OPINION: FivePoint TOD Proposal Draws Scrutiny from Irvine Locals and Advocates

• October 16, 2024, 7:38 pm America/Los_Angeles

This Thursday, October 17th at 5:30 PM, the Planning Commission will consider the development of Developmental District 6 — which is zoned for Transit-Oriented Development as envisioned by the Current General Plan. FivePoint Communities is the developer. A group of residents, comprising housing and transportation advocates, sent a letter to the Planning Commission detailing their concerns over inappropriate land uses given its proximity to the train station, including insufficient density, lack of mixed-use zoning, as well as poor traffic calming measures that are needed for walkable development. The letter asks them to not approve the project until these issues have been addressed. 

Linked is the agenda for the meeting.

Read below:

Hello,

We’re a group of Irvine residents with serious concerns regarding the new development proposal in Planning Area 51/Development District 6 of the Great Park (agenda item #1 for the upcoming October 17th meeting of the Planning Commission).

This location offers a historic opportunity to create Irvine’s first walkable, transit-oriented development due to the proximity of Irvine Station and future Great Park amenities. However, the proposed project fails to take advantage of this once-in-a-generation opportunity. The proposed plans will encourage more traffic, discourage walking and biking, and fail to take advantage of nearby transit. Despite claims that this project is transit-oriented development and incorporates mixed use, neither of those things are true. In fact, we have identified a number of inconsistencies with the General Plan, which we list at the very bottom of this letter, and we also believe the project fails to meet the requirements set by Section 9-51-6(Q)(vi) of the Zoning Ordinance (the staff report refers to item (vii), but this looks to be a typo). We reproduce Section 9-51-6(Q)(vi) in full below (emphasis ours):

Development District 6: Mixed-use urban core serving as a regional destination, with nonresidential uses such as, without limitation, mid- to high-rise office, corporate headquarters, research and development, medical, and cultural/institutional/entertainment facilities of regional interest. This district is characterized by a high floor area ratio and a walkable character. Residential neighborhoods will feature high-density, multi-story residential units (average densities of 20 du/ac or greater within the area south of future Marine Way), which may include affordable housing units. Vertical mixed uses within buildings are allowed (i.e., ground floor office or retail with residential above). The development pattern is focused on increasing density with approaching proximity to the Irvine Station. The focus is to create a thriving, walkable, mixed-use community with a diverse mix of land uses, architecture, landmarks and outdoor gathering places to create a walkable urban environment that encourages on-street pedestrian activity and reduces dependence on the automobile for everyday needs. To accomplish the desired vision, this district will contain a minimum of 1,200 dwelling units and a minimum of 150,000 square feet of nonresidential development with a goal of a minimum jobs-to-housing ratio of 2:1 within one-half mile of the Irvine Station.

Mixed-Use in Name Only

The zoning code talks about mixed-use, but the proposed plan contains no mixed use at all – only a single community commercial development off to the side in a small portion of the site (see the highlighted red part of the attached map). And instead of putting that community commercial space near residences, it’s being placed next to an empty park, forcing pedestrians to walk further to run errands. There’s also no office space, so workers who commute to Irvine won’t be able to take advantage of the train and walk to their jobs – they’ll instead need to continue to clog our highways and surface streets with cars.

There is essentially nothing in this project that reduces vehicle miles traveled. There is no attempt to produce a walkable neighborhood, which is one of the only ways we’re going to be able to keep traffic under control as our population grows. We don’t see any plans for off-street bike lanes other than Marine Way, which means bikers and pedestrians will be forced to share sidewalks, which will make both bikers and pedestrians more likely to just get in their cars instead. The staff report calls these sidewalks “Class 1 trails” but the reality is they’re just plain sidewalks that will exacerbate issues related to bikes/ebikes sharing the same road space with pedestrians, creating uncomfortable and inefficient conflicts.

Development District 6 was always intended to be the pilot for Transit-Oriented Development, and is woefully inadequate relative to the characteristic that was originally promised and relative to the General Plan and zoning code description of the TTOD. Please ask staff to read the description of District 6.

More Ambitious Traffic Calming Measures are Needed

The proposed streets are dangerous and poorly designed. Specifically, they’re much too wide, with no bulb-outs and huge corner radii. This will create a vicious cycle because poorly designed roads make pedestrians feel unsafe, causing more people to get in their cars for short trips, creating more traffic and making pedestrians feel even more unsafe, causing more people to use their cars, and so on. We see the need for increased traffic calming measures, such as lane narrowing, bulb-outs, and adequate Class IV protected bike lanes that meet Level of Traffic Stress (1 or 2) as opposed to just building wide sidewalks.

We should aim to make roads as narrow as possible, as is outlined in the municipal code regarding this development site. Regarding street width, walking from most of the proposed residences to the proposed community commercial space would require crossing very wide, busy roads. In particular, residents would need to cross Marine Way, which is 4 lanes and about 100 feet wide, or else “B” Street, which has multiple lanes and is 64 feet wide. In fact, almost all of the streets in the plans are much wider than they need to be, which makes crossing those streets more dangerous. Some of the private ways are as wide as 26 feet, or even 36 feet. That means it takes longer as a pedestrian to cross, which means more time in potential conflict with cars. People also tend to drive faster on wider roads, which makes accidents more deadly. Even if the road is signed for 25mph, people are going to drive faster than that when the road is wider than multiple highway lanes put together – after all, the road “feels” like it should be faster. 

Regarding bulb-outs and corner radii: the lack of bulb-outs will make it harder for drivers to see waiting pedestrians and for pedestrians to see oncoming cars. And the corner radii of even the smaller residential streets are too big (17 feet or higher), meaning cars can make turns without slowing down (also, the large road widths mean that the effective corner radii are actually much larger than 17 feet). All of this makes collisions with pedestrians more likely, and more likely to be deadly due to high speeds.

Insufficient Density Relative to Existing High-Capacity Transit

Another fundamental problem is that the density of the project is far too low. This is 166 acres of undeveloped land a short walk from the Metrolink station with the 3rd highest ridership in the county, also served by Amtrak, Irvine Connect, and OCTA buses. For comparison, the mixed-use project OC Vibe adjacent to Anaheim Station (ARTIC) and Honda Center is approximately 200 more units despite being on 60 fewer acres of land. And in other parts of the County there are mixed-use projects of higher density despite not enjoying the benefits of a nearby train station! It is irresponsible for Irvine to allow this valuable space adjacent to Irvine Station to be used for low density detached single-family homes and no mixed use.

What makes the proposed project’s failings even more egregious is that Metrolink is dramatically increasing the frequency of their trains to every hour on weekdays starting this coming Monday, October 21st, with plans for further increases in the next few years (the planned OC Maintenance Facility project at the Great Park is a cornerstone of these planned increases as part of Metrolink’s SCORE program). Also, Irvine Connect, which already serves Irvine Station, is likely to expand given the rapid increase in ridership it’s seen since starting service earlier this year, which will mean even more transit destinations available to residents of this area. It is imperative that the development plans be improved to include more residences so that as our population increases more people can live in Irvine without needing their cars to get everywhere. And the development should contain a mix of retail and offices so that workers can commute to their jobs without cars.

The land is zoned for up to 50 units per acre, but the proposed plan is for a paltry 12.4 units per net acre. Additionally, net acres is a misleading measurement for this project: since this is a large development containing multiple very wide roads, the more revealing metric is gross acres. By that measure, the overall density of this project is only 8 units per acre! This project could easily be denser by building higher and by creating more reasonably sized narrower residential streets. The area closest to Irvine Station could easily be 5-over-1s with business on the first floor. 

For comparison, below is one MPO’s suggested guidelines for minimum densities along certain transit facilities. Notice commuter rail (Metrolink/Amtrak) has a recommended minimum density of 20 units per acre for suburban development, with 40-75 being the ideal target. Only a small portion of the proposed project meets this suggested minimum (and barely, at that).

Source

The project also fails to take advantage of new opportunities created by state law AB 2097, which took effect in January 2023. This law eliminated parking requirements within 0.5 miles of a major transit stop, which Irvine Station qualifies as. A large portion of the proposed project is within this half-mile radius (see the yellow dashed circle in the attached map), but the project plans still explicitly cite parking minimums that no longer exist. The design of the commercial property and the residences near Irvine Station are all explicitly described as beholden to these parking minimums, which means a huge amount of valuable transit-adjacent land is being wasted on parking. For example, just eyeballing the community commercial plans, it appears that more of that land is devoted to parking than to the actual commercial buildings. The Great Park is often derided as the “Great Parking Lot”, and this kind of development only reinforces that criticism, and it’s going to make traffic much worse than it already is.

In the words of the Zoning Ordinance, this neighborhood should be “a thriving, walkable, mixed-use community with a diverse mix of land uses, architecture, landmarks and outdoor gathering places to create a walkable urban environment that encourages on-street pedestrian activity and reduces dependence on the automobile for everyday needs”. However, the proposed project does none of this. It seems like a copy and paste of the existing Great Park neighborhoods and fails to correct mistakes made with the previous developments (e.g., lack of mixed-use) while also failing to treat this location as special and unique due to its proximity to Irvine Station. This location should be a vibrant neighborhood with homes, ground-level retail, offices, and cafes. It should be a place where people can run errands or commute without getting in a car.  As Irvine’s population grows, the only way to keep traffic under control and to meet our housing and sustainability goals is to give people viable options besides using their cars, and the only way to do that is to house most of those people in more walkable, bikeable neighborhoods with mixed-use and access to transit.

This development proposal is a shortsighted mistake at the expense of our community, and it’s counter to the very long tradition of master planning that this city is known for. Short-term profit and a desire to sell off the asset quickly cannot come at the expense of this is a once-in-a-generation opportunity to create a real walkable, mixed-use neighborhood of the kind that is lacking in Irvine. And in order to meet our state-mandated housing requirements without hugely increasing car traffic, we need to build mixed-use and transit-oriented development near the train station – and we only have one train station! This is the only undeveloped site adjacent to a train station in Irvine, and it’s paramount that we do the right thing here.

We request that the Planning Commission ask staff to delay the approval of this project and direct staff to work with the developer on the following:

• Increasing density near Irvine Train Station in order to take full advantage of abundant nearby transit (Metrolink/Amtrak/Irvine Connect/OCTA bus routes), following the example of other recent Orange County development projects near mass transit (e.g., OC Vibe), and following best practices for density near mass transit.
• Implementing mixed-use. The proposed project does not integrate commercial uses with residential uses, which is critical to facilitating a walkable environment and reducing traffic.
• Addressing gaps in active transportation infrastructure with measures like bulb-outs, protected bike lanes, corner radii, and reduced road widths that make roads safer for pedestrians and cyclists.

We need a project that actually fulfills the potential of this location, is consistent with the General Plan, and meets the requirements set out in section 9-51-6(Q)(vi) of the zoning ordinance.

General Plan Inconsistencies

Land Use Element

• Objective A-7:

• • “Policy (a): Conduct a comprehensive concept planning process for each planning area to prevent piecemeal and inefficient community development and to resolve area-wide planning issues prior to development approval.”
    • This is inconsistent because:
    • By proposing lower-density housing, poor walkability, and no mixed use near Irvine Station, the project fails to use this land efficiently. It also demonstrates a piecemeal approach. For example, there is no easy way to bike from the north end of the development to Irvine Station without dangerously sharing space with cars on busy roads. For a project next to a train station to not account for this kind of mode splitting shows a lack of area-wide planning.

Circulation Element

• Objective B-2: Roadway Design
  • “Policy (d): Ensure that existing roadways are designed to complement other circulation networks without the need for major reconstruction.”
    • This is inconsistent because:
    • The lack of traffic calming measures will prove detrimental to pedestrian and bicyclist safety, and will make walking and biking unenjoyable. Examples include – but are not limited to – overly wide roads, multilane roads, very large effective corner radii, lack of bulb-outs. This lack of safety will result in few people using active modes of transportation, and future retrofitting and reconstruction will be very expensive and difficult to implement retroactively.

• Objective B-3: Pedestrian Circulation

• • “Policy (b): Require development to provide safe, convenient, and direct pedestrian access to surrounding land uses and transit stops. Issues such as anticipated interaction between pedestrians and vehicles, proposed infrastructure improvements and design standards shall be considered.”
    • This is inconsistent because:
    • There are no clear bikeways or pedestrian pathways directly to Irvine Station, and the indirect routes are long or share space with cars. It’s unclear what role an Ada undercrossing might play. There is no evidence that the anticipated interaction between pedestrians and vehicles, proposed infrastructure improvements, and design standards were adequately considered.

• • “Policy (c): Design and locate land uses to encourage access to them by nonautomotive means.”

• • • This is inconsistent because:
    • There is no obvious and encouraging way to access adjacent areas by bicycle, and there’s no obvious way to access Irvine Station for bicyclists or pedestrians. Given the development’s proximity to the Irvine Train Station, the lack of mixed-use commercial and the location of the isolated commercial development suggests poor planning for access via non-automotive means.

• Objective B-4: Bicycle Circulation

• • “Policy (c): The trail system shall be designed to accommodate cyclists of all levels of experience and shall provide for both recreation and transportation.”

• • • This is inconsistent because:
    • The lack of adequate low Level of Traffic Stress and all-ages-and-abilities Class IV bike infrastructure, and continuing to mix pedestrians and cyclists on sidewalks suggests poor integration of utilitarian cycling planning throughout the project. The sidewalks are labeled as “Class 1 trails” solely because they are of a certain width. They still do not address the aforementioned issues.
• Objective B-6: Public Transit Program

• • “Policy (a): Plan residential, commercial, and industrial areas to enable effective use of public transit.”

• • • This is inconsistent because:
    • Particularly given (a) the proximity to Irvine Train Station, (b) the insufficient density relative to what is permitted, (c) the insufficient integration of mixed-use development that is designed to reduce VMT and encourage walkability and bikeability, (d) the lack of adequate and ambitious traffic calming measures, and (e) the lack of seamless and adequate all-ages-and-abilities bicycle infrastructure, this project seriously squanders the potential of public transit. There is no part of the City more relevant to this particular General Plan policy than this land adjacent to Irvine Station, and the proposed project totally fails to enable effective use of public transit.

Thank you for your consideration,

Sahand Cyrusian, District 1 resident
Doug Elliot, District 3 resident
Nathan Guerrero, District 4 resident
James Hwang, District 5 resident
Youssef Kaddeche, District 1 resident
Nerissa MacLeod, District 4 resident
Joshua Moore, District 5 resident
Yui Sato, District 1 resident
Katie Vu, District 2 resident
Sylvia Walker, Member of Irvine Housing Champions & District 2 resident

DISCLAIMER: The author of this article, who is a Board Member for Irvine Watchdog,  is a signatory to the letter. Two other Irvine Watchdog Board Members are also signatories. The views expressed within the letter do not necessarily reflect those of Irvine Watchdog as an organization, its Board, or any other writers or volunteers affiliated with Irvine Watchdog.