333 W. Ocean Boulevard, 4th Floor Long Beach, CA 90802 (562) 570-5237 FAX (562) 570-6205

February 22, 2013

Mr. Joe Colombo Community Development Director City of Hawaiian Gardens Community Development Department 21815 Pioneer Boulevard Hawaiian Gardens, CA 90716

RE: Draft EIR for Hawaiian Gardens Casino Redevelopment Project Dear Mr. Colombo: The City of Long Beach appreciates the opportunity to review and comment on the Draft Environmental Impact Report for the proposed Hawaiian Gardens Casino Redevelopment Project (SCH 2011061061). The City submits the following comments on the Draft EIR: 3.4 The Project 1. The project objective that states “Provide adequate parking for patrons and employees by maximizing on-site grade-level parking solutions and utilizing off-site parking resources if needed” is unrealistic, given the size and scope of the proposed casino. 4.6 Transportation and Traffic 1. We appreciate that the traffic study analyzed the two additional intersections in Long Beach as outlined in our July 20, 2011 correspondence commenting on the Initial Study for the Draft EIR. However, considering that the Carson Street and Los Coyotes Diagonal intersection was found to be impacted by the project, the City respectfully requests that the traffic study be expanded to include the intersection of Carson Street and Palo Verde Avenue. In addition, the City supports the City of Lakewood’s July 18, 2011 request for additional intersections to be analyzed in that City. 2. The traffic study uses a calculated trip generation rate for the project based on driveway counts at the existing casino facility. The calculated rates are on the order of 7 trips per thousand square feet of gaming floor area in the morning peak and about 17 trips per

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thousand square feet of gaming floor area. These trip numbers seem low and it is unclear how these trip rates compare to other comparable California casinos. The City requests that the traffic study be amended to provide some background information on other similar casinos in the Los Angeles area to justify the trip generation rate used for the proposed project. 3. Based on a review of the proposed parking layout and operations plan by City traffic engineers it is likely that the casino operator has under estimated both the demand for parking and the operational complexities of a peak period valet operation that may have to process an excess of 20 vehicles (combined inbound and outbound) a minute over a sustained period of time. If the valet operation is not complimentary, or free, and operated in such a fashion to return 95% or greater of customer vehicles within 5 minutes, it is likely that surrounding business and residential communities will suffer overflow parking impacts from the project. Providing such a valet service will be extremely costly; therefore, it is strongly suggested that the City of Hawaiian Gardens consider requiring the casino to construct a large self-parking garage to accommodate the expected traffic and parking demands outlined in the study. 4. It is likely that the projected number of employees for the expanded casino is underestimated when taking into consideration the current number of employees and the number of employees that will be required to operate the planned extensive and complex valet parking program. Furthermore, it is unlikely that ridesharing rates will be as high as expected for employees due to security concerns and the nature of casino operations. 5. The City does not support the implementation of Mitigation Measure 4.6.A-2. The proposed improvement would eliminate eastbound u-turns, forcing motorists wishing to return to the freeway or patronize businesses on the northside of Carson Street to drive approximately a half-mile away to make a u-turn. 6. It is unlikely that Mitigation Measure 4.6.A-3 will be successful at attaining a 10% total reduction in trip generation rates over the existing casino operation. Casino operations are such that they do lend themselves well to alternative travel modes for patrons or for employees. Most patrons arrive at a casino independently since their length of stay is somewhat indeterminate due to the nature of gaming. Additionally, many casino employees also have somewhat indeterminate work hours based on casino activity levels and security measures. Unless documentation can be provided that other California casinos have implemented ridesharing programs capable of attaining trip generation reductions in excess of 10% of total trips for both patrons and employees, we reject this mitigation measure and respectfully request that an alternative physical mitigation measure be developed to address the project traffic impacts at the intersection of Carson Street and Los Coyotes Diagonal. 7. It is likely that the traffic study underestimated the number of trips using Pioneer Boulevard south of Carson Street to access the casino. The City requests additional

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documentation to support the traffic study assumption regarding traffic on Pioneer Boulevard south of Carson Street and into Long Beach. 5.4 Alternatives Considered but Rejected 1. Alternative 5: On-Site Parking Structure should be given more serious consideration rather than being rejected. An on-site parking structure would increase the cost of the proposed project but would ultimately save money in the long run. If the applicant’s intent is to create a destination casino that could eventually host poker tournaments and other high profile events, the parking scheme presented in the Draft EIR is grossly inadequate and presents as a “cheap fix” to the parking issue. Asking a developer to provide adequate on-site parking to accommodate their proposed project is a fundamental zoning requirement. The applicant should acknowledge the magnitude of the project’s impacts and incorporate an on-site parking structure that will provide convenient and secure covered parking for patrons and employees of the proposed casino. The City of Long Beach would like to thank the traffic engineering subconsultant for their willingness to meet with City staff regarding the project’s traffic and parking issues. And, again, we appreciate the opportunity to participate in the CEQA process for the proposed project. Sincerely,


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