By Eric Engelbert
OC's Largest Apartment Owner Is Building 1,336 More Units. They Chose Tustin Legacy.
The Irvine Company already owns and operates more apartments in Orange County than any other landlord. They have been building and managing apartment communities across Southern California for decades, with a portfolio that spans from Newport Beach to the inland valleys. When a company with that track record decides to commit $52 million and years of construction to a new site, the choice of location says something. They chose Tustin Legacy, the 1,600-acre planned community built on the former Marine Corps Air Station in central Orange County. The Tustin City Council unanimously approved the project on February 4, 2025. Construction started in early 2026. When it is finished in 2029, Neighborhood D South will have 1,336 new apartments, 334 of them affordable, across six buildings on 19.4 acres. See all new development projects across Orange County.
Tustin Legacy: A Former Air Base Still Being Built Out After 25 Years
To understand why a project like this matters, it helps to understand what Tustin Legacy is and how long it has been in development. The Marine Corps Air Station Tustin operated from 1942 until 1999, when the federal government decommissioned it and transferred the land to the city of Tustin and other agencies. The base covered roughly 1,600 acres in the geographic center of Orange County, bordered by major arterials and adjacent to some of the county's most established residential neighborhoods.
The Tustin Legacy Specific Plan was adopted in 2003, giving the city a framework for converting the former military land into a mixed-use community. The full buildout envisions 4,258 residential units, 1.6 million square feet of commercial space, and more than 90 acres of parks. What makes Tustin Legacy unusual even by California standards is the sheer scale of the planning and the duration of the buildout. More than two decades after the specific plan was adopted, significant portions of the former base are still raw land transitioning between uses.
Neighborhood D South, where the Irvine Company project is located, sits within that transitional zone. The 19.4-acre site is bounded by Warner Avenue, Legacy Road, Tustin Ranch Road, and Compass Avenue, positioning it at the intersection of Legacy's street grid with the broader Tustin circulation network. The city's Development Agreement, Vesting Tentative Tract Map 19353, and Design Review were all bundled into a single approval package, along with a Density Bonus request that enabled the scale of the affordable component.
The Deal: $52 Million and Why the City Agreed
The Irvine Company did not simply buy this land on the open market. The city of Tustin owns significant portions of the former air base and controls their disposition. The transaction required a Disposition and Development Agreement between the city and Tustin Legacy Acquisition LLC, the Irvine Company subsidiary formed for this project.
The financial terms: the Irvine Company agreed to pay $42.1 million for the 19.4-acre development site itself, or approximately $2.7 million per acre. In addition, the company committed nearly $9.6 million toward Tustin Legacy's infrastructure, bringing the total commitment to just under $52 million. A $5 million deposit was paid at the close of escrow. CBRE, brokering for the city, received a 1% commission on the land transaction.
From the city's perspective, the deal accomplishes multiple things at once. It generates $52 million in proceeds and infrastructure investment from a single transaction. It delivers 334 income-restricted apartments, which count directly against Tustin's 6,782-unit RHNA obligation for the 2021 to 2029 cycle. And it brings one of the most experienced apartment operators in Southern California to a site that the city has been trying to activate for over two decades. As Tustin city staff put it in their report to the council, the project will "contribute substantially towards meeting the housing goals identified within the City's Housing Element and Regional Housing Needs Allocation requirements" while providing "housing opportunities for the city and region across a wide variety of income levels."
The Irvine Company: OC's Largest Apartment Owner, Now at Tustin Legacy
The Irvine Company is one of the largest private real estate companies in the United States, with a portfolio that spans office, retail, resort, and residential assets across Southern California and beyond. Their apartment division is particularly dominant in Orange County, where they manage tens of thousands of rental units across a network of planned communities and infill sites. In a county where the rental market is notoriously tight, the Irvine Company's scale gives them an unusual ability to absorb construction risk and execute long-duration projects that smaller developers cannot.
Their approach to apartment development is distinctive. Irvine Company communities typically emphasize walkability, community amenities, and professional property management at scale. The narrow street design specified in the Tustin Legacy project, intended to promote pedestrian activity and limit vehicle speeds within the community, is characteristic of how they design their apartment neighborhoods. They are not building a standard apartment complex. They are building a planned neighborhood with its own internal circulation logic.
The choice to expand into Tustin Legacy makes geographic sense. The site sits at the center of the county, accessible to employment in Irvine, Santa Ana, Anaheim, and the broader employment corridor along the 5 and 55 freeways. For a company that manages apartments at the scale the Irvine Company does, a 1,336-unit project at Tustin Legacy is a natural extension of what they already do in Irvine, Newport Beach, and across the county.
What Gets Built: Six Buildings, Three Blocks, and a Public Park
The project is organized across three blocks, with six apartment buildings ranging from four to five stories each. The buildings are structured around integrated parking garages rather than surface lots, a design approach that allows the ground-level environment to be more pedestrian-friendly. Total parking comes in at 1,956 spaces, which is 368 more than required under California state law.
The unit mix covers a broad range of household sizes:
A 0.66-acre park sits within the project boundary and is designated as a privately owned publicly accessible space, meaning it is open to the public and not exclusively for residents. That public accessibility is one of the community benefits negotiated through the Development Agreement. The project design also emphasizes narrow internal streets to slow traffic and prioritize pedestrian movement within the community, consistent with how walkable urban apartment neighborhoods are typically planned.
The 334 Affordable Units: Who Qualifies and What It Means
One in four apartments at this project, 334 units, will be set aside for lower-income households. That 25 percent affordability ratio is above what standard density bonus law typically requires and reflects what was negotiated in the Development Agreement as a public benefit in exchange for the density bonus approval.
In California, "lower income" is defined as households earning at or below 80 percent of area median income. In Orange County, that covers a significant portion of working residents: nurses, teachers, tradespeople, county employees, and others whose incomes do not stretch to market-rate rents in a metro where a one-bedroom can easily run $2,500 to $3,500 per month. Income-restricted apartments at Tustin Legacy will be priced based on a formula tied to the income threshold, keeping rents affordable over the long term regardless of where the market moves.
The 334 units also matter for the city's RHNA compliance. Tustin needs 6,782 new units by 2029, with the majority required at moderate and low income levels. A single project delivering 334 lower-income units represents a meaningful contribution toward that obligation, particularly at a time when California is actively monitoring cities' progress and suing those that fall short.
Construction Timeline: What Is Happening and When
Construction started in early 2026 with the first of six parking garages. That sequencing is typical for structured-parking apartment projects: the garages are built first because they establish the footprint and structural framework for the residential buildings that sit above or adjacent to them. Grading and site preparation preceded the garage work.
The multi-year construction window is standard for a project of this size. Phasing the delivery across multiple buildings allows leasing to begin in completed phases while construction continues on others, which is how the Irvine Company manages large apartment communities throughout their portfolio. Expect pre-leasing announcements and a community website to launch well before the first buildings are ready for occupancy. You can track this project and others across Orange County on the OC New Developments page.
Looking to Rent or Buy Near Tustin Legacy?
The Irvine Company's 1,336-unit project is the largest single residential approval at Tustin Legacy to date, and it is one of several major developments reshaping this part of Orange County. Whether you are looking to rent, buy, or simply understand what is happening in the Tustin market, we can help you navigate it.
