CITY OF ALHAMBRA ALHAMBRA CITY PLANNING ...€¦ · Web viewA soil management plan (draft for approval) is not provided for review and therefore no finding can be made or reviewed

DATE: January 15, 2017 TO: Ms. Tonya Pace, Dpty. Dtr. Alhambra, Develpmt. Serv. Dept.

111 S. First St. Alhambra, California 90801 626-570-5034 [email protected] City Of Alhambra Alhambra City Planning Commission, Item #6 011717 Agenda

Tentative Tract Map (Ttm 74223) Industrial Planned Development Permit IP-16-4

FROM: Dr. Tom Williams, Director, Northern District, LA-32 Neighborhood CouncilSenior Technical Adviser Citizen Coalition for A Safe CommunityMember, Sierra Club Angeles Chptr - Transportation & Central Group Reorganizing Comtes.El Sereno Representative, No 710 Coalition

SUBJECT: Alhambra Court Commercial DevelopmentNotice of Intent, Initial Study, Mitigated Negative Declaration, and Mitigation Monitoring, and Reporting PlanTentative Tract Map (Ttm 74223) and Industrial Planned Development Permit IP-16-4875 & 1111 South Fremont Avenue Alhambra, California 91803

RE: Request and Comments

REQUEST: Please continue Item 6, Resolution 17-4, Section 2 A-F CEQA Findings for 30 days following 01/12/17 As this item is referenced in the CEQA documents and requires the adoption...Mitigation Monitoring and Reporting Program (MMRP) which has not received an adequate period of review and comment.

SOME GENERAL COMMENTS:Consultants and City Staff have demonstrated that they may not be competent to prepare CEQA documents for public circulation, review, and comments. Use of MND rather than EIR appears to purposefully avoid public scrutiny, comment and consideration of alternatives. The NOI specifically include the MMRP but circulation did not include the MMRP til 011217, 5 days before this hearing.

The MND refers to El Sereno as an unincorporated part of LA County but has been part of LA City for almost 100 years. The City of Alhambra and others are fully aware of its location as they relocated the original SR-710 from Alhambra City to just inside the City of LA 30+ year ago.

As indicated by these and many comments, the preparers of the CEQA documents and City reviewers and approvers for circulation do not appear to have the technical training, experience, and qualifications to undertake the CEQA related activities for this MND and project or the inadequacies and incompleteness were purposeful.

The Project has been Piece-Mealed, separated in to smaller related project components, in order to avoid public review. Demolition, hazardous materials studies, remediation, grading/filling, and now proposed construction have been separately considered and exempted from CEQA process.

MND avoids a "Worst-Case" environmental approach (Best Case Economic Alternative) of doubling structured parking and adding an additional office building, adding two buildings to the Project Site in the open parking.

MND Project has been induced by Project area developments and will contribute to Growth Inducement for The Alhambra, LACounty site, other less-developed properties between Fremont and Meridian, and west of Meridian to Concorde. The proposed project includes the first greater than 3 storied office buildings west of Atlantic Blvd. and provides a model for future developments in the numerous commercial facilities with very large ground level parking spaces.

mailto:[email protected]

NOI states Mitigation Monitoring and Reporting Plan was to be distributed in early December 2016 but was not. Requests for the MMRP were made and city staff responded that it was to be finished and distributed on 011217 which it was but >30 days after it was announced to be circulated.

The entire document NOI, IS, and MND and related studies and reports appear to be inadequate and incomplete and require major revisions and upgrades to a full and comprehensive EIR, including draft MMRP and a thorough development of alternatives. The EIR should be a Programmatic EIR for a Fremont Corridor Specific Plan with this project as a sample Project EIR within the programmatic setting and framework. Throughout the comments a basic comment will be "Withdraw, revise, and recirculate as part of a more comprehensive EIR with adequate publicly accessible documents and references and analyses..." and ".... must provide a Programmatic EIR and include a Project EIR for the proposed project in this CEQA process."

My residences in El Sereno has clear view of the Project site, The Alhambra, and LACo Building and the assessment of Visual-Aesthetics from Hempden Terrace and Barrett Road (90032-1712) and others is totally inadequate and incomplete, especially for nighttime appearances with the LACo office block being the least illuminated and the most blended into/reflective of the changing lighting environment of the Alhambra-Fremont corridor.

Important Initial Comments

MMRP MITIGATION MONITORING AND REPORTING PROGRAM (circulated 011217)1-13/Headers and Footers "...MITIGATION MONITORING AND REPORTING PROGRAM ALHAMBRA COURT"But the MND contains ONLY two other mentions of "reporting" in 13 pages:

3/3 ● A mitigation reporting OR monitoring program will be required; [Emphasis added]7/5 5. MITIGATION MONITORING The monitoring and reporting on the implementation of these measures, including the period for implementation, monitoring agency, and the monitoring action,...Table 1...CEQA (http://resources.ca.gov/ceqa/flowchart/la_mmrp.html) requires monitoring and reporting be designed to ensure compliance with mitigation measures during project implementation.

...Public Resources Code 21081.6, findings: paragraph (1) of subdiv. (a) of Sec. 21081“...shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects...” and “...ensure compliance during project implementation.”

The central issues and intent of an MMRP involve:Mitigation measures change, reduce, minimize, or avoid significant impacts to a level of

insignificance;Measures and the criterion of significance must be measureable;Monitoring must focus on measuring adequacy of measures to achieve levels of "insignificance";If monitoring shows that measures are not achieving/have not achieved levels below the levels of

significance then the measures must be increased/augmented/prolonged until such time that monitoring indicates that impacts have achieved level below the criteria of significance;

Reporting of measures, monitoring, and changes throughout the period prior to achievement of the Significance Criteria is required for the Public and various agencies involved and at the end of project implementation to demonstrate full achievement of less than significant impact levels as stated in approved CEQA documents issued by/supportive of the relevant agencies.

The current Project MMRP does not adequately or completely fulfill the requirement for a MMRP. and must incorporate the following:

Compile all mitigation status forms into a report of measures-benchmarks and compliance on an initial and quarterly basis and as a summary report.

Convey status and recommendations to the relevant agencies and public. Recommendations: updating frequency/duration of monitoring; changing the type of monitoring

and improvements of mitigation implementation; Assisting agencies in reviewing the contractor’s implementation of mitigation requirements, detailing corrective actions and

schedules of completion to resolve issues; assessing mitigation if unsatisfactorily addressed or achieved; documenting all monitoring and measures in on-line/real-time reporting format; and submitting all status, updated and completed reports and statements to the relevant agencies and the Public.

Withdraw, revise, and recirculate the MMRP as part of a more comprehensive EIR with adequate publicly accessible documents and references and analyses for monitoring and reporting of all mitigation throughout the project life and for assuring the mitigation achieves the required level of reduction so as to achieve the "Less than Significant Impact Criterion". The GPU CEQA process may provide a basis for a Programmatic EIR and must include a Project EIR for the proposed project in this CEQA process.

MORE SPECIFIC COMMENTS:Relevant text from the reviewed documents are included at the start of the comments and important phrases are indicated in bolded and underlined phrases/wordWhere relevant the citation of page/paragraph are given for each statement in the CEQA texts.Comment are shown in bolded italics

2016 MND is inadequate and incomplete in its traffic impact analyses and assessment of traffic and transportation impacts, potential growth inducements and the recommended mitigation to reduce them below a level of significance. Due to the complexity and existing adverse conditions, the CEQA compliance must include an Environmental Impact Report (EIR), not a mitigated negative declaration MND).

MND/TIA Traffic analysis used the trip generation rates from ITE Trip Generation Manual, 8th Edition without consideration of later versions in order to calculate the rates for the Lowes store for AM Peak Hour, PM Peak Hour, and Weekend Peak Hour. This represents a clear inadequacy of the assumed approach for assessment.

Provide trip generation value for Lowes calculated using the ITE 9th Edition code 862 rates and compare.

Provide trip generation value for Lowes calculated using both ITE 8th and 9th Editions for the appropriate code rates and compare with those surveyed at Poway.

Kimley/Horn (K/H) requested and received approval from the City of Alhambra prior to using the Lowes/Poway trip generation rates instead of the ITE 9th Edition rates for the Lowes store in the traffic analysis. Please provide documentation as to City's approval regarding the format and contents of the Traffic Impact Analyses and all derived traffic assessment program and moel.

Please provide links and examples of other traffic impact analyses (say, within the last 10 years) either prepared by Kimley/Horn or known to Kimley/Horn in which the trip generation rates associated with a Home Improvement Store land use did not use the ITE Manual (appropriate edition at the time of the analysis) trip generation rates or another state-approved trip generation rate in order to determine the trips associated with the new Home Improvement Store.

The trip distribution assignments shown on Figures 5, 6, and 7 are shown without reference to methods used to determined. The analysis states that the distribution assumptions were "submitted to and approved by the City of Alhambra staff" (see p. 18). Please provide details of this correspondence between Kimley/Horn and City of Alhambra.

The traffic analyses by Kimley/Horn have not included or addressed accidents and other safety metrics at the potentially affected intersections and streets within the area of study in its traffic analyses and it's absence is example of both inadequacy and incompleteness A revised traffic assessment is required.

MND 4/2 The proposed project will require the following approvals: a Tentative Tract Map (TTM 74223)...; Design Review for the new buildings; an...(IP-16-4) to ensure...conformity with City standards; a Uniform Sign Program for the new on-site signs;

the adoption...Mitigated Negative Declaration; and the adoption...Mitigation Monitoring and Reporting Program (MMRP).

The MMRP was delayed and only provided to the public for review on 011217 and was presented for review as was done for other MND, pdf-page-88/Exhibit B Wondries Toyota Project - Initial Study/Mitigated Negative Declaration, 5. Mitigation Monitoring [sic, Reporting must be added]-Program.

ObjectivesMND 4/3 ...findings may be made based on the analysis...in the attached Initial Study:

● The construction and subsequent operation of the proposed project will not have the potential to degrade the quality of the environment.

● ...will not have the potential to achieve short-term goals to the disadvantage of long-term environmental goals.

● ...will not have impacts that are individually limited, but cumulatively considerable, when considering planned or proposed development.

● ...will not have environmental effects that will adversely affect humans, either directly or indirectly.Changes in conditionality of verbs are important and become confusing as to what has been the basis

for their generation from the Initial Study. May be made, will not...potential, and ...x2-will not have impacts or effects

No comparisons are made for differences between potential and non-potential impacts and effects-directly and indirectly.

No definitions or comparisons of potential, short-term goals, or long-term goals.Withdraw, revise, and recirculate the MND as part of a more comprehensive EIR with adequate

publicly accessible documents and references and analyses for the project and the EIR must contain fully quantifiable, comparable, and equally applicable objectives and criteria.

Initial Study 8/1 Although this Initial Study was prepared with consultant support, the analysis, conclusions, and findings made...fully represent the independent judgment and position of the City...,...as the Lead Agency. The City determined...that a Mitigated Negative Declaration is the appropriate environmental document...This Initial Study and the Notice of Intent to Adopt a Mitigated Negative Declaration will be forwarded to...the public for review and comment. A 30-day public review period will...allow...other interested parties to comment on the proposed project and the findings of this Initial Study. CEQA requires the Initial Study and Checklist and a recommendation to be issued separately for

comments from the Public, before circulating the CEQA documents. Combining the circulation of the IS, checklist and the MND reduces the public awareness and review of the project and inputs to the CEQA process.

Circulation of the current CEQA documents/MND-MMRP is without a SCH#, e.g., Wondries Toyota Project SCH# 2016071051 / MND 08/16/2016, and suggests that the CEQA documents may not have been submitted to the State Clearinghouse which would violate .

IS-MND/171 5.1 PREPARERS BLODGETT BAYLOSIS ENVIRONMENTAL PLANNINGAuthors of "Initial Study and Mitigated Negative Declaration - City of Alhambra" www.cityofalhambra.org/.../hellman_medical_office_building_mnd_december_2_2016...The fact that the available CEQA documents are identified with a previous project demonstrates that

the preparers and City reviewers have inadequate background and qualifications for preparation and issuance of CEQA documents.

Consultant Qualifications: Marc Blodgett, Projt.Mgr., BS, Geog.; MA, Urban & Reg'l. Plan., CalState Polytechnic University, Pomona. >500 environmental studies since 1987; >40 general plans.

Bryan Hamilton, Project Planner 3+ yr. BA History + minor in Urban & Regional StudiesLiesl Sullano, Project Planner 2yr BA, Social Ecology University of California, Irvine.Although the manager of the consultant appears to have experience with CEQA, the staff do not

appear to have the technical qualifications for preparation and review of the technical sectors assessments outside of land use planning. The many comments similarly show the inadequacy and incompleteness of qualifications for the consultant preparers and the City Staff approving/accepting Findings (their Qualifications have not been provided).

http://www.cityofalhambra.org/imagesfile/file/201612/hellman_medical_office_building_mnd_december_2_2016_20161201_152717.pdf

IS 9/1 Repeated in MND ...findings may be made based on the analysis...in the attached Initial Study:● The construction and subsequent operation [added] of the proposed project will not have the

potential to degrade the quality of the environment.● ...will not have the potential to achieve short-term goals to the disadvantage of long-term

environmental goals.● ...will not have impacts that are individually limited, but cumulatively considerable, when considering

planned or proposed development . [Deleted later in MND].● ...will not have environmental effects that will adversely affect humans,...directly or indirectly.

Words matter in regulatory documents and noted words are arbitrary, confusing, and ill-defined.

IS9/2 Section 5 References, identifies the sources used in the preparation of this Initial Study.Many references are included as footnotes but not included in list of references (5.2).Section 5.1 includes preparers under References, rather than as separate section of a CEQA

document.

9/3 The Appendix includes the modeling results of the traffic study, air quality analysis, and the noise measurements. [No specific reference; 1,2,3 v A-F, including traffic related to Apdx. F]

The determination of the environmental impact analysis of this Initial Study are summarized in Table 1-1...9-16 / Table 1-1 Summary (Initial Study Checklist) Sectors requiring mitigation for less than significance with mitigation.9/Row 3.1 d) Create a new source of substantial light or glare...adversely affect day or nighttime views...?10/3.3 d) Expose sensitive receptors to substantial pollutant concentrations?11/3.5...Cultural Resources Impacts. Would the project:11/3.5 a) Cause a substantial adverse change in the significance of a historical resource...? 11/3.5 b) Cause a substantial adverse change in...archaeological resource...?11/3.5 c) Directly or indirectly destroy a unique paleontological resource, site, or unique geologic feature?11/3.6 d) Location on expansive soil,..., creating substantial risks to life or property?12/3.8 a) Create a significant hazard...through the routine transport, use, or disposal of hazardous materials?12/3.9 b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge...?13/3-10 e) Create or contribute runoff water,...exceed the capacity of...storm water drainage systems...?13/3-11 Section 3.11 Mineral Resources Impacts....loss of availability of a known mineral resource...?13/3.12 a) Exposure of persons to...noise...in excess of standards...in...general plan...ordinance...standards...?14/3.12 d) Substantial...increases in ambient noise levels in the project vicinity above levels existing...? 14/3.14 a) Fire protection services? b) Police protection services?14/3.16 a) Cause a conflict with an applicable plan, ordinance, or policy...modes of transportation...?15/3.16 d) Substantially increase hazards...(e.g., sharp curves or...intersections) or incompatible uses...?15/3.17 d) Have sufficient water supplies available to serve the project...?16/3.18 d) Will not have environmental effects...adversely affect humans,...directly or indirectly...

Sector/elements with designations as "Less than Significant with Mitigation" and thereby require mitigation measures and measures within the MMRP, many are missing or are not reflected in this listing. All measures are inadequately or incompletely defined both in the MND and even in the MMRP.

18/Exh.2.1 Too generalized and does not identify the location or boundaries of El Sereno or LA City.RR are incorrectly shown in LA and vicinity and around the project site.

19/Exh.2.2 RR are incorrectly shown in and around the project site. Figure does not show LA and Alhambra City boundaries.

20/Exh.2.3 RR are incorrectly shown in and adjacent to the project site. Figure does not show LA and Alhambra City boundaries.

All exhibits require review and revisions to assure features are properly identified and located.

21/2 The majority of the site is covered over in dirt, rocks, and sparse ruderal vegetation. Miscellaneous pipes, valves, tanks, dumpsters, and a shipping container...Finally, an existing two-story office building is located adjacent to Fremont Avenue (875 Fremont Avenue). [NW of Orange/Fremont intersection]...concrete block wall extends along the site’s boundary with the Fremont Business Center.

...south side...is fenced off by both a chain link fence and a brick wall near the site’s boundary with the Shops at the Alhambra.41/2 The majority of the site...is covered over in dirt, rocks, and sparse ruderal vegetation.Miscellaneous pipes, valves, tanks, dumpsters, and other debris are scattered throughout the project site. Piles of concrete rubble occupy the northern portion of the site.This description does not mention stored contaminated soil under plastic covers.The status of 901 and 919 S. Fremont is not provided.22/Exh.2.4 Aerial Photo, undated, shows some of the stored dirt, rocks, and debris and coveed

contaminated soils/debris.

29/1 The project site was developed for industrial use as a foundry and...manufacturing in the 1920’s.... (IEC)… acquired the property in 1963 for aluminum manufacturing operations.\13 Other notable uses within the vicinity of the project site include Emery Park Elementary School, located 1,208 feet to the northwest [1185ft, Google Earth 011017];...No review of available 1923 and 1928 aerial photos has been undertaken, and other documents appear

to not have been definitive as to land ues.

29/1 A portion of the Fremont Business Center will be incorporated into the proposed project.15

Retail. A Lowe’s home improvement store..., three dock high loading doors will be provided for the Lowe’s.16 15 National Engineering & Consulting, Inc. Site Plan. Plan received September 26, 2016 16ibidFBC 901 S Fremont Ave # 268 Alhambra, CA 91803References (e.g., NE&C,Inc.) are not available to the Public and any unaccessible documents not

appropriate for CEQA referencing and use in assessments.

38/1 2.5 PROJECT OBJECTIVESThe City of Alhambra seeks to accomplish the following objectives with this review of the proposed project:● To minimize the environmental impacts associated with the proposed project;● To promote new infill development within underutilized properties;● To promote increased property valuation as a means to finance public services and improvements...,● To ensure...development is in conformance with the policies of the City of Alhambra General Plan. Inclusion of the City's "objectives" in the MND suggests or requires that the City has interests in part

of project. Provide a history/time line of all City interests, activities, and considerations in the project properties from 2000 or since the formation of the Alhambra Community Redevelopment Agency and/or Authority and the Industrial Redevelopment Agency/Authority.

Provide clear numerical definitions for "minimize", "promote", "infill", "underutilize", "increased property valuation", "finance", and specific "policies" of the General Plan which are used as project objectives.

Provide a thorough assessment of the financial/economic/investment sector for this project and potential CEQA sector relationships, e.g., public services, utilities/services, and past/current ARA processes and relations.

Revise objectives for those of the Applicant, only and shall be those pertinent to this project. Objectives must also be quantifiable and comparable across different alternative developments of the project. If references to financial, economic, and employment aspects of the project, then appropriate sectors must be included in the CEQA document.

The project Applicant is seeking to accomplish the following objectives with the proposed project:● To more efficiently utilize the site; and, ● To realize a fair return on their investment [ROI]."Efficiently" is not defined nor any criteria provided for numerical comparisons.ROI is mentioned but no adequate definition is provided for the Applicant, and no criterion is provided

for "realization" for this project. As the City and the Applicant have raised financial and economic analyses a part of the CEQA objectives, the MND or another CEQA document is required to provide an economic, finance, and investment assessment of the "project" including all activities and expenditure from the time that the City or applicant or investors took charge of the properties.

38/2 2.6 DISCRETIONARY ACTIONSThe proposed project will require the following approvals:● A Tentative Tract Map to subdivide the project site into two parcels;Not previously stated nor delineated in MND. Provide and clearly identify current drafts of any

potential submittals.● A Design Review for the new buildings;Provide and clearly identify current drafts of any potential submittals.● An Industrial Planned Development to ensure the project’s conformity with City standards and to permit the construction of the three new buildings within the project site (findings must be made for a project to be eligible for an IPD, the project meets these findings);The IPD application should be provided as draft to demonstrate compliance/conformity with City

standards and requirements and their relationship to mentioned "mitigation measures. Actually four new buildings, provide a listing restriction to three; provide a draft of all relevant findings.

● A Sign Program for the new on-site signs;Provide and clearly identify current drafts of any potential submittals and current restrictions.● The adoption of the Mitigated Negative Declaration and Mitigation Monitoring and ReportingProgram (MMRP).Three mentions of MMRP - above #1 and #2 MND-4/2 the adoption of the Mitigated Negative Declaration; and the adoption of the Mitigation

Monitoring and Reporting Program (MMRP).#3 IS 7/2 The proposed project will require the following approvals:...the adoption of the Mitigation

Monitoring and Reporting Program (MMRP). No Mitigation Monitoring and Reporting Program (MMRP) is provided or linked with the circulation of

the IS and MND. Delayed circulation until 011217 requires extension of public comments.

MMRP to be circulated 011217 4:38pm Wed 01/11/17 Tomorrow City staff SAY they will complete and circulate the "MMRP" Mitigation/Monitoring/Reporting Program (or Plan) for the Court Project...although it was mentioned as available in the Notice of Intent over a month ago. In other MNDs the MMRP was included as part of the MND circulation and available during the review. This is one of the few binding documents and MUST become a condition of any permit....important. Some additional mitigations in a new CEQA document must include:

1. New signalized intersection at Meridian/Mission;2. Improved lane turning at Mission/Fremont with additional bridging over UPRR 20 ft additional

on east and west sides;3. Widening of and Adding turning lanes for Fremont/ Orange intersection;4. Widening of and Adding turning lanes for Concorde/Fremont intersection;5. Widening and Right/Left turning lanes for Mission/Fremont;6. Widening of Fremont from Mission - Shorb...three lanes at least one side or both side with thin

concrete median;7. Ban curb lane parking both sides of Valley from Meridian-Fremont-Elm AND add right and left

turning lanes;8. Bus Pull-Outs along all of Fremont;9. New crossing bridges over UPRR at Palm and 10. either at Westmont and/or Westminister;11. Establish a Special Fremont Corridor Infrastructure Assessment District for Transportation

Sewerage, and Drainage from Commonwealth to Valley to Ross and 1600 feet east and west of Fremont;

12. Provide a Programmatic EIR for Fremont Corridor - Specific Plan (Update) Project including the Special Infrastructure Assessment District and the Proposed Project.

47/Exhibit 3-2 Land Coverage and Land Use Map Aerial Photo is misaligned to topographical map and does not show land coverage and land use; Exh. 2-4 is better

General Plan Update51/4 The City’s 2016 General Plan Community Profile compares and contrasts employment...

130/3 Existing Traffic Characteristics Existing peak hour traffic counts were collected at the study intersections during the weekday morning..., weekday evening..., and weekend...peak periods....While the counts were collected within the one-year timeframe at the time the traffic study was undertaken...Although references are made to the Alhambra City General Plan Update, underway 2015-2017, 2016

existing traffic characterization does not include or reference KOA Corporation studies for the traffic for the Update.

51/5 The Natelson Dale Group, Inc....completed a real estate market overview...is currently “under-represented” in office and industrial employment...new office space will achieve one of the goals set forth by SCAG by diversifying the local economic base....approximately 10 percent of City residents actually worked in Alhambra. By providing additional office space in Alhambra, the vehicle miles traveled during commuting will be reduced along with the attendant air quality impacts.\39 FN\39 Rincon Consultants, Inc. Community Profile, The City of Alhambra General Plan Update. November 2015.As the referenced studies and statement herein include economic bases for the MND, a full economic

assessment of the project must be included and the current MND is inadequate and incomplete with regard to employment, economics, and financial conditions and impacts of the proposed project.

GP-Uhttp://www.cityofalhambra.org/imagesfile/file/201601/gp_community_profile_20160114_151909.pdf58/1 KOA Corporation, a planning and engineering firm, conducted a traffic analysis for the City of Alhambra

as part of the General Plan Update,...summarized...July 2015 Summary of Existing Conditions report.58/2 The [General Plan Update] study area for this traffic analysis is shown in Figure 20. The list below

shows the streets carrying the highest volumes of traffic in Alhambra, with approximate average daily trip (ADT) trip levels available from the City’s Public Works Department: North-South Streets Fremont Avenue (about 27,000-51,000 ADT north of the I-10, with the highest ADT levels near Mission Road and Valley Boulevard).

59/Fig. 1 Intersections 11, 23, 26, 27, 28, & 34 Segments 11, 16, 18, & 19The General Plan Update (GPU) recognizes Fremont as the most congested arterial corridor in the City

with the project in the most constrained portion of the corridor, south of Concorde. Traffic setting/information/profile from GPU must be incorporated within the MND a part of the setting and but is only referenced and as part of the project's assessment and GPU and project mitigation but no consideration appears in the project MND.

The GPU will pass through a CEQA process and is scheduled to scope, prepare, and circulate an EIR in the first quarter of 2017. All information, assessment, mitigation, policies, and considerations for this project MND must be incorporated into the EIR. The stated City policy for a project to only mitigate the significant impacts created by the specific project if applied over the City appear significant and effects substantial. Use of the different criteria from different agencies within the assessment process for traffic congestion and mitigation appears to virtually impossible to apply for the CEQA process of the GPU.

Withdraw, revise, and recirculate as part of a more comprehensive EIR with adequate publicly accessible documents and references and analyses for reduction and intensification due to building location and orientation to impact sources. The GPU CEQA process must provide a Programmatic EIR and include a Project EIR for the proposed project in this CEQA process.

127/Table 3-10 Intersection Impact Significance Threshold142/2 The same intersections shown to operate at an unacceptable Level of Service under Existing Conditions would continue to do so under Opening Year Base conditions....addition of ambient growth would cause the intersection of Fremont...at Valley...to worsen from LOS D to LOS E in the PM peak hour.146/2 The project's impact at...Valley...at Fremont...would be considered significant (0.01 or greater increase in v/c...at LOS E or F in the pre-project condition) in the PM and weekend peak hours.146/4 Although the following intersections will operate at an acceptable LOS with the addition of project traffic, the project impact will exceed the significance thresholds designated by the County's significance criteria: ● Intersection #3 – Fremont Avenue at Commonwealth Avenue - (PM and Weekend Peak – LOS D in the pre-project condition, 0.02 or greater impact)● Intersection #5 – Fremont...at Orange...(PM Peak – LOS C in the pre-project condition, 0.04

or greater impact).\151The MND contains a basic assumption regarding the project and current traffic conditions and a

secondary assumption as to assumed levels for "significance" of traffic impacts:Project impacts are only those created by the project itself and have nothing to do with the current significant impact of traffic...if the project mitigates its own impacts to some level, that level is considered insignificant when added to the exiting or pre-project conditions on a project level or a cumulative level. The current project shall not be penalized for impacts of other projects and cumulative impacts allowed by the City.

The MND must incorporate a mitigation measure for the City to establish a Fremont Corridor Special Assessment District to remedy pre-project traffic conditions and incorporate a fair share for the project and other contributors to the current and future congestion.

Use of the County's criteria lessens the apparent significance of the project impacts. Provide a detailed comparison of all relevant agency criteria for traffic/street/intersection congestion: Alhambra, LACity, LACo, and SCAG.

56/EXHIBIT 3-3 NEAREST SENSITIVE RECEPTORS MAPOutdated and incorrect site map with RR line in wrong locations and must be revised.

57/2 Long-term Impacts on Sensitive ReceptorsWhen interpreting the results of the LST analysis...project’s orientation and design is an inherent mitigation....landscape buffer will be installed along the project site’s northern boundary....create separation between the parking area and the adjacent park....only 34 parking stalls will be provided in the northern portion of the site....1,336 parking stalls will be located further south within the parking structure or in the Lowe’s surface parking lot. Office Building 1 will serve as a barrier [and Building 2]...protect the adjacent sensitive receptors from vehicle emissions [and noise and glare]...adjustments were made to the assumptions programmed into the CalEEMod.Buildings 1 and 2 and northern parking have not been listed as "Mitigation Measures" for Air Quality,

Noise, and Aesthetic-light and glare especially for the residential receptors to the north and northwest.

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents and references and analyses for reduction and intensification due to building location and orientation to impact sources.

57/3 The initial air quality emissions estimates assumed an average “home to shop” or “costumer[sic] to commercial” trip distance of 8.40 miles one-way....reduced to 5.9 miles per one way trip. A reduction in the miles traveled between a costumer’s[sic] house to the Lowe’s was made because the Lowe’s is not a regionally significant project and is meant to serve the local community. Additionally, a survey was conducted using Google Earth to determine the average distances between seven Southern California Lowe’s stores. The stores are located in...Covina, San Dimas, Industry, La Habra, Norwalk, Anaheim, and Pico Rivera. The 5.9 miles...is the average of the sum of the total miles between the seven Lowe’s stores [5.9+5.9=11.8 miles]. These 5.9 miles...was inserted as a new default variable for “home to shop” trip lengths since the Lowe’s is anticipated to serve...These Lowe's sites were not included in traffic studies for Lowe's Stores, while the Poway site in San

Diego County was selected as suitable for Alhambra' site traffic movements and surveys.Lowe's and office service areas are mentioned in the MND and therefore an adequate and complete

setting and assessment of service areas and competition must be providedWithdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible

documents and references and analyses for customers' and users' service areas and related competition for the project facilities and services.

64/3 Based on a review of available historical documents, the subject property was originally developed between 1925 and 1928 with seven industrial structures...The MND is inadequate and incomplete as it does not include and assess available digital aerial photo

composites of the Alhambra city in 1923 and 1928 which have proven useful for hazardous industrial materials, cultural historic resources, and land use developments in adjacent portions of LACity, El Sereno.

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents and references and analyses for hazardous materials source and potential contamination, prospective historic land uses and cultural remains, and the actual physical configurations and locations and some activities based on direct photographic evidence.

64/4 All of the on-site improvements were razed by 2013\53 Since the site is largely undeveloped and contains no historic resources, no impacts will result from the project’s implementation.The site was largely developed and was used for residential and rural purposes before 1925 based on

EDR aerial photos. Many LA sites have yielded historic resources including cemeteries and human remains, "garbage pits", and soil toilets when more recent structures have been removed.

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents and references, assessments, and analyses for potential, prospective historic cultural remains, and direct record of land uses. Series of historic aerial photos are available from 1923 to after 1953.

66/3 The likelihood of the discovery of such materials will increase where the excavations will extend into the Older Quaternary Alluvium. Given the proximity of past fossil discoveries in the surrounding area and the underlying alluvial fan deposits, the project site is moderately to highly sensitive for supporting paleontological resources....have the potential for destroying a unique paleontological resource or site. In the absence of mitigation, the potential damage to paleontological resources or sites during construction would be a potentially significant impact. Therefore, the following mitigation is required:● Prior to commencement of any grading activity on site, the Applicant shall retain a qualified paleontologist, subject to the review and approval of the City’s Development Services Director, or designee.As clearly indicated by the current site setting, the City has not met such mitigation measure for more

than ten year and has allowed the ite to be excavated, buried, graded, and bored with utter disregard to the potential for archaeological, historic, and paleontological resources. Proposed subsurface infrastructure and protective membrane barriers and venting systems have a high potential for encountering resources and mitigation plans for each sector must be formed and presented as drafts for consideration and comment within assessment for each sector and as parts of the MMRP.

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents, references, assessments and analyses for potential resources and mitigation of adverse effects and preservation of such resources.

67/3 As a result, the following mitigation is required:None for historic resources, although above comments have demonstrated that such is required but

could be more focused by review of aerial photos of the project site.Mitigation Measure No. 11 (Cultural Resources Impacts). The project Applicant will be required to obtain the services of a qualified Native American Monitor during construction-related ground disturbance activities....The monitor(s) must be approved...and will be present on-site during the construction phases...on-site monitoring shall end when the project site grading and excavation activities are completed...Use of "will", "must", and "shall" in the same paragraph clearly demonstrates the preparers and

reviewers lack of experience and training in development of contractual mitigation measures for CEQA, epecially when compared with the next measure/paragraph with all "shall".

Mitigation Measure No. 12 (Cultural Resources Impacts). ...Applicant shall retain a qualified paleontologist, subject to the review and approval of the City’s Development Services Director, or designee. The qualified paleontologist shall be on-site during grading and other significant ground disturbance activities that impact Pleistocene alluvial deposits,...depths below six feet. The monitoring shall apply...where excavation shall extend at depths of six feet or more.Without a clear contractual document and MMRP and without any provisions for real time enforcement

and penalties, the mitigation statements herein this MND may be as required by regulation but there is little confidence in their effective implementation, monitoring, reporting, and achievement of mitigation to less than significant damages.

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents, references, assessments, analyses, and enforcements for mitigation of adverse effects and preservation of such resources.

68/1 ● The exposure of people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving...ground-shaking, liquefaction,...including location on a geologic unit or a soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site..., lateral spreading, subsidence,..., or...;No information is provided as to the historic records of measurable seismic events within and under

the project site or the City, although they are available on-line at the So.Cal.Earthquake Data Center (http://scedc.caltech.edu) back to 1932 along with known active faults associated thereto.

69/EXHIBIT 3-4 REGIONAL FAULT MAPErroneously locates a "Project Area" west of Meridian and only locates one named AP-Eq fault in and

under South Pasadena rather than Alhambra.Then erroneously refers the source of the map to the USGS including the fault zone, which was the

Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist using the USGS map as its base..

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents, references, assessments, and analyses of recorded seismic events within Alhambra and those of >3 RM within 5 miles of the project site.

70/2 In addition, the project site is not located in an area that is subject to liquefaction (refer to Exhibit 3-5).According to the United States Geological Survey, liquefaction is the process by which water-saturatedsediment temporarily loses strength and acts as a fluid.The exhibit is from the California Geological Survey (EXHIBIT 3-5 LIQUEFACTION POTENTIAL,

Source: California Geological Survey) and does not mention nor recognize the display of rural watershed features found in 1923 aerial photos of the site and drainage ways to the southwest to Concorde and Mission Road/Alhambra Ave..

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents, references, assessments, and analyses of the watersheds and potential liquefaction areas within Alhambra and the project site, area, or vicinity.

71/EXHIBIT 3-5 LIQUEFACTION POTENTIAL Source: California Geological SurveyHere erroneously locates a "Project Site" west of Meridian.

83/3 The site is currently in the process of being evaluated by the...Control Board for a soils-only closure. Groundwater monitoring is anticipated to continue.No specific information is provided to assess the significance of the "evaluation", significance of the

project to continuing "evaluation", or impact of the project or continuing contamination of the project due to site, area, and vicinity conditions. This groundwater monitoring for contaminants is not mentioned in the MMRP.

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents, references, assessments, and analyses of evaluations of the soil, groundwater, source, and flows/gradients related to contamination sources within the gradient flow regime of the project site.

83/3-BulPt2 The database search identified one TSD facility within a 0.5 mile radius of the subject property, but down gradient of the subject property.\75 ibid\75 URS Corporation. Phase I Environmental Site Assessment for the International Extrusion Corporation Property. Phase I dated April 29, 2010.84/1 The database search identified five RCRA small quantity generators (SQG) upgradient of the project site.Preparers do not define "gradient" and what the importance of gradient flow is to the project and to

TSDs and SQGs.The footnoted reference is not accessible to the Public and thereby renders the assessment, findings,

and commenting inadequate and incomplete. Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible

documents and references.

87/4 Between May 25 and June 12, 2015, N&N oversaw the excavation of the contaminated area, and approximately 5,700 cubic yards of soil were removed from an area of 90 feet by 150 feet at surface, narrowing down to 30 by 90 feet at 20 feet bgs.88/2 N&N also undertook soil borings to 75 feet bgs, collected soil samples at total depth, and installed soil vapor probes at 75 feet bgs at each location. VOCs were not detected in the soil samples.The contaminated area is presumably in the Project site and perhaps the excavated soil and cultural

remains and fossils therein are still on the site. The MND does not identify or delineate the excavated site or current location of excavated material and does not identify and assess the impact of such to the project or urrounding receptors.

The N&N footnotes and references do not provide accessible for the Public and thereby renders the assessment, findings, and commenting inadequate and incomplete.

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents and references.

89/1 ● Installation of Vapor Barrier and Passive Vent System....reduce the (upward) mobility of VOCs that may pose a vapor intrusion risk, and reduce their mass (by venting) in the underlying soil....remedial option provides long-term protection from VOCs potentially migrating upward from the deep silt and clay layers (below 30 feet bgs).\94 \94 GSA Engineering, Inc. Draft Supplemental Remedial Action Report and Feasibility Study – Shallow Unsaturated Zone. February 24, 2016.The preparers apparently have no experience with such measures and systems. The vent system does

not reduce the upward mobility of VOCs but actually promote the gradient flow from the soil to the free atmosphere. The system assures, if properly designed and installed, that the VOCs do not go into occupied buildings.

No discussion is presented about the migration upward and laterally of VOCs under the parking structure or under the asphalt of surface parking; lateral VOC migration does occur through the bedding and other materials until gases may reach a drainage or other pathway to the free air.

Elsewhere the system is stated to be a mitigation measure rather than a "remedial option"The N&N footnotes and references do not provide accessible for the Public and thereby renders the

assessment, findings, and commenting inadequate and incomplete. Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible


89/2 ...mitigation is required...to reduce potential exposure to intrusive vapors once the project is operational....:● A vapor barrier and underlying passive vent system must be installed beneath the proposed buildings in the affected area where the vapors are remaining. The presence of vapor barriers combined with passive sub-slab venting and engineered air flow inside the buildings will minimize the potential exposure of workers to VOCs due to vapor intrusion to indoor air.No delineation of "affected area" and no definition of "proposed buildings" (2, 3, or 4) are provided. This statement also includes- No definition or criteria for "minimize" are provided. Does the barrier also protect the construction

workers from out-gassing of VOCs before the vent system is installed. No estimate of the VOCs releaed by the vents are provided and no measures are included to crub the

gases before they are released to the local mixing layer.The MND does not provide accessible documents, analyses, or mitigation evaluations for the Public

as to the venting of VOCs and thereby renders the assessment, findings, and commenting inadequate and incomplete.


89/2 ● The Applicant will continue to clean up the site...and seek a soil-only closure with deed restriction for a portion of the project site APNs 5342-030-009 and 5342-031-001).Venting to the local mixing air is not "clean up" but only the underlying contaminated soil to a

regulated level of contamination.

No delineation of "a portion" of the site is provided; the statement is incomplete and inadequate for supporting a less than significant assessment.

The MND does not provide accessible undertandablle summaries, documents, analyses, or mitigation evaluations for the APNs 5342-030-009 and 5342-031-001 to allow Public review as to the "Clean Up" of the site where ever it may be and venting of VOCs to the local atmosphere and thereby renders the assessment, findings, and commenting inadequate and incomplete.


89/3 Adherence to the mitigation identified above will reduce potential impacts to levels that are less than significant.As indicated for this section of this sector, mitigation is inadequately defined and delineated as to

VOCs and PCE in the groundwater, in the soil above the groundwater and upto the surface, and dispersion through a "remedial option" into the free local atmosphere. No criteria levels are provided for adherence to or compliance with.


89/4 The project’s implementation will require the export of the underlying soils. Thus, contaminated soil may be encountered on-site during the construction period. The removal and transport of contaminated soil may pose a risk to the surrounding area in the absence of mitigation....must adhere to the recommendations outlined in the soils management plan, which identifies specific requirements.... Adherence to the mitigation identified in subsection 3.8.2.A will reduce potential impacts to levels that are less than significant.Inadequate definitions as to "remedial options", "recommendations", "outlines", "specific

requirements" renders the sector section and the MND inadequate and lack of an accessible draft of the SMP renders the document incomplete.

A soil management plan (draft for approval) is not provided for review and therefore no finding can be made or reviewed.


90/4 The U.S. EPA's National Priorities List (NPL)...project site is listed as an NPL site...one NPL site within one mile of the project site that is the San Gabriel Valley NPL Site, located up gradient approximately 1,000 feet southeast of the subject property....regional groundwater plume contaminated with chlorinated volatile organic compounds (VOCs), and is currently undergoing site investigation and remediation. Here and elsewhere "gradient" is mentioned without context, definition, and significance to the sector

and the environment of the project site..Reference to site investigation and remediation apparently applies to the NPL site 1000ft SE of the

project site or "subject property" but no maps or accessible references are provided. Distance and direction would place the NPL ite under the UPRR or The Alhambra. Statement regarding gradient, direction and distance would indicate that the groundwater is flowing from SE to NW and the project site ("subject proerty") and that contamination may occur under the City's streets and the adjacent west side commercial "properties" before it arrived under the project site.

As indicated for this entire sector assessment, information, findings, and assessments and required mitigation is inadequately defined and delineated. No criteria levels are provided for adherence to or compliance with. The sector assessment appears to be written without consideration to inform and Public and to to promote Public review and comment.


90/4 The project site was investigated by the Los Angeles RWQCB as a potential source to this plume in 2000, as described in above; and a No Further Action (NFA) letter was issued by the agency,.... Recently however, the NFA letter was withdrawn. The statement renders the sector analyses as inadequate as to hazardous contamination under the

project site or project area or within the gradient flow shed.


90/4 Although the regional depth to groundwater is approximately 250 to 300 feet bgs, this regional plume may represent a REC to the subject property.As the findings appear to show that gaseous contamination of the soil beneath the project site maybe

contaminated by gaseous releases from the groundwater plume the depth would indicate that a significant volume of gas exists beneath the project and active gas extraction which had been done before should be continued throughout the life of the project a an appropriate mitigation measure.

The statement renders the sector analyses as inadequate as to hazardous contamination under the project site, project area, or subject property, or above the gradient flow shed.


91/6 At no time will Meridian Avenue or Fremont Avenue be completely closed to traffic. The construction plan must identify specific provisions for the regulation of construction vehicle ingress and egress to the site...as a means to provide continued through-access....As a result, no impacts are associated with the proposed project’s implementation.A site or project or construction management plan is required, and a draft must be accessible for the

Public to conduct an adequate and complete review and to prepare meaningful comments.Part of such a plan would include all vehicular access to the site and their route to and from the

entrance to the I-710 freeway and prohibition and high penalties for any construction vehicle passing on or across Concorde on the north and Fremont south of Valley.

All construction vehicle access must be via Meridian Ave., not Fremont, and all truck access must be prohibited from Fremont to/from the Site.

The lack of any draft or content of the Project Management Plan renders the MND analyses as inadequate and incomplete.


92/2 Mitigation Measure No. 14 (Hazards & Hazardous Materials Impacts). A vapor barrier and underlying passive vent system must be installed beneath the proposed buildings in the affected area where the vapors are remaining. The presence of vapor barriers combined with passive sub-slab venting and engineered air flow inside the buildings will minimize the potential exposure of workers to VOCs due to vapor intrusion to indoor air.No delineation of "affected area" and no definition of "proposed buildings" (2, 3, or 4) are provided. This statement also includes: No definition or criteria for "minimize" are provided. Does the barrier also protect the construction

workers from out-gassing of VOCs before the vent system is installed. No estimate of the VOCs released by the vents are provided and no measures are included to crub

the gases before they are released to the local mixing layer. No comparisons of passive v active vent systems has been provided and the vent system must be

assessed for effectiveness and include active air flows and treatment of air flow before reaching free surface air.

The MND does not provide accessible documents, analyses, or mitigation evaluations for the Public as to the venting of VOCs and thereby renders the assessment, findings, and commenting inadequate and incomplete.


MND 92/2 Mitigation Measure No. 15 (Hazards & Hazardous Materials Impacts). The Applicant will continue to clean up the site under the oversight of the Regional Water Quality Control Board and seek a soil only closure with deed restriction for a portion of the project site (APNs 5342-030-009 and 5342-031-001).Venting to the local mixing air is not "clean up" but only the underlying contaminated soil to a

regulated level of contamination.

No delineation of "a portion" of the site is provided; the statement is incomplete and inadequate for supporting a less than significant assessment.

The MND does not provide accessible undertandablle summaries, documents, analyses, or mitigation evaluations for the APNs 5342-030-009 and 5342-031-001 to allow Public review as to the "Clean Up" of the site where ever it may be and venting of VOCs to the local atmosphere and thereby renders the assessment, findings, and commenting inadequate and incomplete.


MND 133/2 ...to evaluate intersection operating conditions with the proposed project, trip generation estimates ...Daily and peak hour trips for the office use were estimated using trip generation rates...(ITE) Trip Generation Manual (9th Edition) Land Use category 720 – General Office....Lowe's home improvement store, the daily trips are based on the ITE rates for Land Use category 862 – Home Improvement store....Lowe's peak hour trip generation rates are based on actual driveway traffic volume data collected at an existing Southern California Lowe's store located at 13750 Poway Road in the City of Poway, California....technical study, Trip Generation Rates for Lowe's Development (Crown City Engineers, Inc., March, 2016) [Apdx C]. The analysis methodology, justification, and technical backup, along with recommendations by the study traffic engineer, were submitted to the City prior to completing the analysis. \143 133/FN 143 Kimley-Horn and Associates, Inc. Traffic Impact Study for the Proposed Lowe’s and Office Development in the City of Alhambra. October 2016.


134/Table 3.12 Footnote \1 Lowe's Rate: Peak Hour Trip Generation Rates are from driveway counts at...Lowe's..., Poway, CA 92064. Daily trip generation rates are from the Institute of Transportation Engineers CITE) [sic]...9th Edition. A 20% pass-by trips was assumed, per regional guidelines, such as City of L. A.'s Traffic Study Policy and Procedure stores and garden centers,...recommends the use of 20% pass-by trips... hardware/lumber Office Rate: Institute of Transportation Engineers (ITE).... 134/Table 3.12 Footnote \2 A 10% mode shift credit was assumed ridesharing, biking, and walking. for office trips to account for the use of alternative travel modes, such as public transit, carpooling, ridesharing, biking, and walking.No reference other than assumed by preparers/reviewers and without technical backgrounding.Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible


148/2 Adherence to the mitigation identified in the aforementioned subsection will reduce potential impacts to levels that are less than significant."Adherence to" is not the same as "compliance with" and assumed reduction is why the MMRP wa

required. An MMRP must have:Mitigation REQUIRED and described at at least Preliminary Engineering levels;Monitoring to ASSURE planned/scheduled implementation and operation and funding;Reporting to demonstrate measures achieved reductions and if needed additional or prolonged

mitigating was conducted to achieve the criterion for "less than significance".Plan - written, scheduled, with significance criteria which can be monitored.

Without an adequate and complete MMRP the MND is totally inadequate and incomplete, and delayed circulation of the MMRP any adherence or compliance of mitigation cannot be reviewed or supported.

Extend the public review period of the MND for 30 day following the circulation of the MMRP on 01/12/17. OR

Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible documents and references and with a Draft MMRP in the DEIR.

Appendices A-F pdf-286 Apdx. C Trip Generation Rates For Lowe’s Development Fremont Avenue Alhambra, California

Lowe's Trip Generation Rates is for a stand-alone store in Poway, SDCo, CA unrelated to LACo conditions.

Appendix F Projected 2035 Traffic Volumes....SR-710 ExtensionNot included in references and all documents are not publicly accessible to confirm findings and

summary, Apdx. F.Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible


154/1 Other Requirements As stated previously, the project Applicant must prepare a construction traffic management plan to minimize the disruption of traffic flow....must install the right-turn overlap for the westbound approach at the Fremont Avenue and Valley Boulevard intersection...must install traffic signal for the Mission Road and Meridian Avenue intersection.Three measures are mentioned but no draft Contr.Traf.MgmtPlan has been provided or linked,

therefore the sector assessment is incomplete and inadequate and not appropriate for CEQA assessment.


155/2 Transportation Demand Management The project Applicant will be encouraged to implement a Transportation Demand Management (TDM) measures as a part of project development, and provide incentives to take public transportation system,...measures and incentives, if implemented, could include the following elements:● Partial transit fare reimbursements,● Providing shuttle service between the Gold Line station and the office,● Bus stop improvements,● Preferential carpool and vanpool parking,● Carpool/vanpool drop-off and pick-up zones,● Guaranteed ride home program,● Secure bicycle parking areas,● On-site transportation information area for local transportation providers. The information area should be located...:a bulletin board, display case or kiosk displaying transportation information, such as:- Current maps, routes and schedule for public transit routes serving the site,- Telephone numbers for the regional ridesharing agency and local transit operators,- Ridesharing promotional material supplied by commuter-oriented organizations,Lengthy discussion of encourage and have potential measures: TDM, transportation incentives,

partials, provisions, preferentials, guarantees, and secured, are totally inadequate and incomplete. Measures require numerical/quantitative requirements and full commitment of the "Applicant" and their inclusion in the MMRP; these step have not been followed.

Measures/Incentives are mentioned but not provided or linked, therefore the sector assessment is incomplete and inadequate and not appropriate for CEQA assessment.


163/1 As the results indicate, the increase in V/C ratio by project traffic alone would exceed the significance thresholds of project-related impacts at the intersection of Valley Boulevard and Fremont Avenue....will also be considered deficient and have a cumulative impact under Cumulative Conditions (with Project and Cumulative Projects traffic)....mitigation measures are required...to improve the Level of Service to the pre-project condition or better, and the project is required to participate in implementing the improvement on a fair-share basis.163/2 ...unsignalized intersection of Mission Road and Meridian Avenue...expected to operate at an unacceptable Level of Service (LOS F) during the AM and PM peak hours under Opening Year withProject and Cumulative Conditions....signalization will be considered as a mitigation measure to improve the intersection to the pre-project Level of Service or better.

No details or drawings/plans for such "mitigation measures" have been provided and therefore no performance analyses or monitoring can be undertaken therefore the measure is inadequate and incomplete.

No details or measurements are available for "Pre-Project" 2016/2017 levels for such "mitigation measures" to less than pre-project levels" cannot be adequately or completely judged.

No specific City policy has been referenced as to general application to all project developments rather than just this project; such a policy require substantial back-grounding and judicial support to allow future projects to only address the impacts of a current proposed project while avoiding cumulative substantial and significant impacts.


163/2 Mitigation Measure No. 31...Applicant must implement a right-turn overlap for the westbound approach at the Fremont Avenue and Valley Boulevard intersection.Mitigation Measure No. 32...A traffic signal must be installed at the new Driveway C [1] and Fremont Avenue and at the intersection of Mission Road and Meridian Avenue [2].No details or drawings/plans for such "mitigation measures" have been provided and therefore no

performance analyses or monitoring can be undertaken therefore the measure is inadequate and incomplete..


166/2 The addition of...runoff controls will ease the potential strain placed on the existing system by excess runoff because the above-mentioned runoff controls will limit the amount the water that will be discharged....impacts...less than significant.No details or drawings/plans for such "runoff control measures" have been provided and therefore no

performance analyses or monitoring can be undertaken therefore the measure is inadequate and incomplete.

Controls, eases, potential strain, limits, and amounts are undefined and perhaps undefinable and therefore cannot be implemented in manner to achieve appropriate mitigation to a level of insignificance.

Provide a thorough runoff assessment, the appropriate detention/retention measures, and potential excess for a 1%/1 in 100 24hr storm event, and the assess impact of the artificially recharged runoff on the underlying groundwater table (perched and normal) beneath the project ite.


167/1 Even though the demand for water...will not exceed City water supplies, the proposed project should incorporate features that aim to reduce water consumption...following mitigation has been recommended:/2 Adherence...will mitigate potential impacts to levels that are less than significant.Use of "should", áim", "consumption, and "recommended" render the discussion meaningless,

inadequate, and incomplete. Withdraw, revise, and reissue the CEQA document as a full EIR.Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible


168/3 3.17.4 MITIGATION MEASURES...mitigation would be required to address potential impacts to water consumption....:Mitigation Measure No. 33 (Utilities Impacts). ...Applicant will be required to install Xeriscape,...as an alternative to traditional landscaping and turf, subject to review and approval by the Development Services Department and the City’s Design Review Body. For assured implementation of mitigation measures all mitigation measures must include the verrb

SHALL and be included as a permit condition and monitored and reported on in the MMRP. Use of any conditional, "will", or "must" must be removed and replaced by "SHALL" as below.

Withdraw, revise, and reissue the CEQA document as a full EIR.

Mitigation Measure No. 34 (Utilities Impacts). ...Applicant shall install high-efficiency,...toilets in order to reduce water consumption....shall also install WaterSense faucets in all restrooms,....Here the measures are given force of contract/regulation which are proper for mitigation measures

and highlight other unenforceable uses of "would" and "will".Withdraw, revise, and reissue the CEQA document as a full EIR..

5.1 PREPARERSBlodgett Baylosis Environmental Planning 16388 E. Colima Rd., Suite 206J Hacienda Heights, California 91745 Marc Blodgett, Project Manager Bryan Hamilton, Project Planner Liesl Sullano, Project PlannerAs indicated by the many comments, the preparers of the CEQA documents and the City reviewers

and approvers do not appear to have the technical training, experience, and qualifications to undertake the CEQA related activities for this MND.

The entire document NOI, IS, and MND and related studies and reports appear to be inadequate and incomplete and require major revisions and upgrades to a full and comprehensive EIR, including draft MMRP and a thorough development of alternatives. The EIR should be a Programmatic EIR for a Fremont Specific Plan with this project as a sample Project EIR within the programmatic setting and framework.

NOI 1/1 references MMR Program and will be incorporated to reduce impacts to level of insignificance.NOI references MMRP a being circulated but was not provided to public until 011217.

171-172 5.2 References References not available to public and no internet links were provided173/Appendices A-E No F not provided.

215/Appendix C 215-256/GSA Engineering, Inc. Draft - Supplemental Remedial Action Report and Feasibility Study - Shallow Unsaturated Zone 022416 (REMEDIAL ACTION REPORT)256/9 ReferencesThe reference is not available to public and is only a DRAFT, rendering it subject to change.Withdraw, revise, and recirculate as a comprehensive EIR with adequate publicly accessible


Documents

CITY OF ALHAMBRA ALHAMBRA CITY PLANNING ...€¦ · Web viewA soil management plan (draft for approval) is not provided for review and therefore no finding can be made or reviewed