP-1 Would the project conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? Impact Analysis The current General Plan land use designation is Institutional-Educational Facilities. The Project site s current zoning designation, 6.1 Institutional, does not allow for residential development of the nature proposed by the applicant. As a result, the project includes requests for: Michael Brandman Associates 3.5-3

4 Land Use and Planning City of Irvine - William Lyon Homes: Vista Verde A General Plan Amendment ( PGA) to: 1) change the site s land use designation to Medium Density Residential (MDR), to 2) increase the General Plan residential cap for Medium Density Residential by 66 units, and 3) to decrease the non-residential cap by 38,871 square feet (see Table 3.5-1). Note that there will be an increase of 15 Medium Density Residential Units due to the fact 51 unallocated units in University Park will be utilized by the Project. Thus, the difference between the 66 proposed units and the 51 unallocated units is 15 units, as indicated by the * symbol in the table below. Table 3.5-1: General Plan Amendment - University Park Planning Area 20 General Plan Category Existing General Plan Intensity Cap (du/sf) Added/ (Deleted) Intensity (du/sf) Proposed General Plan Intensity Cap (du/sf) Medium Density Residential 1,717 du 66 du 1,783 du Planning Area Total Residential 2,805 du 66 du 2,820 du * Institutional-Educational Facility 155,078 sf (38,871 sf) 116,207 sf Planning Area Total Non- Residential 365,556 sf (38,871 sf) 326,685 sf Notes: * The increase of 15 Medium Density Residential units is proposed due to the fact there are currently 51 unallocated units in University Park. This reflects proposed amendment to General Plan Table A-1: Maximum Intensity Standards by Planning Area. Source: City of Irvine. A Zone Change ( PZC) to change the zoning designation to 2.3B Medium Density Residential (Table 3.5-2). The Project would add 66 dwelling units to the existing Maximum Building Intensity of 98 dwelling units, for a revised maximum building intensity of 164 dwelling units. Additionally, the planning area total residential cap would be changed by the addition of the 66 dwelling units. The existing maximum building intensity would increase from 2,754 dwelling units to 2,820 dwelling units. The Institutional 6.1 Educational Facilities existing maximum building intensity would be reduced by 38,871 square feet from 155,078 square feet to 116,207 square feet. In addition, the Planning Area total non-residential existing maximum building intensity would be reduced by 38,871 feet and would change from 402,630 square feet to 363,759 square feet. The changes above would be reflected in the intensity tables in the Zoning Code s Chapter Michael Brandman Associates

5 City of Irvine - William Lyon Homes: Vista Verde Land Use and Planning Table 3.5-2: Zone Change - University Park Planning Area 20 Zoning District Existing Maximum Building Intensity (du/sf) Added/(Deleted) Building Intensity (du/sf) Revised Maximum Building Intensity (du/sf) Medium Density Residential 2.3B 98 du 66 du 164 du Planning Area Total Residential 2,754 du 66 du 2,820 du Institutional Educational Facilities Planning Area Total Non- Residential 155,078 sf (38,871 sf) 116,207 sf 402,630 sf (38,871 sf) 363,759 sf Notes: Reflects proposed amendment to Statistical Analysis table of Section of the Zoning Code. Source: City of Irvine. There is also a Master Plan ( PMP) application, a Park Plan ( PPP) application and a Tentative Tract Map ( PTT), along with the current environmental review. Compatibility of the Vista Verde Residential Project with the Surrounding Area Existing residential uses, local streets and a private neighborhood park surround the Project site within the General Plan Medium Density Residential and Medium High Density land use categories. Surrounding residential uses include single-family detached and attached homes within the 2.2 Low- Density Residential zoning district, and apartments within the 2.4B Medium-High Density Residential zoning district (Exhibit and Exhibit 3.5-2) The Project proposes a total of 66 singlefamily detached homes with an overall density of 7.8 dwelling units per acre (du/ac). This density is within the maximum limits of the MDR designation of 12.5 du/ac. Potential land use compatibility issues are focused on the Project interface with surrounding residential developments. The existing school s peripheral open space/berm and school building setbacks along Michelson Drive and Rosa Drew Lane will be reduced by Project landscaped residential setbacks along these streets. These setbacks will conform to Medium Density Residential standards (with rear yard setbacks of 10 feet) with slope landscaping to include shrubs, perimeter accent trees, and street trees. No significant compatibility impact would occur at these locations. The project abuts the Parkside Recreation Center and Dave Robins Park to the southwest. The singlefamily homes are compatible with these recreational facilities. Existing homes along Cottonwood are currently separated from school buildings on the project site by a block wall, school parking lot and open playfields. The Project would locate single-family homes adjacent to rear yards of these existing single-family residences along Cottonwood. This condition of abutting single-family homes is common within Irvine, University Park, and the adjacent Parkside Neighborhood, and is regulated from a compatibility standpoint by compliance with rear yard setback standards. As an additional design feature to soften the interface of existing and new homes along Michael Brandman Associates 3.5-5

6 Land Use and Planning City of Irvine - William Lyon Homes: Vista Verde this common boundary, the project proposes placement of screening trees along the block wall in the rear yards of the new homes. No significant land use compatibility impact would occur along this interface with the project. The Project is generally compatible with the densities and residential character of the surrounding area. As a result, the project is considered environmentally compatible with surrounding land uses and no significant impacts are anticipated. General Plan Consistency The Institutional-Educational Facilities land use category allows certain types of residential development as specifically noted in the General Plan text. The project will require a General Plan Amendment (GPA) to increase the maximum number of dwelling units in University Park PA 20 by 66 units and to bring the land use designation into conformance with the proposed Zone Change to Medium Density Residential. An increase in the allowable number of residential units in PA 20 would increase the City s housing stock and improve jobs/housing balance (see Section 3.7 Population and Housing). An analysis of the consistency of the Project with General Plan elements and applicable policies is presented below: Land Use Element The Project proposes amending the General Plan Land Use Element to designate the project site as Medium Density Residential. The Medium Density Residential land use category provides for the development of attached and conventional detached housing and other types of residential uses that have open space characteristics similar to single-family neighborhoods. Since the Project proposes to locate 66 single-family detached homes in close proximity to existing residential neighborhoods of a similar density, the Project complies with the Medium Density Residential land use category. Further guidance in the development of the Project site is provided by General Plan Policies A-4(a), A-6(h), and A-6(i). The applicable components of these policies are excerpted and addressed below: Objective A-4: Balanced Land Uses. Manage growth to ensure balanced residential and nonresidential development throughout the City. Policy (a): Ensure that land uses enable the City to provide necessary municipal services by: Implementing and monitoring Statistical Tables A-1 and A-2. Consistency Analysis: Necessary adjustments to statistical tables A-1 (Maximum Intensity Standards by Planning Area) and A-2 (Non-Regulatory Maximum Intensity Standards: Land Use Acreage by Planning Area) will be made as a result of the proposed GPA for the Project. The proposed GPA would increase the maximum number of residential units allowed in the University Park Planning Area 20 and the City by 66 dwelling units, and would result in a corresponding decrease in non-residential square footage by 38, Michael Brandman Associates

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11 City of Irvine - William Lyon Homes: Vista Verde Land Use and Planning The proposed GPA and Zone Change will improve the existing job/housing balance within the City consistent with Objective A-4. Policy (c): Achieve a land use balance through the following methods: Coordination of land use and circulation patterns to ensure adequate circulation capacity and infrastructure. Promotion of a diversity of housing types and affordability to meet the development objectives of the housing element. Designation of sufficient institutional land to meet the needs of each planning area. Provision of adequate housing opportunities to support employment growth. Provision of open space areas. Consistency Analysis: The Project represents an infill development on a former school site that is no longer needed to meet the institutional-educational facilities needs of the planning area and community. Additionally, the Project, being an infill project, helps the City meet the goals of SB 375, which encourages in-fill development in urbanized areas. The site is located in area with established circulation patterns and existing roads with adequate capacity to serve the Project. The Project proposes conventional single-family detached homes consistent with the character of the surrounding neighborhood and objectives of the housing element. Housing provided by the Project will provide jobs/housing balance to support the City s existing employment base. Although the Project will remove open areas associated with the former school site, the Project includes a Park Plan, which proposes payment of park in-lieu fees to fulfill the community park requirement or if annexed, developer-constructed improvements to the existing Dave Robins Park. No significant conflict with the land use balance objective is anticipated. Objective A-6: Land Use Compatibility. Achieve harmonious land use patterns throughout the City. Policy (a): Ensure, through the discretionary review process, the public health, safety, and welfare of sensitive receptors and land uses when locating such uses in proximity to the following land uses: Uses that handle, generate, and/or transport hazardous substances (as defined by federal and state regulations) Uses that create excessive noise Uses that create excessive dust Uses that create other land use conflicts At the same time, ensure that the proposed sensitive receptors/land uses will not have an impact on the continued operation and/or expansion of the following land uses: Michael Brandman Associates

12 Land Use and Planning City of Irvine - William Lyon Homes: Vista Verde Airports Surface utilities Offsite hazardous waste facilities Solid waste facilities Manufacturing uses Research and development uses Mining and processing uses Any land use that handles, generates, and/or transports hazardous substances as defined by federal and state regulations Consistency Analysis: As with the former school use of the site, the Project would locate a sensitive receptor land use (i.e. residential) on the project site. However, the new homes would be located within an established residential neighborhood of the University Park Planning Area. No uses that would handle, generate or transport hazardous substances, that would create excessive noise or dust, or that would result in other land use conflicts exist or are planned in proximity to the Project. As the residential project is not located near any airport, surface utilities, solid waste or hazardous waste facilities, manufacturing uses, research and development uses, or mining and processing uses, the project would have no impact on the operations or expansion potential for such uses. The Project would not conflict with any public health, safety, and welfare objectives of the General Plan. Note that remaining Policies (b) through (h) all deal with locating sensitive receptors near hazardous waste, landfill, airports, or similar facilities, and therefore do not apply to the Project for similar reasons. Circulation Element The project site is located at 5144 Michelson Drive in University Park. A traffic study has been prepared in order to adequately and accurately determine the overall traffic impacts of the Project. As discussed in Section 3.9, Transportation and Traffic, the construction and operation of the project would not cause any significant and unavoidable impacts. The Project will further the intent of several Circulation Element policies and objectives, including the following: Objective B-2: Roadway Design. Develop a vehicular circulation system consistent with high standards of transportation engineering safety and with sensitivity to adjoining land uses. Policy (a): Align roadways in relationship to adjoining land uses to minimize noise and visual impacts. Consistency Analysis: Vehicular access to the Project would occur via a new interior loop road utilizing a single full intersection at Michelson Drive. This intersection has been located near the existing school site driveway entrance/exit to Michelson Drive to minimize new noise and visual impacts to surrounding residences. A left turn pocket into the site along westbound Michelson will be provided. Daily traffic volumes and movement through this intersection would be well within the capacities of local residential streets and would be controlled by a STOP sign. The project Michael Brandman Associates

13 City of Irvine - William Lyon Homes: Vista Verde Land Use and Planning intersection at Michelson Drive will be designed to provide adequate sight distance for vehicles exiting the project, consistent with City of Irvine traffic safety standards. Policy (e): Design roadways which: Discourage through traffic in residential neighborhoods. Prohibit parking on all thruways, parkways, and community collectors. Limit the routes, speeds, and operation types of trucks and buses. Consistency Analysis: The project interior loop road with single access point at Michelson Drive avoids any potential for cut-through traffic within residential neighborhoods. Parking would occur within the interior of the project without any spillover impact on thruways, parkways, and community collectors (e.g., Michelson Drive, Rosa Drew Lane). All vehicles would be required to follow posted speed limits and established routes. Policy (f): Visually enhance the appearance of roadways and parking areas through design techniques and landscaping. Particular attention should be paid to streetscape design and the creation of new, and preservation of existing, view corridors. Consistency Analysis: Project landscape and parking plans will be reviewed by the City for conformance to established development standards, including perimeter streetscape design and views. Policy (g): Include mitigation measures in the approval of all proposed developments to minimize negative impacts of the automobile. Consistency Analysis: As discussed in Section 3.9, Transportation and Traffic, the construction and operation of the Project would not cause any significant and unavoidable impacts. Based on City of Irvine thresholds of significance, no transportation and traffic mitigation measures would be needed for the Project. Housing Element The Goal of the Housing Element reads, Provide for safe and decent housing for all economic segments of the community. One component necessary for the provision of safe and decent housing is an affordable housing strategy. The strategy for the project is currently being prepared and it is anticipated that with the approval of the strategy by the City there will be adequate housing provided for all economic segments of the community. The City s Fair Share for the planning period from January 1, 2006 through June 30, 2014, was established by SCAG at 35,660 units. 1 Given this need, the project site s ultimate 66 dwelling units would incrementally help the City improve its jobs- 1 Note that per the City of Irvine General Plan, SCAG reports that the City s regional housing need is 10,782 dwelling units (City of Irvine General Plan Page C-50). The current regional housing needs assessment (RHNA) of 35,660 units is noted in the text above because it is a more updated figure than what is in the City s General Plan. Michael Brandman Associates

14 Land Use and Planning City of Irvine - William Lyon Homes: Vista Verde housing balance and help the City meet its SCAG defined need by reducing the number of needed new units to 10,716. Seismic Element The Project site is mapped in the Seismic Element as being within Seismic Response Area 2 (SRA- 2), which is characterized by denser soils, deeper groundwater, and low potential for seismic hazards. Both the State and the City have building code requirements to address this designation. A Geotechnical Due-Diligence Review has been prepared for the project indicating no significant potential for liquefaction hazards. The document indicates the site is considered developable utilizing standard grading techniques similar to the existing former school and surrounding neighborhood. The Project will be constructed in compliance with recommendations of the final geotechnical report, therefore mitigating any negative impact. Cultural Resources Element The Cultural Resources Element of the General Plan has a goal that states: Ensure the proper disposition of historical, archaeological, and paleontological resources to minimize adverse impacts, and to develop an increased understanding and appreciation for the community s historic and prehistoric heritage, and that of the region. Given the fact that the site has been previously disturbed through development of the closed Vista Verde Elementary School, it is not anticipated that any archaeological or paleontological resources are present Onsite. Implementation of City Standard Conditions requiring cultural resources monitoring for development projects would mitigate any potential impact and assure compliance with Cultural Resources Element goals and objectives. Noise Element The goal of the Noise Element is, Contribute to a healthy and safe environment by minimizing noise impacts. This goal will be met through the design of the residential project, and the implementation of recommendations specified in the project Acoustical Assessment, which demonstrates that the project complies with the City noise ordinance. The Acoustical Assessment applies the interior noise standards and land use compatibility standards contained in the Noise Element and Noise Ordinance. Public Facilities and Services Element The Public Facilities and Services anticipated and required by this General Plan Element include Police Services, Fire Services, School Facilities, Library Services, Child Care Centers, Senior Centers, Community Center/Youth Center and Swimming Pools. All of these public facilities are being addressed throughout the processing of the project through the City of Irvine. For example, the Irvine Police Department and the Orange County Fire Authority (OCFA) are responsible for reviewing the Project plans for compliance with their regulations. Additionally, the Project proposes to address the recreation needs of future residents and applicable parks requirements through the payment of in-lieu fees. Also, the project site is an infill development in an area that is built out and on a site that is already served by public services and utilities Michael Brandman Associates

15 City of Irvine - William Lyon Homes: Vista Verde Land Use and Planning Integrated Waste Management Element The Goal of the Integrated Waste Management Element states: Encourage solid waste reduction and provide for the efficient recycling and disposal of refuse and solid waste material, without deteriorating the environment. The Project will include both trash and recycling collections, consistent with City of Irvine code requirements and therefore the Project will be in conformance with the Integrated Waste Management Element. Energy Element The stated Goal of the Energy Element is, Promote energy conservation and the use of renewable energy sources throughout the City in a cost effective way. The Project will be designed in compliance with Title 24 of the State Building Code. This Title requires certain features be incorporated into the design of a project in order to reduce energy consumption. With Title 24 compliance, the Project will meet the goal by conserving energy. The Project will be constructed in conformance with the 2010 California Building code including its provisions for Green Building Standards and Title 24. Safety Element The stated goal of the Safety Element is, Minimize the danger to life and property from man made and natural hazards, including fire hazards, flood hazards, non-seismic geologic hazards, and air hazards. This goal is reached through implementation of the Project. The Project will be constructed consistent with all applicable building and zoning code statutes. Being that the Project is located in a built suburban environment, there are no areas of high fire hazard within close proximity. Any potential flood hazard will be mitigated through compliance with the City s established grading regulations. Parks and Recreation Element The stated goal of the Parks and Recreation Element is: Provide park and recreation opportunities at a level that maximizes available funds and enables residents of all ages to utilize their leisure time in a rewarding, relaxing and creative manner. This goal will be satisfied through the Project s Park Plan, which proposes payment of park in-lieu fees to fulfill the community park requirement while annexation is being pursued. Payment of Park In-Lieu fees will be consistent with the most recent City Council adopted fee resolution. Conservation/Open Space Element The goal of the Conservation and Open Space Element reads, Maintain and preserve the environmental systems as a major feature in the City. The Project will not impede attainment of this goal. The Project site is located within northerly portion of the San Joaquin Hills landform zone as described in the Element (Figure L-1), with no connectivity or adjacency to any areas of permanent natural open space. Michael Brandman Associates

16 Land Use and Planning City of Irvine - William Lyon Homes: Vista Verde Growth Management Element The Goal of the Growth Management Element reads, To ensure that growth and development are integrally planned with, and phased concurrently with, the City of Irvine s ability to provide an adequate circulation system and public facilities. The goal of this Element is satisfied and addressed through project implementation. Consistent with Circulation Element goals, a traffic study has been prepared in order to determine the overall traffic impacts of the project. The traffic study indicates that an adequate circulation system exists to accommodate the growth represented by this new infill residential development, and no significant and unavoidable traffic impacts would occur. Additionally, Objective M-6 of the Element looks to promote balanced growth of residential and nonresidential land uses and supporting public facilities and services. The Project supports this Objective by providing a residential land use near Irvine job centers (i.e. IBC, Spectrum, etc.), thus potentially reducing the travel time and commute costs for the future residents who might otherwise be forced to live farther from their place of work. Zoning Ordinance Consistency The City Zoning Ordinance designates the project site as 6.1 Institutional. This designation allows for a variety of uses, including schools, parks, churches, hospitals, residential care facilities, government and community facilities, and conference centers. However, a Zone Change would be required for the development of 66 residential units at the site. This will be accomplished through the Zone Change application that is part of the Project. Consistency with Regional Comprehensive Plan and Guide Policies As noted in Section above, the Vista Verde residential project is not a project of region-wide significance per SCAG Intergovernmental Review (IGR) criteria and CEQA Guidelines (Section 15206), and therefore does not require this EIR to address project consistency with the RCPG. Note that the Regional Comprehensive Plan and Guide is an advisory document only and the City of Irvine is not required to be consistent with it. Level of Significance Before Mitigation The following impact is considered less than significant because the Project includes a General Plan Amendment and Zone Change. Impact LUP-1 The project is not consistent with the existing General Plan and Zoning designations for the site. Mitigation Measures No mitigation measures are required. Level of Significance After Mitigation Less Than Significant Michael Brandman Associates

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